RICE NESHAP for the Diesel Engine Owner or Operator
What system considerations should you take into account before implementing your solution?
Now that you've determined your compliance requirement needs, there are some considerations to take into account before you establish a solution. Not all of these considerations may apply to your compliance needs.
Type of emission control technology
- The EPA approved technology for CO reduction are Diesel Oxidation Catalysts (DOCs)
- Seek a Diesel Oxidation Catalysts formulated for 70% reduction
- Standard catalysts are formulated for 90% reduction; more expensive
- Not all catalysts are created equal -Some formulations offer:
- Longer service life
- Longer service life
- More robust to catalyst poisons like sulfur
- How does a catalyst work?? Click here.
- If a combination Catalyst/Silencer system is selected due to back pressure and/or size restraints, select an integrated design.
- Integrated design
- Unibody design provides more structural integrity
- Longer service life
- Less leak points
- Lower back pressure
- Separate catalyst housing and silencer design
- Structural weak spot at catalyst-silencer connection point
- Additional point of possible exhaust gas leak
- Extra flanges = extra weight
- Integrated design

A diesel oxidation catalyst

An integrated silencer catalyst design (top) should be preferred versus a separate catalyst housing and silencer design (bottom).
Low Sulfur Diesel
- Do you currently use high sulfur fuel?
- If no, you're already compliant. Most diesel sold in the United States is now ultra low sulfur grade.
- If yes, you don't need to stop using it until the May 3rd, 2013 compliance date. However, make necessary steps to replace the fuel. If you will use up the current high sulfur supply before the compliance date, just make sure to order low sulfur diesel during your next delivery.
- Not sure? You can purchase a diesel sulfur test kit at your nearest engine supply store.
Engine back pressure requirements
- What is the maximum restriction that your engine can sustain?
You can locate this information on your engine's specification data sheet, or contact your engine's supplier for this information.
- What is current exhaust system back pressure?
A catalyst may add an additional 5-10" H20 of back pressure. If the engine can withstand the additional restriction, a catalyst can be inserted into the current exhaust system. However, if the addition of a catalyst exceeds the maximum allowable back pressure on the engine, other options need to be considered. A typical solution would be an integrated catalyst/silencer and removal of the current silencer. By combining the two devices, a more efficient system is produced.
Exhaust piping and supporting structure for emission control device
- Is there space in the current exhaust system?
There may be a straight run of piping that would provide an ideal place to insert the emission control device.
- Will exhaust gas reach 500°F at catalyst inlet?
RICE NESHAP requires that the catalyst reach at least 450°F. The temperature also needs to be continuously logged and reported for non-emergency engines greater than 500 HP. Universal recommends a 500°F operating temperature to ensure the proper treatment of exhaust gases to comply with the 70% CO reduction.
- Will a packed silencer be upstream of the catalyst? (Fibers)
Though not the ideal configuration, if space limitations require such an arrangement, a serviceable catalyst would be recommended to allow for periodic removal of fibers from the catalyst that may migrate from the upstream silencer. If you can't determine the style of the silencer, assume it is packed.
- Will placement of the emission control device provide readily accessible service points?
- As the emissions control device will require an initial performance test and 3 or 5 year follow up performance tests, it's recommended to place the unit where it can be reached without the use of lifts.
- If you are using a serviceable emission control device, your maintenance personnel will be required to remove the catalyst for cleaning and inspection. Consider OSHA and safety requirements and the additional costs to comply. If the emissions control device is high in the air, it may require a lift device, ladder and/or railings.
- If installed outside, will winter temperatures affect performance of the catalyst?
Keep in mind the worst case scenario in determining your RICE NESHAP compliance solution. Some regions in the United States can experience winter temperatures that may not allow the catalyst to operate at its required 500°F operating temperature. Insulation wrap or moving the catalyst closer to the engine are potential solutions.
Installation
- Can your technicians handle? Or will you want to outsource?
Analyze your in house capabilities carefully and the items needed to be performed to bring your engine into compliance. If your technicians are well versed on the operation of the engine, they may be capable of installing a crankcase ventilation system. If you have a staff member that understands structural support, you may be able to handle the installation of the emission control device. Electrical expertise will also be required if your compliance solutions requires a CPMS. However, keep in mind the liabilities this may present to engine as well as operations.
- When to schedule installation?
Whether you've decided to install the system yourself or contract it out, select a time that your operations will be down or your engine may already be taken out of service like an annual maintenance or major engine overhaul.
Monitoring of catalyst temperature and pressure drop
- CPMS (Continuous Parametric Monitoring System) required for recip engines 500 HP and above
- Temperature must be logged continuously
- Pressure drop must be logged monthly
- Sensors must be located in the catalyst housing before and after the catalyst. The monitor can be located remotely.
Catalyst service
- Do you require a serviceable or maintenance-free catalyst? If run hours are relatively low (less than 50 hrs per year), you should consider using a maintenance-free catalyst design.
- If using a serviceable catalyst, locate the access doors to a convenient and safe location.
- Does catalyst weight meet OSHA lifting requirements?
Compliance testing
- If you need to install a DOC, you will need to establish that you have met the CO reductions. Schedule the testing after the new system is installed.
- Testing needs to be in compliance to ASTM D6522-00. The test requires sample gases to calibrate the testing equipment. A hand held device will not meet the testing requirements that need to be sent to the EPA. Contract with a certified stack emissions testing company.

Analyze your in-house capabilities to bring your engine into compliance.
A CPMS (Continuous Parametric Monitoring System) is required for recip engines 500 HP and above


