DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Krystal Rudolph			Date:	October 13, 2023
Company Name:	Future Foam Inc			
Facility Location:	1665 South Veterans Boulevard
Tupelo, MS 38804
Source Number:	1540-00046
County: 		Lee
Action:  SMOP Reissuance
FACILITY DESCRIPTION
Future Foam Inc. (“Future Foam”) is an existing manufacturing facility that produces flexible polyurethane foam and fiber products (SIC Code: 3086). Future Foam produces flexible polyurethane foam using Toluene Diisocyanate (TDI), Methylene Diphenyl Diisocyanate (MDI), Polyol, mineral oil, and other additives. The facility is a source of Particulate Matter (PM), PM less than 10 μm in diameter (PM10), PM less than 2.5 μm in diameter (PM2.5), Sulfur Dioxide (SO2), Carbon Monoxide (CO), Volatile Organic Compounds (VOC), and Hazardous Air Pollutant (HAP) emissions.

PROJECT/PERMIT ACTION DESCRIPTION
Future Foam requests the following change to its permitted emission points:

•	Emission Point AA-037 has previously been permitted as three (3) 0.144 MMBTU/hr natural gas-fired space heaters.  The application identified that 2 of the heaters had been removed, so AA-037 has been updated to reflect only one (1) 0.144 MMBTU/hr natural gas-fired space heater.
•	
EMISSION SUMMARY

Pollutant	Potential Uncontrolled (tpy)	Proposed Allowable (tpy)	
PM/PM10/PM2.5	10.59	10.59	
SO2	0.18	0.18	
NOx	7.57	7.57	
CO	5.04	5.04	
VOC	260	99.01	
Individual HAP	6.04	9.01	
Total HAP	11.07	24.01	
1Facility Proposed Limitation

The facility has the potential to exceed the Title V major source threshold for VOC and individual HAP emissions. The facility has proposed to retain their federally enforceable limitations to maintain VOC and HAP emissions below the Title V thresholds.  The permittee will demonstrate compliance with the emissions limitations by calculating emissions based on coating, adhesive, solvent or other VOC or HAP containing material used. Future Foam will keep records on a monthly basis and for each consecutive 12-month period. 

APPLICABLE/PROPOSED PERMIT LIMITATIONS
The following conditions are included in the permit to ensure that Future Foam remains under the Title V Major Source thresholds:
•	For the entire facility, limit/restrict the following facility-wide emissions:
o	VOC emissions to no more than 99.0 tpy,
o	Individual HAP emissions to no more than 9.0 tpy,
o	Total HAP emissions to no more than 24.0 tpy. 
o	The permittee shall determine VOC, individual HAP, and total HAP emissions on a monthly basis for each consecutive 12-month period on a rolling basis.
•	For the entire facility, determine the following for each coating, adhesive, solvent, or other VOC or HAP containing material used for and maintain sufficient records to document:
o	The identification of each coating, adhesive, solvent, or other VOC or HAP containing material and the total gallons of each coating, adhesive, solvent, or other VOC or HAP containing material used on a monthly basis and in each consecutive 12-monthly period.
o	The VOC and HAP content(s) of each coating, adhesive, solvent, 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 24.
o	The density of each coating, adhesive, solvent, or other VOC or HAP containing material used.
o	Shall use the given parameters to determine VOC, individual HAP, and total HAP emissions on a monthly basis and for each consecutive 12-month period on a rolling basis.

STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES (NSPS) APPLICABILITY

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  (40 CFR 60, Subpart Kb)

40 CFR 60, Subpart Kb establishes emission limitations and operating limitations for each storage vessel with a capacity greater than or equal to 19,812.9 gallons that is used to store volatile organic liquids for which construction, reconstruction, or modification is commenced after July 23, 1984. Subpart Kb does not apply to storage vessels with a capacity greater than or equal to 39,890 gallons storing a liquid with a maximum true vapor pressure less than 3.5 kilopascals (kPa) or with a capacity greater than or equal to 19,812.9 gallons but less than 39,890 gallons storing a liquid with a maximum true vapor pressure less than 15.0 kPa. All tanks at the facility are not subject to Subpart Kb because the storage vessels do not meet the design capacity (< 19,813 gallons) requirement or the true vapor pressure is less than 15 kpa (2.18 psia). 

Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (40 CFR 60, Subpart IIII)

40 CFR 60, Subpart IIII was promulgated to regulate emissions produced by Stationary Compression Ignition Internal Combustion Engine. Subpart IIII applies to owners and operators that commence construction (order date) after July 11, 2005, and the units are manufactured after April 1, 2006. The 300 HP Diesel Fired (CI) Emergency Fire Pump (AA-031) was installed in 2003; therefore, the unit is not subject to this subpart.

Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (40 CFR 60, Subpart JJJJ)

40 CFR 60, Subpart JJJJ was promulgated to regulate emissions produced by spark ignition internal combustion engines that commenced construction after June 12, 2006. Emission Point AA-059 is a 124.07 hp Emergency Generator Natural gas-fired Spark Ignition 4-Stroke Reciprocating Internal Combustion Engine manufactured after January 1, 2009. Emission Point AA-059 is subject to and shall comply with Subpart JJJJ.

NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)/MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) APPLICABILITY

Future Foam has federally enforceable emission limitations which classify the facility as an area source of HAPs.  Therefore, the following addresses the applicability of Future Foam to NESHAPs that regulate area sources.

National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (40 CFR 63, Subpart ZZZZ)

40 CFR 63, Subpart ZZZZ establishes national emission limitations and operating limitations for HAP emitted from stationary reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions. Future Foam is an area source of HAP emissions. Emission Point AA-031 is an existing Diesel Fired (CI) Emergency Fire Pump manufactured in 2003 and therefore is subject to and shall comply with Subpart ZZZZ.  Emission Point AA-059 is a new Natural gas-fired 4-stroke emergency engine with a site rating less than 500 HP. Emission Point AA-059 shall meet the requirements of Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ.

National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers at Area Sources (40 CFR 63, Subpart JJJJJJ - Boiler MACT)

This standard applies to boilers located at area sources of HAPs. Since Future Foam is an area source of HAPs and the boiler is gas-fired, per §63.11195(e) this subpart does not apply.

National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production and Fabrication Area Sources (40 CFR 63, Subpart OOOOOO)

Facilities subject to 40 CFR 63, Subpart OOOOOO own or operate an area source of HAP emissions and a flexible polyurethane foam fabrication facility. Future Foam commenced construction of a flexible polyurethane foam fabrication facility after April 4, 2007, and the facility will be an area source of HAP emissions. Therefore, Future Foam is subject to Subpart OOOOOO.

The facility shall not use any adhesive containing methylene chloride for any flexible polyurethane foam fabrication process or material containing methylene chloride for any flexible polyurethane foam production facility. Future Foam shall demonstrate compliance with the methylene chloride restriction by keeping records of each material adhesive’s Material Safety Data Sheets, usage, and engineering calculations.

PUBLIC PARTICIPATION

The 30-day public notice period began on DATE, with the publication of a notice in the Northeast Mississippi Daily Journal.

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.