PERMIT REVIEW SUMMARY

Permit Writer:	Joe McNamara 			

Company Name:	M/J Feed Mill MS, LLC

Facility Location:	261 Marshall Durbin Drive
			Waynesboro, MS  39367
			Wayne County

Source Number:	2840-00020

County: 		Wayne

PROJECT DESCRIPTION
M/J Feed Mill MS, LLC is applying for the reissuance of a Synthetic Minor Operating Permit (SMOP). 
 
The following changes have been made:
1)	Emission Point AA-002 (50 TPH Pellet Cooling System with 3 cyclones) has been replaced by a 75 TPH Pellet Cooling System with 3 cyclones.
2)	AA-006 (12.6 MMBtu/hr gas-fired Boiler) has been replaced with a 20.5 MMBtu/hr gas-fired Boiler.  

The replacement of Emission Points AA-002 and AA-006 with larger units does not require a construction permit and meets the definition of a De Minimis NSR Modification under 11 Miss. Admin. Code Pt. 2, R2.1.C(5).

NSPS AND SPECIFIC APPLICABILITY REQUIREMENTS 
Emission Point AA-006 is a natural gas and/or distillate fuel oil combustion unit. The unit is subject to state standards for particulate matter, sulfur dioxide and opacity. 

Emission Point AA-006 is subject to NSPS 40 CFR 60, Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units; however, the facility is exempt from certain limitations and monitoring if it only utilizes natural gas as fuel, but must meet the recordkeeping requirements.  Fuel oil containing greater than 0.5% sulfur by weight shall not be combusted.  Compliance with fuel oil sulfur limits shall be determined based on a certification from the fuel supplier.

M/J Feed Mill MS, LLC is not subject to NSPS 40 CFR 60, Subpart Kb – Standards for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984.  A-007 has a capacity of 8,000 gallons.

NESHAP APPLICABILITY
M/J Feed Mill MS, LLC is subject to NESHAP 40 CFR 63, Subpart DDDDDDD – Prepared Feeds Manufacturing as an existing prepared feed manufacturing facility that uses a material containing chromium or manganese and is an area source of hazardous air pollutants.

EXISTING SYNTHETIC MINOR LIMITATIONS
M/J Feed Mill MS, LLC is currently permitted for the following limitations:
•	shall not cause, permit, or allow the emission of smoke into the air which exceeds forty (40) percent opacity
•	shall limit total emissions of PM / PM10 / PM2.5 to 99.0 tpy
•	for AA-001 and AA-006, particulate matter (PM) emission of less than 10 MMBtu/hr shall not exceed 0.6 lbs/MMBtu
•	PM emissions from fossil fuel burning installations of equal to or greater 10 MMBtu/hr shall not exceed an emission rate determine by the relationship E = 0.8808*I-0.1667
•	shall not cause, permit, or allow the emission of particulate matter in total quantities in any one hour from any manufacturing process to exceed the amount determined by the relationship
E = 4.1p0.67
•	for AA-001 and AA-006, sulfur dioxide emissions shall not exceed 4.8 lbs/MMBtu
•	must operate control devices at all times when processing
•	for AA-001, the permittee shall only burn natural gas
•	for AA-002, the permittee must capture emissions and route them to a cyclone
•	for AA-006, the permittee shall only burn natural gas and/or distillate fuel oil
•	minimization of dust from chromium or manganese containing materials
o	use either industrial vacuum system or manual sweeping
o	once per month, remove dust from walls, ledges, and equipment
o	keep exterior doors in immediate affected areas shut except during normal ingress and egress
•	must at all times store any raw materials containing chromium or manganese in closed containers
•	mixer where materials containing chromium and manganese are added must be covered at all times when mixing is occurring, except when the materials are being added to the mixer
o	chromium or manganese must be added to the mixer in a manner that minimizes emissions
•	where materials containing chromium or manganese are loaded into trucks or railcars, you must lessen fugitive emissions by reducing the distance between the loadout spout and the vehicle being loaded

PUBLIC PARTICIPATION
The 30-day public notice period began on June 29, 2017, with the publication of a notice in the Clarion Ledger and ends July 31, 2017.

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.