PERMIT REVIEW SUMMARY
Permit Writer:	Ryan Ozment 		Date:	March 31, 2020
Company Name:	Capline Pipeline Company LLC, Capline Collierville Tank Farm
Facility Location:	1000 Ft. East From the Intersection of
I-269 and Wingo Road
Source Number:	1780-00056
County: 		Marshall
FACILITY DESCRIPTION
Capline Pipeline Company has applied for a permit-to-construct a greenfield site in Marshall County.  The Capline Collierville Tank Farm will consist of four 11,340,000-gallon crude oil storage tanks and a 125 kW diesel-fired emergency engine.  The facility will be used to store a maximum of 420,000 barrels of crude oil a day with a maximum true vapor pressure of 10 psia.  The only other source of emissions will be a result of roof landings, tank cleanings, and fugitives.
PROJECT/PERMIT ACTION DESCRIPTION
This is a greenfield, true minor site.  The source will be one of the 28 listed source categories (“petroleum storage and transfer units with total storage capacity above 300,000 barrels”).  Because the maximum uncontrolled does not surpass 100 tons per year, PSD permitting is not applicable.  In addition, the facility will be a true minor source and not require an operating permit.
EMISSION SUMMARY
Pollutant	Emissions (tons/year)	
Particulate Matter (PM)	0.01	
Sulfur Dioxide (SO2)	0.02	
Nitrogen Oxides (NOX)	0.26	
Carbon Monoxide (CO)	0.06	
Volatile Organic Compounds (VOC)	45.101	
Total Hazardous Air Pollutants (HAP)	1.39	
1VOC has been calculated assuming one roof landing and one tank cleaning per year uncontrolled by a vapor combustion unit with ventilation for 168 hours.
APPLICABLE/PROPOSED PERMIT LIMITATIONS
Facility Wide
•	11 Miss. Admin. Code Pt. 2, R. 1.3.A:  ≤ 40% opacity
•	11 Miss. Admin. Code Pt. 2, R. 1.3.B:  ≤ 40% equivalent opacity
Tanks (Emission Points AA-001, AA-002, AA-003, and AA-004)
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10):  Do not store any volatile organic liquid with a maximum true vapor pressure greater than 11.1 psia; or comply with the applicable requirements of 40 CFR 60, Subpart Kb for tanks with a maximum vapor pressure greater than 11.1 psia.
Emergency Engine (Emission Point AA-005)
•	11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(a):  limit emissions of PM to less than 0.6 pounds per million BTU.
Roofing Landings, Tank Cleanings, and Fugitives (Emission Point AA-006)
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11): 
o	Record the number of events, hours of ventilation, and additional information that will support that emissions remain below 100 tons per year.
o	An uncontrolled roof landing and tank cleaning with a ventilation of 168 hours results in 21.65 tons of VOC per event.  With the maximum potential/proposed allowable of Emission Points AA-001 through AA-005 totaling 23.44 tons of VOC per year, that leaves 75.56 tons allowable in a year to remain below 100 tons per year.  This results in a maximum of 3.49 events allowable in a year (calculation shown below).
o	In the event the facility requires more than three roof landing and tank cleaning events, Capline must report to DEQ and demonstrate that VOC emissions have not surpassed 100 tons per year.

NSPS APPLICABILITY
40 CFR 60, Subpart Kb (Standards of Performance for Volatile Organic Liquid Storage Vessles (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984)—this subpart applies to Emission Points AA-001, AA-002, AA-003, and AA-004 because these tanks store volatile organic liquids, post-1984, and have a capacity larger than 19,813 gallons.  This subpart requires the facility to install and main and external floating roof.  The subpart has different requirements for different maximum true vapor pressures, and Capline will be required to meet those applicable standards.  The standard also includes requirements on measuring primary and secondary seal gaps and methods for monitoring the vapor pressure.
40 CFR 60, Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines)—this subpart applies to Emission Point AA-005 because it applies to stationary compression ignition internal combustion engines.  This requires the engine to meet the emission standards for new non-road engines and fuel standards for sulfur content and cetane index.  The facility will meet the emission standards by being required to purchase a certified engine.  Capline must also install a non-resettable hour meter on the emergency engine and record the emergency and non-emergency use.  The subpart describes what is and is not classified as emergency use and hours allowable for maintenance checks and more.
40 CFR 60, Subpart JJJJ (Standards of Performance for Stationary Spark Ignition Internal Combustion Engine)—this subpart does not apply because the proposed engine will be a compression ignition engine rather than spark.
40 CFR 60, Subpart XX (Standards of Performance for Bulk Gasoline Terminals)—this subpart does not apply because the facility is not a bulk gasoline terminal.
MACT APPLICABILITY
40 CFR 63, Subpart ZZZZ (National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines)—this subpart applies to Emission Point AA-005 because it applies to stationary reciprocating internal combustion engines at a major or area source of HAP emissions.  Emission Point AA-005 will meet the requirements of this subpart by meeting the requirements of 40 CFR 60, Subpart IIII.
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 does not apply because the facility is not a bulk gasoline terminal, pipeline breakout station, pipeline pumping station, or bulk gasoline plant.
PUBLIC PARTICIPATION
The 30-day public notice period began on April 9th, 2020, with the publication of a notice in the New Albany Gazette and ends May 11th, 2020.
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.