Regulation No. 3 Changes For Internal Combustion Engines. Christine Hoefler November 14, 2012

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1 Regulation No. 3 Changes For Internal Combustion Engines Christine Hoefler November 14, 2012

2 Overview Changes to Regulation No. 3 New Source Performance Standard (NSPS) IIII Conflicts with NSPS IIII 2

3 Regulation No. 3 Regulation No. 3, requires that any process or activity that emits criteria and noncriteria pollutants at or above specific limits be reported to the Division. 3

4 What pollutants do I have to report to the Air Division? Criteria Pollutants- Carbon monoxide, nitrogen oxides, sulfur dioxide, PM10, PM 2.5, total suspended particulates, ozone, volatile organic compounds, lead. Non-Criteria Pollutants - those that are deemed Hazardous Air Pollutants per Reg. 3. And other reportable pollutants. 4

5 Recent Changes To Regulation No. 3 Reg. No. 3 listed specific exemptions from reporting requirements for select engines based on size (horse power) and hours of operation. Those exemptions have been removed and now businesses must determine if their engines exceed Reg. 3 reporting limits. 5

6 Reg. 3 Reporting Levels APEN Reporting Construction Permit Criteria Air Pollutants Attainment (tpy) Non-attainment (tpy) Attainment (tpy) Non-attainment (tpy) VOC PM-10 and PM TSP CO SO NOx Lead 100 lb/yr 100 lb/yr 200 lb/yr 200 lb/yr 11/14/2012 6

7 Previous Non-emergency Engine Exemptions Stationary Engines that are: Less than or equal to 175 horsepower that operate less than 1,450 hours per year; or Greater than 175 horsepower and less than or equal to 300 horsepower that operate less than 850 hours per year; or Greater than 300 horsepower and less than or equal to 750 horsepower that operate less than 340 hours per year. 7

8 Previous Emergency Engine Exemptions Emergency power generators that: Have a rated horsepower of less than 260; or Operate no more than 250 hours per year and have a rated horsepower of less than 737; or Operate no more than 100 hours per year and have a rated horsepower of less than 1,840. 8

9 Reason For Exemption Repeal On October 3, 2011, the EPA published a final action partially approving and partially disapproving Colorado s SIP revisions, which revised APEN and permitting exemptions. The Division opted to repeal the APEN exemption and revise the permit exemption to be consistent with current SIP approved language instead of requiring additional recordkeeping and reporting. Sources may still utilize the general one and two ton APEN exemptions found in Part A, Section II.D.1.a. of Regulation No. 3.

10 Regulation Number 3 Engine APEN and Permit Exemptions Part A NO APEN exemptions for engines Part B, Section II.D.1.c Drilling rigs Emergency Power Generators < 250 hr/year Uncontrolled actual emissions < 5 tpy Manufacturer s Site-rated horsepower < 50 hp 11/14/

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12 APENs must be submitted: Every 5 years For a change of ownership or location Significant increase in emissions (50 tons for sources >100 tpy; 5 tons for sources <100 tpy) If control equipment is installed or replaced To modify permit (i.e. switching from Portable to Stationary) 12

13 Regulation Number 3 Part A APEN Exemptions Section II.D.1. APENs must be filed for all emission units identified in any subpart of Part A of Regulation Numbers 6 or 8 Part B Construction Permit Exemptions Section II.D No exemptions apply if a source is subject to Regulation Numbers 6 or 8 Reg. 6 adopts NSPS, Reg. 8 adopts NESHAPs 11/14/

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15 New Source Performance Standards (NSPS) Adopted under Colorado Regulation Number 6, Part A Focus is criteria pollutants CO VOC NOx PM NSPS IIII applies to Stationary Compression Ignition Internal Combustion Engines ~Diesel Engines~ 15

16 NSPS IIII limits emissions of the following pollutants: NOx PM CO Non-methane hydrocarbons (NMHC) SO2 emissions will be reduced through the use of low sulfur fuel NOx will also be controlled through the use of low sulfur fuel 16

17 Who is Subject to NSPS IIII? Manufacturers of 2007 model year or later stationary CI engines <30 liters/cylinder displacement Model years differ for fire pump engines Owners/operators of stationary CI engines constructed (ordered) after July 11, 2005 and manufactured after April 1, 2006 (July 1, 2006 for fire pump engines) modified/reconstructed after July 11,

18 What is a Stationary Internal Combustion Engine (ICE)? 18 Stationary internal combustion engine means any internal combustion engine, except combustion turbines, that converts heat energy into mechanical work and is not mobile. Stationary ICE differ from mobile ICE in that a stationary internal combustion engine is not a nonroad engine as defined at 40 CFR (excluding paragraph (2)(ii) of that definition), and is not used to propel a motor vehicle or a vehicle used solely for competition.

19 Nonroad engines are: Selfpropelled (tractors, bulldozers) 19

20 Nonroad engines are: Propelled while performing their function 20

21 Nonroad engines are: Portable or transportable (has wheels, skids, carrying handles, dolly, trailer, or platform) 21

22 Not a nonroad engine if: A nonroad engine becomes stationary if it stays in one location for more than 12 months (and shorter for a seasonal source). I.B.31.b.(iii). A location is any single site at a building, structure, facility, or installation. 22

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24 Stationary engines are Engines operated at one location. Portable engines used at one location, even if moved to a storage site while not in use. Portable engines which reside at one location for longer than 12 months. 24

25 Key Terms Construction date- date ordered by owner/operator Emergency ICE- operation is limited to emergency situations and required testing and maintenance Reconstructed- engines are given a new manufacture date if the fixed capital cost of the new and refurbished components exceed 75 % of the fixed capital cost of a comparable entirely new facility (engine). 25

26 Owner/Operators of Stationary ICE s Must Meet emission standards Tier standards Use fuel compliant with fuel requirements Low sulfur diesel fuel, etc. Follow compliance requirements recordkeeping, monitoring, testing, and reporting requirements 26

27 Emission Standards Dependent upon: Engine type Emergency Non-emergency Fire pump Model year Cylinder displacement (per cylinder) Horsepower / Kilowatts 27

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29 Fuel Requirements October 1, ppm sulfur diesel (ULSD) for engines <30 liters/cylinder displacement June 1, ,000 ppm sulfur diesel for engines 30 liters/cylinder displacement Note: engines not subject to subpart IIII are not subject to these requirements 29

30 NSPS Emergency Engine Requirements No limits on hours of operation for emergency service Maintenance checks/readiness testing limited to 100 hrs/yr Can be more if mandated by Federal, State, or local standards Owner/operator can also petition for more hours 50 hrs/yr allowed for non-emergencies Counts as part of the 100 hr/yr maintenance & testing limit Engine cannot be used for peak shaving, to supply power to the electric grid, or to supply power as part of financial arrangement with another entity 30

31 Compliance Requirements Emergency Engines Non-resettable hour meter and records of operation if engine does not meet non-emergency standards Engines equipped with diesel particulate filter (DPF) Backpressure monitor and records of corrective action 31

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33 Bringing equipment in from outside of Colorado 33

34 State Only NSPS Regulation Number 6, Part B Non-Federal NSPS for Specific Facilities and Sources General Provisions, Section I.B. Relocation of a source from outside the State of Colorado into the State of Colorado is considered a new source 11/14/

35 Example Diesel Engine 25 horsepower Manufactured 2007 Constructed in Kansas in 2007 Relocated to Colorado in

36 Example HP <11 11 < <50 TIER 2 TIER 4I 50 <75 75 < < < < <

37 Prove source was in Colorado If you can prove that the equipment has been operated previously in Colorado then it will not be considered new. An old permit or APEN showing the equipment was permitted before in Colorado. Bill of Sale showing purchased in Colorado. Other records that show the equipment was operated in Colorado. Rental records 37

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41 References EPA Websites: pspg.html Air Division Home Page AP/CBON/

42 Christine Hoefler Small Business Assistance Program