CT Section 22 Updates
Two subcommittee meetings were held in February and March to discuss the proposed revisions to RCSA 22a-174-22. The topics discussed included Emissions Testing and Compliance. Comment period on the Emissions Testing section is now closed, but comments are open on the Compliance section until April 20th. Below is a summary of the proposed new rule.
Emissions Testing
Facilities can show compliance with emissions limitations in three ways:
- Periodic emissions testing according to this subsection
- Periodic emissions testing under New Source Performance Standards in 40 CFR 60
- Installation/operation of a CEMS monitor for NOx
If the facility is subject to this subsection (option 1 of above), an initial emissions test must be conducted within five calendar years of the effective date of this subsection.
The emissions test will consist of one of the following:
- Three one-hour tests, each performed over consecutive 60-minute periods
- Four 15-minute tests, each performed over consecutive 15-minute periods (This is only if the commissioner approves that three one-hour tests are not reasonable.)
Sampling for the emissions test will be conducted when the unit is operating at 90% capacity, except as follows:
- The unit is subject to testing at a load other than 90% by permit or order.
- The commissioner approves testing at an alternative maximum capacity because
- Operating at 90% is not technically feasible or
- Alternative maximum capacity is more representative of operations encountered by the unit.
- A unit that has operated above 100% of its maximum capacity at any time since December 31, 2016, will be tested at 90% of that new capacity.
Emissions data used to determine compliance will not contain the following:
- Startup/shutdown data
- Data during monitoring system malfunctions
- Out-of-control data
- Data during required quality assurance or quality control activities
- Data when the system is in maintenance
- Data when the unit is not operating
Compliance and Emissions Limitations
The emissions limitations are as follows:
Boiler serving EGU's Phase I
| Natural gas-fired (lb/MMBtu) | Residential oil-fired (lb/MMBtu) | Distillate oil-fired (lb/MMBtu) | Coal-fired (lb/MMBtu) | |
|---|---|---|---|---|
| Non-affected Cyclone Furnace (24 hour average) | 0.43 | 0.43 | 0.43 | 0.43 |
| Non-affected Other boiler (24 hour average) | 0.20 | 0.25 | 0.20 | 0.38 |
| Affected Units Ozone season (5 month average) | 0.10 | 0.20 | 0.10 | 0.15 |
| Affected Units non-ozone season (7 month average) | 0.15 | 0.15 | 0.15 | 0.15 |
ICI Boilers Phase I
| Natural gas-fired (lb/MMBtu) | Residential oil-fired (lb/MMBtu) | Distillate oil-fired (lb/MMBtu) | |
|---|---|---|---|
| Non-affected boilers > 25 MMBtu (24 hour average) | 0.20 | 0.25 | 0.20 |
| Affected Units Ozone season (5 month average) | 0.10 | 0.20 | 0.15 |
| Affected Units non-ozone season (7 month average) | 0.15 | 0.15 | 0.15 |
Simple-cycle Turbines Phase I
| Natural gas-fired | Distillate oil-fired | |
|---|---|---|
| Non-affected turbines < 100 MMBtu (24 hour average) | 0.90 lb/MMBtu | 0.90 lb/MMBtu |
| Non-affected turbines > 100 MMBtu (24 hour average) | 55 ppmvd | 75 ppmvd |
| Affected Units Ozone season (5 month average) | 50 ppmvd | 50 ppmvd |
| Affected Units non-ozone season (7 month average) | 0.15 lb/MMBtu | 0.15 lb/MMBtu |
Combined-cycle Turbines Phase I
| Natural gas-fired | Distallate oil-fired | |
|---|---|---|
| Non-affected turbines (24 hour average) | 55 ppmvd | 75 ppmvd |
| Affected Units Ozone season (5 month average) | 50 ppmvd | 50 ppmvd |
| Affected Units non-ozone season (7 month average) | 0.15 lb/MMBtu | 0.15 lb/MMBtu |
Reciprocating Engines Phase I
| Natural-gas fired (g/bk hp-hr) | Distillate oil-fired (g/bk hp-hr) | landfill gas or digester gas, alone or fired with natural gas (g/bk hp-hr) |
|---|---|---|
| 2.5 | 8.0 | no limit |
Boilers serving EGU's Phase II
| Natural gas-fired (lb/MMBtu) | Residential oil-fired (lb/MMBtu) | Distillate oil-fired (lb/MMBtu) | Coal-fired (lb/MMBtu) | |
|---|---|---|---|---|
| Non-affected boiler (24 hour average) | 0.10 | 0.20 | 0.10 | 0.15 |
| Affected Units non-ozone season (7 month average) | 0.15 | 0.15 | 0.15 | 0.15 |
ICI Boilers Phase II
| Natural gas-fired (lb/MMBtu) | Residential oil-fired (lb/MMBtu) | Distillate oil-fired (lb/MMBtu) | |
|---|---|---|---|
| Non-affected boilers 25-100 MMBtu (24 hour average) | 0.05 | 0.20 | 0.10 |
| Non-affected boilers > 100 MMBtu (24 hour average) | 0.10 | 0.20 | 0.15 |
| Affected Units non-ozone season (7 month average) | 0.15 | 0.15 | 0.15 |
Simple-cycle Turbines Phase II
| Natural gas-fired | Distillate oil-fired | |
|---|---|---|
| Non-affected turbines (24 hour average) | 40 ppmvd | 50 ppmvd |
| Affected Units non-ozone season (7 month average) | 0.15 lb/MMBtu | 0.15 lb/MMBtu |
Combined-cycle Turbines Phase II
| Natural gas-fired | Distillate oil-fired | |
|---|---|---|
| Non-affected turbines (24 hour average) | 25 ppmvd | 42 ppmvd |
| Affected Units non-ozone season (7 month average) | 0.15 lb/MMBtu | 0.15 lb/MMBtu |
Reciprocating Engines Phase II
| Natural-gas fired (g/bk hp-hr) | Distillate oil-fired (g/bk hp-hr) | landfill gas or digester gas, alone or fired with natural gas (g/bk hp-hr) | |
|---|---|---|---|
| Rich burn reciproacting engine | 1.5 | 1.5 | 2.0 |
| Lean burn reciprocating engine | 1.5 | 2.3 | 2.0 |
Phase I: 6/1/2018–5/31/2022
Phase II: 6/1/2022Phase I: 6/1/2018–5/31/2022
The owner/operator of the emission unit shall comply with the above emissions limitations or shall take one of the following actions:
- Implement an alternative compliance mechanism as provided below.
- Reduce emission rate by at least 40% from a 2010 baseline rate (or other representative baseline year).
- To comply with Phase 1, use banked DERCs.
- For EGUs and simple-cycle turbines to comply with Phase 1 non-ozone limits, install/operate a control device.
- As an alternative to Phase 1/2 24-hour limit and seasonal limit, accept an enforceable cap on mass emissions or hours of operation.
- Commit to combust only natural gas if unit can combust either natural gas or fuel oil. (A suggestion was also made during the meeting to include the option for the unit to comply with the Federal boiler MACT.)
- Average emissions with emissions from over-complying units at the same facility or under the same ownership in the same non-attainment area.
- Commit to modifying or replacing unit on a schedule so that Phase I limits will be met by June 1, 2019, or Phase 2 limits will be met by June 1, 2023.
- Commit to retire another unit at the facility that will result in a reduction of mass emissions equal to or greater than the emission reduction that would be achieved by the unit complying with the applicable emissions limitation.
- Limit operations to only OP4, Action 6 events.
- Implement any combination of the above options that would result in the reduction in the rate of emissions of the participating units equal to or greater than the emission rate that would be achieved by compliance with a single option.
- Operate under a case-by-case RACT determination.
- This will be determined based on the economic and technical feasibility of achieving the emission limitations of this section. Any case-by-case RACT will establish the lowest emission limit reasonable for the unit.
- The emission limitation established under this subsection would expire May 31, 2030.
- Cease operations. Any owner/operator who is unable to comply with the applicable emissions limitations at the beginning of Phase 1 or 2 shall cease operations on the first day of Phase 1 or 2; OR at the commissioner’s discretion, enter into an agreement to cease operations no later than June 1, 2019, (Phase 1) or June 1, 2023, (Phase 2).
Requests for any of these other compliance options (#1–3 subsections above) must be submitted to the commissioner no later than September 1, 2017, for Phase I and September 1, 2021, for Phase 2.