New EPA Filing Reveals 275-VLCC Annual Scale of Planned Blue Marlin Offshore Port

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The U.S. Environmental Protection Agency opened public review on September 28 for draft Clean Air Act permits covering Energy Transfer's proposed Blue Marlin Offshore Port, exposing new operational detail on the scale of the planned Louisiana offshore crude-export facility. EPA's permitting case assumes as many as 275 VLCC loadings annually from two CALM buoys connected to the converted West Cameron 509 platform complex, with crude supplied from Energy Transfer's Nederland Terminal through a new 37-mile, 42-inch pipeline and the repurposed 36-inch Stingray Mainline. The system is designed for crude flow of up to 80,000 barrels per hour, or 1.92 million barrels per day. EPA's draft permits remain subject to public comment through October 29 and are only one part of the approval process. MARAD and the Coast Guard issued the project's Final Environmental Impact Statement in July, but Blue Marlin has not yet received its federal deepwater-port license.

Blue Marlin Offshore Port • EPA Draft Permit Review

A crude export chain designed around direct VLCC loading offshore Louisiana

Instead of moving a partially loaded VLCC through a constrained ship channel and topping it off offshore, Blue Marlin is designed to receive crude by pipeline and fully load the tanker at sea.

DRAFT AIR PERMITS • PUBLIC COMMENT THROUGH OCTOBER 29, 2026
Annual Operating Case
275 VLCCs
Maximum annual vessel count used in EPA's permit record.
Crude Loading Rate
80K bbl/h
Published maximum design flow.
Daily Design Capacity
1.92M bbl
Approximately one full VLCC-scale parcel per day.
Water Depth
162 ft
Offshore platform area in federal waters.
Marine Loading Points
2 CALMs
Two catenary anchor leg mooring buoys.

How a barrel reaches the VLCC

Blue Marlin combines new onshore construction with repurposed offshore gas infrastructure rather than building an entirely new marine corridor.

1 • Supply Hub Nederland Terminal

Crude enters the Blue Marlin system from Energy Transfer's existing Nederland terminal in Jefferson County, Texas.

Bakken / WTI-type crude expected
→
2 • New Build 37-Mile Pipeline

A new 42-inch crude line would run from Nederland to Station 501 in Cameron Parish.

42-INCH OD
→
3 • Repurposed Offshore System Stingray → WC 509

The existing 36-inch natural-gas mainline would be converted for crude service and connected to the modified offshore platform complex.

EXISTING 36-INCH MAINLINE
→
4 • Marine Transfer CALM Buoy → VLCC

Subsea lines connect the platform to two offshore loading buoys. Floating crude and vapor-return hoses connect the selected buoy to the tanker.

CALM 1
CALM 2
2-MILLION-BARREL VLCC ≈ 25 Hours

Theoretical loading time at 80,000 barrels per hour.

275 × 2M-BARREL PARCELS ≈ 550M Barrels

Illustrative annual throughput if every modeled vessel loads two million barrels.

AVERAGED OVER 365 DAYS ≈ 1.51M bpd

Equivalent annual average under the same illustrative parcel assumption.

The Permit Reveals More Than an Emissions Number

EPA's record shows how the port is expected to operate, how its loading vapors would be controlled and what approvals still separate the project from construction and operation.
Project Layer Current Detail Operational Meaning Next Step / Limitation Status
EPA Air Permits Draft PSD preconstruction permit R6PSD-DWP-GA10 and draft Title V operating permit R6TV-DWP-GA10. Establishes proposed emission limits, controls, monitoring, testing and operating requirements for the offshore source. Public comments remain open through October 29. EPA must consider comments before issuing or denying final permits. Public Review
Deepwater-Port License MARAD and USCG published the Final Environmental Impact Statement in July 2026. The federal environmental review has reached its final EIS stage. A favorable Record of Decision and deepwater-port license are still required before the project can proceed as licensed. Still Pending
Annual Vessel Case 275 VLCCs EPA's operating assumptions use up to 275 loaded vessels annually. Equivalent to roughly one loading every 31.9 hours averaged across the full year. Actual throughput would depend on parcel sizes, weather, vessel scheduling and commercial utilization. Permit Basis
Loading System Two CALM buoys, subsea crude lines and floating hoses connected back to WC 509. Allows deep-draft tankers to load offshore without entering a shallow or constrained ship channel. Current project descriptions indicate approximately one VLCC-scale loading stream per day. Designed
Vapor Capture 99% Expected collection efficiency during routine operations. Displaced hydrocarbon vapor is returned from the tanker rather than vented directly during normal loading. Capture performance must be demonstrated through testing and monitored under the permit. Draft Requirement
Vapor Destruction Three VCUs with minimum 95% VOC destruction/removal efficiency. Captured loading vapor is combusted offshore at the platform. BMOP must submit an Initial Performance Test plan before startup. Control System
Redundancy Each buoy gets two parallel vapor pathways containing filters and detonation arrestors. A single pathway failure does not automatically require uncontrolled loading. EPA says the maintenance scenario applies only if both pathways serving the same buoy fail. 2 Paths / Buoy
Maintenance Scenario Vessel vapors may be discharged through the ship's mast riser if both vapor pathways for the active buoy are unavailable. Loading can continue under a defined maintenance allowance while vapor-control equipment is serviced. BMOP's permit application estimated up to 629 hours annually for this maintenance allowance. Special Scenario
Pipeline Reuse Existing 36-inch Stingray natural-gas infrastructure would be converted to crude service. Reuses an existing offshore corridor and WC 509 platform assets. A new 37-mile, 42-inch line is still required between Nederland and Station 501. Reuse + New Build
Commercial Anchor TotalEnergies signed a non-binding 2023 HOA covering four million barrels per month. Equivalent to roughly two full 2-million-barrel VLCC parcels monthly. The agreement was subject to definitive contracts and Energy Transfer taking a final investment decision. Non-Binding HOA
VOC 1,329.46 t/yr

Largest listed regulated pollutant by mass.

CO 157.23 t/yr

Potential allowable sitewide emission rate.

NOx 83.50 t/yr

Above the PSD significant emission rate.

HAPs 74.85 t/yr

Makes the facility a Title V major source.

GHG 101,827 t CO₂e

Potential-to-emit value used in PSD review.

629 Hours
The unusual operating detail buried in the permit application

BMOP's air-permit application estimated an annual maintenance allowance of 629 hours. During a qualifying maintenance scenario, when both vapor pathways serving the active buoy are unavailable, displaced loading vapor is modeled as uncaptured and may leave through the tanker's mast riser. EPA's September notice makes clear that this is not the routine operating mode.

Blue Marlin VLCC Throughput & Loading Calendar

Test what EPA's annual vessel count means for barrels exported, loading hours and the amount of calendar time available between tanker calls.

EPA's current permit case uses up to 275 VLCC loadings annually.
Default reflects the annual maintenance allowance estimated in BMOP's underlying air-permit application.
Default mirrors the 2023 non-binding TotalEnergies HOA.
Modeled Annual Crude
550M bbl
Annual calls multiplied by the selected average parcel.
Average Daily Throughput
1.51M bpd
Annual barrels averaged across the selected calendar.
Loading Time Per VLCC
25.0 h
Parcel size divided by the selected pumping rate.
Annual Pumping Hours
6,875 h
Pure crude-transfer time under the selected scenario.
Average Call Interval
31.9 h
Average calendar time available per tanker call.
Non-Pumping Window
6.9 h
Calendar interval minus theoretical pumping time.
Maintenance Allowance
7.2%
Selected maintenance hours as a share of the full calendar.
Offtake Share
8.7%
Selected monthly offtake annualized versus modeled throughput.
Operating Density A 275-call year leaves about 6.9 hours between theoretical 2M-barrel loading blocks

That residual period would have to absorb the average effect of vessel approach, hose connection, disconnection, turnover, weather and other non-pumping time if the facility operated as a single active loading stream. Actual operations can vary substantially from this simplified calendar.

Share of the Annual Calendar

Crude pumping
78.5%
Maintenance allowance
7.2%
Scenario model only. EPA's 275-VLCC figure is an annual permitting assumption, not a guaranteed throughput forecast. Not every tanker must carry exactly two million barrels, and actual loading schedules would depend on vessel size, weather, mooring operations, hose handling, maintenance, crude availability and commercial nominations. The model does not assume simultaneous loading at both CALM buoys.
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