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EPD ANSWERS COMMUNITY QUESTIONS

Karen Hays, responds to questions from 12/5/19 community meeting:


1. Is Georgia Renewable Power permitted to burn and form of municipal solid waste? (example – household garbage?).

EPD response: No, Georgia Renewable Power (GRP) is not permitted to burn municipal solid waste.

2. What specific feed stocks/fuels are allowed to be burned by Georgia Renewable Power under their existing permits?

EPD response: GRP is allowed to burn clean cellulosic biomass, which can include clean construction and demolition wood and railroad ties. Definitions, details, and restrictions are contained in three permit conditions, which are shown below:

Permit condition 2.5 (both GRP Madison and GRP Franklin):

The Permittee shall only fire clean cellulosic biomass, which may include clean construction and demolition wood, creosote treated railroad ties, creosote-borate treated railroad ties, copper naphthenate treated railroad ties, copper naphthenate-borate treated railroad ties, and distillate fuel oil in the boiler (Source Code: B001). “Clean cellulosic biomass”, “creosote treated railroad ties”, “creosote-borate treated railroad ties”, “copper naphthenate treated railroad ties”, and “copper naphthenate-borate treated railroad ties” are defined in Condition 2.9 and 40 CFR 241.

Permit condition 2.9 (both GRP Madison and GRP Franklin):

For the purposes of this Permit:

Clean cellulosic biomass means those residuals that are akin to traditional cellulosic biomass, including, but not limited to: Agricultural and forest-derived biomass (e.g., green wood, forest thinnings, clean and unadulterated bark, sawdust, trim, tree harvesting residuals from logging and sawmill materials, hogged fuel, wood pellets, untreated wood pallets); urban wood (e.g., tree trimmings, stumps, and related forest-derived biomass from urban settings); corn stover and other biomass crops used specifically for the production of cellulosic biofuels (e.g., energy cane, other fast growing grasses, byproducts of ethanol natural fermentation processes); bagasse and other crop residues (e.g., peanut shells, vines, orchard trees, hulls, seeds, spent grains, cotton byproducts, corn and peanut production residues, rice milling and grain elevator operation residues); wood collected from forest fire clearance activities, trees and clean wood found in disaster debris, clean biomass from land clearing operations, and clean construction and demolition wood. These fuels are not secondary materials or solid wastes unless discarded. Clean biomass is biomass that does not contain contaminants at concentrations not normally associated with virgin biomass materials.

Any wood that has been treated with compounds such as chromate copper arsenate or comingled with such compounds or lead is not considered clean cellulosic biomass.

“Creosote treated railroad ties” means railway support ties treated with a wood preservative containing creosols and phenols and made from coal tar oil.

“Creosote-borate treated railroad ties” means railroad ties treated with a wood preservative containing creosols and phenols and made from coal tar oil and borate, including borate made from disodium octaborate tetrahydrate.

“Copper naphthenate treated railroad ties” means railroad ties treated with copper naphthenate made from naphthenic acid and copper salt.

“Copper naphthenate-borate treated railroad ties” means railroad ties treated with copper naphthenate and borate, including borate made from disodium octaborate tetrahydrate.

Permit condition 2.19 (both GRP Madison and GRP Franklin)

Prior to burning creosote treated railroad ties, creosote-borate treated railroad ties, copper naphthenate treated railroad ties, or copper naphthenate-borate treated railroad ties in the boiler (Source Code: B001), the railroad ties shall be processed by, at a minimum, metal removal and shredding or grinding.

3. After they burn their waste, what are they doing with the ash that remains?

EPD response: GRP reported to EPD that the ash is contracted to Cementitious Solutions for removal. GRP stated that Cementitious Solutions sells some of the ash to a farmer who uses it as a lime/nutrient substitute. GRP said the farmer has an approval from the Department of Agriculture. GRP reported the remainder of the ash is removed by Cementitious Solutions is taken to the Gainesville Waste and Recycling facility.

4. Who tests the ash and how often is it tested?

EPD response: GRP stated that the required TCLP (TCLP is an acronym for toxicity characteristic leaching procedure) analysis has been done. EPD has requested the results but has not received them yet.

5. Where is the ash disposed?

EPD response: GRP contracts with Cementitious Solutions to remove and dispose of the ash. Cementitious Solutions sells some of the ash to a farmer and provides the rest of it to the Gainesville Waste and Recycling facility.

6. Have water, soil, and/or gaseous samples been collected and tested for known toxins in the immediate vicinity of the biomass power plant?

a. If so, have the results of these tests come back?

EPD response: Water samples were collected in the stream and pond downstream from the Facility’s stormwater pond on December 12, 2019. A rush on the analysis has been requested. EPD anticipates getting the results before the end of the year. Samples are being analyzed for metals, volatiles and semi-volatiles for which EPD has water quality criteria.

b. What do the data based predictions/projections look like?

EPD response: The facility submitted a national pollutant discharge elimination system (NPDES) permit application which characterized the proposed effluent discharge. However, EPD has asked them to resubmit the application to correct deficiencies in the original submittal.

7. When did the plant begin to burn railroad ties?

a. Was there a public announcement/warning?

EPD Response: GRP received an amendment to their air quality permit in July 2019 to burn railroad ties in the boiler. EPD issued a public advisory for the addition of this new fuel type on June 6, 2018, the advisory was emailed to those on the subscriber list (you can sign up at https://epd.georgia.gov/public-announcements-0/air-protection-branch-public-announcements/subscribe-air-protection-branch) and posted to EPD’s webpage. No comments were received.

8. When will the runoff and ground water be tested for carcinogens?

EPD response: Water samples were collected in the stream and pond downstream from the Facility’s stormwater pond on December 12, 2019. A rush on the analysis has been requested. EPD anticipates getting the results before the end of the year. Samples are being analyzed for metals, volatiles and semi-volatiles for which we have water quality criteria.

a. Is the water paid for and by whom?

9. How can dust be controlled at the plants?

a. What efforts have been made to contain dust? We see dust at the plant daily with no evidence of dust control.

EPD response: Permit Conditions 3.2.1 and 3.2.2 state the air quality rules for fugitive dust (Chapter 391-3-1-.02(2)(n).

Permit condition 3.1 (both GRP Madison and GRP Franklin):

The Permittee shall take all reasonable precautions with any operation, process, handling,

transportation, or storage facilities to prevent fugitive emissions of air contaminants.

Permit condition 3.2 (both GRP Madison and GRP Franklin):

The Permittee shall comply with Georgia Air Quality Control Rules 391-3-1-.02(2)(n),

“Fugitive Dust”, for the entire processing facility including all roadways and processing

equipment not otherwise subject to any other rule or regulation governing fugitive visible

emissions. Subject to this rule, the Permittee shall not cause, let, permit, suffer or allow

visible emissions from any fugitive source to equal or exceed 20 percent opacity.

GRP’s permits require control of the dust emissions or particulate matter (PM) that are generated as a result of their operations. The majority of GRP’s particulate matter (over 99%) is generated by their wood biomass fired stoker boiler (the boiler). Particulate matter from the boiler is controlled via the use of a cyclone and a high voltage electrostatic precipitator (ESP); these devices control particulate matter emissions. The devices have been designed to have an expected control efficiency of 98.8% particulate matter removal efficiency. The allowable particulate matter emission rate from the boiler is 0.03 lb/MMBtu heat input. Required particulate matter performance tests were conducted in November 2019 and final results will be submitted to the Division by the end of January 2020 for review.

The other type of particulate matter emissions is categorized as “fugitive emissions,” (particulate matter emissions that are not released via an emissions stack). GRP has stated to EPD that they are currently working on the following measures to mitigate fugitive emissions:

· GRP is implementing a program to ensure the fuel quality that is delivered to the facility. GRP will ensure that vendors deliver certain sizes of wood chips and refuse sawdust like materials in order to minimize fugitive emissions.

· GRP will install dust suppression spray systems at all fuel transition points to better control dusting.

· GRP is installing a retractable-chute at the fuel stack-out conveyor that can be operated remotely by an operator. The retractable chute will minimize drop heights and minimize fugitive emissions.

· GRP is investing in a fly-ash conditioning system (also known as a pugmill). This system will allow the transfer/loading of fly ash to occur without generating fugitive emissions.

· GRP will implement certain Standard Operating Procedures (SOP), that will direct personnel when to or not to engage in certain activities that could lead to an increase of fugitive emissions.

10. What engineering controls are in place at GRP?

a. Are these controls sufficient to mitigate the known chemicals of public health concern produced by the burning of biomass materials?

EPD Response: Yes. GRP’s air permit application review included an assessment of the expected emissions to ensure that the resulting air quality permit is protective of human health. This assessment (called the Toxic Impact Assessment, or Toxic Guidelines) uses US EPA-developed computer simulations to estimate the offsite concentrations of the air toxics that are expected to be emitted. That value is then compared to a screening level. Based on the information contained in the permit applications submitted by GRP, the concentrations of air toxics were all below the screening level. The facility conducted emissions testing in November 2019 to confirm the results of the assessment. The results of the testing are due to EPD in January for review.

11. Regarding the filter that is supposed to protect the people living close to the plant –

a. How often will it be replaced?

b. Is it safe when it gets dirty?

EPD response: The filter that controls particulate matter emissions is commonly called a “baghouse”. This technology is frequently used by industries to control particulate matter emissions due to the high efficiency. The baghouse has hundreds of filter bags organized in parallel. The filter bags are designed to last several years before replacement. If a filter bag develops a leak, symptoms of that leak will be detected due the use of a “Continuous Opacity Monitor” (COM) that measures the amount of smoke coming out the stack.

The baghouse is equipped with a cleaning mechanism to purge the filter bags periodically. The purged dust goes into a bin to be collected and sent to a landfill.

12. What is “clean c&d” and how is it produced?

EPD response: EPD’s Solid Waste Management Rules do not define “clean c&d” (construction & demolition). However, the rules define Construction/Demolition Waste as “waste building materials and rubble resulting from construction, remodeling, repair, and demolition operations on pavements, houses, commercial buildings and other structures. Such waste includes, but are not limited to asbestos containing waste, wood, bricks, metal, concrete, wall board, paper, cardboard, inert waste landfill material, and other nonputrescible wastes which have a low potential for groundwater contamination” (Solid Waste Management Rules, Chapter 391-3-4-.01(18)). EPD does define “clean concrete” in its guidance for “Use of Recovered Clean Concrete and/or Cured Asphalt as a Structural Fill Material”. In this guidance “clean concrete” is defined as concrete that is free of added paints, insulators, reinforcing materials, sealers, or any other material, which would have a potential for contaminating groundwater.

13. Who monitors the sorting process with c&d materials?

EPD response: GRP is responsible for monitoring the C&D materials generated on-site and properly processing or transporting it to a solid waste handling/disposal or recovered materials site. EPD requested GRP review all of their solid waste streams to ensure that solid waste is being directed to the appropriate facility.

14. a. Who samples the air emissions out of the smoke stack? b. Where are the waste by products disposed of?

EPD response: The primary waste by-product is ash. As noted in the responses for questions 4 & 7, GRP has stated that the ash is being taken to a farmer for land application and to the Gainesville Waste and Recycling facility.

15. Is it too late to prevent soil and water pollution if the plant removes the cross ties and stops burning them?

EPD response: EPD has issued a Notice of Violation dated December 9, 2019 for violations of the Georgia Water Quality Control Act. EPD will ensure that the facility gets into compliance, which will protect from harm resulting from water pollution.

16. Has the EPA amended the NHSM (non-hazardous secondary materials) under RCRA to identify whether non-hazardous secondary materials are solid wastes when used as fuel or ingredients?

a. Specifically – did they add creosote treated railroad ties that are processed and combusted in units designed to burn both biomass and fuel oil?

EPD response: Yes, in EPA’s February 7, 2018 final rule to amend the CFR part 241 standards for combustion of Non-Hazardous Secondary Materials, creosote-borate and mixtures of creosote, copper naphthenate and copper naphthenate-borate treated railroad ties were added to the list of categorical non-waste fuels that can be burned in units designed to burn both biomass and fuel oil.

b. Has the stream water been tested? (suggested – implement testing of water, land, and air for chemicals)

EPD response: Water samples were collected in the stream and pond downstream from the Facility’s stormwater pond on December 12, 2019. A rush on the analysis has been requested. EPD anticipates getting the results before the end of the year. Samples are being analyzed for metals, volatiles and semi-volatiles for which EPD has water quality criteria.

17. When will the burning of railroad ties end?!

a. How is it they are allowed to burn the railroad ties?

EPD response to a. and b.: The air quality permit amendments issued to GRP’s Franklin and Madison facilities in April 2019 allow the burning of clean cellulosic biomass, which can include clean construction and demolition wood and railroad ties. Details, restrictions and definitions are contained in the three permit conditions listed under Question 2.

b. Why is this permitted?

EPD response: The Air Protection Branch’s Stationary Source Permitting Program reviewed GRP’s applications requesting to be allowed to burn up to 20% railroad ties in the boilers and determined that:

· US EPA approved environmental regulations classifying railroad ties as “not solid waste” for use as fuel in boilers provided that certain requirements are met.

· The emissions resulting from combustion of railroad ties in the boiler are not expected to be significantly different from the emissions from burning only “clean cellulosic biomass” as originally permitted.

· There are no environmental provisions or reasons prohibiting the use of railroad ties as fuel in a well-controlled boiler.

c. What legal background allows the burning of crossties?

EPD response: In 2018 EPA finalized changes to 40 CFR 241.4 (Non-Waste Determinations for Specific Non-Hazardous Secondary Materials When Used as a Fuel) that added “Creosote-borate treated railroad ties, and mixtures of creosote, borate and/or copper naphthenate treated railroad ties” to the list of non-hazardous secondary materials that are not solid wastes when used as a fuel in a combustion unit. Processing must include, at a minimum, metal removal and shredding or grinding.

18. Why doesn’t EPA Permitting make sure permits are put in county legal organ?

EPD response on the air quality permitting process: Georgia EPD follows the procedures and rules set forth by our agreement with US EPA (called the State Implementation Plan). That plan does not require public notice in a legal organ for a construction permit, which is the type of permit currently issued to GRP Franklin and GRP Madison. GRP Franklin and GRP Madison are subject to 40 CFR 70, and must submit a Part 70 permit application within 12 months of commencing operations. The draft Part 70 operating permit will require a public notice in the appropriate legal organ prior to the final permit being issued.

EPD response on the wastewater permitting process: EPA has regulations (40 CFR Part 124) requiring public notice of national pollutant discharge elimination system permits for discharges to waters of the U.S. The Georgia Water Quality Control Act requires public participation prior to a wastewater permit being issued for either discharges to waters of the state or discharges to a land treatment system. The type of public notice varies depending on the size of the facility and wastewater disposal method. Upon review of a wastewater permit application, at a minimum EPD will publish a public notice on our website to solicit comments from the public and the regulated entity will post a notice at a public location.

19. Who signed (and why) the permit that allowed GRP to burn railroad ties?

EPD response: All Air Quality Permits in Georgia are signed by EPD Director Richard Dunn, however the permit review, draft permit development, and recommendation to approve the draft permit are conducted by the Air Protection Branch’s Stationary Source Permitting Program (SSPP). SSPP reviewed GRP’s application and determined that:

· US EPA revised their environmental regulations classifying railroad ties as “not solid waste” for use as fuel in boilers provided that certain requirements are met.

· The emissions resulting from combustion of railroad ties in the boiler are not expected to be significantly different from the emissions from burning only “clean cellulosic biomass” as originally permitted.

· There are no environmental provisions or reasons prohibiting the use of railroad ties as fuel in a well-controlled boiler.

20. Do they have a permit to burn chicken litter?

EPD Response: No, they do not have permit to burn chicken litter. The GRP Franklin plant does sit on the site originally permitted as “Plant Carl”, a small chicken litter boiler that was permitted but was never built.

35. Does the plant have electrostatic precipitators and scrubbers installed?

a. If so, are they wet scrubbers?

b. If a wet scrubber, what is done with the water that was used to filter the material that is scrubbed?

c. What is being done with the material that is scrubbed?

EPD Response: GRP Franklin and GRP Madison use an electrostatic precipitator (ESP) but do not use a scrubber. The dust/soot collected in the ESP is shipped to a landfill via truck.

21. May be a redundant question, but what is being done with the ash of any material after it is burned?

EPD response: The primary waste by-product is ash. As noted in the responses for questions 4, 7, and 29a, GRP has stated that the ash is being taken to a farmer for land application and to the Gainesville Waste and Recycling facility.

22. What is being done to monitor the emissions from the stack and who monitors that?

EPD response: Emissions tests were conducted in November 2019 to demonstrate that GRP Franklin and GRP Madison are complying with emiss

ion limits for the following pollutants: 1,2 dibromoethane, hydrogen chloride, arsenic, chromium, lead, silver, volatile organic compounds (generally referred to as VOCs), and particulate matter (PM). The testing for VOCs was added when the permit was amended in 2019 to allow burning railroad ties as fuel in the boiler.

GRP is also required to continuously monitor emissions of nitrogen oxides (NOx) and carbon monoxide (CO) as well as the opacity of the smoke leaving the stack.

The emissions tests are conducted by a third party company, and the test results are analyzed by a certified laboratory. EPD reviewed the test plans prior to the tests and was onsite for the emissions testing. The test results will be are submitted to EPD for review in January 2020.

The facility operations are monitored by EPD using periodic testing, onsite inspection, and review of required records and report

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