DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Thomas Parker 	Date:	September 3, 2025

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 the Synthetic Minor Operating Permit (SMOP), Air Ref. No.: 2420-00051. The facility consists of the emission points listed and described in Table 1. 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-001a, AC-001b, 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, PM10, and PM2.5 emissions.

Table 1: Emission Point Description for Facility	
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-001a	----	Corn Transfer Conveyor Vent No. 1 controlled by Baghouse	
AC-001b	----	Corn Transfer Conveyor Vent No. 2 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)	

PROJECT/PERMIT ACTION DESCRIPTION

Koch has requested modification to the SMOP issued on July 18, 2022. The following changes were made to the SMOP:

•	Koch is proposing to install two grain (corn) transfer conveyor vents (Emission Points AC-001a and AC-001b) controlled by two small baghouse filters, respectively. Emission Points AC-001a and AC-001b will be connected to the conveyor system that serves approximately 68% of the grain (corn) storage. The function of the proposed baghouse filters is to vent the transfer conveyor to reduce internal pressure within the conveyor system. 

•	With the addition of Emission Points AC-001a and AC-001b, the facility will exceed the previously lowered facility-wide PM10 and PM2.5 emission limit of 95.0 tons per year (tpy). Therefore, Koch will need to revert to the PM10 and PM2.5 emission limit of 99.0 tpy to remain a synthetic minor source. 

o	Koch shall demonstrate compliance with the PM10 and PM2.5 limitations by conducting a performance test within 180 days of startup using Method 5 and 201, or an EPA approved equivalent.

•	There will be no changes from the SMOP issued on July 18, 2022, to the capacity or production of the facility.

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	18,963.71	191.62 	No	
PM10	9,480.41	95.92 (99.0)3	No	
PM2.5	4741.21	47.62 (99.0)3	No	
SO2	93.0	79.5	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 99.0 tpy and demonstrate compliance through monitoring and recordkeeping. For Emission Points AB-001, AB-002, AB-003, AC-001, AC-001a, AC-001b, 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 eligibility.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

The following conditions were included in the permit to ensure that Koch remains under the PSD 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 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 99.0 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 wide margin of compliance.

•	Emission Points AA-001 and AA-002 shall not 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.

•	For Emission Points AB-001, AB-002, AB-003, AC-001, AC-001a, AC-001b, 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 non-operational 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 manufacturer’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-001a, AC-001b, 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. 

NSPS APPLICABILITY

40 CFR 60, Subpart Dc (Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units): 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.

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 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.

40 CFR 60, Subpart DD (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.

MACT APPLICABILITY

40 CFR 63, Subpart JJJJJJ (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 currently not subject to Subpart JJJJJJ, unless a fuel switch occurs.

40 CFR 63, Subpart DDDDDDD (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 October 22, 2025, when the notice was posted on MDEQ’s website and ends November 21, 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.