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<From: "Bill Glushko" <billglushko@hotmail.com<
<To: billglushko@hotmail.com <CC: jfields@argentinc.com <Subject: EOTT PL Tanks (compliance) database <Date: Thu, 28 Jun 2001 17:11:35 -0500 < <Latest tank list. <99% complete, unless you request otherwise. < <Note that this list includes tanks that are still standing, <regardless of whether they are inactive or permanently out of <service. < <There are 8 sites which are affected by Texas annual inspection <fees, with a cost of $58,000. (but possibly, after checking the <tank strapping tables, might reduce to $51,000.) These fees would <be due by 11/01 each year if the tank was operated during the <previous Fiscal Year (Sep 1-Aug 31). < <The Teams told me that electric pumps are the norm at EOTT PL tank <farms. Crane has a Title V permit, but there were no combustion <sources that would cause another site to exceed 100 TPY. < <The Texas tanks subject to NSPS K, Ka, or Kb are subject to an <emissions fee, unless they are subject to an inspection fee and it is <higher. < <In Texas, E&P facilities, crude oil and refined product pipelines, natural <gas and LPG are regulated by the Railroad Commission. <However, TNRCC has jurisdiction over the petroleum bulk stations. <SIC code for a petroleum bulk station is 5171; for a crude pipeline <is 4612. SIC 5171 either as a primary or secondary code is correct, <and it generates a TNRCC inspection fee for 8 of the sites. <Designating a 5171 code and/or paying an inspection fee will get the <facility more attention from the state inspectors. The need to document (2 <years recordkeeping required) tank seal inspections becomes critical. < <For TNRCC inspectors in south and east Texas, seal inspections <on petroleum storage tanks with floating<roofs have been an item of <interest for some time. There is even a <requirement to notify the local <environmental agency 30 days in <advance of refilling a floating roof tank <or measuring the seal gap. It is likely that <the EOTT stations have not <been inspected because of the changes <in ownership, use of only 4612 SIC <code, no TNRCC account number <assigned and no inspection/emissions fee <paid. But, sometime sooner than later, the inspector will come, and you <want to be ready. < <Larry, I am very familiar with what is required with your crude <stations and am finalizing a memo which will specify exactly what is <needed. I recommend you move forward with the sugggested changes. With <regard to the seal inspections... I can do them, or I can show you what <you'll need for 100% compliance. Let me know. Thanks! - Bill Glushko 281 953-1014 <Argent < < _________________________________________________________________ Get your FREE download of MSN Explorer at http://explorer.msn.com - EOTT PL Tks 6-27.xls
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