EPA Regulations and Their Affect on Rural Alaska Powerplants Steve Stassel, Gray Stassel Engineering Alaska Rural Energy Conference, April 27, 2016 (Technical Session 4, 1:30 pm)
Prime Power Engine Selection (good ol days) Brand Preference Load Capacity Fuel Efficiency Recoverable Heat Reliability Regulatory Compliance
CFR Citations: EPA Regulations 40 CFR 60 = NSPS (after April 1, 2016) 40 CFR 63 = NESHAP (on/before April 1, 2016) 40 CFR 80 = Fuel Regulations 40 CFR 89 = Nonroad Tier 1-3 40 CFR 94 = Marine Tier 1 & 2 40 CFR 279.11 = Used Oil Specifications 40 CFR 1039 = Nonroad Tier 4 40 CFR 1042 = Marine Tier 3 & 4 40 CFR 1068 = Highway, Stationary, Nonroad Compliance (flex/tpem, Rebuild, Tampering)
Why Does It Matter!?
Prime Power Engine Selection in 2016 Fuel Efficiency Cost of Fuel Reliability Cost of Maintenance Regulatory Compliance - Fines $3,750 per day $37,500 per violation
Pre-2006 Diesel Engine
2016 Diesel Engine
RICE-NESHAP and NSPS RICE-NESHAP applies to stationary diesel engines manufactured on or before April 1, 2006 Owner / Operator responsible for compliance NSPS applies to stationary diesel engines manufactured after April 1, 2006 Manufacturer's responsible for compliance (certified engines) Owner / Operator must document operation & maintenance IAW Manufacturers Recommendations
RICE-NESHAP Relief for Rural Alaska Minimize time at idle and engine startup <30 minutes Operate & Maintain engine IAW manufacturers instruct s Must comply with EPA Management Practices Oil changes every 1000 hours or annually, or use oil analysis plan Inspect air cleaner every 1000 hours or annually Inspect hoses and belts every 500 hours or annually Must maintain maintenance records that document Management Practices AEA/AVTEC Operator Training CD ROM has mtc logs
NSPS - New Source Performance Standards The EPA agreed that the circumstances in remote Alaska require special rules: Removed requirement to use after treatment devices for NOX, in particular, SCR, for engines used in remote Alaska; Allowed the blending of used lubricating oil, in volumes of up to 1.75 percent of the total fuel, if the sulfur content of the used lubricating oil is less than 200 ppm and the used lubricating oil is on-spec Exempted all pre-2014 model year engines from diesel fuel sulfur requirements (no ULSD); Allowed use of engines certified to marine engine standards and Tier 3 nonroad industrial engine emergency standards; but Requires PM after treatment devices for 2014 and later model year
2016 Diesel Engine
What are the Options? Purchase a New Tier 4 Engine Purchase a New Tier 3 Emergency Engine Poor fuel economy Must install Particulate Filter Purchase a New Tier 3 Marine Engine Must install Particulate Filter Particulate filters are problematic Not OEM equipment must be engineered Costly to install Affect fuel efficiency Higher maintenance costs Unproven Reliability
What s the Solution? Re-use of pre-2014 engines new unused engine Low-hour used / rebuilt engines Remanufactured used engines Not same as OEM Repower or Replacement program Must be pre-2014 block April 1, 2006 and newer = Certified Engine (NSPS) On or Before April 1, 2006 = Non-Certified Engine (RICE NESHAP) Must not exceed 50% / 75% of new engine cost May upgrade engine to cleaner emissions standard
What s Next? AEA will publish guidelines for regulatory compliance using pre-2014 engines State of Alaska is continuing to work with EPA on additional regulatory relief for rural Alaska Thursday, April 28 th, Tanana Trade Center, 10:30am Tool for Specifying Diesel Genset Replacements
RICE-NESHAP: Rural Alaska (expanded)
Review RICE-NESHAP Applies to stationary diesel engines older than April 1, 2006 Expanded Rural Alaska: complies using Management Practices Modified or Reconstructed RICE subject to NSPS Tier 1 NSPS Applies to stationary diesel engines newer than April 1, 2006 Diesel Particulate Filters required if not Tier 4 engine Road and Ferry communities subject to final Tier 4