Georgia’s 112(g) Experiences Eric Cornwell Acting Manager Permitting Program

112(g)….aka 40 CFR 63 Subpart B Case by Case MACT 40 CFR – MACT for constructed or reconstructed Major sources

112(g) – Basics Applicability –New sources (greenfield plants or expansions) –Reconstructed sources –“Source” = whole process or production line –HAP major in and of itself –Permitted after June 29, 1998 –Not addressed by a promulgated MACT

112(g) in Georgia Since June 29, 1998, EPD has reviewed ~nine 112(g) permit applications: –6 for boat building and FRP facilities –2 Biomass-fired power plants –1 Coal-fired power plant

112(g) for Boats/FRP These were new or full expansions of boat/FRP products operations –Individual additions of gelcoat or lamination excluded from 112(g) citing example of “process” in 12/27/96 Federal Register EPD determination for 112(g) was short and simple: use proposed MACTs VVVV and WWWW (Presumptive MACT).

112(g) – Presumptive MACT EPD included standards and requirements of proposed MACTS into permit, but cited 112(g) in permit as applicable regulation. Corresponding narrative (statement of basis) explanation of 112(g) was kept to a minimum.

Example of 112(g) discussion in narratives for presumptive MACT “As a major source for hazardous air pollutants and because the new boat manufacturing line was constructed prior to the Boat Manufacturing NESHAP promulgation date, the new boat manufacturing line is subject to Section 112(g) of the 1990 Clean Air Act (40 CFR 63.40). The Division has opted to adopt the provisions of 40 CFR 63 Subpart VVVV, “National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing”, promulgated on August 22, 2001, as the Case-By-Case MACT determination for the facility until August 22, 2004 upon which the facility must comply with 40 CFR 63 Subpart VVVV. Therefore, this amendment also serves to incorporate conditions subjecting the operations relating to the manufacture of fiberglass boats to a Case-By-Case MACT determination under Section 112(g), and upon the compliance date, to the provisions of 40 CFR 63 Subpart VVVV. “

Presumptive MACT 112(g) 112(g) citations were typically removed from permit conditions upon Title V permit update (either initial permit or renewal) after the promulgation dates. Updated permit requirements to match final rule.

Biomass Plant #1 – July 2008 Proposed 400 MMBtu/hr (25MW) FBB plant burning chicken litter (higher HCl than wood) 112(g) applied due to vacatur of Boiler MACT PSD Minor Not in operation yet (limits not achieved in practice)

Biomass Plant #1 112(g) Pollutants Examined Total Selected Metals (inorganic HAPs) HCl Mercury Organic HAP (CO as surrogate)

Biomass Plant #1 - Controls Oxidization Catalyst – CO control; MACT inorganic control Dry Scrubber – SO2 control; MACT HCl control ESP – PM control; MACT mercury and TSM control SNCR - Nox control

Biomass Plant #1 – Proposed Limits Company proposed limits equal to those in vacated Boiler MACT using add-on controls. EPD review concluded that no more- restrictive limits for similar source were achieved in practice

Biomass Plant #1 – Permitted 112(g) Limits PollutantStandardControlsCompliance Assurance TSM3 x lb/MMBtu Dry Scrubber and ESP Annual stack test COMS HCl0.02 lb/MMBtuDry scrubberAnnual stack test SO2 CEMS Mercury3 x lb/MMBtu ESPAnnual stack test COMS CO (surrogate for organic HAP) lb/MMBtuOxidation catalyst CO CEMS

Biomass Plant #2 – Public Draft Proposed 1529 MMBtu/hr (110MW) FBB plant burning woody biomass 112(g) applied due to vacatur of Boiler MACT PSD Major Not in operation yet (limits not achieved in practice)

Biomass Plant #2 112(g) Pollutants Examined TSM (PM as surrogate) HCl Mercury Organic HAP (CO as surrogate)

Biomass Plant #2 - Controls Dry Scrubber – SO2 control; MACT HCl control Baghouse – PM control; MACT mercury and TSM (PM) control SNCR - NOx control

Biomass Plant #2 – Proposed Limits Company proposed limits equal to or more stringent that the MACT floor for biomass plants.

Biomass Plant #2 – Draft 112(g) Limits PollutantStandardControlsCompliance Assurance PM10 filterable (for TSM) lb/MMBtu baghouseAnnual stack test COMS HCl0.006 lb/MMBtu Dry scrubberAnnual stack test SO2 CEMS Lime rate monitoring Mercury2.5 x lb/trillionBtu BaghouseAnnual stack test COMS CO (surrogate for organic HAP) lb/MMBtu Good combustion CO CEMS