Description: Challenge to EPA’s failure to adequately consider carbon capture and sequestration in PSD permitting decision.
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In re ExxonMobil Chemical Company Baytown Olefins Plant
Case Documents:
Filing Date Type File Action Taken Summary 05/14/2014 Order Denying Petition for Review Download Order issued denying review. EAB rejected Sierra Club’s challenge. EAB upheld Region 6’s best available control technology (BACT) analysis. EAB concluded that Region 6 had appropriately determined that the total cost of the CCS technology, which would have increased the project’s capital costs by 25%, made CCS economically unachievable, and that implementing CCS would have secondary environmental impacts such as increased emissions of nitrogen oxides and volatile organic compounds. EAB also said that the absence of comparable facilities justified the Region’s reliance on total cost information instead of on data showing the project’s cost-effectiveness per ton of carbon dioxide avoided. EAB also rejected Sierra Club’s arguments that Region 6 had not followed the methodology required in EPA’s Cost Control Manual and that Region 6 should have considered emissions streams from the project’s steam cracking furnaces (which produce a cleaner stream that would be less costly to capture) separately from emissions from the CCS system’s utility plant. 12/26/2013 Petition for Review Download Petition for review filed. The Sierra Club petitioned the Environmental Appeals Board (EAB) for review of the conditions in the prevention of significant deterioration (PSD) permit issued by EPA Region 6 for the addition of an ethylene production unit at an existing major source at the Baytown Olefins Plant in Harris County, Texas. Sierra Club said that facilities in Texas such as the Baytown Olefins Plant have a “unique opportunity” to consider deployment of carbon capture and sequestration (CCS) and development of carbon storage resources to reduce greenhouse gas emissions. (The petition notes a U.S. Geological Survey study that concluded that the Gulf Coast has 65% of the country’s estimated accessible carbon storage resources.) Sierra Club said that the Baytown facility’s PSD permit “exemplified the Region’s inadequate implementation of the PSD permitting program in general for [greenhouse gases]” and asked the EAB to remand the permit to Region 6 and require a “full and appropriate analysis” of CCS in the best available control technology analysis.