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Air and Water Foundry Audits: Most Common Findings and How to

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Greenhouse Gas Update
Session XV.
Jim Schifo, PE, VP
KERAMIDA Inc.
jschifo@keramida.com
Discussion Items
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Review of EPA Reporting Rule
Permitting – Part 70 (Title V)
Permitting – Prevention of
Significant Deterioration (PSD)
“Tailoring Rule”
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
How to determine GHGs?
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That depends
GHG Inventory Guidelines vary by purpose
EPA reporting has emission factors by
sector
Voluntary Programs have there own set of
rules.
Certain state programs have
their own approved protocols
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
Remember – EPA Reporting Rule Global
Warming Potentials
GWP – Effect compared to Carbon Dioxide
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CO2
CH4
N2O
HFCs
PFCs
SF6
1
21
310
Varies, most 1,000s
Varies, most 1,000
23,900
Intergovernmental Panel on Climate Change - Third Assessment Report
Carbon Dioxide Equivalents (CO2e) are
calculated using the above ratios.
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
What is Your GHG Inventory?
EPA Reporting
Rule/PSD/Permitting
Scope 1 - Direct
•Fuel Combustion on-Site
•Energy Generation on-Site
•Process GHG emissions
(more important for
certain industries)
•Refrigerants
•On Site Waste Disposal
•Fleet Vehicles
Purchased • Electricity
• Steam
Scope 2 - Indirect
• Chilled Water
(Energy)
Scope 3 - Indirect
•Business Air Travel
•Employee Commute
•Raw Materials
•Shipping by Third Parties
•Off-Site Waste Disposal
•Carbon Offsets 5
Greenhouse Gas Reporting Rule –
EPA
Started on January 2010
пЃ± Sector Specific Protocols Required
пЃ± Report at 25,000 Metric tons CO2e
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EPA reconsidering the requirement to
supply back-up data that may be of a
confidential business nature.
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
Report at What Level?
Actual
Natural Gas at about 475,000 MCF
Coke or Coal at about 10,000 tons/yr
(OR Combinations of the above)
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
What Size Metalcasting Facility will be
reporting?
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Al Diecasting Facility will be reporting at
about 25,500 tons of casting shipped per
year.
Iron Greensand Foundry with Cupola
Melting will report at about 43,000 tons
ship.
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
GHG Reporting Rule
40 CFR 98.30 General Stationary Fuel Combustion
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Not one of the 36 previously listed
Need only report CO2, CH4, and N2O from fuel
combustion
Need not report other sources of GHG, e.g.
HFC
Emergency and Portable Equipment Exempt
If you don’t know, then figure it out. Use the GHG
Emissions Calculator on AFS Web Site to
Determine your likely GHG emissions for 2010 and
future years.
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
9
What’s new for 2012?
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GHG Reporting for Industrial Waste Landfills
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If you will trigger 25,000 Metric tons CO2e
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Landfill design capacity of 300,000 Metric tons.
Exemption for greensand only (no cores)
Must determine organic contents and report emissions
of materials of over 0.5% volatiles.
Use EPA methods of estimating GHGs
Must consider all waste previously disposed of in the
landfill.
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Participate in AFS Committee 10-F for additional information on
landfill emissions. And Next EHS Session.
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
Greenhouse Gases as
Pollutants
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
GHG, Including CO2,as a Pollutants
(Condensed Version)
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Court rulings concluded that EPA has the
authority to regulate GHG, including CO2, as
pollutants. (2007 Supreme Court Decision in
Massachusetts v. EPA)
EPA made an Endangerment Finding in 2009
which is the first step in the rulemaking
process for regulating GHGs. GHGs are
regulated by EPA with the passage of the
rules governing new motor vehicles. (The
subject of the 2007 Supreme Court Decision)
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
GHGs as a Pollutant?
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These actions would then require EPA to then regulate
GHGs from Stationary Sources under the Act’s
prevention of significant deterioration (PSD) provisions
related to existing operating permits. (NSR, BACT)
So we now have GHGs as Regulated Pollutants applying
to PSD and Metalcasting Air Operating Permits.
Emission Levels listed in the Clean Air Act
would have required almost all Metalcasting
Facilities to have Major Source Operating
Permits and address PSD. (As would Schools,
Office Buildings, Hospitals, Apartment
Buildings, etc.)
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
Current PSD and CAA Major Source
Emission Triggers
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PSD in Metalcasting Facilities is usually triggered
at 100 tons per year of regulated pollutants and in
some cases 250 tons per year.
Title V Major Source air permits are triggered at
100 tons per year.
This process is based on Potential to Emit (PTE)
and not on Actual Emissions as in the GHG
Reporting Rule.
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
The Problem
EPA finally figured out what they did.
пЃ± GHGs do not fit the mold of criteria pollutants.
 The “Tailoring Rule”, issued on May 13, 2010
was the implemented fix
пЃ± AFS Provided comments to the Proposed
Rule.
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AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
The Problem
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the Tailoring rule counts GHG emissions
based on potential to emit and the
Reporting rule uses actual emissions;
the Tailoring rule uses short tons and the
Reporting rule uses metric; and
the Tailoring rule includes all GHG
emissions from a foundry and the Reporting
rule includes GHG emissions only from
combustion sources.
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
The Tailoring Rule/Title V
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Step 1 – Existing Sources subject to PSD anyway would not
have CO2e apply at 75,000 tons per year January 2 through
June 30, 2011.
Step 2 – Starting July 1, 2011 PSD would be triggered for new
sources at 100,000 tons CO2e and modifications at 75,000 tons
CO2e. (And 100 tons mass per year)
Step 3 – EPA examining the idea of GHG permitting of smaller
sources by July 1,2012. (but no lower than 50,000 tons CO2e)
EPA announced that they do not currently intend to lower the
current threshold.
Title V Major Sources are also at 100,000 tons CO2e per year.
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
What level for PSD/TV Major?
Potential
Natural Gas at about 1,650,000 MCF/yr
Coke or Coal at about 40,000 tons/yr
(Or Combinations of the above)
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
What Size Metalcasting Facility will be
Title V/PSD?
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Al Diecasting Facility will be reporting at
about 25,500+? tons of casting shipped per
year.
Iron Greensand Foundry with Cupola
Melting will report at about 100,000+? tons
ship.
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
Tailoring Rule
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Deadlines:
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PSD – any permit issued after July 1, 2011 will have
to address PSD for GHGs.
Title V Operating Permits
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Any Initial Permit issued after January 2, 2011
must address GHG.
Existing sources becoming Title V must
submit application by June 30, 2012, or
Limits on Potential to Emit (PTE) GHG in
place in a Federally Enforceable State
Operating Permit (FESOP) by June 30, 2012.
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
FESOP Implications
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If a FESOP modification is necessary to
avoid major source permitting it must be
issued by June 30, 2012.
Permit accountability and state goals are
to issue significant modifications within
120 days of submission.
So if you have not already submitted
FESOP modifications or applied for a
Title V permit, contact legal counsel and
permitting agency ASAP.
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
FESOP Implications
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You may already have PTE limitations
without mentioning GHG. e.g., Fuel use
limits for other pollutants.
Think through whether Title V might be
appropriate, or
Whether additional limits to remain
below major source thresholds will or will
not unreasonably interfere with business
plans.
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
Title V Implications
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States have generally folding in GHG
conditions for permits issued after July 1,
2011.
No GHG fees, or applicable requirements
other than PSD applicability have been
incorporated into permits.
EPA Mandatory Reporting Rule is not an
applicable requirement
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
PSD Implications
Already Major for Traditional
Pollutants:
Same as always, plus BACT for GHG
However:
Net increase in mass GHG must
exceed zero, and Net increase CO2e >
75,000 tpy
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
PSD Implications
Currently Minor for other NSR regulated pollutants,
but now Major for GHG, PSD applicability hinges
on applicability embedded in the definition of
“Subject to Regulation”.
“Subject to Regulation”,
“Any Regulated NSR Pollutant”,
“Major Stationary Source”, and
“Major Modification”
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
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PSD Implications
GHGs are “subject to regulation” only:
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At a new stationary source that has a
PTE GHG > 100,000 CO2e tpy
At an existing stationary source that has
a PTE GHG > 100,000 tpy CO2e, and the
physical change increases PTE GHG by
> 75,000 tpy CO2e
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
26
PSD Implications
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Unlike traditional pollutants, an
existing source:
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That is a Major Source for only GHGs
Must increase GHG emissions by > 75,000 tpy CO2e
before
Triggering PSD review for other NSR regulated pollutants
at the significant emissions increase level.
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That is: unless the modification significantly increases GHG,
then PSD applicability is treated as if a minor source.
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This is similar to applicability of Non-attainment NSR
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
PSD Implications
BACT, NAAQS, Monitoring, Increment, and
Other Impacts Analysis
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Updated November 2010 PSD and Title V
Permitting Guidance
Top-down BACT applies, facility-wide v. units
NAAQS, monitoring & Increment not applicable
Additional impacts/Class I not required due to
minimal global impact from single project
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
PSD Implications
BACT (Best Available Control Technology)
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Energy Efficiency
Fundamentally redefine project
Combined cycle v. simple cycle natural gas
IGCC
Carbon Capture & Storage “available”, but not
yet considered technically feasible. But must
be addressed
Has been expressed as energy/unit production
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
Is this all there is? No.
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A Title V permit holder can request limits to become a
FESOP. (Unless BACT or MACT)
A Major PSD Source can request limits to eliminate
the PSD Major Source designation only if the source
has not implemented PSD BACT.
The GHG PSD modification threshold of 75,000
tons/yr is difficult to reach, however once you
become a Major PSD Source, PSD applies for all
pollutants, not just GHG. Other pollutants could more
easily trigger PSD
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
Tailoring Rule
Questions?
AFS 24th Environmental, Health & Safety Conference
August 14-15, 2012 – Nashville, TN
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