Minutes of November 14, 2012 at Littleton/Englewood WWTP In Attendance: Michael Wicklund Tim Grotheer Jerry Raisch Al Baker Nancy Keller Stephanie Fevig Boyd Hansen Mike Bittner Bruce Joslin Martha Hahn Christine Hoefler Jim Dorsch Colleen Young Jim Kendrick Bill Veydovec Dawn Cowell (via GoToMeeting) Jojo La (via GoToMeeting) Ginny Johnson (via GoToMeeting) Shawn Miller (via GoToMeeting) Roy Heald (via GoToMeeting) Paul Ferraro Jeannie Bowser (via GoToMeeting) Monument San. Dst. Centennial Water & San. Dst. Vranesh & Raisch Centennial Water & San. Dst. Pueblo Water & Sanitation Brown & Caldwell Rocky Mountain Water & Sanitation Silverthorne/Dillon JSA City of Northglenn PCWA APCD-SBAP MWRD Greeley Monument Sanitation District Hatch, Mott MacDonald Broomfield Leonard Rice Engineering / Black Hawk / Central City Sanitation District Colorado Springs Utilities Littleton/Englewood IT Security Water & San. Dst. CWWUC CWWUC I. Regulation 3, What Does It Mean for Your Facility?, Christine Hoefler, Air Pollution Control Division Christine gave a review of the changes in Regulation 3, Air Quality Regulations, regarding internal combustion engines. II. Program Planning for 2013, Paul Ferraro Paul reviewed the Elements of the 2013 Program Plan. The revised elements list is attached. Included are those that are to update certain elements. The actual 2012 Annual Schedule for the monthly Council meetings and the 2013 Schedule revised by the Council are also attached. Paul will update the 2013 Program Plan and submit it to the officers for review and comment before emailing to members and then posting on the Council s website. 1
III. IV. Updates: Water Utility Council Next year the Drinking Water Regulations will be revised. Currently, EPA is working on the Coliform Rule. Stormwater No report. Open Discussion No significant items were discussed. Meeting adjourned at 2:40 pm. Next meeting: Wednesday, December 12, 2012 at 1 PM 2
Regulation No. 3 Changes For Internal Combustion Engines Christine Hoefler November 14, 2012
Overview Changes to Regulation No. 3 New Source Performance Standard (NSPS) IIII Conflicts with NSPS IIII 2
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
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
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
Reg. 3 Reporting Levels APEN Reporting Construction Permit Criteria Air Pollutants Attainment (tpy) Non-attainment (tpy) Attainment (tpy) Non-attainment (tpy) VOC 2 1 5 2 PM-10 and PM-2.5 2 1 5 1 TSP 2 1 10 5 CO 2 1 10 5 SO2 2 1 10 5 NOx 2 1 10 5 Lead 100 lb/yr 100 lb/yr 200 lb/yr 200 lb/yr 11/14/2012 6
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
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
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.
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 11/14/2012 10
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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
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 11/14/2012 13
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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
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
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, 2005 17
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 1068.30 (excluding paragraph (2)(ii) of that definition), and is not used to propel a motor vehicle or a vehicle used solely for competition.
Nonroad engines are: Selfpropelled (tractors, bulldozers) 19
Nonroad engines are: Propelled while performing their function 20
Nonroad engines are: Portable or transportable (has wheels, skids, carrying handles, dolly, trailer, or platform) 21
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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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
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
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
Emission Standards Dependent upon: Engine type Emergency Non-emergency Fire pump Model year Cylinder displacement (per cylinder) Horsepower / Kilowatts 27
Fuel Requirements October 1, 2010 15 ppm sulfur diesel (ULSD) for engines <30 liters/cylinder displacement June 1, 2012 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
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
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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Bringing equipment in from outside of Colorado 33
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 11/14/2012 34
Example Diesel Engine 25 horsepower Manufactured 2007 Constructed in Kansas in 2007 Relocated to Colorado in 2012 35
Example HP <11 11 <25 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 25 <50 TIER 2 TIER 4I 50 <75 75 <100 100 <175 175 <300 300 <600 600 <750 750 36
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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References EPA Websites: http://ecfr.gpoaccess.gov http://www.epa.gov/ttn/atw/nsps/cinsps/cins pspg.html Air Division Home Page http://www.colorado.gov/cs/satellite/cdphe- AP/CBON/1251582562056 41
Christine Hoefler Small Business Assistance Program 303-692-3148 christine.hoefler@state.co.us 42