Q&A and a Deeper Dive into 40CFR60 TTTT & PS-11

© 2019 CEMTEK KVB-Enertec

Q&A and a Deeper Dive into 40CFR60 TTTT & PS-11

By John Downs


Agenda

TTTT

PS-11

Summary & Question

Overview of Each Topic

Presenter

Presentation Notes

2 minutes on me, B&W and KVB-Enertec


Quad T or 4T

• New Source Performance Standard affecting EGUs “40 CFR 60, Subpart TTTT – Standards of Performance

for Greenhouse Gas Emissions for Electric Generating Units”• Steam Generating unit, IGCC, or Stationary

Combustion Turbine– Commence Construction After January 8, 2014 or– Commences Mod. Or Reconstruction > June18,

2014


Quad T Applicability

• APPLICABLE (cont.): – Unit has a base load rating > 250 mmBtu/hr AND– Server generator(s) capable of selling >25 MW of electricity

to power distribution system

• NOT APPLICABLE if:– Permit* limits output to 1/3 potential or 219,000 MWH

which ever is greater, or– Capable of combusting ≥50% non-fossil fuel and subject to

permit* limiting ACF to ≤10% fossil fuel, or

* Federally enforceable


4T Not Applicable (cont.)

• NOT APPLICABLE (cont.):– Combined Heat & Power units with permit* limit to no more than

219,000 MWh or product of design efficiency x potential electric output, whichever is greater; or

– EGU serves generator with effective capacity of 25 MWh or less ; or– MSW’s subject to 40 CFR 60 Subpart Eb; or– CISWI units subject to 40 CFR 60 Subpart CCCC; or– Steam Generator/IGCC modified where hr. CO2 increase ≤10%; or– EGU is CT not capable of combusting Natural Gas; or– One of the specific facility’s located in Georgia or Kansas

* Federally enforceable


4T Limits (Table 1)Affected EGU CO2 Emission standard

Newly constructed steam generating unit or integrated gasification combined cycle (IGCC).

640 kg CO2/MWh of gross energy output (1,400 lb CO2/MWh)

Reconstructed steam generating unit or IGCC that has base load rating of 2,100 GJ/h (2,000 MMBtu/h) or less

910 kg of CO2 per MWh of gross energy output (2,000 lb CO2/MWh)

Reconstructed steam generating unit or IGCC that has a base load rating greater than 2,100 GJ/h (2,000 MMBtu/h).

820 kg of CO2 per MWh of gross energy output (1,800 lb CO2/MWh).

Modified steam generating unit or IGCC A unit-specific emission limit determined by the unit’s best historical annual CO2 emission rate (from 2002 to the date of the modification); The emission limit will be no lower than: - 1,800 lb CO2/MWh-gross for units with a base load rating greater than 2,000 MMBtu/h; or - 2,000 lb CO2/MWh-gross for units with a base load rating of 2,000 MMBtu/h or less


4T Limits (Table 2)Affected EGU CO2 Emission standard

CT suppling > its design efficiency or 50 percent, whichever is less, times its potential electric output as net-electric sales on both a 12-operating month and a 3-year rolling average basis and combusts more than 90% natural gas on a heat input basis on a 12-operating month rolling average basis.

450 kg of CO2 per MWh of gross energy output (1,000 lb CO2/MWh);or470 kilograms (kg) of CO2 per megawatt-hour (MWh) of net energyoutput (1,030 lb/MWh).

CT suppling its design efficiency or 50 percent, whichever is less, times its potential electric output or less as net-electric sales on either a 12-operating month or a 3-year rolling average basis and combusts more than 90% natural gas on a heat input basis on a 12-operating month rolling average basis

50 kg CO2 per gigajoule (GJ) of heat input (120 lb CO2/MMBtu).

CT that combusts 90% or less natural gas on a heat input basis on a 12-operating-month rolling average basis.

50 kg CO2/GJ of heat input (120 lb/MMBtu) to 69 kg CO2/GJ of heat input (160 lb/MMBtu) as determined by the procedures in § 60.5525


• Use only valid operating hours, no data substitution or bias adjusted values.

• Limits are based on 12-OPERATING month rolling average.

• Determine initial 12-operating month average.– Once that is determined, reporting is required

How to Determine Units CO2 Emissions for 4T


• Calculate the total CO2 mass emissions by summing valid hourly CO2 mass emissions values for all valid operating hour in compliance period.

• CO2 Mass emission is the hourly CO2 rate in tons/hr times the hour operating fraction.e.g.: 24.2 tons CO2/hr * 0.6 hr. = 14.52 tons CO2

(.6 hour = 36 minutes operating time in clock hour)

Determining Emissions / 4T


• 60.5535 allows for use of CO2 CEMS or App. D/G methods to be followed.

• Using F-11, as noted, multiply the CO2 tons/hr result by the hourly operating time to give CO2 mass (tons).

• Sites subject to electric output standard take the CO2 mass and convert to Kilograms (Kg) – Multiply the CO2 Tons by 909.1 and round to nearest kg.– Hourly CO2 kg values are not reported in ECMPS, the underlying CO2 tons/hr

values are for downstream compliance verification.



• Output based sites without CEMS are required to implement 40CFR75 App. D methods to determine HI on hourly basis. – requires fuel flow and periodic* GCV determination.

• Use equation G-4 to determine hourly CO2 tons/hr rates. Follow same process as above to convert to kg except round off to 2 significant figures.

• If subject to electric output based standard, must install, calibrate and maintain watt meters. CHP units must also determine and record thermal output;

– Steam applications must determine and record hourly steam flow rate, temperature, and pressure

• If unit subject to heat input (HI) standard, must determine total HI using either:– Appendix D to Part 75; or– Procedures under 60.107a(d); or– Tier 3 methodology from 40 CFR 98.33(a)(3) and use the appropriate EF from Table C-1


* monthly



• Once Hourly CO2 is converted to a mass value, next step is to determine initial compliance value.– Use only valid data– Use only valid hourly gross or net energy output values are obtained– Exclude hours where:

• Substituted data following Part 75 methods are applied• Hours where full-scale range of analyzer is exceeded• Total or net MW hours or Heat Input is unavailable

– At least 95% of operating hourly data must be valid– Calculate total CO2 mass by summing all valid hourly CO values in

the compliance period.



• Determine hourly gross MW or hourly total Heat Input by summing the total MWs or the total HI.– Hours where MW (for output based compliance) < auxiliary loads, net output is

considered zero for calculation.

• Output* based: 𝐶𝐶𝐶𝐶𝐶 ⁄𝑘𝑘𝑘𝑘 𝑀𝑀𝑀𝑀𝑀 = ⁄𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡 𝐶𝐶𝐶𝐶𝐶 (𝑘𝑘𝑘𝑘) 𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡 𝑀𝑀𝑀𝑀• Heat-Input based: 𝐶𝐶𝐶𝐶𝐶 ⁄𝑘𝑘𝑘𝑘 𝐺𝐺𝐺𝐺 = ⁄𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡 𝐶𝐶𝐶𝐶𝐶 (𝑘𝑘𝑘𝑘) 𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡 𝐻𝐻𝐻𝐻 (𝐺𝐺𝐺𝐺)

• Result is your initial compliance demonstration value• New value is determined at end of next operating month

* Net or Gross, MW, Steam, or thermal energy, as appropriate


• Initial compliance value must be reported.• Quad T states that once ECMPS reporting is

developed, sites must begin to use ECMPS for reporting.– EPA announced in May 2018 that ECMPS was ready to

accept data.

Quad T / 4T Reporting


• EPA released new emissions XSD schema with 2nd Q 2018 ECMPS release

• Site must notify CAMD if your site is subject to 4T• ECMPS is not performing any data validation checks

on submissions• Data schema is not overly complex and is reported

under main parent Emissions data element



• Required to be incorporated into your site monitoring plan per 40 CFR 75.53(g) and (h).– Portion of Monplan to be reported electronically in

ECMPS (new program code NSPS4T)

• Data required to be reported at all times, including during periods of Startup and Shutdown (SUSD)

• Non-collection considered a violation



• Initial quarterly report after 12th month includes– Initial compliance value – Plus each subsequent compliance value (i.e. next 12

operating month rolling value)– CO2 emissions standard code, i.e. code that let’s EPA

know which emissions standard in Tables 1 or 2 that unit is subject

• The value of the standard is reported only if you are subject to a unit-specific standard



– An indicator value if a compliance period ended in the quarter. A “1” for yes or a “0” value for no.

• A 0 would be reported only if a non-operating quarter for unit• If 0 is reported, site needs to include statement letting EPA

know that no compliance period ended in quarter. Brief and generic statement is acceptable.

– Compliance Period End Data, including Average CO2 emissions rate, unit of measure code, percent valid hours, and indicator if the standard was violated with

comment.



– In 4th quarter EM file only, report total amount of output sold; with code indicating total sold is either the Gross or the Net; and

– The Annual Potential electric output of the EGU. • Note that this it is not defined if unit complies with Heat-input

standard if this is still required



• CEMTEK KVB-Enertec has had email exchanges and phone discussions with EPA in effort to define exactly what needs to be reported

• This discussion is still on-going• Initial EPA response was to manually add data to

XML emissions file. ???



• If unit is subject to 4T but not Acid Rain Program, must begin recording and reporting CO2 emissions using CEMS or Appendix G methodology.

• 60.5520(d)(1) - Stationary combustion turbines permitted to burn fuels with a consistent chemical composition (i.e., uniform fuels) resulting in a consistent emission rate of 160 lb CO2/MMBtu or less are not subject to any monitoring or reporting requirements under this subpart.– Stationary combustion turbines qualifying under this paragraph are only

required to maintain purchase records for permitted fuels.

Quad T Applicability II

Presenter

Presentation Notes

Including, but not limited to, natural gas, methane, butane, butylene, ethane, ethylene, propane, naphtha, propylene, jet fuel kerosene, No. 1 fuel oil, No. 2 fuel oil, and biodiesel


• In order to fully support software changes are required. Both core software version upgrades as well as potential configuration changes will be required.

• If your EGU is not subject to 40 CFR 60, part TTTT, no changes are required and future releases will not affect your DAHS.

• EPA still has open questions from us that need to be answered before we can implement.

• Please contact me or software support if you have a unit that is subject to Quad T by email:

– [email protected] or [email protected]

DAHS Changes

Presenter

Presentation Notes

Including, but not limited to, natural gas, methane, butane, butylene, ethane, ethylene, propane, naphtha, propylene, jet fuel kerosene, No. 1 fuel oil, No. 2 fuel oil, and biodiesel

mailto:[email protected]



Agenda

PS-11

TTTT

KKKK

Summary & Question

Overview of Each Topic

Presenter

Presentation Notes

2 minutes on me, B&W and KVB-Enertec


Performance Spec 11

• Initial Certification requirements spelled out here

• Requires site-specific correlation of the PM CEMS response against reference method measurements– Minimum 15 runs– 3 Particulate load bins: minimum 5 runs at each

PM load; one bin can be zero


Correlation Testing

• Why do the correlation?– Because different measurement techniques– Different PM characteristics stack by stack– A single ‘correlation’ is or may not be applicable

stack to stack– Think particulate size differences– Wet stack versus dry stack…


Types of Correlations

• PS-11 sets 5-types of correlation models• All MUST be evaluated• You choose the best fit:

• Linear

• Polynomial

• Logarithmic

• Exponential

• Power


Other Initial Certification Tests

• Operate the PM CEMS for period of time prior to starting certification…– Time Period not defined other than “stated” period –

i.e. you need to state this in your test plan

– Operate long enough to not trigger any unscheduled maintenance, repairs, or adjustments

• 7-day Drift – Upscale and Zero levels• Upscale = 50 to 100% of instrument response range• Zero = 0 to 20% of instrument response range


To Emit Low or Not

• Low emitting source in PS-11 is not same as what it sounds like

• PS-11 Section 3.16 defines a low emitting source as one that operated at no more than 50 percent of the emission limit during the most recent performance test, and, based on the PM CEMS correlation, the daily average emissions for the source, measured in the units of the applicable emission limit, have not exceeded 50 percent of the emission limit for any day since the most recent performance test. – Does Performance Test for NSPS compliance or PM CEMS Performance?


Implications

• You must redo Correlation Testing IF:→ 24 consecutive hourly average PM CEMS responses > 125 percent of the

highest PM CEMS response used for the correlation curve OR are greater than the PM CEMS response that corresponds to 50 percent of the emission limit

OR→ Cumulative hourly average PM CEMS responses generated are > 125

percent of the highest PM CEMS response used for the correlation curve or are > the PM CEMS response that corresponds to 50 percent of the emission limit, whichever is greater, for more than 5 percent of your PM CEMS operating hours for the previous 30-day period.


Not a Low Emitting Source

• You must Retest IF:→Generate 24 consecutive hourly average PM CEMS responses >

125 percent of the highest PM CEMS response used for the correlation curve,

OR→Cumulative hourly average PM CEMS responses generated are >

125 percent of the highest PM CEMS response used for the correlation curve for more than 5 percent of your PM CEMS operating hours for the previous 30-day period.


After Certification

• On going QA/QC checks spelled out in 40 CFR 60 App. F, Procedure 2– Requires:

• Daily Drift Checks Zero and Upscale• Instrument is out of control (OOC) if zero or upscale drift

exceeds:√ 4 percent for 5 consecutive days√ 8 percent for any one day


After Certification - Daily

• System Optics Check: Light-scattering, Extinction type, or other optical PM CEMS:

• Check system optics to ensure proper operation• No OOC specified.

• Sample Volume Check: Extractive PM CEMS that incorporate measured sample volume in output→ OOC if:

√ 10 percent for 5 consecutive days OR√ 20 percent on single day


After Certification - Daily

• System Optics Check: - Optical-type PM CEMS;– Light-scattering, Extinction type, or Other :

• Check system optics to ensure proper operation• No OOC specified.

• Sample Volume Check: Extractive PM CEMS that incorporate measured sample volume in output→ OOC if:

√ 10 percent for 5 consecutive days OR√ 20 percent on single day


Quarterly

• Absolute Correlation Audit (ACA): - Similar to linearity

Accuracy must be within ±10 percent of audit response or ±7.5 percent of applicable standard

Audit Point Audit Range1 0 to 20 percent of measurement range2 40 to 60 percent of measurement range3 70 to 100 percent of measurement range


Quarterly

• Extractive systems only Sample Volume Audit (SVA)

• Use calibrated device Compare to PM CEMS measured volume– Batch systems sample at least 3 cycles– Continuous systems sample at least three 20-minute periods

Accuracy must be within ±5 percent of measured volume


Questions?Pennsylvania OfficeCEMTEK KVB-Enertec2849 Sterling DriveHatfield, PA 19440Ph.: 215-996-9200Fax: 330-860-8982

California OfficeCEMTEK KVB- Enertec3041 S. Orange Ave.Santa Ana, CA 92707-4247Ph.: 714-437-7100Fax: 714-437-7177

NetDAHS software service help line: 1-800-582-1670NetDAHS Software service email: [email protected]: www.cemteks.com www.netdahs.com


http://www.cemteks.com/

http://www.netdahs.com/

Documents

Q&A and a Deeper Dive into 40CFR60 TTTT & PS-11