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Webinar SeriesPower Generation 201 – Best Practices for Emergency and Non-Emergency Power
November 13, 20191:00 – 2:00 pm ET
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• Attendees phone lines are muted to preserve audio quality.
• Submit a question via the Q&A box, not the Chat.
• Ask “All Panelists”
Q&A
The Diesel Technology Forum is supported by leaders in advanced diesel engines, vehicles, equipment, components and fuels.
• AGCO• Bosch• Caterpillar Inc. • CNH Industrial• Cummins Inc • Daimler • Deere & Company• FCA• General Motors • Isuzu Motors • Johnson Matthey• Mazda North American Operations• MTU America • Neste
• Renewable Energy Group• Tenneco• Umicore• Volvo Group• Yanmar
Allied Members• National Biodiesel Board• Western States Petroleum Association
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• What are the federal rules that cover the installation and operation of emergency and non-emergency source of power generation?
• What is required of equipment owners?
• What is required of equipment manufacturers?
Topics Covered Today
The views and opinions expressed in this course shall not be considered the official position of any regulatory organization and shall not be considered to be, nor be relied upon as, a formal interpretation.
Participants are encouraged to refer to the entire text of all referenced documents. In addition, when it doubt, reach out to the Authority Having Jurisdiction.
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Moderator
Ezra Finkin
Policy Director
The Diesel Technology Forum
Your Presenters
Speaker
T.J. Tarabulski
Global Regulatory Consultant
Caterpillar, Inc.
Speaker
Michael Sanford
Technical Marketing Specialist
Cummins, Inc.
Speaker
Brian Ponstein
Senior Application Engineer
MTU a Rolls Royce solution
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RECAP FROM 101 Webinar
• Unique attributes of diesel technology make stationary and portable diesel emergency generators a ideal choice
• Federal rules and local permitting requirements cover the use of this equipment
• Real world use of this equipment in the field may place limitations on the suitability of aftertreatment technologies
• State of the art solution rests on Tier 2 solutions
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What are the Rules Governing Equipment Installation?
We will Focus on these Rules for Compression Ignition, or Diesel Engines
We might be familiar with the emissions requirements for things that move…but what about stationary engines that generate power?
Gensets are the only power generation certified by the manufacturer
What is NSPS?
New Source Performance Standards
What is NSPS?
New Source Performance Standards
What is NSPS?
New Source Performance Standards
Source of emissions, when manufactured or installed
What is NSPS?
New Source Performance Standards
What is NSPS?
New Source Performance Standards
Emissions limits, operational guidelines and test methodologies
What is NSPS?
New Source Performance Standards
Emissions limits, operational guidelines and test methodologies
Source of emissions, when manufactured or installed
What is NSPS?New Source Performance Standards
Emissions limits, operational guidelines and test methodologies
Applies to New Modified or Reconstructed Stationary Emissions Sources,
Approximately 90 NSPS Regulated Emissions Sources
Only Stationary Engines and Woodstoves are manufacturer Certified!
Remaining 88 Sources are tested on-site at the State level
Requirements for EPA Certified Engines
What is Required for an Emergency Generator & What is Required for Non-Emergency Generator
Engines Are Certified….not Gensets!
Requirements for EPA Certified Engines
• Engines are certified, not generator sets.
• Engines are required to meet emissions levels based on their date of manufacture, usage and brake horsepower rating.
Purpose of Engine Operation Engine Type
Emergency
Non-Emergency
Emergency
Non-Emergency
Emergency
Non-Emergency
Emergency
Non-Emergency
Emergency Vacated May 1, 2016
Non-Emergency
Emergency
Non-Emergency
Emergency
Non-Emergency
0 50 100 Unlimited
Engine Hours/Year
Key - Allowed Prohibited
(f)(3)(i)
Testing and Maintenance
Storm Avoidance
Owner Operator Peaking
Independent System Operator Peaking (f)(2)(ii)&(iii)
Local Grid Financial Arrangement
(local demand response)
Emergency
(loss of normal power)
Independent System Operator (ISO)
Demand Response
(f)(2)(i)
(f)(3)
(f)(3)(i)
(f)(1)
(f)(2)(ii)&(iii)
40 CFR 60.4211 Allowable Hours of Operation/Year
U.S. EPA Emergency Engine Redefined: Demand Response Disallowed
State and local requirements may differ from the above interpretations.
18Case Study: A hospital wants to install
a standby generator. What happens next?
Major Population Centers are Located in Regions not in attainment for federal air quality standards
Regional and state policymaker need to develop, submit and receive approval for State Implementation Plans to make sure sources of emergency and non-emergency power are in keeping with the air quality needs of the region.
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• Your state air pollution control or air quality office is your friend. These officials can walk you through what is required in the region/locality
• Power Generator dealers can facilitate this conversation.
• Be wary of consultants – do your homework
What Should Our Hospital in Our Fictional State do to Install Standby
Power?
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• Equipment should be maintained and tested in accordance with EPA rules and local requirements as outlined in the permit.
• Are you now required to test equipment?• Engines are certified when they leave the factory and certification tests are the
responsibility of manufacturers
• Facility owners should be consider spot checks as opposed to performance tests that are the responsibility of manufacturers.
Our Hospital Has Installed a Generator. What Next?
21Many Maintenance Requirements for
Equipment Owners
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• Emergency: Typically 5 minutes in duration or less. Most customers experiencing an outage longer than 5 minutes will experience an average outage of 112 minutes.
How are Emergency Units Used in the Real World?
• Equipment Owners: EPA testing requirement
• Manufacturers: Emissions standards
Best Available Control Technology
Emergency GeneratorTier 2 – Above 560 kW mechanicalTier 3 – Under 560 Kw mechanical
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How Are Non-Emergency Units Used in the Real World
Best Available Control Technology
Non-Emergency GeneratorAll kW mechanical = Tier 4
Equipment Owners - need for proper maintenance to keep equipment performing as manufactured and certified
Manufacturers - Industry is willing to work with policymakers on workable enforcement rules
Examples = setting limits for very low NOx limits including run times for emergency use (Mike has case study on a fictional state)
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Requirements Regarding Testing of Units
“State and local agencies are not prevented from providing additional regulations beyond these regulations and such agencies may institute additional testing requirements independent of EPA related actions.”Response to Public Comments on Proposed Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
States have the authority to conduct additional tests beyond US EPA requirements. EPA does not require site emissions tests for manufacturer certified products. Additional emissions tests add no value for end users or States for properly maintained certified engines
State / City / County Requirements
State / City / County Requirements
State / City / County Requirements
On-Site Testing
• Non-standard equipment may be needed to secure air-permit / conduct on-site testing:
• Fuel flow meter(s)
• Pollutant monitor(s)
• Exhaust sample port(s)
• Load banks
• Test methodology and permit data must be verified by equipment manufacturer.
• Applicable environmental correction factors allowable by AHJ must be identified.
• Costs and time associated with on-site testing requirements must be considered.
• Review air permit requirements early in the project in order to accommodate lead times.
• Leverage experience of third-party testing companies and engine manufacturers.
• Review implications of failing on-site test including penalties and project delays.
• Permitted emissions values may need to be provided by the engine manufacturer.
On-Site Testing
• Non-standard equipment may be needed to secure air-permit / conduct on-site testing:
• Fuel flow meter(s)
• Pollutant monitor(s)
• Exhaust sample port(s)
• Load banks
• Test methodology and permit data must be verified by equipment manufacturer.
• Applicable environmental correction factors allowable by AHJ must be identified.
• Costs and time associated with on-site testing requirements must be considered.
• Review air permit requirements early in the project in order to accommodate lead times.
• Leverage experience of third-party testing companies and engine manufacturers.
• Review implications of failing on-site test including penalties and project delays.
• Permitted emissions values may need to be provided by the engine manufacturer.
On-Site Testing
• Non-standard equipment may be needed to secure air-permit / conduct on-site testing:
• Fuel flow meter(s)
• Pollutant monitor(s)
• Exhaust sample port(s)
• Load banks
• Test methodology and permit data must be verified by equipment manufacturer.
• Applicable environmental correction factors allowable by AHJ must be identified.
• Costs and time associated with on-site testing requirements must be considered.
• Review air permit requirements early in the project in order to accommodate lead times.
• Leverage experience of third-party testing companies and engine manufacturers.
• Review implications of failing on-site test including penalties and project delays.
• Permitted emissions values may need to be provided by the engine manufacturer.
On-Site Testing
• Non-standard equipment may be needed to secure air-permit / conduct on-site testing:
• Fuel flow meter(s)
• Pollutant monitor(s)
• Exhaust sample port(s)
• Load banks
• Test methodology and permit data must be verified by equipment manufacturer.
• Applicable environmental correction factors allowable by AHJ must be identified.
• Costs and time associated with on-site testing requirements must be considered.
• Review air permit requirements early in the project in order to accommodate lead times.
• Leverage experience of third-party testing companies and engine manufacturers.
• Review implications of failing on-site test including penalties and project delays.
• Permitted emissions values may need to be provided by the engine manufacturer.
On-Site Testing
• Non-standard equipment may be needed to secure air-permit / conduct on-site testing:
• Fuel flow meter(s)
• Pollutant monitor(s)
• Exhaust sample port(s)
• Load banks
• Test methodology and permit data must be verified by equipment manufacturer.
• Applicable environmental correction factors allowable by AHJ must be identified.
• Costs and time associated with on-site testing requirements must be considered.
• Review air permit requirements early in the project in order to accommodate lead times.
• Leverage experience of third-party testing companies and engine manufacturers.
• Review implications of failing on-site test including penalties and project delays.
• Permitted emissions values may need to be provided by the engine manufacturer.
On-Site Testing
• Non-standard equipment may be needed to secure air-permit / conduct on-site testing:
• Fuel flow meter(s)
• Pollutant monitor(s)
• Exhaust sample port(s)
• Load banks
• Test methodology and permit data must be verified by equipment manufacturer.
• Applicable environmental correction factors allowable by AHJ must be identified.
• Costs and time associated with on-site testing requirements must be considered.
• Review air permit requirements early in the project in order to accommodate lead times.
• Leverage experience of third-party testing companies and engine manufacturers.
• Review implications of failing on-site test including penalties and project delays.
• Permitted emissions values may need to be provided by the engine manufacturer.
On-Site Testing
• Non-standard equipment may be needed to secure air-permit / conduct on-site testing:
• Fuel flow meter(s)
• Pollutant monitor(s)
• Exhaust sample port(s)
• Load banks
• Test methodology and permit data must be verified by equipment manufacturer.
• Applicable environmental correction factors allowable by AHJ must be identified.
• Costs and time associated with on-site testing requirements must be considered.
• Review air permit requirements early in the project in order to accommodate lead times.
• Leverage experience of third-party testing companies and engine manufacturers.
• Review implications of failing on-site test including penalties and project delays.
• Permitted emissions values may need to be provided by the engine manufacturer.
Caterpillar: Confidential Green
NSPS Permit Streamlining: Why Now?
1. Understanding emissions levels accurately is critical for permitting stationary
engines.
2. Customers have to meet Federal and State Requirements which can vary and
certified product is not easily modified.
3. Site Emissions Tests conducted by states use different methods than mfr’s are
required to use for certification.
4. PM 2.5 NAAQS and GHG Regulations have added additional reporting
requirements for end users.
5. CI, SI engines and woodstoves are the only U.S. EPA manufacturer Certified
NSPS Category.
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Caterpillar: Confidential Green
EMA Recommendations
1. Wherever possible, harmonize any State-specific emissions limits for stationary engines with the NSPS.
2. Wherever possible, SI and CI NSPS-manufacturer certified emergency (CI Tier 2/Tier 3) and non-emergency (CI
Tier 4) products should be considered BACT for PSD (attainment areas) and LAER for NSR (non-attainment
areas) permits without further testing.
3. Minimize and streamline permitting requirements for sources using NSPS-certified engines.
4. Eliminate requirements for any additional source testing of stationary engines that are NSPS-certified, utilizing
manufacturer supplied data (see Attachment 1) to estimate annual emissions (tons/year).
5. Accept engine manufacturer’s certified emissions test results and owner/operator maintenance records as a
demonstration of compliance.
6. In those instances where source testing is necessary (e.g. renewal of permits), utilize EMA recommended test
methods and reporting template (see Attachment 1) including for formaldehyde and its surrogates.
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Caterpillar: Confidential Green
Manufacturer Emissions Report
• Applicable Emissions Standard
• Applicable Certified Family Cycle-Weighted Results
• Permit Value (PV) - Emissions at 100% engine load and rpm for “Potential to
Emit” calculation
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Caterpillar: Confidential Green
Permit Value: Manufacturer Nominal Value
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• Federal New Source Performance Standards govern the installation and use of stationary generators for emergency & non-emergency use
• Manufacturers are required to meet specific emissions requirements of this equipment
• Often state and local rules regarding use and testing are confusing and even counter-productive
• There is an industry solution that can meet federal rules and local needs to safeguard air quality
Summing up the Discussion
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• Attendees phone lines are muted to preserve audio quality.
• Submit a question via the Q&A box, not the Chat.
• Ask “All Panelists”
Q&A
