INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
July 29, 2026

GENERAL FACILITY INFORMATION
Facility Name:  Milwaukee Electric Tool Corporation, Milwaukee Tool-Grenada
Facility Address:  
2817 American Way
Grenada, MS 38901    
County: Grenada
SIC Code(s): 3546 (Power-Driven Handtools)
NAICS Code(s): 333991 (Power-Driven Handtool Manufacturing), 332213 (Saw Blade and Handsaw Manufacturing)

APPLICATION SUMMARY 
Permit No.: 0960-00044
Permit Action:  Initial Issuance
Permit Folder: PER20260001
Application Receipt Date: March 6, 2026
Application Deemed Complete: April 17, 2026
CBI Submitted?:  No	NSPS (Part 60): Subpart A, IIII
NESHAP (Part 61): N/A
NESHAP (Part 63): Subpart A, ZZZZ
112(r) / RMP: N/A
Other: N/A	

FACILITY DESCRIPTION
Milwaukee Tool-Grenada is an existing industrial facility that manufactures power-driven handtools such as drills and drilling tools, circular saws, saw blades including those for power sawing machines, and other electric power tools. The facility’s SIC Code is 3546 (Power-Driven Handtools), additionally the facility falls under the NAICS codes 333991 (Power-Driven Handtool Manufacturing) and 332213 (Saw Blade and Handsaw Manufacturing). Milwaukee Tools engages in the stamping of blanks, hot and cold forming, welding of caps and seams, heat treatment, powder coating of components, curing of components after powder coating, burning off powder coat for components, pad printing of logos onto components, and packaging operations. The facility currently operates a powder coat line in addition to two (2) 1.0 million British Thermal Unit per hour (MMBTU/hour) natural gas-fired ovens for curing blades following powder coat application (Emission Point AB-001) and a 0.875 MMBTU/hour burn-off oven for powder coat removal from rack system components (Emission Point AB-002). The facility also currently operates a 158 horsepower (HP) diesel-fired emergency generator engine with a  heat input capacity of 0.137 MMBTU/hour (Emission Point AD-001). Other sources of emissions operated at the existing facility considered here are fifteen (15) natural gas-fired space heaters each with a rated capacity of 0.332 MMBTU/hour. The facility has site wide welding operations that do not consume welding electrodes and consist of tungsten inert gas welding (TIG) and resistance welding, which produce very minor emissions of particulate matter (PM). Before the proposed construction, the facility’s emissions classified it as a true minor source of emissions for both Title V and Prevention of Significant Deterioration (PSD), and as an area source of Hazardous Air Pollutants (HAPs). This construction permit will incorporate the existing units into the permit as well as the proposed equipment described below.

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: Particulate Matter less than 10 microns (PM10), Particulate Matter less than 2.5 microns (PM2.5), and Volatile Organic Compounds (VOC).
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 since the facility has taken limits/restrictions on the emissions of total HAPs from the two (2) electrostatic paint lines equipped with fabric filters and on the emission of individual HAPs as glycol ether, and is required to record the amount of paint in gallons used each month and on a 12-month rolling basis as well as the VOC and HAP content of each paint used.

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions
(tons/yr)	
Particulate Matter (TSP)	221.60	
PM10	221.60	
PM2.5	221.59	
Sulfur Dioxide (SO2)	0.04	
Nitrogen Oxides (NOx)	4.57	
Carbon Monoxide (CO)	3.80	
Volatile Organic Compounds (VOC)	245.00	
Individual HAPs2	9.00	
Total HAP 	24.00	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.
2 Individual HAPs as “glycol ethers” pollutant

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)(a); 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 volatile organic compounds (VOCs) but will continue to limit facility-wide emissions of VOCs to 245.0 tpy; therefore, the facility is considered a moderate stationary source.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
The facility was previously classified as a True Minor source of emissions; however, because of the modifications proposed by the facility in the application for a Permit to Construct (PTC) received March 6, 2026, the facility’s maximum uncontrolled emissions will exceed the Title V major source threshold. The application for the PTC proposes installing two (2) electrostatic paint lines and two (2) natural gas-fired cure ovens at the existing facility. The two electrostatic paint lines (Emission Point AA-001) are SAMES Kremlin model manufactured by Systems Technology Inc. and will use liquid paint to paint hole saw blades. The paint lines will operate with a SprayStop E-Pak 950 fabric filter manufactured by Koch Filter. The two (2) natural gas-fired paint ovens (Emission Point AB-003) manufactured by Maxon or Wayne Combustion Systems are each rated 1.0 MMBTU/hour and will be used for curing blades following paint application. Without emission limitations, the maximum uncontrolled emissions from these new emission points would result in the facility becoming a Title V major source, a PSD major source, and a major source of HAPs. Therefore, the facility submitted an application for a Title V operation permit to request reclassification to a Title V major source and to proposes facility-wide emission limitations on VOCs and process specific emission limitations on individual HAPs and total HAPs from the electrostatic paint lines to avoid becoming a PSD major source and a major source of HAP. The facility’s controlled emissions will still classify it as a Title V major source for VOC, PM10, and PM2.5 emissions.

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.

Emission Point AB-002 (0.875 MMBTU/hour burn-off oven for powder coat removal from rack system components) operates an afterburner to control PM, VOC, and carbon monoxide (CO); however, the afterburner is an integrated control device, and is not considered an add-on control device (i.e. inherent to the process) and does not operate a control device to comply with an emission standard; therefore, CAM is not applicable to Emission Point AB-002. 

Emission Point AA-001 (two (2) electrostatic paint lines) are equipped with fabric filters which are control devices to control PM, while Emission Point AA-001 is subject to emission limitations for individual HAPs and total HAPs, the fabric filter control device is not used to comply with this standard; therefore, CAM is not applicable to Emission Point AA-001.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

40 CFR Part 63, Subpart ZZZZ — National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines: Milwaukee Tools operates a 158 HP diesel-fired emergency generator engine with a rated heat capacity of 0.137 MMBTU/hour that was manufactured on May 8, 2023. Given the engine is a new stationary reciprocating internal combustion engine (RICE) located at an area source of HAPs it is subject to the requirements Subpart ZZZZ but shall meet the requirements of the subpart by meeting the requirements 40 CFR Part 60, Subpart IIII, and Milwaukee Tools is subject to no further requirements of Subpart ZZZZ.

40 CFR Part 63, Subpart MMMM — National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products: While Milwaukee Tools performs surface coating operations on metal components that could be classified as miscellaneous metal parts and products, the facility is classified as an area source of HAP emissions. Therefore, since Subpart MMMM applies to major sources of HAPs, Milwaukee Tools are not subject to the requirements of Subpart MMMM.

40 CFR Part 63, Subpart HHHHHH — National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources: While Milwaukee Tools performs surface coating operations and is classified as an area source of HAP emissions, presented environmental data sheets show the facility does not use coatings that contain the target HAPs of chromium, lead, manganese, nickel, and cadmium. Therefore, Milwaukee Tools are not subject to the requirements of Subpart HHHHHH.

40 CFR Part 63, Subpart XXXXXX — National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories: While Milwaukee Tools performs surface coating operations on fabricated metal products and is classified as an area source of HAP emissions, presented environmental data sheets show the facility does not use coatings that contain the target metal fabrication or finishing metal HAP (MFHAP) of cadmium, chromium, lead, or nickel in amounts greater than or equal to 0.1 percent (%) by weight (of the metal) or manganese in amounts greater than or equal to 1.0 percent (%) by weight (of the metal). Therefore, Milwaukee Tools is not subject to the requirements of Subpart XXXXXX.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR Part 60, Subpart IIII — Standards of Performance for Stationary Compression Ignition (CI) Internal Combustion Engines: Milwaukee Tools operates a 158 HP diesel-fired emergency generator compression ignition (CI) engine with a rated heat capacity of 0.137 MMBTU/hour that was manufactured on May 8, 2023. The emergency generator engine was constructed after the applicable date of April 1, 2006, and therefore Milwaukee Tools are subject to the requirements of Subpart IIII for the diesel-fired emergency generator CI engine. Subpart IIII requires the engine to be certified to meet certain standards for PM, non-methane hydrocarbons + NOx, and CO as well as smoke opacity standards during different periods of operation. Also, the engine must use diesel fuel that meets given standards and may only be operated up to 100 hours per year for maintenance, readiness testing, and other non-emergency use as monitored through a non-resettable hour meter.

40 CFR Part 60, Subpart JJJJ — Standards of Performance for Stationary Spark Ignition Internal Combustion Engines: Milwaukee Tools operates a 158 HP diesel-fired emergency generator compression ignition (CI) engine with a rated heat capacity of 0.137 MMBTU/hour that was manufactured on May 8, 2023. Given that the emergency generator engine is not a spark ignition (SI) engine but instead is a CI engine, Milwaukee tools are not subject to the requirements of Subpart JJJJ for a diesel-fired emergency generator SI engine. 

SPECIFIC APPLICABLE REQUIREMENTS 

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-000 (Facility-Wide)	VOCs	≤ 245.0 tpy
(Rolling 12-Month Total)
(PSD Avoidance Limit)	The facility will determine the total quantity of paints and surface coatings (in gallons) and percent VOCs by weight.

The facility will calculate the emission of VOCs from all sources that can reasonably emit the pollutant(s) on both a monthly and rolling 12-month total basis.	
	PM     (Filterable)	E = 4.1 × p0.67	The electrostatic paint lines are equipped with filters and will not be operated without those filters; therefore, a large margin of compliance with this limitation is expected.	
AA-001	HAPs	<  9.00 tpy (Individual) (Rolling 12-month period)

<  24.00 tpy (Total)        (Rolling 12-month period)
(MACT Avoidance Limit)	The facility will determine the total quantity of paints and surface coatings (in gallons) and percent HAPs by weight.

The facility will monitor and document the emission rates in tons per year for individual and combined HAPs based on a rolling 12-month total basis.	
AB-001 AB-002 AD-001 AB-003	PM    (Filterable)	< 0.6 lb/MMBTU	The predominant use of natural gas and intermittent use of diesel (for the emergency generator engines) at the site should ensure a significant margin of compliance with this State standard and Emission Point AB-002 with the integrated afterburner control device will be operated and maintained according to manufacturer specifications	
AB-001 AB-002 AB-003	SO2	< 4.8 lb/MMBTU	The sole usage of natural gas in the applicable sources should ensure a significant margin of compliance with this State standard.	
AD-001	NHMC + NOX
CO
PM (Filterable only)	NHMC + NOX  ≤  4.0 g/kW-hr
CO ≤ 3.5 g/kW-hr
PM ≤ 0.20 g/kW-hr
	The facility will maintain documentation that the engine is EPA-certified.	
	Opacity (Smoke)	20% during the acceleration mode;
15% during the lugging mode
50% during the peaks in either the acceleration or lugging modes	The facility will maintain documentation that the engine is EPA-certified.	
	Fuel Restriction	≤ 15 ppm sulfur content
≥ 40 cetane index or ≤ 35 vol.% aromatic content	The facility will maintain documentation demonstrating the use diesel fuel compliant with the sulfur standards.	
AD-001	Operating Limit	50 hours per calendar year – Non-Emergency Operations                          100 hours per calendar year – Maintenance and Testing	The facility will maintain records of operational hours and the reason the emergency generator was operated	
	Monitoring Limit	Install Hour Meter	N/A