ZZZZ Compliance Testing and Portable Analyzers

Reciprocating Internal Combustion EngineSeveral million stationary reciprocating engines are in use throughout the United States. These engines, in general industry use, provide shaft power to drive process equipment, compressors, pumps, standby generator sets and other machinery. The uses are similar in agriculture, with many engines serving the purpose of driving irrigation pumps. Reciprocating engines also find wide application in municipal water supply, wastewater treatment, and in commercial and institutional emergency power and load-managing stations.

Many of these engines are subject to the RICE NESHAP, promulgated  by the EPA under 40 CFR 63, Subpart ZZZZ. Under Subpart ZZZZ, an owner/operator must demonstrate compliance by stack testing at the outlet exhaust to demonstrate the concentration of Carbon Monoxide (CO) in the stack exhaust of < 23 ppmvd at 15% O2.

This testing is typically conducted using continuous emissions monitors (CEMS), under EPA Test Methods 3a and 10, which provide the most accurate data possible on gaseous emissions. This approach is the gold standard for Subpart ZZZZ compliance testing and, as such, it is the methodology ESS uses.

An alternative approach to 3a and 10 is using ASTM D6522-00.  Rather than using CEMS, ASTM D6522-00 utilizes portable monitors, such as Testo 320s or 350s, for the reading of gaseous emissions.  While this method is EPA-approved for the conduct of ZZZZ testing for all engine ratings, it has been our experience that it simply does not provide the high-level accuracy we demand of our equipment.

However, with any methodology and any test series, an experienced partner is the most crucial component to conducting a successful test, properly compiling and submitting the data, and working with state and federal requirements.

Since 1979, ESS has had the personnel and equipment to help your facility demonstrate compliance with any state and federal air-quality and emission requirement. If a stack test is required for your facility, give ESS a call today at (910) 799-1055.

Learn more:
Your One Stop Shop for RICE NESHAP ZZZZ Compliance
A Guide To Subpart ZZZZ and JJJJ RICE Rules
New RICE Rules for MACT Standards and Compliance

Subpart IIII

In a previous blog entry regarding the ZZZZ and JJJJ RICE Rules , we discussed the National Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustions Engines (RICE NESHAP), and the New Source Performance Standards (NSPS) for Spark Ignition RICE Units, more commonly referred to as Subparts ZZZZ and JJJJ, respectively. There is another related rule that bears consideration, and that is Subpart IIII, the NSPS for Compression Ignition Internal Combustion Units (CI ICE).

There are two basic types of Stationary Reciprocating engines: spark ignition and compression ignition. Spark ignition engines use a spark, across a spark plug, to ignite a compressed fuel-air mixture. Typically, fuels for these engines are gasoline and natural gas. Compression ignition engines compress air to a high pressure, heating the air to the ignition temperature of the fuel, which is then injected. The high compression ratio used for compression ignition engines results in a higher efficiency than is possible with spark ignition engines. Diesel fuel oil is normally used in compression ignition engines, although there are dual-fueled varieties, where natural gas is compressed with the combustion air, and diesel oil is injected at the top of the compression stroke to initiate combustion.

The requirements of the Subpart IIII standards, particularly as they are related to performance testing, are dependent on the size of the engine, the manufacture date, the cylinder displacement, and whether it is used for emergency or non-emergency purposes. The EPA defines an emergency engine as one that is used for the purpose of maintenance checks and readiness testing, and is operated less than 100 hours per year. The owner of the emergency engine can NOT connect the engine to the grid under financial incentive and maintain the unit status as an emergency engine. Therefore, a peak shaving engine will not be classified as an emergency unit under the definitions of the Subparts.

For engines that are required to comply with Subpart IIII, including those engines located at Area Sources and engines less than or equal to 500hp located at Major Sources, there are no further requirements under the RICE NESHAP (Subpart ZZZZ). A Major Source is one that has the potential to emit 10 tons per year of any individual Hazardous Air Pollutant (HAP), or 25 tons per year of all HAPs. An Area Source is any source that is not considered a Major Source under this definition.

Regarding stack testing, an owner or operator of a CI ICE non-emergency unit built after 2007 with a displacement of >30L must demonstrate compliance by a performance test (stack test) for emissions of Particulate Matter (PM) and Oxides of Nitrogen (NOx). There are two methods for demonstrating compliance with either pollutant. The first is to show a percent reduction in emissions, and requires sampling for that pollutant at both the inlet and outlet to the control device for the source. Per IIII requirements, NOx must be reduced by 90% and PM by 60%. The second option is to limit the mass emission rate in the exhaust and only requires sampling at the outlet of the unit. The emission limit for NOx is 1.6 g/KW-hr (1.2 g/HP-hr). The emission limit for PM is 0.15g/KW-hr (0.11 g/HP-hr). In addition to the initial compliance performance test, owners of such engines must then perform annual performance tests to prove continued compliance with the standards.

The NESHAP and NSPS rulings can be an impenetrable maze without expert assistance, and the performance testing requirements can have a substantial impact on a facility’s operating budget. It is important to have a partner that is reliable and knowledgeable when approaching the many new emissions requirements being promulgated by the EPA and state governments. For assistance with your compliance needs, and performance testing requirements, ESS is available to help. If you believe you will or may have compliance issues under Subpart IIII, ZZZZ, or JJJJ, give us a call or an email today: 910-799-1055

Your One Stop Shop for RICE NESHAP ZZZZ Compliance

Environmental Source Samplers, Inc. (ESS) is pleased to announce a partnership with PowerSecure International, Inc. (PowerSecure) and Governor Control Systems, Inc. (GCS) to provide a one-stop-shop for total compliance with the EPA mandated emission standards for Reciprocating Internal Combustion Engine (RICE) units. This ruling, which was finalized in May 2010, is part of the larger Maximum Achievable Control Technology (MACT) standards promulgated by the EPA.

GCS is a provider of control equipment for the affected units, such as DCL’s Diesel Oxidation Catalysts (DOC), Silencers, Diesel Particulate Filters. GCS has also designed and developed the required Continuous Parameter Monitoring Systems (CPMS) Kit necessary to refit existing engines to meet emission requirements. PowerSecure provides products and services in the areas of Energy Efficiency, Interactive Distributed Generation, and Utility Infrastructure. ESS is an air quality consulting firm specializing in project management, emissions sampling and testing for a wide base of industrial, government and municipal clients.

ESS, PowerSecure and GCS have an established history of working together to meet a facility’s compliance requirements. Over the last year our three organizations have worked together on over 100 projects for RICE units demonstrating Subpart ZZZZ compliance. Our project management team provides initial consultation and emission measurements; engineering and design work; an accredited and certified emissions test program; and, guaranteed RICE NESHAP compliance.

Several million stationary reciprocating engines are in use throughout the United States. These engines, in general industry use, provide shaft power to drive process equipment, compressors, pumps, standby generator sets and other machinery. The uses are similar in agriculture, with many engines serving the purpose of driving irrigation pumps. Reciprocating engines also find wide application in municipal water supply, wastewater treatment, and in commercial and institutional emergency power and load-managing stations.

The Subpart ZZZZ RICE rule (see: A Guide to the ZZZZ and JJJJ RICE Rules) includes requirements to regulate emissions from new and reconstructed RICE units located at major sources and area sources of Hazardous Air Pollutants (HAP). A HAP major source is a facility with a potential to emit 10 tons per year of a single HAP, or 25 tons per year of a combination of HAPs. An area source is any source that is not a HAP major source. All RICE units >100 hp (at area sources) and >500 hp (at major sources) have Carbon Monoxide emission testing requirements.

If you have any questions concerning your operations and applicability under these rulings, don’t hesitate to contact our office today. Compliance with the rule must be achieved by May 3, 2013!

Environmental Source Samplers – Brian Mellor (910) 799-1055, sales@essknowsair.com

A Guide To Subpart ZZZZ and JJJJ RICE Rules

United States Environmental Protection AgencyRICE NESHAP – Subparts ZZZZ and JJJJ

Several million stationary reciprocating engines are in use throughout the United States. These engines, in general industry use, provide shaft power to drive process equipment, compressors, pumps, standby generator sets and other machinery. The uses are similar in agriculture, with many engines serving the purpose of driving irrigation pumps. Reciprocating engines also find wide application in municipal water supply, wastewater treatment, and in commercial and institutional emergency power and load-managing stations.

These engines are subject to a number of emissions parameters. Newly constructed engines, in particular, must maintain compliance with two EPA rulings promulgated in the First Quarter of 2008. These are the RICE NESHAP, 40 CFR 63, Subpart ZZZZ, and the New Standards of Performance For Stationary Spark Ignition Internal Combustion Engines (SI ICE NSPS), 40 CFR 63, Subpart JJJJ.

Description of Affected Units

There are two basic types of Stationary Reciprocating engines – spark ignition and compression ignition. Spark ignition engines use a spark, across a spark plug, to ignite a compressed fuel-air mixture. Typically, fuels for these engines are gasoline and natural gas. Compression ignition engines compress air to a high pressure, heating the air to the ignition temperature of the fuel, which is then injected. The high compression ratio used for compression ignition engines results in a higher efficiency than is possible with spark ignition engines. Diesel fuel oil is normally used in compression ignition engines, although there are dual-fueled varieties, where natural gas is compressed with the combustion air, and diesel oil is injected at the top of the compression stroke to initiate combustion.

Summary of Rules and Regulated Pollutants

The JJJJ rule became effective on March 18, 2008, and applies to newly-constructed, modified, or reconstructed Spark units, regardless of size and the fuel that is combusted. This rule does NOT apply to combustion turbines. The emissions are required to be controlled to levels achievable by Best Demonstrated Technology (BDT). The regulated pollutants are Oxides of Nitrogen (NOx), Carbon Monoxide (CO), and Volatile Organic Compounds (VOC). There is a sulfur limit, as well, on the gasoline fired.

The ZZZZ rule also became effective on March 18, 2008, and includes requirements to regulate emissions from new and reconstructed units that are less than or equal to 500 hp, and located at major sources of Hazardous Air Pollutants (HAP), as well as all new and reconstructed units at area sources. A HAP major source is a facility with a potential to emit 10 tons per year of a single HAP, or 25 tons per year of a combination of HAPs. An area source is any source that is not a HAP major source. Typically, the major regulated pollutant is Carbon Monoxide. This ruling was updated on February 25, 2009.

Sources that meet compliance with the emission limits in JJJJ also meet compliance with ZZZZ.

Meeting and Demonstrating Compliance

Newly-constructed, modified, or reconstructed units have 180 days after achieving maximum operating levels to demonstrate compliance with the emission limits in the rules. This can be accomplished in one of two ways. The first is a certificate of compliance from the manufacturer of the unit. For those who do not have the initial certification, compliance must be demonstrated by developing a maintenance plan for the unit, and conducting a performance test for the emission of pollutants from the exhaust of the unit, also known as a stack test.

There are various compliance dates and specific requirements depending on the unit in question, so if you have questions about your applicability and compliance requirements, you can find help using the online tools below from EPA.gov:

RICE Rule Quiz for Determining Requirements Under 40 CFR Section 63, Subpart ZZZZ