For those stationary combustion turbines (SCT) where the stay was removed on March 9, 2022 (New Lean Premix and Diffusion Flame Gas-Fired Turbines), the initial performance test is required to be completed by September 5, 2022 (180 days after the compliance date). Due to the restricted compliance testing window and the industry-wide resource limitations for these highly complex projects, some facilities will not be able to meet the deadline for the initial performance test. Therefore, Alliance recommends consulting with your Administrator (state or local permitting authority who has delegation) to request an extension of the initial performance test leveraging either 40 CFR 63.6(i), extension of compliance with emissions standards, or 40 CFR 63.7(a)(4), performance testing extensions claiming force majeure.
Additionally, Alliance recommends getting your MACT YYYY test scheduled as quickly as possible beyond the current deadline of September 5, 2022 and include this information in your extension request. Schedules after September 5 are rapidly filling and will continue to do so due to the limited industry resources.
Finally, if you need support in requesting an extension, please contact Jonathan Brockhaus at the following email Jonathan.brockhaus@alliancetechnicalgroup.com