Workshop B - Managing Engine Compliance · Workshop B Managing Engine Compliance … ... Ignition...
Transcript of Workshop B - Managing Engine Compliance · Workshop B Managing Engine Compliance … ... Ignition...
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.
1
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 [email protected]
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 3rd 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 [email protected] 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.
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 - GEMr. William Bruscino - Trinity
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
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 RICEare 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 O2
λ = 1.1 For Gasoline
Federal RegulationsOur Focus
˃ 40 CFR Part 60 Subpart IIII, Standards of Performance for [New] Stationary CompressionIgnition Internal Combustion Engines (CI ICE NSPS)
˃ 40 CFR Part 60 Subpart JJJJ, Standards of Performance for [New] Stationary SparkIgnition Internal Combustion Engines (SI ICE NSPS)
˃ 40 CFR Part 63 Subpart ZZZZ, National EmissionStandards 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 NMHC/HC
Formaldehyde and CO (as surrogates for Total
HAPs)
NOx NOx
CO CO
PM
Criteria Pollutants HAPs
˃ 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
Federal Regulations Others
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… 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
1068.30, 89.2, 90, 91, 94, 1039, 1042, 1045, 1048, 1054
“Mobile” = Onroad + Nonroad + Marine
Temporary Exemption – Two Big Caveats1. 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 IIIIStandards of Performance for Stationary [New] CompressionIgnition Internal Combustion Engines
(Original proposal for CI ICE NSPS was in 1979; it was never finalized)
NSPS IIII Applicability
˃ Potentially applies to: All stationary compression-ignition engines
♦ Reciprocating, rotary, other (except turbines)
Of any size (horsepower rating) Emergency & Non-Emergency
˃ If: Constructed (ORDERED) after 7/11/2005 and
manufactured after 4/1/2006 Modified or reconstructed after 7/11/2005
60.4200
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
60.4200(b) & (d)
NSPS IIII Emission Standards˃ Pollutants: NMHC/HC, NOX, NMHC+NOX,
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
60.4204 & 4205
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
Import / Install DeadlinesRegardless 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
60.4208
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 < 2680and 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 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
60.4211
Engine Manufacturer Certifications˃ Engine manufacturers must certify 2007
model year and later engines <30 L/cyl.
60.4201
Emergency Engines
See discussion of definition and operational requirements in MACT ZZZZ section
60.4211(f)
Useful References
˃ Flowcharts˃ EPA Websites
NSPS IIII reg, background info, and implementation toolshttp://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 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
Owners/operators of ICE modified or reconstructed after 6/12/2006
NSPS JJJJ ApplicabilityConstructed (ORDERED) after 6/12/2006 and
manufactured after…
60.4230, 4236
Type / Size Manufactured Date
≥ 500 HP except LB 500 ≤ HP < 1350
7/1/2007
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
NSPS JJJJ Standards˃ Emission standards for HC/NMHC, NOX, CO,
and VOC (excluding CH2O) 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)
60.4233, 4235, 4244(f)
Import / Install DeadlinesRegardless 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
60.4236
Type / Size Manufactured Date
≥ 500 HP except LB 500 ≤ HP < 1350
7/1/2007
LB 500 ≤ HP < 1350 1/1/2008
< 500 hp 7/1/2008
Emergency > 25 hp 1/1/2009
Import/Install Deadline
7/1/2009
7/1/2010
7/1/2010
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 RequirementsNon-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
* Every 8,760 hours or 3 years, whichever is first
60.4243
Required for:≤ 25 hp;> 25 hp gasoline;> 25 hp RB LPG
Required for:Modified and reconstructed engines
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 nonresettablehour 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
60.4243(d) & 4237
Useful References
˃ Flowcharts˃ EPA Website
NSPS JJJJ reg, background info, and implementation toolshttp://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 ZZZZNational Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines
a.k.a., the RICE MACT
History of RICE MACT
Big, major engines; Limits based on catalytic controls; monitoring of T and ΔPRelatively few engines regulated at this point
Proposed 12/19/02
History of RICE MACT
Balance of new RICE, nearly all of which comply via NSPS (exception: 4SLB 250 - 500 hp, which complies with the 2004 rule requirements)
Proposed 6/12/06
History of RICE MACT
Balance of existing RICE; mix of management practices and emission limits based on catalytic controls
Proposed 3/5/09
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
63.6585
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
63.6590(a)
Potential RICE MACT Requirements
˃ Emission limits (CO and CH2O)˃ 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
Limited Use ≤ 500 HP No Such Category – Limited Use Provisions Only Apply to Existing RICE if > 500 HP
Area
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
Major
Non‐Emergency > 500 HP 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 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
Work Practices/Maint. Plan
Hour Meter
Major
Non‐Emergency 4SRB > 500 HP Non‐Emergency 2SLB, 4SLB > 500 HP No MACT Requirements
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
Limited Use Any ≤ 500 HP No Such Category – Limited Use Provisions Only Apply to Existing RICE if > 500 HP
Area
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 Emission Limit(s)
Control Device Monitor
Initial Perform. Test / Cat. Activity Check
Ongoing Perform. Test / Cat. Activity Check
Initial Notif./Comp Reports
Hour Meter
Major
Non‐Emergency 4SRB > 500 HP Non‐Emergency 2SLB > 500 HP Non‐Emergency 4SLB > 500 HP Non‐Emergency 4SLB
If manf’d ≥ 1/1/08 250 – 500 HP
Non‐Emergency 4SLB If manf’d < 1/1/08 250 – 500 HP No MACT Requirements
Non‐Emergency 4SRB ≤ 500 HP Comply with NSPS Only
Non‐Emergency 2SLB ≤ 500 HP Comply with NSPS Only
Non‐Emergency 4SLB < 250 HP Comply with NSPS Only
Non‐Emergency Landfill/Digester Gas > 500 HP I.N. &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 ≥ 1/1/08 250 – 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
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?
63.6625 & 6640
˃ 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
Tables 1 – 4, 63.6625(e)
Maintenance As Work Practice
Oil Analysis Program
Parameter Condemning Limits
Total Base Number (TBN) – CI < 30% of new oil
Total Acid Number (TAN) – SI Increases by more than 3.0 mg of potassium hydroxide per gram from TAN of new oil
Viscosity Changed by more than 20% from the viscosity of new oil
% Water Content by Volume > 0.5 %
˃ Oil analysis must be performed at same frequency specified for oil changes
˃ If condemned, change oil within 2 business days
˃ 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
63.6625(i) & (j)
˃ Operations logs˃ Records of startups and idling periods˃ Inspections / checklists˃ Maintenance logs˃ Document control
Maintenance Plan
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) Landfill or digester gas (LG/DG)
(>10% gross heat input annually)
63.6590(b)(3)
Original floor was ‘no control’. Will be reconsidered…in 8 years
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
63.6590(b)(1) & (2)
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 DefinitionsLimited Use RICE˃ 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
63.6675, 6590
Some Important DefinitionsEmergency RICE
˃ 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)
63.6675
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 Annual reporting via EPA’s Compliance and Emissions
Data Reporting Interface beginning for operation during 2015 calendar year (due 3/31/2016)
63.6650(h)
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 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… 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?
For emission calculations purposes, you may also
need the efficiency or fuel consumption rate
Example Simple Inventory
Facility PRODUCTION POWER ENGINE ENGINE Mfg Order Startup ReconstructSITE COUNTY Type METHOD 1 SOURCE 2 MAKE / MODEL HP Date Date Date Date 3
Lonesome Dove
South comp sta Compression Gas Engine Cat. ???? 1800 <1994 <1994 1994 ?
Lonesome Dove
South comp sta Compression Gas Engine Cat. ???? 1801 <1994 <1994 1994 ?
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 pump2. Power Source: gas engine, electric, diesel engine3. 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
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 notmonitoring
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...
60.8(c), Feb. 2014 email from Melanie King
Certificate of ConformityExpirations 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 preventflooding
˃ 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 ≠ EmergencyUnintended 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-by-case”
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
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