Emergency Engine Emissions Standards
Kathi Harris, HOLT CAT Emissions Business Manager - June 13, 2012
The information presented is an interpretation of federal, state
or local regulations and should not be used as legal guidance.
HOLT Power Systems assumes no liability for errors or omissions.
Today’s Agenda
Is this an Actual
Emergency?
Emissions
Standards
Now What?
Emergency?
TEXAS
FEDERAL
Unforeseen power or gas service failure, flood, fire, or lifethreatening situation
YES
YES
Emergency runtime limits (876 hrs per TX Permit)
YES
NO
100 hours per year Maint. & Testing allowed
YES
YES
Severe Storm Avoidance at Airports or NASA
YES
YES
Other Storm Avoidance up to 30 minutes advance
NO
YES
NEW! Demand Response – up to 100 hrs/yr incl. M&T
YES
YES
NEW! Peak Shaving - up to 50 hrs/yr incl. M&T
NO?
YES
EPA Emergency Engine Regs – Current vs. Proposed
Type
Current
Proposed
Demand Response
15 hours per year
100 hours per year
Demand Response
NESHAP only
NSPS and NESHAP will
allow
Peak Shaving
Not allowed
Up to 50 hours per year
Proposed Demand Response Changes
Up to 100 hours per year for non-emergency activities
Hours include Demand Response, Maint. & Testing, Peak Shaving Hours
Can Get Paid – Peak Shaving up to 50 hrs/year
– TCEQ requires PBR 106.512 or Case-By-Case Permit
Fed Regs Aligned (NESHAP & NSPS)
Proposed Changes - Details, Details
Demand Response When:
Regional Transmission
Authority or equivalent
balancing authority declares
Energy Emergency Alert Level
2 (EEA Level 2)
Voltage sag of 5% or more
below standard voltage or
frequency.
Peak Shaving When:
Done as part of program with local
distribution system operators.
Power can only be used at facility
or towards the local system.
Expires April 16, 2017
Texas Requirements
• Permits By Rule (PBR)
– 106.511 (Portable & Emergency Engines & Turbines)
– 106.263 (Maintenance, Startup & Shutdown)
– 106.512 (Stationary Engines & Turbines; Peak Shaving)
– Case-by-case (Peak Shaving)
• PBR 106.511 = 876 hours emergency use
• Paperwork
– 106.511 – review, keep copies, records of compliance, no fee or
registration.
– 106.263 – same as above if MSS project less than 180 days.
http://www.tceq.texas.gov/permitting/air/nav/numerical_index.html
DFW Minor Source NOx Rule
All federal and state regulations plus:
•No Maintenance & Testing 6 am – noon, with few exceptions
• Old Diesels Relocated into DFW must meet at least
emergency engine emissions standards
•Natural Gas-fired = 0.5 g/bhp-hr NOx, 0.6 for landfill gas
Federal Requirements
Diesel
EPA Standards for Certified
Emergency Diesel Gensets
Natural Gas
For most engines >130 hp
NOx: 2.0g/hp-hr (3.0g/hp-hr
existing)
CO: 4.0g/hp-hr
VOC: 1.0g/hp-hr
Install, Configure per Mfg
Hour meter
Initial Emissions Performance Test Use ULSD
Record-keeping
New Regulations - NESHAP 40 CFR 63,
Subpart ZZZZ
Compliance Dates:
– CI: 5/3/2013
– SI: 10/19/2013
Requirements:
– Maintenance specified
– Minimize idle and startup – 30 minutes
– Record-keeping - 5 yrs.
New Regulations Maintenance
Change oil, filter every 500 hrs. or annually.
– Option to use oil analysis program to extend.
Inspect air cleaner every 1,000 hrs. or annually.
Inspect hoses, belts every 500 hrs. or annually, replace as
needed.
Records:
– malfunctions & reducing emissions during, performance
tests, maintenance, monitoring results, hours ops.,
emergency notifications, demand response, peak
shaving, non-emergency uses.
Close, but no cigar!
EPA taking public comments until July 23, 2012
http://www.epa.gov/ttn/atw/rice/ricepg.html
Webinars – 6/20, 6/25, 6/28
Contacts
Your HOLT CAT Salesperson
HOLT CAT IRVING
– 972-721-2000
TCEQ Air Permits Division
– 512-239-1250