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EPA’s GHG Tailoring Rule: Understand How
              it Will Impact Your Business




                                  ...
Agenda
 The Tailoring Rule – How did we get here?
 Impact of EPA's Greenhouse Gas Tailoring Rule related to
  Title V an...
MotivEarth: Our Offering
 GHG Advisory Services
   EPA and State Regulatory Interpretation
   GHG Inventory – Federal, ...
Justification for the Tailoring Rule
 Greenhouse gas emissions rates significantly higher than
  criteria and HAP emissio...
Tailoring Rule - A Problem of Scale
                        250
                                                          ...
3-Step Implementation




                        6
PSD Permitting – Tricky in the Transition
PSD Permit issued before January 2, 2011
   Need not be re-opened due to GHGs
 ...
Title V Permitting in the Transition
If you are applying for a Title V Permit for the 1st time
   Submit permit applicati...
“Top Down” BACT Process
 Step 1: Indentify all potentially applicable control
  technologies
 Step 2: Eliminate technica...
Steps 1 BACT Analysis – 3 considerations
1. Energy Efficiency
    Technology – Cogeneration, turbines, engines, super
   ...
Other Issues
 Treatment of biomass facilities
 First determinations of GHG BACT
    “Cost effective” GHG control
    E...
EPA Tailoring Rule Permit Strategies
                      James A. Westbrook
                       September 9, 2010
GHG Tailoring Rule Permit Strategies

 • Do anything now? YES!
 • Strategies:
   Avoid triggering permit requirements
   ...
BlueScape, Inc.
• National PSD and Title V permitting
  experience
• Solve tough air quality problems:
  Avoid PSD and Ti...
PSD & Title V Permitting Summary
• PSD Permitting
   New Source Review for construction
   Major Stationary Sources
   ...
Strategies for PSD and GHG
• Biggest PSD Issues:
   Delays, uncertainty, BACT expense, other issues (NO2, SO2
    impact ...
Strategies for Title V and GHG
• Biggest Title V Issues:
   GHG pulls in ALL applicable requirements
   A lot of work, m...
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

             ...
Power Plant Upgrade / Expansion
• Major PSD and Title V source currently
• Application submittal in Oct 2010
   3 existin...
Power Plant Upgrade Emissions

                                     NOx    PM2.5     GHG

Current Emission Factor (lb/MWh)...
Summary
• Evaluate against thresholds - Do you know your GHG
  PTE?
• Develop a permit strategy now to deal with GHG in
  ...
Next Webinar Tue, October 12

      Air Modeling for Non-Modelers
What’s Up with the New Ambient Standards?
              ...
Contact with Questions
      James A. Westbrook
         BlueScape, Inc.
       858-695-9200 x201
 jwestbrook@bluescapeinc...
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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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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 https://www2.gotomeeting.com/register/496570147
  24. 24. Contact with Questions James A. Westbrook BlueScape, Inc. 858-695-9200 x201 jwestbrook@bluescapeinc.com www.bluescapeinc.com Joseph Ritter MotivEarth, LLC 858-735-3288 jritter@motivearth.com www.motivearth.com

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