Your SlideShare is downloading. ×
Recent Regulatory Initiatives Concerning Greenhouse Gases
Upcoming SlideShare
Loading in...5
×

Thanks for flagging this SlideShare!

Oops! An error has occurred.

×
Saving this for later? Get the SlideShare app to save on your phone or tablet. Read anywhere, anytime – even offline.
Text the download link to your phone
Standard text messaging rates apply

Recent Regulatory Initiatives Concerning Greenhouse Gases

380
views

Published on

Published in: Technology

0 Comments
0 Likes
Statistics
Notes
  • Be the first to comment

  • Be the first to like this

No Downloads
Views
Total Views
380
On Slideshare
0
From Embeds
0
Number of Embeds
0
Actions
Shares
0
Downloads
2
Comments
0
Likes
0
Embeds 0
No embeds

Report content
Flagged as inappropriate Flag as inappropriate
Flag as inappropriate

Select your reason for flagging this presentation as inappropriate.

Cancel
No notes for slide

Transcript

  • 1. Recent Regulatory Initiatives Concerning Greenhouse Gases ABR Fall Meeting Las Vegas, NV October 22, 2010 Neal Lebo All4 Inc.
  • 2. Agenda
    • GHG Reporting Rule
      • Amendments During 2010
      • Getting Ready to Report
    • GHG Tailoring Rule
  • 3. GHG Reporting Rule
    • 40 CFR Part 98 – Mandatory Greenhouse Gas Reporting.
    • Effective Date – December 29, 2009
    • Data monitoring and recordkeeping requirements began January 1, 2010.
    • Annual 2010 GHG emissions must be reported by March 31, 2011, and then annually thereafter.
    • Lead smelters that emit ≥ 25,000 mtCO 2 e/yr combined from all listed sources must report.
  • 4. GHG Reporting Rule Amendment Activity During 2010
    • Final new source categories – September 2010
      • Magnesium production – Subpart T
      • Underground coal mines – Subpart FF
      • Industrial wastewater treatment – Subpart II
      • Industrial waste landfills – Subpart TT
  • 5. GHG Reporting Rule Amendment Activity During 2010
    • Final amendments to General Provisions – November 2010. Applies to 2010 reports.
    • Reporters must include the following:
      • Names and physical addresses of all of their U.S. parent companies and their respective percentages of ownership.
      • Primary NAICS code and any additional applicable NAICS codes.
      • Whether any reported emissions include GHG emissions from a cogeneration unit located at the facility (either yes or no).
  • 6. GHG Reporting Rule Amendment Activity During 2010
    • Final technical corrections, clarifying and other amendments – signed but not yet published
      • To correct certain errors and to clarify provisions that have been the subject of questions from reporting entities. 
      • Examples of proposed changes:
        • New exemptions that eliminate the requirement to monitor and report GHG emissions for certain types of stationary combustion sources.
        • Revised calculation methodologies.
  • 7. GHG Reporting Rule Amendment Activity During 2010
    • Proposed Confidential Business Information (CBI) Determinations – July 2010.
      • “ Inputs to emission equations” are not CBI.
      • Include data on production, throughput, raw material consumption.
      • No opportunity to claim CBI when submitting data.
      • Comment period ended September 7, 2010.  
  • 8. GHG Reporting Rule Amendment Activity During 2010
    • Proposed New Source Categories
      • Petroleum and Natural Gas Systems.
      • Carbon Dioxide Injection and Geologic Sequestration.
      • Electronics Manufacturing.
      • Fluorinated Gas Production.
      • Use of Electric Transmission and Distribution Equipment.
      • Imports and Exports of Equipment Pre-charged with Fluorinated GHGs or Containing Fluorinated GHGs in Closed-cell Foams.
      • Manufacture of Electric Transmission and Distribution Equipment.
  • 9. GHG Reporting Rule Getting Ready To Report
    • Upcoming Deadlines
      • January 30, 2011:  Certificate of Representation due.
      • March 31, 2011:  2010 Annual Greenhouse Gas Report due.
  • 10. GHG Reporting Rule Getting Ready To Report
    • Data Checkup
      • Fuel usage and characteristics.
      • Process material quantities.
      • Process material carbon content.
      • Heat input capacity of aggregated units.
      • Sorbent usage.
      • Missing data.
      • Calculation tool.
      • “ Dry run” calculations.
  • 11. GHG Reporting Rule Getting Ready To Report
    • U.S. EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT)
      • User registration portion expected to be online this fall.
      • Must use this system to submit Certificate of Representation (due January 30, 2011).
  • 12. GHG Reporting Rule Getting Ready To Report
    • e-GGRT User Registration Process
    • Step 1 – System user registration
      • User account specific to individual.
      • Current Central Data Exchange (CDX) user name and password can be used to log in.
      • Security features.
      • Electronic Signature Agreement (ESA)
        • Print, sign and mail in.
        • U.S. EPA review for completeness before account is activated.
  • 13. GHG Reporting Rule Getting Ready To Report
    • e-GGRT User Registration Process
    • Step 2 – Facility registration
      • Set up facility profile.
        • Location, owners/operators.
  • 14. GHG Reporting Rule Getting Ready To Report
    • e-GGRT User Registration Process
    • Step 3 – Identify Designated Representative
      • All facilities must have a Designated Representative (DR) to submit reports.
      • Identify yourself or someone else.
      • DR must be a registered e-GGRT user.
      • Electronic invitation sent for acceptance.
      • Can also designate Alternate Designated Representative (ADR) (optional).
  • 15. GHG Reporting Rule Getting Ready To Report
    • e-GGRT User Registration Process
    • Step 4 – Identify Agents (optional)
      • DR or ADR delegates authority to make electronic submissions for the facility.
      • Agent must be a registered e-GGRT user.
      • Electronic invitation sent for acceptance.
      • DR or ADR must confirm.
  • 16. GHG Reporting Rule Getting Ready To Report
    • e-GGRT User Registration Process
    • Step 5 – DR and ADR sign and submit Certificate of Representation
      • Establishes the DR/ADR's authority to certify, sign, and submit annual GHG reports.
      • Electronic invitation sent.
      • Each facility must have a complete Certificate of Representation by January 30, 2011.
  • 17. GHG Reporting Rule Getting Ready To Report
    • e-GGRT User Registration Process
    • Step 5 (cont.) – DR and ADR sign and submit Notice of Delegation for Agents
      • Delegates authority to submit annual GHG reports.
      • Electronic invitation sent.
  • 18. GHG Tailoring Rule
    • Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas (GHG) Tailoring Rule.
      • Amends 40 CFR Parts 51, 52, 70 and 71.
      • Effective Date – August 2, 2010.
      • Sets timing and thresholds for addressing GHG emissions from stationary sources under Clean Air Act (CAA) permitting programs.
  • 19. GHG Tailoring Rule
    • GHGs become “subject to regulation” under the CAA on January 2, 2011.
    • The Light Duty Vehicle Rule (April 2010) established GHG emission standards.
    • U.S. EPA concludes that regulating GHG tailpipe emissions triggers regulating GHG under major source permitting programs (PSD and Title V).
  • 20. GHG Tailoring Rule
    • Major source permitting program emission thresholds are 100 and 250 tons per year (tpy).
      • Tens of thousands of new PSD permits.
      • Millions of new Title V permits.
    • GHG Tailoring Rule “tailors” these requirements to limit facilities required to get permits for GHG emissions.
  • 21. GHG Tailoring Rule
    • GHG Tailoring Rule is implemented for the largest sources of GHG emissions in two (2) steps.
      • Step 1 – January 2, 2011 to June 30, 2011.
      • Step 2 – July 1, 2011 to June 30, 2013.
    • U.S. EPA will begin rulemaking in 2011 to establish requirements for smaller sources.
    • In general, sources with GHG emissions below 50,000 tpy of carbon dioxide equivalent (CO 2 e) will not be regulated for at least six (6) years.
  • 22. GHG Tailoring Rule
    • PSD Applicability for GHG emission sources
      • Projects adding new or modifying emission units.
    • Step 1 – January 2, 2011 to June 30, 2011
      • No sources become major for PSD based solely on GHG emissions.
      • Sources major for any PSD pollutant other than GHG will also be major for GHG if the project increases GHG emissions by 75,000 tpy CO 2 e or more.
    • Step 2 – July 1, 2011 to June 30, 2016
      • Regardless of other PSD pollutants, the following must meet PSD permitting requirements:
        • New sources that emit GHGs at or above 100,000 tpy CO 2 e.
        • Modifications that increase GHG emissions by at least 75,000 tpy CO 2 e.
  • 23. GHG Tailoring Rule
    • What are PSD requirements for GHG emissions?
      • Must demonstrate Best Available Control Technology (BACT).
    • What is BACT for GHG Emissions?
      • U.S. EPA will be issuing guidance soon.
      • Energy efficiency assessment is expected to be a key element.
  • 24. GHG Tailoring Rule
    • Title V Applicability for GHG emission sources
      • Applications for new permits, renewals or revisions.
    • Step 1 – January 2, 2011 to June 30, 2011
      • No sources become major requiring a Title V permit based solely on GHG emissions.
      • Sources currently subject to Title V program for pollutants other than GHG must apply all Title V requirements to their GHG emissions.
    • Step 2 – July 1, 2011 to June 30, 2016
      • Facilities with GHG emissions of 100,000 tpy CO 2 e or more must obtain a Title V Operating Permit if they do not already have one.
  • 25. GHG Tailoring Rule
    • What are Title V requirements for GHG emissions?
      • No current Title V requirements to control GHG.
      • No other current CAA requirements (e.g., NESHAP) applicable to GHG.
      • State rules may have requirements (e.g., monitoring, recordkeeping and reporting).
      • Federal GHG Reporting Rule is not a Title V requirement.
  • 26. GHG Tailoring Rule
    • Impact on permit application process.
      • Emission inventories for PSD applicability must include GHG pollutants for comparison to thresholds.
      • Permit applications pending may have to be reopened or amended to address GHG pollutants.
      • Even minor applications will need to demonstrate that thresholds are not exceeded.
      • Title V renewal or modification applications should explain GHG applicable requirements.
  • 27. GHG Tailoring Rule
    • Related Proposed Rules
    • Finding of Substantial Inadequacy and SIP Call
      • Require permitting programs in 13 states to make changes to their state implementation plans (SIP) to ensure GHG emissions are covered.
      • All other states must review their existing permitting authority and inform U.S. EPA if their programs do not address GHG emissions.
    • Federal Implementation Plan
      • Allow U.S. EPA to issue permits for large GHG emitters located in states not able to develop and submit revisions to their plans before January 1,2011.
  • 28. Questions? [email_address] (610) 933-5246, extension 13 All4 Inc. 2393 Kimberton Road P.O. Box 299 Kimberton, PA 19442 www.all4inc.com