Georgia Renewable Power (GRP) was recently issued a $7,500 fine in a “consent order” by the state Environmental Protection Division (EPD) for improperly handling outdoor “fugitive emissions” at its facility in Colbert.
“The Division has determined that the respondent (GRP) violated permit conditions…by failing to maintain and operate the facility in a manner consistent with good air pollution control practices for minimizing fugitive emissions,” wrote EPD Director Richard E. Dunn in the consent order.
GRP burns wood to generate electricity. That wood must be ground up before it is burnt. The dust from that process is considered a “fugitive emission.” The wind can blow that dust off GRP land and onto neighboring properties. The wood at the plant includes creosote-treated railroad ties. There is currently a bill under consideration in the Georgia Assembly to ban the use of those railroad ties as a fuel source for generating electricity, since creosote is considered a toxin.
Meanwhile, National Salvage, the company that handles the chipping process for GRP, is seeking an air emissions permit from the EPD for the grinding of the railroad ties. The public comment period for that application ends Friday, June 19. Comments can be sent to EPD.Comments@dnr.ga.gov.
The EPD consent order requires GRP to pay a $7,500. Civil penalties can be issued at $25,000 per day for each violation. The order also requires that within 30 days of the June 1 order GRP must demonstrate “standard operating procedures, monitoring, and corrective actions that have been implemented for the minimization of fugitive emissions, including contingencies for prevailing wind conditions.” Within two months of the stacker chute (equipment that mitigates emissions) starting operations, GRP is required to submit a report to the EPD “evaluating the need for a retractable chute and/or netting or barrier wall around the fuel yard.”
WHAT GRP SAYS
Georgia Renewable Power Executive Vice President Carey Davis was asked about the consent order. Here is his full summary of the situation:
“The GRP – Madison Renewable Energy Facility recently resolved a matter with Environmental Protection Division of the Georgia Department of Natural Resources regarding (EPD) regarding pre-combustion air emissions at the facility.
The facility, which generates up to 58 megawatts of electricity from the combustion of biomass materials, has a permit issued by EPD for air emissions. The air emissions from the facility can be produced by the combustion process, which is the burning of biomass, and by non-combustion processes, which would include ‘fugitive’ emissions from other miscellaneous operations at the facility. A potential source of fugitive emissions at the facility is the vegetative debris or ‘dust’ produced by the stacking of the biomass material before being conveyed to the combustion unit. The air permit requires the facility to take all reasonable precautions to prevent dust emissions, including those from the stacking of the biomass material. Typically, dust emissions from biomass stacking activities would be controlled with the application of potable water. However, in early December 2019, the EPD had prohibited the facility from using potable water for dust suppression on the biomass material. The facility immediately began seeking other means to control these fugitive emissions.
On April 20, 2020, the EPD issued a consent order alleging that the facility did not use all reasonable precautions to prevent vegetative debris being blown by wind during stacking operations off the property of the facility. The NOV (notice of violation) did not allege any violation of emission limits for any air pollutants from the combustion process at the facility. On June 1, 2020, the facility executed a consent order with the EPD regarding the alleged dusting issue. By that time, the facility had already proactively implemented measures to mitigate any alleged dusting. These measures included improved standard operating protocols and a new chute designed for the accumulation of biomass in a more controlled manner. These measures have been successful in virtually eliminating any dusting of vegetative debris that had been alleged by the EPD. Under the consent order, the facility has to pay a minor civil penalty and report to the EPD the specific measures that have been undertaken to minimize fugitive emissions and the need for any additional measures that may be required to meet the requirement to mitigate fugitive emissions. Given the effectiveness of the measures already implemented, no additional mitigative measures are contemplated by the facility at this time. The facility has complied with the substantive requirement of the consent order regarding mitigation of fugitive emissions.
The facility takes its environmental obligations very seriously, as demonstrated by its proactive approach to addressing the fugitive emission matter and the timely and appropriate resolution of this matter with the EPD. The facility is committed to providing electrical energy in a sustainable, safe and environmentally responsible manner and remains confident that its emissions, both pre-combustion and post-combustion, are in compliance with the requirements of the Georgia Air Quality Act.”