Public Notice Copy - Southwest Shipyard LP · Customer Reference Number: CN600135354 ... HAP -...

Public Notice Copy

Draft Permit

and

Air Quality Permit Application Documents

Air Quality Permit Number: 9442

Southwest Shipyard

Channelview, Harris County

Customer Reference Number: CN600135354

Regulated Entity Number: RN100248749

Further information may also be obtained from Southwest Shipyard, L.P., 18310 Market St, Channelview, TX 77530-3858 or by calling Ms. Elizabeth Stanko, Project Manager at (713) 244-1039.

Project Number: 308754

Emission Sources - Maximum Allowable Emission Rates

Permit Number 9442 This table lists the maximum allowable emission rates and all sources of air contaminants on the applicant’s property covered by this permit. The emission rates shown are those derived from information submitted as part of the application for permit and are the maximum rates allowed for these facilities, sources, and related activities. Any proposed increase in emission rates may require an application for a modification of the facilities covered by this permit.

Air Contaminants Data

Emission Point No. (1) Source Name (2) Air Contaminant Name (3) Emission Rates

lbs/hour TPY (4)

MAR-DOCKS Marine Emissions at Docks 1,2,3,4, and 5

VOC 32.7 2.50

CA-1 Carbon Adsorption Unit

VOC 65.56 1.40

IOC-U 0.25 0.01

DRL-1 Drum Loading VOC 3.20 0.62

FE-1 Equipment Fugitives (5)

VOC 0.023 0.079

FUG-LOAD Transfer Equipment Fugitives (5)

VOC 0.10 0.46

NDST-1, NDST-2 Vacuum Pump Exhaust

VOC 4.99 0.35

TANKS-1 Caustic Tanks A201, A202

VOC 0.01 0.01

TANKS-2 Storage Tanks A400-A409

VOC 5.76 9.64

TANKS-3 Storage Tanks A113-A116, A301, A410-A413, A501, A502, A505, A506, A507, A508, A509, A510, A512, and A513

VOC 5.76 21.14

TANKS-4 Wastewater Tanks A302-A304

VOC 0.54 1.36

IOC-U 0.03 0.01

TL-1 Truck Loading VOC 3.60 7.58

VCU-2 and VCU-3 (6) Vapor Combustion Unit Cap

VOC 4.22 5.34

NOx 10.26 3.24

CO 40.50 12.80

SO2 0.02 0.09

PM 1.01 0.32

PM2.5 1.01 0.32

PM10 1.01 0.32

Permit Number 9442 Page 2

Emission Sources - Maximum Allowable Emission Rates


Emission Point No. (1) Source Name (2) Air Contaminant Name (3) Emission Rates

lbs/hour TPY (4)

WWP Wastewater Treatment Plant

VOC 1.01 1.30

All Sources at Site (7)

HAP Individual HAP < 10.00

Total HAP < 25.00

(1) Emission point identification - either specific equipment designation or emission point number from plot plan. (2) Specific point source name. For fugitive sources, use area name or fugitive source name. (3) Exempt Solvent - Those carbon compounds or mixtures of carbon compounds used as solvents which have been

excluded from the definition of volatile organic compound. VOC - volatile organic compounds as defined in Title 30 Texas Administrative Code § 101.1 HRVOC - highly reactive volatile organic compounds as defined in 30 TAC § 115.10 IOC-U - inorganic compounds (unspeciated) NOx - total oxides of nitrogen SO2 - sulfur dioxide PM - total particulate matter, suspended in the atmosphere, including PM10 and PM2.5, as represented PM10 - total particulate matter equal to or less than 10 microns in diameter, including PM2.5, as

represented PM2.5 - particulate matter equal to or less than 2.5 microns in diameter CO - carbon monoxide HAP - hazardous air pollutant as listed in § 112(b) of the Federal Clean Air Act or Title 40 Code of

Federal Regulations Part 63, Subpart C (4) Compliance with annual emission limits (tons per year) is based on a 12-month rolling period. (5) Emission rate is an estimate and is enforceable through compliance with the applicable special condition(s) and

permit application representations. (6) The authorized emissions have been used in the issuance of Emission Reduction Credits and cannot be increased

during the service life of the facility. (EBT Project 431652 and Permit Project 308754). (7) The HAP emission limit applies to all facilities at the site, regardless of authorization mechanism.

Date: XX/XX

Special Conditions

Permit Number 9442

Emission Standards

1. This permit authorizes emissions only from those points listed in the attached table entitled “Emission Sources - Maximum Allowable Emission Rates,” and the facilities covered by this permit are authorized to emit subject to the emission rate limits on that table and other operating requirements specified in the special conditions.

2. Non-fugitive emissions from relief valves, safety valves, or rupture discs of gases containing volatile organic compounds (VOC) at a concentration of greater than 1 percent by weight are not authorized by this permit unless authorized on the maximum allowable emission rates table (MAERT). Any releases directly to atmosphere from relief valves, safety valves, or rupture discs of gases containing VOC at a concentration greater than 1 percent by weight are not consistent with good practice for minimizing emissions. (xx/xx)

Operating Specifications

3. Except as provided for below, the use of compounds at all emissions sources including (but not limited to) degassing, de-heeling, drumming, storage, and tank truck loading is limited to those identified in Attachments I, II, and III. Modifications or construction of new facilities at the site that result in emission increases of the chemicals listed in Attachments I, II, or III or chemicals currently in use and previously authorized through the procedure below can only be approved through the use of the procedure below (if no physical modification/new construction) or through permit amendment. New compounds may be added through the use of the procedure below, 30 TAC Chapter 106, or 30 TAC Chapter 116. (03/08)

A. Short-term (pounds per hour [lb/hr]) and annual (TPY) emissions and calculations shall be completed for each chemical at each affected source. Emission rates (ER) shall be calculated in accordance with the following methods, as documented in the permit amendment application (PI-1 dated August 8, 2007). The calculated ER shall not exceed the maximum allowable emissions rate at any emission point.

B. The Effect Screening Level (ESL) for the material shall be obtained from the current TCEQ ESL list or by written request to the TCEQ Toxicology Division.

C. The total emissions of any compound from all emission points in this permit must satisfy one of the following conditions:

(1) The total maximum ER from all sources is less than 0.04 lb/hr and the ESL greater than 2 µg/m3; or

(2) (ER/ESL)N I ≤ (ER/ESL)Ei

(ER/ESL)N i = maximum hourly ER of the new compound divided by its ESL at emission source i

(ER/ESL)Ei = the highest ratio of any previously authorized compound hourly ER divided by its ESL at emission source i

i = emission sources including (but not limited to) degassing, de-heeling, drumming, storage, and tank truck loading

The above equation must be satisfied for each source where the new compound is emitted.

Special Conditions Permit Number 9442 Page 2

D. The permit holder shall maintain records of the information below and the demonstrations in steps A though C above. The following documentation is required for each compound:

(1) Chemical name(s), composition, and chemical abstract registry number if available.

(2) True vapor pressure at maximum hourly and annual average storage temperature.

(3) Molecular weight.

(4) Storage tanks, loading areas, and fugitive areas where the material is to be handled and the emission control device to be utilized.

(5) Date new compound handling commenced.

(6) Material Safety Data Sheet.

(7) Maximum concentration of the chemical in mole percent (or in weight percent for fugitive areas) in the affected facilities.

E. This condition may not be used for pollutants listed on the most current Air Pollutant Watch List for Channelview or Harris County.

4. The volume of vapor in terms of barrels (bbls) being degassed or vented to the atmosphere shall be limited by the following equation: (03/08)

(BVj)i < (MDLj/SCj)i * 3,500 bbls

Where:

(BVj)i = barge volume of compound j to be vented (bbls) at emission source i.

(MDLj/SCj)i = the minimum degassing level (MDL) of compound j in ppmv as specified in Attachment II or III divided by the vent stream sample concentration (SC) of compound j in ppmv of the compound in barge at emission source i.

5. Drum loading or truck loading of a chemical shall not occur at the same time as the chemical at Docks 1,2,3,4 or 5 is vented to the atmosphere. Operational records shall be kept on site to demonstrate compliance with this special condition. (03/08)

6. A vapor collection system shall be installed which will produce a vacuum in a barge during degassing operation. A minimum vacuum of one-inch water column shall be maintained on the barge during degassing operations when the chemical being degassed is listed in Attachment II or Attachment III. The pressure/vacuum measuring device shall be calibrated at a frequency in accordance with the manufacturer’s specifications, or at least annually, whichever is more frequent, and shall be accurate to within two percent of span or five percent of the design value. Degassing operation shall cease immediately if a negative pressure of at least one inch of water column can not be maintained by the vacuum-assist vapor collection system. The vacuum shall be continuously monitored and recorded hourly during degassing operation. (03/08)


7. All vapor emitted from a barge containing a chemical listed in Attachment II except for component fugitives must be routed to a vapor combustion unit (EPNs VCU-2 or VCU-3) during degassing operation for vapor destruction. Vapors emitted from a barge containing a chemical listed in Attachment III except for component fugitives must be routed to a Carbon Adsorption Unit (EPN CA-1) during degassing operation for vapor destruction. Control must be maintained until the concentration for the chemical being degassed is no greater than the limit as specified in Attachment II or Attachment III prior to the barge being allowed to vent to the atmosphere. (xx/xx)

8. The barge vent stream must be sampled to verify acceptable VOC concentration for a chemical as specified in Attachment II or Attachment III prior to uncontrolled venting. The measurement of the volume of purge gas shall not include any make-up air introduced into the control device. The VOC sampling and analysis shall be performed using an instrument with a flame ionization detector (FID), or a TCEQ-approved alternative detector. The instrument/FID must meet all requirements specified in Section 8.1 of EPA Method 21 (Title 40 Code of Federal Regulations Part 60, Appendix A [40 CRF Part 60]). Sampling shall be performed as follows: (03/08)

A. Immediately prior to performing sampling, the instrument/FID shall be calibrated with zero and span calibration gas mixtures. Zero gas shall be certified to contain between 0 and 10 ppmv total hydrocarbons. Span calibration gas shall be methane at a concentration within between 34,000 and 50,000 ppmv, and certified by the manufacturer to be ± 2 percent accurate. Calibration error for the zero and span calibration gas checks must be less than 5 percent of the span calibration gas value before sampling may be conducted. The results of these checks shall be recorded.

B. The sampling point shall be upstream of the inlet to the control device. The sample ports and the collection system must be designed and operated such that there is no air leakage into the sample probe or the collection system downstream of the barge being purged.

C. During sampling, data recording shall not begin until after two times the instrument response time. The date and time shall be recorded, and VOC concentration shall be monitored for at least 5 minutes, recording 1-minute averages. The highest one-minute average measured concentration for the air contaminant shall not exceed the concentration as specified in Attachment II or Attachment III prior to uncontrolled venting.

9. Audio, olfactory, and visual inspections shall be made of quick connect joints, fittings, and hoses in VOC service during all transfer operations.

A. If a liquid leak is detected during VOC transfer, then the transfer operation shall cease until the leak is repaired.

B. If a vapor leak is detected during VOC transfer, then 30 TAC § 115.214(a)(3)(D) shall apply.

10. Fuel gas combusted at this facility shall be sweet natural gas containing no more than 5 grains of total sulfur per 100 dscf.


Vapor Combustor Units

11. Vapor Combustors (EPNs VCU-2 and VCU-3) shall be designed and operated in accordance with the following requirements (xx/xx):

A. The vapor combustor units (VCUs) shall achieve 99.95% control of the waste gas directed to it. This shall be ensured by maintaining the temperature in, or immediately downstream of, the combustion chamber above 1400°F prior to the initial stack test performed in accordance with Special Condition 18. Following the completion of that stack test, the six-minute temperature shall be maintained above the minimum one-hour average temperature maintained during the last satisfactory stack test.

B. The temperature measurement device shall reduce the temperature readings to an averaging period of 6 minutes or less and record it at that frequency. The temperature monitor shall be installed, calibrated or have a calibration check performed at least annually, and maintained according to the manufacturer’s specifications. The device shall have an accuracy of the greater of ±2 percent of the temperature being measured expressed in degrees Celsius or ±2.5°C.

C. Quality assured (or valid) data must be generated when the VCU is operating except during the performance of a daily zero and span check. Loss of valid data due to periods of monitor break down, out-of-control operation (producing inaccurate data), repair, maintenance, or calibration may be exempted provided it does not exceed 5 percent of the time (in minutes) that the VCU operated over the previous rolling 12 month period. The measurements missed shall be estimated using engineering judgment and the methods used recorded. The vapor combustor shall be operated with no visible emissions and have a constant pilot flame during all times waste gas could be directed to it. The pilot flame shall be continuously monitored by a thermocouple or an infrared monitor. The time, date, and duration of any loss of pilot flame shall be recorded. Each monitoring device shall be accurate to, and shall be calibrated or have a calibration check performed at a frequency in accordance with, the manufacturer’s specifications.

D. Each time a VCU is used, records shall be maintained in accordance with Special Condition 17.

Carbon Adsorption Systems

12. The operations for Attachment III compounds shall vent through a carbon adsorption system (CAS) consisting of at least three activated carbon canisters that are connected in series.

A. The time interval that is less than the carbon replacement interval shall be determined and recorded by the maximum design rate and either the organic concentration or the maximum design.

B. The operator shall replace the carbon canisters in the CAS regularly at the time interval determined in A.

C. Breakthrough shall be defined as a measured VOC concentration of 50 ppmv. Sufficient fresh activated carbon canisters shall be maintained at the site such that spent carbon canisters can be replaced as specified.


D. Records of the CAS monitoring maintained at the plant site shall include (but are not limited to) the following:

(1) Methods and results of the determination of the carbon replacement interval; and

(2) Time and date when the replacement carbon canisters were installed.

These records shall be made readily available upon request to representatives of the TCEQ or any local air pollution control program having jurisdiction upon request to show compliance with this condition, and shall be retained for at least two years following the date that the data is obtained.

Wastewater Treatment

13. This facility shall be used only for the liquid phase separation of VOC and water in which the sum of the partial pressures of all species of VOC in any sample is less than 1.5 psia. Records shall be kept for all samples taken.

A. The holder of this permit shall perform sampling and other testing, as necessary, to establish that the sum of the partial pressures of all species of VOC in any sample is less than 1.5 psia. The results of the monitoring and maintenance efforts shall be recorded, and such records shall be maintained for a period of two years. The records shall be made readily available upon request to representatives of the TCEQ or any local air pollution control program having jurisdiction upon request to show compliance with this condition.

B. All wastewater recovered after the first rinse from barge cleaning shall be routed through the oil/water separator prior to storage and transfer to an approved treatment facility.

C. The operating parameter(s) selected to demonstrate continuous compliance with the design standard and all other operating information that will be used to assess continuous compliance shall be continuously monitored and recorded.

Truck Loading

14. Truck loading operation is limited to the compounds and their respective maximum filling rates as specified in Attachment I, II, or III. All trucks, when loading compounds as specified in Attachment II or III for required vapor balancing, shall use vapor balancing systems to minimize the emissions. All truck loading shall be submerged. (03/08)

The permit holder shall maintain and update monthly an emissions record which includes calculated emissions of VOC from all truck loading operation over the previous rolling 12-month period. The record shall include the loading spot, control method used (if applicable), quantity loaded in gallons, name of the liquid loaded, vapor molecular weight, liquid vapor pressure in psi at monthly average temperature for Houston as detailed in EPA document AP-42 Table 7.1-7, liquid throughput for the previous month and rolling 12 months to date. Emissions shall be calculated using the TCEQ publication titled "Technical Guidance Package for Chemical Sources - Loading Operations." Monthly average temperatures for Houston as detailed in EPA document AP-42 Table 7.1-7 must be used in the calculations.


A. All lines and connectors shall be visually inspected for any defects prior to hookup. Lines and connectors that are visibly damaged shall be removed from service until they are repaired to a leak-free state. Operations shall cease immediately upon detection of any liquid leaking from the lines or connections.

B. Each tank truck shall pass vapor-tight testing every 12 months using the methods described in Title 40 Code of Federal Regulations Part 60 (40 CFR 60), Subpart XX. The permit holder shall not allow a tank truck to be filled unless it has passed a leak-tight test within the past year as evidenced by a certificate which shows the date the tank truck last passed the leak-tight test required by this condition and the identification number of the tank truck.

C. During the truck loading operation, compounds being loaded listed in Attachment II or Attachment III shall not be emitted from any degassing emission point on the site at the same time. The site is limited to one truck loading of the same compound at any time. Barge degassing activities which emit compounds as specified in Attachment II or III shall be documented including the description of the activity, start time, duration, and air contaminants emitted during the period of truck loading operation.

Storage Tanks

15. Storage Tanks shall be designed and operated in accordance with the following requirements (xx/xx):

A. The capacity of any tank at this site used to store chemicals appearing on Attachments I, II, and III shall not exceed 25,000 gallons, with the exception of wastewater and waste oil tanks associated with the Wastewater Treatment System.

B. The holder of this permit shall store all products with a vapor pressure greater than 11.0 psia at maximum storage temperature in pressurized vessel.

C. All storage tanks must be equipped with a permanent submerged fill pipe and utilize bottom loading.

D. The emissions from these facilities must be discharged to the atmosphere at a level no lower than four feet above ground level.

E. Tank exterior surfaces exposed to the sun shall be white.

F. Storage and tank loading operations for tanks associated with EPNs TANKS-2 and TANKS-3 shall be limited to the filling rates represented in Table 3-E submitted April 9, 2008 for Attachment I compounds; Table 4-E submitted August 23, 2010 for Attachment II compounds; and Table 5-E submitted April 9, 2008 for Attachment III compounds. (09/10)

16. Operation without visible liquid leaks or spills shall be maintained at all loading/unloading facilities, regardless of vapor pressure. This does not apply to momentary dripping associated with the initial connection or disconnection of fittings. Sustained dripping from fittings during loading/unloading operations is not permitted. Any liquid spill that occurs during loading/unloading activities shall be reported pursuant to 30 TAC § § 101.201 or 101.211, and shall be cleaned up immediately to minimize air emissions. (8/03)


Continuous Demonstration of Compliance

17. The permit holder shall maintain daily operational records during degassing operations including atmospheric venting. Emission calculations for each chemical degassed or vented and total VOCs from all degassing operations including atmospheric venting shall be maintained on a monthly basis and rolling 12-month period. Monthly records shall at least include the following: (xx/xx)

A. Identification name or number of the barge;

B. Name of the chemicals in the barge;

C. Control method used (if applicable);

D. Molecular weight of each chemical handled;

E. Vapor pressure of each chemical handled in psi at monthly average temperature for Houston as detailed in EPA document AP-42 Table 7.1-7;

F. Time and date of barge degassing or venting commencement;

G. Time and date when barge degassing or venting complete;

H. Volume of barge tanks degassed to control;

I. Concentration of the degassing chemical measured in ppmv prior to the barge being allowed to vent to the atmosphere; and

J. Volume of barge tanks vented to atmosphere;

Stack Sampling

18. The permit holder shall perform stack sampling and other testing as required to establish the actual pattern and quantities of air contaminants being emitted into the atmosphere from vapor combustion units VCU-2 and VCU-3 to demonstrate compliance with MAERT limits and to achieve 99.95% destruction efficiency of VOCs. The permit holder is responsible for providing sampling and testing facilities and conducting the sampling and testing operations at his expense. Sampling shall be conducted in accordance with the appropriate procedures of the Texas Commission on Environmental Quality (TCEQ) Sampling Procedures Manual and the U.S. Environmental Protection Agency (EPA) Reference Methods (xx/xx).

Requirements to waive testing for any pollutant specified in this condition shall be submitted to the TCEQ Office of Air, Air Permits Division. Test waivers and alternate/equivalent procedure proposals for Title 40 Code of Federal Regulation Part 60 (40 CFR Part 60) testing which must have EPA approval shall be submitted to the TCEQ Regional Director.

A. The appropriate TCEQ Regional Office shall be notified not less than 45 days prior to sampling. The notice shall include:

(1) Date sampling will occur.

(2) Name of firm conducting sampling.

(3) Type of sampling equipment to be used.

(4) Method or procedure to be used in sampling.


(5) Description of any proposed deviation from the sampling procedures specified in this permit or TCEQ/EPA sampling procedures.

(6) Procedure/parameters to be used to determine worst case emissions during the sampling period.

B. Air contaminants emitted from the vapor combustion units to be tested for include (but are not limited to) total VOC, NOx, CO, and SO2.

C. Sampling shall occur within 60 days after achieving the maximum operating rate, but no later than 180 days after issuance of the permit application, PI-1 dated November 15, 2019 and at such other times as required by the TCEQ Executive Director. Requests for additional time to perform sampling shall be submitted to the appropriate regional office.

D. The facilities being sampled shall operate at maximum emission rates during stack emission testing. These conditions/parameters and any other primary operating parameters that affect the emission rate shall be monitored and recorded during the stack test. Any additional parameters shall be determined at the pretest meeting and shall be stated in the sampling report. Permit conditions and parameter limits may be waived during stack testing performed under this condition if the proposed parameter range is identified in the test notice specified in paragraph A and accepted by the TCEQ Regional Office. Permit allowable emissions and emission control requirements are not waived and still apply during stack testing periods.

E. Copies of the final sampling report shall be forwarded to the offices below within 60 days after sampling is completed. Sampling reports shall comply with the attached provisions entitled “Chapter 14, Contents of Sampling Reports” of the TCEQ Sampling Procedures Manual. The reports shall be distributed as follows:

One copy to the appropriate TCEQ Regional Office. One copy to each local air pollution control program.

F. Sampling ports and platform(s) shall be incorporated into the design of (source stack and EPN) according to the specifications set forth in the attachment entitled “Chapter 2, Guidelines For Stack Sampling Facilities” of the Texas Commission on Environmental Quality (TCEQ) Sampling Procedures Manual. Alternate sampling facility designs must be submitted for approval to the TCEQ Regional Director.

Compliance Assurance Monitoring

19. The following requirements apply to capture systems for vapor combustion units designated as VCU-2 and VCU-3. (xx/xx)

A. If used to control VOC, either:

(1) Conduct a once a month visual, audible, and/or olfactory inspection of the capture system to verify there are no leaking components in the capture system; or

(2) Once a year, verify the capture system is leak-free by inspecting in accordance with 40 CFR Part 60, Appendix A, Test Method 21. Leaks shall be indicated by an instrument reading greater than or equal to 500 ppmv above background.

B. The control device shall not have a bypass.

or

If there is a bypass for the control device, comply with either of the following requirements:


(1) Install a flow indicator that records and verifies zero flow at least once every fifteen minutes immediately downstream of each valve that if opened would allow a vent stream to bypass the control device and be emitted, either directly or indirectly, to the atmosphere; or

(2) Once a month, inspect the valves, verifying the position of the valves and the condition of the car seals prevent flow out the bypass.

A deviation shall be reported if the monitoring or inspections indicate bypass of the control device.

C. Records of the inspections required shall be maintained and if the results of any of the above inspections are not satisfactory, the permit holder shall promptly take necessary corrective action.

Emission Reduction Credits

20. Emission Reduction Credits (ERCs) were issued for the permanent shutdown of the following facilities: FIN BRGCLN/EPN FL-3 and FIN BRGCLN/EPN FL-1. The permit holder shall not restart or operate at the site any of the facilities associated with the issuance of the ERCs, regardless of whether the certified ERCs are used, are transferred, or expire (EBT Project 413652 and Permit Project 308754). These limits are effective until these facilities are permanently removed from the site. (xx/xx)

Date: DRAFT

Attachment I

Permit Number 9442

Compounds Which Do Not Require Any Control

CAS No. Compound Truck Loading Max Filling Rate (gal/hr)

68551-12-2 Alpha olefins (C12-C16) 18,000

N/A Alpha olefins (C16-C20) 18,000

93924-10-8 Alpha olefins (C20-C24) 18,000

10043-01-3 Aluminum sulfate 18,000

110-63-4 Butylene glycol 18,000

7789-41-5 Calcium bromide 18,000

10043-52-4 Calcium chloride 18,000

1310-73-2 Caustic soda solution (sodium hydroxide) 18,000

111-46-6 Diethylene glycol (vapor) 18,000

28553-12-0 Diisononyl phthalate 18,000

110-98-5 Dipropylene glycol 18,000

119-06-2 Ditridecyl phthalate 18,000

149-57-5 Ethylhexanoic acid, 2- 18,000

7720-78-7 Ferrous sulfate 18,000

N/A Fertilizer solutions 18,000

N/A Fuel Oil 6 (Bunker C) 6,000

56-81-5 Glycerin 18,000

8001-26-1 Linseed oil 18,000

N/A Lube oil 18,000

N/A Lube oil additives 18,000

N/A Molasses 18,000

8002-64-0 Neatsfoot oil 18,000

N/A Petroleum Distillates (Marine Diesel Oil, Lube Oil) 6,000

7664-38-2 Phosphoric acid 18,000

N/A Refinery Distillates (Light Cycle Oil, Gas oil) 6,000

N/A Salt water 18,000

497-19-8 Soda ash 18,000

7558-80-7 Sodium phosphate 18,000

6834-92-0 Sodium silicate 18,000

7757-82-6 Sodium sulfate 18,000

7664-93-9 Sulfuric acid 18,000

24800-44-0 Tripropylene glycol 18,000

Attachment I Permit Number 9442 Page 2

Compounds Which Do Not Require Any Control

CAS No. Compound Truck Loading Max Filling Rate (gal/hr)

57-13-6 Urea 18,000

Dated: October 22, 2010

Attachment II

Permit Number 9442

Compounds Routed to Vapor Combustion Unit

CAS No. Compound Truck Loading Max Filling Rate

(gal/hr)

Truck Loading Vapor Balancing

Required

Minimum Degassing

Level (ppmv)

64-19-7 Acetic acid 18,000 Yes 50

108-24-7 Acetic anhydride 11,000 No 50

67-64-1 Acetone 12,000 Yes 50

75-86-5 Acetone cyanohydrin 18,000 No 50

75-05-8 Acetonitrile 18,000 Yes 50

98-86-2 Acetophenone 18,000 No 50

79-10-7 Acrylic acid 18,000 No 50

107-13-1 Acrylonitrile 18,000 Yes 50

111-69-3 Adiponitrile 18,000 No 50

N/A Alkylates 18,000 Yes 50

67774-74-7 Alkylbenzene 18,000 No 50

626-63-7 Amyl acetate, n- 18,000 Yes 50

71-41-0 Amyl alcohol 16,500 No 50

62-53-3 Aniline 18,000 No 50

8052-42-4 Asphalt 18,000 No 50

N/A Aviation gasoline 6,000 Yes 50

71-43-2 Benzene 6,000 Yes 50

71-36-3 Butanol 12,000 No 50

123-86-4 Butyl acetate, n- 4,500 No 50

141-32-2 Butyl acrylate 9,000 No 50

75-65-0 Butyl alcohol, t- 18,000 Yes 50

75-64-9 Butyl amine, t- 5,100 Yes 50

142-96-1 Butyl ether 7,500 No 50

590-01-2 Butyl proprionate 18,000 No 50

105-60-2 Caprolactum 18,000 No 50

110-80-5 Cellosolve 12,500 No 50

111-15-9 Cellosolve acetates 18,000 No 50

8001-29-4 Cottonseed oil 17,500 No 50

1319-77-3 Cresylate 18,000 Yes 50

319-77-3 Cresylic acid 18,000 No 50

Attachment II Permit Number 9442 Page 2



(gal/hr)


Required

Minimum Degassing

Level (ppmv)

8002-05-9 Crude Oil 6,000 Yes 50

98-82-8 Cumene 4,500 No 50

110-82-7 Cyclohexane 18,000 Yes 50

108-93-0 Cyclohexanol 14,500 No 50

108-94-1 Cyclohexanone 18,000 Yes 50

112-30-1 Decanol 18,000 No 50

872-05-9 Decene 18,000 No 50

68515-43-5 Dialkyl Phthalates 15,000 Yes 50

84-74-2 Dibutyl phthalate 18,000 No 50

77-73-6 Dicyclopentadiene 12,000 No 50

N/A Diesel 18,000 No 50

111-42-2 Diethanolamine 18,000 No 50

108-83-8 Diisobutyl ketone 18,000 No 50

12002-23-2 Diisobutylene 18,000 Yes 50

117-84-0 Dioctyl phthalate 18,000 No 50

6842-15-5 Dodecene 18,000 No 50

112-53-8 Dodecyl alcohol 18,000 No 50

N/A Dripolene 18,000 Yes 50

N/A Edible oils 18,000 No 50

64-17-5 Ethanol 18,000 Yes 50

141-43-5 Ethanolamine 18,000 No 50

141-78-6 Ethyl acetate 18,000 Yes 50

140-88-5 Ethyl acrylate 12,000 Yes 50

75-04-7 Ethyl amine 8,000 Yes 50

100-41-4 Ethyl benzene 6,000 No 50

103-11-7 Ethyl hexyl acrylate 18,000 No 50

104-76-7 Ethyl hexyl alcohol 18,000 No 50

107-15-3 Ethylene diamine 18,000 Yes 50

107-21-1 Ethylene glycol 18,000 No 50




(gal/hr)


Required

Minimum Degassing

Level (ppmv)

N/A Fatty acid 18,000 No 50

N/A Fatty alcohol 13,000 No 50

8002-50-4 Fish oil 17,500 No 50

50-00-0 Formalin (37-50% formaldehyde)

18,000 No 50

98-01-1 Furfural 18,000 No 50

8006-61-9 Gasoline 6,000 Yes 50

N/A Gasoline additives 10,000 Yes 50

N/A Heavy aromatics 6,000 No 50

142-82-5 Heptane 18,000 Yes 50

124-09-4 Hexamethylenediamine soln. 8,000 No 25

110-54-3 Hexane 12,000 Yes 50

111-27-3 Hexanol 18,000 Yes 50

592-41-6 Hexene 10,500 Yes 50

N/A Hydraulic oil 18,000 No 50

N/A Isoamyl ketone 18,000 Yes 50

78-83-1 Isobutanol 18,000 Yes 50

78-79-5 Isoprene 5,950 Yes 50

67-63-0 Isopropyl alcohol 18,000 Yes 50

N/A Jet Fuel A 6,000 No 50

N/A Jet Naphtha (JP-4) 6,000 Yes 50

8008-20-6 Kerosene 18,000 No 50

67891-80-9 Light Aromatic Distillate 13,000 No 50

64742-94-5 Light aromatic naphtha 18,000 No 50

141-79-7 Mesityl oxide 6,000 No 50

79-41-4 Methacrylic acid 18,000 No 50

67-56-1 Methanol 18,000 Yes 50

96-33-3 Methyl acrylate 18,000 Yes 50

108-11-2 Methyl amyl alcohol 9,000 No 50

78-93-3 Methyl ethyl ketone 18,000 Yes 50




(gal/hr)


Required

Minimum Degassing

Level (ppmv)

108-10-1 Methyl Isobutyl Ketone 18,000 Yes 50

563-80-4 Methyl isopropyl ketone 14,500 Yes 50

80-62-6 Methyl methacrylate 18,000 Yes 50

98-83-9 Methyl styrene, a- 6,000 No 50

1634-04-4 Methyl tert butyl ether (MTBE) 7,500 Yes 50

8012-95-1 Mineral oil 18,000 No 50

8030-30-6 Naphtha (<2% Benzene) 6,000 Yes 50

91-20-3 Naphthalene (<5% Benzene) 6,000 Yes 50

91-20-3 Naphthalene concentrate 18,000 Yes 50

1338-24-5 Naphthenic Acid 12,000 No 50

N/A Natural gasoline 6,000 Yes 50

N/A Neodol 18,000 No 50

98-95-3 Nitrobenzene 18,000 No 50

79-24-3 Nitroethane 18,000 Yes 50

625-48-9 Nitroethanol 18,000 No 50

79-46-9 Nitropropane 18,000 Yes 50

124-11-8 Nonene 9,500 No 50

25154-52-3 Nonyl phenol 15,500 No 50

111-65-9 Octane 5,500 No 50

111-87-5 Octanol 18,000 No 50

111-66-0 Octene, 1- 18,000 Yes 50

N/A Olefins, a- (<C12) 18,000 Yes 50

8002-74-2 Paraffin (distillates) 18,000 No 50

8002-03-7 Peanut oil 7,500 No 50

504-60-9 Pentadiene, 1,3- (piperylene) 7,000 Yes 50

624-54-4 Pentyl propionate 9,000 Yes 50

N/A Petroleum jelly 18,000 No 50

N/A Petroleum wax 18,000 No 50

108-95-2 Phenol 18,000 No 50




(gal/hr)


Required

Minimum Degassing

Level (ppmv)

25322-69-4 Polyglycol 18,000 No 50

9003-27-4 Polyisobutylene 6,000 No 50

25322-69-4 Polyol 18,000 No 50

71-23-8 Propanol 18,000 Yes 50

79-09-4 Propionic acid 18,000 No 50

109-60-4 Propyl acetate 18,000 Yes 50

57-55-6 Propylene Glycol 18,000 No 50

68514-29-4 Raffinate (<5% Benzene) 6,000 Yes 50

N/A Refinery petroleum products (< 10% benzene)

6,000 No 50

N/A Reformate (< 5% benzene) 6,000 Yes 50

64742-48-9 Reformer feed 9,000 Yes 50

9003-35-4 Resin oil 14,000 No 50

100-42-5 Styrene 6,000 Yes 50

126-33-0 Sulfolane 18,000 No 50

8002-26-4 Tall oil 10,000 No 50

61789-97-7 Tallow 17,500 No 50

112-60-7 Tetraethylene glycol 18,000 No 50

109-99-9 Tetrahydrofuran 14,000 Yes 50

25265-77-4 Texanol 18,000 No 50

108-88-3 Toluene 18,000 Yes 50

112-70-9 Tridecanol 18,000 No 50

102-71-6 Triethanolamine 18,000 No 50

112-27-6 Triethylene glycol 18,000 No 50

8006-64-2 Turpentine 18,000 Yes 50

8001-22-7 Vegetable oil 17,500 No 50

108-05-4 Vinyl acetate 15,000 Yes 50

N/A Wastewater (Untreated) 18,000 No 50

1330-20-7 xylene, mixed or all isomers, except p-

7,500 No 50




(gal/hr)


Required

Minimum Degassing

Level (ppmv)

106-42-3 xylene, p- 7,000 No 50


Attachment III

Permit Number 9442

Compounds Routed to Carbon Adsorber


(gal/hr)


Required

Minimum Degassing

Level (ppmv)

107-05-1 Allyl chloride 18,000 Yes 50

56-23-5 Carbon tetrachloride 18,000 Yes 50

N/A Chlorinated solvent 18,000 Yes 50

108-90-7 Chlorobenzene 18,000 No 50

67-66-3 Chloroform 18,000 Yes 50

95-50-1 Dichlorobenzene, o- 18,000 No 50

107-06-2 Dichloroethane, 1,2- 18,000 Yes 50

540-59-0 Dichloroethylene, 1,2- 18,000 Yes 50

106-89-8 Epichlorohydrin 18,000 Yes 50

N/A Hydrochloric Acid 18,000 Yes 50

75-09-2 Methylene chloride 18,000 Yes 50

78-87-5 Propylene dichloride 18,000 Yes 50

127-18-4 Tetrachloroethylene 18,000 Yes 50

71-55-6 Trichloroethane, 1,1,1- 18,000 Yes 50

79-01-6 Trichloroethylene 18,000 Yes 50

96-18-4 Trichloropropane, 1,2,3- 18,000 No 50


November 8, 2019 SUBMITTED VIA STEERS

Air Permits Initial Review Team (APIRT) Texas Commission on Environmental Quality (TCEQ) 12100 Park 35 Circle, MC‐161 Building C, Third Floor, Room 300 W Austin, Texas 78753

Subject: NSR Permit Amendment Permit No. 9442 Barge Cleaning and Degassing Facility Southwest Shipyard, L.P. Channelview Facility Channelview, Harris County Regulated Entity Number: RN100248749 Customer Reference Number: CN600135354

Dear Sir or Madam:

On behalf of Southwest Shipyard, L.P. (Southwest Shipyard), TRC Environmental Corporation (TRC) hereby submits the following minor New Source Review (NSR) permit amendment application. The purpose of this amendment application is to consolidate by incorporation Pollution Control Project (PCP) Standard Permit No. 154687 into NSR Permit 9442.

An electronic version of the application, including the Excel workbook Form PI‐1 General Application (version 4.0) has been submitted to the TCEQ Air Permits Division via STEERS e‐Permits, and the appropriate permit application fee was paid electronically during the online submission.

Attached to this letter you will find a complete application with all required administrative and technical information. Should you have any questions regarding this submittal, please contact me at 713‐244‐1039 or via email at [email protected].

Sincerely,

TRC Environmental Corporation

Elizabeth Stanko

Project Manager

Attachments

cc: Air Section Manager, TCEQ Region 12, Houston (STEERS) Harris County Public Health & Environmental Services, Attn: Air Section Manager (STEERS) Mr. Bernard Diaz, Managing Director of Environmental Operations, Southwest Shipyard, L.P. (Electronic)

TRC Environmental Corporation | Southwest Shipyard, L.P. © 2011 RMT, Inc.

All Rights Reserved Final 10/29/2019 \\HOUSTON‐FP1\DATA\PROJECTS‐PPL\WPHOU\PJT2\340745\0000\R340745.0000‐001.DOCX

10550 RICHMOND AVENUE, SUITE 210, HOUSTON, TEXAS 77042 ● 713.244.1000 PHONE ● 713.789.5920 FAX ● WWW.TRCCOMPANIES.COM

TCEQ Permit Amendment Application NSR Permit 9442

Barge Degassing and Cleaning Facility

Channelview, Harris County, Texas

November 2019

Prepared For

Southwest Shipyard, L.P.

TRC Environmental Corporation | Southwest Shipyard, L.P. i \\HOUSTON‐FP1\DATA\PROJECTS‐PPL\WPHOU\PJT2\340745\0000\R340745.0000‐001.DOCX 10/29/2019 Final November 2019

Table of Contents

1. Introduction ................................................................................................................................... 1‐1

1.1 Overview of Permitted Sources ....................................................................................... 1‐1

1.2 Purpose of Amendment Application .............................................................................. 1‐1

1.3 Administrative Information ............................................................................................. 1‐2

1.3.1 Administrative Information (Appendix A) ....................................................... 1‐3

1.3.2 Emission Calculations (Appendix B) .................................................................. 1‐3

1.3.3 Impacts Analysis (Appendix C) .......................................................................... 1‐3

1.3.4 Current Permits (Appendix D) ............................................................................ 1‐3

1.4 Summary of Emission Changes ....................................................................................... 1‐3

1.5 Federal Permitting Applicability ..................................................................................... 1‐4

1.5.1 NNSR Applicability .............................................................................................. 1‐4

1.5.2 PSD Applicability .................................................................................................. 1‐5

1.6 Public Notice Applicability ............................................................................................... 1‐5

1.7 Permit Application Fee ...................................................................................................... 1‐5

1.8 Area Map and Plot Plan .................................................................................................... 1‐5

2. Process Description ...................................................................................................................... 2‐1

3. Emission Calculations .................................................................................................................. 3‐1

3.1 VCU Products of Combustion .......................................................................................... 3‐1

3.2 Marine Barge Degassing and Cleaning Emission Calculations ................................... 3‐2

3.3 Equipment Leak Fugitives ................................................................................................ 3‐2

4. Updates to Permit Conditions and MAERT ............................................................................. 4‐1

5. Regulatory Requirements Discussion ........................................................................................ 5‐1

List of Tables

Table 1‐1 Emission Summary for Project Related Sources ............................................... 1‐4

List of Figures Figure 1‐1 Area Map ................................................................................................................ 1‐6

Figure 1‐2 Plot Plan .................................................................................................................. 1‐7

Figure 2‐1 Process Flow Diagram .......................................................................................... 2‐2

TRC Environmental Corporation | Southwest Shipyard, L.P. ii \\HOUSTON‐FP1\DATA\PROJECTS‐PPL\WPHOU\PJT2\340745\0000\R340745.0000‐001.DOCX 10/29/2019 Final November 2019

List of Appendices

Appendix A Form PI‐1 General Application

Appendix B Emission Calculations

Appendix C Impacts Analysis

Appendix D Current Permits

TRC Environmental Corporation | Southwest Shipyard, L.P. 1‐1 \\HOUSTON‐FP1\DATA\PROJECTS‐PPL\WPHOU\PJT2\340745\0000\R340745.0000‐001.DOCX 10/29/2019 Final November 2019

Section 1 Introduction

1.1 Overview of Permitted Sources Southwest Shipyard, L.P. (Southwest Shipyard) owns and operates a barge cleaning and repair

facility located at 18310 Market Street in Channelview, Harris County, Texas. This site, referred

to as the Channelview site, performs marine vessel and barge cleaning and repair activities,

which involve stripping and degassing marine tank barges as well as painting barges. The

Texas Commission on Environmental Quality (TCEQ) Customer Number (CN) for Southwest

Shipyard is CN600135354. The Regulated Entity Number (RN) for the Channelview site is

RN100248749, and the TCEQ account number is HG‐0686‐T.

TCEQ New Source Review (NSR) Permit No. 9442 authorizes the degassing and cleaning of

marine tank barges at the Channelview site’s barge front cleaning docks. At this facility, barges

are cleaned and degassed utilizing a vapor collection system, which produces a vacuum in the

barge, and routes the vapors to a control device for volatile organic compound (VOC)

destruction, as applicable.1

NSR Permit No. 9442 authorizes two flares [Emission Point Numbers (EPNs): FL‐1 and FL‐3],

which are used to control barge degassing emissions. The two flares (EPNs: FL‐1 and FL‐3) are

being replaced with two new Vapor Combustor Units (VCUs) (EPNs: VCU‐2 and VCU‐3) for

the control of the barge and marine vessel degassing operations. The replacement of the control

equipment is authorized by TCEQ Pollution Control Project Standard Permit (PCP SP) No.

154687, issued in December 2018 2. The new VCUs are currently under construction and the

installation is anticipated to occur in November 2019.

1.2 Purpose of Amendment Application The purpose of this amendment application is to consolidate by incorporation PCP Standard

Permit No. 154687 into NSR Permit 9442. The standard permit to be incorporated will result in

a federally enforceable reduction of over 22 tons per year (TPY) of authorized VOC emissions

from the control of the barge and marine vessel degassing operations. Additionally, the

1 NSR Permit 9442, Attachments II and III, list the chemical compounds that must be controlled during degassing

operations. Chemicals listed in Attachments II and III are routed to a flare (EPN FL‐1 or FL‐3), and a Carbon

Adsorption Unit (EPN CA‐1), respectively, for vapor destruction. 2 PCP Standard Permit 154687 was issued on December 12, 2018 (TCEQ Project No. 293968), and a copy of this

registration letter is included in Appendix D.


replacement of the flares with the new VCUs will result in a decrease in short‐term (hourly)

VOC emissions of over 85 pounds VOC per hour (lb/hr). This is because the proposed VCUs

(EPNs: VCU‐2 and VCU‐3) have a higher VOC destruction efficiency than the flares, and each

VCU will have a minimum VOC Destruction and Removal Efficiency (DRE) of 99.95 percent. In

contrast, the flares have a VOC DRE of 98 percent.

Given the pollution control project, Southwest Shipyard applied for Certification of Emission

Reduction Credits (ERCs) with ERC Generation Project No. 413652, which is currently pending

and under review. Southwest Shipyard seeks to generate ERCs by ensuring the strategic

emissions from the control equipment replacement project are permanent and enforceable.

Accordingly, PCP SP 154687 must be fully incorporated into NSR Permit Number 9442 to

remove the flares and reflect the emission reduction in accordance with Title 30 of the Texas

Administrative Code (30 TAC) §101.303(d)(4).

Southwest Shipyard is submitting an amendment to Permit No. 9442 to accomplish the

following objectives:

Consolidate by incorporation PCP Standard Permit No. 154687 into NSR Permit 9442 in an

expedited manner, such that it won’t delay the approval of ERC Generation Project No.

413652. As such, no changes to any other sources are requested as part of this amendment.

Additionally, NSR Permit 9442 is due for renewal next year (October 22, 2020), and the

renewal project will update any other outstanding items that may need to be addressed.

Delete the flares (EPNs: FL‐1 and FL‐3) from the NSR permit and replace with the new

VCUs (EPNs: VCU‐2 and VCU‐3).

Update the Maximum Allowable Emission Rate Table (MAERT) and Special Conditions to

reflect the standard permit consolidation, as well as include conditions that reflect the ERC

generation project using specific language provided by the TCEQ Emissions Banking and

Trading Program. The proposed language is included in Section 4 of this application.

1.3 Administrative Information This permit amendment application is being submitted in accordance with 30 TAC Chapter 116,

Subchapter B. A completed Excel workbook Form PI‐1 General Application (version 4.0) with

additional support information is included in this submittal. A discussion of project‐related

emission rate changes, federal applicability, public notice applicability, and the TCEQ permit

application fee are provided in Sections 1.4 through 1.7 of this section, respectively.

An area map indicating the site location and plot plan identifying the location of the project

emission sources are included in Figures 1‐1 and 1‐2 of this section, respectively. A process


description and process flow diagram are presented in Section 2. The emission calculations for

the project‐related sources can be found in Section 3 of this application, which were previously

submitted with the PCP SP. The Best Available Control Technology (BACT) analysis is

included in the Excel workbook Form PI‐1 General Application. Identification of applicable

federal and state regulatory requirements and compliance with these requirements is

demonstrated in Section 5.

To assist in the review of this submittal, the following appendices are included:

1.3.1 Administrative Information (Appendix A)

Appendix A of this application contains the Form PI‐1 General Application; Excel

workbook file, which has been submitted electronically through the State of Texas

Environmental Electronic Reporting System (STEERS) e‐Permits system.

1.3.2 Emission Calculations (Appendix B)

A copy of the emission rate calculations previously submitted with the PCP SP

registration are included in Appendix B.

1.3.3 Impacts Analysis (Appendix C)

Appendix C contains the Air Quality Analysis (AQA) submitted in support of this

application. Modeling impacts were assessed qualitatively using the impacts analysis

that was previously submitted to TCEQ in support of the PCP SP Project No. 154687,

issued in December 2018.

1.3.4 Current Permits (Appendix D)

A copy of Standard Permit Registration No. 154687 (Pollution Control Projects Air

Quality Standard Permit) and NSR Permit No. 9442 is provided in Appendix D.

1.4 Summary of Emission Changes Emissions associated with this project consist of VOCs from the barge degassing and cleaning

operations, as well as nitrogen oxides (NOX), carbon monoxide (CO), and sulfur dioxide (SO2)

due to the products of combustion. The replacement of the flares with the new VCUs will result

in a decrease in short‐term and annual VOC emissions. The incorporation of the PCP SP will

result in an increase in annual NOX emissions (less than one TPY NOX), as well as an increase in

hourly and annual CO emissions (less than one TPY CO) due to the change in emission factors

for NOX and CO. The incorporation of the PCP SP will also result in a small increase in SO2

emissions due to the use of supplemental assist natural gas, which has always been present but


never before specified in the flare permitting. An emissions summary of the project sources is

provided in Table 1‐1.

Table 1-1 Emission Summary for Project Related Sources

Air Contaminant

Incorporation of PCP SP for Vapor Combustor

Units (EPNs: VCU-2 and VCU-3)

Existing Flares being Replaced

(EPNs: FL-1 and FL-3)

Change in Emissions due to Replacement of

Emissions Control Equipment

(lb/hr) (tons/yr) (lb/hr) (tons/yr) (lb/hr) (tons/yr)

VOC 4.22 5.34 89.26 27.73 -85.04 -22.39

NOx 10.26 3.24 10.33 2.46 -0.07 0.78

CO 40.50 12.80 20.63 12.20 19.87 0.60

SO2 0.02 0.09 -- -- 0.02 0.09

The emission calculation methodologies for the project emission sources are described in

Section 3 of this application. Detailed emission calculations are included in Appendix B.

1.5 Federal Permitting Applicability The Southwest Shipyard Channelview site is an existing major stationary source for VOC

emissions. Therefore, an evaluation of both Prevention of Significant Deterioration (PSD)

applicability and Nonattainment New Source Review (NNSR) applicability needs to be

conducted for any “project” to be authorized at the site. The regulated pollutants evaluated for

this application are VOC, NOX, CO, and SO2. NNSR and PSD applicability evaluations are

discussed in the following sections.

1.5.1 NNSR Applicability

The Southwest Shipyard Channelview site is located in Harris County, Texas. Harris

County is designated as a serious nonattainment area for ozone under the eight‐hour

standard, for which emissions of NOX and VOC are regulated as precursors to ozone.

Harris County is designated an unclassifiable/attainment area for all other criteria

pollutants.

There are no increases in VOC emissions associated with this project, and the NNSR

analysis for the increase in NOX emissions (< 1 TPY) due to the PCP SP being

incorporated in this amendment was done at the time of the standard permit project

authorization and is therefore not part of this review. Therefore, contemporaneous

netting is not required, and NNSR review is not applicable.


1.5.2 PSD Applicability

Harris County is designated an attainment area for all other criteria pollutants. The PSD

analysis for the increase in CO and SO2 emissions due to the PCP SP being incorporated

in this amendment was done at the time of the standard permit project authorization

and is therefore not part of this review. Therefore, PSD review is not required.

1.6 Public Notice Applicability Public notice is not applicable for this permit application per the requirements of 30 TAC

§39.402.

1.7 Permit Application Fee Based on Form PI‐1 General Application, the permit amendment fee was determined to be $900

(minimum fee). The permit amendment fee has been paid online through the TCEQ ePay

system during the online submission via STEERS e‐Permits.

1.8 Area Map and Plot Plan Southwest Shipyard’s Channelview site is located at 18310 Market Street in Channelview,

Texas. The enclosed Area Map, Figure 1‐1, has been included with this permit amendment

application to illustrate the location of the property and surrounding area. The area map

includes a true north arrow, an accurate scale, the entire plant property, the location of the

property relative to prominent geographical features, industrial and non‐industrial

classification, and the location of the nearest schools. Figure 1‐1 includes a circle of 3,000‐ft

radius and a circle of one‐mile radius around the center of the facility. The area map includes

current aerial photography to depict the land use surrounding the facility. There are no schools,

hospitals, nursing homes, or child care facilities within a one‐mile radius of the facility. The

nearest school is located approximately 1.9 miles north of the facility.

The enclosed Plot Plan, Figure 1‐2, shows the location of the new control equipment (EPNs:

VCU‐2 and VCU‐3) and their associated UTM coordinates. The plot plan is to scale and

includes a true north arrow, all property lines, project emission sources, and two bench mark

locations. The plot plan includes current aerial photography to show the buildings, tanks, and

other process equipment located at the Channelview site.

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10550 Richmond Ave.Suite 210

Houston, TX 77042Phone: 713.244.1000

Fig 1 - SW ShipYard-Channelview - Area Map.dwg

DATE: NOVEMBER 2019

APPROVED BY: E. STANKO

CHECKED BY: E. STANKO

DRAWN BY: O. FONSEKA 341760.0000PROJECT No.:

FIGURE 1-1

TITLE:

PROJECT:

.

AREA MAP

.

SOUTHWEST SHIPYARD, L.P.

Channelview Yard

18310 Market Street, Channelview, TX 77530

SCALE IN FEET

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DRAWN BY: O. Fonseka

PROJ. No: 340745.0000.0000APPROVED BY: A. Ochoa

DATE: NOVEMBER 2019

L E G E N D

EPN LOCATIONS

BENCHMARK LOCATION

PROPERTY BOUNDARY

IMAGERY SOURCE: Google Earth (10/28/2017)

EPN

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(METERS)

NORTH

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UTM COORDINATES

300,247 3,297,305


Section 2 Process Description

Southwest Shipyard’s barge cleaning and repair facility has been in operation since the early

1960s. The degassing and cleaning of marine tank barges occurs adjacent to the Channelview

site’s barge cleaning docks.

The barges degassed and cleaned at this facility are used to transport a variety of chemicals and

other liquid products, including crude oil and its petroleum distillates. Many of the barges

handled at Southwest Shipyard are stripped or empty prior to arrival at the site. However,

some barges may contain residual product or cargo. If residual product is found to be present,

it is drained from the barges (a process known as deheeling) prior to degassing. Following the

deheeling process, barges are cleaned and degassed utilizing a vapor collection system, which

produces a vacuum in the barge, and routes the vapors to a control device for volatile organic

compound (VOC) destruction, as applicable.3

Vapors within a barge or marine vessel containing a chemical listed in Attachment II of NSR

Permit No. 9442 are currently routed to one of two flares (EPNs: FL‐1 or FL‐3) for VOC vapor

destruction. The two flares (EPNs: FL‐1 and FL‐3) are being replaced with two new Vapor

Combustor Units (VCUs) (EPNs: VCU‐2 and VCU‐3) for the control of the barge and marine

vessel degassing operations, which are currently under construction. The replacement of the

control equipment is authorized by TCEQ PCP SP No. 154687, issued in December 2018. The

VCUs have a higher VOC DRE than the existing flares, which will result in a substantial

decrease in authorized VOC emissions at the site.

A process flow diagram is included as Figure 2‐1.

3 NSR Permit 9442, Attachments II and III, list the chemical compounds that must be controlled during degassing

operations. Chemicals listed in Attachments II and III are routed to a flare (EPN FL‐1 or FL‐3), and a Carbon

Adsorption Unit (EPN CA‐1), respectively, for vapor destruction.

FILE:

8.5x11 --- ATTACHED XREF'S: --- ATTACHED IMAGES: dcp_color_blk_type; PFD-ImageSlide1; TEXAS- San Angelo;DRAWING NAME: L:\Client-NAME- P-Q-R-S-T\Southwest Shipyard, L.P\Channelview Yard\319247\ Fig 2-1 - SW ShipYard-Channelview - PFD.dwg --- PLOT DATE: October 23, 2019 - 4:11PM --- LAYOUT: LAYOUT


Houston, TX 77042Phone: 713.244.1000

Fig 2-1 - SW ShipYard-Channelview - PFD.dwg

DATE: NOVEMBER 2019


CHECKED BY: N. HALAGERI

DRAWN BY: O. FONSEKA 319247.0000.0000PROJECT No.:

FIGURE 2-1

TITLE:

PROJECT:

.

PROCESS FLOW DIAGRAM

Channelview Yard



L E G E N D

PROCESS FLOW

AIR EMISSIONS


Section 3 Emission Calculations

This section describes and summarizes the air emissions associated with this permit

amendment application. The emission rate calculations provided in this section were

previously submitted with the PCP SP registration issued in December 2018.

Installation of the VCUs (EPNs: VCU‐2 and VCU‐3) only affects barge degassing and cleaning

emissions controlled by the Flares (EPNs: FL‐1 and FL‐3). As such, only emissions associated

with the VCUs that will replace the flares are provided. A summary of the maximum allowable

emission rates (MAER) for the VCUs is provided in the Excel workbook Form PI‐1 General

Application located in Appendix A. Detailed emission calculation tables are provided in

Appendix B.

3.1 VCU Products of Combustion Emissions of NOX and CO products of combustion from the two VCUs were calculated using

the maximum hourly and annual heat of combustion, as well as vendor‐provided emissions

factors. Per the vendor guarantee, the VCUs have a combined maximum heat input rating of

135 MMBtu/hr, which was used in the maximum hourly calculations. For the annual

calculations, a review of the emissions inventories for the previous five years indicated that the

maximum annual heat of combustion is not expected to exceed 85,356 MMBtu/yr. The vendor‐

guaranteed NOX and CO emission factors of 0.076 lb NOX/MMBtu and 0.3 lb CO/MMBtu were

then multiplied by the respective hourly and annual heats of combustion in order to determine

the maximum allowable emission rates using the equations below.

Hourly Emissions (lb/hr) = (Maximum Heat Release, MMBtu/hr) × (Emission Factor,

lb/MMBtu)

Annual Emissions (tpy) = (Average Heat Release, MMBtu/yr) × (Emission Factor,

lb/MMBtu) × (1 ton/2000 lb)

Additionally, SO2 emissions from supplemental assist natural gas were calculated using the

maximum supplemental natural gas flow rate and the SO2 emission factor from US EPA AP‐42

Chapter 1.4 – Natural Gas Combustion Table 1.4‐2. Note that since the NOX and CO emission

limits are based on maximum unit capacity, the supplemental assist natural gas will not

contribute to additional NOX or CO emissions.

The maximum hourly and annual NOX, CO, and SO2 emissions from the new VCUs (EPNs:

VCU‐2 and VCU‐3) are provided in Table B‐1 in Appendix B.


3.2 Marine Barge Degassing and Cleaning Emission Calculations Short‐term VOC emissions for controlled barge degassing and cleaning operations were

calculated using the ideal gas law, which is consistent with the current NSR Permit 9442 basis

for the VOC vapors sent to the flares for control. The maximum rated flow rate of 90,000

standard cubic feet per hour (scfh), which is 1,500 standard cubic feet per minute (scfm) for the

new control equipment, as well as a maximum temperature of 100°F (560 °Rankine) was

utilized. The vapor pressure at 100°F (560 °Rankine) was utilized as well, representing the

short‐term maximum vapor pressure. It was conservatively assumed that the entire barge

vapor was saturated with vapors for the handled products.

The maximum hourly emission rate using these variables was calculated for each chemical

product that is currently authorized, and then the vendor‐guaranteed VOC DRE of 99.95

percent was applied to determine the maximum potential emission rate for all handled chemical

compounds. The list of chemicals used in the VOC emission calculations are the compounds

that were authorized to be routed to the flares (equipment being replaced) as specified in the

NSR Permit 9442, Attachment II.

The annual VOC emissions were calculated using the same ideal gas law methodology that is

consistent with the current NSR Permit 9442 basis for the VOC vapors sent to control. For the

annual emissions estimates, the average barge size of 20,000 barrels (bbls), the vapor pressure at

the annual average temperature of 70°F (530 °Rankine), vapor pressure at 70°F (530 °Rankine),

and the maximum number of barges degassed annually was utilized. It was conservatively

assumed that the entire barge vapor space was saturated with the vapors from the handled

products. The vendor‐guaranteed VOC DRE of 99.95 percent was applied to determine the

potential emission rate for all handled compounds. The worst‐case annual emissions were

calculated using the total annual number of handled barges for all products individually, and

then conservatively based on the chemical compound with the highest potential annual

emissions.

The maximum hourly VOC emissions from the new VCUs are provided in Table B‐2 in

Appendix B. The annual VOC emissions from the new VCUs are provided in Table B‐3 in

Appendix B.

3.3 Equipment Leak Fugitives There is no significant change to the number of components used in the piping to the VCUs

(VCU‐2 and VCU‐3) in comparison to the piping to the existing flares (FL‐1 and FL‐3).

Furthermore, it is anticipated that there will be an overall reduction in the number of

components used in the piping to the VCUs (EPNs VCU‐2 and VCU‐3) in comparison to the


piping to the flares (EPNs FL‐1 and FL‐3). Southwest Shipyard has estimated that there will be

a reduction in approximately 150 piping components associated with this project. As such, no

change in equipment leak fugitives is proposed with this project to maintain a conservative

estimate of the potential equipment leak fugitive emissions.


Section 4 Updates to Permit Conditions and MAERT

This section lists the proposed updates to the NSR Permit 9442 special conditions as a result of

this amendment and the proposed ERC project. The proposed revisions to the permit language

were provided by the TCEQ Emissions Banking and Trading Program as follows:

a. Standard Permit Number 154687 must be fully incorporated into NSR Permit

Number 9442.

i. The facility‐specific maximum allowable emission rates for the new units,

EPNs VCU‐2 and VCU‐3 must be added to NSR Permit 9442. The

following footnote must be added to the emission limit.

1. The authorized emissions have been used in the issuance of Emission Reduction Credits and cannot be increased during the service life of the

facility. (EBT Project 413652 and Permit Project XXXXXX).

b. Remove the facility‐specific maximum allowable emission rates for FIN

BRGCLN/EPN FL‐3 and FIN BRGCLN/EPN FL‐1. You will also need to

document the permanent shutdown of these units by adding the following

special condition to the permit.

i. Emissions Reduction Credits (ERCs) were issued for the permanent shutdown of the following facilities: FIN BRGCLN/EPN FL‐3 and FIN BRGCLN/EPN FL‐1.

The permit holder shall not restart or operate at the site any the facilities

associated with the issuance of the ERCs, regardless of whether the certified

ERCs are used, are transferred, or expire. (EBT Project 413652 and Permit

Project XXXXXX).

If the units have not been removed, also add the following special condition:

ii. This limit is effective until the facility is permanently removed from the site.

The permit project number should replace XXXXXX in the language provided

above. Provide a copy of the updated special conditions.

Note regarding fugitives: There will be an overall decrease in the number of components used

in the piping to the Vapor Combustors (VCU‐2 and VCU‐3) in comparison to the piping to the

flares (FL‐1 and FL‐3); however, this decrease was not quantified in terms of VOC emissions

(i.e., VOC TPY) and was not used in the generation of Emissions Reduction Credits (ERCs). As

such, there should not be any special condition relating to the fugitive components.


Section 5 Regulatory Requirements Discussion

This section addresses the assurance of regulatory compliance by the facility. The requirement

contained in 30 TAC Chapter 116.111(a)(2)(A)(i), states:

The emissions from the proposed facility will comply with all rules and regulations of the TCEQ

and with the intent of the Texas Clean Air Act (TCAA), including protection of the health and

property of the public.

As outlined in the following evaluation, the emissions from the plant will comply with all rules

and regulations of the TCEQ and with the intent of the TCAA, including the protection of the

health and property of the public.

CHAPTER 101 GENERAL RULES

Southwest Shipyard will operate in compliance with all requirements of the TCEQ

General Rules. Some notable rule compliance procedures are summarized below.

§101.3 Circumvention

There will not be the use of any mechanisms or devices to conceal or appear to minimize

the effects of emissions from sources included in this application.

§101.4 Nuisance

There will be no emissions of air contaminants or combined emissions that would be

expected to injure or adversely affect human health or welfare, plant or animal life, or

property in any way.

§101.5 Traffic Hazard

There will be no traffic hazards or interference caused by emissions from the sources

included in this application.

§101.8 Sampling

Upon request of the TCEQ, Southwest Shipyard will conduct sampling to determine the

opacity, rate, composition, or concentration of the stream requested.

§101.9 Sampling Ports

Southwest Shipyard will comply with the applicable requirements related to sampling

ports at the Channelview site.


§101.10 Emissions Inventory Requirements

Southwest Shipyard will comply with the emission inventory requirements. On an

annual basis, Southwest Shipyard files the appropriate emissions data and supporting

information to the Emissions Assessment Section as directed by the commission.

§101.13‐19 Administrative Provisions

Southwest Shipyard will comply with the applicable requirements of these sections.

§101.20 Compliance with Environmental Protection Agency Standards

Southwest Shipyard has addressed compliance with EPA standards for the Channelview

site in Federal Operating Permit (FOP) Number O‐1260. Southwest Shipyard will

comply with the applicable requirements in this section.

§101.21 The National Primary and Secondary Ambient Air Quality Standards

(NAAQS)

Southwest Shipyard will comply with all applicable requirements associated with the

NAAQS.

§101.23 Alternate Emission Reduction (ʺBubbleʺ) Policy

Operation of the facility will not be regulated by the Alternative Emission Reduction

Policy.

§101.24 and §101.27 Inspection Fees and Emissions Fees

Southwest Shipyard will submit all appropriately assessed fees to the TCEQ for the

facility in this application.

§101.26 Surcharge on Fuel Oil in Specified Boilers

The provisions of §101.26 do not apply as the affected sources and equipment from this

project are not boilers.

§101.28 Stringency Determination for Federal Operating Permits

This application is not for a federal operating permit; therefore, this section does not

apply.

§101.201 Emissions Event Reporting and Recordkeeping Requirements

Southwest Shipyard will comply with the requirements of this section as necessary.


§101.211 Scheduled Maintenance, Startup, and Shutdown Reporting and

Recordkeeping Requirements

Southwest Shipyard will comply with the requirements of this section as necessary.

§101.221‐224 Operational Requirements, Demonstrations, Actions to Reduce Excess

Emissions, and Temporary Exemptions during Drought Conditions

Southwest Shipyard will comply with the requirements of these sections as necessary.

§101.231‐233 Variances

Southwest Shipyard is not requesting a variance with this application; therefore, these

sections do not apply.

§101.300‐311 Emission Credit Banking and Trading

Southwest Shipyard has applied for Certification of Emission Reduction Credits (ERCs)

with ERC Generation Project No. 413652, which is currently pending. Southwest

Shipyard seeks to generate ERCs by ensuring the strategic emissions from the control

equipment replacement project are permanent and enforceable. Accordingly, PCP SP

154687 must be fully incorporated into NSR Permit Number 9442 to remove the flares

and reflect the emission reduction in accordance with 30 TAC §101.303(d)(4). Southwest

Shipyard will comply with all requirements of these sections as necessary.

§101.330‐339 Emissions Banking and Trading Allowances

These sections do not apply because this permit action does not include electric

generating facilities permitted under Chapter 116, Subchapter I (relating to Electric

Generating Facility Permits).

§101.350‐363 Mass Emission Cap and Trade Program

The Channelview site is subject to the Mass Emission Cap and Trade (MECT) Program

per 30 TAC §101.351(b) and will comply with all applicable requirements for each

affected facility at that site, which includes the vapor combustor units.

§101.370‐379 Discrete Emission Credit Banking and Trading

Southwest Shipyard will not generate or use any discrete emission credits in association

with this permit action.


§101.390‐403 Highly‐Reactive Volatile Organic Compound Emissions Cap and

Trade Program

Southwest Shipyard will not emit any highly‐reactive volatile organic compounds

(HRVOCs) as a result of this project; therefore, the requirements of this section do not

apply.

§101.501‐508 Clean Air Interstate Rule

This application does not include a stationary, fossil fuel‐fired boiler or stationary, fossil

fuel‐fired combustion turbine meeting the applicability requirements under 40 Code of

Federal Regulations Part 96, Subpart AA or Subpart AAA; therefore, these sections do

not apply.

§101.600‐602 Expedited Permitting

Southwest Shipyard is not requesting expedited permitting under 30 TAC §101.600‐602,

therefore this section is not applicable.

CHAPTER 111 CONTROL OF AIR POLLUTION FROM VISIBLE EMISSIONS AND

PARTICULATE MATTER

§111.111‐113 Visible Emissions

The vapor combustor will be operated with no visible emissions and have a constant

pilot flame during all times waste gas could be directed to it. Southwest Shipyard will

comply with all applicable opacity limitations specified in §111.111.

§111.121‐129 Incineration

The process addressed by this application does not have a solid waste incinerator;

therefore, these sections do not apply.

§111.131‐139 Abrasive Blasting of Water Storage Tanks Performed by Portable

Operations

There is no abrasive blasting of water storage tanks associated with this application;


§111.141‐149 Materials Handling, Construction, Roads, Streets, Alleys, and Parking

Lots

The Channelview site is located in Harris County. However, the facility is not located

inside the loop formed by Beltway 8 and therefore is not included in the Geographic

Areas of Application. Therefore, these sections do not apply


§111.151‐153 Emissions Limits on Nonagricultural Processes

Southwest Shipyard complies with the requirements of these sections as necessary.

§111.171‐175 Emissions Limits on Agricultural Processes

There are no agricultural processes at the facility. Therefore, these sections do not apply.

§111.181‐183 Exemptions for Portable or Transient Operations

The facility is not a portable or transient operation; therefore, these sections do not

apply.

§111.201‐221 Outdoor Burning

Outdoor burning will not be performed at the facility. Therefore, these sections do not

apply.

CHAPTER 112 CONTROL OF AIR POLLUTION FROM SULFUR COMPOUNDS

If requested by TCEQ, Southwest Shipyard will demonstrate compliance with the

reporting and recordkeeping requirements for the applicable SO2 emission limits

specified in §112.2. Southwest Shipyard will comply with the provisions of 30 TAC

§112.3 and operate facilities covered by this application such that SO2 emissions will not

cause an exceedance of the net ground level concentration limit allowed by §112.3(b).

Southwest Shipyard is not seeking an exemption under §112.4; therefore, this rule does

not apply. The remaining sections of 30 TAC Chapter 112, Subchapter A do not apply to

this permit application. Additionally, Chapter 112, Subparts B, C and D are not

applicable to this permit application.

CHAPTER 113 STANDARDS OF PERFORMANCE FOR HAZARDOUS AIR

POLLUTANTS AND FOR DESIGNATED FACILITIES AND

POLLUTANTS

This chapter regulates the following:

1) 40 CFR Part 61, Subpart R (Radionuclide NESHAPs),

2) Regulations promulgated under 40 CFR Part 63,

3) Municipal solid waste landfills,

4) Hospital/medical/infectious waste incinerators, and


5) Consolidated federal air rules for synthetic organic compound manufacturing

industry (40 CFR Part 65)

The facilities covered under this permit application are not subject to 40 CFR 61 Subpart

R, 40 CFR 63, or 40 CFR 65, and they are not municipal solid waste landfill or

hospital/medical /infectious waste incinerators. Therefore, requirements of this Chapter

do not apply.

CHAPTER 114 CONTROL OF AIR POLLUTION FROM MOTOR VEHICLES

Southwest Shipyard will operate its motor vehicles in compliance with the requirements

of this regulation as implemented in the State of Texas.

CHAPTER 115 CONTROL OF AIR POLLUTION FROM VOLATILE ORGANIC

COMPOUNDS

§115.110‐119 Storage of Volatile Organic Compounds

Southwest Shipyard shall comply with the applicable control, monitoring, testing,

recordkeeping, and reporting requirements in these sections.

§115.120‐129 Vent Gas Control



§115.131‐139 Water Separation

There is no water separator associated with this permit application; therefore, these

regulations do not apply.

§115.140‐149 Industrial Wastewater

There is no industrial wastewater processing facility associated with this permit

amendment application; therefore, these sections do not apply.

§115.152‐159 Municipal Solid Waste Landfills

The facility does not operate any municipal solid waste landfill facilities; therefore, these


§115.160‐169 Batch Processes

The facility does not operate any batch processes; therefore, these sections do not apply.


§115.211 Emission Specifications (Loading and Unloading of VOCs)

The facility does not operate a gasoline terminal; therefore, §115.211 does not apply.

§115.212‐219 Loading and Unloading of Volatile Organic Compounds



§115.221‐229 Filling of Gasoline Storage Vessels (Stage I) for Motor Vehicle Fuel

Dispensing Facilities

There is no motor vehicle fuel dispensing associated with the facility; therefore, these


§115.234‐239 Control of Volatile Organic Compound Leaks from Transport Vessels

The Channelview site is located in Harris County; therefore, Southwest Shipyard will

comply with the applicable requirements of these sections.

§115.240‐248 Control of Vehicle Refueling Emissions (Stage II) at Motor Vehicle

Fuel Dispensing Facilities

There is no vehicle fueling station at the facility; therefore, these sections do not apply.

§115.252‐259 Control of Reid Vapor Pressure of Gasoline

The Channelview site is not located in the El Paso area; therefore, these sections do not

apply.

§115.311‐319 Process Unit Turnaround and Vacuum‐Producing Systems in

Petroleum Refineries

The Channelview site is not a petroleum refinery; therefore, these sections do not apply.

§115.322‐329 Fugitive Emission Control in Petroleum Refineries in Gregg, Nueces,

and Victoria Counties

The Channelview site is not a petroleum refinery and is not located in one of these

counties; therefore, these sections do not apply.

§115.352‐359 Fugitive Emission Control in Petroleum Refining, Natural

Gas/Gasoline Processing, and Petrochemical Processes

The Channelview site operations do not consist of petroleum refining, natural

gas/gasoline processing, or petrochemical processes; therefore, the requirements of these



§115.412‐419 Degreasing and Cleanup Processes

Southwest Shipyard does not operate any degreasing units; therefore, these sections do

not apply.

§115.420‐429 Surface Coating Processes

There are no surface coating operations associated with this application; therefore, these


§115.430‐449 Flexographic and Rotogravure Processes and Offset Lithographic

Printing

Southwest Shipyard does not operate these types of facilities; therefore, these sections do

not apply.

§115.450‐459 Control Requirements for Surface Coating Processes

There are no surface coating operations associated with this application; therefore, these


§115.460‐469 Industrial Cleaning Solvents

There are no solvent cleaning operations associated with this application; therefore,

these sections do not apply.

§115.470‐479 Miscellaneous Industrial Adhesives

Southwest Shipyard does not use adhesives or adhesive primers; therefore, these


§115.510‐539 Cutback Asphalt and Pharmaceutical Manufacturing Facilities


not apply.

§115.540‐549 Degassing or Cleaning of Stationary, Marine, and Transport Vessels

Southwest Shipyard will comply with the requirements of this section, as applicable.

§115.552‐619 Petroleum Dry Cleaning Systems and Consumer Products


not apply.

§115.720‐789 Highly‐Reactive Volatile Organic Compounds

The sources authorized by NSR Permit 9442 do not emit any HRVOCs; therefore, these



§115.901‐916 Alternate Means of Control

Southwest Shipyard is not requesting an AMOC as part of this permit application;


§115.920‐923 Early Reductions

Southwest Shipyard is not requesting an extension to comply with any requirement in

this chapter; therefore, these sections do not apply.

§115.930‐940 Compliance and Control Plan Requirements

A schedule for achieving compliance with the applicable sections of this regulation will

be provided upon request by the Executive Director.

§115.950 Emissions Trading

Emission reduction credits and discrete emission reduction credits will not be used to

meet the emission control requirements of this chapter.

CHAPTER 116 CONTROL OF AIR POLLUTION BY PERMITS FOR NEW

CONSTRUCTION OR MODIFICATION

§116.110 Applicability

(a) The purpose of this amendment application is to consolidate by incorporation PCP

Standard Permit No. 154687 into NSR Permit 9442. This permit amendment

application will satisfy all requirements of 30 TAC §116.111.

(b) A portion of this permit application is seeking to modify the emission rates from

existing permitted facilities. As such, the proposed modifications to existing

permitted facilities will be authorized through the amendment of an existing NSR

permit.

(c) This application is subject to the compliance history review requirements under

30 TAC Chapter 60.

(d) The Channelview site is not a major source of HAP.

(e) Change of ownership rules do not apply to this application.

(f) Southwest Shipyard is not required to submit this application under seal of a Texas

licensed professional engineer.

Southwest Shipyard is the owner and operator of the Channelview site and is

responsible for compliance with the requirements in §116.110(g).


§116.111(a)(1) and (2)(A) Protection of Public Health and Welfare and Proximity to

Schools

A completed Form PI‐1 General Application form; Excel workbook file (version 4.0), has

been submitted electronically via STEERS during the online e‐Permits submission. This

application includes information demonstrating that the emission rates from the affected

facilities associated with this proposed modification at the facility comply with the rules

and regulations of the TCEQ and the intent of the Texas Clean Air Act, including

protection of health and property of the public.

As indicated on Figure 1‐1, there are no schools located within 3,000 feet from the

facility.

§116.111(a)(2)(B) Measurement of Emissions

Southwest Shipyard will have provisions for measuring the emissions of significant air

contaminants as determined by the executive director.

§116.111(a)(2)(C) Best Available Control Technology (BACT)

Southwest Shipyard utilizes BACT with consideration given to the technical

practicability and economic reasonableness of reducing emissions. A BACT analysis is

presented in the Form PI‐1 General Application form; Excel workbook file. The vapor

combustors shall achieve 99.95‐percent control of the waste gas directed to it. This level

of control exceeds current BACT requirements for VOC emissions. This level of control

will be achieved by monitoring the combustion chamber temperature and performing an

initial stack test on the equipment.

§116.111(a)(2)(D) Federal New Source Performance Standards (NSPS)

The emission sources in this application are not subject to any New Source Performance

Standards (NSPS) as specified in 40 CFR Part 60; therefore, this requirement is not

applicable.

§116.111(a)(2)(E) National Emission Standards for Hazardous Air Pollutants (NESHAP)

The Channelview site is not a major source of HAPs and the emission sources at the site

are not subject to any National Emission Standards for Hazardous Air Pollutants

(NESHAP) as specified in 40 CFR Part 61; therefore, this requirement is not applicable.

§116.111(a)(2)(F) NESHAP for Source Categories

The emission sources in this application are not subject to any requirements of 40 CFR

Part 63 (MACT), and will not result in the emissions of any pollutants subject to


NESHAP standards as promulgated under 40 CFR Part 61. Therefore, this section does

not apply.

§116.111(a)(2)(G) Performance Demonstration

Southwest Shipyard will operate the facilities as represented in the permit amendment

application and will achieve the performance specified in this application. As may be

requested by the Executive Director, additional performance data and testing will be

provided as appropriate in order to demonstrate further that the proposed facility will

achieve the performance specified in the application.

§116.111(a)(2)(H) Nonattainment Review

This project does not trigger nonattainment review, as discussed in Section 1.5.1.

§116.111(a)(2)(I) Prevention of Significant Deterioration (PSD) Review

As shown in Section 1.5.2, PSD permitting requirements do not apply to this project.

§116.111(a)(2)(J) Air Dispersion Modeling

Modeling impacts were assessed qualitatively using the impacts analysis that was

previously submitted to TCEQ in support of the PCP SP Registration No. 154687, issued

in December 2018. The SCREEN3 modeling analysis that was previously submitted to

TCEQ in support of the PCP Standard permit application is included as Appendix C to

this permit amendment application with a qualitative analysis, which can be used to

assess impacts from the permit amendment to incorporate the PCP SP. The SCREEN3

AQA attached included post processing results using UIMs.

§116.111(a)(2)(K) Hazardous Air Pollutants

This project does not constitute construction or reconstruction of a major source of

HAPS; therefore, this section does not apply.

§116.111(a)(2)(L) Mass Cap and Trade Allowances

Southwest Shipyard will comply with the applicable requirements of this section.

§116.112 Distance Limitations

The Channelview site is not a lead smelter or concrete crushing facility; therefore, these


§116.114 Application Review Schedule

Southwest Shipyard will comply with all conditions of the TCEQ permit review

schedule.


§116.115 General and Special Conditions

Southwest Shipyard will comply with all conditions and provisions of the TCEQ air

permit.

§116.116 Changes to Facilities

The facility will be operated in accordance with the representations made in this

application and any ensuing amendments. Changes in construction or operation

resulting in changes in the method of controlling emissions, the character of the

emissions, or an increase in emissions will be preceded by proper authorization.

§116.117 Documentation and Notification of Changes to Qualified Facilities

This section does not apply to this permit application.

§116.119 De Minimis Facilities or Sources

No de minimis facilities or sources are represented in this permit application.

§116.120 Voiding of Permits

The purpose of this amendment is to consolidate by incorporation PCP Standard Permit

No. 154687 into NSR Permit 9442. Once the PCP SP is fully consolidated into NSR 9442,

the standard permit will be voided.

§116.127 Actual to Projected Actual and Emissions Exclusion Test for Emissions

This section does not apply to this permit application.

§116.128 Amendment Application, Public Notice and Contested Case Hearing

Procedures for Certain Electric Generating Facilities

The Channelview site is not an electric generating facility; therefore, this section does not

apply.

§116.140‐143 Permit Fees

Southwest Shipyard will remit the appropriate application fees in accordance with this

section.

§116.150 New Major Source or Major Modification in Ozone Nonattainment

Area

The proposed project does not constitute a new major source or major modification;

therefore, the requirements of this section are not applicable.


§116.151 New Major Source or Major Modification in Nonattainment Area

Other Than Ozone

The Channelview site is located in Harris County, which is an attainment area for all

criteria pollutants other than ozone.

§116.160‐163 Prevention of Significant Deterioration Review

As shown in Section 1.5.2, PSD permitting requirements do not apply to this project.

§116.164 and 169 Green House Gases

Southwest Shipyard is not subject to a PSD review for Greenhouse Gases (GHGs).

Therefore, the requirements of this section do not apply to this application.

§116.170‐176 Emission Reductions: Offsets

Emission offsets are not required for this project.

§116.178 Portable Facilities

There are no portable facilities associated with this project. Therefore, the requirements

of this section do not apply.

§116.180‐198 Plant‐wide Applicability Limits

Southwest Shipyard is not requesting plant‐wide applicability limits with this

application; therefore, these sections do not apply.

§116.310‐315 New Source Review Permit Renewal

This application is not a permit renewal application; therefore, these sections do not

apply.

§116.400‐406 Hazardous Air Pollutants: Regulations Governing Constructed or

Reconstructed Major Sources

Southwest Shipyard is not constructing or reconstructing a major source. Therefore, the

requirements of this section do not apply.

§116.601‐620 Standard Permits

This application is not a request for authorization under a Standard Permit; therefore,

these sections do not apply to this permit amendment application.


§116.710‐765 Flexible Permits

Southwest Shipyard does not operate under a flexible permit and this application is not

a request for authorization under a Flexible Permit; therefore, these sections do not

apply to this permit application.

§116.770‐807 Permits for Grandfathered Facilities

These sections do not apply to this permit application.

§116.810‐870 Voluntary Emission Reduction Permit


§116.910‐931 Electric Generating Facility Permits

The Channelview site is not an electric generating facility; therefore, these sections do

not apply.

§116.1010‐1070 Multiple Plant Permits


§116.1200 Emergency Orders

Southwest Shipyard will apply for an emergency order in compliance with these rules if

a catastrophic event occurs that necessitates such action.

§116.1400‐1428 Permits for Specific Designated Facilities

These sections do not apply to this application.

§116.1500‐1540 Best Available Retrofit Technology (BART)


CHAPTER 117 CONTROL OF AIR POLLUTION FROM NITROGEN COMPOUNDS

The Channelview site is a minor source for NOX emissions in the Houston‐Galveston‐

Brazoria (HGB) Ozone Nonattainment Area, and is therefore subject to Chapter 117,

Subchapter D. However, the vapor combustors in this application are not the type of

equipment subject to 30 TAC Chapter 117, Subchapter D.

CHAPTER 118 CONTROL OF AIR POLLUTION EPISODES

Southwest Shipyard will implement all reasonably available emission reduction

methods in the event of a Level I air pollution episode and will comply with the TCEQ


directions to reduce or curtail emission rates in the event of a Level II episode.

Southwest Shipyard will also implement an emission reduction plan as applicable.

CHAPTER 122 FEDERAL OPERATING PERMITS

The Channelview site is a major source of VOC emissions and the emission sources

operate under FOP No. O‐1260. Southwest Shipyard will comply with all conditions

and applicable requirements in Title V Permit O‐1260.

TRC Environmental Corporation | Southwest Shipyard, L.P.

\\HOUSTON‐FP1\DATA\PROJECTS‐PPL\WPHOU\PJT2\340745\0000\R340745.0000‐001.DOCX 10/29/2019 Final November 2019

Appendix A Form PI-1 General Application

Please refer to the attached Form PI‐1 General Application; Excel workbook file (version 4.0),

which has been submitted electronically via STEERS e‐Permits.

Voucher Number:Trace Number:Date:Payment Method:Amount:Fee Type:

ePay Actor:

Name:Company:Address:Phone:

Site Name:Site Address:

Customer Name:Customer Address:State Tax ID:

Program Area ID:STEERS Program:STEERS Reference Number:

TCEQ ePay Voucher Receipt

Transaction Information

439228582EA00036462011/08/2019 01:11 PMCC - Authorization 0000267391$900.00AIR PERMIT - AMENDMENT (REF 332621-AMEND)

Elizabeth M Stanko

Payment Contact Information

Elizabeth StankoTrc Environmental10550 Richmond Ave Ste 210, Houston, TX 77042713-244-1039

Site Information

SOUTHWEST SHIPYARD18310 MARKET ST, CHANNELVIEW, TX 77530

Customer Information

SOUTHWEST SHIPYARD, L.P.18310 MARKET ST, CHANNELVIEW, TX 7753017605157027

Other Information

9442EPR_NSR332621-AMEND

Page 1 of 1

11/8/2019https://www3.tceq.texas.gov/epay/index.cfm?fuseaction=cor.viewcor&pmt_log_id=790906



Appendix B Emission Calculations

I. Basis

II. Calculation Inputs and Factors

Vapor Combustor Unit (VCU) Maximum Capacity 67.5 MMBtu/hr Maximum Heat Input per VCU stack

Maximum Hourly Heat Input (VCU-2 and VCU-3) 135 MMBtu/hr Combined Combustion Capacity of both VCUs

Annual Combined Heat Input (VCU-2 and VCU-3) 85,356 MMBtu/yr

VCU Destruction Efficiency 99.95% DRE

Maximum Assist Gas (Natural Gas) 300 scfm

Natural Gas Fuel Heat Content 1020 Btu/scf

NOx Emission Factor 0.076 lb/MMBtu

CO Emission Factor 0.3 lb/MMBtu

SO2 Emission Factor 1.2 lb/MMscf

10.26 lb/hr

3.24 TPY

40.50 lb/hr

12.80 TPY

0.02 lb/hr

0.09 TPY

III. Sample Calculations

Hourly NOx emissions = (Hourly Maximum Heat Input, MMBTU/hr) (NOx emission Factor, lb/MMBTU)

Hourly NOx emissions = 135 (MMBTU/hr) X 0.076 (lb/MMBTU)

Hourly NOx emissions = 10.26 (lb/hr)

Annual NOx emissions = (Annual Average Heat Input, MMBTU/year) (NOx emission Factor, lb/MMBTU) (1 ton/2000 lbs)

Annual NOx emissions = 85356 (MMBTU/year) X 0.076 (lb/MMBTU) X (1 ton/2000 lbs)

Annual NOx emissions = 3.24 (tons/year)

Hourly SO2 emissions = (Hourly Maximum Assist Gas, scfm) (SO2 emission Factor, lb/MMscf) (60 min/1hr)(1 MMscf / 106 scf)

Hourly SO2 emissions = 300 (scfm) X 1.2 (lb/MMscf) X (60 min/1hr) X (1 MMscf / 10^6 scf)

Hourly SO2 emissions = 0.02 (lb/hr)

Annual SO2 emissions = (Hourly SO2 emissions, lb/hr) (Maximum operating hours, hrs/year) (1 ton/2000 lbs)

Annual SO2 emissions = 0.0216 (lb/hr) X 8,760 (hrs/year) X (1 ton/2000 lbs)

Annual SO2 emissions = 0.09 (tons/year)


POLLUTION CONTROL PROJECT STANDARD PERMIT (PCP SP) No. 154687 EMISSION CALCULATIONS

November 2019

Vendor guaranteed NOX emission factor per VCU stack

Based on the maximum annual heat of combustion from the last

five years' emissions inventory queries.

Assist Gas is Natural Gas; ranges from 0-300 scfm

Natural gas fuel heat content per EPA AP-42.

The hourly Vapor Combustor Unit (VCU) NOX and CO combustion emissions are based on the vendor-specified VCU maximum heat capacity,

and vendor guaranteed NOX and CO emission factors. The annual NOX and CO combustion emissions are based on the maximum annual heat

of combustion from the last five years' emissions inventory (EI) queries, and vendor guaranteed NOX and CO emission factors.

The hourly SO2 combustion emissions are based on the maximum assist natural gas flow rate, and the SO2 emission factor from EPA AP-42

Emission Factors, Chapter 1.4 - Natural Gas Combustion, Table 1.4-2. The emission factor is based on 100-percent conversion of fuel sulfur to

SO2 and assumes sulfur content is natural gas of 4,000 grains/106 scf. The annual SO2 combustion emissions are based on the hourly SO2

emission rate and annual operating hours of 8,760.

EPNs: VCU-2 and VCU-3

CO Emissions

SO2 Emissions

Minimum VOC Destruction Efficiency

TABLE B-1: Products of Combustion Emissions from New Control Equipment

Vendor guaranteed CO emission factor per VCU stack

SO2 emission factor assumes sulfur content of natural gas is

4,000 grains/106 scf (0.40 gr/100 scf). The SO2 emission factor

from AP-42 was converted to 4,000 grains/106 scf by multiplying

the SO2 emission factor by the ratio of the site-specific sulfur

content (4,000 grains/106 scf) to 2,000 grains/10

6 scf.

NOx Emissions

Appendix B Page 1 of 11 VCUs Combustion Emissions

I. Basis

II. Calculations

CAS

Number

Chemical Compound Routed to Control

(NSR 9442 Attachment II)

Flow

Rate

VCU-2

Flow

Rate

VCU-3

Combined

Unrestricted

Flow Rate

(SCF/hour)

Combined

Restricted Flow

Rate based on

Max Heat Input

(SCF/hour)

Molecular

Weight

Max.

Temp

(ºF)

TVP @

100°F

(psia)

Maximum Hourly

Uncontrolled

Emission Rate

(lb/hr)

EPNs VCU-2 and

VCU-3

Maximum Hourly

VOC

(lb/hr)

64-19-7 Acetic acid 45,000 45,000 90,000 90,000 60.05 100 0.597 536.91 0.27

108-24-7 Acetic anhydride 45,000 45,000 90,000 90,000 102.09 100 0.235 359.31 0.18

67-64-1 Acetone 45,000 45,000 90,000 90,000 58.08 100 7.251 6307.23 3.16

75-86-5 Acetone cyanohydrin 45,000 45,000 90,000 90,000 85.11 100 0.012 15.30 0.01

75-05-8 Acetonitrile 45,000 45,000 90,000 90,000 41.05 100 3.133 1926.14 0.97

98-86-2 Acetophenone 45,000 45,000 90,000 90,000 120.15 100 0.0196 35.27 0.02

79-10-7 Acrylic acid 45,000 45,000 90,000 90,000 72.06 100 0.169 182.39 0.10

107-13-1 Acrylonitrile 45,000 45,000 90,000 90,000 53.06 100 4.022 3196.12 1.60

111-69-3 Adiponitrile 45,000 45,000 90,000 90,000 108 100 0.00028 0.45 0.01

64741-64-6 Alkylates 45,000 45,000 90,000 90,000 100 100 1.55 2321.38 1.17

67774-74-7 Alkylbenzene 45,000 45,000 90,000 90,000 106 100 0.01 15.88 0.01

626-63-7 Amyl acetate, n- 45,000 45,000 90,000 90,000 130.17 100 1.277 2489.52 1.25

71-41-0 Amyl alcohol 45,000 45,000 90,000 90,000 88.15 100 0.18 237.63 0.12

62-53-3 Aniline 45,000 45,000 90,000 90,000 93.1 100 0.019 26.49 0.02

8052-42-4 Asphalt 45,000 45,000 90,000 90,000 190 100 0.0086 24.47 0.02

N/A Aviation gasoline 45,000 45,000 90,000 71,506 66 100 9 7068.06 3.54

71-43-2 Benzene 45,000 45,000 90,000 90,000 78 100 3.287 3839.80 1.92

71-36-3 Butanol 45,000 45,000 90,000 90,000 74.12 100 0.294 326.36 0.17

123-86-4 Butyl acetate, n- 45,000 45,000 90,000 90,000 116.16 100 0.489 850.71 0.43

141-32-2 Butyl acrylate 45,000 45,000 90,000 90,000 128.17 100 0.214 410.78 0.21

75-65-0 Butyl alcohol, t- 45,000 45,000 90,000 90,000 74.12 100 1.702 1889.34 0.95

75-64-9 Butyl amine, t- 45,000 45,000 90,000 51,913 73.14 100 12.14 7670.45 3.84

142-96-1 Butyl ether 45,000 45,000 90,000 90,000 130.23 100 0.258 503.21 0.26

590-01-2 Butyl proprionate 45,000 45,000 90,000 90,000 130.19 100 0.1 194.98 0.10

105-60-2 Caprolactum 45,000 45,000 90,000 90,000 113 100 0.001 1.69 0.01

110-80-5 Cellosolve 45,000 45,000 90,000 90,000 90.12 100 0.231 311.78 0.16

111-15-9 Cellosolve acetates 45,000 45,000 90,000 90,000 132.16 100 0.07 138.55 0.07

8001-29-4 Cottonseed oil 45,000 45,000 90,000 90,000 150 100 0.099 222.40 0.12

1319-77-3 Cresylate 45,000 45,000 90,000 90,000 108.13 100 0.65 1052.63 0.53

1319-77-3 Cresylic acid 45,000 45,000 90,000 90,000 108.13 100 0.03 48.58 0.03

8002-05-9 Crude Oil 45,000 45,000 90,000 90,000 50 100 5.7 4268.34 2.14

98-82-8 Cumene 45,000 45,000 90,000 90,000 120.19 100 0.468 842.42 0.43


Short-term VOC emissions from controlled barge degassing and cleaning operations were calculated using the ideal gas law, which is consistent with the current NSR permit

basis. The maximum rated flow rate of 90,000 standard cubic feet per minute (SCFM), as well as a maximum temperature of 100 °F (560 °Rankine) was utilized. The vapor

pressure at 100 °F (560 °Rankine) was utilized as well, representing the short-term maximum temperature. It was conservatively assumed that the entire barge vapor was

saturated with vapors for the handled products. The maximum hourly emission rate using these variables was calculated for each chemical product that is authorized, and

then the vendor-guaranteed destruction and removal efficiency (DRE) of 99.95-percent was applied to determine the maximum potential emission rate for all handled

chemical compounds. Note that the VCUs have a maximum rated heat capacity of 135 MMBtu/hr combined. As such, Southwest Shipyard will reduce the hourly degassing

rate of certain compounds that would result in a heat rating above the vapor combustor’s maximum rated heat rating in order to ensure proper operation of the equipment.

TABLE B-2: Short-term (Hourly) VOC Emissions from New Control Equipment



November 2019

Appendix B Page 2 of 11 VCUs Max Hourly VOC Emissions

mailto:TVP@70°F(psia)



I. Basis

II. Calculations

CAS

Number



Flow

Rate

VCU-2

Flow

Rate

VCU-3

Combined

Unrestricted

Flow Rate

(SCF/hour)

Combined

Restricted Flow

Rate based on

Max Heat Input

(SCF/hour)

Molecular

Weight

Max.

Temp

(ºF)

TVP @

100°F

(psia)

Maximum Hourly

Uncontrolled

Emission Rate

(lb/hr)

EPNs VCU-2 and

VCU-3

Maximum Hourly

VOC

(lb/hr)












November 2019

110-82-7 Cyclohexane 45,000 45,000 90,000 90,000 84.16 100 3.249 4095.15 2.05

108-93-0 Cyclohexanol 45,000 45,000 90,000 90,000 100.16 100 0.177 265.51 0.14

108-94-1 Cyclohexanone 45,000 45,000 90,000 90,000 98.15 100 0.75 1102.47 0.56

112-30-1 Decanol 45,000 45,000 90,000 90,000 158.28 100 0.001 2.37 0.01

872-05-9 Decene 45,000 45,000 90,000 90,000 140.2 100 0.077 161.68 0.09

68515-43-5 Dialkyl phthalates 45,000 45,000 90,000 90,000 390 100 0.870 5081.57 2.55

84-74-2 Dibutyl phthalate 45,000 45,000 90,000 90,000 278.34 100 0.0018 7.50 0.01

77-73-6 Dicyclopentadiene 45,000 45,000 90,000 90,000 132.31 100 0.161 319.03 0.16

N/A Diesel 45,000 45,000 90,000 90,000 130 100 0.022 42.83 0.03

111-42-2 Diethanolamine 45,000 45,000 90,000 90,000 105.14 100 0.0002 0.31 0.01

108-83-8 Diisobutyl ketone 45,000 45,000 90,000 90,000 142.23 100 0.095 202.36 0.11

12002-23-2 Diisobutylene 45,000 45,000 90,000 90,000 112.22 100 1.555 2613.45 1.31

117-84-0 Dioctyl phthalate 45,000 45,000 90,000 90,000 390.56 100 0.000284 1.66 0.01

6842-15-5 Dodecene 45,000 45,000 90,000 90,000 168.31 100 0.011 27.73 0.02

112-53-8 Dodecyl alcohol 45,000 45,000 90,000 90,000 186 100 0.026 72.43 0.04

N/A Dripolene 45,000 45,000 90,000 90,000 78 100 2.94 3434.44 1.72

N/A Edible oils 45,000 45,000 90,000 90,000 150 100 0.04 89.86 0.05

64-17-5 Ethanol 45,000 45,000 90,000 90,000 46.07 100 2.32 1600.74 0.81

141-43-5 Ethanolamine 45,000 45,000 90,000 90,000 61.084 100 0.2 182.97 0.10

141-78-6 Ethyl acetate 45,000 45,000 90,000 90,000 88.11 100 3.191 4210.82 2.11

140-88-5 Ethyl acrylate 45,000 45,000 90,000 90,000 100.11 100 1.47 2203.99 1.11

75-04-7 Ethyl amine 45,000 45,000 90,000 78,866 45.08 100 14.103 8343.63 4.18

100-41-4 Ethyl benzene 45,000 45,000 90,000 90,000 106.17 100 0.37 588.33 0.30

103-11-7 Ethyl hexyl acrylate 45,000 45,000 90,000 90,000 184.28 100 0.019 52.44 0.03

104-76-7 Ethyl hexyl alcohol 45,000 45,000 90,000 90,000 130.23 100 0.014 27.31 0.02

107-15-3 Ethylene diamine 45,000 45,000 90,000 90,000 60.1 100 0.573 515.75 0.26

107-21-1 Ethylene glycol 45,000 45,000 90,000 90,000 62.07 100 0.005 4.65 0.01

N/A Fatty acid 45,000 45,000 90,000 90,000 175 100 0.00853 22.36 0.02

N/A Fatty alcohol 45,000 45,000 90,000 90,000 262 100 0.075 294.29 0.15

8002-50-4 Fish oil 45,000 45,000 90,000 90,000 150 100 0.099 222.40 0.12

50-00-0 Formalin (37-50% formaldehyde) 45,000 45,000 90,000 90,000 30.03 100 0.13 58.47 0.03

98-01-1 Furfural 45,000 45,000 90,000 90,000 96.08 100 0.096 138.14 0.07





I. Basis

II. Calculations

CAS

Number



Flow

Rate

VCU-2

Flow

Rate

VCU-3

Combined

Unrestricted

Flow Rate

(SCF/hour)

Combined

Restricted Flow

Rate based on

Max Heat Input

(SCF/hour)

Molecular

Weight

Max.

Temp

(ºF)

TVP @

100°F

(psia)

Maximum Hourly

Uncontrolled

Emission Rate

(lb/hr)

EPNs VCU-2 and

VCU-3

Maximum Hourly

VOC

(lb/hr)












November 2019

8006-61-9 Gasoline 45,000 45,000 90,000 63,749 66 100 10.3 7211.54 3.61

N/A Gasoline additives 45,000 45,000 90,000 76,824 88 100 6 6750.00 3.38

N/A Heavy aromatics 45,000 45,000 90,000 90,000 190 100 0.00019 0.54 0.01

142-82-5 Heptane 45,000 45,000 90,000 90,000 100.21 100 1.586 2380.28 1.20

124-09-4 Hexamethylenediamine soln. 45,000 45,000 90,000 90,000 116.21 100 0.06 104.43 0.06

110-54-3 Hexane 45,000 45,000 90,000 90,000 86.17 100 4.892 6313.31 3.16

111-27-3 Hexanol 45,000 45,000 90,000 90,000 102.18 100 0.744 1138.55 0.57

592-41-6 Hexene 45,000 45,000 90,000 80,464 84.16 100 5.99 6750.00 3.38

N/A Hydraulic oil 45,000 45,000 90,000 90,000 150 100 0.012 26.96 0.02

N/A Isoamyl ketone 45,000 45,000 90,000 90,000 100.16 100 0.671 1006.54 0.51

78-83-1 Isobutanol 45,000 45,000 90,000 90,000 74.12 100 0.513 569.47 0.29

78-79-5 Isoprene 45,000 45,000 90,000 48,131 68.11 100 13.13 7162.56 3.59

67-63-0 Isopropyl alcohol 45,000 45,000 90,000 90,000 60.1 100 1.779 1601.27 0.81

N/A Jet Fuel A 45,000 45,000 90,000 90,000 130 100 0.099 192.75 0.10

N/A Jet Naphtha (JP-4) 45,000 45,000 90,000 90,000 80 100 2.7 3234.95 1.62

8008-20-6 Kerosene 45,000 45,000 90,000 90,000 130 100 0.029 56.46 0.03

67891-80-9 Light aromatic distillate 45,000 45,000 90,000 90,000 119.1 100 0.17 303.23 0.16

64742-94-5 Light aromatic naphtha 45,000 45,000 90,000 90,000 78 100 0.165 192.75 0.10

141-79-7 Mesityl oxide 45,000 45,000 90,000 90,000 98.2 100 0.446 655.93 0.33

79-41-4 Methacrylic acid 45,000 45,000 90,000 90,000 86.09 100 0.084 108.30 0.06

67-56-1 Methanol 45,000 45,000 90,000 90,000 32.04 100 4.525 2171.33 1.09

96-33-3 Methyl acrylate 45,000 45,000 90,000 90,000 86.09 100 3.055 3938.93 1.97

108-11-2 Methyl amyl alcohol 45,000 45,000 90,000 90,000 102.18 100 0.274 419.31 0.21

78-93-3 Methyl ethyl ketone 45,000 45,000 90,000 90,000 72.11 100 3.345 3612.48 1.81

108-10-1 Methyl Isobutyl Ketone 45,000 45,000 90,000 90,000 100.16 100 1.734 2601.10 1.31

563-80-4 Methyl isopropyl ketone 45,000 45,000 90,000 90,000 86.15 100 4.234 5462.86 2.74

80-62-6 Methyl methacrylate 45,000 45,000 90,000 90,000 100.12 100 1.428 2141.23 1.08

98-83-9 Methyl styrene, a- 45,000 45,000 90,000 90,000 118.17 100 0.103 182.29 0.10

1634-04-4 Methyl tert butyl ether (MTBE) 45,000 45,000 90,000 70,296 88.15 100 8 8249.31 4.13

8012-95-1 Mineral oil 45,000 45,000 90,000 90,000 150 100 0.00276 6.20 0.01

8030-30-6 Naphtha (<2% Benzene) 45,000 45,000 90,000 90,000 80 100 5.7 6829.35 3.42

91-20-3 Naphthalene (<5% Benzene) 45,000 45,000 90,000 90,000 128.18 100 0.509 977.13 0.49





I. Basis

II. Calculations

CAS

Number



Flow

Rate

VCU-2

Flow

Rate

VCU-3

Combined

Unrestricted

Flow Rate

(SCF/hour)

Combined

Restricted Flow

Rate based on

Max Heat Input

(SCF/hour)

Molecular

Weight

Max.

Temp

(ºF)

TVP @

100°F

(psia)

Maximum Hourly

Uncontrolled

Emission Rate

(lb/hr)

EPNs VCU-2 and

VCU-3

Maximum Hourly

VOC

(lb/hr)












November 2019

91-20-3 Naphthalene concentrate 45,000 45,000 90,000 90,000 128.18 100 0.509 977.13 0.49

1338-24-5 Naphthenic Acid 45,000 45,000 90,000 90,000 250 100 0.087 325.74 0.17

N/A Natural gasoline 45,000 45,000 90,000 61,770 66 100 10.63 7211.54 3.61

N/A Neodol 45,000 45,000 90,000 90,000 185 100 0.012 33.25 0.02

98-95-3 Nitrobenzene 45,000 45,000 90,000 90,000 123.11 100 0.012 22.13 0.02

79-24-3 Nitroethane 45,000 45,000 90,000 90,000 75.07 100 0.733 824.11 0.42

625-48-9 Nitroethanol 45,000 45,000 90,000 90,000 91.07 100 0.14 190.95 0.10

79-46-9 Nitropropane 45,000 45,000 90,000 90,000 89.1 100 0.913 1218.32 0.61

124-11-8 Nonene 45,000 45,000 90,000 90,000 126.2 100 0.218 412.03 0.21

25154-52-3 Nonyl phenol 45,000 45,000 90,000 90,000 220.36 100 0.075 247.52 0.13

111-65-9 Octane 45,000 45,000 90,000 90,000 114.2 100 0.407 696.11 0.35

111-87-5 Octanol 45,000 45,000 90,000 90,000 130.23 100 0.005 9.75 0.01

111-66-0 Octene, 1- 45,000 45,000 90,000 90,000 112.21 100 0.657 1104.11 0.56

N/A Olefins, a- 45,000 45,000 90,000 90,000 84 100 2.99 3761.53 1.89

8002-74-2 Paraffin (distillates) 45,000 45,000 90,000 90,000 100 100 0.01 14.98 0.01

8002-03-7 Peanut oil 45,000 45,000 90,000 90,000 340.37 100 0.099 504.66 0.26

504-60-9 Pentadiene, 1,3- (piperylene) 45,000 45,000 90,000 54,178 68.12 100 10.9 6694.10 3.35

624-54-4 Pentyl propionate 45,000 45,000 90,000 87,456 144.22 100 4.02 8437.50 4.22

N/A Petroleum jelly 45,000 45,000 90,000 90,000 300 100 0.00284 12.76 0.01

N/A Petroleum wax 45,000 45,000 90,000 90,000 500 100 0.015 112.32 0.06

108-95-2 Phenol 45,000 45,000 90,000 90,000 94.11 100 0.034 47.92 0.03

25322-69-4 Polyglycol 45,000 45,000 90,000 90,000 200 100 0.011 32.95 0.02

9003-27-4 Polyisobutylene 45,000 45,000 90,000 90,000 1250 100 0.035 655.23 0.33

25322-69-4 Polyol 45,000 45,000 90,000 90,000 200 100 0.028 83.87 0.05

71-23-8 Propanol 45,000 45,000 90,000 90,000 60.1 100 0.732 658.87 0.33

79-09-4 Propionic acid 45,000 45,000 90,000 90,000 74.08 100 0.178 197.49 0.10

109-60-4 Propyl acetate 45,000 45,000 90,000 90,000 102.13 100 1.232 1884.42 0.95

57-55-6 Propylene glycol 45,000 45,000 90,000 90,000 76.1 100 0.005 5.70 0.01

68514-29-4 Raffinate (<5% Benzene) 45,000 45,000 90,000 75,405 128 100 4.49 7211.54 3.61

N/A Refinery petroleum products (< 10% 45,000 45,000 90,000 90,000 50 100 0.1 74.88 0.04

N/A Reformate (< 5% benzene) 45,000 45,000 90,000 79,429 88 100 6.2 7211.54 3.61

64742-48-9 Reformer feed 45,000 45,000 90,000 75,808 200 100 2.94 7417.58 3.71





I. Basis

II. Calculations

CAS

Number



Flow

Rate

VCU-2

Flow

Rate

VCU-3

Combined

Unrestricted

Flow Rate

(SCF/hour)

Combined

Restricted Flow

Rate based on

Max Heat Input

(SCF/hour)

Molecular

Weight

Max.

Temp

(ºF)

TVP @

100°F

(psia)

Maximum Hourly

Uncontrolled

Emission Rate

(lb/hr)

EPNs VCU-2 and

VCU-3

Maximum Hourly

VOC

(lb/hr)












November 2019

9003-35-4 Resin oil 45,000 45,000 90,000 90,000 180 100 0.1 269.58 0.14

100-42-5 Styrene 45,000 45,000 90,000 90,000 104.15 100 0.254 396.19 0.20

126-33-0 Sulfolane 45,000 45,000 90,000 90,000 120.17 100 0.017 30.60 0.02

8002-26-4 Tall oil 45,000 45,000 90,000 90,000 250 100 0.1 374.42 0.19

61789-97-7 Tallow 45,000 45,000 90,000 90,000 150 100 0.099 222.40 0.12

112-60-7 Tetraethylene glycol 45,000 45,000 90,000 90,000 194.23 100 0.0062 18.04 0.01

109-99-9 Tetrahydrofuran 45,000 45,000 90,000 90,000 72.1 100 5.261 5680.91 2.85

25265-77-4 Texanol 45,000 45,000 90,000 90,000 216.32 100 0.01 32.40 0.02

108-88-3 Toluene 45,000 45,000 90,000 90,000 92.14 100 1.006 1388.23 0.70

112-70-9 Tridecanol 45,000 45,000 90,000 90,000 200.37 100 0.022 66.02 0.04

102-71-6 Triethanolamine 45,000 45,000 90,000 90,000 149.19 100 0.015 33.52 0.02

112-27-6 Triethylene glycol 45,000 45,000 90,000 90,000 150.17 100 0.0081 18.22 0.01

8006-64-2 Turpentine 45,000 45,000 90,000 90,000 136.23 100 0.903 1842.36 0.93

8001-22-7 Vegetable oil 45,000 45,000 90,000 90,000 150 100 0.099 222.40 0.12

108-05-4 Vinyl acetate 45,000 45,000 90,000 90,000 86.09 100 4.022 5185.72 2.60

N/A Wastewater (Untreated) 45,000 45,000 90,000 90,000 18 100 0.001 0.27 0.01

1330-20-7 xylene, mixed or all isomers, except p- 45,000 45,000 90,000 90,000 106.17 100 0.328 521.54 0.27

106-42-3 xylene, p- 45,000 45,000 90,000 90,000 106.17 100 0.343 545.39 0.28

4.22


The maximum hourly VOC emissions result from a barge handling Pentyl Propionate:

Quc (lb/hr) = (Vapor Pressure, psi) (Maximum Volumetric Flow Rate, ft3/hr)/(10.73 psia. ft

3 / lb-mol.ºR) (Maximum Temperature, ºR)) (Molecular Weight) (Saturation Factor)

Quc (lb/hr) = 4.02 (psi) X 87456 ((ft3/hr) / (10.73 psia . ft3 / lb-mol.ºR) X 560 (ºR)) X 144.22 (lb/lb-mol) X 1.0

Quc (lb/hr) = 8437.5 (lb/hr)

Qc = (1-EDRE ) Q uc

Qc = (1-0.9995) X 8437.5 (lb/hr)

Qc = 4.22 (lb/hr)

EPNs VCU-2 and VCU-3 Maximum Hourly Controlled Emissions - Max Hourly from Worst Case Barge





I. Basis

II. Calculations

CAS NumberChemical Compound Routed to Control


Avg. Barge

Volume

(bbl)

Molecular

Weight

Avg. Temp

(ºF)

TVP @ 70°F

(psia)

Uncontrolled VOC

Emission per barge

(lbs/barge)

Annual No. of

Barges to

VCUs

VOC Emissions

(TPY)

64-19-7 Acetic acid 20,000 60.05 70 0.234 277.45 1700 0.12

108-24-7 Acetic anhydride 20,000 102.09 70 0.082 165.29 1700 0.0767-64-1 Acetone 20,000 58.08 70 3.713 4258.07 1700 1.8175-86-5 Acetone cyanohydrin 20,000 85.11 70 0.006 10.08 1700 4.29E-0375-05-8 Acetonitrile 20,000 41.05 70 1.412 1144.48 1700 0.4998-86-2 Acetophenone 20,000 120.15 70 0.0137 32.50 1700 0.0179-10-7 Acrylic acid 20,000 72.06 70 0.0552 78.54 1700 0.03107-13-1 Acrylonitrile 20,000 53.06 70 1.799 1884.78 1700 0.80111-69-3 Adiponitrile 20,000 108 70 0.000193 0.41 1700 1.75E-04

64741-64-6 Alkylates 20,000 100 70 0.725 1431.53 1700 0.6167774-74-7 Alkylbenzene 20,000 106 70 0.0075 15.70 1700 0.01626-63-7 Amyl acetate, n- 20,000 130.17 70 0.719 1848.00 1700 0.7971-41-0 Amyl alcohol 20,000 88.15 70 0.059 102.69 1700 0.0462-53-3 Aniline 20,000 93.1 70 0.005 9.19 1700 3.91E-03

8052-42-4 Asphalt 20,000 190 70 0.006 22.51 1700 0.01N/A Aviation gasoline 20,000 66 70 7.5 9773.88 1700 4.15

71-43-2 Benzene 20,000 78 70 1.508 2322.51 1700 0.9971-36-3 Butanol 20,000 74.12 70 0.092 134.64 1700 0.06

123-86-4 Butyl acetate, n- 20,000 116.16 70 0.205 470.19 1700 0.20141-32-2 Butyl acrylate 20,000 128.17 70 0.082 207.52 1700 0.09

75-65-0 Butyl alcohol, t- 20,000 74.12 70 0.638 933.72 1700 0.4075-64-9 Butyl amine, t- 20,000 73.14 70 6.04 8722.75 1700 3.71142-96-1 Butyl ether 20,000 130.23 70 0.103 264.86 1700 0.11590-01-2 Butyl proprionate 20,000 130.19 70 0.1 257.06 1700 0.11105-60-2 Caprolactum 20,000 113 70 0.001 2.23 1700 9.48E-04110-80-5 Cellosolve 20,000 90.12 70 0.0774 137.73 1700 0.06111-15-9 Cellosolve acetates 20,000 132.16 70 0.024 62.63 1700 0.038001-29-4 Cottonseed oil 20,000 150 70 0.041 121.43 1700 0.051319-77-3 Cresylate 20,000 108.13 70 0.363 775.02 1700 0.331319-77-3 Cresylic acid 20,000 108.13 70 0.012 25.62 1700 0.01

8002-05-9 Crude Oil 20,000 50 70 3.4 3356.68 1700 1.4398-82-8 Cumene 20,000 120.19 70 0.272 645.50 1700 0.27110-82-7 Cyclohexane 20,000 84.16 70 1.605 2667.12 1700 1.13108-93-0 Cyclohexanol 20,000 100.16 70 0.177 350.05 1700 0.15108-94-1 Cyclohexanone 20,000 98.15 70 0.407 788.76 1700 0.34112-30-1 Decanol 20,000 158.28 70 0.0007 2.19 1700 9.30E-04872-05-9 Decene 20,000 140.2 70 0.28 775.12 1700 0.33

Annual VOC emissions from controlled barge degassing and cleaning operations were calculated using the ideal gas law, which is consistent with the current NSR permit

basis. The annual VOC emissions were based on the average barge size of 20,000 barrels (bbls), the vapor pressure at the annual average temperature of 70 °F, and the

maximum number of barges degassed annually. It was conservatively assumed that the entire vapor space was saturated with the vapors from the chemical products that are

authorized to be handled. The vendor-guaranteed destruction and removal efficiency (DRE) of 99.95% was applied to determine the potential emission rate for all handled

compounds. The worst-case emissions were calculated using the total annual number of handled barges for all products individually, and then conservatively using the

product with the highest potential annual emissions.

SOUTHWEST SHIPYARD, L.P.POLLUTION CONTROL PROJECT STANDARD PERMIT (PCP SP) No. 154687

EMISSION CALCULATIONSNovember 2019

TABLE B-3: Long-term (Annual) VOC Emissions from New Control Equipment EPNs: VCU-2 and VCU-3

Appendix B Page 7 of 11 VCUs Annual VOC Emissions



I. Basis

II. Calculations



Avg. Barge

Volume

(bbl)

Molecular

Weight

Avg. Temp

(ºF)

TVP @ 70°F

(psia)

Uncontrolled VOC

Emission per barge

(lbs/barge)

Annual No. of

Barges to

VCUs

VOC Emissions

(TPY)










68515-43-5 Dialkyl phthalates 20,000 390 70 0.700 5390.44 1700 2.2984-74-2 Dibutyl phthalate 20,000 278.34 70 0.00126 6.92 1700 2.94E-0377-73-6 Dicyclopentadiene 20,000 132.31 70 0.068 177.65 1700 0.08

N/A Diesel 20,000 130 70 0.009 23.10 1700 0.01111-42-2 Diethanolamine 20,000 105.14 70 0.0002 0.42 1700 1.76E-04108-83-8 Diisobutyl ketone 20,000 142.23 70 0.035 98.29 1700 0.04

12002-23-2 Diisobutylene 20,000 112.22 70 0.7 1551.06 1700 0.66117-84-0 Dioctyl phthalate 20,000 390.56 70 0.000199 1.53 1700 6.52E-046842-15-5 Dodecene 20,000 168.31 70 0.003 9.97 1700 4.24E-03112-53-8 Dodecyl alcohol 20,000 186 70 0.026 95.49 1700 4.06E-02

N/A Dripolene 20,000 78 70 1.53 2356.39 1700 1.00N/A Edible oils 20,000 150 70 0.02 59.24 1700 0.03

64-17-5 Ethanol 20,000 46.07 70 0.87 791.41 1700 0.34141-43-5 Ethanolamine 20,000 61.084 70 0.2 241.22 1700 0.10141-78-6 Ethyl acetate 20,000 88.11 70 1.489 2590.49 1700 1.10

140-88-5 Ethyl acrylate 20,000 100.11 70 0.599 1184.04 1700 0.50

75-04-7 Ethyl amine 20,000 45.08 70 14.103 12553.27 1700 5.34

100-41-4 Ethyl benzene 20,000 106.17 70 0.155 324.93 1700 0.14103-11-7 Ethyl hexyl acrylate 20,000 184.28 70 0.019 69.13 1700 0.03104-76-7 Ethyl hexyl alcohol 20,000 130.23 70 0.004 10.29 1700 4.37E-03107-15-3 Ethylene diamine 20,000 60.1 70 0.216 256.32 1700 0.11107-21-1 Ethylene glycol 20,000 62.07 70 0.001 1.23 1700 5.21E-04

N/A Fatty acid 20,000 175 70 0.00597 20.63 1700 0.01N/A Fatty alcohol 20,000 262 70 0.0525 271.60 1700 0.12

8002-50-4 Fish oil 20,000 150 70 0.041 121.43 1700 0.0550-00-0 Formalin (37-50% formaldehyde) 20,000 30.03 70 0.037 21.94 1700 0.0198-01-1 Furfural 20,000 96.08 70 0.035 66.40 1700 0.03

8006-61-9 Gasoline 20,000 66 70 6.2 8079.74 1700 3.43N/A Gasoline additives 20,000 88 70 4.74 8236.12 1700 3.50N/A Heavy aromatics 20,000 190 70 0.00006 0.23 1700 9.57E-05

142-82-5 Heptane 20,000 100.21 70 0.735 1454.32 1700 0.62124-09-4 Hexamethylenediamine soln. 20,000 116.21 70 0.06 137.68 1700 0.06110-54-3 Hexane 20,000 86.17 70 2.467 4197.46 1700 1.78111-27-3 Hexanol 20,000 102.18 70 0.418 843.34 1700 0.36592-41-6 Hexene 20,000 84.16 70 3.035 5043.43 1700 2.14

N/A Hydraulic oil 20,000 150 70 0.0084 24.88 1700 0.01N/A Isoamyl ketone 20,000 100.16 70 0.306 605.17 1700 0.26




I. Basis

II. Calculations



Avg. Barge

Volume

(bbl)

Molecular

Weight

Avg. Temp

(ºF)

TVP @ 70°F

(psia)

Uncontrolled VOC

Emission per barge

(lbs/barge)

Annual No. of

Barges to

VCUs

VOC Emissions

(TPY)










78-83-1 Isobutanol 20,000 74.12 70 0.167 244.41 1700 0.10

78-79-5 Isoprene 20,000 68.11 70 9.192 12361.82 1700 5.2567-63-0 Isopropyl alcohol 20,000 60.1 70 0.667 791.52 1700 0.34

N/A Jet Fuel A 20,000 130 70 0.041 105.24 1700 0.04N/A Jet Naphtha (JP-4) 20,000 80 70 1.6 2527.39 1700 1.07

8008-20-6 Kerosene 20,000 130 70 0.011 28.24 1700 0.0167891-80-9 Light aromatic distillate 20,000 119.1 70 0.14 329.23 1700 0.1464742-94-5 Light aromatic naphtha 20,000 78 70 0.06 92.41 1700 0.04141-79-7 Mesityl oxide 20,000 98.2 70 0.184 356.77 1700 0.1579-41-4 Methacrylic acid 20,000 86.09 70 0.02 34.00 1700 0.0167-56-1 Methanol 20,000 32.04 70 1.954 1236.17 1700 0.5396-33-3 Methyl acrylate 20,000 86.09 70 1.354 2301.62 1700 0.98108-11-2 Methyl amyl alcohol 20,000 102.18 70 0.103 207.81 1700 0.0978-93-3 Methyl ethyl ketone 20,000 72.11 70 1.489 2120.08 1700 0.90108-10-1 Methyl Isobutyl Ketone 20,000 100.16 70 0.744 1471.39 1700 0.63563-80-4 Methyl isopropyl ketone 20,000 86.15 70 2.141 3641.95 1700 1.5580-62-6 Methyl methacrylate 20,000 100.12 70 0.635 1255.33 1700 0.5398-83-9 Methyl styrene, a- 20,000 118.17 70 0.039 91.00 1700 0.04

1634-04-4 Methyl tert butyl ether (MTBE) 20,000 88.15 70 4.1 7136.21 1700 3.038012-95-1 Mineral oil 20,000 150 70 0.001934 5.73 1700 2.43E-038030-30-6 Naphtha (<2% Benzene) 20,000 80 70 3.4 5370.70 1700 2.2891-20-3 Naphthalene (<5% Benzene) 20,000 128.18 70 0.139 351.80 1700 0.1591-20-3 Naphthalene concentrate 20,000 128.18 70 0.139 351.80 1700 0.15

1338-24-5 Naphthenic Acid 20,000 250 70 0.061 301.11 1700 0.13N/A Natural gasoline 20,000 62 70 7 8569.42 1700 3.64N/A Neodol 20,000 185 70 0.0084 30.68 1700 0.01

98-95-3 Nitrobenzene 20,000 123.11 70 0.004 9.72 1700 4.13E-0379-24-3 Nitroethane 20,000 75.07 70 0.309 458.02 1700 0.19625-48-9 Nitroethanol 20,000 91.07 70 0.1 179.82 1700 0.0879-46-9 Nitropropane 20,000 89.1 70 0.639 1124.19 1700 0.48124-11-8 Nonene 20,000 126.2 70 0.081 201.84 1700 0.09

25154-52-3 Nonyl phenol 20,000 220.36 70 0.0525 228.43 1700 0.10111-65-9 Octane 20,000 114.2 70 0.188 423.92 1700 0.18111-87-5 Octanol 20,000 130.23 70 0.0035 9.00 1700 3.82E-03111-66-0 Octene, 1- 20,000 112.21 70 0.238 527.32 1700 0.22

N/A Olefins, a- 20,000 84 70 1.573 2608.97 1700 1.118002-74-2 Paraffin (distillates) 20,000 100 70 0.0075 14.81 1700 0.01




I. Basis

II. Calculations



Avg. Barge

Volume

(bbl)

Molecular

Weight

Avg. Temp

(ºF)

TVP @ 70°F

(psia)

Uncontrolled VOC

Emission per barge

(lbs/barge)

Annual No. of

Barges to

VCUs

VOC Emissions

(TPY)










8002-03-7 Peanut oil 20,000 340.37 70 0.041 275.55 1700 0.12504-60-9 Pentadiene, 1,3- (piperylene) 20,000 68.12 70 6.87 9240.45 1700 3.93624-54-4 Pentyl propionate 20,000 144.22 70 1.36 3872.81 1700 1.65

N/A Petroleum jelly 20,000 300 70 0.00199 11.79 1700 0.01N/A Petroleum wax 20,000 500 70 0.0103 101.69 1700 0.04

108-95-2 Phenol 20,000 94.11 70 0.012 22.30 1700 0.0125322-69-4 Polyglycol 20,000 200 70 0.007 27.64 1700 0.019003-27-4 Polyisobutylene 20,000 1250 70 0.025 617.04 1700 0.2625322-69-4 Polyol 20,000 200 70 0.00199 7.86 1700 3.34E-03

71-23-8 Propanol 20,000 60.1 70 0.26 308.54 1700 0.1379-09-4 Propionic acid 20,000 74.08 70 0.065 95.08 1700 0.04109-60-4 Propyl acetate 20,000 102.13 70 0.514 1036.52 1700 0.4457-55-6 Propylene glycol 20,000 76.1 70 0.0149 22.39 1700 0.01

68514-29-4 Raffinate (<5% Benzene) 20,000 128 70 3 7582.16 1700 3.22N/A Refinery petroleum products (< 10% benzene) 20,000 50 70 0.042 41.46 1700 0.02N/A Reformate (< 5% benzene) 20,000 88 70 3.4 5907.77 1700 2.51

64742-48-9 Reformer feed 20,000 200 70 1.6 6318.47 1700 2.699003-35-4 Resin oil 20,000 180 70 0.042 149.27 1700 0.06100-42-5 Styrene 20,000 104.15 70 0.099 203.59 1700 0.09126-33-0 Sulfolane 20,000 120.17 70 0.012 28.47 1700 0.018002-26-4 Tall oil 20,000 250 70 0.042 207.32 1700 0.0961789-97-7 Tallow 20,000 150 70 0.041 121.43 1700 0.05112-60-7 Tetraethylene glycol 20,000 194.23 70 0.0043 16.49 1700 0.01109-99-9 Tetrahydrofuran 20,000 72.1 70 2.571 3660.15 1700 1.56

25265-77-4 Texanol 20,000 216.32 70 0.007 29.90 1700 0.01108-88-3 Toluene 20,000 92.14 70 0.425 773.21 1700 0.33112-70-9 Tridecanol 20,000 200.37 70 0.015 59.35 1700 0.03102-71-6 Triethanolamine 20,000 149.19 70 0.01 29.46 1700 0.01112-27-6 Triethylene glycol 20,000 150.17 70 0.0057 16.90 1700 0.01




I. Basis

II. Calculations



Avg. Barge

Volume

(bbl)

Molecular

Weight

Avg. Temp

(ºF)

TVP @ 70°F

(psia)

Uncontrolled VOC

Emission per barge

(lbs/barge)

Annual No. of

Barges to

VCUs

VOC Emissions

(TPY)










8006-64-2 Turpentine 20,000 136.23 70 0.636 1710.77 1700 0.738001-22-7 Vegetable oil 20,000 150 70 0.041 121.43 1700 0.05108-05-4 Vinyl acetate 20,000 86.09 70 1.721 2925.47 1700 1.24

N/A Wastewater (Untreated) 20,000 18 70 0.001 0.36 1700 1.51E-04

1330-20-7 xylene, mixed or all isomers, except p- 20,000 106.17 70 0.127 266.24 1700 0.11

106-42-3 xylene, p- 20,000 106.17 70 0.135 283.01 1700 0.12

5.34


Annual VOC Emissions - Ethyl Amine:

Quc (lbs/barge) = 14.103 (psi) X 20000 (bbl) (5.615 ft3/bbl)/((10.73 psia . ft3 / lb-mol.ºR) X 530 (ºR)) X 45.08 (lb/lb-mol) X 1.0

Quc (lbs/barge) =12553.27 lbs/barge

Quc (TPY) = lbs/barge X barges/year X (1 ton/2000 lb)

Quc (TPY) = 12553.27 lbs/barge X 1700 barges/year x (1 ton/2000 lb)

Quc (TPY) = 10670.28 lbs/year

Qc = (1-EDRE ) Q uc

Qc = (1-0.9995) X 10,670.28 (TPY)

Qc = 5.34 (TPY)

Quc (lbs/barge) = (Vapor Pressure, psi) (Average barge volume, bbl) (5.61 ft3/bbl)/(10.73 psia . ft3 / lb-mol.ºR) (Maximum Temperature, ºR)) (Molecular Weight) (Saturation

Factor)

EPNs VCU-2 and VCU-3 ANNUAL Controlled Emissions from Worst Case Barge






Appendix C Impacts Analysis

Administrative Information

Data Type: Facility Information:

Permit Number: NSR Permit 9442

Regulated Entity ID: 100248749

Facility Name: Southwest Shipyard Channelview

Facility Address: 18310 Market Street, Channelview TX 77530

County: Harris

Company Name: Southwest Shipyard, L.P.

Modeling Contact Name: Ms. Elizabeth Stanko

Modeling Company Name: TRC Environmental Corporation

Modeling Contact Number: 713-244-1039

Modeling Contact email: [email protected]

Air dispersion modeling using the USEPA SCREEN3 air quality model was previously

performed for the PCP SP registration to demonstrate that the collateral increases in air

contaminants as a result of the standard permit were protective of the National Ambient Air

Quality Standard (NAAQS) and public health and welfare. As such, the previously submitted

AQA was used to perform a qualitative assessment of impacts for the subject NSR Permit 9442

amendment application. The purpose of this amendment application is to consolidate by

incorporation PCP Standard Permit No. 154687 into NSR Permit 9442. No changes to any other

sources are requested as part of this amendment.

Incorporation of the PCP SP results in an increase in emissions of products of combustion from

the new VCUs, and the following pollutants were evaluated for short‐term (hourly) and annual

emission rate increases; nitrogen oxides (NOX), carbon monoxide (CO), and sulfur dioxide (SO2).

The PCP SP incorporation proposes a large decrease in volatile organic compounds (VOC)

emissions due to a higher VOC DRE for the VCUs, and therefore there will be no increase in

pollutants (i.e., VOC) requiring a state health effects analysis.

For the collateral increase in NAAQS pollutants, Southwest Shipyard performed a SCREEN3

modeling analysis that demonstrates that impacts of products of combustion (NOX, CO, and SO2

emissions) from the VCUs are below the NAAQS Significant Impact Levels (SILs) for all

pollutants and averaging periods, and therefore will not cause or contribute to an exceedance of

the NAAQS. Results of the analysis are summarized in the following sections to provide a



qualitative assessment of impacts for the minor NSR NAAQS and State Property Line standard

for SO2.

State NAAQS Analysis The model predicted concentrations obtained using the modeling approach and methodologies

described in the attached PCP SP AQA are presented in Table 1 to demonstrate compliance

with applicable NAAQS for CO, NO2, and SO2 emissions. A preliminary impact analysis was

conducted for the 1‐hr and 8‐hr CO NAAQS, 1‐hr and annual NO2 NAAQS, and 1‐hr, 3‐hr, 24‐

hr, and annual SO2 NAAQS. Full conversion of NOX to NO2 (Tier I) as assumed for the 1‐hr and

annual NO2 NAAQS analysis. Table 1 compares the GLCMAX with the NAAQS SIL for each

evaluated criteria pollutant.

Table 1 NAAQS SIL Analysis Results

CRITERIA POLLUTANT

AVERAGING PERIOD NAAQS SIGNIFICANT IMPACT LEVEL (SIL)

(µg/m3)

MAXIMUM PREDICTED CONCENTRATION - GLCMAX

(µg/m3)

CO 1-Hour 2,000 15.37

8-Hour 500 10.76

NO2 1-Hour 7.5 3.89

Annual 1.0 0.02

SO2

1-Hour 7.8 0.008

3-Hour 25 0.007

24-Hour 5 0.003

Annual 1 0.001

The predicted concentrations of all criteria pollutants evaluated were less than the SILs for all

applicable averaging periods and a full‐impact refined analysis is not required for these

pollutants. Therefore, the proposed project emissions will not cause or contribute to a violation

of the NAAQS and no further evaluation is necessary.

State Property Line Analysis A State Property Line analysis was performed by modeling SO2 emission increases and

evaluating the maximum 1‐hour average GLCMAX in comparison to 2‐percent of the 30‐minute

State Property Line Standard for Harris County for SO2. Table 2 presents the results.



Table 2 State Property Line Results

AIR CONTAMINANT

AVERAGING PERIOD

HARRIS COUNTY STATE PROPERTY LINE STANDARD

(µg/m3)

2 PERCENT OF STATE PROPERTY LINE

STANDARD

(µg/m3)

MAXIMUM PREDICTED CONCENTRATION

GLCMAX

(µg/m3)

SO2 30-minute [1] 715 14.3 0.008

[1] 1‐hour GLCMAX used for regulatory comparison.

With the above analysis, the State Property Line analysis is complete and demonstrate that the

applicable property line standards will not be exceeded.

I Basis:

SourceStack Height

(ft)Stack Height

(m)Heat Release (Btu/hr)

Distance to Property Line(ft)

VCU-2 40.0 12.19 67,500,000 215

VCU-3 40.0 12.19 67,500,000 195

Modeled Flare Sources

TABLE C-1: Modeled Source Parameters

SOUTHWEST SHIPYARD, L.P.POLLUTION CONTROL PROJECT STANDARD PERMIT (PCP SP)

Air Quality Analysis (AQA)Previously Submitted in November 2018

The new Vapor Combustor Units (VCUs) are enclosed flares and were therefore modeled using the flare source characterization in EPA’s SCREEN3 dispersion model. This method utilizes the height of release and the gross heat release from the flare. The height of release is the actual height of the flare tip. The model uses the gross heat release from the flare together with a fixed exit gas temperature and exit gas velocity to internally calculate the effective diameter. The modeled heat release (BTU/hour) represents the maximum hourly heat input per VCU stack used in the maximum hourly emission calculations. The proposed location of the new control equipment, as shown in the plot plan, was used to determine the distance to the property line. The new control equipment will be located is very close proximity to the existing flares, which will be shutdown from the barge degassing area.

Appendix C Page 1 of 3 C-1 Stack Parameters

1-hr (ug/m3 per lb/hr)




Annual (ug/m3 per tpy)

VCU-2 2,687 819 0.3795 0.342 0.266 0.152 0.007

VCU-3 2,687 819 0.3795 0.342 0.266 0.152 0.007

SourceDistance to

Max (ft)

SCREEN3 Predicted Maximum Ground Level Concentration (GLCmax) with a Unit Emission Rate

(µg/m3 per lb/hr)1Distance to Max (m)



TABLE C-2: Modeled Unit Impacts

1 3-hr, 8-h, 24-hr, and annual unit impacts were calculated using the EPA adjustment factors of 0.9, 0.7, 0.4, and 0.08, respectively. Additionally, the annual unit impacts has been multiplied by (2000 lbs/ton / 8760 hours/year) in order to convert from the unit hourly emission rate.

II Models Used and Modeling Techniques: The U.S. EPA SCREEN3 model (version dated 13043) was used to predict the maximum predicted concentrations for the modeled sources. The following model options were used in the application of the SCREEN3 model:-- Regulatory default options (i.e. mixing height and anemometer height);-- Flat terrain;-- All Stability and Wind Speed Meteorological default options;-- Rural option (conservative default);-- Building wake effects (downwash) was utilized in this analysis to determine if stack discharges might become caught in the turbulent wakes of nearby structures. -- For this analysis, a unit emission rates of 1 lb/hour (0.126 g/s) was modeled. For 3-hour, 8-hour, 24-hour and annual averaging periods, the SCREEN3 1-hour concentration estimates were converted to the averaging period of the applicable air quality standards using EPA multiplying factors.

The SCREEN3 predicted maximum concentrations for the modeled sources occurs beyond the property line, and therefore the maximum predicted impacts are the same for the identical replacement control equipment units.

Appendix C Page 2 of 3 C-2 Unit Impacts

III State NAAQS Analysis Results

Hourly Annual Hourly Annual Hourly Annual

VCU-2 5.13 1.62 20.25 6.40 0.011 0.05

VCU-3 5.13 1.62 20.25 6.40 0.011 0.05

1-hr Annual 1-hr 8-hr 1-hr 3-hr 24-hr Annual

VCU-2 0.379 0.342 0.266 0.152 0.007 1.95 0.01 7.68 5.38 0.004 0.004 0.002 0.0003

VCU-3 0.379 0.342 0.266 0.152 0.007 1.95 0.01 7.68 5.38 0.004 0.004 0.002 0.0003

3.89 0.02 15.37 10.76 0.008 0.007 0.003 0.001

7.5 1 2000 500 7.8 25 5 1

Yes Yes Yes Yes Yes Yes Yes Yes

Total Estimated Impacts

Modeled Project Emission Rates for Criteria Pollutants

SIL (ug/m3)

Less Than SIL?

SourceSO2

Source

Unit Impacts (ug/m3 per lb/hr or tpy)

1-hr 8-hr AnnualNO2

NAAQS Modeling Impacts

SO2

3-hr



CO

TABLE C-3: Modeling Results - NAAQS Analysis

24-hr

NOX CO

A NAAQS analysis was performed to demonstrate compliance with applicable standards and guideline concentrations for offsite impacts of criteria pollutants (NO2, CO, and SO2). The proposed project increases of the criteria air pollutants were evaluated against the NAAQS SILs to determine if impacts were less than the de minimis thresholds. The modeling results of the NAAQS preliminary impact analysis were determined using the SCREEN3 predicted unit impact multipliers (shown in Table C-2) for the applicable averaging periods. Table C-3 summarizes the modeled project emission rates for criteria pollutants, and the NAAQS preliminary impact analysis results for comparison to all of the applicable NAAQS SILs. NOx emissions were conservatively assumed to be 100-percent NO2.

The NAAQS significant impact modeling results indicate that the SCREEN3 predicted GLCMAX associated with the proposed project emissions were less than the SIL for all pollutants and all applicable averaging periods. Therefore, a full-impact refined NAAQS analysis is not required for any pollutants. As such, the project will not cause or contribute to a violation of the applicable NAAQS standards, and the State NAAQS demonstration is complete.

Appendix C Page 3 of 3 C-3 NAAQS Analysis

VCU‐2 11/16/18 13:34:54

*** SCREEN3 MODEL RUN *** *** VERSION DATED 13043 ***

VCU‐2

SIMPLE TERRAIN INPUTS: SOURCE TYPE = FLARE EMISSION RATE (G/S) = 0.126000 FLARE STACK HEIGHT (M) = 12.1920 TOT HEAT RLS (CAL/S) = 0.472492E+07 RECEPTOR HEIGHT (M) = 0.0000 URBAN/RURAL OPTION = RURAL EFF RELEASE HEIGHT (M) = 19.2605 BUILDING HEIGHT (M) = 6.0960 MIN HORIZ BLDG DIM (M) = 10.6680 MAX HORIZ BLDG DIM (M) = 12.1920

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 78.341 M**4/S**3; MOM. FLUX = 47.771 M**4/S**2.

*** FULL METEOROLOGY ***

********************************** *** SCREEN AUTOMATED DISTANCES *** **********************************

*** TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES ***

DIST CONC U10M USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M) DWASH ‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐‐ ‐‐‐‐‐‐ ‐‐‐‐‐‐ ‐‐‐‐‐‐ ‐‐‐‐‐

66. 0.1432E‐03 6 1.0 1.4 10000.0 112.85 22.34 22.23 NO 100. 0.7060E‐02 5 1.0 1.3 10000.0 137.08 34.06 33.69 NO 200. 0.8634E‐02 5 1.0 1.3 10000.0 137.08 35.61 34.23 NO 300. 0.3485E‐01 3 10.0 10.7 3200.0 68.89 35.26 21.92 NO 400. 0.1487 3 10.0 10.7 3200.0 68.89 45.74 28.25 NO 500. 0.2632 3 10.0 10.7 3200.0 68.89 55.97 34.43 NO 600. 0.3303 3 10.0 10.7 3200.0 68.89 66.01 40.47 NO 700. 0.3674 4 20.0 22.1 6400.0 41.57 49.66 24.99 NO 800. 0.3792 4 20.0 22.1 6400.0 41.57 56.00 27.65 NO 900. 0.3755 4 20.0 22.1 6400.0 41.57 62.26 30.25 NO 1000. 0.3627 4 20.0 22.1 6400.0 41.57 68.47 32.82 NO 1100. 0.3430 4 20.0 22.1 6400.0 41.57 74.63 34.81 NO

Page 1

VCU‐2 1200. 0.3231 4 20.0 22.1 6400.0 41.57 80.73 36.74 NO 1300. 0.3099 4 15.0 16.5 4800.0 50.44 87.00 39.09 NO 1400. 0.2978 4 15.0 16.5 4800.0 50.44 93.00 40.89 NO 1500. 0.2853 4 15.0 16.5 4800.0 50.44 98.97 42.66 NO 1600. 0.2729 4 15.0 16.5 4800.0 50.44 104.89 44.39 NO 1700. 0.2608 4 15.0 16.5 4800.0 50.44 110.78 46.08 NO 1800. 0.2490 4 15.0 16.5 4800.0 50.44 116.64 47.75 NO 1900. 0.2408 4 10.0 11.0 3200.0 67.29 122.90 50.42 NO 2000. 0.2352 4 10.0 11.0 3200.0 67.29 128.68 51.99 NO 2100. 0.2293 4 10.0 11.0 3200.0 67.29 134.43 53.54 NO 2200. 0.2232 4 10.0 11.0 3200.0 67.29 140.16 55.06 NO 2300. 0.2171 4 10.0 11.0 3200.0 67.29 145.86 56.56 NO 2400. 0.2111 4 10.0 11.0 3200.0 67.29 151.54 58.05 NO 2500. 0.2050 4 10.0 11.0 3200.0 67.29 157.19 59.51 NO 2600. 0.1991 4 10.0 11.0 3200.0 67.29 162.82 60.95 NO 2700. 0.1939 4 8.0 8.8 2560.0 79.30 168.75 63.22 NO 2800. 0.1900 4 8.0 8.8 2560.0 79.30 174.33 64.61 NO 2900. 0.1859 4 8.0 8.8 2560.0 79.30 179.89 65.98 NO 3000. 0.1831 2 1.0 1.0 526.4 525.42 434.02 392.43 NO 3500. 0.1985 5 1.5 1.9 10000.0 122.18 161.46 54.69 NO 4000. 0.2171 5 1.5 1.9 10000.0 122.18 181.46 57.81 NO 4500. 0.2299 5 1.0 1.3 10000.0 137.08 201.91 62.63 NO 5000. 0.2408 5 1.0 1.3 10000.0 137.08 221.43 65.09 NO 5500. 0.2490 5 1.0 1.3 10000.0 137.08 240.78 67.46 NO 6000. 0.2549 5 1.0 1.3 10000.0 137.08 259.96 69.74 NO 6500. 0.2588 5 1.0 1.3 10000.0 137.08 278.98 71.96 NO 7000. 0.2612 5 1.0 1.3 10000.0 137.08 297.85 74.12 NO 7500. 0.2622 5 1.0 1.3 10000.0 137.08 316.57 76.21 NO 8000. 0.2621 5 1.0 1.3 10000.0 137.08 335.16 78.25 NO 8500. 0.2612 5 1.0 1.3 10000.0 137.08 353.63 80.24 NO 9000. 0.2595 5 1.0 1.3 10000.0 137.08 371.97 82.18 NO 9500. 0.2573 5 1.0 1.3 10000.0 137.08 390.20 84.08 NO 10000. 0.2546 5 1.0 1.3 10000.0 137.08 408.31 85.94 NO 15000. 0.2156 5 1.0 1.3 10000.0 137.08 584.36 101.31 NO 20000. 0.1956 6 1.0 1.4 10000.0 112.85 501.66 65.96 NO 25000. 0.1791 6 1.0 1.4 10000.0 112.85 610.34 70.15 NO 30000. 0.1645 6 1.0 1.4 10000.0 112.85 716.09 73.85 NO 40000. 0.1389 6 1.0 1.4 10000.0 112.85 920.61 79.14 NO 50000. 0.1203 6 1.0 1.4 10000.0 112.85 1117.74 83.58 NO

MAXIMUM 1‐HR CONCENTRATION AT OR BEYOND 66. M: 819. 0.3795 4 20.0 22.1 6400.0 41.57 57.25 28.17 NO

DWASH= MEANS NO CALC MADE (CONC = 0.0) DWASH=NO MEANS NO BUILDING DOWNWASH USED DWASH=HS MEANS HUBER‐SNYDER DOWNWASH USED DWASH=SS MEANS SCHULMAN‐SCIRE DOWNWASH USED DWASH=NA MEANS DOWNWASH NOT APPLICABLE, X<3*LB

Page 2

VCU‐2

**************************************** *** REGULATORY (Default) *** PERFORMING CAVITY CALCULATIONS WITH ORIGINAL SCREEN CAVITY MODEL

(BRODE, 1988) ****************************************

*** CAVITY CALCULATION ‐ 1 *** *** CAVITY CALCULATION ‐ 2 *** CONC (UG/M**3) = 0.000 CONC (UG/M**3) = 0.000 CRIT WS @10M (M/S) = 99.99 CRIT WS @10M (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 CAVITY HT (M) = 7.10 CAVITY HT (M) = 6.82 CAVITY LENGTH (M) = 10.82 CAVITY LENGTH (M) = 12.99 ALONGWIND DIM (M) = 10.67 ALONGWIND DIM (M) = 12.19

CAVITY CONC NOT CALCULATED FOR CRIT WS > 20.0 M/S. CONC SET = 0.0

**************************************** END OF CAVITY CALCULATIONS ****************************************

*************************************** *** SUMMARY OF SCREEN MODEL RESULTS *** ***************************************

CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UG/M**3) MAX (M) HT (M) ‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐ SIMPLE TERRAIN 0.3795 819. 0.

Page 3

VCU‐3 11/16/18 13:34:18

*** SCREEN3 MODEL RUN *** *** VERSION DATED 13043 ***

VCU‐3

SIMPLE TERRAIN INPUTS: SOURCE TYPE = FLARE EMISSION RATE (G/S) = 0.126000 FLARE STACK HEIGHT (M) = 12.1920 TOT HEAT RLS (CAL/S) = 0.472492E+07 RECEPTOR HEIGHT (M) = 0.0000 URBAN/RURAL OPTION = RURAL EFF RELEASE HEIGHT (M) = 19.2605 BUILDING HEIGHT (M) = 6.0960 MIN HORIZ BLDG DIM (M) = 10.6680 MAX HORIZ BLDG DIM (M) = 12.1920

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 78.341 M**4/S**3; MOM. FLUX = 47.771 M**4/S**2.

*** FULL METEOROLOGY ***

********************************** *** SCREEN AUTOMATED DISTANCES *** **********************************

*** TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES ***

DIST CONC U10M USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M) DWASH ‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐ ‐‐‐‐‐‐ ‐‐‐‐‐‐ ‐‐‐‐‐‐ ‐‐‐‐‐‐ ‐‐‐‐‐

59. 0.2715E‐04 6 1.0 1.4 10000.0 112.85 20.92 20.83 NO 100. 0.7060E‐02 5 1.0 1.3 10000.0 137.08 34.06 33.69 NO 200. 0.8634E‐02 5 1.0 1.3 10000.0 137.08 35.61 34.23 NO 300. 0.3485E‐01 3 10.0 10.7 3200.0 68.89 35.26 21.92 NO 400. 0.1487 3 10.0 10.7 3200.0 68.89 45.74 28.25 NO 500. 0.2632 3 10.0 10.7 3200.0 68.89 55.97 34.43 NO 600. 0.3303 3 10.0 10.7 3200.0 68.89 66.01 40.47 NO 700. 0.3674 4 20.0 22.1 6400.0 41.57 49.66 24.99 NO 800. 0.3792 4 20.0 22.1 6400.0 41.57 56.00 27.65 NO 900. 0.3755 4 20.0 22.1 6400.0 41.57 62.26 30.25 NO 1000. 0.3627 4 20.0 22.1 6400.0 41.57 68.47 32.82 NO 1100. 0.3430 4 20.0 22.1 6400.0 41.57 74.63 34.81 NO

Page 1

VCU‐3 1200. 0.3231 4 20.0 22.1 6400.0 41.57 80.73 36.74 NO 1300. 0.3099 4 15.0 16.5 4800.0 50.44 87.00 39.09 NO 1400. 0.2978 4 15.0 16.5 4800.0 50.44 93.00 40.89 NO 1500. 0.2853 4 15.0 16.5 4800.0 50.44 98.97 42.66 NO 1600. 0.2729 4 15.0 16.5 4800.0 50.44 104.89 44.39 NO 1700. 0.2608 4 15.0 16.5 4800.0 50.44 110.78 46.08 NO 1800. 0.2490 4 15.0 16.5 4800.0 50.44 116.64 47.75 NO 1900. 0.2408 4 10.0 11.0 3200.0 67.29 122.90 50.42 NO 2000. 0.2352 4 10.0 11.0 3200.0 67.29 128.68 51.99 NO 2100. 0.2293 4 10.0 11.0 3200.0 67.29 134.43 53.54 NO 2200. 0.2232 4 10.0 11.0 3200.0 67.29 140.16 55.06 NO 2300. 0.2171 4 10.0 11.0 3200.0 67.29 145.86 56.56 NO 2400. 0.2111 4 10.0 11.0 3200.0 67.29 151.54 58.05 NO 2500. 0.2050 4 10.0 11.0 3200.0 67.29 157.19 59.51 NO 2600. 0.1991 4 10.0 11.0 3200.0 67.29 162.82 60.95 NO 2700. 0.1939 4 8.0 8.8 2560.0 79.30 168.75 63.22 NO 2800. 0.1900 4 8.0 8.8 2560.0 79.30 174.33 64.61 NO 2900. 0.1859 4 8.0 8.8 2560.0 79.30 179.89 65.98 NO 3000. 0.1831 2 1.0 1.0 526.4 525.42 434.02 392.43 NO 3500. 0.1985 5 1.5 1.9 10000.0 122.18 161.46 54.69 NO 4000. 0.2171 5 1.5 1.9 10000.0 122.18 181.46 57.81 NO 4500. 0.2299 5 1.0 1.3 10000.0 137.08 201.91 62.63 NO 5000. 0.2408 5 1.0 1.3 10000.0 137.08 221.43 65.09 NO 5500. 0.2490 5 1.0 1.3 10000.0 137.08 240.78 67.46 NO 6000. 0.2549 5 1.0 1.3 10000.0 137.08 259.96 69.74 NO 6500. 0.2588 5 1.0 1.3 10000.0 137.08 278.98 71.96 NO 7000. 0.2612 5 1.0 1.3 10000.0 137.08 297.85 74.12 NO 7500. 0.2622 5 1.0 1.3 10000.0 137.08 316.57 76.21 NO 8000. 0.2621 5 1.0 1.3 10000.0 137.08 335.16 78.25 NO 8500. 0.2612 5 1.0 1.3 10000.0 137.08 353.63 80.24 NO 9000. 0.2595 5 1.0 1.3 10000.0 137.08 371.97 82.18 NO 9500. 0.2573 5 1.0 1.3 10000.0 137.08 390.20 84.08 NO 10000. 0.2546 5 1.0 1.3 10000.0 137.08 408.31 85.94 NO 15000. 0.2156 5 1.0 1.3 10000.0 137.08 584.36 101.31 NO 20000. 0.1956 6 1.0 1.4 10000.0 112.85 501.66 65.96 NO 25000. 0.1791 6 1.0 1.4 10000.0 112.85 610.34 70.15 NO 30000. 0.1645 6 1.0 1.4 10000.0 112.85 716.09 73.85 NO 40000. 0.1389 6 1.0 1.4 10000.0 112.85 920.61 79.14 NO 50000. 0.1203 6 1.0 1.4 10000.0 112.85 1117.74 83.58 NO

MAXIMUM 1‐HR CONCENTRATION AT OR BEYOND 59. M: 819. 0.3795 4 20.0 22.1 6400.0 41.57 57.25 28.17 NO

DWASH= MEANS NO CALC MADE (CONC = 0.0) DWASH=NO MEANS NO BUILDING DOWNWASH USED DWASH=HS MEANS HUBER‐SNYDER DOWNWASH USED DWASH=SS MEANS SCHULMAN‐SCIRE DOWNWASH USED DWASH=NA MEANS DOWNWASH NOT APPLICABLE, X<3*LB

Page 2

VCU‐3

**************************************** *** REGULATORY (Default) *** PERFORMING CAVITY CALCULATIONS WITH ORIGINAL SCREEN CAVITY MODEL

(BRODE, 1988) ****************************************

*** CAVITY CALCULATION ‐ 1 *** *** CAVITY CALCULATION ‐ 2 *** CONC (UG/M**3) = 0.000 CONC (UG/M**3) = 0.000 CRIT WS @10M (M/S) = 99.99 CRIT WS @10M (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 CAVITY HT (M) = 7.10 CAVITY HT (M) = 6.82 CAVITY LENGTH (M) = 10.82 CAVITY LENGTH (M) = 12.99 ALONGWIND DIM (M) = 10.67 ALONGWIND DIM (M) = 12.19

CAVITY CONC NOT CALCULATED FOR CRIT WS > 20.0 M/S. CONC SET = 0.0

**************************************** END OF CAVITY CALCULATIONS ****************************************

*************************************** *** SUMMARY OF SCREEN MODEL RESULTS *** ***************************************

CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UG/M**3) MAX (M) HT (M) ‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐ SIMPLE TERRAIN 0.3795 819. 0.

Page 3

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DATE: NOVEMBER 2019


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Channelview Yard


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Appendix D Current Permits

Jon Niermann, Chairman

Emily Lindley, Commissioner

Toby Baker, Executive Director

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Protecting Texas by Reducing and Preventing Pollution

P.O. Box 13087 • Austin, Texas 78711-3087 • 512-239-1000 • tceq.texas.gov

How is our customer service? tceq.texas.gov/customersurvey printed on recycled paper

December 12, 2018 MR DANIEL H IRVIN VICE PRESIDENT OF ENVIRONMENTAL AFFAIRS SOUTHWEST SHIPYARD LP 18310 MARKET ST CHANNELVIEW TX 77530-3858 Re: Pollution Control Projects Air Quality Standard Permit (Effective 2/9/2011) Standard Permit Registration Number: 154687 Standard Permit Expiration Date: December 12, 2028 Southwest Shipyard LP Channelview Barge Cleaning and Degassing Facilities Affected Permit: 9442 Channelview, Harris County Regulated Entity Number: RN100248749 Customer Reference Number: CN600135354 Dear Mr. Irvin: This is in response to your Form PI-1S (Air Quality Standard Permit for Pollution Control Projects) regarding the proposed construction to be located at 18310 Market St, Channelview, Harris County. We understand that this registration is for emissions associated with the replacement of two flares with two vapor combustion units (EPN: VCU-2, VCU-3). After evaluation of the information you submitted, the Texas Commission on Environmental Quality (TCEQ) has determined that your proposed emissions are authorized by this standard permit pursuant to Title 30 Texas Administrative Code § 116.602 (30 TAC § 116.602) if constructed and operated as represented in your registration. This standard permit was issued under the Texas Clean Air Act (TCAA) § 382.011, which authorizes the commission to control the quality of the state’s air; TCAA § 381.023, which authorizes the commission to issue orders necessary to carry out the policy and purposes of the TCAA; and § 382.05195, which authorizes the commission to issue standard permits. Authorized emissions are listed on the attached table. You must begin construction or modification of these facilities in accordance with this standard permit no later than 18 months after the date of this letter. After completion of construction or modification, the appropriate TCEQ Regional Office must be notified prior to commencing operation and the facility shall be operated in compliance with all applicable conditions of the claimed standard permit. You are reminded that 30 TAC § 116.615 requires that any construction or change authorized by this standard permit be administratively incorporated into the affected facilities’ permit(s) at the next amendment or renewal. You are also reminded that these facilities must be in compliance with all rules and regulations of the TCEQ and of the U.S. Environmental Protection Agency at all times.

Mr. Daniel H Irvin Page 2 December 12, 2018 Re: Standard Permit Registration Number 154687

If you need further information or have any questions, please contact Mr. Guillermo Reyes, P.E. at (512) 239-5716 or write to the Texas Commission on Environmental Quality, Office of Air, Air Permits Division, MC-163, P.O. Box 13087, Austin, Texas 78711-3087. This action is taken under authority delegated by the Executive Director of the TCEQ. Sincerely,

Mark Meyer, Manager Rule Registrations Section Air Permits Division Texas Commission on Environmental Quality cc: Director, Harris County, Pollution Control Services, Pasadena Air Section Manager, Region 12 - Houston


Standard Permit Maximum Emission Rates Table Permit Number 154687

The facilities and emissions included in this table have been represented and reviewed as the maximum emissions authorized by this standard permit registration.

Emission Point No. Source Name NSR Permit Pollutant Authorized PCP Emissions

lbs/hr tpy

VCU-2, VCU-3 Vapor Combustor Units 154687

VOC 4.22 5.34

NOx 10.26 3.24

CO 40.50 12.80

SO2 0.02 0.09

VOC - volatile organic compounds NOx - total oxides of nitrogen CO - carbon monoxide SO2 - sulfur dioxide **Fugitive emissions are an estimate only and should not be considered as a maximum allowable

Date: December 12, 2018

l.TEXAS COn/tvI ISSI ON ON ENVIRONMENTThI QUALTTY

AIR QUALITY PERMIT

A Permit Is Hereby IssuedToSouttrwest Shipyard, L.P.

Aulhorizing the Construction and Operation ofSouthwest Shipyard

Located at Channelview, Harris Count5r, TexasLatitude 29" 47'28" Iongitude -9So g'- SS"

Permit:9442

Revision Date:

Expiration Date: October zz, zozo

Facilities covered by this permit shall be consbrrcted and operated as specified in the applicationfor the permit. All representations regarding construction plans and operation proceduriicontained in the permit application shall be conditions upon which the permit is issued. Variationsfrom these representations shall be unlawful unless the perrnit holder first makes application to theTexas Commissisn on Environmental Quality (commission) Executive Directorto amendthispermit in that regard and such amendment is approved. [Tifle 3o Texas Administrative Code116.116 (3o TAC u6.rr6)lVoiding of Perrnit. A permit or permit amendment is automatically void if the holder fails tobegin constmction within 18 months of the date of issuance, discontinues construction for morethan 18 months prior to completion, or fails to complete construction within a reasonable time.Upon request,,the executive director maygrant an r8-month extension. Before the extension isgranted the permit maybe subject to revision based on best available control technolory, Iowestachievable emission rate, and netting or offsets as applicable. One additional extension of up to 18months maybe granted if the permit holder demonstrates that emissions from the facilitywillcomply with all rules and regulations of the commission, the intent of the Texas Clean air Act(TCAA), including protection of the public's health and physical property; and (bXr)the permitholder is a party to litigation not of the permit holder's initiation regarding the issuance of thepennit; or (bXz) the permit holder has spent, or committed to spend, at least 10 percent of theestimated total cost of the project up to a maximum of g5 millisn. A pemit holder granted anextension under subsection (bXt) of this section may receive one subsequent extension if the permitholder meets the conditions of subsection OXz) of this section. [3o TAC rr6.rzo(a), (b) and (c)]Construetion Progress. Start of construction, construction intemrptions exceeding 45 days, andcompletion of constnrction shall be reported to the appropriate regional of,Ece of the commissi6anot later than 15 working days after occrurence of the event. [3o TAC rr6.rrsGX2XA)]Start-up Noffication. The appropriate air program regional office shall be notified prior to ttrecorlmencement of operations of the facilities authorized by the pemit in such n prnnsl that arepresentative of the commission maybe present. The permit holder shall provide a separate ..

notification forthe corlmencement of operations for each unit of phased construction, which mayinvolve a series 6f rinits commencing operations at different times. prior to operation of thefacilities authorized by the permit, the permit holder shall identiff the source or sources ofallowances to be utilized for compliance with Chapter ror, Subchapter H, Division 3 of this title(relating to Mass Emissions Cap and Trade Program). [go TAC rr6.rrs@XzXBXiii)]Sarnpling Requirements. If sampling is required, the permit holder shall contact thecommission's Office of Compliance and Enforcement prior 1e empling to obtain the proper dataforms and procedures. All sampling and testing procedures must be approved by thelxe-cutivedirector and coordinated with the regional representatives of the mmmfusion. The permit holder isalso responsible for providing sampling facilities and conducting the sampling operitions orcontracting with an independent sampling consultant. [go TAC rr6.rrSGXzXC)]

Mav 18. zors aaa1.

4.

For the Commission

Revised (ro/rz)

3.

o,]

6. Equivalency of Methods. The permit holder mrrst demonstr-atg or otherwise justif the

"q-iri"rt"""v jgsm;ssion conhol --"tt od., sampling or other emission testing methods, and

mbnitori"! methods proposed as alternatives to methods indicated in the conditions of the permit.Altemative *"tnoa" inuU U" applied for in wrjfinf and riiirs'be reviewed and approved by theexecutive alirectorpri"itoinriiuruinfuIfiiling aiyrequirements ofthepermit. l3o TAC

rr6.rrsGX2xD)l :

T. i"""iat "r;pilL. The permit holder shall maintain a copy of the permit ato-n_g with records

containing the ioformatibn and data sufEcient to demonstrate complian:e with thj: nermij, -including production records 4nd operating hours; keep all required r-ecglds h

? flg ut F9 p]"ot '

site. If, fiowewer, the facility normally operates unattended, rgcords gh.{ be maintained at thel r

o"*"si staffed location within Texas specified in the applicationi make the records available at therequest of pslssnlel from the semmisiion or any air pollution_control program !ryi"g j*it{ietion;comply with any additional recordkeeping requirements specified r1 qnegial condilionl atQchdd tothe penmit; and retais information in the.file for at leqst two years following the date that the ,

info-rmation or data is obtained. .[go TAC rr6.rrS(bX2XEI , , , ,!. ,

8. MardmumAllowable Ernission Bates. The total emissions of air contaminants from any gf thesonrces of emissions must not exceed the values stated on the table attachedtothe permit endtled"Emission Sources-Maximum Allowable E'-mission Rates." {3o TAC rr6:rrS(bXzXF)] - !.

g. Maintenance of Ernission Confol. Ttre pennitted facilities shall notbe ope_r1ted tr1l"o aI airpollution emission chpture and abatement equipment is maintained in,g99d yorlglq order-and-

operating properly during normal facilily operitions. The permit hotder:sh{ provide 1o!ficglonfor upsets and maintenance in accordance with Bo TAC 1o1.2o1, 101.211, and 1or_rz_zr_o_t_t!is

tifle;(rehfrngto F'.missions Event Reporting and Recordkeeping,Requirements;_scheduledllaintenance,Stu"trp, uoa Shutdown Reporting and Recordkeeping Requirements; and Operational i

Requirements). [So TAC rr6.rrS&X2XG)] - i

ro. Compliance with Rules. Acceptance of a pemit Py q upplicant constitutes 1q ac:know-I9j$-e"tand afoeement that the permit holder wilt comply with all rules, regulatioqs, and orders of.the

comm-ission issued in confor-mity with the TCAA and the conditions precedent t9 the grantng of thepermit. If more tlan one state or federal,rule or regulation or_permit cgldition is-lndicaplg: F"-most

stringent limit or condition shall govern an! be the standard bywhiSh com_pliance shall bedemonstra:ted. ;Acceptance includes co-nsent to the enlrance of commissionemployees ald !89ntsinto tne permitted piemlses at reasonable times to investigate conditions r,gla!!8 !o the emission orconcentration of,air contaminants;inc-lufli[g compliance with the.permit. '[3o TAC ] ..; . ,l

r16.rrs(bX2xH)l,r. rfri" i"riliIi"",y 19tG traqsferred, assigned, or conveyed by the [older' except as provided by rule

[SoTACrr6.rro(e)].,,, i , '., r

rz. iir""" maybe additionat speclal conditions attached to a permit uponissuancg or modification ofthe permit. Such conditions in a permit maybe more restrictive than the requirements of Title 3o ofthe texasAdministrative Code. [bo TAC rr6.rrS(c)]

13. Errrissions from 'his facility,mlst not cause or contribute to a coa$tion of lair pll$p}],P .-

defined in Texas Health andsafety Code (TIISC) gSz.oog(3) orviolateTHqc gpz"o_85_1 If tu,executive director determines that such a condilion'of violation @curis, the holder shall implementadditional abatement measures as necessary to control or prevent the condition or violation.

r4. The permit holdei shall comply with aII the requirements of this pe.rmil. Emissions tlat exceed the

r^)

Revised (rolrz)

(-) [rEmission Sources - Maximum Allowable Emission Rates

Permit Number 9442

This table lists the maximum allowable emission rates and all sources of air contaminants on the applicant'sproperty coverecl by this permit. Ttre emission rates shown are those derived from information submitted aspart of the applicafion for permit and are the maximum rates allowed for these facilities, sources, and relatedactivities. Any proposed increase in emission rates may require an application for a moffication of thefacilities covered by this permit.

Air Contaminants Dataidl't t,:ti: I ," t I .t iir i

rtssg-,,'."..! ,,,',;.#f]"/t]ll:i''',.'r,j

iffiMAR-DOCKS Marine Emissions at

Docks !,215,4, and 5VOC 32.7 2.50

CA-r Carbon AdsorptionUnit

VOC 6s.s6 L.40

IOC-U o.25 o.o1

DRL-r Drum Loading voc 3.2 o.6z

FE-r Equipment Fugitives(s) VOC o.o23 o.o79

FI,]G-LOAD Transfer EquipmentFugitives (5) VOC o.10 o.46

FL-r, FL-3 Flares VOC 89.26 27.73

NOx 10.33 2.46

CO 2o.63 72.2

NDST-I, NDST-z Vacuum PumpE:rhaust

VOC 4.99 o.35

TAITIKS-r Caustic Tanks A2o1,Azoz VOC o.o1 o.o1

TANKS-z Storage TanksA+oo-A+og VOC 5.76 9.64

TANKS-g Storage Tanks Arr3-Au6,d3or,A4ro-A4r3,A5or, A5oz,ASoS, 45o6, A$oT,ASo8, ASo9, A5ro,A5rz, andASrg

VOC 5.76 2L.14

TANKS-4 WastewaterTanksAgoz-ASo+

VOC o.54 Lg6

IOC-U o.03 o.o1

TL-r Truck Ioading voc S.6 7.58

wwP WastewaterTreatrnent Plant VOC 1.O1 1.30

ProjectNumben 229889

r)

E.mission Sources _ MaximumAllowable F..mission Rates

oPermitNumber 9442Pagez

'

(r) F.mission point identification - either specific equipment designation or emission point number ftom plott t,,Dlan: -' ,."'i:- '. :' r,,1; - -

, " '1 r';- ; ' t'l-i'

(z) ^Specific point source neme. For firgitive sources, use area name or fugitive source nrle.iil fi"-pt'solvent - Those carbon Jompounds ormixtures of carbon_impounds used as_solvents which

have been excluded from the definition ofvolatile organic compound- volatile organic compounds as defined inTitle gO-TeSasA{qi1i{ative Code $ ror.r- highly reactive volatile organic compounds as defined in go TAC 5 rr5.ro- inorganic conipounds (unspeciated)

.- sulfur dioxide :

- total particulate matter, suspended in the ahosphere, including PMro and PMr.5, asrepresented

s thuo to microns in diameter, inclurting pMz.5, as- total particrllate matter equal to or les r diameter, includiqrepresented : --

- particulate matter equal to or less than 2.5'microns in diameter- carbon monoxide- hazardous air pollutant as listed in S rrz@) of the Federal CleanAirAct orTitle 4o Code

ofFederal Regulations Part 63, Subpart C(4) Compliance with annual emission limits (tons per year) is based on a rz month rolling perio{.-(S) Emission rate is an es';'lmate and is enforceable tlrough compliance with the applicable special coudition(s)

and permit application representations.(6) The ifep

"*Gion limit aiplies to all facilities at the site, regardless of authorization mechanism.r'

Date: ' May 18, zprs:

VOCHRVOCIOC-UNO,.so,PM

PM,O

PMr.sCOHAP

ProjectNumben 2298€9

SPECIAL CONDITIONS

Permit Number 9442 EMISSION STANDARDS AND OPERATING SPECIFICATIONS 1. This permit authorizes emissions only from those points listed in the attached table

entitled “Emission Sources - Maximum Allowable Emission Rates,” and the facilities covered by this permit are authorized to emit subject to the emission rate limits on that table and other operating requirements specified in the special conditions.

2. Non-fugitive emissions from relief valves, safety valves, or rupture discs of gases

containing volatile organic compounds (VOC) at a concentration of greater than 1 percent are not authorized by this permit unless authorized on the MAERT. Any releases directly to atmosphere from relief valves, safety valves, or rupture discs of gases containing VOC at a concentration greater than 1 weight percent are not consistent with good practice for minimizing emissions. (03/08)

3. Except as provided for below, the use of compounds at all emissions sources

including (but not limited to) degassing, de-heeling, drumming, storage, and tank truck loading is limited to those identified in Attachments I, II, and III. Modifications or construction of new facilities at the site that result in emission increases of the chemicals listed in Attachments I, II, or III or chemicals currently in use and previously authorized through the procedure below can only be approved through the use of the procedure below (if no physical modification/new construction) or through permit amendment. New compounds may be added through the use of the procedure below, 30 TAC Chapter 106, or 30 TAC Chapter 116. (03/08)

A. Short-term (pounds per hour [lb/hr]) and annual (TPY) emissions and

calculations shall be completed for each chemical at each affected source. Emission rates (ER) shall be calculated in accordance with the following methods, as documented in the permit amendment application (PI-1 dated August 8, 2007). The calculated ER shall not exceed the maximum allowable emissions rate at any emission point.

B. The Effect Screening Level (ESL) for the material shall be obtained from the

current TCEQ ESL list or by written request to the TCEQ Toxicology Section.

C. The total emissions of any compound from all emission points in this permit must satisfy one of the following conditions:

(1) The total maximum ER from all sources is less than 0.04 lb/hr and the

ESL greater than 2 ug/m3; or

SPECIAL CONDITIONS Permit Number 9442 Page 2

(2) (ER/ESL)N I < (ER/ESL)Ei

(ER/ESL)N i = maximum hourly ER of the new compound

divided by its ESL at emission source i

(ER/ESL)Ei = the highest ratio of any previously authorized

compound hourly ER divided by its ESL at emission source i

i = emission sources including (but not limited to)

degassing, de-heeling, drumming, storage, and tank truck loading

The above equation must be satisfied for each source where the new compound is emitted.

D. The permit holder shall maintain records of the information below and the

demonstrations in steps A though C above. The following documentation is required for each compound:

(1) Chemical name(s), composition, and chemical abstract registry number

if available. (2) True vapor pressure at maximum hourly and annual average storage

temperature. (3) Molecular weight. (4) Storage tanks, loading areas, and fugitive areas where the material is to

be handled and the emission control device to be utilized.

(5) Date new compound handling commenced.

(6) Material Safety Data Sheet. (7) Maximum concentration of the chemical in mole percent (or in weight

percent for fugitive areas) in the affected facilities.

E. This condition may not be used for pollutants listed on the most current Air Pollutant Watch List for Channelview or Harris County.

SPECIAL CONDITIONS Permit Number 9442 Page 3 4. The volume of vapor in terms of barrels (bbls) being degassed or vented to the

atmosphere shall be limited by the following equation: (03/08)

(BVj)i < (MDLj/SCj)i * 3,500 bbls

Where: (BVj) i = barge volume of compound j to be vented (bbls) at emission

source i. (MDLj/SCj) i = the minimum degassing level (MDL) of compound j in ppmv

as specified in Attachment II or III divided by the vent stream sample concentration (SC) of compound j in ppmv of the compound in barge at emission source i.

5. Drum loading or truck loading of a chemical shall not occur at the same time as the

chemical at Docks 1,2,3,4 or 5 is vented to the atmosphere. Operational records shall be kept on site to demonstrate compliance with this special condition. (03/08)

6. Pump rates of vapors to the appropriate control device shall not exceed

30,000 scf/hr set for impacts purposes. Pumps with a higher rate shall not be used unless an amendment is submitted and impacts are evaluated and approved.

7. Vapors requiring controls associated with the operations from Dock Nos. 1 shall be

routed to Dock No. FL-1 only. 8. A vapor collection system shall be installed which will produce a vacuum in a barge

during degassing operation. A minimum vacuum of one inch water column shall be maintained on the barge during degassing operations when the chemical being degassed is listed in Attachment II or Attachment III. The pressure/vacuum measuring device shall be calibrated at a frequency in accordance with the manufacturer’s specifications, or at least annually, whichever is more frequent, and shall be accurate to within two percent of span or five percent of the design value. Degassing operation shall cease immediately if a negative pressure of at least one inch of water column can not be maintained by the vacuum-assist vapor collection system. The vacuum shall be continuously monitored and recorded hourly during degassing operation. (03/08)

9. All vapor emitted from a barge containing a chemical listed in Attachment II and

Attachment III except for component fugitives must be routed to a flare (EPN FL-1 or FL-3) or a Carbon Adsorption Unit (EPN CA-1) during degassing operation for vapor destruction. Control must be maintained until the concentration for the chemical being degassed is no greater than the limit as specified in Attachment II or Attachment III prior to the barge being allowed to vent to the atmosphere. (03/08)

SPECIAL CONDITIONS Permit Number 9442 Page 4 10. The barge vent stream must be sampled to verify acceptable VOC concentration for

a chemical as specified in Attachment II or Attachment III prior to uncontrolled venting. The measurement of the volume of purge gas shall not include any make-up air introduced into the control device. The VOC sampling and analysis shall be performed using an instrument with a flame ionization detector (FID), or a TCEQ-approved alternative detector. The instrument/FID must meet all requirements specified in Section 8.1 of EPA Method 21 (Title 40 Code of Federal Regulations Part 60, Appendix A [40 CRF Part 60]). Sampling shall be performed as follows: (03/08)

A. Immediately prior to performing sampling, the instrument/FID shall be

calibrated with zero and span calibration gas mixtures. Zero gas shall be certified to contain between 0 and 10 ppmv total hydrocarbons. Span calibration gas shall be methane at a concentration within between 34,000 and 50,000 ppmv, and certified by the manufacturer to be ± 2 percent accurate. Calibration error for the zero and span calibration gas checks must be less than 5 percent of the span calibration gas value before sampling may be conducted. The results of these checks shall be recorded.

B. The sampling point shall be upstream of the inlet to the control device. The

sample ports and the collection system must be designed and operated such that there is no air leakage into the sample probe or the collection system downstream of the barge being purged.

C. During sampling, data recording shall not begin until after two times the

instrument response time. The date and time shall be recorded, and VOC concentration shall be monitored for at least 5 minutes, recording 1-minute averages. The highest one minute average measured concentration for the air contaminant shall not exceed the concentration as specified in Attachment II or Attachment III prior to uncontrolled venting.

11. Audio, olfactory, and visual inspections shall be made of quick connect joints,

fittings, and hoses in VOC service during all transfer operations. A. If a liquid leak is detected during VOC transfer, then the transfer operation

shall cease until the leak is repaired. B. If a vapor leak is detected during VOC transfer, then 30 TAC

§ 115.214(a)(3)(D) shall apply.

SPECIAL CONDITIONS Permit Number 9442 Page 5 12. Fuel gas combusted at this facility shall be sweet natural gas containing no more

than 5 grains of total sulfur per 100 dscf. 13. Flares shall be designed and operated in accordance with the following

requirements: A. The combined natural gas and waste stream to the flare tip shall meet the

40 CFR § 60.18 specifications for minimum net heating value and maximum tip velocity under normal, upset, and maintenance flow conditions. Compliance with this condition shall be demonstrated by the monitoring required in Section D below. Flare testing per 40 CFR § 60.18(f) is required to demonstrate compliance with this condition.

B. The flare shall be operated with a flame present at all times and have a

constant pilot flame. The pilot flame shall be monitored by a thermocouple or an infrared monitor.

C. The flare shall be operated with no visible emissions except periods not to

exceed a total of five minutes during any two consecutive hours. Such operation shall be ensured by the use of air assist to the flare. The permit holder shall ensure proper operation of the air assist through monitoring as required by Section D below.

D. The holder of this permit shall install a continuous run time flow monitor and

an analyzer that provides a record of the natural gas flow to the flare and an oxygen analyzer. The flow monitor sensor and oxygen analyzer sample points should be installed in the vent stream as near as possible to the flare inlet such that the total vent stream to the flare is measured and analyzed. Calibration of the flow meter shall be done once every two years. The flow rate and composition shall be recorded at least every hour. Records of the recorded values shall be maintained for two years and be made readily available upon request to representatives of the TCEQ or any local air pollution control program having jurisdiction upon request to show compliance with this condition.

14. Carbon Sampling. The operations for Attachment III compounds shall vent through

a carbon adsorption system (CAS) consisting of at least three activated carbon canisters that are connected in series.


A. The time interval that is less than the carbon replacement interval shall be determined and recorded by the maximum design rate and either the organic concentration or the maximum design.

B. The operator shall replace the carbon canisters in the CAS regularly at the

time interval determined in A.

C. Breakthrough shall be defined as a measured VOC concentration of 50 ppmv. Sufficient fresh activated carbon canisters shall be maintained at the site such that spent carbon canisters can be replaced as specified.

D. Records of the CAS monitoring maintained at the plant site shall include (but

are not limited to) the following:

(1) Methods and results of the determination of the carbon replacement interval; and

(2) Time and date when the replacement carbon canisters were installed.

These records shall be made readily available upon request to representatives of the TCEQ or any local air pollution control program having jurisdiction upon request to show compliance with this condition, and shall be retained for at least two years following the date that the data is obtained.

15. Wastewater Treatment - This facility shall be used only for the liquid phase separation of VOC and water in which the sum of the partial pressures of all species of VOC in any sample is less than 1.5 psia. Records shall be kept for all samples taken.

A. The holder of this permit shall perform sampling and other testing, as

necessary, to establish that the sum of the partial pressures of all species of VOC in any sample is less than 1.5 psia. The results of the monitoring and maintenance efforts shall be recorded, and such records shall be maintained for a period of two years. The records shall be made readily available upon request to representatives of the TCEQ or any local air pollution control program having jurisdiction upon request to show compliance with this condition.

B. All wastewater recovered after the first rinse from barge cleaning shall be

routed through the oil/water separator prior to storage and transfer to an approved treatment facility.

SPECIAL CONDITIONS Permit Number 9442 Page 7 C. The operating parameter(s) selected to demonstrate continuous compliance

with the design standard and all other operating information that will be used to assess continuous compliance shall be continuously monitored and recorded.

16. Truck Loading - Truck loading operation is limited to the compounds and their

respective maximum filling rates as specified in Attachment I, II, or III. All trucks, when loading compounds as specified in Attachment II or III for required vapor balancing, shall use vapor balancing systems to minimize the emissions. All truck loading shall be submerged. (03/08)

The permit holder shall maintain and update monthly an emissions record which includes calculated emissions of VOC from all truck loading operation over the previous rolling 12 month period. The record shall include the loading spot, control method used (if applicable), quantity loaded in gallons, name of the liquid loaded, vapor molecular weight, liquid vapor pressure in psi at monthly average temperature for Houston as detailed in EPA document AP-42 Table 7.1-7, liquid throughput for the previous month and rolling 12 months to date. Emissions shall be calculated using the TCEQ publication titled "Technical Guidance Package for Chemical Sources - Loading Operations." Monthly average temperatures for Houston as detailed in EPA document AP-42 Table 7.1-7 must be used in the calculations.

A. All lines and connectors shall be visually inspected for any defects prior to

hookup. Lines and connectors that are visibly damaged shall be removed from service until they are repaired to a leak-free state. Operations shall cease immediately upon detection of any liquid leaking from the lines or connections.

B. Each tank truck shall pass vapor-tight testing every 12 months using the

methods described in Title 40 Code of Federal Regulations Part 60 (40 CFR 60), Subpart XX. The permit holder shall not allow a tank truck to be filled unless it has passed a leak-tight test within the past year as evidenced by a certificate which shows the date the tank truck last passed the leak-tight test required by this condition and the identification number of the tank truck.

C. During the truck loading operation, compounds being loaded listed in

Attachment II or Attachment III shall not be emitted from any degassing emission point on the site at the same time. The site is limited to one truck loading of the same compound at any time. Barge degassing activities which


emit compounds as specified in Attachment II or III shall be documented including the description of the activity, start time, duration, and air contaminants emitted during the period of truck loading operation.

17. Storage Tanks A. The capacity of any tank at this site used to store chemicals appearing on

Attachments I, II, and III shall not exceed 25,000 gallons. B. Tanks A117 and A119 shall maintain a pressure that is sufficient at all times

to prevent vapor or gas loss to the atmosphere, or the tank or container shall be equipped with a relief valve which directs all vapors or gases to a control device having a stationary flue or a waste gas smokeless flare system. The vapors or gases and any necessary fuel gas shall be mixed thoroughly upstream of the heater burner(s) or the flare tip such that the mixed gases have a minimum net or lower heating value of 200 British thermal units per cubic foot.

C. The holder of this permit shall store all products with a vapor pressure greater

than 11.0 psia at maximum storage temperature in pressurized vessel. D. All storage tanks must be equipped with a permanent submerged fill pipe and

utilize bottom loading. E. The emissions from these facilities must be discharged to the atmosphere at a

level no lower than four feet above ground level. F. Tank exterior surfaces exposed to the sun shall be white. G. Storage and tank loading operations for tanks associated with EPNs TANKS-2

and TANKS-3 shall be limited to the filling rates represented in Table 3-E submitted April 9, 2008 for Attachment I compounds; Table 4-E submitted August 23, 2010 for Attachment II compounds; and Table 5-E submitted April 9, 2008 for Attachment III compounds. (09/10)

18. Operation without visible liquid leaks or spills shall be maintained at all

loading/unloading facilities, regardless of vapor pressure. This does not apply to momentary dripping associated with the initial connection or disconnection of fittings. Sustained dripping from fittings during loading/unloading operations is not permitted. Any liquid spill that occurs during loading/unloading activities shall be


reported pursuant to 30 TAC § § 101.201 or 101.211, and shall be cleaned up immediately to minimize air emissions. (8/03)

CONTINUOUS DEMONSTRATION OF COMPLIANCE 19. The permit holder shall maintain daily operational records during degassing

operations including atmospheric venting. Emission calculations for each chemical degassed or vented and total VOCs from all degassing operations including atmospheric venting shall be maintained on a monthly basis and rolling 12 month period. Monthly records shall at least include the following: (03/08)

A. Identification name or number of the barge; B. Name of the chemical in the barge; C. Control method used (if applicable); D. Molecular weight of each chemical handled;

E. Vapor pressure of each chemical handled in psi at monthly average temperature for Houston as detailed in EPA document AP-42 Table 7.1-7;

F. Time and date of barge degassing or venting commencement;

G. Time and date when barge degassing or venting complete;

H. Volume of barge tanks degassed to control;

I. Concentration of the degassing chemical measured in ppmv prior to the

barge being allowed to vent to the atmosphere; and J. Volume of barge tanks vented to atmosphere; Compliance Assurance Monitoring 20. The following requirements apply to capture systems for the flares designated as

EPNs FL-1 and FL-3. (10/10) A. If used to control VOC, either:


(1) Conduct a once a month visual, audible, and/or olfactory inspection of the capture system to verify there are no leaking components in the capture system; or

(2) Once a year, verify the capture system is leak-free by inspecting in

accordance with 40 CFR Part 60, Appendix A, Test Method 21. Leaks shall be indicated by an instrument reading greater than or equal to 500 ppmv above background.

B. The control device shall not have a bypass. or

If there is a bypass for the control device, comply with either of the following requirements:

(1) Install a flow indicator that records and verifies zero flow at least

once every fifteen minutes immediately downstream of each valve that if opened would allow a vent stream to bypass the control device and be emitted, either directly or indirectly, to the atmosphere; or

(2) Once a month, inspect the valves, verifying the position of the

valves and the condition of the car seals prevent flow out the bypass.

A deviation shall be reported if the monitoring or inspections indicate bypass of the control device.

C. Records of the inspections required shall be maintained and if the results

of any of the above inspections are not satisfactory, the permit holder shall promptly take necessary corrective action.


ATTACHMENT I

Permit Number 9442

Compounds Which Do Not Require any Control

CAS No.

Compound

Truck Loading Max filling Rate

(gal/hr) 68551-12-2 Alpha olefins (C12-C16) 18,000 N/A Alpha olefins (C16-C20) 18,000 93924-10-8 Alpha olefins (C20-C24) 18,00010043-01-3 Aluminum sulfate 18,000110-63-4 Butylene glycol 18,000 7789-41-5 Calcium bromide 18,000 10043-52-4 Calcium chloride 18,000 1310-73-2 Caustic soda solution (sodium hydroxide) 18,000 111-46-6 Diethylene glycol (vapor) 18,000 28553-12-0 Diisononyl phthalate 18,000 110-98-5 Dipropylene glycol 18,000 119-06-2 Ditridecyl phthalate 18,000 149-57-5 Ethylhexanoic acid, 2- 18,000 7720-78-7 Ferrous sulfate 18,000 N/A Fertilizer solutions 18,000 N/A Fuel Oil 6 (Bunker C) 6,000 56-81-5 Glycerin 18,000 8001-26-1 Linseed oil 18,000 N/A Lube oil 18,000 N/A Lube oil additives 18,000 N/A Molasses 18,000 8002-64-0 Neatsfoot oil 18,000 N/A Petroleum Distillates (Marine Diesel Oil, Lube Oil) 6,000 7664-38-2 Phosphoric acid 18,000 N/A Refinery Distillates (Light Cycle Oil, Gas oil) 6,000 N/A Salt water 18,000 497-19-8 Soda ash 18,000 7558-80-7 Sodium phosphate 18,000 6834-92-0 Sodium silicate 18,000 7757-82-6 Sodium sulfate 18,000 7664-93-9 Sulfuric acid 18,000 24800-44-0 Tripropylene glycol 18,000 57-13-6 Urea 18,000


ATTACHMENT II

Permit Number 9442

Compounds Routed to Flare

CAS No. Compound Truck Loading Max Filling

Rate (gal/hr)


Required

Minimum Degassing

Level (ppmv)

64-19-7 Acetic acid 18,000 Yes 50 108-24-7 Acetic anhydride 11,000 No 50 67-64-1 Acetone 12,000 Yes 50 75-86-5 Acetone cyanohydrin 18,000 No 50 75-05-8 Acetonitrile 18,000 Yes 50 98-86-2 Acetophenone 18,000 No 50 79-10-7 Acrylic acid 18,000 No 50 107-13-1 Acrylonitrile 18,000 Yes 50 111-69-3 Adiponitrile 18,000 No 50 N/A Alkylates 18,000 Yes 50 67774-74-7 Alkylbenzene 18,000 No 50 626-63-7 Amyl acetate, n- 18,000 Yes 50 71-41-0 Amyl alcohol 16,500 No 50 62-53-3 Aniline 18,000 No 50 8052-42-4 Asphalt 18,000 No 50 N/A Aviation gasoline 6,000 Yes 50 71-43-2 Benzene 6,000 Yes 50 71-36-3 Butanol 12,000 No 50 123-86-4 Butyl acetate, n- 4,500 No 50 141-32-2 Butyl acrylate 9,000 No 50 75-65-0 Butyl alcohol, t- 18,000 Yes 50 75-64-9 Butyl amine, t- 5,100 Yes 50 142-96-1 Butyl ether 7,500 No 50 590-01-2 Butyl proprionate 18,000 No 50 105-60-2 Caprolactum 18,000 No 50 110-80-5 Cellosolve 12,500 No 50 111-15-9 Cellosolve acetates 18,000 No 50 8001-29-4 Cottonseed oil 17,500 No 50 1319-77-3 Cresylate 18,000 Yes 50 1319-77-3 Cresylic acid 18,000 No 50 8002-05-9 Crude Oil 6,000 Yes 50 98-82-8 Cumene 4,500 No 50 110-82-7 Cyclohexane 18,000 Yes 50 108-93-0 Cyclohexanol 14,500 No 50 108-94-1 Cyclohexanone 18,000 Yes 50 112-30-1 Decanol 18,000 No 50 872-05-9 Decene 18,000 No 50

ATTACHMENT II Permit Number 9442 Page 2


Rate (gal/hr)


Required

Minimum Degassing

Level (ppmv)

68515-43-5 Dialkyl Phthalates 15,000 Yes 50 84-74-2 Dibutyl phthalate 18,000 No 50 77-73-6 Dicyclopentadiene 12,000 No 50 N/A Diesel 18,000 No 50 111-42-2 Diethanolamine 18,000 No 50 108-83-8 Diisobutyl ketone 18,000 No 50 12002-23-2 Diisobutylene 18,000 Yes 50 117-84-0 Dioctyl phthalate 18,000 No 50 6842-15-5 Dodecene 18,000 No 50 112-53-8 Dodecyl alcohol 18,000 No 50 N/A Dripolene 18,000 Yes 50 N/A Edible oils 18,000 No 50 64-17-5 Ethanol 18,000 Yes 50 141-43-5 Ethanolamine 18,000 No 50 141-78-6 Ethyl acetate 18,000 Yes 50 140-88-5 Ethyl acrylate 12,000 Yes 50 75-04-7 Ethyl amine 8,000 Yes 50 100-41-4 Ethyl benzene 6,000 No 50 103-11-7 Ethyl hexyl acrylate 18,000 No 50 104-76-7 Ethyl hexyl alcohol 18,000 No 50 107-15-3 Ethylene diamine 18,000 Yes 50 107-21-1 Ethylene glycol 18,000 No 50 N/A Fatty acid 18,000 No 50 N/A Fatty alcohol 13,000 No 50 8002-50-4 Fish oil 17,500 No 50 50-00-0 Formalin (37-50%

formaldehyde) 18,000 No 50

98-01-1 Furfural 18,000 No 50 8006-61-9 Gasoline 6,000 Yes 50 N/A Gasoline additives 10,000 Yes 50 N/A Heavy aromatics 6,000 No 50 142-82-5 Heptane 18,000 Yes 50 124-09-4 Hexamethylenediamine soln. 8,000 No 25 110-54-3 Hexane 12,000 Yes 50 111-27-3 Hexanol 18,000 Yes 50 592-41-6 Hexene 10,500 Yes 50 N/A Hydraulic oil 18,000 No 50 N/A Isoamyl ketone 18,000 Yes 50 78-83-1 Isobutanol 18,000 Yes 50 78-79-5 Isoprene 5,950 Yes 50 67-63-0 Isopropyl alcohol 18,000 Yes 50



Rate (gal/hr)


Required

Minimum Degassing

Level (ppmv)

N/A Jet Fuel A 6,000 No 50

N/A Jet Naphtha (JP-4) 6,000

Yes 50

8008-20-6 Kerosene 18,000 No 50 67891-80-9 Light Aromatic Distillate 13,000 No 50 64742-94-5 Light aromatic naphtha 18,000 No 50 141-79-7 Mesityl oxide 6,000 No 50 79-41-4 Methacrylic acid 18,000 No 50 67-56-1 Methanol 18,000 Yes 50 96-33-3 Methyl acrylate 18,000 Yes 50 108-11-2 Methyl amyl alcohol 9,000 No 50 78-93-3 Methyl ethyl ketone 18,000 Yes 50 108-10-1 Methyl Isobutyl Ketone 18,000 Yes 50 563-80-4 Methyl isopropyl ketone 14,500 Yes 50 80-62-6 Methyl methacrylate 18,000 Yes 50 98-83-9 Methyl styrene, a- 6,000 No 50 1634-04-4 Methyl tert butyl ether (MTBE) 7,500 Yes 50 8012-95-1 Mineral oil 18,000 No 50 8030-30-6 Naphtha (<2% Benzene) 6,000 Yes 50 91-20-3 Naphthalene (<5% Benzene) 6,000 Yes 50 91-20-3 Naphthalene concentrate 18,000 Yes 50 1338-24-5 Naphthenic Acid 12,000 No 50 N/A Natural gasoline 6,000 Yes 50 N/A Neodol 18,000 No 50 98-95-3 Nitrobenzene 18,000 No 50 79-24-3 Nitroethane 18,000 Yes 50 625-48-9 Nitroethanol 18,000 No 50 79-46-9 Nitropropane 18,000 Yes 50 124-11-8 Nonene 9,500 No 50 25154-52-3 Nonyl phenol 15,500 No 50 111-65-9 Octane 5,500 No 50 111-87-5 Octanol 18,000 No 50 111-66-0 Octene, 1- 18,000 Yes 50 N/A Olefins, a- (<C12) 18,000 Yes 50 8002-74-2 Paraffin (distillates) 18,000 No 50 8002-03-7 Peanut oil 7,500 No 50 504-60-9 Pentadiene, 1,3- (piperylene) 7,000 Yes 50 624-54-4 Pentyl propionate 9,000 Yes 50 N/A Petroleum jelly 18,000 No 50 N/A Petroleum wax 18,000 No 50 108-95-2 Phenol 18,000 No 50


CAS No. Compound Truck Loading

Max Filling Rate

(gal/hr)


Required

Minimum Degassing

Level (ppmv)

25322-69-4 Polyglycol 18,000 No 50 9003-27-4 Polyisobutylene 6,000 No 50 25322-69-4 Polyol 18,000 No 50 71-23-8 Propanol 18,000 Yes 50 79-09-4 Propionic acid 18,000 No 50 109-60-4 Propyl acetate 18,000 Yes 50 57-55-6 Propylene Glycol 18,000 No 50 68514-29-4 Raffinate (<5% Benzene) 6,000 Yes 50 N/A Refinery petroleum products

(< 10% benzene) 6,000 No 50

N/A Reformate (< 5% benzene) 6,000 Yes 50 64742-48-9 Reformer feed 9,000 Yes 50 9003-35-4 Resin oil 14,000 No 50 100-42-5 Styrene 6,000 Yes 50 126-33-0 Sulfolane 18,000 No 50 8002-26-4 Tall oil 10,000 No 50 61789-97-7 Tallow 17,500 No 50 112-60-7 Tetraethylene glycol 18,000 No 50 109-99-9 Tetrahydrofuran 14,000 Yes 50 25265-77-4 Texanol 18,000 No 50 108-88-3 Toluene 18,000 Yes 50 112-70-9 Tridecanol 18,000 No 50 102-71-6 Triethanolamine 18,000 No 50 112-27-6 Triethylene glycol 18,000 No 50 8006-64-2 Turpentine 18,000 Yes 50 8001-22-7 Vegetable oil 17,500 No 50 108-05-4 Vinyl acetate 15,000 Yes 50 N/A Wastewater (Untreated) 18,000 No 50 1330-20-7 xylene, mixed or all isomers,

except p- 7,500 No 50

106-42-3 xylene, p- 7,000 No 50


ATTACHMENT III

Permit Number 9442

Compounds Routed to Carbon Adsorber

CAS No.

Compound

Truck Loading Max Filling

Rate (gal/hr)


Required

Minimum Degassing

Level (ppmv)

107-05-1 Allyl chloride 18,000 Yes 50 56-23-5 Carbon tetrachloride 18,000 Yes 50 N/A Chlorinated solvent 18,000 Yes 50 108-90-7 Chlorobenzene 18,000 No 50 67-66-3 Chloroform 18,000 Yes 50 95-50-1 Dichlorobenzene, o- 18,000 No 50 107-06-2 Dichloroethane, 1,2- 18,000 Yes 50 540-59-0 Dichloroethylene, 1,2- 18,000 Yes 50 106-89-8 Epichlorohydrin 18,000 Yes 50 N/A Hydrochloric Acid 18,000 Yes 50 75-09-2 Methylene chloride 18,000 Yes 50 78-87-5 Propylene dichloride 18,000 Yes 50 127-18-4 Tetrachloroethylene 18,000 Yes 50 71-55-6 Trichloroethane, 1,1,1- 18,000 Yes 50 79-01-6 Trichloroethylene 18,000 Yes 50 96-18-4 Trichloropropane, 1,2,3- 18,000 No 50


December 3, 2019 CORRESPONDANCE VIA EMAIL

Mr. Joseph Griesel

Air Permits Division, MC‐163

Texas Commission on Environmental Quality (TCEQ)

12100 Park 35 Circle

Austin, Texas 78753

Re: Permit Amendment

Permit Number: 9442

Southwest Shipyard, Channelview, Harris County

Regulated Entity Number: RN100248749

Customer Reference Number: CN600135354

Dear Mr. Griesel,

The following is Southwest Shipyard’s (SWSY) response to your letter dated November 22, 2019

requesting additional information on the subject Permit No. 9442 amendment application for the barge

cleaning facility located in Channelview, Harris County, Texas. To facilitate the review of SWSY’s

responses, the questions in your letter have been included in italics.

1. Special Condition 7 states that “Vapors requiring control associated with the operations from

Dock Nos. 1 shall be route to Dock No. FL‐1 only”. As stated in Section 1.2 of the amendment

application, the purpose of the amendment is to “Delete the flares (EPNs: FL‐1 and FL‐3)…and

replace with the new VCUs (EPNs: VCU‐2 and VCU‐3)”. Please indicate to which VCU the vapors

associated with the operations of Dock No. 1 will be routed.

o Additionally, please clarify if “Dock No. FL‐1” refers to the flare FL‐1 or a separate EPN.

SWSY Response: This special condition is no longer applicable and should be deleted from the

permit. The vapors associated with the operations at Dock No. 1 may be routed to either of the

new Vapor Combustor Units (VCUs) (EPNs: VCU‐2 and VCU‐3) for the control of the barge and

marine vessel degassing operations. Historically, the reference to “Dock No. FL‐1” refers to the flare

FL‐1 (EPN: FL‐1).

2. Special Condition 16.B. states that Tanks A117 and A119 are equipped with a “smokeless flare

system”. Please clarify if this system is the same as EPN FL‐1 and FL‐3, and if FL‐1 and FL‐3

constitutes the entirety of the flare system that is mentioned

o Additionally, please clarify where the vapors associated with Tanks A117 and A119 are

being routed.

SWSY Response: Special Condition 17.B is applicable to pressurized storage tanks A117 and A119

that when in service, maintained a pressure that was sufficient at all times to prevent vapor or gas

loss to the atmosphere. The condition only requires venting to a control device if sufficient

Mr. Joseph Griesel

Air Permits Division, MC‐163

December 3, 2019 Page 2

pressurization was not maintained and venting with a relief valve was utilized. This condition is

unrelated to the Flares that are the subject of this amendment (EPNs: FL‐1 and FL‐3). Additionally,

these tanks have had a change of service such that this condition is no longer applicable.

Tank A117 has had a change of service authorized by 30 TAC 106.472 and is no longer a pressurized

tank and does not require vapor control. Tank A119 is out of service (OOS) and has been removed

the site. These items will be addressed in the next NSR permit renewal.

3. Once my review is finished and the permit is issued, an electronic copy will be sent to the

Company Official Contact and Technical Contact via email. Hard copies will not be sent, unless

requested. Please indicate whether an electronic version only will be sufficient, or whether a hard

copy will be requested also.

SWSY Response: An electronic version only will be sufficient. Hard copies are not requested.

Please contact me if you have further questions.

Sincerely,


Elizabeth Stanko

Senior Project Manager

cc: Mr. Bernard Diaz, Managing Director of Environmental Operations, Southwest Shipyard, L.P.

1

Stanko, Elizabeth

From: Stanko, ElizabethSent: Wednesday, December 18, 2019 1:00 PMTo: Joseph GrieselCc: Bernard Diaz; Rebecca ParteeSubject: RE: Southwest Shipyard, NSR Permit 9442 (Project 308754) Guidance Document Concerning PM

Emissions Attachments: Table B-1 Combustion Emissions Updated with PM Emissions.pdf; Table C-3 NAAQS Modeling

Results Updated with PM Emissions.pdf

Mr. Griesel,

Attached you will find an updated emission calculation Table B‐1 with the PM/PM10/PM2.5 emissions quantified for the vapor combustors. Additionally, we have attached the updated modeling impacts Table C‐3. The model predicted impacts from PM10 and PM2.5 emissions were assessed qualitatively using the impacts analysis that was previously submitted to TCEQ in support of the PCP SP Project No. 154687 to demonstrate compliance with the PM10 and PM2.5 NAAQS.

We understand the next step will be Public Notice to add the PM/PM10/PM2.5 emissions to NSR Permit 9442. Please let me know what the anticipated timeline in for the NORI/NAPD after you coordinate with Ms. Partee. I spoke with Rebecca earlier today and mentioned Southwest Shipyard would like to move two degassing sources on NSR 43774 (EPNs ST1 and FUGST1) to NSR Permit 9442 via a Permit Revision to NSR 43774 and this subject permitting action. These degassing sources are “out‐of‐place” on NSR 43774, which is a Coating and Blasting Permit and should be managed with the other degassing sources on NSR 9442. Southwest Shipyard would only proceed with this addition if it could fit into the proposed time line, i.e., during the NORI, and we don’t want to delay issuance of the amended NSR 9442.

Please let me know if you have any questions or require additional information to complete your review.

Thank you, Elizabeth

Elizabeth Stanko, CCM Senior Project Manager

10550 Richmond Avenue, Suite 210, Houston, TX 77042 T 713.244.1039 | F 713.789.5920 | C 713.829.3852 | LinkedIn | Twitter | Blog | TRCcompanies.com

My new email address is [email protected].

I. Basis

II. Calculation Inputs and FactorsVapor Combustor Unit (VCU) Maximum Capacity 67.5 MMBtu/hr Maximum Heat Input per VCU stackMaximum Hourly Heat Input (VCU-2 and VCU-3) 135 MMBtu/hr Combined Combustion Capacity of both VCUs

Annual Combined Heat Input (VCU-2 and VCU-3) 85,356 MMBtu/yr

VCU Destruction Efficiency 99.95% DREMaximum Assist Gas (Natural Gas) 300 scfm

Natural Gas Fuel Heat Content 1020 Btu/scf

NOx Emission Factor 0.076 lb/MMBtuCO Emission Factor 0.3 lb/MMBtu

SO2 Emission Factor 1.2 lb/MMscf

PM/PM10/PM2.5 Emission Factor 0.0075 lb/MMBtu

Minimum VOC Destruction Efficiency

TABLE B-1: Products of Combustion Emissions from New Control Equipment

Vendor guaranteed CO emission factor per VCU stack

SO2 emission factor assumes sulfur content of natural gas is 4,000 grains/106 scf (0.40 gr/100 scf). The SO2 emission factor from AP-42 was converted to 4,000

grains/106 scf by multiplying the SO2 emission factor by the ratio of the site-specific

sulfur content (4,000 grains/106 scf) to 2,000 grains/106 scf.

PM/PM10/PM2.5 emission factor per EPA AP-42 Emission Factors, Chapter 1.4 - Natural Gas Combustion, Table 1.4-2. The PM emission factor from AP-42 was

converted to lb/MMBtu by dividing the Total PM emission factor (7.6 lb/106 scf) by the average gross heating value of natural gas, which is 1,020 Britishthermal units per standard cubic foot (Btu/scf).


EMISSION CALCULATIONSDecember 2019

Vendor guaranteed NOX emission factor per VCU stack

Based on the maximum annual heat of combustion from the last five years' emissions inventory queries.

Assist Gas is Natural Gas; ranges from 0-300 scfmNatural gas fuel heat content per EPA AP-42.

The hourly Vapor Combustor Unit (VCU) NOX and CO combustion emissions are based on the vendor-specified VCU maximum heat capacity, and vendor guaranteed NOX and CO emission factors. The annual NOX and CO combustion emissions are based on the maximum annual heat of combustion from the last five years' emissions inventory (EI) queries, and vendor guaranteed NOX and CO emission factors.

The hourly SO2 combustion emissions are based on the maximum assist natural gas flow rate, and the SO2 emission factor from EPA AP-42 Emission Factors, Chapter 1.4 - Natural Gas Combustion, Table 1.4-2. The emission factor is based on 100-percent conversion of fuel sulfur to SO2 and assumes sulfur content of

natural gas is 4,000 grains/106 scf. The annual SO2 combustion emissions are based on the hourly SO2 emission rate and annual operating hours of 8,760.

The hourly PM/PM10/PM2.5 emissions are based on the vendor-specified VCU maximum heat capacity, and the PM/PM10/PM2.5 emission factor from EPA AP-42 Emission Factors, Chapter 1.4 - Natural Gas Combustion, Table 1.4-2. The annual PM/PM10/PM2.5 emissions are based on the maximum annual heat of combustion and the PM/PM10/PM2.5 emission factor from EPA AP-42 Emission Factors, Chapter 1.4 - Natural Gas Combustion, Table 1.4-2.




EMISSION CALCULATIONSDecember 2019

10.26 lb/hr3.24 TPY

40.50 lb/hr12.80 TPY0.02 lb/hr0.09 TPY1.01 lb/hr0.32 TPY

III. Sample CalculationsHourly NOx emissions = (Hourly Maximum Heat Input, MMBTU/hr) (NOx emission Factor, lb/MMBTU)

Hourly NOx emissions = 135 (MMBTU/hr) X 0.076 (lb/MMBTU)Hourly NOx emissions = 10.26 (lb/hr)

Annual NOx emissions = (Annual Average Heat Input, MMBTU/year) (NOx emission Factor, lb/MMBTU) (1 ton/2000 lbs)

Annual NOx emissions = 85356 (MMBTU/year) X 0.076 (lb/MMBTU) X (1 ton/2000 lbs)Annual NOx emissions = 3.24 (tons/year)

Hourly SO2 emissions = (Hourly Maximum Assist Gas, scfm) (SO2 emission Factor, lb/MMscf) (60 min/1hr)(1 MMscf / 106 scf)Hourly SO2 emissions = 300 (scfm) X 1.2 (lb/MMscf) X (60 min/1hr) X (1 MMscf / 10^6 scf)Hourly SO2 emissions = 0.02 (lb/hr)

Annual SO2 emissions = (Hourly SO2 emissions, lb/hr) (Maximum operating hours, hrs/year) (1 ton/2000 lbs)

Annual SO2 emissions = 0.0216 (lb/hr) X 8,760 (hrs/year) X (1 ton/2000 lbs)Annual SO2 emissions = 0.09 (tons/year)

Hourly PM/PM10/PM2.5 emissions = (Hourly Maximum Heat Input, MMBTU/hr) (PM emission Factor, lb/MMBTU)

Hourly PM/PM10/PM2.5 emissions = 135 (MMBTU/hr) X 0.0075 (lb/MMBTU)Hourly PM/PM10/PM2.5 emissions = 1.01 (lb/hr)

Annual PM/PM10/PM2.5 emissions =(Annual Average Heat Input, MMBTU/year) (PM emission Factor, lb/MMBTU) (1 ton/2000 lbs)

Annual PM/PM10/PM2.5 emissions = 85356 (MMBTU/year) X 0.0075 (lb/MMBTU) X (1 ton/2000 lbs)Annual PM/PM10/PM2.5 emissions = 0.32 (tons/year)

PM/PM10/PM2.5 Emissions

CO Emissions

SO2 Emissions

NOx Emissions



Hourly Annual Hourly Annual Hourly Annual Hourly Annual

VCU-2 5.13 1.62 20.25 6.40 0.011 0.05 0.50 0.16

VCU-3 5.13 1.62 20.25 6.40 0.011 0.05 0.50 0.16

PM10

1-hr Annual 1-hr 8-hr 24-hr 24-hr Annual 1-hr 3-hr 24-hr Annual

VCU-2 0.379 0.342 0.266 0.152 0.007 1.95 0.01 7.68 5.38 0.076 0.076 0.001 0.004 0.004 0.002 0.0003

VCU-3 0.379 0.342 0.266 0.152 0.007 1.95 0.01 7.68 5.38 0.076 0.076 0.001 0.004 0.004 0.002 0.0003

3.89 0.02 15.37 10.76 0.15 0.15 0.002 0.008 0.007 0.003 0.001

7.5 1 2000 500 5 1.2 0.2 7.8 25 5 1

Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

December 2019

POLLUTION CONTROL PROJECT STANDARD PERMIT (PCP SP)SOUTHWEST SHIPYARD, L.P.

CO


24-hr

NOX CO

A NAAQS analysis was performed to demonstrate compliance with applicable standards and guideline concentrations for offsite impacts of criteria pollutants (NO2, CO, and SO2). The proposed project increases of the criteria air pollutants were evaluated against the NAAQS SILs to determine if impacts were less than the de minimis thresholds. The modeling results of the NAAQS preliminary impact analysis were determined using the SCREEN3 predicted unit impact multipliers (shown in Table C-2) for the applicable averaging periods. Table C-3 summarizes the modeled project emission rates for criteria pollutants, and the NAAQS preliminary impact analysis results for comparison to all of the applicable NAAQS SILs. NOx emissions were conservatively assumed to be 100-percent NO2.

The NAAQS significant impact modeling results indicate that the SCREEN3 predicted GLCMAX associated with the proposed project emissions were less than the SIL for all pollutants and all applicable averaging periods. Therefore, a full-impact refined NAAQS analysis is not required for any pollutants. As such, the project will not cause or contribute to a violation of the applicable NAAQS standards, and the State NAAQS demonstration is complete.

Air Quality Analysis (AQA)

PM2.5

PM10/PM2.5



SIL (ug/m3)

Less Than SIL?

SourceSO2

Source


1-hr 8-hr AnnualNO2


SO2

3-hr


1

Stanko, Elizabeth

From: Stanko, ElizabethSent: Friday, January 10, 2020 4:05 PMTo: Joseph GrieselCc: Bernard DiazSubject: RE: Southwest Shipyard, NSR Permit 9442 (Project 308754) Guidance Document Concerning PM

Emissions Attachments: Form PI-1 NSR 9442 (01-10-20)v2.xlsx

Dear Mr. Griesel,

Attached you will find an updated Form PI‐1 General Application for the subject NSR Permit 9442 Amendment. This form has been updated with the PM/PM10/PM2.5 emissions quantified for the vapor combustors. Additionally, the Public Notice Applicability has been updated. Please contact me if you have any questions, and we look forward to receiving the draft permit next week and the PN Package soon.

Thank you, Elizabeth

Elizabeth Stanko, CCM Senior Project Manager



Texas Commission on Environmental Quality

Form PI-1 General ApplicationGeneral

Date: November 2019Permit #: 9442

Company: Southwest Shipyard LP

I agree

ZIP Code: 77042

First Name: Elizabeth

10550 Richmond Avenue Address Line 2:

713-244-1039

D. Assigned Numbers

Telephone Number:Fax Number:Email Address: [email protected]

The CN and RN below are assigned when a Core Data Form is initially submitted to the Central Registry. The RN is also assigned if the agency has conducted an investigation or if the agency has issued an enforcement action. If these numbers have not yet been assigned, leave these questions blank and include a Core Data Form with your application submittal. See Section VI.B. below for additional information.

713-789-5920

I. Applicant Information

Texas Secretary of State Charter/Registration Number (if given):

C. Technical Contact Information: This person must have the authority to make binding agreements and representations on behalf of the applicant and may be a consultant. Additional technical contact(s) can be provided in a cover letter.

A. Company Information

B. Company Official Contact Information: must not be a consultantPrefix (Mr., Ms., Dr., etc.): Mr. First Name: BernardLast Name: DiazTitle: Managing Director of Environmental Operations

Permits are issued to either the facility owner or operator, commonly referred to as the applicant or permit holder. List the legal name of the company, corporation, partnership, or person who is applying for the permit. We will verify the legal name with the Texas Secretary of State at (512) 463-5555 or at:

Company or Legal Name: Southwest Shipyard, L.P.

Mailing Address: 18310 Market Street

City:

ZIP Code:

Channelview

Last Name:

City: HoustonState: TX

Company or Legal Name: TRC Environmental Corporation

281-860-3214Email Address: [email protected]

Address Line 2:

StankoTitle:

State:

713-378-8757Fax Number:

https://www.sos.state.tx.us

Suite 210

Project Manager

Mailing Address:

Prefix (Mr., Ms., Dr., etc.): Ms.

77530Telephone Number:

TX

I acknowledge that I am submitting an authorized TCEQ application workbook and any necessary attachments. Except for inputting the requested data and adjusting row height and column width, I have not changed the TCEQ application workbook in any way, including but not limited to changing formulas, formatting, content, or protections.

Version 4.0 Page 1





No

Not applicable

9442

Select from the drop-down the type of action being requested for each permit type. If that permit type does not apply, you MUST select "Not applicable".

Provide all assigned permit numbers relevant for the project. Leave blank if the permit number has not yet been assigned.

https://www.tceq.texas.gov/permitting/air/guidance/authorize.html

Amendment

Permit Type

A. Permit and Action Type (multiple may be selected, leave no blanks)

Special Permit: Not applicable, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Alteration, Extension to Start of Construction

III. Permit Information

De Minimis: Not applicable, Initial Not applicable

Not applicable

PSD: Not applicable, Initial, Major Modification

This cell intentionally left blank

Minor NSR (can be a Title V major source): Not applicable, Initial, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Relocation/Alteration, Change of Location, Alteration, Extension to Start of Construction

Additional information regarding the different NSR authorizations can be found at:

CN600135354

RN100248749

Enter the CN. The CN is a unique number given to each business, governmental body, association, individual, or other entity that owns, operates, is responsible for, or is affiliated with a regulated entity.

Nonattainment: Not applicable, Initial, Major Modification

Flexible: Not applicable, Initial, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Alteration, Extension to Start of Construction

Not applicable

Action Type Requested(do not leave blank)

Does the applicant have unpaid delinquent fees and/or penalties owed to the TCEQ?This form will not be processed until all delinquent fees and/or penalties owed to the TCEQ or the Office of the Attorney General on behalf of the TCEQ are paid in accordance with the Delinquent Fee and Penalty Protocol. For more information regarding Delinquent Fees and Penalties, go to the TCEQ Web site at:

https://www.tceq.texas.gov/agency/financial/fees/delin

II. Delinquent Fees and Penalties


Not applicable

Permit Number (if assigned)

Enter the RN. The RN is a unique agency assigned number given to each person, organization, place, or thing that is of environmental interest to us and where regulated activities will occur. The RN replaces existing air account numbers. The RN for portable units is assigned to the unit itself, and that same RN should be used when applying for authorization at a different location.

Version 4.0 Page 2





No

No

HAP Major Source [FCAA § 112(g)]: Not applicable, Initial, Major ModificationPAL: Not applicable, Initial, Amendment, Renewal, Renewal/Amendment, AlterationGHG PSD: Not applicable, Initial, Major Modification, Voluntary Update

D. Incorporation of Standard Permits, Standard Exemptions, and/or Permits By Rule (PBR)

Not applicable

Not applicable

Not applicable

Will NSR permits be consolidated into this permit with this action?

No

30 TAC §106.263

Will this permit be consolidated into another NSR permit with this action?

To ensure protectiveness, previously issued authorizations (standard permits, standard exemptions, or PBRs) including those for MSS, are incorporated into a permit either by consolidation or by reference. At the time of renewal and/or amendment, consolidation (in some cases) may be voluntary and referencing is mandatory. More guidance regarding incorporation can be found in 30 TAC § 116.116(d)(2), 30 TAC § 116.615(3) and in this memo:

https://www.tceq.texas.gov/assets/public/permitting/air/memos/pbr_spc06.pdf

C. Consolidating NSR Permits

How are/will MSS activities for sources associated with this project be authorized?

Permit by Rule

List the permit number, registration number, and/or PBR number.

Are there any standard permits, standard exemptions, or PBRs to be incorporated by reference?

B. MSS Activities

Version 4.0 Page 3





Yes

No

Channelview

18130 Market Street

PCP SP 154687If yes, list any PBR, standard exemptions, or standard permits that need to be consolidated:

E. Associated Federal Operating Permits

Yes

If yes, are emission calculations, BACT analysis, and an impacts analysis included for each authorization to be consolidated? If any required information is not provided, the authorization will be incorporated by reference.

Yes

77530

Street Address:

Site Location Description: If there is no street address, provide written driving directions to the site. Identify the location by distance and direction from well-known landmarks such as major highway intersections.

A. LocationIV. Facility Location and General Information

TCEQ Region Region 12

29:47:23

Use USGS maps, county maps prepared by the Texas Department of Transportation, or an online software application such as Google Earth to find the latitude and longitude.

Harris

County attainment status as of Sept. 23, 2019

Is a SOP or GOP review pending for this source, area, or site?

SOP 1260

Are there any PBR, standard exemptions, or standard permits associated to be incorporated by consolidation? Note: Emission calculations, a BACT analysis, and an impacts analysis must be attached to this application at the time of submittal for any authorization to be incorporated by consolidation.


County: Enter the county where the facility is physically located.

Serious Ozone nonattainment

Is this facility located at a site required to obtain a site operating permit (SOP) or general operating permit (GOP)?

If required to obtain a SOP or GOP, list all associated permit number(s). If no associated permit number has been assigned yet, enter "TBD":

City: If the address is not located in a city, then enter the city or town closest to the facility, even if it is not in the same county as the facility.

ZIP Code: Include the ZIP Code of the physical facility site, not the ZIP Code of the applicant's mailing address.

Latitude (in degrees, minutes, and nearest second (DDD:MM:SS)) for the street address or the destination point of the driving directions. Latitude is the angular distance of a location north of the equator and will always be between 25 and 37 degrees north (N) in Texas.

Version 4.0 Page 4





No

Briscoe Cain

3732Principal SIC code:

District: 6

B. Project Timing

A. DescriptionV. Project Information

128District:State Representative:


https://www.naics.com/sic-codes-industry-drilldown/

Principal Company Product/Business:

Consolidate by incorporation PCP SP No. 154687 into NSR Permit No. 9442.

Provide a brief description of the project that is requested. (Limited to 500 characters).

A list of SIC codes can be found at:

State Senator:

NAICS codes and conversions between NAICS and SIC Codes are available at:

Carol Alvarado

https://www.census.gov/eos/www/naics/

E. State Senator and Representative for this site

https://wrm.capitol.texas.gov/This information can be found at (note, the website is not compatible to Internet Explorer):

No

Southwest Shipyard Channelview

D. Industry TypeShip Building and Repair

Barge Cleaning and Degassing Facilities

95:03:55

C. Portable Facility

336611Principal NAICS code:

Permanent

Area Name: Must indicate the general type of operation, process, equipment or facility. Include numerical designations, if appropriate. Examples are Sulfuric Acid Plant and No. 5 Steam Boiler. Vague names such as Chemical Plant are not acceptable.

Is this a project for a lead smelter, concrete crushing facility, and/or a hazardous waste management facility?

Permanent or portable facility?

B. General InformationSite Name:

Are there any schools located within 3,000 feet of the site boundary?

Longitude (in degrees, minutes, and nearest second (DDD:MM:SS)) for the street address or the destination point of the driving directions. Longitude is the angular distance of a location west of the prime meridian and will always be between 93 and 107 degrees west (W) in Texas.

Version 4.0 Page 5





No

Yes

No

No

Yes

Yes

YesYes

Yes

N/A

N/A

Yes

Is the area map a current map with a true north arrow, an accurate scale, the entire plant property, the location of the property relative to prominent geographical features including, but not limited to, highways, roads, streams, and significant landmarks such as buildings, residences, schools, parks, hospitals, day care centers, and churches?


D. Is a plot plan attached?Does your plot plan clearly show a north arrow, an accurate scale, all property lines, all emission points, buildings, tanks, process vessels, other process equipment, and two bench mark locations?

Does your plot plan identify all emission points on the affected property, including all emission points authorized by other air authorizations, construction permits, PBRs, special permits, and standard permits?

Did you include a table of emission points indicating the authorization type and authorization identifier, such as a permit number, registration number, or rule citation under which each emission point is currently authorized?

E. Is a process flow diagram attached?

C. Enforcement ProjectsProjected Start of Operation:

VI. Application Materials

C. Is a current area map attached?

Does the map show a 3,000-foot radius from the property boundary?

https://www.tceq.texas.gov/assets/public/permitting/centralregistry/10400.docx

A. Confidential Application MaterialsIs confidential information submitted with this application?

Authorization must be obtained for many projects before beginning construction. Construction is broadly interpreted as anything other than site clearance or site preparation. Enter the date as "Month Date, Year" (e.g. July 4, 1776).

Will sources in this project be authorized to operate 8760 hours per year?

Is this application in response to, or related to, an agency investigation, notice of violation, or enforcement action?

November 18, 2019

B. Is the Core Data Form (Form 10400) attached?

All representations regarding construction plans and operation procedures contained in the permit application shall be conditions upon which the permit is issued. (30 TAC § 116.116)

D. Operating Schedule

Projected Start of Construction: October 18, 2019

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Yes

Yes

Yes

Yes

Yes

N/A

N/A

N/A

Yes

Yes

YesYes

VII. Signature

Are emission rates and associated calculations for planned MSS facilities and related activities attached?

J. Is a discussion of state regulatory requirements attached, addressing 30 TAC Chapters 101, 111, 112, 113, 115, and 117?For all applicable chapters, does the discussion include how the facility will comply with the requirements of the chapter?For all not applicable chapters, does the discussion include why the chapter is not applicable?K. Are all other required tables, calculations, and descriptions attached?

I. Is a list of MSS activities attached?


Is the process flow diagram sufficiently descriptive so the permit reviewer can determine the raw materials to be used in the process; all major processing steps and major equipment items; individual emission points associated with each process step; the location and identification of all emission abatement devices; and the location and identification of all waste streams (including wastewater streams that may have associated air emissions)?

F. Is a process description attached?Does the process description emphasize where the emissions are generated, why the emissions must be generated, what air pollution controls are used (including process design features that minimize emissions), and where the emissions enter the atmosphere?

The owner or operator of the facility must apply for authority to construct. The appropriate company official (owner, plant manager, president, vice president, or environmental director) must sign all copies of the application. The applicant’s consultant cannot sign the application. Important Note: Signatures must be original in ink, not reproduced by photocopy, fax, or other means, and must be received before any permit is issued.

G. Are detailed calculations attached? Calculations must be provided for each source with new or changing emission rates. For example, a new source, changing emission factors, decreasing emissions, consolidated sources, etc. You do not need to submit calculations for sources which are not changing emission rates with this project. Please note: the preferred format is an electronic workbook (such as Excel) with all formulas viewable for review. It can be emailed with the submittal of this application workbook.

Does the process description also explain how the facility or facilities will be operating when the maximum possible emissions are produced?

H. Is a material balance (Table 2, Form 10155) attached?

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Name:

Signature:

Date:

The signature below confirms that I have knowledge of the facts included in this application and that these facts are true and correct to the best of my knowledge and belief. I further state that to the best of my knowledge and belief, the project for which application is made will not in any way violate any provision of the Texas Water Code (TWC), Chapter 7; the Texas Health and Safety Code, Chapter 382; the Texas Clean Air Act (TCAA); the air quality rules of the Texas Commission on Environmental Quality; or any local governmental ordinance or resolution enacted pursuant to the TCAA. I further state that I understand my signature indicates that this application meets all applicable nonattainment, prevention of significant deterioration, or major source of hazardous air pollutant permitting requirements. The signature further signifies awareness that intentionally or knowingly making or causing to be made false material statements or representations in the application is a criminal offense subject to criminal penalties.

Mr. Bernard Diaz

Original signature is required.

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Form PI-1 General ApplicationTechnical



Yes

No

NoIs this a project for a concrete batch plant?

I. Additional Questions for Specific NSR Minor Permit Actions

E. Concrete Batch Plants

Do NESHAP subpart(s) apply to a facility in this application?

No

C. Title 40 CFR Part 63

No

VIII. Federal Regulatory QuestionsIndicate if any of the following requirements apply to the proposed facility. Note that some federal regulations apply to minor sources. Enter all applicable Subparts.

Do MACT subpart(s) apply to a facility in this application?

No

A. Title 40 CFR Part 60Do NSPS subpart(s) apply to a facility in this application?

B. Title 40 CFR Part 61

Does this project require an impacts analysis?


IX. Emissions ReviewA. Impacts AnalysisAny change that results in an increase in off-property concentrations of air contaminants requires an air quality impacts demonstration. Information regarding the air quality impacts demonstration must be provided with the application and show compliance with all state and federal requirements. Detailed requirements for the information necessary to make the demonstration are listed on the Impacts sheet of this workbook.


B. Disaster ReviewIf the proposed facility will handle sufficient quantities of certain chemicals which, if released accidentally, would cause off-property impacts that could be immediately dangerous to life and health, a disaster review analysis may be required as part of the application. Contact the appropriate NSR permitting section for assistance at (512) 239-1250. Additional Guidance can be found at:

https://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/disrev-factsheet.pdfDoes this application involve any air contaminants for which a disaster review is required?

C. Air Pollutant Watch List

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Form PI-1 General ApplicationTechnical



No

Yes

Yes

Yes

https://www.tceq.texas.gov/toxicology/apwl/apwl.htmlIs the proposed facility located in a watch list area?

D. Mass Emissions Cap and Trade

If MECT is applicable, does the application contain documentation demonstrating that the proposed facility, group of facilities, or account has obtained allowances to operate?

Is this facility located at a site within the Houston/Galveston nonattainment area (Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties)?Is Mass Emissions Cap and Trade applicable to the new or modified facilities?

Certain areas of the state have concentrations of specific pollutants that are of concern. The TCEQ has designated these portions of the state as watch list areas. Location of a facility in a watch list area could result in additional restrictions on emissions of the affected air pollutant(s) or additional permit requirements. The location of the areas and pollutants of interest can be found at:

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Texas Commission on Environmental QualityForm PI-1 General ApplicationUnit Types - Emission Rates



Action Requested (only 1 action per FIN)

Include these emissions in annual (tpy) summary?

Facility ID Number (FIN)

Emission Point Number (EPN) Source Name Pollutant

Current Short-Term (lb/hr)

Current Long-Term (tpy)

ConsolidatedCurrent Short-Term (lb/hr)

Consolidated Current Long-Term (tpy)

Proposed Short-Term (lb/hr)

Proposed Long-Term (tpy)

Short-Term Difference (lb/hr)

Long-Term Difference (tpy)

Unit Type (Used for reviewing BACT and Monitoring Requirements)

Unit Type Notes (only if "other" unit type in Column O)

Not New/Modified Yes MAR-DOCKS MAR-DOCKSMarine Emissions at Docks 1, 2, 3, 4, and

VOC 32.7 2.5 32.7 2.5 0 0 OtherBarge/Vessel Marine Emissions (post-control)

Not New/Modified Yes CA-1 CA-1Carbon Adsorption Unit

VOC 65.56 1.4 65.56 1.4 0 0 Control: Adsorption System: Disposable

IOC-U 0.25 0.01 0.25 0.01 0 0Not New/Modified Yes DRL-1 DRL-1 Drum Loading VOC 3.2 0.62 3.2 0.62 0 0 Loading: Drum or ToteNot New/Modified Yes FE-1 FE-1 Equipment Fugitives VOC 0.023 0.079 0.023 0.079 0 0 Fugitives: Piping and Equipment Leak

Not New/Modified Yes FUG-LOAD FUG-LOADTransfer Equipment Fugitives

VOC 0.1 0.46 0.1 0.46 0 0 Fugitives: Piping and Equipment Leak

Remove No Multiple FL-1 Flare 1 VOC 89.26 27.73 -89.26 -27.73 Control: FlareNOx 10.33 2.46 -10.33 -2.46CO 20.63 12.2 -20.63 -12.2

Remove No Multiple FL-3 Flare 3 VOC 89.26 27.73 -89.26 -27.73 Control: FlareNOx 10.33 2.46 -10.33 -2.46CO 20.63 12.2 -20.63 -12.2

Remove Yes Multiple Flare Cap Flare Cap VOC 89.26 27.73 -89.26 -27.73 Control: FlareNOx 10.33 2.46 -10.33 -2.46CO 20.63 12.2 -20.63 -12.2

Not New/Modified No NDST-1 NDST-1Vacuum Pump Exhaust

VOC 4.99 0.35 4.99 0.35 0 0 Process Vent

Not New/Modified No NDST-2 NDST-2Vacuum Pump Exhaust

VOC 4.99 0.35 4.99 0.35 0 0 Process Vent

Not New/Modified Yes Vac Cap Vac CapVacuum Pump Exhaust Cap

VOC 4.99 0.35 4.99 0.35 0 0 Process Vent

Not New/Modified Yes Multiple TANKS-1Caustic Tanks A201, A202

VOC 0.01 0.01 0.01 0.01 0 0Storage Tank (1): Fixed roof with capacity < 25,000 gal or TVP < 0.50 psia

Not New/Modified Yes Multiple TANKS-2Storage Tanks A400-A409


Not New/Modified Yes Multiple TANKS-3A113-116 A301 A410-413 A501-502 A505-510 A512-513


Not New/Modified Yes Multiple TANKS-4Wastewater Tanks A302-A304

VOC 0.54 1.36 0.54 1.36 0 0 Wastewater Facilities

IOC-U 0.03 0.01 0.03 0.01 0 0Not New/Modified Yes TL-1 TL-1 Truck Loading VOC 3.6 7.58 3.6 7.58 0 0 Loading: Truck

Not New/Modified Yes WWP WWPWastewater Treatment Plant

VOC 1.01 1.3 1.01 1.3 0 0 Wastewater Facilities

Consolidate No Multiple VCU-2 Vapor Combustor Unit VOC 2.11 2.67 2.11 2.67 0 0 Control: Vapor CombustorNOx 5.13 1.62 5.13 1.62 0 0CO 20.25 6.4 20.25 6.4 0 0SO2 0.01 0.045 0.01 0.045 0 0

Consolidate No Multiple VCU-3 Vapor Combustor Unit VOC 2.11 2.67 2.11 2.67 0 0 Control: Vapor CombustorNOx 5.13 1.62 5.13 1.62 0 0CO 20.25 6.4 20.25 6.4 0 0SO2 0.01 0.045 0.01 0.045 0 0

Consolidate Yes Multiple VCU CapVapor Combustor Units Cap

VOC 4.22 5.34 4.22 5.34 0 0 Control: Vapor Combustor

NOx 10.26 3.24 10.26 3.24 0 0CO 40.5 12.8 40.5 12.8 0 0SO2 0.02 0.09 0.02 0.09 0 0PM 1.01 0.32 1.01 0.32PM10 1.01 0.32 1.01 0.32PM2.5 1.01 0.32 1.01 0.32

New/Modified No Multiple VCU-2 Vapor Combustor Unit PM 0.5 0.16 0.5 0.16PM10 0.5 0.16 0.5 0.16PM2.5 0.5 0.16 0.5 0.16

New/Modified No Multiple VCU-3 Vapor Combustor Unit PM 0.5 0.16 0.5 0.16PM10 0.5 0.16 0.5 0.16PM2.5 0.5 0.16 0.5 0.16

0 0

this cell is intentionally left blank


Chemical / EnergyPermit primary industry (must be selected for workbook to function)

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Form PI-1 General ApplicationStack Parameters



EPNIncluded in EMEW?

UTM Coordinates

ZoneEast (Meters)

North (Meters)

BuildingHeight (ft)

Height Above Ground (ft)

Stack Exit Diameter (ft)

Velocity (FPS)

Temperature (°F)

Fugitives - Length (ft)

Fugitives - Width (ft)

Fugitives - Axis Degrees

MAR-DOCKS No 15 300291 3297192 N/A 14 1.42 77.3 70 N/A N/A N/ACA-1 No 15 300201 3297254 N/A 8 2 5 40 N/A N/A N/ADRL-1 No 15 300220 3297248 N/A 4 N/A N/A N/A 300 150 312FE-1 No 15 300327 3297260 N/A 3 N/A N/A N/A 12 3 N/AFUG-LOAD No 15 300225 3297257 N/A 4 N/A N/A N/A 50 80 312FL-1 No 15 300252 3297308 N/A 35 2.06 65.6 1831.7 N/A N/A N/AFL-3 No 15 300249 3297310 N/A 35 2.06 65.6 1831.7 N/A N/A N/AFlare Cap No 15 N/A N/A N/A 35 2.06 65.6 1831.7 N/A N/A N/ANDST-1 No 15 300238 3297252 N/A 22 0.5 16.7 80 N/A N/A N/ANDST-2 No 15 300235 3297254 N/A 22 0.5 16.7 80 N/A N/A N/AVac Cap No 15 N/A N/A N/A 22 0.5 16.7 80 N/A N/A N/ATANKS-1 No 15 300310 3297287 N/A 20 N/A N/A N/A 50 80 312TANKS-2 No 15 300195 3297259 N/A 16.83 N/A N/A N/A 40 70 312TANKS-3 No 15 300215 3297258 N/A 17.94 N/A N/A N/A 155 75 312TANKS-4 No 15 300247 3297245 N/A 14.17 N/A N/A N/A 55 50 312TL-1 No 15 300260 3297221 N/A 10 N/A N/A N/A 450 300 312WWP No 15 300225 3297299 N/A 5 N/A N/A N/A 300 140 305VCU-2 No 15 300241 3297306 N/A 40 8 0.25 1400 N/A N/A N/AVCU-3 No 15 300247 3297305 N/A 40 8 0.25 1400 N/A N/A N/AVCU Cap No 15 N/A N/A N/A 40 8 0.25 1400 N/A N/A N/A

Emission Point Discharge Parameters

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Form PI-1 General ApplicationPublic Notice



Yes

Yes

Yes

I. Public Notice Applicability

For public notice applicability, the agency does not include consolidation or incorporation of any previously authorized facility or activity (PBR, standard permits, etc.), changes to permitted allowable emission rates when exclusively due to changes to standardized emission factors, or reductions in emissions which are not enforceable through the amended permit. Thus, the total emissions increase would be the sum of emissions increases under the amended permit and the emissions decreases under the amended permit for each air contaminant.

The table below will generate emission increases based on the values represented on the "Unit Types - Emission Rates" sheet. Use the "yes" and "no" options in column B of the "Unit Types - Emission Rates" worksheet to indicate if a unit's proposed change of emissions should be included in these totals.

Notes:1. Emissions of PM, PM10, and/or PM2.5 may have been previously quantified and authorized as PM, PM10,and/or PM2.5. These emissions will be speciated based on current guidance and policy to demonstrate compliance with current standards and public notice requirements may change during the permit review.

2. All renewals require public notice.

A. Application Type

B. Project Increases and Public Notice Thresholds (for Initial and Amendment Projects)

NoDo the facilities handle, load, unload, dry, manufacture, or process grain, seed, legumes, or vegetable fibers (agricultural facilities)?

Is this an application for a minor permit amendment?Is there any change in character of emissions in this application (a new criteria pollutant or a new VOC or PM species)?Is there a new air contaminant in this application?

This row is optional. If you do not think the table below accurately represents public notice applicability increases for your project, provide discussion here (1000 characters).

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PollutantCurrent Long-Term (tpy)

Consolidated Emissions (tpy)

Proposed Long-Term (tpy)

Project Change in Allowable (tpy)

PN ThresholdNotice required?

VOC 74.17 5.34 51.78 -27.73 5 No

PM 0.00 0.00 0.32 0.32 5 No

PM10 0.00 0.00 0.32 0.32 5 No

PM2.5 0.00 0.00 0.32 0.32 5 No

NOx 2.46 3.24 3.24 -2.46 5 No

CO 12.20 12.80 12.80 -12.20 50 No

SO2 0.00 0.09 0.09 0.00 10 No

Pb 0.00 0.00 0.00 0.00 0.6 No

IOC-U 0.02 0 0.02 0 5 No


C. Is public notice required for this project as represented in this workbook?If no, proceed to Section III Small Business Classification.Note: public notice applicability for this project may change throughout the technical review.

Yes

First Name:

D. Are any HAPs to be authorized/re-authorized with this project? The category "HAPs" must be specifically listed in the public notice if the project authorizes (reauthorizes for renewals) any HAP pollutants.

Complete this section if public notice is required (determined in the above section) or if you are not sure if public notice is required.

Mr. BernardDiazManaging Director of Environmental Operations

Yes

II. Public Notice Information

A. Contact InformationEnter the contact information for the person responsible for publishing. This is a designated representative who is responsible for ensuring public notice is properly published in the appropriate newspaper and signs are posted at the facility site. This person will be contacted directly when the TCEQ is ready to authorize public notice for the application.Prefix (Mr., Ms., Dr., etc.):

Last Name:Title:Company Name:Mailing Address: 18310 Market Street

Southwest Shipyard, L.P.

* Notice is required for PM, PM10, and PM2.5 if one of these pollutants is above the threshold.

** Notice of a GHG action is determined by action type. Initial and major modification always require notice. Voluntary updates require a consolidated notice if there is a change to BACT. Project emission increases of CO2e (CO2 equivalent) are not relevant for determining public notice of GHG permit actions.

Version 4.0 Page 2





Mailing Address:Address Line 2:

ZIP Code:County:

5425 Polk Street, Suite H

Company Name:

ZIP Code:Telephone Number:Fax Number:Email Address:

Ms. Elizabeth

77530

[email protected]

Project Manager

77042713-244-1039

ZIP Code:

713-378-8757281-860-3214

City:

Enter the contact information for the Technical Contact. This is the designated representative who will be listed in the public notice as a contact for additional information.

B. Public placePlace a copy of the full application (including all of this workbook and all attachments) at a public place in the county where the facilities are or will be located. You must state where in the county the application will be available for public review and comment. The location must be a public place and described in the notice. A public place is a location which is owned and operated by public funds (such as libraries, county courthouses, city halls) and cannot be a commercial enterprise. You are required to pre-arrange this availability with the public place indicated below. The application must remain available from the first day of publication through the designated comment period.

If this is an application for a PSD, nonattainment, or FCAA §112(g) permit, the public place must have internet access available for the public as required in 30 TAC § 39.411(f)(3).

If the application is submitted to the agency with information marked as Confidential, you are required to indicate which specific portions of the application are not being made available to the public. These portions of the application must be accompanied with the following statement: Any request for portions of this application that are marked as confidential must be submitted in writing, pursuant to the Public Information Act, to the TCEQ Public Information Coordinator, MC 197, P.O. Box 13087, Austin, Texas 78711-3087.

Address Line 2:City:State:

ChannelviewTX


[email protected]

State:

Yes

City: Houston77023-1452Harris

TCEQ Houston Regional OfficePhysical Address:

Stanko

Prefix (Mr., Ms., Dr., etc.):

713-789-5920

Last Name:

Address Line 2:

First Name:

Has the public place granted authorization to place the application for public viewing and copying?

Title:

HoustonTX

10550 Richmond Avenue Suite 210

Telephone Number:

Email Address:Fax Number:

Name of Public Place:

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C. Alternate Language PublicationIn some cases, public notice in an alternate language is required. If an elementary or middle school nearest to the facility is in a school district required by the Texas Education Code to have a bilingual program, a bilingual notice will be required. If there is no bilingual program required in the school nearest the facility, but children who would normally attend those schools are eligible to attend bilingual programs elsewhere in the school district, the bilingual notice will also be required. If it is determined that alternate language notice is required, you are responsible for ensuring that the publication in the alternate language is complete and accurate in that language.

YesIs a bilingual program required by the Texas Education Code in the School District?

If yes to either question above, list which language(s) are required by the bilingual program?

Yes


Spanish

Are the children who attend either the elementary school or the middle school closest to your facility eligible to be enrolled in a bilingual program provided by the district?

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No

No

Complete this section to determine small business classification. If a small business requests a permit, agency rules (30 TAC § 39.603(f)(1)(A)) allow for alternative public notification requirements if all of the following criteria are met. If these requirements are met, public notice does not have to include publication of the prominent (12 square inch) newspaper notice.

III. Small Business Classification

Small business classification:

Does the company (including parent companies and subsidiary companies) have fewer than 100 employees or less than $6 million in annual gross receipts?

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Texas Commission on Environmental QualityForm PI-1 General Application

Federal Applicability



Determination:

No

Pollutant Project Increase Threshold PSD Review Required?

CO 0 100 No

NOx 0 40 No

PM 0.32 25 No

PM10 0.32 15 No

PM2.5 0.32 10 No

SO2 0 40 No

Pb 0 0.06 No

H2S 0 10 No

TRS 0 10 No

Reduced sulfur compounds (including H2S) 0 10 No

H2SO4 0 7 No

Fluoride (excluding HF) 0 3 No

CO2e 0 75000 No

No

Pollutant Project Increase Threshold NA Review Required?

Ozone (as VOC) 0 25 No


I. County Classification

This project will be located in a county with a Serious Ozone nonattainment classification, and the project will be reviewed under a Serious Ozone nonattainment classification. Complete the nonattainment section below and provide an analysis with the application.

Harris

II. PSD and GHG PSD Applicability Summary


County (completed for you from your response on the General sheet)

Does the project require retrospective review? No

This project will be located in an area that is in attainment for ozone as of Sept. 23, 2019. Select from the drop-down list to the right if you would like the project to be reviewed under a different classification.

III. Nonattainment Applicability Summary

Ozone - Serious

Is netting required for the PSD analysis for this project?

Is netting required for the nonattainment analysis for this project?

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Federal Applicability



Ozone (as NOx) 0 25 No

Pollutant Offset Ratio Offset Quantity Required (tpy) Where is the offset coming from?


IV. Offset Summary (for Nonattainment Permits)


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Form PI-1 General ApplicationFees



No

No

I. General Information - Non-Renewal

II. Direct Costs - Non-RenewalThis cell intentionally left blank

Is this project for new facilities controlled and operated directly by the federal government? (30 TAC § 116.141(b)(1) and 30 TAC § 116.163(a))

A fee of $75,000 shall be required if no estimate of capital project cost is included with the permit application. (30 TAC § 116.141(d)) Select "yes" here to use this option. Then skip sections II and III.

Select Application Type Minor Application

Installation, including foundations, erection of supporting structures, enclosures or weather protection, insulation and painting, utilities and connections, process integration, and process control equipment.

$0.00

Type of Cost AmountProcess and control equipment not previously owned by the applicant and not currently authorized under this chapter.

$0.00

Auxiliary equipment, including exhaust hoods, ducting, fans, pumps, piping, conveyors, stacks, storage tanks, waste disposal facilities, and air pollution control equipment specifically needed to meet permit and regulation requirements.

$0.00

Freight charges. $0.00Site preparation, including demolition, construction of fences, outdoor lighting, road, and parking areas.

$0.00

Auxiliary buildings, including materials storage, employee facilities, and changes to existing structures.

$0.00

For GHG permits: A single PSD fee (calculated on the capital cost of the project per 30 TAC § 116.163) will be required for all of the associated permitting actions for a GHG PSD project. Other NSR permit fees related to the project that have already been remitted to the TCEQ can be subtracted when determining the appropriate fee to submit with the GHG PSD application. Identify these other fees in the GHG PSD permit application.

Ambient air monitoring network. $0.00Sub-Total: $0.00

Sub-Total: $0.00


III. Indirect Costs - Non-RenewalType of Cost AmountFinal engineering design and supervision, and administrative overhead. $0.00Construction expense, including construction liaison, securing local building permits, insurance, temporary construction facilities, and construction clean-up. $0.00

Contractor's fee and overhead. $0.00


IV. Calculations - Non-Renewal

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$0.00

$900.00

$900.00

Yes900.00$

$900.00

Enter the check, money order, ePay Voucher, or other transaction number:Enter the Company name as it appears on the check:

Voucher 439228

paid online

Enter the fee amount:Was the fee paid online?

In signing the "General" sheet with this fee worksheet attached, I certify that the total estimated capital cost of the project as defined in 30 TAC §116.141 is equal to or less than the above figure. I further state that I have read and understand Texas Water Code § 7.179, which defines Criminal Offenses for certain violations, including intentionally or knowingly making, or causing to be made, false material statements or representations.


Your estimated capital cost: Minimum fee applies.Permit Application Fee: $900.00


VII. Payment Information



VI. Total FeesNote: fees can be paid together with one payment or as two separate payments.Non-Renewal Fee

Total

Greater than $25,000,000 $75,000 (maximum fee)

Less than $300,000 $900 (minimum fee)$300,000 - $7,500,000 N/A

$300,000 - $25,000,000 0.30% of capital costGreater than $7,500,000 N/A

Estimated Capital Cost Minor Application Fee

C. Total Paid

A. Payment One (required)

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No

No


VIII. Professional Engineer Seal RequirementIs the estimated capital cost of the project above $2 million?

Is the application required to be submitted under the seal of a Texas licensed P.E.?Note: an electronic PE seal is acceptable.

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Form PI-1 General ApplicationImpacts



PollutantDoes this pollutant require PSD review?

How will you demonstrate that this project meets all applicable requirements?

Notes Additional Notes (optional)

VOC No Not applicableThis pollutant is not a part of this project or does not require an impacts analysis.

IOC-U No Not applicableThis pollutant is not a part of this project or does not require an impacts analysis.

NOx No Qualitative analysisProvide a detailed description of how the project meets all applicable impacts requirements using the Additional Notes column of this worksheet or as an attachment.

Modeling impacts were assessed qualitatively using the impacts analysis that was previously submitted to TCEQ in support of the Pollution Control Project (PCP) Standard Permit (SP) No. 154687, issued in December 2018. The SCREEN3 modeling analysis that was previously submitted to TCEQ in support of the PCP Standard permit application is included as Appendix C to this permit amendment application with a qualitative analysis, which can be used to assess impacts from the permit amendment to incorporate the PCP SP. The SCREEN3 AQA attached included post processing results using UIMs.

CO No Qualitative analysisProvide a detailed description of how the project meets all applicable impacts requirements using the Additional Notes column of this worksheet or as an attachment.


SO2 No Qualitative analysisProvide a detailed description of how the project meets all applicable impacts requirements using the Additional Notes column of this worksheet or as an attachment.


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Form PI-1 General ApplicationImpacts



PollutantDoes this pollutant require PSD review?

How will you demonstrate that this project meets all applicable requirements?

Notes Additional Notes (optional)

PM No Qualitative analysisProvide a detailed description of how the project meets all applicable impacts requirements using the Additional Notes column of this worksheet or as an attachment.


PM10 No Qualitative analysisProvide a detailed description of how the project meets all applicable impacts requirements using the Additional Notes column of this worksheet or as an attachment.


PM2.5 No Qualitative analysisProvide a detailed description of how the project meets all applicable impacts requirements using the Additional Notes column of this worksheet or as an attachment.


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Form PI-1 General ApplicationBACT



Action Requested FINs Unit Type Pollutant Current Tier I BACT Confirm Additional Notes

Consolidate Multiple Control: Vapor Combustor VOC 99% destruction efficiency. Monitor temperature. Perform initial test. Yes

The vapor combustors shall achieve 99.95-percent control of the waste gas directed to it. This level of control exceeds current BACT requirements. This shall be achieved by monitoring the combustion chamber temperature and performing an initial stack test on the equipment.

Consolidate Multiple Control: Vapor Combustor NOx See Additional Notes: Yes

There are no current BACT requirements for NOx emissions from a Vapor Combustor control device. Southwest Shipyard will maintain good combustion practices using natural gas. NOx emissions are based on the vendor guaranteed NOX emission factor.

Consolidate Multiple Control: Vapor Combustor CO See Additional Notes: Yes

There are no current BACT requirements for CO emissions from a Vapor Combustor control device. Southwest Shipyard will maintain good combustion practices using natural gas. CO emissions are based on the vendor guaranteed CO emission factor.

Consolidate Multiple Control: Vapor Combustor SO2 See Additional Notes: YesThere are no current BACT requirements for SO2 emissions from a Vapor Combustor control device. Southwest Shipyard will maintain good combustion practices using natural gas and will use low sulfur fuel.

Consolidate Multiple Control: Vapor Combustor









Consolidate Multiple Control: Vapor Combustor MSS Same as normal operation BACT requirements. Yes

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Monitoring



FIN Unit Type Pollutant Minimum Monitoring Requirements Confirm Additional Notes for Monitoring

Multiple Control: Vapor Combustor VOCContinuous Exhaust Temperature Monitoring recorded in six minute averages. Waste gas flow monitor or operation record that provides flow by design.

Yes

The exhaust temperature will be continuously monitored and recorded when waste gas is directed to the vapor combustors. The temperature measurement device will reduce the temperature readings to an averaging period of six minutes or less. The temperature measurement device shall be installed, calibrated, and maintained according to accepted practice and the manufacturer's specifications. Operational records will be used that provide flow by design to monitor the waste gas flow.

Multiple Control: Vapor Combustor NOxContinuous Exhaust Temperature Monitoring recorded in six minute averages. Waste gas flow monitor or operation record that provides flow by design.

Yes


Multiple Control: Vapor Combustor COContinuous Exhaust Temperature Monitoring recorded in six minute averages. Waste gas flow monitor or operation record that provides flow by design.

Yes


Multiple Control: Vapor Combustor SO2Continuous Exhaust Temperature Monitoring recorded in six minute averages. Waste gas flow monitor or operation record that provides flow by design.

Yes


Version 4.0 Page 1


Form PI-1 General ApplicationMaterials



How submitted Date submitted

Email 01/10/2020STEERS 11/08/2019Not applicable

STEERS 11/08/2019STEERS 11/08/2019STEERS 11/08/2019STEERS 11/08/2019

STEERS 11/08/2019

Not applicable

STEERS 11/08/2019STEERS 11/08/2019

STEERS 11/08/2019

STEERS 11/08/2019Not applicableNot applicableNot applicableNot applicable

STEERS 11/08/2019

Process descriptionProcess flow diagram

Summary and project emission increase determination - Tables 1F and 2F

Plot plan

Item

Core Data Form

Form PI-1 General ApplicationHard copy of the General sheet with original (ink) signature

B. General Information

A. Administrative Information

Professional Engineer Seal

Copy of current permit (both Special Conditions and MAERT)

MERA analysis

PSD modeling protocol

Electronic Modeling Evaluation Workbook: SCREEN3

Qualitative impacts analysis

Proposed Updates to Permit Special Conditions and MAERT (Section 4 of application).

State regulatory requirements discussion

Area map

BACT discussion, if additional details are attachedMonitoring information, if additional details are attached

List of MSS activities

Electronic Modeling Evaluation Workbook: NonSCREEN3

C. Federal Applicability

E. Impacts Analysis

D. Technical Information

F. Additional Attachments

Material Balance (if applicable)Calculations

Netting analysis (if required) - Tables 3F and 4F as needed

Version 4.0 Page 1

1

Stanko, Elizabeth

From: Stanko, ElizabethSent: Monday, February 3, 2020 9:17 AMTo: Joseph GrieselCc: Bernard DiazSubject: RE: Draft Permit 9442/Project Number 308754 for Southwest Shipyard LPAttachments: Table C-3 NAAQS Modeling Results Updated 02-03-2020.pdf

Importance: High

Dear Mr. Griesel, The modeling results Table C‐3 displayed the individual emissions from each VCU for clarity of the modeling demonstration, however the impacts were summed for each VCU to demonstrate compliance with the NAAQS. Given the summation used in the modeling analysis, the full hourly emissions limit could be emitted from one VCU unit and would still result in acceptable impacts. This is because we used SCREEN3 (single‐source model) and summed the impacts, and the unit impact multipliers are identical for each unit. For example, if 10.26 lb NOx/hour were emitted from one stack (instead of 5.13 lb NOx/hour from each), the impacts would be identical as shown in the Table C‐3.

10.26 lb/hour x 0.379 µg/m3 per lb/hr = 3.89 µg/m3. I have updated this table (attached) to show the combine hourly and annual limits, and the impacts are unchanged for the analysis originally submitted. As such, can you please combine the hourly VCU‐2 and VCU‐3 MAERT limits as shown in the application, which is analogous to how the Flares (FL‐1, FL‐3) being replaced are currently permitted. This is necessary as the barge degassing operations use the Flares (and replacement VCUs) interchangeably during barge cleaning operations (FIN BRGCLN), and it would be difficult from a recordkeeping perspective to track these separately. Regarding the Special Conditions, these are acceptable, and we just noticed one typo in SC 15A.

Thank you, Elizabeth Elizabeth Stanko, CCM Senior Project Manager




Hourly Annual Hourly Annual Hourly Annual Hourly Annual

VCU-2 and VCU-3 10.26 3.24 40.50 12.80 0.022 0.09 1.01 0.32

PM10

1-hr Annual 1-hr 8-hr 24-hr 24-hr Annual 1-hr 3-hr 24-hr Annual

VCU-2 and VCU-3 0.379 0.342 0.266 0.152 0.007 3.89 0.02 15.37 10.76 0.153 0.153 0.002 0.008 0.007 0.003 0.0007

3.89 0.02 15.37 10.76 0.15 0.15 0.002 0.008 0.007 0.003 0.001

7.5 1 2000 500 5 1.2 0.2 7.8 25 5 1

Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes


SIL (ug/m3)

Less Than SIL?

SourceSO2

Source


1-hr 8-hr AnnualNO2


SO2

3-hr

December 2019

POLLUTION CONTROL PROJECT STANDARD PERMIT (PCP SP)SOUTHWEST SHIPYARD, L.P.

CO


24-hr

NOX CO

A NAAQS analysis was performed to demonstrate compliance with applicable standards and guideline concentrations for offsite impacts of criteria pollutants (NO 2, CO, and SO2). The proposed project increases of the criteria air pollutants were evaluated against the NAAQS SILs to determine if impacts were less than the de minimis thresholds. The modeling results of the NAAQS preliminary impact analysis were determined using the SCREEN3 predicted unit impact multipliers (shown in Table C-2) for the applicable averaging periods. Table C-3 summarizes the modeled project emission rates for criteria pollutants, and the NAAQS preliminary impact analysis results for comparison to all of the applicable NAAQS SILs. NOx emissions were conservatively assumed to be 100-percent NO2.

The NAAQS significant impact modeling results indicate that the SCREEN3 predicted GLC MAX associated with the proposed project emissions were less than the SIL for all pollutants and all applicable averaging periods. Therefore, a full-impact refined NAAQS analysis is not required for any pollutants. As such, the project will not cause or contribute to a violation of the applicable NAAQS standards, and the State NAAQS demonstration is complete.

Air Quality Analysis (AQA)

PM2.5

PM10/PM2.5



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