INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
September 18, 2023

GENERAL FACILITY INFORMATION

Facility Name:  Avon Engineered Fabrications Inc
Facility Address:  
113 Street A
Picayune, MS 39466    
County: Pearl River
SIC Code(s): 3069
NAICS Code(s): 326299  

APPLICATION SUMMARY 

Permit No.: 2180-00036
Permit Action:  Renewal 
Permit Folder: PER20210001
Application Receipt Date: April 13, 2021
Application Deemed Complete: March 14, 2022
CBI Submitted?:  No	NSPS (Part 60): n/a
NESHAP (Part 61): n/a
NESHAP (Part 63): DDDDD
112(r) / RMP: n/a
Other: n/a	

FACILITY DESCRIPTION

Avon Engineering Fabrications Inc. is a manufacturer of rubber skirts for Air Cushioned Vehicles (ACVs), flexible plastic and rubber storage tanks, and Lift Bags.  Avon manufactures three distinct products.  Air Cushioned Vehicle Skirts, Flexible Tank Manufacturing, and Lift Bag Manufacturing.  
•	Emission Point -AA-000 -  ACV skit fabrication begins with rubber sheet goods that are received on spooled rolls.  The rubber sheets are cut into various shapes and glued together.  A toluene based adhesive is used at a mix rate of 5.387 lbs toluene/gallon of adhesive.  
•	Emission Point AB-000 - Flexible tanks are used for temporary storage of fuel and/or water.  Fabrication of the flexible tanks begin with large sheets of flexible reinforced polyurethane or rubber material.  Emissions are fugitive in nature and exhaust from the building through roof ventilators.  Methyl Ethyl Ketone (MEK) is used in tank manufacturing as a solvent wipe to promote adhesion and cleaning.  
•	Emission Point AC-000 - Lift bags are used by Military groups to raise aircraft for maintenance.  The fabrication begins with rolls of rubber coated drop stitch sheet goods and rolls of sidewall material which is also rubber sheet goods.  Emissions from the Lift Bag manufacturing is toluene.
•	Steam for two large presses is provided by a 2.94 MMBTU/hr boiler (Emission Point AD-001).    

TITLE V SOURCE APPLICABILITY 

The facility’s potential-to-emit hazardous air pollutants (HAPs) exceeds the Title V major source thresholds of 25 tpy of total HAPs and 10 tpy for the following individual HAP – Toluene 

Facility-Wide Potential-to-Emit Summary1

Pollutant	PTE Emissions
(tons/yr)	
Particulate Matter (TSP)	0.096	
PM10	0.09	
PM2.5	0.09	
Sulfur Dioxide (SO2)	0.01	
Nitrogen Oxides (NOx)	1.25	
Carbon Monoxide (CO)	1.05	
Volatile Organic Compounds (VOC)	11.97	
Total Reduced Sulfur (TRS)	--	
Lead	--	
CFC/HCFC	--	
Individual HAP(Toluene)	11.79	
Total HAP 	14.56	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY

The facility is not one of the 28 categorical facilities listed in 40 CFR 52.21(b)(1)(i)(a); therefore, the PSD threshold for a major source is 250 tpy.  The facility has the potential to emit less than 250 tpy of each of the regulated NSR pollutants; therefore, it is an existing minor source under the PSD program.  This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES

A small natural gas-fired boiler is subject to MACT Subpart DDDDD so the applicable language has been added to the permit.

COMPLIANCE ASSURANCE MONITORING (CAM) APPLICABILITY

40 CFR Part 64 specifies the requirements for CAM.  The general applicability of this rule can be found in 40 CFR 64.2 and requires a Title V source to comply with the CAM requirements if all three of the following criteria are met for a pollutant-specific emission unit (PSEU):

1.	The unit is subject to an emission limitation or standard for a regulated air pollutant other than exemptions under 40 CFR 64.2(b)(1);
2.	The unit uses a control device to comply with the standard; and
3.	The unit has pre-control emissions exceeding Title V major source threshold.

There is no control equipment associated with any emission units subject to an emission limit or standard at this facility, so Compliance Assurance Monitoring does not apply.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

Avon Engineered Fabrications Inc., is major stationary source for hazardous air pollutants; however, there are no promulgated or proposed MACT standards applicable to the facility’s operations at this time. Case-by-Case MACT does not apply because the facility has not constructed or reconstructed its operations since May 1998.

40 CFR 63, Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants for Major Sources:  Industrial, Commercial, and Institutional Boilers and Process Heaters.  Emission Point AD-000 (2.94 MMBTU/hr natural gas fired boiler) is subject to this subpart.  All applicable requirements have been added to the permit.  

40 CFR 63, Subpart PPPP – National Emission Standards for Hazardous Air Pollutants for Surface Coating of Plastic Parts and Products -- Plastic parts and products include, but are not limited to, plastic components of the following types of products as well as the products themselves: Motor vehicle parts and accessories for automobiles, trucks, recreational vehicles; sporting and recreational goods; toys; business machines; laboratory and medical equipment; and household and other consumer products.  Avon does not produce any of these parts; therefore, Avon is not subject to this subpart.  

40 CFR 63, Subpart XXXX -- National Emission Standards for Hazardous Air Pollutants for Rubber Tire Manufacturing -- Rubber tire manufacturing includes the production of rubber tires and/or the production of components integral to rubber tires, the production of tire cord, and the application of puncture sealant.  Avon does not manufacture rubber tires; therefore, Avon is not subject to this subpart.  

40 CFR 63, Subpart GG -- National Emission Standards for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities -- This subpart applies to facilities that are engaged, either in part or in whole, in the manufacture or rework of commercial, civil, or military aerospace vehicles or components.  Avon does not manufacture or rework aerospace vehicles; therefore, Avon is not subject to this subpart.  

40 CFR 63, Subpart II -- National Emission Standards for Hazardous Air Pollutants for Shipbuilding and Ship Repair (Surface Coating) -- The provisions of this subpart apply to shipbuilding and ship repair operations.  Avon does not build ships or repair ships; therefore, Avon is not subject to this subpart.  

40 CFR 63, Subpart VVVV -- National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing -- This subpart establishes national emission standards for hazardous air pollutants (HAP) for new and existing boat manufacturing facilities with resin and gel coat operations, carpet and fabric adhesive operations, or aluminum recreational boat surface coating operations.  Avon does not manufacture boats; therefore, Avon is not subject to this subpart.  

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR 60, Subpart Dc – Standards for Small Industrial-Commercial-Institutional Steam Generating Units – This subpart applies to steam generating unit for which construction, modification, or reconstruction is commenced after June 9, 1989 and that has a maximum design heat input capacity of 100 MMBtu/hr or less, but greater than or equal to 10 MMBtu/hr.  Due to the size of the boiler, Avon is not subject to this subpart.  

SPECIFIC APPLICABLE REQUIREMENTS

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-000  AB-000  AC-000	PM/PM10	E = 4.1p0.67	No monitoring necessary because of size of particulate matter.  	
	Toluene	31.24 tpy	Maintain records to document the number of ACV skirt, flexible tanks and lift bags produced on a monthly basis and any consecutive 12-month period.
Monitor and record information for each coating, adhesive, solvent, or other Volatile Organic Compound (VOC) or Hazardous Air Pollutant (HAP) containing material.	
AD-000	SO2	4.8 lb/MMBTU	No monitoring necessary because only burns natural gas	
	PM (filterable only)	0.6 lb/MMBTU		
	HAP	MACT Subpart DDDDD	Operate in such a manner to minimize emissions using good air pollution control practices.  (Ref.:  40 CFR 63.7500(a)(3), Subpart DDDDD)

Conduct a Tune-up every 5 years.  (Ref.  40 CFR 63.7500(a)(1) and Table 3, Item 1, and 63.7540(a)(10)(i)-(vi), Subpart DDDDD)

Be in compliance with the work practice standards at all times when unit is operating.   (Ref.:  40 CFR 63.7505(a), Subpart DDDDD)