Methane Emissions and Colorado Coal Mines

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1 Colorado PUC E-Filings System Methane Emissions and Colorado Coal Mines Will Allison, Director Air Pollution Control Division 7/6/2012 Colorado PUC, CIM, 7/9/2013 1

2 GHG GWP and CO2e Global Warming Potential (GWP) relative ability of Greenhouse Gas (GHG) to trap heat in the atmosphere Carbon Dioxide Equivalent (CO2e) Used to evaluate the global warming effects of different greenhouse gases Calculated by multiplying GHG emissions by the respective GWP, and summing the CO2e from all GHG at a facility or source Source: 7/8/2013 2

3 GHG GWP Global Warming Potential (GWP) GHG GWP Carbon Dioxide 1 Methane 21 Nitrous Oxide 310 HFCs 12-17,200 PFCs ,340 Sulfur Hexafluoride 23, C.F.R. Part 98, Subpart A, Table A-1: Global Warming Potentials (74 FR ) 7/8/2013 3

4 Methane as Regulated Pollutant Evolution of GHG as a Regulated Pollutant Mass v. EPA (2007) GHG included in CAA 302(g) definition of air pollutant, and Court mandated EPA determine if GHG from new motor vehicles endanger public health or welfare EPA s Endangerment Finding and Cause and Contribute Finding (December 2009) EPA concluded GHG endanger public health and welfare EPA reconsideration (March 2010) EPA determines that a previously unregulated pollutant becomes subject to regulation once it is subject to actual control of emissions Light-Duty Vehicle Rule (May 2010) Applies new CAFE standards to 2012 cars for GHG (CO 2 ) 7/8/2013 4

5 Methane as Regulated Pollutant Evolution of GHG as a Regulated Pollutant GHG is subject to regulation as of January 2, 2011, by EPA regulatory actions on automobiles GHG subject to regulation under other federal Clean Air Act programs : Prevention of Significant Deterioration (PSD) program Title V Operating Permit program EPA issued the Tailoring Rule June 2010 to tailor the permitting thresholds, and phase in the permitting requirements for GHGs in a common sense manner EPA s Mandatory Reporting of GHG Rule Sources submit GHG data to EPA as of /8/2013 5

6 Methane as Regulated Pollutant EPA recently denied petition to directly regulate methane emissions from coal mines (April 2013) Petitioners sought NSPSm under CAA section 111 EPA cited sequestration, budget and other priorities in denying petition at this time President s recent Climate Action Plan (June 2013) mentions reducing methane emissions from coal mines and other sources 7/8/2013 6

7 Methane Regulation in Colorado Colorado adopted revisions to AQCC Regulation No. 3 in October 2010 Mirrors EPA s GHG Tailoring Rule GHG can be subject to regulation as of January 2, Colorado regulates GHGs via: Title V Operating Permit required if emissions exceed 100,000 tons/yr. (tpy) CO2e Prevention of Significant Deterioration (PSD) permit required for new major stationary sources and major modifications of GHG. May be triggered at 100,000 tpy or 75,000 tpy CO2e Synthetic Minor permits can be issued to avoid these permit requirements by taking permit limits below these thresholds CDPHE-APCD has not been regulating GHGs, including Methane (CH4), for very long The APCD does not require that GHG emissions data be submitted unless Title V or PSD permitting is triggered 7/8/2013 7

8 Title V Operating Permits Title V Applications Due July 1, 2012 for existing GHG-only sources 3 Colorado coal mines have applied for Title V permits: West Elk Bowie #2 Elk Creek No GHG emission limits generally required as part of the Title V permit at this point 7/8/2013 8

9 PSD Permits No PSD permit applications for GHG emissions from coal mines have been received so far PSD permit would include a requirement to apply Best Available Control Technology (BACT). BACT is determined on a case-by-case basis. 7/8/2013 9

10 Estimated Methane Data Data estimated for Colorado GHG Inventory Update from EPA s State Inventory Tool (2010 data): Active Coal Mining Abandoned Coal Mines Metric tons CO2e Metric tons CH4 Million cubic feet CH4 6,634, ,909 16, ,868 42,946 2,229.8 Total: 7,535, ,855 18, /8/

11 Estimated Methane Data From EPA s Identifying Opportunities for Methane Recovery at U.S. Coal Mines: Selected Gassy Underground Coal Mines (EPA-430-K January 2009): Colorado has a number of underground mines with relatively low methane emissions, but there are also several deep and gassy mines with high emissions; these mines present potential opportunities for those interested in developing a methane recovery project in the West Mine Estimated CH4 Liberated (million cubic feet per day) Million cubic feet CH4 per year West Elk ,643 Bowie No Elk Creek 7.4 2,701 McClane Canyon /8/

12 Reported Methane Data Data on specific Colorado mines from EPA s GHG Reporting Program (2011 data set) as reported by the source: Facility Name Methane Emissions (metric tons CO2e) BOWIE No. 2 Mine 191, Blue Mountain Energy McClane Canyon Mining LLC 12, , Oxbow Mining, LLC 1,153, Twentymile Mine 23, Million cubic feet CH4 7/8/

13 Permit Requirements Combustion of CH4 from coal mines would likely require permitting Possible Permitting Challenges: Demonstrating compliance with National Ambient Air Quality Standards (NAAQS) for combustion products (e.g. Oxides of Nitrogen) PSD permitting for large emission sources 12 month permit issuance timeframe 7/8/

14 Questions? 7/8/

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