1
MEMORANDUM
DATE:
June
9,
2005
SUBJECT:
Information
Obtained
from
State
Agencies
on
NO
X
Control
Technologies
for
Diesel
Internal
Combustion
Engines
FROM:
Bradley
Nelson,
Alpha­
Gamma
Technologies,
Inc.

TO:
Sims
Roy,
EPA
OAQPS
ESD
Combustion
Group
This
memorandum
summarizes
the
information
obtained
from
State
agencies
concerning
the
reduction
of
NO
X
emissions
from
diesel
fired
internal
combustion
engines
(
ICE).
Several
agencies
were
contacted
about
the
types
of
control
technologies
that
were
used
on
permitted
diesel
engines
from
their
State.
The
State
agencies
that
were
contacted
included
New
York,
Massachusetts,
Texas,
Wisconsin,
Pennsylvania,
and
Vermont.
The
State
of
Washington
was
also
contacted
after
some
of
the
State
contacts
stated
that
a
number
of
diesel
engines
had
been
permitted
in
that
State
within
the
last
couple
of
years.

Information
from
State
Agencies
The
EPA
was
notified
that
conEdison,
Inc.
had
installed
selective
catalytic
reduction
(
SCR)
control
on
10
diesel
fired
engines
in
New
York.
Mike
Jennings
from
the
New
York
State
Department
of
Environmental
Conservation,
Division
of
Air
Resources
Bureau
was
contacted
to
obtain
additional
information
about
these
engines.
Mr.
Jennings
stated
he
was
unaware
of
any
diesel
fired
engines
that
used
SCR
in
the
State
of
New
York.
He
stated
that
he
is
currently
working
on
new
NO
X
regulations
and
had
recently
done
an
inventory
of
engines
in
the
State.
Current
New
York
regulations
require
RACT,
or
Reasonably
Available
Control
Technology
on
existing
sources
in
areas
that
are
not
meeting
national
ambient
air
quality
standards
(
i.
e.,
non­
attainment
areas)
for
diesel
engines.
The
State
uses
a
$
3,750
per
ton
cost
effectiveness
as
the
RACT
limit,
and
the
only
technologies
that
were
able
to
meet
that
cost
criteria
were:
airto
fuel
ratio,
timing
retard,
and
ignition
retard.
The
State
currently
uses
the
EPA's
Air
Pollution
Control
Cost
Manual
for
calculating
cost
effectiveness
of
control
technologies
for
RACT.
2
The
Texas
Commission
on
Environmental
Quality
was
contacted
to
find
information
on
control
technologies
used
by
diesel
fired
engines.
Randy
Hamilton
stated
that
he
was
unaware
of
any
diesel
engines
in
Texas
that
used
add­
on
control
devices.
He
stated
there
were
a
few
that
had
some
combustion
process
modifications
and
some
that
added
exhaust
gas
recirculation,
but
there
were
none
that
had
SCR.
He
said
that
most
diesel
engines
meet
the
State's
NO
X
limit
by
using
combustion
control
or
taking
a
limit
on
the
number
of
hours
the
engine
can
operate.
Mr.
Hamilton
said
that
the
State
of
Washington
had
permitted
a
number
of
diesel
fired
engines
in
2001,
and
that
I
should
contact
someone
from
that
agency.

For
Massachusetts,
Don
Squires
from
the
Massachusetts
Department
of
Environmental
Protection
was
contacted
for
diesel
engine
information.
He
said
that
Massachusetts
does
not
have
many
diesel
fired
engines,
and
none
with
any
air
pollution
control
devices.
He
said
that
the
diesel
fired
engines
in
the
State
take
a
restriction
on
the
number
of
hours
that
they
can
operate
to
meet
any
applicable
State
regulations.

Keith
Pierce
of
the
Wisconsin
Department
of
Natural
Resources
was
contacted
to
obtain
information
on
control
technologies
used
on
diesel
engines
in
Wisconsin.
He
stated
that
Wisconsin
had
never
required
SCR
for
NO
X
control
for
diesel
engines.

Information
from
the
Vermont
Agency
of
Natural
Resources
was
obtained
from
Jay
Hollingsworth.
He
said
the
State
currently
has
three
locations
where
SCR
is
used
to
reduce
NO
X
emissions
from
diesel
fired
engines.
Two
of
the
sources
are
located
at
ski
resorts,
Killington
and
Okemo,
and
the
other
source
is
at
Mill
River
Lumber.
A
summary
of
the
diesel
engines,
NO
X
emission
estimates,
and
cost
information
for
each
of
these
sites
is
provided
in
the
following
sections.

Okemo
Mountain,
Ludlow,
Vermont:
The
Okemo
site
operates
25
diesel
engine
generators,
however
only
one,
a
1480
brake
horsepower
(
bhp)
Caterpillar
3516
engine
is
equipped
with
a
SCR
system
installed
by
the
Miratech
Corporation.
Emissions
of
NO
X
from
this
engine
were
calculated
based
on
the
SCR
manufacturer's
guarantee
of
1.6
g/
bhp­
hr.
Based
on
1,500
hours
per
year
of
operation
and
a
diesel
sulfur
limit
of
0.50
percent
by
weight,
the
NO
X
emissions
from
the
engine
were
calculated
to
be
5.2
pounds
per
hour
(
lbs/
hr)
and
3.9
tons
per
year
(
T/
yr).
This
represents
an
85
percent
reduction
of
NO
X
using
the
SCR
technology,
based
on
emission
estimates
without
the
SCR
technology.

Killington
Resort,
Killington,
Vermont:
The
Killington
Resort
operates
a
number
of
diesel
fired
engines
used
to
make
snow
for
skiing,
however
only
one
of
the
engines
is
equipped
with
a
SCR
installed
by
the
RJM
Corporation.
The
State
estimates
the
NO
X
reduction
from
installing
the
SCR
is
approximately
90
percent
with
a
cost
effectiveness
of
$
2,509
per
ton
of
NO
X
removed.
The
State
estimates
the
cost
of
the
addition
of
SCR
3
to
be
$
160,500
which
includes
$
127,500
for
the
SCR,
$
3,000
for
initial
stack
test,
$
20,000
for
urea
tank,
and
$
10,000
labor
to
install.
Additional
indirect
costs
include
$
29,000
for
urea,
additional
stack
testing,
and
a
fuel
penalty
(
approximately
2
to
4
percent)
due
to
back
pressure
from
the
installation
of
the
SCR.

Mill
River
Lumber,
North
Clarendon,
Vermont:
Mill
River
Lumber
is
a
sawmill
that
operates
two
diesel
engine
generators
at
their
facility.
The
facility
added
a
more
fuel
efficient
engine
(
Caterpillar
3508B,
1,341
horsepower
(
hp))
and
installed
SCR
and
an
oxidation
catalyst
on
a
1,023
hp
Caterpillar
3412C.
Based
on
a
NO
X
control
efficiency
of
90
percent
for
the
SCR,
the
NO
X
emissions
from
the
engine
were
estimated
to
be
1.7
pounds
per
hour,
which
corresponds
to
approximately
0.75
g/
hp­
hr.
The
Caterpillar
3508B,
which
does
not
have
any
of
add­
on
control,
has
a
NO
X
manufacturer's
guarantee
of
6.9
g/
hp­
hr.

At
the
Pennsylvania
Department
of
Environmental
Protection,
the
contact
was
Naishadh
Bhatt.
He
stated
there
were
a
number
of
diesel
fired
engines
in
Pennsylvania
that
had
installed
SCR
for
NO
X
control.
He
did
not
have
any
information
on
the
number
of
units,
but
said
he
was
currently
working
on
putting
together
cost
information
on
control
devices
for
engines,
but
did
not
have
any
formal
information
to
share
at
this
time.

From
the
Washington
Department
of
Ecology,
Central
Regional
Office,
Bob
Swackhamer
provided
information
on
diesel
engines
in
the
State
of
Washington.
He
said
that
many
engines
were
permitted
in
the
year
2001
due
to
high
wholesale
electricity
prices
and
outages
in
the
Pacific
Northwest.
Because
of
the
high
demand
for
electrical
generating
sources,
the
State
offered
temporary
operating
permits
to
merchant
power
projects
to
meet
demand
for
summer
electrical
use.
Additional
test
data
information
on
electric
generating
sites
in
Moses
Lake
were
received
through
Greg
Flibbert
from
a
regional
office
in
the
State
of
Washington.

Ophir
Substation,
Okanogan,
Washington:
Only
one
generating
plant,
Ophir
Substation,
was
permitted
and
built
in
the
Central
Region
in
2001,
but
it
no
longer
has
a
permit
to
operate
due
to
changes
in
the
energy
market
and
internal
disputes
with
the
equipment
owners.
The
Ophir
Substation
consisted
of
16
Cummins
Model
QSK60­
G6
diesel
generators
equipped
with
RJM
SCR.
Some
of
the
engines
were
also
equipped
with
CO
catalyst.
Test
data
from
an
emissions
evaluation
of
two
of
the
engines
at
the
substation
was
provided
by
the
State.
Unit
5
is
equipped
with
both
a
SCR
and
oxidation
catalyst
and
averaged
NO
X
concentrations
of
684.4
ppm
@
15
percent
O
2
at
the
inlet
and
98.5
ppm
@
15
percent
O
2
at
the
outlet
for
a
removal
efficiency
of
85.9
percent.
The
CO
concentrations
were
126.7
ppm
@
15
percent
O
2
at
the
inlet
and
0.0
ppm
@
15
percent
O
2
at
the
outlet
for
a
removal
efficiency
of
greater
than
99.9
percent.
Unit
6
is
equipped
with
SCR
and
averaged
NO
X
concentrations
of
663.8
ppm
@
15
percent
O
2
at
the
inlet
and
50.6
ppm
@
15
percent
O
2
at
the
outlet
for
a
removal
4
efficiency
of
92.4
percent.
The
CO
concentrations
were
63.8
ppm
@
15
percent
O
2
at
the
inlet
and
87.0
ppm
@
15
percent
O
2
at
the
outlet
for
a
removal
efficiency
of
­
36.9
percent.
When
comparing
these
two
test
results,
the
CO
catalyst
appears
to
reduce
the
effectiveness
of
the
SCR
for
NO
X,
but
reduces
the
CO
emissions
from
the
engine
to
minimal
emissions.

Grant
County
Public
Utility
District
No.
2,
Moses
Lake,
Washington:
This
facility
operates
20
Caterpillar
Model
3516B
diesel
generators
equipped
with
SCR
control
devices.
Emissions
data
was
collected
in
March
2003
on
two
of
the
engines
using
CEM
analyzers
and
EPA
methods.
The
average
NO
X
concentrations
from
Engine
9
were
1981.6
ppm
@
5
percent
O
2
at
the
inlet
location,
and
167.6
ppm
@
5
percent
O
2
at
the
outlet,
resulting
in
a
removal
efficiency
of
91.5
percent.
The
average
NO
X
concentrations
from
Engine
10
were
1991.9
ppm
@
5
percent
O
2
at
the
inlet
location,
and
119.3
ppm
@
5
percent
O
2
at
the
outlet,
resulting
in
a
removal
efficiency
of
94.0
percent.
The
average
outlet
CO
concentrations
for
Engines
9
and
10
were
143.7
and
130.4
ppm
@
5
percent
O
2
respectively.
The
average
inlet
CO
concentrations
for
Engines
9
and
10
were
77.4
and
69.5
ppm
@
5
percent
O
2
respectively.

Moses
Lake
Generating
LLC,
Moses
Lake,
Washington:
This
facility
generates
electricity
using
26
Mitsubishi
S16
dual­
fuel
generator
sets.
Emissions
tests
were
conducted
on
Engines
2,
19,
10,
and
25,
which
were
all
equipped
with
SCR.
During
the
tests
conducted
in
May
2002
and
September
2003,
the
engines
were
firing
approximately
70
percent
natural
gas
and
30
percent
diesel
fuel.
The
average
outlet
NO
X
results
using
EPA
Method
7E
from
Engines
2
and
29
were
54.2
ppm
and
69.5
ppm
respectively.
The
average
inlet
and
outlet
NO
X
concentrations
from
Engine
10
were
834.4
ppm
@
5
percent
O
2
and
122.7
ppm
@
5
percent
O
2
respectively,
which
corresponds
to
a
NO
X
removal
efficiency
of
85.3
percent.
The
average
CO
concentration
for
this
engine
was
59.3
ppm
@
5
percent
O
2.
The
average
NO
X
concentrations
from
Engine
25
were
272.4
ppm
@
5
percent
O
2
at
the
inlet
location
and
118.1
ppm
@
5
percent
O
2
at
the
outlet
location,
which
corresponds
to
a
NO
X
removal
efficiency
of
56.4
percent.
The
average
CO
concentration
for
this
engine
was
99.5
ppm
@
5
percent
O
2.
