AWMA – Georgia Chapter Air Permitting Update April 16, 2013 Eric Cornwell Stationary Source Permitting Program

SSPP Structure 4 Units - 28 permit engineers, 2 admin – Chem Unit – Glass, engineered wood – NOx Unit – Landfills, engines – VOC Unit – Wood pellets, lumber kilns – Min Unit – Military, rendering, asphalt

Permit Application Timeliness: Pending Application Count (April 2013): – 202 permit applications – 12 (non TV-renewal) apps older than six months – 500 permit apps processed in past 12 months Processing time – Title V significant modifications……161 days – 502(b)10…………………………….…...66 days – Synthetic Minor…………………..……62 days

Expedited Permits In response to Senate Bill 427  O.C.G.A (c)(1)(A). Implemented no later than July 1, 2013 Two stakeholder meetings (Oct and Dec) /expeditedssppmeeting.htm

Expedited Permits, Cont. No rulemaking – Director to implement procedures. Fee-based and optional for applicants Reviews done by EPD – no third party review TV-I, TV-R, MAWO not eligible

PSD Resources PSD Guidance for Industry – now available Pre-processed met data – now available Background ambient concentrations – now available Statewide NAAQS and PSD Increment inventory (aka Off-site Emissions inventory) – Not yet…EPD intends to do this if funding is available

PSD Guidance for Industry Provides up-front expectations for a complete PSD application – BACT, Modeling, Submittals – Emphasizes early resolution of issues. /psd_guidance_document.htm

8 Meteorological Data GA EPD has developed 5-years of meteorological data for each ASOS surface and upper air pairing – Pairing based on distance, climatological zone, and data completeness criteria – Last updated on April 4, 2013 All data sets are available on-line – tdata.htm

9 Surface/Upper Station Pairings

10 Surface Roughness Update Previously, EPD provided data sets with three different surface roughness values (0.05, 0.5, 1.0) and the applicant ran AERSURFACE at the project site to find the most representative value. Now, meteorological data is processed using the surface roughness at the airport – 12 different sectors Applicant will provide a justification for representativeness in modeling protocol

11 Background Concentrations GA EPD has develop background concentrations for each county based on the design values – PM10, PM2.5, SO2, NO2, CO, Pb Will update to design values by the end of April All data sets are available on-line –

12 Permit Modeling Guidance Guideline for Modeling PM10 Ambient Concentration in Areas Impacted by Quarry Operation Producing Crushed Stone - August 7, 2012 – modeling/quarryguideline_august2012.pdf

GHG Permitting July 20, 2014 – Biomass deferral set to end. – GHG-major sources with non-PSD permits must “begin actual construction” prior to this date; otherwise permit invalid. US EPA has recently proposed revised “Global Warming Potential (GWP) for Part FR 19809, Table 2

Boiler MACT and GACT Final standards published in FR Feb 2013 SSPP slowly rolling details into permits – Adding to already pending applications – Companies can request revisions – Conditions as specific as practical – No mass “open for cause”

Wood Pellet Emission Factors Process – Log chipper, dryer (usually direct- contact), hammermill, pelletizer, and pellet cooler. Downstream testing showed VOC previously unaccounted for. – Plants over ~120,000 tpy production may be PSD major without downstream controls. Manny Patel developed default wood pellet emission factors from AP-42 and testing

EPD switching systems – Novell to Outlook – Air Branch transition this week – addys to remain the same – 10 Megabyte attachment limit