On August 23, 2019, the Department of Energy and Environment (DOEE) proposed to renew and revise two source category permits to operate for emergency engines in the District. These source category permits are for engines that are subject to federal New Source Performance Standard (NSPS) Subpart JJJJ and Subpart IIII. The revised source category permit updates are largely to address revisions to the federal NSPS regulations, including the vacatur of provisions related to demand response programs. The revised permits are listed below:
- Permit No. 7048-SC-R1 - for certain diesel-fired emergency engines that are subject to NSPS Subpart IIII. This permit will ultimately replace permit No. 7048-SC, issued September 30, 2015, and scheduled to expire on September 29, 2020
- Permit No. 7043-SC-R1 - for certain natural gas-fired emergency engines subject to NSPS Subpart JJJJ. This permit will ultimately replace permit No. 7043-SC, issued September 16, 2015, and scheduled to expire on September 15, 2020
It is important to note that these permits will not immediately replace the previous source category permits. Sources that are already operating under the current source category permits, will need to submit a renewal application to be covered by the new permit prior to June 29, 2020 for diesel-fired engines, and June 15, 2020 for natural gas-fired engines.
Note that this is a new and simplified renewal application form is for sources seeking to renew approval. The form requires:
- General facility and equipment information
- Certification that there have been no changes to the engine or its operation since the initial application
- Copy of the NSPS Certificate of Conformity
- Copy of the letter from DOEE approving coverage under the original source category permit
Sources that are not currently using a source category permit would be required to submit a different, more detailed application. Both the renewal form and the initial application form for these proposed permits are included in the public notice, and comments can be submitted on the forms in addition to the permits.
As with the existing source category permits finalized by DOEE in 2015, new and existing engines will be able to apply for coverage under the permits. If an applicant is able to demonstrate that their engine meets the applicability requirements of the permit and submits a complete application, the application is passively approved after 45 days, unless DOEE rejects the application within the same timeframe. If an engine already has a site-specific Chapter 2 construction and/or operating permit, and meets the applicability criteria of one of the new source category permits, the owner can apply for coverage under that source category permit instead of renewing the Chapter 2 permit.
The revised source category permits still only allow 500 hours of operation in any given 12-month period. As with the previous source category permits, there are no set maximum emissions levels, except that no unit may emit greater than 25 tons per year of nitrogen oxides (NOx). Exceeding this limit would trigger further regulatory requirements under Title 20 of the District Code of Municipal Regulations Chapter 2 Section 205 (20 DCMR 205), the non-attainment New Source Review Program.
Trinity has been assisting clients with air quality permitting in the District of Columbia for nearly two decades. If you need assistance in determining if these source category permits could apply to your operations, or would like assistance in reviewing the revised source category permits, please call Trinity's DC office at (240) 379-7490.