Friday, June 10, 2016

State SIP for startup and shutdown emissions

The Louisiana DEQ is seeking public comment on its proposed State Implementation Plans (SIP) addressing startup and shutdown emissions.  Written comments should be delivered to the Regulation Development Section in such a way that  they arrive and are date-stamped or e-mailed no later than 4:30 p.m. on the final day of the comment period, August 3 2016.   The June 20 2016 public notice will include the address or e-mail to use.

State SIP for Sulfur Dioxide emissions for sulfuric acid plants

for VOC emission for nitric acid plants

for NOx emissions for non-attainment area of Baton Rouge

Often times the obnoxious odors and disturbing noise is attributed to shutdown and startup procedures.  This rule will repeal the exemption set forth in LAC 33:III.2201.C.8 and replace it with provisions allowing the owner/operator of an affected point source to comply either with the emission factors imposed by LAC 33:III.2201.D at all times (including periods of startup and shutdown) or with newly-established work practice standards designed to minimize emissions during periods of startup and shutdown.

These improvements should improve air quality especially in fence line communities and in areas designated as non-attainment.  The EPA's actions are largely a result of work by the Sierra Club and by public comments  from across the nation, as documented in EPA's docket folder EPA-HQ-OAR-2012-0322

The proposed work practice standards are:

Proposed/June 20, 2016

a.The owner or operator shall operate and maintain each affected point source, including any associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions.

b.Effective November 22, 2016, coal-fired and fuel oil-fired electric power generating system boilers and fuel oil-fired stationary gas turbines shall use natural gas during start-up. Start-up ends when any of the steam from the boiler or steam turbine is used to generate electricity for sale over the grid, or for any other purpose (including on-site use). If another fuel must be used to support the shutdown process, natural gas shall be utilized.

c.Engage control devices such as selective catalytic reduction (SCR) or selective non-catalytic reduction (SNCR) as expeditiously as possible, considering safety and manufacturer recommendations.

d.Minimize the start-up time of stationary internal combustion engines to a period needed for the appropriate and safe loading of the engine, not to exceed 30 minutes.

e.Maintain records of the calendar date, time, and duration of each start-up and shutdown.

f.Maintain records of the type(s) and amount(s) of fuels used during each start-up and shutdown.

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