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RACT Element. March 20, 2006 St. Louis Ozone & PM2.5 Joint Workgroup Meeting John Rustige, P.E. Air Pollution Control Program. Ozone Implementation Schedule. Phase II Requirements. RACT determinations for individual sources must be made. RACT element due September 15, 2006
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RACT Element March 20, 2006 St. Louis Ozone & PM2.5 Joint Workgroup Meeting John Rustige, P.E. Air Pollution Control Program
Phase II Requirements • RACT determinations for individual sources must be made. • RACT element due September 15, 2006 • RACT must be implemented by May 1, 2009 • States can rely on existing RACT guidance, but preamble notes EPA intends to develop additional guidance which states must consider if developed.
Phase II Requirements • Sources subject to NOx SIP call & CAIR will be presumed to meet RACT, so no analysis is required for these sources • State also required to provide implementation of Reasonably Available Control Measures • Rule expects consultation between states and power sector - (CAIR) workgroup
RACT Actions • Staff plans to conduct Review of Existing RACT Rules • Generic VOC & NOx RACT currently exist in Missouri • Consultation with EPA
RFP Element March 20, 2006 St. Louis Ozone & PM2.5 Joint Workgroup Meeting John Rustige, P.E. Air Pollution Control Program
Final demonstration • We will need to confirm our calculations with EPA • (2002-2008) RFP + I/M backslide • Anti-backsliding should be based on comparisons in 2008 ? (through 2014 - end of maintenance period?), not old 1-hour dates??
RACT & RFP Questions March 20, 2006 St. Louis Ozone & PM2.5 Joint Workgroup Meeting John Rustige, P.E. Air Pollution Control Program