6.1. ERMUSR 09-15-2010 - Laserfiche WebLink

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Affected APPA Member August 20, 2010 Page 2 (separate from the RICE NESFIAP rule), compression ignition RICE that are "used to supply power to an electric grid or that supply power as part of a financial arrangement with another entity are not considered to be emergency engines." 7l Fed. Reg. 39,180, col. 1 (definition of emergency stationary internal combustion engine). Only you would know whether you fall under the 2006 NSPS rule. We encoumge you to ensure that you are in compliance with the 2006 NSPS, including seeking legal advice, if necessary. Because of the pervasive impacts of the new RICE rule on public power utilities and the concern it has raised, APPA intends to work with our members to better understand the impacts of the rule, facilitate information sharing among APPA and its members on the issue, and examine potential opportunities for additional flexibility at the state or federal level. APPA is convening a group of experts on the RICE issues within our membership to look at any further actions that might be undertaken by APPA. Tn order to assist you in the interim, we have created amember-only website that should assist you in conveniently finding the EPA materials that you will need as you assess the regulatory impact in your community. The items that are posted on our website include: • Final RICE Engine Compliance Extension Memo from outside counsel and copies of the form for submittal to the EPA by August 3l, 2010. The memo is provided for your initial review. We encourage you to seek your own counsel's advice as to any local circumstances on state permitting issues or if your utility cannot yet know whether you will be covered by August 31, 2010. This memo is available at: ht[o•//www.appanet.ore/files/RFP/Comp) ianceExtensionsWAttachment%2DFINAL.odf • EPA's Final Decision to Continue Applying the Agency's Existing Interpretation of a Regulation That Determines the Scope of Pollutants Subject to the Federal Prevention of Significant Deterioration (PSD) Program under the Clean Air Act (03/29/2010) • uestions Parts L and 2 of the EGU MACT ICR (02/25/10) • Slides from the Tune 2010 APPA webinar on the RICE rule, available at the following link: http•//www ap~anet org/files/PowerPoint/RICEPresentationAPPA ppt • EPA's proposed Spark Ignition Proposed Rule, available on EPA's webpage a[: htto~//www epa gov/ttn/oarpe/t3/fr notices/rice neshap fN81010 odf. Please see pages 107-109 for EPA's reference to emergency usage and comments on emergency generation, limited use, and other special circumstances. The deadline for comments is 60 days after the proposed rule is published in the Federal Register (it has not been published as of today) which will likely be mid- October and APPA encourages you to file comments on your own utility's behalf. We also are soliciting comments that could address APPA's broader membership. Please contact J.P. Blackford to submit ideas for filing comments by September 20. J.P. may be contacted at jpblackford @appanet.org In addition, there may be state regulatory issues that APPA has not tracked including whether or not your state requires operating permits or General permits for operating these units. We encourage you to look at the U. S. EPA materials provided to you on our website thttp://www.appanet.or utility/index.cfm?ItemNumber=286931 and to also check into any applicability under your state law. We know that the coming decade will continue to put considerable pressure on all fossil fuel units- whether they are for baseload generation or use such as these RICE units. The EPA is attempting to regulate all sources of pollution (mostly SO2, NOx, mercury, COZ and carbon monoxide as in this RICE rule). Their regulations promise to continue to require lower levels of allowable emissions through the placement of control technologies. While the news in this rulemaking may not please many APPA