UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2 290 BROADWAY NEW YORK. NY 10007-1866 MAY 15 2015 Honorable Joseph Martens Commissioner New York State Department of Environmental Conservation 625 Broadway Albany, New York 12233-1011 Dear Commissioner Martens: On April 28, 2014, the U.S. Environmental Protection Agency (EPA) wrote to the New York State Department of Environmental Conservation (NYSDEC) concerning the Clean Air Act requirements for the Global Companies, LLC - Albany Terminal iin"!Albany,New York. For your convenience, I am enclosing a copy of the EP A's correspondence. The EPA's letter presented issues that need to be addressed by Global before NYSDEC can issue a proposed Title V permit for the facility. Based on potential changes to the draft permit, EP A requests that the NYSDEC provide EPA with a revised draft permit prior to officially proposing it to EPA for the 45-day review period. This will allow EPA to work collaboratively with NYSDEC to ensure that outstanding permitting issues concerning Global are addressed. Please call me at any time to discuss these issues, or have your staff contact John Filippelli at 212-6373736 or Filippelli.john@epa.gov. Sincerely yours, Ud l+h ?f.. c'.;Yl '*-- Judith A. Enck Regional Administrator Enclosure cc: David Shaw, New York State Department of Environmental Conservation Robert Stanton, New York State Department of Environmental Conservation Recycled/Recyclable. Internet Address (URL). http://www.epa.goY Printed with Vegetable 011Based Inks on Recycled Paper (Minimum 50% Postconsumer content) ,1'0 • ! UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2 290 BROADWAY NEWYORK, NY 10007-1886 Mr. Donald Spencer Regional Air Pollution Control Engineer New York State Department of Environmental Conservation, Region 4 1130 North Westcott Road Schenectady, NY 12306-2014 RE: Draft title V Operating Permit Modification for Global Companies LLCAlbany Terminal, located in Albany, New York Permit ill #: 4-0101-00112/00029 Dear Mr. Spencer: The U.S. Environmental Protection Agency, Region 2 Office has reviewed the New York State Department of Environmental Conservation, Region 4 (NYSDEC)'s draft title V operating permit modification (draft permit) for Global Companies LLC-Albany Terminal (Global or facility) issued for public comment on January 29, 2014, the permitting record for this draft permit, and additional information, which was provided by your staff. Global is a stationary bulk petroleum storage and transfer terminal. The proposed modification (project) comprises of (l) reconfiguration of the existing Kenwood rail facility to allow for the off-loading of heated petroleum products; (2) conversion of Tank 33 which, currently stores distillate fuel, to volatile petroleum product (crude oil, . gasoline, ethanol) storage; (3) installation of seven new boilers that will be utilized to heat viscous petroleum products; and (4) conversion of Tank 118 from volatile petroleum products to distillate fuel storage. EPA has the following comments on the draft permit. We provide these comments to help ensure that the facility meets the federal Clean Air Act (CAA) requirements, that the permit will provide necessary information so that the basis of the permit decision is transparent and readily accessible to the public, and the permit record provides adequate support for the permit decision. 1. Background-Ambient Air Quality and Major Source Status Currently, the area in which Global is located is designated as meeting the National Ambient Air Quality Standards (NAAQS), which are promulgated to protect public health, for all criteria pollutants except for ozone. Ozone is not emitted directly from stationary sources; ozone is formed by the precursor pollutants, nitrogen oxides (NOx), and volatile organic compounds (VOC). Thus, Nonattainment New Source Review (NNSR) regulations, in ozone nonattainment areas, apply to new major stationary sources (major source) of NO x or VOC and to existing major sources ofNOx or VOC making InternetAddress (URL). http://www.epa.gov Recyc:IecIIRecy•••• • Pr1nfildwith Veg....,.. 011• ...cIlnks on RKycIed hper (MlMnum 110%Postcons_ c;onttnt) major modifications for these pollutants. NNSR permitting is intended to allow construction of new or modified sources of air pollution in these areas while still making progress toward cleaner air, and attaining the NAAQS. Whenever a new major source or a major modification at an existing major source is constructed, the source must apply for and obtain a NNSR permit that meets regulatory requirements including: (1) installation of the lowest achievable. emission rate (LAER); (2) obtaining offsets, and (3) opportunity for public involvement. EPA approved New York's NNSR and PSD1 regulations contained in 6 NYCRR., Part 231 (NYSDEC NNSR and PSD regulations) as consistent with the requirements of 40 CFR 51.165, and 40 CFR 52.21, respectively. Under NYSDEC NNNSR regulations, facilities with a potential to emit (PTE) of 50 tons per year (tpy) of VOC, and 100 tpy of NOx, which are locatedin marginal, moderate ozone nonattainment areas, or ozone transport regions, are classified as major source relative to NNSR regulations. Based on the permitting record, Global has a PTE ofVoe of 147 tpy, which is greater than the NYSDEC NNSR applicable threshold of 50 tpy. Thus, Global is a major source for ozone relative toNNSR regulations. EPA notes that, we could not identify any information in the permitting record, draft permit or draft permit review report regarding the facility PTE of NO x emissions. Furthermore, from our review, as ofNYSDEC NNSR and PSD regulations, Global is a listed source category, "Petroleum storage and transfer units with a total storage capacity exceeding 300,000 barrels". As such, the major source level is 100 tpy of a regulated pollutant ~un1ess more stringent levels are required by State regulations)2, and fugitive emissions are considered in determining whether the source is a major source and whether a modification to an existing source is a major modification. For example, a PTE of 100 tpy ofNOx would make Global a major source relative to, both, PSD and NNSR regulations. 2. Nonattainment New Source Regulations Applicability Analysis for the Proposed Modification Conducted by the Facility As discussed above, Global is a major NNSR source, and, therefore, the proposed project represents a modification to an existing major source. From our review of the permitting record (Project Summary table)4, NYSDEC has determined that, since, the increase in actual emissions (project emission potential) of the proposed modification of39.59 tpy of , 1 40 CFR 52.21 applies to new major stationary soun:es or major modification at existing major sources in attainment areas. . 2 For example, based on NYSDEC NNSR, the major facility threshold for ozone non attainment areas could be as low as 25 tpy ofVOC or NOli' 3 40 CFR 51.165(a) (1) (ix),"Fugitive emissions means those emissions which could not reasonably pass through a stack, chimney, vent or other functionally equivalent opening." 4 See Project Summary table in Attachment 1 of this letter. 2 VOC is less than the applicable significant project threshold of 40 tpy, the proposed . modification does not constitute a major modification, and, thus, it would not be subject to LAER, and offsets. . . We note that, for a modification with a project emission potential (calculated using projected actual emissions), which is less than the applicable significant project threshold, the NYSDEC NNSR regulations, only requires that the facility maintains records related to the proposed modification. The draft permit contains such requirements for the proposed modification. However, as discussed below, thus far, it is unclear to us whether the NNSR applicability analysis for this proposed modification was conducted in accordance with the provisions of the NYSDEC NNSR regulations. a. Project Emission Potential Calculation Based on NYSDEC NNSR regulations, the project emission potential must consider 2n!y the proposed emissions increases' . However, as shown in the Project Summary table, it appears that, in determining the project emission potential, the facility, contrary to the NYSDEC NNSR provisions, has also considered decreases in emissions associated with the proposed modification, not only emission increases. As shown in the Project Summary table, the project emission potential of 39.59 tpy was determined by excluding 4.27 tpl VOC from the proposed project emissions potential increases of 43.86 tpy VOC (43.83 tpy minus 4.27 tpy equals 39.59 tpy). From the facility's NNSR applicability analysis 7, the 4.27 tpy represent decreases in VOC emissions resulting from converting Tank 118 from volatile, petroleum products (e.g., gasoline) to distillate products. EP A notes that, the project emission potential determined by considering only the proposed emission increases, as required by the NYSDEC NNSR regulations, would be 43. 83 tpy VOC, which exceeds the significant project threshold of 40 tpy. For a modification with a project emission potential, which equals or exceed the applicable significant project threshold, NYSDEC requires the facility to determine the proposed modification net emission increase (which is the sum of project emission potential, increase and decreases in emissions in the contemporaneous period'', and decreases from the proposed modification). Modification with net emission increases that equal or s See 6-NYCRR-Part231-4.1 (b)(40(i) 6 As shown in the applicability analysis, the project increases in actual emissions of 43.83 tpy VOC was determined based on the difference between the projected actual emissions of 44.25 tpy and the baseline actual emissions of 0.39 tpy. 7 See Attachment 1oftbis letter • See 6 NYCRR Part 2314. (bXI3) Contemporaneous: "... the period beginning five years prior to the scheduled commence construction date of the new or modified emission source, and ending with the scheduled commence operation date ..." 3 exceed the applicable significant net emissions increase threshold" are subject to NNSR regulations (i.e., LAER, offsets). In conclusion, we recommend that the facility should provide a discussion to clarify the calculation method that was used for determination of the project emission potential, and revise the NNSR applicability analysis, including the determination of the project emission potential, net emission increase. We note that, in the event, that the revised NNSR applicability analysis would reveal that the project is subject to NNSR regulations (i.e., LAER, offsets), N!,SDEC would have to reopen the permit for public comment. b. Tank 33 Marine Loading Operations of Crude Oil. and Boilers: Projected Actual Emissions or Potential to Emit As indicated by the Project Summary table, the increases in actual VOC emissions for Tank 33 (Emission Unit: l-Tanks, Process CRI, Tank 33 storing crude oil), marine loading operations of crude oil at dock (Emission Unit: l-Rack 3, Process R3C), and for Boilers (Emission Unit: I-BOLR I) were calculated based on the projected actual emissions. However, from our conversation with you staff, it is our understanding that the tpy ofVOC values listed in the "Projected Actual Emissions" column of the Project Summary table represent the potential to emit of these emission sources, and not their projected actual emissions. Thus, clarify whether the projected actual emissions or potential to emit was used for the calculation of increases in actual emissions resulting from Tank 33 and marine loading operations of crude oil activities. Additionally, in case the projected actual emissions were used (and not potential to emit), please provide supporting information, assumptions, and calculations related to the projected actual emissions included in the , application for these emission 'sources. Furthermore, since the boilers, are new emission source, please clarify that VOC emission increases were based on their potential to emit. c. VOC Decreases in Actual Emission Tank 118 As shown in the Project Summary table and applicability analysis (See Attachment 1 of this letter), the facility has claimed 4.27 tpy ofVOC as decreases in actual emission from converting Tank 118 (which is part of the proposed modification) from gasoline to distillate products. It seems that the 4.27 tpy is the difference between the baseline actual emissions (average over year 2011 and 2012) of 4.31 tpy and 0.037 tpy VOC, which represents the new PTE of Tank 118. However, from our review, it seems that the facility current title V permit does not contain any limitations on Tank 118 VOC emission, throughput (i.e., gallons of gasoline For instance, the applicable significant net emission increase threshold for Global proposed modification is 40 tpy ofVOC. 9 4 " stored per year), or monitoring or recordkeeping requirements for the VOC emissions or for the throughput. Thus, the facility should document how they derived the baseline actual VOC emissions for Tank 118. d. Projected Fugitive Actual Emissions The facility should address the following regarding the projected fugitive actual emissions, which are listed in the Project Summary table: • Identify the sources associated with the projected fugitive actual emissions. • Provide a discussion clarifying how the projected fugitive actual emissions were derived. . . 3. Contemporaneous period-Contemporaneous increases and decreases EPA notes that, since the permitting record does not contain information related to the contemporaneous increases and decreases at the facility, we have requested such information from Region 4 through e-mail dated March 20, 2014. Nevertheless, as we understand from your staff, the files that may contain such information are no longer with Region 4, as these files are with the Central Office Staff. Thus, 'we recommend that the facility should address the following information regarding the contemporaneous period, and contemporaneous increases and decreases at the facility: • Define the contemporaneous period for the proposed modification; the contemporaneous period shall be defined as required by 6 NYCRR Subpart 231-4 (b) (13). • Provide detailed information related to the VOC emissions increases and decreases, including VOC fugitive emissions, which have occurred at the facility and that, are contemporaneous with the proposed modification. Such information shall include, but not be limited to, the emission unit, process, and emission source number and the date of the occurrence of the increase or decrease in VOC emissions. We note that the contemporaneous increases and decreases in emissions should also include emissions resulting from sources, which are exempt from permitting under the NYSDEC regulations. . We note that the Global title V air permit has been modified five times since 2011. Thus, we recommend that the description section of the permit be revised to include a summary of the changes addressed by each one of the title V permit modifications. 5 4. Exempt CombustioD Sources-Emission Estimates From our review of the permftting record, there are at least eight combustion sources consisting of emergency generators, stationary or portable internal combustion engines, and furnaces, which are exempt from permitting under NYSDEC regulations. The facility should address the following information regarding the exempt combustion sources: • Clarify whether the emissions resulting from these sources were included in the determination of the PTE for the facility. • Provide an estimate of these sources potential to emit (tpy) of NO x, VOC, CO, PM, PMlO.PM2.S, S(h, and Greenhouse gases (GHG) emissions. 5. Fugitive Emissions Sources a. Emitting Sources (Processes}-Described in the draft permit as sources of fugitive emissions We recommend that the facility should demonstrate that the facility PTE of 147 tpy of VOC and 23.75 tpy of hazardous air pollutants (HAP) includes the fugitive VOC and HAP emissions (tpy) resulting from the emitting sources (i.e., processes), which are described in the draft permit as sources of fugitive emissions. Such demonstration shall include: (l) an estimate of the PTE of VOC and HAP from each process; (2) emission factors, assumptions, and methodology used to derive the PTE; and (3) briefly identify the activities leading to the fugitive emissions occurrences. Additionally, we recommend that NYSDEC should revise the draft permit, to make sure that it includes the following information for each process: (l) Type of fugitive pollutants resulting from each process; (2) Method for monitoring the annual fugitive emissions from each process (e.g., by calculations), including the emission factors, and assumptions to be used by the facility; (3) Recordkeeping and reporting requirements; (4) Specific mitigation measures and work practices designated to prevent and minimize the occurrence of fugitive emissions ensure; and (5) Detection measures and control plan. b. Sources of Fugitive Dust Emissions We recommend that the facility should (1) Identify the fugitive dust emissions sources at the facility; (2) Estimate the PTE of PM, PMlO, and PM2.s; and (3) indicate the emission factors, assumptions, and methodology used to derive the PTE, for each source. Additionally, we recommend that NYSDEC should revise the draft permit by: (1) identifying the sources of fugitive dust emissions; (2) including the type of fugitive pollutants resulting from each source; (3) Indicating the monitoring method for the annual fugitive emissions (e.g., by calculations), including the emission factors, and 6 : assumptions to be used by the facility; (4) recordkeeping and reporting requirements; and (5) specific mitigation measures and work practices designated to prevent and minimize the occurrence of fugitive emissions ensure, and dust control plan. 6. Vapor Combustion Units-NOx, CO, PM, PMIO, PMl.5t SOl, and GHG Emissions From our review of the permitting record, current and draft permit, it is unclear whether the NO", CO, PM, PMJO,PM2.5, S~, and OHO emissions, which are resulting from the (1) combustion of the vapor emissions (that result from the petroleum products) by the vapor combustion units (VCll) used by the facility; and (2) the combustion of the auxiliary fuel required for the VCU, in order to sustain combustion have been considered in estimating the PTE of this facility. Thus, the facility should address the following: • Provide a discussion clarifying whether the NOx, CO, PM, PMlO, PM2.s, S02, and OHO emissions resulting from the vapor combustion units (from combustion of vapor emissions and auxiliary fuel), have been considered in estimating the facility PTE. • Provide estimates of PTE for each of the above-mentioned pollutants, as well as the emission factors, assumptions, and methodology used to derive the PTE. EPA recommends that, at least, the emission factors for NOx and CO emissions resulting from the combustion of vapor emissions should be expressed as milligrams per liter of product treated ( mg/l), and, if possible, to be guaranteed by the VCU manufacturer(i.e., John Zinc). Additionally, in the event that any of the gasoline vapor collection and control systems at Olobal are employing combustion for the control of the vapors collected, please provide the NOx, CO, PM, PMlO, PM2.S.S~, and OHO emissions estimates, as appropriate. 7. Storage Tanks Emissions We note that, while, the draft permit lists at least 11 storage tanks, it appears that the draft permit contains no conditions limiting the tanks' emissions (tpy ofVOC and HAP), or the tanks' throughput (i.e., gallons of product per year). Consequently, it is unclear to us, whether the facility PTE of 147 tpy ofVOC and 23.75 tpy of HAP includes the VOC and HAPs emissions resulting from the storage tanks. We recommend that the facility should substantiate the permitting record by including a demonstration that the tanks VOC and HAPs emissions are accounted for in the facility PTE. Such a demonstration shall include: (1) an estimate of the PTE ofVOC and HAP from each tank; and (2) emission factors, assumptions, and methodology used to derive the PTE; Additionally, we recommend that NYSDEC should revise the draft permit, by including either limitations on the emissions resulting from the storage tanks, or limitations on the tanks throughput, as well as the corresponding monitoring, recordkeeping and reporting requirements. 7 8. FacilityPTE-Update EPA recommends that, after addressing the issues mentioned in this letter, the facility should update, as necessary, the facility PTE (tpy) to: (1) incorporate any additional VOC or HAP emissions; and (2) add any new regulated NSR pollutants, which may exceed the applicable regulatory thresholds. 9. Clarification on tbe .Des~ription of tbe Proposed Heated Petroleum Products Activities ' ,, ' The facility should substantiate the permitting record by including the following: (1) a description of the proposed heated petroleum products activities that would identify the type and estimated amount of air pollutants resulting from each phase of the heating process; (2) 'description of air pollution control equipment designated for controlling the vapor released during the heating process; and (3) actual emissions data from operational facilities, which are employing similar heated 'petroleum products activities. 10. Type and Amount ofEacb Petroleum Product The permitting record should be substantiate by including information regarding the (1) type and throughput limit (gallons per year of product) for each petroleum product currently authorized under current permit; and (2) type and throughput limit (gallons per year of product) for each petroleum product, as contained in the draft permit. Additionally, we suggest that the information related to each product throughput limit, which is authorized by the draft permit, should, also, be included in the Description Section of the draft permit. 11. Clarifications/Comments on tbe Draft Permit Conditions a. Conditions 41 and 44 Conditions 41 for Emission Unit (EU): I-RACK l-truck loading rack, and EU: I-RACK 2-railcar loading rack, and Condition 44 for EU: I-RACK I, Process (PR): RIG, truck loading rack of gasoline and EU: I-RACK 2, PR: R2G-railcar loading of gasoline, of the draft permit, limit the VOC emissions from the gasoline vapor collection and control systems (which are designed to capture, condense, absorb, adsorb, or combust the gasoline vapors resulting from these emission units/processes) to 0.67 pounds per 1,000 gallons of gasoline (lbll,OOO gallons). Based on our calculation, 0.67 lb VOCIl,OOO gallons would yield about 80 milligrams per liter of gasoline (mg/l), However, we note that there are several conditions, elsewhere in the draft permit, which limit the VOC emissions resulting from the truck vapor recovery unit to 2 mgll (and 10 mgll in once instance) and. the rail vapor combustion unit VOC emissions to 10 mgll. Since, both the 2 and 10 mg VOClllimits, which are found in other draft permit 8 conditions, please, clarify whether there is an inconsistency among the draft permit conditions, and revise the draft permit, as appropriate. . Additionally, we note that Condition 44 for EU: I-RACK I, PR: RI G-truck loading rack . of gasoline and EU: I-RACK 2, PR: R2G-railcar loading of gasoline requires that the 0.671b vac 11,000 gallons limit to be monitored, "Per Delivery". However, it seems that the draft permit does not establish how the above-mentioned monitoring requirement should be carried out by the facility. Thus, we recommend revising the draft permit, by including specific language, establishing clear monitoring requirements for the facility. b. Condition 4-1lItem 4-1.7 Condition 4-Illtem 4-1.7, limits the gasoline/ethanol throughput for EU: I-RACK l-truck loading rack, PR: RIE and RIG to 10,416,667 gallons per year (gallons/yr), for those times "When the Vacuum Assist Vapor Reduction System" is not operational. However, we note that, this is the only time when the draft permit mentions a "Vacuum Assist Vapor Reduction System". Thus, EPA recommends adding language to the permit defining the "Vacuum Assist Vapor Reduction System". Moreover, Condition 4-1lItem 4-1.7, also states that the annual throughput limit, ''was calculated using a Truck Vapor Recovery Unit emission rate of 10 mg/l, a Rail Vapor Combustion Unit emission rate of 10 mg/l, and a Marine Vapor Combustion Unit emission rate of 10 mg/l." However, since, this condition establishes requirements for the tnick loading rack (and not for the rail or marine loading racks), which is controlled by a Truck Vapor Recovery unit, please explain (and revise the condition accordingly) why this condition refers also to "Rail Vapor Combustion Unit emission rate of 10 mg/l, and a Marine Vapor Combustion Unit emission rate of 10 mg/l. " . c. Condition 3-11Item 3-1.6 Condition 3-1IItem 3-1.6, limits the gasoline/ethanol throughput for EU: l-RACK2-PR: R2E and R2G-railcar loading rack, to 150,000,000 gallons Iyr. The condition states that the annual throughput limit, "was calculated using a Truck Vapor Recovery Unit emission rail! of2 mg/l, a Rail Vapor Combustion Unit emission rate of 10 mg/l. and a Marine Vapor Combustion Unit emission rate of 10 mg/l." However, since, this condition establishes requirements for the railcar loading rack (and not for the truck or marine loading racks), which is controlled by a Rail Vapor Combustion Unit, please explain (and revise the condition accordingly) why this condition refers also to "Truck Vapor Recovery Unit emission rate of2 mg/l, and a Marine Vapor Combustion Unit emission rate of 10 mgll. " d. Condition 4-2IItem 4-2.6 Condition 4-2IItem 4-2.6, limits the gasoline/ethanol throughput for EU: l-RACK3-PR: R3E and R3G- marine loading rack to 450,000,000 gallons Iyr. The condition states that 9 the annual throughput limit, ,"was calculated using a Truck Vapor Recovery Unit emission rate oj 2 mgll,a Rail Vapor Combustion Unit emission rate oj 10 mgll, a Marine Vapor Combustion Unit (Control: VCUML) emission rate oj 10 mgll, and another Marine Vapor Combustion Unit (Control: VCUM2) with an emission rate of3 mgll." However, since, this condition establishes requirements for the marine loading rack (and not for the truck or railcar loading racks), which is controlled by the Marine Vapor Combustion Units: VCUML and VCUM2, please explain (and revise the condition accordingly) why this condition refers also to "Truck Vapor Recovery Unit emission rate of 2 mgll, and Railcar Vapor Co'!'bustion Unit emission rate of 10 mgll. " e. Condition 4-4lItem 4-4.6 Condition 4-4lItem 4-4.6, limits the distillate oil throughput for the truck, railcar, marine. and rail spur loading racks to 229,300,000 gallons/yr. However, we note that the only regulated pollutant mentioned by this condition is HAPs. Please clarify whether this condition should also mention VOC emissions as regulated pollutants. f. Condition 4-4lItem 4-5.6 Condition 4-4lItem 4-5.6, limits the crude oil throughput for EU: I-RACK3-PR: R3C marine loading rack to 20,000,000 gallons Iyr. The condition states that the annual throughput limit, "was calculated using a Truck Vapor Recovery Unit emission rate of 2 mgll, a Rail Vapor Combustion Unit emission rate of 10 mgll, a Marine Vapor Combustion Unit (Control: VCUML) emission rate of 10 mg/l, and another Marine Vapor Combustion Unit (Control: VCUM2) with an emission rate of 3 mg/l." However, since, this condition establishes requirements for the marine loading rack (and not for the truck or railcar loading racks), which is controlled by the Marine Vapor Combustion Units: VCUML and VCUM2, please explain (and revise the condition accordingly) why this condition refers also to "Truck Vapor Recovery Unit emission rate of 2 mgll, and Railcar Vapor Combustion Unit emission rate of 10 mgll." g. Condition 4-4lItem 4-6.6 Condition 4-4lItem 4-6.6, limits the gasolinelethanol throughput for EU: I-RACK l-truck loading rack, PR: RIE and Rl G to 639,583,333 gallons Iyr. The condition states that the annual throughput limit, "was calculated using a Truck Vapor Recovery Unit emission rate of2 mgll, a Rail Vapor Combustion Unit emission rate of 10 mg/l, a Marine Vapor Combustion Unit (Control: VCUML) emission rate of 10 mgll, and another Marine Vapor Combustion Unit (Control: VCUM2) with an emission rate oJ3 mg/l." However, since, this condition establishes requirements for the truck loading rack (and not for the railcar or marine loading racks), which is controlled by the Truck Vapor Recovery Unit, please explain (and revise the condition accordingly) why this condition refers also to " Railcar Vapor Combustion Unit emission rate of 10 mg/l, and a Marine Vapor Combustion Unit (Control: VCUML) emission rate of 10 mgll, and another Marine Vapor Combustion Unit (Control: VCUM2) with an emission rate of3 mgll." 10 h. Condition 5-131Item 5-13.7 Condition 5-13lItem 5-13.7 limits the crude oil throughput for EU: l-RACK3-PR: R3C marine loading rack to 1,750,000,000 gallons Iyr. The condition states that the annual throughput limit, ''was calculated using a Truck Vapor Recovery Unit emission rate of 2 mg/l, a Rail Vapor Combustion Unit emission rate of 10 mg/l, a Marine Vapor Combustion Unit (Control: VCUML) emission rate of 10 mg/l, and another Marine Vapor Combustion Unit (Control: VCUM2) with an emission rate of 3 mg/l." However, since, this condition establishes requirements for the marine loading rack (and not for the truck or railcar loading racks), which is controlled by the Marine Vapor Combustion Units: VCUML and VCUM2, please explain (and revise the condition accordingly) why this condition refers also to "Truck Vapor Recovery Unit emission rate of2 mgll, and Railcar Vapor Combustion Unit emission rate of 10 mg/l." i. Condition 107IItem 107.2 The draft permit Condition 107IItem 107.2, states that, "This permit authorizes EU: 1. RA CK1-truck loading rack, PR: FI'1: Fugitive truck emissions while loading products. However, the draft permit does not otherwise specify the type of pollutants comprising the fugitive truck emissions, or provide a description of the activities leading to the occurrences of these fugitive emissions. Thus, please, revise the draft permit, by addressing these issues. 12. Next Generation Monitoring at Global EPA is requesting that NYSDEC consider incorporating "Next 'Generation" or "Next Gen" monitoring into the revised title V permit. Next Gen monitoring includes the following aspects: • Advanced Monitoring Technologies o Use of an Infrared camera to detect volatile organic compounds o Use of in-plant sensor networks o Use of Diffusion Tube Sampling to detect air toxics compounds • • • • Fence line monitoring using traditional fixed or portable monitoring equipment for VOCs and air toxies compounds Use of 3rd Party auditors to perform periodic monitoring Use of Electronic Reporting , Use of Transparency to provide for public access to monitoring data and reports prepared by the facility. 11 II We look forward to working with you to address all of our comments. If you have any questions or wish to discuss specific issues regarding this letter, please contact me at (212) 637-4074, or have your staff contact Ms. Viorica Petriman at (212) 637-402l. For questions related to Item No. 12 "Next Generation Monitoring at Global" of this letter, please contact Mr. Gaetano LaVigna, Acting Chief, Air Compliance Branch at 212) 637-4069. . '~f5ln Steven C. Riva, Chief Permitting Section Air Programs Branch Enclosures: Attachment 1 cc: Robert Stanton (e-mail) Director, Bureau of Stationary Source Division of Air Resources, NYSDEC 625 Broadway Albany, NY 12233-3258 Christopher LaLone (e-mail) Chief, Permitting and Compliance NYSDEC, Bureau of Stationary Sources Division of Air Resources 625 Broadway Albany, NY 12233 Donald Welsted (e-mail) NYSDEC, Division of Air Resources 1130 North Westcott Road Schenectady, NY 12306-2014 12