New Emission Rules for IC Engines

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New Emission Rules for IC Engines

• Presented by
• Scott Wallace
• Devon Gas Services, L.P.

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Topics of Discussion

• ? Consolidated Engine Rule
• NSPS JJJJ for SI Engines
• Update to RICE MACT
• Area Source RICE MACT
• ? Control Requirements
• ? Testing
• ? Records

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Consolidated Engine Rule Background

• Three Separate Rules in One
• New Source Performance Standard (NSPS) (60
  Subpart JJJJ)
• NESHAP, MACT Small Engine Standard (63 Subpart
  ZZZZ) (lt 500 HP at a Major HAP Source)
• National Emission Standards for Hazardous Air
  Pollutants (NESHAP) Areas Source Standard
  (Everything that is not a Major HAP Source is an
  Area Source)
• Proposed June 12, 2006
• Comment Deadline 10/11/2006
• INGAA and API supplied major comments
• Rule Finalized 12/20/07 Published 1/18/08
  Effective 3/18/08
• Follows CI, ICE Philosophy

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Consolidated Engine Rule Overview

• NSPS JJJJ establishes minimum requirements for
  new or modified Spark Ignition engines with
  requirements based on size, type and date of
  manufacture
• NESHAP RICE MACT
• ? Major Source Sites (lt 500 HP) follow NSPS JJJJ
  for new/reconstructed engines and your in
  compliance (Lean Burns require an oxidation
  catalysis for a 93 reduction in CO)
• ? Minor Source Sites follow NSPS JJJJ for
  new/reconstructed engines and your in
  compliance.
• Undecided on existing engines with rule to be
  issued in early 2009 with a final rule in 2010

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Consolidated Engine Rule New Engine Control
Requirements
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NSPS General Certification Criteria

• ? Manufactures Certification
• All IC Engines 25 HP or less require
  certification for
• any engine manufactured after 7/1/2008
• Certification on larger NG fired engines is
• voluntary (Note if an engine is certified and
  
• operated as a certified engine the
  manufactures
• requirements are not voluntary)
• Certification process is the same as the
• mobile source rule

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NSPS Monitoring

• ? Compliance monitoring requirements include
  adherence to manufactures emissions related
  operating and maintenance specifications for
  certified engines
• ? Uncertified or certified engines operated in an
  uncertified manor require an individual written
  maintenance plan
• ? Also applies to emissions control vendors
  requirements (NSCR and Oxidation Catalysis)

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NSPS Testing

• Certified engines operated in a certified manner
  do not require performance testing
• Performance testing required on all uncertified
  engines
• lt 100 hp certified engine operating in
  non-certified manner no test required
• 25 hp 500 hp engines that are not certified
  subject to initial performance test within first
  year of operation.
• 100 hp 500 hp certified engine operating in
  non-certified manner initial performance test
  required within 1st year of operation.
• gt 500 hp certified engine operating in
  non-certified manner or non-certified engines are
  subject to initial performance test within first
  year of operation and every 8760 hours or 3 years.

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Testing Frequency

• Greater than 500 hp
• ? Initial performance test
• ? Periodic test every 8760 hours or 3 years,
  which every comes first.
• Less than 500 hp, but greater than 100 hp
• ? Initial performance test
• Less than 100 hp, but greater than 25 hp
• ? Initial test for uncertified engines
• ? No testing for certified engine, even if
  operated as uncertified (i.e. non-specification
  fuel and owner written maintenance plan

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Performance Testing General Information

• ? Initial performance test must be performed
  within 60 days of achieving maximum production
  rate . . . , but not later that 180 days of
  initial startup.
• ? Certified engines, operated as uncertified
  engines have 1 year to perform initial
  performance test.
• ? Performance testing required on CERTIFIED
  engines after overhaul
• ? Test performed within 10 of 100 peak (or the
  highest achievable) load.
• ? Test consist of 3 one hour test runs
• ? Test must be for NOx, CO and VOC using
  prescribed EPA methods .
• ? Unit does not have to be started-up just to
  perform test, but test must be run on start-up.

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NSPS Recordkeeping and Reporting

• ? All IC engines must maintain records of proper
  maintenance
• ? Initial construction notification required
  within 30 days for uncertified engines gt 500 HP
• ? Notification at least 30 days prior to
  emissions testing
• ? Certified engines require manufacturers
  documentation indicating the engine is certified
  to meet emissions standard
• ? Uncertified engines require performance test
  and period test must be submitted within 60 days
  of completion
• ? Emergency engines must maintain records of all
  operations

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Comments and Considerations

• ? Engines that are overhauled are not considered
  modified unless an emissions increase has
  occurred.
• ? These are minimum standard and the state may
  have additional requirements
• ? As with existing NSPS and NESHAPS requirements,
  the act of relocation in of itself does not
  trigger applicability. The unit must be
  modified, reconstructed, or newly constructed
  within the prescribed dates.
• ? Generally, reconstruction is defined as repairs
  where the fixed capital cost of the new
  components exceeds 50 percent of the fixed
  capital cost that would be required to purchase
  an entirely new engine.
• ? Title V permits will need to be modified to
  incorporate the NSPS Subpart JJJJ and NESHAPS
  Subpart ZZZZ as applicable requirements when
  subject engines are installed at title V sites.

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Additional Information

• Internet links http//www.epa.gov/ttn/atw/rice/r
  icepg.html
• Fact sheet 
• http//www.epa.gov/ttn/oarpg/t1/memoranda/SI20and
  20RICE20fact20sheet20122020200720Scout.pdf
• Rule 
• http//www.epa.gov/ttn/oarpg/t1/memoranda/SI20NSP
  S20NESHAP20FRM2012-20-07.pdf
• API Training completed Summer 2008 (additional
  courses?)
• Go to API.org under meeting and training to get
  the status of the training courses
• API is planning to make the training manual
  available

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• Questions ?
• Answers.

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