March 28, 2014
For many stationary engine owners and operators RICE MACT (40 CFR 63 Subpart ZZZZ) has been one deadline after another for the past several months. Recently Trinity Consultants, working with EPA’s rule writer, regional contacts and state regulators to clarify ambiguities, advised many of its clients of the following three RICE MACT compliance lessons learned.
- Sometimes it is best not to call an emergency engine an emergency engine. For certain categories of engines, the non-emergency provisions are less stringent and less costly.
- Officially, the 180-day performance test clock does not restart upon a switchover from emergency to non-emergency operation. You may be in perfect compliance with emergency engine provisions but decide at some point to switch to non-emergency, which is likely to require catalytic controls, parametric monitoring, and performance testing. Compliance with the first two can be achieved as long as the controls and monitors are in place before you switch over (i.e. before you exceed the 50/100-hour limitation), but if the switch occurs more than six months after the original compliance date then it is impossible to comply (officially) with the initial performance test equipment.
- There is more to the Notification of Compliance Status (NOCS) than just the performance test report. Specifically, the requirements of 63.9(h)(2)(i)(C), (E), and (G) are not typically addressed in a stack test report. Also, remember that a NOCS may be required even if a performance test is not.
What this means to you
Stationary engine owners attempting to meet RICE MACT compliance guidelines have a range of options to comply with the law. However, these options can impact your operations.
MIRATECH can help
Contact MIRATECH for 3-way and oxidation NSCR catalysts, air/fuel ratio controllers, and monitors to meet your stationary engine RICE MACT compliance goals.
Register to attend MIRATECH’s free RICE NESHAP Webinar – April 8, 2014 9:00 AM – 10:00 AM PDT
Click here to register for MIRATECH’s online webinar designed to help you understand the most important RICE NESHAP compliance requirements and schedules. The ultimate goal is to provide key information necessary to help you navigate your compliance options. The webinar is scheduled to occur Thursday, April 8, 2014 at 9:00 AM-10:00 AM PDT.