PERMIT REVIEW SUMMARY

Permit Writer:	Jeffrey Bland	 			Date:	August 17, 2019

Company Name:	Confortaire Inc

Facility Location:	2133 South Veterans Boulevard

Source Number:	1540-00071

County: 		Lee

FACILITY DESCRIPTION

Confortaire Inc. operates a foam fabricating facility that produces cushions primarily for the wood furniture manufacturing industry.  The facility consists of two primary processes: a gluing operation and a foam and fiber cutting operation.  The gluing operation consists of twelve (12) spray stations.  The foam and fiber cutting operation can process 2.75 tons per hour.  After the foam and fiber are cut to specific patterns using jigsaws and other mechanical cutting devices, the fiber is attached to the foam with a spray-on low VOC adhesive.  The facility also has three (8) 0.2 MMBTU/hr space heaters in the plant area, one (1) 0.06 MMBTU/hr space heater in the office and one (1) 0.14 MMBTU/hr space heater in the break room.  

PROJECT/PERMIT ACTION DESCRIPTION

The facility has applied for renewal of their synthetic minor operating permit (SMOP).  Modifications to the permit include the addition of the five 0.2 MMBTU/hr space heaters, one 0.14 MMBTU/hr space heater and one 0.06 MMBTU/hr space heater (Emission Point AA-005).

APPLICABLE/PROPOSED PERMIT LIMITATIONS

Confortaire Inc. has the capability to exceed the Title V threshold for Volatile Organic Compounds (VOC).  The facility has elected to take the following limits:

•	Individual HAP emissions shall not exceed 9.9 tons/year;
•	Total combined HAP emissions shall not exceed 24.9 tons/year; and
•	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 adhesive and adhesive usage, calculated on a monthly basis.  

Summary of Potential Emissions:

Pollutant	Without permit limits
(tpy)	With Permit Limits
 (tpy)	
PM/PM10/PM2.5	35.35		
SO2	<0.01		
NOx	0.73		
CO	0.31		
VOC	495.6	99.0	
Individual HAP		9.9	
Total HAP		24.9	

NSPS APPLICABILITY

No applicable New Source Performance Standards have been identified.  

MACT APPLICABILITY
National Emission Standards for Hazardous Air Pollutants: Flexible Polyurethane Foam Fabrication Operations - Subpart MMMMM
Facilities subject to the National Emission Standards for Hazardous Air Pollutants: Flexible Poly urethane Foam Fabrication Operations (40 CFR 63, Subpart MMMMM) utilize flame lamination or operates a loop slitter and are a major source for HAP emissions. The facility. is an area source for HAP emissions, as seen in the table above. Therefore, the facility is not subject to Subpart MMMMM.
National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production and Fabrication Area Sources – Subpart OOOOOO
The facility is a flexible polyurethane foam fabrication facility and will be an area source of HAP emissions.  Therefore, the facility will be subject to the National Emissions Standards for Hazardous Air Pollutants for Polyurethane Foam Production and Fabrication Area Sources (40 CFR 63, Subpart OOOOOO). The facility will maintain compliance by prohibiting the use of Methylene Chloride.  The facility will not use any adhesive containing methylene chloride, and Safety Data Sheets (SDS) and adhesive usage records will be used to demonstrate that the adhesive used in the foam fabrication process does not contain methylene chloride or any other HAPs.

OTHER REQUIREMENTS

The facility is subject to 11 Miss. Admin Code Pt. 2, R.1.3.A, which requires that all point source emissions register below 40% opacity.
The natural gas fired space heaters at the facility are subject to the following standards. 11 Miss. Admin. Code Pt. 2, R.1.3.D(1)(a) limits PM emissions from all fuel burning equipment with a rated capacity less than 10 MMBTU/hr to 0.6 lbs/MMBTU. 11 Miss. Admin. Code Pt. 2, R.1.4.A(1) restricts SO2 emissions from fuel burning equipment a to 4.8 lbs/MMBTU.  
Manufacturing processes are also subject to PM limitations as required by 11 Miss. Admin. Code Pt. 2, R.1.3.F(1).  The hourly limit of PM emissions is set by the Process Weight Equation.  

The facility is expected to have a large margin of compliance with all these state standards, so no monitoring is being recommended to show compliance with these standards.

PUBLIC PARTICIPATION

The 30-day public notice period began on , with the publication of a notice in the North East Daily Journal and ends .

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.