240 likes | 535 Views
NSPS, NESHAP & Emissions Section Only. Caterpillar Engine Conference November 2009. Gas Compression NPI Update Jim Cue and Vic Sheldon. Agenda. Emission Regulations – Review of NSPS & regional regulations Gas Generator Sets for Oil and Gas Applications
E N D
NSPS, NESHAP & Emissions Section Only. Caterpillar Engine ConferenceNovember 2009 Gas Compression NPI Update Jim Cue and Vic Sheldon
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)
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)
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.
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.
National - SI NSPS Emissions Standards • There are alternate ppm values that may be advantageous depending on engine efficiency. • There are standards for other applications as well. (ie. Landfill, etc.)
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.
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.
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
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
State Emissions Highlights • Colorado, East Slope (Denver Area) Nonattainment • Wyoming, Sublette County • New Mexico, Aftertreatment Permits • Texas, HGB Nonattainment • Regional Regulation Activity
Colorado, East Slope (Denver Area) Non-attainment 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
Colorado, East Slope (Denver Area) Non-attainment 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.
New Mexico 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.
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
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
Four Corners Task Force • National engine emission rules will improve air quality without other measures. • Adding 3-way catalysts to existing RB engines is the only engine measure that showed other significant improvement. • Marcellus Shale • Just now evaluating potential air quality impacts. • Initial focus is on limiting drilling emissions. • Oklahoma & Arkansas • SI NSPS is enough for now. Regional Regulation Activity
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
Information contained in this publication may be considered confidential. Discretion is recommended when distributing. Materials and specifications are subject to change without notice. CAT, CATERPILLAR, their respective logos, ADEM, “Caterpillar Yellow” and the POWER EDGE trade dress, as well as corporate and product identity used herein, are trademarks of Caterpillar and may not be used without permission. LESWXXXX-00 (11/09) 2009 Caterpillar All rights reserved.