U.S. EPA and State Perspectives on Clean Air Act Rules for Stationary/Emergency Engines

Transcription

1 U.S. EPA and State Perspectives on Clean Air Act Rules for Stationary/Emergency Engines Presenters: Melanie King, Energy Strategies Group, Sector Policies and Programs Division, Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency Gary L. Saunders, Special Projects Engineer, Division of Air Quality, Stationary Source Compliance Branch, North Carolina Department of Environmental Quality May 24, :00pm ET

2 The Association of Air Pollution Control Agencies (or AAPCA) is a consensusdriven organization focused on assisting state and local air quality agencies and personnel with implementation and technical issues associated with the federal Clean Air Act. AAPCA s members work collaboratively on behalf of states and the communities they protect to act as a conduit for and provide feedback to federal regulators on air quality rules that have significant impacts across the entire nation. Eighteen state environmental agencies currently sit on AAPCA s Board. They are housed in Lexington, Kentucky as an affiliated association of the Council of State Governments. More information about AAPCA may be found by visiting NASFA is the National Association of State Facilities Administrators and is an association dedicated exclusively to the state facilities professional and the unique challenges they face. Our members are responsible for the planning, development, operations and maintenance of state facilities and infrastructure. For more information about NASFA visit

3 EPA s Air Quality Regulations for Stationary Engines Melanie King U.S. Environmental Protection Agency May 24, 2016

4 These Regulations Do Not Apply to: Engines used in motor vehicles and mobile nonroad equipment: Mobile nonroad engines are: Self-propelled (tractors, bulldozers) Propelled while performing their function (lawnmowers) Portable or transportable (has wheels, skids, carrying handles, dolly, trailer, or platform) Portable nonroad becomes stationary if it stays in one location for more than 12 months, or full annual operating period if seasonal source VS. 4

5 Key Terms RICE: Reciprocating Internal Combustion Engine NESHAP: National Emission Standards for Hazardous Air Pollutants HAP: hazardous air pollutant Major source: 10 tons/year single HAP or 25 tons/year total HAP Area source: not major source NSPS: New Source Performance Standards Compression ignition: Generally includes diesel, and dual fuel where diesel is >2% annually Spark ignition: Generally includes natural gas, gasoline, propane, landfill gas, digester gas Rich burn: operating air/fuel ratio divided by stoichiometric 1.1 Lean burn: anything not meeting rich burn definition 2-stroke: power cycle completed in single crankshaft revolution 4-stroke: power cycle completed in two crankshaft revolutions 5

6 EPA s Stationary Engine Regulations Stationary RICE NESHAP 40 CFR part 63 subpart ZZZZ Applies to existing and new stationary compression ignition (CI) and spark ignition (SI) engines NSPS for Stationary CI Internal Combustion Engines 40 CFR part 60 subpart IIII Applies to stationary CI engines: Ordered after July 11, 2005 and manufactured after April 1, 2006 Modified or reconstructed after July 11, 2005 NSPS for Stationary SI Internal Combustion Engines 40 CFR part 60 subpart JJJJ Applies to stationary SI engines: Ordered after June 12, 2006 and manufactured on/after July 1, 2007 if 500 HP (except lean burn 500 HP<1,350) January 1, 2008 if lean burn 500 HP<1,350 July 1, 2008 if <500 HP and not emergency >25 HP January 1, 2009 if emergency >25 HP Modified or reconstructed after June 12,

7 General Subcategorization Approach Non-Emergency Compression Ignition (CI) Landfill/Digester Gas Emergency Stationary RICE Spark Ignition (SI) Non-Emergency Lean Burn Non-Emergency 4-Stroke Rich Burn Landfill/Digester Gas 2-Stroke 4-Stroke Emergency 7

8 What is an Emergency Engine?... operated to provide electrical power or mechanical work during an emergency situation. Examples include stationary RICE used to produce power for critical networks or equipment... when electric power from the local utility... is interrupted, or stationary RICE used to pump water in the case of fire or flood, etc. Operates in non-emergency situations only as specified in the regulations 8

9 Emergency Engine Operational Limitations Unlimited use for emergencies (e.g., power outage, fire, flood) 100 hr/yr for engine maintenance/testing 50 hr/yr of the 100 hr/yr maintenance/testing allocation can be used for: Non-emergency situations if no financial arrangement Maintaining local reliability as part of a financial arrangement with another entity if: existing RICE at area source (NESHAP limitation only) engine is dispatched by local transmission/distribution system operator dispatch intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads dispatch follows reliability, emergency operation, or similar protocols that follow specific NERC, regional, state, public utility commission, or local standards or guidelines power provided only to facility or to support local distribution system owner/operator identifies and records dispatch and standard that is being followed 9

10 RICE NESHAP/NSPS Vacatur On May 1, 2015, the D.C. Circuit Court vacated the RICE NESHAP and NSPS provisions allowing emergency engines to operate up to 100 hours/year for emergency demand response (EDR) and voltage/frequency deviations Vacatur took effect on May 4, 2016 After the vacatur, engines operating for EDR and voltage/frequency deviations must comply with the standards for non-emergency engines Guidance: pdf EPA requested and received a voluntary remand of the provision allowing emergency engines to operate in a financial arrangement for up to 50 hours/year to maintain local reliability 10

11 Stationary RICE NESHAP Background

12 RICE NESHAP Background Regulates HAP emissions from stationary RICE at both major and area sources of HAP All sizes of engines are covered Only stationary engines not subject: existing emergency engines located at residential, institutional, or commercial area sources and not used to supply power in a financial arrangement to maintain local reliability 12

13 Existing vs. New Construction commenced before: >500 HP at major source Existing December 19, 2002 New 500 HP at major source, and all HP at area source Existing June 12, 2006 New Determining construction date: owner/operator has entered into a contractual obligation to undertake and complete, within a reasonable amount of time, a continuous program for the on-site installation of the engine Does not include moving an engine to a new location 13

14 Stationary RICENESHAP Requirements for Emergency RICE at Area Sources of HAP 14

15 Compliance Requirements: Emergency Engines at Area Sources Existing engine: Change oil/filter & inspect hoses/ belts every 500 hours or annually; inspect air cleaner (CI) or spark plugs (SI) every 1,000 hours or annually May use oil analysis program Operate/maintain per manufacturer s instructions or owner-developed maintenance plan If >100 HP and displacement <30 liters/cylinder, and operates in a financial arrangement to maintain local reliability, use ultra low sulfur diesel (ULSD) fuel Non-resettable hour meter Records of hours of operation and maintenance Initial notifications NOT required New engine: Meet Stationary Engine NSPS part 60 subpart IIII if CI; part 60 subpart JJJJ if SI 15

16 Reporting Requirement for Emergency Engines Requirement applies to emergency RICE >100 HP that are operated in a financial arrangement to maintain local reliability (up to 50 hr/yr) Beginning with 2015 operation, report electronically by March 31 of following year: Facility name/address Engine rating, model year, lat/long Date, start time, end time for operation for local reliability Entity that dispatched engine for local reliability and situation that necessitated dispatch Deviations from fuel requirement Submit report electronically through the Compliance and Emissions Data Reporting Interface Accessed through EPA s Central Data Exchange at 16

17 Stationary RICE NESHAP Requirements for Non-Emergency RICE at Area Sources of HAP 17

18 Emission Standards: Existing Non-Emergency RICE at Area Sources HP Engine Subcategory Non-emergency Compression Ignition Spark Ignition 2SLB Spark Ignition 4S in remote areas Spark Ignition 4S not in remote areas SI LFG/DG 300 Change oil/filter & inspect air cleaner every 1,000 hours or annually; inspect hoses/belts every 500 hours or annually Change oil/filter, inspect spark plugs, & inspect hoses/ belts every 4,320 hours or annually Change oil/ filter, inspect spark plugs, & inspect hoses/belts every 1,440 hours of operation or annually Change oil/ filter, inspect spark plugs, & inspect hoses/ belts every 1,440 hours of operation or annually ppm CO or 70% CO reduction > ppm CO or 70% CO reduction Change oil/ filter, inspect spark plugs, & inspect hoses/belts every 2,160 hours of operation or annually If engine used >24 hrs/yr: 4SLB: Install oxidation catalyst 4SRB: Install NSCR New Non-Emergency RICE Located at Area Sources: meet Stationary Engine NSPS part 60 subpart IIII if CI; part 60 subpart JJJJ if SI 18

19 Compliance Requirements: Non-Emergency Engines at Area Sources Engine Subcategory Existing non-emergency CI >300 HP at area source Existing non-emergency SI 4SLB/4SRB >500 HP at area source used >24 hours/year and not in remote area Compliance Requirements Initial emission performance test Subsequent performance testing every 8,760 hours of operation or 3 years for engines >500 HP (5 years if limited use) Operating limitations - catalyst pressure drop and inlet temperature for engines >500 HP Notifications Semiannual compliance reports (annual if limited use) ULSD Crankcase emission control requirements Initial and annual catalyst activity checks High temperature engine shutdown or continuously monitor catalyst inlet temperature Notifications Semiannual compliance reports 19

20 Compliance Requirements: Non-Emergency Engines at Area Sources Engine Subcategory Existing non-emergency: black start at area source CI 300 HP at area source SI 500 HP at area source SI 2SLB >500 HP at area source SI LFG/DG >500 HP at area source SI 4SLB/4SRB >500 HP at area source used 24 hours/year or in remote area Compliance Requirements Operate/maintain engine & control device per manufacturer s instructions or owner-developed maintenance plan May use oil analysis program instead of prescribed oil change frequency Keep records of maintenance Notifications not required 20

21 Stationary RICE NESHAP Requirements for RICE at Major Sources of HAP 21

22 Emission Standards: Existing RICE at Major Sources HP Engine Subcategory Non-emergency CI SI 2SLB SI 4SLB SI 4SRB SI LFG/DG Emergency <100 Change oil and filter and inspect air cleaner (CI) or spark plugs (SI) every 1,000 hours of operation or annually; inspect hoses and belts every 500 hours of operation or annually ppm CO 225 ppm CO 47 ppm CO 10.3 ppm CH 2 O ppm CO or 70% CO reduction > ppm CO or 70% CO reduction No standards No standards 350 ppb CH 2 O or 76% CH 2 O reduction 177 ppm CO No standards Change oil/filter & inspect hoses/belts every 500 hours or annually; inspect air cleaner (CI) or spark plugs (SI) every 1,000 hours or annually No standards Note: Existing limited use engines >500 HP at major sources do not have to meet any emission standards. Existing black start engines 500 HP at major sources must meet work practice standards. 22

23 Emission Standards New RICE at Major Sources HP Engine Subcategory Non-emergency CI SI 2SLB SI 4SLB SI 4SRB SI LFG/DG Emergency <250 Comply with CI NSPS > ppb CH 2 O or 70% CO reduction Comply with SI NSPS 12 ppm CH 2 O or 58% CO reduction Comply with SI NSPS 14 ppm CH 2 O or 93% CO reduction Comply with SI NSPS 350 ppb CH 2 O or 76% CH 2 O reduction Comply with SI NSPS No standards Comply with CI/SI NSPS No standards Note: New limited use engines >500 HP at major sources do not have to meet any emission standards under the NESHAP. 23

24 Compliance Requirements: RICE at Major Sources Engine Subcategory Existing non-emergency: CI 100 HP at major source SI HP at major source Compliance Requirements Initial emission performance test Subsequent performance testing every 8,760 hours of operation or 3 years for engines >500 HP (5 years if limited use) Operating limitations - catalyst pressure drop and inlet temperature for engines >500 HP Notifications Semiannual compliance reports (annual if limited use) Existing non-emergency CI >300 HP: ULSD Crankcase emission control requirements 24

25 Compliance Requirements: RICE at Major Sources Engine Subcategory Existing non-emergency: SI 4SRB >500 HP at major source New non-emergency: SI 2SLB >500 HP at major source SI 4SLB >250 HP at major source SI 4SRB >500 HP at major source CI>500 HP at major source New emergency/limited use >500 HP at major source New non-emergency LFG/DG >500 HP at major source Compliance Requirements Initial emission performance test Subsequent performance testing semiannually (can reduce frequency to annual)* Operating limitations - catalyst pressure drop and inlet temperature Notifications Semiannual compliance reports Initial notification Reporting and ULSD for emergency engines used for local reliability Initial notification Monitor/record fuel usage daily Annual report of fuel usage *Subsequent testing required for 4SRB engine complying with formaldehyde % reduction standard only if engine is 5,000 HP 25

26 Compliance Requirements: RICE at Major Sources Engine Subcategory Existing emergency/black start 500 HP at major source Existing non-emergency <100 HP at major source Compliance Requirements Operate/maintain engine & control device per manufacturer s instructions or owner-developed maintenance plan May use oil analysis program instead of prescribed oil change frequency Emergency engines must have hour meter and record hours of operation Keep records of maintenance Notifications not required Reporting and ULSD for emergency engines >100 HP used for local reliability 26

27 Stationary Compression Ignition Internal Combustion Engine NSPS

28 CI ICE NSPS Applicability 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, 2005 Modification: physical or operational change resulting in an increase in the emission rate of a regulated pollutant Reconstruction: replacement of components of an existing engine where the fixed capital cost of the new components exceeds 50 percent of the fixed capital cost of a comparable entirely new engine, and it is technologically and economically feasible to meet the applicable standards 28

29 Engine Manufacturer Compliance Requirements Engine manufacturers must certify 2007 model year and later engines with a displacement <30 liters/cylinder Certification = EPA Certificate of Conformity 29

30 Owner/Operator Compliance Requirements 2007 model year and later* Purchase certified engine Emission standards for NOx, CO, PM, HC; generally equivalent to Tier standards for nonroad engines Install, configure, operate and maintain engine per manufacturer s instructions or manufacturer-approved procedures Owner/operator performance testing not required If operate differently than manufacturer s recommendations, must do performance test to show compliance Use ULSD *For CI fire pump engine, model year and later (depending on engine size) 30

31 Monitoring/Recordkeeping/Reporting Engine Type Emergency Engines Equipped with diesel particulate filter (DPF) Non-emergency >3,000 HP or with displacement >10 liters/cylinder Requirement Non-resettable hour meter and records of operation Annual reporting if used for local reliability Backpressure monitor and records of corrective actions Submit initial notification Keep records of notifications and engine maintenance If certified, keep records of documentation of engine certification If not certified, keep records of compliance demonstrations 31

32 Stationary Spark Ignition Internal Combustion Engine NSPS

33 SI ICE NSPS Applicability SI engines constructed (ordered) after June 12, 2006 and Manufactured On/After July 1, 2007 Engine Type 500 HP (except lean burn 500 HP<1,350) January 1, 2008 July 1, 2008 January 1, 2009 Lean burn 500 HP<1,350 <500 HP and not emergency >25 HP Emergency >25 HP Modified/reconstructed after June 12, 2006 Note: engine manufacturers must certify stationary SI engines 25 HP and engines >25 HP that are gasoline or rich burn LPG 33

34 Emission Standards (In General) Engine 25 HP (all engines) Non-emergency gasoline and rich burn LPG Non-emergency natural gas and lean burn LPG 25<HP< HP and not gasoline or rich burn LPG Standards HC, CO, NOx standards for new nonroad SI engines in part 90 or part 1054 HC, CO, NOx standards for new nonroad SI engines in part 1048 HC, CO, NOx standards for new nonroad SI engines in part 1048 (or other options) VOC, CO, NOx standards in Table 1 of subpart JJJJ, part 1048 standards for some engines Owners/operators of gasoline engines must use gasoline that meets the sulfur limit in 40 CFR cap of 80 ppm 34

35 Compliance Requirements for Owners/Operators Certified engines Install, configure, operate and maintain engine according to manufacturer s instructions If you do not operate/maintain according to manufacturer s instructions: keep maintenance plan and maintenance records operate consistent with good air pollution control practices 100 HP 500 initial performance test >500 HP initial performance test and subsequent every 8,760 hours or 3 years, whichever is first Non-certified engines: Maintenance plan Performance testing 25<HP 500 initial test >500 HP - initial test and subsequent every 8,760 hours or 3 years, whichever is first Conduct within 10% of peak (or highest achievable) load 35

36 Monitoring/Recordkeeping/Reporting Non-resettable hour meter and records of operation for emergency engines Annual reporting if emergency engine used for local reliability Documentation of certification Records of engine maintenance Initial notification for non-certified engines >500 HP Results of performance testing within 60 days of test 36

37 Compliance Tools EPA s RICE website: Electronic Code of Federal Regulations: EPA Regional Office RICE contacts: ontacts pdf 37

38 U.S. EPA and State Perspectives on Clean Air Act Rules for Stationary/Emergency Engines A State Perspective Presented by Gary L. Saunders

39 NC s Approach Prior to 2010 (Background) NC DAQ consists of 7 Regional Offices and the Central Office Three local programs NC is setup for automatic adoption/delegation of most NSPS (40 CFR 60), NESHAPs (40 CFR 61) and NESHAPS MACT/GACT (40 CFR 63) RICE rules promulgated under the NESHAPs, 40 CFR 63, 4Z (June 15, 2004) for affected engines at major sources of HAPS AND rules promulgated under the NSPS, 40 CFR 60 Subpart 4I and 4J (January 18, 2008) were largely treated by DAQ as permitting exercises.

40 NC s Approach Prior to 2010 (cont d) Title V permits (Central Office) for the affected facilities under 4Z, 4I, and 4J. Small and synthetic minor (area) source permits issued by Regional Offices (4I and 4J). NC included permit exemption rules based upon size (hp or KWh) /usage (hours, fuel use) Net effect: not all affected engines under the rules were required to have a permit even though they were required to comply with the requirements (still true today)

41 NC s Approach After 2010 Promulgation of revised 4Z rules greatly increased the number of affected engines NC DAQ considered returning the delegation of these revised 4Z rules to EPA Our Planning Section (and MACT Taskforce) made an initial assessment of the rule changes Developed an implementation team to look at the affected regulatory community in more detail and to propose alternatives to management

42 NC s Approach After 2010 (cont d) Implementation team composed of representatives from the Regional Office staff and Central Office staff. Central Office staff included the chairs of three internal workgroups: MACT Taskforce Permit Workgroup Compliance Workgroup This implementation team concept has been used in more recent rule changes

43 NC s Approach After 2010 (cont d) Define the affected community and the magnitude of the rule s impact: Permitted facilities We had a basic inventory of engines sources at our permitted facilities Approximately 2300 engines Most were existing CI engines Most were used exclusively as emergency engines A small minority of engines used as non-emergency peak-shavers at industrial facilities A small minority of SI engines burning NG Permit-exempt facilities No direct NC DAQ contact even though the rules applied. These were the challenge.

44 NC s Approach After 2010 (cont d) NC DAQ had a process for development of model permit conditions and language Develop language for each engine size/classification Easiest to change permits for our small and synthetic minor permits (attachment to permit) Insert placeholder language into Title V permits as they were opened Management chose to keep delegation and use a compliance assistance outreach program to assist both permitted and permit exempt facilities. As permits are opened and/or renewed, NC DAQ is refining the permit language

45 Permit Exempt Facilities Initially identified approximately 100 non-emergency, peak-shaver facilities that were covered and required testing, recordkeeping and reporting Examples: Grocery stores Retail stores Local government operations (e.g., schools, police, fire stations and emergency operations) Co-located engines Issue: Who is the owner/operator? Issue: Identification of co-located engines associated with grid access and leasable space

46 4Z Rule Changes in 2013 (Non-emergency) May 3, 2013 compliance date and the rule proposal and ultimate promulgation date caused uncertainty for both state program and the regulated community NC DAQ received approximately 100 extension requests under 4Z for existing engines and retrofitting controls to existing non-emergency peakshavers. Approximately one-third held permits from DAQ Granted all but one. All extensions expired as of May 3, 2014 Issues associated with DOC availability, installation and testing (later)

47 Other RICE Issues Issues: Emergency demand response program (worked w/ SC DEHC and EPA on permit language). Largely eliminated by the Delaware v. EPA vacatur. What load should be used for engine testing? If a load bank is required, what type? Purely resistive or resistive/inductance? Multiple engine tests for different seasonal conditions (mostly a pressure drop issue) Multiple identical engines and testing. Pressure drop sensor issues (and alarms)

48 Hog Farm Digester Gas Project

49 Engines (Digester Gas)

50 Testing of Engines (LFG)

51 More Engine Testing (LFG)

52 Other RICE Issues (Cont d) Small number of engines classified as new under 4Z w/o any NSPS requirements Non-emergency engines (peak-shavers) used under strictly emergency conditions (with low load/demand) Misunderstanding (users) that most SI engines under 4J may have a performance guarantee but that is not a certified engine (voluntary certification) LFG engines and formaldehyde (Title III Major Source Thresholds) LFG engines and rebuild cycles

53 Emergency Demand Response Vacatur NC DAQ outreach/resource to known or possible facilities participating in emergency demand response program Switch of status (applicability) from emergency to non-emergency Case-by-case determination: Existing engines need retrofit (DOC) New, certified CI engines (certified for non-emergency use) can continue in program but must meet all the requirements for non-emergency use CI engines certified for emergency use lose both their emergency status and their treatment by DAQ as certified engines. Most CI emergency engines appear to have dropped out of the emergency demand response program (it is a matter of economics) Non-certified SI engines that stay in the program are treated as non-emergency engines

54 Continued Compliance Assistance Regional Office Resource Contacts Central Office Resource Contact Gary Saunders Special Projects Engineer NC DAQ, Stationary Source Compliance Branch 1641 Mail Service Center Raleigh, NC (919)

55 Presenter Contact Information NC DEQ Gary Saunders Special Projects Engineer NC DAQ, Stationary Source Compliance Branch 1641 Mail Service Center Raleigh, NC Phone: (919) US EPA Melanie King Energy Strategies Group Sector Policies and Programs Division Office of Air Quality Planning and Standards Office of Air and Radiation Phone: (919) Division of Air Quality