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Diesel emissions in surface work environments

MTI Mark

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May 11, 2011
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Northern New York
I am curious, with all the emission talks for new vehicles, do they affect any of you guys working in surface environments such as general construction, road construction, surface quarries, and such. Specifically diesel emissions. I believe MSHA has jurisdiction over surface mines (quarries), but not sure if they have any emission regulations in regards them. Does OSHA regulate non-mining sites such a construction sites where heavy equipment is used, as far as diesel emissions are concerned?

Underground is regulated quite heavily by MSHA and getting stricter every year, especially with relation to DPM (diesel particulate matter). I am constantly reading about Tier4 interim on surface equipment, which is what peeked my interest to ask the question. Maybe it is just progressive emission laws that heavy equipment manufacturers are supposed to meet over time?
 

rare ss

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we don't have any new emission changes relating to off-highway surface-equipment only the new euro5 rules governing on-highway vehicles which came in with 2011 plated vehicles but we came still import euro3 on-highway vehicles provided they are never driven on a public road (big fines)
 

John C.

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Both MSHA and OSHA are safety regulations agencies and don't have any control over emissions unless they relate to safety. All the emissions regulations are based at the federal level and run by EPA. Off highway regulations began in 1996 in a fashion tiered by horsepower output. At this time we are in Tier 4 Interim. Tier 4 Final begins in 2014. So far all these regulations only apply to the manufacturer levels, they only affect end users as they buy new engines or equipment. You don't have to test your machine for emissions. That may change in the future. Basically the year of manufacture determines the level of pollution your engine can emit.

The big issue with the regulations is what is the new technology going to add in cost and what is it going to take to keep these complicated systems working properly. I haven't heard a lot yet about Tier 4 Interim engines having huge issues except for the extra costs at purchase. Only time will tell on how it works.

My question and concern is what is going to happen to the machines and engines that are old enough to not be covered under the tier system. Does this mean that you will not be able to run an engine built before 1996? Will you be able to buy parts for any of the old motors? Will you be required to scrap out the old machines? So far no one is saying anything.
 

Newman

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AZ
What's to keep people from disabling emissions like they are doing with the new diesel pick up trucks?
 

rare ss

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What's to keep people from disabling emissions like they are doing with the new diesel pick up trucks?

around Europe the trucks get inspected and downloaded on the side of the road resulting in big fines for non-compliance, major fleet companies also have all their trucks on a fleet management system which flags faults and operator abuse, if your operator/s doesnt fill the AdBlue tank or fills it with distilled water (to stop the truck going into limp mode) the O2 sensor flags a fault and its logged onto the system, the aurthories also have the right to access these systems also do check against non-compliance

This is comming worldwide, its just a matter of when its rolled out, we just got euro5 in Oz, euro6 is happening now in Germany i think its rolling out here in 2014
 

John C.

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The stuff I've seen is set up so that if something is wrong it will reduce horsepower output or just quit working. It's not like the seventies when you could just unplug all the crap the EPA forced the manufacturers to put on.

The other side of this is the states wanting to get on board with enforcement and putting together the smoke police. You get enough companies trying to pull the stuff off the machines and that will create a monetary incentive for the states to create what are known as stupid taxes. Do something stupid and they will collect the tax from you.
 

MTI Mark

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Northern New York
So the EPA actually comes up with the Tier specs then. MSHA does regulate and enforce underground diesel emissions (DPM, CO, NO2, etc.), although not in the same way as to determine what Tier equipment you can run. They use threshold limits of exposure for a certain number of hours per day. Basically an u/g mine that has very good ventilation, could run old equipment as long as the DPM and gas tests are below the threshold limits. Most mines dont have the exceptional ventilation, so naturally the higher Tier engines and catalyst equipment becomes a very important part of mine planning.

I assume OSHA has no interest in any emission related equipment? Do they have any regulations for equipment that is being consistently ran indoors?

On our underground mining equipment, we have been using catalysts for DPM and CO for a long time. I was interested in whether or not surface equipment was facing the same scrutiny as underground equipment these days. It appears by your posts that it is not, only that any new equipment manufactured has to meet the new EPA standards.

FYI, if it ever comes to EPA regulations governing older non-Tier equipment, dont worry about it. You can look to the mining aftermarket industry for solutions. MTI recently became a distributor for a passive regenerating DPM catalyst that will reduce DPM by 93-95% and CO by 83-94%, depending on which model is used. There are other types that use diesel fuel injected into a burner, types that use actual changeable filters, and types that use an additive in the exhaust. The NYSDOT trucks that I used to work on had a "7th injector" that was used to burn out the DPF (diesel particulate filter). Problem is that they are high maintenance, not to mention that they burn at ultra high temps and waste precious fuel. You certainly dont want anything flammable near them.
After seeing the units that we sell, I cant imagine why OEMs would use the complicated systems with high maintenance and expensive controls. The Macks at NYSDOT were down quite frquently due to the regeneration cycle not being completed because the snowplow trucks can only do 30 mph max when plowing. Regen required minimum 35 mph for like minimum 20 straight minutes to work, otherwise it ramps down until the truck is useless. The units we put on our mine equipment are regenerating all the time once the cat reaches a minimum temperature of 175*C, no maintenance, no controls, no fuel, no additives, just install it and run.

Just out of curiosity, what types of emission equipment are you guys seeing on your new heavy equipment? I know the engine manufacturers are hard at work to get emissions as low as possible before exiting the exhaust manifold, but I am positive that there will be additional equipment required to meet Tier 4 requirements.
 

John C.

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Cat uses the DPF on many engines. Some have positive crankcase ventilation. All have an advanced injection system.

I've heard of the DEF on a couple of Deere machines but never looked close enough to confirm it. I don't keep track of the Cummins powered machines anymore.

I'm told all will have the Diesel Particulate Filter and PCV and the Diesel engine fluid by 2014.
 

robin yates uk

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as we say in the UK " what a load of bollocks ! " I'm in the Philippines now and they don't comply with anything. The politically correct are destroying everything under a cloak of " do as we say or ??? "
 

CEwriter

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There is some emissions regulation of older in-field equipment going on, most notably in California where the Air Resources Board has required the use of exhaust aftertreatment on machines within certain age ranges, and virtually banned some of the oldest machines (horsepower and age dependent). Those regs have been written about extensively on this forum.

Various other jurisdictions have regulated in-use diesel emissions (as opposed to just regulating new diesels) as well: the New York City metro area, New Jersey, Cook County, IL, and others.

The motivation for these regs comes from the Clean Air Act. EPA develops standards for air quality based on levels of pollution that do not threaten human health, monitors air quality throughout the nation, and has the authority to penalize states in which there are areas that do not meet the clean-air standards (so-called "nonattainment areas").

One of the penalties at EPA's disposal is withholding federal funding to a state with poor air quality. Not good. So the states pass the buck down to political authorities responsible for the nonattainment areas -- counties, municipalities, sometimes coalitions of local and regional governments -- to come up with plans to comply with EPA air-quality standards. When those with the most tenacious air-quality problems consider sources of regulated pollutants, they cannot overlook the amount of particulate matter and oxides of nitrogen (a component of smog) that older diesel engines emit.

The Feds have to walk the walk, so they've developed a process for limiting diesel emissions from projects with large federal funding elements taking place in nonattainment areas. Projects going back as far as Boston's Big Dig and Chicago's Dan Ryan Expressway rehab had limits on diesel emissions from contractors' equipment written into project specifications. They used similar specs the O'Hare Airport expansion on the Illinois Tollway authority adopted similar procedures for Chicagoland work. Retrofits of exhaust aftertreatment can satisfy those bid requirements.

I'm not familiar with exactly how those contract clauses are written, but I do know that contractors who worked out at O'Hare were buying new equipment to do the work in part because they had cleaner exhaust emissions. It helped them satisfy the bid specs.

I know the Chicagoland Cat dealer, Patten, has also been doing big business in machine repowers -- fitting older scrapers and big dozers and loaders with newer, cleaner-burning engines for a couple of years. They (and I'm sure other dealers in nonattainment areas) have helped Cat develop part-numbered repower procedures for specific machine models where the return on investment works.

The Feds have also supported engine upgrades and exhaust-aftertreatment retrofits with the Diesel Emissions Reduction grants for the past five or six years. States like Texas (TERP, I thnk it's called) have had similar grant programs for a while. President Obama signed legislation early this year that authorizes up to $100 million each year for the DERA program for fiscal years 2012 through 2016. Not sure what any of those programs will look like in a year, given the current federal and state budget environments.

Don't get carried away by the scuttlebutt. It's hard to say what the long-term impact of emissions control technologies will be on diesel engines. While there are cases of equipment owners having problems that might be related to a diesel particulate filter or other emissions equipment an engine, there are LOTS of low-emissions diesel engines out there working pretty much like they did before the equipment was added; by and large, a technological non-event.

Here's what some were saying about on-highway engines that met EPA's 2007 emissions standards: Truck Owners Testify to Green-Diesel Performance. The technologies used on-highway in 2007 -- diesel particulate filters and exhaust-gas recirculation for the most part, with some like Mercedes using selective catalytic reduction and an oxidation catalyst with injected DEF -- are very similar to what we're seeing now on the higher-volume 75 hp to 175 hp off-road diesels.

Hope this helps,

Larry
 

Reel hip

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In California we are being hit hard!!! Older machines that still run great, but are a tier 1 or tier 2 engine's are being run out of the state. I have to register my equipment with the California Air Resource Board (CARB) or risk being fined heavily or just to work on a military base! The trucks are being regulated now too. They (CARB) have a breakdown on tier engines and what they will allow, with having to phase out older machines as I go. With the economy the way it is these regulations will probably put a lot of guys out of business. There are some companies in California that help keep us up to date on these never ending regulations!
 

Diesel gal

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In the State of California, all off-road diesel machinery must eventually be replaced by Tier 4 final engines. Most manufacturers are already building Tier 4 Interim and Tier 4 Final motors. California has tough diesel regulations and is acting as a model for other states with regards to emissions reduction. You are correct in stating that emission laws are getting stricter over time. Tier 0 engines are no longer allowed to operate and Tier 1 engines will become obsolete as well. Unfortunately in this state some equipment owners are actually being forced to either shut down or run illegally.
 

Diesel gal

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To John C: If you are located in California you are no longer allowed to run Tier 0 machines which are pre-1998. These engines were built without any regard to emission reductions. You can probably still acquire parts. Engines must be sold out of state or country, or scrapped. In the event you use your machine for personal use only you may continue to operate without restriction. Just don't get caught on a jobsite. The fines vary depending on the infraction but the maximum is $10,000 per day, per machine.
 

Diesel gal

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To Newman: If you're talking about heavy duty diesel trucks (GVWR 26,001 and over) you cannot disable the emissions equipment on your diesel motor. The California Highway Patrol and the California Air Resources Board perform roadside inspections where they check the emissions control label on your engine. If they find your equipment is not to Original Equipment Manufacturers (OEM) specifications you are looking at a fine. Basically California says "If it's diesel, it's regulated".
 

MTI Mark

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Northern New York
To the Californians:
Do the powers to be in California actually test the emissions, or do they require an emission tag attached to the engine stating the Tier of the engine itself? Could you use an exhaust catalyst installed as aftermarket to meet emission requirements?
Like I stated in my previous post, there are aftermarket catalysts which will significantly reduce DPM and gaseous emissions including CO and NO2. Could this be a simple solution to running older equipment in California?
For example, the best performing type of catalyst that we use/sell through MTI, I am told will take an older Tier 0 engine from Tier 0 to Tier 3 emission levels. That would be applicable to a machine that has a well maintained engine. If you are running a worn POS engine that is has a bad injector pump and is burning oil, there isnt much that is going to help other than repair, repower or rebuild.
It is quite common for us to repower older machines that we take in on trade and complete a remanufacture on, to at least Tier 3 engines. Tier 3 is standard on all of our new equipment, with Tier 4i in the works. I believe we can still build with Tier 2 if it is being sold overseas.
Another item that MTI is partnered with is a hydrogen generating unit. They did tests with our best line of catalyst coupled with the Hydrive unit and got zero DPM along with the significantly reduced gaseous emissions. Not only that, but the Hydrive unit also saved an average of 10-12% in fuel costs, so you actually get some payback for money invested. It is pretty interesting technology. The Hydrive is available for OTR and stationary use, but they are still working on the mine unit, which is subjected to severe operating conditions and vibration.
I am quite surprised that NY hasnt adopted the California diesel emission regulations, as they did several years ago with automobiles.
 

Reel hip

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I have looked into buying a Verified Emission Control Device (VDEC). They do offer them. For off road you must have registered your equipment to be able to have put one on a tier 0. Tier 1 and up can be installed if available for the motor. In trucks they want 2010 engine standards depending on fleet size,some can be put off being installed until 2017 if your truck has been recorded with the state no later than January 31 2012. By law you must have an engine control label affixed to to your block. They do inspect your trucks for this along with doing a opacity test at road side inspections. The problem alot of us are seeing in California is the smaller motors (concrete pumps, chippers, Skid steers) don't have VDECs available. Must not be profitable for the manufactures, or the cost might be higher than what the equipment is worth. So now some guys have perfectly running equipment that they can't work. If you have CARB verified components for smaller motors at a reasonable price,they can use them here.
 

MTI Mark

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Reel, I can tell you that the catalysts we use are expensive. I guess you would have to look at the whole picture and determine whether it is economically feasible for you to be able to use the applicable equipment, so that the return on investment is acceptable. These cats use precious metals internally, are a low volume seller, and custom to each application, therefore not cheap by any means.
I will check to see if these are CARB certified or not and let you all know. I dont have much doubt as to whether or not they would meet CARB specs as they are listed by MSHA for underground use, which means they have already gone through rigorous testing, I am just not sure that they have been specifically CARB certified.
They make these cats for any diesel engine application of 20hp & up, would that cover the "small equipment" you are referring to? If not, how small (hp) are you talking about?
 

Reel hip

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40 hp and up in off road and 50hp in portable equipment is what is being regulated. They must be carb tested to be verified. I have contacted other companies and they say it takes time to verify them. The fact that yours have mine certs may make that process faster.
 

CM1995

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as we say in the UK " what a load of bollocks ! " I'm in the Philippines now and they don't comply with anything.

I have also lived in a "developing" country and have seen exactly what you are talking about. Also traveled to China twice and let me tell you, the Chinese care nothing about air quality or the rest of their environment for that matter.

A question to ponder: Everyone in the US gripes about "jobs going overseas". How are the US and Europe supposed to be competitive in the World Market when we impose stringent regulations on ourselves and the developing countries (China, India, etc) don't have the same regulations and if they did, wouldn't follow them?

It seems to me we are tying our own hands and at the same time, sharpening the knife that will cut our throats. Now don't get me wrong, I am not for total de-regulation with the results being dirty air and other pollution but the question stands: At what point is enough, enough?

Do we really need regulations that require the diesel exhaust to be cleaner than the air that goes into the intake?
 

John C.

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What experience I've had with mine certs and Carb or EPA emissions specifications was that they they don't really communicate between each other. I know the underground certs have been effective for many years and that they have made absolutely no difference to the EPA at all. Carb decided they should rule the world and pushed their stuff through two or three years before it was to become federal law anyway.

I'm sure many here would be interested if there were add on devices available to allow Tier 0 engines to keep running after 2014. At this point in time I'm hopeful but won't believe anything until it happens. My own thoughts are that the feds will make industry stop supplying parts for the Tier 0 units so they die out over a short period of time.
 
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