PERMIT REVIEW SUMMARY

Permit Writer:	Chappell Kettleman	Date:	April 7, 2025

Company Name:	Ergon Refining, Inc., Fuels Terminal

Facility Location:	1585 Haining Road, Vicksburg, MS  39180

Source Number:	2780-00063

County: 		Warren

FACILITY DESCRIPTION

Ergon Refining, Inc.’s (Ergon) Fuels Terminal is an existing bulk fuel storage terminal which falls under the standard industrial classification (SIC) code of 5171. The facility stores gasoline, denatured ethanol, gasoline additives, and distillate fuel oils prior to loading cargo trucks. The facility receives gasoline and distillate fuel oils via barge; and the additives and denatured ethanol are received via cargo trucks.  

PROJECT/PERMIT ACTION DESCRIPTION

Ergon is classified as a synthetic minor source with respect to Title V of the Federal Clean Air Act. The facility has the uncontrolled potential to emit more than 100 tons per year of the criteria pollutant, Volatile Organic Compounds (VOC); however, Ergon requested limitations on facility-wide fuel(s) throughput consistent with 11 Miss. Admin. Code, Pt. 2, Ch. 6 to reduce the site-wide emissions below the Title V thresholds. Ergon utilizes internal floating roofs on seven (7) existing bulk fuel tanks and one (1) new, proposed bulk fuel tank. Ergon also operates a vapor combustion unit (VCU) to control emissions from the 3-bay truck loading rack. The internal floating roofs and VCU restrict VOC emissions below the Title V threshold of 100 tpy.

The facility does not have the potential to emit more than 100 tons per year (tpy) of any other criteria pollutant. The facility has the potential to emit more than 25 tpy of total hazardous air pollutants (HAP) or more than 10 tpy of any individual HAP, however with the fuel(s) throughput restriction and control mechanisms in place the facility will limit total HAP and individual HAP to less than the Title V threshold. The following table includes the existing and proposed emission sources at the facility.

Emission 
Point	Description	
AA-000	Bulk Fuel Terminal	
AA-002	1,176,000 gallon Gasoline or Distillate Fuel Oil Internal Floating Roof Storage Tank (Ref. Tank 2), built 1994	
AA-003	840,000 gallon Gasoline or Distillate Fuel Oil Internal Floating Roof Storage Tank (Ref. Tank 3), built 1994	
AA-004	630,000 gallon Gasoline or Distillate Fuel Oil Internal Floating Roof Storage Tank (Ref. Tank 4), built 1961	
AA-005	1,266,000 gallon Gasoline or Distillate Fuel Oil Internal Floating Roof Storage Tank (Ref. Tank 5), built 1985	
AA-006	1,266,000 gallon Gasoline or Distillate Fuel Oil Internal Floating Roof Storage Tank (Ref. Tank 6), built 1985
(Inoperable - Proposed for removal from permit)	
AA-007	1,266,000 gallon Gasoline or Distillate Fuel Oil Internal Floating Roof Storage Tank (Ref. Tank 7), built 1986	
AA-008	1,266,000 gallon Gasoline or Distillate Fuel Oil Internal Floating Roof Storage Tank (Ref. Tank 8), built 1992	
AA-009	1,266,000 gallon Gasoline or Diesel Internal Floating Roof Storage Tank (Ref. Tank 9), built 1996	
AA-012	10,000 gallon Additive Fixed Roof Storage Tank (Ref. Tank A-1)	
AA-013	8,000 gallon Additive Fixed Roof Storage Tank (Ref. Tank A-2)	
AA-014	4,000 gallon Additive Fixed Roof Storage Tank (Ref. Tank A-3)	
AA-015	2,000 gallon Additive Fixed Roof Storage Tank (Ref. Tank A-4)	
AA-016	1,000 gallon Additive Fixed Roof Storage Tank (Ref. Tank A-5)	
AA-018	Loading Rank with Three Loading Bays controlled by Vapor Combustion Unit 	
AA-020	2,000 gallon Additive Fixed Roof Storage Tank (Ref. Tank A-6) 	
AA-021	1,000 gallon Red Dye Fixed Roof Storage Tank (Ref. Tank A-7)	
AA-022	30,000 gallon Denatured Ethanol Fixed Roof Storage Tank (Ref. Tank 10), built 2010 	
AA-023	30,000 gallon Denatured Ethanol Fixed Roof Storage Tank (Ref. Tank 11), built 2010	
AA-024	30,000 gallon Denatured Ethanol Fixed Roof Storage Tank (Ref. Tank 12), Upon Construction	
AA-025	19,500 gallon Fixed Roof Petroleum Contact Water Storage Tank, built 2022	
Proposed
AA-026	1,266,000 gallon Gasoline or Distillate Fuel Oil Internal Floating Roof Storage Tank (Ref. Tank 6), built 2025	
Proposed
AA-027	Barge Loadout	
FUG-001 	Equipment in Gasoline Service Leaks	

EMISSION SUMMARY

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions (tons/yr)	
Particulate Matter (TSP)	0	
PM10	0	
PM2.5	0	
Sulfur Dioxide (SO2)	0	
Nitrogen Oxides (NOx)	3.84	
Carbon Monoxide (CO)	9.60	
Volatile Organic Compounds (VOC)	92.63	
Total HAP 	24	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

Ergon utilizes internal floating roofs on seven (7) existing bulk fuel tanks and on the new, proposed bulk fuel tank. Ergon also operates a VCU to control emissions from the truck loading rack. The internal floating roofs and VCU restrict facility-wide VOC emissions below the Title V threshold of 100 tpy and restricts facility-wide Total HAP emissions below the Title V threshold of 25 tpy.

MODIFICATIONS

Emission Point AA-006 was dilapidated and out of service when Ergon purchased the facility from Citgo Corporation in 2023. With this permit renewal and modification, Ergon proposes to remove the remaining structural components of Emission Point AA-006 and replace the bulk tank with an entirely new bulk fuel storage tank. The proposed replacement is identified as Emission Point AA-026 and is proposed to be the same size and capacity as former Emission Point AA-006. Ergon proposes to store diesel fuel and/or gasoline in the tank.

Ergon also proposes to install one (1) new diesel fuel barge loadout operation proposed as Emission Point AA-027. The existing dock at Ergon’s Fuels Terminal is currently only capable of barge receiving. Modifications to piping and associated components will allow Ergon to load out fuel (diesel fuel only) from the dock.

Other associated changes include receiving diesel fuel via a newly installed pipeline from the Ergon Refinery.  Diesel fuel received at the Fuels Terminal has historically been via barge. No new emission sources are projected to occur due to diesel fuel receipt via pipeline.

Emission Points AA-022, AA-023, and AA-024 are currently permitted to hold gasoline and denatured ethanol. Ergon has indicated that the only liquid stored in these emission points is denatured ethanol. The permit has been updated with this change.
For Emission Points AA-002, AA-003, AA-004, AA-005, AA-007, AA-008, and AA-009, 40 CFR 63, Subpart BBBBBB has been updated to include LEL testing and recordkeeping requirements per the updates to Subpart BBBBBB. 
For Emission Point AA-018, 40 CFR 63 Subpart BBBBBB was updated to include the LEL testing. 

NSPS APPLICABILITY

40 CFR 60 Subpart Kb
The provisions of 40 CFR 60 Subpart Kb - Standards of Performance for Volatile Organic 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) (19,813 gallons) that are used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after July 23, 1984, and on or before October 4, 2023. Emission Points AA-002, AA-003, AA-005, AA-007, AA-008, and AA-009 were each constructed after the NSPS effective date and each have a storage capacity greater than 19,813 gallons. Since each tank is permitted to store not only diesel fuel but also gasoline, which is a VOL, each tank is subject to the provisions of NSPS Kb. None of the facility’s other liquid product storage tanks are subject to the provisions of NSPS Kb.

AA-004 was constructed in 1961, therefore NSPS Kb is not applicable to AA-004. 

AA-022, AA-023, and AA-024 meet the applicability requirements and are subject to Subpart Kb depending on the vapor pressure of the liquid being stored. Ethanol and diesel do not trigger applicability but gasoline does trigger applicability. Denatured ethanol is the only chemical stored in the tanks, therefore the TVP is less than 15.0 kPa and thus AA-022, AA-023, and AA-024 are not subject to Subpart Kb unless they are used for something other than denatured ethanol.

40 CFR 60 Subpart Kc
The provisions of 40 CFR 60 Subpart Kc - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for which Construction, Reconstruction, or Modification Commenced After October 4, 2023 (NSPS Kc) are applicable to storage vessels with a capacity greater than or equal to 20,000 gallons (gal) (75.7 m3) that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after October 4, 2023. Emission Point AA-026 will be constructed after the NSPS effective date and will have a storage capacity greater than 20,000 gallons. Since the tank is proposed to be permitted to store not only diesel fuel but also gasoline, the tank will be subject to the provisions of NSPS Kc. Therefore, Emission Point AA-026 will be subject to the operating, monitoring, recordkeeping, and reporting requirements of Subpart Kc. The source will not be subject to Lower Explosive Limit (LEL) monitoring as long as the tank operates with diesel fuel, i.e., until the tank is filled with gasoline. 

None of the facility’s other liquid product storage tanks are subject to the provisions of NSPS Kc.

40 CFR 60 Subpart XX
The provisions of 40 CFR 60 Subpart XX - Standards of Performance for Bulk Gasoline Terminals That Commenced Construction, Modification, or Reconstruction After December 17, 1980, and On or Before June 10, 2022 (NSPS XX) are applicable to the total of all the loading racks at a bulk gasoline terminal which deliver liquid product into gasoline tank trucks. Emission Point AA-018 is a 3-bay truck loading that uses a VCU to collect and combust vapors from the truck loading rack. None of the facility’s other sources are subject to the provisions of NSPS XX.

MACT APPLICABILITY

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
The facility is an area source of Hazardous Air Pollutants (HAP) since the facility does not have the controlled potential to emit more than 25 tons per year of total HAPs or 10 tpy of any individual HAP.

40 CFR 63 Subpart BBBBBB - National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities
This subpart establishes national emission limitations and management practices for hazardous air pollutants (HAP) emitted from area source gasoline distribution bulk terminals, bulk plants, and pipeline facilities. This subpart also establishes requirements to demonstrate compliance with the emission limitations and management practices.

Emission Point AA-004 is subject to Subpart BBBBBB and as such is required to operate an internal floating roof per the requirements of Subpart BBBBBB. Emission Points AA-002, AA-003, AA-005, AA-007, AA-008, and AA-009 are subject to, and comply with, the control requirements of NSPS Kb. As such, each source is considered compliant with NESHAP BBBBBB, according to 40 CFR 63.11087(f).

Emission Point AA-018 is also subject to operating, monitoring, recordkeeping and reporting requirements of NESHAP BBBBBB.

PUBLIC PARTICIPATION

The 30-day public notice period began on , with the publication of a notice on the MDEQ website and ends .

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.