4 The record articles

Marine Loading Readily Available Permit (RAP)

Posted: September 14th, 2020

Authors: Tanner H. 

The Air Permits Division of the Texas Commission on Environmental Quality (TCEQ) released a new Readily Available Permit (RAP) for Marine Loading operations on June 4, 2020.  A RAP is a type of New Source Review (NSR) permit created by the TCEQ for specific types of operations.  RAPs help streamline permit applications for specific operations to create an efficient permitting process.  RAP applications are generally less expensive than case-by-case NSR applications and take less time to receive a permit; however, they often contain special conditions that might not otherwise apply to the facility.

About the Marine Loading RAP

The Marine Loading RAP can authorize emissions from storage tanks, loading, control devices, combustion units, fugitives, and Maintenance, Startup, and Shutdown (MSS) activities as an amendment to an existing permit or for an initial permit.  The following sources can be covered by the Marine Loading RAP:

  • Up to five storage tanks
  • Loading operations
    • Drum/tote
    • Rail
    • Non-inerted marine vessel
    • Inerted marine vessel
    • Truck
  • One elevated flare
  • One Vapor Combustion Unit (VCU)
  • One vapor oxidizer
  • One Carbon Adsorption System (CAS)
  • Up to two emergency diesel engines
  • Up to two heaters/boilers
  • Fugitive emissions
  • MSS activities
  • Temporary emissions control units:
    • One temporary flare
    • One temporary VCU
    • One temporary Thermal Oxidizer (TO)

To apply for the Marine Loading RAP, the following documents must be included in the application:

  • Core Data Form (if needed)
  • TCEQ’s “RAP: Marine Loading Workbook”
  • Required documentation listed in section III of the instructions tab in the RAP: Marine Loading workbook including but not limited to:
    • Core Data Form (if needed)
    • Process Flow Diagram (PFD)
    • Plot Plan and Area Map
    • RAP: Marine Loading Application Workbook

The restrictions for the Marine Loading RAP include, but are not limited to:

  • The application only includes emissions sources located in TCEQ Regions 10, 12 ,14, or 15
  • The application must include project modified or affected sources
  • No increases to actual or potential emissions rates for sources authorized outside the RAP are authorized
  • The project’s emissions must not exceed Prevention of Significant Deterioration (PSD) or Nonattainment major source thresholds
  • The application cannot include crude carriers with greater than or equal to 2.0 million bbl carrying capacity

For a complete list please visit section II of the instruction tab in the RAP: Marine Loading workbook.

Should I Apply for a Marine Loading RAP?

Depending on specific situations, it can be advantageous to apply for the Marine Loading RAP instead of going through the “normal” NSR case-by-case permitting process.  The Marine Loading RAP is a great tool that can be utilized to streamline the permitting process for marine loading facilities.  However, there are a few questions to consider as part of your decision.

  • Is there a Permit By Rule (PBR) that can cover the emissions?
    • If units/emissions can be covered under a PBR, it is recommended to go down that route to further decrease cost and permitting time.
  • Are there any special conditions that would otherwise not apply to the facility that I am unwilling to accept?
    • The special conditions are located in the tab titled “CND” in the RAP: Marine Loading workbook. For this specific RAP, the special conditions do not seem to ring any alarms, but you should read through these to confirm your specific facility can comply with no issues.

For more information or if you have any questions regarding this blog, please reach out to Tanner Henson in ALL4’s Houston Office at thenson@all4inc.com or 281-937-7553 x308.

    4 THE RECORD EMAIL SUBSCRIPTIONS

    Sign up to receive all of the 4 THE RECORD articles here. You'll get timely updates of current hot issues, plus an in-depth article each month that highlights a regulatory topic.
    First Name: *
    Last Name: *
    Location: *
    Email: *

    +