Navigating the Emissions Regulations Thicket

As companies and individuals whose business is environmental protection, we in the waste-hauling business don't often see our operations as a significant source of pollution.

By Daniel P. Duffy

Although we remove, treat, and dispose of solid waste, hazardous waste, and leachate, our day-to-day equipment and vehicle operations might result in emissions that violate clean-air standards. This article examines the effects of existing and proposed vehicle engine emissions regulations on collection, transfer, and off-road operations in the United States and Canada for the next decade or so.

Current and Pending National Emissions Standards

Typically, national emissions standards are set by national–or in the case of the European Common Market, supra-national–governmental agencies. Enforcing these standards, however, is usually the responsibility of the state governmental agency. The standards are established by research and development performed by the national agencies. For example, the US Environmental Protection Agency (EPA) sets what amounts to minimal standards (a performance "floor") below which operations typically result in a violation. Individual state or provincial agencies publish detailed regulations governing operations, inspections, and penalties for noncompliance.

EPA

The Office of Transport and Air Quality (OTAQ) of EPA is responsible for setting vehicle and equipment emissions standards in the US. Its regulations cover light-duty vehicles (cars, light trucks, and motorcycles), heavy-duty highway engines (buses and heavy trucks), and nonroad vehicles and engines (aircraft, farm equipment, locomotives, marine engines, and so on).

As part of a comprehensive national emissions control program, heavy-duty trucks and their fuel will be regulated as a single system. These new standards, which take effect in 2007, are based on the use of high-efficiency catalytic exhaust emissions-control devices (or equivalent technologies). Particle emissions standards for heavy-duty diesel engines are to be reduced to 0.01 grams per brake horsepower per hour (g/bhp-hr.). Nitrogen oxide and nonmethane hydrocarbon emissions are to set at 0.2 g/bhp-hr. and 0.14 g/bhp-hr., respectively. It is also important to regulate the quality of the fuel such engines use because they are damaged by sulfur. As such, EPA is planning to reduce sulfur in highway diesel fuel by 97% (no more than 15 parts per million) by 2006. Overall, the OTAQ projects the following reductions in emissions by 2030: 2.6 million tons of nitrogen oxide, 115,000 tons of nonmethane hydrocarbons, and 109,000 tons of particulates. Average estimated cost is projected at $1,200-$1,900 per truck.

As part of its mandate to perform research and development, EPA has established test programs to evaluate new emissions-control technology. One such program directly affecting waste hauling and landfill operations is EPA's Voluntary Diesel Retrofit Program. Initiated in the Washington, DC, area in conjunction with Waste Management Inc., this program plans to retrofit 10 recycling trash trucks with emissions-reducing technologies. The primary technology to be used is the Quad Cat four-way catalytic converter, although other retrofit technologies may be considered. The trucks to be retrofitted are diesel-powered recyclable-trash trucks manufactured by Volvo and equipped with Cummins M11 engines.

Canada

As a signatory to the Kyoto Protocols to limit such greenhouse gases (GHGs) as carbon dioxide, Canada is committed to reach a level of GHG emissions that is 6% below its level in 1990. The transport sector is the largest contributor to Canada's total GHG emissions. The Canadian federal and provincial transport ministers agreed to create a Transportation Table to identify and analyze ways of reducing GHG emissions from all Canadian transportation sources.

Even before Kyoto, starting in 1971, Canadian emissions standards have become increasingly stringent. In 1997, Canada published comprehensive new emission regulations requiring more stringent control of exhaust (hydrocarbons, carbon monoxide, nitrogen oxide, and particulates) from 1998 and later model-year, heavy-duty trucks. The new regulations also required the installation of onboard diagnostic devices to monitor vehicle emissions controls and alert the driver by means of a dashboard warning light.

In general, the focus of Canadian environmental regulations has shifted from controlling pollution to preventing it. This new focus includes a heavy investment in research and development of vehicles and fuels that produce low or zero emissions.

European Union

As you can imagine, the European Union's emissions regulations tend to be far more stringent than those of its American counterpart and are scheduled to get even tougher. The first European-wide emissions standards were introduced in 1992 as the "Euro I" standards for medium and heavy-duty engines. The "Euro II" standards were promulgated in 1996 and were expanded to cover heavy-duty highway diesel engines, and specifically prohibited the use of "defeat devices." In 1999 the European Union adopted the "Euro III" standards and planned to enforce "Euro IV" and "Euro V" standards in 2005 and 2008, respectively. The latter two standards are expected to set emissions standards requiring all new diesel-powered, heavy-duty vehicles to be fitted with exhaust-gas after-treatment devices such as particle traps and de-nitrogen oxide catalysts. The projected 2008 nitrogen oxide standard will be finalized by the end of 2002.

To encourage the marketing of vehicles that meet the new standards, the European Union has allowed its member states to develop tax incentives provided they apply to all new vehicles sold in a member state, cease when the new limit values are adopted, and do not exceed the cost of the new emissions-control technology. A recent proposal includes additional requirements: (1) introduction of an onboard diagnostic system for heavy-duty vehicle, (2) standards for the operational life of emissions-control devices, (3) standards for the conformity of in-service maintenance, and (4) even limits for pollutants resulting from the use of new alternate fuels. The Europeans are thorough, to say the least.

Regional Standards

Within each national or common market standards, there is typically some elbowroom for the adoption of region-specific standards by states, provinces, and member nations. Typically these revised standards tend to be more stringent, especially in high-density urban areas or geographically smoggy areas. Occasionally some areas have adopted less stringent standards, although this laxity usually results in a loss of federal funding for transportation projects.

California's South Coast Air Quality Management District (AQMD)

The California South Coast AQMD, which includes Los Angeles, still has the worst air pollution in the US. This reputation places the region in the forefront of new air-pollution-control initiatives. The greatest emphasis will be on exhaust from diesel engines, which the State of California has classified as a toxic air contaminant. Under programs administered by AQMD, California will provide funds to speed the introduction of low-emission, heavy-duty engines and vehicles. In 1999, AQMD converted more than 100 heavy-duty waste-transfer trucks to clean fuels. The trucks were converted from diesel fuel to compressed natural gas, or duel fuel (at 85% compressed natural gas or liquid natural gas mixed with no more than 15% diesel). Nearly half of the trucks received new engines, slightly more were retrofitted, and a few were replaced completely. The additional replacement of 800 heavy-duty diesel trucks was planned for 2000. Additional programs supplement this replacement program with research and development of cleaner engines and the creation of an alternate fuel infrastructure (natural-gas fueling stations). The emphasis in southern California remains on direct governmental action to replace dirtier engines rather than a reliance on the private sector to meet the air-quality goals by itself.

North Texas Metroplex

Earlier this year, EPA announced its approval of a tough air-pollution plan for the North Texas Metroplex (Dallas/Fort Worth urban region and surrounding areas). The proposed plan has set off a firestorm of controversy between advocates of clean air and business/consumer interests. A trade group representing engine manufacturers, landfill operators, and cement kilns is challenging the plan in court. Opponents site the excessive costs for equipment that future technology will render obsolete and the impact on workers who won't be able to work before the heat of midday. The plan will have a significant impact on waste collection and landfill disposal operations that typically peak during early morning hours. Landfill operators and waste-hauling lines will have to significantly adjust their operating schedules and staffing to meet this requirement.

The plan calls for reducing highway speed limits by 5 mph, creating more stringent smog emission tests, and–most importantly for landfill operating equipment and waste-hauling trucks–banning heavy diesel equipment on summer mornings. The last requirement is intended to reduce nitrogen-oxide emissions and subsequent ozone formation. The proposed standards are driven by the federal Clean Air Act (CAA), which allows no more than three ozone violations per three-year period. The Metroplex has averaged four ozone violations per year for the past 20 years, with 10 violations in 1999 alone.

British Columbia

British Columbia has instituted the "Cleaner Vehicles and Fuels Program," aimed primarily at smog producers and secondarily at GHGs. The new British Columbia vehicle emission standards require the same low-emission vehicle (LEV) standards adopted by California. The goal of the LEV program is to reduce by 70% the emissions of pre-1996 vehicles. Clean-technology vehicles are to make up 5% of vehicle sales in British Columbia by 2001 and 10% by 2003. The province's gasoline and diesel standards target benzene and sulfur contaminants. Its vehicle inspection and repair program ("Air Care") has been in place in smog-prone areas such as the Lower Fraser Valley and has resulted in significant reductions in nitrogen oxide (3%), volatile organic compounds (18%), and carbon oxide (24%).

Ontario

The requirements for heavy-duty vehicles and engines operating in Ontario reflect the tightly regulated emissions standards adopted in Canada. Ontario's (and Canadian) standards derive in part from goals established by EPA for heavy-duty diesel engine emission standards. Emissions have been reduced to such a point that it would now take eight of today's cleaner-operating, heavy-duty trucks to equal the emissions from a truck manufactured in 1987. Current Canadian regulations prohibit the use of diesel fuel with a sulfur content greater than 0.05% mass (1 part in 2000). As a result, off-highway transportation (such as diesel locomotives) accounts for the bulk of emissions. Strict enforcement of vehicle inspections, the "Ontario Drive Clean" program, has resulted in an average pass rate for emissions testing greater than 95%.

Significant Deviations From Federal Standards

As mentioned above, when significant local deviations from federal standards occur, more stringent regulations are likely to result. This is to be expected because federal standards tend to set a floor below which local enforcement agencies can go. Also, as is traditional in American environmental administration, it is up to the states (or their appointed regional commissions) to enforce standards, while EPA's main function is to set those standards. Two examples illustrate this point:

In November 2000, 13 states (California, Connecticut, Georgia, Maine, Massachusetts, Nevada, New Hampshire, New Jersey, New York, North Carolina, Rhode Island, Texas, and Vermont) tried to impose new controls on truck emissions by jointly adopting limits that are far stricter than federal rules. These states, which represent about 40% of the market for new trucks, aimed to adopt California's truck emissions and pollution standards. The CAA gives California, the state with the most severe air pollution, the right to draft its own emissions standards. It also gives other states the option to adopt them.

In a matter directly related to the waste-hauling industry, New York City, in a joint project with Cummins Inc., intends to reduce particle emissions from selected sanitary vehicles. The collaborative project will retrofit as many heavy-duty, waste-hauling trucks with advanced emissions control devices. To evaluate the effectiveness of the project and its technology, a sample of the advanced emissions-control devices will be tested for performance and durability. The projected emissions will meet standards that are stricter than federal requirements.

Effects of Emissions Regulations

In October 1999, a CAA settlement was reached between the Department of Justice and EPA and seven manufacturers of heavy-duty diesel engines (Caterpillar Inc., Cummins Engine Company, Detroit Diesel Corporation, Mack Trucks Inc., Navistar International Transportation Corporation, Renault Vehicles Industrial, and Volvo Truck Company). As part of the settlement, these companies are required to introduce and produce cleaner engines, rebuild old engines, recall certain types of trucks and heavy equipment, and conduct emissions testing. The result is a projected reduction of 75 million tons of nitrogen-oxide emissions over the next 27 years (equal to total US nitrogen-oxide emissions for three years). Individual efforts by each company are described below.

Equipment and Engines

There are several types of waste-collecting and -hauling trucks:

• Rolloff–so named because the container rolls off the flat bed of the truck
• Compactor box–which collects garbage and then compacts it to make room for more
• Open-top container–which is covered by a tarp and typically used for construction-site refuse
• Frontloader–which uses large arms, attached to the front of the truck, that are inserted into the side of a waste container for lifting
• Rearloader–which operates similar to the frontloader but with the arms attached to the back of the truck

Typical of many waste-hauling truck fleets is the Mack Truck Model MR powered by a diesel-fueled Mack E7-300 E-Tech (electronic) engine with a flywheel power rating of 300 hp and a maximum torque of 1,160 lb.-ft. at 1,200 rpm. The transmission is an Allison World HD4560P five-speed automatic. Allison also provides special refuse-service drivelines (1710 HD Main and 1710 HD Interaxle). Total operating weight is 18,130 lb. Mack also makes an LE model with a low-entry tilt cab featuring dual steering and a right-side, walk-in cab to improve the productivity of waste collection workers.

The Caterpillar 725 general-purpose articulated truck is also modified for waste hauling operations. The rated operating weight is 25 tons. The diesel-fueled Cat 3176C engine produces a net power of 280 hp. Their electronically controlled engines and transmissions have completely integrated drive systems equipped with an air-to-air after-cooled turbocharger. The electronically controlled module, ADEM 2000, reduces exhaust emissions and aids diagnostics, allowing these trucks to meet emissions standards to the end of 2002. A somewhat larger (30-ton) Cat 730 articulated truck can also be used for waste hauling operations.

Off-Road Operations

Off-road operations primarily deal with landfill operations and landfill construction efforts. Specialized compactors typically perform landfill disposal functions. Landfill construction operations utilize standard earthmoving equipment and rely on soil compactors to construct structural earthen berms and low-permeability soil liners.

The area method, where waste is disposed and compacted against previously deposited waste in a large disposal cell, is typically used for landfill operations handling 500 tpd or more. For a landfill of this size, a medium to large dozer (Cat D8R or equivalent) is required to spread deposited waste prior to compacting. The Cat D8R is powered by a 3406CTA engine with a flywheel power rating of 305 hp and operating at 2,100 rpm. The 3406CTA is a diesel-fueled, six-cylinder engine with a displacement of 893 in.³

The compactor of choice for waste compaction is the Cat 826G, a modified version of the standard Cat 825G soil compactor. The Cat 826G is powered by a 3406C DITA engine with a flywheel power rating of 315 hp and operating at 2,100 rpm. Similar to the 3406CTA, the 3406C DITA is a diesel-fueled, six-cylinder engine with a displacement of 893 in.³

Landfills are constructed using standard earthmoving equipment: medium and heavy dozers, articulated trucks, wheel loaders, soil compactors, trench excavators, wheeled/tractor scrapers and wheeled/tractor loaders. All are typically powered by six-cylinder, diesel-fueled engines with a flywheel power rating ranging from 200 to 400 hp. The horsepower rating for waste hauling and landfill equipment is important because emission standards are measured by grams of pollutants produced per break horsepower for each hour of operation.

Truck and Engine Manufacturers

The Detroit Diesel Corporation plans to introduce new-technology diesel engines by October 2002. The company's proposed technology employs cooled exhaust-gas recirculation to reduce oxides of nitrogen and hydrocarbon emissions. Detroit Diesel Corporation was the first diesel engine manufacturer to introduce cooled recirculation technology in 2000.

Mack Truck and its parent company, Renault Vehicle Industrial, continue to develop low-emission diesel engines. Although spurred by the 1999 settlement, this effort is part of an overall industry trend that has led to a 70% reduction of nitrogen-oxide emissions over the past 20 years. Meeting the final emission standards will be accomplished with Mack's E-Tech engine.

Navistar International Corporation's Green Diesel technology is available in southern California and wherever low-sulfur fuel is available. The new technology provides greater environmental benefits (reduced particulates and hydrocarbons) than any alternate fuel, including natural gas.

Renault Vehicle Industrial has contracted Borg Warner Turbo Systems to develop a new range of turbochargers for a new generation of diesel engines. Using turbochargers on smaller diesel engines has become state-of-the-art in Europe. The engines are proving to be superior to naturally aspirated gasoline engines in controlling emissions. Renault expects this trend to continue, with further advances pending.

Volvo Trucks has developed a hybrid truck designed for gross weights up to 15 tons. The truck, which is intended as a research platform for the development environmentally friendly trucks, is referred to as the "Environmental Concept Truck" (ECT). The ECT hybrid combines a gas turbine engine with an integrated high-speed generator. The high-speed generator produces a surplus of energy at low-power output. This energy is stored in batteries and can be later drawn from these batteries at high-power outputs. The gas turbine driving the generator can be driven by virtually any gas or liquid fuel, although Volvo chooses to power the ECT with ethanol. As a renewable fuel, ethanol use does not result in a net increase in carbon dioxide. Compared with the most efficient diesel engines currently available, the ECT produces 95% lower emissions of nitrogen oxide.

Construction Equipment and Engine Manufacturers

Caterpillar Inc. and Cummins Inc. have both proposed to EPA a plan that would reduce diesel engine emissions by all engine manufacturers two years ahead of schedule–by 2005 instead of 2007. The proposed plan would result in an additional reduction of 4 million tons of pollution. EPA prefers a regional approach to the nationwide plan proposed by Caterpillar and Cummins.

Cummins has the largest research and development department of any diesel engine manufacturer in the world. It intends to achieve the proposed air-quality standards through improvements in cylinder and piston design, turbocharging technology, electronic fuel injection and variable timing, and improvements in fuel characteristics. Cummins prefers these upgrades to potentially troublesome and maintenance-heavy exhaust after-treatment technologies such as catalytic converters. After 2004, the emphasis will be on developing exhaust-gas recirculation devices, split injection, and even higher injection pressures.

Waste Industry Truck Fleet Operators

Waste Management Inc., the country's largest waste management firm, is experimenting with liquid natural gas (LNG)—powered trucks. The project was initiated to evaluate the performance of LNG-fuel waste trucks and provide a database for further analysis and development of this alternate fuel. The performance of five waste-hauling trucks placed in service in the Washington, PA, service area was compared with three standard diesel-fuel trucks operating along the same collection and hauling routes. Preliminary results indicate that the LNG fleet performed as well as its diesel counterparts; however, the operators preferred the LNG trucks because the trucks have no diesel odor. Overall, the LNG trucks were more expensive to operate but produced lower emissions than the diesel trucks.

Conclusions

Heavy-duty diesel-engine technology is in a state of ferment. Technical developments designed to meet ever-stringent air emissions standards worldwide combine with multiple approaches by national and regional governments in enforcing these standards. No single solution or approach meets the air-quality needs of every community. These needs will be shaped by local conditions, economics, and politics. When the dust settles, however, two or three of the new diesel-engine technologies will likely prove themselves and dominate the trucking and equipment market.

Daniel P. Duffy, P.E., is a professional environmental engineer in Cincinnati, OH.