SSM SIP Call Georgia’s Response

Slides:

Advertisements

Similar presentations

Document Categorization Steve Ashbaker Director of Operations Joint Guidance Committee WECC Leadership Annual Training Session Salt Lake City, UT May 6-7,

Advertisements

METAL CAN SURFACE COATING MACT COMPLIANCE ASSURANCE 40 CFR PART 63, SUBPART KKKK June 2006 June CFR PART 63, SUBPART KKKK June 2006 June 2006.

METAL FURNITURE SURFACE COATING MACT COMPLIANCE ASSURANCE

METAL COIL SURFACE MACT COMPLIANCE ASSURANCE 40 CFR PART 63, SUBPART SSSS May 2006 May 2006.

Compliance Dates The final rule was published on January 25, 1995,

IRON & STEEL FOUNDRY MACT COMPLIANCE ASSURANCE

Mission: Mission: To protect human health and the environment Primary services: Expertise DEC brings to the ACMP Primary services: Expertise DEC brings.

Updating Title V Post Permit Forms Joseph A. Janecka, P.E., Air Program Liaison Field Operations Support Division TCEQ.

 We met with EPA last week to get their guidance on what we must do to get SIP approval for Section 107.  We were informed teat there is a “strong”

MSW LANDFILL MACT STANDARD DEVELOPMENT SWANA’s 22nd Annual Landfill Gas Symposium March 22-25, 1999 Michele Laur Emission Standards Division US Environmental.

EPA’S STARTUP, SHUTDOWN, AND MALFUNCTION PROPOSAL: IMPACTS AND IMPLICATIONS West Palm Beach, FL April 8, 2014 PRESENTED BY Randy E. Brogdon Troutman Sanders.

When “My Bad” Means You’re Bad EPA’s Renewed Focus on “Excess Emissions” Steve McKinney Air and Waste Management Association 2007 Annual Meeting & Technical.

Air Protection Branch 1. 2 Air Quality Activities Support the Mission of the Air Protection Branch Monitor and Report Air Quality Data Analysis and Planning.

NCMA Workshop March 24, 2015 Booker Pullen Supervisor, Permitting Section North Carolina Division of Air Quality, Raleigh, NC (919) Permitting.

1 Control Techniques Guidelines Joel Leon September 16, 2011.

ADEM Air Update Ron Gore November, National Issues EPA is delaying many controversial decisions and issues: Implementation of new SO 2 NAAQS Setting.

A&WMA Georgia Regulatory Update Conference Current State of the Air in GA Jac Capp, GA EPD, Branch Chief, Air Protection Branch April 16, 2013.

Air Toxics in Region 4 A&WMA Annual Conference August 6, 2008 Lee Page Air Toxics Assessment and Implementation Section EPA, Region 4 Atlanta, Georgia.

IOWA Department of Natural Resources Air Quality Program Development Jim McGraw Environmental Program Supervisor  8 hr Ozone and PM2.5 NAAQS Implementation.

NEW SOURCE REVIEW REFORM/SIMPLIFICATION JOHN A. PAUL STAPPA/ALAPCO MAY, 2002.

Wireless Password: Tri-State Generation and Transmission Association is… … a wholesale electric power supply cooperative with 44 member.

MS4 Remand Rule Intergovernmental Associations Briefing September 15, 2015.

Proposed Amendments to Enhanced Vapor Recovery Regulations November 18, 2004 Monitoring and Laboratory Division Air Resources Board California Environmental.

1 N.J.A.C. 7:27-21 Possible Revisions ISG Meeting September 14, 2010.

Welcome Revisions of Chapter WAC Sections -035 and -036 Rule advisory committee workshop #5 Lacey, WA October 28, 2009.

Bill Harnett WESTAR Spring Meeting March 30, 2010.

Best Available Retrofit Technology Rule - Colorado David R. Ouimette Colorado Air Pollution Control Division.

The Paper and Other Web Coating (POWC) MACT – Executive Summary The executive summary is a power point presentation designed to be used for basic education.

Region 9 Title V Permit Review Guidelines Ray Vogel EPA/OAQPS.

1 Exceptional Events Rulemaking Proposal General Overview March 1, 2006 US EPA.

NSR and Title V Activities WESTAR Business Meeting May 2005.

Current State Issues in Title V Permitting Matthew A. Paque Environmental Attorney Supervisor Oklahoma Department of Environmental Quality Office of General.

Update on Methane Regulations Affecting Landfills Pat Sullivan Senior Vice President SCS Engineers Nov. 10, 2015.

Indiana Chamber of Commerce Environmental Roundtable August 25, 2008 Thomas W. Easterly, P.E., DEE, QEP Commissioner, Indiana Department of Environmental.

Final Omitted Rulemakings Repeals: Employer Trip Reduction; Portable Fuel Container Requirements; and St. Joe Resources Company Emission Limits Environmental.

Concept – 15A NCAC 2D.0535 Start-up, Shutdown, Malfunction SSM SIP Call EMC – Air Quality Committee January 13, 2016.

Department of Environmental Quality

National Ambient Air Quality Standards (NAAQS)

Preparing for Permit Review

ISG Regulatory Update September 1, 2017

Final Rulemaking Nonattainment Source Review 25 Pa. Code, Chapter 121

Section Update: Monitoring & Planning

Clean Air Act (CAA) Purpose

DNR’s Smoke management Plan Update: Options, Tradeoffs, and Challenges

Georgia Update Jeff Cown Land Protection Branch

Department of Environmental Quality

CAIR Replacement Rule and Regional Haze

Department of Environmental Quality

Overview of New Source Review (NSR)

Georgia Air Regulatory Update

Julie Woosley, Division of Waste Management

Department of Environmental Quality

Department of Environmental Quality

GHG Permitting: Regulatory Update

90-Day NSR Study and NSR Improvements

Department of Environmental Quality

EMC – Air Quality Committee March 9, 2016

15A NCAC 2D Start-up, Shut-down, Malfunction SSM SIP Call

Exceptional Events Rulemaking Proposal

Department of Environmental Quality

Purpose Reflect changes in scientific understanding since 1994

Enforcing the NAAQS Case Study Sean Taylor

Exceptional and Natural Events Rulemaking

Kansas Air Quality Seminar March 5, 2008

Julie Woosley, Division of Waste Management

Air Update, Georgia EPD Karen Hays Chief, Air Protection Branch

RCRA Updates Larry L. Lamberth Enforcement and Compliance Branch

Air Permit Application Fees

Air Quality Committee May 13, 2015

Best Available Control Technology for Greenhouse Gas Emissions Sources

Presentation transcript:

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

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.

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

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)

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

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

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

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

Sierra Club Exclude Malfunctions Not enforceable Not appropriate Not protective

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

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…