1. Greenhouse Gas (GHG) Permit Training Region 4 – Atlanta, GA Dec. 14-15, 2010

2. Overview of Agenda GHGs Overview GHG Applicability GHG Applicability Flow Charts GHG Applicability Example & Exercise Information Resources GHG BACT Determination and examples Other Aspects of PSD GHGs and Title V DRAFT2

3. GHG Overview

4. PSD Permitting for Sources of GHGs GHGs are pollutants that trap heat in the atmosphere and are associated with climate change. Under EPA rulemaking, GHGs are a single air pollutant defined as the aggregate group of the following six gases: – Carbon dioxide (CO 2 ) – Methane (CH 4 ) – Nitrous oxide (N 2 0) – Sulfur hexafluoride (SF 6 ) – Hydrofluorocarbons (HFCs) – Perflurocarbons (PFCs) DRAFT4

5. Key Sources of GHGs Carbon Dioxide (CO 2 ) – Fuel combustion Methane (CH 4 ) – Landfills – Oil and gas production Nitrous oxide (N 2 0) – Fuel combustion Sulfur Hexafluoride (SF 6 ) – Magnesium production – Electrical Transmission DRAFT5

6. Key Sources of GHGs (cont’d) Hydrofluorocarbons (HFCs) – HFC manufacture – Semiconductor manufacturing Perfluorocarbons (PFCs) – Aluminum production – Semiconductor manufacturing DRAFT6

7. CO 2 Equivalency CO 2 equivalent (CO 2 e) aggregate emissions of GHGs based on relative global warming potential (GWP) CO 2 e = (mass of the GHG) x (its GWP) Current GWPs: – CO 2 : 1 – CH 4 : 21 – N 2 0: 310 – SF 6 : 23,900 – HFCs: 140 to over 11,700 – PFCs: 5,210 to 9,200 (Ratios may be revised. Set in Table A-1 of the GHG reporting rule. Subpart A of 40 CFR Part 98.) DRAFT7

8. “Tailoring Rule” Tailoring rule covers applicability of PSD and Title V to GHG emissions Issued June 3, 2010 http://www.gpo.gov/fdsys/pkg/FR-2010-06-03/pdf/2010-11974.pdf#page=1 Does not change the basic applicability processes Does incorporate a way to determine if emissions are in an amount that make GHGs a “regulated NSR pollutant”, based on level of CO 2 e emissions Consequently, applicability determined in two step process that evaluates: – Whether CO2e emissions are over “regulated NSR pollutant” thresholds – Whether mass emissions are over the PSD thresholds DRAFT8

9. Overview of “Tailoring Rule” Application of PSD to GHGs implemented in steps or phases. Applicability criteria Phase-In: – Step 1 between January 2, 2011 and June 30, 2011 – Step 2 on or after July 1, 2011 DRAFT9

10. GHG Permitting Guidance Document “PSD and Title V Permitting Guidance For Greenhouse Gases” November 2010 Assists permit writers and permit applicants Describes terms and requirements Reiterates relevant past guidance Provides recommendations and suggested methods Illustrates methods through examples DRAFT10

11. Contents of the Guidance Document PSD Applicability BACT Analysis Other PSD Requirements Title V Considerations Applicability Flowcharts and Example Calculation BACT Examples Information Resources DRAFT11