INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
August 20, 2025

GENERAL FACILITY INFORMATION
Facility Name:  Patrick Industries Inc dba Baymont Industries Plant No. 2
Facility Address:  
16 Industrial Road
Belmont, MS 38827    
County: Tishomingo
SIC Code(s): 3089
NAICS Code(s): 326199  

APPLICATION SUMMARY 
Permit No.: 2640-00069
Permit Action:  Title V Operating Permit Initial Issuance
Permit Folder: PER20230001
Application Receipt Date: April 17, 2024
Application Deemed Complete: July 1, 2025
CBI Submitted?: No	NSPS (Part 60): N/A
NESHAP (Part 61): N/A
NESHAP (Part 63): WWWW
112(r) / RMP: N/A
Other: N/A	

FACILITY DESCRIPTION
Patrick Industries, Inc., dba Baymont Composites (Baymont) is classified as a manufacturer of reinforced plastic products. The facility operates a single main production line which consists of open mold that move through the production line (Emission Point AA-001) where gel coat and catalyst are applied to the open molds using non-atomized spray guns. After drying, the fiberglass operation uses non-atomized “chop” guns to apply three (3) layers of fiberglass and a resin/filler mixture. Once complete, the units are separated from the molds and are moved to the finish operation (Emission Point AA-002) where irregularities are trimmed and sanded and then holes are drilled for hardware installation. Each unit is cleaned and inspected prior to being moved to the storage area for shipment. The molds are returned to the staging area where flaws are repaired using tooling gel coat and resin before being used again. Additional panel trimming operations are conducted to finish fiberglass access panels. During this process, finished panels are trimmed to size and cleaned prior to being fitted to finished units. 

Fabric filters are used to control PM emissions from the spraying operations. Exhaust from the gel coat operation of the main production line are also  routed through fabric filters before venting to the atmosphere. There are cartridge dust collectors that control PM from the finishing operations. Dust collectors are located and vented inside the manufacturing building. The following table contains the significant emission points at the facility.

Emission Point	Description	
AA-001	Open Mold Spray Lay-up Line 	
AA-002	Finishing Area which includes trimming and grinding/sanding operations	
AB-002	LL Wood Shop (existing minor source) where wood is sawed/cut to make wood forms for molds/bath units	

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: Volatile Organic Compounds (VOCs)

The facility’s potential-to-emit hazardous air pollutants (HAPs) exceeds the Title V major source thresholds of 25 tpy of total HAPs and 10 tpy for the following individual HAPs – Styrene.

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions2
(tons/yr)	
Particulate Matter (TSP)	50.64	
PM10	50.64	
PM2.5	50.64	
Sulfur Dioxide (SO2)	0.02	
Nitrogen Oxides (NOx)	3.13	
Carbon Monoxide (CO)	2.63	
Volatile Organic Compounds (VOC)	249.00	
Total Reduced Sulfur (TRS)	0.00	
Lead	0.00	
CFC/HCFC	0.00	
Total HAP 	99.0	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.
2 The PTE emissions also include the potential emissions from the other minor sources (i.e., Mold Shop, LL Wood, Ceramic Tile) located in the industrial park with Plant No. 2.  

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The facility is not one of the 28 categorical facilities listed in 40 CFR 52.21(b)(1)(i)(a); therefore, the PSD threshold for a major source is 250 tpy.  The facility has the potential to emit more than 250 tons per year of VOCs but will continue to limit facility-wide emissions of VOCs to no greater than 249.0 tpy; therefore, the facility is considered a moderate stationary source. 

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
The following changes have been implemented in the Title V operating permit to reflect as built changes from the previously issued permit to construct. 
1)	Emission Points AA-003 through AA-006 have been identified as insignificant activities. These Emission Points have not been included in Section 2 of the operating permit. Emission Point AA-003 is the panel trimming operations area. Emission Point AA-004 includes the natural gas-fired heaters (all of which are less than 10 MMBtu/hr). Emission Points AA-005 and AA-006 are 6,500-gallon Resin Storage Tanks.
2)	Emission Points AB-001 (Molding Shop), AB-002 (LL Wood Shop), and AB-003 (Ceramic Tile Shop) are considered existing true minor sources under common control of Baymont’s Plant No. 2. Since these entities are contiguous and adjacent to Plant No. 2, they are considered part of the Title V major source. The emission sources located at AB-001 and AB-003 are all insignificant activities and have not been included in Section 2 of the operating permit. Emission Point AB-002 is not considered an insignificant activity and will remain in Section 2 of the operating 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.

Pollutant specific emission units (PSEUs) can be defined as large or small. A large PSEU is defined as a major source post-control, while a small PSEU is a major source prior to controls. Emission units at Baymont do not meet the criteria described above. Emission Points AA-001 and AA-002 use control equipment to control particulate emissions and are subject to the process weight emission limit. However, the potential to emit pre-control for each emission point is below the major source threshold for PM. Also, while the facility has a facility-wide VOC emission limit of 249 tpy and Emission Point AA-001 has the potential to emit VOCs in excess of the major source threshold, a control device is not used to meet the VOC emission limit. Therefore, a CAM plan is not required. 

CAM Applicability Table for Sources with Control Devices
Emission Point ID	Control Device 
(not including inherent controls)	Applicable Limit/ Standard	Is standard exempt? (Yes/No)	Pre-Control > 100 tpy (Yes/No)	CAM Applies? (Yes/No)	Type of CAM PSEU
(Large/Other)	
AA-001	Fabric Filters	PM process weight	No	No	No	N/A	

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
40 CFR 63, Subpart PPPP – NESHAP for Surface Coating of Plastic Parts and Products
The provisions of Subpart PPPP are applicable to plastic part and product surface coating facilities that are a major source of HAP. Subpart PPPP specifies a plastic part as any piece or combination of porous, flexible, or rigid. However, 40 CFR 63.4881(c)(6) specifies that this standard is not applicable to gel coating operations that are subject to the reinforced plastics composites production requirements found in 40 CFR 63, Subpart WWWW. As such, Baymont is not subject to the provisions of Subpart PPPP.

40 CFR 63, Subpart WWWW – NESHAP for Reinforced Plastic Composites Production
The provisions of Subpart WWWW are applicable to reinforced plastic composites production facilities located at a major source of HAP. The manufacturing process at the Baymont facility is considered a reinforced plastic composites production facility and potential emissions indicate the facility is a major source of HAP emissions. As such, Baymont is subject to the applicable requirements of Subpart WWWW. In accordance with 40 CFR 63.5790(b), the affected source consists of all parts of the facility engaged in open molding, mixing, cleaning of equipment used in reinforced plastic composites manufacturing, HAP-containing materials storage, and repair operations on parts that are manufactured. In accordance with 40 CFR 63.5795(a), a reinforced plastic composites production facility is considered a new affected source if construction commenced after August 2, 2001, and no other reinforced plastic composites production affected source exists at that site. There were no existing affected sources located at this site prior to this date; therefore, the facility is considered a new affected source.

Baymont has a federally enforceable Permit to Construct with a 99.0 ton per year emission limit for HAP emissions in order to avoid having to reduce total organic HAP emissions by 95% per 40 CFR 63.5805(d)(1). Baymont complies with the organic HAP emission limits as specified in Table 3 to Subpart WWWW by using resin and gel coat materials that demonstrate they meet the as applied organic HAP emission limits from Table 3 of Subpart WWWW. Baymont complies with the work practice standards of Table 4 to Subpart WWWW by certifying that all cleaning materials, except styrene contained in closed systems, or materials used to clean cured resin from application equipment contain no HAP, and all HAP containing storage containers are kept closed or covered except when adding or removing materials. Bulk storage tanks are vented only as necessary for safety.

Continuous compliance is achieved by including a statement in each compliance report that all resins and gel coats, as applied, meet the organic HAP emission limits in Table 3 of Subpart WWWW and by determining compliance on a rolling 12-month basis. Continuous compliance with the work practice standards from Table 4 is demonstrated by maintaining operations in accordance with the work practice standards and including a certifying statement in each compliance report.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
40 CFR 60, Subpart Kb – Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984.
This subpart applies to each storage vessel with a capacity greater than or equal to 19,813 gallons (75 cubic meters) that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after July 23, 1984. Neither of the resin tanks have a capacity above the applicability threshold; therefore, the storage vessels are not subject to this subpart. 

SPECIFIC APPLICABLE REQUIREMENTS

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
Facility-Wide	VOC	< 249.0 tpy (PSD Avoidance)	Calculate total VOC, total HAP, and individual HAP emission rate via mass balance for each consecutive 12-month period on a rolling basis (tpy)	
	Total HAP	< 99.0 tpy (MACT Avoidance)		
AA-001                	HAP	Organic HAP emission limits	Maintain resin, gel coat, and catalyst usage.	
			Maintain emission factor calculations on a monthly basis.	
AA-001               AA-002          	PM (Filterable Only)	Vent emissions to filters for control	Maintain records of emissions vented to filters.	
			Record maintenance performed on filters.	

OTHER REQUIREMENTS:
None.