Environmental Management and Compliance News, Tips and Tools

March 31, 2012

And so it begins…

image: power plant emissions

It’s what you can’t see that is causing all the fuss…

The US Environmental Protection Agency has formally proposed the first national limits on emissions of greenhouse gases, specifically carbon dioxide. The Carbon Pollution Standard, proposed on March 27, will apply to new fossil-fuel electric utility generating units (EGUs). Affected units include boilers, integrated gasification combined cycle (IGCC) units and combined cycle turbine units larger than 25 megawatts. “New” excludes existing units and permitted units that begin construction within the next 12 months. The standard also will not apply to new EGUs that do not burn fossil fuels (for example, facilities that use biomass as fuel).

The proposed standard limits carbon dioxide emissions to 1,000 pounds of carbon dioxide per megawatt-hour of power output. EPA believes that new natural gas fired power plants will be able to meet the standard without add-on emission controls, but coal or petroleum coke units would need to incorporate additional control technologies, such as carbon capture and storage. While the standard does not explicitly forbid the construction of new coal-fired plants, the prohibitive costs for these carbon control technologies will arguably result in a de facto ban on new coal-burning facilities.
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Filed under: Air Pollution,Climate Change,Compliance,Greenhouse Gases,Rules and Regulations,USEPA — TCozzie @ 2:11 pm

January 30, 2012

Global warming worries? Just, relax…

image: snowstorm

Perhaps we’ll be enjoying these scenes for a long time yet…

Are concerns over man-made global warming (i.e., anthropogenic global climate change) overblown? So says this January 27 opinion piece in the Wall Street Journal online, written by sixteen eminent physical scientists. They argue that predictive computer models have exaggerated the potential effects of continued emissions of carbon dioxide, and point to the documented halt (or pause, depending on your perspective) in rising global temperatures over the last decade or so as evidence supporting their position.

Not to be outdone, the UK Daily Mail waded into the global warming debate with two seemingly contradictory articles: First, theorizing that global cooling, not warming, may be a more immediate concern on the global temperature front, based on solar energy cycles – and then, on the same day, reporting that the British government’s national risk assessment on climate change warns that increasing temperatures will lead to “major increases in flooding, heatwaves and water shortages that could kill thousands of people a year.”

What should we make of the current state of anthropogenic climate change science?
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Filed under: Air Pollution,Climate Change,Greenhouse Gases — TCozzie @ 11:03 am

August 29, 2011

Emissions standards for existing boilers at area sources – It’s time to comply!

Photo of Emissions from Boilers and Other Sources

(A little snow in the picture to alleviate the Florida August heat…)

The initial notification date for the National Emission Standards for Hazardous Air Pollutants (NESHAPs) from boilers at area sources (40 CFR part 63 subpart JJJJJJ) is September 17, 2011. By that date, owners or operators of existing, regulated boilers must complete and submit the Initial Notification of Applicability to the appropriate authority (EPA or State environmental agency).

The rule applies to industrial, institutional and commercial boilers located at “area” sources that burn solid fossil fuels, biomass or liquid fuels – e.g., coal, wood, or oil – if not already regulated under another NESHAP standard. An area source is one with the potential to emit less than 10 tons per year of any one Hazardous Air Pollutant and less than 25 tons per year of total HAPs.

Requirements for work practices or the management standard practice of a tune-up must be met by March 21, 2012. Existing sources subject to emissions limits or an energy assessment requirement must comply by March 21, 2014. Emission standards, applicable to existing coal-fired boilers, include Maximum Achievable Control Technology (MACT) standards for mercury and carbon monoxide and Generally Achievable Control Technology (GACT) limits for particulate matter.

Here’s a general guidance on how to comply:  http://www.epa.gov/ttn/atw/boiler/imptools/area_sm_biz_compli_guide_appx.pdf

Here’s more on the boiler MACT rules: http://www.epa.gov/ttn/atw/boiler/boilerpg.html. A copy of the area source rule can be found at http://www.epa.gov/ttn/atw/boiler/fr21mr11a.pdf.

Filed under: Air Pollution,Compliance,MACT,NESHAPs,Rules and Regulations,Uncategorized,USEPA — TCozzie @ 9:07 am

March 18, 2011

Not ready to report greenhouse gas emissions? No worries…

The Environmental Protection Agency has finalized its rule to extend the deadline for reporting 2010 emissions of greenhouse gases (GHGs) to September 30, 2011. (Reports had been due by the end of this month.)

Those facilities required to report their GHG emissions must first register with the EPA’s electronic greenhouse gas reporting tool (“e-GGRT”). Registration will now be due 60 days prior to the reporting deadline, or by August 1.

For information on the GHG reporting requirements, visit www.epa.gov/climatechange/emissions/ghgrulemaking.html. The e-GGRT reporting tool can be accessed at ghgreporting.epa.gov/ghg/login.do.  And come back to this site soon for upcoming posts on GHG rules.

Filed under: Air Pollution,Climate Change,Compliance,Greenhouse Gases,Rules and Regulations,USEPA — TCozzie @ 3:26 pm

March 9, 2011

Finally! Air emissions standards for boilers and incinerators

The U.S. Environmental Protection Agency (EPA) has issued final Clean Air Act standards for boilers and certain incinerators to reduce toxic air emissions, including mercury and soot. The rule establishes hazardous air pollutant emission standards for new and existing industrial, commercial and institutional boilers and process heaters located at major and area (minor) sources of toxic air pollutants, as well as commercial and industrial solid waste incinerators.  The final rule was signed on February 21.

EPA proposed these rules in April 2010, after a rulemaking period that began in 2007 when a federal court vacated a previous proposal for industry specific standards. Based on substantial public input that was received after the April 2010 proposal, EPA has made extensive revisions to the rules proposed at that time.

EPA estimates that the boiler rules will affect about 200,000 units located at large (major) and small (area) sources of hazardous air pollutant emissions across the country. The types of boilers covered by the new standards include:

  • Boilers and process heaters at major sources of hazardous or toxic air pollutants, such as refineries, chemical plants, and other industrial facilities, that burn natural gas, fuel oil, coal, biomass or other gases. EPA has further identified some 15 (!) subcategories of regulated boilers and process heaters at major sources.
  • Boilers located at area sources of toxic air emissions, including other industrial facilities, universities, hospitals, hotels and commercial buildings that burn fuel oil, coal or biomass. While these units constitute the far greater number of sources, they are responsible for a relatively small amount of the toxic air emissions addressed by the rule.

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Filed under: Air Pollution,Compliance,USEPA — TCozzie @ 5:22 pm

August 9, 2010

Scoffing at skeptics…

On July 29, The U.S. Environmental Protection Agency (EPA) denied 10 petitions challenging its 2009 determination that

  • climate change is real,
  • it is occurring due to emissions of greenhouse gases from human activities, and
  • it threatens human health and the environment.

EPA’s decision rejected claims that climate science cannot be trusted and that collusion (dare we say, a “conspiracy”?) among members of leading research bodies to suppress conflicting data and hide errors or gaps in their own research invalidates the findings of the Intergovernmental Panel on Climate Change (IPCC), the U.S. National Academy of Sciences, and the U.S. Global Change Research Program. Having given “months of serious consideration” to the petitions and to the state of climate change science, EPA found no evidence to support these claims. In fact, EPA has determined that climate science is credible, compelling, and growing stronger!

EPA Administrator Lisa P. Jackson blamed the petitions on “defenders of the status quo [who] will try to slow our efforts to get America running on clean energy,” and called on petitioners “to join the vast majority of the American people who want to see more green jobs, more clean energy innovation and an end to the oil addiction that pollutes our planet and jeopardizes our national security.”

The basic assertions by the petitioners and EPA responses follow.
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Filed under: Air Pollution,Climate Change,Greenhouse Gases,USEPA — TCozzie @ 2:36 pm

May 13, 2010

Thresholds for greenhouse gas permitting announced

On May 13, the US Environmental Protection Agency (EPA) announced its final “GHG Tailoring” rule to address greenhouse gas (GHG) emissions from stationary sources. The phased-in approach will initially address large facilities like power plants and oil refineries that emit most of the greenhouse gases from stationary sources. The regulated GHGs include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride.

(image of clouds)Starting in January 2011, Clean Air Act permitting requirements for GHGs will apply to large facilities that are already obtaining Clean Air Act permits for other pollutants. Those facilities will be required to include GHGs in their permit if they increase their GHG emissions by 75,000 tons per year (tpy). In July 2011, permitting requirements will expand to cover all new facilities with GHG emissions of at least 100,000 tpy and modifications at existing facilities that would increase GHG emissions by at least 75,000 tpy. The permits must demonstrate the use of best available control technologies to minimize GHG emission increases when facilities are constructed or significantly modified. EPA estimates approximately 900 additional permitting actions covering new sources and modifications to existing sources would be subject to review each year. In addition, 550 sources will need to obtain operating permits for the first time because of their GHG emissions.

Permitting requirements for smaller sources will await the findings of a 5-year study of the effects of GHG permitting of these sources, slated for completion in 2015.

According to the EPA press release announcing the final rule, the agency received about 450,000 (!) comments within the 60-day public comment period that followed issuance of the proposed rule in October 2009.

More information on the GHG Tailoring Rule and its implementation schedule can be found at http://www.epa.gov/nsr/actions.html.

What do you think? Has EPA struck the proper balance between regulating a significant threat to health and the environment and providing relief to small businesses and farms?

Filed under: Air Pollution,Compliance,Greenhouse Gases,Permits,USEPA — TCozzie @ 5:01 pm

Air pollutant emission standards for boilers and process heaters

On April 29, 2010, the US Environmental Protection Agency (EPA) proposed three rules to regulate hazardous air emissions from commercial, institutional and industrial boilers, process heaters and incinerators at major and area sources.

(emission control device and exhaust stack)One of the proposed rules addresses boilers at area sources – facilities that potentially emit less than 10 tons per year (tpy) of any single hazardous air pollutant or 25 tpy of combined air toxics. The rule will apply to facilities with boilers that burn coal, oil or biomass (i.e., wood), but not waste materials. New boilers that burn coal would need to meet emission standards for mercury, particulates and carbon monoxide. New boilers burning oil or biomass will need to meet emission limits for particulates and carbon monoxide. Existing large boilers (heat input of 10 million Btu/hr or greater) that burn coal will be required to meet emission limits for mercury and carbon monoxide; existing large boilers that are oil or biomass-fired will have an emission limit for carbon monoxide, only. The rule requires that all facilities with large boilers conduct an energy assessment to identify practicable conservation measures. Facilities with small boilers will be required only to conduct a boiler tune-up at least once every two years.

The second rule applies to boilers and process heaters at major source facilities. The rule will apply to boilers that burn natural gas, fuel oil, coal, biomass or other gas, but not waste, and to process heaters (which heat raw or intermediate materials in an industrial process).
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Filed under: Air Pollution,Compliance,Rules and Regulations,USEPA — TCozzie @ 5:00 pm

April 20, 2010

EPA proposes expansion of mandatory greenhouse gases reporting requirements

In three four (!) separate notices published in the April 12 Federal Register, the US Environmental Protection Agency has proposed to expand the information required under the Mandatory Reporting of Greenhouse Gases Rule.  The additional information to be required includes…

  • reporting of emissions of fluorinated greenhouse gases (GHGs) from certain sources, such as electronics manufacturing, production of fluorinated gases, and use of electrical transmission and distribution equipment, as well as manufacture or refurbishment of electrical equipment;
  • reporting on carbon dioxide (CO2) injection and geologic sequestration;
  • emissions reporting from the following industry segments:  petroleum and natural gas production, natural gas processing, natural gas transmission compressor stations, underground natural gas storage, liquefied natural gas (LNG) storage, LNG import and export terminals and distribution; and
  • for reporters subject to the rule to provide:  the name, address, and ownership status of their US parent company; their primary and all other applicable North American Industry Classification System (NAICS) codes; and an indication of whether or not any of their reported emissions are from a cogeneration unit.

For more information on the proposed rules and how to comment, visit the EPA’s GHG reporting web page.

Filed under: Air Pollution,Compliance,Greenhouse Gases,Reporting,Rules and Regulations,USEPA — TCozzie @ 5:50 pm

March 31, 2010

For “major” sources of air pollution, the hits keep coming…

In a matter of a few weeks, the US Environmental Protection Agency (EPA) has proposed several actions that could have dramatic impacts for facilities subject to Clean Air Act New Source Review (NSR) provisions (i.e., major sources of air pollutant emissions).  These actions address the grandfathering provision for fine particulate emissions, the fugitive emissions rule and the aggregation rule.  To wit:

  • On February 4, EPA proposed to repeal the NSR “grandfathering provision” for emissions of particulate matter less than 2.5 microns, or micrometers, in diameter (PM2.5), commonly termed “fine particulates.”  The rule had allowed permit applicants to rely on permitting requirements for “coarse particulates” – particulate matter 10 microns or less in diameter, or PM10 -  as a surrogate for PM2.5 requirements if the application had been submitted prior to July 15, 2008.  The EPA proposal also will end the “PM10 surrogate policy” by no later than May 2011, eliminating the use of PM10 as a substitute for PM2.5 analysis in State permitting programs.

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Filed under: Air Pollution,Compliance,Permits — TCozzie @ 3:58 pm
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