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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 15, 2010

SUBJECT: MACT Floor Determination for Ex isting Stationary Non-Emergency CI RICE Less Than 100 HP and Existing Stationary Emergency CI RICE Located at Major Sources and GACT for Existing Stationary CI RICE Located at Area Sources

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 document the analysis of the maximum achievable control technology (MACT) floor a nd MACT for existing stationary non-emergency compression ignition (CI) reciprocating intern al combustion engines (RICE) less than 100 horsepower (HP) and existing stationary emergenc y and black start CI engines located at major sources. The generally achievable control technology (GACT) for existing stationary CI RICE located at area sources of hazardous air pollutant s (HAP) emissions that are subject to National

Emission Standards for Hazardous Air Pollutant s (NESHAP) is also presented in this

memorandum.

The analysis for existing stationary non-emer gency CI engines greater than or equal to 100 HP located at major sources of hazardous air pollutants (HAP) emissions is presented in a separate memorandum titled “MACT Floor De termination for Existing Stationary NonEmergency CI RICE Greater Than or Equal 100 HP Located at Major Sources,” which is available in the rulemaking docket (EPA-HQ-OAR-2008-0708).

2.0 INTRODUCTION

The EPA has developed a regulation addressi ng toxic air emissions from the following existing stationary CI RICE e ngines: 1) engines that are lo cated at area sources of HAP emissions; 2) engines that are le ss than or equal to 500 HP and ar e located at major sources of HAP emissions; and 3) non-emergency CI engines that are greater than 500 HP and are located at major sources of HAP emissions. The regul ation was developed following criteria set forth under section 112 of the Clean Air Act (CAA). S ection 112(d) of the CAA stipulates that EPA must promulgate emission standards that require the maximum degree of HAP reduction. According to 112(d)(3)(A) of the CAA, the emi ssion standards for existi ng major sources must be no less stringent than the average emissi on limitation achieved by the best performing 12 percent of existing sources for which the Administrator has emissions information. For existing2 area sources, EPA has the option under 112(d)(5) of the CAA to promulgate emission standards or requirements GACT or management practices in order to reduce HAP emissions. The EPA has previously issued a similar regulation aff ecting existing and new stationary RICE greater than 500 HP at major sources, which was promulgated in 2004 and for new stationary RICE less than or equal to 500 HP at major sources, which was promulgated in 2008.

Section 112 of the CAA outlines the statutor y requirements for the EPA’s stationary source air toxics program. Sec tion 112(k) of the CAA requires th e development of standards for area sources which account for 90 percent of the emissions in urban areas of the 33 urban HAP listed in the Integrated Urban Air Toxics Stra tegy (UATS). These area source standards can require control levels which are equivalent to either MACT or GACT, as defined in the CAA under section 112(d)(2) and (3) and section 112(d)(5), respectively.

Section 112 of the CAA allows the EPA to establish subcategories among a group of sources. A complete discussion of the subcat egory selection is presented in a separate

memorandum. 1

3.0 MACT FLOOR AND MACT DETERMINATION

Non-Emergency CI Engines <100 HP

For stationary CI engines less than 100 HP, EPA determined that it is not feasible to prescribe or enforce an emission standard because the application of measuring methodologies to this subcategory of engines is not practicable due to technological and economic limitations. In

order to measure the CO emissions from these en gines in terms of volum etric concentration on a dry basis and corrected to 15 percent oxygen (O 2 ), the following test methods are required:

• EPA Method 1 or 1A for selection of sampling ports;

• EPA Method 3, 3A, or 3B or ASTM Met hod D6522-00 (2005) for determining the O 2 concentration;

• EPA Method 4 for measuring the moisture content; and

• EPA Method 10 or ASTM Method D6522- 00 (2005) for measuring the carbon monoxide (CO) concentration.

The test methods require the sample point to be a certain distance between the engine and the exhaust. Because engines be low 100 HP often have exhaust pipes with very small diameters and lengths, stack testing using these methods could require a m odification or extension of the exhaust pipe to accomplish the test. Furthermore, the cost of performing a stack test ranges from approximately $1,000-5,000 depending on the method used. Generally, 100 HP engines cost around $5,000-$7,000 and 50 HP engines cost a pproximately $4,000-$5,000, so the cost of performance testing could approach the cost of th e engine itself. Given the cost of the testing itself, the physical adjustments necessary to acco mplish the test, and the particular circumstances pertaining to engines below 100 HP, EPA belie ves that the applica tion of measurement methodology to this class of engines is not pr acticable due to tec hnological and economic

1 Memorandum from Bradley Nelson and Tanya Parise, EC/R Inc. to Melanie King, EPA OAQPS/SPPD/ESG,
Subcategorization of Existing Stationary CI RICE (see EPA-HQ-OAR-2008-0708).3 limitations. Therefore, work practices are the MACT floor for existing stationary nonemergency CI engines less than 100 HP.

To determine the work practices, EPA revi ewed information obtai ned from different manufacturers and operators of CI engines. The EPA has determined that the maximum achievable control, based on the work practices of th e best controlled engines, is to maintain and replace the following stationary engine component s: oil and oil filter , air cleaner, hoses, and belts. According to information received from manufacturers and opera tors of stationary engines, these parameters are the most approp riate to ensure proper operation for minimizing HAP emissions. Each of these work practices limit HAP emissions by allowing the engine to operate at peak efficiency. Changing the oil an d oil filter reduces the wear on the pistons and cylinders and limits the amount on worn metals that may be intr oduced to the exhaust stream. Inspecting the air filter limits the introduction of oil mist and other contaminants to the combustion chamber. Inspecting the belts and hoses ensures that the engines cooling and electrical systems are operating, therefore eliminating the burning of oil and ensuring that the electrical systems are functioning as intended.

Intervals for checking, inspecting and replaci ng the oil and oil filter, air cleaner, hoses, and belts vary with engine makes and models, ap plication, location, and ot her factors, therefore making it difficult to define specific maintenance intervals that would be represent the operation of the best controlled engines. However, EP A must promulgate specific requirements pursuant to section 112(d) of the CAA and the information indicates that there are commonalities in maintenance interval frequencies for the best co ntrolled engines. Based on the information provided, EPA believes that the work practices below are what the best controlled existing stationary non-emergency CI engines less than 100 HP are currently doing and for that reason the MACT floor for these engines is work practices as follows:

• changing the oil and oil filter every 1,000 hours of operation or annually, whichever comes first;

• inspecting the air cleaner every 1,000 hour s of operation or annually, whichever comes first; and

• inspecting all hoses and belts and replaci ng as necessary every 500 hours of operation or annually, whicheve r comes first.

As discussed above, current maintenance proced ures vary from engine to engine based on a number of factors including engine design, fuel, operating characteristics, and so on. Maintaining the oil however, is, one of the most important activities operators can perform to minimize emissions and to ensure pr oper operation and performance.

In addition to following a set schedule for checking and replacing the oil, it is also common that the oil is monitored through an oil analysis program where the oil is periodically sampled to determine oil quality. Based on the oil sa mple that is extracted, an oil analysis can be performed that can indicate if it is time to repl ace the oil or if the existing oil has not reached condemning limits it can continue to be used. Based on the analysis a decision can be made whether to drain and replace the oil or if the oil change interval can be extended if the properties of the oil are within acceptab le limits. Appropriate paramete rs and condemning limits that4 would indicate oil degradation a nd the presence and quantity of c ontaminants varies. However, EPA has determined that the parameters that w ould most appropriately indicate the oil quality are the total base number (TBN), viscosity, and wa ter content. The TBN is an indication of the alkalinity of the oil and the visc osity of the oil is a measure of how well the oil flows and these parameters are, along with water content, measures of the condition of the oil. If the following levels below as measured through an oil analysis program are exceeded, EPA has determined that an oil change must be performed:

• TBN is less than 30 percent of the TBN of the oil when new; or

• viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or

• percent water content (by vol ume) is greater than 0.5.

No other regulatory options beyond the MACT floor were identified as appropriate for existing stationary non-emergency CI engine s below 100 HP. Therefore, MACT for HAP emissions is equivalent to the MA CT floor for these engines.

Emergency CI Engines

For existing stationary CI emergency engine s located at major sources, EPA determined it is not feasible to prescribe or enforce an emission standard becau se the application of measurement methodology to this class of engine is impracticable due to the technological and economic limitations. Emergency engines typically only operate during emergencies or during periods of routine testing and maintenance. EP A determined that application of the emissions measurement methodologies during either of these pe riods is not practicable. It is impracticable to test emissions from stationary CI emergenc y engines during periods of routine testing and maintenance using the test proced ures specified in the rule becau se it would increase the required number of hours of operation of the engine beyo nd the routinely scheduled reliability testing and maintenance operation, thereby increasing emissions . While emergency engines have periods of operation for scheduled maintenance and reliabil ity testing, those period s are usually several

hours shorter than the number of hours that w ould be required to run the necessary emissions tests under subpart ZZZZ. CARB conducted a survey of stationary emergency diesel engines in

2002 2 to determine the average number of hours that stationary emergency diesel engines operate. The average hours of operation for ma intenance and testing were 22 hours per year, which is less than two hours per month. Fo r the engines that CARB surveyed, 86 percent operated less than 30 hours/year for testing and maintenance. Thirty percent operated less than 10 hours/year. National Fire Protection Associati on (NFPA) codes require th at stationary diesel engines that are used for emergency purposes are run 30 minutes per week (27 hours per year) for maintenance and testing purposes. It is also impracticable to apply the testing methodologies required in this rule to test the stationary e ngines during periods of emergency operation because emergencies are unplanned events and and implemen tation of the procedures specified in subpart ZZZZ require advance planning before tests are c onducted. In an emergency, the owner/operator

2 California Air Resources Boar d Staff Report: Initial Statement of Reasons for Proposed Rulemaking. Airborne Toxic C ontrol Measure for Stationary Compression Ignition Engines. Stationary Source Division, Emissions Assessment Branch. September 2003.5 does not have the advance planning time necessary to implement subpart ZZZZ. It is also impracticable to test stationary CI emergency engines at major sources because of the large population of these engines. EPA estimates th at there are over 200,000 ex isting stationary CI emergency engines from 100-500 HP at major sources that are subject to this rulemaking. There are only approximately 300-400 testing firms an d these stationary engines are not the only sources that are required to be test ed, so if testing were required for these engines, it would take many years to test all of these engines. The co st for testing all of these engines would be in
excess of $200 million and would clear ly also be unreasonable.

For these reasons, work practices are appropriate and justified for this group of stationary engines because the application of measur ement methodology is not practicable due to technological and economic limitations. Conseque ntly, work practices are the MACT floor for existing stationary emergency CI e ngines located at major sources.

Again, in order to determine the work prac tices for stationary emergency engines at major sources, EPA reviewed information obtain ed from different manufacturers and operators of CI engines. For the same reasons as disc ussed above for existing stationary non-emergency engines less than 100 HP at major sources, EP A has determined that maximum achievable control, based on the work practices of the the best controlled emergency engines, is to maintain and replace the following stationary engine component s: oil and oil filter, air cleaner, hoses, and

belts. EPA discussed above the effect that maintaining these parameters have on HAP

emissions.

As stated, intervals for checking, inspecting and replacing these components vary from engine to engine and determining specific main tenance intervals that would be represent the operation of the best controlled emergency e ngines is challenging. However, EPA must promulgate specific requirements pursuant to section 112(d) of the CAA and the information indicates that there are commonalities in maintenance interval frequencies for the best controlled engines. Based on the information provided, EPA believes that the below maintenance practices

are what the best controlled ex isting stationary emergency CI e ngines are currently doing and for that reason, the MACT floor for these engi nes is maintenance practices as follows:

• changing the oil and oil filter every 500 hours of operation or annually, whichever comes first;

• inspecting the air cleaner every 1,000 hour s of operation or annually, whichever comes first; and

• inspecting all hoses and belts and replaci ng as necessary every 500 hours of operation or annually, whicheve r comes first.

The changing of oil and the oil filter for stati onary emergency engines is more frequent on an hourly basis than for non-emergency engines because of the nature of operation of these engines, which is for standby and intermittent use, and th us requires less hourly use over the same period of time, and oil quality is reduced over time even during periods when the engine is not used.

Emergency CI engines also have the option to use an oil analysis prog ram to indicate if it is time to replace the oil or if the existing oil has not reached condemning limits it can continue6 to be used. The provisions of the oil analys is program are the same discussed above for nonemergency CI engines <100 HP.

No other regulatory options beyond the MACT floor were identified as appropriate for existing stationary emergency CI engines at majo r sources. Because these engines are typically used only a few number of hours per year, the costs of emission control are not warranted when compared to the emission reductions that would be achieved. The cost per ton estimates for stationary emergency CI engi nes can be found in the memora ndum entitled “Cost per Ton of HAP Reduced for Existing Stationary CI RI CE” in the rulemaking docket (EPA-HQ-OAR-2008- 0708). Therefore, MACT for HAP emissions is equi valent to the MACT floor for these engines.

Black Start Engines

Black start engines are used solely to start up combustion turbines. They operate for very

short durations and have the same issues as emergency CI engines based on their unique and limited operation. According to information rece ived during the public comment period, black start engines typically operate no more than 10 minutes at a time and only operate during emergencies or during periods of high de mand (see for example EPA-HQ-OAR-2008-0708-0088 and 0129). The short time of operation makes tes ting of black start engi nes using the required procedures impracticable. Therefore, work prac tices are the MACT floor for existing stationary black start engines located at major sources and are as follows:

• changing the oil and oil filter every 500 hours of operation or annually, whichever comes first, with the option to use an o il analysis program as discussed above;

• inspecting the air cleaner every 1,000 hour s of operation or annually, whichever comes first; and

• inspecting all hoses and belts and replaci ng as necessary every 500 hours of operation or annually, whicheve r comes first.

As with stationary emergency CI engines, no other regulatory options beyond the MACT floor were identified as appropriate for existing stationary black st art engines at major sources. The limited operating time also makes applying af tertreatment to black start engines not effective. In addition, these engines operate a few hours per year, making further regulation of these engines economically impractical. Therefore, MACT is equivalent to the MACT floor for these engines.

4.0 GACT DETERMINATION

Under CAA section 112(d)(5), EPA may elect to promulgate standards or requirements for area sources "which provide for the use of generally available co ntrol technologies or management practices by such sources to re duce emissions of hazar dous air pollutants." Additional information on generally available co ntrol technologies (GACT) or management practices is found in the Senate report on the legislation (Senate report Number 101-228, December 20, 1989), which describes GACT as:7 . . . methods, practices and techniques whic h are commercially available and appropriate for application by the sources in the category considering economic imp acts and the technical capabilities of the firms to operate and maintain the emissions control systems.

Determining what constitutes GACT involves considering the control technologies and management practices that are generally available to the area sources in the source category.

EPA also considers the standards applicable to major sources in the same industrial sector to

determine if the control technol ogies and management practices are transferable and generally available to area sources. In appropriate circum stances, EPA may also consider technologies and practices at area and major source s in similar categories to dete rmine whether such technologies and practices could be considered generally av ailable for the area source category at issue. Finally, as EPA has already noted, in determin ing GACT for a particular area source category, EPA considers the costs and economic impact s of available control technologies and management practices on that category.

Emergency CI

For existing stationary emergenc y CI engines located at area sources, EPA believes that it is appropriate to set GACT to be the same requi rements as is required fo r emergency engines at major sources because the same issues that were discussed above for stationary emergency CI engines at major sources apply to emergency CI engines at area sources. There is no reason why the requirements for engines located at area sour ces pursuant to GACT should be different than those for engines located at major sources. Th e management practices are generally available and being located at an area source does not prevent the engine from being maintained appropriately and according to how engines at majo r sources are being maintained. Further, the management practices do not present an economic burden on area source engines and are for that reason also considered appropria te. Therefore, GACT for exis ting stationary emergency CI engines at area sources is the use of management practices as follows:

• changing the oil and oil filter every 500 hours of operation or annually, whichever comes first, with an option to use an o il analysis program as discussed above;

• inspecting the air cleaner every 1,000 hour s of operation or annually, whichever comes first; and

• inspecting all hoses and belts and replaci ng as necessary every 500 hours of operation or annually, whicheve r comes first.

Black Start Engines

For existing stationary black start engines located at area sources, EPA believes that it is appropriate to set GACT to be th e same requirements as is requi red for black start engines at major sources because the same issues that we re discussed above for stationary black start engines at major sources apply to these engines at area sources. There is no reason why the requirements for area sources pursuant to GACT s hould be different than those for black start engines at major sources. Therefore, GACT for ex isting stationary emergency CI engines at area sources is the use of manage ment practices as follows:8 • changing the oil and oil filter every 500 hours of operation or annually, whichever comes first, with an option to use an o il analysis program as discussed above;

• inspecting the air cleaner every 1,000 hour s of operation or annually, whichever comes first; and

• inspecting all hoses and belts and replaci ng as necessary every 500 hours of operation or annually, whicheve r comes first.

Non-Emergency CI <100 HP

For existing stationary non-emergency CI engines less than 100 HP located at area sources, EPA believes that it is appropriate to set GACT to be the same requirements as is required for non-emergency CI engines less than 100 HP at major sources because the same issues that were discussed above for stationary non-emergency CI engine s less than 100 HP at major sources apply to non-emergency CI engines less than 100 HP at area sources. There is no reason why the requirements for engines located at area sources pursuant to GACT should be different than the requirements for engines lo cated at major sources. Therefore, GACT for existing stationary non-emergency CI engines less than 100 HP at area sources is the use of management practices as follows:

• changing the oil and oil filter every 1,000 hours of operation or annually, whichever comes first, with an option to use an o il analysis program as discussed above;

• inspecting the air cleaner every 1,000 hour s of operation or annually, whichever comes first; and

• inspecting all hoses and belts and replaci ng as necessary every 500 hours of operation or annually, whicheve r comes first.

Non-Emergency CI 100 ≤ HP ≤ 300

For existing stationary non-emergency engines between 100 HP and 300 HP, EPA determined that management practices were a ppropriate for GACT. A lthough add-on controls are technically feasible for these engines located at area sources, control costs are high and EPA believes that it is possible to achieve reasonabl e controls using manage ment practices. For example, capital costs associated with installing an oxidation catalyst on a 200 HP diesel engine are about $4,500 with annual cost s of $1,500. Such costs are signi ficant particularly when one considers that the cost per ton of this option is as high as $265,000 per ton of HAP reduced for some engines. EPA has estimated that ther e are over 64,000 existing stationary non-emergency engines between 100 HP and 300 HP located at area sources. The impacts of requiring add-on controls on these engines would be more than $320 million for equipment costs alone and total yearly costs would be more than $105 million, no t including associated costs such as monitoring, testing, reporting, and recordkeeping that would be necessary in order to ensure compliance with

an emission standard. For more information on th e cost per ton of HAP reduced, please refer to the memorandum entitled “Cost per Ton of HAP Re duced for Existing Stationary CI RICE” in the rulemaking docket (EPA-HQ-OAR-2008-0708).9 Furthermore, EPA is attempting to minimize th e burden of the proposed rule, specifically

on small businesses and individual owners a nd operators. EPA does not believe that management practices would be a substantial bu rden on owners and operators such as home owners and small entities. Additionally, the cumu lative testing cost that would be associated with requiring existing non-emergency CI engi nes between 100 HP and 300 HP at area sources

to meet a numerical emission limitation would be in the vicinity of $37 million. In addition,

there would be other associated costs with demonstrating comp liance with a numerical emission limit, such as notification and reporting requireme nts. Finalizing the sa me numerical emission

limit consistent with the emission limit finalized for existing non-emergency CI engines between 100 HP and 300 HP at major sources would have possibly resulted in some existing area source engines having to install aftert reatment. Purchasing, installing and operating add-on controls would lead to even further costs, increasing th e total burden on these sources. For example, assuming that 35 percent of exis ting stationary non-emergency CI engines between 100 HP and

300 HP located at area sources woul d have to install and operate af tertreatment controls in order to comply with a numerical emission limit, cap ital and annual costs would add an additional $100 million in capital costs and $37 million yearly for operation and maintenance of the control

device. EPA believes these costs are excessive a nd not justified in comparison to the amount of pollutant that would be reduced with requiri ng a numerical emission lim it as was done for the same engines at major sources.

Consequently, GACT for existi ng stationary non-emergency CI engines between 100 HP

and 300 HP at area sources is the use of management practices as follows:

• changing the oil and oil filter every 1,000 hours of operation or annually, whichever comes first, with an option to use an o il analysis program as discussed above;

• inspecting the air cleaner every 1,000 hour s of operation or annually, whichever comes first; and

• inspecting all hoses and belts and replaci ng as necessary every 500 hours of operation or annually, whicheve r comes first.

Non-Emergency CI 300<HP ≤ 500

For subcategories of existing stationary non- emergency CI engines greater than 300 HP, EPA believes that oxidation catalys t is readily available and feasible for all existing stationary non-emergency CI engines above 300 HP generally regardless of locatio n. Further, EPA has determined that costs associated with impl ementing HAP-reducing technologies are reasonable and justified. In addition, it is estimated th at the benefits per t on are between $330,000 (Pope, 7%) and $790,000 (Laden, 7%) for PM 2.5 for existing stationary CI e ngines at area sources. For

more information on the benefits per ton of PM 2.5 emission reductions, please refer to the Regulatory Impact Analysis for the final rule, av ailable in the docket. The benefits per ton outweigh the costs. Further information on the specific add-on control costs and cost per ton estimates can be found in the memorandum “Cost per Ton of HAP Reduced for Existing Stationary CI RICE,” available from the docket (EPA-HQ-OAR-2008-0708). Therefore, EPA

has determined that GACT should be based on the use of oxidation catalysts for existing stationary non-emergency CI engi nes greater than 300 HP and less th an or equal to 500 HP that are located at area sources. For existing stat ionary non-emergency CI engines greater than 30010 HP and less than or equal to 500 HP located at area sources, GACT for HAP emissions was therefore determined to be 49 parts per million by volume dry basis (ppmvd) at 15 percent O 2 or the reduction of CO by 70 percent.

In addition, in order to provide further re duction in metallic HAP emissions from nonemergency engines between 300 HP and 500 HP at area sources, EPA believes GACT should include the same requirements fo r further reduction in crankcase emissions as was required for such engines at major sources. The rationale for promulgating such requirements for such engines at major sources is found in the preambl e and Response to Comments document for this

rule and in the memorandum titled “MACT Floor Determination for Existing Stationary NonEmergency CI RICE Greater Than or Equal 100 HP Located at Major Sources,” which is available in the rulemaking docket (EPA-HQ-OAR-2008-0708).

Therefore, GACT for non-emer gency CI engines between 300 HP and 500 HP that are located at area sources includes the following requirement: 1) install a closed crankcase ventilation system that prevents crankcase emissi ons from being emitted to the atmosphere, or 2) install an open crankcase filtration emission control system that reduces the crankcase emissions by filtering the exhaust stream to remove oil mist, particulates, and metals.

Non-Emergency CI >500 HP

For stationary non-emergency CI engines greater than 500 HP, EPA believes that oxidation catalyst technology is readily availabl e and feasible for all existing stationary nonemergency CI engines above 500 HP generally regardless of location. Further, EPA has determined that costs associated with impl ementing HAP-reducing technologies are reasonable and justified. In addition, it is estimated that the benefits per ton are between $330,000 (Pope, 7%) and $790,000 (Laden, 7%) for PM for existing st ationary CI engines at area sources. The benefits per ton outweigh the co sts. Further information on th e monetized benefits and the specific add-on control costs and cost per ton estimates can be found in the memorandum “Cost per Ton of HAP Reduced for Existing Stationary CI RICE,” available from the docket as (EPAHQ-OAR-2008-0708). Therefore, EP A has determined that GACT should be based on the use of oxidation catalysts for existing stationary non-emergency CI engi nes greater than 500 HP that are located at area sources. Therefore, for ex isting stationary non-emer gency CI engines greater than 500 HP located at area sources, GACT for HAP emissions is 23 ppmvd of CO at 15 percent

O 2 or the reduction of CO by 70 percent.

Again, in order to provide further reduc tion in metallic HAP emissions from nonemergency engines greater than 500 HP, EP A believes GACT should include the same requirements for further reduction in crankcase emissions as was required for such engines at major sources. Therefore, GACT for non-emergenc y CI engines greater than 500 HP that are located at area sources includes the following: 1) install a closed crankcase ventilation system that prevents crankcase emissions from being emitted to the atmosphere, or 2) install an open crankcase filtration emission control system that reduces the crankcase emissions by filtering the exhaust stream to remove oil mist, particulates, and metals.

CI Engines Located in Rural Areas of Alaska not accessible by FAHS11 For CI engines less than or e qual to 300 HP located in remote areas of Alaska, EPA has determined that GACT is management practices. However, GACT for othe r existing stationary non-emergency CI engines greater than 300 HP lo cated at area sources is based on the use of add-on controls and requires either compliance with a concentration or a percent reduction standard. Non-emergency CI engi nes greater than 300 HP that are located in area of Alaska not accessible by the Federal Air Highway System (FAHS), due to issues related to fuel availability and cost, location of sources, and colder w eather conditions, to name a few, face unique challenges. Therefore, EPA believes it is not ap propriate to set the same standards as for nonemergency CI engines greater than 300 HP atother area sources. Therefore, GACT for nonemergency CI engines greater than 300 HP that are located in area of Alaska not accessible by FAHS is management practices as follows:

• changing the oil and oil filter every 1,000 hours of operation or annually, whichever comes first, with an option to use an o il analysis program as discussed above;

• inspecting the air cleaner every 1,000 hour s of operation or annually, whichever comes first; and

• inspecting all hoses and belts and replaci ng as necessary every 500 hours of operation or annually, whicheve r comes first.12 Appendix A

Existing Stationary CI Engine Test Data Summary13Test Date Engine NumberEngineSize(HP)Test MethodUsedCO Concentration (ppmvd @ 15% O2)CommentsTest FacilityAverageRun1Run2Run3Santa Barbara County Air Pollution Control District 1/22/2009 East Crane 3 160 CARB 100 479.8 496.4 497.5 445.4Santa Barbara County Air Pollution Control District 1/22/2009 West Crane 1 160 CARB 100 222.9 221.3 217.5 229.9Santa Barbara County Air Pollution Control District 1/20/2009 East Crane 1 450 CARB 100 129.6 124.2 127.5 137.2Santa Barbara County Air Pollution Control District 1/21/2009 East Crane 2 450 CARB 100 154.4 140.3 160.2 162.7Precision Power 7/27/2005 Engine 1 550 EPAMethod 10 45.6 46.6 45.0 45.1 100% loadPrecision Power 7/29/2005 Engine 2 550 EPAMethod 10 90.9 93.590.4 88.8 25% loadPrecision Power 7/29/2005 Engine 2 550 EPAMethod 10 57.7 56.658.8 57.5 50% loadPrecision Power 7/29/2005 Engine 2 550 EPAMethod 10 41.6 42.541.0 41.4 75% loadPrecision Power 7/27/2005 Engine 2 550 EPAMethod 10 23.5 23.7 23.7 23.0 100% loadPrecision Power 7/28/2005 Engine 3 550 EPA Method10 82.8 62.0 93.5 92.925% load, Arctic fuelPrecision Power 7/28/2005 Engine 3 550 EPA Method10 59.9 59.3 58.3 62.350% load, Arctic fuelPrecision Power 7/28/2005 Engine 3 550 EPA Method10 39.5 40.8 39.7 37.875% load, Arctic fuelPrecision Power 7/28/2005 Engine 3 550 EPA Method10 42.8 41.6 44.3 42.4 100% load, Arctic fuelPrecision Power 7/26/2005 Engine 3 550 EPAMethod 10 42.3 41.9 43.7 41.2 100% loadPrecision Power 7/26/2005 Engine 4 550 EPAMethod 10 28.9 25.6 23.2 38.0 100% loadCSU-Engines & Energy Conversion Laboratory 9/2/1999 Caterpillar 3508 1000 EPA Method 1076.8 76.8 70% loadCSU-Engines & Energy Conversion Laboratory 9/1/1999 Caterpillar 3508 1000 EPA Method 1044.1 44.1 70% loadCSU-Engines & Energy Conversion Laboratory 8/31/1999 Caterpillar 3508 1000 EPA Method 10 43.5 43.5 100% loadCSU-Engines & Energy Conversion Laboratory 8/31/1999 Caterpillar 3508 1000 EPA Method 10 41.6 41.6 100% loadCSU-Engines & Energy Conversion Laboratory 9/1/1999 Caterpillar 3508 1000 EPA Method 10 42.7 42.7 100% loadCSU-Engines & Energy Conversion Laboratory 8/31/1999 Caterpillar 3508 1000 EPA Method 10 45.2 45.2 100% loadCSU-Engines & Energy Conversion Laboratory 8/31/1999 Caterpillar 3508 1000 EPA Method 10 44.1 44.1 100% loadCSU-Engines & Energy Conversion Laboratory 9/1/1999 Caterpillar 3508 1000 EPA Method 10 41.6 41.6 100% loadCSU-Engines & Energy Conversion Laboratory 9/1/1999 Caterpillar 3508 1000 EPA Method 1076.2 76.2 70% loadCSU-Engines & Energy Conversion Laboratory 8/31/1999 Caterpillar 3508 1000 EPA Method 10 39.8 39.8 100% loadBadami Development Facility 6/26/2003 Generator 2 1680 EPA Method 10 327.1 330.3 330.1 320.8 75% loadBadami Development Facility 6/26/2003 Generator 2 1680EPA Method 10 265.4 267.2 263.7 265.1 100% loadBadami Development Facility 6/26/2003 Generator 21680 EPA Method 10 196.9 182 200 209 50% loadBadami Development Facility 6/25/2003 Generator 21680 EPA Method 10 77.777.8 74.9 80.3 25% loadNorthstar Development Project - BP 7/8/2004 Engine6 3570 EPA Method 10 69.4 69.2 69.2 69.9 Low loadNorthstar Development Project - BP 7/8/2004 Engine6 3570 EPA Method 10 54.9 55.8 54.2 54.6 High loadNorthstar Development Project - BP 7/9/2004 Engine6 3570 EPA Method 10 55.5 56.7 54.9 54.8 Mid loadNorthstar Development Project - BP 7/9/2004 Engine7 3570 EPA Method 10 142.9 142.9 Mid loadNorthstar Development Project - BP 7/9/2004 Engine 73570 EPA Method 10 131.1 126.5 132.1 134.8 High loadNorthstar Development Project - BP 7/9/2004 Engine7 3570 EPA Method 10 127.8 127.8 Low load