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NDEQ NESHAP Training Subpart ZZZZ - Engines

NDEQ NESHAP Training Subpart ZZZZ - Engines. Melissa Ellis February 24, 2011. Overview. Objectives Industry Overview Rule Background Applicability Requirements Tips Tools & Resources. Acronyms. HP = horsepower CI = compression ignition SI = spark ignition 4S = four stroke

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NDEQ NESHAP Training Subpart ZZZZ - Engines

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  1. NDEQ NESHAP Training Subpart ZZZZ - Engines Melissa Ellis February 24, 2011

  2. Overview • Objectives • Industry Overview • Rule Background • Applicability • Requirements • Tips • Tools & Resources

  3. Acronyms • HP = horsepower • CI = compression ignition • SI = spark ignition • 4S = four stroke • 2S = two stroke • LB = lean burn • RB = rich burn

  4. Objectives • Become familiar with industry • Understand rule requirements • Be aware of tools & resources to help do your job more effectively

  5. Industry Overview

  6. Industry Overview • Stationary Internal Combustion Engines • Point of use for 12 months OR 3-12 months for seasonal • Not used to propel motor vehicle • Not a non-road engine

  7. Industry Overview • Engines manufactured the same, used differently • Electrical generators & powering emission units • Compression Ignition • Spark Ignition

  8. Compression Ignition Engines • Diesel or dual fuel • Heat from compression auto-ignites fuel & air mixture • Two-stroke & four-stroke • Diesel trucks

  9. Compression Ignition

  10. Spark Ignition Engines • Gasoline or natural gas • Spark plug ignites fuel/air mixture • Motor vehicle • Two-stroke or Four-stroke • Lean burn or rich burn

  11. Spark Ignition Engines • Rich Burn • Excess fuel in combustion chamber during combustion • Mfg. recommends operating air/fuel ratio divided by stoichiometric at full load = < 1.1 • Existing with no mfg. recommendations if O2 in exhaust at full load < 2%

  12. Spark Ignition Engines • Lean Burn • Excess air in combustion chamber • O2 rich exhaust • Not rich burn

  13. Spark Ignition

  14. Spark Ignition Engines

  15. Nebraska Sources • LOTS? • 96+ facilities have notified • Multiple engines on-site • Many more that don’t need to notify • Mostly municipal power plants & asphalt/concrete • Most compression ignition

  16. Rule Background

  17. Rule Background • NESHAP Subpart ZZZZ • 40 CFR Part 63 – 63.6580 • Title 129, Chapter 28 001.88 (not current rules) • Initial final rule = 6/15/04 (effective 8/16/04)

  18. Rule Background • 4 significant rule actions • Original: June 15, 2004 • Revision: January 18, 2008 (effective 3/18/08) • Revision: March 3, 2010 (effective 5/3/10) • Revision: August 20, 2010 (effective 10/19/10)

  19. Applicability

  20. Applicability • Stationary sources • Major & area sources of HAP • New & existing sources • Need to know: • Manufacture date, installation date, startup date, fuel, engine type, horsepower, displacement, black start, emergency or non-emergency

  21. Applicability • Not subject • Not engines tested @ test cell/stand • RICE for national security • Request exemption • 40 CFR Part 1068, Subpart C • Existing emergency residential, commercial, or institutional at area source • Some existing > 500 HP at major source

  22. Applicability • Residential, commercial, institutional • Homes & apartments • Office, hotel, stores, restaurants, banks, etc. • Hospitals, schools, police station, fire, etc. • Farming – not exempt • Most smaller engines • See Air Toxics Notebook for list

  23. Emergency Engines • Emergency & required testing & maintenance • Not peak shaving for your facility or the grid • Does not have interruptible service contract with power utility

  24. Emergency Engines • Can be used up to 15 hours/yr as part of demand response • Can supply emergency power as part of financial agreement • 100 hours/yr – testing & maintenance • 50 hours/yr for non-emergency • Includes 15 hours for demand response

  25. Reconsideration • 12/7/10 • 15 hours for demand response • Emergency conditions could lead to potential blackout (unusually low frequency, equipment overload, capacity or energy deficiency, or unacceptable voltage level)

  26. Black Start & Limited Use • Black Start • Used to start combustion turbines • Different terminology than industry • Limited Use • Operate < 100 hours/yr

  27. Requirements

  28. Source Classification • Area Source • Existing = Before 6/12/06 • Change in ownership doesn’t make new • New = On or after 6/12/06

  29. Source Classification • Major Source • Existing • > 500 HP = Before 12/19/02 • < 500 HP = Before 6/12/06 • New • > 500 HP = On or after 12/19/02 • < 500 HP = On or after 6/12/06

  30. Typical Controls • Oxidation Catalyst • Spark ignition lean burn & compression ignition • Selective Catalytic Reduction (SCR) • Spark ignition lean burn & compression ignition • Non-selective Catalytic Reduction (NSCR) • Spark ignition rich burn

  31. Catalysts • Causes chemical reactions without being changed or consumed • Steel housing contains a metal or ceramic structure which acts as a catalyst support or substrate. • No moving parts, interior surfaces coated with base or precious catalytic metals • Chemical reaction differs depending on lean, rich, or stoichiometric

  32. Oxidation Catalyst • Flow through honeycomb coated with platinum metals • Small parallel channels = high catalytic contact area to exhaust • Completes combustion & mixed with free O2 in exhaust • Pollutants oxidized into CO2 & H2O vapor • Doesn’t reduce NOx • May need to be combined with SCR

  33. Diesel Oxidation Catalyst

  34. Selective Catalytic Reduction • Converts NOxwith aid of catalyst into N2 and H2O • Anhydrous ammonia, aqueous ammonia or urea added to exhaust & absorbed onto catalyst • CO2 is a reaction product when urea is used

  35. Selective Catalytic Reduction (SCR)

  36. Diesel SCR

  37. Non-selective Catalytic Reduction (NSCR) • Also Three-Way Catalysts (stoichiometric) • Causes CO to react with NOx in presence of catalyst • Creates N2 and H2O vapor

  38. Area Sources Compression Ignition (SI) Spark Ignition (SI)

  39. No Requirements • Existing • Emergency residential, commercial, & institutional at area

  40. No NESHAP Requirements May Be Subject to NSPS • New area sources

  41. Existing CI @ Area • Work practice • Emergency (hour meter) • Black start • Non-emergency < 300 HP • Numerical standards • Non-emergency > 300 HP

  42. Work Practice Standards

  43. Work Practice Standards • Records • Malfunctions • Maintenance • Emergency – hours of operation • No reports or notifications required

  44. Non-emergency > 300 HP • CO limits • Initial Testing • Closed crankcase • Sulfur fuel requirements < 30 l/cyl

  45. Non-emergency > 500 HP • Meet all from previous slide and • Periodic testing • Every three years or 8,760 hours • Limited use = Every five years or 8,760 hours • Continuous monitoring • CPMS • CEMS

  46. Non-emergency > 300 HP • Initial notification • 8/31/10 • Performance test • 60 days prior to test • Compliance Status • Within 60 days after test

  47. Non-emergency > 300 HP • Reports • Semiannual • Malfunctions & deviations • Even if none • Due 30 days after calendar half or according to Title V schedule • Annual if limited use

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