1. Fred P. Osman, P.E. Osman Environmental Solutions Harrisburg, PA April 21, 2011

2. 8 EPA Major Combustion Rules in Past Year

3. CAAProgramAffects §111NSPSNew/Modified §160 -193 NSRNew/Mod (major) §112NESHAPSNew & Existing §129Waste Combustion New & Existing

5. Tailoring Rule sets higher thresholds for GHGs Step 1. Jan 2 – July 1, 2011 – Anyway sources Step 2. July 1, 2011 and after: New PSD/Title V 100,000 TPY CO 2 (e) PSD modification 75,000 TPY CO 2 (e) Step 3 – EPA, effective July 1, 2013 – thresholds TBD Important Note: Biogenic Emissions are deferred(maybe)

6. Triggering major source for GHG requires: BACT - incorporates efficiency considerations Causes triggering for other pollutants as well Very few minor source permits

7. Section 129

8. Not WasteWaste Virgin Fossil FuelNon cellulosic biomass Clean, Woody BiomassPainted/treated wood Chipped Tires, w/o metal Whole tires - tire mgt prog.Whole Tires from piles Spec OilOff-spec Oil Paper sludge – gen controlSewage Sludge Resinated wood Coal Refuse?

9. Exempted MWCs QF’s homogeneous waste MWI’s SSI’s HazWaste

10. New or Modified Units – September 21, 2011 Existing Units – State Plan due 3/21/2012 Compliance due w/i 3 years of state plan approval or by March 21, 2016, which ever is sooner.

11. Major/Area Source? Only Gas Exempt Water Heaters Exempt No Size exemption

12. New Units – Upon Startup Existing Units – March 21, 2012 No Emission Limits, just Work Practice Standards. Notice of Applicability due September 17, 2011 Biennial Tune-ups (1 st due March 21,2012) Boilers >10 MMBTU/hr – one-time energy assessment

13. Finalize by 11/16/11 Compliance in 3 years Hg Control PM surrogate for metals HCl or SO 2 (some cases) Enhanced Monitoring

14. Replaces CAIR Cap and Trade for SO 2 /NO X Trading more limited than CAIR

15. New 1 hour NO X standard Problems with emergency engines New 1 hour SO 2 standard Attainment by modeling and monitoring.