Workshop R Clean Air Act Challenges … Permitting Back Up/Emergency Generators: Surviving the EPA’s New Rules and Regulatory Maze in Ohio Tuesday, March 26, 2019 2 p.m. to 3:15 p.m.
Biographical Information William J. Bruscino, P.E. Principal Consultant - Trinity Consultants 110 Polaris Parkway, Suite 200 Westerville, Ohio 43082 Phone: 614.433.0733 E-mail: bbruscino@trinityconsultants.com Mr. Bruscino manages air quality permitting and compliance services for industries such as refining, chemical manufacturing upstream and midstream oil and gas, and general manufacturing. His experience includes Title V and PSD permitting in EPA Regions IV, V, and VI as well as compliance assessments and implementation projects. Mr. Bruscino has also assisted multiple facilities in establishing Title V and minor source air compliance programs including environmental management information system (EMIS) implementations. More specifically, he has audited and developed regulatory compliance programs for facilities operating a few emergency engines to corporate entities managing hundreds of engines. Mr. Bruscino currently manages Trinity’s Columbus, Ohio office and is a member of the Air & Waste Management Association. He received a Bachelor’s degree in chemical engineering from the University of Cincinnati and holds a Professional Engineering license in the State of Ohio. Michael E. Hopkins, P.E., Assistant Chief, Permitting Division of Air Pollution Control Ohio EPA, P.O. Box 1049, Columbus, OH 43216-0149 (614) 644-2270 FAX: (614) 644-3681 mike.hopkins@epa.ohio.gov Michael Hopkins has been with the Ohio EPA since 1980. He is currently the Assistant Chief, Permitting of the Ohio EPA. His duties include the review and final approval for all air pollution permit-to-install, permit-to-install and operate, and Title V permitting in the State, the development of technical support for air pollution control regulations, litigation support, MACT program support, Tax Program support and general air pollution planning activities. He has been in this position since April 2003. Before this assignment, he was in charge of the Air Quality Modeling and Planning Section with similar duties as above from August 1993 through April 2003. Prior to that assignment, he was in charge of the engineering section of the Ohio EPA Central District Office air program. The engineering section is responsible for reviewing air pollution permit-to- install and permit-to-operate applications for compliance with air pollution regulations, facility inspections, complaint investigations, enforcement case development, policy and rule development, the Emissions Inventory Program, and other related duties in the central Ohio area. Mr. Hopkins earned his Bachelor’s degree in environmental engineering from the Pennsylvania State University. He is a licensed Professional Engineer in the State of Ohio. He is a member of the Air and Waste Management Association, the National Society of Professional Engineers and the Ohio Society of Professional Engineers.
MEC Workshop R – Permitting Your Engines and Managing EPA’s Rules Cincinnati, OH – March 26, 2019 Mr. Michael Hopkins - Ohio EPA Mr. William Bruscino - Trinity
In this presentation, we will… . ˃ Identify Available Permitting Options ˃ Discuss Ohio-Specific Rules ˃ Future Changes ˃ Discuss Federally Applicable Rules
Permit Exemptions ˃ Gets out of need to obtain permit ˃ May still have other obligations ˃ Found in OAC 3745-31-03(B)(1) (B)(1)(nn) - Maintenance NG Compressor Engines (B)(1)(oo) - Emergency Gen, compressors, water pumps (B)(1)(pp) - 2/4-stroke gas engines (B)(1)(qq) - Non-road engines
NG Compressor Engine Exempt. ˃ <10 mmBtu/hr ˃ Use for maintenance purposes only ˃ Fired by NG, gasoline or distillate oil ˃ Complies w NSPS/MACT
Emergency Generator Exempt. ˃ ≤ 50 HP ˃ Burns gasoline, natural gas, distillate oil, or liquid petroleum gas ˃ Comply with NSPS IIII/JJJJ and RICE MACT ˃ “Emergency engine” definition includes emergency Demand Response (DR)
Non-road Engine Exemption ˃ Definition found at OAC 3745-31- 01(CCCC) ˃ Intended for portable or transportable engines ˃ Follows 40 CFR 89 - Control Of Emissions From New And In-use Nonroad Compression-ignition Engines
Permit-by-rule - Qualifications ˃ PBR for Emergency Engines > 50 HP ˃ Limited to 500 hours per rolling, 12- month period ˃ Use for non-emergency DR prohibited ˃ Fire only gasoline, natural gas, distillate oil, or liquid petroleum gas ˃ Comply with NSPS IIII/JJJJ and RICE MACT
Permit-by-rule - Records ˃ Maintain following records: ˃ Monthly records that contain rolling, 12- month summation of operating hours ˃ Records that show type of fuel used, and %S for distillate ˃ Records of the total time operated in emergency situations ˃ Also “general” obligations in 31-03(C)(1)
Permit-by-Rule - Notification ˃ One-time submission of “Qualifying Criteria” form ˃ Submit to local office ˃ Once submitted, can construct/install ˃ Approval process very quick - <7 days typ. ˃ Approval posted on web ˃ No fee, no expiration
PBR Notification Form
Permit-by-Rule Stats ˃ Emergency Electrical Generators / Pump / Compressor PBR Available since mid-2005 Can elect to have existing PTI revoked and go PBR instead ˃ PBR available at: https://epa.ohio.gov/dapc/newpermits/issued Go to “Active List of Permit-by-Rule” ˃ 8,979 PBRs for this category
Permit-to-Install and Operate ˃ What happens if your engines does not qualify for the PBR? Must obtain a traditional Permit-to-Install and Operate (PTIO) PTIO application requires emission estimates, regulatory applicability, Best Available Technology (BAT) review, air dispersion modeling (if necessary), and appropriate application forms ˃ Agency review time: 1-3 months depending on complexity
Impact of Federal Rule 100-Hour Vacatur ˃ Ohio EPA will update OAC rule 3745-31- 01(NN)(2) to be consistent with federal rules ˃ Chapter 31 Interested Party package in 2019 ˃ State definition of emergency engine still includes emergency DR despite federal vacatur ˃ Engines may be non-emergency in a federal context but would still be emergency engines in the State of Ohio ˃ Such engines remain eligible for PBR coverage
Case Study: Evaluation of Ohio EPA Requirements ˃ Emergency DR Participation? May participate as long as comply with PBR provisions This will change when Ohio EPA revises the state definition of “emergency engine” to exclude emergency DR ˃ Economic DR Participation? Must meet all criteria in OAC 3745-31- 01(NN)(2)(d)(i)-(v) which are functionally identical to 40 CFR 63.6640(f)(4)(ii)(A)-(E), or Requires Permit-to-Install and Operate (PTIO) PTIO terms and conditions crafted on case-by-case basis
Federal Engine Regulations – Brief Overview
Federal Regulations Our Focus ˃ 40 CFR Part 60 Subpart IIII, S t andards of Performance for [New] S t at ionary Compression Ignit ion Int ernal Combust ion Engines (CI ICE NSPS) ˃ 40 CFR Part 60 Subpart JJJJ, S t andards of Performance for [New] S t at ionary S park Ignit ion Int ernal Combust ion Engines (SI ICE NSPS) ˃ 40 CFR Part 63 Subpart ZZZZ, Nat ional Emission S t andards for Hazardous Air Pollut ant s for S t at ionary Reciprocat ing Int ernal Combust ion Engines (RICE NESHAP) ˃ Also, Subpart A for each Part
Summary of Regulated Engine Pollutants NSPS JJJJ NSPS IIII RICE MACT VOC NMHC/HC NO x NO x Formaldehyde and CO (as surrogates for Total CO CO HAPs) PM Criteria Pollutants HAPs
Other Federal Regulations ˃ 40 CFR 89 - New and In-Use Nonroad CI Engines Tiers 1, 2, and 3 ˃ 40 CFR 1039 - New and In-Use Nonroad CI Engines Tier 4 ˃ 40 CFR 90 – Nonroad SI Engines < 19 kW ˃ 40 CFR 1048 – New Nonroad SI Engines > 19 kW ˃ 40 CFR 1054 – New Small Nonroad SI Engines ˃ 40 CFR 94 - Marine CI Engines Tier 2 ˃ 40 CFR 1042 - New and In-use Marine CI Engines Tiers 3 and 4 ˃ 40 CFR 91 - Marine SI Engines ˃ 40 CFR 1045 – Marine SI Engines For more informat ion, e.g., hist ory, about Tier st andards, ht t p:/ / www.dieselnet .com/ st andards
Nonroad and Marine Engines
1068.30, 89.2, 90, 91, 94, 1039, 1042, 1045, 1048, 1054 Nonroad and Marine Engines ˃ Not subject to IIII, JJJJ, & ZZZZ ˃ Marine ICE…an integral part of a marine vessel ˃ Nonroad (or “Non-road”) engine means any ICE that is in or on a piece of equipment that is… self-propelled (may serve other purposes too); or propelled while performing its function; or portable or transportable ♦ Designed to be moved, e.g., on wheels or skids, etc. ♦ And actually is moved routinely ♦ Portability is moot if it remains [ in service ] at a location (building, structure, facility, or installation)… – for more than 12 months…or… – for seasonal sources, for the entire season (3 months or more) for at least 2 years “Mobile” = Onroad + Nonroad + Marine
Temporary Exemption –Two Big Caveats 1. Replacing one temporary engine with another to be used for the same purpose does not restart the 12-month clock The 12-mont h clock applies t o t he locat ion and purpose, not a part icular engine 2. An engine to be used temporarily in place of a stationary engine (e.g., while it is being overhauled) is considered a stationary engine The locat ion and purpose is st at ionary even if it consist s of more t han one engine over t ime
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