1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2000 TRAVERWOOD ROAD

ANN ARBOR, MI 48105

- 2498

OFFICE OF

AIR AND RADIATION May 8, 2013

MEMORANDUM

SUBJECT: Potential Emissions Impact of the Transition Program for Equipment Manufacturers

(TPEM) Amendments

FROM: Angela Cullen, Mechanical Engineer

TO: Docket EPA

- HQ

- OAR

- 201 2

- 01 0 2

Background:

California Air Resources Board requested an analysis to quantify th e potential emissions impact of the

amendments to the Nonroad C ompression I gnited (CI) Transition Program for Equipment Manufacturers

( TPEM )

. The t echnical a mendment rule makes the following three change s to the Nonroad CI TPEM :

1. Small volume allowance : Today every equipment manufacturer may use TPEM which allows up

to 700 engines per engine line to meet the previous standard, with a limit of no more than 200

per year. Today’s technical hardship exemption allows non

- integrated manufacturers (with

appr oval) up to an additional 400 engines (for a total of 1,100 units ) and removes the annual

limit, but the relief expires in 24

- 36 months for engines <560kW and limited allowance for <37

kW . The technical amendment would remove the 1,100 per engine model li mit, which becomes

our discretion, and expands to all power categories. The amendment would also remove the

small business criteria to apply for a small volume allowance.

2. Percent of production allowance : Today each equipment manufacturer may use TPEM for 80%

of the production for an engine line for engines <560kW and limited allowance for <37 kW

. Today’s hardship exemption allows non

- integrated manufacturers (with approval) up to an
additional 70% (for a total of 150%) allowance and a 24 month period for using up allowances

for engines <560kW and limited allowance for <37 kW . The technical amendment rule would

remove the 70% cap, which now becomes our discretion, along with the 24 month expiration

period.

3. FEL cap : Today’s engines may not exceed the FEL c ap. The technical amendment would remove

the FEL cap and allow manufacturers to use their banked credits and sell engines with emissions2

above the FEL cap. We did not model the impact of this change because it is emission

- neutral

on a national basis.

Sum mary:

The technical amendments to TPEM could increase the national inventory in 2015 by as much as 45

metric tons of PM emissions and 714 metric tons of NMHC+NOx. To put these numbers in perspective,

the Nonroad Tier 4 program projected reductions of 48,297 metric tons of PM and 176,552 metric tons

of NOx . The amendments w ould reduce the emissions reductions of the nonroad Tier 4 program by less

than 0.1 to 0.4 percent.

Modeling Scenario:

We evaluated the potential emissions impact of the flexibilit ies that will become available through TPEM

amendments using the following assumptions and modeling information.

1. Assumptions:

a. We assumed that there will be no additional flexibilities approved for exemption

requests that have already been denied.

b. We evalua ted each of the approved exemption requests to identify the potential for

additional exemption requests based on the amendments.

c. We ev aluated each of the pending requests to determine the additional exemptions

which potentially could be approved if the exe mption is approved. It is worth noting

that we may not approve all of these requests.

2. Based on the assumptions above, Table 1 identifie s the engines that have the potential to

receive additional exemptions based on the amendments.

Table 1 : Potential Additional Engine Exemptions

Company Power

Category MY Additional

Engines

A 19

- 56 kW 2014 409

B 19

- 56 kW 2014 2590

C 56

- 130 kW 2014 67

D 56

- 130 kW 2014 0

2015 136

130

- 560 kW 2014 259

2015 228

E 130

- 560 kW 2013 281

2014 281

F 130

- 560 kW 2013 150

2014 150

2015 1503

3. If the additional exemption s are approved, then these engines would be required to meet Tier 3

standards (or Tier 2 standards for engines <56 kW) per 40 CFR 1039.625(e)(3) in lieu of the Tier 4

final standards. For engines which cover more than one power category, the standard used in

this analysis was assumed to be the average of the standard for each power category. Table 2

lists the standards with and without the exemption

.

4. Table 3 includes the activity factors associated with the equipment that could use engines that

may be exempted. The source classification code (SCC) was determined by identifying the

closest match to the equipment considered for the exemption. The median power was

calculated as the median power within the power range of engines . The load factor and annual

activity factors w ere taken from EPA’s NONROAD model (see page s A4

- A6 of

http://www.epa.gov/o taq/models/nonrdmdl/nonrdmdl2010/420r10016.pdf).4 Table 2 : Emissions Standards ( g / k W

- h r ) for Modeling Exemptions

With Exemption Without Exemption

Company Power

Category Emissions

Level NMHC

+NOx NMHC NOx PM Emissions

Level NMHC +NOx NMHC NOx PM

A 19

- 56 kW Tier 2 6.1

-- -- 0.50 Tier 4 final 4.7

-- -- 0.03

B 19

- 56 kW Tier 2 6.1

-- -- 0.50 Tier 4 final 4.7

-- -- 0.03

C 56

- 130 kW Tier 3 4.35

-- -- 0.35 Tier 4 final

-- 0.19 0.40 0.02

D 56

- 130 kW Tier 3 4.35

-- -- 0.35 Tier 4 final

-- 0.19 0.40 0.02

Tier 3 4.35

-- -- 0.35 Tier 4 final

-- 0.19 0.40 0.02

130

- 560

kW Tier 3 4.0

-- -- 0.20 Tier 4 final

-- 0.19 0.40 0.02

Tier 3 4.0

-- -- 0.20 Tier 4 final

-- 0.19 0.40 0.02

E 130

- 560

kW Tier 3 4.0

-- -- 0.20 Tier 4 final

-- 0.19 0.40 0.02

Tier 3 4.0

-- -- 0.20 Tier 4 final

-- 0.19 0.40 0.02

F 130

- 560

kW Tier 3 4.0

-- -- 0.20 Tier 4 final

-- 0.19 0.40 0.02

Tier 3 4.0

-- -- 0.20 Tier 4 final

-- 0.19 0.40 0.02

Tier 3 4.0

-- -- 0.20 Tier 4 final

-- 0.19 0.40 0.025 Table 3 : Activity Information for Non

- road Equipment

Activity and Load Fraction

Company Power

Category SCC SCC Description Products Median

Power (kW) Load Factor

(fraction of

power) Activity (hours

per year)

A 19

- 56 kW 2270006025 Diesel Light Commercial

Welders welders 37.5 0.21 643

B 19

- 56 kW 2270006025 Diesel Light Commercial

Welders welders 37.5 0.21 643

C 56

- 130 kW 2270002081 Diesel Other Construction

Equipment excavator,

compaction, skid steer 93 0.59 606

D 56

- 130 kW

2270002045 Diesel Cranes cranes 93 0.43 990

93 0.43 990

130

- 560 kW 345 0.43 990

345 0.43 990

E 130

- 560 kW 2270006015 Diesel Light Commercial

Air Compressors air compressor 345 0.43 815

345 0.43 815

F 130

- 560 kW 2270002081 Diesel Other Construction

Equipment off

- road snow plows

and dump trucks 345 0.59 606

345 0.59 606

345 0.59 6066

5. The potential annual impact of the technical amendments to the TPEM program nationally in
2015 could be as high as 45 metric tons of PM emissions and 714 metric tons of NMHC+NOx. To
put these numbers in perspective, the Tie r 4 program projected reductions of 53, 238 tons (48,297 metric tons) of PM and 19 4

, 615 tons (176,552 metric tons) of NOx (per Table 3.5

- 1b,
Final Regulatory Impact Analysis, http://www.epa.gov/otaq/documents/nonroad

diesel/420r04007.pdf )

. Table 4 p rovides the annual national emissions impact of the provisions
in 2015 for each of the companies.

Table 4 : Potential Emissions Impact of Technical Amendments to TPEM

Annual Emissions Difference

- 2015

Company Power

Category PM

(metric tons) NMHC+NOx

(metric tons)

A 19

- 56 kW 1 3

B 19

- 56 kW 6 18

C 56

- 130 kW 1 8

D 56

- 130 kW 0 0

2 20

130

- 560 kW 7 130

6 114

E 130

- 560 kW 6 116

6 116

F 130

- 560 kW 3 63

3 63

3 63