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 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 Mr. Wheeler provides air quality permitting and compliance services for industries such as oil 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 Mr. Berkebile offers over 32 years of experience in the Energy Services Industry. He currently 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 Technology. Working across all market verticals, Mr. Berkebile has experience assisting these customers identify and implement a variety of Demand Management Programs, Distributed Generation and Energy Conservation Measures for various building and industrial energy disciplines. Mr. Berkebile has conducted Energy Audits and Studies to investigate the feasibility of green technologies such as Smart Grid, Solar Hot Water Heating, Solar Photovoltaic, Geothermal, Cogeneration, Wind, Fuel Cells, Micro turbines and battery storage. Mr. Berkebile has extensive experience in the engineering, project development, project management, construction management and facilities management across institutional, commercial, and industrial industries. Mr. Berkebile is currently responsible for leading a team of energy engineers nationwide to provide a variety of Demand Management, Distributed 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 Mr. Ray Berkebile - CPower Mr. DJ Wheeler - Trinity

Federal Engine Regulations – Brief Overview

Federal Regulations Our Focus ˃ 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 NO x NO x Formaldehyde and CO (as surrogates for Total CO CO HAPs) PM Criteria Pollutants HAPs

Federal Regulations Others ˃ 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

Nonroad and Marine Engines

1068.30, 89.2, 90, 91, 94, 1039, 1042, 1045, 1048, 1054 Nonroad and Marine Engines ˃ 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 “Mobile” = Onroad + Nonroad + Marine

Temporary Exemption –Two Big Caveats 1. Replacing one temporary engine with 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 2. An engine to be used temporarily in place of a stationary engine (e.g., while it is being overhauled) is considered a stationary engine 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 Standards of Performance for Stationary [ New] Compression Ignition Internal Combustion Engines (Original proposal for CI ICE NSPS was in 1979; it was never finalized)

60.4200 NSPS IIII Applicability ˃ Potentially applies to:  All stationary compression-ignition engines ♦ Reciprocating, rotary, other (except turbines)  Of any size (horsepower rating)  Emergency & Non-Emergency ˃ If:  C onst 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(b) & (d) Exemptions ˃ 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

60.4204 & 4205 NSPS IIII Emission Standards ˃ Pollutants: NMHC/HC, NO X , NMHC+NO X, 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 NSPS IIII Emission Standards ˃ 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 NSPS IIII Emission Standards ˃ 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

60.4208 Import / Install Deadlines 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 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 12/31/2018 2017 and 10 ≥ Disp. (L) < 30 * 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

60.4211 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

60.4201 Engine Manufacturer Certifications ˃ Engine manufacturers must certify 2007 model year and later engines <30 L/cyl.

60.4207 NSPS IIII Fuel Requirements Cetane is a measure of ignitability of diesel fuel