PERMIT REVIEW SUMMARY

Permit Writer:	Ivelina Pilgrim 	                                                 Date:	June 17, 2024

Company Name:	Alter Trading Corporation - Sardis

Facility Location:	690 Belmont Road
                                    Sardis, Mississippi

Source Number:	210000034

County: 		Panola

FACILITY DESCRIPTION
Alter Trading Corporation – Sardis dba Martin Bros. (“Alter Trading”) is an existing metal recycling facility. The facility operations fall under SIC Code 5093 (Scrap and Waste Materials). 

Alter Trading is a metal recycling facility with a capacity to process 438,000 tons per year of scrap auto bodies and light iron. The facility separates metal scrap into ferrous and non-ferrous products. Auto shredder residue is recovered as a byproduct. Raw scrap is received via truck, staged, and fed to the auto shredder hammermill. The hammermill uses a water spray to cool the shred for safety reasons generating steam;  the water spray also provides dust control within the mill and downstream processes by wetting the shredded material. The hammermill is driven by two natural gas-fired engines operating simultaneously. The engines exhaust through non-selective catalytic reduction (NSCR) devices. After the hammermill, shredded material is conveyed to a series of separation systems. Magnets remove ferrous metal, which passes through a Z-box cascade separation system to segregate residual auto shredder residue (ASR), a byproduct, from the ferrous metal. The Z-box cascade separation system operates with a closed loop air handling system that does not exhaust to the atmosphere. The ASR from the magnets and cascade cleaning is processed in an offline non-ferrous separation system, which uses eddy current technology to provide discrete non-ferrous scrap products from non-metallic fluff. Products and waste fluff are shipped from the facility via truck.

PROJECT/PERMIT ACTION DESCRIPTION
On February 26, 2024, Alter Trading submitted an initial application for a Synthetic Minor Operating Permit (SMOP).

EMISSION SUMMARY

Table 1: Facility-Wide Emissions
	PM	PM10	PM2.5	SO2	NOX	CO	VOCs	Lead	Ind. HAP	Total HAPs	
Uncontrolled Potential Emissions (tpy)	5.3	3.22	0.6	0.03	185.8	128.6	50.28	---	2.63	7.9	
Proposed Allowable Emissions (tpy)	---	---	---	---	18.581	32.151	---	---	---	---	
1 Based on the maximum uncontrolled operation of all emission sources, the facility has the potential to emit nitrogen oxides (NOX) and carbon monoxide (CO) in excess of the Title V major source threshold of 100 tons per year (tpy).  However, the facility will remain a synthetic minor source by limiting the hours of operation for each of the two (2) shredder hammermill engines to no more than 4380 hours per year. The proposed allowable NOX and CO emissions are based on 4380 hours of operation per year for each engine.

APPLICABLE/PROPOSED PERMIT LIMITATIONS
The facility will comply with the following limitations:

•	4380 hours of operation per year (rolling 12-month total) for each shredder hammermill engine (Emission Points AA-001 and AA-002). The facility must record the hours of operation for each engine daily. 

•	Install NSCR on each shredder hammermill engine and either reduce CO by 75% or more, or limit CO to less than or equal to 270 ppmvd at 15% O2, or reduce total hydrocarbons (THC) by 30% or more. The facility will demonstrate compliance by performing stack-testing annually and either monitor the catalyst inlet temperature or install equipment that automatically shuts down the engine if the catalyst inlet temperature exceeds 1250 °F.

•	40% Opacity – The facility is expected to demonstrate a large margin of compliance with the standard since the shredder hammermill is equipped with a water spray for PM control and the associated engines combust natural gas. 

•	6.7 pounds of PM per hour, as determined by E = 0.8808·(I-0.1667), for each shredder hammermill engine – Combusting natural gas ensures compliance with the standard. 

•	89.7 pounds of PM per hour for the whole facility, as determined by the process weight equation [E = 4.1·(p0.67)] – The facility-wide uncontrolled potential PM emissions are well below the emissions allowed by the state standard. 

NSPS APPLICABILITY
The facility is not subject to any NSPS regulations. 

MACT APPLICABILITY

40 CFR 63, Subpart ZZZZ – National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (RICE)
Emission Points AA-001 and AA-002 are considered “existing” (i.e. constructed prior to June 12, 2006) non-emergency 4-stroke rich burn natural gas-fired stationary RICE and the units must comply with all applicable requirements found in Subpart ZZZZ. Each engine is required to have a NSCR and either reduce CO by 75% or more, or limit CO to less than or equal to 270 ppmvd at 15% O2, or reduce total hydrocarbons (THC) by 30% or more. The facility will perform stack-testing annually and either monitor the catalyst inlet temperature or install equipment that automatically shuts down the engine if the catalyst inlet temperature exceeds 1250 °F.

PUBLIC PARTICIPATION
The 30-day public notice period began on June 19, 2024, with the posting of a public notice on MDEQ’s webpage and ends July 19, 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.