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August 8, 1980 Request for Confirmation re: 100-Ton Source 22.11

This memo discusses the definition of potential 100-ton sources for gasoline storage and marketing. For instance, potential emissions at a bulk gasoline terminal would include potential emissions from tank trucks (loading and unloading) and storage tanks. A tank truck certification program is required only for those urban areas requesting an extension beyond 1982 to attain the ozone standard. As stated in previous determinations of 100 tons/year sources, . . . potential emissions from all similar or connected CTG category sources on a facility-wide basis should be added together to determine if CTG control is required. In the case of bulk gasoline terminals, this would be based on potential emissions from tank trucks (using the appropriate emission factor for splash or submerged fill and the loading rack throughput) as well as potential emissions from storage tanks if they are located on contiguous or adjacent properties which are used or operated by the same person (or by persons under common control). See also: Memo dated September 7, 1978 from Richard Rhoads to Director, Air and Hazardous Materials Division, Region I-X. Notebook Entries: 8.53; 26.14

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