Environmental Permitting

$34K Fine for GHG Violations

The violations were identified and self-disclosed by the company and occurred in late 2011, when the company constructed three steam generators at the oil field without first obtaining a permit for greenhouse gas emissions under the Prevention of Significant Deterioration (PSD) permitting program.

EPA granted authority to the San Joaquin Valley Air Pollution Control District to issue PSD permits to sources within its jurisdiction. Companies can now obtain all necessary air permits from the local air agency. The company will obtain the necessary PSD permit for the steam generators from the District. While the PSD program has been in place for decades, permitting requirements for greenhouse gases became applicable in 2011.

PSD is a preconstruction permitting program that applies to large stationary sources of air pollution. Before beginning construction of a project that is subject to PSD requirements, the owner or operator of the facility must obtain a permit that specifies how the facility will use the Best Available Control Technology to reduce air emissions.

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GHGs and PSD

Large sources of GHGs are subject to PSD permitting requirements, but the emissions thresholds vary from the traditional 100/250 tpy, so determining if your facility is subject to PSD varies from the traditional methodology. PSD applies to new sources of GHG emissions as follows:

•For permits issued from January 2, 2011, to June 30, 2011, PSD applies to GHGs if all these conditions are satisfied:
—The source is otherwise subject to PSD for another regulated NSR pollutant.
—The source has the potential to emit GHGs equal to or greater than 75,000 tpy CO2e.

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•For permits issued on or after July 1, 2011, the PSD applies to GHGs if either of these conditions are satisfied:

—The source satisfies all the aforementioned criteria for permits issued from January 2, 2011, to June 30, 2011; or
—The source has the potential to emit GHGs equal to or greater than 100,000 tpy CO2e and equal to or greater than 100 or 250 tpy on a mass basis, as opposed to the CO2e basis, depending on the source category.

However, biogenic CO2 emissions for bioenergy and other biogenic sources (i.e., the combustion or decomposition of biodegradable organic material) need not be included in GHG emissions calculations until after July 21, 2014.

GHGs aren’t the only pollutants subject to the PSD. See tomorrow’s Advisor for a complete list.