BlueScape GHG Tailoring Rule Webinar 9-9-10

60 %
40 %
Information about BlueScape GHG Tailoring Rule Webinar 9-9-10

Published on September 9, 2010

Author: BlueScape



This webinar by James Westbrook at BlueScape and Joe Ritter at MotivEarth discusses EPA's pending implementation of GHG permitting under the PSD and Title V programs. Find out how this rule will impact your operations. For more information, please contact James at 877-486-9257 or Joe at 877-374-2934.

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

Contact with Questions James A. Westbrook BlueScape, Inc. 858-695-9200 x201 Joseph Ritter MotivEarth, LLC 858-735-3288

Add a comment

Related presentations

Presentación que realice en el Evento Nacional de Gobierno Abierto, realizado los ...

In this presentation we will describe our experience developing with a highly dyna...

Presentation to the LITA Forum 7th November 2014 Albuquerque, NM

Un recorrido por los cambios que nos generará el wearabletech en el futuro

Um paralelo entre as novidades & mercado em Wearable Computing e Tecnologias Assis...

Microsoft finally joins the smartwatch and fitness tracker game by introducing the...

Related pages

BlueScape GHG Tailoring Rule Webinar 9-9-10 - Environment

1. EPA’s GHG Tailoring Rule: Understand How it Will Impact Your Business 1
Read more

BlueScape AB32 GHG Reporting in California: What has ...

... 2013 greenhouse gas or GHG emissions under the AB32 ... BlueScape AB32 GHG Reporting in California: ... BlueScape New Tribal Rules Webinar 9 ...
Read more

Bluescape | LinkedIn

Bluescape Webinar - Hear Whats New and Better with Bluescape. ... BlueScape GHG Tailoring Rule Webinar 9-9-10. 899 Views. bluescape_asia. ERP+ by BlueScape.
Read more

Webinars, Environmental Consulting, Environmental Videos ...

... Air Permitting for Facility Operators ... training, BlueScape hosted a webinar to review changes that ... the EPA's GHG Tailoring Rule, ...
Read more

Tailoring Strategies - Documents - DOCSLIDE.US

Tailoring Strategies. by kshipra007. on Jun 24, ... BlueScape EPA Tailoring Rule Permit Strategies 07/29/10 ... GHG Tailoring Rule Permit Strategies• Do ...
Read more

09-10 Program Calendar - American Bar Association

... 2009- August 31, 2010 Program Calendar 09/10/09- ... GHG Tailoring Rule and EPA’s Reconsideration of ... Webinar 07/22/10 The ...
Read more

Assistant Commissioner for Policy.

... Greenhouse Gas Tailoring Rule Revisions; ... RULES World Trade Center Health Program: Amendments to List of World Trade Center Related Health ...
Read more

Acting Director, Office of Rulemaking.

The GHG Tailoring Rule changes that this final action incorporates into the Jefferson County portion of Kentucky's SIP define the term ...
Read more