Transcript (60 Subpart JJJJ) NESHAP - Montana Petroleum Association

New Emission Rules for IC Engines
Presented by
Scott Wallace
Devon Gas Services, L.P.
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)
(< 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 (< 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
Engine Size
hp
Manufactured Date
NOx
g/hp-hr
CO
g/hp-hr
VOC
g/hp-hr
Excludes H2CO
25 hp – 100 hp
07/01/2008
2.8
4.8
**
100 hp – 500 hp
07/01/2008
2.0
4.0
1.0
100 hp – 500 hp
01/01/2011
1.0
2.0
0.7
> 500 hp Rich Burn
07/01/2007
2.0
4.0
1.0
500 hp -1350 hp
Lean Burn
01/01/2008
2.0
4.0
1.0
> 1350 hp
Lean Burn
07/01/2007
2.0
4.0
1.0
>500 hp
Rich or Lean
07/01/2010
1.0
2.0
0.7
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NSPS General Certification
Criteria
● Manufacture’s 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
manufacture’s
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:
– < 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.
– > 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 > 500 HP
● Notification at least 30 days prior to emissions testing
● Certified engines require manufacturer’s 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/ricepg.html
Fact sheet
– http://www.epa.gov/ttn/oarpg/t1/memoranda/SI%20and%20RICE%2
0fact%20sheet%2012%2020%2007%20Scout.pdf
Rule
– http://www.epa.gov/ttn/oarpg/t1/memoranda/SI%20NSPS%20NESH
AP%20FRM%2012-20-07.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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Thank You.