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Georgia DNR Board Adopts Amended Air Rules

Misc. Rules Update:  https://epd.georgia.gov/sites/epd.georgia.gov/files/033117ProposedAmendments_Miscellaneous.pdf

  • Updates VOC definition for exempt solvents;
  • Revises the ambient air standards to be consistent with the NAAQS;
  • Removes the definition of “Regulated NSR Pollutant” to defer back to the federal definition;
  • Adds NSPS XXX (new MSW landfills);
  • Adds fire pumps to the SIP permitting exemption;
  • Eliminates PM2.5 nonattainment area NSR provisions (since attainment designation was issued); and
  • Adds fire pumps to the Title V insignificant activities list.

Cotton Gin Rule Update:  https://epd.georgia.gov/sites/epd.georgia.gov/files/033117ProposedAmendments_CottonGins.pdf

CSAPR Update:  https://epd.georgia.gov/sites/epd.georgia.gov/files/033117ProposedAmendments_CSAPR.PDF

  • Eliminates references to CAIR;
  • Incorporates CSAPR by reference;
  • Includes state annual trading budgets, new unit set-asides, and variability limits.

For questions, please contact your EPS consultant.

EPA Proposes to Redesignate Ozone Nonattainment Areas

As published in the Federal Register on 08/27/2015, EPA is proposing to redesignate 36 Ozone Nonattainment Areas, including Atlanta.  Based on the 2012-2014 design value, EPA determined that Atlanta did not attain the 2008 ozone NAAQS by July 20, 2015, thereby triggering a “bump up” in nonattainment classification from marginal to moderate.  The new attainment date is July 20, 2018.  The proposed SIP submittal due date is January 1, 2017 or March 1, 2017 (comment solicited).  Several federal standards, including CSAPR, Tier 3 vehicle standards, and Boiler MACT, are expected to support attainment efforts.  However, state agencies could find that additional NOx or VOC control measures (RACT rules) are needed.  Georgia EPD has indicated that it intends to certify 2013-2015 ozone monitoring data in support of a request to redesignate to attainment.

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EPA Releases Revised Framework for Biogenic CO2 Accounting

On 11/19/14, EPA released a revised framework for assessing biogenic CO2 emissions from stationary sources.

  • For the Clean Power Plan, EPA expects to recognize biogenic CO2 emissions and climate poly benefits of waste-derived and certain forest-derived industrial byproduct feedstocks, support states’ efforts in using biomass power to met the CPP goals.  EPA also mentions that sustainably-derived agricultural and forest-derived feedstocks may also be an approvable element of CPP compliance plans.
  • For PSD, EPA plans rule revisions to exempt from BACT requirements waste-derived feedstocks and non-waste biogenic feedstocks derived from sustainable forest or agricultural practices.  This is based on EPA’s position that biogenic CO2 emissions are likely to have minimal or no net atmostpheric contributions of CO2 or even reduce such impacts when compared to an alternate fate of disposal.

Janet McCabe Memo:  http://www.epa.gov/climatechange/downloads/Biogenic-CO2-Emissions-Memo-111914.pdf

EPA Framework Document:  http://www.epa.gov/climatechange/downloads/Framework-for-Assessing-Biogenic-CO2-Emissions.pdf

EPA website:  http://www.epa.gov/climatechange/ghgemissions/biogenic-emissions.html

Gas-Fired Boiler MACT Facility? Prepare… Now

The compliance date for the Boiler MACT is January 31, 2016, but facilities should be preparing now.  Facilities that are subject to emissions limits (solid fuel and liquid fuel boilers) are likely well under way in their compliance plans, including emissions and fuels testing and monitoring equipment installation.  But, facilities that only burn natural gas (with or without fuel oil for curtailment and testing) should also be preparing.  Much of the work to comply with the Boiler MACT will need to be completed in 2015; therefore, facilities may need to make budgetary plans this year to include:

  • Determine if elective fuel oil firing is a possibility in the future – natural gas costs may rise making fuel oil more attractive.  If facilities want this option, engineering stack testing and fuel testing should be conducted to assess compliance.
  • Identify a “qualified energy assessor” and obtain a quote for the one-time energy assessment.
  • Locate a contractor and obtain a quote to perform boiler and process heater tune-ups.
  • Re-check your process heater list to make sure you have not missed any subject units, ask “How is this process heated?  Indirect or direct-fired?”.

The Boiler MACT has been remanded back to EPA to address reconsideration of several aspects of the rule.  However, the rule has not been vacated, and there is no current indication that the compliance date will be changed (but that is a possibility).

Questions?  Contact your EPS consultant.