DRAFT PUBLIC NOTICE PERMIT REVIEW SUMMARY

Permit Writer:	Slater Smith 			Date:	August 20, 2019
Company Name:	Watco Transloading LLC, WTPS Amory Bulk Terminal
Facility Location:	101 Waterway Drive North
Amory, MS 38821
Source Number:	1840-00080
County: 		Monroe

FACILITY DESCRIPTION
Watco Transloading LLC, WTPS Amory Bulk Terminal (Watco – Amory) operates as a bulk materials transloading and storage facility, and a coal preparation and processing plant (SIC 4491 – Marine Cargo Handling). The facility was issued a Permit to Construct on November 15, 2013; however, a determination was made that the facility did not need a Permit to Operate. After re-examining Watco – Amory’s emissions, the facility requested a Synthetic Minor Operating Permit due to the facility’s potential to emit more than the major source threshold for Particulate Matter (PM), Particulate Matter less than 10 μm in diameter (PM10), and Sulfur Dioxide (SO2). 
Watco – Amory is located along the Tennessee – Tombigbee waterway at the Port of Amory as pictured in Image 1. Watco – Amory unloads calcine coke or iron ore from barges with Bucket Elevator #1 (Emission Point AA-006). The coke will be screened and crushed downstream of the dome after removal from storage. The coke or ore is conveyed to the rail loadout area for transfer (Emission Point AA-007).
The facility receives wet coal from barges and unloads the wet coal at Bucket Elevator #2 (Emission Point AA-002), which conveys to the screening process. The wet coal is loaded into a series of conveyors and screens before the drying processes (Emission Point AA-003). The thermal dryer (Emission Point AA-001) removes moisture from the coal. The coal is conveyed to another screen where coal is sorted by size and large coal is crushed before recycling through Emission Point AA-001. Dried and screened coal is conveyed to three storage silos (Emission Point AA-004) before loadout (Emission Point AA-005).
Also, Watco-Amory transloads other bulk material, e.g. sand, wood pellets, miscellaneous bulk materials and liquids, which generate air pollution emissions.
Watco – Amory has the potential to exceed the major source threshold for PM, PM10, and SO2; however, the facility has proposed limitations on throughput (ore, calcine coke, sand, wood pellets, coal, and other miscellaneous bulk materials and liquids) consistent with 11 Miss. Admin. Code, Pt. 2, Ch. 6 that will prevent PM, PM10, and SO2 emissions from exceeding the major source threshold. The facility will demonstrate compliance with the throughput limitations by keeping records of all aforementioned materials on a rolling 12-month basis.
	
Image 1. Aerial Photo of Watco Transloading LLC, WTPS Amory Bulk Terminal	
EMISSION SUMMARY & APPLICABLE/PROPOSED PERMIT LIMITATIONS 
Pollutant	Total Emissions  (tpy)	Title V Threshold (tpy)	Major Source (Yes/No)	
PM/PM10	3,216	100	Yes	
SO2	153.32	100	Yes	
NOx	21.55	100	No	
CO	3.38	100	No	
VOC	10.95	100	No	
Total HAP	0.08	25	No	
Table 1. Comparison of Maximum Uncontrolled Emissions Summary to Title V Threshold	

Pollutant	Total Emissions  (tpy)	Title V Threshold (tpy)	Major Source (Yes/No)	
PM/PM10	69.10	100	No	
SO2	49.00	100	No	
NOx	5.82	100	No	
CO	0.18	100	No	
VOC	43.77	100	No	
Total HAP	8.06	25	No	
Table 2. Comparison of Proposed Allowable Emissions Summary to Title V Threshold	
Watco – Amory has the potential to be a major source for PM, PM10, and SO2, as demonstrated in Table 1. The transloading facility will not exceed the major source thresholds if the facility utilizes baghouses to control PM and PM10 emissions and limits the throughput to control SO2, as seen in Table 2.

11 MISSISSIPPI ADMINISTRATION CODE PART 2, CHAPTER 1
Emission Point AA-001 is a 9.54 MMBtu/hr natural gas-fired dryer. The unit is subject to state standards for particulate matter, sulfur dioxide and opacity. Since natural gas is a relatively clean burning fuel, the unit should have a large margin of compliance with the PM, SO2 and Opacity standards.
STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES (NSPS) APPLICABILITY
Subpart Y – Standards of Performance for Coal Preparation and Processing Plants
Watco – Amory prepares more than 181 megagrams (200 tons) of coal per day by crushing, screening, and thermal drying. Therefore, Watco Transloading LLC, WTPS Amory Bulk Terminal is defined as a coal preparation and processing plant. Watco-Amory is subject to and shall comply with all applicable requirements of the Standards of Performance for Coal Preparation and Processing Plants (40 CFR 60, Subpart Y). 
The affected facility was constructed October 2008, and the natural gas-fired thermal dryer (Emission Point AA-001) was modified in 2013. Therefore, coal processing and conveying equipment (including breakers and crushers), and coal storage systems, transfer and loading systems are subject to the applicable standards of 60.250(c), and Emission Point AA-001 is subject to the applicable standards of 60.250(d). Watco-Amory receives anthracite coal; therefore, the facility does not clean coal and is not subject to any pneumatic coal-cleaning equipment requirements.

EMISSION LIMITATIONS, MONITORING, AND RECORDKEEPING SUMMARY
Emission Point(s)	Limitation	Monitoring/Recordkeeping	
	Applicable Requirement	Standard	Applicable Requirement	Standard	
Facility-Wide	11 Miss. Admin. Code Pt. 2, R. 1.3.A.	Opacity ≤ 40%	Wide Margin of Compliance	
	11 Miss. Admin. Code Pt. 2, R. 1.3.B.			
	11 Miss. Admin. Code Pt. 2, R. 1.3.F(1).	E = 4.1 p0.67		
	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).	Throughput Limit:
Ore ≤ 300,000 tpy
Coke ≤ 200,000 tpy
Sand ≤ 100,000 tpy
Wood Pellets ≤ 150,000 tpy
Coal ≤ 70,000 tpy
Bulk Transfers ≤ 150,000 tpy
Liquid ≤ 10,000,000 gal	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11).	Monitor and Record Throughput	
AA-001	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).	Pressure Drop Differential:
+/- 20 inches H2O range	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11).	Record Daily Baghouse Differential Pressure	
		Control Devices Shall Operate While Processing			
	40 CFR 60.252(b)(1)(ii)(A), (b)(1)(ii)(B), (b)(2)(i), (b)(3)(i), Subpart Y	PM ≤ 0.031 gr/dscf.	40 CFR 60.255(b)(1), Subpart Y
40 CFR 60.255(b)(2)(i), (ii), Subpart Y
40 CFR 60.255(f)(1), Subpart Y
40 CFR 60.258(a)(1), (2), (3), (5), Subpart Y	Perform Stack Tests	
		Opacity ≤ 20%			
		SO2 ≤ 0.20 lb/MMBtu			
		NOx + CO ≤ 1.0 lb/MMBtu		Develop and maintain a maintenance plan, visual observation and throughput logbook.	
AA-002
AA-003
AA-004
AA-005	40 CFR 60.254(b)(1), (b)(2), Subpart Y	Opacity ≤ 10%			
		PM ≤ 0.010 gr/dscf.			
AA-002
AA-003
AA-004
AA-005
AA-006
AA-007	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).	Control Devices Shall Operate While Processing	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11).	Record Daily Baghouse Differential Pressure	

PUBLIC PARTICIPATION
The 30-day public notice period began on August 27, 2019, with the publication of a notice in the Northeast Mississippi Daily Journal.
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.