### MEMORANDUM

DATE: September 11, 2010

SUBJECT: Documentation of Contacts with State Agencies and Facilities Residual Risk Modeling for the Marine Tank Vessel Loading Operations Source Category
EPA Contract No.: EP-D-06- 118; EPA Project No.: 4-15 RTI Project No.: 0210426.004.015

FROM: Karen Schaffner, RTI International

TO: Stephen Shedd and Mary Tom Kissell, EPA

I. Introduction

This memorandum lists contacts to state agen cies and facilities in confirming operating and applicability for marine vesse l loading facilities. This information was used to inform the risk and technology review project for th e marine vessel loading source category.

II. References

Emails from state agencies, state inspectors, and facilities :

Email, P. Siler, TransMontaigne, to K. Sc haffner, RTI. TransMontaigne Products Fort Lauderdale FL input on MVL que stions. Dated June 2, 2010.

Email, W. Fusilier, Plains All American Pipeli ne, to K. Schaffner, RTI. Ingleside Transfer Ingleside TX input on MVL questions. Dated June 1, 2010.

Email, J. Scroggins, TPC Group, to K. Schaffn er, RTI. TPC Group Houston TX input on MVL questions. Dated May 26, 2010.

Email, M. Herman, Chevron, to K. Schaffner, RT I. Chevron Pipe Line Nederland TX input on MVL questions. Dated May 14, 2010.

Email, Z. Smith, KinderMorgan, to K. Schaffner, RTI. Delta Terminal Services Harvey LA input on MVL questions. Dated May 13, 2010.

Email, J. Rhodes, TCEQ, to K. Schaffner, RTI. Ingleside Transfer Facili ty Ingleside TX input on MVL questions. Dated May 12, 2010.

Email, R. Mann, NJ DEP, to K. Schaffner, RTI. St. Linden Terminal St. Linden NJ input on MVL questions. Dated May 4, 2010.

### Email, Z. Smith, KinderMorgan, to K. Schaffner, RTI. Delta Terminal Services Harvey LA input on MVL questions. Dated May 4, 2010.

Emails sent to state agencies, state inspectors, and facilities :

Email, K. Schaffner, RTI, to W. Fusilier, Plains Marketing Ingleside Term inal. Plains Marketing Ingleside questions on marine vessel loading terminal. Dated May 25, 2010.

Email, K. Schaffner, RTI, to P. Siler, Tran sMontaigne. TransMontaign e Fort Lauderdale FL 2005 NEI/NATA dataset. Dated May 24, 2010.

Email, K. Schaffner, RTI, to C. Harris, KinderMorgan. KinderMorgan Galena Park TX 2005 NEI/NATA dataset. Dated May 19, 2010.

Email, K. Schaffner, RTI, to J. Scroggins, TPC Group. TPC Houston TX questions on marine vessel loading terminal. Dated May 18, 2010.

Email. K. Schaffner, RTI, to G. Moore, Mara thon Petroleum. Marathon Petroleum Clarksville IN questions on marine loading terminal. Dated May 17, 2010.

Email, K. Schaffner, RTI, to M. Herman, Chevron. Chevron Nederland TX 2005 NEI/NATA dataset. Dated May 12, 2010.

Email, K. Schaffner, RTI, to J. Rhodes, TCEQ. Ingleside Transfer Faci lity questions on MVL terminal. Dated May 11, 2010.

Email, K. Schaffner, RTI, to N. Richard, TCEQ . Chevron Unocal Nederland TX questions on MVL terminal. Dated May 7, 2010.

Email, K. Schaffner, RTI, to L. Patak, TCEQ , Texas Petrochemical Houston TX questions on MVL terminal. Dated May 6, 2010.

Email, K. Schaffner, RTI, to J. Meyer and R. Mann, NJDEP. St. Linden Terminal Linden NJ questions on MVL terminal. Dated May 3, 2010.

Email, K. Schaffner, RTI, to J. Reed, Louisiana. Delta Terminal Services Harvey LA questions on MVL terminal. Dated May 3, 2010.

Email, K. Schaffner, RTI, to S. Keown, IDEM. Marathon Petroleum Clarksville IN questions on MVL terminal. Dated April 30, 2010.1 

### Schaffner, Karen S.

From: PSiler@transmontaigne.com Sent: Wednesday, June 02, 2010 10:30 AM To: Schaffner, Karen S. Cc: Shedd.Steve@epamail.epa.gov; KBernard@transmontaign e.com; DHall@transmontaigne.com; DTarlton@transmontaigne.com ; TJordan@transmontaigne.com Subject: Re: RTR MVL: questions on FL TransMontaigne MVL te rminal

Hello Karen,

In regard to you previously provided questions, pleas e see our responses below in red.

Please let me know if you have any additional question prior to the visit on June 18th.

Sincerely,

Paul Siler, P.E. Air Quality Compliance Manager

TransMontaigne Products Services, Inc. 1670 Broadway, Suite 3100 P.O. Box 5660 Denver, CO 80217-5660 phone (303) 626-8209 fax (303) 626-8238 psiler@transmontaigne.com

From: "Schaffner, Karen S." <ksschaffner@rti.org>

To: <psiler@transmontaigne.com>

Cc: <Shedd.Steve@epamail.epa.gov>

Date: 05/24/2010 03:03 PM Subject: RTR MVL: questions on FL TransMontaigne MVL termin al

Good Afternoon, Paul: Am sending some questions on the TransMontaigne Terminals, LLC - Port Everglade s North Terminal. I reviewed some available permit information (TransMo ntaigne Terminals, LLC - Port Everglades North Term inal. Permit No.: 0110069-019-AV. Issued 1 Sept 2005) and contacted the local agency. As I mentioned, I am working on the Residual Risk project for the Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I am working with Steve Shed d at U.S. EPA/OAR/OAQPS/SSPD in Research Triangle Park, NC.

I included my basic questions below, and following review of the permit, I filled in the information f ound in the permit. I still I have a few questions. Any additional information you coul d provide would be much appreciated. Thank you, Ka ren Schaffner

1. Is the facility a Major source for HAP?2

Our current potential to emit, based on federally e nforceable permit limits, reflect that the facility is not a major source for

HAPs.

2. Are MVL operations conducted at the facili ty? (loading of MVL, either tanker ships or barges; not un loading)

Yes.

3. What are the HAP emissions in ton/yr from just MVL operations?

Permit files show potential to emit HAP emissions f rom Barge Loading of 3.84 ton HAP. EPA’s 2005 NEI/ NATA database shows 1.97 ton/yr total HAP from MVL. Emissions from gasoline (including ethanol) loading are calculated using t he federally enforceable emission limit of 35 mg/l of gasoline loaded. Emis sions from distillate (which includes 6 oil, diesel and biodiesel) and crude loading are calculated per AP-42, Section 5.2 utilizing a 0 % control efficiency.

4. Subject to 40 CFR part 63, subpart Y, Mari ne Vessel Loading NESHAP? - (Existing sources) Emission reduction re quirements (i.e., control device) if MVL emissions are >10/25 tons HAP? - (Existing sources) Recordkeeping to conf irm MVL emissions are <10/25 tons HAP? - (New sources) Emission reduction require ments (i.e., control device) at all levels of MVL e missions?

Permit indicates that throughput limits on gasoline and crude oil exempt the facility from subpart Y R ACT requirements. TransMontaigne has provided correspondence to the Broward County Pollution Prevention, Remediation an d Air Quality Division clarifying that the marine vessel loading operation s are an existing source with emissions less than 1 0 and 25 tons because of the
definition of Source in Subpart Y. Source is defined in Subpart Y as "any location where at l east one dock or loading berth is bulk loading onto marine tank vessels...". Based on thi s definition, construction of gasoline loading oper ations at berth 6 and decommissioning operations at berth 7 would not tri gger a new source date. As such, the marine vessel loading operations are exempt from the MACT emission standards in 63.562 ( b) and (d), however, operations are still subject t o recordkeeping requirements of 63.567(j)(4) and emission estimatio n requirements of 63.565(1).

5. What kind of emissions control device is u sed? How much of emissions are vented to control d evice? Are there commodities
that are not covered?

Permit indicates that a Marine VRU (Carbon Adsorpti on unit) is used to control all gasoline loading em issions at Berth 6. Control of marine vessel loading operations by a carbon adsorp tion/absorption unit was originally permitted on De cember 10, 1997. I believe the control device was permitted in order to remain below the 10 and 25 ton MACT threshold in Subpart Y. On December 17, 2007 TransMontaigne received a permit to construct (0110 069-016-AC) a new marine VRU at Berth 6 and decommi ssion operations at Berth 7. This construction permit required use of a VRU to control emissions during loading of gasol ine per Rule 62-296.320(1)(a), F.A.C. Additionally, emissions are required to be controlled to a maximum of 35 mg/l of gasoline load ed. This condition is reflected in our current Title V Operating Permit. By permit , TransMontaigne is required to utilize the VRU dur ing all gasoline loading of
marine vessels. Distillate and crude are allowed t o be loaded without use of a control device. Gasol ine (including ethanol), distillate (which includes 6 oil, diesel and biodiesel) and cr ude are the only products loaded onto marine vessel s.

6. Is submerged fill used? Is the marine ves sel (tanker ship or barge) fitted with submerged fi ll, or is it part of the loading berth/loading arm?

The terminal connects via piping to the marine vess el through our petroleum transfer hoses. The conne ction is made to the marine
vessels manifold which is located on its deck. Onc e the product enters the manifold, the TransMontaig ne Terminal is no longer in custody of that product. It becomes subject to Coa st Guard regulations for the marine vessel. As the Terminal has no involvement with the marine vessels loading after the manifold, we cannot answer whether the vessel utilizes subme rged or bottom loading.

7. Possible to identify the inspector who has visited the site and get their contact information ?

Elizabeth Susky at (954) 519-1430

Karen Schaffner Air Quality Engineering Group3

RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Warren D Fusilier [wdfusilier@paalp.com] Sent: Tuesday, June 01, 2010 5:38 PM To: Schaffner, Karen S. Cc: Shedd.Steve@epamail.epa.gov; Rebecca E Esparza; Daniel K Bennett Subject: RE: RTR MVL: questions on TX Ingleside Transfer Fa cility MVL terminal

Karen, please see below for answers to your question s. Rebecca Esparza, Air Quality Compliance Specialist i n our corporate office, and who is familiar with our Ingles ide facility provided the data. I have copied Rebecca o n this reply to keep her in the loop. Let us know if you have any add itional questions.

Warren D. Fusilier Director Environmental and Regulatory Compliance, GC Plains All American Pipeline, LP 333 Clay Street, Suite 1600 Houston, Texas 77002 Office - 713-646-4515 Cell - 713-201-3911 Fax - 713-646-4310 Rightfax - 713-289-7621

From: Schaffner, Karen S. [mailto:ksschaffner@rti.org] Sent: Tuesday, May 25, 2010 1:12 PM
To: Warren D Fusilier Cc: Shedd.Steve@epamail.epa.gov Subject: RTR MVL: questions on TX Ingleside Transfer Facili ty MVL terminal

Good Afternoon, Warren: As I mentioned, I am worki ng on the Residual Risk project for the Marine Vess el Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I a m working with Steve Shedd at U.S. EPA/OAR/OAQPS/SS PD in Research Triangle Park, NC. I am sending on some q uestions on the Ingleside Transfer Facility, Ingles ide TX. I found some permit information in a voided permit document : Voided Federal Operating Permit, Plains Marketin g L.P., Ingleside Transfer Facility. Permit No. O2761. Is sued May 5, 2005.

I included my basic questions below, and following review of the Voided Title V permit and some talks with the state agency and the state inspector, I filled in the inf ormation found in the permit. Please review and ma ke corrections to any of the statements below as needed. It sounded like the Ingleside Transfer Facility merged with an other facility, possibly the Ingleside Petroleum Terminal on Sunray Road, so not certain if the information in the voi ded permit would still be correct for the merged facility. Any addi tional information you could provide would be much appreciated. Thank you, Karen Schaffner

1. What is the current facility name and who owns the facility, i.e., still Plains Marketing LP? The faci lity was previously called Plains Marketing, Ingleside Trans fer Facility, located at E. OF INGLESIDE @ BISHOP R D. & INTERCOASTAL CANAL, Ingleside TX but is thought to have merged with another facility.

Answer **-** Owner: **Plains Marketing, L.P.** - Facility name: I ngleside Terminal Previously Ingleside Terminal and Ingleside Dock (o r transfer facility) were permitted separately. They are not co-located but are connec ted by a one-mile pipeline and function as a single facility, and have been merged into a single permitted entity.2

2. Is the facility a Major source for HAP?

No, the facility is not a major sou rce for HAP. J. Rhodes, TCEQ : Based on the current information we have on this facility, this is correct. Question : Confirm whether the whole, current facility is a major source for HAP, including MVL operations and other operations that occur at t he facility.

Answer - No, the whole, current facility is not a major so urce of HAPs. Facility-wide total HAP PTE is 3.47 tpy.

3. Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes. The site has an emission unit c alled “Dock”. J. Rhodes, TCEQ: Based on the information we have on this facility, this is correct. There are three emissio ns points (EPNs) located at the Ingleside Transfer Facility: EPN DOCK, EPN TANK1, and EPN FUG2. EPN TANK1 is a vertical fixed -roof storm water tank. Barge Loading: EPN DOCK a nd Fugitive Sources (EPN FUG2) are permitted by rule, 30 Texas Administrative Code §106.261. Per the Technical Re view dated 2/4/2008, estimated emissions for EPN DOCK we re listed as 3.82 lb/hr and 1.68 tpy. Estimated em issions for EPN FUG2 were listed as 0.06 lb/hr and 0.24 typ. Quest ion : Confirm the marine vessel loading operations.

Answer: - Yes, Ingleside Terminal has a dock where MVL of barges only is conducted

4. What are the HAP emissions in ton/yr from just MVL operations?

Permit did not mention what the level of HAP emissi ons from MVL only are. EPA’s 2005 NEI/NATA databas e indicates emissions are 3.4 ton/yr total HAP from M VL (this was from the Ingleside Transfer Facility). J. Rhodes, TCEQ : The most recent emissions estimate we have in our r egional office is the 2008 Contaminant Summary Repo rt. Total site emissions, as reported by the regulated entity, for 2008, consisted of 0.0638 ton/yr VOC (unclassifie d) 0.00 ton/yr HAPS were reported. Question : What are the HAP emissions from the MVL operatio ns only?

Answer: - Products loaded at the dock ar e No. 6 fuel oil and No. 4 fuel oil. PTE for HAP emissions from MVL is estimated at 0.311 tpy, total HAPs.

5. Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

Voided Permit includes a Permit Shield. The facili ty is not subject to subpart Y because it is not a major source. The facility is not subject to MACT controls, recor dkeeping, or RACT. J. Rhodes, TCEQ : Based on the current information we have on this facility, this is correct. Questio n : Confirm whether the facility is subject to subpa rt Y, i.e., confirm whether the facility has MVL emissions >10/25 ton H AP and is required to control HAP emissions under s ubpart Y, or whether the facility has MVL emissions <10/25 ton H AP and is required to conduct recordkeeping under s ubpart Y?

Answer: - Facility is not subject to sub part Y. It is exempted per 63.560(d). The facilit y stores and loads No. 6 fuel oil and No. 4 fuel oil (jet kerosene). These products have vapor pressures well below the 1.5 psia limit specified in 63.560(d).

6. What kind of emissions control device is used? How much of emissions are vented to control device? A re there
commodities that are not covered?3

No information on whether there are emission contro ls in place. J. Rhodes, TCEQ : In reviewing TCEQ files, she did not find any record of an emissions control dev ice used to control emissions from marine vessel lo ading. Question : Could you confirm whether there is an emissions con trol device that controls marine vessel loading emi ssions from the dock. Why was the emission control device put in p lace? Is the emissions control device considered f ederally enforceable? Are the marine loading emission from all commodities vented to the control device, or ar e only certain
commodities vented? Which commodities?

Answer - There is no emission control d evice that controls MVL emissions from the dock.

7. Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?

Permit does not mention submerged l oading. J. Rhodes, TCEQ : In reviewing TCEQ files, she did not find any record of what type of fill is used to load the shi p/barge. Question : Does submerged loading occur, and if so, is it f itted onto the vessel or part of the loading berth/arm?

Answer - Yes, submerged fill is used. The barges are fitted with submerged fill piping. It is not part of the loading arm.

8. Possible to identify the inspector who has visited the site and get their contact information?

Jessica Rhodes at (361) 825 3388

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Scroggins, James E. [James.Scroggins@tpcgrp.com] Sent: Wednesday, May 26, 2010 7:02 PM To: Schaffner, Karen S. Cc: Shedd.Steve@epamail.epa.gov; Chu, Celia; Boyer, Robe rta M. Subject: FW: RTR MVL: questions on Texas Petrochemical MVL t erminal

Karen,

We are still working on a couple of your questions but I thought I would pass on what we have so far a nd I need to ask a question. Our responses are added to your question s.

Question : Are these emission estimates correct? I f not, could you confirm what the actual HAP emissio ns from marine vessel loading only were for 2005, and perhaps for 2009 as well?

Response: We are reviewing the data you sent and t here does seem to be some discrepancies. I will co ntact you
tomorrow to discuss them.

Question : Could you confirm whether the facility has MVL e missions >10/25 ton HAP and is required to control HAP emissions under subpart Y, or whether the facility has MVL emissions <10/25 ton HAP and is required to conduct recordkeeping under subpart Y?

. Could you confirm whether each dock is subject to s ubpart Y controls or subpart Y recordkeeping?

Response: TPC’s dock has MVL emissions <10/25 ton HAP, thus, so we are only subject to recordkeeping requirement. MVL emissions from Dock A and B, collectively, are below the <10/25 threshold.

Question : Is the Marine Loading Flare an open flare or an enclosed flare? What was the reason the MVL emissi ons are vented to the Marine Loading Flare – was the flare installed and the MVL emission s vented to comply with a state rule or
a Federal rule? Is the emission control device con sidered federally enforceable? Could you also conf irm what type of control device each of the C-5-A1, C-5-A2, and C-5- P2 has, and the control efficiency achieved for HAP MVL emissions? Are the marine loading emissions from all commodit ies vented to the control device, or are only certa in commodities at
each dock vented? Which commodities?

Response: The flare is an open flare. TPC volunta rily installed the flare to reduce VOC emissions be cause there were no federal or state rules that require such control at that time (1995). The dock flare is authorized b y Permit No. 22052 and has been incorporated in TPC’s Title V Operatin g Permit. Our current Title V permit does not ref erence operating scenarios C-5-A1 or C-5-A2. The only operating sc enario in the Title V permit is C-5-P, which lists the dock flare as the control device and we only have one operating scena rio that we use. Can you forward to us a descripti on on the these scenarios and the date on the permit you are review ing? MTBE and DIB loadings are controlled by the dock fl are, shared by Dock A and B. Vapor associated with all other c ommodities loadings are controlled by the plant fla re.

Question : Does submerged loading occur, and if so, is it f itted onto the vessel or part of loading berth/arm?

Response: Our loading arms flange to piping coming from the barge or ship so we are not familiar with the internal configurations of the vessels. This seems to be a moot point in our case since we are u sing the flare for all unpressurized loading and there are no vents for pressurized load ing.

I hope this helps. I will call tomorrow to follow up on the emissions totals and to see if we can cle ar up the question relating to loading scenarios.2 Regards,



### James Scroggins
TPC Group, LLC Manager EHSS Houston Plant
Phone: 713-740-4236 Mobile: 281-352-2200 Fax: 713-475-5208 E-Mail: James.Scroggins@tpcgrp.com1 

### Schaffner, Karen S.

From: Herman, Michelle L [Michelle.Herman@chevron.com] Sent: Friday, May 14, 2010 9:23 AM To: Schaffner, Karen S. Cc: Shedd.Steve@epamail.epa.gov Subject: RE: questions on TX Unocal MVL terminal



### Michelle Herman Environmental Specialist

Chevron Pipe Line Company Highway 366, P.O. Box 237 Nederland, TX 77627

Tel 409 724 3321 Mobil 409 651 0708 Fax 409 724 3254 Michelle.Herman@chevron.com

From: Schaffner, Karen S. [mailto:ksschaffner@rti.org]
Sent: Wednesday, May 12, 2010 8:36 AM
To: Herman, Michelle L Cc: Shedd.Steve@epamail.epa.gov Subject: questions on TX Unocal MVL terminal

Good Morning, Michelle: As I mentioned on the phon e, I am working on the Residual Risk project for th e Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I am working with Steve Shedd at U.S. EPA/OAR/OAQPS /SSPD in Research Triangle Park, NC. Steve and I have revie wed the facility permit but do have a few remaining questions. **Union Oil Company of California (Unocal), Beaumont Termin**  **al, Permit No. O1025, Issued February 4, 2008**

.

I included my basic questions below, and following review of the permit, I filled in the information f ound in the permit. Any additional information you could provide to hel p answer the remaining questions would be much appr eciated. Thank you, Karen Schaffner

1. Is the facility a Major source for HAP?

No information in the permit on whether major or ar ea for HAP emissions. Likely are major for HAP since facility is subject to subpart Y. Question : Could you confirm whether the facility is a majo r source for HAP, an area source, or a minor source?

Major source for HAP’s.

2. Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes, the facility conducts marine vessel loading. There are 3 marine loading docks: (1) main ship/b arge loading dock (ML255), (2) No.2 Crude Dock (SPR dock), and ( 3) No.3 Crude Barge dock (FLBD3).2

We currently do not load at the (3) No.3 Crude Barg e dock (FLBD3); however, we are authorized to condu ct loading at that dock. We can also conduct unloading operatio ns at all three docks.

3. What are the HAP emissions in ton/yr from just MVL operations?

__ ton/yr total HAP from MVL. Question : Could you confirm what the actual HAP emissions fro m marine vessel loading only are?

108 ton/yr HAP for 2009. This amount will vary depe nding on commodities loaded.

4. Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

Permit indicates the facility is subject to subpart Y, for both MACT and RACT. It is not clear whethe r an emission control device is in place for each dock. Question : Coul d you confirm whether the facility has MVL emission s >10/25 ton HAP and is required to control HAP emissions under subpart Y, or whether the facility has MVL emission s <10/25 ton HAP and is required to conduct recordkeeping under subpart Y?

MVL emissions are >10/25 ton and we are required to control HAP emissions under subpart Y.

5. What kind of emissions control device is used? How much of emissions are vented to control device? A re there commodities that are not covered?

Permit mentions emissions control devices SPR901 an d SPR902 (thermal oxidizers). It is not clear whet her these devices are for the SPR crude dock only, or w hether the other marine loading docks are also vent ed to them.
Question : Could you confirm whether there is an emissions control device that controls marine vessel loading emissions from each berth/dock? Why was the emissi on control device put in place? Is the emission co ntrol device considered federally enforceable? Are the marine l oading emissions from all commodities vented to the control device, or are only certain commodities at each dock vented ? Which commodities?

The control device is used for loading operation at dock 1 and 2. As mentioned in question 2, we do n ot load at dock 3. The control device was installed to comply with subpart Y. The emission control device is fed erally enforceable under the state New Source Review program. All com modities that contain HAP’s with greater than .01 p sia vapor pressure or have a vapor pressure of greater than . 05 psia are controlled.

6. Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?

Permit does not mention submerged loading or bottom loading. Question : Does submerged loading or bottom-loading occur, and if so, is it fitted onto the vessel or part of loading berth/arm?

The marine vessel is fitted with submerged fill and is inspected prior to loading to ensure proper ope ration.

7. Possible to identify the inspector who has visited the site and get their contact information?

Neadra Richard at (409) 898 3838



### Michelle Herman Environmental Specialist3 

### Chevron Pipe Line Company Highway 366, P.O. Box 237 Nederland, TX 77627
Tel 409 724 3321
Mobil 409 651 0708

Fax 409 724 3254 Michelle.Herman@chevron.com

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Smith, Zach - Lower River Region [Zach_Smith@kindermor gan.com] Sent: Thursday, May 13, 2010 12:53 PM To: Schaffner, Karen S. Cc: James.Reed@LA.GOV; Shedd.Steve@epamail.epa.gov Subject: RE: RTR MVL: KinderMorgan Delta Terminal Services, Harvey Facility

The flare is associated with our storage tank 2000- 1. It is currently being installed and
will be available for control of emissions from mar ine vessel loading if needed. Because we are currently storing a material in tank 2000- 1 that does not have a vapor pressure >1.5 psia at loading conditions, no control requirement appli es and we will not use the flare to
control these emissions.

Let me know if you need further information.

Zach

Zach Smith Sr. EHS Specialist, Lower River Region Kinder~Morgan Terminals

225-603-5907

________________________________ From: Schaffner, Karen S. [ksschaffner@rti.org] Sent: Wednesday, May 12, 2010 5:00 PM To: Smith, Zach - Lower River Region Cc: James.Reed@LA.GOV; Shedd.Steve@epamail.epa.gov Subject: RTR MVL: KinderMorgan Delta Terminal Servi ces, Harvey Facility

Good Afternoon, Zach: I have one additional questi on about the Harvey facility with respect to your note that “We are installing a flare which will be available to control emissions from marine loading in the future. This is primari ly to ensure that we remain a synthetic minor source of VOC emissions.” Could you expand a bit on the plans for this flare with respect to marine vessel loading, meaning that whil e you say it is “available” to control emissions from marine loading, will it be hooked up or connected to destroy captured marine vessel loading vapors?

Thank you, Karen

Karen Schaffner Air Quality Engineering Group
RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Jessica Rhodes [JRhodes@tceq.state.tx.us] Sent: Wednesday, May 12, 2010 1:42 PM To: Schaffner, Karen S. Cc: Shedd.Steve@epamail.epa.gov; David Kennebeck; Rosario Torres Subject: Re: RTR MVL: questions on TX Ingleside Transfer Fa cility MVLterminal Attachments: 2008 Emissions Sum.pdf; TR-PBR Ingleside Transfer.p df; Photographs.pdf; Process Flow Diagram.pdf

Ms. Schaffner and Mr. Shedd,

Attached is the information gathered this morning i n order to answer the questions you had on Inglesid e Transfer Facility MVL Terminal. I wanted to clarify that I have not visited this site, however I did search th rough our regional files to try and answer your questions. My answers are indicated in [Red].

A little background on the site: The last investig ation conducted on the facility was an in-office in vestigation, conducted May 26, 2009, to review reported instance s of Title V deviations and to verify compliance wi th their Title V Permit. The last on-site visit was conducted on Ma rch 22, 2007 and that lead investigator is no longe r with The Agency.

Plains Marketing, L.P. - Ingleside Petroleum Termin al (and Transfer Facility) Regulated Entity Number: RN102770690 Air Account No. SD-0035-R

If you have any further questions, please feel free to give me a call.

Thanks,
Jessica

Jessica Rhodes Air Section Environmental Investigator Texas Commission on Environmental Quality (TCEQ) Re gion 14 NRC Building, Suite 1200 6300 Ocean Drive, Unit 5839 Corpus Christi, TX 78412-5839 361.825.3388 phone 361.825.3101 fax 

##  Please consider whether it is necessary to print th is e-mail

>>> "Schaffner, Karen S." <ksschaffner@rti.org> 5/1 1/2010 3:50 PM >>> Good Afternoon, Jessica: As I mentioned, I am work ing on the Residual Risk project for the Marine Ves sel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I a m working with Steve Shedd at U.S. EPA/OAR/OAQPS/SS PD in Research Triangle Park, NC. I am sending on some q uestions on the Ingleside Transfer Facility, Ingles ide TX.

I included my basic questions below, and following review of the Voided Title V permit, I filled in th e information found in the permit. I still I have a few questions. An y additional information you could provide would be much appreciated. Thank you, Karen Schaffner

1. Is the facility a Major source for HAP?

No, the facility is not a major source for HAP. Based on the current information we have on this facility, this is

correct.

2. Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)2

Yes. The site has an emission unit called “Dock”. Based on the information we have on this facility, this is
correct. Attached is the Technical Review for Air Permit by Rule (Attachment TR-PBR). There are thre e emissions points (EPNs) located at the Ingleside Transfer Fac ility: EPN DOCK, EPN TANK1, and EPN FUG2. EPN TANK 1 is a 210 bbl vertical fixed-roof storm water tank. Barge Loadi ng: EPN DOCK and Fugitive Sources (EPN FUG2) are pe rmitted by rule, 30 Texas Administrative Code §106.261. Per the Tech nical Reivew dated 2/4/2008, estimated emissions fo r EPN DOCK were listed as 3.82 lb/hr and 1.68 tpy. Estimated emissions for EPN FUG2 were listed as 0.06 lb/hr an d 0.24 typ. Process Diagram is attached (Attachment: Process Di agram)

3. What are the HAP emissions in ton/yr from just MVL operations?

__ ton/yr total HAP from MVL. Question : What are the HAP emissions from the MVL operatio ns only? The most recent emissions estimate we have in our regio nal office is the 2008 Contaminant Summary Report. Total site emissions, as reported by the regulated entity, for 2008, consisted of 0.0638 ton/yr VOC (unclassifie d) 0.00 ton/yr HAPS were reported (see attachment: 2008 Em issions Sum). The Air Quality Division - Emissions Assessment Section may have a more recent (and detailed) repor t of annual emissions.

4. Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

Voided Permit includes a Permit Shield. The facili ty is not subject to subpart Y because it is not a major source. The facility is not subject to MACT controls, recor dkeeping, or RACT. Based on the current information we have on this facility, this is correct.

5. What kind of emissions control device is used? How much of emissions are vented to control device? A re there commodities that are not covered?

No information on whether there are emission contro ls in place. Question : Could you confirm whether there
is an emission control device that controls marine vessel loading emissions from the dock. Why was th e emission control device put in place? Are the marine loadin g emission from all commodities vented to the contr ol device, or are only certain commodities vented? Which commodities ? In reviewing our files, I did not find any record o f an emissions
control device used to control emissions from marin e vessel loading.

6. Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?

Permit does not mention submerged loading or bottom loading. Question : Does submerged loading or bottom-loading occur, and if so, is it fitted onto the vessel or part of the loading berth/arm? In reviewing our files, I did not find any record of what type of fill is used to load the ship/barge. During the onsite investigat ion on March 22, 2007 two photographs were taken of loading operatio ns (see attachment: photographs).

7. Possible to identify the inspector who has visited the site and get their contact information?

Jessica Rhodes at (361) 825 3388 I have not visited this site; however, in reviewing our files, I was able to gather the information indicated in [red].

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Robert Mann [Robert.Mann@dep.state.nj.us] Sent: Tuesday, May 04, 2010 7:55 AM To: Schaffner, Karen S. Subject: Re: RTR MVL: questions on NJ MVL facility

I'll try to answer your questions with the limited knowledge that I have of the past history of the site. Response are in CAPS below

Bob

>>> "Schaffner, Karen S." < ksschaffner@rti.org > 5/3/10 >>> Good Afternoon, Bob and Jeff: I am working on the Residual Risk project for the Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, s ubpart Y). I am working with Steve Shedd at U.S. EPA/OAR/OAQPS/SSPD in Research Triangle Par k, NC. We are looking at the ST Linden Terminal, LLC at Ft of South Avenue in Linden NJ.

Thank you Bob for directing me to the permit for th e St Linden Terminal LLC Shoreside Facility in Linden City NJ. Looked at: ST Linden Terminal LLC Shoreside Facility, at 4501 Tremley Po int Rd in Linden City NJ, Air Pollution Control Operating Permit, Minor Modification and Pr econstruction Approval. Permit Activity Number: BOP090002. Program Interest Number: 4180 0. Initial Approval Dated September 29,

2003.

Am sending my basic questions below. I reviewed th e permit information and filled in the information found in the permit. I still have a fe w questions. Any additional information you could provide would be much appreciated. Feel free to call or send notes. Thank you,
Karen Schaffner

Is the facility a Major source for HAP? NO

Permit indicates the facility's PTE HAP is 0.243 ton/yr. I assume this is considering emissions controls. Q uestion: The permit does not state
whether it is an area source for HAP or whether it is a synthetic minor for HAP. Could you
confirm? THERE IS NO "AREA" SOURCE FOR MARINE LOAD ING

Conducts MVL operations? (loading of MVL, either t anker ships or barges; not unloading)

Yes, conducts MVL. There are throug hput limits and emission rate limits,
based on VOC.2 What are the HAP emissions in ton/yr from just MVL operations?

Loading emissions PTE is 0.243 ton/y r HAP. The MVL emissions limit for Benzene is <=0.243 ton/yr benze ne. There are several MVL limits: <=27.05 ton/yr total VOC emiss ions; <=420,00 gal/hr total material transferred; <=35.02 lb/hr total VOC max emission r ate.

Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP? NO

- Emission reduction requirements (i.e., c ontrol device) if MVL emissions are >10/25 tons HAP? CARBON ABSORPTION U NIT

- Recordkeeping to confirm MVL emissions a re <10/25 tons HAP? VOC CONCENTRATION

CEMS

There is no mention of subpart Y. Question: Is th e facility subject? NO If synthetic minor due to federally enforceable throughputs or emissio n limits, what year did the facility become a synthetic minor, i.e., before the subpart Y compliance date in 1999? FACILITY

STOPPED PROCESSING MTBE WHICH WAS THE SOURCE OF HAP S WHEN THE MARINE LOAIDNG WAAS INSTALLED
IN 1990.

What kind of emissions control device is used? How much of emission are vented to control
device? Are there commodities that are not covered ?

Permit states that Loading of Petro leum Hydrocarbon liquids and loading of VOC liquids (vp <=11.1 psia) must be directed to CD1 Carbon Adsorption system, that achieves a VOC C ontrol Efficiency of 95% by wt. For Loading of VOC liquids (with vp <=0.02 psia) withou t the control device, permit limits VOC total emissions to <=6.72 lb/hr max emission rate; and limits total material transferred to <=504,000 gal/hr maximum transfer rate.

Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading ar m?

Permit does not mention use of subm erged loading or bottom-filling. Question: Does submerged loading or bottom-loading occur, and if so, is it fitted onto the vessel or is it part of loading berth/arm? SUBMERG ED FILL FOR MARINE LOADING IS NOT
REGULATED IN NEW JERSEY. EMISSIONS MUST BE CONTROL LED3 Possible to identify the inspector who has visited the site and get their contact
information?

Jeff Meyer, at (973) 656 4084

Karen Schaffner

Air Quality Engineering Group

RTI International

3040 Cornwallis Rd (800 Park, C311)

Research Triangle Park, NC 27709

phone: (919) 316 3740

fax: (919) 541 71551 

### Schaffner, Karen S.

From: Smith, Zach - Lower River Region [Zach_Smith@kindermor gan.com] Sent: Tuesday, May 04, 2010 11:51 AM To: Schaffner, Karen S.; James Reed Cc: Dustin Duhon Subject: RE: RTR MVL: questions on LA MVL facility

Karen, I just spoke with our engineering manager. He says that some barges and vessels have submerged fill capability, but since we don't contr ol them we don't necessarily know which or when. Our load arms are not equipped to do submerg e fill.

As far as vapor return lines, some of our tanks do have this equipment. We have typically used these lines for certain hazardous products, fo r example toluene diisocyanate or aniline, moreso than for high vapor pressure products which we don't often ship by barge/vessel. These latter are typically outbound by truck or rai l, and we do use emission controls for
them.

Please let me know if you need anything else.

Zach

Zach Smith Sr. EHS Specialist, Lower River Region Kinder~Morgan Terminals

225-603-5907

________________________________________ From: Schaffner, Karen S. [ksschaffner@rti.org] Sent: Tuesday, May 04, 2010 9:19 AM To: Smith, Zach - Lower River Region; James Reed
Cc: Dustin Duhon Subject: RE: RTR MVL: questions on LA MVL facility

Thank you!

-----Original Message----- From: Smith, Zach - Lower River Region [mailto:Zach_Smith@kindermorgan.com] Sent: Tuesday, May 04, 2010 10:49 AM To: Schaffner, Karen S.; James Reed
Cc: Dustin Duhon Subject: RE: RTR MVL: questions on LA MVL facility

Karen, there is currently no emission control devic e associated with marine vessel loading at our Delta terminal. All of the products we load to vessels have tvp <1.5 psia at loading conditions, or do not have a NESHAP-driven control requirement (e.g., benzene).

We are installing a flare which will be available t o control emissions from marine loading in the future. This is primarily to ensure that we re main a synthetic minor source of VOC
emissions.

I don't know the answer on submerged or bottom load ing, but will respond to this question after I speak with our engineering manager.

Please let me know if you have any other questions.2 Zach

Zach Smith Sr. EHS Specialist, Lower River Region Kinder~Morgan Terminals

225-603-5907

________________________________________ From: Schaffner, Karen S. [ksschaffner@rti.org] Sent: Tuesday, May 04, 2010 8:04 AM
To: James Reed Cc: Smith, Zach - Lower River Region; Dustin Duhon Subject: RE: RTR MVL: questions on LA MVL facility

Good Morning, Zach and Jim: Thank you for the inpu t clarifying that the Delta Terminal Services Harvey Facility is not subject to part 63 subpart Y.

Could you also provide some input on the controls q uestions? These other co ntrol questions I actually was thinking of as separate from the subpa rt Y applicability questions. (1) Whether there is an emission control device, unrela ted to subpart Y, that controls emissions from marine vessel loading operations, what kind of emissions control device is used, how much of emissions are vented to control device, and are there commodities where loading
emissions are not vented to the control device? and (2) Does submerged loading or bottomloading occur, and if so, is it fitted onto the ves sel or is it part of loading berth/arm?

Thank you, Karen

-----Original Message----- From: James Reed [mailto:James.Reed@LA.GOV] Sent: Monday, May 03, 2010 2:01 PM To: Schaffner, Karen S. Cc: Smith, Zach - Lower River Region; Dustin Duhon Subject: FW: RTR MVL: questions on LA MVL facility

Karen,

I forwarded your questions to Zach Smith, the Kinde r Morgan EHS specialist I have been working with on their current permit modification a pplication, and have included his response below. Please let contact me or Zach if you have an y additional questions.

Sincerely,
James Reed
Environmental Scientist III LDEQ Air Permits Division

-----Original Message----- From: Smith, Zach - Lower River Region [mailto:Zach_Smith@kindermorgan.com] Sent: Monday, May 03, 2010 12:57 PM
To: James Reed Subject: RE: RTR MVL: questions on LA MVL facility

Jim, I did some research and here are some prelimin ary answers:3 1. The 2006 application was designed to consolidat e four separate permits into a single one for the facility. Prior permit numbers were 1340-0 0236- V7, otherwise known as the Fina Yard, 1340-00192-V2, Hydril Yard, 1340-00146-00, East Yar d, and 1340-00146-00, West Yard. 2. The two state permits were obviously minor sour ce permits under Part 70, therefore Subpart Y would not have applied. 3. The Fina Yard Title V renewal permit applicatio n from 2003 did address Subpart Y applicability, with a determination of "2" (potent ially applicable but meets exemption criteria; page 30 of the EDMS document 27742008). In the Emissions by Pollutant Section of this appli cation, you can see total loading TAPs reported to be about 1.8 tons in the "Before" colum n. I believe this pretty clearly indicates the marine loading operation emitted less than 10/25 tons of HAPs in 2003, and I doubt this changed dramatically prior to this time and back to 1999. The reason for this is that the permitting action in 2003 was to convert t his Title V permit to a synthetic minor permit. 4. The Hydril Yard Title V renewal application fro m 2004 also addressed Subpart Y applicability, and also made a "2" determination (p age 36 of the EDMS document 30774346). In this particular application, a Facility PTE Emissio ns Aggregate Report was included for all four yards. Total toxics PTE for the Hydril Yard w as shown as 5.64 tons per year. This was clearly below both the 10 ton limit for single HAPs and 25 tons for total HAPs, therefore Subpart Y could not have a pplied. In addition, the overall facility PTE for toxics was shown as 13.23 tons per year.

Based on this information, I think it's clear the f acility met the exemption criteria in Subpart Y back in 1999. It would appear, if this i s correct, that the second and third questions in Karen Schaffner's email would be moot.

Please let me know if additional information will b e needed to settle the Subpart Y issue. I can provide the excerpted documentation I got from EDMS if you need it. The Title V/syn minor permit applications I pulled represent about 475 pages altogether.

Thanks for your help, Jim.

Zach

Zach Smith Sr. EHS Specialist, Lower River Region Kinder~Morgan Terminals

225-603-5907

________________________________ From: James Reed [James.Reed@LA.GOV] Sent: Monday, May 03, 2010 10:18 AM To: Smith, Zach - Lower River Region Subject: FW: RTR MVL: questions on LA MVL facility

Zach,

Could you please read over this and get back to me? I've highlighted her remaining questions. From what I can tell, the 2006 application indicate d that the Loading CAP had 3.1 TPY aggregate HAP, 1.19 TPY individual HAP, and the cap included all sources of transfer, not just marine vessels. Since the Subpart Y thresholds are 10 tpy individual HAPs and 25 tpy aggregate HAPs, I don't think it applies, but I wou ld still like your input.

Thanks!4 Jim

From: Schaffner, Karen S. [mailto:ksschaffner@rti.o rg] Sent: Monday, May 03, 2010 10:35 AM
To: James Reed Cc: Shedd.Steve@epamail.epa.gov Subject: RTR MVL: questions on LA MVL facility

Good Afternoon, James: I am working on the Residua l Risk project for the Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I am working with Steve Shedd at U.S. EPA/OAR/OAQPS /SSPD in Research Triangle Park, NC. We are looking at the Delta Terminal Services, Harvey Facility at 3540 River Rd in Harvey LA.

I tried your telephone number a few times without l uck and talked this morning on the phone with someone in Dept of Env Quality who menti oned that you telecommute a few days and work in another office a few days each work. They provided your email so am hoping to get in touch with you this way. Am sending my basic questions b elow, and following review of the online permit information, filled in the information found in the permit. Looked at: Permit Consolidation and Modification. Harvey Facility, D elta Terminal Services, Inc. Permit No.:

1340-00141-06. February 23, 2007. I still have a few questions. Any additional information you could provide would be much appreciated. Feel free to ca ll or send notes, as below. Thank you,
Karen Schaffner

Is the facility a Major source for HAP?

No, minor source for TAP/HAP. A fa cility-wide TAP cap at 22.44 ton. No
breakdown was shown for individual HAP. Entire fac ility limit on HAP/TAP individual compounds is <=9.4 ton/yr.

Conducts MVL operations? (loading of MVL, either t anker ships or barges; not unloading)

Yes, conducts MVL, both loading and unloading of ships and barges. (The facility also conducts Rail Loading, Truck Loading, and Container Loading.) There is a loading throughput CAP.

What are the HAP emissions in ton/yr from just MVL operations?

Loading CAP level is <=3.1 ton/yr t otal HAP from "Loading" - this would include MVL, rail, truck, and container loading too

.

Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., c ontrol device) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions a re <10/25 tons HAP?

There is no mention of subpart Y.

Question: Is the facility subject? If synthetic m inor due to federally enforceable throughputs or emission limits, what year did the f acility become a synthetic minor, i.e., before the subpart Y compliance date in 1999?

What kind of emissions control device is used? How much of emission are vented to control
device? Are there commodities that are not covered ?5 Permit does not mention any emissio n controls for MVL.

Question: Is there an emissions control device for marine vessel loading HAP emissions?

Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading ar m?

Permit does not mention use of subm erged loading or bottom-filling.

Question: Does submerged loading or bottom-loading occur, and if so, is it fitted onto the vessel or is it part of loading berth/arm?

Possible to identify the inspector who has visited the site and get their contact
information?

Lawrence McCarthy, at (504) 736 775 2?

Karen Schaffner Air Quality Engineering Group
RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Schaffner, Karen S. Sent: Tuesday, May 25, 2010 2:12 PM To: 'wdfusilier@paalp.com' Cc: 'Shedd.Steve@epamail.epa.gov' Subject: RTR MVL: questions on TX Ingleside Transfer Facilit y MVL terminal

Good Afternoon, Warren: As I mentioned, I am worki ng on the Residual Risk project for the Marine Vess el Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I a m working with Steve Shedd at U.S. EPA/OAR/OAQPS/SS PD in Research Triangle Park, NC. I am sending on some q uestions on the Ingleside Transfer Facility, Ingles ide TX. I found some permit information in a voided permit document : Voided Federal Operating Permit, Plains Marketin g L.P., Ingleside Transfer Facility. Permit No. O2761. Is sued May 5, 2005.

I included my basic questions below, and following review of the Voided Title V permit and some talks with the state agency and the state inspector, I filled in the inf ormation found in the permit. Please review and ma ke corrections to any of the statements below as needed. It sounded like the Ingleside Transfer Facility merged with an other facility, possibly the Ingleside Petroleum Terminal on Sunray Road, so not certain if the information in the voi ded permit would still be correct for the merged facility. Any addi tional information you could provide would be much appreciated. Thank you, Karen Schaffner

1. What is the current facility name and who owns the facility, i.e., still Plains Marketing LP? The faci lity was previously called Plains Marketing, Ingleside Trans fer Facility, located at E. OF INGLESIDE @ BISHOP R D. & INTERCOASTAL CANAL, Ingleside TX but is thought to have merged with another facility.

2. Is the facility a Major source for HAP?

No, the facility is not a major sou rce for HAP. J. Rhodes, TCEQ : Based on the current information we have on this facility, this is correct. Question : Confirm whether the whole, current facility is a major source for HAP, including MVL operations and other operations that occur at t he facility.

3. Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes. The site has an emission unit c alled “Dock”. J. Rhodes, TCEQ: Based on the information we have on this facility, this is correct. There are three emissio ns points (EPNs) located at the Ingleside Transfer Facility: EPN DOCK, EPN TANK1, and EPN FUG2. EPN TANK1 is a vertical fixed -roof storm water tank. Barge Loading: EPN DOCK a nd Fugitive Sources (EPN FUG2) are permitted by rule, 30 Texas Administrative Code §106.261. Per the Technical Re view dated 2/4/2008, estimated emissions for EPN DOCK we re listed as 3.82 lb/hr and 1.68 tpy. Estimated em issions for EPN FUG2 were listed as 0.06 lb/hr and 0.24 typ. Quest ion : Confirm the marine vessel loading operations.

4. What are the HAP emissions in ton/yr from just MVL operations?

Permit did not mention what the level of HAP emissi ons from MVL only are. EPA’s 2005 NEI/NATA databas e indicates emissions are 3.4 ton/yr total HAP from M VL (this was from the Ingleside Transfer Facility). J. Rhodes, TCEQ : The most recent emissions estimate we have in our r egional office is the 2008 Contaminant Summary Repo rt. Total site emissions, as reported by the regulated entity, for 2008, consisted of 0.0638 ton/yr VOC (unclassifie d) 0.00 ton/yr HAPS were reported. Question : What are the HAP emissions from the MVL operatio ns only?

5. Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?2

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

Voided Permit includes a Permit Shield. The facili ty is not subject to subpart Y because it is not a major source. The facility is not subject to MACT controls, recor dkeeping, or RACT. J. Rhodes, TCEQ : Based on the current information we have on this facility, this is correct. Questio n : Confirm whether the facility is subject to subpa rt Y, i.e., confirm whether the facility has MVL emissions >10/25 ton H AP and is required to control HAP emissions under s ubpart Y, or whether the facility has MVL emissions <10/25 ton H AP and is required to conduct recordkeeping under s ubpart Y?

6. What kind of emissions control device is used? How much of emissions are vented to control device? A re there
commodities that are not covered?

No information on whether there are emission contro ls in place. J. Rhodes, TCEQ : In reviewing TCEQ files, she did not find any record of an emissions control dev ice used to control emissions from marine vessel lo ading. Question : Could you confirm whether there is an emissions con trol device that controls marine vessel loading emi ssions from the dock. Why was the emission control device put in p lace? Is the emissions control device considered f ederally enforceable? Are the marine loading emission from all commodities vented to the control device, or ar e only certain
commodities vented? Which commodities?

7. Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?

Permit does not mention submerged l oading. J. Rhodes, TCEQ : In reviewing TCEQ files, she did not find any record of what type of fill is used to load the shi p/barge. Question : Does submerged loading occur, and if so, is it f itted onto the vessel or part of the loading berth/arm?

8. Possible to identify the inspector who has visited the site and get their contact information?

Jessica Rhodes at (361) 825 3388

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Schaffner, Karen S. Sent: Monday, May 24, 2010 4:52 PM To: 'psiler@transmontaigne.com' Cc: 'Shedd.Steve@epamail.epa.gov' Subject: RTR MVL: questions on FL TransMontaigne MVL termin al

Good Afternoon, Paul: Am sending some questions on the TransMontaigne Terminals, LLC - Port Everglade s North Terminal. I reviewed some available permit informa tion (TransMontaigne Terminals, LLC - Port Everglad es North
Terminal. Permit No.: 0110069-019-AV. Issued 1 S ept 2005) and contacted the local agency. As I men tioned, I am working on the Residual Risk project for the Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I am working with Steve Shedd at U.S. EPA/OAR/OAQPS/SSPD in Research Triangle Park, NC.

I included my basic questions below, and following review of the permit, I filled in the information f ound in the permit. I still I have a few questions. Any additional infor mation you could provide would be much appreciated. Thank you,
Karen Schaffner

1. Is the facility a Major source for HAP?

2. Are MVL operations conducted at the facility? (loa ding of MVL, either tanker ships or barges; not un loading)

Yes.

3. What are the HAP emissions in ton/yr from just MVL operations?

Permit files show potential to emit HAP emissions f rom Barge Loading of 3.84 ton HAP. EPA’s 2005 NEI/ NATA database shows 1.97 ton/yr total HAP from MVL. Que stion : Confirm that the potential to emit estimate incl udes the Marine VRU control efficiency, i.e., would be poten tial to emit considering controls.

4. Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- (Existing sources) Emission reduction requirements (i.e., control device) if MVL emissions are >10/25 tons
HAP?

- (Existing sources) Recordkeeping to confirm MVL emi ssions are <10/25 tons HAP?

- (New sources) Emission reduction requirements (i.e. , control device) at all levels of MVL emissions?

Permit indicates that throughput limits on gasoline and distillate exempt the facility from subpart Y RACT requirements. Question : Confirm subpart Y applicability for MACT require ments.

5. What kind of emissions control device is used? How much of emissions are vented to control device? A re there
commodities that are not covered?

Permit indicates that a Marine VRU (Carbon Adsorption unit) is used to control emissio ns from barge loading.
Question : Confirm why the emission control device was put in place? Is the emission control device considere d federally enforceable? Are the marine loading emis sions from all commodities vented to the control de vice, or are only
certain commodities at each dock vented? Which com modities?

6. Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?2 Permit does not mention submerged f ill. The facility noted that there are no submerge d fill requirements, and while some marine vessels may have submerged fill, they do not keep track of this.

7. Possible to identify the inspector who has visited the site and get their contact information?

Elizabeth Susky at (954) 519-1430

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Schaffner, Karen S. Sent: Wednesday, May 19, 2010 5:38 PM To: 'christina_harris@kindermorgan.com' Cc: 'Shedd.Steve@epamail.epa.gov' Subject: RTR MVL: questions on TX KinderMorgan Galena Park T erminal

Good Afternoon, Christina: Am forwarding on some q uestions on the KinderMorgan Liquids Terminals LLC, Galena Park Terminal, Permit No. O988. Issuance Date: Februar y 2, 2007. As I mentioned, I am working on the Res idual Risk project for the Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I am working with Steve Shedd at U.S. EPA/OAR/OAQPS/SPPD in Research Triangle Park, NC.

I included my basic questions below, and following review of the permit, I filled in information found in the permit. I still I have a few questions, see yellow highlights. Any additional information you could provide would be much appreciated. Thank you, Karen Schaffner

1. Is the facility a Major source for HAP?

No information in the permit on whether the facilit y is a major source of HAP. Likely is major for HA P because the permit mentions part 63 subpart Y. Question : Could you confirm whether the facility is major for HAP?

2. Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes. The permit indicates there are seven (7) docks at the site, including: Barge Dock No. 1 (BD-1), Barge Dock No. 2 (BD-2), Barge Dock No. 3 (BD-3), Ship Dock No . 1 (SD-1), Ship Dock No. 2 (SD-2), Ship Dock No. 3 (SD-3), and Ship Dock No. 4 (SD-4).

3. What are the HAP emissions in ton/yr from just MVL operations?

84.59 ton/yr total HAP from MVL (from EPA’s 2005 NE I/NATA database), with HAP speciation (in tons) of:

1,3-Butadiene 24.6 Acetaldehyde 1.48

Benzene 20.07

Cumene 0.0025 Ethylbenzene 0.401

Hexane 4.14

MTBE 17.9 Naphthalene 0.0063 Styrene 0.137
Toluene 8.83 Xylenes 7.03

Question : Are these emissions estimates correct? If not c orrect, could you provide MVL only HAP emission est imates for 2005, and perhaps for 2009 as well?

4. Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?2

Permit indicates that all of the docks are subject to MACT subpart Y; BD-3 and SD-4 are also subject t o RACT. BD-3 and SD-4 are vented to the SD-4-VCU, a vapor c ombustion unit. It i s not clear whether controls are in place at all of the docks. Question : Could you confirm whether the facility has MVL e missions >10/25 ton HAP and is required to control HAP emissions under subpart Y, or whether t he facility has MVL emissions <10/25 tons HAP and i s required to conduct recordkeeping under subpart Y? Could you c onfirm whether each dock is subject to subpart Y co ntrols or subpart Y recordkeeping?

5. What kind of emissions control device is used? How much of emissions are vented to control device? A re there
commodities that are not covered?

Permit mentions emission control de vice SD-4-VCU (this is a flare?). One of the Permi t Amendment Source Analysis &Technical Review files seems to refer to VCU-1A and VCU-1B as being an emission control for Marine Loading,
but it is not clear. It is not clear whether loadi ng emissions from all docks are vented to a control device. Question : Could you confirm whether there is an emissions con trol device that controls marine vessel loading emi ssions from each berth/dock? Why was each emission control device p ut in place? Is the emission control device consid ered federally
enforceable? What is the emissions reduction effic iency achieved for marine loading emissions? Are t he marine load ing
emissions from all commodities vented to the contro l device, or are only certain commodities at each d ock vented? Which commodities? If flares are used, are they op en flares or enclosed flares?

6. Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?

Permit does not mention submerged lo ading. Question : Does submerged loading occur, and if so, is it f itted onto the vessel or part of loading berth/arm?

7. Possible to identify the inspector who has visited the site and get their contact information?

Vicky Wang at (713) 767 3759

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Schaffner, Karen S. Sent: Tuesday, May 18, 2010 5:09 PM To: 'james.scroggins@tpcgrp.com' Cc: Shedd.Steve@epamail.epa.gov Subject: RTR MVL: questions on Texas Petrochemical MVL termi nal

Good Afternoon, James: As I mentioned on the telep hone, I am working on the Residual Risk project for the Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, s ubpart Y). I am working with Steve Shedd at U.S. EPA/OAR/OAQPS/SSPD in Research Triangle Park, NC.

I have been reviewing permit information for the Te xas Petrochemical Terminal in Houston TX and have r eviewed several permit documents but do have a few remainin g questions. I have looked at: (1) Permit Renewal , Technical Review Analysis, Texas Petrochemicals LP, Marine Do ck Loading Operations, Permit No. 22052, Project No . 105000, Account No. HG-0562-P, Regulated Entity No.: RN100 219526; and (2) Texas Petrochemicals LLC, Industria l Organic Chemicals, Federal Operating Permit. Permit No. O1 598. Issuance Date: October 7, 2004. I included my basic questions below, and following review, I filled in the inform ation found in the permit. Any additional informat ion you could provide to help answer the remaining questions woul d be much appreciated. Thank you, Karen Schaffner

1. Is the facility a Major source for HAP?

Yes, the facility is a major source for HAP.

2. Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes, conducts marine vessel loading. The marine dock operation includes 2 docks for ship s and barges. Some commodities are pressure-loaded and assumed to have no emissions (except degassing, which go to the Pl ant Flare). Other commodities are loaded at atmospheric pressur e, are captured with vacuum-assist on barges (100% capture) and when possible on ships (95% capture).

3. What are the HAP emissions in ton/yr from just MVL operations?

Could not find information on HAP e missions for MVL only in the permit, not known. _ ton/yr total HAP from MVL. EPA’s 2005 NEI/NATA database shows HAP emissi ons from MVL only emissions are 8.11 ton HAP (2005) , with HAP speciation (in tons) of:

1,3-Butadiene 1.33

MTBE 5.90
Methanol 0.878

Question : Are these emission estimates correct? In not, could you confirm what the actual HAP emissions fro m marine vessel loading only were for 2005, and perhaps for 2009 as well?

4. Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

The facility is subject to subpart Y. It is not cl ear whether the facility is required to comply with MACT control requirements (i.e., MVL emissions are >10/25 ton HA P) or the facility is subject to the recordkeeping requirements (if the MVL emissions are <10/25 tons HAP). P. 77 of o ne of the permit documents reviewed (Permit No. O15 98, dated2 October 7, 2004) looked like MVL HAP emissions are <10/25 ton but am not certain I am interpreting cor rectly.
Question : Could you confirm whether the facility has MVL e missions >10/25 ton HAP and is required to control HAP emissions under subpart Y, or whether the facility has MVL emissions <10/25 ton HAP and is required to conduct recordkeeping under subpart Y? Could you confirm w hether each dock is subject to subpart Y controls o r subpart Y recordkeeping?

5. What kind of emissions control device is used? How much of emissions are vented to control devices? Are
there commodities that are not covered?

Permit shows that a Marine Loading Flare is used to control MVL emissions. It is assu med that the Flare achieves 98% efficiency for VOC. Vacuum-assist cap ture is used for barges (100% capture efficiency) a nd is used when possible for ships (95% capture efficiency). Commo dities that are pressure-loaded are assumed to have no emissions; pressure-loaded commodities include propane, butane s, butadienes, and other compounds with 4 Carbons. MVL at atmospheric pressure is conducted for MTBE, and dii sobutylene (DIB), and loading occurs to barges with vacuum-assist and to ships with vacuum-assist when possible. Fro m one of the facility permit documents, it showed t hat emissions from C-5 had “operating scenarios” C-5-A1 and C-5-A 2 that did not have control devices, and showed tha t operating
scenario C-5-P2 is controlled with the Flare. I as sume that these are operating scenarios at the 2 do cks, related to the barges, ships, and pressure-loaded commodities note d here. Question : Is the Marine Loading Flare an open flare or an
enclosed flare? What was the reason the MVL emissi ons are vented to the Marine Loading Flare – was the flare installed and the MVL emissions vented to comply with a state rule or a Federal rule? Is the emission control d evice considered federally enforceable? Could you also confirm what type of control device each of the C-5-A1, C-5-A2, and C-5-P2 has, and the control efficiency achieved for HAP MVL emi ssions? Are the marine loading emissions from all commodities vented to the control device, or are only certain c ommodities at each dock vented? Which commodities?

6. Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?

Permit does not mention submerged l oading or bottom loading. Question : Does submerged loading occur, and if so, is it fitted onto the vessel or part of load ing berth/arm?

7. Possible to identify the inspector who has visited the site and get their contact information?

Armando Bayoneto (713) 767-3737 Gary Ackerman (713) 767-3577

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Schaffner, Karen S. Sent: Monday, May 17, 2010 5:08 PM To: 'wgmoore@marathonoil.com' Cc: Shedd.Steve@epamail.epa.gov Subject: RTR MVL: questions on IN Marathon MVL terminal

Good Afternoon, Greg: Below are several questions on the Marathon Petroleum Company, LLC Clarksville Terminal in Clarksville IN, Permit F 019-23332-00012. As I me ntioned, I am working on the Residual Risk project for the Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, s ubpart Y). I am working with Steve Shedd at U.S. EPA/OAR/OAQPS/SPPD in Research Triangle Park, NC.

In reviewing the permit and in talking to IN IDEM s taff, I filled in the information found. I highlig hted areas where I still have questions. Any additional information you cou ld provide would be much appreciated. Thank you, K aren Schaffner

1. Is the facility a Major source for HAP?

No, synthetic minor for HAP. 3.82 ton/yr total HAP from facility, reflecting limits o n the emission units. The facility has agreed to limit their HAP emissions be low Title V limits. Federally enforceable throughp ut limits are in place for neat ethanol, gasoline, and distillate. (Unr estricted Potential Emissions are 66.9 ton/yr total HAP for “MVL only” and 68.1 ton/yr total HAP for the facility.) From J. Wilkins, IDEM : The facility is a minor source under Title V and under part 63. The FESOP was issued in Aug 1997, so the facility was a synthetic minor prior to subpart Y c ompliance date (1999).

2. Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes, loading barges.

3. What are the HAP emissions in ton/yr from just MVL operations?

3.47 ton/yr total HAP from MVL, ref lecting throughput limits on the units (throughput limits target VOC).

4. Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

Permit does not mention subpart Y. Curiously, the permit explicitly states that the facility is not s ubject to subpart R, Gasoline Distribution, and is not subjec t to subpart CC, Petroleum Refineries, even though it is a synthetic minor for HAP. Question : Can you confirm that the facility is not subject to subpart Y for Marine Vessel Loading NESHAP? Also, it looks like some subpart R testing requirements are included in the permit? Not cert ain I understand this since the permit states the facility is not su bject to subpart R. Is the facility subject to sub part R, as a major source(?), or not? From J. Wilkins, IDEM : The permit includes some compliance testing prov isions from IAC rules that reference subpart R leak definitions or thresholds, but this does not mean the facility is subject to subpart R.

5. What kind of emissions control device is used? How much of emissions are vented to control device? A re there
commodities that are not covered?

Permit does not mention any emissio n control device for barge loading. (There is a po rtable vapor combustor on truck loading rack that is subject to NSPS subpa rt XX, Bulk Gasoline Terminals.) Question : Is there a control device for barge loading at the facility, and does it cove r all commodities or only certain ones (the control device question here2 is separate from the “subject to subpart Y” questio n, i.e., a facility could have a control device unr elated to subpart Y requirements)? If yes, why was the emission contro l put in place? Is the emission control device con sidered federally
enforceable?

6. Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?

Permit does not mention submerged l oading or bottom loading. Question : Does submerged loading occur, and if so, is it fitted onto the vessel or part of load ing berth/arm?

7. Possible to identify the inspector who has visited the site and get their contact information?

Vaughn Isor at (317) 233 0432

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Schaffner, Karen S. Sent: Wednesday, May 12, 2010 9:36 AM To: 'michelle.herman@chevron.com' Cc: 'Shedd.Steve@epamail.epa.gov' Subject: questions on TX Unocal MVL terminal

Good Morning, Michelle: As I mentioned on the phon e, I am working on the Residual Risk project for th e Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I am working with Steve Shedd at U.S. EPA/OAR/OAQPS /SSPD in Research Triangle Park, NC. Steve and I have revie wed the facility permit but do have a few remaining questions. Union Oil Company of California (Unocal), Beaumont Termin al, Permit No. O1025, Issued February 4, 2008

.

I included my basic questions below, and following review of the permit, I filled in the information f ound in the permit. Any additional information you could provide to hel p answer the remaining questions would be much appr eciated. Thank you, Karen Schaffner

1. Is the facility a Major source for HAP?

No information in the permit on whether major or ar ea for HAP emissions. Likely are major for HAP since facility is subject to subpart Y. Question : Could you confirm whether the facility is a majo r source for HAP, an area source, or a minor source?

2. Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes, the facility conducts marine vessel loading. There are 3 marine loading docks: (1) main ship/b arge loading dock (ML255), (2) No.2 Crude Dock (SPR dock), and ( 3) No.3 Crude Barge dock (FLBD3).

3. What are the HAP emissions in ton/yr from just MVL operations?

__ ton/yr total HAP from MVL. Question : Could you confirm what the actual HAP emissions from marine vessel loading only are?

4. Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

Permit indicates the facility is subject to subpart Y, for both MACT and RACT. It is not clear whethe r an emission control device is in place for each dock. Question : Could you confirm whether the facility has MVL emis sions >10/25 ton HAP and is required to control HAP emissions under subpart Y, or whether the facility has MVL emission s <10/25 ton HAP and is required to conduct recordkeeping under subpart Y?

5. What kind of emissions control device is used? How much of emissions are vented to control device? A re there
commodities that are not covered?

Permit mentions emissions control devices SPR901 an d SPR902 (thermal oxidizers). It is not clear whet her these devices are for the SPR crude dock only, or w hether the other marine loading docks are also vent ed to them.
Question : Could you confirm whether there is an emissions control device that controls marine vessel loading emissions from each berth/dock? Why was the emissi on control device put in place? Is the emission co ntrol device considered federally enforceable? Are the marine l oading emissions from all commodities vented to the control device, or are only certain commodities at each dock vented ? Which commodities?2

6. Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?

Permit does not mention submerged loading or bottom loading. Question : Does submerged loading or bottom-loading occur, and if so, is it fitted onto the vessel or part of loading berth/arm?

7. Possible to identify the inspector who has visited the site and get their contact information?

Neadra Richard at (409) 898 3838

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Schaffner, Karen S. Sent: Tuesday, May 11, 2010 4:50 PM To: 'jrhodes@tceq.state.tx.us' Cc: 'Shedd.Steve@epamail.epa.gov' Subject: RTR MVL: questions on TX Ingleside Transfer Facilit y MVL terminal

Good Afternoon, Jessica: As I mentioned, I am working on the Residual Risk p roject for the Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I am work ing with Steve Shedd at U.S. EPA/OAR/OAQPS/SSPD in Research Triangle Park, NC. I am sending on some questions on the Ingleside Transfer Facility, Ingleside TX.

I included my basic questions below, and following review of the Voided Title V permit, I filled in th e information found in the permit. I still I have a few questions. An y additional information you could provide would be much appreciated. Thank you, Karen Schaffner

1. Is the facility a Major source for HAP?

No, the facility is not a major source for HAP.

2. Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes. The site has an emission unit called “Dock”.

3. What are the HAP emissions in ton/yr from just MVL operations?

__ ton/yr total HAP from MVL. Question : What are the HAP emissions from the MVL operatio ns only?

4. Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

Voided Permit includes a Permit Shield. The facili ty is not subject to subpart Y because it is not a major source. The facility is not subject to MACT controls, recor dkeeping, or RACT.

5. What kind of emissions control device is used? How much of emissions are vented to control device? A re there
commodities that are not covered?

No information on whether there are emission contro ls in place. Question : Could you confirm whether there is
an emission control device that controls marine ves sel loading emissions from the dock. Why was the e mission control device put in place? Are the marine loading emissi on from all commodities vented to the control devic e, or are only
certain commodities vented? Which commodities?

6. Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?

Permit does not mention submerged loading or bottom loading. Question : Does submerged loading or bottom-loading occur, and if so, is it fitted onto the vessel or part of the loading berth/arm?

7. Possible to identify the inspector who has visited the site and get their contact information?2

Jessica Rhodes at (361) 825 3388

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Schaffner, Karen S. Sent: Friday, May 07, 2010 12:34 PM To: 'nrichard@tceq.state.tx.us' Cc: Shedd.Steve@epamail.epa.gov Subject: RTR MVL: questions on TX Unocal MVL terminal

Good Morning, Neadra: As I mentioned on the phone , I am working on the Residual Risk project for the Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I am working with Steve Shedd at U.S. EPA/OAR/OAQPS /SSPD in Research Triangle Park, NC. Steve and I have been working with TCEQ to collect permit information for the Unocal
Beaumont Terminal in Nederland TX and have reviewed the facility permit that TCEQ shared but do have a few remaining questions. Union Oil Company of Californ ia (Unocal), Beaumont Terminal, Permit No. O1025, I ssued February 4, 2008.

I included my basic questions below, and following review of the permit, I filled in the information f ound in the permit. Any additional information you could provide to hel p answer the remaining questions would be much appr eciated. Thank you, Karen Schaffner

1. Is the facility a Major source for HAP?

No information in the permit on whether major or ar ea for HAP emissions. Likely are major for HAP since facility is subject to subpart Y. Question : Could you confirm whether the facility is a majo r source for HAP, an area source, or a minor source?

2. Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes, the facility conducts marine vessel loading. There are 3 marine loading docks: (1) main ship/b arge loading dock (ML255), (2) No.2 Crude Dock (SPR dock), and ( 3) No.3 Crude Barge dock (FLBD3).

3. What are the HAP emissions in ton/yr from just MVL operations?

__ ton/yr total HAP from MVL. Question: Could you confirm what the actual HAP emissions fro m marine vessel loading only are?

4. Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

Permit indicates the facility is subject to subpart Y, for both MACT and RACT. It is not clear whethe r an emission control device is in place for each dock. Question : Could you confirm whether the facility has MVL emis sions >10/25 ton HAP and is required to control HAP emissions under subpart Y, or whether the facility has MVL emission s <10/25 ton HAP and is required to conduct recordkeeping under subpart Y?

5. What kind of emissions control device is used? How much of emissions are vented to control device? A re there
commodities that are not covered?

Permit mentions emissions control devices SPR901 an d SPR902 (thermal oxidizers). It is not clear whet her these devices are for the SPR crude dock only, or w hether the other marine loading docks are also vent ed to them. Question: Could you confirm whether there is an emissions control device that controls marine vesse l loading emissions from each berth/dock? Why was the emissi on control device put in place? Is the emission co ntrol device2 considered federally enforceable? Are the marine l oading emissions from all commodities vented to the control device, or are only certain commodities at each dock vented ? Which commodities?

6. Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?

Permit does not mention submerged loading or bottom loading. Question : Does submerged loading or bottom-loading occur, and if so, is it fitted onto the vessel or part of loading berth/arm?

7. Possible to identify the inspector who has visited the site and get their contact information?

Neadra Richard at (409) 898 3838

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Schaffner, Karen S. Sent: Thursday, May 06, 2010 6:56 PM To: 'lpatak@tceq.state.tx.us' Cc: 'Shedd.Steve@epamail.epa.gov' Subject: RTR MVL: questions on Texas Petrochemical MVL termi nal

Good Afternoon, Linda: I contacted Armando Bayonet o and Gary Ackerman, both of TCEQ to ask some follo w-up questions regarding a Marine Vessel Loading (MVL) t erminal in TX. Armando indicated that I should go through you to request information. I also called you to leave a voicemail. As I mentioned, I am working on the Residual Risk p roject for the Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I am working with Steve Shed d at U.S. EPA/OAR/OAQPS/SSPD in Research Triangle Park, NC. My note and questions for Armando and Gary are belo w.

I have been working with TCEQ to collect permit inf ormation for the Texas Petrochemical Terminal in Ho uston TX and have reviewed several permits that TCEQ shared but do have a few remaining questions. I included my b asic questions below, and following review of the permit, I filled in the information found in the permit. Any addit ional information you could provide to help answer the remaining ques tions would be much appreciated. Thank you, Karen Schaffner

1. Is the facility a Major source for HAP?

Yes, the facility is a major source for HAP.

2. Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes, conducts marine vessel loading.

3. What are the HAP emissions in ton/yr from just MVL operations?

Could not find information on this in the permit, n ot known . _ ton/yr total HAP from MVL. Question : Could you confirm what the actual HAP emissions from mari ne vessel loading only are?

4. Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

The facility is subject to subpart Y. It is not cl ear whether the facility is required to comply with MACT control requirements (i.e., MVL emissions are >10/25 ton HA P) or the facility is subject to the recordkeeping requirements (if the MVL emissions are <10/25 tons HAP). P. 77 of o ne of the permit documents I reviewed (Permit No. O 1598, dated October 7, 2004) looked like MVL HAP emissions are <10/25 ton but am not certain I am interpreting cor rectly.
Question : Could you confirm whether the facility has MVL e missions >10/25 ton HAP and is required to control HAP emissions under subpart Y, or whether the facility has MVL emissions <10/25 ton HAP and is required to conduct recordkeeping under subpart Y?

5. What kind of emissions control device is used? How much of emissions are vented to control device? A re there
commodities that are not covered?

Permit shows that a Marine Loading Flare is used to control MVL emissions. It is assumed that the Fla re achieves 98% efficiency for VOC. Vacuum-assist cap ture is used for barges (100% capture efficiency) a nd is used when possible for ships (95% capture efficiency). Commo dities that are pressure-loaded are assumed to have no emissions. From one of the facility permit documents, it showe d that C-5-A1 and C-5-A2 did not have control devic es, and that C-5-
P2 is controlled with the Flare. I assume that the se are operating scenarios related to the barges, s hips, and pressure-2 loaded commodities noted here. Question : Is the Marine Loading Flare an open flare or an enclosed flare? Why are the MVL emissions vented to the Marine Loading Flar e – was the flare installed and the MVL emissions vente d to comply
with a state rule or a Federal rule? Is the emissi on control device considered federally enforceable? Could you also confirm what each of the C-5-A1, C-5-A2, and C-5-P2 are?

6. Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?

Permit does not mention submerged loading or bottom loading. Question : Does submerged loading or bottom-loading occur, and if so, is it fitted onto the vessel or part of loading berth/arm?

7. Possible to identify the inspector who has visited the site and get their contact information?

Armando Bayoneto (713) 767-3737 Gary Ackerman (713) 767-3577

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Schaffner, Karen S. Sent: Monday, May 03, 2010 2:50 PM To: 'jeffrey.meyer@dep.state.nj.us'; 'robert.mann@dep.sta te.nj.us' Cc: 'Shedd.Steve@epamail.epa.gov' Subject: RTR MVL: questions on NJ MVL facility

Good Afternoon, Bob and Jeff: I am working on the Residual Risk project for the Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I am working wit h Steve Shedd at U.S. EPA/OAR/OAQPS/SSPD in Researc h Triangle Park, NC. We are looking at the ST Linden Terminal, LLC at Ft of South Avenue in Linden NJ.

Thank you Bob for directing me to the permit for th e St Linden Terminal LLC Shoreside Facility in Lind en City NJ. Looked at: ST Linden Terminal LLC Shoreside Facility, at 4501 Tremley Point Rd in Linden City NJ, Air Pollut ion Control Operating Permit, Minor Modification and Preconstruction Appr oval. Permit Activity Number: BOP090002. Program Interest Number: 41800. Initial Approval Dated September 2 9, 2003.

Am sending my basic questions below. I reviewed th e permit information and filled in the information found in the permit. I still have a few questions. Any additio nal information you could provide would be much app reciated. Feel free to call or send notes. Thank you, Karen Schaf fner

Is the facility a Major source for HAP?

Permit indicates the facility’s PTE HAP is 0.243 to n/yr. I assume this is considering emissions contr ols.
Question : The permit does not state whether it is an area source for HAP or whether it is a synthetic minor f or HAP. Could you confirm?

Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes, conducts MVL. There are throughput limits and emission rate limits, based on VOC.

What are the HAP emissions in ton/yr from just MVL operations?

Loading emissions PTE is 0.243 ton/yr HAP. The MV L emissions limit for Benzene is <=0.243 ton/yr ben zene. There are several MVL limits: <=27.05 ton/yr tot al VOC emissions; <=420,00 gal/hr total material tr ansferred; <=35.02 lb/hr total VOC max emission rate.

Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

There is no mention of subpart Y. Question : Is the facility subject? If synthetic minor due to federally enforceable throughputs or emission limits, what ye ar did the facility become a synthetic minor, i.e., before the subpart Y compliance date in 1999?

What kind of emissions control device is used? How much of emission are vented to control device? Ar e there
commodities that are not covered?

Permit states that Loading of Petroleum Hydrocarbon liquids and loading of VOC liquids (vp <=11.1 psia ) must be directed to CD1 Carbon Adsorption system, that a chieves a VOC Control Efficiency of 95% by wt. For Loading of VOC2 liquids (with vp <=0.02 psia) without the control d evice, permit limits VOC total emissions to <=6.72 lb/hr max emission rate; and limits total material transferred to <=50 4,000 gal/hr maximum transfer rate.

Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?

Permit does not mention use of submerged loading or bottom-filling. Question : Does submerged loading or bottom-loading occur, and if so, is it fitted onto the vessel or is it part of loading berth/arm?

Possible to identify the inspector who has visited the site and get their contact information?

Jeff Meyer, at (973) 656 4084

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Schaffner, Karen S. Sent: Monday, May 03, 2010 11:35 AM To: 'james.reed@la.gov' Cc: 'Shedd.Steve@epamail.epa.gov' Subject: RTR MVL: questions on LA MVL facility

Good Afternoon, James: I am working on the Residual Risk project for the M arine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I am working with Steve S hedd at U.S. EPA/OAR/OAQPS/SSPD in Research Triangl e Park, NC. We are looking at the Delta Terminal Services, Harvey Facility at 3540 River Rd in Harvey LA.

I tried your telephone number a few times without l uck and talked this morning on the phone with someo ne in Dept of Env Quality who mentioned that you telecommute a fe w days and work in another office a few days each w ork. They provided your email so am hoping to get in touch wi th you this way. Am sending my basic questions bel ow, and following review of the online permit information, filled in the information found in the permit. Loo ked at: Permit Consolidation and Modification. Harvey Facility, D elta Terminal Services, Inc. Permit No.: 1340-0014 1-06. February 23, 2007. I still have a few questions. Any additiona l information you could provide would be much appre ciated. Feel free to call or send notes, as below. Thank you, Karen Schaffner

Is the facility a Major source for HAP?

No, minor source for TAP/HAP. A facility-wide TAP cap at 22.44 ton. No breakdown was shown for indiv idual HAP. Entire facility limit on HAP/TAP individual c ompounds is <=9.4 ton/yr.

Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes, conducts MVL, both loading and unloading of sh ips and barges. (The facility also conducts Rail L oading, Truck Loading, and Container Loading.) There is a loading throughput CAP.

What are the HAP emissions in ton/yr from just MVL operations?

Loading CAP level is <= 3.1 ton/yr total HAP from “Loading” – this would in clude MVL, rail, truck, and container loading too.

Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

There is no mention of subpart Y. Question : Is the facility subject? If synthetic minor due to federally enforceable throughputs or emission limits, what ye ar did the facility become a synthetic minor, i.e., before the subpart Y compliance date in 1999?

What kind of emissions control device is used? How much of emission are vented to control device? Ar e there
commodities that are not covered?

Permit does not mention any emission controls for M VL. Question : Is there an emissions control device for marine vessel loading HAP emissions?

Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?2

Permit does not mention use of submerged loading or bottom-filling. Question : Does submerged loading or bottom-loading occur, and if so, is it fitted onto the vessel or is it part of loading berth/arm?

Possible to identify the inspector who has visited the site and get their contact information?

Lawrence McCarthy, at (504) 736 7752?

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 71551 

### Schaffner, Karen S.

From: Schaffner, Karen S. Sent: Friday, April 30, 2010 3:27 PM To: 'skeown@idem.in.gov' Cc: 'Shedd.Steve@epamail.epa.gov' Subject: RTR MVL: questions on IN MVL terminal

Good Afternoon, Summer: I received your message an d am forwarding on some questions on the Marathon P etroleum Company, LLC Clarksville Terminal in Clarksville IN , Permit F 019-23332-00012. As I mentioned in my voicemail, I am working on the Residual Risk project for the Marine Vessel Loading (MVL) NESHAP rule (40 CFR part 63, subpart Y). I am working with Steve Shedd at U.S. EPA/OAR/OAQPS/SSPD in Research Triangle Park, NC.

I included my basic questions below, and following review of the permit, I filled in the information f ound in the permit. I still I have a few questions. Any additional infor mation you could provide would be much appreciated. Thank you,
Karen Schaffner

Is the facility a Major source for HAP?

No, synthetic minor for HAP. 3.82 ton/yr total HAP from facility, reflecting limits on the emission u nits. The facility has agreed to limit their HAP emissions be low Title V limits. Federally enforceable throughp ut limits are in place for neat ethanol, gasoline, and distillate. (Unr estricted Potential Emissions are 66.9 ton/yr total HAP for MVL only and 68.1 ton/yr total HAP for the facility.)

Conducts MVL operations? (loading of MVL, either tanker ships or barges; not un loading)

Yes, loading barges.

What are the HAP emissions in ton/yr from just MVL operations?

3.47 ton/yr total HAP from MVL, reflecting limits o n the emission units.

Subject to 40 CFR part 63, subpart Y, Marine Vessel Loading NESHAP?

- Emission reduction requirements (i.e., control devi ce) if MVL emissions are >10/25 tons HAP?

- Recordkeeping to confirm MVL emissions are <10/25 t ons HAP?

Permit does not mention subpart Y. Curiously, the permit explicitly states that the facility is not s ubject to subpart R, Gasoline Distribution, and is not subjec t to subpart CC, Petroleum Refineries, even though it is a synthetic minor for HAP. Question : Can you confirm that the facility is not subject to subpart Y for Marine Vessel Loading NESHAP? Also, it looks like some subpart R testing requirements are included in the permit? Not cert ain I understand this since the permit states the facility is not su bject to subpart R. Is the facility subject to sub part R, as a major source(?), or not?

What kind of emissions control device is used? How much of emissions are vented to control device? A re there
commodities that are not covered?

Permit does not mention any emission control device for barge loading. (There is a portable vapor com bustor on truck loading rack that is subject to NSPS subpa rt XX, Bulk Gasoline Terminals.) Question : Is there a control device for barge loading at the facility, and does it cove r all commodities or only certain ones?

Is submerged fill used? Is the marine vessel (tank er ship or barge) fitted with submerged fill, or is it part of the loading berth/loading arm?2

Permit does not mention submerged loading or bottom loading. Question : Does submerged loading or bottom-loading occur, and if so, is it fitted onto the vessel or part of loading berth/arm?

Possible to identify the inspector who has visited the site and get their contact information?

Vaughn Isor at (317) 233 0432?

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 7155