1
MEMORANDUM
DATE:
June
20,
2005
SUBJECT:
Emission
Standards
for
Engines
with
a
Displacement
of
10­
30
Liters
per
Cylinder,
Engines
>
3,000
HP,
and
Engines
with
a
Displacement
of
 
30
Liters
per
Cylinder
FROM:
Melanie
Taylor,
Alpha­
Gamma
Technologies,
Inc.

TO:
Sims
Roy,
EPA
OAQPS
ESD
Combustion
Group
The
purpose
of
this
memorandum
is
to
provide
the
rationale
used
by
EPA
to
set
the
emission
standards
for
engines
with
a
displacement
between
10
and
30
liters
per
cylinder,
engines
above
3,000
horsepower
(
HP),
and
engines
with
a
displacement
of
30
liters
per
cylinder
or
more
in
the
proposed
new
source
performance
standards
(
NSPS)
for
stationary
compression
ignition
(
CI)
internal
combustion
engines.
During
the
development
of
the
proposed
NSPS,
EPA
met
with
the
Engine
Manufacturers
Association
(
EMA)
and
the
European
Association
of
Internal
Combustion
Engine
Manufacturers
(
Euromot)
to
obtain
information
about
stationary
CI
engines
and
discuss
draft
concepts
for
the
NSPS.

Members
of
EMA
indicated
to
EPA
that
in
many
cases
the
engine
manufacturers
sell
the
same
CI
engines
for
use
in
mobile
nonroad
equipment
as
those
used
in
stationary
applications.
Based
on
this
information,
EPA
considered
the
option
of
requiring
engine
manufacturers
to
certify
2007
model
year
(
MY)
and
later
stationary
CI
engines
to
the
emission
standards
for
nonroad
diesel
engines
in
the
NSPS.
The
EPA
briefed
EMA
on
February
2,
2005
regarding
the
requirements
that
EPA
was
considering
for
the
proposed
NSPS.
Subsequent
to
the
February
meeting,
EMA
submitted
recommendations
to
EPA
for
the
proposed
NSPS
on
March
10,
2005.
A
meeting
between
EPA
and
EMA
was
held
on
March
23,
2005
in
order
to
discuss
EMA's
comments
to
EPA.
The
EPA
also
held
a
meeting
with
Euromot
on
March
22,
2005
to
discuss
the
proposed
NSPS.
Both
groups
had
concerns
about
potentially
requiring
larger
size
stationary
CI
engines
to
meet
the
standards
for
nonroad
diesel
engines,
as
discussed
in
more
detail
in
the
following
sections.

Engines
with
a
Displacement
10­
30
Liters
per
Cylinder
The
EMA
recommended
in
their
March
10,
2005
comments
that
EPA
require
stationary
CI
engines
with
a
displacement
of
10
liters
per
cylinder
or
more
to
certify
to
the
EPA
2
Tier
2
standards
for
marine
diesel
engines,
rather
than
the
standards
for
nonroad
diesel
engines.
According
to
EMA,
these
stationary
CI
engines
are
not
used
in
nonroad
applications;
they
are
more
similar
to
engines
used
in
marine
applications
and
are
operated
differently
than
nonroad
engines.
The
EMA
members
do
not
produce
any
stationary
CI
engines
with
a
displacement
of
10
liters
per
cylinder
or
more
that
are
certified
to
the
nonroad
standards.
Furthermore,
according
to
information
submitted
by
EMA
to
EPA
on
April
28,
2005,
the
number
of
stationary
CI
engines
with
a
displacement
of
10
liters
per
cylinder
or
more
produced
each
year
is
small;
only
three
manufacturers
provide
these
engines,
and
combined
they
sell
about
eight
per
year
for
stationary
applications
in
the
U.
S.
Based
on
the
information
provided
by
EMA,
the
EPA
decided
that
it
would
be
appropriate
to
require
these
engines
to
meet
the
EPA
standards
for
marine
engines.
The
EPA
may
promulgate
Tier
4
marine
standards
in
the
future
and
will
investigate
whether
those
standards
would
be
appropriate
for
stationary
CI
engines
with
a
displacement
of
10
liters
per
cylinder
or
more.
Note
that
EPA
is
proposing
different
requirements
for
engines
with
a
displacement
of
30
liters
per
cylinder
or
more,
as
discussed
further
below.

Engines
>
3,000
HP
The
EMA
also
commented
on
EPA's
possible
requirement
that
manufacturers
of
stationary
CI
engines
above
3,000
HP
certify
the
engines
to
the
Tier
2
nonroad
diesel
engine
standards
beginning
in
2007.
According
to
EMA,
these
engines
are
infrequently
used
in
nonroad
applications,
and
manufacturers
do
not
have
enough
time
to
adapt
these
engines
to
meet
the
Tier
2
nonroad
standards
by
2007.
Members
of
EMA
said
that
for
nonroad
CI
engines
of
this
size,
manufacturers
made
the
decision
to
not
do
Tier
2
standards,
because
they
had
generated
enough
credits
through
the
averaging,
banking,
and
trading
program
allowing
them
to
skip
Tier
2.
However,
engine
manufacturers
would
not
have
additional
remaining
credits
to
do
the
same
for
stationary
engines.
The
EMA
recommended
that
EPA
allow
these
stationary
engines
to
be
certified
to
the
Tier
1
nonroad
diesel
engine
standards
beginning
in
2007,
and
then
the
Tier
4
standards
beginning
in
2011
(
which
is
when
they
begin
for
nonroad
engines).
The
EMA
indicated
that
the
total
number
of
stationary
CI
engines
above
3,000
HP
sold
in
the
U.
S.
per
year
is
approximately
160.
This
excludes
the
number
above
10
liters
per
cylinder
displacement.
The
EPA
determined
based
on
the
information
provided
by
EMA
that
it
would
be
appropriate
to
require
engine
manufacturers
to
certify
stationary
CI
engines
over
3,000
HP
to
the
Tier
1
nonroad
diesel
engine
standard
for
2007­
2010
MY
engines
and
the
Tier
4
nonroad
diesel
engine
standard
beginning
with
2011
MY
engines.

Engines
with
a
Displacement
 
30
Liters
per
Cylinder
The
EPA
also
met
with
Euromot
to
discuss
the
proposed
NSPS.
One
concern
raised
by
Euromot
during
the
meeting
was
the
inability
of
very
large
stationary
CI
engines
to
meet
the
EPA
emission
standards
for
nonroad
diesel
engines.
According
to
Euromot,
these
engines
cannot
use
the
same
emission
control
technologies
as
nonroad
engines,
for
example
diesel
particulate
filter
and
exhaust
gas
recirculation,
due
to
their
large
size.
3
These
large
engines
tend
to
operate
several
thousands
of
hours
per
year
and
at
constant
speed
and
load
as
opposed
to
nonroad
engines
that
normally
operate
for
a
few
hundred
hours
per
year
and
often
at
transient
conditions.
These
large
engines
are
not
produced
in
mass
quantities,
and
if
any,
only
a
few
may
be
installed
in
the
U.
S.
per
year.
For
these
reasons,
EPA
feels
it
is
more
appropriate
to
regulate
the
owners
and
operators
of
these
engines
and
is
not
requiring
manufacturers
to
certify
these
engines.
The
proposed
NSPS
will
require
owners
and
operators
of
stationary
CI
engines
with
a
displacement
of
greater
than
or
equal
to
30
liters
per
cylinder
to
reduce
nitrogen
oxides
(
NOx)
emissions
by
90
percent
or
more,
or
alternatively
they
must
limit
the
emissions
of
NOx
in
the
stationary
CI
internal
combustion
engine
exhaust
to
0.40
grams
per
kilowatthour
(
KW­
hr)
(
0.30
grams
per
HP­
hour).
Owners
and
operators
of
stationary
CI
engines
with
a
displacement
of
greater
than
or
equal
to
30
liters
per
cylinder
will
also
be
required
to
reduce
particulate
matter
(
PM)
emissions
by
60
percent
or
more,
or
alternatively
they
must
limit
the
emissions
of
PM
in
the
stationary
CI
internal
combustion
engine
exhaust
to
0.12
grams
per
KW­
hour
(
0.09
grams
per
HP­
hour).

The
emission
reduction
requirement
of
90
percent
or
more
for
NOx
is
based
on
the
reduction
capabilities
of
selective
catalytic
reduction
(
SCR),
which
can
reduce
NOx
emissions
by
more
than
90
percent
from
stationary
CI
engines.
The
NOx
limit
of
0.40
grams
per
KW­
hr
is
based
on
the
NOx
limits
set
by
both
the
World
Bank
and
the
United
Kingdom
for
large
diesel
engines.
Capital
and
operating
and
maintenance
costs
associated
with
SCR
are
high,
however,
EPA
feels
the
high
cost
of
SCR
is
justified
when
installed
and
operated
with
engines
of
significantly
higher
size
and
cost
than
nonroad
and
other
stationary
engines.
A
facility
with
such
large
engines
will
generally
have
the
resources
to
implement
and
justify
expensive
add­
on
controls.
Furthermore,
power
plant
facilities
typically
have
permit
conditions
that
require
significant
emissions
reductions.

The
requirement
of
60
percent
PM
control
or
more
is
based
on
the
capabilities
of
electrostatic
precipitator
(
ESP).
Information
EPA
has
received
from
Euromot
shows
that
60
to
70
percent
PM
reduction
is
possible
with
ESP
control.
The
PM
emission
standard
of
0.12
grams
per
KW­
hour
is
based
on
information
provided
by
vendors
of
ESP,
who
indicated
that
the
technology
is
capable
of
achieving
that
level
for
oil­
fired
combustion
sources.
The
EPA
believes
the
emission
reduction
levels
proposed
are
appropriate
for
engines
of
high
displacement.
4
References
Summary
of
Meeting
with
the
Engine
Manufacturers
Association
Regarding
the
CI
NSPS,
February
2,
2005.

EMA
Comments
and
Recommendations
on
NSPS
Program.
Email
from
Joe
Suchecki,
Engine
Manufacturers
Association
to
Sims
Roy,
EPA.
March
10,
2005.

Summary
of
Meeting
with
the
European
Association
of
Internal
Combustion
Engine
Manufacturers
Regarding
NSPS
for
CI
Stationary
RICE,
March
22,
2005.

Summary
of
Meeting
with
the
Engine
Manufacturers
Association
Regarding
the
CI
NSPS,
March
23,
2005.

Information
on
Stationary
Engines.
Email
from
Joe
Suchecki,
Engine
Manufacturers
Association
to
Sims
Roy,
EPA.
April
28,
2005.
