ZZZZ Emission Testing
The world of emission testing includes monitoring and reporting the emissions of internal reciprocating combustion engines (RICE). If your organization operates such engines near major HAP (hazardous air pollutant) source, and those engines are rated at over 500 bhp (brake horsepower), then you must comply to the emission standards outlined in NESHAP’s V40 CFR Part 63, Subpart ZZZZ. Let’s take a look at this set of requirements and what you might need to do to demonstrate compliance with them.
Subpart ZZZZ applies to both compression ignition (CI) engines and 2-stroke or 4-stroke spark ignition (SI) stationary engines, although a specific emission level is not required for each and every category of an engine. For compression ignition engines rated above 500 bhp, emissions must be limited to 23 ppm of carbon monoxide or demonstrate a carbon monoxide reduction of 70 percent. 4-stroke rich-burn SI engines must limit their emissions to 350 ppb of hydroxycarbonyl or demonstrate a hydroxycarbonyl reduction of 76 percent.
These requirements are the same for new RICE engines located at major sources. Additionally, 2-stroke SI lean-burn engines must limit emissions to 12 ppm of hydroxycarbonyl or show a 50-percent carbon monoxide reduction; their 4-stroke equivalents must adhere to 12 ppm of hydroxycarbonyl or a 93-percent reduction in carbon monoxide.
You’re expected to monitor your RICE emissions continuously to maintain Subpart ZZZZ compliance, recording and reporting all data collected while the engines are operating (although you can’t use any data collected during a monitoring equipment malfunction). Erthwrks can perform periodic test runs to make sure your engines are operating within compliance parameters, and then provide all the necessary documentation to report that compliance. If you’re out of compliance, we can recommend specific steps you can take to fix the problem.
Stationary Engine Testing
- 40 CFR Part 60 Subpart JJJJ – NOx, CO, and VOC testing
- Pre and Post Catalyst testing for pollutant reduction usually via 40 CFR Part 63 Subpart ZZZZ – Formaldehyde (HCOH) and CO reduction efficiency
- Permit by Rule/Source Performance Guarantees
- Volatile Organic Compounds (VOCs) and Total Hydrocarbons (TOC) results via:
- EPA Method 7E: Nitrogen Oxides (NOx)
- EPA Method 10: Carbon Monoxide (CO)
- EPA Method 18: Gas Chromatograph (GC) Analysis
- EPA Method 25A: Flame Ionization Detection (FID) Analysis
- EPA Method 320 or ASTM D6348-12: Fourier Transform Infrared Spectroscopy Analysis
- EPA Method 323: Fourier Transform Infrared Spectroscopy (FTIR) (methods listed above)