DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Thomas Parker	Date:	July 27, 2026

Company Name:	Ashley Furniture Industries Inc, Verona Facility

Facility Location:	108 Lipford Road

Source Number:	1540-00050

County: 		Lee

FACILITY DESCRIPTION

Ashley Furniture Industries Inc, Verona Facility (Ashley Furniture) is an existing foam manufacturing and fabrication facility located in Verona and falls under the SIC Code 3086 (Plastics Foam Products) and NAICS Code 326150 (Urethane and Other Foam Product (except Polystyrene) Manufacturing). The foam manufacturing operation includes reacting toluene diisocyanate (TDI) or methylene diphenyl isocyanate (MDI) with polyol and other various additives to create flexible foam “buns” which are cut into different sizes and shapes to meet various customer orders and requirements. The components are glued together using “rolled on” water-based adhesives. The facility also has various natural gas-fired comfort heating units on-site. Ashley Furniture process operations will generate Particulate Matter (PM), PM less than 10 microns (µm) in diameter (PM10), PM less than 2.5 µm in diameter (PM2.5), Volatile Organic Compounds (VOCs), Sulfur Dioxide (SO2), Nitrogen Oxides (NOx), Carbon Monoxide (CO), and Hazardous Air Pollutants (HAPs). The facility is a Synthetic Minor source for criteria pollutants and an area source of HAPs. The current emission points at the facility consist of Emission Points AA-001 through AA-006 with modifications to Emission Points AA-001 and AA-005. The proposed modification includes the addition of Emission Points AA-007 through AA-010. The table below provides a summary of the current/proposed emission points at the facility.

Emission Point	Description	
AA-001	One (1) Slabstock Foam Fabrication Production Line including mixing and curing	
AA-002	149 HP (100 kW) SI 4-stroke Natural Gas-Fired Emergency Generator (prior to June 2006)	
AA-003	422 HP (315 kW) CI 4-stroke Diesel-Fired Emergency Fire Pump (2021)	
AA-004	Ten (10) 0.2 MMBTU/hr, Natural Gas-Fired Space Heaters
Five (5) 0.039 MMBTU/hr, Natural Gas-Fired Space Heaters	
AA-005	Four (4) 12,600-gallon methylene diphenyl diisocyanate (MDI) Tanks
Three (3) 21,000-gallon toluene diisocyanate (TDI) Tanks
Eight (8) 21,000-gallon polyol Tanks
Eight (8) 12,600-gallon polyol Tanks 	
AA-006	Foam Fabrication Area	
AA-007	25 HP (18 kW) 1.01 MMBTU/hr Natural Gas-Fired Steam Generator (2024)	
AA-008	Two (2) 550-gallon Double-Walled Diesel Tanks (one with each fire pump)	
AA-009	470 HP (350 kW) CI 4-stroke Diesel-Fired Emergency Generator (prior to June 2006)	
AA-010	422 HP (315 kW) CI 4-stroke Diesel-Fired Emergency Fire Pump (proposed 2026)	

PROJECT/PERMIT ACTION DESCRIPTION

Ashley Furniture is currently operating under the Modified Synthetic Minor Operating Permit (SMOP) issued on September 13, 2021. The facility has requested a reissuance of the SMOP with the following modifications:

•	One (1) slabstock foam fabrication (Existing Emission Point AA-001) was never constructed. Therefore, Emission Point AA-001 is being modified to include only one (1) stabstock foam fabrication production line instead of two (2).

•	Eight (8) 21,000-gallon polyol tanks and eight (8) 12,600-gallon polyol tanks (Proposed Emission Point AA-005) have been added to the existing emission point consisting of four (4) 12,600-gallon methylene diphenyl diisocyanate (MDI) tanks and three (3) 21,000-gallon toluene diisocyanate (TDI) tanks.

•	One (1) 25 HP (18 kW) 1.01 MMBtu/hr natural gas-fired steam generator (Proposed Emission Point AA-007)  has been added with the proposed reissuance modification.

•	Two (2) 550-gallon double-walled diesel tanks (Proposed Emission Point AA-008) have been in place at the facility but left out of the previous permit. Therefore, the facility has requested the addition of Emission Point AA-008 to the proposed reissuance modification.

•	One (1) 470 HP (350 kW) compression ignition (CI) 4-stroke diesel-fired emergency generator (Proposed Emission Point AA-009) has been added with the proposed reissuance modification.

•	One (1) 422 HP (315 kW) CI 4-stroke diesel-fired emergency fire pump (Proposed Emission Point AA-010) is proposed to be added to the facility in 2026.

EMISSION SUMMARY

Facility-Wide Potential Emission Summary
Pollutant	Potential Emissions
(tpy)	Allowable Emissions
(tpy)	
PM/PM10/PM2.5	0.22	-	
SO2	0.68	-	
NOX	3.76	-	
CO	3.39	-	
Total VOC	417.59	99.0	
TDI	3.64	9.0	
MDI	4.09	9.0	
Total HAP	7.78	24.0	

Ashley Furniture has the potential to exceed the Title V major source threshold of 100.0 tons per year (tpy) for VOC emissions, as seen in the table of potential emissions. The facility will remain a Synthetic Minor source and stay below the Title V threshold by limiting VOC emissions to 99.0 tpy. The facility’s maximum uncontrolled and potential emissions for Individual and Total HAPs are below the Title V major source thresholds of 10.0 tpy and 25.0 tpy, respectively. Therefore, Ashley Furniture has also elected to retain the limits set forth in the previous permitting action of 9.0 tpy for Individual HAPs and 24.0 for Total HAPs to ensure the facility remains below the Title V major source thresholds.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

Facility-Wide

•	11 Miss. Admin. Code Pt. 2, R. 1.3.A and B.
o	≤ 40% opacity and equivalent opacity 

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

•	11 Miss. Admin. Code Pt. 2, R. 1.3.F(1).
o	Limit particulate matter and ash 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. 2.9.
o	Maintain records for five years.

Emission Points AA-002, AA-003, AA-004, AA-007, AA-009, and AA-010

•	11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(a).
o	Limit particulate emissions from fossil fuel installations less than 10 MMBtu/hr to below 0.6 lbs/MMBtu

Emission Points AA-004 and AA-007

•	11 Miss. Admin. Code Pt. 2, R. 1.4.A(1).
o	Limit discharge of sulfur oxides (measured as sulfur dioxide) to below 4.8 lbs/MMBtu.

NSPS APPLICABILITY

40 CFR 60, Subpart Dc (Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units): Subpart Dc establishes performance standards for steam generating units that were constructed, modified, or reconstructed after June 9, 1989, and that have a maximum design heat input capacity of 29 MW (100 MMBtu/hr) or less, but greater than or equal to 2.9 MW (10 MMBtu/hr). Emission Point AA-007 has a heat capacity of 1.01 MMBtu/hr; therefore, the facility is not subject to Subpart Dc.

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, and On or Before October 4, 2023): Subpart Kb establishes performance standards for each storage vessel that is used to store Volatile Organic Liquids (VOLs) with a capacity greater than or equal to 19,813 gallons (75 m3) with a maximum true vapor pressure less than 15.0 kPa but less than 39,890 gallon (151 m3) with a maximum true vapor pressure less than 3.5 kPa for which construction, reconstruction, or modification is commenced after July 23, 1984, and on or before October 4, 2023. Ashley Furniture operates three (3) TDI tanks and eight (8) polyol tanks with capacities greater than 20,000 gallons. Based on the Safety Data Sheets (SDS), TDI and polyol will have a maximum true vapor pressure less than 15.0 kPa. The other four (4) MDI tanks and eight (8) polyol tanks have capacities of 12,600 gallons, and the two (2) diesel tanks have capacities of 550 gallons. Therefore, the facility is not subject to Subpart Kb. 

40 CFR 60, Subpart Kc (Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After October 4, 2023): Subpart Kc establishes performance standards for any storage vessels with a capacity greater than or equal to 20,000 gallons (75.7 m3) in which construction, reconstruction, or modification commenced after October 4, 2023. The facility has not constructed, reconstructed, or modified a storage vessel containing VOLs greater than 20,000 gallons (75.7 m3) since October 4, 2023. Therefore, Ashley Furniture is not subject to Subpart Kc.

40 CFR 60, Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines): Subpart IIII establishes performance standards for any stationary compression ignition (CI) internal combustion engine (ICE) that were constructed after July 11, 2005, and engines manufactured after April 1, 2006, for engines that are not National Fire Protection Association (NFPA) certified fire pump engines or after July 1, 2006, for NFPA certified engines. Ashley Furniture operates a NFPA certified, 422 HP diesel-fired emergency fire pump, and plans to install another 422 HP diesel-fired emergency fire pump engine. Therefore, all engines will be subject to Subpart IIII and the emission standards and recordkeeping requirements. The stationary fire pump engines will be certified by the engine manufacturer.

40 CFR 60, Subpart JJJJ (Standards of Performance for Stationary Spark Ignition Internal Combustion Engines): Subpart JJJJ applies to stationary spark ignition (SI) combustion engines with horsepower greater than 25 HP that commence construction after June 12, 2006, and were manufactured after July 1, 2007. Ashley Furniture operates one (1) 149 HP natural gas-fired emergency generator that was installed after June 12, 2006, but was manufactured in 1997. Therefore, the emergency generator is not subject to Subpart JJJJ.

MACT APPLICABILITY

40 CFR 63, Subpart III (National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production): Subpart III establishes national emission standards for HAPs for facilities which produce flexible polyurethane or rebond foam at a plant site that is a major source of HAP emissions. Subpart III is not applicable to Ashley Furniture because the facility is an area source of HAPs.

40 CFR 63, Subpart ZZZZ (National Emissions Standards for Stationary Internal Combustion Engines): Subpart ZZZZ applies to stationary reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions. Ashley Furniture operates one (1) diesel-fired emergency fire pump that was constructed after June 12, 2006, one (1) natural gas-fired emergency generator manufactured in July 25, 1997, and constructed in 2021, one (1) diesel-fired emergency generator that was manufactured on January 6, 1993, and constructed prior to 2020 and plans to construct another identical emergency fire pump engine in 2026. The diesel-fired emergency fire pump engines and the diesel-fired emergency generator are subject to Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart IIII. Therefore, Ashley Furniture must meet the requirements of Subpart ZZZZ by meeting the requirements of NSPS Subpart IIII. The natural gas-fired generator is subject to all applicable requirements of Subpart ZZZZ.

40 CFR 63, Subpart MMMMM (National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Fabrication Operations):
Subpart MMMMM applies to flexible polyurethane foam fabrication operations utilizing a loop slitter with HAP-based adhesives or flame lamination at a major source of HAP emissions. Ashley Furniture does not operate a loop slitter and is an area source of HAPs. Therefore, the facility is not subject to Subpart MMMMM.

40 CFR 63, Subpart OOOOOO (National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production and Fabrication Area Sources):
Subpart OOOOOO applies to new and existing flexible polyurethane foam fabrication operations at facilities classified as an area source of HAP emissions. Ashley Furniture is considered an existing affected source with area source limits. Therefore, the facility is subject to Subpart OOOOOO. This subpart prohibits the use of methylene chloride. The facility will demonstrate compliance with the methylene chloride restriction by keeping records of each adhesive’s Material Safety Data Sheets (MSDS), usage, and engineering calculations. 

PUBLIC PARTICIPATION

The 30-day public notice period began on August 12, 2026, when the notice was posted on MDEQ’s website and ends September 11, 2026.