(AE-17J)

Shane E. Yokom
Senior Environmental Analyst
Enbridge Energy, Limited Partnership
119 North 25th Street East
Superior, Wisconsin 54880
Re:

Request for Alternative Monitoring Procedure Under 40 C.F.R 60.13(i)

Dear Mr. Yokom:

This letter is in response to your letter dated June 4, 2010 requesting an alternative
monitoring procedure under 40 C.F.R. 60.13(i) that Enbridge Energy, Limited Partnership
(Enbridge) can use to meet the 40 C.F.R. Part 60, Subpart Kb (Kb) internal inspection
requirements.
You requested that the U.S. Environmental Protection Agency, Region 5 (EPA), allow
Enbridge the option to perform a Subpart Kb internal inspection on the internal floating roof
(IFR) tanks while they are in-service and out-of-service at your Superior terminal in Superior,
Wisconsin. Enbridge has requested to perform the internal inspection by visually inspecting the
IFR components from the top of the IFR tanks using inspection procedures that are similar to
those found in 40 C.F.R. 63.1063(d)(1), National Emission Standards for Storage Vessels,
40 C.F.R. Part 63, Subpart WW (WW). The proposed alternative monitoring procedure,
based on WW, would serve to satisfy the Kb requirements at 40 C.F.R. 60.113b(a)(4).
According to 40 C.F.R. Part 60, Subpart Kb, Standards of Performance for Volatile
Organic Liquid Storage Vessels for Which Construction, Reconstruction, or Modification
Commenced After July 23, 1984, the owner or operator of an IFR tank shall visually inspect the
internal floating roof, the primary seal, the secondary seal (if one is in service), gaskets, slotted
membranes and sleeve seals (if any) each time the storage vessel is emptied and degassedIn no
event shall inspections conducted in accordance with this provision occur at intervals greater than
10 years in the case of vessels conducting the annual visual inspection as specified in paragraphs
(a)(2) and (a)(3)(ii) of this section and at intervals no greater than 5 years in the case of vessels
specified in paragraph (a)(3)(i) of this section. 40 C.F.R. 60.113b(4).
Based on information from the June 4, 2010 letter, the Superior, Wisconsin facility has
three IFR tanks that have been constructed, reconstructed, or modified after July 23, 1984, and
are subject to the New Source Performance Standards for Volatile Organic Liquid Storage
Vessels (40 C.F.R. Part 60, Subpart Kb).

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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cannot be repaired within 45 days and if the vessel cannot be emptied

within 45 days, a 30-day extension may be requested if the failure cannot
be repaired within 45 days and if the vessel cannot be emptied within 45
days, a 30 day extension may be requested in the inspection report required
in 40 C.F.R. 60.115b(a)(3).
ACH Milan requested alternative monitoring procedures for the Superior, Wisconsins
three IFR tanks. Internal inspections of IFR tanks are essential to maintaining proper storage of
volatile organic liquids. Inspecting the roof, the primary seal, the secondary seal (if one is in
service), gaskets, slotted membranes and sleeve seals (if any) must be completed during an
inspection. According to 40 C.F.R. 60.113b(4):
If the IFR has defects, the primary seal has holes, tears, or other openings in the seal or
the seal fabric, or the secondary seal has holes, tears, or other openings in the seal or the
seal fabric, or the gaskets no longer close off the liquid surfaces from the atmosphere, or
the slotted membrane has more than 10 percent open area, the owner or operator shall
repair the items as necessary so that none of the conditions specified in this paragraph
exist before refilling the storage vessel with VOL.
It is the understanding of the EPA that the intention of Subpart Kbs internal inspection
requirements are still supported through the use of inspection requirements from Subpart WW
when used at the Superior, Wisconsin facility.
EPA therefore approves your request for alternative monitoring requirements from the
provisions of NSPS Subpart Kb. The requirements of NSPS Subpart Kb continue to apply to the
Enbridge facility in Superior, Wisconsin.
This determination has been made in consultation with the Office of Air Quality Planning
and Standards in Research Triangle Park.
If you have any questions regarding this response, please contact Molly DeSalle at
(312) 353-8773.
Sincerely,

George Czerniak, Branch Chief

Air Enforcement and Compliance Assurance Branch
cc:

Neal Baudhuin, Wisconsin Department of Natural Resources

Bill Baumann, Wisconsin Department of Natural Resources
Randy McDonald, U.S. EPA, OAQPS Resources
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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

on the __________ day of __________ 2010.

________________________
Tracy Jamison
Office Automation Assistant
Air and Radiation Division

Certified Mail Receipt Number:______________________________________________

standard bcc's: official file copy w/attachment(s)

Creation Date:

June 21, 2010

Filename:

C:\EPAWork\Applicability Determinations\5EnbridgeEnergyL_NSPS.doc