(b)(2) Unless exempt under Subsection 3 or when complying with a Plan under Rule 845, a person is subject
to this rule and shall not cause or allow the emission of NOx from the combustion of fuels in asphalt plants,
process heaters, engine test cells and stands, lime kilns, or glass manufacturing units in excess of the
allowable emissions, including the limitations of this rule at facilities meeting either of the following criteria:
(a) Located in the 2015 ozone nonattainment areas and either of the following:
(i)
A stationary source with a potential to emit 100 tons per year or greater of NOx from all combined
NOx sources on March 1, 2024, or the effective date of this rule, whichever is later.
(ii) An emission unit installed after the effective date of this rule at a facility whose potential emissions
exceed 100 tpy NOx.
Under Rule 844(5), we would like to suggest the following change to clarify which facilities must comply with
the rule:
(5) A process heater subject to an emission limit in Table 844 and installed at a facility whose potential
emissions of NOx exceed 100 tpy, after March 1, 2024, or the effective date of the rule, whichever is later,
must utilize a low-NOx burner, equivalent technology, or better.
Under Rule 844(5), a monitoring plan is required. In most cases, periodic stack testing and fuel monitoring
should be sufficient to demonstrate compliance with the NOx limit and should not require approval via a
specific monitoring plan.
Under Rule 844(6)(c)(ii). (B) and (C), the term boiler, should be “emission unit”.
(A) A parametric monitoring program that specifies operating parameters, and their ranges, that will
provide reasonable assurance each emission unit’s emissions are consistent with the requirements of this
rule.
(B) A predictive emissions measurement system that relies on automated data collection from
instruments. If an emission unit boiler is equipped with a predictive emission monitoring system,
compliance with the applicable emissions limit is determined based on the 30-day rolling average of the
hourly arithmetic average emissions rates.
(C) A continuous emission monitoring system that complies with 40 CFR part 60 or 40 CFR part 75, both
adopted by reference in R 336.1902. If an emission unit boiler is equipped with a continuous emission
monitoring system, compliance with the applicable emissions limit shall be determined based on the 30-
day rolling average emissions rates.
Under Rule 844(8), it’s unclear exactly when the reduced emission limits would take effect be effective. MMA
recommends the following change:
(8) A person that generates NOx emissions from the use of a process heater located in the 2015 ozone
nonattainment area shall meet the following limits within table 844b 12 months after the effective date of a
final determination by the USEPA, pursuant to section 182(c)(9) of the clean air act 42 USC 7511a, for either of
the following elements of the 2015 ozone National Ambient Air Quality Standard:
(a) The USEPA issues a determination that reasonable further progress as described in Michigan’s approved
state implementation plan was not achieved.
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