ENV-13-05 Strategic Considerations for Effectively Managing the Greenhouse Gas Permitting Process at Petroleum Refineries

Description:

In place since January 2, 2011, the U.S. Environmental Protection Agency’s (EPA’s) tailoring rule has regulated emissions of greenhouse gases (GHGs) under the New Source Review (NSR) program, specifically the Prevention of Significant Deterioration (PSD) regulations. While the tailoring rule sought to modify the thresholds provided for major stationary sources and major modifications found in 40 CFR §52.21 so that only the largest sources of GHGs would require air permits, operators have often found that GHGs are frequently the limiting pollutants in determining whether a new source or project triggers major stationary source or major modification status. As a result, many companies face important decisions related to GHG permitting strategy for a variety of physical changes made at their facilities. GHG permitting under the PSD program can impose additional technical complications and introduces schedule risk for construction of capital projects. Companies must balance the advantages and disadvantages of either undergoing PSD review or accepting synthetic minor restrictions that would avoid elements of the PSD program. To that end, refineries have applied various streamlining methods to improve certainty in the PSD permitting process. Finally, companies must manage potential conflicts between GHG emission calculations required by PSD and the methodologies prescribed by the EPA’s GHG Mandatory Reporting Rule (MRR).