SCAQMD Rule 1470Impact on Diesel Generator Installations

Presented Nov 15, 2012 atBy 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 ExemptFrom 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)

Terminology

• Emergency Use– 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 vs SCAQMD

EQUALS

NEC– Article 700 Emergency Systems– 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”

Terminology

• Emergency Standby Engine– 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

Terminology

• Initial Start-up Testing– 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

Terminology

• Sensitive Receptor– 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

Terminology

• Diesel Particulate Filter (DPF)– 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

Design Considerations

• Total System Backpressure– 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

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

Breaker on Genset

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

Backpressure

Load kW

Temp deg F

Flow acfm

12” Silencer inch H2O

12” Piping: 30’ 4L’s

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

Example - >750 Hp

Particulates (PM)

Tier 4 Interim “Certified”

Clean Emissions Module(CEM)

Diesel Oxidation Catalyst(DOC)

Diesel Particulate Filter(DPF)

Selective Catalytic Reduction(SCR)

Technology Summary

(NRS)

EPA Non-Road Regulatory Impact

Example - >900 bkW genset applications

March 11, 2010

AFTERTREATMENT

MODULE

DEF

TANK

ENGINE / GENSET

DOSING CABINET

& BUFFER TANK

LEGEND

Electrical

Air Supply

DEF Supply

DEF Return

Exhaust

AIR SOURCE

March 11, 2010

CEM = SCR + DOC + ...

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)

Questions/Comments

Thank You

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.com714-282-8240