Construction Permit
Source Analysis & Technical Review
Company
City
County
Project Type
Project Reviewer
Site Name
Slay Transportation Co., Inc.
Permit Number
Baytown
Project Number
Chambers
Account Number
Initial
Regulated Entity Number
Mr. Matt Earnest, Ph.D., E.I.T.
Customer Reference Number
Slay Transportation Baytown Facility
114681
200877
N/A
RN106954704
CN600269427
Project Overview
Slay Transportation Co. (Slay) requested an initial permit for a greenfield site in Baytown TX. Slay is seeking authorization
to construct and operate a facility to internally clean tank containers. The site would consist of two boilers, a flare, a wash
rack, four wastewater tanks, a solvent cleaning system and other buildings not expected to emit pollutants. Normal
operations would include internally cleaning empty tank containers (semi-trailers, isocontainers, intermodals and totes),
solvent rinsing, heel drumming, and wastewater loading. Dependent on the product last transported, vapors will be routed
to the flare or emitted to the atmosphere uncontrolled. As planned MSS activities are developed in the future, they will be
authorized separately under PBR 106.263.
Emission Summary
Air
Contaminant
PM
PM10
PM2.5
VOC
NOX
CO
SO2
Proposed Allowable
Emission Rates (tpy)
0.28
0.28
0.28
11.38
11.51
23.36
0.06
Compliance History Evaluation - 30 TAC Chapter 60 Rules
A compliance history report was reviewed on:
Compliance period:
Site rating & classification:
Company rating & classification:
If the rating is 50<RATING<55, what was the outcome, if
any, based on the findings in the formal report:
Has the permit changed on the basis of the compliance
history or rating?
12/19/2013
9/1/2008 – 8/31/2013
n/a
Unclassified
n/a
no
Public Notice Information - 30 TAC Chapter 39 Rules
Rule Citation Requirement
39.403
Date Application Received:
October 24, 2013
Date Administratively
Complete:
November 12, 2013
Small Business Source?
Date Leg Letters mailed:
November 12, 2013
39.603
Date Published:
12/5/2013
Publication Name:
Houston Chronicle
Pollutants:
organic compounds, nitrogen oxides, carbon monoxide, sulfur
dioxide, and particulate matter including particulate matter
with diameter of 10 microns or less and 2.5 microns or less
Date Affidavits/Copies
Received:
12/19/2013
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Construction Permit
Source Analysis & Technical Review
Permit No. 114681
Page 2
Rule Citation
39.604
39.419
39.603
Requirement
Is bilingual notice required?
Language:
Date Published:
Publication Name:
Date Affidavits/Copies
Received:
Date Certification of Sign
Posting / Application
Availability Received:
Public Comments Received?
Hearing Requested?
Meeting Request?
Date Response to Comments
sent to OCC:
Consideration of Comments:
Is 2nd Public Notice
required?
Date 2nd Public
Notice/Preliminary Decision
Letter Mailed:
Date Published:
Publication Name:
Pollutants:
Regulated Entity No. RN106954704
Yes
Spanish
12/8/2013
Houston Chronicle Dba La Vos
12/19/2013
1/14/2014
No
No
No
n/a
n/a
Yes
4/7/2014
4/24/2014
Houston Chronicle
organic compounds, nitrogen oxides, carbon monoxide, sulfur
dioxide, and particulate matter including particulate matter
with diameter of 10 microns or less and 2.5 microns or less
Date Affidavits/Copies
Received:
Is bilingual notice required?
Language:
Date Published:
Publication Name:
Date Affidavits/Copies
Received:
Date Certification of Sign
Posting / Application
Availability Received:
Public Comments Received?
Meeting Request?
5/13/2014
Yes
Spanish
4/27/2014
La Voz
5/13/2014
5/28/2014
No
No
Construction Permit & Amendment Requirements - 30 TAC Chapter 116 Rules
Rule Citation
Requirement
116.111(a)(2)(G)
Is the facility expected to perform as represented in the application?
yes
116.111(a)(2)(A)(i Are emissions from this facility expected to comply with all TCEQ air quality Rules
yes
)
& Regulations, and the intent of the Texas Clean Air Act?
116.111(a)(2)(B)
Emissions will be measured using the following
Calculations based on truck volume
method:
cleaned
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Source Analysis & Technical Review
Permit No. 114681
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Rule Citation
116.111(a)(2)(D)
116.111(a)(2)(E)
116.111(a)(2)(F)
116.111(a)(2)(H)
116.111(a)(2)(I)
116.111(a)(2)(L)
116.140 - 141
Regulated Entity No. RN106954704
Requirement
Comments on emission verification:
Subject to NSPS?
no
Subparts
&
Subject to NESHAP?
no
Subparts
&
Subject to NESHAP (MACT) for source categories?
no
Subparts
&
Nonattainment review applicability:
The site is a minor source located in Chambers County which is classified as nonattainment for ozone.
Emissions do not exceed the major source threshold, therefore Nonattainment review does not apply.
PSD review applicability:
The site will not be a major source for any regulated air pollutants therefore PSD review does not apply
Is Mass Emissions Cap and Trade applicable to the new or modified facilities?
No
If yes, did the proposed facility, group of facilities, or account obtain allowances to
operate:
n/a
Permit Fee: $ 2,490.00
Fee certification:
R404906
Title V Applicability - 30 TAC Chapter 122 Rules
Rule Citation Requirement
122.10(13)
Title V applicability:
The site will not be a major source for any regulated air pollutants and is not a listed source, therefore
Title V is not applicable
122.602
122.604
Periodic Monitoring (PM) applicability:
This is not a major source therefore PM does not apply. Notwithstanding monitoring is as follows:
--EPN FL-1 (Flare) The flare is monitored with a thermocouple or infrared monitor and assist gas
pressure must be checked daily prior to startup.
Compliance Assurance Monitoring (CAM) applicability:
CAM is not required because the emissions are less than 25 TPY VOC or NOx and less than 10 TPY HAP
prior to control.
Request for Comments
Received From
Program/Area
Name
Region:
12
City:
Baytown
County:
Chambers
Toxicology:
n/a
Compliance:
n/a
Legal:
n/a
Comment resolution and/or
unresolved issues:
Reviewed By
Comments
Mengistu Lemma
n/a
n/a
n/a
n/a
n/a
none
n/a
n/a
n/a
n/a
n/a
Process/Project Description
Slay proposed to construct a tank truck washing rack at this greenfield site. Empty tank trucks which had previously
contained a variety of chemical compounds will be washed using hot water and spinning sprays in one of six wash bays. A
blower will continually draw vapors during the cleaning process. Organic vapors will be routed to the atmosphere or to a
flare if the impacts demand control. Depending on the product last transported, any residual liquid (Heel) remaining
inside the containers is removed and drummed prior to cleaning. Rinse water is preheated in one of two heaters prior to
the wash cycle. Dirty rinse water is pumped to one of four waste water tanks for storage prior to disposal. Emissions from
wastewater loading into tank trucks for off-site transfer were included in the impacts evaluation.
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Regulated Entity No. RN106954704
Containers and transfer hoses that last transported certain resins or other viscous products that tend to adhere to the
container walls may undergo an initial solvent rinse prior to cleaning. An organic solvent (monoethanolamine, MEA) is
pumped from one of two small 550 gallon reservoir or a smaller 330 gallon reservoir tanks into the container through the
spinner assembly to loosen and dissolve the material residue adhering to the interior surface. The spent solvent is returned
to the solvent reservoir for reuse. The system is vented to the flare during solvent rinse operations.
There are nine emission points for the sources associated with the proposed facility.
-Two 4.2 million British thermal unit per hour (MMBtu/hr) natural gas fired boilers, Emission Point Numbers (EPN) BLR1 and BLR-2;
-A 40-foot tall smokeless natural gas fueled, air assisted, flare used to control emissions of VOC collected from the wash
rack during the cleaning of certain chemicals and operating losses from the MEA system ( EPN FLR-1)
-The facility Wash Rack, EPN CL-1, which is the source of uncontrolled VOC emissions generated during the cleaning of
empty containers that last held certain low volatility chemicals with minimal potential for off-property impact, Drumming
of residual product liquids (Heel), and fugitive losses associated with the MEA system.
- Four 8,500 gallon fixed roof tanks that store waste water generated from the internal cleaning process and contain small
concentrations of VOC which will vent to the atmosphere (EPNs WWT-1 thru WWT-4)
-An EPN accounts for loading emissions from the accumulated waste water that is periodically loaded into a tank truck for
off-site shipment (EPN WWLD-1)
Pollution Prevention, Sources, Controls and BACT- [30 TAC 116.111(a)(2)(C)]
Tank Container Cleaning
Transport vessels that last held VOC with vapor pressure > 0.5 psia will be connected to a vacuum vapor collection system,
degassed to a control device (flare), and de-heeled prior to cleaning. Emissions from the Wash Rack were calculated using
an equation derived from the Ideal Gas Law assuming complete displacement of the vapor saturated volume of each
container and based on simultaneous cleaning operations represented in the application. Artificial limits were taken on the
number of trucks that could be cleaned at one time based on impacts. BACT is satisfied.
Flares
The proposed flare is a 40 foot tall smokeless gas flare with continuous pilot and enough supplemental natural gas fuel
system to ensure compliance with the minimum 300 Btu/scfm assuming waste gas has zero heating value. This satisfies
requirements in 40 CFR 60.18. Assist gas feed pressure must be checked daily prior to operation. Emissions of residual
VOC from the flare were calculated based on a thermal destruction efficiency of 98% and assuming simultaneous cleaning
operations in each bay of a representative chemical from Chemical List I in the application. Emissions of the combustion
products NOx and CO were estimated using the emission factors for flares recommended in TCEQ Technical Guidance for
Flares and Vapor Combustors, RG-109. SO2 emissions were estimated using the emission factors for combustion of the
natural gas fuel in Chapter 1.4 of AP-42. BACT is satisfied.
Boilers
The boilers to be operated at the facility will fire sweet natural gas and individually have a rated heat input capacity of 4.2
MMBtu per hour each. The boilers will be equipped with low-NOx burners designed to achieve a NOx emission rate of 30
ppmv at 3% 02 (0.036 lb/MMBtu) or less in which complies with the standard for minor sources in 30 TAC 117.2010(c).
The boilers will have CO emission rate of less than 400 ppmv. Emissions of the other combustion products SO2, PM10
PM2.5 and VOC were estimated using AP-42 factors from Chapter 1.4. BACT is satisfied.
Storage Tanks
The facility operates several tanks for the storage of MEA solvent and the storage of waste water containing small
concentrations of VOC. The MEA solvent storage tanks include two 550 gallon fixed roof vessels (totes) and one 330 gallon
fixed roof vessel (tote) containing monoethanolamine (MEA) which has a vapor pressure less than 0.5 psia. The tanks are
located under a roof and are not exposed to direct sun. Submerged fill is employed when transferring solvent into the tanks
The four 8,500 gallon waste water tanks store waste water containing organic compounds with a VOC partial pressure less
than 0.5 psia. Submerged fill is employed when transferring waste water into the tanks. BACT is satisfied.
Loading Operations
Accumulated waste water is periodically loaded into tank trucks for off-site treatment and disposal. The waste water
loaded has a VOC partial pressure less than 0.5 psia, therefore vapor collection and control is not required. The transfer of
waste water to tank trucks is performed using bottom loading. BACT is satisfied.
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Regulated Entity No. RN106954704
Equipment Leak Fugitives
The TCEQ Best Available Control Technology (BACT) Requirements for Equipment Leak Fugitives (last updated
08/01/2011) requires no implementation of a leak detection and repair (LDAR) program where the level of uncontrolled
fugitive VOC emissions is < 10 TPY. Estimated fugitive emissions from equipment and piping components associated with
the MEA solvent systems is well below 10 TPY. Fugitives from the MEA system are included in the wash rack EPN (CL-1)
because the MEA system is wholly contained within the wash rack structure. Wastewater fugitives are separated out as
their own EPN (WWFUG). Therefore, implementation of a fugitive monitoring program is not required.
Impacts Evaluation - 30 TAC 116.111(a)(2)(J)
Was modeling conducted?
yes
Will GLC of any air contaminant cause violation of NAAQS?
Type of Modeling:
Screen 3
A residence is immediately adjacent to the north
Is this a sensitive location with respect to nuisance?
property line.
[§116.111(a)(2)(A)(ii)] Is the site within 3000 feet of any
school?
no
Additional site/land use information:
The site is located in the Cedar Crossing Industrial Park development within the City of Baytown extra territorial
jurisdiction. Applicant contends all properties within the park are planned for industrial/commercial development, with city
approval.
Summary of Modeling Results
Screen 3 was run for the flare (FL-1) and wash rack (CL-1). The two are adjacent to each other and the nearest property
line is to the south while the nearest non-industrial receptor is the property line to the north (the south property line is
high voltage transmission line right of way). The results of the flare Screen modeling run indicated that stability class 6
with a wind speed of 1.0 m/s produced the worst case GLC. Pursuant to ADMT guidance, the Screen 3 model was rerun
with a fixed wind speed adjusted to 1.5 m/s to calculate the unit impact multiplier used for the MERA analysis.
MERA discussion
Emissions of 51 chemical constituents and two commercial product mixtures were evaluated using the MERA. The MERA
analysis was performed on three tables to ensure that impacts were acceptable. The tables are titled “Chemical List I”,
“Chemical List II”, and “MEA Solvent Cleaning”. All compounds are less than 1 x ESL. 14 Chemicals fell out at Step 4. 7
Chemicals fell out at Step 5 using the x factor from the tables attached to the MERA and the remainder of the constituents
were less than the ESL. Slay had to accept artificial truck washing limits lower than the default of 3 truck per hour for 2.4Toluenediisocyanate, 2,6-Toluenediisocyanate, Dichlorobenzene, and Trichlorobenzene because of impacts.
NAAQS discussion
SCREEN3 was used to conservatively estimate off-property concentrations of criteria pollutants from the proposed new
combustion sources (boilers BLR-1, BLR-2 and flare FL-1). The resulting pollutant concentrations are conservative
because: (1) they were derived utilizing the SCREEN3 meteorological data set, (2) are based on maximum firing capacity
for each source assuming simultaneous operation, and (3) source impacts are summed regardless of receptor location and
time of occurrence.
Table 1 below and show the maximum predicted impacts for the criteria pollutants for each averaging periods and their
respective SILs. As can be seen all pollutants are below the SIL except for 1-hr NO2. New guidance on use of the PM2.5 SIL
has come out based on the fact that the SIL may not be accurate and use of the SIL could cause an exceedance of the PM2.5
standard. Because of this, a demonstration has to be made that the standard minus the background concentration
obtained from a representative monitor is greater than the SIL. If this is true, the SIL can be utilized. Maximum
background concentrations of 13.3 µg/m3 (24-hr) and 1.2 µg/m3 (annual) were obtained from the CAMS 8 (482010024)
Monitor. The 24-hr standard of 35 µg/m3 minus the background concentration of 13.3 µg/m3 is equal to 11.7 µg/m3 which
is greater than the SIL of 1.2 µg/m3 and therefore the 24-hr SIL can be utilized. The annual standard of 12 µg/m3 minus
the background concentration of 1.2 µg/m3 is equal to 10.8 µg/m3 which is greater than the annual SIL and therefore the
annual SIL can be utilized. The PM2.5 project increases are not expected to pose a significant deterioration of the NAAQS.
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Regulated Entity No. RN106954704
Table 1 also shows that the proposed site is expected to comply with the state SO2 fence line standard (30 TAC 112.3(a)).
The standard requires that the offsite SO2 concentration not exceed 0.74 µg/m3 (0.28ppmv) on a 30-min average. AQMD
guidance indicates that the hourly average is acceptable for comparison to this standard. The hourly average maximum
predicted ground level concentration is below the standard,
Table 1: SCREEN3 impacts compared to SILs
Monitoring station CAMS 1015 (482011015) is the closest NO2 monitor (located at the Lynchburg Ferry) to the proposed
site and the monitor has a greater quantity of NO2 emitted within 5 km than NO2 emitted within 5km of the proposed site.
Further, aerial photographs show CAMS 1015 (482011015) represents conditions near the Slay project site with respect to
proximity and density of industrial properties with similar emission sources. Thus, Lynchburg Ferry was accepted as the
representative monitor.
Table 2 below shows the maximum predicted 1-hour and annual NO2 impacts by SCREEN3, the background
concentrations obtained from the nearby ambient monitoring, and the maximum predicted cumulative impacts. As can be
seen, the cumulative impacts are less than the NAAQS, therefore this site is not expected to contribute to a potential
exceedance of the NAAQS.
Table 2: NO2 NAAQS compliance
Notes: (1) The 3-year average of the 98th percentile of the daily maximum 1-hour average from selected ambient
monitoring station.
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Regulated Entity No. RN106954704
Permit Concurrence and Related Authorization Actions
Is the applicant in agreement with special conditions?
Company representative(s):
Contacted Via:
Date of contact:
Other permit(s) or permits by rule affected by this action:
List permit and/or PBR number(s) and actions required or
taken:
Project Reviewer
Date
Yes
Philip Evans
Eamil
3/26/14
n/a
n/a
Team Leader/Section Manager/Backup
7
Date