Transcript Mustang Watchdog

Compliance with RICE
Regulations
Texas Alliance of Energy Producers
Texas & Federal Environmental
Compliance Seminar
April 22, 2014
Agenda
• General Overview of Federal RICE Rules
• NESHAP ZZZZ – More Details
• Compliance Examples
• Other Lessons Learned
• Questions
pg.2
General Overview of
Federal RICE Rules
NSPS IIII
NSPS JJJJ
NESHAP ZZZZ
RICE Rules
• RICE = Reciprocating Internal Combustion
Engine
o CI = Compression Ignition (diesel)
o SI = Spark Ignition (natural gas)
• NSPS = New Source Performance Standards
• NESHAP = National Emission Standard for
Hazardous Air Pollutants
• Nearly ALL are subject to federal regulations
• Consider engine only, not the compressor /
generator / pump / etc.
pg.4
NSPS Subpart IIII
• NEW Diesel Engines
o Constructed (ordered) > 7/11/2005 AND
o Manufactured > 4/1/2006*
• *For fire pump engines, > 7/1/2006
OR
o Modified / Reconstructed > 7/11/2005
pg.5
NSPS Subpart IIII
• Compliance
o IF the engine displacement is =>30 liters/cylinder,
performance testing may be required
o Otherwise, comply by purchasing a certified
engine
• AND install / operate / maintain according to
manufacturer specifications
pg.6
NSPS Subpart JJJJ
• NEW Natural Gas Engines
o Constructed (ordered) > 6/12/2006 AND
Manufactured:
• <500 hp, => 7/1/2008
• =>500 hp, => 7/1/2007
• Lean burn => 500 hp, < 1350 hp, => 1/1/2008
• Emergency > 25 hp => 1/1/2009
OR
o Modified / Reconstructed > 6/12/2006
pg.7
NSPS Subpart JJJJ
• Compliance:
o Purchasing a certified engine may be possible
• AND install / operate / maintain according to
manufacturer specifications
o Otherwise, performance testing is required
• Likely necessary to install a catalyst to meet
emissions limits
pg.8
NESHAP Subpart ZZZZ
• Major HAP Source
o > 500 hp
• Existing < 12/19/2002
• New / Reconstructed => 12/19/2002
o =< 500 hp
• Existing < 6/12/2006
• New / Reconstructed => 6/12/2006
pg.9
NESHAP Subpart ZZZZ
• Area HAP Source
o Existing < 6/12/2006
o New / Reconstructed => 6/12/2006*
• *Complies with this Subpart by Complying with
NSPS 4J or 4I
pg.10
NESHAP Subpart ZZZZ
• Compliance May Include
o Maintenance requirements
o Emissions limits / performance testing (likely
requiring a catalyst)
o CPMS / automatic temperature shut off
o Pressure drop
o Fuel requirements
o Maintenance plan
o Non-resettable hour meter
o Crankcase controls
pg.11
How to Tell them Apart
• Need to Know:
Facility HAP status (area vs major)
Manufacture and construction date
Any modification / reconstruction?
Engine type (CI vs SI, Lean vs Rich Burn, 2-Stroke
vs 4-Stroke, site rated hp)
o Engine use (Emergency / black start / normal to
operate / stationary vs portable)
o *Remote vs Non-Remote
o
o
o
o
pg.12
Some Important
Definitions & Distinctions
• NSPS vs NESHAP
• Manufacture vs Construct vs Order
Date
• Reconstruction & Modification
pg.13
Define “Nearly All”
• A Few Exemptions
o Portable non-road
o Motor vehicles
o Residential, commercial, institutional (area
source) existing emergency
pg.14
Define “Nearly All”
• Date Gap
o 6/12/2006 through 7/1/2008 (Area Source, SI,
<500 hp)
o Technically subject to NESHAP 4Z, comply with
the regulation by complying with NSPS 4J, but NO
REQUIREMENTS under 4J
pg.15
NESHAP ZZZZ Area
Source Engines
More Details
Key Dates
• 5/3/2013
o Compliance date for CI Engines
• “Annual” requirement due date coming up
soon!
• 10/19/2013
o Compliance date for SI Engines
• 4/17/2014 testing due date, if applicable
• 1/31/2014
o First semiannual compliance report due
pg.17
Existing Area Source Engines, excerpted from http://www.epa.gov/region1/rice/
Remote
• A pipeline segment with 10 or fewer
buildings intended for human occupancy
and no buildings with four or more stories
within 220 yards (200 meters) on either side
of the centerline of any continuous 1-mile
(1.6 kilometers) length of pipeline. Each
separate dwelling unit in a multiple dwelling
unit building is counted as a separate
building intended for human occupancy.
• AND
pg.19
Remote
• The pipeline segment does not lie within 100
yards (91 meters) of either a building or a
small, well-defined outside area (such as a
playground, recreation area, outdoor
theater, or other place of public assembly)
that is occupied by 20 or more persons on at
least 5 days a week for 10 weeks in any 12month period. The days and weeks need
not be consecutive. The building or area is
considered occupied for a full day if it is
occupied for any portion of the day.
pg.20
Timeline for RICE
• Existing Non-emergency Non-remote SI >500 hp
4SLB / 4SRB engines
o By October 19, 2013
• Install OC on 4SLB and NSCR on 4SRB
• Install automatic engine shutdown device
(Catalyst inlet limit of 1350°F for 4SLB, 1250°F for
4SRB) OR CPMS
o Initial testing must be complete by 4/17/2014
o Annual compliance demonstration
pg.21
Timeline for RICE
• All Other Existing SI engines – by October 19,
2013
o Implement Maintenance Plan – Document
maintenance and be prepared for inspector review.
pg.22
Timeline for RICE
• Ongoing Requirements
o Engine startups not to exceed 30 minutes.
o “Remote” status must be reviewed every 12 months.
If the status has changed, the facility has 12 months
to comply.
o Annual maintenance activities – in accordance with
maintenance plan for engines
pg.23
Reports / Notifications
• Notification of Compliance Status Report for NonRemote Engines
o Regarding automatic temperature shutdown
equipment
• Notice of Intent to Conduct Performance Testing for
Non-Remote Engines
o Due 60 days prior to test
pg.24
Reports / Notifications
• Notification of Compliance Status Report for NonRemote Engines
o Regarding Initial Compliance Demonstration
Testing
o Due within 60 days of testing
• Semiannual Compliance Report for Non-Remote
Engines
o Initial Report due 1/30/2014
o Next due 7/31/2014
pg.25
Annual / Ongoing
Activities
• Annual review of remote status
• Engine startups not to exceed 30
minutes
pg.26
NESHAP ZZZZ
Compliance Examples
Maintenance
Requirements
• Note that different engine categories have different
maintenance intervals
o 1,440 hours (60 days)
o 2,160 hours (90 days)
o 4,320 hours (180 days)
• Be cautious to ensure that the SITE-RATED hp is used
in determining the frequency.
• Consider each engine category having a unique
tailored PM schedule
• OR
pg.28
Maintenance
Requirements
• Consider a common schedule
• Example:
o Monthly Maintenance
• Inspect spark plugs, belts and hoses
• Obtain oil analyses
• If the oil analysis fails to meet the required
standards, then the oil will be changed within
2 business days of receiving the oil analysis
report
pg.29
Oil Analyses
• Ensure that the required parameters
are included in the report
• Ensure that alerts / notifications are
provided timely
• Ensure that any parameters to be
compared to “new oil” were properly
acquired for the “new oil”
pg.30
Remote / Non Remote
Determination Example
pg.31
RICE Rules – Lessons
Learned
Lessons Learned
pg.33
I’m Getting Thirsty.
Where’s my Lemonade???
pg.34
Questions
• Contact me:
o Kristine Baranski
o [email protected]
o (405) 842 - 1066
pg.35
Resources
• http://www.epa.gov/region1/rice/
• http://www.epa.gov/ttn/atw/icengines/imp
.html#qa
o See especially:
• 04/02/2013 Implementation Question and
Answer Document for NESHAP for Stationary
RICE and NSPS for Stationary CI and SI ICE (pdf
file)
• 02/07/2014 RICE Summary Table of
Requirements (xls file)
pg.36