Proposed Amendments to Rule 1110'2 Emissions from Gaseous and LiquidFueled Internal Combustion Engin

1
Proposed Amendments to Rule 1110.2 Emissions
from Gaseous- and Liquid-Fueled Internal
Combustion Engines

• Presented at Southern California Gas Co. Seminar
  Managing Air Quality Compliance and Audits
• March 22, 2006

2
Engine Compliance Problems

• Unannounced emission tests show high
  non-compliance rate
• 127 tests during 2001-2004 old engines subject
  to Rule 1110.2 and new engines subject to more
  stringent BACT
• Engines driving compressors, pumps and electrical
  generators
• Engines by nine engine manufacturers or packagers

3
2001-2004 AQMD Compliance Testing of I.C. Engines
All dry, by volume, and corrected to 15 O2
4
Tested NOx versus Permit Limit for Non-Compliant
Engines
5
Reasons for High Rate of Non-Compliance

• Inadequate periodic monitoring
• Source tests skipped in many cases
• Source tests not representative of normal
  compliance status
• Inadequate air/fuel ratio control systems on
  rich-burn engines
• Many have inadequate self-diagnostics
• Some problems cannot be self-diagnosed (e.g., O2
  sensor drift)

6
CARB 2001 RACT/BARCT Determination

• Inspection and monitoring recommendations are
  more stringent than Rule 1110.2
• Periodic checking and recording of engine and
  emission control system parameters
• Periodic emission checks using portable analyzer
  in addition to periodic source testing

7
Changes Needed in Rule 1110.2

• Lower CEMS thresholds
• CO CEMS in addition to NOx CEMS
• Increased frequency of source tests
• Reform source test procedures
• As-Is testing (no pre-test)
• AQMD-approved protocol
• Test report submitted to AQMD

8
Changes Needed in Rule 1110.2 (Continued)

• Inspection and Maintenance Plan similar to CARB
  RACT/BARCT
• Continuous monitoring and recording of engine and
  emission control system parameters
• Weekly inspections of data
• Portable analyzer emission checks
• Better recordkeeping
• Reporting of non-compliance
• Rule 430 protection if breakdown

9
ICE Working Group Field Program (Rich-Burn
Engines)

• Task 1 Weekly emission checks on six engines to
  assess capabilities of existing AFRCs when
  properly maintained
• Task 2 Assessment, using CEMS monitoring, of
  four modern AFRCs
• Task 3 Evaluation of low-cost analyzers for
  automatic semi-continuous emissions checking
  (partially funded by AQMD)

10
Other Rule 1110.2 Changes Being Considered

• Reduction of VOC and CO emission limits
• Eliminate efficiency correction because it is
  difficult to determine and often ignored
• Require that new engines to be used for
  distributed generation (DG) meet CARB 2007 DG
  emission standards

11
Emission Comparison
12
CARB 2007 DG Standards
CHP credit of 1 MW-hr per 3.4 MMBtu of waste
heat recovered Natural gas or equiv HHV
efficiency 28-70
13
Process and Estimated Schedule

• Public Workshop June 2006
• Public Hearing (AQMD Board) 9/8/06
• Effective Date of Amended Rule 9/8/06
• Some of the new requirements will have later
  compliance deadlines.