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The EPA’s Tailoring Rule outlines permitting requirements under the Clean Air Act for greenhouse gas (GHG) emissions. Starting July 1, 2011, sources emitting over 100,000 tons per year of CO2e must obtain an operating permit, primarily focusing on Best Available Control Technology (BACT) for GHGs. Existing and new major sources must assess GHG emissions to determine Prevention of Significant Deterioration (PSD) applicability. The rule emphasizes documentation, efficiency, and guidance for specific industries, ensuring compliance with the GHG Reporting Rule and related requirements.
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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 • 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
PSD Permitting • You cannot think of GHG applicability along traditional lines • EPA’s definition of “subject to regulation” adds another applicability test
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
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
SIP Call/FIP • December 1, 2010 EPA finalizes SIP Call and FIP • Does not effect Massachusetts
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
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.
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
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
