© Copyright, Yorke Engineering, LLC 2008 SCAQMD Rule Compliance Steps and Strategies Judy Yorke and Bipul K. Saraf Yorke Engineering, LLC Rancho Viejo Rd., Suite 218 San Juan Capistrano, CA Ph Fax

© Copyright, Yorke Engineering, LLC Compliance Steps and Strategies Step 1: Understanding the Basics Step 2: Reviewing Permits and Equipment Step 3: Strategy Considerations Step 4: Planning Compliance

© Copyright, Yorke Engineering, LLC 2008 Step 1: Understanding the Basics New Emission Requirements* for existing, permitted Natural Gas combustion engines: PollutantCurrent (ppmvd) Effective 7/1/2010 (ppmvd) Effective 7/1/2011 (ppmvd) bhp≥500bhp<500bhp≥500bhp<500All NOx VOC CO * Engines that operate <500 hr/yr or use < 1 x 10 9 Btu/year of fuel are exempt from meeting the lower concentration limits.

© Copyright, Yorke Engineering, LLC 2008 New Monitoring Requirements Rule requires increased monitoring of emissions: Periodic Monitoring using a portable analyzer and following an Inspection and Maintenance Plan (I&M Plan), or Continuous Emissions Monitoring System (CEMS) required for larger engines or groups of engines.

© Copyright, Yorke Engineering, LLC 2008 New Due Dates Submittal or Implementation RequirementNear Term Due Date Permit Amendment (s) to add AFRC* make/ model, to permit (if needed) April1 st (past due) Quarterly Report (Due 15 days after end of qtr)July 15 th Inspection & Maintenance (I&M) Plan SubmittalAug. 1 st Permit Application for new or modified CEMS**Aug. 1 st Implement I&M PlanDec. 1 st *Air to Fuel Ratio Controller ** Non-biogas engines, >750 bhp

© Copyright, Yorke Engineering, LLC 2008 Breakdown Reporting Report breakdowns with emission exceedances within 1 hour Within 7 calendar days, submit a written report. (Time for submittal may be longer depending upon circumstances.)

© Copyright, Yorke Engineering, LLC 2008 Recordkeeping Daily/Weekly/Monthly/Quarterly Logs Data, logs, test reports etc. shall be maintained for five years. Logs include: Total hours of operation, Type of fuel, Fuel consumption Cumulative hours since last source test

© Copyright, Yorke Engineering, LLC 2008 Step 2: Understanding Your Permits Review your engine permits for: Current emission limits; Air-to-Fuel Ratio Controller (AFRC) Specifications; Equipment Description and BHP Rating; Fuel/Hour Usage limits; Operating conditions; and Periodic monitoring conditions.

© Copyright, Yorke Engineering, LLC 2008 Examples: Checking Equipment Descriptions

© Copyright, Yorke Engineering, LLC 2008 Examples: Reviewing the Face Plate Ensure that the Permit matches this description …

© Copyright, Yorke Engineering, LLC 2008 Examples of Current Permit Limits PollutantExample Engine # 1Example Engine # 2Example Engine # 3 g/bhp-hr ppmv NOx VOC CO (Corrected to 15% O2, averaged over 15 minutes)

© Copyright, Yorke Engineering, LLC 2008 To Convert from g/bhp-hr to ppm For NOx: g/bhp-hr x 70.6 ~ NOx ppmv For CO: g/bhp-hr x 116 ~ CO ppmv For VOC g/bhp-hr x 203 ~ VOC ppmv

© Copyright, Yorke Engineering, LLC 2008 Review a Previous Source Test To determine current compliance status, review last source test results: PollutantExample Engine #1 (ppm) Example Engine #2 (ppm) Example Engine #3 (ppm) NOx VOC CO

© Copyright, Yorke Engineering, LLC 2008 Review Permit Conditions Review your permit conditions to determine permit requirements Rule requirements always apply in addition to permit conditions – they both must be followed RECLAIM facilities comply with Regulation XX for NOx emissions, but must follow Rule for CO and VOC

© Copyright, Yorke Engineering, LLC 2008 Step 3: Strategy Considerations Does your AFRC work well? Has it, or should it, be replaced? There are some newer, better AFRCs currently available that can assist in on-going compliance. Correcting or changing AFRCs requires a permit application

© Copyright, Yorke Engineering, LLC 2008 Need a CEMS? CEMS are required if: >1,000 bhp and operating >2 million bhp-hr per calendar year; or Co-located engines (>500bhp) with a combined rating of >1500 bhp and >16 billion Btus/yr HHV Is your engine and operations below these levels? Can you limit and/or derate your engine(s) to be lower than these levels?

© Copyright, Yorke Engineering, LLC 2008 Source Testing, Monitoring, CEMS Source Testing Every 2 years or 8760 operating hours (up to every 3 years for <2000 total hrs) Conducted by third party Portable Analyzer Monitoring Initially every weekly/150 hours 3 successful checks, reduced to monthly SCAQMD training/certification is required.

© Copyright, Yorke Engineering, LLC 2008 Source Testing, Monitoring, CEMS CEMS Operate continuously (take samples once every minute) 15-minute average for compliance Daily calibration Annual relative accuracy test

© Copyright, Yorke Engineering, LLC 2008 Step 4: Planning Compliance Evaluate each engine for what it needs: Monitoring (CEMS or Periodic w/I&M Plan); Recordkeeping (Logs, breakdowns, etc.); Permitting (corrections, modifications, etc.); and Compliance (control improvements?, etc.).

© Copyright, Yorke Engineering, LLC 2008 CEMS & I&M Plan Development Think through the process carefully and consider your equipment and operations Plan for the future, not just today Work with your advisors and vendors on the best approach for your organization Plan for Compliance – not just periodically, but continuously

© Copyright, Yorke Engineering, LLC 2008 I&M Plan Management Make sure your plan is tailored to your equipment, operation, and organization. Initial plan should be specific enough to meet the requirements, but not overly complicated. Changes to the I&M Plan must be submitted and approved. You should also have an internal guidance document identifying specific responsibilities and schedules.

© Copyright, Yorke Engineering, LLC 2008 I&M Plan, Permits and CEMS Apps. I&M Plan Submittal: Form 400-A Plan Fee $ Permit Applications Form 400-A, 400-CEQA Administrative change fee is $ CEMS Applications Form ST-220AP plus fees…

© Copyright, Yorke Engineering, LLC 2008 I&M Plan and CEMS Application Fees Application fees depend upon engine size and facility type (RECLAIM, Title V, both, or neither) For example: Simple Administrative fee: $ bhp engine I&M Plan: $ CEMS application (w/o RECLAIM or Title V: $ $10,000

© Copyright, Yorke Engineering, LLC 2008 Case Study Issues AFRCs Audible Alarm and Malfunction Indicator Light (MIL) Fuel Meters Temp. and Pressure corrections Logs and recordkeeping Portable Monitoring Temperature measurement across catalyst

© Copyright, Yorke Engineering, LLC 2008 Conclusion Review permit and rule carefully to determine your compliance options File applications and I&M Plan on time Prepare for periodic monitoring If you need a CEMS, get started early