Machinery Lubrication magazine published by Noria Corporation
Issue link: https://www.e-digitaleditions.com/i/258778
24 January - February 2014 | www.machinerylubrication.com including existing engines constructed before June 12, 2006; new engines constructed on or after June 12, 2006; and reconstructed engines in which reconstruction began on or after June 12, 2006. Note the qualifications of "major source" and "HAP." The term "major source" has different definitions and thresholds based on whether it is referencing a hazardous air pollutant (HAP), criteria air pollutant (CAP) or greenhouse gas (GHG). The definition of major source for this rule refers to the facility-wide emission of HAPs where the stationary engine is located. A facility is considered a major source if any single HAP exceeds 10 tons per year or if the total of all facility HAPs exceeds 25 tons per year. Everything else is considered an "area source." Emissions standards under the rule target HAPs but ulti- mately cannot be separated from other EPA regulatory drivers that also impact stationary reciprocating internal combustion engines. As an example, the rule has several trigger conditions that directly reference specific New Source Performance Stan- dards (NSPS) for stationary engines and can actually meet an engine's NESHAP ZZZZ requirements by complying with the applicable NSPS standard. Figures 1 and 2 show the results of an applicability determi- nation for both types of engines (CI and SI RICE). The examples were at "area source" facilities in Texas with 2013 and 2002 model-year engines rated at 1,000 horsepower. Notice that the 2013 model-year engine technically triggers NESHAP but has no NESHAP requirements; it satisfies the NESHAP requirements by complying with the applicable NSPS rule. In both the CI and SI examples, stationary engines installed in 2002 trigger almost all of the possible NESHAP ZZZZ require- ments, with the exception of operations and maintenance practices for the CI RICE as well as work practices, operations and maintenance for the SI RICE. If either of the CI or SI examples from 2002 were below 500 horsepower, then only the operations, maintenance and work practices would apply. Figure 3 shows an example of an SI RICE of the same 2002 model year, with one engine above 500 horsepower and the other below 500 horse- power to demonstrate the requirements mentioned previously. "Work practices" is unique to this rule and can identify a specific time interval required for changing the engine oil. While this might be favorable to having emissions limits and testing requirements, the interval may be well below the historical oil change frequency that has been followed. The exact oil change interval specified depends on the engine type and other factors, but in this example, it is 1,440 hours. If this was a non-emer- gency engine with an annual runtime of approximately 7,000 hours, an oil change at 1,440 hours would hinder operations, since such engines routinely reach 4,000 hours or more before the oil is changed. Following public comment on this portion of the proposed rule, the EPA added an option allowing the implementation of oil analysis to extend oil change frequencies. Hence, for those engines that require periodic oil changes, the schedule for changing engine oil can be extended if the oil is part of an oil analysis program. However, oil analysis must be performed at the same frequency as specified for oil changes. An oil analysis program must include the following parame- ters in order to qualify: base number (CI RICE), acid number (SI RICE), viscosity and percent water content. If certain limits are met during the analysis, then the owner/operator is not required to change the oil. However, if any of the limits are exceeded, the oil must be changed within two business days. oIl ChANGes Figure 2. These results are from an applicability analysis for an SI RICE or natural gas engine placed into service in 2002 versus 2013. (Courtesy of step2compliance) Figure 3. In this analysis, two SI RICE or natural gas engines were placed into service in 2002, with one engine above 500 horsepower and one engine below 500 hp. (Courtesy of step2compliance)