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Law, Nicole

From: Kevin Orellana <korellana@aqmd.gov>

Sent: Tuesday, May 03, 2016 7:50 AM

To: Law, Nicole

Cc: Gary Quinn

Subject: RE: Question on Engines under Rule 1110.2

Hi Nicole, 

I was finally able to get some information for you. The number of engines would be very likely 

the same as what I provided last year (email from 6/16/2015). These were the numbers: 

Biogas 58 

RECLAIM 88 

Non-RECLAIM 425 

TOTAL 571 

The information that I received for the Agricultural engines is that the total number of 

permitted stationary engines subject to Rule 1110.2 is three. These three engines that would 

be in the Non-RECLAIM category are all natural gas fueled and use NSCR (or three-way 

catalysts) to comply with the rule. Most of the Agricultural engines out there are emergency 

engines. Others have electrified and there are a handful (5 engines) that do not require 

permits but are registered under our Rule 222 program (Tier 0 engines). Other Agricultural 

engines have been decommissioned because the facilities are no longer in operation. 

As for the costs, here is an excerpt from the 2008 staff report for Rule 1110.2 (page 61): 

“As shown in Table 19, cost effectiveness figures for the proposed Step 1 and Step 2 

requirements are less than $20,000 per ton for all but four engine categories, and the overall 

cost effectiveness for all categories is about $5,650 per ton. Higher figures resulted for some 

of the lean-burn engine categories, with the highest figure being about $29,000 per ton.” 

The Step 2 requirements are those to meet 11 ppm NOx, 30 ppm VOC, and 250 ppm CO 

(corrected to 15% O2). Also worth noting is that the cost effectiveness back then was 

calculated over the course of a 10 year equipment life, a conservative assumption since 

engines are known to operate much longer. Please let me know if you would like any further 

detail. 

Sincerely, 

Kevin Orellana 

Air Quality Specialist 

Planning, Rule Development, and Area Sources 

South Coast Air Quality Management District 

21865 Copley Drive, Diamond Bar, CA 91765 

(909)396-3492 
2

From: Kevin Orellana 

Sent: Thursday, April 28, 2016 3:42 PM 

To: 'Law, Nicole' <Law.Nicole@epa.gov> 

Cc: Gary Quinn <GQuinn@aqmd.gov> 

Subject: RE: Question on Engines under Rule 1110.2 

Hi Nicole, 

Our IM group has been taking an unexpectedly long time to provide the information. I’m 

trying to gather the information through an alternate source, however. I will update you 

tomorrow. I do apologize for the delay. 

Sincerely, 

Kevin Orellana 

Air Quality Specialist 

Planning, Rule Development, and Area Sources 

South Coast Air Quality Management District 

21865 Copley Drive, Diamond Bar, CA 91765 

(909)396-3492 

From: Law, Nicole [mailto:Law.Nicole@epa.gov] 

Sent: Thursday, April 28, 2016 8:43 AM 

To: Kevin Orellana <korellana@aqmd.gov> 

Cc: Gary Quinn <GQuinn@aqmd.gov> 

Subject: RE: Question on Engines under Rule 1110.2 

Hi Kevin, 

I am checking in to see if you have any updates on the status of this inquiry? Thanks. 

Nicole 

From: Kevin Orellana [mailto:korellana@aqmd.gov] 

Sent: Tuesday, April 19, 2016 2:07 PM 

To: Law, Nicole <Law.Nicole@epa.gov> 

Cc: Gary Quinn <GQuinn@aqmd.gov> 

Subject: RE: Question on Engines under Rule 1110.2 

Nicole, 

To update you, I’m still waiting on some data from our Information Management group 

regarding the Ag equipment. I will send over the information as soon as I receive it. 

Sincerely, 

Kevin Orellana 

Air Quality Specialist 

Planning, Rule Development, and Area Sources 
3

South Coast Air Quality Management District 

21865 Copley Drive, Diamond Bar, CA 91765 

(909)396-3492 

From: Kevin Orellana 

Sent: Tuesday, April 12, 2016 5:04 PM 

To: 'Law, Nicole' <Law.Nicole@epa.gov> 

Subject: RE: Question on Engines under Rule 1110.2 

Hi Nicole, 

Just wanted to let you know that I’m working on gathering the information for you. I hope to 

get back to you in the next day or so. 

Sincerely, 

Kevin Orellana 

Air Quality Specialist 

Planning, Rule Development, and Area Sources 

South Coast Air Quality Management District 

21865 Copley Drive, Diamond Bar, CA 91765 

(909)396-3492 

From: Law, Nicole [mailto:Law.Nicole@epa.gov] 

Sent: Monday, April 11, 2016 9:41 AM 

To: Kevin Orellana <korellana@aqmd.gov> 

Subject: Question on Engines under Rule 1110.2 

Hi Kevin, 

I hope you’re well. I just left you a voicemail about this and this is my follow-up email. We are interested in getting 

information about sources that are required to comply with Rule 1110.2. Do you have recent estimates of the number 

of engines (and if possible engines used in agriculture) that are subject to and comply with the 11 ppmv limit in section 

(d)(1)(A) and (d)(1)(B) of Rule 1110.2? Additionally, do you have estimates on the costs for controls to achieve that 

limit? Thanks. 

Nicole 

Nicole Law

Rules Office, Air Division

U.S. EPA Region 9

75 Hawthorne Street

San Francisco, 94105

Office: (415) 947-4126

Fax: (415) 947-3579