  SEQ CHAPTER \h \r 1 MEMORANDUM

DATE:		March 7, 2011

SUBJECT:	Cost and Environmental Impacts for Amendments to CI NSPS

FROM:	Tanya Parise, EC/R, Inc.

		

TO:		Melanie King, EPA OAQPS/SPPD/ESG

1.0	PURPOSE

The purpose of this memorandum is to present the estimated impacts
associated with amendments to the new source performance standards
(NSPS) for stationary compression ignition (CI) internal combustion
engines.  The original CI NSPS was published as 40 CFR part 60, subpart
IIII on June 11, 2006 (71 FR 39154).  EPA proposed amendments to the CI
NSPS on June 8, 2010 (75 FR 32612).  

The amendments are expected to reduce particulate matter (PM1) by 8 tons
per year (tpy), nitrogen oxides (NOx) by 295 tpy, and hydrocarbons (HC)
by 4 tpy in 2018.  Impacts are presented for the year 2018 because the
year 2018 is the first year the emission standards will be fully
implemented for stationary CI engines between 10 and 30 liters per
cylinder (l/cyl).  The capital cost associated with the amendments to
the CI NSPS is $236,000 ($2009) in 2018.  The annual cost is estimated
to be $142,000 ($2009) in 2018.  In the year 2030, the amendments are
expected to reduce PM by 38 tpy, NOx by 1,100 tpy, and HC by 18 tpy. 
The capital and annual cost in year 2030 are estimated at $235,000 and
$711,000 ($2009), respectively.  EPA did not receive any comments on the
environmental and cost impacts that were estimated for the proposed rule
and EPA is finalizing the emission standards as proposed.  The impacts
for the final rule are therefore consistent with those estimated for the
proposed rule.

2.0	BACKGROUND

	EPA is amending the CI NSPS for stationary engines that were published
on June 11, 2006.  Based on a settlement agreement resulting from a
legal challenge to the original rule, EPA had to amend the CI NSPS to
address certain issues and problems identified by the petitioner.  The
impacts discussed in this memorandum are based on implementing more
stringent standards for stationary CI engines with a displacement
greater than or equal to 10 l/cyl and less than 30 l/cyl, consistent
with recent revisions to standards for similar mobile source marine
engines.  No other changes that EPA is making are expected to have an
environmental or cost impact.  

	

	

	Specifically, EPA is amending the CI NSPS to require stationary CI
engines greater than or equal to 10 l/cyl and less than 30 l/cyl to meet
the emission standards for the same size and displacement engines as
currently required under 40 CFR part 1042, Control of Emissions from New
and In-Use Marine Compression-Ignition Engines and Vessels.  These
standards will be phased-in between 2013 and 2017 model year engines
depending on the size and displacement.

3.0	BASIS OF ESTIMATED EMISSION REDUCTIONS

The 40 CFR part 1042 emission standards include recently finalized more
stringent standards, i.e., Tier 3 and Tier 4 emission standards, and are
the standards that EPA is adopting for stationary CI engines greater
than or equal to 10 l/cyl and less than 30 l/cyl.  Tier 3 standards are
based on in-engine controls and ultra low sulfur diesel.  The Tier 4
standards are based on diesel particulate filters (DPF) and selective
catalytic reduction (SCR).  Consistent with how EPA has treated
stationary emergency CI engines in the past, EPA is not requiring
standards that force aftertreatment for stationary emergency CI engines.
 Only stationary non-emergency CI engines greater than or equal to 10
l/cyl and less than 30 l/cyl will be subject to emission standards based
on aftertreatment under the final amended rule.

In order to estimate the number of new stationary CI in the displacement
range that would be subject to Tier 3 and Tier 4 emission standards
under the amendments to the CI NSPS, EPA obtained information from the
Engine Manufacturers Association (EMA).  According to EMA, it is
estimated that 8 new engines between 10 l/cyl and 30 l/cyl would be
produced yearly and would become subject to the rule.  Of these 8
engines, 3 are expected to be non-emergency engines and 5 are expected
to be emergency engines, according to EMA.  These engines are primarily
used to generate electricity, either in remote areas or for backup power
at nuclear power plants or other large facilities, and are also used for
emergency flood water pumps.

In order to estimate the pollutant reductions for stationary CI engines
between 10 l/cyl and 30 l/cyl that would be subject to 40 CFR part 1042
emission standards, EPA compared Tier 4 emission standards from 40 CFR
part 1042 to the previous standards that applied to these engines under
the CI NSPS, which were consistent with the emission standards in 40 CFR
part 94.  EPA used emission standards from Tables 3-16 and 3-41 of the
2008 Regulatory Impact Analysis (RIA) for locomotive and marine CI
engines.  The cumulative emissions reductions associated with the
amendments in the year 2018 are 8 tpy of PM, 295 tpy of NOx, and 4 tpy
of HC.  The year 2018 is the first year these emission standards would
be fully implemented for stationary CI engines between 10 and 30 liters
l/cyl.  In the year 2030, the cumulative emissions reductions are
estimated at 38 tpy of PM4, 1,100 tpy of NOx, and 18 tpy of  HC.  

4.0	BASIS OF ESTIMATED COSTS TO AFFECTED SOURCES

	In order to estimate the costs associated with requiring Tier 4
emission standards for new non-emergency stationary CI engines, EPA
consulted with the Office of Transportation and Air Quality (OTAQ).  EPA
used the costs presented in the 2008 RIA for locomotive and marine
engines2 in order to estimate the cost associated with meeting Tier 4
emission standards based on aftertreatment controls.  Specifically,
after consulting with OTAQ, it was found most appropriate to use the
hardware (or variable) costs in Tables 7A-5 and 7A-6 and the auxiliary
engine costs from Tables 7B-20 and 7B-21 of the 2008 RIA for locomotive
and marine engines.2  The hardware and auxiliary costs were multiplied
by the number of new stationary non-emergency CI engines between 10
l/cyl and 30 l/cyl to determine the total capital costs.  No capital
costs were attributed to new stationary emergency CI engines between 10
l/cyl and 30 l/cyl because these engines will not be subject to emission
standards that force aftertreatment.  The capital cost associated with
the amendments to the CI NSPS is $236,000 ($2009) in 2018.

The annual costs associated with the requirements for new non-emergency
CI engines between 10 l/cyl and 30 l/cyl include the operating costs for
the urea usage for the SCR control system, DPF maintenance, and the
increased fuel consumption associated with DPF.  These annual cost
elements were estimated based on communication with OTAQ, and
information from Nonroad Engine Modeling documents.  The following
assumptions were used in order to determine the annual costs:

Brake specific fuel consumption (BSFC):	0.367 lb/HP-hr

Urea cost:					$1.34/gallon

Urea usage rate:				4% of fuel used

DPF maintenance cost:			$200/200,000 gallons

Increased fuel usage:				1%

Diesel fuel price:				$1.57/gallon

Fuel density:					7.1 lb/gallons

Hours of operation:				1,000 hrs/yr

The annual fuel usage, annual urea usage cost, annual DPF maintenance
cost, and increased fuel usage cost were estimated as follows:

Fuel Usage (gal/yr) = [BSFC (lb-HP-hr) x Engine Size (HP) x Operation
(hrs/yr)] / Fuel Density (lb/gal)

Urea Usage Cost ($/yr) = Fuel Usage (gal/yr) x Urea Usage Rate (% of
Fuel Used) x Urea Cost ($/gal)

DPF Maintenance Cost ($/yr) = Fuel Usage (gal/yr) x DPF Maintenance Cost
($200/200,000 gal)

Increased Fuel Usage Cost ($/yr) = Fuel Usage (gal/yr) x Increased Fuel
Usage (%) x Fuel Cost ($/gal)

 All PM emissions are in fine particulate (PM2.5) mass fraction.  

 Email from Joe Suchecki, EMA to Tanya Parise, EC/R, Inc.  April 7,
2010.

 Regulatory Impact Analysis: Control of Emissions of Air Pollution from
Locomotive Engines and Marine Compression Ignition Engines Less than 30
Liters Per Cylinder, EPA420-R-08-001a May 2008.

All PM emissions are in fine particulate (PM2.5) mass fraction.  

 Email from Todd Sherwood, OTAQ to Tanya Parise, EC/R, Inc.  October 6,
2009.

 Email from Todd Sherwood, OTAQ to Tanya Parise, EC/R, Inc.  April 21,
2010.

 Exhaust and Crankcase Emission Factors for Nonroad Engine Modeling --
Compression Ignition EPA420--P-04-009 April 2004 NR-009c.

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