INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
December 9, 2025

GENERAL FACILITY INFORMATION
Facility Name: TransMontaigne Operating Company LP, Collins Piedmont Terminal Number 1
Facility Address:  135 Highway 588 East, Collins, MS 39428    
County: Covington
SIC Code(s): 5171
NAICS Code(s): 486910  

APPLICATION SUMMARY 
Permit No.: 0640-00016
Permit Action: Renewal without modification
Permit Folder: PER20240001
Application Receipt Date: January 31, 2024
Application Deemed Complete: 10/21/24
CBI Submitted?: No	NSPS (Part 60): N/A
NESHAP (Part 61): N/A
NESHAP (Part 63): Subpart BBBBBB
112(r) / RMP: N/A
Other: N/A	

FACILITY DESCRIPTION
TransMontaigne Operating Company owns and operates the Collins Piedmont Terminal Number 1, an existing bulk fuel storage facility (or terminal) in Collins, Mississippi (Covington County).  Operations at the facility fall within SIC Code 4226, General Warehousing and Storage, and NAICS Code 493190, Other Warehousing and Storage.  The purpose of this permit action is to renew Title V Operating Permit (TVOP) No. 0640-00016 that was previously renewed August 20, 2019.

TransMontaigne’s Collins Piedmont Terminal Number 1 is considered one source with the Collins Piedmont Terminal Number 2 (Air Operating Permit 0640-00011) with respect to the Title V and Prevention of Significant Deterioration (PSD) programs. The potential-to-emit (PTE) from both terminals exceeded 100 tons per year (tpy) of VOCs when emissions were combined.  Terminal 2 was issued a PSD Construction Permit in 2017. The PSD permit issued to Terminal 2 requires the facility to keep up to date records concerning emissions as equipment is constructed to determine if/when the major HAP source threshold is exceeded, which must also include the emissions from Terminal 1. Construction under the 2017 PSD permit concluded in 2019 with the addition of only three rather than 18 gasoline storage tanks, and no loading rack. The additional emissions did not result in the combined terminals HAP emissions exceeding the Title V major source threshold; therefore, the facilities continue to be area sources of HAPS.  

Air emissions equipment at Terminal 1 consists of above ground storage tanks used primarily to store petroleum products received via pipeline. A detailed list of the permitted emission sources is included in the table below.

Emission Point	Description	
AA-000	Bulk Gasoline Terminal	
AA-001	8,442 gallon fixed roof, distillate storage tank (Tank #5960) [Insignificant Activity]	
AA-002	1,580,000 gallon internal floating roof, gasoline storage tank (Tank #5961)	
AA-003	1,580,000 gallon internal floating roof, gasoline storage tank (Tank #5962)	
AA-004	2,352,000 gallon internal floating roof, gasoline storage tank (Tank #5963)	
AA-005	2,352,000 gallon internal floating roof, gasoline storage tank (Tank #5964)	
AA-006	17,640 gallon fixed roof, distillate storage tank (Tank #5965) [Insignificant Activity]	
AA-007	17,640 gallon fixed roof, distillate storage tank (Tank #5966) [Insignificant Activity]	
AA-008	Emissions from internal floating roof landing events for Emission Points AA-002 through AA-005	
AA-009	Fugitive emissions from equipment in gasoline service	

TITLE V SOURCE APPLICABILITY 
The facility’s PTE (Terminal 1 and 2 combined) exceeds the Title V threshold of 100 tons/year for Volatile Organic Compounds (VOCs).   The facility is currently considered an area source of HAPs

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions (tons/yr)	
Particulate Matter (TSP)	-	
PM10	-	
PM2.5	-	
Sulfur Dioxide (SO2)	-	
Nitrogen Oxides (NOx)	-	
Carbon Monoxide (CO)	-	
Volatile Organic Compounds (VOC)	34.02	
Total Reduced Sulfur (TRS)	-	
Lead	-	
CFC/HCFC	-	
Total HAP	1.80	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed 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)(a); therefore, the PSD threshold for a major source is 250 tpy.  The facility emissions, when combined with contiguous Terminal No. 2 emissions, have the potential to exceed 250 tons per year of VOC; therefore, the facility is considered a major stationary source.  This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
There are no modifications to the facility proposed as part of this permitting action. Emission Point AA-000 was changed to reference the bulk gasoline terminal facility, and equipment leaks were designated as Emission point AA-009. The requirements of Condition 3.B.2 of the previous permit were moved to condition 3.D.1. 

Some permit language regarding future applicability of HAP major source requirements was removed since the construction under the PSD permit issued facility remained an area source of HAP. However, the following changes were made to the permit to incorporate the recent updates to 40 CFR 63, Subpart BBBBBB, National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities, and to incorporate other applicable requirements:
•	Old condition 3.B.2 was moved to condition 3.D.1
•	Condition 3.B.3 was added to incorporate the requirement to limit the concentration of gasoline vapors above the floating roof.
•	Condition 3.D.2 was added to incorporate new general requirements of Subpart BBBBBB.
•	Condition 5.B.10 was added to incorporate new equipment leak monitoring requirements of Subpart BBBBBB.
•	Condition 5.B.11 was added to incorporate new equipment leak recordkeeping requirements of Subpart BBBBBB
•	Old condition 5.B.3 regarding malfunctions was removed due to revision of Subpart BBBBBB.
•	Conditions 5.B.6 and 5.B.7 were added to incorporate the new LEL monitoring and recordkeeping required by Subpart BBBBBB.
•	Condition 5.B.12 was added to incorporate the requirement for records of equipment in gasoline service under Subpart BBBBBB
•	Condition 5.B.1 was added to incorporate new recordkeeping requirements for deviations.
•	Condition 5.B2 was added to incorporate the requirements for gasoline throughput under Subpart BBBBBB.
•	Condition 5.B.3 was added to require recordkeeping regarding landing events for the floating roof tank systems.
•	Condition 5.B.8 was added to incorporate electronic reporting requirements under Subpart BBBBBB.
•	Condition 5.C.1 was modified by adding new reporting requirements prior to May 8, 2027, and adding the requirement for an excess emissions report which was old permit condition 5.C.2.
•	Condition 5.C.2 was added to incorporate the requirements for semiannual reports after May 8, 2027.
•	Old condition 5.C.3 regarding reporting of malfunctions was removed.
•	Condition 5.C.3 was added to incorporate electronic reporting requirements.
•	Condition 5.C.4 was added to incorporate Notification of Compliance Status.
•	Condition 5.C.5 was added to the permit to incorporate the notification requirement of Subpart BBBBBBB for refilling a tank following a repair.in accordance with 40 CFR 60.113b(a)(5), incorporated by reference in Subpart BBBBBB. 
•	Condition 5.C.6 was added to require annual reporting of information regarding floating roof landing events.

COMPLIANCE ASSURANCE MONITORING (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.

There is no control equipment associated with any emission units subject to an emission limit or standard at this facility, so Compliance Assurance Monitoring does not apply.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
•	40 CFR 63, Subpart BBBBBB, NESHAP for Source Category: Gasoline Bulk Terminals, Bulk Plants, and Pipeline Facilities – The provisions of Subpart BBBBBB are applicable to area source gasoline distribution bulk terminals, bulk plants, and pipeline facilities.  The facility is currently an area source of HAP emissions, and the facility, including gasoline storage tanks identified as Emission Points AA-002 through AA-005 and equipment leaks of gasoline, identified as Emission point AA-009, are subject to the applicable requirements of Subpart BBBBBB.
•	40 CFR 63, Subpart R, NESHAP for Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout Stations) – The provisions of Subpart R are applicable to bulk gasoline terminals or pipeline breakout stations that are located at a major source of HAP emissions.  The facility is currently an area source of HAP emissions, so the provisions of Subpart R are not applicable.
Equipment that is subject to Subpart BBBBBB is only subject to the applicable requirements when storing gasoline. If the equipment is storing any fuels that are not applicable to requirements in this subpart then the equipment is not subject to the applicable conditions from Subpart BBBBBB of this permit.  
NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
•	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 Subpart Kb are applicable to each storage vessel with a capacity greater than or equal to 75 cubic meters (19,813 gallons) that is used to store volatile organic liquids. The storage tanks identified as Emission Points AA-001, AA-006, and AA-007 do not exceed the storage capacity threshold and were constructed prior to July 1984; therefore, they are not subject to the requirements of Subpart Kb. The storage tanks identified as Emission Points AA-002 through AA-005 exceed the storage capacity threshold and are used to store gasoline or other organic liquids. However, these tanks were constructed prior to July 1984, and only modifications resulting in a decrease to potential emissions have occurred since this time (i.e., conversion from external to internal floating roofs which also did not meet the definition of reconstruction per 40 CFR 60.15); therefore, they are not subject to the requirements of Subpart Kb. 

•	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 – All tanks at the facility were constructed prior to May 18 1978; therefore, they are not subject to the requirements of Subpart Ka.

•	40 CFR 60, Subpart XX, Standards of Performance for Bulk Gasoline Terminals – The provisions of Subpart XX are applicable to the loading racks located at a bulk gasoline terminal which deliver liquid product into gasoline tank trucks.  There is not a loading rack at the terminal; therefore, the provisions of Subpart XX are not applicable to this facility.

SPECIFIC APPLICABLE REQUIREMENTS
There are no specific mass emission limits, however, VOC emissions are minimized through the following requirements:
•	tank design and inspection requirements,
•	gasoline vapor concentration in the space above the floating roof is limited to 25% of the LEL with annual monitoring and repair requirements, and 
•	equipment leak inspection and repair provisions of Subpart BBBBBB.

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-002 through AA-005	VOC	Leak detection and repair	Periodic inspections using AVO and instrumental methods	
	VOC	Design and operating requirements	Periodic inspection of floating roof and components	
	VOC	Vapor concentration limited to 25% of LEL	Annual LEL testing of vapor space