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EPA’s Tailoring Rule

EPA’s Tailoring Rule. Donald Dahl (617) 918-1657 dahl.donald@epa.gov. CAA Permitting. Title V Program Little impact for most sources Only BACT for GHG is an applicable requirement GHG Reporting Rule is not an applicable requirement

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EPA’s Tailoring Rule

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  1. EPA’s Tailoring Rule Donald Dahl (617) 918-1657 dahl.donald@epa.gov

  2. CAA Permitting • Title V Program • Little impact for most sources • Only BACT for GHG is an applicable requirement • GHG Reporting Rule is not an applicable requirement • Need to estimate GHG emissions to determine PSD applicability • For a few sources a significant impact on July 1, 2011 • Sources with 100,000 tpy of CO2e and 100 mass base tons will be required to obtain an operating permit • Sources caught by GHG emissions will need to address all applicable requirements

  3. PSD Permitting • You cannot think of GHG applicability along traditional lines • EPA’s definition of “subject to regulation” adds another applicability test

  4. Am I subject to BACT for GHG? • After January 2, 2011 for sources already required to obtain a PSD permit • Existing major source making a major modification – 75,000 tpy CO2e • New major source – 75,000 toy of CO2e • July 1, 2011: For GHG emissions regardless of traditional pollutants • New source – 100,000 tpy CO2e, 100/250 tpy GHG on mass basis • Existing 100,000 tpy CO2e source, 100/250 GHG on mass basis – 75,000 tpy CO2e • Modification itself is 100,000 tpy CO2e and 100/250 GHG on mass basis

  5. Guidance • November 2010 guidance on BACT • White papers for 7 industries (EGUs and large boilers included) • EPA developing white paper for landfills • In January, EPA will issue further BACT guidance for biomass facilities

  6. SIP Call/FIP • December 1, 2010 EPA finalizes SIP Call and FIP • Does not effect Massachusetts

  7. Other Tidbits • July 1, 2011 – source with minor NSR permit must evaluate GHG emissions if it has not begun actual construction • Term “begin actual construction” defined in 40 CFR 51.166(b)(11) – you have to start physical construction • Can take PTE cap on GHG in minor NSR permit • Biomass is not treated differently for applicability purposes • Biomass can be looked at for BACT in the 4th step – environmental, energy, and economic impacts

  8. Other Tidbits (cont) • Existing source with 105,000 tpy CO2e and minor traditional pollutants makes modification with <75,000 tpy CO2e but 45 tpy SO2. SO2 not subject to BACT under PSD permit program. Unless exempted, BACT would apply under 7.02. • Existing major source of traditional pollutant with <100,000 tpy CO2e, modification increases CO2e >=75,000 tpy, no significant increase in traditional pollutants. Change not subject since existing source minor for CO2e.

  9. GHG Reporting Rule • 40 CFR Part 98 contains the requirements • 25,000 metric ton applicability threshold • First report due March 31, 2011 • Amendments on 12/17/2010 • EPA contact: John Moskal (617) 918-1826 or moskal.john@epa.gov

  10. Industrial, Commercial, and Institutional Boilers • Efficiency, efficiency, efficiency • Document, document, document • Look at CHP possibility • Determine numeric limit for CO2e • Evaluate CEMs for CO2 • EPA comments on BACT determination for Louisiana's draft PSD permit for Nucor

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