BAAQMD Air Quality Update August 2014

August 1, 2014 – BAAQMD
GET YOUR ZZZZ’S: Rest Easier
Understanding 40 CFR 63, Subpart
ZZZZ: NESHAP for Reciprocating
Internal Combustion Engines
The Code of Federal Regulations (CFR)
Title 40 Part 63, Subpart ZZZZ National
Emission Standard for Hazardous Air
Pollutants (NESHAP) is a federal regulation consisting of a set of standards for
reciprocating internal combustion engines (RICEs) that were developed over
several years. The first rule regulates
RICEs with output ratings >500 hp, only at facilities designated as Major
Sources of Hazardous Air Pollutants
(HAPs). The second rule incorporated
RICEs with ratings ≤500 hp at facilities
designated as Major Sources, as well as
facilities designated as Area Sources
with RICEs >500 hp. The last two rules
regulate RICEs ≤500 hp at Area
Sources. A Major Source of HAPs is a
facility with >10 tpy of any single HAP
or >25 tpy of combined HAPs, and an
Area Source is a facility that isn’t a Major Source (i.e., <10 tpy of any single
HAP and <25 tpy of combined HAPs).
If facilities operate a RICE and are in
compliance with Bay Area Air Quality
Management District (BAAQMD)
Regulation 9 Rule 8 for Stationary Internal Combustion Engines, the engine
may be in compliance with the requirements in Subpart ZZZZ, but there
can be some gaps. Some engines have
Subpart ZZZZ emission limits that are
lower than those required in Regulation
9-8, and operators should be careful to
comply with both Subpart ZZZZ and
Regulation 9-8, as they apply.
For example, a non-emergency, nonblack-start stationary diesel RICE between 100 and 300 hp located at a Major
Source of HAP emissions is required to
limit CO to 230 ppmvd or less at 15%
O2. A non-emergency, non-black-start
stationary diesel RICE between 300 and
500 hp located at an Area Source of
HAP emissions is required to limit CO
to 49 ppmvd or less at 15% O2. In both
instances, the limit for an equivalent
engine in Regulation 9-8 is higher (more
than six times higher, in the latter case).
Subpart ZZZZ requires existing nonemergency, non-black-start stationary
four-stroke rich-burn RICEs between
100 and 500 hp located at a Major
Source to limit emissions of formaldehyde to 10.3 ppmvd or less at 15% O2.
Regulation 9-8 does not have formaldehyde limits for existing RICEs.
For RICEs subject to federal emission
limits, an initial performance test may
be required to show compliance with
the limits. In some situations, a petition
to the administrator may be needed before testing to establish operational limitations during the initial performance
test, for continuous monitoring, or for
approval of no operating limitations.
In addition to the differences in emission limits, most subject RICEs, including emergency standby engines,
have operational and maintenance requirements, along with recordkeeping,
which Regulation 9-8 does not have.
For emergency diesel engines, the operational limits include minimizing
the engine’s time spent at idle and the
engine’s startup time to a period needed for appropriate and safe loading of
the engine, not to exceed 30 minutes.
Maintenance requirements include
changing the oil and filter every 500
hours or annually, inspecting the air
cleaner every 1,000 hours or annually,
and replacing as necessary and inspecting all hoses and belts every 500
hours or annually. In lieu of periodic
oil changing, the operator may utilize
an oil analysis program. Recordkeeping involves recording the maintenance events.
Air Quality Tip
For an Authority to Construct (A/C) that
requires initial source testing, the source
test is to be conducted and completed
within a certain time period (startup
period), as stated in the permit condition. For the BAAQMD, the source testing guideline states that the startup time
period starts after the equipment has
commenced any operation. Sources
requiring a startup period longer than
allowed by the A/C should contact the
District to obtain approval for extension.
Upcoming Training Offered by
Yorke Engineering:
 California Multi-Media Environmental Regulations: Permitting, Compliance, and Reporting Seminar:
September 24 – September 25, 2014
 Bay Area Air Quality Regulations,
Permitting, and Compliance Seminar:
October 1 – October 2, 2014
Upcoming Due Dates for 2014/2015
 CARB On-Road HD DV* Reporting
for “Work Truck Phase-In”
Compliance Option ...............7/31/2014
 CARB GHG Verification .......9/2/2014
 CARB GHG Cap-and-Trade Annual
Compliance Surrender ..........11/3/2014
 CARB On-Road HD DV* Reporting
for Flexibility Options ..........1/31/2015
 Semi-Annual Title V
Report .......................... Semi-Annually
 Annual Title V Compliance
Certification ........................... Annually
 Title V – Application for Permit Renewal – Due 180 Days Prior to Permit
*Heavy-Duty Diesel Vehicle
The purpose of Regulation 9 Rule 7 is
to limit nitrogen oxides (NOx) and
carbon monoxide (CO) from industrial, institutional, and commercial boilers, steam generators, and process
The rule affects boilers,
steam generators, and process heaters
with a rated heat input of 1 million
British thermal units per hour (MMBtu/hr) or greater. Boilers, steam generators, and process heaters with a
rated heat input of 2 MMBtu/hr or less
are exempt from the rule if fired exclusively with natural gas, liquefied
petroleum gas, or any combination of
the two. Other exemptions and limited exemptions are provided in Sections 110 through 117 of the rule.
The table below provides the final
emission limits and the dates these
limits are effective.
Once an effective date is established,
the initial demonstration of compliance is required within 1 year of the
effective date. Aside from initial
demonstration of compliance, periodic
testing is also required, in most cases
once per calendar year, except for
units firing non-gaseous fuels. These
units require testing within 60 days of
the first use of non-gaseous fuel in any
calendar year in which non-gaseous
fuel is used (and each calendar year
thereafter). Units with a rated heat
input under 10 MMBtu/hr may be
tested with a portable analyzer.
Records are required to be maintained
for a minimum of 24 months for initial
and periodic testing, tune-ups required
under the low fuel usage limited exemption, non-gaseous fuel use during
a natural gas curtailment or testing,
and operating hours for units fired or
co-fired by digester or landfill gas.
>2 to 5
>5 to <10
10 to <20
20 or more, loadfollowing unit
20 to <75
75 or more
landfill or
1 or more
Facilities that elect to use an effective
date that is based on the original manufacture date of the device (last column in the table below) need to have
the original manufacture date of the
device on the original manufacturer’s
identification, a rating plate permanently fixed to the device, or the same
information on a copy of the manufacturer’s invoice.
For multi-unit facilities, compliance/effective dates are spread over 2
years, based on the percentage of devices that are required to be in compliance. The last effective date for 100%
compliance for multi-unit facilities is
January 1, 2015.
Yorke Engineering, LLC specializes in air quality and environmental consulting
for stationary and mobile sources, including dispersion modeling, health risk
assessments, permitting, emission inventories, air quality compliance systems,
etc. Yorke Engineering has assisted over 400 customers, including a wide variety of industrial facilities and government organizations throughout California.
Regulation 9 Rule 7 Final Emission Limits
Rated Heat
For boilers with heat input greater than
2 MMBtu/hr but less than 10 MMBtu/hr, which are not required to hold a
District Permit to Operate, a registration with the District is required.
NOx Limit
(ppmv, dry
at 3% O2)
CO Limit
(ppmv, dry
at 3% O2)
Landfill or
1 or more
1 or more
average limit
At Least 33%
of Devices at a
Single Facility
Regulation 9 Rule 7 Compliance Schedule
By Percentage / Size
By Original Manufacture Date, Plus
At Least 66% of
100% of Devices
10 Years1 If ManuDevices at a Single
at a Single
factured Prior To:
1/1/2013 for
devices with
rated input <10
7/30/2008 for
devices with
rated input >10
1/1/2014 for
devices with rated
input <10 MMBtu/hr; 7/30/2008 for
devices with rated
input >10 MMBtu/hr, which may
not be grouped
1/1/2015 for
devices with rated
input <10 MMBtu/hr; 7/30/2008 for
devices with rated
input >10 MMBtu/hr, which may
not be grouped
1. If this is later than the normal effective date.
2. Effective date is 5 years after the original manufacture date, if this is later than the effective date.
Same as above for
respective rated heat