INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
May 2, 2013

FOR:
Waste Management of Mississippi, Inc., Pecan Grove Landfill and Recycling Center and Rubbish Site
9685 Firetower Road
Pass Christian, MS 39165    

FACILITY DESCRIPTION
Waste Management of Mississippi, Inc., owns and operates the Pecan Grove Sanitary Landfill and Recycling Center (Pecan Grove).  Pecan Grove is an existing municipal solid waste disposal facility located at 9685 Firetower Road, Pass Christian, Mississippi.  Operations at the site include landfill disposal, solidification of non-hazardous liquid wastes using fly ash and/or sawdust as solidifying agents, routine equipment maintenance, leachate collection and recirculation.  The original Title V application was submitted in 1995.  Waste Management complies with the fee requirements outlined in the Title V Regulations.

TITLE V PROGRAM APPLICABILITY BASIS
NSPS, Subpart WWW (40 CFR 60.750) – Designed disposal capacity meets or exceeds 2.5 million cubic yards.
Major for HAPS – Hydrochloric Acid (CAS 7647-01-0) Maximum PTE equals 12.78898 tons/year.  However, the facility has requested a limit of 9.9 TPY for HCl to remain below the threshold for a major source of HAPs.  With the federally enforceable limit for HCl, the PTE for Total HAPs at this facility is 22.75 TPY and therefore, the facility will not be a major source of HAPs for Total HAP.

Emission Point AA-102 (Leachate Storage Tank) has a design capacity that exceeds 151 m3 (39,980 gallons) and a maximum true vapor pressure less than 3.5 KPa (0.51 psia).  The previous Title V permit evaluation for this emission point was completed prior to regulatory changes to Subpart Kb and therefore, conditions were included in the Title V permit to ensure compliance with the applicable regulation.  Subsequent applicability changes to Subpart Kb (60.110b(b)), indicate that Emission Point AA-102 is no longer subject to regulation.  Therefore, all conditions within the Title V permit related to Subpart Kb have been removed from the proposed renewal Title V permit for this facility.

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 (APC-S-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 (APC-S-1) 
b.	the State of Mississippi Regulations for the Prevention of Air Pollution Emergency Episodes (APC-S-3),
c.	the State of Mississippi Regulations for the Prevention of Significant Deterioration of Air Quality (APC-S-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 (APC-S-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 APC-S-1;

4.	any standard or other requirement under Section 112 of the Federal Act, including relevant sections of APC-S-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 (APC-S-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 APC-S-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
The only individual pollutant which requires an emission limit is HCl and there is no add-on control for this pollutant.  Therefore, CAM does not apply.

MACT APPLICABILITY
The facility is an area source with a design capacity equal to or greater than 2.5 million cubic yards and an NMOC uncontrolled potential to emit equal to or greater than 50 Mg/yr.  Therefore, the facility is subject to MACT Subpart AAAA.

SPECIFIC APPLICABLE REQUIREMENTS

The maximum potential to emit for HCl is 12.78898 TPY based on emissions from year 2021.  The facility will take a limit of 9.9 TPY for HCl.  The source of HCl emissions is from the gas collection and control system installed and operated in accordance with NSPS Subpart WWW.
EMISSION LIMITS	
Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-001	HCl	9.9 TPY	To demonstrate compliance with this limit, the facility will be required to calculate actual annual emissions based on current facility data using the LandGEM program developed by EPA or another methodology as approved by the Department.