PERMIT REVIEW SUMMARY

Permit Writer:	Brad Luke 	Date:	August 12, 2026
Company Name:	Crystal Finishing Systems Inc
Facility Location:	140 Matthews Drive
Senatobia, MS 38668
Source Number:	2600-00026
County: 		Tate

FACILITY DESCRIPTION

Crystal Finishing Systems, Inc., is an existing entity that engages in aluminum extrusion and surface coating.  These operations fall under SIC Code 3354 (Aluminum Extruded Products) and NAICS Code 331318 (Other Aluminum Rolling, Drawing, and Extruding). The operations at the facility include Metal Cutting Operations (Emission Point AA-100), Surface Coating Operations (Emission Point AA-200), and Wood Cutting Operations (Emission Point AA-300). Emission Point AA-100 includes a 1,250-ton aluminum extruder press, a 1,400-ton aluminum extruder press, a 2,200-ton aluminum extruder line, and various metal cutting activities.  Emission Point AA-200 includes a washer tank heater, a washer dry-off oven, two (2) electrostatic liquid spray paint booths, and a bake oven. The facility proposes adding Foam Filling Operations and a De-Bridge Saw (Emission Point AA-400). 

PROJECT/PERMIT ACTION DESCRIPTION

Crystal Finishing Systems are requesting a renewal with a  modification of the Synthetic Minor Operating Permit (SMOP) issued to the facility on August 7, 2023. The facility proposes to add a process where two-part foam is poured into the cavity of an aluminum extrusion by a Graco EP250 Pour Gun to provide thermal insulation to certain extruded parts used in the window manufacturing industry and will use a De-Bridge saw to cut a series of kerfs along the length of the extruded aluminum to provide thermal breaks in the metal. The De-Bridge and filling operations will be known as Foam Filling Operations (Emission Point AA-400). The following is a listing of the facility’s emission points with the additions proposed in the application:

Emission Point	Description	
AA-000	Facility Wide [Crystal Finishing Systems, Inc.]	
AA-100	Metal Cutting Operations	
AA-101	Aluminum Extruder Press Operations [includes one (1) 1,250-ton press and one (1) 1,400-ton press; presses jointly consist of two (2) 3.0 MMBTU / hour natural gas-fired Billet Oven, one (1) 3.5 MMBTU / hour natural gas-fired Age Oven, and one (1) 3.0 MMBTU / hour natural gas-fired Age Oven; emissions routed to a shared cyclone]	
AA-102	2,200-Ton Aluminum Extruder Line [includes one (1) 5.4 MMBTU / hour Billet Oven and one (1) 3.5 MMBTU / hour Age Oven; emissions routed to a cyclone]	
AA-103	Sawing Operations [includes three (3) cooling table saws, one (1) cutback saw, two (2) miter saws, and one (1) band saw]	
AA-200	Surface Coating Operations	
Emission Point	Description	
AA-201	5.0 MMBTU / hour Natural Gas-Fired Washer Tank Heater	
AA-202	2.0 MMBTU / hour Natural Gas-Fired Washer Dry-Off Oven	
AA-203	Two (2) Electrostatic Liquid Spray Paint Booths [each booth equipped with dry filter]	
AA-204	4.0 MMBTU / hour Natural Gas-Fired Bake Oven	
AA-300	Wood Cutting Operations [includes lumber sawing]	
AA-400	Foam Filling Operations	
AA-401	Graco EP250 Pour Gun [45.0 gallons / hour maximum design capacity; two-part foam material poured, not sprayed, into cavity]	
AA-402	De-Bridge Sawing Operations [emissions routed to a cyclone]	

EMISSION SUMMARY

	PM	PM10	PM2.5	SO2	NOX	CO	VOCs	Ind. HAP2	Total HAPs	
Maximum Uncontrolled Emissions (tpy)	319.79	318.99	319.52	0.08	13.91	11.69	551.97	57.55	85.01	
Proposed Permit Limitations (tpy)	5.361	4.571	5.101	--	--	--	99.0 	9.0	24.0	
1 Based on the facility-wide usage of air pollution control devices at all times 
2 Based on the emission of “xylene”

Crystal Finishing is classified as a Synthetic Minor operating source, meaning that it has taken limitations on its emissions to avoid exceeding the Title V major source thresholds. The facility’s maximum uncontrolled emissions of particulate matter (PM), PM less than 10 microns (PM10), PM under 2.5 microns (PM2.5), and volatile organic compounds (VOCs) exceed the Title V major source threshold of 100 tons per year (tpy) and the Prevention of Significant Deterioration (PSD) major source threshold of 250 tpy. Additionally, the facility’s maximum uncontrolled hazardous air pollutant (HAPs) emissions exceed the HAP major thresholds of 10.0 tpy for individual HAPs and 25.0 tpy for total HAPs and would result in the facility being classified as a major source of HAPs. To maintain its Synthetic Minor operating source status, the facility will continue to operate pollution control devices at all times associated process equipment is in active operation on a facility-wide basis to avoid becoming a major source of PM and will comply with facility-wide emission limitations of 99.0 tpy for VOCs, 9.0 tpy for each individual HAP, and 24.0 tpy for total HAPs combined.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

The facility’s permit limitations will remain largely the same. Crystal Finishing will continue to operate all process control devices while the associated process equipment is in active operation to minimize PM10 and PM2.5 emissions. However, the previous limitation on Surface Coating Operations (Emission Point AA-200) of limiting emissions of VOCs to 99.0 tpy, individual HAPs to 9.0 tpy, and total HAPs to 24.0 tpy will be modified into facility-wide emission limitations for the purpose of avoiding Title V major status and HAP major status. The reasons for this are that currently only Surface Coating emissions are limited without considering emissions from other emission points. Only limiting Surface Coating Operations could inadvertently result in a situation where Surface Coating emissions might remain below the limitations, but the emissions from the rest of the emission sources could push overall facility-wide emissions could be pushed over the major source thresholds and result in the facility being classified as a Title V major source or major source of HAPs.

Emission 
Point(s)	Applicable Requirement	Pollutant / 
Parameter	Limitation / Standard	Compliance Demonstration	
AA-000 (Facility-Wide)	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).

(Title V Avoidance Standard)	PM/ PM10 / PM2.5
(filterable only)	Operate Pollution Control Devices at All Times Process Equipment is in Operation	Conduct routine visible emission observations and perform routine inspections on air pollution control devices.	
	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).

(Title V Avoidance Limit)	VOCs	99.0 tpy

(Rolling 12-Month Total)	Recordkeeping of VOC-containing materials	
	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).

(HAP Major Source Avoidance Limits)	HAPs	9.0 tpy (Individual)

24.0 tpy (Total)

(Rolling 12-Month Totals)	Recordkeeping of HAP-containing materials	
AA-200	40 CFR 63.11173(e); Subpart HHHHHH

40 CFR 63.11173(f) and (g); Subpart HHHHHH	HAPs	Spray Coating Application Requirements

Personnel Training Requirements	Maintain certifications on the completion of required training	

NSPS APPLICABILITY

Crystal Finishing Systems, Inc. does not have any process equipment or engage in any operation subject to any subparts under 40 CFR Part 60 – New Source Performance Standards.

MACT APPLICABILITY

40 CFR Part 63, Subpart MMMM – National Emission Standards for Hazardous Air Pollutants (NESHAP) for Surface Coating of Miscellaneous Metal Parts and Products: The provisions of Subpart MMMM are applicable to an affected source that uses at least 250 gallons per year of coatings that contain hazardous air pollutants (HAPs) and is a major source of HAPs. Crystal Finishing Systems is an area source of HAPs; therefore, it is not subject to Subpart MMMM.

40 CFR Part 63, Subpart XXXXXX – National Emission Standards for Hazardous Air Pollutants (NESHAP) for Nine Metal Fabrication and Finishing Source Categories: The provisions of Subpart XXXXXX are applicable to an area source that is primarily engaged in any of the nine source categories outlined in 40 CFR 63.11514(a)(1) through (9) and detailed in Table 1 of the subpart. Crystal Finishing Systems does not perform any operation defined in the nine source categories; therefore, it is not subject to Subpart XXXXXX.

40 CFR Part 63, Subpart HHHHHH – National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources: The provisions of Subpart HHHHHH are applicable to paint stripping using methylene chloride (MeCl) for the removal of dried paint, surface coating applied to motor vehicles and mobile equipment, or the spray application of coatings that contain a target HAP (as defined in 40 CFR 63.11180) performed at an area source of HAPs. Crystal Finishing Systems is engaged in miscellaneous metal coating that involves a targeted HAP; therefore, it is subject to Subpart HHHHHH. 

PUBLIC PARTICIPATION

The 30-day public notice period began on August 12, 2026, when the notice was posted on MDEQ’s website and ends September 14, 2026.