1
MEMORANDUM
DATE:
June
10,
2005
SUBJECT:
Availability
of
Catalyzed
Diesel
Particulate
Filters
for
Stationary
Compression
Ignition
Internal
Combustion
Engines
FROM:
Tanya
Parise,
Alpha­
Gamma
Technologies,
Inc.

TO:
Sims
Roy,
EPA
OAQPS
ESD
Combustion
Group
The
purpose
of
this
memorandum
is
to
document
the
availability
of
catalyzed
diesel
particulate
filters
(
CDPF)
as
they
apply
to
stationary
compression
ignition
(
CI)
internal
combustion
engines
with
a
displacement
of
less
than
30
liters
per
cylinder.
A
CI
engine
is
defined
as
an
engine
that
is
not
spark
ignition
(
SI).
An
SI
engine
is
defined
as
a
gasoline,
natural
gas,
or
liquefied
petroleum
gas
fueled
engine
or
any
other
type
of
engine
with
a
spark
plug
(
or
other
sparking
device)
and
with
operating
characteristics
significantly
similar
to
the
theoretical
Otto
combustion
cycle.
Spark
ignition
engines
usually
use
a
throttle
to
regulate
intake
air
flow
to
control
power
during
normal
operation.
Dual­
fuel
engines
in
which
a
liquid
fuel
(
typically
diesel
fuel)
is
used
for
CI
and
gaseous
fuel
(
typically
natural
gas)
is
used
as
the
primary
fuel
at
an
annual
average
ratio
of
less
than
2
parts
diesel
fuel
to
100
parts
total
fuel
on
an
energy
equivalent
basis
are
SI
engines.

Background
The
EPA
is
in
the
process
of
developing
new
source
performance
standards
(
NSPS)
for
stationary
CI
internal
combustion
engines.
The
EPA
is
under
a
court
ordered
deadline
to
propose
NSPS
by
June
29,
2005
and
promulgate
NSPS
by
June
28,
2006
for
CI
stationary
internal
combustion
engines.
The
NSPS
will
apply
to
stationary
CI
engines
that
are
ordered
after
the
date
the
proposal
is
published
in
the
Federal
Register
and
manufactured
after
April
1,
2005,
and
also
stationary
CI
engines
that
commence
modification
or
reconstruction
after
the
proposal
date.
New
source
performance
standards
are
developed
under
the
authority
of
section
111
of
the
Clean
Air
Act
(
CAA)
and
EPA
must
address
emissions
of
criteria
pollutants
(
those
pollutants
identified
under
section
110
of
the
CAA).
A
criteria
pollutant
of
major
concern
from
stationary
CI
engines
is
particulate
matter
(
PM).
Catalyzed
diesel
particulate
filters
have
been
shown
to
be
very
effective
in
reducing
PM
from
CI
engines.
140
CFR
Parts
9,
69,
et.
al.
Control
of
Emission
of
Air
Pollution
from
Nonroad
Diesel
Engines
and
Fuel;
Final
Rule.
June
29,
2004.
69
FR
38957.

2Catalyzed
Diesel
Particulate
Filters
for
Stationary
Engines.
Email
from
Mike
Tripodi,
Clean
Air
Systems
to
Tanya
Ali,
Alpha­
Gamma
Technologies,
Inc.
July
21,
2003.

2
The
emission
standards
that
EPA
will
propose
for
the
NSPS
for
stationary
CI
internal
combustion
engines
with
a
displacement
of
less
than
30
liters
per
cylinder
will
be
modeled
after
the
EPA
rule
for
nonroad
diesel
engines.
The
final
rule
for
nonroad
diesel
engines,
which
promulgated
Tier
4
emission
standards,
was
published
in
the
Federal
Register
on
June
29,
2004.1
The
final
nonroad
Tier
4
PM
emission
standards
are
based
on
the
use
of
CDPF,
which
is
the
technology
EPA
expects
will
be
used
by
engines
with
a
displacement
of
less
than
30
liters
per
cylinder
to
comply
with
the
PM
Tier
4
emission
standards.
The
PM
emission
standards
that
are
based
on
the
use
of
CDPF
vary
depending
on
engine
power
and
in
some
cases
also
the
application,
but
the
earliest
model
year
that
has
a
PM
standard
based
on
the
use
of
CDPF
is
2011.
Catalyzed
diesel
particulate
filters
have
been
demonstrated
to
reduce
PM
by
at
least
85
percent
from
stationary
CI
engines,
however,
the
filters
require
the
use
of
ultra
low
sulfur
diesel
(
ULSD)
fuel,
i.
e.,
fuel
containing
no
more
than
15
parts
per
million
by
weight
(
ppmw)
of
sulfur,
to
achieve
this
level
of
PM
reduction.
The
EPA
recently
promulgated
regulations
that
require
sulfur
levels
for
nonroad
diesel
fuel
to
be
reduced
to
500
ppm
beginning
in
late
2007
and
15
ppm
beginning
in
late
2010;
similar
regulations
will
be
proposed
for
stationary
engines.
According
to
EPA's
fuel
analysis,
this
is
the
timeframe
that
these
fuels
will
be
available
for
nonroad
diesel
engines.
The
EPA
also
conducted
an
analysis
to
determine
the
availability
of
ULSD
fuel
for
stationary
CI
engines
that
would
be
affected
by
the
NSPS.
Results
of
the
analysis
indicate
that
there
will
be
a
sufficient
amount
of
ULSD
fuel
for
stationary
CI
engines
affected
by
the
NSPS.

Availability
of
CDPF
The
EPA
has
contacted
several
CDPF
vendors
including
major
control
technology
manufacturers
such
as
CleanAir
Systems,
Miratech,
Engelhard,
and
Johnson
Matthey.
Information
received
from
control
technology
vendors
indicate
that
CDPF
are
currently
available
and
can
be
installed
on
stationary
CI
engines
to
significantly
reduce
PM
levels.
Each
of
the
vendors
contacted
has
equipped
stationary
CI
engines
of
a
variety
of
sizes
with
CDPF
and
the
technology
is
performing
as
expected
achieving
PM
reductions
in
excess
of
85
percent.
According
to
control
technology
vendors,
the
technology
is
mature
and
has
been
proven
a
viable
control
solution
for
reducing
PM
from
all
but
the
very
largest
diesel
engines.

CleanAir
Systems
has
developed
the
CleanAir
PERMITTM
Filter,
which
is
applicable
to
all
diesel
engines.
2
The
CleanAir
PERMITTM
Filter
is
a
catalyzed
diesel
particulate
filter
3CleanAir
Systems.
CleanAir
PERMITTM
Filter
System.
http://
www.
cleanairsys.
com/
materials/
pdf/
PERMIT%
20Brochure.
pdf.
August
13,
2004.

4Catalyzed
Diesel
Particulate
Filters
for
Stationary
Engines.
Email
from
Mike
Tripodi,
Clean
Air
Systems
to
Tanya
Ali,
Alpha­
Gamma
Technologies,
Inc.
May
14,
2004.

5Catalyzed
Diesel
Particulate
Filters
used
on
Stationary
Reciprocating
Internal
Combustion
Engines.
Email
from
Rich
Rosowski,
Johnson
Matthey
to
Tanya
Ali,
Alpha­
Gamma
Technologies,
Inc.
July
15,
2003.

6Diesel
Particulate
Filter
Systems
for
Off­
Road
Applications.
http://
www.
jmcsd.
com/
New_
English.
pdf.
August
13,
2004.

7Diesel
Particulate
Filters/
CRT
Costs.
Email
from
Rich
Rosowski,
Johnson
Matthey
to
Tanya
Ali,
Alpha­
Gamma
Technologies,
Inc.
May
17,
2004.

8Catalyzed
Diesel
Particulate
Filters
for
Stationary
RICE.
Email
from
Jim
McDonald,
Miratech
Corporation
to
Tanya
Ali,
Alpha­
Gamma
Technologies.
October
22,
2003.

9Catalyzed
Diesel
Particulate
Filters
for
Stationary
RICE.
Email
from
Jim
McDonald,
Miratech
Corporation
to
Tanya
Ali,
Alpha­
Gamma
Technologies.
October
24,
2003.

10Catalyzed
Diesel
Particulate
Filters
for
Stationary
RICE.
Email
from
Jim
McDonald,
Miratech
Corporation
to
Tanya
Ali,
Alpha­
Gamma
Technologies.
May
15,
2004.

3
that
reduces
PM
by
more
than
85
percent.
3
CleanAir
Systems
indicated
that
it
has
equipped
CDPF
on
stationary
engines
as
large
as
2
megawatt
(
MW)
(
2,680
HP),
but
that
it
can
install
CDPF
on
engines
larger
than
that.
4
Control
technology
vendor
Johnson
Matthey
manufacturers
the
patented
continuous
regenerating
technology
(
CRT
®
)
.
5
This
technology
does
not
include
a
catalyzed
filter
but
contains
a
platinum
based
oxidation
catalyst
and
a
filter
element.
The
vendor
normally
guarantees
a
PM
reduction
of
85
percent
with
the
control
device.
Johnson
Matthey's
technology
is
available
for
all
applications
and
sizes.
6
The
catalyst
vendor
indicated
to
EPA
that
its
largest
DPF
application
was
on
a
3,300
HP
engine.
7
Miratech
Corporation
indicated
to
EPA
that
it
has
recently
introduced
a
new
diesel
particulate
filter.
8
The
diesel
particulate
filter
Miratech
has
developed
called
the
Rypos
Trap,
is
the
active
regeneration
type.
The
regeneration
does
not
depend
on
engine
exhaust
temperatures
or
fuel
sulfur
content.
The
catalyst
vendor
noted
that
the
Rypos
Trap
does
not
require
low
sulfur
diesel
and
the
costs
are
comparable
to
a
catalyzed
diesel
particulate
filter
(
ceramic
wall
flow).
The
Rypos
Trap
is
capable
of
achieving
PM
emissions
reductions
of
up
to
90
percent
and
was
specifically
designed
for
stationary
internal
combustion
engines.
Miratech
said
that
it
plans
to
have
standard
retrofit
units
from
150
kilowatt
(
KW)
(
200
HP)
to
2
MW
(
2,680
HP).
9
The
control
technology
vendor
indicated
to
EPA
that
the
largest
filter
that
it
has
supplied
was
for
an
engine
approximately
4,000
HP
in
size.
10
11California
Air
Resources
Board.
Diesel
Emission
Control
Strategies
Verification
Level
3
Verified
Technologies.
http://
www.
arb.
ca.
gov/
diesel/
verdev/
level3.
htm.
August
13,
2004.

12California
Environmental
Protection
Agency.
Air
Resources
Board.
Staff
Report:
Initial
Statement
of
Reasons
for
Proposed
Rulemaking.
Airborne
Toxic
Control
Measure
for
Stationary
Compression­
Ignition
Engines.
Stationary
Source
Division.
Emissions
Assessment
Branch.
September
2003.

13Miratech's
Silicone
Carbide
Element
Soot
Traps.
Diesel
&
Gas
Turbine
Worldwide.
October
2004.

14Miratech
Corporation.
MobiClean
Soot
Traps.
http://
www.
miratechcorp.
com/
general.
asp?
id=
593.
October
22,
2004.

4
In
addition,
the
California
Air
Resources
Board
(
CARB)
finalized
the
airborne
toxic
control
measure
(
ATCM)
for
stationary
CI
engines
on
November
8,
2004.
The
ATCM
will
take
effect
in
the
year
2005.
The
proposed
standards
require
stationary
new
and
in­
use
prime
CI
engines
greater
than
50
horsepower
(
HP)
to
meet
a
diesel
PM
limit
of
0.01
grams
per
brake
horsepower­
hour
(
g/
bhp­
hr).
The
Board
believes
the
0.01
g/
bhphr
is
technologically
feasible
because
results
from
a
demonstration
program
conducted
by
CARB
in
order
to
evaluate
the
feasibility
of
several
PM
control
technology
options
showed
that
two
stationary
diesel
engines
were
able
to
achieve
a
diesel
PM
emission
rate
of
equal
to
or
less
than
0.01
g/
bhp­
hr
following
the
application
of
DPF
technologies.
In
addition,
emissions
test
data
from
CleanAir
Systems'
PERMITTM
technology
has
shown
that
the
technology
is
capable
of
reducing
PM
emissions
by
85
percent
or
more,
which
has
yielded
diesel
PM
emission
rates
below
0.01
g/
bhp­
hr.
The
PERMIT
technology
from
CleanAir
Systems
has
been
verified
by
CARB
for
application
to
engines
and
is
verified
to
obtain
85
percent
PM
reduction
on
several
engine
models.

Furthermore,
CARB
has
also
verified
several
other
CDPF
systems
from
other
equipment
vendors
on
various
model
year
on­
road
applications.
11
Finally,
as
documented
in
the
Staff
Report
to
the
proposed
ATCM,
12
several
CI
engines
(
emergency
and
prime)
in
California
are
equipped
with
CDPF
including
engines
varying
in
sizes
from
less
than
200
HP
to
up
to
3,000
HP.

A
recent
issue
of
the
industry
journal
Diesel
&
Gas
Turbine
Worldwide
included
an
article
discussing
Miratech's
introduction
of
MobiClean
 
and
CBS
 
silicone
carbide
element
soot
traps.
13
MobiClean
 
is
the
active
regeneration
type
where
the
filter
is
regenerated
by
the
presence
of
a
duct
burner.
This
eliminates
the
dependence
on
engine
exhaust
temperatures.
Regeneration
with
MobiClean
 
can
occur
at
any
load,
a
benefit
to
diesel
generators
that
run
unloaded
the
majority
of
the
time.
The
product
is
applicable
to
generators
80
KW
(
107
HP)
to
2,340
KW
(
3,140
HP),
according
to
Miratech's
website.
14
The
technology
may
achieve
up
to
99
percent
reduction
in
PM
and
when
a
diesel
oxidation
catalyst
is
added,
reductions
of
90
percent
of
CO
and
70
15Summary
of
Meeting
with
the
European
Association
of
Internal
Combustion
Engine
Manufacturers
(
EUROMOT)
Regarding
NSPS
for
CI
Stationary
RICE.
March
22,
2005.

5
percent
of
VOC
are
possible.
The
CBS
 
trap
is
a
lower
cost
solution
for
engines
that
predominantly
run
at
high
loads.
The
trap
is
the
passive
regeneration
type
where
the
filter
contains
a
catalytic
coating
and
is
applicable
to
diesel
applications
550
KW
(
737
HP)
to
7
MW
(
9,380
HP)
in
size.
This
filter
also
has
an
efficiency
of
up
to
99
percent,
according
to
Miratech's
website.

The
EPA
met
with
manufacturers
of
very
large
stationary
CI
internal
combustion
engines,
i.
e.,
engines
with
a
displacement
of
30
liters
per
cylinder
or
greater.
15
The
engine
manufacturers
indicated
that
CDPF
are
not
available
for
engines
of
this
size.
The
manufacturers
stated
that
they
did
not
recommend
placing
several
traps
in
parallel
because
there
would
be
uneven
gas
flow
through
the
units,
resulting
in
a
low
reduction
efficiency.
The
PM
reduction
technology
that
the
engine
manufacturers
have
demonstrated
to
be
effective
for
these
very
large
engines
is
electrostatic
precipitator.

Based
on
the
information
presented
in
this
memorandum,
which
includes
information
from
several
CDPF
vendors
and
CARB,
EPA
believes
that
CDPF
are
currently
available
for
stationary
CI
engines
with
a
displacement
of
less
than
30
liters
per
cylinder,
and
will
be
available
in
the
future
when
the
NSPS
for
stationary
CI
internal
combustion
engines
takes
effect.
