Public Notice: Public Comment and Hearing Opportunity for Blue Marlin Offshore Port LLC (BMOP) Deepwater Port (DWP) Clean Air Act Draft PSD Preconstruction Permit (R6PSD-DWP-GA10) and Draft Title V Federal Operating Permit (R6TV-DWP-GA10)
Summary
Notice:
The United States Environmental Protection Agency (EPA) provides notice of and requests public comments on EPA’s proposed permit actions relating to a Clean Air Act (CAA) Prevention of Significant Deterioration (PSD) preconstruction permit application and a title V federal operating permit application for the BMOP Deepwater Port (DWP). If finalized, the proposed permits would regulate air pollutant emissions associated with the project to modify an existing platform in the Gulf of America to provide crude oil loading services for fully and directly loading Very Large Crude Carriers (VLCCs) and other smaller crude oil carriers for export to the global market.
The BMOP DWP will be located in federal waters approximately 82 statute miles off the coast of Cameron Parish, Louisiana, in an approximate water depth of 162 feet. Crude oil for export at the BMOP DWP will originate from the existing onshore Energy Transfer Nederland Terminal in Jefferson County, Texas. Crude oil will be transported from the Nederland Terminal through a new 42-inch outer diameter (OD) onshore pipeline and the existing 36-inch OD Stingray Mainline to the offshore platform complex [Latitude: 28° 26’ 00.01” North, Longitude: 93° 00’ 15.23” West; 28.433333, -93.004167 in decimal degrees]. Crude oil carriers will moor at two catenary anchor leg mooring (CALM) buoys, connect the floating crude oil hoses, and then transfer the crude oil to the carriers for loading at the DWP. Up to 275 VLCCs are expected to load annually.
Each buoy will have a dedicated vapor collection system (VCS) on the platform that consists of an initial knockout drum prior to vapors entering one of two parallel (redundant) vapor flow pathways that contain both a filter and a detonation arrestor. Vapors from the VCS will be routed through a final liquids knockout drum prior to being routed to three vapor combustion units (VCUs) for emissions control. Dock safety skids and vapor blowers added to the WC 509 Platform Complex will allow the captured vapors from loading operations (expected 99% capture efficiency) to be controlled by VCUs that will have a minimum destruction and removal efficiency (DRE) for volatile organic compounds (VOCs) of 95%.
Based on the application information, the maintenance allowance (as defined in 40 CFR § 63.561) scenario shall apply only if both vapor collection pathways from the same buoy fail, preventing captured vapor from being successfully routed to the vapor combustion units during a loading cycle (as defined in 40 CFR § 63.561). Given potential challenges such as frequent clogging of filters and/or detonation arresters in the vapor collection system, maintenance activities (such as cleaning, repairs, or replacements) at the DWP may need to take place during loading cycles.
Of note, two separate operating scenarios for marine loading are identified in this permit:
- “Routine Operating Scenario” are normal loading operations when all components of the VCS and VCUs are fully functional;
- “Maintenance Allowance Scenario” when vapors cannot be captured in the VCS nor be routed to the VCUs, but are instead vented via the mast riser on the vessel being loaded directly to the atmosphere.
Both operating scenarios for marine loading are addressed in the Special Conditions section of the draft PSD permit and are based upon proposed site-specific operations of the DWP as represented in the permit application for the project. BMOP shall develop a written Operation and Maintenance Plan (O&M Plan) describing in detail a program of corrective action for various air pollution collection and control equipment and monitoring equipment, based on requirements in 40 CFR §63.564, used to comply with the emissions standards for each operating scenario. In addition, an Initial Performance Test (IPT) Plan for the capture and control systems will be developed and submitted to EPA for approval prior to initial startup of loading operations, in accordance with 40 CFR §§ 63.7(e) and 63.563(b) and (c).
To support the crude oil export loading operations, new components for oil service and other ancillary utility equipment will be installed at the WC 509 platform complex, including flares for pigging, microturbines, firewater pump, an emergency generator, and storage tanks. All emission sources at the BMOP DWP are summarized in Table 1 - List of Emission Sources of the draft PSD permit.
Facility Mailing Address: Blue Marlin Offshore Port LLC (BMOP) 1300 Main Street Houston, TX 77002
Proposed PSD Preconstruction Permit: Under the provisions of 40 CFR § 52.21, the BMOP DWP will be classified as a major stationary source for PSD purposes because the potential emissions of regulated air pollutants exceed 250 tpy of the major source threshold. Additionally, project increases in VOC (1329.46 tpy > 40 tpy), NOx (83.50 tpy > 40 tpy), CO (157.23 tpy > 100 tpy), PM2.5 (14.22 tpy > 10 tpy), and GHG (101,826.95 tpy > 75,000 tpy) exceed PSD significant emission rates (SER) as shown in the below emission summary table. Therefore, PSD review is required for VOC, NOx, CO, PM2.5, and GHG.
Proposed Title V Federal Operating Permit: The BMOP DWP will be a title V major source with proposed emissions exceeding the major source thresholds for VOC (1329.46 tpy > 100 tpy), CO (157.23 tpy > 100 tpy), and HAPs (74.85 tpy > 25 tpy), according to the definition in 40 CFR § 71.2. A summary of estimated emissions for each criteria air pollutant is provided in the below table.
BMOP Deepwater Port Sitewide Potential to Emit
| Air Pollutant | Proposed Allowable Emission Rates (tpy) | Major Source Modification SER and Significant Limit for GHG (tpy) | PSD Review | Title V Major Source |
| VOC | 1329.46 | 40 | Yes | Yes |
| NOX | 83.50 | 40 | Yes | No |
| CO | 157.23 | 100 | Yes | Yes |
| PM | 14.22 | 25 | No | No |
| PM10 | 14.22 | 15 | No | No |
| PM2.5 | 14.22 | 10 | Yes | No |
| SO2 | 14.54 | 40 | No | No |
| H2S | 0.55 | 10 | No | No |
| H2SO4 | < 0.01 | -- | -- | No |
| HAPs | 74.85 | -- | -- | Yes |
| GHG (CO2e) | 101,826.95 | 75,000 | Yes | -- |
| Table Notes: VOC: volatile organic compounds as defined in 40 CFR § 52.21(b)(50); NOx: total oxides of nitrogen; CO: carbon monoxide; SO2: sulfur dioxide; PM: total particulate matter, suspended in the atmosphere, including PM10 and PM2.5; PM10: total particulate matter equal to or less than 10 microns in diameter, including PM2.5; PM2.5: particulate matter equal to or less than 2.5 microns in diameter; H2S: Hydrogen sulfide; HAPs: hazardous air pollutant as defined in 112 of the CAA; GHG: greenhouse gases as defined in 40 CFR § 52.21(b)(49). | ||||
Permit Documents:
Starting on September 29, 2026, members of the public may review EPA’s administrative record for the BMOP DWP’s PSD preconstruction and title V operating permit actions. The administrative record includes the proposed draft permit, the statement of basis for the proposed permits, the permit applications, and additional data and supporting documentation for the permit action.
Access to electronic copies of the documents:
- Regulations.gov: 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-2026-1323 into the search box. Follow the online instructions on how to access the documents.
- EPA’s website: https://www.epa.gov/caa-permitting/air-permitting-deepwater-port-act-projects-south-central-region
Access to physical copies of the documents:
- Cameron Parish Library: 512 Marshall St, Cameron, LA 70631; phone: (337) 775-5421.
- EPA Region 6 Office: 1201 Elm Street, Suite 500, Dallas, Texas 75270; phone (214) 665-2732. Please call in advance to arrange viewing times.
Public Hearing:
The EPA will conduct an in-person public hearing to receive comments. The hearing will be held on Thursday, October 29, 2026, beginning at 6:00 p.m., at Cameron Parish Police Jury West Annex, 148 Smith Circle, Cameron, LA. During the hearing, all interested parties will have an opportunity to present oral statements, views, recommendations, opinions and information on the proposed permits.
Final Determination:
A final decision to issue or to deny a permit shall be made after all comments have been considered. Notice of the final decision shall be sent to each person who has submitted comments or requested notice of the final permit decision, provided the EPA has adequate contact information.