PERMIT REVIEW SUMMARY

Date:			May 12, 2026

Permit Writer:	Jeffery Bland (DEQ) / Morgan Hodges/B.J. Hailey (Contractors)	

Company Name:	BWC Terminals Pascagoula Facility

Facility Location:	601 Industrial Road
Pascagoula, MS 39568

Source Number:	1280-00152

County: 		Jackson

FACILITY DESCRIPTION
BWC Terminals Pascagoula Facility (BWC) is proposing to construct a new bulk liquid storage terminal located at 601 Industrial Road in Pascagoula, Mississippi. The facility will operate under NAICS code 424710 and SIC code 5171, Petroleum Bulk Stations and Terminals. BWC will construct and operate twenty-one (21) aboveground storage tanks, three (3) natural gas-fired heaters for product handling, six (6) natural gas-fired boilers for railcar heating, two (2) diesel-fired emergency fire pump engines used to provide water for the fire suppression system, a natural gas-fired vapor combustion unit (VCU) used to control VOC emissions during marine vessel loading operations at the dock, and associated piping, valves, pumps (product and fire), and connectors. The terminal will also transfer Naphtha which will be conveyed directly through the site without any onsite storage. The emission sources at the facility are summarized in the table below:

Emission Point	Description	
AA-001	31.5 MMBtu/hr natural gas-fired boiler used for railcar heating	
AA-002	31.5 MMBtu/hr natural gas-fired boiler used for railcar heating	
AA-003	31.5 MMBtu/hr natural gas-fired boiler used for railcar heating	
AA-004	31.5 MMBtu/hr natural gas-fired boiler used for railcar heating	
AA-005	31.5 MMBtu/hr natural gas-fired boiler equipped with low-NOx burners used for railcar heating	
AA-006	31.5 MMBtu/hr natural gas-fired boiler equipped with low-NOx burners used for railcar heating	
AA-007	12.6 MMBtu/hr natural gas-fired heater used for product handling (Heater #1)	
AA-008	12.6 MMBtu/hr natural gas-fired heater used for product handling (Heater #2)	
AA-009	12.6 MMBtu/hr natural gas-fired heater used for product handling (Heater #3)	
AA-010	6.6 MMBtu/hr (510 HP/380 kW) diesel-fired emergency fire pump engine used to provide water for the fire suppression system (Model Year 2026)	
AA-011	6.6 MMBtu/hr (510 HP/380 kW) diesel-fired emergency fire pump engine used to provide water for the fire suppression system (Model Year 2026)	
AA-012	10,374,000-gallon fixed roof storage tank used to store Asphalt (Tank 250-1)	
AA-013	2,100,000-gallon fixed roof storage tank used to store Base Oils (Tank 50-1)	
AA-014	4,620,000-gallon fixed roof storage tank used to store Base Oils (Tank 100-1)	
AA-015	6,930,000-gallon fixed roof storage tank used to store Base Oils (Tank 150-1)	
AA-016	6,930,000-gallon fixed roof storage tank used to store Base Oils (Tank 150-2)	
AA-017	2,310,000-gallon fixed roof storage tank used to store Bunker Fuels (Tank 50-2)	
AA-018	2,310,000-gallon fixed roof storage tank used to store Bunker Fuels (Tank 50-3)	
AA-019	2,310,000-gallon fixed roof storage tank used to store Bunker Fuels (Tank 50-4)	
AA-020	3,696,000-gallon fixed roof storage tank used to store Bunker Fuels (Tank 80-1)	
AA-021	3,696,000-gallon fixed roof storage tank used to store Bunker Fuels (Tank 80-2)	
AA-022	13,860,000-gallon external floating roof storage tank used to store Crude Oil (Tank 300-1)	
AA-023	13,860,000-gallon external floating roof storage tank used to store Crude Oil (Tank 300-2)	
AA-024	13,860,000-gallon external floating roof storage tank used to store Crude Oil (Tank 300-3)	
AA-025	13,860,000-gallon external floating roof storage tank used to store Crude Oil (Tank 300-4)	
AA-026	13,860,000-gallon external floating roof storage tank used to store Crude Oil (Tank 300-5)	
AA-027	13,860,000-gallon external floating roof storage tank used to store Crude Oil (Tank 300-6)	
AA-028	13,860,000-gallon external floating roof storage tank used to store Crude Oil (Tank 300-7)	
AA-029	10,374,000-gallon fixed roof storage tank used to store Vacuum Gas Oil (Tank 225-1)	
AA-030	10,374,000-gallon fixed roof storage tank used to store Vacuum Gas Oil (Tank 225-2)	
AA-031	4,620,000-gallon external floating roof storage tank used to store Yellow Wax Crude Oil (Tank 100-2)	
AA-032	4,620,000-gallon external floating roof storage tank used to store Yellow Wax Crude Oil (Tank 100-3)	
AA-033	67.32 MMBtu/hr natural gas-fired vapor combustion unit (VCU) used to control VOC emissions during marine vessel loading operations of volatile materials at the docks	

PROJECT/PERMIT ACTION DESCRIPTION
BWC submitted an application for a permit to construct on August 22, 2025. Primary emissions from the facility will be Volatile Organic Compounds (VOC), Nitrogen Oxides (NOx), and Carbon Monoxide (CO). BWC has proposed throughput limits that will limit potential emissions of these pollutants to levels below the Title V major source threshold of 100 tons per year (tpy) as defined in 11 Miss. Admin. Code Pt. 2, Ch. 6.1.A(19). As such, the facility will be considered a moderate stationary source as defined in 11 Miss. Admin. Code Pt. 2, R. 2.1.C(13). 

With regards to applicability to the Prevention of Significant Deterioration (PSD) regulations in 11 Miss. Admin. Code Pt. 2, Ch. 5, the facility is one of the 28 categorical facilities listed in 40 CFR 52.21(b)(10(i)(a) since the total petroleum storage capacity of the facility exceeds 300,000 barrels (or 12.6 million gallons). As such, the facility is considered a stationary source subject to the 100 tpy major source PSD threshold for regulated NSR pollutants. Since the proposed throughput limits will result in a potential-to-emit (PTE) below the 100 tpy threshold, the facility will be considered a moderate stationary source and not subject to the PSD regulations. 

EMISSION SUMMARY
The following table summarizes the uncontrolled potential-to-emit (PTE) based on maximum design throughputs in the proposed permit.

Pollutant	Uncontrolled PTE (tpy)	
PM/PM10/PM2.5	8.26	
SO2	1.75	
NOx	94.09	
CO	55.95	
VOC	53.42	
Total HAP	2.35	

APPLICABLE/PROPOSED PERMIT LIMITATIONS
The facility has proposed throughput limits for each product which results in a PTE for all pollutants less than the major source threshold. The proposed throughput limit for each product is listed in the following table.

Product	Annual throughput 
(barrels/year)	
Yellow Wax Crude	5,500,000	
Crude	10,000,000	
Base Oils	5,500,000	
Naphtha	10,000,000	
Vacuum Gas Oil	5,500,000	
Bunker Fuel	3,000,000	
Asphalt	500,000	

NSPS APPLICABILITY
40 CFR 60, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units - The provisions of Subpart Dc are applicable to steam generating units for which construction commenced after June 9, 1989, and have a maximum heat input capacity of 100 MMBtu/hr or less, but greater than or equal to 10 MMBtu/hr. The boilers (Emission Points AA-001 through AA-006) have a maximum heat capacity greater than 10 MMBtu/hr each; therefore, they will be subject to the applicable provisions of Subpart Dc. The heaters (Emission Points AA-007 through AA-009) will meet the definition of a steam generating unit in 40 CFR 60.41c (i.e., …a device that combusts any fuel and produces steam or heats water or heats any heat transfer medium) and will all have a maximum heat input capacity greater than 10 MMBtu/hr each; therefore, they will also be subject to the applicable provisions of Subpart Dc. Since all boilers and heaters are natural gas-fired units, they will only be required to comply with the recordkeeping and notification requirements in the proposed permit.  
40 CFR 60, Subpart Kc, Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, Modification Commenced After October 4, 2023 - The provisions of Subpart Kc are applicable to storage vessels with a capacity greater than or equal to 20,000 gallons (75.7 m3) that are used to store volatile organic liquids (VOL). Emission Points AA-012 through AA-021, AA-029, and AA-030 will all have a storage capacity that exceeds the applicability threshold; however, the products they store will have a maximum true vapor pressure of less than 0.25 psia. Per 40 CFR 60.110c(b)(8), these storage vessels will not be subject to the requirements of Subpart Kc. Emission Points AA-022 through AA-028, AA-031, and AA-032 will have a storage capacity that exceeds the applicability threshold and will store products that have maximum true vapor pressures in excess of 0.25 psia; therefore, these storage vessels will be subject to the applicable provisions of Subpart Kc. The applicable requirements from Subpart Kc are in the proposed permit. 
40 CFR 60, Subpart XXa, Standards of Performance for Bulk Gasoline Terminals that Commenced Construction, Modification, or Reconstruction After June 10, 2022 - The provisions of Subpart XXa are applicable to loading racks at a bulk gasoline terminal which delivers liquid product into gasoline cargo tanks and that are constructed or modified after June 10, 2022. BWC will not be considered a bulk gasoline terminal as defined in 40 CFR 60.501a; therefore, the Subpart XXa provisions will not be applicable to the facility.   
40 CFR 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines - The provisions of Subpart IIII are applicable to stationary compression ignition (CI) internal combustion engines (ICE) that commenced construction, modification, or reconstruction after July 11, 2005, and the engine is manufactured after April 1, 2006, or July 1, 2006 (fire pump engines). The emergency fire pump engines (Emission Points AA-010 and AA-011) will be constructed and manufactured after the applicability dates; therefore, the provisions of Subpart IIII will be applicable to these engines. These engines will be subject to the applicable emission standards and must be operated and maintained such that they meet the applicable emission standards over the entire life of the engine. The facility will purchase certified engines to meet the applicable emission standards. The applicable requirements of Subpart IIII are in the proposed permit. 
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
The facility will be considered an area source of hazardous air pollutants (HAP) since the facility will not have the PTE to emit more than 25 tpy for total HAP or 10 tpy for any individual HAP. The NESHAP standards potentially subject to area sources were the only ones evaluated for applicability.
40 CFR 63, Subpart ZZZZ, NESHAP for Stationary Reciprocating Internal Combustion Engines - The provisions of Subpart ZZZZ are applicable to stationary reciprocating internal compression-ignition engines (RICE) located at both major and area sources of HAP emissions. BWC will operate two (2) emergency stationary RICE engines (Emission Points AA-010 and AA-011) that will be subject to the applicable requirements of Subpart ZZZZ. For purposes of Subpart ZZZZ, these engines will be considered new, emergency, compression ignition engines located at an area source of HAP emissions. Per 40 CFR 63.6590(c)(1), the facility will comply with Subpart ZZZZ by complying with the applicable requirements of 40 CFR 60, Subpart IIII. 
40 CFR 63, Subpart BBBBBB, NESHAP for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities - The provisions of Subpart BBBBBB are  applicable to bulk gasoline terminals, bulk plants, and pipeline facilities located at area sources of HAP emissions. BWC will not store or handle gasoline as defined in 40 CFR 63.11100; therefore, the provisions of Subpart BBBBBB will not be applicable to the facility.   
40 CFR 63, Subpart CCCCCC, NESHAP for Source Category: Gasoline Dispensing Facilities - The provisions of Subpart CCCCCC are applicable to gasoline dispensing facilities located at an area source of HAP emissions. BWC will not store or handle gasoline as defined in 40 CFR 63.11132; therefore, the provisions of Subpart CCCCCC will not be applicable to the facility.
40 CFR 63, Subpart JJJJJJ, NESHAP for Industrial, Commercial, and Institutional Boilers at Area Sources - The provisions of Subpart JJJJJJ are applicable to owners and operators of industrial, commercial, and institutional boilers that is located at an area source of HAP emissions. BWC will operate six (6) natural gas-fired boilers (Emission Points AA-001 through AA-006) that are potentially applicable to Subpart JJJJJJ; however, per 40 CFR 63.11195(e), gas-fired boilers are not subject to Subpart JJJJJJ.
40 CFR 63, Subpart Y, NESHAP for Marine Tank Vessel Loading Operations - The provisions of Subpart Y are applicable to existing and new sources with emissions of 10 or 25 tons of HAP as defined in 40 CFR 63.561 and new sources with emissions less than 10 and 25 tons of HAP as defined in 40 CFR 63.561. BWC will be considered a new source with emissions less than 10 and 25 tons of HAP; however, the facility does not meet the definition of sources with emissions less than 10 and 25 tons which is defined as “a major source having aggregate actual HAP emissions form marine tank vessel loading operations at all loading berths less than 25 tons of all HAP emissions combined or less than 10 tons of each individual HAP”. BWC will not be a major source of HAP; therefore, it is not subject to the provisions of Subpart Y. 
PUBLIC PARTICIPATION
The 30-day public notice period began on May 13, 2026, when the notice was posted on MDEQ’s website and ends June 12, 2026.

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.