DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Thomas Parker 	Date:	August 20, 2025

Company Name:	Omega Protein, Inc

Facility Location:	5735 Elder Ferry Road
Moss Point, MS 39562

Source Number:	1280-00030

County: 		Jackson

FACILITY DESCRIPTION

Omega Protein, Inc (Omega) owns and operates a fish meal/fish oil production facility (SIC Code: 2077) that operates from April to November each year. During the fishing and processing season, Omega gathers menhaden in the gulf and processes the fish into several products. The facility is a source of Particulate Matter (PM), PM less than 10 µm (PM10), PM less than 2.5 µm (PM2.5), Sulfur Dioxide (SO2), Carbon Monoxide (CO), Volatile Organic Compound (VOC), and Hazardous Air Pollutant (HAP) emissions. The facility operates under Synthetic Minor Operating Permit (SMOP), Air Ref. No. 1280-00030. Omega has the potential to exceed the Title V major source threshold for VOC emissions. The facility restricts VOC emissions by limiting hours of operation and production. Omega determines compliance with the limitations by monitoring and recordkeeping. The emission points of the facility are shown in the tables below.

Table 1: Facility Emission Point Descriptions	
Emission
Point	Facility
Reference	Description	
AA-011	EQPT1	106 MMBTU/hr Natural Gas-fired Boiler	
AA-012	T-14	153,000-gallon #2 Diesel Fuel Oil Storage Tank	
AA-013	GRPT1	Common Vent Stack	
AA-014	T-30	460-gallon Gasoline Storage Tank	
AA-015	T-31	980-gallon #2 Diesel Fuel Oil Storage Tank	
AA-016	T-11	509,000-gallon Fish Oil Storage Tank	
AA-017	T-17	1,850-gallon Hydraulic Oil Storage Tank	
AA-018	T-18	2,166-gallon Lube Oil Storage Tank	
AA-019	T-19	11,923 gallon Used Oil Storage Tank	
AA-020	T-3	308,350-gallon Fish Oil Storage Tank	
AA-021	T-5	9,057-gallon Fish Oil Storage Tank	
AA-022	T-6	8,714-gallon Fish Oil Storage Tank	
AA-023	T-16	509,000-gallon Fish Oil Storage Tank	
AA-024	AREA2	25 ton/hr Cooker #1	
AA-025	AREA3	25 ton/hr Cooker #2	
AA-026	AREA4	25 ton/hr Cooker #3	
AA-027	T-20B	12,000-gallon Net Dip Storage Tank	
AA-029	01-15-VAT	Net Dipping Vat: Coats fishing nets with Asphalt Cutback solution and Mineral Spirits	
AA-030	02-15-CS	Salmonella Inhibitor Spraying: Reduces salmonella and mold growth on fish stockpiles	
AA-031	07-15-DS	Deodorizer Spraying: Minimize stack odor	
AA-032	T-24
06-15-MSST-V	9,500 gallons Mineral Spirits Storage Tank	
AA-034	04-15-DRY-BS	90 MMBTU/hr Natural Gas-fired Secondary Dryer	
AA-036	T-1	20,304-gallon Concentrated Fish Solubles	
AA-037	T-2	308,350-gallon Omega Grow (concentrated fish solubles)	
AA-038	T-4	300,000-gallon Stick Water	
AA-039	T-7	20,304-gallon Concentrated Fish Solubles	
AA-040	T-9	5,208-gallon Concentrated Fish Solubles	
AA-041	T-26	9,408-gallon Omega Grow (concentrated fish solubles)	
AA-042	T-27	9,408-gallon Omega Grow (concentrated fish solubles)	
AA-043	T28	11,000-gallon Bilge Water	
AA-044	T-32	10,000-gallon Fish Oil	
AA-045	T-33	10,000-gallon Fish Oil	
AA-046	T-34	58,750-gallon Bail Water	
AA-047	T-35	36,000-gallon Bail Water	
AA-048	-----	Ammonia Stripper: Lowers content of ammonia in wastewater stream from the evaporators	
AA-049	No. 2 Meal Cooler	Number 2 Meal Cooler controlled by baghouse	
AA-050	AREA5	35 ton/hr Cooker #4	
AA-051	-----	Evaporative Condenser	
AA-052	-----	Evaporative Condenser	
AA-053	T-46	500,000-gallon Fish Oil Storage Tank
Maximum True Vapor Pressure less than 3.5 kPa	

Table 2: Emission Point to Common Vent Stack Descriptions	
Emission Point AA-013 – Common Vent Stack
The Common Vent Stack receives emissions from the following emission points and vents the emissions to the atmosphere.	
Emission
Point	Facility
Reference	Description	
AA-003	-----	73.3 MMBTU/hr Natural Gas-fired Boiler	
AA-033	05-15-DRYER	Primary Dryer Vent	

Table 3: Emission Point to Primary Dryer Vent Descriptions	
Emission Point AA-033 – Primary Dryer Vent
The Primary Dryer Vent receives emissions from the following emission points and vents the emissions to AA-013.	
Emission
Point	Facility
Reference	Description	
AA-004	-----	16.5 MMBTU/hr Natural Gas-fired Dryer controlled by cyclone 	
AA-005	-----	15.2 MMBTU/hr Natural Gas-fired Dryer controlled by cyclone	
AA-006	-----	16.5 MMBTU/hr Natural Gas-fired Dryer controlled by cyclone	
AA-007	-----	16.0 MMBTU/hr Natural Gas-fired Dryer controlled by cyclone	

PROJECT/PERMIT ACTION DESCRIPTION

Omega requests the reissuance of the SMOP with the following modifications:

•	Updated the emission factors for PM, NOx, CO, and VOC in accordance with the August 2023 stack results.

•	Updated the hours of operation from 3,000 hours per year to 2,600 hours per year for the entire facility, except as otherwise noted.

•	Updated Emission Point AA-003 to not exceed 3,000 hours of operation per year instead of 3,400 hours per year. Updated Emission Point AA-011 to not exceed 3,000 hours of operation per year instead of 3,800 hours per year.

•	Updated the VOC content and usage for Emission Points AA-029 and AA-033 based on site data from the last five years with an updated Safety Data Sheet (SDS).

•	Updated the facility emission calculations in accordance with the most recent AP-42 Chapter 7 guidance finalized in June 2020.

EMISSION SUMMARY

Table 4: Comparison of Facility-Wide Uncontrolled and Proposed Allowable Emissions in tpy	
Pollutant	Uncontrolled Emissions
(tpy)	Proposed Allowable Emissions
(tpy)	Proposed Allowable Exceed Title V Major Source Threshold (Yes/No)?	
PM	230.03	67.69	No	
PM10	230.03	67.69	No	
PM2.5	229.94	67.67	No	
SO2	1.05	0.28	No	
NOx	62.09	10.88	No	
CO	94.77	21.61	No	
VOC	266.98	96.58	No	
Individual HAP	< 10.0	< 10.0	No	
Total HAP	3.56	1.13	No	

Omega has the potential to exceed the Prevention of Significant Deterioration major source threshold of 250.0 tpy for VOCs and the Title V major source threshold of 100.0 tpy for PM10 and VOCs, as seen in Table 4. The facility will remain below the VOC threshold by instituting a facility-wide emissions limitation of 99.0 tpy for VOCs. An emissions limitation for PM10 is not needed due to the uncontrolled emissions being calculated for the facility operating 8,760 hours per year. Since the facility only operates 2,600 hours per year from April to November, the PM10 uncontrolled emissions are below the Title V major source threshold of 100.0 tpy.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

Omega will comply with the following requirements to remain under the Prevention of Significant Deterioration and Title V major source thresholds:

•	The permittee shall limit VOC emissions to 99.0 tpy, as determined on a monthly basis and for each consecutive 12-month period on a rolling basis. Emissions shall be calculated using, but not limited to, hours of operation, production, solution sprayed, etc.

o	The permittee shall demonstrate compliance with the VOC emission limit by keeping a record of calculated VOC emissions on a monthly basis and for each consecutive 12-month period on a rolling basis.

•	Except as otherwise stated in the permit, operation of the entire facility shall not exceed 2,600 hours per year. The permittee shall determine hours of operation on a monthly basis and for each consecutive 12-month period on a rolling basis.

o	The permittee shall demonstrate compliance with hours of operation restriction by keeping a record of the hours operated on a monthly basis and for each consecutive 12-month period on a rolling basis.

•	Emission Points AA-003, AA-004, AA-005, AA-006, AA-007, AA-011, and AA-034 shall only combust natural gas. Fuel usage shall be determined by, but not limited to, fuel supplier records, natural gas meter, fuel receipts, etc.

o	The permittee shall record and maintain records of the amount of natural gas combusted during each calendar month. Fuel usage shall be determined by, but not limited to, fuel supplier records, natural gas meter, fuel receipts, etc.

•	Emission Points AA-003 and AA-011, the permittee shall allow additional hours of operation. Emission Points AA-003 and AA-011 shall not exceed 3,000 hours of operation per year. The permittee shall determine hours of operation on a monthly basis and for each consecutive 12-month period on a rolling basis.

o	The permittee shall keep a record of the hours operated per month for each emission point. The records shall be kept for each consecutive 12-month period on a rolling basis.

•	For Emission Points AA-004, AA-005, AA-006, AA-007, and AA-049, the permittee shall operate the control devices at all times when processing. Should the control devices 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 times that the control devices become operational. The permittee shall maintain on hand at all times sufficient equipment as is necessary to repair and/or overhaul the pollution control equipment.

o	The permittee shall perform routine maintenance inspections on all control devices and air emission equipment on a weekly basis to make sure it is operating as designed. A record documenting the date of the inspections, the name of the person who performs the inspections, and any maintenance conducted shall be kept at the facility and be made available to MDEQ upon request.

•	Emission Points AA-023, AA-024, AA-025, and AA-050 shall limit the weight of fish processed to 255,000 tons per year, as determined for each consecutive 12-month period on a rolling basis.  

o	The permittee shall keep a record of the weight of fish, in tons, processed each month for each consecutive 12-month period on a rolling basis.

•	For Emission Point AA-029, the permittee shall keep the emission point closed when not in use.

o	The permittee shall inspect the vat daily when in use and keeping a log of the data, time, and personnel performing the inspection. The log shall indicate any time that the vat is open while not in use, which is considered a deviation.

•	Emission Point AA-031 shall limit the solution sprayed to no more than 2,880 gallons per year, as determined for each consecutive 12-month period on a rolling basis.

o	The permittee shall keep a record of the Safety Data Sheet for each solution used and gallons of solution sprayed each calendar month for each consecutive 12-month period on a rolling basis.

NSPS APPLICABILITY

40 CFR 60, Subpart Kb (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 AA-053 has a storage capacity of 500,000 gallons and the maximum true vapor pressure is 0.0484 psia (0.33 kPa). Emission Point AA-053 is not subject to Subpart Kb.

MACT APPLICABILITY

None.

PUBLIC PARTICIPATION

The 30-day public notice period began on April 22, 2026, when the notice was posted on MDEQ’s website and ends May 22, 2026.