Site Description 

The Ingleside Terminal was acquired by Plains Marketing in the late 1990’s. The tank farm site consists 

of tanks ranging in size from 15,000-50,000 bbls that have been historically used for storage of a variety 

of petroleum liquids (VOL), including 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 boilers 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 onsite that has been inactive since the 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 from 1983 until it was allowed to expire in January 

2008. The permit was allowed to expire after the site was permitted under permits by rule (PBR) as 

discussed below. The NSR permit covered operations 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, Plains 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 pollutants (VOC) due to the pump rate and uncontrolled 

emissions. However, this application was withdrawn in 2002 after TCEQ published guidance defining a 

“site,” which included distance limitations. The dock and tank farm are far enough apart to be defined as 

2 separate sites. Therefore, in 2002, a Title V Operating Permit application was submitted to authorize 

emissions only from the dock. 

In 2003, TCEQ responded by authorizing the dock under 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) for 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 vapor pressure fuel oils. The dock and tank farm 

currently operate as one facility under several PBRs. All previous authorizations have been voided or 

allowed to expire. The facility PBRs have been certified 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 renewal. At that time, the TCEQ did not regulate 

emissions from marine vessel loading. Therefore, the 1997 permit application represented PTE 

calculations only from the tanks and fugitive sources. PTE for the barge loading operation is calculated 

based on the throughputs limits represented 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 diesel. 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 gasoline were taken from a worst-case composite of 

EPA Speciate Profiles Nos. 2490 and 2556. 

Speciation profile for crude oil and condensate taken from TANKS 4.0 speciation profiles.