Reciprocating Internal Combustion Engine NESHAP Compliance Deadline Approaches
By Kelly D. Bartley, Attorney, Bingham Greenebaum Doll LLP
The compliance deadline for existing stationary compression ignition engines subject to 40 CFR Part 63, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants from Reciprocating Internal Combustion Engines (the RICE NESHAP), is fast approaching. Owners and operators of such engines, whether located at an area or major source of hazardous air pollutants (HAP), are required to be in compliance with applicable RICE NESHAP requirements beginning May 3, 2013. Existing spark ignition RICE not already required to comply with RICE NESHAP standards are subject to an October 19, 2013 compliance deadline. Specific compression ignition standards depend upon the size of the engine and whether it operates only for emergency purposes as that term is defined under the NESHAP. Standards may include emission limitations and operating limitations, as well as performance testing, monitoring, reporting and recordkeeping requirements. Air permitting and/or registration obligations may also be triggered.
The RICE NESHAP applies to owners and operators of an extremely wide number of engines. With the exception of RICE tested at engine test cells/stands, the RICE NESHAP defines all stationary RICE regardless of engine size and source HAP status as an affected source subject to standards although certain emergency RICE (those rated greater than 500 horsepower and located at a major HAP source and commercial, residential and institutional RICE located at area HAP sources) are subject only to requirements restricting operation to qualifying “emergency” uses. Certain “limited use” RICE are also subject to minimal requirements. EPA estimates that there are 1.5 million stationary RICE located in the United States. An estimated 78 percent of those engines are compression ignition.
To view a complete PDF of the January/February 2013 issue of the Environmental Letter, click HERE.