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### MEMORANDUM DATE: August 8 , 2010 SUBJECT: Impacts Associated with NESHAP for Existing Stationary SI RICE FROM: Bradley

Nelson and Tanya Parise , EC/R, Inc. TO: Melanie King , EPA OAQPS/SPPD/ESG

1.0 PURPOSE The purpose o f this memorandum is to provide an estimate of the cost impacts and the emission reductions of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for existing spark ignition ( S I) stationary reciprocating internal combustion engines (RICE). The regulation applies to existing stationary S I RICE that are less than or equal to 500 horsepower (HP) located at major sources and all existing SIRICE at area sources of hazardous air pollutants (HAP) emissions . Impacts discussed in this memorandum include emissions reductions and total costs associated with the regulatory requirements that will be promulgated under 40 CFR part 63, subpart ZZZZ . Costs associated with the final rule include the capital and annual cost of purchasing and operating air pollution control equipment, recordkeeping, reporting, and performance testing. The total capital cost associated with the NESHAP for existing stationary S I RICE is estimated to be $ 383 million in the year 201 3 . The total annual cost of the NESHAP is estimated to be $ 2 53 million in the year 2013. The NESHAP for existing stationary SI RICE is estimated to reduce HAP emissions in the year 2013 b y 6,000 tons per year (tpy).

### 2

2.0 ENGINE POPULATION The existing population of S I engines in the U.S. was estimated using information obtained from the Power System Research’s (PSR) North American Engine PartsLink Database provided b y the U.S. EPA Office of Transportation and Air Quality. The number of affected SI engines was estimated using population and engine sales information from PSR. 1 , 2 

### Inaddition to the PSR data , EPA received SIengine population data from the U.S. Department of Agriculture (USDA) that provided a summary of SIengines used as irrigation sets by fuel ty pe and engine size from the Nati onal Agriculture Statistics Service (NASS) . This NASS estimates were used in lieu of the information from PSR for irrigation sets. According to USDA, the majority of irrigation sets are located at area sources. Therefore, it was assumed that 95 percent of existing SIengines that are irrigation sets are located at area sources. Itwas also assumed that 95 percent of existing SIengines used for gas compression are located at area sources, based on information from the natural gas transmission industry. 3 

### For all other industries and applications, it was assumed that 60 percent of existing SIengines are located at area sources. The number of affected S I engines is presented in Table 1 . Table 1. Number of Affected Engines a 

### Size Range (HP) Major Source s Area Sources 25 - 50 55,842 91,709 50 - 100 14,955 39,447 100 - 175 23,679 48,539 175 - 300 5,104 17,393 300 - 500 3,148 12,499 500 - 600 N/A 6,250 600 - 750 N/A 1,071 >750 N/A 11,411 Total 102 , 729 228,318 a

### Engines subject to this rule are existing SI engines constructed before 6/12/2006 that are less than or equal to 500 HP and located at major source and existing SI engines constructed before 6/12/2006 and located at area sources.

1 Memorandum from Tanya Parise, Alpha- Gamma Technologies, Inc. to Jaime Pagán, EPA Energy Strategies Group, Existing Population of Stationary RICE, June 26, 2008. 2 Memorandum from Tanya Parise, EC/R to Melanie King, EPA. Existing Population of Stationary RICE Attachments. February 10, 2010. 3 Letter from the American Petroleum Institute to EPA. Support for Use of Management Practices in the National Emission Standards for Hazardous Air Pollutants Standards for Reciprocating Internal Combustion Engines at Area Sources in Rural Locations . November 2009.

### 3

3.0 COST IMPACTS The cost impacts associated with the final rule include the annual and capital costs of controls, costs associated with keeping records of information necessary to demonstrate compliance, costs associated with reporting requirements under the General Provisions of 40 CFR part 63, subpart A, costs of purchas ing and operating equipment associated with continuous parametric monitoring, and the cost of conducting performance testing to demonstrate compliance with the emission standards. The following sections describe how the various cost elements were estimate d. Control Costs For certain engines, the final rule sets emission standards based on the use of oxidation catalyst and non- selective catalytic reduction (NSCR) . For engines that will need to add control technology

to meet the emission standards, the f ollowing equations were used to estimate capital and annual control costs: HAP Control Technology Capital Cost ($200 9) Annual Cost ($200 9) Oxidation Catalyst (4SLB) $12.8 x HP + $3,069 $1.81 x HP + $3,442

NSCR $24.9 x HP + $13,118 $4.77 x HP + $5,679 The above control cost equations were calculated using retrofit cost data received from industry groups, vendors, and manufacturers of engine control technology . Documentation for how these control cost equations were developed is presented in a memorand um available from the rulemaking docket . 4 

### The final rule emission standards are shown in Table 2. Engines not shown in Table 2 are not subject to numerical emission standards in the final rule, but must meet work practice or management practice s instead. For engines located at major sources of HAP, it is expected that owners and operators of existing non- emergency 2SLB engines between 100 HP and 500 HP, existing non- emergency

4SRB engines between 100 HP and 5 00 HP, and landfill/digester gas engines wil l be able to meet the emission limitation without adding any aftertreatment controls. Therefore, no control costs were attributed to these engines. Existing non- emergency

4SLB engines between 10 0 HP and 500 HP at major sources and existing non- emergency 4S LB engines greater than 500 HP at area sources are expected to use an oxidation catalyst in order to meet the emission standards. Costs estimated for these engines include the cost of installing and operating an oxidation catalyst for reducing HAP emi ssions . It was assumed that 5 percent of the existing population of 4SLB engines already have add- on controls for HAP reduction , which is based on information available from the RICE Population Database . 4 Memorandum from Bradley Nelson, EC/R to Melanie King, EPA OAQPS/SPPD/ESG, Control Costs for Existing Stationary SI RICE, June 29 , 2010.

### 4

Existing non- emergency

4SRB engines greater than 50 0 HP at area sources are expected to use NSCR in order to meet the emission standards. Costs estimated for these engines include the cost of installing and operating NSCR for reducing HAP emissions , assuming that 20 percent of the existing population alre ady have add- on controls for HAP reduction . The percentage of existing 4SRB engines currently operating with add- on controls used to estimate impacts is based on information from different sources, including information from different EPA Regional Offices , the RIC E Population Database, and control technology vendors . Table 2 . Final Emission Standards Subcategory Applicable Standard (except during periods of startup) Aftertreatment Required to Meet Standard 2SLB Non- Emergency 100≤HP≤500 at major sources 22 5 ppmvd CO at 15% O 2 

### None 4SLB Non- Emergency 100≤HP≤500 at major sources 4 7 ppmvd CO at 15% O 2 

### Oxidation Catalyst 4SRB Non- Emergency 100≤HP≤ 5 00 at major sources 10.3 ppmvd CH2 

### O at 15% O 2 

### None Landfill/Di gester Gas Non- Emergency

100≤HP≤500 at major sources 177 ppmvd CO at 15% O 2 

### None 4SLB Non- Emergency

>500 HP at area sources 4 7 ppmvd CO at 15% O 2 

### or 93% CO reduction Oxidation Catalyst 4SRB Non- Emergency

>500 HP at area sources 2.7 ppmvd CH2 

### O at 15% O 2 

### or 76% CH2 

### O reduction NSCR

### 5

Performance Testing Existing stationary

SI RICE subject to numerical emission standards under the final rule must conduct an initial performance test to demonstrate that the standards are being met. Owners and operators o f SI engines that are not subject to any numerical emission standards are not subject to any testing requirements , which includes existing stationary SIengines less than 100 HP at major sources and existing stationary emergency

SI engines less than or equal to 500 HP at major sources , as well as existing stationary SIengines at area sources (except nonemergency

4SLB engines greater than 500 HP and non- emergency engines 4SRB greater than 500 HP) . The following non- emergency existing stationary

SI engines are subject to testing under the final rule:

 2SLB 100≤HP≤500 located at major sources,  4SLB 100≤HP≤500 located at major sources,  4SRB 100≤HP≤500 located at major sources,  Landfill/digester gas 100 ≤HP≤500 located at major sources,  4SLB >500 HP located at area sources, and  4SRB >500 HP located at area sources. The cost of conducting carbon monoxide (CO) performance testing for 2SLB and 4SLB engines is based on the cost of portable analyz er testing and is estimated to be $1,000 per day . It was assumed that 2 engines could be tested each day using the porta

ble analy zer, therefore the costs per engine was estimated to be $500. The testing costs are based on information previously obtained from engine testing firms and summarized in the memorandum “Portable Analyz er Testing Costs.” 5 

### The cost of conducting f ormaldehyde performance testing for non- emergency 4SRB engines was estimated to be $2,000 per day, with two engines being tested per day . Therefore the testing cost was estimated to be $1,000 per engine for formaldehyde testing. Recordkeeping Recordke eping costs were calculated assuming 1 hour per ye ar for each existing SI engine. The costs are attributed to the requirement of following the manufacturer’s emissionrelated operation and maintenance (O&M) requirements or the owner /operator ’s own maintenance plan. It is expected that the majority of owner /operators are already following some ty pe of O&M requirements and minimal to no additional burden is expected. A technical labor rate of $ 73 per hour was used to estimate the cost and is based on technical labor rates obtained from the Bureau of Labor Statistics . 6 

### All costs were converted to 200 9 dollars for purposes of presenting costs associated with the rule in present day terms. The recordkeeping cost for emergency

SI engines is estimated to be 1 hour per year to record the number of hours the emergency

engine is operated.

5 Memorandum from Bradley Nelson , Alpha - Gamma Technologies, Inc. to Sims Roy, EPA/OAQPS/ESD/Combustion Group , Portable Emissions Analyzer Cost Information, August 31 , 200 5. 6 http://www.bls.gov/news.release/ecec.toc.htm

### 6

Reporting Certain non- emergency engines affected b y this rule will be subject to reporting requirements such as reading instructions, training personnel, submitting an initial notification, submitting a notification of perfor mance test(s), and submitting semi - annual compliance reports . It is estimated that a total of 14 hours will be needed, where 4 hours are expected to be used for reading the rule, 4 hours are estimated to be used for training, and 6 hours are expected to be used for preparing and submitting notifications and compliance reports . Owners and operators of SI engines that are not subject to any numerical emission standards are not subject to any reporting requirements. This includes existing emergency SI engines less than or equal to 500 HP located at major sources , existing SIengines less than 100 HP located at major sources , and existing SIengines at area sources (except non- emergency 4SLB greater than 500 HP and nonemergency

4SRB greater than 500 HP) . The following non- emergency existing stationary

SI engines are subject to reporting requirements under the final rule:

 2SLB 100≤HP≤500 located at major sources,  4SLB 100≤HP≤500 located at major sources,  4SRB 100≤HP≤500 located at major sources,  4SLB >500 HP located at area sources , and  4SRB > 500 HP located at area sources. Monitoring The cost of monitoring includes the purchase of a continuous parametric monitoring system (CPMS). Existing non- emergency 4S LB greater than 500 HP at area sources and existing non- emergency 4SRB engines greater than 5 00 HP at area source s that have add- on controls are required to use a CPMS to monitor the catalyst inlet temperature and pressure drop across the catalyst to ensure those parameters do not exceed the operating limitations. The cost of purchasing and operating a CPMS was obtained from vendor quotes received for previous rulemaking and adjusted to current a cost of $568 . 7 

### Itis estimated that 30 hours per year is ne cessary to operate and maintain the CPMS and that 6 hours per ye ar (or 0.5 hours per month) is needed to record information from the CPMS. There are no costs associated with monitoring for emergency

engines. Summary of Costs The total costs estimated for the final rule requirements include the purchase, installation, and operation of aftertreatment controls and monitoring equipment, performance testing, and the costs associated with recordkeeping, notification, and reporting requirements. The total estimated costs associated with the final rule in the year 2013 are presented in Table 3 through Table 7.

7 Part A of the Supporting Statement for Standard Form 83 Stationary Reciprocating Internal Combustion Engines, November 17, 2003.

### 7 Table 3 . Summary of Major Source and Area Source Costs for the S I RICE NESHAP 1 Size Range (HP) Capital

Control Cost Annual

Control Cost Initial Test Recordkeeping Reporting Monitoring

- Capital Cost Monitoring

- Annual Cost Total

Annual Costs Total Capital

Costs Major Sources 2 5 - 5 0 $0 $0 $0 $4,060,795 $0 $0 $0 $4,060,795 $0 50 - 100 $0 $0 $0 $1,087,540 $0 $0 $0 $1,087,540 $0 100 - 175 $48,502,361 $37,071,061 $15,971,384 $1,721,899 $5,725,314 $0 $0 $60,489,657 $48,502,361 175 - 300 $13,225,919 $8,382,568 $3,442,648 $371,157 $1,234,097 $0 $0 $13,430,470 $13,225,919 300 - 500 $ 10,934,795 $ 5,562,872 $2,123,326 $228,919 $761,155 $0 $0 $ 8,676,272 $ 1 0,934,795 500 - 600 $0 $0 $0 $0 $0 $0 $0 $0 $0 600 - 750 $0 $0 $0 $0 $0 $0 $0 $0 $0 >750 $0 $0 $0 $0 $0 $0 $0 $0 $0 Total $ 72,663,076 $5 1,016,500 $21,537,358 $7,470,310 $7,720,566 $0 $0 $ 87,744,734 $72,663,076 Area Sources 2 5 - 5 0 $0 $0 $0 $6,668,9 44 $0 $0 $0 $6,668,944 $0 50 - 100 $0 $0 $0 $2,868,511 $0 $0 $0 $2,868,511 $0 100 - 175 $0 $0 $0 $3,529,711 $0 $0 $0 $3,529,711 $0 175 - 300 $0 $0 $0 $1,264,799 $0 $0 $0 $1,264,799 $0 300 - 5 00 $0 $0 $0 $908,913 $0 $0 $0 $908,913 $0 5 00 - 600 $75,474,33 1 $26,628,053 $3,655,719 $454,493 $1,264,260 $2,821,013 $13,003,822 $45,006,347 $78,295,345 600 - 750 $15,222,363 $5,052,207 $652,400 $77,882 $225,620 $503,438 $2,320,662 $8,328,771 $15,725,801 >750 $210,754,181 $62,143,967 $6,951,011 $829,795 $2,403 ,874 $5,363,896 $24,725,562 $97,054,209 $216,118,077 Total $301,450,875 $93,824,227 $11,259,129 $16,603,048 $3,893,754 $8,688,347 $40,050,046 $165,630,205 $310,139,222 Grand Total $ 374,113,951 $1 44,840,727 $32,796,487 $24,073,358 $11,614,321 $8,688,347 $ 40,050,046 $2 53,374,939 $ 382,802,298 a 

### Costs are presented in 200 9 dollars.

### 8 Table 4 . Summary of Major Source and Area Source NAICS Costs for the S I RICE NESHAP 1 NAICS Major Source Area Source Total (Major + Area) Capital Cost Annual Cost Capital Cost Annual Cost Capital Cost Annual Cost Electric Power Generation (2211) $52,905,258 $63,062,494 $120,301,416 $65,334,028 $173,206,675 $128,396,522 Natural Gas Transmission (48621) $1,484,494 $1,462,530 $140,977,276 $67,467,484 $142,461,771 $68,930,015 Cr ude Petroleum & NG Production (211111) $4,561,236 $6,138,383 $732,943 $1,258,072 $5,294,179 $7,396,454 Natural Gas Liquid Producers (211112) $4,561,236 $6,138,383 $732,943 $1,258,072 $5,294,179 $7,396,454 National Security (92811) $5,878,362 $7,006,944 $ 13,366,824 $7,259,336 $19,245,186 $14,266,280 Hydro Power Units (335312) $0 $25,248 $0 $37,872 $0 $63,120 Irrigation Sets (335312) $3,025,050 $3,230,856 $34,027,819 $22,445,211 $37,052,869 $25,676,067 Welders (333992) $247,440 $679,896 $0 $570,130 $247, 440 $1,250,027 Total $72,663,076 $87,744,734 $310,139,222 $165,630,205 $382,802,298 $253,374,939 a Costs are presented in 200 9 dollars.

### 9 Table 5 . Summary of Major Source and Area Source NAICS Costs for the S I RICE NESHAP

– by Size 1 NAICS Major Source A rea Source Total (Major + Area) Capital Cost Annual Cost Capital Cost Annual Cost Capital Cost Annual Cost Electric Power Generation (2211) 25 - 50 hp $0 $2,758,459 $0 $4,137,688 $0 $6,896,147 50 - 100 hp $0 $606,144 $0 $909,215 $0 $1,515,359 100 - 175 hp $33,868,173 $42,238,648 $0 $1,803,548 $33,868,173 $44,042,196 175 - 300 hp $10,603,849 $10,767,847 $0 $446,361 $10,603,849 $11,214,209 300 - 500 hp $8,433,236 $6,691,397 $0 $264,820 $8,433,236 $6,956,217 500 - 600 hp $0 $0 $26,390,293 $15,169,876 $26,390,293 $15,169,876 600 - 750 hp $0 $0 $5,325,628 $2,820,584 $5,325,628 $2,820,584 >750 hp $0 $0 $88,585,495 $39,781,934 $88,585,495 $39,781,934 Total Electric Power Generation 2211 $52,905,258 $63,062,494 $120,301,416 $65,334,028 $173,206,675 $128,39 6,522 Natural Gas Transmission (48621) 25 - 50 hp $0 $102 $0 $1,934 $0 $2,036 50 - 100 hp $0 $4,872 $0 $92,571 $0 $97,443 100 - 175 hp $301,721 $376,291 $0 $203,518 $301,721 $579,809 175 - 300 hp $643,157 $653,104 $0 $342,928 $643,157 $996,032 30 0 - 500 hp $539,617 $428,162 $0 $214,637 $539,617 $642,799 500 - 600 hp $0 $0 $19,975,323 $11,482,372 $19,975,323 $11,482,372 600 - 750 hp $0 $0 $9,808,436 $5,194,789 $9,808,436 $5,194,789 >750 hp $0 $0 $111,193,518 $49,934,735 $111,193,518 $49,934,735 Total Natural Gas Transmission (48621) $1,484,494 $1,462,530 $140,977,276 $67,467,484 $142,461,771 $68,930,015 Crude Petroleum & NG Production (211111) 25 - 50 hp $0 $388,115 $0 $582,173 $0 $970,288 50 - 100 hp $0 $66,698 $0 $100,047 $0 $166,744 100 - 175 hp $4,549,775 $5,674,246 $0 $242,285 $4,549,775 $5,916,531 175 - 300 hp $1,037 $1,053 $0 $44 $1,037 $1,096 300 - 500 hp $10,424 $8,271 $0 $327 $10,424 $8,598 500 - 600 hp $0 $0 $32,184 $18,500 $32,184 $18,500

### 10

Table 5. Summary of Major Source and Area Source NAICS Costs for the SI RICE NESHAP

– by Size 1 

### (cont’d) 600 - 750 hp $0 $0 $0 $0 $0 $0 >750 hp $0 $0 $700,760 $314,697 $700,760 $314,697 Total Crude Petroleum & NG Production (211111) $4,561,236 $6,138,383 $732,943 $1,258,072 $5,294,179 $7,396,454 Natural Gas Liquid Producers (211112) 25 - 50 hp $0 $388,115 $0 $582,173 $0 $970,288 50 - 100 hp $0 $66,698 $0 $100,047 $0 $166,744 100 - 175 hp $4,549,775 $5,674,246 $0 $242,285 $4,549,775 $5,916,531 175 - 300 hp $1,037 $1,053 $0 $44 $1,037 $1,096 300 - 500 hp $10,424 $8,271 $0 $327 $10,424 $8,598 500 - 600 hp $0 $0 $32,184 $18,500 $32,184 $18,500 600 - 750 hp $0 $0 $0 $0 $0 $0 >750 hp $0 $0 $700,760 $314,697 $700,760 $314,697 Total Natural Gas Liquid Producers (211112) $4,561,236 $6,138,383 $732,94 3 $1,258,072 $5,294,179 $7,396,454 National Security (92811) 25 - 50 hp $0 $306,495 $0 $459,743 $0 $766,239 50 - 100 hp $0 $67,349 $0 $101,024 $0 $168,373 100 - 175 hp $3,763,130 $4,693,183 $0 $200,394 $3,763,130 $4,893,577 175 - 300 hp $1,178,205 $1,196,427 $0 $49,596 $1,178,205 $1,246,023 300 - 500 hp $937,026 $743,489 $0 $29,424 $937,026 $772,913 500 - 600 hp $0 $0 $2,932,255 $1,685,542 $2,932,255 $1,685,542 600 - 750 hp $0 $0 $591,736 $313,398 $591,736 $313,398 >750 hp $0 $0 $9,842,833 $4,420,215 $9,842,833 $4,420,215 Total Natural Gas Liquid Producers (211112) $5,878,362 $7,006,944 $13,366,824 $7,259,336 $19,245,186 $14,266,280 Hydro Power Units (335312) 25 - 50 hp $0 $22,688 $0 $34,032 $0 $56,721 50 - 100 hp $0 $2,560 $0 $3,840 $0 $6 ,399 100 - 175 hp $0 $0 $0 $0 $0 $0 175 - 300 hp $0 $0 $0 $0 $0 $0 300 - 500 hp $0 $0 $0 $0 $0 $0 500 - 600 hp $0 $0 $0 $0 $0 $0

### 11

Table 5. Summary of Major Source and Area Source NAICS Costs for the SI RICE NESHAP

– by Size 1 

### (cont’d) 600 - 750 hp $0 $0 $0 $0 $ 0 $0 >750 hp $0 $0 $0 $0 $0 $0 Total Hydro Power Units (335312) $0 $25,248 $0 $37,872 $0 $63,120 Irrigation Sets (335312) 25 - 50 hp $0 $32,913 $0 $625,338 $0 $658,251 50 - 100 hp $0 $65,825 $0 $1,250,677 $0 $1,316,502 100 - 175 hp $1,222,348 $ 1,524,449 $0 $824,505 $1,222,348 $2,348,954 175 - 300 hp $798,634 $810,986 $0 $425,827 $798,634 $1,236,813 300 - 500 hp $1,004,068 $796,683 $0 $399,376 $1,004,068 $1,196,060 500 - 600 hp $0 $0 $28,933,107 $16,631,556 $28,933,107 $16,631,556 600 - 750 hp $0 $0 $0 $0 $0 $0 >750 hp $0 $0 $5,094,712 $2,287,931 $5,094,712 $2,287,931 Total Irrigation Sets (335312) $3,025,050 $3,230,856 $34,027,819 $22,445,211 $37,052,869 $25,676,067 Welders (333992) 25 - 50 hp $0 $163,908 $0 $245,862 $0 $409,771 50 - 100 hp $0 $207,394 $0 $311,091 $0 $518,485 100 - 175 hp $247,440 $308,594 $0 $13,177 $247,440 $321,771 175 - 300 hp $0 $0 $0 $0 $0 $0 300 - 500 hp $0 $0 $0 $0 $0 $0 500 - 600 hp $0 $0 $0 $0 $0 $0 600 - 750 hp $0 $0 $0 $0 $0 $0 >750 hp $0 $0 $0 $0 $0 $0 Total Wel ders (333992) $247,440 $679,896 $0 $570,130 $247,440 $1,250,027

Total $72,663,076 $87,744,734 $310,139,222 $165,630,205 $382,802,298 $253,374,939

### 12

Table 6 . Summary of Major Source and Area Source NAICS Costs for the S I RICE NESHAP

– by Number of Engine s 1 NAICS Number of Engines Total (Major + Area) Major Area Total Capital Cost Annual Cost Electric Power Generation (2211) 25 - 50 hp 37,933 56,900 94,833 $0 $6,896,147 50 - 100 hp 8,336 12,503 20,839 $0 $1,515,359 100 - 175 hp 16,534 24,802 41, 336 $33,868,173 $44,042,196 175 - 300 hp 4,092 6,138 10,230 $10,603,849 $11,214,209 300 - 500 hp 2,428 3,642 6,070 $8,433,236 $6,956,217 500 - 600 hp 0 2,107 2,107 $26,390,293 $15,169,876 600 - 750 hp 0 363 363 $5,325,628 $2,820,584 >750 hp 0 4,677 4,677 $88, 585,495 $39,781,934 Total Electric Power Generation 2211 69,323 111,132 180,455 $173,206,675 $128,396,522 Natural Gas Transmission (48621) 25 - 50 hp 1 27 28 $0 $2,036 50 - 100 hp 67 1,273 1,340 $0 $97,443 100 - 175 hp 147 2,799 2,946 $301,721 $57 9,809 175 - 300 hp 248 4,716 4,964 $643,157 $996,032 300 - 500 hp 155 2,952 3,107 $539,617 $642,799 500 - 600 hp 0 1,595 1,595 $19,975,323 $11,482,372 600 - 750 hp 0 668 668 $9,808,436 $5,194,789 >750 hp 0 5,871 5,871 $111,193,518 $49,934,735 Total Natural G as Transmission (48621) 619 19,899 20,519 $142,461,771 $68,930,015 Crude Petroleum & NG Production (211111) 25 - 50 hp 5,337 8,006 13,343 $0 $970,288 50 - 100 hp 917 1,376 2,293 $0 $166,744 100 - 175 hp 2,221 3,332 5,553 $4,549,775 $5,916,531 175 - 300 hp 0 1 1 $1,037 $1,096 300 - 500 hp 3 5 8 $10,424 $8,598 500 - 600 hp 0 3 3 $32,184 $18,500

### 13

Table 6 . Summary of Major Source and Area Source NAICS Costs for the SI RICE NESHAP

– by Number of Engines 1 

### (cont’d)

600 - 750 hp 0 0 0 $0 $0 >750 hp 0 37 37 $700,760 $314,697 Total Crude Petroleum & NG Production (211111) 8,479 12,758 21,237 $5,294,179 $7,396,454 Natural Gas Liquid Producers (211112) 25 - 50 hp 5,337 8,006 13,343 $0 $970,288 50 - 100 hp 917 1,376 2,293 $0 $166,744 100 - 175 hp 2,221 3 ,332 5,553 $4,549,775 $5,916,531 175 - 300 hp 0 1 1 $1,037 $1,096 300 - 500 hp 3 5 8 $10,424 $8,598 500 - 600 hp 0 3 3 $32,184 $18,500 600 - 750 hp 0 0 0 $0 $0 >750 hp 0 37 37 $700,760 $314,697 Total Natural Gas Liquid Producers (211112) 8,479 12,758 21,237 $5,294,179 $7,396,454 National Security (92811) 25 - 50 hp 4,215 6,322 10,537 $0 $766,239 50 - 100 hp 926 1,389 2,315 $0 $168,373 100 - 175 hp 1,837 2,756 4,593 $3,763,130 $4,893,577 175 - 300 hp 455 682 1,137 $1,178,205 $1,246,023 300 - 500 hp 270 4 04 674 $937,026 $772,913 500 - 600 hp 0 234 234 $2,932,255 $1,685,542 600 - 750 hp 0 40 40 $591,736 $313,398 >750 hp 0 520 520 $9,842,833 $4,420,215 Total Natural Gas Liquid Producers (211112) 7,702 12,347 20,050 $19,245,186 $14,266,280 Hydro Power Units (335312) 25 - 50 hp 312 468 780 $0 $56,721 50 - 100 hp 35 53 88 $0 $6,399 100 - 175 hp 0 0 0 $0 $0 175 - 300 hp 0 0 0 $0 $0 300 - 500 hp 0 0 0 $0 $0

### 14 500 - 600 hp 0 0 0 $0 $0 600 - 750 hp 0 0 0 $0 $0 >750 hp 0 0 0 $0 $0 Total Hydro Power Units (335312) 347 521 868 $0 $63,120 Irrigation Sets (335312) 25 - 50 hp 453 8,599 9,052 $0 $658,251 50 - 100 hp 905 17,199 18,104 $0 $1,316,502 100 - 175 hp 597 11,338 11,935 $1,222,348 $2,348,954 175 - 300 hp 308 5,856 6,164 $798,634 $1,236,813 300 - 500 hp 289 5,492 5,781 $1,004,068 $1,196,060 500 - 600 hp 0 2,310 2,310 $28,933,107 $16,631,556 600 - 750 hp 0 0 0 $0 $0 >750 hp 0 269 269 $5,094,712 $2,287,931 Total Irrigation Sets (335312) 2,552 51,063 53,615 $37,052,869 $25,676,067 Welders (333992) 2 5 - 50 hp 2,254 3,381 5,635 $0 $409,771 50 - 100 hp 2,852 4,278 7,130 $0 $518,485 100 - 175 hp 121 181 302 $247,440 $321,771 175 - 300 hp 0 0 0 $0 $0 300 - 500 hp 0 0 0 $0 $0 500 - 600 hp 0 0 0 $0 $0 600 - 750 hp 0 0 0 $0 $0 >750 hp 0 0 0 $0 $0 Total Welders (33 3992) 5,227 7,840 13,067 $247,440 $1,250,027

Total 102,729 228,319 331,047 $382,802,298 $253,374,939

### 15

4.0 EMISSION REDUCTIONS The emissions reductions associated with the final rule are based on requiring emission standards that are based on applying add- on controls to existing non- emergency 4SLB engines from 100 HP to 500 HP at major sources, non- emergency 4SLB engines greater than 500 HP at area sources, and non- emergency 4SRB engines greater than 500 HP at area source s . Baseline emissions were calcul ated using the existing stationary SI engine emission factors 8 

### and control efficiencies presented below assuming 2,8 00 hours per year (hrs/yr) for non - emergency operation and 50 hrs/yr for emergency operation . Itwas also assumed for purposes of estimating reductions associated with the final rule that 5 percent of existing 4SLB engines and 20 percent of existing 4SRB engines are currently operating with add- on controls that reduce HAP emissions. Inaddition, the Engine Manufacturers Association (EMA) has indicated that about 5 percent of stationary

SI engines are used for emergency operation. These engines are predominantly

4SRB engines, according to EMA. 9 

### To calculate the tpy emissions reductions associated with the final rule, the following general equation was used: 

## EF pollutant 

## (lb/hp -hr) x (hp) x (hrs/y r) x (ton/2,000 lb ) x (# of engines) x (% reduction) Emission Factors:

Engine HAP

(lb/hp - hr) CO

(lb/hp - hr) NO x



### (lb/hp - hr) VOC

(lb/hp - hr) 2SLB 5.96 x10 -4 

### 1.06 x10 - 2 

### 4.18 x10 - 2 

### 3.07 x10 - 3 

### 4SLB 5.41 x1 0 -4 

### 3.92 x10 - 3 

### 1.15 x10 - 2 

### 2.78 x10 - 3 

### 4SRB 2.43 x10 -4 

### 1.93 x10 - 2 

### 1.47 x10 - 2 

### 1.25 x10 - 3 

### The emission factors were derived using data available in EPA’s Emissions Database for stationary engines and emissions data received following the proposed rule and are presented in a memorandum available from the rulemaking docket. Control Efficiencies:

Technology HAP CO NO x 

### 4SLB Ox. Catalyst 71% 94% N/A 4SRB NSCR 76% 49% 97% The control efficiencies are based on the average percent reduction observed during EPA’ s testing program at Colorado State University. The results from this testing are available from www.regulations.gov as Document ID Number EPA- HQ - OAR- 2002 - 0059 - 0665 .

8 Memorandum from Bradley Nelson, EC/R to Melanie King, EPA OAQPS/SPPD/ESG , Emission Factors for Existing Stationary SI RICE , August 3, 2010. 9 Letter from Joe Suchecki, EMA to Sims Roy, EPA. EMA Response to Questions on Proposed SI NSPS. September 19, 2005.

### 16

Based on the above assumptions and the existing popul ation of engines shown in Table 1 of this memorandum, the HAP, CO, NO x 

### , and VOC baseline emissions and reductions were calculated. The estimated reductions as a result of the final rule are shown in Table 7 .

Table 7 . Summary of Emissions Reductions for the S I RICE NESHAP Engine Size (HP) Emission Reductions (tpy)

HAP CO NO x 

### VOC Major Sources 25 - 50 0 0 0 0 50 - 100 0 0 0 0 100 - 175 744 7,124 0 3,826 175 - 300 277 2,653 0 1,424 300 - 500 288 2,755 0 1,480 500 - 600 N/A N/A N/A N/A 600 - 750 N/A N/A N/A N/A >750 N/A N/A N/A N/A Total 1 , 308 12,532 0 6,730 Area Sources 25 - 50 0 0 0 0 50 - 100 0 0 0 0 100 - 175 0 0 0 0 175 - 300 0 0 0 0 300 - 500 0 0 0 0 500 - 600 1, 005 20,698 20,632 5,170 600 - 750 220 4,533 4,519 1,132 >750 3,475 71,557 71,328 17 , 874 Total 4,700 96,789 96,479 2 4, 177 Grand Total 6 ,008 109,321 96,479 3 0,907