INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT

FOR:

Kimberly-Clark Corporation, Corinth Mill
3461 County Road 100
Corinth, Mississippi 38834
Facility No. 0060-00030    
May 2017
FACILITY DESCRIPTION
Kimberly-Clark Corporation, Corinth Mill, is a non-woven fabric manufacturing facility applying for renewal of the Title V Operating Permit. The facility operates under SIC code 2297 – Non-woven Fabrics, 2676 – Sanitary Paper Products and 2679 – Converted Paper and Paperboard Products, Not Elsewhere Classified.  The facility operates a Meltblown Process (AA-002A through AA-002D); Two (2) Spunbound Processes (AA-003A through AA-003E and AA-009A through AA-009E); NBL Process (AA-028); Three (3) Converting Lines with Dust Filter Cartridges (AA-035C); Two (2) Hydroknit Processes (AA-036 through AA-047 and AA-049 through AA-060); CM-4 Process (AB-001A, AB-001B, AB-002, AB-006A, AB-006B, AB-007, and AB-009); CF Pellet Handling System (AA-063); Two (2) Boilers (AA-048 and AA-061);  Spunbound and Meltblown Handling System (AA-064); Three (3) Emergency Generators (AA-031, AA-032, and AA-062); Cast Film Processes (CF-1 and CF-2); One (1) Emergency Firewater Pump (AA-033); and several heaters and ovens classified as insignificant activities.  

TITLE V PROGRAM APPLICABILITY BASIS
The facility's potential to emit for volatile organic compounds exceeds the major source threshold of 100 tons per year established by the Title V Program of the Clean Air Act, and therefore, the facility is subject to the Title V Program.  The facility does not have the potential to emit above major source thresholds for all other regulated pollutants, nor does the facility have the potential to emit more than 25 TPY of Total HAPs or 10 TPY of a single HAP.

POLLUTANT	POTENTIAL EMISSIONS (TPY)	ALLOWABLE EMISSIONS (TPY)	
PM	71.00	66.00	
PM10	63.00	63.00	
PM2.5	62.00	62.00	
SO2	2.00	2.00	
NOX	73.00	73.00	
CO	43.00	43.00	
VOC	143.00	143.00	
HAPs, Total	13.67	13.67	
(1)As determined from the Process Weight Equation (Ref: 11 Miss. Admin. Code Pt. 2, R. 1.3.F.)

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.  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 :

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.) amended
February 27, 2000,
b.	the State of Mississippi Regulations for the Prevention of Air Pollution Emergency Episodes (11 Miss. Admin. Code Pt. 2, Ch. 3.) amended April 25, 1988,
c.	the State of Mississippi Regulations for the Prevention of Significant Deterioration of Air Quality (11 Miss. Admin. Code Pt. 2, Ch. 5.) amended August 22, 1996, 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.) October 28, 1999, 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 does not apply because all pre-controlled emission rates are less than 100 tons per year.

NSPS APPLICABILITY
40 CFR 60, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, applies to Emission Points AA-048 and AA-061. For these emission points, due to the fuel burned, the facility is required to maintain monthly natural gas fuel records (40 CFR 60.48(c)(g) and shall keep these records on-site for at least two (2) years as specified in 40 CFR 60.48(c)(i).  

40 CFR 60, Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines, is applicable to Emission Points AA-062. The facility is required to install a non-resettable hour meter and maintain emission calculations demonstrating compliance with the 2.0gNOx/HP-hr, 4.0gCO/HP-hr, and 1.0gVOC/HP-hr emission limitations of the rule. 

NESHAP APPLICABILITY
This facility is not major for hazardous air pollutant (HAP) emissions (ie, total HAPs < 25 tpy, Single HAPs < 10 tpy) and therefore an area source.

40 CFR 63, Subpart ZZZZ, National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, is applicable to Emission Points AA-031, AA-032, AA-033, and AA-062.  Emission Points AA-031, AA-032 and AA-033 are considered existing emergency RICE under the subpart and the facility is required to comply with the manufactures instructions, change the oil and filters every 500 hours of operations or annually, whichever comes first, inspect air cleaners every 1000 hours of operations or annually, whichever comes first, inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and install a non-resettable hour meters.  Emission Point AA-062 is considered a new emergency RICE under subpart, however, compliance with Subpart JJJJ is its method of compliance.  

Emission Points AA-048 and AA-061 operates two (2) Boilers (37.8 MMBtu/hr) and appear to be subject to 40 CFR 63, Subpart JJJJJJ, National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources, however these units are natural gas-fired and excluded from the requirements of the subpart.  
SUMMARY OF SPECIFIC APPLICABLE REQUIREMENTS ARE AS FOLLOWS:
Emission Point(s)	Applicable Requirement	Pollutant/ Parameter	Limit/Standard	Monitoring/Recordkeeping/Reporting	
AA-000                  (Facility-wide)	11 Miss. Admin. Code Pt. 2, R.1.3.F(1)	PM	E = 4.1 p0.67 where E is the emission rate in pounds per hour and p is the process weight input in tons per hour.	The Margin of Compliance is Significant such that no additional monitoring, recordkeeping, or reporting is required.	
	11 Miss. Admin. Code Pt. 2, R. 1.3.B.	Opacity	<40%		

AA-048                 and
AA-061         (Boilers)	11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(b).	PM	E = 0.8808 I-0.1667
		
	11 Miss. Admin. Code Pt. 2, R. 1.4.A(1).	SO2	4.8 lb/MMBTU		
	40 CFR 60.40c(a)	NSPS Boilers, Subpart Dc	Applicability	Record and Report the  Amount of Fuel Combusted Monthly (40 CFR 60.48c(g)(1)-(3) and 40 CFR 60.48c(i))	
	Federally Enforceable Condition established in the Title V Permit issued October 7, 2009	Fuel Usage	Fuels other than natural gas are prohibited.	Comply with Subpart Dc	

AA-031
AA-032                 and
AA-033              (Existing Emergency Generators and Firewater Pump)
	40 CFR 63.6585(a), (c), and 40 CFR 63.6590(a)(1))	40 CFR 63, Subpart ZZZZ	Applicability	Comply with applicable provisions (40 CFR 63.6605)	
	40 CFR 63.6603(a)-Table 2d.4	Requirements to ensure engine(s) is meeting emission limits	Change oil and filter every 500 hours of operation or annually, whichever comes first; Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary; and Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary.	Operate engines according to manufacturer’s written instructions or site-specific plan for minimizing emissions, maintain records of all maintenance, and report any instance that emission limit was not met. (Continuous Compliance with emission limitations, monitoring, recordkeeping, and reporting requirements: 40 CFR 63.6640(a) and (e) and  40 CFR 63.6625(a), (e)(3) and (h), and Table 6.9.a.i-ii;   40 CFR 63.6655 (a),(d), (e) and (f)); and 40 CFR 63.6660(a)-(c))	
	40 CFR 63.6625(f)	Limitation	Install a non-resettable hour meter	Record all hours the engine is operated via the non-resettable hour meter and report any hours not recorded by the non-resettable hour meter.	
	40 CFR 63.6625(i)	Optional Limit	Option to implement an oil analysis program to extend the oil change requirement	Operate engines according to manufacturer’s written instructions or site-specific plan for minimizing emissions, maintain records of all maintenance, and report any instance that emission limit was not met.	
	40 CFR 63.6640(f)(1)	Operating Time	Limit non-emergency engine operation to 100 hours per year	The permittee may operate for up to 50 hours per calendar year in non-emergency situations for maintenance and testing	
AA-031, AA-032, AA-033, and AA-062 (Emergency Generators and Firewater Pumps)	11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(a).	PM	0.6 lbs/MMBTU	The Margin of Compliance is Significant such that no additional monitoring, recordkeeping, or reporting is required.	
AA-062              (New Emergency Generator)	40 CFR 60.4233(e)	NOx	2.0g/HP-hr	Comply with the compliance provisions of 40 CFR 60:4243(b)(1), (d), and (g) and Recordkeeping of 60.4245(a)(1-4) and (b))	
		CO	4.0g/HP-hr		
		VOC	1.0g/HP-hr		
	40 CFR 60.4237(b)	Limitation	Install a non-resettable hour meter	Record all hours the engine is operated via the non-resettable hour meter and report any hours not recorded by the non-resettable hour meter.	
	40 CFR 60.4243(d)	Operating Time	Limit non-emergency engine operation to 100 hours per year	The permittee may operate for up to 50 hours per calendar year in non-emergency situations for maintenance and testing	

CHANGES TO PERMIT DURING PERMITTING PROCESS 
The following Emission Points have been deleted from the permit as references as they are no longer located at the facility and were removed prior to issuance of the permit issued on October 7, 2009: 
Emission Point	Description	
AA-001	Process Boiler	
AA-004c	Spunbound Process No. 1 web treater B	
AA-030A	Airlaid Nonwovens Process	
AA-030B	ALNW Process Dust Control System Drum Filter	
AA-030C	ALNW Room Process Exhaust	
AA-035A	CAFH Final Collector No. 1	
AA-035B	CAFH Final Collector No. 2	

The following Emission Points have been deleted from the permit as they are Insignificant Activities:
Emission Point	Description	
AA-019	4.185 MMBtu/hr Converting Area Boiler	
AA-007A	Parts Cleaner for Maintenance Shop	
AA-007B	Parts Cleaner for Tractor Shop	
AA-007C	Parts Cleaner for CPP	
AA-005	Meltblown Beringer	
AA-006	Spunbound Beringer	
AB-008	CM4 Beringer	
AA-028	NBL Process Heater	
AA-029	5MMBtu/hr natural gas (NG) water heater	
AD-001	No. 2 Fuel Storage Tank	

The following were 502(b)(10) changes that occurred during the previous permit term:
Date	Action	
1/19/09	Decomissioning of converting area boiler (Emission Point AA-019); added 2.77 MMBtu/hr WEO2 and converted the SB1 HAK heater to natural gas.	
1/23/12	Added a new polymer to the CHM4 machine, Spunbound.	
5/6/14	Added a treater to the CM4 machine.	
1/23/15	Replaced an existing exhaust fan in the overhead hood above the Hydroknit #2 process (Emission Points AA-049 – AA-060).	
11/6/15	Miscellaneous corrections to the aerosol paint, release agents, lubricants, and solvent usages at the facility.	
1/24/16	Two (2) 7.56 MMBtu/hr air makeup units and removal of one (1) 1.5 MMBtu/hr air make-up unit.	

The following is a list of Minor Modification actions during the previous permit term:
Date	Action	Emission Point	
8/8/13	Added 100kW Emergency Generator	AA-062	
12/2/16	Removed Drum Filters	AA-002A and AA-002D	

Other
The facility previously had temporary electrical generators, AA-034, identified as an emission source.  These units were temporary units that would be rented and brought on-site as needed during major mill downs for maintenance.   Since these units are temporary in nature (i.e. on site for less than 1 year), they are considered as non-road engines and thus are not regulated under stationary source provisions.  Thus, this emission point has been removed from the permit.  If the facility has a need to permit these units for longer than one year, then the facility will need to file a minor modification for this change.