Webinar Series Power Generation 201 Best Practices for Emergency - - PowerPoint PPT Presentation

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Webinar Series Power Generation 201 Best Practices for Emergency - - PowerPoint PPT Presentation

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Webinar Series Power Generation 201 Best Practices for Emergency and Non-Emergency Power November 13, 2019 1:00 2:00 pm ET 2 Q&A Q&A Attendees phone lines are muted to preserve audio quality. Submit a question via

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Webinar Series Power Generation 201 – Best Practices for Emergency and Non-Emergency Power

November 13, 2019 1:00 – 2:00 pm ET

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  • Attendees phone

lines are muted to preserve audio quality.

  • Submit a question

via the Q&A box, not the Chat.

  • Ask “All Panelists”

Q&A Q&A

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SLIDE 3

The Diesel Technology Forum is supported by leaders in advanced diesel engines, vehicles, equipment, components and fuels.

  • AGCO
  • Bosch
  • Caterpillar Inc.
  • CNH Industrial
  • Cummins Inc
  • Daimler
  • Deere & Company
  • FCA
  • General Motors
  • Isuzu Motors
  • Johnson Matthey
  • Mazda North American Operations
  • MTU America
  • Neste
  • Renewable Energy Group
  • Tenneco
  • Umicore
  • Volvo Group
  • Yanmar

Allied Members

  • National Biodiesel Board
  • Western States Petroleum Association
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  • What are the federal rules that cover the installation and operation of

emergency and non-emergency source of power generation?

  • What is required of equipment owners?
  • What is required of equipment manufacturers?

Topics

  • pics Co

Cover ered T ed Today

  • day

The views and opinions expressed in this course shall not be considered the official position of any regulatory

  • rganization and shall not be considered to be, nor be relied upon as, a formal interpretation.

Participants are encouraged to refer to the entire text of all referenced documents. In addition, when it doubt, reach out to the Authority Having Jurisdiction.

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Moderator Ezra Finkin Policy Director The Diesel Technology Forum

Your Pr

  • ur Presen

esenter ters

Speaker T.J. Tarabulski Global Regulatory Consultant Caterpillar, Inc. Speaker Michael Sanford Technical Marketing Specialist Cummins, Inc. Speaker Brian Ponstein Senior Application Engineer MTU a Rolls Royce solution

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RECAP FR RECAP FROM OM 101 W 101 Webinar binar

  • Unique attributes of diesel technology make stationary and portable

diesel emergency generators a ideal choice

  • Federal rules and local permitting requirements cover the use of this

equipment

  • Real world use of this equipment in the field may place limitations on

the suitability of aftertreatment technologies

  • State of the art solution rests on Tier 2 solutions
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Wha hat ar t are the e the Rules Go ules Gover erning ning Equipment Installa Equipment Installation? tion?

We will Focus on these Rules for Compression Ignition, or Diesel Engines

We might be familiar with the emissions requirements for things that move…but what about stationary engines that generate power?

Gensets are the

  • nly power

generation certified by the manufacturer

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SLIDE 8

What is NSPS?

New Source Performance Standards

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SLIDE 9

What is NSPS?

New Source Performance Standards

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What is NSPS?

New Source Performance Standards

Source of emissions, when manufactured or installed

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SLIDE 11

What is NSPS?

New Source Performance Standards

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SLIDE 12

What is NSPS?

New Source Performance Standards

Emissions limits, operational guidelines and test methodologies

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SLIDE 13

What is NSPS?

New Source Performance Standards

Emissions limits, operational guidelines and test methodologies Source of emissions, when manufactured or installed

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SLIDE 14

What is NSPS?

New Source Performance Standards

Emissions limits, operational guidelines and test methodologies Applies to New Modified or Reconstructed Stationary Emissions Sources, Approximately 90 NSPS Regulated Emissions Sources Only Stationary Engines and Woodstoves are manufacturer Certified! Remaining 88 Sources are tested on-site at the State level

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Requirements for EPA Certified Engines

What is Required for an Emergency Generator & What is Required for Non- Emergency Generator Engines Are Certified….not Gensets!

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Requirements for EPA Certified Engines

  • Engines are certified, not generator sets.
  • Engines are required to meet emissions levels based on their date of manufacture,

usage and brake horsepower rating.

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Purpose of Engine Operation Engine Type Emergency Non-Emergency Emergency Non-Emergency Emergency Non-Emergency Emergency Non-Emergency Emergency Vacated May 1, 2016 Non-Emergency Emergency Non-Emergency Emergency Non-Emergency 50 100 Unlimited Engine Hours/Year Key -

Allowed Prohibited

(f)(3)(i) Testing and Maintenance Storm Avoidance Owner Operator Peaking Independent System Operator Peaking (f)(2)(ii)&(iii) Local Grid Financial Arrangement (local demand response) Emergency (loss of normal power) Independent System Operator (ISO) Demand Response (f)(2)(i) (f)(3) (f)(3)(i) (f)(1) (f)(2)(ii)&(iii) 40 CFR 60.4211 Allowable Hours of Operation/Year

U.S. EPA Emergency Engine Redefined: Demand Response Disallowed

State and local requirements may differ from the above interpretations.

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Ca Case se St Stud udy: y: A ho A hosp spita ital l wan ants ts to to inst install all a st a stan andb dby y ge gene nerato tor. . W Wha hat t ha happ ppen ens s ne next xt?

Major Population Centers are Located in Regions not in attainment for federal air quality standards Regional and state policymaker need to develop, submit and receive approval for State Implementation Plans to make sure sources of emergency and non-emergency power are in keeping with the air quality needs of the region.

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  • Your state air pollution control or air quality office is your friend. These officials can walk

you through what is required in the region/locality

  • Power Generator dealers can facilitate this conversation.
  • Be wary of consultants – do your homework

Wha hat t Sh Shou

  • uld

ld Ou Our r Ho Hosp spita ital l in in Ou Our r Fict Fictiona ional l Sta State te do do to to I Ins nsta tall ll Sta Stand ndby by Power er?

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  • Equipment should be maintained and tested in accordance with EPA rules and

local requirements as outlined in the permit.

  • Are you now required to test equipment?
  • Engines are certified when they leave the factory and certification tests are the

responsibility of manufacturers

  • Facility owners should be consider spot checks as opposed to performance tests that are

the responsibility of manufacturers.

Our Hos Our Hospital Has Inst pital Has Installed a alled a Gener Generator tor. . W Wha hat Ne t Next? xt?

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Man Many y Main Mainte tena nanc nce e Req equir uirem emen ents ts for

  • r

Equ Equipmen ipment t Owne Owners

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  • Emergency: Typically 5 minutes in duration or less. Most customers

experiencing an outage longer than 5 minutes will experience an average outage of 112 minutes. Ho How w ar are Em e Emer erge genc ncy y Un Units its Us Used ed in in th the e Real eal Wor

  • rld?

ld?

  • Equipment Owners: EPA testing

requirement

  • Manufacturers: Emissions standards

Best Available Control Technology Emergency Generator Tier 2 – Above 560 kW mechanical Tier 3 – Under 560 Kw mechanical

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Ho How Ar w Are Non e Non-Emer Emergenc gency y Units Used in the R Units Used in the Real W eal Wor

  • rld

ld

Best Available Control Technology Non-Emergency Generator All kW mechanical = Tier 4 Equipment Owners - need for proper maintenance to keep equipment performing as manufactured and certified Manufacturers - Industry is willing to work with policymakers on workable enforcement rules Examples = setting limits for very low NOx limits including run times for emergency use (Mike has case study on a fictional state)

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Requir equirements R ements Regar garding ding Testing of esting of Units Units

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SLIDE 25

“State and local agencies are not prevented from providing additional regulations beyond these regulations and such agencies may institute additional testing requirements independent of EPA related actions.”

Response to Public Comments on Proposed Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

States have the authority to conduct additional tests beyond US EPA

  • requirements. EPA does not require site emissions tests for manufacturer

certified products. Additional emissions tests add no value for end users or States for properly maintained certified engines

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SLIDE 26

State / City / County Requirements

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SLIDE 27

State / City / County Requirements

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SLIDE 28

State / City / County Requirements

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On-Site Testing

  • Non-standard equipment may be needed to

secure air-permit / conduct on-site testing:

  • Fuel flow meter(s)
  • Pollutant monitor(s)
  • Exhaust sample port(s)
  • Load banks
  • Test methodology and permit data must be

verified by equipment manufacturer.

  • Applicable environmental correction factors

allowable by AHJ must be identified.

  • Costs and time associated with on-site testing

requirements must be considered.

  • Review air permit requirements early in the

project in order to accommodate lead times.

  • Leverage experience of third-party testing

companies and engine manufacturers.

  • Review implications of failing on-site test

including penalties and project delays.

  • Permitted emissions values may need to be

provided by the engine manufacturer.

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On-Site Testing

  • Non-standard equipment may be needed to

secure air-permit / conduct on-site testing:

  • Fuel flow meter(s)
  • Pollutant monitor(s)
  • Exhaust sample port(s)
  • Load banks
  • Test methodology and permit data must be

verified by equipment manufacturer.

  • Applicable environmental correction factors

allowable by AHJ must be identified.

  • Costs and time associated with on-site testing

requirements must be considered.

  • Review air permit requirements early in the

project in order to accommodate lead times.

  • Leverage experience of third-party testing

companies and engine manufacturers.

  • Review implications of failing on-site test

including penalties and project delays.

  • Permitted emissions values may need to be

provided by the engine manufacturer.

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SLIDE 31

On-Site Testing

  • Non-standard equipment may be needed to

secure air-permit / conduct on-site testing:

  • Fuel flow meter(s)
  • Pollutant monitor(s)
  • Exhaust sample port(s)
  • Load banks
  • Test methodology and permit data must be

verified by equipment manufacturer.

  • Applicable environmental correction factors

allowable by AHJ must be identified.

  • Costs and time associated with on-site testing

requirements must be considered.

  • Review air permit requirements early in the

project in order to accommodate lead times.

  • Leverage experience of third-party testing

companies and engine manufacturers.

  • Review implications of failing on-site test

including penalties and project delays.

  • Permitted emissions values may need to be

provided by the engine manufacturer.

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SLIDE 32

On-Site Testing

  • Non-standard equipment may be needed to

secure air-permit / conduct on-site testing:

  • Fuel flow meter(s)
  • Pollutant monitor(s)
  • Exhaust sample port(s)
  • Load banks
  • Test methodology and permit data must be

verified by equipment manufacturer.

  • Applicable environmental correction factors

allowable by AHJ must be identified.

  • Costs and time associated with on-site testing

requirements must be considered.

  • Review air permit requirements early in the

project in order to accommodate lead times.

  • Leverage experience of third-party testing

companies and engine manufacturers.

  • Review implications of failing on-site test

including penalties and project delays.

  • Permitted emissions values may need to be

provided by the engine manufacturer.

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SLIDE 33

On-Site Testing

  • Non-standard equipment may be needed to

secure air-permit / conduct on-site testing:

  • Fuel flow meter(s)
  • Pollutant monitor(s)
  • Exhaust sample port(s)
  • Load banks
  • Test methodology and permit data must be

verified by equipment manufacturer.

  • Applicable environmental correction factors

allowable by AHJ must be identified.

  • Costs and time associated with on-site testing

requirements must be considered.

  • Review air permit requirements early in the

project in order to accommodate lead times.

  • Leverage experience of third-party testing

companies and engine manufacturers.

  • Review implications of failing on-site test

including penalties and project delays.

  • Permitted emissions values may need to be

provided by the engine manufacturer.

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SLIDE 34

On-Site Testing

  • Non-standard equipment may be needed to

secure air-permit / conduct on-site testing:

  • Fuel flow meter(s)
  • Pollutant monitor(s)
  • Exhaust sample port(s)
  • Load banks
  • Test methodology and permit data must be

verified by equipment manufacturer.

  • Applicable environmental correction factors

allowable by AHJ must be identified.

  • Costs and time associated with on-site testing

requirements must be considered.

  • Review air permit requirements early in the

project in order to accommodate lead times.

  • Leverage experience of third-party testing

companies and engine manufacturers.

  • Review implications of failing on-site test

including penalties and project delays.

  • Permitted emissions values may need to be

provided by the engine manufacturer.

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SLIDE 35

On-Site Testing

  • Non-standard equipment may be needed to

secure air-permit / conduct on-site testing:

  • Fuel flow meter(s)
  • Pollutant monitor(s)
  • Exhaust sample port(s)
  • Load banks
  • Test methodology and permit data must be

verified by equipment manufacturer.

  • Applicable environmental correction factors

allowable by AHJ must be identified.

  • Costs and time associated with on-site testing

requirements must be considered.

  • Review air permit requirements early in the

project in order to accommodate lead times.

  • Leverage experience of third-party testing

companies and engine manufacturers.

  • Review implications of failing on-site test

including penalties and project delays.

  • Permitted emissions values may need to be

provided by the engine manufacturer.

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SLIDE 36

Caterpillar: Confidential Green

NSPS Permit Streamlining: Why Now?

  • 1. Understanding emissions levels accurately is critical for permitting stationary

engines.

  • 2. Customers have to meet Federal and State Requirements which can vary and

certified product is not easily modified.

  • 3. Site Emissions Tests conducted by states use different methods than mfr’s are

required to use for certification.

  • 4. PM 2.5 NAAQS and GHG Regulations have added additional reporting

requirements for end users.

  • 5. CI, SI engines and woodstoves are the only U.S. EPA manufacturer Certified

NSPS Category.

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Caterpillar: Confidential Green

EMA Recommendations

1. Wherever possible, harmonize any State-specific emissions limits for stationary engines with the NSPS. 2. Wherever possible, SI and CI NSPS-manufacturer certified emergency (CI Tier 2/Tier 3) and non-emergency (CI Tier 4) products should be considered BACT for PSD (attainment areas) and LAER for NSR (non-attainment areas) permits without further testing. 3. Minimize and streamline permitting requirements for sources using NSPS-certified engines. 4. Eliminate requirements for any additional source testing of stationary engines that are NSPS-certified, utilizing manufacturer supplied data (see Attachment 1) to estimate annual emissions (tons/year). 5. Accept engine manufacturer’s certified emissions test results and owner/operator maintenance records as a demonstration of compliance. 6. In those instances where source testing is necessary (e.g. renewal of permits), utilize EMA recommended test methods and reporting template (see Attachment 1) including for formaldehyde and its surrogates.

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Caterpillar: Confidential Green

Manufacturer Emissions Report

  • Applicable Emissions Standard
  • Applicable Certified Family Cycle-Weighted Results
  • Permit Value (PV) - Emissions at 100% engine load and rpm for “Potential to

Emit” calculation

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SLIDE 39

Caterpillar: Confidential Green

Permit Value:

Manufacturer Nominal Value

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  • Federal New Source Performance Standards govern the installation

and use of stationary generators for emergency & non-emergency use

  • Manufacturers are required to meet specific emissions requirements
  • f this equipment
  • Often state and local rules regarding use and testing are confusing

and even counter-productive

  • There is an industry solution that can meet federal rules and local

needs to safeguard air quality

Summing up t Summing up the D he Discus iscussion sion

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41

  • Attendees phone

lines are muted to preserve audio quality.

  • Submit a question

via the Q&A box, not the Chat.

  • Ask “All Panelists”

Q&A Q&A

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42

Thank Y hank You!

  • u!

Please contact us with any questions or concerns at dtf@dieselforum.org