New England Healthcare Engineers’ SocietyNew England Healthcare Engineers’ Society
Recently Promulgated National Recently Promulgated National Air Quality Regulations and Air Quality Regulations and
How They Will Impact HospitalsHow They Will Impact Hospitals
Cathy BeahmCathy BeahmTechnical Assistance SpecialistTechnical Assistance Specialist
NH DES, Air ResourcesNH DES, Air Resources
Presentation OverviewPresentation Overview
Air Emission BasicsAir Emission Basics Boiler RegulationsBoiler Regulations Emergency Generator RegulationsEmergency Generator Regulations QuestionsQuestions
Air Emission BasicsAir Emission Basics
Criteria PollutantsCriteria Pollutants Products of combustion: Nitrogen Oxides (NOx), Carbon Products of combustion: Nitrogen Oxides (NOx), Carbon
Monoxide (CO), Sulfur Dioxide (SOMonoxide (CO), Sulfur Dioxide (SO22), Particulate Matter (PM) ), Particulate Matter (PM)
and Volatile Organic Compounds (VOC) or Non-methane and Volatile Organic Compounds (VOC) or Non-methane hydrocarbons (NMHC)hydrocarbons (NMHC)
The Clean Air Act (CAA) requires EPA to identify The Clean Air Act (CAA) requires EPA to identify sources of Hazardous Air Pollutants (HAPs) and develop sources of Hazardous Air Pollutants (HAPs) and develop regulations to limit these emissions.regulations to limit these emissions. Boilers, Incinerators and Reciprocating Internal Combustion Boilers, Incinerators and Reciprocating Internal Combustion
EnginesEngines
Hazardous Air PollutantsHazardous Air Pollutants List of 188 HAPs from the CAA can be found at List of 188 HAPs from the CAA can be found at
http://www.epa.gov/oar/toxicair/newtoxics.htmlhttp://www.epa.gov/oar/toxicair/newtoxics.html
Air Emission Basics (continued)Air Emission Basics (continued)
EPA has developed both Major and Area Source EPA has developed both Major and Area Source National Emission Standards for Hazardous Air National Emission Standards for Hazardous Air Pollutants (NESHAPs) promulgated under 40 CFR 63Pollutants (NESHAPs) promulgated under 40 CFR 63
Major vs. Area SourcesMajor vs. Area Sources Major sources have the Potential to Emit (PTE) greater than Major sources have the Potential to Emit (PTE) greater than
10 tpy10 tpy individual HAP and individual HAP and 25 tpy25 tpy combined HAPs combined HAPs
Area sources are facilities that are not major sources - who do Area sources are facilities that are not major sources - who do not have PTE above these levels either due to permit limitations not have PTE above these levels either due to permit limitations or design capacity.or design capacity.
Majority of Sources in NH are Area SourcesMajority of Sources in NH are Area Sources
Hospital SpecificsHospital Specifics
Hospitals in NH are Hospitals in NH are area sourcesarea sources of HAPs based on the of HAPs based on the boilers and emergency generators currently permitted.boilers and emergency generators currently permitted. To determine your facility’s classification, you must calculate To determine your facility’s classification, you must calculate
your PTE of HAPs from all devices at your facility (boilers, your PTE of HAPs from all devices at your facility (boilers, emergency generators, ethylene oxide sterilizers, etc.)emergency generators, ethylene oxide sterilizers, etc.)
Hospitals typically burn Hospitals typically burn traditional fuelstraditional fuels in their boilers in their boilers (coal, biomass, oil or gas) as opposed to solid waste.(coal, biomass, oil or gas) as opposed to solid waste. Presentation today is not covering HIMWI (none in NH – few, if Presentation today is not covering HIMWI (none in NH – few, if
any, in New England).any, in New England).
Almost 97% of the hospitals in NH burn Almost 97% of the hospitals in NH burn fuel oilfuel oil alone or alone or in combination with natural gas.in combination with natural gas.
One facility in NH operates 2 small (<10 MMBtu/hr) One facility in NH operates 2 small (<10 MMBtu/hr) biomass boilers.biomass boilers.
Over 70% have at least one boilerOver 70% have at least one boiler >10 MMBtu/hr >10 MMBtu/hr..
Boiler RegulationsBoiler Regulations
Overview of recent EPA actions affecting boilersOverview of recent EPA actions affecting boilers
EPA issued three rules that reduce emissions of HAPs:EPA issued three rules that reduce emissions of HAPs:
NESHAP for Industrial, Commercial, and Institutional Boilers and NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR 63, Subpart DDDDD) (“Boiler MACT”)Process Heaters (40 CFR 63, Subpart DDDDD) (“Boiler MACT”)
NESHAP for Area Sources: Industrial, Commercial, and NESHAP for Area Sources: Industrial, Commercial, and Institutional Boilers (40 CFR 63, Subpart JJJJJJ) (“Boiler Area Institutional Boilers (40 CFR 63, Subpart JJJJJJ) (“Boiler Area Source Rule”)Source Rule”)
Section 129 NSPS and Emission Guidelines for Commercial and Section 129 NSPS and Emission Guidelines for Commercial and Industrial Solid Waste Incinerators (CISWI) Industrial Solid Waste Incinerators (CISWI)
EPA also issued a final rule that defines “solid waste”EPA also issued a final rule that defines “solid waste” Necessary to determine whether a source must meet boiler Necessary to determine whether a source must meet boiler
standards or an incinerator standardstandards or an incinerator standard
Overview of recent EPA actions affecting boilers Overview of recent EPA actions affecting boilers (cont.)(cont.)
ScheduleSchedule Proposals signed on April 29, 2010Proposals signed on April 29, 2010 Published in the Published in the Federal Register Federal Register on on June 4, 2010June 4, 2010 Promulgations signed on February 21, 2011 (Court-ordered)Promulgations signed on February 21, 2011 (Court-ordered) Published in the Published in the Federal Register Federal Register on on March 21, 2011March 21, 2011 Effective Date: May 20, 2011Effective Date: May 20, 2011
EPA has initiated reconsideration of certain aspects of the boiler EPA has initiated reconsideration of certain aspects of the boiler and CISWI rulesand CISWI rules Some of the comments raise difficult technical issues that would benefit from Some of the comments raise difficult technical issues that would benefit from
additional public involvement.additional public involvement. Stakeholders have petitioned for reconsideration of other issues.Stakeholders have petitioned for reconsideration of other issues.
StayStay On May 18, 2011, EPA delayed the effective date of the Boiler MACT and On May 18, 2011, EPA delayed the effective date of the Boiler MACT and
CISWICISWI
Boiler Area Source Rule and Solid Waste Definition are in effect Boiler Area Source Rule and Solid Waste Definition are in effect even during the reconsideration process.even during the reconsideration process. Facilities need to comply with rules as they were promulgated.Facilities need to comply with rules as they were promulgated.
Focus of Today’s Presentation:Focus of Today’s Presentation:
Boiler Area Source RuleBoiler Area Source RuleArea Sources burning Traditional Fuel (oil)Area Sources burning Traditional Fuel (oil)
Boiler Area Source RuleBoiler Area Source Rule
Rule is broken down based on:Rule is broken down based on: Boiler size:Boiler size:
Small (<10 MMBtu/hr)Small (<10 MMBtu/hr) Large (Large (≥10 MMBtu/hr)≥10 MMBtu/hr)
Fuel type:Fuel type: Coal-fired unitsCoal-fired units Biomass-fired unitsBiomass-fired units Oil-fired unitsOil-fired units
Boiler Construction:Boiler Construction: Existing prior to June 4, 2010Existing prior to June 4, 2010 New or reconstructed after June 4, 2010New or reconstructed after June 4, 2010
Are any boilers not subject to this subpart?Are any boilers not subject to this subpart?
Any boiler covered by another part of 40 CFR 63Any boiler covered by another part of 40 CFR 63
Any boiler covered by CISWIAny boiler covered by CISWI
Hazardous waste boilersHazardous waste boilers
A boiler that is used specifically for research and A boiler that is used specifically for research and development.development. This exemption does not include boilers that solely or primarily This exemption does not include boilers that solely or primarily
provide steam (or heat) to a process or for heating at a research provide steam (or heat) to a process or for heating at a research and development facility.and development facility.
Any boiler that is used as a control device to comply with Any boiler that is used as a control device to comply with another Subpart of 40 CFR 63, provided that at least 50 another Subpart of 40 CFR 63, provided that at least 50 percent of the heat input to the boiler is provided by the gas percent of the heat input to the boiler is provided by the gas stream that is regulated under another subpart.stream that is regulated under another subpart.
Are any boilers not subject to this subpart? Are any boilers not subject to this subpart? (continued)(continued)
A hot water heater as defined in this subpart.A hot water heater as defined in this subpart.
Hot water heaterHot water heater means a closed vessel with a capacity of no more means a closed vessel with a capacity of no more than 120 U.S. gallons in which water is heated by combustion of than 120 U.S. gallons in which water is heated by combustion of gaseous or liquid fuel and is withdrawn for use external to the gaseous or liquid fuel and is withdrawn for use external to the vessel at pressures not exceeding 160 psig, … and … water vessel at pressures not exceeding 160 psig, … and … water temperatures exceeding 210°F.temperatures exceeding 210°F.
A gas-fired boiler as defined in this subpart.A gas-fired boiler as defined in this subpart.
Gas-fired boilerGas-fired boiler includes any boiler that burns gaseous fuels not includes any boiler that burns gaseous fuels not combined with any solid fuels, burns liquid fuel only during periods combined with any solid fuels, burns liquid fuel only during periods of gas curtailment, gas supply emergencies, or periodic testing on of gas curtailment, gas supply emergencies, or periodic testing on liquid fuel. Periodic testing of liquid fuel shall not exceed a combined liquid fuel. Periodic testing of liquid fuel shall not exceed a combined total of 48 hours during any calendar year.total of 48 hours during any calendar year.
Fuel Switching Rule ProvisionsFuel Switching Rule Provisions
A boiler is a A boiler is a newnew affected source if you commenced fuel switching from affected source if you commenced fuel switching from natural gas to solid fossil fuel, biomass, or liquid fuel after June 4, 2010.natural gas to solid fossil fuel, biomass, or liquid fuel after June 4, 2010.
If you intend to switch fuels, and this fuel switch may result in the If you intend to switch fuels, and this fuel switch may result in the applicability of a different subcategory or a switch out of Subpart JJJJJJ applicability of a different subcategory or a switch out of Subpart JJJJJJ due to a switch to 100 percent natural gas, you must provide due to a switch to 100 percent natural gas, you must provide 30 days30 days prior notice of the date upon which you will switch fuels.prior notice of the date upon which you will switch fuels.
If you own or operate an industrial, commercial, or institutional boiler and If you own or operate an industrial, commercial, or institutional boiler and would be subject to this subpart except for the exemption for units would be subject to this subpart except for the exemption for units covered by the CISWI rules, and you cease combusting solid waste, you covered by the CISWI rules, and you cease combusting solid waste, you must be in compliance with this subpart on the effective date of the must be in compliance with this subpart on the effective date of the waste to fuel switch.waste to fuel switch.
If you intend to commence or recommence combustion of solid waste, If you intend to commence or recommence combustion of solid waste, you must provide you must provide 30 days30 days prior notice of the date upon which you will prior notice of the date upon which you will commence or recommence combustion of solid waste.commence or recommence combustion of solid waste.
Area Source Requirements – Oil and Biomass Units Only
Industrial, Commercial, and Institutional Boilers 40 CFR Part 63, Subpart JJJJJJ
Do the Emission Limits Requirements Apply?
Existing
Oil Units
New Oil
Units
Existing Biomass
Units
New Biomass
Units ≥ 10 MM
Btu/hr No Yes No Yes
< 10 MM Btu/hr
No No No No
Do I do a One-Time Energy Assessment?
Existing
Oil Units
New Oil
Units
Existing Biomass
Units
New Biomass
Units ≥ 10 MM
Btu/hr Yes No Yes No
< 10 MM Btu/hr
No No No No
Do I do a Biennual (every other year) Tune-Up?
Existing
Oil Units
New Oil
Units
Existing Biomass
Units
New Biomass
Units ≥ 10 MM
Btu/hr Yes Yes Yes Yes
< 10 MM Btu/hr
Yes Yes Yes Yes
Emission Limits for Area Source BoilersEmission Limits for Area Source BoilersOil and Biomass OnlyOil and Biomass Only
SubcategorySubcategory Emission LimitsEmission Limits
PM (lb/MMBtu)PM (lb/MMBtu)
10 – 30 MMBtu/hr10 – 30 MMBtu/hr >30 MMBtu/hr>30 MMBtu/hr
New New BiomassBiomass
0.070.07 0.030.03
New OilNew Oil 0.030.03 0.030.03
Existing Existing BiomassBiomass
-- --
Existing OilExisting Oil -- --
Energy AssessmentEnergy Assessment[40 CFR 63, Subpart JJJJJJ - Table 2][40 CFR 63, Subpart JJJJJJ - Table 2]
One-time energy assessment performed by a qualified energy assessor.One-time energy assessment performed by a qualified energy assessor. An energy assessment completed on or after January 1, 2008, that meets or is An energy assessment completed on or after January 1, 2008, that meets or is
amended to meet the energy assessment requirements satisfies the energy amended to meet the energy assessment requirements satisfies the energy assessment requirements.assessment requirements.
The energy assessment must include:The energy assessment must include: A visual inspection of the boiler system,A visual inspection of the boiler system, An evaluation of operating characteristics of the facility, specifications of energy An evaluation of operating characteristics of the facility, specifications of energy
using systems, operating and maintenance procedures, and unusual operating using systems, operating and maintenance procedures, and unusual operating constraints,constraints,
Inventory of major systems consuming energy from affected boiler(s),Inventory of major systems consuming energy from affected boiler(s), A review of available architectural and engineering plans, facility operation and A review of available architectural and engineering plans, facility operation and
maintenance procedures and logs, and fuel usage,maintenance procedures and logs, and fuel usage, A list of major energy conservation measures,A list of major energy conservation measures, A list of the energy savings potential of the energy conservation measures A list of the energy savings potential of the energy conservation measures
identified,identified, A comprehensive report detailing the ways to improve efficiency, the cost of specific A comprehensive report detailing the ways to improve efficiency, the cost of specific
improvements, benefits, and the time frame for recouping those investments.improvements, benefits, and the time frame for recouping those investments.
Tune-up Requirement [63.11223(b)]Tune-up Requirement [63.11223(b)] As applicable, As applicable, inspect the burnerinspect the burner, and clean or replace any , and clean or replace any
components of the burner as necessary (you may delay the burner components of the burner as necessary (you may delay the burner inspection until the next scheduled unit shutdown, but you must inspect inspection until the next scheduled unit shutdown, but you must inspect each burner at least once every 36 months).each burner at least once every 36 months).
Inspect the flame patternInspect the flame pattern, as applicable, and adjust the burner as , as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer’s specifications, if available.consistent with the manufacturer’s specifications, if available.
Inspect the system controlling the air-to-fuel ratio, as applicable, and Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly.ensure that it is correctly calibrated and functioning properly.
Optimize total emissions of carbon monoxideOptimize total emissions of carbon monoxide. This optimization . This optimization should be should be consistent with the manufacturer’s specificationsconsistent with the manufacturer’s specifications, if available., if available.
Tune-up Requirement [63.11223(b)]Tune-up Requirement [63.11223(b)](continued)(continued)
Measure the concentrationsMeasure the concentrations in the effluent stream of in the effluent stream of carbon monoxidecarbon monoxide in in parts per million, by volume, and parts per million, by volume, and oxygenoxygen in volume percent, in volume percent, before and before and after the adjustmentsafter the adjustments are made (measurements may be either on a dry or are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments wet basis, as long as it is the same basis before and after the adjustments are made).are made).
Maintain onsite and submit, if requested, Maintain onsite and submit, if requested, biennial reportbiennial report containing the containing the following information:following information: The concentration of CO in the effluent stream in ppm, by volume, and oxygen in The concentration of CO in the effluent stream in ppm, by volume, and oxygen in
volume percent, measured before and after the tune-up of the boiler.volume percent, measured before and after the tune-up of the boiler. A description of any corrective actions taken as a part of the tune-up of the A description of any corrective actions taken as a part of the tune-up of the
boiler.boiler. The type and amount of fuel used over the 12 months prior to the biennial tune-The type and amount of fuel used over the 12 months prior to the biennial tune-
up of the boiler.up of the boiler.
If the unit is not operating on the required date for a tune-up, the tune-up If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within one week of startup.must be conducted within one week of startup.
Notifications and Reporting Notifications and Reporting TimelineTimeline
Existing Biomass and Oil-Fired Boilers<10 MMBtu/hr ≥10 MMBtu/hr
Initial Notification of Applicability Report By September 17, 2011Initial Compliance Date First biennial tune-up by March 21, 2012
One Time Energy Assessment NA By March 21, 2014
Notification of Intent to Conduct a Performance Test
NA NA
Initial Compliance Testing NA NA
Initial Notification of Compliance Status Report By July 19, 2012
By July 19, 2012 for initial tune-up;By July 19, 2014 for one-time energy
assessment
Continuing Compliance –Biennial Tune-up
Subsequent tune-ups should be completed no later than 25 months after the previous tune-up
Continuing Compliance –Triennial Testing
NA NA
Biennial Compliance Certification Report – Biennial Tune-up
Prepare first report by March 1, 2015 with subsequent reports prepared biennially by March 1st
Annual Compliance Certification Report NA NA
Notifications and Reporting Notifications and Reporting TimelineTimeline
New Biomass and Oil-Fired Boilers Installed between 6/4/10 and 5/20/11
<10 MMBtu/hr ≥10 MMBtu/hr
Initial Notification of Applicability Report By September 17, 2011
Initial Compliance Date First biennial tune-up by May 20, 2011
One Time Energy Assessment NA NA
Notification of Intent to Conduct a Performance Test
NAAt least 60 days before performance stack
test is scheduled to begin
Initial Compliance Testing NA By May 20, 2011
Initial Notification of Compliance Status Report
By September 17, 2011
Within 60 days of completing the performance test
Continuing Compliance –Biennial Tune-upSubsequent tune-ups should be completed no later than 25
months after the previous tune-up
Continuing Compliance –Triennial Testing NANo more than 37 months after the previous
test
Biennial Compliance Certification Report – Biennial Tune-up
Prepare first report by March 1, 2012 with subsequent reports prepared biennially by March 1st
Annual Compliance Certification Report NAPrepare first report by March 1, 2012 with subsequent reports prepared annually by
March 1st
Notifications and Reporting Notifications and Reporting TimelineTimeline
New Biomass and Oil-Fired Boilers Installed after 5/20/11
<10 MMBtu/hr ≥10 MMBtu/hr
Initial Notification of Applicability Report Within 120 days of startup of the boiler
Initial Compliance Date First biennial tune-up upon startup
One Time Energy Assessment NA NA
Notification of Intent to Conduct a Performance Test
NAAt least 60 days before performance stack
test is scheduled to begin
Initial Compliance Testing NA Within 180 calendar days of startup
Initial Notification of Compliance Status Report
Within 120 days of startup of the boiler
Within 60 days of completing the performance test
Continuing Compliance –Biennial Tune-upSubsequent tune-ups should be completed no later than 25
months after the previous tune-up
Continuing Compliance –Triennial Testing NANo more than 37 months after the previous
test
Biennial Compliance Certification Report – Biennial Tune-up
Prepare first report by March 1st of the year immediately following startup of the boiler with subsequent reports prepared biennially
by March 1st
Annual Compliance Certification Report NA
Prepare first report by March 1st of the year immediately following startup of the boiler
with subsequent reports prepared annually by March 1st
Notification and Reporting GuidanceNotification and Reporting Guidance Sample Initial Notifications, Notifications of Compliance Status, and Sample Initial Notifications, Notifications of Compliance Status, and
Tune-up Guidance and Example Recordkeeping Forms for Area Tune-up Guidance and Example Recordkeeping Forms for Area Sources can be found under “Implementation Tools” at: Sources can be found under “Implementation Tools” at: http://www.epa.gov/ttn/atw/boiler/boilerpg.htmlhttp://www.epa.gov/ttn/atw/boiler/boilerpg.html
Send copies of paperwork toSend copies of paperwork toEPA Region 1 US Environmental Protection AgencyEPA Region 1 US Environmental Protection Agency
5 Post Office Square, Suite 100, Mail code: OES04-2,5 Post Office Square, Suite 100, Mail code: OES04-2,Boston MA 02109-3912Boston MA 02109-3912
Attention: Air ClerkAttention: Air Clerk
and in the case of NH sourcesand in the case of NH sourcesNew Hampshire Department of Environmental ServicesNew Hampshire Department of Environmental Services
Air Resources DivisionAir Resources Division29 Hazen Drive29 Hazen Drive
P.O. Box 95P.O. Box 95Concord, NH 03302-0095Concord, NH 03302-0095
Attention: Section Supervisor, Compliance BureauAttention: Section Supervisor, Compliance Bureau
ContactsContacts
RegulationRegulation ContactContact OfficeOffice Telephone Telephone NumberNumber
E-mailE-mail
Boiler MACTBoiler MACT Brian ShragerBrian Shrager USEPA USEPA Headquarters - Headquarters - OAQPSOAQPS
(919) 541-7689(919) 541-7689 [email protected]@epa.gov
Susan Susan LanceyLancey
USEPA – USEPA – Region 1Region 1
(617) 918-1656(617) 918-1656 [email protected]@epa.gov
Boiler Area Boiler Area Source RuleSource Rule
Jim EddingerJim Eddinger USEPA USEPA Headquarters - Headquarters - OAQPSOAQPS
(919) 541-5426(919) 541-5426 [email protected]@epa.gov
Susan Susan LanceyLancey
USEPA – USEPA – Region 1Region 1
(617) 918-1656(617) 918-1656 [email protected]@epa.gov
CISWICISWI Toni JonesToni Jones USEPA USEPA Headquarters - Headquarters - NRCGNRCG
(919) 541-0316(919) 541-0316 [email protected]@epa.gov
Solid Waste Solid Waste DefinitionDefinition
George George FaisonFaison
USEPA USEPA Headquarters – Headquarters – RCRARCRA
(703) 305-7652(703) 305-7652 [email protected]@epa.gov
Jui-Yu HsiehJui-Yu Hsieh USEPA - USEPA - Region 1Region 1
(617) 918-1646(617) 918-1646 [email protected]@epa.gov
Permitting GuidancePermitting Guidance
NH Permit ApplicabilityNH Permit Applicability
NH Permit ApproachesNH Permit Approaches Individual Permits (Temporary, State, Title V)Individual Permits (Temporary, State, Title V)
DeviceDevice Design gross heat input Design gross heat input (BTU/hr)(BTU/hr)
FuelFuel
External Combustion External Combustion Device (Boiler)Device (Boiler)
≥≥10,000,00010,000,000 Gaseous fuel, LPG, Gaseous fuel, LPG, distillate fuel (#2 fuel distillate fuel (#2 fuel oil) or diesel fuel, any oil) or diesel fuel, any combinationcombination
≥≥4,000,0004,000,000 #4 fuel oil#4 fuel oil
≥≥2,000,0002,000,000 Solid fuel, residual fuel Solid fuel, residual fuel (#6 fuel oil), used oil, (#6 fuel oil), used oil, any combinationany combination
Emergency Generator Emergency Generator RegulationsRegulations
Overview of recent EPA actions affecting Overview of recent EPA actions affecting emergency generatorsemergency generators
EPA issued three rules that regulate EPA issued three rules that regulate emissions from reciprocating internal emissions from reciprocating internal combustion engines (RICE):combustion engines (RICE): NSPS for Stationary Compression Ignition (CI) Internal NSPS for Stationary Compression Ignition (CI) Internal
Combustion Engines (40 CFR 60, Subpart IIII) (“Quad I”)Combustion Engines (40 CFR 60, Subpart IIII) (“Quad I”)
NSPS for Stationary Spark Ignition (SI) Internal Combustion NSPS for Stationary Spark Ignition (SI) Internal Combustion Engines (40 CFR 60, Subpart JJJJ) (“Quad J”)Engines (40 CFR 60, Subpart JJJJ) (“Quad J”)
NESHAP for Stationary Reciprocating Internal Combustion NESHAP for Stationary Reciprocating Internal Combustion Engines (RICE) (40 CFR 63, Subpart ZZZZ) (“Quad Z”) Engines (RICE) (40 CFR 63, Subpart ZZZZ) (“Quad Z”)
How do these three rules compare?How do these three rules compare?(Information is for comparison purposes only)(Information is for comparison purposes only)
RegulationRegulation Fuel TypeFuel Type Manufacture Manufacture Date of EngineDate of Engine11
Pollutants Pollutants RegulatedRegulated
Quad IQuad I DieselDiesel Beginning in model Beginning in model year 2007 and lateryear 2007 and later
NOx, PM, CO, NOx, PM, CO, NMHCNMHC
Quad JQuad J GasolineGasoline Beginning in model Beginning in model year 2007 and lateryear 2007 and later
NOx, PM, CO, NOx, PM, CO, NMHCNMHC
Quad ZQuad Z Both fuelsBoth fuels All enginesAll engines HAPsHAPs
1 Manufacture date varies with size of engine. See rule for more accurate information on the dates.
NSPS for Stationary CI Internal NSPS for Stationary CI Internal Combustion Engines (“Quad I”)Combustion Engines (“Quad I”)
Affects new, modified, and reconstructed Affects new, modified, and reconstructed stationary CI engines [stationary CI engines [diesel fired enginesdiesel fired engines]]
Initially promulgated on July 11, 2006Initially promulgated on July 11, 2006 Amendments signed June 8, 2011Amendments signed June 8, 2011
Who is Subject to Quad I?Who is Subject to Quad I?
Manufacturers of 2007 model year or later Manufacturers of 2007 model year or later stationary CI engines <30 liters/cylinder stationary CI engines <30 liters/cylinder displacementdisplacement Model years differ for fire pump engines (2008-2011 Model years differ for fire pump engines (2008-2011
depending on size)depending on size)
Owners/operatorsOwners/operators of engines of engines Constructed (ordered) after 7/11/2005 and Constructed (ordered) after 7/11/2005 and
manufactured after 4/1/2006manufactured after 4/1/2006 Constructed after 7/1/2006 for fire pump enginesConstructed after 7/1/2006 for fire pump engines Modified/reconstructed after 7/11/2005Modified/reconstructed after 7/11/2005
Quad I - Emission StandardsQuad I - Emission Standards
Phased in over several years and have Tiers Phased in over several years and have Tiers with increasing levels of stringencywith increasing levels of stringency
Output-based, units of g/kW-hr (g/HP-hr)Output-based, units of g/kW-hr (g/HP-hr) Pollutants: NOx, PM, CO, NMHCPollutants: NOx, PM, CO, NMHC SOx reduced through use of low sulfur fuelSOx reduced through use of low sulfur fuel Modeled after EPA’s standards for non-road and Modeled after EPA’s standards for non-road and
marine enginesmarine engines
Quad I - ComplianceQuad I - Compliance
Manufacturers must certify 2007 model year and Manufacturers must certify 2007 model year and later engines with a displacement <30 later engines with a displacement <30 liters/cylinderliters/cylinder Certification = EPA Certificate of ConformityCertification = EPA Certificate of Conformity
Owner/operator of emergency generators Owner/operator of emergency generators complies by:complies by: Purchasing certified enginePurchasing certified engine Install, configure, operate and maintain engine per Install, configure, operate and maintain engine per
manufacturer’s instructions or manufacturer-approved manufacturer’s instructions or manufacturer-approved proceduresprocedures
Install a non-resettable hour meter prior to startupInstall a non-resettable hour meter prior to startup Owner/operator operates unit with Owner/operator operates unit with ultra low sulfur ultra low sulfur
fuelfuel after October 1, 2010 (<15 ppm sulfur content) after October 1, 2010 (<15 ppm sulfur content)
Quad I - Quad I - Notification and RecordkeepingNotification and Recordkeeping
Emergency Generators Emergency Generators notnot required to submit required to submit an initial notification.an initial notification.
Maintain Maintain documentationdocumentation from the manufacturer from the manufacturer certifying that the engine complies with the certifying that the engine complies with the applicable emission standards of Quad Iapplicable emission standards of Quad I
Record the Record the time of operationtime of operation of the engine and of the engine and the the reasonreason the engine was in operation during the engine was in operation during that time.that time.
Keep records of the Keep records of the sulfur contentsulfur content of the fuel of the fuel burned in the device.burned in the device.
NSPS for Stationary SI Internal NSPS for Stationary SI Internal Combustion Engines (“Quad J”)Combustion Engines (“Quad J”)
Affects new, modified, and reconstructed Affects new, modified, and reconstructed stationary SI engines [stationary SI engines [gas fired enginesgas fired engines]]
Initially promulgated on January 18, 2008Initially promulgated on January 18, 2008 Amendments signed June 8, 2011Amendments signed June 8, 2011
Who is Subject to Quad J?Who is Subject to Quad J?
Manufacturers of stationary SI engines:Manufacturers of stationary SI engines: ≤≤25 HP and manufactured on/after 7/1/200825 HP and manufactured on/after 7/1/2008 >25 HP, gasoline or rich burn LPG, manufactured >25 HP, gasoline or rich burn LPG, manufactured
on/after 7/1/2008 (on/after 1/1/2009 for emergency on/after 7/1/2008 (on/after 1/1/2009 for emergency engines)engines)
>25 HP, not gasoline or not rich burn LPG, voluntary >25 HP, not gasoline or not rich burn LPG, voluntary certified engines manufacture on/aftercertified engines manufacture on/after
7/1/20077/1/2007 >500 HP (except lean burn 500≤HP<1,350)>500 HP (except lean burn 500≤HP<1,350) 1/1/20081/1/2008 lean burn 500≤HP<1,350lean burn 500≤HP<1,350 7/1/20087/1/2008 <500 HP<500 HP 1/1/20091/1/2009 emergency enginesemergency engines
Who is Subject to Quad J? (continued)Who is Subject to Quad J? (continued)
Owners/operators of stationary SI engines:Owners/operators of stationary SI engines: Constructed after 6/12/2006 andConstructed after 6/12/2006 and
≥≥500 HP manufactured on/after 7/1/2007 (except lean burn 500 HP manufactured on/after 7/1/2007 (except lean burn 500≤HP<1,350)500≤HP<1,350)
Lean burn 500≤HP<1,350 manufactured on/after 1/1/2008Lean burn 500≤HP<1,350 manufactured on/after 1/1/2008 <500 HP manufactured on/after 7/1/2008<500 HP manufactured on/after 7/1/2008 Emergency >25 HP manufactured on/after Emergency >25 HP manufactured on/after 1/1/20091/1/2009
Modified/reconstructed after 6/12/2006Modified/reconstructed after 6/12/2006
Quad J - Emission StandardsQuad J - Emission Standards
Phased in over several years and have Tiers Phased in over several years and have Tiers with increasing levels of stringencywith increasing levels of stringency
Output-based, units of g/kW-hr (g/HP-hr)Output-based, units of g/kW-hr (g/HP-hr) ppmvd@15% O2, standards for some enginesppmvd@15% O2, standards for some engines Pollutants: NOx, CO, VOCPollutants: NOx, CO, VOC Sulfur limit on gasolineSulfur limit on gasoline Some standards modeled after EPA’s standards Some standards modeled after EPA’s standards
for non-road SI enginesfor non-road SI engines
Quad J - ComplianceQuad J - Compliance
Manufacturers must certify engines ≤25 HP, Manufacturers must certify engines ≤25 HP, gasoline engines, and rich burn LPG enginesgasoline engines, and rich burn LPG engines
Manufacturers can elect to certify other enginesManufacturers can elect to certify other engines
Owner/operator complies by either:Owner/operator complies by either: For For certifiedcertified engines: Install, configure, operate and engines: Install, configure, operate and
maintain engine per manufacturer’s instructions or maintain engine per manufacturer’s instructions or manufacturer-approved proceduresmanufacturer-approved procedures
For For uncertifieduncertified engines: Conduct performance test engines: Conduct performance test (requirements vary depending on engine size)(requirements vary depending on engine size)
Quad J - Notification and RecordkeepingQuad J - Notification and Recordkeeping
Owners/operators of Owners/operators of uncertified SI RICEuncertified SI RICE ≥500 ≥500 HP must submit an initial notification.HP must submit an initial notification.
Owners/operators of all SI RICE must keep Owners/operators of all SI RICE must keep recordsrecords of: of: All notificationsAll notifications All maintenance conducted on the engineAll maintenance conducted on the engine For For certifiedcertified engines: Documentation from the engines: Documentation from the
manufacturer certifying that the engine complies with manufacturer certifying that the engine complies with the applicable emission standards of Quad Jthe applicable emission standards of Quad J
For For uncertifieduncertified engines or certified engines operating engines or certified engines operating in a non-certified manner: Documentation that the in a non-certified manner: Documentation that the engine meets the emission standards. engine meets the emission standards.
NESHAP for Stationary Reciprocating NESHAP for Stationary Reciprocating Internal Combustion Engines (RICE) Internal Combustion Engines (RICE)
(“Quad Z”)(“Quad Z”)
New or reconstructedNew or reconstructed stationary RICE located at stationary RICE located at an area source must meet the requirements of an area source must meet the requirements of Quad I or Quad JQuad I or Quad J. No further requirements . No further requirements apply under Quad Z.apply under Quad Z.
ExistingExisting (1/1/2009) (1/1/2009) institutional institutional emergency emergency stationary RICE located at an area source of stationary RICE located at an area source of HAP emissions do HAP emissions do notnot have to meet the have to meet the requirements of Quad Z or the General requirements of Quad Z or the General Provisions of 40 CFR 63.Provisions of 40 CFR 63.
Permitting GuidancePermitting Guidance
NH Permit ApplicabilityNH Permit Applicability
NH Permit ApproachesNH Permit Approaches General State PermitGeneral State Permit (up for renewal April 2013) (up for renewal April 2013)
On-line permitting (On-line permitting (http://des.nh.govhttp://des.nh.gov)) Easy, fast, less paperworkEasy, fast, less paperwork Initial permit is freeInitial permit is free Emission-based fees still applyEmission-based fees still apply
Individual Permits (Temporary, State, Title V)Individual Permits (Temporary, State, Title V)
DeviceDevice Design gross heat input Design gross heat input (BTU/hr)(BTU/hr)
FuelFuel
IndividualIndividual CombinedCombined
One or more Internal One or more Internal Combustion Devices Combustion Devices (Engines)(Engines)
150,000150,000 1,500,0001,500,000 Liquid fuel oilLiquid fuel oil
1,500,0001,500,000 10,000,00010,000,000 NG or LPGNG or LPG
Questions?Questions?
Contact:Contact:
Cathy BeahmCathy Beahm
N.H. Department of Environmental ServicesN.H. Department of Environmental Services
Air Resources DivisionAir Resources Division
(603) 271-2822(603) 271-2822