State of Maryland and Federal Air Quality Regulations Impac

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State of Maryland and Federal Air Quality Regulations Impacting On-Site Power Generation – A Summary for Facility Managers

Alban

Electric

Power

Group

AGENDA

Maryland Air Pollution Control Regulations

Federal Air Pollution Control Regulations

Regulatory Updates

MARYLAND air pollution control regulations

MARYLAND Definitions

Emergency

generator

Operates during an emergency or for testing and engine maintenance purposes, and

Operates for a PJM declared emergency according to procedures in PJM Emergency Operations Manual – 60 hours per year

Non-emergency

generator

Operates beyond an emergency to generate electricity for use on-site or for sale (load shaving)

MARYLAND Permitting Thresholds and Requirements

MDE permit to construct – Fee: $500 per unit

Permit to construct exemption for

emergency generators

less than or equal to 500

brake horsepower (

bhp

) or 373 kilowatt (kW)

Permit required for all non-emergency generators regardless of size

Emissions resulting from the project can also trigger permitting requirements, and will supersede size-specific

exemptions

MD PSC exemption – Fee: $500 per application

Electric

generating units rated greater than 2

megawatt (MW) must apply for a

Certificate of Public Convenience and Necessity

exemption/waiver

from the Maryland Public Service Commission prior to obtaining an air quality permit to construct from MDE

Must allow time in construction schedule for this multi-step process

MARYLAND Emission Standards

Load

shaving

u

nit

r

equirements, COMAR 26.11.36

:

Existing units (constructed on or before January 1, 2009):

Install a

NO

x

control system to meet emissions standard of 1.4 g/

bhp-hr

by July 1, 2010;

Install a new unit that meets Federal NSPS requirements by July 1, 2010; or

Limit operation of load shaving unit to not more than 10 hours from May 1 – September 30

MARYLAND Emission Standards

Load

shaving

u

nit

r

equirements, COMAR 26.11.36

(Cont’d):

New units (constructed after January 1, 2009):

Equipped with

NO

x

control system to meet emissions standard of 1.4 g/

bhp-hr

NSPS engine with capacity less than or equal to 1,000

bhp

is exempt from

NO

x

requirement

Regulations provide an alternate method of compliance

Acquire

ozone season

NO

x

allowances

for the

NO

x

emitted for load shaving purposes during the period of May 1 to September 30 of each year

MARYLANDOther Requirements

Visible

emissions limits

During idle mode – no greater than 10 percent opacity

During operating mode – no greater than 40

percent

opacity

Does

not apply for a period of 2 consecutive minutes after a period of idling of 15 consecutive minutes for the purpose of clearing the exhaust

system

Does

not apply to emissions resulting directly from cold engine start-up and warm-up for the following maximum

periods:

Engines that are idled continuously when not in service: 30

minutes

All

other engines: 15

minutes

Above limits do

not apply while maintenance, repair, or testing is being performed by qualified

mechanics

Restriction on generator

preventive maintenance and testing operations on ozone days (i.e

.,

Code Red days)

Odor and nuisance control regulations

FEDERAL air pollution control regulations

FEDERALNSPS And NESHAP Regulations

New Source Performance Standards (NSPS) 40 CFR Part 60, Subpart IIII

Applicable to compression ignition engines

NSPS

40 CFR Part 60, Subpart JJJJ

Applicable to spark ignition engines

National Emission Standards for Hazardous Air Pollutants (NESHAP) 40 CFR Part 63, Subpart ZZZZ

Controls hazardous air pollutants (HAPs) from new and existing RICE

FEDERALNSPS And NESHAP Regulations

40 CFR Part 60, Subpart IIII -

NSPS

for Stationary Compression Ignition

Internal

Combustion Engines (ICE) – 11 July 2006:

Require stricter emission standards for emergency generators and other ICE, based on model year, displacement, and function

Sulfur content of diesel fuel oil limited to 0.0015%

Certification from the manufacturer that the engine meets emission standards (EPA Certificate of Conformity)

Units must have a non re-settable hour meter

Emergency engines - Maintenance/testing/emergency demand response limited to 100 hours/year

Must perform maintenance in accordance with manufacturer’s recommendations

Records must be kept, including time/duration of operation and reason for use

FEDERALNSPS And NESHAP Regulations

40 CFR Part 60, Subpart IIII

–Tier

4 Final

Tier 4 Final

2013-2015 timeline depending on engine size

Will require after-treatment to reduce

NO

x

and PM emissions – SCR and DPF in most cases

FEDERALNSPS And NESHAP Regulations

40 CFR Part 60, Subpart JJJJ - NSPS for Stationary Spark Ignition ICE – 12 June 2006

Require stricter emission standards for emergency generators and other ICE, based on model year, displacement, and function

Units must have a non re-settable hour meter

Manufacturers are not required to certify most sizes of engines; therefore, owner/operator must test engine to demonstrate compliance

Initial compliance testing within 180 days of startup

Testing every three years or 8,760 hours of operation if > 500

bhp

Emergency engines - Maintenance/Testing limited to 100 hours/year

Must perform maintenance in accordance with manufacturer’s recommendations

Records must be kept, including time/duration of operation and reason for use

FEDERALNSPS And NESHAP Regulations

40 CFR Part 63, Subpart ZZZZ - NESHAP for Stationary Engines

Applicability

Dependent upon location, unit size, fuel type, use (emergency or non-emergency), construction date

Exemption for existing residential, commercial and institutional emergency stationary engines

New versus Existing Engines less than 500

bhp

:

Existing: constructed/reconstructed before June 12, 2006

New: constructed on/after June 12, 2006

Compliance Dates

Existing compression ignition engines: comply by May 13, 2013

Existing spark ignition engines: comply by Oct. 19, 2013

All new engines: comply upon startup

FEDERALNSPS And NESHAP Regulations

40 CFR Part 63, Subpart ZZZZ - NESHAP for Stationary

Engines (Cont’d)

New

engines – comply with NSPS Subpart IIII or JJJJ

Existing engines - Operational limits and requirements:

Operate in accordance with manufacturer recommendations

Potential for additional maintenance requirements as per applicability criteria

Non-emergency engines – submit initial notification, reports of non-compliance, and conduct semi-annual performance tests

Emergency engines - Maintenance/Testing/Emergency Demand Response limited to 100 hours/year

50 hours per year allowed for non-emergency operation (50 hours can also be used for peak shaving until May 2014) but included in 100 hours allowed above for area sources (most facilities you will see)

Regulatory Updates

District court decision on demand response

On May 1, 2015, the U.S. Court of Appeals for the District of Columbia Circuit ("D.C. Circuit") held that the

USEPA acted

arbitrarily and capriciously

when it modified

the NSPS

to allow backup generators to operate without emission controls for up to 100 hours per year in emergency demand-response programs.

As a result of the ruling, the D.C. Circuit reversed the 100-hour exemption and remanded the rules back to

USEPA

for further action 

Regulatory Updates

Relaxation

of inducement requirements on Tier 4 engines

On

November

6, 2015 U.S. EPA proposed specific amendments to 40 CFR Part 60, Subpart

IIII

Would

allow manufacturers to design CI ICE such that operators can temporarily override the emissions control systems for stationary emergency CI ICE where the operation of the engine is needed to protect human

life

Such instances are known as “qualified emergency

situations”

A qualified emergency situation is one in which the condition of a CI ICE emissions controls poses a significant risk to human life; such as an emissions control condition that inhibits the performance of an engine being used to rescue a person from a life-threatening

situation

During such instances the CI ICE must operate in compliance with the applicable Tier 1 emissions standards promulgated at 40 CFR Part 89

Regulatory Updates

Relaxation

of inducement requirements on Tier 4

engines (Cont’d)

The

onus for complying with the majority of these amended requirements falls on the manufacturer, not the owner/operator, as the manufacturer is required to provide instructions to the owner/operator pertaining to operating a CI ICE without emissions controls during qualified emergency

situations

However

, the owner/operator is required to submit a report to the manufacturer within 60 days of operating the CI ICE without the emissions

controls

Questions?

Mike Kendall, LEHS

Director of Environmental Services

(443) 477-3660

mkendall@albancat.com

Terry Darton

Senior Environmental

Consultant

(443) 761-2426

tdarton@albancat.com