South District

December 7, 2016

Air Resource PermittingCarter B. Endsley, P.E.

Reciprocating Internal Combustion EnginesEPA’S RICE NESHAP and NSPS

Content

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RICE Engines NESHAP and NSPS RICE Rules Emergency Engines Emissions Standards Compliance Controls Permit or No permit

RICE ENGINES

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• A stationary Reciprocating Internal Combustion Engine(RICE) is any internal combustion engine which usesreciprocating motion to convert heat energy intomechanical work and is not mobile. They are not used inroad vehicles or non-road mobile applications, such asbulldozers, mowers, cranes etc.

• SI = Spark Ignition 2SLB = 2 Stroke Lean Burn4SRB = 4 Stroke Rich Burn

• CI = Compression Ignition

Engine Stroke and Burn Definition Four-Stroke Engine: Any type of engine which completes the power cycle in two crankshaft revolutions, with intake and compression strokes in the first revolution and power and exhaust strokes in the second revolution.Two-Stroke Engine: Any type of engine which completes the power cycle in single crankshaft revolution by combining the intake and compression operations into one stroke and the power and exhaust operations into a second stroke.Rich Burn Engine: Any four-stroke spark ignited engine where the manufacturer’s recommended operating air/fuel ratio divided by the stoichiometric air/fuel ratio at full conditions is less than or equal to 1.1. All existing engines where no manufacturer’s recommendations regarding air/fuel ratio will be considered a rich burn engine if excess oxygen of exhaust at full load is less or equal to 2 percent.Lean Burn Engine: Any two-stroke or four-stroke spark ignited (SI) engine that does not meet the definition of a Rich Burn Engine.

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First Step - Identify your engine

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• Is the engine a “CI” (Compression Ignition) or a “SI” (Spark Ignition)?

• What is the horsepower?• Is Cylinder displacement 30 liters or less? Or more?• When was engine ordered? Manufactured?

Modified/Reconstructed?• Is the engine certified by the manufacture?• Is the engine located in a MAJOR source or AREA source of

HAP?• Is the engine a Non-Emergency or Emergency engine?• What is maximum fuel consumption to be used per year?

(Gallons or Cubic Ft.).• Is the engine in a DEP Permitted Facility?

Existing vs. New

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More than 500 HP at a major source• If construction commenced before Dec. 19, 2002, it is

EXISTING!…………… If not, it is NEW.

Less than 500 HP at a major or all HP at areasource

• If construction commenced before June 12, 2006, it is EXISTING!.............. If not, it is NEW.

Diesel Engine Tiers

* Diesel Emissions Tiers 1 to 3• Tier 1 standards were phased-in from 1996 to 2000.

The more stringent• Tier 2 standards took effect from 2001 to 2006, and

yet more stringent • Tier 3 standards phased-in from 2006 to 2008 (Tier 3

standards applied only for engines from 50 -750 hp).

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Diesel Engine Tiers (cont.)

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* Diesel Emissions Tier 4 Standards

Tier 4 Standards (phased-in over a period of 2008-2015) require that emissions of PM and NOx be further reduced by about 90%. It also includes more stringent HC limits. (CO emission limits remain unchanged from Tier 2-3 stage).

Such emission reductions can be achieved through the use of control technologies—including advanced exhaust gas after-treatment.

NESHAP and NSPS RICE Rules

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• RICE NESHAP (National Emission Standards for Hazardous Air Pollutants) - 40 CFR 63, Subpart ZZZZ

- Applies to stationary CI and SI engines, both existing and new.• CI RICE NSPS (New source Performance Standards) – 40 CFR 60,

Subpart IIII– Ordered after July 11, 2005 and manufactured after April 1, 2006– Modified or reconstructed after July 11, 2005– (Does not apply to existing engines)

* SI RICE NSPS- 40 CFR 60, Subpart JJJJ– Ordered after June 12, 2006 and manufactured on/after July, 2007 if

≥500 HP (except lean burn 500 HP to 1350 HP), July 1, 2008 if less than 500 HP, January 1, 2009 if emergency more than 25 HP

– Modified or reconstructed after June 12, 2006.– Does not apply to existing engines).

NESHAP Subpart ZZZZ

• NESHAP = National Emission Standards for Hazardous Pollutants. (There are 187 listed Hazardous Air Pollutants).

• Regulates HAPS from stationary RICE at both Majorand Area source of HAPS. (Hazardous Air Pollutants). (All engines existing and new).

• Major source HAPS = More than 10 tons for single HAP and 25 tons for combined HAPs per year emissions.

• Area Source HAPS = Any area not a major source of HAPS.

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Stationary CI NSPS Subpart IIII

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• CI Engines: 40 CFR part 60 subpart IIII (New Engines)

• CI Engines ordered after July 11, 2005 and manufactured after April 1, 2006 (July 1, 2006 for fire pumps).

• Modified/reconstructed after July 11, 2005

• Engines mfg. after 2007 and later engines less than 30 liter/cyl displacement.

• Manufacturers Certification is required.

NPS Subpart IIII Standards

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• For engines with less than 30 liters/cylinder.Meet Tier standards equivalent to standards for non-road engines.

****************• For engines with more than 30 liters/cylinder.

NOx limits equivalent to EPA’s standards for large marine engines.PM limits: 60% reduction or 0.15 g/KW-hr for non-emergency.

.40 g/KW-hr for emergency.

Stationary SI NSPS Subpart JJJJ

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• SI Engines : 40 CFR Part 60 Subpart JJJJ (New Engines)

• Ordered after June 12, 2006. • Modified/Reconstructed after June 12, 2006.• Some engines require Manufacturers Certification,

but others may not, such as landfill gas, etc.

NSPS Subpart JJJJ Standards

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Engines StandardsLess than 25 HP Part 90 or part 1054 standards

for new non-road SI engines

Non-emergency gasoline or RB LPG

Part 1048 standards for new non-road SI engines

Non-emergency natural gas and LB LPG25 to 100 HP

Part 1048 standards for new non-road SI engines

More than 100 HP and not gasoline or lean burn LPG

Standard in Table 1 subpart JJJJ,part 1048 standards for some engines

Subcategory Criteria

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RICE

CI Engines

Emergency Non-Emergency

SI Engines

Non Emergency Lean Burn

2 Stroke 4 stroke

Non Emergency 4 stroke Rich

Burn

Landfill/Digester gas Emergency

Engines exempt from NESHAP Rule

• Residential: includes apartment buildings.• Commercial: includes office buildings, hotels, stores,

telecommunication facilities, restaurants, financial institutes, doctors office, sports and performing arts facilities.

• Institutional: includes medical centers, nursing homes, research centers, institution of higher education, correctional facilities, elementary and secondary schools, libraries, religious establishments, police stations and fire stations.

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Emergency Engine Definition

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• Emergency Stationary RICE means:• (1) RICE is operated to provide electrical power or

mechanical work during an emergency situation such as: Used to produce power for critical networks or equipment when electric power from local utility or power source is interrupted or stationary RICE is used to pump water in case of fire or flood.

• (2) Stationary RICE is operated under limited situations not included in above paragraph, as defined in 63.6640(f).

Emergency Engine Operational Restrictions

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No time limit on the use of RICE for emergencies caused by power outage, fire or flood.

May be operated for 100 hr./year for any combination

• Maintenance and testing

Emergency Engine Operational Restrictions

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Up to 50 hr./ can be used for Non-Emergency situations. Hours counted as part of the 100 hr. per calendar year in non-emergency situations.* Non-Emergency situation if no financial agreement

exists.* Local reliability as part of a financial agreement

with another entity with conditions.

Maintenance and testingCan’t be used for peak shaving, or non-emergency demand response to generate income or supply power.

Emergency Engine Compliance Requirements

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• Existing Engines: Regulated by NESHAP 40 CFR 63 Subpart ZZZZ but not subject to NSPS 40 CFR 60 Subpart IIII or JJJJ.

• Change oil and filter every 500 hours operation or annually.

• Inspect Air Cleaner every 1,000 hours of operation or annually.

• Inspect hoses and belts every 500 hr. or annually.• Inspect spark plugs (SI) every 1000 hr. or annually.• Operate and maintain the RICE according to

manufacturer’s instructions.

Emergency Engines Requirements

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• Minimize startup and idle time (Not to exceed 30 minutes).

• Non-resettable hour meter must be installed. (40 CFR 63.6625(f)

• Records of hours of operation and maintenance.• Initial Notification is NOT required for Emergency

Engines.• NEW ENGINES- Regulated under NESHAP 40 CFR

63, Subpart ZZZZ and comply with NSPS Rules, Subpart IIII or Subpart JJJJ.

• Reporting requirements.

Emergency Engines: Other requirements

• Reporting requirements: apply to engines with more than 100 HP that are operated to be available more than 15 hr. contractually for demand and voltage deviation etc.

• Reporting starts from 2015.• Reports need to be submitted to EPA through central

data exchange.• Fuel requirement: Apply to emergency CI more than 100 HP

and displacement of less than 30 liters/cylinder that are obligated for demand and local reliability.

• Beginning January 1, 2015, for CI engines, use Ultra Low Sulfur Diesel fuel. Rule allows for depletion of fuel with higher sulfur content purchased prior to January 1, 2015.

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Emissions from RICE Engines

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• Fuel components plus air form exhaust emissions results in emissions of H20, CO2, CO, HC, NOX, SOX, Aldehydes and PM 10. (Particulate Matter).

• EPA is particularly interested in FormaldehydeReduction which is a HAP (Hazardous Air Pollutant), known to be a human carcinogen and Greenhouse Gas which is regulated by the EPA, Clean Air Act.

Emission Standards: Existing RICE at Major Source

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HP Engine subcategory

CI SI 2SLB SI 4SLB SI 4SRBSI

LFG/DG

Non-Emergency Emergency

Lss 100Change oil and filter and inspect air cleaner(CI) or spark plug (SI) every 1000

hours or annually, inspect belts and hoses every 500 hours of operation.

Change oil/filter, insp.

hoses and belts 500 hrsor ann. Insp. air cleaner and spark

plugs 1000 hrsor annually.

100-300 230 ppm CO225 ppm

CO 47 ppm CO 10.5 ppm CH2O177 ppm

CO

300-500

49 ppm CO or 70 % CO

reduction225 ppm

CO 47 ppm CO 10.5 ppm CH2O177 ppm

CO

More 500

23 ppm CO or 70% CO

reductionNo

StandardsNo

Standards

350 ppb CH2O or 70 % CH2o Reduction

No standard

Emission Standards-New RICE at Major Source

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HP Engine subcategory

CI SI 2SLB SI 4SLB SI 4SRBSI

LFG/DG

Non-EmergencyEmergency

Less 250 Comply IIII Comply JJJJ Comply JJJJ Comply JJJJComply JJJJ

Comply with CI or SI but for

more than 500 HP no standard.

250-500 Comply IIII Comply JJJJ

14 ppm CH2O OR 93% CO Red. Comply JJJJ

Comply JJJJ

More 500

580 ppb CH2O or 70% CO

12 ppm CH2O or 58% CO

14 ppm CH2O OR 93% CO Red.

350 ppb CH2O or 70 % CH2o Reduction

No standard

Compliance Requirement: Rice at Major Source

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Engine subcategory Compliance RequirementExisting Non-EmergencyCI More than 100 HP at major sourceSI 100-500 HP at major source

Initial testSubsequent testing every 8760hours or 3 years for more than 500 HP (5 years for limited use)NotificationsSAM reports (annual report for limited use)ULSD FuelCrankcase emission control requirement

Compliance Requirements: Rice at Major Source

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Engine Subcategory Compliance RequirementExisting Non EmergencySI 4 SRB More than 500 HP

New Non EmergencySI 2 SLB More than 500 HPSI 4 SLB More than 250 HPSI 4 SRB More than 500 HPCI more than 500 HP

Initial testSubsequent test semi-annually (can be reduced)Operating limitation –catalyst pressure drop and inlet temp.NotificationSemi- annual compliance report

New Emergency/Limited useMore than 500 HP

Initial notificationReporting and ULSD for emergencyengines used for demand response

New Non-emergency LFG/DGMore than 500 HP major source

Initial notification Monitor/record fuel usesAnnual report of fuel uses

Compliance Requirement: RICE at Major Sources

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Engine Subcategory Compliance RequirementExisting emergency/black start more than 500 HP Existing non-emergency less than 100 HP at major source

Operate and maintain mfg. spec.May use oil analysis programRecord of operation and non-settable hour meterKeep recordsNotification not requiredReporting and ULSD for engines more than 100 HP used for emergency demand

Compliance - Existing Non-Emergency RICE at AREA Source

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HP Engines SubcategoryCI SI 2SLB SI 4S Remote SI 4S Non-remote SI LFG/DG

Non-Emergency

less 300 HP

Change Oil and filter 1000 hours and hoses and belts 500 hours

Change oil/filter spark inspect hoses and belts 4320 hours or annually

change oil/filter, inspect spark plug and hoses and belts 1440 hours or annually same as left

Change oil/filter/ inspect spark plugs inspect hoses and belts 1440 hours or annually

300-500

49 PPM CO or 70 % CO Reduction Same above same above same above same above

More 500

23 ppm CO or 70% CO reduction Same above

Change oil/filter, inspect spark plug and hoses and belts 2160 hours or annually

If engines used more than 24 hours 4 SLB install catalyst, 4 SRB install NSCR same above

Compliance Requirement: Non-Emergency Engines at Area Source

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Engine Subcategory Compliance RequirementsExisting non-emergency CI more than 300 HP at area source

Existing non-emergency SI4SLB/4SRB more than 500 HP at area source used more than 14 hr. and not in remote area.

Initial testSubsequent test 8760 hours or three years for engines more than 500 HP (5 yr. for limited use)Operating limitation catalyst pressure drop 2’’ Water and inlet temperature for engines 450-1350 F more than 500 HPNotification is requiredULSDCrankcase emission control

Initial and annual catalyst activity checkHigh temp. engine shutdown or continuously monitor inlet temp.Notification is requiredSemi annual compliance report

Compliance Requirements: Non-Emergency Engines at Area Sources

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Engine Subcategory Compliance RequirementsExisting Non-EmergencyBlack start at area sourcesCI less 300 HPSI less 500 HPSI 2SLB more 500 HPSI LFG/DG more 500 HPSI 4SLB and 4 SRB more 500 HP used less than 24 hours in remote area

Operate and maintain engine and control system as per mfg. specs.May use oil analysis program instead of frequencyKeep records of maintenanceNotification not required

Controls - Oxidation Catalyst

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• Controls CO and VOC by oxidation.

• CO is reduced to O2• HC is Oxidized to H2O• Catalyst Inlet Temp and

pressure drop monitored if the engine is more than 500 HP.

Controls - Oxidation Catalyst

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Positive Crankcase Ventilation (PCV) System

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• Some exhaust gas escape past piston into crankcase of engines

• In the past these blow-by gas used to be removed from crankcase as emissions

• These gases are re-circulated to intake manifold through a valve.

• Reduces HC by 25%

Small 100 HP 4SRB- Existing

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• Change oil & filter every 1440 hr. of operation or annually.• Inspect spark & plugs every 1440 hr. of operation or annually.• Inspect hoses & belts every 1440 hr. or annually which ever

comes first.

Diesel Fuel Requirements:

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Date RequirementOctober 1, 2007 Low Sulfur Diesel

October 1, 2010

Engines less than 30 litr/cylinderdisplacement

Ultra Low Sulfur Diesel (ULSD)Max sulfur content 15 ppmMinimum cetane index of 40 or max aromatic content of 25 volume%

June 2012Engines with more than 30 lit/cyl.

1000 ppm sulfur diesel

Owner/Operator Compliance Requirements

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• 2007 model year and later with displacement less than 30 liters/cylinder-

Purchase certified engines.**********************

• Displacement more than 30 liters/cylinder.Initial performance test.Annual performance test for non-emergency engines.Continuously monitor operating parameters.

Compliance Requirements

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• Certified enginesInstall according to mfg. and operate

• If not operated according to mfg. spec – Keep maintenance record– Operate with good AP control– 100- 500 HP initial performance test– More than 500 HP initial performance test and

after 8760 hours or three years, whichever comes first

Compliance Requirements

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• Non-certified engines.- Maintenance plan.- Performance testing, 25-500 HP initial test, & more

than 500 HP initial and 8760 hrs. or three years.- Monitoring and record keeping.

Air Permits for Engines

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• Permitted facilities list the engines as emission units. A construction permit must be issued for a new engine at a minor or major permitted facility.

• Engines not qualifying for categorical exemption (Emergency, etc.) must obtain a permit. (Depending upon fuel usage –General Permit or Air Construction/Air Operating Permit).

• All the RICE engines must comply with RICE NESHAP rule 40 CFR 63 Subpart ZZZZ whether they are permitted or not.

• Don’t have to send an initial notification for emergency engines.

Air Permits for Engines

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EXEMPT – No permit required for RICE Emergency Engines or if fuel does not exceed:• This is total for all engines at site

5,400 gallons of Gasoline per year.64,000 gallons of Diesel fuel per year.

288,000 gallons of Propane per year.8.8 million standard cubic feet of Natural Gas / year.

EMERGENCY ENGINES DO NOT REQUIRE A PERMIT IF OPERATED IN ACCORDANCE WITH RULES.

• (Except for Title V facilities, where it must be included as part of the Title V operation).

Air Permits for Engines

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GENERAL PERMIT (GP) - if fuel does notexceed:

20,000 gallons of Gasoline per year250,000 gallons of Diesel fuel per year

1.15 million gallons of Propane per year40 million standard cubic feet of Natural Gas per year

*************• General Permits – $100 Fee - Reciprocating Internal

Combustion Engines (RICE) - Contact:Barbara Friday (D.E.P., Tallahasse, Florida)

Air General Permits850-717-9095

Air Permits for Engines

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• Above General Permit (GP) Thresholds –Over 20,000 gallons of Gasoline per year.Over 250,000 gallons of Diesel fuel per year.Over 1.15 million gallons of Propane per year.Over 40 million standard cubic feet of Natural Gas/year.

* An Air Construction permit is required, with fee and Public Notice, then an Air Operating permit is

required with a fee. (Unless it is a Title V facility).

Air Permits for Engines

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EXEMPTION Documentation• The Department does not issue an exemption

certificate or document. • However, the Department will accept written

notifications from an applicant who is using or plans to use a RICE Engine that meets the exemption rules. This notification will be maintained in the Department’s database files.

Contact

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Florida Department of Environmental Protection

2295 Victoria Avenue, Suite 364Fort Myers, Florida 33902

Carter B. Endsley, P.E.Professional Engineer

Air Resources Management *

Tel: (239) 344-5600 Email: carter.endsley@dep.state.fl.us