DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Slater Smith 	Date:	June 15, 2022

Company Name:	Koch Farms of Mississippi LLC

Facility Location:	278 Herring Road
Morton, MS 39117

Source Number:	2420-00051

County: 		Scott

FACILITY DESCRIPTION
Koch Farms of Mississippi LLC (“Koch”) is an existing poultry feed mill (SIC Code 2048 – Prepared Feed and Feed Ingredients for Animals and Fowls, except Dogs and Cats) that operates under Synthetic Minor Operating Permit (SMOP) Air Ref. No. 2420-00051. The facility consists of the emission points listed and described in Table 1.
Emission 
Point	Facility
Reference	Description	
AA-001	FB-001	20.9 MMBtu/hr Boiler
Natural gas and/or No. 2 Fuel Oil-fired	
AA-002	FB-002	20.9 MMBtu/hr Boiler
Natural gas and/or No. 2 Fuel Oil-fired	
AB-001	AA-107	Truck Receiving controlled by Baghouse	
AB-002	AA-140	Rail Receiving No. 1 controlled by Baghouse	
AB-003	AA-144	Rail Receiving No. 2 controlled by Baghouse	
AC-001	AA-126	Grain Storage Silo Vent controlled by Baghouse	
AC-002	AA-127	Soy Meal Storage Silo Vent controlled by Baghouse	
AC-003	AA-131	Meal Ingredient Transfer Vent controlled by Baghouse	
AC-004	AA-209	Soy Meal Transfer Vent controlled by Baghouse	
AC-005	AA-327	Hammer Mill No. 1 controlled by Baghouse	
AC-006	AA-328	Hammer Mill No. 2 controlled by Baghouse	
AC-007	AA-329	Hammer Mill No. 3 controlled by Baghouse	
AC-008	AA-339	Ground Grain Transfer Vent controlled by Baghouse	
AC-009	AA-599A	Pellet Crumbles Transfer Vent No. 1 controlled by Baghouse	
AC-010	AA-599B	Pellet Crumbles Transfer Vent No. 2 controlled by Baghouse	
AD-001	AA-458	Meal Cleaner Vent controlled by Baghouse	
AE-001	AA-519	Pellet Mill No. 1 controlled by Cyclone	
AE-002	AA-551	Pellet Mill No. 2 controlled by Cyclone	
AE-003	AA-584	Pellet Mill No. 3 controlled by Cyclone	
AF-001	----	Phosphate Receiving controlled by Baghouse	
AF-002	----	Limestone Receiving controlled by Baghouse	
AF-003	----	Salt Receiving controlled by Baghouse	
AF-004	----	Finished Feed Loadout A	
AF-005	----	Finished Feed Loadout B	
AF-006	----	Methionine Receiving controlled by Baghouse	
AF-007	----	Lysine Receiving controlled by Baghouse	
AG-001	AA-101	10,000 gallon Off-Road Diesel Storage Tank	
AG-002	AA-102	20,000 gallon Over the Road Diesel Storage Tank
Maximum True Vapor Pressure less than 15 kPa (2.17psia)	
The fuel burning emission sources, Emission Points AA-001 and AA-002, emit Particulate Matter (PM), PM less than 10 microns (PM10), PM less than 2.5 microns (PM2.5), Sulfur Dioxide (SO2), Carbon Monoxide (CO), Volatile Organic Compounds (VOC), and Hazardous Air Pollutant (HAP) emissions. Emission Points AB-001, AB-002, AB-003, AC-001, AC-002, AC-003, AC-004, AC-005, AC-006, AC-008, AC-009, AC-010, AD-001, AE-001, AE-002, AE-003, AF-001, AF-002, AF-001, AF-002, AF-003, AF-005, AF-006, and AF-007 are sources of PM, PM less than 10 microns, PM less than 2.5 microns emissions.
The following sections will specifically address Project/Permit Action Description, Emissions Summary, Applicable/Proposed Permit Limitations, Standards of Performance for New Stationary Sources (NSPS) applicability, National Emissions Standards for Hazardous Air Pollutants (NESHAP)/ Maximum Achievable Control Technology (MACT) applicability, and Specific Applicable Requirements.
PROJECT/PERMIT ACTION DESCRIPTION
Koch has requested reissuance of SMOP Air Ref. No. 2420-00051 without modification. The following changes were made to the SMOP:
•	Previously, Koch limited Total Feed Mill Production to 1,572,480 tons per year. The limitation conflicted with the PM10 emission limit of 99.0 tpy. The permittee would violate the PM10 emission limit if the facility met the production limit. The facility recalculated the production limit to 1,470,000 tpy.
•	Facility-wide PM10 and PM2.5 emission limitations were lowered to 95.0 tpy to improve operational flexibility. The Total Feed Mill Production limitation of 1,470,000 tpy results in potential-to-emit PM10 and PM2.5 of 92.8 and 46.1 tpy, respectively. The facility will have a wide margin of compliance of the 95.0 tpy PM10 and PM2.5 emission limits. The emission limitations give the facility operational flexibility for modifications resulting in small PM10 and PM2.5 emissions increases. A public comment period is not required for modifications that do not cause the facility to have the potential to exceed the Title V major source threshold.
•	Previously, Koch was required to operate the control devices for Emission Points AB-001, AB-002, AB-003, AC-001, AC-002, AC-003, AC-004, AC-005, AC-006, AC-007, AC-008, AC-009, AC-010, AD-001, AE-001, AE-002, AE-003, AF-001, AF-002, AF-003, AF-006, and AF-007 at all times while processing. Language was added requiring the permittee to route all emissions to the respective control device.
•	Table 2 demonstrates that Koch does not have the potential to exceed the Title V major source threshold for SO2. The facility-wide SO2 emission limitation was removed.
•	Monitoring requirements were added requiring Koch to inspect each control device to ensure the device is operating according to manufacturer’s specifications. Koch shall keep records of each inspection.
•	Stack testing language was updated for Emission Points AC-005, AC-006, AC-007, AE-001, AE-002, and AE-003. For Emission Points AC-005, AC-006, AC-007, AE-001, AE-002, and AE-003, the permittee shall conduct triennial stack tests on a rotational basis. The permittee shall stack test a respective control device once every 3 years, not to exceed 36 months from the previous stack test.
o	The previous permit required stack testing once every five years for either Emission Points AC-005, AC-006, or AC-007. Also, the previous permit required stack testing once every five years for either Emission Points AE-001, AE-002, or AE-003.
•	Previously, the permittee performed weekly EPA Test Method 22 visual observations on each particulate matter control device. The permittee performed EPA Test Method 9 if an emission source failed the EPA Test Method 22. The visual observation requirements have been removed for Emission Points AC-001, AC-002, AC-003, AC-004, AC-008, AC-009, AC-010, AD-001, AF-001, AF-002, AF-003, AF-006, and AF-007 because the emission sources have maximum uncontrolled PM, PM10, and PM2.5 emissions less than the major source thresholds. The permittee will perform monthly inspections of each control device.

EMISSION SUMMARY
Table 2. Comparison of Facility-Wide Uncontrolled and Proposed Allowable Emissions in tpy	
Pollutant	Uncontrolled Emissions	Proposed Allowable Emissions	Proposed Allowable Exceed Title V Threshold (Yes/No)3 ?	
PM	189481	1862 	No	
PM10	94721	92.82 (95.0)3	No	
PM2.5	47371	46.12 (95.0)3	No	
SO2	93.0	76.5	No	
NOx	26.2	22.4	No	
CO	15.4	13.1	No	
VOC	1.0	0.86	No	
Individual HAP	< 10.0	0.02	No4	
Total HAP	< 25.0	0.02	No4	
Notes:
1.	Uncontrolled emissions without control devices (e.g., baghouses and cyclones).
2.	Proposed allowable emissions are reduced by limitations/restrictions.
3.	Proposed emission limitation.
4.	The Title V major source threshold for criteria pollutants (PM10, SO2, NOx, CO, and VOC) is 100 tpy.
5.	The Title V major source threshold for individual and total HAP emissions are 10 and 25 tpy, respectfully.	
Koch has the potential to exceed the Title V major source threshold of 100 tons per year (tpy) for PM10 and PM2.5 emissions, as seen in Table 2. Koch shall limit facility-wide PM10 and PM2.5 emissions to 95.0 tpy and demonstrate compliance through monitoring and recordkeeping. For Emission Points AB-001, AB-002, AB-003, AC-001, AC-002, AC-003, AC-004, AC-005, AC-006, AC-007, AC-008, AC-009, AC-010, AD-001, AE-001, AE-002, AE-003, AF-001, AF-002, AF-003, AF-006, and AF-007 the permittee is required to route all emissions to a control device and operate the control devices at all times while processing. The operating restrictions will allow controlled emissions to remain below the Title V threshold. The permittee will perform stack testing on Emissions Points AC-005, AC-006, AC-007, AE-001, AE-002, and AE-003. The facility will demonstrate compliance via monitoring and recordkeeping. The facility has the potential to exceed the Prevention of Significant Deterioration threshold of 250 tpy for PM, as seen in Table 2. The facility will remain a moderate source under the PSD program by routing all emissions to control devices and operating all control devices while processing to avoid PSD.

APPLICABLE/PROPOSED PERMIT LIMITATIONS
The following conditions were included in the permit to ensure that Koch remains under the Prevention of Significant Deterioration and Title V major source thresholds:
•	For the entire facility, the permittee shall not emit smoke emissions in excess of 40 percent opacity.
o	The facility will demonstrate a large margin of compliance by routing all PM emissions to a control device and operating all control devices while processing animal feed.
•	For the entire facility, the permittee shall not emit contaminants that could cause a nuisance to nearby properties.
•	For the entire facility, the permittee shall limit PM10 and PM2.5 to 95.0 tpy, as determined on a monthly basis and for each consecutive 12-month period on a rolling basis. 
o	The permittee shall monitor and record PM10 and PM2.5 emissions in tpy, as determined on a monthly basis and for each 12-month period on a rolling basis. Emissions shall be calculated using, but not limited to, control device data, feed throughput, hours of operation, manufacturer’s specifications, stack testing, and EPA AP-42.
o	For Emission Points AC-005, AC-006, AC-007, AE-001, AE-002, and AE-003, the permittee shall conduct triennial stack tests on a rotational basis. The permittee shall stack test a respective control device once every 3 years, not to exceed 36 months from the previous stack test.
•	For the entire facility, the permittee shall not exceed the filterable PM emission rate: E=4.1p0.67.
o	The facility demonstrated a wide margin of compliance with engineering calculations.
•	Emission Points AA-001 and AA-002 shall not exceed 4.8 pounds (measured as sulfur dioxide) per million BTU heat input.
o	Emission Points AA-001 and AA-002 shall combust natural gas and low sulfur diesel which guarantees a large margin of compliance.
•	Emission Points AA-001 and AA-002 shall no exceed the filterable PM emission rate: E = 0.8808*I-0.1667.
o	Emission Points AA-001 and AA-002 shall only combust natural gas and low sulfur diesel which guarantees a wide margin of compliance.
•	Emission Points AA-001 and AA-002 shall only combust natural gas and/or distillate fuel oil.
o	Fuel usage shall be determined by, but not limited to, fuel supplier records, natural gas meter, fuel receipts, etc.
•	Emission Points AB-001, AB-002, AB-003, AC-001, AC-002, AC-003, AC-004, AC-005, AC-006, AC-007, AC-008, AC-009, AC-010, AD-001, AE-001, AE-002, AE-003, AF-001, AF-002, AF-003, AF-006, and AF-007, the permittee shall route all emissions to the respective control device. The permittee shall operate each control device at all times when processing. Should the control technologies become nonoperational then the respective process shall be shut down immediately, but not as to cause damage to equipment or property, or cause further environmental problems. The process shall not startup until such time that the control technology becomes operational. The permittee shall maintain on hand at all times sufficient equipment as is necessary to repair and/or overhaul each control device at all times. The permittee shall maintain and perform quality assurance/quality control measures in accordance with the manufacture’s specifications.
o	For Emission Points AE-001, AE-002, and AE-003, the permittee shall perform weekly inspections of the cyclones according to 40 CFR 63, Subpart DDDDDDD.
o	For Emission Points AB-001, AB-002, AB-003, AF-004, and AF-005, the permittee shall perform monthly inspections of the control devices according to 40 CFR 63, Subpart DDDDDDD.
o	For Emission Points AC-001, AC-002, AC-003, AC-004, AC-005, AC-006, AC-007, AC-008, AC-009, AC-010, AD-001, AF-001, AF-002, AF-003, AF-006, and AF-007, the permittee shall perform monthly inspections of the control devices.
STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES (NSPS) APPLICABILITY
Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc)
The Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) was promulgated to regulate SO2 and PM emissions generated by steam generating units. Units subject to Subpart Dc commenced construction, modification, or reconstruction after June 9, 1989, and that has a maximum heat input capacity from fuels combusted in the steam generating unit of 100 MMBtu/hr or less, but greater than 10 MMBtu/hr. Emission Points AA-001 and AA-002 are subject to Subpart Dc because the boilers were constructed after 1989 and have heat input capacities greater than 10.0 MMBtu/hr (20.9 MMBtu/hr). Emission Points AA-001 and AA-002 can combust natural gas and distillate fuel oil. Both boilers are subject to the fuel sulfur concentration restriction, monthly fuel supplier certification recordkeeping, and monthly fuel combustion recordkeeping.
Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 (40 CFR 60, Subpart Kb)
The Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 (Subpart Kb) establishes emission limitations and operating limitations for each storage vessel with a capacity greater than or equal to 19,812.9 gallons that is used to store volatile organic liquids for which construction, reconstruction, or modification is commenced after July 23, 1984. Subpart Kb does not apply to storage vessels with a capacity greater than or equal to 39,890 gallons storing a liquid with a maximum true vapor pressure less than 3.5 kilopascals (kPa) or with a capacity greater than or equal to 19,812.9 gallons but less than 39,890 gallons storing a liquid with a maximum true vapor pressure less than 15.0 kPa. Emission Point AG-001 is not subject to Subpart Kb because the volatile organic liquid storage tank does not meet the capacity requirement of 19,812.9 gallons. Emission Point AG-002 meets the capacity requirement of 19,812.9 gallons (20,000 gallons) but does not meet the maximum true vapor pressure requirement of 2.17 psia (0.009 psia). Emission Points AG-001 and AG-002 are not subject to Subpart Kb.
Standards of Performance for Grain Elevators (40 CFR 60, Subpart DD)
The Standards of Performance for Grain Elevators (Subpart DD) applies to any grain terminal elevator which commences construction, modification, or reconstruction after August 3, 1978. Koch is a grain terminal elevator and was constructed after August 3, 1978. Koch processes and stores grain for poultry consumption. Subpart DD does not regulate facilities processing and storing animal feed. Koch is not subject to Subpart DD.
NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)/MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) APPLICABILITY
National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR 63, Subpart JJJJJJ)
The National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources (Subpart JJJJJJ) establishes national emission limitations and management practices for HAP emissions from industrial, commercial, and institutional boilers located at an area source of HAP. Emission Points AA-001 and AA-002 are defined as existing dual-fuel fired boilers meeting the definition of gas-fired boilers defined in 40 CFR 63.11237. Emissions Points AA-001 and/or AA-002 would only be considered an affected source if the facility performs a fuel switch. If the fuel switch occurs, the facility must provide notice of the date upon which the fuel switch occurs within 30 days of the change. Therefore, Emission Points AA-001 and AA-002 are potentially subject to Subpart JJJJJJ if a fuel switch occurs.
National Emission Standards for Hazardous Air Pollutants for Area Sources: Prepared Feeds Manufacturing (40 CFR 63, Subpart DDDDDDD)
The National Emission Standards for Hazardous Air Pollutants for Area Sources: Prepared Feeds Manufacturing (Subpart DDDDDDD) establishes national emission limitations and management practices for HAP emissions from prepared feeds manufacturing facilities that use a material containing chromium or a material containing manganese and is an area source of emissions of HAP. Koch uses materials containing chromium or manganese and is subject to Subpart DDDDDDD. Emission Points AE-001, AE-002, and AE-003 shall route all emissions to a cyclone for control. Emission Points AB-001, AB-002, AB-003, AF-004, and AF-005 shall minimize all fugitive emissions. Koch is subject to the Work Practice Standards of Subpart DDDDDDD.

PUBLIC PARTICIPATION
The 30-day public notice period began on June 15, 2022, 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.