TITLE V SIGNIFICANT MODIFICATION (WITHOUT CONSTRUCTION) APPLICATION REVIEW

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1 Facility Name: McIntosh Steam Electric Generating Plant City: Rincon County: Effingham AIRS #: Application #: 23343, Date SIP Application Received: July 1, 2015(23343), December 15, 2015 (40488) Date Title V Application Received: July 1, 2015(23343), December 15, 2015 (40488) Permit No: V-03-7 Program Review Engineers Review Managers SSPP Steve Allison Dika Kuoh, Hamid Yavari Permitting Program Manager Eric Cornwell Introduction This narrative is being provided to assist the reader in understanding the content of the referenced SIP permit to construct and draft operating permit amendment. Complex issues and unusual items are explained in simpler terms and/or greater detail than is sometimes possible in the actual permit. This permit is being issued pursuant to: (1) Sections (1) and (10) of the Georgia Rules for Air Quality Control, (2) Part 70 of Chapter I of Title 40 of the Code of Federal Regulations, and (3) Title V of the Clean Air Act Amendments of The following narrative is designed to accompany the draft permit and is presented in the same general order as the permit. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the permit in response to comments received during the public comment period and EPA review process will be described in an addendum to this narrative. McIntosh Steam Electric Generating Plant, TV-23343, TV Page 1 of 6

2 I. Facility Description A. Existing Permits Table 1 below lists the current Title V permit, and all administrative amendments, minor and significant modifications to that permit, and 502(b)(10) attachments. Comments are listed in Table 2 below. Table 1: Current Title V Permit and Amendments Permit/Amendment Number Date of Issuance Comments Yes No V /25/2012 x V /1/2013 x V /21/2015 x V /16/2015 x V /11/2015 x V /18/2015 x V-03-6 TBD x Table 2: Comments on Specific Permits Permit Number V V V V V V V-03-6 Title V Renewal Acid Rain Application Comments Detail the precautions, monitoring and record keeping for the control of fugitive dust. Deadline extension for Plant McIntosh Unit 1 for the Mercury and Air Toxics Standards (MATS) Rule, 40 CFR Part 63 Subpart UUUUU. Additional deadline extension for Plant McIntosh Unit 1 for the Mercury and Air Toxics Standards (MATS) Rule, 40 CFR Part 63 Subpart UUUUU. Incorporation of Activated Carbon Injection (ACI) and Dry Sorbent Injection (DSI) systems for Steam Generating Unit 1. Incorporation of the requirements of 40 CFR 63 Subpart DDDDD, the industrial boiler MACT. McIntosh Steam Electric Generating Plant, TV-23343, TV Page 2 of 6

3 B. Regulatory Status 1. PSD/NSR/RACT 2. Title V Major Source Status by Table 3: Title V Major Source Status If emitted, what is the facility s Title V status for the? Is the Major Source Major Source Status Requesting SM Non-Major Source Status Emitted? Status PM PM 10 PM 2.5 SO 2 VOC NO x CO TRS H 2 S Individual HAP Total HAPs Total GHGs II. Proposed Modification A. Description of Modification These applications (Nos. TV and TV-40488) were received on July 1, 2015 and December 15, 2015 respectively. These applications are requesting changes to the current Phase II NO x Averaging Plan for calendar year The current Phase II NO x Averaging Plan has been approved through calendar year However, due to system-wide changes that need to be made this year and next, this change has been requested for and will be approved for the remainder of calendar year 2015 and for calendar year McIntosh Steam Electric Generating Plant, TV-23343, TV Page 3 of 6

4 B. Emissions Change There will be no change in potential or actual emissions associated with this permit modification. Table 4: Emissions Change Due to Modification Is the Emitted? Net Actual Emissions Increase (Decrease) (tpy) Net Potential Emissions Increase (Decrease) (tpy) PM 0 0 PM PM SO VOC 0 0 NO x 0 0 CO 0 0 TRS 0 0 H 2 S 0 0 Individual HAP 0 0 Total HAPs 0 0 Total GHGs 0 0 C. PSD/NSR Applicability This modification does not include physical changes or changes in the method of operation of the facility. Therefore, PSD/NSR is not applicable. III. Facility Wide Requirements IV. Regulated Equipment Requirements V. Testing Requirements (with Associated Record Keeping and Reporting) McIntosh Steam Electric Generating Plant, TV-23343, TV Page 4 of 6

5 VI. Monitoring Requirements (with Associated Record Keeping and Reporting) VII. Other Record Keeping and Reporting Requirements VIII. Specific Requirements A. Operational Flexibility There are no requests for operational flexibility associated with this modification. B. Alternative Requirements There are no alternative requirements associated with this modification. C. Insignificant Activities There are no insignificant activities associated with this modification. D. Temporary Sources There are no temporary sources associated with this modification. E. Short-Term Activities There are no short-term activities associated with this modification. F. Compliance Schedule/Progress Reports The facility is operating in compliance with all applicable air quality rules and regulations. G. Emissions Trading There are no emissions trading associated with this modification. H. Acid Rain Requirements Georgia Power has permanently shut down Unit 2 at Plant Branch thereby necessitating a revision to the Phase II Acid Rain NOx Averaging Plan for the McIntosh Steam Electric Generating Plant. Condition updates the Phase II NO X averaging plan for calendar year 2016 for Emission Unit SG01. The unit-specific heat input limits have been updated for Emission Unit SG01 in this condition. McIntosh Steam Electric Generating Plant, TV-23343, TV Page 5 of 6

6 I. Prevention of Accidental Releases This permit modification does not affect the applicability of Prevention of Accidental Releases requirements to this facility. J. Stratospheric Ozone Protection Requirements This permit modification does not affect the applicability of Stratospheric Ozone Protection requirements to this facility. K. Pollution Prevention This permit modification does not affect the applicability of Pollution Prevention requirements to this facility. L. Specific Conditions There are no specific conditions associated with this permit modification. McIntosh Steam Electric Generating Plant, TV-23343, TV Page 6 of 6

7 Addendum to Narrative The 30-day public review started on February 29, 2016 and ended on April 1, There were no comments received from the public. Comments were received from Georgia Power Company via . The following were their comments: Georgia Power Comment 1: A NOx Averaging Plan should be listed as Attachments to the draft permit. Environmental Protection Division s Response to Comment 1: The Division agrees and will include the NO x Averaging Plan as an attachment. McIntosh Steam Electric Generating Plant, TV and TV Addendum Page 1 of 1