On July 27, 2018, the District of Columbia Department of Energy and the Environment (DOEE) proposed to amend regulations related to Reasonably Available Control Technology (RACT) requirements codified in Title 20, Subtitle A, Chapter 8 of the Code of District of Columbia Regulations (20 DCMR Chapter 8). Following the update of the National Ambient Air Quality Standards (NAAQS) for ozone in 2008, areas designated nonattainment for a revised ozone NAAQS and states located in the Ozone Transport Region (OTR) are 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 proposed regulations addressing this requirement.
RACT Requirements for Combustion Turbines
Currently, 20 DCMR Chapter 805 establishes NOx RACT requirements for combustion turbines with a minimum energy input capacity of 100 million British thermal units per hour (MMBtu/hr) located at major sources of NOx. Since the last update to the District's NOx RACT standards in 2004, all combustion turbines with a heat capacity greater than 100 MMBtu/hr have been decommissioned and turbines with a heat capacity less than 100 MMBtu/hr have been installed at major stationary sources of NOx. DOEE's proposed 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 proposed 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 number two 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. Other combustion turbines in the District are already subject to the NOx limits in NSPS Subpart KKKK and the impact of this rulemaking is expected to be minimal.
This emergency rulemaking became effective on July 23, 2018 and DOEE simultaneously issued an identical proposed rulemaking for public comment.
RACT for Volatile Organic Compounds (VOC):
DOEE is certifying through this proposed 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 volatile organic compounds (VOC) under the 8-hour ozone NAAQS. As a result, the proposed SIP does not require any changes to sources currently subject to VOC RACT requirements.
RACT for Nitrogen Oxides (NOx)
With the exception of certain combustion turbines, DOEE is certifying through the proposed SIP Revision that the District of Columbia's current, federally-approved SIP meets the CAA RACT requirements in regards to the control of nitrogen oxides (NOx) under the 8-hour ozone NAAQS. As discussed above, DOEE issued a separate emergency rulemaking to address the changes that affect combustion turbines and equipment fired on digester gas. For all other sources subject to NOx RACT requirements, this proposed SIP does result in any changes.
The three proposed regulations are currently out for public comment. The deadline to submit comments is August 27, 2018. In addition, DOEE will be holding a public hearing on the proposed regulations on August 27, 2018 at 5:30 PM. Once the proposed SIP amendments are final, DOEE will submit them to EPA for inclusion in the District's SIP.
More information about the existing regulations, the proposed regulations, and the RACT evaluation for NOx and VOC can be found in the following links:
If you need assistance in determining how these changes would impact your facility or with preparing comments on the draft regulations, please contact Trinity's Washington, DC office at (240) 379-7490.