Time to Plan your Path to Compliance with MSAPR – Part 2: Engines

The Multi-Sector Air Pollutants Regulations (MSAPR) was registered by Environment and Climate Change Canada (ECCC) in June 2016 with the objective to achieve consistent Canada-wide performance standards for certain industrial facilities and equipment.   Stationary Spark Ignition Engines are one type of equipment targeted under the MSAPR, specifically Part 2.  MSAPR establishes a process for registering, monitoring, testing and reporting of oxides of nitrogen (NOx) emissions and provides NOx emission intensity limits (g NOx / kWh) which are phased in over time.

Part 2 applies to stationary spark ignition engines that meet the definition in MSAPR that are “pre-existing” (i.e. manufactured, owned or operated before September 2016), are at an “oil and gas facility” (other than an asphalt refinery) as defined, are > 250 kilowatt (kW) rated output capacity (break power) and that combust gaseous fossil fuel.  Part 2 also applies to stationary spark ignition engines that are “modern” (meaning they are not “pre-existing”), are at one (1) of thirteen (13) regulated facilities as defined, are > 75 kW (for an engine deemed “Regular” use) or > 100 kW (for an engine deemed “Low” use) and that combust gaseous fossil fuel.  

Engines that are operated at least one (1) hour per year are considered “Regular” use unless specifically deemed to be “Low” use.  One of the eligibility criteria for the election of an engine as "Low” use is if it is operated ≤ 1314 hrs in 3 year period (i.e. ≤ 5% of the time). 
Part 2 sets out nitrogen oxides (NOx) emission intensity limits (g NOx/kWh) as well as compliance testing, operation and maintenance and reporting requirements.

Impacted stationary spark ignition engines are to be registered by January 1, 2019.  For “pre-existing” and “Regular” use engines, the first phase NOx emission intensity limits apply January 1, 2021 and the second phase limits apply January 1, 2026.  There are no limits for “pre-existing” and “Low” use engines under MSAPR.  The responsible person (owner or operator) can choose a Flat Limit Approach or a Yearly Average Approach when assessing a fleet of “pre-existing” and “Regular” use engines.  The approach can impact the timing or whether mitigation measures are needed at all to meet future NOx emission intensity limits.

For “modern” and “Regular” or “Low” use engines, the NOx emission intensity limit of 2.7 g NOx/kWh applies starting July 1, 2017.  The Flat Limit Approach is the only option available for assessing a fleet of “modern” engines.  

At the time the future limits apply, compliance must be demonstrated by conducting an initial performance test and reporting with the frequency of ongoing performance tests or simplified emission checks impacted by the output capacity and type of engine (rich burn versus lean burn).

What are the Next Steps on the Path to Compliance?:

Now is the time to formulate a Compliance Plan for MSAPR Part 2.  A lower NOx emission intensity limit could apply as early as 2021 for “pre-existing” engines.   Projects to lower the NOx emission intensity can be capital intensive and time consuming so forward planning is highly recommended.  Suggested next steps in the development of a Compliance Plan should consider:

  • A detailed analysis of facilities to confirm pre-existing engines are indeed subject to MSAPR Part 2 as well as historical and expected future time of use as well as availability/suitability of site conditions for future performance testing;
     
  • A detailed analysis of timelines and mitigation or other measures required to ensure compliance including possible implications of choosing the Flat Limit Approach versus the Yearly Average Approach for your fleet of pre-existing engines;
     
  • Baseline emission testing.  Although not specifically required in advance of registration, there are distinct advantages to confirming the NOx emission intensity of pre-existing engines using actual testing as opposed to estimates especially if mitigation may be required to meet the future limits; and
     
  • An assessment of opportunities for synergies or efficiencies of the activities required in support of the MSAPR and other compliance activities such as those required in support of a provincial environmental permit.

For more information on ORTECH MSAPR service offerings, click here.