PERMIT REVIEW SUMMARY
Permit Writer:	Ryan Ozment 			Date:	January 14, 2019
Company Name:	T and M Terminal Company
Facility Location:	355 Highway 588 East
Source Number:	0640-00025
County: 		Covington
PROJECT DESCRIPTION
T & M Terminal Company owns a pipeline breakout facility in Collins, Mississippi.  The site is a synthetic minor source and applied for reissuance in May 2005.  There are no modifications requested with this permit action.
The facility stores and transports refined petroleum products (i.e., gasoline, distillates, transmix) via pipeline only.  Emission sources consist of 10 tanks, two sumps, two emergency engines, and fugitive components.  Volatile organic compounds (VOC) are the primary emissions at the site, and these emissions surpass Title V thresholds when uncontrolled.  The facility has limited throughput and utilizes oxidation to reduce VOC emissions to below 100 tons per year.  
EXISTING SYNTHETIC MINOR LIMITATIONS
Facility Wide:
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10)
o	Limit throughput of gasoline to 1,600,452,000 gallons per year.
o	Limit throughput of diesel/jet kerosene to 1,066,968,000 gallons per year.
o	Operate and maintain equipment in a manner consistent with good air pollution control practices.
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11)
o	Record gasoline and diesel/jet kerosene fuel received and store monthly.
o	Report semi-annually all required monitoring.
o	Report all deviations within five days.
o	Reports must be certified by Responsible Official.
AA-013, AA-014, and AA-015:
•	11 Miss. Admin. Code Pt. 2, R. 1.3.B
o	Opacity limited to 40%.
AA-013:
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10)
o	Thermal oxidizer must be utilized while cleaning/degassing.
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11)
o	Record dates of cleaning events.
AA-014 and AA-015:
•	11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(a)
o	PM emissions limited to 0.6 pounds per million BTU.
NESHAP LIMITATIONS
40 CFR 63, Subpart BBBBBB (National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities):  This subpart applies to area source bulk gasoline terminals, pipeline breakout stations, pipeline pumping stations, and bulk gasoline plants.  T & M operates an area source pipeline breakout station; therefore, this subpart applies.  Affected sources of this subpart include gasoline storage tanks, gasoline loading racks, vapor collection-equipped gasoline cargo tanks, and equipment components in vapor or liquid gasoline service.  T & M’s pipeline breakout station includes gasoline storage tanks (AA-001 through AA-010) and equipment components in gasoline service.  Because the tanks have a capacity greater than 75 m3, the facility must do the following: (a) Reduce emissions of total organic HAP or TOC by 95 weight-percent with a closed vent system and control device, as specified in §60.112b(a)(3) of this chapter; or (b) Equip each internal floating roof gasoline storage tank according to the requirements in §60.112b(a)(1) of this chapter, except for the secondary seal requirements under §60.112b(a)(1)(ii)(B) and the requirements in §60.112b(a)(1)(iv) through (ix) of this chapter; and (c) Equip each external floating roof gasoline storage tank according to the requirements in §60.112b(a)(2) of this chapter, except that the requirements of §60.112b(a)(2)(ii) of this chapter shall only be required if such storage tank does not currently meet the requirements of §60.112b(a)(2)(i) of this chapter; or (d) Equip and operate each internal and external floating roof gasoline storage tank according to the applicable requirements in §63.1063(a)(1) and (b), except for the secondary seal requirements under §63.1063(a)(1)(i)(C) and (D), and equip each external floating roof gasoline storage tank according to the requirements of §63.1063(a)(2) if such storage tank does not currently meet the requirements of §63.1063(a)(1).  Typically, synthetic minor operating permits require annual reports, but Subpart BBBBBB requires semi-annual compliance reporting so the permit was modified to require such.
40 CFR 63, Subpart ZZZZ (National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines):  This subpart applies to stationary reciprocating internal compression-ignition engines (RICE) at major or area sources of HAP emissions.  T & M operates two emergency stationary RICE sources (AA-014 and AA-015); therefore, this subpart applies.  Because these are for emergency use only, requirements include restrictions for non-emergency use, maintenance requirements, and a requirement to minimize time at idle.  T & M will monitor the engine with a non-resettable hour meter and maintenance records.
NESHAP LIMITATIONS
40 CFR 60, Subpart K (Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978):  This subpart applies to storage vessels with a capacity greater than 40,000 gallons that contain petroleum liquids constructed, reconstructed, or modified between June 1973 and May 1978.  One storage vessel (AA-010) was constructed in October 1973, greater than 40,000 gallons, and contains gasoline; therefore, this subpart applies.  Tanks AA-001 through AA-009 were all constructed prior to June 1973; therefore, this subpart (as well as 40 CFR Subparts Ka and Kb) does not apply to those tanks.  This subpart requires T & M to operate AA-010 with a floating roof.  They will also be required to record the type of petroleum stored, period of storage, and vapor pressure.  
40 CFR 60, Subpart XX (Standards of Performance for Bulk Gasoline Terminals):  This subpart applies to loading racks at bulk gasoline terminals constructed or modified after December 1980.  T & M operates a pipeline breakout station rather than a bulk gasoline terminal; therefore, this subpart does not apply.  
PUBLIC PARTICIPATION
The 30-day public notice period began on January 23, 2019, with the publication of a notice in The News-Commercial and ends February 22, 2019.
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.