1
MEMORANDUM
DATE:
September
20,
2004
SUBJECT:
Summary
of
State
NO
X
Requirements
for
Stationary
Engines
FROM:
Bradley
Nelson
Alpha­
Gamma
Technologies,
Inc.

TO:
Sims
Roy,
EPA/
Emission
Standards
Division/
Combustion
Group
This
memorandum
summarizes
the
requirements
for
stationary
engines
to
meet
new
nitrogen
oxides
(
NO
X)
regulations
in
State
and
local
areas.
Each
of
the
States
or
local
areas
that
have
adopted
NO
X
reduction
regulations
were
contacted
to
get
information
on
what
facilities
with
stationary
engines
are
doing
to
meet
the
new
NO
X
limits.
In
addition,
cost
effectiveness
estimates
of
the
control
technologies
were
obtained.

Texas
De­
Grandfathering
Sources
Houston/
Galeston
Non­
Attainment
Area
cap
and
Trade
Program
The
Texas
Commission
on
Environmental
Quality
has
developed
a
Voluntary
Emission
Reduction
Permit
(
VERP)
for
the
permitting
of
existing
significant
sources
(
i.
e.
grandfathered
facilities).

These
sources
are
required
to
complete
permits
that
reduce
the
emissions
of
NO
X,
and
volatile
organic
compounds
(
VOC)
using
generally
available
control
technology
(
GACT).
The
Texas
Clean
Air
Act
defines
GACT
as
a
control
technology
that
the
Commission
has
found
to
be
generally
achievable
for
facilities
in
the
area
of
the
same
type,
considering
the
age
and
remaining
useful
life
of
the
facility.
In
general,
GACT
will
fall
somewhere
between
10­
year
old
Best
Available
Control
Technology
(
BACT)
and
what
is
considered
current
tier
one
BACT.
To
meet
the
required
NO
X
reductions
many
of
the
owner/
operators
of
stationary
engines
have
either
shut
down,
taken
a
limit
on
the
number
of
hours
of
operation,
installed
selective
catalytic
reduction,
2
added
exhaust
gas
recirculation,
made
timing
adjustments,
or
plan
to
purchase
newer
low
NO
X
emission
engines.
In
the
Houston/
Galveston
non­
attainment
area,
owner/
operators
are
expected
to
replace
older
non­
compliant
engines
with
new
engines
that
meet
the
0.5
grams
per
horsepower
standard.

Louisiana
The
Louisiana
Department
of
Environmental
Quality
is
requiring
owner/
operators
of
stationary
engines
to
implement
reasonable
available
control
technology
(
RACT)
to
reduce
emissions
of
NO
X
in
the
Baton
Rouge
non­
attainment
area.
Facilities
in
the
non­
attainment
areas
have
used
combustion
modifications
to
meet
the
new
NO
X
limits.
The
combustion
modifications
include
injection
timing
retard,
exhaust
gas
recirculation,
and
the
addition
of
turbo
boosters.
Some
owner/
operators
plan
to
install
new
low
NO
X
emission
engines
to
replace
the
older
engines.

Eastern
States
Phase
II
NOX
SIP
Call
Permitting
personnel
from
North
Carolina,
New
York,
Pennsylvania,
and
Massachusetts
were
contacted
to
find
out
what
measures
were
taken
to
reduce
emissions
from
stationary
engines
in
their
State
Implementation
Plan
(
SIP)
to
respond
to
the
Phase
II
NO
X
SIP
Call.
Currently
many
of
the
owner/
operators
of
large
stationary
engines
are
retrofitting
their
engine
with
selective
catalytic
reduction
(
SCR)
to
meet
the
new
NO
X
reduction
requirements.
The
agencies
have
generally
estimated
the
cost
effectiveness
of
SCR
to
be
in
the
range
of
$
500
to
$
2500
per
ton
of
NO
X
removed.
New
York
has
estimated
the
capital
cost
for
a
SCR
system
for
a
475
horsepower
engine
is
$
53,000
and
for
a
550
horsepower
engine,
$
56,000.
Owner/
operators
of
smaller
stationary
engines
are
typically
taking
a
limit
on
the
number
of
hours
of
operation
of
their
stationary
engine
to
meet
the
new
NO
X
levels.
Some
owner/
operators
plan
to
purchase
new
low
NO
X
emission
engines
to
meet
the
standards.

Philadelphia
Area
Small
Source
NOX
Rule
3
The
Pennsylvania
Department
of
Environmental
Protection
is
currently
proposing
the
"
Small
Sources
of
NO
X,
Cement
Kilns,
and
Large
Internal
Combustion
Engine"
regulation.
For
diesel
stationary
engines
greater
than
1000
horsepower
the
NO
X
limit
would
be
2.3
grams
per
horsepower­
hour.
If
emission
reductions
are
needed,
they
can
be
achieved
by
installing
selective
catalytic
reduction
control
equipment,
doing
combustion
modifications,
or
by
switching
fuels.

Costs
to
reduce
emissions
have
been
estimated
by
the
DEP
to
be
in
the
range
of
$
1,700
to
$
4,400
per
ton
of
NO
X
removed
based
on
the
Ozone
Transport
Commission
(
OTC)
cost
estimates.
The
cost
effectiveness
numbers
were
calculated
using
an
1990
model
year
uncontrolled
engine
as
the
baseline.
