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Enviva Pellets Southampton LLC Air Permit Information Meeting

Enviva Pellets Southampton LLC Air Permit Information Meeting. Janet Weyland , Deputy Regional Director. Tidewater Regional Office. August 6, 2019. Tamera Thompson. Air Permit Manager. Stanley Faggert. Air Permit Coordinator. Agenda. Meeting purpose and format

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Enviva Pellets Southampton LLC Air Permit Information Meeting

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  1. Enviva Pellets Southampton LLCAir Permit Information Meeting Janet Weyland, Deputy Regional Director Tidewater Regional Office August 6, 2019 Tamera Thompson Air Permit Manager Virginia Department of Environmental Quality Stanley Faggert Air Permit Coordinator

  2. Agenda Meeting purpose and format Air permit program overview Application background DEQ preliminary determination (draft permit) Public comment period and public hearing Question and answers 3

  3. Purpose of Information Meeting 4 Explain the air permitting process to assist the public’s ability to provide meaningful comments on the draft air permit Provide an overview of the DEQ’s draft air permit Answer questions Note that comments and questions tonight will not be considered as formal comments and will not be part of the formal record

  4. Format of Meeting 5 DEQ will explain the air permitting process and review the draft permit After the presentation, DEQ will take questions from the audience Questions will be taken one at a time to allow everyone the opportunity to speak Please be respectful – everyone is here to learn and to gain a better understanding of the process

  5. What is an Air Permit? A legal document that limits the release of air pollution in compliance with applicable air pollution control laws. 6

  6. Air Quality Standards • The Clean Air Act (CAA) requires EPA to set National Ambient Air Quality Standards (NAAQS) at a level to protect public health with an adequate margin of safety • Based on evaluation of most current health science • Must protect sensitive populations • NAAQS are established for “criteria pollutants”: • Ozone (O3) = Volatile Organic Compounds + NO2 • Nitrogen dioxide (NO2) • Sulfur dioxide (SO2) • Particulate matter (PM10 and PM2.5) • Carbon monoxide (CO) • Lead (Pb) • Reviewed by EPA every 5 years 7

  7. Virginia Toxics Rule • Virginia regulation for “toxic pollutants” • The regulated “toxic” pollutants mirrors EPA’s list of Hazardous Air Pollutants (HAP) • Significant Ambient Air Concentration (SAAC) • Health-based standard • One hour and annual standards 8

  8. Air Permit Process Overview Permits required for new facilities or projects (new or expanded construction) at existing facilities Must have local government zoning approval before application Facility completes a permit application for permit to construct and/or modify and operate DEQ reviews application for regulatory compliance 9

  9. Air Permit Process Overview (cont’d) • DEQ reviews application • Type and quantity of pollutants emitted • Applicable federal and state regulations • Reviews Best Available Control Technology (BACT) • Reviews any necessary air quality analyses – computer program models ambient air concentrations based on permitted emission rates and other factors 10

  10. Air Permit Process Overview (cont’d) • DEQ requiresmonitoring, recordkeeping and reporting to assure compliance • DEQ drafts permit documents • Holds public comment period and/or hearing if required 11

  11. Facility Location 12

  12. Enviva Application Timeline Application received September 2018 Local government approval dated October 2018 Application updated March 2019 Application deemed largely complete on June 2019 13

  13. Enviva Application - Process Changes Green wood hammermills 2ndwood dryer system Proposes increasing production from ~535,000 tons/year to ~781,000 tons/year Proposes increasing the allowed % of softwood (pine, etc.) from 10% to 80% 14

  14. Enviva Application – Air Pollution Controls • Installation of new air pollution controls on: • Existing and new dryer • Green wood hammermills • Dry hammermills • Pellet mill/cooler 15

  15. Enviva General Process Flow 16

  16. Enviva Application - Emission Points • Log processing – PM, VOC • Green wood hammermills – PM, VOC, HAP • Dryers (wood-fired) – PM, NOx, VOC, HAP • Combustion emissions • Process emissions • Dry wood hammermills – PM, VOC, HAP • Pellet mills – PM, VOC, HAP 17

  17. Enviva Application – Air Pollution Controls • Four Regenerative thermal oxidizers (RTOs) for VOC and HAP control • New/existing dryers and green hammermills (2) • Dry wood hammermills (1) • Pellet Mill/Cooler (1) • 97.5% emission reduction • Regenerative = heat recovery to minimize use of supplemental fuel • Contributes to NOx and CO emissions 18

  18. Enviva Application – Air Pollution Controls One wet electrostatic precipitator (WESP) for PM control – new dryer Two wet scrubbers for PM control – dry hammermills and pellet mill/cooler 90% emission reduction 19

  19. Enviva Facility-Wide Potential to Emit *NAAQS Pollutants plus HAP 20

  20. Pollution Requiring Permit at Enviva • Nitrogen oxides (NOx) • Carbon monoxide (CO) • Sulfur dioxide (SO2) • Volatile organic compound (VOC) • Particulate matter (PM2.5 and PM10) 21

  21. Virginia Air Toxic Pollutants Evaluated • The following pollutants were modeled for compliance and limited in the draft permit: • Acetaldehyde – hourly and annual • Acrolein – hourly and annual • Chlorine compounds – hourly and annual • Formaldehyde compounds – hourly and annual • Hydrochloric Acid – hourly only • Methanol – hourly and annual • Phenol – hourly and annual 22

  22. Air Quality Analysis (Modeling) • Facility is not predicted to cause or contribute to a violation of any NAAQS or SAAC • Analysis was conducted using the worst case emission profile (peak emissions) for each pollutant • Analyzed worst-case operational scenarios • Analysis accounts for background pollution concentrations and impacts from nearby sources 23

  23. Proposed BACT Controls • VOC and HAP Emissions • RTOs are top-ranked technology • PM10 and PM2.5 Emissions • WESPs and wet scrubbers are top-ranked control technologies 24

  24. Compliance Requirements • Stack testing requirements • Initial tests for VOC, NOx, CO, PM10, PM2.5 and HAP for all significant emission units; • Follow up stack tests required every 5 years • Continuous parametric monitoring for RTOs, WESPs and wet scrubbers 25

  25. Construction Schedule Requirements • Air pollution controls for existing equipment are required even if the expansion does notoccur • Air pollution controls must be operational within one year of permit issuance • Initial stack tests are required within six months of operation • Air pollution controls for new equipment must be operational at start-up 26

  26. Public Comment Period and Hearing Announcement anticipated for August 11, 2019 Public comment period anticipated to start Aug. 12, 2019 Public hearing anticipated for Sept. 12, 2019 Public comment period anticipated to end Sept. 27, 2019 Public hearing – Receive comments; No Q&A 27

  27. Purpose of Public Comment Period Provide opportunity for public to provide input Refine and improve draft air permit documents based on information received during comment period Ensure air permit properly implements regulatory requirements and meets all federal and state air quality standards 28

  28. Thank you.Questions? 29

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