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 agencies and facilities in confirming operating 

and applicability for marine vessel loading facilities. This information was used to inform the 

risk and technology review project for the marine vessel loading source category. 

II. References

Emails from state agencies, state inspectors, and facilities: 

Email, P. Siler, TransMontaigne, to K. Schaffner, RTI. TransMontaigne Products Fort 

Lauderdale FL input on MVL questions. Dated June 2, 2010. 

Email, W. Fusilier, Plains All American Pipeline, to K. Schaffner, RTI. Ingleside Transfer 

Ingleside TX input on MVL questions. Dated June 1, 2010. 

Email, J. Scroggins, TPC Group, to K. Schaffner, RTI. TPC Group Houston TX input on MVL 

questions. Dated May 26, 2010. 

Email, M. Herman, Chevron, to K. Schaffner, RTI. 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 Facility 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 Terminal. Plains Marketing 

Ingleside questions on marine vessel loading terminal. Dated May 25, 2010. 

Email, K. Schaffner, RTI, to P. Siler, TransMontaigne. TransMontaigne 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, Marathon 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 Facility 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@transmontaigne.com; 

DHall@transmontaigne.com; DTarlton@transmontaigne.com; 

TJordan@transmontaigne.com

Subject: Re: RTR MVL: questions on FL TransMontaigne MVL terminal

Hello Karen, 

In regard to you previously provided questions, please 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 terminal

Good Afternoon, Paul: Am sending some questions on the TransMontaigne Terminals, LLC - Port Everglades North Terminal. I 

reviewed some available permit information (TransMontaigne Terminals, LLC - Port Everglades North Terminal. 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 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 found in the permit. I still I have a 

few questions. Any additional information you could provide would be much appreciated. Thank you, Karen Schaffner 

 

 

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

 

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

HAPs. 

 

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

 

 Yes.

 

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

 

Permit files show potential to emit HAP emissions from 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 the federally enforceable 

emission limit of 35 mg/l of gasoline loaded. Emissions 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, 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 emissions 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 crude oil exempt the facility from subpart Y RACT requirements. 

 TransMontaigne has provided correspondence to the Broward County Pollution Prevention, Remediation and Air Quality Division 

clarifying that the marine vessel loading operations are an existing source with emissions less than 10 and 25 tons because of the 

definition of Source in Subpart Y. Sourceis defined in Subpart Y as "any location where at least one dock or loading berth is bulk 

loading onto marine tank vessels...". Based on this definition, construction of gasoline loading operations at berth 6 and 

decommissioning operations at berth 7 would not trigger 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 to recordkeeping 

requirements of 63.567(j)(4) and emission estimation requirements of 63.565(1). 

 

5. What kind of emissions control device is used? How much of emissions are vented to control device? Are there commodities 

that are not covered? 

 

Permit indicates that a Marine VRU (Carbon Adsorption unit) is used to control all gasoline loading emissions at Berth 6. Control of 

marine vessel loading operations by a carbon adsorption/absorption unit was originally permitted on December 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 (0110069-016-AC) a new marine VRU at Berth 6 and decommission operations at 

Berth 7. This construction permit required use of a VRU to control emissions during loading of gasoline 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 loaded. This condition is reflected 

in our current Title V Operating Permit. By permit, TransMontaigne is required to utilize the VRU during all gasoline loading of 

marine vessels. Distillate and crude are allowed to be loaded without use of a control device. Gasoline (including ethanol), distillate 

(which includes 6 oil, diesel and biodiesel) and crude are the only products loaded onto marine vessels. 

 

6. Is submerged fill used? Is the marine vessel (tanker ship or barge) fitted with submerged fill, or is it part of the loading 

berth/loading arm? 

 

The terminal connects via piping to the marine vessel through our petroleum transfer hoses. The connection is made to the marine 

vessels manifold which is located on its deck. Once the product enters the manifold, the TransMontaigne Terminal is no longer in 

custody of that product. It becomes subject to Coast 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 submerged 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 Group 
3

RTI International 

3040 Cornwallis Rd (800 Park, C311) 

Research Triangle Park, NC 27709 

phone: (919) 316 3740 

fax: (919) 541 7155 

 
1

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 Facility MVL terminal

Karen, please see below for answers to your questions. Rebecca Esparza, Air Quality Compliance Specialist in our 

corporate office, and who is familiar with our Ingleside facility provided the data. I have copied Rebecca on this reply to 

keep her in the loop. Let us know if you have any additional 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 Facility MVL terminal

Good Afternoon, Warren: 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 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 found 

some permit information in a voided permit document: Voided Federal Operating Permit, Plains Marketing L.P., 

Ingleside Transfer Facility. Permit No. O2761. Issued 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 information found in the permit. Please review and make corrections to 

any of the statements below as needed. It sounded like the Ingleside Transfer Facility merged with another facility, 

possibly the Ingleside Petroleum Terminal on Sunray Road, so not certain if the information in the voided permit would 

still be correct for the merged facility. Any additional 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 facility was 

previously called Plains Marketing, Ingleside Transfer Facility, located at E. OF INGLESIDE @ BISHOP RD. & 

INTERCOASTAL CANAL, Ingleside TX but is thought to have merged with another facility. 

Answer - Owner: Plains Marketing, L.P.

 - Facility name: Ingleside Terminal 

Previously Ingleside Terminal and Ingleside Dock (or transfer facility) were permitted 

separately. They are not co-located but are connected 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 source 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 the facility. 

 Answer - No, the whole, current facility is not a major source of HAPs. Facility-wide total HAP 

PTE is 3.47 tpy.

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

 Yes. The site has an emission unit called “Dock”. J. Rhodes, TCEQ: Based on the information we have on this 

facility, this is correct. There are three emissions 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 and Fugitive 

Sources (EPN FUG2) are permitted by rule, 30 Texas Administrative Code §106.261. Per the Technical Review 

dated 2/4/2008, estimated emissions for 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 and 0.24 typ. Question: 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 emissions from MVL only are. EPA’s 2005 NEI/NATA database 

indicates emissions are 3.4 ton/yr total HAP from MVL (this was from the Ingleside Transfer Facility). J. Rhodes, TCEQ: 

The most recent emissions estimate we have in our regional 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 (unclassified) 0.00 ton/yr HAPS 

were reported. Question: What are the HAP emissions from the MVL operations only? 

Answer: - Products loaded at the dock are 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 device) if MVL emissions are >10/25 tons HAP? 

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

Voided Permit includes a Permit Shield. The facility is not subject to subpart Y because it is not a major source. 

The facility is not subject to MACT controls, recordkeeping, or RACT. J. Rhodes, TCEQ: Based on the current information 

we have on this facility, this is correct. Question: Confirm whether the facility is subject to subpart Y, i.e., confirm 

whether the facility has MVL emissions >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? 

 Answer: - Facility is not subject to subpart Y. It is exempted per 63.560(d). The facility 

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? Are there 

commodities that are not covered? 
3

No information on whether there are emission controls in place. J. Rhodes, TCEQ: In reviewing TCEQ files, she 

did not find any record of an emissions control device used to control emissions from marine vessel loading. Question: 

Could you confirm whether there is an emissions control device that controls marine vessel loading emissions from the 

dock. Why was the emission control device put in place? Is the emissions control device considered federally 

enforceable? Are the marine loading emission from all commodities vented to the control device, or are only certain 

commodities vented? Which commodities? 

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

7. Is submerged fill used? Is the marine vessel (tanker ship or barge) fitted with submerged fill, or is it part of the 

loading berth/loading arm? 

 Permit does not mention submerged loading. J. Rhodes, TCEQ: In reviewing TCEQ files, she did not find any 

record of what type of fill is used to load the ship/barge. Question: Does submerged loading occur, and if so, is it fitted 

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 7155
1

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, Roberta M.

Subject: FW: RTR MVL: questions on Texas Petrochemical MVL terminal

Karen, 

We are still working on a couple of your questions but I thought I would pass on what we have so far and I need to ask a 

question. Our responses are added to your questions. 

Question: Are these emission estimates correct? If not, could you confirm what the actual HAP emissions from marine 

vessel loading only were for 2005, and perhaps for 2009 as well? 

Response: We are reviewing the data you sent and there does seem to be some discrepancies. I will contact you 

tomorrow to discuss them. 

Question: Could you confirm whether the facility has MVL emissions >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 subpart 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 emissions 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 device 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 emissions? 

 Are the marine loading emissions from all commodities vented to the control device, or are only certain commodities at 

each dock vented? Which commodities?

Response: The flare is an open flare. TPC voluntarily installed the flare to reduce VOC emissions because there were no 

federal or state rules that require such control at that time (1995). The dock flare is authorized by Permit No. 22052 

and has been incorporated in TPC’s Title V Operating Permit. Our current Title V permit does not reference operating 

scenarios C-5-A1 or C-5-A2. The only operating scenario in the Title V permit is C-5-P, which lists the dock flare as the 

control device and we only have one operating scenario that we use. Can you forward to us a description on the these 

scenarios and the date on the permit you are reviewing? MTBE and DIB loadings are controlled by the dock flare, shared 

by Dock A and B. Vapor associated with all other commodities loadings are controlled by the plant flare. 

Question: Does submerged loading occur, and if so, is it fitted 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 using the flare for all unpressurized 

loading and there are no vents for pressurized loading. 

I hope this helps. I will call tomorrow to follow up on the emissions totals and to see if we can clear 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.com 
1

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 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 reviewed the facility permit but do have a few remaining questions. Union 

Oil Company of California (Unocal), Beaumont Terminal, Permit No. O1025, Issued February 4, 2008. 

I included my basic questions below, and following review of the permit, I filled in the information found in the permit. 

Any additional information you could provide to help answer the remaining questions would be much appreciated. 

Thank you, Karen Schaffner 

1. Is the facility a Major source for HAP? 

 

No information in the permit on whether major or area for HAP emissions. Likely are major for HAP since facility 

is subject to subpart Y. Question: Could you confirm whether the facility is a major 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 unloading) 

 

Yes, the facility conducts marine vessel loading. There are 3 marine loading docks: (1) main ship/barge 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 Barge dock (FLBD3); however, we are authorized to conduct loading at 

that dock. We can also conduct unloading operations 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 from marine vessel 

loading only are? 

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

 

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

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

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

 

Permit indicates the facility is subject to subpart Y, for both MACT and RACT. It is not clear whether an emission 

control device is in place for each dock. Question: Could you confirm whether the facility has MVL emissions >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?

 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? Are 

there commodities that are not covered? 

 

 Permit mentions emissions control devices SPR901 and SPR902 (thermal oxidizers). It is not clear whether 

these devices are for the SPR crude dock only, or whether the other marine loading docks are also vented 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 emission control device put in place? Is the emission control device 

considered federally enforceable? Are the marine loading 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 not load at 

dock 3. The control device was installed to comply with subpart Y. The emission control device is federally enforceable 

under the state New Source Review program. All commodities that contain HAP’s with greater than .01 psia vapor 

pressure or have a vapor pressure of greater than .05 psia are controlled. 

 

6. Is submerged fill used? Is the marine vessel (tanker 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 operation.

 

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 Specialist
3

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 7155
1

Schaffner, Karen S.

From: Smith, Zach - Lower River Region [Zach_Smith@kindermorgan.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 marine 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 applies 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 Services, Harvey Facility 

Good Afternoon, Zach: I have one additional question 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 primarily 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 while 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 7155 
1

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 Facility MVLterminal

Attachments: 2008 Emissions Sum.pdf; TR-PBR Ingleside Transfer.pdf; Photographs.pdf; Process Flow 

Diagram.pdf

Ms. Schaffner and Mr. Shedd, 

 

Attached is the information gathered this morning in order to answer the questions you had on Ingleside Transfer 

Facility MVL Terminal. I wanted to clarify that I have not visited this site, however I did search through our regional 

files to try and answer your questions. My answers are indicated in [Red].

 

A little background on the site: The last investigation conducted on the facility was an in-office investigation, 

conducted May 26, 2009, to review reported instances of Title V deviations and to verify compliance with their Title V 

Permit. The last on-site visit was conducted on March 22, 2007 and that lead investigator is no longer with The 

Agency. 

 

Plains Marketing, L.P. - Ingleside Petroleum Terminal (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) Region 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 this e-mail

 

>>> "Schaffner, Karen S." <ksschaffner@rti.org> 5/11/2010 3:50 PM >>> 

Good Afternoon, Jessica: 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 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 the information found 

in the permit. I still I have a few questions. Any 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 unloading) 
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 three emissions 

points (EPNs) located at the Ingleside Transfer Facility: EPN DOCK, EPN TANK1, and EPN FUG2. EPN TANK1 is a 210 bbl 

vertical fixed-roof storm water tank. Barge Loading: EPN DOCK and Fugitive Sources (EPN FUG2) are permitted by rule, 

30 Texas Administrative Code §106.261. Per the Technical Reivew dated 2/4/2008, estimated emissions for 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 and 0.24 typ. 

Process Diagram is attached (Attachment: Process Diagram) 

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 operations only? The 

most recent emissions estimate we have in our regional 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 (unclassified) 0.00 

ton/yr HAPS were reported (see attachment: 2008 Emissions Sum). The Air Quality Division - Emissions Assessment 

Section may have a more recent (and detailed) report of annual emissions. 

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

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

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

Voided Permit includes a Permit Shield. The facility is not subject to subpart Y because it is not a major source. 

The facility is not subject to MACT controls, recordkeeping, 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? Are 

there commodities that are not covered? 

No information on whether there are emission controls in place. Question: Could you confirm whether there 

is an emission control device that controls marine vessel loading emissions from the dock. Why was the emission 

control device put in place? Are the marine loading emission from all commodities vented to the control device, or are 

only certain commodities vented? Which commodities? In reviewing our files, I did not find any record of an emissions 

control device used to control emissions from marine vessel loading.

6. Is submerged fill used? Is the marine vessel (tanker 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 investigation on March 22, 

2007 two photographs were taken of loading operations (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 7155
1

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, 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 ST Linden 

Terminal, LLC at Ft of South Avenue in Linden NJ. 

 

Thank you Bob for directing me to the permit for the St Linden Terminal 

LLC Shoreside Facility in Linden City NJ. Looked at: ST Linden 

Terminal LLC Shoreside Facility, at 4501 Tremley Point Rd in Linden City NJ, Air Pollution 

Control Operating Permit, Minor Modification and Preconstruction Approval. Permit Activity 

Number: BOP090002. Program Interest Number: 41800. Initial Approval Dated September 29, 

2003. 

 

Am sending my basic questions below. I reviewed the permit information and filled in the 

information found in the permit. I still have a few 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. Question: 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 LOADING 

 

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

 

 Yes, conducts MVL. There are throughput 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/yr HAP. The MVL 

emissions limit for Benzene is <=0.243 ton/yr benzene. There are 

several MVL limits: <=27.05 ton/yr total VOC emissions; <=420,00 gal/hr total material 

transferred; <=35.02 lb/hr total VOC max emission rate. 

 

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

- Emission reduction requirements (i.e., control device) if MVL 

emissions are >10/25 tons HAP? CARBON ABSORPTION UNIT 

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

CEMS 

 

There is no mention of subpart Y. Question: Is the facility subject? NO If synthetic minor 

due to federally enforceable throughputs or emission 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 HAPS 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 Petroleum Hydrocarbon liquids and loading of 

VOC liquids (vp <=11.1 psia) must be directed to 

CD1 Carbon Adsorption system, that achieves a VOC Control Efficiency of 95% by wt. For 

Loading of VOC liquids (with vp <=0.02 psia) without 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 (tanker 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? SUBMERGED FILL FOR MARINE LOADING IS NOT 

REGULATED IN NEW JERSEY. EMISSIONS MUST BE CONTROLLED 

 
3

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 7155 
1

Schaffner, Karen S.

From: Smith, Zach - Lower River Region [Zach_Smith@kindermorgan.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 control them we don't necessarily know which or 

when. Our load arms are not equipped to do submerge 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, for 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 rail, 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 device 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 to control emissions from marine loading in 

the future. This is primarily to ensure that we remain a synthetic minor source of VOC 

emissions. 

I don't know the answer on submerged or bottom loading, 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 input 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 questions? These other control questions I 

actually was thinking of as separate from the subpart Y applicability questions. (1) 

Whether there is an emission control device, unrelated 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 vessel 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 Kinder Morgan EHS specialist I have been 

working with on their current permit modification application, and have included his response 

below. Please let contact me or Zach if you have any 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 preliminary answers: 
3

1. The 2006 application was designed to consolidate four separate permits into a single one 

for the facility. Prior permit numbers were 1340-00236-V7, otherwise known as the Fina Yard, 

1340-00192-V2, Hydril Yard, 1340-00146-00, East Yard, and 1340-00146-00, West Yard. 

2. The two state permits were obviously minor source permits under Part 70, therefore 

Subpart Y would not have applied. 

3. The Fina Yard Title V renewal permit application from 2003 did address Subpart Y 

applicability, with a determination of "2" 

(potentially applicable but meets exemption criteria; page 30 of the EDMS document 27742008). 

In the Emissions by Pollutant Section of this application, you can see total loading TAPs 

reported to be about 1.8 tons in the "Before" column. 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 this Title V permit to a synthetic minor 

permit. 

4. The Hydril Yard Title V renewal application from 2004 also addressed Subpart Y 

applicability, and also made a "2" determination (page 36 of the EDMS document 30774346). In 

this particular application, a Facility PTE Emissions Aggregate Report was included for all 

four yards. Total toxics PTE for the Hydril Yard was 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 applied. 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 facility met the exemption criteria in 

Subpart Y back in 1999. It would appear, if this is correct, that the second and third 

questions in Karen Schaffner's email would be moot.

Please let me know if additional information will be 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 indicated 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 would still like your input. 

Thanks! 
4

Jim 

From: Schaffner, Karen S. [mailto:ksschaffner@rti.org] 

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 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. 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 luck and talked this morning on the phone 

with someone in Dept of Env Quality who mentioned 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 below, and following review of the online 

permit information, filled in the information found in the permit. Looked at: Permit 

Consolidation and Modification. Harvey Facility, Delta 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 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 individual HAP. Entire facility limit on HAP/TAP individual 

compounds is <=9.4 ton/yr. 

Conducts MVL operations? (loading of MVL, either tanker 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 total 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., control device) if MVL 

emissions are >10/25 tons HAP? 

- Recordkeeping to confirm MVL emissions are <10/25 tons 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 year 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? Are there commodities that are not covered? 
5

 Permit does not mention any emission controls for MVL. 

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

Is submerged fill used? Is the marine vessel (tanker 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? 

 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 7155 
1

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 Facility MVL terminal

Good Afternoon, Warren: 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 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 found 

some permit information in a voided permit document: Voided Federal Operating Permit, Plains Marketing L.P., 

Ingleside Transfer Facility. Permit No. O2761. Issued 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 information found in the permit. Please review and make corrections to 

any of the statements below as needed. It sounded like the Ingleside Transfer Facility merged with another facility, 

possibly the Ingleside Petroleum Terminal on Sunray Road, so not certain if the information in the voided permit would 

still be correct for the merged facility. Any additional 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 facility was 

previously called Plains Marketing, Ingleside Transfer Facility, located at E. OF INGLESIDE @ BISHOP RD. & 

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 source 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 the facility. 

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

 Yes. The site has an emission unit called “Dock”. J. Rhodes, TCEQ: Based on the information we have on this 

facility, this is correct. There are three emissions 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 and Fugitive 

Sources (EPN FUG2) are permitted by rule, 30 Texas Administrative Code §106.261. Per the Technical Review 

dated 2/4/2008, estimated emissions for 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 and 0.24 typ. Question: 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 emissions from MVL only are. EPA’s 2005 NEI/NATA database 

indicates emissions are 3.4 ton/yr total HAP from MVL (this was from the Ingleside Transfer Facility). J. Rhodes, TCEQ: 

The most recent emissions estimate we have in our regional 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 (unclassified) 0.00 ton/yr HAPS 

were reported. Question: What are the HAP emissions from the MVL operations only? 

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

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

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

Voided Permit includes a Permit Shield. The facility is not subject to subpart Y because it is not a major source. 

The facility is not subject to MACT controls, recordkeeping, or RACT. J. Rhodes, TCEQ: Based on the current information 

we have on this facility, this is correct. Question: Confirm whether the facility is subject to subpart Y, i.e., confirm 

whether the facility has MVL emissions >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? 

6. What kind of emissions control device is used? How much of emissions are vented to control device? Are there 

commodities that are not covered? 

No information on whether there are emission controls in place. J. Rhodes, TCEQ: In reviewing TCEQ files, she 

did not find any record of an emissions control device used to control emissions from marine vessel loading. Question: 

Could you confirm whether there is an emissions control device that controls marine vessel loading emissions from the 

dock. Why was the emission control device put in place? Is the emissions control device considered federally 

enforceable? Are the marine loading emission from all commodities vented to the control device, or are only certain 

commodities vented? Which commodities? 

7. Is submerged fill used? Is the marine vessel (tanker ship or barge) fitted with submerged fill, or is it part of the 

loading berth/loading arm? 

 Permit does not mention submerged loading. J. Rhodes, TCEQ: In reviewing TCEQ files, she did not find any 

record of what type of fill is used to load the ship/barge. Question: Does submerged loading occur, and if so, is it fitted 

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 7155
1

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 terminal

Good Afternoon, Paul: Am sending some questions on the TransMontaigne Terminals, LLC - Port Everglades North 

Terminal. I reviewed some available permit information (TransMontaigne Terminals, LLC - Port Everglades North 

Terminal. 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 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 found in the permit. I 

still I have a few questions. Any additional information 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? (loading of MVL, either tanker ships or barges; not unloading) 

 Yes. 

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

Permit files show potential to emit HAP emissions from Barge Loading of 3.84 ton HAP. EPA’s 2005 NEI/NATA 

database shows 1.97 ton/yr total HAP from MVL. Question: Confirm that the potential to emit estimate includes the 

Marine VRU control efficiency, i.e., would be potential 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 emissions 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 requirements. 

5. What kind of emissions control device is used? How much of emissions are vented to control device? Are there 

commodities that are not covered? 

 Permit indicates that a Marine VRU (Carbon Adsorption unit) is used to control emissions from barge loading. 

Question: Confirm why the emission control device was put in place? Is the emission control device considered 

federally enforceable? Are the marine loading 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 (tanker ship or barge) fitted with submerged fill, or is it part of the 

loading berth/loading arm? 
2

 Permit does not mention submerged fill. The facility noted that there are no submerged 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 7155
1

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 Terminal

Good Afternoon, Christina: Am forwarding on some questions on the KinderMorgan Liquids Terminals LLC, Galena Park 

Terminal, Permit No. O988. Issuance Date: February 2, 2007. 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 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 facility is a major source of HAP. Likely is major for HAP 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 unloading) 

 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 NEI/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 correct, could you provide MVL only HAP emission estimates 

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 device) if MVL emissions are >10/25 tons HAP? 

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

Permit indicates that all of the docks are subject to MACT subpart Y; BD-3 and SD-4 are also subject to RACT. 

BD-3 and SD-4 are vented to the SD-4-VCU, a vapor combustion unit. It is not clear whether controls are in place at all of

the docks. Question: Could you confirm whether the facility has MVL emissions >10/25 ton HAP and is required to 

control HAP emissions under subpart Y, or whether the facility has MVL emissions <10/25 tons HAP and is required to 

conduct recordkeeping under subpart Y? Could you confirm whether each dock is subject to subpart Y controls or 

subpart Y recordkeeping? 

5. What kind of emissions control device is used? How much of emissions are vented to control device? Are there 

commodities that are not covered? 

 Permit mentions emission control device SD-4-VCU (this is a flare?). One of the Permit 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 loading emissions from all docks are vented to a control device. Question: 

Could you confirm whether there is an emissions control device that controls marine vessel loading emissions from each 

berth/dock? Why was each emission control device put in place? Is the emission control device considered federally 

enforceable? What is the emissions reduction efficiency achieved for marine loading emissions? Are the marine loading 

emissions from all commodities vented to the control device, or are only certain commodities at each dock vented? 

Which commodities? If flares are used, are they open flares or enclosed flares? 

6. Is submerged fill used? Is the marine vessel (tanker ship or barge) fitted with submerged fill, or is it part of the 

loading berth/loading arm? 

 Permit does not mention submerged loading. Question: Does submerged 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? 

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 7155
1

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 terminal

Good Afternoon, James: As I mentioned on the telephone, 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 have been reviewing permit information for the Texas Petrochemical Terminal in Houston TX and have reviewed 

several permit documents but do have a few remaining questions. I have looked at: (1) Permit Renewal, Technical 

Review Analysis, Texas Petrochemicals LP, Marine Dock Loading Operations, Permit No. 22052, Project No. 105000, 

Account No. HG-0562-P, Regulated Entity No.: RN100219526; and (2) Texas Petrochemicals LLC, Industrial Organic 

Chemicals, Federal Operating Permit. Permit No. O1598. Issuance Date: October 7, 2004. I included my basic questions 

below, and following review, I filled in the information found in the permit. Any additional information you could 

provide to help answer the remaining questions 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 unloading) 

 Yes, conducts marine vessel loading. The marine dock operation includes 2 docks for ships and barges. Some 

commodities are pressure-loaded and assumed to have no emissions (except degassing, which go to the Plant Flare). 

Other commodities are loaded at atmospheric pressure, 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 emissions for MVL only in the permit, not known. _ ton/yr total HAP from 

MVL. EPA’s 2005 NEI/NATA database shows HAP emissions 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 from 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 device) if MVL emissions are >10/25 tons HAP? 

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

The facility is subject to subpart Y. It is not clear whether the facility is required to comply with MACT control 

requirements (i.e., MVL emissions are >10/25 ton HAP) or the facility is subject to the recordkeeping requirements (if 

the MVL emissions are <10/25 tons HAP). P. 77 of one of the permit documents reviewed (Permit No. O1598, dated 
2

October 7, 2004) looked like MVL HAP emissions are <10/25 ton but am not certain I am interpreting correctly. 

 Question: Could you confirm whether the facility has MVL emissions >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 subpart Y controls or 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 assumed that the Flare 

achieves 98% efficiency for VOC. Vacuum-assist capture is used for barges (100% capture efficiency) and is used when 

possible for ships (95% capture efficiency). Commodities that are pressure-loaded are assumed to have no emissions; 

pressure-loaded commodities include propane, butanes, butadienes, and other compounds with 4 Carbons. MVL at 

atmospheric pressure is conducted for MTBE, and diisobutylene (DIB), and loading occurs to barges with vacuum-assist 

and to ships with vacuum-assist when possible. From one of the facility permit documents, it showed that emissions 

from C-5 had “operating scenarios” C-5-A1 and C-5-A2 that did not have control devices, and showed that operating 

scenario C-5-P2 is controlled with the Flare. I assume that these are operating scenarios at the 2 docks, related to the 

barges, ships, and pressure-loaded commodities noted here. Question: Is the Marine Loading Flare an open flare or an 

enclosed flare? What was the reason the MVL emissions 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 device 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 emissions? Are the marine loading 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 (tanker 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 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 7155
1

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 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 Shedd at U.S. 

EPA/OAR/OAQPS/SPPD in Research Triangle Park, NC. 

In reviewing the permit and in talking to IN IDEM staff, I filled in the information found. I highlighted areas where I still 

have questions. Any additional information you could provide would be much appreciated. Thank you, Karen 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 on the emission units. The 

facility has agreed to limit their HAP emissions below Title V limits. Federally enforceable throughput limits are in place 

for neat ethanol, gasoline, and distillate. (Unrestricted 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 compliance date 

(1999). 

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

 Yes, loading barges. 

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

 3.47 ton/yr total HAP from MVL, reflecting 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 device) if MVL emissions are >10/25 tons HAP? 

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

Permit does not mention subpart Y. Curiously, the permit explicitly states that the facility is not subject to 

subpart R, Gasoline Distribution, and is not subject 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 certain I understand 

this since the permit states the facility is not subject to subpart R. Is the facility subject to subpart R, as a major 

source(?), or not? From J. Wilkins, IDEM: The permit includes some compliance testing provisions 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? Are there 

commodities that are not covered? 

 Permit does not mention any emission control device for barge loading. (There is a portable vapor combustor 

on truck loading rack that is subject to NSPS subpart XX, Bulk Gasoline Terminals.) Question: Is there a control device 

for barge loading at the facility, and does it cover all commodities or only certain ones (the control device question here 
2

is separate from the “subject to subpart Y” question, i.e., a facility could have a control device unrelated to subpart Y 

requirements)? If yes, why was the emission control put in place? Is the emission control device considered federally 

enforceable? 

6. Is submerged fill used? Is the marine vessel (tanker 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 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? 

 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
1

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 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 reviewed the facility permit but do have a few remaining questions. Union 

Oil Company of California (Unocal), Beaumont Terminal, Permit No. O1025, Issued February 4, 2008. 

I included my basic questions below, and following review of the permit, I filled in the information found in the permit. 

Any additional information you could provide to help answer the remaining questions would be much appreciated. 

Thank you, Karen Schaffner 

1. Is the facility a Major source for HAP? 

No information in the permit on whether major or area for HAP emissions. Likely are major for HAP since facility 

is subject to subpart Y. Question: Could you confirm whether the facility is a major source for HAP, an area 

source, or a minor source? 

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

Yes, the facility conducts marine vessel loading. There are 3 marine loading docks: (1) main ship/barge 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 device) if MVL emissions are >10/25 tons HAP? 

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

Permit indicates the facility is subject to subpart Y, for both MACT and RACT. It is not clear whether an emission 

control device is in place for each dock. Question: Could you confirm whether the facility has MVL emissions >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? Are there 

commodities that are not covered? 

 Permit mentions emissions control devices SPR901 and SPR902 (thermal oxidizers). It is not clear whether 

these devices are for the SPR crude dock only, or whether the other marine loading docks are also vented 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 emission control device put in place? Is the emission control device 

considered federally enforceable? Are the marine loading 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 (tanker 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 7155
1

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 Facility MVL terminal

Good Afternoon, Jessica: 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 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 the information found 

in the permit. I still I have a few questions. Any 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 unloading) 

 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 operations only? 

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

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

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

Voided Permit includes a Permit Shield. The facility is not subject to subpart Y because it is not a major source. 

The facility is not subject to MACT controls, recordkeeping, or RACT. 

5. What kind of emissions control device is used? How much of emissions are vented to control device? Are there 

commodities that are not covered? 

No information on whether there are emission controls in place. Question: Could you confirm whether there is 

an emission control device that controls marine vessel loading emissions from the dock. Why was the emission control 

device put in place? Are the marine loading emission from all commodities vented to the control device, or are only 

certain commodities vented? Which commodities?

6. Is submerged fill used? Is the marine vessel (tanker 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 7155
1

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 California (Unocal), Beaumont Terminal, Permit No. O1025, Issued February 

4, 2008. 

I included my basic questions below, and following review of the permit, I filled in the information found in the permit. 

Any additional information you could provide to help answer the remaining questions would be much appreciated. 

Thank you, Karen Schaffner 

1. Is the facility a Major source for HAP? 

No information in the permit on whether major or area for HAP emissions. Likely are major for HAP since facility 

is subject to subpart Y. Question: Could you confirm whether the facility is a major source for HAP, an area 

source, or a minor source? 

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

Yes, the facility conducts marine vessel loading. There are 3 marine loading docks: (1) main ship/barge 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 device) if MVL emissions are >10/25 tons HAP? 

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

Permit indicates the facility is subject to subpart Y, for both MACT and RACT. It is not clear whether an emission 

control device is in place for each dock. Question: Could you confirm whether the facility has MVL emissions >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? Are there 

commodities that are not covered? 

 Permit mentions emissions control devices SPR901 and SPR902 (thermal oxidizers). It is not clear whether 

these devices are for the SPR crude dock only, or whether the other marine loading docks are also vented 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 emission control device put in place? Is the emission control device 
2

considered federally enforceable? Are the marine loading 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 (tanker 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 7155
1

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 terminal

Good Afternoon, Linda: I contacted Armando Bayoneto and Gary Ackerman, both of TCEQ to ask some follow-up 

questions regarding a Marine Vessel Loading (MVL) terminal 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 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. My note and questions for Armando and Gary are below. 

I have been working with TCEQ to collect permit information for the Texas Petrochemical Terminal in Houston TX and 

have reviewed several permits that TCEQ shared but do have a few remaining questions. I included my basic questions 

below, and following review of the permit, I filled in the information found in the permit. Any additional information 

you could provide to help answer the remaining questions 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 unloading) 

 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, not known. _ 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 device) if MVL emissions are >10/25 tons HAP? 

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

The facility is subject to subpart Y. It is not clear whether the facility is required to comply with MACT control 

requirements (i.e., MVL emissions are >10/25 ton HAP) or the facility is subject to the recordkeeping requirements (if 

the MVL emissions are <10/25 tons HAP). P. 77 of one of the permit documents I reviewed (Permit No. O1598, dated 

October 7, 2004) looked like MVL HAP emissions are <10/25 ton but am not certain I am interpreting correctly. 

 Question: Could you confirm whether the facility has MVL emissions >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? Are there 

commodities that are not covered? 

 Permit shows that a Marine Loading Flare is used to control MVL emissions. It is assumed that the Flare 

achieves 98% efficiency for VOC. Vacuum-assist capture is used for barges (100% capture efficiency) and is used when 

possible for ships (95% capture efficiency). Commodities that are pressure-loaded are assumed to have no emissions. 

From one of the facility permit documents, it showed that C-5-A1 and C-5-A2 did not have control devices, and that C-5-

P2 is controlled with the Flare. I assume that these are operating scenarios related to the barges, ships, 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 Flare – was the flare installed and the MVL emissions vented to comply 

with a state rule or a Federal rule? Is the emission 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 (tanker 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 7155
1

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.state.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 with Steve Shedd at U.S. EPA/OAR/OAQPS/SSPD in Research 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 the St Linden Terminal LLC Shoreside Facility in Linden City NJ. Looked 

at: ST Linden Terminal LLC Shoreside Facility, at 4501 Tremley Point Rd in Linden City NJ, Air Pollution Control Operating 

Permit, Minor Modification and Preconstruction Approval. Permit Activity Number: BOP090002. Program Interest 

Number: 41800. Initial Approval Dated September 29, 2003. 

 

Am sending my basic questions below. I reviewed the permit information and filled in the information found in the 

permit. I still have a few 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? 

 Permit indicates the facility’s PTE HAP is 0.243 ton/yr. I assume this is considering emissions controls. 

Question: 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? 

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

 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 MVL emissions limit for Benzene is <=0.243 ton/yr benzene. 

 There are several MVL limits: <=27.05 ton/yr total VOC emissions; <=420,00 gal/hr total material transferred; <=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 device) if MVL emissions are >10/25 tons HAP? 

- Recordkeeping to confirm MVL emissions are <10/25 tons 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 year 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? Are 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 achieves a VOC Control Efficiency of 95% by wt. For Loading of VOC 
2

liquids (with vp <=0.02 psia) without 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 (tanker 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 7155
1

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 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 luck and talked this morning on the phone with someone in Dept of 

Env Quality who mentioned 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 below, and 

following review of the online permit information, filled in the information found in the permit. Looked at: Permit 

Consolidation and Modification. Harvey Facility, Delta 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 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 individual 

HAP. Entire facility limit on HAP/TAP individual compounds is <=9.4 ton/yr. 

Conducts MVL operations? (loading of MVL, either tanker 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 total 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., control device) if MVL emissions are >10/25 tons HAP? 

- Recordkeeping to confirm MVL emissions are <10/25 tons 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 year 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? Are there 

commodities that are not covered? 

 Permit does not mention any emission controls for MVL. Question: Is there an emissions control device for 

marine vessel loading HAP emissions? 

Is submerged fill used? Is the marine vessel (tanker 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 7155
1

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 and am forwarding on some questions on the Marathon Petroleum 

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 found in the permit. I 

still I have a few questions. Any additional information 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 units. The 

facility has agreed to limit their HAP emissions below Title V limits. Federally enforceable throughput limits are in place 

for neat ethanol, gasoline, and distillate. (Unrestricted 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 unloading) 

 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 on the emission units. 

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

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

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

Permit does not mention subpart Y. Curiously, the permit explicitly states that the facility is not subject to 

subpart R, Gasoline Distribution, and is not subject 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 certain I understand 

this since the permit states the facility is not subject to subpart R. Is the facility subject to subpart R, as a major 

source(?), or not? 

What kind of emissions control device is used? How much of emissions are vented to control device? Are there 

commodities that are not covered? 

 Permit does not mention any emission control device for barge loading. (There is a portable vapor combustor 

on truck loading rack that is subject to NSPS subpart XX, Bulk Gasoline Terminals.) Question: Is there a control device 

for barge loading at the facility, and does it cover all commodities or only certain ones? 

Is submerged fill used? Is the marine vessel (tanker 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