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 Divis ion (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 Tran sMontaigne 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 m arine terminal and a bulk terminal that are permitted together. The permit engineer who ty pically dealt with the initial permitting of the facility is no longer with their off ice. The facility is a major source of

HAP.

Mr. Jairam provided information on the facility, as sum marized 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 st andard, it was agreed to use NSPS subpart XX (Bulk Gasoline Terminals, promulgated in 1983) em ission limit of 35 mg/L as an alternative and the subpart XX testing requirem ents. The emission limit of 35 mg/L also contributes to synthetically limiting the sour ce to below the major PSD source

threshold for VOC.

The NSPS subpart XX gasoline emission limit of 35 mg/L gas oline loaded was applied to the Marine facility, (this was applied since applicati on of the VRU reduced actual marine vessel loading emissions below the 10/25 threshold fo r applying emission control MACT standard under subpart Y, even though subpart XX does n ot explicitly cover marine loading operations; however the rule was transfer able and the test methods in that rule were applied and conducted.). [The permit refers to R ule 62-4.070(3), F.A.C., Construction Permit No. 0110069-016-AC.] Originally, MVL emi ssions 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 ef ficiency of the Marine VRU is,although he noted that the marine terminal does operate we ll below the 35 mg/L gasoline

loaded limit.

Recently, the port authority required the facility to m ove their marine terminal site because of traffic problems at the berth. So the faci lity dismantled the original site, applied for a construction permit with the county, and bu ilt the marine terminal at a different location. The facility purchased new equipme nt to build the marine terminal on the different site. It is not completely clear whet her the marine terminal is a new or existing facility. Although this is still under review, h e 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 th e facility is currently revising the marine construction permit. The use of the term offsho re terminal in the current Marine construction permit is a mistake. The permit will be r evised to remove this text.

With respect to submerged fill for marine tank vessels, th e facility is not certain whether marine vessels are using submerged fill. The marine term inal itself does not have submerged loading.