Transcript NESHAP and NSPS for Stationary Engines

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5.
Regulation Overview (Jason Krosch)
Component Technology (Alex Georgopoulos)
System Considerations (Bill Hasz)
Dealer Strategy, Success Story (David Welch)
Open Discussion (All)
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Acronyms
RICE – Reciprocating Internal Combustion Engine
SI – Spark Ignited
CI – Compression Ignition
NSPS - New Source Performance Standard
NESHAP – National Emission Standards for Hazardous Air Pollutants
HAP – Hazardous Air Pollutants ~188 regulated compounds
– Polycyclic aromatic hydrocarbons, formaldehyde, acetaldehyde, arsenic, benzene,
beryllium compounds, cadmium compounds
– Represented by a surrogate ... Usually CO!!
Background
Impacts new and existing stationary sites
– New stationary sources
• Engine manufacturers must manufacture engines certified to the EPA new
engine standard
• End-User purchases the appropriate emission level and may have to take other
emission reduction actions and on-site testing based on operational conditions
– Existing stationary sources
• End-Users may be required to take specific emission reduction actions and onsite testing based on operational conditions
Requires specific actions by the engine
manufacturer and the end-user:
Regulation Milestones
EPA proposed
standards for diesel
engines
Mobile non-road diesel standards began 1996 (175 – 750 HP)
• Stationary standards were not developed
• Over time, stationary engines became subject to ad-hoc
state/local regulations and/or permits … California, Texas and
NESCAUM states
Tier 1 mobile nonroad standard takes
affect
1979
1996
2003
2004
2006
2008
2010
Regulation Milestones
EPA proposed
standards for diesel
engines
Sued the EPA to establish federal
emission standards for stationary diesel
engines
Advocacy group
‘Environmental
Defense’ lawsuit
Tier 1 mobile non-road
standard takes affect
1979
1996
2003
2004
2006
2008
2010
Regulation Milestones
EPA proposed
standards for diesel
engines
Lawsuit was
resolved by ‘consent
decree’
Standards to be developed to
address both new and existing
stationary engines
Advocacy group
‘Environmental
Defense’ lawsuit
Tier 1 mobile non-road
standard takes affect
1979
1996
2003
2004
2006
2008
2010
Regulation Milestones
EPA proposed
standards for diesel
engines
Lawsuit was resolved
by ‘consent decree’
Standards for new and existing
engines > 500 HP in major sources
Advocacy group
‘Environmental
Defense’ lawsuit
Tier 1 mobile non-road
standard takes affect
1979
Promulgated
Standards for
> 500 HP
1996
2003
2004
2006
2008
2010
Regulation Milestones
EPA proposed
standards for diesel
engines
Lawsuit was resolved
by ‘consent decree’
Advocacy group
‘Environmental
Defense’ lawsuit
Tier 1 mobile non-road
standard takes affect
1979
Tier 1 capable in 2006:
• Apr 2006 - non-fire pumps
• Jul 2006 - fire pumps
Promulgated
certification standards
‘NSPS’ for NEW
stationary DIESEL
engines
Model year 2007:
Meet the same emission
standard as non-road diesel
engines
Promulgated
Standards for
> 500 HP
1996
2003
2004
2006
2008
2010
Regulation Milestones
EPA proposed
standards for diesel
engines
Lawsuit was resolved
by ‘consent decree’
Advocacy group
‘Environmental
Defense’ lawsuit
Tier 1 mobile non-road
standard takes affect
1979
Promulgated NSPS
certification standards
for NEW SPARK IGNITED
engines
Promulgated
certification standards
‘NSPS’ for new
stationary diesel
engines
Promulgated
Standards for
> 500 HP
1996
2003
2004
2006
2008
2010
Regulation Milestones
EPA proposed
standards for diesel
engines
Lawsuit was resolved
by ‘consent decree’
Promulgated certification
standards for new spark
ignited (SI) engines
2003
Advocacy group
‘Environmental
Defense’ lawsuit
Tier 1 mobile non-road
standard takes affect
1979
Promulgated certification
standards ‘NSPS’ for
new stationary diesel
engines
Promulgated standards for
HAPs to address
EXISTING engines
Promulgated
Standards for
> 500 HP
1996
February: CI
August: SI
2004
2006
2008
2010
Source Variables
New/reconstructed vs. existing stationary engine
SI vs. CI
Major Source vs. Area Source
– Major Source - emits or has potential to emit any single HAP at a rate of >10
tons/year or any combination of HAPs of >25 tons/year
• Considers more than just the engine … Can be calculated via tables. Consult
with an environmental engineer
– Area Source – a source that is not a major source
»
JD EW plant is an area source
Emergency vs. Non-Emergency
Power Rating
»
»
»
»
<100 HP
100 HP- 299 HP
300 – 499 HP
> 500 HP
Emission Standards
Area Sources
Non-Emergency
HP
< 300
300 - 500
>500
Emergency
CI
SI 2SLB
SI 4SLB
SI 4SRB
SI LFG/DG
work
practice
standards
49 ppm CO
or 70% CO
reduction
23 ppm CO
work
practice
standards
work
practice
standards
work
practice
standards
work
practice
standards
47 ppm CO
2.7 ppm CH2 0
or 70% CO
or 70% CO
or 76% CH2 0
reduction
reduction
reduction
work
practice
standards
Emission Standards
Major Sources
Non-Emergency
HP
CI
SI 2SLB
SI 4SLB
Emergency
SI 4SRB
SI LFG/DG
workpractice standards
<100
work
practice
100 - <300
300 - 500
>500
230 ppm CO
49 ppm CO
or 70% CO
reduction
23 ppm CO
or 70% CO
reduction
225 ppm CO
47 ppm CO
10.3 ppm
CH2 O
Covered by 2004 Rule
177 ppm
CO
standards
Aristo Intelligent Catalyst Technology
Overview
• Catalyst design criteria
• Catalyst company focus
– Catalyst characteristics and challenges
– Material challenges
• Dealer/Distributor
– Actions to consider
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•
Understand regulations and allowable emissions
•
Identify engine-out parameters
•
Select catalyst size
•
Select support material and cell density
•
Select catalyst formulation
•
Review with customer
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Understand Regulations
Confirm the max allowable emissions – check references or calculators
Design catalyst with engineering tolerance and DF
Identify exhaust parameters
Temperature, Pollutants, mass flow, acoustics – spec is for full load
Size the catalyst
Ideally base upon Space velocity
Often constrained by packaging requirements
Backpressure limitations
distance from manifold
Enclosure dimensions
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Design catalyst formulation
Select washcoat composition
NSCR or Oxidation
high or low temperature
high or low SV
fuel poisons
durability
Select PGM
Low temperature light off needed?
Poison resistance needed?
NSCR or Oxidation needed?
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Standard solutions are typically available, but iterations may be
needed for custom solutions
Overall package often require custom design solutions because
of unique space limitations
Confirm Customer agrees with design criteria – Can standard
solutions meet the requirements?
Supply Customer with quotation
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Review with Customer
Meets cost , emissions, space, and backpressure targets?
Meets warranty requirements, aligned with regulations?
Does the customer need any solutions to assist in minimizing or
eliminating bypass or other specific issues
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Catalyst Company Focus
• Maximize performance while meeting bp goals
– Highest space velocity while meeting requirements (maximize
flowrate, minimize volume)
– Formulation that lights off at low temperature
R-N tests are at full load
• Minimize material usage/cost
– Advanced coating technologies
– Validate new catalyst technologies/formulations that are
poison resistant
• Manage raw materials
– Supply disruptions and cost increases
• Manage capacity and lead times
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Impact on Precious Metal Prices
• EPA est. 200,000+/- Diesel engines for both Major and Area sources
needing catalysts. PGM>150,000 T. Oz. Pt needed out of current
supply of 6.1 million T. Oz.
• PGM prices tied closely to auto production with replacement cycle
getting closer. RICE NESHAP demand likely to make more impact
due to current tight supply demand balance
• Volatility expected to continue because of Russian stockpile
depletion, Norilsk and other mine higher grade pgm depletion, RSA
labor/political/electricity challenges
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Material Costs
• China supplies 95% of Rare Earth Oxides, now
with export quotas
– Prices up 60% in the past year
2010
2011(proj)
2012(est)
2013 (est)
CeO2 supply
49.0
49.7
52.1
67.9
demand
48.2
50.3
52.4
54.6
La2O3 supply 35.2
35.7
37.1
45.6
Demand 33.8
35.3
36.9
38.4
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Dealer/Distributor: Actions to consider
• Utilize resources that are available
Component supplier guidelines/calculations , on-line calculators
• Decide if you will select component suppliers (inhouse integration) or full service supplier
– Catalyst, housing, CPMD, piping/structural, crankcase
emission filtration, testing, and service
– Prepare paperwork/structure/maintenance programs
and reports
• Start early – key dates
CI and Dual fuel- 5/3/2013
SI – 10/19/2013
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RICE NESHAP System
Considerations
• Type of emission control technology
• Engine backpressure requirements
• Placement of emission control device inside or
outside building/enclosure
• Exhaust piping and supporting structure for
emission control device
• Installation
• Continuous monitoring of catalyst temperature
and pressure drop
• Catalyst service
• Compliance testing
System Considerations
• Engine backpressure requirements
• What is current backpressure?
• Will engine withstand an additional 5-10” H20?
• If not, consider an integrated silencer design
• Placement of emission control device
• Is there space in current exhaust system?
• Will exhaust gas reach 500⁰F at catalyst inlet?
• Will a packed silencer be upstream of the
catalyst? (Fibers)
• Are there readily accessible service points?
• If installed outside, will winter temperatures
affect performance of the catalyst?
System Considerations
• Exhaust piping and support structure
for emission control device
• Can current support structure
handle emission control device’s
weight?
• May need to budget for
additional steel supports for the
catalyst
• Minimize additional 45° and
90°elbows for exhaust piping
• Straight through configuration is
ideal
System Considerations
• Installation
• Can your technicians handle? Or
will you want to outsource?
• Will you be able to “splice” into
current exhaust piping?
• When to schedule installation?
• Annual maintenance?
• In conjunction with a major
engine overhaul?
System Considerations
• Monitoring of catalyst
temperature and pressure
drop
• CPMS required for 500 HP and
above
• Temperature must be logged
continuously
• Pressure drop must be logged
monthly
System Considerations
• Catalyst service
• Convenient and safe location of
access doors
• Special lifting equipment required?
• Replace or remove and clean?
• Compliance testing
• Schedule after system is installed
• Requires testing in compliance to ASTM
D6522-00 (contract with a stack testing
service)
RICE NESHAP monitoring and testing
requirements
• Both major and area sources require that
– catalyst inlet temperature is monitored and
maintained between 450 – 1350 F
– differential pressure is monitored and maintained
within limits (less than +/-2 “ WC from initial test)
• Major sources are required to perform semiannual performance tests
• Area sources are required to be tested every
8760 hours/3 yrs
– 5 yrs for limited use applications
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Budgetary Prices for DOC’s
Serviceable DOC
Critical Grade
Catalyst Silencer
Exhaust System with
Critical Grade Catalyst
Silencer
$3600
$5100
$9000
$13,500
1000 kW
$5000
$7300
$13,700
$21,000
1500 kW
$7100
$9800
$16,500
$25,000
2000 kW
$7700
$12,000
$21,500
$33,000
Non-Serviceable
DOC
500 kW
Gen Set Size
•
•
•
•
Monitor system is $3000
Compliance testing runs $3000-$5000
Crankcase emission filter may also be needed
Installation costs can equal the equipment cost
Items to Consider in Selecting a
RICE NESHAP System Supplier
 Installed Base – High & Medium Speed engine
applications
 Installed Base - Catalytic Silencers
 Acoustic Performance – esp. Low Frequencies
 System Backpressure
 Structural Design - Wind and Seismic Loading
 Catalyst Supply
 Catalyst Serviceability
 Catalyst Sealing
 System Integration Expertise
 Supplier’s Product and Market Focus
RICE NESHAP:
Dealer Strategy & Success
David Walch
General Manager Power Generation
INTERSTATE PowerSystems
Line 1
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The Interstate Strategy and Success
Centralized Resources
• Established engineering / sales staff
• Create partnerships with vendors suppliers
• Educate staff who are in contact with your
customer base, “yes”!
• Identify and acquaint you and your company
with the authorities, i.e. District 5 EPA, State
MPCA, etc…
• Gather technical data on known population
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Interstate Strategy…
• A HUGE number of people are in utility
programs
• Many customers are just looking for budgetary
prices to determine if it’s feasible to stay in a
curtailment program or to buy new
• Suppliers promoting big $$$ potential
• We need to be conscious of our time spent
against return, centralize resources
Interstate Strategy…
• Many of the smaller generator sets in
curtailment programs will simply “opt out” if
NESHAP costs are too high, NEW SALES
• Designing spreadsheets for customers to
determine viability quickly, and staff to collect
data
• Focus on customers with larger equipment not
as adversely affected by NESHAP costs
Moving forward….
• EPA has language in the regulations for
delegation of authority (for enforcement) to state
Pollution Control Agencies
• Develop a relationship with Air Quality group at
the state level – a great collaborative resource
• Find stack testing agencies in your area capable of
assisting with ongoing testing requirements
• Educate Mechanical partner(s) in your AOR, offer
turn key solutions
Performance Testing
Has to be done by a stack testing
organization to EPA prescribed
“methods”
Negotiate rates and terms ahead of
time
Reporting and Recordkeeping
Will be an ongoing owner/operator responsibility
Education and value, aside from conforming,
creates a deeper knowledge and interaction
Is offered as part of on going maintenance
One IPS Example….
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• Changing Existing Stack to a Ground Access
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Measurable Success
• Opportunity to touch your customers as well as
those you compete with, builds deeper
relations
• Be a Solution provider not a peddler
• Residual Services
• Turn Key Installations, offer greater scope of
supply at higher than normal margins
• By product of being prepared? O/H and Sales
of NEW Units!
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