Fred P. Osman, P.E. Osman Environmental Solutions Harrisburg, PA April 21, 2011.
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Transcript of Fred P. Osman, P.E. Osman Environmental Solutions Harrisburg, PA April 21, 2011.
AIR PERMITTING OF COMBUSTION SOURCES
Fred P. Osman, P.E.Osman Environmental
SolutionsHarrisburg, PAApril 21, 2011
8 EPA Major Combustion Rules in Past Year
AIR PERMITTING 101
CAA Program Affects§111 NSPS New/Modified§160 -193
NSR New/Mod (major)
§112 NESHAPS New & Existing§129 Waste
Combustion
New & Existing
GHG TAILORING RULE
1620 1860 1880 1920 1940 1980 200013
13.5
14
14.5
15
15.5
16
16.5
-
5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
45,000
50,000
Global Average Temperature vs. Number of Pirates
Avg. Global TemperatureNumber of Pirates
Year
Glo
bal A
vera
ge T
em
pera
ture
(°C
)
Num
ber
of
Pir
ate
s (
Appro
xim
ate
)
TAILORING RULE APPROACHTailoring 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)
TAILORING RULE IMPLICATIONS
Triggering major source for GHG requires: BACT - incorporates efficiency
considerationsCauses triggering for other pollutants as well
Very few minor source permits
DETERMINATION OF NON HAZARDOUS SECONDARY MATERIALS THAT ARE SOLID WASTE
Section 129
WASTE/NOT-WASTE
Not Waste WasteVirgin Fossil Fuel Non cellulosic
biomassClean, Woody Biomass Painted/treated
woodChipped Tires, w/o metalWhole tires - tire mgt prog.
Whole Tires from piles
Spec Oil Off-spec OilPaper sludge – gen control
Sewage Sludge
Resinated woodCoal Refuse?
CISWI (COMMERCIAL INDUSTRIAL SOLID WASTE INCINERATORS)
Exempted• MWCs•QF’s homogeneous waste
•MWI’s•SSI’s•HazWaste
CISWI IMPLEMENTATION
New or Modified Units – September 21, 2011
Existing Units – State Plan due 3/21/2012Compliance due w/i 3 years of state plan
approval or by March 21, 2016, which ever is sooner.
BOILER MACT
Major/Area Source?Only Gas ExemptWater Heaters ExemptNo Size exemption
AREA SOURCE BOILER MACT IMPLEMENTATION
New Units – Upon StartupExisting Units – March 21, 2012No 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
PROPOSED UTILITY MACT
Finalize by 11/16/11Compliance in 3 yearsHg ControlPM surrogate for metalsHCl or SO2 (some cases)Enhanced Monitoring
INTERSTATE TRANSPORT RULE
Replaces CAIR Cap and Trade for SO2/NOX
Trading more limited than CAIR
OTHER CURRENT PERMITTING ISSUES
New 1 hour NOX standardProblems with emergency engines
New 1 hour SO2 standardAttainment by modeling and monitoring.