WWALS Watershed Coalition

WWALS Watershed Coalition, Inc. (WWALS) is Suwannee RIVERKEEPER® WWALS advocates for conservation and stewardship of the surface waters and groundwater of the Suwannee River Basin and Estuary, in south Georgia and north Florida, among them the Withlacoochee, Willacoochee, Alapaha, Little, Santa Fe, and Suwannee River watersheds, through education, awareness, environmental monitoring, and citizen activities.

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Modifications, Spectrum Energy pellet mill permit application, Adel, Cook County, GA @ GA-EPD 2025-03-05 [Up]

You can help with clean, swimmable, fishable, drinkable, water in the 10,000-square-mile Suwannee River Basin in Florida and Georgia by becoming a WWALS member today!
https://wwals.net/donations/

Pictures

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[Modifications, Spectrum Energy pellet mill permit application, Adel, Cook County, GA @ GA-EPD 2025-03-05]
Modifications, Spectrum Energy pellet mill permit application, Adel, Cook County, GA @ GA-EPD 2025-03-05

[Modifications, Spectrum Energy pellet mill permit application, Adel, Cook County, GA @ GA-EPD 2025-03-05]
Modifications, Spectrum Energy pellet mill permit application, Adel, Cook County, GA @ GA-EPD 2025-03-05

Maps

[Map: 801 Cook Street, Adel, GA --WLRWT]
Map: 801 Cook Street, Adel, GA --WLRWT

Narrative

[Narrative From Nada Osman: a proposed wood pellet manufacturing facility to be located at 801 Cook Street in Adel, Georgia.]
Narrative From Nada Osman: a proposed wood pellet manufacturing facility to be located at 801 Cook Street in Adel, Georgia.
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[Table 1. Updated Phase I Equipment List]
Table 1. Updated Phase I Equipment List
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[Emissions Summary]
Emissions Summary
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[Table 2. Facilty-wide Emissions (tpy) in Phase I (After-control)]
Table 2. Facilty-wide Emissions (tpy) in Phase I (After-control)
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[Regulatory Applicability]
Regulatory Applicability
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[Page 6]
Page 6
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[Permit Conditions]
Permit Conditions
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[Page 8]
Page 8
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[Page 9]
Page 9
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[Toxic Impact Assessment]
Toxic Impact Assessment
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[Table 4: Summary of Toxic Impact Analysis]
Table 4: Summary of Toxic Impact Analysis
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[Another Public Advisory comment from 4C raised concerns about potential PM2.s National Ambient Air Quality Standards (NAAQS) exceedances as the facility transitions from Phase I to Phase II.]
Another Public Advisory comment from 4C raised concerns about potential PM2.s National Ambient Air Quality Standards (NAAQS) exceedances as the facility transitions from Phase I to Phase II.
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[A Public Advisory Comment and An additional comment from the EPA]
A Public Advisory Comment and An additional comment from the EPA
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[Page 14]
Page 14
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[Summary & Recommendations]
Summary & Recommendations
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[Addendum to Narrative]
Addendum to Narrative
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Permit

[PERMIT NO. 2499-075-0028-E-01-1 Air Quality Permit]
PERMIT NO. 2499-075-0028-E-01-1 Air Quality Permit
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[NEW CONDITION:]
NEW CONDITION:
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[5. Monitoring MODIFIED CONDITIONS:]
5. Monitoring MODIFIED CONDITIONS:
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[Page 4]
Page 4
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[Page 5]
Page 5
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[NEW CONDITION: Phase I 5.17 The Permittee shall develop and implement a Preventative Maintenance Program (PMP) for the regenerative thermal oxidizer (ID No. RTO) in order to....]
NEW CONDITION: Phase I 5.17 The Permittee shall develop and implement a Preventative Maintenance Program (PMP) for the regenerative thermal oxidizer (ID No. RTO) in order to....
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[6. Performance Testing MODIFIED CONDITIONS: Phase I 6.3. The Permittee shall conduct the following initial performance tests within 120 days of the initial startup of the associated emission units and control devices in Phase I.]
6. Performance Testing MODIFIED CONDITIONS: Phase I 6.3. The Permittee shall conduct the following initial performance tests within 120 days of the initial startup of the associated emission units and control devices in Phase I.
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[Page 8]
Page 8
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[Page 9]
Page 9
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[Page 10]
Page 10
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[Phase II 6.13 If any outlet/stack HAP emission rates recorded in accordance with Conditions 6.12m., o., and p. exceed the corresponding emission factors currently included in Table 7.22 (the proposed emission factors in Application No. 28143), then the Permittee shall submit a permit application within 180 days after testing, demonstrating that either the emission factors derived are not representative of normal emissions or the facility will continue to comply with the GA Air Toxics Guideline with the higher tested results.]
Phase II 6.13 If any outlet/stack HAP emission rates recorded in accordance with Conditions 6.12m., o., and p. exceed the corresponding emission factors currently included in Table 7.22 (the proposed emission factors in Application No. 28143), then the Permittee shall submit a permit application within 180 days after testing, demonstrating that either the emission factors derived are not representative of normal emissions or the facility will continue to comply with the GA Air Toxics Guideline with the higher tested results.
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[7. Notification, Reporting and Record Keeping Requirements MODIFIED CONDITIONS:]
7. Notification, Reporting and Record Keeping Requirements MODIFIED CONDITIONS:
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[Page 12]
Page 12
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[Page 13]
Page 13
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[Page 14]
Page 14
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[Page 15]
Page 15
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[Page 16]
Page 16
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[Page 17]
Page 17
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[Page 18]
Page 18
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[Table 7.12: HAP Emission Factor That Should Be Used Before Any Test Results Are Available]
Table 7.12: HAP Emission Factor That Should Be Used Before Any Test Results Are Available
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[Page 20]
Page 20
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[Page 21]
Page 21
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[Page 22]
Page 22
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[Page 23]
Page 23
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[Page 24]
Page 24
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[Table 7.20: VOC Emission Factor That Should Be Used Before Any Test Results Are Available]
Table 7.20: VOC Emission Factor That Should Be Used Before Any Test Results Are Available
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[Page 26]
Page 26
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[Page 27]
Page 27
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[Table 7.22: HAP Emission Factor That Should Be Used Before Any Test Results Are Available]
Table 7.22: HAP Emission Factor That Should Be Used Before Any Test Results Are Available
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[Page 29]
Page 29
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[Page 30]
Page 30
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