On March 14, 2024, The Environmental Protection Agency (EPA) issued final approval of Yolo-Solano Air Quality Management District’s (YSAQMD) revisions to the California State Implementation Plan (SIP). The YSAQMD proposed revisions to the SIP will be federally enforceable and included in the provisions of 40 CFR Part 52 effective, April 15, 2024. The approved YSAQMD revisions are inclusive of the Reasonably Available Control Technology State Implementation Plan Analysis for the 2008 Federal Ozone Standard and Amendments to District Rule (“2017 RACT SIP”) and amendments to YSAQMD District Rule 2.43 – Biomass Boilers.
On June 30, 2023, the EPA issued a limited approval and disapproval to the YSAQMD portion of the California SIP, due to a lack of provisions that adequately address the requirements of the 1990 Clean Air Act (CAA). The EPA’s limited disapproval of the 2017 RACT SIP in June 2023, primarily depended upon the provisions of YSAQMD District Rule 2.43 – Biomass Boilers, which included language exempting affected units from adhering to standards during startup and shutdown periods, without offering alternative emissions limitations. This language contradicted the EPA’s Startup, Shutdown, and Malfunction (SSM) Policy outlined in the 2015 SSM SIP Action. On December 13, 2023, YSAQMD submitted revisions to Rule 2.43 which address the deficiencies the EPA previously identified in the limited disapproval of the rule. On December 27, 2023, the EPA proposed approval of the California Air Resources Board’s (CARB) submission of a public draft of YSAQMD amendments to Rule 2.43.
The amendments to YSAQMD District Rule 2.43 – Biomass Boilers include the addition of two (2) provisions to the rule, Sections 503 and 504. Section 503 requires the owner/operator of an affected unit to maintain the results of any Relative Accuracy Test Audit (RATA) conducted under Section 304 of the rule for Continuous Emission Monitoring Systems (CEMS). This requires record-keeping and documentation of Relative Accuracy Test Audits (RATA) outcomes to ensure compliance with regulatory standards. Section 504 mandates the owner or operator of an affected unit to submit all necessary records, as specified by the rule, to the EPA at least every six months. These submissions are to be made through the Compliance and Emissions Data Reporting Interface (CEDRI), accessible via the U.S. EPA’s Central Data Exchange (CDX) or any similar electronic submission system provided by the U.S. EPA. There will be no emission reductions from this amendment.
The industry primarily impacted by the EPA’s final decision is biomass power production/cogeneration plants but broadly, the final rule decision will impact any manufacturers and/or operations that use industrial biomass boilers. However, the amendments to YSAQMD District Rule 2.43 – Biomass Boilers are purely administrative and have no direct impact on emissions. All facilities subject to YSAQMD District Rule 2.43 – Biomass Boilers must ensure that results from any RATA for CEMS are maintained and that all records required by the provisions of YSAQMD Rule 2.43 are submitted to the EPA at least every six (6) months on CEDRI accessible via CDX.
If you would like to discuss the proposed adoption of this rule and how it may impact your facility, please contact Trinity’s Sacramento Office or call 916.444.6666.
