PERMIT REVIEW SUMMARY

Permit Writer:	Jeffrey Bland 	Date:	June 11, 2024

Company Name:	Sanderson Farms LLC, Collins Processing

Facility Location:	1111 North Fir Avenue
Collins, MS 39428

Source Number:	0640-00003

County: 		Covington

FACILITY DESCRIPTION

Sanderson Farms Inc. owns and operates the Sanderson Farms Inc, Collins Processing Facility (“Sanderson Farms Collins Processing”) in Covington County, MS. The facility is classified by SIC Code: 2015, Poultry Slaughtering and Processing, and operates under Synthetic Minor Operating Permit (SMOP) No.: 0640-00003.
Sanderson Farms Inc, Collins Processing is located off of Highway 49. Live chickens are delivered to the facility. The chickens are killed then submerged in scalding water to facilitate feather removal. The scalding water is heated by two industrial boilers (Emission Points AA-002 and AA-003) and possibly a third industrial boiler which would only be employed in emergency situations (Emission Point AA-004). Emission Point AA-004 is a temporary boiler and is not on site so the boiler will have to be rented. The de-feathered chickens are eviscerated and deboned/cut-up to be prepared for packaging and shipping. Wastewater produced by the facility is sent to the facility’s onsite, private wastewater treatment plant prior to discharge into Okatoma Creek. Lime/ magnesium oxide is used to control the pH of the activated sludge system, and is provided via a liquid dosing system. During the anaerobic wastewater treatment phase, biological gas is generated, collected, and combusted by either Emission Point AA-002 or a biological gas flare (Emission Point AA-001). Emission Point AA-002 combusts a mixture of biological gas (90%) and natural gas (10%), or if the situation requires, fuel oil (diesel fuel). Emission Point AA-003 is also a duel-fuel fired boiler capable of combusting natural gas or diesel fuel. However, the emergency/temporary boiler, Emission Point AA-004, could be capable of combusting natural gas or diesel fuel. 
For Emission Points AA-002, AA-003, and AA-004, diesel fuel is considered an emergency fuel source if natural gas is unavailable.  A 12,000 gallon storage tank (Emission Point AA-024) stores the fuel oil for boiler combustion. The facility has three other tanks (Emission Points AA-021, AA-022, and AA-023) that contain delivery truck diesel, unleaded gasoline, and off-road diesel.

PROJECT/PERMIT ACTION DESCRIPTION

Sanderson Farms Collins Processing is applying for reissuance of SMOP, Air Ref. No. 0640-00003.  Sanderson Farms Collins Processing is proposing to replace Emission Point AA-002 (25.106 MMBtu/hr Dual Fired Boiler) with a new 24.494 MMBtu/hr Dual Fired Boiler. The new boiler will also have the capability of burning natural gas, biogas, and diesel. Also, this permitting action will clarify the heating value and emission designation for some of the space heaters at the facility. Due to a clerical error, twelve space heaters were left out of the renewal SMOP in 2018. With this permitting action, those space heaters are being added to the permit. Besides the emission description in Section 2, the space heaters do not have any other requirements besides the state regulation for PM.  The facility uses a liquid dosing system instead of Emission Point AA-005. That emission point is inoperable and as such has been removed from the draft permit. 

EMISSION SUMMARY

Pollutant	Total Emissions  (tpy)	Title V Threshold (tpy)	Major Source (Yes/No)	
PM/PM10	5.23	100	No	
SO2	171.66	100	Yes	
NOx	55.99	100	No	
CO	43.64	100	No	
VOC	2.19	100	No	
Total HAP	0.058	25	No	
Table 2. Comparison of Maximum Uncontrolled Emissions Summary to Title V Threshold	

The facility has the potential to exceed the Title V threshold for Sulfur Dioxide. Sanderson Farms Collins Processing is defined as an area source for hazardous air pollutant (HAP) emissions because the facility does not have the potential to produce more than 10 tpy of an individual HAP or 25 tpy of total HAP emissions, as demonstrated in Table 2.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

The facility has the potential to exceed the Title V threshold for Sulfur Dioxide. The facility has a facility-wide 95.0 tpy SO2 emissions limit. The facility will demonstrate compliance with the 95.0 tpy SO2 emissions for any fuel burning equipment besides Emission Points AA-002, AA-003, and AA-004 by monitoring and recording the quantity and quality of fuel combusted. Emission Points AA-002, AA-003, and AA-004demonstrate compliance by limiting their hours of operation. 

Emission Points AA-002, AA-003, and AA-004 produce SO2 emissions by combusting fuel oil (diesel fuel). Sanderson Farms Collins Processing has a limit to reduce the hours of diesel fuel combustion to 13,000 hours of fuel oil combustion, on a 12-month rolling total for these emission points. If all three emission points combusted fuel oil for a total of 13,000 hour on a rolling 12-month total, the SO2 emissions would remain below 90.0 tpy, and the total facility, proposed allowable emissions would be below 95.0 tpy, as demonstrated in Table 2. If the boilers are modified to burn diesel fuel, compliance with the hourly limitation would be demonstrated by installing non-resettable hour meters on each boiler and keeping records of fuel oil usage.

Emission Points AA-002, AA-003, and AA-004 (possibly) are duel-fuel fired boilers (natural gas and diesel), and the units are subject to state standards for particulate matter, sulfur dioxide and opacity. Emission Points AA-002, AA-003, and AA-004 are limited to only combust diesel fuel with a sulfur content of 0.5% or less, and compliance with the limit is demonstrated by keeping a record of the fuel certification. Low sulfur diesel fuel is a relatively clean burning fuel; thus, the units have a large margin of compliance with the state standards for PM, SO2 and Opacity.

NSPS APPLICABILITY

Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units – 40 CFR Part 60, Subpart Db
The Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Db) was promulgated to regulate SO2, PM, and NOx emissions generated by steam generating units. Units subject to Subpart Db commenced construction, modification, or reconstruction after June 19, 1984, and that has a heat input capacity from fuels combusted in the steam generating unit of greater than 100 MMBtu/hr. Sanderson Farms Collins Processing is not subject to Subpart Db because Emission Points AA-002, AA-003, and AA-004 do not have a heat input capacity greater than 100 MMBtu/hr.

Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units – 40 CFR Part 60, Subpart Dc
The Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) was promulgated to regulate SO2 and PM emissions generated by steam generating units. Units subject to Subpart Dc commenced construction, modification, or reconstruction after June 9, 1989, and that has a maximum heat input capacity from fuels combusted in the steam generating unit of greater than 100 MMBtu/hr or less, but greater than 10 MMBtu/hr. Sanderson Farms Collins Processing is not subject to Subpart Dc for Emission Point AA-003 because the emission points were install prior to June 9, 1989. Emission Point AA-004 is a temporary boiler as defined in 40 CFR 60.41c; therefore, Emission Point AA-004 is not subject to Subpart Dc. Emission Point AA-002 is subject to Subpart Dc. 
 
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 – 40 CFR Part 60, Subpart Kb
The Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) was promulgated to regulate volatile organic compound (VOC) emissions generated by volatile organic liquid storage vessels. Facilities subject to Subpart Kb commenced construction, modification, or reconstruction after July 23, 1984, and employ storage vessels with a capacity greater than or equal to 75 m3 (19,812.9 gallons). However, Subpart Kb does not apply to storage vessels with a capacity greater than or equal to 75 m3 (19,812.9 gallons) but less than 151 m3 (39,890 gallons) storing a liquid with a maximum true vapor pressure less than 15.0 kPa (2.175 psi). Emission Points AA-022, AA-024, AA-025, and AA-026 possess storage capacities less than 19,812.9 gallons; therefore, Sanderson Farms Collins Processing is not subject to Subpart Kb.

MACT APPLICABILITY

National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Source – Subpart JJJJJJ
Facilities subject to the National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Source (40 CFR Part 63, Subpart JJJJJJ) own or operate an industrial, commercial, or institutional boiler as defined in 63.11237, that is located at, or is part of, an area source of hazardous air pollutants (HAP), as defined in 63.2, except as specified in 63.11195. Sanderson Farms Collins Processing is an area source of HAP emissions that operates two industrial boilers and potentially a third emergency/temporary boiler (Emission Points AA-02, AA-003, and AA-004). 
Emission Point AA-003 is defined as an existing duel-fuel fired boiler meeting the definition of a gas-fired boiler as defined in 40 CFR 63.11237. Emission Point AA-002 is defined as a new duel-fuel fired boiler meeting the definition of a gas-fired boiler as defined in 40 CFR 63.11237. Emissions Points AA-002 and/or AA-003 would only be considered an affected source, if the facility performs a fuel switch. If the fuel switch occurs, the facility must provide notice of the date upon which the fuel switch occurs within 30 days of the change. Therefore, Emission Points AA-002 and AA-003 are potentially subject to Subpart JJJJJJ if a fuel switch occurs.
Temporary Boilers (Emission Point AA-004) are not subject to Subpart JJJJJJ. By meeting the more stringent requirement of 180 consecutive days for Subpart Dc, the permittee will also meet the temporary boiler definition from Subpart JJJJJJ.

PUBLIC PARTICIPATION

The 30-day public notice period began on , with the publication of a notice in the  and ends .

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.