Federal Engine Regulations NSPS JJJJ/NESHAP ZZZZ
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1 Federal Engine Regulations NSPS JJJJ/NESHAP ZZZZ Presented to OIPA: May A World of Energy Solutions
2 NSPS JJJJ Slide 2
3 NSPS New Source Performance Standards History Regulates criteria pollutants Found under Title 40 (Environmental) Part 60 (NSPS) Where can I find these rules? Google Electronic Code of Federal Regulations Select Title 40 Select 60.1 End Select desired Subpart Slide 3
4 NSPS Subpart JJJJ New Source Performance Standards for Stationary Spark Ignited Internal Combustion Engines NSPS is a federal rule Applies to all states Is NOT regional State rules cannot be less stringent than federal rules Effective date January 18, 2008 rule is currently in effect Slide 4
5 What equipment does this rule affect? Spark ignited engines June 12, 2006 is the magic date Anything before this is exempt Rule affects all new, reconstructed or modified engines If the engine is not new, reconstructed or modified the rule does not apply What is a new engine? Any engine ordered after June 12, 2006 AND manufactured after the following dates: After Manufacture Engine type and fuel Maximum engine power date Non-Emergency Natural Gas 100 HP<500 7/1/2008 Non-Emergency Lean Burn Natural Gas 500<HP<1,350 1/1/2008 Non-Emergency Natural Gas (except lean burn HP 500 7/1/ = HP<1,350) Emergency HP 130 1/1/2009 Slide 5
6 What exactly is reconstruction? Reconstruction 40 C.F.R (NSPS Subpart A) NSPS states that reconstruction means the replacement of components at an existing facility to such an extent that: The fixed capital cost of the components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new like kind facility So what does this mean? If you spend too much on an overhaul, that engine is now subject to the rule We must track ALL engine overhaul information We must know engine pedigrees Once we lose our exemption, we NEVER get it back Slide 6
7 How do we apply reconstruction? This is not an engine to engine cost analysis We must consider the cost of an entirely new like kind facility This means including associated percentages of components that directly service the engine (skid, cooler, control system, fuel gas system, oil system, labor to package) How do I calculate the like kind facility cost? GCA Document Utilizes generic $/hp numbers based upon engine HP ranges Includes ancillary items (i.e. coolers and skid) as well as installation costs (i.e. trucking and cranes) Slide 7
8 GCA Reconstruction Document Reconstruc4on Calcula4on Engine Overhaul Cost Comparable En>rely New LKFC = % Engine Overhaul Costs Engine repair (parts and labor) Trucking and Li7ing Commissioning and Startup Labor LIKE KIND FACILITY COST Horsepower Range Ancillary Items ($/HP) Installation Costs ($/HP) < 100 HP $231 $ to 199 HP $169 $ to 499 HP $117 $ to 999 HP $114 $ to 1750 HP $78 $11 Slide 8
9 Modification NSPS affects all new, reconstructed, and modified engines 40 C.F.R (Subpart A) defines a modification as Any physical or operational change to an existing facility which results in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies Horsepower increases Engine conversions Only applies to modifications AFTER June 12, 2006 Once we lose our exemption, we never get it back Slide 9
10 Compliance Requirements What happens if we have a new, reconstructed, or modified engine? You must comply with NSPS JJJJ Emission Limits (table on next slide) Maintenance Plans Must ensure and document that the engine is operated in a manner consistent with good air pollution control practice Performance Testing Initial and subsequent performance tests (reference method testing) Must submit notifications and results by deadlines or will be referred to enforcement Recordkeeping Maintenance, testing, notifications Notifications Permitting (state by state requirements) Slide 10
11 Emission Limits New Engines Engine type and fuel Maximum engine power After Manufacture date Emission standards a g/hp-hr ppmvd at 15% O 2 NO X CO VOC d NO X CO VOC d Emergency 25>HP<130 1/1/2009 c N/A N/A N/A N/A Non-Emergency Natural Gas 100 HP<500 7/1/2008 Non-Emergency Lean Burn Natural 500<HP<1,350 1/1/2008 Gas Non-Emergency Natural Gas and (except lean burn HP 500 7/1/ = HP<1,350) Emergency HP 130 1/1/2009 Non-Emergency Natural Gas 100 HP<500 1/1/2011 Non-Emergency Lean Burn Natural 500<HP<1,350 7/1/2010 Gas Non-Emergency Natural Gas (except lean burn HP 500 7/1/ = HP<1,350) Slide 11
12 Emission Limits Reconstructed/Modified Engine type and fuel Maximum engine power Prior to Manufacture date Emission standards g/hp-hr ppmvd at 15% O 2 NO X CO VOC NO X CO VOC Reconstructed/ Modified Natural Gas Reconstructed/ Modified Emergency HP<500 7/1/2008 HP 500 7/1/2007 HP>130 1/1/2009 Otherwise Refer to New Engine Standards Slide 12
13 Expected Changes 2010/2011 Emission limits EPA has proposed changes Modified rule will attempt to provide clarity to several existing issues Final rule this summer Slide 13
14 RICE MACT NESHAP Slide 14
15 NESHAP ZZZZ National Emission Standards for Hazardous Air Pollutants History Regulates HAP (formaldehyde for us) Maximum Available Control Technology Found under Title 40 (Environmental) Part 63 (NESHAP/MACT) Where can I find these rules? Google Electronic Code of Federal Regulations Select Title 40 Select Select desired Subpart (ZZZZ) Slide 15
16 Affected Equipment The rule primarily regulated engines at major sources of HAP 10 tons/year of a single HAP or 25 tons/year of a combination Formaldehyde is usually what gets us (lean burns) 3,500 LB HP is a good estimate of what will get you > 10 TPY 15,000 RB HP will get you > 10 TPY Strategy of over controlling to get out of rule applicability Geographic boundaries Federal rule applies everywhere Slide 16
17 Final Rule for Area Sources Nov Stroke Rich burn engines > 500 HP will require emission controls 76% reduction of CH2O 4 Stroke Lean burn engine > 500 HP will require emission controls 93% reduction of CO Emissions testing Method 320 will still be allowed (based on comparative testing submitted to EPA) > 500 HP must test initially (within 180 days) and every 8,760 run hours Continuous Monitoring Continuous catalyst inlet temperature readings (at least 1x/15 min.) 4 hour rolling averages Temperature to stay between 450 and 1350 deg F for 4SLBs and between 750 and 1250 deg F for 4SRBs Monthly Pressure Drop readings across the catalyst Slide 17
18 Final Rule Management Practices 4 stroke engines < 500 HP must inspect oil and spark plugs every 1,440 hours 2 stroke engines must inspect oil and spark plugs every 4,320 hours Recordkeeping requirements Compliance Demonstration Engine Oil Analysis Program Analyze Total Acid Number, Viscosity, and % Water Content Critical Change Levels (likely never reached) Startup Requirements Minimize idle time and startup condition to less than 30 min. Slide 18
19 Final Rule Notifications/Reporting Semiannual reports will be required for all engines with numerical emission limitations (4SRB/4SLBs > 500 HP at area sources) Notice of Compliance Status (Initial) Notification of Performance Testing Notification of Applicability Due February 16, 2011 New/Reconstructed Engines will comply with JJJJ in lieu of ZZZZ Slide 19
20 RICE MACT Questions? Slide 20
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