air quality permitting issues with portable\temporary internal

Air Quality Permitting Issues with Portable\Temporary Internal

Combustion Engines

September 1, 2011

Robert Hammer Air Quality Program Manager ALTUS Environmental, LLC

Examination

Stationary Source Air Permitting Programs

Is a Portable\Temporary Internal Combustion Engine (ICE) a “Stationary Source”?

(Stationary vs. Mobile\Nonroad)

Is a Permit Required?

Robert Hammer, Rocky Mountain AWMA Meeting, September 1, 2011

I texted my wife the other day: “We should open a business of our own. I’d like to open a stationary store.”

She texted me back: “Bad idea! That business would go nowhere. Oh…did you mean stationery? ” 1

1Be aware that this slide, portraying a fictitious event, was reviewed by my wife and received her approval with the understanding that I, Robert Hammer, will be the butt of the joke. I take no responsibility should this humor be shared in any other form.

It’s possible that any of you could be contacted as a witness in my defense, should information to the contrary reach my wife.

A Key Question:

What Does Stationary Mean?

Well…………how’s it being applied?

Presentation Focus is on ICE 1. Air Permitting Overview

2. Stationary ICE

3. Permitting Requirements for Portable\Temporary

Presentation Focus is on ICE

Size Matters

This Presentation Assumes the ICE are Large Enough to Require Permitting

See the Applicable Regulations

1. Air Permitting Overview

Key Factors in Air Permitting

Type of Source

Source Size

Type of Emission

Hours of Operation

Emission Level

State\Local Regulations

Federal Regulations

Air Quality Attainment Status

Source Categories

Portable

Temporary

Fugitive

Stationary

Mobile

Nonroad

Air Permitting Regulations State\Local Specific At least Meet Federal Requirements

Typically Focus on “Stationary” Sources State Regulations Might Not Specify “Stationary

Source” Everywhere May Only Specify “Source”

May Have Unique Requirements for Portable and\or Temporary Sources

Exempts “Mobile” Sources Robert Hammer, Rocky Mountain AWMA Meeting, September 1, 2011

2. Stationary Source

Does “Stationary” Mean Stationary

Stationary

Mobile

Portable\Temporary

According to www.dictionary.com Stationary Standing Still; not Moving.

Having a Fixed Position; not Movable.

Established in One Place; not Itinerant or Migratory.

Remaining in the Same Condition or State; not Changing

“Stationary”: 1990 Clean Air Act Amendments (CAAA)

(z) Stationary Source.— The term “stationary source” means generally any source of an air pollutant except those emissions resulting directly from an internal combustion engine for transportation purposes or from a nonroad engine or nonroad vehicle as defined in section 7550 of this title. (Title III, General Provisions, Section 302, Definitions, paragraph (z) (CAA 302(z)))

Ties Back to: New Source Performance Standards (NSPS) for ICE

National Emission Standards for Hazardous Air Pollutants (NESHAP) for ICE

ICE Federal NSPS and NESHAP

NSPS IIII - Standards of Performance for Stationary Compression ICE

NSPS JJJJ - Standards of Performance for Stationary Spark Ignition ICE

NESHAP ZZZZ – NESHAP for Stationary Reciprocating ICE

Each Applies to “Stationary” not “Mobile”

Connections in ICE NSPS and NESHAP

Stationary

Mobile

Nonroad (40 CFR 1068.30)

“Stationary ICE”: ICE NSPS and NESHAP

Definition in NSPS IIII, NSPS JJJJ, and NESHAP ZZZZ Nearly Identical

40 CFR 60.4219 (NSPS IIII): “Stationary internal combustion engine means any internal combustion engine, except combustion turbines, that converts heat energy into mechanical work and is not mobile. …..”

“Stationary ICE”: ICE NSPS and NESHAP

“Stationary” ICE “Is Not Mobile”

Makes Sense!

So……….

What does “Mobile” Mean?

What Does “Mobile” Mean? According to EPA Website: Mobile Source

Emissions - Past, Present, and Future, Glossary http:www.epa.gov/oms/invntory/overview/definitions.htm

“Mobile Sources: Motor vehicles, engines, and equipment that move, or can be moved, from place to place. Mobile sources include vehicles that operate on roads and highways ("on-road" or "highway" vehicles), as well as nonroad vehicles, engines, and equipment. Examples of Mobile Sources are cars, trucks, buses, earth-moving equipment, lawn and garden power tools, ships, railroad locomotives, and airplanes.”

What Does “Mobile” Mean?

Mobile = Onroad + Nonroad

What Does “Mobile” Mean?

ICE NSPS and NESHAP Don’t Directly Define “Mobile”, but Say that

“Stationary” is Not “Nonroad”

40 CFR 60.4219 (NSPS IIII): “….Stationary ICE differ from mobile ICE in that a stationary internal combustion engine is not a nonroad engine as defined at 40 CFR 1068.30 (excluding paragraph (2)(ii) of that definition), and is not used to propel a motor vehicle or a vehicle used solely for competition. Stationary ICE include reciprocating ICE, rotary ICE, and other ICE, except combustion turbines.”

Similar to CAA Definition of “Stationary”

What Does “Nonroad Engine” Mean? NSPS IIII Reference: 40 CFR 1068.30 says

“Nonroad Engine” Means:

“…portable or transportable, meaning designed to be and capable of being carried or moved from one location to another…”

Unless “…remains or will remain at a location for more than 12 consecutive months or a shorter period of time for an engine located at a seasonal source. …” “…replaces an engine at a location and that is intended to perform the same or similar function as the engine replaced will be included in calculating the consecutive time period….”

ICE NSPS and NESHAP Stationary vs. Mobile vs. Nonroad

Mobile

Nonroad

Stationary YES

Implied

Stipulated

“Stationary”: State\Local

Depends on Their Regulations

But, May Only Reference “Source” not “Stationary Source” in Some Places

References to New Source Review (NSR) will specify “Stationary Source” Major Source

Major Modification

If an ICE Can Be Moved is it “Stationary”?

It’s Possible To Move a “Stationary Source”

Depending on the Circumstances, the Same ICE Could Be Either: Stationary, or

Mobile (Nonroad), or

Change from one to the other

Portable\Temporary ICE Stationary

or Nonroad (reporting\permitting required)

or Mobile\Nonroad (exempt)

Are there State\Local Regulatory Definitions of a “Portable” Source?

Does State\Local Regulatory Definition of “Source” Still Exclude “Nonroad” ICE?

3. Permitting Requirements for Portable\Temporary ICE

Portable\Temporary ICE Permitting Check State\Local Regulations (see examples)

Type Mobile\Nonroad

Why? Replacement?

How Temporary? Length of Time

Seasonal?

Emission Level?

Established Policies for Federal Minor NSR Program? (Other than Nonroad Stationary)

Do Portable\Temporary ICE Need Permits Depending on Factors Such as: State\Local and Federal Jurisdiction

Stationary or Nonroad Designation

Size (hp)

Operating Hours

Emissions Level

Do Portable\Temporary ICE Need Permits

State\Local Permitting Is it Stationary or Nonroad?

Specific to Their Regulations Is your Source a “Stationary Source” According to the

Agency’s Regulations?

Do the Agency’s Regulations Only Require “Stationary Sources” to Obtain Permits?

• Do they exempt Nonroad sources?

Look at Other Exemptions in the Agency’s Regulations?

Do Portable\Temporary ICE Need Permits Federal Major and Minor New Source Review (NSR)

and Title V Permitting Stationary – Possibly (Size, Emission Levels?)

Mobile\Nonroad - No

“Nonroad engines are a category of units/equipment that, under the Clean Air Act Section 302(z), are excluded from the definition of “stationary source,” and, hence, are exempt from stationary source permitting requirements, i.e., Title V (e.g., garden tractors, off-highway mobile cranes and bulldozers).” (U.S. EPA Region IX Letter to the Law Office of Marc Chytilo, December 14, 2001) http://epa.gov/airquality/permits/response/ca-chytilo.pdf

Examples

Is a Permit Required for ICE if Not a “Stationary Source” Defined in IIII/JJJJ/ZZZZ

Colorado (Page 1 of 6)

“Stationary Source” (Reg. 3 Part A I.B.43)

“….Those emissions resulting directly from an internal combustion engine for transportation purposes or from a non-road engine as defined in Section I.B.29. of this Part shall not be considered a stationary source. …”

Air Pollution Emission Notice Regulations Stipulate “Stationary Source” (Reg. 3 Part A I.B.43)

Construction Permit Regulations Stipulate “Stationary Source” (Reg. 3 Part B II.A.1)

Nonroad Engines are not subject to Construction Permit Program under Reg. 3 part B

But……….

“While agreeing that non-road engines should not be treated as stationary sources, the Division expressed a concern that a large aggregation of these engines might result in a violation of ambient air quality standards. To reconcile these conflicting concerns the regulatory revisions create a new state-only non-road engine program for certain non-road engines.”

(Regulation 3, PART G STATEMENTS OF BASIS, SPECIFIC STATUTORY AUTHORITY AND PURPOSE I.DD., Adopted July 18, 2002, Revisions to Regulation Number 3)

Colorado (Page 4 of 6) Nonroad Engine Definition Parallels NSPS IIII and

JJJJ and NESHAP ZZZZ (Reg. 3 Part A I.B.31.a and I.B.31.b)

Nonroad Engine Definition also Stipulates a Permitting Program

(Reg. 3 Part A I.B.31.c and I.B.31.d)

Is a Permit Required for ICE if Not a “Stationary Source” Defined in IIII/JJJJ/ZZZZ Colorado (Page 5 of 6) Nonroad Permitting

Nonroad Engines not Co-located at an Existing Major Source (Reg. 3 Part A I.B.31.c):

• That Have ≥ 1,200 hp and Operate > 4,380 hours per year at the Same Location must then Submit an Air Pollution Emission Notice (APEN) and Pay a Fee

• If NOX ≥ 100 tpy, CO ≥ 100 tpy or SO2 ≥ 40 tpy then Obtain Site-specific Temporary State Only Nonroad Engine Permit

Is a Permit Required for ICE if Not a “Stationary Source” Defined in IIII/JJJJ/ZZZZ Colorado (Page 6 of 6) Nonroad Permitting

Nonroad Engines which are Co-located at an Existing Major Source of NOX and SO2 (Reg. 3 Part A I.B.31.d):

• That Have ≥ 1,200 hp must then Submit an APEN and Pay a Fee

• If NOX ≥ 40 tpy, CO ≥ 100 tpy or SO2 ≥ 40 tpy then Obtain Site-specific Temporary State Only Nonroad Engine Permit

Texas, Arizona, and Washington

No Permit Required for Nonroad ICE

Be Sure to Document that the Source is and REMAINS a “Nonroad” ICE

Arizona Nonroad Engine Checklist Slide 1 of 4

http://www.azdeq.gov/environ/air/permits/download/nonroad.pdf

Example Portable ICE Permitting Programs

SUMMARY Portable\Temporary ICE Could be Either:

Stationary

Nonroad (requiring a permit)

Mobile\Nonroad (No permitting)

Stationary can become Mobile\Nonroad

Mobile\Nonroad can become Stationary

SUMMARY Permitting Programs Vary Mobile\Nonroad could be exempt

Look at State\Local and Federal Regulations

May Depend on:

Size (hp) Operating Hours Emissions

Why? • Replacement?

How Temporary? • Length of Time

Seasonal?

??????????

Robert Hammer (720) 215-4730

rhammer@altusenviro.com www.altusenviro.com

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