Air Permitting: Municipal Facilities with Emergency Generators Sam Cotter, P.E. sam.cotter@cardinalengineers.com 7060 S. Yale, Suite 603 Tulsa, OK 74136
Introduction Generators are located at our utility pumping stations, treatment plants, and civic buildings Many generator installations require air permits Local utility authorities may be unaware of permit requirements Air compliance is a dynamic, developing field Regulations have been recently implemented or modified 2
Outline Introduce regulatory guidelines Evaluate affected sources Permitting requirements Example scenarios Other environmental considerations and permits 3
Stationary engines: Generate backup power in case of an emergency Generate power with digester gas Engine-powered air compressor Engine-powered water pumps Electrical peak shaving 4
NSPS NESHAP New Source Performance Standard 40 CFR 60 Subpart IIII Subpart JJJJ New Engines Many other subparts affect non-engine sources National Emission Standards for Hazardous Air Pollutants 40 CFR 63 Subpart ZZZZ New engines Major sources affected Existing engines Many other subparts affect non-engine sources 5
Definitions/Acronyms Criteria pollutant: NOx, CO, VOC, PM Emergency: Provides power during an emergency situation, when utility power is interrupted HAP: Hazardous Air Pollutant NESHAP: National Emission Standards for Hazardous Air Pollutants NSPS: New Source Performance Standards RICE: Reciprocating Internal Combustion Engine SI: Spark Ignition Natural gas, gasoline, propane, digester gas CI: Compression Ignition Diesel 6
Definitions/Acronyms NEW : Dependent on regulatory definition, date of construction IIII: Governs compression-ignition sources constructed after 7/11/2005 JJJJ: Governs spark-ignition sources constructed after 6/12/2006 Applicability dates are dependent on size of engine ZZZZ: Governs existing engines operation and maintenance New & Existing, depending on area vs. major source Existing: Constructed prior to 6/12/2006 for area source 7
Why should I care? Improve air quality You have a standby generator, or you know someone who does Compliance is driven by regulatory pressure Mitigate risk/exposure to permit violations 8
Process of air compliance Applicability analysis Am I subject to regulation? Do I need a permit? Facility permitting Permit application, calculations of emissions Compliance assurance Ongoing maintenance, testing, and report 9
Do I have affected sources? Engine Characteristics Stationary Engines Mobile Engines Compression Ignition Spark Ignition Emergency Non-Emergency Landfill/Digester Gas 2-Stroke 4-Stroke Rich burn Lean burn Important Engine Data Horsepower Date of construction (existing vs. new) Annual hours: Emergency / Non-emergency Emission certifications Area vs. Major Source for HAPs 10
HAP: Major vs Area source Area vs. Major affects compliance with NESHAP rules Many small standby generator installations will most likely fall under area source Major: > 10 TPY HAP, or 25 TPY total HAPs Remote area 11
NSPS NESHAP New Source Performance Standard 40 CFR 60 Subpart IIII Subpart JJJJ National Emission Standards for Hazardous Air Pollutants 40 CFR 63 Subpart ZZZZ 12
Am I subject to a regulation? Compliance determination 1. Classify engine by key factors and engine data Stationary? Emergency or non-emergency? New or existing? 2. Determine if your engine is subject to NESHAP and/or NSPS 3. Determine if source is area or major 4. Determine compliance requirements 5. Review compliance dates and address any noncompliance. 13
I m subject to regulations, now what? Achieve Compliance Review compliance dates and address any noncompliance Submit any applicable initial notifications Install controls Self disclosure for any noncompliance identified Communicate with state regulatory agency Possible compliance requirements: Install controls, meet compliance requirements, Stack test Engine maintenance 14
IIII Compliance Newer Diesel Engines Is the engine certified? Emergency engines: Operate control devices per manufacturer Non-resettable hour meter Diesel particulate filter: monitor backpressure 15
Certified engine Manufacturer certifies to a specified emission standard Engine must be installed/maintained per manufacturer specifications For new spark-ignition (Subpart JJJJ), noncertified engines require initial emission test and testing every 8,760 hours or 3 years (whichever comes first) 16
IIII Emission Standards Refer to tables in regulation Table 1: Emission Standards for Stationary Pre-2007 Model Year Engines With a Displacement of <10 Liters per Cylinder and 2007-2010 Model Year Engines >2,237 KW (3,000 HP) and With a Displacement of <10 Liters per Cylinder 17
JJJJ Compliance Spark Ignition (Natural gas, gasoline, propane, digester gas) New engine: The easiest way to comply with JJJJ: buy a certified engine Often requires a catalyst to meet emission limits Stack testing Every 8,760 hours or 3 years, whichever comes first Engines < 25 HP must comply with other federal regulations 40 CFR 90, can include certification 18
JJJJ Emission Standards 19
ZZZZ Compliance Variables affecting compliance requirements: Size and type of engine Area vs. major source for HAP New vs. Existing New engine at an area source meets ZZZZ by complying with 40 CFR 60 subpart IIII or subpart JJJJ Assuming existing emergency engine, area source: Oil change / maintenance annually or by hours of operation Non-resettable hour meter Limits on operational hours under some conditions 20
ZZZZ 40 CFR 63 Subpart ZZZZ Table 2d: Requirements for Existing Stationary RICE Located at Area Sources of HAP Emissions See tables for compliance requirements 21
How do I maintain compliance? Continuous Compliance Subpart IIII Operation and maintenance per manufacturer guidelines Maintenance of control devices Subpart JJJJ Operation and maintenance per manufacturer guidelines Stack testing Subpart ZZZZ Maintenance requirements Annual Air Emission Inventory Permitted facilities are required to report annual air emissions 22
Do I need a permit? Generally: If federally applicable requirements apply Permit may be required Federally applicable requirements: Subpart IIII Subpart JJJJ Subpart ZZZZ Requirements vary slightly by state Evaluate on a case-by-case basis 23
Oklahoma permitting General permit for area source NESHAP facilities and small NSPS facilities Form 100-360 Existing facilities subject to NESHAP may be permit-exempt if no modifications have been made Contact: Oklahoma DEQ http://www.deq.state.ok.us/aqdnew/index.htm 24
Louisiana permitting Louisiana DEQ Subject to LAC 33:III 311 311 permit is specific to stationary RICE http://www.deq.louisiana.gov/portal/divisions/airpermits EngineeringandPlanning/RegulatoryPermits.aspx 25
Arkansas permitting Arkansas DEQ Regulation No. 18 Section 18.301(B)(3) indicates certain conditions where IIII/JJJJ/ZZZZ engines may be exempt from permitting Minor source general permit Submit Notice of Intent form Emission estimates http://www.adeq.state.ar.us/air/branch_permits/perm 26 it_aps_inst.htm
What if my engine is already installed? May require self disclosure to regulatory agency 27
Case Study: Cummins DQDAA Date ordered: February 2012 Standby generator 476 HP engine, 250 kw generator capacity Fuel: Diesel Location: Norman, OK 28
Applicability analysis Questions: Stationary? YES Emergency? YES New vs. Existing? NEW SI or CI? CI Subject to NESHAP ZZZZ? YES Area source or major source? AREA (Maintenance requirements) Subject to NSPS IIII or JJJJ? YES - IIII Certified? YES What permit is required? GENERAL PERMIT 29
Other regulatory considerations Above ground tanks: Total facility oil storage > 1,350 gal, need SPCC Underground fuel storage tank: Register with state agency Tier II reporting 30
Summary 1. Stationary engines can be subject to federal regulations 2. Regulatory applicability is dependent on engine characteristics and date of construction 3. Regulations may require maintenance, testing, and permitting 31
Compliance tools Compliance determination quiz http://www.epa.gov/ttn/atw/rice/output/quiz.html EPA guidance for reciprocating engines: http://www.epa.gov/region1/rice/ TCEQ resources with flowcharts for JJJJ and IIII applicability http://tceq.state.tx.us/permitting/air/rules/federal/60/60 hmpg.html KDHE Guidance documents http://www.kdheks.gov/air-permit/cetech_guidance.html 32
EPA Compliance of Stationary Engines at Water & Wastewater Facilities Sam Cotter, P.E. sam.cotter@cardinalengineers.com 7060 S. Yale, Suite 603 Tulsa, OK 74136