PERMIT REVIEW SUMMARY

Permit Writer:	Chappell Ford	 	Date:	May 1, 2025

Company Name:	Industrial Company, The

Facility Location:	On Dixie Farm Road
Germania, MS 39040

Source Number:	3020-00067

County: 		Yazoo

FACILITY DESCRIPTION

The proposed location for the project is in Germania, Yazoo County, Mississippi. TIC supports the “early works” and “main works” required to build a power plant with PCC technology. The power plant with PCC technology (also known as “Project Alpha”, owned and operated by MP Innovations LLC) will supply power to a neighboring yet-to-be-built industrial project. As the proposed location for Project Alpha does not have the necessary power supply available to facilitate construction of the facility, TIC will provide these construction services via the use of several diesel-powered construction generator sets for the duration of the construction activity. 

Air emissions associated with the proposed construction activity will primarily occur from combustion of diesel fuel in the generator sets. Additional emissions may occur from fugitive vehicular traffic from equipment handling and moving activities, portable generators, and firewater pumps. The proposed construction services for the power plant will involve multiple stages with construction activity for simple cycle combustion turbines followed by construction activity for combined cycle combustion turbines. Additional construction support may also be provided for a carbon capture plant. These construction activities are expected to last four to five years. As the construction generator sets are expected to remain on-site for longer than twelve months, the generators are considered “stationary sources” under the Mississippi Administrative Code, Part 2, Chapter 2 air permitting provisions.

PROJECT/PERMIT ACTION DESCRIPTION

The proposed construction activities include the following emissions units:
•	Tier 4 Diesel-fired Non-Emergency Generators (16)
•	Diesel Firewater Pumps (2)
•	Diesel Storage Tanks (3)
•	Fugitive Paved and Unpaved Road Emissions
•	Portable Generators  

The following table includes the proposed emission points at the facility.

Emission Point	Facility ID	Description	
AA-001	GEN-1	Tier 4 Generator Engine 1, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-002	GEN-2	Tier 4 Generator Engine 2, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-003	GEN-3	Tier 4 Generator Engine 3, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-004	GEN-4	Tier 4 Generator Engine 4, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-005	GEN-5	Tier 4 Generator Engine 5, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-006	GEN-6	Tier 4 Generator Engine 6, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-007	GEN-7	Tier 4 Generator Engine 7, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-008	GEN-8	Tier 4 Generator Engine 8, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-009	GEN-9	Tier 4 Generator Engine 9, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-010	GEN-10	Tier 4 Generator Engine 10, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-011	GEN-11	Tier 4 Generator Engine 11, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-012	GEN-12	Tier 4 Generator Engine 12, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-013	GEN-13	Tier 4 Generator Engine 13, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-014	GEN-14	Tier 4 Generator Engine 14, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-015	GEN-15	Tier 4 Generator Engine 15, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-016	GEN-16	Tier 4 Generator Engine 16, a 2695hp/1825 kW, 17.39MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-017	FWP-1	Firewater Pump 1, a 753hp/562 kW, 5.48MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-018	FWP-2	Firewater Pump 2, a 753hp/562 kW, 5.48MMBTU/hr, compression ignition diesel engine with a displacement <10L per cylinder	
AA-019	DST-1	50,000 gallon Diesel Storage Tank 1	
AA-020	DST-2	50,000 gallon Diesel Storage Tank 2	
AA-021	DST-3	50,000 gallon Diesel Storage Tank 3	
FUG-1	FUG-1	Fugitive Emissions	

EMISSION SUMMARY

Pollutant	PTE (tpy)	
PM/PM10	9.80	
PM2.5	2.60	
SO2	1.27	
NOX	91.08	
CO	5.74	
VOC	2.64	
Total HAP	1.12	

APPLICABLE/PROPOSED PERMIT LIMITATIONS

The emissions from these activities will not exceed the Prevention of Significant Deterioration (PSD) threshold (250 tpy) for any PSD pollutant: nitrogen oxides (NOX), volatile organic compounds (VOCs), particulate matter equal to and less than 10 microns in aerodynamic diameter (PM10), particulate matter equal to and less than 2.5 microns in aerodynamic diameter (PM2.5), sulfur dioxide (SO2), and carbon monoxide (CO). 

The proposed facillity has the potential to exceed the Title V major source threshold for NOX emisisons. The emissions from these activities will remain below Title V major source thresholds of 100 tpy of any criteria pollutant (NOX, VOC, PM10, PM2.5, SO2, and CO) by setting a federally enforceable limit on the hours of operation of 88,000 total hours for the entire group of 16 diesel-fired non-emergency generators ( which is 5,500 hr/yr per generator).

Potential emissions of Hazardous Air Pollutants (HAPs) are below the major source thresholds (10 tpy of an individual HAP or 25 tpy of total HAPs); therefore, the project is an area source of HAPs.

NSPS APPLICABILITY

40 CFR 60, Subpart Kc
The provisions of 40 CFR 60 Subpart Kc - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for which Construction, Reconstruction, or Modification Commenced After October 4, 2023 (NSPS Kc) are applicable to storage vessels with a capacity greater than or equal to 20,000 gallons (gal) (75.7 m3) that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after October 4, 2023. The facility is proposing to construct three (3) tanks with a capacity of 50,000 gallons each. The tanks will hold diesel fuel which has a maximum true vapor pressure of less than 0.25 psia. Therefore, Subpart Kc is not applicable.

40 CFR 60, Subpart IIII
The provisions of 40 CFR 60, Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal Combustion Engines are applicable to owners and operators of stationary compression ignition (CI) internal combustion engines (ICE). The facility will have 16 Tier 4 diesel-fired 2,695 hp non-emergency generators built in 2025 and two (2) firewater pumps built in 2025 that are subject to Subpart IIII. 

NESHAP APPLICABILITY

40 CFR 63, Subpart ZZZZ
The provisions of 40 CFR 63, Subpart ZZZZ – National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines are applicable to stationary RICE at a major or area source of HAP emissions. At area sources, engines for which construction commenced on or after June 12, 2006, are considered new stationary RICE. The project will include 16 Tier 4 diesel-fired 2,695 hp non-emergency generators and two (2) diesel firewater pumps.
Per 40 CFR 63.6590(c), a new CI RICE at an area source must meet the requirements of 40 CFR 63 Subpart ZZZZ by meeting the requirements of 40 CFR 60 Subpart IIII for CI ICEs. No further requirements apply for such engines under the RICE MACT. By complying with 40 CFR 60 Subpart IIII, the generators and firewater pumps will meet the requirements of 40 CFR 63 Subpart ZZZZ.

PUBLIC PARTICIPATION

The 30-day public notice period began on May 7, 2025, when the notice was posted on MDEQ’s website and ends June 6, 2025.

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.