SCAQMD Rule 1470 Impact on Diesel Generator Installations Presented Nov 15, 2012 at By Dave Lewis Orange County Chapter
Agenda Background EPA / CARB Terminology NEC vs SCAQMD Rule 1470 Requirements http://www.aqmd.gov/rules/reg/reg14/r1470.pdf Design Considerations Tier 4
EPA Regulatory Requirement July 2006 EPA Established New Source Performance Standards (NSPS) for Internal Combustion Engines (ICE) Non-Emergency Engines Subject to Tier 4 Interim and Tier 4 Final Emissions Standards (See Chart) EPA Established Emergency Standby Power is Exempt From Tier 4 Standards Because of Limited Hours of Use and Inability of After-Treatment to Operate Properly Standards Required - 2007 Emissions Standards Not Allowable for Portable Non-Road Engines
CARB Airborne Toxic Control Measure (ATCM) Effective May 19, 2011 CARB Revised Their ATCM to Align With EPA NSPS Emergency Standby Power is Exempt From Tier 4 Standards PM Standard More Stringent Than EPA for Engines 50 HP 174.9 HP (0.15 g/bhp-hr) PM Standard for Engines 175 HP and Larger Set Also at 0.15 g/bhp-hr (same as Tier 2 standard) NOx, HC and CO Levels for All Engines 50 HP and Larger Must Meet 2008 EPA Emissions Standards 50 HP 74.9 HP - Tier 4 Interim 75 HP 750 HP Tier 3 > 750 HP Tier 2
Terminology Emergency Use (b)(26) Emergency Standby Engine (b)(25) Initial Start-up Testing (b)(38) Maintenance and Testing (b)(43) Portable CI Engine (b)(50) Prime CI Engine (b)(51) Sensitive Receptor (b)(60) School or School Grounds (b)(57) Stationary CI Engine (b)(63)
Emergency Use Terminology Providing electrical power during failure/loss of normal electrical service or facility s internal distribution system Not for reason of contract and only if beyond reasonable control of owner/operator Pumping of water / sewage to mitigate various public safety situations (flood, overflow, fire, breakdown of electric pumping equipment
NEC Article 700 Emergency Systems EQUALS NEC vs SCAQMD Article 701 Legally Required Standby Article 702 Optional Standby Systems SCAQMD Emergency Use Common language: normal electrical supply or system is interrupted or failure of the normal source
Emergency Standby Engine Terminology Stationary Engine meets following criteria: Installed & Operated to provide power for Emergency Use & is not primary power source Not operated to supply power to grid or for $ gain And meets at least one of below: Limited Ops for Maint. / Testing, initial start-up Limited Ops for an impending outage Limited Ops under a Demand Response Program
Initial Start-up Testing Terminology First time after install or re-start after adding emission control equipment Doesn t count against annual Maint & Test hrs Maintenance and Testing Evaluate ability to perform during emergency Facilitate Training Provide power when normal off-line for non-emergency Extra testing after failure during maint might not count (generally, the rule will limit this to 50 hours annually)
Terminology Portable Compression Ignition (CI) Engine Designed and capable of being moved If above but remains in place for a year = stationary Different rules apply to portable Prime CI Engine Stationary, but not Emergency Standby Stationary Engine Attached to foundation or residing at same location for more than 12 months Replacement or moved to circumvent 12 months rule Seasonal source
Sensitive Receptor Terminology Any residence including private homes, condominiums, apartments, and living quarters, schools as defined in (b)(57), preschools, daycare centers and health facilities such as hospitals or retirement and nursing homes. A sensitive receptor includes long term care hospitals, hospices, prisons, and dormitories or similar live-in housing School or School Grounds (b)(57)paraphrased Public or Private, K-12 with >12 kids in K or any 1-12 Juv. Detention Facilities, but Not Private Homes All Improved property
Diesel Particulate Filter (DPF) Terminology Mechanically removes Particulate Matter (PM) and must be cleaned by regeneration or mechanical means Carbon soot Soluble organic fraction (SOF) 20% to 50% Sulfate and water Ash (must be mechanically removed)
SCAQMD Rule 1470 May 2012 Revision Requirements Start January 1, 2013 Alignment with State ATCM (ie: No Tier 4 for standby), Except Within 50 Meters of a Sensitive Receptor, and On or Within 100 Meters of a School > 50 Meters From Sensitive Receptor: 0.15 g/bhp-hr (= Tier 2 limits of >175hp, but for all >50hp) Affects New Installations of 175 HP and Greater (Aggregate) Engines < 175 HP If Installed in Aggregate ay Require DPF Engines (>50hp) within 100 Meters of a School No Change Must Have a DPF (to meet 0.01)
SCAQMD Rule 1470 May 2012 Rev(Cont'd) January 1, 2013 Requirements: For Engines Within 50 Meters of a Sensitive Receptor Engines 175 HP 750 HP DPF (0.01 g/bhp-hr) Engines > 750 HP 0.075 g/bhp-hr (May Not Need DPF; may not need other or any aftertreatment) July 1, 2015 Requirements (new installs not retroactive) For Engines Within 50 Meters of a Sensitive Receptor Engines 175 HP 750 HP DPF (0.01 g/bhp-hr) Engines > 750 HP 0.02 g/bhp-hr
SCAQMD Rule 1470 + Other Requirements Allows Bypass for Critical Installations (Essential Public Services and Health Facilities) Facilities Identified as Title V or Major Sources DPF Required Extensive recordkeeping, reporting and monitoring requirements (paragraph (d)) Two + pages of exemptions check if replacing an older engine (paragraph (h)) Rule 1472 Existing Engines in Groups of 3 or more may require DPFs or Replacement to Meet 0.15 g/bhp-hr PM Emissions Average
Permit Impact Permit applications in and complete (all info correct) by November 30 current CEP OK (no DPF unless already required) If within 1000 of a school, public notice required; adds $2500-5000 for mailings, minimum 45 days extra Until New Permitting instructions & forms printed, customers should utilize a reputable emissions consultant to minimize delays, ensure correct permit issued
PM Reduction Strategies Engine combustion (In-cylinder) improvements (almost all meet 0.15, many meet 0.07) DOC (Diesel Oxydation Catalyst) Designed for HC / CO / odor control, but also provide 20-25% PM reduction Usually enough to meet 0.07 DPF Carb level 3+ verified = 85% reduction in PM Also qualifies to meet 0.01 (for schools) Passive, Active, Hybrid
Total System Backpressure Design Considerations Good Eng g Practice: 60-70% of Limit Access to filter elements Wiring and mechanical tubing to monitor/alarm systems Software system & remote monitoring Specify additional operator training for DPF system, including software
Design Considerations - DOC Not a filter; passes over a catalyst Load on generator not a factor Exhaust silencing can be incorporated Location same as a silencer, but accessible for possible maintenance Adds $ 5-10% to cost of Generator Set
DPF Design Considerations - Passive Load 40% of rating (minimum - varies) Permanent Load Bank or quick-connect cabinet & breaker Location close to gen set, before silencer, accessible for removal of filter elements for cleaning Insulation from Turbo to DPF Adds $ 20% to cost for DPF, another 5-10% for loadbank & breaker
DPF Design Considerations - Active Breaker on Genset 8 kva (3-500kw) Up to 24kVA for 2500kw Load Independent, load bank not required Auto regen Location not as critical Adds 40% to cost
Alarms & Monitoring Backpressure real time and discrete outputs for pre-alarm / shutdown Exhaust Temperature Date, Elapsed Time Event Codes Optional Software to download, analyze data. Integrating load and temp to control load bank
Failure to operate as instructed 100 w.g. Backpressure before piston seized
Passive Need to monitor more than backpressure Load kw Temp deg F Flow acfm 12 Silencer inch H2O 12 Piping: 30 4L s Backpressure Total 16 DPF/ Integral Silencer Operational limits 1000 893 8129 10.5 4.8 15.3 22.2 30.1 500 769 4799 4.0 1.8 5.8 14.2 18.8 100 488 1985 0.9 0.4 1.3 8.2 10.0 Clean no soot or ash build up Design figure based on standard conditions at engine outlet not the DPF Recommended highest level of backpressure before mechanically cleaning needed from inorganic ash
What changes with Tier 4? Tier 4 calls for such dramatic reductions in emissions that introduction is divided into two phases Interim focus primarily on PM reduction for 900 bkw - 2008 for engines <56 bkw; 2011 /12 for engines 56 bkw - Up to 90 % PM reduction & up to 50% NOx reduction vs Tier 3-90% NOx reduction for gensets >900 bkw Final focus primarily on NOx reduction - Does not affect engines <19 bkw - 2013: engines 19 <56 bkw; 2014 / 15: engines 56 bkw - Up to 80% NOx reduction and further PM reductions (gensets 56 bkw 560) - 70% PM reduction for gensets >900 bkw
Particulates (PM) Example - >750 Hp
Tier 4 Interim Certified Technology Summary Clean Emissions Module (CEM) (NRS) Diesel Oxidation Catalyst (DOC) Diesel Particulate Filter (DPF) Selective Catalytic Reduction (SCR)
EPA Non-Road Regulatory Impact Example - >900 bkw genset applications March 11, 2010
CEM = SCR + DOC +... ENGINE / GENSET AFTERTREATMENT MODULE LEGEND Electrical Air Supply DEF TANK DEF Supply DEF Return Exhaust DOSING CABINET & BUFFER TANK AIR SOURCE March 11, 2010
Tier 4 application & TAKE AWAY SCR module must operate for minimum 30 minutes for proper operation SCR inlet temp is monitored and Control Panel issues warnings if not at required temp and duration Diesel Exhaust Fluid storage is problamatic shelf life and temperature sensitive Designed for prime power applications Tier 4 systems with SCR aftertreatment are not designed for use in standby application and are not required by any authority with jurisdicition.
Project Checklist Determine distance from stack to nearest K-12 school or if Title V facility If within 100m of a school or Title V: DPF If not, determine closest sensitive receptor If within 50m, may need aftertreatment Determine kw rating of genset Contact Quinn to confirm need (none/doc/dpf) If DPF, establish clients op/maint comfort level Contact Quinn to determine best type (Passive/Active)
Thank You Questions/Comments For further information or copies of this presentation, Email Dave at: dlewis@quinnpower.com 562-463-6043 For permitting or emissions consulting assistance, we recommend SCEC. Email Karl at klany@scec.com 714-282-8240