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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
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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
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