PERMIT REVIEW SUMMARY
Permit Writer:	Ryan Ozment			Date:	March 24, 2022
Company Name:	Gavilon Fertilizer LLC, Vicksburg Facility
Facility Location:	461 Haining Road
Source Number:	2780-00114
County: 		Warren
FACILITY DESCRIPTION
Gavilon Fertilizer LLC, Vicksburg Facility, owns and operates an existing dry and liquid bulk fertilizer storage and handling facility under SIC Code 5191 (Farm Supplies).  The facility receives dry fertilizer by barge and, through a series of conveyors, unloaders, and hoppers, transfers the fertilizer to the fertilizer storage warehouse.  From there, fertilizer can be loaded to trucks for transport off site.  Gavilon also operates an auger tunnel to (an enclosed system equipped with conditioners consisting of a shaft that moves from site to side and spins) where coatings/additives are sprayed on dry urea.  These additives/coatings may contain VOCs and/or HAPs.  The potential to emit of VOC exceeds 100 tons per year (tpy), and HAP emissions exceed 10 tpy (individual) and 25 tpy (combination).  The facility has taken limitations and monitoring/recordkeeping requirements to qualify as a Synthetic Minor source.  
PROJECT/PERMIT ACTION DESCRIPTION
The facility has applied to reissue the current Synthetic Minor Operating Permit.  The facility is currently required to limit fertilizer coating throughput and VOC/HAP content as well as facility wide limitations on throughput.  In this permitting action, DEQ is removing the facility wide limitations due to redundancy.  The throughput and content requirements will maintain the facility below Title V and HAP major source thresholds.  The facility has requested to increase the VOC/HAP content but decrease the throughput.  These changes will not affect the facility’s SMOP status.  Other changes to the permit include clarification for emission point descriptions and consolidation of emissions points to more accurately represent the site.  This permitting action also included adding the State standard for opacity.
EMISSION SUMMARY
Pollutant	Maximum Potential-to-Emit (tpy)	Proposed Allowable (tpy)	
PM	98.8	33.7	
PM10	71.0	24.2	
PM2.5	47.9	16.3	
VOC	2,372.9	97.5	
Total HAP	475.0	22.5	
Individual HAP	--	 9.0	

APPLICABLE/PROPOSED PERMIT LIMITATIONS
Limitations from Construction Permit issued June 3, 2016, and modified August 3, 2017 (11 Miss. Admin. Code Pt. 2, R. 2.2.B(10) and 11 Miss. Admin. Code Pt. 2, R. 2.2.B(11)):
•	Monitor and record the identity, characteristics, and quantity of VOC and/or HAP containing material used
•	Report deviations within five days
•	Submit certified annual monitoring report
11 Miss. Admin. Code Pt. 2, R. 2.2.B(10):
•	Coating/Additives ≤ 20,000 gallons per year
•	Coating/Additives VOC content ≤ 65.0% by weight
•	Coating/Additives Individual HAP content ≤ 6.0% by weight
•	Coating/Additives Combined HAP content ≤ 15.0% by weight
•	Coating/Additives density ≤ 15.0 lbs/gal
11 Miss. Admin. Code Pt. 2, R. 1.3.A: opacity limit ≤ 40%
11 Miss. Admin. Code Pt. 2, R. 1.3.B:  equivalent opacity limit ≤ 40%
11 Miss. Admin. Code Pt. 2, R. 1.3.F(1):  PM limited to below the amount determined by the relationship E = 4.1  p0.67 where “E” is the emission rate in pounds per hour and “p” is the process weight input rate in tons per hour.
11 Miss. Admin. Code Pt. 2, R. 2.9:  maintain records for a minimum of five years
NSPS APPLICABILITY
This facility does not include any equipment subject to New Source Performance Standards including boilers, engines, volatile organic liquid storage vessels.  This facility is also does not manufacture diammonium phosphate (40 CFR 60, Subpart V), superphosporic acid (40 CFR 60, Subpart U), wet-process phosphoric acid (40 CFR 60, Subpart T), or triple superphosphate plant (40 CFR 60, Subpart W) 
MACT APPLICABILITY
This facility does not include any equipment subject to MACT or NESHAP including boilers or engines.  This facility also does not manufacture phosphoric acid (40 CFR 63, Subpart AA) or phosphate fertilizer (40 CFR 63, Subpart BB).
PUBLIC PARTICIPATION
The 30-day public notice period began on June 10, 2022, with the publication of a notice in the Vicksburg Post and ends July 11, 2022.
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.