PERMIT REVIEW SUMMARY

Permit Writer:	Clinton Gentry 				Date:	March 4, 2021

Company Name:	FXI Inc. - Baldwyn

Facility Location:	976 Highway 45
Baldwyn, MS 38824,

			34º 28’ 54.35” N
			88º 39’ 38.16” W

Source Number:	1540-00135

County: 		Lee

FACILITY DESCRIPTION

FXI Inc. (FXI) Baldwyn Facility is a manufacturer of flexible foam products operating under SIC Code 3086. The facility operates four primary lines to create foam products, including: pillows, mattress toppers, mattresses, and memory foam accessories for bedrooms, leisure, and travel. The first line, Flexible Foam Molding (Emission Point AA-001), is responsible for mixing constituents together in a mold to produce a foam “pillow” or other sleep industry product. After this reaction is complete, the foam is removed from the mold and made ready for packaging and shipping. The second line, Foam Fabrication Operations (Emission Point AA-002), involves cutting and shaping operations that reduce the foam “buns” to smaller “blocks” that are used to produce final products or further processed into smaller products. Finally, the third line, Flexible Foam Manufacturing Operations (Emission Point AA-003), is responsible for pouring and curing large foam “buns” of varying density and other characteristics based on the desired product.

FXI has applied for a reissuance of their Synthetic Minor Operating Permit (SMOP) for their Baldwyn facility, located in Lee county. The facility was issued an initial SMOP on July 26, 2016, with the permit set to expire June 30, 2021. The facility contains the following, existing emission points: Flexible foam folding lines, foam fabrication operations, flexible foam manufacturing operations, 46 natural gas-fired space heaters, bulk chemical storage containers, two (2) diesel fired emergency fire pumps, foam parts cleaner, and two (2) pillow grinding operations.

In previous iterations of FXI’s operating permit, the facility’s Parts Cleaning (Emission Point AA-010) and Pillow Grinding (Emission Point AA-011) were not included in the emission point summary (Section 2). Because there are no insignificant emission points under a synthetic minor classification, these emission points have been added to this permit; however, they are not new emission points. 

EMISSION SUMMARY

Criteria Pollutant	Maximum Uncontrolled	Potential Controlled	Title V Threshold	
Particulate Matter 10 (PM10)	0.86	0.86	100	
Volatile Organic Compounds (VOC)	129.42	99.0	100	
Nitrogen Oxides (NOx)	9.15	9.15	100	
Carbon Monoxide (CO)	5.0	5.2	100	
Sulfur Dioxide (SO2)	0.30	0.30	100	
Total Hazardous Air Pollutants (HAP)	8.5	24.0	25	
Largest Individual HAP		9.0	10	

As shown in the table above, FXI has the potential to exceed the Title V thresholds for Volatile Organic Compounds (VOCs). In order to qualify as a Synthetic Minor Source, FXI has opted to  limit the VOC emissions to no more than 99 tons per year. The facility has also elected to take limits on individual HAPS and total HAPS emissions of 9.0 tons per year and 24.0 tons per year respectively. FXI will then adjust production rates to ensure that VOC emissions as well as total/individual HAP emissions fall below the synthetic minor limits in the draft permit. 

APPLICABLE/PROPOSED PERMIT LIMITATIONS

Emission Point	Pollutant	Limitation	Monitoring/Recordkeeping	
Facility-Wide	VOC               HAP	99.0 tpy VOC;
24.0 tpy total HAPs;
9.0 tpy individual HAP.	Monitor and record the amount of VOC and HAP containing materials used at the facility . Use that data to perform monthly mass balance calculations.	
	CH2Cl2	Shall not use methylene chloride	Compliance Certification	
AA-008
AA-009	VOC
HAP	Record hours of non-emergency operation	Install non-resettable hour meter	
AA-009	NMHC+NOx
PM	3.0 g/HP-hr for NMHC+NOx;
0.15 g/HP-hr for PM.	Maintain records, operate engine according to manufacturer’s specifications	

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
This subpart applies to owners and operators of Compression Ignition (CI) Internal Combustion Engines (ICE) that commence construction after July 11, 2005. Emission Point AA-008 is potentially applicable to this subpart, however, it was manufactured prior to 2004 and therefore is not subject to this subpart. Emission Point AA-009 is a compression ignition, 2-stroke, lean burn emergency fire pump manufactured in 2013. Therefore, this emission point is subject to this subpart.  

Subpart Kb – Standards of Performance for Volatile Organic Liquid Storage Vessels 
This subpart applies to each storage vessel with a capacity greater than or equal to 75 cubic meters (m3) that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after July 23, 1984. As such, this facility is potentially subject to this subpart. However, all tanks on-site are 12,000 gallons or less; therefore, this facility is not subject to this subpart.

NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

Subpart III - National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production 
This subpart applies to each new and existing flexible polyurethane foam or rebond foam process located at a major source of HAP emissions. FXI is currently an area source and is therefore, not subject to this subpart. 

Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
This subpart applies to owners and operators of any Reciprocating Internal Combustion Engines (RICE) located at a major or area source of HAP emissions. Emission Point AA-008 is a compression ignition, 2-stroke, lean burn, emergency fire pump installed on October 13, 2004. Therefore, this unit is considered an existing unit and is subject to this subpart. Emission Point AA-009 was constructed in 2013 and is considered a new unit. Therefore, this unit will meet all applicable requirements under 40 CFR 63 Subpart ZZZZ by complying with 40 CFR 60 Subpart IIII.

Subpart OOOOOO – National Emission Standards for Hazardous Air Pollutants for Flexible Polyuerthane Foam Production and Fabrication Area Sources
This subpart applies to foam production, either slab stock or molded, and foam fabrication area sources. As such, FXI Inc. is subject to this subpart and FXI will not use methylene chloride for any purpose in their facility.

PUBLIC PARTICIPATION

The 30-day public notice period began on March 19, 2021, with the publication of a notice in The New Albany Gazette and ends April 19, 2021.

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.