engine emissions stack testing

Engine Emissions Stack Testing and Analyzer Workshop

New Air Regulations, Test Requirements and Test Strategies

Jeff Thomason, QSTI

P j t Di tProject DirectorTRC

9225 U.S. Highway 183 SouthAustin, Texas512/243-0202

Topics of Conversation

Federal Regulations Subpart JJJJ Subpart ZZZZ Greenhouse Gases Measuring Hydrocarbons EPA Methods 1 and 1A VOCs, HAPs, & Hard Stuff

EPA National Stack Testing Guidelines

Goals Improve uniformity on how tests are

conducted Improve coordination between EPA and Improve coordination between EPA and

state/local agencies Enhance EPA oversight of state/local

programs http://www.epa.gov/ttn/emc/guidlnd/g

d-050.pdf


Regulated units include Reciprocating Internal Combustion

Engines NSPS Turbines NSPS Turbines Title V and PSD Permitted Sources

Title V: 10 tons / 25 tons qualifiers

Adopted by State Agencies for Construction &

Operating Permits


Section VI-Conduct of Stack Tests1. Time Frame

a facility that has not completed a stack test within the requisite time frame would be in violation of the requirement to stack test


Section VI-Conduct of Stack Tests2. Test Waivers-NO WAIVERS even on identical NO WAIVERSeven on identical units unless:

in service at the same facilityoperated/maintained the same wayemissions applicable standard


Section VI-Conduct of Stack Tests3. Notification of Stack Tests

Timing and content of notification Must provide notification of delays

as soon as possibleNotification is not necessary if the test

is for the facilitys own benefitHOWEVER


IF YOU FAIL (and are a Title V source)

YOU MUST REPORT THE FAILURE AND SUBMIT THE DATA TO THE PROPER AGENCY


Section VI-Conduct of Stack Tests Test Protocol should be submitted

www.epa.gov/compliance/assistance/air/index.htmlhtml

Tell the agency which unit, where, why, when, and who

Explain the test matrix Describe process data and load determination Identify the test methods, and explain any request

for deviations


Section VI-Conduct of Stack Tests Observation of Stack Tests

Will they come? Why should it matter? If notification wasnt timely then the

resulting test data may be rejected and a new stack test required.


Section VI-Conduct of Stack Tests Representative Testing Conditions Generally, test at the maximum load condition y,

the source is designed for If you do not operate at that level, test at

where you do operate but you must DOCUMENT historical trends

Different state/local agencies have their own criteria


Section VI-Conduct of Stack Tests Stoppages

If you stop because you might fail, you y p y g , ywould be considered in violation of both the requirement to test and the permit condition

If you have to stop because of equipment failure, severe weather and/or safety, complete the run thats in progress if possible and fully document the reasons for stoppage


Section VI-Conduct of Stack Tests Postponements

Considered in same way as stoppagesy pp g the delegated agency should carefully

scrutinize the circumstances surrounding the postponement to determine whether the facility was in violation of the underlying emission limitationsand postponed to avoid a documented violation.


Section VI-Conduct of Stack Tests Reports

Should be detailed enough to assess Should be detailed enough to assess compliance with the regulatory requirements

www.epa.gov/ttnemc01/guidlnd/gd-043.wpd

Submit as soon as possible-most states have specific timelines-Typically 30, 45, or 60 days. EPA reports have 60 days


Section VI-Conduct of Stack Tests Rounding of Significant Figures

Report the same number of figures that Report the same number of figures that are in your permit

If its less than 5, round down. If its more than 5, round up

If its exactly 5 followed by zeros, round up if the number is odd. Leave it if the number is even

Subpart JJJJ

QUAD JQUAD J

Subpart JJJJ

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

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

Published January 18, 2008 Affects ALL new, reconstructed or modified

IC engines Standards get more stringent in 2010/2011

depending on engine type/size

Subpart JJJJ

Technology Basis Rich Burn: NSCR Lean Burn: combustion based controls

(Low Emission Combustion)

Pollutants and Emission Limits

(Low Emission Combustion) Emission Limits for NOx, CO, VOC

VOC as defined includes HCHO, but notincluded for this subpart

NOx + HC included for some smaller engines

Subpart JJJJ

Non-Emergency Engines 100hp

Subpart JJJJ

Non-Emergency Lean Burn Engines 500hp

Subpart JJJJ

Non-Emergency Engines (except LB) 500 hp


MFGDATE NOx CO VOC NOx CO VOC

7/1/2007 2.0 4.0 1.0 160 540 867/1/2010 1.0 2.0 0.7 82 270 60

g/bhp-hr ppmv @ 15% O2

Subpart JJJJ

Natural Gas Fired Lawn Mower Engines 25hp100


MFGDATE CO

7/1/2008 6.53.8HC + NOx

g/bhp-hr

Subpart JJJJ

Reconstructed or modified engines Applies to EXISTING UNITS (6/12/06)


R/M ppmv @ 15% O2g/bhp-hr

25 hp must meet new engine standard New engines subject to JJJJ that are R/M

must meet JJJJ standards

R/MDATE NOx CO VOC NOx CO VOC

6/12/2006 3.0 4.0 1.0 250 540 86(non emgy,

Subpart JJJJ

What is new? Date the engine was ordered is the day

construction starts

If ordered on or before 6/12/06, engine is EXISTING and Quad J engine is EXISTING and Quad J doesnt apply

If ordered after 6/12/06 but MANUFACTURED before, Quad J doesnt apply

If ordered after and manufactured after 6/12/06, Quad J DOES apply

Subpart JJJJ

What is Modified? Physical or operational change to an

existing facility that results in an increase in the emission rate

An existing facility is affected for each pollutant with a standard and an emission rate increase

Exemptions include installation of pollutant control devices

Compliance required within 180 days of the change

Subpart JJJJ

EPA Revisions proposed 6/8/10

Proposed rule includes new definition for reconstruction The fixed capital cost of new components

exceeds 50% of the cost of an entirely new facility in todays $$$

Engineering, transportation, installation, start-up, etc. costs must be INCLUDED

Must be feasible

Subpart JJJJ

EPA Revisions proposed 6/8/10 New definition: For purposes of

reconstruction, an existing t ti i i d fi d stationary engine is defined as

including those components mounted to or within the cylinder block, the engine housings, and engine mounted components, but excluding ancillary components such as external cooling for fuel supply.

Subpart JJJJ

EPA Revisions proposed 6/8/10 Draws narrower box around the equipment

considered in cost calculations than historical NSPS determinations and historical NSPS determinations and excludes necessary engine components

Mobile source paradigm (mounted on engine) does not properly consider stationary source scenario Comments stressed that components

inherent to engine operation (e.g., cooling) should be included in the costs

Subpart JJJJ

EPA Revisions proposed 6/8/10

Date of manufacture definition includes:Reconstructed engines are assigned a new date of manufacture if the crankshaft is removed as part of the reconstruction or if the the crankshaft is removed as part of the reconstruction or if the fixed capital cost of the new and refurbished components exceeds 75 percent of the fixed capital cost of a comparable new engine (see the definition of "reconstruct"). An engine that is produced from a previously used engine block does not retain the date of manufacture of the engine in which the engine block was previously used if the engine serial number was removed (or the engine otherwise loses its identity), or the engine is produced using all new components except for the engine block. In all these cases, the date of manufacture is the date of reconstruction or the date the new engine is produced.

Subpart JJJJ

What about Relocation? In and of itself, relocation does NOT

trigger modification or reconstruction and are not subject t NSPS to NSPS (unless manufactured after the earlier dates)

Evaluate whether reconstruction or modification occurs

EPA says changes in control equipment or method of operation can trigger applicability

Subpart JJJJAdditional stuff for relocated

engines Operators must understand changes,

if any, to relocated engines Has engine been modified i e rich to Has engine been modified, i.e. rich to

lean? Was engine rebuilt or was major

maintenance or repair completed?

Ownership changes does not make an engine new

Operators ARE responsible for ensuring compliance of relocated engines

Subpart JJJJ

Engine Rating (40CFR1039.140)An engine configurations maximum

engine power is the maximum brake power point on the nominal power curve power point on the nominal power curve for engine configuration

o Its manufacturer nameplate rating without consideration of elevation, etc.

o RICE MACT is site rated.

Subpart JJJJ

THREE ENGINE TYPES1. Certified Engines

2. Non-Certified Engines2. Non Certified Engines

3. Certified engines operating as non-certified engines

Subpart JJJJ

CERTIFIEDo manufacturers test the engine

according to a defined operating cycle to validate compliance

o Full Load tests requiredo High Load engines- 100% & 75%o ISO 8178, D-1 Cycle-100/100% plus

30%/100%; 50%/75%; 20%/50%o DO NOT require compliance tests

under JJJJ, but many states require it

Subpart JJJJ

CERTIFIEDo MFG insures compliance for certified

emissions life-5000 operating hours or lessMFG O&M MUST be followed by o MFG O&M MUST be followed by operator

o Operators must comply with the emission standards for the life of the engine

Subpart JJJJ

NON-CERTIFIEDo Requires an initial performance testo Maintenance plan & recordso Periodic tests for engines >500 Hpg p

o Every 8760 hours or once per 3 years

o No further tests for engines< 500 HPo Unless major repair or rebuild

(40CFR60.4243(f))o Major repair or rebuild is not defined

Subpart JJJJ

CERTIFIED OPERATING AS NON-CERTIFIED

o Operators can opt not to follow MFG O&M or may be precluded y p(fuel quality)

o Same requirements as non-certified

o Engines

Subpart JJJJ

PERFORMANCE TESTSo Subpart REQUIRES compliance

demonstration for NOx, CO, VOCo Applies to modified/reconstructedo Applies to modified/reconstructedo Applies to Non-Certified Engineso Applies to Certified operating as

Non-Certified 100 Hp

Subpart JJJJ

PERFORMANCE TESTSTest Timeline

o Non-certified > 25 Hp: within 60 days of max production but no later than 180 days of startuplater than 180 days of startup

o CONC 100 Hp: within 1 year of start up

o Subsequent tests for both >500 Hp every 8760 hrs/3 years

o After rebuild or major repair for engines >500 Hp

Subpart JJJJ

PERFORMANCE TESTSTest trigger for rebuild/major

repair not currently well definedo Operators burden to determine if

requiredo DOCUMENT THE DECISION

Subpart JJJJ

PERFORMANCE TESTSo Three test runs of at least one

houro Operate at 100 10%o Operate at 100 10%o Measure/collect at outlet of

any control deviceso Dont test during start up,

shut down or malfunction

Subpart JJJJ

PERFORMANCE TESTSo Measure NOx, CO, VOC, O2

and moistureo If complying with g/Hp-hr

o Exhaust gas flow rateo Hp

Subpart JJJJ

PERFORMANCE TESTSo EPA Reference Methods

o NOx-7Eo CO-10o O2-3Ao VOC methods to come

Subpart JJJJ

PERFORMANCE TESTSo Portable Analyzer Methods

o ASTM D6522o Administrator approved alternative portable analyzer method

o ASTM D6420-99 (GC/MS)

Subpart JJJJ

PERFORMANCE TESTSo Fourier Transform Infrared

Spectroscopy (FTIR)o EPA RM 320o ASTM D6348-03

o Wet or Dry Basis?o So?

Subpart JJJJ

PERFORMANCE TESTSo VOC Test Issues

o Does not include methane (CH ) th (C H )(CH4) or ethane (C2H6)

o Does not include HCHOo Reported as ppmv Propaneo Two approaches- additive or subtractive

Subpart JJJJ

PERFORMANCE TESTSo Additive Methods

o Quantify and sum applicable i di id l HC iindividual HC species

o Can be beneficial for NG fired sources due to high CH4/C2H6composition

Subpart JJJJ

PERFORMANCE TESTSo Subtractive Methods

o Difference between THC and CH + C HCH4 + C2H6

o Subtracting two very similar numbers can cause error

o Shouldnt be a problem if C2H6is

Subpart JJJJ

PERFORMANCE TESTSo Additive Methods

o Gas Chromatographyo FTIR

Presurvey requiredo Presurvey requiredo INGAA and EPA discussion of one-time

presurvey to define VOC species for NG-fired ICEs

o Option to adjust aldehydes and other oxygenated HC for 25A response factors

Subpart JJJJ

PERFORMANCE TESTSo Subtractive Methods

o EPA 25A +Gas Chromatographyo VOC = THC (CH + C H )o VOC = THC (CH4 + C2H6)o Poor response to HCHO but not a VOCo Must be performed very well

o EPA 25A with a methane cuttero Dual channel FIDo Possible high bias if high C2H6

Subpart JJJJ

PERFORMANCE TESTSo Exhaust Moisture

o VOC measured hot & weto Mass emissions are dryo Everything must be on same basis

Subpart JJJJ

PERFORMANCE TESTSo Exhaust Flow

o EPA Method 2 Pitot Tubeo EPA Method 19 o EPA Method 19

o Preferred due to pulsating flowo Must have

o Fuel Flow rate (orifice cal!)o Fuel Composition (not last

years)

Subpart ZZZZ

Reciprocating Internal Combustion Engines (RICE), Maximum Available Control Technology (MACT)

Subpart ZZZZ (RICE MACT) is designed to regulate hazardous air pollutants (HAPS). In the case of reciprocating engines, the surrogates are Carbon Monoxide (CO) and Formaldehyde (HCHO).

Subpart ZZZZ

RICE MACT REVISITEDo Final Rule amended 8/20/10o EFFECTIVE DATE IS 10/19/10o Three years (10/19/13) for newly o Three years (10/19/13) for newly

affected engines to complyo Now includes all engines except

existing major source lean burns >500 Hp

o These will be addressed in 2012

Subpart ZZZZ

RICE MACT REVISITEDo With proposed amendments,

ALL new and reconstructed units are affected regardless units are affected regardless of size

o Most units comply based on NSPS

o Original RICE MACT rule applies as appropriate

Subpart ZZZZ

RICE MACT REVISITEDo Major HAP source emits

o 10 tons/year of a single HAPo 25 tons/year of cumulative HAPSo 25 tons/year of cumulative HAPSo HCHO typically drives major source

status for sites with multiple RICEo If emissions reduced below the

threshold prior to the regulatory date, facility is an area source.

Subpart ZZZZ

Emission Limits:Major Sources

o SI RICE < 100 Hpo No numerical emission standards

o 2 Stroke Lean Burn (2SLB) 100 HP 500o CO concentration 225 ppmvd @ 15% O2

o 2 Stroke Lean Burn (2SLB) 500 Hpo Reduction of CO across an oxidation catalyst

58 %o CO concentration 225 ppmvd @ 15% O2

Subpart ZZZZ


o 4 Stroke Lean Burn (4SLB) 100 HP 500CO t ti 47 d @ 15% Oo CO concentration 47 ppmvd @ 15% O2

o 4 Stroke Lean Burn (4SLB) 500 Hpo Reduction of CO across a catalyst 93%o HCHO concentration 14 ppmvd @ 15% O2

Subpart ZZZZ


o 4 Stroke Rich Burn (4SRB) 100 HP 500HCHO t ti 10 3 d @ 15% Oo HCHO concentration 10.3 ppmvd @ 15% O2

o 4 Stroke Rich Burn (4SRB) 500 Hpo Reduction of HCHO across a catalyst 76%o HCHO concentration 350 ppbvd @ 15% O2

Subpart ZZZZ

Emission Limits:Area Sources

o 4 Stroke Lean Burn (4SLB) 500 HpR d ti f CO t l t 93%o Reduction of CO across a catalyst 93%

o CO concentration 47 ppmvd @ 15% O2

o 4 Stroke Rich Burn (4SRB) 500 Hpo Reduction of HCHO across a catalyst 76%o HCHO concentration 2.7 ppmvd @ 15% O2

Subpart ZZZZ

Test Frequency :Major Sources

o SI RICE < 100 Hpo Do not have to conduct any performance test.o Must develop a maintenance plan that specifies how the

management practice will be met and provides to the extent practicable for the maintenance and operation of the engine in a manner consistent with minimizing emissions.

o 2 Stroke Lean Burn (2SLB) 100 HP 500o Must conduct an initial performance test to demonstrate

that they are achieving the required emission standards.o If oxidation catalyst is changed, conduct new emission test.

Subpart ZZZZ

Test Frequency:Major Source

o 2 Stroke Lean Burn (2SLB) 500 Hpo Must conduct an initial performance test to demonstrate

that they are achieving the required emission standards.o Semi-annual testing until demonstrating compliance for

two consecutive tests, then annual testing.o If the results of any subsequent annual performance test

indicate the engine is not in compliance or you deviate from any of your operating limitations, you must resume semiannual performance testing.

o If oxidation catalyst is changed, conduct new emission test.

Subpart ZZZZ

RICE MACT REVISITEDo Oxidation catalyst temperature

monitored continuouslyo Catalyst inlet temperature

450F d 1350Fo 450F and 1350F

o Pressure drop across catalyst measured monthly

o P changes no more than 2 H2O from baseline

Subpart ZZZZ

RICE MACT REVISITEDo Performance tests

o Initial, within 180 days of compliance date

o Semiannual, goes to annual after 2 consecutive compliant tests (comes back if you fail a test)

o Catalyst change performance testo Re-establish P baseline

Subpart ZZZZ

RICE MACT REVISITEDo Performance tests

o Test at 100% 10%o DOCUMENT THE LOAD- define whato DOCUMENT THE LOAD define what

load is and how it was measuredo Measure inlet temperatureo Measure catalyst pressure dropo Must use approved methods

Subpart ZZZZ

RICE MACT REVISITEDo One New Source Subcategory

o N/R 4SLB @ MAJOR HAP SOURCEo 250 hpo 250 hp

o Requires catalytic controlo Requires catalyst inlet temperatureo Requires P monitoringo Requires Performance Testso Requires all reporting & recordkeeping

2010 NESHAP Revisions

NESHAPo National Emission Standards

for Hazardous Air Pollutantso Also known as MACT

o Maximum Achievable Control Technology


Emission Limits:o Proposed limits for existing engines more

stringent that limits for new major source engines subject to RICE MACT

o Startup, shutdown and malfunction (SSM) emission limit:

o Start up must be limited to 30 minuteso EPA states that shutdown emissions should

be the same as normal operation (including catalytic control)

o Limits apply under all conditions and for all fuel types


4SLB Emission Limits:o CO: 47 ppmv @ 15% O2 or 93% Reduction

o Doable for catalyst equipped LB

o Significant debate ongoing about EPA methodology


4SRB Emission Limits:

o Major Source HCHO: 10.3 ppmv for 100 -500 Hp

o Area Source HCHO: 2.7 ppmv OR 76% reduction for >500 Hp

o Significant debate ongoing about EPA methodology


2SLB Emission Limits:

o Major Source CO: 225 ppmv @ 15% O2 for 100 500 Hp

o MUST be met at ALL LOADSA b i t l t ?o Are we buying catalysts?

o Area Source: Management Practices for all regardless of Hp

o Implications unclear for 2012 Review

Green House Gas Emissions

Its here:o NG GHGs: CO2, CH4, N2Oo Engine exhaust CO2 and CH4

account for about 20% of GHG emissions at compressor stations

o Vented and fugitive emissions are ~30-70% of gas transmission emissions

o Mandatory Reporting in Place

Volatile Organic Compound Test Methods

Key difference in sampling is all VOC are sampled hot and wet vs. dry

Non-Methane, Non-Ethane Non Methane, Non Ethane Hydrocarbons

THC-Method 25A VOC-Method 18 (GC/FID) FTIR

VOC Testing

EPA Method 25A-Total Hydrocarbons by FID All THC measured-calibration basis

either methane or propane Mathematical calculation of VOC from

THC-THC in exhaust is reflection of unburned fuel

Methane cutter can give VOC contribution

Insensitive to HCHO

VOC TestingEPA Method 18-Gas Chromatographyo Speciation of hydrocarbons by

GC/FIDo Time intensiveo Time intensiveo QA/QC is vital to regulatory acceptanceo Tedlar bag and off site analyseso On site, direct interface sampling

VOC Testing

EPA Method 320-FTIR Can see most everything at

once except O2onceexcept O2 Requires long path length analytical cell Real time results Can add significantly to cost of testing Calibration technique

Where Does HCHO Come From?

If theres O2 in the exhaust, there can be HCHO

Very little formation in Rich Burn E iEngines

Did we shoot ourselves in the foot with lean charge engines to reduce NOx?

Have a catalyst? Prepare to test!

Formaldehyde (HCHO) Test Methods

CO IS A TREND INDICATOR FOR FORMALDEHYDE

FTIR-real time data, a bit pricey EPA Method 320, ASTM D5348,

Acetylacetone-much less expensive Precision increases with length of test

run EPA re-promulgatged Method 323 with

August 2010 revisions

Formaldehyde (HCHO) Test Methods

Best Choice for a reasonable budget:EPA Method 25A with a Methane Cutter-

VOCEPA Method 323-HCHO

Near Real time ResultsNear Real time ResultsShow trendsShow trendsDONT SAMPLE HCHO FROM A DROP TUBE!DONT SAMPLE HCHO FROM A DROP TUBE!

Other HAPS of Primary Interest

Acrolein- C3H4OTough to sample for, no published method weve

tried completely meets the objectives:i i-inexpensive

-repeatable -straightforward analyses

Test methodology will involve collection in impingersRatio somewhere around 30:1 HCHO to C3H4O

EPA Methods 1 and 1A

Tell you where to sample for velocityBased on the diameter and the configuration

of the stackSpecifies the number of traverse points to

use for velocity measurementsCan specify the measurement location for

emission concentrationsEPA has exempted stacks


AUPSTREAM

2 preferred

0 5 minimum

B

0.5 minimum

DOWNSTREAM

8 preferred

2 minimum

EPA Methods 1 and 1A0.5 1.0 1.5 2.0 2.5

10

20

30

40

50

24 or 25*20

1612

8 or 9*

stack diameter 12-24 in

stack diameter > 24 in

Duct diameters upstream from flow disturbance (Distance A)

M

i

n

i

m

u

m

N

u

m

b

e

r

o

f

T

r

a

v

e

r

s

e

P

o

i

n

t

s

*Larger number forrectangular stacks

P a r t i c u l a t e T raverses

B

ADisturbance

Disturbance

MeasurementSiteNumber of

traverse points is based on

upstream and 2 3 4 5 6 7 8 9 10

0

Duct diameters downstream from flow disturbance (Distance B)

M

0.5 1.0 1.5 2.0 2.5

2 3 4 5 6 7 8 9 100

10

20

30

40

50

1612

8 or 9*

stack diameter 12-24 in

stack diameter > 24 in

Duct diameters downstream from flow disturbance (Distance B)

Duct diameters upstream from flow disturbance (Distance A)

M

i

n

i

m

u

m

N

u

m

b

e

r

o

f

T

r

a

v

e

r

s

e

P

o

i

n

t

s

*Larger number forrectangular stacks

N o n - P a r t i c u l a t e T raverses

B

ADisturbance

Disturbance

MeasurementSite

downstream distance (in

stack diameters)

from the flow disturbance


Number of traverse points

is based on upstream and

24 point layout

downstream distance (in

stack diameters)

from the flow disturbance 12 point layout

Make it Easy on YOURSELF

Too much communication is almost enough

Clearly define your test objectives Involve Gas Control on Day One Prepare a reasonable schedule with time

for things to not go perfectly

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engine emissions stack testing

Documents

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engine emissions stack

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