Dear Friends and Business Associates:
Please see the below follow up report on a recent California Air Resource Board (ARB) class I attended that was open to the public. Take a minute to review my notes on the subject of toxic air clean-up in our California atmosphere and beyond if this subject is of interest to you.
The below is compiled research data along with my personal views as a business owner who rents diesel engine equipment in California used for generating portable power. The above picture is of a CAT Tier 4 Final Engine that shows the technical future of a close to zero emissions diesel engine design.
In 1990, the California Air Pollution Control Officers Association (CAPCOA), which is the governing body for all (35) State of California local districts of operations, adopted Federal and State of California statutes AB531–SB2635 1880 as part of the Health & Safety codes.
NOTES:
CATERPILLAR TIER 4 NEXT GENERATION PRODUCTS PERFORMANCE
“Caterpillar designed Tier 4 Interim products with Tier 4 Final standards in mind. By planning ahead, we were able to minimize design changes and deliver the reliability and performance you demand. Every Tier 4 Final engine is equipped with a combination of proven electronic, fuel, air and after treatment components, based on engine size, application and the geographic location in which it will work. Applying proven technologies systematically and strategically lets us meet your high expectations for productivity, fuel efficiency, reliability and service life.” http://www.cat.com/en_US/support/operations/technology/tier-4-technology.html
Clean Air Act Requirements and History.http://www.epa.gov/air/caa/requirements.htm
“Congress designed the Clean Air Act to protect public health and welfare from different types of air pollution caused by a diverse array of pollution sources.”
“The 1990 Clean Air Act is EPA’s first set regulations using a technology-based or performance-based approach to reduce toxic emissions from industrial sources. After EPA sets the technology-based regulations, the Act requires EPA to evaluate any remaining (“residual”) risks, and decide whether it is necessary to control the source further. That assessment of remaining risk was initiated in the year 2000 for some of the industries covered by the technology-based standards.”
“Congress established much of the basic structure of the Clean Air Act in 1970, and made major revisions in 1977 and 1990. Dense, visible smog in many of the nation’s cities and industrial centers helped to prompt passage of the 1970 legislation at the height of the national environmental movement. The subsequent revisions were designed to improve its effectiveness and to target newly recognized air pollution problems such as acid rain and damage to the stratospheric ozone layer.”
“When cars and trucks burn gasoline, toxic air pollutants are emitted from the tailpipe. Those air toxics are combustion products-chemicals that are produced when gasoline is burned. EPA is working with industries to develop cleaner-burning fuels and more efficient engines, and is taking steps to make sure that pollution control devices installed in motor vehicles work properly. EPA has issued requirements that are leading to cleaner-burning diesel engines, reducing releases of particle pollution and air toxics.”
“Air toxics are also released from industrial sources, such as chemical factories, refineries, and incinerators, and even from small industrial and commercial sources, such as dry cleaners and printing shops. Under the 1990 Clean Air Act, EPA has regulated both large and small sources of air toxics, but has mainly focused efforts on larger sources.” http://www.epa.gov/airquality/peg_caa/toxics.html
“CLEAN DIESEL TECHNOLOGY FOR OFF-ROAD ENGINES AND EQUIPMENT: TIER 4 AND MORE”
“Clean diesel technology is now the standard for all new technology, everything from new passenger cars and pick-up trucks to highway commercial trucks. Clean diesel is a system of three key parts: cleaner diesel fuel, advanced engine technology and aftertreatment. Now, starting in 2011, this new generation of clean diesel technology for off-road engines and equipment known as Tier 4 will be making its way onto the construction and industrial jobsites and farm fields around the country. The below paper describes the milestones and technology and what it means for dealers, distributors, mechanics and those involved with operating diesel engines and equipment.”Reference this link to read the paper for more detailed information on what is Tier 4? http://www.dieselforum.org/files/dmfile/CleanDieselTechnologyforOff-Road.pdf
“Tier 4 refers to a generation of federal air emissions standards established by the U.S. Environmental Protection Agency (EPA) that apply to new diesel engines used in off-road equipment. Essentially it requires manufacturers to reduce the levels of particulate matter and oxides of nitrogen (NOx) to a level that is 50-96 percent lower than existing generation of diesel engines. It is important to note that Tier 4 emissions requirements apply to new products only and do not apply retroactively to any existing machines or equipment. (See section on retrofit). EPA and California have adopted the same standards, so there are no unique Tier 4 diesel emissions standards that apply in California? All Tier 4 Final engines will require ultra-low sulfur diesel (ULSD) fuel to function properly.”
IMPORTANT NOTES ON THE USE OF (DEF) FLUID
“Cat will use two main strategies in its approach to supporting Tier 4 Cat machines sold in lower regulated counties, says Mary Roethler, Caterpillar’s Tier 4 Dealer Readiness manager. “Caterpillar’s Tier 4 Interim engines above 175 hp won’t have to be modified for sale in lower regulated countries. Tier 4 machines, whether Interim or Final, require ultra-low sulfur diesel, which complicates the sale of used Tier 4 machines into countries that do not sell ULSD. For machines in the 75-175 horsepower range, Cat is training and tooling their dealers in lower regulated countries to take off the emissions after treatment. Removal will decertify the machine for sale in highly regulated countries such as the United States. Caterpillars-Tier-4-engines-above-175-hp-wont-have-to-be-modified-for-sale-in-lower-regulated-countries, but for machines above 175 horsepower, Cat says the machine’s regeneration system uses a combination of chemicals and heat to take care of the higher levels of sulfur in the fuel, and thus, no modification is needed. That means that machines in this higher horsepower size classification—since they are not decertified—can be sold back into the North American market and other highly regulated areas.”
“This issue is complicated because of the differing regulations in each country,” Roethler says. Cat’s current Tier 4 machine population is 82,000-plus machines, and many of those have more than 9,000 hours, making them candidates for the used market. “Through our ProductLink telematics, we’re watching these machines, tracking where they go and the typical hours at which they are sold,” she says. For example, excavators are popular in Mexico. As Cat envisions it, for 75 to 175 horsepower machines, Cat dealers in a lower regulated country will take off the after treatment systems, since federal regulations prevent U.S. dealers from doing this procedure. Because of the high integration of fuel management and electronics with the after treatment system, Cat says this process will have to be done by a Cat dealer.”
“Tier 4 Final SCR engine strategy Cat also reviewed its strategy for Tier 4 Final engines.” “The Tier 4 Interim journey was the most challenging new product introduction in our history,” says Doug Mihelick, commercial manager of Cat Machine Engine & Components. The challenges required by these engine emission regulations included developing and producing 350-plus products and meeting multiple emissions requirements that involved several new technologies. Now we get to do it all over again with Tier 4 Final,” Mihelick says, and at a rate that matches our Tier 4 Interim pace of seven new models a month.”
“Tier 4 Final regulations, aimed at reducing oxides of nitrogen coming out of the exhaust, start to go into effect this January. Despite the challenges, Mihelick calls the Tier 4 Interim implementation—which has been in place the past three years—a “very successful new product introduction.” Cat says it has 82,000 Tier 4 Interim powered products in the field with 42 million-plus operating hours in North America, Europe, Australia and New Zealand, as tracked by ProductLink.”
“Earlier this week, Ed Rapp, Cat group president, said the company had invested $7 billion to get from Tier 4 Interim to Tier 4 Final. There are now more than 300 Tier 4 Final “field follow” machines—a term used by Cat for pre-production machines demoed in the dirt at customer sites. Using a Selective Catalytic Reduction after treatment exhaust system that requires the use of Diesel Emission Fluid, or DEF, these machines have logged more than 300,000 hours, some operating in minus 55 degree Fahrenheit temperatures at high altitudes plowing snow. The cold weather experiments are especially critical in learning how to deal with DEF, which is 67.5 percent de-ionzed water, freezes at -12 degrees Fahrenheit.”
“Another maintenance concern is keeping the DEF clean of debris. This will be an off-highway industry challenge, since the on-highway SCR engines don’t deal with the large amount of dirt and other debris that off-highway engines do,” Mihelick says. “Filtration will be one obvious solution,” he says, but others may be required as more hours are logged on DEF-equipped machines.”
“If a machine owner is going from a Tier 4 Interim to a Tier 4 Final machine, the operational differences will be slight, “Mihelick says.” With an Interim machine, the regeneration device was the primary way to remove soot, Mihelick says. “On a Final machine, you’ll be using the regeneration device much less. In fact, some machines will never have to regen.” Because of this, the soot gauge on the dash has been replaced with a DEF-level gauge. A warning system will issue progressive alerts if the DEF tank needs refilling. If the DEF level is too low, the engine will derate until the DEF tank is refilled.”
“SCR: The Leading Technology to Meet 2010 Emission Regulations”
Q: What is Selective Catalytic Reduction (SCR)?
A: SCR is a technology that uses a urea based diesel exhaust fluid (DEF) and a catalytic converter to significantly reduce oxides of nitrogen (NOx) emissions. SCR is the leading technology being used to meet 2010 emission regulations.
Q: How does an SCR system work?
A: The purpose of the SCR system is to reduce levels of NOx (oxides of nitrogen emitted from engines) that are harmful to our health and the environment. SCR is the aftertreatment technology that treats exhaust gas downstream of the engine. Small quantities of diesel exhaust fluid (DEF) are injected into the exhaust upstream of a catalyst, where it vaporizes and decomposes to form ammonia and carbon dioxide. The ammonia (NH3) is the desired product which in conjunction to the SCR catalyst, converts the NOx to harmless nitrogen (N2) and water (H2O).
Q: What is Diesel Exhaust Fluid (DEF)?
A: DEF is the reactant necessary for the functionality of the SCR system. It is a carefully blended aqueous urea solution of 32.5% high purity urea and 67.5% deionized water.
Q: What is urea?
A: Urea is a compound of nitrogen that turns to ammonia when heated. It is used in a variety of industries, including as a fertilizer in agriculture.
Q: How will I know that the DEF product I purchase will work?
A: The DEF you purchase should state and display the certification of the American Petroleum Institute (API), German Institute of Standardization DIN70700, the International Organization for Standardization ISO 22241-1, and meet AUS – 32 specifications. This will ensure the proper purity and concentration (32.5%) of urea. For more information on these specifications, visit www.iso.org.
Q: Can I make DEF myself?
A: OEM’s Cummins Filtration does not recommend customers make DEF themselves. DEF has strict requirements for maintaining concentration and purity of ingredients that is critical to the proper functioning and longevity of the SCR system. Cummins and other OEMs require that DEF used with their SCR systems meet all ISO22241 specifications as well as API certification requirements.
Q: Is the 32.5% urea solution critical?
A: Yes, The 32.5% urea concentration is the ideal solution as it provides the lowest freeze point. Also, SCR systems will be calibrated to the 32.5%, so that optimum NOx will be reduced during operation.
Q: What is the freeze point of DEF?
A: A 32.5% solution of DEF will begin to crystallize and freeze at 12 deg F (-11 deg C). At 32.5%, both the urea and water will freeze at the same rate, ensuring that as it thaws, the fluid does not become diluted, or over concentrated. The freezing and unthawing of DEF will not cause degradation of the product.
Q: Does DEF expand when frozen?
A: Yes, DEF expands by approximately 7% when frozen. DEF packaging and tanks are designed to allow for expansion.
Q: How much does DEF weigh?
A: DEF weighs approximately 9 pounds per gallon.
Q: How do I keep the DEF from freezing? What happens if the DEF freezes in the tank on the vehicle?
A: During vehicle operation, SCR systems are designed to provide heating for the DEF tank and supply lines. If DEF freezes when the vehicle is shut down, start up and normal operation of the vehicle will not be inhibited. The SCR heating system is designed to quickly return the DEF to liquid form and the operation of the vehicle will not be impacted. The freezing and unthawing of DEF will not cause degradation of the product.
Q: Can an anti-gelling or freeze point improver be added to the DEF to prevent it from freezing?
A: No. While an additive could improve freeze point of the mixture, the 32.5% solution is very specific to providing NOx reducing properties. Any further blending or adjusting of the DEF mixture will impede its ability to perform correctly and may cause damage to the SCR components. Additives of any type are not approved for use in DEF today. If the ISO standards should change to allow antifreeze additives, Cummins Filtration will ensure our product continues to meet ISO requirements.
Q: Are there special storage requirements for DEF?
A: DEF should be stored in a cool, dry, well-ventilated area, out of direct sunlight. While the optimum storage temperature is up to 77 deg F (25 deg C), temporary exposure to higher temperatures has little to no impact on the quality of DEF.
Q: What is the shelf life of DEF?
A: The shelf life of DEF is a function of ambient storage temperature. DEF will degrade over time depending on temperature and exposure to sun light. Expectations for shelf life as defined by ISO Spec 22241-3 are the minimum expectations for shelf life when stored at constant temperatures. If stored between 10 and 90 deg F, shelf life will easily be one year. If the maximum temperature does not exceed approximately 75 deg F for an extended period of time, the shelf life will be two years – “Cummins OEM Filtration Bulletin.”
“On a Cat Tier 4 Final machines, after a machine is turned off, an electric system purges DEF from all lines back into the tank, an operation invisible to the operator. In the unlikely event of a high-temperature shut down, the machine will automatically continue to idle in order to cool down the DEF to an acceptable shutdown temperature.” See Article: Marcia Gruver Doyle | November 08, 2013www.equipmentworld.com. {This is very concerning for a continuous use generator application – “says Randall Venerable” – specialized generator equipment rental company owner in Northern California}.
“CAT REGENERATION SYSTEM On-Road and Off-Rord Tier 4 final engines
The Cat Regeneration System is designed to work transparently, without any interaction needed from the operator. Under most operating conditions, engine exhaust is hot enough to oxidize soot through passive regeneration. If supplemental regeneration is needed, the Cat Regeneration System elevates exhaust gas temperatures to burn off soot in the Diesel Particulate Filter (DPF). This is a process that happens automatically, but the operator can initiate the cycle when convenient or interrupt regeneration as needed. A soot level monitor and regeneration indicator lights are integrated into the D7E dash display. Key Off Regeneration ? Optional Key Off Regeneration allows the operator to initiate a regeneration cycle after the key has been turned off. If a cycle takes place, the engine will complete regeneration, followed by a cool down period prior to shutting down. Delayed Engine Shutdown ? Delayed Engine Shutdown feature is available to allow the machine to cool immediately after a heavy work load or regeneration cycle. Engine Idle Shutdown Timer ? An optional Engine Idle Shutdown timer will sound a warning and shut down the engine after the machine has been idling for a pre-set period of time.”
PERSONAL REVIEW AND OPINION:
The current California Air Resourced Board (CARB) laws governing diesel engines .40CFR Part 89 & 1039 Federal and ABR Off-Road 13CCR2423-247 State of California, became effective for the Portable Equipment Registration Program (PERP) on September 17, 1997.
Unless all 50 states and our 2 providences are mandated to comply with the Federal Clean Air mandates consecutively, it is my considered opinion that the current (CARB) governing laws effectively place an unconstitutional financial burden on the backs of small and large businesses in California who have limited resources to meet the 2020 Tier 4 Final engine mandate; this without providing state financial assistance to all (PERP) Portable Equipment Registration Program diesel engine owners, allowing them to apply for low-interest loans to expense this emerging engine technology, technology that is still being tested.
Questions remain regarding if this technology will meet the specific needs of industries that require a diesel engine to drive equipment used in their for profit business operations. Being required to sell off older Tier 0, Tier 1, Tier 2 diesel engine equipment to another stated or countries, seems to me as a counterproductive method of passing the buck of what is considered as gross polluting diesel engine equipment to our neighbors next door. How does this help the stated goal of cleaning the air we breathe throughout the world we all must live in?
The above picture of a CAT Tier 4 final diesel engine design as displayed at a recent ARB class I attended located at the headquarters of Peterson Power (Peterson University- PU) in San Leandro CA, which is Caterpillar’s regional training facility, shows an engine design that increases the diesel engines physical footprint. Another question is if Tier 4 Final engine designs will meet the specialized requirements for the Film, Television and Special Event industry that requires sound attenuated enclosures and Tier 4 Final engine design that will not shutdown to regenerate to burn off soot build-up under low-load conditions.
“Performance issues related to low-loads will have a significant impact on generators reliability given the way that studio generators are typically used. We will not put our customers or their users in a position that compromises the dependability our products have become known for.
We are working diligently behind the scenes directly with the engine manufacturers and on our own to resolve all of the EPA related performance issues. And we will introduce studio generators employing the latest EPA Tier level engines when we are confident they can live up to the high quality standards that Multiquip demands”, says Larry Savitz Multquip Corporation – Director of Government Sales.
One of the many important takeaway notes I received from the ARB class I attended this week and during my research, is their will be no Tier 5-6-7 diesel engine requirements ad-infinitem, as the 2020 emissions standards deadline will have reached an OEM diesel engine technical design as close to zero emissions that you can get. The 2020 emissions standards end-goal is a reduction of “Particulate Matter (PM) [g/kW-hr] by 93 percent, and oxides of nitrogen (NOx) and hydrocarbon (HC) by 63 percent, compared with engines produced in 2000.”
I hope you find the above reading well-worth your time for review and study to gain a clearer understanding of the next generator of Tier 4 Final Diesel Engines and what should be all of our collaborative goals — to do our part to find solutions to help our Planet Earth Breath A Little Easier.
See the Youtube link for more information on Caterpillar’s Tier 4 Final Engine reveal:https://www.youtube.com/watch?v=qx2oGrgo-Cw
See EPA Facts & White Papers Links:
http://www.epa.gov/ttn/oarpg/t3/fact_sheets/rice_neshap_fs_021710.pdf
http://www.mtuonline.com/uploads/tx_templavoila/WhitePaper_Tier4i_and_Tier4.pdf
About the author
Founder, President and CEO of Generators Unlimited, Inc.