SCAQMD Rule 1110.2 Compliance Steps and Strategies Judy Yorke and Bipul K. Saraf

1. SCAQMD Rule 1110.2 Compliance Steps and StrategiesJudy Yorke andBipul K. Saraf Yorke Engineering, LLC 31726 Rancho Viejo Rd., Suite 218 San Juan Capistrano, CA 92675 Ph. 949 248-8490 Fax 949 248-8499

2. 1110.2 Compliance Steps and Strategies • Step 1: Understanding the Basics • Step 2: Reviewing Permits and Equipment • Step 3: Strategy Considerations • Step 4: Planning Compliance

3. Step 1: Understanding the Basics • New Emission Requirements* for existing, permitted Natural Gas combustion engines: * Engines that operate <500 hr/yr or use < 1 x 109 Btu/year of fuel are exempt from meeting the lower concentration limits.

4. New Monitoring Requirements • Rule 1110.2 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.

5. New 1110.2 Due Dates *Air to Fuel Ratio Controller ** Non-biogas engines, >750 bhp

6. 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.)

7. 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

8. 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.

9. Examples: Checking Equipment Descriptions

10. Examples: Reviewing the Face Plate Ensure that the Permit matches this description …

11. Examples of Current Permit Limits (Corrected to 15% O2, averaged over 15 minutes)

12. 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

13. To determine current compliance status, review last source test results: Review a Previous Source Test

14. 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 1110.2 for CO and VOC

15. 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

16. 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?

17. 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.

18. Source Testing, Monitoring, CEMS • CEMS • Operate continuously (take samples once every minute) • 15-minute average for compliance • Daily calibration • Annual relative accuracy test

19. 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.).

20. 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

21. 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.

22. I&M Plan, Permits and CEMS Apps. • I&M Plan Submittal: • Form 400-A • Plan Fee $505.35 • Permit Applications • Form 400-A, 400-CEQA • Administrative change fee is $670.50 • CEMS Applications • Form ST-220AP plus fees…

23. 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: $670.50 • 400 bhp engine I&M Plan: $505.35 • CEMS application (w/o RECLAIM or Title V: $3200 - $10,000

24. 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

25. Review permit and rule 1110.2 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 Conclusion