Titl e V Construction and Operating P er mit Application of Royal Pest Solutions f or Fu mi gation Operations at Schilli Distribution Services Port Wentworth, Georgia Presented to: G e o r g i a Environment al Protection D i v i s i o n A i r Protection Branch 4244 International Parkway, Suite 120 Atlanta, Georgia 30354 Prepared for: Royal Pest Solutions Inc. 53 McCullough Drive New Castle, Delaware 19720 Prepared by: SCS ENGINEERS 11260 Roger Bacon Drive, Suite 300 Reston, VA 23502 (703) 471-6150 May 28, 2015 File No. 02209044.00 Offices Nationwide www.scsengineers.com T i t l e V Construction and Operating Permit Application Royal Fumigation – Port Wentworth , G e o r g i a T i t l e V Construction and Operating Permit Application of Royal Pest Solutions F o r Fumigation Operations at Schilli Distribution Services P o r t W entworth, Georgia Presented to: Georgia Environ mental Protection Division Air Protection Branch 4244 International Parkway, Suite 120 Atlanta, Georgia 30354 Prepared for: Royal Pest Solutions I n c . 53 McCullough Drive New Castle, Delaware 19720 Prepared by: SCS ENGINEERS 11260 Roger Bacon Drive, Suite 300 Reston, VA 23502 (703) 471-6150 May 28, 2015 File No. 02209044.00 i T i t l e V Construction and Operating Permit Application Royal Fumigation – Port Wentworth , G e o r g i a Table of Contents Section Page 1.0 Project Description ................................................................................................................................. 1 2.0 Process Overview and Description ..................................................................................................... 1 Methyl Bromide Fumigation ....................................................................................................... 1 Overview of Fumigation Process ............................................................................................... 2 3.0 Process Emissions .................................................................................................................................... 5 4.0 Regulatory Analysis ............................................................................................................................... 5 Georgia ......................................................................................................................................... 5 Federal Clean Air Act (CAA) ..................................................................................................... 6 Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) ................................................ 7 USDA Animal and Plant Health Inspection Service (APHIS) ................................................. 7 List of Tables No. Page Table 1. Methyl Bromide Potential-to-Emit ............................................................................................ 5 A t t a c h m e n t s A Facility Location and Site Plan B Process Flow Diagram C Permit Application Forms D Dispersion Modeling and Toxic Impact Assessment E Case-by-Case MACT Analysis ii T i t l e V Construction and Operating Permit Application Royal Fumigation – P o r t Wentworth, Georgi a 1.0 P RO JECT DESCRIPTION Royal Pest Solutions Inc. seeks to operate a fumigation facility within a designated area at Schilli Distribution Services, located at 120 Crossgate Road, Port Wentworth, Georgia in Chatham County. The site, which is owned by the Georgia Ports Authority, encompasses approximately52.88 acres. Fumigation operations will include methyl bromide fumigation of bulk log stacks and shipping containers, under tarpaulins and within a designated, open area of the site. A 60-ft stack will be installed to discharge the methyl bromide following completion of fumigation. A site map and a satellite image of the facility are provided in Attachment A. The principal business of the facility is the quarantine and pre-shipment (QPS) fumigation of logs destined for export from the Port of Savannah. This fumigation is conducted under the direct, on-site supervision of officers of United States Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS). Methyl bromide is the sole fumigant used and emitted at this facility. The purpose of this application is to respectfully request an air permit for the fumigation operations detailed in this application. The site will be a major source for Hazardous Air Pollutants (HAPs). Attached to this submittal are the applicable Georgia EPD application forms, an extended description of the project, detailed emissions calculations, site process flow diagram, location map, and dispersion modeling results demonstrating compliance with acceptable ambient levels of methyl bromide. Additionally, a Case-by-Case MACT Analysis for methyl bromide fumigation is provided as Attachment E. 2.0 PRO CESS OVERVIEW AND DESCRIPTION Methyl Bromide Fumigation The facility will be designed and operated to comply with the requirements of the USDA APHIS, Plant Protection and Quarantine (PPQ) division, the regulatory body that oversees QPS treatments in the United States. The fumigant used at the facility is methyl bromide, which has been the principal QPS fumigation tool of APHIS for over forty years and has been regularly used at various ports and fumigation facilities throughout the United States, including sites in Georgia (e.g., Ultimate Pest Control, Ellabell, GA; East Coast Terminal Company, Savannah, GA). Although methyl bromide has been a long-standing and principal QPS treatment tool as prescribed by APHIS, the compound was deemed a depleter of stratospheric ozone in 1992 under the terms of an international treaty, the Montreal Protocol on Substances That Deplete the Ozone Layer, and therefore subject to “phase-out” of most of its uses. The federal Environmental Protection Agency (USEPA), in implementing the requirements of the Montreal Protocol, has greatly restricted use of methyl bromide for applications such as soil fumigation. However, its use for QPS applications such as those to be performed at this location has been preserved until such time as there is a replacement for it, and consequently, the compound is specifically authorized by the QPS exemption under Title VI (Stratospheric Ozone Protection) of the Clean Air Act (CAA). 1 T i t l e V Construction and Operating Permit Application Royal Fumigation – P o r t Wentworth, Georgi a The APHIS officers oversee fumigation of cargo entering the U.S. on which invasive pests, not native to the U.S., are found or are deemed to be present due to past inspections. The cargo is quarantined until it receives treatment in accordance with USDA requirements. APHIS officers also oversee pre-shipment quarantine fumigation treatments that are required by other countries (e.g., China, India, Turkey) to which U.S. goods are to be shipped. Methyl bromide is a hazardous air pollutant (HAP) under CAA § 112, and a case-by-case MACT analysis is provided in Attachment E. In summary, the MACT analysis concludes that methyl bromide emissions will be managed using a combination of best management practices and engineering controls. Overview of Fumigation P r o c e s s The QPS process is dictated by APHIS protocols for commodities through its Plant Protection and Quarantine (PPQ) division. The APHIS protocols and treatment schedules are published in the 920-page PPQ Treatment Manual. Further, all QPS fumigation conducted by Royal at the Port Wentworth location is performed under the direct, on-site supervision of an APHIS officer. In addition, all fumigation at the site is performed in accordance with USEPA’s Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) pesticide label requirements as well as the PPQ Treatment Manual, and applicable international phytosanitary standards. APHIS has developed a series of detailed fumigation protocols for commodities through its Plant Protection and Quarantine (PPQ) division. The protocols and treatment schedules are published in the PPQ Treatment Manual, a document of over 900 pages. Further, all QPS fumigation conducted by Royal at the Port Wentworth location is performed under the direct, on-site supervision of an APHIS officer. In addition, all fumigation at the site is performed in accordance with USEPA’s Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) pesticide label requirements as well as the PPQ Treatment Manual, and applicable international phytosanitary standards. The treatment protocols published in the Treatment Manual are highly prescriptive and dictate detailed requirements for many aspects of the fumigation process, including but not limited to the following: Fumigation chemical (e.g., methyl bromide); Dosage - pounds of fumigant per 1,000 cubic feet of fumigated space; Maintenance of dosage by monitoring fumigant concentrations at multiple locations within the treatment enclosure throughout the treatment period and periodic addition of fumigant as necessary to maintain the required concentration; Treatment duration; Forced recirculation within the tarpaulin enclosure to maintain the correct mixture of the fumigant in air throughout the prescribed treatment period; Monitoring the temperature of the environment and the commodity at multiple locations within the treatment enclosure throughout the treatment period; Weatherization of the treatment enclosure; 2 T i t l e V Construction and Operating Permit Application Royal Fumigation – P o r t Wentworth, Georgi a Availability of utilities; Arrangement of commodities within the treatment enclosure;