The facility violated the New Source Performance Standards for two tanks storing formic acid (a VOC) by not installing controls (either internal or external floating roof tank or closed vent system to a control device). The facility violated the PA SIP by not installing controls on 8 tanks storing fuel-grade ethanol (a VOC which exceeds the vapor pressure limit in the regulation). The facility violated the National Emission Standard for Hazardous Air POllutants (NESHAP) for benzene equipment leaks by not monitoring its valves and connectors in benzene vapor service and by not using the ocrrect calibration gas nor the correct concentration of calibrationi gas. The facility violated the NESHAP for benzene transfer operations by not conducting the performance test in accordance with regulation protocol. The facility conducted the performance test using test methods and calibration gases not explicitly allowed for in the rule.
Lack of controls on the two formic acid tanks and the 8 fuel-grade ethanol tanks results in excess emissions of VOCs in the ozone non-attainment area of Philadelphia, PA. Use of the incorrect calibration gas and calibration gas concentration could result in omission of benzene leak identification and repair. This could result in excess emissions of a hazardous air pollutant (benzene) which is also a VOC. Lack of monitoring vapor lines under the leak, detection and repair program could also result in excess emissions. By not conducting the