INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
May 7, 2013

FOR:
Guardian Fiberglass, Inc
7046 State Line Road
Mineral Wells, MS 38654    

FACILITY DESCRIPTION
Guardian Fiberglass, Inc., is an existing wool fiberglass insulation manufacturer and is seeking to renew their current Air-Title V operating permit. The facility is subject to New Source Performance Standard 40 CFR 60, Subpart PPP and National Emission Standards for Hazardous Air Pollutants for Source Categories; Wool Fiberglass Manufacturing, 40 CFR 63, Subpart NNN and Reciprocating Internal Combustion Engines, 40 CFR 63, Subpart ZZZ .  This is not a Prevention of Significant Deterioration (PSD) project as specified in APC-S-5.  (This facility is a PSD major source).  

TITLE V PROGRAM APPLICABILITY BASIS
The facility’s potential-to-emit exceeds the Title V threshold limits of 100 tons/year of each of the following criteria pollutants:  Carbon Monoxide, Particulate Matter (10 microns or less) and Volatile Organic Compounds.  The facility also has the potential to emit more than 25 TPY of Total HAPs and/or 10 TPY of a single 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 (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
Emission Points AB-003, AB-005, AC-001 and AC-002 are subject to CAM.  MACT Subpart NNN requires the permittee to implement a Quality Improvement Plan (QIP) which in consistent with the CAM provisions.  Therefore, we believe the monitoring required by the MACT is presumptively acceptable. The two remaining emission points, AB-004 and AC-003, the potential uncontrolled emissions are below major source thresholds, so CAM does not apply. 

MACT APPLICABILITY
Emission Points AB-003, AB-005, AC-001 and AC-002 are subject to National Emission Standards for Hazardous Air Pollutants for Source Categories; Wool Fiberglass Manufacturing, 40 CFR 63, Subpart NNN.  Emission Points IA-001 and IA-002 are subject to National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines and General Provisions for the emergency backup generators, 40 CFR 63, Subpart ZZZZ.

GREENHOUSE GAS (GHG) APPLICABILITY
The facility’s potential-to-emit for CO2e (non-biogenic only) is 21358.3; therefore, the facility is not a major source of GHGs.  Because there are no applicable federal standards for GHGs and no PSD or PSD-avoidance permits have been issued for GHGs, there are no specific GHG requirements in this Title V permit.

SPECIFIC APPLICABLE REQUIREMENTS

EMISSION LIMITS	
Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AB-003
(EP-1)	Particulate
	1.98 lb/hr and 8.67 TPY

0.5 lb PM/ton of glass pulled	Stack testing once every 5 years

Performance testing and all applicable monitoring requirements as specified in 40 CFR 63, Subpart NNN once every 5 years.	
	Operating Limit	Corrective action	All applicable monitoring requirements as specified in 40 CFR 60, Subpart NNN.	
AB-005
(EP-5)	Particulate
	1.75 lb/hr and 7.67 TPY 

0.5 lb PM/ton of glass pulled 	Stack testing once every 5 years

Performance testing and all applicable monitoring requirements as specified in 40 CFR 63, Subpart NNN once every 5 years.	
	Operating Limit	Corrective action	All applicable monitoring requirements as specified in 40 CFR 63, Subpart NNN.	
AC-001
(EP-4)	Particulate	7.0 lb/hr and 30.68 TPY

11 lb PM/Ton of glass pulled	Stack testing once every 5 years

Performance testing and all applicable monitoring requirements as specified in 40 CFR 60, Subpart PPP once every 5 years.	
	Formaldehyde	1.2 lb Formaldehyde/Ton of glass pulled	Performance testing and all applicable monitoring requirements as specified in 40 CFR 63, Subpart NNN once every 5 years	
AC-002
(EP-3)	Particulate	11.00 lb/hr and 48.18 TPY 

11 lb PM/Ton of glass pulled	Stack testing once every 5 years

Performance testing and all applicable monitoring requirements as specified in 40 CFR 60, Subpart PPP once every 5 years.	
	Formaldehyde	1.2 lb Formaldehyde/Ton of glass pulled	Performance testing and all applicable monitoring requirements as specified in 40 CFR 63, Subpart NNN once every 5 years	
AC-003
(EP-6)	Particulate	7.0 lb/hr and 30.68 TPY

11 lb PM/Ton of glass pulled	Stack testing once every 5 years

Performance testing and all applicable monitoring requirements as specified in 40 CFR 60, Subpart PPP once every 5 years.	
IA-001 and IA-002	HAP
Operational Restriction		Work Practice Standards	

OTHER LIMITS: