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

Brian Mellor About Brian Mellor

Brian Mellor works with Environmental Source Samplers, Inc. (ESS), an environmental consulting firm specializing in stack testing, CEMS Testing, and EPA air emissions compliance.

ESS has conducted international stack testing projects at Johnson Atoll, in the Philippines, the Dominican Republic, Hong Kong, and various parts of Europe. If you need a team that will do your international job with efficiency and effectiveness, call ESS at (910) 799-1055 or visit www.ESSKnowsAir.com.