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Draft Georgia Rule 391-3-1-.02(2)(sss) Startup, Shutdown, and Malfunction Provisions

Draft Georgia Rule 391-3-1-.02(2)(sss) Startup, Shutdown, and Malfunction Provisions. CAMR Q&A Meeting January 17, 2007. Background on Draft Georgia Rule (sss).

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Draft Georgia Rule 391-3-1-.02(2)(sss) Startup, Shutdown, and Malfunction Provisions

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  1. Draft Georgia Rule 391-3-1-.02(2)(sss)Startup, Shutdown, and Malfunction Provisions CAMR Q&A Meeting January 17, 2007

  2. Background on Draft Georgia Rule (sss) • Draft Georgia Rule (sss) provides a schedule for the operation of multi-pollutant air pollution controls on applicable coal-fired EGUs in Georgia. The only requirement is that the owner/operator may not operate the equipment after specific date unless the applicable unit is controlled as noted. • There are no performance requirements for the required air pollution controls imposed by Georgia Rule (sss) • Draft PTM changes address the performance requirements of these controls in light of the fact that no performance requirements are imposed in Georgia Rule (sss).

  3. SSM Questions • Should Draft Georgia Rule (sss) apply during periods of startup, shutdown, and malfunction of an applicable EGU? • What are the existing applicable regulations in which the EGUs are subject to during periods of SSM? • How are periods of SSM handled in Title V permit language? Would any Title V permit “template” language need to be revised if Georgia Rule (sss) did not apply during periods of SSM?

  4. Definitions • Startup is defined in Georgia Rule 391-3-1-.01(zzz) as the “commencement of operation of any source”. • Shutdown is defined in Georgia Rule 391-3-1-.01(jjj) as the “cessation of the operation of a source or facility for any purpose”. • Malfunction is defined in Georgia Rule 391-3-1-.01(nn) as “mechanical and/or electrical failure of a process, or of air pollution control process or equipment, resulting in operation in an abnormal or unusual manner.”

  5. Treatment of SSM Under Existing Regulations – (1) • The following rules are typically applicable to the EGUs in question and they do apply during periods of SSM: • Georgia Rule (d) – PM and/or opacity standard. • Georgia Rule (b) – Opacity standard. • Georgia Rule (jjj) – Rolling 30-day average of NOx emissions in pound per million Btu.

  6. Treatment of SSM Under Existing Regulations – (2) • The following rules are typically applicable to the EGUs in question and they do apply during periods of SSM: • Acid Rain – NOx and/or SO2 budgets • 391-3-1-.02(2)(a)10 – “Good Air Pollution Control Practice” as found in Title V “template” permit condition 8.17.1.

  7. Georgia Rule (sss) and Title V Permits (1) • Once Georgia Rule (sss) becomes applicable: • Does this state rule impose a“work practice standard or requirement” as contained in Title V Permit Condition 6.1.3 and if so, does this permit condition apply?

  8. Georgia Rule (sss) and Title V Permits (2) • Once Georgia Rule (sss) becomes applicable: • Periods of excursions (as defined in draft PTM Section 2.124) would need to be reported in accordance with Title V Permit Condition 6.1.4.?

  9. Georgia Rule (sss) and Title V Permits (3) • Once Georgia Rule (sss) becomes applicable: • Does Title V Permit Condition 8.14.4 apply [391-3-1-.02(a)7 – Excess Emissions? • Does Title V Permit Condition 8.17.1 apply? If so, does draft PTM Section 2.124.2(b) address this “conflict”?

  10. Draft Georgia Rule (sss) SSM Provisions – (1) • New paragraph 17 along with Draft PTM Section 2.124: • Does not require compliance with this draft rule or the “Good Air Pollution Control Practice” provision during periods of SSM.

  11. Draft Georgia Rule (sss) SSM Provisions – (2) • Owner/operator may choose to not operate required control technology under the following conditions: • Black Start • Startup and/or shutdown of an EGU according to mfg recommendations

  12. Draft Georgia Rule (sss) SSM Provisions – (3) • Owner/operator may choose to not operate required control technology under the following conditions: • Periods of malfunction of EGU and/or control technology equipment; • Periods of scheduled and/or preventative maintenance of the APC if not performed during EGU outage. • Any other occassions as approved by the Division.

  13. Draft Georgia Rule (sss) SSM Provisions – (3) • New paragraph 18: • The SSM provisions do not relieve the owner/operator from the requirements to comply with any other applicable requirements in GR 391-3-1. • Should Yates Unit 1 be added to SSM provisions?

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