Launching a new ethanol transloading operation requires careful alignment with Texas air permitting regulations, especially when handling flammable liquids and managing rail-to-truck transfer systems. When a bulk liquid storage and transfer operator expanded operations to include ethanol loading using closed-loop connections, ESE Partners was brought in to provide the air permitting support needed to move the project forward.
Our team began by evaluating project applicability under 30 TAC §106.4 and §106.261, ensuring the operation met the thresholds for Permit by Rule authorization. We then developed a complete emissions analysis using TCEQ-approved AP-42 methodologies, modeling worst-case loading conditions to confirm compliance with hourly and annual VOC limits.
ESE prepared all required TCEQ documentation, including process descriptions, emissions workbooks, regulatory checklists, and supporting technical files. We also coordinated directly with TCEQ to ensure proper submittal delivery and acceptance — reducing review delays and improving permitting certainty.
With the PBR authorization successfully accepted, the operator secured the approvals necessary to begin operations, maintain compliance, and continue expanding service capabilities.
At ESE Partners, we help industrial clients move projects forward responsibly and efficiently — providing the technical expertise and regulatory insight needed to stay in compliance from day one.
