Transcript Cat Engine Conference 2009

NSPS, NESHAP &
Emissions Section Only.
Caterpillar Engine
Conference
November 2009
Gas Compression NPI Update
Jim Cue and Vic Sheldon
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Agenda
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Emission Regulations – Review of NSPS & regional regulations
Gas Generator Sets for Oil and Gas Applications
Natural Gas Engine Product Line Overview
Break
95 – 220 hp Gas Engine Update (G3300)
215 – 637 hp Gas Engine Update (G3400 – CG137)
524 – 1725 hp Gas Engine Update (G3500 Options)
6000 – 8180 hp Gas Engine Update (GCM34)
Gas Engine Rating Pro (GERP) Update (Optional Attendance)
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Agenda









Emission Regulations – Review of NSPS & regional regulations
Gas Generator Sets for Oil and Gas Applications
Natural Gas Engine Product Line Overview
Break
95 – 220 hp Gas Engine Update (G3300)
215 – 637 hp Gas Engine Update (G3400 – CG137)
524 – 1725 hp Gas Engine Update (G3500 Options)
6000 – 8180 hp Gas Engine Update (GCM34)
Gas Engine Rating Pro (GERP) Update (Optional Attendance)
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Emissions Regulations – NSPS and
regional regulations
 National
– EPA defines minimum standards and rules for the U.S.
• New Source Performance Standards, Nonroad Source Rules
• National Air Quality Attainment Requirements
 States or Local
– State Specific Standards (at least as strict as EPA)
• Permits
– Critical Area Rules: Non-attainment, Parks, BLM etc.
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National - SI NSPS and NESHAP
 SI NSPS : (Stationary) Spark Ignited New Source
Performance Standards
– Published January ’08, Effective March ’08.
– 1st New engine requirements retroactive to July ‘07.
– 1st Remanufactured or Modified (RM) engine requirements
retroactive to June ’06.
– Applies to new, reconstructed or modified stationary
engines.
– Based on the date of engine manufacture, reconstruction
or modification, not the date of installation.
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National - SI NSPS Emissions Standards
EPA SI NSPS Engine Emissions Standards for RB NG, LB NG & LB LPG
by Engine Build Date
NOx / CO / VOC (g/hp-hr)
2006
12-Jun
>= 1350 HP
RB Only - 500 - 1349 HP
LB Only - 500 - 1349 HP
100 - 499 HP
26 - 99 HP
<=25 HP
2007
1-Jul
2008
1-Jul
2009
2010
2011
1-Jul
3 / 4 / 1 RM 2 / 4 / 1
1 / 2 / 0.7
3 / 4 / 1 RM 2 / 4 / 1
1 / 2 / 0.7
3 / 4 / 1 RM
2/4/1
1 / 2 / 0.7
3 / 4 / 1 RM
2/4/1
1 / 2 / 0.7
3 / 5 / 1 RM
40 CFR 1048.101 c, cert not required
Part 90 emiss. levels RM Manditory Certification via Part 90
– There are alternate ppm values that may be advantageous depending on
engine efficiency.
– There are standards for other applications as well. (ie. Landfill, etc.)
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National - NESHAP and SI NSPS
 NESHAP : National Emissions Standards for
Hazardous Air Pollutants
– Update to existing rule published January ’08, Effective
March ’08.
– Existing requirements back to ’02.
– Applies to new or reconstructed stationary engines.
• Are working on applying rule to all existing stationary engines.
– Newly regulated engines only have to meet SI NSPS.
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NESHAP Notice of Proposed Rule Making
 National Emission Standards for Hazardous Air Pollutants
for Reciprocating Internal Combustion Engines; Proposed
Rule change.
– Would change 40 CFR 63, subpart ZZZZ
 Regulates all previously unregulated SI and CI existing and
new stationary engines.
– Intended to drive the use of Catalysts
– Adds Startup, Shutdown and Malfunction Requirements
– Adds Mandatory Maintenance Requirements
 Over 180 comments were submitted.
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NESHAP Notice of Proposed Rule Making
6/3/2009
2/10/2010
Comments Due Effective Date,
3/31/2009
to EPA
Initial Comments
Date of Promulgation
Due to EMA
3/5/2009 - 2/10/2010
Rule Development
2/10/2010 - 2/10/2013
2/10/2013
Existing Engine Compliance Date
2/10/2010
2/10/2013
All
existing -engines
must be
compliant
this date. when
Affected new engines
must bebycompliant
2/10/2010
3/5/2009
Effective Date,
3/5/2009 - 2/10/2010
Date of Promulgation
Affected new engines installed
in this period must be compliant
by the Effective date.
2010
ment
010
installed
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2/10/2010 - 2/10/2013
2/10/2013
2/10/2010 - 2/10/2013
Affected new engines must be compliant when installed.
NESHAP Notice of Proposed Rule Making
 HAPs - ~188 regulated compounds
– Represented by a surrogate: Typically Formaldehyde, CO or VOC
 Major Source – @ site, 10 tons/yr single HAP, or 25 tons/yr all HAPs
 Area Source – Anything that is not a Major Source
>=500 hp
<500 hp
At Major Sources
New
Existing
SS
SSM
SS
SSM
At Area Sources
New
Existing
SS
SSM
SS
SSM
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SS
SSM
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P

P
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P
P
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
P
P
P
P
Steady State
Startup, Shutdown & Malfunction
P
Already regulated under existing NESHAP.
Proposed to be regulated under new NESHAP changes.

Not directly regulated, but steady state requirements apply as written.
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NESHAP Notice of Proposed Rule Making
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NESHAP Notice of Proposed Rule Making
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Example of Proposed NESHAP Ruling
– G3406 NA Engine purchased in 1996
– 215 bhp at 1800 rpm Rich Burn
– Area Source Compression site anywhere in the USA
– Requires change from Standard “Best Efficiency” to Catalytic setting
– Normal operation
– 40CFR60 JJJJ
– 40CFR63.6590c
– Startup, Shutdown & Malfunction
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State Emissions Highlights
– Colorado, East Slope (Denver Area)
Nonattainment
– Wyoming, Sublette County
– New Mexico, Aftertreatment Permits
– Texas, HGB Nonattainment
– Regional Regulation Activity
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Colorado, East Slope (Denver Area) Nonattainment Area
 The Denver area did not
meet the federal 8 hour
Ozone requirements
– Colorado submitted a State
Implementation Plan (SIP)
that shows compliance by
2012
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Colorado, East Slope (Denver Area) Nonattainment Area
 New Rule
– New, modified or relocated-into-the-state SI ICE must
meet the SI NSPS emissions standards in place when the
installation occurs.
– Existing RB ICE >500 hp must have 3 way catalysts, and
Air/Fuel controllers by May 1, 2010.
– Existing LB ICE >500 hp must have oxidation catalysts by
May 1, 2010, unless they are built before June 1, 2004
and the retrofit costs more than $5000/ton VOC.
– Engines regulated under 40 CFR 60, or operating under
MACT or BACT requirements are excluded.
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New Mexico
 Changes “Notice of Intent” Permit Policy
– Previously did not count aftertreatment
in their consideration of “potential
emission rate”.
– Aftertreatment used in meeting the CI
NSPS, SI NSPS or NESHAP will now
be accepted.
– Limits the number of engines that need
to go through the full air permit process.
New Mexico
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Wyoming
 Interim Permit Policy in
Sublette County
– 1 Measurement > Ambient
NOx standard
– Effectively caps VOC and
NOx Emissions
– Requires reduction of 1.5:1
for VOC, and 1.1:1 for NOx
 Still Working on Permanent
Measures
– Gas engines to replace
diesel engines in drill rigs
– SCR in diesel drilling
application
– Regulation of Diesel
Engines as Stationary
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Texas, HGB Nonattainment
 The Houston Area has
been redesignated as a
Severe Nonattainment
area.
– SIP update by 4/15/10.
– Mandatory CAA
compliance by 6/15/19
– New rules for engines in
the area likely.
HGB – Houston-Galveston-Brazoria
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Regional Regulation Activity
 Four Corners Task Force
 Marcellus Shale
– National engine emission rules will
– Just now evaluating potential air
improve air quality without other
quality impacts.
measures.
– Initial focus is on limiting drilling
– Adding 3-way catalysts to existing
emissions.
RB engines is the only engine
measure that showed other  Oklahoma &
Arkansas
significant improvement.
– SI NSPS is enough
for now.
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Key Summary Points Emission Regulations –
Review of NSPS & regional regulations
 National Regulations
– NSPS
• Applies to every new engine
• Based on born on date
• Next key date is July 1st, 2010
– NESHAP
• Proposed plan has not been finalized
• Based on start up date
• Next key date is February 10th, 2010
 States or Local
– Typically more strict than National Regulations
– Non – Attainment Areas
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Questions?
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Back Up Slides
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Information contained in this publication may be considered confidential.
Discretion is recommended when distributing.
Materials and specifications are subject to change without notice.
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as well as corporate and product identity used herein, are trademarks of Caterpillar and may not be used without permission.
LESWXXXX-00 (11/09)
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2009 Caterpillar
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