INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
July 3, 2025

GENERAL FACILITY INFORMATION
Facility Name: Vicksburg Forest Products LLC, Waltersville Lumber Mill
Facility Address:  
1725 North Washington Street
Vicksburg, MS 39183    
County: Warren
SIC Code(s): 5031
NAICS Code(s): 321113  

APPLICATION SUMMARY 
Permit No.: 2780-00004
Permit Action: Renewal with a significant modification 
Permit Folder: PER20240002
Application Receipt Date: 09/25/2024
Application Deemed Complete: 06/20/2025
CBI Submitted?: No	NSPS (Part 60): CCCC
NESHAP (Part 61): N/A
NESHAP (Part 63): DDDD, DDDDD
112(r) / RMP: N/A
Other: N/A 	

FACILITY DESCRIPTION
Vicksburg Forest Products, LLC – Waltersville Lumber Mill (VFP) is an existing facility that manufactures dimensional lumber primarily from harvested softwood timber. The facility’s operations fall within SIC Code 2421 (Sawmills and Planing Mills, General). 

The process involves debarking logs and then creating dimensional timber in the sawmill area.  The lumber is stacked and transferred to twenty-eight (28) steam-heated batch drying kilns and two (2) steam-heated dual path drying kilns. The dried rough lumber is then shaped to the requisite thickness, width, and length within the planer mill area.  Finally, the lumber is strapped and sent to storage prior to shipment off-site.  The by-products from the sawmill (such as bark and sawdust) are used for boiler fuel, and the by-products from the planner mill (such as dried wood shavings) are routed to a truck bin for off-site shipment. 

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: particulate matter less than 10 microns (PM10), particulate matter less than 2.5 microns (PM2.5), nitrogen oxides (NOx), carbon monoxide (CO), and 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)	169.0	
PM10	117.25	
PM2.5	110.61	
Sulfur Dioxide (SO2)	7.2	
Nitrogen Oxides (NOx)	123.87	
Carbon Monoxide (CO)	132.80	
Volatile Organic Compounds (VOC)	629.44	
Total Reduced Sulfur (TRS)	---	
Lead	0.02	
CFC/HCFC	---	
Total HAP 	47.08	
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 twenty-eight (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
On September 25, 2024, VFP applied for a renewal of the Title V Operating Permit (TVOP). On May 16, 2025, the facility applied for a modification of a TVOP for the installation and operation of a new air curtain incinerator (ACI) that will reduce the volume of wood waste generated on site. The ACI (Emission Point AA-014) will have a maximum charge rate of thirteen (13) tons per hour. Combustion air will be provided by a 75 HP diesel-fired ‘nonroad’ generator engine. The following are proposed changes in the TVOP renewal:

•	Adding applicable requirements found in 40 CFR Part 60, Subpart CCCC (Standards of Performance for Commercial and Industrial Waste Incineration Units) for the disposal of wood waste, clean lumber waste, and yard waste via an ACI;

•	Limiting the annual operating hours for the ACI to 1,077 hours based on a rolling 12-month total in order to avoid PSD permitting;

•	Adding the PM emission standard applicable to an incinerator (i.e. 0.2 grains per dry standard cubic foot – calculated to 12% CO2 by volume); and

•	Adding work practice standards and routine inspections for the ACI to ensure the minimizing of emissions.

•	Adding a requirement that the generator engine associated with the ACI may not remain at the facility for more than twelve (12) consecutive months in order for the engine to be classified as a ‘nonroad’ engine as defined in 40 CFR Part 1068.30, Subpart A.

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.

The cyclone associated with the pneumatic wood waste transfer system (Emission Point AA-001) and the multi-clone for the wood waste boiler (Emission Point AA-002) are not pollution control devices.  Therefore, 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.  Since VFP is a major source of HAPs and operates thirty (30) lumber kilns, Subpart DDDD is applicable; however, the only requirement applicable to the lumber kilns is the submittal of an initial notification (which VFP has satisfied).

40 CFR Part 63, Subpart ZZZZ – NESHAP for Stationary Reciprocating Internal Combustion Engines (RICE): The provisions of Subpart ZZZZ are applicable to any facility (that is either a HAP area source or a HAP major source) that operates a stationary RICE. The proposed generator for the ACI will be portable, so the engine will be considered a ‘nonroad’ engine, as defined in 40 CFR Part 1068.30, Subpart A, provided it does not remain at the facility for more than twelve (12) consecutive months. Therefore, Subpart ZZZZ is not applicable. 

40 CFR Part 63, Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants 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.  VFP operates a 94.8 MMBTU / hour wood waste-fired boiler (Emission Point AA-002) in the “fuel cells designed to burn biomass / bio-based solid” fuel” subcategory as defined in the subpart. All applicable requirements from Subpart DDDDD have already been included in the TVOP. 

40 CFR Part 63, Subpart JJJJJJ – National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources:  This subpart affects industrial, commercial, or institutional boilers located at an area source of HAPs.  Since VFP is a major source of HAPs, Subpart JJJJJJ is not applicable. 

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR Part 60, Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units:  This subpart is applicable to any steam generating unit with maximum heat input capacity of 100 MMBTU per hour but greater than 10 MMBTU per hour that was constructed after June 9, 1989.  VFP operates one (1) wood waste-fired boiler (Emission Point AA-002) that has a maximum heat input capacity of 94.8 MMBTU per hour.  However, the boiler was installed before the applicable date of June 9, 1989 (i.e. construction commenced in November 1988).  As such, VFP is not subject to the requirements found in Subpart Dc.

VFP is authorized to operate up to two (2) temporary boilers (Emission Point AA-004) during shutdown periods for Emission Point AA-002.  Under Subpart Dc, a “temporary boiler” must comply with a SO2 emission limitation (no greater than 0.060 pounds per MMBTU) and an on-site time restriction (remaining at a location less than 180 consecutive days).  Therefore, the TVOP has a restriction on the sulfur content contained within fuel oil (i.e. no more than 500 ppm). This ensures that the operation of any boiler brought on-site (natural gas-fired or fuel oil-fired) meets the outlined definition of a “temporary boiler”.

40 CFR Part 60, Subpart CCCC – Standards of Performance for Commercial and Industrial Waste Incineration Units: The provisions of Subpart CCCC are applicable to commercial and industrial solid waste incineration unit (CISWIs) and air curtain incinerators (ACIs) (as defined by 40 CFR 60.2265) that were constructed after June 4, 2010. VFP will operate an ACI; therefore, this subpart is applicable. Subpart CCCC contains limited requirements for ACIs that burn only wood waste, clean lumber, and/or yard waste.  The ACI is subject to an opacity standard of ≤ 10%, except during startup periods which shall not exceed 35% opacity. Subpart CCCC requires an initial and annual opacity test to demonstrate compliance with the standard.

40 CFR Part 60, Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal Combustion Engines: The provisions of Subpart IIII are applicable to any stationary compression-ignition (CI) internal combustion engine (ICE) that was manufactured after July 11, 2005.  The generator engine associated with the ACI will be considered a ‘nonroad’ engine, as defined in 40 CFR Part 1068.30, Subpart A, provided it does not remain at the facility for more than twelve (12) consecutive months. Therefore, Subpart IIII is not applicable.

SPECIFIC APPLICABLE REQUIREMENTS

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-100
(Facility-Wide)	Opacity	40%	Perform Weekly Visible Emission Observations for the Cyclone (AA-001) and Boiler (AA-002)

Perform Weekly Maintenance Inspections	
	PM
(filterable)	E = 4.1(p0.67)	No Monitoring Due to the Expected Large Margin of Compliance with the Standard	
AA-002	PM	0.3 Grains / Dry Standard Cubic Feet	Use of Uncontaminated Wood Waste Ensures Compliance with the Standard	
	PM (filterable)
[or TSM]	0.02 [or 0.0058] lb. / MMBTU of Heat Input; or

0.055 [or 0.016] lb. / MMBTU of Steam Output	Conduct Performance Testing Annually [or Every 3 Years]

Maintain Operating Limits (for Operating Load)

Perform a Fuel Analysis for Maximum TSM Fuel Input	
	CO	1,100 ppmv at 3% O2; or

2.4 lb. / MMBTU of Steam Output	Conduct Performance Testing Annually [or Every 3 Years]

Operate an Oxygen Analyzer System and Maintain Operating Limits (for Operating Load and Oxygen)	
	HCl	0.022 lb. / MMBTU of Heat Input; or 

0.025 lb. / MMBTU of Steam Output	Conduct Performance Testing Annually [or Every 3 Years]

Maintain Operating Limit (Operating Load)

Monitor the Type and Amount of Fuel Combusted on a Daily Basis

Perform a Fuel Analysis for Maximum Chlorine / Mercury Fuel Input	
	Hg	0.0000057 lb. / MMBTU of Heat Input; or
.
0.0000064 lb. / MMBTU of Steam Output		
	SO2	4.8 Pounds / MMBTU	Use of Low-Sulfur Fuels (Uncontaminated Wood Waste) Ensures Compliance with the Standard	
AA-004	SO2	4.8 Pounds / MMBTU	Use of Low-Sulfur Fuel Oil and Natural Gas Ensures Compliance with These Standards

Monitor the Type and Amount of Fuel Oil on a Daily Basis	
	PM	0.6 Pounds / MMBTU; or

E = 0.8808·(I-0.1667)		
	Operational Limitation	Operate No More Than Two (2) Temporary Boilers During Periods of Shutdown for Emission Point AA-002	Comply with the ‘Temporary Boiler’ Definition of 40 CFR Part 60, Subpart Dc	
AA-014	PM
(filterable)	0.2 Grains / Dry Standard Cubic Foot (at 12% CO2 by vol.)	A Significant Margin of Compliance is Expected 	
	Opacity	≤ 35% During Start-Up Periods

≤ 10% During Operations	Conduct Routine Testing in Accordance with EPA Test Method 9 and 40 CFR Part 60, Subpart CCCC	
	Hours of Operation

(PSD Avoidance Limit)	1,077 Hours / Year (Rolling 12-Month Total)	Monitor The Monthly Hours of Operation in Which the Authorized Wastes are Incinerated	
AK-001
through
AK-028	Lumber Throughput

(PSD Avoidance Limit)	115,000.0 MBF / Year (for All Kilns Combined; Rolling 52-Week Total)	Monitor and Record Lumber Throughput 	
	Final Moisture Content	≥ 12% (52-Week Rolling Average)	Monitor and Record the Moisture Content of Dried Lumber Processed Through the Planer Mill 	
AK-029
AK-030	VOCs (as WPP1)

(PSD BACT Limit)	4.43 Pounds / MBF

363.5 tpy (Rolling 12-Month Total)	Monitor and Record Lumber Throughput 	
	Lumber Throughput

(PSD BACT Limit)	164,114.0 MBF / Year (for Combined Kilns; Rolling 12-Month Total)		
	Operational Requirement

(PSD BACT Standard)	Good Work Practices	Perform Routine Inspections and Maintenance for the Kilns