Biographical Information DJ Wheeler, Senior Consultant, Trinity - - PDF document
Workshop L Air Permitting Managing Air P rmitting Managing & P & Permitting Y rmitting Your Stationar ur Stationary Internal Combustion Engines Int rnal Combustion Engines Thur Thursda sday, July 20, 20 , July 20, 2017
Air P Air Permitting … Managing rmitting … Managing & P & Permitting Y rmitting Your Stationar ur Stationary Int Internal Combustion Engines rnal Combustion Engines
Thur Thursda sday, July 20, 20 , July 20, 2017 10:30 a.m. t :30 a.m. to noon noon
Biographical Information DJ Wheeler, Senior Consultant, Trinity Consultants 110 Polaris Parkway, Suite 200, Westerville, Ohio 43085 614.433.0733 Fax: 614.433.0734 dwheeler@trinityconsultants.com
and gas, metallurgical coke production, secondary aluminum recycling, petroleum refineries, steel mini-mills, and gas-fired electricity generating units. He has specialized experience with air dispersion modeling, including full impact analyses for PSD permit applications. Mr. Wheeler currently operates as a Senior Consultant in Trinity’s Columbus, Ohio office and is an active member of the Ohio Gas Association’s Environmental Matters Committee. He received a Bachelor’s degree in chemical engineering from the University of Michigan. Raymond G Berkebile, Director of Engineering, CPower 415 McFarlan St, Suite 201, Kennett Square, PA 19348 610-813-2821 | Raymond.Berkebile@CPowerEnergyManagement.com
works for CPower as the Director of Engineering in their Operations division serving Commercial and Industrial customers. In this role he assists customers identifying and implementing Energy Management strategies which include a comprehensive approach to implement Energy Efficiency improvements, Demand Side Management and Green Energy
customers identify and implement a variety of Demand Management Programs, Distributed Generation and Energy Conservation Measures for various building and industrial energy
feasibility of green technologies such as Smart Grid, Solar Hot Water Heating, Solar Photovoltaic, Geothermal, Cogeneration, Wind, Fuel Cells, Micro turbines and battery storage.
management, construction management and facilities management across institutional, commercial, and industrial industries. Mr. Berkebile is currently responsible for leading a team
Generation and Energy Efficient solutions across all vertical markets. Mr. Berkebile has significant experience meeting the needs of commercial and industrial customer’s significant experience analyzing existing systems and then designing, developing and implementing new systems and solutions which meet budget, schedule and design constraints. Registration Professional Engineering in Training Certification with PE License Pending. Professional Affiliations American Society of Heating, Air Conditioning and Refrigeration Engineers (ASHRAE) -- Member Association of Energy Engineers (AEE) -- Member Association of Energy Services Professionals (AESP) – Member Education BSME Widener University
MEC Workshop L – Managing & Permitting Your Stationary Internal Combustion Engines
Columbus, OH – July 20, 2017
Federal Engine Regulations – Brief Overview
Federal Regulations
˃ 40 CFR Part 60 Subpart IIII, S
t andards of Performance for [New] S t at ionary Compression Ignit ion Int ernal Combust ion Engines (CI ICE NSPS)
˃ 40 CFR Part 60 Subpart JJJJ, S
t andards of Performance for [New] S t at ionary S park Ignit ion Int ernal Combust ion Engines (SI ICE NSPS)
˃ 40 CFR Part 63 Subpart ZZZZ, Nat ional Emission
S t andards for Hazardous Air Pollut ant s for S t at ionary Reciprocat ing Int ernal Combust ion Engines (RICE NESHAP)
˃ Also, Subpart A for each Part
Summary of Regulated Engine Pollutants
NSPS JJJJ NSPS IIII RICE MACT VOC NMHC/HC Formaldehyde and CO (as surrogates for Total HAPs) NOx NOx CO CO PM
Criteria Pollutants HAPs
˃ 40 CFR 89 - New and In-Use Nonroad CI Engines
Tiers 1, 2, and 3
˃ 40 CFR 1039 - New and In-Use Nonroad CI Engines
Tier 4
˃ 40 CFR 90 – Nonroad SI Engines < 19 kW ˃ 40 CFR 1048 – New Nonroad SI Engines > 19 kW ˃ 40 CFR 1054 – New Small Nonroad SI Engines ˃ 40 CFR 94 - Marine CI Engines
Tier 2
˃ 40 CFR 1042 - New and In-use Marine CI Engines
Tiers 3 and 4
˃ 40 CFR 91 - Marine SI Engines ˃ 40 CFR 1045 – Marine SI Engines
˃ For more informat ion, e.g., hist ory, about Tier
st andards, ht t p:/ / www.dieselnet .com/ st andards
Federal Regulations Others
˃ Not subject to IIII, JJJJ, & ZZZZ ˃ Marine ICE…an integral part of a marine vessel ˃ Nonroad (or “Non-road”) engine means any ICE
that is in or on a piece of equipment that is…
self-propelled (may serve other purposes too); or propelled while performing its function; or portable or transportable
♦ Designed to be moved, e.g., on wheels or skids, etc. ♦ And actually is moved routinely ♦ Portability is moot if it remains [in service] at a location
(building, structure, facility, or installation)…
– for more than 12 months…or… – for seasonal sources, for the entire season (3 months or more) for at least 2 years 1068.30, 89.2, 90, 91, 94, 1039, 1042, 1045, 1048, 1054
“Mobile” = Onroad + Nonroad + Marine
Temporary Exemption –Two Big Caveats
another to be used for the same purpose does not restart the 12-month clock
The 12-mont h clock applies t o t he locat ion and purpose, not a part icular engine
a stationary engine (e.g., while it is being
The locat ion and purpose is st at ionary even if it consist s of more t han one engine over t ime
NSPS IIII
(Original proposal for CI ICE NSPS was in 1979; it was never finalized)
˃ Potentially applies to:
All stationary compression-ignition engines
♦ Reciprocating, rotary, other (except turbines)
Of any size (horsepower rating) Emergency & Non-Emergency
˃ If:
Const ruct ed (ORDERED) after 7/11/2005 and
manufact ured after 4/1/2006
Modified or reconst ruct ed after 7/11/2005
60.4200
˃ Engines at test stands ˃ National security exemption (upon
request)
Informal indications are that this is meant
for true military purposes
˃ Engines manufactured as certified NFPA
fire pump engine before 7/1/06 or modified/reconstructed to meet NFPA certification before 7/11/05
60.4200(b) & (d)
˃ Pollutants: NMHC/HC, NOX, NMHC+NOX,
CO, PM
˃ The rule is modeled after the mobile
(nonroad and marine) standards
˃ General engine categories:
Per-cylinder displacement < 10 L 10 L ≥ per-cylinder displacement > 30 L Per-cylinder displacement ≥ 30 L Emergency Fire pump 60.4204 & 4205
˃ For displacement < 10 L/cylinder
Meet nonroad “Tier” standards
♦ Tiers 1, 2, & 3 in 89.112 ♦ Tier 4 in 1039.102 ♦ Specific requirements depend on use, model
year, displacement, and power
Emergency engines are exempt from the
most stringent (Tier 4) standards
Delayed schedule for fire pump engines 60.4204 & 4205
˃ For 10 L/cylinder ≥ Displacement < 30
L/cylinder
“Tier” standards for marine engines
♦ Tier 2 in Part 94; Tiers 3 and 4 in Part 1042
Emergency engines are exempted from most
stringent (i.e., Tier 4) standards
˃ For Displacement ≥ 30 L/cylinder
Standards for large marine engines
♦ Achievable via the use of SCR & ESP
60.4204 & 4205
Regardless of manufacture date, i.e., so for old engines, certain engines imported or installed after the following dates must meet the emission standards for the previous model year
60.4208
Type / Size Import/Install Deadline Model Year Standards All (excluding fire pump ICE) 12/31/2008 2007 HP < 25 12/31/2009 2008 25 ≥ HP < 75 12/31/2014 2013 75 ≥ HP < 175 12/31/2013 2012 HP ≥ 175 12/31/2012 2011 HP ≥ 750 12/31/2016 2015 804 ≥ HP < 2680 and 10 ≥ Disp. (L) < 30 12/31/2018 2017
* These provisions were added to prevent stockpiling of earlier Tier engines. ** They do not apply to modified or reconstructed or moved (from one plant site to another) engines
NSPS IIII Compliance Requirements
˃ Displacement < 30 L/cylinder
Purchase certified engine and follow
manufacturer instructions or
Conduct initial testing (and subsequent testing if
> 500 hp) and
Develop and follow a maintenance plan If pre-2007 model year, additional options:
♦ Test of a similar engine or data from engine
manufacturer or control vendor indicating compliance
˃ Displacement ≥ 30 L/cylinder
Testing and control device monitoring
60.4211
Engine Manufacturer Certifications
˃ Engine manufacturers must certify 2007
model year and later engines <30 L/cyl.
60.4201
60.4207 Cetane is a measure of ignitability of diesel fuel
See discussion of definition and operational
requirements in MACT ZZZZ section
60.4211(f)
NSPS JJJJ
˃ Potentially applies to:
All stationary spark-ignition engines
♦ Reciprocating, rotary, other (except turbines)
Of any size (horsepower rating) That fires any fuel Emergency & Non-Emergency
˃ Exemptions:
Engines at test stands National security exemption (upon request)
60.4230
Owners/operators of ICE modified or reconstructed after 6/12/2006
Constructed (ORDERED) after 6/12/2006 and manufactured after…
60.4230, 4236
Type / Size Manufactured Date ≥ 500 HP except LB 500 ≤ HP < 1350 7/1/2007 LB 500 ≤ HP < 1350 1/1/2008 < 500 hp 7/1/2008 Emergency > 25 hp 1/1/2009 If < 25 hp, no emergency / non‐emergency differentiation
˃ Emission standards for HC/NMHC, NOX, CO,
and VOC (excluding CH2O)
Depends on use, fuel, model year, and power
˃ All engines ≤ 25 hp
All are certified by the manufacturer to standards
in 90 or 1054
˃ Engines > 25 hp
Purchase volunt arily certified engine (standards in
1048 or Table 1) and follow manufacturer’s instructions or
Test and develop/follow a maintenance plan
Any gasoline must meet 80 ppm sulfur limit (40 CFR 80.195) 60.4233, 4235, 4244(f)
Regardless of manufacture date, i.e., so for very old engines, any engines imported or installed after the following dates must meet the emission standards of 60.4233
60.4236
Type / Size Manufactured Date ≥ 500 HP except LB 500 ≤ HP < 1350 7/1/2007 LB 500 ≤ HP < 1350 1/1/2008 < 500 hp 7/1/2008 Emergency > 25 hp 1/1/2009 Import/Install Deadline 7/1/2009 7/1/2010 7/1/2010 1/1/2011
* These provisions were added to prevent stockpiling of earlier Tier engines. ** They do not apply to modified or reconstructed or moved (from one plant site to another) engines
Non-Emergency and Emergency ICE
˃ Purchase a certified engine
Follow mfr. Instructions…–or– maintenance plan
Upon loss of certification, initial performance test if ≥100 hp (within 1 year) and subsequent* performance tests if >500 HP
Cannot comply via non-cert ified opt ions
˃ Non-certified Engines
Maintenance plan
Initial performance test if ≥25 hp
♦ Within 60/180 days
Subsequent* performance tests and initial notifications if >500 HP
* Every 8,760 hours or 3 years, whichever is first
60.4243
Required for: ≤ 25 hp; > 25 hp gasoline; > 25 hp RB LPG Required for: Modified and reconstructed engines
˃ See discussion of definition and operational
requirements in MACT ZZZZ section
˃ Certain (depending on power and build date)
emergency SI ICE not meeting non-emergency emissions standards must have a nonresettable hour meter:
HP ≥ 500 HP “built” on or after 7/1/2010 130 ≤ HP < 500 “built” on or after 1/1/2011 HP < 130 “built” on or after 7/1/2008
“ built ” = “ manufact ured” based on reading of preambles
60.4243(d) & 4237
NESHAP ZZZZ
˃ Applies to all stationary reciprocating ICE ˃ Exemptions:
Engines at test stands National security exemption (upon request) Existing, emergency engines at residential,
commercial, and institutional area sources…
♦ that do not operate and are not contractually obligated to
be available for more than 15 hr/yr for emergency demand response or voltage or frequency deviations
♦ that do not supply power as part of a financial
arrangement with another entity
What if a headquarters “commercial” office
building is co-located with a manufacturing plant?
♦ Informally EPA has said that engines providing backup power
to the HQ building are exempt 63.6585
˃ Determination based on “commence construction”
date (start of on-site construction, not ordered)
˃ What if an engine is relocated to a new facility?
Relocation and/or a change in ownership of an existing RICE does not make it new
63.6590(a)
Potential RICE MACT Requirements
˃ Emission limits (CO and CH2O) ˃ Continuous & monthly monitoring (T and ΔP)
Monitoring system evaluations
˃ Stack testing (emissions or catalyst activity) ˃ Reporting and notifications ˃ Management/work practices (maintenance) ˃ Hour meter ˃ Plans (testing, monitoring, maintenance) ˃ Recordkeeping
Overview of Requirements for Existing CI Engines
Source Status Use category Rating Emission Limit(s) Control Device Monitor Initial Perform. Test Ongoing Perform. Test Initial Notif./ Comp Reports Work Practices/
Hour Meter
Major Non‐Emergency > 500 HP
Non‐Emergency 300 – 500 HP
Non‐Emergency 100 – 300 HP
Non‐Emergency < 100 HP
Emergency ≤ 500 HP
Emergency > 500 HP No MACT Requirements Limited Use > 500 HP No MACT Requirements Limited Use ≤ 500 HP No Such Category – Limited Use Provisions Only Apply to Existing RICE if > 500 HP Area Non‐Emergency > 500 HP
Non‐Emergency 300 – 500 HP
Non‐Emergency < 300 HP
Emergency Any
Note: Sometimes it is better to NOT be an emergency engine (same scenario with SI engines too)
Overview of Requirements for New CI Engines
Source Status Use category Rating Emission Limit(s) Control Device Monitor Initial Perform. Test Ongoing Perform. Test Initial Notif./ Comp Reports Hour Meter
Major Non‐Emergency > 500 HP
Non‐Emergency ≤ 500 HP Comply with NSPS Only Emergency > 500 HP IN only
Emergency ≤ 500 HP Comply with NSPS Only Limited Use > 500 HP
IN only
NAbS Limited Use ≤ 500 HP Comply with NSPS Only Area ALL ALL Comply with NSPS Only
Overview of Requirements for Existing SI Engines
Source Status Use category ICE Type Rating Emission Limit(s) Control Device Monitor / Engine Shutdown Initial Perform. Test / Cat. Activity Check Ongoing Perform. Test / Cat. Activity Check Initial Notif./ Comp Reports Work Practices/
Hour Meter
Major Non‐Emergency 4SRB > 500 HP
Non‐Emergency 2SLB, 4SLB > 500 HP No MACT Requirements Non‐Emergency Landfill/Digester Gas > 500 HP No MACT Requirements Non‐Emergency 2SLB, 4SLB, 4SRB 100 – 500 HP
Non‐Emergency Landfill/Digester Gas 100 – 500 HP
Non‐Emergency 2SLB, 4SLB, 4SRB < 100 HP
Non‐Emergency Landfill/Digester Gas < 100 HP
Emergency Any ≤ 500 HP
Emergency Any > 500 HP No MACT Requirements Limited Use Any > 500 HP No MACT Requirements Limited Use Any ≤ 500 HP No Such Category – Limited Use Provisions Only Apply to Existing RICE if > 500 HP Area Non‐Emergency 4SLB, 4SRB > 500 HP
Non‐Emergency 4SLB, 4SRB if <24 hrs/yr or remote > 500 HP
Non‐Emergency 4SLB, 4SRB ≤ 500 HP
Non‐Emergency 2SLB Any
Non‐Emergency Landfill/Digester Any
Emergency Any Any
Overview of Requirements for New SI Engines
Source Status Use category ICE Type Rating Emission Limit(s) Control Device Monitor Initial Perform. Test / Cat. Activity Check Ongoing Perform. Test / Cat. Activity Check Initial Notif./ Comp Reports Hour Meter
Major Non‐Emergency 4SRB > 500 HP
Non‐Emergency 2SLB > 500 HP
Non‐Emergency 4SLB > 500 HP
Non‐Emergency 4SLB If manf’d ≥ 1/1/08 250 – 500 HP
Non‐Emergency 4SLB If manf’d < 1/1/08 250 – 500 HP No MACT Requirements Non‐Emergency 4SRB ≤ 500 HP Comply with NSPS Only Non‐Emergency 2SLB ≤ 500 HP Comply with NSPS Only Non‐Emergency 4SLB < 250 HP Comply with NSPS Only Non‐Emergency Landfill/Digester Gas > 500 HP I.N. & Fuel usage Non‐Emergency Landfill/Digester Gas ≤ 500 HP Comply with NSPS Only Emergency ALL > 500 HP I.N. only
Emergency ALL ≤ 500 HP Comply with NSPS Only Emergency 4SLB If manf’d ≥ 1/1/08 250 – 500 HP
Limited Use ALL > 500 HP
I.N. only
NAbS Limited Use ALL ≤ 500 HP Comply with NSPS Only Area ALL ALL ALL Comply with NSPS Only
˃ Minimize startup and idling time (30
minutes)
Startup means the time from initial start
until applied load and engine and associated equipment (including catalyst) reaches steady state or normal operation
How do you demonstrate compliance?
♦ Log startups, durations? ♦ Point to startup procedure?
63.6625 & 6640
˃ Develop and follow maintenance plan
Or manufacturer’s emissions-related instructions
˃ Oil & filter changes on specified frequencies
Generally, 4320 hrs for 2S; 1440 for 4S; 1000 hrs for
CI, and 500 hrs for emergency RICE
Optional oil analysis program
˃ Inspections of spark plugs, belts, and hoses on
specified frequencies
Generally, 4320 hrs for 2S; 1440 for 4S; 500 hrs for
CI, and 500 or 1000 hrs for emergency RICE ˃ Maintenance documentation will be key
Tables 1 – 4, 63.6625(e)
Parameter Condemning Limits Total Base Number (TBN) – CI < 30% of new oil Total Acid Number (TAN) – SI Increases by more than 3.0 mg of potassium hydroxide per gram from TAN of new oil Viscosity Changed by more than 20% from the viscosity of new oil % Water Content by Volume > 0.5 %
˃ Oil analysis must be performed at same frequency
specified for oil changes
˃ If condemned, change oil within 2 business days ˃ Must keep records of the analysis
˃
You can petition EPA for use of alternative parameters
˃
But these are fairly generous already
˃
“Our informal guidance has been that it would also extend the time for the filter change” ‐ EPA 63.6625(i) & (j)
˃ Operations logs ˃ Records of startups and idling periods ˃ Inspections / checklists ˃ Maintenance logs ˃ Document control
Engines with NO Requirements
˃ Technically, still “affected sources” ˃ At major sources, existing RICE > 500 hp:
SI 2SLB SI 4SLB Emergency
♦ If it does not operate and is not contractually obligated to
be available for more than 15 hr/yr for emergency demand response or voltage or frequency deviations Limited use (LU) Landfill or digester gas (LG/DG)
(>10% gross heat input annually)
63.6590(b)(3)
Original floor was ‘no control’. Will be reconsidered…in 8 years
Engines Subject To Limited Requirements
˃ At major sources, new and reconstructed
RICE > 500 hp:
Emergency
♦ If it does not operate and is not contractually obligated to be
available for more than 15 hr/yr for emergency demand response or voltage or frequency deviations
♦ Initial notification only
Limited use
♦ Initial notification only
Landfill or digester gas
♦ Initial notification and daily fuel monitoring & reporting
63.6590(b)(1) & (2)
Some Important Definitions Emergency RICE
˃ The RICE is operated to provide
electrical power or mechanical work during an emergency situation
˃ Examples:
Power generation during normal supply
int errupt ions
Pumping water for fire suppression or flood
control
˃ Operational limitations in 63.6640(f)
63.6675
Emergency Use Requirements
˃ No time limit on emergency operation ˃ 100 hrs/yr* of non-emergency operation for:
Maintenance checks and readiness testing
Emergency demand response (DR)
♦ For NERC-declared Energy
Emergency Alert Level 2 periods
During voltage or frequency deviations of ≥ 5%
˃ 50 hrs/yr* of the 100 hrs/yr* can be used for…
Any situation as long as there is no financial arrangement
For existing area source emergency RICE,
♦ Local reliability
63.6640(f)
Vacated on May 2, 2016 by D.C. Circuit Court. * Calendar year basis
Emergency Engine Records & Reporting
˃ Non-resettable hour meter
Software (e.g., a PLC) is okay if tamper-proof /
non-resettable (unofficial determination)
˃ Reporting for emergency RICE > 100 HP if…
Operated or contractually obligated to be available >
15 hours per year in emergency demand response
Operated for periods where there is deviation of
voltage or frequency ≥ 5%
Operated for local grid system reliability Annual reporting via EPA’s Compliance and Emissions
Data Reporting Interface beginning for operation during 2015 calendar year (due 3/31/2016)
63.6650(h)
˃ Agency: Ohio EPA ˃ Emergency generators ≤ 50 hp that burn
gasoline, natural gas, distillate oil, or liquid petroleum gas and that, as applicable, comply with NSPS IIII/JJJJ and RICE MACT are exempt from permitting [OAC 3745-31-03(B)(1)(oo)]
˃ “Emergency engine” definition includes
emergency DR
˃ PBR for Emergency Engines > 50 hp
Limited to 500 hours per rolling 12-month period
Use for non-emergency DR prohibited
Fire only gasoline, natural gas, distillate oil, or liquid petroleum gas and that, as applicable, comply with NSPS IIII/JJJJ and RICE MACT
Maintain following records:
♦ Monthly records that contain rolling 12-month
summation of operating hours
♦ Records that show type of fuel used ♦ Records of the total time operated in emergency
situations
One-time notification using OEPA Form for Emergency Generator/Pump/Compression is required to be submitted to local Ohio EPA office
♦ No fee, no expiration
Permit-to-Install/Operate (PTIO)
˃ Engines >50 hp and can’t qualify for PBR or
de minimis exemptions
˃ Source with PTE <10 lbs/day of an air pollutant may
qualify for a de minimis exemption per OAC 3745-15- 05(D) if records maintained to demonstrate that actual emissions do not exceed 10 lbs/day and other
de minimis criteria are met
˃ PTIO application requires PFD, emission
documentation, regulatory applicability, Best Available Technology (BAT) review, air dispersion modeling (if necessary), and appropriate application forms
˃ Typical agency review time: 4-6 months
˃ Applies to
Existing stationary ICE located in Ashtabula,
Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, or Summit County.
New stationary ICE located anywhere in
Ohio.
˃ NOX limit for engines > 2,000 HP = 3.0
gm/bhp-hr
˃ Emergency engines are exempt
Impact of Federal Rule 100-Hour Vacatur
˃ Ohio EPA has indicated they will update
regulations to be consistent with federal rules, but timing unknown
˃ September 2016 meeting w/ CPower
State definition of emergency engine still
includes emergency DR despite federal vacatur
Engines may be non-emergency in a federal
context but would still be emergency engines in the State of Ohio
Such engines remain eligible for PBR coverage
˃
Emergency DR Participation?
May participate as long as comply with PBR provisions
This would change if OEPA revises the state definition of “emergency engine” to exclude emergency DR
˃
Economic DR Participation?
Must meet all criteria in OAC 3745-31- 01(NN)(2)(d)(i)-(v) which are functionally identical to 40 CFR 63.6640(f)(4)(ii)(A)-(E), or
Requires Permit to Install and Operate
Terms of permit negotiated case-by-case
Case Study: Evaluation of Ohio EPA Requirements
Questions?