June 4, 2014
Terminal Info: Sunoco Logistics
4004 W Main St.
Owosso, Ml 48867
Phone: (989) 723-6781
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Performed By: Jordan Technologies
j\.IL 11. 1.U\4
5051 Commerce Crossings Drive
Louisville, Kentucky 40229
Test Personnel: Tony Fenton
Phone: (502) 267-8344
E-Mail: tfenton@aereon.com
VOC Emissions
27.25 mg/liter
80 mg/liter
Pounds/1 ,000 gal
0.23 lbs/1 ,000 gal
1 lbs/1 ,000 gal
An Aereon Co!llpn'!)'
Certification of sampling procedures by the team leader of the personnel conducting the sampling
procedures and compiling the test report:
"I certify that the sampling procedures were performed in accordance with the approved test plan and that
the data presented in this report are, to the best of my knowledge and belief, true, accurate, and
cilmplete. All exceptions are listed and explained below."
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Manager, Environmental Testing Division
Printed Name of Person Signing: Tony Fenton
G/J CJ f1tJ
Certification of test report by the senior staff person at the company who is responsible for
checking the test report;
"I certify that this test report and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gathered and evaluated
the test information submitted. Based on my inquiry of the person or persons who performed sampling
and analysis relating to the performance test, the information submitted in this test report is, to the best of
my knowle ge and belief, true, accurate, and complete. All exceptions are listed and explained below."
Printed Name of Person Signing: James Stamm. P.E.
Deviations from SOP
No deviations noted during testing
G/10 /; 4
The Sunoco Logistics terminal in Owosso, Michigan is a bulk transport loading
facility for Gasoline and Fuel Oil Products.
The products are bottom loaded into transport tankers and the displaced
hydrocarbon vapors are balanced to a JOHN ZINK VAPOR COMBUSTION UNIT
This facility was source tested for air emissions on June 4, 2014. The purpose of
this test was to confirm proper operation of the VCU and verify compliance with
applicable VOC (Volatile Organic Compound) air emission requirements
The Gasoline Terminal Air Emission Source Test was conducted in accordance
with procedures established, and the test methods referenced, in the Code of
Federal Regulations; CFR 40, Part 60, Subpart XX and CFR 40, Part 63,
Subpart BBBBBB. Specific procedures used include:
Inlet Vapor Volume into VCU
Method 2A
Method 2B
Exhaust Vapor Volume from VCU
Method 10
Exhaust CO Concentration
Method 3A
Exhaust C0 2 Concentration
Method 21
Potential Leak Sources (500 PPM Leak Rate)
Method 258
Inlet and Outlet VOC Concentrations
40 CFR 60 Subsection 60.503 (d) Transport Loading Maximum Backpressure
The results of this air emission test demonstrate that this source is in compliance
with the applicable Federal and Local requirements. A summary of the data is
presented below:
VOC Emissions
27.25 mg/liter
80 mg/liter
Pounds/1 ,OOOgal
0.23 lbs/1,000gal
1 lbs/1 ,OOOgal
The Method 21 Leak Test was performed on the day prior to testing. A portable
LEL meter was calibrated using a 500 PPM methane calibration gas. The meter
was used to check for leaks around all fittings, flanges, valves as well as any
other exposed potential leak source. No leaks were found in excess of 500 ppm.
Light petroleum products are bottom loaded at two loading bays at the Sunoco
Logistics Owosso, Michigan facility.
The terminal is equipped to load three grades of gasoline including: Regular,
Midgrade and Premium Unleaded Gasoline. The terminal is also equipped to
load Diesel Fuel and Heating Oil onto transports as well.
The truck loading rack is equipped with vapor recovery hoses positioned at the
transport loading positions for hook up to the Vapor Combustion System. All
trucks that load must connect the vapor recovery hose before loading liquid
The vapor hoses have individual check valves that prevent unused hoses from
leaking any vapors. The vapor pipe manifold connects the vapor hoses to the
VCU. The vapor pipe system also employs a liquid condensate accumulator,
flame arrester and pressure/vacuum relief valve upstream from the VCU.
A brief description of the vapor combustion unit (VCU) process is presented
below. For a detailed description, please consult the manufacturer's equipment
The VCU consists of the following components:
• Vertical combustion stack with louvers.
• Primary air blower
• Non-flashback burner assembly
• Pilot burner
• Various electric and mechanical controls required for proper and safe
The incoming hydrocarbon vapors from the truck loading facility are mixed with
primary combustion air and then ignited by a natural gas (propane) fueled pilot
burner. Secondary combustion air is mixed with the combustion products as
they continue through the firebox and ultimately vent to the atmosphere at the
top of the vertical stack.
The VCU has an interlock to prevent the venting of vapors to the VCU prior to it
being in an operating mode. When a tank truck enters the loading rack, a vapor
line is attached to the tank truck to move hydrocarbon vapors to the VCU.
Before the truck can be loaded, the VCU must provide a signal indicating that it
is ready to receive vapors.
When the interlock is satisfied, the VCU turns on and purges the stack with the
primary combustion air blower. This step is a safety requirement to remove any
residual vapors that may be present in the stack before lighting the pilot. Once
the pilot is lit and proven, the VCU returns the required "Ready to Load" signal to
the truck load rack. As the truck loads liquid gasoline, the displacement pressure
pushes the hydrocarbon vapors from the truck to the VCU for combustion. The
vapor pipe contains a small condensate accumulator to prevent any thermal
condensation liquid to reach the burner assembly and also a flame arrester for
safety. A moderate increase in vapor line pressure opens a flow control valve
allowing the vapors to pass to the burner of the VCU.
During the operation of the VCU, the primary combustion air blower introduces
fresh air to the hydrocarbon/air vapor mix in front of the burner. The vapors are
passed through the burner assembly and oxidized. The VCU stack is sized to
contain the vapor combustion zone in which the vapor combustion continues as
the combustion products mix with secondary combustion air and vent through
the top of the stack.
The following methods were completed as part of the test protocol:
2A and 28 - vapor volume measurement.
10 - CO! C02 concentration
21 -System leak detection
258 - Hydrocarbon concentration
Transport loading pressure was monitored as described in sub-section 60.503
(d) (i.e., 18" water column gauge test). All sampling procedures conformed to
procedures outlined in New Source Performance Standards (NSPS), 40 CFR 60,
Subpart XX- Section 60.503- Test Methods and Procedures and Subpart
888888. Specifically in the field a Dwyer Magnehelic Pressure Gauge was
connected to the transport vapor hose connection. Pressure readings were
recorded on the truck loading data sheets. All loading bays were tested.
All vapor collection equipment, including fittings, vents and hoses were tested
using the Method 21 test. This test is required by 40 CFR 63 Subpart 888888
requirements (prior to beginning the test). Any readings equal to or greater than
500 PPM as methane would have been considered a leak and noted and repaired
prior to beginning the test. No leaks were observed during the test.
Method 21 leak detection testing was conducted on any gasoline truck whose
emissions showed obvious signs of leaks using sight, sound, and smell as an
indication. In accordance with Subpart 888888, Section 63.11 0902(a)(1)(i), any
leak equal to or greater than 500 ppm vol. methane was considered a leak. Failed
transport truck would have been classified as a failed leak test and loading halted
and terminal personnel would have been notified. No transports were found to be
leaking during the test.
In addition, any truck that loads a distillate fuel was excluded from the Accountable
VOC emission calculations.
US EPA method 258 was used to monitor the exhaust VOC measurements from
the VCU. The non-dispersive infrared analyzer (NDIR) was calibrated on propane
and the full-scale range is 0- 1,000-PPM volume. Protocol1 gases were used to
calibrate the analyzer. The exhaust VOC sample was collected through a heated
sample line that was automatically regulated to 250° F ± 25°F. This feature
prevents any water and soluble VOC condensation in the exhaust sample line.
A non-dispersive infrared analyzer, turbine flow meter, inlet vapor thermistor and
inlet pressure transducer were connected to the VCU vapor inlet pipe to collect all
test da.ta. Inlet VOC flow meter temperature and pressure are used for
standardizing volumes during data reduction.
Method 25B was also used to measure inlet VOC concentration. A continuous
sample was taken through non-heated Teflon tubing from the turbine meter to the
NDIR analyzer. Primary Standard gases were used to calibrate the inlet VOC
analyzer. This analyzer operated on a 0-100% volume propane full-scale range.
Both VOC analyzers were calibrated using propane and nitrogen mixtures of
approximately 0%, 25%, 50%, and 85% of full scale. A full calibration was
performed immediately prior to the start of the test. During the test, hourly drift
checks were performed using the 0% and 50% span gas to document acceptable
span and zero drift. All pertinent field calibration data was made available for local
onsite test observers.
Field data was monitored continuously and recorded every 5 minutes for printout
as a test data point. The data is captured in a PLC and exported to a Windows
compatible laptop computer running Wonderware software. The data monitored
over the test period includes time, ambient temperature, inlet meter temperature,
barometric temperature, flow meter static pressure, inlet hydrocarbon
concentration, exhaust hydrocarbon concentration, exhaust CO and C02
concentrations, and inlet flow rate. All of the accumulated data is downloaded into
an Excel spreadsheet to calculate:
standardized inlet flow rate
calculated exhaust flow rate
inlet hydrocarbon mass
exhaust hydrocarbon mass
At the end of testing, an Excel spreadsheet calculates the total mass of
hydrocarbons emitted from the VCU during testing. The volume of accountable
liters loaded during the test is then used to calculate the mass of hydrocarbons per
liter of gasoline loaded. The inlet and exhaust mass of hydrocarbons is also used
to calculate the VCU's destruction efficiency.
Copies of the transport loading rack sheets, hydrocarbon analyzer strip charts, and
computer printouts are attached as Appendices to this test report.
Thermistor Temperature Probes
(turbine meter standardization,
Allen Bradley PLC, Windows compatible Laptop Computer, Wonderware
software, Excel software data reduction package
Portable LEL Gas Analyzer (Method 21 Leak Testing)
RKIInstruments Eagle Portable Gas Detector (0-500 or 0-10,000 PPM)
Variable Differential Pressure Transducer (turbine meter
standardization) Setra Model: 264
Digital Barometer (turbine meter standardization)
American Meter Co. 8" Turbine Flow Meter (Method 2A Testing)
Strip Chart Recorder: Yokogawa DX1000N Six Channel Paperless
VOC Gas Analyzers (Method 25B) Inlet & Outlet: Horiba VIA 510 NDIR
CO/C02 Gas Analyzer (Method 10 and Method 3A)
Horiba VA3000 Gas Analyzer & Horiba VS3000 Gas Sample Conditioner
Heated Sample Line (250° F ± 25° F)
Stack probe assembly
Dwyer Magnehelic Pressure Gauge Model #2030
(40 CFR 60.503 (d) testing)
Gas cylinder documentation is presented in Appendix B.
Setra Model: 270
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