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EPA Targets New Requirements for Stationary Diesel Engines at Construction Sites

The U.S. Environmental Protection Agency (EPA) recently launched a compliance assistance website to help owners and operators of stationary Reciprocating Internal Combustion Engines (RICE) meet new national emission standards and operating limits by the May 2013 compliance deadline.  Be aware that an “Initial Notification” requirement is currently in effect for certain engine horsepower ranges - Sample Initial Notification- Compression Ignition.    National Emission Standards for Hazardous Air Pollutants or NESHAP for stationary RICE (see 40 CFR Part 63 Subpart ZZZZ) vary depending on criteria such as the engine age, size (HP), fuel type, application (non-emergency) and the source type (major/area).  Related requirements are on the books for new and existing stationary compression ignition (CI or diesel) and spark ignited (SI or gas) RICE at areas sources, as well as for both CI and SI RICE at major sources of HAP.  This article is focused on requirements for existing stationary CI or diesel RICE at area sources[1] because that combination is used at construction sites, quarries and asphalt/concrete plants.  Reciprocating Internal Combustion Engines (RICE) generate electricity and power pumps and compressors used in rock crushers, welders, and generators, for example. If you own or operate a stationary engine at your jobsite or facility (or a portable one that remains at a fixed location for more than 12 consecutive months) that was put into service before June 2006 (and not reconstructed[2] after that date) you are most likely subject to the NESHAP for RICE.  Most notably, the rules require owners and operators of stationary engines to further control emissions of certain hazardous air pollutants (HAP).[3] The RICE rule requires the following items for compliance (for an in-depth look at the requirements click here):
  1. Initial Notification – An Initial Notification to U.S. EPA is required immediately for non‐emergency engines greater than 300 HP at area sources subject to numerical emission standards - Sample Initial Notification- Compression Ignition.
  2. Numeric Emission Control Limits – For non-emergency engines >300 HP, installation of emissions control systems capable of reducing carbon monoxide (CO) emissions by 70% (or meet a CO ppmvd @15% O2 limit).  The majority of industry will rely on Diesel Oxidation Catalysts (DOC) to control CO emissions.  Certain engines are also subject to management practice requirements, operating limits, idling limits, and fuel requirements.  Compliance with the emission limitations for existing CI RICE is required by May 3, 2013.
  3. Compliance Testing – Performance testing to demonstrate compliance must be conducted within 6 months of installation and then again every three years or 8,760 hours of operations, whichever occurs first.  The RICE rule requires all notifications to be submitted to EPA at least 60 days after completing a performance testing.
  4. Recordkeeping – Keep records of pressure drop across the DOC and continuous records of exhaust temperature at the inlet of catalyst to demonstrate compliance.  Keep records of the results of any performance testing conducted. Keep record of maintenance of all engines.
  5. Reporting – A Notification of Compliance Status must be sent within 60 days following completion of the initial performance test, or 30 days after completion of performance evaluation of a continuous emission monitoring system (CEMS). Semiannual or annual compliance reports are required after the compliance date for the engine, depending on the engine size.
The agency had agreed to issue the standards as part of a settlement with the Sierra Club (Sierra Club v. Johnson, D.D.C., No. 01-1537, 3/31/06; 71 DEN A-2, 4/13/06). The national air emission standards for RICE DO NOT apply to mobile or non-road engines.[4]  Existing emergency generator set engines[5]located at residential, commercial or institutional area source facilities also are exempt from the federal rules. Additional Information EPA Region 1 recently launched a webpage that explains what RICE are, why they are regulated, the different categories of RICE, and the applicability of the RICE rule.  See http://www.epa.gov/region1/rice/. The complete rule and related materials – including minor amendments – are online at http://www.epa.gov/ttn/atw/rice/ricepg.html. To view U.S. EPA's website and applicability flowchart on the Subpart ZZZZ regulation and requirements click here. An example Initial Notification Form is available at http://www.epa.gov/ttn/atw/rice/rice_initial_notify.doc. For more information, contact Leah Pilconis at pilconisl@agc.org.
[1]Area Source refers to a small facility that emits less toxic emissions than a major source of HAP.  Major source of HAP is defined as a site with the potential to emit a single Hazardous Air Pollutant (HAP) at the rate of 10 tons/yr or a combination of HAPs at a rate of 25 tons/yr.  Construction sites, quarries and asphalt/concrete plants typically do not meet the definition for “major sources.”
[2] Reconstruction Existing engines that are rebuilt with the cost of the project exceeding 50% of the cost of installing an entirely new engine are considered “reconstructed”. EPA determines whether or not engines meet the definition of “reconstruction” on a case-by-case basis.
[3] EPA air quality requirements for stationary engines differ according to whether the engine is a compression ignition or a spark ignition engine. "Spark ignition" engines are further subdivided by power cycle - -i.e., two vs. four stroke, and whether the engine is "rich burn" (burning with a higher amount of air as compared to fuel) or "lean burn" (less air compared to fuel). [4]Non-road engines (per 40 CFR 1068.30) are:
  • Self-propelled (e.g., bulldozer)
  • Intended to be propelled while operating (lawnmower)
  • Portable – designed to be carried or moved from location to location (e.g., wheels, trailers)
  • Does not remain at a location for more than 12 consecutive months or for the full annual operating period at seasonal source (criteria only applies for the portable engines, not to the self-propelled or intended to be propelled while operating engines).
[5] Engine must meet Subpart ZZZZ definition of emergency engine:
  • Operation is limited to emergency situations and required testing and maintenance
  • Examples: emergency power generation during outage, fire/flood water pump
  • Does NOT include peak shaving units
  • May operate up to 15 hrs/yr in an emergency demand response program.