Terminal Series – Article four
Contributed by Corey Gautreaux, District Manager, PPM Consultants
Why Throughput Upgrades Trigger Hidden Permit Risks
You’ve seen it before. A terminal adds a pump or loading arm to clear a bottleneck. On paper, it’s a small efficiency project, but halfway through design, the air permit throws a curveball: air dispersion modeling, public notice, or even a Prevention of Significant Deterioration (PSD) modification.
Suddenly, what looked simple now means weeks of delay and unexpected cost.
These surprises happen because even minor physical changes can alter a facility’s emissions profile. A new tank, rack, or product mix may push your potential to emit (PTE) across key regulatory thresholds, triggering additional monitoring or reporting.
Here at PPM Consultants, Inc. (PPM), we have observed in the field, most of these issues can be prevented by treating environmental permitting as part of design, not as paperwork at the end.
How Minor Upgrades Create Major Compliance Risk
In the terminal world, throughput is everything. But any increase in pumping capacity, new tankage, or product expansion affects how regulators view your site.
Adding equipment doesn’t just change operations, it can change the air emissions potential of your entire system. For example:
- A new pump or rack arm can increase vapor generation beyond your vapor recovery unit (VRU) or flare design.
- A product swap to a higher vapor pressure blend can trigger state-specific PSD thresholds.
- Even a new floating roof or tank coating can alter breathing loss calculations.
These are not theoretical. According to the U.S. Environmental Protection Agency (EPA), incremental facility changes are one of the top reasons for delayed approvals and unplanned compliance costs in air quality permitting.
A Better Way: The Project-Ready Environmental Permitting Workflow
- Start with a Simple Scoping Sheet
Document changes in products, throughput, tank sizes, controls, and hours of operation. This becomes the foundation for your PTE screening and applicability analysis.
- Run a Conservative PTE Screen
Estimate emissions using maximum expected throughput. Identify whether new controls, modeling, or recordkeeping apply under PSD or state-specific rules.
- Align Control Strategy Early
Confirm that your VRU, flare, or vent systems can handle peak load, not just average rates. Validate utilities, redundancy, and control logic. Keep documentation consistent with your permit narrative.
- Integrate the Permitting Path into the Schedule
Include expected review and public notice time in your project plan. Delays in permit issuance are easier to manage than idle crews or equipment procurement freezes.
- Prepare a Commissioning Compliance Handoff
Create a one-page sheet defining records, monitoring, and alarm responses from day one. Train operators on air quality compliance and reporting responsibilities before startup.
Why Early Permitting Integration Works
Treating environmental permitting as part of design is not just a best practice, it’s a proven risk management tool.
According to U.S. Department of Energy and EPA permitting guidance, integrating environmental compliance early in project design helps facilities minimize retrofit costs, reduce schedule risk, and build credibility with regulators. Both agencies note that applications supported by clear design documentation and realistic emissions data typically move through review faster and with fewer information requests.
For terminals, that means moving dirt on time. It also helps align engineering, EHS, and operations, ensuring that each understands how a capacity change affects long-term compliance.
How PPM Can Help
We support terminals and industrial facilities through every stage of the air permitting process – from early screening and modeling to full permit preparation and commissioning compliance. Our engineers package design notes into reviewer-friendly narratives that keep projects on track and regulators satisfied. If you’re planning a throughput increase, tank expansion, or rack modification, we can help you stay ahead of the permitting curve. To learn more about how PPM simplifies the complex, call 225-293-7270 or email corey.gautreaux@ppmco.com.