Title: Tempo Field
Author: Bruce Ferguson
Last saved by: Amira Feaster
Company: Office of Pollution Control

Information Relative to the Title V Permit
Page  of

INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
March 13, 2023

GENERAL FACILITY INFORMATION
Facility Name:  Trulite Glass and Aluminum Solutions LLC
Facility Address:  
501 Govan Street East
Grenada, MS 38901    
County: Grenada
SIC Code(s): 3231
NAICS Code(s): 327215  

APPLICATION SUMMARY 

Permit No.: 0960-00001
Permit Action: Renewal that does not include any modifications. 
Permit Folder: PER20230001
Application Receipt Date: July 31^st , 2023 
Application Deemed Complete: August 2^nd , 2023
CBI Submitted?: No

NSPS (Part 60): N/A
NESHAP (Part 61): N/A
NESHAP (Part 63): N/A
112(r) / RMP: N/A
Other: N/A

FACILITY DESCRIPTION
Trulite Glass and Aluminum Solutions (“Trulite”) manufactures mirrors and laminated glass products. The facility operations fall within SIC Code 3231 (Glass Products, Made of Purchased Glass)

The facility receives panes of glass and applies a silver solution to create a metallic layer on the glass. A layer of copper is applied on top of the silver layer for protection. Then, the glass is preheated and mirror paint is applied on the back of the mirror with a Curtain Coater (Emission Point AA-003). The mirror goes through the Flash-Off Oven (Emission Point AA-001) where most of the solvent in the mirror backing paint dries. Then, the mirror goes through the Infrared Bake Oven (Emission Point AA-002) where the mirror paint cures. The facility applies the trademark by ink jet printers (Emission Point AA-005) before removing silver and copper residue from the front side of the mirror. 

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 (VOCs). The facility does not have the potential-to-emit more than 25 tpy of total hazardous air pollutants (HAPs) or more than 10 tpy of any individual HAP.  Therefore, the facility is classified as an area source with respect to HAP emissions. 
Facility-Wide Potential-to-Emit Summary^1

Pollutant

PTE Emissions
(tons/yr)

Particulate Matter (TSP) | 0.00
PM_10 | 0.48
PM_2.5 | 0.00
Sulfur Dioxide (SO_2) | 0.04
Nitrogen Oxides (NO_x) | 6.07
Carbon Monoxide (CO) | 3.20
Volatile Organic Compounds (VOC) | 240.0
Total Reduced Sulfur (TRS) | 0.00
Lead | 0.00
CFC/HCFC |
Total HAP | 6.04
^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 (1) one of the twenty-eight (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 tpy of VOCs; However, through operational restrictions, the facility will limit the emission of VOCs below the PSD threshold; therefore, the facility is considered a moderate stationary source. This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
Trulite applied for a renewal of the Title V Operating Permit (TVOP). The facility has removed the 850-gallon solvent storage tank (Emission Point AA-006) from operation. There are no other proposed changes as part of this permitting action.

COMPLIANCE ASSURANCE MONITORING (CAM) APPLICABILITY
There is no control equipment associated with any emission units subject to an emission limit or standard at this facility, so 40 CFR 64, Compliance Assurance Monitoring, does not apply.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
The facility is an area source of hazardous air pollutants (HAPs) since the facility does not have the potential-to-emit more than 25 tpy of total HAPs or 10 tpy of any individual HAP. The facility denoted no equipment or operations subject to any standards of 40 CFR Part 63.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
The facility does not have any equipment or operations subject to any new source performance standards of 40 CFR Part 60.
SPECIFIC APPLICABLE REQUIREMENTS
The facility’s small hot water heaters and space heaters qualify as insignificant activities. These activities are subject to the state standards for PM, SO_2, and Opacity. Since these units combust natural gas and their size is small, no monitoring is proposed for them. There are no other applicable requirements for the facility’s other insignificant activities listed in their Title V application.  Specific facility requirements are shown below.

Emission Point No. | Pollutant | Draft Permit Emission Limits | Monitoring Requirements
AA-000 (Facility – Wide) | VOCs | 240.0 tpy | Monitoring, recordkeeping, and reporting of usage of all VOC-containing materials

919 PER20230001