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SSM SIP Call Georgia’s Response

Published byLeslie Weaver Modified over 6 years ago

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Presentation on theme: "SSM SIP Call Georgia’s Response"— Presentation transcript:

1 SSM SIP Call Georgia’s Response
Eric Cornwell Air Protection Branch March 29, 2016

2 Georgia’s SSM Rule 391-3-1-.02(2)(a)7 – Excess Emissions
(i) Excess emissions resulting from startup, shutdown, malfunction of any source which occur though ordinary diligence is employed shall be allowed provided that (I) the best operational practices to minimize emissions are adhered to, and (II) all associated air pollution control equipment is operated in a manner consistent with good air pollution control practice for minimizing emissions and (III) the duration of excess emissions is minimized.

3 SSM SIP Call May 22, 2015 – EPA found Georgia’s (and many others) SIP substantially inadequate Emissions Standards must apply “continuously” No “affirmative defense” allowed

4 EPA – Approved Options Remove SSM exclusions so that emission limits apply all the time, including during SSM Add “enforcement discretion” language Revise emissions standards Create alternative work practice standards for Startup and Shutdown (WPS)

5 Georgia choosing WPS 3+1 compliance options Comply at all times OR
General standards for control devices Follow NSPS or MACT Case by Case WPS in Permit

6 Other Details WPS only applies to SIP rules
Current “excess emissions” rule still in play for non-SIP rules Toggle / rescission clause Does not include Malfunctions

7 Stakeholder Comments Georgia Industry Environmental Coalition (GIEC) & Georgia Coalition for Sound Environmental Policy (GCSEP) Georgia Paper & Forest Products Association, Inc. Georgia Power Sierra Club

8 GIEC/GCSEP/GPFPA/GP Include malfunctions
Consider manufacturer’s recommendations Expand list of control devices Treat EPA guidance as guidance, not rules

9 Sierra Club Exclude Malfunctions Not enforceable Not appropriate
Not protective

10 Other States… SC/TN/ND - removing SSM exemption
NC - WPS like Georgia (includes Malfunction) – won’t make deadline AL- Not sure yet – won’t make deadline

11 Timeline 11/22/16 - EPA SIP submittal deadline
6/9/16…DNR Board briefing package 9/8/16…DNR Board adoption package …Two months to tweak proposed rule based on stakeholder and EPA comments…

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