Title: afgafgasdgfsd
Author: Aubrey R. Jones
Last saved by: Ryan Ozment

Permit Review Summary
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PERMIT REVIEW SUMMARY
Permit Writer:	Ryan Ozment 			Date:	February 8, 2019
Company Name:	Enviva Port of Pascagoula LLC
Facility Location:	East Bank Facility
Source Number:	1280-00148
County: 		Jackson
PROJECT DESCRIPTION
Enviva Port of Pascagoula is proposing to construct a greenfield wood pellet loading and storage facility at the Port of Pascagoula in Jackson County.  The proposed terminal will receive pellets via truck, barge, and rail for storage and shipment overseas.  Emission sources located at the site will include the truck and rail receiving system, barge unloading operations, two (2) pellet storage domes, five (5) engines, and a series of conveyor systems controlled by baghouses.  
SYNTHETIC MINOR LIMITATIONS
Enviva’s potential-to-emit for particulate matter (PM) and carbon monoxide (CO) surpass the PSD and Title V thresholds; however, the facility has proposed operational limitations to control emissions to below 100 tons per year (see table below).  The facility will also be classified as a minor source in respect to hazardous air pollutant (HAP) emissions.

Pollutant

Uncontrolled Emissions
(tons/year)

Controlled Emissions
(tons/year)

PM | 5,103 | 65.7
SO_2 | 0.025 | 0.014
NO_X | 6.59 | 4.86
CO | 106.8 | 91.7
VOC | 31.6 | 30.8
Particulate matter is generated by the transfer of the wood pellets by the conveyor system.  Each transfer system is controlled by a baghouse.  The facility will be required to operate and maintain these baghouses while also performing weekly visual emission evaluations and daily pressure drop monitoring.  Similar baghouses operated by Enviva in other states have not been required to stack test due to the stack diameter.  Upon completion of construction, Enviva will need to assess and report if it is feasible to test these stacks and, if it is infeasible, why.
Carbon monoxide is generated by the engines located on site.  Three (3) of the engines on-site are non-emergency, compression ignition engines, and will have annual hours-of-operation limits of 4,928 hrs/yr to limit CO emissions below the Title V threshold.  The facility will install non-resettable hour meters on the engines to ensure compliance with the hours of operation limit.   
Facility Wide:
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10)
o	PM emissions limited to less than 99.0 tons/year
o	CO emissions limited to less than 99.0 tons/year
o	Operate efficiently and perform routine maintenance
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11)
o	Calculate annual PM emissions for each consecutive 12 months
o	Submit an annual report
o	Develop, maintain, and implement a “Dust Management Plan” for minimizing emissions of fugitive particulate matter
o	Record pellet throughput and fuel usage at the facility
•	11 Miss. Admin. Code Pt. 2, R. 1.3.A & B
o	Opacity and equivalent opacity limits of 40%
•	11 Miss. Admin. Code Pt. 2, R. 2.9
o	Maintain all records for five years from date generated
Each Baghouse (13 total)
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10)
o	Operate baghouses when material is transferred
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11)
o	Conduct visual emission evaluations on a weekly basis
o	Conduct inspection and maintenance of the ductwork and collection units monthly and annual inspection of bag filters
o	Monitor and record pressure drop daily and take corrective action when necessary
o	Maintain vendor maintenance specifications and spare parts needed to repair and maintain the baghouse in case of malfunction or failure
o	Upon completion of construction, determine if stack testing is infeasible for each baghouse (i.e. stack diameter too small).  If so, report findings to MDEQ.  If not, follow stack testing procedures outlined in permit.
Non-Emergency Engines (AA-017, AA-018, and AA-019)
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10)
o	Each engine is limited to 4,928 hours per year (maintain CO emissions to below Title V thresholds)
•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(11)
o	Monitor hours of operation by installing and maintaining non-resettable hour meter
All Engines (AA-015, AA-016, AA-017, AA-018, and AA-019)
•	11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(a)
o	PM emissions limited to less than 0.6 pounds per million BTU per hour heat input
While the facility will be performing weekly visual emissions testing as mandated by the permit, the facility (not required by the permit) will also be performing daily visual observations to ensure the baghouses are operating properly.
MACT LIMITATIONS
40 CFR 63, Subpart ZZZZ (National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines):  this subpart applies to reciprocating internal combustion engines located at major or area sources of HAP emissions; therefore, this subpart applies to all engines.  The engines will meet all requirements of Subpart ZZZZ by complying with the requirements of 40 CFR 60, Subpart IIII.
NSPS LIMITATION
40 CFR 60, Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines):  this subpart applies to compression ignition internal combustion engines manufactured after 2006; therefore, this subpart applies to all engines.  The permittee will be required to purchase certified engines and will meet the emissions standards in Subpart IIII by doing so.  The two emergency engines (AA-015 and AA-016) shall only be operated for emergency situations, maintenance and readiness checks, emergency demand response, and operation in non-emergency situations not to exceed 50 hours per year.  The facility will install non-resettable hour meters on the two emergency engines and record the reason they were in operation.
PUBLIC PARTICIPATION
The 30-day public notice period began on February 27, 2019, with the publication of a notice in The Mississippi Press and ends March 29, 2019.
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.

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