  SEQ CHAPTER \h \r 1    

MEMORANDUM

DATE:		August 8, 2010

SUBJECT:	Impacts Associated with NESHAP for Existing Stationary SI RICE

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 provide an estimate of the cost
impacts and the emission reductions of the National Emission Standards
for Hazardous Air Pollutants (NESHAP) for existing spark ignition (SI)
stationary reciprocating internal combustion engines (RICE).  The
regulation applies to existing stationary SI RICE that are less than or
equal to 500 horsepower (HP) located at major sources and all existing
SI RICE at area sources of hazardous air pollutants (HAP) emissions. 
Impacts discussed in this memorandum include emissions reductions and
total costs associated with the regulatory requirements that will be
promulgated under 40 CFR part 63, subpart ZZZZ.  Costs associated with
the final rule include the capital and annual cost of purchasing and
operating air pollution control equipment, recordkeeping, reporting, and
performance testing.  

The total capital cost associated with the NESHAP for existing
stationary SI RICE is estimated to be $383 million in the year 2013. 
The total annual cost of the NESHAP is estimated to be $253 million in
the year 2013.  The NESHAP for existing stationary SI RICE is estimated
to reduce HAP emissions in the year 2013 by 6,000 tons per year (tpy). 

2.0	ENGINE POPULATION

The existing population of SI 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 number of affected SI engines was
estimated using population and engine sales information from PSR.,  In
addition to the PSR data, EPA received SI engine population data from
the U.S. Department of Agriculture (USDA) that provided a summary of SI
engines used as irrigation sets by fuel type and engine size from the
National Agriculture Statistics Service (NASS).  This NASS estimates
were used in lieu of the information from PSR for irrigation sets. 
According to USDA, the majority of irrigation sets are located at area
sources.  Therefore, it was assumed that 95 percent of existing SI
engines that are irrigation sets are located at area sources.  It was
also assumed that 95 percent of existing SI engines used for gas
compression are located at area sources, based on information from the
natural gas transmission industry.  For all other industries and
applications, it was assumed that 60 percent of existing SI engines are
located at area sources.  The number of affected SI engines is presented
in Table 1.

Table 1.  Number of Affected Enginesa

Size Range

(HP)	Major Sources	Area Sources

25-50	55,842	91,709

50-100	14,955 	39,447

100-175	23,679 	48,539

175-300	5,104 	17,393

300-500	3,148	12,499

500-600	N/A	6,250

600-750	N/A	1,071

>750	N/A	11,411

Total	102,729	228,318

aEngines subject to this rule are existing SI engines constructed 
before 6/12/2006 that are less than or equal to 500 HP and located at
major source and existing SI engines constructed before 6/12/2006 and
located at area sources.

3.0	COST IMPACTS

	The cost impacts associated with the final rule 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 certain engines, the final rule sets emission standards based on the
use of oxidation catalyst and non-selective catalytic reduction (NSCR). 
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:

HAP Control Technology	Capital Cost

($2009)	Annual Cost

($2009)

Oxidation Catalyst (4SLB)	$12.8 x HP + $3,069	$1.81 x HP + $3,442

NSCR	$24.9 x HP + $13,118	$4.77 x HP + $5,679



The above control cost equations were calculated using retrofit cost
data received from industry groups, vendors, and manufacturers of engine
control technology.  Documentation for how these control cost equations
were developed is presented in a memorandum available from the
rulemaking docket.  

The final rule emission standards are shown in Table 2.  Engines not
shown in Table 2 are not subject to numerical emission standards in the
final rule, but must meet work practice or management practices instead.
 For engines located at major sources of HAP, it is expected that owners
and operators of existing non-emergency 2SLB engines between 100 HP and
500 HP, existing non-emergency 4SRB engines between 100 HP and 500 HP,
and landfill/digester gas engines will be able to meet the emission
limitation without adding any aftertreatment controls.  Therefore, no
control costs were attributed to these engines.  

Existing non-emergency 4SLB engines between 100 HP and 500 HP at major
sources and existing non-emergency 4SLB engines greater than 500 HP at
area sources are expected to use an oxidation catalyst in order to meet
the emission standards.  Costs estimated for these engines include the
cost of installing and operating an oxidation catalyst for reducing HAP
emissions.  It was assumed that 5 percent of the existing population of
4SLB engines already have add-on controls for HAP reduction, which is
based on information available from the RICE Population Database.

Existing non-emergency 4SRB engines greater than 500 HP at area sources
are expected to use NSCR in order to meet the emission standards.  Costs
estimated for these engines include the cost of installing and operating
NSCR for reducing HAP emissions, assuming that 20 percent of the
existing population already have add-on controls for HAP reduction.  The
percentage of existing 4SRB engines currently operating with add-on
controls used to estimate impacts is based on information from different
sources, including information from different EPA Regional Offices, the
RICE Population Database, and control technology vendors.

Table 2.  Final Emission Standards

Subcategory	Applicable Standard 

2SLB Non-Emergency 100≤HP≤500 

at major sources	225 ppmvd CO at 15% O2	None

4SLB Non-Emergency 100≤HP≤500

at major sources	47 ppmvd CO at 15% O2	Oxidation Catalyst

4SRB Non-Emergency 100≤HP≤500

at major sources	10.3 ppmvd CH2O at 15% O2	None

Landfill/Digester Gas 

Non-Emergency 100≤HP≤500

at major sources	177 ppmvd CO at 15% O2	None

4SLB Non-Emergency >500 HP

at area sources	47 ppmvd CO at 15% O2 or 

93% CO reduction	Oxidation Catalyst

4SRB Non-Emergency >500 HP

at area sources	2.7 ppmvd CH2O at 15% O2 or 

76% CH2O reduction	NSCR



Performance Testing

Existing stationary SI RICE subject to numerical emission standards
under the final rule must conduct an initial performance test to
demonstrate that the standards are being met.  Owners and operators of
SI engines that are not subject to any numerical emission standards are
not subject to any testing requirements, which includes existing
stationary SI engines less than 100 HP at major sources and existing
stationary emergency SI engines less than or equal to 500 HP at major
sources, as well as existing stationary SI engines at area sources
(except non-emergency 4SLB engines greater than 500 HP and non-emergency
engines 4SRB greater than 500 HP).  The following non-emergency existing
stationary SI engines are subject to testing under the final rule:

100≤HP≤500 located at major sources,

4SLB 100≤HP≤500 located at major sources,

4SRB 100≤HP≤500 located at major sources,

Landfill/digester gas 100≤HP≤500 located at major sources, 

4SLB >500 HP located at area sources, and

4SRB >500 HP located at area sources.

The cost of conducting carbon monoxide (CO) performance testing for 2SLB
and 4SLB engines is based on the cost of portable analyzer testing and
is estimated to be $1,000 per day.  It was assumed that 2 engines could
be tested each day using the portable analyzer, therefore the costs per
engine was estimated to be $500.  The testing costs are based on
information previously obtained from engine testing firms and summarized
in the memorandum “Portable Analyzer Testing Costs.”   The cost of
conducting formaldehyde performance testing for non-emergency 4SRB
engines was estimated to be $2,000 per day, with two engines being
tested per day.  Therefore the testing cost was estimated to be $1,000
per engine for formaldehyde testing.  

Recordkeeping

Recordkeeping costs were calculated assuming 1 hour per year for each
existing SI engine.  The costs are attributed to the requirement of
following the manufacturer’s emission-related operation and
maintenance (O&M) requirements or the owner/operator’s own maintenance
plan.  It is expected that the majority of owner/operators are already
following some type of O&M requirements and minimal to no additional
burden is expected.  A technical labor rate of $73 per hour was used to
estimate the cost and is based on technical labor rates obtained from
the Bureau of Labor Statistics.  All costs were converted to 2009
dollars for purposes of presenting costs associated with the rule in
present day terms.  The recordkeeping cost for emergency SI engines is
estimated to be 1 hour per year to record the number of hours the
emergency engine is operated.

Reporting

	Certain non-emergency 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 semi-annual compliance reports.  It
is estimated that a total of 14 hours will be needed, where 4 hours are
expected to be used for reading the rule, 4 hours are estimated to be
used for training, and 6 hours are expected to be used for preparing and
submitting notifications and compliance reports.  Owners and operators
of SI engines that are not subject to any numerical emission standards
are not subject to any reporting requirements.  This includes existing
emergency SI engines less than or equal to 500 HP located at major
sources, existing SI engines less than 100 HP located at major sources,
and existing SI engines at area sources (except non-emergency 4SLB
greater than 500 HP and non-emergency 4SRB greater than 500 HP).  The
following non-emergency existing stationary SI engines are subject to
reporting requirements under the final rule:

2SLB 100≤HP≤500 located at major sources,

4SLB 100≤HP≤500 located at major sources,

4SRB 100≤HP≤500 located at major sources,

4SLB >500 HP located at area sources, and

4SRB >500 HP located at area sources.

Monitoring

The cost of monitoring includes the purchase of a continuous parametric
monitoring system (CPMS).  Existing non-emergency 4SLB greater than 500
HP at area sources and existing non-emergency 4SRB engines greater than
500 HP at area sources 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
current a cost of $568.  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. 
There are no costs associated with monitoring for emergency engines.

Summary of Costs

The total costs estimated for the final rule requirements include the
purchase, installation, and operation of aftertreatment controls and
monitoring equipment, performance testing, and the costs associated with
recordkeeping, notification, and reporting requirements.  The total
estimated costs associated with the final rule in the year 2013 are
presented in Table 3 through Table 7.  

Table 3.  Summary of Major Source and Area Source Costs for the SI RICE
NESHAP1

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

Major Sources

25-50	$0 	$0 	$0	$4,060,795	$0	$0	$0	$4,060,795	$0

50-100	$0 	$0 	$0	$1,087,540	$0	$0	$0	$1,087,540	$0

100-175	$48,502,361 	$37,071,061 	$15,971,384	$1,721,899	$5,725,314	$0
$0	$60,489,657	$48,502,361

175-300	$13,225,919 	$8,382,568 	$3,442,648	$371,157	$1,234,097	$0	$0
$13,430,470	$13,225,919

300-500	$10,934,795 	$5,562,872 	$2,123,326	$228,919	$761,155	$0	$0
$8,676,272	$10,934,795

500-600	$0 	$0 	$0	$0	$0	$0	$0	$0	$0

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

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

Total	$72,663,076	$51,016,500	$21,537,358	$7,470,310	$7,720,566	$0	$0
$87,744,734	$72,663,076

Area Sources

25-50	$0 	$0 	$0	$6,668,944	$0	$0	$0	$6,668,944	$0

50-100	$0 	$0 	$0	$2,868,511	$0	$0	$0	$2,868,511	$0

100-175	$0 	$0 	$0	$3,529,711	$0	$0	$0	$3,529,711	$0

175-300	$0 	$0 	$0	$1,264,799	$0	$0	$0	$1,264,799	$0

300-500	$0 	$0 	$0	$908,913	$0	$0	$0	$908,913	$0

500-600	$75,474,331 	$26,628,053 	$3,655,719	$454,493	$1,264,260
$2,821,013	$13,003,822	$45,006,347	$78,295,345

600-750	$15,222,363 	$5,052,207 	$652,400	$77,882	$225,620	$503,438
$2,320,662	$8,328,771	$15,725,801

>750	$210,754,181 	$62,143,967 	$6,951,011	$829,795	$2,403,874
$5,363,896	$24,725,562	$97,054,209	$216,118,077

Total	$301,450,875	$93,824,227	$11,259,129	$16,603,048	$3,893,754
$8,688,347	$40,050,046	$165,630,205	$310,139,222

Grand Total	$374,113,951	$144,840,727	$32,796,487	$24,073,358
$11,614,321	$8,688,347	$40,050,046	$253,374,939	$382,802,298

a Costs are presented in 2009 dollars.

Table 4.  Summary of Major Source and Area Source NAICS Costs for the
SI 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)	$52,905,258	$63,062,494	$120,301,416
$65,334,028	$173,206,675	$128,396,522

Natural Gas Transmission (48621)	$1,484,494	$1,462,530	$140,977,276
$67,467,484	$142,461,771	$68,930,015

Crude Petroleum & NG Production (211111)	$4,561,236	$6,138,383	$732,943
$1,258,072	$5,294,179	$7,396,454

Natural Gas Liquid Producers (211112)	$4,561,236	$6,138,383	$732,943
$1,258,072	$5,294,179	$7,396,454

National Security (92811)	$5,878,362	$7,006,944	$13,366,824	$7,259,336
$19,245,186	$14,266,280

Hydro Power Units (335312)	$0	$25,248	$0	$37,872	$0	$63,120

Irrigation Sets (335312)	$3,025,050	$3,230,856	$34,027,819	$22,445,211
$37,052,869	$25,676,067

Welders (333992)	$247,440	$679,896	$0	$570,130	$247,440	$1,250,027

Total	$72,663,076	$87,744,734	$310,139,222	$165,630,205	$382,802,298
$253,374,939

a Costs are presented in 2009 dollars.

Table 5.  Summary of Major Source and Area Source NAICS Costs for the
SI 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)	 	 	 	 	 	 

25-50 hp	$0	$2,758,459	$0	$4,137,688	$0	$6,896,147

50-100 hp	$0	$606,144	$0	$909,215	$0	$1,515,359

100-175 hp	$33,868,173	$42,238,648	$0	$1,803,548	$33,868,173	$44,042,196

175-300 hp	$10,603,849	$10,767,847	$0	$446,361	$10,603,849	$11,214,209

300-500 hp	$8,433,236	$6,691,397	$0	$264,820	$8,433,236	$6,956,217

500-600 hp	$0	$0	$26,390,293	$15,169,876	$26,390,293	$15,169,876

600-750 hp	$0	$0	$5,325,628	$2,820,584	$5,325,628	$2,820,584

>750 hp	$0	$0	$88,585,495	$39,781,934	$88,585,495	$39,781,934

Total Electric Power Generation 2211	$52,905,258	$63,062,494
$120,301,416	$65,334,028	$173,206,675	$128,396,522

Natural Gas Transmission (48621)	 	 	 	 	 	 

25-50 hp	$0	$102	$0	$1,934	$0	$2,036

50-100 hp	$0	$4,872	$0	$92,571	$0	$97,443

100-175 hp	$301,721	$376,291	$0	$203,518	$301,721	$579,809

175-300 hp	$643,157	$653,104	$0	$342,928	$643,157	$996,032

300-500 hp	$539,617	$428,162	$0	$214,637	$539,617	$642,799

500-600 hp	$0	$0	$19,975,323	$11,482,372	$19,975,323	$11,482,372

600-750 hp	$0	$0	$9,808,436	$5,194,789	$9,808,436	$5,194,789

>750 hp	$0	$0	$111,193,518	$49,934,735	$111,193,518	$49,934,735

Total Natural Gas Transmission (48621)	$1,484,494	$1,462,530
$140,977,276	$67,467,484	$142,461,771	$68,930,015

Crude Petroleum & NG Production (211111)	 	 	 	 	 	 

25-50 hp	$0	$388,115	$0	$582,173	$0	$970,288

50-100 hp	$0	$66,698	$0	$100,047	$0	$166,744

100-175 hp	$4,549,775	$5,674,246	$0	$242,285	$4,549,775	$5,916,531

175-300 hp	$1,037	$1,053	$0	$44	$1,037	$1,096

300-500 hp	$10,424	$8,271	$0	$327	$10,424	$8,598

500-600 hp	$0	$0	$32,184	$18,500	$32,184	$18,500



Table 5.  Summary of Major Source and Area Source NAICS Costs for the SI
RICE NESHAP – by Size1 (cont’d)

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

>750 hp	$0	$0	$700,760	$314,697	$700,760	$314,697

Total Crude Petroleum & NG Production (211111)	$4,561,236	$6,138,383
$732,943	$1,258,072	$5,294,179	$7,396,454

Natural Gas Liquid Producers (211112)	 	 	 	 	 	 

25-50 hp	$0	$388,115	$0	$582,173	$0	$970,288

50-100 hp	$0	$66,698	$0	$100,047	$0	$166,744

100-175 hp	$4,549,775	$5,674,246	$0	$242,285	$4,549,775	$5,916,531

175-300 hp	$1,037	$1,053	$0	$44	$1,037	$1,096

300-500 hp	$10,424	$8,271	$0	$327	$10,424	$8,598

500-600 hp	$0	$0	$32,184	$18,500	$32,184	$18,500

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

>750 hp	$0	$0	$700,760	$314,697	$700,760	$314,697

Total Natural Gas Liquid Producers (211112)	$4,561,236	$6,138,383
$732,943	$1,258,072	$5,294,179	$7,396,454

National Security (92811)	 	 	 	 	 	 

25-50 hp	$0	$306,495	$0	$459,743	$0	$766,239

50-100 hp	$0	$67,349	$0	$101,024	$0	$168,373

100-175 hp	$3,763,130	$4,693,183	$0	$200,394	$3,763,130	$4,893,577

175-300 hp	$1,178,205	$1,196,427	$0	$49,596	$1,178,205	$1,246,023

300-500 hp	$937,026	$743,489	$0	$29,424	$937,026	$772,913

500-600 hp	$0	$0	$2,932,255	$1,685,542	$2,932,255	$1,685,542

600-750 hp	$0	$0	$591,736	$313,398	$591,736	$313,398

>750 hp	$0	$0	$9,842,833	$4,420,215	$9,842,833	$4,420,215

Total Natural Gas Liquid Producers (211112)	$5,878,362	$7,006,944
$13,366,824	$7,259,336	$19,245,186	$14,266,280

Hydro Power Units (335312)	 	 	 	 	 	 

25-50 hp	$0	$22,688	$0	$34,032	$0	$56,721

50-100 hp	$0	$2,560	$0	$3,840	$0	$6,399

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

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

300-500 hp	$0	$0	$0	$0	$0	$0

500-600 hp	$0	$0	$0	$0	$0	$0

Table 5.  Summary of Major Source and Area Source NAICS Costs for the SI
RICE NESHAP – by Size1 (cont’d)

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

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

Total Hydro Power Units (335312)	$0	$25,248	$0	$37,872	$0	$63,120

Irrigation Sets (335312)	 	 	 	 	 	 

25-50 hp	$0	$32,913	$0	$625,338	$0	$658,251

50-100 hp	$0	$65,825	$0	$1,250,677	$0	$1,316,502

100-175 hp	$1,222,348	$1,524,449	$0	$824,505	$1,222,348	$2,348,954

175-300 hp	$798,634	$810,986	$0	$425,827	$798,634	$1,236,813

300-500 hp	$1,004,068	$796,683	$0	$399,376	$1,004,068	$1,196,060

500-600 hp	$0	$0	$28,933,107	$16,631,556	$28,933,107	$16,631,556

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

>750 hp	$0	$0	$5,094,712	$2,287,931	$5,094,712	$2,287,931

Total Irrigation Sets (335312)	$3,025,050	$3,230,856	$34,027,819
$22,445,211	$37,052,869	$25,676,067

Welders (333992)	 	 	 	 	 	 

25-50 hp	$0	$163,908	$0	$245,862	$0	$409,771

50-100 hp	$0	$207,394	$0	$311,091	$0	$518,485

100-175 hp	$247,440	$308,594	$0	$13,177	$247,440	$321,771

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

300-500 hp	$0	$0	$0	$0	$0	$0

500-600 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)	$247,440	$679,896	$0	$570,130	$247,440	$1,250,027

Total	$72,663,076	$87,744,734	$310,139,222	$165,630,205	$382,802,298
$253,374,939



Table 6.  Summary of Major Source and Area Source NAICS Costs for the
SI RICE NESHAP – by Number of Engines1

NAICS	Number of Engines	Total (Major + Area)

	Major	Area	Total	Capital Cost	Annual Cost

Electric Power Generation (2211)	 	 	 	 	 

25-50 hp	37,933	56,900	94,833	$0	$6,896,147

50-100 hp	8,336	12,503	20,839	$0	$1,515,359

100-175 hp	16,534	24,802	41,336	$33,868,173	$44,042,196

175-300 hp	4,092	6,138	10,230	$10,603,849	$11,214,209

300-500 hp	2,428	3,642	6,070	$8,433,236	$6,956,217

500-600 hp	0	2,107	2,107	$26,390,293	$15,169,876

600-750 hp	0	363	363	$5,325,628	$2,820,584

>750 hp	0	4,677	4,677	$88,585,495	$39,781,934

Total Electric Power Generation 2211	69,323	111,132	180,455	$173,206,675
$128,396,522

Natural Gas Transmission (48621)	 	 	 	 	 

25-50 hp	1	27	28	$0	$2,036

50-100 hp	67	1,273	1,340	$0	$97,443

100-175 hp	147	2,799	2,946	$301,721	$579,809

175-300 hp	248	4,716	4,964	$643,157	$996,032

300-500 hp	155	2,952	3,107	$539,617	$642,799

500-600 hp	0	1,595	1,595	$19,975,323	$11,482,372

600-750 hp	0	668	668	$9,808,436	$5,194,789

>750 hp	0	5,871	5,871	$111,193,518	$49,934,735

Total Natural Gas Transmission (48621)	619	19,899	20,519	$142,461,771
$68,930,015

Crude Petroleum & NG Production (211111)	 	 	 	 	 

25-50 hp	5,337	8,006	13,343	$0	$970,288

50-100 hp	917	1,376	2,293	$0	$166,744

100-175 hp	2,221	3,332	5,553	$4,549,775	$5,916,531

175-300 hp	0	1	1	$1,037	$1,096

300-500 hp	3	5	8	$10,424	$8,598

500-600 hp	0	3	3	$32,184	$18,500



Table 6.  Summary of Major Source and Area Source NAICS Costs for the SI
RICE NESHAP – by Number of Engines1 (cont’d)

600-750 hp	0	0	0	$0	$0

>750 hp	0	37	37	$700,760	$314,697

Total Crude Petroleum & NG Production (211111)	8,479	12,758	21,237
$5,294,179	$7,396,454

Natural Gas Liquid Producers (211112)	 	 	 	 	 

25-50 hp	5,337	8,006	13,343	$0	$970,288

50-100 hp	917	1,376	2,293	$0	$166,744

100-175 hp	2,221	3,332	5,553	$4,549,775	$5,916,531

175-300 hp	0	1	1	$1,037	$1,096

300-500 hp	3	5	8	$10,424	$8,598

500-600 hp	0	3	3	$32,184	$18,500

600-750 hp	0	0	0	$0	$0

>750 hp	0	37	37	$700,760	$314,697

Total Natural Gas Liquid Producers (211112)	8,479	12,758	21,237
$5,294,179	$7,396,454

National Security (92811)	 	 	 	 	 

25-50 hp	4,215	6,322	10,537	$0	$766,239

50-100 hp	926	1,389	2,315	$0	$168,373

100-175 hp	1,837	2,756	4,593	$3,763,130	$4,893,577

175-300 hp	455	682	1,137	$1,178,205	$1,246,023

300-500 hp	270	404	674	$937,026	$772,913

500-600 hp	0	234	234	$2,932,255	$1,685,542

600-750 hp	0	40	40	$591,736	$313,398

>750 hp	0	520	520	$9,842,833	$4,420,215

Total Natural Gas Liquid Producers (211112)	7,702	12,347	20,050
$19,245,186	$14,266,280

Hydro Power Units (335312)	 	 	 	 	 

25-50 hp	312	468	780	$0	$56,721

50-100 hp	35	53	88	$0	$6,399

100-175 hp	0	0	0	$0	$0

175-300 hp	0	0	0	$0	$0

300-500 hp	0	0	0	$0	$0

500-600 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)	347	521	868	$0	$63,120

Irrigation Sets (335312)	 	 	 	 	 

25-50 hp	453	8,599	9,052	$0	$658,251

50-100 hp	905	17,199	18,104	$0	$1,316,502

100-175 hp	597	11,338	11,935	$1,222,348	$2,348,954

175-300 hp	308	5,856	6,164	$798,634	$1,236,813

300-500 hp	289	5,492	5,781	$1,004,068	$1,196,060

500-600 hp	0	2,310	2,310	$28,933,107	$16,631,556

600-750 hp	0	0	0	$0	$0

>750 hp	0	269	269	$5,094,712	$2,287,931

Total Irrigation Sets (335312)	2,552	51,063	53,615	$37,052,869
$25,676,067

Welders (333992)	 	 	 	 	 

25-50 hp	2,254	3,381	5,635	$0	$409,771

50-100 hp	2,852	4,278	7,130	$0	$518,485

100-175 hp	121	181	302	$247,440	$321,771

175-300 hp	0	0	0	$0	$0

300-500 hp	0	0	0	$0	$0

500-600 hp	0	0	0	$0	$0

600-750 hp	0	0	0	$0	$0

>750 hp	0	0	0	$0	$0

Total Welders (333992)	5,227	7,840	13,067	$247,440	$1,250,027

Total	102,729	228,319	331,047	$382,802,298	$253,374,939

4.0	EMISSION REDUCTIONS

The emissions reductions associated with the final rule are based on
requiring emission standards that are based on applying add-on controls
to existing non-emergency 4SLB engines from 100 HP to 500 HP at major
sources, non-emergency 4SLB engines greater than 500 HP at area sources,
and non-emergency 4SRB engines greater than 500 HP at area sources. 
Baseline emissions were calculated using the existing stationary SI
engine emission factors and control efficiencies presented below
assuming 2,800 hours per year (hrs/yr) for non-emergency operation and
50 hrs/yr for emergency operation.  It was also assumed for purposes of
estimating reductions associated with the final rule that 5 percent of
existing 4SLB engines and 20 percent of existing 4SRB engines are
currently operating with add-on controls that reduce HAP emissions.  In
addition, the Engine Manufacturers Association (EMA) has indicated that
about 5 percent of stationary SI engines are used for emergency
operation.  These engines are predominantly 4SRB engines, according to
EMA.  To calculate the tpy emissions reductions associated with the
final rule, the following general equation was used:

EFpollutant (lb/hp-hr) x (hp) x (hrs/yr) x (ton/2,000 lb) x (# of
engines) x (% reduction)

Emission Factors:

Engine	HAP

(lb/hp-hr)	CO

(lb/hp-hr)	NOx

(lb/hp-hr)	VOC

(lb/hp-hr)

2SLB	5.96x10-4 	1.06x10-2 	4.18x10-2 	3.07x10-3

4SLB	5.41x10-4 	3.92x10-3 	1.15x10-2 	2.78x10-3

4SRB	2.43x10-4 	1.93x10-2 	1.47x10-2 	1.25x10-3



The emission factors were derived using data available in EPA’s
Emissions Database for stationary engines and emissions data received
following the proposed rule and are presented in a memorandum available
from the rulemaking docket.

Control Efficiencies:

Technology	HAP	CO	NOx

4SLB Ox. Catalyst	71%	94%	N/A

4SRB NSCR	76%	49%	97%



The control efficiencies are based on the average percent reduction
observed during EPA’s testing program at Colorado State University. 
The results from this testing are available from   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov  as Document ID Number
EPA-HQ-OAR-2002-0059-0665.

Based on the above assumptions and the existing population of engines
shown in Table 1 of this memorandum, the HAP, CO, NOx, and VOC baseline
emissions and reductions were calculated.  The estimated reductions as a
result of the final rule are shown in Table 7. 

Table 7.  Summary of Emissions Reductions for the SI RICE NESHAP

Engine Size 

(HP)	Emission Reductions (tpy)

	HAP	CO	NOx	VOC

Major Sources

25-50	0	0	0	0

50-100	0	0	0	0

100-175	744	7,124	0	3,826

175-300	277	2,653	0	1,424

300-500	288	2,755	0	1,480

500-600	N/A	N/A	N/A	N/A

600-750	N/A	N/A	N/A	N/A

>750	N/A	N/A	N/A	N/A

Total	1,308	12,532	0	6,730

Area Sources

25-50	0	0	0	0

50-100	0	0	0	0

100-175	0	0	0	0

175-300	0	0	0	0

300-500	0	0	0	0

500-600	1,005	20,698	20,632	5,170

600-750	220	4,533	4,519	1,132

>750	3,475	71,557	71,328	17,874

Total	4,700	96,789	96,479	24,177

Grand Total	6,008	109,321	96,479	30,907



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

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 Memorandum from Tanya Parise, EC/R to Melanie King, EPA.  Existing
Population of Stationary RICE Attachments.  February 10, 2010.

 Letter from the American Petroleum Institute to EPA.  Support for Use
of Management Practices in the 

National Emission Standards for Hazardous Air Pollutants Standards for
Reciprocating Internal Combustion Engines at Area Sources in Rural
Locations.  November 2009.

 Memorandum from Bradley Nelson, EC/R to Melanie King, EPA
OAQPS/SPPD/ESG, Control Costs for Existing Stationary SI RICE, June 29,
2010.

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

   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, EC/R to Melanie King, EPA
OAQPS/SPPD/ESG, Emission Factors for Existing Stationary SI RICE, August
3, 2010.

 Letter from Joe Suchecki, EMA to Sims Roy, EPA.  EMA Response to
Questions on Proposed SI NSPS.  September 19, 2005.  

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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