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Permit 87923

Attachment B

Page 10

Special ConditionsPermit Number 87923Emission Standards

This permit authorizes emissions only from those points listed in the attached table entitled “Emission Sources - Maximum Allowable Emission Rates,” and the facilities covered by this permit are authorized to emit subject to the emission rate limits on that table and other operating requirements specified in the Special Conditions.

Non-fugitive emissions from relief valves, safety valves, or rupture discs of gases containing volatile organic compounds (VOC) at a concentration of greater than 1 percent are not authorized by this permit unless authorized on the MAERT. Any releases directly to atmosphere from relief valves, safety valves, or rupture discs of gases containing VOC at a concentration greater than 1 weight percent are not consistent with good practice for minimizing emissions.

Federal Program Requirements

These facilities shall comply with all applicable requirements of the U.S. Environmental Protection Agency (EPA) regulations on Standards of Performance for New Stationary Sources promulgated in Title 40 Code of Federal Regulations Part 60 (40 CFR Part 60):

Subpart A, General Provisions.

Subpart K, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978

Subpart Ka, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984

Subpart Kb, 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.

These facilities shall comply with all applicable requirements of the U.S. Environmental Protection Agency (EPA) regulations on National Emission Standards for Hazardous Air Pollutants for Source Categories in 40 CFR Part 63: (TBD)

Subpart A, General Provisions.

Subpart DD, National Emission Standards for Hazardous Air Pollutants for Source Categories.

Operational Limits

Storage tank: (TBD)

Storage tank throughput shall be limited to the following:

EPN / FIN: Tank ID

Service / Multi- purpose

Fill / Withdrawal rate (gal/hr)

Annual Throughput (gal/yr)

Raw material storage tank

01-T-12

Raw Material Tank

3,600

379,600

01-T-15

Raw Material Tank

3,600

468,000

01-T-50

Raw Material Tank

3,600

405,600

01-T-59

Raw Material Tank

3,600

1,095,000

Wastewater storage tanks (WWTS)

VLSVCU / 05-T-4A*

WWTS, DWIS

21,000

84,000

VLSVCU / 05-T-4B*

WWTS, DWIS

21,000

84,000

VLSVCU / 05-T-4C *

WWTS, DWIS

23,000

92,000

VLSVCU / 05-T-4D*

WWTS, DWIS

4,625

18,500

VLSVCU / 05-T-4E*

WWTS, DWIS

4,625

18,500

VLSVCU / T574*

WWTS, RFO, EOTS

20,305

121,830

VLSVCU / T575*

WWTS, RFO, EOTS

20,305

121,830

VLSVCU / T530*

WWTS

420,000

76,056,685

VLSVCU / T532*

WWTS

420,000

76,056,685

VLSVCU / T572*

WWTS

30,030

252,000

VLSVCU / T573*

WWTS

30,030

252,000

VLSVCU / T584*

WWTS, DWIS

88,200

76,056,685

VLSVCU / T585*

WWTS, DWIS

88,200

76,056,685

VLSVCU / T590*

WWTS

88,200

76,056,685

VLSVCU / T591*

WWTS, DWIS, RFO

88,200

76,056,685

VLSVCU / T51*

WWTS, DWIS

11,700

70,200

VLSVCU / T52*

WWTS, DWIS

12,000

72,000

VLSVCU / T53*

WWTS, DWIS

10,100

60,600

VLSVCU / T54*

WWTS, DWIS

10,400

62,400

VLSVCU / T55*

WWTS, DWIS

10,400

62,400

VLSVCU / EB-1*

WWTS

420,000

76,056,685

VLSVCU / T571*

WWTS

420,000

76,056,685

Residual Fuel Oil (RFO)/Emulsified Oil Treatment System (EOTS) Storage Tanks

S-1 / T563**

RFO

30,000

25,000,000

S-1 / T567**

RFO

30,000

25,000,000

VLSVCU / T21*

RFO, EOTS, DWIS

19,990

1,000,000

VLSVCU / T22*

RFO, EOTS, DWIS

19,900

1,000,000

VLSVCU / T574*

RFO, EOTS, WWTS

20,305

487,320

VLSVCU / T575*

RFO, EOTS, WWTS

20,305

487,320

VLSVCU / T591*

RFO, WWTS, DWIS

30,000

3,050,208

Deepwell Injection Wastewater Storage Tanks (DWIS)

VLSVCU / T51*

DWIS, WWTS

11,700

421,200

VLSVCU / T52*

DWIS, WWTS

12,000

432,000

VLSVCU / T53*

DWIS, WWTS

10,100

363,600

VLSVCU / T54*

DWIS, WWTS

10,400

374,400

VLSVCU / T55*

DWIS, WWTS

10,400

374,400

VLSVCU / T583*

DWIS

30,000

12,000,000

VLSVCU / T584*

DWIS, WWTS

30,000

12,000,000

VLSVCU / T585*

DWIS, WWTS

30,000

12,000,000

VLSVCU / T591*

DWIS, WWTS, RFO

30,000

12,000,000

VLSVCU / T589*

DWIS

30,000

12,000,000

VLSVCU / T21*

DWIS, RFO, EOTS

19,990

719,640

VLSVCU / T22*

DWIS, RFO, EOTS

19,900

716,400

VLSVCU / 05-T-4A*

DWIS, WWTS

21,000

63,000

VLSVCU / 05-T-4B*

DWIS, WWTS

21,000

63,000

VLSVCU / 05-T-4C*

DWIS, WWTS

23,000

69,000

VLSVCU / 05-T-4D*

DWIS, WWTS

4,625

13,875

VLSVCU / 05-T-4E*

DWIS, WWTS

4,625

13,875

VLSVCU / 05-T-1B*

DWIS

30,000

12,000,000

VLSVCU / 05-T-9A*

DWIS

24,000

12,000,000

VLSVCU / 05-T-9B*

DWIS

21,000

12,000,000

VLSVCU / 05-T-5*

DWIS

30,000

12,000,000

VLSVCU / 05-T-8*

DWIS

20,305

12,000,000

*Shall be controlled with a Vapor Combustor (EPN: VLSVCU) with 99% efficiency.

**Shall be routed to the scrubber, EPN S-1.

The permit holder shall maintain records of tank throughput on a monthly basis, and the annual throughput shall be calculated on a rolling 12- month basis for each tank.

Except for labels, logos, etc. not to exceed 15 percent of the tank total surface area, uninsulated tank exterior surfaces exposed to the sun shall be white or unpainted aluminum. Storage tanks must be equipped with permanent submerged fill pipes. Tank 05-T-8 shall be painted white on or before 24 months from the date of issuance of this permit.

Service in the storage tanks operating under this permit is limited to storage of wastewater and chemicals appearing on Attachment B. Storage of other chemicals is prohibited unless prior approval for such storage is obtained from the Texas Commission on Environmental Quality (TCEQ) Executive Director by either 30 TAC §106 (Permit by Rule) or 30 TAC §116 (permit amendment), or as prescribed in the Chemical Flexibility Special Condition No. 24.

Prior approval from the TCEQ is not required in situations where storage of a new chemical is authorized by a Permit by Rule (PBR) which does not specify registration with a PI-7. In these situations, the permit holder shall document the change of service pursuant to 30 TAC §106.8(c) and retain the record on-site. (TBD)

Deep Well Injection System Filter Bins: (TBD)

The following maximum operating rates apply:

EPN

Source ID / Service

Rate (gal/hr)

05-F-1AH

Filter Bin

6,000

05-F-1BH

Filter Bin

6,000

05-F-2H

Filter Bin

6,000

05-F-3H

Filter Bin

6,000

05-F-4H

Filter Bin

6,000

Operations for each Deepwell Injection System Filter Bin shall be limited to 4,380 hrs/yr. The permit holder shall maintain records of fill/withdrawal rate and hours of usage. The annual operating time shall be calculated on a rolling 12-month basis.

Filter bins shall be covered when not in use.

Truck Loading: (TBD)

The following maximum loading rates apply:

EPN

Source ID

Hourly Rate (gal/hr)

Annual Rate (gal/yr)

TP1

Truck Pad 1

12,000

10,000,000

TP2

Truck Pad 2

12,000

1,000,000

All loading shall be submerged. The permit holder shall maintain records of throughput on a monthly basis. The annual throughput shall be calculated on a rolling 12-month basis for each product loaded and summed for each truck pad.

Loading operations of chemicals with vapor pressure of 0.03 psia or lower is allowed to be performed at Truck Pad 1 uncontrolled. Loading emissions from Truck Pad 2 operations shall be controlled by the Carbon Adsorption System (FIN/EPN: TP‐2/CAS‐9) with a maximum exit VOC concentration of 100 ppm as identified in Special Condition No. 10 of this permit.

All lines and connectors shall be visually inspected for any defects prior to hookup. Lines and connectors that are visibly damaged shall be removed from service. Operations shall cease immediately upon detection of any liquid leaking from the lines or connections.

Each tank truck shall be leak checked and certified annually in accordance with 49 CFR 180.407 Department of Transportation (DOT), for pressure tank trucks rated at 15 psig or greater. The permit holder shall not allow a tank truck to be filled unless it has passed a leak-tight test within the past year as evidenced by a certificate which shows the date the tank truck last passed the leak-tight test required by this condition and the identification number of the tank truck.

Leak Detection and Repair Programs

Piping, Valves, Connectors, Pumps and Compressors - Intensive Directed Maintenance - 28MID (TBD)

Except as may be provided for in the Special Conditions of this permit, the following requirements apply to the above-referenced equipment:

The requirements of Special Condition Nos. F and G shall not apply (1) where the volatile organic compounds (VOC) has an aggregate partial pressure or vapor pressure of less than 0.044 pounds per square inch, absolute (psia) at 68°F or (2) operating pressure is at least 5 kilopascals (0.725 psi) below ambient pressure. Equipment excluded from this condition shall be identified in a list or by one of the methods described below to be made available upon request.

The exempted components may be identified by one or more of the following methods:

· piping and instrumentation diagram (PID);

· a written or electronic database or electronic file;

· color coding;

· a form of weatherproof identification; or

· designation of exempted process unit boundaries.

Construction of new and reworked piping, valves, pump systems, agitators, and compressor systems shall conform to applicable American National Standards Institute (ANSI), American Petroleum Institute (API), American Society of Mechanical Engineers (ASME), or equivalent codes.

New and reworked underground process pipelines shall contain no buried valves such that fugitive emission monitoring is rendered impractical. New and reworked buried connectors shall be welded.

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. Difficult-to-monitor and unsafe-to-monitor valves, as defined by Title 30 Texas Administrative Code Chapter 115 (30 TAC Chapter 115), shall be identified in a list to be made available upon request. The difficult-to-monitor and unsafe-to-monitor valves may be identified by one or more of the methods described in Special Condition No. A above. If an unsafe to monitor component is not considered safe to monitor within a calendar year, then it shall be monitored as soon as possible during safe to monitor times. A difficult to monitor component for which quarterly monitoring is specified may instead be monitored annually.

New and reworked piping connections shall be welded or flanged. Screwed connections are permissible only on piping smaller than two-inch diameter. Gas or hydraulic testing of the new and reworked piping connections at no less than operating pressure shall be performed prior to returning the components to service or they shall be monitored for leaks using an approved gas analyzer within 15 days of the components being returned to service. Adjustments shall be made as necessary to obtain leak-free performance. Connectors 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 an appropriately sized cap, blind flange, plug, or a second valve to seal the line. Except during sampling, both valves shall be closed. If the isolation of equipment for hot work or the removal of a component for repair or replacement results in an open-ended line or valve, it is exempt from the requirement to install a cap, blind flange, plug, or second valve for 72 hours. If the repair or replacement is not completed within 72 hours, the permit holder must complete either of the following actions within that time period;

a cap, blind flange, plug, or second valve must be installed on the line or valve; or

the open-ended valve or line shall be monitored once for leaks above background for a plant or unit turnaround lasting up to 45 days with an approved gas analyzer and the results recorded. For all other situations, the open-ended valve or line shall be monitored once by the end of the 72 hours period following the creation of the open-ended line and monthly thereafter with an approved gas analyzer and the results recorded. For turnarounds and all other situations, leaks are indicated by readings of 500 ppmv and must be repaired within 24 hours or a cap, blind flange, plug, or second valve must be installed on the line or valve.

Accessible valves shall be monitored by leak-checking for fugitive emissions at least quarterly using an approved gas analyzer with a directed maintenance program. Sealless/leakless valves (including, but not limited to, welded bonnet bellows and diaphragm valves) and relief valves equipped with a rupture disc upstream or venting to a control device are not required to be monitored. For valves equipped with rupture discs, a pressure-sensing device 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.

A check of the reading of the pressure-sensing device to verify disc integrity shall be performed at least quarterly and recorded in the unit log or equivalent. Pressure-sensing devices that are continuously monitored with alarms are exempt from recordkeeping requirements specified in this Special Condition.

An approved gas analyzer shall conform to requirements listed in Method 21 of 40 CFR part 60, appendix A. The gas analyzer shall be calibrated with methane. In addition, the response factor of the instrument for a specific VOC of interest shall be determined and meet the requirements of Section 8 of Method 21. If a mixture of VOCs is being monitored, the response factor shall be calculated for the average composition of the process fluid. A calculated average is not required when all of the compounds in the mixture have a response factor less than 10 using methane. If a response factor less than 10 cannot be achieved using methane, then the instrument may be calibrated with one of the VOC to be measured or any other VOC so long as the instrument has a response factor of less than 10 for each of the VOC to be measured.

A directed maintenance program shall consist of the repair and maintenance of components assisted simultaneously by the use of an approved gas analyzer such that a minimum concentration of leaking VOC is obtained for each component being maintained. A first attempt to repair the leak must be made within 5 days. Records of the first attempt to repair shall be maintained. Replaced components shall be re-monitored within 15 days of being placed back into VOC service.

All new and replacement pumps, compressors, and agitators shall be equipped with a shaft sealing system that prevents or detects emissions of VOC from the seal. These seal systems need not be monitored and may include (but are not limited to) dual pump seals with barrier fluid at higher pressure than process pressure, seals degassing to vent control systems kept in good working order, or seals equipped with an automatic seal failure detection and alarm system. 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.

All other pump, compressor, and agitator seals shall be monitored with an approved gas analyzer at least quarterly.

Damaged or leaking valves, connectors, compressor seals, pump seals, and agitator seals found to be emitting VOC in excess of 500 parts per million by volume (ppmv) or found by visual inspection to be leaking (e.g., dripping process fluids) shall be tagged and replaced or repaired. A leaking component shall be repaired as soon as practicable, but no later than 15 days after the leak is found. If the repair of a component would require a unit shutdown that would create more emissions than the repair would eliminate, 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. A listing of all components that qualify for delay of repair shall be maintained on a delay of repair list. The cumulative daily emissions from all components on the delay of repair list shall be estimated by multiplying by 24 the mass emission rate for each component calculated in accordance with the instructions in 30 TAC 115.782 (c)(1)(B)(i)(II). The calculations of the cumulative daily emissions from all components on the delay of repair list shall be updated within ten days of when the latest leaking component is added to the delay of repair list. When the cumulative daily emission rate of all components on the delay of repair list times the number of days until the next scheduled unit shutdown is equal to or exceeds the total emissions from a unit shutdown as calculated in accordance with 30 TAC 115.782 (c)(1)(B)(i)(I), the TCEQ Regional Manager and any local programs shall be notified and may require early unit shutdown or other appropriate action based on the number and severity of tagged leaks awaiting shutdown. This notification shall be made within 15 days of making this determination.

In lieu of the monitoring frequency specified in Special Condition No. F, valves in gas and light liquid service may be monitored on a semiannual basis if the percent of valves leaking for two consecutive quarterly monitoring periods is less than 0.5 percent.

Valves in gas and light liquid service may be monitored on an annual basis if the percent of valves leaking for two consecutive semiannual monitoring periods is less than 0.5 percent.

If the percent of valves leaking for any semiannual or annual monitoring period is 0.5 percent or greater, the facility shall revert to quarterly monitoring until the facility again qualifies for the alternative monitoring schedules previously outlined in this Special Condition.

The percent of valves leaking used in Special Condition No. I shall be determined using the following formula:

(Vl + Vs) x 100/Vt = Vp

Where:

Vl = the number of valves found leaking by the end of the monitoring period, either by Method 21 or sight, sound, and smell.

Vs = the number of valves for which repair has been delayed and are listed on the facility shutdown log.

Vt = the total number of valves in the facility subject to the monitoring requirements, as of the last day of the monitoring period, not including nonaccessible and unsafe-tomonitor valves.

Vp = the percentage of leaking valves for the monitoring period.

Records of repairs shall include date of repairs, repair results, justification for delay of repairs, and corrective actions taken for all components. Records of instrument monitoring shall indicate dates and times, test methods, and instrument readings. The instrument monitoring record shall include the time that monitoring took place for no less than 95% of the instrument readings recorded. Records of physical inspections shall be noted in the operator’s log or equivalent.

Compliance with the requirements of this condition does not assure compliance with requirements of 30 TAC Chapter 115, an applicable New Source Performance Standard, or an applicable National Emission Standard for Hazardous Air Pollutants and does not constitute approval of alternative standards for these regulations.

Control Devices

The carbon adsorption systems (CAS-9) shall consist of at least two activated carbon canisters that are connected in series. (TBD)

The CAS shall be tested and recorded at least once every seven (7) days to determine breakthrough of volatile organic compounds (VOC). The sampling point shall be at the outlet of the initial canister but before the inlet to the second or final polishing canister. Sampling shall be done during operating conditions, reflecting maximum emission venting to the CAS, during truck pad 2 loading.

The VOC sampling and analysis shall be performed using an instrument with a flame ionization detector (FID), or a TCEQ-approved alternative detector. The instrument/FID must meet all requirements specified in Section 8.1 of EPA Method 21 (40 CFR 60, Appendix A). Sampling and analysis for VOC breakthrough shall be performed as follows:

Immediately prior to performing influent wastewater monthly, the instrument/FID shall be calibrated with zero and span calibration gas mixtures. The instrument/FID shall be calibrated daily with zero and span cylinder calibration gas mixtures. Zero gas shall be certified to contain less than 0.1 ppmv total hydrocarbons. Span calibration gas shall be propane at a concentration within ± 10 percent of the breakthrough concentration of 100 ppmv and certified by the manufacturer to be ± 2 percent accurate. Calibration error for the zero and span calibration gas checks must be less than ± 5 percent of the span calibration gas value before sampling may be conducted.

The sampling point shall be at the outlet of the initial canister but before the inlet to the second or final polishing canister. Sample ports or connections must be designed such that air leakage into the sample port does not occur during sampling.

During sampling, data recording shall not begin until after two times the instrument response time. The VOC concentration shall be monitored for at least 5 minutes, recording 1-minute averages, during truck pad 2 loading.

Breakthrough shall be defined as the highest 1-minute average measured VOC concentration at or exceeding 100 ppmv. When the condition of breakthrough of VOC from the initial saturation canister occurs, the waste gas flow shall be switched to the second canister and a fresh canister shall be placed as the new final polishing canister within four hours. Sufficient new activated carbon canisters shall be maintained at the site to replace spent carbon canisters such that replacements can be done in the above specified time frame.

Records of the CAS monitoring maintained at the plant site, shall include (but are not limited to) the following:

Sample time and date.

Monitoring results (ppmv).

Corrective action taken including the time and date of that action.

Process operations occurring at the time of sampling.

Alternate monitoring or sampling requirements that are equivalent or better may be approved by the TCEQ Regional Manager. Alternate requirements must be approved in writing before they can be used for compliance purposes.

The Vapor Combustor (EPN: VLSVCU) shall be designed and operated in accordance with the following requirements: (TBD)

The Vapor Combustor unit (VCU) shall achieve 99% control of the waste gas directed to it. This shall be ensured by maintaining the temperature in, or immediately downstream of, the combustion chamber above 1400 °F prior to the initial stack test performed in accordance with the permit Special Condition No. 23. Following the completion of that stack test, the six-minute average temperature shall be maintained above the minimum one-hour average temperature maintained during the last satisfactory stack test

The temperature measurement device shall reduce the temperature readings to an averaging period of 6 minutes or less and record it at that frequency. The temperature monitor shall be installed, calibrated or have a calibration check performed at least annually, and maintained according to the manufacturer's specifications. The device shall have an accuracy of the greater of ±2 percent of the temperature being measured expressed in degrees Celsius or ±2.5ºC.

Quality assured (or valid) data must be generated when the VCU is operating except during the performance of a daily zero and span check. Loss of valid data due to periods of monitor break down, out-of-control operation (producing inaccurate data), repair, maintenance, or calibration may be exempted provided it does not exceed 5 percent of the time (in minutes) that the VCU operated over the previous rolling 12 month period. The measurements missed shall be estimated using engineering judgment and the methods used recorded.

The Vapor Combustor shall be operated with no visible emissions and have a constant pilot flame during all times waste gas could be directed to it. The pilot flame shall be continuously monitored by a thermocouple or an infrared monitor. The time, date, and duration of any loss of pilot flame shall be recorded. Each monitoring device shall be accurate to, and shall be calibrated or have a calibration check performed at a frequency in accordance with, the manufacturer’s specifications.

The permit holder shall use a Vapor Combustor (EPN: VLSVCU) in the emission control of a compound from the following FINs:, 05‐T‐21, 05‐T‐22, 01‐C‐5, 01‐C‐5A, 01‐C‐5B, FLOC, , 01‐T‐58, , 01‐T‐571, 01‐T‐572, 01‐T‐573, 01‐T‐574, 01‐T‐575, , EB‐1, 05‐T‐590, GRPTK1 (Tank 530 and Tank 532), CAP1 (Tank 05‐T‐1B, Tank T583, Tank T589, Tank 05‐T‐9A, Tank 05‐T‐9B, 05‐T‐5, and 05‐T‐8), GRPTK2 (Tank 584, Tank 585, Tank 590, and Tank 591), GRPTK4 (Tank T51, Tank T52, Tank T53, Tank T54, and Tank T55), GRPTK5 (Tank 05‐T‐4A, Tank 05‐T‐4B, Tank 05‐T‐4C, Tank 05‐T‐4D, and Tank 05‐T‐4E).

Fuel gas combusted at this facility shall be sweet natural gas containing no more than 5 grains of total sulfur per 100 dry standard cubic feet. (TBD)

Compliance Assurance Monitoring (CAM)

The following requirements apply to capture systems for the vapor combustor (EPN: VLSVCU) and the carbon adsorption system (EPN: CAS:9). (TBD)

The permit holder shall comply with the following monitoring requirements.

Conduct a once a month visual, audible, and/or olfactory inspection of the capture system to verify there are no leaking components in the capture system; or

Once a year, verify the capture system is leak-free by inspecting in accordance with 40 CFR Part 60, Appendix A, Test Method 21. Leaks shall be indicated by an instrument reading greater than or equal to 500 ppmv above background.

The control device shall not have a bypass.

Or

If there is a bypass for the control device, comply with either of the following requirements:

Install a flow indicator that records and verifies zero flow at least once every fifteen minutes immediately downstream of each valve that if opened would allow a vent stream to bypass the control device and be emitted, either directly or indirectly, to the atmosphere; or

Once a month, inspect the valves, verifying that the position of the valves and the condition of the car seals prevent flow out the bypass.

A bypass does not include authorized analyzer vents, highpoint bleeder vents, low point drains, or rupture discs upstream of pressure relief valves if the pressure between the disc and relief valve is monitored and recorded at least weekly. A deviation shall be reported if the monitoring or inspections indicate bypass of the control device when it is required to be in service.

Records of the inspections required shall be maintained and if the results of any of the above inspections are not satisfactory, the permit holder shall promptly take necessary corrective action.

Wastewater and Deep Well Treatment:

Process wastewater shall be immediately directed to a covered system. All lift stations, manholes, junction boxes, conveyances, and any other wastewater facilities shall be covered to minimize emissions. Collection system shall be hard piped/covered conveyance to biological treatment unit and stripped gases from pretreatment shall be equipped with a closed vent system that shall route all organic vapor to the Vapor Combustor (EPN: VLSVCU).

Water seals shall be checked by visual or physical inspection quarterly for indications of low water levels or other conditions that would reduce the effectiveness of water seal controls. Water seals shall be restored as necessary within 24 hours. Records shall be maintained of these inspections and corrective actions taken. (TBD)

The daily wastewater flow into the wastewater treatment plant shall be monitored and recorded. The rolling 12-month wastewater flow shall be totaled on a monthly basis. (TBD)

The minimum mixed liquor total suspended solids (MLSS) concentration in the aeration basins on a daily average basis shall not be less than 2500 mg/L. The MLSS concentration is the arithmetic average of all samples collected during the 24-hour period. The MLSS concentrations shall be monitored and recorded daily using Method 160.2 (Methods for Chemical Analysis of Water and Wastes, EPA-600/4-79-020 or Method 2540D (Standard Methods of the Examination of Water and Wastewater, 18th Edition, American Public Health Association). (TBD)

Wastewater Treatment System and Deep Well Injection System emissions shall be estimated every month using the following: (TBD)

The permit holder shall sample the influent wastewater monthly to determine the concentrations of chemicals listed in Attachment B. Sampling locations, sampling procedures, test methods and calculations shall be in accordance with methods and procedures required in TPDES Permit No. WQ00017310000 and as specified in permit application, PI-1 dated September 11, 2019. The influent wastewater flow rates shall be measured and recorded when a sample required by this condition is collected. Records of analytical results shall be maintained for all air contaminants.

Results of the monthly sampling and analysis shall be compared to the representative waste stream concentrations utilized in the emissions estimates on MAERT. The permit holder shall calculate short term loading rate in terms of pounds per hour (lb/hr) and rolling 12 month loading rate in terms of tons per year (tpy) for each air contaminant. The measured concentrations of each speciated air contaminant shall be converted to an equivalent mass emission rate based upon the flow rates during the sample collection period using the calculation methods and assumptions in the permit application, PI-1 dated September 11, 2019. The MLSS used in the emission calculation shall be either the minimum identified in Special Condition No.16 or the measured concentration for the day the sampling required for this condition is completed. The short-term emission rate calculations for such air contaminants shall be based on the concentrations and flow rates measured during sampling. The rolling 12-month emission rate calculation for each air contaminant shall be based on the rolling 12-month average contaminant concentration and the rolling 12-month wastewater flow. All other inputs into the calculation shall match those in the permit application for that averaging period (worst case). Total VOC mass emission rates shall be calculated as the sum of the individual speciated VOC mass emission rates.

All air contaminants ascertained by the analytical methods shall be evaluated. For any tentatively identified new air contaminant that can be confirmed as present and that would have a calculated air contaminant mass emission rate more than 0.04 pound per hour (lb/hr) above that represented in the permit application PI-1 dated September 11, 2019, using the Water 9 program, the total emissions of that compound must satisfy the Chemical Flexibility equation in Special Condition No. 24, and documentation of the additional or increased chemical concentration shall be maintained. The information below shall be recorded for the air contaminant.

The Effect Screening Level (ESL) for an air contaminant shall be obtained from the current TCEQ ESL list or by written request to the TCEQ Toxicology Section.

The information below shall be recorded for the air contaminant.

Chemical name(s), composition, and chemical abstract registry number if available.

True vapor pressure at maximum hourly and annual average temperature.

Molecular weight.

Date air contaminant was detected in the sample and the demonstration required in (i).

Safety Data Sheet or equivalent.

Concentration of air contaminant detected in the wastewater.

Records of sampling location, sampling procedures, sample chain of custody forms, test methods, sampling results, calculated emission rates, and sample of calculations shall be maintained.

Wastewater Treatment System (WWTS) Operational Limitations

Wastewater flow rate into the wastewater treatment system shall not exceed 202 gallons per minute (gpm) on an hourly average basis and 145 gpm on an annual average (12-month rolling average) basis. The permit holder shall monitor and record the wastewater flow into the wastewater treatment system to comply with these flow rates. The rolling 12-month wastewater flow shall be calculated using the monthly averages. (TBD)

Annual throughput of wastewater into the wastewater treatment system shall not exceed 76,056,685 gal/yr. The permit holder shall maintain records of throughput on a monthly basis and the rolling 12-month wastewater throughput shall be calculated using the monthly averages. (TBD)

The Wastewater Treatment System shall consist of the following facilities and functions: (TBD)

EPN

FIN

Source ID

VLSVCU

05-T-574 / 05-T-575

Emulsion Oil Treatment System (EOTS); Also, a Residual Fuel Oil (RFO) Tank or WWTS Receipt Tank

VLSVCU

05-T-4A, 05-T-4B, 05-T-4C,05-T4D, 05-T-4E, T51, T52, T53, T54, T55

WWTS Phase separated hydrocarbon tanks (PSHT); Also, DWIS Receipt or Fuels or Segregated Receipt Tank

VLSVCU

T-530, T-532, T-585, T-573, T-572, T-584, T-590, EB-1, T-591, T-571, T-574, T-575

WWTS Receipt tanks

VLSVCU

EB-1 & 01-T-571

Equalization Basin (also referred to as 01-C-6); Also, WWTS Receipt Tank

VLSVCU

FLOC

Flocculation Basin

VLSVCU

01-C-5

DAF (Dissolved Air Flotation) unit

VLSVCU

01‐C‐5A

DAF Effluent Pit

VLSVCU

01‐C‐5B

DAF Sludge Pit

WWS

01-T-56

Aeration Basin

WWS

01-C-7

Aeration Basin Clarifier

WWS

Trench

Inlet Trench

WWS

EFFL

Wastewater System (WWTS) Effluent Tank

VLSVCU

01‐T‐58

Neutralization Basin

VLSVCU

01‐C‐9A/B

Digester

DB-1

DB-1

Dewatering box

VLSVCU

05-T-584

WWTS Receipt Tank

VLSVCU

05-T-585

WWTS Receipt Tank

VLSVCU

05-T-591

WWTS Receipt Tank / DWIS Receipt Tank

/ Backup RFO Water Storage

Deep Well System (DWIS) Operational Limitations

The hourly and annual throughputs of the individual tanks in DWIS shall not exceed the throughputs listed in Special Condition No. 5. The permit holder shall maintain records of throughput on a monthly basis and the rolling 12-month wastewater flow shall be calculated using the monthly averages. (TBD)

The Deepwell System shall consist of the following facilities and control requirements for those are as follows: (TBD)

Deepwell System Liquid Non-Segregated waste

EPN

FIN

Source ID

VLSVCU

05-T-1B

DWIS Seg Receipt Tank

VLSVCU

05-T-5

DWIS Non‐Seg Tank

VLSVCU

05-T-8

DWIS Feed Tank

VLSVCU

05-T-9A

DWIS Process Holding / Pretreatment Tank

VLSVCU

05-T-9B

DWIS Process Holding / Pretreatment Tank

VLSVCU

05-T-21

DWIS EOTS / Multi‐service EOTS; Also, RFO Tank

VLSVCU

05-T-22


VLSVCU

05-T-51

WWTS PSHT / DWIS Receipt tank

VLSVCU

05-T-52


VLSVCU

05-T-53


VLSVCU

05-T-54

WWTS PSHT / DWIS Segregated Receipt Tank

VLSVCU

05-T-55

WWTS PSHT / DWIS Segregated Receipt Tank

VLSVCU

05-T-583

DWIS Receipt Tank

VLSVCU

05-T-584

WWTS Receipt tank / DWIS Receipt tank

VLSVCU

05-T-585

WWTS Receipt tank / DWIS Receipt tank

VLSVCU

05-T-589 /

DWIS Receipt tank

TP-1

Truck Pad 1

Truck loading at Truck Pad 1

CAS-9

Truck Pads 2

Truck loading at Truck Pad 2

05‐F‐1AH

05‐F‐1BH

05‐F‐1AH

05‐F‐1BH

DE Filter Hopper

05-F-4H

05-F-4H

Filter Press Collection Bin

VLSVCU

05‐T‐4A

WWTS PSHT / DWIS Fuels

VLSVCU

05‐T‐4B


VLSVCU

05‐T‐4C


Emissions routed to VLSVCU shall be controlled with a minimum of 99% removal efficiency when handling all chemicals on Attachment B.

Deepwell System Sludge and oil non segregated waste

EPN

FIN

Source ID

VLSVCU

05‐T‐4A


VLSVCU

05‐T‐4B


VLSVCU

05‐T‐4C


05-F-4H

05-F-4H


VLSVCU

05-T-21

Fuels Holding Tank DWIS EOTS / Multi‐service EOTS; Also, RFO Tank

VLSVCU

05-T-22

Fuels Holding Tank DWIS EOTS / Multi‐service EOTS; Also, RFO Tank

Deepwell system Segregated System

EPN

FIN

Source ID

VLSVCU

05‐T‐1B

DWIS Seg Receipt Tank

VLSVCU

05‐T‐9B

DWIS Process Holding / Pretreatment

Tank

05-T-3

05-T-3

HCl Tank; Authorized under PBR 106.472

05‐F‐1AH

05‐F‐1BH

05‐F‐1AH

05‐F‐1BH

DE Filter Hopper

VLSVCU

05‐T‐8

DWIS Feed Tank

VLSVCU

05‐T‐54

WWTS PSHT / DWIS Segregated Receipt

Tank

VLSVCU

05‐T‐55

WWTS PSHT / DWIS Segregated Receipt

Tank

CAS-9

Truck Pad 2

Truck Pad 2

05-F-4H

05-F-4H


VLSVCU

05‐T‐21


VLSVCU

05‐T‐22


VLSVCU

05‐T‐4D


VLSVCU

05‐T‐4E


Deepwell System RFO Process

EPN

FIN

Source ID

05‐T‐563

05‐T‐567

05‐T‐563

05‐T‐567

RFO Refining Tank 563 and Tank 567 (GRPTK3)

VLSVCU

05‐T‐21

RFO Tank; Also, DWIS EOTS / Multi‐service EOTS

VLSVCU

05‐T‐22

RFO Tank; Also, DWIS EOTS / Multi‐service EOTS

VLSVCU

VLSVCU

05‐T‐574 / 05‐T‐575

Backup RFO Tank; Also, WWTS EOTS

TP-1

TP-1

Truck Pad 1

05-T-9C

05-T-9C

Authorized under PBR 106.472

Stack Sampling

The permit holder shall perform stack sampling and other testing as required to establish the actual pattern and quantities of air contaminants being emitted into the atmosphere from EPN VLSVCU to demonstrate compliance with the MAERT. The testing shall also demonstrate compliance with the control efficiency for VLSVCU established in these conditions. The permit holder is responsible for providing sampling and testing facilities and conducting the sampling and testing operations at his expense. Sampling shall be conducted in accordance with the appropriate procedures of the Texas Commission on Environmental Quality (TCEQ) Sampling Procedures Manual and the U.S. Environmental Protection Agency (EPA) Reference Methods. (TBD)

Requests to waive testing for any pollutant specified in this condition shall be submitted to the TCEQ Office of Permitting and Registration, Air Permits Division. Test waivers and alternate/equivalent procedure proposals for Title 40 Code of Federal Regulation Part 60 (40 CFR Part 60) testing which must have EPA approval shall be submitted to the TCEQ Regional Director.

The appropriate TCEQ Regional Office shall be notified not less than 45 days prior to sampling. The notice shall include:

Proposed date for prestest meeting.

date sampling will occur.

Name of firm conducting sampling.

Type of sampling equipment to be used.

Method or procedure to be used in sampling.

Description of any proposed deviation from the sampling procedures specified in this permit or TCEQ/EPA sampling procedures.

Procedure/parameters to be used to determine worst case emissions during the sampling period.

The purpose of the pretest meeting is to review the necessary sampling and testing procedures, to provide the proper data forms for recording pertinent data, and to review the format procedures for the test reports. The TCEQ Regional Director must approve any deviation from specified sampling procedures.

Air contaminants emitted to be tested for include (but are not limited to the following: VOC, CO, SO2, NOx, PM10 and PM2.5 from EPN: VLSVCU.

Sampling for vapor combustor (EPN: VLSVCU) shall occur within 120 days after achieving the maximum operating rate, but no later than 180 days after the vapor combustor is installed and at such other times as may be required by the TCEQ Executive Director. Requests for additional time to perform sampling shall be submitted to the appropriate regional office.

The facility being sampled shall operate at the maximum through during stack emission testing. These conditions/parameters and any other primary operating parameters that affect the emission rate shall be monitored and recorded during the stack test. Any additional parameters shall be determined at the pretest meeting and shall be stated in the sampling report.

During subsequent operations, if the throughput is greater than that recorded during the test period, stack sampling shall be performed at the new operating conditions within 120 days. This sampling may be waived by the TCEQ Air Section Manager for the region.

Copies of the final sampling report shall be forwarded to the offices below within 60 days after sampling is completed. Sampling reports shall comply with the attached provisions entitled “Chapter 14, Contents of Sampling Reports” of the TCEQ Sampling Procedures Manual. The reports shall be distributed as follows:

One copy to the appropriate TCEQ Regional Office.

One copy to each local air pollution control program.

Sampling ports and platform(s) shall be incorporated into the design of (source stack and EPN) according to the specifications set forth in the attachment entitled “Chapter 2, Guidelines for Stack Sampling Facilities” of the Texas Commission on Environmental Quality (TCEQ) Sampling Procedures Manual. Alternate sampling facility designs must be submitted for approval to the TCEQ Regional Director. Records of vendor data for control of compounds by VLSVCU shall be kept at the facility and shall be made available to the TCEQ personnel upon request.

Chemical Flexibility

Except as provided for below, the use of compounds at the wastewater / deepwell injection system is limited to those identified in Attachment B. New compounds may be authorized through the use of the procedure below, 30 TAC Chapter 106, or 30 TAC Chapter 116. (TBD)

Short-term (pounds per hour [lb/hr]) and annual (TPY) emissions and calculations shall be completed for each chemical at each affected source. Emission rates (ER) shall be calculated in accordance with the methods documented in the amendment application, Form PI-1 dated September 11, 2019. The calculated ER shall not exceed the maximum allowable emissions rate at any emission point.

The Effect Screening Level (ESL) for the compound shall be obtained from the Toxicity Factor Database. If the compound is not on the current ESL list and does not belong to a category of compounds on the list, the permit holder shall request confirmation from the Toxicology Division that an ESL need not be created for authorization through this condition. If the Toxicology Division determines that an ESL is not required under this condition, the applicant shall ensure that all requirements of this condition except E, F, and G are satisfied. Confirmation that no ESL is required shall be kept on file by the applicant.

The new materials shall serve the same basic function, and the emissions shall emit at the same Emission Point Nos. (EPNs) as the emissions currently authorized.

All the constituents of the new compound shall be known; i.e., the weight percentages of the constituents add to 100 percent or more.

Any air contaminant in the new compound is exempt from Special Condition Nos. F and G below if it meets E(1) or E(2) below:

The compound’s annual ESL ≥ 10 percent of the compound’s short-term ESL, is emitted at a rate, and has a short-term effects screening level (ESL), as stated in the following table:

Emission Rate (lbs/hr)

Short-term ESL (μg/m3)

≤ 0.04

≥ 2 and < 500

≤ 0.10

≥ 500 and < 3,500

≤ 0.40

≥ 3,500

It has a true vapor pressure at 104˚F of less than 0.01 mm Hg.

For all other new or increases in existing air contaminants, the following procedure shall be completed to determine if the short-term impacts are acceptable.

Determine the emission rate of each air contaminant including emissions of the same air contaminant (if an existing air contaminant) from the currently authorized materials that may be emitted at the same time from each emission point.

Multiply the emission rate of the air contaminant by the unit impact multiplier for each emission point from the following table to determine the off-property impact Ground Level Concentration (GLC) for each emission point. The permit holder shall use the unit impact multipliers as listed below.

Emission Point Number

Unit Impacts

(μg/m3 per lb/hr)

VLSVCU

6.66

S-1 / GRPTK3

37.43

TP-1

406.11

FUG

46.29

WWS

106.13

CAS-9

266.50

DB-1

416.63

Sum the impacts from each emission point/emission point group to determine a total short-term off-property impact (Total GLCMAX) for the new or existing air contaminant.

Compare the total off-property impact to the short-term ESL for the air contaminant as shown below to determine if it less than or equal to the ESL.

Total GLCMAX < ESLSHORT

Where:

Total GLCMAX =the sum of the short-term GLCs from each emission point.

ESLSHORT =the short-term ESL of the new or existing air contaminant from the most current ESL list published by the TCEQ or as specifically derived by TCEQ Toxicology Division. The ESL shall be obtained in writing prior to the use of the new or increased air contaminant.

For all other new or increases in existing air contaminants, the following procedure shall be completed to determine if the annual impacts are acceptable.

Compare the annual off-property impact to the annual ESL for the air contaminant as shown below to determine if it less than or equal to the ESL.

Annual GLCMAX < ESLANNUAL

Where:

ESLANNUAL=the annual ESL of the new or existing air contaminant from the most current ESL list published by the TCEQ or as specifically derived by TCEQ Toxicology Division.

The short-term or annual emission rates from new or existing air contaminants shall not cause any increases in the short-term or annual emission rates as listed on the maximum allowable emission rates table (MAERT).

The permit holder shall maintain records of the information below and the demonstrations in steps A through G above. The following documentation is required for each compound:


True vapor pressure at maximum hourly and annual average storage temperature.

Molecular weight.

Storage tanks, loading areas, and fugitive areas where the material is to be handled and the emission control device to be utilized.

Date new compound handling commenced.

Safety Data Sheet.

Maximum concentration of the chemical in mole percent (or in weight percent for fugitive areas) in the affected facilities.

Additional Recordkeeping Requirements

Records required by the Special Conditions of this permit shall be kept and maintained at the plant site for at least five years after the data are obtained. Records of sampling location, sampling procedures, sample chain of custody forms, test methods, sampling results, calculated emission rates, and sample calculations shall be maintained. These records shall be made available to representatives of the TCEQ, the Environmental Protection Agency, or any local pollution control program having jurisdiction upon request. (TBD)

Before Installation of Vapor Combustor (EPN: VLSVCU):

The permit holder shall comply with the requirements listed in Special Condition No. 27 through 45 in lieu of Special Condition No. 5 through 8,10 through 24 until after the installation of the Vapor combustor (EPN: VLSVCU):

Storage tanks

Storage tank throughput shall be limited to the following: (05/11)

EPN

Source ID/Service

Fill/Withdrawal

Rate (gal/hr)

Annual Throughput

(gal/yr)

01-T-12

Raw Material Tank

3,600

379,600

01-T-15

Raw Material Tank

3,600

468,000

01-T-50

Raw Material Tank

3,600

405,600

01-T-59

Raw Material Tank

3,600

1,095,000

05-T-4A*

Fuels/Sludge Tank w/CAS-2

9,000

2,000,000

05-T-4B*

Fuels/Sludge Tank w CAS-3

9,000

2,000,000

05-T-4C,D,E*

Fuels Tank w/CAS-1

9,000

1,000,000

05-T-21**

Fuels Tank/Proc. Unit w/CAS-4

9,000

1,000,000

05-T-22**

Fuels Tank/Proc. Unit w/CAS-5

9,000

1,000,000

05-T-563***

RFO Tank

12,000

----

05-T-567***

RFO Tank

12,000

----

05-T-563 & 567***

RFO Tanks

----

10,000,000

*Shall be controlled with a CAS with 95% efficiency.

**Shall be controlled with a CAS (CAS-4 and/or CAS-5) with 95% efficiency when process units are used as fuel tanks.

***Shall be routed to the scrubber, EPN S-1.

The permit holder shall maintain records of tank throughput on a monthly basis, and the annual throughput shall be calculated on a rolling 12- month basis for each tank.

B.Uninsulated tank exterior surfaces exposed to the sun shall be white or aluminum. All storage tanks must be equipped with permanent submerged fill pipes.

Service in the storage tanks operating under this permit is limited to storage of wastewater and chemicals appearing on Attachment 1. Storage of other chemicals is prohibited unless prior approval for such storage is obtained from the Texas Commission on Environmental Quality (TCEQ) Executive Director by either 30 TAC §106 (Permit by Rule) or 30 TAC §116 (permit amendment), or as prescribed in the Chemical Flexibility Special Condition No. 33.

Prior approval from the TCEQ is not required in situations where storage of a new chemical is authorized by a Permit by Rule (PBR) which does not specify registration with a PI-7. In these situations, the permit holder shall document the change of service pursuant to 30 TAC §106.8(c) and retain the record on-site.

Wastewater Treatment System Filter Bins: (05/11)


EPN

Source ID

Fill/Withdrawal Rate (gal/hr)

01-F-5H

Filter Bin

12,600

Wastewater Filter Bin operations shall be limited to 2,190 hrs/yr. The permit holder shall maintain records of the fill/withdrawal rate and hours of usage. The annual operating time shall be calculated on a rolling 12-month basis.

Filter bins shall be covered when not in use.

Deepwell Injection System Filter Bins: (05/11)


EPN

Source ID

Fill/Withdrawal Rate (gal/hr)

01-F-1AH

Filter Bin

6,000

01-F-1BH

Filter Bin

6,000

01-F-2H

Filter Bin

6,000

01-F-3H

Filter Bin

6,000

01-F-4H

Filter Bin

6,000

The Centrifuge (EPN 05-V-2C) shall be operated at a maximum temperature of 160o F with a maximum throughput of 3,200 gal/hr for a total of 2,920 hr/yr. The permit holder shall maintain records of maximum throughput and the hours of usage. The annual operating time shall be calculated on a rolling 12-month basis. The centrifuge bin shall be covered when not in use.

Truck Loading:

The following maximum loading rates apply:

EPN

Source ID

Hourly Rate (gal/hr)

Annual Rate (gal/yr)

TP1

Truck Pad 1

12,000

10,000,000

TP2

Truck Pad 2

12,000

1,000,000

The permit holder shall maintain records of throughput on a monthly basis. The annual throughput shall be calculated on a rolling 12-month basis for each product loaded and summed for each truck pad.

All trucks shall be loaded using submerged fill methods.

Loading operations of chemicals with vapor pressure of 0.03 psia or lower will be performed at Truck Pad 1 uncontrolled. Loading emissions from Truck Pad 2 operations shall be controlled by the Carbon Adsorption System identified in Special Condition No. 42 of this permit.


Each tank truck shall pass vapor-tight testing every 12 months using the methods described in Title 40 Code of Federal Regulations Part 60 (40 CFR 60), Subpart XX. The permit holder shall not allow a tank truck to be filled unless it has passed a leak-tight test within the past year as evidenced by a certificate which shows the date the tank truck last passed the leak-tight test required by this condition and the identification number of the tank truck.

Chemical Flexibility

New compounds, not authorized by a PBR, may be added through the use of the procedure below: (05/11)

Short-term (pounds per hour [lb/hr]) and annual (TPY) emissions and calculations shall be completed for each chemical at each affected source. Emission rates (ER) shall be calculated in accordance with approved facility-specific methodology represented in this initial permit application received on April 6, 2009. The calculated ER shall not exceed the maximum allowable emissions rate at any emission point.

The Effect Screening Level (ESL) for the material shall be obtained from the current TCEQ ESL list or by written request to the TCEQ Toxicology Section.

The total emissions of any compound from all emission points in this permit must satisfy one of the following conditions:

The total maximum ER from all sources is less than 0.04 lb/hr and the ESL greater than 2 ug/m3; or

(ER/ESL)N ≤ (ER/ESL)E

Where:

(ER/ESL)N =maximum hourly ER of new compound(s) divided by its ESL

(ER/ESL)E =the highest ratio of any previously authorized compounds’ hourly ER divided by its ESL)

The permit holder shall maintain records of the information below and the demonstrations in steps A though C above. The following documentation is required for each compound:


True vapor pressure at maximum hourly and annual average storage temperature.

Molecular weight.

Areas where the material is to be handled and the emission control device to be utilized.

Date new compound handling commenced.

Material Safety Data Sheets.

Maximum concentration of the chemical in mole percent (or in weight percent for fugitive areas) in the affected facilities.

Wastewater Treatment System (WWTS) Operational Limitations and Work Practices

Wastewater flow rate into the wastewater treatment system shall not exceed 262.5 gpm on an hourly average basis and 141 gpm on an annual average (12-month rolling average) basis. The permit holder shall monitor and record the wastewater flow into the wastewater treatment system to comply with these flow rates. The rolling 12-month wastewater flow shall be calculated using the monthly averages.

Annual throughput of wastewater into the wastewater treatment system shall not exceed 74,072,500 gal/yr. The permit holder shall maintain records of throughput on a monthly basis and the rolling 12-month wastewater throughput shall be calculated using the monthly averages.

The Wastewater Treatment System shall consist of the following facilities and functions: (05/11)

01-C-5

IDAF (Dissolved Air Flotation)

01-C-7

Clarifier

01-C-8

API Separator

01-C-9A/B

Digestor

05-T-43

Batch Feed Tank to Centrifuge

05-T-44

Wastewater Receipt Tank from Centrifuge

05-T-51

Receipt Tank (contents can be transferred to DWIS also)

05-T-52


05-T-53


01-T-56

Aeration Basin

01-T-58

Neutralization Basin

01-T-532

Equalization Basin

01-T-569

Receipt Tank

01-T-570

Equalization Basin

01-T-571

Equalization Basin (also referred to as 01-C-6)

01-T-572

Receipt Tank

01-T-573

Receipt Tank

05-T-574

Emulsion Oil Treatment System (EOTS)

05-T-575

EOTS

05-T-584

Treated Wastewater Storage

05-T-585


05-T-591

Receipt/Process Tank

01-T-573

Receipt Tank

05-T-574

Emulsion Oil Treatment System (EOTS)

05-T-575

EOTS

05-T-584


05-T-585


05-T-591


05-T-575

EOTS

05-T-584


05-T-585


05-T-591


Process wastewater shall be immediately directed to a covered system. All lift stations, manholes, junction boxes, conveyances, and any other wastewater conveyance facilities shall be covered to minimize emissions. (05/11)

Deepwell System (DWS) Operational Limitations and Work Practices

Wastewater flow rate into the deepwell system shall not exceed 125.1 gpm on an hourly average basis and 23.8 gpm on an annual average (12-month rolling average) basis. The permit holder shall monitor and record the wastewater flow into the deepwell system to comply with these flow rates.

Annual throughput of wastewater into the deepwell system shall not exceed 12,511,308 gal/yr. The permit holder shall maintain records of throughput on a monthly basis and the rolling 12month wastewater flow shall be calculated using the monthly averages.

The Deepwell System shall consist of the following facilities and control requirements for those are as follows: (05/11)

05-C-1

Circular Clarifier

05-C-2

Clarifier Effluent Tank

05-C-3

Clarifier Sludge Tank

05-C-4

Clarifier Oil Tank

05-T-1A*

Storage Tank with CAS-6

05-T-1B*


05-T-5

Storage Tank

05-T-8

Storage Tank

05-T-9A

Storage Tank

05-T-9B

Storage Tank

05-T-21*

Fuels Holding Tank with CAS-4

05-T-22*

Fuels Holding Tank with CAS-5

05-T-43

Centrifuge Process Tank

05-T-44

Storage Tank

05-T-51

Wastewater Receipt Tank

05-T-52


05-T-53


05-T-54


05-T-55


05-T-583*


05-T-584

Treated Wastewater Storage Tank

05-T-585

Treated Wastewater Storage Tank

05-T-589

Storage Tank

05-T-590

Storage Tank

*Shall be controlled with a CAS with a minimum of 95% removal efficiency when handling all chemicals on Attachment B.


Carbon Adsorption System (CAS)

The permit holder shall perform stack sampling and other testing as required to establish the actual pattern and quantities of air contaminants being emitted into the atmosphere from EPNs CAS-1 and CAS-2 to demonstrate compliance with the MAERT. The permit holder is responsible for providing sampling and testing facilities and conducting the sampling and testing operations at his expense. Sampling shall be conducted in accordance with the appropriate procedures of the Texas Commission on Environmental Quality (TCEQ) Sampling Procedures Manual and the U.S. Environmental Protection Agency (EPA) Reference Methods.

Requests to waive testing for any pollutant specified in this condition shall be submitted to the TCEQ Office of Permitting and Registration, Air Permits Division. Test waivers and alternate/equivalent procedure proposals for Title 40 Code of Federal Regulation Part 60 (40 CFR Part 60) testing which must have EPA approval shall be submitted to the TCEQ Regional Director.

The appropriate TCEQ Regional Office shall be notified not less than 45 days prior to sampling. The notice shall include:

Proposed date for prestest meeting.

date sampling will occur.

Name of firm conducting sampling.

Type of sampling equipment to be used.

Method or procedure to be used in sampling.

Description of any proposed deviation from the sampling procedures specified in this permit or TCEQ/EPA sampling procedures.

Procedure/parameters to be used to determine worst case emissions during the sampling period.

The purpose of the pretest meeting is to review the necessary sampling and testing procedures, to provide the proper data forms for recording pertinent data, and to review the format procedures for the test reports. The TCEQ Regional Director must approve any deviation from specified sampling procedures.

Air contaminants emitted from the CAS-1 and CAS-2 to be tested for include (but are not limited to) VOC.

Sampling shall occur within 60 days after achieving the maximum operating rate, but no later than 180 days after the issuance of this permit and at such other times as may be required by the TCEQ Executive Director. Requests for additional time to perform sampling shall be submitted to the appropriate regional office.

The facility being sampled shall operate at the maximum through during stack emission testing. These conditions/parameters and any other primary operating parameters that affect the emission rate shall be monitored and recorded during the stack test. Any additional parameters shall be determined at the pretest meeting and shall be stated in the sampling report.

During subsequent operations, if the throughput is greater than that recorded during the test period, stack sampling shall be performed at the new operating conditions within 120 days. This sampling may be waived by the TCEQ Air Section Manager for the region.

Copies of the final sampling report shall be forwarded to the offices below within 60 days after sampling is completed. Sampling reports shall comply with the attached provisions entitled “Chapter 14, Contents of Sampling Reports” of the TCEQ Sampling Procedures Manual. The reports shall be distributed as follows:

One copy to the appropriate TCEQ Regional Office.

One copy to each local air pollution control program.

The permit holder shall use a carbon adsorption system in the emission control of a compound from Deepwell Tanks 05-T-1A; 05-T-1B; 05-T-21; 05-T-22; and 05-T-583 (footnoted in Special Condition No.40) , Truck Pad 2 loading and process venting during operations of Tanks 05-T-4A, 4B, 4C, 4D, 4E; 05-T-21 and 05-T-22 (footnoted in Special Condition No. 27) at the facility. CAS will achieve a minimum of 95% removal efficiency. Records of vendor data for control of compounds by CAS shall be kept at the facility and shall be made available to the TCEQ personnel upon request.

The carbon adsorption systems (CAS-1 through CAS-8) shall consist of at least two activated carbon canisters that are connected in series.

The CAS shall be tested and recorded once a week, when utilized, to determine breakthrough of VOC. Sampling shall be done during operating conditions, reflecting maximum emission venting to the CAS. (Example: during loading, tank filling, and process venting of VOC).

The method of VOC sampling and analysis shall be by flame ionization detector (FID), or a TCEQ- approved alternative detector. The instrument/FID must meet all requirements specified in Section 8.1 of EPA Method 21 (40 CFR 60, Appendix A). Sampling and analysis for VOC breakthrough shall be performed as follows:

On each day that sampling is required, the FID shall be calibrated prior to sampling with a certified gas mixture at 0 ppmv ±10 percent and at 100 ppmv ±10 percent. Calibration error for the zero and span calibration gas checks must be less than ±5 percent of the span calibration gas value before sampling may be conducted.

The sampling point shall be at the outlet of the initial canister but before the inlet to the second or final polishing canister. Sample ports or connections must be designed such that air leakage into the sample port does not occur during sampling.

During sampling, data recording shall not begin until after two times the instrument response time. The VOC concentration shall be monitored for at least 5 minutes, recording 1-minute averages, during operating conditions, such as loading, tank filling and process venting, reflecting maximum emission venting to the CAS.

Breakthrough shall be defined as a measured VOC concentration of 100 ppmv as VOC. When VOC breakthrough is detected, the venting operation shall be halted. Operations for which CAS control is specified shall remain shut down until fresh carbon beds are installed to show two carbon canisters in series.

Records of the CAS monitoring maintained at the plant site shall include (but not limited to) the following:

1. Sample time and date;

1. Monitoring results (ppmv);

1. Corrective action taken including time and date of that action; and

1. Process operations occurring at the time of sampling.

These records shall be made available to representatives of the TCEQ and local programs upon request and shall be retained for at least two years following the date that the data is obtained.

Sampling and Calculation of Emission Estimates

Wastewater Treatment System and Deepwell System emissions shall be estimated using the following:

The permit holder shall sample the influent wastewater quarterly to determine the concentrations of chemicals listed in Attachment 1. Sampling locations, sampling procedures, test methods and calculations shall be in accordance with methods and procedures required in TPDES Permit No. WQ00017310000. The influent wastewater flow rates shall be measured and recorded when a sample required by this condition is collected. Records of analytical results shall be maintained.

Results of the quarterly sampling and analysis shall be compared to the representative waste stream concentrations utilized in the emissions estimates on MAERT.

All air contaminants ascertained by the analytical methods shall be evaluated. For any tentatively identified new air contaminant that can be confirmed as present and that would have a calculated air contaminant mass emission rate more than 0.04 pound per hour (lb/hr) above that represented in the permit application using the Water 9 program, the total emissions of that compound must satisfy the Chemical Flexibility equation in Special Condition No. 33, and documentation of the additional or increased chemical concentration shall be maintained. The information below shall be recorded for the air contaminant.


True vapor pressure at maximum hourly and annual average temperature.

Molecular weight.

Date air contaminant was detected in the sample.

Material Safety Data Sheet or equivalent.

Concentration of air contaminant detected in the wastewater.

Incorporated Consent Decree Requirements

No later than four years after July 31, 2017 (hereinafter, “Effective Date”), the permit holder shall ensure that all wastewater that is not permitted to be discharged pursuant to TPDES Permits is routed directly to one or more of the Receipt Tanks or, if the Receipt Tanks have insufficient remaining capacity because of weather events, to EB-1 and Tank 571. (TBD)

No later than four years after the Effective Date, the permit holder shall: (TBD)

fully cover Tank 571 and EB-1, the Flocculation Basin, the DAF, the Neutralization Basin, the Digester, and the DAF Effluent and Sludge Pit; and

construct and install one or more Closed-Vent System(s) to capture and continuously route VOC emissions to a Vapor Combustor from Tank 571 and EB-1, the Flocculation Basin, the DAF, the Neutralization Basin, the Digester, the DAF Effluent and Sludge Pit, and each Receipt Tank.

No later than four years after the Effective Date, the permit holder shall design, install, and continuously operate a Vapor Combustor (EPN: VLSVCU) and associated Vapor Combustor monitoring equipment (including, but not limited to, the equipment necessary to conduct the monitoring required by Special Condition No. 66 and 67 to control and monitor emissions from the Closed-Vent Systems required by Special Condition No.47. The permit holder shall continuously operate such Vapor Combustor in accordance with the Vapor Combustor Operational Requirements specified in Special Condition No. 73 through 75. (TBD)

Upon the Effective Date, prior to any Phase-Separated Hydrocarbon Tank or the Emulsion Oil Treatment System (“EOTS”) receiving or storing any separated organic phase materials, the permit holder shall ensure that each Phase-Separated Hydrocarbon Tank and the EOTS are equipped with a Closed-Vent System that captures and continuously routes VOC emissions to a Carbon Adsorption System or to the Vapor Combustor. (TBD)

The permit holder shall ensure that each hatch and relief device in the Closed-Vent Systems remains in a closed position during normal operations except when, in accordance with good engineering and safety practices for handling flammable, explosive, or other hazardous materials, the permit holder is conducting sampling, inspection, maintenance, or the device opens to prevent physical damage or permanent deformation. (TBD)

Upon the Effective Date, the permit holder shall comply with 30 Texas Administrative Code § 115.212 during all loading or transfers from the Phase-Separated Hydrocarbon Tanks into trucks or transport vessels. (TBD)

Upon the Effective Date, the permit holder shall not directly or indirectly transfer any material from any Phase-Separated Hydrocarbon Tank to the Receipt Tanks or to the Wastewater Treatment System. This special condition does not apply to post-treatment wastewater transferred from the EOTS to the Receipt Tanks where the source of the wastewater is not the Receipt Tanks or the Wastewater Treatment System. (TBD)

Upon the Effective Date, the permit holder shall ensure that (a) all separated organic phase materials that are removed from any of the Receipt Tanks or from Tank 571 or EB-1 (hereinafter, “Removed Organics”) are transported via a closed system to one or more of the Phase-Separated Hydrocarbon Tanks or the EOTS; and (b) all separated organic phase materials that are removed from the EOTS after the EOTS has processed Removed Organics are transported via a closed system to one or more of the Phase-Separated Hydrocarbon Tanks. (TBD)

Upon the Effective Date: (a) Removed Organics may not be commingled in the EOTS with materials from any other source; and (b) post-treatment wastewater from the EOTS may not be transferred directly to Tank 571 or EB-1 or the WWTS. (TBD)

Upon the Effective Date, the permit holder shall continuously operate Carbon Adsorption Systems or a Vapor Combustor to control emissions from the Phase-Separated Hydrocarbon Tanks and the EOTS. (TBD)

Each CAS required by this Consent Decree shall consist of at least two activated carbon canisters that are connected in series, such that the permit holder can detect and address Breakthrough. When a condition of Breakthrough of VOC from the initial saturation canister occurs, the permit holder shall switch the Waste Gas flow to the final polishing canister and place a fresh canister as the new final polishing canister within 24 hours. Carbon canisters shall be appropriately sized based on a CAS design analysis and the intended service. (TBD)

The permit holder may construct and/or designate additional Phase-Separated Hydrocarbon Tanks following the Effective Date, so long as the permit holder: (i) ensures that any newly designated PSHTs comply with Special Condition No. 48 through 55 before such tanks receive any separated organic phase material; and (ii) within 30 days of having first received any separated organic phase material, conducts a CAS stack test to ensure that VOC emissions are compliant with the requirements of paragraphs 31 (a), (b) and (c) of the consent decree. (TBD)

The permit holder may construct and/or designate additional Receipt Tanks following the Effective Date, provided that the permit holder ensures that any newly constructed and/or designated Receipt Tanks comply with Special Condition No. 47.B, 48, and 50 prior to receiving or storing wastewater. (TBD)

The permit holder shall conduct all emissions monitoring and testing required by the Consent Decree in accordance with a Quality Assurance Project Plan (“QAPP”) submitted to and approved by TCEQ and EPA. (TBD)

Carbon Adsorption Systems

Whenever any of the Phase-Separated Hydrocarbon Tanks or the EOTS are being filled, but no more frequently than once per day per CAS, the permit holder shall perform Portable FID monitoring of the vent stream between the initial saturation canister and the final polishing canisters of the associated CAS for breakthrough. The permit holder may submit a request to U.S. EPA and TCEQ to reduce this frequency of monitoring based on an analysis of the amount of time the CAS can be reasonably expected to operate continuously without breakthrough. This condition shall not apply when the Vapor Combustor (EPN: VLSVCU) is installed and is in continuous operation, and the emissions from Phase-Separated Hydrocarbon Tanks or EOTS are routed to the vapor combustor. (TBD)

Wastewater Treatment System Vapor Combustor

No later than 120 Days after the permit holder has commenced continuous operation of the Vapor Combustor required by Special Condition No.48, The permit holder shall demonstrate, through an initial Combustion Efficiency stack test conducted at a time during which Waste Gas flows are within two standard deviations of the mean Waste Gas flow to the Vapor Combustor, that the Vapor Combustor is achieving a Combustion Efficiency of no less than 99 percent as demonstrated via the appropriate EPA testing methods and described in the QAPP. Combustion Efficiency shall be calculated using the following equation:

The stack sampling for the vapor combustor (EPN: VLSVCU) shall be performed in accordance with Special Condition No. 23. (TBD)

Wastewater Treatment System Monitoring

Upon the Effective Date, the permit holder shall revise the Analyte List (Attachment B) on a monthly basis, adding any Tentatively Identified Compounds from Test Methods 8015B, 8260B, and 8270C (hereafter referred to as “specified test methods”) analyses performed following confirmation of the identification of each such TIC by the laboratory. The permit holder may remove any analyte from the Analyte List if such analyte is not on the list of analytes for the specified test methods and has not been detected in any analyses performed over 24 consecutive months. The permit holder shall use the revised Analyte List for the specified test methods analyses. The permit holder shall, for all samples analyzed using the specified test methods, ensure that the sample is stored on ice and delivered to the laboratory cold and in accordance with proper chain of custody procedures. (TBD)

Upon the Effective Date, the permit holder shall monitor and record, in gallons, the following: (TBD)

the volume of wastewater entering the Flocculation Basin each day using a totalizer flow meter located downstream of the confluence of streams exiting Equalization Basin EB-1 or Tank 571 and the point at which recirculated water is added to the system;

the volume of the Removed Organics transferred to any PSHT from any Receipt Tank, Equalization Basin EB-1 or Tank 571, or the EOTS by direct measurement of the level of the PSHT immediately prior to and immediately after such transfer of Removed Organics;

the volume of the materials transferred from any Receipt Tank to the Wastewater Treatment System by direct measurement of the level of the Receipt Tank immediately prior to and immediately after the transfer of its contents; and

the total calendar monthly volume of methanol added to the Aeration Basin.

Upon the Effective Date, the permit holder shall use the specified test methods to sample and analyze each of the analytes listed on the Analyte List, as it may be modified in accordance with Special Condition No. 62, in: (TBD)

the wastewater entering the Flocculation Basin (including any flow that follows the confluence of streams exiting the Equalization Basins, EB-1 or Tank 571) at least once each calendar month, but the permit holder shall not obtain such sample and perform such analyses when the effluent from the Aeration Basin Clarifier is being recirculated;

the Removed Organics transferred from any Receipt Tank, EB-1 or Tank 571, or the EOTS to any PSHT during such transfer; and

the materials transferred from any Receipt Tank to the Wastewater Treatment System immediately prior to such transfer.

No later than the last day of the calendar month following the calendar month during which the stack test described in Special Condition No. 61 occurs, and continuing at least once on a calendar monthly basis thereafter, the permit holder shall use the specified test methods to sample and analyze the concentration of each of the analytes listed on the Analyte List, as it may be modified in accordance with Special Condition No. 62, in (a) the Aeration Basin Clarifier effluent and (b) the Aeration Basin influent. The permit holder shall not obtain the samples and perform the analyses required by this special condition when the effluent from the Aeration Basin Clarifier is being recirculated. (TBD)

Beginning no later than 30 days after the installation and commencement of continuous operation of the Vapor Combustor and Vapor Combustor monitoring equipment required by Special Condition No. 48, the permit holder shall continuously measure the flow of Waste Gas to the WWTS Vapor Combustor. (TBD)

Beginning no later than 30 Days after the installation and commencement of operation of the Vapor Combustor and Vapor Combustor monitoring equipment required by Special Condition No. 48, the permit holder shall use Method 25A to measure continuously and record, on a block 15-minute average, the total gaseous organic concentration (expressed in terms of propane) of the Waste Gas routed to the Vapor Combustor. (TBD)

Beginning no later than 30 Days after the installation and commencement of continuous operation of the Vapor Combustor and Vapor Combustor monitoring equipment required by Special Condition No. 48, the permit holder shall use Method 21 of 40 C.F.R. Part 60, Appendix A to monitor, on a calendar quarterly basis, each Closed-Vent System required by Special Condition No.47.B, and all covers and openings on the following equipment: the Receipt Tanks, Tank 571, the Flocculation Basin, the DAF, the Neutralization Basin, the Digester, and the DAF Effluent and Sludge Pit. If Method 21 monitoring results are equal to or greater than 500 ppmv above background, the permit holder shall make a first effort to repair the equipment as soon as practicable, but no later than 5 Days after detection of the emissions, and such repair shall be completed no later than 15 Days after the emissions are detected. The permit holder shall only be permitted to delay the equipment repair that is required by this special condition if the repair is technically impossible without a complete or partial shutdown of the emissions source, in which case the permit holder shall ensure that the repair occurs before the end of the next such shutdown of the emissions source. (TBD)

Demonstration of Compliance with VOC Removal Requirements at WWTS

No later than 60 Days after the Effective Date, and continuing on a calendar monthly basis thereafter, the permit holder shall calculate: (TBD)

the total calendar monthly mass of VOC transferred from the Receipt Tanks to the Wastewater Treatment System using the volume and analyte concentration measurements required by Special Condition No. 63.C and 64.C. (hereinafter “Mreceipt”);

the total calendar monthly mass of VOC transferred into the PSHTs using the volume and analyte concentration measurements required by Special Condition No. 63.B and 64.B (hereinafter referred to as “MPSHT”); and

the total calendar monthly mass of methanol added to the Aeration Basin using the volume measurements required by Special Condition No. 63.D at standard temperature (20°C) and pressure (1 atm) (hereinafter “MMeOH”).

No later than 45 Days after the commencement of the measurements required by Special Condition No. 66 and 67, and continuing on a calendar monthly basis thereafter, the permit holder shall calculate: (TBD)

the total calendar monthly mass of VOC routed to the WWTS Vapor Combustor using the volume and concentration measurements required by Special Condition No. 66 and 67 (hereinafter, “MVLSVCU”);

using the most updated version of WATER9, the calendar monthly mass of VOC removed by biological treatment in the Aeration Basin (hereinafter, “MAB”). The permit holder shall base this calculation on the monthly average volume measurements required by Special Condition No.62.A. and the analytes concentrations in the Aeration Basin influent as measured under Special Condition No.65;

using the most updated version of WATER9, the calendar monthly VOC concentrations in the effluent of the Aeration Basin using the volume measurements required by Special Condition No.63.A and the analytes concentrations in the Aeration Basin influent as measured under Special Condition No.39.B (hereinafter, “WATER9 Concentration”); and

the calendar monthly mass of methanol removed by biological treatment in the Aeration Basin (hereinafter, “MMeOHAB”). The permit holder shall base this calculation on the monthly mass calculation required by Special Condition No.69.C. multiplied by the fraction of methanol removed by biological treatment as calculated by the most recent version of WATER9.

No later than the last day of the calendar month following the calendar month during which the stack test described in Special Condition No. 61 occurs, and continuing on a calendar monthly basis thereafter, the permit holder shall operate the Wastewater Treatment System with at least 90 percent efficiency, as demonstrated in accordance with the following formula, in which the value of E (“Efficiency”) shall not be less than 90: (TBD)

VLSVCU Operations

No later than four years after the Effective Date, the permit holder shall continuously operate the Vapor Combustor required by Special Condition No.48 in accordance with the Vapor Combustor Operational Requirements set forth in Special Condition No. 73 (Vapor Combustor Operational Requirements). (TBD)

VCU Operational Requirements

At all times when the Vapor Combustor is receiving a Vent Stream, the permit holder shall continuously operate such Vapor Combustor to: (a) achieve a Combustion Efficiency of no less than 99 percent, as demonstrated via the operating parameters established during the required performance test; and (b) ensure no exceedance of applicable permit emission limitations. (TBD)

At all times when a Vapor Combustor at the Facility is receiving a Vent Stream, the permit holder shall continuously operate such Vapor Combustor consistent with good air pollution control practices for minimizing emissions and in accordance with its design and the manufacturer’s specifications. With respect to the Vapor Combustor installed pursuant to Special Condition No.48 (the WWTS Vapor Combustor), good air pollution practices include, but are not limited to, ensuring through engineering design such that the air speed provides complete combustion of collected emissions. (TBD)

Nothing in this Consent Decree shall preclude the permit holder from electing to route Waste Gas from the Phase-Separated Hydrocarbon Tanks or the EOTS to the WWTS Vapor Combustor in accordance with all applicable requirements.

Other Requirements

Upon the Effective Date, the permit holder shall comply with all requirements in Special Conditions 40 and 45 of Permit 87923. (TBD)

Upon the Effective Date, the permit holder shall comply with applicable 40 C.F.R. Part 63, Subpart DD requirements. (TBD)

Recordkeeping and reporting requirements

The permit holder shall maintain the following records: (TBD)

The following data associated with the CAS Portable FID monitoring performed pursuant to Special Condition No. 61:

the calibration of the Portable FID monitoring instrument;

the Portable FID monitoring results, in parts per million by volume, and the monitoring date and time;

the spe

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