INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
April 1, 2026

GENERAL FACILITY INFORMATION
Facility Name: Southeastern Timber Products LLC, Ackerman Plant
Facility Address:  
240 PCA Road
Ackerman, MS 39735    
County: Choctaw
SIC Code(s): 2421
NAICS Code(s): 321113  

APPLICATION SUMMARY 
Permit No.: 0400-00005
Permit Action: Renewal
Permit Folder: PER20240002
Application Receipt Date: 11/14/2024
Application Deemed Complete: 1/13/2025
CBI Submitted?: No	NSPS (Part 60): IIII
NESHAP (Part 61): N/A
NESHAP (Part 63): DDDD, ZZZZ
112(r) / RMP: N/A
Other: N/A	

FACILITY DESCRIPTION
Southeastern Timber Products LLC, Ackerman Plant (“Southeastern Timber Products”) is an existing facility that manufactures dimensional lumber from harvested southern yellow pine timber.  Currently, the facility operates a sawmill area, three (3) natural gas-fired lumber continuous drying kilns (CDKs) and a planer mill area.
The pine logs are debarked and conveyed to the sawmill where they are cut to size.  The green lumber is stacked and transferred to the kilns for drying. The dried rough lumber is planed to customer specifications in the planer mill area. Bark, wood chips, and sawdust, generated in the sawmill, are mechanically conveyed to truck bins and loaded on trucks for sale. Similarly, dried shavings and chips, generated in the planer mill, are pneumatically conveyed to a cyclofilter and mechanically conveyed to truck bins for shipment 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: 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 – methanol.

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions
(tons/yr)	
Particulate Matter (TSP)	24.19	
PM10	12.74	
PM2.5	10.56	
Sulfur Dioxide (SO2)	0.37	
Nitrogen Oxides (NOx)	52.83	
Carbon Monoxide (CO)	21.46	
Volatile Organic Compounds (VOC)	853.2	
Total Reduced Sulfur (TRS)	-	
Lead	-	
CFC/HCFC	-	
Total HAP 	43.04	
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 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 tpy of VOCs; therefore, the facility is considered a major stationary source.  This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
Southeastern Timber Products applied for a renewal of the Title V Operating Permit (TVOP). The proposed TVOP incorporates the project authorized under the PSD Permit to Construct issued December 11, 2019 and modified July 3, 2025 (including all associated emission standards, operational restrictions, and monitoring requirements).  The project consisted of installing one (1) lumber continuous drying kiln (CDK) equipped with a 46 MMBTU/ hour natural gas-fired burner (Emission Point AA-017).

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.

There is no control equipment associated with any emission units subject to an emission limit or standard at this facility, so Compliance Assurance Monitoring 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 (NESHAP): 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 HAPs. Southeastern Timber Products is classified as a major source of HAPs and operates three (3) lumber drying kilns, so Subpart DDDD is applicable. However, the only requirement for lumber kilns is the submittal of an initial notification (which the facility has satisfied).

40 CFR Part 63, Subpart DDDDD – NESHAP for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters:  This subpart is applicable to an industrial, commercial, or institutional boiler and process heater located at a major source of HAPs. The facility operates direct-fired lumber drying kilns which utilize natural gas-fired burners. Since the burners are not considered boilers or process heaters, Subpart DDDDD is not applicable. 

40 CFR Part 63, Subpart ZZZZ – NESHAP for Stationary Reciprocating Internal Combustion Engines (RICE): The provisions of Subpart ZZZZ are applicable to stationary RICE located at area and major sources of HAP emissions. The facility operates a fire pump engine (Emission Point AA-015) which is considered “new” (i.e. constructed after June 12, 2006) emergency stationary RICE. As such, the unit is required to comply with the New Source Performance Standards Subpart IIII to demonstrate compliance with Subpart ZZZZ.  No other requirements under Subpart ZZZZ are applicable for this engine.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR Part 60, Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal Combustion Engines: Emission Point AA-015 is a compression ignition (CI) emergency fire pump engine that was manufactured after July 1, 2006.  Therefore, this unit is subject to the requirements of this subpart and the applicable requirements are included in the permit.

SPECIFIC APPLICABLE REQUIREMENTS

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-008
(Truck Load-Out Operations) 	PM         (filterable)	E = 4.1(p0.67)	No monitoring due to large margin of compliance	
AA-011 AA-012 AA-017
 (Lumber Kilns)	PM	E = 0.8808(I-0.1667)	The kiln burners combust natural gas so there is a large margin of compliance with the limitation; therefore no monitoring is required.	
	PM         (filterable)	E = 4.1(p0.67)	No monitoring due to large margin of compliance	
	VOCs	4.74 lb./MBF
853.2 tpy (Combined Kilns; Rolling 12-Month Total)	Develop, implement, and maintain a Work Practice Standards Plan	
	Dried Lumber Throughput	360,000 MBF/Year (Combined Kilns; Rolling 12-Month Total)	Monitor throughput of dried lumber 	
	Final Moisture Content	≥ 12% (Rolling 12-Month Average)	Monitor the moisture content of dried lumber processed in the planer mill	
AA-015
 (Emergency Fire Pump Engine)	NMHC+NOx
CO               PM 	Emission standards in 40 CFR 60.4205(c); Subpart IIII	Maintain documentation that indicates the engine complies with the applicable emission standards	
	SO2	15 ppm sulfur content (max.); and
40 cetane index (min.) or 35 vol.% aromatic content (max.)	The engine combusts ultra-low sulfur diesel (ULSD) which is compliant with the limitation.	
	Operational Requirements	100 hours / calendar year for maintenance and readiness testing;
50 hours / calendar year for non-emergency situations	Install non-resettable hour meter and record the hours of operation (emergency and non-emergency)	
	PM (filterable)	0.6 lb/MMBtu	The engine combusts diesel so there is a large margin of compliance with the limitation; therefore no monitoring is required.	
AA-016
 (Planer Mill Cyclofilter)	PM         (filterable)	E = 4.1(p0.67)	No monitoring due to large margin of compliance	
	PM/PM10/PM2.5	Install, operate, calibrate and maintain the cyclofilter according to the manufacturer’s specifications	Monitor the differential pressure drop daily
Perform monthly visible emission observations
Perform monthly maintenance inspections	
AA-020 
(Haul Roads)	PM	Reduce PM Emissions by 60%	Maintain adequate base course coverage on the haul roads 
Conduct monthly visual inspections of the base course coverage