DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Slater Smith 	Date:	July 15, 2021
Company Name:	Louis Dreyfus Company River Elevators LLC, Port of Rosedale, River Elevator
Facility Location:	489 David Work Drive
Source Number:	0240-00097
County: 		Bolivar
FACILITY DESCRIPTION
Louis Dreyfus Company River Elevators LLC, Port of Rosedale, River Elevator (Louis Dreyfus) manages an existing grain elevator.  Whole grains such as corn, soybeans, wheat, milo, and rice are received via truck.  Grains are unloaded at two receiving areas each having two hopper truck dump pits, and grains are subsequently transferred into storage bins via a bucket elevator.  There are six storage silos with a total storage capacity of 2,225,000 bushels.  If necessary, grain is dried in the grain tower dryer.  The grain dryer is the only fuel burning equipment onsite. Grains are loaded out into trucks or barges and are sent to loadout through either a truck loadout leg/spout or the barge loadout covered belt.  Louis Dreyfus operates two baghouses to control particulate matter (PM) emissions onsite. The aforementioned equipment and production areas are sources of PM, PM less than 10 μm in diameter (PM10), PM less than 2.5 μm in diameter (PM2.5), Sulfur Dioxide (SO2), Carbon Monoxide (CO), Volatile Organic Compounds (VOC), and Hazardous Air Pollutant (HAP) emissions.
The following sections will specifically address the project/permit action description, emission summary, applicable/proposed permit limitations, Standards of Performance for New Stationary Sources (NSPS) applicability, and National Emissions Standards for Hazardous Air Pollutants (NESHAP)/ Maximum Achievable Control Technology (MACT) applicability.

PROJECT/PERMIT ACTION DESCRIPTION
Louis Dreyfus is requesting modification of Synthetic Minor Operating Permit (SMOP) Air Ref. No. 0240-00097 to incorporate the following changes: accurately name/describe emission sources (Emission Points AA-001, AA-002, AA-010, AA-011, AA-012, AA-013, AA-014, AA-015, AA-016), include existing emission sources that were not explicitly listed in the permit (Emission Points AA-021, AA-022, AA-023, AA-024, AA-025, AA-026, AA-027, AA-028, AA-029, AA-030, AA-031), and add additional equipment (Emission Point AA-032, AA-033, AA-034). The emission sources affected by the modification can be seen in Table 1 below.

Emission 
Point	Facility Reference	Description According to Previous Permitting Action	Proposed Description	
AA-001	1-13	Receiving Dust Control Baghouse System controls emissions from grain receiving and grain handling (DF-500)	20,000 CFM Receiving Dust Control System	
AA-002	2-13	Cartridge Filter Baghouse controls emissions from grain receiving and grain handling (DF-510)	20,000 CFM Receiving Dust Control System	
AA-010	10-13	40,000 BPH Reclaim Belt (BC-310)	20,000 BPH Reclaim Belt (BC-400)	
AA-011	11-13	40,000 BPH Reclaim Belt (BC-320)	20,000 BPH Reclaim Belt (BC-500)	
AA-012	12-13	30,000 BPH Transfer Belt (BC-140)	20,000 BPH Transfer Belt (BC-202)	
AA-013	13-13	30,000 BPH Transfer Belt (BC-150)	20,000 BPH Transfer Belt (BC-201)	
AA-014	14-13	40,000 BPH Transfer Belt (BC-330)	40,000 BPH Transfer Belt (BC-332)	
AA-015	15-13	10,000 BPH Dry Drag (DC-430)	15,000 BPH Dry Drag (DC-308)	
AA-016	16-13	12,000 BPH Wet Drag (DC-400)	15,000 BPH Wet Drag (DC-302)	
AA-021	1-14	Omitted Existing Emission Source	20,000 BPH Receiving Drag (DC-103)	
AA-022	1-15	Omitted Existing Emission Source	20,000 BPH Receiving Drag (DC-109)	
AA-023	2-14	Omitted Existing Emission Source	20,000 BPH Receiving Drag (DC-102)	
AA-024	2-15	Omitted Existing Emission Source	20,000 BPH Receiving Drag (DC-108)	
AA-025	11-14	Omitted Existing Emission Source	20,000 BPH Reclaim Belt (BC-600)	
AA-026	12-14	Omitted Existing Emission Source	20,000 BPH Transfer Belt (BC-206)	
AA-027	13-14	Omitted Existing Emission Source	20,000 BPH Transfer Belt (BC-205)	
AA-028	13-15	Omitted Existing Emission Source	20,000 BPH Transfer Belt (BC-210)	
AA-029	14-14	Omitted Existing Emission Source	40,000 BPH Transfer Belt (BC-322)	
AA-030	14-15	Omitted Existing Emission Source	40,000 BPH Transfer Belt (BC-330)	
AA-031	15-14	Omitted Existing Emission Source	5,000 BPH Loadout Drag (DC-212)	
AA-032	21-13	Proposed Emission Source	20,000 CFM Receiving Dust Control System	
AA-033	22-13	Proposed Emission Source	20,000 BPH Receiving Drag (DC-111)	
AA-034	23-14	Proposed Emission Source	60,000 BPH Receiving Drag (BC-700)	

EMISSION SUMMARY

Table 2. Facility-Wide Comparison of Uncontrolled and Proposed Allowable Emissions (tpy)	
Pollutant	2020 SMOP Reissuance
Uncontrolled Emissions	2020 SMOP Reissuance
Proposed Allowable Emissions	2021 SMOP Modification Uncontrolled Emissions	2021 SMOP Modification
Proposed Allowable Emissions	Change in Proposed Allowable Emissions	Proposed Allowable < Major Source Threshold (100 tpy)?	
PM	356	249.01	517	249.01	+ 28.0	Yes2	
PM10	142	99.01	231	99.01	+ 15.6	Yes	
PM2.5	25.9	10.4	41.2	13.0	+ 2.60	Yes	
SO2	0.00	0.00	0.16	0.16	+ 0.16	Yes	
NOx	27.2	27.2	27.2	27.2	0.00	Yes	
CO	22.9	22.9	22.9	22.9	0.00	Yes	
VOC	1.50	1.50	1.50	1.50	0.00	Yes	
Individual HAP	< 10.0	< 10.0	< 10.0	< 10.0	0.00	Yes3	
Total HAPs	< 25.0	< 25.0	< 25.0	< 25.0	0.00	Yes3	
1.	The facility will limit grain throughput to 684,000 tons per year which will lower the proposed allowable emissions from the uncontrolled emissions. The facility will limit PM emissions below the Prevention of Significant Deterioration (PSD) major source threshold and PM10 below the Title V major source threshold.
2.	The Title V program does not regulate PM emissions; however, the PSD program has a major source threshold of 250 tons per year.
3.	The major source thresholds for Individual and Total HAP emissions are 10 and 25 tpy, respectively.	

Louis Dreyfus has the potential to exceed the Title V major source threshold of 100 tons per year (tpy) for PM10 and PM2.5 emissions and the PSD major source threshold of 250 tpy for PM, as seen in Table 2. The proposed facility-wide grain throughput limit of 684,000 tons per year, will reduce the proposed allowable emission for PM, PM10, and PM2.5. Also, the facility will limit PM and PM10 emissions to below the major source thresholds and compliance will be demonstrated through monitoring and recordkeeping. The facility is an area source for Hazardous Air Pollutant (HAP) emissions because the facility’s potential HAP emissions are less than the major source thresholds for individual HAP emissions (10 tpy) and total HAP emissions (25 tpy).
APPLICABLE/PROPOSED PERMIT LIMITATIONS
The following conditions will be incorporated in the permit to ensure that Louis Dreyfus remains below the PSD and Title V major source thresholds:
•	For the entire facility, the permittee shall limit total facility-wide maximum throughputs to no more than 684,000 tons grain per year (tpy) as determined for each consecutive 12-month period on a rolling basis.
o	The permittee shall maintain sufficient records to document monthly grain throughput in tons per month and a rolling 12-month total. Records should indicate total amount of grain received and loaded-out along with a breakdown by receiving and load-out locations.
•	For the entire facility, the permittee shall limit PM emissions to no more than 249.0 tpy and PM10 emissions to no more than 99.0 tons per year, as determined for each consecutive 12-month period on a rolling basis.
o	Compliance shall be demonstrated via performance testing, visual observations, control device maintenance, and recordkeeping.

STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES (NSPS) APPLICABILITY
Standards of Performance for Grain Elevators (40 CFR 60, Subpart DD)
The Standards of Performance for Grain Elevators (40 CFR 60, Subpart DD) applies to any grain terminal elevator which commences construction, modification, or reconstruction after August 3, 1978. Louis Dreyfus is defined as a grain terminal elevator and was constructed after August 3, 1978; therefore, the facility is subject to Subpart DD. The dust collectors (Emission Points AA-001, AA-002, and AA-032) are subject to the particulate matter and opacity standards. The column dryer (Emission Point AA-003) is subject to the particulate matter and opacity standards. The barge loading station (Emission Points AA-004 and AA-017) is subject to opacity standards. The grain handling area (Emission Points AA-005 through AA-016, AA-020 through AA-034) is subject to opacity standards. The truck loading station (Emission Point AA-018) is subject to opacity standards. The truck unloading station (Emission Point AA-019) is subject to opacity standards.

NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)/MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) APPLICABILITY
None applicable.

PUBLIC PARTICIPATION

The 30-day public notice period began on July 15 2021, with the publication of a notice in The Clarion Ledger.

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.