Clean Power Plan Repealed and Replaced

The Trump administration Wednesday finalized a rule to repeal and replace a capstone Obama-era carbon pollution regulation that they argue exceeded the Environmental Protection Agency’s (EPA) authority.

The new replacement rule to the Clean Power Plan (CPP), deemed the Affordable Clean Energy (ACE) rule, aims to give states more time and authority to decide how to implement the best new technology to ease net emissions from coal-fired plants.

“Under the CPP, the EPA Obama administration went beyond implementing best technology,” said a senior EPA official on a call with reporters Wednesday. “Under the CPP the Obama administration actually imposed emissions reductions on each and every state. We don’t believe that’s an EPA role or authority under the [Clean Air Act.]”

The result of the relaxed rule, the official said, could mean individual coal plants might increase their overall emissions. But, the official said, across the board the agency expects emissions to drop.

Read more coverage here.

NJDEP Adopts New Rules for CO2 Budget Trading Program

The New Jersey Department of Environmental Protection has adopted new rules at N.J.A.C. 7:27-22.28 and 7:27C and amendments to N.J.A.C. 7:27-22.1 and 22.16, and 7:27A-3.2, 3.5, and 3.10, which establish the New Jersey Carbon Dioxide (CO2) Budget Trading Program.  The CO2 Budget Trading Program is New Jersey’s commitment to the Regional Greenhouse Gas Initiative (RGGI), a regional, cooperative program to cap and reduce CO2 emissions from fossil fuel fired units producing 25 or more megawatts of power in the participating states to address the significant challenge of climate change.

The adoption was published in the New Jersey Register on June 17, 2019.  The operative date of the new rules and amendments is June 11, 2019.  A copy of the Department’s adoption is available on the Department’s website at: https://www.nj.gov/dep/rules/adoptions.html and https://www.state.nj.us/dep/aqes/rggi.html as well as LexisNexis free public access to the New Jersey Register,  https://urldefense.proofpoint.com/v2/url?u=http-3A__www.lexisnexis.com_njoal&d=DwIFAg&c=4BTEw-1msHjOY4ITcFLmDM6JB8x6ZgbU2J24IH0HZLU&r=G2jsVVV4jFHeLEjPL09sH5Z1gSxJt54Oz5U9BS0lEidsmUHsZycJoAKJm7vit93B&m=R2uM3LiVNV5tQdBwElNdK6utpm1rEP8k50B5knCMltw&s=qL-wKUpoWVcWce1hThWUs-GilTRiSEJ-SaSqzZsVj7w&e=

Please note that consistent with newly adopted N.J.A.C. 7:27C-3.3, CO2 budget sources must be added to an operating permit by completing an application for a new, renewed, or modified operating permit.  The Department has developed “NJ03-APPLICATION FOR ADDING A CO2 BUDGET SOURCE IN OPERATING PERMIT,” which should be submitted along with the completed application for a new, renewed, or modified operating permit.  The new form may be downloaded from the Department’s website at https://www.state.nj.us/dep/aqes/rggi-who-is-regulated.html

Further information and additional forms related to the CO2 budget trading program compliance certification and compliance plans are also available on the Department’s website at https://www.state.nj.us/dep/aqes/rggi-who-is-regulated.html

The Department has developed two new listservs related to RGGI’s implementation – one specific to the RGGI regulated entities and the other for those interested in the development of the RGGI strategic funding plan.  You can join one or both of those listservs by submitting your email where indicated on the RGGI website at https://www.state.nj.us/dep/aqes/rggi.html.

NESHAP for Area Source Boilers (40 CFR 63, Subpart JJJJJJ)

2017-04-20 NESHAP for Area Source Boilers (40 CFR, Subpart JJJJJJ)

The national emission standards for hazardous air pollutants (NESHAP) for area source boilers (40 CFR part 63, Subpart JJJJJJ) was published in the Federal Register on March 21, 2011 and EPA finalized changes to the rule in the Federal Register on February 1, 2013 and on September 14, 2016. The September 14, 2016, action announced EPA’s final decisions on five issues regarding the February 1, 2013, amendments for which reconsideration was granted.

ESS provides comprehensive emissions testing services to meet the federal and state requirements for industrial boilers, including Subpart JJJJJJ, Subpart DDDDD, Title V, and more.  See our list of capabilities for more information or call 910.799.1055 for more information.

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Submitting Protocols and Reports Via the Electronic Reporting Tool (ERT)

Successful emissions compliance testing projects include the submittal of a test plan or test protocol for approval prior to testing and the submittal of the final test report, at the conclusion of testing, to the regulatory agency responsible for approving the test. The regulatory agency can be the local, state, or federal government environmental department.

Stack Testing for Air Quality ControlIn the past — and still current in many cases — this submittal has been the delivery of hard copies of the report to the state or federal agency. Now the increasing trendis the submittal of digital test data over the internet, utilizing the Electronic Reporting Tool, or ERT.

The ERT is used to electronically create and submit stationary source sampling test plans to regulatory agencies and, after approval, to calculate and submit the test results as an electronic report to the regulatory agency. It is intended to replace the manual preparation and transcription of test plans and reports currently performed by stack testing contractors for emissions sources, as well as the manual quality assurance evaluations and documentation performed by state agencies.

It is the EPA’s hope that the ERT will improve the content and quality of source emissions test reports, reduce the workload associated with manual transcription of information and data contained in the report, reduce the resources required to store and access the reports, and reduce redundant efforts in using the data for multiple purposes.

It needs to be noted that at this time no state agencies have formally adopted this method of accepting test protocols and test reports, so for state air permit requirements, test plans and test reports are still submitted in hard copy. However, for tests that are determined by Federal requirements, such as the many MACT regulations, it is a technical requirement that test data must be submitted via the ERT. As the federal agencies continue to push towards ERT submittal, there may be a period of time where both digital and hard copy submittal are required, but it is expected that the ERT will eventually be the required method of protocol and test report.  A full list of the various EPA regulations that require ERT submittal is provided below.

It is highly recommended that your facility designates a person or contracted testing company to familiarize themselves with the ERT format, structure, and requirements, particularly if your facility is or will be affected by the Federal regulations. ESS personnel are trained to prepare protocols and test plans in the format required for submittal via the  ERT, as well as any required hard copies, in order to meet all regulations for compliance demonstration.

Currently, the EPA requires ERT reporting for compliance tests falling under the following rules:

Promulgated Regulations with Electronic Data Reporting Requirements*

Source Category Code of Federal Regulations Reference
40 CFR Part 60 40 CFR Part 63
Chromium Electroplating (Hard and Decorative) and Chromium Anodizing Tanks   Subpart N
Coal Preparation and Processing Plants Subpart Y
Commercial Industrial Solid Waste Incinerators Subpart CCCC and DDDD
Electric Utility Steam Generating Units Subpart Da Subpart UUUUU
Flexible Polyurethane Foam Production Subpart III
Gold Mines Subpart EEEEEEE
Industrial, Commercial, and Institutional Boilers Area Source Subpart JJJJJJ
Industrial, Commercial, and Institutional Boilers Major Source Subpart DDDDD
Industrial-Commercial-Institutional Steam Generating Units Subpart Db Subpart UUUUU
Industrial-Commercial-Institutional Steam Generating Units, Small Subpart Dc Subpart UUUUU
Marine Tank Vessel Loading Operations Subpart Y
Nitric Acid Plants Subpart Ga
Oil and Natural Gas Production Subpart OOOO Subpart HH and HHH
Pesticide and Active Ingredient Production Subpart MMM
Pharmaceuticals Production Subpart GGG
Polyether Polyols Production Subpart PPP
Polymers and Resins Group I Subpart U
Polymers and Resins Group IV Subpart JJJ
Polyvinyl Chloride and Copolymers Production Subpart HHHHHHH
Portland Cement Subpart F Subpart LLL
Printing and Publishing Industry Subpart KK
Pulp and Paper Industry Subpart S
RICE Subpart IIII and JJJJ Subpart ZZZZ
Secondary Lead Smelting Subpart X
Sewage Sludge Incinerators Subpart LLLL and MMMM
Steel Pickling– HCl Process Facilities and Hydrochloric Acid Regeneration Plants Subpart CCC
*EPA requirements subject to change.  See http://www.epa.gov/ttnchie1/ert/ert_rules.html for the most up-to-date list

 

Compliance Stack Testing and Audit Sample Requirements

Audit Samples for Compliance TestingOn June 16th of 2013, the EPA moved forward with one phase of their Stationary Source Audit Sample Program. The program will require audit samples to be required for specific source tests, if those tests are to be used for the demonstration of compliance with emission limits or federal standards.

An audit sample, the composition of which is unknown to the Stationary Source Tester and Laboratory, is used during a particular test event to evaluate whether the Stationary Source Tester and/or Analytical Laboratory can produce measurement results within specified acceptance criteria. Audit samples are not analyzed on a regular schedule; rather, they are analyzed only during the particular event (e.g., a compliance test) that is being audited. Audit samples are analyzed, or collected and analyzed, as part of the batch of field test samples using the same personnel, procedures, and materials.

At this time, audits are only available for particular pollutants by EPA Methods. The list of current available/required audits is provided in the table below. Other methods that will have audits, but are still unavailable and thus not required, are:

  • Dioxins/Furans by Method 23
  • Non Methane Organic Compounds by Method 25
  • Methylene Chloride by Method 315

The EPA restructured program requires that two accredited providers be available, and audit samples must be available and listed on the provider website for 60 days before audits are required to be utilized with compliance tests.

Table – Currently Required Audit Samples for Compliance Testing

Analyte

EPA Method

NELAC Analyte Code

Inorganics in Impinger Solution

Sulfur Dioxide (SO2)

Methods 6 and 8

4010

Sulfuric Acid Mist (H2SO4)

Method 8

4020

Oxides of Nitrogen (NOx)

Method 7

3885

Fluoride (F)

Methods 13a, 13b

1730

Hydrogen Chloride (HCl)

Methods 26, 26a

1770

Hydrogen Fluoride (HF)

Methods 26, 26a

1775

Metals on Glass/Quartz Fiber Filters and in Impinger Solution

Antimony (Sb)

EPA Method 29

1005

Arsenic (As)

EPA Method 29

1010

Barium (Ba)

EPA Method 29

1015

Beryllium (Be)

EPA Method 29

1020

Cadmium (Cd)

EPA Method 29

1030

Chromium (Cr)

EPA Method 29

1040

Cobalt (Co)

EPA Method 29

1050

Copper (Cu)

EPA Method 29

1055

Lead (Pb)

EPA Method 29

1075

Manganese (Mn)

EPA Method 29

1090

Nickel (Ni)

EPA Method 29

1105

Selenium (Se)

EPA Method 29

1140

Silver (Ag)

EPA Method 29

1150

Thallium (Tl)

EPA Method 29

1165

Zinc (Zn)

EPA Method 29

1190

Mercury (Hg)

EPA Method 29

1095

Lead (Alt. Method)

EPA Method 12

1075

 

Note that in the case of the criteria gases NOx and SO2, compliance audits are only necessary for the wet chemistry methods 6, 7, and 8. Testing utilizing continuous emissions monitors (CEMS) by Methods 7e and 6c do not require audit samples.

Audit samples add a variable cost to the sampling activities, depending on how many samples under what methods are required, and take 4 – 6 weeks to prepare. It is advised to begin preparations as much as two months before doing any required testing, in the same period of time that test plans or test protocols are drafted and submitted to state or federal regulators.

An audit sample has to be prepared specific to the source being tested. In order to prepare the audit, the preparatory lab would need the following information for the source.

  • Analyte/pollutant being measured.
  • Emission limit (lb/hr)
  • Estimated in-stack gas concentration (mg/dscm)
  • Stack flow rate (dscfm)
  • The sampling rate (m3/hr)
  • Length of the sampling run (hr)

The audit sample must be present on-site during the conduct of the compliance test, and the sample must be included and analyzed by the analytical laboratory in the same batch and the same manner as the samples collected from the actual compliance testing. Failure to provide for those factors may delay regulatory acceptance of the compliance test, or cause the test report to be rejected.

In all compliance testing, an experienced partner is crucial to ensuring results acceptable to the regulators. A qualified stack testing firm such as ESS can include the organization, procurement, and analysis of audit samples in the scope of the testing project, leading to less headaches, and a compliance test for your facility that is accurate and follows all necessary protocols and procedures.

Environmental Source Samplers, Inc. (ESS) was founded in 1979 and has been conducting point source, ambient and industrial hygiene air quality testing and consulting. ESS utilizes modern and consistently maintained equipment to conduct its testing services world-wide. They are qualified to conduct a wide range of air testing methodologies in almost any environment – and for almost any industry. ESS clients have easy access to the reliable and accurate reporting of test results through a secure online client portal. accessible at their main website, www.essknowsair.com.

If you have a compliance demonstration required for your facility, give ESS a call today: 910-799-1055.

For more information about the EPA required audit samples for source tests, visit the NELAC Stationary Source Audit Sample Program site at the following link: http://www.nelac-institute.org/ssas/.

 

EPA Proposal – Carbon Pollution Standards for New Power Plants

EPA News & UpdatesOn September 20, 2013, the US Environmental Protection Agency (EPA) proposed new Clean Air Act standards to cut carbon pollution from new power plants. The proposed rule is for New Source Performance Standards (NSPS) for new fossil fuel-fired electric generating units (EGUs), primarily those fired by coal or natural gas. The rule was crafted to limit the emissions of carbon dioxide (CO2), from these EGU units.

The proposal is part of the EPAs plans to combat climate change and improve public health. Fossil fuel-fired power plants are the nation’s largest sources of carbon pollution and emissions of Greenhouse Gases (GHGs). The rule is designed to require any newly constructed power plants be equipped during the construction phase with the available best technology for controlling carbon and GHG emissions. EPA is accepting and encouraging public comment on the new proposed standards, and will maintain the comment period for 60 days after the original publish date in the Federal Register.

The proposed standards are, in actuality, a revision of standards originally proposed in April of 2012, and this new proposal is an attempt on the part of the EPA to accommodate the feedback and criticisms from the 2.5 million public comments received after the initial proposed rule. The chief criticism of the original rule was a single standard for both coal and natural gas-fired units, based on a single concept of “best system of emissions reductions” (BSER). In response to this, the new rule proposes two separate standards for coal and gas-fired units, based on BSERs specific to each category. The original proposal was rescinded by the EPA in a separate action.

This NSPS proposed rule is specific to plants that will be constructed in the future, typically identified as after the date of the proposal. After the proposed NSPS standards, the EPA has announced plans to communicate with the owners and operators of currently-constructed sources, to develop standards for existing units. These standards are expected to be different from, and less stringent than, the standards proposed now for future sources.

The Proposed NSPS Standards

    • Fossil Fuel-fired utility boilers and integrated gasification combined cycle (IGCC) units
      • BSER – Partial Carbon Capture System
      • Proposed limits, dependent on compliance period that best suits the unit:
        • 1,100 lb CO2/MWh gross over 12-operating month period
        • 1,000 – 1,050 lb CO2/MWh gross over an 84-operating month (7-year) period
    • Natural gas-fired stationary combustion units
      • BSER – Current Natural gas combined cycle (NGCC) units
      • Proposed limits, dependent on size of the unit:
        • 1,000 lb CO2/MWh gross for larger units (>850 mmBtu/hr)
        • 1,100 lb CO2/MWh gross for smaller units (?850 mmBtu/hr)

Comment Period and How to Comment

EPA will accept comment on this new proposal for 60 days after publication in the Federal Register.

Comments on the proposed standard should be identified by Docket ID No. EPA-HQ-OAR-2013-0495. All comments may be submitted by one of the following methods:

  • www.regulations.gov – follow the on-line instructions for comment submittal
  • E-mail comments to [email protected]
  • Fax your comments to: 202-566-9744
  • Mail your comments to:
    • Air and Radiation Docket and Information Center
    • Environmental Protection Agency
    • Mail Code: 2822 2T
    • 1200 Pennsylvania Ave. NW
    • Washington, DC 20460
  • Deliver your comments to:
    • EPA Docket Center, Room 3334
    • 1301 Constitution Ave. NW
    • Washington, DC 20460

For Fact Sheets, the full proposed rule, and any other information, visit the following link:
www2.epa.gov/carbon-pollution-standards/2012-proposed-carbon-pollution-standard-new-power-plants

NSHM Rule – Classification of Materials as Fuel or Waste for Combustion

Industrial PlantOn December 20, 2012, the US EPA promulgated several final rules for emissions standards for certain industrial boilers and incinerators. Also finalized at the same time was a rule that determines what standards apply to units that combust secondary materials, rather than traditional fuels. This rule is known as the Identification of Non-Hazardous Secondary Materials That Are Solid Waste (NSHM Rule), and it is important because the EPA determination of a particular fuel as a waste has ramifications for the unit in question. If a unit is firing a fuel determined as a waste, then it will be required to meet the more stringent standards for Commercial/Industrial Incinerators (CISWI), rather than the standards applicable to boilers, known under as MACT standards.

However, the criteria by which the EPA would determine whether a fuel is waste or non-waste has been very opaque since the outset, and early attempts to distinguish between the two categories were even a primary reason for earlier MACT and CISWI rules to be invalidated and vacated entirely. In 2011 EPA attempted to resolve this with the first NSHM rule, but again failed to establish clear and legally sound criteria for distinguishing between the fuel types. This led to the rule being reopened in March of 2011, the publishing of proposed changes in December of that year, and the Final Rule being promulgated in December of 2012.

The regulatory structure is one where the burden of proof is on the unit operator or owner of a unit firing secondary material to demonstrate that the fuel is not a waste, by demonstrating that it meets certain criteria to be a legitimate fuel, rather than the disposal of waste. For materials combusted by the generator (of the material) as fuels, these legitimacy criteria are demonstrated by whether the materials are:

  • Managed as a valuable commodity
  • Have sufficient heating value
  • Contain pollutants at levels comparable to or lower than a traditional fuel for the unit

For materials combusted by third parties (not the generator of the material), the material must meet those legitimacy criteria, and in addition must be either processed into non-waste by removing contaminants, or must be approved by a petition to the EPA.

Some materials that are combusted might be materials in the manufacturing process, and are known as ingredients. These ingredients can be defined as non-waste fuels by meeting a different set of legitimacy criteria.

  • In lieu of heating values, consider the contribution made by the material to the production or manufacturing process.
  • In lieu of evaluating inputs, the contaminant comparison is made by comparing the product produced using the secondary materials to products made using virgin materials.

Ingredient materials meeting these legitimacy criteria can be combusted by both the generator and third parties without requirement for processing or a petition.

Another step taken in the December 2012 rule was the creation of an additional mechanism to identify non-waste fuels by categorical determination. Under this aspect, the EPA may consider any relevant factor, and can list a material as a non-waste fuel even when it does not meet one or more of the legitimacy criteria. These listed fuels can then be combusted without making individual determinations that the fuel is legitimate. However, this mechanism does not apply to materials used as ingredients.

There are already four (4) categories of materials that have been established to not be wastes when combusted, they are:

  • Scrap tires that are not discarded and are managed under established tire collection programs
  • Resinated wood
  • Coal refuse recovered from legacy piles and processed in the same manner as currently generated coal refuse
  • Dewatered pulp and paper sludges that are not discarded and are generated and burned on-site by pulp and paper mills

Future potential categorical listings may also include construction and demolition wood, paper recycling residuals, railroad ties, and treated wood.

The compliance deadline for Boilers is three years, and for CISWI units is five years. Regardless, it is important to make the determination of fuel classification in the immediate, to prepare strategies for compliance with these new emission limits. If an operator combusts a waste after the compliance deadline for the CISWI, even if the waste is burned inadvertently, or if process data is not maintained on secondary materials being burned, then the unit would immediately become a CISWI and be regulated as such for six (6) months. Due to the more stringent requirements, in practical terms this means that many units would have to be shut down for that period of time.

In all aspects of compliance with MACT and CISWI, and other EPA rules and regulations, ESS has experience and the network to facilitate any air-quality needs. For assistance with topics from emissions testing to control device strategies, we are here to assist.  Please call our experts at (910) 799-1055.

Boiler MACT, CISWI, and NHSM Rule Updates

Boiler MACT, CISWI, and NHSM Rule UpdatesAdjustments to the Final Standards For Major and Area Source Boilers an Certain Incinerators

On December 20th, 2012, the U.S. EPA finalized a set of adjustments to Clean Air Act Standards for boilers and certain solid waste incinerators (CISWI). These adjustments to the standards came in response to public comment, petition, and critique following the initial finalization of the rules in March of 2011. The finalized adjustments and rule ostensibly represent an attempt to seek middle ground between the lessening of toxic air-pollutants, while providing a reprieve on the already-burdened industry in the slowly-recovering economy.

Unit-Specific Standards and Compliance

One set of adjustments in the finalized ruling revolve around the creation of new subcategories of specific types of units, in an attempt to provide appropriate regulations for a wide variety of unit types that have significant variations in use, fuels, and emissions output. Some new sub-categories include units that burn light/heavy industrial liquids, coal fluidized bed units, and dual-fuel fired boilers. In addition, certain area source boilers are being reconsidered based on seasonal or limited use, easing the compliance burden for less-frequently used units. These categorical regulations, along with adjustments made to emissions standards for pollutants including Particulate Matter (PM), Carbon Monoxide (CO), and Mercury (Hg), allow the EPA to estimate that most of the existing 1.5 million boilers operating in the United States will already be in compliance with the new standards, and many of those left can demonstrate compliance with work-practice standards, rather than performance tests.

Compliance Dates

Another of the adjustments deals with the dates that facilities must come into compliance with the new standards. For existing Area Source Boilers, initial notification has been extended to January 20, 2014, and the initial tune-up requirements for boilers subject to work practice standards have been extended to March 21, 2014. The date of initial compliance for all units has also been extended until March 21, 2014, as well, with the possibility of requesting an initial year if necessary to integrate the proper control equipment. For existing major source boilers, the date for initial compliance has been extended to early 2016, with an additional year upon request as needed. For CISWI units, existing incinerators have to comply no later than early 2018, while new incinerators will need to meet the standards 180 days following publication in the Federal Register.

Non-Hazardous Secondary Materials (Fuel versus Waste)

The final adjustments made to the NHSM rule represent another step in the long attempt by the EPA to properly define waste versus fuel, and how units are classified and subject to rules and different emissions limits as based on those classification. The classification of waste versus fuel will be a subject in an upcoming entry, but in short the new ruling allows for self-evaluation using certain “legitimacy criteria” — such as whether or not the materials are managed as a valuable commodity, have sufficient heating value, and contain Clean Air Act pollutants at levels comparable to or lower than a traditional fuel that the combustion unit is capable of burning.

Outreach

The EPA has announced its intention to partner with the US Department of Energy (DOE), through its regional Clean Energy Application Centers, to provide site-specific technical and cost information to the major source facilities currently burning coal or oil in their boilers. Technical experts will visit these facilities and discuss compliance strategies, information on potential funding and financing, and analysis of energy assessment and boiler tune-up options. The US Department of Agriculture (USDA) will likewise be reaching out to facilities that have boilers that burn biomass to make sure that operators understand the regulations and how they apply to the units in question.

More information on this program can be found at the following link:
http://www1.eere.energy.gov/manufacturing/states/pdfs/incentives_boiler_mact.pdf

For more information on the Final Standards, visit the following link:
http://www.epa.gov/airquality/combustion/actions.html

 

Related Posts:

New RICE Rules for MACT Standards and Compliance
Stack Testing Methods

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

Latest EPA News

Visit the News page on our main website for the Latest EPA News and Updates.

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