PERMIT REVIEW SUMMARY

Permit Writer:	Clinton Gentry				 	Date:	April 26, 2022

Company Name:	Baxter Healthcare Corporation

Facility Location:	911 North Davis Avenue
			Cleveland, MS (38732)

			33°45’51.76” N
			90°42’51.76” W

Source Number:	0240-00052

County: 		Bolivar

FACILITY DESCRIPTION

The Baxter Healthcare Medication Delivery Facility (Baxter) is a pharmaceutical and medical devices manufacturing facility located in Cleveland, MS. The principal products produced are intravenous and irrigating solutions, specialty medical devices, medical trays, and IV sets. The principal processes used in manufacturing these products include injection molding, blow/stretch molding, tubing extrusion, solution filling of glass and plastic containers, product packaging, parts assembly, steam sterilization, and solvent bonding of parts. Support processes include production of water for injection through distillation, production of drinking water, maintenance activities, steam production, and wastewater treatment. 

PROJECT/PERMIT ACTION DESCRIPTION

Baxter has applied for a modification of their Synthetic Minor Operating Permit (SMOP) issued December 23, 2019 and set to expire on November 30, 2024. The facility is requesting the following modification actions:

1)	The facility was previously adjacent to a co-located non-owned facility that is covered under the current operating permit. This non-owned facility has since closed and all associated equipment/processes have been removed from the site. As such, Baxter is requesting that the fugitive VOC source (Emission Point AA-031) and emergency generator (AA-029) be removed from the permit. Emission Point AA-029 was subject to NSPS IIII and MACT ZZZZ. 
2)	Baxter is requesting the addition of a solvent welding operation (proposed Emission Point AA-034). This source will emit VOCs and HAPs but will not increase the facilities PTE above their associated Title V thresholds. 

SITE MAP

EMISSION SUMMARY

Criteria Pollutant	Maximum  Uncontrolled	Potential Controlled	Title V Threshold	
Carbon Monoxide (CO)	63.37	63.41	100	
Nitrogen Oxides (NOx)	128.041	99.90	100	
Sulfur Dioxide (SO2)	70.44	70.44	100	
Particulate Matter 10 (PM10)	12.81	12.81	100	
Volatile Organic Compounds (VOC)	15.67	15.64	100	
Total Hazardous Air Pollutants (HAP)	15.74	15.74	25	
*All emissions are reported in tons per year (tpy)

APPLICABLE/PROPOSED PERMIT LIMITATIONS

Baxter Healthcare’s Cleveland Facility has the potential to exceed the Title V threshold for Nitrogen Oxides (NOx). In order to qualify as Synthetic Minor Source, Baxter is requesting that federally enforceable limitations be taken on natural gas usage as well as their backup fuel, diesel. These requested limits are 1,500 MM ft3 per year of natural gas and 2,850,000 gallons per year of No. 2 Fuel Oil with a SO2 content no greater than 0.10 wt%. In order to demonstrate compliance, fuel usage records will be taken and provided to MDEQ. These records will ensure that Baxter limits their NOx emissions to no greater than 99.0 tons per year (tpy).

NSPS APPLICABILITY

40 CFR Part 60, Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units
Baxter has one 90.9 MMBtu/hr boiler, Emission Point AA-005, that was constructed after the applicability date in NSPS Subpart Dc.  This boiler will burn natural gas except during gas curtailments or gas supply interruptions, during which distillate fuel oil may be combusted.  Therefore, the boiler is subject to limited requirements in Subpart Dc, including keeping records of the amount of fuel burned and ensuring that any distillate fuel contains no more than 0.5 wt% sulfur.

40 CFR Part 60, Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
This subpart applies to manufacturers, owners, and operators of stationary compression ignition (CI) internal combustion engines (ICE). Emission Points AA-025, AA-027, and AA-030 are all < 10 Liter, Compression Ignition, 4-Stroke, > 50 HP, Emergency Generators constructed after July 11, 2005 and are therefore applicable to this subpart. Subpart IIII requires that these engines are certified to meet certain emissions standards, burn ultra-low sulfur diesel, and have non-resettable hour meters installed to track operation.

MACT APPLICABILITY
Baxter’s potential total HAP emissions are below 25 tpy and potential individual HAP emissions  are below 10 tpy; therefore, the facility is not subject to any standards applicable to major sources of HAP.

40 CFR Part 63, Subpart ZZZZ – National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE). 
This subpart applies to new and existing RICE at both major and minor (or area) sources of HAP emissions. Thus, the emergency generators and firewater pump engines are subject. The emergency generators, Emission Points AA-025, AA-027, and AA-030, which are considered new, must comply by meeting the requirements of NSPS Subpart IIII, and no other requirements of Subpart ZZZZ apply per §63.6590(c)(1). The other two generators, Emission Points AA-023 and AA-026, as well as two firewater pumps, Emission Points AA-011 and AA-012, are considered existing sources subject to the requirements of Subpart ZZZZ related to emergency engines.

40 CFR Part 63, Subpart JJJJJJ – National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources
This subpart applies to owners of industrial, commercial, or institutional boilers located at area sources. However, gas-fired boilers are not subject to the requirements of this subpart per §63.11195(e). Because all emission points may be capable of combusting distillate fuel oil as a backup fuel, a requirement restricting use of distillate fuel oil to periods of gas curtailment, gas supply interruption, startups, or periodic testing on liquid fuel is included in the permit to ensure the boiler meets the definition of “gas-fired boiler” found in §63.11237. However, the only fuel sources that will be allowed to use distillate fuel as a backup fuel source are Emission Points AA-004 and AA-005.

PUBLIC PARTICIPATION

The 30-day public notice period began on May 23, 2022, with the publication of a notice in the Bolivar Commercial and ends June 22, 2022.

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.