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EPA Region IV December 11-12, 2007 Atlanta, GA Case Study: Permitting Mississippi’s Experiences.
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EPA Region IV EPA Region IV December 11-12, December 11-12, 2007 2007 Atlanta, GA Atlanta, GA Case Study: Case Study: Permitting Permitting Mississippi’s Mississippi’s Experiences Experiences
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Transcript of EPA Region IV December 11-12, 2007 Atlanta, GA Case Study: Permitting Mississippi’s Experiences.
EPA Region IV EPA Region IV December 11-12, 2007December 11-12, 2007
Atlanta, GA Atlanta, GA
Case Study: PermittingCase Study: Permitting
Mississippi’s ExperiencesMississippi’s Experiences
Three Permitted SitesThree Permitted Sites– None have completed constructionNone have completed construction
Two Sites with Permits PendingTwo Sites with Permits Pending– One received approval to begin construction prior One received approval to begin construction prior
to receiving permit to receiving permit Met specific criteria for pre-permit construction Met specific criteria for pre-permit construction
approvalapproval
– One application is under our normal processingOne application is under our normal processing
Ethanol ProductionEthanol Production
Processing efficiency has improved Processing efficiency has improved during the last 30 years.during the last 30 years.
In 2005, the use of ethanol reduced In 2005, the use of ethanol reduced the U.S. trade deficit by $8.7 billion by the U.S. trade deficit by $8.7 billion by eliminating the need to import 170 eliminating the need to import 170 million barrels of oil.million barrels of oil.– Source: LECG, LLC January 2006Source: LECG, LLC January 2006
Ethanol ProductionEthanol Production
Nine Permitted SitesNine Permitted Sites
Only a few have been constructed and Only a few have been constructed and are producing.are producing.
BiodieselBiodiesel
Two Sites with Permits PendingTwo Sites with Permits Pending
Additional Pre-Application Meetings Additional Pre-Application Meetings Conducted Conducted
BiodieselBiodiesel
Production IncentivesProduction Incentives– 2002 Farm Bill2002 Farm Bill
Commodities Credit CorporationCommodities Credit Corporation
– MS House Bill 1130 of 2002MS House Bill 1130 of 2002 Established ethanol production incentives outlined in Established ethanol production incentives outlined in
MS Code 69-51-5.MS Code 69-51-5.
– MS House Bill 960 of 2005MS House Bill 960 of 2005 Revised 69-51-5 to include biodiesel production Revised 69-51-5 to include biodiesel production
incentivesincentives
– MS 69-51-5 remains an unfunded programMS 69-51-5 remains an unfunded program
Tax IncentivesTax Incentives– IRS Tax CreditsIRS Tax Credits
Driving FactorsDriving Factors
Clean Air ActClean Air Act– New Source ReviewNew Source Review
Major Source Threshold?Major Source Threshold?
– New Source Performance StandardsNew Source Performance Standards– NESHAPNESHAP
Specific MACT?Specific MACT?
State RequirementsState Requirements
Applicable Air Applicable Air Emission RegulationsEmission Regulations
Clean Water ActClean Water Act– NPDES Effluent Guidelines?NPDES Effluent Guidelines?– NPDES Storm WaterNPDES Storm Water
State RequirementsState Requirements– Pretreatment Effluent Guidelines?Pretreatment Effluent Guidelines?– Pretreatment SIU?Pretreatment SIU?– No Discharge Permit?No Discharge Permit?
Applicable Wastewater and Applicable Wastewater and Storm Water DischargesStorm Water Discharges
Very little from EPA prior to 2006Very little from EPA prior to 2006
Considered what other states had done in Considered what other states had done in permitting permitting – Varied somewhatVaried somewhat
Practical GuidancePractical Guidance
Most proposed ethanol and biodiesel production facilities Most proposed ethanol and biodiesel production facilities identified 2869 as the appropriate SIC Code. identified 2869 as the appropriate SIC Code. (Industrial Organic (Industrial Organic Chemicals, Not Elsewhere Classified)Chemicals, Not Elsewhere Classified)
EPA clarified the major source threshold for NSR May 1, EPA clarified the major source threshold for NSR May 1, 2007.2007.
Evaluate NSPS applicabilityEvaluate NSPS applicability– Subparts A, RRR, NNN, VV, etc.Subparts A, RRR, NNN, VV, etc.
Evaluate MACT applicabilityEvaluate MACT applicability– Subparts A, B, FFFF, GGGG, etc.Subparts A, B, FFFF, GGGG, etc.
Conservative ApproachConservative Approach
Air EmissionsAir Emissions
Multimedia Multimedia Guidance for Guidance for
Ethanol Ethanol ProductionProduction
http://www.epa.gov/region07/priorities/agriculture/ethanol_plants_manual.pdfhttp://www.epa.gov/region07/priorities/agriculture/ethanol_plants_manual.pdf
NPDES Storm Water ConstructionNPDES Storm Water Construction NPDES Storm Water BaselineNPDES Storm Water Baseline NPDES Non-Storm Water DischargesNPDES Non-Storm Water Discharges
– ProcessProcess Applicable Effluent Guidelines?Applicable Effluent Guidelines?
– Non-ProcessNon-Process
Pretreatment (Indirect) DischargesPretreatment (Indirect) Discharges Wastewater Treatment with No DischargeWastewater Treatment with No Discharge
Facility DischargesFacility Discharges
Good ExperiencesGood Experiences
Bad ExperiencesBad Experiences
More Bad ExperiencesMore Bad Experiences
More Bad ExperiencesMore Bad Experiences
Bryan Collins, P.E., BCEEBryan Collins, P.E., BCEE
Chief, Energy & Transportation BranchChief, Energy & Transportation Branch
Environmental Permits DivisionEnvironmental Permits Division
Mississippi Department of Environmental QualityMississippi Department of Environmental Quality
601-961-5239601-961-5239
[email protected][email protected]
Contact InformationContact Information
Questions?Questions?
