DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Thomas Parker 	Date:	April 29, 2025

Company Name:	Albany Industries Inc, New Albany Facility

Facility Location:	504 North Glenfield Road
New Albany, MS 38652

Source Number:	2700-00050

County: 		Union

FACILITY DESCRIPTION

Albany Industries Inc, New Albany Facility (“Albany”) operates a foam cushion and furniture parts production facility (SIC Code: 2512). Albany has requested a Synthetic Minor Operating Permit (SMOP) reissuance without any modifications to the facility. The facility consists of seven (7) Air Atomized, Double-Sided Foam Fabrication Spray Booths (Emission Point AA-101) controlled by exhaust dry filters venting through two (2) stacks, a Foam Fabrication Operation (Emission Point AA-102), and a Sawing and Profiling Part Preparation Wood Mill (Emission Point AA-103) controlled by a dust collector (baghouse). Emission Point AA-102 does not have an outside vent and will not emit into the atmosphere. The emission points at the facility are shown in the table below.

Emission 
Point	Description	
AA-101	Seven (7) Air Atomized, Double-Sided Foam Fabrication Spray Booths
Controlled by exhaust dry filters venting through two (2) stacks	
AA-102	Foam Fabrication Operations	
AA-103	Sawing and Profiling Part Preparation Wood Mill
Controlled by a dust collector (baghouse)	

PROJECT/PERMIT ACTION DESCRIPTION

Albany has not requested any modifications to the facility for the current SMOP reissuance. 

EMISSION SUMMARY

Facility-Wide Potential Emissions Summary
Pollutant	Potential Emissions
(tpy)	Allowable Emissions
(tpy)	
PM	443.59	99.0	
PM10	7.94	-	
PM2.5	2.94	-	
SO2	0.0	-	
NOx	0.0	-	
CO	0.0	-	
VOC	124.36	99.0	
Individual HAP	> 10.0	9.0	
Total HAPs	> 25.0	24.0	

Albany has the potential to exceed the Prevention of Significant Deterioration threshold of 250.0 tons per year (tpy) for Particulate Matter (PM) and the Title V Major Source threshold of 100.0 tpy for Volatile Organic Compound (VOC), 10.0 tpy for Individual Hazardous Air Pollutant (HAP), and 25.0 tpy for Total HAP emissions, as seen in the table of potential emissions. The facility will remain below the thresholds by instituting facility-wide emission limitations for the following: 99.0 tpy for PM, 99.0 tpy for VOCs, 9.0 tpy for Individual HAPs, and 24.0 tpy for Total HAPs. Albany is an area source for HAP emissions because the facility’s HAP emissions are limited to less than the Title V Major Source thresholds detailed above. Albany will demonstrate compliance via monitoring and recordkeeping.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).
o	PM emissions limited to 99.0 tpy
o	VOC emissions limited to 99.0 tpy
o	Total HAP emissions limited to 24.0 tpy
o	Individual HAP emissions limited to 9.0 tpy

•	11 Miss. Admin. Code Pt. 2, R. 1.3.F(1).
o	Particulate and ash limited by the relationship E = 4.1 × p0.67, where “E” is the emission rate in pounds per hour, and “p” is the process weight input rate in tons per hour.

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11).
o	The identification of each coating, adhesive, solvent or other VOC or HAP containing material and the total gallons of each coating, adhesive, solvent or other VOC of HAP material used on a monthly basis and in each consecutive 12-month period on a rolling basis.
o	The VOC and HAP content(s) of each coating, adhesive, solvent or other VOC or HAP containing material used. A description of the methods used to determine the VOC and HAP content shall accompany this data. The permittee may utilize data supplied by the manufacturer, or analysis of VOC and HAP content by EPA Test Method 24, 40 CFR 60, Appendix A and/or EPA Test Method 311, 40 CFR 63, Appendix A, and/or an alternate EPA approved test method.
o	The density of each coating, adhesive, solvent or other VOC or HAP containing material used.
o	The total VOC emission rate, the emission rate of each individual HAP and the total HAP emission rate in tons/year for each consecutive 12-month period on a rolling basis.
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11).
o	Emission Points AA-101 and AA-103 shall only be operated when the control devices are fully functional.
o	Demonstrate compliance by performing monthly maintenance inspections on the baghouse and exhaust fan with dry filter to make sure it is operating as designed. The permittee shall keep a detailed record of each inspection.
o	Demonstrate compliance by performing EPA Test Method 22 visual observation on a weekly basis. Results shall be recorded in log form. The source producing visual emissions shall be shut down in accordance with the manufacturer’s protocols and corrective actions shall be taken. The emission source shall begin operations once corrective actions have been taken. Records of observations, any maintenance work conducted, and any corrective actions shall be kept in log form and made available for review upon request.

NSPS APPLICABILITY

The facility is not subject to any NSPS.

MACT APPLICABILITY

40 CFR 63, Subpart MMMMM (National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Fabrication Operations): Facilities subject to this subpart utilize flame lamination or operate a loop slitter and are a major source for HAP emissions. Albany is an area source of HAP emissions. Therefore, the facility is not subject to Subpart MMMMM.

40 CFR 63, Subpart OOOOOO (National Emission Standard for Hazardous Air Pollutants for Flexible Polyurethane Foam Production and Fabrication at Area Sources): Facilities subject to this subpart own or operate an area source of HAP emissions and a flexible polyurethane foam fabrication facility. Albany 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, Albany is subject to Subpart OOOOOO. The facility shall not use any adhesive containing methylene chloride for any flexible polyurethane foam fabrication process. Albany shall demonstrate compliance with the methylene chloride restriction by keeping records of each adhesive’s Material Safety Data Sheets, usage, and engineering calculations.

PUBLIC PARTICIPATION

The 30-day public notice period began on May 14, 2025, when the notice is posted on MDEQ’s website and ends June 13, 2025.

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.