VanAssche, James, GHD Services, Rice MACT and Boiler MACT Common Compliance Challenges and Solutions, MECC, Kansas City

RICE MACT AND BOILER MACT – COMMON COMPLIANCE

CHALLENGES AND SOLUTIONS

James VanAssche GHD Services Inc.

May 11, 2016

Agenda

• Boiler MACT Implementation

• Common Boiler MACT Challenges

• RICE MACT Status

• RICE MACT Compliance Challenges

Boiler MACT Implementation

Affected Sources: Industrial, commercial, or institutional boilers or process heaters • Major Sources – 40 CFR 63

Subpart DDDDD (5D) • Area Sources – 40 CFR 63

Subpart JJJJJJ (6J) – Excludes

natural gas fired units

Key Exemptions: • Electric utility steam generating unit (EGU) covered by Subpart

UUUUU • Recovery boiler or furnace covered by Subpart MM • R&D Boilers and Process Heaters • Hot water heaters • Refining Kettles under Subpart X • Ethylene Cracking Furnace under Subpart YY • Blast furnace stoves • Boilers and process heaters used as control devices to comply with

subparts JJJ, OOO, PPP, and U • Boilers or process heaters used as a control device • Temporary Boilers • Blast furnace gas fuel-fired boilers and process heaters • A unit that burns hazardous waste covered by Subpart EEE • Residential boilers

Recent Reconsiderations

• November 5, 2015 – Final Reconsideration – Definition of startup and shutdown periods and the

work practices that apply during such periods;

– Retained the carbon monoxide (CO) emission limits based on a minimum CO level of 130 parts per million; and

– Retained the use of a particulate matter continuous parameter monitoring system (PM CPMS) and the consequences of exceeding the operating parameter.

Recent Reconsiderations

• November 5, 2015 – Final Reconsideration – Startup ends when any of the useful thermal energy

from the boiler or process heater is supplied for heating, producing electricity, or any other purpose.

– Shutdown begins when the boiler or process heater no longer makes useful thermal energy (rather than referring to steam supplied by the boiler) for heating, cooling, or process purposes and/or generates electricity, or when no fuel is being fed to the boiler or process heater, whichever is earlier.

Key Compliance Challenges

• Emissions Limitations

– CPMS or CEMS vs. Performance Testing

• Work Practice Standards

• One-Time Energy Assessment

Emissions Limitations

• Continuous Parameter Monitoring – Pressure drop – Opacity – Voltage Parameter monitoring can be good alternative to Emissions Monitors – can be simpler but must maintain operating range

• Continuous Emissions Monitoring

• Fuel Analysis – Mercury or HCl – alternative to performance

testing

• Performance Testing - if below 75% of applicable standards can

be reduced to every 3 years

Work Practice Standards

• Tune Ups

– Determine frequency

– May have resources internally

– Best contractor is the one who installed your boiler

• One-Time Energy Assessment

One Time Energy Assessment

• Conducted by Qualified Energy Assessor

– Not a certification

– Best if performed by ME with Boiler Design

• Hours of on-site assessment are maximums not

minimums

• Key on combustion efficiency and heat recovery

• Must have a cost benefit analysis

RICE MACT

Federal Regulations Impacting Engines • NESHAP (40 CFR 63 Subpart ZZZZ) for stationary

reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions

• NSPS (40 CFR 60 Subpart IIII) for stationary compression ignition (CI) reciprocating internal combustion engines (RICE)

• NSPS (40 CFR 60 Subpart JJJJ) for stationary spark ignition (SI) reciprocating internal combustion engines (RICE)

• 40 CFR 89, 90, 94, 1039, 1042, 1048, 1054 stationary non-road engine regulations applicable by reference from IIII and JJJJ

Vacatur of RICE NESHAP and NSPS Provisions for Emergency Engines • Issued May 4, 2016: “Emergency” Engines no longer

able to run under demand response programs for under 100 hours per year

• 40 C.F.R.§ 63.6640(f)(2)(ii)-(iii) • 40 C.F.R. § 60.4211(f)(2)(ii)-(iii) • 40 C.F.R. § 60.4243(d)(2)(ii)-(iii)

• “(ii) Emergency stationary RICE may be operated for emergency demand response for

periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see §63.14), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3. (iii) Emergency stationary RICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency.”

Stationary vs. Mobile

• Stationary means not used in a motor vehicle and not a 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 platform)

• Portable nonroad becomes stationary if it stays in one location for more than 12 months, or full annual operating period if seasonal source

Owning vs. Leasing

• Regardless of whether an engine is leased or owned, compliance obligations fall on operator

• Regulatory status of leased engines should be verified (applicability analysis)

• Leased engines may have been relocated

• Confirm original construction dates

• Confirm that overhauls conducted do not exceed 50% of the cost of a like-kind new facility (LKNF)

Important Federal Definitions

“Commenced Construction” 40 CFR 60 Commenced means, with respect to the definition of

new source in section 111(a)(2) of the Act, that an owner or operator has undertaken a continuous program of construction or modification or that an owner or operator has entered into a contractual obligation to undertake and complete, within a reasonable time, a continuous program of construction or modification.

Construction means fabrication, erection, or installation of an affected facility.

Important Federal Definitions “Commenced Construction” 40 CFR 63

Commenced means, with respect to construction or reconstruction of an affected source, that an owner or operator has undertaken a continuous program of construction or reconstruction or that an owner or operator has entered into a contractual obligation to undertake and complete, within a reasonable time, a continuous program of construction or reconstruction.

Construction means the on-site fabrication, erection, or installation of an affected source. Construction does not include the removal of all equipment comprising an affected source from an existing location and reinstallation of such equipment at a new location. The owner or operator of an existing affected source that is relocated may elect not to reinstall minor ancillary equipment including, but not limited to, piping, ductwork, and valves. However, removal and reinstallation of an affected source will be construed as reconstruction if it satisfies the criteria for reconstruction as defined in this section. The costs of replacing minor ancillary equipment must be considered in determining whether the existing affected source is reconstructed.


“Reconstruction” Unless otherwise defined in a relevant standard, means the replacement of

components of an affected or a previously nonaffected source to such an extent that:

(1) The fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable new source; and

(2) It is technologically and economically feasible for the reconstructed source to meet the relevant standard(s) established by the Administrator (or a State) pursuant to section 112 of the Act. Upon reconstruction, an affected source, or a stationary source that becomes an affected source, is subject to relevant standards for new sources, including compliance dates, irrespective of any change in emissions of hazardous air pollutants from that source.


“Modification” Means any physical change in, or change in the method of operation of, an

existing facility which increases the amount of any air pollutant (to which a standard applies) emitted into the atmosphere by that facility or which results in the emission of any air pollutant (to which a standard applies) into the atmosphere not previously emitted.

Relocation Important issue with regard to federal applicability

Remember “Construction” definition?

“Construction does not include the removal of all equipment comprising an affected source from an existing location and reinstallation of such equipment at a new location. “

Engine leasing companies offer many “relocated” engines

Relocation

Engines can be relocated and relocation does not constitute a new construction

Applicable standards for relocated engines are based on original construction date, not date of relocation

Leased engines that have not been “reconstructed” can have lighter regulatory burdens (e.g. follow Quad Z “existing” engine maintenance instead of Quad J required field testing)

Key Considerations

Important Engine Characteristics in Navigating Federal Regulations

• Combustion types – compression ignition (diesel) vs. spark

ignition (gasoline, natural gas)

• 2 Stroke vs. 4 Stroke

• Lean Burn vs. Rich Burn and AFR Controllers

• Catalyst Fundamentals

• Engine Testing

Key Considerations

Critical Data to Collect When Assessing a RICE for Compliance

• Date of Manufacture

• Date of Commencing Construction

• Horsepower

• Engine Characteristics

– Combustion Type

– Lean vs. Rich, 2 stroke vs. 4 stroke

• Alternate Use Categories – Emergency, Fire Pumps, Special Fuels

ZZZZ Compliance

• Key dates for understanding ZZZZ RICE compliance:

– 12/19/2002: > 500 HP Major Source Engines - before this date is “existing”, after is “new”

– 6/12/2006: ≤500 HP at Major Source and all HP at Area Sources – before this date is “existing”, after is “new”

– Determining construction date: owner/operator has entered into a contractual obligation to undertake and complete, within a reasonable amount of time, a continuous program for the on-site installation of the engine

ZZZZ Compliance

• “Existing” engines under ZZZZ may have emissions limitations or basic routine maintenance requirements

• Most “New” engines are referred to their respective NSPS and not have any further requirements

• Some “New” engines at Major sources can have requirements under both ZZZZ and NSPS

ZZZZ Compliance

ZZZZ Compliance – Example

• Cat G3508 TA – 4-Stroke, Spark Ignited

– 630 Max HP

– Manufacture Date: 1/13/2005

– Commenced Construction Date: 3/12/2005

– Lean Burn


• Cat G3508 TA – Existing, 4-Stroke, Lean Burn, Spark Ignited, >500 HP,

located at an Area Source of HAP

– Compliance Date: 10/19/2013

– Significant Compliance Requirements


• Cat G3508 TA – Emission Limitations of Table 2d: Install an Oxidation Catalyst,

CPMS to monitor catalyst inlet temp

– Operating Limitations of Table 2b: Maintain inlet temperature

– Performance Testing: Initial performance testing for CO and determining inlet temp

– Monitoring: Monitor catalyst intake temperature with CPMS, maintain below 1350° F

– Notification, Recordkeeping, Reporting

ZZZZ Compliance – Example • Cat G3508 TA

– Emissions and Operating Limits, Performance Testing, Monitoring • Install an oxidation catalyst • Conduct performance testing to show average reduction of CO

emissions is 93% or more, or the average CO concentration is ≤ 47 ppmvd @ 15% O2

• Install a Continuous Parameter Monitoring System (CPMS) to monitor catalyst inlet temperature or install an auto shut down device that shuts the engine down when temperature exceeds 1350°F


– Notifications (§63.6645): • (40 CFR 63.7(b)) Notification of Performance Testing at least 60

days prior to scheduled performance test • (40 CFR 63.8(b)) Notification of Performance Evaluation of CPMS at

least 60 days prior to scheduled performance test • (40 CFR 63.9(b)) Initial Notification of Applicability within 120 days

of becoming subject • (40 CFR 63.9(h)) Notification of Compliance Status within 60 days

of completing the compliance demonstration


– Recordkeeping (§63.6655): • Copies of all notifications and reports submitted • Records of occurrence and duration of each malfunction to the

engine, pollution control equipment, or monitoring systems • Records of performance tests • Records of maintenance • CPMS performance evaluation plan, and maintain records of data

collected by CPMS that demonstrate the operating parameter limits were met


• Cat G3508 TA – Reporting (§63.6650):

• Semi-Annual Compliance Reporting per Table 7

• Semi-Annual Compliance Reporting includes the following info:

– Company name and address

– Certification statement by Responsible Official

– Reporting period

– Descriptions of malfunctions, duration, and corrective actions

– Statement on deviations from emissions or operating limits

ZZZZ Compliance

• Emissions reductions utilizing a catalyst

• Emissions limitations utilizing a catalyst

• Performance testing of catalyst

• Monitoring catalyst operating parameters (pressure drop, temperature)

• Routine engine maintenance


• Cat G3508 TA

– Could this engine be a “Remote” engine?

– Remote engine designation is a significantly lower regulatory burden

– Instead of conducting performance testing and maintaining CPMS, only routine maintenance is conducted

– What is a “Remote” engine?


• Cat G3508 TA – “Remote” Engine Determination

– Located in offshore area; or

– Located on a pipeline segment with 10 or fewer buildings intended for human occupancy and no buildings with 4 or more stories within 220 yards on either side of a continuous 1-mile length of pipeline (DOT Class 1 area), and the pipeline segment is not within 100 yards of a building or small well-defined outside area (playground, etc.) occupied by 20 or more persons on at least 5 days a week for 10 weeks in any 12-month period; or

– Not located on a pipeline and having 5 or fewer buildings intended for human occupancy and no buildings with 4 or more stories within a 0.25 mile radius around the engine


• Cat G3508 TA – “Remote” Engine Requirements – Change oil and filter every 2,160 hours of operation or

annually (or use oil analysis program)

– Inspect spark plugs, hoses, and belts every 2,160 hours of operation or annually, and replace as necessary

– Keep records of maintenance

– Annual evaluation of remote status and keep records of evaluation

– If engine is no longer remote, engine must be in compliance with non-remote requirements within 1 year

NSPS JJJJ - Compliance

• JJJJ establishes emissions performance standards for manufacturers, owners and operators of Spark Ignition (SI) RICE

• Establishes engine certification requirements

• Emissions limitations

• Field Testing

• Fuel Requirements

• Monitoring

• Notification (for > 500 HP SI RICE)


• Regulates all new SI engines regardless of size

• Key Applicability Dates: – 6/12/2006: Engines that commenced construction (or modified or

reconstructed) after this date are applicable but may or may not have requirements depending on manufacture date

Manufactured On/After Engine Type

July 1, 2007 ≥500 HP (except LB 500≤HP<1,350)

January 1, 2008 Lean burn 500≤HP<1,350

July 1, 2008 < 500 HP

January 1, 2009 Emergency >25 HP


• Generalized Emission Standards:

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 and lean burn LPG 25<HP<100

Part 1048 standards for new nonroad SI engines

≥100 HP and not gasoline or rich burn LPG

Standards in Table 1 of JJJJ, part 1048 standards for some engines


• Certified engines – Install, configure, operate and maintain engine

according to manufacturer’s instructions – If you do not operate/maintain according to

manufacturer’s instructions: • 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


• Non-certified engines –Maintenance plan –Performance Testing

• 25<HP≤500 – 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

– Non-resettable hour meter for emergency engines

– Records of hours 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

NSPS JJJJ - Example

Cat G3508 TA 4-Stroke, Spark Ignited

630 Max HP

Manufacture Date: 7/13/2005 7/13/2010

Commenced Construction Date: 3/12/2005 3/12/2010

Lean Burn

ZZZZ applicability based on construction date indicates that ZZZZ is satisfied by following JJJJ

Evaluate JJJJ applicability

NSPS JJJJ - Example

Emissions Standards

Fuel Requirements

Compliance – assume non-certified engine

Notification and Recordkeeping

NSPS JJJJ - Example

Emissions Standards:

Table 1 – Non-Emergency SI Lean Burn Natural Gas 500≤HP<1,350

Manufacture date: 7/13/2010 (after 7/1/2010)

Emission Standards (g/HP-hr): NOx: 1.0

CO: 2.0

VOC: 0.7

Fuel Requirements:

Only relevant if engine will utilize gasoline

NSPS JJJJ - Example

Compliance for Non-Certified Cat G3508 TA:

Operate and maintain engine to achieve engine standards as required over the life of the engine

Keep a maintenance plan and records of conducted maintenance

Conduct an initial performance test

Conduct subsequent performance testing every 8,760 hours or 3 years, whichever comes first

NSPS JJJJ - Example

Notifications

Initial notification within 30 days of the date of construction required for all non-certified engines >500 HP

Submit results of engine field testing within 60 days of completing the test

NSPS JJJJ - Example

Recordkeeping

Maintain records of all notifications

Keep all field performance testing results

Keep records of all maintenance performed on the engine

NSPS IIII – Compression Ignition Engines

NSPS IIII - Compliance

• IIII establishes emissions performance standards for manufacturers, owners and operators of Compression Ignition (CI) RICE

• Ties together nonroad CI engine regulations

• Certification to Tier 1-4 nonroad engine standards

• Field Testing for non-certified engines


• Monitoring

• Notification


• Who is subject and what are key dates?

– 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)

– Modified/reconstructed after July 11, 2005


• Who is subject and what are key dates?

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)

– Modified/reconstructed after July 11, 2005


• Emission Standards for < 10 liters/cylinder

– Pre-2007 model year: Meet Tier 1 or equivalent

– 2007 model year and later: Must meet respective Tier 2, 3 or 4 standards based on manufacture date

– Fire pump engines have the same emissions standards but a delayed implementation schedule

– Tier 2/3: 40 CFR 89

– Tier 4: 40 CFR 1039


• Emission Standards for ≥ 10 liters/cylinder

– 10-30 liters/cylinder • Meet Tier standards for marine CI engines

• Tier 2: 40 CFR 94

• Tier 3 and 4: 40 CFR 1042

• Emergency engines do not have to meet Tier 4 standards

– ≥30 liters/cylinder • NOx limits listed in §60.4204(c)(1-4), equivalent to EPA large

marine engine standards

• PM limit: 60% reduction or 0.15 g/kW-hr for non-emergency – 0.4 g/kW-hr for emergency



Date and Engines Affected Requirement

10/1/2007 Engines < 30 L/cylinder

Low sulfur diesel (LSD) 500 ppm sulfur

10/1/2010 Engines < 30 L/cylinder

Ultra low sulfur diesel (ULSD) - Max sulfur content 15 ppm - Min cetane index of 40 or max aromatic content of 35% by vol

7/1/2012 Engines ≥ 30 L/cylinder

1,000 ppm sulfur diesel


• Certification Requirements

– Engine manufacturers must certify 2007 model year and later engines with a displacement of < 30 L/cylinder

– EPA Certificate of Conformity


• 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 operated differently than manufacturer’s recommendations, conduct performance test to demonstrate compliance

• Displacement ≥30 liters/cylinder – Initial performance test

– Annual performance test for non-emergency engine

– Continuously monitor operating parameters

NSPS IIII – Compliance

• Monitoring, Recordkeeping and Reporting – Emergency Engines: Non-resettable hour meter and records of

operation if engine does not meet non-emergency engine standards

– Engines with Diesel Particulate Filter (DPF): Backpressure monitor and records of corrective actions

– Non-emergency > 3,000 HP or with displacement > 10 L/cylinder and Pre-2007 model year > 175 HP engines that are not certified

• Submit initial notification

• Keep records of notifications and engine maintenance

• Certification documentation (if certified)

• Compliance demonstrations (if not certified)

Key Issues

• Determining Compliance Obligations

– Need accurate info from vendors to utilize pedigree info and certificates of conformity

• Understanding applicability dates

– Commence construction, relocation, reconstruction, modification

• Performance Testing

– When it is necessary?

– Load conditions

• Tracking and Recordkeeping

– Maintain a database of engines and all required records

QUESTIONS?

THANK YOU!

Environment

VanAssche, James, GHD Services, Rice MACT and Boiler MACT Common Compliance Challenges and Solutions, MECC, Kansas City