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New EPA standards will soon affect ability to receive air quality permits

EPA’s New Air Quality Standards

What action did the EPA take? On June 14, 2012, the U.S. Environmental Protection Agency (EPA) proposed to strengthen the National Ambient Air Quality Standards (NAAQS) for fine particle pollution, also known as fine particulate matter (PM2.5). The agency also proposed to retain the existing standards for coarse particle pollution (PM10). This was in response to a court order from the D.C. Circuit Court of Appeals.Specifically, this sets the standard annual level for fine particles within the range of 12 micrograms per cubic meter (μg/m3) to 13 μg/m3. The current annual standard, 15 μg/m3, has been in place since 1997. Evidence supporting this lower standard has continued to grow, leaving the EPA no choice but to enforce the stricter standard. The EPA will retain the existing 24-hour fine particle
standard, at 35 μg/m3.
When do the new regulations go into effect? The rule is expected to become final in December 2012 and effective 60 days later, sometime in March 2013.
What are the sources of fine particulate matter? Fine particles come from a variety of sources including vehicles, smokestacks, and fires. They also form when gases emitted by power plants, industrial processes, and gasoline and diesel engines react in the atmosphere. Sources of coarse particles include road dust that is kicked up by traffic, some agricultural operations, construction and demolition operations, central heating plants at universities and hospitals, industrial processes, and biomass burning.
How does this tighter standard affect obtaining permits on upcoming projects? It will be much harder to pass air dispersion modeling for PM2.5 at property fence lines to demonstrate compliance with NAAQS. Some parts of the country (the Southeast in particular) have close to, or more than, 12 – 13 μg/m3 of background PM2.5 from naturally occurring substances like pollen and dust. That leaves little or no room for emissions generated from the site. Therefore, the sites may need more extensive air pollution control equipment. Some may simply notbe able to meet the standard, not be granted a permit, and therefore not be able to build on the site.Note: The EPA predicts that the projected emission reductions associated with new regulations for power plants, heavy-duty diesel engines, and the sulfur content of gasoline will allow facilities in large areas of the country to meet the revised standards. However, depending on the final standard, manufacturers in other parts of the country may have to install pollution control devices to reduce their emissions.
Do I have any options? Yes, if you act quickly. To ensure a smooth transition to the new standards, the EPA is proposing to grandfather pre-construction permitting applications so long as a draft permit or preliminary determination has been issued for public comment before the revised rule is finalized (early December 2012). It is extremely important that you understand the impact of the new regulations and how you can avoid being denied a permit.
What if I do nothing? After the regulation becomes final, you may have to add additional air pollution controls to your facility or revise your project plans in order to meet the new standards before you can be issued a permit. This could significantly alter the scope, schedule, and cost of your project.
How can SSOE help? Our air quality experts can help you determine if the new regulations will affect your project. We can also assist with all aspects of developing and submitting the application for the permit. Since the process may take several months, you will need to get SSOE involved as soon as possible.

Federal Greenhouse Gas (GHG) Tailoring Rule

What is it? In May 2010, the EPA issued a final ruling to increase the major source thresholds for GHGs from
100/250 TPY to 25,000 TPY, effectively “tailoring” the PSD and Title V permit programs to target only “major” GHG sources and major modifications. GHG’s include CO2, N2O, CH4, HFCs, PFCs, and SF6.
Why does it exist? To phase in permitting requirements and reduce the number of applications submitted at one time.
Who does it affect? All facilities applying for, renewing, or revising an air quality permit; or facilities that increase their GHG emissions by 75,000 TPY.
What’s required? Phase 1:Permits Issued Jan. 2, 2011 – June 30, 2011

  • PSD permit: new construction projects or modifications that increase GHG to more than 75,000 TPY are required to conduct a Best Available Control Technology (BACT) analysis.
  • Title V permits: only when applying for a new, renewing, or revising a permit.

Phase 2: Permits Issued July 1, 2011 – June 30, 2013

  • PSD permit: new construction projects that emit GHG emissions of at least 100,000 TPY, and modifications to existing facilities that increase GHG emissions by at least 75,000 TPY.
  • Title V permit: facilities that emit at least 100,000 TPY
How does SSOE help? Help clients understand the permit requirements and how they apply to them.Complete / coordinate permit applications and help revise processes and/or building plans to meet guidelines.
How does SSOE add value? SSOE applies its broad knowledge of industrial processes and facilities and full range of services to identify emissions issues before permits are submitted for review.

Mandatory GHG Reporting Rule

What is it? In October 2009, the EPA issued the “Mandatory Reporting of GHGs Rule” that requires industrial facilities to report their GHG data and other relevant information. The Rule is referred to as 40 CFR 98 (or Part 98 Rule).The gases reported include CO2, N2O,and CH4.
Why does it exist? To gain accurate and timely GHG data that will inform future decisions.
Who does it affect? Facilities that emit 25,000 TPY of GHGs, and any of the following facility types:

  • Adipic acid production
  • Aluminum production
  • Ammonia production
  • Certain electricity generation
  • Certain manure management systems
  • Certain municipal solid waste landfills
  • HCFC-22 production
  • Certain HFC-23 destruction processes
  • Lime manufacturing
  • Nitric acid production
  • Petrochemical production
  • Phosphoric acid production
  • Silicon carbide production
  • Soda ash production
  • Titanium dioxide production
What’s required? Facilities that exceed thresholds are required to submit annual reports to the EPA.
How does SSOE help? Help clients understand and interpret industry-specific requirements.

Identify processes and sources that emit GHGs.

Help create and implement an effective GHG monitoring plan.

Identify areas and strategies to decrease GHG emissions and increase efficiency.

How does SSOE add value? Alleviate the cost and time of internal resources.

Experienced specialists know what data needs to be collected and calculations performed, as well as how to organize the reports to meet the EPA’s criteria.

Full range of services allow us to help implement components of GHG monitoring plan (i.e. integrate meters and controls systems).

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