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  • Writer's pictureAdrienne Rosecrans

Permitting Loading Operations in Texas

Do you have liquid loading operations at your facility? Do you wonder what the most efficient permitting process is for adjusting your loading rates or authorized liquids? ALG has successfully permitted a variety of loading operations nationwide and stays apprised on regional permitting guidance to best serve our clients. This article will focus on specific updates made by the Texas Commission on Environmental Quality (TCEQ) which impact loading operations.

Earlier this year, the TCEQ issued a new guidance document entitled Air Permit Technical Guidance for New Source Review Loading Operations to address some longstanding loading questions, calculation method clarifications and regulatory interpretations that operators may use to make their permitting process simpler and less confusing. ALG is experienced at navigating these complex loading criteria and permitting options and is ready to help you apply the new guidance to your facility to quicken the permitting process.

Loading Activities: Loading operations are a common activity conducted at almost every terminal, refinery, petrochemical, and chemical complex in the state. Typical loading activities include loading liquids from a storage vessel into a tank truck, railcar, marine vessel, or other container. Often the liquid flows through what is called a “loading arm” that transports the liquid product between equipment. As the facility expands and modifies its business and operations, the liquid loading rates may increase/decrease, new products arrive onsite, or liquid product characteristics change. These modifications and changes may affect the facility’s current air permit authorization and require a permitting action to increase short-term or long-term emission rates.

Permitting Strategies: Under the TCEQ’s new source review program, more than one option exists to authorize or modify a facility’s loading operations or storage tank throughput. ALG has assisted clients in Texas with selecting the best option for their specific operating needs. TAC Chapter 106 Permit by Rule (PBR) authorizations tend to be the quickest and most efficient means of adjusting loading rates, but the facility must meet specific product and proximity criteria that may not be feasible. A new Readily Available Permit (RAP) was published by the TCEQ in late 2020, which is a handy way to apply for a case-by-case permit modification for existing loading operations or storage tanks that don’t meet the PBR requirements or criteria. A specific marine vessel loading RAP was also published that allows for both initial and amendment authorization if applicability conditions are met. RAPs are subject to the same public notice requirements as all NSR case-by-case permits, but all RAP applications determined to be technically complete within 15 days of receipt can begin the public notification process immediately after the completeness determination. The RAP contains special conditions that are already approved and published, much like a standard permit. ALG has been integral to assisting Texas clients navigate TCEQ requirements to determine the best permitting path that minimizes permit processing time to implement the desired loading modifications.

If you are looking for assistance with understanding your facility’s loading activity permitting options, please contact Adrienne Rosecrans, P.E., at (281) 806-5827.

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