PERMIT REVIEW SUMMARY

Permit Writer:	Ryan Ozment 			Date:	May 22, 2017

Company Name:	Gavilon Fertilizer LLC, Vicksburg Facility

Facility Location:	461 Haining Road
Vicksburg, MS

Source Number:	2780-00114

County: 		Warren

PROJECT DESCRIPTION

Gavilon Fertilizer, LLC—Vicksburg (Gavilon) owns and operates a dry bulk fertilizer storage and handling facility.  Gavilon applied for a Permit to Construct on January 9, 2015, and it was issued on June 3, 2015.  Prior to the construction permit issuance, Gavilon was a true minor source.  Upon increasing the throughput of the plant and adding the capability to coat the dry fertilizer, the facility qualified as a Synthetic Minor source.  The Permit to Construct was issued with limits on volatile organic compound (VOC) content of the coating as well as the total annual usage to ensure the facility would not surpass Title V thresholds.  The permit also required that the facility apply for a Synthetic Minor Operating Permit within 12 months of issuance.

On April 26, 2016, Gavilon submitted both a Construction Permit Modification and Synthetic Minor Operating Permit Application.  The facility has determined that these limitations are too restrictive of operational flexibility and requests to modify the coating limitations to suit changing market conditions and consumer preferences.  Gavilon would like to establish facility wide emission limitations on VOC, total HAPs, and individual HAP, and demonstrate compliance through emission calculations and recordkeeping requirements.

EXISTING REQUIREMENTS VS. MODIFIED REQUIREMENTS

Existing	Modified	
The permittee shall limit the VOC content of liquid urease inhibitor to no more than 25 percent VOC by volume.	Removed and replaced with:
•	For the entire facility, the permittee shall limit volatile organic compound (VOC) emissions to no more than 99 tons per year (TPY) as determined for each consecutive 12-month period.  
•	For the entire facility, the permittee shall limit total hazardous air pollutant (HAP) emissions to no more than 24.0 tons per year (TPY) as determined for each consecutive 12-month period.
•	For the entire facility, the permittee shall limit hazardous air pollutant (HAP) emissions to no more than 9.0 tons per year (TPY) of any single HAP as determined for each consecutive 12-month period.  	
The permittee shall not use more than 86,086 gallons of liquid urease inhibitor per year, determined on a 12-month rolling basis.		
The permittee shall comply with the liquid urease inhibitor limitations by maintaining Safety Data Sheets (SDS) for each type or shipment on-site and keeping records of the gallons of inhibitor used for each month and for each consecutive 12-month period.	Removed and replaced with:
•	For the entire facility, the permittee shall maintain sufficient records to document: (a) the identification of each coating, adhesive, solvent or other VOC or HAP containing material and the total gallons of each coating, adhesive, solvent or other VOC or HAP containing material used on a monthly basis and in each consecutive 12-month period; (b) the VOC and HAP content(s) of each coating, adhesive, solvent or other VOC or HAP containing material used.  A description of the method used to determine the VOC and HAP content shall accompany this data; (c) the density of the coating, adhesive, solvent or other VOC or HAP containing material used; and (d) the total VOC emission rate, the emission rate of each individual HAP, and the total HAP emission rate in tons per year for each consecutive 12-month period.  The permittee may utilize data supplied by the manufacturer, or analysis of VOC and HAP content by EPA Test Method 24, 40 CFR 60, Appendix A and/or EPA Test Method 311, 40 CFR 63, Appendix A, and/or an alternate EPA approved test method.	
The permittee shall submit a complete Synthetic Minor Operating Permit application within 12 months of permit issuance.	Removed due to submitted SMOP application.	

PUBLIC PARTICIPATION

The 30-day public notice period began on June 30, 2017, with the publication of a notice in the The Vicksburg Post and ends July 31, 2017.

RECOMMENDATION

The staff has preliminarily decided to recommend issuance of the permit to the Mississippi Environmental Quality Permit Board as shown in the draft permit.  However, the staff recommendation to the Board will be made only after a thorough consideration of all public comments.