EPA Nonattainment New Source Review Updates – Georgia

On September 9, 2019, the US Environmental Protection Agency (EPA) released an Air Plan Approval that will grant approval of proposed changes to Georgia’s Nonattainment New Source Review (NNSR) permitting rules, proposed in Georgia’s July 2, 2018 SIP revision. The proposed changes have already been implemented by the Georgia Environmental Protection Division (GA EPD), and this Air Plan Approval is the EPA saying that it is okay for the GA EPD to continue implementation and begin enforcement.

The proposed changes include the removal of the NNSR provision specific Bartow, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, and Rockdale counties and the removal of references to that provision and application of permitting requirements to certain electric generating units (EGUs). Georgia is removing the current rule in place, Rule 391-3-1-.03-(8)(c)(13), which applied “severe” ozone nonattainment NNSR requirements to counties formerly included in the Atlanta 1-hour Ozone Area. This defined major sources to include facilities with the potential to emit at least 25 tons per year of VOC or NOx, identified the net emissions increase triggering the permitting requirement as a result of a physical or operational change, and set emissions offset to a ratio of 1.3:1.

The proposed changes to Rule 391-3-1-.03(8)(c)(14) add the 13 counties from Rule 391-3-1-.03-(8)(c)(13) and remove 5 counties (Barrow, Carrol, Hall, Spalding, and Walton). With those changes, Rule 391-3-1-.03(8)(c)(14) applies to all of the following counties: Bartow, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, and Rockdale. Now, those counties define major sources to include facilities with the potential to emit at least 100 tons per year of VOC or NOx, as opposed to the previous 25 tons per year, and sets emissions offset to a ratio of 1.15:1. This switch in designation for facilities in the 13 added counties will be beneficial for any facility that became “major source” due to their potential VOC or NOx emissions being above 25 tons per year but less than 100 tons per year.

The five counties (Barrow, Carrol, Hall, Spalding, and Walton) removed from Rule 391-3-1-.03(8)(c)(14) are proposed to be added to the “Additional Provisions for Electrical Generating Units Located in Areas Contributing to the Ambient Air Level of Ozone in the Metropolitan Atlanta Ozone Non-Attainment Area” at Rule 391-3-1-.03(8)(c)(15). This will require Best Available Control Technology (BACT) for the units subject to the permitting requirement and reduce emissions offset to a ratio of 1.1:1 from 1.15:1. This rule only applies for facilities that have a potential to emit at least 100 tons per year of NOx from electrical generating units, such as boilers, generators, etc.

If your facility is within Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, or Rockdale county, and has potential VOC or NOx emissions over 25 but less than 100 tons per year, your facility may be able to apply to become a “minor source”. However, there are still state-specific emission limitations that may prevent the change is permitting classification.

If your facility is within Barrow, Carrol, Hall, Spalding, or Walton county, your facility is now subject to Rule 391-3-1-.03(8)(c)(15), including the BACT requirements for electrical generating units. Again, this rule only applies for facilities that have a potential to emit at least 100 tons per year of NOx from electrical generating units.

Conversion Technology Inc. (CTI) has decades of experience in air compliance with the EPA and Georgia Environmental Protection Division. We will continue to monitor the status of proposed amendments and provide updates as necessary. If you need help in maintaining compliance with any air compliance standards, or if you would like help determining if your facility can apply to be a minor source and navigate through the GA EPD and EPA requirements, please contact us at (770) 263-6330 or cti@conversiontechnology.com.

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