1. BOILERS, ENGINES, & INCINERATORS OH MY! Fred P. Osman, P.E.,BCEE Osman Environmental Solutions Harrisburg, PA July 29, 2011

2. BoilersEngines 2.5 MMBTU/hr – Exempt from P/A<100 b.h.p. – Exempt from P/A 10 MMBTU/hr, NG or No. 2 – Exempt from P/A NO X < 100 lb/hr, 1000 lb/day, 2.75 tons in O 3 season, 6.6 TPY – Exempt from P/A <50 MMBTU/hr – NG, #2, or LPG - GP GP5 – NG compression or processing GP9 – Stringent Control req. for high use Cat ox required between 100-4800 hours depending on engine size 80% NO X control required between 500-7000 hours depending on size GP11 – Nonroad Engines – 12 month limit P/A – Plan Approval or Construction Permit GP – General Permit

3. Major source vs. area source Determine whether facility is major for HAPS Area sources burning NG are not subject to rule All other sources are (all major source and all area source boilers burning liquid or solid fuels)

4. Area Source (Existing)Major Source (Existing) Emission LimitsCoal-fired* >10 MMBTU/hr All but Gas -1 fueled Tune ups2-yr (most), 5-yr except NG 1-yr (most), 2-yr, 5-yr One time energy assess.All >10 MMBTU except NG All Initial NoticeJanuary 20, 2014May 31, 2013 Compliance date, inc. tune-up, energy assessment March 14, 2014January 31, 2016 *Coal-fired means burns any solid fuel, but <15% biomass Gas -1 is NG, refinery gas or other low H g gas

5. Boilers burn fuel/Incinerators burn wastes Fuel is: Traditional fuels (coal, oil, NG, etc.) Clean cellulosic biomass Scrap tires managed under tire collection program Resinated wood Materials under the control of the generator* Wastes processed into fuels* Materials determined to be non-waste by EPA* *Must meet legitimacy criteria

6. EPA emission limits for new engines (Tier Limits) and New Source Performance (NSPS) RICE rule regulates older engines emissions (RICE still applies but generally defers to NSPS) Compliance dates for area sources (CI - 5/3/13, SI - 10/19/13) Emergency operation strictly defined

7. Nonroad engine is any internal combustion engine: (iii) [t]hat, by itself or in or on a piece of equipment, is portable or transportable, meaning designed to be and capable of being carried or moved from one location to another. Indicia of transportability include, but are not limited to, wheels, skids, carrying handles, dolly, trailer, or platform." But a non-road engine that remains at one location for 12 months becomes forever stationary One cannot simply relocate an engine solely to avoid it becoming a stationary engine; there must be some business purpose for the move.

8. Different conditions for: New, existing, or reconstructed engines Area or Major Sources of Hazardous Pollutants Emergency, non-emergency, limited use, landfill or digester gas Engine size, hp and cylinder size Compression or spark Type of engine (2SLB, 4SLB, 2SRB, 4SRB) Date of construction (date of order of engine).

9. Limit CO to 23 ppmvd OR reduce CO by 70% Stack test to prove compliance every 3 years or 8760 operating hours, if not using If using catox, maintain p ± 2 H 2 O from stack test and maintain 450 °F T 1350 °F A Tier 3 certified engine or if above 560kW, Tier 2 can instead comply with the NSPS. <30 liters/cylinder must use ULSD