NOx Emissions from Stationary Combustion Turbines MECP vs. ECCC

Written by: 

ORTECH reviewed the recent changes to the Stationary Combustion Turbine regulations and compared the differences between the Ontario Ministry of Environment, Conservation and Parks (“MECP”), formerly Ministry of Environment and Climate Change (“MOECC”) and Environment and Climate Change Canada ("ECCC").  We noted that some facilities might be compliant on a provincial level but not federally.  This posting will help to compare the two regulations. 

ECCC has updated its NOx emission requirements for new natural gas–fuelled stationary combustion turbines with the publication of Guidelines for the Reduction of Nitrogen Oxide Emissions from Natural Gas–fuelled Stationary Combustion Turbines in November 2017. The new Guidelines introduce a NOx emission limit that is up to 50% more stringent than emission limits set out in the National Emission Guidelines for Stationary Combustion Turbines published in 1992. The ECCC suggests various regulatory authorities use the Guidelines as a starting point for NOx from natural gas–fuelled stationary combustion turbines.

The current MECP policy on emission requirements for new stationary combustion turbines is Guideline A-5 Atmospheric Emissions from Stationary Combustion Turbines published in March 1994. ORTECH compared the differences between the new ECCC guidelines and the current MECP guidelines. We noted that due to the new, more stringent federal requirements, some facilities may be compliant on a provincial level but not federally. This posting will help to compare the two policies.

The MECPpolicy (Guideline A-5 Atmospheric Emissions from Stationary Combustion Turbines) is located here and the ECCC policy (Guidelines for the Reduction of Nitrogen Oxide Emissions from Natural Gas–fuelled Stationary Combustion Turbines) is located here.

Scope

The following table presents a side by side comparison of the scope of both Guidelines, with differences highlighted.

1.jpg

NOx Emission Limits

The following table presents a side by side comparison of the NOx emission limits of both Guidelines.

Picture2.jpg

Testing and Monitoring

The following table presents a side by side comparsion of the scope of the testing and monitoring requirements of both Guidelines, with differences highlighted.

Picture3.jpg

In addition to the testing and monitoring requirements listed in the table above, the MECP Guideline states that a verification of the average operating thermal efficiency of a Combustion Turbine should be conducted whenever there is source testing or in the case of units equipped with CEM devices initially and thereafter every 2 calendar years. The ECCC guideline has no requirement for verification of thermal efficiency.

If you have any questions about this post, please reach to Giulia Celli at gcelli@ortech.ca