INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
April 10, 2025

GENERAL FACILITY INFORMATION
Facility Name:  TransMontaigne Operating Company LP, Collins Piedmont Terminal Number 2
Facility Address:  135 Highway 588 East, Collins, MS 39248    
County: Covington
SIC Code(s): 4226
NAICS Code(s): 493190  

APPLICATION SUMMARY 
Permit No.: 0640-00011
Permit Action:  Permit Renewal
Permit Folder: PER20240001
Application Receipt Date: 01/29/2024
Application Deemed Complete:  11/13/2024
CBI Submitted?: No	NSPS (Part 60): Subparts K, Kb
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 an existing bulk fuel storage terminal) in Collins, Mississippi (Covington County).  Operations at the facility fall within SIC Code 4225, 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. 0640-00011 that was previously issued August 20, 2019.  

TransMontaigne’s Collins Piedmont Terminal Number 2 is considered one source with the Collins Piedmont Terminal Number 1 (Air Operating Permit 0640-00016) with respect to the Title V and Prevention of Significant Deterioration (PSD) programs.  The potential-to-emit (PTE) from both terminals exceed 250 tons per year (tpy) of VOCs when emissions are 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, no butane 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 an area source of HAPS.  

Air emissions equipment at Terminal 2 consists of above ground storage tanks used primarily to store petroleum products received via pipeline. Butane has always been blended into gasoline at the facility.  Butane is blended into the bulk storage tanks (i.e. gasoline tanks) in order to enhance the Reid Vapor Pressure (RVP) of the gasoline.  To accomplish this, the butane is transferred directly from tank trucks into the gasoline tanks via piping from an offloading rack at the southwest end of the property.  There is currently no butane storage at the terminal. The 2017 construction permit had called for the construction of 18 new internal floating roof (IFR) above ground storage tanks and 18 new butane storage tanks on the property, along with a new truck rack that would serve as both loading and offloading capabilities.  The original intent was to store larger quantities of butane on the property to support blending for the 18 new gasoline tanks.  The original proposal from the customer did not ultimately end up going through, and therefore the new loading/unloading rack and 18 butane storage tanks were not constructed.  Of the 18 proposed IFR storage tanks, only three were constructed (AA-024, AA-025 and AA-026), and have stored distillate fuels since entering service, although they are also permitted to store gasoline.  The facility continues to blend butane as it had done originally, which is from the existing offloading rack via truck and injection directly into the storage tanks. A detailed list of the permitted emission sources is included in the table below.

Emission Point	Description	
AA-000	Bulk Gasoline Terminal	
AA-001	12,675,600 gallon, cone roof, distillate storage vessel (Tank # 5907).  	
AA-002	15,315,300 gallon, external floating roof, gasoline or lower vapor pressure product storage tank (Tank # 5908)	
AA-003	15,315,300 gallon, external floating roof, gasoline or lower vapor pressure product storage tank (Tank # 5909)	
AA-004	15,842,400 gallon, external floating roof, gasoline or lower vapor pressure product storage tank (Tank # 5910)	
AA-007	7,392,000 gallon, internal floating roof, gasoline or lower vapor pressure product storage tank (Tank # 5911)	
AA-008	7,392,000 gallon, internal floating roof, gasoline or lower vapor pressure product storage tank (Tank # 5912)	
AA-009	7,392,000 gallon, internal floating roof, gasoline or lower vapor pressure product storage tank (Tank # 5913)	
AA-010	7,392,000 gallon, internal floating roof, gasoline or lower vapor pressure product storage tank (Tank # 5914)	
AA-011	21,546 gallon, horizontal, PCW/distillate storage tank (Frac Tank).	
AA-012	12,182,772 gallon internal floating roof, gasoline storage tank (Tank #5915)	
AA-013	12,182,772 gallon internal floating roof, gasoline storage tank (Tank #5916)	
AA-014	12,182,772 gallon internal floating roof, gasoline storage tank (Tank #5917)	
AA-015	12,182,772 gallon internal floating roof, gasoline storage tank (Tank #5918)	
AA-016	11,421,312 gallon internal floating roof, gasoline storage tank (Tank #5919)	
AA-017	11,421,312 gallon internal floating roof, gasoline storage tank (Tank #5920)	
AA-018	8,756,370 gallon internal floating roof, gasoline storage tank (Tank #5921)	
AA-019	1,381,842 gallon internal floating roof, gasoline storage tank (Tank #5922)	
AA-020	376,026 gallon internal floating roof, gasoline storage tank (Tank #5923)	
AA-021	1,586,298 gallon internal floating roof, gasoline storage tank (Tank #5924)	
AA-022	16,800 gallon fixed roof Transmix tank (petroleum mixture consisting primarily of distillate) (Tank #Transmix A)	
AA-023	16,800 gallon fixed roof Transmix tank (petroleum mixture consisting primarily of distillate) (Tank #Transmix B)	
AA-024	12,181,932 gallon internal floating roof tank used to store refined petroleum liquids including gasoline, jet kerosene, distillate, or other refined petroleum liquids (Tank #5925)	
AA-025	12,181,932 gallon internal floating roof tank used to store refined petroleum liquids including gasoline, jet kerosene, distillate, or other refined petroleum liquids (Tank #5926)	
AA-026	12,181,932 gallon internal floating roof tank used to store refined petroleum liquids including gasoline, jet kerosene, distillate, or other refined petroleum liquids (Tank #5927)	
AA-044	Fugitive emissions from equipment in gasoline service and butane blending	
AA-045	16,800 gallon fixed roof Transmix (petroleum mixture consisting primarily of distillate) (Tank #Transmix C)	

TITLE V SOURCE APPLICABILITY 
As currently constructed and operating, the facility’s potential-to-emit (only Terminal 2 and both Terminal 1 and 2 together) exceeds the Title V threshold limit of 100 tons/year for Volatile Organic Compounds (VOCs). The facility is currently considered an area source of HAPs since the facility’s potential-to-emit hazardous air pollutants (HAPs) does not exceed the major source threshold of 25 tpy of total HAPs and 10 tpy for any individual HAP. 

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions (tpy)	PTE Emissions Combined (tpy)	
Particulate Matter (TSP)	n/a	n/a	
PM10	n/a	n/a	
PM2.5	n/a	n/a	
Sulfur Dioxide (SO2)	n/a	n/a	
Nitrogen Oxides (NOx)	n/a	n/a	
Carbon Monoxide (CO)	n/a	n/a	
Volatile Organic Compounds (VOC)	336.53	370.55	
Total Reduced Sulfur (TRS)	n/a	n/a	
Lead	n/a	n/a	
CFC/HCFC	n/a	n/a	
Total HAP	18.49	20.29	
Hexane (highest single HAP)	5.66	6.21	
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 has the potential to emit more than 250 tpy of VOC; therefore, it is an existing major stationary source under the PSD program.  This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
There are no actual or proposed modifications to the facility that are being addressed in the permit action. However, numerous changes to the permit were necessary since most of the construction under the 2017 PSD construction permit did not occur, therefore all permit conditions related to the proposed loading rack, which was primarily to be used for loading gasoline into trucks, were removed.

The applicable Part 63, National Emission Standard for Hazardous Air Pollutants (NESHAP), Subpart BBBBBB, was revised effective May 8, 2024, which made it necessary to add several new permit conditions to address the new requirements, including the following:
•	New condition 3.B.13 which limits the concentration of gasoline vapor above the floating roof 
•	New work practice standard condition 3.D.4 regarding the handling of gasoline to prevent spills/releases
•	New condition 5.B.15 requiring periodic monitoring of the LEL in the vapor space above the tanks floating roofs
•	New condition 5.B.16 requiring recordkeeping for LEL monitoring events 
•	New condition 5.C.9(e) requiring reporting results of LEL monitoring
•	New condition 5.B.11 regarding the current leak detection monitoring procedures, including an expiration date of May 8, 2027.
•	New condition 5.B.12, which outlines the new Subpart BBBBBB requirements for leak detection monitoring. The new procedures are optional until May 8, 2027, and mandatory thereafter.
•	New condition 5.B.13, which outlines new recordkeeping requirements for leak detection surveys conducted under condition 5.B.12 procedures.
•	New condition 5.B.14 which requires certain records of all equipment in gasoline service subject to leak detection monitoring.
•	New conditions 5.B.18, 5.B.19, 5.B.20, and 5.B.21 are additional recordkeeping requirements under Subpart BBBBBB including records of deviations, gasoline throughput, and electronic submittals.
•	Condition 5.C.8 regarding semiannual reporting was modified to include a termination date of May 8, 2027.
•	New condition 5.C.9 was added for semiannual reporting after May 8, 2027.
•	New condition 5.C.10 was added regarding electronic reporting requirements.
•	New condition 5.C.11 was added to include the requirement for submittal of a notification of compliance status.

Additionally, a new condition 5.B.17 was added to required basic recordkeeping for all roof landings for tanks permitted to store gasoline.

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 active control device as defined in 40 CFR 64.1 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 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 continues to be an area source of HAP emissions, and the facility is 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 continues to be an area source of HAP emissions, so the provisions of Subpart R are not applicable.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
•	40 CFR 60, Subpart K, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978 – The provisions of Subpart K are applicable to each storage vessel for petroleum liquids which has a storage capacity greater than 40,000 gallons.  The only storage vessels constructed during this period were Emission Points AA-001, AA-002, and AA-003 (1975).  Emission Point AA-001 only stores distillate fuel oil which does not meet the definition of a petroleum liquid in Subpart K; therefore, this storage vessel is not subject to the requirements of Subpart K.  Emission Points AA-002 and AA-003 both store gasoline and are subject to the requirements of Subpart K.
•	40 CFR 60, Subpart Ka, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984 – The provisions of Subpart Ka are applicable to each storage vessel with a storage capacity greater than 40,000 gallons that is used to store petroleum liquids for which construction is commenced after May 18, 1978.  None of the storage vessels at the facility were constructed during the applicable time period; therefore, the provisions of Subpart Ka are not applicable to any storage vessel at the facility.
•	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-004, AA-007 through AA-010, AA-012 through AA-021, and AA-024 through AA-041 all exceed the storage capacity threshold and are used to store gasoline and/or other organic liquids, therefore, these storage tanks are subject to the applicable requirements of Subpart Kb.

The storage tank identified as Emission Point AA-011 was constructed in 2002 and has a capacity of 21,546 gallons, but the liquid stored (distillate) has a vapor pressure less than 3.5 kPa at storage temperature and is therefore not subject to Subpart Kb requirements. 
The storage tanks identified as Emission Points AA-0022, AA-0023 and AA-045 have a capacity of less than 19,183 gallons and are therefore not subject to Subpart Kb.

•	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.  The loading rack at the terminal identified in the current Title V permit as Emission Point AA-043 was not constructed, therefore Subpart XX is not applicable to the facility.

SPECIFIC APPLICABLE REQUIREMENTS
The Collins Piedmont Terminal Number 2 is considered a contiguous and adjacent operation under common control with the Collins Piedmont Terminal Number 1.  The two facilities are considered one source when determining applicability to the Title V, PSD, and NESHAP regulations.  As such, the combined potential emissions from both facilities shall be used to determine program applicability.

Emission Points AA-024 through AA-043 are sources that were approved for construction under a PSD Construction Permit issued June 9, 2017.  After the permit was issued, the scope of the project changed, and the facility certified construction for Emission Points AA-024, AA-025, and AA-026 only. 

All of the new storage tanks addressed in the PSD Construction Permit are regulated under 40 CFR 60, Subpart Kb and are required to be constructed with an internal floating roof.  The new storage tanks have a VOC emission limit that applies during normal operation and another VOC emission limit that is applicable when the roof of a storage tank has been landed. Since only 3 of the proposed 18 tanks were constructed (Emission Points AA-024 through AA-026), the VOC limits for the tanks, and for tank landings, were reduced by the factor of 3/18.  To demonstrate compliance with these two emission limits, the facility will keep product storage, material throughput, and roof landing records that will be used to calculate the monthly emissions that are to be used to determine the 12-month rolling totals for the new tanks.  The facility is also required to maintain site-specific plans for determining accurate monthly emissions for VOC from all tanks used for gasoline blending, including determining the RVP when butane is blended with gasoline. 

The storage tanks identified as Emission Points AA-004, AA-007 through AA-010, AA-012 through AA-021 and AA-024 through AA-026 are subject to the requirements of Subpart Kb.  The facility will demonstrate compliance with the Subpart Kb requirements by completing visual inspections of the floating roofs and keeping the required records.

The storage tanks identified as Emission points AA-002 and AA-003 are subject to the requirements of 40 CFR 60 Subpart K. The facility will demonstrate compliance with the Subpart K requirements by the use of external floating roofs (EFR) and keeping the required records. The EFR on these tanks must be inspected in accordance with 40 CFR 63 Subpart BBBBBB with the associated recordkeeping.

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-024 through AA-026	VOC	≤24.77 tons/year on a 12-month rolling total basis (excludes tank landing emissions)	Follow site-specific monitoring plan, monitor throughputs and vapor pressure, and calculate monthly emissions and 12-month rolling totals	
	Tank Requirements VOC 	Install a fixed roof in combination with an internal floating roof with a mechanical shoe primary seal and a rim mounted secondary seal (BACT Requirement)	Keep records of tank design and conduct routine inspections per NSPS Subpart Kb and NESHAP BBBBBB	
	Roof Landing Requirements VOC	Tank design and work practice plan (BACT Requirement)	Comply with work practice plan to reduce emissions during roof landings	
	VOC	Roof landing emissions ≤22.15 tons/year on a 12-month rolling total basis	Keep records for roof landings and calculate monthly emissions and 12-month rolling totals	
	Product Storage Limitation	Limited to refined petroleum products 	Keep records of materials stored	
AA-007 through AA-010, AA-012 through AA-021, and AA-024 through AA-026	HAP	Concentration of gasoline vapor above the IFR limited to at or below 25 percent of the LEL 		
AA-044	HAPs	Equipment Leaks	Periodic inspections using AVO and instrumental methods	
AA-007 through AA-010, AA-012 through AA-021, and AA-024 through AA- 026	HAP	Vapor concentration limited to 25% of LEL	Annual LEL testing of vapor space