PERMIT REVIEW SUMMARY

Permit Writer:	Thomas Parker 	Date:	December 18, 2024

Company Name:	20th State Energy, LLC

Facility Location:	13247 Seaway Road 

Source Number:	1020-00203

County: 		Harrison

FACILITY DESCRIPTION

20th State Energy, LLC (20th State Energy) is proposing to construct an asphalt roofing material processing facility (SIC Code: 3999) in Gulfport, Mississippi. The facility will use patented technology to separate the asphalt of roofing materials into their base components for petroleum, sand, and fiberglass recovery and resale. The process will use a proprietary solvent (Kaniksu) to dissolve the asphaltenes (long chain hydrocarbons, C14 to C20) in the material and separate the oil, fiberglass, and sand into commercial products. The feedstock for the process will include asphaltic (heavy hydrocarbon) compounds that are stable under normal conditions. The proprietary solvent bonds will liquefy the asphaltenes to form new compounds. The chemical bonding between the solvent and the asphalt in the feedstock will produce an oil that can be used as a combustion fuel and allow sand and fiberglass separation and processing. The entire process will be designed to be fully enclosed to the extent possible and will be operated under a vacuum to ensure that any open area will provide inflow of surrounding air into the units for capture through the Granular Activated Carbon (GAC) system (Emission Point AA-007). The following table includes the proposed emission points at the facility. 

Emission Point	Facility ID	Description	
AA-001		Loading System: Container Tipper, Shingle Hopper	
AA-002		Shingle Processing Unit: Trommel No. 1	
AA-003		Sand Processing Unit: Mud Cube, Sand Screw No. 1, Shaker Table, Sand Screw No. 2	
AA-004		Sand Loadout	
AA-005		Fiberglass Processing Unit: Trommel No. 2 and 3	
AA-006		Fiberglass Loadout	
AA-007		Two (2) Granular Activated Carbon Adsorption Devices in Series	
AA-008		Two (2) Oil/Water Separators	
AA-009	EP-02	Two (2) 16,400-gallon Solvent (Kaniksu) Storage Tanks	
AA-010	EP-03	Two (2) 16,400-gallon Light Oil Storage Tanks	
AA-011	EP-04	Twelve (12) 42,000-gallon Oil Production Storage Tanks	
AA-012	EP-05	Surfactant Tote	
AA-013		Oil Production Loadout	

PROJECT/PERMIT ACTION DESCRIPTION

The Loading System (Emission Point AA-001) will contain shingle feedstock that will be loaded using a Tipper and Loading Hopper through an enclosed conveyor that will move the raw materials into the Shingle Processing Unit (Emission Point AA-002). The Shingle Processing Unit (Emission Point AA-002) will separate the oily fiberglass from the oily sand using Trommel No. 1 (rotary screen).  

The oily sand will be transferred through an enclosed conveyor to the Sand Processing Unit (Emission Point AA-003), where the Mud Cube will remove the free oil in the sand and return the recovered oil to the Shingle Processing Unit (Emission Point AA-002). The remaining oily sand from the Mud Cube unit will discharge through a covered chute to Sand Screw No. 1, where the solvent from the Fiberglass Processing Unit (Emission Point AA-005) will be added for additional removal of the residual oil from the oily sand. The oily sand will be transferred to an enclosed Shaker Table with added surfactant and circulation water for final removal of residual oils from the sand. The Shaker Table will discharge through an enclosed conveyor to Sand Screw No. 2 for stacking of the recovered sand, and the sand will be sent to the Sand Loadout (Emission Point AA-004) through an enclosed conveyor.

The oily fiberglass will be directly discharged to the Fiberglass Processing Unit (Emission Point AA-005) through Trommel No. 2 (rotary screen) and treated with the proprietary solvent to remove the bulk of the residual oil and polish the fiberglass. The liquid discharge from this unit will be comprised primarily of the proprietary solvent, which will be sent to Sand Screw No. 1, as noted above. The polished fiberglass will then be sent to Trommel No. 3 (rinse water trommel) containing the surfactant and water to further remove any remaining residual oils. The oil/water mix generated from Trommel No. 3 will be returned to the Oil/Water Separators (Emission Point AA-008) for oil recovery. The cleansed fiberglass will then be conveyed to the Fiberglass Loadout (Emission Point AA-006) for shipment.

There will be two (2) Oil/Water Separators (Emission Point AA-008) in the process. The first separator will recover the oil and water from Trommel No. 3. The recovered oil will be pumped to the Oil Production Storage Tanks (Emission Point AA-011), and the recovered water will be returned to the first water tank for reuse. The second separator will take the recovered oil and water from the enclosed Shaker Table and deposit the recovered oil to the Oil Production Storage Tanks (Emission Point AA-011). The recovered water from the Shaker Table will be sent to the second water storage tank. The recovered oil product, that will be stored in one of the twelve (12) 42,000-gallon Oil Production Storage Tanks (Emission Point AA-011), will require an oil loading system to move the oil product from the storage tanks to tanker trucks (or barges) for resale.

The two (2) Light Oil Storage Tanks (Emission Point AA-010) will feed the Shingle Processing Unit (Emission Point AA-002) and will receive the recovered light oil from Sand Screw No. 1 in the Sand Processing Unit (Emission Point AA-003). The Surfactant Tote (Emission Point AA-012) will supply the enclosed Shaker Table, Sand Screw No. 2, and Trommel No. 3.  The two (2) 16,400-gallon Solvent (Kaniksu) Storage Tanks (Emission Point AA-009) will feed into Trommel No. 2 of the Fiberglass Processing Unit (Emission Point AA-005). The two (2) GAC Adsorption Devices in Series (Emission Point AA-007) will capture the emitted vapors through ductwork from both process units providing at least 90% control of the emissions. 

EMISSION SUMMARY

Facility-Wide Potential Emissions Summary
Pollutant	Potential Emissions	Allowable Emissions	
	(tons/yr)	(tons/yr)	
PM/PM10/PM2.5	0.00	-	
SO2	0.00	-	
NOx	0.00	-	
CO	0.00	-	
Total VOCs	13.37	99.0	
Xylene (Isomers and Mixture)	13.37	9.0	
Total HAPs	13.37	24.0	

20th State Energy will operate a number of air pollutant emission sources, including two (2) GAC Adsorption Devices in Series (Emission Point AA-007), two (2) 16,400-gallon Solvent (Kaniksu) Storage Tanks (Emission Point AA-009), two (2) 16,400-gallon Light Oil Storage Tanks (Emission Point AA-010), and twelve (12) 42,000-gallon Oil Production Storage Tanks (Emission Point AA-011). 

Based on the performance stack testing conducted on August 2, 2022, on the same equipment at the same operating rates of the Iowa facility, 20th State Energy has been conservative in stating that the emissions from the GAC Adsorption Devices in Series (Emission Point AA-007) will be entirely Xylene. Upon completion of construction and commencement of operations, the facility will be required to conduct performance tests on the GAC Adsorption Devices in Series (Emission Point AA-007) to speciate the actual Individual Hazardous Air Pollutant (HAP) emissions. Once the individual HAPs can be identified and documented, determination of the facility as True Minor or Synthetic Minor will be conducted.

The surfactant within the Surfactant Tote (Emission Point AA-012) will essentially be a soap with a high volatility, meaning negligible emissions will come from the tote. There will be no anticipated PM, PM10, or PM2.5 emissions due to the wet nature of the materials throughout the entire process. Since there will be no combustion sources within the facility, there will be no anticipated SO2, NOx, or CO emissions.

20th State Energy has the potential to exceed the Title V Major Source threshold of 10.0 tons per year for Individual HAPs as seen in the table above. The facility will remain below the Title V threshold by limiting Xylene emissions to 9.0 tons per year with two (2) GAC Adsorption Devices in Series (Emission Point AA-007). The facility has also elected to set limits on the Total Volatile Organic Compound (VOC) emissions of 99.0 tons per year, even though the Total VOC emissions from the facility are substantially below this threshold. Limitations have also been set on the Total HAP emissions of 24.0 tons per year, even though the Total HAP emissions from the facility are substantially below this threshold. Once the actual Individual HAPs have been determined, the prior limitations may be subject to change.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).
o	Total HAP emissions limited to 24.0 tons/year
o	Individual HAP emissions limited to 9.0 tons/year

•	11 Miss. Admin. Code Pt. 2, R. 1.3.F(1).
o	Particulate and ash limited by the relationship E = 4.1 × p0.67, where “E” is the emission rate in pounds per hour, and “p” is the process weight input rate in tons per hour.

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).
o	The permittee shall route all emissions to Emission Point AA-007 for control.

•	11 Miss. Admin. Code Pt. 2, R. 2.2.B(10).
o	The permittee shall operate the control device(s) at all times when processing. Should any control device become non-operational then the respective process shall be shut down immediately, but not as to cause damage to equipment or property or cause further environmental problems. The process shall not start up again until such time that the control device becomes operational and proper efficiency of the pollution control equipment is restored. The permittee shall conduct maintenance and quality assurance/quality control measures in accordance with the manufacturer’s specifications.

NSPS APPLICABILITY

40 CFR 60, Subpart UU (Standards of Performance for Asphalt Processing and Asphalt Roofing Manufacture): The affected facilities to which this subpart applies are each saturator and each mineral handling and storage facility at asphalt roofing plants; and each asphalt storage tank and each blowing still at asphalt processing plants, petroleum refineries, and asphalt roofing plants. 20th State Energy will not operate the subject affected facilities. The facility takes asphalt roofing material to separate the asphalt into its base components for recovery and resale. Therefore, 20th State Energy is not subject to Subpart UU.

40 CFR 60, Subpart Kc (Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After October 4, 2023): Storage vessels that are affected facilities for which construction or reconstruction commenced after October 4, 2023, are subject to this subpart if one of the following is applicable:  
•	Storage vessels with a capacity greater than or equal to 40,000 gallons containing a VOL with a maximum true vapor pressure equal or greater than 0.5 psia
•	Storage vessels with a capacity greater than or equal to 20,000 gallons but less than 40,000 gallons containing a VOL with a maximum true vapor pressure equal to or greater than 1.5 psia 
The two (2) 16,400-gallon Solvent Storage Tanks (Emission Point AA-009) and the two (2) 16,400-gallon Light Oil Storage Tanks (Emission Point AA-010) each have a capacity less than 20,000 gallons. The twelve (12) 42,000-gallon Oil Production Storage Tanks (Emission Point AA-011) each have a capacity greater than 40,000 gallons containing a VOL; however, the stored material has a maximum true vapor pressure of 0.04 psia, which is less than the 0.5 psia requirement. Therefore, 20th State Energy is not subject to Subpart Kc.

MACT APPLICABILITY

40 CFR 63, Subpart LLLLL (NESHAP: Asphalt Processing and Asphalt Roofing Manufacturing): Facilities subject to this subpart own or operate an asphalt processing facility or an asphalt roofing manufacturing facility that is a major source or is located at/part of a major source. 20th State Energy is not an asphalt processing facility or an asphalt roofing manufacturing facility. The facility uses patented technology to separate the asphalt of roofing materials into their base components for recovery and resale, and the facility is not a major source. Therefore, 20th State Energy is not subject to Subpart LLLLL.

40 CFR 63, Subpart AAAAAAA (NESHAP for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing): Facilities subject to this subpart own or operate an asphalt processing operation and/or asphalt roofing manufacturing operation that is an area source of HAPs. The following are the definitions to Asphalt Processing and Asphalt Roofing Manufacturing:
•	Asphalt Processing Operation – means any operation engaged in the preparation of asphalt flux at stand-alone asphalt processing facilities, petroleum refineries, and asphalt roofing facilities. Asphalt preparation, called “blowing,” is the oxidation of asphalt flux, achieved by bubbling air through the heated asphalt, to raise the softening point and to reduce penetration of the oxidized asphalt. An asphalt processing facility includes one or more asphalt flux blowing stills.
•	Asphalt Roofing Manufacturing Operation – means the collection of equipment used to manufacture asphalt roofing products through a series of sequential process steps. The equipment configuration of an asphalt roofing manufacturing process varies depending upon the type of substrate used. For example, an asphalt roofing manufacturing line that uses organic substrate typically would consist of a saturator, coating mixer, and coater. An asphalt roofing manufacturing line that uses inorganic substrate typically would consist of a coating mixer and coater.
The 20th State Energy affected sources do not meet the definition for asphalt processing operations due to the facility not having any asphalt flux blowing stills. The affected sources do not meet the definition for asphalt roofing manufacturing operations due to the facility not containing the equipment needed to manufacture asphalt roofing products. The facility solely breaks down asphalt roofing materials into their components for recovery and resale. 20th State Energy is not designed to manufacture asphalt products; therefore, the facility is not subject to Subpart AAAAAAA.   

PUBLIC PARTICIPATION

The 30-day public notice period began on February 12, 2025, and ends March 14, 2025.

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 thorough consideration of all public comments.