Is Your Facility Subject to 6X?

by Barb Johnson, K-State Pollution Prevention Institute

If your facility performs metal fabrication and finishing, you could be subject to a new air regulation - National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Nine Metal Fabrication and Finishing Source Categories. Your facility could be affected if its primary activity is in one of nine source categories. This regulation potentially affects facilities that are an "area" source of hazardous air pollutants (HAPs). Area sources are those that annually emit less than 10 tons of a single HAP or less than 25 tons of a combination of HAPs. So if your facility is an area source of HAPs, is primarily engaged in one of nine source categories, and uses one of the metal fabrication and finishing HAPs (cadmium, chromium, lead, manganese and nickel), you could be subject to 40 CFR Part 63, Subpart XXXXXX, or the "6X rule."

The first requirement of this rule is to submit an initial notification to the Region 7 EPA in Kansas City and to the Kansas Department of Health and Environment (KDHE) in Topeka. Initial notifications for existing sources (those existing before April 3, 2008) are due July 25, and are to meet compliance requirements at that time. New sources are required to submit an initial notification, and notification of compliance status, within 120 days of startup. 

The Kansas Small Business Environmental Assistance Program (SBEAP) has 6X-rule resources on its Air Quality Rules webpage at www.sbeap.org/aqrules. To help facilities determine whether they are an area source affected by this rule, the Web page has posted the regulations, an EPA summary brochure, an archived Webinar with accompanying PowerPoint presentation, a list of affected sources by the North American Industry Classification System (NAICS) and Standard Industrial Classification (SIC) codes, and an applicability flow chart. Other resources available on the Air Quality Rules webpage include an initial notification form, a notice of compliance status form and Q&As resulting from the Webinar. 

For more information on this area source rule or other air regulations, call SBEAP at 800-578-8898 or e-mail at sbeap@ksu.edu.

KDHE Solicits Pollution Prevention (P2) Award Applications

KDHE presents the annual P2 awards to individuals, communities or community groups, businesses and industries who have made a significant impact in protecting our environment by preventing pollution. The application form is available on the P2 award website. Don't miss this opportunity to obtain recognition for all of your hard work!  Applications are due Friday, June 24. Contact Cathy Colglazier at 800-357-6087 if you have any questions on the awards program.

Stationary Engine Regulations

by Jeremy Duis, KDHE Bureau of Air 

If you own a stationary Reciprocating Internal Combustion Engine (RICE) the chances are good that it will be subject to a federal emission standard. On August 20, 2010 the Environmental Protection Agency (EPA) finalized the National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (aka the RICE MACT). This regulation means that some previously unregulated engines are now subject to emission standards which may require the addition of pollution control equipment to new and existing engines. It is important that owners of RICE engines, regardless of size or fuel types, as well as those considering the purchase of new RICE understand the requirements of these regulations.

The Maximum Achievable Control Technology (MACT) is the federal regulation that establishes the level of emission control for a regulated source. EPA is required to set these emission standards under section 112 of the Clean Air Act in order to reduce Hazardous Air Pollutants (HAP). The HAP of concern in the RICE MACT is formaldehyde. EPA sets the standards based on the emission rates of the top 12 percent of existing engines and requires all existing engines to have equivalent emission control.

There are two main categories of the RICE MACT and each of those categories has four sub categories.The two main categories are:

• Major source: Engine located at source with over ten tons of any individual    HAP or 25 tons of any combination of HAPs. 
• Area source: Any engine that is not located at a major source.

In addition to these two main types of source categories, there are four subcategories:

• Manufacture date (new or existing)
• Engine use (emergency or nonemergency)
• Ignition/Fuel type (spark ignition/gas or compression ignition/diesel)- if spark ignition (4 stroke lean burn, 4 stroke rich burn or 2 stroke lean burn)
• Horsepower (hp) rating 

The requirements vary greatly depending on which category the engine falls under. This regulation affects most reciprocating engines including those less than 100 hp. Because area sources generally have less experience with environmental regulations, the remainder of this article will focus on area engine requirements at area sources.

Existing emergency engines with spark ignition less than 500 hp or compression ignition less than 300 hp that are located at area sources are only subject to maintenance requirements and minor recordkeeping. 

Nonemergency engines greater than 500 hp located at area sources have specific emission limits that will more than likely require add-on control equipment to comply. The regulation also increases the reporting and recordkeeping requirements for these sources.

The RICE MACT requires new engines manufactured before June 12, 2006 that are located at area sources to meet the emission standards in New Source Performance Standard (NSPS) JJJJ, Standards of Performance for Stationary Spark Ignition ICE or NSPS IIII Standards of Performance for Compression Ignition ICE.

For additional information and a copy of the regulation please refer to www.epa.gov/ttn/atw/rice/ricepg.html or contact Jeremy Duis at 785-296-1542. The MACT regulations can also be found at 40 CFR 63.6580-6675 and the NSPS regulations are at 40 CFR 60.4200-4248.  

KDHE Division of Environment Regulatory Agenda 

KDHE's Division of Environment has numerous regulations currently in process.  To view the regulatory agenda, click the link below. 

DOE Regulatory Agenda 

The Coleman Company, Inc. Improves Energy Efficiency through K-State Intern Program

by David Carter, K-State Pollution Prevention Institute

The Wichita-based Coleman Company's northeast factory is responsible for manufacturing well-known Coleman coolers and legendary liquid-fuel lanterns. Being a visionary industry leader, The Coleman Company, Inc. (Coleman) has focused on sustainable initiatives to reduce operating costs and continue its longstanding tradition of environmental stewardship. To aid in these efforts, Coleman requested an intern from the Kansas State University Pollution Prevention Institute to research various energy efficiency projects.

Aakash Amatya, a Wichita State University electrical engineering graduate student, was assigned as the intern for Coleman. Amatya worked on five projects during the 10-week internship in the summer of 2010. Implementation of three of his recommendations will result in potential savings of more than 1.3 million kWh; 190,000 therms of natural gas and $250,000 per year.

Amatya's main project at Coleman was an analysis of the natural gas boiler used at the facility. Since there was no meter on the boiler, Amatya used various engineering calculations to calculate a fuel-to-steam efficiency of only approximately five percent. Moreover, although the boiler had a rated capacity of approximately 125 brake horse power (BHP), further research revealed it was being used for a process requiring only 15 BHP. Consequently, Amatya recommended replacing the original boiler with an electric boiler capable of providing at least 15 BHP. Economic analysis of this recommendation indicated a payback of less than four months and an estimated annual savings of $167,000.

In addition to the boiler analysis, Amatya also researched relamping projects for various areas of the plant. The first such project involved calculating costs and savings from replacing current T12 fluorescent lamps and magnetic ballasts.   Amatya suggested retrofitting existing conventional T12s with energy-efficient T8s and replacing existing magnetic ballasts with electronic ballasts, resulting in an estimated annual savings of 120,000 KWh and $8,000. The second relamping project entailed providing a cost analysis of replacing the current 400 W metal halide (MH) fixtures. Amatya researched four options for this project: replacing the 400 W fixtures with 1) 360 W MH; 2) 320 W pulse-start MH on electronic ballasts; 3) four-lamp, T5 high-bay fixtures and 4) six-lamp, T8 high-bay fixtures.Based on the cost analysis, Amatya recommended either option 3 or 4, with estimated annual savings of 1,200,000 KWh and $70,000.

Amatya also conducted initial research on two other manufacturing processes within the facility. Early results indicated potential savings of more than 9.3 million gallons of water per year by reusing industrial process water, but additional research would need to be conducted to prove the viability of these processes changes.

The Coleman Company is currently in the process of obtaining approval for three of Amatya's projects. Further evaluation of the other two projects will be completed to determine if these projects continue to present cost efficiencies. Through its participation in the Pollution Prevention Intern Program, The Coleman Company, Inc. has affirmed its reputation for environmental stewardship and added to its list of projects to achieve continual improvement in its sustainability efforts and operational efficiencies. 

For more information on the Kansas State University Pollution Prevention Intern Program, visit the Kansas Small Business Environmental Assistance Program website at www.sbeap.org/content/internships.

Environmental Cleanup and Property Redevelopment 

Of the Former Farmland Industries Nitrogen Plant in Lawrence

Former Farmland Industries Nitrogen Plant.

Through education, direct services and the assessment of data and trends, coupled with policy development and enforcement, KDHE will improve health and quality of life.  We prevent illness, injuries and foster a safe and sustainable environment for the people of Kansas.