Compliance with RICE Compliance with RICE RegulationsRegulations

Texas Alliance of Energy Texas Alliance of Energy ProducersProducers

Texas & Federal Environmental Texas & Federal Environmental Compliance SeminarCompliance Seminar

April 22, 2014

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AgendaAgenda• General Overview of Federal RICE Rules

• NESHAP ZZZZ – More Details

• Compliance Examples

• Other Lessons Learned

• Questions

General Overview of General Overview of Federal RICE RulesFederal RICE Rules

NSPS IIII

NSPS JJJJ

NESHAP ZZZZ

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RICE RulesRICE Rules• RICE = Reciprocating Internal Combustion

Engineo CI = Compression Ignition (diesel)o SI = Spark Ignition (natural gas)

• NSPS = New Source Performance Standards• NESHAP = National Emission Standard for

Hazardous Air Pollutants• Nearly ALL are subject to federal regulations• Consider engine only, not the compressor /

generator / pump / etc.

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NSPS Subpart IIII NSPS Subpart IIII • NEW Diesel Engines

o Constructed (ordered) > 7/11/2005 ANDo Manufactured > 4/1/2006*

• *For fire pump engines, > 7/1/2006

OR

o Modified / Reconstructed > 7/11/2005

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NSPS Subpart IIII NSPS Subpart IIII • Compliance

o IF the engine displacement is =>30 liters/cylinder, performance testing may be required

o Otherwise, comply by purchasing a certified engine

• AND install / operate / maintain according to manufacturer specifications

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NSPS Subpart JJJJ NSPS Subpart JJJJ • NEW Natural Gas Engines

o Constructed (ordered) > 6/12/2006 AND Manufactured:

• <500 hp, => 7/1/2008• =>500 hp, => 7/1/2007• Lean burn => 500 hp, < 1350 hp, =>

1/1/2008• Emergency > 25 hp => 1/1/2009

OR

o Modified / Reconstructed > 6/12/2006

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NSPS Subpart JJJJ NSPS Subpart JJJJ • Compliance:

o Purchasing a certified engine may be possible• AND install / operate / maintain according to

manufacturer specifications

o Otherwise, performance testing is required • Likely necessary to install a catalyst to meet

emissions limits

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NESHAP Subpart NESHAP Subpart ZZZZZZZZ

• Major HAP Sourceo > 500 hp

• Existing < 12/19/2002• New / Reconstructed => 12/19/2002

o =< 500 hp• Existing < 6/12/2006• New / Reconstructed => 6/12/2006

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NESHAP Subpart NESHAP Subpart ZZZZZZZZ

• Area HAP Sourceo Existing < 6/12/2006o New / Reconstructed => 6/12/2006*

• *Complies with this Subpart by Complying with NSPS 4J or 4I

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NESHAP Subpart NESHAP Subpart ZZZZZZZZ

• Compliance May Includeo Maintenance requirements o Emissions limits / performance testing (likely

requiring a catalyst)o CPMS / automatic temperature shut offo Pressure drop o Fuel requirementso Maintenance plano Non-resettable hour metero Crankcase controls

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How to Tell them How to Tell them ApartApart

• Need to Know:o Facility HAP status (area vs major)o Manufacture and construction dateo Any modification / reconstruction?o Engine type (CI vs SI, Lean vs Rich Burn, 2-

Stroke vs 4-Stroke, site rated hp)o Engine use (Emergency / black start / normal to

operate / stationary vs portable)o *Remote vs Non-Remote

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Some Important Some Important Definitions & Definitions & DistinctionsDistinctions

• NSPS vs NESHAP

• Manufacture vs Construct vs Order Date

• Reconstruction & Modification

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Define “Nearly All”Define “Nearly All”• A Few Exemptions

o Portable non-road

o Motor vehicles

o Residential, commercial, institutional (area source) existing emergency

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Define “Nearly All”Define “Nearly All”• Date Gap

o 6/12/2006 through 7/1/2008 (Area Source, SI, <500 hp)

o Technically subject to NESHAP 4Z, comply with the regulation by complying with NSPS 4J, but NO REQUIREMENTS under 4J

NESHAP ZZZZ Area NESHAP ZZZZ Area Source EnginesSource Engines

More Details

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Key DatesKey Dates• 5/3/2013o Compliance date for CI Engines

• “Annual” requirement due date coming up soon!

• 10/19/2013o Compliance date for SI Engines

• 4/17/2014 testing due date, if applicable

• 1/31/2014o First semiannual compliance report due

Existing Area Source Engines, excerpted from http://www.epa.gov/region1/rice/

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RemoteRemote• A pipeline segment with 10 or fewer

buildings intended for human occupancy and no buildings with four or more stories within 220 yards (200 meters) on either side of the centerline of any continuous 1-mile (1.6 kilometers) length of pipeline. Each separate dwelling unit in a multiple dwelling unit building is counted as a separate building intended for human occupancy.

• AND

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RemoteRemote• The pipeline segment does not lie within

100 yards (91 meters) of either a building or a small, well-defined outside area (such as a playground, recreation area, outdoor theater, or other place of public assembly) that is occupied by 20 or more persons on at least 5 days a week for 10 weeks in any 12-month period. The days and weeks need not be consecutive. The building or area is considered occupied for a full day if it is occupied for any portion of the day.

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Timeline for RICETimeline for RICE• Existing Non-emergency Non-remote SI >500

hp 4SLB / 4SRB engineso By October 19, 2013

• Install OC on 4SLB and NSCR on 4SRB• Install automatic engine shutdown device

(Catalyst inlet limit of 1350°F for 4SLB, 1250°F for 4SRB) OR CPMS

o Initial testing must be complete by 4/17/2014o Annual compliance demonstration

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Timeline for RICETimeline for RICE• All Other Existing SI engines – by October 19,

2013o Implement Maintenance Plan – Document

maintenance and be prepared for inspector review.

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Timeline for RICETimeline for RICE• Ongoing Requirementso Engine startups not to exceed 30 minutes.o “Remote” status must be reviewed every 12 months.

If the status has changed, the facility has 12 months to comply.

o Annual maintenance activities – in accordance with maintenance plan for engines

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Reports / NotificationsReports / Notifications• Notification of Compliance Status Report for

Non-Remote Engineso Regarding automatic temperature shutdown

equipment

• Notice of Intent to Conduct Performance Testing for Non-Remote Engineso Due 60 days prior to test

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Reports / NotificationsReports / Notifications• Notification of Compliance Status Report for

Non-Remote Engineso Regarding Initial Compliance Demonstration

Testingo Due within 60 days of testing

• Semiannual Compliance Report for Non-Remote Engineso Initial Report due 1/30/2014o Next due 7/31/2014

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Annual / Ongoing Annual / Ongoing ActivitiesActivities

• Annual review of remote status

• Engine startups not to exceed 30 minutes

NESHAP ZZZZNESHAP ZZZZCompliance Examples

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Maintenance Maintenance RequirementsRequirements

• Note that different engine categories have different maintenance intervals o 1,440 hours (60 days)o 2,160 hours (90 days)o 4,320 hours (180 days)

• Be cautious to ensure that the SITE-RATED hp is used in determining the frequency.

• Consider each engine category having a unique tailored PM schedule

• OR

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Maintenance Maintenance RequirementsRequirements

• Consider a common schedule• Example:

o Monthly Maintenance• Inspect spark plugs, belts and hoses• Obtain oil analyses• If the oil analysis fails to meet the required

standards, then the oil will be changed within 2 business days of receiving the oil analysis report

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Oil AnalysesOil Analyses• Ensure that the required parameters

are included in the report

• Ensure that alerts / notifications are provided timely

• Ensure that any parameters to be compared to “new oil” were properly acquired for the “new oil”

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Remote / Non Remote Remote / Non Remote Determination Determination

ExampleExample

RICE Rules – Lessons RICE Rules – Lessons LearnedLearned

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Lessons LearnedLessons Learned

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I’m Getting Thirsty. I’m Getting Thirsty. Where’s my Where’s my

Lemonade???Lemonade???

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QuestionsQuestions• Contact me:

o Kristine Baranskio kdb@cardinalengineers.como (405) 842 - 1066

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ResourcesResources• http://www.epa.gov/region1/rice/• http://www.epa.gov/ttn/atw/icengines/imp.

html#qao See especially:

• 04/02/2013 Implementation Question and Answer Document for NESHAP for Stationary RICE and NSPS for Stationary CI and SI ICE (pdf file)

• 02/07/2014 RICE Summary Table of Requirements (xls file)