1Permits, New Source Review,Toxics Subcommittee:Climate Change WorkgroupCo-Chairs:Eric Svenson, PSEGMark Macleod, EDFPeter Tsirigotis, EPAOctober 7, 20092Background•PSD Tailoring Rule for GHGs proposed by EPA last week–Initially, proposal focuses on new and modified stationarysources emitting GHGs >25K tons of CO2e•EPA’s Mobile Source rule scheduled to be promulgated inSpring 2010–GHGs will become a regulated pollutant–PSD will apply to major industrial sources•EPA recognizes that Stateswill need support when GHGBACT determinations are being made for the first time–Technical information and guidance•The Climate Change Workgroup was formed under thePermits, New Source Review and Toxics Subcommitteeto get CAAAC input on how best to provide support–Kick-off call last week–First meeting yesterday3Current Workgroup Charge•Focus on the BACT requirement, including informationand guidance that would be useful for EPA to provideconcerning the technical, economic, and environmentalperformance characteristics of potential BACT options•Identify and discuss approachesto enable state and localpermitting authorities to apply the BACT criteria in aconsistent, practical and efficient manner•Explore new and innovative approaches that can beincorporated in the BACT analysis within the frameworkof the current Clean Air Act•Develop an initial Workgroupdraft by the end of the year4BACT Topic Areas•Topic Area 1: Technical Information and Data regardingGHG Control Technologies, Measures and Strategies•Topic Area 2: Insights on evaluating the energy,environmental, economic impacts of GHG Controls, forexample:–Energy efficiency considerations such as demand-sidemanagement, or plant-wide efficiency standards–Collateral pollutant impacts•Topic Area 3: Evaluating and encouraging new andemerging GHG control technologies and strategies5The BACT Process – In General•EPA gave a presentation onits “top down” BACT process,including the following 5-Step process:–Step 1: Identify all potential control technologies–Step 2: Eliminate technically infeasible options–Step 3: Rank remainingcontrols by effectiveness–Step 4: Evaluate most effective controls and document results•Assumes the best control optionis BACT unless it can be shownto have unacceptable energy, environmental or economicimpacts–Step 5: Select BACT•BACT can be no less stringent than the applicable NSPS6Group Discussion•State permit writers need sufficient technicalinformation and guidance to conduct timely BACTdeterminations beginning potentially this Spring•Group also interested in exploring new andinnovative approaches for determining BACT giventhe unique issues surrounding GHGs•Need to balance the need for a quick product withthe opportunity to promote innovation•Explored interim work products that can helpfocus the workgroup and lead to a product (e.g.,case studies, compiling available info on web)7Next Steps•Goal: Draft product for review by end of year–Initially workgroup will focus oncase studies to identify whatpermit writers will likely face–Engage in primary needs first•technical information and data•Guidance on likely and relatively straight-forward issues–Explore innovative concepts along the way (usually one or moreindividuals will provide the workgroup with a proposal fordiscussion)•We will hold meetings on a bi-weekly basis–Will update full subcommittee regularly–Post interim products and information on subcommittee website