ADVANTAGE ENERGYLINK

REGULATORY COMPLIANCE - AIR EMISSIONS

One significant advantage EnergyLink International brings to the table is global regulatory expertise, developed by over several decades of our team’s world-leading air emissions control expertise. As environmental stewards, our team of highly skilled professionals have significantly invested their time and resources into fully understanding the complexities around air emissions which has further assisted in developing the most advanced solutions for overall operations. These solutions are specifically designed to not only meet but exceed the most stringent regulations. By working collaboratively right from the beginning, we can verify all environmental requirements are met during planning and design. This ensures quality systems that meet your specific needs while avoiding costly mistakes and oversights that can send you back to the drawing board.

AMERICA

Title Year Finalized Authorizing Statute Major Provisions Impact on Gas Turbine Emissions
Cross-State Air Pollution Rule 2011  Implementation – Phase 1: 2015 Phase 2: 2017 Clean Air Act The Cross-State Air Pollution Rule replaced the Clean Air Interstate Rule starting on January 1, 2015, and requires states to reduce power plant emissions of SO2 and NOx that contribute to ozone emissions and fine particle pollution in other states. NOx limits are to become tighter in states where the CAPR applies.

 

 Large electricity generating and industrial NOx sources in select states in New England must achieve a NOx emissions limit of no greater than 0.15 pounds of NOx per million Btu of heat input (lb NOx/mmBtu) during the ozone season from May 1 and October 1.  Many units run on dual fuel and oil is increasingly burned with seasonal arctic temperatures over last few years.
New Source Review 1980: policy updates in 1996 and 2002; 2017 Litigation suspended. Clean Air Act Affects stationary sources of air pollutants. Requires that a new or modified power plant obtain a pre-construction permit to ensure, among other things, that modern (in some cases Best-Available-Technology or Best-Available-Control Technology) pollution control equipment is installed. Requirements differ depending on where the plant is located to meet requirements under the National Ambient air Quality Standards. In a non-attainment area, NOx  is limited to 25 tpy.
National Ambient Air Quality Standards (NAAQS) and SIPS 1973,  amended in 1990, 2012 for PM, and reviewed in 2018. Clean Air Act Under Title 1, the CAA requires the EPA to set NAAQS standards for SO2, NOx, CO, PM2.5, PM10, Ozone and Lead.

  • Annual limit for NOx of 53 ppm (100 ug/m3);
  • Annual limit  for CO of 35 ppm (40 mg/m3) for 1 hour and 9 ppm (10 mg/m3) over 8 hours.

SIPs, or state plans, for compliance with NAAQS attain or exceed the NAAQS requirements.

 40 CFR Part 60 (new stationary gas turbines); limit of 42 ppm @15% O2 or 2.0lb/MWh).

 

Limits vary depending on state and areas within states. California’s limit is 9 ppm @15% O2 per turbine.
Ozone NAAQ 2015 Clean Air Act NOx emissions directly impact ozone levels. On October 2015, EPA lowered the ozone standard to 70 ppb which affects state area designations: Attainment, Unclassifiable, Non-Attainment. Public comment closed in February 2018.  States must meet the new standard by 2024. Affects older oil-, dual- and gas-fueled turbine units.   Example, the New York State Dept. of the Environment has set limits  for peaking units of 100 ppm by May 1, 2023, falling to 25 ppm by May 1, 2025 for gas and 42 ppm for oil and distillates. Estimated 3400 MW  in peaking units to be shut down and replaced.
Mercury and Air Toxics Standards (MATS) 2012; Implementation 2015-2016; 2017 Litigation suspended. Clean Air Act Set mercury, arsenic, acid gases and other toxic pollutants emissions limits for coal- and oil-fired power plants. Affected the sustainability of older coal and oil-fired power plants and caused closures of marginally economic generators.
Regional Haze Rule 1999; policy revisions in 2017; State plans due in 2021. Clean Air Act Requires states to develop long-term strategies, including enforceable measure to improve visibility in 156 national parks and wilderness areas.  Expected to result in more stringent emissions regulations.
New Source Performance Standards (NSPS) 2006; amended in 2013 Clean Air Act ENSPS regulations apply to new, modified and re-constructed facilities in specific stationary categories, including gas turbines. Requires best system of emission reduction (BSER). Subpart KKK of Part 60 limits NOx emissions based on combustion turbine heat at peak load. Most turbines for peaking units fire about 850 MMBtu/h and must limit NOx to 15 ppm @15% O2 (54 ng/J or 0.43/MWh).
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AUSTRALIA

Title Year Finalized Authorizing Statute Major Provisions Impact on Gas Turbine Emissions
National Standards for Criteria Pollutants and Product Emissions Standards Act 2017 2005 National Environment Protection Measures for Ambient Air Quality Nox limits of 0.12 ppm (1 hour) and 0.03 ppm (annual). CO limit of 9.0 ppm (8 hours). State limits vary. New South Wales: 70 Mg/Nm3 NOx limit in the Protection of the Environment (Clean Air) Regulation 2002.
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CANADA

Title Year Finalized Authorizing Statute Major Provisions Impact on Gas Turbine Emissions
Guidelines for the Reduction of Nitrogen Oxide Emissions from Natural Gas-fuelled Stationary Combustion Turbines.  Provinces have set varying emissions limits based on turbine rating.

 

 2017 Canadian Environmental Protection Act, 1999 (CEPA) New federal limit for NOx that is 50% more stringent than previous regulation. Limits, however, will not apply during start-up and shut-down, or part-load operations. Guidelines for the Reduction of Nitrogen Oxide Emissions from Natural Gas-fuelled Stationary Combustion Turbines.  Provinces have set varying emissions limits based on turbine rating.
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EUROPEAN UNION

Title Year Finalized Authorizing Statute Major Provisions Impact on Gas Turbine Emissions
Large Combustion Plant Directive 2001; updated in 2017 with more stringent limits and requiring SCR for NOx and Oxidation catalysts for CO  for oil-, liquids- and gas-fuelled turbines. Large Combustion Plants Directive 2001/80/EC;  Industrial Emissions Directive 2010/75/EU Regulation in effect in all EU countries unless more stringent NOx and CO criteria enacted.

  • Plants larger than 50 MW must achieve a yearly average NOx of 15  – 35 Mg/Nm3 (7.5 – 17 ppm) for new or existing oil -fired units and even lower limits for gas-fired of 10 – 30 Mg/Nm3 (5 – 15 ppm).
  • CO limits also must drop.

As of July, 2017, the best available technology of selective catalytic reduction (SCR) must be used to prevent or reduce NOx emission from gas, liquids and oil in turbines.

 Aeroderivatives for power generation are out of compliance. SCR technology must be used.
Medium Combustion Plant Directive 2015 Directive 2015/2193 Covers new and existing plants between 1 MW – 50 MW. NOx limits of 50 Mg/Nm3 (24 ppm) for new gas-fired turbines and 75 Mg/Nm3 (37 ppm) for new oil-fired.  Most new power plants will comply. Gas turbines at existing plants must reduce emissions to 150 Mg/Nm3 (73 ppm). Gas turbines running on partial load along pipelines won’t comply.
NEC Directive 2012 Gothenburg Protocol Gothenburg Protocol gives ceilings for 5 air pollutants: Sulphur dioxide (-79%), Ammonia (-19%), VOCs (-40%), Nitrogen Oxides (-63%), and fine particulates (PM 2.5).   The NEC Directive set limits identical to the Gothenburg limits and must be implemented into national legislation by 30 June 2018, with each member country producing a National Air Pollution Control Programme by 31 March 2019. NEC requires all states to make even deeper reductions in these 5 air pollutants by 2030.
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INDIA

Title Year Finalized Authorizing Statute Major Provisions Impact on Gas Turbine Emissions
National Clean Air Programme 2019 Air (Prevention and Control of Pollution) Act 1981 and  1987 Target of 20-30% reduction in PM2.5 and PM 10 concentrations by 2024 (2017 as base year). For thermal power plants, new standards set;  PM2.5 of 30 Mg/Nm3; 100 Mg/Nm3 for NOx. All plants are to be in compliance by 2020.
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MENA

Title Year Finalized Authorizing Statute Major Provisions Impact on Gas Turbine Emissions
Improving Country and Local Regulations Selective lowering of limits in certain states to European or North American standards. Not Applicable Saudi Arabia: Commission Environmental Regulations 2015 – Significant lowering of limits between 2001 and 2015. Standard covers all new, modified, reconstructed and existing facilities. Operators are to use Best Available Techniques (BAT).

 

Egypt: Air Quality Limit values are given in Executive Regulations of the Environmental Law No. 4 (1994) NOx (400 Mg/Nm3 (1 hour) and 150 Mg/Nm3 (24 hrs) but World Bank standard most often applies.

 Saudi Arabia Stationary Gas Turbines Over 100MW

NOx = 9 ppmv @15% O2 ; >10 –  100MW NOx 25 ppmv @ 15% O2; < 10MW NOx 42 ppmv @ 15% O2.

 

Qatar Petroleum for Ras Laffan Industrial City:

NOx of 400 Mg/Nm3 (1hour); 150 Mg/Nm3 (24 hrs); 100 Mg/Nm3 (annual).

 

UAE Government of Dubai Regulation EN – 4.0 Air Environment. Gas turbine units are 70 Mg/Nm3 gas fuel and 150 Mg/Nm3 liquid fuel).
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