What are the costs for EPA RICE NESHAP Diesel Generator Compliance?

Cat generator EPA RICE NESHAP compliance service

After completing 117 EPA RICE NESHAP diesel generator compliance upgrades, I have a pretty good feel for what a “typical” turn-key upgrade project will range in cost for generators of any make/model/size or configuration.

1st – are you certain your generator requires upgrading? I’ve run into multiple situations where the generator owner was misinformed and was about to upgrade engines that were already compliant.

Download this easy to follow Diesel Generator EPA Compliance Checklist to confirm if your engine is affected by these regulations.

“Typical” compliance upgrade cost ranges

200kW – 350kW generators (with engines under 500hp) $18,000 – $23,000

400kW – 600kW generators $26,000 – $32,000

750kW – 900kW generators $28,000 – $36,000

1,000kw to 1,300kW generators $34,000 – $40,000

1,500kW to 2,000kW generators $40,000 – $70,000

What does “typical” mean?

RICE NESHAP diesel generator compliance upgrades require installing a diesel oxidation catalyst. Most commonly, we’ll be replacing the engine’s exhaust silencer (muffler) with a new silencer that incorporates a diesel oxidation catalyst. What I describe as “typical” is a generator installation where the exhaust silencer is visible and accessible from outdoors. Like what’s pictured above.

What can increase the costs?

  • Existing exhaust silencer is located indoors or inside a generator enclosure
  • Upgrading to Stainless Steel vs. painted Carbon Steel.
  • Replacing silencer insulation
  • Access limitations – large silencers can weigh #1,500 or more!
  • Over-designed solution
  • Screen walls
  • Temporary backup generation*

What needs to be included?

  • Installation of a Diesel Oxidation Catalyst sized to reduce CO (Carbon Monoxide) emissions by a minimum of 70% or reduce CO to below 23ppm (>500hp) or 49ppm (<500hp)
  • Install a non-resettable hour meter to record annual run time, if needed.
  • Complete an EPA approved “Performance Test” to demonstrate compliance with the new regulations within 180 days of the formal rule notification May 2nd 2016
    • Note: this test is only done after the catalyst has been installed. There is no requirement to conduct an emissions pre-test.
  • Electronically monitor the Catalyst 24/7/365 (all engines >500hp)
  • Install a crankcase ventilation system
  • Use Ultra Low Sulfur Fuel in diesel engines – NOTE: today only Ultra Low Sulfur Fuel is available.
  • Keep appropriate records of fuel consumption and demonstrate required annual maintenance
  • Maintain a Site Specific Monitoring Plan – engines >500HP. Many providers miss providing this, which could be trouble. Your Site Specific Monitoring Plan will be the first document requested by the EPA, when your site is audited.
  • Make regular notifications to the Federal EPA and DEP (Florida Department of Environmental Protection)

*Do I need a backup generator during the project?

The majority (around 95%) of the 117 upgrade projects I’ve managed did not include a temporary backup generator… and there’s a good reason why; for many projects temporary backup generator can increases the length of time there’s no backup power available.

Yes, you read that correctly! If your concern is to minimise the amount of time your facility is without a backup generator, after consulting with your contractor, you may choose to not use a temporary generator during the project. Here’s why…

Temporary generators can take up to three or four hours to connect. The process often requires using the same electrical connections used by the existing generator. After taking your existing generator out of service, those connections are removed and the temporary connections are made.

During that 4 hour connection window, your facility has no backup available and there’s no quick way to revert back. Then consider the whole process needs to be reversed to disconnect the temporary. All totaled, you may be looking at 8 or more hours of exposure without any generator emergency backup.

During one of our typical projects, we may only need 2-3 hours to perform the work that requires the generator be out of service.

So, how can we help?

John Macgowan

Jmacgowan@hillyork.com or 727-565-2137

 

Revised EPA RICE NESHAP Rules Now Affect Duke Energy Customers

EPA RICE NESHAP revised rule affecting Duke Energy demand response program
You can click the image to download a copy of this April 15th letter.

The EPA regulations known as RICE NESHAP, which allowed emergency rated diesel generators to participate in Duke Energy’s demand response programs for up to 100 hours, changed on Monday May 2nd, 2016.

The revised regulation now requires RICE NESHAP non-emergency rated generators for program participation.

Participating generator owners, served by Duke Energy, will have until December 31st 2016 to certify that their engines are RICE NESHAP non-emergency compliant, or lose the substantial savings offered for participation.

You can download a copy of Duke Energy’s April 19th rate tariff revision request here.

Is your diesel generator affected?

There are multiple factors that need to be considered; date of engine manufacture and/or installation, horsepower, Tier Level and location type. Here’s an easy to follow Diesel Generator EPA Compliance Checklist  we created to help our customers throughout Florida.

Would you’d prefer to have the peace of mind that comes from having a trusted expert conduct a no obligation compliance review of your generators?

Schedule a site visit by contacting John Macgowan at 727-565-2137 or by email jmacgowan@hillyork.com

These regulations are very confusing = it pays to have a second opinion. We recently saved the City of Port St. Lucie $110,000 after discovering that they had been misinformed by their generator service company. Our precise knowledge of the RICE NESHAP regulations identified that the city’s generators did not require compliance upgrades. You can download a copy of the ‘Thank You’ letter we received here.

Get a second opinion on rice neshap compliance

 

Is my diesel generator certified as RICE NESHAP compliant?

Diesel Engine EPA Emissions Regulations for RICE NESHAP

As a local Florida contractor of EPA RICE NESHAP compliance upgrades for diesel generators, we are often asked; how can I know if my diesel generator meets the emissions levels required to participate in a load management program that requires a Non-Emergency rated engine?

4/22/16 NOTE: The previous EPA exemption enjoyed by Duke Energy Load Control customers is scheduled to end on Monday May 2nd 2016.

Owners of affected engines will have until December 31st 2016 to demonstrate compliance – or forfeit your annual savings by leaving the program.

Contact John Macgowan to understand how this regulation change will affect you and to schedule a no cost RICE NESHAP compliance evaluation of your generators 727-432-5335 or by email jmmacgowan@gmail.com.

If you’re generator does require compliance upgrades, we can provide a cost effective, turn-key proposal shortly after visiting your facility. 

First, a quick explanation of how the EPA classifies the use of diesel electrical generators…

  • Emergency Standby Generators are those used only for emergencies; i.e. lights out, when the utility has failed and can not provide power to your building. These generators can be small (only supporting critical/life-safety loads) or large enough to power the entire facility.
  • Non-Emergency Generators can be used during emergencies, however they can also be used to provide power when there’s a perfectly good utility electrical feed from your power company. These generators are typically large enough to power all the loads present in the building.

Examples of Non-Emergency use are…

  • Regular monthly exercising and maintenance
  • Participation in a load/demand management or interruptible power program with your utility that brings financial gain.
    • Note that there are two categories of utility programs. Each affects owners differently. A full explanation is available in our compliance checklist. UPDATE: this has been changed and there’s now only one category – all programs will require non-emergency engines for participation.
  • Islanding (running your generator proactively when there’s an approaching storm) to prevent any disruption in electrical service.
  • Peak Shaving
  • Remote location operation – when there is no electrical utility service available.

Duke Energy’s new Schedule B Non-Emergency Standby Generation rate (download the tariff here) is an example of an electrical utility that offers different discount rates, based on the type/level of EPA emissions certification of your engine.

UPDATE: Duke Energy has published a revision to their Rate Tariff (download the revised tariff here) that identifies the Dec 31st 2016 deadline for compliance.

You can download the complete (as of Nov 2015) EPA regulations here.

Download our easy to follow, diesel generator compliance checklist – here.

 

What are the reporting EPA requirements for my diesel generator in Florida?

Initial Rice neshap generator compliance emissions testing
EPA generator compliance can be complicated… with the wrong contractor.

We get a lot of questions about your future reporting and retesting requirements under EPA 40 CFR part 63 ZZZZ – commonly know as RICE NESHAP, from diesel generator owners.

Typically this information would be provided by your compliance contractor, as part of the required Site-Specific Monitoring Plan – NOTE: many aren’t aware of the requirements for this… we are and can provide you with this information if you don’t have it.

 

Reporting is only required for RICE (diesel engines) over 500HP/ >200kW generators. RICE between 300 and 499HP only requires the initial compliance Performance test – no additional reporting or testing 🙂

Here are the regulations verbatim from the EPA’s website:

4.0 Reporting and Recordkeeping Requirements

References: 40 CFR 63.6650

40 CFR 63.6655

40 CFR 63.6660

Table 7 to Subpart ZZZZ of Part 63 (40 CFR 63, subpart ZZZZ, Table 7)

4.1 General Information

Owners and operators must submit the following reports to the permitting authority by the dates outlined below. Records must be maintained as outlined to demonstrate compliance.
4.2 Initial Notification of Applicability

RICE NESHAP requires facility owners or operators to report to their regional EPA office if their facility falls under the provisions stated in 40 CFR Part 63 Subpart ZZZZ (applies to both CI and SI RICE).
This notification should have been submitted in writing by February 16, 2011 for spark-ignited engines and / or August 31, 2010 for compression-ignition engines, or 120 days after you become subject to the relevant standard.
Initial notification is the responsibility of the owner/operator of the source.
A sample form is included in Appendix A.

4.3 Semi-Annual Compliance Reports (For RICE operated 100 hours per year or more)

Semi-Annual Report I
Reporting period covers the first calendar half (January 1 – June 30)
Postmarked or delivered to the permitting authority no later than July 31

Semi-Annual Report II
Reporting period covers the second calendar half (July 1 – December 31)
Postmarked or delivered to the permitting authority no later than January 31

Note: If you already submit semi-annual reports as part of a compliance program with your current air quality permit, you may submit the first and subsequent semi-annual compliance reports according to the dates established by the permitting authority instead of those outlined above.

4.4 Annual Compliance Report (For RICE operated less than 100 hours per year)

Annual Compliance Report
Reporting period covers the entire calendar year (January 1 – December 31)
Postmarked or delivered to the permitting authority no later than January 31

Note: If you experienced a deviation from any emission limitation or operating limitation, a period during which the CPMS was out-of-control, the compliance report shall be submitted semiannually.

4.2 Minimum Requirements of a Compliance Report

Company name and address.
Statement by a responsible official, with that official’s name, title, and signature, certifying the accuracy of the content of the report.
Date of report and beginning and ending dates of the reporting period.
If you had a malfunction during the reporting period, the compliance report must include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report must also include a description of actions taken by an owner or operator during a malfunction of an affected source to minimize emissions, including actions taken to correct a malfunction. For more information, please refer to 40 CFR 63.6650.

If there are no deviations from any emission or operating limitations that apply to you, a statement that there were no deviations from the emission or operating limitations during the reporting period.

If there were no periods during which the continuous monitoring system (CMS), was out-of-control, a statement that there were no periods during which the CMS was out-of-control during the reporting period.

4.6 Recordkeeping Requirements

Maintain a copy of each notification and report that was submitted to comply with this subpart, including all documentation supporting any Initial Notification or Notification of Compliance Status.

Maintain records of performance tests and performance evaluations

Maintain and generate records of all required maintenance performed on the engine generator, air pollution control and monitoring equipment, including all calibration checks and adjustments. Examples of equipment include:
Stationary internal combustion engine, including on-board emission control equipment (if any)
Oxidation catalyst
Continuous parameter monitoring system or continuous emission monitoring system
Open or closed crankcase ventilation systems, including element replacement

Maintain records of the occurrence and duration of each malfunction (including inoperative or out-of-control periods) of operation on the air pollution control and monitoring equipment.

Maintain records of actions taken during periods of malfunction to minimize emissions, including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation.

Maintain records of all required measurements needed to demonstrate compliance with a relevant standard (including, but not limited to, averages of CMS data, raw performance testing measurements, and raw performance evaluation measurements, that support data that the source is required to report).

Purchase and maintain records that indicate ultra low sulfur diesel meeting the following requirements is burned at the facility (For existing, non-emergency, compression ignition engines greater than 300 horsepower).

4.7 Record Retention

Records must be kept for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record.

Records must be in a form suitable and readily available for expeditious review upon request by the permitting authority. A printed ‘hard copy’ or electronic form is acceptable.

NOTE: Your Site-Specific Monitoring Plan will be the first thing an EPA compliance officer requests, when doing an audit of your diesel engine generator. So you can understand how critical it is that this plan is maintained and up-to-date at all times.

More questions? Call John Macgowan 727-432-5335