PUBLIC NOTICE DRAFT SMOP REVIEW SUMMARY

Permit Writer:	Slater Smith	Date:	October 3, 2019
Company Name:	H M Richards Inc
Facility Location:	414 County Road 2790
Guntown, MS 38849
Source Number:	1540-00145
County: 		Lee

FACILITY DESCRIPTION & PERMITTING ACTION
H.M. Richards, Inc. operates as an upholstered furniture manufacturing facility including fiber and gluing under SIC: 2512 (Wood Household Furniture, Upholstered). The facility is an existing facility, having operated below the Title V (TV) major source threshold. The facility currently consists of seven emission points: Lumber, Oriented Strand Board (OSB), and Plywood Processing, Fiber Operations, Frame Gluing, Finger Joint Gluing and Cleaning, Main Facility Space Heaters, and Warehouse Space Heaters.
The Mill Shop contains the Lumber, OSB, and Plywood Processing (Emission Point AA-001) and Finger Joint Gluing and Cleaning (Emission Point AA-004) operations. Emission Point AA-001 produces particulate matter (PM) emissions which is controlled by a baghouse. Fiber Operations (Emission Point AA-002), Frame Gluing (Emission Point AA-003), and Cushing Repair Gluing (Emission Point AA-005) take place in the Main Facility. PM emissions produced by Emission Point AA-002 are controlled by a baghouse. The Main Facility uses 83 Natural Gas-fired Space Heaters (Emission Point AA-006) and 33 Natural Gas-fired Space Heaters are used by the Warehouse (Emission Point AA-007) for temperature control.
The facility requested a Permit to Construct Air Emissions Equipment to add two foam fabrication gluing processes.  The facility will use the Four Foam Fabrication Spray Booths (Emission Point AA-008) and a Foam Fabrication Spray Line Conveyor (Emission Point AA-009) to apply foam with adhesives. Emission Points AA-008 and AA-009 will generate VOC, PM, and hazardous air pollutant (HAP) emissions. The PM emissions produced by Emission Points AA-008 and AA-009 will be controlled by their own respective exhaust fan with a dry filter.
The proposed addition of the two gluing operations will increase the facilities potential emissions for PM, volatile organic compound (VOC), and total hazardous air pollutant (HAP) emissions. The increase in VOC emissions will cause the facility to exceed the TV major source thresholds. H.M. Richards, Inc. has submitted a Synthetic Minor Operating Permit (SMOP) application and SMOP limitations to keep the facility below the Title V major source thresholds. 

EMISSIONS SUMMARY
Table 1. H.M. Richards, Inc. Project Uncontrolled Emission and TV Major Source Threshold Comparison (tpy)	
Pollutant	Project Uncontrolled Emissions	Project Uncontrolled
Emissions > 100 tpy	Project Controlled
Emissions	
PM/ PM10	94.12	No	94.12	
SO2	0.08	No	0.08	
NOx	13.23	No	13.23	
CO	11.11	No	11.11	
VOC	124.44	Yes	90.02	
Total HAPs	5.21	No1	24.02	
Individual HAPs	3.99	No1	9.02	
1. The threshold for Total HAP emissions is 25 tpy and Individual HAP emissions is 10 tpy.
2. Limit proposed by H.M. Richards, Inc.	
Previously, the facility was considered a minor source of emissions because facility-wide uncontrolled emissions were below both State Standards and TV major source thresholds. Table 1 demonstrates that the proposed coating project will cause the entire facility to exceed the TV major source threshold for uncontrolled VOC emissions. However, the facility will implement synthetic restrictions, as seen in Project Controlled Emissions of Table 1, to keep the facility-wide VOC emissions below the TV major source threshold. The facility requested limitations on Total HAP and Individual HAP emissions, as seen in Table 1, for operational flexibility
APPLICABLE/PROPOSED PERMIT LIMITATIONS
Emission Points AA-006 and AA-007 are subject to the State Standards for PM and sulfur dioxide (SO2) emissions. Since natural gas is a relatively clean burning fuel, the units should have a large margin of compliance for PM and SO2.
H.M. Richards, Inc has proposed the installations of Emission Points AA-008 and AA-009, which will cause the facility-wide uncontrolled VOC emissions to exceed the TV major sources threshold (124.45 tpy > 100 tpy). The facility proposes the following facility-wide limits to remain below the Title V major source threshold: VOC emissions to no more than 90.0 tpy, individual HAP emissions to no more than 9.0 tpy, and total HAP emissions to no more than 24.0 tpy. The facility will demonstrate compliance with the limitation by keeping a record of the quantity used (gallons), percentage of VOC’s and HAPs by weight, and density (lbs/gal) of each adhesive, cleaner, or other VOC containing material used. The permittee shall use the given parameters to determine VOC emissions on a monthly basis and 12-month rolling basis in tpy. The records shall be included in the annual synthetic minor monitoring report.
This permit will contain Work Practice Standards that will require the facility to operate and maintain air pollution control equipment (e.g. baghouses and exhaust fans with dry filter) at all times. Also, the permittee will be required to keep all spare parts and equipment as is necessary to repair and/or replace each baghouse and exhaust fan with dry filter. Compliance with the Work Practices will be demonstrated through monthly maintenance inspections and documentation detailing the inspection.

STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES (NSPS) APPLICABILITY
None.
NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)/MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (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. H.M. Richards, Inc. is an area source for HAP emissions, as seen in Table 2. Therefore, H.M. Richards, Inc. is not subject to Subpart MMMMM.
National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production and Fabrication Area Sources – Subpart OOOOOO
Facilities subject to the National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production and Fabrication Area Sources (40 CFR 63, Subpart OOOOOO) own or operate an area source of HAP emissions and a flexible polyurethane foam fabrication facility. H.M. Richards, Inc commenced construction of a flexible polyurethane foam fabrication facility after April 4, 2007, and the facility will be an area source of HAP emissions. Therefore, H.M. Richards, Inc. is subject to Subpart OOOOOO.
As a new flexible polyurethane foam fabrication affected source, the facility shall not use any adhesive containing methylene chloride for any flexible polyurethane foam fabrication process. H.M. Richards, Inc. shall demonstrate compliance with the methylene chloride restriction by keeping records of each adhesive’s Material Safety Data Sheets, usage, and engineering calculations.

EMISSION LIMITATIONS, MONITORING AND RECORDKEEPING, AND REPORTING REQUIREMENTS

Emission Point(s)	Limitations and Standards	Work Practices	Monitoring and Recordkeeping	Reporting	
Facility-Wide	Opacity shall not exceed 40%	-----	Wide Margin of Compliance	Report permit deviations within five (5) working days.
All documents submitted to MDEQ shall be certified by a Responsible Official.
Submit certified annual monitoring report.	
	PM Emissions shall not exceed E = 4.1 p0.67	-----			
	VOC emissions shall not exceed 90.0 tpy.
Total HAP emissions shall not exceed 24.0 tpy.
Individual HAP emissions shall not exceed 9.0 tpy.	-----	Keep a record of all calculated VOC, Individual HAP, and Total HAP emissions.		
	-----	-----	Maintain records for a minimum of 5 years.		
AA-001
AA-002
AA-008
AA-009	-----	Operate each baghouse and exhaust fan with dry filter at all times when processing.	-----		
	-----	Maintain an inventory of all spare parts and equipment.	-----		
AA-006
AA-007	PM emissions shall not exceed
E = 0.8808*I-0.1667	-----	Wide Margin of Compliance		
	SO2 emissions shall not exceed 4.8 lbs/MMBtu	-----			
AA-008
AA-009	40 CFR 63,
Subpart OOOOOO General Applicability	-----	Keep adhesive usage records, Material Safety Data Sheets, and engineering calculations.		
	Use of methylene chloride is prohibited.				

PUBLIC PARTICIPATION

The 30-day public notice period began on October 10, 2019, with the publication of a notice in the Northeast Mississippi Daily Journal.

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.