Transcript GHG Overview - Georgia Air

Greenhouse Gas (GHG) Permit Training
Other Aspects of PSD
Title V Permitting
Other Aspects of PSD Implementation
Air Quality and Impact Analyses:
GHG Specific Considerations
• Since no NAAQS or PSD increments exist for GHGs,
PSD applicants are not required to model GHGs or
conduct ambient monitoring for GHGs.
• While GHGs will induce warming and impact the
environment, including Class I areas and soil and
vegetation, it is not feasible with current climate
change modeling to detect and attribute such
impacts to a specific source of GHGs in permit
review.
DRAFT
3
GHGs and Title V
Title V Considerations
• Title V permit must contain conditions necessary to ensure
compliance with applicable requirements for GHGs (e.g., PSD
permit conditions)
• Title V applications (including permit revision, reopening or
renewal) are required to provide emissions information for all
pollutants for which it is considered “major”
• Under Step 1 of Tailoring Rule, a new or modified stationary
source cannot be "major" solely on basis of GHG emissions
– So not all applicants required to provide GHG emissions information
– However, permitting authority can request GHG emissions information
from applicant to verify that PSD was not triggered by a GHG source
DRAFT
5
Title V Considerations (cont’d)
• Under Step 2, a stationary source can be "major" solely
on basis of GHG emissions if it exceeds the 100,000 tpy
CO2e threshold
– So permit applicants over the threshold must provide GHG
emissions data (in addition to information for all other air
pollutants for which they are major)
– Particularly in cases where there are no applicable requirements
for the GHG emission source, a description of the source
(instead of an emission estimate) may be sufficient (see 1995
Title V policy guidance White Paper #1)
– Sources newly subject to Title V solely because of GHG
emissions will still need to provide required information for all
applicable requirements under Clean Air Act (e.g., requirements
in a SIP). Appropriately, as for other applicable requirements,
monitoring, recordkeeping and reporting conditions will be
required for those requirements.
DRAFT
6
Title V Considerations (cont’d)
Summary of Title V Applicability Criteria for Sources of GHG
January 2, 2011 to June 30 2011
(Step 1 of the Tailoring Rule)
No sources are subject to title V
permitting solely as a result of
their emissions of GHGs.
(Thus, no new title V sources
come into the title V program as
a result of GHG emissions.)
On or after July 1, 2011
(Step 2 of the Tailoring Rule)
The following sources are subject
to title V permitting as a result of
their GHG emissions:
• Existing or newly constructed
GHG emission sources (not
already subject to title V) that
emit or have a PTE equal to or
greater than:
• 100,000 TPY CO2e; and
• 100 TPY GHGs mass-basis
DRAFT
7
Title V Considerations (cont’d)
• Note that in Step 2, as under Step 1, for all “anyway
sources” subject to title V, sources and permitting
authorities need to meet the generally applicable title V
application and permitting requirements as necessary to
address GHG applicable requirements established under
other CAA programs (e.g., the PSD program)
• It is expected, at least at the outset, that this will consist
primarily of meeting application and permitting
requirements necessary to assure compliance with PSD
permitting requirements for GHGs.
DRAFT
8
Title V Considerations (cont’d)
• GHG emissions reporting under Mandatory Reporting Rule
not currently considered an "applicable requirement" under
EPA regulations implementing Title V; so this reporting
requirement does not need to be included in the Title V
permit.
• EPA is not changing its title V fee regulations or requiring new
fee demonstrations from states at this time. However,
permitting authorities must collect fees to cover the costs of
processing title V permits for major GHG sources. ???
• EPA flexible permitting provisions extend to GHG sources.
Permitting authorities and permit applicants, may find that
PALs, alternative operating scenarios and advanced approvals
are useful when energy efficiency measures are being
considered that reduce GHGs.
DRAFT
9