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

GENERAL FACILITY INFORMATION
Facility Name:  Kohler Company, Hattiesburg Engine Plant Number 2
Facility Address:  
95 W L Runnels Industrial Drive
Suite 200
Hattiesburg, MS 39401    
County: Forrest
SIC Code(s): 3519
NAICS Code(s): 333618  

APPLICATION SUMMARY 
Permit No.: 0800-00117
Permit Action: Significant Modification
Permit Folder: PER20230002
Application Receipt Date: 08/16/2023
Application Deemed Complete: 09/29/2023
CBI Submitted?: No	NSPS (Part 60): IIII
NESHAP (Part 61): N/A
NESHAP (Part 63): CCCCCC, ZZZZ
112(r) / RMP: N/A
Other: N/A	

FACILITY DESCRIPTION
Kohler Company, Hattiesburg Engine Plant Number 2 (“Kohler Plant 2”) is an internal combustion engine assembly and testing facility.  The engine parts are fabricated, machined, and finished at a sister facility (Kohler Hattiesburg Engine Plant; AI 1078) before being transported to Kohler Plant 2 for full assembly and testing.  The existing engine testing lines use gasoline, propane, or natural gas as fuel sources.  The facility also currently operates two residential generator assembly and testing lines, using natural gas as a fuel source. Kohler Plant 2 is proposing to construct a new residential generator assembly and testing line.

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 the following criteria air pollutant: Carbon Monoxide (CO).

The facility’s potential-to-emit hazardous air pollutants (HAPs) does not exceed the major source threshold of 25 tpy of total HAPs and 10 tpy for any individual HAP.

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions
(tons/yr)	
Particulate Matter (TSP)	1.57	
PM10	1.51	
PM2.5	1.50	
Sulfur Dioxide (SO2)	1.30	
Nitrogen Oxides (NOx)	71.44	
Carbon Monoxide (CO)	245.0	
Volatile Organic Compounds (VOC)	49.39	
Total Reduced Sulfur (TRS)	—	
Lead	0.36	
CFC/HCFC	—	
Total HAP 	5.27	
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 tpy of Carbon Monoxide (CO) but will continue to limit the facility-wide emission of CO to no more than 245.0 tpy; 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
Kohler Plant 2 is proposing to construct a new residential generator assembly and testing line. This line will consist of three (3) engine test stands, each capable of testing up to four (4) engines, with capacities up to 259 HP, per hour. Natural gas will be utilized as a fuel source. Emissions are uncontrolled. The line has been added to the permit as EL-7 Residential Generator Assembly and Testing (Emission Point AA-019). Additionally, Kohler Plant 2 has requested that Big Block Line No. 2 (Emission Point AA-015) be removed from the permit because construction was started but will not be completed for the emission source due to market changes.

Because Kohler Plant 2 is a moderate stationary source under PSD, the threshold for PSD construction permitting action is 250 tpy.  The project-related emissions do not exceed 250 tpy for CO or any other pollutants.  Furthermore, Kohler Plant 2 will continue to limit the facility-wide emissions of CO to no more than 245.0 tpy, thereby remaining a moderate stationary source under PSD.  Kohler Plant 2 will also continue to demonstrate compliance with the CO limitation by, on a monthly basis, monitoring and recording the volume of each fuel combusted and calculating rolling 12-month total CO emission rates in tpy.

The project-related emissions of CO do not exceed the de minimis threshold of ¾ of 250 tpy (187.5 tpy) and is therefore excluded from the requirement for a Permit to Construct (11 Miss. Admin. Code. Pt. 2, R. 2.13.F.).

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
Kohler Plant 2 is an area source of HAPs.  This project/modification will not change the facility’s HAPs source status or NESHAP applicability. 

40 CFR Part 63, Subpart CCCCCC – National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities: Kohler Plant 2 meets the definition of a “gasoline dispensing facility” (GDF) and is an area source of HAPs; therefore, the facility is subject to and shall comply with the applicable requirements found in Subpart CCCCCC.  The gasoline tanks (Emission Point AA-011) are affected sources under this Subpart.

40 CFR Part 63, Subpart PPPPP – National Emission Standards for Hazardous Air Pollutants for Engine Test Cells/Stands: Kohler Plant 2 operates engine test stands but is an area source, not a major source, of HAPs; therefore, Subpart PPPPP does not apply.

40 CFR Part 63 Subpart ZZZZ – National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE): Kohler Plant 2 operates stationary reciprocating internal combustion engines (Emission Points AA-008, AA-010, and AA-013) and is an area source of HAP emissions.  Therefore, Kohler Plant 2 is subject to and shall comply with the applicable requirements of Subpart ZZZZ.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
This project does not affect the facility’s current NSPS applicability. 

40 CFR Part 60, Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal Combustion Engines: Emission Point AA-010 is a compression-ignition (CI) internal combustion engine (ICE) that was manufactured after April 1, 2006.  Therefore, Kohler Plant 2 is subject to and shall comply with the applicable requirements of Subpart IIII. 

40 CFR Part 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: Kohler Plant 2 utilizes two (2) oil storage tanks (considered “insignificant activities”) and two (2) gasoline storage tanks (Emission Point AA-011).  While oil and gasoline are petroleum-based liquids, the storage tanks do not have a capacity greater than 75 cubic meters.  Therefore, Kohler Plant 2 is not subject to any requirements found in Subpart Kb.

SPECIFIC APPLICABLE REQUIREMENTS
The following table summarizes the emission limitations and corresponding monitoring requirements to which the new emission point, AA-019, is subject. These facility-wide limits and requirements have not changed from the previous Title V permit.

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-100
(facility-wide)	PM
(filterable	E = 4.1p0.67	There are no specific monitoring requirements for these limits.  The margin of compliance should be significant considering the facility will combust gasoline, propane, and natural gas.	
	CO	245.0 tpy
(12-month rolling total)	On a monthly basis, the facility will monitor and record the volume of each fuel combusted and calculate CO emission rates.