NESHAP Deadline for Reciprocating Internal Combustion Engines Initial Notifications is August 31
EPA finalized amendments to the Reciprocating Internal Combustion Engines (RICE) NESHAP to include new requirements for existing stationary compression ignition (CI) engines at area sources and major sources on March 3, 2010. Owners or operators of affected CI engines (typically diesel-fueled engines) are required to submit an initial notification to EPA Region VII by August 31, 2010.
Although the Linn County Public Health Department (LCPH) has not yet adopted the RICE NESHAP amendments into local air quality rules, LCPH expects to adopt the NESHAP after the Iowa Department of Natural Resources (DNR) adopts it into state rules does so in October 2010. Accordingly, LCPH requests that affected facilities submit a copy of their initial notification to LCPH. Facilities should also send a copy to the DNR.
The LCPH has created an initial notification form for the RICE NESHAP. Facilities may also use EPA’s sample initial notification form or DNR's. Facilities are not required to use either form, and may submit their notification in some other format, such as a letter or spreadsheet. However, the submittal must include all of the initial notification information required by the RICE NESHAP. Additionally, neither LCPH, DNR nor EPA can accept electronically-submitted NESHAP notifications at this time. Facilities should submit a hard-copy initial notification to LCPH, DNR and EPA by August 31.
LCPH's initial notification form (which includes agency addresses), as well as other information on the RICE NESHAP, is available on the LCPH Air Quality Division's
Regulations Requirements for Stationary Internal Combustion Engines website.
The following are some questions and answers that will help you determine whether your facility is subject to the initial notification requirements in the RICE NESHAP amendments.
Is an initial notification required for all facilities that operate a CI engine?
Initial notifications are required to be submitted for the following categories of CI engines:
At area sources:
Non-emergency engines greater than 300 HP, installed before June 12, 2006
At major sources:
Non-emergency engines greater than 500 HP, installed before December 19, 2002, and
Non-emergency engines greater than or equal to 100 and less than or equal to 500 HP, installed before June 12, 2006
Is my facility a major source or an area source of hazardous air pollutants (HAP)?
A major source is a facility that has the potential to emit 10 or more tons per year of any single HAP or 25 or more tons per year of any combination of HAPs. An area source is a facility that is not a major source of HAPs.
Is my engine an emergency engine or a non-emergency engine?
It is important to review the definition of "emergency stationary RICE" in 40 CFR 63.6675 before making the determination of whether an engine should be considered emergency or not. The definition is restrictive, and several facilities that previously considered their engines to be emergency-only are finding that the engines don't meet the NESHAP definition.
Engines that are operated as part of interruptible service agreements will very likely be considered non-emergency engines. This is because generating for peaking purposes or as part of a financial arrangement with another entity is not allowed for an emergency engine. An engine that only runs during emergencies and for required maintenance and readiness testing would likely meet the definition of emergency stationary RICE.
For questions on the initial notification requirements or other RICE NESHAP issues, please contact Janell White, NESHAP Coordinator, by phone at (319) 892-6014 or by e-mail at
janell.white@linncounty.org.