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.us 
Texas 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 EIGHT-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 the 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 Source 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 the HGB Attainment Demonstration SIP 

Revision for the 1997 Eight-Hour Ozone Standard 

Appendix J Recommendations for Best Management Practices to Control and 

Reduce Inadvertent Cargo Vapor Emissions in the Tank Barge 

Community 
APPENDIX J 

RECOMMENDATIONS FOR BEST MANAGEMENT PRACTICES 

TO CONTROL AND REDUCE 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 regulations adopted by the Environmental Protection 

Agency (EPA) require each state to achieve attainment with National 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 reductions to meet NAAQS. Both Louisiana and 

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

Rouge, Lake Charles and New Orleans areas in Louisiana 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 meet 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 NAAQS 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, LDEQ and TCEQ have initiated demonstration 

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

develop reduction strategies. The 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 identifying a potential source or plume. To date, the 

technology does not speciate the chemicals or quantify concentrations. 

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

and observed emission events from barges, storage 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 attached 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 Chemical 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 commitment 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 about the AWO BMP matrix. CTAC will take the lead 

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

companies; 2) shipyard/cleaning 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 implementation in your organization. Please further this initiative by 

reviewing the operational best management practices and reiterating the commitment to reduce 

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

initiative in order to ensure the goals of the working group and state agencies are accomplished. 

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

industry has a long history of leadership in environmental protection. The industry believes that 

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

collaboration. In following this long tradition of leadership and proactively, 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. 

 
4

AREA / 

ITEM 

POTENTIAL ISSUE OF 

CONCERN PROPOSED BEST PRACTICE 

Vapor Vent Stack Discharging 

Check vacuum valve is working on P/V valve. Begin Discharge Initially, Then Open Vent Stack for Air Introduction Barge 

Discharging 

Keep all hatches closed, use sight glasses to monitor cargo, vapors introduced through the vent stack. Barge 

Loading through vent stack 

Keep all hatches closed, use sight glasses to monitor cargo, cargo vapor vented through vent stack. Barge 

Butter-Fly Valves, Sealing Problems, Potential Leaks 

If barge is equipped with butter-fly valves consider replacing with gate valves or full port ball valves as the valves need to be replaced. Barge 

Butterworth Hatches 

Improper Tightening of Dog Assemblies 

Remove Dog Assemblies, replace dogs with nuts as needed. (Ensure 

proper torque) Owne

Dog Assemblies Left Loose 

When possible, takes steps to avoid opening hatches or minimize emissions (i.e. load through vent stack using sight glasses, sample 

through ullage hatches or closed sampling devices, etc.). Consider procedure that restricts opening unless the barge is in a shipyard / repair facility. Owne

Improper Gasketing Material Used / Aged / Damaged 

Check and replace as necessary at each opening, and also at each yard stay. Ensure hatch is properly seated on closing. Adapt preventative maintenance program based on experience/data. Owne

Hatch Condition - Knife Edge Deteriorated 

Inspection at each opening. Clean surfaces. Consider retrofitting hatch with stainless rings. Owne

Ullage Hatches Opened / Closed Improperly 

Communicate obligations of proper closure and gauging for inspectors; when possible accompany inspector while on barge Inspe

Improperly Dogged / Tightened Down Training / Procedures InspeImproper Gasketing Material Used / Aged / Damaged 

Check and replace as necessary at each opening, and also at each yard stay. Ensure hatch is properly seated on closing. Adapt preventative maintenance program based on experience/data. Owne
5

Hatch Condition - Knife Edge Deteriorated 

Inspection at each opening. Clean surfaces. Consider retrofitting hatch with stainless rings. Barge 

Sight Glasses Cracked Sight Glass 

Training / Procedures to ensure the sight glasses are inspected once each transfer and cracked sight glasses are reported and replaced. Barge 

Gasketing Material Worn or Improperly Installed 

Inspection every transfer if transfer is under vapor and during shipyard periods. Adapt preventative maintenance program based on experience/data. Barge 

Wiper Mechanism Gasketing Material Deteriorated 

Inspection every transfer if transfer is under vapor and during shipyard periods. Adapt preventative maintenance program based on experience/data. Barge 

Incompatible Gasketing Material for Product 

Training / Procedures to ensure proper gasket selection, inspect during shipyard periods, inspect for leakage and other problems each transfer and report for repair as needed. Owne

Header Flanges (Blinds) No Gasketing Material Used 

Improve inspection protocol / Follow-up, Employee Training / Education / Procedures Owne

Improper Tightening of Bolts 

Reinforce appropriate method through education - Criss/Cross Method Enforced (Vessel / Facility) / Procedures Owne

Flange Face Surface Pitted / Scarred / Worn 

Implement internal inspection guidelines / reporting of deficiencies and replacement protocol, recommend the face be inspected whenever the flange is used and during shipyard periods. Adapt preventative maintenance program based on experience/data. Owne

Incompatible Gasketing Material for Product 

Training / Procedures to ensure proper gasket selection, new gasket whenever flange is used. Owne

Header Valve Seats Leaking 

Check valves that are used during the transfer and hose 

connection/disconnection, and report for repair as needed. Test during shipyard periods, at least annually. Adapt preventative maintenance program based on experience/data. Owne

Cargo Pump 

Deepwell Can Bleed Valve Open or Leaking Install closed bleeder system and / or spring loaded valves Owne
6

Cargo Pump Seal Leaking - Cavity Holding Product 

Recommend tandem seals on deepwell pumps for high hazard cargoes (CDC cargoes) Owne

Deepwell Stripping Plug Installed Improperly / Loose Recommend that this item be part of a pre-transfer inspection. Barge 

Expansion Dome Hatch 

Opened / Closed Improperly by Inspector 

Communicate obligations of proper closure and gauging for inspectors; when possible accompany inspector while on barge. Training / Procedures Inspe

Improperly Dogged / Tightened Down 

Communicate obligations of proper closure and gauging for inspectors; when possible accompany inspector while on barge. Training / Procedures Inspe

Improper Gasketing Material Used / Aged / Damaged 

Consider replacement of gasket material at established intervals; recommend at least every two years, or as required. Gasket should be inspected by PIC if hatch is opened. Adapt preventative maintenance program based on experience/data. Owne

Hatch Condition - Knife Edge Deteriorated 

Inspection every transfer if the hatch is opened and during shipyard periods. Consider retrofitting with stainless rings. Adapt preventative maintenance program based on experience/data. Barge 

Incompatible Gasketing Material for Product 

Training / Procedures to ensure proper gasket selection, inspection every transfer if the hatch is opened and during shipyard periods. Adapt preventative maintenance program based on experience/data. Owne

Restricted Gauge Tubes 

Gauge Tube Cap Improperly Installed / Loose/Missing 

Communicate obligations of proper closure and gauging for inspectors; when possible accompany inspector while on barge. Training / Procedures. Inspe

Gauge Tube Threads Damaged 

Inspection every transfer if the gauge tube is opened and during shipyard periods. Adapt preventative maintenance program based on 

experience/data. Barge 

Slop Tank 

Pressure Relief Valve Setting Incorrect 

Bench Test / Verify Setting / Confirm Labeling is Correct / Inspect during shipyard periods. Adapt preventative maintenance program based on experience/data. Verify leak-free during each transfer. Owne

Improperly Dogged / Tightened Down Operate as a closed system. Training Owne
7

Improper Gasketing Material Used / Aged / Damaged 

Consider replacement of gasket material at established intervals; recommend at least every two years. Adapt preventative maintenance program based on experience/data. Gasket should be inspected by PIC if hatch is opened. Owne

Hatch Condition - Knife Edge Deteriorated 

Inspection at each opening. Clean surfaces. Consider retrofitting hatch with stainless rings. Barge 

Sight Glass Cracked 

Training / Procedures to ensure the sight glasses are inspected once each transfer and cracked sight glasses are reported and replaced. Adapt preventative maintenance program based on experience/data. Barge 

Sight Glass Gasketing Material Used / Aged / Damaged 

Training / Procedures to ensure proper gasket selection, inspect during shipyard periods, inspect for leakage and other problems each transfer and report for repair as needed. Adapt preventative maintenance program based on experience/data. Owne

Cargo Stripping Pump Packing Gland Leakage Training / Procedures / Inspect prior to each transfer Barge 

System Valving Leaking / Incompatible Packing Training / Procedures / Inspect prior to each transfer Barge Blind Flanges/s loose/Threads on plugs bad/Deck stripping valves leak Training / Procedures / Inspect prior to each transfer Barge Priming pot leaks/Strainer pot gasket bad Training / Procedures / Inspect prior to each transfer Barge 

Cargo Tanks 

Leaks to inner bottoms and void hatches leak vapor when checked, not tightened, or bad/ loose dogs / Leaks at vapor penetrations 

Inspect tank tops annually / check for leaks in voids / test barge for vapor tightness annually (PIC checks before transfer and checked during annual inspection if equipped with vapor recovery system). Adapt preventative maintenance program based on experience/data. Owne

Pin hole leaks in raised trunk or deck areas 

Inspect tank tops annually / check for leaks in voids / test barge for vapor tightness annually (PIC checks before transfer and checked during annual inspection if equipped with vapor recovery system). Adapt preventative maintenance program based on experience/data. Owne
8

Cargo Tank Valves 

Packing Gland Leaking (Manual / Mechanical) 

Inspect prior to each transfer / Tighten / Replace Packing (May Involve Shutting Down Transfer) Barge 

Cargo Tank Spill Valves 

Improper Gasketing Material Used / Aged / Damaged 

Consider replacement of gasket material at established intervals; recommend at least every two years. Adapt preventative maintenance program based on experience/data. Owne

Bad O rings 

PIC as part of the pre-transfer inspections verifies the spill valve has not 

leaked cargo or is not leaking vapors Barge 

Pressure Relief Valves 

Improper Gasketing Material Used / Aged / Damaged 

Consider replacement of gasket material at established intervals; recommend at least every two years. Adapt preventative maintenance program based on experience/data. Owne

Pressure Relief Valve Setting Incorrect 

Bench Test / Verify Setting / Confirm Labeling is Correct / Inspect during shipyard periods. Adapt preventative maintenance program based on experience/data. Owne

Bad seats inside valve 

Bench Test / Inspect during shipyard periods. Adapt preventative maintenance program based on experience/data. Owne

Pressure Relief Valve Incorrect Rating Verify manufacture labeling is correct and labeling is in place Owne

Cargo Header Drip Pans Residual Product Left in Drip Pan 

Docks should develop a process to ensure no cargo is dropped in drip pan or the product that is dropped is recovered prior to releasing the barge Facil

Rust Buildup Trapping Cargo / Vapors 

Drip pans inspected and cleaned during shipyard periods at least every two years. Inspect each transfer and arrange for more frequent cleaning as needed/appropriate. Owne

Connect/disconnecting hose allows product in drip pan 

Docks should develop a process to ensure no cargo is dropped in drip pan or the product that is dropped is recovered prior to releasing the barge Facil

Vapor Drop 

Potential facility barge overpressurization Reduce rate of transfer so that negative pressure is maintained Facil
9

Vapor Growth too High for Facility System to Remove Effectively Stop transfer until plan to handle vapors is established Facil

Cargo Vapor Pressure 

Cargo Contains Higher Vapor Pressure than on MSDS 

Notify customer / develop plan for discharging cargo / validate vapor pressure of cargo Facil

Cargo Temperature (Summer) Causes Excessive Pressure (PV Release) PVs are designed to relieve if this occurs Barge Valve Packing Leaks due to Excessive Pressure 

Tighten packing / consider mechanical seal for valve if packing is not providing adequate sealing Barge 

Facility Line Evacuation 

Pigging/Blowing Cargo Pipelines (Vent Stack, Ullage, Dome Release) 

Develop procedures to monitor and control pigging and blowing of cargo pipelines and hoses to minimize releases and avoid cargo spillage. Facilt

Excessive Loading Rate 

Loading Rate Exceeds Barge/Facility Capabilities (Vapor Leaks) 

Training - PIC should monitor pressure and control rate as appropriate. 

Ensure PIC is capable of determining and controlling loading rates / slow load rate or stop transfer Barge 

PVRV/spill valves open due to excessive pressure 

Training - PIC should monitor pressure and control rate as appropriate. 

Ensure PIC is capable of determining and controlling loading rates / slow load rate or stop transfer. Stop transfer until the pressure gets back into normal limits. Commence loading at a slower rate. Barge 

Nitrogen Introduction 

Premature PV Release - No Compression of Nitrogen for Cargo Vapor Growth 

This is primarily an issue with pressure barges - remove N2 if added at Shipyard or transferring facility Facil

Vapor System Vacuum/pressure gauge leaks 

PIC inspects valves for leaks prior to transfer / ensure proper threat sealants are used Barge 

Internal/External Steam 

Leaks through steam condensate lines to deck 

Air test steam coils during shipyard periods (annually). Adapt preventative maintenance program based on experience/data. Owne
10

Coils 

Steam coils leak into inner bottom/wing voids 

Air test steam coils during shipyard periods (annually). Adapt preventative maintenance program based on experience/data. Owne

Inspection / Gauging 

Inconsistent Methods - CFR Not Enforced / Followed 

Inspection Companies required to follow CFR's. If the cargo requires closed / restricted gauging, it should be closed sampled when possible. If barge has Hermetic tubes installed encourage the use of closed sampling/gauging for all cargoes when possible. PIC escort the inspector when possible. 

InspePIC/