DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Thomas Parker	Date:	October 24, 2025

Company Name:	H M Richards Inc

Facility Location:	120 H M Richards Way
Guntown, MS

Source Number:	1540-00145

County: 		Lee

FACILITY DESCRIPTION

H. M. Richards, Inc. (H. M. Richards) operates as an upholstered furniture manufacturing facility including fiber and gluing under SIC: 2512 (Wood Household Furniture, Upholstered). H. M. Richards is an existing facility currently operating under a Synthetic Minor Operating Permit (SMOP), which expires September 30, 2029. Facility process operations generate Particulate Matter (PM), Particulate Matter less than 10 microns (PM10), Particulate Matter less than 2.5 microns (PM2.5), Volatile Organic Compounds (VOCs), Individual Hazardous Air Pollutants (HAPs), and Total HAPs. The facility’s fuel burning equipment generate PM, PM10, PM2.5, Sulfur Dioxide (SO2), Nitrogen Oxides (NOx), Carbon Monoxide (CO), and VOC emissions.. The following table includes the existing and proposed emission points at the facility.

Emission 
Point	Description	
AA-001	Mill Shop
Controlled by a baghouse.	
AA-002	Fiber Operations
Controlled by a baghouse.	
AA-003	Frame Gluing	
AA-004	Finger Joint Gluing and Cleaning	
AA-005	Cushion Repair Gluing	
AA-006	Main Facility Space Heaters
83 Natural Gas-fired units for a combined 17.94 MMBtu/hr	
AA-007	Warehouse Space Heaters
33 Natural Gas-fired units for a combined 12.87 MMBtu/hr	
AA-008	Fourteen (14) Foam Fabrication Spray Booths
Controlled by an exhaust dry filter.	
AA-009	Two (2) Foam Fabrication Spray Line Conveyors
Controlled by an exhaust dry filter.	
AA-010	Polyfoam Re-bonder Boiler
2.04 MMBtu/hr Natural Gas-fired unit	
AA-011	Polyfoam Re-bonding Process	
AA-012	Polyfoam Building Space Heaters
Six (6) 0.30 MMBtu/hr Natural Gas-fired units
Two (2) 0.10 MMBtu/hr Natural Gas-fired units	

PROJECT/PERMIT ACTION DESCRIPTION

H. M. Richards is requesting a modification of their SMOP, issued October 14, 2024, with the following changes:

•	The addition of four (4) foam fabrication spray booths to the existing ten (10) (Emission Point AA-008).

•	When the facility was purchased in 2021, H. M. Richards started replacing the twelve (12) space heaters from the original building. Currently, six (6) 0.30 MMBtu/hr natural gas-fired space heaters and two (2) 0.10 MMBtu/hr natural gas-fired space heaters (Emission Point AA-012) are operational, and four (4) of the original space heaters are non-operational.

o	The eight (8) Polyfoam Building Space Heaters (Emission Point AA-012) were operational but not included in the reissuance on October 14, 2024, of the SMOP because the facility did not include Emission Point AA-012 within the reissuance application. Two (2) heaters were constructed and installed in 1997. Four (4) heaters were constructed and installed in 2021. Lastly, two (2) heaters were constructed and installed in 2023.

o	H.M. Richards does not intend to reconnect or replace the remaining four (4) non-operational space heaters.

•	The addition of the four (4) new spray booths and the twelve (12) natural gas-fired space heaters.

EMISSION SUMMARY

Pollutant	Proposed Uncontrolled Emissions    (tpy)	Exceed Title V Threshold (Yes/No)?	Proposed Allowable Emissions   (tpy)	
PM10	182.43	Yes	90.0	
SO2	0.09	No	0.09	
NOx	14.97	No	14.97	
CO	12.57	No	12.57	
VOC	456.81	Yes	90.0	
Total HAP	13.26	No	24.0	
Individual HAP	< 10.0	No	9.0	

As shown in the table above, H.M. Richards has the potential to exceed the Title V threshold for both PM10 and VOCs.

In order to be categorized as a synthetic minor source, the facility has requested federally enforceable limitations that will limit the VOC, Total HAP, and Individual HAP emissions to 90.0 tpy, 24.0 tpy, and 9.0 tpy, respectively. This will be determined via a mass balance on all adhesive, cleaner, or other VOC or HAP containing materials.

The facility will meet the PM10 limitation of 90.0 tpy by complying with the state standard 11 Miss. Admin. Code Pt. 2, R. 1.3.F(1). which requires that all PM emissions shall not exceed E = 4.1p0.67 and adhering to the federally enforceable limitation of 90.0 tpy. Emission Points AA-001 and AA-002 will use baghouses to control PM, PM10, and PM2.5 emissions. Emission Points AA-008 and AA-009 will use exhaust dry filters to control PM, PM10, and PM2.5 emissions.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).
o	VOC emissions limited to 90.0 tpy
o	Total HAP emissions limited to 24.0 tpy
o	Individual HAP emissions limited to 9.0 tpy
o	PM10 emissions limited to 90.0 tpy

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).
o	Shall route all emissions to the respective control device

•	11 Miss. Admin. Code Pt. 2, R. 1.3.F(1).
o	Particulate and ash limited by the relationship E = 4.1p0.67, 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. 1.3.D(1)(a).
o	Particulate emissions from fossil fuel installations less than 10 MMBtu/hr shall not exceed 0.6 lb/MMBtu

•	11 Miss. Admin. Code Pt. 2, R. 1.4.A(1).
o	SO2 from fossil fuel installations used to produce heat or power by indirect heat transfer shall not exceed 4.8 lb/MMBtu 

NSPS APPLICABILITY

40 CFR 60, Subpart Dc - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units 
This subpart applies to facilities with industrial steam generating units with a rated capacity equal to or greater than 10 MMBtu/hr, but less than 100 MMBtu/hr which were installed, modified, or reconstructed after June 9, 1989. The Polyfoam Re-bonder Boiler (Emission Point AA-010) has a rated capacity of 2.04 MMBtu/hr. Therefore, this emission point is not subject to this subpart.

MACT APPLICABILITY

40 CFR 63, Subpart JJ – National Emission Standards for Hazardous Air Pollutants for Wood Furniture Manufacturing Operations.
This subpart applies to facilities that manufacture wood furniture or wood furniture components and is located at a major source of HAP emissions. This facility is categorized as an area source of HAPs and therefore, is not subject to this subpart.

40 CFR 63, Subpart III – National Emissions Standards for Hazardous Air Pollutants for Flexible Polyurethan Foam Production.
This subpart applies to facilities that produce flexible polyurethane foam or re-bond foam that is located at a major source of HAP emissions. This facility is categorized as an area source of HAPs and therefore, is not subject to this subpart.

40 CFR 63, Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters 
This subpart applies to facilities that own or operate an industrial, commercial, or institutional boiler that is located at a major source of HAPs. This facility is categorized as an area source of HAPs and therefore, is not subject to this subpart.

40 CFR 63, Subpart MMMMM – National Emission Standards for Hazardous Air Pollutants: Flexible Polyurethane Foam Fabrication Operations 
This subpart applies to facilities that own or operate a flexible polyurethane foam fabrication plant site that operates a flame lamination and is a major source of HAPs or operates a loop slitter with HAP-based adhesive and is a major source of HAPs. This facility is categorized as an area source of HAPs and therefore, is not subject to this subpart.

40 CFR 63, Subpart OOOOOO – National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production and Fabrication Area Sources 
This subpart applies to facilities that produce flexible polyurethane foam, re-bond polyurethane foam, and are an area source of HAPs. As such, this facility is subject to this subpart.

40 CFR 63, Subpart JJJJJJ – National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources 
This subpart applies to facilities that own or operate an industrial, commercial, or institutional boiler or process heat unit and is an area source of HAPs. As such, this facility is potentially subject to this subpart. However, the Polyfoam Re-bonder Boiler (Emission Point AA-010) is gas fired. Under 63.11195(e), gas-fired boilers are exempt from this subpart. As such, this facility is not subject to this subpart.

PUBLIC PARTICIPATION

The 30-day public notice period began on March 18, 2026, when the notice was posted on MDEQ’s website and ends April 17, 2026.