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REPLY TO:
LIMETREE BAY TERMINALS, LLC
1 Estate Hope
Christiansted VI 00820-5652
REPLY TO:
LIMETREE BAY TERMINALS, LLC
1 Estate Hope
Christiansted VI 00820-5652

                        
                        
                              November 20, 2017

HAND DELIVERED
Mr. Norman Williams, Director
Division of Environmental Protection
Department of Planning & Natural Resources
45 Mars Hill
Frederiksted, St. Croix, V.I.  00840-4474

Subject:Authority to Construct and Permit to Operate
 For Marine Loading Project - Revision


Dear Mr. Williams:

Limetree Bay Terminals, LLC (Limetree Bay Terminals) is submitting a revision to a permit application originally submitted on October 20, 2016 (the "Initial Application") and is requesting a revision, in accordance with 12 VIRR §206-26(e) to the Authority to Construct and Permit to Operate issued by the Virgin Islands Department of Planning and Natural Resources ("DPNR") for the Marine Loading Project on November 14, 2016 (Permit No. STX-895-AC-PO-16 or the "Permit").  Limetree Bay Terminals was already granted in the Permit an Authority to Construct larger pumps and a Marine Vapor Collection System (MVCS) covered by the Initial Application. This application for a Revision to the Permit (the "Revised Application") seeks an Authority to Construct a Single Point Mooring (SPM), which is a modification to the existing dock system. 

The emissions associated with this project as modified in the Revised Application remain the same as set forth in the Initial Application.  The SPM will supplement the existing docks and will allow certain large crude tanker vessels to load and unload at Limetree Bay Terminals at maximum draft increasing the commercial reliability of the terminal operations.  At the time of the submission of the Initial Application, the SPM had not been designed and too little was known about the project for it to be included in the Initial Application.  However, the emissions from the loading of marine vessels were calculated based on projected throughputs for the Terminal, determined using the total existing tank capacity at Limetree Bay Terminals, and the maximum projected turnover for each tank.  Therefore, emission calculations included in the Initial Application conservatively accounted for the maximum feasible loading capacity for the entire site, which is independent of the total number of docks.  For this reason, the total loading throughputs authorized pursuant to the Permit will not be increased as a result of the modification of the marine docks by the addition of an SPM.  And therefore, the emissions associated with this project as modified in the Revised Application remain the same as set forth in the Initial Application.
  
Despite the fact that emissions associated with this revision are not modified, the PSD Step 1 analysis shows a reduction on the total emissions of volatile organic compounds (VOC).  This reduction is the result of a correction on the Initial Application PSD analysis that inadvertently captured the MVCS and thermal oxidizer as new emission units.  The MVCS and associated thermal oxidizer are control devices designed to control VOC emissions associated with the marine loading of gasoline and gasoline blendstocks.  Therefore, for the purposes of the PSD 


Step 1 analysis, both the MVCS and the thermal oxidizer being control devices on an existing unit, should have been accounted for as existing units instead of new units.  The Revised Application incorporates this correction into the PSD Step 1 analysis.

Attachments include a proposed revised permit for the Marine Loading Project and the Revised Application with any major changes marked in red font.  Most of the changes in the Initial Application were made to include information about the SPM.  However, some changes were made to clarify some of the information previously provided.  Minor changes such as capitalization or change of a single word are not marked because they do not represent material changes to the Initial Application. This is also true of the proposed revisions to the Permit.  One clarification that Limetree Bay Terminals believes is important is the addition of language clarifying consistent with applicable regulations that control of gasoline and gasoline blendstocks loading by the MVCS is not required until the pumps begin operation, which has not yet occurred.

Limetree Bay Terminals started construction on the pumps authorized by the Permit in February this year and is currently engineering the MVCS.  Limetree Bay Terminals would appreciate an expedited review of the Revised Application and issuance of a Revision to the Permit. 




If you have any questions or require any additional information, please call Ms. Catherine Elizee at (340) 692-3073.  



                                    Sincerely,
                                    
                                    
                                    
                                    
                                    Darius Sweet
                                    CEO






DS/CE/jp
Enclosure
cc:  Dawn L. Henry, Commissioner (V.I. DPNR) w/o attachment
      Verline Marcellin (V.I. DPNR) w/ attachment
