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

Permit Review Summary
Page

PERMIT REVIEW SUMMARY

Permit Writer:	Brad Luke	Date:	September 16, 2026
Company Name:	C. L. Dews and Sons Foundry and Machinery Company, Inc.
Facility Location:	1600 Edwards Street
Hattiesburg, MS 39401
Source Number:	0800-00008
County: 		Forrest

FACILITY DESCRIPTION

C. L. Dews and Sons Foundry and Machinery Company, Inc. (C. L. Dews and Sons) is an existing industrial facility that produces gray iron castings and fabricates structural steel products for municipal, commercial, and industrial applications. These specific products include storm gratings, manholes, bridge bearings, and flanges. The facility’s operations are classified by SIC Codes 3321 (Gray and Ductile Iron Foundries) and 3441 (Fabricated Structural Metal). 

Activities at the facility include welding, machining, grinding, tooling, abrasive blasting, surface coating, wood working and coating, molding and core-making, along with ancillary material handling. Additionally, the facility operates two (2) 3.0 MMBTU / hour heat treating furnaces, one (1) 0.4 MMBTU / hour ladle pre-heater, and five (5) natural gas-fired space heaters.

PROJECT/PERMIT ACTION DESCRIPTION

C. L. Dews and Sons are requesting a renewal of the Synthetic Minor Operating Permit (SMOP) issued to the facility on October 5, 2021, and modified on November 8, 2022. The facility has not proposed any changes to the facility’s synthetic‑minor status and the equipment, throughput limits, hours, and permitted limits will remain unchanged. C. L. Dews and Sons have updated the site layout and emission point map, and request MDEQ administratively recognize the relocation of the sandblasting operations (Emission Point AC-012) to a location adjacent to the chemical storage area and across from the foundry building.

EMISSION SUMMARY

The facility has not proposed any modifications or additions that increase emissions; however, more accurate calculation methodology has been utilized in the permit application to provide more accurate maximum uncontrolled emissions. Maximum uncontrolled emissions of particulate matter (PM) under 2.5 microns in diameter (PM_2.5) and PM under 10 microns in diameter (PM_10) exceed the Title V major source thresholds of 100 tons per year (tpy). The facility has established a standard to always operate steel blasting operations (Emission Point AC-002) and sand reclamation operations (Emission Point AC-008) with the baghouse control device, which will keep emissions of PM_10 + PM_2.5 (PM_10 encompasses PM_2.5 so limiting PM_10 effectively limits PM_2.5) below the Title V major source threshold. The maximum uncontrolled emissions of volatile organic compounds (VOCs) exceed the Title V major source threshold of 100 tpy and the prevention of significant deterioration (PSD) major source threshold of 250 tpy, but the facility has taken a facility-wide emission limitation of 99.0 tpy of VOCs. The maximum uncontrolled emissions of individual hazardous air pollutants (HAPs), and total HAPs exceed the respective HAP major source thresholds of 10.0 tpy and 25.0 tpy, but the facility has taken a facility-wide emission limitation of 9.0 tpy for individual HAPs and 24.0 tpy for total HAPs. 

| PM_10 + PM_2.5 | SO_2 | NO_X | CO | VOCs | Lead | Ind. HAPs^* | Total HAPs
Maximum Uncontrolled Emissions (tpy) | 153.98 | 0.02 | 2.75 | 2.31 | 1,930.05 | 2.17 | 1,548.83 | 1,809.40
Potential Emissions with Proposed Limitations (tpy) | 30.69 | 0.02 | 2.75 | 2.31 | 99.0 | 2.17 | 9.0 | 24.0
^*Maximum reported individual HAP at the facility is “Toluene”

The maximum uncontrolled emissions of HAPs and VOCs represent the calculation of the worst-case uncontrolled scenario. In this scenario, spray coating operations are running at the maximum spray rate of 57 gallons per hour for 8,760 hours nonstop while spraying the surface coating materials that have highest VOC and HAP content. Actual VOC and HAP emissions from the facility are much lower. 

APPLICABLE/PROPOSED PERMIT LIMITATIONS

The facility’s permit limitations will remain the same as the previous permit. C.L. Dew and Sons will continue to operate the steel blasting operations and the sand reclamation operations with the associated baghouses to minimize PM_10 + PM_2.5 emissions. The facility will maintain the facility-wide emission limitation on 99.0 tpy for VOCs, 9.0 tpy for individual HAPs, and 24.0 tpy for total HAPs. These emission limits have been established in the SMOP since 2004. Outdoor Sand Blasting Operations will continue to be limited to 800 hours per year. This requirement was originally incorporated into the SMOP reissued October 5, 2021, due to the application stating that “Dews has estimated that if they had unlimited orders that the most they could outdoor sandblast is 800 hours.”

Emission 
Point(s)

Applicable Requirement

Pollutant / 
Parameter

Limitation / Standard

Compliance Demonstration

AA-000 (Facility-Wide)

11 Miss. Admin. Code Pt. 2, 2.2.B(10).

HAPs

< 9.0 tpy (Individual)
< 24.0 tpy (Total) 
(12-Month Rolling Totals)

Calculate and Record Emissions

| | VOCs | < 99.0 tpy                         (12-Month Rolling Total) |
| 40 CFR 63.10885(a), Subpart ZZZZZ | HAPs | Metallic Scrap Management Program | Maintain Documentation of Adherence to Scrap Metal Management Program
| 40 CFR 63.10886, Subpart ZZZZZ | | Adhere to Chemical Formulation Requirement | Maintain Documentation of Adherence to Chemical Formulation Requirement
AC-002 AC-008 | 11 Miss. Admin. Code Pt. 2, R. 2.2.B(10). | PM_10 + PM_2.5 | Operate with baghouse at all times | Monitor the Pressure Drop Across the Baghouse Weekly
AC-012 | 11 Miss. Admin. Code Pt. 2, R. 2.2.B(10). | | Limit Sandblasting to 800 hours per year | Monitor the Hours of Sand Blasting Outside

NSPS APPLICABILITY

Based on the operations and process equipment on-site there is no potentially applicable subpart found in 40 CFR Part 60.

MACT APPLICABILITY

40 CFR Part 63, Subpart ZZZZZ – National Emission Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries Area Sources: The provisions of Subpart ZZZZZ apply to any facility that is an area source of HAP emissions and operates an iron / steel foundry. Given that the facility meets all of the noted criteria, C. L. Dews and Sons is subject to Subpart ZZZZZ. More specifically, the facility is subject to metallic scrap management practices because it is considered an “existing small foundry”. Existing small foundries are considered to be existing if they were constructed before September 2007 and small if they have an annual metal melt production of 20,000 tons of less.

40 CFR Part 63, Subpart XXXXXX – National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories: The provisions of Subpart XXXXXX apply to facility’s primarily engaged in metal fabrication and finishing activities, including welding, machining, grinding, abrasive blasting, and surface coating and has historically been associated with SIC Code 3441. The facility conducts both foundry operations and structural steel fabrication activities. The facility's primary manufacturing operation is the production of castings through its foundry operations. Structural steel fabrication represents a separate portion of the facility's overall manufacturing activities. The facility's structural fabrication activities include welding, machining, grinding, abrasive blasting, and painting/coating; however, these activities are performed as part of individual fabrication projects and do not represent a separate, consistently measurable production stream comparable to the facility's foundry casting production. The structural fabrication portion represents substantially less than 50 percent of the facility's overall manufacturing production, and accordingly, the individual structural steel fabrication and finishing activities do not constitute fifty percent (50%) or more of the facility's overall manufacturing production. The facility's primary manufacturing activity remains the production of castings through the foundry operation. Therefore, the facility is not primarily engaged in a metal fabrication and finishing source category subject to 40 CFR Part 63, Subpart XXXXXX, and facility is not subject to the requirements of Subpart XXXXXX.

40 CFR Part 63, Subpart HHHHHH – Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources: The provisions of Subpart HHHHHH apply to paint stripping operations that involve the use of chemical strippers that contain methylene chloride (MeCl), Chemical Abstract Service number 75-09-2, in paint removal processes; autobody refinishing operations that encompass motor vehicle and mobile equipment spray-applied surface coating operations; or spray application of coatings containing compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd), collectively referred to as the target HAP, to any part or product made of metal or plastic, or combinations of metal and plastic that are not motor vehicles or mobile equipment. The facility does perform surface coating; however, they do not meet any of the three criteria listed above, specifically the facility does not apply coatings that contain any of the target HAP compounds. Therefore, the facility is not subject to Subpart HHHHHH.

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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