INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
April 14, 2025

GENERAL FACILITY INFORMATION
Facility Name:  Mid South Lumber Inc
Facility Address:  
1115 C Street
Meridian, MS 39302    
County: Lauderdale
SIC Code(s): 2421
NAICS Code(s): 321113  

APPLICATION SUMMARY 
Permit No.: 1460-00012
Permit Action:  Renewal with Significant Modification
Permit Folder: PER20230002
Application Receipt Date: 07/05/2023
Application Deemed Complete: 06/20/2024
CBI Submitted?: No	NSPS (Part 60): N/A 
NESHAP (Part 61): N/A 
NESHAP (Part 63): DDDD
112(r) / RMP: N/A
Other: N/A 	

FACILITY DESCRIPTION
Mid South Lumber Inc. is an existing sawmill and dimensional lumber drying facility. Facility operations fall under SIC Code 2421 (Sawmills and Planing Mills). 

Yellow pine logs are debarked and cut into dimensional lumber. The green lumber is dried in one of three direct-fired batch lumber kilns. Then, the kiln-dried lumber is planed and sorted prior to shipping. The chips, sawdust, and planer shavings are used as fuel in the kiln burners or loaded into railcars and shipped off-site. 

TITLE V SOURCE APPLICABILITY 
The facility’s potential-to-emit (PTE) exceeds the Title V major source threshold of 100 tons per year (tpy) for each of the following criteria air pollutants: nitrogen oxides (NOx), carbon monoxide (CO), particulate matter less than 10 microns (PM10), particulate matter less than 2.5 microns (PM2.5), and volatile organic compounds (VOC). The facility’s potential-to-emit hazardous air pollutants (HAPs) does not exceed the major source threshold of 25 tpy of total HAPs and 10 tpy for any individual HAP. Therefore, the facility is considered an area source for HAPs.

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions
(tons/yr)	
Particulate Matter (TSP)	175.7	
PM10	165.6	
PM2.5	140.5	
Sulfur Dioxide (SO2)	6.35	
Nitrogen Oxides (NOx)	124.5	
Carbon Monoxide (CO)	152.4	
Volatile Organic Compounds (VOC)	248.0	
Total Reduced Sulfur (TRS)	-	
Lead	0.16	
CFC/HCFC	-	
Total HAP 	11.7	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The facility is not one (1) of the twenty-eight (28) categorical facilities listed in 40 CFR 52.21(b)(1)(i)(a); therefore, the PSD threshold for a major source is 250 tpy.  While the facility has the potential-to-emit more than 250 tpy of VOCs at its maximum production capacity, it will continue to limit VOCs to more than 248.0 tpy by restricting dried lumber production; therefore, the facility is considered a moderate stationary source. This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
Mid South Lumber applied for a renewal of the Title V Operating Permit (TVOP). The following changes were made to the permit:

•	Addition of a third wood-fired batch lumber kiln (AA-011). The new kiln will allow for operational flexibility and will not result in an increased lumber throughput;

•	The individual limits for lumber throughput and VOCs for the existing lumber kilns (AA-001 and AA-005) were combined into a total lumber throughput limit of 98,608 thousand board-feet per year (MBF/yr) and 248.0 tpy of VOCs for all three kilns;

•	Removing the SO2 standard of 500 ppm for the kiln burners. Since wood is a low sulfur fuel, the burners have a significant margin of compliance with the standard. 

•	Removing the requirement that the facility’s cyclones operate at all times the process equipment is in operation. Since the cyclones are considered inherent to the process equipment, they are expected to operate at all times. 

•	The facility operates a 200-gallon gasoline storage tank and a 2,000-gallon gasoline storage tank. The applicable requirements from 40 CFR Part 63, Subpart CCCCCC were included in the permit. 

COMPLIANCE ASSURANCE MONITORING (CAM) APPLICABILITY
40 CFR Part 64 specifies the requirements for CAM.  The general applicability of this rule can be found in 40 CFR 64.2 and requires a Title V source to comply with the CAM requirements if all three of the following criteria are met for a pollutant-specific emission unit (PSEU):

1.	The unit is subject to an emission limitation or standard for a regulated air pollutant other than exemptions under 40 CFR 64.2(b)(1);
2.	The unit uses a control device to comply with the standard; and
3.	The unit has pre-control emissions exceeding Title V major source threshold.

The facility operates multiple cyclones, which serve as product collectors, so they are considered inherent process equipment. Therefore, there is no control equipment associated with any emission unit subject to an emission limit or standard at this facility, so CAM does not apply.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
40 CFR Part 63, Subpart DDDD – National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products
This subpart regulates any facility that manufactures plywood and composite wood products (which includes kiln-dried lumber) and is a major source of hazardous air pollutant (HAP) emissions. Since Mid South Lumber is classified as an are source for HAPs, this subpart is not applicable.  

40 CFR Part 63, Subpart CCCCCC – National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities (Area Sources)
Mid South Lumber operates two gasoline storage tanks (2,000-gallon and 500-gallon) and the average monthly throughput is less than 10,000 gallons. The facility must maintain records on the monthly gasoline throughput and malfunctions. 

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
40 CFR Part 60, Subpart Dc – Standards of Performance for Small Industrial-Commercial Institutional Steam Generating Units
Mid South Lumber operates three (3) direct-fired lumber kilns.  Since the kilns utilize burners, which are not steam-generating units, this subpart is not be applicable. 

SPECIFIC APPLICABLE REQUIREMENTS

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-100 (Facility-Wide)	PM
(filterable)	E = 4.1(p0.67)	Perform a Weekly Visible Emission Observation / Evaluation on Each Cyclone (AA-002, AA-004, AA-007, and AA-008)

Conduct a Monthly Inspection on Each Cyclone (AA-002, AA-004, AA-007, and AA-008)	
	Opacity 	≤ 40%		
AA-001 AA-005 AA-011	VOCs
(as WPP1)	5.03 Pounds / MBF
248.0 tpy
(For All Kilns Combined; Rolling 12-Month Total)
(PSD Avoidance Limit)	Monitor and Maintain Records of the Throughput and Emissions for Each Kiln	
	Lumber Throughput	98,608.0 MBF / Year 
(For All Kilns Combined; Rolling 12-Month Total)
(PSD Avoidance Limit)