BlueScape GHG Tailoring Rule Webinar 9-9-10


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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.

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  • Thanks Joe, Hi everyone, I’m James Westbrook, President of BlueScape - I’ve done a lot of permitting work in the last 20 years - I have seen the importance of early, strategic planning when doing permitting There can be lots of pitfalls and wild cards in permitting, now we have a new one to consider with the GHG Tailoring Rule
  • Today I am going to talk about thought process to address GHG permitting going into 2011. A question many of you have is should I do anything now? You may have been waiting for EPA or state agencies for guidance or litigation to stay the rule. Recognizing the rule is in effect in less than four months, the answer is yes, you really should be doing something! You really need to find our where you stand and have a plan , especially on construction projects. - Permitting projects can be a long process – more than one year is typical for PSD. I often see companies make the mistake that permits will be issued quickly. I’m going to talk about some planning strategies to follow. These come down to what sounds simple <read> but can be really hard to do. I’ll present a couple case studies to illustrate the thought process – using a new cogeneration plant, and an existing major power plant upgrade. As Joe said earlier, I encourage you to use the webinar panel to send in questions, we’ll address questions as we have time, or we’ll follow-up with you after the webinar. Also, Joe and I will be offering a limited number of phone consultations today and tomorrow.
  • - Before I get into Tailoring rule strategies, some information about BlueScape Air quality consultants specializing in manufacturing, power industry, and oil and gas, esp. energy projects. Solve tough problems LAUNCH THE POLL, Joe asked about current Title V status, here’s a polling question on PSD.
  • YOU SHOULD HAVE LAUNCHED THE POLL Not currently a PSD Major Stationary Source New or modified stationary source Criteria pollutants only - 250 tons/year PTE, 100 tons/year PTE for specific categories Existing PSD Major Stationary Sources New or modified units = modified source Significant emissions increase ex. 40 TPY increase for Nox New Title V facilities, Major Sources: 100 tons/year PTE criteria pollutant threshold Lower in serious to extreme nonattainment areas Not to be confused with a PSD major source Title V application process New facilities, 6 months from starting operation Existing facilities, submit Title V forms with new units, amendments
  • - Can you imagine paying $50 million for a gas turbine to find out it won’t meet developing EPA GHG standards? No exemptions or grandfathering, however permits issued before 1/2/11 need not be reopened. Avoiding may sound easy, but that’s the tough part. It may involve re-defining your project, working with different emission strategies, trying better technology, taking limits, and many other options. - If we know your particular details we can help you develop a strategy.
  • Facilities that don’t want to be in Title V have to go through a special permit process, we can help you with that process. If more than three years on existing Title V, subject to reopening to include GHG. If less than three years, wait until revision or other renewal. New Title V and become subject you must submit an application within a year.
  • Cogen plant to show how avoiding PSD completely and no Title V requirements. Power plant modification to show how companies want to be working on GHG now, and how they would add it to keep permits moving.
  • In this case, the facility has an easy way out. Take a slight reduction in operating hours to avoid PSD and Title V, with an enforceable permit limit.
  • Super efficient plant, but will triggers PSD for PM2.5 and GHG, PSD applies to GHG with BACT review by 1/2/11. - Not much that can be done with PM2.5 to get permit before PSD triggered, recommend filing an amendment before 1/2/11 to include GHG emissions - One option might be to use projected actual emissions instead of PTE, but company may want to preserve all the way to the PTE. - For GHG BACT, follow an approach to decide what is the best performing GT. - Title V will apply to the existing facility Jan 2, 2011, and timing for adding GHG will depend on how close to the 5-year renewal date.
  • I briefly want to mention our next webinar …
  • Take questions. Remind about 30 min consultations. Conclude webinar.
  • BlueScape GHG Tailoring Rule Webinar 9-9-10

    1. 1. EPA’s GHG Tailoring Rule: Understand How it Will Impact Your Business 1
    2. 2. 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
    3. 3. 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
    4. 4. 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
    5. 5. 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
    6. 6. 3-Step Implementation 6
    7. 7. 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
    8. 8. 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
    9. 9. “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
    10. 10. 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
    11. 11. 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
    12. 12. EPA Tailoring Rule Permit Strategies James A. Westbrook September 9, 2010
    13. 13. 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
    14. 14. 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!
    15. 15. 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
    16. 16. 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
    17. 17. 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
    18. 18. CASE STUDIES 1) New Cogeneration Plant 2) Existing Power Plant Upgrade
    19. 19. 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
    20. 20. 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
    21. 21. 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
    22. 22. 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
    23. 23. 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
    24. 24. Contact with Questions James A. Westbrook BlueScape, Inc. 858-695-9200 x201 Joseph Ritter MotivEarth, LLC 858-735-3288