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Public Notice: Clean Air Act Draft Prevention of Significant Deterioration Preconstruction Permit, Draft Title V Federal Operating Permit and Public Hearing for SPOT Deepwater Port

Publish Date: 11/20/2019


Update (December 12, 2019):  A request for a hearing on this matter has not been received by EPA by the published deadline, and therefore, as described in the public notice (below) for this project, a public hearing will not be held.

The United States Environmental Protection Agency (EPA) provides notice of and requests public comments on EPA's proposed permit actions relating to a Clean Air Act (CAA) Prevention of Significant Deterioration (PSD) preconstruction permit application and a title V federal operating permit application for the SPOT Deepwater Port (DWP). If finalized, the proposed permits would regulate air pollutant emissions associated with the project to construct and operate a new DWP export terminal for domestically produced crude oil and condensate located in the federal waters of the Gulf of Mexico. The DWP export terminal consists of a platform equipped with marine loading vapor emissions control equipment, diesel generators, firewater pump engines, pedestal crane engines, storage tanks, and fugitive emissions. From the platform, the crude oil is transferred to two subsea Pipeline End Manifolds (PLEM) that are connected to two Single Point Mooring (SPM) buoys. Each SPM buoy is equipped with two floating product loading hoses that connect to carrier vessels such as Very Large Crude Carriers (VLCCs) for international export. Each SPM buoy is also equipped with a vapor underbuoy hose and a floating vapor recovery hose that connects to the carrier vessels manifold to return the emissions associated with marine loading to the platform for vapor emission control. SPOT's marine loading operations are limited to an annual maximum of 730,000,000 barrels of product loaded on a 12-month rolling total basis and a maximum loading rate of 85,000 barrels per hour at the SPM buoys (i.e., individual rate if loading occurs only at a single SPM buoy, or combined rate for both SPM buoys if simultaneous loading occurs at each). In addition, the maximum frequency of loading carrier vessels shall not exceed 365 vessels on a 12-month rolling total basis.

The DWP export terminal is planned to be located in federal waters, approximately 31.3 to 35.4 statute miles (27.2 to 30.8 nautical miles) off the coast of Brazoria County, Texas in water depths of approximately 115 feet. The project is generally positioned at: Latitude 28° 27' 59.22" North and Longitude 95° 07' 24.49" West.

Proposed PSD Preconstruction Permit: Under the provisions of 40 CFR § 52.21, the SPOT DWP Terminal application provided the following facility wide emission estimates that exceed the PSD review thresholds for criteria pollutants: 1,729.89 tons per year (tpy) Volatile Organic Compounds (VOC), 290.95 tpy Carbon Monoxide (CO), 223.48 tpy Nitrogen Oxides (NOx), and 173,257 tpy Greenhouse Gases (GHG) expressed as Carbon Dioxide equivalents (CO2e). The PSD preconstruction permit application also estimated the following pollutant estimated emissions:  36.85 tpy Sulfur Dioxide (SO2), 8.11 tpy Particulate Matter (PM, PM10, and PM2.5), 1.19 tpy Hydrogen Sulfide (H2S), and 83.11 tpy Hazardous Air Pollutants (HAP). Therefore, the SPOT DWP Terminal is subject to PSD requirements, whereby the PSD permit will limit emissions of each of these identified pollutants.

Proposed Title V Federal Operating Permit: In accordance with 40 CFR part 71, SPOT is a major stationary source and is subject to federal operating permit requirements. SPOT's proposed project is a title V major stationary source with estimated emissions of 1,729.89 tpy VOC, 290.95 tpy CO, 223.48 tpy NOx, 83.11 tpy HAP, and 173,257 tpy GHG expressed as CO2e. The title V federal operating permit will authorize the operation of SPOT's offshore DWP export terminal as represented in the supporting administrative record.

Permit Documents: Starting on November 20, 2019, members of the public may review EPA's administrative record for the permit actions. EPA's administrative record currently includes the proposed permits, statement of basis, permit applications, and additional data and supporting documentation used in the development of the proposed permits. Comments received from the public, other government agencies, and the applicant during the public comment period will also become part of the administrative record if the permits are finalized. All documents may be viewed online or by visiting one of the repositories listed below.

Access to electronic copies of the documents:

EPA's website: website: Navigate your web browser to Once at the site, search and view the permit documents by entering the Docket ID No EPA-R06-OAR-2019-0576 into the search box. Follow the online instructions on how to submit comments, including a comment request for a public hearing.

Access to physical copies of the documents:

EPA Region 6 Office: 1201 Elm Street, Suite 500, Dallas, Texas 75270; phone (214) 665-7161. Monday – Friday, from 7:30 a.m. – 4:30 p.m., excluding Federal holidays. Please call in advance to arrange viewing times.

Freeport Branch Public Library: 410 North Brazosport Blvd., Freeport, Texas 77541; phone (979) 233-3622. Please call in advance to arrange viewing times.

Public Hearing: You have the right to request a public hearing on the proposed permit actions.  Any request for a public hearing must be received by EPA before December 9, 2019 and must state the nature of the issues proposed to be raised in the hearing for each permit action. Any request for a public hearing may be provided to EPA by posting a request on the website listed above for Docket ID No: EPA-R06-OAR-2019-0576, or by U.S. mail addressed to the EPA Contact listed above and postmarked by December 9, 2019. Attendance at a public hearing is not required in order to submit written comments.

If EPA determines that there is significant public interest in either permit action, a public hearing will be held on January 14, 2020, from 6:00 p.m. to 8:00 p.m. at the following location:

Public Hearing Location:

Freeport River Place [located inside Freeport Municipal Park]

733 Mystery Harbor Lane

Freeport, TX 77541

If a public hearing is held, the public comment period shall automatically be extended to the close of the public hearing date. EPA retains the right to cancel the scheduled public hearing if no request for a public hearing is received by December 9, 2019, or if EPA determines that there is not a significant interest. If EPA cancels the public hearing, notification of the cancellation will be posted by December 12, 2019 on the website listed above and also on EPA's website at Individuals may also call the EPA Contact at the number listed above to determine if the public hearing has been cancelled.

Final Determination: A final decision to issue a permit or to deny a permit shall be made after all comments have been considered. Notice of the final decision shall be sent to each person who has submitted written comments or requested notice of the final permit decision, provided the EPA has adequate contact information.

Applicant or Respondent

SPOT Terminal Services LLC
P.O. Box 4324
Houston, TX 77210-4324

Docket Number: 

Permit #: R6PSD-DWP-GM7 and R6T5-DWP-GM7