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Environmental Quality Management: Addressing Start-up, Shut-down, Malfunction in SIP Call

This document outlines the Environmental Quality Management's response to the SIP call regarding start-up, shut-down, and malfunctions. It details proposed amendments and rules to ensure compliance with the Clean Air Act. Facilities will have to comply with work practice standards, emission limits, and reporting requirements for excess emissions during specified periods. Contact Michael Pjetraj for questions.

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Environmental Quality Management: Addressing Start-up, Shut-down, Malfunction in SIP Call

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  1. Environmental Management Commission May 12, 2016 15A NCAC 2D .0535Start-up, Shut-down, MalfunctionSSM SIP Call

  2. Start-up, Shut-down, Malfunction (SSM) SIP Call • On May 22, 2015, the U.S. Environmental Protection Agency (EPA) issued a final action to ensure states have plans in place that are fully consistent with the Clean Air Act and recent court decisions concerning start-up, shut-down and malfunction (SSM) emission limit exemptions. EPA’s final action responds to the Sierra Club Petition; clarifies the EPA’s SSM Policy to assure consistency with the Clean Air Act and recent court decisions; and finalizes findings that the SSM provisions in the SIPs of 36 states that do not meet the requirements of the Clean Air Act (CAA) and accordingly issues a “SIP call” for each of those states. Department of Environmental Quality

  3. Start-up, Shut-down, Malfunction (SSM) SIP Call • In issuing the SIP call action, the EPA directs the affected states to correct specific SSM provisions in their SIPs. The Clean Air Act allows a maximum of 18 months from the issuance of the final action to submit a SIP revision. The SIP submission deadline for each of the 36 states subject to the SIP call action is November 22, 2016. Department of Environmental Quality

  4. Start-up, Shut-down, Malfunction (SSM) SIP Call • As described in the February 2013 proposal, the Petitioner objected to two generally applicable provisions in the North Carolina SIP that provide exemptions for emissions exceeding otherwise applicable SIP emission limitations at the discretion of the state agency during malfunctions (15A NCAC 02D .0535(c)) and during start-up and shut-down (15A NCAC 02D .0535(g)). Department of Environmental Quality

  5. Start-up, Shut-down, Malfunction (SSM) SIP Call • The EPA proposed to, and subsequently did, grant the Petition with respect to 15A NCAC 02D .0535(c) and (g), finding that 15A NCAC 02D .0535(c) and 15A NCAC 02D .0535(g) are substantially inadequate to meet CAA requirements. Consistent with its February 2013 proposal, EPA also proceeded to issue a SIP call with respect to these provisions. Department of Environmental Quality

  6. Start-up, Shut-down, Malfunction (SSM) SIP Call • NC DAQ proposes to edit the existing 15A NCAC 2D .0535 to add an “If then” applicability statement: Department of Environmental Quality

  7. Start-up, Shut-down, Malfunction (SSM) SIP Call • New 15A NCAC 02D .0535 applicability: • 15A NCAC 02D .0535 is not in effect if 15A NCAC 02D .0545 is valid. • In the event that US EPA’s SSM SIP call is declared invalid, unconstitutional, stayed, withdrawn, repealed, revoked or otherwise rendered of no force and effect, rule 15A NCAC 02D .0545 of this Subchapter shall be invalid, void, stayed, or otherwise without force. Department of Environmental Quality

  8. Start-up, Shut-down, Malfunction (SSM) SIP Call • The DAQ proposes to add a new rule: • 15A NCAC 02D .0545 TREATMENT OF MALFUNCTION EVENTS AND WORK PRACTICES FOR START-UP AND SHUT-DOWN OPERATIONS Department of Environmental Quality

  9. Start-up, Shut-down, Malfunction (SSM) SIP Call • 15A NCAC 02D .0545 will have a similar “if-then” statement so that .0545 will not be in effect if the SIP call is invalidated. • 2D .0545 will address Start-up, Shut-down and malfunction events and define how a facility can comply during those time periods. Department of Environmental Quality

  10. Start-up, Shut-down, Malfunction (SSM) SIP Call • For Start-up and Shut-down periods, facilities can comply with: • Existing numeric emission limits • Generally available work practice standards • Federal work practice standards applicable to similar equipment • Source specific start-up and shut-down work practice standard permit limit Department of Environmental Quality

  11. Start-up, Shut-down, Malfunction (SSM) SIP Call • For Malfunction periods, facilities can comply with: • Existing numeric emission limits • Source specific malfunction work practice standard permit limit Department of Environmental Quality

  12. Start-up, Shut-down, Malfunction (SSM) SIP Call • Since the facility will have the ability to comply with work practice standards, the facility will be subject to a standard at all times. • Reporting will continue to be required for excess emissions associated with malfunctions. Department of Environmental Quality

  13. Start-up, Shut-down, Malfunction (SSM) SIP Call • These amendments are being proposed by staff in response to the SIP call. • Statutory Authority • G.S. 143-215.3(a)(1);143-215.107(a)(4); 143-215.107(a)(5). Department of Environmental Quality

  14. Start-up, Shut-down, Malfunction (SSM) SIP Call Questions? • Michael Pjetraj • 919-707-8497 • michael.pjetraj@ncdenr.gov Department of Environmental Quality

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