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AWMA/US EPA Information Exchange, 27-28 Nov, 2012, North Carolina, USA, Day 1

Every year, the US EPA at Research Triangle Park, Raleigh Durham, NC, USA, host an information exchange with interested members of the Air and Waste Management Association (AWMA). The meeting, of around 70-80 people, is a good mix of regulators, utilities and interested parties who openly discuss current and impending legislation being produced at the US EPA. The following notes summarise those points which will be of most interest to IEA CCC members and colleagues. Unless otherwise indicated, the speakers below were US EPA employees.
Nick Hutson gave a summary of the proposed new utility GHG NSPS (greenhouse gas new source performance standards) rule. The rule was announced in the US Federal Register on April 13, 2012 and has turned out to be even more controversial than MATs (the new mercury and air toxics standard). The EPA has received over 1.4million comments and so there is no date for finalisation as this will take time. However, they are prepared to admit that the rule is “not imminent” – probably several years away.
The rule is only for new plants (post 1 April 2012). It will be an output based standard for combustion plants but will not apply to gas turbines. Put simply – new coal and petroleum coke plants will need CCS installed to comply with a 1,000 lb CO2/MWh limit. However, this will be applied as a 30 year average. That is, the plant has to show CO2 overall control eventually but this may take place over three decades.  There is therefore some leniency to start with relatively high emissions and catch up later in the time line. Plants could install CCS immediately and optimise performance over time or delay CCS for up to 10 years to wait for the technology to become economically viable. This also means there is flexibility for utilities to wait for CO2 pipelines and storage facilities to be built. The regulatory authority would determine annual emission limits over the 30 year time line which would demonstrate some movement towards the final overall target is being made.
Transitional sources (those at final planning or construction stages) are exempt and this applies to around 15 plants. More details can be found at www.epa.gov/carbonpollutionstandard
Dave Svendsgaard gave an update on the GHG permitting and tailoring rule which limits CO2 for plants emitting above a defined threshold (25,000 t/y?).  Some problems still remain with refining the rule and 9 states still have not finalised their state permits.  There is a 5 year study to determine the effectiveness of the rule and to see if thresholds need to be lowered which will be finalised by April 30th 2015.
As of Nov 2012, 60 PSD (Prevention of Significant Deterioration) permits had been issued with GHG BACT (best available control technology) requirements – of these, 10 are EPA permits (additional Federal rules apply). The rule is expected to result in efficiency design changes although add-on controls are being considered.
Mark DeFigueiredo described the EPA GHG reporting programme which is applicable to different sources emitting over the threshold amount. There are different methods for calculating emissions available (monitoring, emission factors etc). The e-GGRT  is an electronic GHG reporting tool with a user-friendly interface and automatic electronic verification of all audits being reported online. More details are available at http://ghgdata.epa.gov/

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