Facility Name: Chevron Products Company Doraville Terminal City: Doraville County: DeKalb AIRS #: 04-13-089-00100 Application #: 40411 Date SIP Application Received: September 28, 2015 Date Title V Application Received: September 25, 2015 Permit No: 5171-089-0100-V-03-1 Program Review Engineers Review Managers SSPP Tracey Hiltunen Hamid Yavari SSCP Neal Ritchey James Eason ISMP Bob Scott Daniel McCain TOXICS n/a n/a Permitting Program Manager Eric Cornwell Introduction This narrative is being provided to assist the reader in understanding the content of the referenced SIP permit to construct and draft operating permit amendment. Complex issues and unusual items are explained in simpler terms and/or greater detail than is sometimes possible in the actual permit. This permit is being issued pursuant to: (1) Sections 391-3-1-.03(1) and 391-3-1-.03(10) of the Georgia Rules for Air Quality Control, (2) Part 70 of Chapter I of Title 40 of the Code of Federal Regulations, and (3) Title V of the Clean Air Act Amendments of 1990. The following narrative is designed to accompany the draft permit and is presented in the same general order as the permit. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the permit in response to comments received during the public comment period and EPA review process will be described in an addendum to this narrative. Chevron Products Company Doraville Terminal, TV-40411 Page 1 of 6
I. Facility Description A. Existing Permits Table 1 below lists the current Title V permit, and all administrative amendments, minor and significant modifications to that permit, and 502(b)(10) attachments. Comments are listed in Table 2 below. Table 1: Current Title V Permit and Amendments Permit/Amendment Number Date of Issuance Comments Yes No 5171-089-0100-V-03-0 August 22, 2011 x Table 2: Comments on Specific Permits Permit Number 5171-089-0100-V-03-0 Title V renewal permit. Comments B. Regulatory Status 1. PSD/NSR/RACT PSD regulations name petroleum storage facilities with total capacities of greater than 300,000 barrels as one of the 28 named categories of sources whose annual emissions make them a PSD major source if they exceed 100 tons. Since Chevron Doraville Terminal is above this capacity threshold, potential annual emissions for a pollutant emitted by this facility would only have to exceed 100 tons before it would be considered a major source for PSD purposes. Potential annual emissions of VOCs from this source have been estimated to be over 100 tons. This facility would be considered a major source under PSD regulations; however, this facility is located in DeKalb County which is part of the metro Atlanta ozone non-attainment area. Therefore, the non-attainment area (NAA) portion of the NSR regulations would be applicable instead of PSD, since VOCs are the major pollutant emitted and one of the two pollutants regulated for ozone non-attainment areas (the other regulated pollutant is nitrogen oxides). Chevron Doraville Terminal would be considered a major source for NAA NSR purposes since its potential VOC emissions exceed 25 tons per year in an ozone non-attainment area classified as serious by U.S. EPA. The nitrogen oxides emissions from the facility, however, are less than 25 tons per year. Chevron Products Company Doraville Terminal, TV-40411 Page 2 of 6
2. Title V Major Source Status by Table 3: Title V Major Source Status If emitted, what is the facility s Title V status for the? Is the Major Source Major Source Status Requesting SM Non-Major Source Status Emitted? Status PM n/a PM 10 n/a PM 2.5 n/a SO 2 n/a VOC Yes NO x n/a CO n/a TRS n/a H 2 S n/a Individual Yes HAP Total HAPs Yes Total GHGs n/a II. Proposed Modification A. Description of Modification Chevron Products Company submitted Application No. 40411 on September 25, 2015 for the conversion of an existing fixed roof tank T012 holding diesel into an internal floating roof tank holding gasoline at the Doraville terminal. Tank T012 was previously listed as an insignificant unit in the Insignificant Activities Checklist in Attachment B of the permit. With this modification, Tank T012 is permitted as a significant emission unit, subject to 40 CFR 60 - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984, and listed in Table 3.3.1 of the permit amendment and the Insignificant Activities Checklist is updated to remove this tank. The facility is a Title V major source operating under Air Quality Permit No. 5171-089-0100-V-03-0 issued August 22, 2011. The total products throughput through the loading rack is not expected to change and no changes are made to the loading rack. B. Emissions Change VOC is the main pollutant of concern. VOC emissions are increased due to the change from diesel to gasoline. Gasoline has a higher vapor pressure than diesel. VOC emissions from the modified tank include standing and working tank losses. Emission calculations were submitted by the facility and reviewed by the Division. The table below summarizes the emissions change due to the modification. Note that the Division assumed the net actual emissions increase to be equal to the net potential emissions increase. Chevron Products Company Doraville Terminal, TV-40411 Page 3 of 6
Table 4: Emissions Change Due to Modification Is the Emitted? Net Actual Emissions Increase (Decrease) (tpy) Net Potential Emissions Increase (Decrease) (tpy) PM No - - PM 10 No - - PM 2.5 No - - SO 2 No - - VOC Yes 4.37 4.37 NO x No - - CO No - - TRS No - - H 2 S No - - Individual Yes 0.268 0.268 HAP Total HAPs Yes 1.09 1.09 Total GHGs No - - C. PSD/NSR Applicability This modification is not a major modification as defined by PSD/NSR. The table above shows that the net potential increase in VOC emissions is less than the non-attainment area new source review emission rate for VOC. III. Facility Wide Requirements A. Emission and Operating Caps: There are no emission limits or operating caps associated with this modification. B. Applicable Rules and Regulations 40 CFR 60 Subpart Kb is a federal standard of performance for petroleum storage vessels constructed, reconstructed, or modified after July 23, 1984 that have storage capacities of greater than 40 cubic meters (about 10,000 gallons). Since Tank T012 is subject 40 CFR 60 Subpart Kb, it is also subject to the applicable provisions of 40 CFR 60 Subpart A General Provisions. C. Compliance Status The facility is operating in compliance with the rules and regulations. Chevron Products Company Doraville Terminal, TV-40411 Page 4 of 6
D. Operational Flexibility The facility has not requested any operational flexibility. E. Permit Conditions Condition 2.2.3 has been modified to include 40 CFR 60 Subpart Kb. Since Tank T012 is subject 40 CFR 60 Subpart Kb, it is also subject to the applicable provisions of 40 CFR 60 Subpart A General Provisions. IV. Regulated Equipment Requirements A. Brief Process Description Chevron Products Company Doraville Terminal receives petroleum products by pipeline and ships product by tank trucks to retailers and bulk plants. The facility currently has a truck loading rack with 4 product delivery bays, 2 vapor recovery units (VRU s), and 7 permitted storage tanks. This modification is for the conversion of an existing fixed roof storage tank T012 into an internal floating roof tank. B. Equipment List for the Process Emission Units Specific Limitations/Requirements Air Pollution Control Devices ID No. Description Applicable Corresponding Permit Requirements/Standards Conditions ID No. Description T012 Tank No. 12 (Internal Floating Roof Tank) N/A Internal Floating Roof 391-3-1-.02(2)(bb) 391-3-1-.02(2)(a)(3) 40 CFR 60 Subpart Kb 40 CFR 63 Subpart BBBBBB 2.2.3, 3.3.2, 3.3.5, 3.3.6, 3.4.1, 3.4.2, 5.2.12, 5.2.13, 5.2.14, 6.2.11, 6.2.12, 6.2.13, 6.2.14, 6.2.15 * Generally applicable requirements contained in this permit may also apply to emission units listed above. The lists of applicable requirements/standards and corresponding permit conditions are intended as a compliance tool and may not be definitive. C. Equipment & Rule Applicability Emission and Operating Caps There are no emission limits or operating caps associated with this modification. Applicable Rules and Regulations - 40 CFR 60 Subpart Kb is a federal standard of performance for petroleum storage vessels constructed, reconstructed, or modified after July 23, 1984 that have storage capacities of greater than 40 cubic meters (about 10,000 gallons). Tank T012 is subject to this rule and shall comply with the requirements for internal floating roof tanks. D. Compliance Status The facility is operating in compliance with the rules and regulations. Chevron Products Company Doraville Terminal, TV-40411 Page 5 of 6
E. Operational Flexibility The facility has not requested any operational flexibility. F. Permit Conditions New Condition 3.3.6 requires Tank T012 to comply with the applicable requirements of 40 CFR 60 Subpart Kb. V. Testing Requirements (with Associated Record Keeping and Reporting) New Condition 4.1.4 is a standard template condition requiring the facility to submit performance test results to the US EPA's Central Data Exchange (CDX) for any applicable NSPS or NEHAP containing electronic data reporting requirements. VI. Monitoring Requirements (with Associated Record Keeping and Reporting) New Conditions 5.2.12, 5.2.13, and 5.2.14 contain the applicable monitoring requirements for 40 CFR 60 Subpart Kb. In accordance with 40 CFR 60.116b, the facility is required to monitor the maximum true vapor pressure for product in Tank T012. Tank T012 will be inspected on a routine basis (each year or once each 10 years) to ensure that all equipment needed to contain VOL emissions is operating as designed or specified by the regulation. VII. Other Record Keeping and Reporting Requirements Template Conditions 6.1.3 and 6.1.4 were updated in September 2011 to allow ~60 days to submit periodic reports. Alternative reporting deadlines are allowed per 40 CFR 70.6, 40 CFR 60.19(f) and 40 CFR 63.10(a). Conditions 6.1.3 and 6.1.4 have been modified to include the alternative reporting deadlines. New Conditions 6.2.11, 6.2.12, 6.2.13, 6.2.14, and 6.2.15 contain the applicable recordkeeping and reporting requirements for 40 CFR 60 Subpart Kb. The facility shall keep records of dimensions, capacity, and volatile organic liquid (VOL) stored in Tank T012. The facility shall maintain records of tank inspections and submit notifications for any failures as required. Chevron Products Company Doraville Terminal, TV-40411 Page 6 of 6
Addendum to Narrative The 30-day public review started on December 17, 2015 and ended on January 18, 2016. Comments were not received by the Division. Chevron Products Company Doraville Terminal, TV-40411 Addendum Page 1 of 1