National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines Legacy Docket ID #: A-95-51

Filed on regulations.gov — full text not in the inline record.

The American Petroleum Institute (API) submits the following comments on the Environmental Protection Agency’s (EPA or Agency) proposed national emission standards for hazardous air pollutants (NESHAP) for stationary combustion turbines (CT). The proposed regulation of major sources of hazardous air pollutants (HAP) is intended to reflect the application of the maximum achievable control technology (MACT) for CT. API represents more than 400 member companies involved in all aspects of the oil and natural gas industry. API members are subject to the regulations as proposed, and therefore are strongly interested in this rulemaking. API’s comments support aspects of EPA’s CT MACT proposal, as well as identify concerns that require additional attention by the Agency. API recommends EPA delist the gas-fired stationary combustion turbine source category as this source category, upon evaluation, likely has an insignificant public health impact per the criteria outlined in Section 112(c)(9) of the Clean Air Act (CAA). If EPA goes forward with regulation of this source category, API further asserts that a “no control” floor and exemption for existing turbines is appropriate since operating practices cannot be specifically linked to HAP emission reductions, please see Section III in the attached comments for the particulars. Should EPA decide to establish an emission limitation for lean premix combustion turbines, API strongly supports the option to comply with a formaldehyde concentration limit. API finds the Agency’s proposed numerical formaldehyde concentration limit for lean premix combustion turbines invalid. API has concerns that the available testing and monitoring methods have not been fully proven at the extremely low concentrations required for demonstrating compliance with the proposed CO reduction and formaldehyde concentration standards. Please read the attached document for the full details.

Hazardous Air Pollutants for Source Categories: Proposed National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines, 68 Fed. Reg. 1888 (January 14, 2003). June 6, 2003.