ENV-10-65 Conquering the Challenges Posed by the Reciprocating Internal Combustion Engine (RICE) Rules

Description:

This paper describes one refinery’s method of conquering the challenges posed by the Reciprocating Internal Combustion Engine (RICE) Rules and the changing requirements of three air regulations: 40 CFR 60 Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal Combustion Engines; 40 CFR 60 Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines; and 40 CFR 63 Subpart ZZZZ – National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. A brief summary of the key RICE rule requirements are discussed focusing on the latest amendments to 40 CFR 63 Subpart ZZZZ. The explanation of the rules will also focus on the importance of specific rule definitions and regulatory milestones. The summary will lead into an explanation of the challenges of compliance with these rules at a complex refinery. Examples of common roadblocks, misinterpretations, and Title V “deviations” will be given, along with a case study of rule implementation and management system recommendations for maintaining compliance.