Title: afgafgasdgfsd
Author: Bruce Ferguson
Last saved by: Clinton Gentry
Company: None

Permit Review Summary
Page

PERMIT REVIEW SUMMARY

Permit Writer:	Clinton Gentry				Date:	December 7, 2023

Company Name:	Polychemie Inc.

Facility Location:	Port Beinville Industrial Park
			
			-31° 36’ 50.49” N
			-89° 29’ 49.79” W

Source Number:	1000-00042

County: 		Hancock

FACILITY DESCRIPTION

Polychemie Inc. is a water treatment polymer and monomer production facility located in Pearlington, MS. The facility will be classified under SIC Code 2899, which is defined as “Establishments primarily engaged in manufacturing miscellaneous chemical preparations, not elsewhere classified.”

PROJECT/PERMIT ACTION DESCRIPTION
 
Polychemie has applied for a renewal of their Synthetic Minor Operating Permit (SMOP) that was issued in May, 2019 and is set to expire April, 2024. The facility has also submitted additional information requesting that proposed modifications to the process/facility be reflected in the SMOP reissuance.  

The permit modifications include new equipment for the production of DADMAC (Existing Emission Point AA-050), installation of a new thermal oxidizer (Proposed Emission Point AB-200) and scrubber system (AC-200), as well as miscellaneous, low emitting emission points.

EMISSION SUMMARY

Criteria Pollutant | Maximum  Uncontrolled^1 | Potential Controlled | Title V Threshold
Carbon Monoxide (CO) | 28.11 | 28.11 | 100
Nitrogen Oxides (NO_x) | 36.76 | 37.67 | 100
Sulfur Dioxide (SO_2) | 53.27 | 1.33 | 100
Particulate Matter 10 (PM_10) | 2.58 | 2.58 | 100
Volatile Organic Compounds (VOC) | 77.42 | 16.84 | 100
Total Hazardous Air Pollutants (HAP) | 40.63 | 10.24 | 25
Individual HAP                          Allyl Chloride^2 | 30.26 | 6.20 | 10
(1)	All pollutants are expressed in units of tons per year (tpy)
(2)	Allyl Chloride is the largest Individual HAP. All other individual HAPs have uncontrolled emissions < 10 tpy.

As shown in the table above, Polychemie has the potential to exceed the Title V thresholds for both Total HAP and Individual HAP emissions. In order to be classified as a Synthetic Minor Source, the facility will operate thermal oxidizer/scrubber (Emission Point AB-100 and AC-100, respectively) and thermal oxidizer/scrubber (Proposed Emission Points AB-200 and AC-200, respectively) for the DADMAC process (Emission Point AA-050), EDC-Ammonia Process (Emission Point AA-401), and hazardous waste storage tanks (Emission Points AD-803 and AD-831).

APPLICABLE/PROPOSED PERMIT LIMITATIONS

Emission Point(s) | Pollutant/ Parameter | Limit/Standard | Monitoring

Facility Wide

Production Rate

Production is limited to the following: 
DADMAC Monomer - 447 MMlb/yr
Polyamine - 300 MMlb/yr
EDC-Ammonia Polyamine - 8.0 MMlb/yr
SAS – 34.8 MMlb/yr
MAS – 34.8 MMlb/yr

Maintain records of monthly production rates (12 consecutive months)

AA-004

NMHC               NOx                           CO                      PM

NMHC + NOx – 6.4g/kg-hr
CO – 3.5g/kw-hr
PM – 0.20g/kw-hr

Purchase certified engine

| Hours of Operation | Limit non-emergency operation hours to less than 50 hours per year | Install non-resettable hour meter
AA-050             AA-100             AA-401           AA-530 | HAP | Vent all emissions to thermal oxidizers while processes are operating | Continuously monitor combustion chambers (Maintain logs of temperature and maintenance performed)
AB-100              AB-200 | | Maintain combustion chamber temperature of 1, 1,500 ºF |
| | Vent all emissions from thermal oxidizers to scrubbers |
AC-100            AC-101             AC-200                AC-511 | HAP | Operational requirement for scrubbers | Maintain inspection logs and maintain flow meters

Note: Scrubber A-400 is not required to be operated as part of Polychemie’s plan to maintain their status as a Synthetic Minor Source. The facility had previously requested that the emission point have its requirements removed to allow for operational flexibility with that specific unit. As such, all emission calculations do not include the control efficiency of Emission Point AA-400. 

NSPS APPLICABILITY

40 CFR 60 Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984
This subpart applies to volatile organic liquid (VOL) storage vessels with a storage capacity greater than 75 cubic meters (19,810 gallons). Emission Points AD-001 through AD-004, AD-011, AD-018, and AD-032 would be potentially subject to this subpart based on storage size alone. However, these emission points store VOLs with a true vapor pressure less than 3.5 kpa. As such, these emission points are not subject to this subpart under 40 CFR 60.110b(b).

40 CFR 60 Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
This subpart applies to compression ignition (CI) internal combustion engines (ICE). Emission Point AA-004 is 4-stroke, CI emergency engine and as such is subject to this subpart. 

40 CFR 60 Subpart Dc - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units
This subpart applies to steam generating units with a design capacity less than 100 MMbtu/hr but greater than 10 MMbtu/hr. As such, Emission Points AA-001, AA-002, and AA-005 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 applies to stationary reciprocating internal combustion engines (RICE) located at area and major sources of HAP emissions. Emission Point AA-004 is subject to this subpart. However, under 40 CFR 63.6590(c)(1), this emission point shall meet all requirements under subpart ZZZZ by complying with all applicable requirements under 40 CFR 60 Subpart IIII. No further requirements under subpart ZZZZ will apply to these emission points. 

PUBLIC PARTICIPATION

The 30-day public notice period began on April 10, 2024, and ends May 10, 2024.

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.

83572 PER20230001