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Informal Legislators-Industry Roundtable Meeting Category 1 and 2 Marine Diesel Engines

Informal Legislators-Industry Roundtable Meeting Category 1 and 2 Marine Diesel Engines. Tim French / Todd Hendrickson Ann Arbor, MI September 26 th , 2006. Current Commercial Marine Emissions Landscape. Europe: EU NRMM Directive 97/68/EC (2004/26/EC) - CCNR (Rhine River).

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Informal Legislators-Industry Roundtable Meeting Category 1 and 2 Marine Diesel Engines

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  1. Informal Legislators-IndustryRoundtable MeetingCategory 1 and 2 Marine Diesel Engines Tim French / Todd Hendrickson Ann Arbor, MI September 26th, 2006

  2. Current Commercial Marine Emissions Landscape • Europe: • EU NRMM Directive 97/68/EC (2004/26/EC) • - CCNR (Rhine River) United States: - EPA 40CFR94 Worldwide: - International Maritime Organization(IMO)MARPOLAnnex VI

  3. EMA’s Desired Future Marine Emissions Landscape • National / Regional Standards: • U.S. and European standards are harmonized and used as the basis for other countries Worldwide: - International Maritime Organization(IMO)MARPOLAnnex VI

  4. Presentation Outline • Background • Vessel Segmentation • Industry Concerns When Considering Aftertreatment • Tier 3 and Tier 4 Standards • Key Requirements and Summary

  5. EMA’s Marine and Locomotive Engine Committee • EMA’s Marine and Locomotive Engine Committee (MLEC) is a subcommittee of EMA’s Emissions Group • EMA’s MLEC has been involved in marine diesel engine exhaust regulatory activity since the early-1990’s • EMA’s MLEC is primarily comprised of Category 1 (high-speed) and Category 2 (medium-speed) diesel engine manufacturers • The represented manufacturers produce propulsion and auxiliary engines for both the commercial marine and recreational marine markets

  6. MLEC Member Companies Caterpillar Inc. Cummins Inc. Deere & Company Detroit Diesel Corporation General Motors Corporation Isuzu Manufacturing Services of America, Inc. MTU Volvo Powertrain Corporation Wärtsilä North America, Inc. Yanmar America Corporation

  7. EPA’s Marine Rulemaking Activity MLEC Involvement • EMA submitted detailed written comments regarding EPA’s ANPRM in August 2004 • Since that time, EPA has met several times with EMA as an organization and with individual engine manufacturers • MLEC Goals: • All Standards are technically feasible and cost effective • U.S. and European Marine standards are harmonized • Rest of World Standards follow harmonized U.S. and EU

  8. BackgroundU.S. Standards by Application: Years First Regulated • International and European Marine Regulations • IMO’s Annex VI: retroactive to 2000 • CCNR: first regulated in 2002 (2003) • EU NRMM: first regulates marine in 2006 (2007) Standards roughly equivalent to 1988/1994 on-highway.

  9. Marine Engines are Derivative Engines • Category 1 marine engines are derivatives of on-highway and/or nonroad engines • These engines must be “tailored” for the marine market

  10. Tailoring Engines for Marine Market • Tailoring of on-highway and nonroad engine designs for the marine market includes: • Thermal management – primary focus • Water-cooled exhaust manifolds and turbochargers, • Water-injection into the exhaust downstream of the turbocharger, and/or • Blanketing of engine and vessel exhaust system • Redundant systems, such as oil filtration, to ensure continued engine operation • Relocate components to accommodate space constraints (i.e. high-mount turbocharger may be moved to the rear of the engine) • Component/system certification for “Classed” vessels

  11. U.S. Engine Sales ComparisonOn-highway and Marine – New Trucks/Vessels 380,000 3200 Source:On-highway: Wards Automotive (average of 2003-2005 HD and MD sales)Commercial Marine: Diesel Progress, Workboat, & EMA Estimates

  12. Worldwide Market • Major engine manufacturers sell marine engines worldwide. Included are areas with no emission standards or only IMO Annex VI standards • European and U.S. sales represent a decreasing fraction of overall sales • Future standards which are harmonized will help to justify the investment required to design and certify products for these markets

  13. U.S. EPA Regulation Scope • There are two key differences to keep in mind when comparing the U.S. EPA marine engine regulation and the EU Inland Waterway requirements • The EPA regulation is not limited to inland waterways. The EPA regulation includes vessels that operate in ports and some ocean-going vessels. • The EPA regulation includes recreational marine engines.

  14. Presentation Outline • Background • Vessel Segmentation • Industry Concerns When Considering Aftertreatment • Tier 3 and Tier 4 Standards • Key Requirements and Summary

  15. Vessel Segmentation • Current U.S. EPA Segmentation • Recreational (Propulsion) • Category 1: <5.0 L/cyl • Commercial (Propulsion and Auxiliary) • Category 1: <5.0 L/cyl • Category 2: 5.0 - 30 L/cyl • For Tier 3 and Tier 4, important to reevaluate this segmentation since many small commercial applications exhibit similar performance and installation characteristics as recreational applications

  16. Recreational & Small Commercial I/O Small Pleasure Craft Harbor Patrol Inshore Fishing Inboard Cruiser Military Patrol Craft Inboard Trawler

  17. Large Commercial Planing Displacement Towboat Tugboat Planing Passenger Ferry Offshore Supply Vessel Anchor Handling Vessel Planing Crewboat

  18. SegmentationVessel Characteristics

  19. Comparative Emissions Contribution(Initial Comparison)

  20. Presentation Outline • Background • Vessel Segmentation • Industry Concerns When Considering Aftertreatment • Tier 3 and Tier 4 Standards • Key Requirements and Summary

  21. Aftertreatment for MarineKey Issues Identified

  22. Aftertreatment for Marine Review of Key Issues Recreational Category 1 Small CommercialCategory 1 Large CommercialCategory 1 & 2

  23. Aftertreatment for Marine Issues for Large Commercial

  24. Conclusions • Aftertreatment systems pose unique challenges for marine applications. Just like marine engines, aftertreatment systems will need to be “tailored” for the marine market. • Aftertreatment is more feasible for large commercial applications. • Tier 3 stringent “engine-out” standards should apply to all engines. • Tier 4 “aftertreatment” standards should be limited to engines >600kW • Auxiliary engine requirements should be equivalent to propulsion engine requirements

  25. Presentation Outline • Background • Vessel Segmentation • Industry Concerns When Considering Aftertreatment • Tier 3 and Tier 4 Standards • Key Requirements and Summary

  26. Tier 3 Standards • Tier 2 Marine standards are largely based off Tier 2 Nonroad standards • Given the rulemaking’s emphasis on PM reduction, Tier 3 Marine standards should not be based on Tier 3 Nonroad standards • Compared to Nonroad Tier 2, Nonroad Tier 3 standards: • Reduce NOx by approximately 32% • Reduce PM by 0% • This is also the case when comparing Stage II and Stage IIIA Nonroad Tier 2 Nonroad Tier 2 Marine Tier 3 Nonroad Tier 3 Marine

  27. Tier 3 Standards (cont.) • To achieve Nonroad Tier 3, engine manufacturers primarily chose between two different enabling technologies • Cooled EGR • In-Cylinder Combustion Optimization

  28. Tier 3 Standards (cont.) • Cooled EGR poses unique concerns when considered for marine engines • High peak cylinder pressure requirements already seen in recreational marine without CEGR --- adding CEGR increases cylinder pressure beyond mechanical limits or forces a significant reduction in power density • Significant cost and complexity in marinizing CEGR product • Fuel sulfur level is a design consideration when considering CEGR. Marine in-use fuel sulfur levels are typically high.

  29. Tier 3 Standards (cont.) • For in-cylinder combustion optimization, the traditional NOx/PM trade-off needs to be considered • For Tier 3 Marine to achieve lower PM levels than Tier 3 Nonroad, a higher NOx level is needed Tier 3 NonroadTier 3 Marine

  30. Tier 4 Standards • Due to the emissions inventory analysis and the challenges associated with applying AT to marine applications, Tier 4 standards should only apply to large commercial applications (engines >600kW) • The market must be able to assure the availability of Ultra-Low Sulfur Diesel (ULSD) fuel for Tier 4 engines (15ppm max sulfur)

  31. Tier 4 Standards (cont.) • NOx Reductions • More NOx AT experience than PM AT experience exists for marine applications • NOx AT retrofit experience has proven costly and is often heavily subsidized • Reducing NOx by more than 75% of Tier 2 levels drives additional hardware and operational costs

  32. Tier 4 Standards (cont.) • NOx Reductions • More NOx AT experience than PM AT experience exists for marine applications • NOx AT retrofit experience has proven costly and is often heavily subsidized • Reducing NOx by more than 75% of Tier 2 levels drives additional hardware and operational costs • PM Reductions • Limited experience in the field with PM AT and limited documented successes • Significant amount of development required, especially considering that there are no on-highway counterparts for large engines • 80% PM reduction from Tier 2 corresponds with EPA Nonroad Tier 4 standards for engines >560kW • 80% PM reduction from Tier 2 levels allows for the development of “more forgiving” PM AT systems (passively-regenerated flow-through PM filters)

  33. Additional Tier 3 and Tier 4Considerations • Categorization Scheme • Tier 3: - In-cylinder emissions reductions - Cylinder/component geometry critical factor - Displacement per cylinder (L/cyl) is appropriate • Tier 4: - Aftertreatment-based emissions reductions - Exhaust flows/temps critical factors - Power-based standards appropriate • Category 1 & 2 Differentiation for Tier 3 • Tier 2 / Stage IIIA requirements use 5.0 L/cyl as break-point for high-speed and medium-speed diesels • For future standards, 7.0 L/cyl is a more a better break-point • Results in additional changes for Category 1 categories • Auxiliary engines regulated to same levels as propulsion engines with option to use nonroad certified engines

  34. Presentation Outline • Background • Vessel Segmentation • Industry Concerns When Considering Aftertreatment • Tier 3 and Tier 4 Standards • Key Requirements and Summary

  35. Key Requirements • Harmonization (dates and standards) • Staggered Introduction (phase-in) • Certification using ULSD Fuel for Tier 3 and Tier 4 • In-Use ULSD Fuel for Tier 4 Engines • Review / Adjustment of U.S. EPA NTE Requirements

  36. Summary • Marine Engines Are: • Derivative Engines • Worldwide, Low Volume Engines • Tailored Engines • Unique Aftertreatment Challenges • Harmonization is the key to justifying continued technology investment

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