PERMIT REVIEW SUMMARY

Permit Writer:	Audra Sandifer 			Date:	April 27, 2016

Company Name:	Premier Foam Inc

Facility Location:	103 Industrial Drive
New Albany, MS

Source Number:	2700-00052

County: 		Union

PROJECT DESCRIPTION

Premier Foam, LLC is an existing foam fabrication facility which utilizes adhesive spray stations which are used to glue foam-to-foam and foam-to-fiber to form cushions for various furniture products.  Currently Premier Foam is a True Minor source that is increasing production.  The increase in production will cause the potential-to-emit to exceed the Title V threshold for Volatile Organic Compounds (VOC); therefore, Premier Foam is requesting a Synthetic Minor Operating Permit.  Facility operations fall under the SIC code 3086.  Premier Foam is subject to the Flexible Polyurethane Foam Fabrication Area Source MACT (40 CFR 63, Subpart OOOOOO).  To comply with this MACT, methylene chloride cannot be used in any operation.  

SYNTHETIC MINOR LIMITATIONS

Premier Foam has the capability to exceed the Title V threshold for Volatile Organic Compounds (VOC) and Hazardous Air Pollutants (HAP).  The facility has elected to take the following limits:
•	Individual HAP emissions shall not exceed 9.9 tons/years;
•	Total combined HAP emissions shall not exceed 24.9 tons/year;
•	Total VOC emissions shall not exceed 99.0 tons/year
VOC and HAP compliance demonstration will be determined through the tracking of the VOC and HAP content of the glues and glue usage, calculated on a monthly basis.

Summary of Potential Emissions (prior to permit limits):
Pollutant	lb/hr	tpy	
PM	12.05	52.77	
PM10	12.05	52.77	
PM2.5	12.05	52.77	
VOC	42.17	184.70	

PUBLIC PARTICIPATION

The 30-day public notice period began on June 1, 2016, with the publication of a notice in the New Albany Gazzette and ends July 1, 2016.

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.