Mustang Watchdog April 22, 2014 2/6/2013 Compliance with RICE Regulations Texas Alliance of Energy Producers Texas & Federal Environmental Compliance Seminar April 22, 2014 Confidential Business Information

Agenda General Overview of Federal RICE Rules Mustang Watchdog Agenda 2/6/2013 General Overview of Federal RICE Rules NESHAP ZZZZ – More Details Compliance Examples Other Lessons Learned Questions Confidential Business Information

General Overview of Federal RICE Rules Mustang Watchdog 2/6/2013 General Overview of Federal RICE Rules NSPS IIII NSPS JJJJ NESHAP ZZZZ Confidential Business Information

RICE Rules RICE = Reciprocating Internal Combustion Engine CI = Compression Ignition (diesel) 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.

NSPS Subpart IIII NEW Diesel Engines Constructed (ordered) > 7/11/2005 AND Manufactured > 4/1/2006* *For fire pump engines, > 7/1/2006 OR Modified / Reconstructed > 7/11/2005

NSPS Subpart IIII Compliance IF the engine displacement is =>30 liters/cylinder, performance testing may be required Otherwise, comply by purchasing a certified engine AND install / operate / maintain according to manufacturer specifications

NSPS Subpart JJJJ NEW Natural Gas Engines 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 Modified / Reconstructed > 6/12/2006

NSPS Subpart JJJJ Compliance: Purchasing a certified engine may be possible AND install / operate / maintain according to manufacturer specifications Otherwise, performance testing is required Likely necessary to install a catalyst to meet emissions limits

NESHAP Subpart ZZZZ Major HAP Source > 500 hp Existing < 12/19/2002 New / Reconstructed => 12/19/2002 =< 500 hp Existing < 6/12/2006 New / Reconstructed => 6/12/2006

NESHAP Subpart ZZZZ Area HAP Source Existing < 6/12/2006 New / Reconstructed => 6/12/2006* *Complies with this Subpart by Complying with NSPS 4J or 4I

NESHAP Subpart ZZZZ Compliance May Include Maintenance requirements Emissions limits / performance testing (likely requiring a catalyst) CPMS / automatic temperature shut off Pressure drop Fuel requirements Maintenance plan Non-resettable hour meter Crankcase controls

How to Tell them Apart Need to Know: Facility HAP status (area vs major) Manufacture and construction date Any modification / reconstruction? Engine type (CI vs SI, Lean vs Rich Burn, 2-Stroke vs 4-Stroke, site rated hp) Engine use (Emergency / black start / normal to operate / stationary vs portable) *Remote vs Non-Remote

Some Important Definitions & Distinctions NSPS vs NESHAP Manufacture vs Construct vs Order Date Reconstruction & Modification

Define “Nearly All” A Few Exemptions Portable non-road Motor vehicles Residential, commercial, institutional (area source) existing emergency

Define “Nearly All” Date Gap 6/12/2006 through 7/1/2008 (Area Source, SI, <500 hp) Technically subject to NESHAP 4Z, comply with the regulation by complying with NSPS 4J, but NO REQUIREMENTS under 4J

NESHAP ZZZZ Area Source Engines Mustang Watchdog 2/6/2013 NESHAP ZZZZ Area Source Engines More Details Confidential Business Information

Key Dates 5/3/2013 10/19/2013 1/31/2014 Compliance date for CI Engines Mustang Watchdog Key Dates 2/6/2013 5/3/2013 Compliance date for CI Engines “Annual” requirement due date coming up soon! 10/19/2013 Compliance date for SI Engines 4/17/2014 testing due date, if applicable 1/31/2014 First semiannual compliance report due Confidential Business Information

Mustang Watchdog 8/29/2012 Existing Area Source Engines, excerpted from http://www.epa.gov/region1/rice/ Confidential Business Information

Mustang Watchdog Remote 8/29/2012 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 Confidential Business Information

Mustang Watchdog Remote 8/29/2012 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. Confidential Business Information

Mustang Watchdog Timeline for RICE 2/6/2013 Existing Non-emergency Non-remote SI >500 hp 4SLB / 4SRB engines 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 Initial testing must be complete by 4/17/2014 Annual compliance demonstration Confidential Business Information

Timeline for RICE All Other Existing SI engines – by October 19, 2013 Mustang Watchdog Timeline for RICE 2/6/2013 All Other Existing SI engines – by October 19, 2013 Implement Maintenance Plan – Document maintenance and be prepared for inspector review. Confidential Business Information

Timeline for RICE Ongoing Requirements Mustang Watchdog Timeline for RICE 2/6/2013 Ongoing Requirements Engine startups not to exceed 30 minutes. “Remote” status must be reviewed every 12 months. If the status has changed, the facility has 12 months to comply. Annual maintenance activities – in accordance with maintenance plan for engines Confidential Business Information

Reports / Notifications Notification of Compliance Status Report for Non-Remote Engines Regarding automatic temperature shutdown equipment Notice of Intent to Conduct Performance Testing for Non-Remote Engines Due 60 days prior to test

Reports / Notifications Notification of Compliance Status Report for Non-Remote Engines Regarding Initial Compliance Demonstration Testing Due within 60 days of testing Semiannual Compliance Report for Non-Remote Engines Initial Report due 1/30/2014 Next due 7/31/2014

Annual / Ongoing Activities Annual review of remote status Engine startups not to exceed 30 minutes

NESHAP ZZZZ Compliance Examples Mustang Watchdog 2/6/2013 Confidential Business Information

Maintenance Requirements Note that different engine categories have different maintenance intervals 1,440 hours (60 days) 2,160 hours (90 days) 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

Maintenance Requirements Consider a common schedule Example: 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

Oil 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”

Remote / Non Remote Determination Example Mustang Watchdog 8/29/2012 Remote / Non Remote Determination Example Insert example here. Confidential Business Information

RICE Rules – Lessons Learned Mustang Watchdog 2/6/2013 RICE Rules – Lessons Learned Confidential Business Information

Lessons Learned Mustang Watchdog 2/12/2014 Accurate, up to date information is critical Compliance tracking can be burdensome Not all NSPS 4J limits are the same. Understand the correct limits based on hp, manufacture date. Definition of terms may vary between NSPS / NESHAP Double, triple check serial numbers and use for all compliance correspondence Understand what engine rental agreement specifies for compliance activities (testing, notices, etc.) IF Major for HAP in the past or under another MACT, possible to be synthetic minor for HAP Confidential Business Information

I’m Getting Thirsty. Where’s my Lemonade??? Mustang Watchdog I’m Getting Thirsty. Where’s my Lemonade??? 2/12/2014 Consider converting sites to synthetic minor as renewals come due Lower emissions based on stack test data Opportunity to obtain / implement tracking database; hopefully acquire more accurate information Confidential Business Information

Questions Contact me: Kristine Baranski kdb@cardinalengineers.com Mustang Watchdog Questions 8/29/2012 Contact me: Kristine Baranski kdb@cardinalengineers.com (405) 842 - 1066 Confidential Business Information

Resources http://www.epa.gov/region1/rice/ Mustang Watchdog Resources 8/29/2012 http://www.epa.gov/region1/rice/ http://www.epa.gov/ttn/atw/icengines/imp.html#qa 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) Confidential Business Information