INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
June 2016

FOR:
Darling Ingredients Inc
1299 Prisock Road
Jackson, MS 39272    

FACILITY DESCRIPTION
Darling Ingredients Inc (SIC 2077), located in Jackson, Mississippi processes meat and bone scrap, poultry offal, and spent restaurant grease into bone meal, poultry meal, feather meal, blood meal, and processed grease.  The facility is applying for a minor modification of its Title V Operating Permit.  

TITLE V PROGRAM APPLICABILITY BASIS
Darling Ingredients Inc is a major source as defined by Title V of the Federal Clean Air Act due to their potential to emit more than 100 tons per year of PM, SO2, and NOx.  Darling Ingredients Inc has taken a limit of 249 tons per year, facility wide, to avoid being a major source for PSD for PM, SO2, and NOx.  They also took a 249.9 MMBTU/Hr heat input limit on the six boilers (AA-020, AA-021, AA-022, AA-023, AA-024, AA-025) to keep them from being classified in the “28 listed source” category.

LEGAL AND FACTUAL BASIS FOR DRAFT PERMIT CONDITIONS

The State and Federally-enforceable conditions of Title V Operating Permits are based upon the requirements of the State of Mississippi Air Emissions Operating Permit Regulations for the Purposes of Title V of the Federal Clean Air Act (11 Miss. Admin. Code Pt. 2, Ch. 6.), and applicable requirements effective upon the date of permit issuance.  Applicable requirement means all of the following as they apply to emissions units in a Title V source:

1.	any standard or other requirement set forth in the State Implementation Plan (SIP) approved or promulgated by EPA through rulemaking under Title I of the Federal Clean Air Act (Federal Act) including the following:

a.	most of the State of Mississippi Air Emission Regulations for the Prevention, Abatement, and Control of Air Contaminants (11 Miss. Admin. Code Pt. 2, Ch. 1.) 
b.	the State of Mississippi Regulations for the Prevention of Air Pollution Emergency Episodes (11 Miss. Admin. Code Pt. 2, Ch. 3.),
c.	the State of Mississippi Regulations for the Prevention of Significant Deterioration of Air Quality (11 Miss. Admin. Code Pt. 2, Ch. 5.), and 40 CFR Part 52.21 by reference, and
d.	the provisions of the State of Mississippi Permit Regulations for the Construction and/or Operation of Air Emissions Equipment (11 Miss. Admin. Code Pt. 2, Ch. 2.), relating to construction permits and synthetic minor operating permits;

2.	any term or condition of any construction permits issued pursuant to Mississippi regulations approved or promulgated through rulemaking under Title I;

3.	any standard or other requirement under Section 111 of the Federal Act, including Section 111(d) which includes Title 40, Part 60 of the Code of Federal Regulations (40 CFR Part 60) and relevant sections of 11 Miss. Admin. Code Pt. 2, Ch. 1.;

4.	any standard or other requirement under Section 112 of the Federal Act, including relevant sections of 11 Miss. Admin. Code Pt. 2, Ch. 1.and 40 CFR Parts 61, 63, and 68;

5.	any standard or other requirement of the acid rain program under Title IV of the Federal Act or the regulations promulgated thereunder, including the State of Mississippi Acid Rain Program Permit Regulations for Purposes of Title IV of the Federal Clean Air Act (11 Miss. Admin. Code Pt. 2, Ch. 7.)  adopted November 17, 1994, and 40 CFR Parts 72, 73, 75, 77, and 78;

6.	any requirements established pursuant to Section 504(b) or Section 114(a)(3) of the Federal Act;

7.	any standard or other requirement governing solid waste incineration under Section 129 of the Federal Act;

8.	any standard or other requirement for consumer and commercial products under Section 183(e) of the Federal Act;

9.	any standard or other requirement for tank vessels under Section 183(f) of the Federal Act;

10.	any standard or other requirement of the program to control air pollution from outer continental shelf sources under Section 328 of the Federal Act;

11.	any standard or other requirement of the regulations promulgated to protect stratospheric ozone under Title VI of the Federal Act;

12.	any national ambient air quality standard or increment or visibility requirement under part C of Title I of the Federal Act.

Each State and Federally-enforceable condition of the draft Title V Operating Permit references the specific relevant requirements of 11 Miss. Admin. Code Pt. 2, Ch. 6.or the applicable requirement upon which it is based. Any condition of the draft Title V permit that is enforceable by the State but is not Federally-enforceable is identified in the draft Title V permit as such.

CAM APPLICABILITY
CAM is not applicable because the scrubber systems at the facility do not have pre-controlled emissions exceeding and major source threshold.

MACT APPLICABILITY
Emission points AA-020, AA-021, AA-022, AA-023, AA-024, and AA-025 meet the definition of a gas-fired boiler, as defined in 40 CFR 63.11237, and are not subject to the requirements of 40 CFR Part 63, Subpart JJJJJJ for Industrial, Commercial, and Institutional Boilers at Area Sources. 

For the purposes of 40 CFR Part 63 Subpart JJJJJJ, if a boiler can no longer comply with the gas-fired boiler conditions then he appropriate oil subcategory shall become applicable.  Under such circumstances, Emission Points AA-020, AA-021, and AA-022 would be considered existing and AA-023, AA-024, and AA-025 would be considered new.

MODIFICATIONS TAKING PLACE
Emission point AA-012 (Trane-Murray Boiler) was removed from the facility on March 9, 2014 and has been removed from all fuel burning-related permit conditions.  Existing fuel limitations and requirements for all existing fuel burning equipment remain in effect.  Emission point AA-014 (7,144 Gallon Fuel Oil Storage Tank) was repurposed for a water tank on April 11, 2014.

The previously existing AA-004 (High Intensity Scrubber System consisting of a Venturi Scrubber and a Packed Tower Scrubber) has been redesignated to AA-004a (Venturi Scrubber) and AA-004b (Packed Tower Scrubber).  AA-027 (Regenerative Thermal Oxidizer) has been added to the facility for control of process high-intensity malodorous emissions.

The ducts connecting AA-004a to AA-004b have been reconfigured, with the continued use of only AA-004a as a pre-conditioner (quenching and PM block) of all process emissions, with flow thence to AA-027.  The emissions previously controlled by AA-017 (the other packed tower scrubber) have also been re-ducted to AA-004a and AA-027.  Both AA-004b and AA-017 have been taken to contingency back-up stand-by status in event of AA-027 maintenance or failure.

A temperature limit has been added to Emission Point AA-027 that requires a minimum operating temperature in the combustion chamber of 1300 degrees Fahrenheit.  Monitoring and recordkeeping requirements have also been added.  For Emission Point AA-027, the permittee shall retain records of all required monitoring data and support information according to Condition 5.A.3 and shall report all deviations from permit requirements according to Condition 5.A.5.

SPECIFIC APPLICABLE REQUIREMENTS
Darling Ingredients Inc has proposed to taken a facility-wide 249 tons per year limit for filterable PM, SO2, and NOx emissions to avoid PSD.  A fuel restriction of 0.5% by weight of sulfur for No.2 fuel oil, No.6 fuel oil and on-spec. used oil, is also in effect.

Darling is required to record and submit a 12 month rolling total for filterable PM, SO2, and NOx emissions.  To widen the margin on compliance, all control devices will be required to operate in accordance to their operating plan, which will further lower Darling’s PTE.

Darling shall ensure compliance with the fuel restrictions by maintaining and submitting fuel supplier certifications and/or results of the fuel analysis as required by NSPS Dc.  These records shall be maintained and included in the semiannual reporting.  Darling shall not be allowed to burn any other fuel other than natural gas, No.2 and No.6 fuel oil, on-spec. used oil, and processed fats in any fuel burning equipment and shall be required to monitor and record their daily fuel usage.

Darling is limited to a combined boiler usage limitation of 249.9 MMBTU/Hr heat input at any given time to avoid PSD applicability.  

Darling is required to monitor, record, and submit the combined boiler usage in MMBTU/Hr heat input, a rolling 12 month total of the facility-wide production outputs, and a log of the date, duration (in hours), and amount of fuel oil combusted for each occurrence during the calendar year and shall note the reason that fuel oil was combusted (e.g., maintenance test, natural gas curtailment, etc.).

Darling is required to submit excess emission reports in accordance with NSPS Subpart Dc.

Darling is required to submit written notification to MDEQ within 30 days after a boiler becomes applicable to an oil subcategory boiler as defined in MACT Subpart JJJJJJ.

For emission points AA-020, AA-021, AA-022, AA-023, AA-024, AA-025, Darling shall comply with the “Site Specific Opacity Monitoring Plan” dated August 7, 2015, (or the most current approved revision) as required by NSPS Subpart Dc.

All records that are required to be submitted shall be submitted semiannually for review by MDEQ.

EMISSION LIMITS	
Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
Facility Wide	PM (filterable only)
NOx
SO2	No more than 249 tons per year	Monitor and record a 12-month rolling total for filterable PM,  NOx, and SO2 emissions	
AA-020
AA-021
AA-022
AA-023
AA-024
AA-025	

Fuel Restriction	
Only combust natural gas, No.2 fuel oil, No.6 fuel oil, on-spec used oil, and processed fats	

Monitor and record daily fuel usage	
AA-020
AA-021
AA-022
AA-023
AA-024
AA-025	

Combined Boiler Usage	
Combined boiler usage limitation of 249.9 MMBTU/Hr heat input at any given time	

Monitor and record boiler usage	
AA-020
AA-021
AA-022
AA-023
AA-024
AA-025	

Opacity	When combusting fuel oil, 20% opacity (6-minute) average, except for one 6-minute per hour of not more than 27% opacity shall not be exceeded	
Conduct Test Method 9 or other EPA approved alternative and comply with the MDEQ approved Site Specific Opacity Monitoring Plan	
AA-020
AA-021
AA-022
AA-023
AA-024
AA-025	

SO2	
Maximum fuel oil sulfur content of 0.5% by weight for No.2, No.6 fuel oil, and on-spec used oil	

Monitor and maintain fuel supplier certifications and/or fuel analysis	

See the draft Title V permit for specific limits, standards, monitoring, recordkeeping, and reporting conditions.