PERMIT REVIEW SUMMARY

Permit Writer:	Scott Hodges 			Date:	April 18, 2017

Company Name:	Hood Industries Inc, Wiggins

Facility Location:	1945 South First Street
Wiggins, MS 39577

Source Number:	2540-00003

County: 		Stone

PROJECT DESCRIPTION

Hood Industires, Inc.(Hood), 1945 South First Street, Wiggins, MS, 39577, (601) 928- 7241, has submitted a modification request for the Permit to Construct a third veneer dryer at their plywood production plant in Wiggins. The permit was originally issued on August 16, 2000.  The plant is located at the UTM coordinates 297 km East and 3,412 km North, Zone 16.
Under the Prevention of Significant Deterioration (PSD) regulation, 40 CFR 52.21, the existing facility has the potential-to-emit 250 tons per year or more of CO, PM, PM to, and VOC emissions. As such, the facility is further restricted to the PSD significant emission increase rates.
Hood Industries, Inc. produces plywood and by-products from southern yellow pine logs. The primary air emission sources currently operating at the plant consist of the following:
Emission Point	Description		
AA-001	Perry Smith. 81.8 MMBTU/HR, woodwaste boiler with Barron MuIticlone Collector	
AA-002	Perry Smith. 81.8 MMBTU/HR. woodwaste boiler with Barron Multiclone Collector	
AA-003	Erie City, 90 MMBTU/HR, woodwaste boiler with Zurn Multiclone Collector	
AA-004	23 Section Veneer Dryer (Ref. No. AA005) with a 15 MMBTU/HR, direct, natural gas-fired, burner in Zone #1 (Ref. No. AA005)	
AA-005	Kimwood Wide Belt, 4-head Plywood Sander with a Fisher Klosterman, XQ-120-27-4 Quad-Pak cyclone (four cyclones in parallel) (Ref. No. AA024A)	
AA-006	Fisher Klosterman, XQ-120-10, high pressure relay cyclone located at the wood/bark fired boilers (Ref. No. AA024B)	
AA-007	17 Section Veneer Dryer (Ref. No. AA004)	
AA-008	Dry Veneer Waste Cyclone (Ref. No. AA006)	
AA-009	Dry Veneer Waste Cyclone (Ref. No AA009)	
AA-010	Log Yard Fines Cyclone (Ref. No. AA010)	
AA-011	Log Yard Surge Bin (Ref. No. AA012)	
AA-012	Veneer Surge Bin (Ref. No. AA013)	
AA-013	Core/Log Yard Chip Loading (Ref. No. AA015)	
AA-014	Veneer Chip Loading (Ref. No. AA016)	
AA-015	Core/Log Yard Chip Discharge (Ref. No. AA017)	
AA-0l6	Veneer Chip Discharge (Ref. No. AA018)	
AA-017	Layup and Pressing (Ref. No. AA019)	
AA-018	54 Diverter Exhaust (Ref. No. AA020)	
AA-019	Fugitive Dust Point (Ref. No. AA021)	
AA-025	Regenerative Thermal Oxidizer (RIO). Controls emissions of the exhaust gases from the three drying zones of the 23-section. Coe veneer dryer, steam-heated (AA-026).	

 Project Description
As approved in August 16, 2000 Issuance
Hood proposes to install a new 23-section, steam-heated veneer dryer with three drying zones and three cooling zones, Model M-72, by Coe Manufacturing, in a building expansion on the south side of the existing plywood plant building. Emissions from the three drying zones of this dryer will be controlled by a regenerative thermal oxidizer (RTO) to be installed at the time of the new 23-section, steam-heated veneer dryer. The emissions from the cooling zones will be uncontrolled. The new 23-section, steam-heated veneer dryer will be operated simultaneously with the RTO.
In addition to the installation of the new 23-section, steam-heated veneer dryer and the RTO, Hood proposes to remove the gas burner from the existing 23-section veneer dryer and to reinstall the steam coils in that zone. Hood also proposes to limit the permitted plywood production capacity of the plant to no more than 274 MMsf (3/8" basis) of plywood produced per year. Hood will dry no more than 191 MMsf/yr (3/8" basis) in the two existing veneer dryers.
Hood proposes to extend the three drying zone stacks on the existing 23-section veneer dryer and the 17-section veneer dryer from their present heights of 44 feet to a height of 65 feet above ground level. Hood also proposes to replace the current roof vents over the plywood presses with stacks with an elevation of 65 feet above ground level.
Hood proposes to lower the allowable emission rates for PM and PM-10 at the quad-pak cyclone and the high pressure relay cyclone.
The expected total emission increases due to the proposed additions and changes for the plant are as follows:
Pollutant

	Emission Increase
with BACT
(TPY)	PSD Significant Emission
Rate
(TPY)	
CO	1119.5	100	
PM	137.4	25	
PM10	109.7	15	
VOC	62.6	40	

November 4, 2011 Modification application 
Hood Industries Inc, Wiggins, 1945 South First Street, Wiggins, Mississippi 39577, (601) 928-7241, has submitted a complete air permit application on November 4, 2011, for a modification to the Prevention of Significant Deterioration Construction Permit issued on August 16, 2000.   In the issued construction permit, VOC limits (lb/hr and tons/yr) were placed on Emission Point AA-026, the exhaust gases from the cooling zone of the veneer dryer.  However, it has been determined that although these VOC limits were mentioned in the March 31, 2000 application, they were not intended to be part of the BACT determination limits, as the BACT was only for installation of controls on the heated zones of the veneer dryer.  Therefore, the facility has requested that these VOC limits placed on the cooling zones of the dryers be removed.  No operational or design changes are being made at the facility due to this request. 
Also as part of this application, the applicant has requested that the VOC BACT limits established on the RTO, which controls emissions from the heated zones of the veneer dryer, be revised from mass based limits (i.e. lb/hr, ton/yr) to a minimum 90% DRE limit.  This will make the limits and subsequent compliance demonstration consistent with requirements of 40 CFR Part 63 Subpart DDDD.  Since the existing mass limits were established based on a 90% DRE, this change will not cause an increase in emissions.  No operational or design changes are being made at the facility due to this request.
   
November 11, 2011 Modification request
Additionally, in a separate submittal, dated November 11, 2011, the applicant requested revision to PM and PM10 emission limits for the Sander Dust Quad-Pak Cyclone, AA-005, and the High Pressure Relay Cyclone, AA-006.  In the PSD construction permit issued on August 16, 2000, PM and PM10 emission limits were set at a level which appeared to be necessary at the beginning of modeling during the PSD permitting process.  However, it was determined that these lower emission rates were not necessary to meet modeling for off-site effects. However, subsequent drafts and the final version of the permit did not revise these limits back to their original modeled levels.  Therefore, these emission rates are being revised to meet those consistent with the modeling done in the previous PSD construction permit process.  In determining whether this change would exceed the PSD significance threshold, the applicant conducted a netting analysis.  This analysis shows that PSD significance thresholds were not exceeded.    
Although this request is submitted in close proximity to the November 4, 2011 request, these projects do not appear to be related which would be a concern for aggregating projects.  Since there is no operational or design changes being made at the facility due to this request, new pollutants are not incorporated into the review.

PUBLIC PARTICIPATION

The 30-day public notice period began on May 3, 2017, with the publication of a notice in the Hattiesburg American and ends June 2, 2017.

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.