PERMIT REVIEW SUMMARY
Permit Writer:	Ryan Ozment 			Date:	June 8, 2018
Company Name:	Gavilon Fertilizer LLC, Greenville Facility
Facility Location:	1699 Harbor Front Road
Source Number:	2800-00140
County: 		Washington
PROJECT DESCRIPTION
Gavilon Fertilizer LLC, Greenville Facility owns and operates a dry and liquid bulk fertilizer storage and handling facility.  The facility is an existing source and has been considered exempt from construction and operating air permits based on potential emissions qualifying the site as a true-minor source.  The facility receives dry fertilizer by barge and, through a series of conveyors, unloaders, and hoppers, transfers the fertilizer to the fertilizer storage warehouse.  From there, fertilizer can be loaded to trucks for transport off site.  Gavilon has proposed adding an auger tunnel to this process (an enclosed system equipped with conditioners consisting of a shaft that moves from site to side and spins) where coatings are sprayed on dry urea.  This would allow for the facility to incorporate additives and/or coatings to the fertilizer.  These additives/coatings may contain VOCs and/or HAPs and will increase uncontrolled emissions to qualify as a Synthetic Minor source.  
On April 17, 2018, Gavilon submitted a Construction Permit application and Synthetic Minor Operating Permit Application to incorporate the above changes.  The facility has proposed an annual coating/additive usage limit and VOC/Total HAP/Individual HAP content limits.  The permit also includes facility wide limitation on VOC, total HAPs, and individual HAP.  Gavilon will demonstrate compliance with the facility wide limits by complying with the coating throughput and content limits proposed.  The permittee will demonstrate compliance with the coating limitations through monitoring and recordkeeping requirements.
SYNTHETIC MINOR LIMITATIONS
The following are facility wide limitations that have been incorporated into the permit:
•	VOC ≤ 99.0 tons per year;
•	Total HAP ≤ 24.0 tons per year;
•	Individual HAP ≤ 9.0 tons per year;
•	Coating/Additives ≤ 38,000 gallons per year;
•	Coating/Additives VOC content ≤ 40% by weight;
•	Coating/Additives Individual HAP content ≤ 5% by weight; and
•	Coating/Additives Combined HAP content ≤ 10% by weight.
The facility will maintain records of each coating and/or additive containing VOC and/or HAP at the site, the total gallons of each used on a monthly basis, VOC and/or HAP content of the material used, and the density of the coating/additive.
PUBLIC PARTICIPATION
The 30-day public notice period began on June 15, 2018, with the publication of a notice in the Delta Democrat Times and ends July 16, 2018.
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.