PERMIT REVIEW SUMMARY

Permit Writer:	Megan Rupp	 	

Date:			March 16, 2020

Company Name:	Pinnacle Renewable Energy, Inc., Newton MS Facility

Facility Location:	615 Coliseum Drive
			Newton, MS 39345

Source Number:	1980-00045

County: 		Newton

FACILITY DESCRIPTION

Pinnacle Renewable Energy, Inc., Newton MS Facility (herein referred to as “Pinnacle”) is proposing to construct a new wood pellet production facility.  The facility would be located in the Newton Industrial Park, adjacent to Biewer Sawmill.  Pinnacle will process wood chips, fibers, and sawdust into fuel pellets.  The facility will be designed to produce approximately 440,000 oven-dried tons (ODT) of wood pellets per year utilizing up to 100% softwood by weight.  Pinnacle is proposing a wood pellet production limit of 440,000 ODT per year, as well as other limits to ensure they remain under the Prevention of Significant Deterioration (PSD) major source thresholds.  The wood pellet manufacturing process for this proposed facility is outlined in the attached Process Flow Diagram.

Fugitive Emissions Sources (Emission Point Group AA-100)
Green and dry sawdust, shavings, bark, and wood chips will be delivered to Pinnacle via trucks. Green sawdust, bark, and wood chips are transferred (AA-103) to the green wood storage pile (AA-104).  Dry wood material will be transferred (AA-103) to a separate enclosed storage tent (AA-105).

Future operations will include the processing of whole logs.  Tree length logs will be delivered by truck and debarked (AA-101) and processed in the log chipper (AA-102).  The resulting wood chips will be stored in the green wood storage pile (AA-104).  

Wood Drying Operations (Emission Point Group AA-200)
The rotary drum dryer will be heated by a 170 MMBtu/hr wood-fired step grate furnace burner (AA-201).  Fuel bark will be delivered via truck and stored in a fuel bin and then conveyed to the step grate burner in front of the dryer.  

Green wood material is moved from the green wood storage pile to a feed bin, which will be connected to a conveyer.  The conveyer will feed the green wood from the feed bin directly to the rotary drum dryer or will be diverted to the burner fuel bin.  The dryer processes the green wood from an initial moisture content of approximately 50% to a final moisture content of 5-10%.  Exhaust from the dryer will be routed to a wet electrostatic precipitator (WESP) followed by a regenerative thermal oxidizer (RTO1) control system for the reduction of particulate matter (PM, PM10, PM2.5), volatile organic compounds (VOCs), and hazardous air pollutants (HAPs).  RTO1 is heated by a 10 MMBtu/hr natural gas-fired burner.  The WESP wastewater will go to a centrifuge where the solids are separated.  The solids will then be collected for later use as fuel for the step grate burner or will be fed into the pellet production process.

The dryer and the step grate furnace burner will each be equipped with bypass stacks.  The furnace bypass stack (AA-203) will remain closed, except during periods of furnace start-up, shutdown, and idle mode.  Diversion to the furnace bypass stack is limited to no more than 50 hours per year for periods of start-up and shutdown, and 500 hours per year for periods of idle mode.  The dryer bypass stack (AA-202) will remain closed.  Any diversion to the dryer bypass stack, for any purpose, will constitute a deviation from the Permit.

After the drying process, the dried wood material will be conveyed to the dry chip storage tent (AA-105) or will be fed directly to the pellet production process. 

Wood Pellet Production Operations (Emission Point Group AA-300)
Dried wood material is conveyed to four dry hammermills (AA-301) that process the dried material to desired size.  Particulate matter (PM, PM10, PM2.5) emissions from the hammermills are controlled by a cyclofilter baghouse.  

The pelletizing area consists of nine pellet lines and nine pellet coolers (AA-302).  The pellet lines receive dried wood materials from the dry hammermills.  In each pellet line, rollers push the material through the holes of a die plate.  Knives on the exterior of the die plate cut the wood pellets from the plate to a required length.  Wood pellets enter the cooling chamber and flow countercurrent to a stream of ambient air, thereby reducing the temperature of the pellets.  Exhaust from the pellet lines and pellet coolers will be routed to a cyclofilter baghouse followed by a regenerative thermal oxidizer (RTO2) control system for the reduction of particulate matter (PM, PM10, PM2.5), VOCs, and HAPs.  RTO2 is heated by a 10 MMBtu/hr natural gas-fired burner.

Finished Pellet Storage and Handling (Emission Point Group AA-400)
Cooled, finished wood pellets will be stored in the pellet storage silo (AA-401), which vents directly to the atmosphere. Wood pellets will be conveyed from the silo onto a truck (AA-402) for final shipment to the Pinnacle mill in Demopolis, AL.   

Emergency Engines (AA-500)
Pinnacle proposes to install five diesel-fired compression ignition emergency generator engines (AA-501 through AA-505) and one diesel fired compression ignition emergency fire pump engine (AA-506).

EMISSIONS SUMMARY

Based on the total maximum uncontrolled emissions from all on-site operations, Pinnacle would be a Prevention of Significant Deterioration (PSD) Major source 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) because each exceeds 250 tons per year (tpy).
To avoid PSD applicability, Pinnacle has proposed installing and operating various pollution control devices to reduce the potential emissions of each aforementioned pollutant below the 250 tpy PSD threshold (as shown in Table 1).

Table 1: Proposed Facility-Wide Emissions
	PM	PM10	PM2.5	SO2	NOx	CO	VOC	Lead	Total HAPs	
Maximum Uncontrolled Emissions (tpy)	1,155	1,103	1,070	18.99	110.4	170.6	1,780	18.62	101.0	
Controlled Potential Emissions (tpy)	155.6	103.2	70.59	18.99	110.4	170.6	250.0	0.036	14.90	
Controlled Potential Emissions, excluding fugitives
(tpy)	83.74	67.77	60.73	18.99	110.4	170.6	234.7	0.036	14.02	
 
APPLICABLE/PROPOSED PERMIT LIMITATIONS

The following table is a summary of emissions limitations to which Pinnacle is subject and the proposed demonstration of compliance for each limitation.  This is not a complete list of all the limitations to which Pinnacle is subject.  For a complete listing of all limitations, standards, monitoring, and recordkeeping requirements, please see the permit.

Emission Point	Applicable Requirement	Pollutant/Parameter	Limitation	Compliance Demonstration	
AA-000	11 Miss. Admin. Code Pt. 2, R. 1.3.A.	Opacity (smoke)	40%	Implement Dust Management Plan, operate and maintain control devices, utilize uncontaminated wood waste and natural gas as fuel sources.	
	11 Miss. Admin. Code Pt. 2, R. 1.3.B.	Opacity	40%		
	11 Miss. Admin. Code Pt. 2, R. 1.3.F(1).	PM	E = 4.1p0.67		
	11 Miss. Admin. Code Pt. 2, R.2.2.B(10).

MACT Avoidance Limits	HAPs	24 tpy total HAPs  (12-month rolling total)
9 tpy any individual HAP (12-month rolling total)	Perform routine stack testing, develop site-specific emission factors, monitor control devices, calculate and record HAP emissions in tons monthly, and 12-month rolling totals	

Emission Point	Applicable Requirement	Pollutant/Parameter	Limitation	Compliance Demonstration	
AA-102	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).	Green Wood Chip Throughput	1,100,000 tpy	Monitor and record the throughput of green wood chips processed in tons monthly, and 12-month rolling totals	
AA-200
AA-300
AA-400
AA-500	11 Miss. Admin. Code Pt. 2, R.2.2.B(10).

PSD Avoidance Limits	Total PM (filterable only)
PM10 (filterable + condensable)
PM2.5 (filterable + condensable)
NOx
CO
VOC	245 tpy (12-month rolling total)
For each pollutant	Perform routine stack testing, develop site-specific emission factors, monitor control devices, calculate and record emissions of each pollutant from all point-sources in tons monthly, and 12-month rolling totals	
AA-203	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).	Furnace Bypass Stack Usage Restrictions	≤ 50 hours per year during start-up and shutdown
≤ 500 hours per year during idle mode 	Monitor and record the date, time, and duration of every start-up, shutdown, and idle mode period.
Calculate and record the total duration of all start-up, shutdown, and idle mode periods in hours per year for each rolling 12-month period.	
AA-201	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).	Dried Wood Chip Throughput	440,000 ODT/yr (12-month rolling total)	Monitor and record the throughput of wood chips dried in the dryer in ODT monthly, and 12-month rolling totals.	
	11 Miss. Admin. Code Pt. 2, R. 1.4.B(1).	SO2	500 ppm	Pinnacle’s margin of compliance for this standard should be significant, since they are only allowed to utilize uncontaminated wood waste and natural gas as fuel sources.	
AA-201
AA-302	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).	VOC Control Efficiency	≥ 95% control efficiency for RTO1 and RTO2	Initial performance testing and during the test, establish minimum combustion temperatures for each RTO	

Emission Point	Applicable Requirement	Pollutant/Parameter	Limitation	Compliance Demonstration	
AA-302	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).	Wood Pellet Production	440,000 ODT (12-month rolling total)	Monitor and record the total production of wood pellets in ODT monthly, and rolling 12-month totals.	
AA-500	11 Miss. Admin. Code Pt. 2, R. 1.3.B.	PM	0.6 lb/MMBtu	Pinnacle shall easily comply with this standard by purchasing engines which are certified to meet the emissions standards in 40 CFR 60, Subpart IIII.	
	40 CFR 60.4211(c), Subpart IIII	NMHC + NOx
CO
PM (filterable)	Emission Standards in 40 CFR 60.4211(b) or (c)	Purchase engines certified to emission standards	

NSPS APPLICABILITY

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

Pinnacle has proposed installing six (6) emergency engines, all of which are compression ignition internal combustion engines manufactured after April 1, 2006.  Therefore, the engines are subject to Subpart IIII.  Each engine purchased must be certified to the emission standards given in 40 CFR 60.4211(b) or (c).

40 CFR Part 60, Subpart Kb – Standards of Performance for Volatile Organic Liquid Storage Vessels for which Construction, Reconstruction, or Modification Commenced after July 3, 1984.

Pinnacle will be installing two (2) 500-gallon above-ground diesel storage tanks.  Subpart Kb is applicable to tanks with a capacity greater than 75 m3 (approximately 19,813 gallons).  Therefore, Pinnacle is not subject to Kb.

MACT APPLICABILITY

Pinnacle’s post-control potential emissions of hazardous air pollutants are below the major source thresholds of 25 tons per year for total HAPs and 10 tpy for single HAPs.  Therefore, Pinnacle is 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 manufactured at Pinnacle 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.  Also, the facility is not a major source of HAP emissions.  Therefore, Subpart DDDD will not be applicable.

40 CFR 63, Subpart ZZZZ – National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

Pinnacle has proposed installing six (6) emergency engines, all of which are stationary RICE.  Therefore, the engines are subject to Subpart ZZZZ.  However, by complying with the applicable requirements of 40 CFR Part 60, Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, Pinnacle is deemed to be in compliance with Subpart ZZZZ.

PUBLIC PARTICIPATION

The 30-day public notice period began on March 25, 2020, with the publication of a notice in the Newton County Appeal and ends April 24, 2020.

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.