1. Emergency Engine Emissions Standards
Kathi Harris, HOLT CAT Emissions Business Manager - June 13, 2012

2. 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.

3. Today’s Agenda Is this an Actual Emergency? Emissions Standards
Now What?

4. Emergency? TEXAS FEDERAL
Unforeseen power or gas service failure, flood, fire, or life-threatening situation
YES
Emergency runtime limits (876 hrs per TX Permit) NO
100 hours per year Maint. & Testing allowed
Severe Storm Avoidance at Airports or NASA
Other Storm Avoidance up to 30 minutes advance
NEW! Demand Response – up to 100 hrs/yr incl. M&T
NEW! Peak Shaving - up to 50 hrs/yr incl. M&T
NO?

5. EPA Emergency Engine Regs – Current vs. Proposed
Type
Current
Proposed
Demand Response
15 hours per year
100 hours per year
NESHAP only
NSPS and NESHAP will allow
Peak Shaving
Not allowed
Up to 50 hours per year

6. 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 or Case-By-Case Permit
Fed Regs Aligned (NESHAP & NSPS)

7. 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

8. Texas Requirements Permits By Rule (PBR)
(Portable & Emergency Engines & Turbines)
(Maintenance, Startup & Shutdown)
(Stationary Engines & Turbines; Peak Shaving)
Case-by-case (Peak Shaving)
PBR = 876 hours emergency use
Paperwork
– review, keep copies, records of compliance, no fee or registration.
– same as above if MSS project less than 180 days.

9. 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

10. Introduced much later than non-road regulations
In 2006 EPA began to regulate engines in stationary applications
Known as New Source Performance Standards (NSPS)
No “flexibility program” for OEM’s in NSPS
From April 2006 Tier 1 standards were mandated
No factory certification required
From Jan 2007 NSPS harmonized regulatory limits & timing with EPA’s non-road regulations
engines ≤3000 bhp & <10 litre / cylinder must be certified to the non-road Tier limits for their specific model year & power output
engines >3000 bhp but <10 litre / cylinder must be certified to non-road Tier 1 limits for their specific maximum engine power
engines ≥10 litre / cylinder & <30 litre / cylinder must be certified to Marine Tier 2 limits for their specific displacement & maximum engine power
2010+
Alignment with non-road regulations continues for non-emergency engines

11. Federal Requirements Diesel Natural Gas
EPA Standards for Certified Emergency Diesel Gensets
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

12. 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.

13. 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.

14. Close, but no cigar! EPA taking public comments until July 23, 2012
Webinars – 6/20, 6/25, 6/28

15. Contacts Your HOLT CAT Salesperson HOLT CAT IRVING 972-721-2000
TCEQ Air Permits Division