1. 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
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2. 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
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3. General Overview of Federal RICE Rules
Mustang Watchdog
2/6/2013
General Overview of Federal RICE Rules
NSPS IIII
NSPS JJJJ
NESHAP ZZZZ
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4. 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.

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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

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

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

15. 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

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

17. 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
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18. Mustang Watchdog
8/29/2012
Existing Area Source Engines, excerpted from
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19. 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
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20. 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.
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21. 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
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22. 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.
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23. 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
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24. 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

25. 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

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

27. NESHAP ZZZZ Compliance Examples Mustang Watchdog 2/6/2013
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28. 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

29. 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

30. 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”

31. Remote / Non Remote Determination Example
Mustang Watchdog
8/29/2012
Remote / Non Remote Determination Example
Insert example here.
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32. RICE Rules – Lessons Learned
Mustang Watchdog
2/6/2013
RICE Rules – Lessons Learned
Confidential Business Information

33. 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
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34. 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
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35. Questions Contact me: Kristine Baranski kdb@cardinalengineers.com
Mustang Watchdog
Questions
8/29/2012
Contact me:
Kristine Baranski
(405)
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36. Resources http://www.epa.gov/region1/rice/
Mustang Watchdog
Resources
8/29/2012
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)
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