UPDATE:  Click here to see the comment letter that was sent to USEPA on May 25, 2018.

The SWANA Landfill Gas & Biogas (LGB) Technical Division and the National Waste & Recycling Association (NWRA) have been working with representatives from the U.S. Environmental Protection Agency (EPA) on a technology review of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Combustion Turbines (40 CFR Part 63, Subpart YYYY).

EPA has until March 2020 to meet a court-ordered deadline for updating the turbine rule. EPA anticipates having a proposed rule published late 2018/early 2019 in order to meet that March 2020 deadline.

As an initial part of the review process, EPA has requested that the Associations review the list of facilities and turbines subject to the stationary combustion turbine NESHAP and provide updates where appropriate. The revised list (first tab) is attached for review.

SWANA and NWRA intend to submit comments to EPA recommending that the Agency delist the source category of stationary combustion turbines if the risk assessment results show no risk within the margin of safety. If the risk assessment does not support delisting, it is recommended that no changes be made to the standard.

EPA is also required to revisit the startup, shutdown and malfunction (SSM) requirements in the rule, particularly in regards to startup. The Associations will recommend a 60-minute relief period for start-up operations.

This Alert serves as a notification to the Core Advocacy Group of the intention to submit these comments along with NWRA no later than Friday, May 25. Attached is a first draft that may receive substantial edits; however, it provides an outline of the comments to be submitted.

SWANA requests any feedback or questions from the MA-33 group by COB Wednesday, May 23.  Please contact the Hoosier Chapter to get in touch with SWANA.