View
220
Download
0
Category
Preview:
Citation preview
Compliance UpdateNCMA 2015
What’s New/Changing
Testing
Engines
Boiler MACT/GACT
CEDRI/CDX
Electronic Reporting/Submittal
DAQ’s Role in Federal Performance/Emission Standard Regulations
We are the delegated authority and the “Administrator” for the purpose of these rules
We issue permits when required
We review test protocols/test plans
We observe tests and review test results
We determine compliance and provide compliance assistance to the rules.
DAQ’s Role (cont’d)
We can make minor or moderate changes to the regulations to deal with site-specific factors. There are some things we cannot change, like numerical emission limits.
Developed an implementation plan for rules that affect a large number of sources (e.g., 112j for industrial boilers, 6J GACT boilers, and 4Z engines)
Developed permit conditions for non-Title V for attachment to permits that generally outlined requirements in the regulations
Provided guidance and outreach for compliance (and extensions)
Testing
Proposed rules published March 20, 2015 for NSPS performance tests and RATAs via CEDRI/CDX.
Use of electronic reporting tool (ERT)
Comments due by May 19, 2015. About 1 year to finalize after that.
FR Notice on 2/23/2015 on Broadly Applicable Alternative Methods.
Four alternative added (ALT 105, 106, 107, and 108)
Two alternatives withdrawn (ALT-061 & 081)
FAQs: Testing
Differences between state rules, NSPS, and NESHAPs
State rules (15A NCAC .2600) Requires protocol (at least 45 days if you want it
reviewed and approved by DAQ). Protocol templates are available on DAQ’s website.
15-day notification of DAQ for opportunity to conduct test
Technically, these rules don’t apply to any NSPS or NESHAPs, and MACT/GACT (e.g., engines under 4I, 4J, or 4Z)
FAQs: Testing (cont’d)
NSPS Notification of testing 30 days prior to testing
Testing to be conducted within 60 days of full production or 180 days of startup, whichever comes first.
Test report required within 30 days of completing test.
May require periodic retesting
Certified engines MAY avoid testing
FAQs: Testing (cont’d)
NESHAPS (MACT/GACT) Testing within 180 days of the compliance date
Site-specific monitoring plan (protocol) at least 60 days of test AND notification of intent to test
Site-specific performance evaluation test plan for continuous monitoring systems. Intended for data quality assurance(60 days before testing)
Test reports submitted within 60 days of completing test
Periodic testing
Testing
Testing
Testing and Observation
Testing and Observation
The engine divide
New / Existing engines
Compression ignited / spark ignited
Certified engines / non-certified engines
Emergency / non-emergency engines
Note: the 50-hour non-emergency power generation allowance for emergency engines expired in May 2014
Emergency Engines
Work practice standards Oil changes
Air filter changes
Belt maintenance
Other items as recommended by engine manufacturer to maintain engine emission performance
You can be an “emergency engine” and still be in a contract to provide local grid stabilization under grid emergency conditions to the local grid. NO PEAK SHAVING
Non-emergency, non-black start engines
Peak shaving
Largest group that DAQ deals with directly
May need a permit but there are a number of permit exemptions
Many needed retrofit of catalyst to control carbon monoxide (CO) if you change status
Many need testing per regulation (next round of testing at 3 years or 8760 hours, whichever comes first)
Recordkeeping and reporting requirements
Monitoring & Reporting Requirements
Hours of operation
Continuous temperature monitoring of catalyst inlet during operation
Periodic (once per month) pressure drop monitoring when operating
Semi-annual reporting of problems or that no issues were noted (annual for landfill or digester gas)
Records kept available for inspection
Emergency RICE obligated for 15 hours or more must submit annual reports beginning 3/31/2016
Future Changes?
Probably!
Addressing issues for engines that are classified as non-emergency in emergency conditions
Clarification of testing conditions
Electronic reporting
Boiler MACT – 112(j) and 5D
112(j) permit requirements for testing: performance testing and/or fuels testing (metals)
Do what your (Title V) permit says!
Permits transitioning away from 112(j) requirements to 40 CFR 63, Subpart DDDDD (5D)
If under 5D, be aware of routine tune-up schedules depending upon fuels, oxygen trim, and size ( 2 or 5 years)
Boiler GACT (Subpart 6J)
Tune-ups completed by 2014.
Some earlier tune-ups will be approaching their 2-year tune up schedule this year.
Submittals via CEDRI/CDX
CEDRI/CDX
Increasing role for reporting compliance status and routine reports (i.e., NSPS proposed rulemaking and certain promulgated NESHAPs)
Increasing role for submittal of testing results via ERT (temporary exception is the Utility MATS rule)
Under proposed rule, sources cannot be exempted from electronic reporting requirements
DAQ is currently looking into process and procedures for handling this dataflow, particularly ERT. Certain documents DAQ is not prepared to handle (yet).
Electronic submittals of some documents like protocols is possible.
Questions?GARY L. SAUNDERS
1641 MAIL SERVICE CENTER
RALEIGH, NC 27699-1641
GARY.SAUNDERS@NCDENR.GOV
(919) 707-8413
Recommended