PERMIT REVIEW SUMMARY

Permit Writer:	Laura James 				Date:	November 10, 2020

Company Name:	MGC Terminal LLC

Facility Location:	101 65th Avenue

Source Number:	1460-00009

County: 		Lauderdale

FACILITY DESCRIPTION

MGC Terminal LLC is an existing bulk fuel storage facility which has a standard industrial classification (SIC) code of 4226, for special warehousing and storage, not otherwise classified.  The facility stores and transfers gasoline, denatured ethanol, petroleum distillate and gasoline additives into cargo trucks. The facility has applied for a Permit to Construct (PTC) and an initial issuance of a Synthetic Minor Operating Permit (SMOP). The facility has previously operated as a major source for volatile organic compounds (VOC) under a Title V operating permit. However, with the reversal of EPA’s “once in, always in” policy, MGC Terminal has applied for a Synthetic Minor Operating Permit (SMOP) to replace their Title V Operating Permit.  The facility became a listed PSD major source for future permit actions when it increased its gasoline storage capacity above 300,000 barrels (12,600,000) in 2017 through a 502(b)(10) above.  By becoming a synthetic minor source, the facility will restrict their emissions below the PSD 100 tons/year threshold. 

PROJECT/PERMIT ACTION DESCRIPTION

MGC Terminal is requesting a PTC to construct the following:  

1.	Addition of two new loading lanes (bays) for a total of four at the existing North Loading Rack (Emission Point AA-005). 
2.	Addition of a gasoline/butane blending system which will consist of a 90,000 gallon butane storage tank (Emission Point AA-026), a closed loop butane transfer system, and a blending system. 

EMISSION SUMMARY

MGC Terminal has the potential to emit over 100 tons VOC; however, the facility is able to operate as a Synthetic Minor by taking a federally enforceable limit on VOC by limiting the facility’s gasoline throughput to no more than 400,000,000 gallons in any consecutive 12-month period and shall limit total fuel, additives, and butane to no more than 600,000,000 gallons in any consecutive 12-month period. The facility’s throughput limits will restrict VOC emissions to  95.0 tons per year on a 12 month rolling average. This Title V avoidance limit is also a PSD avoidance limit.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

EMISSION LIMITS	
Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
Facility-wide	VOC	Product throughput limitations	Maintain monthly records of the throughputs of each product.	
AA-005 AA-008 AA-017 AA-025	VOC/HAP	TOC ≤ 35 mg TOC/L gasoline loaded,  
	Stack test once every five years.  
Maintain and operate a continuous monitoring system at all times.
Monthly inspections of the loading rack.

NEW SOURCE PERFORMANCE STANDARD (NSPS) APPLICABILITY

40 CFR Part 60, Subpart XX – Standards of Performance for Bulk Gasoline Terminals
This subpart applies to all loading racks at bulk gasoline terminals which deliver liquid product into gasoline tank trucks which were constructed or modified after December 17, 1980.  The facility is subject to Subpart XX.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

40 CFR Part 63, Subpart R – National Emission Standards for Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout Stations)
This subpart applies to major source bulk gasoline terminals.  With the issuance of the SMOP, the facility becomes an area source of HAPs. Therefore, the facility is not subject to Subpart R. 

40 CFR Part 63, Subpart BBBBBB – National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities.
This subpart applies to area source gasoline distribution bulk terminals, bulk plants, and pipeline facilities, and with the issuance of the SMOP, the facility is subject to Subpart BBBBBB.  As an existing source, the majority of the facility will have three years from the date of issuance to be in compliance with the subpart.  The facility operates as a Bulk Gas Terminal due to a gasoline throughput greater than 20,000 gallons per day.  The equipment in gasoline service include the loading rack, gasoline storage tanks and equipment leaks. The loading racks are subject to 80 mg TOC per liter of gasoline loaded (Table 2 of 40 CFR 63, Subpart BBBBBB). The permittee is also subject to the NSPS Subpart XX limit of 35 mg TOC/liter of gasoline loaded into gasoline cargo tanks from the loading rack. Compliance with the more stringent NSPS limit will demonstrate compliance with the NESHAP Subpart BBBBBB limit. 

PUBLIC PARTICIPATION

The 30-day public notice period began on November 24, 2020, with the publication of a notice in The Meridian Star and ends December 28, 2020.

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.