South District. Reciprocating Internal Combustion Engines EPA S RICE NESHAP and NSPS. Carter B. Endsley, P.E. Air Resource Permitting

Transcription

1 South District Reciprocating Internal Combustion Engines EPA S RICE NESHAP and NSPS Carter B. Endsley, P.E. Air Resource Permitting December 7, 2016

2 Content RICE Engines NESHAP and NSPS RICE Rules Emergency Engines Emissions Standards Compliance Controls Permit or No permit 12/20/2016 2

3 RICE ENGINES A stationary Reciprocating Internal Combustion Engine (RICE) is any internal combustion engine which uses reciprocating motion to convert heat energy into mechanical work and is not mobile. They are not used in road vehicles or non-road mobile applications, such as bulldozers, mowers, cranes etc. SI = Spark Ignition 2SLB = 2 Stroke Lean Burn 4SRB = 4 Stroke Rich Burn CI = Compression Ignition 12/20/2016 3

4 Engine Stroke and Burn Definition Four-Stroke Engine: Any type of engine which completes the power cycle in two crankshaft revolutions, with intake and compression strokes in the first revolution and power and exhaust strokes in the second revolution. Two-Stroke Engine: Any type of engine which completes the power cycle in single crankshaft revolution by combining the intake and compression operations into one stroke and the power and exhaust operations into a second stroke. Rich Burn Engine: Any four-stroke spark ignited engine where the manufacturer s recommended operating air/fuel ratio divided by the stoichiometric air/fuel ratio at full conditions is less than or equal to 1.1. All existing engines where no manufacturer s recommendations regarding air/fuel ratio will be considered a rich burn engine if excess oxygen of exhaust at full load is less or equal to 2 percent. Lean Burn Engine: Any two-stroke or four-stroke spark ignited (SI) engine that does not meet the definition of a Rich Burn Engine. 12/20/2016 4

5 First Step - Identify your engine Is the engine a CI (Compression Ignition) or a SI (Spark Ignition)? What is the horsepower? Is Cylinder displacement 30 liters or less? Or more? When was engine ordered? Manufactured? Modified/Reconstructed? Is the engine certified by the manufacture? Is the engine located in a MAJOR source or AREA source of HAP? Is the engine a Non-Emergency or Emergency engine? What is maximum fuel consumption to be used per year? (Gallons or Cubic Ft.). Is the engine in a DEP Permitted Facility? 12/20/2016 5

6 Existing vs. New More than 500 HP at a major source If construction commenced before Dec. 19, 2002, it is EXISTING! If not, it is NEW. Less than 500 HP at a major or all HP at area source If construction commenced before June 12, 2006, it is EXISTING!... If not, it is NEW. 12/20/2016 6

7 Diesel Engine Tiers * Diesel Emissions Tiers 1 to 3 Tier 1 standards were phased-in from 1996 to The more stringent Tier 2 standards took effect from 2001 to 2006, and yet more stringent Tier 3 standards phased-in from 2006 to 2008 (Tier 3 standards applied only for engines from hp). 12/20/2016 7

8 Diesel Engine Tiers (cont.) * Diesel Emissions Tier 4 Standards Tier 4 Standards (phased-in over a period of ) require that emissions of PM and NOx be further reduced by about 90%. It also includes more stringent HC limits. (CO emission limits remain unchanged from Tier 2-3 stage). Such emission reductions can be achieved through the use of control technologies including advanced exhaust gas after-treatment. 12/20/2016 8

9 NESHAP and NSPS RICE Rules RICE NESHAP (National Emission Standards for Hazardous Air Pollutants) - 40 CFR 63, Subpart ZZZZ - Applies to stationary CI and SI engines, both existing and new. CI RICE NSPS (New source Performance Standards) 40 CFR 60, Subpart IIII Ordered after July 11, 2005 and manufactured after April 1, 2006 Modified or reconstructed after July 11, 2005 (Does not apply to existing engines) * SI RICE NSPS- 40 CFR 60, Subpart JJJJ Ordered after June 12, 2006 and manufactured on/after July, 2007 if 500 HP (except lean burn 500 HP to 1350 HP), July 1, 2008 if less than 500 HP, January 1, 2009 if emergency more than 25 HP Modified or reconstructed after June 12, Does not apply to existing engines). 12/20/2016 9

10 NESHAP Subpart ZZZZ NESHAP = National Emission Standards for Hazardous Pollutants. (There are 187 listed Hazardous Air Pollutants). Regulates HAPS from stationary RICE at both Major and Area source of HAPS. (Hazardous Air Pollutants). (All engines existing and new). Major source HAPS = More than 10 tons for single HAP and 25 tons for combined HAPs per year emissions. Area Source HAPS = Any area not a major source of HAPS. 12/20/

11 Stationary CI NSPS Subpart IIII CI Engines: 40 CFR part 60 subpart IIII (New Engines) CI Engines ordered after July 11, 2005 and manufactured after April 1, 2006 (July 1, 2006 for fire pumps). Modified/reconstructed after July 11, 2005 Engines mfg. after 2007 and later engines less than 30 liter/cyl displacement. Manufacturers Certification is required. 12/20/

12 NPS Subpart IIII Standards For engines with less than 30 liters/cylinder. Meet Tier standards equivalent to standards for nonroad engines. **************** For engines with more than 30 liters/cylinder. NOx limits equivalent to EPA s standards for large marine engines. PM limits: 60% reduction or 0.15 g/kw-hr for nonemergency..40 g/kw-hr for emergency. 12/20/

13 Stationary SI NSPS Subpart JJJJ SI Engines : 40 CFR Part 60 Subpart JJJJ (New Engines) Ordered after June 12, Modified/Reconstructed after June 12, Some engines require Manufacturers Certification, but others may not, such as landfill gas, etc. 12/20/

14 NSPS Subpart JJJJ Standards Less than 25 HP Engines Non-emergency gasoline or RB LPG Non-emergency natural gas and LB LPG 25 to 100 HP More than 100 HP and not gasoline or lean burn LPG Standards Part 90 or part 1054 standards for new non-road SI engines Part 1048 standards for new non-road SI engines Part 1048 standards for new non-road SI engines Standard in Table 1 subpart JJJJ, part 1048 standards for some engines 12/20/

15 Subcategory Criteria RICE CI Engines SI Engines Emergency Non- Emergency Non Emergency Lean Burn Non Emergency 4 stroke Rich Burn Landfill/Dig ester gas Emergency 2 Stroke 4 stroke 12/20/

16 Engines exempt from NESHAP Rule Residential: includes apartment buildings. Commercial: includes office buildings, hotels, stores, telecommunication facilities, restaurants, financial institutes, doctors office, sports and performing arts facilities. Institutional: includes medical centers, nursing homes, research centers, institution of higher education, correctional facilities, elementary and secondary schools, libraries, religious establishments, police stations and fire stations. 12/20/

17 Emergency Engine Definition Emergency Stationary RICE means: (1) RICE is operated to provide electrical power or mechanical work during an emergency situation such as: Used to produce power for critical networks or equipment when electric power from local utility or power source is interrupted or stationary RICE is used to pump water in case of fire or flood. (2) Stationary RICE is operated under limited situations not included in above paragraph, as defined in (f). 12/20/

18 Emergency Engine Operational Restrictions No time limit on the use of RICE for emergencies caused by power outage, fire or flood. May be operated for 100 hr./year for any combination Maintenance and testing 12/20/

19 Emergency Engine Operational Restrictions Up to 50 hr./ can be used for Non-Emergency situations. Hours counted as part of the 100 hr. per calendar year in non-emergency situations. * Non-Emergency situation if no financial agreement exists. * Local reliability as part of a financial agreement with another entity with conditions. Maintenance and testing Can t be used for peak shaving, or non-emergency demand response to generate income or supply power. 12/20/

20 Emergency Engine Compliance Requirements Existing Engines: Regulated by NESHAP 40 CFR 63 Subpart ZZZZ but not subject to NSPS 40 CFR 60 Subpart IIII or JJJJ. Change oil and filter every 500 hours operation or annually. Inspect Air Cleaner every 1,000 hours of operation or annually. Inspect hoses and belts every 500 hr. or annually. Inspect spark plugs (SI) every 1000 hr. or annually. Operate and maintain the RICE according to manufacturer s instructions. 12/20/

21 Emergency Engines Requirements Minimize startup and idle time (Not to exceed 30 minutes). Non-resettable hour meter must be installed. (40 CFR (f) Records of hours of operation and maintenance. Initial Notification is NOT required for Emergency Engines. NEW ENGINES- Regulated under NESHAP 40 CFR 63, Subpart ZZZZ and comply with NSPS Rules, Subpart IIII or Subpart JJJJ. Reporting requirements. 12/20/

22 Emergency Engines: Other requirements Reporting requirements: apply to engines with more than 100 HP that are operated to be available more than 15 hr. contractually for demand and voltage deviation etc. Reporting starts from Reports need to be submitted to EPA through central data exchange. Fuel requirement: Apply to emergency CI more than 100 HP and displacement of less than 30 liters/cylinder that are obligated for demand and local reliability. Beginning January 1, 2015, for CI engines, use Ultra Low Sulfur Diesel fuel. Rule allows for depletion of fuel with higher sulfur content purchased prior to January 1, /20/

23 Emissions from RICE Engines Fuel components plus air form exhaust emissions results in emissions of H20, CO2, CO, HC, NOX, SOX, Aldehydes and PM 10. (Particulate Matter). EPA is particularly interested in Formaldehyde Reduction which is a HAP (Hazardous Air Pollutant), known to be a human carcinogen and Greenhouse Gas which is regulated by the EPA, Clean Air Act. 12/20/

24 Emission Standards: Existing RICE at Major Source HP Engine subcategory CI SI 2SLB SI 4SLB SI 4SRB Non-Emergency SI LFG/DG Emergency Lss 100 Change oil and filter and inspect air cleaner(ci) or spark plug (SI) every 1000 hours or annually, inspect belts and hoses every 500 hours of operation ppm CO More ppm CO or 70 % CO reduction 23 ppm CO or 70% CO reduction 225 ppm CO 225 ppm CO No Standards 47 ppm CO 10.5 ppm CH2O 47 ppm CO 10.5 ppm CH2O No Standards 350 ppb CH2O or 70 % CH2o Reduction 177 ppm CO 177 ppm CO No standard Change oil/filter, insp. hoses and belts 500 hrs or ann. Insp. air cleaner and spark plugs 1000 hrs or annually. 12/20/

25 Emission Standards-New RICE at Major Source HP Engine subcategory CI SI 2SLB SI 4SLB SI 4SRB Non-Emergency Less 250 Comply IIII Comply JJJJ Comply JJJJ 14 ppm CH2O OR 93% CO Comply IIII Comply JJJJ Red. 14 ppm 580 ppb 12 ppm CH2O OR CH2O or CH2O or 93% CO 70% CO 58% CO Red. More 500 Comply JJJJ Comply JJJJ 350 ppb CH2O or 70 % CH2o Reduction SI LFG/DG Comply JJJJ Comply JJJJ No standard Emergenc y Comply with CI or SI but for more than 500 HP no standard. 12/20/

26 Compliance Requirement: Rice at Major Source Engine subcategory Existing Non-Emergency CI More than 100 HP at major source SI HP at major source Compliance Requirement Initial test Subsequent testing every 8760hours or 3 years for more than 500 HP (5 years for limited use) Notifications SAM reports (annual report for limited use) ULSD Fuel Crankcase emission control requirement 12/20/

27 Compliance Requirements: Rice at Major Source Engine Subcategory Existing Non Emergency SI 4 SRB More than 500 HP New Non Emergency SI 2 SLB More than 500 HP SI 4 SLB More than 250 HP SI 4 SRB More than 500 HP CI more than 500 HP New Emergency/Limited use More than 500 HP New Non-emergency LFG/DG More than 500 HP major source Compliance Requirement Initial test Subsequent test semi-annually (can be reduced) Operating limitation catalyst pressure drop and inlet temp. Notification Semi- annual compliance report Initial notification Reporting and ULSD for emergency engines used for demand response Initial notification Monitor/record fuel uses Annual report of fuel uses 12/20/

28 Compliance Requirement: RICE at Major Sources Engine Subcategory Existing emergency/black start more than 500 HP Existing non-emergency less than 100 HP at major source Compliance Requirement Operate and maintain mfg. spec. May use oil analysis program Record of operation and nonsettable hour meter Keep records Notification not required Reporting and ULSD for engines more than 100 HP used for emergency demand 12/20/

29 HP Compliance - Existing Non-Emergency RICE at AREA Source Engines Subcategory CI SI 2SLB SI 4S Remote SI 4S Non-remote SI LFG/DG Non-Emergency Change Oil and filter 1000 hours and hoses and belts 500 less 300 HPhours More 500 Change oil/filter spark inspect hoses and belts 4320 hours or annually change oil/filter, inspect spark plug and hoses and belts 1440 hours or annually same as left Change oil/filter/ inspect spark plugs inspect hoses and belts 1440 hours or annually 49 PPM CO or 70 % CO Reduction Same above same above same above same above 23 ppm CO or 70% CO reduction Same above Change oil/filter, inspect spark plug and hoses and belts 2160 hours or annually If engines used more than 24 hours 4 SLB install catalyst, 4 SRB install NSCR same above 12/20/

30 Compliance Requirement: Non-Emergency Engines at Area Source Engine Subcategory Existing non-emergency CI more than 300 HP at area source Existing non-emergency SI 4SLB/4SRB more than 500 HP at area source used more than 14 hr. and not in remote area. Compliance Requirements Initial test Subsequent test 8760 hours or three years for engines more than 500 HP (5 yr. for limited use) Operating limitation catalyst pressure drop 2 Water and inlet temperature for engines F more than 500 HP Notification is required ULSD Crankcase emission control Initial and annual catalyst activity check High temp. engine shutdown or continuously monitor inlet temp. Notification is required 12/20/

31 Compliance Requirements: Non- Emergency Engines at Area Sources Engine Subcategory Existing Non-Emergency Black start at area sources CI less 300 HP SI less 500 HP SI 2SLB more 500 HP SI LFG/DG more 500 HP SI 4SLB and 4 SRB more 500 HP used less than 24 hours in remote area Compliance Requirements Operate and maintain engine and control system as per mfg. specs. May use oil analysis program instead of frequency Keep records of maintenance Notification not required 12/20/

32 Controls - Oxidation Catalyst Controls CO and VOC by oxidation. CO is reduced to O2 HC is Oxidized to H2O Catalyst Inlet Temp and pressure drop monitored if the engine is more than 500 HP. 12/20/

33 Controls - Oxidation Catalyst 12/20/

34 Positive Crankcase Ventilation (PCV) System Some exhaust gas escape past piston into crankcase of engines In the past these blow-by gas used to be removed from crankcase as emissions These gases are re-circulated to intake manifold through a valve. Reduces HC by 25% 12/20/

35 Small 100 HP 4SRB- Existing Change oil & filter every 1440 hr. of operation or annually. Inspect spark & plugs every 1440 hr. of operation or annually. Inspect hoses & belts every 1440 hr. or annually which ever comes first. 12/20/

36 Diesel Fuel Requirements: October 1, 2007 Date October 1, 2010 Engines less than 30 litr/cylinder displacement June 2012 Engines with more than 30 lit/cyl. Requirement Low Sulfur Diesel Ultra Low Sulfur Diesel (ULSD) Max sulfur content 15 ppm Minimum cetane index of 40 or max aromatic content of 25 volume% 1000 ppm sulfur diesel 12/20/

37 Owner/Operator Compliance Requirements 2007 model year and later with displacement less than 30 liters/cylinder- Purchase certified engines. ********************** Displacement more than 30 liters/cylinder. Initial performance test. Annual performance test for nonemergency engines. Continuously monitor operating parameters. 12/20/

38 Compliance Requirements Certified engines Install according to mfg. and operate If not operated according to mfg. spec Keep maintenance record Operate with good AP control HP initial performance test More than 500 HP initial performance test and after 8760 hours or three years, whichever comes first 12/20/

39 Compliance Requirements Non-certified engines. - Maintenance plan. - Performance testing, HP initial test, & more than 500 HP initial and 8760 hrs. or three years. - Monitoring and record keeping. 12/20/

40 Air Permits for Engines Permitted facilities list the engines as emission units. A construction permit must be issued for a new engine at a minor or major permitted facility. Engines not qualifying for categorical exemption (Emergency, etc.) must obtain a permit. (Depending upon fuel usage General Permit or Air Construction/Air Operating Permit). All the RICE engines must comply with RICE NESHAP rule 40 CFR 63 Subpart ZZZZ whether they are permitted or not. Don t have to send an initial notification for emergency engines. 12/20/

41 Air Permits for Engines EXEMPT No permit required for RICE Emergency Engines or if fuel does not exceed: This is total for all engines at site 5,400 gallons of Gasoline per year. 64,000 gallons of Diesel fuel per year. 288,000 gallons of Propane per year. 8.8 million standard cubic feet of Natural Gas / year. EMERGENCY ENGINES DO NOT REQUIRE A PERMIT IF OPERATED IN ACCORDANCE WITH RULES. (Except for Title V facilities, where it must be included as part of the Title V operation). 12/20/

42 Air Permits for Engines GENERAL PERMIT (GP) - if fuel does not exceed: 20,000 gallons of Gasoline per year 250,000 gallons of Diesel fuel per year 1.15 million gallons of Propane per year 40 million standard cubic feet of Natural Gas per year ************* General Permits $100 Fee - Reciprocating Internal Combustion Engines (RICE) - Contact: Barbara Friday (D.E.P., Tallahasse, Florida) Air General Permits /20/

43 Air Permits for Engines Above General Permit (GP) Thresholds Over 20,000 gallons of Gasoline per year. Over 250,000 gallons of Diesel fuel per year. Over 1.15 million gallons of Propane per year. Over 40 million standard cubic feet of Natural Gas/year. * An Air Construction permit is required, with fee and Public Notice, then an Air Operating permit is required with a fee. (Unless it is a Title V facility). 12/20/

44 Air Permits for Engines EXEMPTION Documentation The Department does not issue an exemption certificate or document. However, the Department will accept written notifications from an applicant who is using or plans to use a RICE Engine that meets the exemption rules. This notification will be maintained in the Department s database files. 12/20/

45 Contact Florida Department of Environmental Protection 2295 Victoria Avenue, Suite 364 Fort Myers, Florida Carter B. Endsley, P.E. Professional Engineer Air Resources Management * Tel: (239) carter.endsley@dep.state.fl.us 12/20/