How to Make Sense of Complicated MSAPR Requirements

Envirosoft - May 18, 2022

Now that engine owners and operators are anticipating the important upcoming deadlines for MSAPR requirements, there are plenty of questions. Understandably so – these requirements are complex, and non-compliance can be an expensive, time-consuming risk. 

As experts on MSAPR compliance and regulations, we have put together the most important and practical information you’ll need to make sense of it all. From identifying requirements for different engine types and specific emissions limits to outlining crucial deadlines, we hope this guide will help you to better understand what is expected as MSAPR compliance comes into effect. 

How Many Parts Are There to MSAPR Regulation? 

There are two parts to MSAPR regulation. The first part has one phase; the second part has two phases. 

At this point, you should have registered all your engines and selected engines for testing and groupings. You should also have chosen whether to use one of two approaches: flat limit or yearly. 

Part One involves one phase: 

  • Registering all modern engines and submitting the first compliance report (as of July 1, 2017).
  • Registering all pre-existing engines (as of January 1, 2019).
  • Selecting a yearly average or flat limit testing approach (as of October 31, 2020).

Part Two involves two phases (with Phase 1 beginning on January 1, 2021). As of this date, there are several things to keep in mind for Phase 1: 

  • NOx limits are in full effect for modern engines.
  • There are, however, options available for pre-existing engines until the 2026 deadline.
  • There are three compliance options (with different requirements) available between 2021 to 2025.
  • Owner/operators may either decide to not group their engines, or can opt for reporting either flat limits or yearly averages.
  • Grouping engines allows owner/operators to take advantage of certain ‘phase-in’ allowances.

Phase 2 involves NOx limits for pre-existing engines. The deadline for Phase 2 is January 1, 2026. As of this date, there are several things to keep in mind: 

  • All engine fleet groupings must meet an average NOx limit of 4 g/kw output or 210 ppmvd at 15% oxygen.
  • Owner/operators can still have individual engines that exceed the 4g/kw emissions threshold, as long as the average of the grouping is still below 4g/kw.
  • Testing will still be required at current frequencies, depending on the engine’s use designation.

Reporting for Phase 2 will have the following requirements: 

  • A Schedule 10 annual report will be due July 1 for the previous year’s results.
  • Engines must be registered within 30 days of ownership transfer.
  • Testing must be completed based on each engine’s requirements. These may depend on lean- or rich-burn, modern or pre-existing, brake power, low and regular use, and its previous testing record. 

For MSAPR, What’s the Difference Between Pre-Existing Engines and Modern Engines? 

The only significant different, according to MSAPR regulation is with the date of manufacture. 

For this reason, the date of September 15, 2016, represents the cut-off between pre-existing engines and modern engines. 

Any engine manufactured before September 15, 2016, is considered pre-existing. Any engine manufactured after this date is considered modern. 

What’s the Difference Between an Emission Check and an Emission Test? 

Emission checks are required more frequently. The timeline for these can vary, depending on whether the engines in question are rich- or lean-burn. 

Emission tests involve a methodology that requires more in-depth and stringent protocols. These include calibrations on site and longer test runs. 

Is It Possible to Convert a Rich-Burn Engine to a Lean-Burn Engine? 

Some control technology can convert a rich-burn engine to a lean-burn. To do so would require establishing the following: when the engine in question is operated at 90% or more of its rated brake power, the excess oxygen in the exhaust gas (without dilution) is greater than or equal to 4%. 

My Engine is Already Lean-Burn – Why Do I Have to Prove This? 

According to MSAPR regulations, lean-burn engines must adhere to less stringent performance testing requirements. 

A manufacturer might have designated an engine as lean-burn even if it isn’t capable of meeting the 4% excess oxygen content. 

For this reason, engine owners and operators interested in less stringent testing requirements must prove that their engine meets the definition of lean-burn. 

Envirosoft’s NOx Manager provides a unique, fit-for-purpose solution to the oil and gas industry for providing a systemized option to overcoming these challenges.  Please contact us today to find out more!