Q760. Is an electric generating unit (EGU) that has a new unit exemption from the Acid Rain Program (40 CFR 72.7) subject to Subpart D? If not, is it subject to subpart C?
Note that non-subpart D fuel combustion units (if any) at the new facility at which the new EGU is located must report emissions under subpart C. Per 40 CFR 98.3(a)(1), a facility that contains any source category that is listed in Table A-3 is required to include emissions from general stationary fuel combustion sources in their annual GHG report. Because subpart D is listed in Table A-3, emissions from non-subpart D combustion sources at a facility subject to subpart D would have to be calculated according to subpart C and included in the annual report.A761. If the EGU is subject to the Acid Rain Program (ARP) or is otherwise required to report CO2 mass emissions data to EPA year-round according to 40 CFR Part 75, the GHG emissions from the unit are not required to be reported between initial startup (“first-fire”) and CEMS certification, provided that the CEMS is certified by the deadline specified in 40 CFR Part 75. According to 40 CFR 98.43, units subject to subpart D must report the same annual CO2 emissions that are submitted to EPA’s Clean Air Markets Division (CAMD) in the 40 CFR Part 75 quarterly electronic data reports, converted from short tons to metric tons. Because emissions prior to CEMS certification or expiration of an allowable window for certification are not reported to CAMD, these emissions would not be reported under subpart D. If the CEMS certification deadline is not met, emissions reporting must begin with the first operating hour after the deadline and the CO2 emissions for the unit(s) in question must be calculated and reported according to the missing data requirements of Part 75.
Source: Mike Hannan, 7/3/2013
Approval / Publishing History: Version 1
Relevant Subparts: Subpart D
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