Webinar Series Power Generation 201 – Best Practices for Emergency and Non-Emergency Power November 13, 2019 1:00 – 2:00 pm ET
2 Q&A Q&A • Attendees phone lines are muted to preserve audio quality. • Submit a question via the Q&A box, not the Chat. • Ask “All Panelists”
The Diesel Technology Forum is supported by leaders in advanced diesel engines, vehicles, equipment, components and fuels. • • AGCO Renewable Energy Group • • Bosch Tenneco • • Caterpillar Inc. Umicore • • CNH Industrial Volvo Group • • Cummins Inc Yanmar • Daimler • Deere & Company Allied Members • • FCA National Biodiesel Board • • General Motors Western States Petroleum Association • Isuzu Motors • Johnson Matthey • Mazda North American Operations • MTU America • Neste
4 Topics opics Co Cover ered T ed Today oday • 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? 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.
5 Your Pr our Presen esenter ters Speaker Speaker Speaker Moderator T.J. Tarabulski Michael Sanford Brian Ponstein Ezra Finkin Global Regulatory Technical Marketing Senior Application Policy Director Consultant Specialist Engineer The Diesel Technology Caterpillar, Inc. Cummins, Inc. MTU a Rolls Royce Forum solution
6 RECAP FR RECAP FROM OM 101 W 101 Webinar binar • 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
7 Wha hat ar t are the e the Rules Go ules Gover erning ning Equipment Installa Equipment Installation? tion? We might be familiar with the emissions requirements for things that move…but what about stationary engines that generate power? We will Focus on Gensets are the these Rules for only power Compression generation Ignition, or certified by the Diesel Engines 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 Engines Are Certified….not Gensets! What is Required for an Emergency Generator & What is Required for Non- Emergency Generator
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.
U.S. EPA Emergency Engine Redefined: Demand Response Disallowed Purpose of Engine Operation Engine Type Allowable Hours of Operation/Year 40 CFR 60.4211 Emergency Testing and Maintenance (f)(2)(i) Non-Emergency Emergency Storm Avoidance (f)(3) Non-Emergency Local Grid Financial Arrangement Emergency (f)(3)(i) (local demand response) Non-Emergency Emergency Emergency (f)(1) (loss of normal power) Non-Emergency Emergency Vacated May 1, 2016 Independent System Operator (ISO) (f)(2)(ii)&(iii) Demand Response Non-Emergency Emergency Independent System Operator Peaking (f)(2)(ii)&(iii) Non-Emergency Emergency Owner Operator Peaking (f)(3)(i) Non-Emergency 0 50 100 Unlimited State and local requirements may Engine Hours/Year differ from the above Key - Allowed Prohibited interpretations.
18 Ca Case se St Stud udy: y: A ho A hosp spita ital l wan ants ts to to inst install all a st a stan andb dby y ge gene nerato tor. . W Wha hat t ha happ ppen ens s next ne xt? 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.
19 Wha hat t Sh Shou ould ld Ou Our r Ho Hosp spita ital l in in Ou Our r Fict Fictiona ional l Sta State te do do to to I Ins nsta tall ll Sta Stand ndby by Power er? • 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
20 Our Hos Our Hospital Has Inst pital Has Installed a alled a Gener Generator tor. . W Wha hat Ne t Next? xt? • 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.
21 Man Many y Main Mainte tena nanc nce e Req equir uirem emen ents ts for or Equ Equipmen ipment t Owne Owners
22 Ho How w ar are Em e Emer erge genc ncy y Un Units its Us Used ed in in th the e Real eal Wor orld? ld? • 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. • Equipment Owners: EPA testing requirement • Manufacturers: Emissions standards Best Available Control Technology Emergency Generator Tier 2 – Above 560 kW mechanical Tier 3 – Under 560 Kw mechanical
23 Ho How Ar w Are Non e Non-Emer Emergenc gency y Units Used in the R Units Used in the Real W eal Wor orld ld Equipment Owners - need for proper Best Available Control Technology maintenance to keep equipment performing as manufactured and certified Non-Emergency Generator All kW mechanical = Tier 4 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)
24 Requir equirements R ements Regar garding ding Testing of esting of Units 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 Costs and time associated with on-site testing secure air-permit / conduct on-site testing: requirements must be considered. • Fuel flow meter(s) • Review air permit requirements early in the • Pollutant monitor(s) project in order to accommodate lead times. • Exhaust sample port(s) • Leverage experience of third-party testing • Load banks companies and engine manufacturers. • • Test methodology and permit data must be Review implications of failing on-site test verified by equipment manufacturer. including penalties and project delays. • • Applicable environmental correction factors Permitted emissions values may need to be allowable by AHJ must be identified. provided by the engine manufacturer.
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