edge it. In December 2009, with a new, amenable president in office, EPA was able to issue its final finding that greenhouse gases do endanger public health and the environment and obtain its foundation for regulating the emissions. “Even though the Supreme Court
case had a focus on mobile sources, the endangerment finding opened the door to stationary sources,” said Jeff Hannapel, vice president of regulatory affairs for The Policy Group, McLean, Va.
Greenhouse Gas Reporting Rule
Before setting standards for green- house gas emissions, data on actual emissions from stationary sources needed to be gathered. An appropria- tions bill for fiscal year 2008 directed EPA to establish a rule requiring facilities to report their greenhouse gas emissions, which set in motion the one set of regulations that has the most direct impact on metalcasters— the Greenhouse Gas Reporting Rule. Starting Jan. 1, 2010, facilities with 25,000 metric tons of carbon dioxide equivalent from combustion units had
to monitor and report their emissions. Te deadline for reporting for 2010 was originally set for April 1, but it has been extended until September as EPA resolves some issues on its electronic reporting system. Te Greenhouse Gas Reporting Rule sets no standards for emissions; rather, it gives EPA an idea of current emission levels. “Right now, it’s more of a data
gathering source,” Hannapel said. EPA continues to make changes
to the reporting rule. In July 2010, the agency announced emissions from onsite industrial landfills with non- inert materials would also need to be part of the emissions calculations. “Emissions from these landfills
shouldn’t be that great (for metalcast- ing facilities),” Hannapel said. “Te significance is not so much in the details but in that we have a reporting rule and we have some add-ons. EPA is continuing to regulate.”
Tailoring Rule In March 2010, EPA promulgated
a light vehicle duty rule that mandated an increase in fuel economy and set a federal limit on greenhouse gas emis-
sions from tailpipes. It was the first time a federal limit for greenhouse gases had been established. “It set in motion other Clean Air
Act requirements,” Hannapel said. “It became the trigger for regulating all facilities, which brings us to the Tailoring Rule.” Te Clean Air Act stipulates
thresholds for emitting a pollutant. According to Hannapel, if a company makes a modification to its facility that increases polluting emissions by 250 tons, or 100 tons for most ferrous metalcasting facilities, the company is required to obtain a “prevention of significant deterioration (PSD)” per- mit. If facility emissions are 100 tons, the company needs a Title V operating permit. However, greenhouse gases have so many sources, EPA deter- mined the thresholds would have to be tailored to limit which facilities would be required to obtain those permits. Eventually, the agency settled on 75,000 tons of carbon dioxide equivalent, which would affect facili- ties responsible for 67% of the national greenhouse gas emissions from a stationary source.
24 | MODERN CASTING June 2011 EPA’s budget grew by nearly $3 billion from 2009 to 2010, reflecting the agency’s 29 major regulations and 172 new rules in the past two years. .
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