PERMIT REVIEW SUMMARY

Company Name:	Plains Marketing LP, Moss Point Rail Facility

Facility Location:	Highway 63 and Elder Ferry Road
Moss Point, MS  39563

Source Number:	1280-00142

County: 		Jackson

Permit Action:	Issuance of Construction Permit

PROJECT DESCRIPTION

Plains Marketing LP, Moss Point Rail Facility is a proposed petroleum liquids storage and transportation facility requesting an air construction and synthetic minor operating permit. The facility will be capable of receiving 24,000,000 barrels of petroleum liquids (excluding gasoline) per year by rail. Plains Marketing LP, Moss Point Rail Facility, which has a SIC code of 5171, consist of one (1) fire pump engine, four (4) storage tanks, and marine barge loading operation.

CONSTRUCTION PERMIT LIMITATIONS

Plains Marketing LP, Moss Point Rail Facility primary emissions will be VOCs coming from marine barge loading of petroleum liquids. The facility is requesting Synthetic Minor limitations in the construction permit to limit their potential to emit below Title V thresholds for VOCs. The permit contains the following limitations:

•	For Emission Points AA-002 through AA-005, the permittee shall limit the VOC emissions to no more than 37.98 tons per 12 month rolling total combined for all the storage tanks;
•	For Emission Point AA-006, the permittee shall only operate with the emissions routed to and controlled by the vapor combustion unit (VCU). The permittee shall maintain 99% destruction efficiency. 

Pollutant	 Uncontrolled Facility Emissions
(tons per year)	Controlled          Facility Emissions
(tons per year)	
Carbon Monoxide	0.07	55.89	
Nitrogen Oxide	0.34	23.60	
Volatile Organic Compounds	870.02	57.43	
Sulfur Dioxide	0.02	0.07	
Particulate Matter (PM10)	0.02	0.21	
Total HAPs	0.55	0.48	

For Emission Point AA-001, the permittee is subject to the New Source Performance Standard for Stationary Compressor Ignition Internal Combustion Engines in 40 CFR 60, Subpart IIII, and the General Provisions in Subpart A.  The following limitations apply under NSPS Subpart IIII for Emissions Point AA-001: 3.0 grams/horsepower-hour for NMHC+NOx, 2.6 grams/ horsepower-hour for CO, and 0.15 grams/horsepower-hour for PM.  The permittee meets the standards for 40 CFR 63, Subpart ZZZZ by complying with 40 CFR 60, Subpart IIII.  

The permittee shall operate and maintain the fire pump (AA-001) according to the manufacturer's written instructions and procedures.  In addition, the only settings that will be changed are those permitted by the manufacturer.  The permittee shall comply with the emission standards by purchasing an engine certified to the emission standards for the same model year and maximum engine power.  The engine shall be installed and configured according to the manufacturer's specifications.  Any operation of the fire pump other than emergency operation, maintenance, and testing will be prohibited.

For Emission Points AA-002 through AA-005, the permittee is subject to the New Source Performance Standard in 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 and the General Provisions in Subpart A. The permittee shall meet the specifications for external roof tanks in 40 CFR 60.112b(a)(2).  The permittee shall meet the testing requirements in 40 CFR 60.113b(b).  The permittee shall keep records and furnish reports according to 40 CFR 60.115b and 60.116b.

CONSTRUCTION PERMIT MONITORING

The permit contains the following monitoring, testing, recordkeeping and reporting to demonstrate compliance with the limitations in the permit:

•	The permittee shall maintain monthly records of the facility's throughput for petroleum liquids and tons/year of volatile organic compounds.  The permittee shall maintain these records on file at the facility for five (5) years and shall make them available upon request by Office of Pollution Control personnel;
•	The permittee shall keep records of all maintenance performed on the vapor combustion unit in order to operate in a manner consistent with good air pollution control practices to minimize emissions and shall make said records available upon request during an inspection visit by the MDEQ personnel;
•	The permittee shall monitor the vapor combustion unit to ensure that a flame is present at all times. The permittee shall monitor marine barge loading rate of crude oil. The permittee shall record anytime the facility is operated without a flame present and the corrective actions taken;
•	The vapor combustion unit shall be operated with a temperature between 1400 and 1500 degrees Fahrenheit. The permittee shall keep a record/log of temperature measurements and shall record anytime the vapor combustion unit is operated with the temperature below 1400 degrees Fahrenheit or above 1500 degrees Fahrenheit including any corrective action taken

PUBLIC PARTICIPATION

The 30-day public notice period began on May 3, 2013, with the publication of a notice in The Mississippi Press and ends June 3, 2013.

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.