 New Regulatory Requirements for Owners of Stationary Internal Combustion Engines by Robert E. Dzymala, P.E. Air Resources Group, LLC If you have stationary internal combustion engines at your facility, then the information that follows may be very important to you. Stationary internal combustion (IC) engines are used to drive emergency generators, electric generators, compressors, pumps and many other devices. Typically they are fueled by diesel fuel, gasoline, and/or natural gas. The New York State Department of Environmental Conservation (DEC) has proposed changes to the existing NOx RACT regulation that will reduce emission limits for stationary internal combustion engines. The effective date of the proposed changes is April 1, 2005. If you don’t meet the thresholds in paragraph “a” or you meet the requirements in paragraph “b”, “c” or “d” that follow, the proposed changes will not apply to you and you needn’t continue reading further.
c) IC engines used to supply emergency power when the usual supply of power is unavailable, and operates for no more than 500 hours per year are exempt from the requirements of Part 227-2. d) You may commit to a permanent shutdown of the IC engines, through the modification, surrender, or planned expiration of your permit which must assure that the source is shutdown no later than July 1, 2004. Owners or operators must submit a permit application or a request for permit modification along with a compliance plan and an operating plan by July 1, 2004 or 12 months before the anticipated startup date for the engine. A compliance plan must describe the measures that will be implemented to achieve compliance with the proposed regulation and include a schedule showing the timing of implementation of the measures. Once approved, the compliance measures and the schedule for their implementation will be made part of the terms and conditions of the facility’s permit. An operating plan must include a summary of applicable standards and requirements and describe how your facility will comply with the proposed regulation. In addition descriptions of the following must be included:
Emission Limits Stationary internal combustion engines of 200 horsepower or larger in lower metropolitan NY and all of Long Island or larger than 400 horsepower in the remainder of the State that provide primary power or is used for peak shaving generation, must comply with the following RACT emission limits: 1. For rich burn internal combustion engines:
2. For lean burn internal combustion engines:
Testing, Monitoring and Reporting Requirements Owners and operators of IC engines that are not excluded from the requirements of this regulation must measure emissions generated by the operation of the engines. Owners have the option of installing a Continuous Emissions Monitoring System (CEMS) or by engaging the services of an emissions testing firm. The up front cost of a CEMS is expensive, and has considerable annual calibration and maintenance costs. In addition, use of a CEMS introduces additional complex regulatory compliance and reporting requirements. For these reasons, the more reasonable option of employing an emissions testing firm to verify NOx emissions should probably be selected. Planning for Compliance The first step that should be looked at to comply with this regulation is to determine whether or not a cap on NOx emissions is practical for your facility. Remember that Part 227-2 Reasonably Available Control Technology (RACT) for Oxides of Nitrogen (NOx) is applicable only to major stationary sources of NOx in New York State. The NOx thresholds that determine if your facility is a major stationary source are 25 tons downstate and 100 tons upstate for potential to emit. The DEC will allow you to cap NOx emissions at your facility at a level ten percent below the thresholds. Review your previously submitted emission statements and determine how close your actual reported emissions were to the allowed capping limit of 22.5 tons/year or 90 tons/year. If it is determined that the emissions were below the threshold and an appropriate margin of safety exists, giving up your Title V permit and applying for a state facility permit would be a likely choice for achieving compliance. If capping is not an alternative, owners should plan to seek a case-by-case RACT determination. By definition RACT must be economically and technically feasible. RACT is not economically feasible if the owner can demonstrate that the cost for reducing NOx exceeds $3500 to $4000 per ton/year. These costs include all up front costs plus annual operating and maintenance costs. Sources for which the owner or operator can demonstrate RACT emission limits are not economically or technically feasible can request the Department to set a higher source specific emission limit. Economic or technical feasibility must include the evaluation of fuel switching, selective catalytic reduction or system averaging as compliance options. Since the compliance plan is required to be submitted as part of a permit application by July 1, 2004 and the plan needs to describe the measures that will be implemented to achieve compliance as well as include a schedule showing the timing of implementation of the measures, you should not delay in preparing to comply with the proposed requirements. Remember compliance must be assured by April 1, 2005.
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