Title: afgafgasdgfsd
Author: Bruce Ferguson
Last saved by: Brad Luke
Company: None

Permit Review Summary
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PERMIT REVIEW SUMMARY

Permit Writer:	Brad Luke 	Date:	September 9, 2026
Company Name:	Apache Industrial Services, Apache Moss Point
Facility Location:	10005 Old Stage Road
	Moss Point, Mississippi
Source Number:	1280-00146
County: 		Jackson

FACILITY DESCRIPTION

Apache Moss Point is an industrial facility that will specialize in repairing and refinishing industrial equipment. The facility’s operations fall within SIC Codes 3479 (Coating, Engraving, and Allied Services, Not Elsewhere Classified) and 1799 (Special Trade Contractors, Not Elsewhere Classified), and within NAICS code 332812 (Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to Manufacturers). On-site operations will include abrasive blasting for the removal of rust and old paint, surface coating operations using high volume, low pressure (HVLP) and airless spray guns, site-wide welding activities, and other miscellaneous metalworking (such as grinding, drilling, buffing, and machining) in assigned locations within a manufacturing building. The facility will also utilize storage tanks for waste oil and fuel. The facility is in Jackson County, which is in attainment with the NAAQS standards.

PROJECT/PERMIT ACTION DESCRIPTION

Previously at this location, BrandSafway Solutions LLC performed identical operations under a synthetic minor operating permit (SMOP) issued February 1, 2020, until August 14, 2025, when the SMOP was terminated with operations being dismantled and decommissioned. Apache is applying for a permit to construct (PTC) to authorize surface coating and abrasive blasting operations and to update the permit owner / operating company name of the Moss Point Facility to accurately represent the entity leasing the property. The following table includes the emission points to be incorporated into the permit:

Emission 
Point

Description

AA-001 | Abrasive Blasting Operations [consists of two (2) non-enclosed abrasive blasting areas (equipment is blasted within a 3-sided shrouded area) and blasting stockpiles]
AA-002 | Surface Coating Operations [consists of a non-enclosed spray-painting area and a paint air drying building]
AA-003 | Miscellaneous Metalworking Operations [consists of grinding, buffing, drilling, machining, and welding]
AA-004 | 2,000-Gallon Portable Gasoline Storage Tank
AA-005 | 3,000-Gallon Portable Diesel Storage Tank

EMISSION SUMMARY

| PM_10 + PM_2.5 | SO_2 | NO_X | CO | VOCs | Ind. HAP* | Total HAPs
Uncontrolled Potential Emissions (tpy) | 326.48 | 0 | 0 | 0 | 167.82 | 239.30 | 271.21
Emission Limitations (tpy) | 99.0 | N/A | N/A | N/A | 99.0 | 9.0 | 24.0
*Maximum facility-wide emissions for an individual HAP are based on xylene pollutant

APPLICABLE/PROPOSED PERMIT LIMITATIONS

Maximum uncontrolled emissions for the Apache Moss Point facility exceed the Title V major source thresholds of 100 tpy for Particulate Matter under 10 microns (PM_10), Particulate Matter under 2.5 microns (PM_2.5), and volatile organic compounds (VOCs). The maximum uncontrolled emissions exceed the hazardous air pollutant (HAP) major source thresholds of 10 tpy for any individual HAP and 25 tpy for total HAPs. Apache’s maximum uncontrolled emissions of PM_10 and PM_2.5 exceed the Prevention of Significant Deterioration (PSD) major source threshold of 250 tpy. However, to avoid becoming major source for Title V, HAPs, and PSD, Apache proposes to comply with the following facility wide emission limitations for PM_10, PM_2.5, VOCs, and HAPs: 
•	PM less than 10 microns in diameter (PM_10) – 99.0 tpy
•	PM less than 2.5 microns in diameter (PM_2.5) – limited as a fraction of the PM_10 limitation
•	Volatile Organic Compounds (VOCs) – 99.0 tpy 
•	Hazardous Air Pollutants (HAPs) – 9.0 tpy for any individual HAP and 24.0 tpy for total HAPs
By complying with the 99.0 tpy emission limit on PM_10 the facility is effectively limiting PM_2.5 to below the 99.0 tpy threshold as well, as PM_10 encompasses PM_2.5. Additionally, by complying with a 99.0 tpy emission limitation, the facility will remain below the 250 tpy PSD major source threshold for PM_10 and PM_2.5.
This permitting action will remove the 249.0 tpy PSD avoidance limit for PM measured as Total Suspended Particulate (TSP). The reason for this removal is TSP is no longer a national ambient air quality standard (NAAQS) pollutant for PM under 40 CFR 51.166(b)(49), which establishes PM_10 and PM_2.5 as the PM pollutants for NAAQS. 
Specific monitoring, recordkeeping, and reporting requirements are addressed in the draft permit to ensure compliance with the limits, including the monitoring of abrasive blasting media and coating / solvent usage. This information is used to calculate monthly and 12-month rolling total emissions of PM_10, HAPs, and VOCs from abrasive blasting and coating operations.

NSPS APPLICABILITY

40 CFR 60, Subpart Kc – Standards of Performance for Volatile Organic Liquid Storage Vessels for which Construction, Reconstruction, or Modification Commenced after October 4, 2023: Subpart Kc applies to facilities that that operate storage vessels with a capacity greater than or equal to 20,000 gallons that are used to store volatile organic liquids for which construction, reconstruction, or modification commenced after October 4, 2023. Apache Moss Point operates a 2,000-gallon portable gasoline storage tank and a 3,000-gallon portable diesel storage tank. Both storage tanks have a capacity well below 20,000 gallons, so Apache Moss Point is not subject to the requirements of Subpart Kc.

MACT APPLICABILITY

40 CFR 63, Subpart MMMM – National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products: Subpart MMMM applies to facilities that operate surface coating operations of miscellaneous metal parts and products at major sources of HAPs. Apache Moss Point engages in the surface coating of cleaned equipment parts. The facility will take federally enforceable limits to remain below the HAP major source threshold of 10 tons per year (tpy) of any individual HAP and 25 tpy for total HAPs, so Apache Moss Point is not subject to the requirements of Subpart MMMM. 

40 CFR 63, Subpart CCCCCC—National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities: Subpart CCCCCC applies to gasoline dispensing facilities at area sources. The fuel tanks used by Apache Moss Point are portable not stationary and will commonly be moved from site to site for project work. The gasoline tank will typically be filled by fuel suppliers coming to the off-site project sites to re-fuel the tank, occasionally the tank may be filled at the Moss Point site to fuel equipment for projects but then moved back to off-site project sites as needed. The tank will be filled by the fuel supplier coming to the tank to fill it and will not be a situation where a portable gasoline tank is filled from a fixed gasoline storage tank for the on-site delivery and subsequent dispensing of gasoline into the fuel tank of an engine or other equipment. Therefore, for all the reasons listed above Apache Moss Point is not subject to the requirements of Subpart CCCCCC.

40 CFR 63, Subpart HHHHHH – National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources): Subpart HHHHHH applies to facilities that operate miscellaneous paint stripping and surface coating operations at area sources of HAPs. Apache Moss Point performs surface coating and paint stripping operations and is an area source of HAPs. However, it does not use chemical strippers containing methylene chloride in paint stripping operations and the coatings used in its spray operations do not contain the target HAPs of chromium, lead, manganese, nickel, or cadmium. Therefore, Apache Moss Point is not subject to the requirements of Subpart HHHHHH.

40 CFR 63, Subpart XXXXXX – National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories: Subpart XXXXXX applies to area sources including dry abrasive blasting, machining, dry grinding and polishing, spray painting, and welding that are primarily engaged in operations in one of the nine source categories listed in the subpart. According to an EPA guidance document ‘Nine Metal Fabrication and Finishing Area Source Categories 40 CFR Part 63 Subpart XXXXXX (6X) NESHAP Questions & Answers Revised June 2020’, SIC Codes 3479 (Coating, Engraving, and Allied Services, Not Elsewhere Classified) and 1799 (Special Trade Contractors, Not Elsewhere Classified) are not part of the affected categories. Therefore, while Apache Moss Point engages in abrasive blasting, machining, grinding, surface coat spraying, and welding during its repairing and refinishing operations, it is not subject to the requirements of Subpart XXXXXX.

PUBLIC PARTICIPATION

The 30-day public notice period began on September 16, 2026, when the notice was posted on MDEQ’s website and ends October 19, 2026.

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