INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
March 20, 2023

GENERAL FACILITY INFORMATION

Facility Name:  Water Way Inc
Facility Address:  
751 County Road 989, Building 1010
Iuka, MS 38852    
County: Tishomingo
SIC Code(s): 3088
NAICS Code(s): 326191  

APPLICATION SUMMARY

Permit No.: 2640-00044
Permit Action:  Renewal with no changes
Permit Folder: PER20220001
Application Receipt Date: October 2, 2022
Application Deemed Complete: 01/09/2023
CBI Submitted?: No	NSPS (Part 60): N/A
NESHAP (Part 61): N/A
NESHAP (Part 63): WWWW
112(r) / RMP: N/A
Other: N/A	

FACILITY DESCRIPTION

Water Way, Inc is a fiberglass reinforced plastic (FRP) motor home parts manufacturing facility applying for the reissuance of their Title V Operating permit. The facility produces fiberglass parts using resin open mold technology and gel coat in the open mold spray lay-up process.  Styrene monomer is one of the main components of the resin and gel coat used in the process which results in volatile organic compounds (VOC) and hazardous air pollutant (HAP) emissions during resin open mold activities, gel coat spray lay-up activities, and gel coat tooling activities (repair and rework). Styrene is considered both a HAP and a VOC. Acetone is the solvent used for equipment cleanup (a non-VOC/non-HAP solvent). Furthermore, there are some sanding and sawing activities taking place at the facility; however, the emissions generated from these activities are not exhausted to the outside atmosphere, but to the building interior. The sanding operation is limited to occasional sanding of flaws in the parts; whereas, sawing is to cut off the excess material from the perimeter of the parts using a circular saw. The following table contains the emission points at the facility. 
Emission Point	Description	
AA-001	Gel Coat Application: Open Mold Spray Lay-up Operation – Four pumps feeding one gel coat gun. Each pump serves a different color with gun head swapping from one feed line to another to change color. Exhaust Filter Control System (i.e. Material spraying is performed in an area of the facility that has a filtered exhaust so any overspray that does not fall to the floor is being captured by the exhaust filters).	
AA-002	Resin Application Operation – Three resin/chopper spraying guns located at one set of exhaust fans. Exhaust Filter Control.	
AA-003	Resin Application Operation: Open Mold Spray Lay-up Operation. Exhaust Filter Control.	
AA-004	3.456 MMBTU/hr Natural Gas Fired Heater (insignificant – comfort heat)	
AA-005	Gel Coat Application: Repair and Rework Operation (Tooling) – Blemishes and defects are repaired then the product is prepared for shipping.	
AA-006	Sanding and Sawing Operation – Small Parts and Large Parts areas -Dust Collector located in Large Parts Sanding and Sawing area which exhausts to building interior.	
AA-007	Resin Application Operation for Mold Production Operation (separate building)	
AA-008	Miscellaneous Material Usage (Facility-wide)	
AA-009	10,000 Gallon Resin Storage Tank (Horizontal fixed roof)	

TITLE V SOURCE APPLICABILITY
 
The facility’s potential-to-emit (PTE) exceeds the Title V major source threshold of 100 tons per year (tpy) for each of the following criteria air pollutants: Volatile Organic Compounds (VOC).  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 HAPs – Styrene.

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions
(tons/yr)	
Particulate Matter (TSP)	23.1	
PM10	23.1	
PM2.5	23.1	
Sulfur Dioxide (SO2)	0.009	
Nitrogen Oxides (NOx)	1.48	
Carbon Monoxide (CO)	1.25	
Volatile Organic Compounds (VOC)	368.14	
Total Reduced Sulfur (TRS)	--	
Lead	--	
CFC/HCFC	--	
Total HAP 	307.22	
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 more than 250 tons per year of VOC; therefore, the facility is considered a major stationary source.  This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES

This permit action is for reissuance of the Title V permit.  No modification was requested, and no changes are being made.

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 the facility. Furthermore, the facility is subject to a promulgated MACT standard which establishes requirements to demonstrate compliance with an organic HAP emission limit and meet work practice standards. Emission limitations established in this MACT are exempt from CAM monitoring.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

40 CFR 63, Subpart WWWW – National Emission Standards for Hazardous Air Pollutants from Reinforced Plastics Composites Production – The Title V permit contains all applicable emission limits, notification requirements, work practice standards, and site-specific monitoring, recordkeeping, and reporting requirements. 

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR 60, Subpart Kb – Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for which Construction, Reconstruction, or Modification Commenced after July 23, 1984 – Emission Point AA-009 is not subject to this subpart due to the capacity of the storage tank.

SPECIFIC APPLICABLE REQUIREMENTS

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
Facility Wide	PM (filterable only)	E = 4.1p0.67	No monitoring needed because of large margin of compliance.	
AA-001 AA-003	Organic HAP	Open molding gel coat: 

(1) White/off white pigmented
Emission limit:  ≤ 267 lb. HAP/ton gel             coat applied
(2) All other pigmented
Emission limit:  ≤ 377 lb. HAP/ton gel coat applied	Monitor and collect data to demonstrate continuous compliance by:

1.	Collect and keep records of resin and gel coat used, organic HAP content, and operation where the resin is used

2.	Retain the records of resin and gel coat organic HAP content, and shall include the list of these resins and gel coats and identify their application methods in the semiannual compliance reports

3.	Maintaining an organic HAP emissions factor value less than or equal to the limit as stated in Condition 3.B.5 on a 12-month rolling average, and/or by including in each compliance report a statement that all resins and gel coats meet the organic HAP emissions limits stated in Condition 3.B.5

4.	Performing the required work practice

(40 CFR 63 Subpart WWWW)
	
AA-002  AA-007		Open molding mechanical resin application: 

(1) Non-CR/HS
Emission limit:  ≤ 88 lb. HAP/ton resin applied		
AA-005		Open molding gel coat: 

(1) Tooling
Emission limit:  ≤ 440 lb. HAP/ton gel coat applied 		
AA-007		Open molding mechanical resin application: 

(1) Tooling
Emission limit:  ≤ 254 lb. HAP/ton resin applied
Open molding manual resin application:

(1) Tooling
Emission limit:  ≤ 157 lb. HAP/ton resin applied		
AA-001 AA-002 AA-003		Maintain exhaust filters at all times when operating or emissions may be vented.	Perform regular inspections and maintenance as needed each week or more often if necessary to maintain proper operation of all filters