Georgia EPD – Public Meeting Regarding Proposed Longleaf Energy Plant October 17, 2006

1. Georgia EPD – Public Meeting Regarding Proposed Longleaf Energy PlantOctober 17, 2006 Jim Ussery – Assistant Director, Georgia EPD Jac Capp – Air Protection Branch of EPD Jeff Cown – Land Protection Branch of EPD Linda MacGregor – Watershed Protection Branch of EPD

2. Air Permit – Key Dates • November 19, 2004 – Application Submitted. • January 23, 2006 – 1st Q & A Session in Blakely. • September 20, 2006 – Public Notice of Draft Permit in Early County News. • October 17, 2006 – 2nd Q & A Session in Blakely. • November 9, 2006 – Public Hearing on Draft Permit in Blakely. • November 16, 2006 – Deadline for submitting written comments to EPD on Draft Air Permit.

3. Old Cedar Springs Rd. CR-103 Longleaf Nuclear Plant Wilkie Mosely Rd. Ga-Pacific

4. Air Permit – PSD Summary, Key Requirements • Best Available Control Technology (BACT) • Air Quality Analysis • Additional Impact Analysis • Class I Area Impact Analysis • Public Participation

5. Coal Fired Power Plants in Georgia HAMMOND > 3000 MW BOWEN 1500-2000 MW MCDONOUGH 500-999 MW YATES BRANCH < 300 MW WANSLEY SCHERER MCINTOSH KRAFT MITCHELL LONGLEAF?

6. Air Permit – IGCC as BACT • IGCC (Integrated Gasification Combined Cycle) determined to be “redefinition of the basic design of the source.” • Thoroughbred (Kentucky) Decision – April 11, 2006 (Appealed in Franklin Circuit Court of Kentucky, May 10, 2006). • EPA letter from Stephen Page, Director of OAQPS, December 13, 2005. Note – This letter is guidance, it is not final agency action (EPA settlement agreement). • NSR Workshop Manual (1990) pg. B.13 – BACT requirement should not “redefine the design of the source”

7. Air Permit – Need for Electricity • Georgia EPD does not consider need for electricity in the permitting process. • Georgia Law has given that authority to the Georgia Public Service Commission (PSC). • To the extent that new electric energy generation is deregulated, that issue is still under the purview of the Georgia PSC.

8. Air Permit – Potential to Emit • PM10, 1805 tons/year • (PM2.5 component concern for PM2.5 NAAQS) • NOX, 3783 tons/year • (concern for both Ozone and PM2.5 NAAQS) • SO2, 6456 tons/year • (concern for PM2.5 NAAQS) • Mercury, 0.11 tons/year (220 lbs) • Potential to Emit based on operation at maximum rate, non-stop, on highest-emitting fuel. • Actual emissions will be lower based on, primarily, operation of the facility at anywhere from 25-85% of capacity and with a margin of compliance of ~ 25% (actual emissions rate @ 75% of permitted rate)

9. Air Permit – New Statewide Rules for Mercury, NOX, and SO2 • Georgia is requiring significant reductions in Mercury, NOX, and SO2 from new and existing coal-fired power plants. Because the Mercury and SO2 controls will also reduce PM10/PM2.5 emissions, significant reductions statewide will also occur for this pollutant. • Mercury: 1.89 tons, actual Power Plant emissions in 2005 • 1.23 tons/year for Phase I CAMR (2010-2017) • 0.48 tons/year for Phase II CAMR (2018 and beyond) • EPD is requiring source specific controls and expects actual emissions to be lower than these levels (particularly for Phase I). • NOX: 111,379 tons, actual Power Plant emissions in 2005 • 66,321 tons/year for Phase I (2009-2014) • 55,268 tons/year for Phase II (2015 and beyond) • SO2: 616,168 tons: actual power plant emissions in 2005 • 213,057 tons/year for Phase I (2010-2014) • 149,140 tons/year for Phase II (2015 and beyond)

10. Air Permit – PM2.5 and Ozone NAAQS • Nearest nonattainment area for either (both) pollutant is Macon, GA. • Deadlines for EPD to submit rules/plans for all PM2.5 and Ozone nonattainment areas are still in the future. • EPD is actively working on rules/plans to bring all the areas into attainment for these NAAQS. • Reductions in NOX, SO2, and PM2.5 described in previous slide will be a significant part of these plans.

11. Air Permit – Ambient Monitoring After the Plant is Built • Agreement between company and EPD to install and operate ambient monitors for the following pollutants: • SO2, PM2.5 (or PM10), Mercury • Monitoring will start at least 12 months before the facility commences operation and will continue until the facility has been in operation for at least 2 years (more than 3 years total). • Agreement between company and EPD will be finalized no later than the date a final permit is issued.

12. Land ProtectionSolid Waste Permitting • The Georgia Comprehensive Solid Waste Management Act and Rules for Solid Waste Management require that a solid waste handling permit be issued to the facility owner before the facility may handle solid waste. • Longleaf Energy submitted an application for a solid waste handling permit on August 17, 2005. • If approved, the permit would be issued for a Private Industry Solid Waste Landfill and is required due to the facility’s intention to dispose of solid waste generated from plant operations.

13. Solid Waste Permitting • Wastes that would be disposed of in the proposed landfill would include: • Non-hazardous, non-liquid, non-putrescible solid waste generated from plant operations including combustion wastes (waste coal & coal mill rejects) • Other wastes including cooling tower sediments, cooling water screenings, construction/demolition debris, sump pit sediments, water treatment sludges, sediments & resins, fire brick & refractory materials, non-hazardous sand blast media, and sediments from dredging operations • Any trash or putrescible wastes would be transported to a permitted, offsite facility.

14. Solid Waste Permitting • No hazardous substances are expected in the process. • Amended Site Limitations were issued on September 13, 2006. Draft design and operational plan: • Area of proposed site – Total: 401 acres Usable: 289 acres • Estimated Life of Proposed Site: 35 years • Waste Volume: 28,611,885 cubic yards.

15. Watershed Protection Permits • Wastewater Discharge Permit • Water Withdrawal Permits

16. Water Withdrawal Permits • Proposed Longleaf Energy Station • Existing Great Southern Paper Company (Georgia Pacific)

17. Monthly Average Flow (MGD) Withdrawals and Discharges 115 Georgia Pacific cooling Chattahoochee River process 25 Longleaf 7

18. Water Withdrawal Permit Requirements • Water Metering Plan • Water Conservation Plan • Longleaf’s primary source is Georgia Pacific treated wastewater and cooling water. • Longleaf will only use Chattahoochee River water under certain circumstances • Longleaf will share Georgia Pacific’s intake structure • The total water withdrawn can not exceed the amount in Georgia Pacific’s existing surface water withdrawal permit.

19. Wastewater Discharge Permit • One combined discharge to the Chattahoochee River • Georgia rules have created instream concentration limits for certain metals, pesticides and other organic chemicals. • EPD has performed calculations to determine if a reasonable potential exists for the proposed facility’s effluent to exceed Georgia water quality standards.

20. Wastewater Discharge Permit • Based on this analysis, the proposed wastewater discharge would not cause an exceedance of the water quality standards in the Chattahoochee River.

21. Permitted Sub-Discharges • The permit covers: • Low volume waste • Coal pile runoff • Chemical metal cleaning waste • Cooling tower blowdown • Final plant discharge

22. Discharge Limitations • pH: 6-9 standard units • Internal waste streams have limitations for: • total suspended solids • oil and grease • copper • chromium • iron • zinc • priority pollutants • chlorine

23. Additional Permit Requirements • Plan of Operation • Self monitoring program • Quarterly reports submitted to EPD • Monitoring for: • biochemical oxygen demand • dissolved oxygen • temperature • phosphorus

24. Fish Tissue Mercury Trend Monitoring

25. Water Permits Summary • Consumptive water use is about 18 million gallons per day • Substantial reduction in oxygen-demanding materials discharged • Effect of color reduced

26. EPD Permit Review and Issuance • The Division will consider all comments made regarding these draft permits before deciding whether or not to issue a permit. • If approved, the final permits and narratives will be made available at our offices and EPD’s website. Responses to comments made tonight will be a part of the final documentation.