Connecticut Department of Energy and Environmental

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Connecticut Department of
Connecticut
Department of
Energy and Environmental Protection
The New Maze of Air Regulations
Th
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for Boilers and Engines: A Map
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for Small Businesses
June 19, 2013
Keith M. Hill, CT DEEP
CBIA’s Annual Environmental & Energy Conference
Connecticut Department of Energy and Environmental Protection
Presentation Overview
• Overview of EPA’s Area Source Rule for Boilers – National Emission Standard for Hazardous Air Pollutants (NESHAP) for Area Sources: Industrial, Commercial, and Institutional Boilers, 40 CFR Area
Sources: Industrial Commercial and Institutional Boilers 40 CFR
Part 63 Subpart JJJJJJ (6J)
• Overview of EPA
Overview of EPA’ss Regulations for Stationary Engines Regulations for Stationary Engines
– National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating Internal Combustion Engines (RICE), 40 CFR part 63 subpart ZZZZ (Area Sources)
63 subpart ZZZZ (Area Sources)
– New Source Performance Standards (NSPS) for Stationary Compression Ignition (CI) Internal Combustion Engines (ICE), 40 CFR part 60 subpart IIII
– New Source Performance Standards for Stationary Spark Ignition (SI) ICE, S
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40 CFR part 60 subpart JJJJ Connecticut Department of Energy and Environmental Protection
Area Source Boiler Rule
40 CFR Part 63 Subpart JJJJJJ (6J)
40 CFR Part 63 Subpart JJJJJJ (6J)
Connecticut Department of Energy and Environmental Protection
Boiler Rules
• National Emission Standard for Hazardous Air Pollutants (NESHAP) for Area Sources: Industrial Commercial and Institutional Boilers 40 CFR
Area Sources: Industrial, Commercial, and Institutional Boilers, 40 CFR Part 63 Subpart JJJJJJ (6J)
– Final Rule published March 21, 2011
– Final Rule amendments published February 1, 2013
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• NESHAP for Major Source Industrial, Commercial, Institutional Boilers and Process Heaters, 40 CFR Part 63 Subpart DDDDD (5D)
– Final Rule published March 21, 2011
– Final Rule amendments published January 31, 2013
Connecticut Department of Energy and Environmental Protection
Of 1.5 million boilers in the U.S., less than 1% will need to meet
numerical emission limits under the Boiler NESHAPs
<1% (about 2,300) would need to
meet numerical emission limits to
minimize toxics
toxics. Most of these are
larger boilers located at industrial
facilities.
~197,000
covered by rules
~1.3 million boilers not covered by rules
13% (about 197,000) would
need to follow work practice
standards such as annual tune
standards,
ups, to minimize toxics.
86% are clean and not covered by
these rules. Many of these boilers are
at places like hospitals, schools and
churches.
Connecticut Department of Energy and Environmental Protection
Connecticut Boilers
In 2011, there were ~40,000 non‐
residential boilers / hot water heaters registered at ~14,000 sources in CT.
Source: DCP, Bureau of Boilers
Connecticut Department of Energy and Environmental Protection
Why is EPA regulating Boilers?
TTo reduce toxic emissions and protect human health
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• Burning biomass, coal, and oil results in emissions of mercury, dioxin, furans, formaldehyde, lead, and hydrochloric acid.
• Health effects are significant: – Mercury can cause adverse effects on children’s developing brains, including effects on IQ, learning and memory. – Air toxics can cause cancer and other serious health effects in adults Air toxics can cause cancer and other serious health effects in adults
and children. – Controlling air toxics will also reduce fine particle pollution and carbon monoxide. • Fine particles are linked to serious cardiovascular and respiratory effects, even premature death.
• Carbon monoxide reduces oxygen delivery to heart and yg
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brain, can cause angina and other problems for people with heart disease.
Connecticut Department of Energy and Environmental Protection
Area Sources – What are they?
• Small stationary sources of air toxics
• A
Any source that emits some hazardous air th t
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pollutant (HAP) but is not a major source of HAP HAP
• “Has
Has a potential to emit less than 10 tpy for a a potential to emit less than 10 tpy for a
single HAP or less than 25 tpy for combined HAP
HAP”
Connecticut Department of Energy and Environmental Protection
Are Source Boiler Rule: Applicability • A
Applies to an area source facility which emits or has li t
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potential to emit less than 10 tons per year (tpy) of any single HAP and less than 25 tpy of any combination of HAP.
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• Expected to apply to about 183,000 boilers located primarily at commercial facilities (e.g., hotels, office i
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buildings, restaurants) and institutional facilities (e.g., schools, universities, hospitals, prisons), as well as industrial facilities.
• Rule applies to coal, biomass, and oil‐fired boilers. Rule does NOT apply to boilers that are gas‐fired, as defined.
Connecticut Department of Energy and Environmental Protection
Area Source Boiler Rule
•
Three subcategories based on design type:
– Coal-fired units
• 3,700 units
– 2% of area source boilers
– 85% less than 10 million Btu/hr
– Biomass-fired units
• 11,000 units
– 6% of area source boilers
– 68% less than 10 million Btu/hr
– Liquid fuel-fired units
• 168,000 units
– 92% of area source boilers
– 95% less than 10 million Btu/hr
Connecticut Department of Energy and Environmental Protection
Area Source Subcategories • Oil subcategory
– Any boiler that burns any liquid fuel and is not in biomass or coal subcategories Gas‐fired
coal subcategories. Gas
fired boilers that burn liquid fuel during boilers that burn liquid fuel during
periods of gas curtailment, gas supply interruption, startups, or periodic testing up to 48 hours per calendar year not included
• Coal subcategory
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– Any boiler that burns any solid fossil fuel and no more than 15 percent biomass on an annual heat input basis
• Biomass subcategory
– Any boiler that burns any biomass and is not in the coal subcategory
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Connecticut Department of Energy and Environmental Protection
Are any boilers not subject to Subpart 6J?
•
•
•
•
Hot water heaters with a capacity of no more than 120 gallons combusting
oil, gas or biomass. Gas, oil, and biomass hot water boilers (e.g., not generating steam) rated at less than 1.6 million Btu per hour are included in this definition and not covered by the rule
and not covered by the rule
Gas-fired boilers that burn gaseous fuels not combined with any solid
fuels, burns liquid fuel only during periods of gas curtailment, gas supply
interruptions,
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, startups,
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periodic testing
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fuel. Periodic testing
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liquid fuel shall not exceed a combined total of 48 hours during any calendar
year.
Residential boilers intended primarily for heat or power for a residential unit of up to four families, or a single unit residence that has been converted or f
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subdivided into apartments or condos
Temporary boilers used temporarily in place of another boiler while that
unit is being replaced or repaired
repaired, generally over an operational period of
less than 12 months, unless an extension approved
Connecticut Department of Energy and Environmental Protection
Are any boilers not subject to Subpart 6J? (cont’d)
•
•
•
Electric boilers
Boilers regulated under another Part 63 rule
Boilers burning
g waste and covered under incinerator rules
– Any boiler specifically listed as an affected source in another
standard(s) established under section 129 of the Clean Air Act.
– A boiler required to have a permit under section 3005 of the Solid Waste
Disposal Act or covered by subpart EEE of this part (e.g., hazardous
waste boilers).
•
•
•
Research and development boilers
Process heaters
Boilers used as a control device to comply with another subpart of
part 60, 61, 63, or 65
– provided that at least 50 percent of the heat input to the boiler is
provided by the gas stream that is regulated under another subpart.
Connecticut Department of Energy and Environmental Protection
Existing vs. New & Large vs. Small Existing Small Boiler
New Small Boiler
Commenced
construction/
reconstruction on
or before
6/4/2010
and
<10 MMBtu/hr
Commenced
construction/
reconstruction or
switched from
natural gas fuel to
biomass or liquid
fuel after
6/4/2010
and
<10 MMBtu/hr
Existing Large Boiler
New Large Boiler
Commenced
construction/
reconstruction on
or before
6/4/2010 and
≥10 MMBtu/hr
Commenced
construction/
reconstruction or
switched from
natural gas fuel to
biomass or liquid
fuel after
6/4/2010
and
≥10 MMBtu/hr
Connecticut Department of Energy and Environmental Protection
1 An existing dual‐fuel fired boiler meeting the definition of gas‐fired boiler that meets the applicability requirements of subpart JJJJJJ after June 4, 2010 due to a fuel switch from gaseous fuel to solid fossil fuel, biomass, or liquid fuel is considered to be an existing source under this subpart as long as the boiler was designed to accommodate the alternate fuel.
Connecticut Department of Energy and Environmental Protection
2
A new or reconstructed dual-fuel gas-fired boiler that meets the applicability criteria of subpart JJJJJJ after June 4, 2010 due to a fuel switch from gaseous fuel to
solid fossil fuel, biomass, or liquid fuel is considered to be a new source.
3 New oil-fired boilers that combust only oil with no more than 0.50 weight % sulfur or a mixture of 0.50 weight % sulfur oil with other fuels not subject to a PM
emission limit under this subpart and that do not use a post-combustion technology (except a wet scrubber) to reduce PM or SO2 emissions are not subject to the PM
emission limit.
Connecticut Department of Energy and Environmental Protection
Tune‐up Frequency Requirements
• Requiring tune‐ups every 5 years, instead of every 2 years, for:
• Seasonal boilers, oil and biomass boilers which undergo a shut down for at least 7 consecutive months each 12
shut down for at least 7 consecutive months each 12‐
month period due to seasonal conditions, except for period testing (not to exceed 15 days in the 7 month shutdown)
• Limited‐use boilers with a federally enforceable annual average capacity factor of no more than 10 percent
average capacity factor of no more than 10 percent
• Oil‐fired boilers with heat input capacity < 5 MMBtu/hr
• Boilers with oxygen trim systems
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• Initial tune‐ups are not required for new boilers
Connecticut Department of Energy and Environmental Protection
Fuel switch requirements for dual‐fuel fired boilers • Existing dual‐fuel fired boilers (i.e., commenced construction or reconstruction on or before June 4, 2010) that fuel switch fuels from gas to coal, biomass or oil after June 4, 2010 remain existing sources as long as the boiler was designed to
sources, as long as the boiler was designed to accommodate the alternate fuel
• New dual‐fuel fired boilers that make such a fuel switch would continue to be considered new sources
switch would continue to be considered new sources
Connecticut Department of Energy and Environmental Protection
PM alternative for new oil‐fired boilers
New oil‐fired units may combust low sulfur oil* as
an alternative method of meeting the particulate
matter (PM) emission standard (provided the boiler
does not use a post‐combustion control technology
(except a wet scrubber) to reduce PM or sulfur
dioxide emissions).
*< 5 i ht
*< .5 weight percent sulfur content requirements
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Connecticut Department of Energy and Environmental Protection
Area Source: Performance Testing Requirements
• Boilers 10 million Btu/hour or greater with emission limits
Boilers 10 million Btu/hour or greater with emission limits
– Initial and triennial stack testing requirements for PM, mercury, CO (as applicable)
mercury
CO (as applicable)
– Fuel sampling analyses requirements for units subject to a mercury emission limit, except boilers
subject to a mercury emission limit, except boilers burning a single fuel
Connecticut Department of Energy and Environmental Protection
Performance Testing (continued)
– Reducing fuel sampling and performance testing requirements under certain circumstances
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Coal boilers demonstrating initial compliance with the Hg l b il d
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emission limit through fuel sampling: if Hg constituents in the fuel or fuel mixture are measured to < half of the Hg emission limit, no need to conduct further fuel analysis sampling. If > half ,
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of the Hg limit, quarterly sampling required.
» Boilers demonstrating initial compliance with the PM emission limit: if the performance test results show that the PM emissions are <
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half of the PM emission
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Connecticut Department of Energy and Environmental Protection
Area Source: Monitoring Requirements
Boilers 10 million Btu/hour or greater with emission limits
• Establish operating parameter limits during initial tests:
– For example, pressure drop, injection rate, power input, oxygen
• Continuously monitor process parameter or opacity
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• Boilers using a CO continuous emissions monitoring system (CEMS) are exempt from initial CO stack testing y
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and oxygen concentration operating limit
Connecticut Department of Energy and Environmental Protection
Energy Conservation Requirements
•
•
EPA has established pollution prevention (P2) as one of its highest
priorities. One opportunity for P2 lies in simply using energy efficient
technologies to minimize emissions.
Tune-ups
– Applicable to small coal-fired boilers < 10 MMBtu/hr, all biomass-fired
boilers, and all oil-fired boilers.
– Rationale – by improving combustion efficiency, fuel usage is reduced
which results in decreased emissions.
•
Energy Assessment
– Applicable to existing large boilers > 10 MMBtu/hr, except limited use
boilers (with a federally enforceable capacity factor of no more than 10
percent)
– Provides valuable information on improving energy efficiency
– Leads to reductions in emissions through process changes and other
efficiency modifications but energy conservation measures identified are
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not required
Connecticut Department of Energy and Environmental Protection
What are the Tune‐up Requirements?
Tune‐up Requirements:
Tune
up Requirements
• (1) As applicable, inspect the burner, and clean or replace any components of the burner as necessary*
•
(2) Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer’s specifications, if available.
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•
(3) Inspect the system controlling the air‐to‐fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly.*
•
(4) Optimize total emissions of carbon monoxide. This optimization should be consistent with the manufacturer’s specifications, if available, and with any nitrogen oxide requirement
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*you may delay the inspection until the next scheduled unit shutdown, not to exceed 36 months from previous inspection
not to exceed 36 months from previous inspection
Connecticut Department of Energy and Environmental Protection
Tune‐up Requirements (cont’d)
•
(5) Measure the concentrations in the effluent stream of carbon monoxide in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the d
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adjustments are made).
•
(6) Maintain onsite and submit, if requested by the Administrator, biennial (6)
Maintain onsite and submit if requested by the Administrator biennial
or five year report containing this information:
– (i) The concentrations of CO in the effluent stream in parts per million, by volume and oxygen in volume percent measured before and after
by volume, and oxygen in volume percent, measured before and after the tune‐up of the boiler
– (ii) A description of any tune‐up corrective actions taken – (iii) The type and amount of fuel used over the 12 months prior to the (iii) Th
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biennial tune‐up of the boiler, but only if the unit is physically and legally capable of burning more than one fuel
Connecticut Department of Energy and Environmental Protection
Tune‐up Requirements (cont’d)
• (7) If the unit is not operating on the required date for a tune‐up, the tune‐up must be conducted within one 30 days of startup
one 30 days of startup
NOTE: You must conduct the tune‐up while burning the fuel that provided the majority of the heat input to the boiler in the last 12 months before the tune‐
up (or both fuels if the boiler routinely burns two
up (or both fuels if the boiler routinely burns two types of fuels at the same time)
Connecticut Department of Energy and Environmental Protection
Energy Assessment Requirements
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The Basics
• Required for existing oil, biomass, and coal‐fired boilers with design heat input capacity of 10 MMBtu/hr or greater except
design heat input capacity of 10 MMBtu/hr or greater, except limited‐use boilers
• One‐time assessment
• Conducted by qualified energy assessor
• Must be completed by March 21, 2014
– Energy
Energy assessments completed after January 1, 2008 that meet (or are assessments completed after January 1 2008 that meet (or are
amended to meet) requirements may be used in lieu of new assessment and the energy assessor qualifications waived
• Source
Source operating under an energy management system operating under an energy management system
compatible with ISO 50001 satisfies the energy assessment requirement
Connecticut Department of Energy and Environmental Protection
Energy Assessment Requirements
Energy assessments must evaluate the:
• Boiler system 1. Boiler;
1
Boiler; and
and
2. Associated components, such as, the feedwater systems, combustion air systems, fuel systems (including burners), blowdown systems, combustion control systems, steam systems, and condensate return systems, directly connected to and serving the energy use systems
• Energy use systems (meeting energy production threshold)
1. Process heating; compressed air systems; machine drive (motors, pumps, fans); g;
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process cooling; facility heating, ventilation, and air conditioning systems; hot heater systems; building envelope, and lighting; or 2. Other systems that use steam, hot water, process heat, or electricity, provided by the affected boiler
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3. Energy use systems are only those systems using energy clearly produced by affected boilers.
Connecticut Department of Energy and Environmental Protection
Energy Use Systems
• Does not encompass energy use systems located off‐site
• Does not encompass energy use systems using purchased electricity from an off‐site
electricity from an off
site source
source
• Limited to energy use systems:
– Located on‐site; and
– Associated with the affected boiler
• Energy use systems may be segmented in the most logical manner as applicable to specific facility being assessed
manner as applicable to specific facility being assessed
– e.g., heating and cooling system, compressed air systems, production area, or a specific building
Connecticut Department of Energy and Environmental Protection
Energy Assessment Requirements
• Boiler Annual Heat Input
– Heat input capacity for each boiler calculated based on 8,760 hr/yr
– A measurement of the facility
A measurement of the facility’ss total boiler capacity
total boiler capacity
• Add together heat input capacity for each boiler subject to energy assessment requirement
– Measured in Trillion Btu/yr (TBtu/yr)
• Example:
A facility has two (2) existing oil‐fired boilers, each with a heat input
capacity of 10 MMBtu/hr
capacity of 10 MMBtu/hr.
The facility’s Boiler Annual Heat Input would equal: 2 x (10,000,000 Btu/hr x 8,760 hr/yr) = 175,200,000,000 Btu/yr
or 0.1752 TBtu/yr
0 1752 TBt /
Connecticut Department of Energy and Environmental Protection
EA Requirements (cont’d)
•
Using our previous example:
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The two boilers provide energy to five (5) distinct energy use systems, id
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each consuming 20% of the boilers’ output.
With Boiler Annual Heat Input (0.1752 TBtu/yr) < 0.3 Tbtu/yr, only the boilers would need to be included in an energy assessment because none of the energy use systems meet or exceed the 50% threshold.
If, the two boilers provide energy to one (1) energy use system, consuming 100% of the boilers’ output, the boilers and the energy use system would have to be evaluated in an energy assessment.
Connecticut Department of Energy and Environmental Protection
Qualified Energy Assessors
SSomeone who has demonstrated capabilities to evaluate energy h h d
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savings opportunities for steam generation and major energy using systems, including, but not limited to:
i.
ii.
iii.
iv
iv.
vv.
vi.
vii.
viii.
Boiler combustion management.
Boiler thermal energy recovery, including
A. Conventional feed water economizer,
B Conventional combustion air preheater, and
B.
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C. Condensing economizer.
Boiler blow down thermal energy recovery.
Primary energy resource selection including
Primary energy resource selection, including
A. Fuel (primary energy source) switching, and
B. Applied steam energy versus direct‐fired energy versus electricity.
Insulation issues
Insulation issues.
Steam trap and steam leak management.
Condensate recovery.
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Steam end‐use management
Connecticut Department of Energy and Environmental Protection
Qualified Energy Assessors (cont’d)
Capabilities and knowledge includes, but is not limited to:
i.
Background, experience, and recognized abilities to perform the assessment activities, data analysis, and report preparation.
ii. Familiarity with operating and maintenance practices for steam or process heating systems.
iii. Additional potential steam system improvement opportunities including improving steam turbine operations and reducing steam demand
improving steam turbine operations and reducing steam demand.
iv. Additional process heating system opportunities including effective utilization of waste heat and use of proper process heating methods.
v. Boiler‐steam turbine cogeneration systems.
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vi. Industry specific steam end‐use systems.
Connecticut Department of Energy and Environmental Protection
Qualified Energy Assessors (cont’d)
• The qualified energy assessor may be a company employee or outside specialist
• The energy assessor qualification requirement is waived in instances where past or amended energy assessments are used to meet the energy assessment requirement.
– So long as the past or amended energy assessment was completed on or after January 1, 2008
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• Region 1 List of Qualified Energy Assessors
– http://www.epa.gov/boilercompliance/whereyoulive.html#region1
http //www epa gov/boilercompliance/whereyoulive html#region1
Connecticut Department of Energy and Environmental Protection
Energy Management Programs
• Facilities operating under an energy management program compatible with ISO 50001 satisfy energy assessment requirement.
requirement
– Program must include affected boiler, associated components, and applicable energy use systems.
• Must be operating under ISO 50001‐compatible program by compliance date (March 21, 2014)
EPA considers these energy management programs to be
• EPA considers these energy management programs to be equivalent to the one‐time energy assessment
– Programs requires facilities to operate under a set of practices and procedures designed to manage energy use on an ongoing basis.
procedures designed to manage energy use on an ongoing basis.
Connecticut Department of Energy and Environmental Protection
Compliance Dates
• Existing Sources (commenced construction on ,
)
or before June 4, 2010)
– Complete initial tune‐up, compliance with emission limits and energy assessment by March gy
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21, 2014
• New Sources (commenced construction after (
June 4, 2010)
– Must comply by May 20, 2011, or upon startup, ust co p y by ay 0, 0 , o upo sta tup,
whichever is later
Connecticut Department of Energy and Environmental Protection
Notifications and Reports
• Initial Notifications due by January 20, 2014 or within 120 days after the source becomes subject to standard
• Notification of Intent to Conduct Performance Test due Notification of Intent to Conduct Performance Test due at at
least 60 days before the performance stack test
• Compliance Certification Reports must be prepared, by March 1 of each year, and submitted to the delegated authority upon request for the previous calendar year.
– must submit the report by March 15 if you had any deviations from p
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applicable requirements. – For boilers subject only to a requirement to conduct a tune‐up and not subject to emission limits or operating limits, you are only
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prepare a Biennial or Five Year Compliance Report
Connecticut Department of Energy and Environmental Protection
Notifications and Reports
• Notification of Compliance Status (NOCS) due no later than 120 days after the applicable compliance date, unless you must conduct a performance stack test If you must conduct a
conduct a performance stack test. If you must conduct a performance stack test, NOCS due within 60 days of completing the performance stack test.
– e.g., NOCS following the energy assessment and tune‐up is due no later than July 19, 2014 for existing sources
– Rule requires electronic reporting of the NOCS reports using the Compliance and Emissions Data Reporting Interface (CEDRI) through EPA’s Central Data Exchange (www.epa.gov/cdx ), once EPA completes the reporting template. EPA is currently developing a reporting t
template for the NOCS, expected in the fall of 2013. EPA is accepting l t f th NOCS
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paper NOCS only until the electronic reporting template is ready.
Connecticut Department of Energy and Environmental Protection
Notifications and Reports
Fuel switch notification – If you have switched fuels or made a physical change to the boiler
fuels, or made a physical change to the boiler, or have taken a permit limit which results in you being in a different subcategory or
you being in a different subcategory, or becoming subject to Subpart 6J, or no longer being subject to Subpart 6J due to a switch to
being subject to Subpart 6J due to a switch to 100% natural gas, you must provide notice within 30 days of the fuel switch, the physical within 30 days
of the fuel switch the physical
change or the permit issuance
Connecticut Department of Energy and Environmental Protection
New Source Performance Standards (NSPS)
40 CFR Part 60 Subpart Dc, NSPS for Small Industrial‐Commercial‐Institutional (ICI) Steam Generating Units
– Applies to ICI boilers modified, constructed, or reconstructed after June 9, 1989 with a maximum design heat input capacity < 100 MMBtu/hr and >
10 MMBtu/hr
10 MMBtu/hr
• For information on all NSPS Rules for boilers
For information on all NSPS Rules for boilers
– http://www.epa.gov/ttn/atw/nsps/boilernsps/boilernsps.html
Connecticut Department of Energy and Environmental Protection
For More Information
For Information on Area Source Boiler NESHAP Rule:
http://www.epa.gov/boilercompliance/
For Information on Major and Area Source Boiler NESHAP Rules:
http://www.epa.gov/ttn/atw/boiler/boilerpg.html
For Information on Major Boiler MACT Technical Assistance from U.S. DOE’s Clean Energy Application Centers (CEAC)
http://www1 eere energy gov/manufacturing/distributedenergy/boilermact html
http://www1.eere.energy.gov/manufacturing/distributedenergy/boilermact.html
U.S. DOE’s Northeast CEAC
http://www.northeastcleanenergy.org/projectstartup/overview.php
Connecticut Department of Energy and Environmental Protection
Area Source Boiler Contact Information
• For questions from sources in New England:
Susan Lancey, U.S. EPA New England
Susan Lancey, U.S. EPA New England
(617) 918‐1656
• For questions about NESHAP energy assessments in New England: Patrick Bird, U.S. EPA New England
(617) 918‐1287
(617) 918‐1287
Connecticut Department of Energy and Environmental Protection
CT DEEP Contact Information
Compliance Analysis & Coordination Unit
860‐424‐3702
860
424 3702 or
or
deep.cacu@ct.gov
Engineering & Technical Services
860‐424‐4152 (Engineer of the Day)
Connecticut Department of Energy and Environmental Protection
EPA’s Air Quality Regulations for EPA’s
Air Q alit Re lations for
Stationary Engines
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Wednesday, June 19, 2013
Keith M. Hill, CT DEEP
CBIA’s Annual Environmental & Energy Conference
Connecticut Department of Energy and Environmental Protection
EPA’s Stationary Engine Regulations
Connecticut Department of Energy and Environmental Protection
EPA’s Stationary Engine Regulations
National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating Internal Combustion Engines (RICE) 40 CFR part 63 subpart ZZZZ
Engines (RICE) 40 CFR part 63 subpart ZZZZ
New Source Performance Standards (NSPS) for Stationary Compression Ignition (CI) Internal Combustion Engines (ICE)
Compression Ignition (CI) Internal Combustion Engines (ICE), 40 CFR part 60 subpart IIII
New Source Performance New
Source Performance
Standards (NSPS) for Stationary Spark Ignition (SI) ICE, 40 CFR part 60 subpart JJJJ Connecticut Department of Energy and Environmental Protection
Why are Engine Emissions a Concern?
•
Pollutants emitted from stationary engines are known or suspected of causing cancer and other serious health effects: – Aggravation of respiratory and cardiovascular disease
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– Changes in lung function and increased respiratory symptoms
– Premature deaths in people with heart or lung disease
– Benzene and 1,3‐butadiene are known human carcinogens
– Non‐cancer health effects from air toxics may include neurological, cardiovascular, liver, kidney effects, also effects on immune and reproductive systems
•
NOx and VOC can react in the presence of sunlight to form ozone
Connecticut Department of Energy and Environmental Protection
Stationary vs. Mobile
• St
Stationary means not used in a motor vehicle and not a ti
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nonroad engine
– Nonroad engines are: • Self‐propelled (tractors, bulldozers)
• Propelled while performing their function (lawnmowers)
• Portable or transportable (has wheels, skids, carrying handles, dolly, trailer, or l tf
)
platform)
– Portable nonroad becomes stationary if it stays in one location for more than 12 months, or full annual operating period if seasonal source
VS.
Connecticut Department of Energy and Environmental Protection
Applicability
RICE NESHAP
• Applies to stationary CI and SI engines, both existing and new
CI ICE NSPS
• Applies
Applies to stationary CI engines:
to stationary CI engines:
• Ordered after July 11, 2005 and manufactured after April 1, 2006
• Modified or reconstructed after July 11, 2005
SI ICE NSPS
SI ICE NSPS
• Applies to stationary SI engines:
• Ordered after June 12, 2006 and manufactured on/after
• July 1, 2007 if ≥500 HP (except lean burn 500≤HP<1,350)
• January 1, 2008 if lean burn 500≤HP<1,350 January 1 2008 if lean burn 500≤HP<1 350
• July 1, 2008 if <500 HP
• January 1, 2009 if emergency >25 HP
• Modified or reconstructed after June 12, 2006
Connecticut Department of Energy and Environmental Protection
Stationary RICE NESHAP
Stationary
RICE NESHAP
Background Connecticut Department of Energy and Environmental Protection
RICE NESHAP Background
• R
Regulates HAP emissions from stationary RICE at both l t HAP
i i
f
t ti
RICE t b th
major and area sources of HAP
– Major:
Major: ≥10 tons/year single HAP or ≥25 tons/year total ≥10 tons/year single HAP or ≥25 tons/year total
HAP
– Area: not major
Area: not major
• All sizes of engines are covered
Connecticut Department of Energy and Environmental Protection
RICE NESHAP Background
• ONLY ENGINES NOT SUBJECT: ONLY ENGINES NOT SUBJECT: existing emergency engines located at existing emergency engines located at
residential, institutional, or commercial area sources used or obligated to be available ≤15 hr/yr for emergency demand response or voltage/frequency deviation, and not used for local reliability
deviation, and not used for local reliability
– residential: includes homes, apartment buildings
– commercial: includes office buildings, hotels, stores, telecommunications facilities, restaurants, financial institutions, doctor’s offices, sports and performing arts facilities
– iinstitutional: includes medical centers, nursing homes, research centers, institutions of i i
l i l d
di l
i h
h
i i i
f
higher education, correctional facilities, elementary and secondary schools, libraries, religions establishments, police stations, fire stations
More info: http://www.epa.gov/ttn/atw/rice/guidance_emergency_engine_def.pdf
Connecticut Department of Energy and Environmental Protection
General Sub‐categorization Approach
Non-Emergency
Compression
Ignition
(CI)
Emergency
Non Emergency
Non-Emergency
St ti
Stationary
RICE
2-Stroke
Lean Burn
Non-Emergency
4-Stroke
4
Stroke Rich
Burn
Spark Ignition
(SI)
Landfill/Digester
Gas
Emergency
Connecticut Department of Energy and Environmental Protection
4-Stroke
Existing vs. New
Construction commenced before:
>500 HP at major source
≤500 HP at major source, and all HP at area source
Existing
Existing
December 19, 2002
June 12, 2006
June 12, 2006
New
New
Determining construction date: owner/operator has entered into a contractual
g
/ p
obligation to undertake and complete, within a reasonable amount of time, a continuous program for the on‐site installation of the engine
–
Does not include moving an engine to a new location
Connecticut Department of Energy and Environmental Protection
Stationary RICE NESHAP
Stationar
RICE NESHAP
Requirements for Emergency RICE
Requirements for Emergency RICE
Connecticut Department of Energy and Environmental Protection
Emergency Engine Operational Limitations
•
Unlimited use for emergencies (e.g., power outage, fire, flood)
•
100 hr/yr for:
– maintenance/testing – emergency demand response (EDR) emergency demand response (EDR)
when Energy Emergency Alert Level 2 has been declared by Reliability Coordinator
– voltage or frequency deviates by 5% or more below standard
Connecticut Department of Energy and Environmental Protection
Emergency Engine Operational Limitations
•
50 hr/yr of the 100 hr/yr allocation can be used for:
– non‐emergency situations if no financial arrangement
– local reliability as part of a financial arrangement with another entity if:
local reliability as part of a financial arrangement with another entity if:
• existing RICE at area source
• engine is dispatched by local transmission/distribution system operator
• dispatch intended to mitigate local transmission and/or distribution dispatch intended to mitigate local transmission and/or distribution
limitations so as to avert potential voltage collapse or line overloads
• dispatch follows reliability, emergency operation, or similar protocols that follow specific NERC, regional, state, public utility commission, or local p
, g
,
,p
y
,
standards or guidelines
• power provided only to facility or to support local distribution system
• owner/operator identifies and records dispatch and standard that is being followed
– peak shaving until May 3, 2014 if existing RICE at area source Connecticut Department of Energy and Environmental Protection
Requirements for Emergency Engines
Major Sources
Existing RICE
Area Sources
New RICE
≤500 HP:
≤500 HP:
•Change oil/filter & inspect hoses/belts every Meet Stationary Engine NSPS 500 hours or annually; inspect air cleaner (CI) or spark plugs (SI) every 1 000 hours or annually
spark plugs (SI) every 1,000 hours or annually CI: part 60 subpart IIII
CI: part 60 subpart IIII
•Non‐resettable hour meter
Existing RICE
New RICE
• Change oil/filter & inspect hoses/ belts every 500 hours or annually; inspect air cleaner (CI) or spark plugs (SI) every 1 000
or spark plugs (SI) every 1,000 hours or annually
Meet Stationary Engine NSPS • Non‐resettable hour meter
SI: part 60 subpart JJJJ CI: part 60 subpart CI:
part 60 subpart
IIII
SI: part 60 subpart JJJJ
•Records of hours of operation
• Records of hours of operation
p
•Records of maintenance
• Records of maintenance
•Operate/maintain per manufacturer’s instructions or owner‐developed maintenance plan
•Minimize startup/idle
Mi i i
/idl
• Operate/maintain per manufacturer’s instructions or owner‐developed maintenance d l
d i
plan
•Reporting and ULSD if used for EDR/voltage or local reliability and >100 HP
>500 HP:
Minimize startup/idle, reporting and ULSD if used for EDR/voltage or local reliability
• Minimize startup/idle
>500 HP:
•Minimize startup/idle, reporting
and ULSD if used for EDR/voltage or local reliability
• Reporting and ULSD if used for and ULSD if used for
EDR/voltage or local reliability
•Initial notification if not used for EDR/voltage or local reliability
EDR/voltage
or local reliability
Connecticut Department of Energy and Environmental Protection
Oil Analysis Programs
Parameter
Condemning Limits
Total Base Number
(CI RICE only)
<30% of the TBN of the oil when new
Total Acid Number
(SI RICE only)
Increases by more than 3.0 mg of potassium hydroxide per gram from TAN of the oil when new
Vi
Viscosity
it
Changed by more than 20% from the viscosity of the oil Ch
db
th 20% f
th i
it f th il
when new
% Water Content by volume
>0.5
• Oil analysis must be performed at same frequency specified for oil changes
• If condemned, change oil within 2 business days
– Owner/operator must keep records of the analysis
Owner/operator must keep records of the analysis
Connecticut Department of Energy and Environmental Protection
Fuel Requirements for Emergency Engines
• Requirements apply to emergency CI RICE >100 HP and displacement <30 liters/cylinder that are:
30 li
/ li d h
– Operated or contractually obligated to be available >15 hr/yr (up to 100 hr/yr) for emergency demand response or voltage/frequency deviation, or
– Operated for local reliability (up to 50 hr/yr)
• Beginning January 1, 2015, use ultra low sulfur diesel fuel Beginning January 1 2015 use ultra low sulfur diesel fuel
– Existing inventory may be depleted
Connecticut Department of Energy and Environmental Protection
Reporting Requirements for Emergency Engines
•
Requirements apply to emergency RICE >100
Requirements apply to emergency RICE 100 HP that are:
HP that are:
– Operated or contractually obligated to be available >15 hr/yr (up to 100 hr/yr) for emergency demand response or voltage/frequency deviation, or
– Operated for local reliability (up to 50 hr/yr)
•
Beginning with 2015 operation, report electronically by March 31 of following year:
Facility name/address
Engine rating, model year, lat/long
d l
l /l
Date, start time, end time for operation for purposes above
Number of hours engine is contractually obligated for emergency demand response or voltage/frequency deviation
g / q
y
– Entity that dispatched engine for local reliability and situation that necessitated dispatch
– Deviations from fuel requirement
–
–
–
–
•
Submit report electronically through the Compliance and Emissions Data Reporting Interface
– Accessed through EPA’s Central Data Exchange at http://www.epa.gov/cdx
Connecticut Department of Energy and Environmental Protection
Stationary RICE NESHAP
Stationar
RICE NESHAP
Requirements for Non‐Emergency RICE
q
g y
Connecticut Department of Energy and Environmental Protection
Emission Standards: Existing Non‐Emergency RICE Located at Major Sources
HP
Engine Subcategory
Non‐emergency
CI
<100
SI 2SLB
SI 4SLB
SI 4SRB
SI LFG/DG
Change oil and filter and inspect air cleaner (CI) or spark plugs (SI) every 1,000 hours of operation or annually; inspect hoses and belts every 500 hours of operation or annually 100‐300
230 ppm CO
300 500
300‐500
49 ppm CO or 49
CO
70% CO reduction
>500
23 ppm CO or 70% CO reduction
225 ppm CO
47 ppm CO
10.3 ppm CH2O
177 ppm CO
No standards
No standards
350 ppb CH2O or 76% CH2O reduction
No standards
Note: Existing limited use engines >500 HP at major sources do not have to meet any emission standards. Existing black start engines ≤500 HP at major sources must meet work practice standards.
Connecticut Department of Energy and Environmental Protection
Emission Standards: Existing Non‐Emergency RICE Located at Area Sources
HP
Engine Subcategory
Engine Subcategory
Non‐emergency
≤300
CI
SI 2SLB
SI 4S in remote areas
SI 4S not in remote areas
SI LFG/DG
Black start
Change oil/filter & inspect air cleaner every 1,000 hours or annually; inspect hoses/belts every 500 hours or h
annually
Change oil/filter, inspect spark plugs, & inspect hoses/
belts every 4,320 h
hours or annually
ll
Change oil/ filter, inspect spark plugs, & inspect hoses/belts every 1,440 hours of operation or annually
Change oil/ filter, inspect spark plugs, & inspect hoses/belts every 1,440 hours of operation or annually
Change oil/ filter, inspect spark plugs, & inspect hoses/
belts every 1,440 h
hours of f
operation or annually
Change oil/filter & inspect hoses/ belts every 500 hours or annually; inspect air cleaner ( )
(CI) or spark plugs k l
(SI) every 1,000 hours or annually
Change oil/ filter, inspect spark plugs, & inspect hoses/belts every 2,160 hours of ,
operation or annually
If engine used >24 hrs/yr:
300‐500
49 ppm CO or 70% CO reduction
>500
23 ppm CO or 70% CO reduction
4SLB: Install oxidation catalyst
y
4SRB: Install NSCR
Connecticut Department of Energy and Environmental Protection
Emission Standards: New Non‐Emergency RICE
New RICE Located at Major Sources:
HP
Engine Subcategory
Non‐emergency
Non
emergency
<250
CI
SI 2SLB
SI 4SLB
SI 4SRB
SI LFG/DG
Comply with CI NSPS
Comply with SI
NSPS
Comply with SI NSPS
Comply with SI NSPS
Comply with SI NSPS
250‐500
>500
580 ppb CH2O or 70% CO reduction
14 ppm CH2O or 93% CO reduction
12 ppm CH2O or 350 ppb CH2O or 58% CO 76% CH2O reduction
reduction
No standards
Note: New limited use engines >500 HP at major sources do not have to meet any emission standards under the NESHAP
Note: New limited use engines >500 HP at major sources do not have to meet any emission standards under the NESHAP. New RICE Located at Area Sources: meet Stationary Engine NSPS •CI: part 60 subpart IIII
•SI:
SI: part 60 subpart JJJJ part 60 subpart JJJJ
Connecticut Department of Energy and Environmental Protection
66
Compliance Requirements: Non‐Emergency RICE
Engine Subcategory
Engine Subcategory
Existing non‐emergency:
•CI ≥100 HP at major source
•CI >300 HP at area source
•SI 100‐500 HP at major source
Compliance Requirements
•Initial emission performance test
•Subsequent performance testing every 8,760 hours of operation or 3 years for engines >500 HP (5 years if l
limited use)
d
)
•Operating limitations ‐ catalyst pressure drop and inlet temperature for engines >500 HP
•Notifications
•Semiannual compliance reports (annual if limited use)
l
l
(
l fl
d
)
Existing CI >300 HP:
•Ultra low sulfur diesel (ULSD)
•Crankcase emission control requirements
k
i i
l
i
•Existing non‐emergency SI 4SLB/4SRB •Initial and annual catalyst activity checks
>500 HP at area source used >24 •High temperature engine shutdown or continuously hours/year and not in remote area
monitor catalyst inlet temperature
•Notifications
•Semiannual compliance reports
Connecticut Department of Energy and Environmental Protection
Compliance Requirements: Non‐Emergency RICE
Engine Subcategory
Existing black start:
•<100 HP at major source
•≤500 HP at major source
•All at area source
Existing non‐emergency:
•<100 HP at major source
•CI ≤300 HP at area source
•SI ≤500 HP at area source
SI ≤500 HP t
•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
Compliance Requirements
•Operate/maintain engine & control device per manufacturer’s instructions or owner‐developed maintenance plan
•May use oil analysis program instead of prescribed oil change frequency
prescribed oil change frequency
•Keep records of maintenance
•Notifications not required
Connecticut Department of Energy and Environmental Protection
Compliance Requirements: Non‐Emergency RICE
Engine Subcategory
Compliance Requirements
Existing non‐emergency:
•SI 4SRB >500 HP at major source
•Initial emission performance test
•Subsequent performance testing semiannually
(can reduce frequency to annual)*
•Operating limitations ‐ catalyst pressure drop and inlet temperature
•Notifications
Notifications
•Semiannual compliance reports
New non‐emergency:
•SI 2SLB >500 HP at major source
SI 4SLB >250 HP at major source
4SLB >250 HP at major source
•SI
•SI 4SRB >500 HP at major source
•CI>500 HP at major source
Connecticut Department of Energy and Environmental Protection
Compliance Requirements: Non‐Emergency RICE
Engine Subcategory
Compliance Requirements
•New limited use >500 HP at major source
•Initial notification
•New non‐emergency LFG/DG >500 HP at major source
>500 HP at major source
•Initial notification
•Monitor/record fuel usage daily
fuel usage daily
•Annual report of fuel usage
Connecticut Department of Energy and Environmental Protection
Key Dates
•
IInitial applicability notifications for engines subject to 2010 amendments ii l
li bili
ifi i
f
i
bj
2010
d
were due by:
– August 31, 2010 for existing CI RICE – February 16, 2011 for existing SI RICE
•
Compliance dates:
Compliance dates:
– June 15, 2007
• Existing RICE >500 HP at major sources (except non‐emergency CI >500 HP at major sources)
– May 3, 2013
• Existing CI RICE (except emergency CI >500 HP at major sources)
– October 19, 2013
• Existing SI RICE ≤500 HP at major sources and all HP at area sources
– Upon startup for new engines
p
p
g
Connecticut Department of Energy and Environmental Protection
Stationary CI ICE NSPS
Connecticut Department of Energy and Environmental Protection
Who is Subject to the CI NSPS
• Manufacturers of 2007 model year or later stationary CI engines <30 liters/cylinder displacement
– Model years differ for fire pump engines • Owners/operators of stationary CI engines
– constructed (ordered) after July 11, 2005 and
manufactured after April 1, 2006 (July 1, 2006 for fire pump engines)
pump engines)
– modified/reconstructed after July 11, 2005
Connecticut Department of Energy and Environmental Protection
Emission Standards: Displacement <10 liters/cylinder
• Pre‐2007 model year engines
– Meet emission standards equivalent to Tier 1 standards for nonroad CI engines
• 2007 model year and later
2007 model year and later
– Meet emission standards equivalent to Tier standards for nonroad CI engines
• Tier 2/3 in part 89, Tier 4 in part 1039
Tier 2/3 in part 89 Tier 4 in part 1039
– Emergency engines >50 HP only have to meet Tier 3 standards (or Tier 2 if no Tier 3)
• Fire pump engines
– Same emission standards, delayed schedule
Connecticut Department of Energy and Environmental Protection
Emission Standards: Displacement ≥10 liters/cylinder
• 10‐30 liters/cylinder
– Meet Tier standards for marine CI engines
• Tier 2 in part 94, Tier 3/4 in part 1042
• Emergency engines do not have to meet the most stringent (Tier 4) standards
• ≥30 liters/cylinder
– NO
NOx limits (g/kW‐hr): equivalent to EPA standards for large marine li it ( /kW h )
i l t t EPA t d d f l
i
engines
– PM limit: • 60% reduction or 0.15 g/kW‐hr for non‐emergency
• 0.40 g/kW‐hr for emergency
Connecticut Department of Energy and Environmental Protection
Fuel Requirements
Date
Requirement
October 1, 2007 Low sulfur diesel (LSD)
October 1 2010
October 1, 2010 Ultra low sulfur diesel (ULSD)
Ultra low sulfur diesel (ULSD) Engines <30 liters/cylinder displacement
•Max sulfur content 15 ppm •Minimum cetane index of 40 or max aromatic content of 35 volume %
June 1, 2012 1,000 ppm sulfur diesel
Engines ≥30 liters/cylinder Engines
≥30 liters/cylinder
displacement Connecticut Department of Energy and Environmental Protection
Engine Manufacturer Compliance Requirements
• Engine
Engine manufacturers must certify 2007 model year manufacturers must certify 2007 model year
and later engines with a displacement <30 liters/cylinder
/ y
– Certification = EPA Certificate of Conformity
Connecticut Department of Energy and Environmental Protection
Owner/Operator Compliance Requirements
•
2007 model year and later with displacement <30 liters/cylinder*
– purchase certified engine
– Install, configure, operate and maintain engine per manufacturer’s instructions or manufacturer‐approved procedures
• Owner/operator performance testing not required
– If operate differently than manufacturer’s recommendations, must do performan e test to sho omplian e
performance test to show compliance
•
Displacement ≥30 liters/cylinder
– Initial performance test
I iti l
f
t t
– Annual performance test for non‐emergency engine
– Continuously monitor operating parameters
*For
For CI fire pump engine, 2008‐2011 model year and later (depending on engine size)
CI fire pump engine 2008 2011 model year and later (depending on engine size)
Connecticut Department of Energy and Environmental Protection
Monitoring/Recordkeeping/Reporting
Engine Type
Emergency Engines
Requirement
•Non‐resettable hour meter and records of operation if engine does not meet non‐emergency engine standards
Equipped with diesel particulate •Backpressure monitor and records of corrective filter (DPF)
actions
Non‐emergency >3,000 HP or with displacement >10
with displacement >10 liters/cylinder
and
Pre‐2007 model year >175 HP that are not certified
•Submit initial notification
•Keep records of notifications and engine
•Keep records of notifications and engine maintenance
•If certified, keep records of documentation of engine certification
•If not certified, keep records of compliance demonstrations
Connecticut Department of Energy and Environmental Protection
Stationary SI ICE NSPS
Connecticut Department of Energy and Environmental Protection
Who is Subject to the SI NSPS?
• Manufacturers of stationary SI engines:
– ≤25 HP and manufactured on/after July 1, 2008
– >25 HP, gasoline or rich burn LPG, manufactured on/after July 1, 2008 (on/after January 1, 2009 if emergency engines)
– Voluntarily certified engines manufactured on or after:
Date
Engine Type
July 1, 2007
>500 HP (except lean burn 500≤HP<1,350)
January 1, 2008 lean burn 500≤HP<1,350
July 1, 2008
<500 HP
January 1, 2009 emergency engines
Connecticut Department of Energy and Environmental Protection
Who is Subject to the SI NSPS? (cont’d)
Owners/operators of engines: Constructed (ordered) after June 12, 2006 and Modified/reconstructed after June 12, 2006
Manufactured On/After
Engine Type
July 1, 2007 ≥500 HP (except lean burn 500≤HP<1,350) January 1, 2008
Lean burn 500≤HP<1,350
July 1, 2008
<500 HP January 1, 2009
Emergency >25 HP Connecticut Department of Energy and Environmental Protection
Emission Standards (In General)
Engine
Standards
≤25 HP (all engines)
Part 90 or part 1054 standards for new nonroad SI engines
Non‐emergency gasoline and rich burn LPG
Part 1048 standards for new nonroad SI engines
Non‐emergency natural gas Part 1048 standards for new nonroad SI engines and lean burn LPG (or other options)
25<HP<100
≥100 HP and not gasoline or rich burn LPG
Standards in Table 1 of subpart JJJJ, part 1048 standards for some engines
Owners/operators of gasoline engines must use gasoline that meets the sulfur limit in 40 CFR 80.195 – cap of 80 ppm
Connecticut Department of Energy and Environmental Protection
Compliance Requirements for Owners/Operators
• Certified engines
– Install, configure, operate and maintain engine according ,
g , p
g
g
to manufacturer’s instructions
– If you do not operate/maintain according to manufacturer’s instructions:
f
’
•
•
•
•
keep maintenance plan and maintenance records
operate consistent with good air pollution control practices
100≤HP≤500 – initial performance test >500 HP – initial performance test and subsequent every 8,760 hours or 3 years, whichever is first
Connecticut Department of Energy and Environmental Protection
Compliance Requirements for Owners/Operators
•
Non certified engines:
Non‐certified engines:
– Maintenance plan
– Performance testing
• 25<HP≤500 –
25<HP≤500 initial test initial test
• >500 HP ‐ initial test and subsequent every 8,760 hours or 3 years, whichever is first
• Conduct within 10% of peak (or highest achievable) load
•
Monitoring/recordkeeping/reporting includes:
i i /
dk i /
i i l d
– Non‐resettable hour meter and records of operation for emergency engines
– Documentation of certification
– Records of engine maintenance
– Initial notification for non‐certified engines >500 HP
– Results of performance testing within 60 days of test
Connecticut Department of Energy and Environmental Protection
Implementation Assistance
• RICE NESHAP/NSPS TTN websites
– http://www.epa.gov/ttn/atw/rice/ricepg.html
http //
epa go /ttn/at /rice/ricepg html
– http://www.epa.gov/ttn/atw/nsps/cinsps/cinspspg.html
– http://www.epa.gov/ttn/atw/nsps/sinsps/sinspspg.html
• EPA Regional Office RICE websites
– Region 1: http://www.epa.gov/region1/rice
– Region 10: http://yosemite.epa.gov/R10/airpage.nsf/Enforcement/rice_rules
• Electronic CFR
Electronic CFR
– http://www.gpoaccess.gov/ecfr
Connecticut Department of Energy and Environmental Protection
Contact Information
Melanie King (rule writer)
Energy Strategies Group
Sector Policies and Programs Division
g
OAQPS, Office of Air and Radiation
Phone: 919‐541‐2469
king.melanie@epa.gov
Susan Lancey
Susan
Lancey
EPA Region 1
Phone: 617‐918‐1656
L
Lancey.susan@epa.gov
@
Roy Crystal
EPA Region 1
Phone: 617‐918‐1745
C t l
Crystal.roy@epa.gov
@
Keith Hill
Keith
Hill
CT DEEP
Bureau of Air Management
860‐945‐9295
860
945 9295
Keith.hill@ct.gov
Connecticut Department of Energy and Environmental Protection
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