PERMIT REVIEW SUMMARY

Permit Writer:	Ivelina Pilgrim			Date:	October 1, 2019

Company Name:	Alternative Energy Development Copiah LLC
Facility Location:	19120 Highway 51 South, Hazlehurst, MS 
Source Number:	0600-00075
County: 		Copiah

FACILITY AND PROJECT DESCRIPTION
Alternative Energy Development Copiah LLC is requesting an air construction permit for the construction of a greenfield wood pellet production facility (SIC 2499) in Hazlehurst, MS, Copiah County. The facility will be designed to produce approximately 473,040 oven-dried tons (ODT) of wood pellets per year utilizing up to eighty-five percent (85%) softwood by weight. The wood pellet manufacturing process for this proposed facility is outlined in the attached process flow diagram. 

Timber logs (both softwood and hardwood) will be debarked (Emission Point AA-002) and processed in the log chippers (Emission Point AA-003). The exhaust from the chippers will be routed to a wet electrostatic precipitator (WESP) followed by a regenerative thermal oxidizer (RTO) control system (Emission Point AA-008). The green wood chips will be stored in a storage bunkers (Emission Point AA-001) until they are screened and fed directly to a rotary drum dryer (Emission Point AA-008a). The green wood chips are routed to a screener (Emission Point AA-005) prior to drying, and any oversized wood chips (greater than 3/8”) will be transferred to the oversized chipper (Emission Point AA-006) for further processing before being fed to the dryer. The facility estimates that no more than 20% of all green chips produced will be routed to the oversize chipper. However, the potential emissions for the oversized chipper (Emission Point AA-006) were based on the whole throughput of green chips.
Once the chips have been sized, they are routed to the rotary drum dryer (Emission Point AA-008a). The exhaust from the dryer will be routed to two cyclones for product recovery and then to a wet electrostatic precipitator (WESP) followed by a regenerative thermal oxidizer (RTO) control system (Emission Point AA-008) for the reduction of particulate matter (PM, PM10, and PM2.5), volatile organic compounds (VOCs), and hazardous air pollutants (HAPs). 

The dried wood chips will be transferred to a dried wood chip bin, then six dry hammer mills (Emission Point AA-009) and then to a ground chip feed bin before being fed to twelve pelletizers (Emission Point AA-010). Exhaust from the dried wood chip bin is routed to the air plant baghouse (Emission Point AA-011).  Within the pelletizers, pressure is exerted onto the wood fibers to force them to create the pellet. As a result of the exerted pressure, heat is generated causing the naturally occurring resins within the wood to act as a binding agent. Exhaust from the 12 pelletizers will also be routed to the WESP/RTO combination (Emission Point AA-008) for control of emissions. The pellets will be transferred to two pellet coolers (Emission Point AA-010) where they will solidify. The exhaust from the hammer mills (AA-009) and pelletizers and pellet coolers (Emission Point AA-010) will be routed to the WESP/RTO control system, as these process units emit a significant quantity of PM, VOCs, and HAPs. The final product will be stored in eight pellet silos (Emission Point AA-012) for transportation off-site. Emissions from the storage silos are routed to a baghouse (Emission Point AA-013).

During periods when the dryer (AA-008a) and dryer furnace must undergo a start-up or shutdown period, the gaseous stream will be diverted to a dedicated furnace bypass stack (AA-008b) and a dryer bypass stack (AA-008c) instead of the pollution control system. However, the hours in which AED may divert the gaseous stream to the bypass stacks will be limited to a total of hundred (100) hours per year.

    
PROPOSED EMISSIONS SUMMARY
Based on the total maximum uncontrolled emissions from all on-site operations, AED would have emissions above the Prevention of Significant Deterioration (PSD) Major source threshold for total particulate matter (PM), PM less than 10 microns (µm) in diameter (PM10), PM less than 2.5 µm in diameter (PM2.5) and volatile organic compounds (VOCs).  However, AED has requested operational and emission limits for these pollutants to reduce emissions below the PSD threshold and therefore will not be subject to the PSD permitting regulations. 

AED has proposed installing and operating various pollution control devices i.e. regenerative thermal oxidizers (RTOs); wet electrostatic precipitators (WESPs); and baghouses to reduce the actual emission of each aforementioned pollutant below 250 tpy (as shown in Table 1).

These emission control devices will also reduce the emissions of hazardous air pollutants below major source threshold of 25 tons per year for combined HAPs and 10 tons per year for individual HAPs.  AED will have federally enforceable limits restricting the HAPs to 9.0 tpy of an individual HAP and 24.0 of all HAPs combined emission limitations; therefore, AED will be classified as an area source of HAPs. 

Table 1: Proposed Facility-Wide Emissions

	PM	PM10	PM2.5	SO2	NOX	CO	VOC	Lead	Total HAPs	
Maximum Uncontrolled Emissions (tpy)	1316	1239	629	16	138	207	2009	0.03	231	
Controlled Emissions (tpy)	79	68	43	16	138	40	217	0.002	17	

A facility-wide emission limit of 245.0 tpy (based on rolling 12-month period) will be imposed for PM, PM10, PM2.5, and VOCs (i.e. PSD Avoidance Limits). Additionally, given the variability in NOX and CO emissions that can be generated from the operation of the RTO, a facility-wide limit of 245.0 tpy will also be imposed on these pollutants for PSD-avoidance purposes.

To reinforce the imposed PSD avoidance limitations for the noted pollutants, additional restrictions have been incorporated into the permit:

•	The throughput rates proposed for the green wood chips processed by the Green Wood Chip Screening (AA-005) and Oversized Green Wood Chipping (AA-006); the wood chips dried by the rotary drum dryer (AA-008a), and wood pellet production (AA-010) have been incorporated in the permit as limitations based on a rolling 12-month period (synonymous with the avoidance limitations).

•	A limit of 10% for the final moisture content of dried wood chips produced by the rotary drum dryer has been incorporated.

•	The draft permit proposes to limit the emissions of VOCs to 245 tpy using the RTO (connected to the wood drying and pellet production). The RTO will be operated to a performance standard of 95% control efficiency based on VOC control.

•	The draft permit proposes to limit the emissions of HAPs to 9.0 tpy of individual HAP or 24.0 tpy of all HAPs combined using the RTO (connected to the wood drying and pellet production). The RTO will be operated to a performance standard of 95% control efficiency of HAPs, measured as VOCs.

•	In addition to operating in accordance with the performance standards, the WESP/RTO control system (AA-008) will be tested to establish site-specific emission factors for PM, PM10, PM2.5, VOCs, NOx, CO and HAPs (methanol, acetaldehyde, formaldehyde and acrolein). These emission factors will be developed in terms of pounds per oven-dried ton of material produced and will be used to determine compliance with the PSD avoidance limits. The facility will use test performance data and vendor-guaranteed control efficiencies for the WESP and RTO to develop site-specific emission factors for the uncontrolled emissions of PM, PM10, PM2.5, VOCs, and HAPs (methanol, acetaldehyde, formaldehyde and acrolein) for the Rotary Dryer Bypass Stack (AA-008c).

REGULATORY APPLICABILITY

11 MISSISSIPPI ADMINISTRATIVE CODE PART 2, CHAPTER 1

Particulate Matter (PM)

•	Process Weight Equation [11 Miss. Admin. Code Pt. 2, R.1.3.F.(1).)]

•	The facility has proposed installing process units that can potentially emit significant quantities of PM (based on maximum uncontrolled emissions); hence, the emission rate limitation, as specified by the Process Weight Equation (in pounds per hour), has been applied to the entire facility in order to encapsulate all applicable sources. 

•	Fossil Fuel Burning [11 Miss. Admin. Code Pt. 2, R. 1.3.D.(1)(a).]

•	The RTO will utilize natural gas as a fuel source and will have a heat input rate of less than ten (10) million BTU (MMBTU) per hour; hence it is subject to the ash / PM limitation for fossil fuel burning process unit (i.e. 0.6 pounds PM per MMBTU).

Sulfur Dioxide (SO2)

•	Fuel Burning [11 Miss. Admin. Code Pt. 2, R. 1.4.A.(1). and 11 Miss. Admin. Code Pt. 2, R. 1.4.B.(1).]

•	The facility has proposed installing process units that were manufactured after January 25, 1972 and have the potential to emit gases that contain SO2, the common emission rate limitation (i.e. 500 parts per million SO2 by volume) has been applied to the entire facility in order to encapsulate all applicable emission sources facility-wide.

MACT APPLICABILITY

As illustrated in Table 1, AED will emit less than 25 tons per year of hazardous air pollutants (HAPs) post-control.  Therefore, the facility will be considered an area source of HAPs.

40 CFR Part 63, Subpart DDDD – National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products

•	The wood pellets will not meet the definition of an engineered wood product in 40 CFR 63.2292 because they will not be bound together by resin or another chemical agent. Therefore, 40 CFR Part 63, Subpart DDDD will not be applicable.

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

•	The facility will not operate any RICE, therefore 40 CFR Part 63, Subpart ZZZZ will not apply.
The facility will not be subject to any National Emission Standards for Hazardous Air Pollutants. 

NSPS APPLICABILITY

40 CFR Part 60, Subpart Db - Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units

The Wood Chip Dryer (AA-008) will not generate steam. Therefore, 40 CFR Part 60, Subpart Db will not be applicable. 

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

•	The facility will not operate any engines in this category, therefore 40 CFR Part 60, Subpart IIII will not apply.

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

•	The facility will not operate any engines in this category, therefore 40 CFR Part 60, Subpart JJJJ will not apply.

The facility will not be subject to any New Source Performance Standards. 

PERMIT LIMITATIONS & PROPOSED MONITORING REQUIREMENTS

Emission 
Point	Pollutant(s) /
Parameter(s)	Applicable Requirement(s)	Limitation(s) / Standard(s)	Monitoring Requirement(s)	
AA-000	Opacity	11 Miss. Admin. Code Pt. 2, R. 1.3.A.

11 Miss. Admin. Code Pt. 2. R. 1.3.B.	 ≤ 40%	Maintain compliance by adhering to a Dust Management Plan, operating and maintaining control devices (i.e. WESP, RTO and Baghouses) and utilizing uncontaminated wood waste and natural gas as the main fuel sources.	
	PM 	11 Miss. Admin. Code Pt. 2, R.1.3.F.(1).	
E = 4.1 p0.67		
	SO2	11 Miss. Admin. Code Pt. 2, R.1.3.F.(1).	500 parts per million (by volume)	The margin of compliance for this standard should be significant, since the facility is only allowed to utilize uncontaminated wood waste and natural gas as the main fuel sources.	
	PM
(filterable only)
PM10 / PM2.5
(filterable + condensable)
NOX  
CO 
VOCs 	

11 Miss. Admin. Code Pt. 2, R. 2.2.B.(10).

PSD Avoidance Limit	
245.0 tpy 

(Rolling 12-Month Period)
(For Each Pollutant)	Calculate and record the emission of each pollutant from all applicable emission sources in tons both monthly and on a rolling 12-month period.	

HAPs	
11 Miss. Admin. Code Pt. 2, R. 2.2.B.(10).
	
24.0 tpy / 9.0 tpy                              
(Rolling 12-Month Period)	Calculate and record HAP emissions from all applicable emission sources in tons both monthly and on a rolling 12-month period.	

AA-005 AA-006	Green Wood Chip Throughput	
11 Miss. Admin. Code Pt. 2, R. 2.2.B.(10).	
473,040 ODT / Year (Rolling 12-Month Period)	Monitor and record the throughput of green wood chips processed in oven-dried tons (ODT) both monthly and on a rolling 12-month period.	
	Softwood Usage Restriction	
11 Miss. Admin. Code Pt. 2, R. 2.2.B.(10).	
≤ 85% Softwood Processed 
(by Weight)	Monitor and record the quantity of softwood and hardwood used as a feedstock in short-tons both monthly and on a rolling 12-month period.	

AA-006	Green Wood Chip Throughput	
11 Miss. Admin. Code Pt. 2, R. 2.2.B.(10).	
94,608 ODT/ Year (Rolling 12-Month Period)	Monitor and record the throughput of green wood chips processed in oven-dried tons (ODT) both monthly and on a rolling 12-month period.	

AA-008a

	Dried Wood Chip Throughput	
11 Miss. Admin. Code Pt. 2, R. 2.2.B.(10).	
473,040 ODT / Year (Rolling 12-Month Period)	Monitor and record the throughput of wood chips dried by the dryer in ODT both monthly and on a rolling 12-month period.	
	VOCs	
11 Miss. Admin. Code Pt. 2, R. 2.2.B.(10).	10% or Greater Final Moisture Content 
(Dried Wood Chips)
(Monthly Average)	Monitor the moisture content of all dried wood chips daily and on a monthly average.	

AA-008b AA-008c	

PM / PM10 / PM2.5
NOX                                CO                     VOCs	

11 Miss. Admin. Code Pt. 2, R. 2.2.B.(10).	

Start-Up and Shutdown Requirements: Bypass Emissions for ≤ 100 Hours Total from Each Furnace

Idle Mode Requirements:
Bypass Emissions for ≤ 500 Hours from Each Furnace	Monitor and record the date, time, and duration of every start-up, shutdown, and idle mode period experienced by the furnace.
Calculate and record the total duration of all start-up / shutdown periods and all idle mode periods in hours per year based on a rolling 12-month period.
Monitor and record the number of fuel pushes that occur during idle mode on a 3-hour block average.	

AA-008 	

HAPs	

11 Miss. Admin. Code Pt. 2, R. 2.2.B.(10).

11 Miss. Admin. Code Pt. 2, R. 1.8.A. and C.	

95% Control Efficiency
(RTO), measured as VOCs	Demonstrate initial compliance with the specified control efficiency by conducting an initial performance test.
During the initial performance testing, the facility must establish operational ranges for specific parameters (WESP – secondary voltage; RTO – minimum combustion chamber temperature) that correspond to the required control efficiency.
  Thereafter, continuous compliance shall be demonstrated by each noted parameter on a 3-hour block average.	

AA-010	Wood Pellet Production	
11 Miss. Admin. Code Pt. 2, R. 2.2.B.(10).	
473,040 ODT / Year (Rolling 12-Month Period)	Monitor and record the total production of wood pellets in ODT both monthly and on a rolling 12-month period.	

PUBLIC PARTICIPATION
The initial 30-day public commenting period begins on October 9, 2019 and ends on November 8, 2019 with a copy of the notice being published in the Copiah County Courier. However, as significant public interest has been expressed towards the draft air construction permit, a public hearing will be held at 7:00 p.m. on November 12, 2019 at the Copiah County Community Safe Room (located on 1060 Epps Ln.) in Gallman, Mississippi.  

A copy of the public hearing notice will be published in the Copiah County Courier on October 9, 2019.  Moreover, to coincide with the public hearing to be held, the public commenting period will also be extended until November 12, 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.