Superior Oil: Reclaimed Energy Division was found to violate the National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and Recovery Operations, 40 C.F.R. Part 63, Subpart DD (Subpart DD); the National Emission Standards for Tanks-Level 1, 40 C.F.R. Part 63, Subpart OO (Subpart OO); The National Emissions Standards for Benzene Waste Operations, 40 C.F.R. Part 61, Subpart FF, and Superior Oil?s Title V permit. Specifically, comparative Method 21 monitoring conducted by EPA inspectors revealed that several closure devices on storage tanks were not operating as required by Subpart DD and Subpart OO. In addition, a review of Superior Oil?s Leak Detection and Repair (LDAR) records indicate that Method 21 is not being conducted properly at their facility. In addition, calibration gases used at the facility to conduct Method 21 monitoring were of the incorrect concentration. A Consent Agreement and Final Order is concurrently being issued to resolve the alleged violations. It was also found that the initial notification report for Subpart FF was not submitted, this violation was remedied before the ACO was completed and, therefore, was not a part of the compliance program.
Emissions savings were calculated by taking a component count at Superior Oils facility, applying average SOCMI factors to each component. It was assumed that EPAs LDAR Best Practices Guide Table 4.1 LDAR control effectiveness would be achieved by a proper LDAR program. It was also assumed