AQ_F_1900039_20180928_CMPL_CmplDetLtr

STATEQr
ROY COOPER NORTH CAROLINA
Governor Environmental QuaUty
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS
Director
September 28, 2018
Mr. Brian van Gelder
Eastern Regional Environmental Manager
Boise Cascade Wood Products,LLC.
306 Corinth Road
Moncure,North Carolina 27559
Subject: Applicability Determination for Testing Requirements for
2S0 HP Fire Pump Engine in Non-Emergency Configuration
Facility ID No.1900039, Permit No. 03424T26
Boise Cascade Wood Products,LLC., Moncure,Chatham County
Dear Mr.van Gelder,
The North Carolina Division of Air Quality(NCDAQ)has reviewed your request to determine the
regulatory requirements in changing operation of a fire pump engine (and associated pump) from
an emergency engine classification to a non-emergency classification and use. Such changes in use
from emergency to non-emergency are generally not allowed because the engine (and the
associated certification to emission standards)becomes an uncertified engine subject to additional
in-use testing requirements that are not the usual testing process and procedures that are familiar
to most owner and operators of stationary sources. Furthermore,it is not possible to"certify" a
single emergency engine to non-emergency standards.
There are limited cases where the emission standards for certification are identical for a given
model year and engine size regardless of whether the engine is classified as an emergency or non-
emergency engine. In these specific cases,the additional testing presented in the regulations may
not be necessary because the initial certification of the engine was to the same numerical value of
the emission standards. In researching the applicable regulations,NCDAQ determined that this is
one of those limited cases where the emission standards are at least equivalent. These findings are
summarized below. We do not consider the warranty aspects of such use as that is between the
owner(Boise Cascade) and the manufacturer of the engine.
BACKGROUND
Boise Cascade (Facility ID 1900039)facility is classified as an area source under 40 CFR 63 and has
installed a 250 bhp fire pump engine that was manufactured in 2013. Under 40 CFR 63,Subpart
ZZZZ (4Z),National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating
Internal Combustion Engines(RICE),the engine is classified as a new stationary RICE located at an
area source(see 40 CFR 63AS90(a)(2)(iii))because the RICE commenced construction after
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M a r_O.Wtr
North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707.8400

Mr.Brian van Gelder
September 28,2018
Page 2
June 12,2006. However,the engine would not be subject to any additional requirements under 40
CFR 63,Subpart 4Z as specified in 40 CFR 63.6590(c)(1)and,instead,would be required to comply
with New Source Performance Standards (NSPS) requirements of 40 CFR 60,Subpart IIII (4I),
Standards of Performance for Stationary Compression Ignition Internal Combustion Engines.
This compression ignition(CI) engine would be classified as an"emergency engine'as defined in 40
CFR 60.4219. The hours of operation are generally restricted to 100 hours of operation per
calendar year for maintenance checks and readiness testing(there is no limit on use in emergency
situations). The other limited uses are included in 40 CFR 60.4211(f). Under 40 CFR 60.4211(f)(3),
the engine may be operated for up to 50 hours per calendar year in certain non-emergency
situations,but that counts towards the 100 hours per year maximum allowable usage. Beyond 50
hours per year on non-emergency usage,the engine is required to be treated as a non-emergency
engine.
The means of complying with the NSPS is through the purchase of an engine certified to emission
standards defined by the engine size,manufacture data and classification. Engines are generally
classified as emergency CI engines and non-emergency CI engines under the NSPS. Fire pump
engines are classified as a specific type of emergency engine under 40 CFR 60.4202(d)based upon
energy output(size). The NSPS required the engines to be certified by the dates specified in Table 3
and to meet the emission standards of Table 4 in the subpart. The engine certification process is
required of the engine manufacturer and compliance with the NSPS Subpart 41 is attained by
purchasing a certified engine,operating in accordance to its certification classification and
maintaining a certified engine in accordance with the manufacturers emission-related written
instructions. If these requirements are met,there is no additional requirement for the owner or
operator of this type of engine related to emissions testing.
APPLICABILITY ISSUE
Through a design issue within the Boise Cascade facility,whenever the boiler feedwater pressure
drops below a certain threshold,a pressure sensor switch activates the fire pump engine to restore
and maintain water pressure within the system. There (apparently) is no automatic cutoff for this
design issue and the engine must be manually shutdown if the water pressure boost from the fire
pump is no longer needed. This type operation is allowable under the 50-hour provision of 40 CFR
60.4211(f)(3). It is not an emergency condition as defined by the regulations and once the 50-hour
maximum is exceeded,the engine no longer meets the definition of an emergency engine. 40 CFR
60.4211(f)states,in part:"Ifyou do not operate the engine according to the requirements in
paragraph 09(1) through (3)of this section, the engine will not be considered an emergency engine
under this subpart and must meet all requirements for non-emergency engines. If the engine is
certified to non-emergency engine standards,then there is no issue. If,however,there is a
difference between the emergency engine and non-emergency engine standards,then there may be
an obligation on the owner or operator to test to demonstrate compliance with the non-emergency
emission limits.
For this specific engine,there could be a requirement to performance an initial performance test
within one-year of the status change as required under 40 CFR 60.4211 (g)(2). Alternatively,the
facility can return the operational status of the engine to its certified classification of an emergency
(fire pump) engine by changing the configuration of the system so that the engine is not triggered
into operation by these non-emergency conditions or by limiting the hours of operation to less than

Mr. Brian van Gelder
September 28,2018
Page 3
50-hours per calendar year. The facility has requested,instead,an applicability determination for
the use of the engine as a non-emergency engine (pending the installation additional pumping
capacity that should reduce or eliminate the usage of the fire-pump engine for maintaining water
pressure).
APPLICABLE EMISSION STANDARDS
As stated in 40 CFR 60.4202(d) and Table 3,engine manufacturers were required to certify their
fire pump engines in this size classification beginning with the 2009 model year. The emissions
standards for certification are specified(Table 4) in the units of g/kW-hr for particulate matter,
carbon monoxide (CO) and the combined value of nitrogen oxides (NOJ and non-methane
hydrocarbons (NMHC)and listed as NMHC+NO,. These values are 0.20, 3.5 and 4.0 g/kW-hr,
respectively. It is the responsibility of the engine manufacturer to certify these engines in
accordance to procedures specified in 40 CFR 89 and 40 CFR 1039,as applicable. If the engine is
operated and maintained in accordance with the certification classification and according to the
written instructions,the engine is presumed to meet the requirements of Subpart 41 without
additional(periodic)testing.
Since the facility has chosen(in the interim) not restore operation of the engine in accordance with
its emergency(fire pump) certification classification,then the requirements of 40 CFR 60.4211(f)
require the engine to be treated as a non-emergency engine and the testing requirements of
paragraph (g)(2) of this section may then also apply. To determine whether testing may be
required,the certification standards for the same size engine and model year must be examined.
If treated as a 250 bhp non-emergency engine manufactured in 2013,an owner and operator of a
non-emergency engine of this size would be subject to 40 CFR 60.4204(b)instead of§60.4205. 40
CFR 60.4204(b) requires compliance with emission standards in§60.4201. In this case,
§60.4201(a)would apply and directs the user to 40 CFR 89 and 40 CFR 1039 and as applicable. As
an engine manufactured in 2013,the engine is subject to Interim Tier 4 Emission Standards
contained in§1039.102. In addition,if performance testing was required and conducted,
§60.4204(d) requires meeting the not-to-exceed(NTE)standards as indicated in§60.4212.
The complete manufacturing and certification requirements are contained for this class of engine in
40 CFR 1039 and are beyond the scope of this analysis. However,the base emission standards
required to be met in certification are found in Table 6 of§1039.102. If this engine was subject to
what is defined as a phase-out engine,the numerical limits for NMHC + NO.and for CO are identical
to NSPS standards in Subpart 4I. The only value that is different is the PM value at 0.02 g/kW-hr.
Unlike Tier 4 engines (manufactured after 2014)the NTE multipliers are different for these Interim
Tier 4 engines and are applied not to the exhaust emission standards,but to family emission limit
(FEL) cap values (under§1039.102(g) or§1039.104(g)). Under Table 8 of§1039.102(g),the PM
FEL cap is 0.04 g/kW-hr. However,under§1039.104(g)Table 1,the alternative FEL cap allowed by
the regulations for engine manufacturing and certification is 0.2 g/kW-hr. The alternative FEL cap
is also identical to the NSPS Subpart 4I standard.
CONCLUSION
Although the fire pump engine at Boise Cascade was certified to the fire pump engine emission
standard requirements for emergency engines in the NSPS Subpart 41,its use as a non-emergency

Mr. Brian van Gelder
September 28,2018
Page 4
engine for more than 50 hours in any calendar year would require it to be treated as a non-
emergency engine. The engine would then be subject to the emission standards for the same model
year and engine size for non-emergency use. For this specific engine,the emission standards that
apply are found in 40 CFR 1039.102 and 40 CFR 1039.104. Comparison of the numerical emission
limits for the fire pump engine standards in NSPS 4I and the non-emergency engine standards
found in§1039.102 and§1039.104 indicate that they are equivalent. Since the engine is already
certified to equivalent emission standards,it is NCDAQ's determination that an initial performance
test referenced in§60.4211(g)(2) is not required. However,the engine is still considered a non-
certified engine for this use and the operation in this configuration may affect the manufacturer's
engine warranty,which is beyond the scope of this determination.
If you have any questions,please feel free to contact me at [e-mail] or at(919)
707-8413.
Sincerely,
Gary L.Saunders,Supervisor
Stationary Source Compliance Branch
Division of Air Quality,NCDEQ
Cc: Ray Stewart, Raleigh Regional (RRO) Supervisor
Betty Gatano,Raleigh Central Office (RCO)
Central Files-Chatham County
IBEAM Documents-1900039