INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
February 17, 2020

FOR:
Delta Terminal Inc
2081 Rear Harbor Industrial Road
Greenville, MS 38701    

FACILITY DESCRIPTION
Delta Terminal is a bulk fuel storage and transfer facility with a Standard Industrial Classification (SIC) code of 5171. Processes at the facility include transfer of gasoline and diesel from barges into storage tanks, blending gasoline and diesel with ethanol, biodiesel and other fuel additives, and transferring the blended product into tanker trucks.  The facility includes a barge unloading area, gasoline storage tanks, ethanol storage tanks, diesel fuel storage tanks, biodiesel tanks, a loading rack with three loading lanes, a vapor combustion unit (VCU), fuel additive storage tanks, storage tanks used for tank bottom clean-outs, small tanks for fuel additives/dye and a tank that stores water from the containment area.  The VCU is used to control air emissions during the loading of all gasoline tank trucks. Emissions are primarily in the form of volatile organic compounds (VOC) and hazardous air pollutants (HAPS). 

TITLE V SOURCE APPLICABILITY 
The facility is a major Title V source because the facility’s potential-to-emit of Volatile Organic Compounds (VOC) exceeds the Title V threshold of 100 tons per year.  The facility’s potential-to-emit Hazardous Air Pollutants (HAPs) also exceeds the Title V threshold of 25 tons per year for total HAPs and 10 tons per year for an individual HAP.  

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
Modified language with respect to NESHAP R and NSPS XX requirements have been included in this draft renewal permit.

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The facility is not one of the 28 categorical facilities listed in 40 CFR 52.21(b)(1)(i)(c)(iii); therefore, the PSD threshold for a major source is 250 tpy.  The potential emissions of VOC from the existing equipment at the facility does exceed 250 tpy and hence the facility is considered as an existing major source for PSD purposes.  The permit action is to reissue the Title V permit which will not trigger a Prevention of Significant Deterioration (PSD) Review.

CAM APPLICABILITY
40 CFR Part 64 specifies the requirements for CAM.  The general applicability of this rule can be found in 40 CFR 64.2 and requires a Title V source to comply with the CAM requirements if all three of the following criteria are met for a pollutant-specific emission unit (PSEU):

1.	The unit is subject to an emission limitation or standard for a regulated air pollutant other than exemptions under 40 CFR 64.2(b)(1);
2.	The unit uses a control device to comply with the standard; and
3.	The unit has pre-control emissions exceeding Title V major source threshold.

The bulk gasoline terminal loading rack with three loading lanes (Emission Point AA-009) has VOC emissions, which are controlled by the VCU (equipped with a 3.3 MMBTU/hr enclosed flare (Emission Point AA-010)). VOC emissions from these sources are limited to 35 milligrams of total organic compounds per liter of gasoline loaded. Since the pre-control emissions are greater than the Title V major source threshold for VOC, a CAM Plan is required for these sources. The facility has an existing CAM Plan requiring the permittee to monitor flame presence during loading events and perform regular VCU inspections.  The CAM plan is incorporated into the current Title V Operating Permit. 

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR 60 SUBPART Kb
The provisions of 40 CFR 60 Subpart Kb - New Source Performance Standards for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 (NSPS Kb) are applicable to storage vessels with a capacity greater than or equal to 75 cubic meters (m3) that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after July 23, 1984.  NSPS Kb does not apply to storage vessels with a capacity greater than or equal to 40,000 gallons storing a liquid with a maximum true vapor pressure less than 3.5 kilopascals (40 CFR 60.110 b (b)). Emission Points AA-008 and AA-011 each have capacities in excess of 40,000 gallons, but each vessel stores product (diesel) with a true vapor pressure that is less than 3.5 kilopascals. All other storage vessels at the facility were constructed prior to July 23, 1984.   Therefore, the provisions of NSPS Kb does not apply to any sources at the facility.  

40 CFR 60 SUBPART XX
The provisions of 40 CFR 60 Subpart XX - New Source Performance Standards for Bulk Gasoline Terminals (NSPS XX) are applicable to loading racks at bulk gasoline terminals which deliver liquid product into gasoline tank trucks that were constructed or modified after December 17, 1980. The permittee added a third loading rack in 1995 which resulted in the facility becoming an affected unit. To comply with the standard for VOC emissions below 35 milligrams of total organic compounds per liter of gasoline loaded, the facility operates a vapor combustion unit (VCU). In addition, loading of liquid product into gasoline tank trucks is limited to vapor-tight gasoline tank trucks.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
The facility is a Major Source of Hazardous Air Pollutants (HAP) since the facility has the potential to emit more than 25 tons per year of total HAPs and 10 tpy of an individual HAP.

40 CFR 63 Subpart R
The permittee is subject to Subpart R—National Emissions Standards for Hazardous Air Pollutants for Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout Stations, and shall comply with all applicable requirements.    Under 40 CFR 63, Subpart R, if the permittee demonstrates to the DEQ’s satisfaction that the results of the emissions screening factor (ET) for bulk gasoline terminals is less than 0.5, then the bulk gasoline terminal is exempt from most requirements of 40 CFR 63, Subpart R. The permittee has demonstrated to the DEQ that ET equals 0.14 for the facility. Therefore, the permittee is required to operate the facility and maintain recordkeeping to document that the facility parameters established in the screening equation have not been exceeded in accordance with 40 CFR 63.420(d). The facility does not handle reformulated or oxygenated gasoline containing 7.6 percent by volume or greater methyl tert-butyl ether (MTBE) and the facility’s loading racks are controlled with a vapor combustion unit. 

40 CFR 63 Subpart BBBBBB
The National Emissions Standards for Hazardous Air Pollutants for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities, 40 CFR Part 63, Subpart BBBBBB  establishes emission and operating limitations for HAP emissions from bulk gasoline terminals, pipeline breakout stations, pipeline pumping stations, and bulk gasoline plants located at an Area source for HAPs.  The facility is classified as a Major source for HAPs; therefore, NESHAP BBBBBB is not applicable to the facility.  

SPECIFIC APPLICABLE REQUIREMENTS
Emission Point AA-010 is subject to the state standards for PM and Opacity.  The only fuel that is being used by the VCU at the facility is natural gas.  Since natural gas is a clean burning fuel, the unit should have a large margin of compliance with the PM and Opacity standards. The only monitoring proposed for compliance demonstration for PM and Opacity for these units is recording the fuel type. 

The provisions of NSPS XX requires that the permittee show compliance with the emission limit of 35 milligrams of total organic compounds (TOC) per liter of gasoline loaded to the atmosphere from the vapor collection system due to the loading of liquid product into gasoline tank trucks by conducting a performance test within 60 days of achieving the maximum production rate at which the affected facility will be operated. This condition has already been met. After reviewing the performance test, the DEQ determined that a performance test conducted once every 5 years, (not to exceed 61 months between tests), in conjunction with the monitoring required by the CAM plan, is sufficient to show continuous compliance with the TOC limit. 

The CAM plan requires the presence of pilot flames at all times the VCU is in operation.  The permit includes onsite recordkeeping requirements to meet compliance with tank truck vapor tightness requirements. Recordkeeping and reporting to demonstrate compliance with the CAM Plan is also required. 

There are no other applicable requirements for the facility’s other insignificant activities listed in their Title V application.

Other requirements are tabularized below.

Emission Point(s)	Pollutant/ Parameter	Limit/Standard	Monitoring	
AA-000	HAP	Screening Equation less than 1.0, and less than 0.5	Monitoring of operations and recordkeeping	
AA-009 and       AA-010	VOC	35 mg of TOC per liter of gasoline	Performance stack testing	
	VOC	CAM Plan	Recordkeeping and reporting	
AA-010	PM	0.6 lbs/MMBtu	Monitoring of operations