PERMIT REVIEW SUMMARY
Permit Writer:	Ryan Ozment	 	Date:	January 13, 2021
Company Name:	AmeriPride Services Inc, Durant Plant
Facility Location:	105 Landrum Street
Source Number:	1140-00061
County: 		Holmes
FACILITY DESCRIPTION
AmeriPride Services operates an industrial laundry facility in Durant, Mississippi.  The plant was acquired by AmeriPride in December 2015.  Previously the plant had not held an air construction or operating permit at the time.  AmeriPride evaluated the plant-wide emissions and determined it required a permit to operate.  AmeriPride applied for a Synthetic Minor Operating permit and proposed limitations to remain a minor source for Title V and HAP purposes.  
The plant launders soiled garments and other soiled textiles for use a by a variety of customers at off-site locations.  Soiled textiles at the site include linens, uniforms, towels, mats, dust mops, and other garments.  Once on site, they are sorted by textile type, weighed, conveyed to an industrial washer, washed using water and detergent, and transported to a natural gas-fired dryer.
SYNTHETIC MINOR LIMITATIONS
The facility-wide potential emissions were determined on an 8760 hour per year basis and for a maximum plant throughput of 45,864,000 lbs of shop towels per year.  Potential Emissions for the facility surpasses the Title V threshold of 100 tons per year for VOC (volatile organic compounds).  AmeriPride will limit these emissions to below 99 tons per year  limiting the plant shop towel throughput to 100,000 lbs per year.  Shop towels are the only laundered items at this site that contain VOC and HAP.  Limiting the throughput will make potential VOC emissions less than five (5) tons per year.  The facility also has the potential to emit HAP (hazardous air pollutant) above major source thresholds (25 tons per year for total HAP, and 10 tons per year for individual HAP).  By limiting the throughput, the facility’s potential for combined HAP will be less than one (1) tons per year.
PROJECT/PERMIT ACTION DESCRIPTION
In March 2019, Ameripride applied for a modification to the synthetic minor operating permit.  In this modification, the facility applied to install an additional dryer (Emission Point AA-010).  After reviewing the application, it was determined that Aramark Uniform & Career Apparel, LLC, had acquired the facility.  The facility submitted a transfer form in September 2020.  That permitting action will be processed with this modification.
EMISSION SUMMARY
Pollutant	Maximum Uncontrolled Emissions 	Proposed Allowable Emissions	
	(tons/year)	
Particulate Matter (10 and 2.5 µm)	9.24	9.24	
Sulfur Dioxide	0.10	0.097	
Nitrogen Oxides	17.3	17.3	
Carbon Monoxide	14.6	14.6	
Volatile Organic Compounds	561	99.01	
Hazardous Air Pollutants, Total	245	24.01	
Hazardous Air Pollutants, Individual	--	9.01	
1Limitations taken to ensure source remains a synthetic minor area source.  The facility will meet these limits by limiting laundry throughput.
APPLICABLE/PROPOSED PERMIT LIMITATIONS
11 Miss. Admin. Code Pt. 2, R. 2.2.B(10):  The facility will limit VOC to below 99.0 tons a year.  The facility will limit aggregate HAP emissions to below 24.0 tons a year.  The facility will also limit any single HAP to below 9.0 tons a year.  The facility will also limit laundry throughput to below 100,000 pounds each year.
11 Miss. Admin. Code Pt. 2, R. 1.3. A and B:  The facility will limit opacity and equivalent opacity to below 40%.
11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(b):  The maximum permissible emissions of PM from any fossil fuel burning installations greater than 10 MMBTU per hour heat input and less than 10,000 MMBTU per hour is determined by the relationship 
E = 0.8808 × I-0.1667
where E is the emission rate in pounds per MMBTU per hour heat input and I is the heat input in MMBTU per hour.
11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(a):  The maximum permissible emission of ash and/or PM from fossil fuel burning installations shall be limited to 0.6 pounds per MMBTU per hour heat input.
11 Miss. Admin. Code Pt. 2, R. 1.4.A(1):  The maximum discharge of sulfur oxides from any fuel burning installations where fuel is burned primarily for heat or power by indirect heat transfer shall not exceed 4.8 lbs (measured as sulfur dioxide) per MMBTU heat input.  
NSPS APPLICABILITY
40 CFR 60, Subpart Dc (Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units):  this subpart applies to steam generating units constructed, modified, or reconstructed after June 1989 and has a capacity between 10 and 100 MMBTU per hour; therefore, this subpart applies to emission point AA-001.  The PM and SO2 standards in this subpart apply to affected sources that combust coal or coal in combination with other fuels.  The facility has proposed to only combust natural gas and will record and report the amount and type of fuel used semiannually.  
MACT APPLICABILITY
40 CFR 63, Subpart DDDDD (National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters):  this subpart applies to boilers at major sources of HAP.  Because the facility will be limiting throughput, it will not be a major source of HAP; therefore, this subpart does not apply.
40 CFR 63, Subpart JJJJJJ (National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources):  this subpart applies to boilers at area sources of HAP; however, gas-fired boilers are not subject to the subpart.  Therefore, Subpart JJJJJJ does not apply.
PUBLIC PARTICIPATION
The 30-day public notice period began on March 18, 2021, with the publication of a notice in the Holmes County Herald and ends April 17, 2021.
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.