1. College & University Hazardous Material Management Conference Challenges with Air Quality Compliance in a Campus Setting August 10, 2015 Chloe Reece, Managing Consultant

2. Summary of Topics ˃ Overview of Trinity ˃ Engine Regulations 101 ˃ Introduction to Ozone Depleting Substances ˃ Regulatory Requirements for Boilers

3. Los Angeles

4. Engine Regulations 101

5. Federal Regulations for Internal Combustion Engines (ICE) ˃ 40 CFR 60, Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (NSPS IIII)  Regulates certain pollutants from newer Compression Ignition (CI) ICE – typically diesel-fired engines ˃ 40 CFR 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (NSPS JJJJ)  Regulates certain pollutants from newer Spark Ignition (SI) ICE – typically gasoline or natural gas fired engines ˃ 40 CFR 63, Subpart ZZZZ – National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE MACT)  Regulates Hazardous Air Pollutants (HAPs) from Reciprocating ICE (RICE) – either fuel type

6. What Engines Are Covered? ˃ Stationary engines only  Not mobile source engines ˃ Generally, not portable or temporary engines  Be careful! See upcoming slides ˃ Variety of fuel types, rated capacities, ages, and functions  Larger engines at campus power plant or emergency generator in basement of an academic building ˃ Not combustion turbines  Those have their own USEPA regulations

7. Guidance on Portable Engines ˃ “Nonroad” engines are excluded from the definition of “stationary” and are therefore not subject to IIII, JJJJ, & ZZZZ ˃ Nonroad engine means any ICE that is in or on a piece of equipment that is…  self-propelled; or  propelled while performing its function; or  portable or transportable ♦ On wheels or skids; designed to be moved ♦ Portability is moot if it remains at a location (building, structure, facility, or installation) for more than 12 months

8. What About Temporary Units? ˃ No exemption for temporary units, but a temporary engine used for a temporary purpose is not a “stationary engine” if it does not remain in the location for more than 12 months ˃ Two big caveats:  Replacing one temporary engine with another to be used for the same purpose does not restart the 12-month clock ♦ The 12-month clock applies to the location and purpose, not a particular engine  An engine to be used temporarily in place of a stationary engine (e.g., while it is being overhauled) is considered a stationary engine ♦ The location and purpose is stationary even if it consists of more than one engine over time

9. What About Emergency Units? ˃ Subject to the USEPA rules, but they generally have less stringent requirements ˃ Emergency = operated to provide electrical power or mechanical work during an emergency situation  Power generation during normal supply interruptions  Pumping water for fire suppression or flood control ˃ Be careful of strict operational limitations

10. What Are the Use Restrictions? ˃ No time limit on true emergency operation ˃ 100 hrs/yr of non-emergency operation for:  Maintenance checks and readiness testing ˃ 50 hrs/yr of the 100 hrs/yr can be used for…  Any situation as long as there is no financial arrangement ˃ Other options for emergency engine use also exist in the federal rules  Very specific instances – must read details  Caution! – Some states don’t allow some or all of these

11. What if you operate an emergency engine more than the allowable non-emergency hours? ˃ Based on USEPA’s April 2013 Q&A document, it is then forever a non- emergency engine ˃ Based on USEPA’s response to comments published with the latest rule amendments, a decision will be made on a “case-by-case” basis

12. Can you use emergency engines to prevent an emergency? ˃ A facility uses pumps during heavy rains to prevent flooding ˃ EPA says NO …, the operation counts towards the allowable 50 hours of non- emergency operation ˃ Same determination for other emergency anticipation situations  Ex. Back-up engines started as a storm approaches

13. NSPS IIII Applicability ˃ Applies to:  Compression-ignition engines  Any size (horsepower rating)  Emergency & Non-Emergency  ICE commence construction, modified, or reconstructed after 7/11/2005 and manufactured after 4/1/2006 ♦ Manufactured after 7/1/06 for certified NFPA fire pump engine ˃ Emission standards vary based on size of engine

14. NSPS IIII Monitoring, Recordkeeping, & Reporting

15. NSPS JJJJ Applicability ˃ Applies to  Spark-ignition ICE  Any size (hp rating)  Any fuel type  Constructed after 6/12/2006 and manufactured after date specified for engine type: *Commence Construction = date engine is ordered by owner/operator (not manufacture date)

16. NSPS JJJJ Standards ˃ Emission standards for various pollutants (ex: NO X, CO, and VOC)  Limit depends on use, fuel, model year, and power ˃ For engines ≤ 25 hp  All are certified by the manufacturer to applicable standards ˃ For engines > 25 hp  Purchase voluntarily certified engine and follow manufacturer’s instructions or  Test and develop/follow a maintenance plan

17. More on certified engines for NSPS JJJJ ˃ Purchase a certified engine  Follow mfr. instructions…–or– maintenance plan  Upon loss of certification, conduct performance test(s)  Note: ♦ Certification expiration does not result in noncompliance with the NSPS rules ♦ The NSPS requirements are to (1) purchase a certified engine and (2) operate and maintain it according to manufacturer instructions OR ˃ Operate a non-certified engine  Follow maintenance plan  Conduct initial performance test if ≥25 hp ♦ Within 60/180 days  Subsequent performance tests and initial notifications if >500 HP ♦ Every 8,760 hours or 3 years, whichever is first

18. RICE MACT (Subpart ZZZZ)- Affected Source ˃ All RICE at major/area sources ˃ Existing and new sources ˃ Existing source dates:  > 500 bhp @ major source – Dec 19, 2002  ≤ 500 bhp @ major source – June 12, 2006  All bhp @ area source – June 12, 2006 ˃ Existing vs. new determination is based on the date you “commence construction” which is date the engine is (contracted to be) installed by the owner/operator  Relocation and/or a change in ownership of an existing RICE does not make it “new”

19. Potential RICE MACT Requirements ˃ Emission limits (CO and CH 2 O) ˃ Continuous & monthly monitoring (T and ΔP)  Monitoring system evaluations ˃ Stack testing (emissions or catalyst activity) ˃ Reporting and notifications ˃ Management/work practices (maintenance) ˃ Runtime meter ˃ Plans (testing, monitoring, maintenance) ˃ Recordkeeping

20. State-Specific Regulations ˃ There may be additional requirements for engines at the state-level ˃ Requirements vary – see your state’s environmental department website for details

21. Permitting Requirements ˃ Prior slides cover only USEPA (and state) regulations ˃ Obtaining and/or operating an engine may also require an air permit ˃ Smaller and/or emergency engines may be exempt from permitting rules – check this out for your state ˃ May still need to be listed as an “insignificant activity” in a facility-wide operating permit

22. Permit Examples Illinois construction permit exemption: Any stationary internal combustion engine with a rated power output of less than 1118 kW (1500 bhp) or stationary turbine, except that a permit shall be required for the following…

23. Common Mistakes ˃ Not having a full inventory of the engines present onsite  Make sure maintenance staff is aware that the environmental department must be notified of any new engines  Ask building engineers to provide information on engines  Do a walk-through of the campus and make a list of all engines ˃ Missing maintenance/recordkeeping requirements  Requirements to change oil filters, inspect air cleaners, and inspect hoses and belts at least annually  Maintain log of engine operation and reason for use

24. Recommendations ˃ Inventory all engines at your facility, and update this inventory at least annually  Example: UIC has about 25 emergency engines, found in about 20 different buildings! ˃ Assign responsible person(s) to be in charge of documentation/recordkeeping ˃ Educate maintenance personnel on inspection/maintenance requirements for engines

25. EPA Guidance http://www.epa.gov/airtoxics/icengines/index.html 25

26. Introduction to Ozone Depleting Substances (ODS)

27. Why Are We Talking About ODS? ˃ USEPA regulations found in 40 CFR 82  Focus today is Subpart F  Other subparts include A/C units in motor vehicle fleet, labeling of containers, phase-out of ODS, etc. ˃ Goal is “maximizing the recapture and recycling of such refrigerants during the service, maintenance, repair, and disposal of appliances” ˃ Although some provisions apply only to industrial and commercial units, institutional units (including comfort cooling units) are not exempt

28. Refrigerants considered to be ODS ˃ Class I substances  Includes CFCs (ex: R-12), halons, & carbon tetrachloride  Production banned (but not use) beyond 2004  Supplies are extremely limited ˃ Class II substances  Includes all HCFCs (ex: R-22, R-141)  Complete ban on production (but not use) in 2030 – now essentially 2020 based on 9/2007 agreement ˃ See 40 CFR 82, Subpart A, Appendices A & B for full list

29. Evacuation/Recovery Requirements ˃ Evacuation/recovery is required before opening or disposal of any appliance to comply with 40 CFR 82.156(a) ˃ Evacuation requirements depend on the appliance type and age of recovery equipment used > Per 40 CFR 82.158(b) & (h), all newer (manufactured/imported after 11/15/1993) recovery equipment must:  Be certified, and  Have manufacturer’s certification label affixed > Cannot recover refrigerant unless person has certified to EPA that certified recovery equipment has been acquired per 40 CFR 82.162  One-time requirement on per site (not per equipment) basis

30. Disposal Requirements > Disposal – process leading to and including:  The discharge, deposit, dumping, or placing of any discarded appliance into or on any land or water;  The disassembly of any appliance for discharge, deposit, dumping, or placing of its discarded component parts into or on any land or water; or  The disassembly of any appliance for reuse of its component parts > Must evacuate & recover ODS from appliances prior to disposal according to Table 1 of 40 CFR 82.156(a)  Special disposal requirements under 40 CFR 82.156(f) for equipment that typically enters waste stream with the charge intact (e.g., small appliances); those that take final step in the disposal process ♦ Either recover any remaining refrigerant from the appliance, or ♦ Verify that the refrigerant has already been evacuated (must include signed statement that refrigerant removed)

31. Certified Technicians > Technicians must be certified in accordance with 40 CFR 82.161(a) to perform any service or maintenance on ODS-containing equipment > Approved certification programs are provided at: http://www.epa.gov/ozone/title6/608/technicians/608certs.html http://www.epa.gov/ozone/title6/608/technicians/608certs.html > Technicians must have proof of certification in accordance with 40 CFR 82.161(c)(3)  Type I (small), II (med., high, & very high), III (low), or Universal  Separate from MVAC technician certification Technician certification classes do not cover leak rate recordkeeping & reporting provisions!

32. Leak Rate Provisions for Comfort Cooling Appliances (CCAs) >Applicable to units with “full charge” > 50 lbs refrigerant per 40 CFR 82.156(i)(1) & (i)(5)  Applicability determined on a circuit-by-circuit basis ♦ A CCA containing a total of 80 lbs of R-12 but with two separate circuits of 40 lbs each would not be subject >If the leak rate is above the applicable “trigger rate” (15% for CCAs):  The leak should be repaired within 30 days*, or  The system should be retrofitted (within 1 year), or  The system should be retired from service (within 1 year) *One option to extend repair window available.

33. Full Charge Definition > The amount of refrigerant required for normal operating characteristics and conditions of the appliance as determined by using one or a combination of the following four methods:  Manufacturer's determination of correct full charge;  Actual measurements of amount of refrigerant added to or evacuated from the appliance;  Calculations based on component sizes, refrigerant density, piping volume, and other relevant considerations; and/or  Established range based on best available data regarding normal operating characteristics/conditions for the appliance ♦ Midpoint of the range will serve as the full charge ♦ Records must be maintained per 40 CFR 82.166(q) – Identification of the owner/operator of appliance; – Location of the appliance; – Original range for the full charge of the appliance, its midpoint, and how the range was determined; – Any and all revisions of the full charge range and how they were determined; and – The dates such revisions occurred.

34. How do I know if my unit is a CCA? >It is a CCA if it doesn’t meet the definition of “commercial refrigeration” or “industrial process refrigeration” >Commercial Refrigeration - Appliances utilized in the retail food sector or cold storage equipment >Industrial Process Refrigeration - Complex customized appliances used in the chemical, pharmaceutical, petrochemical, and manufacturing industries. These appliances are directly linked to the industrial process.  If one appliance is used for both industrial process refrigeration and other applications, it will be considered industrial process refrigeration equipment if 50 percent or more of its operating capacity is used for industrial process refrigeration  Universities not likely to have units that fall under this category

35. How do I calculate leak rates? >Two methods: 1. Annualizing method (most common) 2. Rolling average method ˃ Only one method can be used per facility  “The rate is calculated using only one of the following methods for all appliances located at an operating facility.”

36. Leak Rate Calculation – “Annualizing Method” >Step 1. Take the # of pounds of refrigerant added to return appliance to a full charge and divide it by the # of pounds of refrigerant the appliance normally contains at full charge; >Step 2. Divide 365 days by the shorter of the # of days that have passed since the last day refrigerant was added or 365 days; >Step 3. Take the # calculated in Step 1 and multiply it by the # calculated in Step 2; and >Step 4. Multiply the # calculated in Step 3 by 100 to calculate a percentage

37. Example Leak Rate Tracking Spreadsheet Enter amount of each charge Tool is set up to calculate leak rate based on annualizing method and compare to the threshold

38. Leak Repair Recordkeeping for CCAs >Servicing records per 40 CFR 82.166(k)  Date & type of service  Amount of refrigerant added  Date & amount of refrigerant purchased (if add own refrigerant) >Full charge recordkeeping per 40 CFR 82.166(q) if use “established range” method >Maintain records for 5 years >Best management practice recordkeeping:  The system type (i.e., CCA) – establishes the trigger rate  Full charge for each system (e.g., 100 lbs of R-12) – required input into leak rate calculations  Who performed the work – to verify technician certifications  Leak location and repair method  Calculated leak rate – to determine which leaks trigger a mandatory repair window  Verification tests – to ensure success of repairs

39. Common Mistakes >Not knowing which units have full charge > 50 lbs >Assuming your contractor is handling the leak repair provisions (calculations, etc.) for you  Facility is responsible for violations no matter what the cause! >Assuming technicians have been trained on leak rate recordkeeping & reporting provisions >Not performing leak rate calculations promptly, if at all  Only have 30 days from discovery to repair leaks if over trigger rate >Incomplete service records (often just an invoice is not enough)  Not enough information on leak locations and repair details >Not maintaining technician certifications

40. How do I determine the number of ODS units at my facility? ˃ Ask building engineers to provide any information available on these types of units ˃ Ask the HVAC contractor for their work orders ˃ To ensure that the list generated from the information above is complete, walk around campus and inventory the ODS units

41. Recommendations >Implement program with primary goal of fixing all identified leaks within 30 days – simplifies regulatory impact >Assign responsible person who knows where all compliance documentation is located >Develop inventory (focus on > 50 lb units first) >Educate your maintenance personnel and/or contractor on the leak rate provisions >Develop timely process for integrating service data into leak rate management program – “short feedback loop” >Require technicians to provide detailed information on leak locations to back-up fact that subsequent leaks are new leaks

42. Recommendations Cont. >Add labels/tags clearly identifying > 50 lb units & evacuation requirements >If leak rate calculations have never been done, perform historical calculations to determine if any units are a potential problem  3 years if you do not have a Title V permit  5 years if you have a Title V permit >Ensure contractors are providing required documentation >Consider the value of auditing your program >USEPA does enforce these regulations

43. Regulatory Requirements for Boilers

44. Federal Regulations for Boilers ˃ 40 CFR 60 Subpart Db – Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units  Applies to steam generating units with a heat input capacity greater than 100 MMBtu/hr and which commenced construction, modification, or reconstruction after June 19, 1984  Ex: Large boilers in campus power plant, likely already permitted ˃ 40 CFR 60 Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units  Applies to steam generating units with a heat input capacity greater than 10 MMBtu/hr but less than 100 MMBtu/hr and which commenced construction, modification, or reconstruction after June 9, 1989  Ex: Could apply to smaller boilers in individual campus buildings, which could be overlooked ˃ Not applicable to temporary boilers

45. Federal Regulations for Boilers Cont. – Boiler MACT ˃ 40 CFR 63 Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters  Applies to facilities with emissions of hazardous air pollutants (HAPs) greater than 10 tpy individual HAP and 25 tpy total HAP  Hot water heaters are exempt ˃ 40 CFR 63 Subpart JJJJJJ – National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers at Area Sources  Applies to facilities with HAP emissions less than 10 tpy individual HAP and less than 25 tpy total HAP  Gas-fired boilers, temporary boilers, and hot water heaters are exempt

46. How do I determine which boilers at my facility are potentially subject to these regulations? ˃ Inventory the boilers at the facility  Check gas bills for areas where there may be “higher than normal” gas usage  Discuss with building engineers/maintenance personnel  Do a walk-through of the entire campus to look for boilers on which you don’t have information ˃ Review the air permit  The air permit for the facility should indicate whether it is a Major or an Area source of HAP

47. More Information on Boiler Requirements ˃ EPA Guidance  Boiler Compliance at Area Sources ♦ http://www.epa.gov/airquality/combustion/complian ce/index.html http://www.epa.gov/airquality/combustion/complian ce/index.html ♦ http://www.epa.gov/ttnatw01/boiler/imptools/areab oilerbrochure.pdf http://www.epa.gov/ttnatw01/boiler/imptools/areab oilerbrochure.pdf  Boiler Compliance at Major Sources ♦ http://www.epa.gov/ttnatw01/boiler/boilerpg.html http://www.epa.gov/ttnatw01/boiler/boilerpg.html ˃ Individual states may also have regulations and permitting requirements for boilers – check with your local regulatory agency for additional guidance

48. Questions? Chloe Reece (630) 495-1470 creece@trinityconsultants.com