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OAR Box 1672 

Prepped by Charmelle Mathews 

o 

Document Number: 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 22 of 132 
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• a, 

AS?-13 

TO: 

FROM: 

DATE: 

MEMORANDUM 

Project File 

Organic Liquids Distribution NESHAP 

ESD Project No. 96/05 

Bernd Haneke and Greg LaFlam 

Pacific Environmental Services, IriC? 

December 10,1999 

SUBJECT: Site Visit to Union Carbide's Texas City Marine Terminal 

I. Purpose 

The purpose of this site visit was to tour the facility in an effort to collect information 

related to air emissions from the operations. This work is in support ofthe development of 

national emission standards for hazardous air pollutants (NESHAP) for the organic liquids 

distribution (non-gasoline) source category. 

II. Location and Date 

Union Carbide Corporation-Texas City Marine Terminal 

2800 Loop 197 South 

Texas City, Texas 77590 

October 22, 1998 (8:55-11:30 a.m.) 

III. Participants 

Union Carbide Corporation 

Stacy Dotson - Advanced Distribution Engineer 

Benoit Lamarche - HSE Coordinator 

Dana Neely - Senior Environmental Engineer 

John Soice - Air Issues Manager 

U.S. Environmental Protection Agency (EPA) 

Steve Shedd - OAQPS/ESD/WCPG, Research Triangle Park, NC 

Texas Natural Resource Conservation Commission (TNRCC) 

Sune Nantah - Environmental Investigator, Air Program 
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Site Visit Memo-Union Carbide 

December 10,1999 - Draft Report 

Page 2 

Pacific Environmental Services. Inc. (PES) 

Bernd Haneke - Research Triangle Park, NC 

Greg LaFlam - Research Triangle Park, NC 

IV. Pre-Tour Discussion 

Union Carbide Corporation 

Upon entering the Union Carbide Texas City Main Plant, the EPA/PES project team was 

shown a safety video for the Texas City Marine Terminal. Following this video, Union Carbide 

representatives drove the EPA/PES project team to the Marine Terminal. At this facility Union 

Carbide representatives and project team members assembled in the conference room. 

EPA Introduction 

After the participants introduced themselves, Steve Shedd, EPA, began the meeting by 

discussing the background ofthe EPA's regulation of hazardous air pollutant (HAP) emissions. 

Prior to the Clean Air Act Amendments of 1990 (CAAA), regulations were based on individual 

HAP and a limited number of regulations were completed. The CAAA included a HAP list and 

prescribed that rules be developed for categories of sources (industrial types). The stringency of 

the Organic Liquids Distribution (non-Gasoline) rule (for existing sources) will be based on 

"floor" levels of control representing the control achieved by the average ofthe top 12 percent of 

facilities in this category. The standards are slated to be proposed in 1999, with promulgation of 

the final rule in November 2000. 

Mr. Shedd mentioned that the EPA project team had selected the Union Carbide 

Corporation's Texas City Marine Terminal based upon the location ofthe facility and because it 

contained data of interest to the development ofthe Organic Liquids Distribution NESHAP. He 

also described the EPA's procedures for handling information that the company considers to be 

confidential business information (CBI). The company will have an opportunity to review the 

draft site visit report prepared by PES, and to comment on its accuracy and identify any CBI. 

The report, with any CBI removed, will be made a part ofthe public record for this rulemaking. 

The representatives of Union Carbide were asked if any ofthe information presented was 

confidential and no CBI was identified during or after the meeting. 

Facility Description 

Union Carbide's Texas City Marine Terminal is located on the Houston Ship Channel 

near Texas City. The facility is also located close to Union Carbide's Texas City Main Plant, but 

the company does not consider the two facilities to be collocated. The terminal operates on a 24 

hr/day, 7 day/week, 52 wk/yr schedule. The terminal serves as a distribution center for all 

mainland Union Carbide facilities, and its main customer is the Texas City Main Plant. 
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Site Visit Memo-Union Carbide 

December 10,1999 - Draft Report 

Page 3 

Furthermore, it is Union Carbide's only deep water terminal. The terminal consists of deep 

water tanker docks, barge docks, and so-called "overland" racks that load both tank trucks and 

railcars. Chemicals are received via pipeline or are unloaded from marine and overland transport 

vessels. Some chemicals are stored at the terminal until they are pumped to the Texas City Main 

Plant or loaded into another transport vessel. Other chemicals are transloaded; that is, material is 

unloaded from one transport vessel, such as a ship, into a tank and then loaded into another 

transport vessel, such as a tank truck or railcar. 

As chemicals are loaded, the vapors are either vented to the atmosphere, routed to a flare, 

or collected in a vapor return line that pipes the vapors back to the storage tank. Chemicals that 

have vapor pressures greater than or equal to 0.51 psia at 88 degrees F are routed to a flare. The 

terminal has approximately 120 storage tanks in service, of which 22 are used to store "surveyed 

liquids" (defined in the EPA's 1998 industry survey as having 1,000 ppmw of HAP or more and 

a vapor pressure of 0.1 psia or more). The breakdown is about 20 internal floating roof, 4 

external floating roof, and the remainder fixed-roof tanks. Two of these fixed-roof tanks have 

vapor balance capability for use during barge loading. 

MACT Coverage 

Union Carbide's terminal is subject to the emissions estimation and recordkeeping 

requirements ofthe Marine Vessel Loading MACT rule (40 CFR Part 63, subpart Y), although 

the HAP emissions from the terminal are below the level at which additional emission controls 

are required. No HAP are unloaded from marine vessels at the terminal. An ethanol denaturing 

facility at the terminal will be covered by the Miscellaneous Organic NESHAP (MON). 

According to the survey response submitted by Union Carbide, tank truck and railcar 

loading racks as well as various storage tanks are expected to be affected by the future Organic 

Liquids Distribution NESHAP. 

Equipment Leaks 

The EPA/PES project team requested information regarding the equipment leak emission 

factors that the company uses to calculate fugitive emissions. Union Carbide representatives 

informed the project team that it was using modified SOCMI emission factors (without 

ethylene), issued by the TNRCC. 

Control Equipment 

The facility has three flare systems in operation, two of which are associated with OLD 

operations. A water scrubber is also in operation at the ethanol denaturing facility (the 

denaturants are HAP). 

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Site Visit Memo-Union Carbide 

December 10,1999 - Draft Report 

Page 4 

The EPA/PES project team requested information regarding the costs of operating the 

flares at the terminal, but only wide ranging estimates and not actual figures were available. As 

actual figures were not available, no figures are presented in this memo. 

V. Tour of the Facility 

Loading Racks 

The first stop on a driving tour ofthe facility were tank truck/railcar loading rack nos. 5, 

6, and 7. Vinyl acetate (vapor pressure ~ 1.78 psia at 70°F) was observed being loaded into a 

railcar at rack no. 6. Loading emissions from rack nos. 6 and 7 are controlled by a flare, while 

rack no. 5 is uncontrolled. Low volatility liquids (v.p. < 0.51 psia at 88 °F) are loaded only at 

rack no. 5, in response to emission requirements in the TNRCC regulations. 

The group spent considerable time at these racks so that the project team could observe 

and ask questions about the loading equipment and procedures. The quantity of liquid being 

loaded into tank trucks is monitored in two ways. The primary means is a truck scale situated at 

each truck loading position. As a backup, the driver also uses a gauge rod inserted into the tank. 

For railcars, only a magnetic gauge rod is used. 

Liquid is loaded through an opening in the top ofthe tank using a top loading vapor 

recovery adapter. An OPW "donut" type seal is lowered into the opening and inflated to provide 

a tight seal around the opening. Then a drop tube (to provide submerged loading ofthe liquid) 

and a probe for overfill protection are attached through this adapter. Early versions ofthe donut 

seal had to be replaced every 2 months, but more recent models have been more durable. 

Vapors are returned to the control device through a third connector on the top ofthe tank, 

which includes a pressure gauge. Loading is performed under a vacuum of about 10 inches of 

water (to prevent vapor leakage as loading is taking place). 

Flare 

The group next observed the vapor control device used to control emissions from rack 

nos. 6 and 7, an enclosed flare manufactured by John Zink Company. This flare also controls 

marine (ship and barge) loadings. Natural gas is used as a supplemental fuel; however, there is 

no monitoring or recording ofthe combustion temperature. The system has an automatic 

shutdown feature in case of excessive temperature. Due to the high frequency of loadings, the 

flare is always in operation. 

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Site Visit Memo-Union Carbide 

December 10,1999 - Draft Report 

Page 5 

VI. Followup Discussion 

Following the facility tour, the group reconvened in the terminal's conference room. The 

EPA/PES project team requested that the company provide them with a copy of two documents: 

1) Union Carbide's 1995 flexible permit from the TNRCC (included as Attachment 1), and 2) the 

company's manual describing the operation ofthe loading rack loading and emission control 

systems. The company personnel agreed to supply these documents. 

No other significant discussion occurred, and the site visit was concluded at 11:30 a.m. 

S~ 
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Barry R. McBee, Chairman 

R.B."Ralph" Mirquez, Commissioner f=fc^B>] UNCONTROLLED COPY 

John M. Baker, Commissioner 

Dan Pearson, Executive Director 

TEXAS NATURAL RESOURCE CONSERVATION COMMISSION 

Protecting Texas by Reducing and Preventing Pollution 

May 6, 1996 

Ms. Dana M. Neely 

Senior Environmental Engineer 

UNION CARBIDE CORPORATION 

P.O. Box 471 

Texas City, Texas 77592-0471 

Re: Permit Amendment 

Permit No. 3284 

Texas City Marine Terminal 

Texas City, Galveston County 

Account ID No. GB-0077-H 

Dear Ms. Neely: 

This is in response to your letter dated September 5, 1995 and permit application, Form PI-1, 

concerning the proposed amendment to Permit No. 3284. We understand that you propose to 

consolidate marine terminal Permit Nos. 2197, 2238, 2346, 2788, 4938, 5439, 5729, and 22068 

into a flexible permit. We also understand that you will implement the 28 RCT fugitive 

monitoring program, monitor pump and compressor seals at 500 ppmv each quarter, and provide 

an overall volatile organic compound reduction of 556 tons per year. 

This will acknowledge that your application for the above-referenced amendment is technically 

complete as of December 8, 1995. Pursuant to 30 TAC Section 116.116(a) (Regulation VI), 

Permit No. 3284 is hereby amended and converted into a flexible permit. Enclosed are the 

revised Special Conditions and an "Emission Sources - Emission Caps and Individual 

Limitations" table. 

This amendment will be automatically void upon the occurrence of any of the following, as per 

§116.115(b)(1): 

1. Failure to begin construction of the changes authorized by this amendment within 

18 months from the date of this authorization. 

2. Discontinuance of construction of the changes authorized by this amendment for a period 

of 18 consecutive months or more. 

P.O. Box 13087 • Austin, Texas 78711-3087 • 512/239-1000 

prir.:c\i .ni recvi'trd ;MCer -jjin^ sov-bascti inx 

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P.8 

Ms. Dana M. Neely 

Pase? ' UNCONTROLLED COPY 

May 6, 1996 

Permit No. 3284 

3. Not completing the changes authorized by this amendment within a reasonable time. 

We have enclosed two operations certification forms (Form PI-3A and Form PI-3B). 

Section 116.110(b) requires you to certify that operations addressed in this permit are in 

conformance with representations in the permit application. Please file these certifications with 

both the Texas Natural Resource Conservation Commission (TNRCC) New Source Review 

Division in Austin and the appropriate TNRCC Regional Office in a timely manner. 

Your cooperation in this matter is appreciated. If you have further questions, please contact 

Mr. Paul E. Mix, P.E., of our Office of Air Quality, New Source Review Division at 

(512) 239-1564. 

Sincerely, 

)an Pearson 

Executive Director 

Texas Natural Resource Conservation Commission 

DP/PM/js 

Enclosures 

cc: Ms. Karen Atkinson, Air Program Manager, Houston 

Mr. Ron Schultz, Director, Pollution Control Division, Galveston County Health District, 

La Marque 

€ 
P.9 

TEXAS NATURE RESOURCE CONSERVON COMMISSION 

AIR QUALITY - FLEXIBLE PERMIT 

A PERMIT IS HEREBY ISSUED TO 

UNION CARBIDE CORPORATION ^ 

AUTHOR/ZING THE.CONTINUED OPERATION OF <0£^ " 

Texas City Marine Terminal ^vo^J^ 

LOCATED AT \ # 

Texas City, Galveston County, Texas 

LATITUDE 29° 22' 00 " LONGITUDE 094 ° 57 ! 00 " 

1.Tie facilities covered by this permit shall be constructed and operated as specified in the application for the permit. All representations regarding construction 

plans and operation procedures contained in the permit application shall be conditions upon which the permit is issued, variations from these representations 

shall be unlawful unless the permit holder first makes application to the Executive Director of the Texas Natural Resource Conservation Commission (TNRCC 

or Commission) to amend this permit in that regard and such amendment is approved. It shall be unlawful for any person to vary from such representation or 

flexible permit provision if the change will cause a change in the method of control of emissions, the character of the emissions, or will result in a significant 

increase in emissions, unless application is made to the TNRCC Executive Director to amend the flexible permit in that regard and such amendment is approved 

by the Executive Director. (30 TAC 116.721) 

2. Voiding of Permit A flexible permit or flexible permit amendment under this subchapter is automatically void if the holder fails to complete construction as 

specified in the flexible permit Upon request, the Executive Director may grant a one time 12-month extension of the date to complete construction. This section 

does not aoply to physical or operational changes allowed without an amendment under §116.721 of this title (relating to Amendments and Alterations). 

(30 TAC 1 ^.715(c)(1)) 

3. Construction Progress. The start of construction, construction interruptions exceeding 45 days, and completion of construction shall be reported to the 

appropriate regional office of the TNRCC not later than 15 working days after occurrence ofthe event. (30 TAC 116.715(c)(2)) 

4. Start-up Notification. The appropriate Air Program Regional Office of the TNRCC and any local program having jurisdiction shall be notified prior to the 

commencement of operations of the facilities authorized by the permit in such a manner that a representative of the TNRCC may be present. Phased construction, 

which may involve a series of facilities commencing operations at different times, shall provide separate notification for the commencement of operations for each 

facility. (30 TAC 116.715(c)(3)) 

5. Sampling Requirements. If sampling of stacks or process vents is required, the flexible permit holder shall contact the TNRCC Office of Air Quality prior to 

sampling to obtain the proper data forms and procedures. All sampling and testing procedures must be approved by the Executive Director and coordinated with 

the appropriate Air Program Regional Office of the TNRCC. The flexible permit holder is also responsible for providing sampling facilities and conducting the 

sampling operations or contracting with an independent sampling consultant. (30 TAC 116.715 (c)(4)) 

6. Equivalency of Methods. It shall be the responsibility of the flexible permit holder to demonstrate or otherwise justify the equivalency of emission control 

methods, sampling or other emission testing methods, and monitoring methods proposed as alternatives to methods indicated in the conditions of the flexible 

permit. Alternative methods shall be applied for in writing and must be reviewed and approved by the Executive Director prior to their use in fulfilling any 

requirements of the permit. (30 TAC 116.715(c)(5)) 

7. Recordkeeping. A copy of the flexible permit along with information and data sufficient to demonstrate continuous compliance with the emission caps and 

individual emission limitations contained in the flexible permit shall be maintained in a file at the plant site and made available at the request of personnel frorr 

the TNRCC or any air pollution control program having jurisdiction. For facilities that normally operate unattended, this infonnation shall be maintained at the 

nearest staffed location within Texas specified by the permit holder in the permit application. This information may include, but is not limited to, emission cap anc 

individual emission limitation calculations based on a 12-month rolling basis and production records and operating hours. Additional recordkeeping requirement: 

may be specified in special conditions attached to the flexible permit. Information in the file shall be retained for at least two years following the date that the 

information or data is obtained. (30 TAC 116.715 (c)(6)) 

6. Maximum Allowable Emission Rates. A flexible permit covers only those sources of emissions and those air contaminants listed in the table entitles 

"Emission Sources - Emissions Caps and Individual Emission Limitations" attached to the flexible permit. Flexible permitted sources are limited to the ernissior 

limits and other conditions specified in the table attached to the flexible permit (30 TAC 116.715 (c)(7)) 

9. Emission Cap Readjustment If a schedule to install additional controls is included in the flexible permit and a facility subject to such a schedule is takei 

out of service, the emission cap contained in the flexible permit will be readjusted for the period the unit is out of service to a level as if no schedule had beei 

established. Unless a special condition specifies the method of readjustment of the emission cap, a permit alteration shall be obtained. (30 TAC 116.715 (c)(8) 

10. Maintenance of Emission Control. The facilities covered by the flexible permit shall not be operated unless all air pollution emission capture and abatemen 

equipment is maintained in good working order and operating properly during normal facility operations. Notification for upsets and maintenance shall be madi 

in accordance with §101.6 and §101.7 of this title (relating to Notification Requirements for Major Upset and Notification Requirements for Maintenance). 

(30 TAC 116.715 (c)(9)) 

11. Compliance with Rules. Acceptance of a flexible permit by a permit applicant constitutes an acknowledgement and agreement that the holder will compl 

with all Rules, Regulations, and Orders of the Commission issued in conformity with the Texas Clean Air Act and the conditions precedent to the granting of th 

permit. If more than one state or federal rule or regulation or flexible permit condition are applicable, then the most stringent limit or condition shall govern an 

be the standard by which compliance shall be demonstrated. Acceptance includes consent to the entrance of Commission employees and agents into th 

permitted premises at reasonable times to investigate conditions relating to the emission or concentration of air contaminants, including compliance with the flexibl 

permit. (30 TAC 116.715 (c)(10)) 

12. This permit may be appealed pursuant to Section 263.36 of the General Rules of the TNRCC and Section 382.032 of the TCAA. Failure to take such appe; 

constitutes acceptance by the applicant of all terms of the permit. (Tex. Gov't Code Ann. § 2001, et sea.) 

13. This permit may not be transferred, assigned or conveyed by the holder except as provided by rule. (30 TAC 116.110(c)) 

14. This permit expires 10 years from date of issuance unless renewed as provided in Section 382.055 of the TCAA unless a shorter time period is specifie 

in the special conditions of this permit. 

15. There may be additional special conditions attached to a flexible permit upon issuance or amendment ofthe permit. Such conditions in a flexible pern 

may be more restrictive than the requirements of Title 30 of the Texas Administrative Code. (30 TAC 116.715(d)) 

16. Emissions from this facility must not cause or contribute to a condition of 'air pollution' as defined in Section 382.003(3) of the Texas Clean Air Act (TCA. 

or violate Section 382.085 ofthe TCAA. If the Executive Director determines that such a condition or violation occursxthe holder shall implement addition 

abatement measures as necessary to control or prevent the condition or violation. 

PERMIT 323 4 

DATE 5-6-96 

Texas Natural Resour 

n 

, ctor 

servation Commission 
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SPECIAL CONDITIONS y. 

Permit No. 3284 «*tf^^^ 

HVOSSION CAPS AND INDIVIDUAL EMISSION LIMITATIONS 

1. This permit covers only those sources of emissions listed in the attached table entitled 

"Emission Sources - Emission Caps and Individual Emission Limitations," and those 

sources are limited to the emission caps and other conditions specified in that attached table. 

OPERATING CONDITIONS AND PARAMETERS 

2. Flares shall be designed and operated in accordance with Title 40 Code of Federal 

Regulations Part 60.18 (40 CFR 60.18) including specifications of minimum heating value 

of the waste gas, maximum tip velocity, and pilot flame monitoring. If necessary to insure 

adequate combustion, sufficient fuel gas shall be added to make the gases combustible. An 

infrared monitor is considered equivalent to a thermocouple for flame monitoring purposes. 

3. Barge, ship, and loading controls are to be in place no later than November 15, 1996. 

4. All supplemental fuel gas to the flares shall contain no more than 20 ppmv or 1.25 grains 

of total sulfur/100 scf. 

5. Chemicals handled at the facility represented in the permit application must meet one of the 

following criteria: 

A. The chemical must appear on the "Approved Chemicals List" or 

B. The proposed chemical off-site concentration, predicted by Screen 2 Model for all 

sources, shall be less than two times the Texas Natural Resource Conservation 

Commission (TNRCC) Effects Screening Level (ESL) at the nearest off-site receptor. 

ESLs shall be those published on the TNRCC ESL list dated April 10, 1995. If the 

ESL list of April 10, 1995 does not include the compound to be added, the ESL shall 

be obtained in writing from the Toxicology and Risk Assessment Section of the 

TNRCC. 

C: This flexible permit does not preclude authorizations available under 

30 TAC Section 116.211. 

Data and supporting documentation demonstrating that the proposed chemical meets one of 

the above requirements shall be kept on file and be made available upon request to 

representatives of the TNRCC and local programs having jurisdiction. The handling of any 

other chemicals shall be prohibited without prior approval of the TNRCC Executive 

Director. 

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p. 11 

SPECIAL CONDITIONS 

Permit No. 3284 . ...„AUTDn U F_D COPV 

Page 2 UNCOKTOOUfl) 

6. No single chemical may be stored in more than 10 percent of the terminal's storage tanks 

at any specific time. The only exceptions to this are ethanol and ethylene glycol, which 

may each be stored in up to 20 percent of the terminal's storage tanks. 

7. Carbon canisters shall be used in conjunction with Ethyl and Butyl Acrylate Tanks, Tank 

Nos. L-2 and L-7, for odor control. Carbon canisters shall be changed once per year. 

8. When in acetic acid service, Storage Tank No. 3753 shall vent to a caustic scrubber having 

a caustic concentration greater than

 lA weight percent or more in order to assure 99 percent 

neutralization of the acetic acid. The caustic solution shall be replaced after the low 

concentration alarm is triggered at 2 percent, but before the caustic concentration reaches 

Vi weight percent. 

In order to demonstrate compliance with the control efficiency of the acetic acid scrubber, 

the conductivity of the scrubbing liquid shall be recorded prior to each vessel containing 

acetic acid being loaded into Tank No. 3753. Tank No. 3753 may not accept acetic acid 

if the percent caustic in the scrubbing liquid is less than

 xh weight percent. These records 

shall be made available to representatives of the TNRCC upon request. 

9. Vapors associated with the loading of butyl acrylate and ethyl acrylate shall be captured by 

a vapor balance system. When used, the vacuum loading system for any chemical shall 

have a vacuum of at least 1.5 inch water column and the vent shall be routed to a control 

device achieving a minimum of 98 percent removal efficiency,. Loading system vacuum 

shall be measured once during loading at a location upstream of the detonation arrestor. 

Measurements shall be logged and records of these logs shall be maintained in accordance 

with Special Condition No. 12. 

STORAGE AND LOADING OF VOLATILE ORGANIC COMPOUNDS (VOC) 

10. A. For any tank equipped with a floating roof, the floating roof shall be equipped with one 

of the following closure devices between the wall of the storage vessel and the edge of 

the internal floating roof: (1) a liquid-mounted seal, (2) two continuous seals mounted 

one above the other, or (3) a mechanical shoe seal. Installation of the equivalent 

control requires prior review and approval by the TNRCC Executive Director. 

/ / 
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SPECIAL CONDITIONS 

Permit No. 3284 

Page 3 UNCONTROLLED COPY 

B. An open-top tank containing a floating roof (external floating roof tank) which uses 

double seal or secondary seal technology shall be an approved control alternative to an 

internal floating roof tank provided the primary seal consists of either a. mechanical 

shoe seal or a liquid-mounted seal and the secondary seal is rim-mounted. A 

weathershield is not approvable as a secondary seal unless specifically reviewed and 

determined to be vapor-tight. 

C. For any tank equipped with a floating roof, the holder of this permit shall follow 

40 CFR 60.113b, Testing and Procedures, to verify seal integrity. Additionally, the 

permit holder shall follow 40 CFR 60.115b, Reporting and Recordkeeping 

Requirements, to provide records of the dates seals were inspected, seal integrity, and 

corrective actions taken. 

D. The floating roof design shall incorporate sufficient flotation to conform to the 

requirements of API Code 650, or an equivalent degree of flotation, except that an 

internal floating cover need not be designed to meet rainfall support requirements and 

the materials of construction may be steel or other materials. 

E. Uninsulated tank exterior surfaces exposed to the sun shall be white or aluminum. 

F. Operation without visible liquid leaks or spills shall be maintained at all 

loading/unloading facilities regardless of vapor pressure. This does not apply to 

momentary dripping associated with the initial connection or disconnection of fittings. 

Sustained dripping from fittings during loading/unloading operations is not permitted. 

Any liquid spill that occurs during loading/unloading activities shall be reported 

pursuant to Sections 101.6 or 101.7 of the TNRCC General Rules and shall be cleaned 

up immediately to minimize air emissions. 

PIPING. VALVES. FLANGES. PUMPS. AND COMPRESSORS IN VOC SERVICE -

INTENSIVE DIRECTED MAINTENANCE 

11. Except as may be provided for in the special conditions of this permit, the following 

requirements apply to the above-referenced equipment. 

A. These conditions shall not apply (1) where the VOC have an aggregate partial pressure 

or vapor pressure of less than 0.044 psia at 68°F or (2) operating pressure is at least 

5 kilopascals (0.725 psi) below ambient pressure. Equipment excluded from this 

condition shall be identified in a list to be made available upon request. 

/? 
P.13 

SPECIAL CONDITIONS 

Permit No. 3284 ««^ w 

pag= 4 UNCONTROLLED COPY 

B. Construction of new and reworked piping, valves, pump systems, and compressor 

systems shall conform to applicable ANSI, API, ASME, or equivalent codes. 

C. New and reworked underground process pipelines shall contain no buried valves such 

that fugitive emission monitoring is rendered impractical. 

D. To the extent that good engineering practice will permit, new and reworked valves and 

piping connections shall be so located to be reasonably accessible for leak-checking 

during plant operation. Non-accessible valves, as defined by Regulation V, shall be 

identified in a list to be made available upon request. 

E. New and reworked piping connections shall be welded or flanged. Screwed 

connections are permissible only on piping smaller than two-inch diameter. No later 

than the next scheduled quarterly monitoring after initial installation or replacement, 

all new or reworked connections shall be gas-tested or hydraulically-tested at no less 

than normal operating pressure and adjustments made as necessary to obtain leak-free 

performance. Flanges shall be inspected by visual, audible, and/or olfactory means at 

least weekly by operating personnel walk-through. 

Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a 

second valve. Except during sampling, maintenance work, and when connecting hoses, 

the second valve shall be closed. 

F. Accessible valves shall be monitored by leak-checking for fugitive emissions at least 

quarterly using an approved gas analyzer with a directed maintenance program. 

Sealless/leakless valves (including, but not limited to, welded bonnet bellows and 

diaphragm valves) and relief valves equipped with a rupture disc upstream or venting 

to a control device are not required to be monitored. For valves equipped with rupture 

discs, a pressure gauge shall be installed between the relief valve and rupture disc to 

monitor disc integrity. All leaking discs shall be replaced at the earliest opportunity 

but no later than the next process shutdown. 

An approved gas analyzer shall conform to requirements listed in 

40 CFR 60.485(a)-(b). 

A directed maintenance program shall consist of the repair and maintenance of 

components assisted simultaneously by the use of an approved gas analyzer such that 

a minimum concentration of leaking VOC is obtained for each component being 

maintained. Replaced components shall be re-monitored within 15 days of being placed 

back into VOC service. 

/? 
P.14 

SPECIAL CONDITIONS l IMOHMTDA I | r n PADV 

Permit No. 3284 UNCONTROLLED COPY 

Page 5 

G. Except as may be provided for in the special conditions of this permit, all pump and 

compressor seals shall be monitored with an approved gas analyzer at least quarterly 

or be equipped with a shaft sealing system that prevents or detects emissions of VOC 

from the seal. Seal systems designed and operated to prevent emissions or seals 

equipped with an automatic seal failure detection and alarm system need not be 

monitored. These seal systems may include (but are not limited to) dual pump seals 

with barrier fluid at higher pressure than process pressure, seals degassing to vent 

control systems kept in good working order, or seals equipped with an automatic seal 

failure detection and alarm system. Submerged pumps or sealless pumps (including, 

but not limited to, diaphragm, canned, or magnetic driven pumps) may be used to 

satisfy the requirements of this condition and need not be monitored. 

H. Damaged or leaking valves or flanges found to be emitting VOC in excess of 500 parts 

per million by volume (ppmv) or found by visual inspection to be leaking 

(e.g., dripping liquids) shall be tagged and replaced or repaired. Damaged or leaking 

pump and compressor seals found to be emitting VOC in excess of 500 ppmv or found 

by visual inspection to be leaking (e.g., dripping liquids) shall be tagged and replaced 

or repaired. 

I. Every reasonable effort shall be made to repair a leaking component, as specified in 

this paragraph, within 15 days after the leak is found. If the repair of a component 

would require a unit shutdown, the repair may be delayed until the next scheduled 

shutdown. All leaking components which cannot be repaired until a scheduled 

shutdown shall be identified for such repair by tagging. The TNRCC Executive 

Director, at his discretion, may require early unit shutdown or other appropriate action 

based on the number and severity of tagged leaks awaiting shutdown. 

J. Pump and compressor seals shall be monitored at 500 ppmv each quarter. Records 

shall be kept of pump and compressor seal inspections, findings, and corrective action 

taken in accordance with paragraph K of this condition. 

K. The results of the required fugitive monitoring and maintenance program shall be made 

available to the TNRCC Executive Director or his designated representative upon 

request. Records shall indicate appropriate dates, test methods, instrument readings, 

repair results, and corrective actions taken for all components. Records of flange 

inspections are not required unless a leak is detected. 

L. Fugitive emission monitoring required by TNRCC Regulation V may be used in lieu 

of Items F through I of this condition. 

H 
P.15 

SPECIAL CONDITIONS . ^ **~, 

Permit No. 3284 UNCONTROLLED COPY 

Page 6 

Compliance with the requirements of this condition does not assure compliance with 

requirements of an applicable New Source Performance Standards or an applicable 

National Emission Standard for Hazardous Air Pollutants and does not constitute 

approval of alternative standards for these regulations. 

M. The fugitive emissions monitoring program (28 RCT with additional monitoring of 

pumps and compressor seals at 500 ppmv) will be initiated no more than 30 days after 

permit issuance. 

RECORDKEEPING 

12. All records required by these conditions shall be kept at the facility and maintained for a 

minimum of two years and be made available to representatives of the TNRCC and local 

programs having jurisdiction upon request. Permit recordkeeping requirements will be 

initiated within 60 days of permit issuance. The records for each calendar month will be 

complete and available for inspection by the end of the following calendar month. 

13. The VOC, nitrogen oxide, and carbon monoxide emissions used to calculate an emission 

cap shall be calculated monthly for each pollutant in accordance with the emission cap basis 

table, dated November 29, 1995, in the confidential section of the permit application in 

order to provide the accumulated hourly and total annual emission calculations for 

comparison with the established emission caps. The monthly calculation shall be performed 

using actual operating and control data for the month, and shall be consistent with the 

calculation methodology used in the development of the permit application. Emission 

calculations will be based on the monthly average temperatures obtained from the Galveston 

Weather Bureau for 1993 and 1994, as follows: 

January 

February 

March 

April 

55.9F 

57.9F 

63.3F 

68.6F 

May 

June 

July 

August 

76.2F 

82.4F 

85.2F 

84.9F 

September 

October 

November 

December 

81.2F 

73.4F 

65.OF 

60. IF 

14. Emissions for tanks and loading operations shall be calculated using: (1) AP-42, Fourth 

Edition, Compilation of Air Pollution Emission Factors; Chapter 12, Storage of Organic 

Liquids; and Chapter 4, Transportation and Marketing of Petroleum Liquids; and (2) the 

TNRCC publications titled "Technical Guidance Package for Chemical Sources - Storage 

Tanks" and "Technical Guidance Package for Loading Operations." 

/s 
P.16 

SPECIAL CONDITIONS llAAllTnA I . r n nnnv 

Permit No. 3284 UNCONTROLLED COPY 

Page 7 

15. Tanks noted on the "Emission Sources - Emission Caps and Individual Emission 

Limitations" table will comply with TNRCC Regulation V by continuing to comply the 

Alternate Emission ("Bubble") Policy, Section 101.23, as described on page 3-2 of the 

permit amendment application dated September 1995. 

Dated 5-6-96 

/£ <r> 
P.17 

APPROVED CHEMICALS LIST 

Acetic Acid 

Acetone 

Aminoethylethanolamine 

Anhydride 

Butanol 

Butyl Acetate 

Butyl Acrylate 

Cyclohexanone 

Crude Polyglycol 

Diacetone Alcohol 

Diethanolamine 

Diethyl Sulfate 

Diethylene Glycol 

Diethylenetriamine 

Diisobutyl Carbitol 

Diisobutyl Ketone 

Dimethylethanolamine 

Dimethyl Heptanol 

Dipotasium Phosphate 

Ethanol, pure, all proofs 

Ethanol, denatured 

Ethanol Denaturants 

Ethyl Acetate 

Ethyl Acrylate 

Ethyl, Hexanol, 2-

Ethyl Hexoic Acid, 2-

Ethylene Glycol 

Ethyleneamine Mixtures 

Ethylenediamine 

Ethylhexyl Acrylate 

Gluteraldehyde, 50 percent 

Glycol Ethers 

Glycol Ether Mixtures 

Heavy Polyamine X 

Hexylene Glycol 

Isobutanol 

Isobutyl Acetate 

Isobutyl Heptyl Ketone 

Isopentanoic Acid 

Isophorone 

Isopropanol 

Isopropyl Acetate 

Methanol 

Methyl Amyl Alcohol 

Methyl Butanol, 2-

Methyl Ethyl Ketone 

Methyl Isobutyl Ketone 

Methyldiethanolamine 

Mixed OXO Products 

Monoethanolamine 

Monostill Tails 

N-Methylethanolamine (NMEA) 

NIAX POLYOLS 

N-Pentanol 

Plant Mixtures* 

Potassium Hydroxide 

Primary Amyl Acetate 

Primary Amyl Alcohol 

Primary Amyl Alcohol/Isobutanol 

Mixtures 

Propanol 

Propionic Acid 

Propyl Acetate 

Propylene Glycol 

Sodium Acetate 

Tergitols (nonionic surfactants) 

Triethanolamine 

Triethylene Glycol 

Tetraethylene Glycol 

Tetraethylene Pentaamine 

Triethylene Tetraamine 

Tristill Tails 

UCAR Ester EEP 

(ethyl-3-ethoxypropionate) 

UCAR Filmer IBT 

Valeric Acid 

Vinyl Acetate 

* A plant mixture is a blend of any two or 

more chemicals that appear on the 

Approved Chemicals List or a blend of 

those chemicals and mixtures with water. 

UNCONTROLLED COPY 

Dated 5-9-96 

n 
P.18 

r 

EMISSION SOURCES - EMISSION CAPS AND INDIVIDUAL LIMITATIONS 

Permit No. 3284 UNCONTROLLED COPY 

IMs fcaMe lists the maximum allowable emission rates and all sources of air contaminants on the applicant's 

prqperty covered by this permit. The emission rates shown are those derived from information submitted as 

part of flse application for permit and are the maximum rates allowed for these facilities. Any proposed 

increase in emission rates may require an application for a modification of the facilities covered by this permit. 

AIR CONTAMINANTS DATA 

Emissioni 

Point No, (1) 

E15A079 

E15A152 

E15A153 

E15A079 

E15A152 

E15A153 

Source 

Name Y2) 

Butadiene Flare 

Dock 66 Flare 

Dock 67 Flare 

NOx Emission Cap 

upon operation 

ofthe flares, 

but not later than 

November 15,1996 

Butadiene Flare 

Dock 66 Flare 

Dock 67 Flare 

NQx. 

Air Contaminant 

Name (3) 

EMISSIONS 

NOx 

NOx 

NOx 

CO EMISSIONS 

CO 

CO 

CO 

Emission Cap or 

Individual 

Emission Limit** 

lb/hr TPY 

7.39 5.23 

* • 

• 

CO Emission Cap 

upon operation of 

the flares, but not later 

than November 15, 1996 

63.43 44.86 

VOC EMISSIONS 

E15A154 

E15A057 

Dock 63 

Rack 1 

VOC 

VOC 

/r 
Permit No. 3284 

Page 2 

UNCONTROLLED COPY 

EMISSION SOURCES EMISSION CAPS AND INDIVIDUAL LIMITATIONS 

AIR CONTAMINANTS DATA 

P.19 

Emission 

Point No. Cl) 

E15A058 

E15A060 

E15AQ61 

E15A062 

EI5A063 

E15A065 

E15A066 

E15A067 

E15A068 

E16A038 

F15A001-18 

through 20 

F15A011 

through 025 

F15A030 

ihrcaigh033 

F15A047 

through 052 

F15A085 

through 099 

F15A0P1 

Source 

Name (2) 

Rack 2 

Rack 5* 

Rack 6 

Rack 7* 

Rack 10 

Dock 62 

Dock 65 

Dock 66 

Dock 67 

Ethanol Rack* 

Fugitives (4) 

Fugitives (4) 

Fugitives (4) 

Fugitives (4) 

Fugitives (4) 

Fugitives (4) 

Air Contaminant 

Name (3) 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

Emission Cap or 

Individual 

Emission Limit** . 

lb/hr TPY 

M 
Permit No. 3284 

Page 3 

EMISSION SOURCES EMISSION CAPS AND INDIVIDUAL UMITATIONS 

AIR CONTAMINANTS DATA 

P.20 

EiDJissiGni 

Point Jifo.. Cl) 

F15A1TO 

through F15A1 

F15A157 

F15A33ESLN 

FL5.AM3SCLN 

F1(6AO0M4)1 

iumough40 

E15ASD85 

E15A086 

E15A087 

E15A088 

E15A09O 

E15A092 

E15A012 

E15A!09(6 

E15AW7 

E15A098 

E15A099 

E15A015 

Source 

Name (2) 

Fugitives (4) 

Fugitives (4) 

Fugitives (4) 

Fugitives (4) 

Fugitives (4) 

TOTAL VOC FUGITIVES 

Tank 920 

Tank 930 

Tank 941 

Tank 942 

Tank 948 

Tank 952 

Tank 954 

Tank 3720 

Tank 3721 

Tank 3723 

Tank 3724 

Tank 3725* 

Emission Cap or 

Individual 

Air Contaminant Emission Limit** 

Name (3) lb/hr TPY 

VOC 

VOC 

voc UNCONTROLLED COPY 

VOC 

VOC 

60.48 93.36 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

~> r^ 
P.21 

Permit No 

Page 4 

Emission 

Point No. 

E15A101 

E15A102 

E15A103 

E15A104 

E15A105 

E15A018 

E15A108 

E15A109 

E15A110 

E15A111 

E15A112 

E15A113 

E15A114 

E15A020 

E15A021 

E15A115 

E15A022 

' E15A023 

E15A024 

3284 

i r 

EMISSION SOURCES EMISSION CAPS AND INDIVIDUAL LIMITATIONS 

fl) 

AIR CONTAMINANTS DATA 

Emission Cap or 

Individual 

Source Air Contaminant Emission Limit** 

Namef2) Name (3) lb/hr TPY 

Tank 3727 VOC 

Tank 3729 VOC 

Tank 3730 VOC 

Tank 3731 VOC 

Tank 3732 VOC 

Tank 3735 VOC 

Tank 3736 VOC 

Tank 3737 VOC 

Tank 3738 VOC 

Tank 3740 VOC 

Tank 3741 VOC 

Tank 3742 VOC 

Tank 3743 VOC 

Tank 3744 VOC 

Tank 3745 VOC 

Tank 3746 VOC 

Tank 3747 VOC 

Tank 3748 VOC 

Tank 3749 VOC 

UNCONTROLLED COPY 

; ? / 
P.22 

Permit No. 3284 

IRage5 

EMISSION SOURCES EMISSION CAPS AND INDIVIDUAL LIMITATIONS 

AIR CONTAMINANTS DATA 

Emission 

Point Ife.. (fl) 

E15A12S0 

E15A157 

E15AM8 

E15A1I9 

EL5AL032 

E15A124 

E15A125 

E15AOS 

E15A106 

E15A127 

E15A08 

E15A130 

E15A132 

E15A107 

E15A133 

E15A13S 

E15A139 

E15A051 

E15A052 

Source 

Name C2) 

Tank 3761 

Tank 3757 

Tank 3858 

Tank 3759 

Tank 3764 

Tank 3768 

Tank 3769 

Tank 3773 

Tank 3733N 

Tank 3775 

Tank 3776 

Tank 3780 

Tank 3792 

Tank 3733S 

Tank L-l 

Tank L-10 

Tank L-ll 

Tank L-12 

Tank L-13 

Emission Cap or 

Individual 

Air Contaminant Emission Limit** 

Name f3) lb/hr TPY 

VOC 

VOC 

v nr UNCONTROLLED COPY 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

?;>_ 
P.23 

r 

Permit No. 3284 

Page<6 

EMISSION SOURCES EMISSION CAPS AND INDIVIDUAL LIMITATIONS 

AIR CONTAMINANTS DATA 

ETnissiron 

Paint No. CD 

E15A14D 

E15A141 

E15A134 

EL5A135 

E15A048 

E15A131S 

E15AB7 

E15AO50 

E15A047 

E15A049 

E16A017 

E16A018 

E16A012 

El 6019 

E16A20 

EMA021 

E16A022 

E16A023 

E16A024 

Source 

Name (2) 

Tank L-15 

Tank L-16 

TankL-3 

TankL-4 

Tank L-5* 

TankL-6 

TankL-8 

Tank L-9* 

Tank L-2* 

TankL-7 

Tank BW-19 

Tank BW-20 

Tank BW-13* 

Tank 101 

Tank 102 

Tank 103 

Tank 104 

Tank 105 

Tank 106 

Emission Cap or 

Individual 

Air Contaminant Emission Limit** 

Name (3) lb/hr TPY 

VOC 

VOC 

v oc UNCONTROLLED COPY 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

y^, 
P.24 

Permit No. 3284 

Page 7 

C 

EMISSION SOURCES EMISSION CAPS AND INDIVIDUAL LIMITATIONS 

AIR CONTAMINANTS DATA 

Emission 

Point No. (1) 

E16A025 

E16A002 

E16A003 

E16A033 

E16A026 

E16A027 

EL6AQ50 

E16A032 

E16A028 

E16A029 

E16A055 

E16A051 

E16A052 

E16A053 

E1<6A054 

E15AQ91 

E15A011 

E15A093 

Source 

Name f2) 

Tank 107 

Tank 108 

Tank 109 

Tank 112 

Tank 114 

Tank 116 

Tankl 

Tank 2 

Tank 209 

Tank 211 

Tank 216 

Tank 202 

Tank 203 

Tank 204 

Tank 206 

Tank 950 

Tank 951 

Tank 953 

Air Contaminant 

Name f3) 

Emission Cap or 

Individual 

Emission Limit** 

lb/hr TPY 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

UNCONTROLLED COPY 

r>U 
P.25 

7 

Permit No. 3284 

PageS 

Z**^ 

EMISSION SOURCES EMISSION CAPS AND INDIVIDUAL LIMITATIONS 

AIR CONTAMINANTS DATA 

Emission 

Point No. fl) 

E15A094 

E15A013 

E15ADI4 

E15A100 

E15A016 

E15AD17 

E15A019 

E15A026 

E15AQ3Q 

E15AO! 

E15A031 

E15AQ33 

E15A122 

E15A123 

E15A129 

E15AD89 

E15A025 

E15A053 

E15A054 

Source 

Name f2) 

Tank 955 

Tank 960 

Tank 961 

Tank 3726 

Tank 3728 

Tank 3734 

Tank 3739 

Tank 3754 

Tank 3760* 

Tank 3762 

Tank 3763* 

Tank 3765 

Tank 3766 

Tank 3767 

Tank 3777 

Tank 943 

Tank 3750 

Pat Tank 1 

Pat Tank 2 

Air Contaminant 

Name (3) 

Emission Cap or 

Individual 

Emission Limit** 

lb/hr TPY 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

UNCONTROLLED COPY 

•z> cr 
P.26 

Permit No. 3284 

Page 9 

C: 

EMISSION SOURCES EMISSION CAPS AND INDIVIDUAL LIMITATIONS 

AIR CONTAMINANTS DATA 

Emission 

Point No. O) 

E15A055 

E15A056 

E16AQ45 

E16A046 

E16A048 

E16AQ49 

E15A116 

E15A117 

E15A142 

E15A143 

E15A144 

E15A079 

E15A152 

E15A153 

E15A151 

E16A038C 

Source 

Name (2) 

Pat Tank 3 

Pat Tank 4 

Tank BW-18 

Tank BW-21 

Tank BW-22 

Tank BW-23 

Tank 3752 

Tank 3753 

Slop Tank, Dock 62 

Slop Tank, Dock 66 

Slop Tank, Dock 67 

Butadiene Flare 

Dock 66 Flare 

Dock 67 Flare 

Acetic Acid Scrubber 

DSP Water Scrubber 

Air Contaminan 

Name (3) 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

VOC 

Emission Cap or 

Individual 

t Emission Limit** 

lb/hr TPY 

• 

UNCONTROLLED COPY 

% 

-y f 
P.27 

Permit No. 3284 

Page 1© 

r 

UNCONTROLLED COPY 

EMISSION SOURCES EMISSION CAPS AND INDIVIDUAL LIMITATIONS 

AIR CONTAMINANTS DATA 

Emission 

Point No. (1) 

Source 

Name f2) 

Air Contaminant 

Name f3) 

Emission Cap or 

Individual 

Emission Limit** 

lb/hr TPY 

VOC Emission Cap 1318.71 239.49 

(Including Fugitives) 

upon operation of flares, 

but no later than 

November 15, 1996 

(1) Emission point identification - either specific equipment designation or emission point number from 

plot plan. 

(2) Specific point source name. For fugitive sources use area name or fugitive source name. 

(3) VOC - volatile organic compounds as defined in General Rule 101.1 

NOx - total oxides of nitrogen 

CO - carbon monoxide 

{4) Fugitive emissions must be included in the emission caps. 

* Included in the Alternate Method Of Control (AMOC) Bubble Permit agreement (no permit number). 

* * Emission caps are based on and the facilities are limited by the following maximum operating 

schedule: 

Hrs/day Days/week Weeks/year or 8.760 Hrs/year 

Dated 5-6-96 

?-l