The permitting of greenhouse gasses (GHG) is new to industry, the States, and to the Environmental Protection Agency. The process is further complicated due to the Environmental Protection Agency (EPA) having permitting authority for GHGs in Texas. As a result, in addition to dealing with a new type of “pollutant”, the applicant must also step outside the familiar structure of the Texas Commission on Environmental Quality (TCEQ) permitting program, into an evolving permitting process at the EPA.
This paper presents key aspects to BASF’s experience obtaining the first GHG permit issued to a chemical company. Some of the key areas of concern when a company is faced with a GHG permitting requirement include application structure and content, best available control technology (BACT) selection, and interaction with other federal agencies such as the US Fish and Wildlife Service (USFWS) and the National Oceanic and Atmospheric Administration (NOAA).
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