### Site Description

The Ingleside Terminal was acquired by Plains Marketi ng in the late 1990’s. The tank farm site consists of tanks ranging in size from 15,000-50,000 bbls that hav e been historically used for storage of a variety of petroleum liquids (VOL), includi ng crude, condensate, diesel, naphtha, natural gasoline, alkylates, and fuel oils. An inactive truck rack is located adjacent to the tank farm. Other site features include an office, a garage, a firewater pond and associated pumps, and boi lers for heating heavy products. In the past small truck unloading tanks (436 bbl) were also located at the tank farm, but are no longer present. The facility also has refining equipment on site that has been inactive since t he facility was acquired by Plains.

The Terminal also has a marine dock, located approximately 3⁄4 mile away from the tank farm. Crude oil and products are received and delivered to the marine dock from the tank farm via a pipeline. The dock is only capable of handling barges. A storm water/slop tank and electric loading pump are also located at
the dock.



### Permitting History

The tank farm operated under NSR permit No. 06356 fr om 1983 until it was allowed to expire in January 2008. The permit was allowed to expire after the si te was permitted under permits by rule (PBR) as discussed below. The NSR permit covered operation s at the tank farm, not the marine dock. Marine vessel loading was not regulated by the TCEQ until 2001, so no permits were issued for the marine dock prior to that time.

When TCEQ began regulating MVL emission in 2001, Pl ains submitted a Title V permit application for authorization of emissions from both the dock and tank farm combined in 2001. Only the dock met the major source PTE thresholds for criteria pollu tants (VOC) due to the pump rate and uncontrolled emissions. However, this application was withdr awn in 2002 after TCEQ published guidance defining a “site,” which included distance limitations. The doc k and tank farm are far enough apart to be defined as 2 separate sites. Therefore, in 2002, a Title V O perating Permit application was submitted to authorize emissions only from the dock.

In 2003, TCEQ responded by authorizing the dock unde r General Operating Permit (GOP) 516, facility permit No. O-02533. Then, in February 2004, TCEQ changed the GOP permitting process, and again required Plains to apply for a site-specific Title V Site Operating Permit (SOP) fo r the dock. Another Title V permit application was submitted in August 2004. This permit was approved in May 2005 and the dock operated under SOP no. O2761 until the facility switched to fuel oil service in 2007, and the Title V permit
was voided in June 2008.

In 2008, site operations changed to handling only low vapo r pressure fuel oils. The dock and tank farm currently operate as one facility und er several PBRs. All previous au thorizations have been voided or allowed to expire. The facility PBRs have been certif ied and registered and total site VOC emissions are approximately 18 tpy. PBR documentation shows HAP PTE is below the 10/25 tpy thresholds.



### Subpart Y – Marine Vessel Loading MACT Applicability

In 1997, the tank farm NSR permit came up for rene wal. At that time, the TCEQ did not regulate emissions from marine vessel loading. Therefor e, the 1997 permit application represented PTE calculations only from the tanks a nd fugitive sources. PTE for the bar ge loading operation is calculated based on the throughputs limits represent ed for the tanks, since all receipts/deliveries were via barges.

### Throughput Limits

Tank Farm The following table is included in the 1997 permit renewal application and establishes the basis for the Maximum Allowable Emissions Rates included in the NSR permit. These volumes were used to calculate PTE for the barge loading dock. For simplicity, all VOL heavier than diesel (such as cutterstock, no. 6. fuel oil, and kerosene) have been replaced with dies el. This results in a conservative approach to emission estimation, resulting in slightly higher emissions.

Tank VOL Stored Max. Annual Throughputs (bbl)
100 Diesel 270,000 101 Crude oil 1,500,000 102 Crude oil 1,500,000 120 Crude condensate 600,000 121 Crude condensate 1,000,000 131 Diesel 285,000 132 Crude oil, natural gasoline, naphtha 285,000 133 Crude oil, natural gasoline, naphtha 285,000 140 Diesel 250,000 150 Diesel 225,000 151 Diesel 270,000

Summary for Barge Loading Calculations (from above)

VOL Max. Annual Barge Loading Volumes (bbl)

Diesel 1,300,000 Crude oil 3,000,000 Condensate 1,600,000 Natural gasoline, naphtha 570,000

Potential to Emit for Barge Dock

Naphtha/

Natural
Gasoline Diesel Crude Condensate FUG Totals

n-Hexane 3.53 0.01 0.29 0.20 4.02 2,2,4-Trimethylpentane 0.40 0.00 0.07 0.05 0.52

Benzene 1.33 0.00 0.43 0.30 2.06

Toluene 1.18 0.00 0.72 0.50 2.39 Ethyl benzene 0.12 0.00 0.29 0.20 0.61 Xylenes 0.46 0.00 1.01 0.69 2.16
Cumene 0 0 0.07 0.05 0.12

Total HAPs 7.01 0.01 2.88 1.98 11.89

Total VOC 94.14 0.16 61.27 42.10 0.396 198.08

Note: Speciation profiles for Naphtha and natural gaso line were taken from a worst-case composite of EPA Speciate Profiles Nos. 2490 and 2556. Speciation profile for crude oil and condensat e taken from TANKS 4.0 speciation profiles.