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Air Permitting of Combustion Sources

Air Permitting of Combustion Sources. Fred P. Osman, P.E. Osman Environmental Solutions Harrisburg, PA April 21, 2011. 8 EPA Major Combustion Rules in Past Year. Air Permitting 101. GHG Tailoring Rule. Tailoring Rule Approach. Tailoring Rule sets higher thresholds for GHGs

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Air Permitting of Combustion Sources

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  1. Air Permitting of Combustion Sources Fred P. Osman, P.E. Osman Environmental Solutions Harrisburg, PA April 21, 2011

  2. 8 EPA Major Combustion Rules in Past Year

  3. Air Permitting 101

  4. GHG Tailoring Rule

  5. Tailoring Rule Approach Tailoring Rule sets higher thresholds for GHGs Step 1. Jan 2 – July 1, 2011 – Anyway sources Step 2. July 1, 2011 and after: New PSD/Title V 100,000 TPY CO2(e) PSD modification 75,000 TPY CO2(e) Step 3 – EPA, effective July 1, 2013 – thresholds TBD Important Note: Biogenic Emissions are deferred(maybe)

  6. TAILORING RULE IMPLICATIONS Triggering major source for GHG requires: BACT - incorporates efficiency considerations Causes triggering for other pollutants as well Very few minor source permits

  7. Determination of non hazardous secondary materials that are solid waste Section 129

  8. Waste/Not-Waste

  9. CISWI (Commercial Industrial Solid Waste Incinerators) • Exempted • MWCs • QF’s homogeneous waste • MWI’s • SSI’s • HazWaste

  10. CISwi Implementation New or Modified Units – September 21, 2011 Existing Units – State Plan due 3/21/2012 Compliance due w/i 3 years of state plan approval or by March 21, 2016, which ever is sooner.

  11. Boiler MACT Major/Area Source? Only Gas Exempt Water Heaters Exempt No Size exemption

  12. Area source boiler mact Implementation New Units – Upon Startup Existing Units – March 21, 2012 No Emission Limits, just Work Practice Standards. Notice of Applicability due September 17, 2011 Biennial Tune-ups (1st due March 21,2012) Boilers >10 MMBTU/hr – one-time energy assessment

  13. Proposed Utility MACT Finalize by 11/16/11 Compliance in 3 years Hg Control PM surrogate for metals HCl or SO2 (some cases) Enhanced Monitoring

  14. Interstate transport rule Replaces CAIR Cap and Trade for SO2/NOX Trading more limited than CAIR

  15. Other current permitting issues New 1 hour NOX standard Problems with emergency engines New 1 hour SO2 standard Attainment by modeling and monitoring.

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