September 10, 2013

Question- RICE-MACT
by Michael Holloway, CLS,
Business Development Manager

What is RICE-MACT?


The EPA has new National Emission Standards for Hazardous Air Pollutants (NESHAP) for certain stationary engines. RICE MACT refers to “Reciprocating Internal Combustion Engines” (RICE) and “Maximum Achievable Control Technology” MACT). These new rules are designed to regulate emission standards for stationary reciprocating engines, which go into full effect under NESHAP Subpart ZZZZ.

Who does it affect?


RICE-MACT applies to any piece of equipment driven by stationary reciprocating internal combustion engines located at a major source of hazardous air pollutants (HAP). This new regulation will require implementation of new processes when it comes to testing in-service engine oils. Oil and filter changes will be mandated depending on the Horse Power of the engine, engine design, and whether the application is emergency or non-emergency. This will impact the lubrication management practices of the natural gas conveyance industry. The use of in-service oil analysis allows for determining alternative oil change frequencies instead of the prescribed frequencies detailed in the NESHAP ZZZZ regulations. Natural Gas Engines that fall under this provision are required to test or change their oil depending upon the HP and other factors.

When does it happen?


RICE-MACT will go into effect as of October 19, 2013.

How am I going to remain in compliance?


ALS can provide you with the tools needed to maintain your equipment’s availability and provide compliance with the EPA Ruling. ALS Tribology programs are designed to provide accurate and timely information allowing you the most flexibility in equipment maintenance actions, reducing the potential for costly repairs and possible penalties.

Testing of the used engine oil provides a tool for documenting compliance of the oil change requirements as well as allowing for drain intervals that may be more favorable to maintenance practices. ALS test reports provide horsepower ratings on applicable equipment when this information is provided. Diagnostics protocols can then note a “RICE MACT Alert!” on applicable test reports. This would involve mandatory re-testing of the data outlier to confirm original data reported and recommending an immediate oil change if not done at time of sampling. Alerts would be based on test parameters for viscosity, acid number, and water contamination outlined under NESHAP ZZZZ regulations. Operators will have two business days to change their oil or take the unit out of operation upon receipt of the RICE MACT Alert sample analysis.

What to test for to remain compliant:


Parameter

 

Condemning Limits

Total Base Number (diesel engines)

<30% of TBN of new oil

Total Acid Number
(CNG engines)

Increase of  >3.0 mg TAN of new oil

Viscosity

Change ±20% of new oil

Water

>0.5%

Delivering information that provides more value to lubrication management practices is one more way ALS partners with its clients to make informed decisions.

And the real questions is…We’re ready, are you?  Give us a call, we’re here to help. 

 

 

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