1

MEMORANDUM Subject: Analy sis of the Ty pes of Engines Used to Estimat e the CAA S ection 112(k) Area Source Inventory

for Stationary

Reciprocating Internal Combustion Engines From: Melanie King, Energy Strategies Group To: EPA Docket EPA
- HQ
- OAR
- 2008
- 0 708 Date: January

5, 2010 Section 112(c)(3) of the Clean Air Act (CAA) requires that EPA list categories or subcategories of area sources sufficient to ensure that area sources representing 90 percent of the area source emissions of the 30 HAP that pres ent the greatest threat to public health in the largest number of urban areas are regulated. EPA listed the stationary reciprocating internal combustion engine area source category under 112(c)(3) and (k) as one of the categories needed to ensure that 90 percent of such area source emissions are regulated. Inresponse to comments received on the proposed NESHAP for existing stationary RI CE located at area sources (74 FR 9697), EPA anal yz ed the ty

pes of engines that were included in the area source category listing for stationary RI CE. As a result of this anal ys is, EPA determined that emissions from existing stationary emergency

engines located at residential, commercial, and institutional facilities were not included in the 1990 baseline emissions invento ry that was used as the basis for the listing of source categories needed to ensure that 90 percent of area source emissions are regulated
. 1 Residential, commercial ,and institutional emergency stationary

RI CE include emergency stationary RICE used in resi dential establishments such as homes or residences, commercial establishments such as office buildings, hotels, or stores, or institutional establishments such as medical centers, research centers, and institutions of higher education. Therefore, EPA dete rmined that these engines at these locations will not be subject to this area source standard. A detailed description of the anal ys is to determine the engines that were the basis for the inventory is provided below. Summary of the information used in est imating the 1990 112(k) Area Source Inventory for Stationary RICE The emissions for stationary RI CE used to estimate the 1990 112(k) area source inventory were calculated using national estimates for fuel consumption (in units of J/y r) of natural gas and distillate oil for engines used for two purposes: 1) engines used b y utilities for electricity generation 2) engines used in industrial applications

1 1990 Emissions Inventory of Forty Potential Section 112(k) Pollutants, Supporting Data for EPA’s Section 112(k) Regulatory Strategy. May 21, 1999.2

EPA extrapolated fuel consumption information for the year 1990 from estimates of consumption for the years 1978 and 1985 in an EPA report (Reference 1)
. The 1990 fuel consumption estimates were multiplied by a J/Btu conversion and then multiplied by a lb/MMBtu emission factor in orde r to determine the tons emitted per ye ar for each HAP. This was done for each fuel t ype (natural gas and distillate oil)
. The EPA report does not have an y further description of what type of engines are included in the fuel consumption data. The EPA
- RTP L ibrary was able to obtain some of the references for the fuel consumpt ion data. None of the references have an y information on what size of engines are included. T he primary

references for the 1978/1985 data for the engines used by utilities for electricit y generation do n o t provide an y additional detail about what engines are included. T he reference for the 1978 data for the engines used in industrial applications indicates that the data is for engines used for the following applications:

 o il and gas pipelines  natural gas processing plants  oil and gas exploration  c rude oil production  natural gas production  agricultural  industrial process  municipal water and sewage The L ibrary was unable to obtain the reference for the 1985 data for industrial application engines. Detailed description of fuel consumption data T h e fuel consumption numbers that were used are shown in Table 1 . The 1978 and 1985 fuel consumption data were obtained from Reference 1. EPA extrapolated the estimates for 1990 from the 1978 and 1985 estimates.

Table
- Fuel consumption (10 15 J/y r) for stationary

reciprocating engines Year E ngines used for electricity generation Engines used in industrial applications Natural Gas Distillate Oil Natural Gas Distillate Oil 1978 25 a 31 a 1004 d 62 d 1985 15 b 43 b 1093 e 73 e 1990 26 c 34 c 1171 f 72 f a The 1978 fuel consumption numbers were determined by subtracting National Electric Reliability

Council (NERC) estimates of 1976 fuel consumption for utility turbines (Reference 2 ) from Federal Power Commission (FPC) data for 1976 fuel consumption by internal combu stion plants owned b y utilities (Reference 3 ). The 1978 fuel consumption for electricity generation reciprocating engines was assumed to be equal to the 1976 numbers “as reciprocating engine generating capacity

for the two years are about equal.”3

b The 1 985 fuel consumption estimates for reciprocating engines used by utilities for electricit y generation were determined using NERC estimated fuel requirements for 1985 (Reference 2 ). The NERC estimates were for fuel consumption for combustion turbines. The 1985 estimates were a 40.8% decrease in fuel consumption for gas
- fueled turbines from the 1978 figures. The EPA report estimated that the fuel consumption for natural gas
- fired engines would decrease b y the same percentage as for turbines (40.8%). Based on estimates from the FPC (Reference 4 ), the EPA report estimated that the total diesel engine capacit y would increase by 2.1% from 1976
- 1985. The fuel consumption for distillate
- fired engines would therefore increase b y 37.2% from 1978 to 1985 due to th e increased capacit y and the decreased consumption of natural gas.

c The 1990 consumption estimates were “assumed” by Fred Porter of EPA and it doesn’t say how he “assumed” those numbers. dThe 1978 fuel consumption data for industrial engines was estimate d from 1971 fuel consumption data from an EPA report (Reference 5 ) and the ratios of domestic natural gas and crude oil production figures for those two ye ars (References 6
- 8 ). The 1971 fuel consumption data was for engines used in the following applicati ons: Application Engine uses listed for application Oil and gas pipelines Natural gas processing plants drive gas compressors and refrigeration compressors Oil and gas exploration drive electric generators, drawworks, drilling mud pumps, rotary

drilli ng rigs Crude oil production drive beam pumps, gas lift compressors, hydraulic pump power pumps Natural gas production drive repressuring compressors Agricultural drive agricultural water pumps Industrial process drive industrial process equipment an d plant air compressors Municipal water and sewage drive municipal water and sewage pumps

e Projected 1985 fuel consumption rates for industrial internal combustion sources were estimated based on 1985 domestic natural gas and crude oil supply rates fro m the Federal Energy Administration (Reference 8 ). Assumptions used are that fuel consumption rates are proportional to domestic natural gas production and that fuel consumption rates for distillate oil fueled engines are proportional to domestic crude oi l production. Exception is that fuel consumed b y gas reciprocating engines for crude oil production is assumed to be proportional to the domestic crude oil production rate. f Fuel consumption for 1990 was extrapolated for industrial engines assuming that the growth rate in fuel consumption from 1978 to 1985 was the same as the growth rate from 1985 to 1990. A compound growth rate was assumed. Distribution between gas and oil fired engines was assumed to be the same in 1990 as in 1978.45

References 1. Emissi ons Assessment of Conventional Stationary Combustion Sy stems: Volume II. Internal Combustion Sources. EPA
- 600/7
- 79
- 029c. February 1979. 2. Fossil and Nuclear Fuel for Electric Utility Generation Requirements and Constraints. 1977
- 1986. National Electric Reliability Council, Princeton, New Jersey . August 1977. 3. FPC News Release No. 23009. Federal Power Commission, Washington, D.C. March 25, 1977. 4. FPC News Release No. 22673. Federal Power Commission, Washington, D.C. October 15, 1976. 5. McGowin, C.R. Stationary Internal Combustion Engines in the United States. Report prepared b y the Shell Development Co. for the U.S. Environmental Protection Agency. EPA Report No. R2
- 73
- 210. April 1973. 120 p. NTIS PB
- 221 457. 6. 1974 Gas Facts. American Gas Associatio n. Arlington, VA. 1975. 7. Dupres, W.G., Jr. and J.S. Corsentino. United States Energy through the Year 2000 (Revised) Bureau of Mines, U.S. Department of the Interior. December 1975. 8. National Energy

Outlook, Federal Energy Administration. February 197 6.