January 2, 2015
In its recently published Fall 2014 Quarterly Newsletter, Jeremy Jewell and Shannon Lynn of Trinity Consultants summarize 10 of the most important aspects of the EPA’s stationary internal combustion engine (ICE) regulations. Below is a brief overview of the 10 key regulatory elements. Each is discussed in more detail in the Quarterly Newsletter article.
EPA first proposed regulations for stationary internal combustion engines (ICE) on December 19, 2002. It affected a relatively small number of stationary engines: reciprocating ICE (RICE) with a power rating of greater than 500 hp that operated at major sources of hazardous air pollutants (HAPs). It took more than 18 months for EPA to finalize the regulation, which was codified in 40 CFR Part 63, Subpart ZZZZ. That regulation – commonly known as the RICE MACT – and the process it took to develop it was an omen of things to come.
In the 12 years since the first proposal, EPA has published 25 Federal Register (FR) notices related to RICE MACT revisions/expansions, corrections, and reconsiderations and two other, separate regulations affecting stationary engines: 40 CFR Part 60, Subpart IIII and Subpart JJJJ, which regulate new ICE. This article discusses ten of the key elements of the rules and guidance, and how these elements apply to permitting and compliance projects.
1. What is a stationary engine?
This question speaks to the fundamental applicability of the regulations. Each of the three regulations stipulates that only “stationary” ICE are affected. In contrast, “mobile” ICE, or, more specifically, “nonroad” ICE, are not subject to these regulations (rather, they are subject to mobile source regulations that principally affect the manufacturers of such engines). Thus, the definition of a nonroad ICE is critical to determining applicability.
2. Certification Expirations
For many engines, the simplest method of complying with the two New Source Performance Standards (NSPS) regulations, 40 CFR 60, Subparts IIII and JJJJ, is to purchase engines for which the manufacturer has received a Certificate of Conformity from EPA. The only other substantive compliance requirement for operators of such engines is to properly operate and maintain the engine.
The RICE MACT and two NSPS regulations contain a myriad of notification requirements that are easily forgotten among all the other responsibilities of an environmental manager. Click here to view a table that provides a summary of the most common notification deadlines for stationary engines.
4. What really is an emergency?
The regulatory definition of and operational restrictions for emergency ICE are straightforward: operate only during emergencies except for up to a total of 100 hours per year in specified non-emergency situations. But several areas of clarification are needed regarding the emergency use provision.
5. The regulatory “Gap” for many stationary engines
There is a regulatory gap (loophole) for many stationary engines. In a nutshell, if an area source engine is constructed (installed on site or contracted to be installed on site) after 6/12/06 and is manufactured prior to whichever of the five NSPS manufacture dates applies, then the engine is not subject to any compliance requirements (regardless of when the engine was ordered).
6. Common emission calculation mistakes
Engine air emissions calculations are straightforward – most often taking the form of an activity rate (either power output or fuel heat input) multiplied by an emission factor wherein the “trick” is to simply cancel the units. Despite the simplistic form, there are several common engine emission calculation mistakes.
7. Performance Testing
Exhaust gas volumetric flow rate is a critical parameter for calculating mass emission rates with performance testing. Method 2 is most commonly used to measure velocity, which is in turn used to calculate volumetric flow rate. However, it is not necessarily the best (most accurate) method available.
8. Site-specific monitoring plans
With respect to site-specific monitoring plans (SSMPs), the most important issue is simply to have one available for review that satisfies RICE MACT provisions.
9. Permitting Advice
For engines, unlike many emissions units, mutually agreeable permit conditions are typically the result of education of, not negotiation with, agency permit writers. Between the complexity of these rules and the necessity of knowing many other rules as well, it is simply not reasonable to expect most permit writers to be experts on the stationary engine regulations.
10. Embracing reconstruction
For most projects involving large expenditures, a key goal is to avoid qualifying as reconstruction. However, because of how the stationary engine rules relate to one another, reconstructing an engine can sometimes be beneficial.
What this means to you
Jeremy Jewell and Shannon Lynn identify and review 10 key areas of EPA regulations affecting owners and operators of stationary internal combustion engines.
MIRATECH can help
Contact MIRATECH to learn more about cost effective emission compliance strategies for your stationary ICEs.