The RICE MACT Amendments Remind Me Of…Finding $20 in an Old Pair of Pants

What does finding $20 in an old pair of pants have to do with air quality?  Good question.  Nothing really, except that U.S. EPA’s recent revision of the RICE MACT (i.e., 40 CFR Part 63, Subpart ZZZZ), boosting the allowable time that emergency RICE can operate under a demand response program from 60 to 100 hours per year, reminds me somewhat of finding a crisp twenty in an old pair of slacks.  Area sources that own large emergency stationary RICE, but only operate those RICE infrequently for purposes of exercise and maintenance, can use those emergency RICE as a source of relatively passive revenue if they take part in a peak shaving or a demand response program like Pennsylvania-New Jersey-Maryland’s (PJM’s) Interconnection.  Truth be told operators could have done this very thing prior to the recent revisions to the RICE MACT, but the “margins” are less restrictive now.  Previously, facilities operating emergency stationary RICE had to limit nonemergency operation to 50 hours per year and maintenance and testing operation to 50 hours per year for a combined total of 100 hours per year of nonemergency operation. Exceeding the nonemergency operating hour limits could have cost such emergency RICE their status as “emergency” RICE, making them subject to more stringent requirements under the RICE MACT.  Facilities must still operate their emergency stationary RICE for less than 100 hours of nonemergency operation per year to maintain their status as emergency RICE. However, now facilities have more flexibility to operate their RICE for nonemergency purposes.  Facilities may now perform their maintenance and testing in as short a time as possible and then use the hours remaining in their 100 hour nonemergency operating “bank” toward a demand response program.  Truly emergency operation is not affected by this and facilities can still operate their emergency RICE as much as needed for emergency purposes (barring any state specific limitations, of course).  Looking at their RICE’s historic maintenance and readiness testing operating hours, facilities may find with the recent RICE MACT revisions that there is potential for revenue where there was none before, like that twenty in my old pants.