Environmental Observer
The Associated General Contractors of America | Quality People. Quality Projects.
www.agc.orgJuly 25, 2012 / Issue No. 6-12
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On the Inside
Air
Deadline to Cut Stationary Engine Emissions Slated for 2013: Review of RICE NESHAP Rules
Water
EPA’s Not in a Hurry To Propose National ‘Post-Construction’ Stormwater Rules; Another Deadline Missed
EPA Releases ‘Green Infrastructure’ Permitting and Enforcement Factsheets
Climate
A Recent Court Ruling Upholds Climate Rule; Industry Looks to Capitol Hill for 'Carbon Fix'
News & Events
2013 AGC/Alliant Build America Competition is Now Open; Submit Your Environmental Enhancement Project
Free Podcast from ConsensusDocs Now Available
Air
Deadline to Cut Stationary Engine Emissions Slated for 2013: Review of RICE NESHAP Rules
 

If you own or operate a stationary generator, pump, compressor or some other piece of stationary equipment then you probably need to “retrofit” its engine to comply with federal National Emission Standards for Hazardous Air Pollutants (NESHAP).  Nearly one million existing, stationary diesel Reciprocating Internal Combustion Engines (RICE) are affected by the federal mandate to cut exhaust levels of carbon monoxide by 70 percent or more.  Leading engine manufacturers warn that compliance is not going to be cheap, easy, or quick – especially when a limited number of qualified experts have roughly one year to meet the nation’s retrofit needs under the NESHAP for RICE.  Also be aware that the U.S. Environmental Protection Agency (EPA) recently proposed several amendments to the rule, particularly regarding RICE used for emergency or back-up power.

The U.S. EPA published the final NESHAP for stationary RICE on March 3, 2010, at 40 CFR 63, Subpart ZZZZ (75 FR 9648).  EPA set the following dates for compliance with the national emission limit and operating limits, which generally apply to RICE greater than 300 horsepower (HP)— 

  • Non-Emergency Diesel (CI) Engines by May 3, 2013
  • Non-Emergency Gas (SI) Engines by October 19, 2013.

Do not wait to review the legal requirements, consider options, explore technical issues and establish an appropriate budget.  The federal Clean Air Act has severe penalties for non-compliance, including costly fines of up to $37,500 per day per violation and criminal penalties.

According to Caterpillar Inc. experts, the majority of non-emergency stationary diesel RICE greater than 300 HP will require a diesel oxidation catalyst (DOC) on the exhaust side and closed crankcase ventilation; if you vent your crankcase you must either filter before venting or return it back to the crankcase. The RICE rule also requires owners/operators of regulated engines to monitor inlet temperature and pressure drop (>500 HP only); perform an initial compliance test; re-test engine(s) every 8,760 hours of operation or every three years (>500 HP only); log data; submit and initial notification and notification of all performance tests; and report annually that the specified emission limits have been met.

Note that an initial notification to U.S. EPA is required immediately for non‐emergency existing engines subject to numerical emission standards – Sample Initial Notification- Compression Ignition. 

More Legal Requirements

In addition, the RICE rule requires owners/operators to keep records showing compliance with the required best management practices. These records must include, at a minimum: oil and filter change dates and corresponding hour on the hour meter; inspection and replacement dates for air cleaners, hoses, and belts; and records of other emission-related repairs and maintenance performed.

AGC has prepared a summary of the NESHAP requirements for existing stationary diesel (compression-ignition or CI) RICE and a much more in-depth fact sheet.  Additional information is also on EPA’s website at http://epa.gov/region1/rice/.  EPA also has created two interactive web-based tools that provide users with site-specific instructions on how to comply with the RICE rule based on the data entered input into the system— 

Consider Options & Explore Technical Issues

The reality is that there are a limited number of RICE consultants, equipment suppliers and installers. As the compliance date nears, the demand for – as well as the price of – emission reduction technologies and services will increase, according to industry sources.  Many are predicting that delivery times also will increase. If your company misses the mandatory May 2013 (October 2013 for gasoline engines) deadline for meeting EPA’s RICE emission limits, you risk non-compliance fines of up to $37,500 per day per violation.

Now is the time to consider your options and explore technical issues.  Click here for compliance news and technical information from Caterpillar Emissions Solutions.  Many authorized CAT dealers are providing onsite consultations – click here for an example. Johnson Matthey Stationary Emissions Control Group (JMI) and Cummins Emissions Solutions (CES) have formed an alliance to provide their customers with products to meet the RICE requirements – click here and here to find out more.

Proposed Amendments

In response to a variety of legal challenges to the NESHAP for diesel RICE, EPA recently proposed several amendments to the rule, particularly regarding RICE used for emergency purposes.  The most noteworthy provisions in the proposal would— 

  • Allow owners/operators of RICE maintained to respond to emergency power needs to operate their “back-up” generators for up to 100 hours per year. (If an emergency engine operates for more than 100 hours per year for non-emergency purposes, the engine would need to meet emission limits required for non-emergency engines for the life of the engine.)   EPA also proposed that, through 2017, emergency generators be allowed to operate without limits for up to 50 hours of this 100-hour exception “for peak shaving and non-emergency demand response.” EPA’s explanation is that this temporary exception is necessary “to address reliability issues and develop solutions.”
  • Allow Tier 1 and Tier 2 certified diesel engines that must be replaced by June 1, 2018, under state requirements to meet requirements for management practices rather than numeric limits. This provision is intended to assist owners/operators that must install controls on their engines to meet the RICE NESHAP and then having to replace their engines under state rules shortly thereafter. EPA’s intent here is to address a concern specific to certain engines in use in Texas and California.
  • Broaded the definition of remote area sources in Alaska to ensure that stationary RICE in those areas are subject to management practice requirements as opposed to emission standards likely necessitating aftertreatment.

EPA has extended the public comment period for proposed amendments to August 9, 2012.  The proposed rule is online – click here.  EPA also released a synopsis of the proposed changes.

To find out more, contact Leah Pilconis at pilconisl@agc.org or your EPA Regional RICE Contact.

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