  SEQ CHAPTER \h \r 1    

MEMORANDUM

DATE:		February 15, 2010

SUBJECT:	MACT Floor and MACT Determination for Existing Stationary
Non-Emergency CI RICE Greater Than or Equal to 100 HP Located at Major
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) greater than or equal to 100
horsepower (HP) located at major sources that are subject to the
National Emission Standards for Hazardous Air Pollutants (NESHAP).  

The MACT analysis for existing stationary non-emergency CI engines less
than 100 HP and existing stationary emergency and black start CI engines
at major sources, and the Generally Achievable Control Technology
analysis for existing stationary CI engines located at area sources of
hazardous air pollutants (HAP) emissions are presented in a separate
memorandum titled “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,” which is available in the rulemaking
docket (Docket No. EPA-HQ-OAR-2008-0708).  A “major source” means
generally any stationary source or group of stationary sources located
within a contiguous area and under common control that emits or has the
potential to emit considering controls, in the aggregate, 10 tons per
year or more of any hazardous air pollutant or 25 tons per year or more
of any combination of HAP.

2.0	INTRODUCTION

The EPA has developed a regulation affecting existing stationary CI RICE
located at major sources that will address toxic air emissions from
these engines.  The regulation was developed following criteria set
forth under section 112 of the Clean Air Act (CAA).  The MACT floor for
existing 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.  The MACT
standards must be no less stringent than the MACT floor.  EPA must also
determine whether to control emissions “beyond-the-floor,” after
considering the costs, non-air quality health and environmental impacts,
and energy requirements of such more stringent control.  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 allows the EPA to establish subcategories among
a group of sources.  A complete discussion of the subcategory selection
is presented in a separate memorandum which can also be found in the
rulemaking docket.  

3.0	MACT FLOOR AND MACT DETERMINATION

General Approach

The MACT floor for existing stationary RICE 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.  In the proposed rule, EPA established the MACT floor for
each subcategory of stationary existing CI engines using the emissions
data that EPA had for stationary CI engines, which consisted of testing
conducted by EPA and industry at Colorado State University (CSU) on a
1,000 HP CI engine.  During the comment period, EPA received five
additional test reports that included emission results for 13 existing
stationary CI engines ranging from 160 HP to 3,570 HP.  These new test
data along with the test data from the CSU testing were used to
determine the MACT floor for each of the subcategories.  A summary of
the average test results for each of the engines is presented in
Appendix A.  The test reports for the test data used to determine the
MACT floor are provided in the Docket as Document ID Nos.
EPA-HQ-OAR-2002-0059-0018 and EPA-HQ-OAR-2008-0708-0272 through 0275.

EPA has previously conducted an analysis for the RICE NESHAP for engines
greater than 500 HP at major sources, which investigated whether carbon
monoxide (CO) could be used as a surrogate for HAP from stationary
engines.  The conclusion of the analysis was that CO is a reasonable
surrogate for formaldehyde for CI engines, and that formaldehyde is a
reasonable surrogate for HAP for CI engines.  To determine the MACT
floor for each of the subcategories, EPA used the following methodology:
 (1) we ranked the average emissions from each engine from lowest to
highest; (2) we determined the units in the MACT floor; (3) we assessed
variability.  The MACT floor and MACT determination for each subcategory
is described below and is summarized in Table 1.  A summary of the test
data that was used to set the MACT floor is presented in Appendix B.

Table 1.  Summary of Determination for 

≥100 HP

Located at Major Sources 

Subcategory	MACT Floor	MACT

Non-Emergency CI 100≤HP≤300	230 ppmvd CO @15% O2	230 ppmvd CO @15%
O2

Non-Emergency CI 300<HP≤500	137 ppmvd CO @15% O2	49 ppmvd CO @15% O2

or

70% CO reduction

Non-Emergency CI

>500 HP	38 ppmvd CO @15% O2	23 ppmvd CO @15% O2

or

70% CO reduction



Non-Emergency CI 100≤HP≤300

EPA has test data for two engines in this subcategory; therefore, the
best performing 12 percent of sources in this subcategory is represented
by a single engine.  The MACT floor engine was tested for three runs. 
To account for variability, EPA used the highest individual run to
establish the MACT floor.  As shown in Appendix B, the resulting MACT
floor for non-emergency CI engines between 100 and 300 HP is 230 parts
per million by volume, dry basis (ppmvd) of CO at 15 percent oxygen
(O2).

We also evaluated whether to go beyond-the-floor.  Specifically, EPA
considered additional emission controls that would further reduce HAP
emissions.  One control that we considered for reducing HAP is a diesel
oxidation catalyst (DOC).  The DOC technology is capable of reducing HAP
emissions by 70 percent or more.  The DOC technology also reduces
emissions of CO by 70 percent or more, as well as particulate matter
(PM) emissions.  Achievable reductions of PM are on the order of 30
percent for the DOC.  

EPA also considered the use of open crankcase ventilation (OCV) or
closed crankcase ventilation (CCV) systems to further reduce emissions
of metallic HAP under section 112(d)(2)(B) and (C), as a measure that
encloses systems to eliminate emissions or collects, captures or treats
such pollutants.  EPA also notes that it does not believe it would be
feasible at this time to prescribe an emission standard for metallic
HAP.  It is believed that combustion gases and oil mist that are vented
from the engine crankcase are a substantial source of any metallic HAP
emissions from stationary CI engines.  Most existing stationary CI
engines have open crankcases that vent the crankcase emissions directly
to the atmosphere.  It would not be practicable to measure the metallic
HAP emissions since the crankcase is open directly to the atmosphere
rather than vented to the engine exhaust.  Capturing these emissions
using EPA Method 29 would be difficult due to the sporadic flowrate of
the blow-by gases, making isokinetic sampling of the crankcase exhaust
difficult.  In addition, testing for metallic HAP is at least
$15,000-$20,000 per engine, and the emission levels from stationary CI
engines are likely to be below method detection limits, so current test
methods may not be able to accurately measure such emissions. 
Consequently, it would be infeasible to prescribe a numerical emission
standard for metallic HAP for existing stationary CI engines. 
Therefore, the use of OCV or CCV systems would also be justified under
section 112(d)(2)(D) as a design, equipment or work practice.  EPA
believes that a standard that requires the use of OCV or CCV systems
would be the most appropriate method for further reducing metallic HAP
emissions for existing stationary CI engines.  For the purpose of this
analysis, EPA used OCV, rather than CCV as the emission control we would
expect sources to use; while CCV systems that prevent the crankcase
emissions from being emitted to the atmosphere are also an option for
reducing crankcase emissions, EPA does not believe that it is feasible
to retrofit all existing stationary CI engines with CCV systems due to
feasibility concerns.  This was discussed in a meeting between EPA and
the Engine Manufacturers Association and in a letter from EMA to EPA
(see “Summary of the November 19, 2009 Teleconference with the Engine
Manufacturers Association and the U.S. Environmental Protection Agency
to Discuss Crankcase Emissions from Stationary Compression Ignition
Engines”  and EMA’s November 19, 2009 letter to EMA titled “EMA
Response to Question Regarding Crankcase Emission Controls” both
available in the docket (EPA-HQ-OAR-2008-0708)).  

HP≤500

EPA has test data for two engines in this subcategory.  The average of
the top 12 percent of existing sources is therefore based on data from
one engine.  In order to account for emissions variability, the highest
test run for the engine was determined to be the MACT floor.  As shown
in Appendix B, the MACT floor for CI non-emergency stationary RICE
between 300 HP and 500 HP is 137 ppmvd of CO at 15 percent O2.

We also evaluated whether to go beyond-the-floor for this subcategory. 
Specifically, EPA considered additional emission controls to further
reduce HAP emissions.  EPA considered the use of DOC systems in
conjunction with OCV systems.  Stationary existing CI engines were
largely uncontrolled at the Federal level prior to the promulgation of
EPA’s emission standards for stationary CI engines in 2004, which
affected engines constructed beginning in 2002.  Non-emergency CI
engines are estimated to emit 90 percent of total combined PM and
nitrogen oxides (NOX) emissions from all existing stationary CI engines,
with emergency engines emitting the remaining 10 percent.  Of the
non-emergency CI engines, about 50,000 non-emergency engines rated 300
HP or higher were built prior to 2002, which is about 29 percent of the
existing population of non-emergency stationary CI engines.  These
50,000 non-emergency CI engines emit approximately 72 percent of the
total HAP emissions, 66 percent of the total PM emissions, and 62
percent of the total NOX emissions from existing non-emergency
stationary CI engines.  This information is based on data from the Power
Systems Research Database that was presented in Tables 1-4 of EPA’s
January 24, 2008 ANPRM for stationary CI engines emission standards (73
FR 4136).  For these reasons, EPA concluded that it can achieve the
highest level of emission reduction relative to cost, while requiring
controls where appropriate, by requiring more stringent emission
standards on non-emergency stationary CI engines with a power rating
greater than 300 HP.  

EPA evaluated the cost of these systems compared to the emission
reductions that would be achieved by the use of DOC/OCV for engines in
this subcategory and determined that the costs were reasonable when
compared to the amount of emission reductions that would be achieved
through the use of these controls.  For example, the cost per ton of HAP
reduced for non-emergency CI engines between 300 HP and 500 HP is about
$170,000.  Again, the cost per ton is based on reducing HAP emissions by
70 percent from uncontrolled levels.  For a non-emergency 400 HP CI
engine this would equate to an emission reduction of approximately 30
lb/yr; twice that of a 200 HP engine.  For 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).

To determine MACT for non-emergency CI engines greater than 300 HP and
less than or equal to 500 HP, EPA reviewed the test data for CI engines
greater than 300 HP and less than or equal to 500 HP and selected the
highest CO test run for the two engines in that range.  Then, EPA
applied a control efficiency of 70 percent to that CO concentration
level.  The 70 percent reduction efficiency for DOC represents the
lowest reduction in CO from a DOC that was measured during EPA’s
testing of a stationary diesel engine at CSU; the CO reduction measured
during the CSU testing ranged from 70 to 84 percent.  By selecting the
highest CO test run and the lowest reduction percentage, EPA has
accounted for emissions variability in the subcategory while ensuring
that emission levels will be below the MACT floor level after accounting
for emission controls.  Consequently, EPA determined that MACT for HAP
for non-emergency CI engines greater than 300 HP and less than or equal
to 500 HP is 49 ppmvd of CO at 15 percent O2, or 70 percent CO
efficiency.  EPA has also determined that it would be appropriate to
require the use of ultra low sulfur diesel (ULSD) fuel for these
engines.  The use of ULSD is necessary due to concerns about DOCs
simultaneously oxidizing SO2 to form sulfate particulate. A limit on the
diesel fuel sulfur level of 15 ppm will reduce the potential for
increased sulfate emissions from diesel engines equipped with DOCs. The
limit on fuel sulfur will also improve the efficiency of the DOC.  

In order to further reduce metallic HAP emissions, EPA believes it is
appropriate establish a separate requirement for metallic HAP emissions
from the crankcase.  As discussed above, it is not possible to set a
numerical emission standard for metallic HAP.  To reduce emissions of
metallic HAP, an OCV filtration system was considered.  The OCV system
captures blow-by emissions from the pistons, which include both oil mist
and worn metal from the combustion cylinders, and reduces metallic HAP
emissions from the engine.  Closed crankcase ventilation (CCV) systems
that prevent the crankcase emissions from being emitted to the
atmosphere are also an option for reducing crankcase emissions; however
EPA believes that it may not be feasible for some existing stationary CI
engines to retrofit with CCV systems (see “Summary of the November 19,
2009 Teleconference with the Engine Manufacturers Association and the
U.S. Environmental Protection Agency to Discuss Crankcase Emissions from
Stationary Compression Ignition Engines” and EMA’s November 19, 2009
letter to EMA titled “EMA Response to Question Regarding Crankcase
Emission Controls” both available in the docket
(EPA-HQ-OAR-2008-0708)).  Therefore, EPA believes it is appropriate to
provide sources the option to choose either OCV or CCV systems and has
specified that non-emergency CI engines between 300 HP and 500 HP
located at major sources must either:  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.

Of further consideration are the co-benefits that would be achieved by
requiring the use of the DOC/OCV option.  The control technology will
reduce other pollutants such as CO and PM, which are of significant
health concern.  In addition, the requirement will also reduce the
emissions of sulfur dioxide (SO2), because this control option requires
the use of ULSD fuel.  (Note, however that EPA has not quantified the
SO2 emission reductions because EPA is unable to estimate the percentage
of engines that may switch to ULSD in the absence of this rule).   For
instance, the cost per ton of PM reduced for non-emergency CI engines
between 300 HP and 500 HP is around $61,000 and the cost per ton for SO2
is about $32,000.  The cost per ton for PM is based on reducing PM
emissions by 30 percent from uncontrolled levels, which would mean an
emission reduction of more than 80 lb/yr of PM from a 400 HP engine.  It
is estimated that the benefits per ton are $210,000 (Pope, 7%) and
$500,000 (Laden, 7%) for PM2.5 for existing stationary CI engines at
major sources.  It is clear that the overall benefits significantly
outweigh the costs.  Further information on the monetized benefits can
be found in the Regulatory Impact Analysis for the final rule, which is
available from the rulemaking docket.  The total reductions of HAP and
other pollutants from this regulation are presented in the memorandum
titled “Impacts Associated with NESHAP for Existing Stationary CI
RICE,” available from the rulemaking docket.

Non-Emergency CI >500 HP

EPA has test data for eight engines in this subcategory.  The average of
the top 12 percent is therefore based on data for one engine.  To
determine the MACT floor for this subcategory, EPA selected the highest
test run for the MACT floor engine in order to account for emissions
variability.  As shown in Appendix B, the MACT floor for CI
non-emergency stationary RICE greater than 500 HP is 38 ppmvd of CO at
15 percent O2.

We also evaluated whether to go beyond-the-floor for this subcategory. 
Specifically, EPA considered DOC/OCV.  After evaluating the cost of
these controls and the emission reductions that can be achieved for
engines in this subcategory, EPA believes that requiring above-the-floor
levels that are based on DOC/OCV control is appropriate for
non-emergency CI engines greater than 500 HP.  For example, the cost per
ton of HAP reduced for non-emergency CI engines above 500 HP is about
$162,000 or less.  Based on reducing HAP emissions by 70 percent from
uncontrolled levels, annual emission reduction would be approximately 45
lb/yr per engine for a 600 HP engine.  

To determine the above-the-floor emission limitation for non-emergency
CI engines greater than 500 HP, EPA reviewed the test data for CI
engines greater than 500 HP.  EPA applied a control efficiency of 70
percent to the CO concentration level that represented the highest CO
concentration value taken from the CSU-Engines & Energy Conservation
Laboratory data, which tested over a wide range of operating loads.  The
CO reduction measured during the CSU testing ranged from 70 to 84
percent; EPA selected the lowest percent reduction that was measured
during the testing in order to account for emissions variability.  As a
result, EPA determined that MACT for HAP emissions for non-emergency CI
engines greater than 500 HP is 23 ppmvd of CO at 15 percent O2 or 70
percent CO efficiency.  

To further address metallic HAP emissions from stationary non-emergency
CI engines greater than 500 HP, EPA is requiring that these sources
either: 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.

Of further consideration are the co-benefits that would be achieved by
requiring the use of the DOC/OCV option.  The control technology will
reduce other pollutants such as CO and PM, which are of significant
health concern.  In addition, the requirement will also reduce the
emissions of SO2, because this control option requires the use of ULSD
fuel.  (Note, however that EPA has not quantified the SO2 emission
reductions because EPA is unable to estimate the percentage of engines
that may switch to ULSD in the absence of this rule).  The cost per ton
of PM reduced for non-emergency CI engines above 500 HP is less than
$58,000.  The cost per ton of VOC is $7,000 or below for non-emergency
engines above 500 HP.  Again, the cost per ton for PM is based on
reducing PM emissions by 30 percent from uncontrolled levels, which
would mean an emission reduction of more than 120 lb/yr of PM from a 600
HP engine.  Again, the total benefits per ton for existing stationary CI
engines at major sources, which for PM2.5 are $210,000 (Pope, 7%) and
$500,000 (Laden, 7%) show that overall benefits significantly outweigh
the costs.  Further information on the monetized benefits can be found
in the Regulatory Impact Analysis for the final rule, which is available
from the rulemaking docket.  The total HAP and other pollutant
reductions from this regulation are presented in the memorandum titled
“Impacts Associated with NESHAP for Existing Stationary CI RICE,”
available from the rulemaking docket (EPA-HQ-OAR-2008-0708).

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



Appendix B

MACT Floor Summary

Test Facility	Test Date	Engine Number	Engine Size (HP)	Test Method Used
Highest CO run (ppmvd @ 15% O2)	Average CO Concentration (ppmvd @ 15%
O2)	Comments

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

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

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

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

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

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

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

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

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

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

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

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

 	 	 	 	 	 	 	 





	Draft Floor (< 300 HP)	 





	Count	2	 





	Top 12%	1	 





	Ave of Top 12%	230	ppm @15 %O2





	Draft Floor (300-500 HP)	 





	Count	2	 





	Top 12%	1	 





	Ave of Top 12%	137	ppm @15 %O2





	Draft Floor (> 500 HP)	 





	Count	8	 





	Top 12%	1	 





	Ave of Top 12%	38	ppm @15 %O2





	Above the Floor (300-500 HP)







Data Point Used	162.7	ppm @15 %O2





	CO reduction	70	%





	Above the Floor Standard	49	ppm @15 %O2





	Above the Floor (> 500 HP)







Data Point Used	76.8	ppm @15 %O2





	CO reduction	70	%





	Above the Floor Standard	23	ppm @15 %O2



 Note there are more than 30 engines in each subcategory

 Memorandum from Bradley Nelson and Tanya Parise, EC/R Inc. to Melanie
King, EPA OAQPS/SPPD/ESG, Subcategorization of Existing Stationary CI
RICE (see EPA-HQ-OAR-2008-0708).

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ᔀ轨慕ᘀ轨慕　ཊ䠀Īࡕḁ Alpha-Gamma Technologies to Sims
Roy, EPA OAQPS ESD Combustion Group, CO Removal Efficiency as a
Surrogate for HAP Removal Efficiency, January 7, 2004
(EPA-HQ-OAR-2002-0059-0665.)  

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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