ECT is CSX Transportation Inc.’s (CSXT’s) air environmental consultant for air regulatory permitting and compliance system-wide. ECT is responsible for maintaining compliance with federal, state, and local air regulatory requirements for all CSXT facilities and operations throughout their entire 23-state system. ECT combines its extensive air regulatory experience with a thorough understanding of CSXT facilities and operations to ensure that CSXT maintains continuous compliance with all air regulatory issues.
ECT’s responsibilities include performing comprehensive air emission inventories and regulatory assessments to determine permitting/regulatory applicability. ECT provides construction and operation permitting in both attainment and nonattainment areas, conducts onsite compliance training, conducts visible emissions testing in accordance with EPA Method 9, and prepares annual operating reports. ECT negotiates permit strategies, permit conditions and regulatory interpretations with state and local regulatory agencies.
ECT also assists CSXT in maintaining compliance with 40 CFR Part 1033, Emission Standards for Locomotives and Locomotive Engines. ECT prepares and submits applications for Certificates of Conformity for various engine families, verifies emission test data to ensure compliance with emission standards, prepares quarterly reports, and reviews audit program and quality assurance to maintain continuous compliance.
ECT also assists CSXT with maintaining compliance with other federal regulatory programs such as New Source Performance Standards (NSPSs) and National Emission Standards of Hazardous Air Pollutants (NESHAPs). Specifically, in order to maintain compliance with the federal regulations for stationary internal combustion engines, 40 CFR 60 Subpart IIII, 40 CFR 60 Subpart JJJJ, and 40 CFR 63 Subpart ZZZZ, ECT instituted a generator compliance program within CSXT. The generator compliance program monitors compliance for all generators systemwide within CSXT’s 23-state territory. ECT’s responsibilities include monitoring hours of operation and maintenance performed on the engines and creating an internal report for recordkeeping requirements.