AIR PERMITTING OF COMBUSTION SOURCES

Fred P. Osman, P.E.Osman Environmental

SolutionsHarrisburg, PAApril 21, 2011

8 EPA Major Combustion Rules in Past Year

AIR PERMITTING 101

CAA Program Affects§111 NSPS New/Modified§160 -193

NSR New/Mod (major)

§112 NESHAPS New & Existing§129 Waste

Combustion

New & Existing

GHG TAILORING RULE

1620 1860 1880 1920 1940 1980 200013

13.5

14

14.5

15

15.5

16

16.5

-

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

50,000

Global Average Temperature vs. Number of Pirates

Avg. Global TemperatureNumber of Pirates

Year

Glo

bal A

vera

ge T

em

pera

ture

(°C

)

Num

ber

of

Pir

ate

s (

Appro

xim

ate

)

TAILORING RULE APPROACHTailoring Rule sets higher thresholds for

GHGs

Step 1. Jan 2 – July 1, 2011 – Anyway sources

Step 2. July 1, 2011 and after: New PSD/Title V 100,000 TPY CO2(e)PSD modification 75,000 TPY CO2(e)

Step 3 – EPA, effective July 1, 2013 – thresholds TBD

Important Note: Biogenic Emissions are deferred(maybe)

TAILORING RULE IMPLICATIONS

Triggering major source for GHG requires: BACT - incorporates efficiency

considerationsCauses triggering for other pollutants as well

Very few minor source permits

DETERMINATION OF NON HAZARDOUS SECONDARY MATERIALS THAT ARE SOLID WASTE

Section 129

WASTE/NOT-WASTE

Not Waste WasteVirgin Fossil Fuel Non cellulosic

biomassClean, Woody Biomass Painted/treated

woodChipped Tires, w/o metalWhole tires - tire mgt prog.

Whole Tires from piles

Spec Oil Off-spec OilPaper sludge – gen control

Sewage Sludge

Resinated woodCoal Refuse?

CISWI (COMMERCIAL INDUSTRIAL SOLID WASTE INCINERATORS)

Exempted• MWCs•QF’s homogeneous waste

•MWI’s•SSI’s•HazWaste

CISWI IMPLEMENTATION

New or Modified Units – September 21, 2011

Existing Units – State Plan due 3/21/2012Compliance due w/i 3 years of state plan

approval or by March 21, 2016, which ever is sooner.

BOILER MACT

Major/Area Source?Only Gas ExemptWater Heaters ExemptNo Size exemption

AREA SOURCE BOILER MACT IMPLEMENTATION

New Units – Upon StartupExisting Units – March 21, 2012No Emission Limits, just Work Practice

Standards.Notice of Applicability due September

17, 2011 Biennial Tune-ups (1st due March 21,2012)Boilers >10 MMBTU/hr – one-time energy

assessment

PROPOSED UTILITY MACT

Finalize by 11/16/11Compliance in 3 yearsHg ControlPM surrogate for metalsHCl or SO2 (some cases)Enhanced Monitoring

INTERSTATE TRANSPORT RULE

Replaces CAIR Cap and Trade for SO2/NOX

Trading more limited than CAIR

OTHER CURRENT PERMITTING ISSUES

New 1 hour NOX standardProblems with emergency engines

New 1 hour SO2 standardAttainment by modeling and monitoring.