Open for Public Comment – EPA’s GHG Permitting Rule

Posted by admin on October 5th, 2009 filed in Uncategorized

Admittedly, placing controls on greenhouse gases from industrial sources sounds like a really good idea.  It is, of course, more of the same from EPA – continual point source controls on industry, while the real culprits are the individual consumers not willing to take responsibility for their __________ [vehicle emissions, storm water runoff, household waste].  The EPA’s new GHG Tailoring Proposal (love the name – sounds like something you’d get from Brook Brothers) takes a stab at the issue of raising the Title V (T5) and PSD significance levels for GHG sources at 25,000 tons CO2e.  While this is all well and good, the real issue is buried at the back of EPA’s proposal following a rambling legal exegesis of the criteria (“absurd results” and “administrative necessity”) required to allow them to move the limit from 250 TPY to 25,000 TPY.

That issue, is “potential to emit.”  Those three little words throw EPA’s proposal into a righteous scramble that far exceeds any of the issues associated with the threshold.  The threshold, after all, could be increased with one stroke of the pen by Congress inserting a single sentence into the Clean Air Act.  Not so the PTE issue.  You see, it’s like this – unlike emissions of the other criteria pollutants, industrial facilities burning natural gas or other fuels for heat (including convenience heat), facilities burning complex solvents in pollution control devices, and facilities using GHG-containing compounds are likely using that equipment at a fraction of it “rated capacity.”  What PTE really is is:  Rated Capacity (in pounds CO2e per hour) * 8760 hours (nominal number of hours in a year for permitting purposes).

This number is fairly simple to compute for a boiler (such as are used at power plants or some industrial facilities), it can be obtained for space heaters, engines, and generators. Where the PTE argument breaks down is in calculations for sources such as steel or glass plants that may use natural gas as a backup or secondary fuel, whose fuel consumption depends heavily on market, atmospheric, or other conditions. While EPA has proffered some lame proposals, such as developing source category limits, this all smacks of years of research and litigation.   In my opinion, there are hundreds, if not thousands of emissions sources with no idea how large their PTE for CO2e really is.  It’s very clear to me that EPA’s rule makers have never spent much time in an investment-cast foundry (with attendant heat treating) or a beef processing facility.

EPA’s rule places not only a burden on sources, but will also create huge external costs which will be passed on to consumers.  In the long run, it would be far cheaper and easier to charge a penny a therm more for natural gas and use those monies for the control of GHG.

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