INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
March 2013

FOR:
SABIC Innovative Plastics US LLC
3531 Port and Harbor Drive
Bay St. Louis, MS 395209669

FACILITY DESCRIPTION
SABIC Innovative Plastics US LLC, an existing thermoplastics manufacturer, is applying for a significant modification to the existing Title V Operating Permit.  This modification includes the following:
•	Permitting an operating scenario for Emission Point AM-016 (RTO), which controls VOC and HAP emissions from the STAMAX extruders and Finishing Lines BA, BB, and BD.  
•	Construction of an additional particulate collection point which will be routed to and controlled by the Central Dust Collector (Emission Point AM-024).  
•	Update “as-built” information for sources added with the Polypropylene Production Project and the STAMAX Project which were approved with the modified Title V Permit in November 2010.  
•	Installation of a 150 kW non-emergency natural gas fired generator (Emission Point AB-013).
•	Construction of a second glass row on the STAMAX production line.

An actual-to-potential emissions analysis was performed for all existing sources affected and all proposed new emission sources to determine if a significant increase in emissions, which respect to PSD thresholds, would result from the project.  The emissions increase is 0.48 tpy for NOx, 0.96 tpy for CO, 0.34 tpy for VOC, 0.32 tpy of HAPs, and negligible changes to all other pollutants.

TITLE V PROGRAM APPLICABILITY BASIS
SABIC is major for NOx emissions.  SABIC has facility-wide limitations on emissions of total hazardous air pollutants (HAPs) and individual HAPs below the Title V threshold status to avoid future potentially applicable MACT standards.

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
Not applicable with this modification.

MACT APPLICABILITY
Emission Points AF-001, AF-002, AF-003, AM-016, and AB-001 are not subject to the Area Source Boiler MACT because all units use natural gas only.

RICE MACT language has been modified to address the new changes to the Area Source rule.

NSPS APPLICABILITY
Emission Point AB-013 is subject to NSPS Subpart JJJJ (Spark Ignition ICE).  NSPS language has been added.

SPECIFIC APPLICABLE REQUIREMENTS

For Emission Point AM-016, the permittee may operate the STAMAX production line and the 3 finishing extrusions lines without firing the RTO when these lines are manufacturing polypropylene-based products.  The permittee shall continue to operate the exhaust fan on the RTO to collect the emissions from the extruders and route them to the existing RTO stack.  

SABIC requested that visible emissions monitoring of the flare (Emission Point AF-003) be removed.  Because no deviations have been reported since the permit was issued over three years ago, this requirement has been removed.