  SEQ CHAPTER \h \r 1    

MEMORANDUM

DATE:		February 17, 2010

SUBJECT:	Impacts Associated with NESHAP for Existing Stationary CI RICE

FROM:	Bradley Nelson, EC/R, Inc.

		

TO:		Melanie King, EPA OAQPS/SPPD/ESG

1.0	PURPOSE

The purpose of this memorandum is to provide an estimate of the cost
impacts and the emission reductions of the National Emission Standards
for Hazardous Air Pollutants (NESHAP) for existing compression ignition
(CI) stationary reciprocating internal combustion engines (RICE).  The
regulation applies to existing stationary CI RICE located at major and
area sources of hazardous air pollutants (HAP) emissions.  It is
estimated that 40 percent of stationary CI RICE are located at major
sources and 60 percent of stationary CI RICE are located at area
sources.  Impacts discussed in this memorandum include emissions
reductions and total costs associated with regulatory requirements.
Costs associated with the rule include the capital and annual cost of
purchasing and operating air pollution control equipment, recordkeeping,
and performance testing.  

The total capital cost associated with the NESHAP for existing
stationary CI RICE is estimated to be $744 million in the year 2013. 
The total annual cost of the NESHAP is estimated to be $373 million in
the year 2013.  The NESHAP for existing stationary RICE is estimated to
reduce HAP emissions in the year 2013 by 1,014 tons per year (TPY). 

2.0	ENGINE POPULATION

The existing population of CI engines in the U.S. was estimated using
information obtained from the Power System Research’s (PSR) North
American Engine PartsLink Database provided by the U.S. EPA Office of
Transportation and Air Quality.  The CI RICE population was estimated
using the baseline engine population and engine sales information from
PSR.  A summary of the total number of affected engines is presented in
Tables 1 and 2.  

Table 1.  Number of Affected Engines – Major Sources

Size Range

(HP)	Affected CI Engines1

25-50	0

50-100	92,734 

100-175	121,507 

175-300	92,144 

300-500	48,481

500-600	4,298

600-750	2,200

>750	4,853

Total	366,217

1Number of affected engines are estimated based on the following
applicability dates:

i.  > 500 HP non-emergency CI engines at major sources constructed
before 12/19/2002.

ii. < 500 HP engines at major sources constructed before 6/12/2006.

Table 2.  Number of Affected Engines – Area Sources

Size Range

(HP)	Affected CI Engines1

25-50	0

50-100	127,973

100-175	167,679

175-300	127,159

300-600	100,355

600-750	16,822

>750	29,802

Total	569,790

1Number of affected engines are estimated based on all engines at area
sources constructed before 6/12/2006.

	The population of affected CI engines located at area sources is less
than the population of existing areas source engines presented in the
population memorandum.  The final rule does not apply to area source
emergency CI engines that are residential, commercial, or institutional;
therefore these CI engines were removed from the affected source
inventory for area sources.  The number of area source emergency CI
engines that are residential, commercial, or institutional was
calculated assuming that 10 percent of the area source engines are
residential, commercial, or institutional.  That 10 percent value was
then divided into emergency and non-emergency using the assumed 80/20
percentage (e.g., 80% emergency/20% non-emergency) that was used for all
CI engines.  The totals in Table 2 include only those engines that are
subject to the regulation.

3.0	COST IMPACTS

3.1	Introduction

	The cost impacts associated with the final rule consist of different
types of costs, which include the annual and capital costs of controls,
costs associated with keeping records of information necessary to
demonstrate compliance, costs associated with reporting requirements
under the General Provisions of 40 CFR part 63, subpart A, costs of
purchasing and operating equipment associated with continuous parametric
monitoring, and the cost of conducting performance testing to
demonstrate compliance with the emission standards.  The following
sections describe how the various cost elements were estimated. 

Control Costs

For engines that will need to add control technology to meet the
emission standards, the following equations were used to estimate
capital and annual control costs:

Technology	Capital Cost ($2008)	Annual Cost ($2008)

Diesel oxidation catalyst (DOC)	$27.4 x HP - $939	$4.99 x HP + $480

Open crankcase ventilation (OCV)	$0.26 x HP + $997	$0.065 x HP + $254



The control costs for DOC were calculated using cost data obtained from
a California Air Resources Board (CARB) study.  The study provided cost
ranges for diesel engines ranging from 40 HP to 1400 HP.  The average
cost from the range was selected and was adjusted to 2008 dollars.  The
capital and annual cost were calculated using maintenance data from the
CARB study and cost assumptions from the EPA Control Cost Manual.  The
control costs for the OCV system were calculated using 2008 cost data
obtained from a diesel engine equipment vendor.  An equipment life of 10
years was used to calculate the capital recovery factor (CRF) for
developing the annual cost for each of the control devices.  A linear
regression equation was developed for the capital cost of the DOC and
OCV using the capital cost data and the engine size in HP.  This
approach was used to develop a linear regression equation for annual
cost.      

Recordkeeping

No recordkeeping costs were attributed to the requirement of following
the manufacturer’s emission-related operation and maintenance (O&M)
requirements or the owner or operator’s own maintenance plan.  It is
expected that the majority of owners and operators are already following
some type of O&M requirements and minimal to no additional burden is
expected.  Labor costs associated with recording the hours of operation
of emergency engines are based on a technical labor rate of $68 per hour
which was obtained from the Department of Labor Statistics web site. The
final total wage rate was based on the 2005 compensation rates for
professional staff and adjusted by an overhead and profit rate of 167
percent.  The year 2005 was used for consistency in order to have the
same basis for all costs.  All costs were later converted to 2008
dollars for purposes of presenting costs associated with the rule in
present day terms.  One hour per year is expected to be sufficient to
record hours of operation for stationary emergency engines.  No cost is
attributed to purchasing and installing an hour-meter since the majority
of stationary engines already come equipped with such equipment.  For
owner/operators of non-emergency CI engines, EPA assumed that one hour
per year was sufficient for recordkeeping for these engines.

Reporting

	Most engines affected by this rule will be subject to reporting
requirements such as reading instructions, training personnel,
submitting an initial notification, submitting a notification of
performance test(s), and submitting a compliance report.  However,
owners and operators of engines less than 100 HP, existing stationary
emergency engines, and existing stationary engines less than 300 HP
located at area sources are not subject to any specific reporting
requirements.  For stationary non-emergency limited use CI engines that
operate less than 100 hours per year, EPA is finalizing less burdensome
reporting requirements by requiring these engines to submit compliance
reports on an annual basis, as opposed to semiannually as is required
for other engines subject to numerical emission limitations.  The
reporting requirements are based on $68 per hour for technical labor to
comply with the reporting requirements.  It is estimated that a total of
14 hours will be needed for non-limited use engines, and 13 hours for
limited use engines.

Monitoring

The cost of monitoring includes the purchase of a continuous parametric
monitoring system (CPMS).  Non-emergency engines greater than 500 HP
that have add-on controls are required to use a CPMS to monitor the
catalyst inlet temperature and pressure drop across the catalyst to
ensure those parameters do not exceed the operating limitations.  The
cost of purchasing and operating a CPMS was obtained from vendor quotes
received for previous rulemaking and adjusted to 2008 dollars.  The
capital cost of a CPMS for a large engine facility is $531.  It is
estimated that 30 hours per year is necessary to operate and maintain
the CPMS and that 6 hours per year (or 0.5 hours per month) is needed to
record information from the CPMS.  It is assumed that all engines
subject to continuous monitoring would be located at large engine
facilities. 

Performance Testing

Initial performance testing is required for non-emergency engines
greater than 100 HP at major sources and non-emergency engines greater
than 300 HP located at area sources.  The cost of conducting a
performance test on a CI engine is based on cost information gathered
for previous rulemakings.  The performance testing cost is based the use
of a portable analyzer and was estimated to cost $1,000 per day of
testing.  This daily performance test cost was adjusted to 2008 dollars
and was estimated to be $1,165.  Because the regulation requires three-1
hour runs, EPA assumed that two engines could be tested at each facility
in one day.  Therefore, the estimated impacts performance testing cost
will be assumed to be $583 per engine (or half of the $1,165 daily cost)
using a portable analyzer.

Work Practices

	The costs for performing work practices for CI engines less than 100 HP
located at a major source was assumed to be negligible and were not
included in these impact calculations.  The work practices are based on
engine maintenance procedures that the owner/operators perform
regardless of the regulation.  These work practices include:

Changing the oil and filter;

Inspecting the air cleaner; 

Inspecting all hoses and belts, and replacing as necessary.

EPA believes that these work practices will limit HAP emissions from
these engines, because these work practices ensure that the engine is
operating efficiently.  Owner/operators of these engines regularly
perform these work practices as part of the preventive maintenance
schedule for the engine.  Therefore, EPA believes that it is appropriate
to not include these work practice costs in the impacts determination.

Management Practices

	The costs for performing management practices for non-emergency CI
engines less than or equal to 300 HP located at area sources and all
emergency engines located at area sources was assumed to be negligible
and were not included in these impact calculations.  The management
practices are based on engine maintenance procedures that the
owner/operators perform regardless of the regulation.  These management
practices include:

Changing the oil and filter;

Inspecting the air cleaner; and  

Inspecting all hoses and belts, and replacing as necessary.

EPA believes that these work practices will limit HAP emissions from
these engines, because these work practices ensure that the engine is
operating efficiently.  Owner/operators of these engines regularly
perform these work practices as part of the preventive maintenance
schedule for the engine.  Therefore, EPA believes that it is appropriate
to not include these work practice costs in the impacts determination.

3.2 	Major Sources

The cost impacts for stationary RICE vary depending on the engine type
and size.  The following sections describe the specific costs that apply
to each subcategory of CI engines located at major sources.

All CI Engines HP < 100

The costs associated with CI engines less than 100 HP include minimal
requirements.  Owners and operators of engines less than 100 HP are
required to follow the manufacturer’s emission-related O&M
requirements or must develop their own maintenance plan to follow. 
Emergency engines must record the hours of operation, which is estimated
at one hour per year at $72 per hour.  

≤ HP ≤ 300 HP 

	The costs associated with non-emergency CI engines greater than or
equal to 100 HP and less than or equal to 300 HP include the cost of an
initial test, recordkeeping, and reporting.  In addition, EPA assumes
that some of these engines will be required to install a control device
to meet the emissions standard.  To estimate the number of CI engines
that would be required to install control technology, EPA compared the
emission rate of the test that was used to determine the MACT floor with
the CI nonroad emission factors.  EPA found that only the emission
factors for Tier 0 CI engines were greater than the 1.2 g/HP-hr value
that was used to set the MACT floor.  Therefore, it was assumed that
Tier 1 engines and greater would be able to meet the final emission
standard.  The model year for Tier 1 engines begins in 1997 for 100 to
175 CI engines, and 1996 for 175 to 300 HP CI engines.  Using the model
year data in the population memorandum, EPA estimated that 35 percent of
the existing CI engines greater than or equal to 100 HP and less than or
equal to 300 HP are Tier 0 engines and would need to install control
technology to meet the emission standard.  The cost estimates for this
subcategory of engines do not account for possible fuel price increases
that may result from using ultra-low sulfur diesel (ULSD).  EPA
estimated the cost of lubricity additives to ULSD would increase the
cost of the fuel by 0.2 cents per gallon, which EPA believes is
negligible.  In addition, there are no additional maintenance
requirements for owner/operators using ULSD in existing diesel engines. 
Many owner/operators have found that time between oil changes can be
extended for engines using ULSD fuel, which would decrease the overall
cost of switching to ULSD fuel.  Therefore, EPA believes that it is
appropriate to not include any costs for switching to ULSD in the
impacts for this NESHAP.

Non-emergency CI Engines > 300 HP

The costs associated with non-emergency CI engines above 300 HP include
the cost of installing and operating an oxidation catalyst for reducing
HAP, as well as the cost of installing an open crankcase ventilation
system.  Non-emergency CI engines greater than 500 HP are also subject
to continuous monitoring requirements.  In addition, owners and
operators must conduct an initial performance test to demonstrate
compliance with the emission limitation.  Owners and operators of
engines above 500 HP must conduct subsequent performance testing every
8,760 hours or 3 years, whichever comes first to demonstrate compliance.
 The cost estimates for this subcategory of engines do not account for
possible fuel price increases that may result from using ultra-low
sulfur diesel (ULSD).  EPA estimated the cost of lubricity additives to
ULSD would increase the cost of the fuel by 0.2 cents per gallon, which
EPA believes is negligible.  In addition, there are no additional
maintenance requirements for owner/operators using ULSD in existing
diesel engines.  Many owner/operators have found that time between oil
changes can be extended for engines using ULSD fuel, which would
decrease the overall cost of switching to ULSD fuel.  Therefore, EPA
believes that it is appropriate to not include any costs for switching
to ULSD in the impacts for this NESHAP.  

Emergency CI Engines 100 ≤ HP ≤ 500 

The costs associated with emergency CI engines greater than 300 HP and
less than or equal to 500 HP (emergency CI engines above 500 HP were
subject to an earlier rule and are not subject to further regulation in
this rule) include minimal recordkeeping requirements.  The owners and
operators must follow the manufacturer’s emission-related operating
and maintenance (O&M) requirements or must develop their own maintenance
plan to follow and must also keep records of the hours of operation.  It
is estimated that one hour per year at $68 per hour would be sufficient
to record the hours of operation.  No costs were included in the impacts
for following the manufacturer’s emission-related O&M plan, because it
is expected that owner/operators will follow this plan regardless of the
regulation.  

3.3 	Area Sources

All Emergency CI Engines

The costs associated with emergency CI engines include recordkeeping
requirements for tracking the hours of operation, but these engines are
not subject to any performance testing.  The owners and operators must
follow the manufacturer’s emission-related O&M requirements or must
develop their own maintenance plan to follow.  It is estimated that one
hour per year at $68 per hour would be sufficient to record the hours of
operation.  Emergency CI engines at areas sources will be subject to
management practices, rather numerical emission limits.  The management
practices do not require aftertreatment controls.  Therefore, no control
costs have been estimated for these engines.  These engines will be
subject to management practices which are not included in the costs,
because it is assumed that these management practices are performed
regardless of the regulation.  

Non-Emergency CI Engines ≤ 300 HP

The costs associated with non-emergency CI engines less than or equal to
300 HP are minimal and only include following the manufacturer’s
emission-related O&M requirements or the owner or operator’s own
maintenance plan.  These engines are not subject to any numerical
emission limitations, therefore no control costs apply and no
performance testing is required.   These engines will be subject to
management practices which are not included in the costs, because it is
assumed that these management practices are done regardless of the
regulation.

Non-Emergency CI Engines > 300 HP

The costs associated with non-emergency CI engines above 300 HP include
the cost of installing and operating an oxidation catalyst for reducing
HAP, as well as the cost of installing an open crankcase ventilation
system.  Non-emergency CI engines greater than 500 HP are also subject
to continuous monitoring requirements.  In addition, owners and
operators must conduct an initial performance test to demonstrate
compliance with the emission limitation and engines above 500 HP must
conduct subsequent performance testing every 8,760 hours or 3 years,
whichever comes first.  The cost estimates for this subcategory of
engines do not account for possible fuel price increases that may result
from using ultra-low sulfur diesel.  The cost estimates for this
subcategory of engines do not account for possible fuel price increases
that may result from using ultra-low sulfur diesel (ULSD).  EPA
estimated the cost of lubricity additives to ULSD would increase the
cost of the fuel by 0.2 cents per gallon, which EPA believes is
negligible.  In addition, there are no additional maintenance
requirements for owner/operators using ULSD in existing diesel engines. 
Many owner/operators have found that time between oil changes can be
extended for engines using ULSD fuel, which would decrease the overall
cost of switching to ULSD fuel.  Therefore, EPA believes that it is
appropriate to not include any costs for switching to ULSD in the
impacts for this NESHAP.

A summary of the total costs associated with the rule and a breakdown of
the costs by NAICS codes are presented in Tables 4 through 7.  For
estimating the number of engines located at major and area sources, we
used our best engineering judgment, and we recognize that it may lead to
an overestimate or underestimate of impacts for certain sectors.Table
4.  Summary of Major Source and Area Source Costs for the CI RICE
NESHAP1

Size Range (HP)	Non-Emergency CI	Initial Test	Recordkeeping	Reporting
Monitoring - Capital Cost	Monitoring - Annual Cost	Total Annual Costs
Total Capital Costs

	Capital Control Cost	Annual Control Cost



















Major Sources

50-100	$0 	$0 	$0	$6,654,888	$0	$0	$0	$6,654,888	$0

100-175	$24,057,778 	$9,918,465 	$14,150,269	$8,719,731	$5,973,016	$0	$0
$38,761,480	$24,057,778

175-300	$35,917,270 	$10,740,189 	$10,730,759	$6,612,548	$4,529,595	$0
$0	$32,613,092	$35,917,270

300-500	$107,841,136 	$26,722,727 	$5,645,923	$3,479,152	$2,383,219	$0
$0	$38,231,021	$107,841,136

500-600	$13,126,952 	$3,020,849 	$500,530	$61,688	$211,280	$481,765
$2,220,755	$6,015,102	$13,608,716

600-750	$8,240,540 	$1,824,295 	$256,204	$31,576	$108,147	$246,599
$1,136,729	$3,356,951	$8,487,139

>750	$26,903,091 	$5,618,803 	$565,163	$69,653	$238,563	$543,975
$2,507,521	$8,999,703	$27,447,066

Total	$216,086,768	$57,845,329	$31,848,848	$25,629,236	$13,443,820
$1,272,338	$5,865,005	$134,632,238	$217,359,106

Area Sources

50-100	$0	$0	$0	$9,183,746	$0	$0	$0	$9,183,746	$0

100-175	$0	$0	$0	$12,033,196	$5,231,824	$0	$0	$17,265,020	$0

175-300	$0	$0	$0	$9,125,316	$3,967,529	$0	$0	$13,092,845	$0

300-600	$272,814,082	$65,640,094	$12,703,298	$7,201,827	$5,362,230
$4,075,682	$18,787,376	$109,694,825	$276,889,764

600-750	$68,490,125	$15,162,379	$2,129,405	$1,207,215	$898,850	$683,191
$8,952,336	$28,350,186	$69,173,315

>750	$179,573,835	$37,504,615	$3,772,372	$2,138,655	$1,592,368
$1,210,315	$15,859,613	$60,867,624	$180,784,150

Total	$520,878,041	$118,307,088	$18,605,076	$40,889,956	$17,052,802
$5,969,187	$43,599,324	$238,454,245	$526,847,229

Total	$736,964,809	$176,152,417	$50,453,924	$66,519,191	$30,496,622
$7,241,526	$49,464,330	$373,086,483	$744,206,335

1 Costs are presented in 2008 dollars.

Table 5.  Summary of Major Source and Area Source NAICS Costs for the
CI RICE NESHAP1

NAICS	Major Source	Area Source	Total (Major + Area)

	Capital Cost	Annual Cost	Capital Cost	Annual Cost	Capital Cost	Annual
Cost

Electric Power Generation (2211)	$161,766,376	$90,982,105	$471,230,478
$203,529,267	$632,996,854	$294,511,373

Hospitals (622110)	$20,220,797	$11,372,763	$0	$0	$20,220,797	$11,372,763

Crude Petroleum & NG Production (211111)	$2,374,401	$3,807,478
$1,611,601	$2,599,033	$3,986,003	$6,406,510

Natural Gas Liquid Producers (211112)	$2,374,401	$3,807,478	$1,611,601
$2,599,033	$3,986,003	$6,406,510

National Security (92811)	$20,220,797	$11,372,763	$52,358,942
$22,614,363	$72,579,739	$33,987,126

Hydro Power Units (335312)	$0	$16,637	$0	$22,959	$0	$39,597

Irrigation Sets (335312)	$10,294,073	$11,791,567	$34,606	$5,208,210
$10,328,679	$16,999,777

Welders (333992)	$108,260	$1,481,447	$0	$1,881,380	$108,260	$3,362,827

Total	$217,359,106	$134,632,238	$526,847,229	$238,454,245	$744,206,335
$373,086,483

1 Costs are presented in 2008 dollars.

Table 6.  Summary of Major Source and Area Source NAICS Costs for the
CI RICE NESHAP – by Size1

NAICS	Major Source	Area Source	Total (Major + Area)

	Capital Cost	Annual Cost	Capital Cost	Annual Cost	Capital Cost	Annual
Cost

Electric Power Generation (2211)	 	 	 	 	 	 

50-100 hp	$0	$3,396,123	$0	$5,272,480	$0	$8,668,603

100-175 hp	$13,406,919	$21,600,998	$0	$10,824,132	$13,406,919
$32,425,129

175-300 hp	$23,012,914	$20,895,861	$0	$9,437,454	$23,012,914	$30,333,314

300-600 hp	$96,907,266	$35,304,866	$248,552,865	$98,468,656	$345,460,132
$133,773,522

600-750 hp	$6,789,032	$2,685,292	$62,249,758	$25,512,616	$69,038,790
$28,197,908

>750 hp	$21,650,245	$7,098,966	$160,427,854	$54,013,930	$182,078,100
$61,112,896

Total Electric Power Generation 2211	$161,766,376	$90,982,105
$471,230,478	$203,529,267	$632,996,854	$294,511,373

Hospitals (622110)	 	 	 	 	 	 

50-100 hp	$0	$424,515	$0	$0	$0	$424,515

100-175 hp	$1,675,865	$2,700,125	$0	$0	$1,675,865	$2,700,125

175-300 hp	$2,876,614	$2,611,983	$0	$0	$2,876,614	$2,611,983

300-600 hp	$12,113,408	$4,413,108	$0	$0	$12,113,408	$4,413,108

600-750 hp	$848,629	$335,662	$0	$0	$848,629	$335,662

>750 hp	$2,706,281	$887,371	$0	$0	$2,706,281	$887,371

Total Hospitals (622110)	$20,220,797	$11,372,763	$0	$0	$20,220,797
$11,372,763

Crude Petroleum & NG Production (211111)	 	 	 	 	 	 

50-100 hp	$0	$420,256	$0	$579,954	$0	$1,000,210

100-175 hp	$2,026,868	$3,265,655	$0	$1,454,578	$2,026,868	$4,720,233

175-300 hp	$3,592	$3,261	$0	$1,309	$3,592	$4,571

300-600 hp	$151,812	$55,308	$346,112	$137,119	$497,925	$192,426

600-750 hp	$0	$0	$0	0	$0	$0

>750 hp	$192,129	$62,998	$1,265,489	$426,073	$1,457,619	$489,071

Total Crude Petroleum & NG Production (211111)	$2,374,401	$3,807,478
$1,611,601	$2,599,033	$3,986,003	$6,406,510

Natural Gas Liquid Producers (211112)	 	 	 	 	 	 

50-100 hp	$0	$420,256	$0	$579,954	$0	$1,000,210

100-175 hp	$2,026,868	$3,265,655	$0	$1,454,578	$2,026,868	$4,720,233

175-300 hp	$3,592	$3,261	$0	$1,309	$3,592	$4,571

300-600 hp	$151,812	$55,308	$346,112	$137,119	$497,925	$192,426

600-750 hp	0	0	0	0	$0	$0

>750 hp	$192,129	$62,998	$1,265,489	$426,073	$1,457,619	$489,071

Total Natural Gas Liquid Producers (211112)	$2,374,401	$3,807,478
$1,611,601	$2,599,033	$3,986,003	$6,406,510

National Security (92811)	 	 	 	 	 	 

50-100 hp	$0	$424,515	$0	$585,831	$0	$1,010,346

100-175 hp	$1,675,865	$2,700,125	$0	$1,202,681	$1,675,865	$3,902,806

175-300 hp	$2,876,614	$2,611,983	$0	$1,048,606	$2,876,614	$3,660,589

300-600 hp	$12,113,408	$4,413,108	$27,616,985	$10,940,962	$39,730,393
$15,354,070

600-750 hp	$848,629	$335,662	$6,916,640	$2,834,735	$7,765,269	$3,170,397

>750 hp	$2,706,281	$887,371	$17,825,317	$6,001,548	$20,531,598
$6,888,919

Total National Security (92811)	$20,220,797	$11,372,763	$52,358,942
$22,614,363	$72,579,739	$33,987,126

Hydro Power Units (335312)	 	 	 	 	 	 

50-100 hp	$0	$16,637	$0	$22,959	$0	$39,597

100-175 hp	$0	$0	$0	$0	$0	$0

175-300 hp	$0	$0	$0	$0	$0	$0

300-600 hp	$0	$0	$0	$0	$0	$0

600-750 hp	$0	$0	$0	$0	$0	$0

>750 hp	$0	$0	$0	$0	$0	$0

Total Hydro Power Units (335312)	$0	$16,637	$0	$22,959	$0	$39,597

Irrigation Sets (335312)	 	 	 	 	 	 

50-100 hp	$0	$245,565	$0	$338,880	$0	$584,446

100-175 hp	$3,137,134	$5,054,497	$0	$2,251,359	$3,137,134	$7,305,856

175-300 hp	$7,143,945	$6,486,744	$0	$2,604,167	$7,143,945	$9,090,911

300-600 hp	$12,145	$4,425	$27,689	$10,969	$39,834	$15,394

600-750 hp	$849	$336	$6,917	$2,835	$7,766	$3,171

>750 hp	$0	$0	$0	$0	$0	$0

Total Irrigation Sets (335312)	$10,294,073	$11,791,567	$34,606
$5,208,210	$10,328,679	$16,999,777

Welders (333992)	 	 	 	 	 	 

50-100 hp	$0	$1,307,020	$0	$1,803,688	$0	$3,110,708

100-175 hp	$108,260	$174,427	$0	$77,693	$108,260	$252,119

175-300 hp	$0	$0	$0	$0	$0	$0

300-600 hp	$0	$0	$0	$0	$0	$0

600-750 hp	$0	$0	$0	$0	$0	$0

>750 hp	$0	$0	$0	$0	$0	$0

Total Welders (333992)	$108,260	$1,481,447	$0	$1,881,380	$108,260
$3,362,827

Total	$217,359,106	$134,632,238	$526,847,229	$238,454,245	$744,206,335
$373,086,483

1 Costs are presented in 2008 dollars.

Table 7.  Summary of Major Source and Area Source NAICS Costs for the
CI RICE NESHAP – by Number of Engines1

NAICS	Number of Engines	Total (Major + Area)

	Major	Area	Total	Capital Cost	Annual Cost

Electric Power Generation (2211)	 	 	 	 	 

50-100 hp	47,324	79,859	127,183	$0	$8,668,603

100-175 hp	67,713	114,266	181,980	$13,406,919	$32,425,129

175-300 hp	59,039	99,627	158,666	$23,012,914	$30,333,314

300-600 hp	42,113	97,919	140,032	$345,460,132	$133,773,522

600-750 hp	1,760	16,455	18,215	$69,038,790	$28,197,908

>750 hp	3,828	28,746	32,574	$182,078,100	$61,112,896

Total Electric Power Generation 2211	221,777	436,872	658,649
$632,996,854	$294,511,373

Hospitals (622110)	 	 	 	 	 

50-100 hp	5,916	0	5,916	$0	$424,515

100-175 hp	8,464	0	8,464	$1,675,865	$2,700,125

175-300 hp	7,380	0	7,380	$2,876,614	$2,611,983

300-600 hp	5,264	0	5,264	$12,113,408	$4,413,108

600-750 hp	220	0	220	$848,629	$335,662

>750 hp	479	0	479	$2,706,281	$887,371

Total Hospitals (622110)	27,722	0	27,722	$20,220,797	$11,372,763

Crude Petroleum & NG Production (211111)	 	 	 	 	 

50-100 hp	5,856	8,784	14,640	$0	$1,000,210

100-175 hp	10,237	15,355	25,592	$2,026,868	$4,720,233

175-300 hp	9	14	23	$3,592	$4,571

300-600 hp	66	136	202	$497,925	$192,426

600-750 hp	0	0	0	$0	$0

>750 hp	34	227	261	$1,457,619	$489,071

Total Crude Petroleum & NG Production (211111)	16,202	24,517	40,719
$3,986,003	$6,406,510

Natural Gas Liquid Producers (211112)	 	 	 	 	 

50-100 hp	5,856	8,784	14,640	$0	$1,000,210

100-175 hp	10,237	15,355	25,592	$2,026,868	$4,720,233

175-300 hp	9	14	23	$3,592	$4,571

300-600 hp	66	136	202	$497,925	$192,426

600-750 hp	0	0	0	$0	$0

>750 hp	34	227	261	$1,457,619	$489,071

Total Natural Gas Liquid Producers (211112)	16,202	24,517	40,719
$3,986,003	$6,406,510

National Security (92811)	 	 	 	 	 

50-100 hp	5,916	8,873	14,789	$0	$1,010,346

100-175 hp	8,464	12,696	21,160	$1,675,865	$3,902,806

175-300 hp	7,380	11,070	18,450	$2,876,614	$3,660,589

300-600 hp	5,264	10,880	16,144	$39,730,393	$15,354,070

600-750 hp	220	1,828	2,048	$7,765,269	$3,170,397

>750 hp	479	3,194	3,672	$20,531,598	$6,888,919

Total National Security (92811)	27,722	48,541	76,263	$72,579,739
$33,987,126

Hydro Power Units (335312)	 	 	 	 	 

50-100 hp	232	348	580	$0	$39,597

100-175 hp	0	0	0	$0	$0

175-300 hp	0	0	0	$0	$0

300-600 hp	0	0	0	$0	$0

600-750 hp	0	0	0	$0	$0

>750 hp	0	0	0	$0	$0

Total Hydro Power Units (335312)	232	348	580	$0	$39,597

Irrigation Sets (335312)	 	 	 	 	 

50-100 hp	3,422	5,133	8,555	$0	$584,446

100-175 hp	15,845	23,767	39,611	$3,137,134	$7,305,856

175-300 hp	18,327	27,491	45,819	$7,143,945	$9,090,911

300-600 hp	5	11	16	$39,834	$15,394

600-750 hp	0	2	2	$7,766	$3,171

>750 hp	0	0	0	$0	$0

Total Irrigation Sets (335312)	37,599	56,403	94,003	$10,328,679
$16,999,777

Welders (333992)	 	 	 	 	 

50-100 hp	18,213	27,319	45,532	$0	$3,110,708

100-175 hp	547	820	1,367	$108,260	$252,119

175-300 hp	0	0	0	$0	$0

300-600 hp	0	0	0	$0	$0

600-750 hp	0	0	0	$0	$0

>750 hp	0	0	0	$0	$0

Total Welders (333992)	18,760	28,140	46,899	$108,260	$3,362,827

Total	366,217	619,337	957,832	$744,206,335	$373,086,483

1 Costs are presented in 2008 dollars.

4.0	EMISSION IMPACTS

The emissions reductions associated with the final rule are based on
requiring emission standards that are based on applying add-on controls
to non-emergency CI engines greater than 300 HP.  Baseline emissions
from the current population of stationary RICE less than or equal to 500
HP at major sources and existing stationary RICE at area sources were
calculated based on non-emergency CI engines operating 1,000 hrs/yr, and
emergency CI engines operating 50 hrs/yr.  The following additional
assumptions were used:

Emission Factors:

Engine	HAP 

(lb/hp-hr)	CO 

(lb/hr)	PM 

(lb/hp-hr)

CI	1.07x10-4 	6.96x10-1 	7.00x10-4

*Obtained from AP-42, section 3.4 where S1 is sulfur content.

				

Control Efficiencies:

Technology	HAP	CO	PM

Oxidation catalyst	70%	70%	30%



Based on the above assumptions and the existing population of engines
shown in Tables 1 through 3 of this memorandum, the HAP, CO, and PM
baseline emissions and reductions were calculated.  In addition to the
final rule reducing HAP, CO, and PM, the rule will also lead to
reductions in sulfur dioxide (SO2) emissions by requiring existing
non-emergency CI engines greater than 300 HP that use diesel fuel to use
diesel fuel containing no more than 15 parts per million (ppm) of
sulfur.  However, EPA has not quantified the SO2 emission reductions
that would occur as a result of these engines switching to ULSD.
 Although EPA is confident that some SO2 reductions would occur as a
result of this rule, EPA is unable to estimate the percentage of engines
that may switch to ULSD in the absence of this rule.  As a PM2.5
precursor, these SO2 emission reductions would lead to fewer
PM2.5-related health effects. Because of uncertainty in the magnitude of
the attributable SO2 reductions and to avoid the appearance of
double-counting, EPA has chosen to not include SO2 reduction estimates
in Table 8 of this memorandum.  In addition, it is expected that
additional PM reductions will be achieved by the requirement to use ULSD
for CI engines that install a DOC.  The use of ULSD reduces the
formation of sulfates in the exhaust gas, therefore reducing the
emission of these sulfate PM emissions from the exhaust.  EPA has
estimated that the use of ULSD can reduce PM emissions by 5-30 percent
depending on the sulfur concentration of the diesel fuel that is being
replaced.  Because EPA has no information on the type of fuel that CI
engines are currently using, the PM reductions from switching to ULSD
were not quantified and included in this summary.

	The work practice requirement of using an open crankcase ventilation
system to control metallic HAP emissions is expected to achieve
additional HAP reductions from CI engines.  However, the metallic HAP
emission reduction cannot be quantified because of the difficulty of
measuring metallic HAP from the crankcase exhaust.  Therefore, the
metallic HAP reductions are not included in the total emission
reductions.

Table 8.  Summary of Major Source and Area Source Emissions Reductions
for the CI RICE NESHAP 

Size Range (HP)	Emission Reductions (TPY)

	HAP	CO	PM	VOC

Major Sources 

50-100	0	0	0	0

100-175	44	2,072	123	1,183

175-300	57	1,571	161	1,549

300-500	145	2,362	407	3,923

500-600	18	209	50	478

600-750	11	107	31	300

>750	36	236	102	982

Total	312	6,558	874	8,416

Area Sources 

50-100	0	0	0	0

100-175	0	0	0	0

175-300	0	0	0	0

300-600	368	5,314	1,031	9,930

600-750	92	891	259	2,497

>750	243	1,578	680	6,553

Total	703	7,784	1,970	18,980

Grand Total	1,014	14,342	2,844	27,395



 Memorandum from Tanya Parise, Alpha-Gamma Technologies, Inc. to Jaime
Pagán, EPA Energy Strategies Group, Existing Population of Stationary
RICE, June 26, 2008.

 Diesel PM Control Technologies, Appendix IX, California Air Resource
Board, October 2000.    HYPERLINK
"http://www.arb.ca.gov/diesel/documents/rrpapp9.pdf" 
http://www.arb.ca.gov/diesel/documents/rrpapp9.pdf  

 U.S. Department of Labor, Employer Costs for Employee Compensation,  
HYPERLINK "http://www.bls.gov/news.release/ecec.toc.htm" 
http://www.bls.gov/news.release/ecec.toc.htm  

 Part A of the Supporting Statement for Standard Form 83 Stationary
Reciprocating Internal Combustion Engines, November 17, 2003.

 Memorandum from Bradley Nelson, Alpha-Gamma Technologies, Inc. to Sims
Roy, EPA/OAQPS/ESD/Combustion Group, Portable Emissions Analyzer Cost
Information, August 31, 2005.  

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and Standards Division, EPA420-P-04-009, Revised April 2004.

  HYPERLINK
"http://www.epa.gov/oms/models/nonrdmdl/nonrdmdl2004/420p04009.pdf" 
http://www.epa.gov/oms/models/nonrdmdl/nonrdmdl2004/420p04009.pdf  

 Memorandum from Melanie Taylor and Brad Nelson, AGTI to Sims Roy, EPA
OAQPS ESD Combustion Group, Lubricity of Ultra Low Sulfur Diesel Fuel,
June 2, 2004.

 Memorandum from Melanie Taylor and Brad Nelson, AGTI to Sims Roy, EPA
OAQPS ESD Combustion Group, Lubricity of Ultra Low Sulfur Diesel Fuel,
June 2, 2004.

E C/R Incorporated	Providing Environmental Technical Support Since 1989



	

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