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

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.

Nuclear Plant

Ga-Pacific

Longleaf

CR-103

Old C

edar Springs Rd.

Wilk

ie M

osel

y R

d.

Air Permit – PSD Summary, Key Requirements

• Best Available Control Technology (BACT)

• Air Quality Analysis

• Additional Impact Analysis

• Class I Area Impact Analysis

• Public Participation

Coal Fired Power Plants in Georgia

1500-2000 MW

500-999 MW

< 300 MW

> 3000 MWHAMMOND

BOWEN

MCDONOUGH

YATES

WANSLEYSCHERER

BRANCH

MCINTOSH

KRAFT

MITCHELL

LONGLEAF?

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”

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.

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)

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)

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.

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.

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.

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.

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 acresUsable: 289 acres

• Estimated Life of Proposed Site: 35 years• Waste Volume: 28,611,885 cubic yards.

Watershed Protection Permits

• Wastewater Discharge Permit

• Water Withdrawal Permits

Water Withdrawal Permits

• Proposed Longleaf Energy Station

• Existing Great Southern Paper Company (Georgia Pacific)

Longleaf

ChattahoocheeRiver

GeorgiaPacific

Withdrawals and Discharges

• Monthly Average Flow (MGD)

25

115cooling

process

7

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.

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.

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.

Permitted Sub-Discharges

• The permit covers:– Low volume waste– Coal pile runoff– Chemical metal cleaning waste– Cooling tower blowdown– Final plant discharge

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

Additional Permit Requirements

• Plan of Operation • Self monitoring program• Quarterly reports submitted to EPD• Monitoring for:

– biochemical oxygen demand– dissolved oxygen– temperature – phosphorus

Fish Tissue Mercury Trend Monitoring

Water Permits Summary

• Consumptive water use is about 18 million gallons per day

• Substantial reduction in oxygen-demanding materials discharged

• Effect of color reduced

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.