buescape & miratech epa rice neshap the meter is running webinar 4-08-14

EPA Stationary RICE NESHAP: The Meter is Running

BlueScape and MIRATECH James Westbrook and Scott McBryde

April 8, 2014

Agenda •  Review Typical Engine Use •  NESHAP Rule Introduc?on •  Applicability and Exemp?ons •  Compliance Requirements •  Emission Control and Monitoring

•  Summary

Typical Engine Use Primary modes: •  Emergency Standby Use

–  Backup for water pumps –  Emergency power for support facili?es –  Surge protec?on –  Black start –  U?lity emergency demand response programs

•  Non-‐Emergency Standby and “Prime” Use –  Compress gas, move water –  Reduce electricity cost –  Greater efficiency & reliability

•  U?lity reliability, economic incen?ves Engine Types: •  (RICE) Reciproca?ng Internal Combus?on Engine

–  (CI) Compression Igni?on, diesel –  (SI) Spark Igni?on, natural gas

RICE NESHAP Introduc?on •  Na?onal Emission Standards for Hazardous Air

Pollutants for Reciproca?ng Internal Combus?on Engines

•  Regula?on 40 CFR Part 63 Subpart ZZZZ •  CI RICE compliance by May 3, 2013 •  SI RICE compliance by October 19, 2013 •  Upcoming: April 17, 2014, performance tes?ng

due for large gas engines •  EPA Resources:

–  www.epa.gov/`n/atw/icengines/ –  www.epa.gov/region1/rice/#RuleApplicability –  h`p://www.epa.gov/`n/atw/icengines/docs/

20130919complianceinfo.pdf

Federal Engine Rules

•  NESHAP for Exis?ng CI and SI, 40 CFR Part 63 Subpart ZZZZ –  > 500 hp at major source of HAP:

•  Exis?ng Engines constructed before 12/19/02 •  New Engines constructed on or aeer 12/19/02

–  ≤ 500 hp at major source of HAP or all at area source of HAP

•  Exis?ng Engines constructed before 6/12/06 •  New Engines constructed on or aeer 6/12/06

•  NSPS for New SI, 40 CFR 60 Subpart JJJJ •  NSPS for New CI, 40 CFR Subpart IIII •  State Rules can be more stringent

–  CA Air Toxics Control Measure (ATCM)

Lots of Variables – Let’s Make it Easier! Review Variables CI SI

Exempt Mobile, Portable, or Emergency X X Major Source, Area Source of HAPs X X New, Exis?ng, Reconstructed X X Emergency, Non-‐Emergency, Black Start X X 100 hp, 300 hp, 500 hp X <=500 hp, >500 hp X 2-‐stroke, 4-‐stroke X Lean-‐burn, Rich-‐burn X Remote, Non-‐Remote X Non-‐Limited, Limited Use X X Low-‐Sulfur, Ultra-‐low Sulfur Diesel X

Exemp?ons from RICE NESHAP •  Motor Vehicles or Portable Non-‐Road Engines

–  Portable engines sta?onary if at one loca?on 12 months

•  Exis?ng Emergency Engines –  Residen?al, commercial, ins?tu?onal area sources –  Used <= 15 hrs/year for emergency demand response,

not used for local reliability –  > 15 hrs/year meet Subpart ZZZZ opera?onal

requirements, 100 hours per year for any of: •  Tes?ng and Maintenance •  Emergency demand response when blackout imminent •  50 hrs/year for non-‐emergency, local reliability

–  Electronic repor?ng to EPA star?ng 3/31/16

RICE NESHAP Applicability

Engines at HAP major sources

Non-‐Emergency SI, >500 hp, HAP area source

Non-‐Emergency CI, SI <500, remote, HAP area

source

Emergency CI >500 hp, HAP area source

Emergency CI, SI, HAP area source <500 hp

REQUIREM

ENTS

Emission Standards: Exis?ng RICE at Major Sources HP

Engine Subcategory

Non-‐emergency Emergency

Cl SI 2SLB SI 4SLB SI 4SRB SI LFG/DG

<100 Change oil and filter and inspect cleaner (CI) or spark plugs (SI) every 1,000 hours of opera?on or annually; inspect hoses and belts every 500 hours of

opera?on or annually

Change oil/filter & inspect hoses/belts

every 500 hours or annually; inspect air

cleaner (CI) or spark plugs (SI) every 1,000 hours or annually

100 -‐ 300 230 ppm CO

225 ppm CO

47 ppm CO

10.3 ppm CO

177 ppm CO

300 -‐ 500

49 ppm CO or 70% CO reduc[on

>500 23 ppm CO or 70% CO reduc[on

No standards

No standards

350 ppb HCHO or 76%

HCHO reduc[on

No standards

No standards

Note: Exis?ng limited use engines >500 HP at major sources do not meet any emission standards. Exis?ng black start engines ≤500 HP at major sources must meet work prac?ce standards.

HP

Engine Subcategory Non-‐emergency

Emergency or Black Start Cl SI 2SLB SI 4S in remote

areas

SI 4S not in remote areas

SI LFG/DG

≤300

Change oil/filter & inspect air cleaner every 1,000 hours or annually; inspect

hoses/belts every 500 hours or annually

Change oil/filter, inspect spark plugs, & inspect hoses/belts every 4,320 hours or annually

Change oil/filter, inspect spark plugs, & inspect hoses/belts every

1,440 hours of opera?on or annually

Change oil/filter, inspect spark plugs, & inspect hoses/belts every

1,440 hours of opera?on or annually

Change oil/filter, inspect

spark plugs, & inspect hoses/belts every 1,440 hours of opera?on or annually

Change oil/filter & inspect

hoses/belts every 500 hours or annually; inspect air

cleaner (CI) or spark plugs (SI) every

1,000 hours or annually

300 -‐ 500

49 ppm CO or 70% CO reduc[on

>500 23 ppm CO or 70% CO reduc[on

Change oil/filter, inspect spark

plugs, & inspect hoses/belts every 2,160 hours of opera?on or annually

If engine used >24 hrs/yr:

4SLB: Install oxida[on catalyst

4SRB: Install

NSCR

Emission Standards: Exis?ng RICE at Area Sources

HP

Engine Subcategory

Non-‐emergency Emergency

Cl 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

250 -‐ 500

14 ppm HCHO or 93% CO reduc?on

>500

580 ppb HCHO or 70% CO reduc?on

12 ppm HCHO or 58% CO reduc?on

350 ppb HCHO or 76% HCHO

reduc?on

No standards

No standards

Notes: 1. New limited use engines >500 HP at major sources do not meet any emission standards under the NESHAP. 2. New RICE at Area Sources meet: CI: Part 60 Subpart IIII; SI: Part 60 Subpart JJJJ

Emission Standards: New RICE at Major Sources

Engine Subcategory Compliance Requirements Exis[ng non-‐emergency: •  CI ≥100 HP at major source •  CI >300 HP at area source •  SI 100-‐500 HP at major source

•  Ini?al emission performance test (*) o  Subsequent performance tes?ng every 8,760

hours of opera?on or 3 years for engines >500 HP (5 years if limited use)

o  Opera?ng limita?ons -‐ catalyst pressure drop and inlet temperature for engines >500 HP

o  No?fica?ons o  Semiannual compliance reports (annual if limited

use) •  Exis?ng non-‐emergency CI >300 HP:

o  Ultra low sulfur diesel (ULSD) o  Crankcase emission control requirements

•  Exis[ng non-‐emergency SI: 4SLB/4SRB >500 HP at area source used >24 hours/year and not in remote area

•  Ini?al performance test (*) •  Annual compliance demonstra?on •  High temperature engine shutdown or con?nuously

monitor catalyst inlet temperature •  No?fica?ons •  Semiannual compliance reports

Most Compliance Requirements

(*) Waiver of performance test can be requested

Engine Subcategory Compliance Requirements

Exis[ng non-‐emergency: •  SI 4SRB >500 HP at major source New non-‐emergency: •  SI 2SLB >500 HP at major source •  SI 4SLB >250 HP at major source •  SI 4SRB >500 HP at major source •  CI >500 HP at major source

•  Ini?al emission performance test o  Subsequent performance tes?ng semiannually (can reduce frequency to annual) (subsequent performance tes?ng required for 4SRB engine complying with formaldehyde % reduc?on standard if engine is ≥5000 HP)

o  Opera?ng limita?ons -‐ catalyst pressure drop and inlet temperature

o  No?fica?ons o  Semiannual compliance reports

Most Compliance Requirements


Exis[ng emergency/black start: •  <100 HP at major source •  ≤500 HP at major source •  All at area source Exis[ng non-‐emergency: •  <100 HP at major source •  CI ≤300 HP at area source •  SI ≤500 HP at area source •  SI 2SLB >500 HP at area source •  SI LFG/DG >500 HP at area source •  SI 4SLB/4SRB >500 HP at area source

used ≤24 hours/year or in remote area

•  Operate/maintain engine & control device per manufacturer’s instruc?ons or owner-‐developed maintenance plan

•  May use oil analysis program instead of prescribed oil change frequency

•  Emergency engines must have hour meter and record hours of opera?on

•  Keep records of maintenance •  No?fica?ons not required •  Repor?ng and ULSD for emergency

engines used for emergency demand response or local reliability

Less Compliance Requirements

LFG/DG = landfill gas / digester gas


•  New emergency/limited use >500 HP at major source

•  Ini?al no?fica?on •  Repor?ng and ULSD for emergency

engines used for emergency demand response or local reliability

•  New non-‐emergency LFG/DG >500 HP at major source

•  Ini?al no?fica?on •  Monitor/record fuel usage daily •  Annual report of fuel usage

Less Compliance Requirements

Catalyst Required? •  Yes, most engines will need CO or VOC catalyst •  One year compliance extensions were allowed

–  1/3/13 for CI; 6/21/13 for SI •  Catalyst installa?on requires:

–  Air permi{ng process –  Establish performance parameters –  Complete ini?al and ongoing performance tes?ng –  Following a compliance plan

•  Alterna?ves to catalyst: –  Take an enforceable permit restric?on, area source –  Re-‐categorize to an emergency engine –  Engine replacement –  Electrifica?on

CPMS and SSMP •  Con?nuous Parameter Monitoring System (CPMS)

–  Table 5 of Subpart ZZZZ -‐ install, operate, and maintain a CPMS –  CPMS operated according to a Site-‐Specific Monitoring Plan (SSMP) –  Collect data once every 15 min; 4-‐hr rolling avgs; 1-‐hr block avg values –  Temperature range – 5 deg F or 1% of measurement range, whichever larger –  Pressure drop tolerance; 2 inches of water from measured during test –  Evalua?on, system accuracy audits, other audit procedures annually –  Performance evalua?on of each CPMS parameter

•  Site-‐Specific Monitoring Plan (SSMP): –  The performance criteria and design specifica?ons for the monitoring system

equipment, including the sample interface, detector signal analyzer, and data acquisi?on and calcula?ons

–  Sampling interface (e.g., thermocouple) loca?on such that the monitoring system will provide representa?ve measurements

–  Equipment performance evalua?ons, system accuracy audits, or other audit procedures

–  Ongoing opera?on and maintenance procedures –  Ongoing repor?ng and recordkeeping procedures

Quiz – Pump Sta?on Facility

Exis?ng Area Source of Hazardous Air Pollutants, Non-‐Remote

1.  Two x Non-‐Emergency SI Engines, 2,160 hp 4SLB, no CO catalyst installed – con?nuous drive pumps

2.  Two x Emergency Backup CI Engines, 465 hp, no CO catalyst installed -‐ facility reliability

Let’s Review – In Compliance?

•  Have you surveyed engines, know where they fit? Know your compliance deadlines?

•  Good recordkeeping procedures, esp. hours, how engine used and maintenance records?

•  Have you done Ini?al No?fica?ons? Filed Compliance Reports?

•  Permi`ed equipment changes for catalyst, or changed permit condi?ons?

•  Installed catalyst, replaced engine, electrify? •  Completed the Ini?al Performance Test? •  Established monitoring parameters, installed meters,

scheduling maintenance? •  If installed catalyst, CPMS or shut down device? •  If CPMS, Site-‐Specific Monitoring Plan?

NESHAP Compliance Products

Customer

Engine

CO Reduction

DOC/3Way

DOC Temperature Monitoring

Data Logger

DOC Pressure

Monitoring

Data Logger

Closed Crankcase Ventilation

Engine

Customer’s Want a Complete RICE NESHAP Solution

=

Catalytic Converter Solutions – Carbon Monoxide (CO) Reduction Systems

Non-Silenced

Silenced (Critical/Hospital/Super)

Performance

Ground Access Low Profile

Serviceable Catalytic Converter – Proven and Straightforward

q  Oxidizes CO up to 95%, can easily meet NESHAP requirements q  Up to 80% formaldehyde (CH2O) reduction

q  Carbon Steel or 304SS housings in many diameters sized to engine

q  Benefits o  Serviceable and removable catalyst o  up to 9,000 hrs operation before a cleaning may be needed o  ½” NPT sample ports in both necks & pre and post catalyst o  Durable, metal foil catalyst designed for industrial engines o  Up to 2500 HP engines

Slide # 23

Integrated Silencer Catalytic Converter

q  Same catalyst features as the base converter q  Good option for NESHAP retrofits as usually there is an existing

silencer in place o  New unit can fit within the flange to flange space of the existing old silencer o  Silencing Capabilities from 25-45+ dBA o  Custom inlets/outlets, saddles, etc. can be added to customize as needed

Large Engines - Ground Access Catalyst/Silencer

q  Same catalyst features as the base converter q  Good option for large engine NESHAP retrofits as usually

there is an existing ground access silencer. o  New unit can fit within the location of the existing old GA silencer o  Silencing Capabilities from 25-50+ dBA o  Customization is common, with heat protection added at ground level o  2500-15,000 HP engines

q  Catalyst inlet temperature on engines greater than 500 HP is required to be continuously monitored and recorded by a Continuous Parametric Monitoring System (CPMS).

q  Pressure drop across the catalyst measured on a monthly basis. q  Both inlet temperature and pressure drop across the catalyst must be

measured for the initial performance test. q  Many options exist from all manufacturers that can be customized.

o  Basic data logging up to complete SCADA system interfacing capabilties

Continuous Parametric Monitoring System (CPMS) For Compliance - Data Logging & Recording

PRESSURE SENSOR

POWER SUPPLY

DATA LOGGER

CUSTOMER POWER SUPPLY

HOOK-UP

THERMOCOUPLE TERMINATION

POINTS

Crankcase Ventilation (CCV) Systems

q  For NESHAP compliance, most stationary engines over 300HP must be equipped with a crankcase ventilation system.

q  Prevents hazardous vented crankcase emissions (Oil Mist and Particulate) from entering the surrounding atmosphere.

q  Two primary types of CCV systems: Open Closed

Recovered Oil Drained to Used Oil Container or Crankcase Sump

Depending on Engine OEM Instructions and Operator’s Discretion

Provides engine and catalyst protection from oil contamination, simple installation

Summary

•  The meter is running are you in compliance? •  Get a handle on NESHAP requirements

–  Good engine database and records •  Meet ini?al no?fica?on, performance tes?ng,

monitoring, maintenance, repor?ng requirements •  Minor requirements for most equipment

–  Mainly good records and maintenance •  Major sources, non-‐emergency CI or SI, > 500 hp at area

sources – greater requirements –  Catalyst can be required, permit changes –  Alterna?ves for monitoring and tes?ng

•  BlueScape and MIRATECH can help get you into compliance!

Ques?ons? Contact Informa?on

James Westbrook, President BlueScape Environmental Office: 858-‐695-‐9200 x201 Mobile: 858-‐774-‐2009

[email protected] www.bluescapeinc.com

Sco` McBryde Regional Sales Manager

MIRATECH Corp Office Direct: 918-‐794-‐0341

Mobile: 909-‐821-‐0039 [email protected]

www.miratechcorp.com