PUBLIC NOTICE DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Slater Smith 		Date:	March 26, 2019

Company Name:	Omega Protein, Inc

Facility Location:	5735 Elder Ferry Road
			Moss Point, MS 39562

Source Number:	1280-00030

County: 		Jackson

FACILITY DESCRIPTION
Omega Protein, Inc (Omega) owns and operates a fish meal/fish oil production facility. Omega is classified by SIC Code: 2077, and operates under Synthetic Minor Operating Permit (SMOP) No.: 1280-00030.
Omega is an integrated fishing and byproduct processing facility located along the Escatawpa River, as seen in Image 1. Omega operates a fleet of fishing vessels that begins production in April and concludes operations in November. During the fishing and processing season, Omega gathers menhaden in the gulf using large oxidized asphalt/mineral spirit coated nets (Emission Points AA-027, AA-029, and AA-032). The fish are processed into several products.
Fish are removed from fishing vessels and conveyed to three cookers (Emission Points AA-024, AA-025, and AA-026) that receive steam from two industrial boilers (Emission Points AA-003 and AA-011). Emissions generated by Emission Point AA-003 are routed to the Common Vent Stack (Emission Point AA-013) with Deodorizer Spraying (Emission Point AA-031) to reduce the odor. After the cooking process, the byproducts are separated into fish solids and liquids via press/extraction mechanisms. 
The fish solids are conveyed to the Natural Gas, Direct-Fired Dryers (Emission Points AA-004, AA-005, AA-006, AA-007, and AA-034) where any remaining moisture is removed. Emissions from Emission Points AA-004, AA-005, AA-006, and AA-007 are controlled by cyclones and collected by the Primary Dryer Vent (Emission Point AA-033) before the emissions are routed to Emission Point AA-013. The hot, dry fish meal is cooled and conveyed to storage via two Meal Coolers (Emission Points AA-035 and AA-049), controlled by a cyclone and baghouse, respectively. While the fish meal is in storage, the fish meal is treated with a Salmonella Inhibitor Solution (Emission Point AA-030). The fish meal is sold and transported from the facility in hopper trucks or barges.

The liquids separated from the fish solids contain water, fish oil, and other fish solubles. The fish oils are separated from the mixture, refined, and stored in Fish Oil Tanks (Emission Points AA-020- AA-021, AA-022, AA-023, AA-044, or AA-045) prior to sale. The fish solubles are either reintroduced to the fish meal prior to drying or the concentration is stored in Concentrated Fish Soluble, Stickwater, or Omega Grow Storage Tanks (Emission Points AA-036, AA-037, AA-038, AA-039, AA-040, AA-041, and AA-042) prior to sell.
The water separated from the fish solids is evaporated then condensed to be discharged as wastewater. The wastewater is treated via an Ammonia Stripper (Emission Point AA-048) to remove VOCs from the wastewater prior to discharge into the Escatawpa River, as seen in Image 1.
Except as otherwise specified, emissions from equipment or processing equipment vent to the atmosphere.
	
Image 1. Aerial view of Omega Protein, Inc.
Latitude: 30° 25’ 25.66”
Longitude: 88° 30’ 54.34”	

PREVIOUS MODIFICATIONS DURING THE LAST PERMIT CYCLE
The following section describes the four modifications issued to Omega Protein, Inc.’s SMOP during the current permit cycle. All potential emissions due to the modifications can be seen in Table 2. 
2016
Omega proposed the addition of a Net Dipping Storage Tank (5,812 gallons), Natural Gas-Fired Dryer (90 MMBtu/hr), Deodorizer Spraying to reduce odors from the stack, Chemical Spraying of fish meal stockpiles, and a Mineral Spirits Storage Tank (1,200 gallons). The equipment additions coincide with the reduction of hours of operation from 3,200 hours to 2,600 hours per year.
The modification lead to the revision of the short term VOC emission limitation for AA-013, and the fish production limitation on AA-024, AA-025, and AA-026. Also, a once per permit cycle stack test of AA-033 was required for VOC emissions.
2016
Omega proposed the addition of a Meal Cooler controlled by a cyclone (AA-035). The modification included language to monitor the facility-wide hours of operation, while removing facility-wide long term PM/PM10, NOx, and CO emission limitations. Short and long term PM/PM10, NOx, CO, and VOC emission limitations for AA-011 and AA-013 were found to be unnecessary to remain under major source thresholds and were removed from the SMOP.
2017
Omega submitted a reconciliatory permit modification application to add 13 emission sources not included in previous SMOP applications. The application to updated/revised emissions of existing sources based on new information and testing data, as seen in Table 1. The new emission points and revisions of emissions resulted in the increase of PM/PM10 (5.95 tpy) and VOC (1.04 tpy) emissions while remaining below major source thresholds, as seen in Table 2.

Emission Point	Reconciliation	
AA-011 106 MMBTU/hr Natural Gas-fired Boiler	Previous calculations were based on AP-42 factors. Current calculations are based on stack test data.	
AA-013 Common Vent Stack	Emissions reduced due to lower dryer temperatures and air flow rates after the addition of Emission Point AA-034.	
AA-014 Gasoline Storage Tank	Calculations used higher RVP gasoline	
AA-016 Fish Oil Storage Tank
AA-023 Fish Oil Storage Tank	Previous calculations combined the two tanks and vapor pressure was represented by diesel fuel. Current calculations split the emission point to two emission points and used laboratory-measured fish oil vapor pressure.	
AA-020 Fish Oil Storage Tank
AA-021 Fish Oil Storage Tank
AA-022 Fish Oil Storage Tank	Previous calculations were based on diesel vapor pressure. Current calculations used laboratory-measured fish oil vapor pressure.	
AA-024 Cooker #1
AA-025 Cooker #2
AA-026 Cooker #3	Previous calculations were based on 85,000 TPY fish processed. The facility’s throughput is restricted to 66,700 TPY by the equipment downstream of the cookers. Current calculations are based on 66,700 TPY and AP-42 factors.	
AA-027 Net Dip Storage Tank	Previous calculations were based on toluene. Current calculations are based on asphalt and mineral spirits.	
AA-029 Net Dipping Vat	Pervious calculations based on parts washer algorithm. Current calculations based on chemical use records.	
AA-030 Salmonella Inhibitor Spraying	Current calculations based on lab evaporation data from chemical provider to the facility	
AA-034 90 MMBTU/hr Natural Gas-fired Secondary Dryer	Previous calculation included AP-42 estimate of emissions from burner only. Current calculations are based on stack test and includes burner and dryer.	
AA-048 Ammonia Stripper	Lowers content of ammonia in wastewater stream from the evaporators. This is a new emission source.	
AA-049 Number 2 Meal Cooler	Fish Meal cooler controlled by baghouse used for product recovery. This is a new emission source.	
Table 1. Results from internal audit performed by Omega Protein, Inc.
The 2017 audit resulted in the revision and addition of several emission sources.	

2017
Omega submitted a SMOP modification application to add 800 and 1,200 hours of operation to AA-003 and AA-011, respectively. The increase in hours of operation will cause CO (3.72 TPY), NOx (5.88 TPY), and VOC (0.59 TPY) emissions to increase. 
The increase in operational hours for AA-003 and AA-011 is for startup/shutdowns, boiler idle time when fish is not being processed, while waiting for fish to arrive, and during equipment failure. The increased hours will also be used for wash down of equipment, boiler maintenance, and boiler tuning. The resulting emissions increase did not lead breaching the major source threshold.

CURRENT PROJECT/PERMIT ACTION DESCRIPTION
Omega Protein, Inc is applying for reissuance and modification of SMOP 1280-00030. MDEQ received Omega’s application for reissuance/modification on May 17, 2018. In the application, Omega requested to add a 35 ton per hour Cooker #4 (Emission Point AA-050), increasing the facility-wide hourly limit to 3,000 hours, and increasing the capacity of Emission Points  AA-027 and AA-032 to 12,000 and 9,500 gallons, respectively. Emission increases in the permit action will not result in a breach of the major source threshold, as seen in Table 3.
EMISSION SUMMARY
Year	Permit Action	Pollutant Emissions (tpy)	
		PM/PM10	VOC	NOx	SO2	CO	Total HAPs	
2014	Reissuance	26.10	95.50	8.90	0.46	31.90	-----	
2016	Modification	21.62	99.25	58.56	0.25	55.64	-----	
2016	Modification	25.43	98.28	41.04	0.15	40.91	3.50	
2017	Modification	19.00	98.50	17.41	0.26	26.82	1.10	
2017	Modification	19.27	95.06	23.29	0.31	30.54	1.26	
2019	Reissuance	22.17	79.18	24.97	0.34	34.23	1.34	
Table 2. Potential Emissions Summary by Permit Action	

Omega Protein, Inc. was reissued a SMOP in 2014, and following the reissuance the facility modified the SMOP twice in 2016 and 2017. No modifications resulted in the facility becoming a major source. In Table 2, one will notice a large decrease (15.88 tpy) in VOC emissions. The decrease in VOC emissions can be attributed to emission calculations using stack test data (Emission Points AA-011 and AA-013) and an internal audit where emissions data was collected (Emission Points AA-024, AA-025, and AA-026) for calculating the potential emissions. Table 3 demonstrates that Omega remains below the major sources threshold with this reissuance/modification.

Pollutant	Total Emissions  (tpy)	Title V Threshold (tpy)	Major Source (Yes/No)	
PM/PM10	22.17	100	No	
SO2	0.34	100	No	
NOx	24.97	100	No	
CO	34.23	100	No	
VOC	79.18	100	No	
Total HAP	1.34	25	No	
Table 3. Comparison of Emission Summary to Title V Threshold	

APPLICABLE/PROPOSED PERMIT LIMITATIONS
The facility is subject to a facility-wide 99.0 tpy VOC emission limit and 3,000 hours of operation per year, as determined for each consecutive 12-month period of a rolling basis.
Emission Points AA-003, AA-004, AA-005, AA-006, AA-007, AA-011, and AA-034 are natural gas units, and the units are subject to state standards for particulate matter, sulfur dioxide and opacity. The fuel burning equipment shall only combust natural gas. Since natural gas is a relatively clean burning fuel, the units have a large margin of compliance with the PM, SO2 and Opacity standards. 
Emission Points AA-003 and AA-011 shall be granted additional hours of operation. AA-003 shall be limited to 3,400 hours of operation, and AA-011 shall be limited to 3,800 hours of operation, as determined for each consecutive 12-month period of a rolling basis.
Emission Points AA-023, AA-024, AA-025, and AA-050 shall limit the weight of fish processed to 255,000 tons per year, as determined for each consecutive 12-month period of a rolling basis.
Emission Point AA-030 shall be limited to spraying no more than 7,085 gallons of solution per year, as determined for each consecutive 12-month period of a rolling basis.
Emission Point AA-031 shall limit the solution sprayed to no more than 2,880 gallons per year, as determined for each consecutive 12-month rolling total.

STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES (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 (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. Omega is not subject to Subpart Db because AA-003 and AA-011 neither emission point 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 (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. Omega is not subject to Subpart Dc because AA-003 and AA-011 were install prior to June 9, 1989.

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 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). Omega was construct prior to July 23, 1984, and while Emission Points AA-039 and AA-047 have a capacity greater than 19,812.9 gallons, they, have a maximum true vapor pressure less than 15.0 kPa. Therefore, Omega is not subject to Subpart Kb.

NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)/MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) APPLICABILITY
National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Source – Subpart JJJJJJ
Facilities are 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. Omega is an area source of HAP emissions and operates two industrial boilers (Emission Points AA-003 and AA-011); however, Omega is not subject to Subpart JJJJJ because Emission Points AA-003 and AA-011 are natural gas-fired as defined in 63.11237, thus meet the exemption listed in 63.11195(e).

PUBLIC PARTICIPATION
The 30-day public notice period began on April 2, 2019, with the publication of a notice in The Mississippi Press.

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.