Is Your RICE MACT Monitoring Plan Ready?

If your facility has a stationary engine controlled by a catalyst, then it is likely that EPA's RICE MACT (40 CFR Part 63, Subpart ZZZZ) requires you to develop and follow a site-specific monitoring plan describing your monitoring of the catalyst. The standard monitoring parameters are catalyst inlet temperature and pressure drop across the catalyst bed. The maximum allowable values for each should be established during the initial performance test of each engine, which, for the last classifications of engines regulated by the RICE MACT (< 500 hp SI RICE at major sources and all SI RICE at area sources), is required by April 17th of this year for any subcategories subject to an emission standard. Note that the deadline has passed for all other applicable categories of engines. The site-specific monitoring plan for each engine should also be in place no later than the test date.

The rule provides some minimum standards for measurement frequency, sensor tolerance, operational load, and periodic performance evaluations. Otherwise, the monitoring plans can be (should be) engine-specific, addressing items such as instrument/equipment design, performance criteria, data acquisition and calculations/averaging, auditing procedures, and planned maintenance.

Trinity has worked with numerous companies to develop and implement RICE MACT monitoring plans, and based on that experience we recommend keeping the plans as simple as possible. One approach has been to reference other, already established plans/manuals where appropriate. And, as always, establishing a system to document compliance with the plan may be the most difficult part. For assistance with developing a plan or a compliance system, or for any other related questions, please call your local Trinity office or (800) 229-6655.