NESHAP for ExistingStationary RICEStationaryRICEPromulgation Briefingu gat o e gMelanie KingMelanieKingEnergy Strategies GroupJanuary 11, 2010IntroductionStatus of rule (subpart ZZZZ):Statusofrule(subpartZZZZ):Proposed amendments published on 3/5/09Final rule will be promulgated in 2 partsSignature dates for final rule per consent decree2/10/10 for compression ignition (diesel) engines8/10/10 for spark ignition(gas-fired)enines/ p g (ggThis final rule affects existing CI engines at majorand area sourcesThis final rule also revises SSM provisions for enginesThisfinalrulealsorevisesSSMprovisionsforenginescurrently regulated by subpart ZZZZDRAFT - DO NOT CITE OR QUOTE 2Control technology basisIssue: Shouldthe emission standards for existingou d o a da d o gnon-emergency diesel engines >300 HP be based ondiesel particulate filter (DPF) in addition to oxidationcatalyst control?Recommendation:Finalize the rule based on oxidation catalyst andcrankcase emission controlLack of data to tie PM reductions to HAP reductionsFeasibility and cost concerns for catalyzed DPFU d t k t ti t t bli h thUndertake atesting programto establishtheperformance capabilities of DPF, and compare it tooxidation catalyst for control of metallic HAP prior tothe residual risk and technologyreview for this rule inDRAFT - DO NOT CITE OR QUOTE 32012.Emission limitationsReceived comments on data used toReceivedcommentsondatausedtoset MACT floorFloor based on data from one 1 000 HPFloorbasedondatafromone1,000HPengineComments – not representative forll ismaer enginesReceived additional emissions data postproposal that has been included in theproposalthathasbeenincludedintheMACT floor analysisincludes data for smaller enginesDRAFT - DO NOT CITE OR QUOTE 4Emergency enginesIssue: What should the requirements be for emergencyIssue:Whatshouldtherequirementsbeforemergencyengines?Proposed emission limitations but no performance testingto show compliance for emergency engines at majord 500 HP tsources and>500HPatarea sourcesMaintenance practices for <500 HP at area sourcesRecommendation:Promulgate work practice standards for emergency enginesat major sources based on section 112(h) of CAAPromulgate maintenancepractice standards for emergencyp gyengines at area sources (all HP)Determine that residential/industrial/commercialemergency engines at area sources were not part oforiginal source category listing and are not subject to ruleDRAFT - DO NOT CITE OR QUOTE 5originalsourcecategorylistingandarenotsubjecttoruleEmission requirementsSubcategory Emission limitation100≤HP≤300 at majorsource157 ppmvd CO300<HP≤500 46 ppmvd CO or70% CO reduction>500 HP 23 ppmvd CO or70% CO reductionWork/management practices for:<100 HP (major and area sources)emergency (major and area sources)≤300 HP (area sources)DRAFT - DO NOT CITE OR QUOTE 6Startup/shutdown/malfunctionapproachIssue: How should the final rule deal with the court decisionIssue:Howshouldthefinalruledealwiththecourtdecisionon SSM?Recommendation:Establish standards that apply continuouslySame requirements apply during normal operation andshutdownSeparate requirements for startupSeparaterequirementsforstartupEmissions significantly different during startupImpracticable to prescribe numerical emission limitationsduring startup due to difficultly in obtaining representativelt f i i t ti d i t tresultsfrom emissionstestingduring startupNote that the SSM provisions will also be applicable toengines >500 HP at major sources that were previouslyregulated bysubpart ZZZZDRAFT - DO NOT CITE OR QUOTE 7g ypUrban vs. rural distinctionIssue: Should there be different standards forIssue:Shouldtherebedifferentstandardsforexisting stationary area source CI engines in urbanvs. rural locations?Recommendation:National standard for area source CI enginesNationalstandardforareasourceCIenginesNon-emergency engines >300 HP targeted foremission control; emergency engines subject tomanagementpracticespExisting CI engines evenly distributed between urbanand rural areasCo-benefit of PM reductionsDRAFT - DO NOT CITE OR QUOTE 8Environmental JusticeConsiderationsWhile we have insufficient information to locate these enginesWhilewehaveinsufficientinformationtolocatetheseenginesdown to the community level, we have elected to requirecontrols on non-emergency engines >300HP in order toprovide a greater degree of protection to the public in bothurban and rural areasurbanandruralareasWe believe that stationary CI engines are evenly distributedbetween urban and rural areasGiven this even distribution and nationwide emission reductionrequirements presume even distribution of costs and economicrequirements,presumeevendistributionofcostsandeconomicimpacts but no specific impacts available at the community levelBenefits of rule are national estimates; we cannot provide them atthe community levelC t d ith EDF i d EPA t l tConsentdecree withEDFrequiredEPAto regulate nonemergency diesel engines >300 HP manufactured prior to1996; this final rule goes beyond that to regulate the engines<300 HP and engines manufactured prior to 2002/2006(d di j / d i )DRAFT - DO NOT CITE OR QUOTE 9(depending on major/area status andsize)Costs and Economic ImpactsEstimated costs in 2013:Estimatedcostsin2013:$744 million capital cost$380 million annual cost (2008 dollars)Estimated emissions reductions in 2013:Estimatedemissionsreductionsin2013:1,010 tons HAP2,800 tons PM (all of this is PM2.5)5,100 tons SO214,300 tons CO27,400 tons VOCMetallic HAP reduction (unable to quantify)Benefits and economic/small entity impacts not availableyet; will be completed early this weekExpect higher impacts than for proposal since costs perengine are higher–costs per firm will be higherDRAFT - DO NOT CITE OR QUOTE 10enginearehighercostsperfirmwillbehigher