· 1 day ago · P:\SOUTHWEST SHIPYARD\340745.0000_2019 CHANNELVIEW PERMITTING\43774 DRY DOCK...

$: · 1 day ago · P:\SOUTHWEST SHIPYARD\340745.0000_2019 CHANNELVIEW PERMITTING\43774 DRY DOCK PERMIT\TCEQ COVER LETTER.DOCX July 15, 2020 …$

P:\SOUTHWEST SHIPYARD\340745.0000_2019 CHANNELVIEW PERMITTING\43774 DRY DOCK PERMIT\TCEQ COVER LETTER.DOCX

July 15, 2020

Air Permits Initial Review Team (APIRT) Texas Commission on Environmental Quality (TCEQ) 12100 Park 35 Circle, MC‐161 Building C, Third Floor, Room 300 W Austin, Texas 78753

Subject: NSR Permit 43774 Renewal and Amendment Application Dry Docks Abrasive Blasting and Surface Coating Facility Southwest Shipyard, L.P. Channelview Facility Channelview, Harris County Regulated Entity Number: RN100248749 Customer Reference Number: CN600135354

On behalf of Southwest Shipyard, L.P. (Southwest Shipyard), TRC Environmental Corporation (TRC) hereby submits the following minor New Source Review (NSR) air quality permit application to renew and amend NSR Permit No. 43774 pursuant to 30 TAC Chapter 116, Subchapter D and Subchapter B requirements, respectively. The subject NSR permit authorizes a Dry Docks Abrasive Blasting and Surface Coating Facility located in Channelview, Harris County, Texas.

Southwest Shipyard respectfully requests Mr. Alejandro Cavazos in the TCEQ Coatings Section to review the subject application, as this project is very similar to a NSR renewal and amendment project that he reviewed last year for Southwest Shipyard’s same site and facility type (surface coating and abrasive blasting) for RN100248749; NSR 36241. Mr. Alejandro Cavazos is familiar with the Channelview site and the NSR project went very well.

An electronic version of the application, including the Excel workbook Form PI‐1 General Application (version 4.0), Excel Electronic Modeling Evaluation Workbook (EMEW) for non‐SCREEN3 (version 2.3), and Excel Outdoor Coating and Abrasive Blasting Emission Calculations Workbook has been submitted to TCEQ Air Permits via email ([email protected]).

The appropriate permit application renewal and amendment fee has been submitted to the TCEQ Financial Administration Division under a separate cover. A copy of the fee payment check is included in Appendix A. If there are any questions concerning this submittal, please contact me at 713‐244‐1039 or via email at [email protected].

Sincerely, TRC Environmental Corporation

Elizabeth Stanko Senior Project Manager

Attachments

cc: Air Section Manager, TCEQ Region 12, Houston Harris County Public Health & Environmental Services, Attn: Air Section Manager

Mr. Bernard Diaz, Managing Director of Environmental Operations, Southwest Shipyard, L.P. (Electronic)


TRC Environmental Corporation | Southwest Shipyard, L.P.

Final 7/14/2020 \\HOUSTON‐FP1\DATA\PROJECTS‐PPL\WPHOU\PJT2\340745\0000\R340745.0000‐002.DOCX

10550 RICHMOND AVENUE, SUITE 210, HOUSTON, TEXAS 77042 ● 713.244.1000 PHONE ● 713.789.5920 FAX ● WWW.TRCCOMPANIES.COM

Application for Renewal and Amendment of NSR Permit No. 43774

Dry Dock Abrasive Blasting and Surface Coating Operations

Channelview, Harris County, Texas

July 2020

Prepared For

Southwest Shipyard, L.P.


TRC Environmental Corporation | Southwest Shipyard, L.P. i \\HOUSTON‐FP1\DATA\PROJECTS‐PPL\WPHOU\PJT2\340745\0000\R340745.0000‐002.DOCX 7/14/20 Final July 2020

Table of Contents

1. Introduction ................................................................................................................................... 1‐1

1.1 Overview of Permitted Source ......................................................................................... 1‐1

1.2 Purpose of the Permit Application .................................................................................. 1‐1

1.3 TCEQ Forms and Information .......................................................................................... 1‐2

1.3.1 PI‐1 General Application and Fee Payment (Appendix A) ............................. 1‐3

1.3.2 Emissions Calculations (Appendix B) ................................................................ 1‐3

1.3.3 Impacts Analysis ‐ EMEW (Appendix C) .......................................................... 1‐3

1.3.4 Modeling Files ‐ CD (Appendix D)..................................................................... 1‐3

1.3.5 Current NSR Permit Authorization (Appendix E) ........................................... 1‐3

1.3.6 TCEQ Guidance and Equipment Specifications (Appendix F) ...................... 1‐3

1.4 Emissions Summary .......................................................................................................... 1‐4

1.5 EPN Name Changes .......................................................................................................... 1‐5

1.6 Federal Applicability ......................................................................................................... 1‐7

1.6.1 NNSR Applicability .............................................................................................. 1‐7

1.6.2 PSD Applicability .................................................................................................. 1‐7

1.6.3 Hazardous Air Pollutants (HAPs) ...................................................................... 1‐7

1.7 Public Notice ....................................................................................................................... 1‐8

1.8 Permit Fees .......................................................................................................................... 1‐8

1.9 Impacts Analysis ................................................................................................................ 1‐8

1.10 Area Map and Plot Plan .................................................................................................... 1‐9

2. Process Description ...................................................................................................................... 2‐1

2.1 Dry Abrasive Blast Cleaning ............................................................................................ 2‐1

2.2 Dust Collector Face Velocity Calculations ...................................................................... 2‐1

2.3 Surface Coating .................................................................................................................. 2‐2

2.4 Paint Equipment Cleaning ................................................................................................ 2‐2

2.5 Planned Maintenance, Startup, and Shutdown (MSS) Activities ................................ 2‐3

2.6 Process Flow Diagram ....................................................................................................... 2‐3

3. Emission Calculations .................................................................................................................. 3‐1

3.1 Dry Abrasive Blast Cleaning ............................................................................................ 3‐1

3.2 Surface Coating .................................................................................................................. 3‐2

3.3 Roller Surface Coating ....................................................................................................... 3‐3

3.4 Blast Pot Filling ................................................................................................................... 3‐3


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3.5 Spent Media Cleanup ........................................................................................................ 3‐4

3.6 Excel Workbook Calculations ........................................................................................... 3‐5

4. Best Available Control Technology (BACT) ............................................................................. 4‐1

4.1 BACT for Enclosed Abrasive Blasting ............................................................................. 4‐1

4.2 BACT for Surface Coating Operations ............................................................................ 4‐2

5. Considerations for Granting a Permit Renewal ....................................................................... 5‐1

List of Figures

Figure 1‐1 Area Map .............................................................................................................. 1‐11

Figure 1‐2 Plot Plan ................................................................................................................ 1‐12

Figure 2‐1 Process Flow Diagram .......................................................................................... 2‐4

List of Appendices

Appendix A PI‐1 General Application and Fee Payment

Appendix B Emissions Calculations

Appendix C Impacts Analysis ‐ EMEW

Appendix D Modeling Files ‐ CD

Appendix E Current NSR Permit Authorization

Appendix F TCEQ Guidance and Equipment Specifications


TRC Environmental Corporation | Southwest Shipyard, L.P. 1‐1 \\HOUSTON‐FP1\DATA\PROJECTS‐PPL\WPHOU\PJT2\340745\0000\R340745.0000‐002.DOCX 7/14/20 Final July 2020

Section 1 Introduction

1.1 Overview of Permitted Source Southwest Shipyard, L.P. (Southwest Shipyard) owns and operates a barge cleaning and repair

facility located at 18310 Market Street in Channelview, Harris County, Texas. This site, referred

to as the Channelview yard, performs marine vessel and barge cleaning and repair activities,

which involves stripping and degassing marine tank barges as well as painting and blasting

barges. The Texas Commission on Environmental Quality (TCEQ) Customer Number (CN) for

Southwest Shipyard is CN600135354. The Regulated Entity Number (RN) for the Channelview

yard is RN100248749, and the TCEQ account number is HG‐0686‐T.

The Dry Docks are one of several operational areas located at the Channelview yard.

Operations at the Dry Docks consist of abrasive blast cleaning and surface coating of marine

barges and boats. The operation of emission sources at the Dry Docks is authorized by TCEQ

New Source Review (NSR) Permit No. 43774 (last revised on September 30, 2015), Federal

Operating Permit (FOP) No. O‐1260 (last renewed on July 17, 2018), and various Permits by

Rule (PBR) under Title 30 Texas Administrative Code (30 TAC) Chapter 106.

1.2 Purpose of the Permit Application Southwest Shipyard is requesting to renew NSR Permit No. 43774, which has a renewal date of

August 17, 2020. This renewal application is being submitted prior to the permit expiration

date in accordance with 30 TAC Chapter 116, Subchapter D. An extension request for submittal

of the renewal application was submitted and approved by TCEQ on March 2, 2020, which

extends the renewal application due date to July 15, 2020. In addition to the renewal, a

concurrent permit amendment application is being submitted in accordance with 30 TAC

Chapter 116, Subchapter B to authorize permit changes at the facility as detailed below.

Southwest Shipyard proposes to accomplish the following objectives with this permit renewal

and amendment application:

Renew Permit No. 43774 pursuant to 30 TAC Chapter 116, Subchapter D requirements.

Authorize the addition of exempt solvent (ES) emissions to the permit Maximum

Allowable Emission Rate Table (MAERT), which are currently not represented in the NSR

permit. Exempt solvent (ES) emissions have always been present and used at the facility

but have never been identified in the permit. The addition of the new chemical species



(exempt solvent) is included in the surface coating emissions calculations and impacts

analysis.

Revised numbering of Emission Point Numbers (EPNs) as detailed in Section 1.5.

Update the permit representations to demonstrate that all abrasive blasting emissions at the

Dry Docks are controlled using a dust collector and are emitted from the control equipment

stacks (EPNs: DD8STK, DD15STK, and DD12STK) and are not emitted as fugitives. This

update is discussed in Sections 1.5 and 2.2. The surface coating emissions will continue to

be represented as fugitives.

Add emissions to account for cleanup of spent abrasive blast media at the Dry Docks

(EPNs: DD8CLN, DD15CLN, and DD12CLN);

Add the new emission source (EPN: POT‐FILL) where blast pot filling will occur;

Add particulate matter with an aerodynamic diameter of 2.5 micrometers or less (PM2.5)

emissions to the permit MAERT, which have always been present in the authorized

blasting and coating activities that emit particulates and PM10 but were not speciated as

PM2.5 on the NSR permit.

Remove EPNs: ST1 and FUGST1 from the air permit, which are being administratively

transferred from NSR Permit 43774 to NSR Permit 9442 per the permit alteration request

dated July 6, 2020 (TCEQ Project No. 317595) 1.

Consolidate a Permit‐by‐Rule (PBR) Registration 155161 by reference for site‐wide paint

equipment cleanup facilities into Permit No. 43774, which is discussed in Section 2.4.

1.3 TCEQ Forms and Information This application has been prepared in accordance with Title 30 Texas Administrative Code (30

TAC) Chapter 116, Subchapter B. A completed Excel workbook Form PI‐1 General Application

(version 4.0) with additional support information is included in this submittal. A discussion of

federal applicability, public notice applicability, TCEQ permit application fee, the impacts

analysis, are provided in Sections 1.6 through 1.9 of this section, respectively.

An area map indicating the site location and a plot plan identifying the location of the project

emission sources are included in Figures 1‐1 and 1‐2 of this section, respectively. A project

description and process flow diagrams are presented in Section 2. Emission calculations are

described in Section 3 of this application. The analysis of Best Available Control Technology

(BACT) is provided in Section 4. Identification of applicable federal and state regulatory

1 Emission Point Numbers (EPNs) ST1 and FUGST1 are associated with the shipyard’s marine vessel degassing and cleaning operations. NSR Permit 43774 is a surface coating and abrasive blasting permit for the Channelview site’s Dry Docks, and NSR Permit 9442 is the atmospheric (non-pressurized) barge degassing and cleaning permit. As such, the alteration request will transfer the facilities associated with the barge degassing and cleaning operations from NSR Permit 43774 to NSR Permit 9442.



requirements and compliance with these requirements is demonstrated in Section 5. To assist in

the review of this submittal, the following appendices are included:

1.3.1 PI-1 General Application and Fee Payment (Appendix A)

Appendix A of this application contains the Form PI‐1 General Application; Excel

workbook file (version 4.0) and a copy of permit fee check.

1.3.2 Emissions Calculations (Appendix B)

The emission calculation methodologies for the emission sources covered by this air

permit are described in Section 3 of this application. Detailed emission calculations

including chemical speciation were performed using the Excel Outdoor Coating and

Abrasive Blasting Emission Calculations Workbook developed by the TCEQ Air Permits

Division (APD) Coatings Section, which has been submitted electronically to TCEQ Air

Permits via email ([email protected]). Documentation submitted in the emissions

calculations section (Section 3) represents a material balance. Therefore, a Material

Balance Table (Table 2) has not been provided with this application.

1.3.3 Impacts Analysis - EMEW (Appendix C)

Appendix C of this application contains the Electronic Modeling Evaluation Workbook

(EMEW) for non‐SCREEN3 (version 2.3) submitted in support of the new air quality

permit application, and modeling attachments. Air dispersion modeling using

AERMOD v19191 was performed for assessing off‐property impacts, which is discussed

in the EMEW and the Appendix C modeling memo with attachments.

1.3.4 Modeling Files - CD (Appendix D)

Electronic versions of all input and output files for each dispersion modeling run,

including data, grid, plot files, and plot plan have been included on the enclosed

compact disc (CD). Likewise, all files produced by the software entry program and

meteorological data files are included.

1.3.5 Current NSR Permit Authorization (Appendix E)

A copy of the current NSR Permit 43774 is provided in Appendix E of this application.

1.3.6 TCEQ Guidance and Equipment Specifications (Appendix F)

Relevant TCEQ guidance documents that pertain to the abrasive blasting emission

factors, TCEQ guidance for calculating PM emission calculations for spray coating



operations, dust collector filter data, and vendor‐provided spray gun equipment

specifications are include in Appendix F.

1.4 Emissions Summary Southwest Shipyard has prepared updated air emissions calculations for the Dry Docks facility,

which are included in Section 3 of this application. The emission calculations demonstrate that

there is no net increase in the permitted volatile organic compounds (VOC) or particulate

matter (PM) emissions limits, including particulate matter with an aerodynamic diameter of 10

micrometers or less (PM10), and PM2.5. The proposed amendment to Permit No. 43774 will result

in changes in allowable emission rates. A summary of the current and proposed maximum

allowable emission rates (MAER) is provided in Table 1‐1.

Table 1-1 Emissions Summary Table

EPN FIN Source Name Air

Contaminant Name

Current MAERT Limits

Proposed Emission Rates

lbs/hr TPY lbs/hr TPY

DD1, DD2, and DD3STK

DD1, DD2, and DD3

Surface Coating and Abrasive Blasting Cap

VOC 161.50 33.20 PM 35.75 24.97

PM10 17.15 8.32

DD8, DD15, and DD12

DD8, DD15, and

DD12

Surface Coating Cap

VOC 149.66 32.25 ES 37.69 1.90 PM 2.62 1.08

PM10 0.24 0.10

PM2.5 0.02 0.01

DD8STK, DD15STK, and

DD12STK

DD8, DD15, and

DD12

Abrasive Blasting Cap

PM 0.07 0.06

PM10 0.02 0.01

PM2.5 0.003 0.001

DD8CLN, DD15CLN, and

DD12CLN

DD8, DD15, and

DD12

Spent Media Cleanup Cap

PM 0.01 0.02

PM10 0.004 0.007

PM2.5 0.001 0.002

POT-FILL POT-FILL Blast Pot Filling

PM 0.01 0.02

PM10 0.01 0.01

PM2.5 0.002 0.002

Project Net Change in Allowable Emissions

VOC Emissions -11.84 -0.95Exempt Solvent (ES) Emissions 37.69 1.90

PM Emissions -33.04 -23.79PM10 Emissions -16.89 -8.19



Proposed MAER in pounds per hour (lb/hr) and tons per year (tpy) for all the emissions sources

authorized under Permit No. 43774 are provided in the Form PI‐1 General Application; Excel

workbook file in Appendix A.

1.5 EPN Name Changes This application proposes a nomenclature change for the Dry Dock numbering system, such

that the dry dock EPN “numbers” match the actual numbering used at the Channelview facility.

For example, Dry Dock 1 (EPN: DD1) in the current NSR permit is actually Dry Dock 8 and

should be renumbered EPN: DD8. Likewise, Dry Dock 2 (EPN: DD2) in the current NSR permit

is actually Dry Dock 15 and should be renumbered EPN: DD15, and Dry Dock 3 (EPN: DD3) in

the current NSR permit is actually Dry Dock 12 and should be renumbered EPN: DD12.

Additionally, all abrasive blast cleaning emissions at the Dry Docks are emitted from control

equipment (dust collector) stacks and not as fugitives. Blasting activities occur in movable

enclosures (mobile shrouds) that completely surround the barge sections on the dry docks. The

mobile shrouds capture 100‐percent of the blasting PM, PM10, and PM2.5 emissions and routes

them to the dry filter system for control. As such, the abrasive blast cleaning emissions should

be separated for the surface coating activities in the permit MAERT and the dust collector stacks

should be designated EPNs: DDSTK8, DDSTK15, and DDSTK12.

A summary of the proposed EPN numbering changes in provide in Table 1‐2.



Table 1-2 EPN Numbering Change Table

Current EPN Number and Description New / Proposed EPN Number and Description

EPN FIN Source Description EPN FIN Source Description

DD1

DD1 (DRY DOCK 1)

Dry Dock 1 Surface Coating (Fugitive

emissions) DD8

DD8 (DRY DOCK 8)


emissions)

DD1 (DRY DOCK 1)

Dry Dock 1 Abrasive Blasting (Fugitive

emissions) DD8STK

DD8 (DRY DOCK 8)

Dry Dock 8 Abrasive Blasting (Stack

emissions)

DD2

DD2 (DRY DOCK 2)


emissions) DD15

DD15 (DRY DOCK 15)


emissions)

DD2 (DRY DOCK 2)

Dry Dock 2 Abrasive Blasting (Fugitive

emissions) DD15STK

DD15 (DRY DOCK 15)


emissions)

DD3STK

DD3 (DRY DOCK 3)

Dry Dock 3 Surface Coating (Stack

emissions) DD12

DD12 (DRY DOCK 12)


emissions)

DD3 (DRY DOCK 3)

Dry Dock 3Abrasive Blasting (Stack

emissions) DD12STK

DD12 (DRY DOCK 12)


emissions)

ST1 BARGE DOCK

1

Barge Degassing, De-Heeling, and Cleaning

at Dock 1

REMOVE FROM NSR PERMIT 43774; TRANSFER VIA PERMIT ALTERATION TO NSR PERMIT 9442

FUGST1 BARGE DOCK

1

Cleaning and Degassing Pipeline

Fugitives

REMOVE FROM NSR PERMIT 43774; TRANSFER VIA PERMIT ALTERATION TO NSR PERMIT 9442

NEW SOURCE

DD8CLN, DD15CLN,

and DD12CLN

DD8, DD15, and DD12

Spent Media Cleanup

NEW SOURCE POT-FILL BLASTPOT Blast Pot Filling



1.6 Federal Applicability The Southwest Shipyard Channelview site is an existing major stationary source for VOC

emissions and a minor source for all other pollutants. Therefore, an evaluation of both

Prevention of Significant Deterioration (PSD) applicability and Nonattainment New Source

Review (NNSR) applicability needs to be conducted for any “project” to be authorized at the

site. The regulated NSR pollutants evaluated for this application are VOC, ES, PM, PM10, and

PM2.5. NNSR and PSD applicability evaluations are discussed in the following sections.

1.6.1 NNSR Applicability

The Southwest Shipyard Channelview site is located in Harris County, Texas. Harris

County is designated as a serious nonattainment area for ozone under the eight‐hour

standard, for which emissions of nitrogen oxides (NOX) and VOC are regulated as

precursors to ozone.

There are no existing or proposed NOx emission sources associated with this permit.

Additionally, there are no increases in VOC emissions associated with this project. As

demonstrated in the Federal Applicability Tab of the electronic PI‐1 General Application

spreadsheet, there are no emission increases for VOC associated with this project.

Therefore, contemporaneous netting is not required, and NNSR review is not applicable.

1.6.2 PSD Applicability

Harris County is designated an unclassifiable/attainment area for all other criteria

pollutants. As demonstrated in the Federal Applicability Tab of the electronic PI‐1

General Application spreadsheet, the associated project emission increases of criteria

pollutants are less than their respective major source designation thresholds. Therefore,

PSD review is not required.

1.6.3 Hazardous Air Pollutants (HAPs)

The definition of an affected source subject to federal standards of review requirements

includes stationary sources which emit 10 tons or more of any individual hazardous air

pollutant (HAP), or 25 tons or more of any combination of HAPs and for which no

MACT standards have been promulgated under 40 CFR 63. The Channelview yard does

not emit 10 tons or more of any individual HAP, or 25 tons or more of any combination

of HAPs, therefore this is not applicable to Southwest Shipyard.



1.7 Public Notice Air quality permit applications are required to comply with the Public Notice of Air Quality

Application requirements of 30 TAC Chapter 39, Subchapters H and K. In accordance with

Texas Clean Air Act §382.056, Southwest Shipyard will publish notice of intent to obtain a

permit renewal and concurrent amendment application. Southwest Shipyard will comply with

all public notification requirements in accordance with 30 TAC Chapter 39. The notice will be

published in a newspaper of general circulation in the municipality where the existing facility is

located, with a description of the location of the facility, and emissions that result from the

operation of the facility.

1.8 Permit Fees Based on the Fees tab of the of the Excel PI‐1 General Application, the permit renewal fee was

determined to be $1,580.45 and the amendment fee was determined to be $900 (minimum fee).

One check is being submitted to cover the air quality permit renewal and amendment fees,

which total $2,480.45. The fee payment check has been submitted under a separate cover to the

TCEQ Revenue Section. A copy of the checks is included in Appendix A.

1.9 Impacts Analysis In accordance with the requirements in 30 TAC §116.111(a)(2)(J), atmospheric dispersion

modeling may be required to determine air quality impacts from a proposed new facility or

source modification. Southwest Shipyard performed refined air dispersion modeling, which is

included in the Electronic Modeling Evaluation Workbook (EMEW) in Appendix C. The

following modeling analyses were performed:

National Ambient Air Quality Standards (NAAQS) modeling was performed to

demonstrate compliance with the NAAQS for PM10 and PM2.5 at all off‐property receptors.

Specifically, a NAAQS Significant Impact Level (SIL) analysis was performed

demonstrating that the project impacts are less that the respective PM10 and PM2.5 SILs

(minor NSR de minimis analysis);

A minor source health effects evaluation was performed for exempt solvents, and two

species of exempt solvents were evaluated, which are 1‐chloro‐4‐(trifluoromethyl)benzene

(CAS 98‐56‐6), and acetone (CAS 67‐64‐1);

Generic modeling using Unit Impact Multipliers (UIMs) was performed to demonstrate

that changes in permit representations (i.e., emission point discharge parameters) will not

be detrimental to the general public or the environment and accordingly, do not require a

health affects analysis for surface coating operations (speciated VOC or speciated PM

species); and



A MERA Step 3 (10‐percent of ESL Evaluation) was performed for crystalline silica

emissions (PM10) using UIMs, showing project impacts are less than 10‐percent of the ESL.

The modeling attachments include a detailed description of the MERA Step 3

demonstration, including speciated emissions rates.

The NSR permit has a “chemical flexibility” condition (Special Condition 11), which authorizes

emissions of new or replacement compound/products as the surface coatings typically change

based on client demands, and due to manufacturer formulation changes. As such, there is no

change in the character of VOC or particulate emissions associated with the project, and any

new VOC or particulate chemical species in the materials used are authorized by NSR Permit

No. 36241’s Special Condition 11.

The outdoor surface coating operations at this site use shrouds as described in the Process

Description to provide acceptable off‐property impacts for the surface coating operations. The

shroud adjustment factor was used in the air quality impacts analysis in accordance with the

TCEQ Air Permits Division (APD) memo dated March 17, 2006. The shroud adjustment factor

will be used for modeling purposes only.

Since the Channelview site is a shipbuilding and ship repair operation, the TCEQ will not

require and may not consider air dispersion modeling results predicting ambient concentrations

of non‐criteria air contaminants over coastal waters of the state. Therefore, the model predicted

off‐property concentrations of exempt solvents (noncriteria pollutants) were evaluated at land‐

based (onshore) off‐property locations for determination of compliance with non‐criteria

pollutant standards and guidelines.

1.10 Area Map and Plot Plan Southwest Shipyard’s Channelview yard is located at 18310 Market Street in Channelview,

Texas. The enclosed Area Map, Figure 1‐1, has been included with this application to illustrate

the location of the property and surrounding area. The area map includes a true north arrow,

an accurate scale, the entire plant property, the location of the property relative to prominent

geographical features, industrial and non‐industrial classification, and the location of the

nearest schools. Figure 1‐1 includes a circle of 3,000‐ft radius and a circle of one‐mile radius

around the center of the facility. The area map includes current aerial photography to depict

the land use surrounding the facility. There are no schools, hospitals, nursing homes, or child

care facilities within a one‐mile radius of the facility. The nearest school is located

approximately 1.9 miles north of the facility.



The enclosed Plot Plan, Figure 1‐2, shows the location of all the emission sources covered by this

air permit and their associated UTM coordinates. The plot plan is to scale and includes a true

north arrow, all property lines, project emission sources, and two bench mark locations. The

plot plan includes current aerial photography to show the buildings, tanks, and other process

equipment located at the Channelview site.

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10550 Richmond Ave.Suite 210

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Fig 1-1 - SW ShipYard-Channelview - Area Map.dwg

DATE: JULY 2020

PROJECT-MGR: E. STANKO

REQUEST BY: N. NUSSBAUM

DRAWN BY: O. FONSEKA 380356.0000PROJECT No.:

FIGURE 1-1

TITLE:

PROJECT:

AREA MAP

NSR Permit 43774 Renewal and Amendment

SOUTHWEST SHIPYARD, L.P.

Channelview Site - Dry Docks

18310 Market Street, Channelview, TX 77530

SCALE IN FEET

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FILE:


Houston, TX 77042Phone: 713.244.1000

Fig 1-2 - SW ShipYard-Channelview - Plot Plan.dwg

DATE:JULY 2020

PROJECT-MGR:E. STANKO

REQUEST BY: N. HALAGERI


FIGURE 1-2

TITLE:

PROJECT:

PLOT PLAN

NSR Permit 43774 Renewal/Amendment




L E G E N D

EPN LOCATIONS

BENCHMARK LOCATION

PROPERTY BOUNDARY

DRY DOCKS



Section 2 Process Description

The Channelview Dry Docks Permit No. 43774 authorizes emissions that are generated during

abrasive blast cleaning and surface coating operations at the three dry docks; Dry Dock 8, Dry

Dock 15, and Dry Dock 12 (previously referred to as Dry Dock 1, Dry Dock 2, and Dry Dock 3).

2.1 Dry Abrasive Blast Cleaning Cleaned but unfinished barges in need of abrasive blasting are moved onto the Dry Docks.

Southwest Shipyard uses two types of blasting media; silica sand as well as copper slag and

coal slag to perform the blast cleaning operations. The majority of blasting is conducted using

low dusting abrasives such as copper/coal slag, however silica sand is used, as necessary, in the

abrasive blast cleaning process.

Abrasive blasting operations are conducted outdoors within moveable enclosures (mobile

shrouds), which fully enclose and surround the parts of the barges and marine vessels being

blasted. The moveable enclosures (mobile shrouds) are equipped with mobile dust collection

systems, which are used to capture and control PM, PM10, and PM2.5 emissions generated from

abrasive blasting operations conducted within the mobile shrouds. All emissions captured from

abrasive blasting are exhausted through a cartridge‐type dry filter system that achieves an

overall particulate removal efficiency of at least 99.9‐percent. The vendor data on the filters

used at the facility is provided in Appendix F. This data shows the efficiency on particulate

sizes, which is a MERV 15 filtration efficiency rating per ASHRAE 52.2‐2007.

Emissions captured from the abrasive blasting operations at each of the dry docks are exhausted

through the dust collector stacks (EPNs: DD8STK, DD15STK, and DD12STK).

After abrasive blasting operations are completed, the spent abrasive is cleaned up and collected

via utility vehicle and transferred to a spent abrasive storage building. The spent blast media

cleanup occurs within a tarped and shrouded area. From there, the spent abrasive is loaded

into dump trucks via front loaders and transferred offsite for recycling, as needed.

2.2 Dust Collector Face Velocity Calculations The mobile dust collectors maintain a negative pressure (face velocity of 100 feet per minute

[fpm] or greater) across the shrouded blasting area during abrasive blasting operations (EPNs:

DD8STK, DD15STK, and DD12STK). Face velocity calculations for the mobile shrouds are

included in Table 2‐1.



Table 2-1 Dry Docks Face Velocity Calculations

EPN Source Description

Area of Opening (Total

Intake Area)

Flow Rate of Blowers [1]

Flow Rate of Blowers

[1]

Face Velocity

ft2 scfm ft3/s ft/min

DD8STK Moveable Enclosure Shrouds (Mobile Dust Collector Stack

Emissions) 140 22,000 366.7 157


Emissions) 140 22,000 366.7 157


Emissions) 140 22,000 366.7 157

[1] The mobile dust collectors each have two motors and blowers with a flow rate of 11,000 SCFM each. The two blowers associated with each mobile dust collector have a total flow rate of 22,000 SCFM.

2.3 Surface Coating After the marine vessel surface has been appropriately cleaned, it is then coated as per the

client’s specifications. Paints and solvents are received at the Channelview yard in cans, pails,

and drums. High transfer efficiency application equipment is used for the spray coating

operations. The spray application equipment in use at the Dry Docks site are airless spray guns.

Shrouds are used at all the outdoor spray‐painting areas (EPNs: DD8, DD15, and DD12) to

partially enclose and surround the area being spray painted to minimize the atmospheric

entrainment of VOC and fine particles. The shroud sides are connected and have overlapping

seams to prevent leakage of particulates.

In addition to spray painting, manual application of coatings using paint rollers is also

performed at the dry docks. The manual coating operations consist of non‐skid coating

application to barge deck surfaces, and striping applications to barge deck perimeters.

2.4 Paint Equipment Cleaning The Channelview yard has multiple surface coating facilities, which include the subject Dry

Dock Operations (authorized by NSR 43774), the Barge Rail facility (NSR 36241), and several

small parts, barge tank interior, and barge deck/rail surface coating operations, which are

authorized by 30 TAC §106.433 (PBR Registrations 54007, 34783, and 75773, respectively). As

such, the painting equipment cleaning operations for these NSR and PBR authorizations have

been authorized by PBR for “site‐wide” spray application and paint roller equipment cleaning

operations and are managed under a separate PBR authorization. This PBR should be



referenced as part of this permit renewal, and the PBR compliance records are maintained

separately for the site‐wide cleanup operations.

2.5 Planned Maintenance, Startup, and Shutdown (MSS) Activities All planned maintenance activities that are anticipated or scheduled at the Channelview yard

Dry Docks are covered under a Permit by Rule (PBR) in 30 TAC Chapter 106, or the activity is

listed on the de minimis source list under 30 TAC § 116.119. For example, temporary

maintenance facilities used for abrasive blasting, surface preparation, and surface coating on

immovable fixed structures (e.g., storage tanks) are authorized under 30 TAC §106.263(c)(3)(A)

and are not part of this NSR permit authorization. Barge or equipment maintenance and repairs

that require welding, soldering, or brazing equipment are authorized by 30 TAC §106.227.

Maintenance or repairs that require handheld and manually operated machines are authorized

by 30 TAC §106.265. The startup and shutdown emissions associated with facilities at the

Channelview site are no worse (or emits no more) than those emissions experienced during

normal operations. Therefore, the startup and shutdown emissions are covered in the current

permit maximum allowable emission rate tables.

2.6 Process Flow Diagram A process flow diagram, Figure 2‐1, is enclosed on the following page.

8.5x11 --- ATTACHED XREF'S: --- ATTACHED IMAGES: TEXAS- San Angelo;DRAWING NAME: C:\OF-TRC\DRAFTING-CDrive\PPL-Files\SW Shipyard\Channelview Site\380356\ Fig 2-1 - SW ShipYard-Channelview - PFD.dwg --- PLOT DATE: July 14, 2020 - 10:13AM --- LAYOUT: PFD-2


Houston, TX 77042Phone: 713.244.1000

Fig 2-1 - SW ShipYard-Channelview - PFD.dwg

DATE: JULY 2020

APPROVED BY: E. STANKO

CHECKED BY: N. HALAGERI

DRAWN BY: O. FONSEKA

FILE:

380356.0000PROJECT No.:

FIGURE 2-1

TITLE:

PROJECT:

.

NOTE:

ABRASIVE BLASTING AND COATING OPERATIONS AT THE DRY DOCKS OCCUR WITHIN MOBILE SHROUDS / MOVABLE ENCLOSURES.

PROCESS FLOW DIAGRAM

R NSR Permit 43774 enewal/Amendment




UNFINISHED BARGES

AND BOATS 15

DRY DOCK

8

DRY DOCK

12

DRY DOCK

ABRASIVE BLASTING

POTS

BLAST

ABRASIVE BLASTING

ABRASIVE BLASTING SURFACE COATING

SURFACE COATING

SURFACE COATING

BLAST MEDIACOAL / COPPER SLAG OR SILICA SAND

POT-FILL

EPN:

MOBILE SHROUDS

MOBILE SHROUDS

MOBILE SHROUDS

EPN: DD8

EPN: DD15

EPN: DD12

FILTER

EPN: DD15STK

FILTER

EPN: DD12STK

FILTER

EPN: DD8STK

CLEANUP

BLAST MEDIA

DD8CLN

EPN:

CLEANUP

BLAST MEDIA

DD15CLN

EPN:

CLEANUP

BLAST MEDIA

DD12CLN

EPN:

MOBILE SHROUDS

MOBILE SHROUDS

MOBILE SHROUDS



Section 3 Emission Calculations

This section describes and summarizes the air emissions associated with this permit application.

A summary of the maximum allowable emission rates (MAER) is provided in the Excel

workbook Form PI‐1 General Application located in Appendix A. Detailed emission calculation

tables are provided in Appendix B.

3.1 Dry Abrasive Blast Cleaning Emissions from dry abrasive blast cleaning occur whenever a barge or marine vessel must be

cleaned prior to surface coating. Blast cleaning results in emissions of PM, PM10, and PM2.5.

Blasting activities occur in movable enclosures (mobile shrouds). The mobile shroud is

equipped with dust collectors to capture and control PM, PM10, and PM2.5 emissions generated

from abrasive blasting. As described in Sections 2.1 and 2.2, all of the emissions from the

blasting operations conducted in the mobile enclosures are captured and routed to a dry filter

system for control. The dust collector filter system has a rated 99.9‐percent control efficiency for

particulates (PM/PM10/PM2.5), and specifications on the filter data is provided in Appendix F.

Emissions associated with abrasive blasting were calculated using the TCEQ Outdoor Coating

and Abrasive Blasting Emission Calculations and Impacts Analysis Workbook. Emissions are

based on equations and factors found in the TCEQ guidance document ʺAbrasive Blast

Cleaningʺ (document RG‐169, dated March 2001). The PM2.5 emissions from blasting were

considered 15‐percent of PM10 emissions per TCEQ guidance to ratio fugitive emissions using

the aerodynamic k factors in EPA Document AP‐42 Chapter 13.2.4. Specifically, the emission

factor for PM2.5 was derived based on the ratio of the PM10/PM2.5 and PM particle size multiplier

(k), obtained from the Section 13.2.4, “Aggregate Handling and Storage Piles”, November 2006,

of Environmental Protection Agency (EPA) AP‐42 publication [k[PM10] = 0.35; k[PM2.5] = 0.053;

EF PM2.5 = (0.053 / 0.35) × EF PM10].

Southwest Shipyard uses two types of blasting media; silica sand or copper/coal slag. The

maximum short‐term emission rates were based on usage of silica sand due to silica sand

having a higher emission factor, which represents the worst‐case potential to emit (PTE).

At any one time, twelve (12) blast nozzles may be used simultaneously at the three dry dock

locations. The blast nozzles have a maximum hourly spray rate of 1,000 pounds of material per



hour each. The maximum hourly emissions were based on use of 12 blast nozzles operating

simultaneously at the Dry Docks (12,000 lbs/hour or 6 tons/hour).

Annual emissions were conservatively based on 2,000 tons of silica sand blast media per year

and 18,000 tons of copper or coal slag low dusting abrasives per year (20,000 tons/year total).

However, Southwest Shipyard should be limited on the permitted annual emission rates in tons

per year (tpy), and not the annual throughput rates, because use of low dusting abrasives such

as coal or copper slag will have much lower actual emission rates, allowing for higher annual

throughput rates than what is used in the calculations based on silica sand.

3.2 Surface Coating Emissions from paint spray coating may occur whenever a barge or boat needs surface coating.

Surface coating operations result in emissions of VOC, Exempt Solvent (ES), PM, PM10, and

PM2.5. At any time, four (4) spray guns may be used to spray coatings simultaneously at the

three dry docks, with a maximum application rate of 40 gal/hr, with no more than four (4)

coating spray guns in use at any one EPN location (i.e. dry dock) at once. As discussed in

Section 2.3, surface coating activities occur in the shrouded dry dock areas. All the shrouds have

a material shade factor of 85‐percent or greater and are 35 ft. tall.

Maximum hourly spray coating emissions for each spray coating source were based on use of

spray guns applying either high‐gloss coating or applying weld‐through preconstruction

primer. Since no more than four (4) spray guns may be in use simultaneously, a short‐term

limit is proposed for the dry docks coating operations, plus paint roller coating operations.

Annual spray coating emissions were based on the annual sitewide coating usage and the

average VOC and solids contents of the coatings as determined on a weighted basis.

Specifically, annual average VOC and PM content (including PM10 and PM2.5) were calculated

based upon a weighted average of the coating usage at the dry docks. Since Southwest

Shipyard repairs a variety of vessels at the dry docks, the calculations were based on the

volume of coating used in each category rather than a specific amount of any one coating. The

annual emission rate calculations were based on the use of Chapter 115 compliant coatings.

Southwest Shipyard will not use more than 33,000 gallons of coating (as applied) for these

operations on an annual basis.

Emissions associated with spray application of coating are calculated using the TCEQ Outdoor

Coating and Abrasive Blasting Emission Calculations and Impacts Analysis Workbook. A

transfer efficiency factor was used in surface coating PM, PM10, and PM2.5 emission rate

calculations based on data obtained from Table 232 of the Air Pollution Engineering Manual,

AP‐40 (Air Pollution Control District of Los Angeles, U.S. EPA OAQPS). In accordance with



this engineering manual, the transfer efficiency percentage is a function of the type of

application equipment used and the part geometry. At the dry docks, coatings are applied

using airless spray guns and the coatings are applied to the surface of large marine vessels such

as barges and boats. Given the very large, flat surfaces in which the coatings are applied, and

the use of airless spray application equipment, the appropriate transfer efficiency is 80‐percent

as per Table 232 of the Air Pollution Engineering Manual. This table has been included in

Appendix B. PM fallout factors were acquired from the TCEQ surface coating guidance

document titled ʺPaint PM Emission Calculationsʺ dated April 4, 2011.

3.3 Roller Surface Coating Non‐skid surface coatings and deck striping coating application also occurs at these dry docks.

Coatings are applied via hand rollers; manual application of coatings using paint rollers result

in emissions of VOC and ES. Emissions associated with rolled on coatings are calculated using

the TCEQ Outdoor Coating and Abrasive Blasting Emission Calculations and Impacts Analysis

Workbook. As hand rollers have no associated overspray, a transfer efficiency factor of 100‐

percent is claimed. As such, no PM emissions are generated due to these operations.

3.4 Blast Pot Filling Particulate matter emissions occur when the blast pots are filled with abrasive material (EPN:

POT‐FILL). Blast media is gravity fed into the blast pots which are then moved to the abrasive

blasting areas. Emissions are generated at the blast pot via media loading operations. A

cover/skirt is used to partially enclose the blast pot filling operation, and therefore a partial

enclosure control efficiency of 85‐percent was applied to the emissions per TCEQ guidance

(TCEQ Rock Crushing Plants Guidance 2002).

Emissions generated from loading abrasives into the blast pot were calculated using the drop

point equation from the EPA Compilation of Air Pollutant Emission Factors AP‐42, Section

13.2.4. The maximum fill rate of the blast pots is 8.0 tons per hour (tph).

𝐸 𝑘 𝑥 0.0032 𝑥

𝑈5

.

𝑀2

.

Where:

E = emission factor, lb/ton loaded

k = particulate size multiplier, dimensionless

U = mean wind speed, mph

M = material moisture content, %



The particle size multiplier (k) is determined by AP‐42 Section 13.2.4.3. The mean wind speed

(U) is equivalent to the annual average wind speed provided in AP‐42 Section 7.1 Table 7.1‐9

“Average Annual Wind Speed (v) for selected U.S. Locations” for Houston, Texas, which is 7.4

mph. The moisture content is 1.0‐percent for the blast media used by Southwest Shipyard.

Annual emissions were based on 20,000 tons/year of blast media usage, which is consistent with

the abrasive blasting calculations.

3.5 Spent Media Cleanup After abrasive blasting operations are completed, the spent abrasive is cleaned up and collected

via utility vehicle and transferred to a spent abrasive storage building. The spent blast media

cleanup occurs within a tarped and shrouded area and therefore a partial enclosure control

efficiency of 85‐percent was applied to the emissions per TCEQ guidance (TCEQ Rock Crushing

Plants Guidance 2002). Particulate matter emissions are generated during the cleanup activities.

Emissions generated from spent media cleanup will be calculated with the drop point equation

from Section 13.2.4 of AP‐42.

𝐸 𝑘 𝑥 0.0032 𝑥

𝑈5

.

𝑀2

.

Where:

E = emission factor, lb/ton loaded

k = particulate size multiplier, dimensionless

U = mean wind speed, mph

M = material moisture content, %

The particle size multiplier (k) is determined by AP‐42 Section 13.2.4.3. The mean wind speed

(U) is equivalent to the annual average wind speed provided in AP‐42 Section 7.1 Table 7.1‐9

“Average Annual Wind Speed (v) for selected U.S. Locations” for Houston, Texas, which is 7.4

mph. The moisture content is assumed to be 1.0‐percent for all blast media used by Southwest

Shipyard.

As discussed above, at any individual dry dock, no more than twelve (12) nozzles are used at

any time. Therefore, a maximum rate of 6 tons per hour is used. Annual emissions were based

on 20,000 tons/year of blast media usage, which is consistent with the abrasive blasting

calculations.



3.6 Excel Workbook Calculations Detailed emission calculations including chemical speciation were performed using the Excel

Outdoor Coating and Abrasive Blasting Emission Calculations Workbook developed by the TCEQ Air

Permits Division (APD) Coatings Section, which has been submitted electronically to TCEQ Air

Permits via email ([email protected]) and is Appendix B of this application.



Section 4 Best Available Control Technology (BACT)

The TCEQ regulations require new or modified stationary sources to apply BACT in the control

of air contaminants that may be emitted from the project. As stated in 30 TAC §116.111(a)(2)(C),

any new or modified facility must utilize the best available control technology (BACT), with

consideration given to the technical practicability and economic reasonableness of reducing or

eliminating the emissions from the facility. The BACT analysis is accomplished using a three‐

tier approach. In each tier, BACT is reviewed on a case‐by‐case basis for technical practicability

and economic reasonableness. A BACT analysis is presented in the Form PI‐1 General

Application form; Excel workbook file.

In the first tier, emission controls established as BACT in recent permit reviews for the same

process or industry are evaluated. If no facilities have been recently permitted, a second tier

BACT review would be conducted, considering emission controls from similar sources in

industries other than the proposed sources evaluated. If no facilities have been recently

permitted in different processes or industries, a third tier BACT review can be considered,

including a detailed economic and engineering analysis in support of a BACT determination.

4.1 BACT for Enclosed Abrasive Blasting The Dry Docks use movable enclosures (mobile shrouds) in the abrasive blasting areas to

control offsite impacts from these operations. The mobile shrouds are used to enclose and

surround the equipment (i.e., barge or marine vessel) being blasted to minimize the

atmospheric entrainment of fine particles and direct the blasting material to a confined area for

disposal. The mobile shroud sides are connected and have overlapping seams to prevent

leakage of particulates.

The mobile shrouds are equipped with a filter control device to capture and control PM, PM10,

and PM2.5 emissions generated from abrasive blasting. All of the particulate emissions from the

blasting operations are controlled and routed to the dust collection systems. All emissions

captured from abrasive blasting are exhausted through a cartridge‐type dry filter system that

achieves an overall particulate removal efficiency of at least 99.9‐percent. The opacity shall not

exceed 5‐percent and/or there shall be no visible emission from each stack.

Spent filters from the dust collection system are removed in such a manner to minimize PM

emissions. This is performed by placing the spent filters in sealable bags or other sealable



containers prior to removal from the site. The bags or containers are kept closed at all times

except when adding spent filters.

In addition, the collection and removal of spent (waste) abrasive blast media is done in such a

manner to minimize dust emissions. This is performed by placing the spent blast media in

covered piles or in covered containers prior to removal from the site. Good housekeeping

procedures are maintained for spills. Therefore, the control system for Southwest Shipyard’s

abrasive blasting operations at the dry docks meets BACT.

4.2 BACT for Surface Coating Operations The dry docks use high solid content coatings and marine coatings compliant with 30 TAC

§115.421(a)(16) requirements. High transfer efficiency application equipment is utilized for the

surface coating operations. Specifically, airless paint spray application equipment or other

equipment that is demonstrated to reach the same or higher transfer efficiency, such as hand

rollers, are utilized for all surface coating operations. Manual paint rollers are typically only

used to apply non‐skid surface coatings and deck perimeter striping. As discussed in the

previous section, surface coating operation are carried out within mobile shrouds to mitigate

offsite impacts at all outdoor spray coating emission sources.

Southwest Shipyard employs good housekeeping procedures for control and minimization of

spills and has implemented best management practices (BMPs) to minimize fugitive emissions,

which include the following:

All coating materials and thinners/solvents spilled are cleaned up immediately. All

materials used to clean up the spill (i.e., rags, absorbent materials) are stored in sealed

containers until transported offsite for disposal.

All spray gun cleaning operations are performed by discharging the cleaning solvent into a

container. Any spent cleaning solvent accumulated as a result of spray gun cleaning

operations is placed in a closed container until either recycled on‐site or disposed of off‐

site.

All waste coatings are stored in closed containers until transported and disposed of off‐site

by a permitted/licensed carrier.



Section 5 Considerations for Granting a Permit Renewal

This section addresses the assurance of regulatory compliance by the proposed facility. The

requirement contained in TCEQ Rule 116.111(a)(2)(A)(i) states the following:

The emissions from the proposed facility will comply with all rules and regulations of the

commission and with the intent of the Texas Clean Air Act (TCAA), including protection of

health and property of the public.

As outlined in the following evaluation, the emissions from the dry docks comply with all rules

and regulations of the TCEQ and with the intent of the Texas Clean Air Act (TCAA).

Chapter 101 - General Rules Southwest Shipyard will comply with all requirements of the TCEQ General Rules.

Some notable rule compliance procedures are summarized below.

§101.3 Circumvention

There will not be the use of any mechanisms or devices to conceal or appear to minimize

the effects of emissions from sources within the site.

§101.4 Nuisance

There will be no emissions of air contaminants or combined emissions that would be

expected to injure or adversely affect human health or welfare, site or animal life, or

property in any way.

§101.5 Traffic Hazard

There will be no traffic hazards or interference caused by emissions from the site.

§101.8 Sampling

Upon request from the TCEQ, Southwest Shipyard will conduct sampling to determine

the opacity, rate, composition, or concentration of the stream requested.

§101.9 Sampling Ports

Southwest Shipyard will comply with the sampling port requirements found in this rule.



§101.10 Emissions Inventory Requirements

On an annual basis, Southwest Shipyard files the appropriate emissions data and

supporting information to the Emissions Assessment Section as directed by the

commission.

§101.13‐19 Administrative Provisions

Southwest Shipyard will comply with the applicable requirements in this section.

§101.20 Compliance with Environmental Protection Agency Standards

Southwest Shipyard has addressed compliance with EPA standards for the dry docks in

this application and will continue to comply with these standards.

§101.21 The National Primary and Secondary Ambient Air Quality Standards

(NAAQS)

The site will comply with all applicable requirements associated with the NAAQS.

§101.23 Alternate Emission Reduction (ʺBubbleʺ) Policy

Operation of the site will not be regulated by the Alternative Emission Reduction Policy.

§101.24 and §101.27 Inspection Fees and Emissions Fees

Southwest Shipyard will submit all appropriately assessed fees to the TCEQ and is

currently in good standing with respect to assessed fees.

§101.26 Surcharge on Fuel Oil in Specified Boilers

The site does not have an industrial boiler capable of combusting fuel oil; therefore, the

provisions of §101.26 do not apply.

§101.28 Stringency Determination for Federal Operating Permits

This application is not for a federal operating permit; therefore, this section does not

apply.

§101.201 Emissions Event Reporting and Recordkeeping Requirements

Southwest Shipyard complies with the requirements of this section, as necessary.



§101.211 Scheduled Maintenance, Startup, and Shutdown Reporting and

Recordkeeping Requirements

All planned maintenance activities that are anticipated or scheduled at the dry docks are

covered by a PBR under 30 TAC Chapter 106, or the activity is listed on the de minimis

list under 30 TAC §116.119(a)(1).

§101.221‐224 Operational Requirements, Demonstrations, and Actions to Reduce

Excess Emissions

Southwest Shipyard complies with the requirements of this section as necessary.

§101.231‐233 Variances

Southwest Shipyard is not requesting a variance with this application; therefore, these

sections do not apply.

§101.300‐311 Emission Credit Banking and Trading

This permit action does not result in any VOC or NOX emission reductions that will be

used for emission credit banking and trading.

§101.330‐339 Emissions Banking and Trading Allowances

These sections do not apply because this permit action does not include electric

generating facilities permitted under Chapter 116, Subchapter I (relating to Electric

Generating Facility Permits).

§101.350‐363 Mass Emission Cap and Trade Program

Southwest Shipyard is located in Harris County and is subject to the TCEQ Mass

Emission Cap & Trade (MECT) Program. However, since the dry abrasive blasting and

surface coating operations at the dry docks do not emit nitrogen compounds, this

specific project is exempt from the MECT Program.

§101.370‐379 Discrete Emission Credit Banking and Trading

Southwest Shipyard will not generate or use any discrete emission credits in association

with this permit action.

§101.390‐403 Highly‐Reactive Volatile Organic Compound Emissions Cap and

Trade Program

Southwest Shipyard does not emit any highly‐reactive volatile organic compounds

(HRVOCs) as a result of this project; therefore, the requirements of this section do not

apply.



§101.501‐508 Clean Air Interstate Rule

This application does not include a stationary, fossil fuel‐fired boiler or stationary, fossil

fuel‐fired combustion turbine meeting the applicability requirements under 40 Code of

Federal Regulations Part 96, Subpart AA or Subpart AAA; therefore, these sections do

not apply.

§101.600‐602 Expedited Permitting

Southwest Shipyard is not requesting expedited permitting under 30 TAC §101.600‐602,

therefore this section is not applicable.

Chapter 111 – Control of Air Pollution from Visible Emissions and Particulate Matter

§111.111‐113 Visible Emissions

Visible emissions from sources associated with this application will not exceed the

opacity limitations during the normal operations specified by these sections. Southwest

Shipyard will comply with all applicable opacity limitations specified in §111.111.

§111.121‐129 Incineration

The process addressed by this application does not have a solid waste incinerator;

therefore, these sections do not apply.

§111.131‐139 Abrasive Blasting of Water Storage Tanks Performed by Portable

Operations

There is no abrasive cleaning of water storage tanks associated with this permit;


§111.141‐149 Materials Handling, Construction, Roads, Streets, Alleys, and Parking

Lots

The Channelview Dry Docks are located in Harris County. However, the facility is not

located inside the loop formed by Beltway 8 and therefore is not included in the

Geographic Areas of Application. Therefore, these sections do not apply.

§111.151‐1535 Emissions Limits on Nonagricultural Processes

Southwest Shipyard complies with the requirements of these sections, as necessary.

§111.171‐175 Emissions Limits on Agricultural Processes

There are no agricultural processes at the facility; therefore, these sections do not apply.



§111.181‐183 Exemptions for Portable or Transient Operations

The facility is not a portable or transient operation; therefore, these sections do not

apply.

§111.201‐221 Outdoor Burning

Outdoor burning is not performed at the facility. Therefore, these sections do not apply.

Chapter 112 – Control of Air Pollution from Sulfur Compounds The dry docks blasting, and coating operations do not result in any amount of SO2

emissions; therefore, this Chapter does not apply.

Chapter 113 – Control of Air Pollution from Toxic Materials This chapter regulates the following:

1) 40 CFR 61, Subpart R (Radionuclide NESHAPs),

2) Regulations promulgated under 40 CFR Part 63,

3) Municipal solid waste landfills,

4) Hospital/medical/infectious waste incinerators, and

5) Consolidated federal air rules for synthetic organic compound manufacturing

industry (40 CFR Part 65)

Subchapter B of Chapter 113 incorporates by reference National Emission Standards for

Hazardous Air Pollutants (NESHAP, 40 CFR Part 61), and Subchapter C of Chapter 113

incorporates by reference National Emissions Standards for Hazardous Air Pollutants

for Source Categories (MACT, 40 CFR Part 63). The dry docks are not subject to any

NESHAP, nor is it subject to any Maximum Achievable Control Technology Standard

(MACT); therefore, this requirement does not apply.

Chapter 114 – Control of Air Pollution from Motor Vehicles Southwest Shipyard will operate its motor vehicles in compliance with the requirements

of this regulation as implemented in the State of Texas.



Chapter 115 – Control of Air Pollution from Volatile Organic Compounds

§115.110‐119 Storage of Volatile Organic Compounds

Southwest Shipyard shall comply with the applicable control, monitoring, testing,

recordkeeping, and reporting requirements in these sections.

§115.120‐129 Vent Gas Control

Southwest Shipyard shall comply with the applicable control, monitoring, testing,

recordkeeping, and reporting requirements in these sections.

§115.131‐139 Water Separation

There is no water separator associated with this permit application; therefore, these

regulations do not apply.

§115.140‐149 Industrial Wastewater

There is no industrial wastewater processing facility associated with this permit

amendment application; therefore, these sections do not apply.

§115.152‐159 Municipal Solid Waste Landfills

The site does not operate a municipal solid waste landfill; therefore, these sections do

not apply.

§115.160‐169 Batch Processes

Southwest Shipyard does not operate a batch process operation; therefore, these sections

do not apply.

§115.211 Emission Specifications (Loading and Unloading of VOCs)

The facility does not operate a gasoline terminal; therefore, §115.211 does not apply.

§115.212‐219 Loading and Unloading of Volatile Organic Compounds

Southwest Shipyard does not perform bulk loading or unloading of materials at the site

that contain VOC; therefore, these sections do not apply.

§115.221‐229 Filling of Gasoline Storage Vessels (Stage I) for Motor Vehicle Fuel

Dispensing Facilities

There is no motor vehicle fuel dispensing associated with this site; therefore, these




§115.234‐239 Control of Volatile Organic Compound Leaks from Transport Vessels

Southwest Shipyard shall comply with the applicable requirements of these sections.

§115.240‐248 Control of Vehicle Refueling Emissions (Stage II) at Motor Vehicle

Fuel Dispensing Facilities

There is no motor vehicle fuel dispensing associated with this site; therefore, these


§115.252‐259 Control of Reid Vapor Pressure of Gasoline

The site is not located in the El Paso area; therefore, these sections do not apply.

§115.311‐319 Process Unit Turnaround and Vacuum‐Producing Systems in

Petroleum Refineries

The site is not a petroleum refinery; therefore, these sections do not apply.

§115.322‐329 Fugitive Emission Control in Petroleum Refineries in Gregg, Nueces,

and Victoria Counties

The site is not a petroleum refinery and is not located in one of these counties; therefore,

these sections do not apply.

§115.352‐359 Fugitive Emission Control in Petroleum Refining, Natural

Gas/Gasoline Processing, and Petrochemical Processes

The Channelview site is not a petroleum refinery, or a synthetic organic chemical,

polymer, resin, or methyl tert‐butyl ether manufacturing process, or a natural

gas/gasoline processing operation; therefore, these regulations do not apply.

§115.410‐419 Degreasing Processes

The site does not operate a degreasing process; therefore, these regulations do not apply.

§115.420‐429 Surface Coating Processes

Southwest Shipyard will comply with the applicable requirements associated with

surface coating processes. Specifically, the facility will comply with the requirements of

§115.421(16) as to the allowable VOC content of marine coatings applicable to

shipbuilding and ship repair operations. The VOC emission limits of this rule are based

on the VOC content of the coatings as delivered to the application system. A

demonstration that the as mixed, thinned, and ready to spray coating VOC contents

meet the limits in Chapter 115 is provided in Appendix B. The table provides the VOC

content of coatings utilized at the dry docks, the coating category, VOC limits specified



in 30 TAC §115.421(16)(A), as well as maximum allowable thinning ratios specified in 30

TAC §115.421(16)(B)(i). For coatings that are noncompliant with the corresponding VOC

content limit (less water and exempt solvent), daily averaging will be used to

demonstrate site compliance.

In addition, the facility will also comply with the requirements of §115.422(4), Control

Requirements. This will include the following:

— All handling and transfer of VOC‐containing materials to and from containers,

tanks, vats, drums, and piping systems is conducted in a manner that minimizes

spills.

— All containers, tanks, vats, drums, and piping systems are free of cracks, holes, and

other defects and remain closed unless materials are being added to or removed

from them.

— All organic solvent used for line cleaning or to clean spray guns is pumped or

drained into a normally closed container.

§115.430‐539 Flexographic and Rotogravure Processes, Offset Lithographic Printing,

Cutback Asphalt and Pharmaceutical Manufacturing Facilities

The Southwest Shipyard Channelview site does not operate these types of facilities;


§115.540‐549 Degassing or Cleaning of Stationary, Marine, and Transport Vessels

Southwest Shipyard will comply with the applicable requirements associated with the

cleaning of storage tanks or transport vessels.

§115.552‐619 Petroleum Dry Cleaning Systems and Consumer‐Related Sources

Southwest Shipyard does not operate these types of facilities; therefore, these sections do

not apply.

§115.720‐789 Highly‐Reactive Volatile Organic Compounds

The dry dock operations do not emit any amount of HRVOC; therefore, it is not subject

to HRVOC requirements.

§115.901‐916 Alternate Means of Control (AMOC)

Southwest Shipyard is not requesting an AMOC as part of this permit application;




§115.920‐923 Early Reductions

Southwest Shipyard is not requesting an extension to comply with any requirement in

this chapter; therefore, these sections do not apply.

§115.930‐940 Compliance and Control Plan Requirements

A schedule for achieving compliance with the applicable sections of this regulation will

be provided upon request by the Executive Director.

§115.950 Emissions Trading

Emission reduction credits and discrete emission reduction credits will not be used to

meet the emission control requirements of this chapter.

Chapter 116 – Control of Air Pollution by Permits for New Construction or Modification

§116.110 Applicability

(a) The purpose of this permit amendment application is to update permit

representations to match the facility operations, add emissions from filling abrasive

material in the blast pots as well emissions from cleaning up of spent blast media.

This permit amendment application will satisfy all requirements of

30 TAC §116.111.

(b) A portion of this permit application is seeking to modify the emission rates from

existing permitted facilities. As such, the proposed modifications to the emission

rates from existing permitted facilities will be authorized through the amendment

of an existing NSR permit.

(c) This application is submitted to modify the emission rates from existing permitted

facilities and is subject to the compliance history review requirements under

30 TAC Chapter 60.

(d) The Channelview site is not a major source of HAP.

(e) Change of ownership rules do not apply to this application.

(f) Southwest Shipyard is not required to submit this application under seal of a Texas

licensed professional engineer.

Southwest Shipyard is the owner and operator of the Channelview site and is

responsible for compliance with the requirements in §116.110(g).



§116.111(a)(1) and (2)(A) Protection of Public Health and Welfare and Proximity to Schools

A completed Form PI‐1 General Application form; Excel workbook file (version 4.0), has

been submitted electronically to TCEQ APIRT. This application includes information

demonstrating that the emission rates from the affected facilities associated with this

proposed modification at the facility comply with the rules and regulations of the TCEQ

and the intent of the Texas Clean Air Act, including protection of health and property of

the public.

As indicated on Figure 1‐1, there are no schools located within 3,000 feet from the

facility.

§116.111(a)(2)(B) Measurement of Emissions

Southwest Shipyard will have provisions for measuring the emission of significant air

contaminants as determined by the executive director.

§116.111(a)(2)(C) Best Available Control Technology (BACT)

Southwest Shipyard utilizes BACT with consideration given to the technical

practicability and economic reasonableness of reducing emissions. A BACT analysis is

presented in Section 4 of this application as well as in the Form PI‐1 General Application

form; Excel workbook file.

§116.111(a)(2)(D) Federal New Source Performance Standards (NSPS)

The emission sources in this application are not subject to any New Source Performance

Standards (NSPS) as specified in 40 CFR Part 60; therefore, this requirement is not

applicable.

§116.111(a)(2)(E) National Emission Standards for Hazardous Air Pollutants (NESHAP)

The Channelview site is not a major source of HAPs and the emission sources at the site

are not subject to any National Emission Standards for Hazardous Air Pollutants

(NESHAP) as specified in 40 CFR Part 61; therefore, this requirement is not applicable.

§116.111(a)(2)(F) NESHAP for Source Categories

The Channelview dry docks are subject to the MACT standards as promulgated under

40 CFR Part 63, Subpart II — National Emission Standards for Shipbuilding and Ship

Repair. To ensure compliance with this regulation, Southwest Shipyard will follow the

following four principles:

— Use only compliant coatings;



— Do not thin any coatings beyond the associated maximum allowable thinning ratio;

— Use good work practices when handling and transferring coatings, solvents, and/or

resulting wastes; and

— Follow all recordkeeping and reporting requirements.

Southwest Shipyard is in compliance with 40 CFR Part 63, Subpart II, and will

remain in compliance.

§116.111(a)(2)(G) Performance Demonstration

Southwest Shipyard will achieve the performance specified in this application. As may

be requested by the Executive Director, additional performance data and testing will be

provided as appropriate in order to demonstrate further that the proposed facility will

achieve the performance specified in the application.

§116.111(a)(2)(H) Nonattainment Review

The Channelview site is located in Harris County, Texas which is classified as a

nonattainment area for ozone under the 1‐hour and 8‐hour standards. There are no

proposed increases in VOC emissions from this project. Therefore, non‐attainment

permitting requirements do not apply to this facility.

§116.111(a)(2)(I) Prevention of Significant Deterioration (PSD) Review

Prevention of Significant Deterioration (PSD) is not applicable for this project. The

Southwest Shipyard Channelview yard is not considered to be among the 28 designated

source categories as listed in 40 CFR §51.166(b)(1). Current annual Potential To Emit

(PTE) emission rates of all NSR regulated pollutants are all less than their respective

major source designation thresholds and there are no proposed increases of these

pollutants. Therefore, PSD permitting requirements do not apply.

§116.111(a)(2)(J) Air Dispersion Modeling

Southwest Shipyard performed refined air dispersion modeling, which is included in

the Electronic Modeling Evaluation Workbook (EMEW) in Appendix C and discussed in

Section 1.9.

§116.111(a)(2)(K) Hazardous Air Pollutants

This project does not constitute construction or reconstruction of a major source of HAPs,

therefore this section does not apply.



§116.111(a)(2)(L) Mass Cap and Trade Allowances

Southwest Shipyard is located in Harris County and is subject to the TCEQ Mass Emission

Cap & Trade (MECT) Program. However, since the dry docks dry abrasive blasting

operations do not emit nitrogen compounds, this specific project is exempt from the MECT

Program.

§116.112 Distance Limitations

The Channelview site is not a lead smelter or hazardous waste management facility;


§116.114 Application Review Schedule

Southwest Shipyard will comply with all conditions of the TCEQ permit review

schedule.

§116.115 General and Special Conditions

Southwest Shipyard will comply with all conditions and provisions of the TCEQ air

permit.

§116.116 Changes to Facilities

The Channelview site will be operated in accordance with the representations made in

this application. Any changes in construction or operation resulting in changes in the

method of controlling emissions, the character of the emissions, or an increase in

emissions will be preceded by proper authorization.

§116.117 Documentation and Notification of Changes to Qualified Facilities

This section does not apply to this permit application.

§116.118 Pre‐Change Qualification

This section does not apply to this permit application.

§116.119 De Minimis Facilities or Sources

Southwest Shipyard performs maintenance activities that are considered as de minimis

sources under 30 TAC §116.119(a)(1). A listing of the planned activities that are de

minimis facilities or sources is provided in Appendix D.

§116.120 Voiding of Permits

This permit amendment application does not involve voiding permit.



§116.127 Actual to Projected Actual and Emissions Exclusion Test for Emissions

This section does not apply to this permit amendment application.

§116.128 Amendment Application, Public Notice and Contested Case Hearing

Procedures for Certain Electric Generating Facilities

The Channelview site is not an electric generating facility; therefore, this section does not

apply.

§116.131 Public Notification and Comment Procedures

Southwest Shipyard will comply with the public notification and comment procedures

in accordance with this section.

§116.141 Permit Fees

Southwest Shipyard will remit the appropriate application fees in accordance with this

section.

§116.150 New Major Source or Major Modification in Ozone Nonattainment

Area

The Channelview site is located in Harris County, Texas which is classified as a

nonattainment area for ozone under the 1‐hour and 8‐hour standards. There are no

proposed increases in annual VOC emissions. Therefore, non‐attainment permitting

requirements do not apply to this facility.

§116.151 New Major Source or Major Modification in Nonattainment Area

Other Than Ozone

The Channelview site is located in Harris County, which is an attainment area for all

criteria pollutants other than ozone and therefore is not subject to the requirements of

this section.

§116.160‐163 Prevention of Significant Deterioration Review

The Channelview site is located in Harris County, Texas, which has been designated as

an attainment area for the NAAQS for NOX, CO, PM, PM10, PM2.5 and SO2. There are no

emissions of NOX, SO2 and CO from this project and the proposed emission increases for

PM, PM10, and PM2.5 from this project are less than the PSD netting threshold, therefore

PSD regulations do not apply.



§116.164 and 169 Greenhouse Gases

Southwest Shipyard is not subject to a PSD review for Greenhouse Gases (GHGs).

Therefore, the requirements of this section do not apply to this application.

§116.170‐176 Emission Reductions: Offsets

Emission offsets are not required for this project.

§116.178 Portable Facilities

There are not any portable facilities associated with this project. Therefore, the

requirements of this section do not apply.

§116.180‐198 Site‐wide Applicability Limits

Southwest Shipyard does not have a site‐wide applicability limit (PAL) permit and is

not requesting one under this amendment application. Therefore, these sections do not

apply to this permit application.

§116.311(a)(1) Inclusion of Dockside Emissions

Southwest Shipyard does not have any dockside emissions associated with this facility.

§116.311(a)(2) Compliance with Existing Permit

Southwest Shipyard operates in compliance with the existing Permit No. 43774.

§116.311(a)(3) Compliance with NSPS

The emission sources in this application are not subject to New Source Performance

Standards (NSPS); therefore, this requirement is not applicable.

§116.311(a)(4) Compliance with NESHAPs

The emission sources in this application are not subject to any National Emission

Standards for Hazardous Air Pollutants (NESHAP) as specified in 40 CFR 61; therefore,

this requirement is not applicable.

§116.311(a)(5) Compliance with MACT

The facility is subject to the MACT standards as promulgated under 40 CFR Part 63,

Subpart II — National Emission Standards for Shipbuilding and Ship Repair. To ensure

compliance with this regulation, Southwest Shipyard will follow the following four

principles:

— Use only compliant coatings;

— Do not thin any coatings beyond the associated maximum allowable thinning ratio;



— Use good work practices when handling and transferring coatings, solvents, and/or

resulting wastes; and

— Follow all recordkeeping and reporting requirements.

Since this amendment is for the increase of an existing process, Southwest Shipyard is

already in compliance with Subpart II and will remain in compliance.

§116.311(a)(6) Compliance with 112(g)

The Section 112(g) program is designed to ensure that emissions of Hazardous Air

Pollutants (HAPs) do not increase if a facility that is a major source of HAPs is

constructed or reconstructed before EPA issues a MACT or air toxics regulation for that

particular source category. Southwest Shipyard is not a major source of HAP emissions,

i.e. site‐wide emissions are less than 10 tons per year of any single HAP and less than 25

tons per year of total HAPs; therefore, this section is not applicable.

§116.311(b) Additional Requirements

Southwest Shipyard will comply with these requirements if the TCEQ determines that

they are necessary to avoid a condition of air pollution or to ensure compliance with

otherwise applicable requirements or regulations.

§116.312 Public Notification

Southwest Shipyard will comply with the public notification and comment procedures

in accordance with this section.

§116.313 Renewal Application Fees

Southwest Shipyard will remit the appropriate renewal application fees in accordance

with this section.

§116.315 Permit Renewal Submittal

Southwest Shipyard is submitting this application in accordance to schedule specified in

§116.315(a).

§116.400‐406 Hazardous Air Pollutants: Regulations Governing Constructed or

Reconstructed Major Sources

Southwest Shipyard is not constructing or reconstructing a major source. Therefore, the

requirements of this section do not apply.



§116.601‐620 Standard Permits

This application is not a request for authorization under a Standard Permit; therefore,

these sections do not apply to this permit renewal application.

§116.710‐760 Flexible Permits

Southwest Shipyard does not operate under a flexible permit and this application is not

a request for authorization under a Flexible Permit; therefore, these sections do not

apply to this permit application.

§116.770‐807 Permits for Grandfathered Facilities

These sections do not apply to this permit amendment application.

§116.810‐870 Voluntary Emission Reduction Permit


§116.910‐931 Electric Generating Facility Permits

The Channelview site is not an electric generating facility; therefore, these sections do

not apply.

§116.1010‐1070 Multiple Site Permits


§116.1200 Emergency Orders

Southwest Shipyard will apply for an emergency order in compliance with these rules if

a catastrophic event occurs that necessitates such action.

§116.1400‐1428 Permits for Specific Designated Facilities


§116.1500‐1540 Best Available Retrofit Technology (BART)


Chapter 117 – Control of Air Pollution from Nitrogen Compounds The Dry Dock operations at Southwest Shipyard do not generate nitrogen compounds,

therefore this section is not applicable for this permitting action. The Southwest

Shipyard site operates and will continue to operate in compliance with Chapter 117.



Chapter 118 – Control of Air Pollution Episodes Southwest Shipyard will implement all reasonably available emission reduction

methods in the event of a Level I air pollution episode and will comply with the TCEQ

directions to reduce or curtail emission rates in the event of a Level II episode.

The Channelview site is located in Harris County, Texas but does not have the potential

to emit 100 tpy or more of any air contaminant specified on Table 1 of §118.1; therefore,

the facility is not required to prepare or maintain an emissions reduction plan.

Chapter 122 – Federal Operating Permits As required by 30 TAC Chapter 122, Southwest Shipyard has obtained SOP No. O‐1260.

Southwest Shipyard operates and will continue to operate in compliance with Chapter

122. No elementary, junior high/middle, or senior high schools are located within feet

of the Southwest Shipyard Facility as can be seen in the area map Figure 1‐1 of this

permit amendment application.



\\HOUSTON‐FP1\DATA\PROJECTS‐PPL\WPHOU\PJT2\340745\0000\R340745.0000‐002.DOCX 7/14/2020 Final July 2020

Appendix A PI-1 General Application and Fee Payment

TCEQ Form PI-1 General Application Excel Workbook

Copy of Check

Texas Commission on Environmental QualityForm PI-1 General Application

General

Date: July 2020Permit #: 43774

Company: Southwest Shipyard, L.P.

I agree

I acknowledge that I am submitting an authorized TCEQ application workbook and any necessary attachments. Except for inputting the requested data and adjusting row height and column width, I have not changed the TCEQ application workbook in any way, including but not limited to changing formulas, formatting, content, or protections.

https://www.sos.state.tx.us

Project Manager

Mailing Address:

Prefix (Mr., Ms., Dr., etc.): Ms.

77530Telephone Number:

Texas

TRC Environmental Corporation

281-860-3214Email Address: [email protected]

Address Line 2:

StankoTitle:

State:

713-378-8757Fax Number:


Mailing Address: 18310 Market Street

City:

ZIP Code:

Channelview

Last Name:

City: HoustonState: Texas

Company or Legal Name:

I. Applicant Information

Texas Secretary of State Charter/Registration Number (if given):

C. Technical Contact Information: This person must have the authority to make binding agreements and representations on behalf of the applicant and may be a consultant. Additional technical contact(s) can be provided in a cover letter.

A. Company Information

B. Company Official Contact Information: must not be a consultantPrefix (Mr., Ms., Dr., etc.): Mr.First Name: BernardLast Name: DiazTitle: Managing Director of Environmental Operations

Permits are issued to either the facility owner or operator, commonly referred to as the applicant or permit holder. List the legal name of the company, corporation, partnership, or person who is applying for the permit. We will verify the legal name with the Texas Secretary of State at (512) 463-5555 or at:

Company or Legal Name:

713-244-1039

D. Assigned Numbers

CN600135354Enter the CN. The CN is a unique number given to each business, governmental body, association, individual, or other entity that owns, operates, is responsible for, or is affiliated with a regulated entity.

Telephone Number:Fax Number:Email Address: [email protected]

The CN and RN below are assigned when a Core Data Form is initially submitted to the Central Registry. The RN is also assigned if the agency has conducted an investigation or if the agency has issued an enforcement action. If these numbers have not yet been assigned, leave these questions blank and include a Core Data Form with your application submittal. See Section VI.B. below for additional information.

713-789-5920

ZIP Code: 77042

First Name: Elizabeth

10550 Richmond Avenue Suite 210Address Line 2:

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General



No

HAP Major Source [FCAA § 112(g)]: Not applicable, Initial, Major ModificationPAL: Not applicable, Initial, Amendment, Renewal, Renewal/Amendment, AlterationGHG PSD: Not applicable, Initial, Major Modification, Voluntary Update

Not applicable

Not applicable

Not applicable

Permit Number (if assigned)

Enter the RN. The RN is a unique agency assigned number given to each person, organization, place, or thing that is of environmental interest to us and where regulated activities will occur. The RN replaces existing air account numbers. The RN for portable units is assigned to the unit itself, and that same RN should be used when applying for authorization at a different location.

This cell intentionally left blank

Not applicable

II. Delinquent Fees and Penalties


Minor NSR (can be a Title V major source): Not applicable, Initial, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Relocation/Alteration, Change of Location, Alteration, Extension to Start of Construction

Additional information regarding the different NSR authorizations can be found at:

RN100248749

Nonattainment: Not applicable, Initial, Major Modification

Flexible: Not applicable, Initial, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Alteration, Extension to Start of Construction

Not applicable

Action Type Requested(do not leave blank)

Does the applicant have unpaid delinquent fees and/or penalties owed to the TCEQ?This form will not be processed until all delinquent fees and/or penalties owed to the TCEQ or the Office of the Attorney General on behalf of the TCEQ are paid in accordance with the Delinquent Fee and Penalty Protocol. For more information regarding Delinquent Fees and Penalties, go to the TCEQ Web site at:https://www.tceq.texas.gov/agency/financial/fees/delin

Not applicable

43774

Select from the drop-down the type of action being requested for each permit type. If that permit type does not apply, you MUST select "Not applicable".

Provide all assigned permit numbers relevant for the project. Leave blank if the permit number has not yet been assigned.

https://www.tceq.texas.gov/permitting/air/guidance/authorize.html

Renewal/Amendment

Permit Type

A. Permit and Action Type (multiple may be selected, leave no blanks)

Special Permit: Not applicable, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Alteration, Extension to Start of Construction

III. Permit Information

De Minimis: Not applicable, Initial Not applicable

Not applicable

PSD: Not applicable, Initial, Major Modification

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General



No

No

Yes

No

Is this facility located at a site required to obtain a site operating permit (SOP) or general operating permit (GOP)?

How are/will MSS activities for sources associated with this project be authorized? Permit by Rule

List the permit number, registration number, and/or PBR number.

Are there any standard permits, standard exemptions, or PBRs to be incorporated by reference?If yes, list any PBR, standard exemptions, or standard permits that need to be referenced:

Is a SOP or GOP review pending for this source, area, or site?

Are there any PBR, standard exemptions, or standard permits associated to be incorporated by consolidation? Note: Emission calculations, a BACT analysis, and an impacts analysis must be attached to this application at the time of submittal for any authorization to be incorporated by consolidation.

PBR 155161

B. MSS Activities

N/A

Will this permit be consolidated into another NSR permit with this action?

To ensure protectiveness, previously issued authorizations (standard permits, standard exemptions, or PBRs) including those for MSS, are incorporated into a permit either by consolidation or by reference. At the time of renewal and/or amendment, consolidation (in some cases) may be voluntary and referencing is mandatory. More guidance regarding incorporation can be found in 30 TAC § 116.116(d)(2), 30 TAC § 116.615(3) and in this memo:

https://www.tceq.texas.gov/assets/public/permitting/air/memos/pbr_spc06.pdf

C. Consolidating NSR Permits

D. Incorporation of Standard Permits, Standard Exemptions, and/or Permits By Rule (PBR)

E. Associated Federal Operating Permits

No

Will NSR permits be consolidated into this permit with this action?

Yes

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General



No

Serious Ozone nonattainment

Permanent or portable facility?

B. General Information

If required to obtain a SOP or GOP, list all associated permit number(s). If no associated permit number has been assigned yet, enter "TBD":

Site Name:

Are there any schools located within 3,000 feet of the site boundary?

City: If the address is not located in a city, then enter the city or town closest to the facility, even if it is not in the same county as the facility.ZIP Code: Include the ZIP Code of the physical facility site, not the ZIP Code of the applicant's mailing address.

Longitude (in degrees, minutes, and nearest second (DDD:MM:SS)) for the street address or the destination point of the driving directions. Longitude is the angular distance of a location west of the prime meridian and will always be between 93 and 107 degrees west (W) in Texas.

Latitude (in degrees, minutes, and nearest second (DDD:MM:SS)) for the street address or the destination point of the driving directions. Latitude is the angular distance of a location north of the equator and will always be between 25 and 37 degrees north (N) in Texas.

C. Portable FacilityPermanent

Harris

Area Name: Must indicate the general type of operation, process, equipment or facility. Include numerical designations, if appropriate. Examples are Sulfuric Acid Plant and No. 5 Steam Boiler. Vague names such as Chemical Plant are not acceptable.

County attainment status as of Sept. 23, 2019

1260


Is this a project for a lead smelter, concrete crushing facility, and/or a hazardous waste management facility?

County: Enter the county where the facility is physically located.

Shipbuilding and Ship Repair Facility

77530

Street Address:

095:03:55

Site Location Description: If there is no street address, provide written driving directions to the site. Identify the location by distance and direction from well-known landmarks such as major highway intersections.

A. LocationIV. Facility Location and General Information

TCEQ Region Region 12

029:47:23

Use USGS maps, county maps prepared by the Texas Department of Transportation, or an online software application such as Google Earth to find the latitude and longitude.

D. Industry Type

18310 Market Street

No

Channelview Dry Docks Facilities

Channelview

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General



No

Yes

No

No

D. Operating Schedule

Projected Start of Construction: August 1, 2020

336611Principal NAICS code:


B. Is the Core Data Form (Form 10400) attached?

All representations regarding construction plans and operation procedures contained in the permit application shall be conditions upon which the permit is issued. (30 TAC § 116.116)

State Senator:

NAICS codes and conversions between NAICS and SIC Codes are available at:

Carol Alvarado

https://www.census.gov/eos/www/naics/

E. State Senator and Representative for this site

https://wrm.capitol.texas.gov/This information can be found at (note, the website is not compatible to Internet Explorer):

Authorization must be obtained for many projects before beginning construction. Construction is broadly interpreted as anything other than site clearance or site preparation. Enter the date as "Month Date, Year" (e.g. July 4, 1776).

Will sources in this project be authorized to operate 8760 hours per year?

Renewal and concurrent permit amendment to add exempt solvent (ES) and PM2.5 emissions to the permit MAERT, which have always been present at the facility but never before identified in the permit. Project requests to update the permit representations and emission calculations, which includes the addition of new sources of particulate matter (PM/PM10/PM2.5) and revised numbering of EPNs.

Is this application in response to, or related to, an agency investigation, notice of violation, or enforcement action?

August 1, 2020

Provide a brief description of the project that is requested. (Limited to 500 characters).

A list of SIC codes can be found at:

VI. Application Materials

https://www.tceq.texas.gov/assets/public/permitting/centralregistry/10400.docx

A. Confidential Application MaterialsIs confidential information submitted with this application?

https://www.naics.com/sic-codes-industry-drilldown/

Principal Company Product/Business:

C. Enforcement ProjectsProjected Start of Operation:

Briscoe Cain

3731Principal SIC code:

District: 6

B. Project Timing

A. DescriptionV. Project Information

128District:State Representative:



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General



Yes

Yes

YesYes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

N/A

N/A

N/A

Yes

Yes

Yes

H. Is a material balance (Table 2, Form 10155) attached?

C. Is a current area map attached?

Does the map show a 3,000-foot radius from the property boundary?

G. Are detailed calculations attached? Calculations must be provided for each source with new or changing emission rates. For example, a new source, changing emission factors, decreasing emissions, consolidated sources, etc. You do not need to submit calculations for sources which are not changing emission rates with this project. Please note: the preferred format is an electronic workbook (such as Excel) with all formulas viewable for review. It can be emailed with the submittal of this application workbook.

Does the process description also explain how the facility or facilities will be operating when the maximum possible emissions are produced?

Is the area map a current map with a true north arrow, an accurate scale, the entire plant property, the location of the property relative to prominent geographical features including, but not limited to, highways, roads, streams, and significant landmarks such as buildings, residences, schools, parks, hospitals, day care centers, and churches?

Are emission rates and associated calculations for planned MSS facilities and related activities attached?

J. Is a discussion of state regulatory requirements attached, addressing 30 TAC Chapters 101, 111, 112, 113, 115, and 117?For all applicable chapters, does the discussion include how the facility will comply with the requirements of the chapter?For all not applicable chapters, does the discussion include why the chapter is not applicable?

I. Is a list of MSS activities attached?

D. Is a plot plan attached?Does your plot plan clearly show a north arrow, an accurate scale, all property lines, all emission points, buildings, tanks, process vessels, other process equipment, and two bench mark locations?

Does your plot plan identify all emission points on the affected property, including all emission points authorized by other air authorizations, construction permits, PBRs, special permits, and standard permits?Did you include a table of emission points indicating the authorization type and authorization identifier, such as a permit number, registration number, or rule citation under which each emission point is currently authorized?E. Is a process flow diagram attached?Is the process flow diagram sufficiently descriptive so the permit reviewer can determine the raw materials to be used in the process; all major processing steps and major equipment items; individual emission points associated with each process step; the location and identification of all emission abatement devices; and the location and identification of all waste streams (including wastewater streams that may have associated air emissions)?F. Is a process description attached?Does the process description emphasize where the emissions are generated, why the emissions must be generated, what air pollution controls are used (including process design features that minimize emissions), and where the emissions enter the atmosphere?

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Renewals



Yes

Yes

Yes

No

No

YesYes

Yes

Yes

Yes

II. Federal Regulatory QuestionsThis cell intentionally left blank

A. Current Operations

B. Changes Made Since Last Amendment or RenewalHave any of the following changes been made to or proposed for the facilities covered by this permit since it was last amended or renewed and are not currently authorized by a PBR, standard permit, or other authorization? Select "Yes" or "No" to answer each question.

Do all dockside vessel emissions associated with the facility comply with all rules and regulations of the commission and with the intent of the TCAA, including protection of the health and property of the public and minimization of emissions to the extent possible, consistent with good air pollution practices? (30 TAC § 116.311(a)(1))

Have emission factors changed since the last permitting action?

If "yes" to any question in Section B above is selected, a concurrent permit amendment is required before the permit can be renewed.

An increase in emission rates on a short term or annual basis? (This includes increases of a criteria pollutant as well as increases of a chemical species.)A change in the method of emission control if the emission control is a source itself, such as a thermal oxidizer or flare?Are new pollutants being added in the renewal process, not currently listed in the permit?

I. Type of Permit Renewal and Associated Actions

Permit Alteration to remove EPNs: ST1 and FUGST1 from the air permit, which are being administratively transferred from NSR Permit 43774 to NSR Permit 9442 (TCEQ Project No. 317595)

7/6/2020

Press TAB to move input areas. Press UP or DOWN ARROW in column A to read through the document.

Additional Information for Renewal ProjectsThis sheet must be completed for all renewal projects. If you can see the page header, there are questions applicable to your project on this sheet.

Instructions:1. Complete all applicable sections below.2. Continue to the Technical sheet for additional questions.Click here to return to Cover Sheet.

Is the facility being operated in accordance with all requirements and conditions of the existing permit, including representations in the application for permit to construct and subsequent amendments, and any previously granted renewal, unless otherwise authorized for a qualified facility?

Permit Action: Date Submitted:If Yes, list actions and dates of submittal:

Have any qualified facility changes under 30 TAC § 116.116(e) occurred since originally issued or last renewed?

Construction of a new emission source?The emission of new chemical species or a change in character of emissions?

Are there any permit actions pending before the TCEQ?

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Renewals



If applicable, list applicable subparts you will demonstrate compliance with (e.g. Subpart VVVV)

Subpart II


Indicate if any of the following requirements apply to the proposed facility. Note that some federal regulations apply to minor sources. Enter all applicable Subparts.A. Title 40 CFR Part 60Do NSPS subpart(s) apply to a facility in this application? No

B. Title 40 CFR Part 61Do NESHAP subpart(s) apply to a facility in this application? No

Do MACT subpart(s) apply to a facility in this application? Yes

C. Title 40 CFR Part 63

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Technical



I. Additional Questions for Specific NSR Minor Permit Actions

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Technical



E. Concrete Batch PlantsNoIs this a project for a concrete batch plant?


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http://www.txdirectory.com/







Technical




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Technical




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Technical





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Technical



Yes

No

No

Yes

No

Does this project require an impacts analysis?

Is this facility located at a site within the Houston/Galveston nonattainment area (Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties)?


IX. Emissions ReviewA. Impacts AnalysisAny change that results in an increase in off-property concentrations of air contaminants requires an air quality impacts demonstration. Information regarding the air quality impacts demonstration must be provided with the application and show compliance with all state and federal requirements. Detailed requirements for the information necessary to make the demonstration are listed on the Impacts sheet of this workbook.

Is Mass Emissions Cap and Trade applicable to the new or modified facilities?

B. Disaster ReviewIf the proposed facility will handle sufficient quantities of certain chemicals which, if released accidentally, would cause off-property impacts that could be immediately dangerous to life and health, a disaster review analysis may be required as part of the application. Contact the appropriate NSR permitting section for assistance at (512) 239-1250. Additional Guidance can be found at:https://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/disrev-factsheet.pdfDoes this application involve any air contaminants for which a disaster review is required?

C. Air Pollutant Watch ListCertain areas of the state have concentrations of specific pollutants that are of concern. The TCEQ has designated these portions of the state as watch list areas. Location of a facility in a watch list area could result in additional restrictions on emissions of the affected air pollutant(s) or additional permit requirements. The location of the areas and pollutants of interest can be found at:https://www.tceq.texas.gov/toxicology/apwl/apwl.htmlIs the proposed facility located in a watch list area?

D. Mass Emissions Cap and Trade

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https://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/disrev-factsheet.pdf






http://www.tceq.texas.gov/toxicology/apwl/apwl.html








Texas Commission on Environmental QualityForm PI-1 General ApplicationUnit Types - Emission Rates



Action Requested (only 1 action per FIN)

Include these emissions in annual (tpy) summary?

Facility ID Number (FIN)

Emission Point Number (EPN) Source Name Pollutant

Current Short-Term (lb/hr)

Current Long-Term (tpy)

ConsolidatedCurrent Short-Term (lb/hr)

Consolidated Current Long-Term (tpy)

Proposed Short-Term (lb/hr)

Proposed Long-Term (tpy)

Short-Term Difference (lb/hr)

Long-Term Difference (tpy)

Unit Type (Used for reviewing BACT and Monitoring Requirements)

Unit Type Notes (only if "other" unit type in Column O)

New/Modified No DD8 DD8 Surface Coating VOC 149.66 32.25 149.66 32.25 Painting/Surface Coating (Non-Enclosed / Outdoor)

Exempt Solvents 37.69 1.9 37.69 1.9

PM 2.62 1.08 2.62 1.08PM10 0.24 0.1 0.24 0.1PM2.5 0.02 0.01 0.02 0.01



PM 2.62 1.08 2.62 1.08PM10 0.24 0.1 0.24 0.1PM2.5 0.02 0.01 0.02 0.01



PM 2.62 1.08 2.62 1.08PM10 0.24 0.1 0.24 0.1PM2.5 0.02 0.01 0.02 0.01

New/Modified Yes DDSCCAP Surface Coating Cap VOC 149.66 32.25 149.66 32.25 Painting/Surface Coating (Non-Enclosed / Outdoor)


PM 2.62 1.08 2.62 1.08PM10 0.24 0.1 0.24 0.1PM2.5 0.02 0.01 0.02 0.01

New/Modified No DD8 DD8STK Abrasive Blasting PM 0.07 0.06 0.07 0.06 Abrasive Blasting (Enclosed Booth / Building)PM10 0.02 0.01 0.02 0.01PM2.5 0.003 0.001 0.003 0.001



New/Modified Yes DDABCAP Abrasive Blasting PM 0.07 0.06 0.07 0.06 Abrasive Blasting (Enclosed Booth / Building)PM10 0.02 0.01 0.02 0.01PM2.5 0.003 0.001 0.003 0.001

New/Modified Yes BLASTPOT POT-FILL Blast Pot Filling PM 0.01 0.02 0.01 0.02 Other Blast Pot FillingPM10 0.01 0.01 0.01 0.01PM2.5 0.002 0.002 0.002 0.002

New/Modified No DD8 DD8CLN Spent Media Cleanup PM 0.01 0.02 0.01 0.02 Other Spent Media Cleanup PM10 0.004 0.007 0.004 0.007PM2.5 0.001 0.002 0.001 0.002



New/Modified Yes DDCLNCAP Spent Media Cleanup PM 0.01 0.02 0.01 0.02 Other Spent Media Cleanup PM10 0.004 0.007 0.004 0.007PM2.5 0.001 0.002 0.001 0.002

Remove Yes DD1,2,3 DD1,2,3STK Abrasive Blasting and Surface Coating Cap VOC 161.5 33.2 -161.5 -33.2 Other REMOVED

PM 35.75 24.97 -35.75 -24.97PM10 17.15 8.32 -17.15 -8.32

0 0

this cell is intentionally left blank

This cell intentionally left blankCoatingsPermit primary industry (must be selected for workbook to function)

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Stack Parameters



EPNIncluded in EMEW?

UTM Coordinates

ZoneEast (Meters)

North (Meters)

BuildingHeight (ft)

Height Above Ground (ft)

Stack Exit Diameter (ft)

Velocity (FPS)

Temperature (°F)

Fugitives - Length (ft)

Fugitives - Width (ft)

Fugitives - Axis Degrees

DD8 YesDD15 YesDD12 YesDDSCCAP YesDD8STK YesDD15STK YesDD12STK YesDDABCAP YesPOT-FILL YesDD8CLN YesDD15CLN YesDD12CLN YesDDCLNCAP YesDD1,2,3STK Yes

Emission Point Discharge Parameters

Version 4.0 Page 1


Public Notice



Yes

Yes

Yes

Yes

This row is optional. If you do not think the table below accurately represents public notice applicability increases for your project, provide discussion here (1000 characters).

Is this an application for a renewal?

Is this an application for a minor permit amendment?Is there any change in character of emissions in this application (a new criteria pollutant or a new VOC or PM species)?Is there a new air contaminant in this application?

I. Public Notice Applicability

For public notice applicability, the agency does not include consolidation or incorporation of any previously authorized facility or activity (PBR, standard permits, etc.), changes to permitted allowable emission rates when exclusively due to changes to standardized emission factors, or reductions in emissions which are not enforceable through the amended permit. Thus, the total emissions increase would be the sum of emissions increases under the amended permit and the emissions decreases under the amended permit for each air contaminant.

The table below will generate emission increases based on the values represented on the "Unit Types - Emission Rates" sheet. Use the "yes" and "no" options in column B of the "Unit Types - Emission Rates" worksheet to indicate if a unit's proposed change of emissions should be included in these totals.

Notes:1. Emissions of PM, PM10, and/or PM2.5 may have been previously quantified and authorized as PM, PM10,and/or PM2.5. These emissions will be speciated based on current guidance and policy to demonstrate compliance with current standards and public notice requirements may change during the permit review.

2. All renewals require public notice.

A. Application Type

B. Project Increases and Public Notice Thresholds (for Initial and Amendment Projects)

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

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Public Notice



Pollutant Current Long-Term (tpy)

Consolidated Emissions (tpy)

Proposed Long-Term (tpy)

Project Change in Allowable (tpy)

PN Threshold Notice required?

VOC 33.20 0.00 32.25 -0.95 5 NoPM 24.97 0.00 1.18 -23.79 5 NoPM10 8.32 0.00 0.13 -8.19 5 NoPM2.5 0.00 0.00 0.02 0.02 5 NoNOx 0.00 0.00 0.00 0.00 5 NoCO 0.00 0.00 0.00 0.00 50 NoSO2 0.00 0.00 0.00 0.00 10 NoPb 0.00 0.00 0.00 0.00 0.6 NoExempt Solvents 0 0 1.9 1.9 5 No

* Notice is required for PM, PM10, and PM2.5 if one of these pollutants is above the threshold.** Notice of a GHG action is determined by action type. Initial and major modification always require notice. Voluntary updates require a consolidated notice if there is a change to BACT. Project emission increases of CO2e (CO2 equivalent) are not relevant for determining public notice of GHG permit actions.

A. Contact InformationEnter the contact information for the person responsible for publishing. This is a designated representative who is responsible for ensuring public notice is properly published in the appropriate newspaper and signs are posted at the facility site. This person will be contacted directly when the TCEQ is ready to authorize public notice for the application.Prefix (Mr., Ms., Dr., etc.):

Last Name:Title:Company Name:Mailing Address: 18310 Market Street


Complete this section if public notice is required (determined in the above section) or if you are not sure if public notice is required.

Mr.BernardDiazManaging Director of Environmental Operations

Yes

II. Public Notice InformationThis cell intentionally left blank

C. Is public notice required for this project as represented in this workbook?If no, proceed to Section III Small Business Classification.Note: public notice applicability for this project may change throughout the technical review.

Yes

First Name:

D. Are any HAPs to be authorized/re-authorized with this project? The category "HAPs" must be specifically listed in the public notice if the project authorizes (reauthorizes for renewals) any HAP pollutants.

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Texas Commission on Environmental Quality

Form PI-1 General ApplicationPublic Notice



ChannelviewTexas77530713-378-8757281-860-3214

Has the public place granted authorization to place the application for public viewing and copying?

Title:

HoustonTexas

10550 Richmond Avenue Suite 210

Telephone Number:

Email Address:Fax Number:

Name of Public Place:

713-789-5920

Last Name:

Address Line 2:

Yes

First Name:Stanko

Prefix (Mr., Ms., Dr., etc.):

Harris

And available online via internet direct weblink:http://www.swslp.com/wp-content/uploads/2020/03/Permit_43774_Public_Notice.pdf

TCEQ Region 12 OfficePhysical Address:

Enter the contact information for the Technical Contact. This is the designated representative who will be listed in the public notice as a contact for additional information.

B. Public placePlace a copy of the full application (including all of this workbook and all attachments) at a public place in the county where the facilities are or will be located. You must state where in the county the application will be available for public review and comment. The location must be a public place and described in the notice. A public place is a location which is owned and operated by public funds (such as libraries, county courthouses, city halls) and cannot be a commercial enterprise. You are required to pre-arrange this availability with the public place indicated below. The application must remain available from the first day of publication through the designated comment period.

If this is an application for a PSD, nonattainment, or FCAA §112(g) permit, the public place must have internet access available for the public as required in 30 TAC § 39.411(f)(3).

If the application is submitted to the agency with information marked as Confidential, you are required to indicate which specific portions of the application are not being made available to the public. These portions of the application must be accompanied with the following statement: Any request for portions of this application that are marked as confidential must be submitted in writing, pursuant to the Public Information Act, to the TCEQ Public Information Coordinator, MC 197, P.O. Box 13087, Austin, Texas 78711-3087.

Address Line 2:City:State:


[email protected]

State:

City: Houston77023

77042713-244-1039

ZIP Code:

City:

Company Name:

ZIP Code:Telephone Number:Fax Number:Email Address:

Ms.Elizabeth

[email protected]

Project Manager

Mailing Address:Address Line 2:

ZIP Code:County:

5425 Polk, Suite H, 3rd Floor

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Public Notice



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?

Spanish


YesIs a bilingual program required by the Texas Education Code in the School District?

If yes to either question above, list which language(s) are required by the bilingual program?

Yes

C. Alternate Language PublicationIn some cases, public notice in an alternate language is required. If an elementary or middle school nearest to the facility is in a school district required by the Texas Education Code to have a bilingual program, a bilingual notice will be required. If there is no bilingual program required in the school nearest the facility, but children who would normally attend those schools are eligible to attend bilingual programs elsewhere in the school district, the bilingual notice will also be required. If it is determined that alternate language notice is required, you are responsible for ensuring that the publication in the alternate language is complete and accurate in that language.

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https://www.nps.gov/subjects/air/class1.htm







Public Notice



No

No

Complete this section to determine small business classification. If a small business requests a permit, agency rules (30 TAC § 39.603(f)(1)(A)) allow for alternative public notification requirements if all of the following criteria are met. If these requirements are met, public notice does not have to include publication of the prominent (12 square inch) newspaper notice.

III. Small Business Classification

Small business classification:

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

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Federal Applicability



Determination:

No

Pollutant Project Increase Threshold PSD Review Required?

CO 0 100 NoNOx 0 40 No

PM 0 25 NoPM10 0 15 NoPM2.5 0.02 10 NoSO2 0 40 No

Pb 0 0.6 NoH2S 0 10 No

TRS 0 10 NoReduced sulfur compounds (including H2S) 0 10 NoH2SO4 0 7 No

Fluoride (excluding HF) 0 3 No

CO2e 0 75000 No

No

Pollutant Project Increase Threshold NA Review Required?

Ozone (as VOC) 0 40 No

This project will be located in an area that is in serious nonattainment for ozone as of Sept. 23, 2019. Select from the drop-down list to the right if you would like the project to be reviewed under a different classification.

III. Nonattainment Applicability Summary

Is netting required for the PSD analysis for this project?

Is netting required for the nonattainment analysis for this project?


I. County Classification

This project will be located in a county with a Serious Ozone nonattainment classification. Complete the nonattainment section below and provide an analysis with the application.

Harris

II. PSD and GHG PSD Applicability SummaryThis cell intentionally left blank

County (completed for you from your response on the General sheet)

Does the project require retrospective review? No

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Federal Applicability



Ozone (as NOx) 0 40 No

Pollutant Offset Ratio Offset Quantity Required (tpy) Where is the offset coming from?

This cell intentionally left blankIV. Offset Summary (for Nonattainment Permits)


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Fees



No

No


IV. Calculations - Non-RenewalFor GHG permits: A single PSD fee (calculated on the capital cost of the project per 30 TAC § 116.163) will be required for all of the associated permitting actions for a GHG PSD project. Other NSR permit fees related to the project that have already been remitted to the TCEQ can be subtracted when determining the appropriate fee to submit with the GHG PSD application. Identify these other fees in the GHG PSD permit application.

Ambient air monitoring network. $0.00Sub-Total: $155,500.00

Sub-Total: $10,000.00


III. Indirect Costs - Non-RenewalType of Cost AmountFinal engineering design and supervision, and administrative overhead. $10,000.00Construction expense, including construction liaison, securing local building permits, insurance, temporary construction facilities, and construction clean-up. $0.00

Contractor's fee and overhead. $0.00

Process and control equipment not previously owned by the applicant and not currently authorized under this chapter. $145,000.00

Auxiliary equipment, including exhaust hoods, ducting, fans, pumps, piping, conveyors, stacks, storage tanks, waste disposal facilities, and air pollution control equipment specifically needed to meet permit and regulation requirements.

$10,000.00

Freight charges. $500.00Site preparation, including demolition, construction of fences, outdoor lighting, road, and parking areas. $0.00

Auxiliary buildings, including materials storage, employee facilities, and changes to existing structures. $0.00

I. General Information - Non-Renewal

II. Direct Costs - Non-RenewalThis cell intentionally left blank

Is this project for new facilities controlled and operated directly by the federal government? (30 TAC § 116.141(b)(1) and 30 TAC § 116.163(a))

A fee of $75,000 shall be required if no estimate of capital project cost is included with the permit application. (30 TAC § 116.141(d)) Select "yes" here to use this option. Then skip sections II and III.

Select Application Type Minor Application

Installation, including foundations, erection of supporting structures, enclosures or weather protection, insulation and painting, utilities and connections, process integration, and process control equipment.

$0.00

Type of Cost Amount

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Fees



$165,500.00

35.266

$ 1,580.45

$900.00 $ 1,580.45

$2,480.45

No$2,480.45

$2,480.45C. Total Paid

B. Payment Two (if paying renewal and non-renewal fees separately)

A. Payment One (required)

Was the fee paid online?Enter the fee amount:Enter the check, money order, ePay Voucher, or other transaction number:Enter the Company name as it appears on the check:

V. Renewal FeeThe fee for renewal is based on the total annual allowable emissions from the permitted facility to be renewed. If this project includes an amendment, the amendment permit fee will be calculated separately.

Enter the total allowable emissions (tons per year). The total emissions must include those represented in any PBR or standard permits to be incorporated by consolidation into this permit.

Greater than $25,000,000 $75,000 (maximum fee)

Less than $300,000 $900 (minimum fee)$300,000 - $7,500,000 N/A

$300,000 - $25,000,000 0.30% of capital costGreater than $7,500,000 N/A

Estimated Capital Cost Minor Application Fee


Your estimated capital cost: Minimum fee applies.Permit Application Fee: $900.00


VII. Payment Information



VI. Total FeesNote: fees can be paid together with one payment or as two separate payments.Non-Renewal FeeRenewal FeeTotal

Permit fee due

In signing the "General" sheet with this fee worksheet attached, I certify that the total estimated capital cost of the project as defined in 30 TAC §116.141 is equal to or less than the above figure. I further state that I have read and understand Texas Water Code § 7.179, which defines Criminal Offenses for certain violations, including intentionally or knowingly making, or causing to be made, false material statements or representations.

Enter the check, money order, ePay Voucher, or other transaction number:Enter the Company name as it appears on the check:

Check No.

Southwest Shipyard, LP

Enter the fee amount:Was the fee paid online?

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Fees



No

No

Is the estimated capital cost of the project above $2 million?

Is the application required to be submitted under the seal of a Texas licensed P.E.?Note: an electronic PE seal is acceptable.


VIII. Professional Engineer Seal Requirement

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Form PI-1 General ApplicationImpacts



PollutantDoes this pollutant require PSD review?

How will you demonstrate that this project meets all applicable requirements?

Notes Additional Notes (optional)

VOC No Modeling: screen or refinedAttach a completed "Electronic Modeling Evaluation Workbook" (EMEW).

Generic modeling using Unit Impact Multipliers (UIMs) was performed to demonstrate that changes in emission point discharge parameters from VOC (surface coating) sources will not be detrimental to the general public or the environment and accordingly, do not require a health affects analysis for speciated VOC emissions.

Exempt Solvents No Modeling: screen or refinedAttach a completed "Electronic Modeling Evaluation Workbook" (EMEW).

A minor source health effects evaluation was performed for exempt solvents.

PM No Not applicableThis pollutant is not a part of this project or does not require an impacts analysis.

N/A

PM10 No Modeling: screen or refinedAttach a completed "Electronic Modeling Evaluation Workbook" (EMEW).

NAAQS SIL Modeling performed for PM10.

Additionally, MERA Step 3 (10% of ESL Evaluation) was performed for crystalline silica emissions (PM10) using UIMs, showing project impacts are less than 10-percent of the ESL. Modeling attachments include detailed description of the MERA Step 3 demonstration, including speciated emissions rates.

PM2.5 No Modeling: screen or refinedAttach a completed "Electronic Modeling Evaluation Workbook" (EMEW).

NAAQS SIL Modeling performed for PM2.5.

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BACT



FINs Unit Type Pollutant Current Tier I BACT Confirm Additional Notes

DD8 Painting/Surface Coating (Non-Enclosed / Outdoor) VOC

Use of 30 TAC §115.453 or 115.421 (as applicable) compliant coatings. Alternate controls as specified in 30 TAC §115,454 or 115.423 may be used to meet the applicable VOC content limits.

Use of high transfer efficiency application equipment: airless, air-assisted airless, or electrostatic high-volume low-pressure spray equipment or brushes, rollers, dipping, and/or flow coating. Please specify which application type(s).

Good housekeeping and best management practices. See applicable 30 TAC §115 and/or 40 CFR Part 63 requirements.

Installation of an enclosure equipped with a ventilation and PM control system may be required if the operation can reasonably be conducted within a structure of 100,000 cubic feet or less.

Yes

The dry docks use high solid content coatings and marine coatings compliant with 30 TAC §115.421(a)(16). Southwest Shipyard employs good housekeeping for spills and exercises procedures to minimize fugitive emissions. All materials used to clean up the spill (i.e., rags, absorbent materials) are stored in sealed containers until transported offsite for disposal. Waste coatings are stored in closed containers until transported and disposed of off

‐

site by a permitted/licensed carrier.

DD8 Painting/Surface Coating (Non-Enclosed / Outdoor) Exempt Solvents

Use of 30 TAC §115.453 or 115.421 (as applicable) compliant coatings. Alternate controls as specified in 30 TAC §115.454 or 115.423 may be used to meet the applicable VOC content limits.




Yes


‐


DD8 Painting/Surface Coating (Non-Enclosed / Outdoor) PM

The emission reduction techniques for PM10 and PM2.5 will follow the technique for PM. Use of high transfer efficiency application equipment: airless, air-assisted airless, or electrostatic high-volume low-pressure spray equipment or brushes, rollers, dipping, and/or flow coating. Please specify which application type(s).



There shall be no visible emissions crossing the property line.

Although no emission credit will be given, use of shrouds is highly recommended to meet state/federal PM standards and health effects review. Shroud material shade factor should be 85% or greater.

Yes

Particulate (PM, PM10, and PM2.5) emissions are generated during the spray coating operations. The spray painting operations are shrouded to enclose and surround the area being spray painted to minimize the atmospheric entrainment of VOC and fine particles.

DD8 Painting/Surface Coating (Non-Enclosed / Outdoor)










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BACT




DD8 Painting/Surface Coating (Non-Enclosed / Outdoor) MSS

Startup and shutdown emissions are already included in the emission estimates for both hourly and annual emissions for the coating operations and abrasive blasting operations. The short term emission rates are no higher than normal operations and the emission control techniques for normal operations are considered acceptable for startup and shutdown. Emissions from filter replacement are limited through the use of work practices that limit the emissions of captured particulate matter.

Yes N/A





Installation of an enclosure equipped with a ventilation and PM control system may be required if the operation can reasonably be conducted within a structure of 100,000 cubic feet or less

Yes


‐







Yes


‐







Although no emission credit will be given, use of shrouds is highly recommended to meet state/federal PM standards and health effects review. Shroud material shade factor should be 85% or greater.

Yes












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BACT






Yes N/A






Yes


‐







Yes


‐







Although no emission credit will be given, use of shrouds is highly recommended to meet state/federal PM standards and health effects review. Shroud material shade factor should be 85% or greater

Yes












Version 4.0 Page 3


BACT






Yes N/A

DDSCCAP Painting/Surface Coating (Non-Enclosed / Outdoor) VOC





Yes


‐


DDSCCAP Painting/Surface Coating (Non-Enclosed / Outdoor) Exempt Solvents





Yes


‐


DDSCCAP Painting/Surface Coating (Non-Enclosed / Outdoor) PM





Although no emission credit will be given, use of shrouds is highly recommended to meet state/federal PM standards and health effects review. Shroud material shade factor should be 85% or greater

Yes


DDSCCAP Painting/Surface Coating (Non-Enclosed / Outdoor)










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BACT




DDSCCAP Painting/Surface Coating (Non-Enclosed / Outdoor) MSS


Yes N/A

DD8 Abrasive Blasting (Enclosed Booth / Building) PM

The emission reduction techniques for PM10 and PM2.5 will follow the technique for PM. Use of a filter control device such as a baghouse or cartridge filter system with an outlet grain loading of ≤ 0.002 grains/dry standard cubic foot or an efficiency of at least 99.9%.

Opacity shall not exceed 5% and/or no visible emissions from each stack or vent.

Yes

Abrasive blasting operations are carried out within mobile shrouds, which fully enclose and surround the marine vessels being blasted. All emissions captured from abrasive blasting are exhausted through a cartridge

‐

type dry filter system that achieves an overall particulate removal efficiency of at least 99.9

‐

percent. The opacity shall not exceed 5

‐

percent and/or there shall be no visible emission from each stack.

DD8 Abrasive Blasting (Enclosed Booth / Building)












DD8 Abrasive Blasting (Enclosed Booth / Building) MSS

Removal of spent filters in such a manner to minimize PM emissions and placing the spent filters in sealable bags or other sealable containers prior to removal from the site.

Bags or containers shall be kept closed at all times except when adding spent filters.

Collection and removal of spent or waste abrasive blast media in such a manner to minimize emissions and placing the waste in covered containers prior to removal from the site.

Yes N/A




Yes


‐


‐


‐














Version 4.0 Page 5


BACT








Yes N/A




Yes


‐


‐


‐


















Yes N/A

DDABCAP Abrasive Blasting (Enclosed Booth / Building) PM



Yes


‐


‐


‐


DDABCAP Abrasive Blasting (Enclosed Booth / Building)












Version 4.0 Page 6


BACT




DDABCAP Abrasive Blasting (Enclosed Booth / Building) MSS




Yes N/A

BLASTPOT Blast Pot Filling PM The emission reduction techniques for PM10 and PM2.5 will follow the technique for PM. See additional notes: Yes

A cover/skirt is used to partially enclose the blast pot filling operation, and therefore a partial enclosure control efficiency of 85% was applied per TCEQ guidance.

BLASTPOT Blast Pot Filling












BLASTPOT Blast Pot Filling MSS See additional notes: Yes N/A

DDCLNCAP Spent Media Cleanup PM The emission reduction techniques for PM10 and PM2.5 will follow the technique for PM. See additional notes: Yes

Tarps or shrouds are used to partially enclose the spent blast media area and a partial enclosure control efficiency of 85% was applied per TCEQ guidance.

DDCLNCAP Spent Media Cleanup












DDCLNCAP Spent Media Cleanup MSS See additional notes: Yes N/A

Version 4.0 Page 7


Monitoring



FIN Unit Type Pollutant Minimum Monitoring Requirements Confirm Additional Notes for MonitoringProposed Measurement Technique (only complete for pollutants with a project increase above the PSD threshold)

Additional Notes for Measuring:

DD8 Painting/Surface Coating (Non-Enclosed / Outdoor) VOC Recordkeeping of material usage and hours of operation on a (daily,

monthly) basis Yes

Data to be recorded includes daily total gallons of paint and solvent used, and daily hours and times of day of operation of each source. Environmental Data Sheet (EDS) or similar documentation (i.e., SDS) for all paints and solvents used in the coating operations. Data recorded will be used to ceate a monthly summary report.

DD8 Painting/Surfac e Coating (Non-Enc los ed / Outdoor) Exempt Solvents Recordkeeping of material usage and hours of operation on a (daily, monthly) basis Yes


DD8 Painting/Surfac e Coating (Non-Enc los ed / Outdoor) PM

The emission monitoring techniques for PM10 and PM2.5 will follow the technique for PM. Recordkeeping of material usage and hours of operation on a (daily, monthly) basisQuarterly visible emissions observations and recordkeeping

Yes

Data to be recorded includes daily total gallons of paint and solvent used, and daily hours and times of day of operation of each source. Environmental Data Sheet (EDS) or similar documentation (i.e., SDS) for all paints and solvents used in the coating operations. Data recorded will be used to ceate a monthly summary report. Quarterly field records of visible emissions observation and/or opacity measurements, as applicable. Records of any corrective action taken, if applicable.

DD8 Painting/Surfac e Coating (Non-Enc los ed / Outdoor)











monthly) basis Yes






Yes







This c e l l in tentional ly le ft b lank

Press TAB to move input areas Press UP or DOWN ARROW in column A to read through the document On this sheet if a FIN is not listed in the first column of the table the remainder of the table is completeMonitoringThis sheet provides the minimum acceptable requirements to demonstrate compliance through monitoring for each pollutant proposed to be emitted from each FIN. This sheet also includes measuring techniques for sources of significant emissions in the project.

Instructions:1. The unit types listed under Unit Type (column B) include all new, modified, consolidated, and/or renewed sources as indicated on the "Unit Types - Emission Rates" sheet. Each new, modified, consolidated, and/or renewed source must address how compliance will be demonstrated.2. The pollutants listed in Pollutant (column C) include the pollutants indicated on the "Unit Types - Emission Rates" sheet.

Monitoring (30 TAC § 116.111(a)(2)(G))3. The minimum acceptable monitoring is automatically populated for each unit type and pollutant. - Additional monitoring may be required, particularly for Title V sources, and will be included in the NSR and/or Title V permits.4. Fully expand the Minimum Monitoring Requirements (column D) by increasing the row heights so all text is visible. (Place the cursor on the bottom of the number line to the far left of the screen, click and drag downward until all text is visible.) 5. Review the monitoring and confirm that you will meet all representations listed on the sheet and any additional attachments by entering or selecting "Yes" in Confirm (column E).6. Add additional notes as necessary in Additional Notes for Monitoring (column F), limited to 500 characters or fewer. Examples include the following: - Proposed monitoring for pollutants or units that list "See additional notes:"; - Details requested in the populated data; - Alternative monitoring you are proposing; and - Any additional information relevant to the minimization of emissions.7. Cap EPNs do not need monitoring (leave those rows blank).

Measurement of Emissions (30 TAC § 116.111(a)(2)(B))Note: this section will be greyed out if this project does not require PSD or nonattainment review, as represented on the General sheet.7. For each pollutant with a project increase greater than the PSD significant emission rate, select the proposed measurement technique using the dropdown (column G).8. For each pollutant with a project increase less than the PSD significant emission rate: leave blank.9. If selecting "other", provide details in Additional Notes for Measuring (column H).10. You may also use the Additional Notes for Measuring (column H) to provide more details on a selection.Click here to return to Cover Sheet.Important Note: The permit holder shall maintain a copy of the permit along with records containing the information and data sufficient to demonstrate compliance with the permit, including production records and operating hours. All required records must be maintained in a file at the plant site. If, however, the facility normally operates unattended, records shall be maintained at the nearest staffed location within Texas specified in the application. The site must make the records available at the request of personnel from the commission or any air pollution control program having jurisdiction in a timely manner. The applicant must comply with any additional recordkeeping requirements specified in special conditions in the permit. All records must be retained in the file for at least two years following the date that the information or data is obtained. Some permits are required to maintain records for five years. [30 TAC § 116.115(b)(2)(E)]

This c el l in tentional ly le ft b lank





Version 4.0 Page 1


Monitoring









monthly) basis Yes






Yes












DDSCCAP Painting/Surface Coating (Non-Enclosed / Outdoor) VOC Recordkeeping of material usage and hours of operation on a (daily,

monthly) basis Yes


DDSCCAP Painting/Surfac e Coating (Non-Enc los ed / Outdoor) Exempt Solvents Recordkeeping of material usage and hours of operation on a (daily, monthly) basis Yes


DDSCCAP Painting/Surfac e Coating (Non-Enc los ed / Outdoor) PM


Yes


DDSCCAP Painting/Surfac e Coating (Non-Enc los ed / Outdoor)











The emission monitoring techniques for PM10 and PM2.5 will follow the technique for PM. Recordkeeping of blast media usage and hours of operation on a (daily, monthly) basisQuarterly visible emission observations/opacity measurements and record keepingMonthly AVO Inspections of capture systemPressure drop monitoring across the filters.Record pressure drop measurement at least once per day.

Yes

Data to be recorded includes daily total pounds of abrasive blasting material used, and daily hours and times of day of operation of each source. Quarterly field records of visible emissions observation and/or opacity measurements, as applicable. Records of any corrective action taken, if applicable.

DD8 Abras iv e Blas ting (Enc los ed Booth / Bui ld ing)














Yes







Version 4.0 Page 2


Monitoring












Yes














DDABCAP Abrasive Blasting (Enclosed Booth / Building) PM


Yes


DDABCAP Abras iv e Blas ting (Enc los ed Booth / Bui ld ing)












BLASTPOT Blast Pot Filling PM The emission monitoring techniques for PM10 and PM2.5 will follow the technique for PM. See additional notes: Yes

The facility will maintain records of the daily total pounds of abrasive blasting material filled into the blast pots, and daily hours of operation.

BLASTPOT Blas t Pot Fi l l ing












DDCLNCAP Spent Media Cleanup PM The emission monitoring techniques for PM10 and PM2.5 will follow the technique for PM. See additional notes: Yes The facility will maintain records of the hours of operation and good

housekeeping procedures for cleanup of spent blast media. DDCLNCAP Spent M edia Cleanup

DDCLNCAP Spent M edia Cleanup







Version 4.0 Page 3


Materials



How submitted Date submitted

EmailMailNot applicable

EmailEmailEmailEmail

Email

Not applicable

EmailNot applicable

Email

Not applicableEmailNot applicableEmailNot applicable

Electronic Modeling Evaluation Workbook: NonSCREEN3

C. Federal Applicability

E. Impacts Analysis

D. Technical Information

F. Additional Attachments

Material Balance (if applicable)Calculations

Netting analysis (if required) - Tables 3F and 4F as needed

MERA analysis

PSD modeling protocol

Electronic Modeling Evaluation Workbook: SCREEN3

Qualitative impacts analysis

State regulatory requirements discussion

Area map

BACT discussion, if additional details are attachedMonitoring information, if additional details are attached

List of MSS activities

Process descriptionProcess flow diagram

Summary and project emission increase determination - Tables 1F and 2F

Plot plan

Item

Core Data Form

Form PI-1 General ApplicationHard copy of the General sheet with original (ink) signature


A. Administrative Information

Professional Engineer Seal

Copy of current permit (both Special Conditions and MAERT)

Version 4.0 Page 1




Appendix B Emissions Calculations

TCEQ Outdoor Coating and Abrasive Blasting Emission Calculations Excel Workbook

(Submitted Electronically)




Appendix C Impacts Analysis - EMEW

TCEQ Electronic Modeling Evaluation Workbook (EMEW) Excel Workbook for non‐

SCREEN3

Modeling Memo and Attachments

Texas Commission on Environmental QualityElectronic Modeling Evaluation Workbook (EMEW)

General


Company Name: Southwest Shipyard, LP

Select from the drop down:

I agree

Section: Select an X from the dropdown menu if included:

1 X2 X3 X45 X6 X7 X8 X

https://ftps.tceq.texas.gov/help/

Acknowledgement:

I acknowledge that I am submitting an authorized TCEQ Electronic Modeling Evaluation Workbook and any necessary attachments. Except for inputting the requested data, I have not changed the TCEQ Electronic Modeling Evaluation Workbook in any way, including but not limited to changing formulas, formatting, content, or protections.

Bernard DiazCompany Contact Name:

Volume Source CalculationsVolume Source Parameters

Building Downwash

Sheet Instructions: Indicate in the Table of Contents which sections are applicable and included for this modeling demonstration. Select "X" from the drop down if the item below is included in the workbook. Note: This workbook is only for the following air dispersion models: AERSCREEN, ISC/ISCPrime, and/or AERMOD. If SCREEN3 is used, please use the separate Electronic Modeling Evaluation Workbook (EMEW) for SCREEN3 workbook.

Flare Source ParametersPoint Source Parameters

EMEW Version No.: Version 2.3

Sheet Title (Click to jump to specific sheet):

Model Options

Administrative Information:

Project Number (6 digits):Permit Number:Regulated Entity ID (9 digits):

Facility Information:

TRC Environmental CorporationModeling Company Name, as applicable:

General

Table of Contents:

Data Type:

43774100248749

Facility Name: Channelview Facility Dry DocksFacility Address:Facility County (select one):

New/Existing Site (select one):Modeling Date (MM/DD/YYYY):

NAD 8315

Datum Used (select one):UTM Zone (select one):

7/13/2020

18310 Market StreetHarrisSouthwest Shipyard, L.P.

[email protected]

Modeling Contact Number:Modeling Contact Email:

Company Contact Number:Company Contact Email:

Modeling Contact Name:

[email protected]

Elizabeth Stanko713-244-1039

Area Source Parameters

Company Name:

Page 1







General



9 X10 X11 X12 X13 Intermittent Sources14 Modeling Scenarios X15 Monitor Calculations16 Background Justification1718 NAAQS/State Property Line (SPL) Modeling Results X19 Unit Impact Multipliers X20 X21 X22 Speciated Chemicals

Area Source EmissionsPoint and Flare Source Emissions

Health Effects Modeling Results

Volume Source EmissionsSpeciated Emissions

Secondary Formation of PM2.5

Modeling File Names

Page 2


General



Select an X from the dropdown menu if included:

XXXX

XXXSelect an X from the dropdown menu if included:

Choose an itemChoose an item

Choose an item

XChoose an itemX

Choose an item

X

Choose an itemChoose an item

Description of model setup.Description and justification of model options selected (i.e., NO2 to NOx in-stack ratios).

Additional Attachments (as applicable):Note: These are just a few examples of attachments that may need to be included. There may be others depending on the scope of the modeling analysis.

Included AttachmentsInstructions: The following are attachments that must be included with any modeling analysis. If providing the plot plan and area map with the permit application, ensure there is also a copy with the EMEW. The copy can be electronic.

Post Processing using Unit Impact Multipliers (UIMs)Include documentation on any calculations used with the UIMs (i.e., Step 3 of the MERA).

Tier 3 NO2 analysisIf OLM or PVMRM are used, provide all justification and documentation on using this approach.

Discussion on modeling techniques not discussed in workbook.Justification for exceedance refinements, as applicable.Discussion and images for worst-case determination, as applicable.Single Property Line Designation, as applicableInclude Agreement, Order, and map defining each petitioner.

Processed Met Data InformationExcel spreadsheet of processed meteorology data.Meteorological Files (all input and outputs).Source Group Descriptions

Modeling Techniques and ScenariosProvide all justification and discussion on modeling scenarios used for the modeling analyses. The following boxes are examples of approaches that should be provided but is not all inclusive.

f f

Description of modeling source groups (could be in a tabulated format).

All sources and buildings are clearly labeled.Area Map:Instructions: Mark all that apply in the attached area map.Annotate schools within 3,000ft of source's nearest property line.

Non-industrial receptors are identified.All property lines are included.

Instructions: Mark all that apply in the attached plot plan. For larger properties or dense source areas, provide multiple zoomed in plot plans that are legible.

Plot Plan:

Property/Fence Lines all visible and marked.North arrow included.Clearly marked scale.

Other AttachmentsProvide a list in the box below of additional attachments being provided that are not listed above:

Page 3


General



XPlease see NSR 43774 EMEW Memo & Attachments for details on UIMs used to determine "worst-case" source locations in NAAQS and Health Effects modeling grids. This Memo includes MERA Analysis for Exempt Solvents and Crystalline Silica. Memo also describes source changes from prior permitting.

Page 4


Model Options



ISC or ISCPrimeX AERMOD

Yes4274

X State Property LineX

B. Building Downwash

C. Type of Analyses: (Select "X" in all that apply)*PSD projects should submit a protocol and not utilize this form.

Minor NSR NAAQSHealth Effects

AERSCREENEnter in all applicable Model Version(s).19191

Is downwash applicable? (Select "Yes" or "No")Enter BPIP version (AERMOD and ISCPrime only).

I. Project Information

Instructions: Fill in the information below based on your modeling setup. The selections chosen in this sheet will carry throughout the sheet and workbook. Based on selections below, only portions of the sheet and workbook will be available. Therefore, it is vital the sheet and workbook are filled out in order, do NOT skip around.

For larger text boxes, double click to type or insert text.

A. Type of Model Used: Select "X" in all that apply

This line was intentionally left blank.II. Air Dispersion Modeling Preliminary Information

A. Project Overview: In the box below, give a brief Project Overview. To type or insert text in box, double click in the box below. Please limit your response to 2000 characters.

The project is a Renewal and concurrent Amendment of NSR Permit No. 43774, which authorizes surface coating and abrasive blasting of barges and boats at the Channelview site Dry Docks. Project changes include adding Exempt Solvents (ES) to the permit; adding new abrasive blasting sources of PM, PM10 and PM2.5, which are blast pot filling and three sources associated with abrasive blasting media cleanup; revising the numbering of the Dry Docks; and updating the permit representation such that all abrasive blasting activities are captured and controlled by dust collectors, while all surface coating activities occur within shrouds remain emitted as fugitives.

Page 1


Model Options



SO2 X PM10

CO X PM2.5

Pb NO2

H2S SO2

H2SO4

D. Constituents Evaluating: (Select "X" in all that apply)NAAQS: List all pollutants that require a modeling review. (Select "X" in all that apply)

Identify the 1-hr NO2 tier used for the ISC/ISCPrime analyses.

Health Effects: Fill in the Speciated Emissions sheet with all applicable pollutants, CAS numbers, and ESLs.

Identify which averaging periods are being evaluated for NO2.

Identify the 1-hr NO2 tier used for the AERMOD or AERSCREEN analyses.

Identify the annual NO2 tier used for the AERMOD or AERSCREEN analyses.

Provide additional information relied on for the Tier 3 analysis for conversion of NOx to NO2 in the box below. Note the ozone monitor relied on should be documented in the Monitor Calculations and Background Justification Sheets.

State Property Line: List all pollutants that require a modeling review. (Select "X" in all that apply)

Identify the annual NO2 tier used for the ISC/ISCPrime analyses.

Page 2


Model Options



X Urban 101645 Population Used

Zo ValueAlbedo

X MediumHigh

300405 3297302 Center UTM Northing (meters)1NoNoAverage

E. Dispersion Options: If "Urban" has been selected and this project is using AERMOD or AERSCREEN, include the population used. Select "X" in the box to select an option.

Provide any additional justification on the dispersion option selected above:According to the AERMOD implementation guide, the urban option can be used to “To account for the dispersive nature of the “convective-like” boundary layer that forms during nighttime conditions due to the urban heat island effect.” The dry dock facility is located in Channelview within the Houston-Sugar Land-Baytown metropolitan area northeast of the heavily developed Houston ship channel and is influenced by the urban heat island effect. According to the AERMOD implementation guide, because the urban heat island effect is regional in character and not a localized phenomenon, an argument stating that the barge rail facility is too close to water bodies or rural areas would be invalidated.

Further, NWS meteorological data was utilized for the modeling analysis and the AERMOD Implementation guide also states that, “For urban applications using representative NWS meteorological data the AERMOD urban option (URBANOPT) should be selected (EPA, 2018b), regardless of whether the NWS site is located in a nearby rural or an urban setting. This is due to the fact that the limited surface meteorological measurements available from NWS stations will not account for the enhanced turbulence or other meteorological characteristics of the urban boundary layer included in the AERMOD urban algorithms.”

The population utilized was the population within the receptor domain and was obtained using the Missouri Census Data Center Circular Area Profiles (CAPS) version 10C.

Select basis for surface roughness:

F. Determination of Surface Roughness: If AERSCREEN or AERMOD is used, fill out the section below.

If you are using AERSCREEN, please enter the following information:

Select "X" in one of the three surface roughness categories:Low

If you are using AERSURFACE, please complete the following section:13016

Center UTM Easting (meters)AERSURFACE Version Number

Study Radius (km)Airport? (Select Yes or No)Continuous Snow Cover (Select Yes or No)Surface Moisture (Select Wet, Dry, or Average)

AERSURFACE

Bowen Ratio

Rural

Page 3


Model Options



NoDefault

Arid Region? (Select Yes or No) Month/Season Assignment

Page 4


Model Options



Meters (m)

Meters (m)Yes 1 Year Years used

2016 5 Years

Meters (m) Anemometer Height

G. Meteorological Data:

3937

Provide any other justification for Meteorological Data, as applicable.

Upper Air StationProfile Base Elevation (AERMOD only)AERMET Version Number

12918

19191

Was TCEQ pre-processed data used?

For other processed meteorological data, provide a description below. In addition, be sure to include all raw data, AERSURFACE, AERMINUTE and AERMET input and outputs, and AERMOD ready files as an attachment.

For applicants using AERSCREEN, please fill out the boxes below:

14.3

Please enter the year(s) selected for this meteorological data:1 Year

Which analysis(es) relied on 1 year?

Anemometer Height (ISC/ISCPrime only).

If AERMOD and/or ISC/ISCPrime are selected, please complete the following section:

Which analysis(es) relied on 5 years?

Surface Station

Maximum TemperatureMinimum TemperatureSelect whether Adjust u* was used. (Select "Yes" or "No")For AERSCREEN which met selection was used?

Page 5


Model Options



Meters (m)Meters (m)Meters (m)Meters (m)Meters (m)Meters (m)Meters (m)Meters (m)

Meters (m)

X Flat

25 Tight Receptor Spacing

H. Receptor Grid:

Per Section 382.006 of House Bill 3040, as the Channelview site is a shipbuilding and ship repair operation, receptors were not placed over water for non-criteria pollutants. Due to the dry docks being located in the Houston Ship Channel, this required the use of separate receptor grids for the State Health Effects analysis, which excludes the receptors located over water, and the NAAQS analysis which includes the receptors located over water starting at a distance of 25 meters from the dry docks.

I. Terrain:

For additional justification on terrain selection, fill in the box below:

Describe any other receptor grid designs (over water, GLCni, SPLD etc.):

25010010005005000100010000

Coarse Receptor Spacing Coarse Receptor Distance

Medium Receptor Distance

For AERMOD or ISC/ISCPrime, fill in the following information on your modeled receptor grid. Note: Receptor grid resolution (tight, fine, medium, coarse) are based on recommended receptor grid spacing per the AQMG, if something outside of this is used, fully describe it below.

Tight Receptor Distance Fine Receptor SpacingFine Receptor Distance Medium Receptor Spacing

18081 AERMAP Version.Elevated

If AERSCREEN is selected, enter minimum distance to ambient air.

Page 6


Building Downwash



Downwash Type Modeled Building ID Tank Diameter (m) Number of Tiers Maximum Height (m) Tier 1 Height (m) Tier 2 Height (m) Tier 3 Height (m)Building RAILBLDG 2 12.192 7.62 12.192Building BLDG1 1 6.7056 6.7056Building BLDG2 1 8.2296 8.2296Building BLDG3 1 7.62 7.62Building BLDG4 1 6.096 6.096

Facility:

Page 1


Point Source Parameters



EPN Model IDModeling Scenario Source Description

Point Source Type Point Source Justification

Easting:X [m]

Northing:Y [m]

Base Elevation

[m] Height [m]Exit Temperature

[K]Exit Velocity

[m/s] Diameter [m]

DD3STK DD3STKHU

Unit Modeling -

Health Effects

DD3 Stack - Current Authorization POINT Vertical Stack 300441.00 3297371.00 1.32 12.19 0.000 10.363 0.305

DD3STK DD3STKNU

Unit Modeling - NAAQS Analysis

DD3 Stack - Current Authorization POINT Vertical Stack 300441.00 3297371.00 1.32 12.19 0.000 10.363 0.305

DD8STK DD8BLASTNU


DD8 Stack Location POINT Vertical Stack 300467.02 3297398.32 1.29 13.72 0.000 24.049 0.518

DD15STK DD15BLASTNU



DD12STK DD12BLASTNU



DD8STK DD8BLASTN NAAQS Analysis DD8 Stack Location POINT Vertical Stack 300467.02 3297398.32 1.29 13.72 0.000 24.049 0.518

DD12STK DD12BLASTN NAAQS Analysis DD12 Stack Location POINT Vertical Stack 300476.26 3297431.44 1.29 13.72 0.000 24.049 0.518

POT-FILL POTFILLN NAAQS Analysis

Blasting pot filling - Updated Representation POINT Vertical Stack 300454.70 3297405.96 1.32 0.91 0.000 0.001 0.001

BRSTK1 BRSTK1Health Effects

Analysis

NSR 36241 Sitewide Source Barge Rail Stack POINT Vertical Stack 300361.00 3297543.00 1.60 13.72 0.000 14.387 0.914

DD8STK DD8BLASTHU

Unit Modeling -

Health Effects


DD15STK DD15BLASTHU

Unit Modeling -

Health Effects


DD12STK DD12BLASTHU

Unit Modeling -

Health Effects


POT-FILL POTFILLHU

Unit Modeling -

Health Effects


POT-FILL POTFILLNU



Facility:

Page 1


Area Source Parameters



EPN Model IDModeling Scenario Area Source Type

Easting:X [m]

Northing:Y [m] Base Elevation [m]

Modeled Release Height

[m]Length X

[m]Length Y

[m]Rotation Angle

[deg] Radius [m]Initial Vertical

Sigma (m)Area Source Initial Sigma

Justification Area Source Size JustificationArea Source Release Height

Justification Source Description

DD2 DD2HU Unit Modeling - Health Effects AREA 300441.68 3297338.79 1.33 10.67 18.29 41.15 40.00 Size of shroud Height of shroud Dry Dock 2 - Current

Authorization

DD1 DD1HU Unit Modeling - Health Effects AREA 300462.95 3297388.83 1.29 10.67 41.15 18.29 37.00 Size of shroud Height of shroud Dry Dock 1 - Current

Authorization

DD15 DD15HU Unit Modeling - Health Effects AREA 300441.68 3297338.79 1.33 10.67 18.29 41.15 40.00 Size of shroud Height of shroud Dry Dock 15 - Updated

Representation


Representation


Representation

DD2 DD2NUUnit Modeling -

NAAQS Analysis

AREA 300441.68 3297338.79 1.33 10.67 18.29 41.15 40.00 Size of shroud Height of shroud Dry Dock 2 - Current Authorization


NAAQS Analysis

AREA 300462.95 3297388.83 1.29 10.67 41.15 18.29 37.00 Size of shroud Height of shroud Dry Dock 1 - Current Authorization


NAAQS Analysis

AREA 300441.68 3297338.79 1.33 10.67 18.29 41.15 40.00 Size of shroud Height of shroud Dry Dock 15 - Updated Representation


NAAQS Analysis



NAAQS Analysis


DD12 DD12H Health Effects Analysis AREA 300472.24 3297420.29 1.29 10.67 76.20 22.86 37.00 Size of shroud Height of shroud Dry Dock 8 - Updated

Representation

DD8 DD8N NAAQS Analysis AREA 300462.95 3297388.83 1.29 10.67 41.15 18.29 37.00 Size of shroud Height of shroud Dry Dock 8 - Updated

Representation

DD12 DD12N NAAQS Analysis AREA 300472.24 3297420.29 1.29 10.67 76.20 22.86 37.00 Size of shroud Height of shroud Dry Dock 12 - Updated

Representation

DD15CLN DD15CLHU Unit Modeling - Health Effects AREA 300441.68 3297338.79 1.33 0.00 18.29 41.15 40.00 Size of Dry Dock Ground Level Dry Dock 15 - Abrasive

Cleanup


Cleanup


Cleanup

DD15CLN DD15CLNUUnit Modeling -

NAAQS Analysis

AREA 300441.68 3297338.79 1.33 0.00 18.29 41.15 40.00 Size of Dry Dock Ground Level Dry Dock 15 - Abrasive Cleanup


NAAQS Analysis



NAAQS Analysis


DD15CLN DD15CLN NAAQS Analysis AREA 300441.68 3297338.79 1.33 0.00 18.29 41.15 40.00 Size of Dry Dock Ground Level Dry Dock 15 - Abrasive

Cleanup

Facility:

Page 1


Volume Source Calculations



EPN Model ID

Footprint of Source

Length (m)

Footprint of Source

Width (m)

Length of Side (making it a square)

SQRT(L * W)

Type of Volume Source (sigma y)

Pick from drop-down

Sigma Y

(m)

Vertical Span

Min Release (m)

Vertical Span

Max Release (m)

Vertical Dimension

(m)

Type of Volume Source (sigma z)

Pick from drop-down

Release Height(middle point of vertical span)

(m)

Building Name(if on/adjacent to a

building)Pick from drop-down

Adjacent Building Height, if applicable

(m)

Sigma Z

(m)BRFUG BRFUG1 24.38 22.86 23.61 Multiple Volumes: Adjacent Volume Sources 10.98 0.00 12.19 12.19 Surface-Based Source 6.10 5.67BRFUG BRFUG2 24.38 22.86 23.61 Multiple Volumes: Adjacent Volume Sources 10.98 0.00 12.19 12.19 Surface-Based Source 6.10 5.67BRFUG BRFUG3 24.38 22.86 23.61 Multiple Volumes: Adjacent Volume Sources 10.98 0.00 12.19 12.19 Surface-Based Source 6.10 5.67BRFUG BRFUG4 24.38 22.86 23.61 Multiple Volumes: Adjacent Volume Sources 10.98 0.00 12.19 12.19 Surface-Based Source 6.10 5.67MAR4 MAR4 18.29 21.34 19.75 Single Volume Source 4.59 0.00 7.62 7.62 Surface-Based Source 3.81 3.54FU4 FU4 16.76 15.24 15.98 Single Volume Source 3.72 0.00 7.62 7.62 Surface-Based Source 3.81 3.54

0.00 Incomplete 0.00 0.00 Incomplete

Facility:

Page 1


Volume Source Parameters



EPN Model ID

Modeled Release

Height [m]

Modeled Length X

[m]

Lateral DimensionSigmaY [m]

Vertical DimensionSigmaZ [m]

Modeling Scenario

Easting:X [m]

Northing:Y [m]

Base Elevation

[m] Source Description Volume Source Size Justification

BRFUG BRFUG1 6.10 23.61 10.98 5.67 Health Effects Analysis 300342.89 3297532.69 1.67

NSR Permit 36241. Building Fugitives. Due to length/width of

building, divided into 4 equal-sized adjacent volumes. Combined impact represented by source group BRFUG

Building where painting occurs, divided into 4 adjacent volumes. Emissions occur throughout

the structure, so surface-based was used.
















MAR4 MAR4 3.81 19.75 4.59 3.54 Health Effects Analysis 300520.63 3297433.02 1.23 PBR 75783 Barge coating work area Size of typical barge work area. Unshrouded

painting.

FU4 FU4 3.81 15.98 3.72 3.54 Health Effects Analysis 300404.30 3297512.03 1.52 PBR 34783 Small Parts Coating

Enclosure

Enclosure where painting occurs Emisisons occur throughout the structure, so surface

based was used.

Facility:

Page 1


Point + Flare Emissions



EPN Model IDModeling Scenario Pollutant

Modeled Averaging Time Standard Type Review Context

Intermittent Source?

Modeled Emission Rate [lb/hr] Basis of Emission Rate

Scalars or Factors Used? Scalar/Factor in Use

DD3STK DD3STKHU odeling - Health E Generic 1-hr No 1.00 Unit Modeling NoDD3STK DD3STKNU deling - NAAQS A Generic 24-hr No 1.00 Unit Modeling NoDD8STK DD8BLASTNU deling - NAAQS A Generic 24-hr No 1.00 Unit Modeling No

DD15STK DD15BLASTNU deling - NAAQS A Generic 24-hr No 1.00 Unit Modeling NoDD12STK DD12BLASTNU deling - NAAQS A Generic 24-hr No 1.00 Unit Modeling NoDD3STK DD3STKHU odeling - Health E Generic Annual No 0.228 Unit Modeling NoDD3STK DD3STKNU deling - NAAQS A Generic Annual No 0.228 Unit Modeling NoDD8STK DD8BLASTNU deling - NAAQS A Generic Annual No 0.228 Unit Modeling No

DD15STK DD15BLASTNU deling - NAAQS A Generic Annual No 0.228 Unit Modeling NoDD12STK DD12BLASTNU deling - NAAQS A Generic Annual No 0.228 Unit Modeling NoDD8STK DD8BLASTN NAAQS Analysis PM2.5 24-hr NAAQS SIL analysis No 0.00252 Max Allowable NoPOT-FILL POTFILLN NAAQS Analysis PM2.5 24-hr NAAQS SIL analysis No 0.00186 Max Allowable NoDD12STK DD12BLASTN NAAQS Analysis PM2.5 Annual NAAQS SIL analysis No 3.06E-04 Max Allowable NoPOT-FILL POTFILLN NAAQS Analysis PM2.5 Annual NAAQS SIL analysis No 5.30E-04 Max Allowable NoDD8STK DD8BLASTN NAAQS Analysis PM10 24-hr NAAQS SIL analysis No 0.0168 Max Allowable NoPOT-FILL POTFILLN NAAQS Analysis PM10 24-hr NAAQS SIL analysis No 0.00590 Max Allowable NoBRSTK1 BRSTK1 alth Effects Analy Health Effects Pollutant 1-hr Health Effects Site Wide No Max Allowable NoBRSTK1 BRSTK1 alth Effects Analy Health Effects Pollutant Annual Health Effects Site Wide No Max Allowable NoDD8STK DD8BLASTHU odeling - Health E Generic 1-hr No 1.00 Unit Modeling No

DD15STK DD15BLASTHU odeling - Health E Generic 1-hr No 1.00 Unit Modeling No

DD12STK DD12BLASTHU odeling - Health E Generic 1-hr No 1.00 Unit Modeling No

DD8STK DD8BLASTHU odeling - Health E Generic Annual No 0.228 Unit Modeling No



POT-FILL POTFILLHU odeling - Health E Generic 1-hr No 1.00 Unit Modeling NoPOT-FILL POTFILLHU odeling - Health E Generic Annual No 0.228 Unit Modeling NoPOT-FILL POTFILLNU deling - NAAQS A Generic 1-hr No 1.00 Unit Modeling NoPOT-FILL POTFILLNU deling - NAAQS A Generic Annual No 0.228 Unit Modeling No

Facility:

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Area Source Emissions








DD2 DD2HU deling - Health Generic 1-hr No 0.300

Unit Modeling with shroud adjustment factor of 0.3 from

TCEQ Shroud Memo "Outdoor Blasting and Coating

Adjustment Factors for Shrouds" 2006

Yes

Shroud factor based on 4 sides and height of shroud

and height above ship being painted. Shrouds are 35 feet tall and extend a minimum of 9 feet above the vessel being blasted and spray coated. As

such, the height is between 0.5 and 0.75 of the shroud height and >1 meter below

the top of the shroud.





Yes









Yes









Yes









Yes





DD2 DD2HU deling - Health Generic Annual No 0.0685




Yes





Facility:

Page 1














Yes









Yes









Yes









Yes





DD2 DD2NU eling - NAAQS Generic 24-hr No 0.300




Yes









Yes





Page 2














Yes









Yes









Yes





DD2 DD2NU eling - NAAQS Generic Annual No 0.0685




Yes









Yes









Yes





Page 3














Yes









Yes





DD8 DD8N AAQS Analys PM2.5 24-hr NAAQS SIL analysis No 0.00550

Max allowable with shroud adjustment factor of 0.3 from



Yes





DD12 DD12N AAQS Analys PM2.5 Annual NAAQS SIL analysis No 5.25E-04




Yes





DD8 DD8N AAQS Analys PM10 24-hr NAAQS SIL analysis No 0.0710




Yes





DD12 DD12H th Effects Ana Health Effects Pollutant 1-hr Health Effects Project Wide No




Yes





Page 4










DD12 DD12H th Effects Ana Health Effects Pollutant Annual Health Effects Project Wide No




Yes





DD12 DD12H th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No




Yes





DD12 DD12H th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No




Yes




the top of the shroud.DD15CLN DD15CLHU deling - Health Generic 1-hr No 1.00 Unit Modeling. NoDD8CLN DD8CLHU deling - Health Generic 1-hr No 1.00 Unit Modeling. No

DD12CLN DD12CLHU deling - Health Generic 1-hr No 1.00 Unit Modeling. NoDD15CLN DD15CLHU deling - Health Generic Annual No 0.228 Unit Modeling. NoDD8CLN DD8CLHU deling - Health Generic Annual No 0.228 Unit Modeling. No

DD12CLN DD12CLHU deling - Health Generic Annual No 0.228 Unit Modeling. NoDD15CLN DD15CLNU eling - NAAQS Generic 24-hr No 1.00 Unit Modeling. NoDD8CLN DD8CLNU eling - NAAQS Generic 24-hr No 1.00 Unit Modeling. No

DD12CLN DD12CLNU eling - NAAQS Generic 24-hr No 1.00 Unit Modeling. NoDD15CLN DD15CLNU eling - NAAQS Generic Annual No 0.228 Unit Modeling. NoDD8CLN DD8CLNU eling - NAAQS Generic Annual No 0.228 Unit Modeling. No

DD12CLN DD12CLNU eling - NAAQS Generic Annual No 0.228 Unit Modeling. NoDD15CLN DD15CLNU eling - NAAQS PM2.5 24-hr NAAQS SIL analysis No 0.00139 Max Allowabe NoDD15CLN DD15CLNU eling - NAAQS PM2.5 Annual NAAQS SIL analysis No 5.30E-04 Max Allowabe NoDD15CLN DD15CLNU eling - NAAQS PM10 24-hr NAAQS SIL analysis No 0.00443 Max Allowabe No

Page 5


Volume Source Emissions








BRFUG BRFUG1 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Maximum Allowable NoBRFUG BRFUG2 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Maximum Allowable NoBRFUG BRFUG3 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Maximum Allowable NoBRFUG BRFUG4 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Maximum Allowable NoMAR4 MAR4 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Maximum Allowable NoFU4 FU4 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Maximum Allowable No

BRFUG BRFUG1 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Maximum Allowable NoBRFUG BRFUG2 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Maximum Allowable NoBRFUG BRFUG3 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Maximum Allowable NoBRFUG BRFUG4 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Maximum Allowable NoMAR4 MAR4 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Maximum Allowable NoFU4 FU4 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Maximum Allowable No

Facility:

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Speciated Emissions


Company Name: Southwest Shipyard, LPPr ess TAB t o m ove input ar eas. Pr ess UP or DO WN ARRO W in colum n A t o r ead t hr ough t he docum ent .

Data Type: Facility Information:Project Number:Permit Number: 43774Regulated Entity ID: 100248749Facility Name: Channelview Facility Dry DocksCompany Name: Southwest Shipyard, L.P.Company Contact Name:

Bernard Diaz

Company Contact Number:

713-378-8757

County: Harris

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CAS # Chemical Species Other SpeciesShort-Term ESL

(µg/m³)Long-Term ESL

(µg/m³)STACK1 STACK1 STACK1 STACK1

78-93-3 methyl ethyl ketone 18000 2600 50 75 200 320108-88-3 toluene 4500 1200 10 55 40 235497-19-8 sodium carbonate Must Meet NAAQS Must Meet NAAQS

N/A Other (Please specify): Activated charcoal Provide Documentation Provide Documentation 6 10 25 40

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CAS # Chemical Species Other SpeciesShort-Term ESL

(µg/m³)Long-Term ESL

(µg/m³) BRSTK1 BRSTK1 BRSTK1 BRSTK1 DD12H DD12H DD12H DD12H BRFUG1 BRFUG1 BRFUG1 BRFUG1 BRFUG2 BRFUG2 BRFUG2 BRFUG2 BRFUG3 BRFUG3 BRFUG3 BRFUG3 BRFUG4 BRFUG4 BRFUG4 BRFUG4 MAR4 MAR4 MAR4 MAR4 FU4 FU4 FU4 FU498-56-6 1-chloro-4-(trifluoromethyl)benzene 1830 183 8.16 1.32 55.31 16.59 72.66 0.874 0.141 0.874 0.141 0.874 0.141 0.874 0.141 4.22 3.16 4.22 5.00

Administrative Information:


Speciated Emissions

Speciated Emissions by Model ID

Example:

This sheet documents emissions for all source types with speciated emissions (i.e., health effect analyses). All cells that apply must be completed for each Model ID.

Warning: Do NOT print this sheet.

Instructions: 1. Select the Chemical Abstract Service (CAS) number of each species. The name of chemical species and the short-term and long-term ESLs of each chemical species will be automatically populated, if it is known. 2. For CAS numbers not listed, select "N/A". The Chemical Species cell will populate with "Other (Please Specify):". In the Other Species column, a drop down list of all pollutants without a CAS number listed (“not found”) but still in the Toxicology Factor Database will appear. Reference the “Speciated Chemicals” sheet to determine if your chemical is one of these first. If it is found, select this chemical from the Other Species drop down. If the chemical species is still not on the Speciated Chemicals sheet, you may type in the name of the chemical species. For these chemical species, provide additional attachments or correspondence for which ESL will be used in your modeling demonstration. 3. Enter the modeled project-wide and site-wide emission rates for each chemical species, in pounds per hour and tons per year, as applicable. If a site-wide analysis is not evaluated, leave the site-wide emissions blank or indicate with “N/A”.

Notes: 1. For pollutants where the ESL populates “Must Meet NAAQS,” be sure that these emissions are included in your NAAQS demonstration rather than your health effects demonstration. 2. For pollutants when the ESL populates “Provide Documentation,” the applicant must provide documentation for the ESL they will be using. This can include, but is not limited to, email correspondence with the Toxicology Division. 3. The Model IDs where “Health Effect Pollutant” was indicated in the Point+Flare Emissions, Area Source Emissions, and Volume Source Emissions sheets (collectively “Emissions sheets”) will auto populate in row 24.

Tips:1. Be sure to select CAS number first so the chemical species and ESLs will automatically populate. 2. To check the list of chemical species or confirm the CAS numbers go to the “Speciated Chemicals” sheet. 3. Do not insert, cut, or delete rows.

Go to Speciated Chemicals sheet

Page 1


Combined Emissions


Company Name: Southwest Shipyard, LPEPN Model ID

Modeling Scenario Pollutant

Modeled Averaging Time Standard Type Review Context Intermittent

Source Type

Modeled Emission Rate [lb/hr]

DD3STK DD3STKHU deling - Health Generic 1-hr No Point 1.00DD3STK DD3STKNU eling - NAAQS Generic 24-hr No Point 1.00DD8STK DD8BLASTNU eling - NAAQS Generic 24-hr No Point 1.00DD15STK DD15BLASTNU eling - NAAQS Generic 24-hr No Point 1.00DD12STK DD12BLASTNU eling - NAAQS Generic 24-hr No Point 1.00DD3STK DD3STKHU deling - Health Generic Annual No Point 0.23DD3STK DD3STKNU eling - NAAQS Generic Annual No Point 0.23DD8STK DD8BLASTNU eling - NAAQS Generic Annual No Point 0.23DD15STK DD15BLASTNU eling - NAAQS Generic Annual No Point 0.23DD12STK DD12BLASTNU eling - NAAQS Generic Annual No Point 0.23DD8STK DD8BLASTN AAQS Analys PM2.5 24-hr NAAQS SIL analysis No Point 0.00POT-FILL POTFILLN AAQS Analys PM2.5 24-hr NAAQS SIL analysis No Point 0.00DD12STK DD12BLASTN AAQS Analys PM2.5 Annual NAAQS SIL analysis No Point 0.00POT-FILL POTFILLN AAQS Analys PM2.5 Annual NAAQS SIL analysis No Point 0.00DD8STK DD8BLASTN AAQS Analys PM10 24-hr NAAQS SIL analysis No Point 0.02POT-FILL POTFILLN AAQS Analys PM10 24-hr NAAQS SIL analysis No Point 0.01BRSTK1 BRSTK1 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Point --BRSTK1 BRSTK1 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Point --DD8STK DD8BLASTHU deling - Health Generic 1-hr No Point 1.00DD15STK DD15BLASTHU deling - Health Generic 1-hr No Point 1.00DD12STK DD12BLASTHU deling - Health Generic 1-hr No Point 1.00DD8STK DD8BLASTHU deling - Health Generic Annual No Point 0.23DD15STK DD15BLASTHU deling - Health Generic Annual No Point 0.23DD12STK DD12BLASTHU deling - Health Generic Annual No Point 0.23POT-FILL POTFILLHU deling - Health Generic 1-hr No Point 1.00POT-FILL POTFILLHU deling - Health Generic Annual No Point 0.23POT-FILL POTFILLNU eling - NAAQS Generic 1-hr No Point 1.00POT-FILL POTFILLNU eling - NAAQS Generic Annual No Point 0.23DD2 DD2HU deling - Health Generic 1-hr No Area 0.30DD1 DD1HU deling - Health Generic 1-hr No Area 0.30DD15 DD15HU deling - Health Generic 1-hr No Area 0.30DD8 DD8HU deling - Health Generic 1-hr No Area 0.30DD12 DD12HU deling - Health Generic 1-hr No Area 0.30DD2 DD2HU deling - Health Generic Annual No Area 0.07DD1 DD1HU deling - Health Generic Annual No Area 0.07DD15 DD15HU deling - Health Generic Annual No Area 0.07DD8 DD8HU deling - Health Generic Annual No Area 0.07DD12 DD12HU deling - Health Generic Annual No Area 0.07DD2 DD2NU eling - NAAQS Generic 24-hr No Area 0.30DD1 DD1NU eling - NAAQS Generic 24-hr No Area 0.30DD15 DD15NU eling - NAAQS Generic 24-hr No Area 0.30DD8 DD8NU eling - NAAQS Generic 24-hr No Area 0.30DD12 DD12NU eling - NAAQS Generic 24-hr No Area 0.30DD2 DD2NU eling - NAAQS Generic Annual No Area 0.07DD1 DD1NU eling - NAAQS Generic Annual No Area 0.07DD15 DD15NU eling - NAAQS Generic Annual No Area 0.07DD8 DD8NU eling - NAAQS Generic Annual No Area 0.07DD12 DD12NU eling - NAAQS Generic Annual No Area 0.07DD8 DD8N AAQS Analys PM2.5 24-hr NAAQS SIL analysis No Area 0.01DD12 DD12N AAQS Analys PM2.5 Annual NAAQS SIL analysis No Area 0.00DD8 DD8N AAQS Analys PM10 24-hr NAAQS SIL analysis No Area 0.07DD12 DD12H th Effects Ana Health Effects Pollutant 1-hr Health Effects Project Wide No Area --DD12 DD12H th Effects Ana Health Effects Pollutant Annual Health Effects Project Wide No Area --DD12 DD12H th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Area --DD12 DD12H th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Area --DD15CLN DD15CLHU deling - Health Generic 1-hr No Area 1.00DD8CLN DD8CLHU deling - Health Generic 1-hr No Area 1.00DD12CLN DD12CLHU deling - Health Generic 1-hr No Area 1.00DD15CLN DD15CLHU deling - Health Generic Annual No Area 0.23DD8CLN DD8CLHU deling - Health Generic Annual No Area 0.23DD12CLN DD12CLHU deling - Health Generic Annual No Area 0.23DD15CLN DD15CLNU eling - NAAQS Generic 24-hr No Area 1.00DD8CLN DD8CLNU eling - NAAQS Generic 24-hr No Area 1.00DD12CLN DD12CLNU eling - NAAQS Generic 24-hr No Area 1.00DD15CLN DD15CLNU eling - NAAQS Generic Annual No Area 0.23DD8CLN DD8CLNU eling - NAAQS Generic Annual No Area 0.23DD12CLN DD12CLNU eling - NAAQS Generic Annual No Area 0.23DD15CLN DD15CLNU eling - NAAQS PM2.5 24-hr NAAQS SIL analysis No Area 0.00DD15CLN DD15CLNU eling - NAAQS PM2.5 Annual NAAQS SIL analysis No Area 0.00DD15CLN DD15CLNU eling - NAAQS PM10 24-hr NAAQS SIL analysis No Area 0.00BRFUG BRFUG1 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Volume --BRFUG BRFUG2 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Volume --BRFUG BRFUG3 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Volume --BRFUG BRFUG4 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Volume --MAR4 MAR4 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Volume --FU4 FU4 th Effects Ana Health Effects Pollutant 1-hr Health Effects Site Wide No Volume --BRFUG BRFUG1 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Volume --BRFUG BRFUG2 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Volume --BRFUG BRFUG3 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Volume --BRFUG BRFUG4 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Volume --MAR4 MAR4 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Volume --FU4 FU4 th Effects Ana Health Effects Pollutant Annual Health Effects Site Wide No Volume --

Page 1


Modeling Scenarios


Company Name: Southwest Shipyard, LPModeling Scenario

Health Effects Analysis

NAAQS Analysis

Unit Modeling - Health Effects


For the exempt solvent site-wide modeling, all emissions were modeled as occurring simultaneously as a conservative estimate. For the project MERA review of crystalline silica emissions, two source groups were used

with the UIMs to represent sources which cannot occur within the same hour and are described below.

Source Group BLAST – This source group contains both the blast pot filling and the abrasive blasting emissions from the dust collector stacks, as abrasive blasting cannot occur in the same hour as abrasive cleanup.

Source Group CLEAN – This source group contains both the blast pot filling and the abrasive cleanup emissions from the dry docks, as abrasive spent media cleanup operations cannot occur in the same hour as either

abrasive blasting.

The worst-case UIM impacts from these two source groups was used for the short-term silica MERA analysis. The annual MERA impacts included all of the silica sources, represented by Source Group ALL.

NAAQS analysis for project. UIMs used to determine "worst-case" source locations in NAAQS analysis. All sources were evaluated at their maximum allowable emission rate and operating simultaneously. Additionally, all

the of the project sources were modeled as if new, rather than just evaluating the project increase in order to provide a conservative evaluation of potential impacts.

Unit Modeling for Health Effects Analysis. Each source was modeled with a 1 lb/hr or 1 ton per year emission rate, for the 1-hr and annual averaging period respectively. For emissions from the shrouds, the emission rate

was multiplied by 0.3 per the TCEQ Shroud Memo "Outdoor Blasting and Coating Adjustment Factors for Shrouds" 2006. Additionally, due to Section 382.006 of House Bill 3040, as Channelview is a shipbuilding and

ship repair operation, receptors were not placed over water for non-criteria pollutants.

Unit Modeling for NAAQS analysis. Each source was modeled with a 1 lb/hr or 1 ton per year emission rate, for the 24-hr and annual averaging period respectively. For emissions from the shrouds, the emission rate was

multiplied by 0.3 per the TCEQ Shroud Memo "Outdoor Blasting and Coating Adjustment Factors for Shrouds" 2006

Scenario Description:

Page 1


NAAQS-SPL Modeling Results



Pollutant Averaging Time GLCmax (µg/m3) De Minimis (µg/m3)

SO2 1-hr 14.3H2SO4 1-hr 1H2SO4 24-hr 0.3

H2S 1-hr

2.16(If property is residential, recreational, business, or

commercial)

H2S 1-hr

3.24(If property is not residential,

recreational, business, or commercial)

Pollutant Averaging Time GLCmax (µg/m3) Standard (µg/m3)

SO2 1-hr 715H2SO4 1-hr 50H2SO4 24-hr 15

H2S 1-hr

108 (If property is residential, recreational, business, or

commercial)

H2S 1-hr

162 (If property is not residential,

recreational, business, or commercial)

Pollutant Averaging Time GLCmax (µg/m3) De Minimis (µg/m3)

SO2 1-hr 7.8*SO2 3-hr 25SO2 24-hr 5SO2 Annual 1PM10 24-hr 3.59417 5NO2 1-hr 7.5**NO2 Annual 1CO 1-hr 2000CO 8-hr 500

Table 3. Modeling Results for Minor NSR De Minimis

Table 1. Project-Related Modeling Results for State Property Line

Table 2. Site-wide Modeling Results for State Property Line

Additional information for the De Minimis values listed above can be found at:

** https://www.tceq.texas.gov/assets/public/permitting/air/memos/guidance_1hr_no2naaqs.pdf* https://www.epa.gov/sites/production/files/2015-07/documents/appwso2.pdf

Page 1

https://www.epa.gov/sites/production/files/2015-07/documents/appwso2.pdf



https://www.tceq.texas.gov/assets/public/permitting/air/memos/guidance_1hr_no2naaqs.pdf









Pollutant Averaging Time GLCmax (µg/m3) Secondary PM2.5 Contribution (µg/m3)

Total Conc. = Secondary PM2.5 + GLCmax (µg/m3)

De Minimis (µg/m3)

PM2.5 24-hr 0.632 0 0.63158 1.2*PM2.5 Annual 0.0545 0 0.05448 0.2*

Table 4. PM2.5 Modeling Results for Minor NSR De Minimis

Additional information for the De Minimis values listed above can be found at:* https://www.tceq.texas.gov/permitting/air/modeling/epa-mod-guidance.html

Page 2

https://www.tceq.texas.gov/permitting/air/modeling/epa-mod-guidance.html










Pollutant Averaging Time GLCmax (µg/m3) Background (µg/m3)Total Conc. = [Background +

GLCmax] (µg/m3) Standard (µg/m3)

SO2 1-hr 0 0 196SO2 3-hr 0 0 1300SO2 24-hr 0 0 365SO2 Annual 0 0 80PM10 24-hr 0 0 150Pb 3-mo 0 0 0.15

NO2 1-hr 0 0 188NO2 Annual 0 0 100CO 1-hr 0 0 40000CO 8-hr 0 0 10000

Table 5. Total Concentrations for Minor NSR NAAQS (Concentrations > De Minimis)

Page 3





Pollutant Averaging Time GLCmax (µg/m3)Secondary PM2.5 Contribution

(µg/m3) Background (µg/m3)Total Conc. = [Background + Secondary + GLCmax] (µg/m3) Standard (µg/m3)

PM2.5 24-hr 0 0 0 35PM2.5 Annual 0 0 0 12

Table 6. Total Concentrations for Minor NSR NAAQS (Concentrations > De Minimis)

Page 4


Unit Impact Multipliers



EPN Model ID Modeling Scenario Averaging TimeGLCmax

(µg/m3 per lb/hr)GLCmax

(µg/m3 per tpy)DD3STK DD3STKHU Unit Modeling - Health Effects 1-hr 42.59DD3STK DD3STKNU nit Modeling - NAAQS Analys 24-hr 17.64DD8STK DD8BLASTNU nit Modeling - NAAQS Analys 24-hr 11.88DD15STK DD15BLASTNU nit Modeling - NAAQS Analys 24-hr 11.50DD12STK DD12BLASTNU nit Modeling - NAAQS Analys 24-hr 11.68DD3STK DD3STKHU Unit Modeling - Health Effects Annual 0.592DD3STK DD3STKNU nit Modeling - NAAQS Analys Annual 0.592DD8STK DD8BLASTNU nit Modeling - NAAQS Analys Annual 0.439DD15STK DD15BLASTNU nit Modeling - NAAQS Analys Annual 0.431DD12STK DD12BLASTNU nit Modeling - NAAQS Analys Annual 0.450DD8STK DD8BLASTHU Unit Modeling - Health Effects 1-hr 39.39DD15STK DD15BLASTHU Unit Modeling - Health Effects 1-hr 38.38DD12STK DD12BLASTHU Unit Modeling - Health Effects 1-hr 42.22DD8STK DD8BLASTHU Unit Modeling - Health Effects Annual 0.439DD15STK DD15BLASTHU Unit Modeling - Health Effects Annual 0.431DD12STK DD12BLASTHU Unit Modeling - Health Effects Annual 0.450POT-FILL POTFILLHU Unit Modeling - Health Effects 1-hr 85.82POT-FILL POTFILLHU Unit Modeling - Health Effects Annual 1.30POT-FILL POTFILLNU nit Modeling - NAAQS Analys 1-hr 99.77POT-FILL POTFILLNU nit Modeling - NAAQS Analys Annual 4.05

DD2 DD2HU Unit Modeling - Health Effects 1-hr 18.28DD1 DD1HU Unit Modeling - Health Effects 1-hr 21.10DD15 DD15HU Unit Modeling - Health Effects 1-hr 18.28DD8 DD8HU Unit Modeling - Health Effects 1-hr 21.10DD12 DD12HU Unit Modeling - Health Effects 1-hr 23.44DD2 DD2HU Unit Modeling - Health Effects Annual 0.198DD1 DD1HU Unit Modeling - Health Effects Annual 0.199DD15 DD15HU Unit Modeling - Health Effects Annual 0.198DD8 DD8HU Unit Modeling - Health Effects Annual 0.199DD12 DD12HU Unit Modeling - Health Effects Annual 0.207DD2 DD2NU nit Modeling - NAAQS Analys 24-hr 9.96DD1 DD1NU nit Modeling - NAAQS Analys 24-hr 12.58DD15 DD15NU nit Modeling - NAAQS Analys 24-hr 9.96DD8 DD8NU nit Modeling - NAAQS Analys 24-hr 12.58DD12 DD12NU nit Modeling - NAAQS Analys 24-hr 10.18DD2 DD2NU nit Modeling - NAAQS Analys Annual 0.261DD1 DD1NU nit Modeling - NAAQS Analys Annual 0.268DD15 DD15NU nit Modeling - NAAQS Analys Annual 0.261DD8 DD8NU nit Modeling - NAAQS Analys Annual 0.268DD12 DD12NU nit Modeling - NAAQS Analys Annual 0.293

DD15CLN DD15CLHU Unit Modeling - Health Effects 1-hr 130.95DD8CLN DD8CLHU Unit Modeling - Health Effects 1-hr 146.61DD12CLN DD12CLHU Unit Modeling - Health Effects 1-hr 133.83DD15CLN DD15CLHU Unit Modeling - Health Effects Annual 1.08DD8CLN DD8CLHU Unit Modeling - Health Effects Annual 1.10DD12CLN DD12CLHU Unit Modeling - Health Effects Annual 1.19DD15CLN DD15CLNU nit Modeling - NAAQS Analys 24-hr 3231.46DD8CLN DD8CLNU nit Modeling - NAAQS Analys 24-hr 2632.16DD12CLN DD12CLNU nit Modeling - NAAQS Analys 24-hr 1947.96DD15CLN DD15CLNU nit Modeling - NAAQS Analys Annual 649.03DD8CLN DD8CLNU nit Modeling - NAAQS Analys Annual 220.20DD12CLN DD12CLNU nit Modeling - NAAQS Analys Annual 528.89

Facility:

Page 1


Health Effect Modeling Results


Company Name: Southwest Shipyard, LPStep 3 Step 4: Production Step 4: MSS Step 5: MSS Only Step 5: Hours of Exceedance Step 6 Step 7: Site Wide Step 7: Hours of Exceedance

Chemical Species CAS Number Averaging Time ESL [µg/m3]

10% ESLStep 3 Modeled GLCmax

[µg/m3]

25 % ESL Step 4 Production GLCmax since most recent site wide

modeling [µg/m3]

10% ESL Step 4 Production

Project Only GLCmax [µg/m3]

50% ESLStep 4 MSS GLCmax since

most recent site wide modeling [µg/m3]

25% ESL Step 4 MSS Project Only

GLCmax [µg/m3]

Full ESL Step 5 GLCmax

[µg/m3]

1X ESL GLCmax Step 5 MSS Hours of

Exceedance


Exceedance


Exceedance


Exceedance Was Step 6 relied on to fall out of the

MERA?Site Wide GLCmax

[µg/m3]Site Wide GLCni

[µg/m3]

GLCni LocationEasting:X [m]

GLCni LocationNorthing:

Y [m] 1X ESL GLCni

Hours of Exceedance 2X ESL GLCmax



Hours of Exceedance 1-chloro-4-(trifluoromethyl)benzene 98-56-6 1-hr 1830 1296.52 No (Proceed with Step 7) 1806.24 458.15 300100.00 3297800.00

acetone 1-hr 32.401-chloro-4-(trifluoromethyl)benzene 98-56-6 Annual 183 NA 71.42 13.80 300100.00 3297800.00

silica, crystalline (quartz) 1-hr 1.22silica, crystalline (quartz) Annual 0.02

Modeled Health Effect Results (MERA Guidance):Facility:

Page 1


Modeling File Names



Model File Base Name Pollutant Averaging Time File Extensions Additional File Description

Unit Impacts Health Effects_2016_Unit_HR Generic 1-hr *.dta, *.grf, *.lst, *.run, *.bndUnit Modeling using health effects

receptor grid 1-hour averaging period.

Unit Impacts Health Effects_2016_Unit_AN Generic Annual *.dta, *.grf, *.lst, *.run, *.bndUnit Modeling using health effects

receptor grid annual averaging period.

Unit Impacts NAAQS_2016_HR Generic 24-hr *.dta, *.grf, *.lst, *.run, *.bnd Unit Modeling using NAAQS receptor grid 24-hour averaging period.

Unit Impacts NAAQS_2016_AN Generic Annual *.dta, *.grf, *.lst, *.run, *.bnd Unit Modeling using NAAQS receptor grid annual averaging period.

NAAQS Analysis_2016_PM2.5HR PM2.5 24-hr *.dta, *.grf, *.lst, *.run, *.bnd NAAQS SIL Analysis for PM2.5 24-hour averaging period.

NAAQS Analysis_2016_PM2.5AN PM2.5 Annual *.dta, *.grf, *.lst, *.run, *.bnd NAAQS SIL Analysis for PM2.5 annual averaging period.

NAAQS Analysis_2016_PM10HR PM10 24-hr *.dta, *.grf, *.lst, *.run, *.bnd NAAQS SIL Analysis for PM10 24-hour averaging period.

GLCMax_2016_CHLR_HR1-chloro-4-

(trifluoromethyl)benzene

1-hr *.dta, *.grf, *.lst, *.run, *.bnd, *.max

Sitewide GLCMax health effects analysis for 1-chloro-4-

(trifluoromethyl)benzene for 1-hour averaging period

GLCMax_2016_CHLR_AN1-chloro-4-


Annual *.dta, *.grf, *.lst, *.run, *.bnd, *.max

Sitewide GLCMax health effects analysis for 1-chloro-4-

(trifluoromethyl)benzene for annual averaging period

GLCNI_2016_CHLR_HR1-chloro-4-


1-hr *.dta, *.grf, *.lst, *.run, *.bnd, *.max

Sitewide GLCNI health effects analysis for 1-chloro-4-

(trifluoromethyl)benzene for 1-hour averaging period

GLCNI_2016_CHLR_AN1-chloro-4-


Annual *.dta, *.grf, *.lst, *.run, *.bnd, *.max

Sitewide GLCNI health effects analysis for 1-chloro-4-

(trifluoromethyl)benzene for annual averaging period

Channelviewdrydock all all .pdf

AERSURFACE analysis. Calculated using AERSURFACE version 13016.

While a new version of AERSURFACE was released earlier

in 2020, the software is having difficulty working on our systems.

Given then the current surface is low and the facility is located on the ship

channel, the update to AERSURFACE is unlikely to be

significantly different.

HARRISHOULCH16L all all .SFC, .PFL TCEQ-provided MET data.

CAPs 10 km radius all all .pdf Population estimate for urban dispersion.

Downwash - Health Effects Grid all all *.pip, *.prw, *.so, *.tab Downwash for health effects receptor grid.

Downwash - NAAQS Grid all all *.pip, *.prw, *.so, *.tab Downwash for NAAQS receptor grid.

NED_61502284 all all *.tif NED data file.

Facility:

Page 1

BM2

E 300.219

N 3,297.187

BM1

E 300.601

N 3,297.546

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FU4

BLDG3

BLDG1

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DD15BLAST

DD8BLAST

DD12BLAST

MAR4

POTFILL

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SCALE IN FEET

0 200' 400'100'

1" = 200'-0"

E

S

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NIMAGERY SOURCE: Google Earth (12/01/2019)

FILE:


Houston, TX 77042Phone: 713.244.1000

Fig 1-2 - SW ShipYard-Channelview - Modeling Plot Plan.dwg

DATE: JULY 2020

PROJECT-MGR: E. STANKO

REQUEST BY: N. NUSSBAUM


FIGURE 1-2

TITLE:

PROJECT:

MODELING PLOT PLAN




L E G E N D

POINT SOURCE MODEL ID

BENCHMARK LOCATION

PROPERTY BOUNDARY

DRY DOCKS

VOLUME SOURCE MODEL ID

VOLUME SOURCE AREA

DOWNWASH STRUCTURE (BUILDING)

WITH DOWNWASH STRUCTURES

NSR Permit 43774 Renewal and Amendment

AREA SOURCE MODEL ID


July 15, 2020

Air Permits Division, MC‐163

Texas Commission on Environmental Quality (TCEQ)

12100 Park 35 Circle

Austin, Texas 78753

Re: Impacts Analysis and EMEW Attachments

Permit Renewal and Amendment

Permit Number: 43774, TCEQ Project Number: TBD

Dry Dock Surface Coating and Abrasive Blasting Facility

Southwest Shipyard, LP Channelview, Harris County

Regulated Entity Number: RN100248749

Customer Reference Number: CN600135354

Dear TCEQ Air Permits Division:

Southwest Shipyard LP (Southwest Shipyard) is submitting refined modeling in support of the subject

NSR permit application. The following modeling analyses were performed:

National Ambient Air Quality Standards (NAAQS) modeling was performed to demonstrate compliance with the NAAQS for PM10 and PM2.5 at all off‐property receptors. Specifically, a NAAQS Significant Impact Level (SIL) analysis was performed demonstrating that the project impacts are less that the respective PM10 and PM2.5 SILs (minor NSR de minimis analysis);

A minor source health effects evaluation was performed for exempt solvents, and two species of exempt solvents were evaluated, which are 1‐chloro‐4‐(trifluoromethyl)benzene (CAS 98‐56‐6), and acetone (CAS 67‐64‐1);

A MERA Step 3 (10‐percent of ESL Evaluation) was performed for crystalline silica emissions (PM10) using UIMs, showing project impacts are less than 10‐percent of the ESL.

Generic modeling using Unit Impact Multipliers (UIMs) was performed to demonstrate that changes in permit representations (i.e., emission point discharge parameters) will not be detrimental to the general public or the environment and accordingly, do not require a health affects analysis for surface coating operations (speciated VOC or speciated PM species). This was necessary for previous source EPN: DD3STK, which is now EPN: DD12. The proposed changes for this source do not result an increase in the model predicted off‐property concentrations.

Generic modeling using UIMs to evaluate unit impacts for new sources added as part of this amendment.

A summary of changes associated with this project and updated representations are provided in Table 1.

Page 1 of 9

DD1 DD8 Dry Dock 1 Shroud Dry Dock 8 Shroud Blasting and Coating Coating Only No ChangeDD2 DD15 Dry Dock 2 Shroud Dry Dock 15 Shroud Blasting and Coating Coating Only No Change

DD3STK DD12 Dry Dock 3 Stack Dry Dock 12 Shroud Blasting and Coating Coating Only Change from stack to shroud-- DD8BLAST -- Dry Dock Blasting 8 Dust Collector -- Blasting Only New Source Added-- DD15BLAST -- Dry Dock Blasting 15 Dust Collector -- Blasting Only New Source Added-- DD12BLAST -- Dry Dock Blasting 12 Dust Collector -- Blasting Only New Source Added

DD8CLN -- Dry Dock Blasting 8 Abrasive Cleanup -- Abrasive Cleanup New Source AddedDD15CLN -- Dry Dock Blasting 15 Abrasive Cleanup -- Abrasive Cleanup New Source AddedDD12CLN -- Dry Dock Blasting 12 Abrasive Cleanup -- Abrasive Cleanup New Source Added

-- POTFILL -- Blast Pot Filling -- Blast Pot Filling New Source Added

Currently, three (3) Dry Docks where coating and abrasive blasting operations occur are authorized under NSR permit No. 43744, which are: Dry Dock 1 (EPN: DD1), Dry Dock 2 (EPN: DD2), and Dry Dock 3 (EPN: DD3STK). Under the current authorization, blasting and coating operations within Dry Docks 1 and 2 occur within movable shrouds (EPNs DD1 and DD2), while emissions from coating and blasting from Dry Dock 3 are captured and routed to a stack (EPN DD3STK).

As part of the changes in this renewal and amendment, all three dry docks are being renamed, with Dry Dock 1 being renamed Dry Dock 8 (EPN: DD8), Dry Dock 2 being renamed Dry Dock 15 (EPN: DD15) and Dry Dock 3 being renamed Dry Dock 12 (EPN: DD12). Additionally:

• Coating operations from Dry Dock 12 (formerly Dry Dock 3) will no longer be captured by the stack (formerly EPN: DD3STK) and will now occur within 4-sided movable shrouds, the same as Dry Docks 8 and 15 (formerly Dry Docks 1 and 2).

• Abrasive blasting at all the dry docks will now be captured by mobile dust collectors and vented through a stack (EPNs DD8STK, DD15STK, and DD12STK). These are new sources.

• A new source is being added representing blast pot filling operations (EPN POT-FILL).

• Three new EPNs associated with cleanup of abrasive blasting media at the dry docks are being added (EPNS DD8CLN, DD15CLN, and DD12CLN).

Southwest Shipyard, LP

Impacts Analysis and EMEW AttachmentsJuly 2020

Updated Authorization

Associated Operation

Change in Emission Type Representation

Permit Number 43774 Renewal and Amendment

Current Authorization

Model Source ID

Updated Representation Model Source ID

Current Authorization Description

Updated Representation DescriptionCurrent Authorization Associated Operation

Table 1 - Description of Project Changes

Table 1 ‐ Description of Project Changes Page 2 of 9


July 15, 2020 Impacts Analysis and EMEW Attachments

UIM Comparison

This memo presents the UIMs from two (2) sets of modeling evaluations denoted as “Current

Authorization”, and “Updated Representation” as detailed in Table 2.

Table 2: Model Setups Evaluated

Model Run Description Model and Version


Current authorization source parameters evaluated using AERMOD to determine UIMs.

AERMOD v19191

Updated Representation

Updated source parameters for coating operations and dust collectors’ stacks evaluated using AERMOD to determine UIMs.

AERMOD v19191

Note that due to Section 382.006 of House Bill 3040, as the Channelview yard is a shipbuilding and ship

repair operation, receptors were not placed over water for non‐criteria pollutants health effect impact

evaluation. Due to the proximity of the dry docks to the Houston Ship Channel, this required the use of

separate receptor grids for the State Health Effects analysis, which excludes the receptors located over

water, and the NAAQS analysis which includes the receptors located over water.

The unit impacts for both scenarios and receptor grids were evaluated separately and are presented in

Tables 3 and 4.

The impacts presented in Table 3 are the UIMs from both the current authorization and the updated

representation for the NAAQS analysis receptor grid. The results are summarized below.

The 24‐hour and annual unit impacts from DD1/DD8 and DD2/DD15 are the same as these

sources have not changed;

The 24‐hour and annual unit impacts from DD12 are lower than the prior DD3STK

representation; and

The UIMs for new sources are presented.

Page 3 of 9

Unit 24-hr Impacts

(µg/m3)

Unit Annual Impacts

(µg/m3)

Unit 24-hr Impacts

(µg/m3)

Unit Annual Impacts

(µg/m3)

Unit 24-hr Impacts

(µg/m3)

Unit Annual Impacts

(µg/m3)

DD1 DD8 Dry Dock 1 Shroud Dry Dock 8 Shroud NAAQS 12.6 0.27 12.6 0.27 0.0 0.0

DD2 DD15 Dry Dock 2 Shroud Dry Dock 15 Shroud NAAQS 10.0 0.26 10.0 0.26 0.0 0.0

DD3STK DD12 Dry Dock 3 Stack Dry Dock 12 Shroud NAAQS 17.6 0.59 10.2 0.29 -7.5 -0.3

-- DD8BLAST -- Dry Dock Blasting 8 Dust Collector NAAQS -- -- 11.9 0.44 -- --



-- DD8CLN -- Dry Dock Blasting 8 Abrasive Cleanup NAAQS -- -- 2632.2 220.20 -- --



-- POTFILL -- Blast Pot Filling NAAQS -- -- 99.8 4.05 -- --

24-Hour Impacts

Annual Impacts

DD8 DD12

DD8BLAST DD12BLAST

DD15CLN DD15CLN

Worst Case Coating Shroud:

Worst Case Blasting Dust Collector:

Worst Case Spent Abrasive Cleanup:

Worst Case Sources for Modeling NAAQS Impacts (for Emissions Caps):

Southwest Shipyard, LP Permit Number 43774 Renewal and Amendment


2 Due due to the new EPN POT-FILL representing blast pot filling and the addition of dry dock abrasive cleanup operations, a project NAAQS analysis has been performed to demonstrate that the impacts are below the SIL.

1 All emissions from all blasting operations are proposed to be captured and controlled by mobile dust collectors DD8STK, DD15STK, and DD12STK. Currently, only emissions from drydock 3 is captured and emitted from stack DD3STK. Proposed particulate from dry dock shroud represents particulate emissions from coating operations only.


Model Source ID 1



Model Source ID


Description

Current Authorization Impacts Net Change 2

Updated Representation Impacts

Grid

Table 3 - Current Authorization Impacts vs Updated Representation- NAAQS Analysis Grid

Table 3 ‐ Current Authorization Impacts vs Updated Representation‐ NAAQS Analysis Grid

Unit 1-hr Impacts

(µg/m3)

Unit Annual Impacts

(µg/m3)

Unit 1-hr Impacts

(µg/m3)

Unit Annual Impacts

(µg/m3)

Unit 1-hr Impacts

(µg/m3)

Unit Annual Impacts

(µg/m3)

DD1 DD8 Dry Dock 1 Shroud Dry Dock 8 Shroud Health Effects 21.1 0.20 21.1 0.20 0.0 0.0

DD2 DD15 Dry Dock 2 Shroud Dry Dock 15 Shroud Health Effects 18.3 0.20 18.3 0.20 0.0 0.0

DD3STK DD12 Dry Dock 3 Stack Dry Dock 12 Shroud Health Effects 42.6 0.59 23.4 0.21 -19.2 -0.4

-- DD8BLAST -- Dry Dock Blasting 8 Dust Collector Health Effects -- -- 39.4 0.439 -- --



-- DD8CLN -- Dry Dock Blasting 8 Abrasive Cleanup Health Effects -- -- 146.6 1.097 -- --



-- POTFILL -- Blast Pot Filling Health Effects -- -- 85.8 1.30 -- --

Hourly Impacts

Annual Impacts

DD12 DD12

DD12 DD12

DD8 DD12

Worst Case Sources for Modeling HEALTH EFFECTS Impacts (for Emissions Caps):

Worst Case Coating Shroud:

Worst Case Blasting Dust Collector:

Worst Case Spent Abrasive Cleanup:



1. As shown, the impacts for state health effects analysis are equal to or less than the current representation. As such, these changes will not result in an increase in offsite impacts forhealth effects analysis for VOCs. As exempt solvents are not listed on the current MAERT, a health effects analysis has been included to demonstrate compliance with these compounds with applicable health effects standards. Additionally, abrasive blasting operations at the Dry Docks may utilize silica blasting media. As such, a health effects analysis was included for project increases and new sources of crystalline silica.

Updated Representation Model Source ID


Description

Table 4 - Current Authorization Impacts vs Updated Representation- State Health Effects Analysis Grid


Model Source ID


Grid

Updated Representation Impacts

Current Authorization Impacts Net Change 1

Table 4 ‐ Current Authorization Impacts vs Updated Representation‐ Health Effects Analysis Grid



The impacts presented in Table 4 are the UIMs from both the current authorization and the updated

representation for the State Health Effects analysis receptor grid. The results are summarized below.

The 1‐hour and annual unit impacts from DD1/DD8 and DD2/DD15 are the same as these

sources have not changed;

The 1‐hour and annual unit impacts from DD12 are lower than the prior DD3STK representation.

This demonstrates that the changes in permit representations (i.e., emission point discharge

parameters) will not be detrimental to the general public or the environment and accordingly,

do not require a health affects analysis for surface coating operations (speciated VOC or

speciated PM species); and

The 1‐hour and annual unit impacts from the dust collector stacks, abrasive blast media cleanup,

and blasting pot filling are provided (EPNs: DD8BLAST, DD15BLAST, DD12BLAST, DD8CLN,

DD15CLN, DD12CLN, and POTFILL). These unit impacts are utilized in the Table 6 MERA analysis.

As shown, impacts from the updated representation for the EPN: DD12 (shrouded surface coating) are

equal to or lower than the current authorization. As this project involves a reduction in the emissions of

both 1‐hour and annual emission rates from coating activities, offsite impacts for the state health effects

analysis using the updated representation should be lower than the current authorization, indicating

that health effects modeling is not required. However, as the current MAERT does not include exempt

solvents from coating operations, health effects modeling for the exempt solvents has been included to

demonstrate compliance with applicable health effects standards. Table 5 includes the health effects

analysis for these ES compounds using the worst‐case unit impacts.

The new blasting sources; abrasive blasting dust collector stacks, spent media cleanup, and blast pot

filling operations potentially use silica blasting media. As such, there are potential offsite impacts of

crystalline silica. As such, a state health effects MERA (Step 3: 10‐percent of ESL evaluation) analysis has

been provided calculating the predicted offsite impacts using unit modeling in Table 6.

The impacts presented in Table 5 are the estimated exempt solvent offsite concentrations using the

worst‐case UIM from the updated representation using the State Health Effects analysis receptor grid.

The results are summarized below.

Estimated impacts from emissions of 1‐chloro‐4‐(trifluoromethyl)benzene using the unit impacts

are 1,296.52 µg/m3, below the short‐term ESL of 1,800 µg/m3, but greater than 10% of the ESL.

As such, site‐wide modeling is required for this compound. The sitewide modeling for both the

short‐term and annual impacts for 1‐chloro‐4‐(trifluoromethyl)benzene is included with the

modeling submitted with this application.

Estimated unit from emissions of acetone using the unit impacts are 32.4 µg/m3, below 10% of

the ESL of 7,800 µg/m3.. Additionally, as the annual ESL for acetone is 4,800 µg/m3, per MERA

Step 3, no further analysis is required.

Page 6 of 9

Exempt Solvent CAS Emissions (lbs/hr)1

1-chloro-4-(trifluoromethyl)benzene 98-56-6 55.31Acetone 67-64-1 1.38

Exempt SolventWorst-Case Unit Impacts

(ug/m3 per lb/hr)

ST Modeling Impacts

(ug/m3)

Short-Term

ESL (ug/m3)

Long-Term

ESL (ug/m3)

Ratio of Estimated

Impacts to ST ESL

LT ESL < 10% of ST ESL?

Further Modeling Required (MERA

Step 3)?

1-chloro-4-(trifluoromethyl)benzene 1296.52 1,830 183 0.71 No Yes

Acetone 32.40 7,800 4,800 0.004 No No

1 As the unit modeling for the dry dock coating used a 0.3 shroud factor, the emission rate for the unit modeling is the unadjusted emission rate.

23.44

Permit Number 43774 Renewal and AmendmentSouthwest Shipyard, LP


Table 5 - Exempt Solvents Health Effects Modeling Using Unit Impacts

Table 5 ‐ Exempt Solvents Health Effects Modeling Using Unit Impacts Page 7 of 9

Source Material CAS Emissions

(lbs/hr)1

Emissions

(tpy/hr)1

Dry Docks Blasting Dust Collectors 1.68E-02 8.92E-03

Dry Docks Abrasive Cleanup 4.43E-03 7.38E-03

Blast Pot Filling 5.90E-03 7.38E-03

ST Scenarios2 SourceWorst-Case ST

Unit Impacts

(ug/m3 per lb/hr)

ST Modeling Impacts

(ug/m3)

Short-Term

ESL (ug/m3)

Long-Term

ESL (ug/m3)

Ratio of Estimated

Impacts to ST ESL

LT ESL < 10% of ST ESL?

Further Modeling Required (MERA

Step 3)?

Dry Docks Blasting Dust Collectors 42.22

Blast Pot Filling 85.82

Dry Docks Abrasive Cleanup 146.61


LT Scenario SourceWorst-Case LT Unit Impacts

(ug/m3 per tpy)

LT Modeling Impacts

(ug/m3)

Long-Term

ESL (ug/m3)

Ratio of Estimated

Impacts to LT ESL

Further Modeling

Required (MERA Step 3)?

Dry Docks Blasting Dust Collectors 0.45

Dry Docks Abrasive Cleanup 1.19


0.27 8.29% No

Table 6 - Crystalline Silica Health Effects MERA Analysis

Yes Yes, LT analysis required

Scenario 2 - Abrasive Cleanup and Blast Pot

Filling

Scenario 1 - Abrasive Blasting and Blast Pot

Filling1.22

1.16 14

Scenario 3- All sources 0.022

Crystalline Silica (Quartz) 14808-60-7

MERA Step 3 using UIMs

2 Abrasive Blasting and Abrasive Cleanup do not occur at the same time; the spent media cleanup is conducted after the blasting is completed.

Yes Yes, LT analysis required



1 As the unit modeling for the dry dock coating used a 0.3 shroud factor, the emission rate for the unit modeling is the unadjusted emission rate.

0.27 8.26%

14 0.27 8.68%

Table 6 ‐ Crystalline Silica Health Effects Modeling Using Unit Impacts Page 8 of 9



The impacts presented in Table 6 are the estimated crystalline silica offsite concentrations and MERA

analysis from the new blasting sources using the worst‐case UIM from the Health Effects analysis

receptor grid. As abrasive blasting and spent media cleanup cannot occur in the same hour, two

scenarios have been evaluated examining the emissions of both activities in conjunction with blast pot

filling. The results are summarized below.

Estimated short‐term impacts from emissions of crystalline silica from both scenarios are 1.22

µg/m3and 1.16 µg/m3, both below 10% of the short‐term ESL of crystalline silica of 14 µg/m3.

However, as the long‐term ESL of crystalline silica is 0.27 µg/m3, less than 10% of short‐term ESL,

an annual evaluation was performed as well; and

Estimated long‐term impacts of crystalline silica were 0.022 µg/m3, less than 10% of the long‐

term ESL of 0.27. As such, the MERA demonstration is complete and no further analysis is

required.

Summary

Based on the UIM comparison, the changes in representations for surface coating at the dry docks will

result in lower short‐term (1‐hour) and annual UIMs. This demonstrates that the changes in emission

point discharge parameters will not be detrimental to the general public or the environment and

accordingly, do not require a health affects analysis for surface coating operations (speciated VOC or

speciated PM species). Additionally, there is no increase in VOC or PM/PM10/PM2.5 emissions from

surface coating associated with this project.

Due to the new abrasive blasting sources, a project NAAQS analysis has been included to demonstrate

that impacts of PM10 and PM2.5 are below the applicable SILs and has been included in the submitted

modeling. Likewise, project emissions of crystalline silica from the new abrasive blasting sources was

evaluated using MERA Step 3. As both ST and LT impacts were below 10% of the ESL, per MERA Step 3,

no further analysis is required.

As exempt solvents are not listed on the current MAERT, a health effects review of exempt solvents was

performed. Estimated project offsite impacts for acetone were below 10% of the ESL, and therefore

sitewide modeling was not required. Project impacts from 1‐chloro‐4‐(trifluoromethyl)benzene were

above 10% of the ESL, and as such sitewide modeling was required and had been included in the

submitted modeling.

This analysis and the submitted modeling demonstrate that the changes in source parameters will not

result in an increase in the off‐property concentrations and will not be detrimental to the public health

or the environment.

The electronic modeling files along with the EMEW used in this analysis are attached in a hard copy CD

that is included with this submittal.

Page 9 of 9

Texas Commission On Environmental Quality

Example A:

Example B:




Appendix D Modeling Files - CD




Appendix E Current NSR Permit Authorization

Project Number: 241665

Emission Sources - Maximum Allowable Emission Rates

Permit Number 43774 This table lists the maximum allowable emission rates and all sources of air contaminants on the applicant’s property covered by this permit. The emission rates shown are those derived from information submitted as part of the application for permit and are the maximum rates allowed for these facilities, sources, and related activities. Any proposed increase in emission rates may require an application for a modification of the facilities covered by this permit.

Air Contaminants Data

Emission Point No. (1)

Source Name (2) Air Contaminant Name

(3)

Emission Rates

lbs/hour TPY (4)

ST1 Degassing, De-Heeling and Cleaning at Dock 1 (DOCK1)

VOC 196.02 5.85

DD1, DD2, and DD3STK

Surface Coating and Abrasive Blasting at Dry Dock 1, Dry Dock 2, and Dry Dock 3 (DD1, DD2, and DD3)

VOC (7)(8) 161.50 33.20

PM (7) 35.75 24.97

PM10 (7) 17.15 8.32

FUGST1 Cleaning and Degassing Pipeline Fugitives (DOCK1)

VOC (5) 0.02 0.04

All Sources at Site (6)

HAP Individual HAP < 10.00

Total HAP < 25.00

(1) Emission point identification - either specific equipment designation or emission point number from plot plan.

(2) Specific point source name. For fugitive sources, use area name or fugitive source name. (3) VOC - volatile organic compounds as defined in Title 30 Texas Administrative Code § 101.1

PM - total particulate matter, suspended in the atmosphere, including PM10 and PM2.5, as represented

PM10 - total particulate matter equal to or less than 10 microns in diameter, including PM2.5, as represented

HAP - hazardous air pollutant as listed in § 112(b) of the Federal Clean Air Act or Title 40 Code of Federal Regulations Part 63, Subpart C

(4) Compliance with annual emission limits (tons per year) is based on a 12 month rolling period. (5) Emission rate is an estimate and is enforceable through compliance with the applicable special condition(s)

and permit application representations. (6) The HAP emission limit applies to all facilities at the site, regardless of authorization mechanism. (7) Fugitive emissions except for DD3 which exhausts emissions through Stack DD3STK. (8) The annual allowable VOC emission rate was reduced from 79.44 tpy to 33.2 tpy for EPNs DD1, DD2, DD3STK in

conjunction with the generation of VOC Emission Reduction Credits. Any subsequent increase in allowable emission rates must be evaluated in conjunction with a creditability review of the ERCs issued, or may be prohibited if the credits generated have been used.

Date: September 30, 2015

Special Conditions

Permit Number 43774

1. This permit authorizes the surface coating and abrasive blasting operations at Dry Dock Nos. 1, 2, and 3 (Emission Point Nos. [EPNs] DD1, DD2, and DD3STK) in addition to barge degassing, de-heeling, and cleaning at Dock 1 (EPNs ST1 and FUGST1). This facility is located at 18310 Market Street, Channelview, Harris County. (9/02)

Emission Limitations

2. Except for those periods described in 30 Texas Administrative Code (30 TAC) §§ 101.201 and 211, opacity of particulate matter emissions shall not exceed five percent:

A. For Emission Point DD3STK this determination shall be made first by observing for visible emissions. Observations shall be made at least 15 feet and no more than 0.25 mile from the emission point. If visible emissions are observed from the stack, then opacity shall be determined by Title 40 Code of Federal Regulations Part 60 (40 CFR Part 60), Appendix A, Test Method 9. Contributions from uncombined water shall not be included in determining compliance with this condition. Observations shall be performed and recorded quarterly. (4/06)

B. For Emission Points DD1 and DD2 this determination shall be made first by observing for visible emissions. Observations shall be made at least 15 feet and no more than 0.25 mile from the nearest property line to the emission points. If visible emissions are observed crossing the property line, then opacity shall be determined by Title 40 Code of Federal Regulations Part 60 (40 CFR Part 60), Appendix A, Test Method 22 Contributions from uncombined water shall not be included in determining compliance with this condition. Observations shall be performed and recorded quarterly. (4/06)

3. Title 40 Code of Federal Regulations Part 63, Subpart II (Shipbuilding and Ship Repair [Surface Coating]) applies to this facility.

4. Title 30 Texas Administrative Code § 115.421(a)(15) (Shipbuilding and Ship Repair Operations) applies to this facility.

5. Emissions from the facility shall comply with 30 TAC § 101.4 regarding nuisances. If compliance with 30 TAC § 101.4 so requires, this permit shall be amended to control nuisance-causing emissions either through process controls or emission controls. (4/06)

Operational Limitations

6. Surface Coating.

A. High volume, low-pressure spray guns, airless spray guns, or coating application equipment achieving a transfer efficiency of at least 80 percent shall be used for all surface coating operations.

Special Conditions Permit Number 43774 Page 2

B. Dry Dock 1 and Dry Dock 2 are limited to paints and solvents previously grand-fathered. Replacement compounds, paints, and solvents must meet the requirements of Special Condition No. 11.

C. Coating operations from Dry Dock 3 shall be conducted within an enclosure which encases the entire dry dock, as described in the permit application dated February 28, 2000. The enclosure shall maintain a negative pressure at all times with a minimal face velocity at all openings of 100 feet per minute during coating operations. (4/06)

7. Abrasive Blasting.

All abrasive cleaning operations shall occur in an enclosure which has been designed with four walls and a roof. The walls and roof shall either be solid or consist of fabric with a shade factor of 95 percent or greater as specified by the manufacturer of the fabric. Fabric walls shall be drawn together with minimal openings during all abrasive cleaning operations. Doors shall either remain closed or consist of overlapping plastic strips designed to facilitate passage in and out of the enclosure while also providing effective particulate emissions control. For Dry Dock 3, all captured emissions shall be exhausted through a dry filter system that achieves an overall particulate removal efficiency of 95.0 percent (EPN DD3STK).

8. Cleaning and Degassing.

A. Barge cleaning and degassing is limited to the chemicals found in the permit application dated May 11, 2001. Barge cleaning and degassing of new chemicals may be performed at Dock No. 1 provided the new chemicals meet the requirements of Special Condition No. 11.

B. All barges shall be de-heeled prior to degassing and/or water washing.

9. All emissions released from Dry Dock 3 (EPN DD3STK) shall be routed to shore and exhausted vertically through an elevated stack with a minimum height from ground level of 40 feet. The stack shall have no obstruction to vertical discharge.

10. The following air contaminants shall not be emitted from anywhere else on the site while they are emitted from operations at Dry Dock No. 3:

Epoxy resin Isobutanol

Iron oxide pigment Xylene

Crystalline silica Ethyl benzene

Alkylated phenol Butanol

Magnesium silicate Methyl n-amyl ketone

Benzyl alcohol


11. This permit allows the use of replacement materials and compounds which meet the following conditions:

A. Emissions from the replacement material shall be from the established emission points as identified on the maximum allowable emission rates table (MAERT) and shall not cause the annual rates specified on the MAERT to be exceeded;

B. The total constituents of the replacement and replaced material are known (i.e., weight percentages add to 100 percent);

C. Operations that emit constituents of the replacement material shall not be conducted at the same time anywhere on the site while operations that emit the constituents of the replacement material are being conducted at Dry Dock No. 3; and

D. The following formula is satisfied:

where: there is a direct substitution of one constituent for another

(ER2)/(ESL2) < (ER1)/(ESL1)

OR

where: the replacement and replaced materials have multiple constituents

where:

ER1 is the authorized ER of each of the constituents in the replaced material;

ER2 is the maximum hourly ER of each of the constituents in the replacement material;

ESL1 is the ESL for each of the constituents in the replaced material, and;

ESL2 is the ESL for each of the constituents in the replacement material. The ESL shall be taken from the permit application or the current Texas Commission on Environmental quality (TCEQ) ESL list. If a constituent is not on the current TCEQ ESL list, the ESL shall be obtained in writing from the TCEQ Toxicology Section;

E. Calculations and other data supporting Special Condition No. 11A, B, C, and D shall be retained in the permit file directly after such change is implemented. (4/06)

Pollution Prevention

12. Spent solvent shall be discharged into closed containers and shall be removed from the site by a licensed disposal service unless reused or recycled.

13. All waste paint, solvents, and cleanup rags shall be stored in sealed containers until removed from the site by a licensed disposal service unless reused or recycled.

(ER2a) + (ER2b) + (ER2n…) ≤ (ER1a) + (ER1b) + (ER1n…) (ESL2a) (ESL2b) (ESL2n…) (ESL1a) (ESL1b) (ESL1n…)


14. The filters shall be removed and disposed of in such a manner that minimizes trapped particulates from escaping into the atmosphere.

15. All spills shall be cleaned up promptly using appropriate procedures, and the associated waste materials shall be stored in sealed containers until removed from the site by a licensed disposal service.

Recordkeeping

16. General Condition No. 7 regarding information and data to be maintained on file is supplemented as follows and shall be used to demonstrate compliance with Special Condition Nos. 2, 4, and 11 and the maximum allowable emission rates table:

A. Environmental Data Sheet (EDS)or similar documentation (including Material Safety Data Sheets) for all paints. The EDS or similar documentation for materials shall indicate the maximum composition of all constituents;

B. Data to be collected:

(1) Daily total gallons of paint and solvent used;

(2) Daily total tons of blast media used;

(3) Daily hours and times of day of operation of each source; and

(4) As applied coating volatile organic compound (VOC) content.

C. This data shall be used to produce a monthly report that reflects:

(1) Emissions from each EPN in lbs/hr as a daily average.

(2) Emissions from each EPN in tons per year over the rolling 12 previous months.

(3) Each coating used at the facility shall be classified according to the categories listed in 30 TAC § 115.421(a)(15) and the coating VOC content as applied for all coatings in each category shall be determined as the daily weighted average. Averaging is not necessary if all coatings applied in a category if the VOC content is below the applicable limit.

D. A monthly record of individual and total hazardous air pollutant emissions in TPY for the rolling 12 previous months.

E. Records of opacity observations.

F. Records of all material substitutions authorized under Special Condition No.11.

All records required by this special condition shall be maintained in either hard copy or electronic format. The reports in paragraphs C shall contain examples of the calculations performed (including units and conversion factors), any assumptions made in the calculations, and the basis for those assumptions. (6/15)

Date: June 5, 2015




Appendix F TCEQ Guidance and Equipment Specifications

Draft Page 4 of 10

Emission ( lb /hr ,yr ) Usage ( lb /hr ,yr )•EmissionFactor•(1 RemovalEfficiency (%)100

)

Enclosed OperationsIf you will be operating an enclosed blast cleaning operation, you will most likely

be able to be exempt from permitting under Dry Abrasive Cleaning (30 TAC

§ 106.452).

The following equation can be used to calculate hourly and annual PM and PM10

emission rates:

where

Usage is the blast media usage,

Emission Factor is selected from the following:

Particle Size Silica Sand Coal Slag

PM 0.00590 lb PM/lb usage 0.00286 lb PM/lb usage

PM10 0.00140 lb PM10/lb usage 0.00034 lb PM10/lb usage

NOTE: For other types of blast media, please consult the manufacturer for

this data.

Removal Efficiency is the manufacturer’s average weight arrestance efficiency

for fabric filters. For baghouses or cartridge filters, a 95% average weight

arrestance efficiency may be used if the outlet grain loading is less than or

equal to 0.01 grains per dry standard cubic foot.

4 April 2011 Paint PM Emission Calculations The PM emission calculations for spray coating operations must consider transfer efficiency, particulate fallout and filter performance. Each of these is discussed individually as follows: Transfer Efficiency One of the variables that must be accurately determined in order to estimate PM emissions from the spray application of coatings is transfer efficiency. The geometry of the part and the application equipment determine the transfer efficiency (TE), which is a measure of the amount of sprayed coating that is applied to the part. TE may be determined through several methods such as estimation from tables or charts, the volume of coating applied to a part, or through the weighing of parts and the paint pots. Given the size of the parts to be coated it is acceptable to estimate transfer efficiency from the following table.

Transfer Efficiency as a Function of Application Equipment and Part Geometry

Application Equipment Flat Surface Table Leg Bird Cage

Air Atomized 50 15 10

Airless 75-80 10 10

HVLP 65 15 10

Electrostatic Disk 95 90-95 90-95

Electrostatic Airless 80 70 70

Electrostatic Air Atomized 75 65 65

Fallout Droplets larger than 30 microns in diameter tend to fall out quickly while smaller particles tend to stay suspended for a long period. Therefore, the fraction of the paint overspray that will be emitted is the fraction of the droplet sizes that are smaller than 30 microns in diameter. Determination of the fraction of the droplets smaller than PM10 and PM 2.5 is also necessary to determine the emission rates in these size ranges. The particle size distribution will depend on the type of application equipment used since each type of equipment has differing droplet size distributions. The following table should be used to estimate PM, PM10, and PM2.5 emission rates for both enclosed and outdoor coating operations. Application Equipment

Type Droplet Fraction Greater

than PM30 Droplet Fraction Greater

than PM10 Droplet Fraction Greater

than PM2.5

Air Atomized 0.81 0.94 0.99

Airless 0.9856 0.9987 0.9999

HVLP 0.90 Not Available Not Available

Please note that these are interim factors and the TCEQ Air permits Division is currently revising these factors. Filter Performance The filters must have an efficiency of at least 99% as determined by ASHRAE Method 52.1 to meet current BACT requirements. In order to be able to estimate PM10 and PM 2.5 emission rates vendor data using ASHRAE Method 52.2 should also be provided. The vendor need only provide the minimum efficiency removal value (MERV) number for the media to be used. Efficiencies for the various particle sizes may be determined using the following table.

Composite Average Particle Size Removal Efficiency (%) in Size Range (μm) - ANSI/ASHRAE Standard 52.2-2007

Contaminants Typically Controlled Typical Applications MERV 0.3–1.0 1.0–3.0 3.0–10.0

1 — — <20 Particles >10.0 μm: pollens, dust mites, textile/carpet fibers

Minimum filtration; residential buildings

2 — — <20

3 — — <20

4 — — <20

5 — — 20–35 Particles 3 - 10.0 μm: mold, spores, cement dust

Most commercial and better residential buildings

6* — — 35–50

7 — — 50–70

8 — — >70

9 — <50 >85 Particles 1.0 - 3.0 μm: Legionella, lead dust, coal dust, auto emissions

Superior residential and better commercial buildings 10 — 50–65 >85

11 — 65–80 >85

12 — >80 >90

13 <75 >90 >90 Particles 0.3 - 1.0 μm: all bacteria, most tobacco smoke, droplet nuclei,

Hospital inpatient and general surgery; superior commercial buildings 14 75–85 >90 >90

15 85–95 >90 >90 most smoke

16 >95 >95 >95

IEST Standards

17 >99.97 on 0.30 μm particles, IEST Type A Particles <0.3 μm (viruses, radon progeny, carbon dust)

Cleanrooms and pharmaceutical manufacturing 18 >99.99 on 0.30 μm particles, IEST Type C

19 >99.999 on 0.30 μm particles, IEST Type D

20 >99.9999 on 0.10–0.20 μm particles, IEST Type F

* Mimimum requirement under ASHRAE standard 62.1 (Ventilation for Acceptable Indoor Air Quality)

Source: Adapted with permission from ANSI/ASHRAE Standard 52.2-2007: Method of Testing General Ventilation Air-Cleaning Devices for Removal Efficiency by Particle Size. Atlanta, GA: American Society of Heating, Refrigerating, and Air-Conditioning Engineeers, Inc. 2007 © American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc., www.ashrae.org

-For the application of architectural paints and coatings- / - Pour l’application de peintures et revêtements architecturaux - / –Para la aplicación de pinturas y revestimientos con fines arquitectónicos – / - Para aplicação de pinturas e demãos

arquitectónicas - / - Per l’applicazione di vernici e di rivestimenti architettonici -

Models: pg. 3 / Modèles: p. 5 / Modelos: pg. 7 / Modelos: pág. 9 / Modelli: pag. 11

Warning / Mise en garde / Advertencia / Advertência / Pericolo . . . . . . . . .2Component Identification /

Identification des composants /Identificación de los componentes /Identificação dos componentes /Identificazione dei componenti . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12

Grounding /Mise à la terre /Conexión a tierra /Ligação à terra /Messa a terra . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13

Pressure Relief Procedure /Procédure de décompression /Procedimiento de descompresión /Procedimento de descompressão /Procedura di decompressione . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15

Setup / Réglage / Ajuste / Preparação / Configurazione . . . . . . . . . . . . . .17Spray Instructions /

Instructions de pulvérisation /Instrucciones de pulverización /Instruções de pintura /Istruzioni di spruzzatura . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20

Clear Clog /Déboucher /Elimine la obstrucción /Desobstrução /Pulizia delle ostruzioni . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23

Repair / Réparation / Reparación / Reparação / Riparazione . . . . . . . . . .25Parts / Pièces / Piezas / Peças / Parti . . . . . . . . . . . . . . . . . . . . . . . . . . . . .30Technical Data /

Caractéristiques techniques /Características técnicas /Ficha técnica /Dati tecnici . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32

Graco Standard Warranty /Garantie Graco standard /Garantía estándar de Graco /Garantia Standard da Graco /Garanzia standard Graco . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .34

Important Safety InstructionsRead all warnings and instructions in this manual. Save these instructions.Instructions de sécurité importantesLire toutes les mises en garde et instructions de ce manuel. Sauvegarder ces instructions.Instrucciones importantes de seguridadLea todas las advertencias e instrucciones de este manual. Guarde las instrucciones.Instruções de segurança importantesLeia todas as advertências e instruções deste manual. Guarde estas instruções.Importanti istruzioni sulla sicurezzaLeggere tutte le avvertenze e le istruzioni contenute in questo manuale. Conservarle.

311254K

Instructions / Instructions / Instrucciones / Instruções / Istruzioni

Silver and Flex Plus Airless Spray GunsPistolets airless Plus Silver et FlexPistolas de pulverización sin aire Silver y Flex PlusPistolas de pintura a alta pressão Silver e Flex PlusPistole a spruzzo airless Silver e Flex Plus

EN FR ES PT IT

ti28979a

Warning

2 311254K

WarningThe following are general warnings related to the setup, use, grounding, maintenance and repair of this equipment.Additional, more specific, warnings may be found throughout the text of this manual, where applicable. Symbolsappearing in the body of the manual refer to these general warnings. When these symbols appear throughout themanual, refer back to these pages for a description of the specific hazard.

WARNINGFIRE AND EXPLOSION HAZARDFlammable fumes, such as solvent and paint fumes, in work area can ignite or explode. To help preventfire and explosion:• Use equipment only in well ventilated area.• Eliminate all ignition sources; such as pilot lights, cigarettes, portable electric lamps, and plastic drop

cloths (potential static arc).• Keep work area free of debris, including solvent, rags and gasoline.• Do not plug or unplug power cords, or turn power or light switches on or off when flammable fumes

are present.• Ground equipment and conductive objects in work area. See Grounding instructions.• Use only grounded hoses.• Hold gun firmly to side of grounded pail when triggering into pail.• If there is static sparking or you feel a shock, stop operation immediately. Do not use equipment

until you identify and correct the problem.• Keep a fire extinguisher in the work area.

SKIN INJECTION HAZARDHigh-pressure fluid from gun, hose leaks, or ruptured components will pierce skin. This may look like justa cut, but it is a serious injury that can result in amputation. Get immediate surgical treatment.• Do not point gun at anyone or at any part of the body.• Do not put your hand over the spray tip.• Do not stop or deflect leaks with your hand, body, glove, or rag.• Do not spray without tip guard and trigger guard installed.• Engage trigger lock when not spraying.• Follow Pressure Relief Procedure in this manual, when you stop spraying and before cleaning,

checking, or servicing equipment.

EQUIPMENT MISUSE HAZARDMisuse can cause death or serious injury.• Do not exceed the maximum working pressure or temperature rating of the lowest rated system

component. See Technical Data in all equipment manuals.• Use fluids and solvents that are compatible with equipment wetted parts. See Technical Data in all

equipment manuals. Read fluid and solvent manufacturer’s warnings. For complete informationabout your material, request MSDS from distributor or retailer.

• Check equipment daily. Repair or replace worn or damaged parts immediately with genuine Gracoreplacement parts only.

• Do not alter or modify equipment.• Use equipment only for its intended purpose. Call your Graco distributor for information.• Route hoses and cables away from traffic areas, sharp edges, moving parts, and hot surfaces.• Do not kink or over bend hoses or use hoses to pull equipment.• Keep children and animals away from work area.• Do not operate the unit when fatigued or under the influence of drugs or alcohol.• Comply with all applicable safety regulations.

Warning

311254K 3

Models

PRESSURIZED ALUMINUM PARTS HAZARDDo not use 1,1,1-trichloroethane, methylene chloride, other halogenated hydrocarbon solvents or fluidscontaining such solvents in pressurized aluminum equipment. Such use can cause serious chemicalreaction and equipment rupture, and result in death, serious injury, and property damage.

PERSONAL PROTECTIVE EQUIPMENTYou must wear appropriate protective equipment when operating, servicing, or when in the operatingarea of the equipment to help protect you from serious injury, including eye injury, inhalation of toxicfumes, burns, and hearing loss. This equipment includes but is not limited to:• Protective eyewear• Clothing and respirator as recommended by the fluid and solvent manufacturer• Gloves• Hearing protection

Type, ModelNo., Series

MWP Trigger Tip Guard Tip

Silver234237, A

5000 psi(345 bar, 34.5 MPa)

4-finger trigger HandTite Tip Guard 517 RAC V SwitchTip

Silver,235460, C

5000 psi(345 bar, 34.5 MPa)

2-finger triggerStandard (nonreversing)

Dripless Tip GuardNo Spray Tip.

Order Separately

Silver,235461, B

5000 psi(345 bar, 34.5 MPa)



Order Separately

Silver,235462, C

5000 psi(345 bar, 34.5 MPa)


Dripless Tip GuardNo Spray Tip. Order Separately

For Fine Finish

Silver,235464, C

5000 psi(345 bar, 34.5 MPa)

2-finger trigger Heavy Duty RAC Tip Guard XHD617 SwitchTip

Silver,238591, A

5000 psi(345 bar, 34.5 MPa)


Silver,243283, A

5000 psi(345 bar, 34.5 MPa)

2-finger trigger HandTite Tip Guard 517 RAC V SwitchTip

Silver,246240, A

5000 psi(345 bar, 34.5 MPa)

2-finger trigger HandTite Tip Guard 517 RAC X SwitchTip

Silver,249941, A

5000 psi(345 bar, 34.5 MPa)

2-finger trigger HandTite Tip Guard 210 RAC X Fine Finish Tip

Flex Basic,235457, C

5000 psi(345 bar, 34.5 MPa)

2-finger triggerNo Tip Guard.

Order Separately.No Spray Tip.

Order Separately.

Flex,235458, C

5000 psi(345 bar, 34.5 MPa)



Order Separately

Flex,246468, A

5000 psi(345 bar, 34.5 MPa)

2-finger trigger HandTite Tip Guard 517 RAC X SwitchTip

Sliver,257093, A

5000 psi(345 bar, 34.5 MPa)


WARNING

Component Identification / Identification des composants / Identificación de los componentes / Identificação dos componentes /Identificazione dei componenti

12 311254K

Component Identification / Identification des compo-sants / Identificación de los componentes / Identifica-ção dos componentes / Identificazione dei componenti

ti6929b

A

B

C

D

E

F

ti28994a

English Français Español Português Italiano

A Tip Guard Protecteur de buse Portaboquillas Protector do bico Protezione dell’ugello

B Trigger lock Loquet de sécurité Seguro del gatillo Fecho do gatilho Sicura del grilletto

C Trigger Gâchette Gatillo Gatilho Grilletto

D Tip Buse Boquilla Bico Ugello

E Fluid inlet Entrée produit Entrada de fluido Entrada de líquido Ingresso fluido

F Trigger guard / FluidTube

Sous-garde /Tube produit

Protección del gatillo /tubo para líquido

Dispositivo de segurançado gatilho/Tubo do

líquido

Protezione del grilletto/Flessibile del fluido

ULTRA-WEB® CARTRIDGEENGINEERED FOR DUST COLLECTION

• Premium performance on extremely fine, dry, and nonfibrous dust

• Durable for more abrasive dust

• Outer liner available for most applications

• Outer liner removed for agglomerative dust applications

• Fine fiber technology ensures longer filter life at a significantly lower pressure drop

• Substrate media features increased rigidity, higher durability, and superior cleanability

• MERV* 15 filtration efficiency rating per ASHRAE 52.2-2007

• Superior particle release due to surface filtration

• Lower pressure drop saves energy

• Longer filter life reduces replacement and maintenance costs

• Lightweight and easy to install

• Flame retardant media available

• Stainless steel construction available

THE ULTRA-WEB ADVANTAGE IS CLEANER AIRUltra-Web® is proprietary and made with an electrospinning process that produces a very fine, continuous, resilient fiber of 0.2-0.3 micron in diameter to form a permanent web-like net. This fine fiber “web” with its very fine interfiber spaces is constructed onto tough cellulose substrate media, resulting in:

• A more robust media that captures even submicron dust on the surface

• Better pulse cleaning and lower pressure drop

• Cleaner air, longer filter life, and greater cost savings

APPLICATIONS

Ultra-Web Cartridge

ULTRA-WEB ® CARTRIDGE - ENGINEERED FOR DUST COLLECTION

* Refer to Minimum Efficiency Reporting Value on page 2.† Scanning Electron Microscope

SPECIFICATIONSMEDIA COMPOSITION

Fine Fiber Technology

Durable proprietary synthetic filter media fibers and polymerMean fiber diameter of 0.2 µm

SubstrateProprietary blend of cellulose fibersFlame retardant version per UL® Standard 558, TAPPI Standard T 461om-94, and DIN 53438 Part 3

CARTRIDGE CONSTRUCTION

Standard Construction

Galvanized metal end capsGalvanized expanded metal liner72% open areaUrethane gasket

OptionsStainless steel liner and end capsNo outer liner versionEPDM gasket

MEDIA EFFICIENCY

U.S. Efficiency Rating MERV* 15 per ASHRAE 52.2-2007

MEDIA COMPATIBILITY DATA

Temperature Resistance 180°F / 82°C

Moisture Absorption* Maximum 14% @ 70°F (21°C) and 65% RH

Chemical Tolerance* AcidsàPoor OxidantsàPoorBasesàFair SolventsàFair

Abrasion Resistance Good per TAPPI 476 (Taber Method)

* Refer to Minimum Efficiency Reporting Value on page 4.

Ultra-Web (600x)Fine Fiber Media

10 micron

SEM IMAGES2

1 micron = 1/25,400 of an inch (1/1000 of a millimeter)

Cellulose Media (600x)

10 micron


CONFIGURATIONS

CollectorModels

Filter Area Pleat Height Dimensions Ultra-Web

ft2 m2 in mm in mm Standard FR NL SS Beaded

AerBooth 170226

15.821.0

1.52.0

38.150.8

11.74 x 2612.74 x 26

298.2 x 660.4323.6 x 660.4

••

•• • • •

Ambient Air Tubesheets

Cylindrical 226 21.0 2.0 50.8 12.74 x 26 323.6 x 660.4 • •

Coned 260 24 2.0 50.8 12.74 x 15.9 x 26 322.6 x 403.9 x 660.4 • • •

Bin Vent (TBV) 170226

15.821.0

1.52.0

38.150.8

11.74 x 2612.74 x 26

298.2 x 660.4323.6 x 660.4

••

•• • • •

CF Series 226 21.0 2.0 50.8 12.74 x 26 323.6 x 660.4 •

CX Series 191254

17.723.6

1.52.0

38.150.8

12.84 x 2613.84 x 26

326.1 x 660.4351.5 x 660.4

••

••

••

••

Downdraft Bench (DB) 191254

17.723.6

1.52.0

38.150.8

12.84 x 2613.84 x 26

326.1 x 660.4351.5 x 660.4

••

••

••

••

Torit Downdraft Bench (TDDB) 226 21.0 2.0 50.8 12.74 x 26 323.6 x 660.4 •

Downflo® (DF) 170226

15.821.0

1.52.0

38.150.8

11.74 x 2612.74 x 26

298.2 x 660.4323.6 x 660.4

••

•• • • •

Downflo II (DFT) 191254

17.723.6

1.52.0

38.150.8

12.84 x 2613.84 x 26

326.1 x 660.4351.5 x 660.4

••

•• • • •

Downflo Containment System (DCS) 190 17.7 1.5 38.1 11.4 x 14.4 x 26 289.6 x 365.8 x 660.4 • • • •

Downflo Oval (DFO) 190 17.7 1.5 38.1 11.4 x 14.4 x 26 289.6 x 365.8 x 660.4 • • • •

Downflo Evolution (DFE) 254 23.6 2 50.8 13.74 x 13.74 x 26 348.9 x 348.9 x 660.4

Downflo (SDF) 103 9.6 1.5 38.1 9.2 x 22.3 233.7 x 566.4 • •

Downflo WorkStation (DWS) 190 17.7 1.5 38.1 11.4 x 14.4 x 26 289.6 x 365.8 x 660.4 • • • •

Easy-Trunk™ 103 9.6 1.5 38.1 9.2 x 22.3 233.7 x 566.4 •

Environmental Control Booth™ (ECB) 170 226

15.8 21.0

1.5 2.0

38.1 50.8

11.74 x 26 12.74 x 26

298.2 x 660.4 323.6 x 660.4

••

•• • • •

Mini-Trunk™ 72 6.7 1.5 38.1 9.2 x 16 233.7 x 406.4 •

MTD 170 226

15.8 21.0

1.5 2.0

38.1 50.8

11.74 x 26 12.74 x 26

298.2 x 660.4 323.6 x 660.4

••

•• • • •

Porta-Trunk™ 220 20.4 2.0 50.8 17.6 x 18 447.0 x 457.2 •

ProBooth™ 170 226

15.8 21.0

1.5 2.0

38.1 50.8

11.74 x 26 12.74 x 26

298.2 x 660.4 323.6 x 660.4

••

•• • • •

TD Large 170 226

15.8 21.0

1.5 2.0

38.1 50.8

11.74 x 26 12.74 x 26

298.2 x 660.4 323.6 x 660.4

••

•• • • •

TD Small 45 60

4.2 5.5

1.5 2.0

38.1 50.8

7.9 x 16 7.9 x 16

200.7 x 406.4 200.7 x 406.4

••

•• • •

Trunk 2000 (T-2000) 212 19.7 2.0 50.8 13.84 x 22 351.5 x 558.8 •

WeldAir 103 220

9.6 20.4

2.0 2.0

50.8 50.8

9.2 x 22.3 17.6 x 18

233.7 x 566.4 447.0 x 457.2

••

Weld Bench 254 23.6 2.0 50.8 13.84 x 26 351.5 x 660.4 •

Important NoticeMany factors beyond the control of Donaldson can affect the use and performance of Donaldson products in a particular application, including the conditions under which the product is used. Since these factors are uniquely within the user’s knowledge and control, it is essential the user evaluate the products to determine whether the product is fit for the particular purpose and suitable for the user’s application. All products, product specifications, availability and data are subject to change without notice, and may vary by region or country.


F118123 ENG (06/18) Ultra-Web Cartridge ©2011-2018 Donaldson Company, Inc. Donaldson, Torit, Downflo, Ultra-Web, Easy-Trunk, Environmental Control Booth, Mini-Trunk, Porta-Trunk, ProBooth and the color blue are marks of Donaldson Company, Inc. All other marks belong to their respective owners.

Donaldson Company, Inc. Minneapolis, MN

donaldsontorit.com • shop.donaldson.com

North AmericaEmail: [email protected] Phone: (USA): 800-365-1331 • (MX): 800-343-3639

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South AfricaEmail: [email protected] Phone: +27 11 997 6000

Southeast Asia IAFEmail: [email protected] Phone: (65) 63117373

Significantly improve the performance of your collector with genuine Donaldson Torit replacement filters and parts. Call Donaldson Torit at 800-365-1331.

MINIMUM EFFICIENCY REPORTING (MERV)The Minimum Efficiency Reporting Value (MERV) of this filter cartridge has been determined through independent laboratory testing using ASHRAE 52.2 (2007) test standards. The MERV rating was determined at a face velocity of 118 feet per minute (36.0 meters per minute) and loading up to four inches (101.6 millimeters) water gauge. Actual efficiency of any filter cartridge will vary according to the specific application parameters. Dust concentration, airflow, particle characteristics, and pulse cleaning methods all affect filtration efficiency.

MOISTURE ABSORPTIONEnvironmental conditions involving combinations of high temperature, corrosive material, and moisture can reduce media strength. Reduction in media strength may compromise cartridge integrity and performance.

CHEMICAL TOLERANCEA combination of chemicals may alter fiber resistance to the specified performance level. Chemical attack may compromise cartridge integrity and performance.


P:\SOUTHWEST SHIPYARD\340745.0000_2019 CHANNELVIEW PERMITTING\43774 DRY DOCK PERMIT\FEE COVER LETTER.DOCX

July 15, 2020 Texas Commission on Environmental Quality (TCEQ) Financial Administrative Division Revenue Operations Section, MC‐214 12100 Park 35 Circle, Bldg. A, Third Floor Austin, TX 78753

Subject: NSR Permit 43774 Renewal and Amendment Application Dry Docks Abrasive Blasting and Surface Coating Facility Southwest Shipyard, L.P. Channelview Facility Channelview, Harris County Regulated Entity Number: RN100248749 Customer Reference Number: CN600135354

To whom it may concern:

On behalf of Southwest Shipyard, L.P. (Southwest Shipyard), TRC Environmental Corporation (TRC) hereby

submits the enclosed permit fee check for the subject project. A copy of the “General” sheet of the Excel

workbook Form PI‐1 General Application (version 4.0) for your reference.

If there are any questions concerning this submittal, please contact me at 713‐244‐1039 or via email at

[email protected].

Sincerely,


Elizabeth Stanko

Senior Project Manager

Attachments

cc: Air Section Manager, TCEQ Region 12, 5425 Polk St., Ste. H, Houston, TX 77023‐1452 Harris County Public Health & Environmental Services, Attn: Air Section Manager

Mr. Bernard Diaz, Managing Director of Environmental Operations, Southwest Shipyard, L.P. (Electronic)


Form PI-1 General ApplicationGeneral



I agree

ZIP Code: 77042

First Name: Elizabeth

10550 Richmond Avenue Suite 210Address Line 2:

713-244-1039

D. Assigned Numbers

CN600135354Enter the CN. The CN is a unique number given to each business, governmental body, association, individual, or other entity that owns, operates, is responsible for, or is affiliated with a regulated entity.

Telephone Number:Fax Number:Email Address: [email protected]

The CN and RN below are assigned when a Core Data Form is initially submitted to the Central Registry. The RN is also assigned if the agency has conducted an investigation or if the agency has issued an enforcement action. If these numbers have not yet been assigned, leave these questions blank and include a Core Data Form with your application submittal. See Section VI.B. below for additional information.

713-789-5920

I. Applicant Information

Texas Secretary of State Charter/Registration Number (if given):

C. Technical Contact Information: This person must have the authority to make binding agreements and representations on behalf of the applicant and may be a consultant. Additional technical contact(s) can be provided in a cover letter.

A. Company Information

B. Company Official Contact Information: must not be a consultantPrefix (Mr., Ms., Dr., etc.): Mr.First Name: BernardLast Name: DiazTitle: Managing Director of Environmental Operations

Permits are issued to either the facility owner or operator, commonly referred to as the applicant or permit holder. List the legal name of the company, corporation, partnership, or person who is applying for the permit. We will verify the legal name with the Texas Secretary of State at (512) 463-5555 or at:

Company or Legal Name: Southwest Shipyard, L.P.

Mailing Address: 18310 Market Street

City:

ZIP Code:

Channelview

Last Name:

City: HoustonState: Texas

Company or Legal Name: TRC Environmental Corporation

281-860-3214Email Address: [email protected]

Address Line 2:

StankoTitle:

State:

713-378-8757Fax Number:

https://www.sos.state.tx.us

Project Manager

Mailing Address:

Prefix (Mr., Ms., Dr., etc.): Ms.

77530Telephone Number:

Texas

I acknowledge that I am submitting an authorized TCEQ application workbook and any necessary attachments. Except for inputting the requested data and adjusting row height and column width, I have not changed the TCEQ application workbook in any way, including but not limited to changing formulas, formatting, content, or protections.

Version 4.0 Page 1





No

Not applicable

43774

Select from the drop-down the type of action being requested for each permit type. If that permit type does not apply, you MUST select "Not applicable".

Provide all assigned permit numbers relevant for the project. Leave blank if the permit number has not yet been assigned.


Renewal/Amendment

Permit Type

A. Permit and Action Type (multiple may be selected, leave no blanks)

Special Permit: Not applicable, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Alteration, Extension to Start of Construction

III. Permit Information

De Minimis: Not applicable, Initial Not applicable

Not applicable

PSD: Not applicable, Initial, Major Modification


Minor NSR (can be a Title V major source): Not applicable, Initial, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Relocation/Alteration, Change of Location, Alteration, Extension to Start of Construction

Additional information regarding the different NSR authorizations can be found at:

RN100248749

Nonattainment: Not applicable, Initial, Major Modification

Flexible: Not applicable, Initial, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Alteration, Extension to Start of Construction

Not applicable

Action Type Requested(do not leave blank)

Does the applicant have unpaid delinquent fees and/or penalties owed to the TCEQ?This form will not be processed until all delinquent fees and/or penalties owed to the TCEQ or the Office of the Attorney General on behalf of the TCEQ are paid in accordance with the Delinquent Fee and Penalty Protocol. For more information regarding Delinquent Fees and Penalties, go to the TCEQ Web site at:https://www.tceq.texas.gov/agency/financial/fees/delin

II. Delinquent Fees and Penalties


Not applicable

Permit Number (if assigned)

Enter the RN. The RN is a unique agency assigned number given to each person, organization, place, or thing that is of environmental interest to us and where regulated activities will occur. The RN replaces existing air account numbers. The RN for portable units is assigned to the unit itself, and that same RN should be used when applying for authorization at a different location.

HAP Major Source [FCAA § 112(g)]: Not applicable, Initial, Major ModificationPAL: Not applicable, Initial, Amendment, Renewal, Renewal/Amendment, AlterationGHG PSD: Not applicable, Initial, Major Modification, Voluntary Update

Not applicable

Not applicable

Not applicable

Version 4.0 Page 2





No

No

Yes

No

D. Incorporation of Standard Permits, Standard Exemptions, and/or Permits By Rule (PBR)

E. Associated Federal Operating Permits

No

Will NSR permits be consolidated into this permit with this action?

Yes

N/A

Will this permit be consolidated into another NSR permit with this action?

To ensure protectiveness, previously issued authorizations (standard permits, standard exemptions, or PBRs) including those for MSS, are incorporated into a permit either by consolidation or by reference. At the time of renewal and/or amendment, consolidation (in some cases) may be voluntary and referencing is mandatory. More guidance regarding incorporation can be found in 30 TAC § 116.116(d)(2), 30 TAC § 116.615(3) and in this memo:

https://www.tceq.texas.gov/assets/public/permitting/air/memos/pbr_spc06.pdf

C. Consolidating NSR Permits

How are/will MSS activities for sources associated with this project be authorized? Permit by Rule

List the permit number, registration number, and/or PBR number.

Are there any standard permits, standard exemptions, or PBRs to be incorporated by reference?If yes, list any PBR, standard exemptions, or standard permits that need to be referenced:

Is a SOP or GOP review pending for this source, area, or site?

Are there any PBR, standard exemptions, or standard permits associated to be incorporated by consolidation? Note: Emission calculations, a BACT analysis, and an impacts analysis must be attached to this application at the time of submittal for any authorization to be incorporated by consolidation.

PBR 155161

B. MSS Activities

Is this facility located at a site required to obtain a site operating permit (SOP) or general operating permit (GOP)?

Version 4.0 Page 3





No

Channelview

No

Channelview Dry Docks Facilities

D. Industry Type

18310 Market Street


77530

Street Address:

095:03:55

Site Location Description: If there is no street address, provide written driving directions to the site. Identify the location by distance and direction from well-known landmarks such as major highway intersections.

A. LocationIV. Facility Location and General Information

TCEQ Region Region 12

029:47:23

Use USGS maps, county maps prepared by the Texas Department of Transportation, or an online software application such as Google Earth to find the latitude and longitude.

C. Portable FacilityPermanent

Harris

Area Name: Must indicate the general type of operation, process, equipment or facility. Include numerical designations, if appropriate. Examples are Sulfuric Acid Plant and No. 5 Steam Boiler. Vague names such as Chemical Plant are not acceptable.

County attainment status as of Sept. 23, 2019

1260


Is this a project for a lead smelter, concrete crushing facility, and/or a hazardous waste management facility?

County: Enter the county where the facility is physically located.

Serious Ozone nonattainment

Permanent or portable facility?


If required to obtain a SOP or GOP, list all associated permit number(s). If no associated permit number has been assigned yet, enter "TBD":

Site Name:

Are there any schools located within 3,000 feet of the site boundary?

City: If the address is not located in a city, then enter the city or town closest to the facility, even if it is not in the same county as the facility.ZIP Code: Include the ZIP Code of the physical facility site, not the ZIP Code of the applicant's mailing address.

Longitude (in degrees, minutes, and nearest second (DDD:MM:SS)) for the street address or the destination point of the driving directions. Longitude is the angular distance of a location west of the prime meridian and will always be between 93 and 107 degrees west (W) in Texas.

Latitude (in degrees, minutes, and nearest second (DDD:MM:SS)) for the street address or the destination point of the driving directions. Latitude is the angular distance of a location north of the equator and will always be between 25 and 37 degrees north (N) in Texas.

Version 4.0 Page 4





No

Yes

No

No


C. Enforcement ProjectsProjected Start of Operation:

Briscoe Cain

3731Principal SIC code:

District: 6

B. Project Timing

A. DescriptionV. Project Information

128District:State Representative:


VI. Application Materials

A. Confidential Application MaterialsIs confidential information submitted with this application?


Principal Company Product/Business:

Authorization must be obtained for many projects before beginning construction. Construction is broadly interpreted as anything other than site clearance or site preparation. Enter the date as "Month Date, Year" (e.g. July 4, 1776).

Will sources in this project be authorized to operate 8760 hours per year?

Renewal and concurrent permit amendment to add exempt solvent (ES) and PM2.5 emissions to the permit MAERT, which have always been present at the facility but never before identified in the permit. Project requests to update the permit representations and emission calculations, which includes the addition of new sources of particulate matter (PM/PM10/PM2.5) and revised numbering of EPNs.

Is this application in response to, or related to, an agency investigation, notice of violation, or enforcement action?

August 1, 2020

Provide a brief description of the project that is requested. (Limited to 500 characters).

A list of SIC codes can be found at:

B. Is the Core Data Form (Form 10400) attached?

All representations regarding construction plans and operation procedures contained in the permit application shall be conditions upon which the permit is issued. (30 TAC § 116.116)

State Senator:

NAICS codes and conversions between NAICS and SIC Codes are available at:

Carol Alvarado

https://www.census.gov/eos/www/naics/

E. State Senator and Representative for this site

https://wrm.capitol.texas.gov/This information can be found at (note, the website is not compatible to Internet Explorer):


336611Principal NAICS code:

D. Operating Schedule

Projected Start of Construction: August 1, 2020

Version 4.0 Page 5





Yes

Yes

YesYes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

N/A

N/A

N/A

Yes

Yes

Is the area map a current map with a true north arrow, an accurate scale, the entire plant property, the location of the property relative to prominent geographical features including, but not limited to, highways, roads, streams, and significant landmarks such as buildings, residences, schools, parks, hospitals, day care centers, and churches?

Are emission rates and associated calculations for planned MSS facilities and related activities attached?

J. Is a discussion of state regulatory requirements attached, addressing 30 TAC Chapters 101, 111, 112, 113, 115, and 117?For all applicable chapters, does the discussion include how the facility will comply with the requirements of the chapter?

I. Is a list of MSS activities attached?

D. Is a plot plan attached?Does your plot plan clearly show a north arrow, an accurate scale, all property lines, all emission points, buildings, tanks, process vessels, other process equipment, and two bench mark locations?

Does your plot plan identify all emission points on the affected property, including all emission points authorized by other air authorizations, construction permits, PBRs, special permits, and standard permits?Did you include a table of emission points indicating the authorization type and authorization identifier, such as a permit number, registration number, or rule citation under which each emission point is currently authorized?E. Is a process flow diagram attached?Is the process flow diagram sufficiently descriptive so the permit reviewer can determine the raw materials to be used in the process; all major processing steps and major equipment items; individual emission points associated with each process step; the location and identification of all emission abatement devices; and the location and identification of all waste streams (including wastewater streams that may have associated air emissions)?F. Is a process description attached?Does the process description emphasize where the emissions are generated, why the emissions must be generated, what air pollution controls are used (including process design features that minimize emissions), and where the emissions enter the atmosphere?

G. Are detailed calculations attached? Calculations must be provided for each source with new or changing emission rates. For example, a new source, changing emission factors, decreasing emissions, consolidated sources, etc. You do not need to submit calculations for sources which are not changing emission rates with this project. Please note: the preferred format is an electronic workbook (such as Excel) with all formulas viewable for review. It can be emailed with the submittal of this application workbook.

Does the process description also explain how the facility or facilities will be operating when the maximum possible emissions are produced?

C. Is a current area map attached?

Does the map show a 3,000-foot radius from the property boundary?


H. Is a material balance (Table 2, Form 10155) attached?

Version 4.0 Page 6

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