Earlier this year, the Environmental Protection Agency (EPA) issued new rules under the Clean Air Act on toxic emissions and in particular, the emission of pollutants by diesel-powered, internal combustion engines. Reciprocating Internal Combustion Engines (RICE) are also known as "compression engines", are the target of this legislation and they are used very widely across the country to generate electricity, for use in power generation plants, industrial facilities, chemical plants and refineries as well as many manufacturing installations. RICE installations are also used to provide emergency back-up power for use by emergency services and for flood prevention and management.
The new rules mean that practically, all engine and associated pump and compressor equipment will require the installation of pollution control measures, and be subjected to additional checks and monitoring procedures. In some instances, engines will be required to burn ultra-low sulfur fuels.
The pollutants which the EPA rules are targeting include carbon monoxide (the primary pollutant which the EPA is seeking to reduce and control). Carbon monoxide has been found by the EPA to be associated closely with pollution by a wide variety of toxic emissions, including but not limited to benzene, formaldehyde, toluene, styrene, naphthalene and many others (primarily organic compounds in nature).
Other toxic pollutants not directly covered by the new rules are also expected to be reduced by the measures being introduced, including the emission of nickel, mercury, selenium, chromium, cadmium, manganese and in particular the emission of sulfur oxides.
The new EPA rules deals with only existing static installations and sub-divides RICE engines into "major" and "area" sources. A major source is any static pollutant source with actual or potential emissions in the range of 10 tons per year or of a single regulated pollutant, or; has the potential or is actually emitting 25 tons or more of any combination of regulated pollutants.
If a static ICE installation does not qualify as a major source it is designated as an area source.
There are several sub-classifications of based on emission limits of both major and area sources and which is based upon engine horsepower.
Engine start-up s may involve the emission of pollutants in excess of the mandated EPA limits, and to accommodate the new limits, the EPA rules only allow for engine start-ups to exceed more than 30 minutes. There are exceptions to this rule.
The new EPA rules also require changes to maintenance schedules, in particular the changes of lubricants and filters as well as certifying inspection of air hoses, belts and cleaners all within specified time periods. A key pillar of the new rules is the need for operators to demonstrate compliance with the new rules.
In summary, the new rules impact all existing, static RICE installations. Ancillary equipment such as pumping equipment will also be affected. Operators using RICE facilities to generate electricity are most affected. There is a comprehensive need to comply with the new rules in fact but also to demonstrate compliance which means improving or establishing documentation procedures as well as establishing appropriate maintenance and inspection scheduling.
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