DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Thomas Parker	Date:	August 4, 2026

Company Name:	Southern Motion Inc, Plant Number 3

Facility Location:	1 Fashion Way
Baldwyn, MS 38824

Source Number:	2340-00052

County: 		Lee 

FACILITY DESCRIPTION

Southern Motion Inc, Plant Number 3 (Southern Motion), acquired the brownfield building previously permitted under Cushions To Go LLC, Plant 3 (Cushions To Go), which was terminated on July 9, 2025. Therefore, there was not an existing facility at the location when Southern Motion obtained ownership. Cushions To Go only assembled sofas, cushions, and frames. Under SIC Code: 3086 (Plastics Foam Products), Southern Motion is proposing to install and operate a flexible polyurethane foam pouring line, chemical storage tanks, a fiber manufacturing line that includes a natural gas-fired oven, and foam fabrication operations. Southern Motion’s final product will still be sofas with the addition of the proposal to produce more raw materials in house. While frame milling operations are already present, Southern Motion is proposing to add additional woodworking and air pollution control equipment. The facility also has various natural gas-fired space heaters, a diesel-fired emergency fire pump engine, and a diesel-fired emergency generator currently onsite and nonoperational. Southern Motion is not allowed to operate the existing equipment from the Cushions to Go acquisition until the Permit to Construct (PTC) has been issued.

Southern Motion’s process operations will generate emissions of Particulate Matter (PM), Particulate Matter less than 10 µm (PM10), Particulate Matter less than 2.5 µm (PM2.5), Volatile Organic Compounds (VOCs), Individual Hazardous Air Pollutants (HAPs), and Total HAPs. The facility’s fuel burning equipment will generate emissions of PM, PM10, PM2.5, Sulfur Dioxide (SO2), Nitrogen Oxides (NOx), Carbon Monoxide (CO), and VOCs. The emission points for the facility are listed in the table below. 

Emission Point	Description	
AA-100	Foam Pourline Operations: one (1) slabstock flexible polyurethane foam production line	
AA-200a	Forty-four (44) 0.13 MMBtu/hr Natural Gas-Fired Radiant Heaters	
AA-200b	Six (6) 0.3 MMBtu/hr Natural Gas-Fired Forced Draft Heaters	
AA-300	One (1) 300 HP (0.764 MMbtu/hr) Diesel-Fired (CI) Emergency Fire Pump Engine	
AA-301	One (1) 402 HP (1.023 MMBtu/hr) Diesel-Fired (CI) Emergency Generator	
AA-400	Foam Bun Marking: buns and foam pieces marked for identification with black spray paint	
AA-500	Foam Fabrication Operations: cutting and gluing foam pieces, nine (9) adhesive spray booths equipped with exhaust dry filters	
AA-600	Frame Mill: CNC routers, optimizer, rip saw, bandsaw, chop saw, and more woodworking equipment controlled by a baghouse	
AA-700	Fiber Manufacturing Line: one (1) manufacturing line	
AA-800a	Two (2) 13,208-gallon Polyol Fixed Roof Storage Tanks
One (1) 5,284-gallon Polyol Fixed Roof Day Tank	
AA-800b	Two (2) 13,208-gallon Toluene Diisocyanate (TDI) Fixed Roof Storage Tanks
One (1) 5,284-gallon TDI Fixed Roof Day Tank	
AA-800c	One (1) 100-gallon Diesel Fixed Roof Storage Tank
One (1) 80-gallon Diesel Fixed Roof Storage Tank	
AA-800d	Miscellaneous Day Tanks < 6,000 gallons:
One (1) 5,284-gallon Fixed Roof Day Tank
Three (3) 2,642-gallon Fixed Roof Day Tanks
One (1) 1,321-gallon Fixed Roof Day Tank	
AA-800e	Miscellaneous Small Material Tanks < 100 gallons:
Fifteen (15) 79.25-gallon Fixed Roof Small Material Storage Tanks	
AA-900	One (1) 0.9 MMBtu/hr Natural Gas-Fired Oven	
AB-100	One (1) Injection Molding Machine and Regrinder	

PROJECT/PERMIT ACTION DESCRIPTION

Foam Pourline Operations (Emission Point AA-100): Emission Point AA-100 include one (1) flexible polyurethane foam pouring line. TDI, polyol, and traces of other chemicals will be the primary constituents of the flexible polyurethane foam. These constituents will be fed through the pour head, which will mix the constituents together and feed down the pourline to produce a foam “bun”. After this reaction is complete, the foam will be removed from the pourline, cured, and stored until ready for fabrication. Polyol will be used to flush the pour head and lines one per day. Pouring is expected to occur two (2) days per week for approximately eight (8) hours per day.

Foam Fabrication Operations (Emission Point AA-500): Emission Point AA-500 includes foam cutting and gluing foam pieces together. PM emissions from cutting foam buns are negligible. Once the foam buns are cut, fiber and foam pieces will be glued together to form cushions. Gluing operations include the use of nine (9) identical spray booths. Each booth is equipped with fabric filters to control PM emissions from overspray.

Foam Bun Marking (Emission Point AA-400): Foam buns produced in AA-100 and pieces fabricated in AA-500 are marked using black spray paint for identification.

Fram Mill (Emission Point AA-600): Emission Point AA-600 consists of CNC routers, optimizer, rip saw, bandsaw, chop saw, and more woodworking equipment  using various types of wood (i.e., hardwood and plywood) to build frames for sofa production. Emission Point AA-600 is existing with a cyclone but will be moved to another location of the property and additional woodworking and new air pollution control equipment will be added. These operations generate PM emissions. All woodworking equipment will be routed to a baghouse with 95% efficiency.

Fiber Manufacturing Line (Emission Point AA-700): Fiber operations will consist of one (1) manufacturing line that manufactures fiber mats to be used in sofas from raw polyester fiber and recycled fiber. Fiber manufacturing operations will generate PM.

Facility-Wide Fuel Burning (Emission Points AA-200a, AA-200b, AA-300, AA-301, and AA-900): The facility operates forty-four (44) natural gas-fired radiant heaters and six (6) natural gas-fired forced draft heaters (Emission Points AA-200a and AA-200b) along with one (1) 300 HP diesel-fired emergency fire pump engine (Emission Point AA-300) and one (1) 402 HP diesel-fired emergency generator (Emission Point AA-301) as existing equipment. Southern Motion is proposing the addition of one (1) natural gas-fired oven (Emission Point AA-900) for bonding the fibers into a mat in the fiber manufacturing line (Emission Point AA-700). The fuel burning equipment at the facility burns natural gas and diesel.

Facility-Wide Storage Tanks (Emission Points AA-800a through AA-800e): Emission Points AA-800a and AA-800b includes two (2) 13,208-gallon and one (1) 5,284-gallon polyol storage tanks and two (2) 13,208-gallon and one (1) 5,284-gallon TDI storage tanks, all of which are horizontal bulk storage tanks. Emission Point AA-800c also includes one (1) 100-gallon diesel tank for Emission Point AA-300, one (1) 80-gallon diesel tank for Emission Point AA-301, and several vertical day tanks of various sizes. Emission Point AA-800d and AA-800e are miscellaneous day tanks less than 100 gallons. Emission Point AA-800c is existing equipment while all other tanks are proposed to be added. VOC and HAP emissions will result from the chemical storage equipment because of the volatile chemicals stored.

Injection Molding Machine and Regrinder (Emission Point AB-100): The facility is proposing the addition of one (1) 20-metric ton per day injection molding machine along with a regrinder (Emission Point AB-100). Resin pellets will be fed through the molding machine where plastic bags will be produced for use by Southern Motion. The operations of Emission Point AB-100 will produce PM, VOC, and HAP emissions.

The 402 HP diesel-fired emergency generator (Emission Point AA-301) and 80-gallon diesel storage tank (Emission Point AA-800c) were not included in the original application but have been added to the PTC from the addendum received on June 29, 2026. The injection molding machine and regrinder (Emission Point AB-100) were also not included in the original application but have been added to the PTC from the second addendum received on August 3, 2026. All existing equipment mentioned above are to be nonoperational until the PTC has been issued.

EMISSION SUMMARY

Pollutant	Uncontrolled Emissions1
(tpy)	Proposed Allowable Emissions
(tpy)	Proposed Allowable Exceed Title V Major Source Threshold (Yes/No)4?	
PM	83.21	2.44	No	
PM10	83.21	2.44	No	
PM2.5	83.21	2.44	No	
SO2	0.38	0.38	No	
NOx	9.04	9.04	No	
CO	4.19	4.19	No	
VOC	415.86	59.722 (95.0)3	No	
Diethanolamine	169.29	8.472 (9.0)3	No	
Total HAP	183.55	11.352 (24.0)3	No	
Notes:
1.	Uncontrolled emissions without control devices (e.g., baghouses and cyclones).
2.	Proposed allowable emissions are reduced by limitations/restrictions.
3.	Proposed emission limitation.
4.	The Title V major source threshold for criteria pollutants (PM10, SO2, NOx, and CO) is 100 tpy.
5.	The Title V major source threshold for Individual and Total HAP emissions are 10 and 25 tpy, respectfully.	
As shown in the table above, Southern Motion has the potential to exceed the Title V major source threshold for VOCs, Individual HAPs, and Total HAPs. The facility has the potential to exceed the Prevention of Significant Deterioration (PSD) threshold for VOCs.

In order to be categorized as a synthetic minor source, the facility has requested federally enforceable limitations that will limit the VOC, Individual HAP, and Total HAP emissions to 95.0 tpy, 9.0 tpy, and 24.0 tpy, respectively. Southern Motion is not one of the 28 specific industrial categories where the PSD emission threshold is reduced from 250.0 tpy to 100.0 tpy for any regulated air pollutant. Therefore, the VOC limitation excludes Southern Motion from being a PSD major source.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).
o	VOC emissions limited to 95.0 tpy
o	Total HAP emissions limited to 24.0 tpy
o	Individual HAP emissions limited to 9.0 tpy

•	11 Miss. Admin. Code Pt. 2, R. 1.3.F(1).
o	Particulate and ash limited 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. 1.4.A(1).
o	SO2 from fossil fuel installations used to produce heat or power limited to 4.8 lbs/MMBtu

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

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11).
o	The identification of each coating, adhesive, solvent, resin, or other VOC or HAP containing material and the total gallons of each coating, adhesive, solvent or other VOC or HAP material used in each consecutive 12-month period on a rolling basis.
o	The VOC and HAP content(s) of each coating, adhesive, solvent, resin, or other VOC or HAP containing material used. A description of the methods used to determine the VOC and HAP content shall accompany this data. The permittee may utilize data supplied by the manufacturer, or analysis of VOC and HAP content by EPA Test Method 24, 40 CFR 60, Appendix A and/or EPA Test Method 311, 40 CFR 63, Appendix A, and/or an alternate EPA approved test method.
o	The density or weight of each coating, adhesive, solvent, resin, or other VOC or HAP containing material used. 

NSPS APPLICABILITY

40 CFR 60, Subpart Dc (Standard 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 100 million MMBtu/hr or less, but greater than 10 MMBtu/hr. All facility fuel burning equipment have capacities less than 10 MMBtu/hr and do not meet the definition of “steam generating units.” Therefore, the facility is not subject to Subpart Dc.

40 CFR 60, Subpart Ka (Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984):
Subpart Ka establishes performance standards for any storage vessels with a storage capacity greater than 151,416 liters (~40,000 gallons) that is used to store petroleum liquids for which construction commenced after May 18, 1978. All petroleum liquid containing tanks at the site have capacities of less than 40,000 gallons. Therefore, the facility is not subject to Subpart Ka.

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 any storage vessels with a capacity greater than or equal to 75 m3 (~20,000 gallons) but less than 151 m3 (~38,890 gallons) storing a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa and vessels with a capacity greater than 75 m3 and less than 151 m3 storing a liquid with a maximum true vapor pressure less than 15.0 kPa. All tanks at the facility are planned to have capacities less than 75 m3 and will be installed after October 4, 2023. 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 in which construction, reconstruction, or modification commenced after October 4, 2023. All tanks at the facility are planned to have capacities less than 20,000 gallons. Therefore, the facility 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 engines (ICE) that were constructed after July 11, 2005, and engines manufactured after April 1, 2006. Southern Motion operates an existing 300 horsepower (HP) emergency diesel fire pump. The engine was constructed and manufactured before 2006. Therefore, the facility is not subject to Subpart IIII.

40 CFR 60, Subpart JJJJ (Standards of Performance for Stationary Spark Ignition Internal Combustion Engines): 
The provisions of Subpart JJJJ are applicable to manufacturers, owners, and operators of stationary spark ignition (SI) internal combustion engines (ICE). Engines subject to Subpart JJJJ are stationary SI ICE that commenced construction (order date) after June 12, 2006, where the stationary SI ICE are manufactured on or after July 1, 2008. Stationary SI ICE that were modified after June 12, 2006, are also subject to Subpart JJJJ. The facility does not have any SI ICE. Therefore, the facility is not subject to Subpart JJJJ.

MACT APPLICABILITY

40 CFR 63, Subpart III (National Emissions Standards for Flexible Polyurethane Foam Production):
The provisions of Subpart III are applicable to each new and existing flexible polyurethane foam or rebond foam process located at a major source of HAP emissions. Southern Motion is requesting limits for emissions to be below major source thresholds for HAPs. Therefore, the facility is an area source for HAPs and is not subject to Subpart III.

40 CFR 63, Subpart ZZZZ (National Emissions Standards for Stationary Internal Combustion Engines (RICE)): 
The provisions of Subpart ZZZZ establish emission and operating limitations for HAPs emitted from stationary RICE located at major and area sources of HAP emissions. Potentially affected sources are any existing, new, or reconstructed stationary RICE located at a major or area source of HAP emissions. Existing stationary RICE units of an area source of HAPs are units in which construction or reconstruction commenced prior to June 12, 2006. New stationary RICE at an area source of HAPs are units in which construction or reconstruction commenced on or after June 12, 2006.

Southern Motion operates an existing 300 HP emergency diesel fire pump (Emission Point AA-300) and a 402 HP emergency generator (Emission Point AA-301) constructed and manufactured before 2006. Therefore, the facility is subject to Subpart ZZZZ. Requirements are to change oil and filter every 500 hours or within one (1) year and thirty (30) days of pervious change, whichever comes first; inspect air cleaner every 1,000 hours or within one (1) year and thirty (30) days of pervious inspection, whichever comes first; inspect all hoses and belts every 500 hours or within one (1) year and thirty (30) days of pervious inspection, whichever comes first; and install a non-resettable hour meter. Due to the age of the engine, the engine is not EPA certified. Southern Motion will either perform performance testing to demonstrate compliance with the emissions standards of Subpart ZZZZ or submit a modification request to rebuild or replace the engine.

40 CFR 63, Subpart DDDDD (National Emission Standards for Industrial, Commercial, and Institutional Boilers and Process Heaters):
The provisions of Subpart DDDDD are applicable to each industrial, commercial, or institutional boiler or process heater that is located at or is part of a major source of HAP emissions. Southern motion is requesting limits to be an area source for HAPs. Therefore, the facility is not subject to Subpart DDDDD.

40 CFR 63, Subpart OOOOOO (National Emission Standards for Flexible Polyurethane Foam Production and Fabrication Area Sources):
The provisions of Subpart OOOOOO are applicable to new and existing affected sources of foam production, either slabstock or molded, and foam fabrication area sources. Each affected source is the collection of all equipment and activities necessary to produce slabstock flexible polyurethane foam, molded foam, or conduct flexible polyurethane foam fabrication. An affected source is existing if construction or reconstruction commenced on or before April 4, 2007.

Southern Motion will be a new source that plans to comply with the requirements of Subpart OOOOOO by not using any material containing methylene chloride for any purpose in the production processes. In addition to not using methylene chloride, the facility is required to submit a notification of compliance status report prior to 180 days after start up at the facility. Therefore, the facility is subject to Subpart OOOOOO.

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.