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EPA Region IV December 11-12, 2007 Atlanta, GA . Case Study: Permitting Mississippi’s Experiences. Three Permitted Sites None have completed construction Two Sites with Permits Pending One received approval to begin construction prior to receiving permit
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EPA Region IV December 11-12, 2007Atlanta, GA Case Study: Permitting Mississippi’s Experiences
Three Permitted Sites None have completed construction Two Sites with Permits Pending One received approval to begin construction prior to receiving permit Met specific criteria for pre-permit construction approval One application is under our normal processing Ethanol Production
Processing efficiency has improved during the last 30 years. In 2005, the use of ethanol reduced the U.S. trade deficit by $8.7 billion by eliminating the need to import 170 million barrels of oil. Source: LECG, LLC January 2006 Ethanol Production
Nine Permitted Sites Only a few have been constructed and are producing. Biodiesel
Two Sites with Permits Pending Additional Pre-Application Meetings Conducted Biodiesel
Production Incentives 2002 Farm Bill Commodities Credit Corporation MS House Bill 1130 of 2002 Established ethanol production incentives outlined in MS Code 69-51-5. MS House Bill 960 of 2005 Revised 69-51-5 to include biodiesel production incentives MS 69-51-5 remains an unfunded program Tax Incentives IRS Tax Credits Driving Factors
Clean Air Act New Source Review Major Source Threshold? New Source Performance Standards NESHAP Specific MACT? State Requirements Applicable Air Emission Regulations
Clean Water Act NPDES Effluent Guidelines? NPDES Storm Water State Requirements Pretreatment Effluent Guidelines? Pretreatment SIU? No Discharge Permit? Applicable Wastewater and Storm Water Discharges
Very little from EPA prior to 2006 Considered what other states had done in permitting Varied somewhat Practical Guidance
Most proposed ethanol and biodiesel production facilities identified 2869 as the appropriate SIC Code. (Industrial Organic Chemicals, Not Elsewhere Classified) EPA clarified the major source threshold for NSR May 1, 2007. Evaluate NSPS applicability Subparts A, RRR, NNN, VV, etc. Evaluate MACT applicability Subparts A, B, FFFF, GGGG, etc. Conservative Approach Air Emissions
Multimedia Guidance for Ethanol Production http://www.epa.gov/region07/priorities/agriculture/ethanol_plants_manual.pdf
NPDES Storm Water Construction NPDES Storm Water Baseline NPDES Non-Storm Water Discharges Process Applicable Effluent Guidelines? Non-Process Pretreatment (Indirect) Discharges Wastewater Treatment with No Discharge Facility Discharges
Bryan Collins, P.E., BCEE Chief, Energy & Transportation Branch Environmental Permits Division Mississippi Department of Environmental Quality 601-961-5239 Bryan_Collins@deq.state.ms.us Contact Information