Federal Engine Regulations
NSPS JJJJ/NESHAP ZZZZ
Presented to OIPA:
May 11-12 2011
A World of Energy Solutions
NSPS JJJJ
Slide 2
NSPS
• New Source Performance Standards
–
–
–
–
History
Regulates criteria pollutants
Found under Title 40 (Environmental)
Part 60 (NSPS)
• Where can I find these rules?
– Google “Electronic Code of Federal
Regulations”
– Select “Title 40”
– Select “60.1 – End”
– Select desired Subpart
Slide 3
NSPS Subpart JJJJ
• New Source Performance Standards for Stationary Spark
Ignited Internal Combustion Engines
– §60.4230
• NSPS is a federal rule
– Applies to all states
– Is NOT regional
– State rules cannot be less stringent than federal rules
• Effective date – January 18, 2008
– rule is currently in effect
Slide 4
What equipment does this rule affect?
•
•
Spark ignited engines
June 12, 2006 is the magic date
– Anything before this is exempt
•
Rule affects all new, reconstructed or modified engines
– If the engine is not new, reconstructed or modified – the rule does not
apply
•
What is a new engine?
– Any engine ordered after June 12, 2006 AND manufactured after the
following dates:
After Manufacture
Engine type and fuel
Maximum engine power
Non-Emergency Natural Gas
100≤HP<500
7/1/2008
500<HP<1,350
1/1/2008
HP≥500
7/1/2007
HP≥130
1/1/2009
Non-Emergency Lean Burn
Natural Gas
Non-Emergency Natural Gas
(except lean burn
500=≥HP<1,350)
Emergency
date
Slide 5
What exactly is reconstruction?
• Reconstruction – 40 C.F.R. 60.15 (NSPS Subpart A)
• NSPS states that reconstruction means the replacement of
components at an existing facility to such an extent that:
– The fixed capital cost of the components exceeds 50 percent of
the fixed capital cost that would be required to construct a
comparable entirely new like kind facility
• So what does this mean?
– If you spend too much on an overhaul, that engine is now subject
to the rule
– We must track ALL engine overhaul information
– We must know engine “pedigrees”
– Once we lose our exemption, we NEVER get it back
Slide 6
How do we apply reconstruction?
• This is not an engine to engine cost analysis
– We must consider the cost of an entirely new like kind facility
– This means including associated percentages of components that
directly service the engine (skid, cooler, control system, fuel gas
system, oil system, labor to package)
• How do I calculate the like kind facility cost?
– GCA Document
– Utilizes generic $/hp numbers based upon engine HP ranges
– Includes ancillary items (i.e. coolers and skid) as well as
installation costs (i.e. trucking and cranes)
Slide 7
GCA Reconstruction Document
Reconstruc4on
Calcula4on
Engine
Overhaul
Cost
Comparable
En>rely
New
LKFC
=%
Engine
Overhaul
Costs
Engine
repair
(parts
and
labor)
Trucking
and
Li7ing
Commissioning
and
Startup
Labor
LIKE KIND FACILITY COST
Horsepower Range
Ancillary Items ($/HP)
Installation Costs ($/HP)
< 100 HP
$231
$48
100 to 199 HP
$169
$43
200 to 499 HP
$117
$21
500 to 999 HP
$114
$15
1000 to 1750 HP
$78
$11
Slide 8
Modification
• NSPS affects all new, reconstructed, and modified engines
• 40 C.F.R. 60.14 (Subpart A) defines a modification as…
– Any physical or operational change to an existing facility which
results in an increase in the emission rate to the atmosphere of
any pollutant to which a standard applies
•
•
•
•
Horsepower increases
Engine conversions
Only applies to modifications AFTER June 12, 2006
Once we lose our exemption, we never get it back
Slide 9
Compliance Requirements
•
•
•
•
What happens if we have a new, reconstructed, or modified engine?
You must comply with NSPS JJJJ
Emission Limits (table on next slide)
Maintenance Plans
– Must ensure and document that the engine is operated in a manner
consistent with good air pollution control practice
•
Performance Testing
– Initial and subsequent performance tests (reference method testing)
– Must submit notifications and results by deadlines or will be referred to
enforcement
•
Recordkeeping
– Maintenance, testing, notifications
•
•
Notifications
Permitting (state by state requirements)
Slide 10
Emission Limits – New Engines
Engine type and
fuel
Emergency
Non-Emergency
Natural Gas
Non-Emergency
Lean Burn Natural
Gas
Non-Emergency
Natural Gas and
(except lean burn
500=≥HP<1,350)
Emergency
Non-Emergency
Natural Gas
Non-Emergency
Lean Burn Natural
Gas
Non-Emergency
Natural Gas
(except lean burn
500=≥HP<1,350)
After
Maximum engine
Manufacture
power
date
25>HP<130
1/1/2009
100≤HP<500
7/1/2008
500<HP<1,350
1/1/2008
HP≥500
7/1/2007
HP≥130
1/1/2009
100≤HP<500
1/1/2011
500<HP<1,350
7/1/2010
HP≥500
7/1/2010
NOX
c10
Emission standardsa
g/HP-hr
ppmvd at 15% O2
d
CO
VOC
NOX
CO
VOCd
387
N/A
N/A
N/A
N/A
2
4
1
160
540
86
1
2
0.7
82
270
60
Slide 11
Emission Limits – Reconstructed/Modified
Emission standards
Prior to
Engine type
Maximum
Manufacture
and fuel
engine power
date
ppmvd at 15%
O2
g/HP-hr
NOX CO VOC NOX CO VOC
Reconstructed/
Modified
Natural Gas
Reconstructed/
Modified
Emergency
HP<500
7/1/2008
HP≥500
7/1/2007
HP>130
1/1/2009
Otherwise
3
4
1
250
540
86
Refer to New Engine Standards
Slide 12
Expected Changes
• 2010/2011 Emission limits
• EPA has proposed changes
• Modified rule will attempt to provide clarity to several
existing issues
• Final rule this summer
Slide 13
RICE MACT NESHAP
Slide 14
NESHAP ZZZZ
• National Emission Standards for
Hazardous Air Pollutants
–
–
–
–
–
History
Regulates HAP (formaldehyde for us)
Maximum Available Control Technology
Found under Title 40 (Environmental)
Part 63 (NESHAP/MACT)
• Where can I find these rules?
– Google “Electronic Code of Federal
Regulations”
– Select “Title 40”
– Select “63.6580 – 63.8830”
– Select desired Subpart (ZZZZ)
Slide 15
Affected Equipment
• The rule primarily regulated engines at major sources of
HAP
– 10 tons/year of a single HAP or 25 tons/year of a combination
– Formaldehyde is usually what gets us (lean burns)
– 3,500 LB HP is a good estimate of what will get you > 10 TPY
• 15,000 RB HP will get you > 10 TPY
• Strategy of over controlling to get out of rule applicability
• Geographic boundaries
– Federal rule – applies everywhere
Slide 16
Final Rule for Area Sources – Nov. 2013
•
4 Stroke Rich burn engines > 500 HP will require emission controls
– 76% reduction of CH2O
•
4 Stroke Lean burn engine > 500 HP will require emission controls
– 93% reduction of CO
•
Emissions testing
– Method 320 will still be allowed (based on comparative testing submitted
to EPA)
– > 500 HP must test initially (within 180 days) and every 8,760 run hours
•
Continuous Monitoring
– Continuous catalyst inlet temperature readings (at least 1x/15 min.)
• 4 hour rolling averages
• Temperature to stay between 450 and 1350 deg F for 4SLBs and
between 750 and 1250 deg F for 4SRBs
– Monthly Pressure Drop readings across the catalyst
Slide 17
Final Rule
• Management Practices
– 4 stroke engines < 500 HP must inspect oil and spark plugs every
1,440 hours
– 2 stroke engines must inspect oil and spark plugs every 4,320
hours
– Recordkeeping requirements – Compliance Demonstration
– Engine Oil Analysis Program
• Analyze Total Acid Number, Viscosity, and % Water Content
• Critical Change Levels (likely never reached)
• Startup Requirements
– Minimize idle time and startup condition to less than 30 min.
Slide 18
Final Rule
• Notifications/Reporting
– Semiannual reports will be required for all engines with numerical
emission limitations (4SRB/4SLBs > 500 HP at area sources)
– Notice of Compliance Status (Initial)
– Notification of Performance Testing
– Notification of Applicability Due February 16, 2011
• New/Reconstructed Engines will comply with JJJJ in lieu
of ZZZZ
Slide 19
RICE MACT Questions?
Slide 20