7-38 HRAP dated June 26, 2015
Section 2.0 of HRA narrative states that facility will be major source for CO2, which was not mentioned in Protocol. Please clarify how or why this change from HRAP occurred.
RESPONSE 7-38
| The definition of “Major Stationary Source” in RIDEM Air Pollution Control Regulation No. 9 (Section 9.5.1(f)) does not include a major source threshold for CO2 emissions. Section 9.1.41(e) states that beginning July 1, 2011, the pollutant greenhouse gas emissions (“GHG”) will be subject to regulation at a new stationary source that will emit or have the potential to emit 100,000 tpy CO2e. The CREC will be a major stationary source with the potential to emit 100,000 tpy CO2e, and thus its GHG emissions are subject to the applicable RIDEM major source permitting requirements contained in Sections 9.4 and 9.5 of Air Pollution Control Regulation No. 9.
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RESPONDENT:
| Michael Feinblatt, ESS Group, Inc.
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DATE: | May 17, 2016
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