BlueScape GHG Tailoring Rule Webinar 9-9-10
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Transcript of BlueScape GHG Tailoring Rule Webinar 9-9-10
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EPA’s GHG Tailoring Rule: Understand How it Will Impact Your Business
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
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Agenda
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 ERCsProject Screening → Credit Development → Transaction
Training 3
MotivEarth: Our Offering
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
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Justification for the Tailoring Rule
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Tailoring Rule - A Problem of Scale
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173
228
0.14 0.37 0.880
50
100
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250
Natural Gas Fuel Oil #6 Coal
Emis
sion
s, lb
s/M
MBt
u
Fuel Type
GHGNOx
Emissions Intensity
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3-Step Implementation
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
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PSD Permitting – Tricky 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
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Title V Permitting in the Transition
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
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“Top Down” BACT Process
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 sequestration10
Steps 1 BACT Analysis – 3 considerations
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
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Other Issues
EPA Tailoring Rule Permit StrategiesJames A. Westbrook
September 9, 2010
GHG Tailoring Rule Permit Strategies
• Do anything now? YES!• Strategies:Avoid triggering permit requirementsAccept requirements and minimize issues
• Case Studies:New Cogeneration FacilityPower Plant Upgrade / Expansion
BlueScape, Inc.
• National PSD and Title V permitting experience
• Solve tough air quality problems:Avoid PSD and Title V requirementsPass ambient standards with AERMOD
dispersion modelingNegotiate flexible permit conditionsKeep in compliance, stay out of trouble!Get the permit!
PSD & Title V Permitting Summary • PSD PermittingNew Source Review for constructionMajor Stationary SourcesSignificant emission thresholdsAmbient Air Analysis and BACT requirements
• Title V PermittingOperating Permit Program for applicable rulesNew Title V facilities, application processExisting 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 StrategyGet below GHG thresholds for Title V
• Can’t avoid Title VNew facilities – submit within one yearExisting Title V
oMore than three years to renewal – could reopen
oLess 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 GHGEmission Factor
(lb/MWh): 0.15 0.011 1,000
Emissions (TPY): 15.8 1.2 105,120PSD 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 20103 existing gas turbines, 450 MWe totalReplace with 3 x 250 MWe units, phased Increase to 750 MWe total in future8,760 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 1,890,000Future PTE (TPY): 263 66 2,792,250
Emissions Increase (TPY): -7 25 902,250PSD 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-ModelersWhat’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 QuestionsJames A. Westbrook
BlueScape, Inc.858-695-9200 x201
Joseph RitterMotivEarth, LLC858-735-3288