Non-road diesel emissions management and the implications of the NSW regulatory proposals

Transcription

1 Non-road diesel emissions management and the implications of the NSW regulatory proposals Rio Tinto Coal Australia Stuart Ritchie Manager Environment 14 August, 2017

2 Outline Emissions management challenges for Rio Tinto and the mining industry RTCA s emissions and fuel efficiency programmes and learnings NSW non-road diesel policy approach Current policy status

3 Emissions management challenges for Rio Tinto and the mining industry

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5 Our actions to address climate change: We have set quantified emissions intensity reduction goals. We are working to reduce our emissions intensity We are seeking a substantial decarbonisation of the business by We are adapting to climate change. We recognise the value of action on climate change.. We work with others.. [Extract from Rio Tinto s Climate Change Position Statement]

6 ... protecting the environment Our other environmental responsibilities include managing risks and impacts from air emissions and non-mineral waste In these areas we aim to protect human health and the environment. We work with neighbouring communities to understand any impacts and further improve our practices.

7 High horsepower diesel equipment Rio Tinto RTCA

8 RTCA: fuel savings and emissions reduction programme 2012: fuel savings programme commenced as part of a larger internal transformation project ideas were generated internally and in collaboration with OEMs ideas were prioritised on the basis of value and effort projects constrained by limited CAPEX due to coal prices projects focused on open-cut operations - three major streams of activity commenced Project progress 2013: early win projects were completed in 2012 and : projects with proven technical feasibility progressed 2015: initiation of projects with robust technical feasibility 2017/18: ongoing assessment/implementation technologies arising

9 Stream 1: Carbon optimised engine software These software updates typically increase engine combustion temperatures with a resultant fuel efficiency improvement but also a beneficial spin-off outcome of reduced PM 2.5 emissions CAT: Less Regulated Country (LRC) flashfiles MTU: Fuel Combustion Optimised (FCO) calibration Cummins: Fuel Emission Optimised (FEO) calibration

10 Stream 2: Engine Power Optimisation (EPO) Energy Usage 11% 10% 26% 53% Loaded Dynamic Braking Stationary Idle Transient

11 Stream 3: Other potential high-value projects Fuel additives Operator behaviour Multiple Injection Event (MIE) technology; e.g. repower of D11R dozers (CAT 3508 to CAT C32 engine models) = CO 2 1,600 t; DPM 71%, NOX 28% Repower of 830E from QSSK-60 HPI to QSK-60 MCRS/MTU C21

12 NSW EPA: non-road diesel policy approach

13 NSW EPA approach to diesel exhaust emissions 2014 June 2014 Diesel Emissions Management Workshop Dec 2014 NSW Coal Mining Benchmarking Study, Final Draft Report included a CBA for reducing NRD particulate matter Final report released in 2015 Project Scope Review International best practice Conduct a survey of EPA-licensed premises Complete a Cost Benefit Analysis (CBA) Implement findings through a Pollution Reduction Program (PRP)

14 NSW EPA approach to diesel exhaust emissions 2016 June Coal Mine Diesel Emissions Industry Information Workshop; draft PRP provided to industry requiring: site specific BPM determination for all existing in-service equipment between 8 and 560 kw + baseline assessment of PM 2.5 & NO x emissions; a Fleet Management Plan to reduce PM 2.5 emissions by 25% (fleet-total kg/kl basis); all new NRD purchased from 1 Jan 2019 to meet latest USEPA Tier 4 standard annual progress reporting October Clean Air for NSW consultation paper released references ongoing EPA proposals in relation to NRD

15 Initial PRP draft - RTCA concerns Inefficient point of regulation Inability of operators to influence engine/emissions technology Market interference resulting in unintended consequences Inequitable baseline definition Industry has already moved, particularly in relation to fuel efficiency optimisation increasing the task to achieve a 25% reduction Excessive administrative burden/emissions data shortcomings Significant reporting effort and reliance on OEM data/ inability to cost-effectively measure performance Multiple/ potentially conflicting regulatory objectives NO x inclusion dramatically increases potential cost and technical difficulty - counterproductive Inadequate case for regulation Exhaust emissions contributing < 5% PM 2.5 at Singleton/Muswellbrook

16 Second PRP draft - RTCA concerns Definition of included fleet (80:20 rule) Suggested 30 L engine capacity lower threshold to pick up 85%-90% of site total fuel burn Included fleet - contractor exemptions Suggested to be framed around a materiality trigger (10% total fuel usage basis) rather than the proposed 3 month engagement duration

17 Second PRP draft - RTCA concerns Definition of included fleet (80:20 rule) Suggested 30 L engine capacity lower threshold to pick up 85%-90% of site total fuel burn Included fleet - contractor exemptions Suggested to be framed around a materiality trigger (10% total fuel usage basis) rather than the proposed 3 month engagement duration

18 Second PRP draft key industry concerns Timeframes Suggested 8 months for initial PRS development rather than 4 months (esp. given substantial information to be sourced from 3rd parties) Exemptions approval scope EPA process for non-compliant equipment approval not defined - suggested inclusion of tests of commercial competitiveness, equipment suitability, cost-benefit analysis, adverse/unintended consequences Date of adoption of US EPA Tier 4 Standards Proposed 31 December 2021 to allow for Tier 4 Standard compliant equipment to be proven under service conditions Verification Concerns raised re lack of emissions performance certification/ verification information

19 Current status Status/ learnings NSW EPA still deliberating on final PRP outcome further consultation with OEMs and other third party providers Acknowledge a constructive consultation process (albeit lengthy) with greater understanding by all parties and a much more pragmatic outcome anticipated Industry needs to be able to recognise where environmental improvement opportunities exist and act accordingly