NARRATIVE. Manny Patel Ginger Payment DATE: June 15, 2015

Transcription

1 Georgia Department of Natural Resources Environmental Protection Division Air Protection Branch 4244 International Parkway Suite 120 Atlanta Georgia / Fax: 404/ Judson H. Turner, Director NARRATIVE TO: FROM: Manny Patel Ginger Payment DATE: June 15, 2015 Facility Name: LJR Forest Products AIRS No.: Location: Swainsboro, GA (Emanuel County) Application #: Date of Application: August 1, 2014 Background Information LJR Forest Products is an existing facility located at 1377 Old Nunez Road in Swainsboro (Emanuel County). The facility is wood pellet plant which was permitted with Permit No E-02-0 on September 12, Wet chips will be unloaded from trailers onto a chip storage pad (CSP). Chips will be moved from the chip storage pad by front end loader to a chain feed hopper (WH). Chips will convey by enclosed belt conveyor to a covered vibrating screener (SCW) to remove any gross overs. Acceptable chips will convey by enclosed belt to a Hammermill (HMW) which will reduce the chips to a dryable flake size. The flakes will convey by enclosed belt from the Hammermill to a rotary feeder in the Dryer (DY1) which is fed by a direct fired suspension burner utilizing dry pine fines. A portion of the exhaust gas is recycled back to the dryer inlet. The dried flakes will be separated from the air stream by dual cyclones (CY1) and dropped through the rotary air locks to enclosed conveyors which transfer the dried flakes to a chain feed hopper (DH1) or the warehouse storage pad (DSP) to be moved as needed. The dry flakes will be conveyed from the dry hopper on an enclosed belt to an enclosed vibrating screening conveyor. Fines will be removed and conveyed to a fuel bin for the burner. The remaining dry flakes will convey directly into a Hammermill (HMD) to be ground into pellet furnish. Pellet furnish convey via air from Hammermill to Pellet Mill surge bin through cyclone separators. The Hammermill air lift system pulls air from the dry hopper out feed to the cyclone. The air from the cyclone will discharge into a baghouse filter. Air from the clean air side of the baghouse will duct into the burner as combustion air and to control emissions. Because all of the air cannot be used as combustion air, a portion of this air is vented to the atmosphere via Stack B. The surge bin holding the dry pellets furnish has two out feed conveyor systems. Each out feed supplies an individual Pellet Mill. From the Pellet Mill surge bin, pellet furnish is conveyed via enclosed augers to the individual pellet machine. Pellets from each pellet machine are conveyed on a belt conveyor to the pellet cooler (CO1). Cooled pellets are discharged to a belt conveyor which takes the pellets to an aspirator (ASP). The aspirator is used to remove dust and fines from the acceptable pellets. The acceptable pellets are dropped from the aspirator directly into trailers for delivery. The cooler uses ambient air pulled over the pellets by an induction fan. This air is pulled through a cyclone (CYC) with rotary airlock. The clean air side of the cyclone discharges to a baghouse (). The clean air side of the baghouse ducts to the burner as combustion air and to control emissions.

2 Rejects and/or fines collected in any cyclone or baghouse are delivered into an air system through rotary airlocks at the bottom of each unit. These collections are blown to the cyclone (CYR) located in the warehouse over the dry shavings pad. These materials upon entering the dry shavings pad will be recycled back to the pellet machines. Purpose of Application Application No was submitted on August 1, 2015 and was received by the Division on August 27, 2015 to request the construction and operation of a third Pellet Mill (PM3). The application was placed on hold pending the completion of performance tests which have currently been completed. A pubic advisory (PA0914-1) was issued on September 1, 2014 and expired on October 3, A revised application was received on June 1, 2015 and included updated emissions based on the emission factors determined during performance tests. Updated Equipment List Source Code BU1/DY1 Emission Units Description /Dryer (50 MMBtu/hr wood burner, 12 diameter x 70 triple pass rotary drum Dryer) Installation Date Associated Control Devices Source Code Description Stack ID August 2013 CY1 Cyclone STA HMD Hammermill (Bliss Model E-4460-TFA) / 350 hp mill April 2013 BU1 PM1 Pellet Mill 1 (Bliss Model 200B-141) / 500hp mill April PM2 Pellet Mill 2 (Bliss Model 200B-141) / 500hp mill August PM3 Pellet Mill 3 (Bliss Model 200B-141) / 500hp mill March 2014* CO1 ASP Pellet Cooler (Bliss Model A) / cool 10 tons of Pellets per hour to ambient temperature Aspirator (Kice Model 4E36) / removes the fines from cooled Pellets April 2013 April 2013 CYR BU1 CYR Cyclone Cyclone SCD Screening Conveyor April Fugitive APU Air Power Unit April Fugitive DSP Dry Shavings Pad (storage) April Fugitive DH Dry Hopper April Fugitive LOS Load Out Handling April Fugitive *proposed within current application The (BU1) also controls emissions from the Hammermill (HMD), Pellet Cooler (CO1), and the Aspirator (ASP) with the exhaust of these sources being ducted into the. Page 2

3 Emissions Summary The potential and actual emissions before modification emissions shown the following table had been calculated for Application No This application used AP-42 emissions factors as advised by the Division for the /Dryer emission factors. The Hammermill, the Pellet Mills with the Cooler and the Storage/Handling emission factors were based on Division approved emission factors that were established during tests at wood pellet facilities located in Georgia. The potential and actual emissions after modification were calculated using the emission factors determined from performance tests for the Dryer. The Hammermill, the Pellet Mills with the Cooler and the Storage/Handling emission factors are based on Division approved emission factors that were established during tests at wood Pellet facilities located in Georgia. The Pellet Cooler does not have steam injection; therefore, the emission factors use the applicable emission factors. The VOC/HAP emissions from Storage/Handling will not be vented to the /Dryer and will not have any controls. The PM emissions from the baghouses include 99.9% control efficiency. Cyclone CY1 for the /Dryer estimates 95% control efficiency. The Division calculated the VOC emissions from Stack V ( which includes the Pellet Cooler and Hammermill exhaust) using AP-42 emission factors, the design capacity of the equipment and a ratio of the Dryer combustion air to the air flow. The airflow ration was used because part of this line is exhausted and the remainder is recycled back to the. The VOC emissions from Stack A (STA) are based on emission factors determined during performance tests. The VOC emissions from Stack B () are based on AP-42 emission factors and the design capacity of the equipment. Because the calculations used different emission factors for the /Dryer, the emission change shown the following table does not represent the project emission increase. The additional Pellet Mill (PM3) is the only new equipment proposed with this application. The potential uncontrolled emissions from the proposed Pellet Mill are 2.2 tpy of PM emissions, 1.1 tpy of VOC emissions and 0.01 tpy of HAP emissions. These emissions were calculated using Division approved emission factors and a design capacity of 5 ton per hour for the Pellet Mill. This includes 95% control of PM emissions due to the baghouse and 90% control of VOC and HAP emissions due to routing back to the /Dryer. Because these emissions do not exceed any PSD Significant Emission Rate limit, the construction and operation of the Pellet Mill (PM3) will not be subject to PSD review. The Greenhouse Gases (GHG) do not exceed 75,000 tpy of CO2e and the facility will continue to be a minor source for GHG. The facility has 249 tpy limits for PM, CO and VOC which will allow the facility to be a PSD minor source and avoid PSD review. The HAP emissions will be limited to 10 tpy for any single HAP emission and 25 tpy for combined HAP emissions which will allow the facility to avoid MACT requirements. Acetaldehyde, formaldehyde, methanol, hydrogen chloride are the significant HAP pollutants. SO 2 emissions are well below the major source threshold of 100 tpy. Most of the SO 2 is generated from the combustion of fuel in the /Dryer. The main fuel is wood/saw dust (green and dry) from yellow southern pine, which has naturally low sulfur content. Page 3

4 Pollutant Before Facility-Wide Emissions (in tons per year) Potential Emissions After Emissions Change Before Actual Emissions After Emissions Change PM NOx (92.3) SO CO (189.2) VOC Max. Individual HAP Total HAP Total GHG (if applicable) Regulatory Applicability There are no changes in the applicable rules and regulations due to this application. The facility will continue to be subject to Georgia Rule (b) Visible Emissions, Georgia Rule (e) Particulate Emissions from Manufacturing Processes and Georgia Rule (n) Fugitive Emissions. In order to avoid PSD, the VOC, CO and PM emissions will continue to be limited to 249 tpy. Because the NOx emissions do not have the potential to exceed 250 tpy, an emission limit was not included for NOx emissions. In order to avoid MACT requirements, HAP emissions will continue to be limited to less than 10 tpy for an individual HAP and 25 tpy for combined HAP emissions. Permit Conditions Condition 4.1 was modified require the to be operated when the associated equipment is being operated. This condition clarifies the requirement. Condition 4.4 was modified to add inlet to clarify where the recycle line should be vented. Condition 4.5 was modified to add inlet to clarify where the recycle line should be vented. Condition 5.2 was deleted because it concerned emission checks from the baghouse and the cyclones which is not applicable for these control devices. The particulates from these control devices are recycled back into the hammermill. All other emissions such as VOC and HAP emissions are sent to the burner. Condition 5.5 was deleted because it required an oxygen monitoring system to be installed for the /Dryer. Since oxygen levels are not a good indicator of /Dryer r operating conditions, the permit will be modified to include inlet and outlet temperatures of the /Dryer instead. Condition 5.6 was modified to require temperature monitoring for both the inlet and outlet of the Dryer. Condition 5.8 is a new condition which requires the pressure to be monitored between the Hammermill () and the Combustion Air Plenium (CAP1) in order to assure that makeup air is being vented to the which is acting as a control device for this air. Page 4

5 Condition 6.2 was deleted because it required an initial performance test for PM, NOx and CO emissions from the /Dryer which has already been completed. The facility will continue these performance tests every 2 years as required by Condition 6.3 which is unchanged with this amendment. Conditions 6.4 and 6.5 were deleted because they concerned the initial performance test for VOC, formaldehyde, acetaldehyde, and methanol emissions from the Dryer exhaust which has already been completed. The facility will continue these performance tests every 2 years as required by Condition 6.6 which is unchanged with this amendment. Condition 6.6 was modified to add exhaust to the requirement for VOC, formaldehyde, acetaldehyde, and methanol emissions testing every two years. This clarifies the test point. Condition 6.7 is a new condition which requires a performance test for Stack V. Condition 6.8 is a new condition which requires the facility to measure and record the pressure drop between the Hammermill () and the Combustion Air Plenium (CAP1) during the performance test for Stack V in order to establish a minimum pressure drop in order to assure the proper amount of makeup air is being sent to the which is acting as a control device for this air. Condition 6.9 is a new condition which requires performance tests of VOC, formaldehyde, acetaldehyde, and methanol emissions for Stack V every 2 years. Condition 6.10 is a new condition which requires a performance test for Stack B. Condition 6.11 is a new condition which requires performance tests of VOC, formaldehyde, acetaldehyde, and methanol emissions for Stack B every 2 years. Condition 8.4 was deleted because it required a Title V application to be submitted and the facility has complied by submitting their application. Toxic Impact Assessment A toxic impact assessment was prepared by the Division using information provided by the facility. SCREEN3 was used to evaluate formaldehyde, acetaldehyde, hydrogen chloride, methanol and phenol emissions. The TIA was based on the maximum allowed emissions for an individual pollutant which is 10 tpy as limited by the permit in order to avoid MACT. As a worst case scenario, all of these emissions were vented from one stack. The maximum concentrations of the pollutants were below the acceptable ambient pollutant concentrations; therefore, the TIA passed. Summary & Recommendations I recommend issuance of Permit Amendment No E-02-1 to LJR Forest Products for the construction and operation of the additional Pellet Mill (PM3). The facility is located at 1377 Old Nunez Road in Swainsboro (Emanuel County). A public advisory was issued and expired on October 3, The SSCP will continue to be responsible for compliance. The platform was reviewed for accuracy. Page 5