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On November 27, 2018, the District of Columbia Department of Energy and Environment (DOEE) finalized amendments to regulations related to Reasonably Available Control Technology (RACT) requirements codified in Title 20, Subtitle A, Chapter 8 of the District of Columbia Municipal Regulations (20 DCMR Chapter 8). Following the update of the National Ambient Air Quality Standards (NAAQS) for ozone in 2008, areas designated nonattainment with regard to the revised ozone NAAQS and states located in the Ozone Transport Region (OTR) were required to revise their state implementation Plans (SIP) accordingly. Since the District is located in the OTR, DOEE needed to analyze and update their RACT regulations for ozone precursors [volatile organic compounds (VOC) and nitrogen oxides (NOx)]. Below is the summary of the revised regulations addressing this requirement.

RACT Requirements for Combustion Turbines

Prior to the rule revisions, 20 DCMR Chapter 805 contained NOx RACT requirements for combustion turbines with a minimum heat input capacity of 100 million British thermal units per hour (MMBtu/hr) located at major sources of NOx. All combustion turbines in the District with a heat input capacity greater than or equal to 100 MMBtu/hr have been decommissioned and combustion turbines with a heat capacity less than 100 MMBtu/hr have been installed at major stationary sources of NOX. DOEE's changes to the NOX RACT standards for combustion turbines are aligned with federal regulations found at Title 40 of the Code of Federal Regulations Part 60, Subpart KKKK (NSPS Subpart KKKK). The only difference is that DOEE's updated regulation provides an alternate standard for units if they commenced construction, modification, or reconstruction on or before February 18, 2005, and if they limit the combustion of liquid fuel to ultra-low sulfur No. 2 fuel oil and only combust the fuel oil during periods of natural gas curtailment, natural gas supply interruption, startup, or periodic testing. This alternate standard is expected to affect one source in the District.

The final rule is largely the same as the initial proposed rule and subsequent emergency rulemaking, with the following minor updates:

  • Clarification that the averaging period for using Continuous Emissions Monitoring System (CEMS) is one (1) hour,
  • Allowing that stack testing performed in 2018 can be used to demonstrate compliance with the applicable emission limits, if notice and the stack testing results are provided to DOEE within 180 days of July 23, 2018;
  • Clarification that the compliance period began with the publication of the emergency rulemaking on July 23, 2018; and
  • Clarification that duct burners servicing combustion turbines regulated under 20 DCMR 805.4 are not subject to regulation under 20 DCMR 805.5.

This final rule became effective on December 14, 2018.

RACT for VOC and NOx (other than Combustion Turbines)

With the exception of the revisions to the NOx regulations for combustion turbines noted above, DOEE is certifying through the SIP revision that the District of Columbia's current, federally-approved SIP meets the Clean Air Act (CAA) RACT requirements in regards to the control of VOC and other sources of NOx under the 8-hour ozone NAAQS. As a result, the revised SIP does not require any changes for sources currently subject to VOC RACT or sources other than combustion turbines currently subject to NOx RACT.

If you need assistance in determining how these changes would impact your facility and with the upcoming compliance requirements, please contact Trinity's Washington, DC office at (240) 379-7490.