TPC Group (TPC) has operated in Houston’s East End for more than 75 years. TPC is not only a business in the neighborhood, it’s a vital member of the community. The Company is a visible and supporting partner to many local organizations. Our community relationships and activities support our efforts to always be a good neighbor and maintain transparency in our actions and communications. We also work closely with state and federal regulators to ensure all applicable safety and environmental standards, which are implemented to protect the public and the environment, are met.

In this permitting process and in all Company activities, TPC Group:

• Builds mutually beneficial community relationships that are responsible, respectful and supportive.
• Operates its facility in an environmentally responsible manner.
• Provides a positive economic impact on the community and the city through investments, growth and the associated multiplier effect of this spending.
• Engages in ongoing dialogue in the community to understand and respond to concerns.
• Delivers local leadership and investment level to impact the community economy.

TPC is a major independent crude C4 processing company in North America. Crude C4 is a byproduct of cracking natural gas liquids or naphtha into ethylene and sourced from ethylene crackers. TPC is modernizing and expanding its processing capacity in Houston to meet the growing crude C4 processing needs of suppliers and provide support for customers that require butadiene for the production of synthetic rubber used in automobile tires and hoses.

TPC filed permit amendment applications in February 2020 with the Texas Commission on Environmental Quality (TCEQ). These permits will authorize:

• A butadiene (BD) capacity increase and operational improvement projects that support crude C4 processing and BD extraction.
• A Compliance Assurance Plan (CAP) to address particulate matter.
• This project will result in an estimated 90 full-time, contract jobs to support the construction and engineering phases of the project.

Upgraded Technology Will Increase Production

TPC has proposed to expand capacity of the Houston site using more efficient and less impactful equipment.

• TPC is seeking TCEQ approval of these permits in 2021 to ensure the Company is prepared for the startup of the next wave of U.S. ethylene crackers, which is anticipated to occur as early as 2022.
• Upfront engineering for the project has been completed.
• Crude C4 processing expansion will add an additional 25 percent to the Houston plant’s butadiene production capacity.

What are these permits for? TPC Group has filed four separate amendment applications, one for each of three permits affected by the project: The Voluntary Emissions Reduction Program (VERP), Cogen, and Dock permits. Additionally, there is an amendment application for the Dehydro 2 Unit. To ensure the protectiveness of the project, all new, modified and affected sources are being comprehensively evaluated under one Federal New Source Review (FNSR) Analysis and one Air Quality Analysis (AQA):

• VERP Permit Amendment will authorize the BD production capacity increase, implement several reliability improvement projects and add the production of new final products (such as ethyl tertiary butylene ether/ETBE and Iso-octene). These products are used in the blending and refining of gasoline. Also included in the amendment is construction and installation of new towers, heat exchangers, storage tanks, sphere, pumps, associated piping and supporting equipment.
• Cogen Permit Amendment will authorize the installation of a new boiler and associated control equipment to replace the oldest and least reliable boiler at the site. This replacement boiler will result in a significant reduction in NOx emissions from the site.
• Dock Permit Amendment will authorize additional loading capacities, as well as the authorization of loading new products, including raffinate. A new thermal oxidizer will be installed to upgrade the emission control equipment utilized during loading/unloading of raw materials, intermediates and final products.
• Dehydro 2 Unit Amendment will authorize the installation of new equipment and other miscellaneous changes to implement a Compliance Assurance Plan with TCEQ.   

How do the activities this permit would enable at the Houston Plant vary from how the plant currently operates?  Permit changes will provide for newer, more reliable equipment. These changes will result in less unauthorized emissions and fewer flaring events.

What technologies will TPC’s Houston Plant implement to assure any emissions are as low as possible? The BD expansion project at TPC Group’s Houston plant includes modernization and upgrades to existing equipment following extensive engineering upgrades and new equipment installation using Best Available Control Technology (BACT) or greater level of control.

What are some of the key emission reductions that will occur as a result of the new permits?

 Shutting down largest emitter

•  Boiler 9 permitted to emit 658 tons per year of NOx
•  Amended permit authorizes Boiler 12 as the replacement, with emissions of 29 tons per year of NOx – a reduction of 629 tons of NOx

Lower emissions limits on all Cooling Towers

•  Currently permitted to emit 33.0 tons per year of VOC
• Amended permit authorizes 20.3 tons per year of VOC – a reduction of 12.7 tons of VOC

Lower emissions limits on the Plant Flare

• Currently permitted to emit 75.3 tons per year of VOC
• Amended permit authorizes 20.9 ton per year of VOC – a reduction of 54.4 tons of VOC

Do you expect emissions at the Houston Plant to increase due to these new permits? While we are seeking some increases in allowable emissions as part of this permitting, we are proud of the emissions reductions outlined above that will help offset these proposed increases. In addition, we note:

• Since 2004, TPC has reduced annual 1,3- butadiene emission by nearly 90 percent from its Houston plant.
  • TPC operates BD fence line monitoring along both the south and north site perimeter and conducts routine monitoring of VOCs onsite and at its fence line with the use of a handheld infrared camera (FLIR camera).
• TPC implements a robust investigation protocol for possible leaks of BD, which includes procedures for notifying the TCEQ, City of Houston and TPC’s industrial and residential neighbors with regards to fence line BD monitoring.
• TPC uses portable spectrometer devices monthly to identify work practices in all major process areas, including rail loading, BD finishing area and API and wastewater area, that may be a source of BD emissions.