PERMIT REVIEW SUMMARY

Permit Writer:	LaTrina Williams			 	Date:	January 10, 2022

Company Name:	Olin Winchester LLC

Facility Location:	411 County Road 101
Oxford, MS 38655

Source Number:	1420-00029

County: 		Lafayette

FACILITY DESCRIPTION

Olin Winchester LLC is a manufacturer of small arms ammunition.  The operations include two (2) adjoining business units: the Rimfire facility and the Centerfire facility.  The Rimfire facility is used for the production, assembly, and shipping of small arms ammunition, power tool loads, and military ammunition.  The Centerfire facility is used for the production, assembly, and shipping of small arms ammunition.  The facility’s operations fall within SIC Codes 3482 (Small Arms Ammunition) and 2892 (Explosives).  Both facilities are adjacent and their operations are similar. Therefore, for permitting purposes they are considered one source and are permitted under one permit.

PROJECT/PERMIT ACTION DESCRIPTION

The facility applied for a renewal of their Synthetic Minor Operating Permit and is proposing the installation of the following:
•     Addition of one Cobmea1 Bullet Tumbler with pollution control (addition to M-004)
•     Addition of one Cobmeal Bullet Tumbler without solvent (addition to AA-005)
•     Addition of one Extrusion Press (addition to AA-010)
•     Addition of two Progressive Die Presses (addition to AA-011)
•     Addition of one Cooling Tower (addition to AA-015)
•     Addition of two Natural-Gas fired units (Addition to AB-006)
•     Addition of five Cappers (addition to AC-003)
•     Addition of five Bullet Swagers (addition to AC-007)
•     Addition of three National Steel Header (addition to AC-010)

EMISSION SUMMARY

Table 1: Facility-Wide Emissions 
	PM	PM10	PM2.5	SO2	NOX	CO	VOC	Lead	Ind. HAP1	Total HAPs	
Uncontrolled Potential Emissions (tpy)	40.7	39.2	35.95	0.2	39.97	91.8	117.5	6.13	55.17	59.26	
Emission Limitations (tpy)	---	---	---	---	---	---	99.0	---	9.9	24.9	
1	Based on the maximum emission of Methylene Chloride

Based on the facility’s maximum production capabilities, the facility has the potential to exceed the Title V major source threshold for VOCs [i.e. 100 tons per year (tpy)] and methylene chloride (which is an individual HAP – i.e. 10 tpy).  Therefore, the facility will continue to limit and monitor their emissions in order to stay below the synthetic minor limitations by calculating the VOCs and HAPs (individual and total) monthly and 12-month rolling totals.  This shall be achieved by monitoring the quantity, percentage of VOCs and HAPs by weight and density of coatings, adhesives, solvents, or other VOC or HAP containing materials used on-site.

Emissions for all other criteria pollutants at the facility [particulate matter less than 10 microns (µm) in diameter (PM10), PM less than 2.5 µm in diameter (PM2.5), volatile organic compounds (VOCs), sulfur dioxide (SO2), carbon monoxide (CO), nitrogen oxides (NOX), total reduced sulfur compounds (TRS), and lead] are far below Title V threshold of 100 tpy. 

The facility is not one (1) of the twenty-eight (28) listed sources as defined in 40 CFR Part 52.21(b)(1)(iii); therefore, the applicable Prevention of Significant Deterioration (PSD) threshold is 250 tpy.  Based on the maximum uncontrolled emissions, the facility does not exceed 250 tpy for any new source review (NSR) pollutant.  Therefore, the facility is a PSD minor source. 

Compliance with the noted emission limitations will be demonstrated through applicable monitoring and recordkeeping requirements outlined within the permit.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

Emission 
Point(s)	Pollutant /
Parameter	Applicable Requirement	Limitation / Standard	Monitoring Requirement(s)	
AA-000	Opacity	11 Miss. Admin. Code Pt. 2, R. 1.3.A.
.
11 Miss. Admin. Code Pt. 2. R. 1.3.B.	 ≤ 40%	The margin of compliance for these standards is expected to be significant given that the facility emits minimal PM emissions.  Therefore, no additional requirements are needed.	
AA-000	VOCs
HAPs	11 Miss. Admin. Code Pt. 2, R. 2.2.B.(10).	
99.0 tpy

9.9 tpy (Individual)

24.9 tpy (Total)

(Rolling 12-Month Totals)	The facility will monitor and record the usage of applicable materials on a monthly basis.	
	PM
(filterable)	11 Miss. Admin. Code Pt. 2, R. 1.3.F(1).		By ensuring the adequate operation of baghouses, the margin of compliance for these standards should be significant.
The facility is required to operate any baghouse in accordance with manufacture’s specifications.	
AB-001
AB-002
AB-003	SO2	11 Miss. Admin. Code Pt. 2, R. 1.4.A(1).	4.8 lbs. / MMBTU	By solely using natural gas, the margin of compliance for these standards is expected to be significant given that the units combust natural gas.  Therefore, no additional requirements are needed.	
AB-000	PM	11 Miss. Admin. Code Pt. 2, R.1.3.H.(1).	0.6 Pounds / MMBTU per hour	By solely using natural gas, the margin of compliance for these standards is expected to be significant given that the facility emits minimal PM emissions.  Therefore, no additional requirements are needed.	
AB-008	NMHC + NOX	40 CFR 60.4205(c) – Table 4, 60.4206, and 60.4211(c), Subpart IIII	4.0 Grams per Kilowatt-Hour (or 3.0 Grams per Horsepower-Hour)	The facility will maintain documentation that indicates the engine as EPA-certified.	
	PM		0.30 Grams per Kilowatt-Hour (or 0.22 Grams per Horsepower-Hour)		
	Fuel Requirement	40 CFR 60.4207(b); Subpart IIII

40 CFR 80.510(b); Subpart I	15 ppm Sulfur Content (Max.); and

40 Cetane Index (Min.) or 35% Aromatic Content (Max. – by volume)	No additional requirements are needed, since the EPA mandates that fuel manufacturers must meet the noted standards.	

NSPS APPLICABILITY

40 CFR Part 60, Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units
Emission Points AB-001, AB-002, and AB-003 are subject because each steam generating unit was constructed after June 9, 1989 and has a maximum design heat input capacity of between 10 and 100 MMBTU/hr.  The applicable requirements regarding Subpart Dc have been added to the proposed permit.    

40 CFR Part 60, Subpart IIII – New Source Performance Standards for Stationary Compression Ignition (CI) Internal Combustion Engines. 
AB-008 is a new emergency compression ignition internal combustion engine (CI ICE) generator (constructed after June 12, 2006).  Therefore, this subpart is applicable.

40 CFR Part 60, Subpart JJJJ – New Source Performance Standards for Stationary Spark Ignition (SI) Internal Combustion Engines. 
Emission Point AB-004 is a certified natural gas-fired emergency (SI) generator engine with power over 25 HP that was manufactured after January 1, 2009.  Therefore, this subpart is applicable

MACT APPLICABILITY

40 CFR Part 63, Subpart ZZZZ – National Emission Standard for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE).
Emission Points AB-004, AB-005, and AB-008 are stationary RICE that are located at an area source of HAPs.  AB-005 is considered an existing emergency compression ignition internal combustion engine (CI ICE) fire pump (constructed before June 12, 2006).    Emission Points AB-004 and AB-008 were constructed after June 12, 2006.  As such, these units are required to comply with the New Source Performance Standards Subpart JJJJ and Subpart IIII (respectively) to demonstrate compliance with Subpart ZZZZ.  
40 CFR Part 63, Subpart XXXXXX – National Emission Standards for Hazardous Air Pollutants for Nine Metal Fabrication and Finishing Source Categories (Area Sources).
While an area source for HAP emissions, the facility does not primarily engage in any of the operations specifically outlined in Table 1 of the subpart.  Moreover, based on EPA guidance documents, the facility’s primary operation does not fall under any of the corresponding Standard Industrial Classification (SIC) and North American Industry Classification System (NAICS) codes that apply to this subpart.  Therefore, this subpart is not applicable.

40 CFR Part 63, Subpart JJJJJJ – National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters for Area Sources
The boilers are all gas-fired boilers and are therefore exempt.  

PUBLIC PARTICIPATION

The 30-day public notice period began on , with the publication of a notice in the  and ends .

RECOMMENDATION

The staff has preliminarily decided to recommend issuance of the permit to the Mississippi Environmental Quality Permit Board as shown in the draft permit.  However, the staff recommendation to the Board will be made only after a thorough consideration of all public comments.