Permitting Flexibility for a Transloading Facility

摘要

Facilities that transload liquid and solid material from trucks, railcars, ships and barges may be required to obtain an air quality permit depending on the types of material to be transloaded and the amounts to be transloaded. These facilities can transload a wide variety of material including petroleum-based liquids such as crude oil, gasoline, or diesel fuels; other volatile organic compound-based material such as ethanol; acids such as hydrochloric acid or sulphuric acids; non-organic liquids such as ammonia nitrate, sodium hydroxide or caustic; and solids such as coal, and non-organic material such as soda ash. These operations often require emission control devices to keep the emission under thresholds that would require more stringent permitting (e.g., Title V permit thresholds). They may also be located in non-attainment areas and will need to limit emissions due to those requirements. The demand for transloading of material changes rapidly requiring a facility to be flexible with the types of material being transloaded. Emissions from these facilities include volatile organic compounds from the transloading of organic liquids, particulate matter from the transloading of solids and other criteria pollutants emitted from boilers that are needed to heat liquids. There are also roadway fugitive emissions as these facilities often have large volumes of trucks entering and leaving the facility. Control devices typically include baghouses for particulate controls, flares, carbon beds and acid gas scrubbers. This paper will discuss the types of transloading operations, emissions associated with those operations, emission calculations, controls employed and methods for permitting that will allow for flexible operation of the facility.