~ SWCAA TECHNICAL SUPPORT DOCUMENT TRISTAR TRANSLOAD PNW, INC. SWCAA ID: Air Discharge Permit Air Discharge Permit Application CL-3039

Transcription

1 ~ SWCAA ~\ Southwest Clean Air Agency TECHNICAL SUPPORT DOCUMENT TRISTAR TRANSLOAD PNW, INC. SWCAA ID: 2500 Air Discharge Permit Issued: March 15, 2018 Prepared By: Clint Lamoreaux Air Quality Engineer Southwest Clean Air Agency

2 TABLE OF CONTENTS Section I. Facility Identification 2. Facility Description 3. Current Permitting Action 4. Process Description 5. Equipment/ Activity Identification 6. Emissions Determination 4 7. Regulations and Emission Standards RACT/BACT/BART/LAER/PSD/CAM Determinations Ambient Impact Analysis Discussion of Approval Conditions Start-up and Shutdown Provisions/ Alternative Operating Scenarios/Pollution 14 Prevention 12. Emission Monitoring and Testing Facility History Public Involvement 14 Page

3 Air Discharge Pennit Application CL-3039 Abbreviations ADP AP-42 BACT BART Btu CAS # CPM CFR co C02e EPA GWP HAP lb/hr lb/mmbtu lb/yr MMBtu/hr NOx PM PM10 ppm PSD RCW SQER S02 SW CAA TAP T-BACT tpy voe WAC Air Discharge Permit Compilation of Emission Factors, AP-42, Fifth Edition, Volume 1, Stationary Point and Area Sources - published by the US Environmental Protection Agency Best available control technology Best Available Retrofit Technology British thermal unit Chemical Abstracts Service registry number Condensable particulate matter Code of Federal Regulations Carbon monoxide Carbon dioxide equivalent U.S. Environmental Protection Agency Global warming potential Hazardous air pollutant listed pursuant to Section 112 of the Federal Clean Air Act Pounds per hour Pounds per million British thermal units Pounds per year Millions of British thermal units per hour Nitrogen oxides Total particulate matter (includes both filterable and condensable particulate matter as measured by EPA Methods 5 and 202) Particulate matter with an aerodynamic diameter less than or equal to 10 micrometers (includes both filterable and condensable particulate matter as measured by EPA Methods 5 and 202) Particulate matter with an aerodynamic diameter less than or equal to 2.5 micrometers (includes both filterable and condensable particulate matter as measured by EPA Methods 5 and 202) Parts per million Prevention of Significant Deterioration Revised Code of Washington Small Quantity Emission Rate listed in W AC Sulfur dioxide Southwest Clean Air Agency Toxic air pollutant pursuant to Chapter WAC Best Available Control Technology for toxic air pollutants Tons per year Volatile organic compound Washington Administrative Code

4 1. FACILITY IDENTIFICATION Applicant Name: Applicant Address: 3702 NW Gateway Ave., Vancouver, WA Facility Name: Facility Address: SWCAA Identification: Contact Person: Primary Process: SIC/NAICS Code: Facility Classification: Tristar Transload PNW, Inc 3702 NW Gateway Ave., Vancouver, WA Mr. Peter Howe LPG (butane and propane) transfer 5171 I BACT / Minor 2. FACILITY DESCRIPTION Tristar Transload transfers liquified petroleum gas (LPG) from railcars to tanker trucks using portable transloaders. Two transloaders will be used primarily for butane transloading (Butane Transloader #1 and #2), and two transloaders will be used primarily for propane transloading (Propane Transloader #1 and #2). 3. CURRENT PERMITTING ACTION This permitting action is in response to Air Discharge Permit application number CL-3039 (ADP Application CL-3039) received February 27, ADP application CL-3039 requests approval to utilize a different butane transloader and engine than originally approved. 4. PROCESS DESCRIPTION Butane/Propane/LPG is received by railcar on a rail spur at the site. Two liquid lines and one vapor return line are connected between the railcar and the tank truck. The transfer compressor and hydraulics on each transloader are powered by a diesel engine. The compressor pushes vapor collected from the tank car to the top of the railcar, which pushes liquid out of drop tubes in the railcar. Displaced vapors are all retained within this system (balanced vapor recovery, no displacement venting). The rail spur at the site can accommodate up to eight railcars at one time. The connectors to the railcar and tank truck are valved off until connected. At disconnection, the space between the valves is vented. Operators know that the railcar is empty when only vapor is being pushed through the liquid loading lines. This is usually evident from sight glasses on liquid line check valves. Emissions result from the diesel engines, leaks, and venting of the connectors upon disconnection. No, flares, heaters, chillers, dryers, or intermediate storage tanks are associated with the transloading process. The facility will primarily operate during the winter season when there is increased demand for propane and butane. 5. EQUIPMENT/ ACTIVITY IDENTIFICATION 5.a Butane Transloader 1. The compressor on Butane Transloader 1 is powered by the Butane Transloader 1 Engine. Specific equipment details are listed below: Make I Model: Serial Number: Manufactured: Transfer Rate: Custom "Unit 15" identifier found on the unit 2016 ~200 gallons per minute

5 Connection Points: (6) - Two liquid connections and one vapor connection to the railcar, two liquid connections and one vapor connection to the tank truck. Potential Leak Points: -8 valves in vapor service, 11 valves in liquid service, 1 compressor, 92 screwed connectors and flanges in vapor service, 82 connectors and flanges in liquid service, 1 pressure relief device in vapor service, and 4 pressure relief devices in liquid service. 5.b Butane Transloader 2 (new). The compressor on Butane Transloader 2 is powered by the Butane Transloader 2 Engine. Specific equipment details are listed below: Make I Model: Serial Number: Manufactured: Custom Unknown Unknown Transfer Rate: -200 gallons per minute Connection Points: (6) - Two liquid connections and one vapor connection to the railcar, two liquid connections and one vapor connection to the tank truck. Potential Leak Points: -8 valves in vapor service, 11 valves in liquid service, 1 compressor, 92 screwed connectors and flanges in vapor service, 82 connectors and flanges in liquid service, I pressure relief device in vapor service, and 4 pressure relief devices in liquid service. 5.c Propane Transloader 1. The compressor on Propane Transloader 1 is powered by the Propane Transloader 1 Engine. Specific equipment details are listed below: Make I Model: Serial Number: Manufactured: Custom To be determined To be determined Transfer Rate: gallons per minute Connection Points: (6) - Two liquid connections and one vapor connection to the railcar, two liquid connections and one vapor connection to the tank truck. Potential Leak Points: -8 valves in vapor service, 11 valves in liquid service, I compressor, 92 screwed connectors and flanges in vapor service, 82 connectors and flanges in liquid service, I pressure relief device in vapor service, and 4 pressure relief devices in liquid service. 5.d Propane Transloader 2. The compressor on Propane Trans loader 1 is powered by the Proopane Transloader l Engine. Specific equipment details are listed below: Make I Model: Custom Serial Number: To be determined Manufactured: To be determined Transfer Rate: gallons per minute Connection Points: (6) - Two liquid connections and one vapor connection to the railcar, two liquid connections and one vapor connection to the tank truck. Potential Leak Points: - 8 valves in vapor service, 11 valves in liquid service, I compressor, 92 screwed connectors and flanges in vapor service, 82 connectors and flanges in liquid service, 1 pressure relief device in vapor service and 4 pressure relief devices in liquid service. 5.e Butane Transloader I Engine. Specific equipment details are listed below: Make I Model: Serial Number: Manufactured: Fuel: Engine Power: Yanmar I 4TNV84T-ZDSADT October 19, 2010 Diesel 55.2 brake horsepower 2

6 Certification: EPA Interim Tier 4 Stack Description: - 2" diameter oriented vertically -6' above grade Federal Regulations: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ 5.f Butane Transloader 2 Engine (new). Specific equipment details are listed below: Make I Model: Serial Number: Deutz I D2011 L03I Manufactured: September 2012 Fuel: Diesel Engine Power: 46 brake horsepower Certification: EPA Interim Tier 4 Stack Description: - 2" diameter oriented vertically-6' above grade Federal Regulations: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ 5.g Propane Transloader 1 Engine. Specific equipment details are listed below: Make I Model: Yanmar I "3MTDA" Serial Number: To be determined Engine Family: EPA Family CYDXL2.00N4T Manufactured: To be determined Fuel: Diesel Engine Power: 57.5 brake horsepower (based on CARB Certification) Certification: EPA Interim Tier 4 Stack Description: - 2" diameter oriented vertically-6' above grade Federal Regulations: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ 5.h Propane Transloader 2 Engine. Specific equipment details are listed below: Make I Model: Yanmar I "3MTDA" Serial Number: To be determined Engine Family: EPA Family CYDXL2.00N4T Manufactured: To be determined Fuel: Diesel Engine Power: 57.5 brake horsepower (based on CARB Certification) Certification: EPA Interim Tier 4 Stack Description: - 2" diameter oriented vertically - 6' above grade Federal Regulations: 40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ 3

7 Teclmical Support Document 5.i Equipment/Activity Summary. ID No. I Generating Equipment/ Activity Butane Transloader I 2 Butane Transloader 2 3 Propane Transloader I 4 Propane Transloader 2 5 Butane Transloader I Engine 6 Butane Transloader 2 Engine 7 Propane Transloader 1 Engine 8 Propane Transloader 2 Engine #of Units I I I I I I 1 1 #of Control Measure/Equipment Units Balanced vapor recovery I Balanced vapor recovery I Balanced vapor recovery 1 Balanced vapor recovery 1 Ultra-low sulfur diesel, EPA Interim Tier 4 Certification Ultra-low sulfur diesel, EPA Interim Tier 4 Certification Ultra-low sulfur diesel, EPA Interim Tier 4 Certification Ultra-low sulfur diesel, EPA Interim Tier 4 Certification NIA NIA NIA NIA 6. EMISSIONS DETERMINATION 6.a Transloading. Potential emissions were estimated using the South Coast Air Quality Management District's "Guidelines for Fugitive Emissions Calculations (June 2003)." In this guidance, the District updated emissions factors that were identified in the EPA's "Protocol for Equipment Leak Emission Estimates (November 1995)". For purposes of determining emissions, equipment in contact with liquid butane or propane is considered to be in "light liquid" service and equipment in contact only with butane or propane vapor is in "vapor service". There are a variety of techniques for determining emissions from leaking components. In this case, SW CAA has determined that the use of an "average" emission factor for untested components and a "screening value range" emission factor for tested components provides a straightforward method of determining emissions. The "average" emission factor was determined using actual survey data from multiple facilities and based on the survey, a certain percentage of components at the facilities were found to be leaking and others were not. Using statistical methods, an average emission rate among all the components within the survey sample was determined and represents a probable leak rate for components that have not been tested. This would represent a base level for determining emissions from a facility that has not yet been built or for a facility that has not determined whether a specific component was leaking. Once a testing program has been established, then a "screening value range" emission factor can be used. Using similar survey data and a screening value - which is typically 500 ppm, 1,000 ppm, 10,000 ppm, or 100,000 ppm - a probable leak rate can be calculated for a screening value range. For example, assuming the screening value is 10,000 ppm, there would be two ranges, < I 0,000 ppm and 2'.: I 0,000 ppm, and using the actual leak rates determined during the survey, an emission factor for components leaking <10,000 ppm or 2'.: I 0,000 ppm can be determined. Based on leak-no leak determination or an actual leak concentration reading, a facility can determine which emission factor to use. In the case where a non-numeric method is being used, such as a soap solution, SWCAA assumes that if no leak is detected that the component could be leaking at less than the screening value and that if a leak is detected then it is leaking at a rate above the screening value. From an emissions standpoint, this means that only the presence or absence of a leak is necessary to determine which emission factor to use. Based on the above discussion, the following emission factors are used to determine fugitive emissions: 4

8 Teclmical Support Document Description Valves (includes flanges) in Vapor Service Valves (includes flanges) in Light Liquid Service Others (compressors, sightglasses, meters, etc.) in Vapor Service Fittings (connectors and flanges) in Vapor Service Fittings (connectors and flanges) in Light Liquid Service Pressure Relief Devices (PRVs) in Vapor Service Average Emission Factor (lb/hr)/unit l.4x x x lo x x x 10-2 Non-Leaker (<10,000 ppm) Emission Factor (lb/hr)/unit 2.9x x x io x l0-5 l.6x l x 10-5 Pressure Relief Devices (PRVs) in Light Liquid Service 2.2x x Applies to any component other than fittings, pump seals, or valves. Leaker (2:10,000 ppm) Emission Factor (lb/hr)/unit 5.1x x l x x 10-2 I.4x io- 2 5.l x!0-2 5.I x10-2 With the exception of the PRVs, all leaker/non-leaker emission factors came from Table IV-2b. PRV's nonleaker/leaker emission factors came from the emission factors for valves because no comparable emission factors was available in Table IV-2b. Average emission factors for all components came from the Terminals/Depots table on Page 6. To calculate potential fugitive leak emissions the total number of each component type was counted on one of the transloaders and the number multiplied by 1.25 to account for up to 25% more components on each transloader. This allows for minor configuration modifications (and the potential for miscounting). c omponent Count per T rans I oa d er Valves in Vapor Service 8 Valves in Light Liquid Service 11 Others (compressors, sight-glasses, meters, etc.) in Vapor Service 1 Fittings (connectors and flanges) in Vapor Service 92 Fittings (connectors and flanges) in Light Liquid Service 82 Pressure Relief Devices in Vapor Service 1 Pressure Relief Devices in Liquid Service 4 Based on the number of components and using the "average" emission factor, the emissions from the components on both transloaders for each product combined are calculated to be 3,231 lb/yr (1.62 tpy) based on 8,760 hours per year of service. 5

9 Connection I Disconnection During disconnection of the transfer connector valve assemblies from the railcars and tanker trucks, the internal volume between the valves on each end of the connection must be vented. There are two liquid connections and one vapor connection to each railcar and tanker truck. Railcars and tanker trucks have butane and propane load capacities of approximately 30,000 gallons and 8,000 gallons respectively. Therefore, four tanker trucks will be needed to unload each railcar. Each tanker truck could be connected/disconnected twice if the truck is disconnected to be weighted once prior to completion of loading. Potential emissions from disconnection were calculated from a total potential throughput of 200,000 barrels per year (8,400,000 gallons per year) for each product. This translates to unloading 280 railcars into 1,050 tanker trucks per year. It is assumed that there is one disconnection of each railcar before it is fully unloaded, and two disconnections of every truck before the railcar is fully unloaded. When a railcar is fully unloaded, it is not empty, but vapor has displaced the majority of the liquid in the liquid transfer lines. In this fully unloaded state, disconnection results in negligible butane emission. Disconnection emissions are ~ 100 times lower for butane and ~40 times lower for propane when the transfer lines are filled with vapor instead of liquid. The liquid transfer lines have a nominal diameter of 2". The liquid connections to the railcars have approximately 18" of connection between the isolation valves. Approximately 2.46 pounds of butane or 2.03 pounds of propane would be lost when these two liquid lines are decoupled from the railcar before the railcar is empty. The liquid connections to the tanker truck have approximately 3.5" of connection between the isolation valves. Approximately 0.48 pounds of butane or 0.39 pounds of propane would be lost when these two liquid lines are decoupled from the tanker truck before the railcar is empty. Based on these estimates an average of 1.57 pounds of butane or 1.30 pounds of propane will be emitted per truck loaded. Disconnecting Emissions Number of Butane Truck.loads = Butane Emissions per Truck.load= Butane Annual Emissions = Number of Propane Truck.loads = Propane Emissions per Truck.load = Propane Annual Emissions = 1, lbs/event 0.82 tons 1, lbs/event 0.68 tons The above emission factor per truck.load must be used to calculate annual emissions from the facility unless the number of truck and railcar disconnections is documented. If the number of truck and railcar disconnections is documented, the railcar and tanker truck disconnection factors (2.46 lbs/event and 0.48 lbs/event respectively for butane, and 2.03 lbs/event and 0.39 lbs/event respectively for propane) may be used. Propane/LPG may contain mercaptan odoronts that are Toxic Air Pollutants (e.g. methyl mercaptan or ethyl mercaptan), or hydrogen sulfide. Assuming that mercaptan concentrations could be as high as 50 ppmw and hydrogen sulfide could be as high as 185 ppmw (the maximum sulfur content allowed in commercial propane), the following emissions are possible: 6

10 Propane Sulfur Species Methyl Mercaptan Ethyl Mercaptan Hydrogen Su lfide ppmw* lb/yr * These values represent expected maximums - may not be actually present. Refer to Safety Data Sheet or technical data sheet for the specific product to determine actual concentrations. 6.b Butane Transloader I Engine. Potential annual emissions from the combustion of ultra-low sulfur di esel (<0.0015% sulfur by weight) were calculated with the assumption that the engine will operate at full load for up to 3,080 hours per year. The engine is capable of producing 55.2 horsepower at full load. Butane Transloader l Engine How s of Operation = 3,080 hours Power Output = 55.2 horsepower Diesel Density = pounds per gallon Fuel Sulfur Content = % by weight Fue l Consumption Rate = 3.18 gallons per hour Fuel Heat Content = MMBtu/gal (for use with GHG factors from 40 CFR 98) Annual Fuel Consumption = 9,783 gallons Emission Emission Emission Factor Factor Factor Emissions Emission Factor Pollutant lb/hp-hr lb/hr lb/ 1,000 gal tov Source NOx CARB CERT co CARB CERT voe AP-42 Table ( 10/96) SOx as S Mass Balance PM/PM10/PM2.s CARB CERT C02e C02e ' Greenhouse Gases kg/mmbtu GWP lb/mmbtu lb/gallon tpy, C02e C I CFR 98 CH CFR 98 N CFR 98 Total GHG - C02e Em issions must be calculated using the hourly emission factors identified above unless new emission factors are developed through source testing. 7

11 6.c Butane Transloader 2 Engine. Potential annual emissions from the combustion of ultra-low sulfur diesel ( <0.0015% sulfur by weight) were calculated with the assumption that the engine will operate at full load for up to 3,080 hours per year. The engine is capable of producing 46.2 horsepower at full load. Butane Transloader 2 Engine Hours of Operation= 3,080 hours Power Output = 46.2 horsepower Diesel Density = pounds per gallon Fuel Sulfur Content = % by weight Fuel Consumption Rate = gallons per hour (43.5 mm /stroke) Fuel Heat Content = Mlvffitu/gal (for use with GHG factors from 40 CFR 98) Annual Fuel Consumption = 8,932 gallons Emission Emission Emission Factor Factor Factor Emissions Emission Factor Pollutant lb/hp-hr lb/hr lb/1,000 gal tov Source NOx EPA Family Test Data co EPA Family Test Data voe AP-42 Table (10/96) SOx as S EPA Family Test Data PMIPMJO/PM2.s EPA Family Test Data C02e C02e Greenhouse Gases kg!mlvibtu GWP lb/mmbtu lb/gallon tpy, C02e C CFR 98 CH CFR 98 N CFR 98 Total GHG - C02e Emissions must be calculated using the hourly emission factors identified above unless new emission factors are developed through source testing. 8

12 6.d Proane Transloader 1 Engine and Transloader 2 Engine. Potential annual emissions from the combustion of ultralow sulfur diesel (<0.0015% sulfur by weight) were calculated with the assumption that each engine will operate at full load for up to 3,080 hours per year. Each engine is capable of producing 55.2 horsepower at full load. Propane Trans loader Engines (each) Hours of Operation = 3,080 hours Pow er Output = 57.5 horsepower (CARE Certification) Diesel Density = pounds per gallon Fuel Sulfur Content = % by weight ~ Fuel Conswnption Rate = 3.32 gallons per hour Fuel Heat Content = MMBtu/gal (for use with GHG factors from 40 CFR 98) Annual Fuel Consumption= 10,215 gallons Emission Emission Emission Factor Factor Factor Emissions Emission Factor Pollutant lb/hp-hr lb/hr lb/ 1,000 gal tnv Source NOx CARE CERT co CARE CERT voe AP-42 Table (10/96) SOx as S Mass Balance PM/PM 10/PM2.s CARE CERT C02e C02e Greenhouse Gases kg/mmbtu GWP lb/mmbtu lb/gallon tpy, C02e C l CFR 98 CH CFR 98 NzO CFR 98 Total GHG - C02e Emissions must be calculated using the hourly emission factors identified above unless new emission factors are developed through source testing. 6.e Facilitywide Potential Emissions CPTE) Summary. Pollutant Nitrogen oxides Carbon monoxide Volatile organic compounds Sulfur oxides as sulfur dioxide Particulate matter PM10 PM2.s Toxic Air Pollutants Hazardous Air Pollutants C02e Ethyl mercaptan or methyl mercaptan Hydrogen sulfide Annual Emissions (tpy)

13 Air Discharge Pem1it Application CL REGULATIONS AND EMISSION STANDARDS Regulations that have been used to evaluate the acceptability of the proposed facility and establish emission limits and control requirements include, but are not limited to, the regulations, codes, or requirements listed below. 7.a Title 40 Code of Federal Regulations ( 40 CFR) Part et seq. "Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines" requires that new diesel engines meet specific emission standards at the point of manufacture and during operation. In addition, maximum fuel sulfur contents are specified and minimum maintenance standards are established. The transloader engines are affected sources. For new non-emergency engines, the following is required: (1) Owners or operators must comply with the emission standards for new nonroad compression ignition engines as specified in , for all pollutants. New non-emergency engines must meet the same standards as nonroad engines for the same size and model year found in 40 CFR 89 or 40 CFR (40 CFR (b)] (2) Owners or operators must operate and maintain each stationary CI internal combustion engine and control device according to the manufacturer's written instructions. In addition, owners and operators may only change those settings that are permitted by the manufacturer; and (40 CFR l(a)] (3) Beginning October 1, 2010, owners and operators must use diesel fuel with a sulfur content that does not exceed 15 ppm. (40 CFR (b)] 7.b 40 CFR et seq. (Subpart ZZZZ) "National Emissions Standards for Hazardous Air Pollutants CNESHAP) for Stationary Reciprocating Internal Combustion Engines" establishes national emission limitations and operating limitations for HAP emitted from stationary reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions. The transloader engines are affected sources under this regulation. A stationary rice located at an area source of HAP emissions is new if construction was commenced on or after June 12, The Transloader engines are "new" for the purposes of this rule because they were (or will be) built after June 12, A new stationary RICE at an area source must comply with Subpart ZZZZ by meeting the requirements of 40 CFR 60 Subpart IIII for compression ignition engines or 40 CFR 60 Subpart JJJJ for spark ignition engines. The Transloader engines are new diesel engines at an area HAP source, therefore compliance with 40 CFR 60 Subpart IIII constitutes compliance with 40 CFR 63 Subpart ZZZZ. 7.c 40 CFR 68 "Chemical Accident Prevention Provisions" requires affected stationary sources to compile and submit a risk management plan, as provided in Sections to Applicability is determined by the type and quantity of material at the facility. This facility is subject to this regulation because more than 10,000 pounds of butane or propane will be present at one time at the facility. A facility representative indicated that the original plan was submitted May 31, d Revised Code of Washington CRCW) empowers any activated air pollution control authority to prepare and develop a comprehensive plan or plans for the prevention, abatement and control of air pollution within its jurisdiction. An air pollution control authority may issue such orders as may be necessary to effectuate the purposes of the Washington Clean Air Act [RCW 70.94] and enforce the same by all appropriate administrative and judicial proceedings subject to the rights of appeal as provided in Chapter 62, Laws of 1970 ex. sess. 7.e RCW provides for the inclusion of conditions of operation as are reasonably necessary to assure the maintenance of compliance with the applicable ordinances, resolutions, rules and regulations when issuing an Air Discharge Permit for installation and establishment of an air contaminant source. 7.f Washington Administrative Code (WAC) "Controls for New Sources of Toxic Air Pollutants" (as in effect February 14, 1994) requires Best Available Control Technology for toxic air pollutants (T-BACT), identification and quantification of emissions of toxic air pollutants and demonstration of protection of human health and safety. IO

14 7.g WAC "Ambient Air Quality Standards" establishes ambient air quality standards for PM10, PM2.s, lead, sulfur dioxide, nitrogen dioxide, ozone, and carbon monoxide in the ambient air, which shall not be exceeded. 7.h SW CAA "General Standards for Maximum Emissions" requires all new and existing sources and emission units to meet certain performance standards with respect to Reasonably Available Control Technology (RACT), visible emissions, fallout, fugitive emissions, odors, emissions detrimental to persons or property, sulfur dioxide, concealment and masking, and fugitive dust. 7.i SWCAA (1) "Visible Emissions" requires that no emission of an air contaminant from any emissions unit shall exceed twenty percent opacity for more than three minutes in any one hour at the emission point, or within a reasonable distance of the emission point. 7.j SW CAA (2) "Fallout" requires that no emission of particulate matter from any source shall be deposited beyond the property under direct control of the owner(s) or operator(s) of the source in sufficient quantity to interfere unreasonably with the use and enjoyment of the property upon which the material is deposited. 7.k SWCAA (3) "Fugitive Emissions" requires that reasonable precautions be taken to prevent the fugitive release of air contaminants to the atmosphere. 7.1 SWCAA (4) "Odors" requires that any person who shall cause or allow the generation of any odor from any source, which may unreasonably interfere with any other property owner's use and enjoyment of their property use recognized good practices and procedures to reduce these odors to a reasonable minimum. 7.m SW CAA (5) "Emissions Detrimental to Persons or Property" prohibits the emission of any air contaminant from any "source" if it is detrimental to the health, safety, or welfare of any person, or causes damage to property or business. Some of the coating materials utilized at this facility contain compounds that are not T APs under WAC , however can be hannful if inhaled. If no filtration is used, the ambient impact could exceed the relevant worker health thresholds for these compounds. 7.n SW CAA (8) "Fugitive Dust Sources" requires that reasonable precautions be taken to prevent fugitive dust from becoming airborne, and minimize emissions. 7.o SW CAA "Emission Standards for Combustion and Incineration Units" requires that all provisions of SW CAA be met and that no person shall cause or pennit the emission of particulate material from any combustion or incineration unit in excess of 0.23 grams per dry cubic meter (0.1 grains per dry standard cubic foot) of exhaust gas at standard conditions. 7.p SWCAA "New Source Review" requires that an Air Discharge Permit Application be filed with SW CAA, and an Air Discharge Pennit be issued by SW CAA, prior to establishment of the new source, emission unit, or modification. 7.q SWCAA "Requirements for Sources in a Maintenance Plan Area" requires that no approval to construct or alter an air contaminant source shall be granted unless it is evidenced that: (1) The equipment or technology is designed and will be installed to operate without causing a violation of the applicable emission standards; (2) Emissions will be minimized to the extent that the new source will not exceed emission levels or other requirements provided in the maintenance plan; (3) Best Available Control Technology will be employed for all air contaminants to be emitted by the proposed equipment; (4) The proposed equipment will not cause any ambient air quality standard to be exceeded; and (5) If the proposed equipment or facility will emit any toxic air pollutant regulated under WAC , the proposed equipment and control measures will meet all the requirements of that Chapter. 11

15 8. RACT/BACT/BART/LAER/PSD/CAM DETERMINATIONS The proposed equipment and control systems incorporate Best Available Control Technology (BACT) for the types and amounts of air contaminants emitted by the processes as described below: 8.a BACT Determination - Fugitive Emissions. Potential fugitive leaks from this facility are relatively small, however the effort to annually check for leaks should be relatively small, providing a cost-effective method of controlling fugitive leaks. SW CAA has determined that implementation of a leak detection and repair program utilizing annual leak detection meets the requirements of BACT for the control of fugitive emissions from this facility. 8.b BACT Determination - Transloader Engines. One option to reduce emissions from operating the hydraulic system is to use alternative fuels (other than diesel) to drive the process. Electricity is an alternative fuel for this process. The applicant indicated that replacing the existing engines (the transloaders are already built with the incorporated diesel engines), would cost approximately $80,000 each for the motor and $20,000 for the electrical upgrades to the site. Offsetting this would be the reduction in maintenance and fuel costs. The reduction in fuel costs could be on the order of $11,000 per year per engine based on 3,080 hours of operation per year at full load, each engine burning 9, 783 gallons of fuel per year, a diesel cost of $2.30 per gallon and an electrical cost of $0.08 per kw-hr. Using an 8% cost of capital and a 5 year equipment life (15,400 hour of operation), the cost-effectiveness of replacing the diesel engines at this point in over $10,000 per ton of pollutant prevented. The certified "useful life" of these engines is 5,000-8,000 hours. The applicant has informed SWCAA that based on the fuel consumption records for a similar facility, the average engine load is less than 20% of maximum load (facilities operating 24 hours per day burned no more than 400 gallons of fuel per month while at full load the engine would burn approximately 2,300 gallons per month). Based on this analysis, replacement of the engines with electric motors will not be a cost-effective method of reducing emissions. Available control measures for new diesel engines include engine design, the use of ultra-low sulfur fuel and addon control equipment such as selective catalytic reduction (SCR) units and oxidation catalysts. Because emission rates from these engines are relatively low (the engines meet EPA's Interim Tier 4 emission standards) neither SCR for NOx emissions, nor an oxidation catalyst for CO, VOC and organic PM emissions would be cost-effective. The use of modem diesel-fired engine design meeting the relevant EPA emission standard for the new engines as applicable, the use of ultra-low sulfur diesel fuel (:'.S % sulfur by weight), limitation of visible emissions to 5% opacity or less, and limitation of lifetime engine operation to 3,080 hours per year has been detem1ined to meet the requirements of BACT for the types and quantities of air contaminants emitted. The use of ultra-low sulfur fuel is also required by 40 CFR 60 Subpart IIII for "new" engines. 8.c Prevention of Significant Deterioration CPSD) Applicability Determination. This permitting action will not result in a potential increase in emissions equal to or greater than the PSD thresholds. Therefore, PSD review is not applicable to this action. 8.d Compliance Assurance Monitoring (CAM) Applicability Determination. CAM is not applicable to any emission unit at this facility because it is not a major source and is not required to obtain a Part 70 permit. 9. AMBIENT IMPACT ANALYSIS Emissions of criteria air pollutants or precursors (nitrogen oxides, carbon monoxide, sulfur oxides, particulate matter, and volatile organic compounds) are all at or below 6 tons per year each. At these emission rates, no significant adverse ambient air quality impact is anticipated. Incremental increases in toxic air pollutant emissions will not exceed the applicable Small 12

16 Quantity Emission Rates (SQER) listed in WAC (in effect February 14, 1994); therefore, toxic impacts are presumed to be below regulatory significance. Conclusions 9.a Operation of the transloading facility as proposed in ADP Application CL-3039 will not cause the ambient air quality requirements of Title 40 Code of Federal Regulations (CFR) Part 50 "National Primary and Secondary Ambient Air Quality Standards" to be violated. 9.b The transloading facility proposed in ADP Application CL-3039, can be operated without causing a violation of the applicable emission standards, which include the limits established under SWCAA "General Standards for Maximum Emissions." 9.c Operation of the transloading facility as proposed in ADP application CL-3039 in accordance with the Air Discharge Permit will not cause the requirements of WAC "Controls for New Sources of Toxic Air Pollutants," (in effect February 14, 1994) or WAC "Ambient Air Quality Standards" to be violated. 10. DISCUSSION OF APPROVAL CONDITIONS SWCAA has made a determination to issue Air Discharge Permit in response to ADP Application CL Air Discharge Permit contains approval requirements deemed necessary to assure compliance with applicable regulations and emission standards as discussed below. 1 O.a General Basis. Approval conditions for equipment affected by this permitting action incorporate the operating schemes proposed by the permittee in the Air Discharge Permit application. 1 O.b Emission Limits. Emission limits were established equivalent to the emission potentials identified in Section 6. Engine emissions are based on 3,080 hours of operation per year, which is the maximum operation identified by the applicant. 1 O.c Operating Limits and Requirements. The fugitive VOC emission potential is relatively small, so leak detection was required only annually. Consistent with USEPA rules for other industries, leaking components must be repaired within 15 days. Because this facility is not a continuous process, no delay provisions related to process shutdown were included. 1 O.d Monitoring and Recordkeeoine:. Sufficient monitoring and recordkeeping was established to document compliance with the annual emission limits and provide for general requirements (e.g. excess emission reporting, annual emission inventory submission). In addition, engine maintenance activities and leak detection events must be logged for each occurrence. Engine maintenance logs can be used to assure that the engines are being operated in accordance with 40 CFR 60 Subpart IIII. This record also allows the facility and SWCAA inspectors to assure the equipment is being properly maintained and investigate any complaints or excess emissions incidents. 10.e Emission Monitoring and Testing Requirements. See Section 12. I O.f Reporting. The pennit requires reporting of the annual air emissions inventory, and reporting of the data necessary to develop the inventory. Excess emissions must be reported immediately in order to qualify for relief from monetary penalty in accordance with SWCAA In addition, prompt reporting was required because it allows for accurate investigation into the cause of the event and prevention of similar future incidents. 13

17 11. ST ART-UP AND SHUTDOWN/ ALTERNATIVE OPERA TING SCENARIOS/POLLUTION PREVENTION I I.a Start-up and Shutdown Provisions. Pursuant to SWCAA "Start-up and Shutdown," technology based emission standards and control technology determinations shall take into consideration the physical and operational ability of a source to comply with the applicable standards during start-up or shutdown. Where it is determined that a source is not capable of achieving continuous compliance with an emission standard during start-up or shutdown, SWCAA shall include appropriate emission limitations, operating parameters, or other criteria to regulate performance of the source during start-up or shutdown. This source is capable of achieving continuous compliance with all applicable requirements; therefore, no startup or shutdown provisions were included in the Air Discharge Permit. 11.b Alternate Operating Scenarios. SWCAA conducted a review of alternate operating scenarios applicable to equipment affected by this permitting action. Neither SWCAA nor the permittee identified or proposed any applicable alternate operating scenarios. Therefore, none were included in the approval conditions. 11.c Pollution Prevention Measures. SWCAA conducted a review of possible pollution prevention measures for the facility. No pollution prevention measures other than the control measures identified in the permit were identified by either the permittee or SWCAA. Therefore, none were included in the approval conditions. 12. EMISSION MONITORING AND TESTING Potential emissions from the diesel engines were too small to warrant periodic emission testing. A relatively simple leak detection and repair program was required because the relatively small effort is justified by the potential emissions prevented. 13. FACILITY HISTORY This facility was originally permitted in early 2017 as a butane transloading facility. Later in 2017 the facility proposed to add the ability to transload propane. In 2018 the second butane transloader Tristar received was not the one originally permitted, so CL-3039 was submitted to modify the permit to accommodate the different transloader. 13.a Previous Approvals/Permits/Orders. The following approvals, Permits, and Orders have been issued for this facility: Permit I Application Order# # Date Issued Description CL-3004 May 24, Approval of butane transloading facility utilizing two 2017 transloading skids CL-3027 January 3, Approval of two additional transloaders to be used for 2018 propane transloading. Bold font indicates that the Order or Air Discharge Permit will have been superceded or will no longer be in effect when Air Discharge Permit is issued. 14. PUBLIC INVOLVEMENT 14.a Public Notice for. Public notice for Air Discharge Permit Application CL-3039 was published on the SWCAA internet website for a minimum of 15 days beginning on February 27,

18 14.b Public/Applicant Comment for. SWCAA did not receive formal comments, a comment period request, or any other inquiry from the public or the applicant regarding this Air Discharge Permit application. Therefore, no public comment period was provided for this permitting action. 14.c State Environmental Policy Act. This project is exempt from SEPA requirements pursuant to WAC (3) since it only involves repair, remodeling, maintenance, or minor alteration of existing structures, equipment or facilities, and does not involve material expansions or changes in use. SWCAA issued a detennination that the project is exempt from SEPA review on March 15, 2018 (Determination of SEPA Exempt - SWCAA ). 15