INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
August 2, 2022

GENERAL FACILITY INFORMATION
Facility Name:  Renewable Wood Solutions, LLC
Facility Address:  State-Wide
P.O. Box 233
Crystal Springs, MS
County: State-Wide
SIC Code(s): 4953, Refuse Systems
NAICS Code(s): 562213, Solid Waste Combustors and Incinerators

APPLICATION SUMMARY 
Permit No.: 0600-00076
Permit Action: Initial Issuance
Permit Folder: PER20210002
Application Receipt Date: 10/14/2021
Application Deemed Complete: 
CBI Submitted?: No	NSPS (Part 60): Subpart CCCC 
NESHAP (Part 61): N/A
NESHAP (Part 63): N/A
112(r) / RMP: N/A
Other: State-Wide Permit	

FACILITY DESCRIPTION
Renewable Wood Solutions, LLC (RWS) proposes to operate one or more portable air curtain incinerators (ACIs) across the State of Mississippi for purposes of reducing wood waste at permitted solid waste management facilities, as well as at locations RWS harvests purchased timber. The remaining ash produced following combustion will be stored and managed by RWS. Operation of the ACIs will fall under the Standard Industrial Classification (SIC) code of 4953 for “Refuse Systems” and NAICS code 562213 for “Solid Waste Combustors and Incinerators.” 

The ACIs are equipped with a firebox, which will be loaded with wood waste. The wood waste is ignited and a fan powered by a diesel engine blows a curtain of air across the top of the waste such that the air circulates within the firebox to promote more complete combustion and minimize smoke. The ash is routinely removed once it reaches a certain height in the firebox. The sketch on the following page depicts the ACI design.

In order to comply with federal regulations for ACIs, the ACIs will only be allowed to burn (1) wood waste, (2) clean lumber, or (3) yard waste, or a combination of these three waste streams. Each term is defined in the proposed permit. 11 Miss. Admin. Code Pt. 2, R. 2.1.D(5). allows the Mississippi Department of Environmental Quality (MDEQ) to issue a state-wide permit for portable facilities that will be located only temporarily at a site or sites throughout the state. Therefore, the proposed Permit to Construct addresses installation of one or more ACIs on a temporary basis at specified locations across the state. The Permit to Construct does not address and is not intended to limit operation of the ACIs for purposes of combusting debris generated from a declared disaster or emergency as long as operation is in accordance with all applicable State and Federal regulations.

11 Miss. Admin. Code Pt. 2, R. 6.3.E. of the Title V regulations allows the Permit Board to issue a single Title V Operating Permit (TVOP) authorizing emissions from similar operations by the same source owner or operator at multiple temporary locations. The operation must involve at least one change of location during the term of the permit to qualify as temporary. The proposed Permit to Construct limits each ACI to 12 consecutive months at any single location, which will be incorporated into the TVOP.

Source: Air Burners Inc. (https://airburners.com/resource-center/sketches/)   

TITLE V SOURCE APPLICABILITY 
Based on the limits proposed in the Permit to Construct, 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: Carbon Monoxide (CO), Particulate Matter less than 10 microns (PM10), and Particulate Matter less than 2.5 microns (PM2.5). The facility’s potential-to-emit hazardous air pollutants (HAPs) does not exceed the Title V major source threshold of 25 tpy of total HAPs or 10 tpy for any individual HAP. Additionally, the federal regulations applicable to the ACIs (i.e., 40 CFR Part 60, Subpart CCCC) require the owner/operator maintain a TVOP for the ACIs. Therefore, a TVOP is being proposed for issuance concurrently with the Permit to Construct.
Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions
(tons/yr)	
Particulate Matter (TSP), including PM10 and PM2.5	117.03	
Sulfur Dioxide (SO2)	8.75	
Nitrogen Oxides (NOx)	87.5	
Carbon Monoxide (CO)	227.5	
Volatile Organic Compounds (VOC)	78.75	
Total HAP 	9.78	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.
PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
RWS is not considered one of the 28 categorical facilities listed in 40 CFR 52.21(b)(1)(i)(a); therefore, the Prevention of Significant Deterioration (PSD) threshold for a major source is 250 tons per year (tpy). Since emissions may occur simultaneously from one or more ACIs located at one or more solid waste management facilities across the state, potential emissions were evaluated as the sum of emissions from all ACIs operated by RWS state-wide. This results in a conservative evaluation of potential emissions. With no restrictions on throughput, RWS has the potential to emit more than 250 tpy of carbon monoxide, a regulated NSR pollutant. 

To ensure RWS does not exceed this PSD major source threshold, the proposed Permit to Construct limits the annual total wood waste combusted to 175,000 tons per year and requires each ACI be guaranteed by the manufacturer to meet those emission factors represented in the permit application. The emission factors are also incorporated as limits in the proposed Permit to Construct. As a result, RWS will be considered a moderate stationary source under 11 Miss. Admin. Code Pt. 2, Ch. 2., and the proposed limits will be incorporated in the TVOP.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
This permit action addresses the initial issuance of the TVOP, which coincides with initial issuance of the Permit to Construct for the facility; therefore, there are no modifications or permit changes to evaluate.

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.

CAM does not apply to the facility because no control devices are used to comply with the emission limits in the permit. 

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
RWS is considered an area source of hazardous air pollutants (HAPs). Therefore, only NESHAP applicable to area sources were evaluated. There were no NESHAP identified as potentially applicable to the ACI. With regards to the diesel-fired engines associated with the ACIs, these engines will not be considered “stationary reciprocating internal combustion engines (RICE)” under the NESHAP for Stationary RICE in 40 CFR Part 63, Subpart ZZZZ, because they will meet the definition of a “nonroad engine” in 40 CFR 1068.30.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
Standards of Performance for Commercial and Industrial Solid Waste Incineration (CISWI) Units – 40 CFR Part 60, Subpart CCCC
Because the ACIs would be operated by a commercial entity at solid waste management facilities receiving municipal, commercial, and/or industrial solid waste, the ACIs were determined to be CISWI units. The permit requires the permittee only operate an ACI for which construction commenced after June 4, 2010, or reconstruction or modification commenced after August 7, 2013. (See Permit Condition 3.7.) Therefore, each ACI will be considered a new incineration unit subject to Standards of Performance for Commercial and Industrial Solid Waste Incineration (CISWI) Units in 40 CFR Part 60, Subpart CCCC. Subpart CCCC contains limited requirements for ACIs that burn only wood waste, clean lumber, and/or yard waste. “Wood waste” and “clean lumber” are defined in Subpart CCCC. “Yard waste” is defined in the similar NSPS Subpart EEEE and incorporated for clarity. 

Under Subpart CCCC, each 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. The permit clarifies that such tests should occur during normal operations when the 10% standard applies, rather than during startups. This clarification is consistent with 40 CFR 60.8(c) requiring tests be conducted under “representative conditions.” 

Standards of Performance for Small Municipal Waste Combustion Units – 40 CFR Part 60, Subpart AAAAA
Although the ACIs will operate at sites that may accept municipal solid waste, the ACIs are not considered municipal solid waste incinerators under the Standards of Performance for Municipal Waste Combustion Units in 40 CFR Part 60, Subpart AAAA. The definition of “municipal solid waste” in 40 CFR 60.1465 does not include clean wood or wood waste, as defined in Subpart CCCC; therefore, the ACIs are not considered small municipal waste combustion units under Subpart AAAA.

Standards of Performance for Other Solid Waste Incineration (OSWI) Units – 40 CFR Part 60, Subpart EEEE
The Standards of Performance for Other Solid Waste Incineration (OSWI) Units in 40 CFR Part 60, Subpart EEEE were also evaluated. Because operation of the ACIs will only take place at permitted solid waste management facilities and will not combust waste produced by RWS, the ACIs may be classified as OSWI units per 40 CFR 60.2888. However, since the proposed ACIs may burn up to 13 tons per hour of wood waste, clean lumber, and/or yard waste, they would not fall under the 35 ton per day threshold specified in Subpart EEEE. Therefore, Subpart EEEE does not apply to the proposed ACIs. 

Standards of Performance for Compression Ignition Internal Combustion Engines – 40 CFR Part 60, Subpart IIII
The only other potentially applicable NSPS is related to operation of the diesel-fired engines mounted with the ACI, which may be addressed under the Standards of Performance for Compression Ignition Internal Combustion Engines in 40 CFR Part 60, Subpart IIII. However, as specifically addressed in the permit, each engine shall meet the definition of a “nonroad engine” in 40 CFR 1068.30, since it may not remain at the same location for more than 12 consecutive months. Therefore, the engines are not subject to Subpart IIII per the definition of “stationary internal combustion engine” in 40 CFR 60.4219.  
   
SPECIFIC APPLICABLE REQUIREMENTS

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
State-Wide	Location	Locate ACI at permitted solid waste disposal facilities or locations where RWS harvests purchased timber	Notify DEQ 10 days prior to locating/relocating an ACI, including date of installation and startup; ACI manufacturer, model number, and unique ID; maximum capacity of ACI; name, physical address and owner/operator at the location; and a map showing proposed location of ACI and nearby building and property boundary. 	
	Buffer Zone Criteria	150 feet		
AA-001	Annual Waste Combusted	≤ 175,000 tons per year	Use the maximum capacity of each ACI (tons/hr) and hours of operation of each ACI to determine the monthly and 12-month rolling total waste combusted in all ACIs.	
	Hours of Operation	Sunrise to 6:00 p.m.	For each ACI, maintain a log of the date and start and stop time, as well as total hours of operation for the day and for each calendar month.	
	PM, NOx, CO, and VOC	PM ≤ 1.3 lb/ton
NOx ≤ 1.0 lb/ton
CO ≤ 2.6 lb/ton
VOC ≤ 0.9 lb/ton	Maintain a record of the manufacturer’s guarantee for the ACI model in operation.	
	Location	No more than 12 months at any one location	Notify DEQ 10 days prior to locating/relocating the ACI. 	
	Opacity	≤ 10%, not to exceed 35% during startup	Conduct an initial 3-hour EPA Method 9 opacity test, followed by an annual test within 12 months of the previous test.	
	Waste Restriction	Only burn wood waste, clean lumber, and/or yard waste	Inherent to operation of the ACI and production of an ash that can be beneficially used.	
	Operation and Maintenance	Operate and maintain according to manufacturer’s instructions	Maintain a copy of the manufacturer’s instructions, ensuring it is accessible by the operator of the ACI.	
	Operating Criteria	No combustible material within 100 feet and comply with setbacks for higher wind speeds	Compliance with manufacturer’s instructions and include in the ACI log the wind speed and direction when the ACI starts up and shuts down.	
	Prohibited accelerants	Clean oils and no highly combustible accelerants	Note the accelerant used in the ACI log. 	
AA-002	Ash Handling	Work practice standards	Record location and date ash is first generated at each location and the date it is removed.