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Connecticut Department of Connecticut Department of Energy and Environmental Protection Th N The New Maze of Air Regulations M f Ai R l ti for Boilers and Engines: A Map g p for Small Businesses June 19, 2013 Keith M. Hill, CT DEEP CBIAs


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Connecticut Department of Connecticut Department of Energy and Environmental Protection

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Th N M f Ai R l ti The New Maze of Air Regulations for Boilers and Engines: A Map g p for Small Businesses

June 19, 2013 Keith M. Hill, CT DEEP CBIA’s Annual Environmental & Energy Conference

Connecticut Department of Energy and Environmental Protection

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Presentation Overview

  • Overview of EPA’s Area Source Rule for Boilers

– National Emission Standard for Hazardous Air Pollutants (NESHAP) for

Area Sources: Industrial Commercial and Institutional Boilers 40 CFR Area Sources: Industrial, Commercial, and Institutional Boilers, 40 CFR Part 63 Subpart JJJJJJ (6J)

  • Overview of EPA’s Regulations for Stationary Engines

Overview of EPA s Regulations for Stationary Engines

– National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating Internal Combustion Engines (RICE), 40 CFR part

63 subpart ZZZZ (Area Sources) 63 subpart ZZZZ (Area Sources)

– New Source Performance Standards (NSPS) for Stationary Compression Ignition (CI) Internal Combustion Engines (ICE), 40 CFR part 60 subpart IIII S f S d d f S i S k i i (S ) C – New Source Performance Standards for Stationary Spark Ignition (SI) ICE,

40 CFR part 60 subpart JJJJ

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Area Source Boiler Rule 40 CFR Part 63 Subpart JJJJJJ (6J) 40 CFR Part 63 Subpart JJJJJJ (6J)

Connecticut Department of Energy and Environmental Protection

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Boiler Rules

  • National Emission Standard for Hazardous Air Pollutants (NESHAP) for

Area Sources: Industrial Commercial and Institutional Boilers 40 CFR Area Sources: Industrial, Commercial, and Institutional Boilers, 40 CFR Part 63 Subpart JJJJJJ (6J)

– Final Rule published March 21, 2011 Fi l R l d t bli h d F b 1 2013 – Final Rule amendments published February 1, 2013

  • NESHAP for Major Source Industrial, Commercial, Institutional Boilers

and Process Heaters, 40 CFR Part 63 Subpart DDDDD (5D)

– Final Rule published March 21, 2011 – Final Rule amendments published January 31, 2013

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 6

Of 1.5 million boilers in the U.S., less than 1% will need to meet numerical emission limits under the Boiler NESHAPs

<1% (about 2,300) would need to

meet numerical emission limits to minimize toxics Most of these are minimize toxics. Most of these are larger boilers located at industrial facilities.

13% (about 197,000) would

need to follow work practice standards such as annual tune

~197,000 covered by rules

~1.3 million boilers not covered by rules standards, such as annual tune ups, to minimize toxics.

86% are clean and not covered by 86% are clean and not covered by

these rules. Many of these boilers are at places like hospitals, schools and churches.

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 7

Connecticut Boilers

In 2011, there were ~40,000 non‐ residential boilers / hot water heaters registered at ~14,000 sources in CT.

Source: DCP, Bureau of Boilers

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Why is EPA regulating Boilers?

T d i i i d h h l h To reduce toxic emissions and protect human health

  • Burning biomass, coal, and oil results in emissions of mercury,

dioxin, furans, formaldehyde, lead, and hydrochloric acid.

  • Health effects are significant:

– Mercury can cause adverse effects on children’s developing brains, including effects on IQ, learning and memory. Air toxics can cause cancer and other serious health effects in adults – Air toxics can cause cancer and other serious health effects in adults and children. – Controlling air toxics will also reduce fine particle pollution and carbon monoxide.

  • Fine particles are linked to serious cardiovascular and

respiratory effects, even premature death.

  • Carbon monoxide reduces oxygen delivery to heart and

yg y brain, can cause angina and other problems for people with heart disease.

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Area Sources – What are they?

  • Small stationary sources of air toxics

A th t it h d i

  • Any source that emits some hazardous air

pollutant (HAP) but is not a major source of HAP HAP

  • “Has a potential to emit less than 10 tpy for a

Has a potential to emit less than 10 tpy for a single HAP or less than 25 tpy for combined HAP” HAP

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Are Source Boiler Rule: Applicability A li t f ilit hi h it h

  • Applies to an area source facility which emits or has

potential to emit less than 10 tons per year (tpy) of any single HAP and less than 25 tpy of any b f combination of HAP.

  • Expected to apply to about 183,000 boilers located

i il t i l f iliti ( h t l ffi primarily at commercial facilities (e.g., hotels, office buildings, restaurants) and institutional facilities (e.g., schools, universities, hospitals, prisons), as well as industrial facilities.

  • Rule applies to coal, biomass, and oil‐fired boilers.

Rule does NOT apply to boilers that are gas‐fired, as defined.

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Area Source Boiler Rule

  • Three subcategories based on design type:

– Coal-fired units

  • 3,700 units

2% of area source boilers – 2% of area source boilers – 85% less than 10 million Btu/hr – Biomass-fired units

  • 11,000 units

– 6% of area source boilers – 68% less than 10 million Btu/hr – Liquid fuel-fired units

  • 168,000 units

– 92% of area source boilers – 95% less than 10 million Btu/hr

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Area Source Subcategories

  • Oil subcategory

– Any boiler that burns any liquid fuel and is not in biomass or coal subcategories Gas‐fired boilers that burn liquid fuel during coal subcategories. Gas fired boilers that burn liquid fuel during periods of gas curtailment, gas supply interruption, startups, or periodic testing up to 48 hours per calendar year not included

C l b t

  • Coal subcategory

– Any boiler that burns any solid fossil fuel and no more than 15 percent biomass on an annual heat input basis

  • Biomass subcategory

– Any boiler that burns any biomass and is not in the coal b t subcategory

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Are any boilers not subject to Subpart 6J?

  • Hot water heaters with a capacity of no more than 120 gallons combusting
  • il, gas or biomass. Gas, oil, and biomass hot water boilers (e.g., not generating

steam) rated at less than 1.6 million Btu per hour are included in this definition and not covered by the rule and not covered by the rule

  • Gas-fired boilers that burn gaseous fuels not combined with any solid

fuels, burns liquid fuel only during periods of gas curtailment, gas supply interruptions, startups, or periodic testing on liquid fuel. Periodic testing of p , p , p g q g liquid fuel shall not exceed a combined total of 48 hours during any calendar year.

  • Residential boilers intended primarily for heat or power for a residential unit of

f f ili i l i id h h b d up to four families, or a single unit residence that has been converted or subdivided into apartments or condos

  • Temporary boilers used temporarily in place of another boiler while that

unit is being replaced or repaired generally over an operational period of unit is being replaced or repaired, generally over an operational period of less than 12 months, unless an extension approved

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Are any boilers not subject to Subpart 6J? (cont’d)

  • Electric boilers
  • Boilers regulated under another Part 63 rule
  • Boilers burning waste and covered under incinerator rules

g

– Any boiler specifically listed as an affected source in another standard(s) established under section 129 of the Clean Air Act. – A boiler required to have a permit under section 3005 of the Solid Waste Disposal Act or covered by subpart EEE of this part (e.g., hazardous waste boilers).

  • Research and development boilers
  • Process heaters
  • Boilers used as a control device to comply with another subpart of

part 60, 61, 63, or 65

– provided that at least 50 percent of the heat input to the boiler is provided by the gas stream that is regulated under another subpart.

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 15

Existing vs. New & Large vs. Small

Existing Large Boiler New Small Boiler New Large Boiler Existing Small Boiler

Commenced construction/ Commenced construction/ reconstruction or Commenced construction/ reconstruction or Commenced construction/ construction/ reconstruction on

  • r before

6/4/2010 and ≥10 MMBtu/hr switched from natural gas fuel to biomass or liquid fuel after switched from natural gas fuel to biomass or liquid fuel after construction/ reconstruction on

  • r before

6/4/2010 and ≥10 MMBtu/hr 6/4/2010 and <10 MMBtu/hr 6/4/2010 and ≥10 MMBtu/hr and <10 MMBtu/hr

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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1 An existing dual‐fuel fired boiler meeting the definition of gas‐fired boiler that meets the applicability requirements of subpart JJJJJJ after June 4,

2010 due to a fuel switch from gaseous fuel to solid fossil fuel, biomass, or liquid fuel is considered to be an existing source under this subpart as long as the boiler was designed to accommodate the alternate fuel.

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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2 A new or reconstructed dual-fuel gas-fired boiler that meets the applicability criteria of subpart JJJJJJ after June 4, 2010 due to a fuel switch from gaseous fuel to

solid fossil fuel, biomass, or liquid fuel is considered to be a new source.

3 New oil-fired boilers that combust only oil with no more than 0.50 weight % sulfur or a mixture of 0.50 weight % sulfur oil with other fuels not subject to a PM

emission limit under this subpart and that do not use a post-combustion technology (except a wet scrubber) to reduce PM or SO2 emissions are not subject to the PM emission limit.

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Tune‐up Frequency Requirements

  • Requiring tune‐ups every 5 years, instead of every 2 years, for:
  • Seasonal boilers, oil and biomass boilers which undergo a

shut down for at least 7 consecutive months each 12 shut down for at least 7 consecutive months each 12‐ month period due to seasonal conditions, except for period testing (not to exceed 15 days in the 7 month shutdown)

  • Limited‐use boilers with a federally enforceable annual

average capacity factor of no more than 10 percent average capacity factor of no more than 10 percent

  • Oil‐fired boilers with heat input capacity < 5 MMBtu/hr
  • Boilers with oxygen trim systems

yg y

  • Initial tune‐ups are not required for new boilers

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Fuel switch requirements for dual‐fuel fired boilers

  • Existing dual‐fuel fired boilers (i.e., commenced

construction or reconstruction on or before June 4, 2010) that fuel switch fuels from gas to coal, biomass or oil after June 4, 2010 remain existing sources as long as the boiler was designed to sources, as long as the boiler was designed to accommodate the alternate fuel

  • New dual‐fuel fired boilers that make such a fuel

switch would continue to be considered new sources switch would continue to be considered new sources

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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PM alternative for new oil‐fired boilers

New oil‐fired units may combust low sulfur oil* as an alternative method of meeting the particulate matter (PM) emission standard (provided the boiler does not use a post‐combustion control technology (except a wet scrubber) to reduce PM or sulfur (except a wet scrubber) to reduce PM or sulfur dioxide emissions).

*< 5 i ht t lf t t i t *< .5 weight percent sulfur content requirements

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Area Source: Performance Testing Requirements

  • Boilers 10 million Btu/hour or greater with emission limits
  • Boilers 10 million Btu/hour or greater with emission limits

– Initial and triennial stack testing requirements for PM,

mercury CO (as applicable) mercury, CO (as applicable) – Fuel sampling analyses requirements for units subject to a mercury emission limit, except boilers subject to a mercury emission limit, except boilers burning a single fuel

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Performance Testing (continued)

– Reducing fuel sampling and performance testing requirements under certain circumstances

C l b il d t ti i iti l li ith th H » Coal boilers demonstrating initial compliance with the Hg emission limit through fuel sampling: if Hg constituents in the fuel or fuel mixture are measured to < half of the Hg emission limit, no need to conduct further fuel analysis sampling. If > half , y p g

  • f the Hg limit, quarterly sampling required.

» Boilers demonstrating initial compliance with the PM emission limit: if the performance test results show that the PM i i h lf f h PM i i emissions are < half of the PM emission

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Area Source: Monitoring Requirements

Boilers 10 million Btu/hour or greater with emission limits

  • Establish operating parameter limits during initial tests:

– For example, pressure drop, injection rate, power input, oxygen C ti l it t it

  • Continuously monitor process parameter or opacity
  • Boilers using a CO continuous emissions monitoring

system (CEMS) are exempt from initial CO stack testing y ( ) p g and oxygen concentration operating limit

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Energy Conservation Requirements

  • EPA has established pollution prevention (P2) as one of its highest
  • priorities. One opportunity for P2 lies in simply using energy efficient

technologies to minimize emissions.

  • Tune-ups

– Applicable to small coal-fired boilers < 10 MMBtu/hr, all biomass-fired boilers, and all oil-fired boilers. – Rationale – by improving combustion efficiency, fuel usage is reduced which results in decreased emissions.

  • Energy Assessment

– Applicable to existing large boilers > 10 MMBtu/hr, except limited use boilers (with a federally enforceable capacity factor of no more than 10 percent) Provides valuable information on improving energy efficiency – Provides valuable information on improving energy efficiency – Leads to reductions in emissions through process changes and other efficiency modifications but energy conservation measures identified are not required to be implemented

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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What are the Tune‐up Requirements?

Tune up Requirements Tune‐up Requirements:

  • (1) As applicable, inspect the burner, and clean or replace any components
  • f the burner as necessary*
  • (2) Inspect the flame pattern, as applicable, and adjust the burner as

necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer’s specifications, if available. p ,

  • (3) Inspect the system controlling the air‐to‐fuel ratio, as applicable, and

ensure that it is correctly calibrated and functioning properly.*

  • (4) Optimize total emissions of carbon monoxide. This optimization should

be consistent with the manufacturer’s specifications, if available, and with i id i any nitrogen oxide requirement

*you may delay the inspection until the next scheduled unit shutdown, not to exceed 36 months from previous inspection

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

not to exceed 36 months from previous inspection

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Tune‐up Requirements (cont’d)

  • (5) Measure the concentrations in the effluent stream of carbon

monoxide in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either d b i l i i h b i b f d f h

  • n a dry or wet basis, as long as it is the same basis before and after the

adjustments are made).

  • (6) Maintain onsite and submit if requested by the Administrator biennial
  • (6) Maintain onsite and submit, if requested by the Administrator, biennial
  • r five year report containing this information:

– (i) The concentrations of CO in the effluent stream in parts per million, by volume and oxygen in volume percent measured before and after by volume, and oxygen in volume percent, measured before and after the tune‐up of the boiler – (ii) A description of any tune‐up corrective actions taken (iii) Th d f f l d h 12 h i h – (iii) The type and amount of fuel used over the 12 months prior to the biennial tune‐up of the boiler, but only if the unit is physically and legally capable of burning more than one fuel Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Tune‐up Requirements (cont’d)

  • (7) If the unit is not operating on the required date

for a tune‐up, the tune‐up must be conducted within

  • ne 30 days of startup
  • ne 30 days of startup

NOTE: You must conduct the tune‐up while burning the fuel that provided the majority of the heat input to the boiler in the last 12 months before the tune‐ up (or both fuels if the boiler routinely burns two up (or both fuels if the boiler routinely burns two types of fuels at the same time)

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Energy Assessment Requirements

Th B i The Basics

  • Required for existing oil, biomass, and coal‐fired boilers with

design heat input capacity of 10 MMBtu/hr or greater except design heat input capacity of 10 MMBtu/hr or greater, except limited‐use boilers

  • One‐time assessment
  • Conducted by qualified energy assessor
  • Must be completed by March 21, 2014

Energy assessments completed after January 1 2008 that meet (or are – Energy assessments completed after January 1, 2008 that meet (or are amended to meet) requirements may be used in lieu of new assessment and the energy assessor qualifications waived

  • Source operating under an energy management system
  • Source operating under an energy management system

compatible with ISO 50001 satisfies the energy assessment requirement

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Energy Assessment Requirements

Energy assessments must evaluate the:

  • Boiler system

1 Boiler; and

  • 1. Boiler; and
  • 2. Associated components, such as, the feedwater systems, combustion air

systems, fuel systems (including burners), blowdown systems, combustion control systems, steam systems, and condensate return systems, directly connected to and serving the energy use systems

  • Energy use systems (meeting energy production threshold)
  • 1. Process heating; compressed air systems; machine drive (motors, pumps, fans);

g; p y ; ( , p p , ); process cooling; facility heating, ventilation, and air conditioning systems; hot heater systems; building envelope, and lighting; or

  • 2. Other systems that use steam, hot water, process heat, or electricity, provided by

h ff d b il the affected boiler

  • 3. Energy use systems are only those systems using energy clearly produced by

affected boilers.

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Energy Use Systems

  • Does not encompass energy use systems located off‐site
  • Does not encompass energy use systems using purchased

electricity from an off‐site source electricity from an off site source

  • Limited to energy use systems:

– Located on‐site; and – Associated with the affected boiler

  • Energy use systems may be segmented in the most logical

manner as applicable to specific facility being assessed manner as applicable to specific facility being assessed

– e.g., heating and cooling system, compressed air systems, production area, or a specific building

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Energy Assessment Requirements

  • Boiler Annual Heat Input

– Heat input capacity for each boiler calculated based on 8,760 hr/yr – A measurement of the facility’s total boiler capacity A measurement of the facility s total boiler capacity

  • Add together heat input capacity for each boiler subject to energy assessment

requirement

– Measured in Trillion Btu/yr (TBtu/yr)

  • Example:

A facility has two (2) existing oil‐fired boilers, each with a heat input capacity of 10 MMBtu/hr capacity of 10 MMBtu/hr. The facility’s Boiler Annual Heat Input would equal: 2 x (10,000,000 Btu/hr x 8,760 hr/yr) = 175,200,000,000 Btu/yr 0 1752 TBt /

  • r 0.1752 TBtu/yr

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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EA Requirements (cont’d)

  • Using our previous example:

Th t b il id t fi (5) di ti t t The two boilers provide energy to five (5) distinct energy use systems, each consuming 20% of the boilers’ output. With Boiler Annual Heat Input (0.1752 TBtu/yr) < 0.3 Tbtu/yr, only the boilers would need to be included in an energy assessment because none

  • f the energy use systems meet or exceed the 50% threshold.

If, the two boilers provide energy to one (1) energy use system, consuming 100% of the boilers’ output, the boilers and the energy use system would have to be evaluated in an energy assessment. Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Qualified Energy Assessors

S h h d t t d biliti t l t Someone who has demonstrated capabilities to evaluate energy savings opportunities for steam generation and major energy using systems, including, but not limited to:

i. Boiler combustion management. ii. Boiler thermal energy recovery, including

  • A. Conventional feed water economizer,

B C i l b i i h d

  • B. Conventional combustion air preheater, and

C. Condensing economizer. iii. Boiler blow down thermal energy recovery. iv Primary energy resource selection including iv. Primary energy resource selection, including

  • A. Fuel (primary energy source) switching, and
  • B. Applied steam energy versus direct‐fired energy versus electricity.

v Insulation issues v. Insulation issues. vi. Steam trap and steam leak management.

  • vii. Condensate recovery.
  • viii. Steam end‐use management

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

g

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Qualified Energy Assessors (cont’d)

Capabilities and knowledge includes, but is not limited to:

i. Background, experience, and recognized abilities to perform the assessment activities, data analysis, and report preparation. ii. Familiarity with operating and maintenance practices for steam or process heating systems. iii. Additional potential steam system improvement opportunities including improving steam turbine operations and reducing steam demand improving steam turbine operations and reducing steam demand. iv. Additional process heating system opportunities including effective utilization of waste heat and use of proper process heating methods. v. Boiler‐steam turbine cogeneration systems. g y vi. Industry specific steam end‐use systems.

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Qualified Energy Assessors (cont’d)

  • The qualified energy assessor may be a company employee or
  • utside specialist
  • The energy assessor qualification requirement is waived in

instances where past or amended energy assessments are used to meet the energy assessment requirement.

– So long as the past or amended energy assessment was completed on

  • r after January 1, 2008

y

  • Region 1 List of Qualified Energy Assessors

http //www epa gov/boilercompliance/whereyoulive html#region1 – http://www.epa.gov/boilercompliance/whereyoulive.html#region1

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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Energy Management Programs

  • Facilities operating under an energy management program

compatible with ISO 50001 satisfy energy assessment requirement requirement.

– Program must include affected boiler, associated components, and applicable energy use systems.

  • Must be operating under ISO 50001‐compatible program by

compliance date (March 21, 2014)

  • EPA considers these energy management programs to be

EPA considers these energy management programs to be equivalent to the one‐time energy assessment

– Programs requires facilities to operate under a set of practices and procedures designed to manage energy use on an ongoing basis. procedures designed to manage energy use on an ongoing basis.

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 37

Compliance Dates

  • Existing Sources (commenced construction on
  • r before June 4, 2010)

, )

– Complete initial tune‐up, compliance with emission limits and energy assessment by March gy y 21, 2014

  • New Sources (commenced construction after

( June 4, 2010)

– Must comply by May 20, 2011, or upon startup, ust co p y by ay 0, 0 , o upo sta tup, whichever is later

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 38

Notifications and Reports

  • Initial Notifications due by January 20, 2014 or within 120 days

after the source becomes subject to standard

  • Notification of Intent to Conduct Performance Test due at
  • Notification of Intent to Conduct Performance Test due at

least 60 days before the performance stack test

  • Compliance Certification Reports must be prepared, by March 1
  • f each year, and submitted to the delegated authority upon

request for the previous calendar year.

– must submit the report by March 15 if you had any deviations from p y y y applicable requirements. – For boilers subject only to a requirement to conduct a tune‐up and not subject to emission limits or operating limits, you are only required to j p g , y y q prepare a Biennial or Five Year Compliance Report Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 39

Notifications and Reports

  • Notification of Compliance Status (NOCS) due no later than

120 days after the applicable compliance date, unless you must conduct a performance stack test If you must conduct a conduct a performance stack test. If you must conduct a performance stack test, NOCS due within 60 days of completing the performance stack test.

– e.g., NOCS following the energy assessment and tune‐up is due no later than July 19, 2014 for existing sources – Rule requires electronic reporting of the NOCS reports using the Compliance and Emissions Data Reporting Interface (CEDRI) through EPA’s Central Data Exchange (www.epa.gov/cdx ), once EPA completes the reporting template. EPA is currently developing a reporting t l t f th NOCS t d i th f ll f 2013 EPA i ti template for the NOCS, expected in the fall of 2013. EPA is accepting paper NOCS only until the electronic reporting template is ready. Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 40

Notifications and Reports

Fuel switch notification – If you have switched fuels or made a physical change to the boiler fuels, or made a physical change to the boiler,

  • r have taken a permit limit which results in

you being in a different subcategory or you being in a different subcategory, or becoming subject to Subpart 6J, or no longer being subject to Subpart 6J due to a switch to being subject to Subpart 6J due to a switch to 100% natural gas, you must provide notice within 30 days of the fuel switch the physical within 30 days of the fuel switch, the physical change or the permit issuance

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 41

New Source Performance Standards (NSPS)

40 CFR Part 60 Subpart Dc, NSPS for Small Industrial‐Commercial‐Institutional (ICI) Steam Generating Units

– Applies to ICI boilers modified, constructed, or reconstructed after June 9, 1989 with a maximum design heat input capacity < 100 MMBtu/hr and > 10 MMBtu/hr 10 MMBtu/hr

  • For information on all NSPS Rules for boilers
  • For information on all NSPS Rules for boilers

– http://www.epa.gov/ttn/atw/nsps/boilernsps/boilernsps.html Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 42

For More Information

For Information on Area Source Boiler NESHAP Rule: http://www.epa.gov/boilercompliance/ For Information on Major and Area Source Boiler NESHAP Rules: http://www.epa.gov/ttn/atw/boiler/boilerpg.html For Information on Major Boiler MACT Technical Assistance from U.S. DOE’s Clean Energy Application Centers (CEAC) http://www1 eere energy gov/manufacturing/distributedenergy/boilermact html http://www1.eere.energy.gov/manufacturing/distributedenergy/boilermact.html U.S. DOE’s Northeast CEAC http://www.northeastcleanenergy.org/projectstartup/overview.php Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 43

Area Source Boiler Contact Information

  • For questions from sources in New England:

Susan Lancey, U.S. EPA New England Susan Lancey, U.S. EPA New England (617) 918‐1656

  • For questions about NESHAP energy

assessments in New England: Patrick Bird, U.S. EPA New England (617) 918‐1287 (617) 918‐1287

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 44

CT DEEP Contact Information

Compliance Analysis & Coordination Unit 860‐424‐3702 or 860 424 3702 or deep.cacu@ct.gov Engineering & Technical Services 860‐424‐4152 (Engineer of the Day)

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 45

EPA’s Air Q alit Re lations for EPA’s Air Quality Regulations for Stationary Engines y g

Wednesday, June 19, 2013 Keith M. Hill, CT DEEP CBIA’s Annual Environmental & Energy Conference

Connecticut Department of Energy and Environmental Protection

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SLIDE 46

EPA’s Stationary Engine Regulations

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 47

EPA’s Stationary Engine Regulations

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating Internal Combustion Engines (RICE) 40 CFR part 63 subpart ZZZZ Engines (RICE) 40 CFR part 63 subpart ZZZZ New Source Performance Standards (NSPS) for Stationary Compression Ignition (CI) Internal Combustion Engines (ICE) Compression Ignition (CI) Internal Combustion Engines (ICE), 40 CFR part 60 subpart IIII New Source Performance New Source Performance Standards (NSPS) for Stationary Spark Ignition (SI) ICE, 40 CFR part 60 subpart JJJJ

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

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SLIDE 48

Why are Engine Emissions a Concern?

  • Pollutants emitted from stationary engines are known or suspected of

causing cancer and other serious health effects:

f d d l d – Aggravation of respiratory and cardiovascular disease – Changes in lung function and increased respiratory symptoms – Premature deaths in people with heart or lung disease – Benzene and 1,3‐butadiene are known human carcinogens – Non‐cancer health effects from air toxics may include neurological, cardiovascular, liver, kidney effects, also effects on immune and reproductive systems

  • NOx and VOC can react in the presence of sunlight to form ozone

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-49
SLIDE 49

Stationary vs. Mobile

St ti t d i t hi l d t

  • Stationary means not used in a motor vehicle and not a

nonroad engine

– Nonroad engines are:

  • Self‐propelled (tractors, bulldozers)
  • Propelled while performing their function (lawnmowers)
  • Portable or transportable (has wheels, skids, carrying handles, dolly, trailer, or

l tf ) platform)

– Portable nonroad becomes stationary if it stays in one location for more than 12 months, or full annual operating period if seasonal source

VS. Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-50
SLIDE 50

Applicability

  • Applies to stationary CI and SI engines, both existing and new

RICE NESHAP

  • Applies to stationary CI engines:

Applies to stationary CI engines:

  • Ordered after July 11, 2005 and manufactured after April 1, 2006
  • Modified or reconstructed after July 11, 2005

CI ICE NSPS

  • Applies to stationary SI engines:
  • Ordered after June 12, 2006 and manufactured on/after
  • July 1, 2007 if ≥500 HP (except lean burn 500≤HP<1,350)
  • January 1 2008 if lean burn 500≤HP<1 350

SI ICE NSPS

  • January 1, 2008 if lean burn 500≤HP<1,350
  • July 1, 2008 if <500 HP
  • January 1, 2009 if emergency >25 HP
  • Modified or reconstructed after June 12, 2006

SI ICE NSPS

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-51
SLIDE 51

Stationary RICE NESHAP Stationary RICE NESHAP Background

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-52
SLIDE 52

RICE NESHAP Background

R l t HAP i i f t ti RICE t b th

  • Regulates HAP emissions from stationary RICE at both

major and area sources of HAP

Major: ≥10 tons/year single HAP or ≥25 tons/year total – Major: ≥10 tons/year single HAP or ≥25 tons/year total HAP – Area: not major Area: not major

  • All sizes of engines are covered

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-53
SLIDE 53

RICE NESHAP Background

  • ONLY ENGINES NOT SUBJECT: existing emergency engines located at
  • ONLY ENGINES NOT SUBJECT: existing emergency engines located at

residential, institutional, or commercial area sources used or obligated to be available ≤15 hr/yr for emergency demand response or voltage/frequency deviation, and not used for local reliability deviation, and not used for local reliability

– residential: includes homes, apartment buildings – commercial: includes office buildings, hotels, stores, telecommunications facilities, restaurants, financial institutions, doctor’s offices, sports and performing arts facilities i i i l i l d di l i h h i i i f – institutional: includes medical centers, nursing homes, research centers, institutions of higher education, correctional facilities, elementary and secondary schools, libraries, religions establishments, police stations, fire stations More info: http://www.epa.gov/ttn/atw/rice/guidance_emergency_engine_def.pdf

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-54
SLIDE 54

General Sub‐categorization Approach

Compression Ignition (CI) Non-Emergency Emergency St ti RICE Emergency Non Emergency 2-Stroke Stationary RICE Non-Emergency Lean Burn 4-Stroke Non-Emergency 4 Stroke Rich Spark Ignition (SI) 4-Stroke Rich Burn Landfill/Digester Gas Gas Emergency

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-55
SLIDE 55

Existing vs. New

Construction commenced before:

Existing New

December 19, 2002 >500 HP at major source

Existing New

June 12, 2006 ≤500 HP at major source,

Determining construction date: owner/operator has entered into a contractual

Existing New

June 12, 2006 and all HP at area source

g / p

  • bligation to undertake and complete, within a reasonable amount of time, a

continuous program for the on‐site installation of the engine

– Does not include moving an engine to a new location

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-56
SLIDE 56

Stationar RICE NESHAP Stationary RICE NESHAP Requirements for Emergency RICE Requirements for Emergency RICE

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-57
SLIDE 57

Emergency Engine Operational Limitations

  • Unlimited use for emergencies (e.g.,

power outage, fire, flood)

  • 100 hr/yr for:

– maintenance/testing – emergency demand response (EDR) emergency demand response (EDR) when Energy Emergency Alert Level 2 has been declared by Reliability Coordinator – voltage or frequency deviates by 5%

  • r more below standard

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-58
SLIDE 58

Emergency Engine Operational Limitations

  • 50 hr/yr of the 100 hr/yr allocation can be used for:

– non‐emergency situations if no financial arrangement – local reliability as part of a financial arrangement with another entity if: – local reliability as part of a financial arrangement with another entity if:

  • existing RICE at area source
  • engine is dispatched by local transmission/distribution system operator
  • dispatch intended to mitigate local transmission and/or distribution
  • dispatch intended to mitigate local transmission and/or distribution

limitations so as to avert potential voltage collapse or line overloads

  • dispatch follows reliability, emergency operation, or similar protocols that

follow specific NERC, regional, state, public utility commission, or local p , g , , p y , standards or guidelines

  • power provided only to facility or to support local distribution system
  • owner/operator identifies and records dispatch and standard that is being

followed – peak shaving until May 3, 2014 if existing RICE at area source

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-59
SLIDE 59

Major Sources Area Sources

Requirements for Emergency Engines

Existing RICE New RICE Existing RICE New RICE

≤500 HP:

  • Change oil/filter & inspect hoses/belts every

500 hours or annually; inspect air cleaner (CI) or spark plugs (SI) every 1 000 hours or annually ≤500 HP: Meet Stationary Engine NSPS CI: part 60 subpart IIII

  • Change oil/filter & inspect

hoses/ belts every 500 hours or annually; inspect air cleaner (CI)

  • r spark plugs (SI) every 1 000

Meet Stationary Engine NSPS CI: part 60 subpart spark plugs (SI) every 1,000 hours or annually

  • Non‐resettable hour meter
  • Records of hours of operation

CI: part 60 subpart IIII SI: part 60 subpart JJJJ

  • r spark plugs (SI) every 1,000

hours or annually

  • Non‐resettable hour meter
  • Records of hours of operation

CI: part 60 subpart IIII SI: part 60 subpart JJJJ

  • Records of maintenance
  • Operate/maintain per manufacturer’s

instructions or owner‐developed maintenance plan Mi i i /idl p

  • Records of maintenance
  • Operate/maintain per

manufacturer’s instructions or d l d i

  • Minimize startup/idle
  • Reporting and ULSD if used for EDR/voltage or

local reliability and >100 HP

  • wner‐developed maintenance

plan

  • Minimize startup/idle
  • Reporting and ULSD if used for

>500 HP: >500 HP: Reporting and ULSD if used for EDR/voltage or local reliability Minimize startup/idle, reporting and ULSD if used for EDR/voltage or local reliability

  • Minimize startup/idle, reporting

and ULSD if used for EDR/voltage

  • r local reliability
  • Initial notification if not used for

EDR/voltage or local reliability

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

EDR/voltage or local reliability

slide-60
SLIDE 60

Oil Analysis Programs

Parameter Condemning Limits Parameter Condemning Limits Total Base Number (CI RICE only) <30% of the TBN of the oil when new Total Acid Number (SI RICE only) Increases by more than 3.0 mg of potassium hydroxide per gram from TAN of the oil when new Vi it Ch d b th 20% f th i it f th il Viscosity Changed by more than 20% from the viscosity of the oil when new % Water Content by >0.5

  • Oil analysis must be performed at same frequency specified for oil

volume

changes

  • If condemned, change oil within 2 business days

– Owner/operator must keep records of the analysis

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

Owner/operator must keep records of the analysis

slide-61
SLIDE 61

Fuel Requirements for Emergency Engines

  • Requirements apply to emergency CI RICE >100 HP and displacement

30 li / li d h <30 liters/cylinder that are:

– Operated or contractually obligated to be available >15 hr/yr (up to 100 hr/yr) for emergency demand response or voltage/frequency deviation, or – Operated for local reliability (up to 50 hr/yr)

  • Beginning January 1 2015 use ultra low sulfur diesel fuel

Beginning January 1, 2015, use ultra low sulfur diesel fuel

– Existing inventory may be depleted Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-62
SLIDE 62

Reporting Requirements for Emergency Engines

  • Requirements apply to emergency RICE >100 HP that are:

Requirements apply to emergency RICE 100 HP that are:

– Operated or contractually obligated to be available >15 hr/yr (up to 100 hr/yr) for emergency demand response or voltage/frequency deviation, or – Operated for local reliability (up to 50 hr/yr)

  • Beginning with 2015 operation, report electronically by March 31 of following year:

– Facility name/address d l l /l – Engine rating, model year, lat/long – Date, start time, end time for operation for purposes above – Number of hours engine is contractually obligated for emergency demand response or voltage/frequency deviation g / q y – Entity that dispatched engine for local reliability and situation that necessitated dispatch – Deviations from fuel requirement

  • Submit report electronically through the Compliance and Emissions Data Reporting

Interface

– Accessed through EPA’s Central Data Exchange at http://www.epa.gov/cdx

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-63
SLIDE 63

Stationar RICE NESHAP Stationary RICE NESHAP Requirements for Non‐Emergency RICE q g y

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-64
SLIDE 64

Emission Standards: Existing Non‐Emergency RICE Located at Major Sources

HP

Engine Subcategory

Non‐emergency CI SI 2SLB SI 4SLB SI 4SRB SI LFG/DG <100 Change oil and filter and inspect air cleaner (CI) or spark plugs (SI) every 1,000 hours of

  • peration or annually; inspect hoses and belts every 500 hours of operation or annually

100‐300 230 ppm CO 225 ppm CO 47 ppm CO 10.3 ppm CH2O 177 ppm CO 300 500 49 CO 300‐500 49 ppm CO or 70% CO reduction >500 23 ppm CO or No standards No standards 350 ppb CH2O No standards 70% CO reduction

2

  • r

76% CH2O reduction

Note: Existing limited use engines >500 HP at major sources do not have to meet any emission standards. Existing black start engines ≤500 HP at major

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

sources must meet work practice standards.

slide-65
SLIDE 65

Emission Standards: Existing Non‐Emergency RICE Located at Area Sources

HP Engine Subcategory HP Engine Subcategory Non‐emergency

CI SI 2SLB SI 4S in remote areas SI 4S not in remote areas SI LFG/DG Black start ≤300 Change oil/filter & inspect air cleaner every 1,000 hours

  • r annually; inspect

hoses/belts every h Change oil/filter, inspect spark plugs, & inspect hoses/ belts every 4,320 h ll Change oil/ filter, inspect spark plugs, & inspect hoses/belts every 1,440 hours of Change oil/ filter, inspect spark plugs, & inspect hoses/belts every 1,440 hours of Change oil/ filter, inspect spark plugs, & inspect hoses/ belts every 1,440 h f Change oil/filter & inspect hoses/ belts every 500 hours or annually; inspect air cleaner ( ) k l 500 hours or annually hours or annually

  • peration or

annually

  • peration or

annually hours of

  • peration or

annually (CI) or spark plugs (SI) every 1,000 hours or annually 300‐500 49 ppm CO or 70% CO reduction >500 23 ppm CO or 70% CO reduction Change oil/ filter, inspect spark plugs, & inspect hoses/belts every 2,160 hours of If engine used >24 hrs/yr: 4SLB: Install

  • xidation catalyst

,

  • peration or

annually y 4SRB: Install NSCR

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-66
SLIDE 66

Emission Standards: New Non‐Emergency RICE

HP

Engine Subcategory

Non‐emergency

New RICE Located at Major Sources:

Non emergency CI SI 2SLB SI 4SLB SI 4SRB SI LFG/DG <250 Comply with CI NSPS Comply with SI NSPS Comply with SI NSPS Comply with SI NSPS Comply with SI NSPS NSPS NSPS NSPS NSPS NSPS 250‐500 14 ppm CH2O or 93% CO reduction >500 580 ppb CH2O 12 ppm CH2O or 350 ppb CH2O or No standards

  • r

70% CO reduction 58% CO reduction 76% CH2O reduction

Note: New limited use engines >500 HP at major sources do not have to meet any emission standards under the NESHAP Note: New limited use engines >500 HP at major sources do not have to meet any emission standards under the NESHAP.

New RICE Located at Area Sources: meet Stationary Engine NSPS

  • CI: part 60 subpart IIII
  • SI: part 60 subpart JJJJ

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

66

SI: part 60 subpart JJJJ

slide-67
SLIDE 67

Compliance Requirements: Non‐Emergency RICE

Engine Subcategory Compliance Requirements Engine Subcategory Compliance Requirements

Existing non‐emergency:

  • CI ≥100 HP at major source
  • CI >300 HP at area source
  • Initial emission performance test
  • Subsequent performance testing every 8,760 hours of
  • peration or 3 years for engines >500 HP (5 years if

l d )

  • SI 100‐500 HP at major source

limited use)

  • Operating limitations ‐ catalyst pressure drop and inlet

temperature for engines >500 HP

  • Notifications

l l ( l f l d )

  • Semiannual compliance reports (annual if limited use)

Existing CI >300 HP:

  • Ultra low sulfur diesel (ULSD)

k i i l i

  • Crankcase emission control requirements
  • Existing non‐emergency SI 4SLB/4SRB

>500 HP at area source used >24

  • Initial and annual catalyst activity checks
  • High temperature engine shutdown or continuously

hours/year and not in remote area monitor catalyst inlet temperature

  • Notifications
  • Semiannual compliance reports

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-68
SLIDE 68

Compliance Requirements: Non‐Emergency RICE

Engine Subcategory Compliance Requirements Existing black start:

  • Operate/maintain engine & control
  • <100 HP at major source
  • ≤500 HP at major source
  • All at area source

device per manufacturer’s instructions or

  • wner‐developed maintenance plan
  • May use oil analysis program instead of

prescribed oil change frequency Existing non‐emergency:

  • <100 HP at major source
  • CI ≤300 HP at area source

SI ≤500 HP t prescribed oil change frequency

  • Keep records of maintenance
  • Notifications not required
  • SI ≤500 HP at area source
  • SI 2SLB >500 HP at area source
  • SI LFG/DG >500 HP at area source
  • SI 4SLB/4SRB >500 HP at area source used

/ ≤24 hours/year or in remote area

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-69
SLIDE 69

Compliance Requirements: Non‐Emergency RICE

Engine Subcategory Compliance Requirements Existing non‐emergency:

  • SI 4SRB >500 HP at major source
  • Initial emission performance test
  • Subsequent performance testing semiannually

New non‐emergency:

  • SI 2SLB >500 HP at major source
  • SI 4SLB >250 HP at major source

(can reduce frequency to annual)*

  • Operating limitations ‐ catalyst pressure drop and

inlet temperature

  • Notifications

SI 4SLB >250 HP at major source

  • SI 4SRB >500 HP at major source
  • CI>500 HP at major source

Notifications

  • Semiannual compliance reports

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-70
SLIDE 70

Compliance Requirements: Non‐Emergency RICE

Engine Subcategory Compliance Requirements

  • New limited use >500 HP at
  • Initial notification

major source

  • New non‐emergency LFG/DG

>500 HP at major source

  • Initial notification
  • Monitor/record fuel usage daily

>500 HP at major source

  • Monitor/record fuel usage daily
  • Annual report of fuel usage

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-71
SLIDE 71

Key Dates

I i i l li bili ifi i f i bj 2010 d

  • Initial applicability notifications for engines subject to 2010 amendments

were due by:

– August 31, 2010 for existing CI RICE – February 16, 2011 for existing SI RICE

  • Compliance dates:

Compliance dates:

– June 15, 2007

  • Existing RICE >500 HP at major sources (except non‐emergency CI >500 HP at major

sources) sources)

– May 3, 2013

  • Existing CI RICE (except emergency CI >500 HP at major sources)

– October 19, 2013

  • Existing SI RICE ≤500 HP at major sources and all HP at area sources

– Upon startup for new engines

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

p p g

slide-72
SLIDE 72

Stationary CI ICE NSPS

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-73
SLIDE 73

Who is Subject to the CI NSPS

  • Manufacturers of 2007 model year or later stationary

CI engines <30 liters/cylinder displacement

– Model years differ for fire pump engines

  • Owners/operators of stationary CI engines

– constructed (ordered) after July 11, 2005 and manufactured after April 1, 2006 (July 1, 2006 for fire pump engines) pump engines) – modified/reconstructed after July 11, 2005

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-74
SLIDE 74

Emission Standards: Displacement <10 liters/cylinder

  • Pre‐2007 model year engines

– Meet emission standards equivalent to Tier 1 standards for nonroad CI engines

  • 2007 model year and later

2007 model year and later

– Meet emission standards equivalent to Tier standards for nonroad CI engines

  • Tier 2/3 in part 89 Tier 4 in part 1039
  • Tier 2/3 in part 89, Tier 4 in part 1039

– Emergency engines >50 HP only have to meet Tier 3 standards (or Tier 2 if no Tier 3)

  • Fire pump engines

– Same emission standards, delayed schedule Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-75
SLIDE 75

Emission Standards: Displacement ≥10 liters/cylinder

  • 10‐30 liters/cylinder

– Meet Tier standards for marine CI engines

  • Tier 2 in part 94, Tier 3/4 in part 1042
  • Emergency engines do not have to meet the most stringent (Tier

4) standards

  • ≥30 liters/cylinder

NO li it ( /kW h ) i l t t EPA t d d f l i – NOx limits (g/kW‐hr): equivalent to EPA standards for large marine engines – PM limit:

  • 60% reduction or 0.15 g/kW‐hr for non‐emergency
  • 0.40 g/kW‐hr for emergency

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-76
SLIDE 76

Fuel Requirements

Date Requirement October 1, 2007 Low sulfur diesel (LSD) October 1 2010 Ultra low sulfur diesel (ULSD) October 1, 2010 Engines <30 liters/cylinder displacement Ultra low sulfur diesel (ULSD)

  • Max sulfur content 15 ppm
  • Minimum cetane index of 40 or max aromatic

content of 35 volume % June 1, 2012 Engines ≥30 liters/cylinder 1,000 ppm sulfur diesel Engines ≥30 liters/cylinder displacement

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-77
SLIDE 77

Engine Manufacturer Compliance Requirements

  • Engine manufacturers must certify 2007 model year
  • Engine manufacturers must certify 2007 model year

and later engines with a displacement <30 liters/cylinder / y

– Certification = EPA Certificate of Conformity

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-78
SLIDE 78

Owner/Operator Compliance Requirements

  • 2007 model year and later with displacement <30 liters/cylinder*

– purchase certified engine – Install, configure, operate and maintain engine per manufacturer’s instructions or manufacturer‐approved procedures

  • Owner/operator performance testing not required

– If operate differently than manufacturer’s recommendations, must do performan e test to sho

  • mplian e

performance test to show compliance

  • Displacement ≥30 liters/cylinder

I iti l f t t – Initial performance test – Annual performance test for non‐emergency engine – Continuously monitor operating parameters

*For CI fire pump engine 2008 2011 model year and later (depending on engine size)

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

For CI fire pump engine, 2008‐2011 model year and later (depending on engine size)

slide-79
SLIDE 79

Monitoring/Recordkeeping/Reporting

Engine Type Requirement Emergency Engines

  • Non‐resettable hour meter and records of
  • peration if engine does not meet non‐emergency

engine standards Equipped with diesel particulate •Backpressure monitor and records of corrective filter (DPF) actions Non‐emergency >3,000 HP or with displacement >10

  • Submit initial notification
  • Keep records of notifications and engine

with displacement >10 liters/cylinder and

  • Keep records of notifications and engine

maintenance

  • If certified, keep records of documentation of

engine certification Pre‐2007 model year >175 HP that are not certified

  • If not certified, keep records of compliance

demonstrations

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-80
SLIDE 80

Stationary SI ICE NSPS

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-81
SLIDE 81

Who is Subject to the SI NSPS?

  • Manufacturers of stationary SI engines:

– ≤25 HP and manufactured on/after July 1, 2008 – >25 HP, gasoline or rich burn LPG, manufactured on/after July 1, 2008 (on/after January 1, 2009 if emergency engines) – Voluntarily certified engines manufactured on or after:

Date Engine Type July 1, 2007 >500 HP (except lean burn 500≤HP<1,350) January 1, 2008 lean burn 500≤HP<1,350 July 1, 2008 <500 HP January 1, 2009 emergency engines

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-82
SLIDE 82

Who is Subject to the SI NSPS? (cont’d)

Owners/operators of engines:

Constructed (ordered) after June 12, 2006 and Modified/reconstructed after Manufactured On/After Engine Type June 12, 2006 July 1, 2007 ≥500 HP (except lean burn 500≤HP<1,350) January 1, 2008 Lean burn 500≤HP<1,350 July 1, 2008 <500 HP January 1, 2009 Emergency >25 HP

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-83
SLIDE 83

Emission Standards (In General)

Engine Standards

≤25 HP (all engines) Part 90 or part 1054 standards for new nonroad SI engines Non‐emergency gasoline Part 1048 standards for new nonroad SI engines and rich burn LPG Non‐emergency natural gas and lean burn LPG Part 1048 standards for new nonroad SI engines (or other options) 25<HP<100 ≥100 HP and not gasoline

  • r rich burn LPG

Standards in Table 1 of subpart JJJJ, part 1048 standards for some engines

Owners/operators of gasoline engines must use gasoline that meets the sulfur limit in 40 CFR 80.195 – cap of 80 ppm

Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-84
SLIDE 84

Compliance Requirements for Owners/Operators

  • Certified engines

– Install, configure, operate and maintain engine according , g , p g g to manufacturer’s instructions – If you do not operate/maintain according to f ’ manufacturer’s instructions:

  • keep maintenance plan and maintenance records
  • operate consistent with good air pollution control practices
  • 100≤HP≤500 – initial performance test
  • >500 HP – initial performance test and subsequent every 8,760

hours or 3 years, whichever is first Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-85
SLIDE 85

Compliance Requirements for Owners/Operators

  • Non certified engines:
  • Non‐certified engines:

– Maintenance plan – Performance testing

  • 25<HP≤500

initial test

  • 25<HP≤500 – initial test
  • >500 HP ‐ initial test and subsequent every 8,760 hours or 3 years, whichever is first
  • Conduct within 10% of peak (or highest achievable) load

i i / dk i / i i l d

  • Monitoring/recordkeeping/reporting includes:

– Non‐resettable hour meter and records of operation for emergency engines – Documentation of certification – Records of engine maintenance – Initial notification for non‐certified engines >500 HP – Results of performance testing within 60 days of test Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-86
SLIDE 86

Implementation Assistance

  • RICE NESHAP/NSPS TTN websites

http // epa go /ttn/at /rice/ricepg html – http://www.epa.gov/ttn/atw/rice/ricepg.html – http://www.epa.gov/ttn/atw/nsps/cinsps/cinspspg.html – http://www.epa.gov/ttn/atw/nsps/sinsps/sinspspg.html

  • EPA Regional Office RICE websites

– Region 1: http://www.epa.gov/region1/rice – Region 10: http://yosemite.epa.gov/R10/airpage.nsf/Enforcement/rice_rules

  • Electronic CFR
  • Electronic CFR

– http://www.gpoaccess.gov/ecfr Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection

slide-87
SLIDE 87

Contact Information

Melanie King (rule writer) Energy Strategies Group Sector Policies and Programs Division Roy Crystal EPA Region 1 Phone: 617‐918‐1745 C t l @ g OAQPS, Office of Air and Radiation Phone: 919‐541‐2469 Crystal.roy@epa.gov Keith Hill king.melanie@epa.gov Susan Lancey Keith Hill CT DEEP Bureau of Air Management 860‐945‐9295 Susan Lancey EPA Region 1 Phone: 617‐918‐1656 L @ 860 945 9295 Keith.hill@ct.gov Lancey.susan@epa.gov Connecticut Department of Energy and Environmental Protection Connecticut Department of Energy and Environmental Protection