Table I - Permitted chemicals

AIR PERMIT BRIEFING SHEET
AIR QUALITY DIVISION
LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY

MOBILE THERMAL TREATMENT SYSTEM
PURGIT EMISSION CONTROL SYSTEM
STATE OF LOUISIANA
 

I. BACKGROUND
     Purgit Emission Control System, a division of Hilliard Emission  Controls, Inc., is a small Texas based business providing services to the chemical, petrochemical, refining and marine and land transportation industries for VOC control and destruction during the cleaning of vessels. Purgit operates under Permit No. 7777-00267-0l issued June 10, 1996.

II. ORIGIN
     Purgit submitted an application and Emission Inventory Questionnaire dated November 26, 1996, requesting a permit modification for a mobile source. Additional information dated December 29 and January 8, 1997 was also received.

III. PROJECT DESCRIPTION
     Purgit proposes to add fugitive emissions of H2S and CO from phosphoric acid treatment of rusty buoyancy spaces (tanks) in marine vessels, replace the leased John Zinc flare, Emission Point FL-l, with an enclosed flare (thermal oxidizer) designated Purgit T/O model 1000, and add a mobile refrigerated vapor recovery unit using liquid nitrogen as a refrigerant.

     A mobile thermal treating system processes VOC/ammonia vapors displaced from stationary tanks, land transport vessels and containers, tank barges, and ships. The vapors are collected and either condensed using the refrigerated condenser or destroyed in a portable thermal oxidizer, flare, or a VR4 combustion engine system.

     The portable thermal oxidizer is a Model No. 1000 Blagrave and Duffy mobile enclosed vapor combustor and the flare is a Model No. TFS-150 Tornado Flare. The VR4 internal combustion engine system is equipped with an exhaust system containing a dual NOX reduction monolith and a dual HC/CO monolith. An Xchanger, Inc. Model TV-275 condenser uses liquid nitrogen as the refrigerant. The mobile treating system also includes equipment for acid treatment of marine vessels.

    This permit includes a federally enforceable condition limiting emissions from all sources to less than 5 tons per year of any one toxic air pollutant, less than 15 tons per year of any combination of toxic air pollutants, and less than 25 tons per year of VOC. Speciated VOC and toxic air pollutants (TAP's) emissions from the control devices shall be calculated and recorded each day and for each month. A typical list of products that may be combusted or condensed is found in Table I.

IV. TYPE OF REVIEW
     This project was reviewed for compliance with the Louisiana Air Quality Regulations. Prevention of Significant
     Deterioration (PSD), NSPS, and NESHAP do not apply. This facility is a minor source of toxic air pollutants.

V.   PUBLIC NOTICE
     Notice was published in the Advocate, Baton Rouge on April 12, 1996 to insure federal enforceability for Specific Condition Nos. 4 and 7.
 
 

Purgit shall use only one of the following treating devices at each job site. The Blagrave and Duffy thermal oxidizer is designed for handling l,000 acfm hydrocarbon vapors maximum heat release 21 MMBTU/hr). The Tornado Flare is designed to burn 150 cfm with an inlet concentration of 60% hydrocarbons (propane) and is equipped with a natural gas pilot. Vapors are enriched to assure combustion if required.
 
A refrigerated Xchanger, Inc. Model TV-275 condenser may be used to recover and return condensable product to the owner. The condenser is designed to process 1,000 cfm of vapor and will be operated at a temperature sufficient to remove 99% of the condensable vapors.

The VR4 engine system (dual Ford 460 C.I.D. engines) is to be used primarily as a soil remediation and tank degassing system. These internal combustion engines are capable of extracting hydrocarbon vapors from contaminated or storage tanks without the use of a compressor or pump and destroy such vapors as fuel in a controlled manner by use of an on-board computer system. The system is capable of removing 110 lbs/hr of hydrocarbons with a destruction efficiency of 99%·

Purgit will also treat rusty void spaces of marine vessels to inhibit rust by filling the space with water and phosphoric acid. When the acid is put into the tanks, it reacts with small amounts of oil based preservatives to emit slight amounts of carbon monoxide and hydrogen sulfide. The CO and H2S will exit the compartment through a vent to a forced air blower to be dispersed into the atmosphere.
 

Estimated emissions from the facility in tons per year are listed below:
 

Pollutant	Permitted	Proposed	Change
PM10	0.26	0.23	-0.03
SO2	0.02	0.04	+0.02
NOx	3.0	5.1	+2.1
CO	15	13.2	-1.8
VOC	25	<25	---
Ammonia	---	<5	+5
H2S	---	<0.5	+<0.5

 
 
 

Specific Conditions for Mobile Thermal Treatment System

2. Written permission must be obtained from the Air Quality Division prior to relocating the unit to a new operational site. The permittee shall provide the following information:

    a) A map showing location of new site including UTM coordinates, use of adjoining properties and a list of businesses and residences within a one thousand yard radius of the operations.
    b) A laboratory analysis or MSDS (if applicable) of the waste to be treated (as supplied by client) containing as a minimum the following:
        1. Organic contents w/speciation.
        2. Speciation of TAPs
        3. Sulfur content.
    c)   A description of equipment to be purged/cleaned, an estimate of the time required and estimated emissions at the new site, and what thermal treating equipment will be utilized.

3.   Permittee shall comply with all applicable regulations of local and/or other state agencies.

4.   Permittee shall limit the operation of the thermal treatment and condenser units (all) to no more that 3500 hours during any 12 consecutive month period. Records of operating hours and feed rates shall be kept on site and available for review by the Air Quality Division. Operation above the maximum hours listed in this specific condition for any twelve consecutive month period shall be a violation of this permit and must be reported to the Air Quality Division, Enforcement Section. A report of annual operating hours shall be submitted to the Air Quality Division by February 15 for the preceding year.

5.   Permittee shall notify the Regional Office 5 days prior to beginning operations at the site.

6.   Compliance testing shall be conducted at the discretion of the Air Quality Division.

7.   Permittee shall limit the emissions of any one TAP to less than 5 tons, total toxic emissions to less than 15 tons and VOC emissions to less than 25 tons in any 12 consecutive month period. Speciated toxic and VOC emissions shall be recorded each day and month, as well as the toxic emissions for the last twelve consecutive months. These records shall be maintained on site and available for inspection by the Air Quality Division. Emissions above the maximum listed in this specific condition for any twelve consecutive month period shall be a violation of this permit and must be reported to the Air Quality Division, Enforcement Section. A report showing the amount of Toxic Air Pollutants (TAPs) and VOCs emitted for the preceding calendar year shall be submitted to the Air Quality Division by February 15.

8.    The VR4 engine, Emission Point CE-l, shall be equipped with a dual NOX reduction monolith and a dual HC/CO monolith. The oxygen supply to the NOX monolith shall be controlled at 0.5% to 0.7% as measured by an OZ sensor in the exhaust manifold. Engine emissions shall be tested annually for NOX, CO, and OZ concentrations in the stack gas utilizing portable analyzers that are calibrated before each test using a known reference gas sample. Test results shall be maintained on site and available for inspection by the Air Quality Division.

9.    Permittee shall operate only one of the four control devices (Blagrave and Duffey thermal oxidizer, Tornado Flare, VR4 Engine and Xchanger refrigerated condenser), Emission Points FL-1, FL-2, CE-l, and VRU-1 respectively, at any one time.

10.   The Flare, Emission Points FL-2, shall comply with the applicable provisions of New Source Performance Standards, 40 CFR 60.18 of Subpart A-General Control Device requirements.

11. Thermal oxidizer, Emission Point No. FL-1, operating conditions shall be controlled as specified below:
 

Total Heat release	21 MM BTU/hr	Maximum
Combustion Temperature	1600 deg. F	Minimum
Residence Time at 1600 deg. F	0.50	Minimum
VOC DRE	99.9%	Minimum
HCL/Cl2	Negligible
Flue Gas
* Stack Oxygen Concentration (dry)	2%	Minimum
* CO Concentration (one hour rolling average corrected to 7% oxygen (dry) updated every minute)		Maximum
PM10  grains/dscf	0.04	Maximum

 
12.  Continuous emission monitors shall be installed, maintained, and calibrated to provide a continuous record of OZ and CO concentrations in the thermal oxidizer, Emission Point FL-l, stack gas.    Permittee may develop a CO/O2 operating curve (during compliance testing) in place of a continuous analyzer for CO control. These analyzers shall comply with the applicable provisions of performance specifications 2, 3, and 4, of 40 CFR 60, Appendix B.

13. The following operating parameters shall be continuously monitored and recorded:

         l. Thermal oxidizer combustion temperature
         2. Vent gas feed rate/temperature
         3. Heat release rate
         4. Combustion air flow rate

    Records of these operating variables shall be maintained on site and available for inspection by the Air Quality Division.

14.  A compliance test shall be conducted on the thermal oxidizer, Emission Point FL-l, during the initial operation to determine the VOC destruction efficiency, CO, O2, and PM10 concentration by methods acceptable to the Air Quality Division.

15.  The refrigerated condenser, Emission Point VRU-l, shall be operated at a outlet vapor temperature and flow sufficient to insure at least 99% recovery of condensable VOCs. Inlet and outlet vapor temperature, VOC concentration, and vapor pressure shall be monitored and recorded every 4 hours to ensure VOC removal efficiency and emissions. These records shall be maintained on site and available for inspection by the Air Quality Division.
 
 
 

General Conditions for Louisiana Air Emission Permit

II.    The permittee is subject to all applicable provisions of the Louisiana Air Quality Regulations. Violation of the terms and conditions of the permit constitutes a violation of these regulations.

III.   The attached data sheets establish the emission and operating limitations and are a part of the permit. The synopsis and data sheets are based on the application and Emission Inventory Questionnaire dated November 26,1996, and additional information dated December 29, 1996 and January 8,1997.

IV.    This permit shall become invalid, for the sources not constructed, if:
       A. Construction is not commenced, or binding agreements or contractual obligations to undertake a program of construction of the project are not entered into, within two (2) years (18 months for PSD permits) after issuance of this permit, or;
       B. If construction is discontinued for a period of two (2) years (18 months for PSD permits) or more.

The administrative authority may extend this time period upon a satisfactory showing that an extension is justified.

This provision does not apply to the time period between construction of the approved phases of a phased construction project. However, each phase must commence construction within two (2) years (18 months for PSD permits) of its projected and approved commencement date.

V.       The permittee shall submit semi-annual reports of progress outlining the status of construction, noting any design changes, modifications or alterations in the construction  schedule which have or may have an effect on the emission rates or ambient air quality levels. These reports shall continue to be submitted until such time as construction is certified as being complete. Furthermore, for any significant change in the design, prior approval shall be obtained from the Louisiana Air Quality Division.

VI.    The permittee shall notify the Department of Environmental Quality, Air Quality Division within ten (10) calendar days from the date that construction is certified as complete and the estimated date of start-up of operation.  The appropriate Regional Office shall also be so notified within the same time frame.

VII. Any emissions testing performed for purposes of demonstrating compliance with the limitations set forth in paragraph III shall be conducted in accordance with the methods described in the Division's test manual or any other methods approved by the U.S. EPA. Any deviation from or modification of the methods used for testing shall have prior approval from the Louisiana Air Quality Division.

VIII. The emission testing described in paragraph VII above, or established in the specific conditions of this permit, shall be conducted within sixty (60) days after achieving normal production rate, but in no event later than 180 days after initial start-up (or restart-up after modification). The Air Quality Division Surveillance Section shall be notified at least (30) days prior to testing and shall be given the opportunity to conduct a pretest meeting and observe the emission testing. The test results shall be submitted to the Air Quality Division within forty-five (45) days after the complete testing. As required by LAC 33:III.9l3, the permittee shall provide necessary sampling ports in stacks or ducts and such other safe and proper sampling and testing facilities for proper determination of the emission limits.

IX.   The permittee shall, within 180 days after start-up of each project or unit, report to the Louisiana Air Quality Division any significant difference in operating emission rates as compared to those limitations specified in paragraph III. This report shall also include, but not be limited to, malfunctions and upsets.

X.    The permittee shall retain records of all information resulting from monitoring activities and information indicating operating parameters as specified in the specific conditions of this permit for a minimum of at least five (5) years.

XI.   If for any reason the permittee does not comply with, or will not be able to comply with, the emission limitations specified in this permit, the permittee shall provide the Air  Quality Division with the following information in writing within five (5) days of such conditions:
    A.    Description of noncomplying emission(s);
    B.    Cause of noncompliance;
    C.    Anticipated time the noncompliance is expected to continue , or, if corrected, the duration of the period of noncompliance;
    D.    Steps taken by the permittee to reduce and eliminate the noncom lying emissions; and  p
    E.    Steps taken by the permittee to prevent recurrences of the noncomplying emissions.

XII. Permittee shall allow the authorized officers and employees  of the Department of Environmental Quality, at all reasonable times and upon presentation of identification,  to:

    A.   Enter upon the permittee's premises where regulated facilities are located, regulated activities are conducted or where records required under this permit are kept;
    B.   Have access to and copy any records that are required to be kept under the terms and conditions of this  permit, the Louisiana Air Quality Regulations, or the Act;
    C.   Inspect any facilities, equipment (including monitoring methods and an operation and maintenance inspection), or operations regulated under this permit; and
    D. Sample or monitor, for the purpose of assuring compliance with this permit or as otherwise authorized by the Act or regulations adopted thereunder, any substances or parameters at any location.

XIII. If   samples are taken under Section XII.D. above, the officer or employee obtaining such samples shall give the owner, operator or agent in charge a receipt describing the sample obtained. If requested prior to leaving the premises, a portion of each sample equal in volume or weight to the portion retained shall be given to the owner, operator or agent in charge.  If an analysis is made of such samples, a copy of the analysis shall be furnished promptly to the owner, operator or agency in charge.

 XIV. The permittee shall allow authorized officers and employees of the Department of Environmental Quality, upon presentation  of identification, to enter upon the permittee's premises to investigate potential or alleged violations of the Act or the rules and regulations adopted thereunder. In such investigations, the permittee shall be notified at the time entrance is requested of the nature of the suspected violation. Inspections under this subsection shall be limited to the aspects of alleged violations. However, this shall not in any way preclude prosecution of all violations found.

XV.    The permittee shall comply with the reporting requirements specified under LAC 33:III.9l8 as well as notification requirements specified under LAC 33:III.927.

XVI.   In the event of any change in ownership of the source described in this permit, the permittee and the succeeding owner shall notify the Louisiana Air Quality Division, within ninety (90) days after the event, to amend this permit.

XVII.   Typical emissions associated with routine operations that are under control upon release, that are predictable in nature, and that are quantifiable as described in this permit application, are considered authorized discharges. Any significant deviation from the emissions specified in the permit application for such discharges, by event, shall be reported to the department according to LAC 33:I.3901. Actual emissions resulting from such activities must be reported to the department on an annual basis. These emissions are not reflected in the permit totals as they are short term and/or intermittent in duration and have no significant impact on air quality. Examples of such events include but are not limited to cleaning equipment, startups, shutdowns, opening off-line equipment (dual units), and releases to control devices such as flares or incinerators. This permit condition does not authorize the maintenance of a nuisance or a danger to public health and safety.