AIR PERMITTING OF COMBUSTION SOURCES Fred P. Osman, P.E. Osman Environmental Solutions Harrisburg, PA April 21, 2011
Dec 13, 2015
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.