What Are My Compliance Requirements?
January 8, 2020 @ 3:00 pm - 3:45 pm
Let’s cover requirements for Reciprocating Internal Combustion Engine (RICE)?
The compliance requirements listed in 40 CFR 63 Subpart ZZZZ for RICE’s are quite onerous. Many companies have minor source permits with area source generators that have compliance requirements just like major sources. A RICE may not be started up every month or it might be started up just for maintenance purposes like recirculating oil. US EPA developed some guidance and memo’s concerning the management of the compliance risks.
For example, facilities are not required to start the RICE for the SOLE purpose of recording the pressure drop across the catalyst. US EPA requires recording the periods the RICE is not operating. US EPA has developed other options to manage compliance risks of the facility’s particular RICE. Many facilities us their RICE for different purposes that do not fit within the compliance requirements in 40 CFR 63 Subpart ZZZZ. In most cases the actual intent of whether a generator or an emergency generator does not matter. Another key component to remember is recording non-operating events is just as important as recording operating events. Formalizing the actual use of the generator along with the applicable alternate compliance activities should be formalized in the required Monitoring Plan.
In order to use the US EPA guidance and memo solutions, it is important to discuss how you operate the RICE to manage air compliance risk.
About the Presenter: Jeffrey Miller
Jeffrey serves as Senior Regulatory Expert for Compliance Services for August Mack. He has more than 35 years of experience in Wastewater treatment, RCRA site closures, and regulatory compliance. Mr. Miller received a Bachelor of Science in petroleum engineering and a Master of Science in petroleum engineering. He is a registered Professional Engineer in several states. Jeff can be reached at firstname.lastname@example.org.