PUBLIC NOTICE PERMIT REVIEW SUMMARY

Permit Writer:	Slater Smith 			Date:	June 19, 2019

Company Name:	CITGO Petroleum Corporation, Meridian Terminal

Facility Location:	180 65th West Avenue
Meridian, MS 39307

Source Number:	1460-00006

County: 		Lauderdale

PROJECT DESCRIPTION
CITGO Petroleum Corporation, Meridian Terminal (CITGO) is a bulk fuel storage terminal. CITGO is applying for reissuance of Synthetic Minor Operating Permit (SMOP) 1460-00006. The facility has the potential to exceed the Title V threshold for volatile organic compound (VOC) and total hazardous air pollutant (HAP) emissions; however, the facility proposes limitations on VOC and HAP emissions consistent with 11 Miss. Admin. Code Pt. 2, R.2.1.C(29). CITGO proposes facility-wide limits on gasoline, diesel, denatured ethanol, and loading rack throughput, and will demonstrate compliance by recording the tank and loading rack throughputs facility-wide. 
EMISSIONS SUMMARY & TITLE V PROGRAM APPLICABILITY
Emission Totals by Year since Last Renewal (tpy)	
Permit Action	Year	NOx	CO	VOC	HAP	
Renewal	2010	5.38	13.46	57.28	3.02	
Modification	2013	5.38	13.46	63.37	3.36	
Renewal	2016	5.38	13.46	75.52	1.58	
The VOC and HAP emission changes are due to the change in throughputs of several of the facility’s storage tanks. Emission Points AA-010, AA-013, AA-014, and AA-096 saw an increase in throughput, while Emission Point AA-012 saw a decrease in throughput. As demonstrated above, the changes in emissions did not cause a breach of any regulatory threshold.
CITGO has the potential to exceed the Title V threshold for VOC and total HAP emissions; however, the facility will be defined as an Area source of HAP emissions by implementing limitations on VOC and HAP emissions consistent with 11 Miss. Admin. Code Pt. 2, R.2.1.C(29).
11 MISSISSIPPI ADMINISTRATION CODE PART 2, CHAPTER 1
The facility is subject to the standards for Opacity, and Emission Point AA-099 is subject to filterable particulate matter (PM) emission standards, but production size and operational maintenance should create a large margin of compliance with the standards. 

NEW SOURCE PERFORMANCE STANDARDS (NSPS)
Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) – Subpart Kb
CITGO has many storage tanks containing volatile organic liquids; however, the facility is not an affected facility because several tanks (Emission Points AA-001, AA-002, AA-003, AA-004, AA-005, AA-006, AA-007, AA-010, and AA-012) were constructed prior to July 23, 1984, and those that were constructed after do not meet either the capacity (Emissions Points AA-008, AA-011, AA-013, AA-014, and AA-096) or true vapor pressure (Emission Points AA-015, AA-016, and AA-017) requirements.
Standards of Performance for Bulk Gasoline Terminals - Subpart XX
CITGO is a bulk gasoline terminal with a loading rack that has a gasoline throughput greater than 19,997 gallons per day which is defined as an affected facility according to Subpart XX. The affected facility’s loading rack is controlled by a vapor combustion unit (Emission Point AA-099) per 60.502(a).
NATIONAL EMISSION STANDARDS OF HAZARDOUS AIR POLLUTANTS (NESHAPs)
National Emission Standards for Hazardous Air Pollutants for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities – Subpart BBBBBB
CITGO is a bulk gasoline terminal because the facility has a gasoline throughput greater than 20,000 gallons per day. CITGO was constructed prior to 2006 and is an Area source of HAP emissions. The facility is subject to and shall comply with all applicable requirements of Subpart BBBBBB. 
Emission Points AA-001, AA-002, AA-006, and AA-007 will comply with Table 1 to Subpart BBBBBB by complying with 40 CFR 63, Subpart WW; 63.1063(b). Operational requirements for floating roofs are presented via 63.1063(b).
Emission Points AA-010, AA-011, AA-012, and AA-096 are used to collect drained material that can be used to pump to storage. According to Subpart BBBBBB, gasoline storage tank or vessel means each tank, vessel, reservoir, or container used for the storage of gasoline, but does not include oil/water separators and sumps, including butane blending sample recovery tanks, used to collect drained material such that it can be pumped to storage or back into a process. Therefore, the emission points are not subject to Subpart BBBBBB.

SMOP LIMITATIONS, MONITORING, AND RECORDKEEPING REQUIREMENTS
The following limitations, monitoring, and recordkeeping requirements are expressed in the permit:
•	For the entire facility,
o	Maximum annual gasoline throughput shall not exceed 176,000,000 gallons per year (gal/yr).
o	Maximum annual diesel throughput shall not exceed 120,000,000 gal/yr.
o	Maximum annual ethanol throughput shall not exceed 26,400,000 gal/yr.
o	Maintain monthly records of the facility’s gasoline, diesel, and ethanol throughput.
o	Maintain an inspection log book.
o	Submit a semiannual report.
•	For Emission Points AA-002 and AA-006, shall install and maintain a storage tank pole float system as required by the “Storage Tank Emission Reduction Partnership program” between the Environmental Protection Agency and CITGO Petroleum Corporation.
•	For Emission Points AA-001, AA-002, AA-006, and AA-007, the permittee shall comply with Item 2(d) of Table 1 to Subpart BBBBBB by meeting the operational requirements of Subpart WW.
•	For Emission Point AA-099,
o	Ash and/or particulate matter from fossil fuel burning installations of equal to or greater than 10 million BTU per hour per heat input shall not exceed an emission rate as determined by E = 0.8808 * I-0.1667.
o	Limit emissions to the atmosphere from the vapor collection system due to the loading of liquid product into gasoline tank trucks to 35 milligrams of total organic compounds per liter of gasoline loaded, not to exceed 13.07 lb/hr and 57.27 tpy.
•	Shall not allow any total organic compounds vapors collected at one loading rack pass to another loading rack.
o	Shall ensure loadings of liquid product into gasoline tank trucks shall be limited to vapor-tight gasoline tank trucks using the procedures of 60.502(e), (f), and (g).
o	Shall be inspected each calendar month during the loading of gasoline tank trucks for total organic compounds liquid or vapor leaks. Detection methods incorporating sight, sound, or smell are acceptable.
o	Shall conduct performance tests referenced in 60.503, 63.11092(g).
o	Shall keep records of the tank truck vapor tightness documentation.
o	Shall keep the records of the test results for each gasoline cargo tank loading at the facility.
o	Shall keep records of each monthly leak inspection.
o	Submit a semiannual report to meet the requirements of 63.1109(a)(1), (2), (3).

PUBLIC PARTICIPATION
The 30-day public notice period began on June 26, 2019, with the publication of a notice in The Meridian Star.

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