# Presentation: 001004

## LME Monitoring Option

- Low Mass Emissions Units

## LME Monitoring Option for Determining Mass Emissions

- Low Mass Emissions Methodology (§75.19)
- Generic NOx Emission Rate or Fuel-and-unit specific NOx Emission Rate
- Generic SO2 Emission Rate or Fuel-and-unit specific SO2 Emission Rate (using procedures in Appendix D section 2.3.6)
- Maximum Rated Heat Input Rate or Long Term Fuel Flow

## Low Mass Emissions Unit Methodology

- Procedure that may be used in lieu of CEMS or the excepted methods under App D and E for the purpose of determining hourly heat input, SO2 mass emissions, and NOx mass emissions
- Natural gas and fuel oil only
- Emissions limitations
- Year round reporting units: NOx < 100 tons/year and _<_ 50 tons/control period
- Ozone season only reporting units: NOx _<_ 50 tons/control period
- SO2 _<_ 25 tons/year

**Notes:**
LME is all or nothing!!

## Low Mass Emissions Unit Methodology

- Units must demonstrate that in **each **of the three years immediately preceding the year of the application, the SO2 and NOx emissions did not exceed the annual and or seasonal threshold limits
- In the absence of historical EDR’s, reliable estimates of the unit’s emissions for the previous 3 years may be based on records of unit operation, fuel usage etc.

## Low Mass Emissions Unit Methodology

- If at the end of a calendar year or ozone season, it is determined that the emissions from an LME unit exceeded the applicable threshold the unit is required to install Part 75 continuous monitoring systems by December 31 of the calendar year following the year in which the LME status is lost

## LME - NOx Generic Emission Rate

- Generic NOx Emission Rate
- Table LM-2 of §75.19(c)

## LME – SO2 Generic Emission Rate

- Generic SO2 Emission Rate
- Table LM-1 of §75.19(c)

| Fuel type  | SO2 emission factors |
| --- | --- |
| Pipeline Natural Gas | 0.0006 lb/mmBtu |
| Other Natural Gas | 0.06 lb/mmBtu |
| Residual Oil | 2.1 lb/mmBtu. |
| Diesel Fuel | 0.5 lb/mmBtu |

## LME - NOx Emission Rate

- Fuel-and-Unit Specific NOx Emission Rate (§75.19(c)(1)(iv)(C))
- Perform four load Appendix E testing
- Use the highest 3-run average NOx emission rate from the testing
- For units tested with SCR or SNCR
- Use the highest 3-run average NOx emission rate from the testing, or
- 0.15 lb/mmBtu whichever is greater
- Fuel-and-Unit Specific NOx Emission Rate (§75.19(c)(1)(iv)(G))
- Use the 95th percentile value from 3 years of quality-assured NOX emission rate data from a NOX-diluent CEMS

**Notes:**
4 load testing except for as provided under 75.19(c)(1)(iv)(I)

## LME - NOx Emission Rate                

- Reduced Testing requirements (§75.19(c)(1)(iv)(I))
- Rather than test at four load levels, testing may be conducted at one load level (for a single unit or all units in a group of identical units) if the data analysis required by §75.19(c )(1)(iv)(j) demonstrates that a unit or set of identical units operated at a single load level for at least 85.0 percent of all operating hours in the previous three years (12 calendar quarters) prior to the calendar quarter of the appendix E testing

## LME - NOx Emission Rate                Identical Units

- Representative appendix E testing may be done on a subset of low mass emissions units in a group of identical units
- Identical units must be of the same size (based on maximum rated hourly HI), manufacturer and model, similar operating conditions etc. (§75.19(c)(1)(iv)(B)(1))
- If all the LME units in a group qualify as identical, then representative testing of the units may be performed according to Table LM-4 of  §75.19

## LME - Heat Input Rate

- Maximum Rated Heat Input Method
- §72.2 defines the Maximum Rated Heat Input as “a unit-specific maximum hourly heat input (mmBtu) which is the higher of the manufacturer’s maximum rated heat input or the highest observed hourly heat input”
- Total Heat Input for the quarter is the product of the number of operating hours and the Maximum Rated Heat Input
- 			HIqtr = OPHrsqtr x MRHI

## LME - Heat Input Rate

- Long Term Fuel Flow Heat Input Method
- Fuel Flow
- Qualified fuel billing records
- A fuel measurement standard listed in §75.19(c)(3)(ii)(B)(2), or
- A fuel flowmeter certified, maintained, and quality assured according to Part 75 Appendix D

## LME - Heat Input Rate(LTFF Method)

- GCV
- Part 75, Appendix D §2.2 and 2.3, or
- Default GCV in Table LM-5
- Pipeline Natural Gas - 1050 Btu/scf
- Natural Gas - 1100 Btu/scf
- Residual Oil - 19,700 Btu/lb or 167,500 Btu/gal
- Diesel Fuel - 20,500 Btu/lb or 151,700 Btu/gal
- Total Heat Input is apportioned by load to each operating hour at the end of each reporting period
- EPA provides software to generate quarterly reports based on total HI and emission rate