Asphalt Plant Air Permit Consulting
Bowen Environmental Services (BES) specializes in air permitting for hot mix asphalt (HMA) plants in Georgia. We help plant owners, paving contractors, and developers obtain the right air permits from the Georgia Environmental Protection Division (EPD) and stay in compliance throughout the life of the facility.
Why Asphalt Plants Need Air Permits
Asphalt production involves high-temperature combustion in the dryer drum, which generates a range of regulated pollutants including particulate matter (PM), nitrogen oxides (NOx), sulfur dioxide (SO2), carbon monoxide (CO), volatile organic compounds (VOCs), and hazardous air pollutants (HAPs) such as formaldehyde and benzene.
Because of this emissions profile, Georgia EPD requires an air permit before an asphalt plant can be constructed or operated. Failing to obtain the right permit can result in project delays, fines, and enforcement actions.
How Fuel Type Affects Your Permit
The fuel you burn in the dryer is one of the most important factors in your permitting process. It directly affects your emission rates, the type of permit you qualify for, and your ongoing compliance obligations.
Natural Gas / LPG
The cleanest option. SO2 emissions are negligible, HAP metal emissions are essentially zero, and there are no fuel sulfur limits to track. Plants with pipeline access get the most operational flexibility with the least permitting complexity.
No. 2 Distillate Fuel Oil (Diesel)
A common choice for portable plants and rural sites without gas pipelines. Moderately higher emissions than natural gas, particularly SO2. Your permit will require fuel sulfur content documentation for every delivery.
Recycled Fuel Oil (Waste Oil) / Residual Oil
The cheapest fuel, but the most complex permitting pathway. Waste oil and residual oils carry higher sulfur content (increasing SO2), higher metal concentrations (lead, cadmium, chromium, arsenic), and a greater likelihood of triggering a toxic impact assessment by Georgia EPD. Your permit will require waste oil specification testing — including arsenic, cadmium, chromium, lead, total halogens, and flash point — for every batch of fuel. The trade-off is real: lower fuel cost, but tighter permit limits, more testing, and heavier recordkeeping.
Georgia Permit Types for Asphalt Plants
Almost all asphalt plants have the potential to be a major source — primarily from SO2 and NOx. To avoid the burden of Title V major source permitting, most Georgia asphalt plants operate under either a Permit-by-Rule or a Synthetic Minor permit.
Permit-by-Rule (PBR)
A streamlined option with lower annual permit fees. PBR limits depend on your fuel type:
Plants burning natural gas, LPG, and/or distillate oil only:
- Production: 400,000 tons per 12-month period
- Hours of operation: 3,000 hours per 12-month period
Plants burning residual oil or recycled fuel oil (in any combination with gas/distillate):
- Production: 200,000 tons per 12-month period
- Hours of operation: 3,000 hours per 12-month period
- Fuel oil usage: 678,000 gallons per 12-month period
- Fuel sulfur content: 1.5% maximum
A PBR does not exempt you from also applying for a standard SIP Construction and Operating Permit. Both applications must be submitted to Georgia EPD.
Synthetic Minor (SM) Permit
For plants that need higher production capacity. An SM permit establishes enforceable limits to keep emissions below major source thresholds.
- Production: Typically limited to 600,000 tons per 12-month consecutive period
- Fuel sulfur, fuel usage, and hours of operation are also limited based on facility-specific emission calculations
SM permits carry higher annual fees and more detailed monitoring and reporting requirements than PBR, but they allow significantly more production.
Title V Major Source Permit
Required for the largest plants that cannot stay below major source thresholds. Title V involves comprehensive monitoring, recordkeeping, reporting, and annual compliance certifications. Most operators prefer to avoid Title V by accepting SM or PBR limits.
Atlanta Non-Attainment Area
If your plant is in the Atlanta ozone non-attainment area, the NOx major source threshold drops from 100 tons per year to 50 tons per year. This may require tighter operational limits to maintain Synthetic Minor status. Georgia EPD has separate PBR categories for plants in the non-attainment counties (Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, and Rockdale).
Portable Plant Permitting
Georgia EPD offers state-wide permits for portable asphalt plants. Each operating location must be identified in the permit, and a Public Advisory is issued for each site. Adding new sites is handled through a permit amendment, which is faster than a new application.
You must receive a permit before erecting a plant at a new location. Georgia air quality permits are not transferable — if you purchase an existing plant, you must notify EPD in writing within 30 days.
Key Regulations
Your Georgia permit will reference these federal and state rules:
40 CFR Part 60, Subpart I (NSPS) — Limits PM to 0.04 gr/dscf and opacity to 20% for plants constructed or modified after June 11, 1973. Initial compliance testing is required.
Georgia Rule (b) — Limits stack opacity to 40% (unless a stricter standard applies).
Georgia Rule (g) — Limits fuel sulfur content based on dryer heat input capacity.
Georgia Rule (k) — PM limits specific to asphalt plants (NSPS Subpart I typically takes precedence).
Georgia Rule (n) — Requires reasonable precautions to control fugitive dust; limits fugitive opacity to 20%.
Asphalt Plant Air Permit Cost
Typical consulting fee ranges:
PBR applications (with SIP): $2,500 – $4,500
Synthetic Minor applications: $4,500 – $8,500
Title V applications: $10,000 +
Air modeling / toxic impact assessments: $1,200 – $4,000
State regulatory and annual permit fees are separate and paid directly to Georgia EPD. BES provides a detailed proposal specific to your project before any work begins.
Get Started Early
Air permitting in Georgia can take several months or longer if a public hearing is requested or your application is incomplete. Contact BES early in your project planning to ensure your facility is designed for compliance from day one.
Phone: 770-359-9271
Email: info@bowenenvironmental.com
