AIR WAVES. Volume 20, 6, Number Hour Ozone Standard Exceedances

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1 AIR WAVES Volume 20, 6, Number 86 August June 21, Hour Ozone Standard Exceedances Update! As of June 28 th, which is the last update on the CTDEEP Air Quality website, Connecticut experienced twelve (12) more 8-hour ozone standard exceedances since our last edition, bringing the total for the 2016 ozone season to twenty-two (22). There remains only one 1-hour ozone standard exceedance to date that occurred on May 26 th. The latest exceedances included June 23 rd and 26 th, and July 6 th, 12 th, 15 th, 16 th, 17 th, 18 th, 21 st, 22 nd, 25 th, and 28 th (again, through July 28 th ):

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3 CTDEEP s Section 126 Petition Update! On June 1, 2016, CTDEEP Petitioned the EPA pursuant to section 126(b) of the Clean Air Act to abate emissions from the Brunner Island Steam Electric Station owned by Talen Energy and located in York County, Pennsylvania. The station is approximately 175 miles from the Connecticut border and the petition sites that the station significantly contributes to ozone levels that exceed the hour ozone standard at six out of twelve ozone monitoring locations in Connecticut and hence interfere with both attainment and maintenance of the ozone standard. The Brunner Island Station consists of three bituminous coal-fired electricity generating units with a combined capacity of over 1,500 MW. While construction is underway to add the capacity to burn natural gas, the station retains the capacity to burn coal without limitation. The station has no postcombustion controls in place to limit NOx emissions and emitted over 11,000 tons of NOx in CTDEEP included various demonstrations in its petition and concluded that EPA must: 1) Issue a Finding that Brunner Island Emissions are Significantly Contributing to Nonattainment of, and Interference with Maintenance of, the 2008 Ozone NAAQS in the State of Connecticut; and 2) Direct the Plant s Operators to Either Reduce Emissions of Cease Operations As Expeditiously As Practicable But In No Later Than Three Years. On July 25, 2016, EPA published notice in the Federal Register ( 25/pdf/ pdf) that the agency has determined that 60 days is insufficient time to complete the technical and other analyses and public notice-and-comment process required for its review of a petition submitted by the state of Connecticut pursuant to section 126 of the Clean Air Act (CAA). The petition requests that the EPA make a finding that the Brunner Island Steam Electric Station located in York County, Pennsylvania, emits air pollution that significantly contributes to nonattainment and interferes with maintenance of the 2008 ozone national ambient air quality standards (NAAQS) in Connecticut. The EPA is therefore extending the deadline for acting on the petition to no later than January 25, 2017.

4 RCSA sections 22a e/22a f No Change From Last Issue. On June 8, 2016, the CTDEEP Bureau of Air Management held the public hearing for its proposed changes to the NOx RACT regulations under Section 22a e and under Section 22a f that applies to high daily NOx emitting units at non-major sources of NOx. Comments submitted can be viewed at: Supreme Court Stays Clean Power Plan No Change From Last Issue. On February 9, 2016, the U.S. Supreme Court ordered that the Clean Power Plan be stayed until the case can be heard by the U.S. Court of Appeals. The following is the order: ORDER IN PENDING CASE 15A773 WEST VIRGINIA, ET AL. V EPA, ET AL. The application for a stay submitted to The Chief Justice and by him referred to the Court is granted. The Environmental Protection Agency s "Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units," 80 Fed. Reg. 64,662 (October 23, 2015), is stayed pending disposition of the applicants petitions for review in the United States Court of Appeals for the District of Columbia Circuit and disposition of the applicants petition for a writ of certiorari, if such writ is sought. If a writ of certiorari is sought and the Court denies the petition, this order shall terminate automatically. If the Court grants the petition for a writ of certiorari, this order shall terminate when the Court enters its judgment. MWCs Revisions to RCRA Section 22a Update! On January 21, 2016, the CTDEEP published notice that it is proposing an amendment to RCSA Section 22a to add three new requirements: A more stringent NOx emission limit for mass burn waterwall MWCs. The lower NOx limit is necessary to comply with an ozone nonattainment requirement of the EPA under which DEEP must certify that major sources of NOx emissions in the state, such as the MWCs, are held to

5 standards consistent with the use of reasonably available control technology (RACT). The emission reductions associated with the more stringent NOx emission limit are also important for planning to attain the 2015 ozone national ambient air quality standard. A new ammonia emission limit of 20 7% O 2 on units controlled by selective noncatalytic reduction (SNCR) systems. The new ammonia emission limit is necessary because of the potential increase in ammonia emissions that may result from the use of the SNCR system to meet the more stringent NOx emission limit. A requirement to demonstrate compliance with the new ammonia emission limit by either continuous emission monitoring (CEM) or annual stack testing. Interested persons were invited to comment on the proposal by Friday, February 26, A public hearing was also held on February 24, EPA currently regulates NOx emissions from MWCs in its New Source Performance Standards (NSPS), emission guidelines and Federal Plans. Connecticut s proposed NOx emission limits are more stringent than the corresponding Federal emission limitations for new sources in the NSPS (40 CFR 60, Subparts Ea, Cb and Eb) and for existing sources in the emissions guidelines and corresponding Federal Plan (40 CFR 62, Subpart FFF). While EPA does regulate NOx emissions from MWCs, there are no corresponding Federal emissions limitations for ammonia emissions from MWCs. Some of the Connecticut MWC units currently have ammonia emissions limitations that developed so that the owner could obtain a New Source Review permit to construct and operate the MWC. The addition of the ammonia emission limit to the regulation will mean that all Connecticut MWC units that have SNCR to control NOx will be subject to the same ammonia limit. On July 26, 2016, the Legislative Regulatory Review Committee approved the regulatory changes with technical corrections. LRRC Regulation Number: eregulation Tracking Number: PR RGGI, Inc. Announces Selection of New Executive Director New! The Regional Greenhouse Gas Initiative, Inc. (RGGI, Inc.) Board of Directors announced the selection of Andrew McKeon as the new Executive Director of RGGI, Inc. He began serving in the role of Executive Director on July 25, Mr. McKeon comes to RGGI, Inc. from an extensive career in finance and sustainability. He previously served as Director of Operations for the Environmental Registry at Markit, Inc., overseeing the platform for management of environmental credits for products such as carbon, water, bio-diversity, energy efficiency, and energy capacity throughout the credit lifecycle. He has also served as a sustainability consultant to major businesses and worked for leading financial firms.

6 Revised NSP Minor Modification Application New! The CTDEEP Bureau of Air Management revised the Minor Modification Application for an Existing New Source Review Permit on July 6, The new form and instructions can be found on its website at The following was developed for readers to enjoy during the dog days of Summer.

7 Air Waves Word Search! T T I T E L U R Y B T I M R E P R R S K C A T S I L R H A P L E A U E X R E P O R T A U T O D R D A O L I R E N G I N E S N O I I S I C A M P L A N S X M B M O N S L I P Y T I C A P O S A G D G N I T S E T C O Y O N S C O V O P E R A T E I A N R R A T E E R U C I L A G E L I T N L C R L D T L A D O M R E A M A E F E T E R A L O S W G A T U A U C I I R A C P I S O G D T L Q F M M T S T E S F F O I C A S S R A T A E S I M E R P A R T D E R I F S N O B R A C R E C E P T O R A H See if you can find the following: Actual Engine NOV SIL AERMOD Fired NOx SIPRAC Air Fog Offsets Slip Air Quality Alert Fuel Oil Solar Ash Gas Opacity SOx Attain HAP Operator Stacks Auto Ion Period Start Up BACT ITT Permit Testing Calc LAER Permit By Rule Title V CAM Plan Lead Premise Trading Orders Carbon Legal RATA Transport CFC Load Rate Trap Coal MATS Receptor Trial Dust Mod Report ULSD EMIT NAAQS RGGI VOC Bonus: Where did Apollo 11 land on July 24, 1969? VOCs

8 Use your head. Air Waves was never intended to be a legal document or a compliance document. It is purely informational, to provide those interested with a heads-up that events are happening on the state and federal fronts with regard to air quality and air emissions. Failure to construe Air Waves as anything else is the sole responsibility of the reader. If you have a legal problem, consult your lawyer. If you have a compliance issue, consult the specific regulations or the Agency involved. silvestri/personal/august 2016.pdf Remember those who serve, those who have served, and those who never made it home.