On November 10, 2010, the Environmental Protection Agency released a number of resources to assist permitting authorities with implementation of the tailoring rule. This rulemaking applies the Clean Air Act provisions of Prevention of Significant Deterioration and Title V Operating Permits to greenhouse gases. Because of the complexity and novelty of this issue EPA has developed multiple resources including:
- General Guidance on application of PSD and Title V to GHG
- White papers on best available control technologies (BACT) options for a number of specific sources
- GHG Mitigation Technologies Database
In the guidance released EPA does not specify what any specific BACT should be. Instead they emphasize that permitting authorities should continue to use the five step BACT determination process that site is site specific, case-by-case basis. This process is:
- Identify all available control technologies
- Eliminate those technically infeasible
- Evaluate and rank remaining controls based on environmental effectiveness
- Evaluate cost effectiveness of controls
- Select BACT
Because of the lack of commercially available carbon capture and storage technology, EPA is strongly emphasizing facilities considering energy efficiency measures as a way to reduce their GHG emissions.
Many items specific to the solid waste sector have yet to be finalized. EPA is planning on releasing a landfill specific white paper on potential best available control technologies in the coming weeks. We will notify members when this is published. The agency however is not currently planning specific guidance for waste-to-energy facilities. In January, EPA is planning on releasing a guidance document on the use of biomass as a potential BACT.
We are still in the process of analyzing this document and will provide our members with additional updates as we continue our analysis.
More information can be found here.