Emissions Overview

2010 Regional Sales

Product Training
US EPA Emission Regulation Overview
• This presentation is an overview of our
understanding of U.S. emissions regulations – not a
legal interpretation.

• Emissions regulations are complex and always

subject to change. Please make sure to obtain your
own legal interpretation.

• You can obtain emissions information documents at

this website;
http://www.epa.gov

February 2012 2
 US EPA Terminology

February 2012 3
 US EPA Emission Regulations Overview
40 CFR 60 NSPS - New Source Performance Standards (New Stationary Products)

  Subpart Engine Type Rule Published Effectivity Date

IIII CI-Compression Ignition (Diesel) 7/11/2006 1/1/2007
JJJJ SI-Spark Ignited (Gas) 1/18/2008 1/1/2009

40 CFR 9 Non-Road Mobile (Compression Ignition Trailerized Products)

    Engine Type Rule Published Effectivity Date

CI-Compression Ignition (Diesel) 8/27/1994 1/1/1996

40 CFR 63 NESHAP - National Emissions Standards for Hazardous Air Pollutants

(Existing Stationary Engine Installations Made Prior To January 1, 2007)

  Subpart Engine Type Rule Published Effectivity Date

ZZZZ CI-Compression Ignition (Diesel) 2/17/2010 5/3/2013
ZZZZ SI-Spark Ignited (Gas) 8/10/2010 5/3/2013

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 US EPA NSPS
Stationary Diesel Emissions

2010 Regional Sales

Product Training
 US EPA NSPS Stationary Emergency Definition

The EPA has changed the way the power generation

industry applies generator ratings. We must think about
the application of the generator rather than just the rating.

• Stationary
– The generator will remain in one location for >12 months

• Emergency
– The generator is a secondary power source to the primary (utility)
– The generator usage is unlimited when a utility failure occurs
– Maintenance and readiness testing is limited to 100 hours/year, but the EPA
can be petitioned when local regulations require more hours
– Owner/operators must maintain records & have them available for inspection
– The majority of applications will require a standby rating, however,
applications that require a 10% overload and meet the definitions above can
be prime rated

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US EPA NSPS Stationary Amendments
Diesel and Gas powered stationary emergency generator set rule
clarifications (EPA-HQ-OAR-2010-0295)
Key Notes:
• 100 hours runtime allowed:
– 50 hours maintenance & readiness testing
– 50 hours of non-emergency situations
– Cannot be used for peak shaving or to generate income for a
facility to supply power to an electric grid or otherwise supply
power as part of a financial arrangement with another entity
– Exception; owners and operators may operate the emergency
engine for a maximum of 15 hours per year as part of a “demand
response” program if the regional transmission organization or
equivalent balancing authority and transmission operator has
determined there are emergency conditions that could lead to a
potential electrical blackout

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US EPA NSPS Stationary Amendments
Key Notes (cont’d):
• Clarification to what a reconstructed engine is:
– The fixed capital cost of the new and refurbished
components exceeds 50 percent of the fixed capital cost of
a comparable new engine; or
– The crankshaft is removed as part of the reconstruction; or
– The serial number of the engine is removed as part of the
reconstruction; or
– The reconstructed engine consists of a previously used
engine block with all new components.

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 US EPA NSPS Stationary Emergency Diesel Regulations

ENGINE GENERATOR
kWm kWe 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016
8 - <19 10-15 6.6/7.5/0.40
19 - <37 15-20 5.5/7.5/0.30

37 - <56 20-40 5.0/4.7/0.40

56 - <75 40-60 5.0/4.7/0.40

75 - <130 80-100 5.0/4.0/0.30

130 - <560 125-450 3.5/4.0/0.20

560 - <900 500-800 3.5/6.4/0.20

>900 900-2000 3.5/6.4/0.20

>2200 >=2000 11.4/1.3/9.2/.54 3.5/6.4/0.20

TIER 1 EFFECTIVE
CO/HC/NOx/PM (g/kW-hr) TIER 2 EFFECTIVE TIER 4 INTERIM EFFECTIVE
CO/NMHC+NOx/PM (g/kW-hr) TIER 3 EFFECTIVE TIER 4 FINAL EFFECTIVE

Stationary emergency regulations have not changed since 2008, and will not change in the foreseeable future

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 US EPA NSPS Stationary Non-Emergency Diesel

• Stationary
– The generator is in one location for 12 months or longer

• Non-Emergency
– The generator operates as the primary source of power;
OR, the generator is a secondary power source to the utility,
and will be used for peak shaving, interruptible rate, or any
use that generates income for a facility by supplying power
to the electric grid.
– Owner/operators must maintain records & have them
available for inspection
– The generator may have a prime or continuous rating.
Refer to TIB-101 for ratings definitions and sizing guidelines.

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 US EPA NSPS Stationary Non-Emergency Diesel
• Diesel engines used in non-emergency applications 40kWe and greater
will require after-treatment which must be supplied by the
manufacturer of record (certified).

• Engine after-treatment cannot be added at the site for compliance on

new engines. After-treatment can only be added in the field to
existing engines.

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 US EPA NSPS Stationary Non-Emergency Diesel

ENGINE GENERATOR
kWm kWe 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016
8 - <19 10-15 6.6/7.5/0.40
19 - <37 15-20 5.5/7.5/0.30 5.5/4.7/0.03

37 - <56 20-40 5.0/4.7/0.30 5.0/4.7/0.03

56 - <75 40-60 5.0/4.7/0.40 5.0/2.3/0.02 5.0/0.19/0.40/0.02

75 - <130 80-100 5.0/4.0/0.30 5.0/2.3/0.02 5.0/0.19/0.40/0.02

130 - <560 125-450 3.5/4.0/0.20 3.5/2.0/0.02 3.5/0.19/0.40/0.02

560 - <900 500-800 3.5/6.4/0.20 3.5/0.40/0.67/0.10 3.5/0.19/0.67/0.03

>900 900-2000 3.5/6.4/0.20 3.5/0.40/0.67/0.10 3.5/0.19/0.67/0.03

>2200 >=2000 11.4/1.3/9.2/0.54 3.5/0.40/0.67/0.10 3.5/0.19/0.67/0.03

TIER 1 EFFECTIVE
CO/NMHC+NOx/PM (g/kW-hr) TIER 2 EFFECTIVE TIER 4 INTERIM EFFECTIVE
CO/NMHC/NOx/PM (g/kW-hr) TIER 3 EFFECTIVE TIER 4 EFFECTIVE

2012: 40-100kWe require Tier 4i (2011 engines must install by 12/31/2013)

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US EPA NESHAP
Existing Source Emissions

2010 Regional Sales

Product Training
 NESHAP – EPA Existing Source Emissions
Covers previously installed Diesel and Gas Non-Emergency stationary gensets

• Major sources of air toxics emissions: “Major sources” of air toxics are defined as those
sources that emit 10 short tons per year of a single air toxic or 25 short tons per year of
a mixture of air toxics.
– Engines ≤ 500 hp constructed or reconstructed before June 12, 2006.
– Engines > 500 hp constructed or reconstructed before Dec. 19, 2002.

• Area sources of air toxics emissions: “Area sources” are those sources that are not
“major sources”
– Engines constructed or reconstructed before June 12, 2006

• Emission reduction completion required by May 2013

• Owners/ Operators will be required to;

• Reduce emissions with catalysts and diesel particulate filters
• Perform an emissions test to demonstrate compliance
• OR use only as an emergency application

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 NESHAP – EPA Existing Source Emissions

Chart Courtesy of Melanie King (EPA) - Spring 2011 EGSA Conference

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 NESHAP – EPA Existing Source Emissions

Chart Courtesy of Melanie King (EPA) - Spring 2011 EGSA Conference

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 NESHAP – EPA Existing Source Emissions
• This is an opportunity for you to provide a service to an
existing customer.
• A review of the total financial picture will be needed.
• Is the application truly a non-emergency application?
• Is there a utility agreement in place? If so, do the utility
agreements savings have a payback for the end
customer?
• You will need to establish a relationship with a third
party after-treatment supplier.
February 2012 17
 NESHAP – EPA Existing Source Emissions
Third party after-treatment suppliers:

• GT Exhaust
• Sud Chemie
• Bergari Solutions
• Miratech
• Johnson Matthey
• DCL International

February 2012 18
CALIFORNIA EMISSIONS

2010 Regional Sales

Product Training
 CARB Diesel Regulations
• Local air management districts
may require lower emission
levels than the U.S. EPA
• CARB harmonized with EPA
– Except for stationary
emergency PM (0.15 g/hp-
hr),
– All Kohler Power Systems
current models meet this
PM requirement

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SCAQMD Rule 1470 Diesel Regulations
Public Hearing, March 2, 2012

Courtesy of Lori Moore AQMD

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SCAQMD Rule 1470 Diesel Regulations

Courtesy of Lori Moore AQMD

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SCAQMD Rule 1470 Diesel Regulations

(125REOZJG and above)

Courtesy of Lori Moore AQMD

February 2012 23
SCAQMD Rule 1470 Diesel Regulations
“A sensitive receptor is a person in the population
who is particularly susceptible to health effects due
to exposure to an air contaminant. The following
are land uses (sensitive sites) where sensitive
receptors are typically located:
•Schools, playgrounds, and child care centers
•Hospitals and Long-term health care facilities
•Rehabilitation centers
•Convalescent centers
•Retirement homes
•Residences”
Courtesy of AQMD Guidance Document Chapter 2 Air Quality Issues Regarding Land Use

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SCAQMD Rule 1470 Diesel Regulations

(100REOZJF and below)

(500REOZJ/ 500REOZVC and above)

Courtesy of Lori Moore AQMD

February 2012 25
SCAQMD Rule 1470 Diesel Regulations

Courtesy of Lori Moore AQMD

February 2012 26
 US EPA
Stationary Gaseous Emissions

2010 Regional Sales

Product Training
 US EPA NSPS – Stationary Gas Emissions
• EPA Definitions
– EPA Certified: Engine manufacturer (or Manufacturer of Record) has
submitted data and received certification paperwork from the EPA.
– EPA Compliant: Emissions meet EPA standards, but is not EPA certified.
Site certification is required by the owner/ operator, and may be subject
to additional testing and maintenance requirements.

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 US EPA NSPS – Stationary Gas Emissions
• Engine Manufacturer Certification
– Required for Rich Burn LPG engines
– Voluntary for all Natural Gas engines and Lean Burn LPG
• Owner/ Operator Certification - Possible for NG and Lean Burn LPG
• Site Certification Requirements:

• All NG/ LP engines used in KOHLER generators are EPA certified rich burn
• Site certification can cost the owner thousands of dollars plus annual
maintenance and verification tests.

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 US EPA NSPS – Stationary Gas Emissions

• There is a less restrictive EPA requirement (Small Off Road Engine (SORE) 40 CFR
90) for 15-75 kWe models
• The >80kWe models have a more stringent requirement (40 CFR 1048)
• Even more stringent standards for non-emergency natural gas
– 60-300kWe, Jan 1, 2011
– 300-810kWe, July 1, 2010

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KOHLER Product Summary - Emissions
• Stationary, Emergency
– 10-3250kW Diesel and 25-400kW Gas – EPA certified to
existing regulations

• Stationary, Non-Emergency
– Diesel 10-30kW
• Complete to Tier 4i/ 4 regulations

– Gas 180-400kW
• Complete to existing (NG only) and also meets non-
road standard

• Non-Road Mobile Diesel

– 20-40kW Tier 4i
– 60-500kW TPEM

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Non-Road Mobile Regulations
Towable Emissions

2010 Regional Sales

Product Training
 US EPA Non-Road Definition
• Non-Road (towable/rental)
– The generator is run in more than one location in a 12 month period
(transportable)
– Similar emission levels to stationary non-emergency (Tier 4i/f are the same)
– The generator may have a standby, prime or continuous rating.
ENGINE GENERATOR
kWm kWe 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
8 - <19 10-15
19 - <37 15-20
37 - <56 20-40
56 - <75 40-60
75 - <130 80-100
130 - <225 125-200
225 - <450 250-350
450 - <560 400-450
>560 500-3250

TIER 1 EFFECTIVE TIER 2 EFFECTIVE TIER 4 INTERIM EFFECTIVE

TIER 3 EFFECTIVE TIER 4 EFFECTIVE

• Alternative to Tier 4i/4

– Transition Program for Equipment Manufacturers (TPEM)
– This program is often referred to as “flexibility” under 40 CFR 1039.625

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 US EPA Non-Road Mobile Emissions

• OEM Flexibility TPEM (Transition Program for Equipment

Manufacturers)
– Can use current tier product during a transition period up to 7
years
– Applies only to non-road mobile

• Customer Constructed Mobile Units

– Stationary generator sets used in non-road mobile applications will
no longer meet EPA regulations

• Program to help smooth the transition of product development

through Tier 4 Final

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 TPEM Program
• Equipment manufacturers are allowed to produce a limited number of
non-road equipment with exempted engines (credits/flexibility)
• Kohler & SDMO flexibility is based on
– Small Volume Allowance
– Multiple engine families

• KPS and SDMO are considered as one company/equipment

manufacturer and must share credits under this program

• Total shipment volumes must be reported to the EPA

February 2012 35