INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
May 31, 2012

FOR:
Masonite Corporation
1001 South 4th Avenue
Laurel, MS 39441    

FACILITY DESCRIPTION
Masonite Corporation in Laurel, Mississippi is a manufacturing facility producing hardboard and softboard wood composites doorskins, softboard wood composites door cores, and plastic composites doorskins.  The applicant's operations fall within SIC Code 2493.  A Title V Permit to Operate is a permit that is required by Title V of the Federal Clean Air Act and the Mississippi Air and Water Pollution Control Law. The primary emission sources at this facility are detailed in Section 2 of the draft Title V Permit.   

On January 14, 2009 Masonite Corporation was issued an Air Construction Permit for the installation of equipment and control devices which would enable them to comply with the requirements of 40 CFR Part 63, Subpart DDDD, the National Emission Standards for Hazardous Air Pollutants:  Plywood and Composite Wood Products.  On January 11, 2010, the Air Construction Permit was modified to include the construction of a pneumatic conveyance of wood waste ash with baghouse control from the Energy Plant.  Also, on December 2, 2010 was issued a subsequent modification to their Air Construction Permit 1360-00028 to allow wood fuels “in all forms” to be burned in the wood fired heater.  Potential emissions did not increase as a result of the requested change.  The changes approved through these construction permitting actions are now being incorporated into the renewal of the Title V permit to Operate as modifications to the previous permit.  The Title V Operating Permit will be renewed for a five year term.

TITLE V PROGRAM APPLICABILITY BASIS
This facility's potential to emit particulate matter, nitrogen oxides, volatile organic compounds, and hazardous organic pollutants (HAPs) exceeds the major source threshold of 100 tons per year that was established by the Title V program of the Clean Air Act.

LEGAL AND FACTUAL BASIS FOR DRAFT PERMIT CONDITIONS
The State and Federally-enforceable conditions of Title V Operating Permits are based upon the requirements of the State of Mississippi Air Emissions Operating Permit Regulations for the Purposes of Title V of the Federal Clean Air Act (APC-S-6), and applicable requirements effective upon the date of permit issuance.  Applicable requirement means all of the following as they apply to emissions units in a Title V source:

1.	any standard or other requirement set forth in the State Implementation Plan (SIP) approved or promulgated by EPA through rulemaking under Title I of the Federal Clean Air Act (Federal Act) including the following:

a.	most of the State of Mississippi Air Emission Regulations for the Prevention, Abatement, and Control of Air Contaminants (APC-S-1) 
b.	the State of Mississippi Regulations for the Prevention of Air Pollution Emergency Episodes (APC-S-3),
c.	the State of Mississippi Regulations for the Prevention of Significant Deterioration of Air Quality (APC-S-5), and 40 CFR Part 52.21 by reference, and
d.	the provisions of the State of Mississippi Permit Regulations for the Construction and/or Operation of Air Emissions Equipment (APC-S-2), relating to construction permits and synthetic minor operating permits;

2.	any term or condition of any construction permits issued pursuant to Mississippi regulations approved or promulgated through rulemaking under Title I;

3.	any standard or other requirement under Section 111 of the Federal Act, including Section 111(d) which includes Title 40, Part 60 of the Code of Federal Regulations (40 CFR Part 60) and relevant sections of APC-S-1;

4.	any standard or other requirement under Section 112 of the Federal Act, including relevant sections of APC-S-1 and 40 CFR Parts 61, 63, and 68;

5.	any standard or other requirement of the acid rain program under Title IV of the Federal Act or the regulations promulgated thereunder, including the State of Mississippi Acid Rain Program Permit Regulations for Purposes of Title IV of the Federal Clean Air Act (APC-S-7)  adopted November 17, 1994, and 40 CFR Parts 72, 73, 75, 77, and 78;

6.	any requirements established pursuant to Section 504(b) or Section 114(a)(3) of the Federal Act;

7.	any standard or other requirement governing solid waste incineration under Section 129 of the Federal Act;

8.	any standard or other requirement for consumer and commercial products under Section 183(e) of the Federal Act;

9.	any standard or other requirement for tank vessels under Section 183(f) of the Federal Act;

10.	any standard or other requirement of the program to control air pollution from outer continental shelf sources under Section 328 of the Federal Act;

11.	any standard or other requirement of the regulations promulgated to protect stratospheric ozone under Title VI of the Federal Act;

12.	any national ambient air quality standard or increment or visibility requirement under part C of Title I of the Federal Act.

Each State and Federally-enforceable condition of the draft Title V Operating Permit references the specific relevant requirements of APC-S-6 or the applicable requirement upon which it is based. Any condition of the draft Title V permit that is enforceable by the State but is not Federally-enforceable is identified in the draft Title V permit as such.

CAM APPLICABILITY
CAM Plans are required for the “large pollutant-specific emissions units” (i.e., those with controlled emissions exceeding 100 percent of the major source threshold).  Emission Points AB-102 (Line I and II dust collection system with baghouse), AI-102 (Line III Dust Collection System with baghouse), AD-011 (Baghouse for dust collection from sawing activities), AJ-011 (Cut/Coat Line II: First Saw, Second Saw, and Third Saw equipped with a single baghouse), AD-103 (Cut/Coat Line I with cyclonic separator and disposable filter), and AJ-103 (Cut/Coat Line II with cyclonic separator and disposable filter) are subject to 40 CFR 64, Compliance Assurance Monitoring.  A copy of the facility’s CAM plan has been incorporated into the permit as Conditions 5.B.22 and 5.B.23 and as Appendix G.

AN-001 (Sheet Mold Compound Line with RTO), is subject to CAM due to VOC emissions in excess of 100 tpy uncontrolled emissions.  These units are subject to MACT standards which require parametric monitoring which meets CAM requirements.

MACT APPLICABILITY
Emission Points AL-101, AN-001, and AN-002 shall comply with all applicable requirements and limitations of the National Emission Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production, 40 CFR Part 63, Subpart WWWW.    

Emission Points AD-102, AD-103, AJ-102, and AJ-103, shall comply with all applicable requirements and limitations of the National Emission Standards for Hazardous Air Pollutants: Surface Coating of Wood Building Products, 40 CFR Part 63, Subpart QQQQ.   

Emission Points AB-101, AB-007, AC-101, AC-007, AI-101, AI-005, BS-001 and BS-002, are subject to the requirements of 40 CFR Part 63, Subpart DDDD, the National Emission Standards for Hazardous Air Pollutants:  Plywood and Composite Wood Products.  Masonite has a Routine Control Device Maintenance Exemption approved by the Department and this document with Department approval letter is attached to the permit in Appendix H.

Emission Points EG-001, EG-002, EG-003, EG-004, and EG-005, are subject to the requirements of 40 CFR Part 63, Subpart ZZZZ, the National Emission Standards for Hazardous Air Pollutants:  Reciprocating Internal Combustion Engines (RICE).  For Emission Point EG-005, the RICE requires that the unit must comply with New Source Performance Standards for Stationary Compression Ignition Internal Combustion Engines, NSPS Subpart IIII requirements. 

For all applicable MACT Regulations, the permittee has complied with all initial notifications and initial compliance demonstrations, and submitted the required reports as required by the rule.  None of these requirements are included in the proposed permit.  

Masonite removed all the boilers and now uses a heat energy plant (HEP).  This HEP is not subject to the requirements of Boiler MACT, Subpart DDDDD.  First the HEP dries the material using direct contact by the exhaust gas.   Part of the exhaust is diverted to heat water for use in other areas of the mill, however the “boiler” unit is not attached to the HEP and not under a common or associated controls system.  The HEP operations are influenced only by process demand.  Lastly, the HEP is covered under the Plywood MACT.

SPECIFIC APPLICABLE REQUIREMENTS

Units Removed during this permitting action:

Boilers and associated units
BB-001	Boiler No. 1
BB-003	Boiler No. 14
BB-004 	Boiler No. 15
AD-013	Boiler Relay Baghouse

Removal of the Coe Wicket Ovens with Associated RTO’s
AB-009	Line 1 Coe Oven and RTO
AC-009	Line 2 Coe Oven and RTO
AI-008		Line 3 Coe Oven and RTO

Removal of the Door Core Process
AE-001	Three routers, waste hog and lockblock system equipped with a baghouse
AA-002	Sander and board cleaner equipped with a baghouse
AE-003	Baghouse serving the relay to the boiler for AE-001, AE-002, AE-004, and AE-005
AE-005	Saw line, one router, and waste hog equipped with a baghouse
AE-006	Door Core Processing Area Dust Bin for storing excess boiler fuel equipped with a baghouse

Removal of Coating Line 6
AH-104	Preheat and HVHA Ovens – Coating 6

Removal of Graphical Door Line
AM-001	Basecoat Spray Booth #1
AM-002	Basecoat Spray Booth #2
AM-003	Ovolo/Edge Spray Booth #1
AM-004	Ovolo/Edge Spray Booth #2
AM-005	Drying Chamber
AM-006	RTO
AM-007	Topcoat UV Curing Booth
AM-008	IR Pre-Heat Oven
AM-009	Graphical Spray Booth
AM-010	HVHA Oven 1
AM-013	HVHA Oven 2
AM-014	Graphical UV Cure Booth 1
AM-015	Graphical Hot Oil Heater

AI-009 	Backside Buffer Baghouse, now new emission point BS-003
AP-101	Prefinish Roll Coating Line (6 drying ovens)

New Units Added during this permitting action:
BS-001	Scheuch SABA Bio-scrubber
BS-002	Energy Plant – direct fired/wood fired, with bypass stack and electrostatic precipitator for particulate matter control
BS-003	Energy Plant Dust System

OTHER LIMITS: