1
MEMORANDUM
DATE:
June
13,
2005
SUBJECT:
Summary
of
California
ATCM
for
Stationary
CI
Engines
FROM:
Tanya
Parise,
Alpha­
Gamma
Technologies,
Inc.

TO:
Sims
Roy,
EPA
OAQPS
ESD
Combustion
Group
The
purpose
of
this
memorandum
is
to
present
the
basis
for
the
diesel
particulate
matter
(
PM)
standards
for
California=
s
airborne
toxic
control
measure
(
ATCM)
for
stationary
compression
ignition
(
CI)
engines.
The
final
rulemaking
became
operative
December
8,
2004
and
is
published
in
section
93115,
title
17,
of
California=
s
Code
of
Regulations.
This
memorandum
will
also
present
other
estimates
and
compliance
requirements
associated
with
the
ATCM
for
stationary
CI
engines.

Basis
for
Standards
0.40
g/
bhp­
hr
The
diesel
PM
limit
of
0.40
grams
per
brake
horsepower­
hour
(
g/
bhp­
hr)
applies
to
in­
use
emergency
standby
engines
greater
than
50
bhp
that
are
operated
less
than
or
equal
to
30
hours
per
year
for
maintenance
and
testing
purposes.
Air
dispersion
modeling
performed
by
the
California
Air
Resources
Board
(
ARB)
shows
that
most
engines
that
emit
diesel
PM
at
an
emission
rate
of
0.40
g/
bhp­
hr
could
operate
for
up
to
30
hours
per
year
without
exceeding
a
potential
cancer
case
threshold
of
about
10
potential
cancer
cases
per
million
at
the
point
of
maximum
impact.
According
to
ARB,
the
0.40
g/
bhp­
hr
limit
is
technologically
achievable
because:

$
Off­
road
Certified
Engines
with
hp
ratings
from
100­
175
have
been
required
to
meet
a
0.22
g/
bhp­
hr
standard
since
2003.

$
Off­
road
Certified
Engines
with
hp
ratings
from
175­
750
have
been
required
to
meet
a
0.40
g/
bhp­
hr
standard
since
1996.

$
Off­
road
Certified
Engines
with
hp
ratings
greater
than
750
have
been
required
to
meet
a
0.40
g/
bhp­
hr
standard
since
2000.
2
$
Three
pre­
1996
model
year
engines
were
tested
for
diesel
PM
emission
rate
as
part
of
the
ARB/
Center
for
Environmental
Research
&
Technology
(
CE­
CERT)
Diesel
PM
Control
Technology
Demonstration.
All
three
engines
emitted
diesel
PM
at
levels
below
0.40
g/
bhp­
hr,
the
highest
being
0.19
g/
bhp­
hr.

$
Diesel
PM
emission
test
results
from
the
ARB/
CE­
CERT
Diesel
PM
Control
Technology
Demonstration
and
independent
testing
have
shown
diesel
oxidation
catalyst
(
DOC)
technology
can
reduce
diesel
PM
emissions
from
20
to
30
percent.
A
typical
uncontrolled
diesel­
fueled
engine
currently
operating
in
California
emits
between
0.50
and
0.60
g/
bhp­
hr
of
diesel
PM.
An
engine
with
baseline
diesel
PM
emission
rate
of
0.55
g/
bhp­
hr
would
be
able
to
meet
the
0.40
g/
bhp­
hr
standard
if
it
installed
a
DOC
with
a
reduction
efficiency
of
27
percent.

0.15
g/
bhp­
hr
The
diesel
PM
limit
of
0.15
g/
bhp­
hr
applies
to
new
and
in­
use
emergency
standby
engines
greater
than
50
bhp
that
are
operated
less
than
or
equal
to
50
hours
per
year
for
maintenance
and
testing
purposes
and
to
new
agricultural
engines.
Air
dispersion
modeling
performed
by
ARB
shows
that
most
engines
that
emit
diesel
PM
at
an
emission
rate
of
0.15
g/
bhp­
hr
could
operate
for
up
to
50
hours
per
year
without
exceeding
a
potential
cancer
case
threshold
of
10
potential
cancer
cases
per
million.
According
to
ARB,
the
0.15
g/
bhp­
hr
standard
is
appropriate
for
all
new
emergency
standby
engines
installed
after
January
1,
2005
because
new
engines
meeting
this
standard
are
currently
available
"
off­
the­
shelf."
The
0.15
g/
bhp­
hr
is
technologically
feasible
because:

$
Newly
manufactured
off­
road
engines
less
than
175
hp
are
held
to
less
stringent
standards,
but
certification
data
indicate
that
approximately
18
percent
of
the
off­
road
certified
engines
emitted
diesel
PM
at
a
rate
less
than
or
equal
to
0.15
g/
bhp­
hr.

$
Off­
road
Certified
Engines
with
hp
ratings
from
175­
299
have
been
required
to
meet
a
0.15
g/
bhp­
hr
standard
since
2003.

$
Off­
road
Certified
Engines
with
hp
ratings
from
300­
599
have
been
required
to
meet
a
0.15
g/
bhp­
hr
standard
since
2000.

$
Off­
road
Certified
Engines
with
hp
ratings
greater
than
600­
750
have
been
required
to
meet
a
0.15
g/
bhp­
hr
standard
since
2002.

$
Seven
stationary
diesel­
fueled
engines
were
tested
for
diesel
PM
emission
rate
as
part
of
the
ARB/
CE­
CERT
Diesel
PM
Control
Technology
Demonstration.
Of
the
seven,
two
of
the
engines
emitted
diesel
PM
at
a
rate
less
than
or
equal
to
0.15
g/
bhp­
hr.
The
remaining
five
were
retrofitted
with
different
diesel
PM
control
technologies.
These
control
technologies
included
emulsified
fuels,
active
and
passive
diesel
3
particulate
filter
(
DPF)
systems,
and
DOCs.
All
five
engines
were
tested
after
the
control
technologies
were
implemented
and
all
five
engines
emitted
diesel
PM
at
levels
below
0.15
g/
bhp­
hr.

0.01
g/
bhp­
hr
The
diesel
PM
limit
of
0.01
g/
bhp­
hr
applies
to
new
and
in­
use
emergency
standby
engines
greater
than
50
bhp
that
are
operated
less
than
or
equal
to
100
hours
per
year
for
maintenance
and
testing
purposes,
and
to
new
and
in­
use
prime
engines.
For
new
and
in­
use
emergency
standby
engine
applications,
air
dispersion
modeling
conducted
by
ARB
shows
that
most
engines
that
emit
diesel
PM
at
an
emission
rate
of
0.01
g/
bhp­
hr
could
operate
for
up
to
100
hours
per
year
without
exceeding
a
potential
cancer
case
threshold
of
about
one
potential
cancer
case
per
million.
For
new
and
inuse
prime
engines,
air
dispersion
modeling
conducted
by
ARB
shows
that
most
engines
that
emit
diesel
PM
at
an
emission
rate
of
0.01
g/
bhp­
hr
could
operate
for
up
to
1,000
hours
per
year
without
exceeding
a
potential
cancer
case
threshold
of
about
10
potential
cancer
cases
per
million.
According
to
survey
response
information,
the
average
hours
of
operation
for
a
stationary
prime
diesel­
fueled
engine
is
approximately
1,000
hours
per
year.
According
to
ARB,
the
0.01
g/
bhp­
hr
limit
is
technologically
achievable
because:

$
Two
stationary
diesel­
fueled
engines
that
were
tested
for
diesel
PM
emission
rate
as
part
of
the
ARB/
CE­
CERT
Diesel
PM
Control
Technology
Demonstration
were
able
to
achieve
a
diesel
PM
emission
rate
of
equal
to
or
less
than
0.01
g/
bhp­
hr
through
the
application
of
DPF
technologies.

$
In
support
of
its
Verification
application
to
the
ARB,
CleanAIR
Systems
has
submitted
diesel­
fueled
CI
engine
emission
test
data
that
show
its
passive
DPF
technology,
the
PERMIT
technology,
is
capable
of
diesel
PM
emission
rate
reductions
of
85
percent
and
greater,
and
has
resulted
in
reducing
diesel­
fueled
CI
engine
emission
rates
to
below
0.01
g/
bhp­
hr.

Baseline
Emissions
According
to
Table
IV­
1:
Stationary
Diesel­
Fueled
Engines
Year
2002
Emissions
Estimates
of
the
Staff
Report
1,
there
are
1,319
prime
engines
in
California
emitting
0.8
tons/
day
of
PM,
13.8
tons/
day
of
NOx,
and
4.8
tons/
day
of
CO
and
19,659
emergency
standby
engines
in
California
emitting
0.3
tons/
day
of
PM,
6.4
tons/
day
of
NOx,
and
2.1
tons/
day
of
CO.
The
emissions
are
total
emissions
for
all
engines
and
1
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.
4
are
not
emissions
per
engine.
5
Costs
Cost
to
install
DPF
is
estimated
at
$
38/
hp,
DOC
is
$
10.40/
hp,
and
the
cost
of
a
new
engine
is
estimated
at
$
92.65/
hp.
The
costs
estimated
for
DPF
were
based
on
costs
associated
with
both
active
and
passive
DPF.
The
ARB
staff
estimated
the
costs
to
comply
with
the
ATCM
for
a
typical
business
with
a
590
hp
prime
engine
operated
1,040
hours
per
year.
The
estimated
capital
cost
is
$
22,400
for
the
installation
of
a
DPF.
For
those
engines
installing
a
DOC
and
then
later
replacing
that
engine
with
a
new
Tier
IV
engine
in
2011,
the
estimated
capital
cost
is
$
60,850
($
6,150
in
2005
and
$
54,700
in
2011).
For
engines
with
a
DPF,
there
will
be
an
additional
annual
cost
of
approximately
$
550
for
maintenance.
For
businesses
with
emergency
standby
engines,
ARB
expects
most
operators
to
reduce
their
annual
hours
of
operation
to
avoid
installation
of
diesel
emission
controls
(
DECS),
which
should
result
in
cost
savings
due
to
a
reduction
in
the
annual
diesel
fuel
usage.
For
example,
an
operator
with
one
engine
(
520
hp)
could
reduce
maintenance
and
testing
usage
from
35
to
20
hours,
thereby
saving
about
$
760
annually.
While
most
operators
will
likely
reduce
their
hours
of
operation
to
meet
the
ATCM
requirements,
ARB
estimates
that
about
1
percent
of
operators
will
need
to
install
a
DOC.

The
cost
effectiveness
of
$
15/
lb
is
an
estimated
overall
annual
cost
effectiveness
based
on
dividing
the
annualized
costs
and
annual
ongoing
costs
by
the
diesel
PM
emission
reductions
attributable
to
the
ATCM
each
year
between
2005
and
2020.
The
cost
effectiveness
ranges
from
$
4
to
$
26/
lb
of
diesel
PM
reduction
between
these
years
due
to
different
regulatory
provisions
for
different
types
of
stationary
diesel
engines.

Source
Testing
The
types
of
information
that
can
be
submitted
to
the
district
air
pollution
control
officer
(
APCO)
compliance
with
the
emissions
standards
of
the
ATCM
includes:

$
Engine
manufacturer=
s
data,

$
Emission
test
data
from
similar
engines,

$
Emission
test
data
used
in
meeting
the
requirements
of
the
Verification
Procedure,

$
Certification
data,
and
$
Source
test
information
from
the
engine
subject
to
the
requirements.

The
ARB
staff
does
not
anticipate
that
a
majority
of
the
engines
subject
to
the
ATCM
will
be
required
to
be
source
tested.
Staff
believes
that
most
owners
of
emergency
standby
diesel­
fueled
CI
engines
subject
to
the
requirements
of
the
ATCM
will
reduce
their
hours
of
operation
for
maintenance
and
testing
to
below
20
hours
per
year.
This
is
the
most
cost­
effective
method
of
compliance.
For
prime
engines,
and
6
those
emergency
standby
engines
that
are
unable
to
reduce
their
hours
of
operation
to
below
20
hours
per
year,
engine
certification
test
data
for
post­
1996
engines
and
manufacturers
test
data
for
post­
1988
engines
is
available
for
many
in­
use
engines.
Emissions
testing
is
estimated
at
$
5,000
to
$
17,000
per
source
test.
The
lower
end
represents
a
single
mode
test
in
triplicate
and
the
upper
end
a
3­
mode
test
done
in
triplicate.
To
be
conservative,
for
ARB=
s
cost
estimate,
it
assumed
the
higher
costs.
The
ARB
believes,
however,
that
in
many
cases,
there
will
be
alternative
data
available
that
can
be
used
in
lieu
of
emission
testing
(
e.
g.,
manufacturer's
certification
data).

Test
Methods
The
final
regulation
order
requires
that
diesel
PM
emission
testing
is
performed
in
accordance
with
one
of
the
following
three
methods:

1.
CARB
Method
5
(
ARB
Method
5),
"
Determination
of
Particulate
Matter
Emissions
from
Stationary
Sources,"
as
amended
July
28,
1997.

a.
For
purposes
of
the
ATCM,
diesel
PM
shall
be
measured
only
by
the
probe
catch
and
filter
catch
and
shall
not
include
PM
captured
in
the
impinger
catch
or
solvent
extract.

b.
The
tests
are
to
be
carried
out
under
steady
state
operation.
Test
cycles
and
loads
shall
be
in
accordance
with
ISO­
8178
Part
4
or
alternative
test
cycle
approved
by
the
APCO.

c.
The
District
APCO
may
require
additional
engine
or
operational
duty
cycle
data
if
an
alternative
test
cycle
is
requested;
or
2.
International
Organization
for
Standardization
(
ISO)
8178
Test
procedures:
ISO
8178­
1:
1996(
E)
("
ISO
8178
Part
1");
ISO
8178­
2:
1996(
E)
("
ISO
8178
Part
2");
and
ISO
8178­
4:
1996(
E)
("
ISO
8178
Part
4");
or
3.
Title
13,
California
Code
of
Regulations,
section
2423,
Exhaust
Emission
Standards
and
Test
Procedures
 
Off­
Road
Compression
Ignition
Engines.

Appendix
G
of
the
Staff
Report
for
the
proposed
ATCM
has
a
discussion
of
the
concerns
with
the
inconsistencies
between
test
methods
used
to
certify
off­
road
engines
versus
the
methods
used
to
measure
emissions
from
stationary
engines.
A
direct
comparison
between
the
test
methods
was
conducted
on
five
engines,
four
that
were
uncontrolled
and
one
with
passive
diesel
particulate
filter
(
DPF).
The
ARB
Method
5
was
used
for
stationary
source
type
sampling
and
ISO
8178
was
used
for
the
off­
road
test
method.
The
tests
were
performed
using
a
3­
mode
D1
test
cycle
and
weighting
factors
as
specified
in
the
ISO
8178
Part
4.
The
test
results
indicated
that
7
total
PM
measured
using
ARB
Method
5
is
two
to
four
times
higher
than
total
PM
measured
by
ISO
8178.
There
was
good
agreement
when
the
total
PM
results
for
ARB
Method
5
filter
only,
ARB
Method
5
front
half,
and
ISO
8178
levels
were
compared.

In
Appendix
G
of
the
Staff
Report,
CARB
noted
that
the
emission
levels
and
control
efficiencies
in
the
ATCM
are
derived
from
off­
road
engine
certification
and
verification
programs.
Based
on
the
comparison
of
the
off­
road
and
stationary
test
methods,
CARB
concluded
that
the
limits
in
the
ATCM
may
not
be
attainable
using
a
compliance
method
that
contains
a
condensable
component.
Therefore,
CARB
recommended
having
ISO
8178
as
the
primary
test
method
for
demonstrating
compliance
with
the
ATCM
and
allowing
ARB
Method
5
front
half
(
filter
+
probe
wash)
to
be
used
as
an
alternative.
The
CARB
staff
also
recommended
using
steady­
state
emission
test
cycles
as
outlined
in
ISO
8178
Part
4
if
ARB
Method
5
front
half
is
used.

Compliance
The
CARB
estimates
that
only
a
small
number
of
emergency
standby
engines
will
need
to
install
DECS.
The
ARB
expects
most
operators
of
emergency
standby
engines
to
reduce
their
annual
hours
of
operation
to
avoid
installation
of
DECS.
The
majority
of
the
costs
will
be
borne
by
prime
engine
owners,
while
in
many
cases,
owners
of
emergency
standby
engines
will
have
no
cost
or
net
savings
due
to
the
reduced
operating
hours.

For
new
prime
engines,
the
ATCM
requires
the
engine
to
meet
a
PM
emission
rate
of
0.01
g/
bhp­
hr.
Because
0.01
g/
bhp­
hr
engines
are
not
expected
to
be
available
"
off
the
shelf"
until
2011,
new
engine
purchasers
would
need
to
buy
engines
that
are
certified
to
0.15
g/
bhp­
hr
or
less
and
install
a
DPF
on
the
engine
to
lower
the
emissions
to
0.01
g/
bhp­
hr.
The
ARB
assumed
the
capital
costs
attributable
to
the
ATCM
are
the
costs
of
purchase
and
installation
of
the
DPF
on
new
engines
put
into
service
prior
to
2011.

For
new
emergency
standby
engines,
the
ATCM
requires
the
engine
to
meet
a
PM
emission
rate
of
0.15
g/
bhp­
hr
in
2005.
There
are
engines
in
all
hp
ranges
greater
than
50
hp
that
can
be
purchased
off
the
shelf
at
this
emission
limit.
Therefore,
ARB
assumed
there
will
be
no
capital
cost
attributable
to
the
ATCM
for
this
category.

Certified
existing
prime
engines
(
generally
engines
manufactured
in
1996
or
later)
are
required
to
either
reduce
diesel
PM
emissions
by
at
least
85
percent
or
meet
0.01
g/
bhp­
hr
in
the
2005­
2009
timeframe.
In
most
cases,
ARB
expects
that
engine
operators
will
choose
to
retrofit
their
engine
with
emission
control
technology
to
reduce
diesel
PM
emissions
by
85
percent.
Based
on
the
current
availability
of
emission
control
technologies
for
diesel
engines,
ARB
expects
most
operators
to
install
a
DPF.
8
For
non­
certified
engines,
where
it
is
not
possible
to
install
a
DPF
due
to
technical
issues,
the
ATCM
allows
for
installation
of
a
DOC
in
2005,
followed
by
replacement
of
the
engine
with
a
new
Tier
4
engine
in
the
2011­
2013
timeframe.
The
capital
cost
in
this
case
includes
the
cost
of
the
DOC
and
the
purchase
of
a
new
engine
in
2011.
The
ARB
expects
that
for
in­
use
prime
engines
80
percent
will
install
DPF
and
20
percent
will
install
DOC
and
new
engine
later.

There
are
a
wide
variety
of
compliance
options
available
for
in­
use
emergency
standby
engines,
depending
on
the
hours
of
operation
needed
for
maintenance
and
testing
and
the
emission
rate
of
the
engine.
Because
the
ATCM
requires
increasingly
more
stringent
performance
standards
with
increasing
hours
of
operation
for
maintenance
and
testing,
ARB
expects
that
many
operators
will
comply
with
the
requirements
by
adjusting
their
hours
for
maintenance
and
testing
to
a
level
where
additional
controls
are
unnecessary.
The
ARB
believes
that
the
majority
of
owners
of
emergency
standby
engines
will
be
able
to
limit
the
hours
for
maintenance
and
testing
and
avoid
installing
DECS.
However,
in
some
cases,
an
engine
with
a
lower
emissions
rate
will
require
the
installation
of
a
DOC
to
allow
routine
maintenance
and
testing.
In
other
situations,
particularly
for
engines
emitting
more
than
0.15
g/
bhp­
hr
that
require
over
30
hours
a
year
for
maintenance
and
testing,
the
owner
may
need
to
install
DPF
or
some
other
highly
effective
emission
control
device.
The
ARB
expects
that
for
in­
use
emergency
standby
engines,
90
percent
of
older
engines
operating
over
20
hours
per
year
will
reduce
hours
of
operation
to
below
20
hours
per
year
and
avoid
controls.
