DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Thomas Parker 	Date:	August 5, 2025

Company Name:	PCC GulfChem Corporation

Facility Location:	7685 Kiln DeLisle Road

Source Number:	1020-00205

County: 		Harrison

FACILITY DESCRIPTION

PCC GulfChem Corporation (PCC GulfChem) is proposing to locate at 7685 Kiln Delisle Road in Pass Christian, Mississippi 39571. PCC GulfChem plans to design, build, and operate a chlor-alkali facility (SIC Code: 2812). The facility will be contiguous and adjacent to Chemours Company FC LLC, The Delisle Plant (Chemours), but PCC GulfChem is considered a separate source. The facility is considered a separate source because Chemours and PCC GulfChem are not controlled from a central unified position through parent-subsidiary or other forms of corporate management relationships. The facility will import salt to make brine to manufacture liquid chlorine (Cl2) and be able to produce hydrochloric acid (HCl) and bleach (NaOCl) byproducts. PCC GulfChem will consist of thirteen (13) emission sources in a closed-loop system that primarily include emissions of particulate matter (PM), PM less than 10 micrometers (µm) (PM10), PM less than 2.5 µm (PM2.5), nitrogen oxide (NOx), Cl2, and HCl. Based on the Permit to Construct application, the facility will be a true minor source under the Prevention of Significant Deterioration (PSD) construction permitting program and Title V operating permit program for all pollutants. The emission points at the proposed facility are listed in the table below.

Emission Point	Description	
AA-001	Salt Unloading and Storage	
AA-002	Waste Gas Dechlorination Unit
Controlled by Scrubber	
AA-003	HCl 32% Truck Loading Rack	
AA-004	HCl 32% Storage Tank
47,551-gallon Storage Capacity	
AA-005	HCl 32% Storage Tank
47,551-gallon Storage Capacity	
AA-006	HCl 15% Storage Tank
47,551-gallon Storage Capacity	
AA-007	HCl 15% Storage Tank
47,551-gallon Storage Capacity	
AA-008	Cooling Tower	
AA-009	Diesel-Fired CI Emergency Generator (South Plot)
670.511 hp/ 500 kW, 4.78 MMBTU/hr	
AA-010	Diesel-Fired CI Emergency Generator (North Plot)
1,341.02 hp/ 1 MW, 10.55 MMBTU/hr	
AA-011	1.5 MW (14.52 MMBTU/hr) Diesel-Fired CI Emergency Generator (North Plot)
2,011.533 hp/ 1.5 MW, 14.52 MMBTU/hr	
AA-012	Diesel-Fired CI Emergency Firewater Pump (North Plot)
670.511 hp/ 500 kW, 4.78 MMBTU/hr	
AA-013	Truck Loading Rack for HCl and Byproducts	

PROJECT/PERMIT ACTION DESCRIPTION

PCC GulfChem will import salt to make brine to manufacture liquid chlorine (Cl2). The brine will pass through electrolyzers where it will undergo electrolysis. During this process the chloride ions (Cl-) from the sodium chloride (NaCl) will be oxidized at the anode and converted to chlorine gas (Cl2), and the water molecules will be reduced, forming hydrogen gas (H2) and hydroxide ions (OH-). The chlorine gases will undergo drying and liquefication processes to produce the final liquid chlorine product, and the hydrogen gases will be filtered and sent through the HCl Synthesis Unit. 

The facility will also produce useful byproducts that include hydrochloric acid (HCl) and bleach (NaOCl). HCl will be recovered using a Waste Gas Dechlorination Unit (Emission Point AA-002) equipped with a wet scrubber. NaOCl will be produced as a reaction between Cl2 gas recovered by the scrubber and caustic soda (NaOH). The HCl may be sent to the Truck Loading Rack (Emission Point AA-013) or diluted and diverted back into the system. The bleach will be chlorinated to achieve selling specifications and sent to the bleaching lye storage tanks or the Truck Loading Rack (Emission Point AA-013). 

The project will include operations at two separate plots on site: a North plot and a South plot. The two plots will be integrated, and all associated emissions will be routed through the Waste Gas Dechlorination Unit (Emission Point AA-002) equipped with a wet scrubber located at the North plot. The wet scrubber is considered inherent to the process. The chlorine facility will consist of thirteen (13) emission sources that include PM from salt unloading, Cl2 emissions from the scrubber, and HCl emissions from the HCl Storage Tanks (Emission Points AA-004, AA-005, AA-006, and AA-007) and the Truck Loading Rack (Emission Point AA-013). The process will operate in a closed-loop system. So, emissions from chemical production will be minimal. The system has been designed to a much greater capacity than it will operate, meaning the potential emissions would still be minimal even in the event of an emergency scenario.
 
PCC GulfChem will receive sulfuric acid (H2SO4), sodium carbonate (Na2CO3), sodium bisulfite (NaHSO3), and NaOH. However, none of the materials will generate criteria or HAP emissions. Likewise, the facility will produce byproducts like anolyte from electrolysis, brine after dichlorination, H2SO4, and H2 that will not generate any regulated emissions.

EMISSION SUMMARY

Facility-Wide Potential Emissions Summary
Pollutant	New Construction Potential Emissions 
(tons/yr)	
PM	64.02	
PM10	30.72	
PM2.5	4.76	
SO2	0.01	
NOx	31.03	
CO	7.12	
Cl2	0.29	
HCl	2.32	
Total VOCs	0.90	
Total HAPs	2.61	

The proposed chlor-alkali facility is subject to the PSD major source threshold of 100 tons per year (tons/yr) because the industry is a Chemical Plant, which is one of the 28 named sources specified in the Mississippi Regulations for PSD of Air Quality, 11 Miss. Admin. Code Pt. 2, Ch. 5, and more specifically in 40 CFR 52.21. The emissions from this project will remain below the PSD significant levels because the process is primarily close-looped, and the uncontrolled emissions are significantly below the threshold limits of 100 tons per year to be a true minor source.

The wet scrubber controlling Emission Point AA-002 is considered inherent to the process. In PPC GulfChem’s application, the applicant answered the following three (3) questions to determine if a process is inherent or not:

(1)	Is the primary purpose of the equipment to control air pollution?
•	No, the wet scrubber is integrated into the closed-loop process for manufacturing chlorine and byproducts. Also, the scrubber is for ensuring employee safety and generating bleach, which can be sold or returned to the process.

(2)	Where is the equipment recovering product? How do the cost savings from the product recovery compare to the cost of the equipment?
•	The facility has a proposed Truck Loading Rack (Emission Point AA-013) to transport and sell the produced bleach, HCl, and other byproducts. The Waste Gas Dechlorination Unit (Emission Point AA-002) installation cost will amount to approximately $21.3 million with an internal rate of return greater than 25%.

(3)	Would the equipment be installed if no air quality regulations were in place?
•	Yes, the wet scrubber is integrated due to a closed-loop system and for process safety for employees. The scrubber is not installed for pollution control of Emission Point AA-002.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

•	11 Miss. Admin. Code Pt. 2, R. 1.3.C.:
o	Shall not allow emissions of contaminants in sufficient amounts to be injurious to humans, plants, or property, or to be a public nuisance, or create a condition of air pollution.

•	11 Miss. Admin. Code Pt. 2, R. 1.3.F(1).:
o	Particulate matter limited by the relationship E = 4.1 × p0.67, where “E” is the emission rate in pounds per hour and “p” is the process weight input rate in tons per hour.

•	11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(a).:
o	Particulate emissions from biogas treatment less than 10 MMBTU/hr limited to 0.6 lbs/MMBTU

•	11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(b).:
o	Ash and/or particulate matter from fossil fuel burning installations limited by the relationship E = 0.8808 * I-0.1667, where “E” is the emission rate in pounds per million BTU per hour heat input and “I” is the heat input in millions of BTU per hour.

NSPS APPLICABILITY

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): This standard is applicable to storage vessels with a capacity greater than or equal to 20,000 gallons that are used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification commenced after October 4, 2023. Subpart Kc is potentially applicable as PCC GulfChem plans to install four (4) hydrochloric acid storage vessels with capacities greater than 20,000 gallons. However, these tanks will store aqueous solutions of hydrochloric acid which does not meet the definition of VOL. Therefore, the facility is not subject to Subpart Kc.

40 CFR 60, Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines): This regulation applies to owners or operators of stationary compression ignition (CI) internal combustion engine (ICE) that commence construction, modification, or reconstruction after July 11, 2005, and to manufacturers of 2007 and later model year CI ICE. Subpart IIII provides emission limitations, fuel requirements, and operational requirements for applicable CI ICE. The facility plans to have three (3) diesel-fired generators and one (1) diesel-fired firewater pump that are subject to this subpart.

MACT APPLICABILITY

40 CFR 63, Subpart ZZZZ (National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines): This subpart regulates HAP emissions from existing, new, and reconstructed stationary CI and spark ignition (SI), emergency and non-emergency, reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions. The diesel generators are subject to Subpart ZZZZ. The diesel generators will demonstrate compliance with Subpart ZZZZ by complying with Subpart IIII.

40 CFR 63, Subpart CCC (National Emissions Standards for Hazardous Air Pollutants for Steel Pickling – Hydrochloric Acid (HCl) Process Facilities and HCl Regeneration Plants): This subpart is applicable to all new and existing steel pickling facilities and hydrochloric acid regeneration plants that are major sources for HAP. PCC GulfChem is not a major source of HAP and as such, is not subject to Subpart CCC.

40 CFR 63, Subpart EEEE (National Emissions Standards for Hazardous Air Pollutants: Organic Liquids Distribution (Non-Gasoline)): This subpart establishes national emission limitations, operating limits, and work practice standards for organic HAPs emitted from organic liquids distribution (OLD) (non-gasoline) operations at major sources of HAP emissions. Since PCC GulfChem does not have an OLD operation, the facility is not subject to Subpart EEEE.

40 CFR 63, Subpart NNNNN (National Emissions Standards for Hazardous Air Pollutants: HCl Production): This subpart establishes national emission standards for HAPs associated with the production of HCl. PCC GulfChem is not considered a major source of HCl production. Therefore, the facility is not subject to Subpart NNNNN.

PUBLIC PARTICIPATION

The 30-day public notice period began on August 6, 2025, when the notice was posted on MDEQ’s website and ends September 5, 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.