4 The record articles

PSD Permitting in Georgia – Homework Isn’t Just for Kids!

Posted: October 1st, 2012

Author: All4 Staff 

In the spirit of a brand new school year, the Georgia Environmental Protection Division (GEPD) recently published a document that is required reading for those with air permitting interests in Georgia. On September 18, 2012, GEPD released its Prevention of Significant Deterioration (PSD) Permit Application Guidance Document that addresses technical issues often associated with the PSD permitting process. The document, comprised of a multiple section narrative and 10 appendices, describes the PSD application review process employed by GEPD, and provides figures, flowcharts, and checklists that illustrate many of the nuances in the PSD permitting process. The document covers the basics of the PSD permitting process, from determining a facility’s PSD status, to performing emission calculations, and reviewing the scope of a top-down Best Available Control Technology (BACT) analysis. The document also explores the often misunderstood elements of a PSD permit application, the ambient air quality analysis and the additional impact analysis. Finally, the application submission and agency review process is explained in detail.

Of particular benefit are the GEPD’s discussions on the procedures to estimate changes in emissions by covering the concepts of baseline actual emissions and projected actual emissions. The document then delves into the concept of demand growth emissions and the ever mysterious “could have accommodated” provisions of the PSD regulations.

All in all, the document does an excellent job in summarizing the key concepts of the PSD process in a plain English format. Unfortunately, as described in the purpose section, the document does not address the permitting requirements for sources located in nonattainment areas, or the permitting of greenhouse gas emissions. However, in the grand scheme of regulatory agency guidance documents, this document will be a valuable resource for PSD projects for me personally, and the Georgia permitting community at large.

The document can be found on the GEPD’s website in its PSD Resources section at the following link: http://www.georgiaair.org/airpermit/html/sspp/psdresources.htm.  Happy reading!

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