ghd - mplx · 2020. 3. 26. · ghd | 1712 s staples street corpus christi texas 78404 usa may 2018...

GHD | 1712 S Staples Street Corpus Christi Texas 78404 USA May 2018

Application to Amend TCEQ Air Permit #19296

MarkWest Javelina Company, LLC Javelina Gas Processing Facility

Corpus Christi, Texas CN603319880 RN102190139

TCEQ Account NE-0253-K

GHD | MarkWest Javelina Air Permit Amendment 2018 | i

Table of Contents Table of Contents .............................................................................................. i

1. Introduction .................................................................................................... 1-1

2. Administrative Forms and Information .................................................. 2-1

3. Area Map and Plot Plan .............................................................................. 3-1

4. Process Description .................................................................................... 4-1

5. Process Emissions ....................................................................................... 5-1

6. Best Available Control Technology Evaluation ................................... 6-1

7. Federal NSR Applicability .......................................................................... 7-1

8. General Application Requirements ......................................................... 8-1 Appendices Appendix A Detailed Emission Calculations Appendix B Current Permit Appendix C Current TCEQ BACT Guidelines Appendix D Screen3 Modeling Results for the Cooling Tower

1-1

1. Introduction

Background and Purpose of This Permit Amendment

MarkWest Javelina Company, LLC (MarkWest) owns and operates the Javelina Gas Processing

Facility, located at 5438 Union Street in Nueces County, Texas. The Javelina Gas Processing

Facility is authorized by New Source Review (NSR) Permit Number 19296. On June 13, 2014,

the TCEQ received an application to renew Permit Number 19296. On January 5, 2018,

MarkWest also submitted a permit amendment application to authorize emission increases that

were represented in the June 2014 renewal application and address additional items

subsequently identified by the TCEQ. The permit renewal and this permit amendment

application are pending issuance by the TCEQ.

MarkWest has recently conducted a retagging of its fugitive equipment leak components.

MarkWest has also conducted a technical evaluation of its maintenance, startup, and shutdown

(MSS) activities. This permit amendment application reflects corrections to the fugitive

emissions, MSS emissions, and other updates to appropriately represent the existing facility

operations. MarkWest requests to replace the January 2018 amendment application with this

amendment application.

The Javelina Gas Processing Facility was designed to process 140,000,000 standard cubic feet

per day of inlet gas and is not requesting any production increases. Please note that this

amendment application is not for an increase in operation or production, but rather to update

fugitive equipment leak representations, include additional MSS activities, and correct other

representations.

Tables A and B contain an annual and hourly summary of the current permit limits, proposed

permit limits, and changes in emissions for this proposed amendment, respectively. The

Javelina Gas Processing Facility is not a major source for criteria pollutants, and the proposed

changes do not trigger major new source review permitting. Therefore, Greenhouse Gas (GHG)

emissions are not required to be included in the permit application. MarkWest complies with the

applicable GHG reporting requirements under 40 Code of Federal Regulations Part 98. Boiler

representations remain unchanged since the 2004 permit renewal.

MarkWest Javelina Gas Processing Facility Air Permit 19296 Amendment, May 2018 Table AMay 2018

Proposed Current Change Proposed Current Change Proposed Current Change Proposed Current Change Proposed Current Change Proposed Current Change Proposed Current ChangeHTR-1 1 Mol Sieve Heater 3.08 3.08 0.00 5.13 5.13 0.00 0.38 0.39 -0.01 0.72 0.73 -0.01 0.28 0.22 0.06HTR-2 2 Regeneration Heater 1.60 1.60 0.00 2.66 2.66 0.00 0.20 0.20 0.00 0.37 0.38 -0.01 0.14 0.10 0.04

3, BLR-21, BLR-22

3, BLR-21, BLR-22 Boiler Cap 39.48 39.48 0.00 42.98 42.98 0.00 3.87 3.87 0.00 8.31 8.31 0.00 2.94 2.94 0.00

4 4Sulfur Recovery Incinerator 2.02 0.99 1.03 1.20 0.59 0.61 0.18 0.09 0.09 2.18 1.87 0.31 0.13 0.07 0.06 0.01 0.01 0.00

HTR-8 8 Butylene Converter 1.10 1.10 0.00 1.30 1.30 0.00 0.10 0.10 0.00 0.19 0.01 0.18 0.07 0.08 -0.0122.11 7.27 2.06 17.13 0.072.60 4.46 0.01 0.01 0.040.70 0.15 3.38 0.61 0.05 0.016.36 0.75 0.01 4.44 0.01 0.01

7 7 Cooling Tower3 5.28 - 5.28 5.78 5.78 0.00FUG-6 FUG-6 Fugitive Emissions 44.74 45.34 -0.60DEGAS DEGAS Requested limit 0.72 - 0.72

IGC VENT 1 IGC VENT 1 Requested limit 2.17 - 2.17


93.49 78.02 15.47 65.18 65.29 -0.11 10.01 4.65 0.08 17.56 16.76 0.80 90.40 76.72 13.68 0.06 0.07 -0.01 0.08 0.13 -0.05

Notes: 1. Table used to determine applicability of public notice.2. Site also contains emergency engines, low VOC-emitting tanks and the wastewater treatment system, which are permitted by rule.3. Existing emissions represented for the first time, consistent with TCEQ permitting policy, are not included in public notice totals.

18.12 90.63 0.06 0.08Proposed Potential to Emit (PTE) 94.40 68.84 10.80

-0.72

H2S (TPY)

-0.055.79 0.33 31.26 9.07 0.05 -0.01 0.08

NH3 (TPY)

Total Requested Changes (TPY)

CO (TPY) NOX (TPY) PM10 (TPY) SO2 (TPY) VOC (TPY)FIN EPN Description

FLR-5 5 Flare 46.22 14.45 11.91

MarkWest Javelina Gas Processing Facility Air Permit 19296 Amendment, May 2018Table BMay 2018

Proposed Current Change Proposed Current Change Proposed Current Change Proposed Current Change Proposed Current Change Proposed Current Change Proposed Current ChangeHTR-1 1 Mol Sieve Heater 0.70 0.70 0.00 1.17 1.18 -0.01 0.09 0.09 0.00 0.16 0.17 -0.01 0.06 0.05 0.01HTR-2 2 Regeneration Heater 0.36 0.36 0.00 0.61 0.61 0.00 0.05 0.05 0.00 0.09 0.09 0.00 0.03 0.03 0.00

3, BLR-21, BLR-22

3, BLR-21, BLR-22 Boiler Cap 0 0 0.00 0 0 0.00 0 0 0.00 0 0 0.00 0 0 0.00

4 4Sulfur Recovery Incinerator 0.46 0.25 0.21 0.27 0.15 0.12 0.04 0.03 0.01 0.50 0.43 0.07 0.03 0.02 0.01 0.00 0.01 -0.01

HTR-8 8 Butylene Converter 0.25 0.25 0.00 0.30 0.30 0.00 0.02 0.02 0.00 0.04 0.01 0.03 0.02 0.02 0.0012.10 5.76 0.47 3.51 0.0270.36 26.49 0.14 0.18 4.330.43 0.16 123.06 7.11 1.31 0.01

247.76 80.40 0.01 1554.03 1.99 0.017 7 Cooling Tower 1.20 - 1.20 1.32 1.32 0.00

FUG-6 FUG-6 Fugitive Emissions 10.21 10.44 -0.23DEGAS DEGAS Requested limit 574.40 - 574.40



779.34 342.08 1.21 2137.24 566.61 30.14 36.64Notes: 1. Site also contains emergency engines, low VOC-emitting tanks and the wastewater treatment system, which are permitted by rule.

Total Requested Changes (lb/hr) CO NOx PM10 SO2 H2S NH3

-9.83

SO2 (lb/hr) VOC (lb/hr) H2S (lb/hr) NH3 (lb/hr)

33.45 30.15 41.01 36.642260.83 2137.15 1555.00

VOC

PM10 (lb/hr)

454.78

FIN EPN Description CO (lb/hr)NOX (lb/hr)

FLR-5 5 Flare 1109.78 779.13 341.97

2-1

2. Administrative Forms and Information

This section contains the required TCEQ application forms including:

• General Application Form PI-1 with an original signature;

• Table 1(a), Emission Point Summary; and

• Table 2, Material Balance.

TCEQ-10252 (APDG 5171v39, Revised 04/18) PI-1 This form is for use by facilities subject to air quality requirements and may be revised periodically.

Texas Commission on Environmental Quality Form PI-1 General Application for

Air Preconstruction Permit and Amendment Page 1

Important Note: The agency requires that a Core Data Form be submitted on all incoming applications unless a Regulated Entity and Customer Reference Number have been issued and no core data information has changed. For more information regarding the Core Data Form, call (512) 239-5175 or go to www.tceq.texas.gov/permitting/central_registry/guidance.html.

I. Applicant Information

A. Company or Other Legal Name: MarkWest Javelina Company LLC

Texas Secretary of State Charter/Registration Number (if applicable): N/A

B. Company Official Contact Information: ( Mr. Mrs. Ms. Other:)

Name: Kevin Thompson

Title: General Manager

Mailing Address: 5438 Union Street

City: Corpus Christi State: Texas ZIP Code: 78407

Telephone No.: (361) 289-4955 Fax No.: (361) 289-4907

E-mail Address: [email protected]

All permit correspondence will be sent via electronic copies unless hard copies are specifically requested through regular mail. The company official must initial here if hard copy correspondence is requested.

C. Technical Contact Name Information: ( Mr. Mrs. Ms. Other:)

Name: Lisa Reaves

Title: Environmental Coordinator

Company Name: MarkWest Javelina Company LLC





D. Site Name: Javelina Gas Processing Facility

E. Area Name/Type of Facility: Gas Processing Facility Permanent Portable

For portable units, please provide the serial number of the equipment being authorized below.

Serial No: Serial No:

F. Principal Company Product or Business: Refinery Off-Gas Processing

Principal Standard Industrial Classification Code (SIC): 4925

Principal North American Industry Classification System (NAICS): 221210

G. Projected Start of Construction Date: N/A

Projected Start of Operation Date: N/A

http://www.tceq.texas.gov/permitting/central_registry/guidance.htmlmailto:[email protected]:[email protected]




I. Applicant Information (continued)

H. Facility and Site Location Information (If no street address, provide clear driving directions to the site in writing.):

Street Address: 5438 Union Street

City/Town: Corpus Christi County: Nueces ZIP Code: 78407

Latitude (nearest second): 27° 48’ 17” Longitude (nearest second): -97° 27’ 27”

I. Account Identification Number (leave blank if new site or facility): NE-0253-K

J. Core Data Form

Is the Core Data Form (Form 10400) attached? If No, provide customer reference number and regulated entity number (complete K and L).

YES NO

K. Customer Reference Number (CN): CN603319880

L. Regulated Entity Number (RN): RN102190139

II. General Information

A. Is confidential information submitted with this application? If Yes, mark each confidential page confidential in large red letters at the bottom of each page.

YES NO

B. Is this application in response to an investigation, notice of violation, or enforcement action? If Yes, attach a copy of any correspondence from the agency and provide the RN in section I.L. above.

YES NO

C. Number of New Jobs: 0

D. Provide the name of the State Senator and State Representative and district numbers for this facility site:

State Senator: Juan “Chuy” Hinojosa District No.: 20

State Representative: Abel Herrero District No.: 34

III. Type of Permit Action Requested

A. Mark the appropriate box indicating what type of action is requested.

Initial Amendment Revision (30 TAC § 116.116(e)

Change of Location Relocation

B. Permit Number (if existing): 19296

C. Permit Type: Mark the appropriate box indicating what type of permit is requested. (check all that apply, skip for change of location)

Construction Flexible Multiple Plant Nonattainment Plant-Wide Applicability Limit

Prevention of Significant Deterioration (PSD) Hazardous Air Pollutant Major Source

PSD for greenhouse gases (GHGs) Other: Update to reconcile permit to reflect facility operation




III. Type of Permit Action Requested (continued)

D. Is a permit renewal application being submitted in conjunction with this amendment in accordance with 30 TAC § 116.315(c).

YES NO

E. Is this application for a change of location of previously permitted facilities? YES NO

If Yes, complete all parts of III.E.

Current Location of Facility (If no street address, provide clear driving directions to the site in writing.):

Street Address:

City: County: ZIP Code:

Proposed Location of Facility (If no street address, provide clear driving directions to the site in writing.):

Street Address:

City: County: ZIP Code:

Will the proposed facility, site, and plot plan meet all current technical requirements of the permit special conditions? If “NO,” attach detailed information.

YES NO

Is the site where the facility is moving considered a major source of criteria pollutants or HAPs? YES NO

F. Consolidation into this Permit: List any standard permits, exemptions or permits by rule to be consolidated into this permit including those for planned maintenance, startup, and shutdown.

List: N/A

G. Are you permitting planned maintenance, startup, and shutdown emissions? YES NO

If Yes, attach information on any changes to emissions under this application as specified in VII and VIII.

H. Federal Operating Permit Requirements (30 TAC Chapter 122 Applicability)

Is this facility located at a site required to obtain a federal operating permit? YES NO To be determined

If Yes, list all associated permit number(s), attach pages as needed).

Associated Permit No (s.):

Identify the requirements of 30 TAC Chapter 122 that will be triggered if this application is approved.

FOP Significant Revision FOP Minor Application for an FOP Revision

Operational Flexibility/Off-Permit Notification Streamlined Revision for GOP

To be Determined None




III. Type of Permit Action Requested (continued)

H. Federal Operating Permit Requirements (30 TAC Chapter 122 Applicability) (continued)

Identify the type(s) of FOP(s) issued and/or FOP application(s) submitted/pending for the site. (check all that apply)

GOP Issued GOP application/revision application submitted or under APD review

SOP Issued SOP application/revision application submitted or under APD review

IV. Public Notice Applicability

A. Is this a new permit application or a change of location application? YES NO

B. Is this application for a concrete batch plant? If Yes, complete all parts of V.D. YES NO

C. Is this an application for a major modification of a PSD, nonattainment, FCAA § 112(g) permit, or exceedance of a PAL permit?

YES NO

D. If this is an application for emissions of GHGs, select one of the following:

separate public notice (requires a separate application) consolidated public notice

E. Is this application for a PSD or major modification of a PSD located within 100 kilometers or less of an affected state or Class I Area?

YES NO

If Yes, list the affected state(s) and/or Class I Area(s).

List:

F. Is this a state permit amendment application? If Yes, complete all parts of IV.F.

Is there any change in character of emissions in this application? YES NO

Is there a new air contaminant in this application? YES NO

Do the facilities handle, load, unload, dry, manufacture, or process grain, seed, legumes, or vegetables fibers (agricultural facilities)?

YES NO

List the total annual emission increases associated with the application (List all that apply and attach additional sheets as needed):

Volatile Organic Compounds (VOC): 13.68 tpy

Sulfur Dioxide (SO2): 0.80 tpy

Carbon Monoxide (CO): 15.47 tpy

Nitrogen Oxides (NOx): -0.11 tpy

Particulate Matter (PM): 0.08 tpy

PM 10 microns or less (PM10): 0.08 tpy

PM 2.5 microns or less (PM2.5): 0.08 tpy

Lead (Pb):

Hazardous Air Pollutants (HAPs):

Other speciated air contaminants not listed above: H2S: -0.01; NH3: -0.05




V. Public Notice Information (complete if applicable)

A. Responsible Person: ( Mr. Mrs. Ms. Other:)

Name: Lisa Reaves


Company Name: MarkWest Javelina Company LLC





B. Technical Contact: ( Mr. Mrs. Ms. Other:)

Name: Lisa Reaves






C. Name of the Public Place: La Retama Central Library

Physical Address (No P.O. Boxes): 805 Comanche Street

City: Corpus Christi County: Nueces ZIP Code: 78401

The public place has granted authorization to place the application for public viewing and copying. YES NO

The public place has internet access available for the public. YES NO

D. Concrete Batch Plants, PSD, and Nonattainment Permits

County Judge Information (For Concrete Batch Plants and PSD and/or Nonattainment Permits) for this facility site.

The Honorable:

Mailing Address:

City: State: ZIP Code:

mailto:[email protected]:[email protected]

TCEQ-10252 (APDG 5171v39, Revised 04/18). PI-1 This form is for use by facilities subject to air quality requirements and may be revised periodically.



V. Public Notice Information (complete if applicable)

D. Concrete Batch Plants, PSD, and Nonattainment Permits (continued)

Is the facility located in a municipality or an extraterritorial jurisdiction of a municipality? (For Concrete Batch Plants)

YES NO

Presiding Officers Name(s):

Title:

Mailing Address:


Provide the name, mailing address of the chief executive for the location where the facility is or will be located.

Chief Executive:

Mailing Address:


Provide the name, mailing address of the Indian Governing Body for the location where the facility is or will be located.

Indian Governing Body:

Mailing Address:


Identify the Federal Land Manager(s) for the location where the facility is or will be located.

Federal Land Manager(s):

E. Bilingual Notice

Is a bilingual program required by the Texas Education Code in the School District? YES NO

Are the children who attend either the elementary school or the middle school closest to your facility eligible to be enrolled in a bilingual program provided by the district?

YES NO

If Yes, list which languages are required by the bilingual program?

VI. Small Business Classification (Required)

A. Does this company (including parent companies and subsidiary companies) have fewer than 100 employees or less than $6 million in annual gross receipts?

YES NO

B. Is the site a major stationary source for federal air quality permitting? YES NO

C. Are the site emissions of any regulated air pollutant greater than or equal to 50 tpy? YES NO

D. Are the site emissions of all regulated air pollutants combined less than 75 tpy? YES NO




VII. Technical Information

A. The following information must be submitted with your Form PI-1 (this is just a checklist to make sure you have included everything)

Current Area Map Plot Plan

Existing Authorizations

Process Flow Diagram

Process Description

Maximum Emissions Data and Calculations

Air Permit Application Tables

Table 1(a) (Form 10153) entitled, Emission Point Summary

Table 2 (Form 10155) entitled, Material Balance

Other equipment, process or control device tables

B. Are any schools located within 3,000 feet of this facility? YES NO

C. Maximum Operating Schedule:

Hour(s): 24 Day(s): 7

Week(s): 52 Year(s): N/A

Seasonal Operation? If Yes, please describe in the space provide below. YES NO

Hour(s): Day(s):

Week(s): Year(s):

D. Have the planned MSS emissions been previously submitted as part of an emissions inventory?

YES NO

Provide a list of each planned MSS facility or related activity and indicate which years the MSS activities have been included in the emissions inventories. Attach pages as needed.

MSS Facility(s) or Activity Year(s)

E. Does this application involve any air contaminants for which a disaster review is required? YES NO

If Yes, list which air contaminants require a disaster review.




VII. Technical Information (continued)

F. Does this application include a pollutant of concern on the Air Pollutant Watch List (APWL)? YES NO

G. Are emissions of GHGs associated with this project subject to PSD? YES NO

If “yes,” provide a list of all associated applications for this project:

VIII. State Regulatory Requirements Applicants must demonstrate compliance with all applicable state regulations to obtain a permit or amendment. The application must contain detailed attachments addressing applicability or non-applicability; identify state regulations; show how requirements are met; and include compliance demonstrations.

A. Will the emissions from the proposed facility protect public health and welfare, and comply with all rules and regulations of the TCEQ?

YES NO

B. Will emissions of significant air contaminants from the facility be measured? YES NO

C. Is the Best Available Control Technology (BACT) demonstration attached? YES NO

D. Will the proposed facilities achieve the performance represented in the permit application as demonstrated through recordkeeping, monitoring, stack testing, or other applicable methods?

YES NO

IX. Federal Regulatory Requirements Applicants must demonstrate compliance with all applicable federal regulations to obtain a permit or amendment. The application must contain detailed attachments addressing applicability or non-applicability; identify federal regulation subparts; show how requirements are met; and include compliance demonstrations.

A. Does Title 40 Code of Federal Regulations Part 60, (40 CFR Part 60) New Source Performance Standard (NSPS) apply to a facility in this application?

YES NO

B. Does 40 CFR Part 61, National Emissions Standard for Hazardous Air Pollutants (NESHAP) apply to a facility in this application?

YES NO

C. Does 40 CFR Part 63, Maximum Achievable Control Technology (MACT) standard apply to a facility in this application?

YES NO

D. Do nonattainment permitting requirements apply to this application? YES NO

E. Do prevention of significant deterioration permitting requirements apply to this application? YES NO

F. Do Hazardous Air Pollutant Major Source [FCAA § 112(g)] requirements apply to this application?

YES NO

G. Is a Plant-wide Applicability Limit permit being requested? YES NO

X. Professional Engineer (P.E.) Seal

Is the estimated capital cost of the project greater than $2 million dollars? YES NO

If Yes, submit the application under the seal of a Texas licensed P.E.

PERMIT 19296 RNCN

Review of applications and issuance of permits will be expedited by supplying all necessary information requested on this Table.

EAST NORTH DIA. VEL. TEMP. LENGTHWIDT

H AXIS

EPN FIN NAME [meters] [meters] [ft.] [ft.] [ft.] [fps] [°F] [ft.] [ft.]DEG

.1 HTR-1 Mol Sieve Heater CO 0.70 3.08 14 651854 3076480 50 1.2 50 325

NOx 1.17 5.13PM/PM10 0.09 0.38SO2 0.16 0.72VOC 0.06 0.28

2 HTR-2 Regeneration Heater CO 0.36 1.60 14 651854 3076474 0 50 0.83 54.5 325NOx 0.61 2.66PM/PM10 0.05 0.20SO2 0.09 0.37VOC 0.03 0.14

3, BLR-21, BLR-22 3, BLR-21, BLR-22 Boilers CAP CO - 39.48 na naNOx - 42.98PM/PM10 - 3.87SO2 - 8.31VOC - 2.94

4 4 SRU Incinerator CO 0.46 2.02 14 651948 3076354 100 0.3 104 110H2S 0.002 0.01NOx 0.27 1.20PM/PM10 0.04 0.18SO2 0.50 2.18VOC 0.03 0.13

5 FLR-5 Flare CO 1109.78 46.22 14 651955 3076354 308 2.5 165 1200NH3 41.01 0.08H2S 33.45 0.05NOx 454.78 11.91SO2 2260.83 5.79VOC 1555.00 31.26

FUG-6 FUG-6 Fugitive Emissions VOC 10.21 44.74 500 1000 07 7 Cooling Tower PM10 1.20 5.28 651851 3076759 108 54 0

PM2.5

PERMIT 19296 RNCN

Review of applications and issuance of permits will be expedited by supplying all necessary information requested on this Table.

EAST NORTH DIA. VEL. TEMP. LENGTHWIDT

H AXIS

EPN FIN NAME [meters] [meters] [ft.] [ft.] [ft.] [fps] [°F] [ft.] [ft.]DEG

.TONS/YR

TABLE 1(a) Emission Point Summary

ZONE

COMPONENT OR AIR

CONTAMINANT NAME

Air Contaminant emission rate

UTM COORDINATES OF EMISSION POINT

AIR CONTAMINANT DATA EMISSION POINT DISCHARGE PARAMETERS

EMISSION POINT

Date: May 2018Area Name: Javelina Gas Processing Facility

ACCOUNT NE-0253-K

SOURCE

102190139

#/HR

603319880

Building Height

Height Above Ground

STACK EXIT DATA FUGITIVES

DEGAS DEGAS Post-Control Degassing Emissions VOC 574.40 0.72 500 1000 0

IGC VENT1 IGC VENT1

Vent from Inlet Gas Compressors A, B, and C rod packing, Stage 1 VOC

1.12 2.17 14

IGC VENT2 IGC VENT2

Vent from Inlet Gas Compressors A, B, and C rod packing, Stage 2 VOC

1.12 2.17 14

LIST EVERY MATERIAL INVOLVED IN EACH OF THE FOLLOWING GROUPS

No. from Plot Plan

mea

sure

men

t

estim

ate

calc

ulat

ion

Refinery Offgas 140 MMSCFD X

Fuel Gas 272.51 MMBtu/hr X

Residue Gas 100 MMSCFD XHydrogen Gas 30 MMSCFD XEthylene 30,000 lbs/hr XEthane 65,000 lbs/hr XPropylene 12,000,000 lbs/month XPropane 25,000,000 lbs/month XButanes 17,000,000 lbs/month XPentanes 13,000,000 lbs/month XSulfur 7,533.33 lbs/month XDSO 6 lbs/hr X

Please see Table 1(a) X

Please see Table 1(a) X

Airborne waste solid - output

Airborne waste gaseous - output

Raw materials - Inputs

Fuels - Input

Products and by-products - output

Solid wastes - output

Liquid wastes - output

TEXAS COMMISSION ON ENVIRONMENTAL QUALITYTABLE 2

MATERIAL BALANCE

This material balance table is used to quantify possible emissions of air contaminants and special emphasis should be placed on potential air contaminants, for example: If feed contains sulfur,show distribution to all products. Please relate each material (or group of materials) listed to its respective location in the process flow diagram by assigning point numbers (taken from the flow diagram) to each material.

Process Rate

3-1

3. Area Map and Plot Plan

Figure 3-1 is an area map showing 3,000-feet and one-mile distance markings. The area map

is derived from the Corpus Christi, Texas USGS 7.5-minute series topographical map. The plot

plan for the Javelina Gas Processing Facility is also contained in Section 3.

There are no schools within 3,000 feet of the facilities.

Figure 3-1. Javelina Gas Processing Facility - Area Map

650,000 651,000 652,000 653,000

3,078,000 3,078,000

3,077,000 3,077,000

0

3,076,000 3,076,000

3,075,000 3,075,000

650,000 651,000 652,000 653,000

UTMEaot(m)Edge Markings in UTM Coordinates (Zone 14)

0 1,000 2,000 3,000 4,000

Feet

5,000

.

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4-1

4. Process Description

Javelina Gas Processing Facility is unique and functions as a reuse/recovery operation that

ultimately provides waste minimization and emissions reduction in the area by processing

refinery off-gas from several facilities in the Corpus Christi area. Excess off-gas at the refineries,

if not beneficially used, would have to be flared. The Javelina facility processes refineries off-

gas, recovers various useful products, and the residue gas is returned to the refineries as clean

fuel gas.

Refinery off-gases from Corpus Christi area refineries are delivered via pipeline to the Javelina

Gas Processing Facility, and the gases are further processed. MarkWest produces LPG, which

is primarily sent off site via pipeline. This section contains a process flow diagram, which

outlines the primary equipment at the site. This application includes an update of the piping

components such as valves, connectors, and compressors, based on a recent retagging of

equipment.

Additionally, routine maintenance occurs at the Javelina Gas Processing Facility to ensure

equipment is operating properly and control devices are operating properly to minimize

emissions and ensure compliance with permitted limits. MarkWest authorized many of its MSS

activities in the December 2014 amendment to Permit Number 19296; however, MarkWest has

since identified additional activities to authorize in its permit. Thus, additional activities and

routine maintenance on additional process equipment is represented in this amendment

application. Process equipment and other routine maintenance that may occur at MarkWest

include, but are not limited to, the following examples:

• Maintenance/catalyst change/cleaning of process vessels and associated piping and

other equipment and activities, such as:

o Acetylene unit

o Butylene conversion unit

o Ethylene and propane refrigeration systems

o C4 reactor

o C5 HDS unit

o Demethanizer unit

o Deethanizer/C2 splitter

4-2

o Depropanizer/C3 splitter

o E/E treaters

o P/P treaters

o Expander

o Mercury guard bed

o Gas compressor areas

o Scrubbers and separators

o Dehy units

o Meter provings

o Maintenance of all pumps and valves

o Sulfurox unit and incinerator

o Amine regeneration and tail gas treating areas

o Various filters

o PSA unit

o Exchangers and coolers

o Cryo Unit

o VRU

o Fuel gas system

o Flare pilot

o Heaters

o Wastewater and storm water system maintenance

o Filter maintenance

o Prover trailer and meters

o Pipeline clearing and rebalancing, and

o Pig launching for maintenance.

Further, many routine MSS activities are controlled in MarkWest’s flare, which has continuous

monitoring. MarkWest is submitting this amendment application to update permitted emission

limits to more accurately represent reasonable worst-case flare emissions. In addition,

MarkWest’s permit currently authorizes 876 hours of sulfur recovery incinerator bypass. During

these periods, the waste gases are routed to the flare, and MarkWest is representing these

flaring emissions. Markwest’s current permit also includes off-gas flaring from the neighboring

Air Products facility. MarkWest proposes to simplify the permit structure outlined in the

Maximum Allowable Emissions Rate Table, which provides for four separate emission limits for

4-3

the flare. Currently, the permit contains separate emission limits for routine MarkWest

emissions, MSS emissions from activities conducted at MarkWest, Air Products emissions, and

MarkWest startup and turnaround emissions. MarkWest contends that the four emission limits

for the EPN presents unique recordkeeping challenges, since the four limits apply to the same

EPN, and multiple limits may apply simultaneously. MarkWest, therefore, requests a simplified

permit structure, the specifics of which are outlined in Sections 6 and Appendix A.

Prior to conducting maintenance on a facility such as a process vessel, it must be cleared,

purged, and degassed. MarkWest previously permitted vessel purging, which is controlled by

the site’s flare. In accordance with TCEQ control requirements for MSS, vessel purging and

degassing is controlled to 10% Lower Explosive Limit (LEL). The residual VOCs that are

contained in the vessel may be vented to atmosphere, and MarkWest identified that these VOC

emissions are not currently included in its air permit. MarkWest is amending its permit to

authorize the degassing emissions and ensure that its permit comprehensively includes the

appropriate emissions associated with routine MSS. Markwest conducted a comprehensive

retag effort for fugitive components throughout the facility. This permit amendment application

also includes the updated component counts to appropriately represent as-built operation and

its associated emissions.

5-1

5. Process Emissions This section describes the emission calculation methods associated with this permit amendment

application.

Flare Emissions

This amendment application includes updated flare emission calculations. The emissions are

based on historical flare CEMs data from 2014 through 2017, with a 15% safety factor included.

Site-wide plant startup/shutdown/turnaround (TAR) emissions were based on a full shutdown

scenario, with three nitrogen purges to 10% LEL. Flare data from shutdown events occurring in

2016 were also evaluated, which included a shutdown for Hurricane Harvey and two additional,

smaller-scaled shutdown/maintenance events, with a 15% safety factor. The emissions for TAR

are established with the higher of the TAR full shutdown calculation, 2016 flare data, or permit

limits established in the current permit. The overall flare limits are proposed by summing all

potential events on an annual basis. Hourly limits were established by taking the higher of

hourly routine emissions that may occur or plantwide MSS emissions.

Fugitive Emissions

Fugitive emission rates of VOC from the piping components and ancillary equipment are

estimated using the methods outlined in the TCEQ’s Air Permit Technical Guidance for

Chemical Sources: Fugitive Guidance, December 2017. Each fugitive component is classified

first by equipment type (valve, pump, connector, etc.) and then by material type (gas/vapor, light

liquid, heavy liquid). An uncontrolled hourly VOC emission rate is obtained by multiplying the

number of fugitive components of a particular equipment/material type by the appropriate

SOCMI emission factor. To obtain controlled fugitive emission rates, the uncontrolled rates are

multiplied by a control factor. MarkWest historically employed the TCEQ’s 28 M LDAR program

and is currently using EPA’s approved Alternate Work Practice (AWP) that enhances the LDAR

program using Optical Gas Imaging (OGI). EPA has incorporated OGI in the promulgated

regulations (e.g. 40 Code of Federal Regulations Part 60, Subparts OOOO and OOOOa). OGI

can detect leaks for VOC and Greenhouse gases. MarkWest uses OGI on a bi-monthly basis,

and any leak detected is then followed by Method 21 monitoring to confirm and take corrective

actions for any VOC leaks. This practice includes difficult to monitor components. Markwest’s

LDAR contractor is working with TCEQ for approval of OGI as an AWP. The emissions in this

application represent the implementation of TCEQ’s 28 VHP LDAR program. In addition,

5-2

MarkWest monitors and identifies leaks for repair for connectors on an annual basis. As such,

28 CNTA control credits are applied to the connectors and 28 VHP control credits are applied to

the other fugitive components. Stream speciation is applied to determine the hourly emissions.

Annual fugitive emission calculations are based on 8,760 hours of service. Pumps with dual

tandem seals with vapor barrier vents to flare that are alarmed are exempt from monitoring and

100% reduction credit is taken. Inlet Gas Compressor D rod packings are vented to the flare,

and a 100% reduction credit is also taken on those components. Additionally, the refrigerant

compressors are contained in a closed loop system with no emissions to the atmosphere, and

100% credit is taken on those components. The Inlet Gas Compressors’ 1st stage and 2nd stage

rod packing are routed to two separate pipe vents, IGC Vent 1 and IGC Vent 2. Over time, the

rod packings have potential to leak. MarkWest has added these two EPNs in the permit

amendment application. The emission are estimated based on flow rate measured for the

Greenhouse gas (GHG) reporting and using expected worst case short-term and average

compositions for hourly and annual calculations.

Process Heater Emissions

Emissions of PM10 and VOC from the Molecular Sieve and Regeneration Heaters are based on

AP-42 emission factors. CO and NOX emissions from the Butylene Converter are also based on

AP-42. SO2 emissions are based on combustion of gas containing 0.05 grains sulfur per dry

standard cubic feet. Assuming all of the sulfur is converted to SO2 during combustion, 1 lb-

mole of sulfur in the fuel yields 1 lb-mole of SO2 out of the stack. The molar flow rate of SO2 out

of the stack is then multiplied by the molecular weight of SO2 to obtain the hourly emission

rates. Annual emission rates are based on the average heat input and 8,760 hours per year.

Boiler Emissions

Boiler emissions remain as represented in the current permit and Maximum Allowable Emission

Rate Table (MAERT).

Cooling Tower Emissions

The cooling tower is an existing facility, and PM10 and PM2.5 emissions are represented in the

application per TCEQ guidance. Historically, TCEQ was not including PM emissions from the

cooling towers. The PM10 and PM2.5 emissions are estimated using the methodology provided in

5-3

the Reisman and Frisbie paper entitled “Calculating Realistic PM10 Emissions from Cooling

Towers.” Detailed calculations are provided in Appendix A.

The recirculation rate and the current BACT limit of 0.08 ppmw are the basis for the hourly and

annual emissions of VOC. Markwest is not requesting any change from the current MAERT.

Please note, that currently the cooling tower has a VOC leak. As discussed in prior

conversations with TCEQ, Air Permit Division, the corrective action will require a plant wide

shutdown, which will result in emissions more than current cooling tower emissions. Therefore,

the cooling tower is under a delay of repair. The cooling water exchanger system upstream of

the cooling tower was sampled to identify potential leak locations. MarkWest has already

purchased four (4) replacement exchangers which are being stored on site. Two (2) additional

exchangers will be replaced or repaired. All exchanger work will be addressed during the next

scheduled turnaround. Meanwhile, MarkWest is continuing to sample the cooling tower on a

monthly basis.

Sulfur Recovery Incinerator Emissions

Vendor-specific data and AP-42 factors are used to estimate the emissions from the sulfur

recovery incinerator. Detailed calculations are provided in Appendix A.

6-1

6. Best Available Control Technology Evaluation A BACT analysis is required since this permitting application includes an amendment. No

modifications have been proposed, and this permit application is for all existing equipment and

facilities. This section contains a summary of the BACT analysis. BACT is established

pursuant to the TCEQ’s three-tiered BACT review. Tier I BACT consists of the level of control

technology currently accepted and established as BACT through permit reviews for that type of

facility in the same industry. Tier II BACT consists of the level of control technology currently

accepted as BACT in recent permits for similar air emissions streams in a different industry.

Tier III BACT is a detailed technical and quantitative economic analysis of all emission reduction

options available for the process under review. For the types of facilities covered by this

application, current Tier I BACT can be identified by examining current TCEQ air permit

technical guidance documents.

Flare The flare was designed to meet the standards in 40 Code of Federal Regulations §60.18.

Further, MarkWest monitors the flow of vent gas to the flare, BTU content, ammonia, and

monitors H2S and hydrocarbons with a GC. A 98% control efficiency for all hydrocarbons is

conservatively represented. Therefore, BACT is met.

Fugitives

Markwest, through consultant, is working with TCEQ for approval of Optical Gas Imaging (OGI)

as an Alternative Work Practice (AWP) for the Texas LDAR program. Upon issuance of this

amendment, MarkWest will employ 28 VHP, which is current TCEQ BACT. Additionally,

MarkWest will conduct annual monitoring of connectors.

Process Heaters

The adjustments in the emissions calculations results in an increase in VOC emissions for the

Molecular Sieve Heater and Regeneration Heater. Following good combustion practices will

minimize VOC and represents BACT for the heaters. Small increases are also represented for

the Butylene Converter. This heater is less than 4 MMBtu/hr, and TCEQ prescribes BACT for

heaters greater than 40 MMBtu/hr.

6-2

Sulfur Recovery Incinerator

The permit amendment includes slight emissions increases for the sulfur recovery incinerator. It

does not appear that the last permit renewal properly represented the facility’s heater duty, and

the emission calculations have been corrected. The minimum inlet gas flowrate remains

unchanged, and the facility is not increasing production. The incinerator continues to represent

99% efficiency, which reflects BACT given the facility’s age.

MSS

Equipment is purged to 10% LEL, and gas streams resulting from MSS activities and equipment

purging are controlled by the flare. Current TCEQ guidelines indicate that BACT for MSS is the

same as current BACT requirements for flares. Since BACT for flares is met, BACT for MSS is

also met.

7-1

7. Federal NSR Applicability The Javelina Gas Processing Facility is located in Nueces County, which is an attainment or

unclassified area for all pollutants. Therefore, Nonattainment NSR permitting does not apply.

MarkWest has calculated the emission increases for all affected sources. The site is an existing

minor source, and PSD would be required if the project increase meets major source

thresholds. The requested emission rates from all affected sources are below major source

thresholds, therefore PSD review is not required.

8-1

8. General Application Requirements

Pursuant to 30 TAC § 116.111, MarkWest proposes to meet all rules and regulations of

the TCEQ and the intent of the Texas Clean Air Act (TCAA) for the proposed changes

addressed in this permit amendment application as follows:

8.1 Protection of Public Health and Welfare - 30 TAC § 116.111(a)(2)(A)(i)

As outlined below, the emissions from the facilities comply with all air quality rules and

regulations and with the intent of the TCAA, including protection of the health and physical

property of the people.

8.1.1 Chapter 101 - General Rules

The facility will be operated in accordance with the General Rules relating to circumvention,

nuisance, traffic hazard, notification requirements for major upsets, notification requirements for

maintenance, sampling, sampling ports, emissions inventory requirements, sampling

procedures and terminology, compliance with Environmental Protection Agency standards, the

National Primary and Secondary Air Quality Standards, inspection fees, emissions fees and all

other applicable General Rules.

8.1.2 Chapter 111 - Visible Emissions and Particulate Matter

The operation of this facility may result in occasional visible emissions. Any emissions that

occur in excess of the opacity limits specified in 30 TAC § 111.111 will be reported to the TCEQ

in compliance with the Chapter 101 emission and opacity event reporting requirements.

8.1.3 Chapter 112 - Sulfur Compounds

The sources being permitted will not contribute to an exceedance of the net ground level

concentrations specified by 30 TAC § 112.3, § 112.31, or § 112.32.

8.1.4 Chapter 113 - Toxic Materials

This chapter does not apply to the MarkWest Javelina Gas Processing Facility.

8-2

8.1.5 Chapter 114 - Motor Vehicles

There are no motor vehicles specifically associated with the units in this permit application. To

the extent that motor vehicles are owned by MarkWest, the company will continue to comply

with applicable requirements in 30 TAC § 114.20.

8.1.6 Chapter 115 - Volatile Organic Compounds (VOC)

Chapter 115 does not apply to the facilities addressed in this amendment application.

8.1.7 Chapter 117 - Nitrogen Compounds

Chapter 117 does not apply to the facilities addressed in this amendment application.

8.1.8 Chapter 118 - Air Pollution Episodes

The sources included in this permit application will be operated in compliance with the

generalized and localized air pollution episode rules.

8.1.9 Chapter 122 – Federal Operating Permits

MarkWest is not a major source and is not required to obtain a Title V Federal Operating Permit.

8.2 Impact on Schools - 30 TAC § 116.111(a)(2)(A)(ii)

There are no schools within 3000 feet of the facilities associated with this amendment.

8.3 Measurement of Emissions - 30 TAC § 116.111(a)(2)(B)

MarkWest has flow monitoring, ammonia monitoring, and a GC to monitor BTU and

hydrocarbons sent to the flare. The system calculates flare emissions on continuous basis

based on destruction efficiency.

8.4 Best Available Control Technology - 30 TAC § 116.111(a)(2)(C)

As described in Section 6 of this application, the facilities meet best available control technology

(BACT).

8-3

8.5 New Source Performance Standards (NSPS) - 30 TAC § 116.111(a)(2)(D)

New Source Performance Standards do not apply to the facilities addressed in this permit

amendment application. The Javelina Gas Processing Facility complies with 40 Code of Federal

Regulation Part 60, Subpart VV.

8.6 National Emissions Standards for Hazardous Air Pollutants - 30 TAC

§ 116.111(a)(2)(E)

These standards do not apply to the facilities addressed in this permit amendment application.

The Javelina Gas Processing Facility complies with 40 Code of Federal Regulation Part 61,

Subpart M.

8.7 NESHAPS for Source Categories - 30 TAC § 116.111(a)(2)(F)

These standards do not apply to the facilities addressed in this permit amendment application.

The Javelina Gas Processing Facility complies with 40 Code of Federal Regulation Part 63,

Subpart ZZZZ.

8.8 Performance Demonstration - 30 TAC § 116.111(a)(2)(G)

This facility will perform as represented in the application and as required by the permit.

8.9 Nonattainment Review - 30 TAC § 116.111(a)(2)(H)

Nueces County is an attainment/unclassified area for all pollutants. Nonattainment new source

review requirements do not apply.

8.10 Prevention of Significant Deterioration (PSD) Review – 30 TAC

§ 116.111(a)(2)(I)

PSD does not apply. See Section 7 for a detailed discussion of PSD permit review applicability.

8.11 Air Dispersion Modeling – 30 TAC § 116.111(a)(2)(J)

8-4

A Screen3 modeling analysis for the PM10 and PM2.5 emissions from the cooling tower are

contained in Appendix D. Additional air quality analysis, if required by TCEQ, will be submitted

upon request.

8.12 Hazardous Air Pollutants – 30 TAC § 116.111(a)(2)(K)

These requirements do not apply to the MarkWest Javelina Gas Processing Facility.

8.13 Mass Cap and Trade Allowances – 30 TAC § 116.111(a)(2)(L)

The requirements of Chapter 101, Subchapter H, Division 3 do not apply to this site.

Appendix A _______________________________________________________________________

Detailed Emission Calculations

MarkWest Javelina Gas Processing Facility Air Permit 19296 Amendment, May 2018

Table A-1 MOLECULAR SIEVE HEATER (EPN 1)

EPN 1DescriptionHeat Input 11.72 MMBtu/hrSCF/Hr 11490 scf/hrRuntime 8760 hr/yrFuel Type Fuel Value 1020 Btu/scf

Pollutant Short Term (lb/hr)Annual

(tpy)

CO1 0.06 lb/MMBtu 0.70 3.08NOx

1 0.10 lb/MMBtu 1.17 5.13PM/PM10/PM2.5

2 0.0075 lb/MMBtu 0.09 0.38SO2

3 0.0140 lb/MMBtu 0.16 0.72VOC2 0.0054 lb/MMBtu 0.06 0.28

1. Emission factor obtained from vendor data.2. Emission factor obtained from AP-42, Section 1.4, Table 1.4-2.3. Natural gas delivery specification for sweet gas.

SAMPLE CALCULATIONS (Same calculation methodology applies to every criteria pollutant):

Example, Annual Emissions of NOx:Total Annual Emissions of NOx = (lb/MMBtu) x (MMBtu/hr) x (1/2000 tons/lb) x 8760 hr

Mol Sieve Heater

Natural Gas

Natural Gas Emission Factor


Table A-2 REGENERATION HEATER EMISSIONS (EPN 2)

EPN 2DescriptionHeat Input 6.07 MMBtu/hrRuntime 8760 hr/yrSCF/Hr 5951 scf/hrFuel Type Fuel Value 1020 Btu/scf

Pollutant Short Term (lb/hr)Annual

(tpy)CO1 0.06 lb/MMBtu 0.36 1.60NOx

1 0.10 lb/MMBtu 0.61 2.66PM/PM10/PM2.5

2 0.0075 lb/MMBtu 0.05 0.20SO2

3 0.0140 lb/MMBtu 0.09 0.37VOC2 0.0054 lb/MMBtu 0.03 0.141. Emission factor obtained from vendor data.2. Emission factor obtained from AP-42, Section 1.4, Table 1.4-2.3. Natural gas delivery specification for sweet gas.

SAMPLE CALCULATIONS (Same calculation methodology applies to every criteria pollutant):

Example, Annual Emissions of NOx:Total Annual Emissions of NOx = (lb/MMBtu) x (MMBtu/hr) x (1/2000 tons/lb) x 8760 hr

Regeneration Heater

Natural Gas



Table A-4 SULFUR RECOVERY INCINERATOR EMISSIONS (EPN 4)

EPN 4 Manufacturers design specification Heat Load.Description Incinerator Heat Duty @1500 F 5,032,956 BTU/hrFuel Type Waste Heat Flow 3,912 lb/hrMax Inlet Gas Flowrate 140,000,000 scfd 140 MM Waste Heat LHV 2 BTU/lbMax CO2 % into plant 0.7 % Fuel Heat Flow 207 lb/hrIncinerator Efficiency 99 % Fuel Heat LHV a 24,276 BTU/lbMax H2S Concentration from Sulferox5 50 ppm * Based on Incinerator DesignIncinerator Duty @ 1500F 5,032,956 Btu/hr a. Based on AP-42 density of natural gas 23.8 ft3/lbHours of operation 8760 hr/yr

PollutantNatural Gas

Emission Factor (lb/MMBtu)

Hourly (lb/hr) Annual (tpy)

CO1,4 0.0915 0.46 2.02 Max Inlet 140000 MCFH2S -- 0.002 0.01 Incin Gas Flow 980000 ft3/dayNOx

1,4 0.054 0.27 1.20 Exhaust Temp 520 RPM/PM10/PM2.5

2, 4 0.0083 0.04 0.18 H2S MW 34.08 lb/lb-molSO2

natural gas (pilot and burner)3 0.05 gr S/scf 0.07 0.31 Atm Pressure 14.7 psiSO2 waste gas -- 0.427 1.87 H2S Concentration 50 ppmVOC2,4 0.0060 0.030 0.13 I G Const. 10.73 ft3 psi R−1 lb-mol−1

Total H2S Waste stream to Incinerator 2.04 scfhH2S to Incinerator 0.23 lb/hr Include 25% contingencySO2 Emissions 0.427 lb/hr

2. Emission factor obtained from AP-42, Section 1.4, Table 1.4-2.3. Natural gas delivery specification for sweet gas.4. Vendor data uses LHV, and emission factors are adjusted to HHV using AP-42 factors and Appendix A.1.3 of API Publication dated August 2009, which specifies that emission factors at low heating value = emission factors at high heating value/0.9.5. H2S Concentration of 50 ppm is Treated Gas Specification guaranteed by Dow Gas Spec.

SAMPLE CALCULATIONS:

Annual Emissions of SO2 (from waste gas combustion):Annual Emissions of SO2 (from waste gas combustion) = max H2S lb/hr * mole ratio SO2/H2S

Total Annual Emissions of NOx for Sulfur Recovery Incinerator (EPN 4) = 50 lbs/106 *1/1020btu/scf/.90 *5032956btu/hr*8760 hrs*1/2000 ton/lb

1. Emission factor obtained from AP-42, Section 1.4, Table 1.4-1

Waste Gas Incineration

Sulfur Recovery IncineratorNatural Gas

Annual Emissions of NOx (same methodology applies to CO, VOC, PM, PM10, PM2.5, and SO2 [from natural gas combustion and converting to high heating value emission factor per footnote 4]):

MarkWest Javelina Gas Processing Facility Air Permit 19296 Amendment, May 2018 Table A‐5, Flare Emissions Summary

EPN 5

(lb/hr) 1 (tpy) 2 (lb/hr) 1 (tpy) 2 (lb/hr) 1 (tpy) 2 (lb/hr) 1 (tpy) 2 (lb/hr) 1 (tpy) 2 (lb/hr) 1 (tpy) 2

Inlet Gas Compressor 41.42 0.16 4.83 0.022 48.53 0.12 0.06 0.00 0.00 0.00 5.71 0.01IG Dehydrator 68.27 2.90 8.01 0.08 11.15 0.23 0.00 0.00 0.00 0.00 0.00 0.00Regen Dehydrator 19.97 0.48 2.33 0.06 6.86 0.15 0.00 0.00 0.00 0.00 4.59 0.00Mercury Guard Bed 15.58 0.02 2.35 0.00 8.76 0.01 0.00 0.00 0.00 0.00 0.00 0.00Pump Maintenance 17.50 0.64 8.77 0.22 90.14 4.71 0.00 0.00 0.00 0.00 0.00 0.00E/E System 38.13 0.30 4.45 0.03 7.37 0.06 0.01 0.00 0.00 0.00 0.62 0.00P/P System 18.07 0.27 7.62 0.04 49.73 0.15 0.00 0.00 0.00 0.00 0.00 0.02Butylene Conversion Unit 110.71 0.38 13.00 0.06 71.27 0.28 16.23 0.01 0.00 0.00 756.05 0.51Aceylene Unit 31.19 0.55 5.04 0.08 44.04 0.38 0.02 0.00 0.00 0.00 1.59 0.00C5/HDS 31.11 0.46 7.96 0.05 37.21 0.31 0.05 0.00 0.00 0.00 4.29 0.00Meter Provings 53.94 0.16 6.29 0.04 44.69 0.18 0.00 0.00 0.00 0.00 0.00 0.00Refrigeration Systems 19.63 0.10 9.83 0.03 17.05 0.05 0.00 0.00 0.00 0.00 0.00 0.00Demethanizer 90.55 0.95 10.63 0.14 42.22 0.33 0.00 0.00 0.00 0.00 0.00 0.00Expander 7.57 0.06 3.35 0.01 23.04 0.06 0.00 0.00 0.00 0.00 0.27 0.00VRU 4.08 0.00 0.48 0.00 2.48 0.00 0.00 0.00 0.00 0.00 0.00 0.00IG Scrubber 9.20 0.01 1.08 0.00 4.05 0.00 0.00 0.00 0.00 0.00 0.00 0.00Cryo Unit 66.43 0.13 7.80 0.07 48.79 2.16 0.00 0.00 0.00 0.02 0.00 0.00Flare Pilot Maintenance 26.65 0.03 3.13 0.00 14.32 0.01 0.01 0.00 0.00 0.00 1.32 0.00Exchanger Repair 91.28 0.75 34.33 0.16 75.12 0.49 0.00 0.00 0.00 0.00 0.00 0.00Vessel Decant 4.94 0.06 1.61 0.01 3.70 0.49 0.02 0.00 0.00 0.00 1.59 0.01Pipeline clearing/MSS prep/rebalance 123.77 0.28 14.53 0.04 13.45 0.08 0.00 0.00 0.00 0.00 0.00 0.00Pigging Operations 436.03 0.58 51.19 0.07 44.77 0.12 0.00 0.00 0.00 0.00 0.00 0.00WW Equipment Maintenance 23.83 0.22 2.80 0.03 8.85 0.07 0.08 0.00 0.00 0.00 7.19 0.02PSA Unit 216.11 1.41 270.14 0.17 42.56 0.26 0.00 0.00 31.51 0.00 0.00 0.00Filter maintenance 17.18 0.01 2.02 0.00 12.22 0.00 0.00 0.00 0.00 0.00 0.00 0.00Incinerator Downtime/Maintenance 86.04 5.97 10.10 0.85 11.30 2.89 9.86 0.03 0.00 0.00 927.43 2.52Ongoing, Routine MSS Totals (above) 2 886.62 16.88 370.19 2.25 286.26 13.60 26.23 0.04 31.51 0.02 1696.38 3.10Add 15% Contingency 3 1019.62 19.41 425.72 2.58 329.20 15.64 30.16 0.04 36.23 0.03 1950.84 3.56Normal Operations Total 1 5.83 10.28 0.93 1.23 3.66 6.91 0.00 0.00 0.00 0.00 0.06 0.01Flaring Off‐spec Gas 13.97 0.03 1.64 0.02 52.11 0.90 3.29 0.00 0.45 0.01 309.79 0.18Flare ‐ Air Products Emissions 4 70.36 2.60 26.49 4.46 0.18 0.01 0.00 0.00 4.33 0.04 0.14 0.01Total Routine Maximum Emissions 5 1109.78 32.32 454.78 8.29 385.15 23.45 33.45 0.05 41.01 0.07 2260.83 3.75Plantwide TAR Emissions 6 294.60 13.90 89.29 3.623 1555.00 7.81 1.99 0.005 0.009 0.005 187.14 2.040Flare MSS Maximums 7 1109.78 46.22 454.78 11.91 1555.00 31.26 33.45 0.05 41.01 0.08 2260.83 5.79

Notes:1. Emission rates based on continuous flare monitoring data.2. Routine MSS totals are summed to determine annual emissions and the highest four are summed to determine reasonable worst‐case short‐term emissions.3. Since the emission rates are based on monitoring data, a 15% contingency is added to account for MSS activities that may not have occurred during the four‐year period on which this analysis is based, or at the highest potential maximum rate.4. Established in the permit's current maximum emission rates table.5. Routine MSS totals with 15% contingency, Normal Operations totals, flaring of off‐spec gas, and Air Products flaring emissions are summed to establish total routine maximum emissions.6. Established plantwide turnaround totals were evaluated with 2017 events, which included shutdown/startup for Hurrican Harvey and two other planned events. A full plant shutdown scenario was also considered (see Table A‐12). Currently established permit limits were also considered, and a 15% contingency was applied as necessary. The highest values are used to establish the limits.7. TAR emissions are tracked separately from routine flaring emissions and, as such, the highest of the routine maximum emissions and TAR emissions are taken to establish the flare permit limits.

Process Area Undergoing MSSCO NOx VOC H2S NH3 SO2


Table A-6 TOTAL SITE FUGITIVE EMISSIONS

Annual Hours of Operation 8760

Valves Gas/Vapor 6819 0.0089 97 1.38 6.04 2.53 11.09Light Liquid 96 0.0035 97 0.01 0.03 2.52 11.02Heavy Liquid 125 0 0.09 0.38

Connnectors Gas/Vapor 15867 0.0029 75 8.52 37.31 3.80 16.63Light Liquid 145 0.0005 30 0.04 0.18 1.53 6.70Heavy Liquid 313 0 0.02 0.07

Pumps Light Liquid 3 0.0386 85 0.02 0.07 0.01 0.04Pumps 3 Light Liquid 46 0.0386 100 0.00 0.00 0.00 0.00Compressors 4 Gas/Vapor 13 0.5027 85 0.15 0.66 0.00 0.00

0.00 0.0010.21 44.74 10.39 45.49

1. The ethylene concentration in the inlet gas stream is less than 11%; therefore, SOCMI Without Ethylene Factors were used.2. Relief valves are routed to the flare ; therefore, 100% control efficiency is applied.3. Pumps packing are controlled with dual seals, leakage routed to seal pot then flare.4 IG Compressor D emissions are routed to flare. IG compressors A, B, and C rod packing streams are manifolded and emitted through two stacks, with remaining emissions routed to the flare. Refrigerant compressors are in a closed-loop system. LDAR factor appiled to all other compressors.

Annual VOC Emissions

Hourly Emissions -

VOC Speciated

Annual Emissions

VOC Speciated

PRVs 2

Total fugitive emission rate

Component Type Service

VOC Compone

nts

SOCMI w/o

Ethylene 1

(lb/hr)

VOC Control Efficiency

(w/28M and 28 CNTA for Connectors)

Hourly VOC Emissions


Table A-7 COOLING TOWER EMISSIONS (EPN 7)

EPNDescriptionCooling Tower Circulation Rate 1.884 MMgal/hrMaximum Pump Rated Circulation Rate 31400 gal/minTDS in Circulating Water 1 5500 ppm

Hourly AnnualPollutant (lb/hr) (tpy)

PM10 2 1.20 5.28

PM2.5 2

PM Emission Estimates - Cooling Tower

InputsAnnual Operating Period hr/yr 8760

Circulating Water gal/min 31,400

Drift % of water flow 0.0050 0.02% AP-42, > 20 year old towers0.001% BACT0.0005% new tower, best demister (source:www.ctdepotinc.com)

Represented TDS ppmw 5,500 33,000 sea water12,000 AP-42, high dissolved solids

### Other standadard referenceDensity solid particles g/cm3 2.2 Density of NaCl

OutputsPM Emission Rate lb/hr 4.32

PM Emission Rate tpy 18.93

PM_10 for MAERT lb/hr 1.20

PM_10 for MAERT tpy 5.28

PM_2.5 for MAERT lb/hr

Solid PM_10 % by droplet diameter(top) and TDS(left) Solid PM_2.5 % by droplet diameter(top) and TDS(left)10 20 30 40 50 60 70 90 110 130 150 180 210 240 270 300 350 400 450 500 600 10 20 30 40 50 60 70 90 110 130 150 180 210 240 270 300 350 400 450 500 600

89.41 0.6482.04 0.30

72.59 0.2263.50 0.2155.84 0.2150.00 0.20

43.64 0.2038.33 0.2033.84 0.1929.97 0.1826.59 0.1723.59 0.15

20.86 0.1518.20 0.1415.78 0.1313.57 0.1211.54 0.129.65 0.117.91 0.106.28 0.10


Table A-8 BUTYLENE CONVERTER STEAM SUPERHEATER EMISSIONS (EPN 8)

EPN 8

DescriptionHeat Input 3.040 MMBtu/hrSCF/Hr 2980.392 Scf/hrFurnace operating hours 8760 hr/yrFuel Heating Value, HHV 1020 Btu/scfFuel Type

PollutantHourly(lb/hr)

Annual(tpy)

CO1 0.0824 lb/MMBtu 0.25 1.10NOx

1 0.0977 lb/MMBtu 0.30 1.30PM/PM10/PM2.5

1 0.00745 lb/MMBtu 0.02 0.10SO2

2 0.0140 lb/MMBtu 0.04 0.19VOC1 0.0054 lb/MMBtu 0.02 0.071. Emission factor obtained from AP-42, Section 1.4, Tables 1.4-1 and 1.4-2.2. Natural gas delivery specification for sweet gas.

Example, Annual Emissions of NOx:

Natural Gas

Butylene Converter Steam Super Heater

Total Annual Emissions of NOx from Steam Heater (EPN 8) = 0.10 (lb/MMBtu) x 3.04 (mmbtu/hr) x 1/2,000 (tons/lb)] x 8760 (hrs/year)


DescriptionVolumetric emission rate on hourly basis (scf/hr)1

Annual operating time (hrs.)Gas Stream Specific Gravity2

Gas Stream Density, lb/scf3

Max VOC Percentage in Gas Stream, wt%2

Max Hourly VOC Emission Rates (lb/hr): Annual VOC Emission Rates (tpy):

Notes:

Sample Calculation:Gas stream density is calculated as follows:

(28.96 lb/mole) / (379 scf/mole) * (0.5020) = 0.038 lb/scf

where, MW of ait is 28.96 lb/mole

Max Hourly VOC Emission Rates (lb/hr)= 86.18 scf 0.0384 lb 34.00%

hr scf

= 1.12 lb/hr

Average Hourly VOC Emission Rates (lb/hr)= 86.18 scf 0.0384 lb 15.00%

hr scf

= 0.5 lb/hr

Annual VOC Emission Rates (T/yr):=

= 0.5 lb 8760 hr 1 ton

hr 2000 lb

= 2.17 tpy

868,760

0.50200.038

34.00%

868,760

0.50200.038

34.00%


IGC VENT1 IGC VENT2

Hourly VOC Emission Rates (lb/hr) x Annual operating tim

1From process knowledge - Greenhouse gas data.2From inlet gas analysis report.3Refer to sample calculation below.

Table A-9, Compressor Vent Emissions (EPNs IGC VENT1 and IGC VENT2)

1.121.12

IGC VENT1 IGC VENT286 86

8,760 8,7600.5020 0.50200.038 0.038

15.00% 15.00%

Hourly VOC Emission Rates (lb/hr): Volumetric emission rate on hourly basis (scf/hr) x Gas Stream Density, lb/scf x Max VOC Percentage in Gas Stream, wt%

Hourly VOC Emission Rates (lb/hr): Volumetric emission rate on hourly basis (scf/hr) x Gas Stream Density, lb/scf x Max VOC Percentage in Gas Stream, wt%

0.50 0.502.17 2.17

Annual Events- Post Control Venting 1 Frequency 1Short Term Events - Post Control Venting 2 Frequency 1

°F 85°R 545

Molecular weight of vapor (M)4 lb/ (lb-mol) 50Flare header pressure psig 2Vessel storage pressure (P)5 psia 16.7Concentration or Saturation Factor (S) - Post Control 6 Dimensionless 0.01Gas Constant, R (psia-ft3) / (lb-mol-R) 10.73

Total available system volume ft3/event 1,139,260Total available degassing volume (due to flare header pressure) (V) 7 ft3/event 1,002,822Actual degassing volume per event (V) 8 ft3/event 1002821.679

Total available system volume ft3/event 457005.74Total available degassing volume (due to flare header pressure) (V) 7 ft3/event 402274.5156Actual degassing volume per event (V) 8 ft3/event 402274.5156

Is Venting Controlled? Y/N/NA N Number of moles (hourly). n 9 n =(PV/RT) 1148.80Number of moles (annual). n 9 n =(PV/RT) 2863.81Duration of activity10 Hours 1Short-term VOC emissions per hr. vented to atmosphere (lb/hr) lb/hr = lb/event * Short Term Event Frequency / Duration of activity 574.40Annual VOC emissions vented to atmosphere tpy tpy = lb/event * Annual Frequency * Duration of activity / 2000 0.716

Notes:

Annual

Hourly

9 Ideal gas law. 10Process knowledge.

6 Concentration at 10,000 ppm = 10,000/1,000,000 = 0.01.

5 Vessel degassing to atmosphere. Total pressure = Atmospheric pressure + Flare header pressure = 14.7 + 2 = 16.7 psia.

4 Used molecular weight of 50 as representative.

8 Actual degassing volume per event is 100% of total available degassing volume.

2 Assumes largest vessel will undergo degassing for each event and no more than one event will occur per hour.3 Assumes average daily temperature.

1 Assumes one degassing of each vessel per year.

7 From process knowledge. Total degassing volume from all the vessels.

Post Control Equipment MSS Venting

Emission Calculation ParametersVessels/Piping

Daily average temperature (T)3

MarkWest Javelina Gas Processing Facility Air Permit 19296 Amendment, May 2018 Table A-10, Equipment MSS Venting Emissions (EPN DEGAS)

Total available degassing volume available 24,050,191 Actual degassing volume per event % 100

Annual Events- Post Control Venting1 Frequency 1Short Term Events - Post Control Venting2 Frequency (Simultaneous events) 1

°F 85°R 545

Molecular weight of vapor (M)4 lb/ (lb-mol) 50Flare header pressure psig 2Vessel storage pressure (P)5 psia 16.7Concentration or Saturation Factor (S) - Pre Control6 Dimensionless 0.35Gas Constant, R (psia-ft3) / (lb-mol-R) 10.73Total available system volume ft3/event 24,050,191Actual degassing volume per event (V)8 ft3/event 24,050,191Actual degassing volume per year (V) ft

3/event 24,050,191

This is step between Degassing and Opening system to atmosphere after it reaches 10,000 ppm of VOC or less.

After Degassing the system, it needs N2 Purging to reduce VOC concentrations to 10,000 ppm or below.

Assume it takes 3 purge volumes for the clearance before opening to atmosphere (after that it is covered under Post Control Degassing).

Total System volume 24050190.68 SCF3 N2 Purges, so N2 Volume to Flare 72150572.03 SCFN2 Heating Value 0 BtuFlare Requires 300 Btu/scfSupplemental Natural Gas 35073194.74 SCFHeat for combustion 35774.65863 MMBtu

300= X * 1020/(X+E9)OR 300X + E9*300 = 1020XOR 720X = E9 * 300 Usually, for compliance assurance use 350 Btu/scfOR X= (E9 * 350)/720NG = 35073194.74

MarkWest Javelina Gas Processing Facility Air Permit 19296 Amendment, May 2018 Table A-11, Equipment MSS Venting Emissions

Emission Calculation ParametersVessels/Piping

Daily average temperature (T)3


FIN FLR-5EPN 5

PollutantEmission Factor

(Non-steam assisted, high Btu)

Emission Factor (Non-steam

assisted, low Btu)Unit Parameter Constant unit

NOX 0.138 0.0641 lb/MMBtu Pressure 14.7 psiaCO 0.2755 0.5496 lb/MMBtu Gas Constant 10.73 (psia.ft3)/(lb-mol.R)

VOC 5.5 5.5 lb/MMScf Standard Temp 528 RSO2 0.6 0.6 lb/MMScf

FIN MSS MSS FL-1

Hourly Total Gas Flowrate to Flare (lb/hr) 25.79 _ 25.79 lb/hr

Hourly Total Gas Flowrate to Flare (scfh) 549.09 4,003.79 455.29 5,008.17 scfh

Annual Total Gas Flowrate to Flare

(scf/yr)24,050,191 35,073,195 5,912,339 65,035,724 scf/yr

Heating Value of the Stream (Btu/scf) 1,035 1,000 1,020 _ _

NOX 0.078 0.2566 0.06 0.40 lb/hrCO 0.157 2.2005 0.13 2.49 lb/hrSO2 0.093 0.0024 0.00 0.10 lb/hrVOC 3.74 0.0220 0.00 3.77 lb/hrH2S 0.00023 - 0.00 0.00023 lb/hrNH3 0.00025 0.00 0.00025 lb/hr

NOX 1.72 1.1241 0.42 3.26 tpyCO 3.43 9.6381 0.83 13.90 tpySO2 2.03 0.011 0.00 2.04 tpyVOC 7.7 0.096 0.02 7.81 tpyH2S 0.005 - - 0.005 tpyNH3 0.005 - 0.005 tpy

Waste and Pilot Gas Stream

Table A-12, TAR Flaring Emissions

TotalSource Degassing Purging Flare Pilot

Hourly Flare Emissions (lb/hr)

Annual Flare Emissions (tpy)

NOTE: The Degassing gas is estimated to contain 1000 ppm of H2S, with 99.5% destruction by Flare. Also, it will have 5 ppm of NH3 and 98% destruction in Flare.

FIN MSS

wt% (lb/hr)2 (scfh)3 (lb/yr)2 (scf/yr)3Heat of

Combustion4

(KJ/gmol)(Btu/lb)5 (Btu/scf)6

Methane 16.043 28.60% 7.38 174.4842 646168.09 15284817.51 31.78% 890.4 23750 1001 318.04Ethane 30.069 24.37% 6.29 79.3519 550782.58 6951228.21 14.45% 1559.9 22199 1753 253.39Ethylene 28.05 9.57% 2.47 33.3883 216187.45 2924811.89 6.08% 1411 21525 1586 96.44Propane 44.097 9.64% 2.49 21.4040 217875.14 1874990.03 3.90% 2220 21543 2495 97.27Propylene 42.08 4.41% 1.14 10.2643 99703.43 899155.29 1.87% 2058 20928 2313 43.24Isobutane 58.123 3.27% 0.84 5.5104 73932.91 482714.23 1.00% 2868.8 21121 3225 32.36n-Butane 58.123 3.42% 0.88 5.7590 77268.23 504490.82 1.05% 2878.52 21192 3236 33.94Butene 56.108 0.46% 0.12 0.7947 10293.05 69617.70 0.14% 2718 20729 3055 4.42Isopentane 72.15 1.30% 0.33 1.7590 29295.24 154085.22 0.32% 3287.73 19499 3696 11.84n-Pentane 72.15 1.26% 0.32 1.7062 28417.01 149465.96 0.31% 3536.15 20973 3975 12.35Pentene 70.135 0.02% 0.01 0.0301 487.82 2639.54 0.01% 2717 16577 3054 0.17Hydrogen 2.02 4.42% 1.14 214.0264 99798.14 18748711.32 38.98% 286 60586 321 125.31n-Hexane 86.177 0.00% 0.00 0.0000 0.00 0.00 0.00% 4194.75 20829 4715 0.00Cyclohexane 84.16 0.00% 0.00 0.0000 0.00 0.00 0.00% 3656.8 18593 4110 0.00Other Hexanes 86.177 0.00% 0.00 0.0000 0.00 0.00 0.00% 3914.16 19436 4400 0.00Heptanes 100.203 0.00% 0.00 0.0000 0.00 0.00 0.00% 4853.48 20727 5456 0.00Methylcyclohexane 98.186 0.00% 0.00 0.0000 0.00 0.00 0.00% 4259.5 18564 4788 0.002,2,4-Trimethylpentane 114.231 0.00% 0.00 0.0000 0.00 0.00 0.00% 5136.29 19241 5773 0.00Benzene 78.114 0.00% 0.00 0.0000 0.00 0.00 0.00% 3301.5 18086 3711 0.00Toluene 92.14 0.00% 0.00 0.0000 0.00 0.00 0.00% 3947.9 18335 4438 0.00Ethylbenzene 106.167 0.00% 0.00 0.0000 0.00 0.00 0.00% 4607.13 18569 5179 0.00Xylenes 318.501 0.00% 0.00 0.0000 0.00 0.00 0.00% 4595.25 6174 5165 0.00C6+ Heavies 115 0.72% 0.19 0.6125 16259.00 53653.28 0.11% 5332.9 19844 5994 6.69Total 91.45% 25.79 549.0911 2,259,631 24,050,191 100% 1,035.46

Sample calculation: FIN DegassingHourly NOX emission = (NOX EF in lb/MMBtu) x (Heating Value of degassing stream, BTU/Scf) x (Hourly gas flowrate from degassing to Flare, Scfh) ÷ (10

6)= 0.138 lb 1035.46 Btu 549.09 Scf 1 = 0.0785 lb/hr

Mmbtu Scf hr 1,000,000Annual NOX emission = (NOX EF in lb/MMBtu) x (Heating Value of degassing stream, BTU/Scf) x (Annual gas flowrate from degassing to Flare, Scf/yr) ÷ (10

6) x (1 ton/2,000 lb)= 0.138 lb 1035.46 Btu 24050190.68 Scf 1 1 ton = 1.7183 tpy

Mmbtu Scf yr 1,000,000 2000 lb

Determination of Waste Gas Heating Value

Compound Molecular Weight

Total Gas Flow to Flare Total Gas Flow to FlareMole (%)

Net Heating Value

Notes:

Net Heat Release7

(Btu/scf total)

Appendix B _______________________________________________________________________

Current Permit

Project No. 186971

TEXAS COMMISSION ON ENVIRONMENTAL QUALITYAIR QUALITY PERMIT

A Permit Is Hereby Issued ToMarkWest Javelina Company, L.L.C.

Authorizing the Construction and Operation ofJavelina Gas Processing Facility

Located at Corpus Christi, Nueces County, TexasLatitude 27° 48 17 Longitude 097° 27 27

Permit: 19296

Amendment Date : August 1, 2013

Renewal Date: December 27, 2014For the Commission

Facilities covered by this permit shall be constructed and operated as specified in the applicationfor the permit. All representations regarding construction plans and operation procedurescontained in the permit application shall be conditions upon which the permit is issued. Variationsfrom these representations shall be unlawful unless the permit holder first makes application to theTexas Commission on Environmental Quality (commission) Executive Director to amend thispermit in that regard and such amendment is approved. [Title 30 Texas Administrative Code116.116 (30 TAC 116.116)]Voiding of Permit. A permit or permit amendment is automatically void if the holder fails tobegin construction within 18 months of the date of issuance, discontinues construction for morethan 18 months prior to completion, or fails to complete construction within a reasonable time.Upon request, the executive director may grant an 18-month extension. Before the extension isgranted the permit may be subject to revision based on best available control technology, lowestachievable emission rate, and netting or offsets as applicable. One additional extension of up to 18months may be granted if the permit holder demonstrates that emissions from the facility willcomply with all rules and regulations of the commission, the intent of the Texas Clean Air Act(TCAA), including protection of the public’s health and physical property; and (b)(1)the permitholder is a party to litigation not of the permit holder’s initiation regarding the issuance of thepermit; or (b)(2) the permit holder has spent, or committed to spend, at least 10 percent of theestimated total cost of the project up to a maximum of $5 million. A permit holder granted anextension under subsection (b)(1) of this section may receive one subsequent extension if the permitholder meets the conditions of subsection (b)(2) of this section. [30 TAC 116.120(a), (b) and (c)]Construction Progress. Start of construction, construction interruptions exceeding 45 days, andcompletion of construction shall be reported to the appropriate regional office of the commissionnot later than 15 working days after occurrence of the event. [30 TAC 116.115(b)(2)(A)]Start-up Notification. The appropriate air program regional office shall be notified prior to thecommencement of operations of the facilities authorized by the permit in such a manner that arepresentative of the commission may be present. The permit holder shall provide a separatenotification for the commencement of operations for each unit of phased construction, which mayinvolve a series of units commencing operations at different times. Prior to operation of thefacilities authorized by the permit, the permit holder shall identify the source or sources ofallowances to be utilized for compliance with Chapter 101, Subchapter H, Division 3 of this title(relating to Mass Emissions Cap and Trade Program). [30 TAC 116.115(b)(2)(B)(iii)]Sampling Requirements. If sampling is required, the permit holder shall contact thecommission’s Office of Compliance and Enforcement prior to sampling to obtain the proper dataforms and procedures. All sampling and testing procedures must be approved by the executivedirector and coordinated with the regional representatives of the commission. The permit holder isalso responsible for providing sampling facilities and conducting the sampling operations orcontracting with an independent sampling consultant. [30 TAC 116.115(b)(2)(C)]

Project No. 186971 2

Equivalency of Methods. The permit holder must demonstrate or otherwise justify theequivalency of emission control methods, sampling or other emission testing methods, andmonitoring methods proposed as alternatives to methods indicated in the conditions of the permit.Alternative methods shall be applied for in writing and must be reviewed and approved by theexecutive director prior to their use in fulfilling any requirements of the permit. [30 TAC116.115(b)(2)(D)]Recordkeeping. The permit holder shall maintain a copy of the permit along with recordscontaining the information and data sufficient to demonstrate compliance with the permit,including production records and operating hours; keep all required records in a file at the plantsite. If, however, the facility normally operates unattended, records shall be maintained at thenearest staffed location within Texas specified in the application; make the records available at therequest of personnel from the commission or any air pollution control program having jurisdiction;comply with any additional recordkeeping requirements specified in special conditions attached tothe permit; and retain information in the file for at least two years following the date that theinformation or data is obtained. [30 TAC 116.115(b)(2)(E)]Maximum Allowable Emission Rates. The total emissions of air contaminants from any of thesources of emissions must not exceed the values stated on the table attached to the permit entitled“Emission Sources--Maximum Allowable Emission Rates.” [30 TAC 116.115(b)(2)(F)]Maintenance of Emission Control. The permitted facilities shall not be operated unless all airpollution emission capture and abatement equipment is maintained in good working order andoperating properly during normal facility operations. The permit holder shall provide notificationfor upsets and maintenance in accordance with 30 TAC 101.201, 101.211, and 101.221 of this title(relating to Emissions Event Reporting and Recordkeeping Requirements; Scheduled Maintenance,Startup, and Shutdown Reporting and Recordkeeping Requirements; and OperationalRequirements). [30 TAC 116.115(b)(2)(G)]Compliance with Rules. Acceptance of a permit by an applicant constitutes an acknowledgmentand agreement that the permit holder will comply with all rules, regulations, and orders of thecommission issued in conformity with the TCAA and the conditions precedent to the granting of thepermit. If more than one state or federal rule or regulation or permit condition is applicable, themost stringent limit or condition shall govern and be the standard by which compliance shall bedemonstrated. Acceptance includes consent to the entrance of commission employees and agentsinto the permitted premises at reasonable times to investigate conditions relating to the emission orconcentration of air contaminants, including compliance with the permit. [30 TAC116.115(b)(2)(H)]This permit may not be transferred, assigned, or conveyed by the holder except as provided by rule.[30 TAC 116.110(e)]There may be additional special conditions attached to a permit upon issuance or modification ofthe permit. Such conditions in a permit may be more restrictive than the requirements of Title 30 ofthe Texas Administrative Code. [30 TAC 116.115(c)]Emissions from this facility must not cause or contribute to a condition of “air pollution” asdefined in Texas Health and Safety Code (THSC) 382.003(3) or violate THSC 382.085. If theexecutive director determines that such a condition or violation occurs, the holder shall implementadditional abatement measures as necessary to control or prevent the condition or violation.The permit holder shall comply with all the requirements of this permit. Emissions that exceed thelimits of this permit are not authorized and are violations of this permit.

SPECIAL CONDITIONS

Permit Number 19296

1. This permit authorizes emissions only from those points listed in the attached table entitled“Emission Sources - Maximum Allowable Emission Rates,” and the facilities covered bythis permit are authorized to emit subject to the emission rate limits on that table and otheroperating conditions specified in this permit.

Federal Applicability

2. This facility shall comply with all applicable requirements of the U.S. EnvironmentalProtection Agency (EPA) regulations on Standards of Performance for New StationarySources, Title 40 Code of Federal Regulations Part 60 (40 CFR Part 60), promulgated forEquipment Leaks of volatile organic compounds (VOC) in the Synthetic OrganicChemicals Manufacturing Industry, Subparts A and VV.

Emission Standards and Operating Specifications

3. Boiler Nos. 2 and 3 shall demonstrate compliance with the best available controltechnology (BACT) standards represented for nitrogen oxides (NOx) and carbon monoxide(CO) during the initial compliance testing. The best available control technology (BACT)standards to be demonstrated are: 0.035 pound per million British thermal units (MMBtu)of NOx and 100 parts per million by volume, (ppmv) dry of CO at full firing rate.Concentration limits are stated corrected to 3 percent oxygen (O2).

4. Upon request by the Executive Director of the Texas Commission on EnvironmentalQuality (TCEQ), the holder of this permit shall provide a sample and/or analysis of the fuelused in this facility.

5. Fuel for Boiler Nos. 1, 2, and 3 shall be limited to pipeline-quality, sweet natural gascontaining no more than 0.05 grain total sulfur per dry standard cubic feet. A copy ofspecifications for the purchased natural gas shall be kept on-site. (6/10)

6. The VOCs associated with cooling tower water shall be monitored monthly with anapproved air stripping system or equivalent; such as total organic carbon water analyses onthe cooling tower water return line. The appropriate equipment shall be maintained so as tominimize fugitive VOC emissions from the cooling tower. Faulty equipment shall berepaired at the earliest opportunity, but no later than the next scheduled shutdown of theprocess unit in which the leak occurs. The results of the monitoring and maintenanceefforts shall be recorded. (6/10)

SPECIAL CONDITIONSPermit Number 19296Page 2

Flare Conditions

7. Flares shall be designed and operated in accordance with the following requirements:

A. The flare systems shall be designed such that the combined assist natural gas andwaste stream to each flare meets the 40 CFR § 60.18 specifications of minimumheating value and maximum tip velocity under normal and maintenance flowconditions.

The heating value and velocity requirements shall be satisfied during operationsauthorized by this permit. Flare testing per 40 CFR § 60.18(f) may be requested bythe appropriate regional office to demonstrate compliance with these requirements.

B. The flare shall be operated with a flame present at all times and/or have a constantpilot flame. The pilot flame shall be continuously monitored by a thermocouple or aninfrared monitor. The time, date, and duration of any loss of pilot flame shall berecorded. Each monitoring device shall be accurate to, and shall be calibrated at afrequency in accordance with, the manufacturer’s specifications

C. The flare shall be operated with no visible emissions except periods not to exceed atotal of five minutes during any two consecutive hours. This shall be ensured by theuse of air assist to the flare.

D. The permit holder shall install a continuous flow monitor and composition analyzerthat provide a record of the vent stream flow and composition Btu content to the flare.The flow monitor sensor and analyzer sample points shall be installed in the ventstream as near as possible to the flare inlet such that the total vent stream to the flareis measured and analyzed. Readings shall be taken at least once every 15 minutesand the average hourly values of the flow and composition shall be recorded eachhour.

The monitors shall be calibrated on an annual basis to meet the following accuracyspecifications: the flow monitor shall be ±5.0 percent, temperature monitor shall be±2.0 percent at absolute temperature, and pressure monitor shall be ±5.0 mm Hg.

The calorimeter shall be calibrated, installed, operated, and maintained, in accordancewith the manufacturer recommendations, to continuously measure and record the netheating value of the gas sent to the flare, in Btu/standard cubic foot of the gas, at leastonce every 15 minutes.

SPECIAL CONDITIONSPermit Number 19296Page 3

The monitors and analyzers shall operate as required by this section at least 95percent of the time when the flare is operational, averaged over a rolling 12-monthperiod. Flared gas net heating value and actual exit velocity determined inaccordance with 40 CFR § 60.18(f)(4) shall be recorded at least once every 15minutes. (11/09)

8. The Facility Flare, Emission Point Number (EPN) 5, shall be located at least 100 feet fromany recreational area or residence or other structu

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