New MOE Policy Proposal

Newsletter ID: Pen #32, 2008.
Services: Environmental Air & Noise

Emission Limits for Internal Combustion Engines used for Non-Emergency Power Generation

Note: MOE sought public input until March 1, 2008.

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 Authorities (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.

The proposed limits are shown below:

Unlike the off-property point-of-impingement limits defined in Ontario Regulation 419/05 which governs 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 time. The proposed limits would apply during steady state operating conditions and not during start-up or shut-down. 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

Independent Electricity System Operator Emergency Load Reduction Program

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 contacted 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 not be required to meet the limits stated above but will be required to meet the ELRP limits and the standards of O. Reg. 419.

Implementation Considerations

The MOE is seeking pubic input (until March 1, 2008) on implementation options. Implementation through the Certificate of Approval (CofA) air permitting process, or a regulation under the Environmental Protection Act (EPA), or the development of an MOE guideline are being considered.

As with all equipment that discharges contaminants to the natural environment, a MOE Certificate of Approval (CofA, 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 on-going compliance.

Authors Comments

The provincial government is reacting to the Ontario Medical Association (OMA) studies on the detrimental health, financial and societal impact of air pollution and the provinces commitment to phase out or diminish coal power generation with cleaner technologies. The OMA’s 2005 report titled “The Illness Cost of Air Pollution” attributes more than 29 million minor illnesses, 59000 emergency room visits, 16000 hospital admissions and more than 5,800 premature deaths to smog and air pollution.

The proposed emission limits could be challenging. We conducted an on-line search of several equipment suppliers and found that quite a few generator models do not comply with the 2011 emission limits. However, most suppliers claim to have low-emission technology that is US EPA Tier 3 compliant and believe they can meet the Tier 4 limits with some back-end technology additions such as selective catalytic reduction. Clearly, emerging technology will benefit new installations but the cost of converting existing systems likely just went up.

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 costs of preparing applications. The MOE has not disclosed if there will be any changes to their CofA review fees.

The verification of compliance aspect of this proposal is not insignificant. Under this proposal, periodic testing to strict standards would be required, but the frequency of testing hasn’t been specified. While testing for combustion gases should not be discounted as being simple, it is in the author’s opinion considerably simpler than isokinetic sampling for particulate matter. Consequently, testing could easily exceed $10k when you account for the number of technicians that will be required to conduct a test, the duration of the tests, and the complexity of set-up. Perhaps the MOE will consider annual or biennial testing for the combustion gases and particulate matter testing every other time.

For details of the proposed policy see Emission Limits for Internal Combustion Engines used for Non-Emergency Power Generation.

PEN 32 Newsletter by Philip Girard, P.Eng.
Philip Girard is a Vice President at Pinchin Environmental Ltd.

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