DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Thomas Parker	Date:	July 22, 2025

Company Name:	Saunders Midwest LLC

Facility Location:	6604 Old Highway 80 West

Source Number:	1460-00131

County: 		Lauderdale

FACILITY DESCRIPTION

Saunders Midwest LLC (Saunders) was issued an Air Permit to Construct on May 13, 2022, to build a fiberglass components manufacturing facility. The facility is located at an existing warehouse in Meridian and falls under the SIC code 3089 (Plastic Products, not elsewhere classified) and NAICS code 325991 (Custom Compounding of Purchased Resins). The facility can manufacture approximately 3,000,0000 fiberglass parts (shovel and axe handles) each year. The process includes combining raw materials into two (2) mixers then routing the mixture to four (4) pultrusion lines. Raw products are added in batches of a maximum of 100 pounds for each mixer, and resin accounts for approximately 87% of mix. The process also consists of extruding, cutting, sawing, shaping, and laser printing. Additional air emissions equipment includes natural gas-fired space heaters and parts washing. Each mixer, the laser printing operations, cutting, sawing, and shaping are equipped with dust collection systems. The table below provides a summary of the emission points at the facility.

Emission Point	Facility Ref. No.	Description	
AA-001	M-001	Resin and Additives Mixer #1 Operations	
AA-002	M-002	Resin and Additives Mixer #2 Operations	
AA-003	PL-1	Pultrusion Line #1	
AA-004	PL-2	Pultrusion Line #2	
AA-005	PL-3	Pultrusion Line #3	
AA-006	PL-4	Pultrusion Line #4	
AA-007	--	Eighteen (18) 0.2 MMBtu Natural Gas-Fired Space Heaters	
AA-008	--	Extruding Operations	
AA-009	--	Cutting, sawing, and shaping operations equipped with dust collector	
AA-010	--	Laser Printing Operations equipped with dust collector	
AA-011	--	Part Washing Operations	

PROJECT/PERMIT ACTION DESCRIPTION

The facility certified construction of all the equipment addressed in the Permit to Construct on September 7, 2023, except for Mixer #3, Mixer #4, and Pultrusion Line #5. Saunders will not be installing the three (3) pieces of equipment mentioned above. The facility is not one of the 28 listed source categories in 40 CFR 52.21(b)(1)(i)(A), and potential emissions are below the Prevention of Significant Deterioration (PSD) threshold of 250 tons per year (tpy) for a major stationary source. Potential emissions for Volatile Organic Compounds (VOC) and Hazardous Air Pollutants (HAPs) exceed the Title V threshold of 100 tons per year (tpy) for VOC and 10 tpy for an Individual HAP (i.e., styrene). Therefore, the facility is proposing to maintain a Synthetic Minor status by requesting facility-wide limits of 25.0 tpy for VOC, 24.0 tpy for Total HAP, and 9.0 tpy for Individual HAP. 

After inspection from the Environmental Compliance and Enforcement Division (ECED), Saunders received a Notice of Violation (NOV) for not having dust collectors installed on Mixer #1 (Emission Point AA-001) and Mixer #2 (Emission Point AA-002). Initially, the construction application proposed that the mixer vats would be much greater in size allowing several “mixes” to be prepared and used throughout each day. However, the product specifications changed from the time production ceased at the previous location to the time the installation began at the current facility. Currently, Emission Points AA-001 and AA-002 have a maximum design capacity of 100 pounds and typically only hold one 40-pound mixture of resin product each. Along with the specification change to the mixers, the amount of solid products introduced to the mixture decreased to approximately 2-5 pounds. The decreased size of the mixers means dust collection is not feasible due to the flammable vapor atmosphere within the facility.

EMISSION SUMMARY

Pollutant	Uncontrolled Emissions1
(tpy)	Proposed Allowable Emissions
(tpy)	Proposed Allowable Exceed Title V Major Source Threshold (Yes/No)4?	
PM	17.13	0.53	No	
PM10	17.12	0.52	No	
PM2.5	0.03	0.03	No	
SO2	0.01	0.01	No	
NOx	0.03	0.03	No	
CO	5.1	5.1	No	
VOC	362.6	20.02 (25.0)3	No	
Styrene	123.6	6.82 (9.0)3	No	
Total HAP	123.6	6.82 (24.0)3	No	
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.	

The manufacturing of fiberglass components noted in the facility description have the potential to emit (PTE) the following Title V pollutants: Particulate Matter with a diameter of 10 µm or less (PM10), Particulate Matter with a diameter of 2.5 µm or less (PM2.5), VOC, and HAPs. Potential emissions of VOC, Individual HAPs, and Total HAPs could exceed the Title V thresholds of 100.0 tpy, 10.0 tpy, and 25.0 tpy, respectively. Therefore, Saunders proposes to maintain the current emissions limits and control requirements to remain a synthetic minor source. Limits on VOC and HAPs will be applied to the fiberglass operations, since styrene is the primary pollutant of concern emitted from those operations. 

APPLICABLE/PROPOSED PERMIT LIMITATIONS

Facility-Wide Requirements:

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10):
o	≤ 25.0 tons per year of VOC
o	≤ 24.0 tons per year of total HAP
o	≤ 9.0 tons per year of any single HAP

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11):
o	Determine compliance with VOC and HAP limits by monitoring and recording the identity and characteristics of all VOC- and/or HAP-containing material used at the site
o	Report deviations within five (5) days
o	Submit a certified annual monitoring report including facility wide VOC and HAP.
o	Certify all submitted reports by a responsible official

•	11 Miss. Admin. Code Pt. 2, R. 1.3.A and 1.3.B:  
o	≤ 40% opacity and equivalent opacity

•	11 Miss. Admin. Code Pt. 2, R. 1.3.F(1): 
o	Limit particulate matter by the relationship E = 4.1 × p0.67 where “E” is the emission rate and “p” is the throughput. The potential to emit PM is well below the PM state limitation for manufacturing.

•	11 Miss. Admin. Code Pt. 2, R. 2.9:
o	Maintain records for a minimum of five (5) years.

Emission Points AA-009 and AA-010 Requirements:

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10): 
o	Minimize particulate matter emissions by operating dust controls during operation and maintaining each in accordance with manufacturers’ specifications. This will ensure compliance with the State standards for PM and opacity.

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11):
o	Inspect dust collectors and perform regular maintenance each month to maintain proper operation of the equipment, keep records of maintenance in log form, and maintain onsite equipment sufficient to repair the equipment.

•	Emission Points AA-001 and AA-002 have been removed from these requirements since dust collectors were never installed on the mixers.

Emission Points AA-001 and AA-002 Requirements:

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11):  
o	Monitor and record throughput of dry material added to the mixers.  

Emission Point AA-007 Requirements:

•	11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(a): 
o	  0.6 lb of PM per MMBtu

•	11 Miss. Admin. Code Pt. 2, R. 1.4.A(1):
o	Emission Point AA-007 is not applicable to this regulation since the eighteen (18) wall heaters transfer heat directly into the air.

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): This subpart applies to storage vessels. No storage vessels have been proposed at the facility; therefore, this subpart does not apply.

MACT APPLICABILITY

40 CFR 63, Subpart WWWW (National Emissions Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production): This subpart applies to new or existing reinforced plastic composites production facilities at a major source of HAPs. The facility is requesting minor source limits; therefore, this subpart does not apply.

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.