Published on September 9, 2010
EPA’s GHG Tailoring Rule: Understand How it Will Impact Your Business 1
Agenda The Tailoring Rule – How did we get here? Impact of EPA's Greenhouse Gas Tailoring Rule related to Title V and PSD permitting What facilities are affected Timeline of EPA's 3-step implementation process Implications for Best Available Control Technology (BACT) Near term affect on PSD and Title V facilities Application of Tailoring Rule to projects and permitting Case study Strategies to advancing the permitting process 2
MotivEarth: Our Offering GHG Advisory Services EPA and State Regulatory Interpretation GHG Inventory – Federal, California, and Voluntary Reporting Life Cycle Analysis Carbon markets – leading registries, project development protocols, GHG offsetting, offset pricing Credit generation from projects: Carbon, REC, and ERCs Project Screening → Credit Development → Transaction Training 3
Justification for the Tailoring Rule Greenhouse gas emissions rates significantly higher than criteria and HAP emissions rates Clean Air Act thresholds for major sources are currently 100/250 tons per yr Avoids issuance of thousands of PSD permits Significant pushback from air agencies Manpower and training issues Proposes a 3-phase implementation regarding permitting under PSD and Title V requirements 4
Tailoring Rule - A Problem of Scale 250 228 Emissions Intensity 200 173 Emissions, lbs/MMBtu 150 117 GHG NOx 100 50 0.14 0.37 0.88 0 Natural Gas Fuel Oil #6 Coal Fuel Type 5
3-Step Implementation 6
PSD Permitting – Tricky in the Transition PSD Permit issued before January 2, 2011 Need not be re-opened due to GHGs Make sure permit is not expired Sources not subject to PSD Permitting until Step 2 Can begin or continue construction prior to July 1, 2011 Sources that begin construction after July 1 need to obtain a PSD Permit 7
Title V Permitting in the Transition If you are applying for a Title V Permit for the 1st time Submit permit application within 12 months after becoming subject to Title V If you submit your permit application, but prior to release of the draft permit, the source is obligated to supplement the permit application What if I have a Title V permit? If 3 years or more remaining on the permit, the permit authority is required to re-open the permit and account for GHGs 8
“Top Down” BACT Process Step 1: Indentify all potentially applicable control technologies Step 2: Eliminate technically infeasible options Step 3: Rank remaining technologies by control effectiveness Step 4: Evaluate most effective controls and document results Step 5: Propose BACT 9
Steps 1 BACT Analysis – 3 considerations 1. Energy Efficiency Technology – Cogeneration, turbines, engines, super critical boilers Thermal efficiency 2. Non-fossil and low carbon fuels Renewable energy Biofuels Natural gas, propane, etc. 3. Carbon capture, transport, and sequestration 10
Other Issues Treatment of biomass facilities First determinations of GHG BACT “Cost effective” GHG control Establishing the RACT/BACT/LAER Clearinghouse What happens if States are not ready to implement? Enter the FIP Legal challenges No grandfathering 11
EPA Tailoring Rule Permit Strategies James A. Westbrook September 9, 2010
GHG Tailoring Rule Permit Strategies • Do anything now? YES! • Strategies: Avoid triggering permit requirements Accept requirements and minimize issues • Case Studies: New Cogeneration Facility Power Plant Upgrade / Expansion
BlueScape, Inc. • National PSD and Title V permitting experience • Solve tough air quality problems: Avoid PSD and Title V requirements Pass ambient standards with AERMOD dispersion modeling Negotiate flexible permit conditions Keep in compliance, stay out of trouble! Get the permit!
PSD & Title V Permitting Summary • PSD Permitting New Source Review for construction Major Stationary Sources Significant emission thresholds Ambient Air Analysis and BACT requirements • Title V Permitting Operating Permit Program for applicable rules New Title V facilities, application process Existing Title V facility, 5-year renewal • Potential emissions vs. actual emissions
Strategies for PSD and GHG • Biggest PSD Issues: Delays, uncertainty, BACT expense, other issues (NO2, SO2 impact modeling) • Avoidance Strategy Current PSD action - Get below PSD thresholds for criteria pollutants New facility - Get GHG emissions below 100,000 tons/year Existing facility – Total GHG below 100,000 tons/year, increases below 75,000 tons/year PSD permit in process, time is running out quick! • Can’t Avoid PSD PSD process planned, put GHG in, carefully plan equipment purchases Follow developing agency and BACT requirements closely
Strategies for Title V and GHG • Biggest Title V Issues: GHG pulls in ALL applicable requirements A lot of work, monitoring, deviation reporting • Avoidance Strategy Get below GHG thresholds for Title V • Can’t avoid Title V New facilities – submit within one year Existing Title V o More than three years to renewal – could reopen o Less than three years to renewal – more time
CASE STUDIES 1) New Cogeneration Plant 2) Existing Power Plant Upgrade
New Cogen Plant • New Source, 8,760 hours/year • 3 x 8 MWe lean burn engines = 24 MWe • BACT for NOx and PM NOx PM10 GHG Emission Factor (lb/MWh): 0.15 0.011 1,000 Emissions (TPY): 15.8 1.2 105,120 PSD and Title V Threshold (TPY): 250 250 100,000 Exceed Threshold? No No YES1 1No PSD or Title V trigger for GHG limited to under 8,333 hours/year
Power Plant Upgrade / Expansion • Major PSD and Title V source currently • Application submittal in Oct 2010 3 existing gas turbines, 450 MWe total Replace with 3 x 250 MWe units, phased Increase to 750 MWe total in future 8,760 hours/year proposed • Modification - Emissions increases from 2YR actuals to future potential-to-emit (PTE) • BACT for criteria pollutants • Application does not currently include GHG
Power Plant Upgrade Emissions NOx PM2.5 GHG Current Emission Factor (lb/MWh): 0.2 0.03 1400 Future Emission Factor (lb/MWh): 0.08 0.02 850 2-Yr Baseline Actuals (TPY): 270 41 1,890,000 Future PTE (TPY): 263 66 2,792,250 Emissions Increase (TPY): -7 25 902,250 PSD Significance Threshold (TPY): 40 10 75,000 Exceed Threshold? no YES YES
Summary • Evaluate against thresholds - Do you know your GHG PTE? • Develop a permit strategy now to deal with GHG in permits • PSD permitting: Avoiding PSD may be your best option Current PSD - wrap it up by 1/2/11 Need to do a PSD permit, plan for GHG emissions now • Title V permitting: Avoid Title V if you can If no way to avoid, understand new requirements, timing • Stay on top of agency implementation requirements
Next Webinar Tue, October 12 Air Modeling for Non-Modelers What’s Up with the New Ambient Standards? 1-hour NO2 1-hour SO2 PM2.5 How to know your PROJECT WILL PASS so you can Get the Permit https://www2.gotomeeting.com/register/496570147
Contact with Questions James A. Westbrook BlueScape, Inc. 858-695-9200 x201 firstname.lastname@example.org www.bluescapeinc.com Joseph Ritter MotivEarth, LLC 858-735-3288 email@example.com www.motivearth.com
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