INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
6/24/2026

GENERAL FACILITY INFORMATION
Facility Name:  Bimbo Bakeries USA Inc
Facility Address:  
3400 Saint Paul Street
Meridian, MS 39301    
County: Lauderdale
SIC Code(s): 2051 (Bread and Other Bakery Products, Except Cookies and Crackers)
NAICS Code(s): 311812 (Commercial Bakeries)

APPLICATION SUMMARY 
Permit No.: 1460-00104
Permit Action:  Renewal
Permit Folder: PER20250001
Application Receipt Date: 5/20/2025
Application Deemed Complete: 1/20/2026
CBI Submitted?: No	NSPS (Part 60): N/A
NESHAP (Part 61): Subpart M
NESHAP (Part 63): N/A
112(r) / RMP: N/A
Other: N/A	
FACILITY DESCRIPTION
Bimbo Bakeries USA, Inc. is a commercial bakery operation that has applied for a reissuance of the Title V Operating Permit (TVOP). The facility operations begin with the pneumatic flour transfer system (Emission Point AA-004), which supplies (3) mechanical sifters and two (2) hoppers with flour from six (6) silos. The flour is then distributed to four (4) mixers where it is combined with yeast, water, and other ingredients. The dough is divided and molded into metal pans and then placed in a proof box where humidified conditions allow the yeast to ferment. The steam is supplied by two (2) natural gas-fired boilers, which are vented through a common stack. The dough is then transferred to one (1) of three (3) natural gas-fired ovens (Emission Points AA-001, AA-002, and AA-003). The emissions from natural gas combustion, yeast fermentation, and baking activities are combined through a single stack for each oven before they are released to the outside. The finished product is allowed to cool and then it is packaged.

TITLE V SOURCE APPLICABILITY 
The facility’s potential-to-emit (PTE) exceeds the Title V major source threshold of 100 tons per year (tpy) for each of the following criteria air pollutants: volatile organic compounds (VOCs). The facility’s potential-to-emit hazardous air pollutants (HAPs) does not exceed the major source threshold of 25 tpy of total HAPs and 10 tpy for any individual HAP.

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions
(tons/yr)	
Particulate Matter (TSP)	14.31	
PM10	14.31	
PM2.5	14.31	
Sulfur Dioxide (SO2)	0.04	
Nitrogen Oxides (NOx)	6.56	
Carbon Monoxide (CO)	5.51	
Volatile Organic Compounds (VOC)	245.01	
Total HAP 	0.1240	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The facility is not one of the 28 categorical facilities listed in 40 CFR 52.21(b)(1)(i)(c)(iii); therefore, the PSD threshold for a major source is 250 tpy. The facility has the potential to emit more than 250 tons per year of VOCs but will continue to limit facility-wide emissions of VOCs below this threshold. The facility will maintain VOC emissions below this threshold by continuing to limit VOC emissions from the bread ovens (i.e. Emission Points AA-001, AA-002, and AA-003) to 245.0 tpy by tracking the throughputs of the various products made; therefore with the only other sources of VOCs being two (2) natural gas-fired boilers, ink jet coding, and space heaters which classify as “Insignificant Activities,” the facility will continue to be considered a moderate stationary source.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
The emission limitation of 4.8 lb/MMBTU of sulfur dioxide (SO2) has been removed for the ovens (Emission Points AA-001, AA-002, and AA-003) because the standard applies to units that transfer heat indirectly.  These emission units transfer heat directly to the product; therefore, they are not subject to 11 Miss. Admin. Code Pt. 2, R. 1.4.A(1). This regulation will remain in place for two (2) boilers because they use indirect heat transfer. The boilers are considered “insignificant” because they have a capacity less than 10 MMBTU/hr and are natural gas-fired (in accordance with 11 Miss. Admin. Code Pt. 2, R. 6.7.B(2)). The facility combusts only natural gas so the impact on emissions of SO2 are expected to be minimal. There are no modifications to the facility or other significant permit changes proposed as part of this permitting action.

COMPLIANCE ASSURANCE MONITORING (CAM) APPLICABILITY
40 CFR Part 64 specifies the requirements for CAM.  The general applicability of this rule can be found in 40 CFR 64.2 and requires a Title V source to comply with the CAM requirements if all three of the following criteria are met for a pollutant-specific emission unit (PSEU):

1.	The unit is subject to an emission limitation or standard for a regulated air pollutant other than exemptions under 40 CFR 64.2(b)(1);
2.	The unit uses a control device to comply with the standard; and
3.	The unit has pre-control emissions exceeding Title V major source threshold.

The pneumatic flour transfer system (Emission Point AA-004) has a total of twenty-four (24) relief vents equipped with filter bags. These vents are an integral part of the transfer system and, therefore, are not considered add-on control devices (i.e. inherent to the process). Moreover, the facility does not operate any control devices to comply with an emission standard. Therefore, CAM is not applicable.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

40 CFR 61, Subpart M – National Emission Standard for Asbestos: The facility has asbestos in several areas of the facility. If this material is removed, the facility will be subject to all applicable federal, state, and local notification and work practice standards requirements, including compliance with 40 CFR 61, Subpart M.

40 CFR 63, Subpart JJJJJJ – National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers (Area Sources): The facility operates two (2) natural gas-fired boilers, which provide steam for humidification of the proof boxes.  As natural gas-fired boilers are exempt from the requirements of this subpart [based on 40 CFR 63.11195(e); Subpart JJJJJJ], the facility is not subject to this subpart. 

40 CFR, Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters:  This subpart applies to boilers and process heaters at major sources of HAP.  This facility is considered an area source; therefore, the facility is not subject to this subpart.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR 60, Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units: This subpart applies to facilities with steam generating units for which construction, modification, or reconstruction began after June 9, 1989, and that have a maximum design heat input capacity of greater than 10 million British thermal units per hour (MMBTU/hr) but less than 100 MMBTU/hr.  The facility’s two (2) boilers are rated below 10 MMBTU/hr; therefore, this subpart is not applicable. 

SPECIFIC APPLICABLE REQUIREMENTS 

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	

AA-001    AA-002     AA-003	PM	0.6 lb/MMBTU	Given that the facility only utilizes natural gas, there is an expectation that the margin of compliance with these limitations will be large.	
	VOCs	245.0 tpy
(Rolling 12-Month Period)

(PSD Avoidance Limit)	The facility will determine the total quantity of product (in pounds or tons) and percent VOC by weight.

The facility will monitor and document the emission rates in tons per year for VOCs based on a rolling 12-month total basis.	
AA-004	PM
(filterable)	E = 4.1(p0.67)	The flour transfer system vents are equipped with filters, which vent inside the building; therefore, a large margin of compliance with this limitation is expected.	

Insignificant Activities	PM	0.6 lb/MMBTU	Given that the facility only utilizes natural gas, there is an expectation that the margin of compliance with these limitations will be large.	
	SO2	4.8 lb/MMBTU	The ovens directly transfer heat to the product and are not subject to this regulation; however, the boilers are subject to it. Given that the facility only utilizes natural gas, there is an expectation that the margin of compliance with these limitations will be large.