Shane E. Yokom
Senior Environmental Analyst
Enbridge Energy, Limited Partnership
119 North 25th Street East
Superior, Wisconsin 54880
Re:
Enbridge requests that EPA approve the following in-service internal inspection
procedure as an acceptable alternative to the out-of-service Subpart Kb internal inspection:
1. If a subpart Kb tank has not been emptied and degassed within the
applicable five or ten-year period, Enbridge will conduct the internal
inspection on the tank while it is in service according to the procedure in
Subpart WW, 40 C.F.R. 63.1063(d)(1). This means that Enbridge will
perform the internal inspection entirely from the top side of the floating
roof. Absent an independent need to empty or degas the tank for some
reason other than the Kb internal inspection, Enbridge will then not
perform the Kb internal inspection for another five or ten years, as
applicable. Each time a NSPS IFR tank is emptied and degassed, however,
Enbridge will perform an internal inspection while the tank is out of
service as required under Subpart Kb, 40 C.F.R. 60.113b(a)(4).
2. While performing an in-service internal inspection, Enbridge will also
measure seal gaps on its NSPS IFR tanks according to the procedure
outlines for external floating roof tanks in Subpart Kb, 40 C.F.R.
60.113b(b)(2)-(4).
3. The following conditions would constitute inspection failure under an inservice internal inspection:
a. Stored liquid on the floating roof.
b. Holes or tears in the primary or secondary seal (if one is present).
c. Floating roof deck, deck fittings, or rim seals that are not
functioning as designed as specified in Subpart Kb, 40 C.F.R.
60.112b(a)(1)(i)-(ix).
d. Failure to comply with the operational requirements of Subpart Kb,
40 C.F.R. 60.112b(a)(1)(i)-(ix).
e. Seal gaps that exceed the requirements for the applicable seal type
found in Subpart Kb for tanks with external floating roofs,
40 C.F.R. 60.113b(b)(4)(i) or (ii).
4. If failures are detected during an in-service internal inspection, Enbridge
will comply with the reporting requirements of 40 C.F.R. 60.115b(a)(3).
Enbridge will also comply with the seal gap reporting and recordkeeping
requirements 40 C.F.R. 60.115b(a)(2) through (4) for seal gap
measurements, as applicable.
5. If failures are detected during an in-service internal inspection, Enbridge
will comply with the repair requirements of 40 C.F.R. 60.113b(a)(2)
would require Enbridge to repair the items or remove the storage vessel
from service within 45 days. If a failure that is detected during inspections
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CERTIFICATE OF MAILING
I, Tracy Jamison, certify that I sent a Request to Provide Information Pursuant to the Clean Air
Act by Certified Mail, Return Receipt Requested, to:
Shane E. Yokom
Senior Environmental Analyst
Enbridge Energy, Limited Partnership
119 North 25th Street East
Superior, Wisconsin 54880
I also certify that I sent a copy of the Request to Provide Information Pursuant to the Clean Air
Act by First Class Mail to:
Neal Baudhuin
Supervisor, Northern Region Air Management
Wisconsin Department of Natural Resources
107 Sutliff Avenue
Rhinelander, Wisconsin 54501
Bill Baumann
Chief of Compliance, Enforcement and Emissions Inventory Section
Wisconsin Department of Natural Resources
PO Box 7921
Madison, Wisconsin 53707
Randy McDonald
U.S. EPA, Research Triangle Park
109 T.W. Alexander Drive
Mail Code: E143-01
Research Triangle Park, North Carolina 27709
________________________
Tracy Jamison
Office Automation Assistant
Air and Radiation Division
Filename:
C:\EPAWork\Applicability Determinations\5EnbridgeEnergyL_NSPS.doc