RICE NESHAP Frequently Asked Questions (FAQ) What does RICE NESHAP mean? RICE NESHAP is an acronym for Reciprocating Internal Combustion Engines National Emission Standards for Hazardous Air Pollutants. In February 2010 the Environmental Protection Agency (EPA) officially made the RICE NESHAP ruling for compression ignition engines. The official EPA ruling for spark ignition engines was announced in August 2010. These rules are intended to reduce emissions of hazardous air pollutants (HAP) from previously unregulated engines. What is the difference between NSPS and RICE NESHAP? NESHAP for Stationary Reciprocating Internal Combustion Engines (RICE) o 40 CFR part 63 subpart ZZZZ o Applies to existing, new and reconstructed stationary CI and SI engines o Focus is on air toxics (30 HAPs) NSPS (New Source Performance Standards) for Internal Combustion Engines (ICE) o Stationary Compression Ignition (CI) ICE 40 CFR part 60 subpart IIII o Stationary Spark Ignition (SI) ICE 40 CFR part 60 subpart JJJJ o Applies to new, modified and reconstructed stationary CI and SI engines o Focus is on criteria pollutants (CO, NOx, and SOx) What are the requirements of the ruling? The affected stationary compression ignition diesel engines must comply with CO emission limits or must be fitted with emission controls, such as diesel oxidation catalysts, to reduce CO emissions by 70%. The rule also requires the use of Ultra-Low Sulfur Diesel (ULSD) fuel for stationary non-emergency engines greater than 300 HP with a displacement of less than 30 liters per cylinder. The regulation will be fully implemented by May 2013. The new regulations include provisions affecting work practices, metallic HAP emissions, operating limits, start-up requirements, regulation compliance and reporting of test results. The new regulations do not mandate a specific emission control technology but the EPA designed the standards based on the capabilities of current oxidation catalysts (OCs). When do I need to retrofit my engine with an emission control product to meet the requirements? May 3rd, 2013 (CI) and October 19th, 2013 (SI)
Who is affected by the RICE NESHAP ruling? This ruling affects existing stationary diesel engines in the following categories: Engines used at "Area sources" of HAP and constructed or reconstructed before June 12, 2006; Engines used at "Major sources" of HAP, have a site rating of less than or equal to 500 hp, and constructed or reconstructed before June 12, 2006; Engines used at "Major sources" of HAP for non-emergency purposes, have a site rating of greater than 500 hp, and constructed or reconstructed before December 19, 2002. If not in a non-attainment zone, is RICE NESHAP still in effect? Non-attainment zones have no bearing on this ruling. Each diesel and Natural Gas engine in the US is affected by this rule one way or another. The Area source and Major source categories are determined by that engine's specific pollutant output, in this case Carbon Monoxide. How is a major source of emissions defined? Major sources of air toxins are defined as those that emit or have the potential to emit 10 tons per year of a single hazardous air pollutant (HAP) or 25 tons (total) per year of multiple HAPs. How is an Area source of emissions defined? Area sources are those that are not classified as major sources. Will Crankcase Vent Systems be required? Non-Emergency CI engines > 300 HP located at major and area sources must install a closed or open crankcase vent filtration system if one has not previously been installed.
What levels of emission control must be achieved through RICE NESHAP? For CI Engines at a Major source: For CI Engines at an Area source: For SI Engines at a Major source: For SI Engines at an Area source: What emission control products are offered to meet RICE NESHAP requirements? Diesel oxidation catalysts (DOC) are recommended to meet the new emission regulations. Diesel particulate filtration (DPF) is also offered. For engines greater than 500 HP a continuous parametric monitoring system (CPMS) is required to satisfy monitoring of pressure drop across catalyst and temperature at catalyst. The pressure drop across the catalyst cannot exceed 2 H2O from the initial performance test and temperature at the catalyst must remain between 450 F and 1350 F to ensure an efficient catalytic reaction.
What levels of emission control can be offered with a Diesel Oxidation Catalyst (DOC)? Diesel oxidation catalysts are capable of reduction carbon monoxide (CO) emissions by 90%, hydrocarbon (HC) emissions by 80% and particulate matter (PM) emissions by 20%. The EPA is requiring a 70% reduction of CO emissions for the new ruling. How can I determine if my engine needs to comply with the ruling? To determine the HAP requirements for your specific engine, you must know the following information: Horsepower, operating hours per year, and if you have an Area or Major source of emissions. To determine what category your engine falls under refer to the Applicability Application in our RICE NESHAP Library and work with your regulator. Are there different rulings for natural gas engines versus diesel engines? The ruling made on February 17th 2010 only applies to diesel (CI) internal combustion engines. The EPA made a ruling on existing natural gas (SI) engines in August 2010. Are emergency engines affected by RICE NESHAP? Yes. Emergency engines are affected by the current ruling made by the EPA, but have different requirements than non-emergency engines. How is an "emergency" engine defined? An emergency engine is one that is operated for emergency purposes only such as during a power outage or conditioned power event. Maintenance and testing of the engine is limited to 100 hours per year. The engine is allowed to operate for nonemergency purposes for 50 hours per year, but these 50 hours are counted towards the total 100 hours provided for operation other than true emergencies. The 50 hours per year cannot be used to generate income. Use is unlimited in emergency situations. Note: The most recent proposed Amendment to RICE NESHAP states that the 100 hours will be available to use as needed for monitoring and testing, demand response for Energy Emergency Alert Level 2 Situations, and responding to at least a 5% or more change in voltage. Note: It is recommended that you work closely with the local and federal regulator to make final determination on whether or not an engine is classified as emergency or non-emergency to ensure compliance. How is a "non-emergency" engine defined? A non-emergency engine is any engine not defined as an emergency engine.
My facility has a backup generator; will I be impacted by RICE NESHAP? Are you receiving financial gain the use of the engine/generator? If you participate in any utility program; peak shaving, interruptible, demand management, etc Your answer is likely Yes and your engine is likely to be classified as Non- Emergency. What pollutants are regulated through RICE NESHAP? How are HAP emissions measured? Because CO has many measurement advantages over HAP, CO is used as the surrogate for HAP emissions from CI engines. Using a relationship determined by the EPA, HAP emission reduction is determined from CO emission reduction instead of individually measuring the 30 urban HAP. Do I need to do testing or monitoring on my engine after it is retrofit with an emission control device? Non-emergency CI Engines between 300 and 500 HP at either an Area or Major source: An initial performance test is required to demonstrate that emission standards are achieved using a Diesel Oxidation Catalyst. Non-emergency SI Engines between 100 and 500 HP at a Major source: An initial performance test is required to demonstrate that emission standards are achieved using an Oxidation Catalyst or NSCR catalyst.
Non-emergency CI and SI Engines greater than 500 HP located at an Area source: Testing depends on the use of your engine. For "Not Limited Use Engines", you must perform an initial performance test and re-test every 8,760 hours of operation or 3 years, whichever comes first. You must also continuously monitor and record the catalyst inlet temperature, and perform monthly monitoring of the pressure drop across the catalyst. For "Limited Use Engines", you must perform an initial performance test and retest every 8,760 hours of operation or 5 years, whichever comes first. You must also continuously monitor and record the catalyst inlet temperature, and perform monthly monitoring of the pressure drop across the catalyst. For non-emergency engines greater than 500 HP located at a Major source: You must perform an initial performance test, and re-test every 8,760 hours of operation or 5 years, whichever comes first. You must also continuously monitor and record the catalyst inlet temperature, and perform monthly monitoring of the pressure drop across the catalyst. When do I need to perform the initial performance test? This can be completed prior to the compliance date but isn t due until 180 days after the compliance date. Notification needs to be provided to the local and federal regulator at least 60 days prior to performing the initial performance test, as well as for subsequent performance tests. A compliance status notification is due within 60 days after the performance test to the regulator. Is there a site specific monitoring and maintenance plan that I need to create? Yes, you must develop a site-specific monitoring plan that addresses the following areas: Installation of CPMS sampling probe at appropriate location to give representative measurements Performance and equipment specifications for the CPMS Performance evaluation procedures and acceptance criteria for the CPMS (Calibration methods). Ongoing operation and maintenance procedures for the engine, emission control system, and crankcase vent filtration system (if applicable). Ongoing recordkeeping and reporting procedures. Conduct a performance evaluation for each CPMS in accordance with the sitespecific plan. Operate and maintain the CPMS in continuous operation according the sitespecific plan.
What are the reporting requirements? Reports are required to be submitted semiannually to your local and federal regulator for engines that are not limited use engines. Information contained within these reports includes: A copy of each notification and report that you submitted to comply with RICE NESHAP. Records showing compliance with emissions and operating limitations. If there are no deviations in emissions or operating limitations, a statement that there were no deviations during the reporting period. Records of any occurrence and duration of malfunction of operation as well as actions taken during the malfunction. If there were no malfunctions or deviations in the Emissions Control and Monitoring systems, a statement that there were no deviations during the reporting period. Records of performance tests. Records of all required maintenance performed on the Emissions Control and Monitoring Equipment. If Emergency Records of hourly usage from the non-resettable hour meter. Documentation must be provided on how many hours are spent for emergency operation and non-emergency operation. Complete guidance on reporting requirements are contained within 63.6655 as there are additional situational specific requirements. How long do I need to keep these reports? Five years following the date of each submittal. Are there state requirements that I have to follow as well? It s likely that you will be required to obtain a state specific Air Permit and follow all requirements for record keeping, emissions limitations, and reporting found within this permit. State and Federal RICE contacts are provided within the GT Exhaust RICE NESHAP Library; Scroll down to EPA Contacts and Fact Sheets. Is a monitoring device (CPMS) required to comply with RICE NESHAP? Catalyst inlet temperature on non-emergency CI and SI RICE engines greater than 500 HP is required to be continuously monitored and recorded by a Continuous Parametric Monitoring System (CPMS). Pressure drop across the catalyst must also be measured on a monthly basis. Both inlet temperature and pressure drop across the catalyst must be measured for the initial performance test.
What are the operating limitations for engine temperature and pressure? For engines equipped with an Oxidation or NSCR catalyst, operators must maintain the catalyst such that the pressure drop across the catalyst does not change by more than 2 of water from where it was first measured during the initial performance test. In addition, for engines equipped with an Oxidation catalyst, the exhaust temperature must be maintained so that the catalyst inlet temperature is between 450 F and 1350 F. For engines operating with an NSCR catalyst, the exhaust temperature must be between 750 F and 1250 F. See above for the temperature and pressure monitoring requirements. Are the operating limitations and emissions standards required on start-up? Owners and operators must minimize the engine s time spent at idle and minimize the engine s startup to a period needed for appropriate and safe loading, not to exceed 30 minutes, after which time the engine must meet the applicable operating limitations and emissions standards. How is a limited use engine defined? A limited use engine is one that operates less than 100 hours per year. How is a not limited use engine defined? A not limited use engine is one that operates more than 100 hours per year. I m unable to obtain compliance by May 3 rd, 2013 for CI Engines or October 19 th, 2013 for SI engines. What are my options? The request for a compliance extension can be made no longer than 120 days prior to the affected source s compliance date. There are no specific reasons that must be submitted as part of the request for a compliance extension. The EPA or the delegated agency will review each request on a case-by-case basis. At a minimum, a request for a compliance extension should address why the owner/operator would not be able to install the appropriate air pollution controls within this 120-day period. Circumstances that arose beyond the control of the owner/operator also should be included in the request. The request must include the information specified in 40 CFR 63.6(i)(6). Instead of compliance, can I just pay the fine? Operating stationary RICE engines out of compliance may subject the owner/operator to daily fines and penalties as a violation of the Clean Air Act. It s reported that the federal level for non-compliance is $37,500 per day that would be dictated under the Clean Air Act Stationary Civil Penalty Policy. You would likely be in violation of state law as well and subject to state fines and penalties. While monetary penalties are civil in nature, willful negligence can give rise to criminal liability.
What if the engine is a residential, institutional or commercial emergency engine? If yes, it is exempt from the RICE NESHAP ruling. However, if the engine is used on a Peak shaving, On-Demand, or Curtailment contract and receives a financial incentive (discounted electric rate, tariff, or flat fee), the engine is considered nonemergency and therefore will fall under the RICE NESHAP ruling. Where can I look for basic information on the ruling from the EPA? The GT Exhaust RICE NESHAP Library provides a great deal of information on the ruling and what it takes to stay compliant. The EPA RICE NESHAP Implementation Q&A Document provides further detail to various parts of RICE NESHAP. Who is the proper person to contact at the EPA for further information? Visit the GT Exhaust RICE NESHAP Library and Scroll down to EPA Contacts and Fact Sheets for Local and Federal regulatory contacts.