TELEPHONE CONTACT SUMMARY – 0210426.004.015 

FROM: Karen Schaffner, RTI International 

DATE OF CONTACT: May 14, 2010 

ORGANIZATION CONTACTED: 

Broward County, FL 

Pollution Prevention, Remediation, and Air Quality Division (PPRAQD) 

1 North University Drive, Suite 203 

Plantation, Florida 33324-2038 

PERSON CONTACTED: 

Seree Jairam, (954) 519-1248; SJAIRAM@broward.org 

SUMMARY OF CONTACT: 

Ms. Schaffner contacted Mr. Jairam to discuss the TransMontaigne Terminals, LLC, Port 

Everglades North Terminal, Facility ID No. 0110069. Ms. Schaffner asked about 

applicability of 40 CFR part 63, subpart Y, NESHAP for Marine Vessel Loading 

Operations. Mr. Jairam noted the facility includes a marine terminal and a bulk terminal 

that are permitted together. The permit engineer who typically dealt with the initial 

permitting of the facility is no longer with their office. The facility is a major source of 

HAP. 

Mr. Jairam provided information on the facility, as summarized in the following 

paragraphs. The facility had a construction permit (0110069-006-AC) in 1997 to install a 

marine VRU; the marine VRU began operation in May 1998. The marine terminal 

emissions were now <10/25 ton HAP, due to the VRU, and is subject to the NESHAP 

subpart Y recordkeeping requirements for facilities with marine vessel loading emissions 

<10/25 ton HAP. In the absence of the subpart Y testing standard, it was agreed to use 

NSPS subpart XX (Bulk Gasoline Terminals, promulgated in 1983) emission limit of 35 

mg/L as an alternative and the subpart XX testing requirements. The emission limit of 35 

mg/L also contributes to synthetically limiting the source to below the major PSD source 

threshold for VOC. 

The NSPS subpart XX gasoline emission limit of 35 mg/L gasoline loaded was applied 

to the Marine facility, (this was applied since application of the VRU reduced actual 

marine vessel loading emissions below the 10/25 threshold for applying emission control 

MACT standard under subpart Y, even though subpart XX does not explicitly cover 

marine loading operations; however the rule was transferable and the test methods in that 

rule were applied and conducted.). [The permit refers to Rule 62-4.070(3), F.A.C., 

Construction Permit No. 0110069-016-AC.] Originally, MVL emissions were ≥10/25 

tons of HAP, but after installation of the Marine VRU, the MVL emissions were < 10/25 

tons of HAP. He is not certain what the control efficiency of the Marine VRU is, 
although he noted that the marine terminal does operate well below the 35 mg/L gasoline 

loaded limit. 

Recently, the port authority required the facility to move their marine terminal site 

because of traffic problems at the berth. So the facility dismantled the original site, 

applied for a construction permit with the county, and built the marine terminal at a 

different location. The facility purchased new equipment to build the marine terminal on 

the different site. It is not completely clear whether the marine terminal is a new or 

existing facility. Although this is still under review, he thought the relocated marine 

terminal met the definition of “reconstruction” in the construction permit, and could be 

considered a “new” terminal. Mr. Jairam noted that the facility is currently revising the 

marine construction permit. The use of the term offshore terminal in the current Marine 

construction permit is a mistake. The permit will be revised to remove this text. 

With respect to submerged fill for marine tank vessels, the facility is not certain whether 

marine vessels are using submerged fill. The marine terminal itself does not have 

submerged loading.