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February 27, 1979 Policy Decisions re: CAA Requirements Strategic Petroleum Reserve 22.4
Ballasting and lightering emissions should be considered secondary emissions. Neither of their emissions arise from the operation of the dock itself, as opposed to transportation to the dock, and therefore neither may be considered direct emissions of the dock. However, both arise as a direct consequence of the dock and dome construction and operation, and both may therefore be considered secondary emissions of the dock and domes. An increase in emissions associated with any dock, regardless of whether that dock is new, modified or unchanged, should be considered to be secondary emissions to be allocated proportionally among the storage domes which are fed from that dock. If the dock itself is subject based on its direct emissions, the ballasting and lightening emissions from the dock would be dealt with as secondary emissions to the dock and need not be considered in reviewing the storage dome fed from that dock.