EPA proposes changes to New Source Performance Standards (NSPS) for stationary combustion turbines

Posted on October 10, 2012

The Proposed Rule Is Not Consistent With Historical Determinations And Could Set A Precedence Causing Uncertainty

The proposed regulation says that EPA intended that sources applicable to NSPS subpart GG (i.e. old NSPS emission limits and requirements) that replace or overhaul their engine is a NEW SOURCE and subject to NSPS subpart KKKK emission limitations and requirements which are more stringent.  EPA does this by maintaining the definition of stationary combustion turbine to determine applicability to NSPS subpart KKKK while restricting what components of the combustion turbine (i.e. limiting to the engine only) are considered when determining whether an affected facility is new or reconstructed.
This line of thinking (i.e. narrowing) by EPA is a significant concern because it is not consistent with historical NSPS applicability determinations.  In addition, if finalized it could set precedence that this narrowing approach is acceptable thereby the applicability to NEW SOURCE requirements for other sources (e.g. boilers) that make repairs or replacements is uncertain because EPA’s says their “intent was not clear”.   Further, this uncertainty can be extended to the Prevention of Significant Deterioration (PSD) with regard to the exclusion of changes that are routine maintenance, repair and replacement (RMRR).  Specifically, the RMRR exclusion is evaluated on a case-by-case basis where one significant consideration is the RMRR cost compared to the replacement cost of the affected facility, not the individual component which changes the result of the comparison. 
The Proposed Rule As Written Is Retroactive
The proposed regulation is a stationary combustion turbine that commenced construction, modification, or reconstruction after February 18, 2005 is applicable to NSPS subpart KKKK and the EPA’s intent is that affected facilities applicable to NSPS subpart GG that replace an engine become applicable to NSPS subpart KKKK.  Therefore, an affected facility that replaced an engine after February 18, 2005 will be applicable to all NSPS subpart KKKK requirements on the effective date of the regulation.  Affected facilities will not have sufficient time to meet the requirements and will be subject to enforcement action for non-compliance.
The Proposed Regulation Has An Input Limit (lb/mmBTU) And A Concentration Limit (ppm) As An Alternate – The Monitoring Requirements Change Depending On The Option You Select
EPA is increasing the compliance flexibility for the emission limits by adding an input based limit in lb/mmBTU.  If you select that option then you are required to install a stack gas flow meter.  If you select the concentration limit then you do not need a stack gas flow meter and would use an f-Factor along with the % O2 to determine the stack gas flow rate.  The big watch out is that some permits may already have both limits in mass and concentration because of meeting other requirements.  You need to make sure your permit specifies which limit is for NSPS KKKK for clarity.
The Proposed Regulation Applies At All Times
The proposed regulation requires the emission limits to apply at all times even during startup and shutdown.  This is not consistent with other NSPS emission limits that do not apply during startup and shutdown.  EPA’s rationale is that the minimum averaging period for compliance is 4 hours and the data they reviewed showed that a source could achieve compliance.  Most new engines can meet the proposed requirements within the 4 hour averaging time, however you need to check and make sure.
The Proposed Regulation Requires Electronic Reporting Of Your Performance Test – This Is An Extra Step That Will Require More Resources
The proposed regulation requires electronic reporting of performance test results via EPA’s electronic reporting tool (ERT).  Our inquiry with stack testers has concluded that most customers contract this out to them because the facility is unfamiliar with the tool and the infrequent use of the tool does not present a business case to train their employees.  The average time by an experienced user is 4-5 hours per stack testing event.
For more information on how Environmental360 can assist your facility with NSPS GG and KKKK, please contact Dell Majure at Dell.Majure@environmental360.com.
Source: E360 Old Site

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