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Federal Register / Vol. 86, No. 24 / Monday, February 8, 2021 / Notices permit the use of an AMEL by a source if, after notice and opportunity for public hearing, it is established to the Administrators satisfaction that such AMEL will achieve emissions reductions at least equivalent to the reductions required under the applicable CAA section 111h1
standards. NSPS subpart Kb also includes specific regulatory provisions i.e., 40 CFR 114b allowing sources to request an AMEL for the VOC standards at 40 CFR 112b.
Rohm and Haas included in its AMEL
application information to demonstrate that the proposed bulk storage tank, through its vapor balancing system and pressure containment design, will achieve a reduction in emissions at least equivalent to the reduction in emissions achieved by the VOC standards at 40
CFR 60.112b. Rohm and Haass AMEL
request was submitted on June 17, 2020.
For Rohm and Haass AMEL request, including any supporting materials Rohm and Haas submitted, see Docket ID No. EPAHQOAR20200599.
II. Request for AMEL

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Pursuant to 40 CFR 60.114b, Rohm and Haas is seeking an AMEL for the VOC standards set forth at 40 CFR
60.112b for a proposed bulk storage tank to be used at its chemical plant in Kankakee, Illinois. Rohm and Haass application includes an engineering evaluation to support its request, as required by 40 CFR 60.114bc.2 We, therefore, deem this AMEL application by Rohm and Haas to be complete.
Rohm and Haas submitted this AMEL
request because the proposed tank design does not contain either an external or internal floating roof or a closed vent system and control device that are specified by 40 CFR 60.112b.
Rohm and Haas is proposing an alternative tank design that will eliminate breathing losses by storing material in a pressure tank and control working losses using vapor balancing.
The information provided by Rohm and Haas states that the proposed new tank is an American Petroleum Institute API620, 160,000 gallon approximately 600 cubic meter fixedroof storage tank used for the storage of VAM. An API620 specification tank is designed to contain pressures up to 15
psig. According to Rohm and Haas, 2 As explained in the preamble to the proposed NSPS subpart Kb, equivalence could be demonstrated by a number of methods including:
1 An actual emissions test that uses a full size or scale-model storage vessel that accurately collects and measures all VOC emissions from the storage vessel, or 2 an engineering evaluation as approved by the Administrator. Emphasis added. 49 FR
29698, 29706 July 23, 1984.

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breathing losses will not occur because there are no vents, and the tank can withstand pressures up to 9 psig before activation of a PRD. Rohm and Haass engineering evaluation indicates the tank is not expected to exceed these pressures. The published vapor pressure of VAM is 1.72 pounds per square inch psi 89.1 millimeters of mercury at 68
degrees Fahrenheit F; however, the EPA defines the maximum true vapor pressure MTVP as the vapor pressure of a specific material at the maximum average monthly temperature, which is 74.7 F and occurs during the month of July in the Kankakee locale. At the specified maximum temperature, using the Antoine equation and appropriate coefficients, the MTVP of vinyl acetate was estimated to be 2.09 psi, which is well below the 9 psig rupture disk and PRD settings for the proposed tank.
Therefore, PRDs will be designed to open only in emergency instances i.e., external fire or uncontrolled polymerization.
The PRDs will consist of two pressure relief assemblies. The primary assembly will include in series a rupture disk, a pressure indicator, and a pressure relief valve PRV. The rupture disk and PRV
will both be set at 9 psig. The purpose of this assembly is to provide early controlled remediation in case of fire/
polymerization/over-pressurization.
Because the PRV is downstream of the rupture disk, the design will allow the assembly to return to its closed position once the pressure release event ends.
The secondary pressure relief assembly will consist of a rupture disk set at 13
psig, followed by a pressure indicator.
This assembly is designed to contain extreme fire/polymerization in the event the first assembly is unable to do so. In such event, the rupture disk will vent to protect against vessel rupture.
To demonstrate that the PRV does not open, the tank vapor space pressure and the space between the rupture disk and PRV will be continuously monitored for pressure and recorded. If a release occurs, a new rupture disk will be installed, and the corresponding PRV
will be reseated properly. This PRV will be checked quarterly to ensure the PRV
is seated properly using EPA Method 21
following 40 CFR 63.119g5i, part of the vapor balancing provisions in NESHAP subpart G 40 CFR 63.119g.
In the event that a PRV opens, this would qualify as an excess emission event and must be reported on the semiannual compliance report. If designed and operated as described above, there will not be any emission events, therefore, this alternative is equivalent with the standard.

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No PRD on the storage tank, railcar, or tank truck is expected to open during loading or as a result of diurnal temperature changes breathing losses.
During filling of the tank, any displaced vapors will be collected and routed through the vapor balancing line. There are no PRDs associated with the vapor balancing line itself, and the PRDs on the railcar are set at 165 psig and tank trucks are set between 25 to 50 psig to prevent an opening of a PRD while the vessel is being unloaded.
The tank will also be equipped with a vacuum relief system that will be used when VAM is transferred to the process area, and both the vacuum relief system and a vapor balance system will be used when VAM is added to the tank. The vacuum relief system only serves to allow ambient air into the tanks head space to equalize pressure decreases as material is removed. The vapor balance system operation collects and contains vapors discharged during tank filling operations.
In its request, Rohm and Haas states that the proposed tank would comply with the vapor balancing requirements in NESHAP subpart G, 40 CFR 63.119g to confirm proper vapor balancing.
The facility unloads VAM from tank trucks or railcars, which are connected to the tank systems vapor balance system. The Kankakee facilitys bulk unloading Standard Operating Procedure requires that each U.S.
Department of Transportation DOTspecification tank truck or railcar containing vinyl acetate be inspected to verify that its DOT qualification inspections and tests are current. VAM
will be unloaded only from tank trucks or railcars which are connected to the tank systems vapor balance system.
The site will require that railcars and tank trucks that deliver VAM will be reloaded or cleaned only at facilities which utilize the control techniques specified at 40 CFR 63.119g6i or ii of NESHAP subpart G. The site will mandate that each railcar or tank truck is connected to a closed-vent system with a control device that reduces inlet emissions of HAP by 95 percent by weight or greater.
The Kankakee facility will request, maintain, and submit to the Administrator a written certification from the VAM supplier that each suppliers current reloading or cleaning facility meets the above requirements. If the suppliers of the VAM changes in the future, the Kankakee facility will obtain a written certification that the new suppliers meet these requirements.
Rohm and Haas believes that this tank, as designed and operated, will
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