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


2

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)


3

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)


4

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


5

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


6

Proposal Affected All Engine Sizes

4100 HP Generator Set

Utility

4 HP Emergency Generator

Residential


7

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


8

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


9

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


10

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


11

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


12

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)


13

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)


14

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


15

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


16

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


17

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


18

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


19

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.


20

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


21

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


22

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


23

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


24

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


25

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 *


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)


Reduction

Floor = 137 ppmv *


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


26

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


27

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


28

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


29

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%


30

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


31

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.


32

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%


33

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


34


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


35


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

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