PERMIT REVIEW SUMMARY

Permit Writer:	Chappell Ford		 	Date:	January 13, 2026

Company Name:	VBM Three Rivers LLC, VBM Three Rivers

Facility Location:	2006 Pontotoc Parkway W
			Pontotoc, MS 38863
			34°17'35.15"N
			89° 3'41.99"W

Source Number:	2300-00055

County: 		Pontotoc

FACILITY DESCRIPTION

VBM Three Rivers LLC (VBM Three Rivers or VBM) is proposing to construct a renewable natural gas (RNG) processing facility, known as the “Three Rivers RNG Facility”, that will treat and convert landfill gas (LFG) generated at the adjacent Three Rivers Solid Waste Management Authority Regional Landfill (the Landfill) into RNG, a pipeline quality natural gas. The gas treatment process includes the removal of moisture, siloxane/sulfur, and other gas components (e.g., carbon dioxide, oxygen, nitrogen, and volatile organic compounds) leaving the gas with a higher methane concentration. Off-gas from the gas treatment process will be controlled via a thermal oxidizer (TOX) and an off-specification gas flare with limited operation. 

Although VBM is located adjacent to the Landfill and belongs to the same two-digit SIC code (49), VBM and the Landfill do not share common control. The Landfill owns the property and VBM will be considered a lessee, however the facility will be owned and operated by VBM. Therefore, the two facilities are not considered a single stationary source.

Under normal operation, waste gas streams will be routed to the TOX (Emission Point AA-002) for destruction. The TOX may receive off-specification RNG or treated gas if the flare (Emission Point AA-001) is offline. Under normal operation, the flare will be in standby mode. If there is an upset, the flare may combust LFG or off-specification RNG or waste gas streams from PSA #1 and #2. 

The table below lists the proposed emission points at the facility. 

Emission Point	Facility ID	Description	
AA-000	--	Landfill gas processing: filtering, compressing and dewatering	
AA-001	EU-01	68 MMBtu/hr Flare	
AA-002	EU-02	36 MMBtu/hr Thermal Oxidizer (TOX)	

The Facility will operate under SIC Code 4925 and NAICS code 221210.

PROJECT/PERMIT ACTION DESCRIPTION

VBM Three Rivers is requesting an air permit to construct. 

EMISSION SUMMARY

A worst case scenario for all emissions is assumed for the Potential-To-Emit calculations. 

Pollutant	Proposed Facility Uncontrolled Emissions (tpy)	Exceed Title V Threshold (Yes/No)?	
PM/PM10/ PM2.5	18.59	No	
SO2	52.48	No	
NOx	11.23	No	
CO	17.14	No	
VOC	2.95	No	
H2S	0.56	No	
Total HAP	6.66	No	
Individual HAP	6.20	No	

As shown in the table above, VBM Three Rivers does not have the potential to exceed the Title V threshold for any criteria pollutant or Hazardous Air Pollutants (HAPs). While VBM Three Rivers will have two control devices, a TOX and an off-spec gas flare, these devices will not be subject to any state mandated recordkeeping or reporting requirements. As such, the facility will be considered a True Minor Source and will not require a permit to operate. However, since the facility’s emissions of PM, SO2, NOX, and CO are > 10 tpy, the facility is required to obtain a permit to construct. 

NSPS APPLICABILITY

40 CFR 60, Subpart Dc - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units 
This subpart applies to facilities with industrial steam generating units with a rated capacity equal to or greater than 10 MMBtu/hr, but less than 100 MMBtu/hr which were installed, modified, or reconstructed after June 9, 1989. Neither the TOX nor the off-spec gas flare meets the definition of steam generating unit. Therefore, this subpart does not apply.

40 CFR 60, Subpart XXX - Standards of Performance for Municipal Solid Waste Landfills That Commenced Construction, Reconstruction, or Modification After July 17, 2014
This subpart applies to new, modified, or reconstructed landfills on or after July 17, 2014. The VBM Three Rivers site is not a landfill and therefore is not subject to this subpart.

MACT APPLICABILITY

40 CFR 63, Subpart AAAA - National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills
This subpart applies to landfills that have accepted waste since November 8, 1987 and is a major source, collocated with a major source, or is an areas source with a design capacity equal to or greater than 2.5 million megagrams and 2.5 million cubic meters and has estimated uncontrolled emissions equal to or greater than 50 megagrams per year NMOC as calculated according to 40 CFR 63.1959. The VBM Three Rivers site is not a landfill and therefore is not subject to this subpart.

PUBLIC PARTICIPATION

The 30-day public notice period began on April 1, 2026, when the notice was posted on MDEQ’s website and ends May 1, 2026.