BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
NOx EMISSIONS FROM STATIONARY
)
RECIPROCATING INTERNAL COMBUSTION )
ENGINES AND TURBINES:
)
AMENDMENTS TO 35 ILL.ADM.CODE
)
SECTION 201.146 AND PARTS 211 AND 217.
)
NOTICE OF FILING
R07-19
(Rule
making
- Air)
To:
John
T. Therriault, Assistant Clerk
Illinois Pollution Control Board
James
R. Thompson Center
Suite 11-500
100 West Randolph
Chicago, Illinois 60601
Tim Fox
Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
PLEASE TAKE NOTICE that we have today filed with the Office
of the Clerk of the
Pollution Control Board the
PRE-FILED TESTIMONY
OF JAMES McCARTHY.
Dated: April 23, 2008
Renee Cipriano
Kathleen
C. Bassi
Stephen
J. Bonebrake
Joshua
R. More
SCHIFF HARDIN, LLP
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606
312-258-5500
Fax: 312-258-5600
Electronic Filing - Received, Clerk's Office, April 23, 2008
CERTIFICATE OF SERVICE
I, the undersigned, certify that on this 23
rd
day of April, 2008, I have served electronically
the attached
PRE-FILED TESTIMONY OF JAMES McCARTHY
upon the following
persons:
John
T. Therriault, Assistant Clerk
Illinois Pollution Control Board
James
R. Thompson Center
Suite 11-500
100 West Randolph
Chicago, Illinois 60601
Rachel
L. Doctors
Illinois Environmental Protection Agency
1
021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
rachel.doctors@illinois.gov
paper service having been waived.
Renee Cipriano
Kathleen
C. Bassi
Stephen
J. Bonebrake
Joshua
R. More
SCHIFF HARDIN, LLP
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606
312-258-5500
Fax: 312-258-5600
eH2\ 1920316.5
Tim Fox
Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
foxt@ipcb.state.il.us
N. LaDonna Driver
HODGE DWYER ZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
nldriver@hdzlaw.com
Electronic Filing - Received, Clerk's Office, April 23, 2008
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
SECTION 27 PROPOSED RULES FOR
NITROGEN OXIDE (NOx) EMISSIONS
FROM STATIONARY RECIPROCATING
INTERNAL COMBUSTION ENGINES AND
TURBINES: AMENDMENTS TO 35 ILL.
ADM. CODE PARTS 211 AND 217
)
)
)
)
)
)
)
)
R07-19
(Rulemaking - Air)
TESTIMONY OF JAMES McCARTHY
My name is James McCarthy. I am a Principal with Innovative Environmental Solutions,
Incorporated ("IES"). IES specializes
in air quality and greenhouse gas emission consulting on
energy-related issues, and technical facilitation
of regulatory development with a focus on the
natural gas industrial sector. IES
is located in Cary, Illinois. I am co-owner and have been with
IES for six years. Prior to IES, from 1994 through 2002, I managed the air quality research and
development ("R&D") program for the Gas Research Institute ("GRI"), which was located in
Chicago. GRI was a Federal Energy Regulatory Commission ("FERC") regulated non-profit
organization that planned, managed and directed R&D programs for the benefit
of natural gas
consumers.
GRI was funded by a FERC sanctioned surcharge on natural gas deliveries. The
characterization, control, costs, and environmental impact
of air emissions associated with the
type
of equipment impacted by the Illinois Environmental Protection Agency ("IEPA") proposal
were a primary component
of the GRI R&D program under my direction. This research included
development
of retrofit control technologies to reduce emissions of nitrogen oxides ("NOx") for
natural gas-fired reciprocating internal combustion engines ("IC engines"), which are the
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Electronic Filing - Received, Clerk's Office, April 23, 2008
primary type of equipment affected by IEPA'sproposed rule. Stationary combustion turbines
("turbines") are also affected by the proposed rule, and the GRI program included development
of retrofit NOx control technologies for combustion turbines in conjunction with leading turbine
manufacturers. Prior to GRI, I was an engineering manager in compliance and planning with the
Santa Barbara County, California, Air Pollution Control District and an R&D manager and
engineer in private industry addressing air quality and waste management challenges for
combustion sources. I hold multiple patents related to air emissions control and measurement. I
am an Illinois native and have a Bachelor
of Science degree in Chemical Engineering from the
University
of California at San Diego, with graduate studies in respiratory toxicology.
IES has worked with a group
of natural gas transmission and storage companies since the
summer
of 2005 to provide technical and regulatory analysis and support associated with the
IEPA proposed rulemaking that is the subject
of this hearing and my testimony today. My
testimony today
is on behalf of two natural gas transmission companies ("Pipeline Group"):
ANR Pipeline Company and Natural Gas Pipeline Company
of America. The objective of my
testimony
is to provide background on the affected industry and its proactive approach to
addressing air emissions,
as well as the Pipeline Group'sperspective on the IEPA proposal in
R07-19.
The Pipeline Group operates
IC engines and turbines at natural gas compressor stations in
Illinois. Current generation
IC engines are typically 4-stroke cycle, higher speed, separable
engines, where the
IC engine and driven equipment (e.g., a compressor in natural gas
transmission) are separate units. Natural gas compressor drivers operated by the Pipeline Group
in Illinois are typically 2-stroke cycle or 4-stroke cycle, slow speed, large cylinder bore, integral
units, where the engine and compressor are integrated into a single piece
of equipment with one
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Electronic Filing - Received, Clerk's Office, April 23, 2008
crank shaft. These slow speed, large bore, integral units were uniquely designed and developed
for gas compression and are no longer manufactured. Within the U.S. gas transmission system,
the majority
of the IC engines were installed when primary components of the U.S. interstate
pipeline system were developed from the 1940'sthrough about 1970. Turbines used in gas
transmission are small industrial scale units, with capacity and emissions much lower than
turbines used in other sectors such as electric utilities. The characteristics
of compressor station
equipment are important because
of the implications on control technology applicability and
economic feasibility for retrofit application
of emission controls at compressor stations. The
continued operability
of these units is essential to our national energy infrastructure and its
reliability.
Because
of the unique attributes of compressor drivers in gas transmission, emissions
technology advances for the existing
IC engine infrastructure have primarily been due to efforts
of natural gas transmission companies. The natural gas industry has a legacy of commitment to
R&D. This has advanced the technological status for existing equipment, including an ongoing
dedication to advancing emission reduction technologies for the prevalent slow speed, integral
IC engines. In addition, natural gas companies have worked with leading manufacturers of small
industrial turbines to develop and demonstrate retrofit NOx controls for turbines. This proactive
approach to technology development
is a pragmatic objective to protect the specialized
infrastructure and ensure the availability and operability
of a key physical industry asset: the IC
engines and turbines that drive compressors and provide natural gas to markets throughout the
U.S. For IC engines, the technology used to reduce NOx emissions from natural gas compressor
drivers has primarily been developed through industry supported research with academic
institutions such
as the Colorado State University Large Bore Engine Testbed and Kansas State
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Electronic Filing - Received, Clerk's Office, April 23, 2008
University National Gas Machinery Laboratory, as well as niche aftermarket service providers
that have filled the commercial market gap left by the previous manufacturers.
These efforts have resulted in the development and enhancement
of Low Emission
Combustion ("LEC") technology for retrofit application to natural gas industry IC engines, and
the development
of Dry Low NOx Combustors ("DLN") for turbines. Through both R&D and
the application
of the technologies within the pipeline system, the Pipeline Group has extensive
experience in the retrofit application
of air pollution controls on natural gas-fired IC engines and
turbines, and in the installation
of new units that incorporate the latest emission control
technologies. This proactive approach and commitment to emissions issues
is also apparent
through the proactive approach to emission reductions
in Illinois for the large engines affected by
Subpart
Q under the R07-I8 rulemaking in 2007. For those engines, natural gas industry sources
implemented early reductions at a number
of facilities and assisted IEPA in communicating with
the U.S. EPA regarding status
of control implementation that addresses requirements in the
federal NOx SIP Call Phase 2 Rule.
In addition to technology issues, the operational attributes
of gas transmission compressor
stations warrant special consideration. The pipeline system
is regulated by FERC, who requires
that pipeline systems be designed to meet peak natural gas delivery demand. Thus, the system
is
designed with additional capacity relative to the norm or average demand. Because of this, high
utilization is not typical or expected for many gas transmission compressor drivers. Historical
gas demand
is typically characterized by lower utilization during the ozone season, with gas
demand and use increasing during the winter heating season.
It
is common for equipment to be
idle due to the excess system capacity inherent
to the system during non-peak times. Thus, some
compressor stations may run sporadically or not at all over extended periods depending upon gas
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Electronic Filing - Received, Clerk's Office, April 23, 2008
demand and seasonal markets. At some facilities, larger IC engines or turbines that run more
regularly can be co-located with other IC engines or turbines at the facility that exhibit low
or
minimal utilization. Because of system operational characteristics, it is not reasonable or
economically feasible to require retrofit control
of all units, as low-use units would bear the
burden
of significant cost while not providing meaningful emission reductions, especially during
the ozone season.
In addition, the response
of IC engines and turbines to emission controls varies for
different manufacturers and models. Unit-specific technology costs and performance can vary
dramatically for the slow speed, integral IC engines prevalent in gas transmission. Due to both
technology and operational limitations, it is imperative that
NOx regulations include flexible
options to facilitate compliance without undue burden. We note that IEPA has properly
considered an example
of performance limitations by including a less stringent NOx standard
under Section 217.388(a)(3) for a certain engine type found in the gas transmission sector.
Similar to the R07-18 rulemaking, the Pipeline Group was dedicated to working
constructively with IEPA to identify regulatory approaches for the R07-19 rulemaking. It was
imperative that the rule achieve the needed
NOx reductions while providing flexibility to the
affected sources. The proposed rule includes several notable provisions in this regard:
(l)
emissions averaging in Section 217.388(b); (2) low-usage criteria in Section 217.388(c); and, (3)
under Section 217.392(c), the limited use
of NOx allowances when anomalous situations pose
problems with emissions averaging
or low-usage requirements. These provisions are necessary
for a workable rule, and the Pipeline Group strongly supports their inclusion in Subpart Q. In
addition to these provisions, the Pipeline Group notes that rule applicability is limited to
nonattainment areas. This applicability criterion was adamantly supported by the Pipeline Group
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Electronic Filing - Received, Clerk's Office, April 23, 2008
throughout rule development, and substantiated by regional air quality modeling completed in
the fall
of2007.
The Pipeline Group does not object to the IEPA Subpart
Q
proposal under consideration
at today's hearing. As noted above, the Pipeline Group has worked with IEPA to
integrate
compliance options that provide compliance flexibility and address some of the unique
technology and operating attributes and limitations
of the natural gas transmission sector.
However, there are several items
of interest associated with the IEPA proposal that we would
like to highlight to ensure that our remaining concerns are identified.
First, the applicability threshold
of 500 horsepower ("hp") for IC engines and 3.5
megawatts ("MW") for turbines capture relatively small sources.
By limiting the proposal to
applicability only within nonattainment areas, the impact
of these capacity thresholds is limited.
However, the Pipeline Group notes that IEPA was pursuing broader applicability during rule
development, without reasonable substantiation
of the need for controls at these capacity
thresholds. We firmly believe that larger units for both
IC engines and turbines provide the most
cost effective and environmentally beneficial avenue for emission reductions, and question the
basis and legitimacy
of a 500 hp IC engine threshold and 3.5 MW turbine threshold. However,
the geographical applicability limitation and low usage criteria partially ameliorate our concerns
and thus the Pipeline Group does not strenuously object here, though the question
ofjustifying
such low thresholds remains.
In addition, we offer several comments on the IEPA Technical Support Document
("TSD")
in regard to emission control technologies. Several technologies discussed in the TSD
are not proven for application to natural gas transmission
IC engines and turbines or are of
limited or no benefit. Selective Catalytic Reduction ("SCR") is included as an applicable control
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Electronic Filing - Received, Clerk's Office, April 23, 2008
technology for both IC engines and turbines. However, to date, SCR has not been successfully
applied to gas transmission units, and U.S. EPA has acknowledged this limitation. In a 2002
notice regarding the NOx SIP Call that discusses large
IC engines affected by that regulation,
U.S. EPA states:
[T]hese engines (lean-bum IC engines
in natural gas transmission)
experience frequently changing load conditions which make application
of
SCR infeasible.... [O]ur ACT document states that little data exist with
which to evaluate application
of SCR for the lean-bum, variable load
operations. We now believe that there
is an insufficient basis to conclude
that SCR
is an appropriate technology for large lean-bum engines.
67 Fed.Reg. 8395,
8411 (February 22, 2002). In addition, Section 3.2.4.2 of the July 2000
version
of the EPA AP-42 document, which discusses control techniques for lean-bum IC
engines, states:
For engines which typically operate at variable loads, such as engines on
gas transmission pipelines, an SCR system may not function effectively,
causing either periods
of ammonia slip or insufficient ammonia to gain the
reductions needed.
Thus, although SCR
is marketed for application to IC engines, it has not been
demonstrated on retrofit units in service at a natural gas transmission compressor station. SCR
has been installed on a gas transmission turbine
in California, but that application has been
fraught with technical difficulties. This has resulted in significant site-specific re-engineering
that has resulted in exorbitant costs and a relaxation
of the initial emission limits. A very recent
installation on new
IC engines at a compressor station in the eastern U.S. has had very limited
operation, i.e., the station only operates when gas demand
is very high. Thus, based on the U.S.
EPA record and very limited industry experience, SCR
is not a demonstrated technology for
retrofit application to
IC engines or turbines in gas transmission. Additional engineering facts
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Electronic Filing - Received, Clerk's Office, April 23, 2008
are available to substantiate concerns about SCR applicability and performance and the immature
status
of SCR technology for gas transmission applications.
For turbines, water
or steam injection is also identified as a NOx control technology.
This technology is a "first generation" retrofit control that introduces operational, efficiency, and
emissions challenges.
It
has been supplanted by DLN technology and, to our knowledge, water
or steam injection has not been applied to any turbines in gas transmission. In addition, some
of
the NOx control technologies included in the TSD are questionable in regard to applicability to
natural gas-fired IC engines. For example, ignition timing retard may not provide meaningful
emission reductions, and the commercial availability and performance
of prestratified charge
technology are questionable.
In closing,
we reiterate that the efforts of the Pipeline Group to develop a functional and
effective rule that addresses
IC engine and turbine emissions in nonattainment areas are evident
through multiple meetings with IEPA and Pipeline Group comments submitted to IEPA since
August 2005. The Pipeline Group's intentions are apparent through proactive emission
reduction projects associated with the initial Subpart
Q
rulemaking in R07-18 and ongoing
dialogue with IEPA to facilitate the R07-19 rulemaking considered in the current IEPA proposal.
This proactive effort
by natural gas companies and IEPA's willingness to consider the technical
veracity
of our positions has culminated in a workable proposal that will assist IEPA in fulfilling
state implementation plan obligations mandated by the Clean Air Act.
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Electronic Filing - Received, Clerk's Office, April 23, 2008