Embed Size (px)
Citation preview
5/14/2013
1
Prepared by Tiffany L. Medley, Ph.D.
Birdsall Services Group, Inc
� Subpart ZZZZ: National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating Internal Combustion Engines
� Subpart JJJJ: New Source Performance Standards (NSPS) for Stationary Spark Ignition Internal Combustion Engines
� Subpart IIII: NSPS for Stationary Compression Ignition Combustion Engines
2
�Reporting may include:� Maintaining engine manufacturer certificates
of emissions
� Stack testing
� EPA notifications of compliance
� Maintaining records of maintenance
� Maintaining and submitting hour logs
3
�The EPA wants to reduce
particulate matter and sulfur
dioxide emissions
� There is evidence that pollutants
emitted from diesel engines are
known or suspected of causing
cancer and other serious health
effects
�The EPA has information that the
majority of emergency engines
do not use ultra low sulfur diesel
(ULSD)
4
� Emergency engines may be used to prevent electrical outages and to test and maintain engines for up to a total of 100 hour per calendar year
�A combined total of 100 hours per year may be used without meeting emission limits for the following:� Testing and maintenance
� Responding to a 5% or more change in voltage
� Operating for up to 50 hours to head off potential line overloads that could result in local or regional power disruption
5
� Legal by Federal Standards
�Not yet adopted by New Jersey DEP
� April 8, 2013: NJDEP Compliance Advisory
specifically stated:
� “Demand Response” is outside the allowable operation
of emergency generators without air pollution control
� To participate in a Demand Response program the
generator is no longer an “emergency” generator and
must be permitted as a stationary engine with all
enforceable emission limits and controls
� The NJDEP will issue violations to the facility and/or
the demand response aggregator if a permitted
emergency generator runs under Demand Response
6
5/14/2013
2
� In 2015, emergency engines will be required to use ULSD if they operate or commit to operate for more than 15 hours annually as part of blackout/brownout prevention
� In 2015, 100 hp or larger engines that operate or commit to operate for more than 15 hours and up to 100 hours will need to collect and submit an annual report including location, dates and times of operation
� WHY???Requirements to report annual usage of emergency engines will provide data for EPA and states to better understand the health impacts and the emissions that result from the engines
7
� In an emergency such as a hurricane or other
catastrophic event any emergency engine
can run without meeting any federal control
requirements
�After Hurricane Sandy, the NJDEP also
allowed the temporary use of any non-
permitted engine
� Required notification to the NJDEP and follow-up
reporting on the non-permitted engine’s usage
8
9
�Applicability:
� Does not apply to emergency engines unless at a
site of MAJOR source of HAP emissions
� Includes digester and landfill gas engines
� Existing Compression Ignition stationary RICE and
Existing Spark Ignition stationary RICE at area
sources :
� Existing = You commenced construction or reconstruction
BEFORE June 12, 2006
� New engines are subject to the requirements of Subpart
JJJJ for Spark Ignition engines or Subpart IIII for
Compression Ignition engines in lieu of this Subpart
10
�How do I comply if I owned and still operate a non-emergency CI engine before June 12, 2006?:
� For engines less than 300 HP� change oil, change filter and inspect air cleaner every
1,000 hours of operation or annually whichever comes first
� Inspect all hoses and belts every 500 hours of operation or annually and replace as needed
� For CI engines greater than 300 HP� Limit concentration of CO in the exhaust to 49 ppmvd
for engines 300-500 HP and 23 ppmvd for engines greater than 500 HP or reduce CO emissions by 70% or more
11
�How do I comply if I owned and still operate a
digester gas engine before June 12, 2006?:
� For engines less than 100 HP and greater at a MAJOR
source of HAP emissions
� change oil, change filter and inspect spark plugs every 1,000
hours of operation or annually whichever comes first
� Inspect all hoses and belts every 500 hours of operation or
annually and replace as needed
� Limit concentration of CO in the exhaust to 177 ppmvd for
engines 100-500 hp
� For engines at an AREA source of HAP emissions
� Change oil/filter & inspect spark plugs, hoses and belts every
1,440 hours or annually12
5/14/2013
3
�How do I comply if I owned and still operate
a non-emergency SI engine before June 12,
2006 at an AREA source of HAP emissions?:
� For SI lean burn and rich burn engines less than
500 HP
� change oil, change filter and inspect spark plugs,
hoses and belts every 1,440 hours of operation or
annually whichever comes first
� For all SI engines greater than 500 HP
� If engine is used more than 24 hours/yr: install an
oxidation catalyst for lean burn engines or install an
SCR for rich burn engines
13
�How do I comply if I owned and still operate a
non-emergency SI engine before June 12, 2006?:
� For SI lean or rich burn engines greater than 500 HP
that operate less than 24 hours/yr
� change oil, change filter and inspect hoses and belts every
500 hours of operation or annually and replace as needed
� Inspect spark plugs every 1,000 hours of operation or
annually and replace as needed
14
� How do I comply if I am subject to an emission standard and own a CI engine greater than 300 HP?:
� Conduct an initial performance test within 180 days after the compliance date and establish each operating limitation
� Use a past performance test if conducted within the past 2 years
� Install an oxidation catalyst to meet standard and conduct semiannual performance test to demonstrate the CO percent reduction is met
� Conduct semi annual CO performance tests to demonstrate that the emissions are being met
15
�How do I comply if I am subject to an
emission standard and own a SI engine or CI
engine?:
� For CI engines less than 300 HP and SI engines
that operate less than 24 hours/yr
� Comply by following proper maintenance plan
� For SI lean burn and rich burn greater than 500
HP
� Install an oxidation catalyst to meet standard if needed
and conduct performance tests every 8,760 hours or 3
years whichever comes first
16
� What are my reporting requirements:
� You must submit an initial notification of applicability
� If you are required to conduct an initial performance
test you must submit a Notification of Intent at least
60 days prior to conducting the test
� You must submit a copy of the initial performance test
� For CI engines greater than 300 BHP and SI engines
greater than 500 HP, submit semi-annual reports
containing any deviations to standards or malfunctions
during the reporting period
� For applicable digester/landfill gas engines submit a
report annually (need proof that combusts digester gas
10% or more and meeting operating permit limits)
17
�By what date am I required to comply:� For existing CI engines located at
an area source no later than May 3, 2013
� For existing SI engines located at an area source no later than October 19, 2013
� For new engines, you must comply by complying with Subpart JJJJ (Spark Ignition engines) or Subpart IIII (Compression Ignition engines) upon startup
18
5/14/2013
4
19
�Applicability:� Manufacturers, owners and operators of (natural
gas) stationary engines
� Owners and operators that commence construction (date engine is ordered) after June 12, 2006 where the engine was manufactured� On or after July 1, 2007 for engines greater than or equal
to 500 HP (if lean burn then 500 – 1350 HP)
� On or after July 1, 2008 for engines less than 500 HP
� On or after January 1, 2009 for emergency engines greater than 25 HP (19 KW)
� Owners and operators of stationary engines that are modified or reconstructed after June 12, 2006
20
�How do I comply?� Purchase an engine that complies with the emission
standards� Manufacturers must certify their engines in accordance with
the standards in the Subpart
� Note: manufacturers will usually not certify an engine using an alternate fuel (digester/landfill gas) and emissions testing may be required to demonstrate compliance.
� Operate your certified engine in accordance with manufacturers written instructions and keep records of maintenance
� For emergency engines do not exceed 100 hours of operation for maintenance and testing unless written approval is received from EPA
21
� If you are NOT operating and maintaining a certified engine (these include non certified digester engines)
� Keep a maintenance plan, records of maintenance and operate in a manner that minimizes air pollution
� For engines 100-500 HP, conduct an initial performance test of emissions within 1 year of startup
� For engines greater than 500 HP, you must conduct an initial performance test and repeat every 8,760 hours or 3 years for compliance with the emissions standards
22
�Reporting and Recordkeeping Requirements
� Keep records of:
� Manufacturer certification
� Maintenance
� Performance tests
� Emergency engines must keep records
of hours of operation (Have a non resettable hour meter)
� Send EPA notification of applicability if you own a
non certified engine greater than 500 HP
� Send EPA copy of performance tests within 60 days of
testing
23 24
5/14/2013
5
� Applicability:
� Manufacturers, owners and operators of diesel
stationary engines manufactured after April 1, 2006
� How do I comply?
� Purchase an engine that complies with the emission standards
� Manufacturers must certify their engines in accordance
with the standards in the Subpart
� You must not install non emergency stationary CI
engines that do not meet the applicable emission
requirements
� Example: after December 31, 2012 owners and operators may not install CI engines 130 KW or greater that do not
meet the requirements of a 2011 model year engine
25
�How do I comply?
� Beginning June 1, 2012 use diesel fuel with a
sulfur content less than 1,000 ppm (LSD or ULSD
will satisfy this)
� Install or purchase an engine with a non
resettable hour meter
� If a diesel particulate filter has been installed to
ensure compliance, it must have a backpressure
monitor
26
�How do I comply?
� Operate your certified engine in accordance with
manufacturers written instructions and keep
records of maintenance
� For engines with a displacement of greater than
or equal to 30 liters per cylinder conduct
emissions test for NOx, O2 and Particulate
27
�What are the reporting requirements
� Engines greater than 3,000 HP (2,237 KW) or pre-
2007 model year engines must submit
� An initial notification
� Annual reports beginning March 31, 2016 for 2015
calendar year
� Must be submitted electronically using EPA’s Central
Data Exchange
28
�Check the model year, HP, and KW of your
engine to determine which regulations may
apply to you
� Just because these regulations are not in
your NJDEP permit does NOT mean that they
are not applicable
29
�Tiffany L. Medley, Ph.D.
Birdsall Services Group
65 Jackson Drive
Cranford, NJ 07016
(908) 497-8900 ext. 6126
�Alternative email:
30
