Connecticut Department of Connecticut Department of Energy and Environmental Protection The New Maze of Air Regulations Th N M f Ai R l ti for Boilers and Engines: A Map g p 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 f S d d f S i S k i i (S ) C 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 Fi l R l d t bli h d F b 1 2013 • 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 d i i i d h h lh • 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 y 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 it h d i 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 f ilit hi h it h potential to emit less than 10 tons per year (tpy) of any single HAP and less than 25 tpy of any combination of HAP. b f • Expected to apply to about 183,000 boilers located primarily at commercial facilities (e.g., hotels, office i il t i l f iliti ( h t l ffi 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 C l b t – 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 b t 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, p , startups, p , or p periodic testing g on liquid q fuel. Periodic testing g of 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 f ili i l i id h h b d 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 yg y • 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 t lf t t i t 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 » C Coal boilers demonstrating initial compliance with the Hg l b il d t ti i iti l li ith th H 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 , y p g 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 < i i h lf f h PM half of the PM emission i i 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 C ti l it t it • Boilers using a CO continuous emissions monitoring system (CEMS) are exempt from initial CO stack testing y ( ) p g 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 q to be implemented p 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. p , • (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 i id i *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 b i l i i h b i b f d f h 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 d ff l d h 12 h i h 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 Th B i 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; p y ; ( ,p p , ); 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 h ff d b il 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: Th t b il The two boilers provide energy to five (5) distinct energy use systems, id t fi (5) di ti t t 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 t t d biliti t l t 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. C i l b i i h d 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. g 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. g y 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 y • 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 y 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 y y y 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 j p g ,y y required to q 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 t d i th f ll f 2013 EPA i ti 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 y g 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 f d d l d – 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 t di t hi l d t 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