### Bryan W. Shaw, Ph.D., 

### Chairman

Buddy Garcia, 

### Commissioner

Carlos Rubinstein, Commissioner 

## -



# .

:**~~·.->** .:.\ \ .: I·

### !d:~ 

# fJLr.;·u:i: . !·



### Mark R. 

### Vickery, P.G., 

### Executive Director 

# 10 APR -9 Pii 

# 1:55

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

Protecting Texas bg Reducing and Preventing Pollution 

# April6,2010

Docket No. 2009-0802-SIP, Project No. 2009-017-SIP-NR**~** 

## Docket No. 2009-0932-RUL, Rule Project No. 2009-006-101-EN

·

Docket No. 2009-0867-RUL, Rule Project No. 2009-019-101-EN

A1 Armendariz, PhD, Regional Administrator

U.S. Environmental Protection Agency- Region 6



## 1445 Ross Avenue

Dallas, Texas 75202-2733

.

Dear Dr. Armendariz:

On March 10, 2010, the Texas Commission on Environmental Quality (Commission) adopted revisions to 

## the

State Implementation Plan (SlP) for the control of ozone air pollution for the Houston-Galveston-Brazoria

(HGB) 

## area.

The Commission adopted amendments to 

## 30 Texas Administrative Code (TAC) Chapter 101, Subchapter A,

General Rules, Section 101.1; and Subchapter H, Emissions Banking and Trading, Division 6, Highly Reactive

Volatile Organic Compound Emissions Cap and 

## Trade Program, 

## Sections 101.390

- 101.394, 101.396, and



## 101.399

- 101.401; 30 TAC Chapter 101, Subchapter H, 

## Emissions Banking and Trading, Division 3, Mass

Emissions C and 

## Trade Pro 

## Sections 101.350 101.351 and 

## 101.353 and co · revisions to the

SlP; and 

## GB Attsinment Demonstration SlP Revision for the 1997 Ei t-Hour Ozone Standard. These rule

changes and SIP revisions demonstrate that the HGB area 

## will attain the 

## 1997 eight-hour ozone National

Ambient Air 

## Quality Standard by June 15, 2019.

Enclosed are 

## the proposed revisions to the SlP, a public hearing certification, a 

## complete record of the public

hearings, and the accompanying orders.· I 

## look forward to your expeditious approval of these SlP revisions.

Sincerely, 

# B**~,;ktw.--·**

# B~haw,PhD.

Chairman

BWS/jmm

Enclosures

cc: The Honorable Rick Perry, Governor ofTexas

Mr. Toby Baker, Office ofBudget, Planning and Policy, Office of the Governor

Mr. Mark 

## R Vickery, P.G., Executive Director, Texas Cor!unission on Environmental Quality

P.O. Box 13087 Austin, Texas 78711-3087 512-239'1000 1ntemet address: www.tceq.state.tx.usTexas Commission on Environmental Quality

Public Hearings

Odober 28-29, 2009

Houston-Galveston-Brazoria (HGB)

Attainment Demonstration SIP Revision

for the 1997 Eight-Hour Ozone Standard

Projed Number 2009-017-SIP-NR

Volume 2 of2

### REVISION TO THE STATE IMPLEMENTATION PLAN

FOR THE CONTROL OF OZONE AIR POLLUTION

HOUSTON-GALVESTON-BRAZORIA 1997 EI GHT-HOUR OZONE STANDARD

NONATTAINMENT AREA

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

P.O. BOX 13087

AUSTIN, TEXAS 78711-3087

Houston-Galveston-Brazoria Attainment Demonstration

State Implementation Plan Revision for the 1997 Eight-Hour Ozone Standard

PROJECT NO. 2009-017-SIP-NR

Adopted

March 10, 2010

### xv LIST OF APPENDICES

Appendix Appendix Name

Appendix A Meteorological Modeling for the HGB Attainment Demonstration SIP

Revision for the 1997 Eight-Hour Ozone Standard

Appendix B Emissions Modeling for th e HGB Attainment Demonstration SIP

Revision for the 1997 Eight-Hour Ozone Standard

Appendix C Photochemical Modeling for the HGB Attainment Demonstration SIP

Revision for the 1997 Eight-Hour Ozone Standard

Appendix D Reasonably Available Control Technology Analysis

Appendix E Reasonably Available Control Measure Analysis

Appendix F Evaluation of Mobile Sour ce Control Strategies for the HoustonGalveston-Brazoria State Implementation Plan (With Detailed

Strategies), Prepared for Houston-Galveston Area Council, Prepared by

ENVIRON International Corporation

Appendix G Transportation Control Measures for the HGB Attainment

Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard

(Excerpt from Evaluation of Mobile Source Control Strategies for the

Houston-Galveston-Brazoria State Implementation Plan), Prepared for

Houston-Galveston Area Council, Prepared by ENVIRON International

Corporation

Appendix H Voluntary Mobile Emission Reduction Program for the HGB Attainment

Demonstration SIP Revision for the 1997 Eight-Hour Ozone Standard

(Excerpt from Evaluation of Mobile Source Control Strategies for the

Houston-Galveston-Brazoria State Implementation Plan), Prepared for

Houston-Galveston Area Council, Prepared by ENVIRON International

Corporation

Appendix I Corroborative Analysis for th e HGB Attainment Demonstration SIP

Revision for the 1997 Eight-Hour Ozone Standard

Appendix J Recommendations for Best Ma nagement Practices to Control and

Reduce Inadvertent Cargo Vapor Emissions in the Tank Barge

Community

## APPENDIX J

RECOMMENDATIONS FOR BEST MANAGEMENT PRACTICES

TO CONTROL AND RED UCE INADVERTENT CARGO VAPOR EMISSIONS

IN THE TANK BARGE COMMUNITY

# Recommendations for Best Management Practices to

Control and Reduce Inadvertent Cargo Vapor

Emissions in the Tank Barge Community

A Collaboration of

the Chemical Transportation Advisory Committee (CTAC),

the Louisiana Department of Environmental Quality (LDEQ),

the Texas Commission on Environmental Quality (TCEQ) and

the American Waterways Operators (AWO)



# CTAC



# The American Waterways Operators

## 2 BACKGROUND

The federal Clean Air Act and federal regula tions adopted by the Environmental Protection

Agency (EPA) require each state to achieve a ttainment with Nationa l Ambient Air Quality

Standards (NAAQS). States that do not meet NAAQS must prepare a State Implementation Plan

(SIP) under the Clean Air Act to incorporate re ductions to meet NAAQS. Both Louisiana and

Texas have air quality issues in demonstrat ing attainment for NAAQS for ozone. The Baton

Rouge, Lake Charles and New Orleans areas in L ouisiana have been identified as areas that

either are near non-attainment or close to designation of non-attainment under the Clean Air Act.

In Texas, Houston-Galveston and Beaumont-Port Arthur areas are in non-attainment and have

SIP in place to accomplish reductions to m eet attainment of the ozone standard.

Louisiana Department of Environmental Quality (LDEQ) is responsible for revising Louisiana’s

SIP to demonstrate that Louisiana will be able to meet ozone standards. Texas Commission on

Environmental Quality (TCEQ) is responsible for SIP preparation and oversight in Texas. EPA

approval of the SIP and attainment of NAAQ S are essential for economic development and

funding of federal projects.

Remote Sensing Projects

Because highly reactive volatile organic compounds (HRVOCs) and volatile organic compounds

(VOCs) may contribute to ozone formation, LD EQ and TCEQ have in itiated dem onstration

projects utilizing remote sensing cameras to id entify potential sources of emissions in order to

develop reduction strategies. Th e camera called the “HAWK” is a helicopter-mounted infrared

camera system capable of providing real time leak detection data. The HAWK provides

qualitative information with respect to identifyi ng a potential source or plume. To date, the

technology does not speciate the chemi cals or quantify concentrations.

Both LDEQ and TCEQ implemented overflight s in summer of 2005 utilizing the HAWK camera

and observed emission events from barges, stor age tanks and other shoreside facilities.

AWO Best Management Practice

In response to the Hawk data, AWO Southern Region developed a Barge Emissions Working

Group to develop industry Best Management Practices (BMP) to reduce and control emissions

from barges. The working group developed the a ttached BMP matrix which identifies areas of

activity that can accomplish emission reductions. The BMP document has been reviewed with

both LDEQ and TCEQ, in addition to the Ch emical Transportation Advisory Committee

(CTAC) and U.S. Coast Guard. The intent is to ensure AWO membership incorporates these

BMPs into their operations in order to contribute to the control and reduction of emissions from

tank barges without the necessity of federal or state regulation.

Both LDEQ and TCEQ have embraced industry’s co mmitment to take action in addressing the

issue of barge emissions on its own behalf as opposed to requiring states or federal government

to implement regulations to accomplish this goal. In addition, CTAC has identified core third

## 3 party industries that need to be educated abou t the AWO BMP matrix. CTAC will take the lead

in disseminating the AWO BMP matrix to th e following industries: 1) shore tankering

companies; 2) shipyard/cl eaning vendors; 3) terminals/facilities; and 4) cargo

inspectors/surveyors; In addition, AWO members are asked to ensure this product is shared with

its outside vendors and suppliers of these services in order to ensure our commitment to this

initiative is fully communicated.

Attached is the BMP for implemen tation in your organization. Pleas e further this initiative by

reviewing the operational best management practices and reit erating the commitment to reduce

emissions at your operations level. It is incumbent upon each organization to support this

initiative in order to ensure th e goals of the working group and st ate agencies are accomplished.

As one of the most environmentally friendly forms of transportation, the barge and towing

industry has a long history of lead ership in environmental protec tion. The industry believes that

the most significant challenges it faces are be st resolved through government and industry

collaboration. In following this long tradition of lead ership and proactiv ely, the industry has

worked with the LDEQ and TCEQ to develop the scope of their emissions-reduction programs

and to implement a set of industry recommended best management practices to reduce

inadvertent emissions from tank barges.4AREA /ITEMPOTENTIAL ISSUE OFCONCERNPROPOSED BEST PRACTICERESPONSIBLE PARTYVapor VentStack DischargingCheck vacuum valve is working on P/V valve. Begin Discharge Initially,Then Open Vent Stack for Air IntroductionBarge PICDischargingKeep all hatches closed, use sight glasses to monitor cargo, vaporsintroduced through the vent stack.Barge PICLoading through vent stackKeep all hatches closed, use sight glasses to monitor cargo, cargo vaporvented through vent stack.Barge PICButter-Fly Valves, SealingProblems, Potential LeaksIf barge is equipped with butter-fly valves consider replacing with gatevalves or full port ball valvesas the valves need to be replaced. Barge PIC/Owner/OperatorButterworthHatchesImproper Tightening of DogAssembliesRemove Dog Assemblies, replace dogs with nuts as needed. (Ensureproper torque) Owner/OperatorDog Assemblies Left LooseWhen possible, takes steps to avoid opening hatches or minimizeemissions (i.e. load through vent stack using sight glasses, samplethrough ullage hatches or closed sampling devices, etc.). Considerprocedure that restricts opening unless the barge is in a shipyard / repairfacility.Owner/OperatorImproper Gasketing MaterialUsed / Aged / DamagedCheck and replace as necessary at each opening, and also at each yardstay. Ensure hatch is properly seatedon closing. Adapt preventativemaintenance program based on experience/data.Owner/OperatorHatch Condition - Knife EdgeDeterioratedInspection at each opening. Clean surfaces. Consider retrofitting hatchwith stainless rings. Owner/OperatorUllageHatches Opened / Closed ImproperlyCommunicate obligations of proper closure and gauging for inspectors;when possible accompany inspector while on barge Inspector/Barge PIC/Dock PICImproperly Dogged / TightenedDownTraining / Procedures Inspector/Barge PIC/Dock PICImproper Gasketing MaterialUsed / Aged / DamagedCheck and replace as necessary at each opening, and also at each yardstay. Ensure hatch is properly seatedon closing. Adapt preventativemaintenance program based on experience/data. Owner/Operator5Hatch Condition - Knife EdgeDeterioratedInspection at each opening. Clean surfaces. Consider retrofitting hatchwith stainless rings. Barge PIC/Owner/OperatorSightGlasses Cracked Sight GlassTraining / Procedures to ensure the sight glasses are inspected onceeach transfer and cracked sight glasses are reported and replaced. Barge PIC/Owner/OperatorGasketing Material Worn orImproperly InstalledInspection every transfer if transfer is under vapor and during shipyardperiods. Adapt preventative maintenance program based onexperience/data.Barge PIC/Owner/OperatorWiper Mechanism GasketingMaterial DeterioratedInspection every transfer if transfer is under vapor and during shipyardperiods. Adapt preventative maintenance program based onexperience/data.Barge PIC/Owner/OperatorIncompatible Gasketing Materialfor ProductTraining / Procedures to ensure proper gasket selection, inspect duringshipyard periods, inspect for leakage and other problems each transferand report for repair as needed. Owner/OperatorHeaderFlanges(Blinds)No Gasketing Material UsedImprove inspection protocol / Follow-up, Employee Training / Education /ProceduresOwner/Operator/Barge PIC/Dock PICImproper Tightening of BoltsReinforce appropriate method through education - Criss/Cross MethodEnforced (Vessel / Facility) / ProceduresOwner/Operator/Barge PIC/Dock PICFlange Face Surface Pitted /Scarred / WornImplement internal inspection guidelines / reporting of deficiencies andreplacement protocol, recommend the face be inspected whenever theflange is used and during shipyard periods. Adapt preventativemaintenance program based on experience/data. Owner/OperatorIncompatible Gasketing Materialfor ProductTraining / Procedures to ensure proper gasket selection, new gasketwhenever flange is used.Owner/OperatorHeader Valve Seats LeakingCheck valves that are usedduring the transfer and hoseconnection/disconnection, and report for repair as needed. Test duringshipyard periods, at least annually. Adapt preventative maintenanceprogram based on experience/data.Owner/OperatorCargoPumpDeepwell Can Bleed Valve Openor Leaking Install closed bleeder system and / or spring loaded valves Owner/Operator6Cargo Pump Seal Leaking -Cavity Holding ProductRecommend tandem seals on deepwell pumps for high hazard cargoes(CDC cargoes) Owner/OperatorDeepwell Stripping Plug InstalledImproperly / Loose Recommend that this item bepart of a pre-transfer inspection. Barge PICExpansionDomeHatchOpened / Closed Improperly byInspectorCommunicate obligations of proper closure and gauging for inspectors;when possible accompany inspector while on barge. Training /ProceduresInspector/Barge PICImproperly Dogged / TightenedDownCommunicate obligations of proper closure and gauging for inspectors;when possible accompany inspector while on barge. Training /ProceduresInspector/Barge PICImproper Gasketing MaterialUsed / Aged / DamagedConsider replacement of gasket material at established intervals;recommend at least every two years,or as required. Gasket should beinspected by PIC if hatch is opened.Adapt preventative maintenanceprogram based on experience/data. Owner/Operator/Barge PICHatch Condition - Knife EdgeDeterioratedInspection every transfer if the hatch is opened and during shipyardperiods. Consider retrofitting with stainless rings. Adapt preventativemaintenance program based on experience/data. BargePIC/Owner/OperatorIncompatible Gasketing Materialfor ProductTraining / Procedures to ensure proper gasket selection, inspectionevery transfer if the hatch is openedand during shipyard periods. Adaptpreventative maintenance program based on experience/data. Owner/Operator/Barge PICRestrictedGaugeTubesGauge Tube Cap ImproperlyInstalled / Loose/MissingCommunicate obligations of proper closure and gauging for inspectors;when possible accompany inspector while on barge. Training /Procedures. Inspector/Barge PIC/Dock PICGauge Tube Threads DamagedInspection every transfer if the gauge tube is opened and duringshipyard periods. Adapt preventative maintenance program based onexperience/data. BargePIC/InspectorSlop TankPressure Relief Valve SettingIncorrectBench Test / Verify Setting / Confirm Labeling is Correct / Inspect duringshipyard periods. Adapt preventative maintenance program based onexperience/data. Verify leak-free during each transfer.Owner/OperatorImproperly Dogged / TightenedDown Operate as a closed system. TrainingOwner/Operator7Improper Gasketing MaterialUsed / Aged / DamagedConsider replacement of gasket material at established intervals;recommend at least every two years. Adapt preventative maintenanceprogram based on experience/data. Gasket should be inspected by PICif hatch is opened. Owner/OperatorHatch Condition - Knife EdgeDeterioratedInspection at each opening. Clean surfaces. Consider retrofitting hatchwith stainless rings. Barge PIC/Owner/OperatorSight Glass CrackedTraining / Procedures to ensure the sight glasses are inspected onceeach transfer and cracked sight glasses are reported and replaced.Adapt preventative maintenance program based on experience/data.Barge PIC/Owner/OperatorSight Glass Gasketing MaterialUsed / Aged / DamagedTraining / Procedures to ensure proper gasket selection, inspect duringshipyard periods, inspect for leakage and other problems each transferand report for repair as needed.Adapt preventative maintenanceprogram based on experience/data. Owner/OperatorCargoStrippingPump Packing Gland Leakage Training / Procedures / Inspect prior to each transferBarge PIC/Owner/OperatorSystem Valving Leaking /Incompatible PackingTraining / Procedures / Inspect prior toeach transfer Barge PIC/Owner/OperatorBlind Flanges/s loose/Threads onplugs bad/Deck stripping valvesleakTraining / Procedures / Inspect prior toeach transfer Barge PIC/Owner/OperatorPriming pot leaks/Strainer potgasket bad Training / Procedures / Inspect priorto each transferBarge PIC/Owner/OperatorCargoTanksLeaks to inner bottoms and voidhatches leak vapor whenchecked, not tightened, or bad/loose dogs / Leaks at vaporpenetrationsInspect tank tops annually / check for leaks in voids / test barge forvapor tightness annually (PIC checks before transfer and checkedduring annual inspection if equipped with vapor recovery system).Adapt preventative maintenance program based on experience/data. Owner/OperatorPin hole leaks in raised trunk ordeck areasInspect tank tops annually / check for leaks in voids / test barge forvapor tightness annually (PIC checks before transfer and checkedduring annual inspection if equipped with vapor recovery system).Adapt preventative maintenance program based on experience/data. Owner/Operator8CargoTankValvesPacking Gland Leaking (Manual /Mechanical)Inspect prior to each transfer / Tighten / Replace Packing (May InvolveShutting Down Transfer)Barge PICCargoTank SpillValvesImproper Gasketing MaterialUsed / Aged / DamagedConsider replacement of gasket material at established intervals;recommend at least every two years.Adapt preventative maintenanceprogram based on experience/data. Owner/OperatorBad O ringsPIC as part of the pre-transfer inspections verifies the spill valve has notleaked cargo or is not leaking vaporsBarge PICPressureReliefValvesImproper Gasketing MaterialUsed / Aged / DamagedConsider replacement of gasket material at established intervals;recommend at least every two years.Adapt preventative maintenanceprogram based on experience/data. Owner/OperatorPressure Relief Valve SettingIncorrectBench Test / Verify Setting / Confirm Labeling is Correct / Inspect duringshipyard periods. Adapt preventative maintenance program based onexperience/data. Owner/OperatorBad seats inside valveBench Test / Inspect during shipyardperiods. Adapt preventativemaintenance program based on experience/data.Owner/OperatorPressure Relief Valve IncorrectRating Verify manufacture labeling is correct and labeling is in placeOwner/OperatorCargoHeaderDrip Pans Residual Product Left in Drip PanDocks should develop a process to ensure no cargo is dropped in drippan or the product that is dropped is recovered prior to releasing thebarge Facility/DcckPICRust Buildup Trapping Cargo /VaporsDrip pans inspected and cleaned during shipyard periods at least everytwo years. Inspect each transfer and arrange for more frequent cleaningas needed/appropriate. Owner/OperatorConnect/disconnecting hoseallows product in drip panDocks should develop a process to ensure no cargo is dropped in drippan or the product that is dropped is recovered prior to releasing thebargeFacility/Dcck PICVapor DropPotential facility barge overpressurizationReduce rate of transfer so that negative pressure is maintained Facility/Barge PIC/Dock PIC9Vapor Growth too High for FacilitySystem to Remove Effectively Stop transfer until plan to handle vapors is establishedFacility/Barge PIC/Dock PICCargoVaporPressureCargo Contains Higher VaporPressure than on MSDSNotify customer / develop plan for discharging cargo / validate vaporpressure of cargo Facility/Barge PIC/Dock PICCargo Temperature (Summer)Causes Excessive Pressure (PVRelease) PVs are designed to relieve ifthis occurs Barge PIC monitorsValve Packing Leaks due toExcessive PressureTighten packing / consider mechanical seal for valve if packing is notproviding adequate sealingBarge PIC/Owner/OperatorFacilityLineEvacuationPigging/Blowing Cargo Pipelines(Vent Stack, Ullage, DomeRelease)Develop procedures to monitor and control pigging and blowing of cargopipelines and hoses to minimize releases and avoid cargo spillage. FaciltiyExcessiveLoadingRateLoading Rate ExceedsBarge/Facility Capabilities (VaporLeaks)Training - PIC should monitor pressureand control rate as appropriate.Ensure PIC is capable of determining and controlling loading rates / slowload rate or stop transfer Barge PIC/Dcok PIC/Owner/OperatorPVRV/spill valves open due toexcessive pressureTraining - PIC should monitor pressureand control rate as appropriate.Ensure PIC is capable of determining and controlling loading rates / slowload rate or stop transfer. Stop transfer until the pressure gets back intonormal limits. Commence loading at a slower rate. Barge PIC/Dock PICNitrogenIntroductionPremature PV Release - NoCompression of Nitrogen forCargo Vapor GrowthThis is primarily an issue with pressure barges - remove N2 if added atShipyard or transferring facilityFacility/Barge PIC/Dock PICVaporSystem Vacuum/pressure gauge leaksPIC inspects valves for leaks priorto transfer / ensure proper threatsealants are used Barge PICInternal/ExternalSteamLeaks through steam condensatelines to deckAir test steam coils during shipyard periods (annually). Adaptpreventative maintenance program basedon experience/data.Owner/Operator10CoilsSteam coils leak into innerbottom/wing voidsAir test steam coils during shipyard periods (annually). Adaptpreventative maintenance program basedon experience/data.Owner/OperatorInspection /GaugingInconsistent Methods - CFR NotEnforced / FollowedInspection Companies required to follow CFR's. If the cargo requiresclosed / restricted gauging, it should be closed sampled when possible.If barge has Hermetic tubes installed encourage the use of closedsampling/gauging for all cargoes when possible. PIC escort theinspector when possible.Inspection Company/Dock PIC/BargePIC/ Facility/Customer