Don’t Get Caught Sleeping – The RICE MACT Compliance Date Will Be Here Before You Know It
Posted: April 19th, 2012Author: All4 Staff
Are you subject to the RICE MACT? No? Are you sure? The term “RICE MACT” refers to the National Emission Standards for Stationary Reciprocating Internal Combustion Engines (RICE), codified at 40 CFR Part 63, Subpart ZZZZ. The RICE MACT rules apply to any piece of equipment driven by a stationary RICE located at a major source or area source of hazardous air pollutants (HAP). The rule was originally promulgated on June 15, 2004, and applied only to RICE rated at over 500 brake horsepower (bhp) that were located at major sources of HAP emissions. Since then, the RICE MACT has been revised two (2) times: Once in January 2008, and again in March 2010. With each revision, the U.S. EPA has cast their net a little bit wider, capturing more and more RICE units. Now, the RICE MACT potentially applies to any stationary reciprocating internal combustion engine, regardless of size, located at both major and area sources of HAP emissions. There are some exemptions, of course.
First of all, the RICE MACT only applies to stationary RICE. Stationary RICE differ from mobile RICE because a stationary RICE is not a non-road engine as defined at 40 CFR §1063.30, and it is not used to propel a motor vehicle. Stationary RICE are used in association with generators, fire pumps, water pumps, black start motors, compressors, etc.
The RICE MACT is a rule that takes time for even an expert to navigate. There is nothing cut-and-dry about it. But before you even sit down with this rule to try to steer through its many twists and turns, you will need to know some things about your facility and your RICE:
- Major Source Status
- New, Reconstructed, or Existing RICE
- Manufacture Date, Construction Date, Rated Capacity
- Fuel Type and Engine Type
Is your facility a major source or area source of HAP emissions? A major source is a plant site that emits or has the potential to emit any single HAP at a rate of 10 tons per year or any combination of HAP at a rate of 25 tons per year or more. An area source is any plant site that is not classified as a major source of HAP. When determining your major source status, it is important to keep in mind that major source status is determined based on your plant’s potential to emit, a term that is defined by U.S. EPA. Unless otherwise restricted by one or more federally enforceable permit conditions, you must assume that your plant operates 8,760 hr/yr at maximum capacity while processing your worst-case HAP-emitting material and/or while firing your worst-case HAP emitting fuel when determining your potential to emit. Even though your facility may actually emit very small amounts of HAP, your facility’s potential to emit HAP could be above major source thresholds.
New, Reconstructed, or Existing RICE
Remember the days when determining whether your emissions unit was “new” or “existing” was as simple as knowing only one calendar date? As stated earlier, there is nothing simple about the RICE MACT. Welcome to the entrance of the RICE MACT maze:
- Existing Stationary RICE means the following:
- A stationary RICE with a site rating of more than 500 brake horsepower located at a major source of HAP emissions if construction or reconstruction commenced before December 19, 2002.
- A stationary RICE with a site rating of less than or equal to 500 brake horsepower located at a major source of HAP emissions and any stationary RICE located at an area source of HAP emissions if construction or reconstruction commenced before June 12, 2006.
- New Stationary RICE means the following:
- A stationary RICE with a site rating of more than 500 brake horsepower located at a major source of HAP emissions if construction was commenced on or after December 19, 2002.
- A stationary RICE with a site rating of equal to or less than 500 brake horsepower located at a major source of HAP emissions and any stationary RICE located at an area source of HAP emissions if construction commenced on or after June 12, 2006.
- Reconstructed Stationary RICE means the following:
- A stationary RICE with a site rating of more than 500 brake horsepower located at a major source of HAP emissions if it meets the definition of reconstruction in §63.2 and reconstruction commenced on or after December 19, 2002.
- A stationary RICE with a site rating of equal to or less than 500 brake horsepower located at a major source of HAP emissions and any stationary RICE located at an area source of HAP emissions if it meets the definition of reconstruction in §63.2 and reconstruction commenced on or after June 12, 2006.
The month and year in which the engine was produced in the factory is the engine’s Manufacture Date. The date that the engine was purchased and/or installed at your facility is the engine’s Construction Date. The Rated Capacity of the engine refers to its maximum brake horsepower output (bhp). Determining an engine’s rated capacity could be as simple as reading a number off of a name plate, or it could require some investigation on your part using manufacturer literature that you have onsite or obtained from the manufacturer’s website. Many times, a call to the manufacturer may yield the answers you seek.
Fuel Type and Engine Type
Many engines are designed to fire gasoline, diesel, propane, or natural gas. But there are other, less traditional fuels that are fired in some engines. For example, some engines are designed to fire landfill gas, or a combination of fuels such as landfill gas and natural gas. Knowing which fuel(s) your engine is capable of firing is an important clue to understanding how your engine fires its fuel. Is your engine a compression ignition (CI) or spark ignition (SI) engine? If it is an SI engine, is the engine a four (4) stroke rich burn (4SRB) engine, four (4) stroke lean burn engine (4SLB), or a two (2) stroke lean burn (2SLB) engine? Each of these terms (4SRB, 4SLB, and 2SLB) is defined in the rule. Determining whether an SI engine is 4SRB, 4SLB, or 2SLB oftentimes can be determined from manufacturer literature. However, you may end up having to contact the engine manufacturer.
Once you know all there is to know about your RICE, you can finally sit down, crack open the rule, and begin to work your way through this regulation. If you determine that you do have an existing RICE that is subject to an emission limitation and/or work practice standard, your RICE’s compliance date could be June 17, 2007, May 3, 2013, or October 19, 2013, depending upon your major source status and the engine information.
Are you completely confused yet? Don’t worry, you are not alone. ALL4 will be conducting a webinar on June 6, 2012 to help shed some more light on this rule. Stay tuned to our website for information on how to sign up for the RICE webinar.