INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
[RENEWAL – MAY 2013]

Aluminum Extrusions, Inc.
140 Matthews Drive, Senatobia, Mississippi 38668    

FACILITY DESCRIPTION

Aluminum Extrusions, Inc. is an existing manufacturer of aluminum extruded products (SIC 3354; NAICS 331316) located in Senatobia, Mississippi.  The facility is applying for the renewal of their Title V Operating Permit (Air Ref. No. 2600-00026).  During the permitting process it was determined that the facility is subject to 40 CFR Part 63, Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters.  The primary source of emissions at the facility is generated from surface coating operations.  The facility will continue to maintain the previously established Prevention of Significant Deterioration avoidance limitation on volatile organic compound emissions so as to avoid triggering Prevention of Significant Deterioration requirements.

TITLE V PROGRAM APPLICABILITY BASIS

The facility’s potential to emit exceeds the major source threshold of 100 tons per year for volatile organic compounds, the major source threshold of 25 tons per year of combine hazardous air pollutants, and the major source threshold of 10 tons per year for an individual hazardous air pollutant, all of which were established by the Title V Program of the Clean Air Act.

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.

GREENHOUSE GAS (GHG) APPLICABILITY

The facility’s GHG emissions are significantly below the major source threshold.  (There are no GHG requirements in the permit.)

CAM APPLICABILITY

The facility is not subject to any of the requirements as stated in 40 CFR 64.2(a), therefore, Compliance Assurance Monitoring (CAM) provisions do not apply.

MACT APPLICABILITY

The facility’s uncontrolled potential to emit for hazardous air pollutants is above (Title V) major source thresholds.  Therefore, the facility is subject to 40 CFR Part 63, Subpart MMMM – National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products in accordance with 40 CFR 63.3881(b).  The facility is also subject to 40 CFR Part 63, Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, Institutional Boilers and Process Heaters.

NSPS APPLICABILITY

The facility is not subject to any of the requirements as stated in 40 CFR Part 60, New Source Performance Standards.

PSD APPLICABILITY

The facility is subject to Prevention of Significant Deterioration since their uncontrolled potential to emit for volatile organic compounds is above the Prevention of Significant Deterioration major source threshold; however, the facility’s existing permit limits/restricts volatile organic compound emissions (entire facility) to no more than 249.0 tons per year.  Therefore, Prevention of Significant Deterioration permitting requirements are not applicable.

SPECIFIC APPLICABLE REQUIREMENTS

Aluminum Extrusions, Inc.’s current operations (as listed in the permit) include metal working operations (Emission Point AA-001), surface coating operations (Emission Point AA-002), and washer burners (Emission Point AA-003).

The entire facility is restricted by a Prevention of Significant Deterioration avoidance limitation placed on volatile organic compound emissions.  To assure compliance with the limitation, the facility is required to monitor and maintain, for each VOC-containing material used, sufficient (monthly) records of the quantity used (gal), the percent VOC by weight, and the density (lb/gal) so as to provide the mass of volatile organic compound emissions in tons per year, based on a consecutive 12-month period.  The facility is required to submit the results of the recordkeeping in accordance with submittal requirements as stated in the permit.

The entire facility (specifically Emission Point AA-002) is subject to and shall comply with federal requirements as stated in 40 CFR Part 63, Subpart MMMM – National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products.  To ensure compliance, the facility is required to monitor, record, and report in accordance with the standard.

The entire facility (specifically Emission Point AA-003) is subject to and shall comply with federal requirements as stated in 40 CFR Part 63, Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters.  To ensure compliance, the facility is required to monitor, record, and report in accordance with the standard.

[Note:	The facility has another washer burner (5.0 MMBTU/hr natural gas-fired ‘existing’ unit) that was evaluated for applicability to 40 CFR Part 63, Subpart DDDDD.  It was determined that because the unit is already subject to 40 CFR Part 63, Subpart MMMM, it meets the exemption specified in 40 CFR 63.7491(h) of Subpart DDDDD.]