1.6 Gasoline Dispensing/Motor Vehicle Refueling Facilities Permitting Process
When new Gasoline Dispensing/Motor Vehicle Refueling Facilities (GD/MVRFs) are planned for installation at BWI Marshall and Martin State Airports, a General Permit to Construct Motor Vehicle Refueling Facilities must be obtained from MDE/ARMA if the facility will dispense gasoline into the tanks of motor vehicles and have a gasoline storage tank larger than 2,000 gallons. Multiple tanks at the same location are considered a tank farm and only one permit is required for all the tanks in the tank farm. Preparing the applications for such permits is the responsibility of the Consultant.
The emission sources to which these regulations apply are gasoline storage tanks larger than 2,000 gallons and their associated equipment components in vapor or liquid gasoline service, including pressure/vacuum vents on storage tanks and equipment necessary to unload product from cargo tanks into the storage tanks. Equipment used for refueling motor vehicles is not deemed an emission source under these regulations.
No General Permit to Construct is required for the storage of diesel fuel, kerosene, jet fuel, or fuel oils. However, the Consultant must inform/notify MDOT MAA’s Environmental Compliance Section with the appropriate information that will be necessary to update the Oil Operations Permit (OOP) for newly acquired permanent tanks greater than 10,000 gallons which store oil (includes but is not limited to the following: asphalt, gasoline, ethanol that is intended to be used as a motor fuel or fuel source, kerosene, aviation/jet fuels, diesel fuel, biodiesel fuel regardless of whether the fuel is petroleum based, used oil, waste oil, lubricating oils, hydraulic oil, mineral oil, and all heating oils) through MDE. Consultant must also provide sufficient information to allow for update and PE review/stamp of the Spill Prevention Control & Countermeasures (SPCC) Plan and the Stormwater Pollution Prevention Plan (SWPPP). Additionally, Form A and Form M92 must be completed prior to use of the tanks and can be found on the MDE Land Permit Applications and Instructions web page.
1.6.1 Permitting Requirements for GD/MVRFs
The Consultant shall be responsible for completing the Air Quality General Permit to Construct Application Package for Motor Vehicle Refueling Facilities, including the Request for Coverage Form (Form No. MDE/ARMA/PER.006). The Application Package can be obtained by calling MDE/ARMA at (410) 537-3230 or downloading from the MDE Air Quality General Permits to Construct Application Forms web page.
The Application Package shall be submitted to the MDOT MAA Environmental Compliance Section in the Office of Environmental Services. MDOT MAA shall be responsible for signing and submitting the Application Package to the MDE/ARMA. In addition, the MDOT MAA is responsible for paying the $200 permitting fee (payable to MDE Clean Air Fund) that must accompany the Application Package. If the MDOT MAA is notified that any permit application is deemed incomplete, the Consultant shall take immediate action to rectify the situation and submit the appropriate documents to MDE/ARMA.
Coverage under the General Permit to Construct begins on the day a complete Application Package (as determined by MDE/ARMA) and full payment of the permitting fee is submitted to MDE/ARMA.
1.6.2 Design Guidelines for GD/MVRFs
1. The Consultant shall be responsible for preparing all Application Packages and submitting the appropriate documentation to the MDOT MAA for all required permits and exemptions as defined above. In addition, the Consultant shall specify equipment that meets all State and Federal air quality requirements.
a. Specifications for all GD/MVRFs requiring permits shall include:
· Notification that a General Permit to Construct the equipment is required;
· Designation of the "Owner” or “Owner's Agent" as the party responsible for completing the Application Package;
· A statement that Coverage under the General Permit to Construct begins on the day a complete Application Package (as determined by MDE/ARMA) and full payment of the permitting fee is submitted to MDE/ARMA. MDE/ARMA will reply with a letter acknowledging the receipt of the Application Package and fee payment, which must be retained along with the General Permit to Construct document.
2. Stage I and II Vapor Recovery
· Stage I vapor recovery systems capture the gasoline vapors emitted when a tank truck refills the gasoline storage tank and is required for all gasoline storage tanks larger than 2,000 gallons.
· Stage II vapor recovery systems capture gasoline vapors lost during vehicle refueling at the pump. Stage II vapor recovery is required for gasoline tanks larger than 2,000 gallons and facilities with a monthly throughput greater than or equal to 10,000 gallons in the following areas: Baltimore City, Anne Arundel, Baltimore, Calvert, Carroll, Cecil Charles, Frederick, Harford, Howard, Montgomery, and Prince George’s counties.
3. Permitting and compliance requirements for GD/MVRFs are dependent on various thresholds of monthly throughput of gasoline, where monthly throughput is defined as the total volume of gasoline during a month as calculated on a rolling 30-day average. The Consultant shall be responsible for determining the projected throughput threshold, discussed below, that will drive design specifications and notification requirements to comply with state requirements as well as Federal requirements under 40 CFR Part 63 Subpart C. Please refer to Chapter 10 “Environmental Procedures and Requirements” for notification, recordkeeping, and reporting requirements.
4. Monthly Throughput of Less Than 10,000 Gallons – The Consultant shall specify a vapor balance line to load product into gasoline storage tanks per Part II.A(1)(a)(i) of the Air Quality General Permit to Construct Application Package for Motor Vehicle Refueling Facilities. Additionally, the Consultant shall specify a submerged fill pipe no higher than 6 inches from the bottom of the storage tank for loading product into the storage tank. Other specifications as necessary must be incorporated to minimize vapor releases, such as those that minimize gasoline spills, allow for expeditious cleanup of gasoline spills, use of gasketed seals for gasoline containers and storage tank fill pipes, and minimize product being sent to open waste collection systems that collect and transport gasoline to reclamation and recycling devices such as oil/water separators.
5. Monthly Throughput of 10,000 Gallons or More – The Consultant shall specify identical requirements as above for monthly throughput of less than 10,000 gallons. In addition, in order to comply with Subpart CCCCCC, all storage tanks at or above 250 gallons shall be loaded using submerged fill (drop tubes).
6. Monthly Throughput of 100,000 Gallons or More
a. The Consultant shall specify identical requirements as outlined above in the section for facilities with monthly throughput of 10,000 gallons; in addition, in order to meet the requirements of Subpart CCCCCC, the facility must either (1) operate a vapor balance system that meets a specified enforceable State, local rule or permit or (2) operate a vapor balance system during storage tank loadings, test the system periodically to make sure it works correctly, and includes specific equipment or work practices according to the rule, or meets 95% control.
b. Because BWI Marshall and Martin State Airports are located in Anne Arundel and Baltimore County, respectively, the Consultant must specify Stage II vapor recovery equipment for all new sources.
· For Stage II vapor recovery equipment, the Consultant shall specify instructional signs, to be placed in conspicuous locations at each gasoline dispenser, that include instructions and illustrations for inserting and removing the nozzle and dispensing product, warn against attempts to continue refueling after automatic shut-off of the gasoline occurs (i.e. “topping off”), and that display the MDE/ARMA’s toll-free number for submitting complaints or comments regarding use of the Stage II vapor recovery system.
c. If the GD/MVRF had a permit for gasoline storage tanks issued before January 10, 2008, the facility is deemed to be in compliance with the following requirements. If not, the Consultant must specify the following (note: these requirements do not apply to gasoline storage tanks equipped with a floating roof or equivalent):
· A vapor balance system having vapor connections and lines that are equipped with closures that seal upon disconnect, and a vapor line between the storage tank and cargo tank that is vapor-tight to 100% of the Lower Explosive Limit (when measured with a combustible gas detector, calibrated with propane, at a distance of one inch from the source). The vapor balance system must not allow the pressure in the tank truck to exceed 18 inches water pressure or 5.9 inches water vacuum when transferring product. All vapor recovery adaptors and connections must be designed to prevent over-tightening or loosening of fittings during normal product delivery.
· If a gauge well separate from the fill tube is specified, it must be provided with a submerged drop tube that extends no more than 6 inches from the bottom of the tank. Liquid fill connections must be equipped with vapor-tight caps.
· Pressure/vacuum (PV) vent valves shall be specified for the storage tank vent pipes. The pressure specifications for PV vent valves must be a positive pressure setting of 2.5 to 6.0 inches of water and a negative pressure setting of 6.0 to 10.0 inches of water. The total leak rate of all PV vent valves at the GD/MVRF must not exceed 0.17 cubic foot per hour at a pressure of 2.0 inches of water, and 0.63 cubic foot per hour at a vacuum of 4 inches of water.
· The vapor balance system must be capable of meeting the static pressure performance requirement of the following equation:
Pf = 2e-500.887/v
Where
Pf = Minimum allowable final pressure, inches of water
v = Total ullage affected by the test, gallons
e = Dimensionless constant equal to approximately 2.718
2 = The initial pressure, inches water; and
· For new or reconstructed facilities, or new storage tank(s) at an existing facility, the Consultant must specify gasoline storage tank(s) with a dual-point vapor balance system in which the storage tank is equipped with an entry port for a gasoline fill pipe and a separate exit port for a vapor connection.
d. The Consultant shall specify that, at the time of installation and every three years thereafter, the PV vent valves must comply with the leak rate and cracking pressure requirements specified above, using the California Air Resources Board (CARB) Vapor Recovery Test Procedure TP-201.1E or alternative method approved by the MDE/ARMA.
e. The Consultant shall specify that, at the time of installation, the vapor balance system must comply with the static pressure performance requirements specified above, using the CARB Vapor Recovery Test Procedure TP-201.3 or alternative method approved by the MDE/ARMA.
This requirement also applies every three years after initial installation.
f. If any alternative vapor balance system other than that described in 5.c., above, is specified, the Consultant must specify that initial compliance is demonstrated such that a 95 percent reduction in emissions is achieved by the vapor balance system using CARB Vapor Recovery Test Procedure TP-201.1, and determine and document alternative acceptable values for the leak rate and cracking pressure requirements described in (d) and (e), above.
g. The Consultant must specify the following initial CARB-approved tests:
· A leak test in accordance with CARB Vapor Recovery Test Procedure TP-201.3
· An air to liquid volume ratio test in accordance with CARB Vapor Recovery Test Procedure TP-201.5
· A dynamic pressure performance test in accordance with CARB Vapor Recovery Test Procedure TP-201.4
· A vapor return line vacuum integrity test for the Healy Model 400 ORVR System
· A vapor return line vacuum integrity test for the Healy Model 600 System