PERMIT REVIEW SUMMARY

Permit Writer:	Clinton Gentry 				Date:	November 12, 2025

Company Name:	Enviva Port of Pascagoula LLC

Facility Location:	549 Industrial Road

			30° 20’ 43” N
			88° 30’ 04” W

Source Number:	1280-00148

County: 		Jackson (39851)

FACILITY DESCRIPTION

Enviva Port of Pascagoula, LLC (Enviva) is a wood pellet receiving, storage, and loading facility categorized under SIC Code 4491: Marine Cargo Handling. 

The Pascagoula terminal receives wood pellets via railcar, truck, and barge. Except for transfer of pellets into ships and barge unloading hopper discharge to conveyor, all pellet transfers, whether by vehicle to hopper, conveyor to conveyor, or conveyor to storage dome are enclosed and equipped with induced draft baghouses or bin vents to control particulate matter (PM) emissions. Currently there are ten (10) such PM control devices constructed and in operation.

PROJECT/PERMIT ACTION DESCRIPTION

Enviva is requesting a Synthetic Minor Operating Permit (SMOP) with modifications to their initial application to reflect the final design of the terminal. The facility was issued a permit to construct on April 9, 2019, but has since undergone changes to the initially proposed design. These changes have been expressed and discussed with DEQ and as such, Enviva has submitted an updated SMOP application to replace the initial application submitted in 2018. 

The following emission points, present in the permit to construct, have been removed from the operating permit:
Emission Point	Description	
AA-004	Baghouse 4 controlling emissions from material transfer from Dome Feed Belt Conveyor (BC3) to Pellet Storage Dome No. 1 	
AA-009	Baghouse 9 controlling emissions from material transfer from Belt Conveyor (BC8) to Belt Conveyor (BC9) and material transfer from Belt Conveyor (BC9) to Ship Loading Conveyor	
AA-011	Baghouse 11 controlling emissions from material transfer to ships via telescoping ship loadout spout	
AA-015	671 bhp diesel-fired Emergency Generator 	
AA-017	525 hp diesel-fired non-emergency Compression Ignition Engine No. 1 	
AA-018	525 hp diesel-fired non-emergency Compression Ignition Engine No. 2	
AA-019	322 hp diesel-fired non-emergency Compression Ignition Hopper Engine	

The three control devices being removed are for the following reasons:
•	Emission Point AA-004’s emissions are now being controlled by Emission Point AA-003.
•	Emission Point AA-009’s emissions are now being controlled by Emission Point AA-010.
•	Emission Point AA-011’s emissions are now being accounted for at Emission Point AA-014.

No new emission points are being requested to be added.

EMISSION SUMMARY

Criteria Pollutant	Maximum Uncontrolled	Potential Controlled	Title V Threshold	
Carbon Monoxide (CO)	90.14	90.1	100	
Nitrogen Oxides (NOx)	0.48	0.48	100	
Sulfur Dioxide (SO2)	0.00	0.00	100	
Particulate Matter 10 (PM10)	6148.72	67.3	100	
Volatile Organic Compounds (VOC)	28.26	28.3	100	
Total Hazardous Air Pollutants (HAP)	2.81	2.81	25	
*All pollutants are expressed in units of tons per year (tpy)

As shown in the table above, Enviva has the potential to exceed the Title V threshold of 100 tpy for PM10. The facility also has the potential to exceed the PSD threshold of 250 tpy for PM. However, by limiting PM10 emissions below the Title V threshold, the facility will be subsequently limiting PM emissions below the PSD threshold. As such, the facility is requesting a federally enforceable limit of 99.0 tons per year of PM10 emissions. In order to achieve this, the facility is required to operate all baghouses whenever material is being transferred.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
Facility-Wide	PM	< 99.0 tpy (Title V Avoidance)	Keep records of material and calculate emission rate (Title V Avoidance)	
AA-001            AA-002             AA-003            AA-005             AA-006               AA-007             AA-008                 AA-010             AA-012               AA-013	PM	Operate baghouses when material is transferred (Title V Avoidance)	Maintain pressure drop gauges (Title V Avoidance)	

NSPS APPLICABILITY

Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines
This subpart applies to owners and operators of stationary reciprocating internal combustion engines (RICE) that commenced construction after July 5, 2005. Emission Point AA-031 is an emergency, spark ignition generator with a rated power of 34.9 hp that was manufactured or reconstructed after July 11, 2005. As such, Emission Point AA-031 is subject to this subpart. 

Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
This subpart applies to owners and operators of stationary, compression ignition (CI) internal combustion engines (ICE). Emission Point AA-016 is an emergency compression ignition generator with a rated power of 211 bhp that commenced construction after July 11, 2005. As such, Emission Point AA-016 is subject to this subpart. 

MACT APPLICABILITY

Subpart ZZZZ – National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
This subpart applies to owners and operators of stationary internal combustion engines located at major and area sources of HAP emissions. As such, Emission Points AA-016 and AA-031 are subject to this subpart. However, under 40 CFR 63.6590(c)(a), this engine is classified as a new or reconstructed RICE located at an area source. Therefore, Emission Point AA-031 will demonstrate compliance with 40 CFR Part 63 Subpart ZZZZ by complying with all applicable requirements under 40 CFR Part 60 Subpart JJJJ. Emission Point AA-016 will demonstrate compliance with 40 CFR Part 60 Subpart IIII. No further requirements under Subpart ZZZZ will apply to Emission Points AA-016 and AA-031. 

PUBLIC PARTICIPATION

The 30-day public notice period began on November 12, 2025, with the publication of a notice on MDEQ’s website, and ends December 12, 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 a thorough consideration of all public comments.