Starting in June 2016, Environment and Climate Change Canada instituted the current Mulit Sector Air Pollutants Regulation (MSAPR) that covers Part 2 Stationary Spark Ignition Engines in the categories of Modern engines (installed new after September 2016) and Pre-Existing engines manufactured before that date for both “Lean Burn” and “Rich Burn” configurations.
The Performance Test (section 69) is required for all engines in your fleet that meet the need of the reporting and grouping for your emissions plan. Performance testing is used to start off the time line for your testing program and at specified intervals and refer to ASTM and EPA test methods that outline test port location, sampling procedures and specific testing requirements. NOx intensity units for the Performance Test can be reported and submitted in either g/kWh or ppmvd15% (parts per million by volume dry, corrected to 15% O2).
The first Performance Test puts the wheels in motion for your program with that engine and subsequent Emission Checks can be used to extend your testing program and is required for both the Modern and Pre-Existing engines in the Lean Burn and Rich burn categories.
As of January 1, 2021 the first tier of limits apply and now testing is coming to the forefront for those in the subgroups and subsets as outlined in the regulation.
What are the testing time requirements for Performance Testing?
Testing frequency for the engines will depend on the engine burn type and testing program outlook. Clients can select to do only Performance Testing for the their program or to extend testing frequencies with Emission Checks.
There is more to consider when setting up your program than just simply picking an intensity unit to report. The type / method of testing can be affected and because of this can potentially affect the testing cost. There are reasons beyond this when choosing how to quantify NOx and having a good dialog with your testing contractor would aide in developing an effective and productive strategy.
Consulting the Emissions Intensity Testing contractor to develop a strategy and describing these differences should be a priority for those in charge of implementing a testing program.
Testing integrity, accuracy, and repeatability remains paramount for us at EMS Inc. Being adaptable is also valuable whereby we do not require a dedicated trailer to achieve testing results. This is achievable by utilizing truly portable Horiba PG-350 CEMS Lab Quality Analyzer systems that allow us access into any areas by our own E33 Van and able to utilize portable lifting systems.
Also, the portable PG-350 CEMS system by Horiba are purpose built for mobility and are built for the various means of transport we encounter and not rack mounted for the lab. The Horiba PG-350 Portable Gas Analyzer Series offers the same reliability of an USEPA compliance system even though it is a portable unit. The systems are lab quality to comply with current EPA methods outlined in the MSAPR documentation yet durable for transport and repeatable testing results.
Above all we have been very selective to ensure that the testing and reporting will be in compliance with the MSAPR guidelines and follow all protocols that are outlined in it for the specific instrument used. ASTM 6522-11, EPA Method 3, EPA Method 7E, Method 10 are all examples depending on the system utilized on site. Reliable data can be reported, documented and be repeatable. We have been diligently attending the ECCC workshops, communicating with ECCC and ensuring we understand the requirements you need to attain to meet the current guideline.
ECCC MSAPR Part 2 Workshop
What does your testing program look like? Getting input from your contractor can be paramount to developing a long lasting relationship of reporting and testing commitments. Contact us and start the program with EMS Inc.