Universal Continuing Decision Process For: Trinity Consultants *
| Joe Sullivan, Managing Consultant Trinity Consultants, reviewed EPA’s proposed Tailoring Rule for regulated greenhouse gas emissions and identified the potential impacts of GHG regulation under the PSD and Title V permitting programs. In particular, he discussed a letter issued by the EPA Administration this week which suggests that GHG permitting for stationary sources will be phased-in over a longer period of time than originally proposed and with much higher thresholds. Joe also discussed BACT analyses in the context of CO2 emissions and indicated that a traditional “top-down” BACT analysis was recently conducted for a facility in California. For our participants’ reference, that facility was Calpine’s Russell City Energy Center in Hayward, California. For a copy of the permit, see: |
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