DEQ-CFW_00008780

From: Pjetraj,Michael [michuelNetnaj@pncdencgov
Sent: 4/20/20114:32:14PN1
To: PjetraiMichael [/O=NCMA|L/OU=EXCHANSEADMINISTRATIVE GROUP
(FYD|BOHFI]3PDLT)/CN=REOP|ENT3/CN=K8|CHA[LB[TRA]];NCDENR.DENR.DAD.Reg_Supervisors
[/O=NCK8A|L/OU=EXCHAN6EADMINISTRATIVE GROUP
(FYD|BOHFI]3PDLT)/CN=REOP|ENT3/CN=NCDENR.DEN R.DAQ.RES_3UPERV|3OR5];
NCDEN R. DEN R.DAQ.Compliance—Coordinators [/O=NCMAIL/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYD|BOHFI]3PD[n/CN=REOP|ENT3/CN=NCDENR.DEN R.DAOLCOK8PL|ANCE_COOKD|NATORS]
CC: Saunders, Gary [/O=NCK8A|L/OU=EXCHAN6EADMINISTRATIVE GROUP
(FY08OHF23SPDLT)/CN=REOP|ENTS/CN=GARYIAUNDER5];Parekh,Samir[/Q=NCK8A|L/OU=EXCHANGE
ADMINISTRATIVE GROUP (FYD|8OHF23SPDLT)/CN=REC|PIE NTS/CN=SAPW|R.RAR[KH];Evans, John
[/O=NCyWA!L/OU=EXCHANGEADMINISTRATIVE GROUP (FY0BQHF2]SPDLT)/CN=REC|P|ENTS/CN=]OHNl.EVANS];
Thaker,Rahu|[/O=NCPWA|L/QU=EXCHANGEADMINISTRATIVE GROUP
(FY08OHF23SPDLT)/CN=REOP|ENTS/CN=RAHULTHAKER]
Subject: RE: URGENT NSPS Subpart D boilers (Specifically Dc boilers) & new monitoring requirements needed by 4/29/11
Attachments: NSPSsubpart DBoilers in|8[AMasuf4-20-2Ol1x|s;ATT00O01'c
& the attachment
From: Pjetraj, Michael [mailto:[e-mail]]
Sent: Wednesday, April 20, 2011 12:31 PM
Subject: URGENT - NSPS Subpart D boilers (Specifically Dc boilers) & new monitoring requirements needed by 4/29
Hey folks,
Sorry for this last minute crisis — Please read the email from Steve Carr below & then the response from
Gary Saunders. Gary, Samir Parekh & Rahul Thaker have researched the issue and provided the response
that Gary wrote. I have also included a list of all Subpart D sources in the attached excel file that Bernard
pulled from IBEAM.
From: Carr, Steven
To: Pjetraj, Michael
Cc: Hall, Steve; Mceachern, Charles
Subject: Dc boilers
Dear Mike: One ufour facilities with two higher than 3OmmBTU boilers (NSPS—Ddisperforming aMethod 9
test before April J9,JO11. These units burn gas and #Jfuel oil and were installed around ZUUO. Their corporate
office indicated that new regulations required the test. Federal Registers —76FR3Sl7,O1/2U/2D1lamending
74FRSO72,Ol/ZO/2UO9seemtoindicatethatonutineMethod9testsmaynovvberequiredfor|ar8erthan3U
mmBTUunits (oi|,wood, coa|). This does not make sense for #Jfuel oil users (with low sulfur fue|d. When you
read these regulations carefully it seems that those sources meeting the criteria of paragraph (g) of 60.47c may
not have to install a COK4 or perform Method 9 teuts—but it is not clear to us. Talking to some folks in
permitting, their impression is that these rules do apply to all Dc boiler larger than 30 mmBTU — oil, coal,
wood. RROcould have over 2Oofthese units. April 29,2U11might beadeadline that they are not aware
of. Any suggestions?? Maybe vveare missing something here. Steve Carr

From Cary Saunders:
To all regional offices with the potential situation Identified in the email frorn Steve Carr:
To simplify the scenarios, we are assuming that a facility has not and does not have a COO because it has used one of
the exemptions provided under 40 CFR 60.47c in paragraphs (c), (d), (e), (f), or (g). The way the rules are currently
written in paragraph 60.47c (a) Is that periodic opacity monitoring is required and would have to be completed by April
29, 2011 (and submitted to DAQ on that date), if they had not yet performed their first round of initial periodic
performance monitoring AND they took the exemption from using a COMS under 00.47c (c), (d), (e), or (f). Of course,
there are the notification provision of Subpart A that could be a problem from a compliance .standpoint.
The °pt"_ .. ..` T� x �-a sourc k� x fax d r i ().. ld fa t be..re u rid #�Iae �ar������ps
----------- - - - - --
under 6{ 47c were met.
The way the regulations are currently written at: 40 CFR 00.47c (g), the source would have to have a site -specific
monitoring plan approved by the DAQ. Whether that was .something submitted as part of the permit application and
written into the permit or a separate document is not specified. The paragraph does require that the plan include
procedures and criteria for establishing and monitoring specific parameters Indicative of compliance with the opacity
standard. Conducting a method 9 in lieu of this plan will cause Issues with notification requirements. Ifs a facility
sib"act t0 this ra t�Ir rr�ant s bruits a lan fOr a real and D&Q approves it b Aril 2 2011 the facility
will be in technical cq lianca of the re irementso
That's the strict reading, and requirements of the rule.
However, as Rahul pointed out, in 2007, what is now paragraph (f) did not exist and the current paragraph (g) was then
paragraph (f). and in the 2007 version of the regulation there was only the exemption from COMB and not the
exemption from periodic monitoring. In 2009, the current paragraph (f) was added and paragraph (f) became paragraph
(g). It is our understanding that EPf`-°s intended to require periodic monitoring for all the COMB exemption but that they
have carried through this oversight into the 2011 version.
Facilities that have been cornplvina with the 2007 version of the rule should be o
Cary L. Saunders, Special Projects Engineer
NC Department: of Environment: and Natural Resources
Division of Air Quality
Technical Services Section
Stationary Source Compliance Branch
1641 Mail Service `enter
Raleigh, NC 27609-1641
[phone]
(910) 73.3--1812 (FAST)
gat-y.sakinders@nc(lenr.gov
www.ncair.org
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.
DEQ-CFW 00008781

Pk,eas�e n0te -- my adc.4'es�N.-,;s cta,,nged to, [e-mail]
St"e-Cal­r, P.E., Environmental Engineer
NC DEATR, Division of Air Quality
Raleigh Regional office
3800 Barrett Drive, Raleigh, NC 27609
Voice: [phone] Fax: [phone]
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.
DEQ-CFW-00008782