INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
May 2025

GENERAL FACILITY INFORMATION
Facility Name: Dart Container Company of Mississippi LLC
Facility Address: 197 Harris Avenue, Quitman, MS 39355    
County: Clarke
SIC Code(s): 3086
NAICS Code(s): 326140  

APPLICATION SUMMARY 
Permit No.: 0440-00053
Permit Action: Renewal
Permit Folder: PER20230001
Application Receipt Date: July 28, 2023
Application Deemed Complete: {Use administrative completeness date}
CBI Submitted?  Yes	NSPS (Part 60): IIII
NESHAP (Part 61): N/A
NESHAP (Part 63): ZZZZ
112(r) / RMP: N/A
Other: N/A	
FACILITY DESCRIPTION
Dart Container Company of Mississippi, LLC (Dart) is an existing expandable polystyrene (EPS) container manufacturer located in Quitman, Mississippi. The facility has submitted a timely application to renew the Title V Operating Permit (TVOP) which was last issued February 14, 2019, and expired on January 31, 2024. The following table contains a list of the significant emission points contained in the proposed permit.

Emission Point	Description	
AA-001	29.3 MMBtu/hr natural gas or No. 2 fuel oil-fired steam generating boiler.	
AA-002	25.1 MMBtu/hr natural gas or No. 2 fuel oil-fired steam generating boiler.	
AA-003	33.5 MMBtu/hr natural gas or No. 2 fuel oil-fired steam generating boiler.	
AA-004	Cup Manufacturing: Pre-Expansion Process Area which consists of expandable polystyrene (EPS) bead pre-blender dumpers, blenders, holding tanks, pre-expanding equipment, pre-puff screeners, and pre-puff holding bags. Emissions from this process are vented to Emission Points AA-001, AA-002, and AA-003 for control of VOCs. Fugitive emissions are vented through the building ventilation system.	
AA-005	Cup Manufacturing: Pre-Puff Storage and Steam Chest Molding where pre-puff is converted to EPS containers. Emissions are vented through the building ventilation system.	
AA-006	Cup Printing: Flexographic-type UV printing presses which print UV curable ink on EPS containers.	
AA-007	Cup Manufacturing: Finished Product Warehouse Area where packaged cups are stored prior to shipping. Emissions are vented through the building ventilation system.	
AA-011	Part Cleaners associated with the printing machines.	
AA-012	Part Cleaners associated with manufacturing equipment.	
AA-013	Part Cleaners associated with maintaining delivery trucks and forklifts.	
AA-015	Scrap Cup Baler	
AA-018	Cold Press Densifier used to handle post-consumer waste by compacting EPS foam	
EG-001	158 HP (118 kW/1.15 MMBtu/hr) diesel-fired emergency engine used to power backup generator for the lighting system (Model Year 2007)	

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 Sulfur Dioxide (SO2) and Volatile Organic Compounds (VOC). The facility’s potential-to-emit hazardous air pollutants (HAP) 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)	5.70	
PM10	1.85	
PM2.5	2.81	
Sulfur Dioxide (SO2)	195.10	
Nitrogen Oxides (NOx)	59.20	
Carbon Monoxide (CO)	24.51	
Volatile Organic Compounds (VOC)	495.0	
Total Reduced Sulfur (TRS)	0.00	
Lead	0.00	
CFC/HCFC	0.00	
Total HAP 	0.64	
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)(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 VOC; therefore, the facility is considered a major stationary source. This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
The following changes are being proposed as part of this permitting action.
•	The previous permit indicated Emission Points AA-001, AA-002, and AA-003 (boilers) were subject to the provisions of the Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units found in 40 CFR 60, Subpart Dc. Upon further review, it appears the boilers were originally constructed prior to the applicability date (at another facility). Dart confirmed that the boilers were purchased as used units and were subsequently installed at the site without being reconstructed or modified. As such, the MDEQ has determined that the boilers are not subject to Subpart Dc. The conditions contained in the previous version of the TVOP have been removed from the proposed permit. 
•	Dart submitted a 502(b)10 modification request in April 2023 to install a new densifier to replace the one currently in service. Installing the new densifier resulted in the removal of Emission Points AA-016 and AA-017 so those emission points have been removed from the proposed permit. The new densifier is included in the proposed permit as Emission Point AA-018.
•	The previous permit required a biennial compliance certification report to be submitted by March 15 of the year following the biennial tune-up of the boilers. While this date is the date required by 40 CFR 63, Subpart JJJJJJ, the standard only requires it be prepared and then submitted upon request. In an effort to streamline reporting requirements for the facility, the proposed permit has been revised such that the required information in the report be submitted along with the semiannual reports already required by the permit (i.e., Condition 5.A.4). The required information shall be submitted in the next semiannual report following the completion of a tune-up.

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.

CAM Applicability Table for Sources with Control Devices
Emission Point ID	Control Device 
(not including inherent controls)	Applicable Limit/ Standard	Is standard exempt? (Yes/No)	Pre-Control > 100 tpy (Yes/No)	CAM Applies? (Yes/No)	Type of CAM PSEU
(Large/Other)	
AA-004*	Boiler (AA-001)
Boiler (AA-002)
Boiler (AA-003)	VOC ≤ 495.0 TPY (facility-wide)	No	Yes	Yes	Large	
*The boilers are used as a control device for VOC. The exhaust gases from Emission Point AA-004 are captured and routed to the boilers where they are introduced into the combustion zone to meet the 95% minimum destruction efficiency requirement. 

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
•	40 CFR 63, Subpart ZZZZ, NESHAP for Stationary Reciprocating Internal Combustion Engines - The provisions of Subpart ZZZZ are applicable to stationary reciprocating internal combustion engines (RICE) located at area and major sources of HAP emissions. The facility is an area source of HAP emissions and has a new, emergency compression ignition stationary RICE. The engine meets the requirements of Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart IIII.
•	40 CFR 63, Subpart JJJJJJ, NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources – The provisions of Subpart JJJJJJ are applicable to industrial, commercial, or institutional boilers located at an area source of HAP. The facility is considered an area source of HAP and does have three (3) existing boilers. These boilers are permitted to burn both natural gas and fuel oil. 40 CFR 63.11237 defines a gas-fired boiler as any boiler that burns gaseous fuels not combined with any solid fuels and burns liquid fuel only during periods of gas curtailment, gas supply interruption, startups, or for periodic testing, maintenance, or operator training on liquid fuel provided the time spent for periodic testing, maintenance, or operator training does not exceed a total of 48 hours during any calendar year. While the boilers have operated as and would likely be defined as gas-fired boilers, Dart has chosen to classify these boilers as oil-fired boilers to maintain the flexibility to burn fuel oil as market conditions and fuel supplies dictate. As such, the applicable provisions for oil-fired boilers in Subpart JJJJJJ are included in the proposed permit. 

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
•	40 CFR 60, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units – The provisions of Subpart Dc are applicable to steam generating units for which construction, modification, or reconstruction is commenced after June 9, 1989, and that have a maximum design heat input capacity between 10 and 100 MMBtu/hr. These boilers all have a rated capacity within this range, and all were installed after the applicability date. However, the permit application indicates the model year for each boiler is 1969, 1963, and 1972, respectively. Boilers that are relocated from one facility to another do not trigger construction or reconstruction and there are no records indicating these units have been modified. Dart confirmed such during the permit review process. Since these units were originally constructed prior to the applicability date and they were not modified or reconstructed when installed at Dart, they are not subject to the requirements of Subpart Dc. All previously identified Subpart Dc requirements have been removed from the proposed permit.
•	40 CFR 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition (CI) Internal Combustion Engines - The provisions of Subpart IIII are applicable to stationary CI engines that commenced construction after July 11, 2005, and the engine was manufactured after April 1, 2006. The facility has one (1) emergency CI engine that was constructed and manufactured after the applicability dates. As such, the engine is subject to the applicable requirements of Subpart IIII.

SPECIFIC APPLICABLE REQUIREMENTS
Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
Facility-wide	VOC	≤ 495.0 tons per year determined on a 12-month rolling total basis	Monitor and record material usages on a monthly basis and calculate VOC emissions on a monthly and 12-month rolling total basis	
AA-001    AA-002    AA-003	PM 
(filterable)	E = 0.8808*I-0.1667	No monitoring required since large margin of compliance expected due to combustion of natural gas or low sulfur diesel	
	SO2	4.8 lbs/MMBtu		
	VOC	Minimum destruction efficiency of 95% for captured vent gas from the pre-expander process area	Performance testing once every 5 years	
	Fuel limitation	Limited to burning only natural gas, No. 2 fuel oil with a maximum sulfur content of 0.5% by weight, or vent gas from the pre-expander process area	Monitor and record monthly fuel usages	
AA-004    AA-005    AA-007	PM 
(filterable)	E = 4.1p0.67	No monitoring required since a large margin of compliance is expected	
EG-001	PM 
(filterable)	0.6 lbs/MMBtu	No monitoring required since large margin of compliance expected	
	NOx + NMHC
CO
PM  
(filterable)	4.0 g/kW-hr
5.0 g/kW-hr
0.30 g/kW-hr	Keep records documenting engine meets emission standards	
	Opacity	≤ 20% during acceleration mode
≤ 15% during lugging mode
≤ 50% during the peaks in either mode	No monitoring required since a large margin of compliance is expected	
	SO2 
(Diesel fuel requirements)	Sulfur content of 15 ppm max AND
Minimum cetane index of 40 OR maximum aromatic content of 35 volume percent	Monitor fuel usage	
	NOx + NMHC
CO
PM  
(filterable)	Install non-resettable hour meter	Record hours of operation	
		Certified engine requirements	Keep records documenting engine meets emission standards	
		Operating requirements	Record hours of operation and submit semiannual report documenting operation