privileged & confidential reciprocating internal combustion engine (rice) regulatory update...
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Reciprocating Internal Combustion Engine(RICE) Regulatory Update
Reciprocating Internal Combustion Engine(RICE) Regulatory Update
American Public Power Association
June 8, 2010
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Overview: RICE Regulated in 4 Stages
1. June 2004 Final Rule– New and reconstructed >500 HP at major sources
– Existing 4SRB RICE >500 HP at major sources
– No requirements for emergency or area sources
2. January 2008 Final Rule (new engines only)– area sources
– <500 HP at major sources
– proposal for existing engines not finalized because of decision in Sierra Club v. EPA (brick/clay MACT)
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Overview: RICE Regulated in 4 Stages
3. February 2010 Final Rule (March 2009 proposal for compression ignition engines)– NESHAPs for new, reconstructed and existing RICE
– Many subcategories, based on• size (HP)• area Source or major source• emergency or non-emergency use
4. August 10, 2010 Final Rule (March 2009 proposal for spark ignition engines)
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Compliance Dates
• Existing compression ignition RICE must comply by May 3, 2013
• New compression ignition RICE must comply by May 3, 2010
– mostly a manufacturer issue?
• Petition for review by Enernoc, Cpower, Energyconnect and Innovative Power
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Major Sources and Area Sources
• A major source has potential to emit 10 tpy of any HAP or 25 tpy or more of all HAPs
– probably all coal-fired power plants
• Area sources are sources that are not major sources
– many nuclear plants, CT stations, hydro
• Cost/economic impacts are factors for area sources but not in setting MACT floor for major sources
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Proposal Affected All Engine Sizes
4100 HP Generator Set
Utility
4 HP Emergency Generator
Residential
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Basis for Proposed Limits• Utilized emission data from 2000 database
– no new data collected from 2000 to 2010
• Based MACT floor emissions on insufficient data– utilized “best performing 12%” criterion
failed to consider total engines in population
– some floor emission levels based on one engine
– no variability in floor limit determination• Generally poor technical work
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Basis for Proposed Limits
• Based above-the-floor limits on oxidation catalysts– assumed oxidation catalyst achieves 90% reduction– assumed most RICE would not require catalyst
low proposed CO limit makes assumption inaccurate
most actually could not meet MACT floor
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Proposal for Major Sources
2 p
pm
fo
rmal
deh
yde
4 ppm CO or 90% CO Reduction
40 ppm CO
2 p
pm
fo
rmal
deh
yde
40 ppm CO
10050 200 300 400 500
HORSE POWER
0
NON-EMERGENCY
EMERGENCY
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Proposal for Area Sources
500
Hr
Insp
ecti
on
PERIODIC MAINTENANCE 500 Hrs - Change Oil & Filter
and Inspect Hoses & Belts, 1000 Hrs - Inspect Air Cleaner
PERIODIC MAINTENANCE 500 Hrs - Change Oil & Filter and Inspect Hoses
and belts 1000 Hrs - Inspect Air Cleaner 40 ppm CO
500
Hr
Insp
ecti
on
4 ppm COor 90% CO reduction
10050 200 300 400 500
HORSE POWER
0
NON-EMERGENCY
EMERGENCY
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Example of EPA’s Misinterpretation of Data4SRB Spark Ignition Engines
0
50
100
150
200
250
300
350
400
450
0 500 1000 1500 2000 2500 3000 3500 4000 4500
Engine Size, HP
CO
Em
iss
ion
s,
pp
mv
d
Data Used to Set the CO MACT
Limit
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Revised MACT Floor Analysis
• 5 new emission data reports
– 11 new stationary engines plus 1 previous CSU engine
• Engines 100 ≥HP ≤300 MACT floor
– based on 2 engines using CO from 6 runs
– CO emission floor set at 230 ppm (previously 40 ppm)
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Revised MACT Floor Analysis
• Engines 300 <HP ≤500 MACT floor
– based on 2 engines using CO from 6 runs
– CO floor set at 137 ppm (previously 40 ppm)
• Engines > 500 HP
– Based on 1 test from data on 8 Engines
– CO emission floor set at 38 ppm (previously 40 ppm)
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Revised MACT Floor Dataset
0
100
200
300
400
500
600
0 500 1000 1500 2000 2500 3000 3500 4000
Engine Rating HP
CO
Em
iss
ion
s, p
pm
vTest Run 1 Run 2 Run 3
100<HP≤300 Floor
300<HP≤500 Floor
> 500 HP Floor
70 % Reduct Basis
70 % Reduct Basis
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Uncontrolled CO Emission Load CharacteristicsAverage Emissions for 550 HP CI Engines 2 & 3
0
10
20
30
40
50
60
70
80
90
100
0 20 40 60 80 100 120
Percent of Rated Load
CO
Em
iss
ion
, pp
mv
264 Percent CO Emission
Increase
Basis of MACT CO
Floor Level
0
10
20
30
40
50
60
70
80
90
100
0 20 40 60 80 100 120
Percent of Rated Load
CO
Em
iss
ion
, pp
mv
264 Percent CO Emission
Increase
Basis of MACT CO
Floor Level
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Emergency RICE• Engines whose operation is limited to
emergency situations and required testing and maintenance, for example:
– produce power for critical networks or equipment when power is interrupted
– pump water during a fire or flood• Peak shaving engines do not qualify as
emergency engines
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Emergency RICE• No time limit for emergency operations• Minimize testing, but no time limit for routine
testing and maintenance• Engines >500 HP installed before June 2006 may
operate 50 hr/yr in non-emergency situations• If regional transmission authority determines need,
may operate 15 hours/year while generating revenue to maintain system voltage or avoid potential blackout
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Improvements at Area Sources• Existing emergency engines located at residential,
commercial and institutional facilities are exempt
– were not included in 1990 baseline emissions for CAA amendments
– eliminated 95% of engines for one utility
– some engines may be ambiguous• Requirements for many existing sources are work
practices (periodic maintenance and inspections), not emission limits
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Improvements for Major Sources
• Emergency RICE <500 HP have work practice standards only, no emission limits
• Non-emergency RICE <100 HP have work practice standards only, no emissions limits
• Work practices include periodic changes of oil and filters; periodic inspections of air cleaners, hoses, belts, etc.
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CI RICE Catalyst Capital Cost
0
10,000
20,000
30,000
40,000
50,000
60,000
70,000
80,000
90,000
100,000
0 500 1,000 1,500 2,000 2,500 3,000 3,500
Engine Horspower
Cap
ital
Co
st, $
Proposed RICE Rule Final RICE Rule
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CI RICE Catalyst Annual Operating Cost
0
2,000
4,000
6,000
8,000
10,000
12,000
14,000
16,000
18,000
0 500 1,000 1,500 2,000 2,500 3,000 3,500
Engine Horsepower
An
nu
al
Op
era
tin
g C
os
t, $
Proposed RICE Rule Final RICE Rule
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Start-up, Shutdown, Malfunction• In 2008, D.C. Circuit invalidated EPA’s rules that
exempted SSM from emissions standards --NESHAPs must apply even during SSM
• EPA proposed NESHAPs for startup and malfunction (not shutdown) for all ZZZZ engines
– shutdowns are short and can meet normal limit
• UARG objected to setting startup and malfunction NESHAPs at same levels as normal operations
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Start-up, Shutdown, Malfunction• Final rule eliminated NESHAPs for startup
and set instead work practice standards– emissions significantly different from normal operations
– minimize idle and startup time (maximum 30 minutes)
• No malfunction limits – EPA assumes engine would shut down immediately
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Compliance
• Compliance for engines with numerical limits
– initial and periodic tests (3 one-hour tests)
• Monitoring
– engines > 500 HP must install continuous parameter monitoring systems (CPMS) monitor CO reduction, catalyst inlet temperature and
pressure drop CO reduction demonstrated on 4-hour rolling average
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COMPARISON OF PROPOSED & FINAL EMISSION REQUIREMENTS FOR COMPRESSION IGNITION ENGINES LOCATED AT MAJOR SOURCES
* Above-the-Floor Used Highest CO 163 ppmv
** Above-the-Floor Used Highest CO 77 ppmv
230 ppm COPeriodic
Maintenance (See Below)
49 ppm CO or 70 % CO
Reduction
Floor = 137 ppmv *
23 ppm CO or 70 % CO
Reduction Floor = 38
ppmv **
2 p
pm
form
ald
eh
yd
e
4 ppm CO or90 % CO Reduction Floor = 40 ppmv
40 ppm CO
2 p
pm
form
ald
eh
yd
e
PERIODIC MAINTENANCE FOR EMERGENCY AND BLACK START ENGINES
500 Hrs - Change Oil & Filter and Inspect Hoses & Belts, 1000 Hrs - Inspect Air Cleaner
40 ppm CO
10050 200 300 400 500
HORSE POWER
0
NO
N-E
ME
RG
EN
CY
FIN
AL
PR
OP
OS
ED
FIN
AL
PR
OP
OS
ED
EM
ER
GE
NC
Y
* Above-the-Floor Used Highest CO 163 ppmv
** Above-the-Floor Used Highest CO 77 ppmv
230 ppm COPeriodic
Maintenance (See Below)
49 ppm CO or 70 % CO
Reduction
Floor = 137 ppmv *
23 ppm CO or 70 % CO
Reduction Floor = 38
ppmv **
2 p
pm
form
ald
eh
yd
e
4 ppm CO or90 % CO Reduction Floor = 40 ppmv
40 ppm CO
2 p
pm
form
ald
eh
yd
e
PERIODIC MAINTENANCE FOR EMERGENCY AND BLACK START ENGINES
500 Hrs - Change Oil & Filter and Inspect Hoses & Belts, 1000 Hrs - Inspect Air Cleaner
40 ppm CO
10050 200 300 400 500
HORSE POWER
0
NO
N-E
ME
RG
EN
CY
FIN
AL
PR
OP
OS
ED
FIN
AL
PR
OP
OS
ED
EM
ER
GE
NC
Y
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COMPARISON OF PROPOSED & FINAL EMISSION REQUIREMENTS FOR COMPRESSION IGNITION ENGINES LOCATED AT AREA SOURCES
50
0 H
r In
spe
cti
on
PERIODIC MAINTENANCE500 Hrs - Change Oil & Filter and
Inspect Hoses & Belts, 1000 Hrs - Inspect Air Cleaner
PERIODIC MAINTENANCE500 Hrs -Change Oil & Filter and Inspect Hoses & Belts,
1000 Hrs - Inspect Air Cleaner 40 ppm CO
49 ppmCO, or 70 % CO Reduction
23 ppm CO,or 70 % CO Reduction
PERIODIC MAINTENANCE500 Hrs - Change Oil & Filter and Inspect
Hoses & Belts, 1000 Hrs - Inspect Air Cleaner
PERIODIC MAINTENANCE500 Hrs - Change Oil & Filter and Inspect Hoses & Belts,
1000 Hrs - Inspect Air Cleaner(BOTH EMERGENCY AND NON-EMERGENCY BLACK START ENGINES)
50
0 H
r In
spe
cti
on
4 ppm CO , or 90 % CO Reduction
10050 200 300 400 500
HORSE POWER
0
NO
N-E
ME
RG
EN
CY
FIN
AL
PR
OP
OS
ED
FIN
AL
PR
OP
OS
ED
EM
ER
GE
NC
Y
50
0 H
r In
spe
cti
on
PERIODIC MAINTENANCE500 Hrs - Change Oil & Filter and
Inspect Hoses & Belts, 1000 Hrs - Inspect Air Cleaner
PERIODIC MAINTENANCE500 Hrs -Change Oil & Filter and Inspect Hoses & Belts,
1000 Hrs - Inspect Air Cleaner 40 ppm CO
49 ppmCO, or 70 % CO Reduction
23 ppm CO,or 70 % CO Reduction
PERIODIC MAINTENANCE500 Hrs - Change Oil & Filter and Inspect
Hoses & Belts, 1000 Hrs - Inspect Air Cleaner
PERIODIC MAINTENANCE500 Hrs - Change Oil & Filter and Inspect Hoses & Belts,
1000 Hrs - Inspect Air Cleaner(BOTH EMERGENCY AND NON-EMERGENCY BLACK START ENGINES)
50
0 H
r In
spe
cti
on
4 ppm CO , or 90 % CO Reduction
10050 200 300 400 500
HORSE POWER
0
NO
N-E
ME
RG
EN
CY
FIN
AL
PR
OP
OS
ED
FIN
AL
PR
OP
OS
ED
EM
ER
GE
NC
Y
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Metallic HAP for RICE >300 HP
• Non-emergency units not already equipped with a closed crankcase system must:
– install a closed crankcase systemOR
– install an open crankcase filtration system to remove oil, mist, PM and metals
• Applies to both major and area sources
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Closed Crankcase System Costs• Capital Costs
– $1,075 (300 HP)
– $1,777 (3,000 HP)
• Annual Operating Costs
– $275 (300 HP)
– $450 (3,000 HP)
• Cannot assess accuracy of estimates
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Low Sulfur Fuel Requirements• Applies to both major and area sources• Applies to RICE >300 HP with displacement
of less than 30 liters per cylinder• Maximum sulfur content of 15 ppm
and• Either a minimum cetane index of 40 or a
maximum aromatic content of 35%
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RICE Used to Start CTs• Engines used to start up combustion
turbines are deemed to be “black start” engines
• Back start engines must meet the same work practice standards as emergency engines
• Such engines typically operate <20 hours per year
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Title V Permits for Area Sources
• Section 63.6585(d)
• All RICE located at area sources are exempt from Title V permits under parts 70 and 71 provided sources do not otherwise have to meet such requirements.
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Assessment of Final Rule• Greatly reduced need for above-the-floor controls
– proposal would have required catalyst on most CI engines
– MACT floor 6-12 times higher than proposed
• Engines < 300 HP may avoid oxidation catalyst• Engines > 300 HP
– some might comply w/o oxidation catalyst
– oxidation catalyst must reduce CO by 70%, not 90%
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Planning for Compliance With ZZZZ
1. Detailed inventory – make, model, rated HP, year in service, type (CI, SI [4/2 stroke, rich/lean burn], fuel type
2. Identify requirements for CI engine population
a. > 300 HP that do not have closed crankcase systems
b. those with low sulfur fuel requirements
c. those required to install CPMS
d. those subject to maintenance practices
e. those potentially subject to oxidation catalyst
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Planning for Compliance With ZZZZ
3. Review manufacturer’s recommended maintenance practices for maintenance practice-only engines
– prepare a maintenance plan to meet RICE MACT requirements
4. Develop test plans for engines with numerical limits
– assess availability of test contractors
– schedule tests
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Planning for Compliance With ZZZZ
5. Assess applicability of installation of oxidation catalyst
– potential degree of installation difficulty,
– assemble a list of catalyst vendors
– assess whether installation can be performed in-house
6. Assess CPMS requirements for engines > 500 HP
7. Develop an implementation plan with timelines to ensure that all engines are in compliance by May 2013