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Technical Report
Cost Effectiveness of Large Aircraft
Engine Emission Controls
Final Report
by
Richard S. Wilcox
December 1979
NOTICE
Technical Reports do not necessarily represent final EPA
decisions or positions. They are intended to present tech-
nical analysis of issues using data which are currently
available. The purpose in the release of such reports is to
facilitate the exchange of technical information and to inform
the public of technical developments which may form the basis
for a final EPA decision, position or regulatory action.
Standards Development and Support Branch
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
Office of Air, Noise and Radiation
U.S. Environmental Protection Agency
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EXECUTIVE SUMMARY
Introduction
To determine the most efficient means of achieving the
National Ambient Air Quality Standards (42 CFR §420), the cost
effectiveness of various pollution abatement strategies is com-
pared and the most effective are implemented. This report contains
the final cost-effectiveness analysis of alternative aircraft
emission control strategies. It was prepared in support of the
current rulemaking action on aircraft engine gaseous exhaust
emission standards (43 FR 12615).
The cost effectiveness of promulgating alternative emission
standards was determined by evaluating several emission control
scenarios which are based on three basic control strategies. The
three strategies are:
1. 1982 NME — Control newly-manufactured commercial gas
turbojet or turbofan engines in 1982 for HG and CO;
2. 1986 IUE — Retrofit in-use commercial gas turbojet or
turbofan engines by 1986 for HC and CO; and
3. 1986 NME — Control newly-manufactured commercial gas
turbojet or turbofan engines in 1986 for HC, CO, and NOx.
Cost-effectiveness values were developed for the following emission
control scenarios:
1. 1982 NME only;
2. 1982 NME and 1986 IUE only;
3. 1982 NME in conjunction with 1986 NME;
4. 1982 NME and 1986 IUE in conjunction with 1986 NME;
5. 1986 NME only;
6. 1982 NME only, when CF6 engines use an alternative
combustor;
7. 1982 NME and 1986 IUE with the CF6 alternative combustor;
8. 1986 NME in conjunction with 1982 standards; and
9. 1986 NME in conjunction with 1982 standards and the CF6
alternative combustor.
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11
The 1986 IUE Standard was not evaluated as a separate control
scenario because it would not be implemented without an accompany-
ing newly-manufactured engine standard. The retrofit (1986 IDE) is
evaluated, however, as a control strategy to detemine its incre-
mental cost effectiveness as an addition to the 1982 NME Standard.
This report is the result of a comprehensive effort by
EPA to accurately assess the cost effectiveness of the proposed
aircraft engine emission standards. Consequently all of the major
costs of pollution control for large turbine engines were analyzed
and documented., A special effort was made to ensure the validity of
the economic impact analysis by assembling cost information from
several sources. EPA was able to independently judge the accur-
acy of the cost data used in this study by: 1) gathering cost data
from manufacturers in a standardized format to allow comparisons
between industry sources; 2) using information from other sources
including major airlines, original equipment vendors, independent
manufacturers of engine combustion chambers, and previous EPA
reports and contract efforts; and 3) preparing new cost estimates
with the data elements acquired from the above sources.
In spite of the efforts made to gather accurate cost data and
because of uncertainties in forecasting future airline aircraft
requirements, the values derived in this analysis should be inter-
preted as being representative and not absolute indicators of cost
effectiveness.
Methodology
The procedure used in this analysis consisted of determining
the annual costs and exhaust emission reductions for the fleet-
weighted average engine under each control scenario or strategy, as
appropriate. A portion of the total annual cost was allocated to
the reduction of each pollutant by using either of two method-
ologies. The methodologies differ in the way the cost is dis-
tributed among the pollutants.
The first method divides the control costs equally between the
pollutants being regulated by each particular standard. The second
method allocates the compliance costs by specifying a maximum
allowable cost-effectiveness value for one or more of the pollu-
tants. The remaining unaccounted for portion of the total cost is
then burdened to the pollutants for which no cost-effectiveness
values were specified. Regardless of the cost methodology which
was used, the resulting HC, CO, and NOx cost-effectiveness factors
are defined in terms of dollars spent per ton of pollutant reduced
($/t). The costs of pollution control are expressed in 1978
dollars throughout this analysis.
The relative cost effectiveness of the aircraft engine
standards was evaluated by comparing their costs and benefits with
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ill
those for non-aircraft control strategies which are either present-
ly in effect, or may be implemented in the future.
Results
The 1982 Newly-Manufactured Engine (NME) and 1986 In-Use
Engine (IUE) Standards were found to be as cost effective as other
non-aricraft control strategies under every scenario evaluated.
However, no scenario containing the 1986 NME low-NOx standard was
found to be as cost effective at this time. The higher cost-
effectiveness values for NOx control are principally caused by
a large maintenance increase which appears to be associated with
low-NOx stage-combustion systems.
The effect on cost-effectiveness values of excluding sunk
investment costs was investigated since money which has already
been spent is not relevant to the present issue of deciding whether
or not to proceed with implementing the aircraft standards. It was
found that by using only the costs which have yet to be spent, the
cost-effectiveness values of the 1982 NME and 1986 IUE Standards
were reduced up to about 45 percent from the figures derived by
using the total cost (past and present) of the standards. The
cost-effectiveness values for the 1986 NME low-NOx standard were
not significantly affected. None of the cost-effectiveness values
for any of the standards were sensitive to reasonable changes in
the projection of new engine production.
The cost-effectiveness values for aircraft exhaust emission
standards are summarized below. They were calculated by excluding
sunk costs and by using the most appropriate cost allocation
methodology. Under these constraints, the figures represent the
maximum cost-effectiveness values (i.e., the highest cost per ton
of pollutant reduced), for the scenarios and strategies considered
in the analysis.
Maximum Value
Cost Effectiveness ($/t)
Scenario/Strategy I/ (Sunk Costs Excluded)
HC CO NOX
1982 NME only 160 120 N/A
1982 NME and 1986 IUE only 200 160 N/A
1982 NME in conjunction with 1986 260 150 N/A
NME
1982 NME and 1986 IUE in conjunction 420 150 N/A
with 1986 NME
1986 NME only 1,781 150 3,400
1986 NME in conjunction with 1982 N/A N/A 9,700
standards
1986 IUE strategy only 925 150 N/A
(analyzed as an
increment to 1982 NME)
I/ See Table 1 for a complete explaination of the scenarios,
¥/A - Not Applicable.
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IV
The analysis identified some consistent patterns of economic
and energy impacts. The average engine produced in compliance with
the 1982 NME Standard, or the 1982 NME Standard and the 1986 IUE
Standard when evaluated as a single control strategy, will exper-
ience penalties, in fuel consumption during taxi-idle ($+230 to
$+1300/yr), and in hot section maintenance ($+530 to $+630/yr).
The increased fuel consumption results from the use of sector-
burning control technology in many engines. When the 1986 IUE
Standard was considered as a separate control strategy from the
1982 NME Standard, the retrofit would result in a small decrease in
taxi-idle fuel consumption ($-500/yr), but this cost was offset by
a small maintenance increase ($+460/yr).
For engines complying with the 1986 NME Standard, which
reduces NOx in addition to HC and CO, both a benefit and penalty in
fuel consumption were calculated. The benefit occurs during
taxi-idle because of increased combustion efficiency ($-1100 to
$-2200/yr). The penalty occurs during cruise flight and is the
consequence of an increase in aerodynamic drag resulting from the
additional weight of the low-emissions combustor ($+1130/yr). The
overall change in fuel consumption ranges from about zero to a
small decrease in fuel use ($0 to $-1100/yr). A very significant
maintenance penalty may occur for the average engine produced under
the 1986 NME Standard ($+42,500/yr). Because of the magnitude of
this penalty and the speculative nature of the assumptions upon
which it is based, EPA will continue to evaluate the potential
maintenance -increments of low-NOx staged combustors during the
final rulemaking on aircraft engine emission standards.
As described in the preceding paragraph, the proposed stan-
dards could result in fuel consumption increments ranging from an
increase of up to about $1300/yr, to a decrease of about $1100/yr
for the fleet-weighted average engine. The increase of $1300/yr is
associated with the average engine produced in compliance with the
1982 NME Standard when the 1986 NME Standard is also promulgated
(this fuel penalty lasts for the 4-year life of the 1982 standard).
The decrease of $1100/yr is associated with the average engine
produced in compliance with the 1986 NME Standard. The figures are
equal to or less than about 0.2 percent of the total fuel consumed
by the average aircraft engine in one year. Expressed differently,
the change in annual fuel consumption for all of the aircraft
engines in the U.S. fleet would equal the annual heating require-
ments of about 20,000-25,000 homes in Detroit, Michigan.
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY i
TABLE OF CONTENTS v
LIST OF TABLES vii
LIST OF FIGURES ix
INTRODUCTION 1
METHODOLOGY 3
Cost Derivation 3
Non-recurring Production 3
Recurring Production 3
Operating 4
Annual Costs and Emissions 4
First-Cost Increase 4
Operating Costs 5
Emission Reductions 5
Fleet Projection 5
Cost Effectiveness 6
Cost Apportionment 6
Cost-Effectiveness Calculations 7
DISCUSSION: Part I 10
Control Methods 10
Fuel Sectoring 10
Minor Combustor Redesign 10
Air Blast 11
Fuel Staging 11
Control Method by Manufacturer 12
Pratt and Whitney 12
General Electric 12
Rolls Royce 12
Control Scenarios 13
Average Engine 15
Fleet Projection 15
Weighting Factors 16
Population Factors 16
Useful Life Factors 17
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VI
TABLE OF CONTENTS (Cont'd)
Engine Costs 17
Engine Selling Price Increment 17
Specific Engine Costs . 17
Annualized Average Engine Selling Price Increment 21
Operating Costs 22
Fuel Consumption Increments: Idle 22
Fuel Consumption Increments: Cruise 23
Maintenance Increments 24
Emission Reductions 26
Baseline Cost-Effectiveness Values ..... 27
DISCUSSION; Part II 29
Sensitivity Analysis ....... 29
Sunk Costs Excluded 30
Retrofit Cost Effectiveness 30
DISCUSSION; Part III 32
Aircraft Cost Effectiveness
Compared to Other Strategies 32
REFERENCES CITED . 35
APPENDICES A-l
Appendix A - EPA Cost Questionnaire A-l
Appendix B - Cost Information Submitted in
Response to EPA Questionnaire B-l
Appendix C - Summaries of EPA Combustion
Assembly Price Estimates - Double
Annular and Vorbix Designs C-l
Appendix D - Derivation of Non-Recurring
and Recurring Engine Cost D-l
Appendix E - Derivation of the Average
Engine Selling Price Increments E-l
Appendix F - Derivation of Idle Fuel
Consumption Increments . F-l
Appendix G - Derivation of Maintenance
Increments G-l
Appendix H - Derivation of Emission Reductions 11-1
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Vll
LIST OF TABLES
Page
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Table 10
Table 11
Table 12
Table 13
Table 14
Table 15
Table 16
Table 17
Table 18
Table 19
Table 20
Description of the Aircraft Emission Control 38
Senarios
Estimated Engines Affected by Each Proposed 39
Standard
Population Weighting Factors by Scenario 40
Useful Life Weighting Factors 41
Cost Components and Their Elements . 42
Engine Costs Associated with the 1982 Standards ... 43
Engine Costs Associated with the 1986 Low NOx .... 44
Standard
Parent Engines and Their Derivatives . . 45
Engine Costs Associated with the CF6 Alternative ... 46
Combustor
Annual Engine Expenses 47
... 48
Approximate Percentage of Idle Fuel Increment
by Engine Model
Annual Idle Fuel Consumption Increment for the .
Average Engine
Cruise Flight Fuel Penalty by Aircraft Type . .
Annual Cruise Fuel Consumption Increment for the
Averge Engine Brought about by NOx Control
49
50
51
52
Annual Maintenance Costs for the Average Engine . .
Average Airport-Specific Taxi-Idle Times 53
Annual Pollution Reductions for the Average 54
Engine
Cost-Effectiveness Computations 55
Effect of Variations in Fleet Projections 56
Effect of Excluding Sunk Costs 57
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Vlll
LIST OF TABLES (Cont'd)
Page
Table 21 Incremental Cost Effectiveness of the 1986 58
Standards
Table 22 Selected Cost-Effectiveness Values for Air- 59
craft Control Strategies
Table 23 Cost Effectiveness of Non-Aircraft Control 60
Strategies
Table 24 Summary Results of Aircraft Emission Control 61
Cost-Effectiveness Evaluation
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IX
LIST OF FIGURES
Page
Figure 1 Time Expenditure of Non-Recurring Funds for 62
the 1982 NME and 1986 IUE Standards
Figure 2 Time Expenditure of Non-Recurring Funds for 63
the 1986 NME Standard
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1
INTRODUCTION
To determine the most efficient means of achieving the Nation-
al Ambient Air Quality Standards (42 CFR §420), the cost effective-
ness of various pollution abatement strategies is compared and the
most effective are implemented. This report contains the final
cost-effectiveness analysis of alternative aircraft emission
control strategies. It was prepared in support of the current
rulemaking action on aircraft engine gaseous exhaust emission
standards (43 FR 12615).
Several alternative scenarios which incorporate three basic
control strategies are evaluated. The three strategies are:
1. Control newly-manufactured commercial gas turbojet or
turbofan engines in 1982 for HC and CO (1982 NME);
2. Retrofit in-use commercial gas turbojet or turbofan
engines by 1986 for HC and CO (1986 IUE); and
3. Control newly-manufactured commercial gas turbojet or
turbofan engines in 1986 for HC, CO, and NOx (1986 NME).
This final report is the result of an extensive effort to
assemble and document uniform cost data from the aircraft engine
manufacturers and the domestic air carriers. The effort yielded
more specific and complete cost information than was available at
the time the two previous cost-effectiveness analyses were prepared
(Wilcox and Munt, 1977 and 1978). In addition to the information
gathered by EPA's active solicitation of data from the industry,
all comments received regarding the March 24, 1978 Notice of
Proposed Rulemaking (NPRM) were considered in the preparation of
this report.
Every major cost element has been accounted for in the analy-
sis. The cost figures in this report are based on data gathered
from a variety of sources: engine manufacturers, original equipment
vendors, major airlines, and previously documented information.
EPA critically reviewed all of this data. Special attention was
given to the information supplied by the engine manufacturers,
since they have historically overestimated the economic impact of
aircraft pollution control requirements. The Agency supplemented
and attempted to verify the industry figures with data from other
sources whenever possible. In some cases, industry data was
tempered by EPA's best judgment when large inconsistencies between
industry submittals were evident. If the necessary cost data were
completely lacking or if the economic claims were clearly unjusti-
fiable, substitutions were made based on previously documented
information.
The added effort which was required to quantify some of the
minor cost elements could not be justified since it is doubtful
that their inclusion would significantly affect the concluding
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cost-effectiveness values. Also, because of the conservative
nature of the industry submitted cost estimates, i.e., many appear
to be excessive, it is assumed that the smaller undocumented costs
are accounted for in the industry figures which were used in the
analysis; therefore, their specific inclusion would be repetitive.
The complexity of the subject matter necessitates the use of
simplifying assumptions and projections in an attempt to ascertain
future facts. No matter how carefully considered, these forecasts
will be subject to error and individual interpretation. Within
these constraints, the cost-effectiveness ratios derived in this
analysis represent EPA's best estimate of the costs and benefits
which will accrue by implementing any of the alternative control
scenarios. Furthermore, these values should be interpreted as
being representative and not absolute cost-effectiveness indica-
tors .
The Discussion section of this analysis is divided into three
parts. Part I documents the various cost parameters and fully
explains the derivation of the overall cost-effectiveness values
for the various aircraft engine control scenarios. Part II
applies a variety of assumptions to the basic data elements from
Part I to more completely document alternative cost-effectiveness
values. Part III compares the cost effectiveness of aircraft
engine emission controls to values for other control strate-
gies which either have been implemented or are being considered.
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METHODOLOGY
The procedure used in this analysis consisted of determining
the annual costs and exhaust emission reductions for the fleet-
weighted average, engine under each control scenario. A portion of
the total annual cost was then applied to each individual pollut-
ant. The resulting HC, CO, and NOx cost-effectiveness factors are
defined in terms of dollars spent per ton of pollutant reduced
($/ton). The costs of pollution control are expressed in 1978
dollars throughout this analysis.
A brief description of each part of the methodology is pre-
sented in the following sections.
Cost Derivation
The incremental cost of each control scenario was separated
into three major components: non-recurring production, recurring
production, and operating. The amounts of each cost component were
derived with data acquired from aircraft engine manufacturers,
major airlines, original equipment vendors, independent manufactur-
ers of engine combustion chambers, and information from previous
EPA contract efforts. The most recent unpublished cost information
is presented in Appendices B and C.
Non-Recurring Production
This major component is composed of several elements: devel-
opment, certification, service evaluation, initial production, and
engine dedication. These funds represent the corporate investment
associated with the application of demonstrated technology to
specific engine families and must be recovered in the engine
selling price. Not included are the research and development (R&D)
costs of initial design and engine demonstration which were funded
through U.S. Government contract and Independent Research and
Development (IR&D) money.
Recurring Production
The cost of manufacturing refers only to the increment in
engine selling price as a consequence of the increased complexity
or more expensive materials found in a low-emission engine. This
burden is generally attributed to the combustor and fuel supply
system, but may include increased costs to manufacture the pressure
casing and equipment bay.
The non-recurring and recurring costs associated with each of
the proposed standards are presented in greater detail in Appendix
D.
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Operat ing
Operating cost is defined as the increment in fuel consumption
and maintenance between regulated and non-regulated engines.
Differences in fuel use will occur at ground idle for each control
strategy, and during cruise flight conditions for the 1986 low-NOx
standard. The use of low-emission technology is also expected to
increase engine hot section maintenance costs. No performance
penalties (such as a loss of thrust) are associated with the
standards. The incremental costs for idle fuel consumption and
maintenance are derived in Appendices F and G, respectively.
The above major components were used to determine the total
annual cost of aircraft engine pollution control. This cost is
made up of (1) the annualized engine selling price increase (first
cost), and (2) the increment in annual operating expenses.
Annual Costs and Emission Reductions
First Cost Increase
The non-recurring and recurring production expenses are
incurred in different years. Because of the time value of money,
these costs are not comparable to one another. To account for this
aspect of future capital expenditures, their present value was
calculated by using a discount factor of 10% per annum. All values
were discounted to the effective date of the standard being
analyzed in each scenario, i.e., 1982 or 1986.
The present value of the first cost increase was derived by
assuming that the annual production costs are incurred on January 1
of the year in which the expenditure is made, and that the revenue
from that year's engine sales are received on January 1 of the
following year. Furthermore, it was assumed that the discounted
costs (which includes profit) are equivalent to the -discounted
revenues as shown in the following equation:
(Discount Factor)(Revenues) = (Discount Factor)(Costs) (1)
If the revenue received from the average engine price increase (AP)
is equal to the number of engines sold multiplied by AP as shown
below:
Revenue = (AP)(£ngine Sales) (2)
Then by substituting Equation 2 into Equation 1 and rearranging,
the first cost increase is found by the following equation:
(Discount Factor)(Cost)
(Discount Factor)(Engine Sales) (3)
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The increase in engine selling price was then annualized based
on the useful life of the fleet-weighted average engine.
The average first cost increase is derived in Appendix
E.
Operating Costs
The incremental costs of fuel and maintenance for each engine
type were calculated as constant recurring annual expenditures;
therefore, no discounting was necessary,
Emission Reductions
The pollution abatement brought about by the use of a low-
emission version of an engine was computed by finding the net
reduction per landing-takeoff (LTO) cycle and multiplying that
figure by an estimate of the annual LTO cycles the engine will
experience.
The following formulae were used to determine the number of
LTO cycles for specific engines based on their representative
aircraft type. The data inputs came from CAB statistics published
in CAB (1978) and AWST (1978 and 1979).
, _ (x Stage Length) (Total Annual Revenue Airborne Hours)
^ TlT Airborne Speed) (x" Number of Aircraft in Service) (4)
or
. _ Total Annual Revenue Hours
(3f Airborne Speed) (3f Number of Aircraft in Service) (5)
or
TTO I = (Total Annual Revenue Hours)(Annual Revenue Departures)
s/yr (Daily Aircraft Utilization)(365 Days/Year) (6)
A complete discussion and table of the emission performances for
the engines affected by the proposed.regulations are presented in
Appendix H.
Fleet Projection
In order to define the average engine costs and emission
reductions for each control scenario, the appropriate figures for
each engine model were weighted by their population in the overall
aircraft fleet. There are three basic fleets of interest: (1)
the fleet of pre-1982 aircraft which is subject to the 1986 IUE
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Standard; (2) the 1982 through 1985 aircraft fleet which is subject
to the 1982 NME Standard; and the 1986 and beyond fleet of new
aircraft which is subject to the 1986 NME Standard. The -project ion
used to obtain each fleet mix was based on an EPA technical report
by Hunt (1978), which relied primarily on an earlier FAA fleet
projection (FAA, 1977). The number of foreign aircraft that would
be affected by the proposed standards are included in this anal-
ysis, and were estimated from information contained in Day and
Bertrand (1978).
Cost Effectiveness
Two methodologies were used to determine the cost-effective-
ness values in this analysis: method A and method B. Both methods
assign compliance costs to the same pollutants, but differ in the
way the cost is distributed among the pollutants. Each method is
described iii the following sections.
Cost Apportionment
Method A
This costing methodology is consistent with that used for
automobile emission control strategies (DOT, 1976). For the 1982
NME and 1986 IUE Standards which control only HC and CO, no quan-
titative approach to cost application exists which is based on
technological costs, since the same technology controls both
species. For this reason, the cost of control is divided equally
between the two pollutants.
The 1986 NME Standard which regulates NOx, also regulates HC
and CO to the same levels that are allowed by the 1982 NME Stand-
ard. Therefore, . in the control scenarios where both standards are
implemented, the incremental burden of NOx control is qualified by
determining the costs accrued beyond those encountered by control-
ling HC and CO in 1986 with 1982 control technology. This incre-
mental cost burden is attributed to NOx emission controls.
In scenarios which evaluate the 1986 NME Standard as the only
standard in effect, i.e., no preceding 1982 standard, the cost of
control is divided equally between the three pollutants.
Method B
As previously mentioned, methods A and B differ only with
respect to the way costs are distributed among the various pollu-
tants being controlled. Method B allocates the compliance costs by
specifying a maximum allowable cost-effectiveness value for one or
more of the pollutants. The portion of the total cost which
is accounted for by these specified pollutants is then calculated
by multiplying the emission reduction for each pollutant by its
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respective cost-effectiveness value. The remaining unaccounted
for portion of the total cost is then burdened to the pollutants
for which no cost-effectiveness values were specified.
Cost-Effectiveness Calculations
The cost effectiveness for each control scenario was calcu-
lated by determining the total annual cost for the fleet-weighted
average engine, and then using method A or B to complete the
calculation. The total annual cost is found by the following
equat ion:
Total Annual Cost = (7)
Annualized First Annual Fuel Annual Maintenance
Cost Increase Consumption Increment Increment
Method A
By using this method to evaluate the 1982 NME and 1986 IUE
Standards, 50 percent of the total annual cost is allocated to the
annual reduction in each pollutant (HC and CO) for the average
engine. This yields the final cost-effectiveness ratio:
Cost Effectiveness for Pollutant A = (8)
50 % of Equation 5
Annual Reduction in Pollutant A
When the 1986 NME standard is considered as the only require-
ment, 33 percent of the total annual cost is applied to the annual
reduction in each of the three pollutants being controlled (HC, CO,
and NOx).
Cost Effectiveness for Pollutant A = (9)
33% of Equation 5
Annual Reduction in Pollutant A
When the 1986 NME Standard is required in conjunction with the
earlier 1982 NME Standard, the cost-effectiveness ratio for HC and
CO is the same as that found by Equation 6 for the preceding
standards. The total annual cost of NOx control is defined by
Equation 5 where:
1) The first cost increase (A?) includes the non-recurring
manufacturing expenses incurred as a result of developing and
implementing 1986 control technology, no 1982 technology non-recur-
ring costs are included;
2) The first cost increase also includes the difference
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between the 1986 NME and 1982 NME recurring average engine manu-
facturing costs; and
3) The fuel consumption and maintenance costs are the
differences between the increments calculated for the in-service
engines when utilizing either 1986 NME or 1982 NME control hard-
ware .
The cost effectiveness of NOx control is found by the fol-
lowing equation:
Cost Effectiveness for NOx = (10)
Equation 5
Annual Reduction in NOx
The cost effectiveness of the retrofit control strategy (1986
IUE Standard) was calculated as an increment, since the 1986
retrofit would not be implemented unless the 1982 NME Standard was
also promulgated. Therefore, the total annual incremental cost of
the 1986 IUE Standard is defined by Equation 5, where the annual-
ized first cost increase is based only on the recurring costs of j
production. The non-recurring costs for this technology are
assumed to have been paid by the preceding 1982 NME Standard.
The 1986 IUE Standard's cost effectiveness is found by the
following equation:
Incremental Retrofit Cost Effectiveness for Pollutant A = (11)
50% of Eq. 5 (recurring costs only)
Annual Reduction in Pollutant A
Method B
This method is used only when method A proves to be unsatis-
factory. If, by using method A, the cost-effectiveness values for
one or two pollutants is unacceptably high, method B is employed
to determine if reweighting the costs would lead to acceptable
values for all pollutants. Therefore, method B distributes the
costs of compliance unequally between the pollutants. The costs,
however, are defined in the same way by both methodologies.
The method can be used with any number of pollutant species,
but will be illustrated for standards which control two pollutants
simultaneously, e.g., the 1982 NME or 1986 IUE Standards. By
specifying a maximum acceptable cost-effectiveness value for
Pollutant A, the cost effectiveness of controlling Pollutant B is
determined by the following equations:
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Cost Allocated to Pollutant A = (12)
($/ton for Pollutant A) (Annual Reduction in Pollutant A)
Cost Allocated to Pollutant B = (13)
Total Annual Cost - Equation 10
Cost Effectiveness for Pollutant B = (14)
Equation 11
Annual Reduction in Pollutant B
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10
DISCUSSION
Part I
In order to comply with the aircraft emission standards,
manufacturers will have to make changes to the turbine engine's hot
section (e.g., combustor). For a more complete understanding of
the major issues involved in the cost-effectiveness analysis, brief
descriptions of these changes are presented in this part of the
discussion. If desired, the reader may refer to Hunt (1979) for a
more rigorous description of the requisite control technology.
The discussion of control techniques is followed by a descrip-
tion of several control scenarios which are used to evaluate the
cost effectiveness of promulgating alternative emission standards.
The major elements of the cost-effectiveness analysis are then
derived (i.e., fleet projection, engine costs, operating costs, and
emission reductions), and the final cost-effectiveness values for
the fleet-weighted average engine in each control scenario are
calculated.
Control Methods
Four basic types of technology will be used singly or in
combination to produce a low-emission combustion system. Fuel
sectoring, minor combustor redesign, and air blast concepts will be
used to control HC and CO as required by the 1982 Newly-Manufac-
tured Engine (1982 NME) Standard and the 1986 In-Use Engine (1986
IUE) Standard. To comply with the 1986 Newly-Manufactured Engine
Standard (1986 NME) which controls NOx in addition to HC and CO,
fuel staging will be required.
Fuel Sectoring
This method is used to improve the combustion conditions at
idle which results in lower HC and CO emissions. Specifically,
during the idle mode combustion is quite lean with an attendant low
flame temperature; consequently, the combustion efficiency is poor
because of inadequate heat to vaporize the fuel and to stimulate
the CO to C02 reaction. This problem is resolved by eliminat-
ing the fuel flow entirely to a part of the combustor (usually
about half), and injecting it with the rest of the fuel into the
remaining portion of the combustor. . Th.is has two beneficial
effects: (1) the atomization of the fuel is improved and (2) the
fuel/air ratio is increased (enriched) so that a hotter flame
exists, improving vaporization of the fuel and enhancing the CO to
C02 reaction.
Minor Combustor Redesign
This method may consist of enrichening the primary combustion
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11
zone or delaying the introduction of dilution air into the com-
bustor. With the rich primary concept-, reducing primary airflow
increases the local fuel/air ratio and, hence, the primary zone
temperature. At low power, this is beneficial since the higher
temperature enhances the CO to C02 conversion when 0.2 becomes
available in the secondary combustion zone, and aids in fuel
droplet evaporation, thereby improving the consumption of HC. If
the primary zone equivalence ratio is greater than one, smoke
becomes a problem. Mediating excessive smoke emissions may
require complicated air flow patterns and dilution zones in the
secondary.
The delayed dilution concept consists of postponing the
introduction of dilution air, thereby producing a longer combus-
tion zone at intermediate temperatures. This allows the CO to C02
conversion to approach equilibrium and unburnt hydrocarbons are
consumed by increasing the residence time of the reactants. The
difficulty lies in adjusting the air flow in the intermediate
zone at all power settings so it is hot enough for CO consumption,
yet cold enough to prevent NOx, and still achieve flame stability,
liner durability, etc.
Air Blast
The pressure differential that exists between the compressor
and the combustor is employed to produce high velocity air through
a venturi system at the combustor inlet. This air is directed
toward the fuel spray to help break up the fuel droplets, result-
ing in the elimination of locally rich hot spots and an improvement
in combustion efficiency.
The basic concept is relatively simple since it only requires
the addition of venturi tubes. However, to achieve the standards
in most cases, it usually proves necessary to also optimize the
airflow distribution of the liner.
Fuel Staging
The combustor is divided into two regions, each having its own
fuel injection system. These are termed the pilot stage and the
main stage. At low power, fuel is supplied only to the pilot
stage, thereby allowing a much higher local fuel/air, ratio than
would be possible if the fuel were distributed throughout the
combustor. This mixture is then able to burn hotter, enhancing the
CO to C02 conversion and droplet evaporation (reducing HC).
At high power, the fuel is distributed between the two stages
in such a way so as to minimize the peak temperature. This aids .in
preventing NOx production. Staging requires two fuel injection
locations which adds to the complexity of the fuel supply system
and the fuel control. The combustor liner is also more complex and
may have additional cooling and temperature profile problems.
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12
Control Method by Manufacturer
Pratt and Whitney Aircraft (PWA)
The air blast control concept will be used in each engine
model to control HC and CO to the levels required by the 1982 NME
and 1986 IUE Standards. This will require modifications to the
fuel nozzles, nozzle supports, combustion liners, combustion dome,
and in some cases the transition and diffuser case must be re-
worked .
To meet the 1986 NME Standard, PWA will use a vortex-mixing
fuel-staged combustor called the Vorbix. This combustor is con-
sidered the most complex configuration which is required to reduce
NOx emissions. Along with the staged combustion systems of the
other manufacturers, the Vorbix incorporates changes to the liner,
dome, fuel nozzle, nozzle supports, fuel manifold, swirlers, and
fuel logic control system.
General Electric (GE)
The control methods used by this manufacturer to meet the 1982
NME and 1986 IUE Standards are sector burning and air blast. At
the present, the following engine models are scheduled to be
introduced with sectoring hardware: CF6-6, CF6-32, CF6-50, CF6-45,
and CFM-56. The hardware modifications include: fuel nozzle
orifice diameter changes, nozzle support check valves in the
primary fuel delivery of the unfueled sector, fuel manifold, and
logic control. No changes are required to the dome or combustion
liner. The newest GE derivative engine, the CF6-80, is expected to
use the air blast control method in lieu of sector burning. Air
blast affects the design of the fuel nozzles and supports, dome,
and lines. Because the air blast concept enjoys greater customer
acceptance than does the sector burning concept, GE has recently
indicated it may change to air blast in their other CF6 engine
models if possible. tf GE actually decides to make this switch,
the air blast hardware would not be available to the airlines until
sometime after the compliance date of the 1982 NME Standard.
Therefore, it is expected that GE will certify and produce some
engine models with sectoring controls regardless of whether or not
air blast will eventually predominate in the fleet.
To control NOx emissions in 1986, GE engines will use the fuel
staging control method. Their combustor configuration, however,
differs from PWA's and is called the Double Annular. This combus-
tor incorporates the same design changes from conventional hardware
as was described for the Vorbix.
Rolls Royce (RR)
This manufacturer will use the same control technology as GE
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13
to meet the 1982 NME, 1986 IDE, and 1986 NME Standards. Rolls
Royce, however, does not appear to have the option of using the
airblast concept. Controlling HC and CO to the required levels
with air blast modifications appears to be impossible because of
certain engine design constraints. Therefore, all RR engines will
be produced with sector burning hardware in order to comply with
the 1982 NME and 1986 IUE Standards.
Control Scenarios
Several control scenarios are evaluated to determine the cost
effectiveness of promulgating alternative emission standards.
These control scenarios are presented in Table 1, along with, a
brief explanation of each. As shown in this table, Scenarios. 7
and 8 evaluate the potential effect of General Electric's change
from sector burning to combustor modifications in order to meet the
1982 NME and 1986 IUE Standards. The analysis of these CF6
alternative scenarios necessitated the use of several important
assumptions.
As previously stated, the CF6-80 will be produced with combus-
tor modifications and could precipitate a change to similar control
Hardware in the other CF6 models. If the conversion does take
place, it would be accomplished sometime after the scheduled
introduction of the CF6-80 in 1982.
A significant amount of time and money will be required to
incorporate the CF6-80 control hardware into other engine models,
and to allow for an adequate service evaluation. The EPA does not
expect any production change from sector burning to combustor
modifications until the 1985 to 1986 time frame if any HC and CO
standards are promulgated.
The assumptions that were used to complete the CF6 alterna-
tive scenarios are presented below. These assumptions were neces-
sary to limit the analysis to manageable proportions.
1. Combustor modifications are incorporated into CF6-6,
CF6-32, CF6-50, and CF6-45 production engines beginning on January
1, 1986. By choosing this date, the CF6 alternative will not exist
prior to 1986; therefore, the alternative affects only the 1982 NME
Standard when it is effective beyond that date, i.e., when it is
promulgated without the 1986 NME Standard.
2. The increments in maintenance and emission reductions are
considered to be equivalent for sector burning and combust,ion
modifications. The assumption concerning incremental maintenance
is based on information contained in the section entitled, "Oper-
ating Costs." This information shows that the added costs of
maintaining modified PWA combustors, which are very similar to GE's
alternative combustor design, are nearly identical to the incremen-
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14
tal maintenance costs for GE's sector burning hardware. Since the
PWA and GE modified combustors are very similar, it is assumed that
the costs would also be about the same. The emission reductions
are assumed to be equivalent because both technologies must meet
the same standards.
3. For newly-manufactured engines, the differences in the
average engine selling price for sector burning and modified
combustor engines is ignored. The number of sector burning engines
produced prior to 1986 is small in relation to the number of
engines produced with combustor modifications after that date. For
this reason, the increments are of minor consequence to the overall
results of the study. A difference in price of only about 8
percent would occur if the engines produced with sector burning
were accounted for. This is well within the experimental uncer-
tainty of the analysis.
4. No significant penalty is associated with concurrently
maintaining retrofitted engines which utilize sector, burning
hardware and newly-manufactured engines incorporating combustor
modifications within the fleet. EPA is aware that the possibility
of logistics problems exists in operating and maintaining two
different types of control hardware for the same engine model, but
that the problems are manageable and are not economically signifi-
cant in a study of this kind. Furthermore, the magnitude of any
potential problems is not expected to be great enough to force the
airlines to voluntary retrofit combustor modification hardware into
engines already equipped with sector burning hardware.
5. For retrofitted and newly-manufactured engines the
differences in fuel consumption during ground idle operations
for engines equipped with either sector burning or combustor
modifications are ignored. All engines are assumed to have 'idle
fuel usage increments equivalent to the vast majority of engines in
the fleets of interest. Since the GE alternative is relevant only
when .the 1982 NME Standard is promulgated without the 1986 NME
Standard, the vast majority of engines will be equipped with
combustor modification hardware. This assumption simplifies the
analysis and maintains compatibility with the way in which annual
fuel increments are calculated in the other scenarios. On the
basis of total engine years for each fleet, newly manufactured
engines with sector burning control make up only 6 percent or less
of the total, and retrofitted engines with these controls make up
only 1 percent of the total. These small percentage differences
will not have a significant effect on the results of this study.
One of the major constraints of incorporating modified combus-
tors into CF6 engines is in attaining the CO standard. Therefore,
if EPA promulgated a standard that controlled only HC emissions, GE
might be able to produce engines which utilize this technology
prior to 1986. The effect of producing a smaller number of sector-
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15
burning engines would be two fold. First, it would reduce the fuel
penalty which is associated with those engines. Second, the
average engine selling price would be reduced slightly, since
sector-burning is more expensive to manufacture than combustor
modifications. However, these small potential benefits may be
offset by a larger cost penalty if a smaller fleet of engines with
sector-burning controls was regarded by the airlines as a strong
incentive to voluntarily retrofit modified combustors to maintain
commonality within the fleet. These possibilities are purely
speculative of this time, and are not considered to be within the
scope of this analysis.
Average Engine
The cost effectiveness of each control scenario is based on a
representative fleet-weighted average engine. This hypothetical
engine is defined by weighting the costs and emission reductions
for each affected engine model by 1) its fractional population
within the aircraft fleet of interest, and 2) its useful life.
Therefore the average engine is directly determined by t.he aircraft
engine fleet projections which vary according to the standards
being reviewed.
Fleet Projection
The fleet projections used in this analysis are based on an
EPA technical report entitled, "U.S. Aircraft Fleet Projection and
Engine Inventory to the Year 2000" (Hunt, 1978). The fleet figures
from the above report have been updated to reflect the most recent
information concerning future aircraft demand, and to include an
estimate of the foreign aircraft which would be affected by the
proposed standards. The foreign aircraft fleet was estimated from
information contained in Day and Bertrand (1978).
To derive the average engine' statistics for each control
scenario, three different aircraft fleet projections are used.
These fleets, singly or in combination, correspond directly to the
standard being analyzed. For the 1982 NME and 1986 NME Standards,
the estimates of new aircraft production include airplanes built
for both the domestic and foreign markets. New foreign air carrier
aircraft are included because engine manufacturers are not expected
to produce engines in both controlled and uncontrolled configura-
tions. The additional cost of maintaining two production facili-
ties simply could not be justified. For the 1986 IDE Standard, the
estimate of retrofitted aircraft reflects the inventory of the
domestic airlines in addition to foreign air carrier airplanes that
may operate within the U.S.
Each aircraft fleet forms the basis for determining the number
of in-service and spare part engines that will be produced or
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16
retrofitted. The number of spare engines is assumed to be 20% of
the in-service engine population. The engine projections are
presented in Table 2.
The fleet projections are based on an assumed aircraft attri-
tion rate. In EPA's fleet projections, the selection of this rate
is the main determinant of the number of new aircraft entering the
fleet and, hence, the number of new aircraft engines being produced
each year. In previous cost-effectiveness analyses (Wilcox and
Hunt, 1978) , EPA used an attrition rate of 15 years. This rate
was an approximation of the corporate accounting lifetime. None of
the comments which were received in response to the March 24, 1978
Notice of Proposed Rulemaking were directly critical of this
selection. Actually, some reinforcement for this useful life was
received when Pratt and Whitney Aircraft Group used the same figure
in some of its comments (United Technologies, 1978). Also, a very
similar figure (16 years) was used by Douglas Aircraft Company
(1976) in an economic analysis of energy consumpton by commercial
air transport. Therefore, because no comments were received that
suggested the figure was incorrect,a useful life of 15 year is used
again in this study. Previous EPA fleet projections were criti-
cized in general, however, by the Air Transport Association (1978).
In response to this criticism, this report incorporates a sensi-
tivity analysis of each control scenario based on ^10 percent of
the projected engine inventory. In this way, a "best" and "worst"
case is estimated. The sensitivity analysis is applied to EPA's
"best estimate" in the discussion section entitled, "Cost-Effec-
tiveness Calculations."
Weighting Factors
The weighting factors for each engine model are divided into
two principle types: population and useful life. The population
factors are based the ratio of each model's population to the total
engine population within the fleet. The useful life factors are
necessary to account for the varying life expectancies in scenarios
which evaluate the 1986 IUE Standard. If an engine has an expected
life which is less than the maximum, it receives proportionately
less weight in .the derivation of the average engine parameters with
regard to annual increments in maintenance, fuel consumption, and
gaseous emissions.
Population Factors
Three fleet projections are used either singly or in combina-
tion to derive the four groups of population weighting factors
which are required to define the particular average engine for the
scenario being reviewed. These groups of weighting factors, and
the corresponding control scenarios in which they are used, are
shown in Table 3.
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17
Useful Life Factors
Only one group of useful life weighting factors is used in
the scenarios which evaluate the 1986 retrofit standard. These
factors are based on the overall aircraft attrition rate which is
used in the fleet projections.
Newly-manufactured engines are considered to have a useful
life of 15 years. The fleet projection forecasts that all retro-
fitted engines except the CF6-50, CFM56, and JT8D-209 will have an
average useful life of 7 years remaining. The CF6-50 was intro-
duced on later airplane models and would have expended less of its
useful life; therefore, this engine has 10 of its original 15 year
lifetime remaining. The CFM56 and JT8D-209 would be retrofitted
on older aircraft (e.g., B707), but because of the high cost of
reengining these airplanes they are expected to remain in service
beyond the end of their normal service lives. Therefore, these
engines are considered to have a useful life of 15 years, and are
treated as newly-manufactured engines. The useful life weighting
factors are presented in Table 4.
Engine Costs
EPA undertook an extensive program to define the costs of
controlling gaseous exhaust emissions from gas turbine aircraft
engines. The program resulted in quantifying all of the major cost
increments which are associated with the proposed standards:
engine selling price; idle fuel consumption; cruise fuel con-
sumption; and maintenance. The costs for each of these major
categories are based on data gathered from the engine manufac-
turers, major airlines, EPA independent investigations, and other
published and unpublished information. Each major category is
discussed in detail below.
Engine Selling Price Increment
Specific Engine Costs - - The categories of cost for each
engine model are typically made up of several elements which when
combined, account for all of the expenses incurred by ^he turbine
engine manufacturers. Where appropriate, these elements also
include corporate profit and the costs of incorporating control
hardware into in-use aircraft engines. The main elements within
each component are shown in Table 5.
Recent studies which have attempted to define the engine-
specific costs of aircraft emission controls have referred to the
difficulties of acquiring complete .and verifiable information.
This study attempted to mediate these difficulties by developing a
standardized format for gathering relevant cost information (Ap-
pendix A). A request for information was then sent to the three
engine manufacturers, a fuel nozzle vendor, and several major
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18
airlines. The standardized format was necessary to reduce the
variability of all the responses into a manageable form. The
requests for information were detailed enough to allow an objective
evaluation of the economic claims made by the industry, and at the
same time, attempted to avoid sensitive or proprietary subject
matter. Independent EPA sponsored investigations were also used to
document the costs of producing low-NOx staged combustion liners
(Appendix C).
The complexity of controlling emissions from lar^e turbine
engines places the affected industry in a superior position to
accurately assess the associated costs. Therefore, this study
began with industry supplied data whenever possible. However, after
carefully reviewing manufacturers' cost information it was often
necessary to make substitutions or to adjust manufacturers' cost
estimates. Sometimes it was preferable to use costs from EPA's
independent estimates. These deviations were required for a
variety of reasons:
1) Manufacturers did not always report cost data in EPA's
recommended format. In some cases, the manufacturers claimed the
data was proprietary, while in others, no reason was given.
2) Manufacturers' submittals were sometimes incomplete or
vague. For some categories, no cost data was reported.
3) Some cost estimates were grossly inconsistent when
figures reported in .the same format were compared. Some figures
that were not directly comparable, but which should have varied in
a normally expected way, were also grossly inconsistent.
4) Manufacturers claimed the information was not needed for
various reasons. They also claimed the costs of specific items
could not be estimated even though their previous statements may
have attempted to quantify those same costs.
If, after reviewing an engine manufacturer's cost information,
it was not used in the analysis for any of the above reasons, an
attempt was generally made to be consistent with any other related
information supplied by that manufacturer or other manufacturers if
these costs were judged to be reasonable. Therefore, the cost data
which were used to generate the specific engine costs in this
study, are often based on manufacturers' estimates, although they
will not necessarily agree with the estimates submitted by the
manufacturers in every instance. The estimates can be considered
somewhat conservative, i.e., overestimate the actual costs of
control, because of the vested interests of the industry. This is
probably most true of the costs associated with the 1986 NOx
standard.
Tables 6 and 7 contain the specific engine costs for the
various control strategies. Additional information concerning the
actual deviation of these figures is presented in Appendix D.
Footnotes to the tables have been provided, however, to indicate
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19
the basis and source of the cost figures. The reader should
consult the appendix for a more complete description of the esti-
mates .
Some of the engines in Tables 6 and 7 are derivatives of
others. These derivative engines and their so-called "parent"
engines are shown in Table 8. The engines in this table are so
closely related that most of the non-recurring costs cannot be
ascribed to any single engine model. Because they utilize the same
basic engine parts or design, the new new engine increment is the
same. It should be pointed out, that although the RB211-524 is not
generally considered to be derivative of the RB211-22B, they do
utilize the same combustor. Therefore, the RB211-524 is treated as
a derivative of the RB211-22B in this analysis.
As in the case of new engines, derivatives do not require a
service evaluation of emission control hardware. These evalutions
are necessary only to define the durability of design changes in
relation to the prior service characteristics of an existing
engine. For new engines such as CFM56, no prior service record
exists for comparison, so no evaluation is required. Derivative
engines do not require a service evaluation because it is assumed
that the information gathered for the parent engine is also useful
for characterizing the derivative.
Certification is the only non-recurring cost category where
derivatives incur some costs independently of their parent en-
gines. For the HC and CO emission standards which begin in 1982,
the derivative engines may have some unknown incremental certifi-
cation costs due to emission controls. These engines are expected
to be type certified while incorporating emission control hardware,
however, so any cost increment will be insignificant in relation to
the total expense. Additionally, the certification costs for the
parent engines have some associated uncertainties and some the
costs appear to be inflated. For these reasons, no allowance is
made for HC and CO emission control certification testing in these
derivatives (Table 8).
The retrofit prices in Table 6 are based on the costs of
purchasing and installing the requisite control hardware. No
allowance which reflects the cost of prematurely scrapping life-
limited parts has been included. Conversely, no allowance has been
included which reflects the possibility that some low-time, life-
limited parts or non-life limited parts that are displaced by the
retrofit, could be sold to foreign airlines not requiring emission
control hardware (This possibility exists primarily for JT8D
engines). The salvage value of non-life limited parts has also
been excluded. These potential costs and revenues are assumed to
cancel out each other.
The engine-specific costs are different from those shown in
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20
Table 6 for scenarios which evaluate the change from sector burning
to combustor modifications by all CF6 engines except the CF6-80.
The costs to develop, certify, service, evaluate, and initially
produce the CF6 alternative for the derivatives and parent engines
(Table 9) are additional expenses to the non-recurring costs that
have already been incurred to introduce sector burning. The new
engine increment is reduced since combustor modifications are less
expensive to produce and install. The retrofit price is unchanged
because the alternative is not introduced until after the end of
1986 when the retrofit is complete.
The JT10D and Spey engines represent a special case in the
analysis. Recent informat ion indicates that the JT10D presently
has no companion airframe, nor does it appear likely to have one in
the near future. The only potential use for the JT10D appears to
be on the B757 ai.rframe, although it is not expected to capture
this market because airlines preceive an inherent risk in using a
totally new engine, and because suitable derivative engines
exist such as CF6-32 and RB211-535. For these reasons EPA's engine
inventories for the 1982 NME and 1986 NME Standards do not include
the production of any JTlOD's. However, the manufacturer has
claimed an expenditure of development funds for the controlling HC
and CO emissions from this engine. These costs are accounted for
in Table 6 since the engine is ready to be certified, and the money
has already been spent. It is assumed that because no market
exists, the company will not develop the requisite NOx control
hardware to meet the 1986 standard. For this reason, no develop-
ment costs are shown in Table 7. The Spey is an older engine that
cannot possibly meet the standards. It is not included in this
analysis because it is assumed to be out of production by the time
the 1982 standard is implemented. Several possibilities exist
which explain why the Spey will not be produced:
1. If it does not meet the standard, it will not be made;
2. No market exists; and
3. If a market does develop in the future, it is likely the
Spey will be replaced with the RB432. (EPA lacks emission control
information on the RB432.)
The manufacturer of the Spey claimed an expenditure for
development funds for reducing HC and CO emissions, although none
are accounted for in Table 6 for three principle reasons. First,
the engine cannot meet the standard and is not ready to be certi-
fied with low-emission hardware as was the case for the JT10D.
Therefore, only a portion of the claimed development -funds have
actually been expended. Second, EPA does not have data with which
to quantify the expenditures made by Rolls Royce to reduce HC and
CO emissions from the Spey. Third, it is assumed that the manufac-
turer has not continued to expend funds without an identifiable
market for the engine.
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21
Annualized Average Engine Selling Price
The average engine selling price increment is based on the
non-recurring and recurring costs of control as defined in the
above section. Computing the selling price in this manner is
considered to be more accurate than relying on manufacturers'
estimates of this price increment. Manufacturers use various
strategies to determine the selling price of their engines.
Generally, however, the costs incurred by one engine model are not
recovered solely in the sales price of that engine. Instead, the
non-recurring costs from all engine models are pooled. These costs
are then amortized across the product line of the company as the
anticipated market and other variables permit. Therefore, the
selling price increment is somewhat independent of the money spent
on any one individual engine model. This also explains why a
manufacturer's estimate of the increment in selling price for a
particular engine model may vary from time to time.
Basing the average selling price increment on the actual costs
which are incurred by the manufacturers and airlines, is also a
more realistic expression of the true cost to society. The compu-
tation insures that all costs are recovered, i.e., no company loses
money and no company will make excess profits. These types of
profits are not a societal cost but are simply transfer payments.
The costs of emission controls actually occur as a series of
variable annual disbursements by either the engine manufacturers or
the airlines. To make these disbursements comparable, they must be
converted into equivalent uniform annual payments. To determine
the annual cost for the average engine in each scenario, the
present value of the selling price increment for the average engine
must be calculated from the non-recurring and recurring costs.
This present value engine price increase is then multiplied by a
suitable capital recovery factor to obtain the uniform equivalent
annual cost.
To derive the average engine price increase (AP), certain
assumptions were made. First, the revenue which is received from
the engine price increase is exactly equal to the total engine
costs including profit. In this manner, no excess profits or
losses are experienced. Second, the revenue received from the
average price increase is equal to the annual sales multiplied by
AP. Third, the revenues for a particular year's sales are received
on January 1 of the following year, and the total annual costs are
charged on January 1 of the year in which they are incurred. A
discount rate of 10 percent per annum is used to calculate the
present value of the costs and revenues at the first date a stan-
dard is implemented in a scenario, i.e., 1982 or 1986. The average
engine price increase C^P), therefore, is equivalent to the total
discounted annual costs, divided by the total discounted annual
engine sales.
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22
Before the discounted selling price increment can actually be
calculated, however, a time series of expenditures for the non-
recurring costs must be estimated, and an average recurring cost
increment has to be determined. The cash flow was estimated by
assuming that the most substantial disbursements would occur near
the implementation date of each standard when certification,
service evaluation, and initial production were taking place
simultaneously. The earliest expenditures would be predominately
for development. The estimated annual disbursements are shown in
Figures 1 and 2.
The average recurring cost increment is different for each
year because the sales mix of engines does not remain constant.
Rather than laboriously sales weighting the recurring engine prices
for every year under each scenario, the cost increment was sales
weighted by the fleet mix which occurred over the life of each
standard. This greatly simplified the computations without com-
promising the final results of the analysis.
A computer program was devised to compute the average engine
selling price increment for each scenario. The results for each
scenarios are shown in Table 10. The derivation of these figures
is presented in Appendix E.
Now that the discounted selling price increase for the average
engine has been determined, it must be annualized with the use of a
suitable capital recovery factor. The discount rate for this
factor is the same as that used to determine the present value of
the engine costs and revenues, i.e., 10 percent per annum. The
useful life of the average engine in each scenario is found by
sales weighting each engine model's respective useful life as
previously discussed under "Fleet Projection." The average useful
lives and the appropriate capital recovery factors are shown in
Table 10, along with the annual engine costs for each scenario.
Operating Costs
Three types of operating costs have been identified as a
consequence of emission control schemes. These costs are the
differences in ground idle fuel consumption, in-flight cruise fuel
consumption, and hot section maintenance between non-regulated and
regulated engines. They are calculated on an equivalent annual
basis for the average engine in each scenario. Therefore, it is
not necessary to derive uniform payments as it was for the engine
selling price increment.
Fuel Consumption Increments - Idle
To meet the proposed standards, manufacturers will improve the
combustion efficiency of their engines. This improvement will
result in a specific fuel consumption (SFC) reduction during ground
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23
idle operations. Most engines will experience a 3 percent reduc-
tion in idle SFC with the exception of the JT8D. The JT8D's
smokeless combustor is already more efficient than average; it will
experience about a 1 percent improvement.
The General Electric and Rolls Royce engines which are pro-
duced in compliance with the 1982 NME and 1986 IUE Standards may
experience a net increase in fuel consumption in spite of the
improvement in combustion efficiency. The use of sector burning by
these engines causes an 8 percent decrease in component efficiency,
which coupled with the 3 percent benefit in combustion efficiency,
yields a 5 percent overall penalty in idle SFC.
Furthermore, the CFM56 apparently can only meet the 1982 CO
emission standards by increasing its idle thrust from about 4
percent up to 6 percent of rated output. The EPA estimates this
will result in a 19,6 percent increase in idle fuel consumption in
addition to any other fuel usage increment brought about by com-
bustion efficiency changes or the use of sector burning.
The fuel consumption increments (idle only) are summarized in
Table 11. These changes are the differences in usage from a base-
line engine to the controlled engine under the various standards.
For the 1982 standards (which includes the retrofit standard) and
the 1986 standard with no pre-existing 1982 standards, the baseline
engine for each model is its uncontrolled counterpart. For the
1986 standard, which is implemented in addition to a prior stan-
dard, the already-controlled engine is used as a baseline. As
shown (Table 11), the use of sector burning has two interesting
effects. First, the majority of engines in compliance with the
1982 standards will experience an increase in idle SFC unless
GE produces the alternative combustor modifications. Second, when
sector burning is replaced by staged combustors in 1986, a sub-
stantial fuel benefit occurs. This is most apparent for the CFM56
where a portion of the benefit is due to a reduction ir idle thrust
since the staged combustor is more effective than sector burning in
reducing CO emissions.
The derivation of incremental idle fuel costs is presented in
Appendix F and is summarized in Table 12 for each scenario.
Fuel Consumption Increments - Cruise
The staged combustion systems that have been configured by the
engine manufacturers to comply with the 1986 NOx standard are not
only more complex than current systems, but also weigh more. The
manufacturers have estimated this increase at between 200 and 300
pounds per engine. This additional weight increases the aerodynam-
ic drag of the aircraft during the flight regime. This penalty is
most significant during cruising flight, and manifests itself as an
increase in fuel consumption. The value of this increment was
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24
estimated by Logistics Management Institute (Day and Bertrand,
1978) for various aircraft categories from industry-supplied data.
The LMI document, however, did not specify cost penalties for
the medium-and regular-bodied aircraft that are represented in
EPA's fleet projection. The costs for these aircraft were arbit-
rarily estimated by EPA and are included in Table 13.
The fuel penalty costs are assigned to each engine model on
the basis of its predominate usage on a particular aircraft type.
As shown in Table 14, these figures are weighted on the basis
of the engine's useful life and market share to determine the cost
for the fleet average engine.
Maintenance Increments
Historically, even minor corabustor changes have often resulted
in an increase in maintenance costs. Therefore, some increase is
anticipated when emission control hardware is implemented. Two
types of maintenance penalties could occur. The first type is the
result of introducing immature or unproven hardware. As stated by
the engine manufacturers in submittals to EPA (United Technologies,
1977) and testimony at the aircraft public hearings (EPA, 1978a) ,
the standards as originally proposed would not have allowed enough
time to adequately service evaluate the requisite hardware. The
penalty of introducing these immature combustors would last until
an adequate amount of data could be collected and production
configurations were modified accordingly. In the case of the
proposed 1984 NME Standard (NOx control), this penalty would last
about 3 years as estimated by PWA (United Technologies, 1977) at a
cost of about $493.5 million to the industry worldwide (Day and
Bertrand, 1978). The penalty for the proposed 1981 NME and 1985
IUE Standards was somewhat less. In considering the significance
of the penalties, EPA concluded that the benefits do not justify
the added costs. For this reason, it is very likely that the
implementation schedule for HC and CO control will be delayed from
the proposed 1981 date to 1982 for newly-manufactured engines, and
from 1985 to 1986 for retrofitted engines. The proposed 1984
standard which controls NOx in addition to HC and CO, will likely
be delayed to 1986, if implemented. EPA has determined that these
dates would allow the industry to perform adequate service evalua-
tions which will avoid the penalty associated with introducing
immature combustors.
The second potential maintenance cost is associated with a
reduction in combustor durability throughout the life of the
engine, higher replacement costs for life limited parts, or is the
result of maintaining all new engine parts. Durability can be
impacted because emission control generally entails "fine tuning"
the combustor system. A common design requirement involves alter-
ing the airflow distibution of the combustor. This can adversely
affect liner temperatures and turbine inlet temperature profiles.
Higher replacement costs are not necessarily caused by an increase
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25
in manufacturing costs, as was demonstrated in EPA-sponsored
investigations of staged-combustion designs (Appendix C), but
occur through the amortization of low-emissions research and
deve lopment expenses over the expected production volume. In
addition, some low emissions configurations will be produced with
hardware that has no existing counterpart. The maintenance of this
hardware, such as the sectoring control valve used by General
Electric and Rolls Royce, is totally charged to the costs of
emission control.
Some maintenance increases which have been described may be
partially offset by the use of staged combustors to- reduce NOx
emissions. The aromatic content of jet fuel has been escalating in
recent years and the use of high-aromatic shale and coal-derived
fuels in the future is almost certain. Conventional technology
combustors cannot cope with these fuels: combustion becomes smokey
and increases in flame luminosity cause combustor cooling prob-
lems. Staged combustors avoid these problems since they are lean
burning and, therefore, operate at cooler temperatures. Moreover,
higher aromatic fuels are expected to be lower in price. This
potential benefit has not been accounted for in this analysis.
Since no experience with in-service, gaseous emission control
hardware has occurred, the quantification of potential maintenance
penalties is difficult to determine and is, of course, specula-
tive. This has been amply exemplified in Pratt and Whitney Air-
craft submittals to EPA with regard to this subject. When EPA
conducted its economic analysis of the proposed standards, PWA
(United Technologies, 1977) estimated a maintenance cost increase
for engines in compliance with the 1982 NME and 1986 IUE Stan-
dards. In its most recent submittal to EPA (United Technologies,
1979), PWA concluded that no maintenance increment is expected from
the use of low-emission hardware in these engines.
Overall, the evidence suggests that a penalty is associated
with the use of low-emission technology in all engines which are
produced in compliance with any of the standards. For 1982 tech-
nology, this penalty is expected to be small. For 1986 technology,
industry representatives have stated that the penalty will probably
be significant, although no real evidence has been presented to
substantiate this claim. .
EPA independently estimated the increase in maintenance costs
based primarily on data acquired from engine manufacturers (Appen-
dix B), major air carriers (Appendix B), the LMI document (Day and
Bertrand, 1978), and independent manufacturers of engine combustion
chambers (Appendix C). The incremental maintenance costs for the
1986 NME Standard are based on a "worst case" situation. EPA
remains skeptical of industry estimates concerning the incremental
maintenance costs for low-NOx staged combustors, and will continue
to evaluate these potential penalties in the future. The fleet-
weighted annual costs of the expected maintenance increment for
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26
each engine are shown in Table 15. The costs are determined for
parent engines only. All derivative engines are assumed to have
basically the same maintenance characteristics and, hence, the same
costs as their respective parent engines. No penalty is estimated
for the CFM 56 because it is a completely new engine without any
prior maintenance history. Therefore, controlling this engine has
no increment associated with it. The cost per engine hour and the
fleet-weighted annual cost for each scenario are, derived in Appen-
dix G.
Emission Reductions
Reductions in gaseous exhaust emissions for each engine model
were calculated from data contained in an EPA report entitled,
"Review of Emissions Control Technology for Aircraft Gas Turbine
Engines" (Hunt, 1979). The emission reductions for the average
engine in each control scenario are derived in Appendix H.
The engine specific reductions were computed by assuming an
average landing and takeoff cycle (LTO) time for all airports in
the nation. Previous cost-effectiveness reports (Wilcox and Hunt,
1977 and 1978) used the EPA defined LTO time of 26 minutes. This
cycle was originally developed to reflect peak traffic times at the
nation's busiest air terminals. The use of that figure was criti-
cized by industry representatives as being unrealistically long to
characterize the national average. EPA concurs with this criti-
cism, but at the time of the previous reports the Agency had no
data upon which to base a more realistic average LTO time. It
should also be clarified that only HC and CO are significantly
affected by the choice of an average figure. All but an extremely
small portion of these emissions are generated during the taxi-idle
modes of the LTO. There are two principle reasons for this:
(1) emissions of HC and CO are related to the poor combustion
environment that occurs during low-power operations and (2) the
taxi-idle time-in-mode makes up the majority of the LTO cycle.
The production of NOx emissions is associated with the hot
temperatures that occur during high-power operations; consequently,
very little NOx is generated during the taxi-idle mode. The time
spent in the higher power operations of the cycle does not change
significantly between airports, although the taxi-idle times do.
Therefore, the average airport NOx emissions are adequately char-
acterized by EPA's LTO cycle, but HC and CO emissions are not.
In the preparation of this report, airport specific taxi-idle
times were determined for EPA by ORI (Bauchspies, 1979), and were
based on data contained in FAA (1977) and Bauchspies et al.
(1978). This information is displayed in Table 16. The figures in
this table are block-to-block times and, therefore, do not include
the time incurred while idling at the gate, or, as described by CAB
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27
(1978), the time the aircraft is being towed by the ground-service
tractor. Additionally, the control strategies being analyzed are
most effective in future years when air traffic is expected to
become more congested. For this reason, some period of time
greater than the national average is more realistic when projecting
airport emissions. The simple average of the figures contained .in
Table 16 is about 16 minutes. To account for the above mentioned
shortcomings of this taxi-idle time, 19 minutes is used to calcu-
late the HC and CO emission reductions from all types of aircraft
engines.
The gaseous emission reductions for the average engine in each
scenario are presented in Table 17.
Baseline Cost Effectiveness Values
The cost effectiveness values for each of the scenarios are
derived in Table 18. Scenarios 1, 2, 6, and 7 are the most cost
effective and can be considered to have the same level of cost
effectiveness because of uncertainties in the analysis. Each of
these scenarios control HC and CO emissions beginning in 1982
without any follow-on 1986 NOx standard.
As shown in Table 18, the introduction of the CF6 alternative
in Scenarios 6 and 7 makes very little difference in the new engine
selling price increment when compared to Scenarios 1 and 2. Even
though the alternative. is much less expensive to manufacturer
(Table 6), that savings is equally offset in the price calculations
by the increased non-recurring costs which are incurred in devel-
oping the alternative combustion system. Therefore, the slightly
lower cost-effectiveness values for Scenarios 6 and 7 are due
almost exclusively to the redu.cxon in idle fuel consumption when
sector burning engines cease prediction.
The effect of the 1986 re.rofit- in conjunction with other
standards (i.e., Scenarios 2, 4 and 7) is to de'crease che cost-
effectiveness of the strategy, iithough the result is of minor
consequence. Nevertheless, the -ffeet is caused by two principle
factors. First, the annualizect average engine cost is higher.
This occurs because the retrofit !•'it costs more than the new engine
increment (Table 6), and the remaining useful life of the average
engine is less. Second, JTSDs account for as much as 35 percent of
the controlled engines in these scenarios. Since the JT8D "smoke-
less combustor" is already cleaner than many larger engines at
present, the preponderance of JTCOs causes a reduction in the
pollution abated from the average engine. However, the large
number of these engines also offsets some of the decrease in cost
effectiveness by lowering the average costs for maintenance and
idle fuel consumption. This is accomplished by reducing the
fraction of high-cost engines in the fleet (e.g., the CFM 56 sector
burning fuel penalty is greatly reduced in Scenario 4).
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28
The next higher group of cost-effectiveness values comes about
in Scenarios 3 and 4 when the 1986 NOx standard is added to the
1982 standards. The primary cause for higher values is that the
non-recurring expenses for controlling HC and CO only, must be
amortized over fewer engines; consequently, each engine produced
costs more.
The 1986 NOx standard scenarios are the least cost effective
(Scenarios 5, 8, and 9). Within the group, however, the cost
effectiveness is best when the 1986 standard is promulgated without
a prior 1982 standard. The cost per ton of pollutant reduced is
still much larger than if any 1982 strategy were promulgated alone
(including the retrofit). As shown in Table 18, Scenario 8, a
substantial benefit in idle fuel consumption results when staged,
low-NOx combustors replace sector burning hardware in GE and RR
engines. Comparing Scenarios 8 and 9 reveals that there is very
little change in the NOx cost-effectiveness figure regardless of
whether or not GE sector burns.
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29 .
DISCUSSION
Part II
In this part of the discussion, a variety of assumptions are
applied to more completely document alternative cost-effectiveness
values. This part includes a sensitivity analysis which investi-
gates the effect that variations in the production of new engines
would have on the final cost-effectiveness values. Alternative
cost-effectiveness values are also determined for each of the
control scenarios by assuming that the cost-effectiveness computa-
tions should be restricted to include only those costs that have
yet to be spent. Finally, the incremental cost effectiveness of
the 1986 IUE Standard (retrofit) is determined.
Sensitivity Analysis
The fleet projection used in this analysis is an attempt to
ascertain future facts by using reasoned assumptions. As time
passes and updated information becomes available, the projection
will become less accurate. Also, no matter how carefully consider-
ed, the assumptions which were necessary to complete the projec-
tion may be incorrect. The sensitivity analysis is an attempt to
account for these inaccuracies by parametrically evaluating the
effect of different production volumes on the average engine
selling price and the final cost effectiveness of the various
scenarios.
The number of newly-manufactured engines produced under each
scenario is varied by +_ 10 percent. To ensure that the production
volume, is the only parameter being evaluated, it is assumed that
the variations are the result of fluctuations in air traffic
demand; therefore, the expected useful life of each engine is
unchanged. Also, it is assumed that each engine model experiences
the same relative change in production volume. In this way, the
costs for the other major cost categories remain unchanged. The
sensitivity analysis excludes variations in the number of retro-
fitted engines since the number of these engines is not expected to
change significantly.
Table 19 shows the sensitivity of the costs to changes in new
engine production volumes. By manipulating the projected produc-
tion figures by +_ 10 percent, the engine selling price increments
vary from about 3 to 9 percent. The final cost-effectiveness
values vary from 2 to 7 percent depending on the scenario. These
small differences do not seriously affect the accuracy or compar-
ability of the baseline cost-effectiveness figures. Therefore, the
overall analysis shows very little effect from reasonable changes
in the projection of new engine production.
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30
Sunk Investments Excluded
The aircraft standards were originally promulgated in 1973.
Since that time, the industry has been working toward achieving
those standards. Currently, the standards have undergone revisions
in reponse to more recent information concerning the costs of
control, technological limitations, and air quality impacts of
aircraft and aircraft engines. Because the standards are being
reevaluated on the basis of whether or not to proceed from this
time forward, it is also reasonable to review the cost effective-
ness of the standards on the basis of what must be spent from this
point onward to achieve the requisite controls. Therefore, pre-
vious expenditures are treated as unrecoverable sunk costs, and
judgments as to the cost effectiveness of the standards are made
entirely on the future costs and benefits which will accure.
EPA's estimate of the annual disbursements which are necessary
for the engine manufacturers to begin the production of the engines
in compliance with the various standards was previously presented
in Figure 1 and 2. These figures are based on a division of the
total non-recurring expenses into two categories: funds that
have already been expended and funds that remain to be expended.
EPA estimated that at the time this analysis was prepared (mid-
1979), manufacturers had spent about 75 percent of their develop-
ment funds to meet the 1982 standards, or about 60 percent of the
total non-recurring costs. For the 1986 standard, it was estimated
that manufacturers had spent about 10 percent of the development
costs or about 6 percent of the total non-recurring costs.
As previously stated, the average engine selling price incre-
ment was calculated by assuming that all annual costs are incurred
at the beginning of each year. Therefore, to compute the average
engine selling price, all sunk costs prior to January 1, 1980 were
excluded. Table 20 presents the alternative cost-effectiveness
values, along with the previously determined baseline (total cost)
values for comparison. As might be expected, the cost-effective-
ness values for the 1982 standards (NME and IDE), are affected the
most since a large share of the non-recurring funds will already
be expended by 1980.
Retrofit Cost Effectiveness
The 1986 IUE Standard was not separately evaluated in Part I
of the Discussion because it is not, strictly speaking, a complete
control strategy by itself. The retrofit would not be considered
without an accompanying newly-manufactured engine standard. It is
relevant, however, to be concerned with the incremental cost
effectiveness of the retrofit as an addition to the 1982 NME
Standard.
Since the 1986 retrofit standard is optional, only the costs
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31
and benefits which would accrue exclusively because of the retrofit
are considered. Specifically, any costs which were previously
incurred to develop the requisite control hardware are excluded
from the cost-effectiveness computations. All other costs and
benefits are calculated in the same manner as described in the
Methodology. Table 21 shows the cost-effectiveness derivation for
the retrofit. In comparison to the 1982 NME Standard (Table 18),
the incremental cost effectiveness of the 1986 IDE Standard is
significantly more expensive.
The higher cost figures result primarily from 1) a high
annual engine price increment, and 2) the relatively low emission
reductions for the average engine. For the average retrofit
engine, the selling price increment is up to $3,000 higher than the
increment which is associated with a newly manufactured engine
(Tables 18 and 21). This higher cost results because installing
pollution control hardware in an in-service engine is more expen-
sive than installing the same hardware in its newly produced
counterpart. Also, the useful life of the average retrofitted
engine is only 7 years, compared to 15 years for a new engine.
This causes the annual cost of the retrofit to be relatively more
expensive because the selling price increment is amortized over a
much shorter time period.
The relatively low emission reductions from the average
retrofitted engine also contribute to the high cost-effective
values. For the average in-service engine, the mass of emissions
abated are only about 50 percent of those achieved by controlling
the average 1982 newly-manufactured engine (Tables 18 and 21).
The preponderance of JT8D engines in the retrofit fleet is the
primary cause of this lower emission reduction. JTSDs have a
relatively clean baseline combustor (because of the previous
retrofit for smoke control), so when these engines are controlled,
the mass of pollutants which are reduced is less than for many
other engines. The above factors, acting in concert, overwhelm the
retrofits small fuel savings, and result in a higher cost per ton
of pollutant reduced in comparison to the 1982 newly-manufactured
engine standard.
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32
DISCUSSION
Part III
Aircraft Cost Effectiveness Compared to Other Strategies
In this part, the cost effectiveness of aircraft engine
emission controls are evaluated on the basis of their relative cost
effectiveness. Before this evaluation is presented, however,
several of the basic tenants of cost-effectiveness .analysis are
briefly discussed.
First, the point at which a control strategy is not considered
to be cost effective has never been precisely defined. For this
reason, the cost-effectiveness values of other implemented or
seriously considered strategies are used as a general benchmark for
determining cost efficiency. Second, when future control strate-
gies are being evaluated, it is important to remember that as the
most efficient controls are implemented, each succeeding control
increment will have a higher marginal cost. Because of this
expected price increase, it is not necessarily correct to make
decisions with regard to a potential control strategy by limiting
its cost effectiveness to that of other past or presently consid-
ered programs. Third, because of uncertainties and different
methodologies, differences between analyses of up to a few hundred
dollars per ton for HC, less than a few hundred dollars per ton for
CO (e.g., perhaps $100 per ton), and several hundred dollars per
ton for NOx should generally be regarded as insignificant.
As previously presented, the aircraft cost-effectiveness
values which will be compared with values for other strategies are
the figures which characterize "post-1979 costs" and the incremen-
tal cost of the 1986 retrofit standard. These values are sum-
marized in Table 22. In the cost effectiveness comparisons, the
values that reflect the exclusion of pre-1980 costs are appropriate
since the decision of whether or not to proceed must be based only
on the future investment which will be required to attain the goal
of aircraft engine pollution control. Previously expended funds
are not relevant to this issue. The cost effectiveness values for
the other strategies are presented in Table 23. The values for
these strategies range up to about $1,000 per ton of HC, $50 per
ton of CO, and $3,000 per ton of NOx. Emission control strategies
for aircraft engines will be considered cost effective if they are
reasonably close to these values for each respective pollutant.
As shown in Tables 22 and 23, all scenarios which included the
1986 NME Standard (low NOx) either singly, or in combination with a
previous standard, are not considered to be as cost effective as
other non-aircraft control strategies at this time (Scenarios 5, 8,
and 9). Controlling HC and NOx emissions in Scenario 5 for about
$1,000 and $3,400, respectively, are reasonably close to the upper
values of about $1,000 and $3,000, respectively, for other non-
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33
aircraft related strategies. The cost effectiveness of $900 for GO
control, however, is much higher than the cost of about $50 per
ton for other non-aircraft strategies. In cases such as these, it
is important to remember that one of the main determinants of cost
effectiveness is the cost allocation methodology. Therefore, when
one or more of the pollutants being controlled is significantly
more costly than with other techniques, an alternate method may be
used to ascertain if reweighting the costs would lead to more
reasonable cost-effectiveness values for all pollutants. In this
instance, $150 per ton of CO and $3,400 per ton of NOx will be
specified as cost-effectiveness values. The portion of total costs
which are represented by these two pollutants are then recalculated
with their respective total emission reductions, and the remaining
costs are burdened to HC control. By following this methodology,
the cost effectiveness for HC is $1,781 per ton. This is still
greater than the $1,000 per ton for non-aircraft strategies as
shown in Table 23.
Scenarios 8 and 9 are not reasonably close to the $3,000 per
ton of NOx allotted for non-aircraft strategies (Table 22).
Therefore, no 1986 NME Standard scenario is as cost effective as
other alternative methods of controlling NOx when a 1982 NME
Standard is also promulgated.
Control scenarios which evaluate the 1982 NME Standard and
1986 IUE Standard remain to be discussed. The cost-effectiveness
values for Scenarios 1, 2, 6, and 7 are either less than, or
reasonably close to, the values for other non-aircraft strategies.
Controlling HC emissions with the 1982 NME Standard singly, or in
conjunction with the 1986 IUE Standard, ranges from $110 to $200
per ton. This is significantly more cost effective than the
highest value for other non-aircraft strategies, i.e., $1,000 per
ton. The reduction in CO emissions at $90 to $160 per ton is
reasonably close to the $50 per ton for other strategies, and
is also considered to be equally as cost effective.
The cost-effectiveness values for Scenario 3 are $230 per ton
of HC and $180 per ton of CO reduced. This scenario evaluates the
1982 NME Standard when the 1986 NME Standard is also promulgated.
Scenario 4 evaluates the 1982 NME and 1986 IUE Standards as a
single control strategy when the 1986 NME Standard is also pro-
mulgated. The cost-effectiveness of controlling HC and CO in this
scenario is $310 per ton and $230 per ton, respectively. The
alternate methodology of cost allocation will be applied to Scen-
ario 3 and 4. The CO cost effectiveness values will be specified
at $150 and $50 per ton. The costs of controlling HC when CO is
specified at $150 per ton are $260 per ton for Scenario 3 and $420
per ton for Scenario 4. When CO is specified at $50 per ton, the
costs of controlling HC increase to $400 and $560 per ton for
Scenario 3 and 4, respectively. It is clear that values below $50
per ton of CO could be specified and the cost-effectiveness of
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34
controlling HC emissions from aircraft engine would remain less
costly per ton than the maximum which is already being spent by
non-aircraft strategies.
As a control strategy, the retrofit has an incremental or
marginal cost effectiveness of $590 for HC and $360 for CO. Since
CO control at this value is much greater than for other strategies,
but the HC value is lower, the alternate cost methodology will be
used to ascertain the effect of reallocating the costs of pollution
control. If the CO control is specified at $150 per ton, the HC
cost-effectiveness value would be $925. The CO could also be
specified as low as $50/ton, the maximum currently being spent
(Table 23), with a resulting HC cost effectiveness of about $1,100.
Even at this level for HC, the retrofit is reasonably close to the
$1,000 per ton which has been calculated for non-aircraft stra-
tegies. Therefore, the retrofit is as cost effective as the
non-aircraft control strategies.
Table 24 summarizes the cost-effectiveness comparisons of the
various control scenarios and the 1986 retrofit strategy.
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35
REFERENCES CITED
Air Transport Association of America. 1978. Comments to Docket
No. OMSAPC 78-1. Letter of November 27, 1978 to EPA from C.F. von
Kann, ATA, Washington, D.C.
Aviation Week and Space Technology. 1978. Operating and cost
data - B727, B737, DC-9, BAG 111: Aircraft in passenger service -
year 1977. 108(21)36-37.
Aviation Week and Space Technology. 1979. Operating and cost
data: Airbus A300B. 110(9)37.
Bauchspies, J.S., L. Kaplan, C.W. Patten, M. Robinson, W. Simpson,
and F. Zuman. 1978. FAA airport emissions data base user's
manual. FAA-EQ-78-06. [As cited by Bauchspies (1979)].
Bauchspies, J.S., Operations Research, Inc., Transportation
Systems Division. 1979. Letter of March 5, 1979 to R.S. Wilcox,
Emission Control Technology Division, Office of Mobile Source Air
Pollution Control, U.S. Environmental Protection Agency, Ann Arbor,
MI.
Civil Areonautics Board. 1978. Aircraft operating cost and
performance report for calender years 1976 and 1977, Vol. 12.
Economic Evaluation Division, Bureau of Accounts and Standards,
Washington, D.C.
Day, C.F. and H.E. Bertrand. 1978. The economic impact of revised
gaseous emission regulations for commercial aircraft engines. EPA
Contract No. 68-01-4647 (Task EP701).
Douglas Aircraft Company. 1976. Cost/benefit tradeoffs for
reducing the energy consumption of the commercial air trans-
port system, Volume II: Market and economic analyses. NASA
CR-137924.
Federal Aviation Administration. 1977. Fleet projection to
year 2000. Office of Aviation Policy, Washington, D.C. (unpub-
lished.)
. 1977. Airline delay trends 1974-1975. FAA-EM-77
-2. [As cited by Bauchspies (1979).]
Munt, R.W. 1978. U.S. aircraft fleet projection and engine
inventory to the year 2000. TSR AC78-02. Emission Control Tech-
nology Division, Office of Mobile Source Air Pollution Control,
U.S. Environmental Protection Agency, Ann Arbor, MI.
1979. Review of emissions control technology for
aircraft gas turbine engines. Emission Control Technology Divi-
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sion, Office of Mobile Source Air Pollution Control, U.S. Environ-
mental Protection Agency, Ann Arbor, MI.
O'Rourke, C. 1979. Cost effectiveness of Portland I/M program.
Internal memorandum to J. Becker, U.S. Environmental Protection
Agency, Emission Control Technology Division, Ann Arbor, MI.
United Technologies Corporation, Pratt and Whitney Aircraft
Group. 1977. Estimated economic impact of proposed EPA emissions
regulations for aircraft. East Hartford, CT. Prepared for Log-
istics Management Institute, Washington, D.C.
. 1978 Control of air pollution from aircraft and
aircraft engines, Vol. 3. Comments to U.S. Environmental Protec-
tion Agency Docket No. OMSAPC 78-1. East Hartford, CT.
Titcomb, G.A., United Technologies Corporation, Pratt and Whitney
Aircraft Group. 1979. Letter of February 28, 1979 to C.L. Gray,
Emission Control Technology Division, Office of Mobile Source Air
Pollution Control, U.S. Environmental Protection Agency, Ann Arbor,
MI.
U.S. Department of Transportation, Interagency Task Force on
Motor Vehicle Goals Beyond 1980. 1976. Air quality, noise,
and health.
U.S. Environmental Protection Agency. 1976. Exhaust and' crankcase
regulations for the 1978 and later model year motorcycles. Emis-
sion Control Technology Division, Ann Arbor, MI.
. 1978a. Public hearing on revised aircraft engine
emission standards. November 2, 1978. Region IX, 215 Fremont
Street, San Francisco, CA.
. 1978b. Proposed gaseous emission regula-
tions for 1983 and later model year heavy-duty engines: draft
regulatory analysis. Emission Control Technology Division,
Ann Arbor, MI.
. 1979. Gaseous emission regulations for 1983 and
later model year light-duty trucks. 44FR40784.
Vector Research, Inc. 1978. Cost effectiveness estimates for
mobile source emission control. U.S. Environmental Protection
Agency contract.
Wilcox, R.S. and R.W. Munt. 1978. Cost-effectiveness analysis
of the proposed revision in the exhaust emission standards for
new and in-use gas turbine aircraft engines based on EPA's inde-
pendent estimates. TSR AC78-01. Emission Control Technology
Division, Office of Mobile Source Air Pollution Control, U.S.
Environmental Protection Agency, Ann Arbor, MI.
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37
Wilcox, R.S. and R.W. Munt. 1978. Cost-effectiveness analysis
of the proposed revisions in the exhaust emission standards
for new and in-use gas turbine aircraft engines based on industry
estimates. TSR AC77-02. Emission Control Technology Division,
Office of Mobile Source Air Pollution Con trol, U.S. Environmental
Protection Agency, Ann Arbor, MI.
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Table 1
oo
f)
Scenario
Number
1.
2.
3.
4.
Scenario
Title
Description of the Aircraft Emission Control Scenarios
Description
1982 NME only.
1982 NME and 1986 IUE only.
1982 NME in conjunction
with 1986 NME.
1982 NME and 1986 IUE in conjuntion
with 1986 NME.
1986 NME only.
1982 NME only with CF6 alterntive,
1982 NME and 1986 IUE with CF6
alternative.
1986 NME in conjunction with 1982
standards.
1986 NME in conjunction with 1982
standards and the CF6 alternative,
Evaluates HC and CO control
tured engines only.
in 1982 for newly-manufac-
Evaluates HC and CO control in 1982 for newly-manufactured
engines and a retrofit of the same hardware for in-use
engines by 1986.
Evaluates four years of HC and CO control in 1982 newly-
manufactured engines prior to the control of NOx in addi-
tion to HC and CO in 1986 newly-manufactured engines.
Evaluates four years of HC and CO control in 1982 newly-
manufactured and 1986 in-use engines prior to the control
of NOx in addition to HC and CO in 1986 newly-manufactured
engines.
Evaluates HC, CO, and NOx control in 1986 newly-manufac-
tured engines only.
Evaluates HC and CO control in 1982 newly-manufactured only
with GE using combustor change on all CF6 engine models
instead of sector burning. RR continues with sector burning.
Evaluates HC and CO control in 1982 newly-manufactured and
1986 in-use engines with GE using combustor change on CF6
engine models.
Evaluates HC, CO, and NOx control in 1986 newly-manufactured
engines as an increment to previously implemented 1982 standards
Evaluates HC, CO, and NOx control in 1986 newly-manufactured
engines as an increment to previously implemented 1982 stan-
dards in which only RR ssector burns, i.e., with the CF6
alternative.
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Table 2
Estimated Engines Affected by Each Standard
1982 NME
JT8D-17
JT8D-200
JT8D-7
JT9D-7R
JT9D-70
CF6-6
CF6-32
CF6-50
CF6-45
CF6-80
RB211-22B
RB211-535
RB211-524
CFM56
In-Service
3,349
0
1,250
0
0
587
0
144
0
0
583
0
0
0
1986 IUE
Spares
670
0
250
•0
0
117
0
29
0
0
116
0
0
0
w/1986 NME
Total
4,019
0
1,500
0
0
704
0
173
0
0
699
0
0
0
In-Service
0
764
302.
93
307
235
180
503
187
91
235
174
235
404
Spares
0
153
60
19
61
47
36
101
37
18
47
35
47
81
Total
0
917
362
112
368
282
216
604
224
109
282
209
282
485
1986 NME
In-Service
0
816
1,869
286
1,869
1,267
1,084
3,225
573
286
1,267
1,088
1,267
818
Spares
0
163
374
57
374
253
217
645
115
57
253
218
253
164
Total
0
979
2,243
343
2,243
1,520
1,301
3,870
688
343
1,520
1,306
1,520
982
5,913
7,095
3..710
4,452
15,715
18,858
-------
40
Table 3
Population Weighting Factors by Scenario
Group 1 Group 2
Scenarios Scenarios
#1, 2, 6, 7 #3, 4
1982 NME 1982 NME
(w/o 1986 NME) (w/1986 NME)
We igh t ing
Factors
JT8D-17
JT8D-200
JT9D-7
JT9D-7R
JT9D-70
CF6-6
CF6-32
CF6-50
CF6-45
CF6-80
RB211-22B
RB211-535
RB211-524
CFM-56
0
0.08
0.11
0.02
0.11
0.08
0.07
0.19
0.04
0.02
0.08
0.06
0.08
0.06
Weighting
Factors
0
0.22
0.08
0.03
0.08
0.06
0.05
0.14
0.05
0.02
0.06
0.05
0.06
0.11
Group 3
Scenarios
#2, 4, 7
1986 IUE I/
(w/1982 NME)
Weighting
Factors
0.57
0
0.21
0
0
0.10
0
0.02
0
0
0.10
0
0
0
Group 4
Scenarios
#5, 8, 9
1986 NME
We igh t ing
Factors
0.05
0.12
0.02
0.12
0.08
0.07
0.21
0.04
0.02
0.08
0.07
0.08
0.05
T7Thesepopulation weighting factors represent only the retro-
fitted portion of the fleet. Therefore, they are used in conjunc-
tion with the population factors for newly manufactured engines to
describe the total fleet in Scenarios #2, 4, and 7.
-------
JT8D-17
JT8D-200
JT9D-7
JT9D-7R
JT9D-70
CF6-6
CF6-32
CF6-45
CF6-50
CF6-80
RB211-22B
RB211-535
RB211-524
CFM56
41
Table 4
Useful Life Weight
Retrofit
Useful Life (yr)
7
NA
7
NA
NA
7
NA
NA
10
NA
7
NA
NA
NA ,
Scenarios #2, 4, 7
1986 IUE (W/1982 NME)
Weighting Factor
0.47
NA
0.47
NA
.NA
0.47
NA
NA
0.67
NA
0.47
NA
NA
NA
-------
42
Component
Development
Table 5
Cost Components and Their Elements
Element
Design and general laboratory effort
General engine hardware
Specific modification hardware
Various engine tests
General engineering support
Emission testing
Certification
Engine hardware
Specific modification hardware
Endurance test
Certification test
Miscellaneous tests
Flight test
Emissions test
General engineering support
Service Evaluation
Administrative costs
Maintenance
Inspect ion
Engine hardware
Initial Production
Engine Dedication
Non-Recurring Total
Tool design
Tool procurement
Initial start-up
Engines
Development
Certification
Service Evaluation
Initial Production
Engine Dedication
New Engine Increment
Parts
Labor
Retrofit
Parts
Labor
-------
Table 6
Engine Costs Associated with the 1982 Standards
(Thousands of 1978 dollars)
JT8D-17
JT8D-200
JT9D-7
JT9D-7R
JT9D-70
CF6-6
CF6-32
CF6-50
CF6-45
CF6-80
RB211-22B
RB21 1-535
RB211-524
CFM56
JT10D
Development
19,725
14,063
14,063
5,130.
7,370
7,370
44,608
5,763
3,860
5,850
Certification
6,575
4,688
4,688
600
600
4,565
4,565
150
NA •
Service
Evaluation
1,200
600
600
276
284
1,500
NA
NA
Initial
Production
300
800
500
165
16.5
850
35
' "NA
Non-recurring
Total
27,800
. 20,151
19,851
6,171
8,419
7,370
51,523
5,763
4,.565
4,045
5,850
New Engine
Increment
2.7
2.7
6
6
6
25
25
25
6
25
25
25
5
NA
Retrofit
23.5
55
47
43
50
73
73
NA
NA
-p-
U)
Spey
NA
NA
NA
NA
NA
NA
NA
-------
Table 7
Engine Costs Associated with the 1986 Low-NOx Standard
(Thousands of 1978 dollars)
JT8D-200
JT9D-7
JT9D-7R
JT9D-70
CF6-6
CF6-32
CF6-50
CF6-45
CF6-80
RB211-22B
RB211-535
RB211-524
CFM56
JT10D
Spey
Development
18,000
35,300
35,300
16,000
16,000
30,000
13,000
NA
NA
Certification
17,200
4,000
17,200
7,700
3,400
7,700
3,900
3,900
4,565
4,565
4,565
5,000
NA
NA
Service
Evaluation
4,200
5,300
5,340
5,400
5,400
4,300
3, 300
NA
NA
Initial
Production
1,800
3,800
3,800
3,400
3,400
3,400
2,600
NA
NA
Non-recurring
Total
24,000
61,600
4,000
61,000
32,500
3,400
32,500
3,900
3,900
42,300
4,600
4,600
23,900
NA
NA
New Engine
Increment
21
33
33
25
25
25
25
25
25
25
25
17
NA
NA
-------
45
Table 8
Parent Engines and Their Derivatives
Parent
JT8D-17 (-7, -9, -15)
JT9D-7
JT9D-70
CF6-6
CF6-50
RB211-22
CFM-56
JT10D
Derivative
JT8D-200
JT9D-7R
NA
CF6-32
CF6-45
CF6-80
RB211-535
RB211-524
NA
NA
Characteristics
Higher thrust—basically
same core
Higher thrust—same core
Clipped fan—same core
Derated—same core
Lower thrust—smaller in size-
basically same core
Clipped fan—same core
Higher thrust—same core
-------
Table 9
Engine Costs Associated with the CF6 Alternative Combustor I/
(Thousands of 1978 dollars)
CF6-6
CF6-32
CF6-80
CF6-50
CF6-45
Develop- Cert if i-
ment cation
7,000 4,600
21 4,600
NA NA
3/ 4,600
3_/ 4,600
Service
Evaluation
600
21
NA
I/
I/
Initial Non-recurring
Production Total
500 12,700
27, 4,600
NA NA
3_/ 4, 600
3_/ 4,600
New Engine
Increment
8
8
NA
6
6
\J Based on the latest manufacturer or vendor submittals to EPA
(Appendicies B and C).
2j Requirements for the CF6-32 already have been fulfilled by the
CF6-6 parent engine; therefore, no additional cost is incurred.
3_/ Requirements for the CF6-50 and CF6-45 already have been
fulfilled by the closely related CF6-80; therefore, no addi-
tional cost is incurred.
-------
47
Table 10
Annual Engine Expenses
Scenario #
1
2
3
4
5
6
7
8
9
Average
Engine
Increase
40,800
41,200
78,800
56,000
72,600
35,500
39,100
57,200
57,200
Average
Useful
Life
15
13
15
10
15
15
13
15
15
Capital
Recovery
Factor
.1315
.1408
.1315
.1628
.1315
.1315
.1408
.1315
.1315
Annual
Engine
Cost
5,360
5,800
10,360
9,120
9,550
4,670
5,500
7,520
7,520
-------
Approximate
Percentage
48
Table
Idle Fuel
1982
w/ GE
1982 I/ Alternative
JT8D-17
JT8D-200
JT9D-7
JT9D-7R
JT9D-70
CF6-6
CF6-32
CF6-50
CF6-45
CF6-80
RB211-22B
RB211-535
RB211-524
CFM56
+ 1
-i-l
+3
+3
+3
-5
-5
-5
-5
+3
-5
-5
-5
-22
+ 1
+ 1
+ 3
+ 3
+ 3
+ 3
+ 3
+ 3
+3
+3
-5
-5
-5
-22
11
Increment
1986 w/
1982
0
0
0
0
0
+8
+8
+8
+8
0
+8
+8
+8
+20
by Engine Model
1986
w/1982
Alternative
0
0
0
0
0
0
0
0
0
0
+8
+8
+8
+ 20
1986
w/o
1982
+ 1
+ 1
+ 3
+ 3
+ 3
+ 3
+ 3
+ 3
+ 3
+ 3
+ 3
+ 3
+ 3
+3
I/ Since the 1985 retrofit standard begins in 1982, it is termed a
T982 standard.
-------
49
Table 12
Annual Idle Fuel Consumption Increment for the Average Engine
Scenario
1
2
3
4
5
6
7
8
9
Gallons
+2,855
+2,630
+3,306
+1,569
-2,632
+ 674
+ 566
-5,425
-3,023
Dollars I/
+1,142
+1,052
+1,322
+ 628
-1,053
+ 270
+ 226
-2,170
-1..209
I/ At a nominal value of $.40 per gallon.
-------
50
Table 13
Cruise Flight Fuel Penalty
Engine Weight Increase (Ibm)
Cost per Pound per Year ($)
Cost per Engine per Year ($)
4EWB 3EWB 2EWB 2EMB 3ERB 2ERB
300 200 200 200 200 200
8 5 4 4 4 2.5
2400 1000 800 800 800 500
-------
51
Table 14
Annual Cruise Fuel Consumption Increment
for the Average Engine Brought About by NOx Control
(Scenarios 5, 8, and 9 only) (1978 dollars)
JT8D-200
JT9D-7
JT9D-7R
JT9D-70
CF6-6
CF6-32
CF6-50
CF6-45
CF6-80
RB211-22B
RB211-535
RB211-524
CFM56
Weighted
Useful Life
1
1
1
1
1
1
1
1
1
1
1
1
1
Weighted
Sales
.05
.12
.02
.12
.08
.07
-.21
.04
.02
.08
.07
.08
.05 .
Annual
Cruise Penalty
(Dollars)
500
2,400
2,40'0
1,000
1,000
800
1,000
1 , 000 .
1,000
1,000
800
1,000
500
Weighted Annual
Cruise Penalty
(Dollars)
25
288
48
120
80
56
210
40
20
80
56
80
25
1,128
-------
52
Table 15
Annual Maintenance Costs for the Average Engine (1978 dollars)
Scenario Dollars
1 632
2 604
3 541
4 526
5 42,500
6 632
7 604
8 42,500
9 42,500
-------
Table 16
Average Airport-Specific Taxi-Idle Times
Airport
Atlanta Hartsfield
Boston Logan
Cleveland Hopkins
Washington National
Denver Stapleton
Dallas-Forth Worth
Detroit Metropolitan
Newark
Honolulu
Houston
John F. Kennedy
McCarran
Los Angeles
La Guardia
Kansas City
Memphis
Miami
Minneapolis-St. Paul
Chicago O'Hare
Philadelphia
Phoenix Sky Harbor
Greater Pittsburgh
Seattle Tacoma
San Francisco
Lambert St. Louis
Tampa
Jumbo Jet. Long-Range Jet
Medium-Range
Jet (3 engines)
Medium-Range
Jet (2 engines)
ATL
BOS
CLE
DCA
DEN
DFW
DTW
EWR
HNL
IAH
JFK
LAS
LAX
LGA
MCI
MEM
MIA
MSP
ORD
PHL
PHX
PIT
SEA
SFO
STL
TPA
Idle
Out
11.8
9.6
6.1
8.4
7.3
7.3
6.1
10.7
18.6
10.2
19.8
11.8
10.7
15.3
9.6
7.6
8.4
8.4
15.3
9.6
10.7
5.0
7.3
10.7
7.3
10.4
Idle
In
8.0
5.7
5.7
5.7
8.0
6.8
6.8
9.1
13.0
9.3
12.5
8.2
9.1
9.1
9.3
7.4
6.8
5.7
10.3
8.0
8.8
5.7
5.7
6.8
5.7
8.0
Idle
Out
10.3
8.3
5.3
7.3
6.3
6.3
5.3
9.3
16.2
8.9
17.3
10.3
9.3
13.3
8.3
6.6
7.3
7.3
13.3
8.3
9.3
4.3
6.3
9.3
6.3
9.0
Idle
In
7.0
5.0
5.0
5.0
7.0
6.0
6.0
8.0
11.4
8.2
11.0
7.2
8.0
8.0
8.2
6.5
6.0
5.0
9.0
7.0
7.7
5.0
5.0
6.0
5.0
7.8
Idle
Out
10.3
8.3
5.3
7.3
6.3
6.3
5.3
9.3
16.2
8.9
17.3
10.3
9.3
13.3
8.3
6.6
7.3
7.3
13.3
8.3
9.3
4.3
6.3
9.3
6.3
..9.0
Idle
In
7.0
5.0
5.0
5.0
7.0
6.0
6.0
8.0
11.4
8.2
11.0
7.2
8.0
8.0
8.2
6.5
6.0
5.0
9.0
7.0
7.7
5.0
5.0
6.0
5.0
7.8
Idle
Out
9.9
7.9
5.1
7.0
6.0
6.0
5.1
8.9
16.5
8.5
16.6
9.9
8.9
12.7
7.9
6.3
7.0
7.0
12.7
7.9
8.9
4.1
6.0
8.9
6.0
8.6
Idle
In
6.7
4.8
4.8
4.8
6.7
5.8
5.7
7.7
10.9
7.9
10.6
6.9
7.7
7.7
7.9
6.2
5.8
4.8
8.6
6.7
7.4
4.8
4.8
5.8
4.8
7.5
u>
-------
54
Table 17
Annual Pollution Reductions for the Average Engine
Scenario
1
2
3
4
5
6
7
8
9
Annual
HC
16.4
15.4
14.5
12.2
17.7
16.4
15.4
NA
NA
Pollution Reduction
CO
20.8
19.8
19.1
16.9
19.2
20.8
19.8
NA
NA
(tons)
NOx
NA
NA
NA
NA
5.0
NA
NA
5.0
5.0
-------
Table 18
Cost Effectiveness Computation (1978 Dollars)
Engine
Cost "x~ Capital
introl Increment Engine Recovery
:enario (?) Life (years) Factor
1 40,800
2 41,200
3 78,800
4 56,000
5 72,600
6 35,300
7 39,100
8 57,200
9 57,200
15
13
15
10
15
15
13
15
15
0.1315
0.1408
0.1315
0.1628
0.1315
0.1315
0.1408
0.1315
0.1315
Annual
Idle Fuel
Increment
($)
+ 1142
+ 1052
+ 1322
+ 628
-1053
+ 270
+ 226
-2170
-1209
Annual
Cruise Fuel
Increment
($)
0
0
0
0
+ 1128
0
0
+ 1128
+1128 -
Annu a 1
Maintenance
($)
+632
+604
+541
+526
+42,500
+632
+604
+42,500
+42,500
Average Engine Cost Effectiveness
Pollution Reduction ($/t)
HC CO NOx HC CO NOx
16.4
15.4
14.5
12.2
17.7
16.4
15.4
0
0
20.8
19.8
19.1
16.9
19.2
20.8
19.8
0
0
0
0
0
0
5.0
0
0
5.0
5.0
220
240
420
420
980
170
210
NA
NA
170
190
320
300
900
130
160
NA
NA
NA
NA
NA
NA
3500
NA
NA
9800
10,000
-------
56
Table 19
Effect of Variations in Fleet Projections (1978 Dollars)
Cost Effectiveness ($/t)
Selling Price
Increment ($) -10 Percent Baseline +10 Percent
Scenario -10% Baseline +10% HC CO NOx HC CO NOx HC CO NOx
1 43,300 40,800 38,800 230 180 NA 220 170 NA 210 160 NA
2 42,700 41,200 39,800 250 190 NA 240 190 NA 240 180 NA
3 85,900 78,800 73,100 450 340 NA 420 320 NA 400 300 NA
4 57,600 56,000 54,500 430 310 NA 420 300 NA 410 300 NA
5 77,400 72,600 68,700 990 920 3,500 980 900 3,500 970 900 3,400
6 37,800 35,500 33,300 180 140 NA 170 130 NA 160 130 NA
7 40,800 39,100 37,500 210 170 NA 210 160 NA 400 310 NA
8 62,000 57,200 53,300 NA NA 9,900 NA NA 9,800 NA NA 9,700
9 62,000 57,200 53,300 NA NA 10,000 NA NA 10,000 NA NA 9,900
-------
57
Table 20
Effect of Excluding Sunk Cost (1978 Dollars)
Selling Price Increase ($)
Scenario
1
2
3
4
5
6
7
8
9
Post
26
31
36
39
68
20
29
53
53
1979
,100
,800
,700
,800
,700
,600
,600
,300
,300
Baseline
40
41
78
56
72
35
39
57
57
,800
,200
,800
,000
,600
,500
,100
,200
,200
HC
160
200
230
310
970
110
160
NA
NA
Cost
Post
CO
120
160
180
230
900
90
130
NA
NA
Effectiveness
1979
NOx
NA
NA
NA
NA
3,400
NA
NA
9,700
9,900
($/t)
Baseline
HC
220
240
420
420
980
170
210
NA
NA
CO
170
190
320
300
900
130
160
NA
NA
NOx
NA
NA
NA
NA
3,500
NA
NA
9,800
10,000
-------
Engine
Cost
Increment
($)
41,798 I/
Table 21
Incremental Cost Effectiveness of the 1986 IUE Standard (1978 Dollars)
"x" Annual
Engine Capital Idle Fuel Annual Average Engine Cost Effectiveness
Life Recovery Increment Maintenance Pollution Reduction (t) ($/t)
(years) Factor ($) ($) HC CO HC CO
0.2054
-497 21
460 3/
7.3 4/ 12.0 4/
590
360
I/ Derived in Appendix D.
2/ Derived in Appendix C.
3/ Derived in Appendix B.
4/ Derived in Appendix H.
Ul
00
-------
Table 22
Selected Cost-Effectiveness Values for Aircraft Emission Control (1978 Dollars)
Scenario/ Strategy
Scenario
Number
1.
2.
3.
4.
5.
6.
7.
8.
9.
Description
1982 NME only.
1982 NME and 1986 IUE only.
1982 NME in conjunction with 1986 NME.
1982 NME and 1986 IUE in conjunction
with 1986 NME.
1986 NME only.
1982 NME only with CF6 alternative.
1982 NME and 1986 IUE with CF6
alternative.
1-986 NME in conjunction with 1982
standards.
1986 NME in conjunction with 1982
Cost Effectiveness ($/t)
(Post 1979 costs only)
HC
160
200
230
310
970
110
160
NA
NA
CO
120
160
180
230
900
90
130
NA
NA
NOx
NA
NA
NA
NA
3,400
NA
NA
9,700
9,900
standards and the CF6 alternative.
1986 IUE (retrofit) only. 590 360 NA
-------
60
Table 23
Cost Effectiveness for Non-Aircraft Control Strategies
(1978 Dollars)
Cost Effectiveness ($/t)
Control Strategy
Degreasing 0-48%
Gravure 0-98%
Gas Terminal 0-67%
Miscellaneous Chemicals 0-35%
Dry Cleaning 0-80%
GHDV Evap. 5.8-0.5 g/mi.
Degreasing 41-90%
Industrial Finishing 76-97%
Gasoline Handling 16-50%
Miscellaneous Chemicals 35-53%
Gasoline Distributions 67-99%
Coke Ovens 0-80%
LDV Exhaust 0.9-0.41 g/mi
Gas Handling 51-91%
GHDV 90% of Baseline
DHDV 90% of Baseline
LDV I/M
LOT 1.7-0.8 g/mi
Motorcycles 9 to 8-22.5 g/mi
Motorcycles 34.67-27.4 g/mi
LDV 15-3.4
LDV 3.1-0.4
Stationary Engines 0-75%
Utility Boilers 0-90%
HC
CO
NOx
139-
-230 I/
-60 I/
0 I/
0 I/
10 I/
20 1/2/
100 I/
110 I/
110 I/
220 I/
300 I/
490 I/
530 I/
780 1/3/
300 4/ 8 4/
162 4/
955 5/ 49 5/
-201 11
420 8/
neg.8/
48 J_/
2,763 6/
2,700 I/
400 I/
1,400 I/
JY U. S. DOT (1976)
2/ A more recent EPA analysis, which supports a regulation yet to
be published as a proposal, yields numbers in the range of $70
to $250 per ton (yet to be released).
3/ Agrees reasonably well with a more recent EPA analysis (yet to
be released).
47 U.S. EPA (1978b).
_5/ O'Rourke (1979).
6/ Vector Research (1978).
TJ U.S. EPA (1979).
8/ U.S. EPA (1976).
-------
61
Table 24
Summary Results of Aircraft Emission Control
Cost Effectiveness Evaluation
Scenario/Strategy
Scenario
Number
1.
2.
3.
4.
5.
6.
7.
8.
9.
Description
1982 NME only.
1982 NME and 1986 IUE only.
1982 NME in conjunction with 1986 NME.
1982 NME and 1986 IUE in conjunction
with 1986 NME.
1986 NME only.
1982 NME only with CF6 alternative.
1982 NME and 1986 IUE with CF6
alternative.
1986 NME in conjunction with 1982
standards.
1986 NME in conjunction with 1982
standards and the CF6 alternative.
1986 IUE (retrofit) only.
Relative Cost Effectiveness
Compared to Other Strategies
Better
Better
Better
Better
Worse
Better
Better
Worse
Worse
Equivalent
I/Relative cost effectiveness is determined on the basis of the
maximum cost for other strategies, taking into account that those
figures also have an associated range of costs because of uncertan-
ties which are found in all cost-effectiveness analyses.
-------
35
30
Ul
^
CO
25
20
U-l
O
U)
§ 15
•H
10
Figure 1
Time Expenditure of Non-Recurring Funds for the 1982 NME and 1986 IUE Standards.
32.30 32.30 32.30
25.84
19.38
12.92
6.46
CF6 ALTERNATIVE ONLY
75 76 77 78 79 80 81 82 83 84 85
Year
-------
80
70
60
Figure 2
Time Expenditure of Non-Recurring Funds for
the 1986 NME Standard.
77.71
73.62
W
t-i
rt
o
o
oo
r-
co
o
•H
r-l
50
30
20
10
53.17
40.90
28.63
12.27
4.09
4.09
>i09 4.09
OJ
75
76
77
78
79
80
81
82
83
84
85
Year
-------
A-l
Appendix A
EPA Cost Questionaire
-------
_QUESTIONNAIRF TO MAJOR ATRl'TMF.9
Enclosure I
Retrofit Cost Information
To be most cost effective, airlines are expected to rework existing
engine components into low-emission configurations during routine main-
tenance to the greatest extent possible. Therefore, the economic impact
of the 1985 Retrofit Standard will be defined as the increment between
the cost of incorporating low-emission hardware and the cost of routinely
repairing existing components. We expect that your company will be able
to supply only the routine repair costs. The costs associated with the
low-emission hardware will be supplied by the engine manufacturers.
The baseline routine repair cost estimates should be specific for each
generic engine family, unless otherwise indicated. Exclude engine
disassembly and assembly unless components are involved that are not
normally accessible during hot section or related maintenance. Costs
for repairing (or replacing as appropriate) the following items are of
interest at this time:
Combustion liners and dome
Fuel nozzle tip and support
Fuel manifold
• Fuel sectoring control hardware (CF6 generic families)
Transition duct (JT8D-1, -7, and -9 generic family)
Transition duct guides (JT8D-1, -7, and -9 and JT8D -15 and -17
generic families)
The answers may be reported as an average with an associated range of
uncertainty, if necessary. Additional baseline information may be
included if, in your opinion, more detail or other items should :be
considered. All expenses should be reported in 1978 dollars.
If premature engine removals appear necessary to complete the retrofit
within the scheduled time, they will be accounted for in a more general
manner using data from Enclosure II and other information from the
comments on this and prior rulemaking actions.
A-2
-------
Enclosure II
Maintenance Cost Information
Possible maintenance increments associated with the low-emission control
hardware will be evaluated with the following data elements. These
elements represent the absolute minimum amount of information from the
airlines that is essential to complete the analysis. Additional comments
are invited if, in your opinion, other information should also be considered.
The estimates should be specific for each generic engine family.
1. What is the mean of the times between overhaul?
2. What is the mean of calendar intervals between overhaul?
3. What is the mean shop cost for engine maintenance in 1978
dollars?
4. What is the mean number of man-hours necessary to remove and
reinstall an engine on the aircraft?
-------
TO PARKFR HRNNJFTN
Enclosure I
. Manufacturer's Coat and Price Information '
The following information will be used to develop EPA's third and final
cost-effectiveness analysis of the proposed standards. The format of
this report will closely resemble TSR AC78-01 which is enclosed. Speci-
fic responses are needed to assure a more accurate and complete economic
assessment than has been possible in the past. If some cost categories
require modification to be more representative, please retain the degree
of detail. Specific figures based on your records for each generic
engine family are preferred; however, when these are unavailable, please
include an estimate, based on your best judgment, of the anticipated cost.
In these non-specific cases, insert the word "typical" under the engine
model heading along with any additional qualifying information. The
expenses may be presented as an average with an associated range of
uncertainty where necessary. Only the costs incurred as a consequence
of the gaseous emission standards should b'e included in the cost esti-
mates; items relating to normal product improvement should be excluded.
All prices should be reported in 1978 dollars.
When low-emission hardware involves a design change to existing hard-
ware, or the addition of a new part, and it is not obvious why it is
necessary, please include a brief explanation of the modification in-
cluding how it relates to the control strategy.
Your submittal should include, but not be limited to, information on the
following items:
1981 NME and 1985 Retrofit HC and CO Control Hardware
General Electric Pratt. and Whitney Aircraft
nozzle tip dual-aerating nozzle
nozzle support single-aerating nozzle
check valves
swirler
1984 NME HC, CO, and NOx Staged Combustion Hardware
General Electric Pratt and Whitney Aircraft
nozzle assembly nozzle assemblies
swirlers
During EPA's initial investigation of the PWA aerating nozzle design,
several pieces of information were acquired. This information may be
used as a basis for your cost estimates of fuel systems not produced by
Parker Hannifin.
A-A
-------
A- 5
ENCLOSURE U
If the low-emission fuel nozzles will require special overhaul tools and
dies, please estimate the retail value per set and the number of sets
typically required by an airline maintenance shop.
-------
A-6
NEW ENGINE PRICE INCREMENT1
Generic Engine Model Price Increment
Do not include amortization on non-recurring costs.
-------
INITIAL PRODUCTION
Increment in Manufacturing Cost Economic Pro-
Engine Model Part Name Tool Design Tool Procurement Based on Current Part duction Volume
>
Increment should account for increase or decrease in material, labor, machining, and corporate profit.
No amortization of development, certification, or other non-recurring expenses should be included. If no
conventional counterpart exists, the increment will be the full manufacturing cost of the part.
-------
A-8
Enclosure II
Retrofit Cost Information
The following information is needed for our evaluation of the economic
impact of the 1985 Retrofit Standard. Please make your responses as
specific as possible for each generic engine family. Some of the answers
may be reported as an average with an associated range of uncertainty
where necessary.
1. To be most cost effective, airlines will rework existing engine
components into low-emission configurations to the greatest extent
possible. Therefore, it seems plausible that in most cases, items
such as all new combustion liners or cans will not be purchased,
but instead a kit containing modified parts will be available to
rework existing hardware. Please detail the minimum number of
parts per engine that airlines are likely to use for in-house low-
emission modifications along with an estimate of their retail
price.
2. As described in question one, the retrofit of low-emission hardware
is expected to be accomplished during routine maintenance activities.
The following simplified format was developed to provide the necessary
information while providing a clearer understanding of how the
final results were derived. The basic elements of the format may
also be useful in analyzing other portions of the economic impact.
The estimates should be specified for each hardware item (e.g.,
combustion liner, fuel nozzle tip, and transition duct), and exclude
engine disassembly and assembly unless the modification would
involve items not normally accessible during hot section or related
maintenance. (This possibility exists in parts c and d below.) In
all cases, a general description of the changes should be included
along with the reason why the modification is necessary. Please
specify the cost per manhour used in the analysis.
a. When low-emission modifications are incorporated into the
repair of existing hardware, certain materials and labor that would
have normally been expended should be deducted from the cost of the
modification.
Response format: ($ Mod. hardware 4- $ Mod. labor) - ($ Routine
material + $ Routine labor) = $ Increment
b. When new low-emission hardware totally replaces hardware that
xjould normally be reworked or repaired, the cost of the repair
(material and labor) should be deducted from the purchase price of
the new part.
-------
A-9
Response format: $ New component - ($ Routine material + $ Routine
labor) = $ Increment
c. In parts which have no existing counterpart, both the cost of
the part (available from question one), and the average number of
manhours for its installation should be reported.
Response format: $ New component + $ Installation labor =
$ Increment
d. For parts which must be reworked to accept the low-emission
modification (e.g., JT9D-7 diffuser case), the cost should include
disassembly and assembly if it involves items not normally accessible
during typical hot section or related maintenance.
Response format: $ New parts + $ Mod. labor + $ Installation
labor = $ Increment.
3. Estimate the one-time cost of new rework fixtures or other tools
which will be needed (per set), and the number- of sets necessary to
equip the average repair facility.
4. What are the range and mean of times between overhaul experienced
by different models? We realize that much maintenance, is done "on
condition", but as part of the statistical history, the mean TBO's
are available.
-------
A-10
Enclosure III
Maintenance Cost Information
Part I
In some instances, maintenance increments may be associated with the use
of low-emission control hardware due to durability degradation and added
complexity. Estimate what increases may be experienced by engines in
compliance with the 1981 NME and 1984 NME Standards. These changes may
be reported as a "best" and "worst" case if desired. Be sure to include
the quantitative basis for the estimate.
Completion of this part should not be substituted for Part II.
Part II
In addition to the above, possible maintenance increments will be evaluated
with the following data elements. These elements represent the absolute
minimum amount of baseline information that is essential to complete
EPA"s analysis. Additional comments are invited if in your opinion
other information should also be considered.
The estimates should be specific for each generic engine family.
1. What is the mean time between overhauls?
(See Enclosure II question 4).
2. What is the mean calendar interval between overhauls?
3. What is the mean shop cost for engine maintenance?
4. What is the mean number of man-hours necessary to remove
and reinstall an engine on the aircraft?
5. For a mature low NOx staged combustor (1984 NME) , what is the
increase in labor (man-hours) for a typical repair beyond
that incurred by a conventional combustor. This additional
effort should reflect the increase in complexity only.
6. What is the mean incremental cost per shop visit that may
be expected because of sector burn control hardware?
-------
ADDITIONAL ENCLOSURES TO PRATT A*1D '^ITiEY QUESTIOTJATRF
ENCLOSURE V
I. As referenced below, the following questions pertain to Pratt &
Whitney Aircraft's December 15, 1978 submittal to Mr. Cornelius Day
of Logistics Management Institute (hereafter called the LMI submittal),
and the letter of August 25, 1978 from Mr. G. N. Frazier, Vice President,
Engineering, Pratt & Whitney Aircraft, to Charles L. Gray, Director,
Emissions Control Technology Division, EPA.
1. LMI Submittal.
Are the costs for the JT8D-209 the same as those for the JT8D-9?
2. LMI Submittal, Table I and II, pages 3-1 and 3-2, and Pratt
& Whitney Aircraft's August 25, 1978 letter by Mr. G. N. Frazier
to EPA.
In Mr. Frazier's letter, the 1981 NME total development costs
appear to be the sum of the Table I column entitled Total
Through 1977 for each specific engine model, and the total cost
for each specific engine model as listed in Table II of the
LMI submittal. Does this mean that none of the other previous
development costs are attributable to the proposed 1981 NME
gaseous exhaust emission rules as shown in Table I?
3. LMI Submittal, Table I and II, pages 3-1 and 3-2.
What portion of these costs is attributable only to gaseous
emissions control? Presumably some funds were expended for
smoke control and these should be excluded since the existing
standard is not significantly affected by the proposed smoke
standard.
4. LMI Submittal, Table II, page 3-2.
Some of the categories in this table are the same as those used
in EPA Report No. AC78-01 (e.g., service evaluation), while
others are not. We assume that certification is included
and initial production (e.g., tooling) is excluded; however,
neither is directly stated nor implied in the text. Is this
correct? If these categories are not accounted for in Table
II, what are the costs associated with them?
5. LMI Submittal, Table II, page 3-2.
Why is the future development cost of the 1984 NME JT10D so
high? It would seem that vorbix experience gained from the
JT9D and the fact that the JT10D is not in production would
both reduce the total development for this engine as well as the
new selling price increment shown in Table III, page 4-1.
6. LMI Submittal, Table III, page 4-1 and Pratt & Whitney
Aircraft's August 25, 1978 letter by Mr. G. N. Frazier to EPA.
As the text of your LMI submittal indicates, the production
A-ll
-------
A-12
—2—
price increments for 1981 NME includes a portion of the
development costs which will be recovered. In Mr. Frazier's
letter, the increments do not account for the recovery of
specific development costs, yet these figures are nearly
identical to those in Table III (LMI). Please clarify
this apparent discrepancy.
7. LMI Submittal, Table IV, page 5-2.
For the column entitled Retrofit in Conjunction With Other
Hot Section Maintenance, is the Shop Labor (Manhours) the
difference between normal maintenance on the affected parts
and the installation of the retrofit kit consisting of new
parts, or just the time it takes to install the retrofit kit?
In other words, some manpower would have normally been expended
maintaining the affected parts and EPA wants to be sure that
fact is accounted for so the true incremental cost is reported.
The same is true for material costs.
8. LMI Submittal, Table VI, page 6-1.
For the worst case, estimated increases in maintenance costs
included a value for HP turbine degradation in the 1984 NME
configuration. Please specify the degree of turbine maintenance
assumed (rework or replace blades) and the typical charge for
this work.
9. Pratt & Whitney Aircraft's August 25, 1978 letter by Mr. G.
N. Frazier to EPA.
How is the aggregate 1981 NME price increment without specific
development costs determined? The prices quoted seem very high
for a new engine where some changes may be as simple as
rearranging the location of dilution and cooling holes in the
combustor.
II. The following questions are general in nature.
1. It is our understanding that the dual aerating nozzle will
be used by the JT8D and JT9D to meet the 1981 NME and 1985
Retrofit Standards until the less expensive single aerating
nozzle is perfected. What is the anticipated introduction date
and price difference of the single aerating nozzle compared to
the dual aerating nozzle, and what will be the impact on the
new engine price increment?
2. Will Pratt & Whitney Aircraft produce low emission configurations
for the domestic airline fleet and uncontrolled configurations for
foreign air carriers not operating in the U.S.? Or will only low
emission configurations be produced?
-------
A-13
ENCLOSURE V
I. As referenced below, the following questions pertain to Pratt &
Whitney Aircraft's December 15, 1978 submittal to Mr. Cornelius Day
of Logistics Management Institute (hereafter called the LMI submittal),
and the letter of August 25, 1978 from Mr. G. N. Frazier, Vice President,
Engineering, Pratt & Whitney Aircraft, to Charles L. Gray, Director,
Emissions Control Technology Division, EPA.
1. LMI Submittal.
Are the costs for the JT8D-209 the same as those for the JT8D-9?
2. LMI Submittal, Table I and II, pages 3-1 and 3-2, and Pratt
& Whitney Aircraft's August 25, 1978 letter by Mr. G. N. Frazier
to EPA.
In Mr. Frazier's letter, the 1981 NME total development costs
appear to be the sum of the Table I column entitled Total
Through 1977 for each specific engine model, and the total cost
for each specific engine model as listed in Table II of the
LMI submittal. Does this mean that none of the other previous
development costs are attributable to the proposed 1981 NME
gaseous exhaust emission rules as shown in Table I?
3. LMI Submittal, Table I and II, pages 3-1 and 3-2.
What portion of these costs is attributable only to gaseous
emissions control? Presumably some funds were expended for
smoke control and these should be excluded since the existing
standard is not significantly affected by the proposed smoke
standard.
4. LMI Submittal. Table II, page 3-2.
Some of the categories in this table are the same as those used
in EPA Report No. AC78-01 (e.g., service evaluation), while
others are not. We assume that certification is included
and initial production (e.g., tooling) is excluded; however,
neither is directly stated nor implied in the text. Is this
correct? If these categories are not accounted for in Table
II, what are the costs associated with them?
5. LMI Submittal, Table II, page 3-2.
Why is the future development cost of the 1984 NME JT10D so
high? It would seem that vorbix experience gained from the
JT9D and the fact that the JT10D is not in production would
both reduce the total development for this engine as well as the
new selling price increment shown in Table III, page 4-1.
6. LMI Submittal, Table III, page 4-1 and Pratt & Whitney
Aircraft's August 25, 1978 letter by Mr. G. N. Frazier to EPA.
As the text of your LMI submittal indicates, the production
-------
A-14
-2-
price increments for 1981 1IME includes a portion of the
development costs which will be recovered. In Mr. Frazier's
letter, the increments do not account for the recovery of
specific development costs, yet these figures are nearly
identical to those in Table III (LMI). Please clarify
this apparent discrepancy.
7. LMI Submittal, Table IV. page 5-2.
For the column entitled Retrofit in Conjunction With Other
Hot Section Maintenance, is the Shop Labor (Manhours) the
difference between normal maintenance on the affected parts
and the installation of the retrofit kit consisting of new
parts, or just the time it takes to install the retrofit kit?
In other words, some manpower would have normally been expended
maintaining the affected parts and EPA wants to be sure that.
fact is accounted for so the true incremental cost is reported.
The same is true for material costs.
8. LMI Submittal, Table VI, page 6-1.
For the worst case, estimated increases in maintenance costs
included a value for HP turbine degradation in the 1984 NME
configuration. Please specify the degree of turbine maintenance
assumed (rework or replace blades) and the typical charge for
this work..
9. Pratt & Whitney Aircraft's August 25,'1978 letter by Mr. G.
N. Frazier to EPA.
How is the aggregate 1981 NME price increment without specific
development costs determined? The prices quoted seem very high
for a new engine where some changes may be as simple as
rearranging the location of dilution and cooling holes in the
combustor.
II. The following questions are general in nature.
1. It is our understanding that the dual aerating nozzle will
be used by the JT8D and JT9D to meet the 1981 NME and 1985
Retrofit Standards until the less expensive single aerating
nozzle is perfected. What is the anticipated introduction date
and price difference of the single aerating nozzle compared to
the dual aerating nozzle, and what will be the impact on the
new engine price increment?
2. Will Pratt & Whitney Aircraft produce low emission configurations
for the domestic airline fleet and uncontrolled configurations for
foreign air carriers not operating in the U.S.? Or will only low
emission configurations be produced?
-------
ADDITIONAL ENCLOSURFS TO PRATT AND !-?!!rNEV qiESTTQ
Enclosure IV
The 15 December 1978 Pratt and Whitney submittal to Logistics Management
Institute has been reviewed. Please include information on the JT8D-209
in your submittal to this request.;
A-1
-------
ADVANCED DEVELOPMENT, CERTIFICATION, AND SERVICE EVALUATION COSTS1
(in $1000)
Development Certification Service Evaluation
Design and
Generic General General
Engine Laboratory Engineering Testing Certification Miscellaneous Engine
Model Effort Support Hardware Tests Tests Hardware Total Cost
Development should not include product improvement,
-------
mFSTTWIATRE Tfl ATRCAF TIIRWRCTIF>W!UFACTIIRFS
Enclosure I
Manufacturer's Cost and Price Information
The following information will be used to develop EPA's third and final
planned cost-effectiveness analysis of the proposed standards. The
format of this report will closely resemble TSR AC78-01 which is enclosed.
Specific responses are needed to assure a more accurate and complete
economic assessment than has been possible in the past. If some cost
categories require modification to be more representative, please retain
the degree of detail. The expenses may be presented as an average with
an associated range of uncertainty where necessary. Only the costs
incurred as a consequence of the gaseous emission standards should be
included in the cost estimates; items relating to normal product improve-
ment should be excluded.
A-17
-------
ADVANCED DEVELOPMENT COSTS1
(in $1000)
Design and »
Generic General General Specific 3 - General
Engine Laboratory Engine Modification Rig Engine Emission Special Engineering
Model Effort Hardware Hardware Tests Tests Testing Tests Support Total Cost
00
Development should not include product improvement.
2
If applicable, include number of engines dedicated.
Breakdown into general tasks, e.g., cold and hot starting test,
coking and temperature distribution test, and low cycle fatigue test, as appropriate.
-------
CERTIFICATION COSTS
(in $1000)
Overtemperature
Generic Specific 150 Hour Hot and Test and L.P. . Foreign Engin-
Engine Engine Modification Endurance Certifica- Cold Start- Turbluu Ovnr- LCP Object Emission ciTliti) Flight Totol
Model Hardware Hardware Test tion Test inR Test Speed Test Test Ingestiqn Teuting Support Teat Cost
-------
INITIAL PRODUCTION
Increment in Manufacturing.Cost
Generic Engine Model Part Name Tool Design Tool Procurement Based on Current Part
NJ
o
Increment should account for increase or decrease in material, labor, machining, and corporate profit,
1 f^.i — i..^.j
-------
A-21
SERVICE EVALUATION1
Generic
Engine
Model Total Cost Total Time Required
Include a description of typical service evaluation, i.e., what
responsibilities or cost categories are incurred separately by the
engine manufacturer and the air carrier?
-------
A-22
NEW ENGINE PRICE INCREMENT
Generic
Engine Model Price Increment1
Do not include amortization of non-recurring costs.
-------
B-l
Appendix B
Cost Information
Submitted in Response to
EPA Questionnaire
-------
7 <
Commercial Products Division
East Hartford. Connecticut 06108
December 21, 1978
Mr. Charles L. Gray, Jr.
Director
Emission Control Technology Division
United States Environmental Protection Agency
Ann Arbor, Michigan 48105
Dear Mr. Gray:
This letter is in reply to your letter of December 8 in which you re-
quest additional information relative to the proposed aircraft engine
exhaust emission standards.
Enclosed are attachments answering the inquiries of your Enclosures IV
and V. We are working on answers to enclosures I, II and III.
Considerable effort is involved. We will forward the requested
information as soon as it is available.
Very truly yours,
Gordon /\. Titcomb
Executive Vice President
cc: Mr. George Kittredge
Senior Technical Advisor
Office of Mobile Source Air Pollution Control
Environmental Protection Agency
Waterside Mall, Washington, D.C. 20460
Re: Docket #OMSAPC-78-I
Control of Air Pollution from Aircraft and Aircraft Engines
Enclosures
-------
Enclosure IV - All production v:'8D-209 engines will incorporate the
best available reduced emission -:ombustion systems. Therefore, there
should be no requirement to retro'it in use JT8D-209 engines. If a cur-
rent production type combustion .;ystetn were incorporated in this en-
gine, the engine price would be lower by an a.nounf equal to the price
increment listed for the JT8D-9 in Table III of P&WA's report to LMI.
Enclosure V -
I.I. See above (Enclosure IV discussion).
1.2. The other costs- listed in Table I, Technology Contracts, Propo-
sals and Emissions R&D, relate to technology development efforts
for control of all emitted pollutants of concern (HC, CO, NOX
and smoke). A precise breakdown of these costs to reflect the
specific effort directed toward the proposed 1981 NME Rules is
not possible.
1.3. All costs listed in Tables I and II are attributable to gaseous
emissions control. Efforts related to reduction of smoke emis-
sions have been undertaken only to the extent made necessary by
increases in smoke above the proposed level induced by the con-
trol strategies adopted for gaseous emissions. The proposed regu-
lations require simultaneous control of gaseous and smoke emis-
,sions.
1.4. . True.
1.5. The JT10D development cost estimates are predicated upon a more
difficult development effort induced by operation at higher pres-
sure ratios and by constraints placed upon combustion section
volume and geometry. The competitive pressure of the market place
for specific fuel consumption and shorter lighter engines have
brought about this situation.
1.6. The figures in Mr. Frazier's letter arc averages for each engine
model of the specific increments presented in Table III. These
increments and their averages although not including the specific
development cost write-offs for each engine model, do include al-
lowances for recovery of development costs. Development costs
have -been "pooled" and then allocated across the entire P&WA com-
mercial engine production base in a manner analogous to the way
other necessary development costs arc recovere.d.
1.7. The Shop Labor (tnanhours) represents the added work over the work
that would normally be performed at a hot section inspection
(HSl). It includes the manhours required to rework parts and the
effort required for more extensive disassembly into the engine
than would normally be required in a normal HSI.
B-3
-------
1.8. Tlic .worst case burner repi'r estimates an; 'prod i cntrd on the
basis that JT9D engines msrurfactured from January 1984 to the
end of 1986 (NME) will hav immature burners with up to a 50%
reduction in life relative :o a mature 1984 rule vorbix burner.
This analysis indicates thai; these engines will require two extra
shop visits for burner an! turbine repair during an engine's
lifetime. Our best engineering judgements indicate that a 50% re-
duction in burner life will cause a 25% reduction in high pres-
sure turbine (HPT) life and a 12% reduction in low pressure tur-
bine (LPT) life. This HPT and LPT degradation . is fundamentally
blade, vane and seal replacement due to loss of life or increased
frequency of scfappage. The labor value reflects, the increased
frequency of repairing the HPT and LPT modules.
1.9. The price increments are based upon the modifications required to
incorporate the new reduced emission combustors. These modifica-
tions include new fuel injector supports, nex* fuel injectors, and
changes to the combustor itself to accommodate the new fuel in-
jectors and the new combustor and cooling airflow distributions.
In at least one instance, modifications are required to engine
cases to accommodate the new combustors are also included. The
increased prices are a result of the estimated increase in. costs
for the new and modified parts.
II. 1. P&WA has no current plan to develop a new single aerating nozzle
for the JT9D or JT8D engines. Based upon our current state of
knowledge, if such a nozzle could be developed, utilization in
JT8D and JT9D engines would require completely new fuel systems,
modified fuel controls and new fuel pumps. The net result of
these changes would probably be more costly than the current dual
'aerating nozzle approach being pursued.
II.2. No decision has been made in this regard. The regulations finally
promulgated by EPA, the actions of ICAO, inputs from our custom-
ers, and the pressures of competition will all play a role in de-
ciding whether to produce both controlled and uncontrolled
engines.
B-4
-------
^.twip^fcUT*^^
EASTERN AIR LINES INCORPORATED / INTERNATIONAL. AIRPORT / MIAMI, FLORIDA 33148 / 3O5-873-6733
Sr.
VICE PRESIDENT/OPERATIONS SERVICES
June 26, 1978
Mr. Charles L. Gray, Acting Director
Emission Control Technology Division
United States Environmental Protection Agency
Ann Arbor, Michigan 48105
Subject: Economic Impact of Proposed Jet Engine Emission
Standards.
Reference: 1) Letter from C. L. Gray to F. Borman dated
May 31, 1978.
2) Our File No. 2PP 511/72-00-17
Dear Mr. Gray:
Attached is the information requested in your referenced
letter.
The EAL engine maintenance program is an "on condition"
program which keys engine restoration action to actual engine
condition and performance, rather than to fixed intervals of
calendar time or operating hours. The term "time between
overhaul" is not applicable to a program of this type. Hence
the information in Tables I and II is presented in terms of
mean time between combustion section repair.
We will be happy to supply any additional information
you require.
Sincerely
JMS/JEW/mf
Encl.
B-5
-------
B-6
TABLE I — COST OF REPAIR OF COMBUSTION SECTION COMPONENTS.
(Mean Time Between Repair Shown in Table II)
COMBUSTION SECTION COMPONENT
Combustion Liners & Dome
Fuel Nozzle Tips & Support
Fuel Manifold
Fuel Sectoring Control Hardware
Transition Duct
>
Transition Duct Guides
JT8D ENGINE
$l,700/Eng.
$l,000/Eng.
$ 140/Eng.
Not Applicable
$ 650/Eng.
$ 100/Eng.
RB211 ENGINE
$7,300/Eng.
$ 280/Eng.
$ 280/Eng.
Not Applicable
Not Applicable
Not Applicable
TABLE II
MAINTENANCE COST INFORMATION.
ITEM
Mean Time Between Combustion
Section Repair (Hrs.)
Mean Time Between Combustion
Section Repair (Mos.)
Maintenance Costs (1978 $'s)
Man-Hours Required For
Engine Change
JT8D ENGINE
Approximately
4800 Fit. Hrs.
Approximately
18 Mos.
$28/Flt. Hr.
727 = 30 Man-Hrs.
DC9 = 23 Man-Hrs.
RB211 ENGINE
Approximately
1400 Fit. Hrs.
Approximately
6 Mos.
$80/Flt. Hr.
64 Man-Hours
-------
DELTA AIR LINES, INC.
GENERAL OFFICES/HAHTSFIELO ATLANTA INTERNATIONAL AIRPORT/ATLANTA. GEORGIA 3O32O U.
July 5, 1978
Mr. Charles L. Gray
Acting Director
Emission Control Technology Division
U.S. Environment Protection Agency
Ann Arbor, Michigan 48105
Dear Mr. Gray,
Thank you for your letter of May 31, 1978 to our Mr. W.T. Beebe concerning
EPA's continuing effort to accurately define the economic impact of proposed
revisions in the aircraft jet engine exhaust emission standards. Attach-
ment's I and II contain the information you requested relative to Delta's
recent jet engine maintenance experience.
This data, together with data from other operators and the engine manufac-
turers should assist you in your attempt to define the impact on maintenance
costs, which, incidentally, we noted were not included in the analyses
covered by your report No's AC 77-02 & AC 78-01. Inasmuch as maintenance
costs are a significant portion of our total operating expenses, we strongly
feel that any meaningful impact analysis must include maintenance cost
considerations, both installation and repair costs as well as - and probably
more significantly - lost revenue due to schedule disruptions.
If there is any other information we can provide that will assist you in this
effort, please advise.
Sincerely,
D.C. Garrett, Jr.
President
DCG/mn
B-7
-------
B-8
ATTACHMENT I
July 5, 1978
ENCLOSURE I INFORMATION
Total cost to repair the following items in 1978 dollars include parts
and labor for all engines in our operation. >•
1. Combustion liners and dome
a. JT8D-7 =$3,774.00 average per engine
b. JT8D-15 =$3,906.00 average per engine
c. JT3D =$5,244.00 average per engine
d. RB211 =$7,295.00 average per engine
2. Fuel Nozzle and Support
a. JT8D-7 =$1,125.00 average per engine
b. JT8D-15 =$1,097.00 average per engine
c. JT3D =$1,175.00 average per engine
d. RB211 =$490.00 average per engine
3. Fuel Manifold
a. JT8D-7 =$350.00 average per engine
.b. JT8D-15 =$300.00 average per engine
c. JT3D =$916.00 average per engine
d. RB211 =$740.00 average per engine
Transition Duct
a. JT8D-7 =$795.00 average per engine
b. JT8D-15 =$522.00 average per engine
c. JT3D =$1,126.00 average per engine
d. N/A
5. Transition Duct Guides
a. JT8D-7 =$208.00 average per engine
b. JT8D-15 =$208.00 average per engine
c. JT3D - N/A
d. RB211 - N/A
-------
B-9
ATTACHMENT II
July 5, 1978
ENCLOSURE II INFORMATION
What is the mean times between overhaul?
We do not have a hard time overhaul. All engines are scheduled off
at specific intervals for inspection and maintenance except the RB211
which is on an on condition/condition monitoring program. The present
scheduled intervals are:
| JT8D-7 - 4200 hours
JT8D-15 - 6200 hours
JT3D - 6000 hours
2. What is the mean of calendar intervals between overhaul?
The mean of calendar time between scheduled shop visits are:
JT8D-7 - 20 months
JT8D-15 - 25 months
JT3D - 32 months
RB211 - N/A
3. What is the mean shop cost for engine maintenance in 1978 dollars?
JT8D-7 and -15 - $16.38 per engine hour
JT3D - $29.01 per engine hour
RB211 - $69.64 per engine hour
4. What is the mean number of man hours necessary to remove and reinstall
an engine on an aircraft?
JT8D-7 = 20 man hours
JT8D-15 = 20 man hours
JT3D = 47 man hours
RB211 = #1 and 3 positions = 51 manhours
#2 position - 70 manhours
-------
AmericanAirlines
July 20, 1978
United States Environmental Protection Agency
Office of Air and Waste Management
Ann Arbor, MI 48105
Attention: Mr. Charles L. Gray, Acting Director
Emission Control Technology Division
Reference: Your Letter to Mr. A. V. Casey dated May 31, 1978
Dear Mr. Gray:
In response to your letter, we are attaching the specific
information regarding engine maintenance. We have provided
this in tabular form as Enclosures I and II, as outlined in
your request. The information is for the JT8, CF6 and JT9
family of engines and the question numbers and individual
items directly reflect those contained in your letter.
American Airlines operates the JT8D-l,-7,-9, CF6-6D and JT9D-
3A,-7AH models of engines > and the data are the actual ex-
perience for the first five months of 1978. We also operate
the JT3D model, but no information is provided for it as its
operation will not extend into 1985 and will, therefore, hot
be affected by the hew exhaust emission standards.
We appreciate your efforts to accurately define the economic
impact of the proposed revisions to exhaust emission stan-
dards. We are concerned, however, about those costs which
cannot be determined at this stage, but will have adverse
effect on future airline operations. We refer to the long-
range aspects of operating revised designs and the increased
costs to the airlines of coping with added operating prob-
lems. The JT8 reduced smoke burner conversion is an excel-
lent example. The problems of off-idle stall and the 1500-
2000 hour loss in engine hot section life were not forecast,
but related costs continue to impact us. In addition, the
actual material costs for that conversion were 25% higher
than estimated and we believe the manufacturer who provided
the estimate, and not the airlines, should absorb that dif-
ference. W,e trust your economic impact study will include
some factor for optimistic estimates.
If you feel you require further information, please contact
us.
Very truly M?urs ,
-4.
Lloi$d-ones
Senior Vice ^resident
Operations
-------
B-ll
File: 10-9/J6
ENCLOSURE I
Retrofit Cost Information Note 1
Combustion Liner & Dome
JT8
$1917
CFG
$11410
JT9
$9740 Note 2
Fuel Nozzle & Support
$1031
$1576
$3700
Fuel Manifold
$ 53
$ 638
-0-
Fuel Sectoring Control
Hardware (CF6)
Note 3
Transition Duct (JT8)
$ 742
X
Transition Duct Guides (JT8) $ 31
X
NOTES
1 - Costs are actual direct maintenance cost per engine for
first five months of 1978. Repair cost includes labor,
material, and outside service. New material cost for
replacement is also included in total.
2 - American Airlines has no repair experience on TN combus-
tion liner for JT9. Cost provided represents best esti-
mate of production and staff personnel.
3 - American Airlines has no meaningful basis on which to
estimate routine maintenance costs for the components
required in what General Electric refers to as "sector
burning". It is a concept being developed for the CF6 to
meet the proposed standards for CO and HC. Testing to
date has used laboratory components and the results,
along with schematic line drawings, have been discussed
with various airline engineers. Production components
have yet to be designed and cost estimates at this stage
could be wrong by several orders of magnitude.
-------
•• • •--'- >-»-•- -• • .-^*J.'..l
B-12
File: 10-9/J6
ENCLOSURE II
Maintenance Cost Information
Question
1
2
3
4
JT8
CF6
JT9
3645 Hours 2726 Hours 1856 Hours
16.7 Months 10.9 Months 8.25 Months
$80389
35 M/Hrs,
$201526
50 M/Hrs
$271200
50 M/Hrs,
All figures represent actual experience of cost and utiliza-
tion for the first five months of 1978.
-------
B-13
v
TRANS WORLD AIRLINES, INC
P. O. BOX 20126
KANSAS C/rr INTERNATIONAL AIRPORT
KANSAS C/ry, MISSOURI, U.S.A. 64195
July 31, 1978
Mr. Charles L. Gray
Acting Director-
Emission Control Technology Division
United States Environmental Protection Agency
Ann Arbor, Michigan 48105
Subj: Aircraft Engine Exhaust Emission Control
Ref: Letter, Charles L. Gray to Charles C. Tillinghast,
dated May 31, 1978
Dear Mr. Gray:
Attached, in accordance with your request, is data relative to
the maintenance of the various aircraft engine types operated
by TWA.
I hope this data satisfies your requirements. Please let me
know if I can be of further assistance.
yours.
. Pearson
Vice President-
Technical Services
Attachments
-------
B-14
TWA ENGINE MAINTENANCE DATA FOR
EPA EXHAUST EMISSION CONTROL ANALYSES
Reference: Letter, Charles L. Gray to Charles C. Tillinghast,
dated May 31, 1978
The attached Table 1 contains the repair costs for specific components of TWA
engines as requested by Enclosure I of the reference EPA request. The costs
in Table 1 are based on direct labor, at the current mechanic rate of $10.28
per hour, and direct material. It was assumed that direct costs would be of
most value to the EPA in their analyses. The other labor rates commonly used
by TWA for various purposes are $18.30 per hour (direct labor plus employee
fringe benefits) used for purposes such as make or buy studies, and $25.10 per
hour (all costs including overhead) used for evaluating capital projects.
The descriptions of the items provided in Enclosure I of the EPA request were
general without reference to the specific parts that were to be included in
the cost calculations. Therefore, the nomenclature of the parts that were in-
cluded in the TWA cost calculations for Table 1 are listed in Table 2.
Table 3 answers the questions contained in Enclosure II of the EPA request.
The moan shop costs for engine repairs arc Hiroch costs only. TWA does not.
routinely "overhaul" any of its engine types so the mean time between repairs
is provided in answer to question number one of Enclosure II.
Care should be exercised when comparing or consolidating TWA cost data with
that submitted by other airlines or engine manufacturers. Cost accounting
procedures and engineering, quality control, and shop practices may vary sig-
nificantly from company to company. Cost estimates, therefore, may vary
accordingly in the absence of a common basis for computation. In particular,
it may be misleading to compute incremental repair costs for incorporating
low emission hardware by comparing pre-modi fication repair costs provided by l:
airlines with post-modification costs provided by the engine manufacturers.
0. W. Johnson
Maintenance Systems Planning
July 19, 197H
-------
Item &
Combustion Liners
and Dome
Fuel Nozzle Tip
and Support
Fuel Manifold
Transition • .
Duct/Guides
JT3D-3B
Labor
Material
Total
Labor
Material
Total
Labor
Material
Total
Labor
Material
Total
S
S
$
S
S
1
SI
$
S
565
170
735
123
-
123
419
.135
,554
.
-
-
.40
.25
.65
.36
.36
.42
.08
.16
JT8D-7 &
$
$
$
S
S
S
SI
SI
408.
236.
644.
277.
12.
289.
313.
-
313.
,245.
469.
,714.
-9
12
54
66
56
35
91
54
54
93
03
96
JT9D-7AH
$
5
S5
$
1
SI
S
$
$
$
175
,511
,686
515
.365
,830
318
-
318
-
-
.30
.40
.70
.03
.20
.23
.63
.68
RB211-22B
$178.89
276.43
$455.30
$ 99.72
-
S 99.72
$182.98
15-. 53
S337.51
S -
-
S -
\j Includes direct labor (at rale of S10.23 per hour) and ir,a:erial.
y See Table 2 for breakdown of components included in the calculation
of the costs to repair these items.
w
Table 1.
-------
I
3*
Ite~ as Listed
in Enclosure I
cr i3A Letter
Ccir.bustion
lir.ers and
F'je'i nozzle
ar.d suoport
tip
Components by Nomenclature Included In Item to Arrive at Repair Costs Given 1r Table 1
JT3D-3B
Combustion chamber
assemblies.
Clamp.
Fuel nozzle.
JTSD-7 & -9
Burner cans.
Burner can guides.
JT9D-7AH
RB211-22B
Outer burner can.
Inner burner can.
Guide plates.
i Guide assembly.
Fuel nozzle and
support assembly.
Fuel norzle
assembly..
Front cc".bustion
liner.
Rear ir.rer combus-
tion Iv'er.
Rear oj'er combus-
tion l-'-er.
Fuel nozzle and
support assembly.
Fuel s: •"?.'/ nozzles.
Fuel manifold
Fuel manifold,
Fuel manifolds(left).
Fuel manifolds
(right).
Fuel inlet manifolds
(left)
Fuel inlet manifolds
(right).
Fuel
Fuel
manifolds.
tubes.
Fuel r?.-Jfold(left).
Fuel marifold(right)
Fuel rr;2'---fold.
iransition
duct/guides.
Transition
Transition
guides.
ducts.
duct
Table 2.
-------
Mean time —
between repairs
(flying hours)
JT3D-3B
3,685
JTSD-7 JT8D-7
(DC-9 (727-100
Aircraft) Aircraft)
1,479
2,729
JT8D-9
2,444
JT9D-7AH
1/3S
RB211-22B
1,115
I
f—'
^J
Mean calendar
interval be-
tween repairs
(days)
21
Mean shop —
reoair cost
Mean number —
of manhours to
remove and
install
engine
409
$86,462
48
247
30
390
$64,737
36
306
36
120
$133.6c~
75
112
'
51
V This is the mean time between shop visits for scheduled or unscheduled repairs, .'tone o'
TWA's engines are routinely "overhauled".
2f Includes direct labor and material and outside repair costs.
3/ Includes approximately five manhours inspection time on JT3D and JT8D engines, and ten
manhours inspection time on JT9D and RB211 engines.
4/ Includes $25,366 per repair recovered from manufacturer while engine under w2r--anty.
*
Table 3.
-------
B-18
PRATT & WHITNEY AIRCRAFT GROUP
Commercial Products Division
East Hartford, Connecticut 06108
February 28* 1979
Mr. Charles L. Gray, Jr.
Director
Emission Control Technology Division
United States Environmental Protection Agency
Ann Arbor, Michigan 48105
Dear Mr. Gray,
This letter transmits the completion of our reply to your letter of
December 8, 1978 in which you requested additional information
relative to the proposed aircraft engine exhaust emission standards.
Our initial response on December 21, 1978 answered the inquiries of
your Enclosures IV and V. Enclosed with this letter are responses for
Enclosures I, II and III. The information presented represents our
best estimates of costs in accordance with your requested breakdown.
These estimates assume our reduced emission combustor programs will be
successfully completed without major problems and that the proposed
regulations will be modified before final promulgation to accommodate
these combustors.
You stated in your letter that the data solicited " is necessary
for the preparation of a complete and meaningful' cost effectiveness
analysis." In furtherance of that purpose, we enclose for your consid-
eration, and by copy submit for the docket, EPA's report on "Control
Techniques for Carbon Monoxide Emissions", dated December, 1978. As
shown in Table 2-4, the CO emissions estimated by EPA from commercial
aircraft in 1977 totalled less than 2/10 of 12 of CO emissions from
all transportation sources. We conclude that control of the commercial
aircraft source is not cost effective.
-------
B-19
-2- February 28, 1979
We have not generated any new estimates related to the proposed 1984
NOX and the newly certified engine requirements nor do we expect to
generate such estimates. As stated in my July 11, 1978 letter to Mr.
George Kittredge and in our comments both verbal and written to the
NPRM, neither the need nor the technology exists for the proposed 1984
regulations. It ia therefore not possible to estimate the costs
associated with these proposals.
Very truly yours,
Gordon A/. Tit comb
Executive Vice President
cc: Mr. George Kittredge
Senior Technical Advisor
Office of Mobile Source Air Pollution Control
Environmental Protection Agency
Waterside Mall, Washington, D.C. 20460
Res Docket #OMSAPC-78-l
Control of Air Pollution from Aircraft and Aircraft Engines
Enclosures
-------
B-20
ENCLOSURE I
MANUFACTURER'S COST AND PRICE INFORMATION
The cost and price estimates for Enclosure I are based on the fol-
lowing assumptions:
o Only costs incurred as a consequence of the proposed gaseous
emission standards are included in the cost estimates.
o Development program estimated costs include both development
and certification costs but exclude service evaluation costs
which are provided separately.
o Contract and non-specific engine related technology research
and development work is excluded.
o Our reduced emissions combustor programs will be successfully
completed without major problems and that the proposed
regulations will be modified before final promulgation to
accommodate these combustors.
-------
ADVANCED DEVELOPMENT COSTS
1978 DOLLARS (in $1000)
Estimate of Costs to Address Proposed 1981 EPA Emissions Regulation
JT8D
JT9D
JT10D
NOTES:
Design &
Analysis
$1,200
3,900
2,000
General(1)
Engine
Hardware
$2,700
2,400
1,100
Specific(2)
Modification
Hardware
$2,500
6,100
500
Rig
Tests
$2,700
800
800
General(3)
Engine
Tests
$3,100
7,000
Engine (4)
Emission
Tests
$6,800
7,300
700
Flight
Test
$1,700
1,700
1,600
General (5)
Engineering
Support
$5,600
8,300
1,100
Total
$26,300
37,500
7,800
w
NJ
h—
(1) Costs of engine hardware required to support engine test programs except burner or controls related
hardware which affects emissions.
(2) Coats of all burner or controls related engine hardware which affects emissions whether utilized in
engines or rigs.
(3) Costs of all engine endurance tests specific to emissions.
(4) Costs of all emissions and performance testing.
(5) All costs not included in other categories.
-------
CERTIFICATION COSTS
(in $1000)
Generic Specific
Inline Engine Modification Endurance
Kodel lldrdware Hardware Test
150 Hour
rtlllca-
tlon Teat
Hoc and
Cold Start-
ing Test
Overteoperature
Test and L.P.
Turbine Over-
Speed Test
LCF
Te»t
Foreign
Object
Ingestloa
Flight
Tesi
Total
Cost
These costs are included in Advanced Development
Cost estimates. A precise breakout is not
possible. However, we expect that certification
costs will be not more than 25 percent of total
estimated development costs.
Cd
I
to
NJ
-------
INITIAL PRODUCTION
Increment in Manufacturing Cost
Generic Engine Model Part Name Tool Design Tool Procurement Based on Current Part^
THIS INFORMATION IS PROPRIETARY
w
N>
OJ
^Increment should account for increase or decrease in material, labor, machining, and corporate profit.
No amortization of development, certification, or other non-recurring expenses should be included.
-------
B-24
SERVICE EVALUATION
ESTIMATE OF COSTS TO ADDRESS PROPOSED 1981 EMISSIONS REGULATIONS
1978 dollars (in $1000)
Generic P&WA*
Engine Model Cost
JT8D 1,100
JT9D 2,100
Estimated
Airline Operator Total Total Time
Cost Cost Required
100 1,200 2 Years
100 2,200 2 Years
*During the service evaluation program time period, burner development
continues. The costs associated with this development have been
included in the table of Advanced Development Costs.
-------
B-25
NEW ENGINE PRICE INCREMENT
ESTIMATE OF COSTS TO ADDRESS PROPOSED 1981 EMISSIONS REGULATIONS
1978 dollars (in $1000)
Generic
Engine Model Price Increment
THIS INFORMATION IS PROPRIETARY
-------
B-26
SERVICE EVALUATION
I. Description of Hardware Changes and Programs
A. JT9D Engine Family
1. For the 1981 Emissions Combustor in the JT9D-7 series en-
gine,, current plans call for six (6) combustor/fuel nozzle
sets to be supplied to six (6) different operators. In
addition to one new inner combustor liner, one new outer
combustor liner, and twenty (20) new fuel nozzles and sup-
port assemblies per engine, a reoperation to the D-7
series diffuser case is required as follows: a) the fuel
nozzle mount pad will require a cutback to allow installa-
tion of the increased length fuel nozzle supports; b) the
inner wall of the diffuser case will require installation
of seven (7) grommets to locate mount pins and ensure pro-
per combustor positioning; c) two (2) borescope bosses
will require modification to become igniter bosses for the
new configuration.
2. For the 1981 Emissions Combustor in the JT9D-59A/-70A
series engine, current plans call for six (6) sets of cora-
bustors and fuel nozzles and supports to be supplied to
three (3) operators. One inner combustor liner and one
outer combustor liner and the twenty (20) fuel nozzle and
support assemblies per engine will be a direct replacement
of the current configuration with no required modification.
B. JT8D Engine Family
1. For the reduced HC and CO combustor in the JT8D-1, 7, 9,
series engine, current plans call for ten (10) sets of
JT8D-9 reduced emissions combustors, ten (10) sets of lou-
ver cooled outer transition ducts, ten (10) sets of split
combustor rear support guides and ten (10) sets of fuel
nozzles and supports.
2. For the reduced HC and CO combustors in the JT8D-15, 17
series engine, the planned program is the same as that for
the JT8D-1, 7, 9 series engine except JT8D-15, 17 combus-
tors will be used and no change of outer transition ducts
is required.
-------
B-27
II. Expected Schedule of Events
Item 1
Airline operators considered for participation will be selected.
Item 2
An Engineering Change (EC) which authorizes the use of evaluation
parts and describes any reoperation requirements will be prepared.
Based upon the information contained in the EC, a Special Instruc-
tion document for use by the operators will be prepared.
Item 3
Pratt & Whitney Aircraft will offer the operators the opportunity
to participate in the Service Evaluation Program by letter. The
Special Instruction will be attached to the letter.
Item 4
The participating airline operators will transform the Pratt &
Whitney Aircrsft supplied Special Instruction into an instruction
sheet suitable for use in their overhaul shop.
Item 5
' Upon receipt of agreement to participate, Pratt & Whitney Aircraft
will deliver the Service Evaluation parts to the airline operator.
Item 6
After the Service Evaluation parts are received, the airline
operator will dissemble the selected candidate engine, make the
necessary reoperations, install the service evaluation parts, and
reassemble the engine.
Item 7
The assembled engine will then be tested and if acceptable,
installed in the next available aircraft position. At this time,
the airline operator will document the total engine time and
cycles and report this information to PWA.
-------
B-28
Item 8
During the evaluation period, the operator will provide Pratt &
Whitney Aircraft with the results of borescope and/or isotope
inspection of the evaluation parts. Inspections will be a combina-
tion of scheduled and special request inspections.
Item 9
Periodically, Pratt & Whitney Aircraft will publish the results of
the evaluation to date. This will include the engine serial number
(S/N), the time and cycles accumulated on the combustor and the
results of inspections for each airline operator.
Item 10
When an engine with a high time set of hardware is removed for any
cause, a Pratt & Whitney Aircraft specialist will travel to the
operator to review the condition of the combustors and fuel noz-
zles and resultant HPT/LPT condition.
Item 11
After conclusion of the service evaluation program, whenever the
combustors and fuel nozzles are removed during normally scheduled
engine refurbishment periods, the parts will be returned to Pratt
& Whitney Aircraft for final review and analysis. Subsequently,
the parts will either be scrapped or returned to the participating
operator.
Item 12
Pratt & Whitney Aircraft will provide each airline operator with a
letter report summarizing the evaluation program results.
-------
B-29
ENCLOSURE II
ESTIMATED JT8D/JT9D RETROFIT COST INFORMATION
1. Summary
To meet the proposed in-use engine requirements, all JT8D and JT9D
engines delivered prior to 1982, pursuant to our recommended time
schedule, will have to be retrofitted with new aerated fuel nozzles
and revised combustion chambers.
Estimated
Kit Price
Minimum Qty. of per Engine
Engine Model Parts/Engine (1978 Dollars)
JT8D-7/9 33 $40,000
JT8D-13/17 27 $37,000
JT9D-3A/7 46 $102,000
JT9D-59A/70 45 $102,000
2. Retrofit Estimates
The following are JT8D/JT9D retrofit estimates for each hardware item
together with a general description of the change and the reason for
each modification. All estimates assume that retrofits would be per-
formed during routine maintenance when the engine hot section is
exposed. All estimated labor costs are based on a labor rate of
$18.50/man-hour.
JT8D Engine
To reduce JT8D engine emissions, significant modifications to the cur-
rent production combustion system are required. The fuel nozzle and
support assemblies in all JT8D engines delivered prior to 1982 will
require replacement with aerated fuel nozzles which incorporate pres-
sure atomizing primary and aerated secondary supply passages. All JT8D
models will also be retrofitted with combustion chambers which incor-
porate a modified dome, revised cooling air distribution, and modified
combustion and dilution hole patterns in the combustor liners. The
combustion chamber liner dilution hole patterns for the JT8D-15 and
JT8D-17 engines, which have air cooled stages in their high pressure
turbine, will be different from those for the JT8D-9. In addition, the
JT8D-9 will require replacement of the outer transition duct and
rework of the transition duct guides, whereas the JT8D-15 and -17
engines will require only rework of the transition duct guides.
Table 2.1 provides a detailed breakdown of the estimated average
retrofit costs per engine.
-------
B-30
TABLE 2.1
JT8D ESTIMATED RETROFIT COST INFORMATION
(1978 Dollars)
JT8D-7/9
Estimated Retrofit Kit Cost $40,000
Estimated Modification and Installation Labor +3,400
Normal Repair Labor and Material -4,100
Cost Increment $39,300
JT8D-15/17
Estimated Retrofit Kit Cost $37,000
Estimated Modification and Installation Labor + 100
Normal Repair Labor and Material -4,100
Cost Increment . $33,000
-------
B-31
JT9D Engine
To reduce JT9D engine emissions also requires significant modifications
to the current production combustion systems.
The JT9D-7 fuel nozzle will be replaced with a dual-pipe welded
aerated nozzle similar to those discussed for the JT8D engines. Clear-
ance relief cuts in the diffuser case fuel nozzle insertion holes will
be required for each assembly. A major change will be required in the
combustor front end. A new bulkhead front end combustion liner will be
substituted for the current combustion liner, which consists of twenty
short cone front ends. The bulkhead combustion liner will require in-
creased length fuel nozzle supports and will incorporate a new hood,
revised mount pin arrangement, and new ignitor locations. To accommo-
date these changes in the JT9D-7 engine, the diffuser case will have
to be removed and reworked as follows:
a) The fuel nozzle mount pad will require a cutback to allow instal-
lation of the increased length fuel nozzle;
b) The inner wall of the diffuser case will require installation of
seven (7) grommets to locate mount pins and ensure proper burner
positioning; and
c) Two (2) borescope bosses will require modification to become igni-
ter bosses for the new configuration.
For the JT9D-59/70 engine, the major modification will be to replace
the present fuel nozzles with new aerated fuel nozzle and support as-
semblies, since the engine already incorporates a bulkhead combustion
liner. Other modifications will include redistribution of the combus-
tion and dilution air, revisions to the liner cooling air schedule,
and the addition of support pins to maintain the louver tip spacing to
maintain combustor durability. The JT9D-59/70 engine will not require
reoperatiori of the diffuser case.
Table 2.2 provides a detailed breakdown of the estimated average
retrofit costs per engine.
-------
B-32
TABLE 2.2
JT9D ESTIMATED RETROFIT COST INFORMATION
(1978 Dollars)
JT9D-3A/7
Estimated Retrofit Kit Cost $102,000
Estimated Modification and Installation Labor + 3,600
Normal Repair Labor and Material -16,700
Cost Increment $ 88,900
JT9D-59A/70
Estimated Retrofit Kit Cost $102,000
Estimated Modification and Installation Labor +100
Normal Repair Labor and Material -20,900
Cost Increment $81,200
-------
B-33
3. Estimated Tool Costs
The following are the estimated JT8D/JT9D one-time cost in 1978
dollars for rework fixtures or other tools that will be required in
the retrofit program.
Average No. of Sets
Engine Cost Per Set per Repair Facility
JT8D $5,000 One set per Maintenance Facility
JT9D None None
4. Mean Time Between Overhaul
In general JT8D/JT9D maintenance is performed based on engine condi-
tion and the intervals for scheduled engine refurbishment reflects a
particular airline's operation (average flight length, derating, en-
gine modification status, etc.).
-------
B-34
ENCLOSURE III
MAINTENANCE COST INFORMATION
We assume that production incorporation will not begin until January
1, 1982 as recommended by Pratt & Whitney Aircraft and that the
results of the service evaluation program will allow engines produced
after 1982 to have maintenance characteristics comparable to current
engines.
-------
B-35
PRATT& WHITNEY AIRCRAFT GROUP
Commercial Products Division
East Hartford, Connecticut 06108
August 25, 1978
Mr. Charles L. Gray
Acting Director
Emissions Control Technology Division
Environmental Protection Agency
Ann Arbor, Michigan 48105
Dear Mr. Gray:
In your letter of July 14, 1978, you indicated that the Pratt &
Whitney Aircraft submittal of 26 February 1976 from D. D. Pascal to
Eric 0. Stork followed the EPA recommended format by reporting the
increment in engine selling price and development costs separately.
You requested that we provide updated cost information in this same
manner which you stated has proven to be both appropriate and worth-
while.
In response to your request, the attachment to this letter
provides our latest estimates of the production engine price increases
resulting from incorporation of the new combustors currently being
developed for reduced HC and CO emissions, kit prices for retrofitting
these same combustors into in use engines and total combustor develop-
ment program costs associated with each specific engine family exclusive
of costs for technology development. It should be noted that the JT8D
prices are believed to be representative of combustors which have sub-
stantial reductions in CO but which fall short of meeting the proposed
CO emissions standard.
No cost information relative to NOx is included because EPA has not
proposed a NOx standard based on air quality/public health needs or on
available technology.
We trust this information will be useful in your study.
Sincerely,
UNITED TECHNOLOGIES CORPORATION
Pratt & Whitney Aircraft Group
Commercial Products Division
Vice President-Engineering
UNITED
TECHNOLOGIES
-------
B-36
Low Emission Burner Pricing Estimates
The pricing information given below represents estimates for
incorporation of reduced HC and CO combustors currently under
development into production engines. Because development is
not complete, this pricing information can only be considered
as "rough order of magnitude" estimates and is in no way to be
construed as forming any commitment on the part of Pratt &
Whitney Aircraft for use as a basis for the establishment or
negotiation of actual prices. It should be noted that the JT8D
prices are believed to be representative of combustors which
have substantial reductions in CO but which fall short of
meeting the proposed CO emissions standard.
Production price increment
for modified low emissions
burners w/o specific develop-
ment (average)
Retrofit kit price w/o specific
development (average)
1978 Dollars
JT8D JT9D
$ 11,300 $ 48,300
$ 34,200 $166,300
Total Development Cost
Then Year Dollars
$15,156,000 $35,827,000
-------
B-37
AIRCRAFT
GENERAL® ELECTRIC
ENGINE
GENERAL ELECTRIC COMPANY CINCINNATI, OHIO 4521E
Phone (513) 243-2000
Mail Drop H-52 243-3537
GROUP
February 19, 1979
Mr. Charles L. Gray, Acting Director
Emission Control Technology Division
U. S. Environmental Protection Agency
2565 Plymouth Road
Ann Arbor, Michigan 48105
Dear Mr. Gray:
In response to your letter request, we have assembled the attached
information concerning the estimated costs of compliance by our various
commercial aircraft turbine engines with the proposed gaseous emission
standards.
The attached information is presented in the format requested in your
letter. To the extent possible, we have attempted to answer the various
questions asked in your reporting format and to provide the detailed cost
breakouts-included in the various cost element forms of this reporting format,
The attached information only includes the cost impacts associated with
the proposed carbon monoxide (CO) and hydrocarbons (HC) standards, which
are presently proposed to become effective on January 1, 1981. No infor-
mation is included concerning the cost impacts associated with th0 proposed
nitrogen oxides (NOX) standard, which is presently proposed to become ef-
fective on January 1, 1984. In our view, the feasibility and practicality
of attaining satisfactory compliance with this latter standard, while still
meeting all the other performance and durability requirements of commercial
aircraft engines, have not yet been fully demonstrated. As such, we believe
that any cost estimates we might attempt to provide at this time concerning
the design and development of an arbitrary combustor concept, not yet known
to be capable of meeting the mandatory requirements of commercial aircraft
engines, would be meaningless and possibly misleading.
The attached cost data consist of actual costs incurred during the
period of 1974 through 1978 and estimates of the remaining costs associated
with attaining compliance with the proposed CO and HC standards. Only the
actual and projected costs directly associated with the development,
Continued on Page 2
-------
B-38
GENERAL©ELECTRIC
Mr. Charles L. Gray
February 19, 1979
Page 2
demonstration and production of CO and HC abatement features for use in the
specific engine families noted in the attachments are shown. Thus, the costs
associated with various generalized emission control technology programs we
have conducted during the past several years are not included in the attached
cost tabulations.
As is indicated in Enclosure I of the attached material, a new CF6 family,
the CF6-80, has been recently added to our series of CF6 engines. Efforts
are currently underway to define and develop suitable features for use in
this new engine family to permit compliance with the proposed CO and HC
standards. For this new engine family, CO and HC abatement features different
from those evolved to date for the CF6-6 and CF6-50 engine families are
being developed. The intent of these CF6-80 engine development efforts is
to evolve a combination of CO and HC abatement features which do not in-
clude the use of sector burning at idle. Thus, this latest CF6 engine emis-
sion abatement program is expected to involve a significant effort and an
additional total development cost similar in magnitude to that associated
with the CF6-50 engine family—as is noted in Page 1 of Enclosure I.
I trust the attached information will be useful to you in the studies
you are conducting to assess the economic impacts of the proposed gaseous
emission standards applicable to commercial aircraft turbine engines. If
you have any questions or comments on this information, please do not hesi-
tate to contact me.
•
Very truly yours,
D. W. Bahr, Manager
Combustion and
Emission Control
DWB/cr
Attachments
-------
ENCLOSURE I - PAGE 1
ADVANCED DEVELOPMENT COSTS"
(In 1978 Dollars)
To Meet Proposed 1981 Standards For CO & HC Emissions
Generic
Engine
Model
CF6-6 1
CF6-32 }
CF6-50 |
CF6-45 '
CF6-80
CFM56
CF34
Design and ' ,,
General General Specific « - . General
Laboratory Engine Modification Rig Engine Emission Special Engineering
Effort Hardware Hardware Tests Tests Testing Tests Support Total Cost
(See (See (See
Note A) Note B) ' Note C)
$1,750 K $110 K $ 470 K $ 790 K $1,680 K $220 K $110 K - $5,130 K
1,660 K 220 K 1,210 K • 1,280 K 2,240 K 670 K 90 K - . 7,370 K
(Detailed Cost Estimates Not Available At This Tine - Total Cost Is Expected To Be Approximately The
Same As Total Cost Associated With CF6-50/CF6-45 Engine Family)
1,110 K 670 K 450 K • 620 K 560 K 450 K - -' 3,860 K
(Detailed Cost Estimates Not Available At This Time)
w
I
NOTES:
(A) Includes extensive cyclic endurance testing to verify acceptability of using sector burning at idle.
(B) .Includes special flight tests of engines to determine altitude starting performance capabilities.
(C) Includes actual costs incurred during 1974 through 1978 and projected costs for 1979 and 1980.
Development should not include product improvement.
If applicable, include number of engines dedicated.
Breakdown -into general tasks, e.g., cold and hot starting test,
coking and temperature distribution test, and low cycle fatigue test, as appropriate.
-------
ENCLOSURE I - PAGE 2
cr.crlc
n£ir.e
c-Jel
F6-6
F6-32
F6-50
F6-45
F6-80
FM56
ESTIMATED CERTIFICATION COSTS
. (In 1978 Dollars)
To Meet Proposed 198] Standards For CO & HC Emissions
Ovtrtenporacure
Specific 150 Hour Hot ond Test and I..P. • Foreign
Modification Endurance- Certifica- Cold St-irt- Turbine Over- I.C7 Object
ydunre ii.irdvare Test tion Tost ing Test Speed Test Test
Total.
'import Test Cost
(See Note A)
$600 K '
"*" (See Note B)
•$600 K
(See Note B)
$150 K
(See Note C) w
$150 K
(See Note C)
i
o
$150 K
(See Note C)
\) Because the details of the certification testing required to demonstrate compliance with gaseous emission
standards have not yet been specified, detailed cost estimates cannot be provided.
J) Approximate estimate of total cost of special engine tests conducted.to demonstrate compliance with
proposed CO and HC standards--assuming testing of only a single engine is required for this purpose..
:) Approximate estimate of total cost of special engine tests conducted to demonstrate.compliance with
proposed CO and HC standards--assuming testing is conducted in conjunction with the initial type-
certification testing of these engines. The target schedules for the completion of these initial type-
certification tests are:
CF6-80 1981
CFM56 1980
CF34 1981
-------
ENCLOSURE I - PAGE 3
ESTIMATED INITIAL PRODUCTION COSTS
(In T97R Dollars)
- To Meet Proposed 1981 Standards For CO & HC Emissions
Generic
CF6-6 ]
CF6-32 j
CF6-50 )
CF8-45 J
rrfi-sn
•
Engine Model Part Kama
• Fuel Splitter
Valve
« Misc. Piping/
Valving
• Fuel Splitter
Val v-s
• Misc. Piping/
Valving
Tool Design Tool Procurement
- .,, . 'Kl'in K (See Note A^
* « 1 g If to-
r> 'fil'iO K (lr>f> Nnt-ir» Rx
i« Ti 1 5 K to
incremenc in Manuraccuring.i
Based on Current Part
(Not Applicable)
(Not Applicable)
(Not Applicable)
(Not Applicable)
CFM56
CFG 4
Combustor Dome
$10K $25 K
— (To Be Determined)
$5 K
w
NOTES:
(A) 50% Cost Sharing With CF6-50/CF6-45 Program.
(B) 50% Cost Sharing With CF6-6/CF6-32 Program.
Increment should account for increase or decrease in material, labor, machining, and corporate profit.
. No amortization of development:, certification, or other non-recurring expenses should'be included.
-------
B-42
ENCLOSURE I - PAGE 4
ESTIMATED SERVICE EVALUATION1 COSTS
(In 1978 Dollars)
To Meet Proposed 1981 Standards For CO & HC Emissions
Generic
Engine
Model Total Cost Total Time Required
CF6-6 $276.0 K. 12 Months
(See Note A) .
CF6-50 $284.0 K 12 Months
(See Note A)
CF6-32
CF6-~80 (Not Applicable)
CFM56
CF34
NOTES:
(A) Program involves service evaluation testing of 5 engines. The above
cost total includes the procurement/fabrication of six engines sets
of emission abatement hardware, with one set intended as a spare.
All costs associated with engine removal from the aircraft, modifi-
cation/rework, ground checkout, reinstallation on the aircraft and
inspection are borne by General Electric. However, some of these
latter operations are performed by the air carriers which operate
the 5 engines.
1 tKvscriptlon of t.yplc.i.l si-ivK-o cvalu.i t:ioii, i.f., whnt
! t it i,-: r«- r ,.-:...- .-.- - •• ~ ' - • • ' '..- •
-------
B-43
ENCLOSURE I - PAGE 5
ESTIMATED NEW ENGINE PRICE INCREMENT
(In 1978 Dollars)
To Meet Proposed 1981 Standards For CO & HC Emissions
Generic
Engine Model . Price Increment
CF6~6 J $24.0 K
CF6-32
CF6-50 $25.5 K
CF6-45 J
CF6-80 ; (To Be Determined)
CFM56 $ 510 K
CF34 - (To Be Determined)
1
no not include amortization of non-recurrj.n" costs.
-------
B-44
ENCLOSURE II - PAGE 1
ESTIMATED RETROFIT COST INFORMATION
(In 1978 Dollars)
To Meet Proposed 1981 Standards For CO & HC Emissions
Cost (To Air Carrier)
• Added Hardware (See Note A)
• Engine Fuel Nozzle Rework (16
Out of Each Engine Set of 30)
• Engine Main Fuel Control Rework
• Engine Modification/Asseihbly
With New Hardware & Reworked
Control--If Performed As A
Part Of Routine Engine Mainten-
ance Operations.
• Average Depreciated Cost of
Fuel Nozzle Hardware That Must
Be Replaced, Less Salvage Value
of Hardware.
TOTAL COST PER ENGINE
Engine Family
CF6-6/
CF6-32
$27.6 K
6.1 K
3.5 K
2.0 K
2.8 K
$52.0 K
CF6-50/
CF6-45
$52.6 K
3.5 K
2.0 K
9.0 K
$67.1 K
NOTES: (See Page 2)
-------
B-45
ENCLOSURE II - PAGE 2
ESTIMATED RETROFIT COST INFORMATION
NOTES:
A) For the most part, the selected CF6 engine emission abatement
features require that replacement of existing fuel nozzle hardware
and the addition of new hardware. The costs of these required hardware
i terns are:
Hardware Item Quantity Required
1) Replacement Hardware
- Fuel Nozzles 30 (CF6-50)
- Fuel Nozzles 14 (CFG-6)
2) New Hardware
Fuel Nozzle Check Valves 15
Splitter Valve 1
Enrichment Valve 1
Starter Valve 1
Electric Cable 1
Pylon Fireseal 1
Tubes & Manifold Assembly 1 Set
Misc. Plumbing Hardware 1 Set
Misc. Brackets 1 Set
B) The following comments are in response to the question on the mean
time between-overhaul (TBO) of the CF6 engine models:
As maintenance work is done "on condition" and as the
engine shop work is done on modules, "mean TBO" is
not a meaningful parameter. Shop visit rate (number
of shop visits per 1000 flight hours based on a
three-month rolling average) is a much more useful
and meaningful measurement. The shop visit rate of
the CF6 engine models was running at 0.36 during mid-
1978. The range was 0.24 to 0.59. This average shop
visit rate of 0.36 equates to a mean of 2780 flight
hours between removals resulting in shop maintenance.
-------
B-46
ENCLOSURE III - PAGE 1
MAINTENANCE COST INFORMATION
Pertinent To Meeting Proposed 1981 Standards for CO & HC Emissions
Part I
The impacts of the selected CO/HC emission abatement features (sector burning
at idle and fuel nozzle modifications) on the maintenance costs of the CFG
engine models cannot be estimated at this time - as the effects on engine
life of the differential heating and cooling associated with the use of
sector burning cannot be fully evaluated at present. The planned service
evaluation tests are expected to provide the information needed for such
assessments. In any case, overhaul of the required additional fuel control
hardware will be a maintenance cost adder. Specifically, the flow splitter
valve will require a test bench that has been quoted at $300,000 by a pro-
posed supplier. However, airline operators may be able to adapt existing
facilities (at some expense) to provide the necessary test bench if they
desire to overhaul the valve.
Part II
1. Main Time Between Overhauls: See Note B of Enclosure II.
2. Mean Calendar Interval Between Overahuls: The average CF6 engine is
currently operated 9.9 hours per day. Therefore, the mean time between
shop visits is approximately 280 days (based upon the mean of 2750 flight
hours between removals resulting in shop maintenance).
3. Mean Shop Cost For Engine Maintenance: The average cost is approximately
$224,000 (labor, material and outside services) per shop visit.
4. Mean Number Of Man-hours Necessary To Remove And Reinstall A CF6 Engine
On The Aircraft: 35-40 man-hours for wing-tail engines, respectively.
5. Increase In Repair Labor Required For Low NOX Staged Combustor, Compared
To Conventional Combustor: Cannot be estimated at this time.
6. Mean Incremental Cost Per Shop Visit That May Be Expected Because Of
Sector Burning Control Hardware: Cannot be estimated at this time.
-------
B-47
ROLLS-ROYCE LIMITED
FILE COPY
/\Lf vO bP./JolON
ABW 3/KN
P.O. Box 31. DERBY DE2 8BJ
Telegrams: 'Roycar. Derby' Telex: 37645
Telephone: Derby (0332) 42/,24 Ext. H06
31 Janxiary 1979
Dr R Hunt
.Environmental Protection Agency
Office of Air and Waste Management
2565 Plymouth Road
Ann Arbor
Michigan 48105
USA
Dear Dick
It was good to talk to you on the telephone on 23 January and to know
that you had received both the cost data which was dispatched from
Derby while I was on vacation and the material which we presented to
George Kittredge on 6 December last.
I can confirm that while the average level of RB211-524 and RB211-22B
emissions will, on the basis of our present data, lie below the proposed
EPA standards of 36.1 g/kN for CO and 6.7 g/kN for HC (without sector
burning at 1% idle thrust) , this cannot be achieved by the RB211-535.
The -535 values are still about twice the proposed standard demonstrating
the very significant influence of rated pressure ratio on the operating
conditions at idle (all other parameters like combustor volume remaining
unchanged). You will, of course, appreciate that "on average" implies
that there are no margins available for variability so that our considered
opinion would be that the standards as currently proposed represent the
base technology level now available for the high pressure ratio large
fan engines. They do not, therefore, take account of lower pressure
ratio derivatives nor do they take account of the known engine emissions
variability (since EPA has never had sufficient data of this type on
which to base any rational judgements).
In addition, the impact of the size of the sample of engines available
for emissions certification of a new engine type on the safety margins,
that must be allowed for both the engine manufacturers and the
certification authority, has never been assessed.
Thus, Rolls-Royce would recommend that the base technology levels as
represented by the present CO and HC standards be made a function of
engine rated pressure ratio (refer to charts CVG 3715, CVG 3716 from
the 6 December, 1978 presentation - attached here for convenience) and
should further be raised to take account of the knan variability and
the need for certification margins.
-------
B-48 _ 2 -
You asked whether Rolls-Royce could suggest what values night be
adopted for the standards. I, therefore, instructed some further
work aimed at identifying a possible regulatory position (bearing in
mind the ICAO position which is also currently under review as you
know) which is summarised for CO and HC on the attached charts
CVG- 6117, CVG 6118.
The charts show the current EPA standard set at a pressure ratio of
27.5 (approximate average of the three large fan engines) through
which a curve is drawn based on the ICAO emissions output/Pressure
ratio relationships. This then purports to represent the available
level of technology. You will note that the RB211 data points (a ifo
idle has been assumed) sugge3t that a true technology relationship
would be steeper than that proposed so that lower pressure ratio
engines are still slightly penalised. In both cases, an absolute
maximum would be specified regardless of pressure ratio (no consideration
has been given to these maxima so no values are recommended here).
In the following analysis it has been assumed that the objective of
the regulations is to ensure that there will be 90?£ confidence that the
mean of the population of all engines will lie below the standard.
This objective has to be reached in two stages:-
(a) The manufacturer has to meet a certification value which is set
assuming that he vrill have a 90$ chance of passing based on the
average of three engine tests and
(b) The regulation limit is set to achieve the desired compliance
confidence assuming that the manufacturer will, in fact, only
use one engine.
Thus two further curves are defined, as shown on the charts. The use of
•a' certification value above the achievable technology level takes
account of the known variability, but forces the manufacturer to produce
a population whose mean is unlikely to exceed the available technology -curve.
This curve also represents the expected level of emission output and
would normally be used to calculate the average impact.
On the other hand, if upper bound predictions of aircraft emissions
were required, it would be appropriate to use the regulation limit
(ie. 90/o confidence) as the basis for impact calculations.
The Rolls-Royce recommendation would therefore be to specify the
standards as defined by the curves labelled "Regulation Limit" for
CO and HC emissions as shown on CVG 6117/6118 respectively, but expect
the certificating authority to administer the legislation on the basis
of the certification value curve. It would, of course, be possible
to construct a certification value curve depending on the number of
engines sampled, based on the fixed regulation limit defined above,
but this is a refinement which needs to be discussed only if EPA
adopts the above philosophy. It must once again be emphasised that
the above recommendations assume a 7$ idle thrust (to achieve
equitability throughout the industry) and the choice of any other
idle thrust definition would necessitate an upward revision of the
-------
B-49
I have reviewed the coat data I supplied in my letter of 21 December 1978
and have had the advanced development costs for the RB211-22 and
RB211-524 split down to identify the separate expenditure on the "1981"
technology (CO and HC) and the "1984" technology (CO. HC and NOx).
I hope you will find this satisfactory.
It has not, however, been possible to find an uncomplicated way in
which to present the increase in the new production hardware price to
conform with your requirements. I can confirm that the prices quoted
do include a contribution associated with the non-recurring costs of
both the engineering programme and tooling since this is the way in
which we quote prices in the market place - and is consistent with
the way in which we supply data to our customers (eg. via ATA response
to the 24 March 1978NPRM).
Since in arriving at a price, different manufacturers will use different
judgements, it is our considered opinion that you will obtain a more
accurate economic impact of the regulations by using the price
differentials as we have quoted them and we should be loathe to alter
our position and accounting practices.
Yours sincerely
A B Wassell
Chief Research Engineer
(High Temperature Components)
Att:
c: G Kittredge - EPA
-------
© RiMIs noyrc Lninlr'1. II ^'"i document is Hie p>; r.eity nl Hulls Rftyce LiniilMJ jiul truy rn« lie copmti i.« CUMIMIU,
used lot .my piirpiisi-iiiiioi Ilidn (lint lur whicli >l is siipp1 C'Osswiiil'!iiaulhiviiynl Rulh, Ituyrc LutuioU.
I
I
I
_
Date ^\
ADVANCED DEVELOPMENT COSTS (31000) 29 Jan 79 }
(1972-1984)
Chart No.
CVG 7069
'
ENGINE
RB 211-22 &
-524
1981
1984
RB 211-535
SPEY.
TOTALS
DESIGN &
GENERAL
ENGINE
SUPPORT
8,982
2,410
2,607
2/020
16,019
ENGINE
PARTS
15,149
5,302
768
5,552
26,771
RIG
TESTS
12,146
3,663
1,806
1,245
18,860
ENGINE
TESTS
7,971
2,780
382
3,521
14,654
SPECIAL
TESTS
360
40
200
3,080
3,680
TOTAL
44,608
14,195
5,763
15,418
79,984
ALL IN 1978 TERMS, CONVERTED AT S2 TO £1
•~- —> •• • •— — — —
j
» B
n
I
f
1
-------
B-51
ROLLS-ROYCE LIMITED
ID)
AERO DIVISION
ABW 8/KN
FILE COPY
P.O. Box 31. DERBY DE2 8BJ
Telegrams: 'Roycar. Derby' Telex: 37645
Telephone: Derby (0332) 42424 Ext. 1406
21 December 1978
Mr Charles L Gray
Acting Director, Emission Control Technology Division
United States Environmental Protection Agency
Office of Air and Waste Management
Ann Arbor
Michigan 48105
USA
Dear
In response to your letter to Sir Kenneth Keith dated 31 May 1978
and to the commitments made to EPA by Mr Pepper in his acknowledgement
of 23 June 1978 and by myself at the Public Hearings held in
San Francisco recently, Rolls-Royce has been collating the cost
data you requested. This has proved to need a very extensive
investigation and has only just been completed.
It has not been possible to break down our engineering costs into
the precise format that you requested, but we have endeavoured to
identify equivalent categories of work. Nor are we able to supply
you with our internal production costs since these represent
proprietary information, but the price increases associated with the
new low emission hardware have been identified. We have also
attempted to quantify the costs associated with service evaluation,
supply of retrofit kits and resulting increases in maintenance costs
as well as the supplementary data requested in your letter.
Should you have any queries relating to these costs, please do not
hesitate to write to me. You will, of course, appreciate that all
the costs or prices we are supplying are only indications since, as
we have already pointed out, the severity of the regulations
themselves has yet to be defined and the combustor modifications which
we have been developing may still need further changes that could
affect both the engineering costs and the combustor configuration
(and hence production costs).
Yours sincerely
A B Wassell
Chief Research Engineer (High Temperature Components)
Att:
c:
Mr G D Kittredge
Mr D J Pepper
Mr D R Blundell "
Mr A G Gray
EPA Washington for Docket OMSAPC-78-1
Buckingham Gate
Rolls-Royce Inc
-------
flf
:.| lui Illy I n Hi;...•:.• I il!i. -I I,1, ui !'••<< V' v.l'rrh <*••»• T .--_- -vs.I'itm! If.:; i.'.|)i,-.S vlilli I, .r.I'1 . !i\, ul Hi.: 'i ".J,LC I 'I'll',
ADVANCED DEVELOPMENT COSTS $
\
(.hart No.
Cv/G
£ MCI ME
Re> 211 -22 4-
-524
RQ2II-535
SPEY
TOTALS.
O£S/CA/ 4
GEHERAL
ENGINE
SUPPORT.
11,392
2,607
2,020.
16,019
ENGINE
PARTS
20,451
76Q
5,552
2t>, 71}
Z/G
TESTS
15,809
1,806
1,245
78,860
ENGINE
TESTS
10,751
332
3,521
Ik, 654
SPECIAL
TESTS.
l>00
200
3,030
3,b&0
TOTAL.
S8,&03
MI- L)«,^-'t
lit*- i^ji^''
5,763
I5.UIB
-7S.9BU
ALL in /9?<3 T£/r/yiS,
AT $2 To //.
J
-------
B) CERTIFICATION COSTS ($/,OOo)
ih\
ROKt
1 DEC '
E«,,«S
KB 2 n - 22 8 Low En i ss io*fs (we. co)
&& 211- $24 LovS £-A-3/55/OA/5
£62J/-S3S Lavs EMISSIONS
&&2H-22S. Zoiv' A/O/c
CeMaasne
SA2K - SS£~ /Ju/ /Vc5<
COM 805 7a d
Sf£ Y 5/v/o /trtf- ^ f£S
SpeY Lauj £MISSIO*/S
^ S£C™ ^^G'
TOTAL.
SUPPORT
1 9 0^
y
/ 9 &Q
/
1,9 $°
,,93*
1,980
1,980
V"
1,111
1,111
15,213
t4AK.DvJAK.E~
f
/
7,595-
/,5SS
IS9S
1,595
(,2,Q
&3Q
"s
,,~
CERTIFICATION
TESTING.
990
330
990
99o
9 So
990
^•-69
// 6»9
UG9
•7,3^7
TOT/1 L.
4,565
^,565
A ,565
4,565
A, 565
4,565
2,2/6
2. 2 IB
2,2, Z
3^4
AT
-------
1 Re! 'loyi'Jl-'.: ".' . Ml:'. .|i>:i,:ni!l-.( IS '.III- tMCS=Ct7:al U*& ^..., .• l.,lll,|l»tj'- : " :. •>..! I'lM >ii:,i:i1 'ii cumiM'l
u'-'J loi .IMVIK.-:-?--' .•'•<•' !lm lli.ll Idl ^!i» Inl ilEllii|.'''~r«rjaBdHl :•:'. :-•, vvrillrn 3..- •• ', .-I flu'.:-.. Hovi.H Limited
fifl CERTIFICATION COSTS ($1,000)
HA
?->="!
'- •
_ , LDEC.
..--irr. M
CVS 70t
£-A/C/Ayf
RB2H-228 Law EMISSIONS (we. fa)
COM6US-T&Z •+ S£CTo.<
gam - s2v /low //iO<
CeM3dSTaf
£42/t - SSS~ LOVJ /VO<
/v7cW57b*r
Sf£ Y S/woX£ i. £SS
Cos*39
4<2>9
UG9
"7,34-7
TOTAL.
4,S6S
4,565
A ,565
4,56s
U, 565
U. 565
2,2/fi
2. 2'S
2,2/fi
34,0^4
;^
-, 4
j _ i
»2
w
I
AT
H
-------
^
Chart No.
70 £.
TOT^L COST
3, 900
7220
R8
SPey
-------
/" ,--,.
f!R?
PSLICB
X -524 Low
R& 2ll -22, - S24, - S3S
S/UOK£L£SS
iovj
-SECTOR
y DEC 76
COO
7, 000
77,000
AS 6,
8,500
56,000
Ul
*» *,,,. . /
-------
COST
R&2/I ONLV
I. MINIMUM
Of= P/MZTS:-
(rt
(b) SECTOR
2. (a) A/or
(c)
(d) A/or APf>uc/\6L£
3.
TOOLS
7230O.
OOO ->• IOO MA+4
6O.OOO
- 22 B
ZffOO
46,000
3, ooo - ~jt ooo
OS
V
-------
cl.it isMinpiiril v
«'CJ It) j fniiJ pjfiy ijt
COSTS (PAKT I)
Date
DifC 70
C/iart No.
Cl/C 7067
THE"
A/7 /»
A'Mf
4-0
Is <=3Ti/V\/<\T£.b To
Q 7* A.T.A.
2/JC. I
Gn/G
Of
IT Is
THOSE.
IfJ
7*vcy
Ay
Ln
00
-------
COST
A
TT)
7068
-22
£3211- S~24
77 M^
24 C»O
S SS^
StJof> CoST
24
VJfTH
Coo
/ ooo
SecTo/e
-------
- B-60
COMMUNICATION RECORD
Originator of Record
(Name - Organization)
// /""
/\ . J>
Communication With ~r~
(Name - Organization) /Q/Q
/ \O
f — /{
Date
Subject of Conmunication
Communication Summary
IWj #62f/
SMI//? faf east
o'fil-
-t
a
-------
COMMUNICATION RECORD
Originator of Record
Communication Kith
Subject of Communication
. Communication Summary
C£>s.f-
^>> 7
HJistribution
B-61
-------
B-62
-------
B-63
November 9, 1978
Aerospace
U.S. Environmental Protection Agency
Ann Arbor, Michigan 48105
Attention: Mr. Richard S. Wilcox
Parker Hannifin Corporation
Gas Turbine Fuel Systems Division
17325 Euclid Avenue
Cleveland. OH 44112 USA
Phone (216) 531-3000
Telex 98-0636
Dear Mr. Wilcox,
Attached is your completed questionaire for fuel nozzle costs in
lower emission gas turbine engines. These estimates are based
on projected designs now being qualified for production engines.
We appreciate ttiis opportunity to be of service.
Regards,
PARKER HANNIFIN CORPORATION
Gas Turbine Fuel Systems Division
W.R. Haney
Division Sales Manaafer
Attachment
Letter Reference #78-1108
:ba
-------
ADVANCED DEVELOPMENT, CERTIFICATION, AND SERVICE EVALUATION COSTS1
(in $1000)
____^ ; Development Certification Service Evaluation
Design and . ' '
Generic General General
Engine Laboratory Engineering Testing Certification Miscellaneous Engine
• Model Effort Support Hardware Tests Tests Hardware Total Coat
J$L ~~~
LFi - L
4
same sti
ij
Development should not include product improvement.
-------
INITIAL PRODUCTION
Increment in Manufacturing Cost Economic Pro-
Enp.ine Model Part Name Tool Design Tool Procurement Based on Current Part duction Volume
£75
'>-(fill) H& SATett
fO
Increment should account for increase or decrease in material, labor, machining, and corporate profit.
No amortization of development, certification, or other non-recurring expenses should be included. If no
conventional counterpart exists, the increment will be the full manufacturing cost of the part.
require
i I / •
**• / •'c. ~iucf fcti/ro/ • ff A
< ? if .. , / '
-------
B-66
NEW ENGINE PRICE INCREMENT
Generic Engine Model
Price Increment
Do not include amortization on non-recurring costs.
od
o
-------
B-67
ENCLOSURE H
If the low-emission fuel nozzles will require special overhaul tools and
dies, please estimate the retail value per set and the number of sets
typically required by an airline maintenance shop.
0/=
-------
B-68
References for Appendix B
Bahr, D.W., General Electric Company, Aircraft Engine Group.
1979. Letter of February 19, 1979, C.L. Gray, Emission Control
Technology Division, Office of Mobile Source Air Pollution Control,
U.S. Environmental Protection Agency, Ann Arbor, MI.
Frazier, G.N., United Technologies Corporation, Pratt and Whitney
Aircraft Group. 1978. Letter of August 25, 1978 to C.L. Gray,
Emission Control Technology Division, Office of Mobile Source Air
Pollution Control, U.S. Environmental Protection Agency, Ann Arbor,
MI.
Garrett, D.C., Delta Airlines, Inc. 1978. Letter of July 5,
1978 to C.L. Gray, Emission Control Technology Division, Office of
Mobile Source Air Pollution Control, U.S. Environmental Protection
Agency, Ann Arbor, MI
General Electric Company, Aircraft Engine Group. Approximate
distribution design/development/qualification/ initial production
costs (double annular combustor). Cincinnati, OH. Undated 1978
submittal to Logistics Management Institute, Washington, D.C.
Haney, W.R., Parker Hannifin Corporation, Gas Turbine Fuel Systems
Division. 1978. Letter of November 9, 1978, to R.S. Wilcox,
Emission Control Technology Division, Office of Mobile Source Air
Pollution Control, U.S. Environmental Protection Agency, Ann Arbor,
MI.
. 1978. Personal communication of November 14,
1978 with R.S. Wilcox, Emission Control Technology Division, Office
of Mobile Source Air Pollution Control, U.S. Environmental Protec-
tion Agency, Ann Arbor, MI.
Johnstone, P.M., Eastern Airlines, Inc., Operations Services.
1978. Letter of June 26, 1978 to C.L. Gray, Emission Control
Technology Division, Office of Mobile Source Air Pollution Control,
U.S. Environmental Protection Agency, Ann Arbor, MI.
Lloyd-Jones, D.J., American Airlines, Operations. 1978. Letter of
July 20, 1978 to C.L. Gray, Emission Control Technology Division,
Office of Mobile source Air Pollution Control, U.S. Environmental
Protection Agency, Ann Arbor, MI.
Pearson, R.D., Trans World Airlines, Inc., Technical Serives.
1978. Leter of July 31, 1978 to C.L. Gray, Emission Control
Technology Division, Office of Mobile Source air Pollution Control,
U.S. Environmental Protection Agency, Ann Arbor, MI.
-------
B-69
Titcomb, G.A., United Technologies Corporation, Pratt and Whitney
Aircraft Group. 1979. Letter of February 28, 1979 to C.L. Gray,
Emission Control Technology Division, Office of Mobile Source Air
Pollution Control, U.S. Environmental Protection Agency, Ann Arbor,
MI.
United Technologies Corporation, Pratt and Whitney Aircraft
Group. 1977. Estimated economic impact of proposed EPA emissions
regulations for aircraft, East Hartford, CT. Prepared for Log-
istics Management Institute, Washington, B.C.
Wassell, A.D., Rolls-Royce Limited, Aero Division. 1978. Letter
of December 21, 1978 to C.L. Gray, Emission Control Technology
Division, Office of Mobile Source Air Pollution Control, U.S.
Environmental Protection Agency, Ann Arbor, MI.
. 1978. Personal communication of January 23, 1978
with R.W. Munt and R.S. Wilcox, Emission Control Technology Divi-
sion, Office of Mobile Source Air Pollution Control, U.S. Environ-
mental Protection Agency, Ann Arbor, MI.
. 1979. Letter of January 31, 1979 to R.W.
Munt, Emission Control Technology Division, Office of Mobile
Source Air Pollution Control, U.S. Environmental Protection
Agency, Ann Arbor, MI.
. 1978. Personal communication of February
15, 1978 with R.S. Wilcox, Emission Control Technology Divi-
sion, Office of Mobile Source Air Pollution Control, U.S. Environ-
mental Protection Agency, Ann Arbor, MI.
-------
C-l
Appendix C
Summaries of
EPA Combustion Assembly Price
Estimates - Double Annular and Vorbix Designs
-------
C-2
' •
DIVISION OF HEIX1CKE INSTRUMENTS CO.
(305) 987-6101 TELEX 512-610
July 1, 1978
U. S. Environmental
Protection Agency
2565 Plymouth Road
Ann Arbor, Michigan 48105
Attn: Mr. Richard Wilcox
Project Officer, SDSB
Ref: Order No. CD-8-02-0280-A
Gentlemen:
In accordance with your purchase order we hereby submit a
selling price estimate of the JT8D Vorbix Combustion Can.
The estimate is based on information gleaned from the Pratt
and Whitney drawings L105810 and L105372, memo dated April
28, 1978, photographs supplied, and verbal information
supplied by telephone and your visit with us on June 13, 1978.
PART
QTY
MAT
LABOR
TOOL
DESIGN
TOOL
MFG.
L105810-1 1
L105810-2 1
L105810-3 1
L105810-5 1
L105810-6 1
L105810-7 1
L105810-8 1
L105810-9 .2
L105810-10 1
L105810-11 1
L105810Assyl
L105372-14 1
L105372-15 1
L105372-16 1
L105372-20 1
L105372-21 1
L105372-22 1
L105372-23 1
L105372-24-1
L105372-27 1
2.70
5.14
6.44
12.00
8.76
12.00
1.8,6
4.68ea
2.52
.44
-0-
3.86
6.42
8.34
8.10
4.92
9.10
10.66 /
26.60 /
14.00
.21.96
8.98
2.32ea
14.20
4.90
69.66
750.00
1250.00
2500.00
2250.00
800.00
250.00
-0-
-0-
600.00
1200.00
2500.00
7
7
27
4
6
70
20
50
86
84
8.82
9.12
7.75
9.92
9.00
9.00
38.66
4.10
6.76
1800.00
1600.00
1400.00
1600.00
800.00
800.00
400.00
450.00
1500.00
Manufacturers of FAA-PMA Approved Aircraft Components • FAA Appro
rni•.-;
1035.00
2485.00
4065.00
3180.00
1350.00
975.00
-0-
-0-
900.00
2325.00
3225.00
2715.00
2715.00
2015.00
2950.00
1465.00
1465.00
975.00
900.00
2895.00
'*
-------
JULY 7, 1978
PART QTY
L105372-28
L105372-29
L105372-30
L105372-52
L105372-53
L105372-54
L105372-58
Fuel Inj.
Tube
Assy 5
Assy 8
Final Assy
1
1
1
3
6
3
1
1
1
1
1
MAT
3.38
2.44
20.80
30. OOea
2.46ea
30. OOea
10.96
4.68
-0-
-0-
-0-
LABOR
6.
3.
36.
5.
2.
5.
16.
5.
56.
126.
39.
30
84
66
06ea
56ea
06ea
80
48
88
68
00
TOOL
DESIGN
2000.
700.
2000.
200.
75.
200.
2200.
-0-
1000.
1000.
1000.
00
00
00
00
00
00
00
TOOL
MFG.
4615
1165
4525
375
75
375
5775
.00
.00
.00
.00
.00
.00
.00
-0-
00
00
00
2250
2100
2250
.00
.00
.00
TOTAL
$379.06
$630.12 $32,825.00 $61,140.00
This amounts to a unit price of $1009.18. Our selling price
for a JT8D,-l,-7,-9, part No. JA731562 (with igniter plug)
is $911.00. This is an increase in selling price of 10.77%.
Pratt & Whitney sells this combustion chamber for $1300.00.
If we can assume proportionality then Pratt & Whitney's
selling price for the Vortex can would be about $1440.00
The estimates are based on a total production quantity of
6,000 cans with deliveries at the rate of 400 cans per year
over a period of 15 years. Should this quantity be increased
to 9,000 cans with deliveries of 600 cans per year (to include
sales to the foreign market), the reduction in estimated unit
price would be about .5%.
The method of estimating is as outlined in our letter of
June 2, 1978, except that packing and shipping costs have, been
omitted.
Very truly yours,
Harold Holden
Manager of Engineering
HH:PR
C-3
-------
C-4
A COMPARISON OF THE FABRICATION COST
AND SELLING PRICE OF THE PROPOSED LOW
EMISSION COMBUSTION CHAMBERS WITH
CURRENT COMPONENTS
SEPTEMBER 19?8
Prepared for
The Environmental Protection Agency
Under EPA Order No. CD-8-I312-A
ELECTRO-METHODS INC.
Governors Highway
South Windsor
Connecticut
-------
C-5
INTRODUCTION
The Environmental Protection Agency has been seeking co determine the
cost impact of its proposed gaseous emission regulations for commercial
aircraft engines. The studies that have been performed to date (Ref. 1-3)
\
have been dependent upon the engine manufacturers estimates of fabrication cost
analysis and an incremental cost estimate based upon current flight hardware.
The results presented herein are the products of work performed by
Electro-Methods for EPA under Order Number CD-3-1312-A.
-------
C-6
SUMMARY
A detailed fabrication cost analysis was performed on both the
proposed Pratt & Whitney Aircraft Vorbix Combustion Chamber and the
proposed General Electric Double Annular Combustion Chamber. It was
determined that the proposed P&WA design would result, in a minor cost
increase while the proposed G. E. design would increase the cost of
the combustion section by over 200%.
The cost increase in the G. E. design can be reduced to be
competitive to the P&WA design if improved fabrication tecnniques are
assumed for production quantities.
-------
Discussion
General Procedure
The drawing sets provided by the Environmental Protection Agency were
analyzed and the major assemblies of each of trie combustion sections were
reduced to their basic components and listed on Electro-Methods cost
analysis sheets. These sheets are provided as Appendix I (P&WA) and
Appendix II (G.E.) respectively.
Each component was then studied to determine the method of fabrication,
tooling design and procurement costs, material costs and labor hours to
fabricate. In general, where Electro-Methods nornally would sub-contract
a specialized procedure such as resistance welding it was assumed that
the equipment was in-house therefore, the labor content was estimated.
It was assumed that the acquisition of such equipment would have a negligible
effect upon quoting rates.
Electro-Methods normal suppliers were solicited for quotations on
material charges and fabrication charges for the specialized components.
These quotations are presented in Appendix III for P&WA's Vorbix Combustion
Chamber and Appendix IV for General Electric's Double Annular Combustion
Chamber. The results of these quotations formed t:ie basis for the resulting
material costs for each configuration.
Electro-Methods own rate structure was evai..a-:ed rrom a direct cost
and absorption cost basis. This was done ~.o eli::.inat-.' all "design engineering"
C-7
-------
charges so that the resulting selling price would be based upon a true
fabrication cost and, therefore, more indicative of an aftermarket replacement
cost.
It should be remembered that Electro-Methods rates do not have to
include the "write-off" of the original design costs nor the costs inherent
with a continuing product improvement effort.
Direct costing is a form of cost analysis taat divides all costs into
two areas: l). those costs that are dependent upon production volume, ie,
material costs and production labor, and 2) costs that are time dependent,
ie, rent, salaries, etc. It is a form of cost analysis that is an extremely
useful management tool. Absorption costing is more commonly utilized by
accountants. It is based upon the philosophy that each production hour
worked must bear its share of all costs incurred.
The two costing methods resulted in a minimal difference therefore
the current quoting rate of $3^/hour was used. The rates utilized for
both the Pratt & Whitney and General Electric analysis were assumed.
Electro-Methods is constantly in a competitive position with both manufacturers,
therefore, we feel that the $53 and $^3 hourly rate is quite accurate for this
type of fabrication. '
The selling price was computed by marking up the tooling and material
cost by 15$ and adding it to the cost of the labor. Tae tooling charges
were distributed over the full production run (Table I). The selling price
of both the JT9D and CFo components were oboainei t'rcn oacn manufacturer's
customers. The labor and material content ci' tne JT..-D and CFo was estimated
from Electro-Methods experience in fabricating similar interchangeable
components.
C-8
-------
Pratt & Whitney Aircraft Vorbix Combustion Chamber
The P&WA Vorbix Combustion Chamber is a modification of the existing
JT9D combustion chamber. The chamber has been extended and the geometry
has been modified. These changes do not greatly affect the fabrication
cost or selling price (Table II). The material (Kastelloy X) remains
unchanged. The additional labor is required to fabricate the additional
sections. The result of these changes is to create a lo$ increase in the
selling price. The massive cost increase shown in Ref. 1 is either
ultraconservative or based upon information beyond the scope of this
study.
C-9
-------
c-io
General Electric Double Annular Combustion Chamber
General Electric's design is a radical departure from the CF6 in
both design and required fabrication techniques. The double row of nozzles
require a centerbody (Part No. U013l32-6o8GOl) which in itself is expensive:
approximately $6,000. In addition, the construction methodology has
departed from the conventional developed sheet metal to macained forcings.
The increase in the selling price exceeds 200$ as shown in Table III. It
is our opinion that this configuration may be greatly simplified to make
it more cost effective without sacrificing its performance.
It is our estimate that if General Electric were to redesign to
utilize developed sheet metal fabrication techniques, the cost of the
double annular combustor would approximate Vorbix Combustion Chamber.
-------
TABLE I
ASSUMED PRODUCTION QUANTITIES
Year
1
2
3
h
5
6
7
8
9
10
11
12
13
lU
15
1200 Units
80
80
80
80
80
80
80
80
80
80
80
80
80
80
80
1800 Units
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
C-ll
-------
-3
Tooling (xlO ) .
Design
Procurement
Total
Table II
P&WA Vorbix Combustion Chamber
Electro
Methods
$ 160
$ 780
$ 940
Vorbix
$ 294
$ 1,435
$ 1,729
P&WA
JT9-.D
o
i
Fabrication (Unit)
Labor Hours
Labor Rate
Labor Cost
.'•'.aterial Cost
775
$ 34
$26,350
.$ 4,630
775
$ 53
$41,075
$ 4,630
700
$ 53
$37,100
$+ 3,975
$+ 630
Unit Selling Price
1200 Units
1-300 Units
$37,000
$36,000
,500
$+ 6,600
$+ 6,100
-------
Tooling (xlO"3)
Design
Procurernent
Total
TABLE III
G.E. Double Annular Combustion Chamber
Electro
Methods
$ 222
$ 944
$ 1,166
G.E.
Annular
$ 407
$ 1,738
CF6
Fabrication (Unit)
Labor Hours
Labor Rate
Labor Cost
.'Material Cost
1,600
$ 34
$54,400
$17,000
1,600
$ 43
$ 68,800
$ 17,000
650
$ 43
$27,950
$ 5,000
+950
+4o,850
+12,000
Unit Selling Price
1200 Units
1300 Units
$75,000
$74,700
$125,000
$124,500
$53,500
$53,500
$ 71,500
$ 71,000
-------
C-14
\
CONCLUSIONS
1. The JT9-D Combustor can be modified to the Vorbix configuration with
an approximate 15$ cost increase in the combustor section.
2. The CF6 Combustor can be modified to the proposed double annular
configuration with a 200$ cost increase. It is likely that the
proposed fabrication methods will be modified to maintain a
competitive position.
3. In the case of such a simplification, the cost incurred for the
double annular configuration should be comparable to Vorbix
configuration.
-------
C-15
References
1. The Economic Impact of Revised Gaseous Emission Regulations for
Commercial Aircraft Engines prepared by Logistics Management Institute
VfOl Sangamore Road
Washington, D. C. 20016
Cost-Effectiveness Analysis of the Proposed Revisions in the Exhaust
Emission Standards for New and In-Use Gas Turbine Aircraft Engines Based
on EPA's Independent Estimates by Standards Development and Support Branch
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
Office of Air and Waste Management
U. S. Environmental Protection Agency
No. AC73-01
Cost-Effectiveness Analysis of the Proposed Revision in the Exhaust
Emission Standards for New and In-Use Gas Turbine Aircraft Engines
based on Industry Submittals by Standards Development and Support Branch
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
Office of Air and Waste Management
U. S. Environmental Protection Agency
No. AC77-02
-------
C-16
References for Appendix C
Holden, H. 1978. Selling price estimate of the JT8D Vorbix
Corabustor. Jet Avion, Hollywood, FL. EPA Order No. CD-8-02-
0280-A.
Electro-Methods Inc. 1978. A comparison of the fabricati-on
cost and selling price of the proposed low-emission combustion
chambers with current components. South Windsor, CT. EPA Order
No. CD-8-1312-A.
-------
D-l
Appendix D
Derivation of Non-Recurring and
Recurring Engine Costs
-------
D-2
Appendix D
Derivation of Non-Recurring and Recurring Engine Costs
For each of the proposed standards, engine costs are separated
into broad categories: non-recurring and recurring. These catego-
ries reflect the costs for manufacturing and installing emission
control hardware as well as corporate profit.
The cost figures which are documented in this appendix origi-
nate longly with manufacturers' or vendors' estimates. EPA
revised the manufacturers' figures or made independent estimates
(1) when industry submittals were incomplete, (2) when large
unexplainable descrepancies existed between different manufac-
turers' estimates, or (3) when manufacturers' estimates appeared to
be inappropriate based on additional information acquired by
EPA.
The expenditures for specific cost categories are shown in
Tables D-1A through D-3A. Each of these tables have an accom-
panying table, when required, which more completely explains the
basis of each cost figure (Tables D-1B and D-3B).
-------
TABLE D-1A
Engine Costs Associated with the 1982 Standards
(Thousands of 1978 dollars)
NON-RECURRING
Development Certification 9/
JT8D-17 I/ 19,725
JT8D-200 I/
JT9D-7
JT9D-7R 21
JT9D-70
CF6-6
CF6-32 3/
CF6-50
CF6-45 _4/
CF6-80 57
RB211-22B
RB211-535 6/
RB211-524
CFM56
JT10D 7/
14,
14,
5,
7,
7,
44,
5,
3,
5,
063
063
130
370
370
608
763
860
850
-/
lorn,
10/16/
167
I6./
ii/
13/16/
ll/l6./
16/
16/
6,575
4,688
4,688
600
600
4,565
4,565
150
NA
li/
^0/j_6/
lo/iy
16/
I6./
16/
i6./
16/
Service Initial
Evaluation Production Total
1,200 16_/ 300 17/ 27
600 JO/_16/ 800 \T_I 20
600 _HV_16/ 500 _17/ 19
276 16/ 165 11/16/ 6
284 16_/ 165 167 8
7
1,500 147 850 13/17/ 51
5
4
NA 35 16/ 4
NA NA 5
,800
,151
,851
,171
,419
,370
,523
,763
,565
,045
,850
RECURRING
New Engine
Increment
2
2
6
6
6
25
25
25
6
25
25
25
5
NA
.7 167
.7 16/
16/
ii/
_16/
16/
_16/
«/
Jl/li/
16/
167
J!/
ii/
Retrofit
Installed
23.5 _167
55 16/
47 16/
43 16/
50 16/
73 16/
73 _!£/
NA
NA
Sepy 8/
NA
NA
NA
NA
NA
NA
NA
-------
D-4
Table D-lB
Explanation of Footnotes in Table D-1A
_!/ Cost for all JT8D models or average cost where appropriate.
2J JT9D-7R is a rerated JT9D-7, same combustor as JT9D-7, no
extra development, no certification differential because it is
assumed the engine will be certified with 1982 type tech-
nology, or crossover from "parent" engine will fulfill cer-
tification requirements of combustor, it is a new engine so no
service evaluation, no added tooling, and new engine increment
is the same as "parent" engine.
_3/ CF6-32 is a rerated CF6-6, same combustor as CF6-6, same cost
considerations as _2/ above.
kj CF6-45 is a derated CF6-50, same cost considerations as _2/
above.
5_/ CF6-80 is a derivative of the CF6-50, redesign needed because
of different control system. Therefore, added development
costs and a different new engine increment. Because engine is
new and must go through certification and initial production
regardless of emission control requirements, no cost is
allowed for these categories.
6_/ RB211-535 is a derated RB211-22B, essentially the same core as
RB211-22B, assumed to use phase II combustor as other RB211's,
same considerations as in _2_/ above for other cost categories.
TJ JT10D has no market at present and its prospects are not
bright. Manufacturer is expected to certify with 1982 type
technology so no added certification costs are allowed. Added
development costs are allowed. Because EPA fleet projection
shows no engines produced, there is no initial production, no
new engine increment and no retrofit. No service evaluation
will be performed since it is a new engine.
8/ The Spey is an engine of older design that can not possibly
meet the proposed standards. EPA assumes the engine is out of
production either because (1) it would not meet the standard,
and hence, would not be made, (2) there is no market, or (3)
it is replaced by the RB432 for which EPA has no information.
9J For all derivative engines, some certification cost for
emission control may be expected. In relation to other costs
of certification, when incurred (e.g., CF6-80), these costs
well be insignificant. Additionally, the "parent" engine
certification costs have a fairly large degree of uncertainity
and in some instances appear to be inflated. Also the
"parent" engine certification can often be used in the certi-
fication of the derivative's combustor. Therefore, no allow-
ance is made for emission certification testing in derivative
engines.
10/ Fifty percent cost sharing between JT9D-7 and JT9D-70 families.
11/ Fifty percent cost sharing between CF6-6 and CFB-SO families.
-------
D-5
121 CF6-80 will be produced with aerating nozzles instead of
sector burning.
13/ Fifty percent cost sharing between RB211-22B and RB211-524.
EPA is unable to explain this high cost in relation to the
task involved.
147 Service evaluation cost as reported by Rolls Royce ($7.22
million) disallowed because they were completely inconsistent
with information from the other engine manufacturers. EPA
estimated this cost based on data contained in Wilcox and Munt
(1978). EPA's figure may still be somewhat liberal in compari-
son to the cost reported for sector burning hardware by
General Electric.
157 Additional cost claimed by the manufacturer for the RB211-535
because development was not done in conjunction with other
RB211's. Also, extra expense may be do, in part, to an
evaluation of a phase III combustor in this engine.
16/ Based on the latest manufacturer or vendor submittal to EPA
(see Appendices B and C).
177 From Wilcox and Munt (1978) with costs updated to 1978 dollars
by using a 6 percent annual inflation rate for industrial
prices.
-------
TABLE D-2A
Engine Costs Associated with the CF6 Alternative Combustor \J
(Thousands of 1978 dollars)
Develop- Cert ifi- Service Initial Non-recurring New Engine
inent cation Evaluation Production Total Increment
I/
2/
CF6-6
CF6-32
CF6-80
CF6-50
CF6-45
Based on the
Requirements
7,000
U
NA
I/
I/
latest
for the
4,600
4,600
NA
4,600
4,600
manufacturer or
CF6-32 already
600
I.'
NA
I/
500
If
NA
I/
I/ I/
vendor submittals to
have been fulfilled 1
12,700
4,600
NA
4,600
4,600
EPA (Appendices B
ay the CF6-6 parent
8
8
NA
6
6
and C).
engine ;
therefore, no additional cost i.s incurred.
J3/ Requirements for the CF6-50 and CF6-45 already have been fulfilled by the closely
related CF6-80; therefore, no additional cost is incurred.
-------
TABLE D-3A
Engine Costs Associated with the 1986 Low-NOx Standard
Development Cert
JT8D-200 I/
JT9D-7
JT9D-7R 21
JT9D-70
CF6-6
CF6 32 V
CF6-50
CF6-45 4/
CF6-80 _5/
RB211-22B 6/
RB211-535 11
RB211-524
CFM56
JT10D 8/
Spey 9/
18,000 12/
35,300 11/14/19/ 17,
4,
35,300 11/14/19/ 17,
16,000 18/19/ 7,
3,
16,000 18/19/ 7.
3,
3,
30,000 12/ 4,
4,
4,
13,000 13/ 5,
NA
NA
(Thousands of 1978 dollars)
Service Initial
ification 10/ Evaluation Production
200
000
200
700
400
700
900
900
565
565
565
000
NA
NA
4,200 12/ 1,800 137
11/14/19/ 5,300 11/14/ 3,800 13/
IT/ ~
11/14/_12/ 5,340 11/14/ 3,800 13/
18/19/ 5,400 14/ 3,400 13/
!!/ ~ ~
18/19/ 5,400 147 3,400 137
157 ~~
!!/
16/ 4,300 17/20/ 3,400 137
16/
T6/
\2_l 3,300 12/ 2,600 13/
NA NA
NA NA
Non-recurring
Total
24
61
4
61
32
3
32
3
3
,000
,600
,000
,000
,500
,400
,500
,900
,900
42 , 300
4,600
4,600
23
,900
NA
NA
New Engine
Increment
2i
33
33
33
25
25
25
25
25
25
25
25
17
12/
13/
137
!!/
13/ V
13/
137
T37
H/
13/
13/
I3./
_12/
NA
NA
-------
D-8
Table D-3B
Explaination of Footnotes in Table D-3A
_!_/ Costs for all JT8D models are average costs where appropriate.
T/ JT9D-7R is a rerated JT9D-7, same combustor as JT9D-7, no
extra development, no added initial production, and the new
engine increment is the same as the "parent" engine. Ad-
ditional certification costs are allowed for derivatives using
low-NOx combustors because of the possibility that the com-
plexity of the hardware may require some separate certifica-
tion testing (e.g., flight tests) to verify the airworthiness
of the hardware even though essentially the same hardware was
certified in "parent" engines. No separate service evaluation
is required because data acquired from the "parent" engine is
expected to apply.
3/ GF6-32 is a rerated CF6-6, same cost considerations as
2jabove.
_4/ CF6-45 is a derated CF6-50. Same cost considerations as _2/
above.
5/ CF6-80 is a derivative of CF6-50. Same cost considerations as
21 above.
bj Development of the Rolls Royce (RR) double annular combustor
is higher than for General Electric"s comparable combustor
design because RR does not have crossover from other engine
families to reduce costs. Also, they have not benefited from
U.S. Government IR&D and NASA funding as domestic manufac-
turers have.
_7_/ RB211-535 is a derated RB211-22B. Same cost conisderations as
2/ above.
8/ JT10D is forecast to have no market and, therefore, will not
be redesigned to comply with the 1986 low-NOx standard.
9/ The Spey is assumed to be out of production by 1986.
10/ Some certification cost for emission control may be expectd
for all derivative engines. For the 1986 low-NOx standard,
these costs are accounted for in the overall cost of cert-
ification which is listed for each engine.
ll/ Fifty percent cost sharing between JT9D-7 and JT9D-70 fami-
lies .
12/ From Wilcox and Hunt (1978) with costs updated to 1978 dollars
by using a 6 percent annual inflation rate for industrial
prices.
13/ New estimate based on Wilcox and Hunt (1978), latest manu-
facturer or vendor submittal to EPA (Appendix B), and EPA
combustor price estimates (Appendix C).
14/ From United Technologies Corporation (1977).
-------
D-9
15/ New estimate based on data contained in Wilcox and Munt
(1978).
16/ Based on the latest manufacturer or vendor submittals to EPA
(Appendices B and C) .
17/ EPA revised figure based on manufacturers latest submittals to
EPA (Appendix B).
18/ From General Electric Company (1977) updated to 1978 dollars.
19/ General Electric and Rolls Royce reported development and
certification costs which did not fully correspond to the EPA
cost accounting format. The manufacturers expenses were
reapportioned by using weighting factors for the two cate-
gories which were based on data contained in Wilcox and Munt
(1978). This method produced cost figures which are com-
parable between manufacturers. The overall cost as reported
for the two categories was not changed, however.
20/ Service evaluation costs as reported by Rolls Royce ($12.78
million) were disallowed because they were completely incon-
sistent with information submitted by other manufacturers.
EPA reduced the cost to 33 percent of that claimed, to reflect
service evaluation for one "parent" engine within the RB211
family.
-------
D-10
References for Appendix D
Wilcox, R.S. and R.W. Hunt. 1978. Cost-effectiveness analysis
of the proposed revisions in the exhaust emission standards
for new and in-use gas turbine aircraft engines based on EPA's
independent estimates. TSR AC 78-01. Emission Control Technology
Division, Office of Mobile Source Air Pollution Control, Environ-
mental Protection Agency, Ann Arbor, MI.
United Technologies Corporation, Pratt and Whitney Aircraft
Group. 1977. Estimated economic impact of proposed EPA emissions
regulations for aircraft. East Hartford, CT., Prepared for Log-
istics Management Institute, Washington, D.C.
General Electric Company, Aircraft Engine Group. 1977. Approx-
imate distribution-design/development/qualification/ initial
production costs (double annular combustor). Cincinnati, OH.
Undated submittal to Logistics Management Institute, Washington,
D.C.
-------
E-l
Appendix E
Derivation of the Average Engine
Selling Price Increment
-------
Table E-l
SCENARIO *2: 1982 NME AND 1986 IUE STANDARDS ONLY - EXPECTED SALES.
YEAR
1975.
1976.
1977.
1978.
1979.
1980.
1981.
1982.
1983.
19b4.
1985.
1986.
1987.
1988.
1989.
1990.
1991.
1992.
1993.
1994,
1995,
1996.
1997.
1998.
1999.
?000.
?001.
UTOT
DTOT
NEW
ENG
SOLD
0.
0.
0.
0.
0.
0.
240.
9.02.
910.
1224.
1129.
1266.
1418.
1498.
1552.
1092.
1108.
782.
836.
1135,
1230.
1174.
1 J35.
1372.
1415.
0.
23226.
11U32.
OLD
ENG
rtTRO
0.
0.
0.
0.
0.
0.
0.
1773.
1774.
177^.
1774.
0.
0.
0.
0.
0.
0.
0.
0.
0,
0.
0.
0.
0.
0.
0.
0.
7095.
6185.
F1XO
COST .
6460000.
12920000.
19380000.
2!sb40000.
32300000.
32300000.
32300000.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
161500000.
222125205.
NME
HARD
WARE
0.
0.
• o.
V 0.
0.
o. •
17000.
17000, ,
. 17000.
17000.
17000.
17000.
17000.
17000.
17000.
17000.
17000.
17000.
17000.
17000.
17000.
17000.
17000.
17000.
17000.
17000.
6.
340000.
175125.
IUE
HAND
WAKE
0.
0.
0.
0.
0.
0.
0.
38000.
38000.
38000.
38000..
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0..
0.
0.
0.
0.
152000.
132500.
TOT
COST
6460000.
12920000.
19340000.
25840000.
32300000.
32300000.
36380000.
82708000. .
82882000.
83220000.
86605000.
.21522000.
24106000.
25466000.
?6384000.
18564000.
18836000.
13294000.
14212000.
1929SOOO.
20910000.
19958000.
•22695000.
23324000.
27336000.
' 24055000.
0.
825,952,000.
644687162.
TOT#
ENG
CONT
0.
0.
0.
0.
0.
0.
240.
2675.
2684.
2998.
2903.
1266.
141U.
1498,
1552.
1092.
1108.
782.
836.
1135.
1230.
1174.
1335.
1372.
1608.
1415.
0.
30321.
17217.
DISC
FACT
.94871
.7715ft
.61051
.46410
.33100
.21000
.10000
.00000
0.90909
O.B2645
0.75132
0.68301
0.62092
0.56448
0.51316
0.46651
0.42410
0.38555
0.35050
0.31H63
0.28967
0.26333
O.P3939
0.21763
0.19785
0.17986
0.16351
19.80082
PRES
VALU
COST
12588667,
22888497,
31211603.
37832265.
42991233.
39082959.
40017979.
82708000.
75347312.
72909167.
65067720.
14699846.
1496796B.
14374938.
13539213.
8660279.
7988J40.
5125439.
4981248,
6148020.
6056923.
5255603.
• 5433045.
5076024,
5406330.
4326544.
0.
6446H7162.
THE'FIRST PRICE INCREASE IS COMPUTED USING THE PRESENT VALUE OF ALL COSTS AND THE TOTAL NUMBER
OF ENGINES AFFECTED, DISCOUNTED TO THE SAME VEAR AS THE COSTS. THIS COST ANAL-YSIS ASSUMES
THAT ALL COSTS AHE INCURRED AT THF. BEGINNING OF THE YEAR, AND ALL REVENUES ARE RECEIVED AT THE
END OF THE YEAR, THUS FORCING DISCOUNTING ONE ADDITIONAL YEAH. THEREFORE* THE FIRST PRICE
INCREASE IS THE PRESENT VALUE UF ALL COSTS DIVIDED BY THE DISCOUNTED TOTAL ENGINES AFFECTED
AND MULTIPLIED BY 1.10.
w
i
ho
FIRST PRICE INCREASE = $ I 644687162.07 / 17216.69 ) « 1.10 = .$ 41190.01
-------
F-l
Appendix F
Derivation of Idle Fuel Consumption Increments
In order to meet the standards under consideration, manufac-
turers will improve the combustion efficiency of their engines at
idle power settings. For all engines except the JT8D, this im-
provement will reduce idle specific fuel consumption (SFC) by
about 3 percent. The JT8D smokeless combustor is already more
efficient than average and will experience a 1 percent reduction in
idle SFC.
The sector-burning control concept which may be used to comply
with ther 1982 NME and 1986 IUE Standards has net fuel consumption
penalty associated with it. Sectoring at idle causes an 8 percent
decrease in turbine component efficiency. This decrease, in
conjunction with the combustion efficiency improvement of 3 per-
cent, yields a 5 percent over all penalty in idle SFC. The CFM 56
has the greatest fuel penalty of any controlled engine. To achieve
the CO standard, the idle thrust must be increased from about 4
percent to 6 percent. This change along results in 19.6 percent
fuel consumption increase. When this penalty is combined with the
8 percent increase brought about by the use of sector burning and
the 3 percent combustion efficiency benefit, the result is an
overall 20 percent increase in the engine's uncontrolled baseline
idle SFC.
Low-NOx staged combustors (1986 technology) are also about 3
percent more efficient at idle than are their uncontrolled counter-
parts. In control scenarios where a preexisting standard is
assumed, no increment in idle SFC occurs unless a staged combustor
replaces an emission control scheme that had a fuel penalty associ-
ated with it, i.e., sector burning. Therefore, the fuel penalty of
a previous standard provides an additional fuel savings when 1986
technology is introduced into the fleet. In scenarios with no
preexisting standard, the introduction of a staged combustion
system produces a benefit in every engine because of better combus-
tion efficiency.
The fuel consumption increment in gallons per year for the
average engine in each control scenario is calculated by using the
following equation:
Idle fuel increment=
Lt ul sf Mf Tj FC/FW (1)
Z Ui Sf
-------
F-2
Where:
Lt = landing and take-off cycles per year for
each engine model.
Uj = useful life weighting factor for each
engine model.
Sf = sales weighting factor for each engine
model.
Mf = baseline idle fuel flow in pounds mass
per hour.
T| = average time spent in idle mode (19/60)
FC = fractional fuel consumption increment.
Fw = weight of jet fuel in pounds per gallon
(6.7).
The dollar value of the fuel increment is found by:
(Equation 1) ($ 0.40) (2)
Where: $0.40 per gallon, including tax, represents a nominal
value for jet fuel in 1978.
Table F-l illustrates the derivation of the idle fuel consump-
tion increments for each control scenario.
-------
Table F-l
Annual Idle Fuel Increment Scenario 2
(1982 NME and IUE Only)
Engine
JT8D-17
Sitro
JT6D-200
JT9D-7
?.-=•: ro
JT9D-7R
JT9D-70
CF6-6
Retro
CT5-32
CI'5-50
!"..;-tro
CF6-A5
CF6-SO
R32J ;-223
Xe:ro
XB211-533
R5 2-1 I -5 24
CFM56
A
Fraction
Useful
Life
1
0.47
1
i
0.47
1
1
i
0.47
i
i
0.57
i
1
1
0.47
1
1
1
B
Fractional
Sales
0
0.13
0.06
0.09
0.05
0.01
0.09
0.06
0.02
0.05
0.15
0.01
0.03
0.01
0.06
0.02
0.05
0.06
0.05
A x B
IA x B
Sales
Parent
'Thrust
Weighted LTCs/ Correction
Useful Life Year Factor
0.07
0.07
0.10
0.03
0.01
0.10
0.07
O.C1
0.06
0.17
0.01
0.03
O.C1
0.07
0.01
0.06
0.06
0.06
2,000 0
2,600
2,600
900
900
2,600 1.04
900
1,300
1,300
1,300 0.82
1,300
1 , 300
2,600 0.93
2,600 0.96
1,300
1,300
2,600 0.76
1,300
2,600
Baseline
Mf Idle
(uncontrolled)
1,150
1,150
1,090
1,850
1,850
1,925
1,800
1,060
1,060
870
1,210
1,210
1,125
1,160
1,475
1,475
1,120
1,500
715
Controlled
Increment
Mf Idle
0
-12
-11
-56
-56
-58
-54
+53
+53
+44
+60
+60
+56
-35
+ 74
+ 74
+56
+ 75
+ 155
Weighted
Controlled
Increment
Mf Idle
0
-0.8
-0.8
-5.6
-1.7
-0.6
-5.4
+ 3.7
+0.5
+ 2.6
+ 10.2
+ 0.6
+ 1.7
-0.4
+ 5.2
+0.7
+3.4
+4.5
+9.3
Ibn
Weighted
Annual
Fuel
Increment
0
-659
-659
-1 , 596
-484
-494
-1,539
+1,523
+ 206
+1,070
+4,299
+ 247
+1,400
-329
+2,141
+ 28S
a — t ' Js
+1,852
+7,657
Annual Ar.nu^i
Gallons Coses
(6.7 lb/ (50.40/
gal) gal)
i
10
Total
+17,622
+2,630 +1.C52
-------
G-l
Appendix G
Derivation of Maintenance Increments
Emission control has the potential of increasing maintenance
costs by reducing combustor durability throughout the life of the
engine, increasing replacement costs for life-limited parts, or
necessitating the maintenance of all new engine parts (e.g. ,
sectoring control). No maintenance increment is associated with
the introduction of immature engine hardware for the standards
analyzed in this study. The implementation date for each proposed
standard has been selected to provide an adequate service evalua-
tion by the engine manufacturers which will eliminate any potential
service penalty.
The incremental maintenance cost estimates are based upon
manufacturers' estimates, supplemental data from major airlines,
information from EPA's contractor report entitled, "The Economic
Impact of Revised Gaseous Emission Regulations for Commerical
Aircraft Engines" (Day and Bertrand 1978), and EPA's independent
estimates of increased maintenance requirements.
EPA recognizes the possibility that significant maintenance
penalties may be associated with the staged-combustion systems
which are required to comply with the proposed 1986 NME Standard.
However, industry proponents of these potential penalties have
not presented evidence which substantiates their claim. Therefore,
any discussion of this issue remains conjecture.
The "worst case" maintenance cost for staged combustors is
evaluated in this analysis. The estimate is predicated on the
assumption that 500 additional person-hours of repair work are
required to overhaul a large engine with a Vorbix combustor and 400
added person-hours are required for Double Annular combustors.
Also, it is assumed that mature staged-combustors could experience
up to a 25 percent reduction in the average number of engine hours
between hot section overhauls and that some turbine blade degrada-
tion will occur.
The annual maintenance increment for each engine is calculated
by using the following equation:
Annual Maintenance cost = 12 Ho C^
Where: 12 = Number of calendar months in a year.
Ho = Mean engine hours before combustor overhaul.
C^ = Dollar cost per engine hour for incremental
maintenance.
MO = Mean calendar months between combustor overhaul.
The annual increment for each engine (Table G-l) is then
weighted by the appropriate sales- and useful-life factors to
derive the average engine maintenance increment in each control
scenario. Table G-2 illustrates this latter computation for
Scenario 2.
-------
Table G-l
Incremental Maintenance Costs per Engine
Hot Section
Overhaul Intervals _!_/
(Months)
JT8D-17
JT8D-200
JT'JU-7
JT9D-70
CKG-f.
CK6-50
RB2 11-22
KB2 11-524
20
20
9
9
9
9
10
19
5/
5/
X
Overhaul
per Year I/
0.6
0.6
1.3
1.3
1 .3
1.3
1.2
0.63
Engine Hours
Between Overhaul 2/
4,700
4,700
2 , 700
2,700
2,7«0
2,780
2,400
4,500
1982 Standards
Dollar/Hour
(HC and CO)
0.10
0.10
0.20
0.20
0.20
0.20
0.20
0.20
I/
1986 Standards 4/
Dollar/Hour
(HC, CO and NOx)
6.65
6.65
13.25
13.25
12.50
12.50
13.00
11.50
1982 Standards
Dollar
Annual Costs
280
280
700
700
725
725
575
900
1986 Standards
Dollar
Annual Costs
18,700
18,700
46,500
46,500
45,200
45,200
37,450
32,600
\j Based on the latest engine manufacturer and airline submittals (Appendix B), and Day and Bertrand (1978).
2/ Based on the lateut engine manufacturer and airline submittals (Appendix B).
3V Based on the latest engine manufacturer submittals (Appendix B), United Technologies Corporation (1977), and EPA's estimate of maintenance requirements.O
~kj Based primarily on United Technolgies Corporation (1977), and EPA's estimate of maintenance requirements . ro
5/ Insufficient data. Based on CF6.
-------
G-3
Table G-2
Annual Maintenance Increment for Scenario 2
(1982 NME and 1986 IUE Only)
Engine
JT8D-17
Retro
JT8D-200
JT9D-7
Retro
JT9D-7R
JT9D-70
CF6-6
Retro
CF6-32
CF6-50
Retro
CF6-45
CF6-80
RB211-22B
Retro
RB211-535
RB211-524
CFM56
A
Fractional
Useful Life
1
0.47
1
1
0.47
1
1
1
0.47
1
1
0.67
1
1
1
0.47
1
1
1
B
Fract ional
Sales
0.13
0.06
0.09
0.05
0.01
0.09
0.06
0.02
0.05
0.15
0.01
0.03
0.01
0.06
0.02
0.05
0.06
0.05
A x B
ZA x B
Sales Weighted
Useful Life
0.07
0.07
0.10
0.03
0.01
0.10
0.07
0.01
0.06
0.17
0.01
0.03
0.01
0.07
0.01
0.06
0.06
0.06
$
Annual
Maintenance
280
280
700
700
700
700
725
725
725
725
725
725
725
575
575
575
900
0
Weighted
Annual
Maintenance
20
20
70
21
7
70
51
7
44
123
7
22
7
40
6
35
54
0
Total
604
-------
G-4
References for Appendix G
Day, C. F. and H. E. Bertrand. 1978. The economic impact of
revised gaseous emission regulations for commercial aircraft
engines. Logistics Management: Institute, Washington, D.C.
EPA Contract No. 68-01-4647 (Task EP701).
United Technologies Corporation, Pratt and Whitney Engine Group.
1977. Estimated economic impact of proposed EPA emissions regula-
tions for aircraft. East Hartford, CT. Prepared for Logistics
Management Institute, Washington, D.C.
-------
H-l
APPENDIX H
Derivation of Emission Reductions
The regulated EPAP values used to derive the exhaust emission
reductions per engine reflect the actual levels achievable based on
current test results (Munt 1979). By using these values instead
of the more conservative approach of limiting the EPAP's to the
maximum allowable levels permitted by the regulation, a more
realistic simulation of the actual decrease in air pollutants at
major air carrier terminals is accomplished.
In a few instances where the demonstrated EPAP's were above
the maximum permissible levels, they were adjusted to meet the
standard. This is consistent with the fact that all engines must
comply with the regulation or they will not be certified. Where no
data were available and no reasonable basis for estimating the
engine's emissions existed, EPAP values which conformed to the
standard were assigned.
Except for CO, the levels of the standards are as proposed by
EPA in the March 24, 1978 Notice of Proposed Rulemaking (43 FR
12615). Based on the comments which were received in response to
the NPRM, EPA has tentatively concluded that the proposed CO
standard may be technically unattainable by most turbine engines
and that some relaxation may be necessary. For the purposes of
this analysis, it is assumed that the standard is 40 percent less
stringent than the proposed value. This results in a total reduc-
tion from uncontrolled CO emissions of about 60 percent instead of
about 70 percent.
The tons of pollutant reduced per engine each year is computed
by using, the following equation:
Annual reduction of pollutant A =
[EPAP(A) . . - EPAP(A) . ,] R L /(2.000 Ibm/t) (1)
unregulated regulated t y '
Where: R = pounds of rated thrust.
L = annual landing-takeoff cycles (LTOs).
The EPA values used in Equation 1 are based on the EPA-
defined LTO cycle. This cycle is representative of maximum times-
in-mode for aircraft at major metropolitan air terminals. It is
not useful to characterize modal times at average airports in
future years, however. The pollutant species HC and CO are sen-
sitive to the time-in-mode differences between major and average
air terminals, because they are mainly the products of low-power
operations, i.e., taxi-idle. Emissions of NOx do not change
significantly between airports since it is produced during high-
power modes of the flight regime which do not vary substantially
from airport-to-airport.
-------
H-2
EPA assumes that the average taxi-idle time-in-mode for
turbine-powered aircraft at airports throughout the nation is about
19 minutes (see Discussion — Part I). This contrasts with the 26
minutes of the EPA LTD cycle upon which the EPAP's are based. To
account for the difference in ground times, the annual HC and CO
emission reductions derived in Equation 1 are adjusted to represent
the average airport time-in-mode in the following way:
Adjusted annual reduction in HC or CO =
(Equation 1)(0.73) (2)
Where: 0.73 is the ratio of the average and major air term-
inal taxi-idle times (19/26).
The annual emission reductions for the average engine in each
control scenario is determined by weighting the annual reductions
for each engine model (Tables H-l through H-3) by useful life and
sales projection data.
This computation is illustrated in Table H-4 for the average
engine in Scenario 2.
-------
Emission Reduce ions per Engine Resulting from the I9S2 NME end 19S5 IUE Standards
Enpi.no
JT3D-17
JT8D-200 I/
JT9D-7
JT9D-7R
JT9D-70
CF6-5
CV6-32
Cr-6-50
-:?6-45
cyb-GO
KB211-22B
RZ2I1-535
RB211-524
CTM56
Ibm
Thrust
(COO)
16.0
18.5
46.2
48.0
51.2
38.9
32.6
49.9
46 . 5
48.0
42.0
32.0
50.0
22.7
Standard LTD
Unregulated EPAP
(uncorrec ted)
LTOs/Yr
2,600 "
2,600
900-
2,600
900
1,300
1,300
1,300
2,600
2,600
1,300
2,600
1,300
2,600
HC
0.37
0.37
0.45
0.47 2/
0.20
0.42
0.47
0.62
0.58 2/
0.60 2/
1.3
3.0 5/
l.i
0.12 6/
CO
1.1
1.1
0.97
1.0 2/
0.86
0.95
1.0
1.2
l.i 2/
1.2 2/
1.7
3.1 5/
1.4
C.78 6/
Standard
Regulated
LTD
EPAP
(uncorrec ted)
HC
0.075
0.075
0.056
0.66 3/
0.037
0.016
0.020
0.010
0.066 3/
0.066 3/
0.041
0.025
0.030
0.009
CO
0.4S
0.48
0.24
0.50 4/
C.20
0.28
0.29
0.36
0.50 4/
0.50 4/
0.28
0.50 4/
0.22
0.41
Standard LTO
Net
EPAP Reduction
(uncorrec ted)
HC
0.30
0.30
0.39
0.40
0.16
0.40
0.45
0.61
0.51
0.53
1.26
2.98
1.07
0.11
CO
0.62
0.62
0.73
0.5
0.66
0.-67
0.71
O.S4
0.60
0.70
1.42
2.60
1.18
0.37
Taxi-idle
Correction
Fac
(HC-CC
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
tor
only)
73
73
73
73
73
73
73
73
73
73
73
73
73
73
Tons
Annual Reduction
(corrected)
HC
4.6
5.3
5.9
18.2
2.7
7.4
7.0
14 .4
22.5
24.1
25.1
90.5
25.4
2.3
CO
9.4
10.9
11.1
22.8
11.1
12.4
11.0
i.9.9
26.5
31.9
28.3
79.0
28.0
7.8
\J No data. Based on JTCD-17.
2J Eased or. the thrust ratio of the parent engine and the derivative.
_3y No data. A.ssorr.ed tc rceot the standard.
_£/ Assumed to r:.::et the standard with a 40% increase; compliance not yet
_5_/ Eased on the thrust ratio of the parent and the derivative, multiplied by the EPAP' s
6/
of the RB211-22B with a Phase II combustor. Also accounts for the R3211-535's
reduced idle speed.
Based on the Mod. PFRT combustor.
-------
Table H-2
Emission Reductions per Engine When 1986 NME is implemented subsequent to the 1982 NME Standard
Ibm
Thrust
Std. LTD Std LTD
Unregulated EPAP Regulated EPAP
(uncorrected) (uncorrected)
(000) LTOs/Yr
JT8D-17
JT8D-200
JT9D-7
JT9D-7R
JT9D-70
CF6-6
CF6-32
CF6-50
CF6-45
CF6-80
RB211-22B
RB211-535
RB211-524
CFM56
I/ Baseline
2/ Assumed
37 No data.
4/ No data.
T/ 1982 NME
16
18
46
48
51
38
32
49
46
48
42
32
50
22
.0
.5
.2
.0
.2
.9
.6
.9
.5
.0
.0
.0
.0
.2
2,600
2,600
900
2,600
900
1,300
1,300
1,300
2,600
2,600
1,300
2,600
1,300
2,600
is 1982 NME emissions.
to meet standard; compl
Baseline
Assumed
meets the
NOx
NA
0.67
0.46
0.48 3/
0.48
0.64
0.63
0.60
0.56 3/
0.58
0.63
0.30
0.69
0.43
iance not
emissions estimated on
NOx
NA
0
0
0
0
0
0
0
0
0
0
0
0
.32
.26
.32
.35
.32
.32
.38
.34
.36
.32
NA
.34
.32
U
4/
21
11
21
4/
4/
4/
5/
4/
4/
Net
EPAP Reduction
(uncorrected)
NOx
NA
0
0
0
0
0
0
0
0
0
0
0
0
.35
.20
.16
.13
.32
.31
.22
.22
.22
.31
NA
.35
.11
Tons
Annual Reduction
(corrected)
NOx
NA
6
3
7
2
5
4
5
9
10
6
8
2
1
» 1
.0
.3
.2
.9
.8
.2
.7
.0
.2
NA
.3
.3
yet demonstrated.
the basis of
the
parent
engine.
to meet the standard.
NOx standard
,
-------
Emission Reductions per Engine Resulting from the 1986 N">iE Standards I/
En?i ne
JT3D-200 21
JT9D-7
JTSD-7R
JT9J-70
CF6-6
CF6-32
CF6-50
Cr'6-45
C:'£-SO
R3211-22B
RB211-535
RE211-524
CFX56
Ibm
Thrust
(000)
13.5
46.2
43.0
51.2
38.9
32.6
49.9
46.5
4S.O
42.0
32.0
50.0
22.2
Std. LTO
Unregulated EPAP
(uncorrected)
LTOs/Yr
2,600
900
2,500
900
1,300
1,300
1,300
2,600
2,600
1,300
2,600
1,300
2,600
HC
0.37
0.45
0.47
0.20
0.42
0.47
0.52
0.58
0.60
1.3
3.0
1.1
0.12
CO
1.1 .
0.97
1.0
0.86
0.95
1.0
1.2
1.1
1.2
1.7
3.1
1.4
0.78
NOx
0.67
C.46
0.48 5/
0.48
0.64
0.63
0.60
0.56 5/
0.53
0.63
0.30
0.69
0.43
Std LTO
Regulated EPAP
(uncorrected)
HC
0.015
0.021
0.066
0.020
0.027
0.031
0.024
O.Oco
0.066
0.066
0.066
0.066
0.066
I/
6/
&/
6/
CO
0.50 3/
0.30
0.50 7/
0.26
0.50 3/
0.50 3/
0.49
0.50 7/
0.50 7/
0.50 11
6/8/0.50 7/8/
6/
6/
0.50 11
0.50 TJ
NOx
0.324/
0.26
0.32 6/
0.35
0.32 4/
0.32 4/
0.38 4/
0.34 6/
0.36 6/
0.32
NA 9/
0.34 6/
0.326
EPAP
Net
Reduct ion
(uncorrected)
HC
0.35
0.43
0.40
0.18
0.39
0.44
0.60
0.51
0.53
1.23
2.93
1.03
0.05
CO
0.6
0.67
0.5
0.60
0.45
0.5
0.71
0.60
0.70
1.2
2.6
0.90
0.28
NOx
0.35
0.20
0.16
0.13
0.32
0.31
0.22
0.22
0.22
0.31
0
0.35
0.11
Std. LTO
Taxi-idle
Correction
Factor
(HC-CO
10
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
only)
.5
73
73
73
73
73
73
73
73
73
73
73
73
Tons
Annual Reduc
t ion
(corrected)
HC
6.1
6.5
18.2
3.0
7.2
6.S. .
14.2
22.5
24.1
24.5
89.0
24.4
1 . i
CO
10.5
10.2
22.8
!0. 1
8.3
7.7
16 . S
26.5
31.9
23.9
79.0
21.4
5.9
NOx
6.!
3.0
7.3
2.2
5.9
4 S
5.2
0.7
10.0
5.2
0
S.3
:.3
i/ ihe iiC and CO value;; presented in this table are used in scenarios where no previous 1982 standard exists.
~2j No da La. Based on JT8D-17.
J3y Assumed to meet the standard with a 40% increase; compliance not yet demonstrated.
4y Assumed to nect the standard; compliance not yet demonstrated.
_5_/ Eased on thrust ratio of parent and derivative.
fjj ;.'o d.-.ta. Assumed tr. meet the standard with a 40% increase.
TJ No daia. Assured to rceet the standard.
_£/ The RB211-535 nay not require a staged ccrr.bustor, but to simplify the analysis, a staged combustor is
assurr.ed in scenarios which evaluate a 1986 low-NOx standard with no previous 1982 standard.
9/ Not applicable. The uncontrolled RB211-535 meets the standard.
a
-------
H-6
Table H-4
Annual Reduction in Pollutants for Scenario 2
(1982 NMF and 1986 IUE Only)
Engine
JT8D-17
Retro
JT8D-200
JT9D-7
Retro
JT9D-7R
JT9D-70
CF6-6
Retro
CF6-32
CF6-50
Retro
CF6-45
CF6-80
RB211-22B
Retro
RB211-535
RB211-524
CFM56
Total
A
Fractional
Useful Life
. 1
0.47
1
1
0.47
1
1
1
0.47
1
1
0.67
1
1
1
0.47
1
1
1
B
Fract ional
Sales
0
0.13
0.06
0.09
0.05
0.01
0.09
0.06
0.02
0.05
0.15
0.01
0.03
0.01
0.06
0.02
0.05
0.06
0.05
A x B
ZA x B
Sales Weighted
Useful Life
0
0.07
0.07
0.10
0.03
0.01
0.10
0.07
0.01
0.06
0.17
0.01
0.03
0.01
0.07
0.01
0.06
0.06
0.06
Tons
Pol
lutant/
Year
HC
4.6
4.6
5.3
5.9
5.9
18.2
2.7
7.4
7.4
7.0
14.4
14.4
22.5
24.1
25.1
25.1
90.5
25.4
2.3
CO
9.4
9.4
10.9
11.1
11.1
22.8
11.1
12.4
12.4
11.0
19.9
19.9
26.5
31.9
28.3
28.3
79.0
28.0
7.8
Weighted
Annual
Tons
HC CO
0
0.3
0.4
0.6
0.2
0.2
0.3
0.5
0.1
0.4
2.4
0.1
0.7
0.2
1.8
0.2
5.4
1.5
0.1
15.4
0
0.7
0.8
1.1
0.3
0.2
1.1
0.9
0.1
0.7
3.4
0.2
0.8
0.3
2.0
0.3
4.7
1.7
0.5
19.8
-------
H-7
References for Appendix H
Hunt, R. W. 1979. Review of emissions control technology for
aircraft gas turbine engines. Emission Control Technology Divi-
sion, Office of Mobile Source Air Pollution Control, Environmental
Protection Agency, Ann Arbor, MI.
------- |