RICE Rule Service: NSPS & NESHAP Compliance

Do you know which of your stationary engines are subject to NESHAP Subpart ZZZZ or NSPS Subpart IIII/JJJJ, and which requirements are triggered? Are there state standards that may also apply to your “RICE*”?

At step2compliance, we have developed the proprietary RICE Rule Tool to automate the process of evaluating regulatory applicability and identifying specific requirements triggered for stationary RICE (reciprocating internal combustion engines). The RICE Rule Tool is the “engine” of our RICE Rule Service. No one else in the industry offers such a simple solution to such a complex and challenging problem. Our solution scales from a single engine to an entire fleet.

The problem

When regulatory applicability determinations are performed manually for each of your stationary engines, these “snapshots in time” are only valid until the underlying rules or installed configurations change. At this point the process must be repeated, and often times there is no systematic approach in place for documenting each set of assumptions and logic flow taking place through each applicability assessment made.

Once the applicability status is determined for NESHAP Subpart ZZZZ, NSPS Subpart IIII or JJJJ, and any relevant state rules, identifying and managing all applicable requirements for a triggered rule can in itself become an overwhelming task. The problem is only compounded for fleet owners/operators that need to track compliance obligations for a large number of units, particularly as that fleet shifts geographically.

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The solution

The RICE Rule Service (RRS) allows you to manage your stationary engines, gensets, or fleet, and track their applicability under federal and state emission regulations. Federal and state rules impacting stationary CI or SI engines are continually monitored for updates, so applicability determinations and identified applicable requirements stay current in the system with changing rules or changes to your engine configuration and location. The RRS dashboard displays “trigger” or “exempt” status for NESHAP, NSPS, NAAQS, and state standards at a glance.

In addition to comprehensive applicability determinations, triggered rule requirements are presented in both summary and detail format in some of the many reports that can be generated on demand. RRS reports can be run for single engines or engine batches, and saved in various file formats including PDF.

How it works

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  • Step 1—You enter your engine profile data, or we pre-populate it for you at the fleet level
  • Step 2—Your current state/federal applicability status is immediately available for each engine
  • Step 3—You have continual access to report documentation of applicability & requirements

What you get

When you subscribe to our service, you come away with solid documentation supporting the resulting RICE rule applicability determinations along with detailed reports to guide you through achieving and maintaining compliance:

  • Engine input data & assumptions
  • Applicability snapshot
  • Federal applicability summaries
  • Statements of applicability – NESHAP / NSPS
  • Emission standard summaries
  • NESHAP / NSPS detailed requirements (varying by engine scenario)
  • State standards and applicability conditions
  • NAAQS attainment status (National Ambient Air Quality Standards)
  • NESHAP Subpart ZZZZ initial notifications

The advantages of our service

  • Analyze an entire fleet of engines at one time
  • Maintain defendable documentation of RICE rule applicability status
  • Have Statements of Applicability available at your fingertips; documents can be maintained on-site for reference by testing & maintenance personnel
  • Easily communicate specific requirements to team or contractors
  • Re-assess your status quickly to anticipate impacts of engine configuration changes
  • Comply with NESHAP and NSPS rules proactively by understanding the scope of requirements triggered
  • Minimize non-compliance risk
  • Facilitate long-term planning and forecasting of emissions control capital expenditures and O&M obligations

* RICE = reciprocating internal combustion engine