PERMIT REVIEW SUMMARY

Permit Writer:		Carter Cress 				Date:	October 2016

Company Name:		Yellow Creek Coating Services

Facility Location:		9 County Road 370
Iuka, MS  38852

Permit Number:		2580-00041

Agency Interest Number:	56952

County: 			Tishomingo

PROJECT DESCRIPTION

Yellow Creek Coating Services has submitted an application for reissuance of their current Synthetic Minor Operating Permit (SMOP), which was originally issued on March 13, 2012.  The facility is a manufacturer of fabricated metal products; specifically, steel pipes and fittings.  The facility receives fabricated steel pipes and associated materials from vendors.  These components are then cleaned via abrasive blasting and coated based on design requirements or product specifications.  

There are five (5) emission points identified in the SMOP: surface coating operations (AA-001), abrasive blasting operations (AA-002), metal working operations (AA-003), a 550-gallon diesel tank (AA-004), and space heaters (AA-005).  

EXISTING SYNTHETIC MINOR LIMITATIONS

The facility’s proposed reissued SMOP has emissions limits placed on PM, PM10, PM2.5, VOC, individual HAP, and total/combined HAP.  To remain below Title V major source thresholds, PM, PM10, and VOC have federally-enforceable limits of 99.0 tpy, individual HAP has a limit of 9.90 tpy, and total/combined HAP limit is 24.90 tpy.  The facility has requested in their SMOP renewal application an additional federally-enforceable limit be placed on PM2.5 of 99.0 tpy; therefore, appropriate monitoring, recordkeeping, and submitting requirements have been amended in the reissued permit to include PM2.5 emissions.        

The facility is not subject to 40 CFR Part 63, Subpart XXXXXX – National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories.  Although its activities (40 CFR 63.11514(a)(2): Fabricated Metal Products) are one of the nine source categories listed as governed by this regulation, this NESHAP applies to area sources “primarily engaged” in one of these nine operations.  40 CFR 63.11522 defines primarily engaged as “the manufacturing, fabricating, or forging of one or more products listed in one of the nine metal fabrication and finishing source category descriptions … where this production represents at least 50 percent of the production in a facility, and where production quantities are established by the volume, linear foot, square foot, or other value suited to the specific industry.  The period used to determine production should be the previous continuous 12 months of operation. Facilities must document and retain their rationale for the determination that their facility is not ‘primarily engaged’ pursuant to §63.10(b)(3) of the General Provisions.”  The SMOP renewal application indicates that metal fabrication only constituted 0.5% of all sales, with only 48 hours spent welding in the year 2015.  Therefore, this regulation does not apply to this facility.

The facility is not subject to 40 CFR Part 63, Subpart HHHHHH – National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources.  Although the facility does perform surface coating, this regulation is not applicable because the facility does not fall into any of the categories listed in 40 CFR 63.11170: their paint stripping operations do not involve the use of methylene chloride, no auto body/motor vehicle/mobile equipment are surface coated, and no spray application of “target HAP” is used.  

The facility is not subject to 40 CFR Part 63, Subpart ZZZZ – National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines because no ICE are present at the facility.  In addition, the facility is not subject to 40 CFR Part 63, Subpart JJJJJJ – National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources because no boilers are present.  

Finally, the facility is not subject to the state regulation 11 Miss. Admin. Code Pt. 2, R. 1.4.A(1).:

“The maximum discharge of sulfur oxides from any fuel burning
installation in which the fuel is burned primarily to produce heat or power
by indirect heat transfer shall not exceed 4.8 pounds (measured as sulfur
dioxide) per million BTU heat input.”  

because this sulfur oxide limit does not apply to direct heat transfer to the air; the facility’s only fuel burning installations are space heaters.  This regulation has been removed from the previous permit.            
PROPOSED ALLOWABLE EMISSIONS

				          Emission Points
	AA-001	AA-002	AA-003	AA-004	AA-005	Facility Total	
Pollutant	lb/hr	lb/hr	lb/hr	lb/hr	lb/hr	lb/hr	
	tpy	tpy	Tpy	tpy	tpy	tpy	
TSP (PM)	2433.56	67.13	0.089	---	0.015	2500.79	
	< 99.0*	< 99.0*	0.390	---	0.064	99.0*	
PM10	2433.56	67.13	0.089	---	0.015	2500.79	
	< 99.0*	< 99.0*	0.390	---	0.064	99.0*	
PM2.5	2433.56	67.13	0.089	---	0.015	2500.79	
	< 99.0**	< 99.0**	0.390	---	0.064	99.0**	
SO2	---	---	---	---	0.002	0.002	
	---	---	---	---	0008	0.008	
NOX	---	---	---	---	0.155	0.155	
	---	---	---	---	0.680	0.680	
CO	---	---	---	---	0.043	0.043	
	---	---	---	---	0.189	0.189	
VOC	478.5	---	---	---	0.006	478.506	
	< 99.0*	---	---	---	0.027	99.0*	
Total 
HAP	417.6	---	0.0049	---	---	417.60	
	< 24.90* 	---	0.0214	---	---	24.90*	
Individual HAP	361.80	---	0.0048	---	0.0003	361.805	
	< 9.90*	---	0.0212	---	0.0012	9.90*	

*The facility will accept permit limits to remain under the Title V threshold for the indicated criteria pollutants.  Also, individual HAP emissions will be limited to 9.90 tpy; total (combined) HAP emissions will be limited to 24.90 tpy to remain beneath major source thresholds. 

**The facility has requested an emission limit for PM2.5 be included in the reissued permit; therefore, a limit of 99.0 tpy for PM2.5 will be enforced in the reissued SMOP.   

PROPOSED CHANGES IN REISSUED PERMIT

The emission point identified as AA-004 has been re-named; it has been changed from “Tank Storage” to “550-gallon Diesel Tank.”  This change was undertaken due to the fact that only one (1) fuel tank is utilized at the facility.  In addition, the emission point identified as AA-005 has been re-named; it has been changed from “Miscellaneous Equipment” to “Space Heaters.”  This change was made because the only miscellaneous equipment present at the facility that requires governing via an air permit are the space heaters.  Formerly, the “Miscellaneous Equipment” emission point included sources that are exempt, including mobile sources.  The space heaters are also involved in accelerating the drying of coatings, not exclusively for climate control.      

Previously, the 99.0 tpy limit on particulate matter (PM) was not specific enough.  In addition to the 99.0 tpy limit on total suspended particles (TSP or general PM), 99.0 tpy limits have been added to specifically address PM10 and PM2.5.   

The state regulation 11 Miss. Admin. Code Pt. 2, R. 1.4.A(1). regarding sulfur dioxide referenced earlier has been removed.  

PUBLIC PARTICIPATION

The 30-day public notice period began on October 11, 2016, with the publication of a notice in the Daily Times Leader and ends November 10, 2016.  

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.