1
Approval
and
Promulgation
of
Implementation
Plans;
State
of
Texas
;
Agreed
Orders
in
the
Beaumont
/
Port
Arthur
Ozone
Nonattainment
Area
Technical
Support
Document
R06­
OAR­
2005­
TX­
0019
February
14,2005
The
TCEQ
entered
into
eight
Agreed
Orders
with
six
companies
at
seven
sites
to
make
sure
activities
and
emission
reductions
could
become
federally
enforceable.
This
proposed
SIP
revision
is
site
specific.
There
are
a
variety
of
projects
contained
with
in
the
Agreed
Orders,
some
will
result
in
quantifiable
emission
reductions
and
others
will
improve
the
operations,
maintenance,
and
reliability
of
systems.
TCEQ
calculated
the
emission
reductions
in
terms
of
allowable
emissions.
As
delineated
in
the
Agreed
Orders
with
each
company
the
reductions
stipulated
in
each
order
will
not
be
used
for
future
offsets
or
banking.
Due
to
this
stipulation,
some
of
the
companies
have
reserved
some
of
the
reductions
gained
by
the
submitted
projects
for
their
own
future
offsets
and
banking.
The
modeling,
attainment
demonstration
SIP,
and
the
rate
of
progress
plan
submitted
on
November
16,
2004,
for
the
Beaumont
Port
Arthur
Ozone
nonattainment
area
do
not
take
credit
for
these
emission
reductions
whether
they
are
delineated
in
the
Orders
as
required
reductions
or
are
reserved
by
the
companies
for
future
use.

ExxonMobil
Oil
Corporation,
Jefferson
County
Agreed
Order;
Docket
No.
2004­
0846­
SIP
TCEQ
Account
number
JE­
0067­
I,
Customer
No.
601470214,
Regulated
Entity
No.
102450756
ExxonMobil
installed
a
wet
gas
scrubber
on
the
fluid
catalytic
cracking
unit
in
order
to
reduce
sulfur
dioxide
(
SO
2)
emissions.
The
previous
permit
allowable
for
Emission
Point
Number
(
EPN)
06STK_
001
was
12,833.75
tons
per
year
(
TPY),
established
in
TCEQ
Permit
#
19566.
This
allowable
was
established
for
the
grandfathered
FCCU
CO
(
carbon
monoxide)
boiler
stack
in
order
to
assure
that
any
expansion
projects
elsewhere
in
the
plant
would
not
cause
emission
increases
from
the
unit.
This
project
was
originally
submitted
as
a
voluntary
emissions
reduction
permit
(
VERP).
The
new
allowable
rate
for
EPN
06ST_
003,
the
FCCU
Scrubber
Stack,
is
2,849.19
TPY
SO
2.
The
new
allowable
is
reported
to
be
based
upon
an
outlet
concentration
of
200
ppmv.
The
emission
reductions
from
this
project
is
9,984.6
TPY
SO
2
(
12,833.75
TPY
­
2,849.19
TPY).
These
reductions
are
enforceable
through
TCEQ
Permit
#:
46534.
The
Company
reserved
300
TPY
SO
2
to
be
allocated
to
other
projects,
and
any
SO2
emissions
reductions
above
9400.
This
left
no
more
than
9,400
TPY
and
no
less
than
584
TPY
in
SO
2
reductions.

By
December
31,
2004
ExxonMobil
implemented
improved
practices
and
maintenance
procedure
for
the
two
ketone
units.
These
improved
practices
and
procedures
will
help
to
reduce
the
fugitive
emissions.
The
emissions
are
reported
under
EPN
41FUG_
001,
EPN
41FUG_
002,
EPN
42FUG_
001,
and
EPN
41FUG_
002.
The
company
will
prepare
a
written
plan
describing
the
detailed
maintenance
procedures.
The
company
will
keep
a
copy
of
the
plan
available
for
review
on
site
for
2
inspection
by
TCEQ.
These
improved
practices
were
submitted
as
part
of
VERP
#:
47358,
which
is
currently
under
review
by
TCEQ.
The
leak
detection
and
repair
program
for
fugitive
emissions
have
also
been
changed.
The
program
has
been
changed
from
28
RCT
to
the
more
stringent
28
VHP.
Leaks
from
pumps
and
compressors
are
repaired
at
a
lower
leak
detection
limit,
2,000
ppmv
verses
10,000
ppmv.
This
project
is
estimated
to
provide
a
volatile
organic
compounds
(
VOC)
reduction
of
4
TPY.
The
Company
did
not
reserve
any
of
the
VOC
emission
reductions
that
would
be
achieved
by
these
practices.

ExxonMobil
is
building
a
new
cogeneration
unit.
This
unit
will
allow
for
the
shut
down
of
six
existing
boilers
by
May
1,
2006.
The
following
boilers
will
be
shutdown
EPN
56STK_
015,
EPN
56STK_
016,
EPN
56STK_
017,
EPN
56STK_
018,
EPN
56STK_
019,
and
EPN
56STK_
032.
The
Company
did
not
reserve
any
of
the
emissions
reductions
that
will
be
achieved
by
the
shutdown
of
these
six
boilers.

The
VOC
emissions
as
reported
in
the
Emissions
Inventory
(
EI)
for
2001­
2003
averaged
approximately
37
TPY.
The
company
assigned
29
TPY
of
the
VOC
reductions
to
the
Agreed
Order,
they
are
reserving
the
remaining
VOC
and
other
emissions
reduction
for
other
projects
which
are
not
part
of
the
Agreed
Orders.
The
following
table
contains
the
VOC
emissions
from
the
2001­
2003
EIs
for
these
boilers.

Year
EPN
F­
KVGS
Total
Tons
RFR­
COMP1
Tons
RFR­
COMP2
Tons
RFR­
COMP3
Tons
RFR­
FUGS
Tons
1997
282.8
70.7
70.7
70.7
70.7
1998
366.5
91.62
91.62
91.62
91.62
1999
180
45.04
45.04
45.04
45.04
2000
36
9.0
9.0
9.0
9.0
2001
shutdown
ExxonMobil
will
continue
to
operate
two
SO
2
monitors
as
described
in
Ordering
Provision
No.
2
of
the
Agreed
Order
between
the
Company
and
TCEQ,
Docket
No.
97­
0827­
AIR­
E.
The
company
will
continue
to
operate
these
SO
2
Monitoring
Stations
until
EPA
has
determined
that
the
BPA
area
has
attained
the
8­
hour
standard
and
redesignated
the
area
to
attainment
or
until
December
31,
2008,
which
ever
is
later.
SO
2
Monitoring
Station
2,
Site
1
is
located
inside
the
refinery
left
of
the
Buford
gate
in
the
scaffolding
lay
down
area.
The
monitor
at
this
location
is
a
Thermo
Electron
Instruments
Model
Number
43A
(
Serial
#:
34876­
249).
SO
2
Monitoring
Station
3,
Site
3
is
inside
the
plant
a
the
B&
P
docks.
The
monitor
at
this
location
is
a
Thermo
Electron
Instruments
Model
Number
43C
(
Serial
#:
61673­
333).

The
Company
has
also
installed
new
Vivicom
Software
and
installed
new
NO
x,
CO,
and
O
2
emissions
analyzers.
This
updated
software
will
allow
for
more
accurate
and
timely
response
to
emission
variations.
The
software
allows
for
more
efficient
maintenance
activities
such
as
calibration
and
3
validation
of
equipment.
There
are
no
quantifiable
reductions
associated
with
this
project.

Mobil
Chemical
Company,
Division
of
ExxonMobil
Oil
Corporation,
Jefferson
County
Agreed
Order;
Docket
No.
2004­
0841­
SIP
TCEQ
Account
number
JE­
0062S,
Customer
No.
601470214,
Regulated
Entity
No.
102450756
The
Mobil
Chemical
Company
will
shut
down
the
grandfathered
olfins
and
aromatics
(
O&
A)
plant
boiler,
EPN
EH34,
on
or
before
December
1,
2006.
The
Company
stated
the
grandfathered
emission
level
for
NO
x
as
261
TPY,
the
2002­
2003
EI
data
showed
an
average
level
of
235
TPY.
75
tons
per
year
of
NO
x
were
retained
by
the
Company
for
future
use.
All
of
the
NOx
emissions
reductions
above
75
TPY
that
will
be
achieved
by
the
shutdown
of
the
boiler
are
required
by
the
Order.
This
amounts
to
about
160­
180
TPY
NO
x
reductions.
All
of
the
other
emissions
reductions
that
will
be
achieved
by
the
shutdown
are
required
by
the
Agreed
Order;
the
Company
did
not
reserve
them
for
future
use.
Estimated
VOC
reductions
of
1.3
TPY
were
based
upon
the
highest
of
the
last
four
years
of
EI
data
(
2002).
The
emissions
reported
for
the
olfins
&
aromatics
plant
boiler
for
the
2000­
2003
EI
are
as
follows:

Air
Contaminant
Determination
Method
2003
TPY
2002
TPY
2001
TPY
2000
TPY
VOC
AP­
42
emission
factors
1.22
1.26
1.07
1.22
NO
x
Stack
test
232.22
237.63
202.26
224.36
CO
Stack
test
0.747
0.768
0.709
4.17
By
December
31,
2005
Mobil
Chemical
Company
will
remove
components
of
the
O&
A
Plant
UDEX
Unit
which
will
result
in
a
reduction
of
fugitive
emissions
of
VOC
from
EPNs
EF3,
EF4,
EF9,
EF10,
and
EF11.
The
new
configuration
is
represented
in
TCEQ
Air
Quality
Permit
#:
18838.
EPN
EF9
had
also
been
listed
in
TCEQ
Permit
#:
7799
at
an
allowable
emission
rate
of
68.61
TPY
VOC.
The
emission
reductions
for
this
project
is
estimated
to
be
158.49
TPY
VOC.
The
revised
allowable
emission
rates
are
listed
below.
The
total
VOC
reductions
required
by
this
Agreed
Order
are
estimated
to
be
159.8
TPY
(
158.49
TPY
+
1.3
TPY).
All
of
the
emissions
reductions
that
will
be
achieved
by
the
removal
of
the
components
are
required
by
the
Order.
The
Company
did
not
reserve
any
of
the
emissions
reductions
for
future
use.
4
EPN
Previous
VOC
TPY
Revised
VOC
TPY
VOC
Reduction
TPY
EF3
38.60
2.56
36.04
EF4
6.10
0.68
5.42
EF9
35.30
+
68.61
5.90
98.01
EF10
10.70
1.12
9.58
EF11
9.70
0.26
9.44
TOTAL
100.4
10.52
158.49
Mobil
Chemical
Company,
Division
of
ExxonMobil
Oil
Corporation,
Jefferson
County
Agreed
Order
Docket
No.
2004­
1654­
SIP
TCEQ
Account
number
JE­
0064O,
Customer
No.
601549660,
Regulated
Entity
No.
101485738
The
Chemical
Specialties
Plant
sulfurized
isobutylene
unit
authorized
by
TCEQ
Air
Quality
Permit
#:
3186
has
been
shutdown.
The
Company
did
not
reserve
for
future
use
any
of
the
emissions
reductions
that
will
be
achieved
by
this
shutdown.
The
permitted
allowable
emission
rates
for
this
unit
were
as
follows:
13.8
TPY
VOC,
0.8
TPY
H
2
S
(
hydrogen
sulfide),
and
0.1
TPY
CO.
TCEQ
has
estimated
that
there
will
be
5.7
TPY
of
VOC
and
0.2
TPY
H
2
S
reductions
.

ISP
Elastomers,
Jefferson
County,
Agreed
Order
Docket
No.
2004­
0842­
SIP
TCEQ
Account
number
JE­
0017­
A,
Customer
No.
602296287,
Regulated
Entity
No.
10224799
ISP
Elastomers
has
shutdown
a
grandfathered
ammonia
refrigeration
unit
thereby
eliminating
the
fugitive
ammonia
emissions
from
EPN
F­
KVGS.
The
Company
did
not
reserve
for
future
use
any
of
the
emissions
reductions
that
will
be
achieved
by
the
shutdown.
Since
the
unit
was
grandfathered
there
was
not
an
allowable
emission
rate.
The
Company
has
reported
the
fugitive
ammonia
emissions
under
four
facility
identification
numbers
(
see
below).
The
estimated
emission
reductions
resulting
from
the
shutdown
are
280
TPY
ammonia.
During
2000,
the
shut
down
of
the
unit
had
begun
therefore
the
emissions
reported
to
the
EI
that
year
are
not
representative
of
the
actual
values.
The
average
emission
rate
from
1997­
1999
is
about
280
TPY.
According
to
the
EI,
the
emissions
were
calculated
based
upon
material
balancing.
The
company
assumed
that
all
of
the
purchased
ammonia
was
lost
as
fugitive
emissions.
Since
there
are
four
FINs
associated
with
EPN
F­
KVGS.
The
emissions
were
distributed
evenly
across
all
of
them
for
simplicity.
5
Year
EPN
F­
KVGS
Total
Tons
RFR­
COMP1
Tons
RFR­
COMP2
Tons
RFR­
COMP3
Tons
RFR­
FUGS
Tons
1997
282.8
70.7
70.7
70.7
70.7
1998
366.5
91.62
91.62
91.62
91.62
1999
180
45.04
45.04
45.04
45.04
2000
36
9.0
9.0
9.0
9.0
2001
shutdown
Huntsman
Petrochemical
Corporation,
Jefferson
County,
Port
Neches
Plant
Agreed
Order
Docket
No.
2004­
0882­
SIP
TCEQ
Account
Number
JE­
0052­
V,
Customer
No.
600632848,
Regulated
Entity
No.
100219252
The
Huntsman
Petrochemical
Corporation
has
installed
and
configured
for
use
E!
CEMS
Software
to
improve
the
data
and
system
reliability
regarding
electronic
data
gathered
for
compliance
purposes.
E!
CEMS
is
an
web­
enabled,
electronic
database
information
management
system
developed
by
Ellipsys.
The
system
will
improve
tracking
of
emissions
and
allow
for
quicker
response
to
potential
problems.
There
are
no
quantifiable
emission
reductions
from
the
implementation
of
this
measure.

Huntsman
Petrochemical
Corporation,
Jefferson
County,
Port
Arthur
Plant
Agreed
Order
Docket
No.
2004­
0845­
SIP
TCEQ
Account
Number
JE­
0135­
Q,
Customer
No.
600632848,
Regulated
Entity
No.
1002192522
Huntsman
Petrochemical
Corporation
is
controlling
emissions
of
benzene
from
Storage
Tanks
4865,
4866,
and
4867.
The
Company
is
not
reserving
for
future
use
any
of
the
emissions
reductions
that
will
be
achieved
by
the
benzene
tank
project.
These
tanks
have
internal
floating
roof
which
meet
the
best
available
control
technology
(
BACT)
requirements.
The
emissions
from
these
tanks
were
routed
to
a
thermal
oxidizer
on
December
31,
2003.
Huntsman
sumibitted
a
permit
revision
to
TCEQ
Permit
#
16989
and
the
benzene
emissions
cap
has
been
reduced.
The
reductions
were
included
in
an
Emission
Cap
Compliance
Plan
dated
May
15,
2002
and
calculated
by
the
EPA
program
TANKS.
The
reductions
are
reported
as
follows:
6
Tank
4865
0.83
TPY
benzene
Tank
4866
0.83
TPY
benzene
Tank
4867
1.50
TPY
benzene
Tank
4868
0.99
TPY
benzene
TOTAL:
4.15
TPY
benzene
Huntsman
Petrochemical
Corporation
has
also
installed
and
configured
E!
CEMS
Software
at
the
Port
Arthur
Plant.

Premcor
Refining
Group,
Jefferson
County
Agreed
Order
Docket
No.
2004­
0845­
SIP
TCEQ
Account
Number
JE­
0042B,
Customer
No.
601420748,
Regulated
Entity
No.
102584026
Premcor
Refining
Group
has
replaced
the
fuel
gas
burners
(
combined
rated
duty
of
approximately
600
million
British
Thermal
Units
per
hour)
in
five
of
its
process
heaters
in
catalytic
reforming
unit
#
1344
with
low
NO
x
burners.
The
Company
did
not
reserve
for
future
use
any
of
the
emissions
reductions
that
would
be
achieved
by
this
replacement.
In
issuing
the
revised
permit,
the
TCEQ
estimated
that
the
replacement
of
the
fuel
gas
burners
with
the
low
NOx
burners
would
produce
an
estimated
400
TPY
NO
x
emission
reductions.
The
TCEQ's
technology
control
requirements
for
the
operation
of
the
low
NOx
burners
would
result
in
291
TPY
of
NOx
reductions.
The
Company
agreed
in
the
permit
to
operate
the
low
NOx
burners
even
more
stringently
and
thereby
achieve
an
additional
109
TPY
of
NOx
emissions
reductions.

The
Company
has
installed
a
sulfur
degassing
system
designed
to
remove
H
2
S
from
the
sulfur
prior
to
loading
into
trucks
from
all
of
the
in­
ground
storage
tanks
at
Sulfur
Recovery
Units
543
and
544.
The
Company
did
not
reserve
for
future
use
any
of
the
emissions
reductions
that
would
be
achieved
by
this
installation.
The
TCEQ's
technology
control
requirements
for
operation
of
the
degassing
system
would
require
3.1
TPY
of
H2S
reductions.
The
Company
agreed
in
the
permit
to
more
effective
controls
and
thereby
achieve
an
additional
1.6
TPY
of
H2S
emissions
reductions.

Premcor
has
installed
and
configured
for
use
the
Ops
EnvironmentalTM
Software.
This
system
will
integrate
a
multi­
media
environmental
data
management
system
linked
to
60
existing
boiler
and
process
heater
continuous
emissions
monitoring
systems
(
CEMS)
and
the
Refinery
process
information
system.
The
software
is
designed
to
improve
tracking
of
actual
emissions,
operator
response
times
and
corrective
action
by
the
Company.
There
are
no
quantifiable
emission
reductions
from
the
implementation
of
this
measure.

The
Company
has
made
equipment
modifications
to
improve
the
regenerative
thermal
oxidizer
(
RTO)
for
wastewater
treatment
unit
#
8742.
The
following
modifications
are
designed
to
improve
the
reliability
of
the
unit
and
help
prevent
RTO
shutdowns.
Since
the
nature
of
these
modifications
are
to
prevent
emission
events
associated
with
RTO
shutdowns
and
not
a
reduction
in
allowable
emissions,
there
are
no
quantifiable
emission
reductions
from
the
implementation
of
these
measures.
7
The
modifications
are
listed
below.
°
Redundant
flame
detectors
with
100%
voting
logic
to
minimize
false
signals
that
can
cause
unwarranted
shutdowns
and
instrument
air
purge
to
flame
scanner
path.
The
improved
flame
detector
design
will
also
allow
on­
stream
cleaning.
°
Fiber
optics
control
communications
wiring
that
will
be
less
susceptible
to
lightning
induced
voltage
spikes.
°
New
motor
actuated
combustion
air
and
fuel
flow
control
valves
that
do
not
use
mechanical
linkages
which
for
combustion
control.
°
Modified
deal
drum
level
control
design.
°
Deletion
of
damper
fauld
shutdown
(
kept
alarm
alive).
°
Reduction
of
induced
draft
fan
vibration
and
bearing
temperature
shutdowns
(
kept
alarm
active).
°
Replacement
of
all
damper
actuators.
°
Replacement
of
both
hydraulic
pumps.
°
Adjustment
of
burner
minimum
fire
to
lowest
possible
setting.

Premcor
will
also
improve
the
RTO
by
upgrading
the
master
electronic
control
system
by
June
30,
2005.
As
with
the
previously
listed
modifications
to
the
RTO,
there
are
no
quantifiable
emission
reductions.
The
Company
will
be
making
the
following
modifications
to
the
Master
electronic
control
system
to
the
RTO.
°
Replace
the
new
master
Programmable
Logic
Controller.
°
The
logic
programming
will
be
reviewed
and
revised
to
simplify
its
function
while
maintaining
necessary
fail
sage
operational
integrity.
°
Certain
RTO
control
loops
sill
ve
moved
to
the
existing
distributed
Control
System
to
allow
for
better
control
and
tuning.

By
April
30,
2005
Premcor
will
complete
the
installation
of
a
wet
gas
scrubber
at
the
outlet
of
the
regenerator
on
the
fluid
catalytic
cracking
unit
#
1241.
The
wet
gas
scrubber
uses
caustic
and
water
solution
sprays
to
remove
sulfur
and
particulates
from
the
generator
flue
gas.
BACT
requirements
for
flexible
permit
#
6825A
require
reduction
of
3,300
TPY
SO
2,
the
scrubber
will
reduce
emissions
by
4,400
TPY
SO
2.
The
excess
reductions
of
1,100
TPY
SO
2
are
considered
to
be
voluntary.

By
April
30,
2005
Premcor
will
complete
the
installation
of
a
wet
gas
scrubber
at
the
outlet
of
the
regenerator
on
the
fluid
catalytic
cracking
unit
#
1241.
The
Company
did
not
reserve
for
future
use
any
of
the
emissions
reductions
that
will
be
achieved
by
this
installation.
The
wet
gas
scrubber
uses
caustic
and
water
solution
sprays
to
remove
sulfur
and
particulates
from
the
generator
flue
gas.
The
TCEQ's
technology
control
requirements
for
the
wet
gas
scrubber
would
require
reductions
of
3,300
TPY
SO
2.
The
Company
agreed
in
the
permit
to
more
stringent
controls
and
thereby
achieve
an
additional
1,100
TPY
SO
2
emissions
reductions.
8
Motiva
Enterprises
LLC,
Jefferson
County
Agreed
Order
Docket
No.
2004­
0843­
SIP
TCEQ
Account
Number
JE­
0095D,
Customer
No.
600124051,
Regulated
Entity
No.
1000209451
Motiva
Enterprises
LLC
has
shut
down
Boilers
26
and
27,
EPN
SPS2­
6
and
EPN
SPS2­
7
respectively.
The
Company
did
not
reserve
for
future
use
any
of
the
emissions
reductions
that
will
be
achieved
by
the
shutdown
of
these
two
boilers.
The
allowable
emission
rates
from
the
shutdown
of
the
boilers
will
be
removed
from
TCEQ
permit
#
6056.
The
current
allowable
emission
rates
are
as
follows:

Air
Contaminant
Boiler
26
EPN
SPS2­
6
TPY
Boiler
27
EPN
SPS2­
7
TPY
Total
Reduction
from
Shutdown
TPY
NO
x
680.0
680.0
1360.0
SO
2
32.7
32.7
65.4
PM
10
6.2
6.2
12.4
CO
41.9
41.9
83.8
VOC
1.7
1.7
3.4
The
Company
will
shutdown
Boiler
31
(
EPN
SPS3­
1)
and
replace
it
with
a
new
waste
heat
boiler
(
EPN
WHB37SCR)
under
TCEQ
Standard
Pollution
Control
Permit
#
54322.
The
Company
will
also
uncouple
the
Gas
Turbine
Generator
35
from
Boiler
34
(
EPN
SPS3­
4
and
Boiler
35
(
EPN
SPS3­
5)
and
route
the
exhaust
gas
to
the
new
waste
heat
boiler.
NO
x
emissions
from
the
waste
heat
boiler
will
be
controlled
with
selective
catalytic
reduction.
The
Company
did
not
reserve
for
future
use
any
of
the
emissions
reductions
that
will
be
achieved
by
the
shutdown
of
Boiler
31
and
the
uncoupling/
rerouting.
Boiler
31
is
permitted
under
TCEQ
Air
Quality
Permit
#:
6056
with
an
allowable
NO
x
emission
rate
of
905.8
TPY.
The
new
Waste
Heat
Boiler
is
authorized
by
TCEQ
Air
Quality
Permit
#
54322
with
an
allowable
emission
rate
for
NO
x
of
236.1
TPY.
The
emissions
from
this
project
are
rounded
to
670
TPY
(
905.8
TPY
­
236.1
TPY).
No
other
emission
reductions
have
be
quantified.

Under
a
Consent
Decree
between
the
Untied
States
of
America
and
the
States
of
Delaware
and
Louisiana
and
Motiva
Enterprises,
Inc.,
Motiva
Enterprises
was
required
to
comply
with
40
CFR
§
60.11
and
ensure
that
New
Source
Performance
Standards
(
NSPS)
compliance
at
four
flares.
This
requirement
was
to
be
met
by
meeting
the
emissions
limitation,
monitoring
and
other
requirements
for
refinery
fuel
gas
found
in
40
CFR
§
60.104
and
60.105,
or
alternative
monitoring
protocols
approved
pursuant
to
40
CFR
§
60.13(
I).
The
Company
has
begun
to
comply
with
the
NSPS
requirements
at
the
remaining
three
flares
at
the
Plant,
EPN
FCCUNO3FS,
EPN
HCUNO1
FS,
and
9
EPN
VPSNO4FS.
The
nature
of
these
modifications
are
to
prevent
emission
events
and
not
a
reduction
in
allowable
emissions,
therefore
there
are
no
quantifiable
emission
reductions
from
the
implementation
of
these
measures
Recommendation
EPA
has
reviewed
the
submitted
Agreed
Orders.
The
emission
reductions
memorialized
in
the
Agreed
Orders
between
each
of
the
companies
and
TCEQ
represent
actions
that
appear
to
be
taken
above
and
beyond
the
requirements
of
any
State
or
Federal
Agency.
The
emission
reductions
and
other
measures
outlined
in
each
of
the
Orders
are
permanent
and
can
not
be
used
for
future
banking,
trading
or
offsets.
Only
emission
reductions
specifically
identified
in
the
Orders
as
being
reserved
for
future
use
may
be
used
for
offsets,
trading,
etc.
The
Beaumont
Port
Arthur
Attainment
Demonstration
Ozone
SIP
and
the
rate
of
progress
plan
do
not
take
credit
for
any
of
these
emission
reductions
required
by
the
Agreed
Orders.
The
reduction
in
emissions
required
by
these
Orders
will
aid
in
the
improvement
of
the
air
quality
in
the
Beaumont
Port
Arthur
Ozone
Nonattainment
Area,
will
contribute
to
maintenance
of
the
standards
in
northeast
Texas,
and
strengthen
the
existing
Texas
SIP;
therefore
these
Agreed
Orders
should
be
approved
and
adopted
into
the
Texas
SIP.
