Electronic Reporting for Engines is here!

On August 30, 2024, the U.S. Environmental Protection Agency (U.S. EPA) finalized amendments to the following regulations applicable to Reciprocating Internal Combustion Engines (RICE):

40 CFR Part 60 [Standards of Performance for New Stationary Sources, also referred to as New Source Performance Standards (NSPS)]:

• Subpart IIII (NSPS for Stationary Compression Ignition Internal Combustion Engines)
• Subpart JJJJ (NSPS for Stationary Spark Ignition Internal Combustion Engines)

40 CFR Part 63 [National Emission Standards for Hazardous Air Pollutants (NESHAP)]:

• Subpart ZZZZ (NESHAP for Stationary Reciprocating Internal Combustion Engines)

This rulemaking is mostly geared toward establishing electronic reporting requirements for RICE for various routine compliance reporting but does include several clarifications and language updates facilities should be aware of. The final revisions are generally consistent with what was proposed by U.S. EPA on June 26, 2023. See ALL4’s blog on the 2023 proposed revisions for more details.

Electronic Reporting

Facilities with engines subject to NSPS Subparts IIII or JJJJ, or NESHAP Subpart ZZZZ, must now submit the following reports electronically through U.S. EPA’s Central Data Exchange (CDX) using the Compliance and Emissions Data Reporting Interface (CEDRI):

• Certain initial notifications of compliance,
• Performance test reports,
• Notification of Compliance Status (NOCS), and
• Annual and semiannual compliance reports.

Performance test results must be submitted in the format generated using the Electronic Reporting Tool (ERT), if the test method is supported. If not, performance test results must be submitted in portable document format (PDF) using the attachment module of the ERT. For annual and semiannual compliance reports, facilities must use the appropriate spreadsheet template to submit information to CEDRI.

U.S. EPA asked for comments on the proposed reporting templates with the 2023 proposal. Based on comments received, the final reporting templates include some additional clarifications and are available in the docket. Interestingly, the Department of Defense (DoD) and the U.S. Navy provided comments to U.S. EPA with concern that the electronic reporting templates, which require specific latitude and longitude coordinates, could disclose the location of certain engines that would compromise national security. U.S. EPA acknowledged the potential risks, and now facilities can submit a national security exemption and not provide coordinates.

Carbon Monoxide (CO) standards for Fire Pump Engines

In the 2023 proposal, U.S. EPA recognized that Table 4 to Subpart IIII of Part 60—Emission Standards for Stationary Fire Pump Engines has been frequently misinterpreted based on how the table appears in the CFR. As proposed, Table 4 to Subpart IIII has been updated to show that the same CO standard applies for all model years. Facilities should review any fire pumps they operate to ensure that any applicable CO standard was correctly captured in permitting.

Clarifications to Annual Oil Changes and Inspections

40 CFR Part 63, Subpart ZZZZ requires routine oil changes and spark plug, air cleaner, and hose/belt inspections for several different types of RICE. Generally, the requirements are “Change oil and filter (or perform inspection) every X,XXX hours or annually, whichever comes first.” As we’ve seen with other rules, there is often confusion on how to interpret whether “annual” means once per calendar year (e.g., January 2022 and December 2023 [23 months apart]) or within 365 days.

In the proposed revisions, U.S EPA sought comments on replacing “annual” with “every 12 months” for oil changes and inspections. U.S EPA received comments pointing out that “every 12 months” potentially results in owners and operators needing to complete oil changes in January 2025 and December 2025 (11 months apart). U.S. EPA acknowledged the practical issues with their proposed language, so the final language is “within 1 year + 30 days of the previous change (or inspection).” This is a similar solution to the industrial boiler annual tune-up requirements of 40 CFR Part 63, Subpart DDDDD (Boiler MACT), which must be conducted within 13 months of the previous tune-up for several types of boilers. It is important to note that the new Subpart ZZZZ language of “1 year + 30 days” is not always exactly equivalent to 13 months. Facilities should be mindful of the discrepancy if they are attempting to sync up annual engine maintenance and boiler tune-ups.

50-Hour Provision

In the proposed rule, U.S. EPA requested comments on the NSPS and NESHAP provisions specifying that emergency engines can operate for up to 50 hours per year to supply power for local system reliability. U.S. EPA received numerous comments both for and against removing the 50-hour provisions from various industries, municipalities, states, and government organizations. However, U.S. EPA is not finalizing any changes to the 50-hour provisions with this rulemaking and state they are still considering what action, if any, to take.

What now?

The electronic reporting requirements for all three rules are effective 180 days from the final rule. Mark your calendars – any submittals due February 26, 2025, or later must be submitted electronically. For any newly required electronic annual or semiannual reporting, the compliance date is February 26, 2025, or 1 year from the date that the report template is made available on CEDRI, whichever is later. All other clarification and language updates are effective immediately, as of August 30, 2024.

The RICE regulations are notorious for their complexity and apply to a wide range of industries that operate stationary engines. Facilities should review the reporting requirements that apply to their RICE and develop a plan for developing and submitting upcoming reports electronically. ALL4 is here to help! Reach out to me at ghowell@all4inc.com or your ALL4 Project Manager for more information.