Workshop B Managing Engine Compliance Best Practices for a RICE/ICE Compliance Plan Tuesday, March 22, 2016 9:45 a.m. to 11 a.m.
Biographical Information William J. Bruscino, C.M. Manager of Consulting Services Trinity Consultants 8425 Pulsar Place, Suite 280, Columbus, Ohio 43240 Phone: 614.433.0733 Fax: 614.433.0734 bbruscino@trinityconsultants.com Mr. Bruscino manages air quality permitting and compliance services for industries such as refining, chemical manufacturing upstream and midstream oil and gas, and general manufacturing. His experience includes Title V and PSD permitting in EPA Regions IV, V, and VI as well as compliance assessments and implementation projects. Mr. Bruscino has recently been directing efforts for numerous energy audits required by the Boiler MACT rule as well as general 3 rd party compliance audits throughout the state of Ohio. He has also assisted multiple facilities in establishing Title V and minor source air compliance programs including environmental management information system (EMIS) implementations. Mr. Bruscino currently manages Trinity s Columbus, Ohio office and is a member of the Air & Waste Management Association. He received a Bachelor s degree in chemical engineering from the University of Cincinnati. James W. Sumner, QEP US Region Air Leader Global Operations, Environment, Health & Safety General Electric Company (513) 607-0590 jim.sumner@ge.com Jim Sumner is an air program leader with GE s Global Operations, Environment, Health & Safety team. In this role, Jim supports GE facilities across the US. He has over 37 years experience in the EHS management field including extended environmental and international experience. This includes environmental policy and concepts, permitting, regulatory advocacy, and air, water, and waste management. Prior to joining GE Jim worked for 10 years at the Ohio EPA where he was supervisor for the Air Pollution Control Program within the Southwest District. Jim graduated with honors from Florida Institute of Technology with a Bachelor s Degree in Environmental Science and is certified as a Qualified Environmental Professional (QEP). Professional memberships include the Air & Waste Management Association and the Water Environment Federation. 1
MEC Workshop BB Managing Engine Compliance Focusing on NSPS IIII, NSPS JJJJ and NESHAP ZZZZ ( RICE MACT ) Cincinnati, OH March 22, 2016 Mr. Jim Sumner - GE Mr. William Bruscino - Trinity
Engine Background
Engine Technically, Engine = Motor = a machine designed to convert energy into useful mechanical motion Commonly, Engine = Heat Engine = an engine that combusts (oxidizes) fuel to create heat energy, which is converted to motion C. 1910 single cylinder gasoline engine
EPA s Categorization of Engines = Key Terms Displacement Reciprocating Internal Combustion
Rich v. Lean Burn Rich burn (RB) more fuel, less air Lean burn (LB) less fuel, more air Lower combustion temperature Up to 50:1 A/F ratios for spark ignition engines and 500:1 for diesel engines Flame extinction/ stability issues For Gasoline
EPA Draws a Different Line Some theoretical LB RICE are considered RB by EPA Any engine where the recommended A/F ratio divided by the ideal A/F ratio at full load is less than or equal to 1.1 λ = 1.1, which equates to an A/F ratio of ~16:1 and ~2% excess O 2 For Gasoline λ = 1.1
Federal Engine Regulations Brief Overview
Federal Regulations Our Focus 40 CFR Part 60 Subpart IIII, Standards of Performance for [New] Stationary Compression Ignition Internal Combustion Engines (CI ICE NSPS) 40 CFR Part 60 Subpart JJJJ, Standards of Performance for [New] Stationary Spark Ignition Internal Combustion Engines (SI ICE NSPS) 40 CFR Part 63 Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE NESHAP) Also, Subpart A for each Part
Introduction to QUAD-ZILLA [this] is the most complicated and confusing regulation in the entire suite of EPA NSPS and NESHAPS regulations, bar none. We seriously believe that a viable defense could be mounted against an EPA enforcement action with the simple but true statement, 'Your honor, we honestly could not discern our obligation under the rule in a timely manner. - Public comment submitted in response to EPA s request for public input on improving regulations per Executive Order 13563
Summary of Regulated Engine Pollutants NSPS JJJJ NSPS IIII RICE MACT VOC NO x CO NMHC/HC NO x CO PM Formaldehyde and CO (as surrogates for Total HAPs) Criteria Pollutants HAPs
Federal Regulations Others 40 CFR 89 - New and In-Use Nonroad CI Engines Tiers 1, 2, and 3 40 CFR 1039 - New and In-Use Nonroad CI Engines Tier 4 40 CFR 90 Nonroad SI Engines < 19 kw 40 CFR 1048 New Nonroad SI Engines > 19 kw 40 CFR 1054 New Small Nonroad SI Engines 40 CFR 94 - Marine CI Engines Tier 2 40 CFR 1042 - New and In-use Marine CI Engines Tiers 3 and 4 40 CFR 91 - Marine SI Engines 40 CFR 1045 Marine SI Engines For more information, e.g., history, about Tier standards, http://www.dieselnet.com/standards
Nonroad and Marine Engines
Nonroad and Marine Engines Not subject to IIII, JJJJ, & ZZZZ Marine ICE an integral part of a marine vessel Nonroad (or Non-road ) engine means any ICE that is in or on a piece of equipment that is 1068.30, 89.2, 90, 91, 94, 1039, 1042, 1045, 1048, 1054 self-propelled (may serve other purposes too); or propelled while performing its function; or portable or transportable Designed to be moved, e.g., on wheels or skids, etc. And actually is moved routinely Portability is moot if it remains [in service] at a location (building, structure, facility, or installation) for more than 12 months or for seasonal sources, for the entire season (3 months or more) for at least 2 years Mobile = Onroad + Nonroad + Marine
Temporary Exemption Two Big Caveats 1. Replacing one temporary engine with another to be used for the same purpose does not restart the 12-month clock The 12-month clock applies to the location and purpose, not a particular engine 2. An engine to be used temporarily in place of a stationary engine (e.g., while it is being overhauled) is considered a stationary engine The location and purpose is stationary even if it consists of more than one engine over time
NSPS IIII Standards of Performance for Stationary [New] Compression Ignition Internal Combustion Engines (Original proposal for CI ICE NSPS was in 1979; it was never finalized)
60.4200 NSPS IIII Applicability Potentially applies to: If: All stationary compression-ignition engines Reciprocating, rotary, other (except turbines) Of any size (horsepower rating) Emergency & Non-Emergency Constructed (ORDERED) after 7/11/2005 and manufactured after 4/1/2006 Modified or reconstructed after 7/11/2005
60.4200(b) & (d) Exemptions Engines at test stands National security exemption (upon request) Informal indications are that this is meant for true military purposes Engines manufactured as certified NFPA fire pump engine before 7/1/06 or modified/reconstructed to meet NFPA certification before 7/11/05
NSPS IIII Emission Standards 60.4204 & 4205 Pollutants: NMHC/HC, NO X, NMHC+NO X, CO, PM The rule is modeled after the mobile (nonroad and marine) standards General engine categories: Per-cylinder displacement < 10 L 10 L per-cylinder displacement > 30 L Per-cylinder displacement 30 L Emergency Fire pump
NSPS IIII Emission Standards For displacement < 10 L/cylinder Meet nonroad Tier standards Tiers 1, 2, & 3 in 89.112 Tier 4 in 1039.102 Specific requirements depend on use, model year, displacement, and power Emergency engines are exempt from the most stringent (Tier 4) standards Delayed schedule for fire pump engines 60.4204 & 4205
NSPS IIII Emission Standards For 10 L/cylinder Displacement < 30 L/cylinder Tier standards for marine engines Tier 2 in Part 94; Tiers 3 and 4 in Part 1042 Emergency engines are exempted from most stringent (i.e., Tier 4) standards For Displacement 30 L/cylinder Standards for large marine engines Achievable via the use of SCR & ESP 60.4204 & 4205
60.4208 Import / Install Deadlines Regardless of manufacture date, i.e., so for old engines, certain engines imported or installed after the following dates must meet the emission standards for the previous model year Type / Size Import/Install Deadline Model Year Standards All (excluding fire pump ICE) 12/31/2008 2007 HP < 25 12/31/2009 2008 25 HP < 75 12/31/2014 2013 75 HP < 175 12/31/2013 2012 HP 175 12/31/2012 2011 HP 750 12/31/2016 2015 804 HP < 2680 and 10 Disp. (L) < 30 12/31/2018 2017 * These provisions were added to prevent stockpiling of earlier Tier engines. ** They do not apply to modified or reconstructed or moved (from one plant site to another) engines
NSPS IIII Compliance 60.4211 Requirements Displacement < 30 L/cylinder Purchase certified engine and follow manufacturer instructions or Conduct initial testing (and subsequent testing if > 500 hp) and Develop and follow a maintenance plan If pre-2007 model year, additional options: Test of a similar engine or data from engine manufacturer or control vendor indicating compliance Displacement 30 L/cylinder Testing and control device monitoring
Engine Manufacturer 60.4201 Certifications Engine manufacturers must certify 2007 model year and later engines <30 L/cyl.
60.4207 NSPS IIII Fuel Requirements Cetane is a measure of ignitability of diesel fuel
60.4211(f) Emergency Engines See discussion of definition and operational requirements in MACT ZZZZ section
Useful References Flowcharts EPA Websites NSPS IIII reg, background info, and implementation tools http://www.epa.gov/ttn/atw/icengines/ Summary spreadsheet http://www.epa.gov/region1/rice Reg Navigator http://www.epa.gov/ttn/atw/rice/output/quiz.html Florida DEP spreadsheets www.dep.state.fl.us/air/emission/engine_pump_tools.htm
NSPS JJJJ Standards of Performance for Stationary [New] Spark Ignition Internal Combustion Engines
60.4230 NSPS JJJJ Applicability Potentially applies to: All stationary spark-ignition engines Reciprocating, rotary, other (except turbines) Of any size (horsepower rating) That fires any fuel Emergency & Non-Emergency Exemptions: Engines at test stands National security exemption (upon request)
60.4230, 4236 NSPS JJJJ Applicability Constructed (ORDERED) after 6/12/2006 and manufactured after Type / Size Manufactured Date 500 HP 7/1/2007 except LB 500 HP < 1350 LB 500 HP < 1350 1/1/2008 < 500 hp 7/1/2008 Emergency > 25 hp 1/1/2009 If < 25 hp, no emergency / non emergency differentiation Owners/operators of ICE modified or reconstructed after 6/12/2006
60.4233, 4235, 4244(f) NSPS JJJJ Standards Emission standards for HC/NMHC, NO X, CO, and VOC (excluding CH 2 O) Depends on use, fuel, model year, and power All engines 25 hp All are certified by the manufacturer to standards in 90 or 1054 Engines > 25 hp Purchase voluntarily certified engine (standards in 1048 or Table 1) and follow manufacturer s instructions or Test and develop/follow a maintenance plan Any gasoline must meet 80 ppm sulfur limit (40 CFR 80.195)
60.4236 Import / Install Deadlines Regardless of manufacture date, i.e., so for very old engines, any engines imported or installed after the following dates must meet the emission standards of 60.4233 Type / Size Manufactured Import/Install Date Deadline 500 HP 7/1/2007 7/1/2009 except LB 500 HP < 1350 LB 500 HP < 1350 1/1/2008 7/1/2010 < 500 hp 7/1/2008 7/1/2010 Emergency > 25 hp 1/1/2009 1/1/2011 * These provisions were added to prevent stockpiling of earlier Tier engines. ** They do not apply to modified or reconstructed or moved (from one plant site to another) engines
NSPS JJJJ Requirements Non-Emergency and Emergency ICE Purchase a certified engine Follow mfr. Instructions or maintenance plan Upon loss of certification, initial performance test if 100 hp (within 1 year) and subsequent* performance tests if >500 HP Cannot comply via non-certified options Non-certified Engines Maintenance plan Initial performance test if 25 hp Within 60/180 days Subsequent* performance tests and initial notifications if >500 HP 60.4243 Required for: 25 hp; > 25 hp gasoline; > 25 hp RB LPG Required for: Modified and reconstructed engines * Every 8,760 hours or 3 years, whichever is first
60.4243(d) & 4237 Emergency Engines See discussion of definition and operational requirements in MACT ZZZZ section Certain (depending on power and build date) emergency SI ICE not meeting non-emergency emissions standards must have a nonresettable hour meter: HP 500 HP built on or after 7/1/2010 130 HP < 500 built on or after 1/1/2011 HP < 130 built on or after 7/1/2008 built = manufactured based on reading of preambles
Useful References Flowcharts EPA Website NSPS JJJJ reg, background info, and implementation tools http://www.epa.gov/ttn/atw/icengines/ Summary spreadsheet Reg Navigator http://www.epa.gov/ttn/atw/rice/output/quiz.html Florida DEP spreadsheets www.dep.state.fl.us/air/emission/engine_pump_tools.htm Texas flowchart 102 pages!
NESHAP ZZZZ National Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines a.k.a., the RICE MACT
History of RICE MACT Proposed 12/19/02 Big, major engines; Limits based on catalytic controls; monitoring of T and ΔP Relatively few engines regulated at this point
History of RICE MACT Proposed 6/12/06 Balance of new RICE, nearly all of which comply via NSPS (exception: 4SLB 250-500 hp, which complies with the 2004 rule requirements)
History of RICE MACT Proposed 3/5/09 Balance of existing RICE; mix of management practices and emission limits based on catalytic controls
63.6585 RICE MACT Today Applies to all stationary reciprocating ICE Exemptions: Engines at test stands National security exemption (upon request) Existing, emergency engines at residential, commercial, and institutional area sources that do not operate and are not contractually obligated to be available for more than 15 hr/yr for emergency demand response or voltage or frequency deviations that do not supply power as part of a financial arrangement with another entity What if a headquarters commercial office building is co-located with a manufacturing plant? Informally EPA has said that engines providing backup power to the HQ building are exempt
63.6590(a) Existing v. New Sources Determination based on commence construction date (start of on-site construction, not ordered) What if an engine is relocated to a new facility? Relocation and/or a change in ownership of an existing RICE does not make it new
Potential RICE MACT Requirements Emission limits (CO and CH 2 O) Continuous & monthly monitoring (T and ΔP) Monitoring system evaluations Stack testing (emissions or catalyst activity) Reporting and notifications Management/work practices (maintenance) Hour meter Plans (testing, monitoring, maintenance) Recordkeeping
Overview of Requirements for Existing CI Engines Source Status Use category Rating Emission Limit(s) Control Device Monitor Initial Perform. Test Ongoing Perform. Test Initial Notif./ Comp Reports Work Practices/ Maint. Plan Hour Meter Major Non Emergency > 500 HP Non Emergency 300 500 HP Non Emergency 100 300 HP Non Emergency < 100 HP Emergency 500 HP Emergency > 500 HP No MACT Requirements Limited Use > 500 HP No MACT Requirements Area Limited Use 500 HP No Such Category Limited Use Provisions Only Apply to Existing RICE if > 500 HP Non Emergency > 500 HP Non Emergency 300 500 HP Non Emergency < 300 HP Emergency Any Note: Sometimes it is better to NOT be an emergency engine (same scenario with SI engines too)
Overview of Requirements for New CI Engines Source Status Use category Rating Emission Limit(s) Control Device Monitor Initial Perform. Test Ongoing Perform. Test Initial Notif./ Comp Reports Hour Meter Non Emergency > 500 HP Major Non Emergency 500 HP Comply with NSPS Only Emergency > 500 HP IN only Emergency 500 HP Comply with NSPS Only Limited Use > 500 HP IN only NAbS Limited Use 500 HP Comply with NSPS Only Area ALL ALL Comply with NSPS Only
Overview of Requirements for Existing SI Engines Source Status Major Area Use category ICE Type Rating Emission Limit(s) Control Device Monitor / Engine Shutdown Initial Perform. Test / Cat. Activity Check Ongoing Perform. Test / Cat. Activity Check Initial Notif./ Comp Reports Non Emergency 4SRB > 500 HP Non Emergency 2SLB, 4SLB > 500 HP No MACT Requirements Work Practices/ Maint. Plan Non Emergency Landfill/Digester Gas > 500 HP No MACT Requirements Non Emergency 2SLB, 4SLB, 4SRB 100 500 HP Non Emergency Landfill/Digester Gas 100 500 HP Non Emergency 2SLB, 4SLB, 4SRB < 100 HP Non Emergency Landfill/Digester Gas < 100 HP Emergency Any 500 HP Emergency Any > 500 HP No MACT Requirements Limited Use Any > 500 HP No MACT Requirements Hour Meter Limited Use Any 500 HP No Such Category Limited Use Provisions Only Apply to Existing RICE if > 500 HP Non Emergency 4SLB, 4SRB > 500 HP Non Emergency 4SLB, 4SRB if <24 hrs/yr or remote > 500 HP Non Emergency 4SLB, 4SRB 500 HP Non Emergency 2SLB Any Non Emergency Landfill/Digester Any Emergency Any Any
Overview of Requirements for New SI Engines Source Status Use category ICE Type Rating Major Emission Limit(s) Control Device Monitor Initial Perform. Test / Cat. Activity Check Ongoing Perform. Test / Cat. Activity Check Initial Notif./ Comp Reports Non Emergency 4SRB > 500 HP Non Emergency 2SLB > 500 HP Non Emergency 4SLB > 500 HP Non Emergency 4SLB If manf d 1/1/08 Non Emergency 4SLB If manf d < 1/1/08 250 500 HP No MACT Requirements Non Emergency 4SRB 500 HP Comply with NSPS Only 250 500 HP Non Emergency 2SLB 500 HP Comply with NSPS Only Non Emergency 4SLB < 250 HP Comply with NSPS Only I.N. & Non Emergency Landfill/Digester Gas > 500 HP Fuel usage Non Emergency Landfill/Digester Gas 500 HP Comply with NSPS Only Emergency ALL > 500 HP I.N. only Emergency ALL 500 HP Comply with NSPS Only Emergency 4SLB If manf d 1/1/08 Hour Meter 250 500 HP Limited Use ALL > 500 HP I.N. only NAbS Limited Use ALL 500 HP Comply with NSPS Only Area ALL ALL ALL Comply with NSPS Only
63.6625 & 6640 Work Practice Standards Minimize startup and idling time (30 minutes) Startup means the time from initial start until applied load and engine and associated equipment (including catalyst) reaches steady state or normal operation How do you demonstrate compliance? Log startups, durations? Point to startup procedure?
Tables 1 4, 63.6625(e) Maintenance As Work Practice Develop and follow maintenance plan Or manufacturer s emissions-related instructions Oil & filter changes on specified frequencies Generally, 4320 hrs for 2S; 1440 for 4S; 1000 hrs for CI, and 500 hrs for emergency RICE Optional oil analysis program Inspections of spark plugs, belts, and hoses on specified frequencies Generally, 4320 hrs for 2S; 1440 for 4S; 500 hrs for CI, and 500 or 1000 hrs for emergency RICE Maintenance documentation will be key
63.6625(i) & (j) Oil Analysis Program Parameter Oil analysis must be performed at same frequency specified for oil changes If condemned, change oil within 2 business days Condemning Limits Total Base Number (TBN) CI Total Acid Number (TAN) SI Viscosity < 30% of new oil Increases by more than 3.0 mg of potassium hydroxide per gram from TAN of new oil Changed by more than 20% from the viscosity of new oil %Water Content by Volume > 0.5 % Must keep records of the analysis You can petition EPA for use of alternative parameters But these are fairly generous already Our informal guidance has been that it would also extend the time for the filter change EPA
Maintenance Plan Operations logs Records of startups and idling periods Inspections / checklists Maintenance logs Document control
Engines with NO Requirements Technically, still affected sources At major sources, existing RICE > 500 hp: SI 2SLB SI 4SLB Emergency If it does not operate and is not contractually obligated to be available for more than 15 hr/yr for emergency demand response or voltage or frequency deviations Limited use (LU) Original floor was no control. Will be reconsidered in 8 years Landfill or digester gas (LG/DG) (>10% gross heat input annually) 63.6590(b)(3)
63.6590(b)(1) & (2) Engines Subject To Limited Requirements At major sources, new and reconstructed RICE > 500 hp: Emergency If it does not operate and is not contractually obligated to be available for more than 15 hr/yr for emergency demand response or voltage or frequency deviations Initial notification only Limited use Initial notification only Landfill or digester gas Initial notification and daily fuel monitoring & reporting
A Dilemma for Emergency, Limited Use, Landfill Gas, and Digester Gas Engines With No or Limited Requirements How do you prove that the engine qualifies as emergency or limited use or that it burns the required amount of LG or DG? And does the proof have to be enforceable? Some states, e.g., Arkansas, say yes So you end up being subject to the RICE MACT definition in 63.6640 for emergency or limited use (hours of operation limitations) or the minimum LG/DG usages EPA recognizes the problem but doesn t offer much help
Some Important Definitions Limited Use RICE 63.6675, 6590 Operates 100 hours per year or less Includes routine testing and maintenance The limited use exemptions only apply to the following RICE at major sources Existing, > 500 hp No requirements New/reconstructed, 500 hp Comply with NSPS as applicable New/reconstructed, > 500 hp Initial notification only
Some Important Definitions Emergency RICE 63.6675 The RICE is operated to provide electrical power or mechanical work during an emergency situation Examples: Power generation during normal supply interruptions Pumping water for fire suppression or flood control Operational limitations in 63.6640(f)
Emergency Use Requirements No time limit on emergency operation 100 hrs/yr* of non-emergency operation for: Maintenance checks and readiness testing Emergency demand response (DR) For NERC-declared Energy Emergency Alert Level 2 periods During voltage or frequency deviations of 5% 50 hrs/yr* of the 100 hrs/yr* can be used for Any situation as long as there is no financial arrangement For existing area source emergency RICE, Local reliability 63.6640(f) CAUTION: Local demand response rules vary widely Remanded to EPA by May 1, 2015 D.C. Circuit Court ruling. Some states don t allow some or all of these, e.g., NJ, MD, VA, D.C. * Calendar year basis
Emergency Engine Records & Reporting Non-resettable hour meter Software (e.g., a PLC) is okay if tamper-proof / non-resettable (unofficial determination) Reporting for emergency RICE > 100 HP if Operated or contractually obligated to be available > 15 hours per year in emergency demand response Operated for periods where there is deviation of voltage or frequency 5% Operated for local grid system reliability 63.6650(h) Annual reporting via EPA s Compliance and Emissions Data Reporting Interface beginning for operation during 2015 calendar year (due 3/31/2016)
Is it always worth the hassle? No, for several types of engines, it is easier to comply with non-emergency provisions than with emergency provisions Maintenance requirements only v. maintenance requirements + hours records Major source existing RICE < 100 hp Area source existing CI RICE < 300 hp Area source existing 4S RICE < 500 hp Area source existing 2S RICE Area source existing 4S remote RICE
Useful References Flowcharts EPA HQ Website: NESHAP ZZZZ reg, background info, and implementation tools http://www.epa.gov/ttn/atw/icengines/ Reg. navigation tool Does not cover black start engines or remote/non-remote Q&A documents; memos; cost information; etc. Some states and EPA Regions have RICE sites/tools Often difficult to navigate
Asset, Data, and Task Management
Asset Management Know what you have To track hundreds of engines, O&G companies are using Environmental Management Information Systems (EMIS) Keep track of relocations & replacements Email reminders of due dates
Engine Information To Track Stationary or mobile? Is it at a major or area source facility? What is its power output? Nameplate Site-rated When was it For emission calculations purposes, you may also need the efficiency or fuel consumption rate Manufactured? Ordered? Installed or contracted to be installed on site? Modified and/or reconstructed (if applicable)? Is it for emergencies only? Or is it limited use? Or is it a black start engine? What fuel(s) does it burn? If it is spark ignited, is it 4SRB, 4SLB, or 2SLB?
Example Simple Inventory Facility PRODUCTION POWER ENGINE ENGINE Mfg Order Startup Reconstruct SITE COUNTY Type METHOD 1 SOURCE 2 MAKE / MODEL HP Date Date Date Date 3 Lonesome South comp sta Compression Gas Engine Cat.???? 1800 <1994 <1994 1994? Dove Lonesome South comp sta Compression Gas Engine Cat.???? 1801 <1994 <1994 1994? Dove Lonesome Dove South comp sta Compression Gas Engine Wak.??? 800 <1994 <1994 1994? Hat Creek North gas well Compression Gas Engine Compressco??? 14 <6/13/2003 <6/13/2003 6/13/2003? Hat Creek North gas well Compression Gas Engine Wak.??? 425 <7/31/2003 <7/31/2003 7/31/2003? 1. Production methods: compression, plunger lift, rod pump 2. Power Source: gas engine, electric, diesel engine 3. Reconstruction means more than 50% of the cost of comparable new engine
Information to Track Non-road engines: Date moved to location Date removed from location Rule applicability NSPS JJJJ/IIII, MACT ZZZZ Tier standard Monitoring/testing requirements Engine Certification (link to location)
What About Leased Engines? Treat them as if you own them Some leasing companies have databases that provide all the information you need to determine applicability and maintain compliance But the operator is ultimately responsible to the state and EPA
What About Contractor Engines? Should you include contractor engines in compliance program? Best practices for ensuring compliance: Request that they provide a list of engines they are bringing onsite: Date log - date onsite/offsite Size Fuel type Provide definition of nonroad Ensure engines are not used at one location for more than 12 months
Examples, Case Studies, Interesting Dilemmas, Unresolved Questions and some Guidance
Engine v. Compressor Used to be asked a lot At a natural gas compressor station, a brand new reciprocating compressor is coupled with an old (2001 vintage) but rebuilt engine The compressor is subject to NSPS OOOO (standards for upstream O&G facilities) Rod packing change-out requirements The engine is subject to MACT ZZZZ It could have also triggered NSPS JJJJ if the rebuild had cost more than 50% of a new engine
Stationary Engines Ex. 1 Common in remote areas: An engine used to generate electric power during initial construction until utilities are available at a site Is not a stationary engine if it does not remain on site for more than 12 months Therefore it is not subject to NSPS or MACT May still need to be permitted
Stationary Engines Ex. 2 Examples common in the forest products, metals, and minerals industries. An engine that is routinely (more often than every 12 months) moved from location to location within a facility site e.g., portable welders, chippers, crushers, ladle pushers, water pumps, etc. Is not a stationary engine It is a nonroad engine Therefore it is not subject to NSPS or MACT May still need to be permitted
Stationary Engines Ex. 3 An engine that is temporarily (< 12 months) used in place of a stationary engine that performs the same function as the stationary engine Is considered a stationary engine Review NSPS and MACT applicability! This is clear based on a June 7, 2013 email from Melanie King, but not all companies are adhering to the policy
NSPS Modification Example Bi-fuel technology is retrofitted to a diesel engine New equipment is external to engine itself Injects natural gas into the air intake Increases hourly CO emissions Does this meet NSPS modification definition? Yes, while it is arguably not a physical change to the engine, it is a change in the method of operation, and It increases hourly emissions of an NSPS regulated pollutant What if oxidation catalyst is also installed so that the CO lb/hr emission rate does not increase? The phrase, to the atmosphere has been clarified by EPA guidance to be emissions after reduction by control device Be wary of inconsistency among NSPS-delegated states
Reconstructing on purpose Existing major source 380-hp 4SRB RICE that operates ~200 hrs/yr (so not emergency or limited use) MACT ZZZZ requires continuous T and monthly ΔP monitoring Upon reconstruction, MACT ZZZZ simply points to NSPS JJJJ NSPS JJJJ requires testing but not monitoring
60.8(c), Feb. 2014 email from Melanie King MACT allows 30 minutes for startup. Why doesn t NSPS? Are you out of compliance with NSPS during every startup until the catalyst activates? No, per Melanie King (2/2014), see 60.8(c) nor shall emissions in excess of the level of the applicable emission limit during periods of startup, shutdown, and malfunction be considered a violation...
Certificate of Conformity Expirations and Disclaimers The easiest compliance requirement for many NSPS engines is to purchase a certified engine But these certifications expire And some certificates have a disclaimer that certified emissions are only good for XXX hours of operation Neither document expiration nor operation limitation exceedances results in noncompliance with the NSPS rules The NSPS requirements are to (1) purchase a certified engine and (2) operate and maintain it according to manufacturer instructions See RTC for July 11, 2005 proposed IIII rule
The Flex Program for Stationary RICE? Some manufacturers are claiming that you can comply with NSPS IIII for stationary RICE by purchasing engines built under the flex program (1039.625(e)(2)) Lower standards for nonroad engines Do not fall for it EPA says flex engines are not allowed for stationary applications (12/1/14 email from M. King)
Backup Stormwater Pumps A facility uses pumps during heavy rains to prevent flooding Are the pump engines emergency units? EPA says no or, at least the operation counts towards the 50 hours limitation Same determination for other emergency anticipation/prevention situations Engines use to rotate horizontal lime kilns during power outages
Planned Outage Emergency Unintended Consequences A power generation facility planned a 3-day (72-hour) outage to comply with new NERC standards (switchyard maint.) Power for critical systems needed to come from engines Existing, on-site emergency engines could accommodate the need, but 72 hours of operation in a single year would make them non-emergency forever? EPA was asked for a variance no such luck; their solution is to bring in portable engines which is likely worse for the environment Potentially higher emitting design Extra fuel storage and transportation
What If An Emergency Engine Operates More Than The Allowable Non-Emergency Hours? Based on EPA s Q&A document, it is then a non-emergency engine Based on EPA s RTC 10.2.1 published with the 2013 rule amendments, case-bycase
Status Change: Area to Major In general, a site that changes from an area source to a major source has three years to comply with the major source requirements However, if the site status change coincides with the installation of a new engine (or engines), then compliance is required immediately (180-day demonstration period) 63.6595(b)(1)
Status Change: Major to Area A major source gas plant experienced a fire and had to replace all their engines As a result the site s emissions were going to be less than 10/25 tpy Are the new engines subject to major source or area source requirements?... The unofficial consensus was that as long as a federally enforceable limit of <10/25 was in place before commencement of construction of the engines, then comply with area source rule
Real-life QUAD-ZILLA gap engine? CI RICE at area source Ordered on June 1, 2012 Manufactured on March 1, 2005 Contracted for on-site installation on July 1, 2012 Engine is a new RICE MACT source since it was constructed (on-site) after June 12, 2006 RICE MACT requires compliance with NSPS IIII, as applicable NSPS IIII does not apply Ordered after July 11, 2005, but Manufactured prior to April 1, 2006 81
Questions?