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Re: Landfill Gas "Certified Engine" per Subpart JJJJ

Not Certified? I commisioned a G3520 last year and the cert lable is on on a tag on the left side of the unit. Up on the valve cover, has a big bar code on it....Pretty sure it's also in the front of the maint manual as well...

Contributor

Re: Landfill Gas "Certified Engine" per Subpart JJJJ

YES!  Now we are on to something.  It definitely is coming from a state regulator.  She says that if we can get Caterpillar to put this placard on our engine, we don't have to do certain annual emissions testing.

Cat Dealer
Dealer

Re: Landfill Gas "Certified Engine" per Subpart JJJJ

Scott,

 

I think we are getting to the core of the question. 

 

Where did the assertion "that in order "certify" an engine under JJJJ is to provide a placard or label stating that, "This engine must only be run on landfill gas." come from?   Possibly from a state regulator?

 

This is not the case, as there is much more to engine certification for both JJJJ and IIII.

Contributor

Re: Landfill Gas "Certified Engine" per Subpart JJJJ

I definitely appreciate the responses, however, I fear that I am not making my request clear enough.  

 

All Caterpillar would have to do, in order "certify" an engine under JJJJ is to provide a placard or label stating that, "This engine must only be run on landfill gas."  That's it.

 

My question is, who do I need to talk to so that we can get this done?

 

 

Cat Dealer
Dealer

Re: Landfill Gas "Certified Engine" per Subpart JJJJ

 As you note, EPA makes certification of SI engines optional.   Certification to JJJJ requirements would absolutely be for emissions as this is the primary reason for the IIII and JJJJ regs in the first place.  As noted by scushman, certifying a landfill engine would be impractical due to the variations in fuels from day to day and from site to site.  Basically the engine would have to be "locked down" in regards to air fuel ratio and BTU input and it would meet emissions at a certain set of fuel values but not outside a small window which most sites would regularly have excursions from.  EPA does not allow latitude in this regard and you would have an engine that you could rarely run.   

 

Another aspect is return on investment for the engine manufacturer, Because certification is optional and expensive and volumes of large SI engines are comparably low, there is no payback for the engine mfr.  This is borne out by the lack of certified SI product above 500ekW or so (my research is not current so this may have changed), by any mfr.  In my opinion, all the mfr's have made the same calculation on the larger, low volume SI engines and come to the same conclusion about the certification ROI for these engines, not to mention the technical issues above.  All of this is just my opinion.

Contributor

Re: Landfill Gas "Certified Engine" per Subpart JJJJ

Anybody?  All I am asking for a contact at Cat corporate.

Contributor

Re: Landfill Gas "Certified Engine" per Subpart JJJJ

Let me clarify. This is not certifying emissions, fuel quality or anything else. A manufacturer certifying an engine under JJJJ is ONLY certifying that the engine is designed to run on a certain fuel.  In my case, this would be landfill gas.  Here is an excerpt from JJJJ:

 

40 CFR Part 60, Subpart JJJJ

Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

§60.4241

 

(g) A stationary SI engine manufacturer may certify an engine family solely to the standards applicable to landfill/digester gas engines as specified in § 60.4231(d) or (e), as applicable, but must certify their engines for operation using landfill/digester gas and must add a permanent label stating that the engine is for use only in landfill/digester gas applications. The label must be added according to the labeling requirements specified in 40 CFR 1048.135(b).

 

 

Cat Dealer
Dealer

Re: Landfill Gas "Certified Engine" per Subpart JJJJ

CAT does not have "Certified" gas engines for several reasons.  All are related to the burden placed on the owner when the engine is certified.  The burdens are: guaranteeing fuel's quality and following the engine mfg's recommended maintenance schedule.  Biomass fuel heat rates and quality vary greatly so the engine mfg would have to set the maintenance requirements for the worst case.  This would make many potential applications uneconomical.  For all other applications the recommended maintenance intervals are conservative; so, in most applications the operating cost savings by changing oil and performing other maintenance functions based on SOS and operating experiences exceeds the cost of emissions compliance testing.  The only application where the economics favor factory certified engines are standby and  low hours peak shaving.

Contributor

Landfill Gas "Certified Engine" per Subpart JJJJ

It has been brought to my attention that an owner/operator of a spark-ignited IC engine (e.g... G3520C) can demonstrate compliance with 40 CFR Part 60, Subpart JJJJ by utilizing a "Certified Engine," which is defined in the regulation.  However, my engine bears no certification.   As such, to demonstrate compliance with JJJJ, we have to do stack testing every 8,760 hours, or in our case, a little more than once a year - an expensive proposition.

 

However, if a manufacturer certifies that the engine is only meant to run on landfill gas, then the owner does not have perform annual stack tests to demonstrate compliance.  I have contacted Caterpillar via my dealer to get my engine "certified."  However, my dealer (Ransome Engine) stated that CAT will not "certify" a landfill gas engine.  I anticipate that they mistakenly thought that certification entailed guaranteeing emissions.  This is not the case as it appears to be just a placard attached to the engine by the manufacturer will make my 3520 a "certified engine," and get us out of annual stack testing.

 

My question is, who can I speak to at CAT corporate to help me out with this?  I would be happy to share the specific citation in JJJJ that allows for this.  I believe that "Certifying" an engine under JJJJ will be a trivial matter for CAT, but I just don't know whom to ask.  Thanks in advance for everyone's help.

 

Scott Mengle

SECCRA Landfill