  SEQ CHAPTER \h \r 1    

MEMORANDUM

DATE:		February 15, 2010

SUBJECT:	MACT Floor Determination for Existing Stationary Non-Emergency
CI RICE Less Than 100 HP and Existing Stationary Emergency CI RICE
Located at Major Sources and GACT for Existing Stationary CI RICE
Located at Area Sources

FROM:	Bradley Nelson and Tanya Parise, EC/R, Inc.

		

TO:		Melanie King, EPA OAQPS/SPPD/ESG

1.0	PURPOSE

The purpose of this memorandum is to document the analysis of the
maximum achievable control technology (MACT) floor and MACT for existing
stationary non-emergency compression ignition (CI) reciprocating
internal combustion engines (RICE) less than 100 horsepower (HP) and
existing stationary emergency and black start CI engines located at
major sources.  The generally achievable control technology (GACT) for
existing stationary CI RICE located at area sources of hazardous air
pollutants (HAP) emissions that are subject to National Emission
Standards for Hazardous Air Pollutants (NESHAP) is also presented in
this memorandum.  

The analysis for existing stationary non-emergency CI engines greater
than or equal to 100 HP located at major sources of hazardous air
pollutants (HAP) emissions is presented in a separate memorandum titled
“MACT Floor Determination for Existing Stationary Non-Emergency CI
RICE Greater Than or Equal 100 HP Located at Major Sources,” which is
available in the rulemaking docket (EPA-HQ-OAR-2008-0708).  

2.0	INTRODUCTION

The EPA has developed a regulation addressing toxic air emissions from
the following existing stationary CI RICE engines: 1) engines that are
located at area sources of HAP emissions; 2) engines that are less than
or equal to 500 HP and are located at major sources of HAP emissions;
and 3) non-emergency CI engines that are greater than 500 HP and are
located at major sources of HAP emissions.  The regulation was developed
following criteria set forth under section 112 of the Clean Air Act
(CAA).  Section 112(d) of the CAA stipulates that EPA must promulgate
emission standards that require the maximum degree of HAP reduction. 
According to 112(d)(3)(A) of the CAA, the emission standards for
existing major sources must be no less stringent than the average
emission limitation achieved by the best performing 12 percent of
existing sources for which the Administrator has emissions information. 
For existing area sources, EPA has the option under 112(d)(5) of the CAA
to promulgate emission standards or requirements GACT or management
practices in order to reduce HAP emissions.  The EPA has previously
issued a similar regulation affecting existing and new stationary RICE
greater than 500 HP at major sources, which was promulgated in 2004 and
for new stationary RICE less than or equal to 500 HP at major sources,
which was promulgated in 2008.

Section 112 of the CAA outlines the statutory requirements for the
EPA’s stationary source air toxics program.  Section 112(k) of the CAA
requires the development of standards for area sources which account for
90 percent of the emissions in urban areas of the 33 urban HAP listed in
the Integrated Urban Air Toxics Strategy (UATS).  These area source
standards can require control levels which are equivalent to either MACT
or GACT, as defined in the CAA under section 112(d)(2) and (3) and
section 112(d)(5), respectively.    

Section 112 of the CAA allows the EPA to establish subcategories among a
group of sources.  A complete discussion of the subcategory selection is
presented in a separate memorandum.  

3.0	MACT FLOOR AND MACT DETERMINATION

Non-Emergency CI Engines <100 HP

	For stationary CI engines less than 100 HP, EPA determined that it is
not feasible to prescribe or enforce an emission standard because the
application of measuring methodologies to this subcategory of engines is
not practicable due to technological and economic limitations.  In order
to measure the CO emissions from these engines in terms of volumetric
concentration on a dry basis and corrected to 15 percent oxygen (O2),
the following test methods are required:

EPA Method 1 or 1A for selection of sampling ports;

EPA Method 3, 3A, or 3B or ASTM Method D6522-00 (2005) for determining
the O2 concentration;

EPA Method 4 for measuring the moisture content; and

EPA Method 10 or ASTM Method D6522-00 (2005) for measuring the carbon
monoxide (CO) concentration.

The test methods require the sample point to be a certain distance
between the engine and the exhaust.  Because engines below 100 HP often
have exhaust pipes with very small diameters and lengths, stack testing
using these methods could require a modification or extension of the
exhaust pipe to accomplish the test.  Furthermore, the cost of
performing a stack test ranges from approximately $1,000-5,000 depending
on the method used.  Generally, 100 HP engines cost around $5,000-$7,000
and 50 HP engines cost approximately $4,000-$5,000, so the cost of
performance testing could approach the cost of the engine itself.  Given
the cost of the testing itself, the physical adjustments necessary to
accomplish the test, and the particular circumstances pertaining to
engines below 100 HP, EPA believes that the application of measurement
methodology to this class of engines is not practicable due to
technological and economic limitations.  Therefore, work practices are
the MACT floor for existing stationary non-emergency CI engines less
than 100 HP.

To determine the work practices, EPA reviewed information obtained from
different manufacturers and operators of CI engines.  The EPA has
determined that the maximum achievable control, based on the work
practices of the best controlled engines, is to maintain and replace the
following stationary engine components:  oil and oil filter, air
cleaner, hoses, and belts.  According to information received from
manufacturers and operators of stationary engines, these parameters are
the most appropriate to ensure proper operation for minimizing HAP
emissions.  Each of these work practices limit HAP emissions by allowing
the engine to operate at peak efficiency.  Changing the oil and oil
filter reduces the wear on the pistons and cylinders and limits the
amount on worn metals that may be introduced to the exhaust stream. 
Inspecting the air filter limits the introduction of oil mist and other
contaminants to the combustion chamber.  Inspecting the belts and hoses
ensures that the engines cooling and electrical systems are operating,
therefore eliminating the burning of oil and ensuring that the
electrical systems are functioning as intended.

Intervals for checking, inspecting and replacing the oil and oil filter,
air cleaner, hoses, and belts vary with engine makes and models,
application, location, and other factors, therefore making it difficult
to define specific maintenance intervals that would be represent the
operation of the best controlled engines.  However, EPA must promulgate
specific requirements pursuant to section 112(d) of the CAA and the
information indicates that there are commonalities in maintenance
interval frequencies for the best controlled engines.  Based on the
information provided, EPA believes that the work practices below are
what the best controlled existing stationary non-emergency CI engines
less than 100 HP are currently doing and for that reason the MACT floor
for these engines is work practices as follows:

changing the oil and oil filter every 1,000 hours of operation or
annually, whichever comes first;  

inspecting the air cleaner every 1,000 hours of operation or annually,
whichever comes first; and

inspecting all hoses and belts and replacing as necessary every 500
hours of operation or annually, whichever comes first. 

	As discussed above, current maintenance procedures vary from engine to
engine based on a number of factors including engine design, fuel,
operating characteristics, and so on.  Maintaining the oil however, is,
one of the most important activities operators can perform to minimize
emissions and to ensure proper operation and performance.  

	In addition to following a set schedule for checking and replacing the
oil, it is also common that the oil is monitored through an oil analysis
program where the oil is periodically sampled to determine oil quality. 
Based on the oil sample that is extracted, an oil analysis can be
performed that can indicate if it is time to replace the oil or if the
existing oil has not reached condemning limits it can continue to be
used.  Based on the analysis a decision can be made whether to drain and
replace the oil or if the oil change interval can be extended if the
properties of the oil are within acceptable limits.  Appropriate
parameters and condemning limits that would indicate oil degradation and
the presence and quantity of contaminants varies.  However, EPA has
determined that the parameters that would most appropriately indicate
the oil quality are the total base number (TBN), viscosity, and water
content.  The TBN is an indication of the alkalinity of the oil and the
viscosity of the oil is a measure of how well the oil flows and these
parameters are, along with water content, measures of the condition of
the oil.  If the following levels below as measured through an oil
analysis program are exceeded, EPA has determined that an oil change
must be performed:

TBN is less than 30 percent of the TBN of the oil when new; or

viscosity of the oil has changed by more than 20 percent from the
viscosity of the oil when new; or

percent water content (by volume) is greater than 0.5. 

	No other regulatory options beyond the MACT floor were identified as
appropriate for existing stationary non-emergency CI engines below 100
HP.  Therefore, MACT for HAP emissions is equivalent to the MACT floor
for these engines.   

Emergency CI Engines	

	For existing stationary CI emergency engines located at major sources,
EPA determined it is not feasible to prescribe or enforce an emission
standard because the application of measurement methodology to this
class of engine is impracticable due to the technological and economic
limitations.  Emergency engines typically only operate during
emergencies or during periods of routine testing and maintenance.  EPA
determined that application of the emissions measurement methodologies
during either of these periods is not practicable.  It is impracticable
to test emissions from stationary CI emergency engines during periods of
routine testing and maintenance using the test procedures specified in
the rule because it would increase the required number of hours of
operation of the engine beyond the routinely scheduled reliability
testing and maintenance operation, thereby increasing emissions.  While
emergency engines have periods of operation for scheduled maintenance
and reliability testing, those periods are usually several hours shorter
than the number of hours that would be required to run the necessary
emissions tests under subpart ZZZZ.  CARB conducted a survey of
stationary emergency diesel engines in 2002 to determine the average
number of hours that stationary emergency diesel engines operate.  The
average hours of operation for maintenance and testing were 22 hours per
year, which is less than two hours per month.  For the engines that CARB
surveyed, 86 percent operated less than 30 hours/year for testing and
maintenance.  Thirty percent operated less than 10 hours/year.  National
Fire Protection Association (NFPA) codes require 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.  It is also
impracticable to apply the testing methodologies required in this rule
to test the stationary engines during periods of emergency operation
because emergencies are unplanned events and and implementation of the
procedures specified in subpart ZZZZ require advance planning before
tests are conducted.  In an emergency, the owner/operator does not have
the advance planning time necessary to implement subpart ZZZZ.  It is
also impracticable to test stationary CI emergency engines at major
sources because of the large population of these engines.  EPA estimates
that there are over 200,000 existing stationary CI emergency engines
from 100-500 HP at major sources that are subject to this rulemaking. 
There are only approximately 300-400 testing firms and these stationary
engines are not the only sources that are required to be tested, so if
testing were required for these engines, it would take many years to
test all of these engines.  The cost for testing all of these engines
would be in excess of $200 million and would clearly also be
unreasonable.  

For these reasons, work practices are appropriate and justified for this
group of stationary engines because the application of measurement
methodology is not practicable due to technological and economic
limitations.  Consequently, work practices are the MACT floor for
existing stationary emergency CI engines located at major sources.  

Again, in order to determine the work practices for stationary emergency
engines at major sources, EPA reviewed information obtained from
different manufacturers and operators of CI engines.  For the same
reasons as discussed above for existing stationary non-emergency engines
less than 100 HP at major sources, EPA has determined that maximum
achievable control, based on the work practices of the the best
controlled emergency engines, is to maintain and replace the following
stationary engine components:  oil and oil filter, air cleaner, hoses,
and belts.  EPA discussed above the effect that maintaining these
parameters have on HAP emissions.  

As stated, intervals for checking, inspecting and replacing these
components vary from engine to engine and determining specific
maintenance intervals that would be represent the operation of the best
controlled emergency engines is challenging.  However, EPA must
promulgate specific requirements pursuant to section 112(d) of the CAA
and the information indicates that there are commonalities in
maintenance interval frequencies for the best controlled engines.  Based
on the information provided, EPA believes that the below maintenance
practices are what the best controlled existing stationary emergency CI
engines are currently doing and for that reason, the MACT floor for
these engines is maintenance practices as follows:

changing the oil and oil filter every 500 hours of operation or
annually, whichever comes first; 

inspecting the air cleaner every 1,000 hours of operation or annually,
whichever comes first; and

inspecting all hoses and belts and replacing as necessary every 500
hours of operation or annually, whichever comes first. 

The changing of oil and the oil filter for stationary emergency engines
is more frequent on an hourly basis than for non-emergency engines
because of the nature of operation of these engines, which is for
standby and intermittent use, and thus requires less hourly use over the
same period of time, and oil quality is reduced over time even during
periods when the engine is not used.  

	Emergency CI engines also have the option to use an oil analysis
program to indicate if it is time to replace the oil or if the existing
oil has not reached condemning limits it can continue to be used.  The
provisions of the oil analysis program are the same discussed above for
non-emergency CI engines <100 HP.

 No other regulatory options beyond the MACT floor were identified as
appropriate for existing stationary emergency CI engines at major
sources.  Because these engines are typically used only a few number of
hours per year, the costs of emission control are not warranted when
compared to the emission reductions that would be achieved.  The cost
per ton estimates for stationary emergency CI engines can be found in
the memorandum entitled “Cost per Ton of HAP Reduced for Existing
Stationary CI RICE” in the rulemaking docket (EPA-HQ-OAR-2008-0708). 
Therefore, MACT for HAP emissions is equivalent to the MACT floor for
these engines.

Black Start Engines

	Black start engines are used solely to start up combustion turbines. 
They operate for very short durations and have the same issues as
emergency CI engines based on their unique and limited operation. 
According to information received during the public comment period,
black start engines typically operate no more than 10 minutes at a time
and only operate during emergencies or during periods of high demand
(see for example EPA-HQ-OAR-2008-0708-0088 and 0129).  The short time of
operation makes testing of black start engines using the required
procedures impracticable.  Therefore, work practices are the MACT floor
for existing stationary black start engines located at major sources and
are as follows:  

changing the oil and oil filter every 500 hours of operation or
annually, whichever comes first, with the option to use an oil analysis
program as discussed above; 

inspecting the air cleaner every 1,000 hours of operation or annually,
whichever comes first; and

inspecting all hoses and belts and replacing as necessary every 500
hours of operation or annually, whichever comes first. 

As with stationary emergency CI engines, no other regulatory options
beyond the MACT floor were identified as appropriate for existing
stationary black start engines at major sources.  The limited operating
time also makes applying aftertreatment to black start engines not
effective.  In addition, these engines operate a few hours per year,
making further regulation of these engines economically impractical. 
Therefore, MACT is equivalent to the MACT floor for these engines.

4.0	GACT DETERMINATION

Under CAA section 112(d)(5), EPA may elect to promulgate standards or
requirements for area sources "which provide for the use of generally
available control technologies or management practices by such sources
to reduce emissions of hazardous air pollutants."  Additional
information on generally available control technologies (GACT) or
management practices is found in the Senate report on the legislation
(Senate report Number 101-228, December 20, 1989), which describes GACT
as:

. . . methods, practices and techniques which are commercially available
and appropriate for application by the sources in the category
considering economic impacts and the technical capabilities of the firms
to operate and maintain the emissions control systems.

	 

Determining what constitutes GACT involves considering the control
technologies and management practices that are generally available to
the area sources in the source category.  EPA also considers the
standards applicable to major sources in the same industrial sector to
determine if the control technologies and management practices are
transferable and generally available to area sources.  In appropriate
circumstances, EPA may also consider technologies and practices at area
and major sources in similar categories to determine whether such
technologies and practices could be considered generally available for
the area source category at issue.  Finally, as EPA has already noted,
in determining GACT for a particular area source category, EPA considers
the costs and economic impacts of available control technologies and
management practices on that category.  

Emergency CI 

For existing stationary emergency CI engines located at area sources,
EPA believes that it is appropriate to set GACT to be the same
requirements as is required for emergency engines at major sources
because the same issues that were discussed above for stationary
emergency CI engines at major sources apply to emergency CI engines at
area sources.  There is no reason why the requirements for engines
located at area sources pursuant to GACT should be different than those
for engines located at major sources.  The management practices are
generally available and being located at an area source does not prevent
the engine from being maintained appropriately and according to how
engines at major sources are being maintained.  Further, the management
practices do not present an economic burden on area source engines and
are for that reason also considered appropriate.  Therefore, GACT for
existing stationary emergency CI engines at area sources is the use of
management practices as follows:

changing the oil and oil filter every 500 hours of operation or
annually, whichever comes first, with an option to use an oil analysis
program as discussed above; 

inspecting the air cleaner every 1,000 hours of operation or annually,
whichever comes first; and

inspecting all hoses and belts and replacing as necessary every 500
hours of operation or annually, whichever comes first. 

Black Start Engines

For existing stationary black start engines located at area sources, EPA
believes that it is appropriate to set GACT to be the same requirements
as is required for black start engines at major sources because the same
issues that were discussed above for stationary black start engines at
major sources apply to these engines at area sources.  There is no
reason why the requirements for area sources pursuant to GACT should be
different than those for black start engines at major sources. 
Therefore, GACT for existing stationary emergency CI engines at area
sources is the use of management practices as follows:

changing the oil and oil filter every 500 hours of operation or
annually, whichever comes first, with an option to use an oil analysis
program as discussed above; 

inspecting the air cleaner every 1,000 hours of operation or annually,
whichever comes first; and

inspecting all hoses and belts and replacing as necessary every 500
hours of operation or annually, whichever comes first. 

Non-Emergency CI <100 HP

For existing stationary non-emergency CI engines less than 100 HP
located at area sources, EPA believes that it is appropriate to set GACT
to be the same requirements as is required for non-emergency CI engines
less than 100 HP at major sources because the same issues that were
discussed above for stationary non-emergency CI engines less than 100 HP
at major sources apply to non-emergency CI engines less than 100 HP at
area sources.  There is no reason why the requirements for engines
located at area sources pursuant to GACT should be different than the
requirements for engines located at major sources.  Therefore, GACT for
existing stationary non-emergency CI engines less than 100 HP at area
sources is the use of management practices as follows:

changing the oil and oil filter every 1,000 hours of operation or
annually, whichever comes first, with an option to use an oil analysis
program as discussed above;  

inspecting the air cleaner every 1,000 hours of operation or annually,
whichever comes first; and

inspecting all hoses and belts and replacing as necessary every 500
hours of operation or annually, whichever comes first. 

CI 100≤HP≤300

For existing stationary non-emergency engines between 100 HP and 300 HP,
EPA determined that management practices were appropriate for GACT. 
Although add-on controls are technically feasible for these engines
located at area sources, control costs are high and EPA believes that it
is possible to achieve reasonable controls using management practices. 
For example, capital costs associated with installing an oxidation
catalyst on a 200 HP diesel engine are about $4,500 with annual costs of
$1,500.  Such costs are significant particularly when one considers that
the cost per ton of this option is as high as $265,000 per ton of HAP
reduced for some engines.  EPA has estimated that there are over 64,000
existing stationary non-emergency engines between 100 HP and 300 HP
located at area sources.  The impacts of requiring add-on controls on
these engines would be more than $320 million for equipment costs alone
and total yearly costs would be more than $105 million, not including
associated costs such as monitoring, testing, reporting, and
recordkeeping that would be necessary in order to ensure compliance with
an emission standard.  For more information on the cost per ton of HAP
reduced, please refer to the memorandum entitled “Cost per Ton of HAP
Reduced for Existing Stationary CI RICE” in the rulemaking docket
(EPA-HQ-OAR-2008-0708).

Furthermore, EPA is attempting to minimize the burden of the proposed
rule, specifically on small businesses and individual owners and
operators.  EPA does not believe that management practices would be a
substantial burden on owners and operators such as home owners and small
entities.  Additionally, the cumulative testing cost that would be
associated with requiring existing non-emergency CI engines between 100
HP and 300 HP at area sources to meet a numerical emission limitation
would be in the vicinity of $37 million.  In addition, there would be
other associated costs with demonstrating compliance with a numerical
emission limit, such as notification and reporting requirements. 
Finalizing the same numerical emission limit consistent with the
emission limit finalized for existing non-emergency CI engines between
100 HP and 300 HP at major sources would have possibly resulted in some
existing area source engines having to install aftertreatment. 
Purchasing, installing and operating add-on controls would lead to even
further costs, increasing the total burden on these sources.  For
example, assuming that 35 percent of existing stationary non-emergency
CI engines between 100 HP and 300 HP located at area sources would have
to install and operate aftertreatment controls in order to comply with a
numerical emission limit, capital and annual costs would add an
additional $100 million in capital costs and $37 million yearly for
operation and maintenance of the control device.  EPA believes these
costs are excessive and not justified in comparison to the amount of
pollutant that would be reduced with requiring a numerical emission
limit as was done for the same engines at major sources.

Consequently, GACT for existing stationary non-emergency CI engines
between 100 HP and 300 HP at area sources is the use of management
practices as follows:

changing the oil and oil filter every 1,000 hours of operation or
annually, whichever comes first, with an option to use an oil analysis
program as discussed above;  

inspecting the air cleaner every 1,000 hours of operation or annually,
whichever comes first; and

HP≤500

For subcategories of existing stationary non-emergency CI engines
greater than 300 HP, EPA believes that oxidation catalyst is readily
available and feasible for all existing stationary non-emergency CI
engines above 300 HP generally regardless of location.  Further, EPA has
determined that costs associated with implementing HAP-reducing
technologies are reasonable and justified. In addition, it is estimated
that the benefits per ton are between $330,000 (Pope, 7%) and $790,000
(Laden, 7%) for PM2.5 for existing stationary CI engines at area
sources.  For more information on the benefits per ton of PM2.5 emission
reductions, please refer to the Regulatory Impact Analysis for the final
rule, available in the docket.  The benefits per ton outweigh the costs.
 Further information on the specific add-on control costs and cost per
ton estimates can be found in the memorandum “Cost per Ton of HAP
Reduced for Existing Stationary CI RICE,” available from the docket
(EPA-HQ-OAR-2008-0708).  Therefore, EPA has determined that GACT should
be based on the use of oxidation catalysts for existing stationary
non-emergency CI engines greater than 300 HP and less than or equal to
500 HP that are located at area sources.  For existing stationary
non-emergency CI engines greater than 300 HP and less than or equal to
500 HP located at area sources, GACT for HAP emissions was therefore
determined to be 49 parts per million by volume dry basis (ppmvd) at 15
percent O2 or the reduction of CO by 70 percent.

In addition, in order to provide further reduction in metallic HAP
emissions from non-emergency engines between 300 HP and 500 HP at area
sources, EPA believes GACT should include the same requirements for
further reduction in crankcase emissions as was required for such
engines at major sources.  The rationale for promulgating such
requirements for such engines at major sources is found in the preamble
and Response to Comments document for this rule and in the memorandum
titled “MACT Floor Determination for Existing Stationary Non-Emergency
CI RICE Greater Than or Equal 100 HP Located at Major Sources,” which
is available in the rulemaking docket (EPA-HQ-OAR-2008-0708).  

Therefore, GACT for non-emergency CI engines between 300 HP and 500 HP
that are located at area sources includes the following requirement: 1)
install a closed crankcase ventilation system that prevents crankcase
emissions from being emitted to the atmosphere, or 2) install an open
crankcase filtration emission control system that reduces the crankcase
emissions by filtering the exhaust stream to remove oil mist,
particulates, and metals.

Non-Emergency CI >500 HP

For stationary non-emergency CI engines greater than 500 HP, EPA
believes that oxidation catalyst technology is readily available and
feasible for all existing stationary non-emergency CI engines above 500
HP generally regardless of location.  Further, EPA has determined that
costs associated with implementing HAP-reducing technologies are
reasonable and justified.  In addition, it is estimated that the
benefits per ton are between $330,000 (Pope, 7%) and $790,000 (Laden,
7%) for PM for existing stationary CI engines at area sources.  The
benefits per ton outweigh the costs.  Further information on the
monetized benefits and the specific add-on control costs and cost per
ton estimates can be found in the memorandum “Cost per Ton of HAP
Reduced for Existing Stationary CI RICE,” available from the docket as
(EPA-HQ-OAR-2008-0708).  Therefore, EPA has determined that GACT should
be based on the use of oxidation catalysts for existing stationary
non-emergency CI engines greater than 500 HP that are located at area
sources.   Therefore, for existing stationary non-emergency CI engines
greater than 500 HP located at area sources, GACT for HAP emissions is
23 ppmvd of CO at 15 percent O2 or the reduction of CO by 70 percent.

Again, in order to provide further reduction in metallic HAP emissions
from non-emergency engines greater than 500 HP, EPA believes GACT should
include the same requirements for further reduction in crankcase
emissions as was required for such engines at major sources.  Therefore,
GACT for non-emergency CI engines greater than 500 HP that are located
at area sources includes the following: 1) install a closed crankcase
ventilation system that prevents crankcase emissions from being emitted
to the atmosphere, or 2) install an open crankcase filtration emission
control system that reduces the crankcase emissions by filtering the
exhaust stream to remove oil mist, particulates, and metals.

CI Engines Located in Rural Areas of Alaska not accessible by FAHS

For CI engines less than or equal to 300 HP located in remote areas of
Alaska, EPA has determined that GACT is management practices.  However,
GACT for other existing stationary non-emergency CI engines greater than
300 HP located at area sources is based on the use of add-on controls
and requires either compliance with a concentration or a percent
reduction standard.  Non-emergency CI engines greater than 300 HP that
are located in area of Alaska not accessible by the Federal Air Highway
System (FAHS), due to issues related to fuel availability and cost,
location of sources, and colder weather conditions, to name a few, face
unique challenges.  Therefore, EPA believes it is not appropriate to set
the same standards as for non-emergency CI engines greater than 300 HP
at other area sources.  Therefore, GACT for non-emergency CI engines
greater than 300 HP that are located in area of Alaska not accessible by
FAHS is management practices as follows:

changing the oil and oil filter every 1,000 hours of operation or
annually, whichever comes first, with an option to use an oil analysis
program as discussed above;  

inspecting the air cleaner every 1,000 hours of operation or annually,
whichever comes first; and

inspecting all hoses and belts and replacing as necessary every 500
hours of operation or annually, whichever comes first. 



Appendix A

Existing Stationary CI Engine Test Data Summary	Test Date	Engine Number
Engine Size (HP)	Test Method Used	CO Concentration (ppmvd @ 15% O2)
Comments

Test Facility



	Average 	Run 1	Run 2	Run 3

	Santa Barbara County Air Pollution Control District	1/22/2009	East
Crane 3	160	CARB 100	479.8	496.4	497.5	445.4	 

Santa Barbara County Air Pollution Control District	1/22/2009	West Crane
1	160	CARB 100	222.9	221.3	217.5	229.9	 

Santa Barbara County Air Pollution Control District	1/20/2009	East Crane
1	450	CARB 100	129.6	124.2	127.5	137.2	 

Santa Barbara County Air Pollution Control District	1/21/2009	East Crane
2	450	CARB 100	154.4	140.3	160.2	162.7	 

Precision Power	7/27/2005	Engine 1	550	EPA Method 10	45.6	46.6	45.0	45.1
100% load

Precision Power	7/29/2005	Engine 2	550	EPA Method 10	90.9	93.5	90.4	88.8
25% load

Precision Power	7/29/2005	Engine 2	550	EPA Method 10	57.7	56.6	58.8	57.5
50% load

Precision Power	7/29/2005	Engine 2	550	EPA Method 10	41.6	42.5	41.0	41.4
75% load

Precision Power	7/27/2005	Engine 2	550	EPA Method 10	23.5	23.7	23.7	23.0
100% load

Precision Power	7/28/2005	Engine 3	550	EPA Method 10	82.8	62.0	93.5	92.9
25% load, Arctic fuel

Precision Power	7/28/2005	Engine 3	550	EPA Method 10	59.9	59.3	58.3	62.3
50% load, Arctic fuel

Precision Power	7/28/2005	Engine 3	550	EPA Method 10	39.5	40.8	39.7	37.8
75% load, Arctic fuel

Precision Power	7/28/2005	Engine 3	550	EPA Method 10	42.8	41.6	44.3	42.4
100% load, Arctic fuel

Precision Power	7/26/2005	Engine 3	550	EPA Method 10	42.3	41.9	43.7	41.2
100% load

Precision Power	7/26/2005	Engine 4	550	EPA Method 10	28.9	25.6	23.2	38.0
100% load

CSU-Engines & Energy Conversion Laboratory	9/2/1999	Caterpillar 3508
1000	EPA Method 10	76.8	76.8	 	 	70% load

CSU-Engines & Energy Conversion Laboratory	9/1/1999	Caterpillar 3508
1000	EPA Method 10	44.1	44.1	 	 	70% load

CSU-Engines & Energy Conversion Laboratory	8/31/1999	Caterpillar 3508
1000	EPA Method 10	43.5	43.5	 	 	100% load

CSU-Engines & Energy Conversion Laboratory	8/31/1999	Caterpillar 3508
1000	EPA Method 10	41.6	41.6	 	 	100% load

CSU-Engines & Energy Conversion Laboratory	9/1/1999	Caterpillar 3508
1000	EPA Method 10	42.7	42.7	 	 	100% load

CSU-Engines & Energy Conversion Laboratory	8/31/1999	Caterpillar 3508
1000	EPA Method 10	45.2	45.2	 	 	100% load

CSU-Engines & Energy Conversion Laboratory	8/31/1999	Caterpillar 3508
1000	EPA Method 10	44.1	44.1	 	 	100% load

CSU-Engines & Energy Conversion Laboratory	9/1/1999	Caterpillar 3508
1000	EPA Method 10	41.6	41.6	 	 	100% load

CSU-Engines & Energy Conversion Laboratory	9/1/1999	Caterpillar 3508
1000	EPA Method 10	76.2	76.2	 	 	70% load

CSU-Engines & Energy Conversion Laboratory	8/31/1999	Caterpillar 3508
1000	EPA Method 10	39.8	39.8	 	 	100% load

Badami Development Facility	6/26/2003	Generator 2	1680	EPA Method 10
327.1	330.3	330.1	320.8	75% load

Badami Development Facility	6/26/2003	Generator 2	1680	EPA Method 10
265.4	267.2	263.7	265.1	100% load

Badami Development Facility	6/26/2003	Generator 2	1680	EPA Method 10
196.9	182	200	209	50% load

Badami Development Facility	6/25/2003	Generator 2	1680	EPA Method 10
77.7	77.8	74.9	80.3	25% load

Northstar Development Project - BP	7/8/2004	Engine 6	3570	EPA Method 10
69.4	69.2	69.2	69.9	Low load

Northstar Development Project - BP	7/8/2004	Engine 6	3570	EPA Method 10
54.9	55.8	54.2	54.6	High load

Northstar Development Project - BP	7/9/2004	Engine 6	3570	EPA Method 10
55.5	56.7	54.9	54.8	Mid load

Northstar Development Project - BP	7/9/2004	Engine 7	3570	EPA Method 10
142.9	142.9

	Mid load

Northstar Development Project - BP	7/9/2004	Engine 7	3570	EPA Method 10
131.1	126.5	132.1	134.8	High load

Northstar Development Project - BP	7/9/2004	Engine 7	3570	EPA Method 10
127.8	127.8	 	 	Low load



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愀Ȥ摧૗¦ᜀ(see EPA-HQ-OAR-2008-0708).  

 California 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.  

E C/R Incorporated	Providing Environmental Technical Support Since 1989



	

501 Eastowne Drive, Suite 325  (  Chapel Hill, North Carolina 27514

Telephone:  (919) 484-0222  (  Fax:  (919) 484-0122

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E C/R Incorporated	Providing Environmental Technical Support Since 1989



	

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