EC

/R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Drive, Suite 325 y Chapel Hill, North Carolina 27514 

Telephone: (919) 484-0222 y Fax: (919) 484-0122 

 

MEMORANDUM 

DATE: February 11, 2010 

SUBJECT: Cost per Ton of HAP Reduced for Existing Stationary CI RICE 

FROM: Bradley Nelson and Tanya Parise, EC/R, Inc. 

 

TO: Melanie King, EPA OAQPS/SPPD/ESG 

1.0 PURPOSE 

The purpose of this memorandum is to present the cost per ton of emissions reduced by 

applying controls to existing stationary compression ignition (CI) reciprocating internal 

combustion engines (RICE) less than or equal to 500 horsepower (HP) located at major sources 

subject to National Emission Standards for Hazardous Air Pollutants (NESHAP). 

2.0 INTRODUCTION

 EPA has extensively discussed the various exhaust aftertreatment controls available to 

stationary CI engines in background documentation for previous rulemakings. The applicable 

add-on controls for stationary CI engines include add-on control technologies based on oxidation 

and/or reduction of pollutants. The add-on control technologies discussed in this memorandum 

are diesel oxidation catalysts (DOC) and open crankcase ventilation (OCV) 

3.0 COST OF CONTROLS 

The capital and annual cost of controls were developed using equipment cost information 

obtained from control technology vendors and state agencies and the estimation methodology 

outlined in the EPA Air Pollution Control Cost Manual.1

 The development of the cost equations 

for each of the applicable control technologies is presented in a control cost memorandum.2 EPA 

determined that the following cost equations in Table 2 are representative of the applicable addon controls to be considered for stationary CI engines. 

 

1

 EPA Air Pollution Control Cost Manual Sixth Edition, January 2002, EPA/452/B-02-001. 

2

 Memorandum from Bradley Nelson, EC/R Inc., to Melanie King, EPA OAQPS/SPPD/ESG, Control Costs for 

Existing Stationary CI RICE (see EPA-HQ-OAR-2008-0708). 
2 

Table 2. Summary of Capital and Annual Costs for Diesel HAP Control Technology 

Technology Capital Cost ($2008) Annual Cost ($2008) 

DOC $27.4 x HP - $939 $4.99 x HP + $480 

OCV $0.26 x HP + $997 $0.065 x HP + $254 

4.0 EMISSION REDUCTIONS 

 In order to estimate the baseline emissions of HAP, PM, volatile organic compounds 

(VOC), and sulfur dioxide (SO2) from stationary engines affected by this rulemaking, EPA 

obtained HAP emission factors from the memorandum “Development of HAP Emission Factors 

for Small (≤500 HP) Stationary Reciprocating Internal Combustion Engines (RICE)” (EPA-HQOAR-2005-0030-0009). Using the uncontrolled HAP emission factors in conjunction with 

previously well-accepted assumptions listed below, EPA estimated the uncontrolled HAP 

emissions per year per subcategory. EPA then estimated the emissions reductions per engine 

subcategory. 

Assumptions: 

• Stationary prime CI engines annual operation: 1,000 hrs/yr 

• Stationary emergency CI engines annual operation: 50 hrs/yr 

• Uncontrolled CI HAP emissions: 1.07 x 10-4 lb/HP-hr 

• Uncontrolled CI PM emissions: 7.00 x 10-4 lb/HP-hr 

• Uncontrolled CI VOC emissions: 2.47 x 10-3 lb/HP-hr 

The cost per ton of HAP, PM, and VOC reduced for the DOC/OCV add-on control 

technology options for emergency and non-emergency engines are presented in Tables 3, 4, and 

5. 
3 

Table 3. Cost per ton ($/ton) of HAP Reduced1 per Engine ($2008) 

< 50 HP 50–100 HP 100–175 HP 175-300 HP 300-500 HP 500-600 HP 

CI Prime Engines 

(DOC + OCV) $632,888 $380,463 $265,225 $207,583 $170,108 $162,459 

CI Emergency Engines 

(DOC + OCV) 

$17,706,275 $7,609,257 $5,304,503 $4,151,664 $3,402,166 $3,249,181 

1 HAP reductions are estimated to be 70% based on the use of DOC and OCV. 

Table 4. Cost per ton ($/ton) of PM Reduced1 per Engine ($2008) 

< 50 HP 50–100 HP 100–175 HP 175-300 HP 300-500 HP 500-600 HP 

CI Prime Engines 

(DOC + OCV) $225,730 $135,698 $94,597 $74,038 $60,672 $57,944 

CI Emergency Engines 

(DOC + OCV) $6,315,238 $2,713,968 $1,891,939 $1,480,760 $1,213,439 $1,158,874 

1 PM reductions are estimated to be 30% based on the use of DOC and OCV. 

Table 5. Cost per ton ($/ton) of VOC Reduced1 per Engine ($2008) 

< 50 HP 50–100 HP 100–175 HP 175-300 HP 300-500 HP 500-600 HP 

CI Prime Engines 

(DOC + OCV) $27,417 $16,482 $11,490 $8,992 $7,369 $7,038 

CI Emergency Engines 

(DOC + OCV) $767,033 $329,632 $229,790 $179,849 $147,381 $140,754 

1 VOC reductions are estimated to be 70% based on the use of DOC and OCV.
4 

4.0 BENEFITS 

The benefits per ton of PM and SO2 at 7 percent interest rate are shown in Table 3. For 

more information on the benefits per ton of pollutants reduced and total monetized benefits, 

please refer to the “Regulatory Impact Analysis (RIA) for Existing Stationary Compression 

Ignition Engines NESHAP,” which can be found in the docket (EPA-HQ-OAR-2008-0708). 

Table 3. Summary of PM and SO2 Benefit per Ton for Existing Stationary CI Engines 

Pollutant Benefit per ton (Pope, 7%) Benefit per ton (Laden, 7%) 

Major Area Major Area 

PM $210,000 $330,000 $500,000 $790,000 

SO2 $27,000 $18,000 $65,000 $44,000