PUBLIC NOTICE DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Slater Smith 			Date:	November 15, 2017

Company Name:	Monsanto Company, Deltapine Facility

Facility Location:	407 Goldstein Street
Hollandale, MS 38748

Source Number:	2800-00012

County: 		Washington

PROJECT DESCRIPTION
Monsanto Company, Deltapine Facility (Monsanto) is a cottonseed delinting operation. Monsanto is applying for the reissuance of Synthetic Minor Operating Permit (SMOP) 2800-00012. Monsanto has the potential to exceed the Title V threshold for PM and PM10; however, the facility self-imposed limitations on PM and PM10 emissions consistent with 11 Miss. Admin. Code, Pt. 2, Ch. 6.
The facility self-imposed a facility wide limit of 99.0 tons per year (tpy) for PM and PM10 emissions. Monsanto will demonstrate compliance by using actual stack test data, if available, and actual production and/or operating hours to calculate emissions, but if stack test data is not available, EPA AP-42 Emission Factors are used instead. Also, PM and PM10 emissions are limited by a facility wide, total seed production limit that is monitored and recorded on a rolling, consecutive 12-month total. As currently permitted, stack testing is required biennially, and this condition will remain in the permit to prove effectiveness of control technology.
EMISSIONS SUMMARY
Emission Changes Due to Modifications since Renewal (tpy)	
Permit Action	PM	PM10	SO2	NOx	CO	VOC	
2012	72.30	24.00	0.02	3.94	3.31	9.31	
2013	72.51	24.12	0.02	3.94	3.31	9.31	
2016	73.94	24.60	0.02	3.94	3.31	6.23	
2017	66.45	22.13	0.02	3.88	3.26	6.37	
Monsanto was issued a SMOP Renewal in 2012; since, PM, PM10 and VOC emissions have decreased. PM, PM10 and VOC emissions are associated with delinting and chemical treatment of the seeds, and 2017 SMOP Renewal Application reflects a decrease in production.
11 MISSISSIPPI ADMINISTRATION CODE PART 2, CHAPTER 1
Emission Points AB-001 and AB-002 are 10 MMBtu/hr and 3.6 MMBtu/hr natural gas-fired burners, respectively. The units are subject to state standards for particulate matter, sulfur dioxide and opacity. Since natural gas is a relatively clean burning fuel, the unit should have a large margin of compliance with the PM, SO2 and Opacity standards.
NEW SOURCE PERFORMANCE STANDARDS (NSPS)
No NSPSs apply to the facility.

NATIONAL EMISSION STANDARDS OF HAZARDOUS AIR POLLUTANTS (NESHAPs)
No NESHAPs apply to the facility.
SMOP LIMITATIONS, MONITORING, AND RECORDKEEPING REQUIREMENTS
The following limitations, monitoring, and recordkeeping requirements are expressed in the permit:
•	the facility’s total seed production shall not exceed 58,000 tpy
•	PM and PM10 emissions shall not exceed 99.0 tpy
•	record weekly maintenance inspections on all control devices and 
air emissions equipment
•	must maintain all spare parts and equipment to repair/replace the filter bags.
•	the facility shall not 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, the facility shall not exceed 250 hours per year of uncontrolled operation
•	for AA-001, the facility must conduct and submit a stack test using Method 5 or 17 biennially, rotating among the cyclones. One cyclone shall be tested biennially until all have been tested at least once.
•	for AA-003, AA-005, and AA-006, the facility must maintain devices for continuous monitoring of the  baghouses, and record pressure drop measurements across the baghouses. 
o	AA-004 (BH-5) does not have a pressure measurement device installed
•	The facility has indicated it will cease operation by 2019; thus, AA-004 is not required by this permitting action to install a measuring device for continuous monitoring and/or measurement of pressure drop across the baghouse emission system. However, if the facility is still in operation upon reissuance, the facility will be required to install a pressure drop measurement device.
•	for AA-003, AA-004, AA-005, AA-006, and AA-007, the facility must conduct and submit a stack test using Method 5 or 17 biennially, rotating among the baghouses. One baghouse shall be tested biennially until all have been tested at least once.
•	for AA-003, AA-004, AA-005, AA-006, and AA-007, the facility shall not exceed 50 hours per year, total of uncontrolled operation.
•	for AB-001 and AB-002, sulfur dioxide emissions shall not exceed 4.8 lbs/MMBtu
•	for AB-001, PM emissions shall not exceed an emission rate determine by E = 0.8808*I-0.1667
•	for AB-002, PM emissions shall not exceed 0.6 lbs/MMBtu
PUBLIC PARTICIPATION
The 30-day public notice period began on November 22, 2017, with the publication of a notice in the Delta Democrat Times and ends December 22, 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.