DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Slater Smith 	Date:	March 8, 2023
Company Name:	Louis Dreyfus Company River Elevators LLC, Port of Rosedale, River Elevator
Facility Location:	489 David Work Drive
Source Number:	0240-00097
County: 		Bolivar
FACILITY DESCRIPTION
Louis Dreyfus Company River Elevators LLC, Port of Rosedale, River Elevator (Louis Dreyfus) manages an existing grain elevator. Whole grains such as corn, soybeans, wheat, milo, and rice are received via truck. Grains are unloaded at two receiving areas each having two hopper truck dump pits, and grains are subsequently transferred into storage bins via a bucket elevator. There are six storage silos with a total storage capacity of 2,225,000 bushels. If necessary, the facility dries grain in the grain tower dryer (Emission Point AA-003) which has a maximum throughput of 960,000 tons per year (tpy). The grain dryer is the only fuel burning equipment onsite. Grains are loaded out into trucks or barges and are sent to loadout through either a truck loadout leg/spout or the barge loadout covered belt. Louis Dreyfus operates two baghouses to control particulate matter (PM) emissions onsite. The aforementioned equipment and production areas are sources of PM, PM less than 10 micrometers (μm) in diameter (PM10), PM less than 2.5 μm in diameter (PM2.5), Sulfur Dioxide (SO2), Carbon Monoxide (CO), Volatile Organic Compounds (VOC), and Hazardous Air Pollutant (HAP) emissions.
The following sections will specifically address the project/permit action description, emission summary, applicable/proposed permit limitations, Standards of Performance for New Stationary Sources (NSPS) applicability, and National Emissions Standards for Hazardous Air Pollutants (NESHAP)/ Maximum Achievable Control Technology (MACT) applicability.

PROJECT/PERMIT ACTION DESCRIPTION
Louis Dreyfus has a maximum grain throughput of 960,000 tpy. The facility is requesting modification of Synthetic Minor Operating Permit (SMOP) Air Ref. No. 0240-00097 to increase grain throughput from 684,000 tpy to 850,000 tpy. The maximum grain storage capacity will not increase. The increase in throughput reflects a forecast for increased production caused by market conditions.
EMISSION SUMMARY

Table 1. Facility-Wide Comparison of Uncontrolled and Proposed Allowable Emissions (tpy)	
Pollutant	2021 SMOP Modification Uncontrolled Emissions	2021 SMOP Modification
Proposed Allowable Emissions	2022 SMOP Modification Uncontrolled Emissions	2022 SMOP Modification
Proposed Allowable Emissions	Change in Proposed Allowable Emissions	Proposed Allowable < Major Source Threshold (100 tpy)?	
PM	517	249.01	506	249.01 (179.42)	0.00	Yes3	
PM10	231	99.01	222	99.01 (59.42)	0.00	Yes	
PM2.5	41.2	13.0	37.8	10.12	0.00	Yes	
SO2	0.16	0.16	0.16	0.16	0.00	Yes	
NOx	27.2	27.2	27.2	27.2	0.00	Yes	
CO	22.9	22.9	22.9	22.9	0.00	Yes	
VOC	1.50	1.50	1.50	1.50	0.00	Yes	
Individual HAP	< 10.0	< 10.0	< 10.0	< 10.0	0.00	Yes4	
Total HAPs	< 25.0	< 25.0	< 25.0	< 25.0	0.00	Yes4	
1.	The facility proposed Prevention of Significant Deterioration (PSD) and Title V major source Avoidance Limitations to determine direct compliance with the respective thresholds.
2.	The facility will limit grain throughput to 850,000 tpy which will lower the proposed allowable emissions from the uncontrolled emissions. This limitation indirectly demonstrates compliance with the PSD and Title V major source thresholds. Monitoring and recordkeeping requirements will demonstrate compliance with the throughput limitation.
3.	The Title V program does not regulate PM emissions; however, the PSD program has a major source threshold of 250 tpy.
4.	The major source thresholds for Individual and Total HAP emissions are 10 and 25 tpy, respectively.	

Louis Dreyfus has the potential to exceed the Title V major source threshold of 100 tpy for PM10 emissions and the PSD major source threshold of 250 tpy for PM, as seen in Table 1. The proposed facility-wide grain throughput limit of 850,000 tons per year, will reduce the proposed allowable emission for PM and PM10. The facility will limit PM and PM10 emissions to below the major source thresholds and compliance will be demonstrated through monitoring and recordkeeping. The facility is an area source of HAP emissions and does not have the potential to exceed the major source thresholds for individual HAP emissions (10 tpy) and total HAP emissions (25 tpy).
Louis Dreyfus requested an increase in grain throughput; however, the current permitting action demonstrates a decrease in uncontrolled emissions, as seen in Table 1. The previous permit application was calculated with Emission Point AA-003 operating at a grain throughput of 960,000 tpy, while the facility-wide grain throughput limit was 684,000 tpy. This permitting action will correct the calculation error, and the emissions of Emission Point AA-003 reflect the proposed 850,000 tpy limit.
APPLICABLE/PROPOSED PERMIT LIMITATIONS
The following conditions will be incorporated in the permit to ensure that Louis Dreyfus remains below the PSD and Title V major source thresholds:
•	For the entire facility, the permittee shall limit total facility-wide maximum grain throughputs to no more than 850,000 tpy, as determined on  a monthly basis and for each consecutive 12-month period on a rolling basis.
o	The permittee shall maintain sufficient records to document monthly grain throughput in tons per month and a rolling 12-month total. Records should indicate total amount of grain received and loaded-out along with a breakdown by receiving and load-out locations.
•	For the entire facility, the permittee shall limit total facility-wide PM emissions to no more than 249.0 tpy, as determined on  a monthly basis and for each consecutive 12-month period on a rolling basis.  
o	The permittee shall determine compliance performance testing, visual observations, control device maintenance, and recordkeeping.
•	For the entire facility, the permittee shall limit PM10 emissions to no more than 99.0 tpy, as determined on  a monthly basis and for each consecutive 12-month period on a rolling basis.
o	The permittee shall determine compliance performance testing, visual observations, control device maintenance, and recordkeeping.
STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES (NSPS) APPLICABILITY
Standards of Performance for Grain Elevators (40 CFR 60, Subpart DD)
The Standards of Performance for Grain Elevators (40 CFR 60, Subpart DD) applies to any grain terminal elevator which commences construction, modification, or reconstruction after August 3, 1978. Louis Dreyfus is defined as a grain terminal elevator and was constructed after August 3, 1978; therefore, the facility is subject to Subpart DD. The dust collectors (Emission Points AA-001, AA-002, and AA-032) are subject to the particulate matter and opacity standards. Emission Point AA-003 is subject to the particulate matter and opacity standards. The barge loading station (Emission Points AA-004 and AA-017) is subject to opacity standards. The grain handling area (Emission Points AA-005 through AA-016, AA-020 through AA-034) is subject to opacity standards. The truck loading station (Emission Point AA-018) is subject to opacity standards. The truck unloading station (Emission Point AA-019) is subject to opacity standards.

NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)/MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) APPLICABILITY
None applicable.

PUBLIC PARTICIPATION

The 30-day public notice period began on March 8, 2023, with the publication of a notice in The Clarion Ledger.

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.