PERMIT REVIEW SUMMARY

Permit Writer:	Clinton Gentry				Date:	May 22, 2023

Company Name:	Patrick Industries, Inc., dba Baymont Composites

Facility Location:	26 Industrial Drive Access Road
			Burnsville, MS

Source Number:	2640-00070

County: 		Tishomingo

FACILITY DESCRIPTION

Patrick Industries, Inc., dba Baymont Composites (Baymont) is classified as a manufacturer of plastics products under SIC Code 3089 and NAICS 326199. 

The facility will have two (2) main production lines and one (1) secondary line. Each line will begin with open recreational vehicle (RV) part molds being transferred to the gel coat spray area. The open molds will hang from an overhead conveyor and will be moved by hand through the production lines. Baymont will use non-atomized spray gun equipment to apply gel coat and catalyst to the open molds. The catalyst causes a chemical reaction, which creates a strong thermoset plastic layer. After the gel coat layer is sprayed and allowed to dry in the cure room, the units will be moved to the fiberglass operation. Non-atomized “chop” guns will be used to apply three (3) layers (i.e., skin coat, second coat, and cover coat) of fiberglass and a resin mixture. The resin will be stored in an exterior storage location in two (2) resin tanks.

Once gel coat and fiberglass operations are complete, units will be separated from the molds and moved to the finish operation where irregularities will be trimmed and sanded, and holes will be drilled for hardware installation. After the units are wiped and buffed, they will be inspected and moved to storage prior to shipment. The molds will be returned to the mold staging area, where minor flaws will be repaired using tooling gel coat and resin and buffed before being used again. 

Fabric filters will be used to control PM emissions from the spraying operations. Exhaust from the gel coat operation of the main production line will also be routed through fabric filters before venting to the atmosphere. There will be cartridge dust collectors that control PM from the finishing operations. Dust collectors will be located and vented inside the manufacturing building. 

PROJECT/PERMIT ACTION DESCRIPTION

Baymont has applied for a Permit to Construct a proposed reinforced plastics composites manufacturing process in an existing industrial building located in Burnsville, MS. The application also included a request for Pre-Permit Construction Approval. The request included the required proof of publication in a local newspaper and no adverse comments were received. Once the application was reviewed and deemed complete, the Pre-Permit Construction Approval was granted on May 1, 2023. Baymont provided the Start of Construction Notice on May 4, 2023.

Baymont proposes the following emission sources: An open mold spray lay-up line (Emission Points AA-001, AA-002, and AA-003), a finishing area (Emission Point AA-004), natural gas fired fuel burning sources (Emission Point AA-005), two resin tanks (Emission Points AA-006 and AA-007), and touch-up operations where minor repairs are made to molds and manufactured units (Emission Point AA-008).

The following table contains the proposed emission points at the facility. 

Emission Point	Description	
AA-001	Open Mold Spray Lay-up Line #1 consisting of Gel Coat Application Area, Cure Area, and Lamination Area	
AA-002	Open Mold Spray Lay-up Line #2 consisting of a Gel Coat Application Area, Cure Area, and Lamination Area	
AA-003	Open Mold Spray Line #3 consisting of a Gel Coat Application Area, Lamination Area, and Finishing Area. 	
AA-004	Finishing Area which includes trimming and grinding/sanding operations	
AA-005	Natural Gas-Fired Fuel Burning Sources (i.e, space heaters and air makeup units, all of which are less than <10 MMBtu/hr)	
AA-006	6,500 Gallon Resin Storage Tank #1	
AA-007	6,500 Gallon Resin Storage Tank #2	
AA-008	Touch-up operations where minor repairs are made to molds and manufactured units	

EMISSIONS SUMMARY
Baymont Composites Emissions Summary	
Criteria Pollutant	Maximum Uncontrolled	Potential Controlled	PSD Threshold	
Carbon Monoxide (CO)	2.89	2.89	250	
Nitrogen Oxides (NOx)	3.44	3.44	250	
Sulfur Dioxide (SO2)	0.02	0.02	250	
Particulate Matter 10 (PM10)	9.75	23.20	250	
Volatile Organic Compounds (VOC)	925.39	249.0	250	
Total Hazardous Air Pollutants (HAP)	857.5473	99.0	-	
*All emissions are expressed in tons per year (tpy)

As shown in the table above, Baymont has the potential to exceed the Prevention of Significant Deterioration (PSD) limits for VOCs. In order to be classified as a PSD moderate stationary source, Baymont is requesting a limit for the emissions of VOC to 249 tons per year or less. 

Baymont is also requesting a limit on HAPs to 99.0 tons per year or less to remain below the 100 tpy threshold for controlling HAP emissions from new sources established in 40 CFR 63, Subpart WWWW.
 
NSPS APPLICABILITY

Baymont is not believed to be subject to any NSPS at this time.

MACT 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 will be a reinforced plastic composites production facility and potential emission estimates indicate the facility will be a major source of HAP emissions. As such, Baymont will be 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 are no existing affected sources located at this site; therefore, the facility will be considered a new affected source.

Baymont is proposing to establish 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 will comply 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 will comply 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 will be kept closed or covered except when adding or removing materials. Bulk storage tanks will be vented only as necessary for safety.

Continuous compliance will be 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 will be demonstrated by maintaining operations in accordance with the work practice standards and including a certifying statement in each compliance report.

PUBLIC PARTICIPATION

The 30-day public notice period began on , with the publication of a notice in the Daily Corinthian and ends .

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.