Environmental Observer
The Associated General Contractors of America | Quality People. Quality Projects.
www.agc.orgFebruary 28, 2013 / Issue No. 2-13
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On the Inside
Air
May 3 Deadline to Cut Stationary Engine Emissions
Waste
EPA Warns Contractors to Get Certified Under the Federal Lead Renovator Rules
Green Construction
Public Comment Period Opens for GSA Report on Green Building Certification Systems
Last Public Comment Period on LEED v4 Opens March 1
EPA Releases New Fact Sheets to Assuage Concerns about Low-Impact Development
News & Events
Exciting New Events Planned for 2013 AGC Contractors Environmental Conference
US Congress Extends Alternative Fuel and Infrastructure Tax Credits
Not Too Late to Send Nominations - Steering Committee Volunteers
Air
May 3 Deadline to Cut Stationary Engine Emissions
AGC Explains Federal RICE NESHAP Rule
 

If you own or operate a stationary [1] 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) covering stationary reciprocating internal combustion engines (RICE).  Leading engine manufacturers warn that compliance is not going to be cheap, easy, or quick – especially when a limited number of qualified experts have just over two months to meet the nation’s retrofit needs.  Also be aware that the U.S. Environmental Protection Agency (EPA) recently published amendments to the RICE NESHAP rule, mainly regarding RICE used for emergency or back-up power (78 Fed. Reg. 6674, Jan. 30, 2013).  EPA just announced it will host a series of free webinars in advance of the May 3, 2013, compliance deadline.

Nearly one million existing stationary diesel RICE are affected by the federal standards and certain existing non-emergency engines (see below) must cut exhaust levels of carbon monoxide by 70 percent or more.   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 limits and operating limits

  • Non-Emergency Diesel (compression-ignition or CI) Engines by May 3, 2013.
  • Non-Emergency Gas (spark-ignition or SI) Engines by Oct. 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 horsepower (HP) will require a diesel oxidation catalyst (DOC) on the exhaust side and crankcase ventilation controls; 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 semi-annually that the specified emission limits have been met.

Be aware 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; the management practices generally apply to non-emergency engine < 300 HP and emergency engines of any size. 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.

As previously reported in AGC’s Environmental Observer, AGC has prepared a summary of the NESHAP requirements for existing stationary diesel (compression-ignition or CI) RICE, as well as a much more in-depth fact sheet(AGC has made preliminary updates to its fact sheet – first released a year ago – to reflect EPA’s 2013 RICE NESHAP amendments, as described below.)  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—

2013 RICE NESHAP Amendments

On Jan. 30, EPA published revisions to standards for stationary RICE to address legal challenges brought by regulated industries. The biggest dispute over the rule was the extent to which it would allow backup diesel generators to run for emergency demand response purposes and be considered emergency engines.  Among other changes, the amendments specify how the standards apply to emergency engines used for emergency demand response.  EPA published a proposal last June to allow backup generators to run for up to 100 hours for emergency demand response purposes without being subject to emissions limits. Both the Electric Power Supply Association and environmentalists raised concerns about allowing such extensive use of backup generators.

In the final revisions and summarized in EPA’s Fact Sheets (overview fact sheet and fact sheet on emergency engines), EPA will allow backup stationary engines that generate electricity to run without emissions controls for 100 hours per year during electricity peak-use periods and emergencies, but the engines must use ultralow-sulfur diesel fuel beginning in 2015, according to the final rule.

Briefly, other amendments will—

  • Replace the numerical emissions limits for existing area source, spark ignition engines above 500 horsepower in populated areas with requirements to install catalytic controls with an initial test and annual performance test checks of the catalyst and to equip the engine with a high temperature shutdown device or monitor the catalyst inlet temperature continuously;
  • Subject existing area source, spark ignition four-stroke engines above 500 HP that are not located in populated areas to management practice standards;
  • Allow certain compression ignition engines scheduled for replacement – due to state or local rules – to meet management practices rather than emissions limits until January 1, 2015 (or 12 years after installation date, but not later than June 1, 2018);
  • Add a 30 percent reduction of total hydrocarbon emissions as an alternative for demonstrating compliance with the formaldehyde emissions limit for 4-stroke, rich burn, spark ignition engines above 500 HP;
  • Subject existing area source, compression ignition, non-emergency engines above 300 HP on offshore drilling vessels to management practice requirements; and
  • Broaden the definition of “remote areas of Alaska” to allow wider use of the option to comply with management practices rather than emissions limits.

The final revised rule will reduce the capital and annual costs of the original 2010 rules by $287 million and $139 million, respectively, according to EPA.

Webinar Registration

EPA is hosting free webinars on the RICE NESHAP rule, including the revisions published Jan. 30.  Space is limited. Registration and log-on to the webinar will be first come, first served. Follow one of these links to register online:

For questions about webinar registration, contact Jorge Burgos at 617-918-1790 or burgos.jorge@epa.gov.  For questions about the webinar program, contact Roy Crystal at 617-918-1745 or crystal.roy@epa.gov.

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 spark ignition 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.

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

________________________________________
[1]According to EPA’s regs [40 CFR 63, Subpart ZZZZ] “stationary” means… NOT used in a motor vehicle and NOT a nonroad engine.

“Nonroad engines” (as defined at 40 CFR 1068.30) are:
• Self-propelled (tractors, bulldozers)
• Propelled while performing their function (lawnmowers)
• Portable or transportable (has wheels, skids, carrying handles, dolly, trailer, or platform)  Note: a “portable nonroad engine” become stationary if it stays in one location for more than 12 months (note different time criteria for seasonal source).


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