EC

/R Incorporated Providing Environmental Technical Support Since 1989

6330 Quadrangle Drive, Suite 325 y Chapel Hill, North Carolina 27517 

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

 

MEMORANDUM 

DATE: February 17, 2010 

SUBJECT: Impacts Associated with NESHAP for Existing Stationary CI RICE 

FROM: Bradley Nelson, EC/R, Inc. 

 

TO: Melanie King, EPA OAQPS/SPPD/ESG 

1.0 PURPOSE 

The purpose of 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 compression ignition (CI) stationary reciprocating internal combustion engines 

(RICE). The regulation applies to existing stationary CI RICE located at major and area sources 

of hazardous air pollutants (HAP) emissions. It is estimated that 40 percent of stationary CI 

RICE are located at major sources and 60 percent of stationary CI RICE are located at area 

sources. Impacts discussed in this memorandum include emissions reductions and total costs 

associated with regulatory requirements. Costs associated with the rule include the capital and 

annual cost of purchasing and operating air pollution control equipment, recordkeeping, and 

performance testing. 

The total capital cost associated with the NESHAP for existing stationary CI RICE is 

estimated to be $744 million in the year 2013. The total annual cost of the NESHAP is estimated 

to be $373 million in the year 2013. The NESHAP for existing stationary RICE is estimated to 

reduce HAP emissions in the year 2013 by 1,014 tons per year (TPY). 

2.0 ENGINE POPULATION 

The existing population of CI engines in the U.S. was estimated using information 

obtained from the Power System Research’s (PSR) North American Engine PartsLink Database 

provided by the U.S. EPA Office of Transportation and Air Quality. The CI RICE population 

was estimated using the baseline engine population and engine sales information from PSR.1

 A 

summary of the total number of affected engines is presented in Tables 1 and 2. 

 

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

Table 1. Number of Affected Engines – Major Sources 

Size Range 

(HP) Affected CI Engines1

25-50 0 

50-100 92,734 

100-175 121,507 

175-300 92,144 

300-500 48,481 

500-600 4,298 

600-750 2,200 

>750 4,853 

Total 366,217 

1

Number of affected engines are estimated based on the following applicability dates: 

i. > 500 HP non-emergency CI engines at major sources constructed before 12/19/2002. 

ii. < 500 HP engines at major sources constructed before 6/12/2006. 

Table 2. Number of Affected Engines – Area Sources 

Size Range 

(HP) Affected CI Engines1

25-50 0 

50-100 127,973 

100-175 167,679 

175-300 127,159 

300-600 100,355 

600-750 16,822 

>750 29,802 

Total 569,790 

1

Number of affected engines are estimated based on all engines at area sources constructed 

before 6/12/2006. 

 The population of affected CI engines located at area sources is less than the population 

of existing areas source engines presented in the population memorandum. The final rule does 

not apply to area source emergency CI engines that are residential, commercial, or institutional; 

therefore these CI engines were removed from the affected source inventory for area sources. 

The number of area source emergency CI engines that are residential, commercial, or 

institutional was calculated assuming that 10 percent of the area source engines are residential, 

commercial, or institutional. That 10 percent value was then divided into emergency and nonemergency using the assumed 80/20 percentage (e.g., 80% emergency/20% non-emergency) that 

was used for all CI engines. The totals in Table 2 include only those engines that are subject to 

the regulation. 
3

3.0 COST IMPACTS 

3.1 Introduction 

 The cost impacts associated with the final rule consist of different types of costs, which 

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 purchasing 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 estimated. 

Control Costs

For engines that will need to add control technology to meet the emission standards, the 

following equations were used to estimate capital and annual control costs: 

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

Diesel oxidation catalyst (DOC) $27.4 x HP - $939 $4.99 x HP + $480 

Open crankcase ventilation (OCV) $0.26 x HP + $997 $0.065 x HP + $254 

The control costs for DOC were calculated using cost data obtained from a California Air 

Resources Board (CARB) study.2 The study provided cost ranges for diesel engines ranging 

from 40 HP to 1400 HP. The average cost from the range was selected and was adjusted to 2008 

dollars. The capital and annual cost were calculated using maintenance data from the CARB 

study and cost assumptions from the EPA Control Cost Manual. The control costs for the OCV 

system were calculated using 2008 cost data obtained from a diesel engine equipment vendor. 

An equipment life of 10 years was used to calculate the capital recovery factor (CRF) for 

developing the annual cost for each of the control devices. A linear regression equation was 

developed for the capital cost of the DOC and OCV using the capital cost data and the engine 

size in HP. This approach was used to develop a linear regression equation for annual cost. 

Recordkeeping

No recordkeeping costs were attributed to the requirement of following the 

manufacturer’s emission-related operation and maintenance (O&M) requirements or the owner 

or operator’s own maintenance plan. It is expected that the majority of owners and operators are 

already following some type of O&M requirements and minimal to no additional burden is 

expected. Labor costs associated with recording the hours of operation of emergency engines are 

based on a technical labor rate of $68 per hour which was obtained from the Department of 

Labor Statistics web site.3

 The final total wage rate was based on the 2005 compensation rates 

for professional staff and adjusted by an overhead and profit rate of 167 percent. The year 2005 

 

2

 Diesel PM Control Technologies, Appendix IX, California Air Resource Board, October 2000. 

http://www.arb.ca.gov/diesel/documents/rrpapp9.pdf 3

 U.S. Department of Labor, Employer Costs for Employee Compensation, 

http://www.bls.gov/news.release/ecec.toc.htm 
4

was used for consistency in order to have the same basis for all costs. All costs were later 

converted to 2008 dollars for purposes of presenting costs associated with the rule in present day 

terms. One hour per year is expected to be sufficient to record hours of operation for stationary 

emergency engines. No cost is attributed to purchasing and installing an hour-meter since the 

majority of stationary engines already come equipped with such equipment. For owner/operators 

of non-emergency CI engines, EPA assumed that one hour per year was sufficient for 

recordkeeping for these engines. 

Reporting

 Most engines affected by this rule will be subject to reporting requirements such as 

reading instructions, training personnel, submitting an initial notification, submitting a 

notification of performance test(s), and submitting a compliance report. However, owners and 

operators of engines less than 100 HP, existing stationary emergency engines, and existing 

stationary engines less than 300 HP located at area sources are not subject to any specific 

reporting requirements. For stationary non-emergency limited use CI engines that operate less 

than 100 hours per year, EPA is finalizing less burdensome reporting requirements by requiring 

these engines to submit compliance reports on an annual basis, as opposed to semiannually as is 

required for other engines subject to numerical emission limitations. The reporting requirements 

are based on $68 per hour for technical labor to comply with the reporting requirements. It is 

estimated that a total of 14 hours will be needed for non-limited use engines, and 13 hours for 

limited use engines. 

Monitoring

The cost of monitoring includes the purchase of a continuous parametric monitoring 

system (CPMS). Non-emergency engines greater than 500 HP 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 2008 dollars.4

 The capital cost of a CPMS for a large engine facility 

is $531. It is estimated that 30 hours per year is necessary to operate and maintain the CPMS 

and that 6 hours per year (or 0.5 hours per month) is needed to record information from the 

CPMS. It is assumed that all engines subject to continuous monitoring would be located at large 

engine facilities. 

Performance Testing

Initial performance testing is required for non-emergency engines greater than 100 HP at 

major sources and non-emergency engines greater than 300 HP located at area sources. The cost 

of conducting a performance test on a CI engine is based on cost information gathered for 

previous rulemakings.5 The performance testing cost is based the use of a portable analyzer and 

 

4 Part A of the Supporting Statement for Standard Form 83 Stationary Reciprocating Internal Combustion Engines, 

November 17, 2003. 

5

 Memorandum from Bradley Nelson, Alpha-Gamma Technologies, Inc. to Sims Roy, 

EPA/OAQPS/ESD/Combustion Group, Portable Emissions Analyzer Cost Information, August 31, 2005. 
5

was estimated to cost $1,000 per day of testing. This daily performance test cost was adjusted to 

2008 dollars and was estimated to be $1,165. Because the regulation requires three-1 hour runs, 

EPA assumed that two engines could be tested at each facility in one day. Therefore, the 

estimated impacts performance testing cost will be assumed to be $583 per engine (or half of the 

$1,165 daily cost) using a portable analyzer. 

Work Practices

 The costs for performing work practices for CI engines less than 100 HP located at a 

major source was assumed to be negligible and were not included in these impact calculations. 

The work practices are based on engine maintenance procedures that the owner/operators 

perform regardless of the regulation. These work practices include: 

• Changing the oil and filter; 

• Inspecting the air cleaner; 

• Inspecting all hoses and belts, and replacing as necessary. 

EPA believes that these work practices will limit HAP emissions from these engines, because 

these work practices ensure that the engine is operating efficiently. Owner/operators of these 

engines regularly perform these work practices as part of the preventive maintenance schedule 

for the engine. Therefore, EPA believes that it is appropriate to not include these work practice 

costs in the impacts determination. 

Management Practices

 The costs for performing management practices for non-emergency CI engines less than 

or equal to 300 HP located at area sources and all emergency engines located at area sources was 

assumed to be negligible and were not included in these impact calculations. The management 

practices are based on engine maintenance procedures that the owner/operators perform 

regardless of the regulation. These management practices include: 

• Changing the oil and filter; 

• Inspecting the air cleaner; and 

• Inspecting all hoses and belts, and replacing as necessary. 

EPA believes that these work practices will limit HAP emissions from these engines, because 

these work practices ensure that the engine is operating efficiently. Owner/operators of these 

engines regularly perform these work practices as part of the preventive maintenance schedule 

for the engine. Therefore, EPA believes that it is appropriate to not include these work practice 

costs in the impacts determination. 

 
6

3.2 Major Sources 

The cost impacts for stationary RICE vary depending on the engine type and size. The following 

sections describe the specific costs that apply to each subcategory of CI engines located at major 

sources. 

All CI Engines HP < 100

The costs associated with CI engines less than 100 HP include minimal requirements. 

Owners and operators of engines less than 100 HP are required to follow the manufacturer’s 

emission-related O&M requirements or must develop their own maintenance plan to follow. 

Emergency engines must record the hours of operation, which is estimated at one hour per year 

at $72 per hour. 

Non-emergency CI Engines 100 ≤ HP ≤ 300 HP 

 The costs associated with non-emergency CI engines greater than or equal to 100 HP and 

less than or equal to 300 HP include the cost of an initial test, recordkeeping, and reporting. In 

addition, EPA assumes that some of these engines will be required to install a control device to 

meet the emissions standard. To estimate the number of CI engines that would be required to 

install control technology, EPA compared the emission rate of the test that was used to determine 

the MACT floor with the CI nonroad emission factors.6 EPA found that only the emission 

factors for Tier 0 CI engines were greater than the 1.2 g/HP-hr value that was used to set the 

MACT floor. Therefore, it was assumed that Tier 1 engines and greater would be able to meet 

the final emission standard. The model year for Tier 1 engines begins in 1997 for 100 to 175 CI 

engines, and 1996 for 175 to 300 HP CI engines. Using the model year data in the population 

memorandum, EPA estimated that 35 percent of the existing CI engines greater than or equal to 

100 HP and less than or equal to 300 HP are Tier 0 engines and would need to install control 

technology to meet the emission standard. The cost estimates for this subcategory of engines do 

not account for possible fuel price increases that may result from using ultra-low sulfur diesel 

(ULSD). EPA estimated the cost of lubricity additives to ULSD would increase the cost of the 

fuel by 0.2 cents per gallon,7

 which EPA believes is negligible. In addition, there are no 

additional maintenance requirements for owner/operators using ULSD in existing diesel engines. 

Many owner/operators have found that time between oil changes can be extended for engines 

using ULSD fuel, which would decrease the overall cost of switching to ULSD fuel. Therefore, 

EPA believes that it is appropriate to not include any costs for switching to ULSD in the impacts 

for this NESHAP. 

 

6

 Exhaust and Crankcase Emission Factors for Nonroad Engine Modeling--Compression-Ignition, U.S. EPA, Office 

of Transportation and Air Quality, Assessment and Standards Division, EPA420-P-04-009, Revised April 2004. 

http://www.epa.gov/oms/models/nonrdmdl/nonrdmdl2004/420p04009.pdf 7

 Memorandum from Melanie Taylor and Brad Nelson, AGTI to Sims Roy, EPA OAQPS ESD Combustion Group, 

Lubricity of Ultra Low Sulfur Diesel Fuel, June 2, 2004. 
7

Non-emergency CI Engines > 300 HP

The costs associated with non-emergency CI engines above 300 HP include the cost of 

installing and operating an oxidation catalyst for reducing HAP, as well as the cost of installing 

an open crankcase ventilation system. Non-emergency CI engines greater than 500 HP are also 

subject to continuous monitoring requirements. In addition, owners and operators must conduct 

an initial performance test to demonstrate compliance with the emission limitation. Owners and 

operators of engines above 500 HP must conduct subsequent performance testing every 8,760 

hours or 3 years, whichever comes first to demonstrate compliance. The cost estimates for this 

subcategory of engines do not account for possible fuel price increases that may result from 

using ultra-low sulfur diesel (ULSD). EPA estimated the cost of lubricity additives to ULSD 

would increase the cost of the fuel by 0.2 cents per gallon,8

 which EPA believes is negligible. In 

addition, there are no additional maintenance requirements for owner/operators using ULSD in 

existing diesel engines. Many owner/operators have found that time between oil changes can be 

extended for engines using ULSD fuel, which would decrease the overall cost of switching to 

ULSD fuel. Therefore, EPA believes that it is appropriate to not include any costs for switching 

to ULSD in the impacts for this NESHAP. 

Emergency CI Engines 100 ≤ HP ≤ 500 

The costs associated with emergency CI engines greater than 300 HP and less than or 

equal to 500 HP (emergency CI engines above 500 HP were subject to an earlier rule and are not 

subject to further regulation in this rule) include minimal recordkeeping requirements. The 

owners and operators must follow the manufacturer’s emission-related operating and 

maintenance (O&M) requirements or must develop their own maintenance plan to follow and 

must also keep records of the hours of operation. It is estimated that one hour per year at $68 per 

hour would be sufficient to record the hours of operation. No costs were included in the impacts 

for following the manufacturer’s emission-related O&M plan, because it is expected that 

owner/operators will follow this plan regardless of the regulation. 

3.3 Area Sources 

All Emergency CI Engines

The costs associated with emergency CI engines include recordkeeping requirements for 

tracking the hours of operation, but these engines are not subject to any performance testing. 

The owners and operators must follow the manufacturer’s emission-related O&M requirements 

or must develop their own maintenance plan to follow. It is estimated that one hour per year at 

$68 per hour would be sufficient to record the hours of operation. Emergency CI engines at 

areas sources will be subject to management practices, rather numerical emission limits. The 

management practices do not require aftertreatment controls. Therefore, no control costs have 

been estimated for these engines. These engines will be subject to management practices which 

are not included in the costs, because it is assumed that these management practices are 

performed regardless of the regulation. 

 

8

 Memorandum from Melanie Taylor and Brad Nelson, AGTI to Sims Roy, EPA OAQPS ESD Combustion Group, 

Lubricity of Ultra Low Sulfur Diesel Fuel, June 2, 2004. 
8

Non-Emergency CI Engines ≤ 300 HP

The costs associated with non-emergency CI engines less than or equal to 300 HP are 

minimal and only include following the manufacturer’s emission-related O&M requirements or 

the owner or operator’s own maintenance plan. These engines are not subject to any numerical 

emission limitations, therefore no control costs apply and no performance testing is required. 

These engines will be subject to management practices which are not included in the costs, 

because it is assumed that these management practices are done regardless of the regulation. 

Non-Emergency CI Engines > 300 HP

The costs associated with non-emergency CI engines above 300 HP include the cost of 

installing and operating an oxidation catalyst for reducing HAP, as well as the cost of installing 

an open crankcase ventilation system. Non-emergency CI engines greater than 500 HP are also 

subject to continuous monitoring requirements. In addition, owners and operators must conduct 

an initial performance test to demonstrate compliance with the emission limitation and engines 

above 500 HP must conduct subsequent performance testing every 8,760 hours or 3 years, 

whichever comes first. The cost estimates for this subcategory of engines do not account for 

possible fuel price increases that may result from using ultra-low sulfur diesel. The cost 

estimates for this subcategory of engines do not account for possible fuel price increases that 

may result from using ultra-low sulfur diesel (ULSD). EPA estimated the cost of lubricity 

additives to ULSD would increase the cost of the fuel by 0.2 cents per gallon, which EPA 

believes is negligible. In addition, there are no additional maintenance requirements for 

owner/operators using ULSD in existing diesel engines. Many owner/operators have found that 

time between oil changes can be extended for engines using ULSD fuel, which would decrease 

the overall cost of switching to ULSD fuel. Therefore, EPA believes that it is appropriate to not 

include any costs for switching to ULSD in the impacts for this NESHAP. 

A summary of the total costs associated with the rule and a breakdown of the costs by NAICS 

codes are presented in Tables 4 through 7. For estimating the number of engines located at 

major and area sources, we used our best engineering judgment, and we recognize that it may 

lead to an overestimate or underestimate of impacts for certain sectors.
9

Table 4. Summary of Major Source and Area Source Costs for the CI RICE NESH

Size 

Range 

(HP) 

Non-Emergency CI 

Initial Test Recordkeeping Reporting 

Monitoring 

- Capital 

Cost 

Monitoring - 

Annual Cost 

Total 

C

Capital 

Control Cost 

Annual 

Control Cost 

Major Sources 

50-100 $0 $0 $0 $6,654,888 $0 $0 $0 $6,6

100-175 $24,057,778 $9,918,465 $14,150,269 $8,719,731 $5,973,016 $0 $0 $38,7175-300 $35,917,270 $10,740,189 $10,730,759 $6,612,548 $4,529,595 $0 $0 $32,6300-500 $107,841,136 $26,722,727 $5,645,923 $3,479,152 $2,383,219 $0 $0 $38,2500-600 $13,126,952 $3,020,849 $500,530 $61,688 $211,280 $481,765 $2,220,755 $6,0600-750 $8,240,540 $1,824,295 $256,204 $31,576 $108,147 $246,599 $1,136,729 $3,3

>750 $26,903,091 $5,618,803 $565,163 $69,653 $238,563 $543,975 $2,507,521 $8,9

Total $216,086,768 $57,845,329 $31,848,848 $25,629,236 $13,443,820 $1,272,338 $5,865,005 $134,

Area Sources

50-100 $0 $0 $0 $9,183,746 $0 $0 $0 $9,1

100-175 $0 $0 $0 $12,033,196 $5,231,824 $0 $0 $17,2175-300 $0 $0 $0 $9,125,316 $3,967,529 $0 $0 $13,0300-600 $272,814,082 $65,640,094 $12,703,298 $7,201,827 $5,362,230 $4,075,682 $18,787,376 $109,600-750 $68,490,125 $15,162,379 $2,129,405 $1,207,215 $898,850 $683,191 $8,952,336 $28,3

>750 $179,573,835 $37,504,615 $3,772,372 $2,138,655 $1,592,368 $1,210,315 $15,859,613 $60,

Total $520,878,041 $118,307,088 $18,605,076 $40,889,956 $17,052,802 $5,969,187 $43,599,324 $238,

Total $736,964,809 $176,152,417 $50,453,924 $66,519,191 $30,496,622 $7,241,526 $49,464,330 $373,

1 Costs are presented in 2008 dollars. 
10

Table 5. Summary of Major Source and Area Source NAICS Costs for the CI RICE N

NAICS Major Source Area Source To

Capital Cost Annual Cost Capital Cost Annual Cost Capita

Electric Power Generation (2211) $161,766,376 $90,982,105 $471,230,478 $203,529,267 $632,99

Hospitals (622110) $20,220,797 $11,372,763 $0 $0 $20,22

Crude Petroleum & NG Production (211111) $2,374,401 $3,807,478 $1,611,601 $2,599,033 $3,986

Natural Gas Liquid Producers (211112) $2,374,401 $3,807,478 $1,611,601 $2,599,033 $3,986

National Security (92811) $20,220,797 $11,372,763 $52,358,942 $22,614,363 $72,57

Hydro Power Units (335312) $0 $16,637 $0 $22,959 $0 

Irrigation Sets (335312) $10,294,073 $11,791,567 $34,606 $5,208,210 $10,32

Welders (333992) $108,260 $1,481,447 $0 $1,881,380 $108

Total $217,359,106 $134,632,238 $526,847,229 $238,454,245 $744,20

1 Costs are presented in 2008 dollars. 
11

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

NAICS Major Source Area Source To

Capital Cost Annual Cost Capital Cost Annual Cost Capita

Electric Power Generation (2211) 50-100 hp $0 $3,396,123 $0 $5,272,480 $0 100-175 hp $13,406,919 $21,600,998 $0 $10,824,132 $13,40175-300 hp $23,012,914 $20,895,861 $0 $9,437,454 $23,01300-600 hp $96,907,266 $35,304,866 $248,552,865 $98,468,656 $345,46600-750 hp $6,789,032 $2,685,292 $62,249,758 $25,512,616 $69,03>750 hp $21,650,245 $7,098,966 $160,427,854 $54,013,930 $182,07Total Electric Power Generation 2211 $161,766,376 $90,982,105 $471,230,478 $203,529,267 $632,99Hospitals (622110) 50-100 hp $0 $424,515 $0 $0 $0 100-175 hp $1,675,865 $2,700,125 $0 $0 $1,675175-300 hp $2,876,614 $2,611,983 $0 $0 $2,876300-600 hp $12,113,408 $4,413,108 $0 $0 $12,11600-750 hp $848,629 $335,662 $0 $0 $848>750 hp $2,706,281 $887,371 $0 $0 $2,706Total Hospitals (622110) $20,220,797 $11,372,763 $0 $0 $20,22Crude Petroleum & NG Production (211111) 50-100 hp $0 $420,256 $0 $579,954 $0 100-175 hp $2,026,868 $3,265,655 $0 $1,454,578 $2,026175-300 hp $3,592 $3,261 $0 $1,309 $3,5300-600 hp $151,812 $55,308 $346,112 $137,119 $497600-750 hp $0 $0 $0 0 $0 >750 hp $192,129 $62,998 $1,265,489 $426,073 $1,457Total Crude Petroleum & NG Production (211111) $2,374,401 $3,807,478 $1,611,601 $2,599,033 $3,986Natural Gas Liquid Producers (211112) 50-100 hp $0 $420,256 $0 $579,954 $0 100-175 hp $2,026,868 $3,265,655 $0 $1,454,578 $2,026175-300 hp $3,592 $3,261 $0 $1,309 $3,5
12

NAICS Major Source Area Source To

Capital Cost Annual Cost Capital Cost Annual Cost Capita

300-600 hp $151,812 $55,308 $346,112 $137,119 $497600-750 hp 0 0 0 0 $0 >750 hp $192,129 $62,998 $1,265,489 $426,073 $1,457Total Natural Gas Liquid Producers (211112) $2,374,401 $3,807,478 $1,611,601 $2,599,033 $3,986National Security (92811) 50-100 hp $0 $424,515 $0 $585,831 $0 100-175 hp $1,675,865 $2,700,125 $0 $1,202,681 $1,675175-300 hp $2,876,614 $2,611,983 $0 $1,048,606 $2,876300-600 hp $12,113,408 $4,413,108 $27,616,985 $10,940,962 $39,73600-750 hp $848,629 $335,662 $6,916,640 $2,834,735 $7,765>750 hp $2,706,281 $887,371 $17,825,317 $6,001,548 $20,53Total National Security (92811) $20,220,797 $11,372,763 $52,358,942 $22,614,363 $72,57Hydro Power Units (335312) 50-100 hp $0 $16,637 $0 $22,959 $0 100-175 hp $0 $0 $0 $0 $0 175-300 hp $0 $0 $0 $0 $0 300-600 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) $0 $16,637 $0 $22,959 $0 Irrigation Sets (335312) 50-100 hp $0 $245,565 $0 $338,880 $0 100-175 hp $3,137,134 $5,054,497 $0 $2,251,359 $3,137175-300 hp $7,143,945 $6,486,744 $0 $2,604,167 $7,143300-600 hp $12,145 $4,425 $27,689 $10,969 $39,600-750 hp $849 $336 $6,917 $2,835 $7,7>750 hp $0 $0 $0 $0 $0 Total Irrigation Sets (335312) $10,294,073 $11,791,567 $34,606 $5,208,210 $10,32Welders (333992) 50-100 hp $0 $1,307,020 $0 $1,803,688 $0 
13

NAICS Major Source Area Source To

Capital Cost Annual Cost Capital Cost Annual Cost Capita

100-175 hp $108,260 $174,427 $0 $77,693 $108175-300 hp $0 $0 $0 $0 $0 300-600 hp $0 $0 $0 $0 $0 600-750 hp $0 $0 $0 $0 $0 >750 hp $0 $0 $0 $0 $0 Total Welders (333992) $108,260 $1,481,447 $0 $1,881,380 $108

Total $217,359,106 $134,632,238 $526,847,229 $238,454,245 $744,20

1 Costs are presented in 2008 dollars. 
14

Table 7. Summary of Major Source and Area Source NAICS Costs for the CI RICE NESHAP – by Nu

NAICS Number of Engines Total (Major + Are

Major Area Total Capital Cost Annua

Electric Power Generation (2211) 50-100 hp 47,324 79,859 127,183 $0 $8,668100-175 hp 67,713 114,266 181,980 $13,406,919 $32,42175-300 hp 59,039 99,627 158,666 $23,012,914 $30,33300-600 hp 42,113 97,919 140,032 $345,460,132 $133,77600-750 hp 1,760 16,455 18,215 $69,038,790 $28,19>750 hp 3,828 28,746 32,574 $182,078,100 $61,11Total Electric Power Generation 2211 221,777 436,872 658,649 $632,996,854 $294,51Hospitals (622110) 50-100 hp 5,916 0 5,916 $0 $424100-175 hp 8,464 0 8,464 $1,675,865 $2,700175-300 hp 7,380 0 7,380 $2,876,614 $2,611300-600 hp 5,264 0 5,264 $12,113,408 $4,413600-750 hp 220 0 220 $848,629 $335>750 hp 479 0 479 $2,706,281 $887Total Hospitals (622110) 27,722 0 27,722 $20,220,797 $11,37Crude Petroleum & NG Production (211111) 50-100 hp 5,856 8,784 14,640 $0 $1,000100-175 hp 10,237 15,355 25,592 $2,026,868 $4,720175-300 hp 9 14 23 $3,592 $4,5300-600 hp 66 136 202 $497,925 $192600-750 hp 0 0 0 $0 $0 >750 hp 34 227 261 $1,457,619 $489Total Crude Petroleum & NG Production (211111) 16,202 24,517 40,719 $3,986,003 $6,406Natural Gas Liquid Producers (211112) 50-100 hp 5,856 8,784 14,640 $0 $1,000100-175 hp 10,237 15,355 25,592 $2,026,868 $4,720
15

NAICS Number of Engines Total (Major + Are

Major Area Total Capital Cost Annua

175-300 hp 9 14 23 $3,592 $4,5300-600 hp 66 136 202 $497,925 $192600-750 hp 0 0 0 $0 $0 >750 hp 34 227 261 $1,457,619 $489Total Natural Gas Liquid Producers (211112) 16,202 24,517 40,719 $3,986,003 $6,406National Security (92811) 50-100 hp 5,916 8,873 14,789 $0 $1,010100-175 hp 8,464 12,696 21,160 $1,675,865 $3,902175-300 hp 7,380 11,070 18,450 $2,876,614 $3,660300-600 hp 5,264 10,880 16,144 $39,730,393 $15,35600-750 hp 220 1,828 2,048 $7,765,269 $3,170>750 hp 479 3,194 3,672 $20,531,598 $6,888Total National Security (92811) 27,722 48,541 76,263 $72,579,739 $33,98Hydro Power Units (335312) 50-100 hp 232 348 580 $0 $39,5100-175 hp 0 0 0 $0 $0 175-300 hp 0 0 0 $0 $0 300-600 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) 232 348 580 $0 $39,5Irrigation Sets (335312) 50-100 hp 3,422 5,133 8,555 $0 $584100-175 hp 15,845 23,767 39,611 $3,137,134 $7,305175-300 hp 18,327 27,491 45,819 $7,143,945 $9,090300-600 hp 5 11 16 $39,834 $15,3600-750 hp 0 2 2 $7,766 $3,1>750 hp 0 0 0 $0 $0 Total Irrigation Sets (335312) 37,599 56,403 94,003 $10,328,679 $16,99Welders (333992) 
16

NAICS Number of Engines Total (Major + Are

Major Area Total Capital Cost Annua

50-100 hp 18,213 27,319 45,532 $0 $3,110100-175 hp 547 820 1,367 $108,260 $252175-300 hp 0 0 0 $0 $0 300-600 hp 0 0 0 $0 $0 600-750 hp 0 0 0 $0 $0 >750 hp 0 0 0 $0 $0 Total Welders (333992) 18,760 28,140 46,899 $108,260 $3,362

Total 366,217 619,337 957,832 $744,206,335 $373,08

1 Costs are presented in 2008 dollars. 
17 

4.0 EMISSION IMPACTS 

The emissions reductions associated with the final rule are based on requiring emission 

standards that are based on applying add-on controls to non-emergency CI engines greater than 

300 HP. Baseline emissions from the current population of stationary RICE less than or equal to 

500 HP at major sources and existing stationary RICE at area sources were calculated based on 

non-emergency CI engines operating 1,000 hrs/yr, and emergency CI engines operating 50 

hrs/yr. The following additional assumptions were used: 

Emission Factors: 

Engine HAP 

(lb/hp-hr) 

CO 

(lb/hr) 

PM 

(lb/hp-hr) 

CI 1.07x10-4 6.96x10-1 7.00x10-4

*Obtained from AP-42, section 3.4 where S1 is sulfur content. 

 

Control Efficiencies: 

Technology HAP CO PM 

Oxidation catalyst 70% 70% 30% 

Based on the above assumptions and the existing population of engines shown in Tables 1 

through 3 of this memorandum, the HAP, CO, and PM baseline emissions and reductions were 

calculated. In addition to the final rule reducing HAP, CO, and PM, the rule will also lead to 

reductions in sulfur dioxide (SO2) emissions by requiring existing non-emergency CI engines 

greater than 300 HP that use diesel fuel to use diesel fuel containing no more than 15 parts per 

million (ppm) of sulfur. However, EPA has not quantified the SO2 emission reductions that 

would occur as a result of these engines switching to ULSD. Although EPA is confident that 

some SO2 reductions would occur as a result of this rule, EPA is unable to estimate the 

percentage of engines that may switch to ULSD in the absence of this rule. As a PM2.5

precursor, these SO2 emission reductions would lead to fewer PM2.5-related health effects. 

Because of uncertainty in the magnitude of the attributable SO2 reductions and to avoid the 

appearance of double-counting, EPA has chosen to not include SO2 reduction estimates in Table 

8 of this memorandum. In addition, it is expected that additional PM reductions will be achieved 

by the requirement to use ULSD for CI engines that install a DOC. The use of ULSD reduces 

the formation of sulfates in the exhaust gas, therefore reducing the emission of these sulfate PM 

emissions from the exhaust. EPA has estimated that the use of ULSD can reduce PM emissions 

by 5-30 percent depending on the sulfur concentration of the diesel fuel that is being replaced. 

Because EPA has no information on the type of fuel that CI engines are currently using, the PM 

reductions from switching to ULSD were not quantified and included in this summary. 

 The work practice requirement of using an open crankcase ventilation system to control 

metallic HAP emissions is expected to achieve additional HAP reductions from CI engines. 

However, the metallic HAP emission reduction cannot be quantified because of the difficulty of 

measuring metallic HAP from the crankcase exhaust. Therefore, the metallic HAP reductions 

are not included in the total emission reductions. 
18 

Table 8. Summary of Major Source and Area Source Emissions Reductions for the 

CI RICE NESHAP 

Size Range 

(HP) 

Emission Reductions (TPY) 

HAP CO PM VOC 

Major Sources 

50-100 0 0 0 0 

100-175 44 2,072 123 1,183 

175-300 57 1,571 161 1,549 

300-500 145 2,362 407 3,923 

500-600 18 209 50 478 

600-750 11 107 31 300 

>750 36 236 102 982 

Total 312 6,558 874 8,416 

Area Sources 

50-100 0 0 0 0 

100-175 0 0 0 0 

175-300 0 0 0 0 

300-600 368 5,314 1,031 9,930 

600-750 92 891 259 2,497 

>750 243 1,578 680 6,553 

Total 703 7,784 1,970 18,980 

Grand Total 1,014 14,342 2,844 27,395