1
MEMORANDUM
DATE:
June
20,
2005
SUBJECT:
Hours
of
Operation
for
Stationary
Compression
Ignition
Internal
Combustion
Engines
FROM:
Tanya
Parise,
Alpha­
Gamma
Technologies,
Inc.

TO:
Sims
Roy,
EPA
OAQPS
ESD
Combustion
Group
The
purpose
of
this
memorandum
is
to
present
various
estimates
of
the
average
number
of
hours
stationary
compression
ignition
(
CI)
internal
combustion
engines
(
ICE)
operate
annually.
These
estimates
will
support
regulatory
decisions
associated
with
the
new
source
performance
standards
(
NSPS)
for
stationary
CI
ICE.

RICE
NESHAP
An
inventory
database
of
stationary
engines
was
developed
for
the
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
for
stationary
reciprocating
internal
combustion
engines
(
RICE).
1
The
RICE
NESHAP
database
is
a
compilation
of
information
from
a
variety
of
sources
including
the
Aerometric
Information
Retrieval
System,
the
Ozone
Transport
and
Assessment
Group,
and
State
and
local
agencies'
databases.

Information
in
the
RICE
NESHAP
database
indicates
that
stationary
prime
CI
engines
greater
than
50
horsepower
(
HP)
operate
on
an
average
of
2,100
hours
per
year.
Prime
engines
are
defined
as
those
engines
not
used
exclusively
for
emergency
service.
Stationary
prime
CI
engines
greater
than
500
HP
operate
on
an
average
of
1,700
hours
per
year,
according
to
the
RICE
NESHAP
database.

1
Environmental
Protection
Agency
­
Air
Toxics
Website.
Rule
and
Implementation
Information
for
the
Reciprocating
Internal
Combustion
Engines
National
Emission
Standards
for
Hazardous
Air
Pollutants.
Inventory
Database
for
RICE.
December
2,
2002.
http://
www.
epa.
gov/
ttn/
atw/
rice/
ricepg.
html.
2
CARB
Prime
In
support
of
the
airborne
toxic
control
measure
for
stationary
CI
engines,
the
California
Air
Resources
Board
(
CARB)
conducted
a
survey
of
prime
diesel
engines
in
March
of
2003.
The
purpose
of
the
survey
was
to
determine
how
prime
diesel
engines
are
operated
in
California.
The
results
of
the
survey
were
presented
in
CARB's
Staff
Report.
2
Engines
in
the
prime
diesel
engines
survey
ranged
from
under
50
HP
to
over
2,000
HP.
The
majority
of
the
engines
were
in
the
100­
174
HP,
300­
599
HP,
and
greater
than
750
HP
size
categories.
These
size
categories
represent
66
percent
of
the
engines
surveyed.
The
average
size
of
the
prime
diesel
engines
surveyed
was
556
HP.
According
to
the
survey,
the
average
hours
of
operation
for
prime
CI
engines
is
953
hours.
Table
1
shows
the
average
annual
hours
for
each
application
for
prime
diesel
engines.

Table
1.
Average
Hours
of
Operation
for
Prime
Diesel
Engines
Application
Average
Annual
Hours
Air
compressor
334
Cogeneration
5,501
Crane
1,024
Crusher
1,114
Generator
1,563
Grinder
798
Hay
compressor
1,482
Magnetic
silencer
8
Mud
mixer
517
Pump
46
Sand
blaster
313
Turbine
starter
22
2
California
Environmental
Protection
Agency,
Air
Resources
Board.
Staff
Report:
Initial
Statement
of
Reasons
for
Proposed
Rulemaking.
Airborne
Toxic
Control
Measure
for
Stationary
Compression­
Ignition
Engines.
Stationary
Source
Division,
Emissions
Assessment
Branch.
September
2003.
3
Application
Average
Annual
Hours
Winch
<
50
Wood
chipper
869
Other
852
Emergency
A
survey
of
emergency
diesel
engines
was
also
conducted
by
CARB
in
September
of
2002.
The
purpose
of
the
survey
was
to
determine
the
average
number
of
hours
that
stationary
emergency
diesel
engines
operate.
The
results
of
the
survey
were
presented
in
Appendix
B
of
CARB's
Staff
Report.
Engines
in
the
emergency
engines
survey
ranged
from
under
50
HP
to
over
1,000
HP,
although
the
survey
targeted
engines
greater
than
or
equal
to
50
HP.
The
survey
requested
hours
of
operation
for
1999
through
2001
for
maintenance
and
testing,
interruptable
service
contracts,
and
emergencies.
Table
2
shows
the
average
annual
hours
for
emergency
diesel
engines
based
on
CARB's
survey.

Table
2.
Average
Hours
of
Operation
for
Emergency
Diesel
Engines
Year
Activity
1999
2000
2001
Maintenance
and
Testing
22
22
21
Interruptable
service
contracts
1
3
4
Emergency/
Standby
6
6
8
Total
29
31
33
Average
31
NESCAUM
The
Northeast
States
for
Coordinated
Air
Use
Management
(
NESCAUM)
recently
published
a
report
on
control
technology
options
and
air
quality
policy
issues
for
stationary
diesel
engines
in
the
Northeast.
3
The
main
purpose
of
the
report
was
to
obtain
information
on
the
numbers
and
types
of
stationary
CI
engines
that
operate
in
3
Stationary
Diesel
Engines
in
the
Northeast:
An
Initial
Assessment
of
the
Regional
Population,
Control
Technology
Options
and
Air
Quality
Policy
Issues.
Northeast
States
for
Coordinated
Air
Use
Management.
June
2003.
4
the
eight­
state
NESCAUM
region,
which
includes
Connecticut,
Maine,
Massachusetts,
New
Hampshire,
New
Jersey,
New
York,
Rhode
Island,
and
Vermont.
Power
Systems
Research
(
PSR)
conducted
a
survey
of
diesel­
fired
generators
in
New
York
City
and
Fairfield
County,
Connecticut,
and
results
were
presented
in
NESCAUM's
report.
The
results
from
the
survey
includes
information
on
the
number
of
hours
prime
diesel
engines
operate
in
Fairfield
County.
No
information
was
presented
on
the
number
of
hours
prime
engines
located
in
New
York
City
operate,
however,
emergency
diesel
engines
operate
on
average
of
150
hours
per
year.
Based
on
information
reported
in
surveys
distributed
in
Fairfield
County,
prime
diesel
engines
operate
on
average
of
3,790
hours
per
year.
According
to
the
report,
emergency
diesel
engines
in
Fairfield
County
operate
on
average
42
hours
per
year.

PSR
Supporting
documentation
for
the
EPA's
NONROAD
model
includes
activity
estimates
for
nonroad
diesel
engines.
4
The
activity
estimates
were
obtained
from
a
1998
database
developed
by
PSR,
an
independent
research
firm
that
conducts
yearly
surveys
of
equipment
owners.
Estimates
of
yearly
operation
are
available
for
several
different
applications
and
fuel
types.

Included
in
the
NONROAD
model
activity
estimates
are
average
hours
per
year
of
operation
for
engines
that
are
non­
stationary
engines
and
also
engines
that
are
using
other
fuels
than
diesel.
Table
3
presents
the
activity
estimates
for
applications
associated
with
stationary
engines
combusting
diesel
fuel.
Note
that
the
PSR
information
did
not
specifically
address
engines
used
for
emergency
service
and
the
information
in
Table
3
may
include
prime
and
emergency
diesel
engines.

Table
3.
Activity
Estimates
for
Stationary
Diesel
Engine
Applications
based
on
1998
PSR
Database
Equipment
Description
Activity
(
hours/
year)

Hydro
Power
Units
790
I
rrigation
Sets
749
Generator
Sets
338
Pumps
403
Air
Compressors
815
4
United
States
Environmental
Protection
Agency.
Air
and
Radiation.
Median
Life,
Annual
Activity,
and
Load
Factor
Values
for
Nonroad
Engine
Emissions
Modeling.
EPA420­
P­
04­
005.
NR­
005c.
April
2004.
5
Equipment
Description
Activity
(
hours/
year)

Gas
Compressors
8,500
Welders
643
ACT
Information
in
EPA's
Alternative
Control
Techniques
Document
5
presents
a
variety
of
information
on
stationary
engines,
including
estimates
of
yearly
operating
hours
for
diesel­
fired
stationary
engines.
The
average
operation
is
presented
for
different
industries
including
the
oil
and
gas
industry,
industrial
and
municipal
applications,
agricultural
applications,
and
electrical
power
generation.
A
summary
of
the
average
annual
hours
of
operation
for
various
applications
of
diesel­
fired
stationary
engines
is
presented
in
Table
4.
Please
note
that
the
information
presented
in
Table
4
may
include
the
hours
of
operation
for
prime
and
emergency
engines.

Table
4.
Average
Operation
for
Stationary
Diesel
Engine
Applications
based
on
1993
ACT
Document
Industry1
Average
Size
(
HP)
Average
Operation
(
hours/
year)

Oil
and
gas
­
Production
On­
land
drilling
Off­
shore
drilling
350
2,000
Oil
and
gas
­
Transmission
2,000
6,000
General
industrial
and
municipal
­
Construction
Small
Large
Portable
50
240
75
500
500
500
General
industrial
and
municipal
­
Generator
sets,
standby
<
50
kilowatt
(
KW)
(
67
HP)
50­
400
KW
(
67­
536
HP)
400­
1000
KW
(
536­
1,340
HP)
75
250
750
500
250
100
General
industrial
and
municipal
­
100
3,500
5
United
States
Environmental
Protection
Agency.
Office
of
Air
Quality
Planning
and
Standards.
Alternative
Control
Techniques
Document
­­
NOx
Emissions
from
Stationary
Reciprocating
Internal
Combustion
Engines.
EPA­
453/
R­
93­
032.
July
1993.
6
Industry1
Average
Size
(
HP)
Average
Operation
(
hours/
year)

Marine
­
nonpropulsive
General
industrial
and
municipal
­
Miscellaneous,
large2
750
100
General
industrial
and
municipal
­
Municipal
water
supply
120
3,000
General
industrial
and
municipal
­
Pumps
100
1,000
General
industrial
and
municipal
­
Welders
100
500
Electrical
power
generation
2,500
2,600
1General
industrial
and
municipal
applications
include
some
agricultural
uses.
2Includes
pumps,
snow
blowers,
aircraft
turbine
starters,
etc.

NC
Diesel
Engine
Operators
The
EPA
contacted
the
North
Carolina
Department
of
Environment
and
Natural
Resources
(
NCDENR)
to
obtain
information
on
prime
diesel
engines
operating
in
North
Carolina.
In
response
to
EPA's
request,
the
NCDENR
sent
a
list
it
had
compiled
of
stationary
engines
that
were
potentially
subject
to
the
stationary
RICE
NESHAP.
The
information
indicated
which
application
each
facility
was
and
also
which
fuel
is
used.
However,
the
information
did
not
indicate
what
the
engines
are
used
for
or
if
the
engines
are
prime
or
emergency
engines.
The
EPA
briefly
reviewed
the
Title
V
permits
for
the
facilities
that
were
using
diesel
fuel
to
determine
from
the
facility's
permit
if
the
engines
were
prime
or
emergency.
The
facility
permits
did
not
consistently
indicate
whether
the
engines
were
prime
or
emergency,
although,
some
indicated
that
the
engines
were
used
for
emergency
service.
For
the
facilities
where
the
permit
did
not
mention
that
the
engines
were
used
for
emergency
service,
EPA
contacted
these
facilities
directly
to
determine
if
the
engines
at
the
facilities
were
prime
or
emergency
engines.
In
addition,
EPA
also
asked
the
facilities
to
provide
the
annual
hours
of
operation
if
it
had
prime
diesel
engines
that
were
operating.

Several
of
the
facilities
contacted
by
EPA
responded
that
they
only
operate
stationary
diesel
engines
for
emergency
purposes.
Two
facilities
responded
that
they
currently
do
operate
prime
diesel
engines.
The
Camp
Lejeune
facility
responded
that
it
has
a
prime
diesel
engine
1,600
KW
(
2,144
HP)
in
size
that
is
used
for
peak
shaving
purposes.
The
engine
operated
80
hours
in
2003
and
129
hours
in
2002.
Weyerhaeuser's
Elkin
plant
responded
that
it
operates
a
woodyard
hog
engine
that
by
EPA's
definition
is
a
prime
diesel
engine.
The
diesel
engine
basically
takes
unusable
wood
debris
and
grinds
it
into
wood
fuel
or
wood
mulch.
The
engine
is
permitted
to
run
2,600
hours
per
7
year
but
typically
operates
on
average
of
250­
300
hours
per
year,
according
to
the
facility
contact.
One
additional
facility,
Grady­
White
Boats,
indicated
that
it
has
two
diesel
engines
that
are
used
for
emergency
service
and
peak
demand
shaving.
The
facility
said
that
the
engines
operate
about
250
hours
per
year
but
that
it
could
not
specify
the
number
of
hours
for
each
use
as
the
facility
has
never
had
a
need
to
do
so.
However,
the
compliance
manager
provided
an
educated
guess
that
the
facility
probably
operates
about
3
hours
per
year
on
emergency
supply.
The
compliance
manager
pointed
out
that
this
would
change
quickly
with
a
damaged
grid
system
such
as
what
is
currently
occurring
in
Florida.
The
facility
has
not
been
hit
with
that
type
of
incident
since
it
put
the
capacity
in
to
run
the
entire
facility.
Appalachian
State
University
operates
three
1.0
megawatt
(
1,340
HP)
diesel
engines
in
a
steam
plant
used
for
electrical
peak
shaving.
The
usage
is
controlled
by
New
River
Light
and
Power,
which
estimates
average
usage
of
about
8­
10
hours
per
month,
with
some
months
2­
4
hours,
according
assistant
director
of
the
university's
physical
plant.

National
Fire
Protection
Association
The
National
Fire
Protection
Association
(
NFPA)
develops
codes,
standards,
recommended
practices,
and
guides
for
the
protection
of
life
and
property,
e.
g.,
NFPA
70,
is
the
National
Electric
Code.
The
NFPA
also
issues
NFPA
20,
which
is
the
Standard
for
the
Installation
of
Stationary
Pumps
for
Fire
Protection.
The
NFPA
requires
that
stationary
diesel
engines
that
are
used
for
emergency
purposes
are
run
30
minutes
per
week
(
27
hours
per
year)
for
maintenance
and
testing
purposes
to
ensure
that
the
engine
will
respond
properly
in
the
event
of
an
emergency.

Conclusion
Presented
in
Table
5
is
a
summary
of
the
information
presented
in
this
memorandum
on
the
average
number
of
hours
stationary
diesel
engines
operate
annually.

Table
5.
Summary
of
Stationary
Diesel
Engine
Annual
Operation
S
ource
Average
Operation
(
hours/
year)

RICE
NESHAP
Prime
>
50
HP
Prime
>
500
HP
2,100
1,700
CARB
Prime
Emergency
953
31
NESCAUM
Prime
(
Fairfield
County)
3,790
8
S
ource
Average
Operation
(
hours/
year)

Emergency
(
Fairfield
County)
Emergency
(
New
York
City)
42
150
PSR1
338­
8,500
ACT1
100­
6,000
NC
Prime
Diesel
Operators
Camp
Lejeune
(
2003)
Camp
Lejeune
(
2002)
Weyerhaeuser
Grady­
White
Boats
Appalachian
State
University
80
129
250­
300
2502
8­
10
NFPA
(
Emergency)
27
1May
include
yearly
operation
of
prime
and
emergency
diesel
engines.
2Includes
an
estimated
3
hours
per
year
for
operation
during
emergencies.

Based
on
information
presented
in
this
memorandum,
the
EPA
believes
that
1,000
hours
per
year
are
appropriate
to
represent
the
annual
operation
of
stationary
prime
diesel
engines.
The
1,000
hours
per
year
for
stationary
prime
diesel
engines
are
consistent
with
results
of
CARB's
survey
of
prime
diesel
engines,
which
was
based
on
annual
usage
by
actual
stationary
prime
diesel
engines
operating
in
California.
The
EPA
believes
that
37
hours
per
year
are
appropriate
to
represent
the
annual
operation
for
stationary
emergency
diesel
engines.
A
minimum
of
27
hours
per
year
of
operation
is
required
for
maintenance
and
testing,
and
consistent
with
results
of
CARB's
survey
of
emergency
diesel
engines,
an
additional
10
hours
per
year
would
be
sufficient
to
account
for
operation
during
emergencies.
