PERMIT REVIEW SUMMARY

Permit Writer:	Clinton Gentry				Date:	August 26, 2024

Company Name:	H M Richards Inc

Facility Location:	120 H M Richards Way
			Guntown, MS
			
			34° 28’ 53.63” N
			88° 40’ 09.20” W

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 consisting of nine (9) emission points: Lumber, Oriented Strand Board (OSB), and Plywood Processing, Fiber Operations, Frame Gluing, Finger Joint Gluing and Cleaning, Main Facility Space Heaters, Warehouse Space Heaters, Eight (8) Foam Fabrication Spray Booths (Emission Point AA-008), and a Foam Fabrication Spray Line Conveyor (Emission Point AA-009). The following table includes the currently existing 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	Eight (8) 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.	

PROJECT/PERMIT ACTION DESCRIPTION

H.M. Richards is requesting reissuance of their Synthetic Minor Operating Permit (SMOP) Air Ref. No. 1540-00145, issued November 2019 and set to expire October 2024. The facility is requesting the permit be modified to include the addition of a polyfoam re-bond process (Proposed Emission Point AA-011) as well as a 2.041 MMBtu/hr boiler to provide steam to the re-bond process (Proposed Emission Point AA-010). In addition, the facility is proposing to add two more Foam Fabrication Spray Booths to Emission Point AA-008.

EMISSION SUMMARY

Pollutant	Proposed Facility Uncontrolled Emissions	Exceed Title V Threshold (Yes/No)?	Proposed Allowable Emissions	
PM10/ PM2.5	161.72	Yes	80.22	
SO2	0.10	No	0.10	
NOx	16.12	No	16.12	
CO	13.54	No	13.54	
VOC	387.98	Yes	90.02	
Total HAP	11.89	No	24.02	
Individual HAP	< 10.0	No	9.02	

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 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. 

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 proposed boiler (Emission Point AA-010) has a rated capacity of 2.041 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 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 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 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 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 proposed 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

This permitting action will undergo a 30-day public notice period. This public notice period began on September 4th, 2024 and ended on October 4th, 2024. The public notice is available online at https://www.mdeq.ms.gov/ensearch/epd-permits-at-public-notice/

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.