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Emission Limits for Peak-Shaving Generators May Need Upgrades to Qualify for OPA Program
March, 2008
By Philip Girard
The Ontario Ministry of the Environment (MOE) has posted for comment a Policy Proposal Notice that provides emission limits for power generator sets that are used in non-emergency situations such as for peak shaving or in the Ontario Power Authority's (OPA) Demand Response (DR) Program. The limits will apply to internal combustion engines running on diesel, bio-diesel, natural gas or dual fuel (natural gas/diesel) systems.
According to the MOE, the purpose of the emission limits is to ensure that emissions from new power sources that will replace or offset some of Ontario's coal-fired generation capacity will be as clean as, or cleaner, than emissions generated from natural gas combustion turbines.
Unlike the off-property, point-of-impingement limits defined in Ontario Regulation 419/05 that governs the Certificate of Approvals (air permits) these limits are end-of-pipe, meaning in-stack concentrations or mass emission rates per unit of power produced per unit of time. The proposed limits would apply during steady state operating conditions and not during start-up or shutdown. In addition, these limits would not apply to facilities or communities that are essentially off-the-grid and rely on diesel generation as their primary source of power.
Proposed Limit (kilogram/megawatt-hour)
Emission 2007-2001 2011 Onward
Nitrogen Oxides (NOx) 1 0.40
Particulate Matter (PM) 0.2 0.02
Non-Methane Hydrocarbons (NMHC) 1.3 0.19
Carbon Monoxide (CO) 3.5 3.5
Sulphur Dioxide (SO2) 15 ppm 15 ppm
EMERGENCY RESPONSE HELD TO CLEAN TECHNOLOGY STANDARDS
The Independent Electricity System Operator (IESO) balances electricity supply and demand in Ontario and directs transmission. When an energy emergency is foreseen the Emergency Load Reduction Program (ELRP) is initiated and participants in the program are contracted so they can offer to turn down their consumption or increase their power generation supply to the grid. In both instances there must be a 1-megawatt (MW) commitment. Participants in the ELRP program will be required to meet the ELRP limits and the standards of O.Reg. 419. This includes a NOx emission limit of three kilograms per megawatt-hour.
The MOE has outlined three possible implementation options: the Certificate of Approval (CofA) air permitting process; a regulation under the Environmental Protection Act; or a new MOE guideline. As with all equipment that discharges contamination, a MOE Certificate of Approval (Air & Noise) would be required before the power generator can be operated (emergency and non-emergency equipment.)
To verify that the equipment can meet the proposed limits, the MOE will probably require performance guarantees from equipment suppliers or validated source testing following MOE protocol. Thereafter, the MOE might require periodic validated source testing to demonstrate ongoing compliance.
The provincial government is reacting to Ontario Medical Association (OMA) studies on the detrimental health, financial and societal impact of air pollution and the province's commitment to phase out or diminish coals power generation with cleaner technologies. The OMA's 2005 report entitled The Illness Cost of Air Pollution attributes more than 29 million minor illnesses, 59,000 emergency room visits, 16,000 hospital admissions and more than 5,800 premature deaths to smog and air pollution.
CHALLENGING TARGET, COSTLY VERIFICATION REQUIREMENT
The proposed emission limit could be challenging. An on-line search of several equipment suppliers reveals that quite a few models do not comply with the 2011 emission limits. However, most suppliers claim to have low-emission technology that is compliant with US EPA Tier 3 (limits proposed for 2007-2010) and suggest they can meet the Tier 4 limits (proposed requirements for 2011 and beyond) with some back end technology additions such as selective catalytic reductions. New installations will likely benefit from emerging technology, but the cost of converting existing systems will likely rise.
An MOE Certificate of Approval will continue to be required to operate power generation equipment, and documenting compliance with these new limits should not impact the cost of preparing application. The MOE has not disclosed if there will be any charges for its CofA review fees.
The verification of compliance aspect of this proposal is not insignificant. Under this proposal, periodic testing to strict standard would be required, but the frequency of testing hasn't been specified. Testing for combustion gases should not be discounted as simple, but it is considerably simpler than isokinetic sampling for particulate matter.
Testing costs could easily exceed $10,000 when accounting for the number of technicians that will be required to conduct the tests, the duration of the tests, and the complexity of the setup. A more cost-effective alternative might be annual or biennial testing for the combustion gases and particulate matter in a turnabout sequence.
Philip Girard is Vice President, Air & Noise, with Pinchin Environmental. The preceding is reprinted from the Pinchin Environmental Newsletter. For more information, see the web site at www.pinchin.com.
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