Public Notice: Public Comment and Hearing Opportunity for Texas Gulflink LLC Deepwater Port Minor New Source Review and Federal Operating Permit Number: R6NSRT5-DWP-GA9

Summary

The United States Environmental Protection Agency (EPA) provides notice of and requests public comments on the draft Clean Air Act (CAA) permit for the proposed Texas Gulflink, LLC deepwater port (DWP) crude oil export terminal; specifically, a draft combined synthetic minor new source review (NSR) preconstruction and Part 71, title V federal operating permit. If finalized, the proposed CAA permit would authorize construction and regulate stationary source air pollutant emissions associated with operation of the facility.

Texas Gulflink, LLC (TGL) proposes to construct and operate a DWP in federal waters approximately 26.6 nautical miles southeast of Freeport, Brazoria County, Texas. The port will consist of two single point mooring buoys and a central, manned platform that will provide crude oil loading service to fully and directly load Very Large Crude Carriers (VLCCs) and other oceangoing sized carriers for export to the global market. The DWP terminal’s maximum loading rate will be 85,000 barrels per hour (bbl/hr) and maximum annual throughput will be 365,000,000 bbl/year.

Permit Number:  R6NSRT5-DWP-GA9

Fixed Offshore Platform.  One fixed offshore platform with piles will be located in Outer Continental Shelf Galveston Area Lease Block GA-423 in a water depth of approximately 104 feet. The platform will be located at approximately 28° 33’ 08.99” North latitude, 97.8° 01’ 42.35” West longitude . The platform will have four decks comprised of personal living space, pipeline metering, a surge system, a pig receiving station, generators, lease automatic custody transfer unit, oil displacement prover loop, sample system, radar tower, electrical and instrumentation building, portal cranes, a hydraulic crane, an operations/traffic room, and helicopter deck.

Connections for Loading Crude Oil from the Platform to VLCC Tankers. The fixed offshore platform will be connected to VLCC tankers for loading by two separate 42-inch diameter departing pipelines. Each pipeline will depart the fixed offshore platform, carrying the crude oil to a Pipeline End Manifold (PLEM) in approximately 104 feet of water depth located 1.25 nautical miles from the fixed offshore platform. Each PLEM is then connected to a Single Point Mooring (SPM) Buoy through two 24-inch cargo hoses. Two 24-inch floating cargo hoses will connect each SPM Buoy to the VLCC (or other crude oil carrier type). SPM Buoy 1 is to be positioned in Outer Continental Shelf Galveston Area Lease Block GA-423 and SPM Buoy 2 is to be positioned in Outer Continental Shelf Galveston Area Lease Block GA-A36.

Offshore Support Vessel for DWP Loading Emissions Capture & Control. A dynamically positioned third-party Offshore Support Vessel (OSV) meeting the United States Coast Guard classification requirements of a gas carrier, remains within approximately100 feet of the tanker ship moored at the deepwater port in preparation for loading and for the duration of the loading operation. The tanker ships being loaded with crude oil will be certified as having passed a leak tightness test within the 12 months prior to the loading operation at the port and will be evaluated for leaks during the loading operation while at the deepwater port.  The emissions generated and displaced from the cargo hold of the tanker ship being loaded at the deepwater port are continuously routed via a closed vent system (99.49% capture efficiency) using a flexible transfer hose to the OSV for processing and control.

The OSV supplies the flexible hose that connects the vapor manifold onboard the tanker ship being loaded to the inlet vapor manifold of the OSV.  The vapors are then routed and processed through a Vapor Processing Module (VPM). The output of the VPM includes slop related water and volatile organic compounds (VOCs), including methane, in either condensible or non-condensible form. Condensable VOCs are processed into liquid form (called L-VOCs) and are stored in pressure vessels onboard the OSV. All of the non-condensible emissions stream processed through the VPM (called surplus VOCs, or S-VOCs) is routed to gas turbines mounted on the OSV where it is used as fuel for the gas turbines and thus destroyed.  Some of the stored L-VOCs is regasified and then routed through the gas turbines for use as supplemental fuel necessary to generate electricity for the VPM and other OSV use.  However, most of the recovered L-VOCs remain stored in pressure vessels on the OSV until offloaded at a mainland port near Freeport. The overall capture and control efficiency of the tanker ship loading related VOC emissions at the DWP is over 97.6% as represented in the permit application. 

Proposed combined synthetic minor NSR and title V federal operating permit. EPA applies the provisions of the Deepwater Port Act (DPA), 33 U.S. Code (U.S.C.) § 1501, et seq, as the primary source of its authority to apply the CAA to activities associated with DWPs. In relevant part 33 U.S.C. § 1518(a)(1) extends the Constitution and law of the United States “to deepwater ports…and to activities connected, associated, or potentially interfering with the use or operation of any such port, in the same manner as if such port were an area of exclusive Federal jurisdiction located within a State.”

In addition, 33 U.S.C. § 1518(b) “federalizes” consistent laws of the adjacent state and directs that they be applied by federal officials. For this DWP permitting action, the nearest adjacent state is determined to be Texas. Thus, the laws of Texas apply to the proposed port, to the extent they are “applicable” and not inconsistent with federal law. The applicable state law includes Chapter 382 of the Texas Health and Safety Code (the Texas Clean Air Act), the federally approved State Implementation Plan (40 CFR 52 Subpart SS Texas), including but not limited to the approved provisions found in 30 TAC Chapter 116, Control of Air Pollution by Permits for New Construction or Modification, and 30 TAC Chapter 122, Federal Operating Permits Program.  The source is also subject to permitting under the Federal Operating Permit Programs, 40 CFR Part 71. The source’s potential to emit (PTE), as proposed, will emit air contaminants for which ambient air quality standards have been established under title 1 of the CAA (criteria pollutants) and will emit some air contaminants which are also identified as hazardous air pollutants under Title II of the CAA (HAP).  The location of the proposed DWP is in an area that is treated as attainment/unclassifiable as to air quality, and as such the source is not subject to federal nonattainment area new source review requirements for criteria pollutants.

In accordance with 30 TAC Chapter 116 the TGL DWP stationary source is subject to NSR preconstruction permitting requirements for non-major sources because the source’s PTE is above the source permitting threshold for minor sources and below the thresholds for the prevention of significant deterioration requirements for major sources of criteria pollutants under 40 CFR §52.21. Further, while the source, as proposed will emit HAPs, its PTE will be below the major source thresholds for HAPs and as such will not be subject to 40 CFR Part 63, National Emissions Standards for Hazardous Air Pollutants for Source Categories (MACT standards). The DWP is subject to the federal operating permit program under 40 CFR Part 71 because the PTE from the source as proposed will be above the threshold for one or more air contaminants. The estimated PTE in tons per year for the facility are as follows:

Texas Gulflink DWP Sitewide Emissions Potential to Emit

Notes for Table

Source-wide PTE includes emissions from the regulated emission units in tons per year (tpy).

NO_x – nitrogen oxide, VOC – volatile organic compounds (non-HAP), SO_{2 –} sulfur dioxide, CO – carbon monoxide, HAP – hazardous air pollutants (mostly n-Hexane)

Permit Documents: Starting on May 22, 2025, members of the public may review EPA’s administrative record for the TGL DWP synthetic minor NSR and title V operating permit action. The administrative record includes the proposed draft permit, the statement of basis for the proposed permit, the permit applications, and additional data and supporting documentation for the permit action.

Access to electronic copies of the documents: Regulations.gov website: Navigate your web browser to http://www.regulations.gov. Once at the site, search and view the permit documents by entering the Docket ID No EPA-R06-OAR-2020-0413 into the search box. Follow the online instructions on how to access the documents.

Access to physical copies of the documents: The documents may be found in two locations- 1) Lake Jackson Branch Public Library: 250 Circle Way, Lake Jackson, TX 775; phone (979) 415-2590. Please call in advance to arrange viewing times, and 2) EPA Region 6 Office: 1201 Elm Street, Suite 500, Dallas, Texas 75270; phone (214) 665-7258.  Monday – Friday, from 8:00 a.m. – 4:30 p.m., excluding Federal holidays. Please call in advance to arrange viewing times.

Public Hearing: You have the right to request a public hearing on the proposed permit action. Any request for a public hearing must be received by EPA no later than June 4, 2025, and the request must state the nature of the issues proposed to be raised in the hearing for the permit action. Any request for a public hearing must be provided to EPA by posting a request on the Regulations.gov website listed above under Docket ID EPA-R06-OAR-2021-0413. Please note attendance/participation at a public hearing is not required in order to submit written comments.

If EPA determines that there is significant public interest in the permit action, a virtual public hearing will be held on June 24, 2025.   Due to the logistics involved in planning a virtual meeting, a pre-registration period will be necessary and will last from June  10, 2025  until June 24, 2025, the means by which one can sign up to request to speak at the public hearing will be included in the public notice as of June 10. For participants not able to pre-register, EPA will allow time for individuals attending and wanting to speak to participate, at the end of the meeting as participants indicate their interest to speak, and as time allows. EPA will send verification by e-mail to all participants who pre-register to inform them of the order of speakers registered and approximate times for speakers to provide their verbal comments during the public hearing.

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 June 4, 2025, or if EPA determines that there is not a significant interest. If EPA decides to cancel the public hearing notification of the cancellation will be posted by June 10, 2025 on the Regulations.gov website listed above and also on EPA’s website at https://www.epa.gov/publicnotices.  Once at that page, select Texas in the ‘find public notices by state’ drop down box to find the public notice.

Applicants or Respondents

Docket Numbers

• EPA-R06-OAR-2021-0413

Related Documents

• Public Notice Announcement in Spanish for Texas Gulflink DWP Permit R6NSRTV-DWP-GA9 (pdf) (168.52 KB, 5/21/2025)
  Provides Spanish Language Translation of the full Public Notice Document
• Public Notice Announcement in English for Texas Gulflink DWP Permit R6NSRTV-DWP-GA9 (pdf) (187.31 KB, 5/21/2025)
  This is the full Public Notice Announce for the project in English