INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
April 2018

FOR:
Cottonseed Co Op Corporation
100 Mill Street
Jonestown, MS 38639    

FACILITY DESCRIPTION
Cottonseed Co-Op Corporation owns and operates an oil seed processing mill in Jonestown, Mississippi.  The Jonestown mill produces cottonseed oil, cottonseed meal, cottonseed hulls, and short-cut cotton lint from raw cottonseed.  The operation involves removing short-cut lint from cottonseed, hulling the seed, conditioning the inner seed meats, and extracting oil from the seed meats.  The facility is capable of processing 500 tons/day and 182,500 tons/year of cottonseed.
TITLE V PROGRAM APPLICABILITY BASIS
Cottonseed Co-Op is a major source as defined by Title V of the Federal Clean Air Act due to its potential to emit more than 100 tons per year (tpy) of PM/PM10 and volatile organic compounds (VOCs), and its potential to emit more than 10 tons per year of hexane, a hazardous air pollutant (HAP).
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 to this facility.  The uncontrolled emissions of criteria pollutants are less than PSD major source threshold of 250 tons per year.
NSPS/MACT APPLICABILITY
40 CFR Part 60, Subpart Dc
This subpart applies to any steam generating unit which was constructed after June 9, 1989 and has a maximum design heat capacity of more than 10 million British thermal units per hour (MMBTU/hr) but less than 100 MMBTU/hr. Emission Points AA-001 and AA-002 were constructed after the specified date and have a maximum design heat capacity of 29.3 MMBTU/hr and 17.0 MMBTU/hr, respectively. As such, these units are subject to and shall comply with all applicable requirements of 40 CFR Part 60, Subpart Dc – Standards of Performance for Small Industrial, Commercial, and Institutional Steam Generating Units.
40 CFR Part 63, Subpart GGGG
This subpart applies to any vegetable oil production process which removes oil from oilseeds through direct contact with an organic solvent (i.e. a hexane isomer blend) and which is located at a major source of HAPs. Furthermore, the vegetable oil production process must use one of eight specific oilseed feedstocks to be considered subject to the subpart. This facility does operate a vegetable oil production process using a hexane solvent and cottonseed, which is one of the eight specified feedstocks. As such, this facility is subject to and shall comply with all applicable requirements of 40 CFR Part 63, Subpart GGGG - National Emission Standards for Hazardous Air Pollutants: Solvent Extraction for Vegetable Oil Production.
40 CFR Part 63, Subpart ZZZZ
This subpart applies to the owners and operators of stationary reciprocating internal combustion engines (RICE) which are located at either major or area sources of HAPs. Emission Point AA-003 is a 50 HP diesel fired emergency generator which is located at a major source of HAPs. As such, this emission point is subject to and shall comply with all applicable requirements of 40 CFR Part 63, Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines.
40 CFR Part 63, Subpart DDDDD
This subpart applies to the owners and operators of industrial, commercial, or institutional boilers or process heaters which are located at a major source of HAPs. Emission Points AA-001 and AA-002 are natural gas fired boilers located at a major source of HAPs. As such, these emission points are subject to and shall comply with all applicable requirements of 40 CFR Part 63, Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters.

SPECIFIC APPLICABLE REQUIREMENTS
For the entire facility, the permittee shall limit the emissions of particulate matter (PM) and particulate matter with a diameter of 10 microns or less (PM10) to no more than emission rate determined by the relationship below:
	E = 4.1(p)0.67
where “E” is the emission rate in pounds per hour and “p” is the process weight input rate in tons per hour.  For purposes of this permit, the maximum allowable process weight input rate (p) shall not exceed 200 tons of cottonseed per hour.
The permittee shall also restrict the throughput of various feedstocks and products to the values represented in the table below.
Emission Point(s)	Operational Restriction	
AB-001 AB-002	No more than 182,500 tons of cottonseed per year for both emission points combined	
AB-011	No more than 87,600 tons of meal per year	
AG-000	No more than 500 tons of cottonseed per day (monthly average)	
AH-001
AH-002
AH-007	No more than 182,500 tons of cottonseed per year for all emission points combined	
AH-003
AH-006	No more than 179,600 tons of meal per year for both emission points combined	
AH-004
AH-005	No more than 74,360 tons of hulls per year for both emission points combined	
The permittee shall also meet all applicable State environmental regulations located in 11 Miss. Admin. Code Pt. 2.