NESHAP for Existing 

Stationary RICE Stationary RICE

Pr

o u gat o e g m

ulgation Bri

efin

g

Melanie King Melanie King

Energy Strategies Group

January 11, 2010
Introduction

 Status of rule (subpart ZZZZ): Status of rule (subpart ZZZZ):

 Proposed amendments published on 3/5/09 Final rule will be promulgated in 2 parts Signature dates for final rule per consent d

 2/10/10 for compression ignition (diesel) engin 8/ / p g (g 10/10 for spark ignition (gas-fired) g en ines

 This final rule affects existing CI engines at 

and area sources

 This final rule also revises SSM provisions fo

This final rule also revises SSM provisions fo

currently regulated by subpart ZZZZ

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Control technology basis

 Iss

u ou d o a da d o 

e: Should the emissi

on st

a

nda

r

ds f

or exis

non-emergency diesel engines >300 HP be badiesel particulate filter (DPF) in addition to oxidcatalyst control?

 Recommendation: 

 Finalize the rule based on oxidation catalyst a

crankcase emission control

 Lack of data to tie PM reductions to HAP reduction Feasibility and cost concerns for catalyzed DPF

 U d t k t ti t t bli h th U

n

der

t

a

ke a 

testing program 

to es

t

abli

s

h the 

performance capabilities of DPF, and compare oxidation catalyst for control of metallic HAP the residual risk and technology review for th

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2012. 
Emission limitations

 Received comments on data use

Received comments on data use

set MACT floor

 Floor based on data from one 1 00

Floor based on data from one

1

,00

engine

 Comments – not representative for 

small i er engines

 Received additional emissions data 

proposal that has been included in proposal that has been included in 

MACT floor analysis

 includes data for smaller engines

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Emergency engines

 Issue: What should the requirements be for eme

Issue: What should the requirements be for eme

engines?

 Proposed emission limitations but no performance 

to show compliance for emergency engines at maj

sources and 500 HP t d >500 HP a

t area sources

 Maintenance practices for <500 HP at area source

 Recommendation:

 Promulgate work practice standards for emergenc

at major sources based on section 112(h) of CAA

 Promul

g p 

ate maintenance 

practice standards for em

engines at area sources (all HP)

 Determine that residential/industrial/commercial 

emergency engines at area sources were not part original source category listing and are not subjec

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original source category listing and are not subjec
Emission requirements

Subcategory Emission limitation100

≤HP

≤300 at major 

source

157 ppmvd CO

300<HP

≤500 46 ppmvd CO or 

70% CO reduction

>500 HP 23 ppmvd CO or 

70% CO reduction

 Work/management practices for:

 <100 HP (major and area sources) emergency (major and area sources)

≤300 HP (area sources)

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Startup/shutdown/malfunction 

approach

 Issue: How should the final rule deal with the court d

Issue: How should the final rule deal with the court d

on SSM?

 Recommendation:

 Establish standards that apply continuously Same requirements apply during normal operation 

shutdown

 Separate requirements for startup Separate requirements for startup

 Emissions significantly different during startup Impracticable to prescribe numerical emission lim

during startup due to difficultly in obtaining repre

result f i i t ti d i t t lts 

from emissions 

testing 

during s

tar

tup

 Note that the SSM provisions will also be applicab

engines >500 HP at major sources that were prevre

gulated b

y sub

part ZZZZ

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g yp
Urban vs. rural distinction

 Issue: Should there be different standards 

Issue: Should there be different standards 

existing stationary area source CI engines in vs. rural locations?

 Recommendation: 

 National standard for area source CI engines National standard for area source CI engines

 Non-emergency engines >300 HP targeted f

emission control; emergency engines subjecmana

g p ement 

practices

 Existing CI engines evenly distributed betwe

and rural areas

 Co-benefit of PM reductions

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Environmental Justice 

Considerations

 While we have insufficient information to locate these 

While we have insufficient information to locate these 

down to the community level, we have elected to requcontrols on non-emergency engines >300HP in order provide a greater degree of protection to the public in 

urban and rural areas urban and rural areas

 We believe that stationary CI engines are evenly distribu

between urban and rural areas

 Given this even distribution and nationwide emission red

requirements presume even distribution of costs and ecrequirements, presume even distribution of costs and ec

impacts but no specific impacts available at the commun

 Benefits of rule are national estimates; we cannot provid

the community level

 C t d ith EDF i d EPA t l t Consen

t

decree with EDF require

d EPA

to regula

te non

emergency diesel engines >300 HP manufactured prio1996; this final rule goes beyond that to regulate the <300 HP and engines manufactured prior to 2002/200

(d di j / d i )

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(depending on ma

jor/area status an

d size

)
Costs and Economic Impact

 Estimated costs in 2013: Estimated costs in 2013:

 $744 million capital cost  $380 million annual cost (2008 dollars)

 Estimated emissions reductions in 2013: Estimated emissions reductions in 2013:

 1,010 tons HAP 2,800 tons PM (all of this is PM2.5

)

 5,100 tons SO

2

 14,300 tons CO 27,400 tons VOC Metallic HAP reduction (unable to quantify)

 Benefits and economic/small entity impacts not a

yet; will be completed early this week

 Expect higher impacts than for proposal since cost

engine are higher

– costs per firm will be higher

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engine are higher costs per firm will be higher