Request For Information: Techniques to Substantially Reduce Carbon Monoxide Emissions from Gasoline Powered Portable Generators

Division of Procurement Services, U.S. Consumer Product Safety Commission (CPSC), 4330 East-West Hwy, Bethesda, MD 20814 http://www.cpsc.gov/volstd/engine/rfi.pdf.

"Portable Generators Killing Again" by Broderick Perkins

More and more often, natural disasters from summer hurricanes to winter snow storms don't blow through without leaving injuries and deaths in their wake -- not from the event itself, but from misusing power generators to keep the lights on when the power goes out. After Hurricane Katrina left much of the Gulf Coast in the dark last year, a dozen deaths and scores of carbon monoxide (CO) poisonings were blamed on portable gas-fired generators in the hands of those unfamiliar with their proper use.

After a Pacific Northwest Dec. 2006 snow storm with hurricane force winds knocked out electrical power to 1.5 million customers in the Pacific Northwest, including homes and businesses, hospital officials said CO poisonings reached "epidemic" levels. Just a week before Christmas, at least one man died of inhaling the colorless, odorless gas, more than a hundred were treated at area hospitals and dozens were sent to pressurized hyperbaric chambers which forced oxygen into their blood. (2 high school age boys near Port Angeles died of CO poisoning inside a garage which had a portable generator operating).

At least 222 Americans died from portable generator-linked CO poisoning from 2000 through 2005, with more than a quarter of them (64) occurring in 2005 alone, according to the Consumer Product Safety Commission.

The commission is researching product safety improvements including reduced emission, automatic shut offs during high levels of CO, weatherization and electrocution protection. It also recently approved plans to mandate generator makers replace ambiguous text-based "CAUTION" labels with more prominent labels that include international symbol-like pictograms and statements that include "Using generators indoors will KILL YOU IN MINUTES."

With greater incidence of harsh weather in recent years, more and more people are using portable generators for the first time and often under stressful, emergency conditions and that can cause them to use the otherwise helpful appliances in an unsafe manner.

Consumers Union, publisher of Consumer Reports says generator sales have risen roughly 20 percent in each of the past two years with the portable generator variety accounting for 92 percent of that total.

Published: December 19, 2006

http://www.eea-inc.com/rrdb/DGRegProject/modelrule.html

The U.S. DOE, through the National Renewable Energy Lab, has sponsored the development of a national model rule for regulation of emissions from distributed electrical generation. The project was coordinated by the Regulatory Assistance Project (RAP) . The goal of the effort was to establish air pollutant emission standards that could be applied uniformly across the country to ensure appropriate emission limits for distributed generation (DG) technologies and to streamline the permitting process for those technologies. The group has developed a draft model rule which was released in late October of 2002. Once the model rule is completed, it will need to be adopted by individual states to become effective.

Background

The national model rule is being developed by a working group of state air and energy regulators along with a few industry and environmental group representatives. The model rule development effort started in January 2001 and has proceeded primarily through conference calls and emails. There are two primary justifications for the rule. One is to set emission limits for distributed generation sources that are currently not regulated or not effectively regulated. The increased use of diesel standby generators as peaking units is one of the primary concerns. The second justification is to streamline the permitting of distributed generation units that meet the new limits and provide manufacturers with one uniform, national target. Coordinating these two goals has been difficult. Streamlining is really not an issue for the many small electrical generators that currently are not regulated at all. On the other hand, jurisdictions with stringent and complex requirements will have a difficult time accepting a national standard that may be less stringent.

A related underlying tension in the development of the rule has been the debate between those who would like to set limits based on the electrical output-based performance of large gas combined cycle generation units and those who believe that approach is not appropriate. The combined cycle levels of control cannot be achieved by most currently available technologies and are unlikely to be achievable in the foreseeable future.

Defining the applicability was another difficult issue. There is no clear definition of "distributed generation". The group considered factors including generating capacity, location, and emission and technology factors and eventually settled on including all sources that are not major emission sources. This means that the regulation would apply to much larger units of a clean technology than a higher emitting technology. This fits the streamlining goal. Since the major source threshold varies regionally, this means that the applicability will vary regionally. In attainment areas, the rule could include very large clean units, while in nonattainment areas it would apply only to much smaller units.

The Draft Rule

A draft model rule was released in late October of 2002. The rule applies to new, non-mobile electric generators that do not exceed the Federal new source review major source threshold in a given location. The rule would allow them to be automatically permitted if they meet the required emission levels and certain record-keeping requirements.

Portable generators subject to the Federal non-road engine standards are not covered by this rule.

The primary focus of the rule is on certification of small generators. However, other generators that can show compliance would be eligible to use this rule even if they were not certified. This is important for larger size generators or special application technologies that are not likely to go through the certification process.

The model rule includes separate standards for emergency and non-emergency units. The limits are phased in over time. The initial phase begins in 2004. The second phase is 2008 - 2012. The third phase is 2012 and beyond. The phase-in is supposed to encourage the development and commercialization of new technologies.

The rule sets limits for NOx, CO, particulates and CO2, however the development discussion has focused mostly on NOx and CO2. The CO2 limits are intended to send the message that CO2 emissions are important, without necessarily creating compliance problems for existing technologies. Since most of the technologies are already gas-fired, there is little that can actually be done at this point to reduce CO2 emissions.

Emergency Generators

This category is limited to generators that run only during power outages and limited maintenance hours. The generator may run up to a maximum of 50 hours per year for maintenance and whenever there is a power emergency, with a total limit of 300 hours per year. Operation for peaking, load shaving or load response programs is not allowed under this category. The source must record the date and start/stop time for every operation as well as total annual run hours. Maintenance hours must be separately accounted for.

Emergency generators must meet the emissions standards set by the US EPA for non-road engines (40 CFR 89) at the time of installation. Any engine that is certified under the US EPA non-road standards is automatically certified under this rule to operate as an emergency generator. In addition, CO2 emissions standards for emergency generators are as follows:

Phase One: Phase Two: Phase Three:

Beginning on 01/01/2004 Beginning on 01/01/2008 Beginning on 01/01/2012

1900 lbs/MWh 1900 lbs/MWh 1650 lbs/MWh

Non-Emergency Generators

All stationary generators that cannot qualify as emergency generators and that are not subject to the Prevention of Significant Deterioration or New Source Review programs will be limited to the following:

Phase One: (lbs/MWh) Phase Two: (lbs/MWh) Phase Three: (lbs/MWh)

PM-10 0.7 0.07 0.03

CO 10.0 2.0 1.0

CO2 1900 1900 1650

PM limits for nonreciprocating engines (such as turbines) are yet to be determined.

By December 31, 2010, the agency will complete a review of the Phase Three standards. Beginning in 2017 and every five years thereafter, the agency will review these standards and determine whether the emissions set out should be amended.

Dual-fuel electrical generators must meet these requirements when operated on gaseous fuels and are limited to no more than thirty days per year of operation using liquid fuel.

Combined Heat and Power (sometimes called "cogeneration units" or "CoGen units")

To receive thermal output related emission credits, CHP installations must:

# 20% or more of the fuel’s total recovered energy must be thermal and at least 13% must be electric.

# The design system efficiency must be at least 55%.

# A Combined Heat & Power system can receive a compliance credit based on the emissions that would

have been created by a conventional separate system. The credit will be subtracted from the actual

generator emissions. The credit will be calculated according to the following assumptions and procedures:

Pollutant Maximum emission rate (lbs/MMBtu)

NOx 0.3

CO 0.08

CO2 117

California To Limit Lawnmower Emissions By Erica Werner December 12, 2006

California, home to some of the nation's most polluted air in the Los Angeles basin and San Joaquin Valley, is under constant pressure to meet federal air quality standards or risk sanctions including losing money for highway projects. The California Air Resources Board, which passed the mower emissions rule three years ago but couldn't enforce it pending the EPA waiver, welcomed the news as key in developing clean air plans.

The EPA granted California long-awaited permission Monday (Dec 11, 2006) to slash emissions from lawnmowers and other small-engine machines, a change it will seek nationally next year. The EPA waiver will allow California, the nation's most populous state, starting Jan. 1, 2007 to require highly polluting small engines to be sold with catalytic converters that cut smog emissions by roughly 40 %. "The emission standards we are considering would reduce smog-forming pollutants from lawn mowers by over 40 % when fully implemented," said Bill Wehrum, EPA acting assistant administrator for air and radiation. "EPA approved the California waiver request because new, cleaner engines can safely reduce emissions." Engines under 50 horsepower account for 7 % of smog emissions in California from mobile sources, the equivalent of about 3 million cars. The engines also power pressure washers and small generators, but the bulk are on lawnmowers.

The EPA action Monday ended several years of political dispute driven by Republican Sen. Kit Bond, whose state of Missouri is home to two factories owned by Briggs & Stratton Corp., the nation's largest small-engine maker. Briggs & Stratton had resisted installing catalytic converters on its engines, and Bond had sought to block California from instituting its regulation.

California has unique authority under the Clean Air Act to set tougher pollution standards than the federal government, once it gets an EPA waiver.

Bond backed off under pressure from Sen. Dianne Feinstein, D-Calif., but he did succeed in blocking other states from being able to copy California's rule, something the Clean Air Act normally allows. Instead, he required EPA to write a national standard. Bond had questioned whether mowers with catalytic converters could spark fires, but an EPA study earlier this year found there was no safety problem.

"This is a giant step forward for California," Feinstein said. "It paves the way for California to implement strict emission controls on lawnmowers and other small engines and to see major reductions in air pollution." The California Air Resources Board has estimated that walk-behind mowers will cost between $37 and $52 more under the new regulation, while the price of commercial turf care mowers will go up between $71 and $179. California, home to some of the nation's most polluted air in the Los Angeles basin and San Joaquin Valley, is under constant pressure to meet federal air quality standards or risk sanctions including losing money for highway projects. The California Air Resources Board, which passed the mower emissions rule three years ago but couldn't enforce it pending the EPA waiver, welcomed the news as key in developing clean air plans.