EMISSIONS SOLUTIONS GUIDE
March 2009
EPA Reviews and Revisits Three Bush Administraion Air Quality Actions
In February 2009 the Environmental Protection Agency (EPA) announced it was revisiting or reviewing three major air quality actions originating from the last year of the Bush administration. The three Bush-era actions now being reviewed or revisited are:
• The California Greenhouse Gas Emissions Waiver Request,
• The New Source Review Aggregation Final Rule
• The Steven L. Johnson (former EPA Administrator) interpretive memo regarding the Clean Air Act.
California Waiver Request - The Clean Air Act gives EPA the authority to allow California to adopt its own emission standards for motor vehicles due to the seriousness of the state’s air pollution challenges. In December of 2005 California requested waiver permission to set standards controlling greenhouse gases from motor vehicles. California’s request was denied by then-EPA Administrator Stephen Johnson on 6 March 2008. On February 6, 2009 the EPA announced it will revisit California’s waiver request. “It is imperative that we get this decision right, and base it on the best available science and a thorough understanding of the law” Said EPA Administrator Lisa P. Jackson.
New Source Review - New Source Review (NSR) is a pre-construction permitting program to ensure air quality is maintained when factories, industrial boilers and power plants are built or modified. Aggregation, with regard to NSR, refers to the grouping of multiple, related physical or operational changes into a single project for evaluating requirements under the NSR program. On February 10, 2009, the EPA announced a delay in enacting a 15 January 2009 New Source Review final rule regarding the air permitting program’s “aggregation” policy. The aggregation policy now will not take effect before May 18, 2009 in order to allow time for further review.
Johnson Clean Air Act Memo – In December 2008 then-EPA Administrator Stephen Johnson put forward an interpretive memo addressing when the Prevention of Significant Deterioration program applies to carbon dioxide, a chief greenhouse gas. Concerns were soon raised about the memo’s potential impact on American communities and neighborhoods. The Sierra Club and other parties in early January petitioned EPA to reconsider the Johnson memorandum. On February 17, 2009 the EPA granted a petition for reconsideration of the Johnson/Bush Administration memo regarding the scope of the Clean Air Act.
SMU Report Finds North Texas Shale Drilling Contributes to DFW Smog
A peer reviewed comprehensive analysis of air emissions associated with natural gas and oil production in the Barnett Shale area of North Texas finds that the area’s emissions may be a significant contributor to Dallas/Fort Worth smog formation, comparable to the combined emissions from all Metroplex cars and trucks.
The report by Dr. Al Armendariz , Engineering Professor at Southern Methodist University, projects that emissions from Barnett Shale drilling for 2009 will be 200 percent higher than emissions from all motor vehicles and area airports combined.
The report examines each step of the gas production process, from well drilling and completion, to gas processing and transmission. Armendariz said the industry could reduce emissions by using improved, readily available methods for completing wells, plus other technologies for engines or compressors. Currently, there are nearly 10,000 functioning gas wells in the Barnett Shale.
The EPA Proposes to Reduce Toxic Emissions from Stationary Diesel and Gas Engines
On February 25, 2009 the Environmental Protection Agency (EPA) announced it intends to set emission limits for formaldehyde, benzene, acrolein and other air toxics – also called hazardous air pollutants (HAPS) – from reciprocating internal combustion engines (RICE). EPA says its proposed RICE HAPS rule would apply to stationary diesel and gas-fired engines used at facilities such as power plants and chemical and manufacturing plants to generate electricity and power pumps and compressors. They are also used in emergencies to produce electricity and pump water for flood and fire control.
The proposed limits would apply to engines located at smaller sources of air toxics. For major sources of air toxics, this rule would only apply to engines that are:
• Smaller than or equal to 500 horsepower that were constructed or reconstructed before June 12, 2006, or,
• Larger than or equal to 500 horsepower that were constructed or reconstructed before December 19, 2002.
To meet the proposed emissions requirements, the EPA believes owners and operators of these engines would need to install after treatment controls, such as filters or catalysts, to engine exhaust systems. The EPA expects owners of rich burn natural gas or gasoline engines would install a non-selective catalytic reduction (NSCR) system to meet proposed emission limits. For existing diesel engines EPA expects owners will focus on oxidation catalysts or catalyzed diesel particulate filters to meet emission limits.
EPA has posted links to a fact sheet as well as its proposed rule on its Web site. The public may comment on EPA’s proposed rule for a period of 60 days after its publication in the Federal Register.
California Issues Compliance Guidelines for Commercial Harbor Craft Regulation
A Compliance Guideline for the Commercial Harbor Craft Regulation is now available from the California Air Resources Board (ARB). The Compliance Guideline discusses who will have to comply with the regulation and explains what is required to comply.
The purpose of ARB’s Commercial Harbor Craft Regulation is to reduce emissions of diesel particulate matter (diesel PM) and oxides of nitrogen (NOx) from diesel engines used on commercial harbor craft operated in California regulated waters (waters within 24 nautical miles of the California coast).
The regulation includes requirements for new and existing engines as well as monitoring, recordkeeping and reporting requirements. Two tables in the guideline list compliance dates by engine model year and annual hours of operation for vessels with homeports in or outside of the South Coast Air Quality Management District (generally the Los Angeles Basin). The regulation became effective on 1 January 2009.
California Orders Stricter NO2 Diesel Emissions Limits Effective January 2009
As of January 2009 all diesel emission control systems (DECS) used to satisfy the California Air Resources Board (ARB) in-use fleet rules must meet stricter rules for emissions limits for Nitrogen Dioxide (NO2). The rules state NO2 emissions may not be increased by more than 20% over the uncontrolled engine baseline. In 2007-2008 the emission limits was 30% over the uncontrolled engine baseline.
Effective January 1, 2009, ARB states only DECS that comply with the 2009 NO2 limit in the verification procedure will be considered verified systems.
Systems that currently meet the 2009 NO2 emission limit are indicated by a “+” in ARB’s table of verified systems. As of January 2009, DECS that do not comply with the NO2 emission limit may not be installed or sold as verified. Systems that do not comply with the limit, but are installed prior to January 2009, may remain in service and continue to be candidate compliance options for fleet rules.
Note: MIRATECH Corporation’s CombiKat Diesel Particulate Filter meets ARB’s January 2009 “+” requirements and remains verified as an ARB level 3 DECS for stationary, emergency and prime generators.
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