PERMIT REVIEW SUMMARY

Permit Writer:	Jeffrey Bland 		Date:	March 31, 2026

Company Name:	TransMontaigne Operating Company LP, Greenville Clay Street

Facility Location:	310 Walthall Street, Greenville, MS 38701    

Source Number:	2800-00012

County: 		Washington

FACILITY DESCRIPTION

TransMontaigne Operating Company owns and operates a bulk fuel storage and transfer facility in Greenville, Mississippi. Fuels may include gasoline diesel, hexane, and other lower vapor pressure products. All gasoline is received via pipeline. The site contains two (2) truck loading racks that are controlled by a vapor combustion unit (VCU) and two (2) barge distillate loading docks that are not controlled.  Gasoline is stored in eight (8) storage tanks equipped with internal floating roofs. The facility also operates numerous other liquid product storage tanks for storage of the less volatile products; one (1) diesel-fired boiler, as well as fugitive emissions from equipment and components.  
PROJECT/PERMIT ACTION DESCRIPTION

The facility has the uncontrolled potential to emit more than 100 tons per year (tpy) of the criteria pollutant, Volatile Organic Compounds (VOC); however, the facility has requested limitations on facility throughput consistent with 11 Miss. Admin. Code, Pt. 2, Ch. 6 to reduce the site-wide emissions below the Title V thresholds. These throughput limits, in conjunction with the requirements of 40 CFR 63 Subpart BBBBBB for gasoline to be stored in tanks with internal floating roofs and for gasoline vapors from loading operations to be captured and destroyed with high efficiency, gives assurance that the facility emissions of VOC will be less than 100 tons per year.

The facility also has the uncontrolled potential to emit more than 10 tpy of the individual hazardous air pollutant (HAP), Hexane; however, since Emission Points AA-001 and AA-004 utilize a Vapor Combustion Unit (VCU) for compliance with 40 CFR 63, Subpart BBBBBB, Hexane emissions are restricted below the Title V threshold of 10 tpy. With the facility throughput limits included in the draft permit, and in conjunction with the requirements of 40 CFR 63 Subpart BBBBBB, the facility does not have the potential to emit more than 100 tpy of any other criteria pollutant or more than 25 tpy of total HAPs or more than 10 tpy of any other individual HAP. The following table includes the emission points at the facility.

Emission Point	Description	
AA-000	Entire Facility, Bulk Gasoline Terminal	
AA-001	North Truck Loading Rack and South Truck Loading Rack, each with emissions routed to Emission Point AA-004	
AA-002	North Barge Dock and South Barge Dock	
AA-003	12.554 MMBTU/hr Diesel-fired Boiler	
AA-004	Vapor Combustion Unit (VCU) for controlling emissions from Emission Point AA-001	
AT-001	420,000 gallon Liquid Product Internal Floating Roof Storage Tank for storing Gasoline or Lower Vapor Pressure Petroleum Product (Ref. T-24)	
AT-002	210,000 gallon Liquid Product Internal Floating Roof Storage Tank for storing Gasoline or Lower Vapor Pressure Petroleum Product (Ref. T-22	
AT-003	210,000 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-19)	
AT-004	126,000 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-18)	
AT-005	84,000 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-17)	
AT-006	210,000 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-20)	
AT-007	210,000 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-21	
AT-008	630,000 gallon Liquid Product Internal Floating Roof Storage Tank for storing Gasoline or Lower Vapor Pressure Petroleum Product (Ref. T-23	
AT-013	630,126 gallon Liquid Product Internal Floating Roof Storage Tank for storing Gasoline or Lower Vapor Pressure Petroleum Product (Ref. T-25)	
AT-014	630,000 gallon Liquid Product Internal Floating Roof Storage Tank for storing Gasoline or Lower Vapor Pressure Petroleum Product (Ref. T-26)	
AT-015	2,310,000 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Petroleum Product (Ref. T-15)	
AT-016	1,050,000 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-16	
AT-017	8,272 gallon Liquid Product Fixed Roof Storage Tank for storing Additive or Lower Vapor Pressure Product (Ref. A-3)	
AT-018	12,000 gallon Liquid Product Fixed Roof Storage Tank for storing Additive or Lower Vapor Pressure Product (Ref. A-1)	
AT-019	840,000 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-01)	
AT-020	634,116 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-02)	
AT-021	588,000 gallon Liquid Product Internal Floating Roof Storage Tank for storing Gasoline or Lower Vapor Pressure Petroleum Product (Ref. T-03)	
AT-022	546,000 gallon Liquid Product Internal Floating Roof Storage Tank for storing Gasoline or Lower Vapor Pressure Petroleum Product (Ref. T-04)	
AT-023	504,000 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-05).	
AT-024	767,760 gallon Liquid Product Internal Floating Roof Storage Tank for storing Hexane, Diesel, or Lower Vapor Pressure Product (Ref. T-06	
AT-025	714,000 gallon Liquid Product Internal Floating Roof Storage Tank for storing Gasoline or Lower Vapor Pressure Petroleum Product (Ref. T-07)	
AT-026	1,407,000 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel, Lower Vapor Pressure Product, or Fertilizer (Ref. T-08)	
AT-027	500,094 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-9)	
AT-028	2,205,000 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Petroleum Product (Ref. T-10)	
AT-029	30,000 gallon Liquid Product Fixed Roof Storage Tank for storing Heptane or Lower Vapor Pressure Petroleum Product (Ref. T-14)	
AT-030	975,954 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-11)	
AT-031	319,788 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-12)	
AT-032	319,788 gallon Liquid Product Fixed Roof Storage Tank for storing Diesel or Lower Vapor Pressure Product (Ref. T-13)	
AT-037	4,000 gallon Liquid Product Fixed Roof Storage Tank for storing Additive or Lower Vapor Pressure Product (Ref. A-2)	
AT-038	8,000 gallon Liquid Product Polyethylene Storage Tank for storing Additive or Lower Vapor Pressure Product (Ref. A-7)	
AT-040	1,092 gallon Liquid Product Fixed Roof Storage Tank for storing Additive or Lower Vapor Pressure Product (Ref. T-34)	
AT-041	10,152 gallon horizontal fixed roof polyethylene tank for storing miscellaneous chemicals (PCW) with vapor pressure of diesel or lower (Ref. PCW-1)	
AT-042

	10,152 gallon  horizontal fixed roof polyethylene tank for storing miscellaneous chemicals (PCW) with vapor pressure of diesel or lower (Ref, PCW-2)	
FUG-001	Fugitive Leaks from Equipment in Gasoline Service	

EMISSION SUMMARY

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions (tons/yr)	
Particulate Matter (TSP)	0.00	
PM10	0.60	
PM2.5	0.60	
Sulfur Dioxide (SO2)	1.41	
Nitrogen Oxides (NOx)	8.29	
Carbon Monoxide (CO)	7.42	
Volatile Organic Compounds (VOC)	77.42	
Total HAP 	9.46	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

The facility has requested federally enforceable limits on the throughput of the individual products managed at the facility. The following table includes the throughput limits.

Product	Throughput Limit	
Gasoline/Ethanol	100,000,000 gal/yr	
Additive 	5,000,000 gal/yr	
Distillate	260,000,000 gal/yr	
Methanol	500,000 gal/yr	
Heptane	2,100,000 gal/yr	
Hexane	2,000,000 gal/yr	
Synermax	1,500,000 gal/yr	
Glycerin 	1,000,000 gal/yr	
Sodium Hydrosulfide	3,000,000 gal/yr	
Fertilizer	2,100,000 gal/yr	

The draft permit also includes the requirements of 40 CFR 63 Subpart BBBBBB, which limits VOC and HAP emissions through requirements for a control device for vapors from the loading rack, requirements for floating roofs on gasoline storage tanks, and the requirement to implement an equipment leak detection and repair program.

PERMIT MODIFICATIONS

In addition to the new throughput limits on the various materials handled at the facility, substantial changes to permit requirements were necessary due to revisions/updates to40 CFR 63, Subpart BBBBBB, including the following:
•	Loading rack emissions are reduced from 80 mg/l gasoline loaded to 35 mg/l effective May 8, 2027.
•	Vapor concentration within the gasoline storage tanks above the floating roof ≤ 25 percent of the LEL. with associated monitoring, effective May 8, 2027.
•	New monitoring requirements for the VCU are effective May 8, 2027.
•	New leak detection and repair requirements with instruments are effective May 8, 2027,
•	New cargo tank testing requirements are effective May 8, 2027.
•	New recordkeeping and reporting requirements associated with the modifications listed above.
•	Two (2) existing 10,152-gallon poly tanks (Emission Points AT-041 and AT-042) storing Petroleum Contact Water (PCW) were added to the permit.
•	Emission Point AT-039, facility reference Tank-33, was removed from the permit since it was never constructed/does not exist.
•	Requirements under 40 CFR 60 Subpart Dc were removed from the permit since the facility provided documentation that the boiler was constructed in 1965 and has not been modified or reconstructed.
•	Condition 3.3 was modified to include clarity that storage of any chemical that is not listed within the condition is prohibited.
•	Condition 3.3 was modified to revise the term ‘gasoline’ to ‘gasoline/ethanol’ in order to accommodate the terminal receiving and transferring gasoline blended with ethanol for distribution.

NSPS APPLICABILITY

40 CFR 60 Subpart Ka - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after May 18, 1978 and Prior to July 23, 1984
The provisions of NSPS Ka are standards applicable to storage vessels with a capacity greater than or equal to 40,000 gallons that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after May 18, 1978.  Each of the facility’s storage tanks are exempt from the requirements of NSPS Ka, based on tank size, construction date, or vapor pressure requirements for the stored liquid products. The facility was constructed prior to 1978. 

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
The provisions of NSPS Kb are standards 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.  Each of the facility’s storage tanks are exempt from the requirements of NSPS Kb, based on tank size, construction date, or vapor pressure requirements for the stored liquid products.  

40 CFR 60 Subpart XX - Standards of Performance for Bulk Gasoline Terminals
The provisions of NSPS XX apply to the loading racks at a bulk gasoline terminal which deliver liquid product into gasoline tank trucks for which construction or modification commenced after December 17, 1980.   While the facility operates two (2) truck loading operations that are controlled by a VCU, the facility has not reconstructed or modified these operations since the NSPS XX effective date.  Therefore, the facility is not subject to any requirements of NSPS XX.

40 CFR 60 Subpart Dc - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units
The provisions of NSPS Dc are applicable to each steam generating unit for which construction, modification, or reconstruction commenced after June 9, 1989 and that has a maximum design heat input capacity of 29 megawatts (MW) (100 MMBTUH) or less, but greater than or equal to 2.9 MW (10 MMBTUH).  The 10.043 MMBTUH diesel-fired boiler (Emission Point AA-003) was constructed in 1965 and installed at the Greenville facility in 2005 as a 502(b)(10) modification to the Title V permit. Since the boiler has not been modified or reconstructed it is not subject to the requirements of Subpart Dc.

MACT APPLICABILITY

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

40 CFR 63 Subpart R - National Emission Standards for Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout Stations)
The provisions of 40 CFR Part 63, Subpart R apply to bulk gasoline terminals that are Major Sources for HAP emissions. While the facility is a Bulk Gasoline Terminal, the facility is an area source; therefore, the facility is not subject to any requirements of 40 CFR Part 63, Subpart R.   

40 CFR 63 Subpart Y - National Emission Standards for Marine Tank Vessel Loading Operations
The provisions of 40 CFR Part 63, Subpart Y apply to bulk marine tank vessel loading operations that are Area and Major Sources for HAP emissions.  The facility operates two (2) marine tank vessel loading operations, however, the facility is an existing area source and not subject to the emission standards of the Subpart.  The subpart does require existing area source marine loading facilities to calculate and maintain records of HAP emissions and requires loading at the marine docks to be conducted via submerged fill.  These are the only applicable requirements of NESHAP Y to the facility.

40 CFR 63 Subpart BBBBBB - National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities
The provisions of 40 CFR Part 63, Subpart BBBBBB establishes national emission limitations and management practices for HAPS 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.  Since the facility is an area source and is a Bulk Terminal, the facility is subject to the requirements of 40 CFR Part 63, Subpart BBBBBB.  The facility submitted the required Notice of Compliance Status for affected units in January 2011.

Emission limitations and operating requirements are included for the truck loading operations, including the VCU controlling emissions, and for the storage tanks in gasoline service. Due to the updated Subpart BBBBBB requirements promulgated on May 8, 2024, the draft permit contains new requirements which will become effective May 8, 2027, including concentration limits and monitoring of vapor space LEL in gasoline storage tanks, more stringent monitoring requirements for the VRU, more stringent cargo tank testing and more stringent leak detection and repair requirements.

40 CFR 63 Subpart JJJJJJ - National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources
The provisions of 40 CFR Part 63, Subpart JJJJJJ establishes requirements for industrial, commercial, or institutional boilers that are located at an area source of HAPs.  The 12.043 MMBTUH diesel-fired boiler (Emission Point AA-003) qualifies as an existing industrial boiler located at an area source; therefore, the boiler is subject to the operating requirements of NESHAP JJJJJJ, which includes a 1-time energy assessment and biennial tune-ups.  The facility has completed the 1-time energy assessment.

PUBLIC PARTICIPATION

The 30-day public notice period began on April 22, 2026, with the publication of a notice MDEQ website and ends May 22, 2026.