August 2010 40 CFR Part 63 Subpart ZZZZ review April 27, 2011 Presentation to AWMA Rocky Mountain Section Matthew J. Hazleton TRC Littleton, CO 1
Overview: Brief History of Subpart ZZZZ June 2004; Initial Promulgation January 2008; Revision and New Rules Subparts JJJJ and IIII March 2010; CI engine revision August 2010; Revision and New Rules Review of August 2010 Revision December 2010; Notice of Reconsideration March 2011; Notice of Proposed Rule & Amendments Discussion w/ Questions and Answers Conclusion 2
Clay Bennett CS Monitor; used under fair use 3
History of Subpart ZZZZ Initial Promulgation: August 16, 2004 effective date Generally; Affected engines at Major sources for HAPs over 500 hp in size; Minor (Area) sources unaffected More latitude on use of Emergency Use and Limited Use Generators/RICE. Did not include Diesel engines In many cases installed temperature probes and ΔP monitors to comply with requirements (CPMS) 4
Matt s Subpart ZZZZ flowchart version 1 (after initial rule) Start Yes Do you have an engine on-site? Is your site major for HAPs? No Yes Is your engine over 500 hp? No No No worries! Yes Man, now I am going to have to figure this out. 5
History of Subpart ZZZZ 1 st Revision (1/18/2008): March 18, 2008 effective date Generally; 40 CFR Part 60 Subparts JJJJ (RICE) and IIII (Diesel) simultaneously promulgated. Regulated engines under 500 hp at Major Sources. Certain engines could meet ZZZZ by complying w/ Subpart JJJJ or IIII requirements. Regulated engines at Area sources as well. Tightened regulations regarding emergency engines/generators. Additional monitoring/testing requirements. 6
History of Subpart ZZZZ 2 nd Revision (3/10/10): May 3, 2010 effective date Generally; Dealt only with Compression Ignition (CI-Diesel) engines located at Major and Area sources Makes allowances for residential /commercial /institutional emergency stationary RICE December 7, 2010: EPA issues Notice of Reconsideration of final rule and requests public comments Pertaining to ability of engines to participate in emergency demand response programs Still outstanding; comments were due by February 7, 2011 7
History of Subpart ZZZZ Current (3 rd ) Revision (8/20/10):October 19, 2010 effective date Generally; Further refined regulations on all engines at Major sources (less than 500 hp) Further refined regulations on all SI engines at Area sources Further defined (restricted?) use of emergency / limited / black start / non-black start generators / engines 8
Review of Current Outstanding Revisions Timeline August 20, 2010 - EPA publishes final rule in Federal Register Effective date is October 19, 2010 January 19, 2011 EPA administrator issues 90 day stay on two provisions (API and INGAA); 40 CFR 63.6625 (b) Table 5 CPMS installation 40 CFR 63.6625 (k) temperature measurement Stay indicates that EPA does not necessarily agree with claimants characterizations Stay also indicates that an amendment addressing CPMS is to published soon 9
Review of Current Outstanding Revisions Timeline March 9, 2011 EPA publishes direct final rule effective May 9, 2011 without final notice Also issues amendment notice to allow for public input. Currently where we stand. 10
Matt s Subpart ZZZZ flowchart version 2 (2008 revision) Start When was the engine manufactured? Not sure Yes Time to enjoy the existential joys of paperwork Hell, it s older than I am Uh Oh! Was engine bought after you started working here? No Find Oldest field supervisor you can and have him swear on a stack of bibles that the engine is older than his grandmother Can you prove it? No Yes! How? Really old Paperwork or other spotty documents Should be OK unless state doesn t like your documentation 11
March 2010 Revision - Summary Stationary CI RICE 500 hp @ Major source Stationary CI RICE @ Area source Stationary CI RICE > 500 hp @ Major source 12
August 2010 Revision - Summary Existing Stationary Rice 500 hp @ Major Source 1) Non-emergency 2SLB 100-500 hp 2) Non-emergency 4SLB 100-500 hp 3) Non-emergency 4SRB 100-500 hp 4) Non-emergency landfill & digester SI RICE 100-500 hp 5) Non-emergency Stationary SI RICE < 100 hp 6) Emergency Stationary SI RICE Existing Stationary SI RICE at Area Sources 13
August 2010 Management Practices Major source Existing Stationary Emergency SI RICE 500 hp @ Major source: Change oil & filter every 500 hrs or annually (1 st ) Use of Oil Analysis program can extend period Inspect spark plugs every 1,000 hrs or annually (1 st ) Inspect all hoses & belts every 500 hrs or annually (1 st ) 14
August 2010 Management Practices Major source Existing Stationary non-emergency SI RICE < 100 hp @ Major source: Change oil & filter every 1,440 hrs or annually (1 st ) Use of Oil Analysis program can extend period Inspect spark plugs every 1,440 hrs or annually (1 st ) Inspect all hoses & belts every 1,440 hrs or annually (1 st ) 15
August 2010 Management Practices Major source Existing 2SLB stationary SI RICE < 100 hp @ Major source: Change oil & filter every 4,320 hrs or annually (1 st ) Use of Oil Analysis program can extend period Inspect spark plugs every 4,320 hrs or annually (1 st ) Inspect all hoses & belts every 4,320 hrs or annually (1 st ) 16
August 2010 Management Practices Oil Change Analysis program Analysis three (3) parameters at a minimum; Total Acid Number (TAN) Viscosity Percent water content Oil must be changed within two (2) days if TAN Increases by more than three (3) milligrams potassium hydroxide over TAN number when new Viscosity changes by more than 20% from when new % water content (by volume) is greater than 0.5 Per 40 CFR 63.6(g) alternative work practice can be requested 17
August 2010 Management Practices Area source Existing non-emergency 4SLB & 4SRB stationary SI RICE 500 @ Area sources (landfill or digester gas); Change oil & filter every 1,440 hrs or annually (1 st ) Use of Oil Analysis program can extend period Inspect spark plugs every 1,440 hrs or annually (1 st ) Inspect all hoses & belts every 1,440 hrs or annually (1 st ) 18
August 2010 Management Practices Area source Existing stationary 2SLB non-emergency engines @ Area sources; Change oil & filter every 4,320 hrs or annually (1 st ) Use of Oil Analysis program can extend period Inspect spark plugs every 4,320 hrs or annually (1 st ) Inspect all hoses & belts every 4,320 hrs or annually (1 st ) 19
August 2010 Management Practices Area source Existing stationary emergency SI RICE engines @ Area sources & Existing non-emergency 4SLB & 4SRB stationary SI RICE > 500 hp @ Area sources (< 24 hrs/yr) Change oil & filter every 500 hrs or annually (1 st ) Use of Oil Analysis program can extend period Inspect spark plugs every 500 hrs or annually (1 st ) Inspect all hoses & belts every 500 hrs or annually (1 st ) 20
Matt s Subpart ZZZZ flowchart version 2 (Current revision) Agency Flowchart Matt s Flowchart Do you have an engine? Is it for emergencies? Do you have an engine? Is the engine black? Does the engine smell funny? Do you have another engine? Is it a steam engine? How does it sound at night? Not good. Was it built on a Tuesday? How many dogs live at the station? Call us we can help? Not good. Better increase budget and hire more help. 21
August 2010 Start-up Requirements Existing stationary SI RICE 500 hp @ Major source & Existing stationary SI RICE @ Area source; Minimize time spent at idle Start-up time not to exceed 30 minutes Defined as steady state or normal operation Per 40 CFR 63.6(g) alternative work practice can be requested (Major source) 40 CFR Subpart E w/ state approval (Area source) 22
August 2010 Operating Limitations Area source Existing stationary non-emergency 4SLB and 4SRB RICE > 500 hp @ Area source (> 24 hrs/yr) NSCR Catalyst Within 2 inches ΔP water from initial performance test; Temperature must be between 750 & 1,250 F Oxidation Catalyst Within 2 inches ΔP water from initial performance test; Temperature must be between 450 & 1,350 F May petition for different temperature range per 40 CFR 63.8(f) 23
August 2010 Compliance Requirements Major source Existing Stationary non-emergency SI RICE < 100 hp @ Major source & Existing stationary emergency SI RICE @ Major source; Operate and maintain according to manufacturer s written instructions OR Develop maintenance plan per Subpart ZZZZ requirements. Not required to conduct performance testing 24
August 2010 Compliance Requirements Major source Existing Stationary non-emergency SI RICE > 100 hp & 500 hp @ Major source; Operate and maintain according to manufacturer s written instructions OR Develop maintenance plan per the rule Required to conduct initial performance test to demonstrate compliance 25
August 2010 Compliance Requirements Area source Existing stationary RICE @ Area source that are subject to management practices Not required to conduct performance testing Must develop maintenance plan as per the rule 26
August 2010 Compliance Requirements Area source Existing 4SLB & 4SRB non-emergency stationary SI RICE > 500 hp ( > 24 hrs/yr) @ Area source; Conduct Initial performance test Conduct subsequent performance test 8,760 hours of operation or three (3) years (1 st ) Continuously monitor & record inlet temperature of the catalyst Monthly measurements of ΔP across catalyst If no catalyst, must monitor parameters (if any) approved by administrator. 27
August 2010 Recordkeeping & Reporting Existing stationary emergency SI RICE; Don t meet requirements for non-emergency engines Record hours of operation Install non-resettable hour meter Existing stationary SI RICE @ Major or Area source; Subject to work/management practices Records to demonstrate compliance Oil/Filter change logs & corresponding hours of operation Inspection/replacement dates for plugs, hoses & belts Records of other emission-related repairs and maintenance 28
August 2010 Recordkeeping & Reporting Existing non-emergency stationary SI RICE 100 hp & 500 hp @ Major source & Existing non-emergency 4SLB & 4SRB stationary RICE > 500 hp @ Area source (> 24 hrs/yr) Submit notifications required in Table 8 which include; Initial notification Notification of performance test Notification of compliance Submit semiannual compliance reports 29
Hang in there! 30
August 2010 Emission Standards Major Source w/ Catalyst ( 100 hp 500 hp) 4SRB non-emergency 10.3 ppmvd formaldehyde @ 15% O 2 4SLB non-emergency 47 ppmvd CO @ 15% O 2 2SLB non-emergency 225 ppmvd CO @ 15% O 2 Landfill/digester gas 177 ppmvd CO @ 15% O 2 31
August 2010 Emission Standards Area Source w/ Catalyst (> 500 hp) 4SRB non-emergency ( > 24 hrs/yr) 2.7 ppmvd formaldehyde @ 15% O 2 OR 76% CO reduction 4SLB non-emergency ( > 24 hrs/yr) 47 ppmvd CO @ 15% O 2 OR 93% CO reduction 32
August 2010 Other Other items of interest Method 323 is allowed as an option to measure formaldehyde If engine does not meet 40 CFR 63.6640(f) then the engine is not considered to an emergency stationary RICE. Compliance dates: October 19, 2013 Existing stationary SI RICE 500 hp @ Major source Existing stationary SI RICE @ Area source New or Re-constructed must comply at time of construction 33
Constant Parametric Monitoring System 40 CFR 63.6625 (b) (1) The CPMS must complete a minimum of one cycle of operation for each successive 15-minute period. You must have a minimum of four successive cycle of operation to have a valid hour of data. (2) Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), you must conduct all monitoring in continuous operation at all times that the unit is operating. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. 34
Constant Parametric Monitoring System 40 CFR 63.6625 (b) (3) For purposes of calculating data averages, you must not use data recorded during monitoring malfunctions, associated repairs, out of control periods, or required quality assurance or control activities. You must use all the data collected during all other periods in assessing compliance. Any 15-minute period for which the monitoring system is out-of control and data are not available for required calculations constitutes a deviation from the monitoring requirements. (4) Determine the 3-hour block average of all recorded readings, except as provided in paragraph (b)(3) of this section. (5) Record the results of each inspection, calibration, and validation check. 35
Constant Parametric Monitoring System 40 CFR 63.6625 (b) con t; (6) You must develop a site-specific monitoring plan that addresses paragraphs (b)(6)(i) through (vi) of this section. (i) Installation of the CPMS sampling probe or other interface at the appropriate location to obtain representative measurements; (ii) Performance and equipment specifications for the sample interface, parametric signal analyzer, and the data collection and reduction systems; (iii) Performance evaluation procedures and acceptance criteria (e.g.,calibrations); (iv) Ongoing operation and maintenance procedures in accordance with the general requirements of 63.8(c)(1), (c)(3), and (c)(4)(ii); (v) Ongoing data quality assurance procedures in accordance with the general requirements of 63.8(d); and (vi) Ongoing recordkeeping and reporting procedures in accordance with the general requirements of 63.10(c), (e)(1), and (e)(2)(i). 36
Constant Parametric Monitoring System 40 CFR 63.6625 (b) con t; (7) You must conduct a performance evaluation of each CPMS in accordance with your site-specific monitoring plan. (8) You must operate and maintain the CPMS in continuous operation according to the site-specific monitoring plan. 37
Constant Parametric Monitoring System 40 CFR 63.6625 (k); If you have an operating limitation that requires the use of a temperature measurement device, you must meet the requirements in paragraphs (k)(1) through (4) of this section. (1) Locate the temperature sensor and other necessary equipment in a position that provides a representative temperature. (2) Use a temperature sensor with a minimum tolerance of 2.8 degrees Celsius (5 degrees Fahrenheit), or 1.0 percent of the temperature value, whichever is larger, for a noncryogenic temperature range. (3) Use a temperature sensor with a minimum tolerance of 2.8 degrees Celsius (5 degrees Fahrenheit), or 2.5 percent of the temperature value, whichever is larger, for a cryogenic temperature range. (4) Conduct a temperature measurement device calibration check at least every 3 months. 38
CPMS March 9, 2011 proposed rule Original August 2010 rule 63.6625(b)(4) 3 hr. block. Proposed March 2011 rule Clarifies and corrects; - Now a 4 hr block so as to be consistent to Table 6 1 hr. Averages 4 hr. rolling average 39
CPMS March 9, 2011 proposed rule Original August 2010 rule 63.6625(k)(4) Temp. Calibration check every 3 months. Proposed March 2011 rule Clarifies and re-defines No longer a calibration check ; now a system accuracy audit (SAA). Allowed to establish a SAA which is tailored to client preferences. Could include redundant sensors or reference gauge(s). Device checks performed annually rather than 3 month intervals 40
CPMS March 9, 2011 proposed rule Other considerations and information EPA re-iterated ability of source to request alternative CPMS quality assurance and quality control requirements per 40 CFR 63.8(f)(4). Extends by 180 days date of compliance for CPMS operation and 40 CFR 63.6625(b) May 2014 deadline Corrected several inadvertent errors within initial issuance. 41
Yikes! Photos: NREL Photographic Information Exchange 42
Contact Information Mr. Matthew Hazleton TRC Environmental Littleton, CO (303) 304-0850 (720) 288-1771 MHazleton@TRCSolutions.com TRCSolutions.com 43
Additional Information Useful Links http://www.epa.gov/ttn/atw/rice/ricepg.html http://www.epa.gov/ttn/atw/rice/output/quiz.html http://www.regulations.gov/#!searchresults;rpp=10;po =0;s=EPA-HQ-OAR-2008-0708 44