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Two alternatives withdrawn (ALT-061 & 081)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