This webinar by James Westbrook of BlueScape and Scott McBryde of MIRATECH provides an update on the compliance requirements of the RICE NESHAP, 40 CFR 63 Subpart ZZZZ as applied to stationary compression ignition and spark-ignited reciprocating internal combustion (RICE) engines located at industrial facilities, including major and area sources of hazardous air pollutants. The goal of the webinar is to help companies understand where their engines fit with the regulation, and identify possible compliance alternatives. For more information, Mr. Westbrook can be reached at 877-486-9257 or jwestbrook@bluescapeinc.com, and Mr. McBryde can be reached at 909-821-0039 or smbryde@miratechcorp.com. Also see www.bluescapeinc.com and miratechcorp.com.
BueScape & MIRATECH EPA RICE NESHAP the Meter is Running Webinar 4-08-14
1. EPA Stationary RICE NESHAP:
The
Meter
is
Running
BlueScape and MIRATECH
James Westbrook and Scott McBryde
April 8, 2014
2. Agenda
• Review
Typical
Engine
Use
• NESHAP
Rule
Introduc?on
• Applicability
and
Exemp?ons
• Compliance
Requirements
• Emission
Control
and
Monitoring
• Summary
3. Typical
Engine
Use
Primary
modes:
• Emergency
Standby
Use
– Backup
for
water
pumps
– Emergency
power
for
support
facili?es
– Surge
protec?on
– Black
start
– U?lity
emergency
demand
response
programs
• Non-‐Emergency
Standby
and
“Prime”
Use
– Compress
gas,
move
water
– Reduce
electricity
cost
– Greater
efficiency
&
reliability
• U?lity
reliability,
economic
incen?ves
Engine
Types:
• (RICE)
Reciproca?ng
Internal
Combus?on
Engine
– (CI)
Compression
Igni?on,
diesel
– (SI)
Spark
Igni?on,
natural
gas
4. RICE
NESHAP
Introduc?on
• Na?onal
Emission
Standards
for
Hazardous
Air
Pollutants
for
Reciproca?ng
Internal
Combus?on
Engines
• Regula?on
40
CFR
Part
63
Subpart
ZZZZ
• CI
RICE
compliance
by
May
3,
2013
• SI
RICE
compliance
by
October
19,
2013
• Upcoming:
April
17,
2014,
performance
tes?ng
due
for
large
gas
engines
• EPA
Resources:
– www.epa.gov/`n/atw/icengines/
– www.epa.gov/region1/rice/#RuleApplicability
– h`p://www.epa.gov/`n/atw/icengines/docs/
20130919complianceinfo.pdf
5. Federal
Engine
Rules
• NESHAP
for
Exis?ng
CI
and
SI,
40
CFR
Part
63
Subpart
ZZZZ
– >
500
hp
at
major
source
of
HAP:
• Exis?ng
Engines
constructed
before
12/19/02
• New
Engines
constructed
on
or
aeer
12/19/02
– ≤
500
hp
at
major
source
of
HAP
or
all
at
area
source
of
HAP
• Exis?ng
Engines
constructed
before
6/12/06
• New
Engines
constructed
on
or
aeer
6/12/06
• NSPS
for
New
SI,
40
CFR
60
Subpart
JJJJ
• NSPS
for
New
CI,
40
CFR
Subpart
IIII
• State
Rules
can
be
more
stringent
– CA
Air
Toxics
Control
Measure
(ATCM)
6. Lots
of
Variables
–
Let’s
Make
it
Easier!
Review
Variables
CI
SI
Exempt
Mobile,
Portable,
or
Emergency
X
X
Major
Source,
Area
Source
of
HAPs
X
X
New,
Exis?ng,
Reconstructed
X
X
Emergency,
Non-‐Emergency,
Black
Start
X
X
100
hp,
300
hp,
500
hp
X
<=500
hp,
>500
hp
X
2-‐stroke,
4-‐stroke
X
Lean-‐burn,
Rich-‐burn
X
Remote,
Non-‐Remote
X
Non-‐Limited,
Limited
Use
X
X
Low-‐Sulfur,
Ultra-‐low
Sulfur
Diesel
X
7. Exemp?ons
from
RICE
NESHAP
• Motor
Vehicles
or
Portable
Non-‐Road
Engines
– Portable
engines
sta?onary
if
at
one
loca?on
12
months
• Exis?ng
Emergency
Engines
– Residen?al,
commercial,
ins?tu?onal
area
sources
– Used
<=
15
hrs/year
for
emergency
demand
response,
not
used
for
local
reliability
– >
15
hrs/year
meet
Subpart
ZZZZ
opera?onal
requirements,
100
hours
per
year
for
any
of:
• Tes?ng
and
Maintenance
• Emergency
demand
response
when
blackout
imminent
• 50
hrs/year
for
non-‐emergency,
local
reliability
– Electronic
repor?ng
to
EPA
star?ng
3/31/16
8. RICE
NESHAP
Applicability
Engines
at
HAP
major
sources
Non-‐Emergency
SI,
>500
hp,
HAP
area
source
Non-‐Emergency
CI,
SI
<500,
remote,
HAP
area
source
Emergency
CI
>500
hp,
HAP
area
source
Emergency
CI,
SI,
HAP
area
source
<500
hp
REQUIREMENTS
9. Emission
Standards:
Exis?ng
RICE
at
Major
Sources
HP
Engine
Subcategory
Non-‐emergency
Emergency
Cl
SI
2SLB
SI
4SLB
SI
4SRB
SI
LFG/DG
<100
Change
oil
and
filter
and
inspect
cleaner
(CI)
or
spark
plugs
(SI)
every
1,000
hours
of
opera?on
or
annually;
inspect
hoses
and
belts
every
500
hours
of
opera?on
or
annually
Change
oil/
filter
&
inspect
hoses/belts
every
500
hours
or
annually;
inspect
air
cleaner
(CI)
or
spark
plugs
(SI)
every
1,000
hours
or
annually
100
-‐
300
230
ppm
CO
225
ppm
CO
47
ppm
CO
10.3
ppm
CO
177
ppm
CO
300
-‐
500
49
ppm
CO
or
70%
CO
reduc[on
>500
23
ppm
CO
or
70%
CO
reduc[on
No
standards
No
standards
350
ppb
HCHO
or
76%
HCHO
reduc[on
No
standards
No
standards
Note:
Exis?ng
limited
use
engines
>500
HP
at
major
sources
do
not
meet
any
emission
standards.
Exis?ng
black
start
engines
≤500
HP
at
major
sources
must
meet
work
prac?ce
standards.
10. HP
Engine
Subcategory
Non-‐emergency
Emergency
or
Black
Start
Cl
SI
2SLB
SI
4S
in
remote
areas
SI
4S
not
in
remote
areas
SI
LFG/DG
≤300
Change
oil/filter
&
inspect
air
cleaner
every
1,000
hours
or
annually;
inspect
hoses/belts
every
500
hours
or
annually
Change
oil/
filter,
inspect
spark
plugs,
&
inspect
hoses/belts
every
4,320
hours
or
annually
Change
oil/
filter,
inspect
spark
plugs,
&
inspect
hoses/
belts
every
1,440
hours
of
opera?on
or
annually
Change
oil/
filter,
inspect
spark
plugs,
&
inspect
hoses/
belts
every
1,440
hours
of
opera?on
or
annually
Change
oil/
filter,
inspect
spark
plugs,
&
inspect
hoses/belts
every
1,440
hours
of
opera?on
or
annually
Change
oil/
filter
&
inspect
hoses/belts
every
500
hours
or
annually;
inspect
air
cleaner
(CI)
or
spark
plugs
(SI)
every
1,000
hours
or
annually
300
-‐
500
49
ppm
CO
or
70%
CO
reduc[on
>500
23
ppm
CO
or
70%
CO
reduc[on
Change
oil/filter,
inspect
spark
plugs,
&
inspect
hoses/belts
every
2,160
hours
of
opera?on
or
annually
If
engine
used
>24
hrs/yr:
4SLB:
Install
oxida[on
catalyst
4SRB:
Install
NSCR
Emission
Standards:
Exis?ng
RICE
at
Area
Sources
11. HP
Engine
Subcategory
Non-‐emergency
Emergency
Cl
SI
2SLB
SI
4SLB
SI
4SRB
SI
LFG/DG
<250
Comply
with
CI
NSPS
Comply
with
SI
NSPS
Comply
with
SI
NSPS
Comply
with
SI
NSPS
Comply
with
SI
NSPS
Comply
with
CI/SI
NSPS
250
-‐
500
14
ppm
HCHO
or
93%
CO
reduc?on
>500
580
ppb
HCHO
or
70%
CO
reduc?on
12
ppm
HCHO
or
58%
CO
reduc?on
350
ppb
HCHO
or
76%
HCHO
reduc?on
No
standards
No
standards
Notes:
1.
New
limited
use
engines
>500
HP
at
major
sources
do
not
meet
any
emission
standards
under
the
NESHAP.
2.
New
RICE
at
Area
Sources
meet:
CI:
Part
60
Subpart
IIII;
SI:
Part
60
Subpart
JJJJ
Emission
Standards:
New
RICE
at
Major
Sources
12. Engine
Subcategory
Compliance
Requirements
Exis[ng
non-‐emergency:
• CI
≥100
HP
at
major
source
• CI
>300
HP
at
area
source
• SI
100-‐500
HP
at
major
source
• Ini?al
emission
performance
test
(*)
o Subsequent
performance
tes?ng
every
8,760
hours
of
opera?on
or
3
years
for
engines
>500
HP
(5
years
if
limited
use)
o Opera?ng
limita?ons
-‐
catalyst
pressure
drop
and
inlet
temperature
for
engines
>500
HP
o No?fica?ons
o Semiannual
compliance
reports
(annual
if
limited
use)
• Exis?ng
non-‐emergency
CI
>300
HP:
o Ultra
low
sulfur
diesel
(ULSD)
o Crankcase
emission
control
requirements
• Exis[ng
non-‐emergency
SI:
4SLB/4SRB
>500
HP
at
area
source
used
>24
hours/year
and
not
in
remote
area
• Ini?al
performance
test
(*)
• Annual
compliance
demonstra?on
• High
temperature
engine
shutdown
or
con?nuously
monitor
catalyst
inlet
temperature
• No?fica?ons
• Semiannual
compliance
reports
Most
Compliance
Requirements
(*)
Waiver
of
performance
test
can
be
requested
13. Engine
Subcategory
Compliance
Requirements
Exis[ng
non-‐emergency:
• SI
4SRB
>500
HP
at
major
source
New
non-‐emergency:
• SI
2SLB
>500
HP
at
major
source
• SI
4SLB
>250
HP
at
major
source
• SI
4SRB
>500
HP
at
major
source
• CI
>500
HP
at
major
source
• Ini?al
emission
performance
test
o Subsequent
performance
tes?ng
semiannually
(can
reduce
frequency
to
annual)
(subsequent
performance
tes?ng
required
for
4SRB
engine
complying
with
formaldehyde
%
reduc?on
standard
if
engine
is
≥5000
HP)
o Opera?ng
limita?ons
-‐
catalyst
pressure
drop
and
inlet
temperature
o No?fica?ons
o Semiannual
compliance
reports
Most
Compliance
Requirements
14. Engine
Subcategory
Compliance
Requirements
Exis[ng
emergency/black
start:
• <100
HP
at
major
source
• ≤500
HP
at
major
source
• All
at
area
source
Exis[ng
non-‐emergency:
• <100
HP
at
major
source
• CI
≤300
HP
at
area
source
• SI
≤500
HP
at
area
source
• SI
2SLB
>500
HP
at
area
source
• SI
LFG/DG
>500
HP
at
area
source
• SI
4SLB/4SRB
>500
HP
at
area
source
used
≤24
hours/year
or
in
remote
area
• Operate/maintain
engine
&
control
device
per
manufacturer’s
instruc?ons
or
owner-‐developed
maintenance
plan
• May
use
oil
analysis
program
instead
of
prescribed
oil
change
frequency
• Emergency
engines
must
have
hour
meter
and
record
hours
of
opera?on
• Keep
records
of
maintenance
• No?fica?ons
not
required
• Repor?ng
and
ULSD
for
emergency
engines
used
for
emergency
demand
response
or
local
reliability
Less
Compliance
Requirements
LFG/DG
=
landfill
gas
/
digester
gas
15. Engine
Subcategory
Compliance
Requirements
• New
emergency/limited
use
>500
HP
at
major
source
• Ini?al
no?fica?on
• Repor?ng
and
ULSD
for
emergency
engines
used
for
emergency
demand
response
or
local
reliability
• New
non-‐emergency
LFG/DG
>500
HP
at
major
source
• Ini?al
no?fica?on
• Monitor/record
fuel
usage
daily
• Annual
report
of
fuel
usage
Less
Compliance
Requirements
16. Catalyst
Required?
• Yes,
most
engines
will
need
CO
or
VOC
catalyst
• One
year
compliance
extensions
were
allowed
– 1/3/13
for
CI;
6/21/13
for
SI
• Catalyst
installa?on
requires:
– Air
permi{ng
process
– Establish
performance
parameters
– Complete
ini?al
and
ongoing
performance
tes?ng
– Following
a
compliance
plan
• Alterna?ves
to
catalyst:
– Take
an
enforceable
permit
restric?on,
area
source
– Re-‐categorize
to
an
emergency
engine
– Engine
replacement
– Electrifica?on
17. CPMS
and
SSMP
• Con?nuous
Parameter
Monitoring
System
(CPMS)
– Table
5
of
Subpart
ZZZZ
-‐
install,
operate,
and
maintain
a
CPMS
– CPMS
operated
according
to
a
Site-‐Specific
Monitoring
Plan
(SSMP)
– Collect
data
once
every
15
min;
4-‐hr
rolling
avgs;
1-‐hr
block
avg
values
– Temperature
range
–
5
deg
F
or
1%
of
measurement
range,
whichever
larger
– Pressure
drop
tolerance;
2
inches
of
water
from
measured
during
test
– Evalua?on,
system
accuracy
audits,
other
audit
procedures
annually
– Performance
evalua?on
of
each
CPMS
parameter
• Site-‐Specific
Monitoring
Plan
(SSMP):
– The
performance
criteria
and
design
specifica?ons
for
the
monitoring
system
equipment,
including
the
sample
interface,
detector
signal
analyzer,
and
data
acquisi?on
and
calcula?ons
– Sampling
interface
(e.g.,
thermocouple)
loca?on
such
that
the
monitoring
system
will
provide
representa?ve
measurements
– Equipment
performance
evalua?ons,
system
accuracy
audits,
or
other
audit
procedures
– Ongoing
opera?on
and
maintenance
procedures
– Ongoing
repor?ng
and
recordkeeping
procedures
18. Quiz
–
Pump
Sta?on
Facility
Exis?ng
Area
Source
of
Hazardous
Air
Pollutants,
Non-‐Remote
1. Two
x
Non-‐Emergency
SI
Engines,
2,160
hp
4SLB,
no
CO
catalyst
installed
–
con?nuous
drive
pumps
2. Two
x
Emergency
Backup
CI
Engines,
465
hp,
no
CO
catalyst
installed
-‐
facility
reliability
19. Let’s
Review
–
In
Compliance?
• Have
you
surveyed
engines,
know
where
they
fit?
Know
your
compliance
deadlines?
• Good
recordkeeping
procedures,
esp.
hours,
how
engine
used
and
maintenance
records?
• Have
you
done
Ini?al
No?fica?ons?
Filed
Compliance
Reports?
• Permi`ed
equipment
changes
for
catalyst,
or
changed
permit
condi?ons?
• Installed
catalyst,
replaced
engine,
electrify?
• Completed
the
Ini?al
Performance
Test?
• Established
monitoring
parameters,
installed
meters,
scheduling
maintenance?
• If
installed
catalyst,
CPMS
or
shut
down
device?
• If
CPMS,
Site-‐Specific
Monitoring
Plan?
23. Serviceable Catalytic Converter –
Proven and Straightforward
q Oxidizes CO up to 95%, can easily meet NESHAP requirements
q Up to 80% formaldehyde (CH2O) reduction
q Carbon Steel or 304SS housings in many diameters sized to engine
q Benefits
o Serviceable and removable catalyst
o up to 9,000 hrs operation before a cleaning may be needed
o ½” NPT sample ports in both necks & pre and post catalyst
o Durable, metal foil catalyst designed for industrial engines
o Up to 2500 HP engines
Slide # 23
24. Integrated Silencer Catalytic Converter
q Same catalyst features as the base converter
q Good option for NESHAP retrofits as usually there is an existing
silencer in place
o New unit can fit within the flange to flange space of the existing old silencer
o Silencing Capabilities from 25-45+ dBA
o Custom inlets/outlets, saddles, etc. can be added to customize as needed
25. Large Engines - Ground Access Catalyst/Silencer
q Same catalyst features as the base converter
q Good option for large engine NESHAP retrofits as usually
there is an existing ground access silencer.
o New unit can fit within the location of the existing old GA silencer
o Silencing Capabilities from 25-50+ dBA
o Customization is common, with heat protection added at ground level
o 2500-15,000 HP engines
26. q Catalyst inlet temperature on engines greater than 500 HP is required to be
continuously monitored and recorded by a Continuous Parametric
Monitoring System (CPMS).
q Pressure drop across the catalyst measured on a monthly basis.
q Both inlet temperature and pressure drop across the catalyst must be
measured for the initial performance test.
q Many options exist from all manufacturers that can be customized.
o Basic data logging up to complete SCADA system interfacing capabilties
Continuous Parametric Monitoring System (CPMS)
For Compliance - Data Logging & Recording
PRESSURE
SENSOR
POWER
SUPPLY
DATA
LOGGER
CUSTOME
R POWER
SUPPLY
HOOK-UP
THERMOCOUPLE
TERMINATION
POINTS
27. Crankcase Ventilation (CCV) Systems
q For NESHAP compliance, most stationary engines over 300HP
must be equipped with a crankcase ventilation system.
q Prevents hazardous vented crankcase emissions (Oil Mist and
Particulate) from entering the surrounding atmosphere.
q Two primary types of CCV systems:
Open Closed
Recovered Oil Drained to Used Oil
Container or Crankcase Sump
Depending on Engine OEM Instructions
and Operator’s Discretion
Provides engine and catalyst protection
from oil contamination, simple installation
28. Summary
• The
meter
is
running
are
you
in
compliance?
• Get
a
handle
on
NESHAP
requirements
– Good
engine
database
and
records
• Meet
ini?al
no?fica?on,
performance
tes?ng,
monitoring,
maintenance,
repor?ng
requirements
• Minor
requirements
for
most
equipment
– Mainly
good
records
and
maintenance
• Major
sources,
non-‐emergency
CI
or
SI,
>
500
hp
at
area
sources
–
greater
requirements
– Catalyst
can
be
required,
permit
changes
– Alterna?ves
for
monitoring
and
tes?ng
• BlueScape
and
MIRATECH
can
help
get
you
into
compliance!