AIR PERMITTING REQUIREMENTS FOR ON-SITE STATIONARY POWER GENERATING ENGINES

Transcription

1 AIR PERMITTING REQUIREMENTS FOR ON-SITE STATIONARY POWER GENERATING ENGINES MAY 15, 2012 FOR MORE INFORMATION CONTACT NEGIB HARFOUCHE, PH.D. NJDEP DIVISION OF AIR QUALITY (609) DISCLAIMER: Every effort was made to ensure the content of this presentation is identical to the official version of the rules, where applicable. Should there be any discrepancies between the references to the rules in this presentation and the official version of the rules, the official version of the rules will prevail.

2 Engine Regulations Outline N.J.A.C. 7:27-8 (after December 19, 2005) N.J.A.C. 7:27-19 or NOx RACT Rules (after 03/07/2007) NSPS 40 CFR 60 Subpart IIII (CI RICE- after 7/11/2006) NSPS 40 CFR 60 Subpart JJJJ (SI RICE after 6/12/2006) NESHAP for RICE MACT ZZZZ (CI & SI after 12/19/2002)

3 N.J.A.C. 7: : Allowable NOx Limits for New or Modified Engines** >= 37 KW (50 HP) ** Any new or modified electrical generating engine of any HP size, except emergency generator, firing natural gas or diesel fuel. Started operation on or after 3/7/ g NOx/hp.hr Modified on or after 3/7/ g NOx/hp.hr or 90% NOx removal {NJAC 7; (e)3} NOx >= 5 tons/year 0.15 g NOx/hp.hr SOTA Manual (2003) Existing Sub 8 or Sub 22 Air Permit New or Modified Sub 8 or Sub 22 Air Permit NOx RACT Rules

4 NJAC 7: Table 8: Allowable NOx Limits for Existing** Single or Multiple(*) Electric Generators existing means installed and in operation prior to and after 3/7/2007. ** Any existing electrical generating engine of any HP size, except emergency generator, firing natural gas or liquid fuel. Rich- burn firing gaseous or liquid fuel? 1.5 gm NOx/hp.hr At any size facility, Single existing engine rated >= 148 kw (~200 HP), {NJAC 7: (e)1} or multiple engines with a total combined power rated >= 148 kw(*)? {NJAC 7: (e)4} Lean- burn firing gaseous fuel? 1.5 gm NOx/hp.hr or 80% NOx Lean- burn firing liquid or gaseous and liquid fuels? 2.3 gm NOx/hp.hr Sub 8 or Sub 22 Permit (*) Only combined engines individually rated >= 37 kw but < 148 kw. NOx RACT Rules

5 N.J.A.C. 7:27-8: Allowable Limits(*) for Existing, New, Modified or Reconstructed Engines** >= 37 KW (50 HP) (*) CO, VOC/HC and TSP/PM 10, 2.5 ** Any existing or new SI or CI electrical generating engine, except emergency generator, firing natural gas or liquid fuel, respectively. 40 CFR part 63 Subpart ZZZZ or RICE NESHAP CO ppmv or % based on engine HP rating and subcategory whether it s located at a major source or area source of HAP. if yes New (***) RICE located at area source? Meet Stationary Engine 40 CFR 60 NSPS: CI: Part 60 Subpart IIII or SI: Part 60 Subpart JJJJ (***) New, Modified or Reconstructed NJ State Rules: + existing, means installed and in operation prior to or after 3/7/ new or modified, means installed or modified and in operation on or after 3/7/ CFR 63 Subpart ZZZZ Sub 8 or Sub 22 Permit CO {g/hp.hr or 15% O 2 } TSP/PM10/2.5 {g/hp.hr} NOx <= 0.9 g/hp.hr or 90% NOx removal VOC {g/hp.hr} SO2 HAP {i.e. benzene, etc.} ULSD {15 ppmw S} Fuel limit {gal or ft 3 /year} Engines >500 HP at major source of HAP: Existing, if construction commenced before December 19, New, if construction commenced on or after December 19, Reconstructed/modified if reconstruction/modification commenced after December 19, Engines 500 HP located at major source of HAP, and engines of all HP located at an area source of HAP: Existing, if construction commenced before June 12, New, if construction commenced on or after June 12, Reconstructed/modified, if reconstruction/modification commenced after June 12, 2006.

6 HP RICE NESHAP EMISSION STANDARDS EXISTING RICE LOCATED AT MAJOR SOURCES Engine Subcategory n-emergency Emergency CI SI 2SLB SI 4SLB SI 4SRB SI LFG/DG <100 Work practice Work ppm CO 225 ppm CO 47 ppm CO 10.3 ppm CH 2 O ppm CO or 70% CO 177 ppm CO practice > ppm CO or 70% CO (2004 rule) (2004 rule) 350 ppb CH 2 O or 76% CH 2 O (2004 rule) (2004 rule) (2004 rule) Limits in yellow are expected to require emissions control retrofit te: Existing limited use engines >500 HP at major sources do not have to meet any emission. Existing black start engines 500 HP at major sources must meet work practice.

7 RICE NESHAP EMISSION STANDARDS EXISTING RICE LOCATED AT AREA SOURCES HP Engine Subcategory n-emergency CI SI 2SLB SI 4SLB SI 4SRB SI LFG/DG Emergency or Black start 300 Mgmt practice Mgmt practice Mgmt practice Mgmt practice Mgmt practice Mgmt practice ppm CO or 70% CO * > ppm CO or 70% CO * 47 ppm CO or 93% CO ** 2.7 ppm CH 2 O or 76% CH 2 O ** Limits in yellow are expected to require emissions control retrofit *Except engines in rural Alaska **If engine used >24 hrs/yr

8 RICE NESHAP EMISSION STANDARDS NEW RICE LOCATED AT MAJOR SOURCES HP Engine Subcategory n-emergency Emergency CI SI 2SLB SI 4SLB SI 4SRB SI LFG/DG 250 Comply with CI NSPS Comply with SI NSPS Comply with SI NSPS Comply with SI NSPS Comply with SI NSPS Comply with CI/SI NSPS > ppb CH 2 O or 70% CO (also comply with CI NSPS) 12 ppm CH 2 O or 58% CO (also comply with SI NSPS) 14 ppm CH 2 O or 93% CO (also comply with SI NSPS) 350 ppb CH 2 O or 76% CH 2 O (also comply with SI NSPS) (also comply with SI NSPS) (also comply with CI/SI NSPS) Limits in yellow are expected to require emissions control retrofit te: New limited use engines >500 HP at major sources do not have to meet any emission under the NESHAP. New engines may also be subject to the NSPS.

9 NJAC 7: EMERGENCY GENERATORS "Emergency generator" means a combustion source greater than or equal to 37 kw (50 HP) that: 1. Is located at a facility and produces mechanical or thermal energy, or electrical power exclusively for use at the facility; 2. Is the source of mechanical or thermal energy, or electrical power during an emergency when the primary source of energy is unavailable; and 3. Is operated only: i. During the performance of normal testing and maintenance procedures, as recommended in writing by the manufacturer and/or as required in writing by a Federal or State law or regulation; ii. When there is power outage or the primary source of mechanical or thermal energy fails because of an emergency; or iii. When there is a voltage issued by PJM and posted on the PJM internet website ( under the emergency procedures menu. All other uses, i.e. peak shaving, as part of a financial arrangement with another entity, supply power to the grid or for demand response are NOT considered emergency uses and the generator must meet the NOx RACT emission limits. Less than 80 MMBtu/hr (single engine or total combined ratings engines) Complies with NSPS Subpart IIII and burns Ultra Low Sulfur Diesel (if combusting liquid fuel)? Sub 8 or Sub 22 Permit Comply with: i) Work Practice Standards ii) Management Practice Standards &/or iii) Comply with CI/SI NSPS. iv) O&M Testing <= 100 hrs/year General Permit GP-005 NJAC 7: : RECORDKEEPING

10 N.J.A.C. 7: et seq.: How Do I Demonstrate Compliance with NOx RACT Emission Limits? 1. N.J.A.C. 7: : i. Continuous Emission Monitoring (CEM) installed on the engine [NOT COMMON] or ii. Stack Testing based upon the average NOx of three (1)-hr tests, each performed over a consecutive 60-minute period specified by the Department, and performed in compliance with N.J.A.C. 7: , where the engine is operating at maximum achievable load at the ambient conditions of the day of testing. NOx testing shall be conducted concurrently with CO testing. The applicable NOx emission limits will not be considered to have been met unless the concurrent CO testing demonstrates compliance with the CO limit in N.J.A.C. 7: which is CO <= % O 2, or the permit limit for CO, whichever is more stringent, is also met. 2. N.J.A.C. 7: : Annual Combustion Adjustment : Determine concentrations of NOx, CO and Oxygen measured before and after the adjustment was made.

11 N.J.A.C. 7: et seq.: What if I Cannot Meet or Demonstrate Compliance with NOx RACT Emission Limits? The facility can seek approval of one of the following: 1. N.J.A.C. 7: Emissions Averaging for two (2) or more source operations or items of equipment. Facility to submit a written application or emissions averaging plan to the Department in accordance with N.J.A.C. 7: (a), (b) and (c) for approval. or 2. N.J.A.C. 7: Alternate (Maximum) Emission Limit or AEL instead of meeting NOx RACT regulatory. Facility to submit a request for a proposed AEL in accordance with N.J.A.C. 7: (b) for approval. Procedure will require a public comment period. AEL is submitted to EPA for approval as a revision to the State Implementation Plan (SIP) for ozone. Agency review may last from six (6) months up to one year.

12 IN CLOSING... NOx RACT < 37 KW (50 HP) Standards 37 KW (50 HP) at major & area sources New/Reconstructed or Modified 0.9 g NOx/hp.hr or 90% NOx removal Existing engine 148 kw (200 hp) or multiple existing engines with total combined 148 kw (200 hp) March 7, 2007 Dec. 19, 2002 RICE NESHAP Existing New/Reconstructed >500 HP at major source Existing New/Reconstructed June 12, 2006 Existing/New status based on date construction (on-site installation) commenced CI NSPS 500 HP at major source, or any HP at area source New engines 500 HP at major source, or any HP at area source, comply with the RICE NESHAP by complying with the applicable NSPS. July 11, 2005 Constructed (ordered) after 7/11/05 and manufactured after 4/1/06, or modified/reconstructed after 7/11/05 SI NSPS Constructed (ordered) after 6/12/06 and manufactured after 7/1/07-1/1/09, or modified/reconstructed after 6/12/06 NH/ June 12, 2006

13 Where Can I find Typical Requirements for Power Generating Sources on the NJDEP Website? DEP Website: 1. General Permits GP-005: Emergency Generators: 2. DATA Miner Search for Regulated Sites by ID Number Choose Program = Air Examples: Enter: i) ID#35442-PCP Verizon Corporate Services Group Inc. (Stationary Engines) ii) ID#26544-PCP Verizon Wireless (Portable Emergency Generators) iii) ID#18859-PCP Edison Twp. Div of Sewer (Portable Emergency Generators)