Emissions Regulations for Electric Power

1. Stationary Diesel Emissions
and EPA Tier 4 Final
Caterpillar Electric Power
Last updated: September 2016

2.  The following material represents an overview of regulatory requirements related to engine emissions
for Electric Power applications
 The material is intended for general informational purposes only
 The information is NOT COMPREHENSIVE and DOES NOT address specific manufacturers’
circumstances
 There is no substitute for reading and understanding the rules; companies are strongly encouraged to
investigate and apply the regulations accordingly
 Regulations may change, and these materials may not be updated to reflect the latest regulatory
revisions
 Companies relying on this information do so at their own risk and assume any liability for so doing
 The information IS NOT intended to be and should not be construed as legal advice or as a substitute
for competent legal advice
 Please consult your legal advisor if you have questions or need assistance
Notice

3. Basic Diesel Emissions
EPA Diesel Emissions Regulations
 EPA Emissions Regulations Changes
 EPA Tier 4 Final
 Product Changes
Application Considerations
 When does Tier 4 Final apply?
 Stationary Emergency Definition
 Important considerations
 Inducement Override
 Confusion in the Marketplace
 Specification Suggestions
Caterpillar Tier 4 Final Products
Summary
Overview

4.  Emissions Regulated by EPA Standards
 Carbon Monoxide (CO)
 Hydrocarbons (HC)
 Particulate Matter (PM)
 Oxides of Nitrogen (NOx)
 Emphasis is on NOx and PM
 Tradeoffs between NOx and PM, HC, and CO during combustion
 Higher temperatures/pressures – more efficient – more NOx
 Lower temperatures/pressures – less efficient – more PM, HC, and CO
Air Quality Basics

5. EPA Diesel Emissions Regulations

6.  This is what the majority of industry is thinking about when it talks about
“EPA” or “Tier 4” regulations
 Applies to non-road mobile machinery or on-road diesel powered
vehicles
 Includes a “flexibility program” for equipment OEMs
 Engines in stationary applications are regulated separately
EPA On-Road and Non-Road Regulations

7.  Introduced much later than non-road regulations, tier 1 did not take
effect until 2006.
 Shorter periods between regulation changes for the first 3 tiers.
 Different emissions regulations depending on application (emergency
or non-emergency)
 Cannot field certify/decertify to different emissions levels
 No “flexibility program” for OEMs in NSPS
 Averaging, Banking, and Trading (AB&T) credits could be used to
gain emissions certifications
EPA Stationary Regulations

8. EPA Emissions Regulations Changes
g/kW-hr OR g/kW-hr
bkW 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2008 2009 2011 2012 2013 2014 2015 2016
<8
10.5
8.0, 1.0
7.5
8.0, 0.402
>8
<19
9.5
6.6,
0.80
7.5
6.6, 0.40
4.7
5.5, 0.03
Option #1
4.7
5.0, 0.30
Option #1 4.7
5.0, 0.03
Option #2 4.7
5.0, 0.03
3.41
, 0.19
5.0, 0.02
0.40, 0.19
5.0, 0.02
3.41
, 0.19
5.0, 0.02
0.40, 0.19
5.0, 0.02
2.01
, 0.19
3.5, 0.02
0.40, 0.19
3.5, 0.02
2.01
, 0.19
3.5, 0.02
0.40, 0.19
3.5, 0.02
2.01
, 0.19
3.5, 0.02
0.40, 0.19
3.5, 0.02
3.5, 0.40
3.5, 0.10
0.67, 0.19
3.5, 0.03
0.67, 0.40
3.5, 0.10
0.67, 0.19
3.5, 0.03
0.67, 0.40
3.5, 0.10
0.67, 0.19
3.5, 0.03
6.4
3.5, 0.20
Fuel
Sulfur
Option #2
Tier 4 Interim Tier 4 Final
500 ppm
5000 ppm 15 ppm
4.7
5.0, 0.40
Emergency Applications Only
Emergency Applications Only
Emergency Applications Only
Emergency Applications Only
EPA Stationary Diesel Genset Emissions Limits and Timing (engines <10 litres per cylinder)
2007 2010
7.5
8.0, 0.80
7.5
6.6, 0.80
7.5
8.0, 0.603
7.5
5.5, 0.30
4.7
5.0, 0.40
9.2, 1.3
11.4,
0.54
4.0
3.5, 0.20
9.2, ----
----, ----
Tier 1 Tier 2
9.2, ----
----, ----
>2237
NOx, HC
CO, PM
NOx+HC
CO, PM
7.5
5.0, 0.40
>75
<130
9.5
5.5,
0.80
7.5
5.5, 0.60
9.2, 1.3
11.4,
0.54
2006
>19
<37
>37
<56
>56
<75
>130
<225
>225
<450
4.0
5.0, 0.30
Emergency Applications Only
4.0
3.5, 0.20
>300 hp
<750 hp
per CD
9.2, 1.3
11.4,
0.54
>560
<900
>900
<2237
>450
<560
9.2, 1.3
11.4,
0.54
9.2, 1.3
11.4,
0.54
9.2, 1.3
11.4,
0.54
6.4
3.5, 0.20
Emergency Applications Only
Tier 3
Emergency Applications Only
Emergency Applications Only
Emergency Applications Only
Emergency Applications Only
>560 bkW ≤900 Genset Applications
0
1.55
3.1
4.65
6.2
7.75
9.3
10.85
12.4
13.95
15.5
0 0.125 0.25 0.375 0.5 0.625 0.75 0.875
Tier 4 Final
Tier 4 Interim
Tier 2
Tier 1
Unregulated
2000
2006
NOx
+
HC
2011
2015
Particulates
>900 bkW Genset Applications
0
1.55
3.1
4.65
6.2
7.75
9.3
10.85
12.4
13.95
15.5
0 0.125 0.25 0.375 0.5 0.625 0.75 0.875
Tier 4 Final
Tier 4 Interim
Tier 2
Tier 1
Unregulated
NOx
+
HC
Particulates
2000
2006
2011
2015

9.  In the case of Tier 4 Finals, emissions levels are now so low that other technology solutions
are needed, including the use of aftertreatment devices. Tier 2/3 can usually be met without
aftertreatment.
 Emissions standards vary based on the power category
 Differing technologies available: DPF (PM), SCR (NOx), DOC (HC and CO), CEM (PM, NOx, HC, and CO)
 Optimum technology varies by power category
 Engine and aftertreatment must be certified as a complete system by manufacturer, No option
for field certification or decertification of new equipment
 The EPA certification process includes demonstration that no aftertreatment deterioration will
occur prior to 8000 hours of usage
 Reliant on introduction of ULSD (<15 ppm)
 Manufacturers may have credits to allow for Tier certification
 AB&T (Average Banking and Trading) credits
 Used to certify a product to a tier level
 Tier 4 Certified Generator sets subject to Inducement
 Shutdown if unit is not meeting emissions
 Recently introduced inducement override for emergency situations
Product Changes

10. Application Considerations

11.  Affects diesel generator sets in U.S. Minimum standard that must be met
(states/counties/cities can introduces stricter regulations)
 Stationary engines ≥10 liters/cylinder and <30 liters/cylinder must be
certified to Marine Tier 2 limits defined in 40 CFR 94 Subpart C.
 Regulations vary on use
 Stationary Emergency – Tier 2/3
 Mobile generators sets – move more than once in a 12 month period – Tier 4 Final
 Non-Emergency Stationary– Tier 4 Final
Application – When does Tier 4 Final apply?
Understanding the EPA emergency definition is critical

12. When Tier 4 Interim and Final were initially introduced, “Emergency”
effectively meant no running when normal power was available
 No limit to actual emergency running time (no normal power available)
 100 hours per year for testing and maintenance
 Unless local codes mandate other limits
 No allowances for other use (demand response, storm avoidance, peak shaving,
etc)
 Operator must record use and reference to hours meter
Note: 2010 through 2012, EPA has reviewed the allowances for non-emergency running of stationary emergency CI
engines. These changes are discussed in subsequent slides.
Original Emergency Definition

13. EPA rules continued to be amended up to 2015, allowing stationary emergency generator
sets to operate for limited periods under a wider range of non-emergency conditions.
 No limitation on actual run time (no normal power available)
 100 hours per year limit for non-emergency operation for stationary emergency gensets
 Site Testing and Maintenance
 Normal power frequency or voltage deviate 5% or greater below standard
 Up to 100 hours can be used for emergency demand response
 Transmission Authority Operator declared emergency
 Power created is provided only to the facility itself or to support the local transmission and distribution system
 Site can receive financial benefit
 Up to 50 hours per year:
 Can be used for storm avoidance (no voltage or frequency deviation from normal power)
 Cannot be used for peak shaving
 Counts towards 100 hours per year limit
 Operator must record use and reference to hours meter
May 2015 Emergency Definition
Updated May, 2015

14. In May 2015, US Court of Appeals overturned EPA’s rule allowing 100 hours of demand
response with emergency generator sets. Issues raised by the State of Delaware stated that
the EPA acted arbitrarily in modifying the NESHAP and NSPS standards for backup
generators/emergency engines and did not consult any authorities (such as FERC) before
adjusting regulation
 No limitation on actual run time (no normal power available)
 100 hours per year limit for non-emergency operation for stationary emergency gensets
 Site Testing and Maintenance
 Normal power frequency or voltage deviate 5% or greater below standard
 Up to 50 hours per year:
 Can be used for storm avoidance (no voltage or frequency deviation from normal power)
 Cannot be used for peak shaving
 Counts towards 100 hours per year limit
 Operator must record use and reference to hours meter
Emergency Definition – Latest Update
Updated September 2016
Regulations are constantly being adjusted, and need to be consulted every time

15. Application – Important Considerations
 Tier 4 Final certified generator sets will be required for the following applications:
 Non-emergency standby units, including demand response
 Prime Power applications
 Load management / peak shaving
 Mobile units (move more than once per year)
 EPA sets the minimum requirement for emergency and non-emergency generator set
emissions in the United States. State and local regulations may drive stricter emissions
requirements for emergency and/or non-emergency generator sets, requiring additional
aftertreatment.
 For non emergency use, only certified Tier 4 Final product can be used. Units cannot be field
certified to a different emissions levels
 Confusion drove EPA clarify with a letter on this: www3.epa.gov/ttn/atw/iceengines/imp.html
 Aftertreatment can be added to Tier 2/3 generators sets, however; they can still only be used for
Emergency use
 Tier 4 Final certified generator sets can be used for Stationary Emergency, newly added
inducement override make them a viable option when lower emissions are required or there is
interest in using the generator sets for demand response

16. Inducement Override
 Federal regulations require inducement shutdowns for Tier 4 Certified product
 Mandatory shutdown of generator set if it was not meeting emissions, even in emergency situations
 Could not be overridden or turned off
 Avoided using Tier 4 Certified product in life-safety/mission critical applications
 Introduced additional risk to site: significantly more points of failure
 For stricter requirements for emergency generators, utilized Tier 4 compliant systems – Tier 2 generator sets with 3rd
party aftertreatment
 Meant sites could not participate in demand response with emergency generator sets
 End users and manufacturers petitioned EPA for Inducement override
 Exists for On-Road and Non-Road EPA regulations
 In June 2016, EPA issued notice of inducement override allowance for stationary engines, effective 4Q2016
 Tier 4 Certified product is still subject to Inducement, however; Inducement can be overridden if
needed in emergency situations
 Manual override of 120 service hours.
 Timer can be reset by manufacturer or authorized dealers
 Units must meet EPA Tier 1 emissions levels while in override
 Site must log overrides and cause
 Inducement override can be retrofitted on existing Tier 4 generator sets
Less risk for using Tier 4 Certified equipment in life-safety/mission critical applications, opens the
door to using emergency equipment for demand response

17. Product Options – Federal Regulations
EPA Tier 2/3 Certified
 Can be used for Emergency Stationary applications, cannot be used for Non-Emergency
Stationary applications, even if aftertreatment is added to meet Tier 4 Final emissions levels.
 Unlimited hours allowed during an emergency (no normal power available)
 When normal power available: 100 hours maintenance and testing
 50 (of 100) for general use – Storm Avoidance
 No peak shaving or demand response
Tier 4 Final Certified
 Only equipment legal for non-emergency applications. Can be used in emergency applications
 Inducement override makes this an option for emergency stationary applications were lower
emissions are needed or where users want to participate in demand response programs.
 No limitation on run time with or without normal power available

18. Confusion in the Marketplace
With the upcoming emissions change, confusion is dominating the market
“Provide factory test reports including noise level and exhaust emissions showing compliance
with Tier 4”
“The unit that we quoted for this project is EPA Tier 4 compliant. It meets or exceeds the
standards set by the EPA for this application.”
“The unit is Verified to meet Clean Air Act Standards for 2015. A Verified unit has the ability to
run per local air permit approvals.”
Important to define what Tier (2, 3, 4 Final), and if it is being driven by local requirements
‘Compliant’ and ‘Verified’ product will meet federal requirements for non-emergency uses!

19. Emissions Specification Suggestions
The diesel engine generator shall be certified by the engine
manufacturer to the applicable EPA non-road mobile regulations
and/or the EPA NSPS rule for stationary reciprocating compression
ignition engines (Non-Emergency: Tier 4 Final Stationary Emergency:
Tier 2). Additionally, the engine generator shall comply with the State
Emission regulations based on the operating conditions. Actual engine
emissions values must be in compliance with applicable EPA
emissions standards per ISO 8178 – D2 Emissions Cycle at specified
ekW / bHP rating. EPA "Verified" or the proposal of EPA "Compliant"
engine generator sets are not acceptable. Manufacturer must provide
letter of conformity for the specified product.

20. Caterpillar Tier 4 Final Products

21. Caterpillar Stationary Tier 4 F Product
 C18, 500 ekW
 3516C-HD, 2000 ekW*
 3516C-HD, 2500 ekW*
 C175-16, 3000 ekW*
*Tier 4 Final PM requirements met with with AB&T Credits

22. Tier 4 Final – 2000 kW Example
Tier 4 Final Certified
 EPA Tier 4 final certified product
 No federal run hour limitation
 Can be used in standby, prime, and
continuous applications
 Engine will meet Tier 4 final outputs
 Units = g/ kW hr
 NOx = .67
 HC = .19
 CO = 3.5
 PM = .03
Tier 4 Final Certified with AB&T
 EPA Tier 4 final certified product
 No federal run hour limitation
 Can be used in standby, prime, and
continuous applications
 Engine will meet Tier 4 interim outputs
 Units = g/ kW hr
 NOx = .67
 HC = .19
 CO = 3.5
 PM = .10
 ABT credits get the PM to EPA Tier 4 final
levels

23. Summary
 EPA is the starting point… Understanding local requirements is vital
 Local or state emissions regulations for emergency and non-emergency
 Non-attainment areas
 Understanding if an installation falls within the EPA definition of “emergency” is
important. This definition is also a moving target.
 Non Emergency or demand response – must be a certified Tier 4 Final engine and
aftertreatment system from the manufacturer. Tier 2 units can not be field certified to
Tier 4. Tier 4 Final certified units cannot be de-certified
 Tier 4 final certified products are subject to inducement, but an inducement override is
allowed for emergency situations
 Local regulations requiring Tier 4 Final emissions may be able to be met with ‘compliant’
product, using separate aftertreatment systems, however; cannot be used in demand
response
EPA Stationary ICE website: https://www3.epa.gov/ttn/atw/icengines/

24. Thank You