P.1 

OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

) ll-B-8 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 14 of 132 
P.2 

MEMORANDUM 

n-a-s 

TO: Project File 

Organic Liquids Distribution NESHAP 

ESD Project No. 96/05 

FROM: BerndHanekeT^^ 

Pacific Environmental Services, Inc. (PES) 

DATE: April 28,1998 

SUBJECT: Site Visit to ST Services (StanTrans, Inc.), Texas City, Texas 

I. Purpose 

The purpose of this site visit was to tour the facility in an effort to educate EPA and 

contractor personnel concerning organic liquids distribution operations and 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 

ST Services (StanTrans, Inc.) 

Loop 197 South 

P.O. Box 3608 

Texas City, Texas 77592 

April 23,1998 (9:00 a.m. -1:30 p.m.) 

III. Participants 

ST Services (StanTrans. Inc.) 

Michael Holdman - Director of Operations 

Kyle J. Mullins - Manager, Environmental and Safety 

Mark A. Saxton - Environmental and Quality Manager 

Environmental Protection Agency 

Mr. Steve Shedd - Project Officer, OAQPS/ESD/WCPG 

Research Triangle Park, NC 

Pacific Environmental Services. Inc. (PES) 

GregLaFlam-RTP,NC 

BerndHaneke-RTP,NC 

OCT I i iCOD 

EPrt r\\?\ L/OCivET 
P.3 

Site Visit Memo/ST Services, Inc. 

April 28,1998 

Page 2 

IV. Pre-Tour Discussion 

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 on the basis of 

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 ofthe 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 best 

performing 12 percent of sources in this category. The standards are slated to be proposed in 

1999, with promulgation ofthe final rule in November 2000. 

Mr. Shedd mentioned that the EPA has prepared an industry questionnaire and 

distributed it to trade organizations for their review and comment. The questionnaire, when 

final, will be sent to approximately 160 companies in this industry. 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 the EPA project team, and to comment on its accuracy and to identify any 

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

rulemaking. The representatives of ST Services were asked to identify whether any ofthe 

information in the conversations and handouts was confidential. No information during the 

conversations was noted by ST Services to be confidential except for customer names. 

Customer names were not mentioned and none of were recorded by the EPA project team. 

Facility Processes 

ST Services is a provider of bulk liquid terminaling services. As such, it provides liquid 

storage capabilities on a for-hire basis which conforms to the applicable laws, rules and 

regulations, and to customers' contract requirements and expectations. ST Services is 

experienced in handling a wide variety of organic liquids, and considers itself to be a leader in 

its field. The facility is physically located on 44 acres of land, and has an additional 12.1 acres 

which it can develop should the need arise. 

ST Services has at its disposal 124 storage tanks ranging in size from 1,000 to 112,000 

barrels (Attachment 1). The facility's storage tanks consist of cone roof, fixed roof, and 

internal floating roof tanks. The facility has tanks which are made of carbon steel and stainless 

steel. Furthermore, it also has insulated tanks to handle products at higher/lower temperatures. 

ST Services does not have any external floating roof tanks at the Texas City facility because its 

1 
P.4 

Site Visit Memo/ST Services, Inc. 

April 28,1998 

Page 3 

operations are not geared toward petroleum products. 

Mr. Holdman informed the EPA project team that the facility was currently operating at 

98 percent capacity. This figure was calculated by dividing the non-idle tank space by total 

capacity of all tanks (2.0 x IO6 bbl). Currently, the management of ST Services estimates that 

at this level of utilization, there are approximately 4 turnovers per year per tank, which in total 

equates to 8.0 x IO6 bbl/yr throughput. Furthermore, the facility operates on a 24 hr/day 

schedule, and 365 days/year. The EPA project team inquired and was told that the facility's 

Standard Industrial Classification (SIC) code is 4226 (Special Warehousing, Not Elsewhere 

Classified). 

ST Services also has access to various modes of transportation, including vessel, barge, 

pipeline, rail, and truck. Each storage tank can load to any of these modes. The facility has rail 

spots for up to 88 rail cars, with numerous loading racks. Furthermore, it has 3 docks for 

vessels, one of which can accommodate ships up to 1,000 feet in length. By mode of 

transportation, ST Services moves most of its material by tanker ship, followed by barge, and 

an equal distribution between railcars and tank trucks. Currently no liquids are distributed by 

pipeline. 

Some ofthe major liquids which the facility is handling include: 

Product 

Acrylates 

Butadiene 

Propylene oxide 

Acrylic acid 

Toluene/Xylene 

Methyl tert-butyl ether (MTBE) 

Liquid fertilizer 

Caprolactam 

Percent of Total Throughput 

10 

5 

2.5 

2.5 

10 

? 

10 

? 

This list was provided to the EPA project team by ST Services, and is not exhaustive. For a 

more detailed listing, consult Attachment 1. 

ST Services treats all of its wastewater at its own treatment facility. Wastewater at the 

facility is primarily a result of storm water. Wastewater from sewers is also directed into the 

treatment facility. 

3 
P.5 

Site Visit Memo/ST Services, Inc. 

April 28,1998 

Page 4 

Emissions from ST Services 

Mr. Saxton of ST Services provided the EPA project team with a 1997 hazardous air 

pollutant (HAP) emissions inventory (Attachment 2). Included in the emissions inventory is 

information pertaining to every tank that stores a liquid containing HAP. Table 1 summarizes 

this information: 

TABLE 1. TOTAL HAP LOSSES IN 1997 

Chemical Name 

Sodium Methylate 

Dimethyformamide 

Ethyl Acrylate 

Acrylic Acid 

Hexamethylene Diisocyanate 

MTBE 

Cresylic Acid 

Methyl Methacrylate 

Toluene/Xylene(s) 

Toluene 

Xylene 

Total 

Tank(s) 

310 

402 

502/505 

507/601/1001/1002/1501 

657/659 

1006/4001/5501/6501 

1901 

2001 

3002/3004 

4002 

5002/6501/11201 

n/a 

Total Losses (gal) 

15.03 

23.77 

4.02 

267.06 

0.0026 

1993.57 

12.46 

0.41 

170.33 

93.93 

267.31 

2,847.90 

The facility is not a major source for HAP, and it emits approximately 30 tons per year 

(tpy) of VOC from tanks and 8-10 tpy from liquid loading operations. 

The facility uses the synthetic organic chemicals manufacturing industry (SOCMI) 

emission factors for calculating fugitive emissions from pumps and valves. In ST Service's 

opinion these emission factors are too high, and do not adequately represent equipment leaks at 

the facility. 

ST Services also uses Tanks3.1 software to calculate emissions from storage vessels. 

Of special interest is the fact that the Texas Natural Resources Conservation Commission 

(TNRCC) sets a limit on the rate of emissions, not on the total amount. Because of this, many 

liquids have a restricted loading rate, and new products must first be modeled by TNRCC 

n 
P.6 

Site Visit Memo/ST Services, Inc. 

April 28,1998 

Page 5 

before they can be handled by ST Services. The TNRCC will first model and determine 

permissible loading rates to determine fenceline concentrations of various chemicals. It is 

because of this that some liquids at ST Services can only be loaded at a rate of 1,000 bbl/hr into 

tank trucks and 2,500 bbl/hr into ships/barges. 

Control Measures 

ST Services makes use of numerous emission control technologies at its Texas City 

facility. Among these technologies are: 

1. Carbon adsorption 

2. Thermal incineration 

3. Scrubbers 

4. Flares. 

What follows is a detailed discussion about these technologies and their uses/applications at ST 

Services. 

Carbon adsorption is used primarily for organic liquid transfer operations to and from 

tank trucks and railcars with liquids having a true vapor pressure of 0.5 psia or higher. The 

TNRCC dictates that this method must have at least a 95 percent control efficiency. Carbon 

adsorption systems seen at ST Services consisted of six drums (55 gal each) in three series of 

two drums. The carbon canisters were supplied by CETCO Industrial Services Group and at 

one location were used to control odors from the loading of acrylates. The carbon canisters are 

checked on a quarterly basis, and replaced if necessary. Breakthroughs in the carbon bed are 

determined visually, or with a vapor sensor installed in a line between the drums. 

ST Services also makes use of a marine vapor recovery unit (MVRU) for controlling 

vapors resulting from the loading of marine vessels. The MVRU only collects vapors from one 

dock (Dock 15). The MVRU is manufactured by John Zink Company and its ideal operating 

temperature is approximately 1,400 degrees Fahrenheit (°F). Back-up fuel for the MVRU is 

natural gas. TNRCC regulations dictate that the thermal incinerator be used for loading 

compounds with true vapor pressures of 0.5 psia or greater. Per TNRCC regulations, collection 

efficiency must be at least 95 percent and destruction efficiency must be at least 98 percent. 

Temperature is monitored continuously on the MVRU via a thermocouple and infrared sensor. 

Furthermore, the MVRU is monitored by on-site personnel on a daily basis. 

The facility has two flares which are used to control vapors from railcar loadings and 

storage tanks handling liquids with true vapor pressures greater than or equal to 0.5 psia. The 

flares are manufactured by John Zink Company and are equipped with blowers. Per TNRCC 

regulations, flares are required to have a destruction efficiency of at least 98 percent and the 

s 
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Site Visit Memo/ST Services, Inc. 

April 28,1998 

Page 6 

collection efficiency ofthe vapor collection system must be at least 95 percent. 

Scrubbers are used to control odors from acrylates. For example, excess vapors from 

storage tanks containing acrylates are routed to scrubbers at the facility. The goal is to have no 

emissions of acrylates due to their pungent odor. All scrubbers at the facility make use of 

carbon canisters as backups. The carbon canisters are similar to those described above. No 

special requirements were identified in the TNRCC permit (Attachment 3) that pertained to the 

operation of scrubbers. 

Railcar Loading 

ST Services has 88 rail car loading spots, and loads an average of 12-15 railcars per 

night. Railcar loading operations make use of vapor recovery only if the product requires it. 

Usually this will occur when its true vapor pressure is 0.5 psia or greater. Vapor recovery lines 

from railcar loading go either to a flare or to a carbon canister adsorption system. 

Railcars are equipped with 3 inch product induction/eduction holes on the top and are 

equipped with 1 to 2 inch holes for vapor recovery. Only top-loaded railcars were seen at the 

facility. 

Tank Trucks 

Most liquid loading at ST Services is performed with 3 inch stainless steel hoses 

equipped with quick connects. Tank trucks are top-loaded with liquids that do not require 

vapor recovery. Tank trucks loading liquids that do require vapor recovery are bottom loaded 

with the top connections used for vapor control and high-level alarms/overfill protection. Since 

the individual tank trucks are not equipped for vapor recovery, the 3-inch cleanout ports on the 

top ofthe trucks are used when vapor recovery is required under the TNRCC rules. Tank 

trucks loading chemicals may also be equipped with a "christmas tree" that enables them to 

have vapor recovery/nitrogen purging in all five compartments. 

Tank trucks are inspected on a Department of Transportation (DOT) mandated 

schedule. A rigorous checklist is followed and leaks must be repaired if found. ST Services 

pressure tests tank trucks that are to handle ethyl acrylate and methyl acrylate for 3 days after 

material is loaded to ensure that the vehicle has no emissions. Tank trucks not passing the 

rigorous tightness tests are turned away from the facility. Furthermore, tank trucks which are 

not equipped for vapor recovery/control are also turned away from the facility. 

Wastewater Treatment 

ST Services operates its own wastewater treatment facility. Furthermore, the facility 

I 
P.8 

Site Visit Memo/ST Services, Inc. 

April 28,1998 

Page 7 

has two discharge permits, one covering non-contact stormwater, the other covering contact 

stormwater. Non-contact stormwater is discharged directly into Galveston Bay, and stormwater 

coming into contact with organic liquids is routed into an open top collection tank. The facility 

has a series of pipes and open trenches which direct stormwater into die collection tank. 

Contact stormwater passes through a skimmer (not an actual API oil/water separator), 

which removes oil. The actual treatment basin is a 212,000 gallon open basin with continuous 

aeration. To maintain a healthy population of bacteria, sanitary sewer wastewater is mixed with 

the contact stormwater. Following biological degradation, the water is sent to a clarifier from 

which it is then discharged into Galveston Bay. Personnel at ST Services estimate that an 

approximate volume of 40,000 gal/day are treated at the facility, but actual volumes depend 

upon daily rainfall. By letter dated August 12,1998 (Attachment 4) ST Services informed the 

EPA that wastewater quantities and concentrations of HAP within the wastewater are moving 

targets and that records are not kept. ST Services also informed the EPA that wastewater 

containing "copious" amounts of HAP is drummed and disposed of as hazardous waste. 

Sludge from the wastewater treatment facility is shipped offsite by a contractor. The 

facility has no other sources of sludge. 

Fugitive Emissions 

Fugitive emissions at the ST Services facility are principally from pumps, flanges, and 

valves. There are 159 pumps at the facility, of which 35 service liquids with vapor pressures 

greater than or equal to 0.5 psia. Additionally, there are 3,225 valves in light liquid/light oil 

service, and a total of 7,285 flanges (Attachment 5). Per TNRCC regulations, flanges must be 

inspected by visual, audible, and/or olfactory means at least weekly by operating personnel 

walk-throughs. Valves are checked by a contractor on a quarterly basis for leaks using an 

approved gas analyzer. All pump seals are checked quarterly with a gas analyzer. 

Equipment found to be leaking VOC in excess of 10,000 ppmv, or found to be leaking 

by routine checks must be tagged and repaired within 15 days. Per TNRCC regulations, only 

under extreme conditions can there be any deviation from this requirement. ST Services 

informed the EPA project team that daily checks were standard, and that any equipment found 

to be leaking was usually repaired within hours following the detection. 

V. Plant Tour 

Following the sit-down discussion, Mr. Saxton took the EPA project team on a tour of 

the facility. The first stop on the tour was to observe a loading rack dedicated to acrylates. A 

scrubber, used to neutralize acrylate odors, as well as three series of two interlinked carbon 

canisters were observed. 

1 
P.9 

Site Visit Memo/ST Services, Inc. 

April 28,1998 

Page 8 

Following this, Mr. Saxton showed the EPA project team a truck loading rack dedicated 

to loading of methyl acrylate. A 2-inch green vapor return hose, as well as the filling hose/pipe 

were observed. Two carbon canisters were also seen at the site. Mr. Saxton informed the team 

that a single carbon canister had to achieve at least 95 percent control, while a connected pair of 

two carbon canisters had to achieve 99 percent control. 

Next, Mr. Saxton showed the team Dock 16 (shared with other companies), which is not 

hooked into the marine vapor recovery unit. At this point Mr. Saxton informed the team that 

Dock 15 controls vapors via the MVRU, and that the third dock, Dock 19 has no vapor control 

devices. 

Mr. Saxton then took the EPA project team to a railcar loading spot. A railcar was 

observed, as was the loading arm and vapor recovery line. This loading spot was dedicated to 

dry liquids (0 percent water) and thus was connected to two carbon canisters. Furthermore, this 

railcar loading spot was equipped to provide nitrogen blanketing in the railcar. The nitrogen 

blanketing was required for Monder, a dry liquid. The rail car observed at the site had a total 

storage capacity of 20,659 gallons. 

The wastewater treatment facility was scrutinized after the railcar loading spot. The 

wastewater treatment facility consisted of an open storage tank, a large open bioreactor, 

clarifier, and drain. The wastewater was aerated heavily, and had a brownish color. The 

clarifier and drain were also inspected, and it was estimated by the EPA project team that an 

approximate 10 gal/hr was discharged into Galveston Bay. The wastewater treatment basin was 

also estimated to be approximately 100 feet long, and 30 feet wide. 

Located next to the wastewater treatment plant was the John Zink marine vapor 

recovery unit and the two John Zink flares. The MVRU was observed to be functioning 

normally at 1400°F. The two flares were equipped with blowers to control vapors from storage 

tanks. A boiler for heat/steam was observed near the flares. The heat/steam from the boiler is 

used to heat insulated storage vessels. 

Dock 15 and its vapor return connection line were observed briefly by the EPA project 

team. The "pit area" was also observed by the team. It is at this location that product from 

marine vessels can be directed into any number of tanks. 

The final stop was at a truck loading rack for acrylates, which at the time was empty. 

Vapor return lines as well as product lines were observed. The theoretical operation ofthe 

system was also discussed on site. 

% 
P.10 

Site Visit Memo/ST Services, Inc. 

April 28, 1998 

Page 9 

VI. Post-Tour Discussion 

A brief post-tour discussion was held in which Mr. Haneke expressed his desire to 

obtain a copy ofthe air emissions inventory detailing emissions from tanks, product loading 

operations, and fugitive emissions from ST Services. Photocopies of various documents (see 

Attachments) were made and handed to the EPA project team. Following this, the EPA project 

team thanked the personnel from ST Services and the tour was concluded. 

VII. Action Items 

The EPA project team inquired, and ST Services agreed to provide information on the 

following items (if available): 

1. Wastewater generation rates and sources of wastewater generation 

2. HAP content of wastewater 

3. Incoming and outgoing HAP concentrations of wastewater 

4. Total emissions of VOC and HAP from the facility in 1997. 

1 
P.11 

STANTRANS, INC 

TEXAS CITY, TEXAS 

A KANEB COMPANY 

II 
P.12 

ST Services 

Mftiiianu 

Wyonitm; 

\ , 

North Dakota \ Minnesota /~ /%L 

\ i 

\ ^ ^ L Nevada 

\ Callfoi'nla 

1-

South Dakota 

Nobrusici 

ca 

N^l | H«ITip3llll'<J 

InsaachuMittt 

Utah 

^•Jl'V'. IVllUtu 

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GD 

Okituioaip 

Wisconsin £/J / " V , - Nliw ,orl( > ^-^ ^ |5lu|v 

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r ^jpilu.ta u ^ 0|lj.. j \ ..y;:-.^.; 

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Alnbumo 

CH) I'lorlr'-. ' 

m 

Terminal Locations 

No. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

Locations 

Alamogordo, NM 

Andrews AFB, MD 

Augusta, GA 

Baltimore, MD 

Bremen, GA 

Brunswick, GA 

Chillicothe, IL 

Columbus, GA 

Drumright, OK 

Dumfries, VA 

Homestead, FL 

Imperial, CA 

Indianapolis, IN 

Jacksonville, FL 

Macon, GA 

Milwaukee, WI 

No. of 

Tanks 

5 

3 

8 

49 

8 

3 

6 

25 

4 

16 

2 

6 

18 

30 

10 

7 

Capacity 

(bbls.) 

120,000 

72,000 

110,000 

821,000 

180,000 

302,000 

270,000 

180,000 

315,000 

554,000 

72,000 

124,000 

410,000 

2,066,000 

307,000 

308,000 

Modes 

Served 

P.T 

P.B 

P.T 

P,T,R,V,B 

P.T 

T,B 

P.T.R 

T.R.B 

P.T 

P.T.B 

P 

P.T 

P.T 

T.R.V.B 

P.T 

V.B.T.R 

No. 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

Locations 

Montgomery, AL 

Moundville, AL 

Peru, IL 

Piney Point, MD 

Salina, KS 

San Antonio, TX 

Savannah, GA 

Stockton, CA 

Texas City, TX 

Tucson, A2 

Virginia Beach, VA 

Washington, DC 

Washington, DC 

Westwego, LA 

Winona, MN 

No. of 

Tanks 

7 

6 

8 

28 

10 

4 

17 

18 

124 

7 

2 

5 

3 

54 

7 

Capacity 

(bbls.) 

162,000 

310,000 

221,000 

5,403,000 

98,000 

207,000 

699,000 

314,000 

2,002,000 

181,000 

40,000 

176,000 

133,000 

858,000 

229,000 

Modes 

Served 

P.T 

P.T 

P.T.B 

P,T,V,B 

P.T 

P.T 

T.R.V.B 

P.T 

T,R,V,B 

P.T 

P.B 

P.T 

P.T.B 

T,R,V,B 

T,R,B 

8 - Barge T - Truck R - Rail P - Pipeline V - Vessel 

Marketing Offices 

DALLAS- HEADQUARTERS 

17304 Preston Road, Suite 1000 

Dallas, Texas 75252-5623 

(972) 931-8065 

(972)931-6526 FAX 

STAN TRANS, Inc. 

201 Dock Road 

Texas City, Texas 77590 

(409) 948-3561 

(409) 948-4460 FAX 

PINEY POINT TERMINAL 

17877 Piney Point Road 

Piney Point, MD 20674 

(301) 994-1200 

(301) 994-2744 FAX 

1VVW 

MOttPOMOClPn- UQUtO 

ILTA 

KKMMMJ MSOCttlKIN 

internet Home Page: www.3tservices.net 

BULK LIQUID TERMINALING NATIONWIDE 

A KANEB COMPANY j ^ 
P.13 

05/21/93 

StanTrans, Inc. 

QUALITY POLICY 

StanTrans, Inc. is committed to providing liquid terminaling services which 

conform to the applicable laws, rules and regulations, and to our customers' 

contract requirements and expectations in a timely and cost effective manner for 

both our customers and ourselves. 

Our quality program will result in greater customer confidence and satisfaction, 

improve company productivity and profitability, and strengthen our position in the 

terminaling industry. 

Through our quality program, each employee will have the means to be involved 

in the continuing update and improvement of all our systems. Management will 

commit the resources necessary to maintain and continually improve the quality 

program, and will encourage a spirit of innovation and participation by all 

personnel in our total quality effort. 

<a£ 

Fred T. Johnson Ronald A. Rushton 

President Senior Vice President 

I3 
/ \ 

ISO 9000 CERTIFICATE OF COMPLIANCE 

^W,iMN| ; 

This Is to certify that the Quality Management System of: 

STANTRANS, INC. 

1111 MAIN DOCK ROAD 

TEXAS CITY, TX 77590 

has been assessed by ABS Quality Evaluations, Inc. and found to be in compliance with the following quality standards: 

ISO 9002 

The Quality Management System is applicable to: 

PROVISION OF BULK LIQUID STORAGE SERVICES 

-fr 

Certificate No.: 

Effective Date: 

Expiration Date: 

Rev. No./Date: 

30831 

25 October 1995 

24 October 1998 

0/25 October 1995 

behalf of ABS Quality Evaluations, Inc. 

-fl Eva/^ 

»> 

Acvnililcil hy 

•hi- Until) Council 

tor (c i lifiialiun 

Validity of Ihis certificate is subject lo the organization and procedures being audited twice annually anil Ihe audited company 

submitting to AHS Quality Evaluations, Inc. interim written reports of any major changes in the elements of its Quality Management System. 

ABS Quality evaluations. Inc. 18855 Northchase Drive, Houston. Texas 77060 U.S.A. 

P.16 

StanTrans, Inc. 

Texas City, Texas Terminal 

ISO 9002 CERTIFIED 

201 Dock Road 

Texas City, TX 77590 

or 

P.O. Box 3608 

Texas City, TX 77592-3608 

MANAGED BY: Ronald A. Rushton 

Michael D. Holdman 

John R. Springer 

TEL Number: 

FAX Number: 

TEL Number: 

FAX Number: 

Executive Vice President (Dallas, TX) 

Director of Operations (Texas City, TX) 

General Manager (Texas City, TX) 

(409) 948-3561 (Mr. Holdman) 

(409) 948-4460 (Mr. Holdman) 

(972) 931-8065 (Mr. Rushton) 

(972) 931-6526 (Mr. Rushton) 

MODES SERVED: Vessel, Barge, Pipeline, Rail, Truck 

SCALE FACILITIES: Truck Platform Scales/Rail Car Scales (Two) 

TRUCK FACILITIES: Truck Loading/Unloading Facilities, Scale and Meters 

RAIL SPUR DATA: Private Spur, 85 Cars; Lease Track, 1350' 

Rail spots for up to 68 simultaneous rail car loadings/unloadings; 

served by Texas City Terminal Railway Co. (Santa Fe, Southern 

Pacific/Union Pacific, Burlington Northern) 

DOCK/VESSEL DATA: Three (3) Ship/Barge Docks, 40-50,000 DWT, Maximum Beam 110', 

Maximum Length 1000', 40 MLW with vehicle access 

Dock 15: Barge and Ship, 36' Draft, 900' Length, 110' Width 

Dock 16: 40* Draft, 1000' Length, Unlimited Width 

Dock 19: 36' Draft, 800' Length, 110' Width 

STORAGE TANKS: 124 

Total Capacity 

Gallons: Barrels: 

Range in Sizes 

M3: Gallons: Barrels: M3: 

84,084,000 2,002,000 318,318 42,000-4,704,000 1,000-112,000 159-17,808 

Texas City, TX Data Sheet Page 1 of 3 j (p Revised 11/24/97 
P.17 

OTHER FACILITIES AND SERVICES: 

A. Intermodal ex-rail 

B. Approved ATF Facility (Bonded) 

C. U.S. Customs Bonded Warehouse 

D. Direct Transfers barge-ship and rail-ship and vice-versa 

E. All major chemical vessels call at terminal 

F. Store specialty chemicals with high purity requirements 

G. Leased railroad trackage available 

H. Refrigerated, insulated, heated, lined and floating roof tanks 

I. Expansion acreage available 

J. 150-ton combination truck/rail scale 

K. 60-ton truck scale (70') 

L. Boiler supplied steam (2) -150#, 750 HP 

M. 150,000 cu./ft./hr. nitrogen capabilities 

N. Multiple flare systems 

O. Fire fighting system 

P. Waste water treatment system 

Q. Vapor incineration capabilities (rail, truck and water) 

R. Stainless steel storage 

COMMODITIES HANDLED: 

A. Petroleum and Gas Products: 

•1. Light Oils 

2. Solvents 

3. #2 Fuel Oil 

4. #6 Fuel Oil 

5. Gasoline Blend Stocks 

6. Lube Oils 

B. Chemicals (See Next Page Please) 

ST stores all major chemicals including Olefins, Aromatics, Aldehydes, Alcohols, 

Amines, Waxes, Acids, etc. 

Texas City, TX Data Sheet Page 2 of 3 / f- Revised 11/24/97 
P.18 

B. 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

11. 

12. 

13. 

14. 

15. 

16. 

17. 

18. 

19. 

20. 

21. 

22. 

23. 

24. 

25. 

26. 

27. 

28. 

29. 

30. 

31. 

32. 

33. 

34. 

35. 

36. 

37. 

38. 

39. 

40. 

41. 

42. 

43. 

44. 

45. 

46. 

47. 

Chemicals 

Acetaldehyde 

Acetic Anhydride 

Acetone 

Acetone Cyanohydrin 

Acetonitrile 

Acrylic Acid 

Alkenylsuccinic Anhydride 

Alpha Olefins 

Ammonium Bisulfite 

Ammonium Hydroxide 

Aniline 

Anolon 

Aromatic/Hydrocarbon 

Mixture 

Asphalt 

Benzene 

Butadiene 

Butanediol 

N-Butanol 

Butene-1 

N-Butylacetate 

N-Butylacrylate 

N-Butylalcohol 

Butylene Glycol 

Butylene Oxide 

Butyrolactone 

Caprolactam (Repro.) 

Carbon Black Oil 

Caustic Potash 

Caustic Soda 

Chloroform 

Corn Syrup 

Cotton Seed Oil 

Cresylic Acid 

Crude Caprolactam 

Crude Industrial Ethanol 

Cumene 

Cyclohexane 

Cyclohexanol 

Cyclohexanone 

Cyclohexylamine 

Denatured Alcohol 

Dicyclopentadiene 

Diethanolamine 

Diisobutylene 

Diisopropylamine 

Dimethylaminopropylamine 

Dimethylcyclohexylamine 

Texas City, TX Data Sheet 

48. 

49. 

50. 

51. 

52. 

53. 

54. 

55. 

56. 

57. 

58. 

59. 

60. 

61. 

62. 

63. 

64. 

65. 

66. 

67. 

68. 

69. 

70. 

71. 

72. 

73. 

74. 

75. 

76. 

77. 

78. 

79. 

80. 

81. 

82. 

83. 

84. 

85. 

86. 

87. 

88. 

89. 

90. 

91. 

92. 

93. 

94. 

95. 

Dimethylformamide 

Di Normal Propylamine 

Diol Fractions 

Distillates 

Ethanol 

Ethyl Acetate 

Ethyl Acrylate 

Ethyl Benzene 

N-Ethyl Cyclohexylamine 

2-Ethyl Hexanol 

Ethyl Hexoic Acid 

Ethyl Hexyl Acrylate 

Ethylbenzene 

Ethylene Diamines 

Ethylene Dichloride 

Ethylene Glycol Diacetate 

Formic Acid 

Fuel Oil Additive 

Glycerine 

Glyceryl Triacetate 

Heavy Aromatic Distillate 

Heavy Aromatic Oil 

Hexane 

Hexylene Glycol 

Isobutyl Acetate 

Isobutyl Acrylate 

Isobutyl Alcohol 

Isobutylene 

Isophorone 

Isoprene 

Isopropyl Alcohol 

Latex Solution 

Meta Sodium 

Methanol 

Methyl Acrylate 

Methyl Chloride 

Methyl Ethyl Ketone 

Methyl Formate 

Methyl Isobutyl Ketone 

N-Methyl Pyrrolidone 

Methyl Tertiary Butyl Ether 

3-Methylbutyric Acid 

Methylene Chloride 

Micro Crystalline Wax 

Mineral Spirits 

Monoalcohols - HD 

Monochlorobenzene 

Monoethanolamine 

Page 3 of 3 | g 

96. Morpholine 

97. Naptha 

98. Napthalene 

99. Niax Polyol 

100. Nitro Ethane 

101. Nitro Propane 

102. Nitrogen 

103. Nitrotoluene 

104. Ortho-Nitrotoluene 

105. Ortho-Toluenediamine 

106.PACN20 

107. Para-Dichlorobenzene 

108. Paraffin Wax 

109. Paraxylene 

110. Perchloroethylene 

111. Phosphoric Acid 

112. Piperylene Concentrate 

113. Poly (Oxyalkylene) 

114. Poly Wash Water 

115. Polybutene 

116. Poly butene/Xylene 

117. Polymeric M.D.I. 

118. Polypropylene Glycol 

119. Propionitrile 

120. Propylene Glycol 

121. Propylene Oxide 

122. Propylene Tetramer 

123. PyrolysisTar 

124. Resin Plasticizer 

125. Slack Wax 

126. Sodium Carbonate 

127. Sulphuric Acid 

128. Tall Oil Fatty Acid 

129. Tergitol 

130.Tetrahydrofuran 

131. Toluene 

132. Toluene Diisocyanate 

133. Trichlorethane 

134. Trichiorethylene (111 & 124) 

135. Trichlorobenzene (124) 

136. Triethanolamine 

137. Triethylamine 

138. Triethylene Glycol 

139. Vinyl Acetate Monomer 

140. Vinyl Toluene 

141. White Mineral Oil 

142. Xylene 

Revised 11/24/97 
P.19 
P.20 

StanTrans, Inc. 

Memo 

T« Bemd Haneke 

From: Mark Saxton 

CC: 

Date: April 24,1998 

Re: EPA/PES Environmental Survey 

Dear Mr. Haneke, 

I apologize for the inconvenience with the e-mail. The following pages are the printed repot for 1997 

emissions. If I can be of any further assistance, please contact me at your earliest convenience. 

Sincerely yours, 

Mark Saxton 

Environmental/Quality Manager 

StanTrans, Inc. 

• Pagel ai 
EPA/PES Environmental Survey 

SO 

50 

Chemical Name 

Sodium Methylate 

Dimethylformamide 

Ethyl Acrylate 

Acrylic Acid 

Hexamethylene Diisocyanate 

MTBE 

Cresylic Acid 

Methyl Methacrylate 

Toluene/Xylene 

Toluene 

Xylene 

Total HAP losses 

Tank(s) 

310 

402 

502/505 

507/601/1001/1002/1501 

657/659 

1006/4001/5501/6501 

1901 

2001 

3002/3004 

4002 

5002/6501/11201 

Total Losses (Gallons) 

15.03 

23.77 

4.02 

267.06 

0.0026 

1993.57 

12.46 

0.41 

170.33 

93.93 

267.31 

Total HAP Emissions 2347.90 

StanTrans, Inc. 4/24/98 Pagel 

ho 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 310 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

Sodium Methylate 

54 

70 

0.7101 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

Rail 

Ship 

Barge 

Barrels 

12,943 

0 

0 

0 

Losses Lbs. 

245.025 

0.000 

0.000 

0.000 

TPY 

0.1225 

0.0000 

0.0000 

0.0000 

90 

LP 

Tank losses (pounds) 

Total losses gallons 

113.82 

15.03 

Loading losses 

Total PoundsL 245.025 

Controlled 

Total TPY[ 

Controlled 

4.9005 

0.1225 

0.0025 

StanTrans, Inc. 4/24/98 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 402 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

DMF 

73.1 

70 

0.07 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

Rail 

Ship 

Barge 

Barrels 

11,709 

0 

0 

0 

Losses Lbs. 

29.580 

0.000 

0.000 

0.000 

TPY 

0.0148 

0.0000 

0.0000 

0.0000 

50 

Tank losses (pounds) 159.72 

Loading losses 

Total Poundsf 29380 

Total TPY| 0.0148 

Total losses gallons 23.77 

StanTrans, Inc. 4/24/98 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 502 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

EA 

100.1 

70 

0.7011 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

Rail 

Ship 

Barge 

Barrels 

22,282 

1,824 

0 

0 

Losses Lbs. 

772.022 

63.198 

0.000 

0.000 

TPY 

0.3860 

0.0316 

0.0000 

0.0000 

so 

Tank losses (pounds) 

Total losses gallons 

8.0216 

1.31 

Loading 

Total Pounds L 

Controlled 

Total TPY 

Controlled 

losses 

83S.220| 

2.0880 

0.4176 

0.0010 

StanTrans, Inc. 4/24/98 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 505 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

EA 

100.1 

70 

0.7011 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

Rail 

Ship 

Barge 

Barrels 

23310 

4048 

847 

0 

Losses Lbs. 

814369 

147.184 

11.739 

0.000 

TPY 

0.4073 

0.0736 

0.0059 

0.0000 

so Tank losses (pounds) 

Total losses gallons 

16.0495 

2.42 

Loadin 

Total Pounds 

Controlled 

Total TPY 

Controlled 

I losses 

973.492 

2.6392 

0.4867 

0.0013 

StanTrans, Inc. 4/24/98 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 507 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

AAE 

72 

70 

0.0623 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

Rail 

Ship 

Barge 

Barrels 

3,933 

423 

0 

0 

Losses Lbs. 

8.710 

0537 

0.000 

0.000 

TPY 

0.0044 

0.0005 

0.0000 

0.0000 

SO 

Tank losses (pounds) 218.02 

Loading losses 

Total Pounds! 

nel 

9.647 

Total TPY 0.0048 

Total losses gallons 25.84 

StanTrans, Inc. 4/24/98 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 601 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

AAE 

72 

70 

0.0623 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

Rail 

Ship 

Barge 

Barrels 

5361 

1,984 

12,185 

0 

Losses Lbs. 

12.315 

4.394 

10.794 

0.000 

TPY 

0.0062 

0.0022 

0.0054 

0.0000 

so 

Tank losses (pounds) 340.93 

Loading losses 

Total Pounds f_ 27.502 

Total TPY 0.0138 

Total losses gallons 41.81 

StanTrans, Inc. 4/24/98 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

Receiving Vessel 

Truck 

Rail 

Ship 

Barge 

Tank losses (pounds) 

so 

_ 2> 

Total losses gallons 

StanTrans, Inc. 

Tank 657 

HMDI 

168 

70 

0.0007 

Barrels 

6352 

0 

0 

0 

0.0121 

0.0015 

4/24/98 

(degrees F) 

@Temp 

(ug/m3) 

Losses Lbs. 

0369 

0.000 

0.000 

0.000 

TPY 

0.0002 

0.0000 

0.0000 

0.0000 

Loading losses 

Total Pounds! 0369 

Controlled 0.0009 

Total TPY| 0.0002 

Controlled 0.0000 

. • 

8 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 659 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

HMDI 

168 

70 

0.0007 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

Rail 

Ship 

Barge 

Barrels 

3,766 

3^81 ' 

0 

0 

Losses Lbs. 

0.219 

0.225 

0.000 

0.000 

TPY 

0.0001 

0.0001 

0.0000 

0.0000 

Loading losses 

o 

Tank losses (pounds) 

Total losses gallons 

0.009 

0.0012 

Total Pounds 

Controlled 

Total TPY 

Controlled 

'f_ 0.444 

0.0011 

0.0002 

0.0000 

StanTrans, Inc. 4/24/98 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

u 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Tank losses (pounds) 

Total losses gallons 

StanTrans, Inc. 

Tank 808 

Ethyl Acrylate 

100.1 

70 

0.7011 

Barrels 

6,669 

9,737 

0 

0 

0.8609 

0.30 

4/24/98 

(degrees F) 

@Temp 

(ug/m3) 

Losses Lbs. 

231.066 

337366 

0.000 

0.000 

TPY 

0.1155 

0.1687 

0.0000 

0.0000 

Loading losses 

Total Pounds! 568.432 

Controlled 1.4211 

Total TPY 0.2842 

Controlled 0.0007 

10 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 1001 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

AAE 

72 

70 

0.0623 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

Rail 

Ship 

Barge 

Barrels 

54,113 

8,484 

0 

9,692 

Losses Lbs. 

119.835 

18.788 

0.000 

21.463 

TPY 

0.0599 

0.0094 

0.0000 

0.0107 

Loading losses 

<o4 

30 

Tank losses (pounds) 780.13 Total Pounds [ 

Total TPYf 

160.086 

0.0800 

Total losses gallons 106.71 

StanTrans, Inc. 4/24/98 11 

CO 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 1002 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

AAE 

72 

70 

0.0623 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

Rail 

Ship 

Barge 

Barrels 

32309 

14,235 

8335 

0 

Losses Lbs. 

71.992 

31324 

7383 

0.000 

TPY 

0.0360 

0.0158 

0.0037 

0.0000 

in 

Tank losses (pounds) 

Total losses gallons 

702.93 

9237 

Total Pounds 

Total TPY 

V 110.899 

0.0554 

StanTrans, Inc. 4/24/98 12 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 1006 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

MTBE 

88.15 

70 

3.93 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Barrels 

0 

0 

0 

48,175 

Losses Lbs. 

0.000 

0.000 

0.000 

8239.447 

TPY 

0.0000 

0.0000 

0.0000 

4.1197 

Tank losses (pounds) 

Total losses gallons 

2848.6 

484.55 

Loading losses 

Total PoundsL 

Controlled 

Total TPY 

Controlled 

8239.4471 

164.7889 

4.1197 

0.0824 

StanTrans, Inc. 4/24/98 13 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 1501 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

AAE 

72 

70 

0.0623 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Barrels 

76,228 

2,006 

5,002 

6,060 

Losses Lbs. 

168.809 

4.442 

4.431 

13.420 

TPY 

0.0844 

0.0022 

0.0022 

0.0067 

Loading losses 

Tank losses (pounds) 

Total losses gallons 

2.4443 

033 

ng 

Total PoundsL 

Controlled 

Total TPY 

Controlled 

191.103 

0.4778 

0.0956 

0.0002 

StanTrans, Inc. 4/24/98 14 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 1901 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

Cresylic Acid 

113 

70 

0.0055 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Barrels 

0 

0 

47,671 

0 

Losses Lbs. 

0.000 

0.000 

5.851 

0.000 

TPY 

0.0000 

0.0000 

0.0029 

0.0000 

Loading losses 

Tank losses (pounds) 102.19 Total Pounds 5.851 

Total TPY 0.0029 

Total losses gallons 12.46 

StanTrans, Inc. 4/24/98 15 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 2001 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

MMA 

100 

70 

0341 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Barrels 

3307 

26,088 

0 

0 

Losses Lbs. 

101.681 

696.786 

0.000 

0.000 

TPY 

0.0508 

03484 

0.0000 

0.0000 

u 

Tank losses (pounds) 

Total losses gallons 

13786 

0.41 

Loadini 

Total Pounds 

Controlled 

Total TPY 

Controlled 

I losses 

798.468 

1.9962 

03992 

0.0010 

StanTrans, Inc. 4/24/98 16 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 3001 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

Toluene/Xylene 

93.07 

70 

03838 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Barrels 

30356 

81,124 

0 

8365 

Losses Lbs. 

814391 

2176.129 

0.000 

221.706 

TPY 

0.4071 

1.0881 

0.0000 

0.1109 

Tank losses (pounds) 

Total losses gallons 

341.47 

55.99 

Loading losses 

Total Pounds! 3212.127| 

Controlled 64.2425 

Total TPY 1.6061 

Controlled 0.0321 

StanTrans, Inc. 4/24/98 17 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 3002 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

Toluene/Xylene 

93.07 

70 

03838 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

Rail 

Ship 

Barge 

Barrels 

0 

179,619 

0 

0 

Losses Lbs. 

0.000 

4818.230 

0.000 

0.000 

• TPY 

0.0000 

2.4091 

0.0000 

0.0000 

$ 

Loading losses 

Tank losses (pounds) 

Total losses gaUons 

639.88 

101.61 

ug 

Total Pounds|_ 

Controlled 

4818330 

963646 

Total TPY[ 

Controlled 

2.4091 

0.0482 

StanTrans, Inc. 4/24/98 18 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 3004 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

Toluene/Xylene 

93.07 

70 

03838 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Barrels 

0 

101,422 

0 

0 

Losses Lbs. 

0.000 

2720.617 

0.000 

0.000 

TPY 

0.0000 

13603 

0.0000 

0.0000 

O 

Tank losses (pounds) 

Total losses gallons 

44335 

68.72 

Loading 

Total Pounds [_ 

Controlled 

Total TPY 

Controlled 

losses 

2720.6171 

54.4123 

13603 

0.0272 

StanTrans, Inc. 4/24/98 19 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 4001 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

MTBE 

88.15 

70 

3.93 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Barrels 

0 

0 

0 

377398 

Losses Lbs. 

0.000 

0.000 

0.000 

64581.187 

TPY 

0.0000 

0.0000 

0.0000 

323906 

!losses 

+ 

Tank losses (pounds) 

Total losses gallons 

305436 

698.86 

Loading 

Total Pounds! 64581.187 

Controlled 1291.6237 

Total TPY 323906 

Controlled 0.6458 

StanTrans, Inc. 4/24/98 20 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 4002 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

Toluene 

92 

70 

0.425 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Barrels 

107,607 

111,969 

37,617 

42,675 

Losses Lbs. 

2077302 

2161.404 

290.457 

823.781 

TPY 

1.0386 

1.0807 

0.1452 

0.4119 

Loading losses 

Tank losses (pounds) 

Total losses gallons 

57435 

93.93 

Total Pounds|_ 

Controlled 

Total TPY 

Controlled 

5352.845 

107.0569 

2.6764 

0.0535 

StanTrans, Inc. 4/24/98 21 

Tl 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 5002 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

Xylene 

106.2 

70 

0.1308 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Barrels 

183 

96383 

0 

0 

Losses Lbs. 

1355 

660.989 

0.000 

0.000 

TPY 

0.0006 

03305 

0.0000 

0.0000 

• 7 > 

Tank losses (pounds) 

Total losses gaUons 

168.06 

114.57 

Loading losses 

Total Pounds [_ 662.2441 

Total TPY| 03311 

StanTrans, Inc. 4/24/98 22 

fe 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 5501 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

MTBE 

88.15 

70 

3.93 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Barrels 

0 

8,442 

42,749 

0 

Losses Lbs. 

0.000 

1443.849 

2924372 

0.000 

TPY 

0.0000 

0.7219 

1.4623 

0.0000 

* 

Tank losses (pounds) 

Total losses gallons 

1804.87 

260.64 

Loadinnggl losses 

Total Pounds 

Controlled 

Total TPY 

Controlled 

4368.420 

87.3684 

2.1842 

0.0437 

StanTrans, Inc. 4/24/98 23 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 6501 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

MTBE 

88.15 

70 

0393 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Barrels 

99320 

171,797 

0 

143,976 

Losses Lbs. 

1707.237 

2938371 

0.000 

2462.444 

TPY 

0.8536 

1.4691 

0.0000 

1.2312 

Tank losses (pounds) 

Total losses gaUons 

3847.43 

549.53 

Loadtn; 

Total Pounds 

Controlled 

Total TPY 

Controlled 

t losses 

7107.953| 

142.1591 

33540| 

0.0711 

StanTrans, Inc. 4/24/98 24 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 6501 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

Xylene 

106.2 

70 

0.1308 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

Rail 

Ship 

Barge 

Barrels 

0 

10,628 

0 

0 

Losses Lbs. 

0.000 

72.886 

0.000 

0.000 

TPY 

0.0000 

0.0364 

0.0000 

0.0000 

Tank losses (pounds) 

Total losses gallons 

12.05 

11.72 

Loadin 

Total Pounds t losses 

72.886 

Total TPY} 00364 

StanTrans, Inc. 4/24/98 25 
MAXIMUM HOURLY LOADING EMISSIONS 

(AP-42 CALCULATION) 

Tank 11201 

Product Name: 

Molecular Weight: 

Average Temperature 

Vapor Pressure: 

ESL: 

Meta Xylene 

106.18 

70 

0.1304 

(degrees F) 

@Temp 

(ug/m3) 

Receiving Vessel 

Truck 

RaU 

Ship 

Barge 

Barrels 

0 

0 

54,194 

98,789 

Losses Lbs. 

0.000 

0.000 

148.181 

675.290 

TPY 

0.0000 

0.0000 

0.0741 

03376 

Tank losses (pounds) 19834 

Loading losses 

Total Pounds L 823.471 

Total TPY 0.4117 

Total losses gallons 141.02 

StanTrans, Inc. 4/24/98 26 

Tl 
P.47 

Draft 

SPECIAL CONDITIONS 

PERMIT NO. 1677 

DOCKET 95-0358-AIR 

EMISSIONS STANDARDS 

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

Maximum Allowable Emission Rates'" and those sources are limited to the emission limits and other conditions 

specified in the maximum allowable emission rates table (MAERT). 

2. These facilities shall comply with all applicable requirements of Environmental Protection Agency (EPA) 

Regulations on Standards of Performance for New Stationary Sources promulgated for Storage Vessels for 

Petroleum Liquids in Title 40 Code of Federal Regulations Part 60 (40 CFR 60), Subparts A, K, Ka, and Kb. 

(The permit holder will maintain a list showing applicability of K, Ka, or Kb.) 

3. When benzene is stored, these facilities shall comply with all applicable requirements of EPA Regulations on 

National Emission Standards for Hazardous Air Pollutants Promulgated for Benzene Emissions in 40 CFR 61, 

Subparts A, J, Y, BB, and FF. 

DESIGN CONDITIONS 

4. New flares and those incorporated in any loading emissions abatement system shall be designed and operated in 

accordance with 40 CFR 60.18 including specifications of minimum heating value of the waste gas, maximum tip 

velocity, and pilot flame monitoring. If necessary to ensure adequate combustion, sufficient fiiel gas shall be 

added to make the gases combustible. An infrared monitor is considered equivalent to a thermocouple for flame 

monitoring purposes. 

5. Vapor Collection Systems 

A. A vacuum-assisted marine loading vapor abatement system shall be installed and operational for loading 

of compounds with true vapor pressures of 0.5 psia or higher. Control of compounds with true vapor 

pressures less than 0.S psia required under Special Conditions No. 13 shall be implemented before 

compound is received. Collected vapors shall be routed to a flare, carbon adsorption system, or other 

Texas Natural Resource Conservation Commission (TNRCC) approved abatement device. The 

collection efficiency shall be at least 95 percent. Destruction efficiency shall be at least 98 percent for 

flares. Carbon adsorption systems shall have a control efficiency of at least 95 percent. 

B. Emissions from tank truck and railroad tank car loading of compounds with true vapor pressures of 0.5 

psia or higher shall be controlled. The control of tanks storage and filling, and tank truck, or railroad 

tank car loading of compounds with true vapor pressures less than 0.5 psia required under Special 

Condition No. 13 shall be installed and operational before the compound is received. Collected vapors 

shall be routed to a flare, carbon adsorption system, or other TNRCC approved abatement device. The 

collection efficiency shall be at least 95 percent. Destruction efficiency shall be at least 98 percent for 

flares. Carbon adsorption systems shall have a control efficiency of at least 95 percent. 

C. A vapor control system shall be judged at least 95 percent efficient if a return line is directed to the 

control system or when vapor balance back to the originating tank is used. 

D. A vapor collection system shall be judged 100 percent efficient if an approved vacuum assist or 

"hard piped" system is used. Proof of "hard piped" connections shall be: 

1. Records certifying receipt and presentation, at each loading and unloading event, of current DOT 

certification that the liquid carrying vessel meets a pressure standard of at least 15 pounds per 

square inch gauge (psig); 

Rev. 1 2/06/98 ^rQ Page 1 of 6 
Draft 

2. Documentation shall be presented to the Office of Air Quality, Permits Section (see Special 

Condition No. 6 below) that shows the connections to the vapor control system are capable of 

vapor-tight operation at the proposed loading conditions. This is construed to mean any 

combination of data indicating leak tight operation at a minimum of 15 psig, particularly at each 

connection. This documentation shall be updated when new or modified loading spots are brought 

under this permit. Approved "hard piped" loading spots shall be identified as required controls "D" 

on the Required Controls List (RCL) of this permit. 

6. The holder of this permit shall forward to the staff" of the TNRCC more detailed engineering data on future 

abatement equipment as it becomes available. This information shall include (but is not limited to): final system 

designs, collection efficiencies, destruction efficiencies, and appropriate TNRCC tables (e.g., Tables 8 for a 

flare). 

OPERATIONAL LIMITATIONS 

7. Loading emissions abatement requirements, by compound storage and loading scenario, are shown in 

Attachment I. These restrictions shall be implemented in accordance with the schedules in Special Condition 

No. 5. 

8. Storage of benzene at these facilities shall be limited to no more than 300,000 barrels at any time in no more 

than six tanks. Throughput of benzene shall be limited to no more than 1.8 million barrels per year. 

9. The holder of this permit shall reduce the temperature and/or vapor pressure ofthe stored material, as needed, 

to maintain a vapor pressure of less than 0.5 psia at actual storage conditions in all fixed-roof tanks. Storage 

of compounds with higher vapor pressures shall be allowed in a fixed-roof tank if all working and breathing 

losses are vented to a flare, carbon adsorption system, or other TNRCC-approved abatement device. 

10. For compounds with true vapor pressures greater than or equal to 0.5 psia, records shall be maintained at the 

terminal showing start and stop times for loading operations. 

11. Tank filling rates shall not exceed the ESL off-site impact represented on the most recent scenario sheet. 

Loading rates at the loading spots shall be as noted in the Required Controls List (RCL). Product transfer 

records shall include loading rates. 

12. Only loading spots approved in accordance with Special Condition No. 13 may be used. Maximum ESL offsite impacts specified in the RCL shall not be exceeded. New loading spots or increased pumping rates must 

also be approved through the process specified in Special Condition No. 13. 

SERVICE AND CHANGE OF SERVICE LIMITATIONS 

13. New service and change of service in tanks, as well as, direct transfer operations at this facility shall be 

reviewed as described below. 

A. Baseline full facility modeling current at the date of new or change of service, and on record with the 

TNRCC, shall be used. The modeling shall be updated each time an emissions point is added or 

physically changed in a manner that results in an increase in or change in character of emissions (i.e., a 

permit amendment is triggered or an emissions point is added through registration of a standard 

exemption). All off-property health impact determinations shall be made based on the latest TNRCC 

Toxicology and Risk Assessment (TARA) Section Effects Screening Levels (ESL). 

B. Compounds not listed on the ACL: The permit holder shall submit a letter change, including (1) scenario 

sheet (s) listing tank number, compound name, loadspots, controls required, (2) EPA Tanks 3 

calculations, (3) ESL Checklist (s)-Short-Term (equivalent to those included in the permit 

representations), (4) exceedance summary (ies), (5) modeling impacts summary (ies), (6) ESL Summary 

(ies), and (7) Verification of ESL assessment. 

Rev. 1 2/06/98 J^O PaS

e 2 of 6 
Draft 

C. Compounds: 

1. If the worst-case impacts from all tanks and loading losses are less than or equal to lOxESL, then 

tank product service may be changed immediately. The impacts check data shall be attached to the 

facility's duplicate RCL (Special Condition No. 16) on or before service changes. The permit RCL 

shall be updated monthly by a letter change containing the items listed in subparagraph 13 (B) 

above. 

a. For simultaneous loading at two different loading points, the maximum off-property impacts 

shall simply be added and compared to the ESL. If less than 2xESL, then submit the required 

information. If greater, then proceed to sub paragraph 13© (2). 

b. For simultaneous loading at three or more different points, full modeling will be done to 

identify the maximum off-property impacts. If less than 2xESL, submit the required 

information. If greater, then proceed to paragraph 13© (2). 

c. The combined loading rate of a single compound from a single tank through two or more 

loading spots, if limited to the lowest loading rate specified on the approved scenario sheet, 

shall not be considered simultaneous loading under Special Condition No. 10. 

2. If the worst-case impacts from all tank and loading losses are greater than 2xESL but less than 

lOxESL, an amendment request shall be submitted. The request shall include the items listed in 

subparagraph 13(B) above. Any permit amendment in the 2xESL to lOxESL range may not 

exceed a total of 10 hours of exceedances per year. 

3. Impacts greater than lOxESL are unacceptable to the TNRCC. Additional abatement or 

operational restrictions must be found to create a storage and loading scenario acceptable under 

(1) or (2) above, or a permit amendment shall be filed for a variance request review. 

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

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

of less than 0.5 psia at 100°F or at maximum process operating temperature if less than 100°F, or (2) 

where the. 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. 

B. Construction of new and reworked piping, valves, and pump 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 in TNRCC 30 TAC Chapter 115 (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 

period 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, 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. Sealless/leakless valves (including, but not limited to, bellows and diaphragm 

Rev. 1 2/06/98 Jj | Page 3 of 6 
P.50 

Draft 

valves) and relief valves equipped with a rupture disc, 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 the requirements listed in Title 40 Code of Federal 

Regulations Part 60.485(a) - (b) (40 CFR 60.485 [a] - [b]). 

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 automatic seal failure detection, and alarm systems need not be 

monitored. Seal systems that prevent emissions may include (but are not limited to) dual pump seals with 

barrier fluid at higher pressure than process pressure or seals degassing to vent control systems kept in 

good working order. 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, flanges, compressor seal, and pump seals found to be emitting VOC in 

excess of 10,000 ppmv or found by visual inspection to be leaking (e.g., dripping liquids) shall be tagged 

and replaced or repaired. 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. 

I. The results ofthe 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. 

J. Fugitive emission monitoring required by TNRCC regulation V, applicable New Source Perfonnance 

Standard (NSPS), Title 40 Code of Federal Regulations Part 60 (40CFR 60), or an applicable National 

Emission Standard for Hazardous Air Pollutants (NESHAPS) 40 CFR 61 may be used in lieu of items F 

through I of this condition. 

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

TNRCC Regulation V, NSPS, or NESHAPS and does not constitute approval of alternative standards 

for these regulations. 

15. STORAGE AND LOADING OF VOC 

A. The control requirements specified in paragraphs B-E of this condition shall not apply (1) where the 

VOC has an aggregate partial pressure of less than 0.5 psia at the maximum expected operating 

temperature or (2) to storage tanks smaller than 25,000 gallons. 

B. An internal floating deck or "roof or equivalent control shall be installed in all tanks. The floating roof 

shall be equipped with one of the following closure devices between the wall ofthe storage vessel and 

the edge ofthe 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 equivalent control requires prior review 

and approval by the Executive Director. 

C. 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 intemal 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. 

D. For any tank equipped with a floating roof, the holder of this permit shall follow Title 40 Code of 

Rev. 1 2/06/98 Page 4 of6 
P.51 

Draft 

Federal Regulations Part 60.113b (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 ofthe dates seals were inspected, seal integrity, and corrective actions taken. 

E. 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. 

F. Uninsulated tank exterior surfaces exposed to the sun shall be white. 

G. Throughput records shall be kept for all tanks and load spots to assure compliance with Special 

Condition 16 entitled, Verification of Continuing Compliance. 

H. Emissions for tanks and loading operations shad be calculated using: (a) AP-42 "Compilation of Air 

Pollution Emission Factors"; and (b) the attached edition of Texas Air Control Board (now a part ofthe 

TNRCC) memo entitled "Annual and short Term Emissions from Storage Tanks". 

* I. Operation without visible liquid leaks or spills shall be maintained at all loading and/or 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 and/or 

unloading operations is not permitted. Any liquid spill that occurs during loading and/or unloading 

activities shall be reported pursuant to TNRCC Rule CFR101.6 or CFR101.7 and shall be cleaned up 

immediately to minimize air emissions. 

16. VERIFICATION OF CONTINUOUS COMPLIANCE 

A. Hourly and Annual Emission caps shall be calculated as follows: 

1. Total cumulative tank volatile organic compounds (VOC) emissions shall be reviewed monthly to 

ensure the annual allowable listed in the maximum allowable emissions rate table will not be 

exceeded. Tank filling rates shall not exceed the ESL offsite impact represented to the TNRCC as 

required by Special Condition 13. Annual emission caps will be made available for review when 

requested. 

2. Throughput records for all loading operations shall be maintained to ensure VOC emission rates do 

not exceed the maximum ESL off site impact represented to the TNRCC as required by Special 

Condition 13. 

R Carbon Adsorption System Special Conditions: 

1. All Carbon Adsorption Systems required by Special Condition 13, or 40 CFR 60, will consist of a 

minimum of two carbon beds in series. 

2. Tanks or loading systems dedicated to a single compound will be checked a minimum of once a 

quarter with a portable Organic Vapor Analyzer during loading operations. An OVA reading of 

100 ppmv or greater, at a point between the canisters, shall indicate breakthrough has occurred. 

The first canister shall be disposed of in an approved manner, and the second canister shall replace 

the first. A new canister shall be added to the end ofthe series. Records shall be kept of canister 

life and replacement. 

3. A minimum of three (3) carbon canisters in series shall be installed when more than three (3) 

compounds are vented directly to a carbon adsorption system at the same time. 

17. RECORDKEEPING REQUIREMENTS 

A. A duplicate ofthe RCL, or its equivalent, shall be kept available at the facility. It shall be organized by 

tank, showing the compound currently approved to be in that tank, the loading spots currently approved 

for use, and the associated control requirements for loading operations. These records will be annotated 

Rev. 1 2/06/98 s^ J3 J Page 5 of 6 
P.52 

Draft 

with the date the tank/spot scenario was added or last changed, and will reference the document used to 

obtain TNRCC approval (permit amendment, standard exemption registration, and letter change). 

B. StanTrans is to notify the TNRCC how any changes in permit emissions will affect the Confidential 

Section ofthe permit application. 

C. StanTrans is to determine if any proposed emission increases associated with the addition or change of 

chemicals will increase VOC or nitrogen oxides by five tons per year (tpy) or more. If a five tpy 

increases in actual emissions is noted, StanTrans is to submit plantwide modeling to the TNRCC prior to 

initiating the change. Emission Point Numbers (EPNs) listing cumulative annual emissions by facility 

type (i.e., all tanks together, all tank farm loading, all dock loading) shall be considered as the pertinent 

EPN for purposes of netting. 

18. DISCLAIMER 

Issuance of this permit does not assure compliance with or constitute approval of marine vapor control 

systems pursuant to requirements ofthe United States (U.S.) Coast Guard which may have jurisdiction over 

the design and operation of such systems. The holder of this permit is advised to contract the U.S. Coast 

Guard regarding this matter. 

19. AMPLIFICATION OF SPECIAL AND GENERAL CONDITIONS 

A. General Condition No. 9: The air pollution control equipment is defined as that required by the permit or 

applicable Federal and Texas rules and regulations. 

B. Special Condition No. 14E: Second sentence means screwed connections are permissible on piping two 

inches and smaller in diameter. 

C. Special Conditions No. 15: 

1. 15A: 87.5° F as shown on Tanks 3.0 Program, Galveston, Texas, meteorological data. 

2. 15D: Internal floating roof tanks shall be inspected visually in accordance with 40 CFR 60, 

paragraph 113b. 

3. 151: Equipment fugitives are not included in the required calculations. 

Rev. 1 2/06/98 —54' • Page 6 of 6 -
P.53 

ATTACHMENT 4 

65 
P.54 

STANTRANS, INC. 

AdUU 1 \\i 

P.O. Box 3608 "^ ' f 

201 Dock Road 

Texas City. TX 77592-3608 

(409) 948-3561 

Aumist 12 1998 <409> •«-«««• (FAX) 

August iz, iw o mike_holdman@8t8«rvice8.net (EMAIL) 

Mr. Kent C. Hustvedt 

Group Leader 

Waste and Chemical Process Group 

United States Environmental Protection Agency 

Research Triangle Park* NC 27711 

Dear Mr. Hustvedt: 

We are in receipt of your site visit report dated July 10,1998 and generally speaking, it was very 

accurate. One area that requires further clarification is the tank trucks section on page 6. The report 

states that tank trucks are top loaded at the ST Service facility. We do top-load a few tank trucks with 

products that do not require vapor control. All products requiring vapor control are bottom loaded 

widi die top connections used for vapor control and high-level alarms/overfill protection devices. 

The tank truck section on page 6 also states that ST Services pressure tests tank trucks that handle 

Acrylates for 3 days. Acrylate tank trucks are pressured up after being loaded and all threaded 

connections are checked and the tank truck is released if no vapors are detected. We pressure test tank 

cars of Ethyl Acrylate and Memyl Acrylate for three days after they are loaded. 

The report also states on page 9 under VTJ Action Items that ST Services agreed to provide 

infonnation about wastewater generation rates and sources of wastewater generation, HAP content of 

wastewater and the incoming and outgoing HAP concentrations of wastewater. The wastewater 

quantities and concentrations of HAP in the wastewater are moving targets and records of both are not 

kept. Most of our wastewater is storm water and water from hydrostatic testing of tanks, pipelines and 

hoses. We do not have any processes that generate wastewater that would contain any HAP's. All 

wastewater that would possibly contain copious amounts of HAP's is drummed and disposed of as 

hazardous waste. 

If you have any questions regarding diis matter, please contact me at the above address, or by calling 

(409)948-3561. 

Sincerely, 

Michael D. Holdman 

Director of Operations 

Cc: Kyle Mullins, Mark A. Saxton 

ISO 9002 Certified 5<o 
P.55 

ATTACHMENTS 

5? 
SECTION 3 - E 

FACILITY FUGITIVE EQUIPMENT INFORMATION 

FOR ADDED AND EXISTING FACILITIES 

INRCC AIR PROGRAM ACCOUNT NUMBER: GBOOOSJ 

IIN: -HlfL FACILITY NAME:

 FS3] U ve s 

1

 METHODOLOGY USED: 

CtiMPttNENT ! 

1

 VALVES- GAS/VAPOR 

LIGHT LIQUID/LIGHT OIL 

HEAVY LIQUID/HEAVY OIL 

WATER/LIGHT OIL MIXTURE 

J

 PUMPS- GAS/VAPOR 

LIGHT LIQUID/LIGHT OIL 

HEAVY LIQUID/HEAVY OIL 

WATER/LIGHT OIL MIXTURE 

* FLANGES- GAS/VAPOR 

LIGHT LIQUID/LIGHT OIL 

HEAVY LIQUID/HEAVY OIL 

WATER/LIGHT OIL MIXTURE 

1

 RELIEF VALVES 

• rOMI'RFWORS 

PROCESS FUGITIVE EMISSIONS ESTIMATION METHODOLOGY 

COMPONENT COUNT 

3225 

159 

7285 

TOTAL HRS IN SERVICE* 

8760 

8760 

8760 

INSPECTION PROGRAM 

' I lour, ihould he 8760 unlc» the linei hive been purged 

IIIKCC0137J lllev. 10/24/96) •5* 

cn 
Chemical Manufacturing Fugitives 

SOCMI without ethylene; TNRCC derived 

Component 

Valves 

Pumps 

Flanges 

Compressors 

Relief Valves 

Open Lines 

Sampling 

Connections 

Gas 

Light Liq. 

Heavy Liq. 

Light Liq. 

Heavy Liq. 

Gas 

Light Liq. 

Heavy Liq. 

Count 

0 

3225 

0 

159 

0 

0 

7285 

0 

0 

0 

0 

27 

Factor Ibs/hr comp. 

0.0089 

0.0035 

0.0007 

0.0386 

0.0161 

0.0029 

0.0005 

7.00E-05 

0.5027 

0.2293 

0.004 

0.033 

Hours/year 

8760 

8760 

8760 

8760 

8760 

8760 

8760 

8760 

8760 

8760 

8760 

8760 

% Reduc. 

0 

75 

0 

75 

0 

0 

30 

0 

0 

75 

75 

75 

Lbs/Year 

0 

24.719.63 

0 

13,440.91 

0 

0 

22,335.81 

0 

0 

0 

0 

1.951.29 

Tons/Year 

0.000 

12.360 

0.000 

6.720 

0.000 

0.000 

11.168 

0.000 

0.000 

0.000 

0.000 

0.976 

|Tolals 62.447.63 31.2238| 

Note: Without ethylene is defined as < 11% ethylene in the stream. 

4/21/97 

Ui