Electric Generating Units: Are You Submitting the Appropriate Electronic Reports for NSPS TTTT?

40 CFR Part 60, Subpart TTTT, Standards of Performance for Greenhouse Gas Emissions for Electric Generating Units (NSPS TTTT) establishes emissions standards for new stationary combustion turbines for the control of greenhouse gases (GHGs).  NSPS TTTT applies to certain steam generating units, integrated gasification combined cycle units (IGCCs), and stationary combustion turbines [i.e., electric generating units (EGUs)].  For NSPS TTTT to apply, these units must (1) have a base load rating greater than 250 million British Thermal Units per hour (MMBtu/hr) of fossil fuel and serve generators capable of selling greater than 25 megawatts (MW) of electricity, and (2) commence construction after January 8, 2014 or commence modification or reconstruction after June 18, 2014.

Certain emissions limits for units subject to NSPS TTTT require electronic self-reporting through the U.S. Environmental Protection Agency’s (U.S. EPA’s) Emissions Collection and Monitoring Plan System (ECMPS) Client Tool, which is managed by U.S. EPA’s Clean Air Markets Division (CAMD).  Specifically, for units that are required to demonstrate compliance with emissions limits on a 12-operating-month rolling average basis, quarterly reports are required.  For new applicable units that have recently commenced operation, the first report must be submitted after accumulating 12 operating months of data, for the first calendar quarter that includes the 12^th operating month.  We’ve learned that there is confusion on initiating NSPS TTTT-specific reports within ECMPS, especially for those facilities already reporting under the Acid Rain Program, or other regulations that require reporting.

Possible Compliance Gaps

Affected sources, with applicable 12-operating-month rolling average CO₂ emissions standards are required to submit reports electronically.  For example, an affected source that is subject to an output-based emissions limit (e.g., lb CO₂/MW) and has gathered more than 12-operating months of data should have an NSPS4T Summary tab in their ECMPS Client Tool, highlighted in the figure below.

However, for NSPS TTTT data to be submitted via ECMPS, a Certificate of Representation Form must be properly completed and sent to CAMD, and older versions of the Certificate of Representation Form did not identify GHG NSPS (including NSPS TTTT) as being an applicable program.  Therefore, while many Facilities may be subject to NSPS TTTT, they may not have submitted a Certificate of Representation Form that indicates NSPS TTTT applies, as presented in the image below.

Required Action Needed

For many combined-cycle combustion turbine and other EGU projects that were permitted in the early to mid-2010s, NSPS TTTT (originally proposed on June 2, 2014, and finalized on October 23, 2015) was a new rule, with little compliance guidance published.  Moreover, electronic report submissions were not due until 12-operating months of data were collected, further prolonging required reporting.

CAMD does not maintain a list of units subject to electronic reporting under NSPS TTTT; therefore, the responsibility falls to owners and operators to inform CAMD of a unit’s correct applicability via the Certificate of Representation Form.  Whether your newly constructed EGUs are coming online or have been operating for more than a year, it is important to review your NSPS TTTT reporting obligations.

Because these reporting platforms and obligations can, at times, be a little unclear, our ALL4 team has formed relationships within U.S. EPA’s CAMD over the years and has assisted our clients with navigating ECMPS and electronic quarterly reporting.  We’re always ready to assist you with compliance questions, so if this article made you stop and think about your NSPS TTTT reporting obligations or if you have additional questions, do not hesitate to reach out to Frank Dougherty at fdougherty@all4inc.com or 281-937-7553 x302.