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
combustion
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
will
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
million
per
year
in
the
fifth
year.
The
total
national
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
reductions
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
Requirementa
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
will
reduce
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
reduced
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
reductions,
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
Internal
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

 )
100

1,829]
average
emission
factors
for
formaldehyde,
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.
­
 
is
the
percent
reduction
for
formaldehyde
achieved
by
the
catalyst
system.
For
4SRB
stationary
RICE,
 =
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.
Table
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/
year)
achieved
with
each
regulatory
requirement,
and

HAP
percent
reduction
corresponding
to
each
regulatory
requirement.
4
Table
2.
Population
of
RICEa
Engine
Subcategory
HP
Rangeb
Existing
Population
of
Engines
Forecasted
Population
of
New
RICE
Total
increase
of
RICE
over
5
years
Annual
increase
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
RICEc
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
RICEd
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
will
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
will
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
will
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
Baselined
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
estimated
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
controlling
4SRB
stationary
RICE.
This
represents
a
2
percent
emissions
reduction
from
the
baseline
emission
level
from
all
existing
engines.
This
regulation
will
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
controlling
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
will
also
reduce
NOx
emissions
by
90
percent.
Assuming
that
60
percent
of
4SRB
(
new
and
existing)
engines
that
are
covered
by
the
emission
standards
will
use
NSCR,
the
cumulative
emissions
reductions
of
NOx
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
estimate
national
impacts
associated
with
controlling
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
(
utilities)
required
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
engine
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
Reductiona
(
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
million,
with
a
total
national
annual
cost
of
$
35
million.
The
total
national
capital
cost
for
this
rule
for
new
stationary
RICE
by
the
5th
year
is
estimated
to
be
approximately
$
371
million,
with
a
total
national
annual
cost
of
$
213
million
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
installing
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
115,626b
Cooper
Bessemer
GMV10
1100
27,072
13,851
25
13
173,755b
Cooper
Bessemer
GMV10TC
1350
30,777
16,527
23
12
365,359b
Cooper
Bessemer
10V250
3800
72,003
43,646
19
11
1,377,059c
Worthington
ML20
7500
121,112
82,202
16
11
2,904,933b
2SLB
Average:
21
12
Caterpillar
3512
1000
14,344
10,730
14
11
192,710d
Caterpillar
3512
1220
21,325
13,763
17
11
192,710d
Waukesha
7042
GL
1478
28,497
17,135
19
12
400,000
Cooper
Bessemer
LSV16G
5200
84,352
57,098
16
11
2,014,087e
4SLB
Average:
17
11
Waukesha
F3521
GSI
738
27,833
11,094
38
15
246,454e
Waukesha
7042
G
1024
32,012
14,144
31
14
300,000f
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
76,500g
Caterpillar
D399
750
11,399
8,193
15
11
112,500h
Detroit
12V92
818
13,964
9,205
17
11
122,700g
Cummins
KTA50
1850
31,775
20,709
17
11
500,677b
Detroit
16V149
1965
22,399
19,919
11
10
531,800b
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
$/
HP
for
CI
engines
for
each
HP
rating
segment.
h
Cost
estimate
is
the
average
of
the
cost
of
CI
engines
RICE
3516
(
1200
HP)
and
3306
(
375
HP).
9
Table
6.
Total
Control
Costs
Associated
with
Existing
RICE
Engine
Subcategorya
HP
Rangeb
Total
#
Engines
Average
HP
Control
Cost
per
enginec
($/
engine)
Annual
Control
Cost
per
enginec
($/
yr)
Total
Control
Costd
($
1,000)
Total
Annual
Control
Costd
($
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
Rangea
Engine
increase
per
year
Average
HP
Control
Cost
per
engineb
($/
engine)
Annual
Control
Cost
per
engineb
($/
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
4,757
12
Table
9.
Summary
of
HAP
Emissions
Reductions
and
Cost
Impacts
Associated
with
the
Regulation
Engine
Subcategory
Existing
Engines
New
Engines
Baseline
Emissions
(
ton/
yr)
HAP
Emissions
Reduction
(
ton/
yr)
Total
Capital
Investment
($
1,000)
a
Total
Annual
Cost
($
1,000)
a
Baseline
Emissions
(
ton/
yr)
HAP
Emissions
Reduction
(
ton/
yr)
Total
Capital
Investment
($
1,000)
a
Total
Annual
Cost
($
1,000)
a
2SLB
Stationary
RICE
5,762
0
0
0
130
52
1,169
629
4SLB
Stationary
RICE
5,206
0
0
0
1,392
895
21,706
13,145
4SRB
Stationary
RICE
407
284
68,331
34,566
76
53
18,220
8,911
CI
Stationary
RICE
465
0
0
0
105
68
33,150
19,847
Total:
11,840
284
68,331
34,566
1,703
1,068
74,245
42,532
a
Total
capital
investment
and
total
annual
costs
include
the
cost
of
control,
monitoring,
testing,
recordkeeping,
and
reporting.

b
In
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
Group.
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
Group.
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
Group.
November
28,
2001.
Population
of
Stationary
Reciprocating
Internal
Combustion
Engines:
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Catalyst
Manual,
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Operation,
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Published
by
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Tulsa,
Oklahoma,
October
1998.

5.
The
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in
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on
Catalyst
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Manufacturers
of
Emission
Control
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Washington,
DC,
March
15,
1999.

6.
Personal
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from
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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
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Personal
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from
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J.,
Alpha­
Gamma
Technologies,
Inc.
to
Tripp,
J.,
Gregory
Poole
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February
2,
2000.

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Association
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(
AMSA)
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by
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