The Slotted Guidepole Agreement

The Slotted Guidepole Agreement

Rob Ferry
Rob Ferry
the TGB partnership
the TGB partnership
Hillsborough, NC
Hillsborough, NC
tgb@mindspring.com
tgb@mindspring.com
2 2
The STERPP
The STERPP

Storage
Storage

Tank
Tank

Emission
Emission

Reduction
Reduction

Partnership
Partnership

Program
Program
3 3
Guidepole Through a Floating Roof
Guidepole Through a Floating Roof
Floating roof deck Floating roof deck
Guidepole Guidepole
Guidepole Guidepole
Deck Fitting Deck Fitting
Guidepole Guidepole
4 4
Guidepole Deck Fitting
Guidepole Deck Fitting
Pole wiper Pole wiper
Guidepole Guidepole
Deck cover gasket Deck cover gasket
Roller assembly Roller assembly
(optional) (optional)
Floating Floating
roof roof
deck deck
Deck cover Deck cover
(sliding (sliding-- --
shown shown
cutaway) cutaway)
Rim Rim
5 5
What Controls are Acceptable?
What Controls are Acceptable?
1. Pole Float (w/cover gasket/pole wiper).
1. Pole Float (w/cover gasket/pole wiper).
2. Alternate Technology Equal to Option 1.
2. Alternate Technology Equal to Option 1.
3. Pole Sleeve (w/cover gasket/pole wiper).
3. Pole Sleeve (w/cover gasket/pole wiper).
4. Internal Sleeve (blocking all slots).
4. Internal Sleeve (blocking all slots).
5. Solid Guidepole (no slots).
5. Solid Guidepole (no slots).
6. Flexible Enclosure (slinky).
6. Flexible Enclosure (slinky).
7. Covered EFRT (no add
7. Covered EFRT (no add
-
-
on controls).
on controls).
8. Removal from (regulated
8. Removal from (regulated
matl
matl
) Service.
) Service.
6 6
STERPP Option 1: Pole Float
STERPP Option 1: Pole Float
Slotted guidepole Slotted guidepole
Pole wiper Pole wiper
Deck cover Deck cover
(sliding) (sliding)
Rim Rim
Deck cover Deck cover
gasket gasket
Opening Opening
through through
the deck the deck
Bottom of Bottom of
the float the float
Liquid Liquid
surface surface
Pole float Pole float
Wiper/seal on Wiper/seal on
pole float rim pole float rim
Floating roof Floating roof
deck deck
Rim Rim
Dotted lines under the sliding cover show Dotted lines under the sliding cover show
an alternate location for the pole wiper. an alternate location for the pole wiper.
7 7
STERPP Option 2: Alternates
STERPP Option 2: Alternates

Any slotted guidepole control device with

Any slotted guidepole control device with
emission factor equal to Option 1 or lower.
emission factor equal to Option 1 or lower.

Any combination of deck fitting controls

Any combination of deck fitting controls
with equal or lower combined emission
with equal or lower combined emission
factor as if subject to Kb and STERPP.
factor as if subject to Kb and STERPP.

API Test Methods are an accepted basis for

API Test Methods are an accepted basis for
demonstrating equivalency.
demonstrating equivalency.
8 8
Slotted guidepole Slotted guidepole
Pole wiper Pole wiper
Deck cover Deck cover
(sliding) (sliding)
Deck cover Deck cover
gasket gasket
Opening Opening
through through
the deck the deck
Liquid Liquid
surface surface
Pole sleeve Pole sleeve
Floating roof Floating roof
deck deck
Rim Rim
Dotted lines show an alternate location Dotted lines show an alternate location
for attachment of the pole sleeve. for attachment of the pole sleeve.
STERPP Option 3: Pole Sleeve
STERPP Option 3: Pole Sleeve
Bottom of Bottom of
the sleeve the sleeve
Rim Rim
9 9
Slotted guidepole Slotted guidepole
Pole wiper Pole wiper
Deck cover Deck cover
(sliding) (sliding)
Cover (hatch) at the Cover (hatch) at the
top of the pole top of the pole
Rim Rim
Deck cover Deck cover
gasket gasket
Opening Opening
through through
the deck the deck
Cover (hatch) at the Cover (hatch) at the
top of the guidepole top of the guidepole
(shown partially open) (shown partially open)
Liquid Liquid
surface surface
Internal sleeve Internal sleeve
Floating roof Floating roof
deck deck
Rim Rim
The internal sleeve extends the entire The internal sleeve extends the entire
length of the guidepole, thereby length of the guidepole, thereby
blocking flow through the slots. blocking flow through the slots.
STERPP Option 4: Internal Sleeve
STERPP Option 4: Internal Sleeve
Internal sleeve Internal sleeve
10 10
STERPP Option 5: Solid Guidepole
STERPP Option 5: Solid Guidepole
Bottom Bottom
of the of the
guidepole guidepole
Liquid surface Liquid surface
at the lowest at the lowest
operating level operating level
Solid guidepole Solid guidepole
(unslotted) (unslotted)
Slots, if any, only Slots, if any, only
located below located below
the liquid level the liquid level
No slots above the No slots above the
liquid level for vapors liquid level for vapors
to enter the guidepole to enter the guidepole
Bottom Bottom
of the of the
tank tank
Solid guidepole Solid guidepole means a means a
guidepole or gaugepole guidepole or gaugepole
that does not have slots that does not have slots
or holes through the wall or holes through the wall
of the pole at or above the of the pole at or above the
level of the floating roof level of the floating roof
when it is at its lowest when it is at its lowest
operating level. operating level.
Cover (hatch) at the Cover (hatch) at the
top of the guidepole top of the guidepole
(shown partially open) (shown partially open)
11 11
STERPP Option 6: Flexible Enclosure
STERPP Option 6: Flexible Enclosure
Opening Opening
through through
the deck the deck
Liquid Liquid
surface surface
Flexible enclosure Flexible enclosure
Floating roof Floating roof
deck deck
Rim Rim
Cover (hatch) at the Cover (hatch) at the
top of the guidepole top of the guidepole
(shown partially open) (shown partially open)
Flexible enclosure: Flexible enclosure:
A flexible device that completely A flexible device that completely
encloses the slotted guidepole and encloses the slotted guidepole and
eliminates the hydrocarbon vapor eliminates the hydrocarbon vapor
emission pathway from inside the emission pathway from inside the
tank through the guidepole slots tank through the guidepole slots
to the outside air. to the outside air.
12 12
STERPP Option 7: Covered EFRT
STERPP Option 7: Covered EFRT
The tank was built as an external floating The tank was built as an external floating- -roof tank, roof tank,
and was subsequently covered with a fixed roof. and was subsequently covered with a fixed roof.
13 13
STERPP Option 8:
STERPP Option 8:
Removal from Service
Removal from Service

Rather than upgrade the slotted guidepole;

Rather than upgrade the slotted guidepole;
remove the tank from regulated
remove the tank from regulated
matl
matl
service.
service.

The tank may still be used, but only to store

The tank may still be used, but only to store
liquid stocks with true vapor pressure < the
liquid stocks with true vapor pressure < the
Ka/Kb cutoffs.
Ka/Kb cutoffs.

Surrender (revise) operating permits to

Surrender (revise) operating permits to
show that this tank is not to store regulated
show that this tank is not to store regulated
material.
material.
14 14
To Get a Copy of the FR Notice
To Get a Copy of the FR Notice

Download the Final Notice of the STERPP:

Download the Final Notice of the STERPP:

www.access.
www.access.
gpo
gpo
.
.
gov
gov
/
/
su
su
_docs/
_docs/
fedreg
fedreg
/a000413c.
/a000413c.
html
html

Listing April 13, 2000 Federal Register Notices

Listing April 13, 2000 Federal Register Notices

Scroll to Environmental Protection Agency

Scroll to Environmental Protection Agency

Find the STERPP under Notices

Find the STERPP under Notices

65 FR 19891 (April 13, 2000)

65 FR 19891 (April 13, 2000)