PERMIT REVIEW SUMMARY
Permit Writer:	Ryan Ozment 			Date:	June 18, 2019
Company Name:	Murphy Oil USA Inc, Meridian Terminal
Facility Location:	6540 North Frontage Road
Source Number:	1460-00030
County: 		Lauderdale
FACILITY DESCRIPTION
Murphy Oil USA Inc., Meridian Terminal, operates a petroleum bulk storage facility.  The facility can receive and distribute approximately 19.2 million gallons a month of gasoline and distillates.  The emission points include many petroleum and additive storage tanks, loading rack with a vapor combustion unit, equipment leaks, and PCW vat.  The facility is an area source of HAPs.
PROJECT/PERMIT ACTION DESCRIPTION
Murphy Oil submitted a modification application in March 2019 due to a revised plan for new inventory.  Emission Point AA-017 was authorized to be constructed when the permit was reissued July 2018; however, the facility is proposing to construct a tank half the anticipated capacity.  The facility is also intending to construct three new tanks (Emission Points AA-023, AA-024, and AA-025).  Currently, the facility is limited to a maximum combined throughput of 230,000,000 gallons of gasoline in any consecutive 12-month period.  Because of the increase in emissions due to the addition of the tanks, the facility is proposing to decrease the gasoline throughput limitation to 220,000,000 gallons. 
EMISSION SUMMARY
Pollutant	Potential to Emit (tons/year)	
	Prior to Modification	Proposed	
Particulate Matter	0.4374	0.4374	
Sulfur Dioxide	0.1197	0.1197	
Nitrogen Oxides	7.9529	7.9529	
Carbon Monoxide	17.9422	17.9422	
Volatile Organic Compounds	95.6060	93.3352	
Total Hazardous Air Pollutants	3.5261	3.8438	
STATE STANDARDS
11 Miss. Admin. Code Pt. 2, R. 2.2.B(10):  While Murphy’s potential-to-emit VOC’s is 93 tons per year, a limit of 99 tons per year was incorporated into the previous reissuance.  Due to the changes in inventory, the throughput limit for gasoline will be decreased from 230,000,000 gallons per year to 220,000,000.  
NSPS APPLICABILITY
40 CFR 60, Subpart Kb (Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984):  this subpart applies to storage vessels containing volatile organic liquids greater than 19,813 gallons.  The proposed storage tank (Emission Point AA-017) will be subject to Subpart Kb due to its contents and size (4,200,000 gallons).  Emission Points AA-023 and AA-025 are not subject to Subpart Kb due to the exclusion for storage vessels greater than 39,890 gallons with a maximum true vapor pressure less than 0.5 psi, and Emission Point AA-024 is not subject to the subpart due to the exclusion for vessels between 19,813 and 39,890 gallons with a maximum true vapor pressure less than 2.2 psia (40 CFR 60.110b(b)).
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.  The loading rack was constructed before this date; therefore, the subpart does not apply.
MACT APPLICABILITY
40 CFR 63, Subpart BBBBBB (National Emission Standards for Hazardous Air Pollutants for Source Categories:  Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities):  this subpart applies to area sources of HAPs bulk gasoline terminals, pipeline breakout stations, pipeline pumping stations, and bulk gasoline plants. Murphy is considered an area source and a bulk gasoline terminal as defined in this subpart.   All equipment in gasoline service is subject to the regulation.  Emission Point AA-017 will meet the conditions of this subpart by complying with the conditions of 40 CFR 60 Subpart Kb.  This subpart has emission limits and management practices for loading racks and storage tanks.  There are also requirements for leak inspections, performance testing, continuous monitoring system installation, and recordkeeping.
PUBLIC PARTICIPATION
The 30-day public notice period began on July 25, 2019, with the publication of a notice in the Meridian Star and ends August 26, 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.