Over the years, INGAA has commented on many EPA rulemakings and provided technical data and other content to facilitate the development of better federal regulations and policies. In these comments, INGAA raises many of these same concerns to EPA’s attention in order to identify issues that warrant regulatory review. These issues are as follows:
For the spark ignition engine NSPS (40 C.F.R., Part 60, Subpart JJJJ): (1) initial notification should not be required when an engine is ordered because its location may not be known, and (2) compliance test requirements for volatile organic compounds (VOCs) should be streamlined by identifying the list of hydrocarbons to be included for natural gas-fired engines; other related engine test requirements should also be addressed.
For the reciprocating internal combustion engine (RICE) NESHAP (40 C.F.R., Part 63, Subpart ZZZZ), EPA should simplify categorization of “remote” engines and compliance testing requirements. The latter were negatively impacted by a 2016 “test methods” rule.
Proposed amendments to the Turbine NSPS (40 C.F.R., Part 60, Subpart KKKK) would introduce definitions and new requirements regarding routine maintenance that unnecessarily affect applicability of existing simple cycle turbines. The proposed rule should be withdrawn.
Definitions should be consistent across NSPS and NESHAP regulations.
Download the full comments here.