This article is mostly directed at the gins in Georgia but there is a bit of information that all gins should take from it. For the past several years we’ve seen a lot of changes to air quality permits in the region. North Carolina was the first to change to a general permit and it required baseline and periodic checking of the air flows. Next was South Carolina that developed a general permit equipment based standard that didn’t require a baseline but did require more frequent checking of the air. Then North Carolina did away with the small permits but left the underlying rules in place. In 2017, Georgia developed a new equipment based rule that provides gins an alternative to a process weight formula. This new rule will be much easier to comply with and obtain permits going forward. We are now in the process of implementing that new rule.
In order for the new rule (or addition to the old rule) to be effective, gins will need to have it incorporated into their permits. Since Georgia permits don’t expire, we have a wide variety of requirements in permits that have been written over the years. Some gins may have no reference to any particular rule, some may have a reference that says something like you must stay in compliance with rule (q) and some may have mathematical formulas that indicated an emission limit or variations on all of the above.
If your permit has a formula, you will definitely need to update your permit to include the new language. If the permit has a reference to rule (q) with no formula or if the permit just has a general reference to the air quality rules, you’re fine if you haven’t updated the gin. If you’ve made changes to the gin since your permit was issued, you will want to update it as well.
If you need to update your permit because you need to add the updated rules or if you’ve made changes to your gin or both, we are in the beginning stages of getting that done.
Over the next few months, we will be sending out letters to all Georgia gins explaining the changes, the new rule and how to update your permit. We are asking that you start preparing for this process as soon as you can. If you haven’t made any changes but need to update to the new rule (i.e. you have a formula in your permit) it’s a simple form letter that we will send you. If you have made changes, it won’t get any simpler to update than it will be right now. We will begin sending letters out in the next couple weeks and stagger them over the summer. This will help the permit engineer in Atlanta that will be handling these to not get overloaded.
We encourage you to prepare now. Please go ahead and locate your air quality permit and read it. Review it for the general conditions, and special conditions that may be written and if you can locate your application review that as well. Most gins have made SOME change at some point. Go ahead and make a list of cyclones, with names, numbers and sizes such as “1A Pull Fan – 2-54″ cyclones”. You may want to make a drawing as well to make it clearer. This may be the only chance you have to update without filling out a bunch of forms with technical data to get your permit fully updated. Don’t send anything in yet!
That brings up a point for ALL gins. Every once in a while it doesn’t hurt to pull your air quality permit and review it. Does it require an annual reporting? Does your permit reflect the gin you have? How does it get updated? Keeping up with your permit will help avoid the problems we have occasionally where a relatively minor complaint ends up in a Notice of Violation (NOV) because there are four more cyclones than in the permit. Self disclosure is always the best policy. If you need to update your permit, please do so. Call us if you don’t know how. We can get you in touch with the right people.
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