### 1 MEMORANDUM DATE: February 19, 2004 SUBJECT: National Impacts Associated with the Final NESHAP for RICE FROM: Tanya Ali and Melanie Taylor, Alpha-Gamma Technologies, Inc. TO: Sims Roy, EPA OAQPS ESD Combustion Group

The purpose of this memorandum is to estimate the national impacts associated with the final national emission standards for hazardous air pollutants (NESHAP) for stationary reciprocating internal combusti on engines (RICE). The regulation applies to stationary RICE located at major sources of hazardous air pollutants (HAP) emissions. It is estimated that 40 percent of stationary RICE w ill be located at major sources. Impacts discussed in this memorandum include HAP emissions reductions and total costs associated with regulatory requirements. For existing stationary RICE, implementation of the final NESHAP is estimated to reduce nationwide HAP emissions by 284 tons per year at a total annual cost of $35 million. For new engines, the final regulation is projected to prevent national HAP emissions by 5,300 tons per year in the fifth year at a total annual cost of $213 m illion per year in the fifth year. The total nat ional HAP emissions reductions are the sum of formaldehyde, acetaldehyde, acrolein , and methanol emissions reductions. A previous version of this memorandum based on the requirements for the proposed NESHAP was developed at the time of proposal and entered into the docket (Document ID Number OAR-2002-0059-0071 or A-95-35 II-B- 48). The primary reasons for the difference in the estimated impacts of the final rule as compared to the proposed rule are the change in the monitoring requirements for large RICE and the updated HAP emission factors. The emissions reducti ons and costs for the final rule are not substantially different than those for the proposed rule. The regulatory requirements of the final rule are presented in Table 1 for the following four RICE subcategories: Two-Stroke Lean Burn (2SLB) Stationary RICE Four-Stroke Lean Burn (4SLB) Stationary RICE Four-Stroke Rich Burn (4SRB) Stationary RICE

### 2 Compression Ignition (CI) Stationary RICE. Table 1. Summary of Regulatory Requirements for RICE Subcategories Subcategory Regulatory Requirement a



### Existing 4SRB Stationary RICE 76 percent CH 2 

### O efficiency or emission limitation of 350 ppbvd CH 2 

### O 2SLB, 4SLB, and CI Stationary RICE No emissions reduction

New 2SLB Stationary RICE 58 percent CO efficiency or emission limitation of 12 ppmvd CH 2 

### O 4SLB Stationary RICE 93 percent CO efficiency or emission limitation of 14 ppmvd CH 2 

### O 4SRB Stationary RICE 76 percent CH 2 

### O efficiency or emission limitation of 350 ppbvd CH 2 

### O CI Stationary RICE 70 percent CO efficiency or emission limitation of 580 ppbvd CH 2 

### O

a All concentrations must be corrected to 15 percent oxygen, dry basis. 

### The nationwide air quality impacts for RICE reaching compliance were estimated relative to baseline emissions reflecting the emission levels in the absence of any regulation. Cost impacts are based on the application of the emission controls necessary to bring the engines into compliance with the final regulation. For engines where no emissions reduction is required, no impacts were estimated.
Emissions Reductions The final stationary RICE NESHAP w ill r educe HAP emissions by an estimated 5,600 tons per year in the fifth year after the rule is promulgated. Emissions of CO, NOx, and PM will also be r educed by the NESHAP. The calculation of the emissions reductions of HAP and criteria pollutants associated with the final RICE NESHAP is discussed in the following sections.
HAP Reduction For the purpose of estimating emissions r eductions, baseline HAP emissions (tons per year) are calculated using average emission factors from the Emissions Database. These emission factors are presented in the memorandum entitled “Revised Emission Factors for Stationary Reciprocating Inter nal Combustion Engines.” The sum of the

### 3 HAP Emission Factor ( tons yr ) EF HAP 

### ( lb hr )  6,500 ( hrs yr ) 2,000 ( lb ton )

Baseline HAP

Emissions ( tons yr ) [EF HAP 

### ( tons yr ) 

###  Y 

###  1,829] 

### [EF HAP 

### ( tons yr ) 

###  Z 

###  (100



###  η ) 100 

###  1,829] 

### average emission factors for formaldehy de, acetaldehyde, acrolein, and methanol represents the total HAP emission factor. A sample calculation of baseline HAP emissions for existing 4SRB stationary RICE is provided below:

where: -EF HAP 

### is the uncontrolled emission factor for HAP in tons/yr. -6,500 is the average number of operating hours per year for engines in the Population Database. -Y is the fraction of uncontrolled 4SRB stationary RICE. -Z is the fraction of controlled 4SRB stationary RICE.

- η is the percent reduction for fo rmaldehyde achieved by the catalyst system. For 4SRB stationary RICE, η =76. -1,829 is the number of existing 4SRB stationary RICE. The population of existing RICE and the forecasted population of new RICE for the next five years is presented in Table 2. T able 3 is a summary of the HAP emissions reductions associated with the regulatory requirements for the RICE subcategories. The following information is included in Table 3: Baseline HAP emissions (tons/year) which represent the current emission level for this subcategory in the absence of MACT regulation, HAP emissions with MACT (tons/year) resulting after applying the regulatory requirement, HAP emissions reductions (tons/yea r) achieved with each regulatory requirement, and HAP percent reduction corresponding to each regulatory requirement.

### 4 Table 2. Population of RICE a
Engine Subcategory HP Range b Existing Population of Engines Forecasted P opulation of New RICE Total increase of RICE over 5 years Annual incr ease RICE per year

2SLB Stationary RICE 500-1,000 565 200 40 1,000-5,000 1,090 None None 5,000-10,000 122 None None Total 1,777 200 40

4SLB Stationary RICE c 500-1,000 346 850 170 1,000-5,000 1,238 1,365 273 5,000-10,000 75 5 1 Total 1,660 2,219 444

4SRB Stationary

RICE d 500-1,000 1,341 743 149 1,000-5,000 486 967 193 5,000-10,000 2 3 1 Total 1,829 1,713 343

CI Stationary RICE 500-1,000 2,125 2,395 479 1,000-5,000 1,416 1,596 319 5,000-10,000 None None None Total 3,541 3,991 798

a The presented population excludes stationary RICE that are used as emergency power units and stationary RICE located at area sources. b There are no existing stationary RICE greater than 10,000 HP and it is predicted that no stationary RICE greater than 10,000 HP w ill be sold during the next five years.
c 3 percent of existing 4SLB stationary RICE are controlled with a CO oxidation catalyst and it is predicted that 3 percent of new 4SLB stationary RICE w ill be controlled with a CO oxidation catalyst in the absence of this regulation. d 27 percent of existing 4SRB stationary RICE are controlled with NSCR and it is predicted that 27 percent of new 4SRB stationary RICE w ill be controlled with NSCR in the absence of this regulation.

### 5 Table 3. Summary of HAP Emissions Reductions for RICE

Engine Subcategory Baseline HAP Emissions (tons/yr) a,b,c HAP Emissions w/MACT (tons/yr) HAP Emissions Reduction

(tons/yr) HAP Percent Reduction (%) from Baseline d Existing: 2SLB Stationary RICE 5,762 5,762 0 0.0 4SLB Stationary RICE 5,206 5,206 0 0.0 4SRB Stationary RICE 407 123 284 69.8 CI Stationary RICE 465 465 0 0.0 Total 11,840 11,556 284 2.4 New: 2SLB Stationary RICE 130 78 52 40.0 4SLB Stationary RICE 1,392 497 895 64.3 4SRB Stationary RICE 76 23 53 69.8 CI Stationary RICE 105 37 68 65.0 Total 1,703 634 1,068 62.7

a Baseline HAP emissions from new 4SLB stationary RICE are based on the assumption that 3 percent of new 4SLB stationary RICE would be using an oxidation catalyst achieving 65 percent formaldehyde efficiency in the absence of the MACT regulation. b Baseline HAP emissions from 4SRB existing and new stationary RICE are based on the assumption that 27 percent of these stationary RICE are using NSCR achieving 76 percent formaldehyde efficiency in the absence of the MACT regulation. A sample calculation of baseline emissions for 4SRB existing stationary RICE is provided in the next footnote.
c Baseline HAP Emissions = EF HAP (tons/yr) x [(0.73 x 1,829 existing 4SRB engines) + (0.23 x 0.24 x 1,829 existing 4SRB engines)] d The impact of MACT is on 97 percent of the 4SLB stationary RICE and 73 percent of the 4SRB stationary RICE. 

### The MACT for existing engines is estimat ed to reduce HAP emissions by 284 tons/year from a baseline level of 11,840 tons/year. The emissions reductions for existing engines is a result of contro lling 4SRB stationary RICE. This represents a 2 percent emissions reduction from the baseline emission level from all existing engines. This regulation w ill have a greater impact on new engines. The MACT floor is estimated to reduce HAP emissions from all new engines by 1,068 tons/year in the first year from a baseline level of 1,703 tons/year. This represents a 63 percent HAP emissions reduction from the baseline level. The baseline level for new engines is the emission level one would expect to see in the absence of any regulation. The largest reduction in HAP emissions from new engines is a result of contro lling 4SLB stationary RICE, which have an emissions reduction of 895 tons /year in the first year, representing 84

### 6 percent of the total HAP emissions reductions from new engines.
Criteria Pollutant Reduction A benefit of this regulation is that it is expected to reduce criteria emissions in addition to HAP emissions. A summary of the total reduction in criteria pollutants as a result of the MACT rule is given in Table 4. Oxidation catalysts (used on either lean burn or rich burn engines) and NSCR (used on rich burn engines) are capable of reducing CO by as much as 95 percent at ideal conditions. The regulation is projected to reduce CO emissions by 234,400 tons per year at the end of the fifth year following promulgation. Oxidation catalysts used on CI stationary RICE are also capable of reducing total particulate emissions by 25 to 50 percent. The total estimated PM emissions reduction in the fifth year is estimated to be 3,700 tons per year. The application of NSCR controls to 4SRB engines w ill also r educe NO x emissions by 90 percent. Assuming that 60 percent of 4SRB (new and existing) engines that are covered by the emission standards w ill use NSCR, the cumulative emissions r eductions of NO x by the end of the fifth year after promulgation are calculated to be about 167,900 tons per year.
Control Costs It has been determined by EPA that oxidation catalysts, such as CO oxidation catalyst and NSCR, are applicable controls for the reduction of HAP from stationary RICE. The costs associated with these add-on control devices were gathered by EPA and are summarized in the memorandum entitled “Control Costs for Reciprocating Internal Combustion Engines.” In order to estima te national impacts associated with contro lling RICE emissions, control cost estimates for engines were extrapolated to the actual population of engines in the United States, and national impacts were then determined. Cost impacts include the total capital investment of new control equipment, the cost of energy (ut ilities) r equired to operate the control equipment, operation and maintenance costs, and the cost of monitoring. Table 5 lists the capital control costs and annual control costs associated with each model engine in dollars per horsepower. Control costs per engine are then extrapolated to the existing population and forecasted number of new engines to obtain total control costs for the entire existing population and for the predicted number of new RICE. Total control costs and total annual control costs for existing RICE are presented in Table 6 and for new stationary RICE in Table 7. Costs of monitoring are presented in Table 8 for each of the engi ne subcategories. For 4SRB engines, the monitoring costs are different for different size engines due to larger engines having different monitoring requirements. The monitoring costs for 2SLB, 4SLB, and CI RICE are the same for all size engines.

### 7 Table 4. Summary of Criteria Pollutant Emissions Reductions in the First Year
Engine Subcategory Pollutant Percent Reduction (%) Total Emission Reduction a

(tons/yr) Existing 4SRB Stationary RICE CO 90 98,040 NOx 90 69,862 New 2SLB Stationary RICE CO 58 391 New 4SLB Stationary RICE CO 93 7,248 New 4SRB Stationary RICE CO 90 18,364 NOx 90 98,023 New CI Stationary RICE CO 70 1,264 PM 25 3,746

a Total emissions reduction is based on the population of RICE obtained from Table 2. The reduction in this table is the reduction in the first year. 

### Cost Impacts A summary of total baseline HAP emissions, total HAP emissions reductions, total capital investment and total annual costs for all existing and new RICE in the first year is presented in Table 9. The total national capital cost for this rule for existing stationary RICE is estimated to be approximately $68 m illion, with a total nati onal annual cost of $35 m illion. The total nati onal capital cost for this rule for new stationary RICE by the 5th year is estimated to be approximately $371 m illion, with a total nati onal annual cost of $213 m illion in the 5th year. Energy Impacts Energy impacts associated with this regulation would be due to additional energy consumption that the regulation would require by insta lling and operating control equipment. The only energy requirement for the operation of the control technologies is due to a small increase in fuel consumption resulting from back pressure caused by the control system. This energy impact is however considered minimal in comparison to cost of other impacts, and is therefore considered negligible.

### 8 Table 5. Control Costs Associated with Model Engines
Model Engines HP Rating Capital Control Cost per

model engine ($) Annual Control Cost per

model engine

($/yr) Capital Control Cost per

model engine ($ per HP) Annual Control Cost per model

engine ($ per HP/yr) Cost of Engine ($) a

Clark RA6 600 13,299 7,339 22 12 115,626 b Cooper Bessemer GMV10 1100 27,072 13,851 25 13 173,755 b Cooper Bessemer GMV10TC 1350 30,777 16,527 23 12 365,359 b
Cooper Bessemer 10V250 3800 72,003 43,646 19 11 1,377,059 c Worthington ML20 7500 121,112 82,202 16 11 2,904,933 b 2SLB Average: 21 12 Caterpillar 3512 1000 14,344 10,730 14 11 192,710 d Caterpillar 3512 1220 21,325 13,763 17 11 192,710 d Waukesha 7042 GL 1478 28,497 17,135 19 12 400,000 Cooper Bessemer LSV16G 5200 84,352 57,098 16 11 2,014,087 e 4SLB Average: 17 11 Waukesha F3521 GSI 738 27,833 11,094 38 15 246,454 e Waukesha 7042 G 1024 32,012 14,144 31 14 300,000 f Waukesha L7042 GSI 1478 40,690 19,532 28 13 385,000 4SRB Average: 32 14 Detroit 16V71 510 12,102 6,401 24 13 76,500 g Caterpillar D399 750 11,399 8,193 15 11 112,500 h Detroit 12V92 818 13,964 9,205 17 11 122,700 g Cummins KTA50 1850 31,775 20,709 17 11 500,677 b Detroit 16V149 1965 22,399 19,919 11 10 531,800 b CI Average: 17 11

a Costs of engines are suggested retail costs, representing the costs for a standard engine not including any additional options an engine might require, and are therefore to be considered minimum. Also note that installation will add a significant amount to the capital cost depending on the use and size of the engine. b Cost estimated based on $/HP for 4SLB engines for each HP rating segment.
c Cost estimated by interpolation. d Cost estimate based on the cost of 4SLB engine 3512 G, with a horsepower rating of 800.
e Cost estimated by extrapolation. f Cost estimate based on the cost of 4SRB engine L7042 GU, with a horsepower rating of 901. g Cost estimated based on $/HP for CI engines for each HP rating segment. h Cost estimate is the average of the cost of CI engines RICE 3516 (1200 HP) and 3306 (375 HP).

### 9 Table 6. Total Control Costs Associated with Existing RICE
Engine Subcategory a HP Range b Total # Engines Average HP Control Cost per engine c ($/engine) Annual Control Cost per engine c ($/yr) Total Control Cost d ($1,000) Total Annual Control Cost d

($1,000/yr)

4SRB Stationary RICE 500-1,000 1,341 750 24,000 10,500 23,498 10,280 1,000-5,000 486 3,000 96,000 42,000 34,067 14,905 5,000-10,000 2 7,500 240,000 105,000 340 149 Total 57,906 25,334

a Existing 2SLB, 4SLB, and CI engines have no emissions reduction requirement and therefore no control cost associated with the regulation. b There are no existing stationary RICE greater than 10,000 HP, and the presented population excludes emergency power units, engines 500 HP or less, and engines at area sources.
c Control costs are calculated using the average HP for the HP range in question, multiplied times the average control cost in $ per HP, obtained from Table 5. d Total control cost and total annual control cost were not included for 27 percent of the existing 4SRB stationary RICE, since these engines would be controlled in the absence of the regulation.

### 10 Table 7. Total Control Costs Associated with New RICE
Engine Subcategory HP Range a Engine increase per year Average HP Control Cost per engine b

($/engine) Annual Control Cost per engine b ($/yr) Total Control

Cost ($1,000) Total Annual Control Cost

($1,000/yr)

2SLB Stationary RICE 500-1,000 40 750 15,750 9,000 630 360

4SLB Stationary RICE 500-1,000 170 750 12,750 8,250 2,101 1,360 1,000-5,000 273 3000 51,000 33,000 13,503 8,737 5,000-10,000 1 7,500 127,500 82,500 119 77 Total 15,724 10,174

4SRB Stationary RICE 500-1,000 149 750 24,000 10,500 2,604 1,139 1,000-5,000 193 3,000 96,000 42,000 13,551 5,928 5,000-10,000 1 7,500 240,000 105,000 112 49 Total 16,267 7,117
CI Stationary RICE 500-1,000 479 750 12,750 8,250 6,107 3,951 1,000-5,000 319 3,000 51,000 33,000 16,284 10,537 5,000-10,000 0 7,500 127,500 82,500 0 0 Total 22,391 14,448

a No stationary RICE greater than 10,000 HP are expected to be sold during the next five years. b Control costs are calculated using the average HP for the HP range in question, multiplied times the average control cost in $ per HP, obtained from Table 5.

### 11 Table 8. Costs of Monitoring for RICE Subcategories
Engine Subcategory HP Range Monitoring Capital Cost

($/engine) Monitoring Annual Cost

($/engine) Total Monitoring Capital Cost ($1,000) Total Monitoring Annual Cost ($1,000) Existing 4SRB 500-5,000 5,699 4,487 10,414 8,199 5,000-10,000 5,699 13,383 11 26 4SRB Total 10,425 8,225 New 2SLB all 13,479 5,959 539 238 New 4SLB all 13,479 5,959 5,983 2,645 New 4SRB 500-5,000 5,699 4,487 1,949 1,535 5,000-10,000 5,699 13,383 4 9 4SRB Total 1,953 1,544 New CI all 13,479 5,959 10,760 4,75712Table 9. Summary of HAP Emissions Reductionsand Cost Impacts Associated with the RegulationEngineSubcategoryExisting Engines New EnginesBaselineEmissions(ton/yr)HAPEmissionsReduction(ton/yr)TotalCapitalInvestment($1,000)aTotalAnnualCost($1,000)aBaselineEmissions(ton/yr)HAPEmissionsReduction(ton/yr)TotalCapitalInvestment($1,000)aTotalAnnualCost($1,000)a2SLBStationaryRICE5,762 0 0 0 130 52 1,169 6294SLBStationaryRICE5,206 0 0 0 1,392 895 21,706 13,1454SRBStationaryRICE407 284 68,331 34,566 76 53 18,220 8,911CIStationaryRICE465 0 0 0 105 68 33,150 19,847Total: 11,840 284 68,331 34,566 1,703 1,068 74,245 42,532aTotal capital investment and total annual costs include the cost of control, monitoring, testing, recordkeeping, and reporting.bIn this table, the air and cost impact estimates for new engines are presented for the first year.

### 13 References: 1. Memorandum from Taylor, M., Alpha-Gamma Technologies, Inc., to Sims Roy, EPA OAQPS ESD Combustion Gr oup. January 20, 2004. Revised Emission Factors for Stationary Reciprocating Internal Combustion Engines. 2. Memorandum from Snyder, J. and M. Taylor, Alpha-Gamma Technologies, Inc., to Sims Roy, EPA OAQPS ESD Combustion Gr oup. January 7, 2002. Control Costs for Reciprocating Internal Combustion Engines. 3. Memorandum from Snyder, J., Alpha-Gamma Technologies, Inc., to Sims Roy, EPA OAQPS ESD Combustion Gr oup. November 28, 2001. Population of Stationary Reciprocating Internal Combustion Engines: Summary. 4. Catalyst Manual, Installation, Operation, and Troubleshooting. Published by Miratech Corporation, Tulsa, Oklahoma, October 1998. 5. The Impact of Sulfur in Diesel Fuel on Catalyst Emission Control Technology. Manufacturers of Emission Control Association, Washington, DC, March 15, 1999. 6. Personal Communication from Snyder, J., Alpha-Gamma Technologies, Inc. to Heater, B., Cooper Energy Services. January 31, 2000. 7. Facsimile transmission from Wheless, E., County Sanitation District of Los Angeles County, to Snyder, J., Alpha-Gamma Technologies, Inc. December 13, 1999. Draft of Landf ill Gas Utilization Survey of United States Projects. 8. Personal Communication from Snyder, J., Alpha-Gamma Technologies, Inc. to Tripp, J., Gregory Poole E quipment. February 2, 2000. 9. Association of Metropolitan Sewerage Agencies (AMSA) Population Database. Sent by Torres, E., AMSA to Porter, F., U.S. Environmental Protection Agency. September 30, 1997.