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

FOR:
Delta Oil Mill
100 Mill Street
Jonestown, MS 38639    

FACILITY DESCRIPTION
Delta Oil Mill 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
Delta Oil Mill 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, and its potential to emit more than 10 tons per year of hexane, a hazardous air pollutant.

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
CAM is not applicable.  Uncontrolled emissions are less than major source threshold.

MACT APPLICABILITY
National Emissions Standard for Hazardous Air Pollutants (NESHAP), Subpart GGGG, Solvent Extraction for Vegetable Oil Production applies to Emission Group AG-000.  These emission points are associated with the solvent plant for cottonseed oil extraction and have a throughput limit of 500 tons of cottonseed per day to indirectly limit hexane emissions.  Other standards, recordkeeping, and reporting requirements associated with the MACT Subpart GGGG standard are listed in the Title V permit.

National Emissions Standard for Hazardous Air Pollutants (NESHAP), Subpart ZZZZ, for Stationary Reciprocating Internal Combustion Engines applies to Emission Point AA-003.  This emergency generator was installed in 1994 and qualifies as an existing emergency CI engine <500 HP located at a HAP major source.  This unit is required to comply with the requirements of Subpart ZZZZ by May 3, 2013.

National Emissions Standards for Hazardous Air Pollutants (NESHAP), Subpart DDDDD, for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters applies to Emission Points AA-001 and AA-002.  These two boilers commenced construction or reconstruction on or before June 4, 2010 and have a heat input capacity of 10 MMBTU/hr or greater, therefore are classified as existing large major source boilers.  These units are required to perform annual tune-ups and a one-time energy assessment due by January 31, 2016.  The facility is required to submit a Notification of Compliance Status Report before September 30, 2016, or within 60 days following the completion of compliance demonstrations, whichever is earlier, and annual compliance reports thereafter.  A notification of applicability was submitted by the facility on April 2, 2013.

SPECIFIC APPLICABLE REQUIREMENTS
For the entire facility, as required by APC-S-1, Section 3.6(a), the particulate matter levels shall not exceed the equation 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.  The Title V application indicated that Delta Oil Mill has the capability of receiving a maximum of 200 tons of cottonseed per hour.  To ensure that the facility cannot increase production without regulatory approval, the process weight input rate shall not exceed 200 tons per hour.  To monitor the compliance of this requirement, Condition 5.B.4 requires monitoring and recordkeeping on a monthly basis for all raw materials received at the facility.  This monitoring and recordkeeping condition is based on APC-S-6, Section III.A.3 which contains the requirements with respect to monitoring.  The reporting of these conditions shall be semiannually, as required by APC-S-6, Section III.A.3.c.(1).

Emission point AA-001 is a 29.3 MMBTU/hr natural gas fired boiler and is subject to New Source Performance Standards (NSPS), Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units.  This standard requires this boiler to burn No. 1 or No. 2 fuel oil when burning distillate oil.  This standard also requires the use of fuel oil with a sulfur content less than or equal to 0.5 percent by weight.  To comply with this standard, Conditions 5.B.7 and 5.B.8 are in this permit.  These conditions require the permittee to monitor and maintain fuel supplier certifications and to monitor and record monthly fuel usage.  To demonstrate compliance with these requirements, the permittee shall submit a report of the fuel supplier certifications and a summary report of type, quantity, and quality of fuel used.  These reports shall be submitted semiannually, as required by APC-S-6, Section III.A.3.c.(1) and 40 CFR 60.48c(j).  

Additionally, emission point AA-001 is subject to two State regulations, APC-S-1, Section 3.4(a)(2) and APC-S-1, Section 4.1(a).  APC-S-1, Section 3.4(a)(2) requires that all emissions from installations equal to or greater than 10 million BTU per hour of heat input but less than 10,000 million BTU per hour heat input shall not exceed an emission rate as determined by the relationship E=0.8808*I‑0.1667, where E is the emission rate in pounds per million BTU per hour input and I is the heat input in millions of BTU per hour.  APC-S-1, Section 4.1(a) limits sulfur dioxide emissions from fuel burning installations to 4.8 pounds per million BTU heat input.  Both of these requirements are monitored, recorded, and reported in the same manner as listed in the above paragraph.

Emission point AA-002 is a 17.0 MMBTU/hr natural gas fired boiler.  This boiler was constructed before August 7, 1977 and therefore is not applicable to the New Source Performance Standards, Subpart Dc.  APC-S-1, Section 3.4(a)(2) and APC-S-1, Section 4.1(a) apply to this boiler in the same fashion as it did in emission point AA-001; therefore, compliance is assured exactly the same way as emission point AA-001.  This boiler also requires the use of fuel oil with a sulfur content less than or equal to 0.5 percent by weight.

To maintain a minor source status with regards to PSD, throughput limitations were previously established for emission points AB-001, AB-002, and AB-011.  This throughput limit shall be no more than 182,500 tons of cottonseed per year for the combined emission points AB-001 and AB-002 and no more than 87,600 tons of meal per year for emission point AB-011.  Delta Oil Mill also has limits on their loadout areas to maintain a minor source in regards of PSD.  These throughput limits are 182,500 tons of cottonseed per year for AH-001, AH-002, and AH-007 combined; no more than 179,600 tons of meal per year for AH-003 and AH-006 combined; and no more than 74,360 tons of hulls per year for AH-004 and AH-005 combined.  These monthly amounts of materials received shall be monitored, recorded, and reported semiannually.

Delta Oil Mill is required to demonstrate compliance on all control devices at least once within the life of the permit.  Additionally Title V monitoring, including visible emission evaluations and operation and maintenance inspections, will be performed on a weekly basis.  Other monitoring will include recordkeeping and reported requirements and consist of raw materials and fuel usage.

Emission Points AD-001, AE-001 through AE-006, AG-002, and AG-003 were previously listed in Section 2 as emission points which have been removed from the facility.  These emission points have been taken out of the permit.

Several control devices in the previous Title V permit were listed as ‘Not Operational’.  This title has been removed from the description, as a modification would be required to operate the units under the title of ‘Not Operational’.  Additionally, The First Cut Motes/ Safety Shaker Seed Delinting Cyclones Reference No. SD-14 and SD-15 have been given Emission Points, AD-017 and AD-018, respectively.  The Second Cut Motes Cyclone, Reference No. SD-28 has been given Emission Point AE-018 and the Suction Solvent Extraction Cyclone, Reference No. SP-02 is now Emission Point AG-008.  

See the Title V draft permit for specific limits, standards, monitoring/recordkeeping, and reporting conditions.