Regulatory and Permitting Requirements of Stationary Generators In Delaware

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1 Regulatory and Permitting Requirements of Stationary Generators In Delaware Delaware - DNREC Air Quality Management February 7, 2006 Mark A. Prettyman and Guadalupe J. Reynolds

2 Outline Regulation No Control of Stationary Generator Emissions Affected Sources (Generators in DE) Background on Development Requirements Permitting of Stationary Generators Permitting Requirements prior to Regulation No Amendment. Permitting Requirements after Regulation No Amendment and Adoption of Regulation No Additional Permit Requirements. 2

3 Generators in Delaware 2 municipal power plants with peaking generators: One with 5 generators: 7 MW total One with 2 generators: 1.8 MW total 1 company with 4 peaking generators at 3 different facilities: 2.7 MW total Approx. 215 distributed generators in Delaware Electric Cooperative Interruptible Service Program (primarily on poultry farms). Approx emergency generators located at poultry farms throughout the state (ranging in sizes from 40 kw to 150 kw). 3

4 Other Generators At least 180 diesel emergency generators (from 125 kw 2.0 MW) are known to be present at companies/facilities in Delaware, for a total generating capacity of over 85 MW. If all were part of a demand response program, this would be a significant benefit in times of need. If all were part of a demand response program and ran for 1 hour, collectively they would emit OVER ONE (1) TON OF NOx EACH HOUR. This is more NOx per hour than most of Delaware s EGUs or peaking units emit in a single day, when operating during the ozone season. 4

5 Regulation No History Regulation Development Workgroup was formed in Fall 2003 to develop an initial draft of a regulation. Workgroup met 7 times over 14 month period (11/03-12/04). Starting with the Regulatory Assistance Project s model rule, 3 drafts of a regulation were prepared, discussed, and commented on. 4th draft was developed and then presented at 3 separate workshops in May Public hearing held in August 2005 on proposed regulation. Regulation No Control of Stationary Generator Emissions became effective on January 11,

6 Applicability Applies to all generators, except for: residential generators, for emergency purposes only; generators already subject to specific NOx limitations due to best available control technology (BACT) or lowest achievable emission rate (LAER); generators 10 kw; or mobile generators existing, emergency generators at fire stations. 6

7 Definitions of Importance Generator: internal combustion engine (except combustion turbine) and associated equipment that converts fuel to electricity, or electricity and thermal energy. Emergency: a power outage (due to various unintentional reasons), or a deviation of voltage or frequency from the electrical provider. 7

8 Definitions of Importance Emergency Generator: operates only during emergencies, for testing purposes, or for maintenance purposes. Distributed Generator: may operate for any reason. 8

9 Definitions of Importance New: any generator installed or repowered after the effective date (January 11, 2006). Existing: any generator installed prior to the effective date. An existing generator will be considered new if it is re-installed at a separate location (other than the current property). 9

10 Definitions of Importance Mobile: a generator which is self-propelled or intended to be propelled, or is portable or transportable. Stationary: a generator which is not mobile. If a mobile generator stays at a location for more than 12 consecutive months, it could be considered stationary. This requirement cannot be circumvented by moving a mobile generator which is acting as a stationary generator. 10

11 Initial Notification Generator owner must submit information to the Department: generator owner s name and address; generator s installed address, make, model, year, rating; and classification (emergency vs. distributed). Required to be submitted by: date of installation for new generators, or April 11, 2006 (3 months after effective date of regulation) for existing generators. A fill-form PDF is available on the Regulation No website (submit via , fax, or mail). 11

12 Compliance Dates Owners must comply with the regulation s requirements by: existing emergency generator April 11, 2006 (3 months after effective date); existing distributed generator April 1, 2007*; poultry growers signed up for cost-share program 3 months after effective date; or new emergency or distributed generator before the date of installation. * One year extension available for existing distributed generators. 12

13 Emissions Standards Generator Type Existing New Emergency no emission standards EPA Nonroad standards Distributed Regulatory Assistance Project suggested emission standards Engine Manufacturers Association suggested emission standards 13

14 Emissions Standards Emergency generators: Existing no actual emissions limits; just follow manufacturers maintenance and operating requirements/instructions. New generator must meet the emissions standards set by the US EPA for Nonroad engines. ***An old generator being installed as a new generator must comply with the currently applicable Nonroad standards. Example: a 400 kw 1995 diesel generator being installed in July 2006 must meet the 2006 Tier 3 Emissions standards for engines 225 kw<450, per 40 CFR Part

15 Emissions Standards Existing, distributed generators must meet the following standards: Pollutant Nitrogen Oxides Nonmethane Hydrocarbons Emission Standards In lbs/mwh Particulate Matter (liquid-fueled reciprocating engines only) Carbon Monoxide Carbon Dioxide ,900 15

16 Emissions Standards Alternative available to certain existing distributed generators. Delaware Electric Cooperative (DEC) has approx. 215 participants in its Interruptible Service Program. Almost all are poultry growers with uncontrolled diesel generators. Kent and Sussex Conservation Districts have a costshare program designed to retrofit the poultry generators participating in DEC s program. 100% cost-share for Rentar Fuel Catalyst (reduces NOx ~20% and increases fuel efficiency). 16

17 Emissions Standards Section states that existing, distributed generators installed on poultry farms may be exempt from emissions standards if: the generator is participating or is signed up to participate in the Rentar cost-share program, offered by one of the two Conservation Districts; or the generator is gaseous fueled. Section does NOT exempt existing distributed generators installed on poultry farms from the regulation s other requirements. 17

18 Emissions Standards Newdistributed generators must meet the following standards: Pollutant Nitrogen Oxides Nonmethane Hydrocarbons Particulate Matter (liquid-fueled reciprocating engines only) Carbon Monoxide Carbon Dioxide Installed On or After Jan. 11, ,900 Emission Standards in lbs/mwh Installed On or After Jan. 1, ,900 Installed On or After Jan. 1, ,650 18

19 Operating Requirements An emergency generator can operate for an unlimited amount of hours but only during emergencies, testing, or maintenance. A distributed generator can operate at any time, for an unlimited amount of hours. However No generator can be operated for testing or maintenance before 5pm (except those required to meet NFPA* or JCAHO** standards) on a day when: Ground Level Ozone Pollution Forecast or Particle Pollution Forecast = Code Red or Code Orange *National Fire Protection Association ** Joint Commission on Accreditation of Healthcare Organizations 19

20 Other Requirements Sulfur content limits for all fuels: Diesel Fuel Gaseous Fuels Alternative Fuels Sulfur Content Limit 500 ppm (0.05%) 10 grains Total S Per 100 dscf 10 grains Total S Per 100 dscf Monthly and yearly fuel usage must be recorded. Monthly and yearly operating hours (via an hour meter) must be recorded. Monthly and yearly testing and maintenance must be recorded. 20

21 Other Requirements For each shipment of liquid fuel received, a receipt must be obtained from the distributor which identifies: the type of fuel; the sulfur content of the fuel; and the method used to determine the sulfur content. As an alternative, a laboratory may analyze the fuel tank after each shipment, in order to certify the above information. 21

22 Other Requirements Records must be kept at least 5 years. Records can be hard copies (papers) or electronic copies (CDs, floppy disks, etc.). No requirement to report records but an owner must provide the records to the Department upon request. 22

23 Emissions Certification Suppliers/manufacturers may opt to certify new distributed generators: must certify generator for the lesser of 3,000 hours of operation or five years; allows owner to easily verify generator s compliance with emissions standards. New emergency generators must be certified to meet the currently applicable EPA Nonroad standards. 23

24 Emissions Certification If not certified by these methods, generator must have its emissions VERIFIED by: adequate paper documentation (technical specs) to verify emissions of generator, or third party testing. Every 5 years, a distributed generator must reverify its compliance with emissions standards via: manufacturer certified maintenance, third party testing, or any other method proven to the Department. 24

25 Credit for Emissions Reductions A generator can receive credit to use toward achieving its applicable emission rates by: operating on a fuel that would otherwise be flared (landfill gas, process gas); operating as a combined heat and power system; or simultaneously generating electricity from a nonemitting resource (wind, solar, etc.). 25

26 Permitting Requirements What must I do to apply for an emergency generator air permit? Submit AQM-2 form (Combustion Equipment Form) pursuant to Regulation No (previously known as Regulation No. 2). Stationary Generator Initial Notification. Permit fees: $165 for construction permit $165 for legal advertising $ 75 for operating permit (annually) (<100 MMBtu/hr) 26

27 Air Regulation No Application Form (AQM-2) Combustion Equipment This is the current application we are using. We are in the process of updating it. 27

28 Air Regulation No Stationary Generator Initial Notification 28

29 Permitting Requirements Prior to Regulation No Amendment Generators < 10 MMBtu/hr Regulation No Section 2.2: Provided that Regulation No [NSR] does not apply, equipment listed in Appendix A is exempt from permitting. Appendix A, Section (b) (i) exempts fuel burning equipment rated < 10 MMBtu/hr. Many sources tried to use this provision to be exempt from permitting. But Regulation No will apply if the PTE is: 25 TPY for NO x in New Castle and Kent Counties 100 TPY for NO x in Sussex County. A generator of 184 hp (137 kw or 1.3 MMBTU/hr) will have a PTE of 25 TPY of NO x (based on AP-42 emission factors). 29

30 Emergency Generators PTE 500 hours is an appropriate default assumption for calculating the PTE (EPA recommendation). The 8760 hours per year calculation for PTE is not applied. Permit will state the following: To use the generator only for periods when power is not available. The generator cannot be used for peak shaving or interruptible power contracts (Distributed Generation). The generator cannot be tested on an ozone action day. 30

31 Permitting Requirements An engine qualifies for a registration if: it is not required to obtain a Regulation No permit. it has aggregated emissions of all air contaminants, before the application of controls, which are greater than 0.2 lbs/day but less than 10 lbs/day. 31

32 Permitting Requirements PLEASE NOTE! The registration required under Regulation No is separate from the Initial Notification requirements of Regulation No A generator may or may not need to be registered or permitted, but ALL generators subject to Regulation No must submit the Initial Notification information. 32

33 Permitting Changes and Why Regulation Development Workgroup agreed that permitting requirements for generators needed to be addressed because of new regulation. Amendments to Regulation No coincided with the adoption of Regulation No Only Appendix A was amended, in order to clarify permitting requirements for generators. 33

34 Permitting Changes and Why The equipment < 10 MMBtu/hr exemption section was amended to clarify that it only applied to external combustion equipment (boilers). New sections added which exempt the following equipment from permitting: residential generators; generators at poultry farms; or emergency only generators w/standby rating of 450 kw or less. internal combustion equipment with an engine power rating of 450 hp or less. 34

35 Permitting Changes and Why Residential and poultry farm generators exempted from permitting to relieve the burden from both Air Quality Staff and generator owners. Emergency Generators 450 kw exempted: to relieve the burden from both Air Quality Staff and generator owners, and their actual and potential emissions are minimal (NOx PTE 4.73 TPY). 35

36 Permitting Requirements after Regulation No Amendment and Adoption of Regulation No Example of an Existing Emergency Generator Title V Permit Facility with an 872 hp (650 kw or 6.16 MMBTU/hr) emergency generator. Unit was registered and included under Insignificant Activities in the Title V Permit. With Regulation No Amendment, this generator requires a Regulation No operating permit. 36

37 For More Information Visit the Regulation No Website at: page/regulationno.1144.htm Mark A. Prettyman Phone: Guadalupe J. Reynolds Phone:

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