PERMIT REVIEW SUMMARY

Permit Writer:	Jeffrey Bland			Date:	August 9, 2026

Company Name:	PG Technologies LLC

Facility Location:	135 Technology Boulevard, Ellisville, MS 39437

Source Number:	1360-00158

County: 		Jones

FACILITY DESCRIPTION
PG Technologies, LLC (PGT) is an industrial facility that operates surface coating operations that are used to coat various parts for clients. Operations at the facility fall under SIC Code 3479, Coating, Engraving, and Allied Services, Not Elsewhere Classified and NAICS Code 332812, Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to Manufacturers.

PROJECT/PERMIT ACTION DESCRIPTION
PGT submitted an application to modify the current Synthetic Minor Operating Permit (SMOP) in December 2025 and another in June 2026. The June 2026 modification application also indicated it was being submitted as  a renewal of the SMOP since it expires November 30, 2026. Since the requested modifications significantly impacted the emission points identified in the previous SMOP, this permitting action is being processed to incorporate the requested modifications and to renew the facility’s SMOP. The Permit to Construct issued in January 2017 is concurrently being modified to update the Emission Point descriptions to reflect the changes requested in the two SMOP modification requests.
The modification application submitted in December 2025 requested changes to the following:
•	Emission Point AA-001 – Removal of two (2) grit blasting units and associated control equipment (GB-27, GB-28, DC-27G, and DC-28G) and changes to the facility references for the remaining grit blasters.
•	Emission Point AA-002 – Removal of a coating station and associated control equipment (HV003 and DC-28) and changes to the facility references for the remaining equipment.
•	Emission Point AA-003 – Addition of two (2) vapor deposition coating stations and associated control equipment (EC010, EC011, DC-EC010, DC-EC011) and changes to the facility references for the other equipment.
•	Emission Point AA-004 – Removal of three (3) coating booths and associated control equipment (SS002, SS003, SS004, DC-41, DC-42, and  DC-43) and changes to the facility reference for the remaining control equipment.
•	Emission Point AA-006 – Addition of a coating station (PA005).
•	Emission Point AA-008 – Removal of two coating stations an associated control equipment (P002, P003, DC-30, and DC-31) and changes to the facility reference for the remaining control equipment.
•	Emission Point AA-009 – Removal of a coating station and associated control equipment (HY002 and DC-36) and changes to the facility reference for the remaining control equipment.
•	Emission Point AA-010 – Removal of one coating station and associated control equipment (S003 and DC-44) and changes to the facility reference for the remaining control equipment. 
•	Emission Point AA-011 – Removal of the two (2) surface finishing systems and associated control device (SF-1, SF-2, and DC-41) and the addition of a NgTBC Coating Process that dabs an aluminum nitrate coating onto parts. These parts are rinsed and then cured in three (3) electric ovens.
•	Emission Point AA-015 – Addition of a natural gas-fired rooftop air handling unit (RTU-22) with a maximum rated heat capacity of 0.70 MMBtu/hr; a natural gas-fired boiler (B005) with a maximum rated heat capacity of 0.63 MMBtu/hr; and two (2) natural gas-fired emergency generators (EG-3 and EG-4) each with a maximum rated heat capacity of 0.44 MMBtu/hr (42 HP/31 kW). Since the emergency generators will have additional federal requirements, these units are included in the proposed permit under Emission Point AA-015a.
•	Emission Point AA-016 – Addition of three (3) dry ice blasters, two (2) wet blast cleaning operations, four (4) additional TIG Welding Stations and a Plasma Cutting Station to the Maintenance Welding activities, and the addition of three (3) manual grit blasters.
•	Requested removal of duplicated Emission Points in Section 2.
•	Requested a reduction in frequency for the weekly monitoring of differential pressure of the dust collectors to quarterly. The proposed permit has been modified to require such monitoring on a bi-weekly basis.   
The modification application submitted in June 2026 requested changes to the following:
•	Emission Point AA-001 – Additional changes to the facility references was requested.
•	Emission Point AA-003 - Addition of two (2) vapor deposition coating stations and associated control equipment (EC012, EC013, DC-EC012, DC-EC013).
•	Emission Point AA-005 – Addition of another coating station (VF010).
•	Emission Point AA-006 – Addition of two (2) coating stations (PA006 and PA007) and additional clarifying language concerning the process and associated equipment (i.e., tanks).
•	Emission Point AA-007 – Addition of a coating station (N002).
•	Addition of a fully enclosed laser ablation system used to remove coatings from tools used in the EC013 coating process. Emissions are controlled using a high-efficiency particulate air (HEPA) filtration system. The proposed permit identifies this equipment in Emission Point AA-017.
•	Emission Point AA-016 - Addition of two (2) wet blast operations to clean tooling from the EC012 and EC013 coaters.
In addition to the requested changes, a condition requiring the facility to monitor the scrubber liquid level (Emission Point AA-005) has been added to verify the scrubber used to demonstrate compliance with HAP emissions is being operated as designed.
EMISSION SUMMARY
The maximum uncontrolled emissions exceed the Title V major source threshold of 100 tons per year for Particulate Matter less than 10 microns (PM10), Particulate Matter less than 2.5 microns (PM2.5). Additionally, the maximum uncontrolled emissions of hazardous air pollutants (HAP) exceed the Title V major source thresholds of 25 tons per year for total combined HAP and 10 tons per year for the following individual HAP: chromium, nickel, and cobalt. However, the facility uses control devices (i.e., dust collectors and a wet scrubber) to limit the facility’s potential to emit below the applicable Title V thresholds. 

The table below contains a summary of the emissions from the facility upon issuance of the initial SMOP and after the requested modifications in December 2025 and June 2026.
Facility-Wide Potential-to-Emit/Allowable Summary1
Pollutant	PTE/Allowable Emissions
(tons/yr)
2021 SMOP	PTE/Allowable Emissions
(tons/yr)
After Mods	Net Change (tons/yr)	
Particulate Matter (TSP)	47.95	45.37	-2.58	
PM10	37.90	34.56	-3.34	
PM2.5	37.60	34.26	-3.34	
Sulfur Dioxide (SO2)	0.16	0.16	-	
Nitrogen Oxides (NOX)	26.20	27.15	0.95	
Carbon Monoxide (CO)	14.86	15.66	0.80	
Volatile Organic Compounds (VOC)	44.75	24.33	-20.42	
Total Reduced Sulfur (TRS)	-	-	-	
Lead	-	-	-	
CFC/HCFC	-	-	-	
Total HAP	24.0	24.0	-	
1 The PTE/Allowable emissions reflect any emission limits or enforceable restrictions included in the proposed permit.
APPLICABLE/PROPOSED PERMIT LIMITATIONS
•	Title V Avoidance Limit for HAP – PGT established limits in the 2017 Permit to Construct and previous SMOP of 9.0 tons per year for individual HAP and 24.0 tons per year for combined HAP determined on a rolling 12-month total basis. As such, the facility is considered an area source of HAP emissions. Compliance with the HAP limits consists of the development and implementation of a HAP monitoring plan, monthly HAP emission rate calculations, and submittal of HAP the emission totals for each 12-month period in the annual monitoring report (AMR).
•	Title V Avoidance Limit for PM10 and PM2.5 – PGT established a limit of 99.0 tons per year determined on a rolling 12-month total basis in the previous SMOP for both PM10 (filterable and condensable) and PM2.5 (filterable and condensable). PGT complies with these limits by operating and maintaining all dust collectors and other control devices any time the processes are operating, monthly PM10 and PM2.5 emission rate calculations, and submittal of the emission totals for each 12-month period in the AMR.
•	PSD Avoidance Limit for PM – Total PM (filterable) is not considered a Title V criteria pollutant; however, it is a considered a new source review (NSR) criteria pollutant. PGT is potentially subject to the applicable Prevention of Significant Deterioration (PSD) requirements since the facility’s maximum uncontrolled PM emissions would exceed 250 tons per year; however, PGT is not subject to the PSD requirements since the facility is required to operate the dust collectors at all times the corresponding process equipment is in operation in order to minimize PM emissions. 

NSPS APPLICABILITY
•	40 CFR 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines – The provisions of Subpart IIII are applicable to stationary compression ignition internal combustion engines that are constructed after July 11, 2005, and that are manufactured after April 1, 2006, or July 1, 2006 (NFPA fire pump engines). PGT operates three (3) stationary diesel-fired, emergency engines that were constructed and manufactured after the applicability dates; therefore, they are subject to the Subpart IIII requirements. The engines are required to be certified to meet the applicable emission standards and must install non-resettable hour meters to monitor hours of operation. The applicable emission and operating limits and associated monitoring, recordkeeping, and reporting requirements are included in the proposed permit.
•	40 CFR 60, Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines - The provisions of Subpart JJJJ are applicable to stationary spark ignition internal combustion engines that are constructed after June 12, 2006, and that are manufactured after the specific dates contained in 40 CFR 60.4230(a)(4)(i) through (iv). PGT has requested to add two (2) stationary natural gas-fired, emergency engines which will be constructed and manufactured after the applicability dates; therefore, the engines will be subject to the Subpart JJJJ requirements. These engines have been added to the permit as Emission Point AA-015a, are required to be certified to meet the applicable emission standards, and must install non-resettable hour meters to monitor hours of operation. The applicable emission and operating limits and associated monitoring, recordkeeping, and reporting requirements are included in the proposed permit.

MACT APPLICABILITY
•	40 CFR 63, Subpart HHHHHH, National Emission Standards for Hazardous Air Pollutants (NESHAP): Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources – The provisions of Subpart HHHHHH are applicable to facilities that are considered area sources of HAP emissions with the following operations: (1) paint stripping that uses methylene chloride (MeCl); (2) spray-applied surface coating of motor vehicle and mobile equipment; (3) spray application of coatings which contain a target HAP (i.e., chromium, lead, manganese, nickel, or cadmium) to any part or product made of metal or plastic or combination thereof, that are not motor vehicle or mobile equipment. PGT is considered an area source of HAP emissions and does use coatings that contain one or more of the target HAP; however, none of the coating operations at the facility are considered “spray-applied coating operations” as defined in 40 CFR 63.11180 of Subpart HHHHHH.
•	40 CFR 63, Subpart WWWWWW, NESHAP: Area Source Standards for Plating and Polishing Operations – The provisions of Subpart WWWWWW are applicable to plating and polishing facilities which are considered an area source of HAP emissions that uses or has emissions of one or more metal HAP (i.e., cadmium, chromium, lead, manganese, and nickel). A plating and polishing facility is a plant site that is engaged in one or more of the following processes: (1) Electroplating other than chromium electroplating; (2) Electroless or non-electrolytic plating; (3) Other non-electrolytic metal coating processes, such as chromate conversion coating, nickel acetate sealing, sodium dichromate sealing, and manganese phosphate coating; and thermal spraying; (4) Dry mechanical polishing of finished metals and formed products after plating or thermal spraying; (5) Electroforming; and (6) Electropolishing.
The coating operations identified as Emission Points AA-002, AA-008, and AA-009 are considered “other non-electrolytic metal coating processes”. More specifically, they are thermal spraying operations where metallic coatings are applied by projecting heated, molten, or semi-molten metal particles onto a substrate. These coating operations can utilize coatings that contain chromium and/or nickel; therefore, these Emission Points are subject to the Subpart WWWWWW requirements. The applicable requirements of Subpart WWWWWW are included in the proposed permit.
•	40 CFR 63, Subpart ZZZZ, NESHAP for Stationary Reciprocating Internal Combustion Engines (RICE) – The provisions of Subpart ZZZZ are applicable to stationary reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions. The facility is considered an area source of HAP emissions and has five (5) emergency engines identified as Emission Points AA-014a, AA-014b, AA-014c, and AA-015a that are subject to the Subpart ZZZZ requirements.
For purposes of Subpart ZZZZ, Emission Points AA-014a, AA-014b, and AA-014c are considered new, emergency compression ignition (CI) stationary RICE located at an area source of HAP emissions. The two engines listed in Emission Point AA-015a are considered new, emergency spark ignition (SI) stationary RICE located at an area source of HAP emissions. Per 40 CFR 63.6590(c)(1), all engines shall comply with the Subpart ZZZZ requirements by complying with the applicable requirements of 40 CFR 60, Subparts IIII and JJJJ, respectively. 

PUBLIC PARTICIPATION
The 30-day public notice period began on , when the notice was posted on MDEQ’s website and ends .