Engine

And
Turbine
Environmental
Certification Workbook

For use with the MassDEP

Environmental Results Program

Massachusetts Department of Environmental Protection

January 2011
 THE
ENVIRONMENTAL
RESULTS PROGRAM

INTRODUCTION

The Massachusetts Environmental Results Program (ERP) is an on-going environmental

performance enhancement and measurement initiative that seeks to cost-effectively
improve the environmental performance of whole small business sectors. In this
regulatory system, comprised of a unique set of linked regulatory tools, institutions and
businesses are educated about their environmental impact and obligations, are required to
self-evaluate and certify compliance, and are tracked to measure environmental
performance changes. The Massachusetts Department of Environmental Protection
(MassDEP) uses a statistical approach to track individual facility and whole-group
performance results to identify poor performance areas and to effectively target limited
agency compliance assistance and enforcement resources.
The ERP now includes performance standards that include the use of clean fuels,
equipment maintenance, and record keeping requirements for new engines with a rated
power output equal to or greater than 50 kilowatts (kW) and combustion turbines with a
rated power output less than ten megawatts (MW). You must submit an initial
installation certification that your facility meets environmental performance standards.
By simplifying and clarifying the regulatory process, MassDEP hopes to reduce the cost
and time required for compliance, while maintaining effective standards and improving
environmental results. This workbook provides the information you must understand to
meet your environmental obligations.

January 2011 2
 Table of Contents

Getting Started
1.1 Who is Subject
1.2 Who Should Read This Workbook
1.3 What You Should Know as a Facility Owner/Administrator

Air Quality Requirements

2.1 Emission Limits
2.2 Fuel Requirements
2.3 Operational Requirements
2.4 Stack Design
2.5 Sound
2.6 Record Keeping

Related Activities
3.1 Underground Storage Tanks

Definitions and Terms

Appendix 1: Information Needed for Air Dispersion Modeling

Appendix 2: MassDEP Regional Offices

January 2011 3
GETTING STARTED

1.1 WHO IS SUBJECT TO ERP FOR ENGINE AND TURBINES?

An owner or operator who installs, after March 23, 2006, an engine with a rated power
output equal to or greater than 50 kW or a combustion turbine with a rated power output
equal to or less than ten MW is subject to the requirements of the Environmental Results
Program (ERP) for engines and turbines.
The applicability thresholds are based upon the engine or turbine rated power output,
not the electrical output of the electrical generator.

1.2 WHO SHOULD READ THIS WORKBOOK?

Engine or Turbine Supplier/Installer:

All engines with a rated power output equal to or greater than 50 kW and combustion
turbines with a rated power output equal to or less than one MW installed after March 23,
2006 must meet the air emission limits specified in the Engine and Combustion Turbine
ERP regulation [310 CMR 7.26(43)] and outlined in this workbook. Therefore, it is
crucial that you understand the requirements to ensure that the engine or turbine you
install is capable of meeting the standards. You are also a primary source of technical
expertise to your customers. Providing the information and service that your customer
needs to operate and maintain the engine or turbine as efficiently and cleanly as possible
not only minimizes emissions but is a good business practice as well. You are also
responsible for supplying information to the owner/operator that each engine or turbine
you supply/install complies with the applicable emission performance standards.

Facility Owner/Administrator:
As the owner or chief administrator of the facility, it is important that you understand the
regulatory requirements described in this workbook. It is your responsibility to ensure
that your new engine or turbine is operated in compliance with the applicable
environmental regulations. By ensuring that the “hands-on” person who operates the
engine or turbine understands the material in this workbook, you can make sure that the
new engine or turbine is run cleanly and efficiently, with minimal impact to the
environment. You will also be confident that the compliance certification you must sign
is completed accurately and truthfully.
Under the heading "Related Activities", this workbook provides information you may
need if underground petroleum storage tanks are located on your property.

Engine or Turbine Operator:

January 2011 4
As the operator, it is equally important that you understand the material in this
workbook. You are the “hands-on” person who has the daily responsibility to operate
and maintain the unit properly. To ensure compliance you must understand the fuel,
stack, operational and record keeping requirements. You should also read the Related
Activities section if you manage underground petroleum storage tanks.

1.3 WHAT YOU SHOULD KNOW AS A FACILITY OWNER /

ADMINISTRATOR
 The cornerstone of the Engine and Turbine ERP is the requirement that these
engines comply with the applicable emission standards contained in the
regulations at the time of installation. For example, a 500kW engine installed in
2006 must meet emission limitations for a model year 2006, 500kW engine.
(Note that a unit being relocated at the same site, to serve the same power need,
i.e. the same building, is not considered installed after March 23, 2006, however
care must be exercised in locating the unit to cause a condition of air pollution.
See Sections 2.4 and 2.5.)
 Particular care is required when locating engines and turbines so as not to cause a
localized health or nuisance problem from emissions or sound impacts. The clean
fuels requirement is a key component in assuring exhaust impacts are minimized
from these units.
 The air contaminants emitted by engines and turbines can have significant health
impacts, especially to the very young, the elderly, and the people suffering from
respiratory illnesses. Particulate matter, especially the small-sized particulate
matter generated by fuel combustion, can cause and contribute to serious
respiratory problems. Sulfur dioxide (SO2 ) and oxides of nitrogen (NOx) are
respiratory irritants and key ingredients in the formation of acid rain. NOx is
also a major contributor to summertime smog.
 There is no need to obtain a pre-construction plan approval under 310 CMR 7.02.
Under ERP you submit a certification within 60 days following the start of engine
or turbine operation. This allows you to quickly replace an old failing engine or
turbine with a new unit that meets currently applicable standards for new units at
the time of installation.
 If you identify compliance problems that cannot be corrected before submittal
deadline, you must file a Return to Compliance Plan (RTC) for each of the
problems along with your Compliance Certification. The RTC requires you to
explain the problem, list the correction actions to be taken, and provide an
anticipated return to compliance date. MassDEP may follow up with additional
questions or an on-site inspection, if necessary.
 There is no fee associated with the certification. Please note that your facility still
may be subject to other MassDEP fees, such as the annual air quality or
hazardous waste compliance assurance fees.

January 2011 5
  Installation of an engine or turbine subject to ERP requires the submittal of a
Source Registration (310 CMR 7.12) to MassDEP, when:

 the engine has a maximum energy input capacity of 3 million Btu/hr or

greater, or
 the turbine has a maximum energy input capacity of 10 million Btu/hr or
greater, or is located at a facility with an energy input capacity of 10
million Btu/hr in total (including the newly installed turbine).

 If installation of the engine or turbine results in you being subject to the emissions
reporting requirements of MassDEP’s Source Registration for the first time, you
must contact MassDEP by January 31, and follow up by submitting a Source
Registration.

 If you are uncertain how to file a Source Registration, you should go to the
MassDEP website at: http://www.mass.gov/dep/service/compliance/srfaq.htm.
Under the heading: Important Information for New Facilities, you will find
guidance on how to file a Source Registration.

 Installation of a new engine and turbine can have facility-wide ramifications.

Potential emissions of the new engine and turbine may cause total emissions from
your facility to exceed thresholds for other air pollution control requirements,
including New Source Review (NSR), Operating Permits, and Prevention of
Significant Deterioration (PSD).

 If are or become a major source of air emissions you could be subject to one or
more of the following:
 Operating Permit Program
 Emission Offsets and Non-attainment Review
 Prevention of Significant Deterioration requirements

January 2011 6
 If you have any questions concerning whether or not your facility is subject to
any of these programs, please call your MassDEP Regional Service Center for
additional information. See http://mass.gov/dep/about/region/findyour.htm.

***************
Central Regional Office: (508) 792-7650
Northeast Regional Office: (978) 694-3200
Southeast Regional Office: (508) 946-2714
Western Regional Office: (413) 784-1100

***************
 You should also be aware that compliance with the requirements of engine and
turbine ERP does not relieve you of the responsibility to comply with other
regulations such as:
 40 CFR 60 Subpart IIII – Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines.
 40 CFR 60 subpart JJJJ- Standards of Performance for Stationary Spark
Ignition Internal Combustion Engines.
 40 CRR 63 Subpart ZZZZ—National Emissions Standards for Hazardous Air
Pollutants for Stationary Reciprocating Internal Combustion Engines
 40 CFR 60 Subpart KKKK- Standards of Performance for Stationary
Combustion Turbine
The EPA Customer Service Center at EPA-New England may be called at (617)
918-1111 for further information.
 NOTIFICATION TO MassDEP IS REQUIRED within 60 days following the start
of operation. Certification Forms are available on the MassDEP web site at
www.mass.gov/dep/service/online/erpforms.htm

The following sections describe the specific air quality and industrial wastewater
requirements for engines and turbines.

January 2011 7
AIR QUALITY REQUIREMENTS

2.1 EMISSION LIMITS

The owner or operator must obtain from the supplier a completed Emission Limit
Certification form, certifying that the engine or turbine as designed and installed will
comply with the applicable emission limits for the lesser of the first three years or 15,000
hours of operation when operated according to the manufacturer’s instructions. The
emission limitations are set forth in the following tables:

Emission Limitations – Engines

Installation Date Oxides of Particulate Matter Carbon

Nitrogen (Liquid Fuel Only) Monoxide
On and after 0.6 lbs/MWh < 1MW 0.7 lbs/ 10 lbs/MWh
March 23, 2006 MWh;
> 1 MW 0.09 lbs/MW
On and after 0.3 lbs/MWh 0.07 lbs/MWh 2 lbs/MWh
1/1/08
On and after 0.15 lbs/MWh 0.03 lbs/MWh 1 lb/MWh
1/1/12

Emission Limitations – Turbines

Rated Power Oxides of Nitrogen Ammonia Carbon Monoxide

Output
Less than 1 MW 0.47 lbs/MW-hr N/A 0.47 lbs/MW-hr Natural Gas
Natural Gas
1 to 10 MW 0.14 lbs/MW-hr Natural Gas 2.0 ppm at 0.09 lbs/MW-hr Natural Gas
0.34 lbs/MW-hr Oil 15% O2 dry 0.18 lbs/MW-hr Oil
basis

Emission Limitations – Engines and Turbines

Installation Date Carbon Dioxide

On and after March 23, 2006 1900 lbs/MWh
On and after 1900 lbs/MWh
1/1/08
On and after 1650 lbs/MWh
1/1/12

Visible emissions may not exceed 20% opacity at any time during engine and turbine
operation. Visible emissions do not include water vapor.

January 2011 8
2.2 FUEL REQUIREMENTS

To ensure efficient combustion and compliance with the emissions limitations, engines
and turbines must be operated and maintained according to the manufacturer's
instructions. On and after July 1, 2007, you shall not accept delivery for burning in your
unit, fuel oil that does not conform to EPA’s sulfur limits for transportation distillate fuel
(15 parts per million (ppm) sulfur).

2.3 OPERATIONAL REQUIREMENTS

 An engine or turbine shall be operated and maintained in accordance with the

manufacturer’s recommended operating and maintenance procedures.

2.4 STACK DESIGN REQUIREMENTS

The stack must discharge vertically upward. Stack heads, devices used to prevent
precipitation from entering the stack, must not restrict the vertical flow of the exhaust gas
stream. Devices such as “shanty caps” and “egg beaters” are prohibited. Coning of the
top of the stack is acceptable. No more than a one-inch change in diameter to every five
inches in length of cone is recommended in order to avoid serious backpressure that may
affect air flow at the point of origin.
Stacks must be designed to minimize plume entrapment in wakes caused by obstructions
to air streams.
 Regardless of the physical stack height requirements specified below, care must be
taken to locate units to avoid exhaust impacts upon people, windows and doors that
open, fresh air intake, and other sensitive receptors.
 Units rated less than 300kw shall have a minimum stack height of five feet above the
facility roof-top or the engine or turbine enclosure, whichever is lower.
 Units rated at 300kw but less than one megawatt shall have a minimum stack height
of ten feet above the facility roof-top or engine or turbine enclosure, whichever is
lower.
 For units rated at one megawatt and above, the minimum stack height must be 1.5
times the height of the building on which the stack is located. If the stack is less than
1.5 times the height of your building, or if any adjacent structures are taller than your
stack (see adjacent structure in Definitions), air quality modeling must be performed
to document that the National Ambient Air Quality Standards (NAAQS) will not be
exceeded. Appendix 1 lists the minimum data inputs that would be needed to execute
an EPA Screen3 Model run. If you need assistance, call the BWP Air Planning &
Evaluation Branch at 617-292-5766. A copy of the modeling analysis must be
attached to the certification.

January 2011 9
2.5 SOUND
Another potential result of improper attention to locating your unit is the creation of a
noise nuisance. Units should be housed in enclosures specifically designed to attenuate
sound. Similar to exhaust impacts, locations that will impact people, such as locations
near windows and doors that open, and other sensitive receptors are to be avoided.

2.6 RECORD KEEPING REQUIREMENTS

The following records must be kept onsite for the life of the ERP engine and/or turbine.
 Information on the equipment type, make and model and rated power output.
 If applicable, the results of an air quality model run which demonstrates that
engine and/or turbine emissions have not caused an exceedence of the National
Ambient Air Quality Standards (NAAQS).
 Copies of certificates and documents from the manufacturer and supplier related
to the certificates.
You must also keep the following records for at least three years. This means that each
individual record must be retained onsite (or at the closest facility where records can be
maintained) for three years from the date it was “created”.
 A monthly log of hours of operation, fuel type, and for fuel oil, heating value and
sulfur content.
 Purchase orders, invoices, and other documents to substantiate information in the
monthly log.

RELATED ACTIVITIES

3.0 Underground petroleum storage tanks:

Single wall, bare steel underground storage tanks containing petroleum products,
including those resting on the ground, were required to meet leak detection and
corrosion protection standards, or be replaced, as of December 22, 1998. For
more information, contact your local fire Department.

*****

January 2011 10
DEFINITIONS AND TERMS

Adjacent structure: means a structure that is within 5L of the stack. 5L means five times
the lesser dimension (height or maximum horizontal width) of the structure.

Air contaminant: volatile organic compounds (VOC’s), sulfur dioxide (SO2), nitrogen
oxides (NOx), carbon monoxide (CO), and particulate matter are contaminants of concern
in achieving air quality standards in the United States. Each geographic area is required
to meet specific limits for each contaminant.

Distillate Fuel Oil: fuel oil that complies with the specifications for fuel oil, numbers 1 or
2, as defined by the American Society for Testing and Materials.

Emission: any discharge or release of an air contaminant to the ambient air.

Engines: spark ignition and compression ignition stationary reciprocating internal

combustion engines.

NAAQS (National Ambient Air Quality Standards): Massachusetts is subject to national

standards that deal with six criteria pollutants: particulate matter (PM), nitrogen oxides
(NOx), sulfur dioxide (SO2), ozone, carbon monoxide (CO) and lead.

Natural Gas: a naturally occurring mixture of hydrocarbon gases found in geologic

formations beneath the earth’s surface, of which the principal constituent is methane, or
liquid petroleum gas (LPG), as defined by the American Society for Testing and
Materials. LPG includes propane, butane, or a combination of propane and butane.

Rated Power Output: the maximum electrical or equivalent mechanical power output
stated on the nameplate affixed to the engine or turbine by the manufacturer.

Supplier: a person that manufactures, assembles, or otherwise supplies engines or

turbines.

Turbine: a stationary combustion turbine.

January 2011 11
 Appendix 1
Minimum Data Inputs Required for an EPA Screen3 Model Run
(For use in determining emission impacts upon ambient air quality – Section 2.4.)

1. Stack height (feet) =>

2. Stack inside diameter (feet) =>

3. Stack gas exit temperature (o F) =>

4. Stack flow rate (cubic feet per minute) =>

5. Building height (feet) =>

6. Minimum horizontal building width (feet) =>

7. * Maximum horizontal building width (feet) =>

8. Type of fuel (natural gas or red dye distillate fuel oil) =>

9. Millions of Btu per hour of fuel input =>

10. Emission rate (grams per second) =>

* Length of the diagonal line that bisects a building when viewing it from above.

January 2011 12