WWALS Watershed Coalition

WWALS Watershed Coalition, Inc. (WWALS) is Suwannee RIVERKEEPER® WWALS advocates for conservation and stewardship of the surface waters and groundwater of the Suwannee River Basin and Estuary, in south Georgia and north Florida, among them the Withlacoochee, Willacoochee, Alapaha, Little, Santa Fe, and Suwannee River watersheds, through education, awareness, environmental monitoring, and citizen activities.

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Comment period to GA-EPD about second Adel wood pellet plant 2022-04-01 [Up]

WWALS blog post:

Permit draft documents from GA-EPD:

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2499-075-0028-E-01-0-nar

[On October 6, 2021, Spectrum Energy Georgia, LLC’s (hereinafter “facility”) consultant, Mr. Todd Cloud,]
On October 6, 2021, Spectrum Energy Georgia, LLC’s (hereinafter “facility”) consultant, Mr. Todd Cloud,
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[Equipment List]
Equipment List
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[ID No. Description ID No. Description]
ID No. Description ID No. Description
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[Emissions Summary]
Emissions Summary
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[Regulatory Applicability]
Regulatory Applicability
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[Permit Conditions]
Permit Conditions
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[Condition 5.2 requires that the facility use a VOC continuous emission monitoring system (CEMS) to]
Condition 5.2 requires that the facility use a VOC continuous emission monitoring system (CEMS) to
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[Condition 5.9a. requires that the facility use a VOC CEMS to continuous monitor VOC emissions from]
Condition 5.9a. requires that the facility use a VOC CEMS to continuous monitor VOC emissions from
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[¢ Condition 6.5 includes some additional requirements for the above testing, and requires that the facility]
¢ Condition 6.5 includes some additional requirements for the above testing, and requires that the facility
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[¢ Condition 6.13 requires that the facility, in the event if any tested results are higher than the associated]
¢ Condition 6.13 requires that the facility
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[than 80 percent of the value established in accordance with Condition 6.8a. Prior to any performance]
than 80 percent of the value established in accordance with Condition 6.8a. Prior to any performance
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[Condition 7.6 requires that the facility maintain records of throughput data, which will be used to track]
Condition 7.6 requires that the facility maintain records of throughput data, which will be used to track
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[Page 13]
Page 13
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[Page 14]
Page 14
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[e Finally, Condition 7.15 requires that the facility calculate the 12 month rolling totals using the monthly]
e Finally, Condition 7.15 requires that the facility calculate the 12 month rolling totals using the monthly
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[¢ Condition 7.16 requires that the facility maintain records of throughput data, which will be used to track]
¢ Condition 7.16 requires that the facility maintain records of throughput data, which will be used to track
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[Page 17]
Page 17
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[Page 18]
Page 18
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[e Finally, Condition 7.25 requires that the facility calculate the 12 month rolling totals using the monthly]
e Finally, Condition 7.25 requires that the facility calculate the 12 month rolling totals using the monthly
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[Toxic Impact Assessment]
Toxic Impact Assessment
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[TIA Phase II]
TIA Phase II
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[Summary & Recommendations]
Summary & Recommendations
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2499-075-0028-E-01-0-permit

[In accordance with the provisions of the Georgia Air Quality Act, O.C.G.A. Section 12-9-1, et seq and the]
In accordance with the provisions of the Georgia Air Quality Act, O.C.G.A. Section 12-9-1, et seq and the
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[1. General Requirements; 2. Allowable Emissions]
1. General Requirements; 2. Allowable Emissions
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[Page 3]
Page 3
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[3. Fugitive Emissions; 4. Process & Control Equipment]
3. Fugitive Emissions; 4. Process & Control Equipment
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[5. Monitoring]
5. Monitoring
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GA-EPD

[n = _ Total number of fields]
n = _ Total number of fields
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GA-EPD

[Page 7]
Page 7
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GA-EPD

[Page 8]
Page 8
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GA-EPD

[n = _ Total number of fields]
n = _ Total number of fields
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GA-EPD

[Page 10]
Page 10
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GA-EPD

[Page 11]
Page 11
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GA-EPD

[6. Performance Testing]
6. Performance Testing
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GA-EPD

[Page 13]
Page 13
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GA-EPD

[Page 14]
Page 14
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GA-EPD

[Page 15]
Page 15
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GA-EPD

[If any test results are less than 50 percent of the associated emission rates specified in]
If any test results are less than 50 percent of the associated emission rates specified in
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GA-EPD

[Page 17]
Page 17
PDF

GA-EPD

[Page 18]
Page 18
PDF

GA-EPD

[Page 19]
Page 19
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GA-EPD

[If any test results are less than 50 percent of the associated emission rates specified in]
If any test results are less than 50 percent of the associated emission rates specified in
PDF

GA-EPD

[Page 21]
Page 21
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GA-EPD

[7. Notification, Reporting and Record Keeping Requirements]
7. Notification, Reporting and Record Keeping Requirements
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GA-EPD

[each report shall be as specified by the Division’s Procedures for Testing and Monitoring]
each report shall be as specified by the Division’s Procedures for Testing and Monitoring
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GA-EPD

[Page 24]
Page 24
PDF

GA-EPD

[5.4 that is less than 80 percent of the value established in accordance with Condition]
5.4 that is less than 80 percent of the value established in accordance with Condition
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GA-EPD

[5.10b., and 5.11 that is less than 80 percent of the value established in accordance]
5.10b., and 5.11 that is less than 80 percent of the value established in accordance
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GA-EPD

[Page 27]
Page 27
PDF

GA-EPD

[Page 28]
Page 28
PDF

GA-EPD

[Page 29]
Page 29
PDF

GA-EPD

[Page 30]
Page 30
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GA-EPD

[month and shall include an explanation of how the Permittee intends to maintain compliance]
month and shall include an explanation of how the Permittee intends to maintain compliance
PDF

GA-EPD

[Page 32]
Page 32
PDF

GA-EPD

[Page 33]
Page 33
PDF

GA-EPD

[Page 34]
Page 34
PDF

GA-EPD

[Page 35]
Page 35
PDF

GA-EPD

[Page 36]
Page 36
PDF

GA-EPD

[Page 37]
Page 37
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GA-EPD

[Page 38]
Page 38
PDF

GA-EPD

[Page 39]
Page 39
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GA-EPD

[month and shall include an explanation of how the Permittee intends to maintain compliance]
month and shall include an explanation of how the Permittee intends to maintain compliance
PDF

GA-EPD

[Page 41]
Page 41
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GA-EPD

[8. Special Conditions]
8. Special Conditions
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GA-EPD

[ID No. Description ID No. Description]
ID No. Description ID No. Description
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GA-EPD

[ID No. Description ID No. Description]
ID No. Description ID No. Description
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