PERMIT REVIEW SUMMARY
Permit Writer:	Ryan Ozment	 		Date:	October 28, 2022
Company Name:	AITX Railcar Services LLC, Brookhaven Facility
Facility Location:	113 Boyce Drive
Source Number:	1620-00054
County: 		Lincoln
FACILITY DESCRIPTION
AITX Railcar Services in Brookhaven currently carries out inspections, cleaning, and light repair of railroad tank and covered hopper cars.  These activities were established in the Permit to Construct issued April 22, 2014, and included the following emission sources:  open air assisted flare controlling car depressurization and steam purge, railcar steam cleaning, natural gas-fired boiler, welding operations, space heaters, and a diesel storage tank.  
PROJECT/PERMIT ACTION DESCRIPTION
AITX is proposing to expand operations at a second building across the street.  This building will house railcar sandblasting, lining, painting, and repair operations.  Emission sources for this expansion include the following activities:  exterior blasting, interior blasting, interior lining painting, exterior painting, and hopper car painting.  The previous permit included facility wide emission limits on volatile organic compounds (VOC), individual hazardous air pollutants (HAP), and total HAP of six tons per year, 0.2 tons per year, and three tons per year, respectively.  To accommodate the new emissions sources, these limits need to modified.  The facility is not considered a 28 listed source categories, and the PTE is below the PSD threshold of 250 tons per year; however, the new sources will increase the potential-to-emit (PTE) of VOC above the Title V threshold and the HAP emissions to major source threshold.  The modified permit will include Synthetic Minor limits to maintain the emissions below these thresholds.
EMISSION SUMMARY
Pollutant	PTE (tons/year)	
Particulate Matter (PM)	4.43	
Sulfur Dioxide (SO2)	0.02	
Nitrogen Oxides (NOX)	3.43	
Carbon Monoxide (CO)	3.42	
VOC	99.01	
Individual HAP	9.01	
Total HAP	24.01	
1Emission limits incorporated into the permit.
APPLICABLE/PROPOSED PERMIT LIMITATIONS
Facility Wide Requirements
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10):
o	≤ 99.0 tons per year of VOC
o	≤ 24.0 tons per year of total HAP
o	≤ 9.0 tons per year of individual HAP
o	Operate equipment in a way to minimize pollutants
o	Paint stripping with methylene chloride prohibited
o	Coatings containing chromium, lead, manganese, nickel and/or cadmium prohibited
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11):
o	Monitor, record, and report facility wide VOC and HAP emissions
o	Monitor and record fuel combustion
o	Monitor, record, and report identification, characteristics, and quantity used of all VOC and/or HAP containing material.
o	Report permit deviations within five working days.
o	Submit certified annual monitoring report.
o	Submit certified statement with annual monitoring report stating paint stripping with methylene chloride and spray application of coatings containing prohibited HAPs were not performed.
•	11 Miss. Admin. Code Pt. 2, R. 1.3. A & B:  ≤ 40% opacity 
•	11 Miss. Admin. Code Pt. 2, R. 2.9: Maintain records for five years.
Car Depressurization and Steam Purge equipped with Open Air Assisted Flare (Emission Point AA-001)
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10):  
o	Route emissions to flare for control
o	Operate flare at all times emissions may be vented to it
o	Operate and maintain flare according to manufacturer’s recommendations
o	Operate flare with no visible emissions as determined by Method 22
o	Maintain a flare pilot flame at all times when emissions may be vented to the flare
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11): 
o	Monitor, record, and report presence of flare pilot flame through thermocouple
o	Monitor, record, and report monthly Method 22 testing
200 hp natural gas-fired boiler and 0.4 MMBTU/hr natural gas-fired space heaters (Emission Points AA-003 and AA-005)
•	11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(a): ≤ 0.6 pounds of PM per MMBTU
0.4 MMBTU/hr natural gas-fired space heaters (Emission Point AA-005)
•	11 Miss. Admin. Code Pt. 2, R. 1.4.A(1): ≤ 4.8 pounds of SO2 per MMBTU
NSPS APPLICABILITY
40 CFR 60, Subpart Db (Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units)—this subpart applies to facilities with steam generating units constructed after June 1984 with a capacity greater than 100 MMBTU per hour.  The existing boiler (Emission Point AA-003) is 6.695 MMBTU per hour; therefore, this subpart does not apply.
40 CFR 60, Subpart Dc (Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units)—this subpart applies to facilities with steam generating units constructed after June 1989 with a capacity between 10 and 100 MMBTU per hour.  The existing boiler (Emission Point AA-003) is 6.695 MMBTU per hour; therefore, this subpart does not apply.
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 or process heaters at a major source of HAP.  This facility has taken limits to maintain area source status; 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 located at area sources of HAP; however, there is an exception for gas-fired boilers (40 CFR 63.11195(e)).  Because of this exception, this subpart does not apply.
40 CFR 63, Subpart XXXXXX (National Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories)—this subpart applies to area sources that primary engage in one of the following: electrical and electronic equipment finishing operations; fabricated metal products; fabricated metal products; fabricated plate work (boiler shops); fabricated structural metal manufacturing; heating equipment, except electric; industrial machinery and equipment finishing operations; iron and steel forging; primary metal products manufacturing; and valves and pipe fittings.  This facility primarily engages in activities under NAICS Code 488210: Support Activities for Rail Transportation.  This source category is not covered under this subpart; therefore, this subpart does not apply.
40 CFR 63, Subpart MMMM (National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products)—this subpart applies to major sources of HAP engaging in surface coating of metal parts and products including the following: motor vehicle parts and accessories, bicycles and sporting goods, recreational vehicles, extruded aluminum structural components, railroad cars, heavy duty trucks, medical equipment, lawn and garden equipment, electronic equipment, magnet wire, steel drums, industrial machinery, metal pipes, and numerous other industrial, household, and consumer products.  This facility has taken limits to maintain area source status; therefore, this subpart does not apply. 
40 CFR 63, Subpart HHHHHH (National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources)—this subpart applies to area sources that perform paint stripping using methylene chloride, spray apply coatings to mobile equipment, and/or spray apply coatings to a plastic and/or metal substrate on a part or product.  The facility does engage in coating mobile equipment; however, coatings used at the site do not contain the target HAPs of the subpart.  Because of this, the construction permit includes a federally enforceable limit to prohibit (1) paint stripping operations using methylene chloride and (2) spray application of coatings containing the target HAPs (chromium, lead, manganese, nickel, and/or cadmium).  This limit along with recordkeeping and an annual certification statement will ensure the facility will not be subject to the requirements of this subpart. 
PUBLIC PARTICIPATION
The 30-day public notice period began on January 26, 2022, with the publication of a notice in the Enterprise Journal and ends February 27, 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.