Several regulations have expanded the number and type of stationary RICE rules that must comply with federal requirements. These include:
- National Emission Standards for Hazardous Air Pollutants (NESHAP) for RICE to reduce the more toxic compound emissions listed as hazardous air pollutants (HAPS); this is the “RICE NESHAP Rule.”
- New Source Performance Standards (NSPS) — Standards of Performance for Stationary Spark Ignition Internal Combustion Engines for gaseous fuels; this is the “Spark Ignition NSPS Rule.”
- Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, the “Compression Ignition NSPS Rule” is for liquid fuels such as diesel or #2 fuel oil.
The intent is to require the manufacturing and operation of new equipment to meet more stringent emission standards using the best available technology.
Most environmental agencies have RICE criteria that exempt smaller engines from air permitting. However, simply because the equipment is small enough not to require permitting, the RICE rules, as well as other local and state rules, may still apply.
Most engines must follow typical minimum requirements, including installing an hour meter and logging operation hours. Older engines have prescribed requirements at specific frequencies for maintenance, including changing the oil and filter, inspecting the air cleaner or spark plugs, and inspecting hoses and belts. Operators must follow the manufacturer’s recommendations for the maintenance of newer engines.
There are typical requirements as described, but there is no one general approach or rule of thumb. For air regulatory compliance, there are many variables to consider. Many factors can affect what requirements apply. For instance:
- An institutional facility with an engine model year before 2005 may be relieved of any RICE requirements.
- Two engines with the same power rating but built at different times, say 2004 and 2009, will have entirely different requirements.
- Joining a demand response program may change an engine’s purpose from emergency use to non-emergency use, thus triggering the need for add-on control devices to meet differing emission standards.
- Purchasing a brand-new, non-certified engine may lead to high-cost stack testing efforts.
In April, I’ll bring you part II of this discussion, “Considerations for Managing Emergency Generators,” in which I’ll provide a four-step process to evaluate your engine and initiate compliance with the requirements. Between now and then, feel free to reach out.