Climate Change Update:
What Lies Beyond GHG Reporting
for the Lead Industry
Presented by All4 Inc.
Neal Lebo | nlebo@all4i...
Agenda






2
2

Climate Change Regulatory Activity
Measurement and Reporting
Permitting/Standards
Actions to Conside...
Strong Words
“If Congress won’t act soon to protect future generations, I
will. I will direct my Cabinet to come up with e...
National GHG Actions
October 2009: Mandatory Reporting of
Greenhouse Gases Rule.
 December 2009: Endangerment Finding - G...
National GHG Actions


May 2010: Prevention of Significant Deterioration (PSD)
and Title V Greenhouse Gas Tailoring Rule
...
National GHG Actions
March 2012: Proposed New Source Performance
Standards (NSPS) to control GHG from new fossil
fuel-fire...
National GHG Actions


What hasn’t happened:



Over a year later new EGU GHG standard not final.
U.S. EPA also committ...
State GHG Actions






Regional market-based regulatory programs.
Additional annual reporting requirements.
Permit ap...
Measurement and Reporting


What gases are considered GHG?
• Six (6) recognized greenhouse gases (GHG)







9
9

...
Measurement and Reporting


Global Warming Potential (GWP)
A measure of how much a given mass of GHG is
estimated to cont...
Measurement and Reporting


Emissions measured in CO2 equivalency (CO2e).
Each gas placed on CO2e basis by multiplying GW...
Measurement and Reporting


40 CFR Part 98 – Mandatory Greenhouse Gas Reporting.





Lead smelters that emit ≥ 25,000...
Measurement and Reporting




EPA’s Facility Level Information on GreenHouse
gases Tool (FLIGHT).
First two years of rep...
Measurement and Reporting


Part 98 Combustion Emissions Calculation:
CO2/CH4/N2O = 1x10-3 * Fuel (SCF) * HHV * Emission ...
Measurement and Reporting


Part 98 Lead Production Emissions Calculation:
CO2 = 3.67 * 0.91 * Mass of Feed * %Carbon Con...
Measurement and Reporting


% Carbon Content – what we have seen.*
Lead Scrap Carbon Content
Annual Average
3.4%

0.9%
0....
Measurement and Reporting


Concerns:





17
17

Public data available to stakeholders.
Permitting.
Applicability un...
GHG Permitting


Currently must address GHG in all applications.





Full GHG emission inventories required in renewa...
GHG Standards


NSPS/NESHAP requirements.





Questionable GHG control technologies.
Energy efficiency requirements.
...
Actions to Consider


Review what has been submitted.




Assure representative carbon content data.





Increase s...
Questions?
Neal Lebo | nlebo@all4inc.com | 610.933.5246 x 113
All4 Inc.
2393 Kimberton Road
P.O. Box 299
Kimberton, PA 194...
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Climate Change Update: What Lies Beyond GHG Reporting for the Lead Industry

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Neal Lebo of All4 Inc. describes "What Lies Beyond GHG Reporting for the Lead Industry". The presentation includes: Climate Change Regulatory Activity, Measurement and Reporting, Permitting/Standards, and Actions to Consider.

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Climate Change Update: What Lies Beyond GHG Reporting for the Lead Industry

  1. 1. Climate Change Update: What Lies Beyond GHG Reporting for the Lead Industry Presented by All4 Inc. Neal Lebo | nlebo@all4inc.com | 610.933.5246 x 113 May 10, 2013 www.all4inc.com Kimberton, PA | 610.933.5246 Columbus, GA | 706.221.7688
  2. 2. Agenda     2 2 Climate Change Regulatory Activity Measurement and Reporting Permitting/Standards Actions to Consider Your environmental compliance is clearly our business.
  3. 3. Strong Words “If Congress won’t act soon to protect future generations, I will. I will direct my Cabinet to come up with executive actions we can take, now and in the future, to reduce pollution, prepare our communities for the consequences of climate change, and speed the transition to more sustainable sources of energy.” “I’m also issuing a new goal for America: Let’s cut in half the energy wasted by our homes and businesses over the next 20 years.” President Barack Obama, February 12, 2013 3 3 Your environmental compliance is clearly our business.
  4. 4. National GHG Actions October 2009: Mandatory Reporting of Greenhouse Gases Rule.  December 2009: Endangerment Finding - GHG threaten health & human welfare.  April 2010: Light Duty Vehicle Rule - First rule to control GHG emissions.  4 4 Your environmental compliance is clearly our business.
  5. 5. National GHG Actions  May 2010: Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas Tailoring Rule (GHG Tailoring Rule).    5 5 January 2011: Step 1 - GHG air permitting began for facilities that would otherwise require permitting. July 2011: Step 2 - GHG permitting began for all facilities that would emit more than 100,000 tons of CO2e per year and facilities that undergo modification that would increase emissions by 75,000 tons of CO2e per year. July 2012: Step 3 amendments and streamlining options. Your environmental compliance is clearly our business.
  6. 6. National GHG Actions March 2012: Proposed New Source Performance Standards (NSPS) to control GHG from new fossil fuel-fired electric utility generating units (EGUs).  December 2012: First GHG enforcement.    Climate Change Adaptation Plans.   6 6 Construction without GHG PSD permit. Federal agencies evaluate risks and vulnerabilities. Develop plans to manage effects of climate change on the agency’s mission, programs, and operations. Your environmental compliance is clearly our business.
  7. 7. National GHG Actions  What hasn’t happened:   Over a year later new EGU GHG standard not final. U.S. EPA also committed to, but has not acted on, GHG standards for:    7 7 Existing EGUs by May 26, 2012. New/existing petroleum refineries by November 10, 2012. During a recent interview U.S. EPA Administrator Nominee Gina McCarthy suggested that “it’s really states that develop their own processes” for existing plants. Your environmental compliance is clearly our business.
  8. 8. State GHG Actions     Regional market-based regulatory programs. Additional annual reporting requirements. Permit application requirements. Challenging U.S. EPA authority to regulate.   8 8 Overturn Massachusetts v. EPA. Legality of the Tailoring Rule. Your environmental compliance is clearly our business.
  9. 9. Measurement and Reporting  What gases are considered GHG? • Six (6) recognized greenhouse gases (GHG)       9 9 Carbon dioxide (CO2) Methane (CH4) Nitrous oxide (N2O) Hydrofluorocarbons (HFC) Perfluorocarbons (PFC) Sulfur hexafluoride (SF6) Your environmental compliance is clearly our business.
  10. 10. Measurement and Reporting  Global Warming Potential (GWP) A measure of how much a given mass of GHG is estimated to contribute to global warming. It is a relative scale which compares the gas in question to CO2. GHG CO2 1 Methane 21 N2O 310 HFC-32 650 PFC-14 6,500 SF6 10 10 GWP 23,900 Your environmental compliance is clearly our business.
  11. 11. Measurement and Reporting  Emissions measured in CO2 equivalency (CO2e). Each gas placed on CO2e basis by multiplying GWP.  For GHG Reporting Rule emissions are measured in metric tons. 1 metric ton = 2,204.62 lbs  For GHG Tailoring Rule emissions are measured in short tons. 1 short ton = 2,000 lbs 1 short ton = 0.907186 metric tons 11 11 Your environmental compliance is clearly our business.
  12. 12. Measurement and Reporting  40 CFR Part 98 – Mandatory Greenhouse Gas Reporting.    Lead smelters that emit ≥ 25,000 mtCO2e/yr combined from all listed sources must report.    Subpart C – Stationary Combustion Sources Subpart R – Lead Production Confidential Business Information (CBI) Determinations.   12 12 Subpart A - General Provisions Subparts C to UU - Specific Source Categories Class of 2013 Class of 2015 Your environmental compliance is clearly our business.
  13. 13. Measurement and Reporting   EPA’s Facility Level Information on GreenHouse gases Tool (FLIGHT). First two years of reported data publicly available.   13 13 2010 annual emissions 2011 annual emissions Your environmental compliance is clearly our business.
  14. 14. Measurement and Reporting  Part 98 Combustion Emissions Calculation: CO2/CH4/N2O = 1x10-3 * Fuel (SCF) * HHV * Emission Factor ? CCF ? MCF ? MMCF ? CO2/CH4/N2O = 1x10-3 * Fuel (Therms) * 0.1 * Emission Factor ? Dth ? MDth ? MMDth ? CO2/CH4/N2O = 1x10-3 * Fuel (MMBtu) * Emission Factor ? MBtu ? CBtu ? Btu ? 14 14 Your environmental compliance is clearly our business.
  15. 15. Measurement and Reporting  Part 98 Lead Production Emissions Calculation: CO2 = 3.67 * 0.91 * Mass of Feed * %Carbon Content  % Carbon Content:   15 15 Provided by supplier. Collect and analyze at least 3 representative sample each year. Your environmental compliance is clearly our business.
  16. 16. Measurement and Reporting  % Carbon Content – what we have seen.* Lead Scrap Carbon Content Annual Average 3.4% 0.9% 0.3% 2010 2011 2012 Lead Scrap Carbon Content Individual Samples Within Year 21.5% 5.0% 2.0% Sample 1 Sample 2 Sample 3 * Examples – Not Real Data 16 16 Your environmental compliance is clearly our business.
  17. 17. Measurement and Reporting  Concerns:     17 17 Public data available to stakeholders. Permitting. Applicability under future standards. Lead-Carbon battery technology. Your environmental compliance is clearly our business.
  18. 18. GHG Permitting  Currently must address GHG in all applications.    Full GHG emission inventories required in renewal applications.   “Major source” label for another pollutant. Tailoring Rule Step 4 by April 2016.  18 18 Demonstrate PSD status. Best Available Control Technology (BACT) analysis. Thresholds could be lowered. Your environmental compliance is clearly our business.
  19. 19. GHG Standards  NSPS/NESHAP requirements.    Questionable GHG control technologies. Energy efficiency requirements.    19 19 Output based standard in current EGU proposal. Introduced in “Boiler MACT.” Could be part of Step 4. Could be added to existing standards. Your environmental compliance is clearly our business.
  20. 20. Actions to Consider  Review what has been submitted.   Assure representative carbon content data.    Increase sample frequency. Measure and sample more categories. Develop industry or facility-specific direct emission factors.  20 20 Amend if you find errors. Emission test data. Your environmental compliance is clearly our business.
  21. 21. Questions? Neal Lebo | nlebo@all4inc.com | 610.933.5246 x 113 All4 Inc. 2393 Kimberton Road P.O. Box 299 Kimberton, PA 19442 www.all4inc.com www.all4inc.com Kimberton, PA | 610.933.5246 Columbus, GA | 706.221.7688
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