PUBLIC NOTICE PERMIT REVIEW SUMMARY

Permit Writer:	Slater Smith 			Date:	January 14, 2019

Company Name:	Resinall Corp

Facility Location:	102 Dixie Pine Road
Hattiesburg, MS 39401

Source Number:	0800-00009

County: 		Forrest

FACILITY DESCRIPTION
Resinall Corp (Resinall), formally Resinall Mississippi, Inc., is a specialty resin manufacturing facility in Hattiesburg, MS. The applicant's operations fall within SIC Code 2821. Resinall currently operates under Synthetic Minor Operating Permit (SMOP) 0800-00009 that includes the operations of Resinall QalicB (RQB). RQB operates the Hydrogenated Hydrocarbon Resin Unit and associated equipment to hydrogenate resins to produce hydrogenated tackifier resins. All resins produced at the RQB facility are then be conveyed to co-located Resinall for further manufacture prior to being shipped to customers. 
MODIFICATION DESCRIPTION
Resinall is planning for possible modification to the materials stored in multiple tanks, which will occur in two phases. The first phase will include changing the service of Tanks T-110, T-121, and T-122 from Hydrocarbon Polymer Storage, with vapor return lines, to Hydrocarbon Feedstock Storage, without vapor return lines. Once the tanks are modified to hold Hydrocarbon Feedstock and the vapor return lines are removed, the tanks will vent to the atmosphere. The second phase of the proposed modifications will include changing the service of Tanks T-045, T-054, T-111, T-114, and T115 from Process Oil/Resin Oil Blend to Hydrocarbon Feedstock Storage Service.
Although Resinall is requesting the changes, the service changes may not occur or may not be implemented in the near future. Therefore, Resinall is requesting that the tanks be permitted to store either of the materials.

EMISSIONS SUMMARY
Proposed Potential Emissions (tons per year)	
Permit Action	Year	PM	PM10	PM2.5	SO2	NOx	CO	VOC	Total HAP	
Reissuance	2016	23.4	21.3	15.0	99.4	63.6	36.9	84.1	5.40	
Modification	2018	23.4	21.3	15.0	97.8	63.6	36.9	83.7	5.14	
Table 1. Potential emissions based on the 2016 reissuance of SMOP 0800-00009 and modification of SMOP 0800-00009. The emissions above demonstrate a marginal decrease in SO2, VOC, and Total HAP emissions.	
Table 1 represents the potential controlled emissions of Resinall for the 2016 SMOP reissuance and current SMOP modification. While neither phase one or phase two are guaranteed to take place, the emissions represented in the 2018 SMOP modification display a decrease in two criteria pollutants (SO2 and VOC) and Total HAPs. Therefore, the 2018 SMOP modification is not a risk for breaching the major source threshold for criteria pollutants (100 tons per year) or HAPs (10 tons per year for individual or 25 tons per year for aggregate Total HAPS). 
EXISTING SYNTHETIC MINOR LIMITATIONS
The draft permit contains federally enforceable emission limitations that limit facility-wide Sulfur Dioxide (SO2) emissions to 99.4 tons per year by implementing fuel usage restrictions, and attendant recordkeeping and reporting requirements. The permit also limits their volatile organic compound (VOC) emissions below 100 tpy by limiting product loading throughput at the railcars and requiring use of condensers on the existing volatile organic storage tanks. To continue to avoid PSD and Title V applicability, Resinall wishes to maintain the operating limits in the proposed permit. No other criteria pollutants or hazardous air pollutants have the potential to exceed the major source thresholds for Title V (i.e. 100 TPY for criteria pollutants and 10/25 TPY for HAP(s)). 
Facility wide emissions of SO2 are calculated based upon the combined annual maximum amount of fuel oil and zecosol combusted at the facility of 2,800,000 gallons. VOC emissions are calculated for comparison against the potential emission represented in application based on the maximum transfer/load of no more than 1,150,000 gallons of intermediate hydrocarbon product in any consecutive 12 month period.
No new limitations or modifications to limitations were made due to the nature of the modification. Therefore, the monitoring, recordkeeping, and reporting conditions remain unchanged.

PUBLIC PARTICIPATION
The 30-day public notice period began on January 22, 2019, with the publication of a notice in the Hattiesburg American.
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.