Approval and Promulgation of Implementation Plans; Kentucky; Approval of Revisions to the Jefferson County Portion of the Kentucky SIP; Emissions During Startups, Shutdowns, and Malfunctions, 33101-33107 [2014-13429]
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Federal Register / Vol. 79, No. 111 / Tuesday, June 10, 2014 / Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 52
[EPA–R04–OAR–2013–0272; FRL–9911–96Region 4]
Approval and Promulgation of
Implementation Plans; Kentucky;
Approval of Revisions to the Jefferson
County Portion of the Kentucky SIP;
Emissions During Startups,
Shutdowns, and Malfunctions
Environmental Protection
Agency.
ACTION: Final rule.
AGENCY:
The Environmental Protection
Agency (EPA) is taking final action to
approve part of a revision to the
Kentucky State Implementation Plan
(SIP), submitted by the Commonwealth
of Kentucky, through the Kentucky
Division for Air Quality (KDAQ), on
March 22, 2011. The proposed revision
was submitted by KDAQ on behalf of
the Louisville Metro Air Pollution
Control District (District), which has
jurisdiction over Jefferson County,
Kentucky. The portion of the revision
that EPA is approving modifies the
Regulation entitled ‘‘Emissions During
Startups, Shutdowns, Malfunctions and
Emergencies’’ in the Jefferson County
portion of the Kentucky SIP. EPA is
approving this portion of the March 22,
2011, SIP revision because the Agency
has determined that it is in accordance
with the requirements for SIP provisions
under the Clean Air Act (CAA or Act).
EPA will act on the other portions of
KDAQ’s March 22, 2011, submittal,
which are severable and unrelated, in a
separate action. EPA is also responding
to comments received on its May 21,
2013, proposed rulemaking.
DATES: This rule will be effective July
10, 2014.
ADDRESSES: EPA has established a
docket for this action under Docket
Identification No. EPA–R04–OAR–
2013–0272. All documents in the docket
are listed on the www.regulations.gov
Web site. Although listed in the index,
some information is not publicly
available, i.e., Confidential Business
Information or other information whose
disclosure is restricted by statute.
Certain other material, such as
copyrighted material, is not placed on
the Internet and will be publicly
available only in hard copy form.
Publicly available docket materials are
available either electronically through
www.regulations.gov or in hard copy at
the Regulatory Development Section,
Air Planning Branch, Air, Pesticides and
Toxics Management Division, U.S.
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SUMMARY:
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Environmental Protection Agency,
Region 4, 61 Forsyth Street SW.,
Atlanta, Georgia 30303–8960. EPA
requests that if at all possible, you
contact the person listed in the FOR
FURTHER INFORMATION CONTACT section to
schedule your inspection. The Regional
Office’s official hours of business are
Monday through Friday 8:30 a.m. to
4:30 p.m., excluding Federal holidays.
FOR FURTHER INFORMATION CONTACT: Joel
Huey, Regulatory Development Section,
Air Planning Branch, Air, Pesticides and
Toxics Management Division, U.S.
Environmental Protection Agency,
Region 4, 61 Forsyth Street SW.,
Atlanta, Georgia 30303–8960. Mr. Huey
may be reached by phone at (404) 562–
9104 or via electronic mail at huey.joel@
epa.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. What action is EPA taking?
II. What is the background for EPA’s action?
III. What is EPA’s response to comments?
IV. Final Action
V. Statutory and Executive Order Reviews
I. What action is EPA taking?
EPA is approving a revision to the
Jefferson County portion of the
Kentucky SIP to incorporate revisions to
Jefferson County Regulation 1.07,
‘‘Emissions During Startups,
Shutdowns, Malfunctions and
Emergencies’’ (referred to hereafter as
‘‘Rule 1.07’’). The revision modifies all
seven sections of the existing version of
Rule 1.07 currently in the EPAapproved SIP for Jefferson County.
These changes to Rule 1.07 became
effective in Jefferson County on July 1,
2005. EPA believes that the changes to
this rule are consistent with CAA
requirements that apply to excess
emissions during startup, shutdown and
malfunction (SSM) events. In addition,
EPA believes that these changes correct
existing concerns about Rule 1.07 in the
Jefferson County portion of the
Kentucky SIP, as explained below.
Please refer to the docket for this
rulemaking for the complete text of the
adopted provisions.
II. What is the background for EPA’s
action?
On March 22, 2011, KDAQ submitted
a request for EPA approval of a SIP
submittal containing proposed revisions
to the Regulation entitled ‘‘Emissions
During Startups, Shutdowns,
Malfunctions and Emergencies’’ in the
Jefferson County portion of the
Kentucky SIP. In an action published on
May 21, 2013 (78 FR 29683), EPA
proposed to approve the proposed
revisions. As noted in that proposal
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notice, the Louisville Metro Air
Pollution Control District proactively
adopted changes on June 21, 2005, with
the intent of correcting inconsistencies
between its rule and the CAA and EPA
guidance regarding SIP provisions that
apply to the treatment of excess
emissions that may occur during source
SSM events. The changes to Rule 1.07,
which were included in the March 22,
2011, SIP revision provided to EPA by
KDAQ, include: (1) Changing the name
of the regulation from ‘‘Emissions
During Startups, Shutdowns,
Malfunctions and Emergencies’’ to
‘‘Excess Emissions During Startups,
Shutdowns, and Upset Conditions’’; (2)
clarifying that excess emissions from a
process or process equipment due to
startup, shutdown, or upset (i.e.,
malfunction) condition shall be deemed
in violation of the applicable emission
standards; (3) removing the authority of
the District to grant discretionary
exemptions from compliance with SIP
emission standards during SSM events;
(4) augmenting the source excess
emission reporting requirements to
assist the District in evaluating whether
ambient standards and goals have been
exceeded and whether enforcement
actions are needed to protect public
health and welfare; and (5) removing the
provisions that created exemptions for
excess emissions during emergencies
based upon factors comparable to an
affirmative defense.
III. What is EPA’s response to
comments?
EPA received numerous comments on
the May 21, 2013, rulemaking proposing
to approve a revision to the Regulation
entitled ‘‘Emissions During Startups,
Shutdowns, Malfunctions and
Emergencies’’ in the Jefferson County
portion of the Kentucky SIP.
Specifically, the Louisville Gas and
Electric and Kentucky Utilities Energy
Company (LG&E) provided comments
adverse to the proposed rulemaking,
and a number of environmental
organizations and approximately 74
citizens provided comments supporting
the proposed rulemaking. All of the
comments received by EPA are included
in the docket for today’s final action
using Docket ID EPA–R04–OAR–2013–
0272. A summary of the comments and
EPA’s responses are provided below.
The adverse comments provided by
LG&E consist primarily of technical
concerns associated with the
administration of the revised version of
Rule 1.07 during SSM events. These
technical concerns, however, do not
appear to have been raised by LG&E at
earlier stages of the rulemaking process
when these revisions were being
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considered at the state level.1 EPA notes
that these types of concerns are more
appropriately raised first during the rule
development process undertaken by a
state, rather than later during EPA’s
evaluation of a submitted SIP revision.
Nevertheless, EPA has evaluated the
specific technical concerns raised by the
commenter, identified as comments 1
through 8 below, and provides detailed
responses. EPA has determined that the
revisions to Rule 1.07 are consistent
with the CAA and applicable EPA
guidance, and therefore the Agency is
approving these revisions into the
Kentucky SIP as it applies to Jefferson
County.
Comment 1: The commenter asserted
that the revised version of Rule 1.07 as
‘‘written and presently enforced’’ is
‘‘having a negative and unnecessary
impact on LG&E and KU Energy LLC’s
operations and customers’’ and that
‘‘continued enforcement could have an
escalated and even more detrimental
impact on electric reliability and
customer costs.’’
Response 1: The commenter provided
no specific information supporting its
contentions that the revised rule is
having negative or unnecessary impacts
on LG&E’s operations and customers.
EPA is aware of one action taken by the
District in recent years to enforce SIP
requirements consistent with revised
Rule 1.07 and two other Jefferson
County rules at the LG&E Cane Run
Power Plant in Louisville. That
enforcement action resulted in a
requirement that the source take
corrective action and pay penalties
pursuant to an administrative
settlement.2 Such enforcement actions
are intended to encourage better source
compliance with applicable
environmental regulations that are in
place for the protection of the
environment and human health.
With respect to how the revised Rule
1.07 is written, the revisions reflect the
District’s decision to bring it into
compliance with CAA requirements and
thus warrant approval by EPA into the
Commonwealth’s SIP. With respect to
how the District elects to enforce SIP
requirements consistent with Rule 1.07,
that likewise reflects the District’s
proper exercise of its enforcement
discretion authority, consistent with
1 LG&E did provide comments to the
Commonwealth, however, those comments did not
reflect the issues raised here by the Company. See
EPA Docket Number EPA–R04–OAR–2013–0272.
2 See Agreed Board Order No. 12–01, Louisville
Metro Air Pollution Control Board, Incident Nos.
05933 and 06082 regarding, among other things,
failure to report excess particulate emissions from
the sludge processing plant on five days in August
2011. See EPA Docket Number EPA–R04–OAR–
2013–0272.
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CAA requirements. By contrast, EPA
believes that SIP provisions that allow
for automatic and discretionary
exemptions for excess emissions during
SSM events, such as those eliminated by
the District in the revised version of
Rule 1.07, allow facilities to be less
diligent in minimizing pollutant
emissions during such times and that
this can result in unnecessary adverse
impacts on citizens, including
customers of LG&E. The commenter’s
concern that it may be required to
comply with SIP requirements as a
result of the revisions to Rule 1.07
through enforcement actions is not a
basis for EPA to disapprove a SIP
revision that complies with CAA
requirements.
Comment 2: The commenter claimed
that the District’s assertion that an
electric generating unit (EGU) should be
able to operate in compliance with
emission standards during startup,
shutdown and upset periods is
‘‘technically infeasible and goes against
past EPA actions and findings
pertaining to emissions during these
periods.’’
Response 2: The commenter did not
provide specific facts or information to
support this broad claim regarding EGU
operation. Furthermore, EPA disagrees
with the basic premise stated by the
commenter for multiple reasons. First,
the commenter asserted that EGUs
cannot operate in compliance with
emission standards during startup and
shutdown. EPA disagrees with this
presumption. Startup and shutdown are
normal modes of source operation, and
it is technically feasible for sources to
meet emission standards during such
periods of operation. When appropriate,
emission standards may entail
imposition of different numerical levels
or averaging periods allowed during
startup and shutdown or may require
imposition of different forms of
emission control during startup and
shutdown. Rather than allowing EGUs
to have impermissible exemptions from
applicable emission limits during SSM
events, the District has elected to
require sources to meet the applicable
SIP emission limits at all times, and this
decision is consistent with CAA
requirements.
Second, the commenter claimed that
the District’s expectation that sources
meet emission standards during startup
and shutdown ‘‘goes against past
Agency actions.’’ The commenter did
not state which ‘‘Agency actions’’ it was
referring to, and the commenter also
failed to note that EPA’s own recent
regulations pertaining to various source
categories do in fact impose numerical
emission limits upon sources that apply
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at all times, including startup,
shutdown and malfunction periods. For
example, in 2012 EPA amended the
National Emission Standards for
Hazardous Air Pollutant (NESHAP)
Emissions for Steel Pickling-HCl Process
Facilities by adding provisions requiring
that the emission limits of the rule
apply at all times, including during
SSM periods.3 As a more recent
example, EPA revised the NESHAPs for
Group IV Polymers and Resins,
Pesticide Active Ingredient Production,
and Polyether Polyols Production by
eliminating the exemption for SSM
periods so that the emission standards
in each rule apply at all times.4
Third, the commenter disregarded
EPA’s longstanding interpretation of the
CAA with respect to SIP provisions
addressing emissions during SSM
events. Since at least 1982, EPA’s
interpretation of the CAA has been that
periods of startup and shutdown of
process equipment are part of the
normal operation of a source and should
be accounted for in the design and
implementation or the operating
procedure for the process and control
equipment. Accordingly, careful
planning can be reasonably expected to
eliminate violations of emission
limitations during such periods.5
Fourth, the commenter implied that
because compliance with emission
limits during malfunctions is
‘‘technically infeasible,’’ sources should
be entitled to exemptions from
applicable SIP emission limits and thus
excused for violations due to excess
emissions during such events. EPA has
long interpreted the CAA to prohibit
exemptions for excess emissions during
malfunctions and to require that the
excess emissions be treated as
violations.6 EPA’s own recent
regulations provide no such exemptions
3 See National Emission Standards for Hazardous
Air Pollutant Emissions: Hard and Decorative
Chromium Electroplating and Chromium Anodizing
Tanks; and Steel Pickling-HCl Process Facilities and
Hydrochloric Acid Regeneration Plants; Residual
Risk and Technology Review; Final Rule (77 FR
58219, September 19, 2012).
4 See National Emission Standards for Hazardous
Air Pollutant Emissions: Group IV Polymers and
Resins; Pesticide Active Ingredient Production; and
Polyether Polyols Production (79 FR 17339, March
27, 2014).
5 See, e.g., Policy on Excess Emissions During
Startup, Shutdown, Maintenance, and
Malfunctions, from Kathleen M. Bennett, Assistant
Administrator for Air, Noise and Radiation to
Regional Administrators, Regions I–X, September
28, 1982.
6 See, e.g., State Implementation Plans (SIPs):
Policy Regarding Excess Emissions During
Malfunctions, Startup, and Shutdown, from Steven
A, Herman, Assistant Administrator for
Enforcement and Compliance Assurance, and
Robert Perciasepe, Assistant Administrator for Air
and Radiation, to Regional Administrators, Regions
I–X, September 20, 1999 (the 1999 SSM Policy).
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for excess emissions during
malfunctions as the courts have held
that no such exemptions are permissible
because emission limits must apply
continuously.
Finally, EPA notes that the District, in
addition to be being correct that the
CAA requires sources to be subject to
emission limitations at all times,
including during SSM events, has
discretion to elect how to regulate air
pollutant emissions, consistent with
CAA requirements. The District has
authority to develop SIP provisions that
impose appropriate alternative emission
limitations applicable during startup
and shutdown, consistent with EPA’s
guidance for such provisions in the
1999 SSM Policy, but the District is not
required to do so. In adopting this rule
revision, the District has determined
that sources do not need exemptions for
SSM events and should be required to
meet the otherwise applicable SIP
emission limits at all times. By
removing the exemptions for SSM
events, the District may seek to limit the
number of SSM events, the duration of
such events, and the amount of excess
emissions during such events in order to
meet CAA requirements and to protect
public health. For the District to elect to
do so is reasonable and also consistent
with CAA requirements. EPA’s duty
under section 110(k) of the CAA is to act
upon submitted SIP revisions and to
approve those that meet applicable CAA
requirements.
Comment 3: The commenter stated
that emission standards are developed
as limits to assure a source does not
create an issue with National Ambient
Air Quality Standards (NAAQS) based
on ‘‘full load normal operation.’’
Response 3: EPA disagrees with the
commenter’s limited view of the
purpose of emission limits in SIPs. The
CAA requires the imposition of SIP
emission limits on sources for a variety
of purposes, including for attainment
and maintenance of the NAAQS,
protection of PSD increments, and
protection of visibility. Even with
respect to attainment and maintenance
of the NAAQS, however, the commenter
is incorrect concerning the way in
which states may devise the required
emission limits. Pursuant to the CAA,
each state is required to adopt and
submit to the Administrator a plan that
provides for implementation,
maintenance, and enforcement of the
NAAQS within such state. Each such
plan must include enforceable emission
limitations and other control measures,
means, or techniques, as well as
schedules and timetables for
compliance, as may be necessary or
appropriate to meet the applicable
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requirements of the Act. See CAA
sections 110(a)(1) and (2). Additional
requirements apply in certain areas,
such as requirements that sources meet
a reasonably available control measure
(RACM) or reasonably available control
technology (RACT) level of control in
areas designated nonattainment for
purposes of the NAAQS. See, e.g., CAA
sections 172(c), 188, and 189 (applicable
to areas designated nonattainment for
purposes of particulate matter NAAQS).
In particular, the Agency disagrees
that states must develop all emission
standards to limit emissions only during
‘‘full load normal operation.’’ States
have discretion as to how they arrive at
appropriately protective emission
limitations, and their approach may or
may not be based only upon evaluation
of emissions during ‘‘full load normal
operation.’’ Nevertheless, the otherwise
applicable emission limitations adopted
by the state and approved into the SIP
apply at all times unless the applicable
provisions include alternative emission
limitations under specific
circumstances, such as during startup or
shutdown.
EPA also notes that, in accordance
with CAA section 302(k), SIPs must
contain emission limitations that ‘‘limit
the quantity, rate, or concentration of
emissions of air pollutants on a
continuous basis.’’ EPA has reiterated
these requirements of the CAA with
respect to SIP provisions in a recent
proposal.7 Court decisions confirm that
this requirement for continuous
compliance prohibits exemptions for
excess emissions during SSM events.8
Exemptions from SIP emission limits
would authorize sources to emit
pollutants during such periods in
quantities that could interfere with
attainment and maintenance of the
NAAQS, protection of PSD increments,
and protection of visibility.
Comment 4: The commenter stated
that ‘‘[d]uring periods of startup, certain
emissions control equipment (i.e.,
electrostatic precipitator, selective
catalytic reduction, pulsed jet fabric
filters) cannot be activated until specific
temperatures are reached from operation
of the source.’’ Based on this assertion,
the commenter argued, ‘‘[i]t follows that
a source required to utilize such
emission control equipment should not
be held to a numerical standard that was
7 See ‘‘State Implementation Plans: Response to
Petition for Rulemaking; Findings of Substantial
Inadequacy; and SIP Calls To Amend Provisions
Applying to Excess Emissions During Periods of
Startup, Shutdown, and Malfunction; Proposed
Rule,’’ 78 FR 12460 at 12470, February 22, 2013.
8 See, e.g., Sierra Club v. EPA, 551 F.3d 1019,
1021 (D.C. Cir. 2008); US Magnesium, LLC v. EPA,
690 F.3d 1157, 1170 (10th Cir. 2012).
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developed for limiting emissions during
full load, normal operation.’’
Response 4: The main premise of the
commenter’s argument is that some
existing control measures at a source
may not function, or function as
effectively, during all modes of source
operation. EPA understands that certain
emission control equipment at some
sources are not fully operational in
some circumstances, such as when
sufficient temperatures have not been
reached, as described by the commenter.
EPA does not agree, however, that ‘‘it
follows’’ automatically that sources
should be excused from meeting any
emission limitations during startup. As
noted above, SIPs must contain
emission limitations that apply on a
continuous basis. EPA also does not
necessarily agree that sources are
incapable of meeting emission
limitations that may have been
developed based upon full load
operation. Sources that have difficulty
meeting existing emission limitations
during startup should take steps to
reduce emissions during such events.
These steps may include changes to the
facility’s operations or installation of
supplemental control measures. As also
noted above, the District has the
authority to establish appropriate
alternative emission limitations to apply
during startup periods but is not
required to do so. The District has
exercised its discretion to revise Rule
1.07 such that the SIP does not provide
for exemptions to otherwise applicable
emission limitations during startup
events.
Comment 5: The commenter claimed
that ‘‘during periods of startup, although
an emission rate may be exceeded, the
mass emissions are actually very low in
comparison to normal operation because
volumetric flow is very low during
startup.’’ Based upon this assertion, the
commenter argued that ‘‘concerns with
emissions that affect the NAAQS are
negated.’’
Response 5: As noted above, EPA’s
interpretation of the CAA is that periods
of startup are part of the normal
operation of a source. Here, EPA
interprets the commenter’s reference to
‘‘normal operation’’ to mean full load
operation. EPA disagrees with the basis
of the commenter’s argument—that
emissions rate exceedances are of less
concern when they occur during periods
of startup than during full load
operation because the mass emissions
may be lower in comparison to full load
operation. The relatively lower flow and
lower gas stream temperatures that may
be associated with a startup period
could result in less dispersion and
transport of pollutants. As a result,
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communities located close to the facility
could experience greater adverse
impacts during startup than during full
load operation, even if the rate of total
pollutant emissions is lower by mass.
The District’s revisions to Rule 1.07
eliminated impermissible exemptions
that precluded the District, the
Commonwealth, EPA and citizens from
taking legal action to require sources to
make reasonable efforts to reduce these
emissions.
Comment 6: The commenter
advocated that EPA should make clear
that ‘‘certain measures, including good
engineering combustion and pollution
control practices, are an appropriate
limitation to apply during startup,
shutdown and upset condition periods.’’
The commenter asserted that EPA has
promulgated work practice standards to
minimize emissions during these
periods in both the utility Mercury and
Air Toxics Standards (MATS) and the
boiler Maximum Achievable Control
Technology (MACT) rules and should,
to the extent possible, address such
emissions in a consistent manner under
all CAA regulatory programs. The
implication of the commenter’s
statements is that EPA should require
the District to adopt some other mode or
means of control of sources to apply
during SSM events.
Response 6: EPA agrees that states
have discretion to determine how to
regulate emissions during startup and
shutdown events in most SIP
provisions, consistent with CAA
requirements, but SIP emission limits
may not include exemptions for
emissions during startup and shutdown
events. Instead, states may include
alternative emission limits for such
modes of source operation so long as
they are consistent with CAA
requirements. EPA’s 1999 SSM Policy
includes guidance to states that elect to
develop such alternative limits to apply
during startup and shutdown. EPA
notes that emission limits that apply
during specific modes of source
operation such as startup and shutdown
do not necessarily need to be expressed
as a numerical limit, so long as they
meet other CAA requirements with
respect to enforceability and the
requisite level of control (e.g., RACT or
RACM). Similarly, the emission limits
applicable during startup and shutdown
do not necessarily have to be set at the
same numerical level as during other
modes of source operation, so long as
they otherwise meet all CAA
requirements. By contrast, however,
EPA considers it impracticable to
develop alternative SIP emission limits
(whether stated numerically or as
requirement for a particular control or
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technique) that apply specifically
during malfunctions because, by
definition, malfunctions are events that
are not reasonably foreseeable, are not
avoidable through appropriate source
design, operation and maintenance, and
are not controllable. Accordingly,
sources are required to meet the
otherwise applicable SIP emission
limits during malfunctions, and any
excess emissions during such events are
considered violations. To the extent,
however, that the commenter suggests
that EPA should require states to
develop alternative emission limits that
apply during startup and shutdown, in
lieu of the otherwise applicable SIP
emission limits, EPA disagrees that its
role is to require states to do so.
The commenter also suggests that SIP
rules should be consistent with
federally promulgated standards and
points to, as examples, the rules often
referred to as the MATS and Boiler
MACT rules. The MATS rule
established standards for hazardous air
pollutant (HAP) emissions from coaland oil-fired electric utility steam
generating units (40 CFR part 63 subpart
UUUUU). See 77 FR 9304 (February 16,
2012). In the same rulemaking that
promulgated the MATS rule, EPA also
finalized changes to the New Source
Performance Standards (NSPS) that
apply to coal- and oil-fired EGUs,
industrial-commercial-institutional
steam generating units, and small
industrial commercial-institutional
steam generating units (40 CFR part 60
subparts D, Da, Db, and Dc), often
referred to as the Utility NSPS rule.9
The major source Boiler MACT rule was
published on March 21, 2011 (76 FR
15608), and applies to industrial,
commercial, and institutional boilers
and process heaters that are located at,
or are part of, a major source 10 of HAP
emissions (40 CFR 63 subpart DDDDD).
The area source Boiler MACT, also
published on March 21, 2011 (76 FR
15554), applies to industrial,
9 Following promulgation of the MATS NESHAP
and Utility NSPS, the EPA received petitions for
reconsideration of numerous provisions of both
rules pursuant to CAA section 307(d)(7)(B).
Subsequently, EPA proposed reconsideration of
specific provisions of those rules, including the
requirements applicable during periods of startup
and shutdown. 77 FR 71323 (November 30, 2012).
In that action, EPA proposed to revise the
definitions of ‘‘startup’’ and ‘‘shutdown’’ as set
forth in 40 CFR 63.10042 and to revise the work
practice standard provisions as set forth in Table 3
to Subpart UUUUU. The EPA has not yet taken final
action on the proposed revisions to those
requirements.
10 For the purposes of subpart DDDDD, a major
source of HAPs is as defined in 40 CFR 63.2, except
that for oil and natural gas production facilities a
major source of HAPs is as defined in 40 CFR
63.761.
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commercial, and institutional boilers
that are located at, or are part of, an area
source 11 of HAP emissions (40 CFR 63
subpart JJJJJJ).12
Under the MATS, Utility NSPS, and
Boiler MACT rules, numeric emission
limits generally apply for all relevant air
pollutants and their surrogates (except
organic HAPs) and for all periods of
operation. For periods of startup and
shutdown, however, these rules require
facilities to comply with work practice
standards 13 for minimizing emissions
in lieu of numeric emission limits.
EPA understands the commenter’s
suggestion that regulatory requirements
applicable to sources for purposes of
SIPs should be consistent, ‘‘to the extent
possible,’’ with the requirements of
other CAA programs. On this point, EPA
notes that the rules established under
the NSPS and NESHAP programs are
designed to achieve different objectives
of the CAA than that of SIPs. They are
technology-based, industry-specific
standards that are nationally uniform in
limiting the amount of emissions
allowed from sources. Under section
111 of the CAA, an NSPS must reflect
the degree of emission limitation and
the percentage reduction achievable by
new sources or modified existing
sources through application of the best
technological system of continuous
emission reduction that the
Administrator determines has been
adequately demonstrated. Similarly,
under section 112 of the CAA, a
NESHAP must require the maximum
degree of reduction in emissions of
hazardous air pollutants achievable by
new sources and existing sources as
determined by the Administrator. In
setting standards under sections 111
and 112, the Administrator must take
into consideration the cost of achieving
such emission reductions and any nonair quality health and environmental
11 For the purposes of subpart JJJJJJ, an area source
of HAPs is as defined in 40 CFR 63.2, except as
specified in 40 CFR 63.11195.
12 Revisions to the major source Boiler MACT and
the area source Boiler MACT were published on
January 31, 2013 (78 FR 7138), and on February 1,
2013 (78 FR 7488), respectively. In those actions,
EPA revised the definitions of ‘‘startup’’ and
‘‘shutdown’’ as set forth in 40 CFR 63.7575 and 40
CFR 63. 11237 and revised the work practice
standard provisions as set forth in Table 3 to
subpart DDDDD and in Table 3 to subpart JJJJJJ.
13 The work practice standards under these rules
are contained in Table 3 of Subpart UUUUU, Table
3 of subpart DDDDD, and Table 3 of subpart JJJJJJ.
These standards require several actions by sources,
such as following manufacturer’s recommended
procedures for minimizing startup and shutdown
periods, tuning, maintaining and inspecting burners
and associated combustion controls, keeping
records of activity and measurements, using either
natural gas or distillate oil for ignition during
startup, and operating all control devices necessary
to meet the normal operating standards.
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impact and energy requirements; under
section 112, the statute requires a
minimum stringency standard for
existing sources based on the average
emission limitation achieved in practice
by the best controlled 12 percent of
sources and a minimum stringency
standard for new sources based on the
best controlled similar source.
In contrast to the NSPS and NESHAP
programs, SIPs are EPA-approved state
plans to provide for the attainment and
maintenance of the NAAQS and to meet
other requirements such as protecting
PSD increments and visibility. Under
section 110 of the Act, each state must
adopt a plan that it determines will
provide for air quality that meets the
primary and secondary NAAQS within
the state. Consequently, SIPs must be
consistent with attainment and
maintenance of the NAAQS and
prevention of significant deterioration of
air quality throughout the state.
Exemptions from SIP emission limits,
such as that allowed under the prior
version of Rule 1.07, are not appropriate
because any emissions above the SIP
allowable rate may cause or contribute
to violations of the ambient air quality
standards and interfere with
enforcement of those SIP limits. Thus,
EPA’s interpretation of the CAA, upheld
by the courts, is that all periods of
excess emissions must be considered
violations.
While the NSPS and NESHAP may
provide good models of emission
control technology and emission limits,
they do not necessarily address all of
the issues relevant to SIP provisions and
they do not dictate state choices with
respect to control measures or emission
limitations. To the extent that a
particular NSPS or NESHAP imposing a
specific control measure or emission
limit is relevant to a given source
category, states may elect to consider
imposing comparable controls to meet
SIP requirements, as appropriate. In
addition, to the extent that imposition of
a specific control measure or emission
limit in an EPA regulation helps to
establish that a given control measure is
technologically or economically feasible
for a given source category, states may
need to take such controls into account
when evaluating emission limits for SIP
purposes. EPA emphasizes, however,
that any such consideration would need
to be based on the specific facts and
circumstances of a given source
category, as the considerations relevant
to the development of the NSPS or
NESHAP may or may not be useful for
SIP purposes.
Further, while some emission sources
may have difficulty complying with
emission standards during startup,
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shutdown and upset periods, there are
other sources of similar type that are
capable of complying continuously
during such events, especially events
that are planned for in advance, such as
startups and shutdowns. Thus, an
appropriately protective SIP rule
encourages compliance by all sources at
all times through generally applicable
emission limits that apply during full
load operation as well as during startup
and shutdown events. Where such
generally applicable limits are not
feasible for an emission source during
startup or shutdown events, the SIP may
contain appropriately established
alternative emission limitations that
apply during those events. In instances
in which an exceedance of an emission
limit is truly unavoidable because of a
malfunction, exercise of enforcement
discretion by potential enforcers, or
exercise of discretion with respect to
penalties by courts in the event of
citizen enforcement, consistent with the
provisions of CAA section 113, allows
for proper consideration of the relevant
circumstances during the event.
Comment 7: The commenter
expressed concerns about the accuracy
of emission rates that are calculated for
startup and shutdown periods. The
commenter stated that:
From a technical viewpoint, emission
limits with measurement units of mass per
heat input (e.g., pounds per million British
thermal units) pose significant concern with
respect to startup and shutdown periods.
Some emission rates are calculated using
monitored inputs of both pollutant
concentration and diluent (e.g., carbon
dioxide (CO2)) concentration. During startup
of a coal-fired EGU, there is a period of time
when the combustion airflow is much higher
than during normal operation which
inversely yields much lower CO2
[concentration] than normal. When
calculating the emission rate, [concentration
of the diluent] CO2 is used in the
denominator of these calculations. The
resulting low CO2 value can yield calculated
emission rates that are skewed high and are
not representative of actual emission
concentrations to the atmosphere. EPA
should take into consideration that skewed
emission indications during these periods
will not have an adverse impact on NAAQS
attainment or maintenance, interfere with
PSD increments, or otherwise cause adverse
impacts.
In essence, the commenter explains that
the methodology for calculating
emissions may sometimes be based
upon assumptions that reflect certain
modes of source operation, which
would make such calculations less
accurate with respect to emissions
during other modes of operation.
Response 7: EPA does not dispute that
emission rates calculated for a coal-fired
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33105
EGU during startup and shutdown may
be less accurate than during full load
operation, assuming that the formula
used for the calculations only reflects
full load operation. In some instances, a
calculated emission rate may indicate
exceedance of an applicable SIP
emission limit only because existing
parameters, such as combustion airflow,
are not consistent with the assumptions
inherent to the calculation method.
To the extent that the commenter
advocates that calculated emission rates
should be adjusted so that they more
accurately reflect the emissions that
may occur during startup and
shutdown, EPA believes such an
approach would be appropriate and
would serve to assure that emissions
estimates are more accurate for the
purposes of compliance determination
and emissions inventories. EPA notes
that some existing Federal rules provide
options for dealing with the concern
expressed by the commenter. For
example, for computing nitrogen oxide
emission rates and using CO2 as a
diluent, the continuous emission
monitoring procedures of 40 CFR Part
75 allow boiler operators to substitute a
minimum concentration of 5.0 percent
CO2 whenever the measured
concentration is less than 5.0 percent.
See 40 CFR Part 75, Appendix F,
paragraph 3.3.4.1. This prevents the
calculation of disproportionately high
emission rates due to very a low CO2
concentration, which, as indicated by
the commenter, is a factor in the
denominator of the calculation.
As noted in response to Comment 2
above, an appropriately protective SIP
provision is designed to impose
appropriate emission limits or controls
and to require compliance at all times.
However, if a source cannot
demonstrate compliance based upon the
applicable method in use, enforcement
discretion may be used to determine
whether to bring an enforcement action
and, in the event that there is
enforcement, the extent of any actual
violation will be based upon all relevant
factual information that is credible
evidence. By eliminating the
impermissible exemptions in the prior
version of Rule 1.07, the District has
taken steps to properly account for all
emissions.
Comment 8: The commenter
expressed concerns about the accuracy
of PM CEMS for determining
compliance with PM emission limits
during startup and shutdown events.
The commenter argued that:
Sources that use PM continuous emission
monitoring systems (PM CEMS) as a
continuous indication of compliance are
required to provide a periodic correlation of
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the PM CEMs output to values derived
through EPA Reference Method testing. The
correlation testing occurs at three separate
and distinct levels of operation and PM
emissions. As PM reference method testing
cannot occur during periods of startup and
shutdown due to isokinetic requirements,
there is no correlation provided during these
periods. As a result, the output of the PM
CEMS during periods of startup and
shutdown will not be adequately tied to an
EPA reference test method and cannot be
considered accurate or representative.
Response 8: EPA disagrees that the
output of the PM CEMS during periods
of startup and shutdown cannot be
considered representative of actual
emissions, regardless of whether
Reference Method stack testing has been
performed during startup and shutdown
periods. The accuracy of PM CEMS data
would be questionable if those data
were recorded when the response of the
PM CEMS falls outside the correlation
range obtained during Reference
Method testing. During periods of
startup and shutdown, at times some
PM CEMS responses may fall outside
the correlation range, but any data
measurements recorded within that
range would be considered useful in
assessing PM control device
performance.
Furthermore, the subject rule of this
action does not require that PM CEMS
data must be used to determine
compliance status during startup and
shutdown periods; it merely requires
that that the applicable emission limit
applies at all times, including SSM
periods. PM CEMS data is not the only
type of information that a court may
find credible when evaluating whether
or not a source would have been in
violation of an emission standard. For
example, opacity data from continuous
opacity monitors (which may be
required by another provision of the
statute or the SIP) and recordkeeping
data on emission control equipment use
may also provide relevant information.
The validity of all data is a
consideration that must be taken into
account, along with all other available
credible evidence, when evaluating
whether a source is in compliance with
SIP emission limits.
Comment 9: One commenter, a
national environmental group,
submitted comments in support of
EPA’s proposed approval of the
District’s revisions to Rule 1.07. The
commenter provided its own analysis of
the merits of the revisions to Rule 1.07
and its own explanation of why these
revisions are consistent with CAA
requirements and EPA’s interpretation
of the CAA with respect to proper
treatment of excess emissions during
SSM events. In particular, the
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commenter supported the clarification
that excess emissions are violations of
emission standards, the elimination of
the prior discretionary exemptions for
excess emissions, and the improved
notification and reporting requirements.
In addition, the commenter
emphasized that these revisions to Rule
1.07 will help to reduce excess
emissions during SSM events from
sources that ‘‘jeopardize[] public health
and quality of life in nearby
communities.’’ As an example, the
commenter stated that an environmental
justice community in Kentucky has
been impacted by such emissions from
specific sources. The commenter
supported the District’s revisions to
Rule 1.07 and EPA’s approval of those
revisions as a means ‘‘to help mitigate
the impacts of large pollution events on
local communities in Jefferson County,
directly improving people’s lives.’’ EPA
notes that 74 individual citizens from
Kentucky also filed supportive
comments, echoing the key points
raised by the environmental group.
Response 9: EPA agrees with the
commenters who supported the
Agency’s approval of the District’s
revisions to Rule 1.07 on the grounds
that this will help to assure that sources
take appropriate action to reduce their
emissions in order to meet CAA
requirements and thereby help to
protect public health and welfare.
Although the commenters did not
provide detailed information concerning
the specific sources and specific events
that they described, EPA agrees that
exemptions for excess emissions during
SSM events in SIP provisions have the
potential to expose surrounding
communities to higher levels of
pollutants and to remove incentives for
sources to control and minimize such
emissions during SSM events. As a
result of such exemptions, communities
near such sources may have no adequate
legal recourse to address these
problems. For the protection of public
health, the CAA imposes obligations
upon both states and EPA. States are
required to develop SIPs that meet CAA
requirements; EPA is required to
evaluate the SIPs to assure that they
meet CAA requirements. A key CAA
requirement for SIP provisions is that
they must impose emission limitations
upon sources that apply continuously,
thereby precluding exemptions for
excess emissions from sources during
SSM events and allowing for effective
enforcement by air agencies, EPA, and
the public to assure that sources comply
with CAA requirements.
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IV. Final Action
EPA is approving part of a revision to
the Kentucky SIP submitted by the
Commonwealth of Kentucky, through
KDAQ, on March 22, 2011. This
approval includes the changes to Rule
1.07 in the Jefferson County portion of
the Kentucky SIP noted in section II
above. After review and consideration of
the relevant information and data,
including the comments received, EPA
has determined that this portion of
Kentucky’s March 22, 2011, SIP revision
is consistent with the CAA and EPA’s
SSM policy.
V. Statutory and Executive Order
Reviews
Under the CAA, the Administrator is
required to approve a SIP submission
that complies with the provisions of the
Act and applicable federal regulations.
42 U.S.C. 7410(k); 40 CFR 52.02(a).
Thus, in reviewing SIP submissions,
EPA’s role is to approve state choices,
provided that they meet the criteria of
the CAA. Accordingly, this action
merely approves state law as meeting
federal requirements and does not
impose additional requirements beyond
those imposed by state law. For that
reason, this action:
• Is not a ‘‘significant regulatory
action’’ subject to review by the Office
of Management and Budget under
Executive Order 12866 (58 FR 51735,
October 4, 1993);
• does not impose an information
collection burden under the provisions
of the Paperwork Reduction Act (44
U.S.C. 3501 et seq.);
• is certified as not having a
significant economic impact on a
substantial number of small entities
under the Regulatory Flexibility Act (5
U.S.C. 601 et seq.);
• does not contain any unfunded
mandate or significantly or uniquely
affect small governments, as described
in the Unfunded Mandates Reform Act
of 1995 (Pub. L. 104–4);
• does not have Federalism
implications as specified in Executive
Order 13132 (64 FR 43255, August 10,
1999);
• is not an economically significant
regulatory action based on health or
safety risks subject to Executive Order
13045 (62 FR 19885, April 23, 1997);
• is not a significant regulatory action
subject to Executive Order 13211 (66 FR
28355, May 22, 2001);
• is not subject to requirements of
Section 12(d) of the National
Technology Transfer and Advancement
Act of 1995 (15 U.S.C. 272 note) because
application of those requirements would
be inconsistent with the CAA; and
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• does not provide EPA with the
discretionary authority to address, as
appropriate, disproportionate human
health or environmental effects, using
practicable and legally permissible
methods, under Executive Order 12898
(59 FR 7629, February 16, 1994).
In addition, this rule does not have
tribal implications as specified by
Executive Order 13175 (65 FR 67249,
November 9, 2000), because the SIP is
not approved to apply in Indian country
located in the Commonwealth, and EPA
notes that it will not impose substantial
direct costs on tribal governments or
preempt tribal law.
The Congressional Review Act, 5
U.S.C. 801 et seq., as added by the Small
Business Regulatory Enforcement
Fairness Act of 1996, generally provides
that before a rule may take effect, the
agency promulgating the rule must
submit a rule report, which includes a
copy of the rule, to each House of the
Congress and to the Comptroller General
of the United States. EPA will submit a
report containing this action and other
required information to the U.S. Senate,
the U.S. House of Representatives, and
the Comptroller General of the United
States prior to publication of the rule in
the Federal Register. A major rule
cannot take effect until 60 days after it
is published in the Federal Register.
This action is not a ‘‘major rule’’ as
defined by 5 U.S.C. 804(2).
Under section 307(b)(1) of the CAA,
petitions for judicial review of this
action must be filed in the United States
Court of Appeals for the appropriate
circuit by August 11, 2014. Filing a
petition for reconsideration by the
Administrator of this final rule does not
affect the finality of this action for the
purposes of judicial review nor does it
extend the time within which a petition
for judicial review may be filed, and
shall not postpone the effectiveness of
such rule or action. This action may not
be challenged later in proceedings to
enforce its requirements. See section
307(b)(2).
List of Subjects in 40 CFR Part 52
Environmental protection, Air
pollution control, Carbon monoxide,
Incorporation by reference,
Intergovernmental relations, Lead,
Nitrogen dioxide, Ozone, Particulate
matter, Reporting and recordkeeping
requirements, Sulfur oxides, Volatile
organic compounds.
Authority: 42 U.S.C. 7401 et seq.
Dated: May 29, 2014.
Heather McTeer Toney,
Regional Administrator, Region 4.
40 CFR part 52 is amended as follows:
PART 52—APPROVAL AND
PROMULGATION OF
IMPLEMENTATION PLANS
1. The authority citation for part 52
continues to read as follows:
■
Authority: 42 U.S.C. 7401 et seq.
Subpart S—Kentucky
2. Section 52.920(c) Table 2 is
amended under ‘‘Reg 1—General
Provisions’’ by revising the entry for
‘‘1.07’’ to read as follows:
■
§ 52.920—Identification
*
*
*
(c)* * *
*
of plan.
*
TABLE 2—EPA-APPROVED JEFFERSON COUNTY REGULATIONS FOR KENTUCKY
Reg
EPA Approval
date
Title/Subject
*
*
*
District
effective
date
Federal Register notice
*
*
*
Explanation
*
Reg 1—General Provisions
1.07 .............
Excess Emissions During Startups, Shutdowns,
and Upset Conditions.
*
*
*
*
*
*
*
*
BILLING CODE 6560–50–P
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 52
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[EPA–R09–OAR–2013–0762; FRL–9912–01–
Region 9]
Approval and Promulgation of
Implementation Plans—Maricopa
County PM–10 Nonattainment Area;
Five Percent Plan for Attainment of the
24-Hour PM–10 Standard
Environmental Protection
Agency (EPA).
AGENCY:
Final rule.
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*
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[Insert citation of publication].
*
The Environmental Protection
Agency (EPA) is approving a State
implementation plan (SIP) revision
submitted by the State of Arizona to
meet Clean Air Act (CAA) requirements
applicable to the Maricopa County
(Phoenix) PM–10 Nonattainment Area.
The Maricopa County PM–10
Nonattainment Area is designated as a
serious nonattainment area for the
national ambient air quality standards
(NAAQS) for particulate matter of ten
microns or less (PM–10). The submitted
SIP revision consists of the Maricopa
Association of Governments 2012 Five
Percent Plan for PM–10 for the Maricopa
County Nonattainment Area and the
2012 Five Percent Plan for the Pinal
County Township 1 North, Range 8 East
Nonattainment Area’’ (collectively, the
2012 Five Percent Plan). EPA is
approving the 2012 Five Percent Plan as
SUMMARY:
[FR Doc. 2014–13429 Filed 6–9–14; 8:45 am]
ACTION:
6/10/2014
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7/21/2005
*
*
meeting all relevant statutory and
regulatory requirements.
DATES: This rule is effective on July 10,
2014.
ADDRESSES: You may inspect the
supporting information for this action,
identified by docket number EPA–R09–
OAR–2013–0762, by one of the
following methods:
1. Federal eRulemaking portal,
https://www.regulations.gov, please
follow the online instructions; or,
2. Visit our regional office at, U.S.
Environmental Protection Agency
Region IX, 75 Hawthorne Street, San
Francisco, CA 94105–3901.
Docket: The index to the docket for
this action is available electronically at
https://www.regulations.gov and in hard
copy at EPA Region IX, 75 Hawthorne
Street, San Francisco, California. While
documents in the docket are listed in
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[Federal Register Volume 79, Number 111 (Tuesday, June 10, 2014)]
[Rules and Regulations]
[Pages 33101-33107]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-13429]
[[Page 33101]]
-----------------------------------------------------------------------
ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 52
[EPA-R04-OAR-2013-0272; FRL-9911-96-Region 4]
Approval and Promulgation of Implementation Plans; Kentucky;
Approval of Revisions to the Jefferson County Portion of the Kentucky
SIP; Emissions During Startups, Shutdowns, and Malfunctions
AGENCY: Environmental Protection Agency.
ACTION: Final rule.
-----------------------------------------------------------------------
SUMMARY: The Environmental Protection Agency (EPA) is taking final
action to approve part of a revision to the Kentucky State
Implementation Plan (SIP), submitted by the Commonwealth of Kentucky,
through the Kentucky Division for Air Quality (KDAQ), on March 22,
2011. The proposed revision was submitted by KDAQ on behalf of the
Louisville Metro Air Pollution Control District (District), which has
jurisdiction over Jefferson County, Kentucky. The portion of the
revision that EPA is approving modifies the Regulation entitled
``Emissions During Startups, Shutdowns, Malfunctions and Emergencies''
in the Jefferson County portion of the Kentucky SIP. EPA is approving
this portion of the March 22, 2011, SIP revision because the Agency has
determined that it is in accordance with the requirements for SIP
provisions under the Clean Air Act (CAA or Act). EPA will act on the
other portions of KDAQ's March 22, 2011, submittal, which are severable
and unrelated, in a separate action. EPA is also responding to comments
received on its May 21, 2013, proposed rulemaking.
DATES: This rule will be effective July 10, 2014.
ADDRESSES: EPA has established a docket for this action under Docket
Identification No. EPA-R04-OAR-2013-0272. All documents in the docket
are listed on the www.regulations.gov Web site. Although listed in the
index, some information is not publicly available, i.e., Confidential
Business Information or other information whose disclosure is
restricted by statute. Certain other material, such as copyrighted
material, is not placed on the Internet and will be publicly available
only in hard copy form. Publicly available docket materials are
available either electronically through www.regulations.gov or in hard
copy at the Regulatory Development Section, Air Planning Branch, Air,
Pesticides and Toxics Management Division, U.S. Environmental
Protection Agency, Region 4, 61 Forsyth Street SW., Atlanta, Georgia
30303-8960. EPA requests that if at all possible, you contact the
person listed in the FOR FURTHER INFORMATION CONTACT section to
schedule your inspection. The Regional Office's official hours of
business are Monday through Friday 8:30 a.m. to 4:30 p.m., excluding
Federal holidays.
FOR FURTHER INFORMATION CONTACT: Joel Huey, Regulatory Development
Section, Air Planning Branch, Air, Pesticides and Toxics Management
Division, U.S. Environmental Protection Agency, Region 4, 61 Forsyth
Street SW., Atlanta, Georgia 30303-8960. Mr. Huey may be reached by
phone at (404) 562-9104 or via electronic mail at huey.joel@epa.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. What action is EPA taking?
II. What is the background for EPA's action?
III. What is EPA's response to comments?
IV. Final Action
V. Statutory and Executive Order Reviews
I. What action is EPA taking?
EPA is approving a revision to the Jefferson County portion of the
Kentucky SIP to incorporate revisions to Jefferson County Regulation
1.07, ``Emissions During Startups, Shutdowns, Malfunctions and
Emergencies'' (referred to hereafter as ``Rule 1.07''). The revision
modifies all seven sections of the existing version of Rule 1.07
currently in the EPA-approved SIP for Jefferson County. These changes
to Rule 1.07 became effective in Jefferson County on July 1, 2005. EPA
believes that the changes to this rule are consistent with CAA
requirements that apply to excess emissions during startup, shutdown
and malfunction (SSM) events. In addition, EPA believes that these
changes correct existing concerns about Rule 1.07 in the Jefferson
County portion of the Kentucky SIP, as explained below. Please refer to
the docket for this rulemaking for the complete text of the adopted
provisions.
II. What is the background for EPA's action?
On March 22, 2011, KDAQ submitted a request for EPA approval of a
SIP submittal containing proposed revisions to the Regulation entitled
``Emissions During Startups, Shutdowns, Malfunctions and Emergencies''
in the Jefferson County portion of the Kentucky SIP. In an action
published on May 21, 2013 (78 FR 29683), EPA proposed to approve the
proposed revisions. As noted in that proposal notice, the Louisville
Metro Air Pollution Control District proactively adopted changes on
June 21, 2005, with the intent of correcting inconsistencies between
its rule and the CAA and EPA guidance regarding SIP provisions that
apply to the treatment of excess emissions that may occur during source
SSM events. The changes to Rule 1.07, which were included in the March
22, 2011, SIP revision provided to EPA by KDAQ, include: (1) Changing
the name of the regulation from ``Emissions During Startups, Shutdowns,
Malfunctions and Emergencies'' to ``Excess Emissions During Startups,
Shutdowns, and Upset Conditions''; (2) clarifying that excess emissions
from a process or process equipment due to startup, shutdown, or upset
(i.e., malfunction) condition shall be deemed in violation of the
applicable emission standards; (3) removing the authority of the
District to grant discretionary exemptions from compliance with SIP
emission standards during SSM events; (4) augmenting the source excess
emission reporting requirements to assist the District in evaluating
whether ambient standards and goals have been exceeded and whether
enforcement actions are needed to protect public health and welfare;
and (5) removing the provisions that created exemptions for excess
emissions during emergencies based upon factors comparable to an
affirmative defense.
III. What is EPA's response to comments?
EPA received numerous comments on the May 21, 2013, rulemaking
proposing to approve a revision to the Regulation entitled ``Emissions
During Startups, Shutdowns, Malfunctions and Emergencies'' in the
Jefferson County portion of the Kentucky SIP. Specifically, the
Louisville Gas and Electric and Kentucky Utilities Energy Company
(LG&E) provided comments adverse to the proposed rulemaking, and a
number of environmental organizations and approximately 74 citizens
provided comments supporting the proposed rulemaking. All of the
comments received by EPA are included in the docket for today's final
action using Docket ID EPA-R04-OAR-2013-0272. A summary of the comments
and EPA's responses are provided below.
The adverse comments provided by LG&E consist primarily of
technical concerns associated with the administration of the revised
version of Rule 1.07 during SSM events. These technical concerns,
however, do not appear to have been raised by LG&E at earlier stages of
the rulemaking process when these revisions were being
[[Page 33102]]
considered at the state level.\1\ EPA notes that these types of
concerns are more appropriately raised first during the rule
development process undertaken by a state, rather than later during
EPA's evaluation of a submitted SIP revision. Nevertheless, EPA has
evaluated the specific technical concerns raised by the commenter,
identified as comments 1 through 8 below, and provides detailed
responses. EPA has determined that the revisions to Rule 1.07 are
consistent with the CAA and applicable EPA guidance, and therefore the
Agency is approving these revisions into the Kentucky SIP as it applies
to Jefferson County.
---------------------------------------------------------------------------
\1\ LG&E did provide comments to the Commonwealth, however,
those comments did not reflect the issues raised here by the
Company. See EPA Docket Number EPA-R04-OAR-2013-0272.
---------------------------------------------------------------------------
Comment 1: The commenter asserted that the revised version of Rule
1.07 as ``written and presently enforced'' is ``having a negative and
unnecessary impact on LG&E and KU Energy LLC's operations and
customers'' and that ``continued enforcement could have an escalated
and even more detrimental impact on electric reliability and customer
costs.''
Response 1: The commenter provided no specific information
supporting its contentions that the revised rule is having negative or
unnecessary impacts on LG&E's operations and customers. EPA is aware of
one action taken by the District in recent years to enforce SIP
requirements consistent with revised Rule 1.07 and two other Jefferson
County rules at the LG&E Cane Run Power Plant in Louisville. That
enforcement action resulted in a requirement that the source take
corrective action and pay penalties pursuant to an administrative
settlement.\2\ Such enforcement actions are intended to encourage
better source compliance with applicable environmental regulations that
are in place for the protection of the environment and human health.
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\2\ See Agreed Board Order No. 12-01, Louisville Metro Air
Pollution Control Board, Incident Nos. 05933 and 06082 regarding,
among other things, failure to report excess particulate emissions
from the sludge processing plant on five days in August 2011. See
EPA Docket Number EPA-R04-OAR-2013-0272.
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With respect to how the revised Rule 1.07 is written, the revisions
reflect the District's decision to bring it into compliance with CAA
requirements and thus warrant approval by EPA into the Commonwealth's
SIP. With respect to how the District elects to enforce SIP
requirements consistent with Rule 1.07, that likewise reflects the
District's proper exercise of its enforcement discretion authority,
consistent with CAA requirements. By contrast, EPA believes that SIP
provisions that allow for automatic and discretionary exemptions for
excess emissions during SSM events, such as those eliminated by the
District in the revised version of Rule 1.07, allow facilities to be
less diligent in minimizing pollutant emissions during such times and
that this can result in unnecessary adverse impacts on citizens,
including customers of LG&E. The commenter's concern that it may be
required to comply with SIP requirements as a result of the revisions
to Rule 1.07 through enforcement actions is not a basis for EPA to
disapprove a SIP revision that complies with CAA requirements.
Comment 2: The commenter claimed that the District's assertion that
an electric generating unit (EGU) should be able to operate in
compliance with emission standards during startup, shutdown and upset
periods is ``technically infeasible and goes against past EPA actions
and findings pertaining to emissions during these periods.''
Response 2: The commenter did not provide specific facts or
information to support this broad claim regarding EGU operation.
Furthermore, EPA disagrees with the basic premise stated by the
commenter for multiple reasons. First, the commenter asserted that EGUs
cannot operate in compliance with emission standards during startup and
shutdown. EPA disagrees with this presumption. Startup and shutdown are
normal modes of source operation, and it is technically feasible for
sources to meet emission standards during such periods of operation.
When appropriate, emission standards may entail imposition of different
numerical levels or averaging periods allowed during startup and
shutdown or may require imposition of different forms of emission
control during startup and shutdown. Rather than allowing EGUs to have
impermissible exemptions from applicable emission limits during SSM
events, the District has elected to require sources to meet the
applicable SIP emission limits at all times, and this decision is
consistent with CAA requirements.
Second, the commenter claimed that the District's expectation that
sources meet emission standards during startup and shutdown ``goes
against past Agency actions.'' The commenter did not state which
``Agency actions'' it was referring to, and the commenter also failed
to note that EPA's own recent regulations pertaining to various source
categories do in fact impose numerical emission limits upon sources
that apply at all times, including startup, shutdown and malfunction
periods. For example, in 2012 EPA amended the National Emission
Standards for Hazardous Air Pollutant (NESHAP) Emissions for Steel
Pickling-HCl Process Facilities by adding provisions requiring that the
emission limits of the rule apply at all times, including during SSM
periods.\3\ As a more recent example, EPA revised the NESHAPs for Group
IV Polymers and Resins, Pesticide Active Ingredient Production, and
Polyether Polyols Production by eliminating the exemption for SSM
periods so that the emission standards in each rule apply at all
times.\4\
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\3\ See National Emission Standards for Hazardous Air Pollutant
Emissions: Hard and Decorative Chromium Electroplating and Chromium
Anodizing Tanks; and Steel Pickling-HCl Process Facilities and
Hydrochloric Acid Regeneration Plants; Residual Risk and Technology
Review; Final Rule (77 FR 58219, September 19, 2012).
\4\ See National Emission Standards for Hazardous Air Pollutant
Emissions: Group IV Polymers and Resins; Pesticide Active Ingredient
Production; and Polyether Polyols Production (79 FR 17339, March 27,
2014).
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Third, the commenter disregarded EPA's longstanding interpretation
of the CAA with respect to SIP provisions addressing emissions during
SSM events. Since at least 1982, EPA's interpretation of the CAA has
been that periods of startup and shutdown of process equipment are part
of the normal operation of a source and should be accounted for in the
design and implementation or the operating procedure for the process
and control equipment. Accordingly, careful planning can be reasonably
expected to eliminate violations of emission limitations during such
periods.\5\
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\5\ See, e.g., Policy on Excess Emissions During Startup,
Shutdown, Maintenance, and Malfunctions, from Kathleen M. Bennett,
Assistant Administrator for Air, Noise and Radiation to Regional
Administrators, Regions I-X, September 28, 1982.
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Fourth, the commenter implied that because compliance with emission
limits during malfunctions is ``technically infeasible,'' sources
should be entitled to exemptions from applicable SIP emission limits
and thus excused for violations due to excess emissions during such
events. EPA has long interpreted the CAA to prohibit exemptions for
excess emissions during malfunctions and to require that the excess
emissions be treated as violations.\6\ EPA's own recent regulations
provide no such exemptions
[[Page 33103]]
for excess emissions during malfunctions as the courts have held that
no such exemptions are permissible because emission limits must apply
continuously.
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\6\ See, e.g., State Implementation Plans (SIPs): Policy
Regarding Excess Emissions During Malfunctions, Startup, and
Shutdown, from Steven A, Herman, Assistant Administrator for
Enforcement and Compliance Assurance, and Robert Perciasepe,
Assistant Administrator for Air and Radiation, to Regional
Administrators, Regions I-X, September 20, 1999 (the 1999 SSM
Policy).
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Finally, EPA notes that the District, in addition to be being
correct that the CAA requires sources to be subject to emission
limitations at all times, including during SSM events, has discretion
to elect how to regulate air pollutant emissions, consistent with CAA
requirements. The District has authority to develop SIP provisions that
impose appropriate alternative emission limitations applicable during
startup and shutdown, consistent with EPA's guidance for such
provisions in the 1999 SSM Policy, but the District is not required to
do so. In adopting this rule revision, the District has determined that
sources do not need exemptions for SSM events and should be required to
meet the otherwise applicable SIP emission limits at all times. By
removing the exemptions for SSM events, the District may seek to limit
the number of SSM events, the duration of such events, and the amount
of excess emissions during such events in order to meet CAA
requirements and to protect public health. For the District to elect to
do so is reasonable and also consistent with CAA requirements. EPA's
duty under section 110(k) of the CAA is to act upon submitted SIP
revisions and to approve those that meet applicable CAA requirements.
Comment 3: The commenter stated that emission standards are
developed as limits to assure a source does not create an issue with
National Ambient Air Quality Standards (NAAQS) based on ``full load
normal operation.''
Response 3: EPA disagrees with the commenter's limited view of the
purpose of emission limits in SIPs. The CAA requires the imposition of
SIP emission limits on sources for a variety of purposes, including for
attainment and maintenance of the NAAQS, protection of PSD increments,
and protection of visibility. Even with respect to attainment and
maintenance of the NAAQS, however, the commenter is incorrect
concerning the way in which states may devise the required emission
limits. Pursuant to the CAA, each state is required to adopt and submit
to the Administrator a plan that provides for implementation,
maintenance, and enforcement of the NAAQS within such state. Each such
plan must include enforceable emission limitations and other control
measures, means, or techniques, as well as schedules and timetables for
compliance, as may be necessary or appropriate to meet the applicable
requirements of the Act. See CAA sections 110(a)(1) and (2). Additional
requirements apply in certain areas, such as requirements that sources
meet a reasonably available control measure (RACM) or reasonably
available control technology (RACT) level of control in areas
designated nonattainment for purposes of the NAAQS. See, e.g., CAA
sections 172(c), 188, and 189 (applicable to areas designated
nonattainment for purposes of particulate matter NAAQS).
In particular, the Agency disagrees that states must develop all
emission standards to limit emissions only during ``full load normal
operation.'' States have discretion as to how they arrive at
appropriately protective emission limitations, and their approach may
or may not be based only upon evaluation of emissions during ``full
load normal operation.'' Nevertheless, the otherwise applicable
emission limitations adopted by the state and approved into the SIP
apply at all times unless the applicable provisions include alternative
emission limitations under specific circumstances, such as during
startup or shutdown.
EPA also notes that, in accordance with CAA section 302(k), SIPs
must contain emission limitations that ``limit the quantity, rate, or
concentration of emissions of air pollutants on a continuous basis.''
EPA has reiterated these requirements of the CAA with respect to SIP
provisions in a recent proposal.\7\ Court decisions confirm that this
requirement for continuous compliance prohibits exemptions for excess
emissions during SSM events.\8\ Exemptions from SIP emission limits
would authorize sources to emit pollutants during such periods in
quantities that could interfere with attainment and maintenance of the
NAAQS, protection of PSD increments, and protection of visibility.
---------------------------------------------------------------------------
\7\ See ``State Implementation Plans: Response to Petition for
Rulemaking; Findings of Substantial Inadequacy; and SIP Calls To
Amend Provisions Applying to Excess Emissions During Periods of
Startup, Shutdown, and Malfunction; Proposed Rule,'' 78 FR 12460 at
12470, February 22, 2013.
\8\ See, e.g., Sierra Club v. EPA, 551 F.3d 1019, 1021 (D.C.
Cir. 2008); US Magnesium, LLC v. EPA, 690 F.3d 1157, 1170 (10th Cir.
2012).
---------------------------------------------------------------------------
Comment 4: The commenter stated that ``[d]uring periods of startup,
certain emissions control equipment (i.e., electrostatic precipitator,
selective catalytic reduction, pulsed jet fabric filters) cannot be
activated until specific temperatures are reached from operation of the
source.'' Based on this assertion, the commenter argued, ``[i]t follows
that a source required to utilize such emission control equipment
should not be held to a numerical standard that was developed for
limiting emissions during full load, normal operation.''
Response 4: The main premise of the commenter's argument is that
some existing control measures at a source may not function, or
function as effectively, during all modes of source operation. EPA
understands that certain emission control equipment at some sources are
not fully operational in some circumstances, such as when sufficient
temperatures have not been reached, as described by the commenter. EPA
does not agree, however, that ``it follows'' automatically that sources
should be excused from meeting any emission limitations during startup.
As noted above, SIPs must contain emission limitations that apply on a
continuous basis. EPA also does not necessarily agree that sources are
incapable of meeting emission limitations that may have been developed
based upon full load operation. Sources that have difficulty meeting
existing emission limitations during startup should take steps to
reduce emissions during such events. These steps may include changes to
the facility's operations or installation of supplemental control
measures. As also noted above, the District has the authority to
establish appropriate alternative emission limitations to apply during
startup periods but is not required to do so. The District has
exercised its discretion to revise Rule 1.07 such that the SIP does not
provide for exemptions to otherwise applicable emission limitations
during startup events.
Comment 5: The commenter claimed that ``during periods of startup,
although an emission rate may be exceeded, the mass emissions are
actually very low in comparison to normal operation because volumetric
flow is very low during startup.'' Based upon this assertion, the
commenter argued that ``concerns with emissions that affect the NAAQS
are negated.''
Response 5: As noted above, EPA's interpretation of the CAA is that
periods of startup are part of the normal operation of a source. Here,
EPA interprets the commenter's reference to ``normal operation'' to
mean full load operation. EPA disagrees with the basis of the
commenter's argument--that emissions rate exceedances are of less
concern when they occur during periods of startup than during full load
operation because the mass emissions may be lower in comparison to full
load operation. The relatively lower flow and lower gas stream
temperatures that may be associated with a startup period could result
in less dispersion and transport of pollutants. As a result,
[[Page 33104]]
communities located close to the facility could experience greater
adverse impacts during startup than during full load operation, even if
the rate of total pollutant emissions is lower by mass. The District's
revisions to Rule 1.07 eliminated impermissible exemptions that
precluded the District, the Commonwealth, EPA and citizens from taking
legal action to require sources to make reasonable efforts to reduce
these emissions.
Comment 6: The commenter advocated that EPA should make clear that
``certain measures, including good engineering combustion and pollution
control practices, are an appropriate limitation to apply during
startup, shutdown and upset condition periods.'' The commenter asserted
that EPA has promulgated work practice standards to minimize emissions
during these periods in both the utility Mercury and Air Toxics
Standards (MATS) and the boiler Maximum Achievable Control Technology
(MACT) rules and should, to the extent possible, address such emissions
in a consistent manner under all CAA regulatory programs. The
implication of the commenter's statements is that EPA should require
the District to adopt some other mode or means of control of sources to
apply during SSM events.
Response 6: EPA agrees that states have discretion to determine how
to regulate emissions during startup and shutdown events in most SIP
provisions, consistent with CAA requirements, but SIP emission limits
may not include exemptions for emissions during startup and shutdown
events. Instead, states may include alternative emission limits for
such modes of source operation so long as they are consistent with CAA
requirements. EPA's 1999 SSM Policy includes guidance to states that
elect to develop such alternative limits to apply during startup and
shutdown. EPA notes that emission limits that apply during specific
modes of source operation such as startup and shutdown do not
necessarily need to be expressed as a numerical limit, so long as they
meet other CAA requirements with respect to enforceability and the
requisite level of control (e.g., RACT or RACM). Similarly, the
emission limits applicable during startup and shutdown do not
necessarily have to be set at the same numerical level as during other
modes of source operation, so long as they otherwise meet all CAA
requirements. By contrast, however, EPA considers it impracticable to
develop alternative SIP emission limits (whether stated numerically or
as requirement for a particular control or technique) that apply
specifically during malfunctions because, by definition, malfunctions
are events that are not reasonably foreseeable, are not avoidable
through appropriate source design, operation and maintenance, and are
not controllable. Accordingly, sources are required to meet the
otherwise applicable SIP emission limits during malfunctions, and any
excess emissions during such events are considered violations. To the
extent, however, that the commenter suggests that EPA should require
states to develop alternative emission limits that apply during startup
and shutdown, in lieu of the otherwise applicable SIP emission limits,
EPA disagrees that its role is to require states to do so.
The commenter also suggests that SIP rules should be consistent
with federally promulgated standards and points to, as examples, the
rules often referred to as the MATS and Boiler MACT rules. The MATS
rule established standards for hazardous air pollutant (HAP) emissions
from coal- and oil-fired electric utility steam generating units (40
CFR part 63 subpart UUUUU). See 77 FR 9304 (February 16, 2012). In the
same rulemaking that promulgated the MATS rule, EPA also finalized
changes to the New Source Performance Standards (NSPS) that apply to
coal- and oil-fired EGUs, industrial-commercial-institutional steam
generating units, and small industrial commercial-institutional steam
generating units (40 CFR part 60 subparts D, Da, Db, and Dc), often
referred to as the Utility NSPS rule.\9\ The major source Boiler MACT
rule was published on March 21, 2011 (76 FR 15608), and applies to
industrial, commercial, and institutional boilers and process heaters
that are located at, or are part of, a major source \10\ of HAP
emissions (40 CFR 63 subpart DDDDD). The area source Boiler MACT, also
published on March 21, 2011 (76 FR 15554), applies to industrial,
commercial, and institutional boilers that are located at, or are part
of, an area source \11\ of HAP emissions (40 CFR 63 subpart
JJJJJJ).\12\
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\9\ Following promulgation of the MATS NESHAP and Utility NSPS,
the EPA received petitions for reconsideration of numerous
provisions of both rules pursuant to CAA section 307(d)(7)(B).
Subsequently, EPA proposed reconsideration of specific provisions of
those rules, including the requirements applicable during periods of
startup and shutdown. 77 FR 71323 (November 30, 2012). In that
action, EPA proposed to revise the definitions of ``startup'' and
``shutdown'' as set forth in 40 CFR 63.10042 and to revise the work
practice standard provisions as set forth in Table 3 to Subpart
UUUUU. The EPA has not yet taken final action on the proposed
revisions to those requirements.
\10\ For the purposes of subpart DDDDD, a major source of HAPs
is as defined in 40 CFR 63.2, except that for oil and natural gas
production facilities a major source of HAPs is as defined in 40 CFR
63.761.
\11\ For the purposes of subpart JJJJJJ, an area source of HAPs
is as defined in 40 CFR 63.2, except as specified in 40 CFR
63.11195.
\12\ Revisions to the major source Boiler MACT and the area
source Boiler MACT were published on January 31, 2013 (78 FR 7138),
and on February 1, 2013 (78 FR 7488), respectively. In those
actions, EPA revised the definitions of ``startup'' and ``shutdown''
as set forth in 40 CFR 63.7575 and 40 CFR 63. 11237 and revised the
work practice standard provisions as set forth in Table 3 to subpart
DDDDD and in Table 3 to subpart JJJJJJ.
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Under the MATS, Utility NSPS, and Boiler MACT rules, numeric
emission limits generally apply for all relevant air pollutants and
their surrogates (except organic HAPs) and for all periods of
operation. For periods of startup and shutdown, however, these rules
require facilities to comply with work practice standards \13\ for
minimizing emissions in lieu of numeric emission limits.
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\13\ The work practice standards under these rules are contained
in Table 3 of Subpart UUUUU, Table 3 of subpart DDDDD, and Table 3
of subpart JJJJJJ. These standards require several actions by
sources, such as following manufacturer's recommended procedures for
minimizing startup and shutdown periods, tuning, maintaining and
inspecting burners and associated combustion controls, keeping
records of activity and measurements, using either natural gas or
distillate oil for ignition during startup, and operating all
control devices necessary to meet the normal operating standards.
---------------------------------------------------------------------------
EPA understands the commenter's suggestion that regulatory
requirements applicable to sources for purposes of SIPs should be
consistent, ``to the extent possible,'' with the requirements of other
CAA programs. On this point, EPA notes that the rules established under
the NSPS and NESHAP programs are designed to achieve different
objectives of the CAA than that of SIPs. They are technology-based,
industry-specific standards that are nationally uniform in limiting the
amount of emissions allowed from sources. Under section 111 of the CAA,
an NSPS must reflect the degree of emission limitation and the
percentage reduction achievable by new sources or modified existing
sources through application of the best technological system of
continuous emission reduction that the Administrator determines has
been adequately demonstrated. Similarly, under section 112 of the CAA,
a NESHAP must require the maximum degree of reduction in emissions of
hazardous air pollutants achievable by new sources and existing sources
as determined by the Administrator. In setting standards under sections
111 and 112, the Administrator must take into consideration the cost of
achieving such emission reductions and any non-air quality health and
environmental
[[Page 33105]]
impact and energy requirements; under section 112, the statute requires
a minimum stringency standard for existing sources based on the average
emission limitation achieved in practice by the best controlled 12
percent of sources and a minimum stringency standard for new sources
based on the best controlled similar source.
In contrast to the NSPS and NESHAP programs, SIPs are EPA-approved
state plans to provide for the attainment and maintenance of the NAAQS
and to meet other requirements such as protecting PSD increments and
visibility. Under section 110 of the Act, each state must adopt a plan
that it determines will provide for air quality that meets the primary
and secondary NAAQS within the state. Consequently, SIPs must be
consistent with attainment and maintenance of the NAAQS and prevention
of significant deterioration of air quality throughout the state.
Exemptions from SIP emission limits, such as that allowed under the
prior version of Rule 1.07, are not appropriate because any emissions
above the SIP allowable rate may cause or contribute to violations of
the ambient air quality standards and interfere with enforcement of
those SIP limits. Thus, EPA's interpretation of the CAA, upheld by the
courts, is that all periods of excess emissions must be considered
violations.
While the NSPS and NESHAP may provide good models of emission
control technology and emission limits, they do not necessarily address
all of the issues relevant to SIP provisions and they do not dictate
state choices with respect to control measures or emission limitations.
To the extent that a particular NSPS or NESHAP imposing a specific
control measure or emission limit is relevant to a given source
category, states may elect to consider imposing comparable controls to
meet SIP requirements, as appropriate. In addition, to the extent that
imposition of a specific control measure or emission limit in an EPA
regulation helps to establish that a given control measure is
technologically or economically feasible for a given source category,
states may need to take such controls into account when evaluating
emission limits for SIP purposes. EPA emphasizes, however, that any
such consideration would need to be based on the specific facts and
circumstances of a given source category, as the considerations
relevant to the development of the NSPS or NESHAP may or may not be
useful for SIP purposes.
Further, while some emission sources may have difficulty complying
with emission standards during startup, shutdown and upset periods,
there are other sources of similar type that are capable of complying
continuously during such events, especially events that are planned for
in advance, such as startups and shutdowns. Thus, an appropriately
protective SIP rule encourages compliance by all sources at all times
through generally applicable emission limits that apply during full
load operation as well as during startup and shutdown events. Where
such generally applicable limits are not feasible for an emission
source during startup or shutdown events, the SIP may contain
appropriately established alternative emission limitations that apply
during those events. In instances in which an exceedance of an emission
limit is truly unavoidable because of a malfunction, exercise of
enforcement discretion by potential enforcers, or exercise of
discretion with respect to penalties by courts in the event of citizen
enforcement, consistent with the provisions of CAA section 113, allows
for proper consideration of the relevant circumstances during the
event.
Comment 7: The commenter expressed concerns about the accuracy of
emission rates that are calculated for startup and shutdown periods.
The commenter stated that:
From a technical viewpoint, emission limits with measurement
units of mass per heat input (e.g., pounds per million British
thermal units) pose significant concern with respect to startup and
shutdown periods. Some emission rates are calculated using monitored
inputs of both pollutant concentration and diluent (e.g., carbon
dioxide (CO2)) concentration. During startup of a coal-
fired EGU, there is a period of time when the combustion airflow is
much higher than during normal operation which inversely yields much
lower CO2 [concentration] than normal. When calculating
the emission rate, [concentration of the diluent] CO2 is
used in the denominator of these calculations. The resulting low
CO2 value can yield calculated emission rates that are
skewed high and are not representative of actual emission
concentrations to the atmosphere. EPA should take into consideration
that skewed emission indications during these periods will not have
an adverse impact on NAAQS attainment or maintenance, interfere with
PSD increments, or otherwise cause adverse impacts.
In essence, the commenter explains that the methodology for calculating
emissions may sometimes be based upon assumptions that reflect certain
modes of source operation, which would make such calculations less
accurate with respect to emissions during other modes of operation.
Response 7: EPA does not dispute that emission rates calculated for
a coal-fired EGU during startup and shutdown may be less accurate than
during full load operation, assuming that the formula used for the
calculations only reflects full load operation. In some instances, a
calculated emission rate may indicate exceedance of an applicable SIP
emission limit only because existing parameters, such as combustion
airflow, are not consistent with the assumptions inherent to the
calculation method.
To the extent that the commenter advocates that calculated emission
rates should be adjusted so that they more accurately reflect the
emissions that may occur during startup and shutdown, EPA believes such
an approach would be appropriate and would serve to assure that
emissions estimates are more accurate for the purposes of compliance
determination and emissions inventories. EPA notes that some existing
Federal rules provide options for dealing with the concern expressed by
the commenter. For example, for computing nitrogen oxide emission rates
and using CO2 as a diluent, the continuous emission
monitoring procedures of 40 CFR Part 75 allow boiler operators to
substitute a minimum concentration of 5.0 percent CO2
whenever the measured concentration is less than 5.0 percent. See 40
CFR Part 75, Appendix F, paragraph 3.3.4.1. This prevents the
calculation of disproportionately high emission rates due to very a low
CO2 concentration, which, as indicated by the commenter, is
a factor in the denominator of the calculation.
As noted in response to Comment 2 above, an appropriately
protective SIP provision is designed to impose appropriate emission
limits or controls and to require compliance at all times. However, if
a source cannot demonstrate compliance based upon the applicable method
in use, enforcement discretion may be used to determine whether to
bring an enforcement action and, in the event that there is
enforcement, the extent of any actual violation will be based upon all
relevant factual information that is credible evidence. By eliminating
the impermissible exemptions in the prior version of Rule 1.07, the
District has taken steps to properly account for all emissions.
Comment 8: The commenter expressed concerns about the accuracy of
PM CEMS for determining compliance with PM emission limits during
startup and shutdown events. The commenter argued that:
Sources that use PM continuous emission monitoring systems (PM
CEMS) as a continuous indication of compliance are required to
provide a periodic correlation of
[[Page 33106]]
the PM CEMs output to values derived through EPA Reference Method
testing. The correlation testing occurs at three separate and
distinct levels of operation and PM emissions. As PM reference
method testing cannot occur during periods of startup and shutdown
due to isokinetic requirements, there is no correlation provided
during these periods. As a result, the output of the PM CEMS during
periods of startup and shutdown will not be adequately tied to an
EPA reference test method and cannot be considered accurate or
representative.
Response 8: EPA disagrees that the output of the PM CEMS during
periods of startup and shutdown cannot be considered representative of
actual emissions, regardless of whether Reference Method stack testing
has been performed during startup and shutdown periods. The accuracy of
PM CEMS data would be questionable if those data were recorded when the
response of the PM CEMS falls outside the correlation range obtained
during Reference Method testing. During periods of startup and
shutdown, at times some PM CEMS responses may fall outside the
correlation range, but any data measurements recorded within that range
would be considered useful in assessing PM control device performance.
Furthermore, the subject rule of this action does not require that
PM CEMS data must be used to determine compliance status during startup
and shutdown periods; it merely requires that that the applicable
emission limit applies at all times, including SSM periods. PM CEMS
data is not the only type of information that a court may find credible
when evaluating whether or not a source would have been in violation of
an emission standard. For example, opacity data from continuous opacity
monitors (which may be required by another provision of the statute or
the SIP) and recordkeeping data on emission control equipment use may
also provide relevant information. The validity of all data is a
consideration that must be taken into account, along with all other
available credible evidence, when evaluating whether a source is in
compliance with SIP emission limits.
Comment 9: One commenter, a national environmental group, submitted
comments in support of EPA's proposed approval of the District's
revisions to Rule 1.07. The commenter provided its own analysis of the
merits of the revisions to Rule 1.07 and its own explanation of why
these revisions are consistent with CAA requirements and EPA's
interpretation of the CAA with respect to proper treatment of excess
emissions during SSM events. In particular, the commenter supported the
clarification that excess emissions are violations of emission
standards, the elimination of the prior discretionary exemptions for
excess emissions, and the improved notification and reporting
requirements.
In addition, the commenter emphasized that these revisions to Rule
1.07 will help to reduce excess emissions during SSM events from
sources that ``jeopardize[] public health and quality of life in nearby
communities.'' As an example, the commenter stated that an
environmental justice community in Kentucky has been impacted by such
emissions from specific sources. The commenter supported the District's
revisions to Rule 1.07 and EPA's approval of those revisions as a means
``to help mitigate the impacts of large pollution events on local
communities in Jefferson County, directly improving people's lives.''
EPA notes that 74 individual citizens from Kentucky also filed
supportive comments, echoing the key points raised by the environmental
group.
Response 9: EPA agrees with the commenters who supported the
Agency's approval of the District's revisions to Rule 1.07 on the
grounds that this will help to assure that sources take appropriate
action to reduce their emissions in order to meet CAA requirements and
thereby help to protect public health and welfare. Although the
commenters did not provide detailed information concerning the specific
sources and specific events that they described, EPA agrees that
exemptions for excess emissions during SSM events in SIP provisions
have the potential to expose surrounding communities to higher levels
of pollutants and to remove incentives for sources to control and
minimize such emissions during SSM events. As a result of such
exemptions, communities near such sources may have no adequate legal
recourse to address these problems. For the protection of public
health, the CAA imposes obligations upon both states and EPA. States
are required to develop SIPs that meet CAA requirements; EPA is
required to evaluate the SIPs to assure that they meet CAA
requirements. A key CAA requirement for SIP provisions is that they
must impose emission limitations upon sources that apply continuously,
thereby precluding exemptions for excess emissions from sources during
SSM events and allowing for effective enforcement by air agencies, EPA,
and the public to assure that sources comply with CAA requirements.
IV. Final Action
EPA is approving part of a revision to the Kentucky SIP submitted
by the Commonwealth of Kentucky, through KDAQ, on March 22, 2011. This
approval includes the changes to Rule 1.07 in the Jefferson County
portion of the Kentucky SIP noted in section II above. After review and
consideration of the relevant information and data, including the
comments received, EPA has determined that this portion of Kentucky's
March 22, 2011, SIP revision is consistent with the CAA and EPA's SSM
policy.
V. Statutory and Executive Order Reviews
Under the CAA, the Administrator is required to approve a SIP
submission that complies with the provisions of the Act and applicable
federal regulations. 42 U.S.C. 7410(k); 40 CFR 52.02(a). Thus, in
reviewing SIP submissions, EPA's role is to approve state choices,
provided that they meet the criteria of the CAA. Accordingly, this
action merely approves state law as meeting federal requirements and
does not impose additional requirements beyond those imposed by state
law. For that reason, this action:
Is not a ``significant regulatory action'' subject to
review by the Office of Management and Budget under Executive Order
12866 (58 FR 51735, October 4, 1993);
does not impose an information collection burden under the
provisions of the Paperwork Reduction Act (44 U.S.C. 3501 et seq.);
is certified as not having a significant economic impact
on a substantial number of small entities under the Regulatory
Flexibility Act (5 U.S.C. 601 et seq.);
does not contain any unfunded mandate or significantly or
uniquely affect small governments, as described in the Unfunded
Mandates Reform Act of 1995 (Pub. L. 104-4);
does not have Federalism implications as specified in
Executive Order 13132 (64 FR 43255, August 10, 1999);
is not an economically significant regulatory action based
on health or safety risks subject to Executive Order 13045 (62 FR
19885, April 23, 1997);
is not a significant regulatory action subject to
Executive Order 13211 (66 FR 28355, May 22, 2001);
is not subject to requirements of Section 12(d) of the
National Technology Transfer and Advancement Act of 1995 (15 U.S.C. 272
note) because application of those requirements would be inconsistent
with the CAA; and
[[Page 33107]]
does not provide EPA with the discretionary authority to
address, as appropriate, disproportionate human health or environmental
effects, using practicable and legally permissible methods, under
Executive Order 12898 (59 FR 7629, February 16, 1994).
In addition, this rule does not have tribal implications as specified
by Executive Order 13175 (65 FR 67249, November 9, 2000), because the
SIP is not approved to apply in Indian country located in the
Commonwealth, and EPA notes that it will not impose substantial direct
costs on tribal governments or preempt tribal law.
The Congressional Review Act, 5 U.S.C. 801 et seq., as added by the
Small Business Regulatory Enforcement Fairness Act of 1996, generally
provides that before a rule may take effect, the agency promulgating
the rule must submit a rule report, which includes a copy of the rule,
to each House of the Congress and to the Comptroller General of the
United States. EPA will submit a report containing this action and
other required information to the U.S. Senate, the U.S. House of
Representatives, and the Comptroller General of the United States prior
to publication of the rule in the Federal Register. A major rule cannot
take effect until 60 days after it is published in the Federal
Register. This action is not a ``major rule'' as defined by 5 U.S.C.
804(2).
Under section 307(b)(1) of the CAA, petitions for judicial review
of this action must be filed in the United States Court of Appeals for
the appropriate circuit by August 11, 2014. Filing a petition for
reconsideration by the Administrator of this final rule does not affect
the finality of this action for the purposes of judicial review nor
does it extend the time within which a petition for judicial review may
be filed, and shall not postpone the effectiveness of such rule or
action. This action may not be challenged later in proceedings to
enforce its requirements. See section 307(b)(2).
List of Subjects in 40 CFR Part 52
Environmental protection, Air pollution control, Carbon monoxide,
Incorporation by reference, Intergovernmental relations, Lead, Nitrogen
dioxide, Ozone, Particulate matter, Reporting and recordkeeping
requirements, Sulfur oxides, Volatile organic compounds.
Authority: 42 U.S.C. 7401 et seq.
Dated: May 29, 2014.
Heather McTeer Toney,
Regional Administrator, Region 4.
40 CFR part 52 is amended as follows:
PART 52--APPROVAL AND PROMULGATION OF IMPLEMENTATION PLANS
0
1. The authority citation for part 52 continues to read as follows:
Authority: 42 U.S.C. 7401 et seq.
Subpart S--Kentucky
0
2. Section 52.920(c) Table 2 is amended under ``Reg 1--General
Provisions'' by revising the entry for ``1.07'' to read as follows:
Sec. 52.920--Identification of plan.
* * * * *
(c)* * *
Table 2--EPA-Approved Jefferson County Regulations for Kentucky
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EPA Approval District
Reg Title/Subject date Federal Register notice effective date Explanation
--------------------------------------------------------------------------------------------------------------------------------------------------------
* * * * * * *
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Reg 1--General Provisions
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1.07................................. Excess Emissions During 6/10/2014 [Insert citation of 7/21/2005 ........................
Startups, Shutdowns, and publication].
Upset Conditions.
* * * * * * *
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* * * * *
[FR Doc. 2014-13429 Filed 6-9-14; 8:45 am]
BILLING CODE 6560-50-P