SCAQMD Rule 1110.2 Compliance Steps and Strategies Judy Yorke and Bipul K. Saraf

© Copyright, Yorke Engineering, LLC 2008

SCAQMD Rule 1110.2

Compliance Steps and Strategies Judy Yorke and Bipul K. Saraf

Yorke Engineering, LLC31726 Rancho Viejo Rd., Suite 218San Juan Capistrano, CA 92675

Ph. 949 248-8490 Fax 949 248-8499


1110.2 Compliance Steps and Strategies

Step 1: Understanding the BasicsStep 2: Reviewing Permits and EquipmentStep 3: Strategy ConsiderationsStep 4: Planning Compliance


Step 1: Understanding the Basics

New Emission Requirements* for existing, permitted Natural Gas combustion engines:

Pollutant Current (ppmvd)

Effective 7/1/2010(ppmvd)

Effective 7/1/2011(ppmvd)

bhp≥500 bhp<500 bhp≥500 bhp<500 All

NOx 36 45 11 45 11

VOC 250 250 30 250 30

CO 2000 2000 250 2000 250

* Engines that operate <500 hr/yr or use < 1 x 109 Btu/year of fuel are exempt from meeting the lower concentration limits.


New Monitoring Requirements

Rule 1110.2 requires increased monitoring of emissions: Periodic Monitoring using a

portable analyzer and following an Inspection and Maintenance Plan (I&M Plan), or

Continuous Emissions Monitoring System (CEMS) required for larger engines or groups of engines.


New 1110.2 Due Dates

Submittal or Implementation Requirement Near Term Due Date

Permit Amendment (s) to add AFRC* make/ model, to permit (if needed)

April1st

(past due)

Quarterly Report (Due 15 days after end of qtr) July 15th

Inspection & Maintenance (I&M) Plan Submittal Aug. 1st

Permit Application for new or modified CEMS** Aug. 1st

Implement I&M Plan Dec. 1st

*Air to Fuel Ratio Controller** Non-biogas engines, >750 bhp


Breakdown Reporting

Report breakdowns with emission exceedances within 1 hour

Within 7 calendar days, submit a written report. (Time for submittal may be longer depending upon circumstances.)


Recordkeeping

Daily/Weekly/Monthly/Quarterly Logs Data, logs, test reports etc. shall be

maintained for five years.

Logs include: Total hours of operation, Type of fuel, Fuel consumption Cumulative hours since last source test


Step 2: Understanding Your Permits

Review your engine permits for: Current emission limits; Air-to-Fuel Ratio Controller (AFRC)

Specifications; Equipment Description and BHP Rating; Fuel/Hour Usage limits; Operating conditions; and Periodic monitoring conditions.


Examples: Checking Equipment Descriptions


Examples: Reviewing the Face Plate

Ensure that the Permit matches this description …


Examples of Current Permit Limits

Pollutant Example Engine # 1 Example Engine # 2 Example Engine # 3

g/bhp-hr ppmv g/bhp-hr ppmv g/bhp-hr ppmv

NOx 0.30 21 0.15 11 0.15 11

VOC 0.15 30 0.15 30 0.15 30

CO 0.5 58 0.6 70 0.6 70

(Corrected to 15% O2, averaged over 15 minutes)


To Convert from g/bhp-hr to ppm

For NOx: g/bhp-hr x 70.6 ~ NOx ppmv

For CO: g/bhp-hr x 116 ~ CO ppmv

For VOC g/bhp-hr x 203 ~ VOC ppmv


Review a Previous Source Test

To determine current compliance status, review last source test results:

Pollutant Example Engine #1

(ppm)

Example Engine #2

(ppm)

Example Engine #3

(ppm)

NOx 1.3 4.8 4.0

VOC 7.8 1.1 1.3

CO 39 40 14.9


Review Permit Conditions

Review your permit conditions to determine permit requirements

Rule requirements always apply in addition to permit conditions – they both must be followed

RECLAIM facilities comply with Regulation XX for NOx emissions, but must follow Rule 1110.2 for CO and VOC


Step 3: Strategy Considerations

Does your AFRC work well?Has it, or should it, be replaced?There are some newer, better AFRCs

currently available that can assist in on-going compliance.

Correcting or changing AFRCs requires a permit application


Need a CEMS?

CEMS are required if: >1,000 bhp and operating >2 million bhp-hr per

calendar year; or Co-located engines (>500bhp) with a combined

rating of >1500 bhp and >16 billion Btus/yr HHV

Is your engine and operations below these levels?

Can you limit and/or derate your engine(s) to be lower than these levels?


Source Testing, Monitoring, CEMS

Source Testing Every 2 years or 8760 operating hours (up

to every 3 years for <2000 total hrs) Conducted by third party

Portable Analyzer Monitoring Initially every weekly/150 hours 3 successful checks, reduced to monthly SCAQMD training/certification is required.


Source Testing, Monitoring, CEMS

CEMS Operate continuously (take samples once

every minute) 15-minute average for compliance Daily calibration Annual relative accuracy test


Step 4: Planning Compliance

Evaluate each engine for what it needs: Monitoring (CEMS or Periodic w/I&M Plan); Recordkeeping (Logs, breakdowns, etc.); Permitting (corrections, modifications, etc.);

and Compliance (control improvements?, etc.).


CEMS & I&M Plan Development

Think through the process carefully and consider your equipment and operations

Plan for the future, not just today Work with your advisors and vendors on

the best approach for your organization Plan for Compliance – not just

periodically, but continuously


I&M Plan Management

Make sure your plan is tailored to your equipment, operation, and organization.

Initial plan should be specific enough to meet the requirements, but not overly complicated.

Changes to the I&M Plan must be submitted and approved.

You should also have an internal guidance document identifying specific responsibilities and schedules.


I&M Plan, Permits and CEMS Apps.

I&M Plan Submittal: Form 400-A Plan Fee $505.35

Permit Applications Form 400-A, 400-CEQA Administrative change fee is $670.50

CEMS Applications Form ST-220AP plus fees…


I&M Plan and CEMS Application Fees

Application fees depend upon engine size and facility type (RECLAIM, Title V, both, or neither)

For example: Simple Administrative fee: $670.50 400 bhp engine I&M Plan: $505.35 CEMS application (w/o RECLAIM or

Title V: $3200 - $10,000


Case Study Issues

AFRCs Audible Alarm and Malfunction Indicator

Light (MIL) Fuel Meters

Temp. and Pressure corrections Logs and recordkeeping

Portable Monitoring Temperature measurement across catalyst


Conclusion

Review permit and rule 1110.2 carefully to determine your compliance options

File applications and I&M Plan on time

Prepare for periodic monitoringIf you need a CEMS, get started early

Documents

SCAQMD Rule 1110.2 Compliance Steps and Strategies Judy Yorke and Bipul K. Saraf