The sense of urgency is growing as the deadline for compliance on new spark-ignited reciprocating internal combustion engines (SI RICEs) regulations nears, says one industry expert.
“The NESHAP ZZZZ regulation has the attention of the midstream industry,” Steve Abernathy, Exterran’s vice president of quality, safety, health and environment and North American operations, tells Midstream Business. “However, we also find that some operators, while generally aware of the new regulation, may not understand all its implications and may find it challenging to be fully prepared in time for the effective date.”
In a move to lessen air pollution, the Environmental Protection Agency (EPA) introduced new SI RICE rules through the Subpart ZZZZ of its National Emission Standards for Hazardous Air Pollutants (NESHAP) regulation, which will force companies to better control, manage and regulate their engines. All existing engines will be impacted.
The new regulation will extend environmental standards to all area-source SI RICEs, meaning each piece of equipment will be somehow federally regulated. New maintenance requirements and emission-control equipment will be based on engine location and horsepower. Engines in remote locations must follow maintenance programs, while those in non-remote status are required to follow emission-control system rules.
The rules are aimed at reducing engine emissions, thereby improving local air quality. Aside from making the necessary adjustments to their engines, affected companies will be required to prove their compliance by closely monitoring and documenting activities.
The clock is ticking on compliance, with the new regulations set to kick in October 19. Consequences of failing to comply could be severe and costly. Penalties could add up to hundreds of thousands of dollars, depending on the number of engines involved and how regulations are enforced, says Abernathy.
“Under Section 114 of the Clean Air Act, the EPA has the authority to request information that enforcement officials believe is necessary to assess compliance,” he says. “This means that operators need to be prepared to provide documentation to show they are complying with all the new requirements. It is also possible that enforcement could occur at smaller sites that historically were not targeted for enforcement action.”
Operators who haven’t yet complied with the NESHAP rules will be challenged to meet the deadline, Abernathy adds.
“We estimate that compliance readiness takes at least 12 weeks and may take significantly longer depending on the size of one’s fleet of affected engines,” he says. “That is why we proactively began formulating our plans more than three years ago, even before the regulation was published in its final form."
“The key message for all midstream operators: Compliance with the NESHAP ZZZZ regulation requires good business processes, standardization and integration, especially as it relates to maintenance practices and record keeping. Compliance requires much more than a simple technology fix.”
For more information, visit www.NESHAPZZZZ.com.
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