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/R Incorporated Providing Environmental Technical Support Since 1989

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MEMORANDUM 

DATE: February 4, 2010 

SUBJECT: Draft MACT Floor and MACT Determination for Existing Stationary NonEmergency CI RICE Greater Than or Equal to 100 HP Located at Major 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 and MACT for existing stationary non-emergency 

compression ignition (CI) reciprocating internal combustion engines (RICE) greater than or 

equal to 100 horsepower (HP) located at major sources that are subject to the National Emission 

Standards for Hazardous Air Pollutants (NESHAP). 

The MACT analysis for existing stationary non-emergency CI engines less than 100 HP 

and existing stationary emergency and black start CI engines at major sources, and the Generally 

Achievable Control Technology analysis for existing stationary CI engines located at area 

sources of hazardous air pollutants (HAP) emissions are presented in a separate memorandum 

titled “MACT Floor Determination for Existing 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,” which is available in the rulemaking 

docket (Docket No. EPA-HQ-OAR-2008-0708). A “major source” means generally any 

stationary source or group of stationary sources located within a contiguous area and under 

common control that emits or has the potential to emit considering controls, in the aggregate, 10 

tons per year or more of any hazardous air pollutant or 25 tons per year or more of any 

combination of HAP. 

2.0 INTRODUCTION

The EPA has developed a regulation affecting existing stationary CI RICE located at 

major sources that will address toxic air emissions from these engines. The regulation was 

developed following criteria set forth under section 112 of the Clean Air Act (CAA). The 

MACT floor for existing sources must be no less stringent than the average emission limitation 

achieved by the best performing 12 percent of existing sources for which the Administrator has 
2 

emissions information.1 The MACT standards must be no less stringent than the MACT floor. 

EPA must also determine whether to control emissions “beyond-the-floor,” after considering the 

costs, non-air quality health and environmental impacts, and energy requirements of such more 

stringent control. The EPA has previously issued a similar regulation affecting 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 allows the EPA to establish subcategories among a group of 

sources. A complete discussion of the subcategory selection is presented in a separate 

memorandum2 which can also be found in the rulemaking docket. 

3.0 MACT FLOOR AND MACT DETERMINATION 

General Approach

The MACT floor for existing stationary RICE must be no less stringent than the average 

emission limitation achieved by the best performing 12 percent of existing sources for which the 

Administrator has emissions information. In the proposed rule, EPA established the MACT 

floor for each subcategory of stationary existing CI engines using the emissions data that EPA 

had for stationary CI engines, which consisted of testing conducted by EPA and industry at 

Colorado State University (CSU) on a 1,000 HP CI engine. During the comment period, EPA 

received five additional test reports that included emission results for 13 existing stationary CI 

engines ranging from 160 HP to 3,570 HP. These new test data along with the test data from the 

CSU testing were used to determine the MACT floor for each of the subcategories. A summary 

of the average test results for each of the engines is presented in Appendix A. The test reports 

for the test data used to determine the MACT floor are provided in the Docket as Document ID 

Nos. EPA-HQ-OAR-2002-0059-0018 and EPA-HQ-OAR-2008-0708-0272 through 0275. 

EPA has previously conducted an analysis for the RICE NESHAP for engines greater 

than 500 HP at major sources, which investigated whether carbon monoxide (CO) could be used 

as a surrogate for HAP from stationary engines. The conclusion of the analysis was that CO is a 

reasonable surrogate for formaldehyde for CI engines, and that formaldehyde is a reasonable 

surrogate for HAP for CI engines.3

 To determine the MACT floor for each of the subcategories, 

EPA used the following methodology: (1) we ranked the average emissions from each engine 

from lowest to highest; (2) we determined the units in the MACT floor; (3) we assessed 

variability. The MACT floor and MACT determination for each subcategory is described below 

and is summarized in Table 1. A summary of the test data that was used to set the MACT floor 

is presented in Appendix B. 

 

1 Note there are more than 30 engines in each subcategory 

2

 Memorandum from Bradley Nelson and Tanya Parise, EC/R Inc. to Melanie King, EPA OAQPS/SPPD/ESG, 

Subcategorization of Existing Stationary CI RICE, January 29, 2010. 

3

 Memorandum from Melanie Taylor and Jennifer Snyder, Alpha-Gamma Technologies to Sims Roy, EPA OAQPS 

ESD Combustion Group, CO Removal Efficiency as a Surrogate for HAP Removal Efficiency, January 7, 2004 

(EPA-HQ-OAR-2002-0059-0665.) 
3 

Table 1. Summary of Determination for 

Existing Stationary Non-Emergency CI RICE ≥100 HP 

Located at Major Sources 

Subcategory MACT Floor MACT 

Non-Emergency CI 

100≤HP≤300 230 ppmvd CO @15% O2 230 ppmvd CO @15% O2

Non-Emergency CI 

300<HP≤500 137 ppmvd CO @15% O2

49 ppmvd CO @15% O2 

or 

70% CO reduction 

Non-Emergency CI 

>500 HP 38 ppmvd CO @15% O2

23 ppmvd CO @15% O2 

or 

70% CO reduction 

Non-Emergency CI 100≤HP≤300

EPA has test data for two engines in this subcategory; therefore, the best performing 12 

percent of sources in this subcategory is represented by a single engine. The MACT floor engine 

was tested for three runs. To account for variability, EPA used the highest individual run to 

establish the MACT floor. As shown in Appendix B, the resulting MACT floor for nonemergency CI engines between 100 and 300 HP is 230 parts per million by volume, dry basis 

(ppmvd) of CO at 15 percent oxygen (O2). 

We also evaluated whether to go beyond-the-floor. Specifically, EPA considered 

additional emission controls that would further reduce HAP emissions. One control that we 

considered for reducing HAP is a diesel oxidation catalyst (DOC). The DOC technology is 

capable of reducing HAP emissions by 70 percent or more. The DOC technology also reduces 

emissions of CO by 70 percent or more, as well as particulate matter (PM) emissions. 

Achievable reductions of PM are on the order of 30 percent for the DOC. 

EPA also considered the use of open crankcase ventilation (OCV) or closed crankcase 

ventilation (CCV) systems to further reduce emissions of metallic HAP under section 

112(d)(2)(B) and (C), as a measure that encloses systems to eliminate emissions or collects, 

captures or treats such pollutants. EPA also notes that it does not believe it would be feasible at 

this time to prescribe an emission standard for metallic HAP. It is believed that combustion 

gases and oil mist that are vented from the engine crankcase are a substantial source of any 

metallic HAP emissions from stationary CI engines. Most existing stationary CI engines have 

open crankcases that vent the crankcase emissions directly to the atmosphere. It would not be 

practicable to measure the metallic HAP emissions since the crankcase is open directly to the 

atmosphere rather than vented to the engine exhaust. Capturing these emissions using EPA 

Method 29 would be difficult due to the sporadic flowrate of the blow-by gases, making 

isokinetic sampling of the crankcase exhaust difficult. In addition, testing for metallic HAP is at 

least $15,000-$20,000 per engine, and the emission levels from stationary CI engines are likely 
4 

to be below method detection limits, so current test methods may not be able to accurately 

measure such emissions. Consequently, it would be infeasible to prescribe a numerical emission 

standard for metallic HAP for existing stationary CI engines. Therefore, the use of OCV or CCV 

systems would also be justified under section 112(d)(2)(D) as a design, equipment or work 

practice. EPA believes that a standard that requires the use of OCV or CCV systems would be 

the most appropriate method for further reducing metallic HAP emissions for existing stationary 

CI engines. For the purpose of this analysis, EPA used OCV, rather than CCV as the emission 

control we would expect sources to use; while CCV systems that prevent the crankcase 

emissions from being emitted to the atmosphere are also an option for reducing crankcase 

emissions, EPA does not believe that it is feasible to retrofit all existing stationary CI engines 

with CCV systems due to feasibility concerns. This was discussed in a meeting between EPA 

and the Engine Manufacturers Association on November 19, 2009 and in a letter from EMA to 

EPA dated December 4, 2009. A summary of that meeting and the letter from EMA are 

available in the docket as Document ID Numbers EPA-HQ-OAR-2008-0708-XXXX and 

YYYY. 

EPA evaluated the cost of DOC/OCV control compared to the HAP reductions that 

would be achieved. Going above-the-floor and requiring DOC/OCV on all non-emergency CI 

engines would require significant total capital investment and total annual control costs, which 

EPA does not believe are justified for these engines. For example, the cost per ton of HAP 

reduced for non-emergency CI engines between 100 HP and 175 HP is more than $265,000. The 

cost per ton is based on reducing HAP emissions by 70 percent from uncontrolled levels or an 

emission reduction of approximately 15 pounds per year (lb/yr) for a 200 HP engine. Capital 

costs for a 200 HP for installing DOC/OCV is estimated at close to $6,000. For information on 

the cost per ton of HAP reduced, please refer to the memorandum entitled “Cost per Ton of HAP 

Reduced for Existing Stationary CI RICE” in the rulemaking docket (EPA-HQ-OAR-2008-

0708). MACT is therefore equivalent to the MACT floor for this subcategory. 

Non-Emergency CI 300<HP≤500

EPA has test data for two engines in this subcategory. The average of the top 12 percent 

of existing sources is therefore based on data from one engine. In order to account for emissions 

variability, the highest test run for the engine was determined to be the MACT floor. As shown 

in Appendix B, the MACT floor for CI non-emergency stationary RICE between 300 HP and 

500 HP is 137 ppmvd of CO at 15 percent O2. 

We also evaluated whether to go beyond-the-floor for this subcategory. Specifically, 

EPA considered additional emission controls to further reduce HAP emissions. EPA considered 

the use of DOC systems in conjunction with OCV systems. Stationary existing CI engines were 

largely uncontrolled at the Federal level prior to the promulgation of EPA’s emission standards 

for stationary CI engines in 2004, which affected engines constructed beginning in 2002. Nonemergency CI engines are estimated to emit 90 percent of total combined PM and nitrogen 

oxides (NOX) emissions from all existing stationary CI engines, with emergency engines 

emitting the remaining 10 percent. Of the non-emergency CI engines, about 50,000 nonemergency engines rated 300 HP or higher were built prior to 2002, which is about 29 percent of 

the existing population of non-emergency stationary CI engines. These 50,000 non-emergency 
5 

CI engines emit approximately 72 percent of the total HAP emissions, 66 percent of the total PM 

emissions, and 62 percent of the total NOX emissions from existing non-emergency stationary CI 

engines. This information is based on data from the Power Systems Research Database that was 

presented in Tables 1-4 of EPA’s January 24, 2008 ANPRM for stationary CI engines emission 

standards (73 FR 4136). For these reasons, EPA concluded that it can achieve the highest level 

of emission reduction relative to cost, while requiring controls where appropriate, by requiring 

more stringent emission standards on non-emergency stationary CI engines with a power rating 

greater than 300 HP. 

EPA evaluated the cost of these systems compared to the emission reductions that would 

be achieved by the use of DOC/OCV for engines in this subcategory and determined that the 

costs were reasonable when compared to the amount of emission reductions that would be 

achieved through the use of these controls. For example, the cost per ton of HAP reduced for 

non-emergency CI engines between 300 HP and 500 HP is about $170,000. Again, the cost per 

ton is based on reducing HAP emissions by 70 percent from uncontrolled levels. For a nonemergency 400 HP CI engine this would equate to an emission reduction of approximately 30 

lb/yr; twice that of a 200 HP engine. For information on the cost per ton of HAP reduced, please 

refer to the memorandum entitled “Cost per Ton of HAP Reduced for Existing Stationary CI 

RICE” in the rulemaking docket (EPA-HQ-OAR-2008-0708). 

To determine MACT for non-emergency CI engines greater than 300 HP and less than or 

equal to 500 HP, EPA reviewed the test data for CI engines greater than 300 HP and less than or 

equal to 500 HP and selected the highest CO test run for the two engines in that range. Then, 

EPA applied a control efficiency of 70 percent to that CO concentration level. The 70 percent 

reduction efficiency for DOC represents the lowest reduction in CO from a DOC that was 

measured during EPA’s testing of a stationary diesel engine at CSU; the CO reduction measured 

during the CSU testing ranged from 70 to 84 percent. By selecting the lowest reduction, EPA 

has accounted for emissions variability in the subcategory while ensuring that emission levels 

will be below the MACT floor level after accounting for emission controls. Consequently, EPA 

determined that MACT for HAP for non-emergency CI engines greater than 300 HP and less 

than or equal to 500 HP is 49 ppmvd of CO at 15 percent O2, or 70 percent CO efficiency. EPA 

has also determined that it would be appropriate to require the use of ultra low sulfur diesel 

(ULSD) fuel for these engines. The use of ULSD is necessary due to concerns about DOCs 

simultaneously oxidizing SO2 to form sulfate particulate. A limit on the diesel fuel sulfur level of 

15 ppm will reduce the potential for increased sulfate emissions from diesel engines equipped 

with DOCs. The limit on fuel sulfur will also improve the efficiency of the DOC. 

In order to further reduce metallic HAP emissions, EPA believes it is appropriate 

establish a separate requirement for metallic HAP emissions from the crankcase. As discussed 

above, it is not possible to set a numerical emission standard for metallic HAP. To reduce 

emissions of metallic HAP, an OCV filtration system was considered. The OCV system captures 

blow-by emissions from the pistons, which include both oil mist and worn metal from the 

combustion cylinders, and reduces metallic HAP emissions from the engine. Closed crankcase 

ventilation (CCV) systems that prevent the crankcase emissions from being emitted to the 

atmosphere are also an option for reducing crankcase emissions; however EPA believes that it 

may not be feasible for some existing stationary CI engines to retrofit with CCV systems (see 
6 

EPA-HQ-OAR-2008-0708-XXXX and YYYY). Therefore, EPA believes it is appropriate to 

provide sources the option to choose either OCV or CCV systems and has specified that nonemergency CI engines between 300 HP and 500 HP located at major sources must either: 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. 

Of further consideration are the co-benefits that would be achieved by requiring the use 

of the DOC/OCV option. The control technology will reduce other pollutants such as CO and 

PM, which are of significant health concern. In addition, the requirement will also reduce the 

emissions of sulfur dioxide (SO2), because this control option requires the use of ULSD fuel. 

Taking into account the reductions in CO, SO2 and PM associated with applying DOC/OCV to 

non-emergency CI engines, the cost per ton of pollutants reduced decreases. For instance, the 

cost per ton of PM reduced for non-emergency CI engines between 300 HP and 500 HP is 

around $61,000 and the cost per ton for SO2 is about $32,000. The cost per ton for PM is based 

on reducing PM emissions by 30 percent from uncontrolled levels, which would mean an 

emission reduction of more than 80 lb/yr of PM from a 400 HP engine. It is estimated that the 

benefits per ton are $210,000 (Pope, 7%) and $500,000 (Laden, 7%) for PM for existing 

stationary CI engines at major sources. The benefits per ton of SO2 for existing stationary CI 

engines at major sources are estimated at $27,000 (Pope, 7%) and $65,000 (Laden, 7%). It is 

clear that the overall benefits significantly outweigh the costs. Further information on the 

monetized benefits can be found in the memorandum titled “Cost per Ton of HAP Reduced for 

Existing Stationary CI RICE,” available from the docket as Document ID Number EPA-HQOAR-2008-0708-XXXX. The total co-benefits of this regulation are presented in the 

memorandum titled “Impacts Associated with NESHAP for Existing Stationary CI RICE,” 

available from the rulemaking docket. 

Non-Emergency CI >500 HP

EPA has test data for eight engines in this subcategory. The average of the top 12 percent 

is therefore based on data for one engine. To determine the MACT floor for this subcategory, 

EPA selected the highest test run for the MACT floor engine in order to account for emissions 

variability. As shown in Appendix B, the MACT floor for CI non-emergency stationary RICE 

greater than 500 HP is 38 ppmvd of CO at 15 percent O2. 

We also evaluated whether to go beyond-the-floor for this subcategory. Specifically, 

EPA considered DOC/OCV. After evaluating the cost of these controls and the emission 

reductions that can be achieved for engines in this subcategory, EPA believes that requiring 

above-the-floor levels that are based on DOC/OCV control is appropriate for non-emergency CI 

engines greater than 500 HP. For example, the cost per ton of HAP reduced for non-emergency 

CI engines above 500 HP is about $162,000 or less. Based on reducing HAP emissions by 70 

percent from uncontrolled levels, annual emission reduction would be approximately 45 lb/yr per 

engine for a 600 HP engine. 
7 

To determine the above-the-floor emission limitation for non-emergency CI engines 

greater than 500 HP, EPA reviewed the test data for CI engines greater than 500 HP. EPA 

applied a control efficiency of 70 percent to the CO concentration level that represented the 

highest CO concentration value taken from the CSU-Engines & Energy Conservation Laboratory 

data, which tested over a wide range of operating loads. The CO reduction measured during the 

CSU testing ranged from 70 to 84 percent; EPA selected the lowest percent reduction that was 

measured during the testing in order to account for emissions variability. As a result, EPA 

determined that MACT for HAP emissions for non-emergency CI engines greater than 500 HP is 

23 ppmvd of CO at 15 percent O2 or 70 percent CO efficiency. 

To further address metallic HAP emissions from stationary non-emergency CI engines 

greater than 500 HP, EPA is requiring that these sources either: 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. 

Of further consideration are the co-benefits that would be achieved by requiring the use 

of the DOC/OCV option. The control technology will reduce other pollutants such as CO and 

PM, which are of significant health concern. In addition, the requirement will also reduce the 

emissions of SO2, because this control option requires the use of ULSD fuel. Taking into 

account the reductions in CO, SO2 and PM associated with applying DOC/OCV to nonemergency CI engines, the cost per ton of pollutants reduced decreases. The cost per ton of PM 

reduced for non-emergency CI engines above 500 HP is less than $58,000 and the cost per ton 

for SO2 is $31,000 or less. The cost per ton of VOC is $7,000 or below for non-emergency 

engines above 500 HP. Again, the cost per ton for PM is based on reducing PM emissions by 30 

percent from uncontrolled levels, which would mean an emission reduction of more than 120 

lb/yr of PM from a 600 HP engine. Again, the total benefits per ton for existing stationary CI 

engines at major sources, which for PM are $210,000 (Pope, 7%) and $500,000 (Laden, 7%) and 

for SO2 are $27,000 (Pope, 7%) and $65,000 (Laden, 7%) show that overall benefits significantly 

outweigh the costs. Further information on the monetized benefits can be found in the 

memorandum titled “Cost per Ton of HAP Reduced for Existing Stationary CI RICE,” available 

from the docket as Document ID Number EPA-HQ-OAR-2008-0708-XXXX. The total cobenefits of this regulation are presented in the memorandum titled “Impacts Associated with 

NESHAP for Existing Stationary CI RICE,” available from the rulemaking docket. 
8 

Appendix A 

Existing Stationary CI Engine Test Data Summary
9 

Test Date Engine Number 

Engine Size (HP) 

Test Method 

Used 

CO Concentration (ppmvd @ 15% O2) 

Average Comments 

Run 

1 

Run 

2 

Run 

3 

1/22/2009 East Crane 3 160 CARB 100 479.8 496.4 497.5 445.4 

1/22/2009 West Crane 1 160 CARB 100 222.9 221.3 217.5 229.9 1/20/2009 East Crane 1 450 CARB 100 129.6 124.2 127.5 137.2 1/21/2009 East Crane 2 450 CARB 100 154.4 140.3 160.2 162.7 7/27/2005 Engine 1 550 EPA Method 10 45.6 46.6 45.0 45.1 100% load 7/29/2005 Engine 2 550 EPA Method 10 90.9 93.5 90.4 88.8 25% load 7/29/2005 Engine 2 550 EPA Method 10 57.7 56.6 58.8 57.5 50% load 7/29/2005 Engine 2 550 EPA Method 10 41.6 42.5 41.0 41.4 75% load 7/27/2005 Engine 2 550 EPA Method 10 23.5 23.7 23.7 23.0 100% load 7/28/2005 Engine 3 550 EPA Method 10 82.8 62.0 93.5 92.9 25% load, Arctic fuel 7/28/2005 Engine 3 550 EPA Method 10 59.9 59.3 58.3 62.3 50% load, Arctic fuel 7/28/2005 Engine 3 550 EPA Method 10 39.5 40.8 39.7 37.8 75% load, Arctic fuel 7/28/2005 Engine 3 550 EPA Method 10 42.8 41.6 44.3 42.4 100% load, Arctic fuel 7/26/2005 Engine 3 550 EPA Method 10 42.3 41.9 43.7 41.2 100% load 7/26/2005 Engine 4 550 EPA Method 10 28.9 25.6 23.2 38.0 100% load 

9/2/1999 Caterpillar 3508 1000 EPA Method 10 76.8 76.8 70% load 9/1/1999 Caterpillar 3508 1000 EPA Method 10 44.1 44.1 70% load 

8/31/1999 Caterpillar 3508 1000 EPA Method 10 43.5 43.5 100% load 8/31/1999 Caterpillar 3508 1000 EPA Method 10 41.6 41.6 100% load 

9/1/1999 Caterpillar 3508 1000 EPA Method 10 42.7 42.7 100% load 

8/31/1999 Caterpillar 3508 1000 EPA Method 10 45.2 45.2 100% load 8/31/1999 Caterpillar 3508 1000 EPA Method 10 44.1 44.1 100% load 

9/1/1999 Caterpillar 3508 1000 EPA Method 10 41.6 41.6 100% load 9/1/1999 Caterpillar 3508 1000 EPA Method 10 76.2 76.2 70% load 

8/31/1999 Caterpillar 3508 1000 EPA Method 10 39.8 39.8 100% load 6/26/2003 Generator 2 1680 EPA Method 10 327.1 330.3 330.1 320.8 75% load 6/26/2003 Generator 2 1680 EPA Method 10 265.4 267.2 263.7 265.1 100% load 6/26/2003 Generator 2 1680 EPA Method 10 196.9 182 200 209 50% load 6/25/2003 Generator 2 1680 EPA Method 10 77.7 77.8 74.9 80.3 25% load 

7/8/2004 Engine 6 3570 EPA Method 10 69.4 69.2 69.2 69.9 Low load 7/8/2004 Engine 6 3570 EPA Method 10 54.9 55.8 54.2 54.6 High load 7/9/2004 Engine 6 3570 EPA Method 10 55.5 56.7 54.9 54.8 Mid load 7/9/2004 Engine 7 3570 EPA Method 10 142.9 142.9 Mid load 7/9/2004 Engine 7 3570 EPA Method 10 131.1 126.5 132.1 134.8 High load 7/9/2004 Engine 7 3570 EPA Method 10 127.8 127.8 Low load 
10 

Appendix B 

MACT Floor Summary
11 

Test Facility Test Date Engine Number 

Engine Size (HP) 

Test Method 

Used 

Highest CO run (ppmvd 

@ 15% O2) 

Santa Barbara County Air Pollution Control District 1/22/2009 West Crane 1 160 CARB 100 229.9 Santa Barbara County Air Pollution Control District 1/22/2009 East Crane 3 160 CARB 100 Santa Barbara County Air Pollution Control District 1/20/2009 East Crane 1 450 CARB 100 137.2 Santa Barbara County Air Pollution Control District 1/21/2009 East Crane 2 450 CARB 100 162.7 Precision Power 7/26/2005 Engine 4 550 

EPA Method 10 38.0 

Precision Power 7/27/2005 Engine 1 550 

EPA Method 10 

Precision Power 7/28/2005 Engine 3 550 

EPA Method 10 

Precision Power 7/29/2005 Engine 2 550 

EPA Method 10 

CSU-Engines & Energy Conversion Laboratory 9/2/1999 

Caterpillar 3508 1000 

EPA Method 10 76.8 

Badami Development Facility 6/26/2003 Generator 2 1680 

EPA Method 10 

Northstar Development Project - BP 7/8/2004 Engine 6 3570 

EPA Method 10 

Northstar Development Project - BP 7/9/2004 Engine 7 3570 

EPA Method 10 

Draft Floor (< 300 HP)Count Top 12% Ave of Top 12% Draft Floor (300-500 HP)Count Top 12% Ave of Top 12% Draft Floor (> 500 HP)Count Top 12% Ave of Top 12% 

Above the Floor (300-500 

Data Point Used 

CO reduction 

Above the Floor Standard 
12 

Above the Floor (> 500 HP

Data Point Used 

CO reduction 

Above the Floor Standard