AQ_F_2100073_20200529_ST_RvwMemo

Chowan County
DIVISION OF AIR QUALITY
Technical Services Section
May 29, 2020
MEMORANDUM
To: Betsy Huddleston, Washington Regional Office
From: Gregg O'Neal, P.E., Stationary Source Compliance Branch (SSCB)
Subject: Regulator Marine, Inc.
Edenton, Chowan County, North Carolina
Facility ID 2100073, Air Permit No. 07132T13
Carbon Monoxide Emissions Testing of MACT Subpart ZZZZ
Diesel-Fired Peak Shaving Generator (I.D. No. ES-14)
Performed October 29, 2019 by Integrity Air Monitoring, Inc.
Tracking No. 2019-335ST
Integrity Air Monitoring performed EPA Method 10 for carbon monoxide (CO) emissions.
Generator ES-14 is a Caterpillar peak shaving generator rated at 764 horsepower (hp) maximum
capacity. The electrical rated capacity of the generator is approximately 576 kW. This test was
performed with the generator operating within ±10 of normal load which is approximately 250
kW according to section 1.1 in the report. The engine CO emissions are controlled by oxidation
catalyst CD-14. During testing air permit number 07132T12 was in effect.
40 CFR 63 Subpart ZZZZ National Emission Standards for Hazardous Air Pollutants for
Reciprocating Internal Combustion Engines (RICE) applies and requires at least a 70% or more
reduction of CO emissions by the catalyst. In addition, permit condition (2.1.B.3.1) requires the
permittee to maintain the catalyst so the pressure drop across it does not change by more than
2 inches of water or±10% from the pressure drop measured during the most recent
performance test. Permit condition (2.1.B.3.k) requires maintaining the temperature of the
exhaust so that the catalyst inlet temperature is greater than or equal to 450 OF and less than or
equal to 1350 IF [See: 40 CFR 63.6600(b), Table 2a, Table 2b]. The test results are tabulated
below.
40 CFR 63 Subpart ZZZZ: EPA Method 10 - CO Emissions 10-29-2019 Test Results
Actual Catalyst CO ppmvd at Reduction
Source ID Generator Inlet AP Across 15%02 Efficency
and Serial# Power Output Temperature Catalyst Inlet Outlet Result Required Standard Compliance
ES-14 248.3 kW
#3PG01814 (99%of max Not reported Not reported 47.80 0.312 99.3% >_70% 63 ZZZZ Indicated
Normal)
According to section 1.2 in the report Regulator Marine was not able to recover the one-minute
test period data for the inlet and outlet differential pressure and engine temperature. Since this
information was not available the most recent CO Emissions performance test (i.e., 10-25-2018)
values for Catalyst Inlet Temperature at 685.2 OF and AP Across Catalyst at 0.33 inches H2O
will remain.
Compliance was indicated for peak shaving generator ES-14 with 40 CFR 63 Subpart ZZZZ, for
CO emissions despite the deficiencies in collection of the catalyst operation parameters noted
above. If there are any questions concerning this matter, please contact me at [phone]
or gregq.oneal(@ncdenr.gov.
cc: Central Files, Chowan County
IBEAM Documents - 2100073