Understanding the Impact of January 1, 2011Emission Regulations on Power GenerationProducts and Customer Use.

Lunch and Learn

February 11, 2011

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Cummins’ Commitment

Rich Freeland, Engine Business Director August 18, 2010:

“Our product introduction teams have maintained the Cummins reputation for meeting the emissions standards on time, every time, and our manufacturing and supplier partners were ready on January 1, 2010.”

“We will stay focused on delivering the Cummins value package to customers, on working with regulators on tough, fair and enforceable standards and on continuing to deliver the right technology, on time, every time.”

Cummins Power Generation products were ready on January 1, 2011 as the EPA laws for the power generation market were effective.

The EPA Law

EPA New Source Performance Standards (NSPS) for Stationary CI Engines, Part 60, Subpart IIII

60.4219 What definitions apply to this subpart?

Emergency stationary internal combustion engine means any stationary internal combustion engine where operation is limited to emergency situations and required testing and maintenance. Examples include stationary ICE used to produce power for critical networks or equipment (including power supplied to portions of a facility) when electric power from the local utility (or the normal power source, if the facility runs on its own power production) is interrupted, or stationary ICE used to pump water in the case of fire or flood, etc. Stationary CI ICE used to supply power to an electric grid or that supply power as part of a financial arrangement with another entity are not considered to be emergency engines.

http://www.epa.gov/ttn/oarpg/new.html

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EPA New Source Performance Standards (NSPS) for Stationary CI Engines, Part 60, Subpart IIII

The EPA law defines actual product use by the End User:

– Stationary Emergency

All other use not considered emergency can be classified as:

– Stationary Non-emergency

– Nonroad Mobile

The EPA law is directed to actual site application and does not address traditional industry application descriptions found in ISO, NEC, NFPA and other reference agencies.

The January 1, 2011 law affects usage type AND varies in tier requirements by engine horsepower.

The EPA law compliance is the responsibility of the Engine Manufacturer and the End User is responsible to use the product as it is intended.

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Nomenclature – EPA Terminology Power Generation Classification: Nonroad Mobile (subject to higher emission standards)

Portable (rental, trailorized, etc.) – Must comply with T4/T4i standards or utilize Transitioned Program for Equipment Manufacturers (TPEM)

Portables move once a year

Cannot mount designated stationary emergency generator on a trailer or mobilize in any way

Federal laws prohibits the use of TPEM-certified products in stationary emergency and stationary non-emergency applications

Cummins use of TPEM is defined under separate policy; consult your BDM for information

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Stationary Non-emergencyPeak shaving (reduce or flatten peak electricity use)

Stationary Non-emergencyRate curtailment (favorable energy rates)

Stationary Non-emergencyInterruptible rate programs (favorable energy rates)

Stationary Non-emergencyContinuous base load (const. power to utility grid)

Stationary Non-emergencyCo-generation (capture and use waste heat)

Stationary Non-emergency

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Prime Power rated generator set (to be used as aprimary source of power)

Nomenclature – EPA Terminology Power Generation Classification: Stationary Emergency

Emergency standby (safe evacuation, life support) – Stationary Emergency

Legally required standby (fire-fighting operations) – Stationary Emergency

Optional standby (could cause an economic loss) – Stationary Emergency

Prime power rated generator set (at loss of utility electricity supply) – Stationary Emergency

EPA does not allow a stationary emergency engine to be used in a mobile application where it does not remain stationary for 12 months

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CI NSPS Stationary Emissions

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U.S. EPA NOx / HC2 / CO / PM (g/kW-hr)

Engine Power (NOx+NMHC) / CO / PM (g/kW-hr) [Conversion: (g/kW-hr) x 0.7457 = g/bhp-hr]

( 4.0 ) / 3.5 / 0.20 Emergency

Notes:

1. All standards are based upon ISO 8178 C1 8-mode test for variable-speed engines and D2 5-mode test for constant-speed engines. Transient testrequired beginning in 2011 for Tier 4 and Stage IIIB.

2. Separate NOx and HC standards separated by a "/". Combined NOx and NMHC standards denoted in parenthesis "( )". Tier 4, Stage IIIB, and Stage IV are NMHC limits.

3. For U.S. Tier 4, "Split-family" standards are show n above for 56 - 560kW. Optional "Phase-in" and "Phase-out" standards for NOx are permitted by EPA.4. For U.S.Tier 4, optional 0.30 g/kW-hr PM standard for engines 37-55kW in 2008. Selecting this option allow s a 1 year delay of Tier 4 Final implementation

(HP)

(>3000)

(1208 - 3000)

(752 - 1207)

(174 - 751)

(100 - 173)

(75 - 99)

(49 - 74)

(0 - 24)

(25 - 48)

( 4.0 ) / 3.5 / 0.20

( 4.0 ) / 5.0 / 0.30( 4.0 ) / 5.0 / 0.30 Emergency

( 4.7 ) / 5.0 / 0.40 Emergency

( 4.7 ) / 5.0 / 0.40 Emergency

( 4.7 ) / 5.0 / 0.40

( 4.7 ) / 5.0 / 0.40

0.40 / 0.19 / 5.0 / 0.023.4/0.19/5.0/0.02

2013

0.40 / 0.19 / 5.0 / 0.02

Tier 4 FinalTier 4 InterimTier 3Tier 2

2011

0.67 / 0.40 / 3.5 / 0.10 0.67/ 0.19/ 3.5/ 0.03

0.67 / 0.40 / 3.5 / 0.10

2014 2015

( 7.5 ) / 5.5 / 0.30 Emergency

0.67/ 0.19/ 3.5/ 0.03

( 4.7 ) / 5.0 / 0.03

( 6.4 ) / 3.5 / 0.20

0.40 / 0.19 / 3.5 / 0.02

3.5 / 0.40 / 3.5 / 0.10

2008 2009 2010

( 4.7 ) / 5.0 / 0.03

2016 2017

( 7.5 ) / 6.6 / 0.40

2012

( 7.5 ) / 5.5 / 0.30

( 6.4 ) / 3.5 / 0.20 Emergency

3.4/0.19/5.0/0.02

2.0 / 0.19 / 3.5 / 0.02

Tier 1

9.2 / 1.3 / 11.4 / 0.54( 6.4 ) / 3.5 / 0.20 Emergency

( 6.4 ) / 3.5 / 0.20( 6.4 ) / 3.5 / 0.20 Emergency

0.67/ 0.19/ 3.5/ 0.03

• Areas that do not meet EPA National Ambient Air Quality Standards (NAAQS) 40 CFR Part 50 for ozone and particulate matter are called “non-attainment areas.”

• A diesel generator used in or transported to non-attainment areas may be required to meet more stringent air regulations.

• Non-attainment areas include California, Houston (TX), Atlanta, Chicago, and Boston.

EPA Emissions: Non-Attainment Areas

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EPA National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating Internal Combustion Engines (RICE)

Law defines Existing Stationary Engines as those built prior to NSPS effective date, June 2006

Existing engines must be in compliance by May 2013

188 total chemicals deemed hazardous air pollutants

– Formaldehyde, acrolein, methanol, and acetaldehyde from IC engines (primarily from lean-burn gas)

Primary focus is formaldehyde (HCHO)

– Higher levels than all others combined

– Sometimes represented by surrogate, usually CO

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RICE NESHAP Requirements

  HPMajor Source: PTE > 10 tpy of single HAP or > 25 tpy combined HAPS.

Area Source: any source that is not a major source.

< 500 HP

New/Reconstructed Engines: Must meet NSPS 250-500 HP 4SLB must also meet RICE MACT rule

Existing CI Non-emergency Engines: Minimize Start-up Time: ● 0-99 HP - Work practices ● 100- 299 HP - 230 ppm Co ● 300 - 500 HP - 49ppm CO or 70% reduction Work Practices, Crankcase Ventilation, USLD Existing CI Emergency Engines: 0- 49 HP - Work Practices

New/Reconstructed Engines: Must meet NSPS; finalized 1/18/08

Existing CI Non-emergency Engines: Minimize Start-up Time: ● 0-99 HP - Work practices ● 100 - 299 HP - Work Practices ● 300 - 500 HP - 49ppm CO or 70% reduction Work Practices, Crankcase Ventilation, USLD

Existing CI Emergency Engines: 0- 49 HP - Work practices

> 500 HP

New/Reconstructed Engines: RICE MACT rule finalized 1/18/08 Existing CI Non-emergency Engines: 23 ppm CO or 70% reduction, Work Practices, minimize start-up time, crankcase ventilation, ULSD, operating requirements Existing CI Emergency Engines: Work practices, minimize start-up time

New/Reconstructed Engines: Must meet NSPS; finalized 1/18/08 Existing CI Non-emergency Engines: 23 ppm CO or 70% reduction, Work Practices, minimize start-up time, crankcase ventilation, ULSD, operating requirements Existing CI Emergency Engines: Work practices, minimize start-up time

EPA – RICE NESHAP designated use:Stationary Emergency

40 CFR 63.6640(f) published in August 2010

– Unlimited use during emergencies

– Maximum 100hr/yr for maintenance and testing

50hrs/year of Non-emergency operation allowed as part of the 100hr/yr

15hrs/year of operation allowed for demand response as part of the 50hrs/yr

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Evolution of EPA Off-Highway Emission Standards (>751 HP) Excludes Stationary Emergency

2000 Tier 1

2006 Tier 2

2011 Tier 4i (751 – 1207 HP)

2011 Tier 4i (>1207 HP)

2015 Tier 4f (>751 HP)

Off-Highway

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T2, T3,T4 Interim vs T4 Final

EPA Requirements (350 kW and above)

EPA Prime Power Requirements (300 kW and below)

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(gm/kw-hr)Tier 3 (2010)

Tier 4i (2011)

T4 (2015) Reduction

NOx+HC 4 2.19 0.4 90%Particulates 0.2 0.02 0.02 90%

(gm/kw-hr)Tier 2 (2010)

Tier 4i (2011)

T4 (2015) Reduction

NOx+HC 6.4 1.07 1.07 83%Particulates 2.0 1.0 0.03 98%

Federal EPA Emissions Measurement*

*Local requirement measurement method may be different.

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After-treatment

High Pressure Fuel Systems

Advanced TurbochargingEngine Filtration

Controls and Algorithms

Combustion

Emission Solutions

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Emission Control OptionsEmission Control Options

Diesel oxidation catalyst (DOC)

Catalyzed soot filter

Active regenerating filter

CRT

Miller Cycle

EGR

Lean NOx

Lean NOx + HC

Plasma-assisted lean NOx

NOx adsorber

Selective catalytic reduction (SCR)

Diesel oxidation catalyst (DOC)

Catalyzed soot filter

Active regenerating filter

CRT

Miller Cycle

EGR

Lean NOx

Lean NOx + HC

Plasma-assisted lean NOx

NOx adsorber

Selective catalytic reduction (SCR)

NOxNOx

Exhaust and Emission Control SystemsExhaust and Emission Control Systems

PMPM

RED: Most commonly usedRED: Most commonly used

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Which DPF to Choose?

Cummins Emissions Solutions

Cleaire Emission Controls

Miratech

Johnson Matthey

Harco

Rypos

GT Exhaust

CleanAir Systems

Universal

All offer > 85% PM reduction19

Advanced In-cylinder Technology

1. New modular common rail fuel system

2. New advanced engine monitoring

3. New high-efficiency fuel pump

4. New engine control modules with 3X faster processing power

5. High durability piston/power cylinder

Diesel Engine Technology

Advanced Fuel Systems Technology

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Examples of Changes to Engine Design for Reduced Emissions

New combustion bowl geometry for optimum combustion

Multiple fuel injection capabilities that provide more combustion control and better part load performance in terms of emissions and fuel consumption, without sacrificing power

Advanced fuel injection systems

Solenoid-controlled electronic injectors for precise fuel delivery

New engine control modules with improved sensors, which control engine operating parameters more precisely and are critical to maximizing power output

High-durability ferrous cast ductile pistons, which are stronger than aluminum, especially when operating at higher temperatures. They help deliver optimal power output.

Cooled exhaust gas recirculation (CEGR), which recycles a part of the exhaust to lower combustion chamber temperatures and reduce emissions at part loads

Variable geometry turbocharger, which gives precise control of airflow at all engine speeds and loads

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Tier 4 Interim Architecture − Example

Engine HP (100−600 kW range)

CEGR for NOx reduction

Regenerating particulate filter (DPF) for PM reduction

Direct Flow Air Cleaner

TBAP Sensor

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TailpipeExhaust

Diesel Oxidation Catalyst Diesel Particulate Filter

DOC catalytic material reacts above 572ºF (300ºC) in passive regeneration mode to generate Nitrogen Dioxide (NO2) which oxidizes the carbon soot

Ceramic wall flow filter captures up to 95% of the carbon soot (PM) carried by the NO2. This collects on the filter to form Carbon Dioxide (CO2 ) which leaves the tailpipe as clean gas

Build up of incombustible ash will eventually require filter service cleaning, though only required at very long intervals

When soot accumulation in the DPF exceeds soot oxidation a periodic active regeneration mode is performed to prevent filter plugging. This is actuated by small quantities of fuel from a dosing injector or HPCR injection pulse during exhaust blow down. The heat released (no flame or burning) at 1022ºF( 550ºC) ensures sufficient oxidation to remove soot

Active Regeneration Filter Service

How the Diesel Particulate Filter (DPF) Works

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SCR Catalyst

Urea

Urea Tank

Urea Injector

Tank Heater

Exhaust Tailpipe

Dosing Unit (pump, metering, filter)

Urea solution is injected ahead of the catalyst. This converts to ammonia in the exhaust stream above 392ºF (200ºC).

The ammonia reacts with Oxides of Nitrogen (NOx) over the SCR catalyst to form harmless nitrogen & water.

Urea is injected at a ratio of typically 5% to diesel fuel use, depending on duty cycle. Urea tank sizes vary, but must be refilled to ensure emissions compliance.

Selective Catalytic Reduction

The urea-water solution (AdBlue in Europe) is a clear liquid, non-hazardous and non-flammable with a 12-month shelf life. Heaters are required to prevent urea freezing at 11ºF (-11ºC).

Urea Solution

How SCR Works

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Tu

rbo

Aft

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Co

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Tier 4 Interim and Final: After-Treatment for Cummins Diesel Generator Sets

DEF Pump

DEF

Diesel Exhaust Fluid Tank

Turbo

Air Filter

DOC SCRCatalyst

ElectricHeater

Cummins Diesel Engine

Exhaust

Control Panel

Generator

Heater Control

NOx Sensing

Temp Sensing

Level Sensing

Pressure Sensing

DOC reduces

PM 10−20%

SCR reduces NOx 90%

Precise DPF and SCR

Temperature Control

DPF

DPF reduces PM 90%

DEF Injector

Standard Cummins Diesel Generator Set

Mixing

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Particulate Filter Access

DEF Injector

Exhaust Heater Load Bank

SCR Catalyst Access

Exhaust Inlet

DEF Tank (5% of fuel capacity)26

Dual System for 1250 kW and Larger Units

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750−1000 kW with Single T4 Unit on CPG Housing

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T4 System for QSK50-60 1500−2250 kW

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The Deal with After-Treatment

Expensive SCR systems can add 20−50% to the cost of the generator.

Increased space requirement and installation costs related to after-treatment component type and design. Individual systems are required for each individual engine-driven product.

Space and power requirements for devices such as compressors and heaters must be considered as some SCR products utilize these to insure effective chemical action.

Increased system air flow must be accommodated due to larger cooling systems and increased heat rejection to the room or enclosure.

After-treatment can take up considerable real estate and is very sensitive to packaging and mounting location constraints.

Some systems increase back pressure in exhaust system causing possible derating.

Associated maintenance with SCR and related devices must be considered.

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The Deal with After-Treatment (Continued)

System operation logs must be maintained.

Handling additional chemicals, DEF– Storage tank– Consistency assurance– Refill costs

Introduce additional points of failure in an emergency systems.

Some systems meet only T4i and not final T4 levels requiring upgrade in just 4 years.

Load factors affect SCR effectiveness.

Exercise with engine load may be recommended, complicating exercise timing affecting facility operation or further complicating SCR system complexity.

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Installation and Application

Stationary Non-emergency engines meeting previous EPA regulations built on or before December 31, 2010, must be installed within a two-year period.

Installed means the engine is placed and secured at the location where it is intended to be operated; piping and wiring for exhaust, fuel, controls, etc., is installed and all connections are made; and the engine is capable of being started. 

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Open Generator Set with SCR

Snow Summit: (2) 2 MW units with JM SCRTs

Lehigh Cement: (5) CAT 1500 kW w/ DPFs

Chevron: (8) DPFs on various size pumps/compressorsCalifornia Water Svc: SCR on a 1250 kW

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Require certifications in accordance with all federal, state and local emissions regulations at the time of order

Be aware of the impact of manufacturing vs. shipping dates

At many ratings, multiple generator models of different configurations are available; some use EPA-certified engines, some do not.

Clearly define generator application duty

Your local Cummins Power Generation distributor can help you identify any generator emissions-related components that would be required in your area.

Suggested Specification Criteria

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Thank You.

For additional information,

visit our Emissions webpage:

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cumminspower.com/en/about/environmental/emissions/