United States Air and Radiation EPA420-D-02-002
Environmental Protection April 2002
Agency
&EPA Draft Regulatory
Support Document
Control of Emissions from
Compression-Ignition Marine
Diesel Engines At or Above
30 Liters per Cylinder
y£u Printed on Recycled
Paper
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EPA420-D-02-002
April 2002
Draft Regulatory Support Document
Control of Emissions from Compression-Ignition Marine
Diesel Engines At or Above 30 Liters per Cylinder
Assessment and Standards Division
Office of Transportation and Air Quality
U.S. Environmental Protection Agency
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Table of Contents
CHAPTER 1: Introduction 1-1
1.1 Categories of Marine Diesel Engines 1-4
1.2 Proposed Standards 1-4
1.3 Projected Impacts 1-6
CHAPTER 2: Health and Welfare Concerns 2-1
2.1 Ozone 2-1
2.1.1 General Background 2-1
2.1.2 Health and Welfare Effects of Ozone and Its Precursors 2-2
2.1.3 Additional Health and Welfare Effects of NOx Emissions 2-3
2.1.4 Ozone Nonattainment 2-4
2.1.5 Public Health and Welfare Concerns from Prolonged and Repeated
Exposures to Ozone 2-6
2.2 Paniculate Matter 2-7
2.2.1 General Background 2-7
2.2.2 Health and Welfare Effects of PM 2-8
2.2.3 PM Nonattainment 2-10
2.2.4 Diesel Exhaust 2-12
2.3 Carbon Monoxide 2-12
2.4 Other Adverse Public Health and Welfare Effects Associated with Category 3
Marine Diesel Engines 2-13
2.4.1 Nonroad Engines and Regional Haze 2-13
2.4.2 Acid Deposition 2-15
2.4.3 Eutrophication and Nitrification 2-15
2.5 Inventory Contributions 2-16
2.5.1 National Inventory 2-16
2.5.2 Inventories for Specific Ports 2-21
2.5.3 Emissions in Nonport Areas 2-23
2.5.4 Contribution by flag 2-24
CHAPTER 3: Industry Characterization 3-1
3.1 Description of Category 3 Marine Engines 3-1
3.2 Category 3 Marine Engine Manufacturers 3-3
3.2.1 Companies That Make Category 3 Marine Engines 3-3
3.2.2 Production of Category 3 Marine Engines 3-4
3.2.3 Relationship Among Worldwide Engine Manufacturers 3-5
3.3 Vessel Manufacturers 3-6
3.3.1 United States Vessel Manufacturers 3-7
3.3.2 International Vessel Manufacturers 3-16
3.4 U.S. Fleet Characterization 3-16
3.4.1 Background 3-16
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3.4.2 U.S. Fleet 3-16
3.4.3 Foreign Flag Fleet 3-17
3.4.4 Cruise Vessels 3-17
3.5 U.S. Port Activity 3-18
3.5.1 Background 3-18
3.5.2 Cruise Ship Activity 3-21
3.6 Conclusion 3-21
CHAPTER 4: Technological Feasibility 4-1
4.1 Overview of Category 3 Marine Engine Technology 4-1
4.1.1 Diesel Engine Emission Formation in Category 3 Marine Engines 4-1
4.1.2 Category 3 Marine Engine Design and Use 4-3
4.2 General Description of Emission-Control Strategies 4-4
4.2.1 Combustion Optimization 4-4
4.2.2 Improving Charge Air Characteristics 4-7
4.2.3 Exhaust Gas Recirculation 4-8
4.2.4 Fuel Injection 4-9
4.2.5 Electronic Control 4-13
4.2.6 Lube Oil Consumption 4-13
4.2.7 Distillate Fuel 4-14
4.2.8 Emission-Controls and System Approaches 4-14
4.3 Anticipated Technology to Meet Emission Standards 4-16
4.3.1 Tier 1 (Annex VI) Standards 4-16
4.3.2 Additional Tier 2 Standards 4-17
4.4 Impact on Noise, Energy, and Safety 4-18
CHAPTER 5: Estimated Costs 5-1
5.1 Methodology 5-1
5.2 Technology Costs 5-2
5.2.1 Fuel Injection Improvements 5-2
5.2.2 Engine Modifications 5-3
5.2.3 Direct Water Injection 5-5
5.2.4 Selective Catalytic Reduction 5-7
5.2.5 Certification and Compliance 5-11
5.2.6 Fuel Costs 5-11
5.2.7 Sensitivity 5-12
5.3 Total Engine Costs 5-13
5.3.1 Distribution of Category 3 Marine Engines 5-13
5.3.2 Projected Costs for Engines on U.S.-flag Vessels 5-14
5.3.3 Cost Considerations Related to Including Engines on Foreign-Flag Vessel-slS
5.4 Aggregate costs 5-16
CHAPTER 6: Emissions Inventory 6-1
6.1 Baseline Inventories 6-1
6.1.1 Ports Inventories 6-2
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6.1.2 Non-Port Inventories 6-4
6.2 Future Year Baseline Inventory Projections 6-5
6.3 Inventory Effects 6-7
CHAPTER 7: Cost Per Ton 7-1
7.1 Methodology 7-1
7.2 Engine Lifetime Cost per ton of the New Standards 7-2
7.3 Comparison with Cost Per Ton of Other Control Programs 7-3
7.4 20-Year Cost Per Ton 7-5
7.5 Potential Economic Impacts 7-6
7.5.1 Summary of Compliance Costs 7-6
7.5.2 Market Impacts 7-7
CHAPTER 8: Analysis of Alternatives 8-1
8.1 Overview of Alternative Approaches 8-1
8.2 Anticipated Technology for Alternative Approaches 8-1
8.2.1 Water Introduction into the Combustion Process 8-2
8.2.2 Selective Catalytic Reduction 8-4
8.2.3 Fuel Cells 8-7
8.2.4 Low Sulfur Fuel 8-8
8.3 Emissions Inventory 8-9
8.4 Cost per Ton 8-12
8.5 Summary 8-14
Chapter 9: TEST PROCEDURE 9-1
9.1 Proposed Certification Test Procedures 9-1
9.1.1 Duty Cycle 9-1
9.1.2 TestFuel 9-2
9.1.3 Sampling Procedures and Calculations 9-4
9.1.4 Modifications to the Annex VI Test Procedures 9-4
9.2 Shipboard NOx Emission Measurement System 9-5
9.2.1 System Description and Component Specifications 9-6
9.2.2 Emission Targets 9-10
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Chapter 1: Introduction
CHAPTER 1: Introduction
EPA is proposing emission standards for emissions of oxides of nitrogen (NOx),
hydrocarbons (HC), and carbon monoxide (CO) from new marine engines at or above 30 liters
per cylinder on U.S. vessels. This Draft Regulatory Support Document provides technical,
economic, and environmental analyses of the proposed Tier 1 NOx standards and a second tier of
standards currently under consideration of 30 percent below the Tier 1 NOx standards.
Nationwide, these engines contribute to ozone and carbon monoxide nonattainment and to
ambient particulate matter levels, particularly in commercial ports and along coastal areas.
EPA is proposing a first tier of emission controls that is equivalent to the internationally
negotiated oxides of nitrogen standards and would be enforceable under U.S. law for new
engines built in 2004 and later. We are also considering adoption of a second tier of standards,
which reflect additional reductions that can be achieved through engine-based controls, and
would apply to new engines built in 2007 and later.
Chapter 2 reviews information related to the health and welfare effects of the pollutants
of concern. Chapter 3 contains an overview of the affected manufacturers, including engine
manufacturers and ship builders, and a broad description of the range of engines involved and
their place in the market. Chapter 4 summarizes the available information describing the
technologies that could be used to meet both tiers of standards. Chapter 5 applies cost estimates
for the emission controls. Chapter 6 presents the estimated contribution of these engines to the
nationwide emission inventory and discusses the emission reductions that could be achieved by
applying both tiers of standards. Chapter 7 presents the cost effectiveness of the emission
controls. This chapter also includes analysis of the social and economic costs of the rule and
overall environmental benefits. Chapter 8 discusses several alternative approaches we
considered for the standards. These technologies hold out the potential for emission
improvements in the future, after constraints on their application to large ocean-going marine
diesel engines are resolved. Finally, Chapter 9 contains new test procedures for these engines.
The remainder of this Chapter 1 contains the definition of the categories of marine diesel
engines and a summary of our analysis of the benefits and costs of this proposal. It should be
noted that we are not claiming benefits for the proposed Tier 1 standards. These standards have
already been adopted by the international community, although they are not yet enforceable.
Because engine manufacturers are already producing engines that achieve these standards, this
rule will result in emission reductions only to the extent that owners of U.S. vessels are not
currently complying with the standards. The costs of the proposed Tier 1 standards are negligible
and reflect certification and compliance costs only.
Table 1-1 contains a general summary of the per vessel costs, projected emissions
reductions, and cost per ton of pollutant reduced for the various emission standards we
considered for a second tier of NOx limits (all costs are presented in 2002 dollars). These costs
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Draft Regulatory Support Document
should be considered in conjunction with the technical feasibility of the different alternatives as
described in Chapters 4 and 8.
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Table 1-1
Summary of Vessel Costs, Emissions Reductions in 2030, and Cost per Ton
from Category 3 Marine Diesel Engine and Fuel Control Programs (2002 Dollars)
Scenario
30% NOx reduction
below Tier 1 -U.S.
flagged vessels only
30% NOx reduction
below Tier 1 -U.S.
and foreign flagged
vessels
50% NOx reduction
below Tier 1 -U.S.
flagged vessel only
80% NOx reduction
below Tier 1 -U.S.
flagged vessel only
1. 5% S fuel -U.S.
and foreign flagged
vessels
0.3% S fuel -U.S.
and foreign flagged
vessels
Cost per
vessel -
(thousand $)'
$115
$57
$207
$1,014
$50
$50
Increased
operating
costs NPV
(thousand $)
$66
$66
$527
$9,542
$139
$273
NOx
Reduc-
tion
(1000
tons)
56
139
92
148
53
Percent
reduc-
tion
10.5%
26.1%
17.3%
27.9%
10%
Cost per
ton
$145
$1,585
$370
$3,405
__
PM
Reduc-
tion
(1000
tons)
9.7
34
Percent
reduc-
tion
18%
63%
Cost per
ton
$38,066
$32,968
SOx
Reduc-
tion
(1000
tons)
176
356
Percent
reduc-
tion
44%
89%
Cost per
ton
$302
$262
1. These per vessel costs reflect the costs for the first five years of the program. For the technology-based options these costs would go down after five years, as
discussed in Chapter 5.
NOTE: Technological feasibility constraints are not reflected in these costs; refer to Chapters 4 and 8.
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Draft Regulatory Support Document
1.1 Categories of Marine Diesel Engines
In our 1999 commercial marine diesel engine rule, we defined marine engine as an engine
that is installed or intended to be installed on a marine vessel. We also differentiated between
three types of marine diesel engines. As explained in that rule, this approach is necessary
because marine diesel engines are typically derivatives of land-based diesel engines and the land-
based engines are not all subject to the same numerical standards and effective dates. The
definitions for the different categories of marine diesel engines are contained in 40 CFR part 94.2
and are summarized in Table 1.1-1.
Table 1.1-1
Marine Engine Category Definitions
Category
1
2
O
Displacement per cylinder
disp. < 5 liters (and power > 37 kW)
5 < disp. < 30 liters
disp > 30 liters
hp range (kW)
37-2,300
1,500-8,000
2,500 - 80,000
rpm range
1,800-3,000
750- 1,500
80 - 900
1.2 Proposed Standards
Our proposal discusses two tiers of NOx emission controls for these engines. The first
tier is equivalent to the internationally negotiated NOx standards by the International Maritime
Organization (EVIO) in Annex VI to the International Convention on the Prevention of Pollution
from Ships, 1973, as Modified by the Protocol of 1978 Relating Thereto (this convention is also
known as MARPOL; the standards are referred to as the Annex VI NOx limits). These Tier 1
standards would be enforceable under U.S. law for new engines built in 2004 and later.
The second tier of NOx standards under consideration reflect additional reductions that
can be achieved through engine-based emission controls and would apply to new engines built in
2007 and later. We are also considering standards for HC and CO emissions as part of the Tier 2
emission controls to ensure that these emissions do not increase on an engine-specific basis. We
would review the Tier 2 standards prior to their effective date to take into consideration
continued development of new technologies, such as selective catalyst reduction and water-based
emission reduction techniques, and international activity such as action at International Maritime
Organization (EVIO) to set more stringent international standards.
As discussed in greater detail in Chapter 4, both tiers of standards can be met through
engine-based emission-control technologies. The Annex VI NOx limits are based on
certification on distillate fuel, which has a lower nitrogen content than the residual fuel that these
engines are most likely to use in operation. We are proposing numerical emission limits based
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Chapter 1: Introduction
on residual fuel, but allow for certification testing using distillate or residual fuel. In either case,
we are proposing that the test results be adjusted to account for the nitrogen content of the fuel,
and then be compared to the proposed emission limits. The fuel quality adjustment is described
in Section IV.A.2 of the preamble for this rule.
Table 1.2-1: Emission Limits for
Category 3 NOx Emission Limits (g/kW-hr)*
Engine Speed (n)
Tierl
Tier 2 standards under
consideration
Blue Sky
n > 130 rpm**
49.5 xn02
31.5xn-°2+1.4
9.0xn-°-2+1.4
n< 130 rpm
18.7
13.3
4.8
*The proposed regulations specify emission standards based on testing with
measured emission values corrected to take into account the nitrogen content of the
fuel. Emission values are corrected to values consistent with testing engines with
fuel containing 0.4 weight percent nitrogen. Testing with fuel containing 0.2
weight-percent nitrogen (typical for in-use distillate marine fuels) would have a
correction of 1.4 g/kW-hr, so the proposed Tier 1 NOx standards would match the
Annex VI NOx standards at this test point.
**No cap would apply to Category 3 engines over 2000 rpm, because these engines
all have engine speeds well below that speed.
We are not proposing a standard for particulate emissions from these engines because
most of the particulate emissions are a result of the high sulfur and ash content of the fuel used
by these engines and because there is no acceptable measurement procedure for fuels with these
characteristics. Potential PM reductions can be obtained, however, by setting a fuel sulfur
content limit for the fuels used by these engines. One option, for example, would be to set a
sulfur content cap equivalent to the limit for fuel used in SOx Emission Control Areas provided
in Regulation 14 of MARPOL Annex VI. Pursuant to that regulation, the sulfur content of fuel
used by vessels operating in those areas cannot exceed 15,000 ppm. For comparison, the sulfur
content of highway diesel fuel is 500 ppm, to be reduced to 15 ppm in 2007. The sulfur content
of nonroad diesel fuel is between 2,000 and 3,000 ppm. Additional discussion of this alternative
can be found in Chapter 4 of this document.
We are also proposing voluntary low emission NOx standards for Category 3 marine
diesel engines. These standards, which represent an 80 percent reduction from the Annex VI
NOx limits, are intended to encourage the introduction and more widespread use of low-emission
technologies. A discussion of technologies that can be used to achieve these voluntary limits, as
well as other approaches we considered for this proposal, can be found in Chapter 8 of this
document.
To implement these standards for marine diesel engines at or above 30 liters per cylinder
in an effective way, we are proposing several compliance requirements. These requirements are
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Draft Regulatory Support Document
discussed in more detail in Section V of the preamble for this rule. In general, the proposed
compliance program reflects our traditional manufacturer-based approach. This is in contrast to
the international approach reflected in Annex VI, which holds the vessel owner responsible for
compliance once the engine is delivered onboard. We have attempted to propose compliance
requirements that are sufficiently consistent with Annex VI that manufacturers would be able to
use a single harmonized compliance strategy to certify under both systems. However, the Clean
Air Act specifies certain requirements for our compliance program that are different from the
Annex VI requirements.
Many of the proposed compliance provisions, including certification application, engine
labeling, and warranty requirements, are similar or identical to the compliance provisions that we
finalized in our 1999 rulemaking. In addition, we are including a post-installation verification
provision which would require an emission test after an engine is installed on a vessel. We are
also proposing a field measurement provision that would apply to engines with adjustable
parameters or add-on emission control devices. Manufacturers of these engines would be
required to equip the engine with a field measurement device. The owner of a vessel with such
an engine would have to perform a field measurement when the vessel approaches within 175
nautical miles of the U.S. coastline from the open sea or when it adjusts an engine parameter
within that distance. The results of this field measurement will demonstrate that the engine is in
compliance with the relevant standards when it is operated in an area that affects U.S. air quality.
The field measurement procedure and other testing issues are discussed in Chapter 9.
1.3 Projected Impacts
Because the Tier 1 standards are equivalent to the internationally negotiated NOx limits
for these engines, we are not claiming any emission reductions from adopting these standards.
The proposed Tier 1 standards have already been adopted by the international community,
although they are not yet enforceable. Because engine manufacturers are already producing
engines that achieve these standards, this rule will result in emission reductions only to the extent
that owners of U.S. vessels are not currently complying with the standards. The costs of the
proposed Tier 1 standards are negligible and reflect certification and compliance costs only.
The following paragraphs and tables summarize the projected emission reductions and
costs associated a second tier of emission standards under consideration. See the detailed
analysis later in this document for further discussion of these estimates as well as estimates for
the alternative regulatory approaches we considered. Table 1.3-1 contains the projected
emissions from the engines subject to this proposal.
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Chapter 1: Introduction
Table 1.3-1
Category 3 Marine Vessel NOx National Emissions Inventories
Tier 1 (Baseline - thousand short tons)
Tier 2 under
consideration -
30% below
Tierl
Control (thousand short tons)
Percent reduction (relative to Tier 1)
1996
190
190
—
2010
274
269
2.0%
2020
367
343
6.8%
2030
531
475
10.5%
2050
1319
1168
11.5%
Table 1.3-2 summarizes the projected costs to meet a second tier of emission standards.
This is our best estimate of the cost associated with adopting the technologies to meet such a
second tier of emission standards. The analysis projects that engines will not have increased
operating costs to meet such a second tier of emission standards. The same manufacturers
produce engines used in U.S. and foreign-flagged vessels. In addition, the majority of the vessels
visiting the U.S. are foreign flagged. Therefore, we do not estimate separate costs for applying
such a second tier of standards to foreign flagged vessels only.
Table 1.3-2
Summary of Projected Costs to Meet Second Tier of Emission Standards
(30% Below Tier 1)*
Time Frame
Medium-speed Engines
6cyl.
9cyl.
12 cyl.
Slow-speed Engines
4 cyl.
8 cyl.
12 cyl.
U.S.-flag only
Total cost per engine
(yr. 1)
Total cost per engine
(yr. 6 and later)
Annual operating costs
$93,587
$25,452
$5,000
$98,977
$28,902
$5,000
$104,368
$32,352
$5,000
$106,414
$33,661
$5,000
$129,723
$48,579
$5,000
$153,031
$63,496
$5,000
Including foreign-flag (or foreign-flag only)
Total cost per engine
(yr. i)
Total cost per engine
(yr. 6 and later)
Annual operating costs
$35,970
$25,452
$5,000
$41,360
$28,902
$5,000
$46,751
$32,352
$5,000
$48,797
$33,661
$5,000
$72,106
$48,579
$5,000
$95,414
$63,496
$5,000
*A11 costs are in 2002 dollars.
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Draft Regulatory Support Document
We also calculated the cost per ton of emission reductions for a second tier of emission
standards. We attributed the entire cost of such standards to the control of NOx, as summarized
in Table 1.3-3.
Table 1.3-3
Cost Per Ton of Second Tier of Emission Standards 30% Below Tier 1
Model Year
Grouping
NPV Benefits
(short tons)
NPV Operating
Costs
Engine & Vessel
Costs
Discounted Cost
Per Ton
U.S.-flag only
Ito5
6 +
1149
$66,000
$115,000
$39,000
$145
$87
Foreign-flag only
Ito5
6 +
45
$66,000
$57,000
$39,000
$2,590
$2,235
All Vessels
Ito5
6 +
73
$66,000
$57,000
$39,000
$1,585
$1,368
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Chapter 1: Introduction
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Chapter 2: Health and Welfare Concerns
CHAPTER 2: Health and Welfare Concerns
The engines and vehicles that would be subject to the proposed standards generate
emissions of NOx, PM, HC and CO that contribute to ozone and CO nonattainment as well as
adverse health effects associated with ambient concentrations of PM. This section summarizes
the general health effects of these substances. In it, we present information about these health
and environmental effects, air quality modeling results, and inventory estimates in the absence of
emissions controls.
2.1 Ozone
2.1.1 General Background
Ground-level ozone, the main ingredient in smog, is formed by complex chemical
reactions of volatile organic compounds (VOC) and NOx in the presence of heat and sunlight.
Ozone forms readily in the lower atmosphere, usually during hot summer weather. Oxides of
nitrogen are emitted largely from motor vehicles, off-highway equipment, power plants, and
other sources of combustion. Volatile organic compounds are emitted from a variety of sources,
including motor vehicles, chemical plants, refineries, factories, consumer and commercial
products, and other industrial sources. Volatile organic compounds also are emitted by natural
sources such as vegetation. Hydrocarbons (HC) are a large subset of VOC, and to reduce mobile
source VOC levels we set maximum emissions limits for hydrocarbons.
The science of ozone formation, transport, and accumulation is complex. Ground-level
ozone is produced and destroyed in a cyclical set of chemical reactions involving NOx, VOC,
heat, and sunlight.1 As a result, differences in weather patterns, as well as NOx and VOC levels,
contribute to daily, seasonal, and yearly differences in ozone concentrations and differences from
city to city. Many of the chemical reactions that are part of the ozone-forming cycle are sensitive
to temperature and sunlight. When ambient temperatures and sunlight levels remain high for
several days and the air is relatively stagnant, ozone and its precursors can build up, resulting in
higher ambient ozone levels than typically would occur on a single high temperature day.
Further complicating matters, ozone also can be transported into an area from pollution sources
found hundreds of miles upwind, resulting in elevated ozone levels even in areas with low local
NOx or VOC emissions.
On the chemical level, NOx and VOC are the principal precursors to ozone formation.
The highest levels of ozone are produced when both VOC and NOx emissions are present in
significant quantities on clear summer days. Relatively small amounts of NOx enable ozone to
form rapidly when VOC levels are relatively high, but ozone production is quickly limited by
removal of the NOx. Under these conditions, NOx reductions are highly effective in reducing
ozone while VOC reductions have little effect. Such conditions are called "NOx limited."
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Draft Regulatory Support Document
Because the contribution of VOC emissions from biogenic (natural) sources to local ambient
ozone concentrations can be significant, even some areas where man-made VOC emissions are
relatively low can be NOx limited.
When NOx levels are relatively high and VOC levels relatively low, NOx forms
inorganic nitrates but relatively little ozone. Such conditions are called "VOC limited." Under
these conditions, VOC reductions are effective in reducing ozone, but NOx reductions can
actually increase local ozone under certain circumstances. Even in VOC limited urban areas,
NOx reductions are not expected to increase ozone levels if the NOx reductions are sufficiently
large.
Rural areas are almost always NOx limited, due to the relatively large amounts of
biogenic VOC emissions in such areas. Urban areas can be either VOC or NOx limited, or a
mixture of both.
Ozone concentrations in an area also can be lowered by the reaction of nitric oxide with
ozone, forming nitrogen dioxide (NO2); as the air moves downwind and the cycle continues, the
NO2 forms additional ozone. The importance of this reaction depends, in part, on the relative
concentrations of NOx, VOC, and ozone, all of which change with time and location.
2.1.2 Health and Welfare Effects of Ozone and Its Precursors
Based on a large number of recent studies, EPA has identified several key health effects
caused when people are exposed to levels of ozone found today in many areas of the country.2'3
Short-term exposures (1-3 hours) to high ambient ozone concentrations have been linked to
increased hospital admissions and emergency room visits for respiratory problems. For example,
studies conducted in the northeastern U.S. and Canada show that ozone air pollution is associated
with 10-20 percent of all of the summertime respiratory-related hospital admissions. Repeated
exposure to ozone can make people more susceptible to respiratory infection and lung
inflammation and can aggravate preexisting respiratory diseases, such as asthma. Prolonged (6
to 8 hours), repeated exposure to ozone can cause inflammation of the lung, impairment of lung
defense mechanisms, and possibly irreversible changes in lung structure, which over time could
lead to premature aging of the lungs and/or chronic respiratory illnesses such as emphysema and
chronic bronchitis.
Children and outdoor workers are most at risk from ozone exposure because they
typically are active outside during the summer when ozone levels are highest. For example,
summer camp studies in the eastern U.S. and southeastern Canada have reported significant
reductions in lung function in children who are active outdoors. Further, children are more at
risk than adults from ozone exposure because their respiratory systems are still developing.
Adults who are outdoors and are moderately active during the summer months, such as
construction workers and other outdoor workers, also are among those most at risk. These
individuals, as well as people with respiratory illnesses such as asthma, especially asthmatic
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Chapter 2: Health and Welfare Concerns
children, can experience reduced lung function and increased respiratory symptoms, such as
chest pain and cough, when exposed to relatively low ozone levels during prolonged periods of
moderate exertion.
Evidence also exists of a possible relationship between daily increases in ozone levels
and increases in daily mortality levels. While the magnitude of this relationship is too uncertain
to allow for direct quantification, the full body of evidence indicates the possibility of a positive
relationship between ozone exposure and premature mortality.
In addition to human health effects, ozone adversely affects crop yield, vegetation and
forest growth, and the durability of materials. Because ground-level ozone interferes with the
ability of a plant to produce and store food, plants become more susceptible to disease, insect
attack, harsh weather and other environmental stresses. Ozone causes noticeable foliage damage
in many crops, trees, and ornamental plants (i.e., grass, flowers, shrubs) and causes reduced
growth in plants. Studies indicate that current ambient levels of ozone are responsible for
damage to forests and ecosystems (including habitat for native animal species). Ozone
chemically attacks elastomers (natural rubber and certain synthetic polymers), textile fibers and
dyes, and, to a lesser extent, paints. For example, elastomers become brittle and crack, and dyes
fade after exposure to ozone.
2.1.3 Additional Health and Welfare Effects of NOx Emissions
In addition to their role as an ozone precursor, NOx emissions are associated with a wide
variety of other health and welfare effects.4 5 Nitrogen dioxide can irritate the lungs and lower
resistance to respiratory infection (such as influenza). NOx emissions are an important precursor
to acid rain that may affect both terrestrial and aquatic ecosystems. Atmospheric deposition of
nitrogen leads to excess nutrient enrichment problems ("eutrophication") in the Chesapeake Bay
and several nationally important estuaries along the East and Gulf Coasts. Eutrophication can
produce multiple adverse effects on water quality and the aquatic environment, including
increased algal blooms, excessive phytoplankton growth, and low or no dissolved oxygen in
bottom waters. Eutrophication also reduces sunlight, causing losses in submerged aquatic
vegetation critical for healthy estuarine ecosystems. Deposition of nitrogen-containing
compounds also affects terrestrial ecosystems. Nitrogen fertilization can alter growth patterns
and change the balance of species in an ecosystem. In extreme cases, this process can result in
nitrogen saturation when additions of nitrogen to soil over time exceed the capacity of plants and
microorganisms to utilize and retain the nitrogen. These environmental impacts are discussed
further in Sections 2.6.4 and 2.6.5, below.
Elevated levels of nitrates in drinking water pose significant health risks, especially to
infants. Studies have shown that a substantial rise in nitrogen levels in surface waters are highly
correlated with human-generated inputs of nitrogen in those watersheds.6 These nitrogen inputs
are dominated by fertilizers and atmospheric deposition. Nitrogen dioxide and airborne nitrate
also contribute to pollutant haze, which impairs visibility and can reduce residential property
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Draft Regulatory Support Document
values and the value placed on scenic views.
2.1.4 Ozone Nonattainment
The current primary and secondary ozone National Ambient Air Quality Standard
(NAAQS) is 0.12 ppm daily maximum 1-hour concentration, not to be exceeded more than once
per year on average. The determination that an area is at risk of exceeding the ozone standard in
the future was made for all areas with current design values greater than or equal to 0.125 ppm
(or within a 10 percent margin) and with modeling evidence that exceedances will persist into the
future.
Ground level ozone today remains a pervasive pollution problem in the United States. In
1999, 90.8 million people (1990 census) lived in 31 areas designated nonattainment under the 1-
hour ozone NAAQS.7 This sharp decline from the 101 nonattainment areas originally identified
under the Clean Air Act Amendments of 1990 demonstrates the effectiveness of the last decade's
worth of emission-control programs. However, elevated ozone concentrations remain a serious
public health concern throughout the nation.
Over the last decade, declines in ozone levels were found mostly in urban areas, where
emissions are heavily influenced by controls on mobile sources and their fuels. Twenty-three
metropolitan areas have realized a decline in ozone levels since 1989, but at the same time ozone
levels in 11 metropolitan areas with 7 million people have increased.8 Regionally, California and
the Northeast have recorded significant reductions in peak ozone levels, while four other regions
(the Mid-Atlantic, the Southeast, the Central and Pacific Northwest) have seen ozone levels
increase. The highest ambient concentrations are currently found in suburban areas, consistent
with downwind transport of emissions from urban centers. Concentrations in rural areas have
risen to the levels previously found only in cities.
To estimate future ozone levels, we refer to the modeling performed in conjunction with
the final rule for our most recent heavy-duty highway engine and fuel standards.9 We performed
a series of ozone air quality modeling simulations for nearly the entire Eastern U.S. covering
metropolitan areas from Texas to the Northeast.10 This ozone air quality model was based upon
the same modeling system as was used in the air quality analysis for Tier 2 standards for light-
duty vehicles and light-duty trucks, with the addition of updated inventory estimates for 2007 and
2030. The model simulations were performed for several emission scenarios, and the model
outputs were combined with current air quality data to identify areas expected to exceed the
ozone NAAQS in 2007, 2020, and 2030.n The results of this modeling are contained in Table
2.1-1. Areas presented in Table 2.1-1 have 1997-99 air quality data indicating violations of the
1-hour ozone NAAQS, or are within 10 percent of the standard, are predicted to have exceedance
in 2007, 2020, or 2030. An area was considered likely to have future exceedances if exceedances
were predicted by the model, and the area is currently violating the 1-hour standard, or is within
10 percent of violating the 1-hour standard. Table 2.1-1 shows that 37 areas with a 1999
population of 91 million people are at risk of exceeding the 1-hour ozone standard in 2007.
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Chapter 2: Health and Welfare Concerns
Table 2.1-1: Eastern Metropolitan Areas with Modeled Exceedances of the 1-Hour Ozone
Standard in 2007, 2020, or 2030 (Includes all emission controls through HD07 standards)
MSA or CMSA / State
Atlanta, GA MSA
Barnstable-Yarmouth, MA MSA *
Baton Rouge, LA MSA
Beaumont-Port Arthur, TX MSA
Benton Harbor, MI MSA *
Biloxi-Gulfport-Pascagoula, MS MSA *
Birmingham, AL MSA
Boston-Worcester-Lawrence, MA CMSA
Charleston, WV MSA *
Charlotte-Gastonia-Rock Hill, NC MSA
Chicago-Gaiy-Kenosha, IL CMSA
Cincinnati-Hamilton, OH-KY-IN CMSA *
Cleveland-Akron, OH CMSA *
Detroit- Ann Arbor-Flint, MI CMSA
Grand Rapids-Muskegon-Holland, MI MSA*
Hartford, CT MSA
Houma, LA MSA *
Houston-Galveston-Brazoria, TX CMSA
Huntington-Ashland, WV-KY-OH MSA
Lake Charles, LA MSA *
Louisville, KY-IN MSA
Macon, GA MSA
Memphis, TN-AR-MS MSA
Milwaukee-Racine, WI CMSA
Nashville, TN MSA
New London-Norwich, CT-RI MSA
New Orleans, LA MSA *
New York-Northern NJ-Long Island, NY-NJ-
CT-PA CMSA
Norfolk- Virginia Beach-Newport News, VA-
NC MSA *
Orlando, FL MSA *
Pensacola, FL MSA
Philadelphia- Wilmington-Atlantic City, PA-NJ-
DE-MD CMSA
Providence-Fall River-Warwick,RI-MAMSA*
Richmond-Petersburg, VA MSA
St. Louis, MO-IL MSA
Tampa-St. Petersburg, FL MSA *
Washington-Baltimore
Total number of areas
Pnniilatinn
2007 2020 2030 pop (1999)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
37
Q1 9
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
32
88 S
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
32
87 8
3.9
0.2
0.6
0.4
0.2
0.3
0.9
5.7
0.3
1.4
8.9
1.9
2.9
5.4
1.1
1.1
0.2
4.5
0.3
0.2
1
0.3
1.1
1.7
1.2
0.3
1.3
20.2
1.6
1.5
0.4
6
1.1
1
2.6
2.3
7.4
Q1 4
* These areas have registered 1997-1999 ozone concentrations within 10 percent of standard.
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With regard to future ozone levels, our photochemical ozone modeling for 2020 predicts
exceedances of the 1-hour ozone standard in 32 areas with a total of 89 million people (1999
census; see Table 2.1-1). We expect that the control strategies contained in this proposal for
Category 3 marine diesel engines will further assist state efforts already underway to attain and
maintain the 1-hour ozone standard.
The inventories that underlie this predictive modeling for 2020 and 2030 include
reductions from all current and committed to federal, state and local control programs, including
the recently promulgated NOx and PM standards for heavy-duty vehicles and low sulfur diesel
fuel. The geographic scope of these areas at risk of future exceedances underscores the need for
additional, nationwide controls of ozone precursors.
It should be noted that this modeling did not attempt to examine the prospect of areas
attaining or maintaining the ozone standard with possible future controls (i.e., controls beyond
current or committed federal, State and local controls). Therefore, this information should be
interpreted as indicating what areas are at risk of ozone violations in 2007, 2020 or 2030 without
federal or state measures that may be adopted and implemented in the future. We expect many of
these areas to adopt additional emission reduction programs, but we are unable to quantify or rely
upon future reductions from additional State programs since they have not yet been adopted.
2.1.5 Public Health and Welfare Concerns from Prolonged and Repeated Exposures to
Ozone
In addition to the health effects described above, there exists a large body of scientific
literature that shows that harmful effects can occur from sustained levels of ozone exposure
much lower than 0.125 ppm. Studies of prolonged exposures, those lasting about 7 hours,
showed health effects from exposures to ozone concentrations as low as 0.08 ppm. Prolonged
and repeated exposures to ozone at these levels are common in areas that do not attain the 1-hour
NAAQS, and also occur in areas where ambient concentrations of ozone are in compliance with
the 1-hour NAAQS.
Prolonged exposure to levels of ozone below the NAAQS have been reported to cause or
be statistically associated with transient pulmonary function responses, transient respiratory
symptoms, effects on exercise performance, increased airway responsiveness, increased
susceptibility to respiratory infection, increased hospital and emergency room visits, and transient
pulmonary respiratory inflamation. Such acute health effects have been observed following
prolonged exposures at moderate levels of exertion at concentrations of ozone as low as 0.08
ppm, the lowest concentration tested. The effects are more pronounced as concentrations
increase, affecting more subjects or having a greater effect on a given subject in terms of
functional changes or symptoms. A detailed summary and discussion of the large body of ozone
health effects research may be found in Chapters 6 through 9 (Volume 3) of the 1996 Criteria
Document for ozone.12 Monitoring data indicates that 333 counties in 33 states exceed these
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Chapter 2: Health and Welfare Concerns
levels in 1997-99.13
To provide a quantitative estimate of the projected number of people anticipated to reside
in areas in which ozone concentrations are predicted to exceed the 8-hour level of 0.08 to 0.12
ppm or higher for multiple days, we performed regional modeling using the variable-grid Urban
Airshed Model (UAM-V).14 UAM-V is a photochemical grid model that numerically simulates
the effects of emissions, advection, diffusion, chemistry, and surface removal processes on
pollutant concentrations within a 3-dimensional grid. As with the previous modeling analysis,
the inventories that underlie this predictive modeling include reductions from all current and
committed to federal, state and local control programs, including the recently promulgated NOx
and PM standards for heavy-duty vehicles and low sulfur diesel fuel. This modeling forecast that
111 million people are predicted to live in areas that areas at risk of exceeding these moderate
ozone levels for prolonged periods of time in 2020 after accounting for expected inventory
reductions due to controls on light- and heavy-duty on-highway vehicles; that number is expected
to increase to 125 million in 2030.15 Prolonged and repeated ozone concentrations at these levels
are common in areas throughout the country, and are found both in areas that are exceeding, and
areas that are not exceeding, the 1-hour ozone standard. Areas with these high concentrations are
more widespread than those in nonattainment for that 1-hour ozone standard.
Ozone at these levels can have other welfare effects, with damage to plants being of most
concern. Plant damage affects crop yields, forestry production, and ornamentals. The adverse
effect of ozone on forests and other natural vegetation can in turn cause damage to associated
ecosystems, with additional resulting economic losses. Prolonged ozone concentrations of 0.10
ppm can be phytotoxic to a large number of plant species, and can produce acute injury and
reduced crop yield and biomass production. Ozone concentrations within the range of 0.05 to
0.10 ppm have the potential over a longer duration of creating chronic stress on vegetation that
can result in reduced plant growth and yield, shifts in competitive advantages in mixed
populations, decreased vigor, and injury. Ozone effects on vegetation are presented in more
detail in Chapter 5, Volume II of the 1996 Criteria Document.
2.2 Particulate Matter
2.2.1 General Background
Particulate pollution is a problem affecting urban and non-urban localities in all regions
of the United States. Category 3 marine diesel engines that would be subject to the proposed
standards contribute to ambient particulate matter (PM) levels.
Particulate matter represents a broad class of chemically and physically diverse
substances. It can be principally characterized as discrete particles that exist in the condensed
(liquid or solid) phase spanning several orders of magnitude in size. All particles equal to and
less than 10 microns are called PM10. Fine particles can be generally defined as those particles
with an aerodynamic diameter of 2.5 microns or less (also known as PM25), and coarse fraction
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particles are those particles with an aerodynamic diameter greater than 2.5 microns, but equal to
or less than a nominal 10 microns.
Manmade emissions that contribute to airborne particulate matter result principally from
combustion sources (stationary and mobile sources) and fugitive emissions from industrial
processes and non-industrial processes (such as roadway dust from paved and unpaved roads,
wind erosion from cropland, construction, etc.). Human-generated sources of particles include a
variety of stationary sources (including power generating plants, industrial operations,
manufacturing plants, waste disposal) and mobile sources (light- and heavy-duty on-road
vehicles, and off-highway vehicles such as construction, farming, industrial, locomotives, marine
vessels and other sources). Natural sources also contribute to particulate matter in the
atmosphere and include sources such as wind erosion of geological material, sea spray, volcanic
emissions, biogenic emanation (e.g., pollen from plants, fungal spores), and wild fires.
The chemical and physical properties of PM vary greatly with time, region, meteorology,
and source category. Particles may be emitted directly to the atmosphere (primary particles) or
may be formed by transformations of gaseous emissions of sulfur dioxide, nitrogen oxides or
volatile organic compounds (secondary particles). Secondary PM is dominated by sulfate in the
eastern U.S. and nitrate in the western U.S.16 The vast majority (>90 percent) of the direct
mobile source PM emissions and their secondary formation products are in the fine PM size
range. Mobile sources can reasonably be estimated to contribute to ambient secondary nitrate
and sulfate PM in proportion to their contribution to total NOx and SOx emissions.
Table 2.2-1: Percent Contribution to PM2 s by Component, 1998
Sulfate
Elemental Carbon
Organic Carbon
Nitrate
Crustal Material
East
56
5
27
5
7
West
33
6
36
8
17
Source: National Air Quality and Emissions Trends Report, 1998, March, 2000, at 28. This document is
available at http://www.epa. gov/oar/aqtrnd98/. Relevant pages of this report can be found in Memorandum
to Air Docket A-2000-01 from Jean Marie Revelt, September 5, 2001, Document No. II-A-63.
2.2.2 Health and Welfare Effects of PM
Particulate matter can adversely affect human health and welfare. Discussions of the
health and welfare effects associated with ambient PM can be found in the Air Quality Criteria
for Particulate Matter.17
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Chapter 2: Health and Welfare Concerns
Key EPA findings regarding the health risks posed by ambient PM are summarized as
follows:
a. Health risks posed by inhaled particles are affected both by the penetration and deposition
of particles in the various regions of the respiratory tract, and by the biological responses
to these deposited materials.
b. The risks of adverse effects associated with deposition of ambient particles in the thorax
(tracheobronchial and alveolar regions of the respiratory tract) are markedly greater than
for deposition in the extrathoracic (head) region. Maximum particle penetration to the
thoracic regions occurs during oronasal or mouth breathing.
c. Published studies have found statistical associations between PM and several key health
effects, including premature death; aggravation of respiratory and cardiovascular disease,
as indicated by increased hospital admissions and emergency room visits, school
absences, work loss days, and restricted activity days; changes in lung function and
increased respiratory symptoms; changes to lung tissues and structure; and altered
respiratory defense mechanisms. Most of these effects have been consistently associated
with ambient PM concentrations, which have been used as a measure of population
exposure, in a large number of community epidemiological studies. Additional
information and insights on these effects are provided by studies of animal toxicology and
controlled human exposures to various constituents of PM conducted at higher than
ambient concentrations. Although mechanisms by which particles cause effects are not
well known, there is general agreement that the cardio-respiratory system is the major
target of PM effects.
d. Based on a qualitative assessment of the epidemiological evidence of effects associated
with PM for populations that appear to be at greatest risk with respect to particular health
endpoints, we have concluded the following with respect to sensitive populations:
1. Individuals with respiratory disease (e.g., chronic obstructive pulmonary disease,
acute bronchitis) and cardiovascular disease (e.g., ischemic heart disease) are at
greater risk of premature mortality and hospitalization due to exposure to ambient
PM.
2. Individuals with infectious respiratory disease (e.g., pneumonia) are at greater risk
of premature mortality and morbidity (e.g., hospitalization, aggravation of
respiratory symptoms) due to exposure to ambient PM. Also, exposure to PM
may increase individuals' susceptibility to respiratory infections.
3. Elderly individuals are also at greater risk of premature mortality and
hospitalization for cardiopulmonary problems due to exposure to ambient PM.
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Draft Regulatory Support Document
4. Children are at greater risk of increased respiratory symptoms and decreased lung
function due to exposure to ambient PM.
5. Asthmatic individuals are at risk of exacerbation of symptoms associated with
asthma, and increased need for medical attention, due to exposure to PM.
e. There are fundamental physical and chemical differences between fine and coarse fraction
particles. The fine fraction contains acid aerosols, sulfates, nitrates, transition metals,
diesel exhaust particles, and ultra fine particles; the coarse fraction typically contains high
mineral concentrations, silica and resuspended dust. It is reasonable to expect that
differences may exist in both the nature of potential effects elicited by coarse and fine PM
and the relative concentrations required to produce such effects. Both fine and coarse
particles can accumulate in the respiratory system. Exposure to coarse fraction particles
is primarily associated with the aggravation of respiratory conditions such as asthma.
Fine particles are closely associated with health effects such as premature death or
hospital admissions, and for cardiopulmonary diseases.
With respect to welfare or secondary effects, fine particles have been clearly associated
with the impairment of visibility over urban areas and large multi-State regions. Particles also
contribute to soiling and materials damage. Components of paniculate matter (e.g., sulfuric or
nitric acid) also contribute to acid deposition, nitrification of surface soils and water
eutrophication of surface water.
2.2.3 PM Nonattainment
The NAAQS for PM10 was established in 1987. According to these standards, the short
term (24-hour) standard of 150 //g/m3 is not to be exceeded more than once per year on average
over three years. The long-term standard specifies an expected annual arithmetic mean not to
exceed 50 //g/m3 over three years.
Recent PM10 monitoring data indicate that 14 designated PM10 nonattainment areas with a
projected population of 23 million violated the PM10 NAAQS in the period 1997-1999. Table
2.2-2 lists the 14 areas, and also indicates the PM10 nonattainment classification, and 1999
projected population for each PM10 nonattainment area. The projected population in 1999 was
based on 1990 population figures which were then increased by the amount of population growth
in the county from 1990 to 1999.
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Chapter 2: Health and Welfare Concerns
Table 2.2-2: PM,0 Nonattainment Areas Violating the PM,0 NAAQS in 1997- 1999
Nonattainment Area or County
Anthony, NM (Moderate)8
Clark Co [Las Vegas], NV (Serious)
Coachella Valley, CA (Serious)
El Paso Co, TX (Moderate) A
Hay den/Mi ami, AZ (Moderate)
Imperial Valley, CA (Moderate)
Los Angeles South Coast Air Basin, CA (Serious)
Nogales, AZ (Moderate)
Owens Valley, CA (Serious)
Phoenix, AZ (Serious)
San Joaquin Valley, CA (Serious)
Searles Valley, CA (Moderate)
Wallula, WA (Moderate)8
Washoe Co [Reno], NV (Moderate)
Total Areas: 14
1999 Population
fnroiected. in millions")
0.003
1.200
0.239
0.611
0.004
0.122
14.352
0.025
0.018
2.977
3.214
0.029
0.052
0.320
23 167
A EPA has determined that continuing PM10 nonattainment in El Paso, TX is attributable to transport under
section 179(B).
B The violation in this area has been determined to be attributable to natural events under section 188(f) of
the Act.
In addition to the 14 PM10 nonattainment areas that are currently violating the PM10
NAAQS listed in Table 2.2-2, there are 25 unclassifiable areas that have recently recorded
ambient concentrations of PM10 above the PM10 NAAQS. EPA adopted a policy in 1996 that
allows areas with PM10 exceedances that are attributable to natural events to retain their
designation as unclassifiable if the State is taking all reasonable measures to safeguard public
health regardless of the sources of PM10 emissions. Areas that remain unclassifiable areas are not
required under the Clean Air Act to submit attainment plans, but we work with each of these
areas to understand the nature of the PM10 problem and to determine what best can be done to
reduce it. With respect to the monitored violations reported in 1997-99 in the 25 areas
designated as unclassifiable, we have not yet excluded the possibility that factors such as a one-
time monitoring upset or natural events, which ordinarily would not result in an area being
designated as nonattainment for PM10, may be responsible for the problem.
Current 1999 PM25 monitored values, which cover about a third of the nation's counties,
indicate that at least 40 million people live in areas where long-term ambient fine particulate
matter levels are at or above 16 //g/m3 (37 percent of the population in the areas with monitors).18
This 16 //g/m3 threshold is the low end of the range of long term average PM2 5 concentrations in
cities where statistically significant associations were found with serious health effects, including
premature mortality.19 To estimate the number of people who live in areas where long-term
ambient fine particulate matter levels are at or above 16 //g/m3 but for which there are no
monitors, we can use modeling. According to our national modeled predictions, there were a
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total of 76 million people (1996 population) living in areas with modeled annual average PM25
concentrations at or above 16 //g/m3 (29 percent of the population).20
To estimate future PM25 levels, we refer to the modeling performed in conjunction with
the final rule for our most recent heavy-duty highway engine and fuel standards using EPA's
Regulatory Model System for Aerosols and Deposition (REMSAD).21 The most appropriate
method of making these projections relies on the model to predict changes between current and
future states. Thus, we have estimated future conditions only for the areas with current PM2 5
monitored data (which covers about a third of the nation's counties). For these counties,
REMSAD predicts the current level of 37 percent of the population living in areas where fine PM
levels are at or above 16 //g/m3 to increase to 49 percent in 2030.22
2.2.4 Diesel Exhaust
Diesel emissions are of concern beyond their contribution to ambient PM. As discussed
in detail in the draft RSD, there have been health studies specific to diesel exhaust emissions
which indicate potential hazards to human health that appear to be specific to this emissions
source. For chronic exposure, these hazards included respiratory system toxicity and
carcinogenicity. Acute exposure also causes transient effects (a wide range of physiological
symptoms stemming from irritation and inflammation mostly in the respiratory system) in
humans though they are highly variable depending on individual human susceptibility. The
chemical composition of diesel exhaust includes several hazardous air pollutants, or air toxics.
In our Mobile Source Air Toxic Rulemaking under section 202(1) of the Act, we determined that
diesel particulate matter and diesel exhaust organic gases be identified as a Mobile Source Air
Toxic (MSAT).23 The purpose of the MS AT list is to provide a screening tool that identifies
compounds emitted from motor vehicles or their fuels for which further evaluation of emissions
controls is appropriate.
2.3 Carbon Monoxide
Carbon monoxide (CO) is a colorless, odorless gas produced through the incomplete
combustion of carbon-based fuels. Carbon monoxide enters the bloodstream through the lungs
and reduces the delivery of oxygen to the body's organs and tissues. The health threat from CO
is most serious for those who suffer from cardiovascular disease, particularly those with angina
or peripheral vascular disease. Healthy individuals also are affected, but only at higher CO
levels. Exposure to elevated CO levels is associated with impairment of visual perception, work
capacity, manual dexterity, learning ability and performance of complex tasks.
High concentrations of CO generally occur in areas with elevated mobile-source
emissions. Peak concentrations typically occur during the colder months of the year when
mobile-source CO emissions are greater and nighttime inversion conditions are more frequent.
This is due to the enhanced stability in the atmospheric boundary layer, which inhibits vertical
mixing of emissions from the surface.
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The current primary NAAQS for CO are 35 parts per million for the one-hour average
and 9 parts per million for the eight-hour average. These values are not to be exceeded more
than once per year. Air quality carbon monoxide value is estimated using EPA guidance for
calculating design values. In 1999, 30.5 million people (1990 census) lived in 17 areas
designated nonattainment under the CO NAAQS.24
Nationally, significant progress has been made over the last decade to reduce CO
emissions and ambient CO concentrations. Total CO emissions from all sources have decreased
16 percent from 1989 to 1998, and ambient CO concentrations decreased by 39 percent. During
that time, while the mobile source CO contribution of the inventory remained steady at about 77
percent, the highway portion decreased from 62 percent of total CO emissions to 56 percent
while the nonroad portion increased from 17 percent to 22 percent.25 Over the next decade, we
would expect there to be a minor decreasing trend from the highway segment due primarily to the
more stringent standards for certain light-duty trucks (LDT2s).26 CO standards for passenger cars
and other light-duty trucks and heavy-duty vehicles did not change as a result of other recent
rulemakings.
2.4 Other Adverse Public Health and Welfare Effects Associated with
Category 3 Marine Diesel Engines
The previous section describes national-scale adverse public health effects associated
with the Category 3 marine diesel engines covered by this proposal. This section describes other
adverse health and welfare effects arising from Category 3 marine diesel engines, including
regional haze, acid deposition, and water eutrophication and nitrification
2.4.1 Nonroad Engines and Regional Haze
The Clean Air Act established special goals for improving visibility in many national
parks, wilderness areas, and international parks. In the 1977 amendments to the Clean Air Act,
Congress set as a national goal for visibility the "prevention of any future, and the remedying of
any existing, impairment of visibility in mandatory class I Federal areas which impairment
results from manmade air pollution" (CAA section 169A(a)(l)). The Amendments called for us
to issue regulations requiring States to develop implementation plans that assure "reasonable
progress" toward meeting the national goal (CAA Section 169A(a)(4)). We issued regulations in
1980 to address visibility problems that are "reasonably attributable" to a single source or small
group of sources, but deferred action on regulations related to regional haze, a type of visibility
impairment that is caused by the emission of air pollutants by numerous emission sources located
across a broad geographic region. At that time, we acknowledged that the regulations were only
the first phase for addressing visibility impairment. Regulations dealing with regional haze were
deferred until improved techniques were developed for monitoring, for air quality modeling, and
for understanding the specific pollutants contributing to regional haze.
In the 1990 Clean Air Act amendments, Congress provided additional emphasis on
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regional haze issues (see CAA section 169B). In 1999 we finalized a rule that calls for States to
establish goals and emission reduction strategies for improving visibility in all 156 mandatory
Class I national parks and wilderness areas. In that rule, we also encouraged the States to work
together in developing and implementing their air quality plans. The regional haze program is
designed to improve visibility and air quality in our most treasured natural areas. At the same
time, control strategies designed to improve visibility in the national parks and wilderness areas
will improve visibility over broad geographic areas.
Regional haze is caused by the emission from numerous sources located over a wide
geographic area. Such sources include, but are not limited to, major and minor stationary
sources, mobile sources, and area sources. Visibility impairment is caused by pollutants (mostly
fine particles and precursor gases) directly emitted to the atmosphere by a number of activities
(such as electric power generation, various industry and manufacturing processes, truck and auto
emissions, construction activities, etc.). These gases and particles scatter and absorb light,
removing it from the sight path and creating a hazy condition.
Some fine particles are formed when gases emitted to the air form particles as they are
carried downwind (examples include sulfates, formed from sulfur dioxide, and nitrates, formed
from nitrogen oxides). These activities generally span broad geographic areas and fine particles
can be transported great distances, sometimes hundreds or thousands of miles. Consequently,
visibility impairment is a national problem. Without the effects of pollution a natural visual
range is approximately 140 miles in the West and 90 miles in the East. However, fine particles
have significantly reduced the range that people can see and in the West the current range is 33-
90 miles and in the East it is only 14-24 miles.
Because of evidence that fine particles are frequently transported hundreds of miles, all
50 states, including those that do not have Class I areas, will have to participate in planning,
analysis and, in many cases, emission control programs under the regional haze regulations.
Even though a given State may not have any Class I areas, pollution that occurs in that State may
contribute to impairment in Class I areas elsewhere. The rule encourages states to work together
to determine whether or how much emissions from sources in a given state affect visibility in a
downwind Class I area.
The regional haze program calls for states to establish goals for improving visibility in
national parks and wilderness areas to improve visibility on the haziest 20 percent of days and to
ensure that no degradation occurs on the clearest 20 percent of days. The rule requires states to
develop long-term strategies including enforceable measures designed to meet reasonable
progress goals. Under the regional haze program, States can take credit for improvements in air
quality achieved as a result of other Clean Air Act programs, including national mobile-source
programs.
Nonroad engines (including construction equipment, farm tractors, boats, planes,
locomotives, recreational vehicles, and marine engines) contribute significantly to regional haze.
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Chapter 2: Health and Welfare Concerns
This is because there are nonroad engines in all of the states, and their emissions contain
precursors of fine PM and organic carbon that are transported and contribute to the formation of
regional haze throughout the country and in Class I areas specifically.
2.4.2 Acid Deposition
Acid deposition, or acid rain as it is commonly known, occurs when SO2 and NOx react
in the atmosphere with water, oxygen, and oxidants to form various acidic compounds that later
fall to earth in the form of precipitation or dry deposition of acidic particles.27 It contributes to
damage of trees at high elevations and in extreme cases may cause lakes and streams to become
so acidic that they cannot support aquatic life. In addition, acid deposition accelerates the decay
of building materials and paints, including irreplaceable buildings, statues, and sculptures that are
part of our nation's cultural heritage. To reduce damage to automotive paint caused by acid rain
and acidic dry deposition, some manufacturers use acid-resistant paints, at an average cost of $5
per vehicle—a total of $61 million per year if applied to all new cars and trucks sold in the U.S.
Acid deposition primarily affects bodies of water that rest atop soil with a limited ability
to neutralize acidic compounds. The National Surface Water Survey (NSWS) investigated the
effects of acidic deposition in over 1,000 lakes larger than 10 acres and in thousands of miles of
streams. It found that acid deposition was the primary cause of acidity in 75 percent of the acidic
lakes and about 50 percent of the acidic streams, and that the areas most sensitive to acid rain
were the Adirondacks, the mid-Appalachian highlands, the upper Midwest and the high elevation
West. The NSWS found that approximately 580 streams in the Mid-Atlantic Coastal Plain are
acidic primarily due to acidic deposition. Hundreds of the lakes in the Adirondacks surveyed in
the NSWS have acidity levels incompatible with the survival of sensitive fish species. Many of
the over 1,350 acidic streams in the Mid-Atlantic Highlands (mid-Appalachia) region have
already experienced trout losses due to increased stream acidity. Emissions from U.S. sources
contribute to acidic deposition in eastern Canada, where the Canadian government has estimated
that 14,000 lakes are acidic. Acid deposition also has been implicated in contributing to
degradation of high-elevation spruce forests that populate the ridges of the Appalachian
Mountains from Maine to Georgia. This area includes national parks such as the Shenandoah
and Great Smoky Mountain National Parks.
2.4.3 Eutrophication and Nitrification
Nitrogen deposition into bodies of water can cause problems beyond those associated
with acid rain. The Ecological Society of America has included discussion of the contribution of
air emissions to increasing nitrogen levels in surface waters in a recent major review of causes
and consequences of human alteration of the global nitrogen cycle in its Issues in Ecology
series.28 Long-term monitoring in the United States, Europe, and other developed regions of the
world shows a substantial rise of nitrogen levels in surface waters, which are highly correlated
with human-generated inputs of nitrogen to their watersheds. These nitrogen inputs are
dominated by fertilizers and atmospheric deposition.
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Human activity can increase the flow of nutrients into those waters and result in excess
algae and plant growth. This increased growth can cause numerous adverse ecological effects
and economic impacts, including nuisance algal blooms, dieback of underwater plants due to
reduced light penetration, and toxic plankton blooms. Algal and plankton blooms can also
reduce the level of dissolved oxygen, which can also adversely affect fish and shellfish
populations. This problem is of particular concern in coastal areas with poor or stratified
circulation patterns, such as the Chesapeake Bay, Long Island Sound, or the Gulf of Mexico. In
such areas, the "overproduced" algae tends to sink to the bottom and decay, using all or most of
the available oxygen and thereby reducing or eliminating populations of bottom-feeder fish and
shellfish, distorting the normal population balance between different aquatic organisms, and in
extreme cases causing dramatic fish kills.
Collectively, these effects are referred to as eutrophication, which the National Research
Council recently identified as the most serious pollution problem facing the estuarine waters of
the United States (NRC, 1993). Nitrogen is the primary cause of eutrophi cation in most coastal
waters and estuaries.29 On the New England coast, for example, the number of red and
browntides and shellfish problems from nuisance and toxic plankton blooms have increased over
the past two decades, a development thought to be linked to increased nitrogen loadings in
coastal waters. We believe that airborne NOx contributes from 12 to 44 percent of the total
nitrogen loadings to United States coastal water bodies. For example, some estimates assert that
approximately one-quarter of the nitrogen in the Chesapeake Bay comes from atmospheric
deposition.
Excessive fertilization with nitrogen-containing compounds can also affect terrestrial
ecosystems.30 Research suggests that nitrogen fertilization can alter growth patterns and change
the balance of species in an ecosystem, providing beneficial nutrients to plant growth in areas
that do not suffer from nitrogen over-saturation. In extreme cases, this process can result in
nitrogen saturation when additions of nitrogen to soil over time exceed the capacity of the plants
and microorganisms to utilize and retain the nitrogen. This phenomenon has already occurred in
some areas of the U.S.
2.5 Inventory Contributions
2.5.1 National Inventory
We developed baseline Category 3 vessel emissions inventories under contract with E. H.
Pechan & Associates, Inc.31 Inventory estimates were developed separately for vessel traffic
within 25 nautical miles of port areas and vessel traffic outside of port areas but within 175
nautical miles of the coastline. Different techniques were used to develop the port and non-port
inventories. For port areas we developed detailed emissions estimates for nine specific ports
using port activity data including port calls, vessel types and typical times in different operating
modes. Emissions estimates for all other ports were developed by matching each of those ports
to one of the nine specific ports already analyzed based on characteristics of port activity, such as
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predominant vessel types, harbor draft and region of the country. The detailed port emissions
were then scaled to the other ports based on relative port activity. We developed non-port
emissions inventories using cargo movements and waterways data, vessel speeds, average dead
weight tonnage per ship, and assumed cargo capacity factors. More detailed information
regarding the development of the baseline emissions inventories can be found in Chapter 6.
There has been little study of the transport of marine vessel NOx emissions and the
distance they may travel to impact air quality on land. Pollutant transport is a very complicated
subject, and the transport distance can vary dramatically depending on a variety of factors,
including the pollutant under consideration, prevailing wind speed and direction, and other
atmospheric conditions. When we consider how far off the coast to consider when determining
which emissions to include in our baseline the correct answer may well vary depending on
geographic area and prevailing atmospheric conditions. In developing baseline emissions
inventories we looked at two different scenarios. First, we looked only at the pollutants emitted
within 25 nautical miles of a port area as a reasonable lower bound to estimate the national
inventory of Category 3 marine diesel engines. The primary reason for choosing the 25-mile
radius is that is was used in work done for us in support of previous modeling efforts. We also
estimated Category 3 emissions within 175 nautical miles (200 statute miles) of shore as a more
reasonable estimate of the distance from shore that vessel emissions may be expected to impact
air quality on land. This 175-mile limit was also used in support of previous rulemaking and
modeling efforts.
Not surprisingly, these two different distances yield different inventory results. The 1996
NOx and PM emissions inventories under these tow scenarios are shown in Table 2.6-1. We
used 1996 as the starting point for this analysis because that is the most recent year that we have
detailed information available for the nine specific port areas. As will be discussed later in this
section, this initial analysis shows that the contribution from U.S. and foreign flagged vessels
differs between these two areas.
Table 2.5-1
Category 3 Marine Diesel Engine 1996 Baseline Emissions Inventories (thousand short tons)
Scenario
Within 25 nautical miles of ports
Within 175 nautical miles of coast
NOx
101
190
PM
9.3
17
For the remainder of this analysis we will consider all emissions that occur within 175
nautical miles from the coast as our primary scenario. However, we will continue to investigate
this issue throughout this rulemaking, and will incorporate any new information into the final
rule. For example, the U.S. Department of Defense (DoD) has presented information to us
recommending that a different, shorter (offshore distance) limit be established rather than the
proposed 175 nautical miles as the appropriate location where emissions from marine vessels
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would affect on-shore air quality. DoD's extensive work on the marine vessels issue in Southern
California resulted in a conclusion that emissions within 60 nautical miles of shore could make it
back to the coast due to eddies and the nature of the sea breeze effects. Satellite data however
showed a distinct tendency for a curved line of demarcation separating the offshore
(unobstructed) or parallel ocean wind flow from a region of more turbulent, recirculated air
which would impact on-shore areas. That curved line of demarcation was close to San Nicolas
Island which is about 60 nautical miles offshore. Studies and published information on other
coastal areas in California indicates that they experience somewhat narrower (perhaps 30 nautical
miles) region of "coastal influence." The Gulf Coast and the U.S. East coast would similarly
have their own unique meteorological conditions that might call for different lines of
demarcation between on-shore and off-shore effects.
To estimate inventories for years after 1996, we developed inventory projections based on
expected increases in vessel freight movement and expected changes in vessel characteristics, as
well as feet turnover based on 25 years as the average age of the world fleet at time of scrappage.
We also take the MARPOL Annex VI NOx limits into account because, although these
international NOx standards are not yet effective, most, if not all shipbuilders and shipping
companies around the world are currently complying with them, and this is a trend we expect to
continue. Our estimated emissions inventories are based on the assumption that all vessels built
after 1999, both U.S. and foreign flagged, will comply with the Annex VI NOx limits. Table 2.6-
2 shows the future year NOx and PM inventories for selected years out to 2030. The ports
inventories refer to the areas within 25 nautical miles of ports areas, while the non-ports
inventories refer to the areas outside of 25 nautical miles, but within 175 nautical miles of the
coast. More detailed information regarding the development of the future year emissions
inventories can be found in Chapter 6.
Table 2.5-2
Future Year NOx and PM Inventories for Uncontrolled Category 3 Marine Diesel Engines
(thousand short tons)
Year
1996
2010
2020
2030
NOx
Ports
101
146
196
288
Non-ports
89
128
172
243
All areas
190
274
367
531
PM
Ports
9
14
20
30
Non-ports
8
12
16
24
All areas
17
26
37
54
Baseline emission inventory estimates (total port and non-port) for the year 2000 for
Category 3 marine diesel engines are summarized in Table 2.6-3. This table shows the relative
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Chapter 2: Health and Welfare Concerns
contributions of the different mobile-source categories to the overall national mobile-source
inventory. Of the total emissions from mobile sources, all Category 3 marine diesel engines
contribute about 1.5 percent of NOx and 2.6 percent of PM emissions in the year 2000.
Our draft emission projections for 2020 for Category 3 marine diesel engines show how
emissions from these engines are expected to increase over time if left uncontrolled. The
projections for 2020 are summarized in Table 2.6-4 and indicate that Category 3 marine diesel
engines are expected to contribute 5.7 percent NOx and 5.8 percent of PM emissions in the year
2020. Population growth and the effects of other regulatory control programs are factored into
these projections. The relative importance of uncontrolled nonroad engines in 2020 is higher
than in the projections for 2000 because there are already emission control programs in place for
the other categories of mobile sources which are expected to reduce their emission levels. The
effectiveness of all control programs is offset by the anticipated growth in engine populations.
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Table 2.5-3
Modeled Annual Emission Levels for
Mobile-Source Categories in 2000 (thousand short tons)
Category
Total for engines subject to
proposed standards (U.S.
flagged commercial marine -
Category 3 - uncontrolled)
Commercial Marine CI -
Category 3 - uncontrolled
Commercial Marine CI -
Categories 1 and 2
Highway Motorcycles
Nonroad Industrial SI > 19 kW
Recreational SI
Recreation Marine CI
Marine SI Evap
Marine SI Exhaust
Nonroad SI< 19 kW
Nonroad CI
Locomotive
Total Nonroad
Total Highway
Aircraft
Total Mobile Sources
Total Man-Made Sources
Mobile Source percent of Total
Man-Made Sources
NOx
tons
79
195
700
8
306
13
24
0
32
106
2,625
1,192
5,201
7,981
178
13,360
24,444
55%
percent
of
mobile
source
0.6%
1.5%
5.2%
0.1%
2.3%
0.1%
0.2%
0.0%
0.2%
0.8%
19.6%
8.9%
39%
60%
1%
100%
-
—
HC
tons
2
8
22
84
247
737
1
89
708
1,460
316
47
3,719
3,811
183
7,713
18,659
41%
percent of
mobile
source
0.0%
0.1%
0.3%
1.1%
3.2%
9.6%
0.0%
1.2%
9.2%
18.9%
4.1%
0.6%
48%
50%
2%
100%
-
—
CO
tons
4
16
103
329
2,294
2,572
4
0
2,144
18,359
1,217
119
27,157
49,811
1,017
77,985
100,064
78%
percent of
mobile
source
0.0%
0.0%
0.1%
0.4%
2.9%
3.3%
0.0%
0.0%
2.7%
23.5%
1.6%
0.2%
35%
64%
1%
100%
-
—
PM
tons
7.0
18.0
20
0.4
1.6
5.7
1
0
38
50
253
30
418
240
39
697
3,093
23%
percent
of
mobile
source
1.0%
2.6%
2.9%
0.1%
0.2%
0.8%
0.1%
0.0%
5.4%
7.2%
36.3%
4.3%
60%
34%
6%
100%
-
-
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Chapter 2: Health and Welfare Concerns
Table 2.5-4
Modeled Annual Emission Levels for
Mobile-Source Categories in 2020 (thousand short tons)
Category
Total for engines subject to
proposed standards (U.S.
flagged commercial marine -
Category 3 - uncontrolled)
Commercial Marine CI -
Category 3 - uncontrolled
Commercial Marine CI -
Categories 1 and 2
Highway Motorcycles
Nonroad Industrial SI > 19 kW
Recreational SI
Recreation Marine CI
Marine SI Evap
Marine SI Exhaust
Nonroad SI< 19 kW
Nonroad CI
Locomotive
Total Nonroad
Total Highway
Aircraft
Total Mobile Sources
Total Man-Made Sources
Mobile Source percent of Total
Man-Made Sources
NOx
tons
150
367
617
14
486
27
39
0
58
106
1,791
611
4,116
2,050
232
6,398
16,374
39%
percent
of
mobile
source
2.3%
5.7%
9.6%
0.2%
7.6%
0.4%
0.6%
0.0%
0.9%
1.7%
28.0%
9.5%
63%
33%
4%
100%
-
—
HC
tons
5
17
24
144
348
1,706
1
102
284
986
142
35
3,789
2,278
238
6,305
16,405
38%
percent of
mobile
source
0.1%
0.3%
0.4%
2.3%
5.5%
27.1%
0.0%
1.6%
4.5%
15.6%
2.3%
0.6%
60%
36%
4%
100%
-
—
CO
tons
9
37
125
569
2,991
5,407
6
0
1,985
27,352
1,462
119
40,053
48,903
1,387
90,343
114,011
79%
percent of
mobile
source
0.0%
0.0%
0.1%
0.6%
3.3%
6.0%
0.0%
0.0%
2.2%
30.3%
1.6%
0.1%
44%
54%
2%
100%
-
—
PM
tons
14.0
37.0
19.0
0.8
2.4
7.5
1.5
0
28
77
261
21
455
145
43
643
3,027
21%
percent
of
mobile
source
2.2%
5.8%
3.0%
0.1%
0.4%
1.2%
0.2%
0.0%
4.4%
12.0%
40.6%
3.3%
70%
23%
7%
100%
-
-
2.5.2 Inventories for Specific Ports
In the previous section we presented estimates of Category 3 marine diesel engine
emissions as percentages of the national mobile source inventory. However, marine vessel
activity tends to be concentrated in port areas, and thus we would expect that Category 3 marine
diesel engines would have a proportionately bigger impact on the mobile source pollution
inventories of port areas. Using the port-specific Category 3 inventories developed for use in our
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national inventory in conjunction with total port area inventories developed in support of the
heavy-duty on-highway 2007 rule, we developed estimates of the contribution of Category 3
marine diesel engines to the mobile source NOx and PM inventories of several selected port
areas, including several ozone nonattainment areas. The NOx results are shown in Table 2.6-5,
and the PM results are shown in Table 2.6-6. As can be seen from these tables, the relative
contribution of Category 3 marine diesel engine pollution to mobile source pollution is expected
to increase in the future. This is due both to the expected growth of shipping traffic in the future
and the effect of emissions control programs already in place for other mobile sources.
Table 2.5-5
Uncontrolled Category 3 Marine Diesel Engines NOx Inventories
as a Percentage of Mobile Source NOx in Selected Port Areas
Ozone
Nonattainment Area?
Y
Y
Y
Y
Y
Y
Y
N
N
N
N
N
N
Port Area
Baton Rouge and New Orleans, LA
Los Angeles/Long Beach, CA
Beaumont/Port Arthur, TX
Houston/Galveston/Brazoria, TX
Baltimore/Washington DC
Philadelphia/Wilmington/ Atlantic City
New York/New Jersey
Seattle/Tacoma/Bremerton/
Bellingham, WA
Miami/Ft. Lauderdale, FL
Portland/Salem, OR
Wilmington, NC
Corpus Christi, TX
Brownsville/Harlington/San Benito, TX
% of Mobile Source
NOx from C3
1996
7.4
2.0
1.4
1.5
2.1
1.8
1.0
4.3
5.4
1.9
6.9
4.8
1.8
20201
15.8
8.6
3.1
4.9
11.4
6.9
6.2
26.3
28.1
11.9
26.8
12.2
6.6
1. For reference, the nationwide contribution of Category 3 marine diesel engines to mobile
source NOx in 2020 is projected to be 5.7 percent.
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Chapter 2: Health and Welfare Concerns
Table 2.5-6
Modeled PM Inventories as a Percentage of Mobile Source PM
in Selected Port Areas
Port Area
Baton Rouge and New Orleans, LA
Los Angeles/Long Beach, CA2
Beaumont/Port Arthur, TX
Houston/Galveston/Brazoria, TX
Baltimore/Washington DC
Philadelphia/Wilmington/ Atlantic City
New York/New Jersey
Seattle/Tacoma/Bremerton/
Bellingham, WA
Miami/Ft. Lauderdale, FL
Portland/Salem, OR
Wilmington, NC
Corpus Christi, TX
Brownsville/Harlington/San Benito, TX
% of Mobile Source PM from C3
1996
12.1
3.9
7.4
3.3
3.2
2.8
1.6
8.5
10.6
3.9
8.1
6.0
3.1
20201
22.6
10.8
18.3
8.5
9.6
6.3
5.7
25.5
28.7
12.1
22.4
9.6
14.9
1. For reference, the nationwide contribution of Category 3 marine diesel engines to mobile
source PM in 2020 is projected to be 5.8 percent.
2. PM nonattainment area.
2.5.3 Emissions in Nonport Areas
These ships can also have a significant impact on inventories in areas without large
commercial ports. For example, Santa Barbara estimates that engine on ocean-going marine
vessels contribute about 37 percent of total NOx in their area. These emissions are from ships
that transit the area, and "are comparable to (even slightly larger than) the amount of NOx
produced onshore by cars and truck.32 These emissions are expected to increase to 62 percent by
2015. While Santa Barbara's exact conditions may be unique due to the relative close proximity
of heavily used shipping channels to shore and the meteorological conditions in their area, other
coastal areas may also have relatively high inventory impacts from ocean-going vessels.
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Table 2.5-7
NOx Emissions, Santa Barbara County, California
Source
1999
Tons/Day
% total
2015
Tons/day
Onshore
Motor vehicles
Other mobile sources
Stationary sources
Area-wide sources
25.95
17.27
5.3
0.76
33
22
7
1
9.96
14.19
4.42
1.24
13
18
6
1
Offshore
Ships, boats
Oil and gas production
TOTAL
28.38
0.7
78.36
36
1
47.29
0.66
77.76
61
1
Source: Santa Barbara County Air Quality News., Issue 62, July-August 2001
2.5.4 Contribution by flag
It is important to determine how much of the Category 3 marine diesel engine pollution
inventory is contributed by U.S. flagged vessels given that we are only proposing to apply the
emission standards to U.S. flagged vessels. We estimated the relative contribution of U.S. and
foreign flagged vessels separately for the ports areas and the non-ports areas due to the fact the
we had different data sets available to us for the two areas.
We estimated the contribution of U.S. flagged vessels for the ports areas using port call
data obtained from the U.S. Maritime Administration (MARAD). These data contained all port
calls in 1999 to U.S. ports by vessels of greater than 1000 gross registered tons, including the
country in which they are flagged and the number of port calls each vessel made. An analysis of
the port call data shows that U.S. flagged vessels only account for 6.4 percent of port calls to
U.S. ports. For the lack of more detailed information regarding the breakout of U.S. and foreign
flagged vessel emissions we applied the percentage of port calls from U.S. and foreign flagged
vessels to the national ports inventories to determine the relative contributions of each to the
national ports inventories.
We used freight tonnage data from the U.S. Army Corp of Engineers (USAGE) to
develop relative U.S. and foreign flagged emissions contributions in non-ports areas within 175
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Chapter 2: Health and Welfare Concerns
nautical miles of the coast. In contrast to the data for the ports areas, the USAGE data suggests
that almost 80 percent of the non-ports emissions come from U.S. flagged vessels.
The relative contributions from U.S. and foreign flagged vessels are quite different
between the ports areas and the non-ports areas. Some of this difference can be explained
through U.S. cabotage law, which requires that any vessel operating between two U.S. ports be
U.S. flagged. Thus, while most port traffic is foreign flagged, the foreign flagged vessels would
tend to come into a single U.S. port and then leave U.S. waters. In contrast, U.S. flagged vessels
would typically travel from one U.S. port to another, thus accounting for a higher percentage of
the non-ports emissions. Table 2.5-8 shows the relative contribution of U.S. and foreign flagged
vessels to ports emissions (within 25 nautical miles of port areas), non-ports emissions (between
25 and 175 nautical miles from the U.S. coast) and total emissions from Category 3 vessels
within 175 nautical miles of the U.S. coast.
Table 2.5-8
Relative Contribution by Vessel Flag to 1996 NOx Emissions Inventories
Area
Ports
Non-port
Total
NOx Emissions (1000 tons)
U.S. Flagged
6.5
70.2
76.7
Foreign Flagged
94.7
18.6
113.3
Percent of total from
U.S. Flagged
6.4%
79%
40%
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Draft Regulatory Support Document
Chapter 2 References
1.Carbon monoxide also participates in the production of ozone, albeit at a much slower rate than
most VOC and NOx compounds.
2.U.S. EPA, 1996, Review of National Ambient Air Quality Standards for Ozone, Assessment of
Scientific and Technical Information, OAQPS Staff Paper, EPA-452/R-96-007. A copy of this
document can be obtained from Air Docket A-2001-11, Document No. D-XX-XX.
3.U.S. EPA, 1996, Air Quality Criteria for Ozone and Related Photochemical Oxidants,
EPA/600/P-93/004aF. The document is available on the internet at
http://www.epa.gov/ncea/ozone.htm. A copy can also be obtained from Air Docket No. A-2001-
11, Document No. II-XX-XX.
4.U.S. EPA, 1995, Review of National Ambient Air Quality Standards for Nitrogen
Dioxide, Assessment of Scientific and Technical Information, OAQPS Staff Paper,
EPA-452/R-95-005.
5.U.S.EPA, 1993, Air Quality Criteria for Oxides of Nitrogen, EP A/600/8-9 l/049aF.
6.Vitousek, Pert M., John Aber, Robert W. Howarth, Gene E. Likens, et al. 1997. Human
Alteration of the Global Nitrogen Cycle: Causes and Consequences. Issues in Ecology.
Published by Ecological Society of America, Number 1, Spring 1997.
7.National Air Quality and Emissions Trends Report, 1999, EPA, 2001, at Table A-19. This
document is available at http://www.epa.gov/oar/aqtrnd99/. The data from the Trends report are
the most recent EPA air quality data that has been quality assured. A copy of this table can also
be found in Docket No. A-2001-11, Document No. II-XX-XX.
S.National Air Quality and Emissions Trends Report, 1998, March, 2000, at 28. This document
is available at http ://www.epa. gov/oar/aqtrnd98/. Relevant pages of this report can be found in
Memorandum to Air Docket A-2000-01 from Jean Marie Revelt, September 5, 2001, Document
No. II-A-63. A copy of this document can also be found in Docket No. A-2001-11, Document
No. II-X-XX.
9. Additional information about this modeling can be found in our Regulatory Impact Analysis:
Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control
Requirements, document EPA420-R-00-026, December 2000. Docket No. 1-2001-11,
Document No. IJ-XX-XX. This document is also available at
http://www.epa.gov/otaq/diesel.htmtfdocuments.
10.We also performed ozone air quality modeling for the western United States but, as described
further in the air quality technical support document, model predictions were well below
corresponding ambient concentrations for out heavy-duty engine standards and fuel sulfur control
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Chapter 2: Health and Welfare Concerns
rulemaking. Because of poor model performance for this region of the country, the results of the
Western ozone modeling were not relied on for that rule.
11. Additional information about these studies can be found in Chapter 2 of "Regulatory Impact
Analysis: Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control
Requirements," December 2000, EPA420-R-00-026. Docket No. A-2001-11, Document
Number II-XX-XX. This document is also available at
http://www.epa.gov/otaq/diesel.htmtfdocuments.
12. Air Quality Criteria Document for Ozone and Related Photochemical Oxidants, EPA National
Center for Environmental Assessment, July 1996, Report No. EPA/600/P-93/004cF. The
document is available on the internet at http://www.epa.gov/ncea/ozone.htm. A copy can also be
obtained from Air Docket No. A-2001-11, Document No. U-XX-XX.
13. A copy of this data can be found in Air Docket A-2001-11, Document No. II-XX-XX.
14.Memorandum to Docket A-99-06 from Eric Ginsburg, EPA, "Summary of Model-Adjusted
Ambient Concentrations for Certain Levels of Ground-Level Ozone over Prolonged Periods,"
November 22, 2000. Docket A-2001-11, Document Number U-XX-XX.
15.Memorandum to Docket A-99-06 from Eric Ginsburg, EPA, "Summary of Model-Adjusted
Ambient Concentrations for Certain Levels of Ground-Level Ozone over Prolonged Periods,"
November 22, 2000, at Table C, Control Scenario - 2020 Populations in Eastern Metropolitan
Counties with Predicted Daily 8-Hour Ozone greater than or equal to 0.080 ppm. Docket A-
2001-11, Document Number U-XX-XX.
16. Air Quality and Emissions Trends Report, 1998, March, 2000. This document is available at
http://www.epa.gov/oar/aqtrnd98/. Relevant pages of this report can be found in Memorandum
to Air Docket A-2000-01 from Jean Marie Revelt, September 5, 2001, Document No. U-A-63.
A copy of this document can also be found in Docket No. A-2001-11, Document No. U-X-XX.
17.EPA (1996) Review of the National Ambient Air Quality Standards for Particulate Matter:
Policy Assessment of Scientific and Technical Information OAQPS Staff Paper. EPA-452/R-96-
013. Docket Number A-2001-11, Document No. U-XX-XX. The particulate matter air quality
criteria documents are also available at http://www.epa.gov/ncea/partmatt.htm.
18.Memorandum to Docket A-99-06 from Eric O. Ginsburg, Senior Program Advisor,
"Summary of 1999 Ambient Concentrations of Fine Particulate Matter," November 15, 2000.
This memo is also available in the docket for this rule. Docket A-2001-11, Document Number
II-XX-XX.
19.EPA (1996) Review of the National Ambient Air Quality Standards for Particulate Matter:
Policy Assessment of Scientific and Technical Information OAQPS Staff Paper. EPA-452/R-96-
013. Docket Number A-2001-11, Document No. U-XX-XX. The parti culate matter air quality
criteria documents are also available at http://www.epa.gov/ncea/partmatt.htm. .
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20.Memorandum to Docket A-99-06 from Eric O. Ginsburg, Senior Program Advisor,
"Summary of Absolute Modeled and Model-Adjusted Estimates of Fine Particulate Matter for
Selected Years," December 6, 2000. This memo is also available in the docket for this rule.
Docket A-2001-11, Document Number U-XX-XX.
21. Additional information about the Regulatory Model System for Aerosols and Deposition
(REMSAD) and our modeling protocols can be found in our Regulatory Impact Analysis: Heavy-
Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements,
document EPA420-R-00-026, December 2000. Docket No. A-2001-11, Document No. A-XX-
XX. This document is also available at http://www.epa.gov/otaq/diesel.htmtfdocuments.
22. Technical Memorandum, EPA Air Docket A-99-06, Eric O. Ginsburg, Senior Program
Advisor, Emissions Monitoring and Analysis Division, OAQPS, Summary of Absolute Modeled
and Model-Adjusted Estimates of Fine Particulate Matter for Selected Years, December 6, 2000,
Table P-2. Docket Number 2001-11, Document Number U-XX-XX.
23.See our Mobile Source Air Toxics final rulemaking, 66 FR 17230, March 29, 2001, and the
Technical Support Document for that rulemaking. Docket No. A-2001-11, Documents Nos. II-
A-XX and U-A-YY.
24.National Air Quality and Emissions Trends Report, 1999, EPA, 2001, at Table A-19. This
document is available at http://www.epa.gov/oar/aqtrnd99/. The data from the Trends report are
the most recent EPA air quality data that have been quality assured. A copy of this table can also
be found in Docket No. A-2001-11, Document No. II-A-XX.
25.National Air Quality and Emissions Trends Report, 1998, March, 2000; this document is
available at http://www.epa.gov/oar/aqtrnd98/. National Air Pollutant Emission Trends, 1900-
1998 (EPA-454/R-00-002), March, 2000. These documents are available at Docket No. A-2000-
01, Document No. II-A-72. See also Air Quality Criteria for Carbon Monoxide, US EPA, EPA
600/P-99/001F, June 2000, at 3-10. Air Docket A-2001-11, Document Number II-A-XX. This
document is also available at http://www.epa.gov/ncea/coabstract.htm.
26.LDT2s are light light-duty trucks greater than 3750 Ibs. loaded vehicle weight, up through
6000 gross vehicle weight rating.
27.Much of the information in this subsection was excerpted from the EPA document, Human
Health Benefits from Sulfate Reduction, written under Title IV of the 1990 Clean Air Act
Amendments, U.S. EPA, Office of Air and Radiation, Acid Rain Division, Washington, DC
20460, November 1995. Air Docket A-2001-11, Document No. U-XX-XX.
28.Vitousek, Peter M., John Aber, Robert W. Howarth, Gene E. Likens, et al. 1997. Human
Alteration of the Global Nitrogen Cycle: Causes and Consequences. Issues in Ecology. Published
by Ecological Society of America, Number 1, Spring 1997.
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Chapter 2: Health and Welfare Concerns
29.Much of this information was taken from the following EPA document: Deposition of Air
Pollutants to the Great Waters-Second Report to Congress., Office of Air Quality Planning and
Standards, June 1997, EPA-453/R-97-011.
30.Terrestrial nitrogen deposition can act as a fertilizer. In some agricultural areas, this effect can
be beneficial.
31 .Cite Pechan report(s) when completed.
32.Memorandum to Docket A-2001-11 from Jean Marie Revelt, "Santa Barbara County Air
Quality News, Issue 62, July-August 2001 and other materials provided to EPA by Santa Barbara
County," March 14, 2002. Air Docket A-2001-11, Document No. II-A-47..
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Chapter 3: Industry Characterization
CHAPTER 3: Industry Characterization
To help assess the potential impact of this emission control program, it is important to
understand the nature of affected industries. This chapter describes the Category 3 marine diesel
engine and vessel industries. The picture that emerges is one of a fairly concentrated market,
with only four companies producing over 75 percent of all Category 3 marine diesel engines
worldwide and shipyards in only three countries producing over 60 percent of all vessels that use
these engines. Through Caterpillar's acquisition of MaK, the United States now has a presence
in the C3 marine diesel engine market, although no engines are currently produced in the United
States. The U.S. share of the world market of vessel construction, however, is very small. This
is mainly due to the shipyard subsidy policies of other governments. Because the United States
does not provide similar subsidies most, if not all, of U.S. ship production is vessels required
under the Jones Act to be built in the United States.
This chapter concludes with a brief profile of the vessels that enter U.S. ports. Analysis
of national port entrance data indicates that the vast majority of Category 3 vessels that enter U.S.
ports are flagged elsewhere. We do not attempt to perform this analysis on a port-specific basis.
However, given that the small number of U.S.-flagged vessels in comparison to the world fleet, it
is likely that the contribution of U.S. C3 vessels to local air pollution in any given port is likely to
be small compared to that of foreign-flag vessels.
It should be noted from the outset that it is difficult to obtain reliable data on engine
construction, vessel construction, fleet size, and port activity levels. While there are several
sources available through various government agencies (e.g., Coast Guard, the Maritime
Administration) and industry groups, the data they provide are often inconsistent or incomplete.
There are also differences in what these groups count and how they count it. Therefore, the
numbers contained in this chapter should be interpreted as approximations and not as definitive
counts. However, because of the differences in magnitude between U.S. and foreign
manufacture of engines, vessels, and fleet sizes, the observations we make about these sectors
remain valid.
3.1 Description of Category 3 Marine Engines
For large ocean-going vessels, it is common for the ship to have multiple engines. The primary
purpose for the engines is to provide propulsive power to propel the vessel. Engines are also
required to generate electrical power to be used for auxiliary purposes such as navigation
equipment, maneuvering equipment, and crew services. Marine engines have traditionally been
diesel- or steam-powered engines. Since 1980, virtually all large marine engines built have been
diesel.
EPA defines Category 3 marine engines as compression-ignition (i.e., diesel) engines
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with a displacement greater than or equal to 30 liters per cylinder. Steam engines are not
considered Category 3 engines. Category 3 engines can be incredibly large. These engines are
equipped with anywhere between four to 14 cylinders with displacement ranging from 30 liters
per cylinder up to 2000 liters per cylinder and output between 2,000 kW to over 100,000 kW.
There are two common types of Category 3 engines: "low-speed" (e.g., engine speed of 150 rpm
or less) and "medium-speed" (e.g., engine speed of approximately 300 rpm). The low-speed
engines are two-cycle models which are typically connected to a direct drive propulsion system.
The medium-speed engines are typically four-cycle engines (a very small percentage are two-
cycle). Most of these engines are connected to an electric drive propulsion system. The electric
drive system is actually a large electrical generator that can also be used to generate auxiliary
power as well drive the propulsion system.
Another important aspect of Category 3 diesel engines is that they generally operate on a
very low-grade petroleum-based fuel called "bunker" or "residual" fuel. This fuel is the remnant
fuel left over from the refinery process of making gasoline, diesel, and other petroleum fuels. It
is inexpensive and contains high levels of sulfur and nitrogen, which make it a very dirty fuel.
Because of it's high level of paraffins, bunker fuel is solid at room temperature. Therefore, the
fuel has to be heated in order for it to become a liquid which can be combusted in the engine.
As a result, vessels using Category 3 engines are equipped with elaborate fuel storage and
handling systems.
There is usually a distinction between the engines used for propulsion and the engines
used to generate electrical power for navigation equipment (radar, gyrocompass,
telecommunications), maneuvering equipment (steering gear, bow thrusters) and crew services
(lighting & cooking). The engines used to generate electrical power are typically Category 2
diesel engines (5-30 liters per cylinder). Some vessels, such as refrigerated cargo vessels
("reefers") may require Category 3 engines to meet electric power requirements. Examples of
this are the Dole Columbia and Dole Chile which are equipped with MaK M32 engines (39 liters
per cylinder) as generators.1 Cruise ships often employ diesel-electric engines, discussed above,
that provide both propulsion and power generation. In addition to propulsion and electric power
engines, an auxiliary engine is typically installed for emergency use. According tho the US
Census Bureau, the total delivered cost of all shipbuilding and repair diesel and semidiesel
engines in 1997 was $131 million.2 Only a fraction of this amount is attributable to Category 3
marine diesel engines.
Category 3 marine diesel engines are unique among engines in the sense that they are
incredibly large and many are not mass-produced. They also come in a broad configuration of
models: varying number of cylinders, engine displacement, power output, and engine speed.
Because there are so many different vessel applications and such a large selection of available
engine configurations, the engine selection is a major design consideration in the overall design
of a vessel. As a result, the engine selected for a specific vessel is often a unique design or
configuration that is designed specifically for that vessel.
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Chapter 3: Industry Characterization
Once a vessel manufacturer has determined the size and output of engine necessary for
their particular design, the engine manufacturer develops the engine on a test bed. After engine
development is completed, the engine is assembled and tested. The tests consists of making sure
the engine starts and operates properly as well as performing Annex VI emission testing. The
engines is disassembled and shipped to the shipyard where the vessel is to be built. The shipyard
or an approved licensed assembler reassembles the engine and fits it into the vessel, typically
with engine manufacturer supervision.
Once the vessel is complete, the shipyard will typically perform a series of three more
engine tests. The first is referred to as "light-off," which is when the engine is started for the first
time in the vessel. The second engine test is dock testing, where the engine is operated in dock to
make sure that all systems are operational. The third test is sea testing, where the vessel is taken
out on it's "maiden voyage."
3.2 Category 3 Marine Engine Manufacturers
3.2.1 Companies That Make Category 3 Marine Engines
Most Category 3 engine manufacturers are large, multi-national, diversified companies
which often produce smaller marine engines, marine propulsion and marine electric generation
equipment. In addition, these companies also produce engines for other uses such as locomotives
and power plants. Many also have divisions which manufacture vessels and operate shipyards.
We have determined that there are at least 16 companies that manufacture Category 3
marine diesel engines. Four large companies (MAN B&W Diesel, Wartsila/New Sulzer,
Catepillar/MaK, and Mitsubishi) dominate the sales of Category 3 engines. These four
companies account for nearly 75 percent of medium-speed engine sales and 100 percent of low-
speed engine sales. The remaining 25 percent of medium-speed engine sales are distributed
among the other 12 engine manufacturers.
The majority of Category 3 diesel engine manufacturers are located in Europe and Japan.
Only one engine company which manufactures Category 3 diesel engines is headquartered in the
United States. This manufacturer is Caterpillar who recently purchased MaK, located in Kiel,
Germany. However, Caterpillar does not manufacture any Category 3 diesel engines in the
United States. Therefore, there are no Category 3 engines manufactured in the United States.
Table 3.2-1 is a list of engine manufacturers which currently produce models which are
Category 3 engines. This list was compiled from the Directory of Marine Diesel Engines^
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Table 3.2-1 Current Worldwide Manufacturers of
Category 3 Marine Diesel Engines
Akasaka Diesels
Caterpillar Motoren GmbH & Co., KG
Daihatsu Diesel Mfg. Co., Ltd.
Fincantieri Diesel
Hanshin Diesel Works Ltd
Makita Corp
MAN B&W Diesel
Matsui Iron Works Co., Ltd.
Mitsubishi Heavy Industries Ltd
Mitsui Engineering & Shipbuilding Co.
Ltd
Niigata Engineering Co Ltd, Japan
Rolls-Royce
SEMT Pielstick
SKL Motoren-und Systemtechnik GmbH
Wartsila/New Sulzer
Yanmar Diesel Engine Co., Ltd
3.2.2 Production of Category 3 Marine Engines
Shipbuilding is a multi-year process, therefore the number of engines produced per year is
not generally tracked by the shipping industry. The number of engines "produced" in a given
year is reported as the number of engine installations on vessels which are delivered in that year.
This number reflects the number of engines installed for propulsion power, not electric
generating or auxiliary power.
Due to the size and complexity of the engine manufacturing companies, it is difficult to
obtain sales and production data for individual engine models or classes. Most companies which
were researched only report annual income at the division level. It is not appropriate to compare
these sales data since the types of activities and structure of a given division varies greatly
between companies. In addition, many of the engines provided by these manufacturing
companies are used for other applications other than marine propulsion and power, such as
locomotive and land-based electric power generation.
We estimated the number of propulsion engines installed annually by each manufacturer
based on information in Motorship's Annual Analysis publication.4 The Annual Analysis data are
based on a survey of ships with dead weight tonnage (DWT) greater than 2,000 that were
delivered in 1998. These data are presented in Table 3.1-2. The analysis gives the number of
engines installed on all vessels by manufacturer. Note that several of the companies are now
owned or controlled by other manufactures including Sulzer (Wartsila), Bergen (Rolls Royce),
MaK (Caterpillar), Rushton (MAN B&W). Table 3.2-2 indicates that for 1998, approximately
765 low-speed engines and 497 medium-speed engines were produced for a total of 1,262
Category 3 engines worldwide.
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Chapter 3: Industry Characterization
Table 3.2-2
Summary of Worldwide Category 3 Engine Manufacturer Production
for Vessels of >2,000 DWT in 1998
LC
Manufacturer
MAN B&W
Sulzer
Mitsubishi
Total
)W-SPEED E
Engines
515
150
100
765
NGINES
Percent of Total
67.3%
19.6%
13.1%
MEE
Manufacturer
Wartsila
MAN B&W
MaK
Caterpillar
Sulzer
Bergen
DeutzMWM
GMT
Ruston
Hanshin
MTU
Niigata
Yanmar
Pi el stick
Akasaka
Unknown
SKL
Daihatsu
Russki
Total
HUM-SPEED E
Engines
135
92
75
32
24
21
20
19
15
13
9
9
7
6
6
5
4
3
2
497
,NGINES
Percent of Total
27.2%
18.5%
15.1%
6.4%
4.8%
4.2%
4.0%
3.8%
3.0%
2.6%
1.8%
1.8%
1.4%
1.2%
1.2%
1.0%
0.8%
0.6%
0.4%
0.4%
Source: Motorship, Annual Analysis
3.2.3 Relationship Among Worldwide Engine Manufacturers
Engine manufacturing companies are often involved with financial and design agreements
with other engine manufacturers. The types of associations included component manufacturing
licensing agreements, engine licensing agreements, controlling stock ownership of other
companies, and acquisitions. The following acquisitions occurred in recent years: Rolls Royce
acquired Bergen, Wartsila acquired Sulzer, Caterpillar acquired MaK, MAN B&W acquired
Alstom (Mirrlees Blackstone and Ruston).
Licensing agreements also exist between the manufacturers and the shipyards. These
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licensing agreements generally are for a model design. Engines are vessel-specific and are field
erected during installation on a vessel. The shipyard typically assembles the engine within the
vessel at the shipyard per the engine manufacturers instructions.
Licensee information was also reported in the Motorship database. We compiled a list of
the licensees based on the manufacturer, the location and the number of engines installed for
years 1999 and 2000. This information is presented in Table 3.2-3 for the top 10 licensees.
Notice that the top five licensees are the same for both years.
Table 3.2-3
Top 10 Licensees of Category 3 Engines for Years 1999 and 2000
Yard Nationality
Licensee
Manufacturer
No of Engines
1999
JAPAN
S. KOREA
JAPAN
JAPAN
JAPAN
S. KOREA
NORWAY
S. KOREA
FINLAND
CHINA
Mitsui Engineering & Shipbuilding Co Ltd
Hyundai Heavy Industries Co
Kawasaki Heavy Industries Ltd
DIESEL UNITED
Hitachi Zosen Corp
Sasung Heavy Industries Co
WARTSILA FINLAND
Korea Heavy Industries & Construction Co
WARTSILA FINLAND
Hudong Heavy Machinery Co
MAN B&W DIESEL A/S
MAN B&W DIESEL A/S
MAN B&W DIESEL A/S
SULZER
MAN B&W DIESEL A/S
MAN B&W DIESEL A/S
WARTSILA
MAN B&W DIESEL A/S
WARTSILA
MAN B&W DIESEL A/S
117
93
45
45
31
28
26
25
23
19
2000
JAPAN
S. KOREA
JAPAN
JAPAN
JAPAN
ITALY
S. KOREA
CHINA
JAPAN
GERMANY
Mitsui Engineering & Shipbuilding Co Ltd
Hyundai Heavy Industries Co
Kawasaki Heavy Industries Ltd
DIESEL UNITED
Hitachi Zosen Corp
WARTSILA FINLAND
Hyundai Heavy Industries Co
WARTSILA FINLAND
HANSHIN
MaK
MAN B&W DIESEL A/S
MAN B&W DIESEL A/S
MAN B&W DIESEL A/S
SULZER
MAN B&W DIESEL A/S
WARTSILA
SULZER
WARTSILA
HANSHIN
MaK
107
101
48
43
42
33
28
26
24
22
Source: Motorship, Annual Analysis
3.3 Vessel Manufacturers
This section gives a general characterization of the large vessel manufacturing segment of
the marine industry that may be impacted by the proposed regulations. This industry
characterization was developed in part under contract with ICF Consulting5 as well as
independent analyses conducted by EPA through interaction with the industry and other sources.
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Chapter 3: Industry Characterization
3.3.1 United States Vessel Manufacturers
3.3.1.1 Description of Vessels
This section characterizes the U.S. manufacturers of large commercial vessels equipped
with Category 3 engines. These vessels engage in waterborne trade and/or passenger transport
and typically exceed 400 feet in length and/or weigh more than 1,000 gross tons. The U.S.
Department of Transportation Maritime Administration (MARAD) identifies a major shipbuilder
as one that is capable of producing a ship of 400 feet in length or greater. Commercial vessels
operate in the Great Lakes, coastwise, intercoastal, and/or transoceanic routes. The principal
commercial vessel types are auto carriers, bulk carriers, container ships, general cargo ships,
refrigerator ships, roll-on/roll-off (RORO), tankers, and passenger ships. Passenger ships include
cruise ships and large ferries.
3.3.1.2 Production of Large Vessels Equipped with Category 3 Marine Diesel
Engines
The process of designing and building a large vessel is long and complicated. The whole
process takes approximately 32 to 36 months. Once a fleet owner decides to build a new ship,
they work with a shipyard and engine manufacturer to design the ship. The design process is the
most time consuming and can take up to 18 months alone. In the early stages of the design
process, the owner works with ship architects and classification societies that ensure that the
design and materials to be used for the vessel meet appropriate performance and safety
specifications. An example of a U.S. classification society is the American Bureau of
Shipbuilding (ABS). It is also during this period of the design process that the owner and
architects decide what engine or engines to use. In determining the appropriate engine for the
specific vessel design, they consider engine type (e.g., medium- or slow-speed), engine size, and
power output to name a few. Once a design has been approved and completed, the actual
construction of the vessel begins. This process takes place at a shipyard and can take between 12
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to 14 months.
3.3.1.3 Background of the U.S. Shipbuilding Industry and Global Competition
Shipyards that build ships, operate on a job specific basis. Unlike most other industries,
only a small number of orders are received each year and they often take years to fill. Orders for
vessels are placed by either the private sector or the federal government. Companies that place
orders often include commercial shipping companies, passenger and cruise companies, ferry
companies, and petrochemical companies.
Shipbuilding has historically been an important industry in the United States. It is
dominated by two main components: the commercial market for large vessels and the military
market. However, according to the American Shipbuilding Association (ASA), the U.S.
shipbuilding industry has been contracting since 1980. In 1981, there were 22 shipyards holding
ship construction contracts for the government, commercial customers, or both. By 2001, the
number of active new construction shipyards building large oceangoing vessels fell to three.
Shipbuilding is a global industry. The vast majority of commercial ships used throughout
the world are foreign-built. A major shift in shipbuilding market share began in the 1960s with
Japan's entry into the market. South Korea entered the market in the 1970s, and China entered in
1980. The Japanese and South Korean penetration into the market came at the expense of
American (and European) shipbuilders. Few ships have been built in the U.S. since the boom
years in the mid 1970's through the mid 1980's. Between 1987 to 1989, no commercial ships
were built at U.S. shipyards. Since 1990, approximately 19 large commercial ships that use
Category 3 engines have been built in the U.S., for an average of 1.9 ships per year.
The ASA believes that the collapse of commercial shipbuilding in the United States was
largely due to the elimination of the Construction Differential Subsidy Program (CDS) in 1981.
The CDS program, established in 1936 and administered by MARAD, provided for a subsidy of
up to 50 percent of the construction cost of a commercial vessel built in the United States to
offset the lower foreign construction costs. The subsidy was only available for those ships built
in the United States that were to be registered under the laws of the United States, and operated
in the international trades. The United States was the only shipbuilding country in the world to
eliminate its subsidies as Asia and Europe dramatically increased subsidies to their industries.
As a result, the U.S. lost its international commercial market share, which was at nine percent.
U.S. commercial business is today comprised of construction of ships to serve our domestic
coastwise trade. This market accounts for about one percent of the worldwide commercial
market. Figure 3.3-1 illustrates the change in the distribution of the world's commercial
shipbuilding tonnage.
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Chapter 3: Industry Characterization
Figure 3.3-1: World Commercial Shipbuilding Tonnage
1979
2001
United States Cnina
1%
A moderate resurgence in U.S. commercial orders began in 1995 as a result of demand
for replacement tonnage for the U.S. domestic coastwise trade, known as Jones Act Vessels
(which requires ships transporting cargo between two U.S. points to be U.S. built, owned and
crewed; see below) and the revitalization of the Title XI Ship Loan Guarantee Program (a
government ship loan guarantee program administered by MARAD).
Both commercial and naval shipbuilding are cyclical. This mix of commercial and
military shipbuilding orders has been the cornerstone of the shipbuilding industrial base in the
United States. Between 1955 and 1985, U.S. shipbuilders delivered an average of 20 commercial
ships per year for both domestic and international trades. Between the same period, the U.S.
Navy ordered an average of 19 ships per year.
Table 3.3-2 presents the delivery of merchant and military vessels from U.S. shipyards
over the ten year period between 1990 and 2000 according to the Colton company.6
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Table 3.3-2.
Deliveries from U.S. Shipyards, 1990 to 2000
(Merchant ships over 1000 GT and Naval ships over 1000 LT)
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
Merchant
(No. of ships)
0
0
3
0
1
1
1
4
2
6
1
Merchant
(1000GT)
0
0
45
0
17
2
28
107
24
161
7
Naval
(No. of ships)
14
14
18
18
15
17
11
11
11
5
8
Naval
(1000LT)
102
100
218
129
158
221
92
186
251
90
134
Source: The Col ton Company
3.3.1.4 Cabotage Laws in the United States: The Jones Act and the Passenger Vessel
Services Act
The term "cabotage," (derived from the French "caboter," meaning to sail coast-wise, or
literally, "by the capes") is often used to refer to a body of maritime law dealing with the right to
conduct trade or transport goods in coastal waters or between two points within a country. These
laws, common in some form to more than 40 nations with significant ocean-going fleets, are
designed to ensure a strong national flag merchant marine fleet for defense, employment, and
general economic purposes by reserving a country's domestic maritime transportation for its own
citizens. The principles of cabotage laws are designed to guarantee the participation of a
country's citizens in its own domestic trade. These laws foster the development of a merchant
marine and give preference to local labor and industry. They also support national security and
protect the domestic economy.
In the United States, Congress first restricted participation in coastal trades and fisheries
to U.S.-built and U.S.-owned vessels, and gave these vessels preferential treatment regarding
taxes and import duties, in 1789. Currently, U.S. maritime cabotage laws include a number of
different statutes that govern the transportation of cargo and passengers between two points in
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Chapter 3: Industry Characterization
the U.S. (including its territories and possessions), as well as all dredging, towing, salvage, and
other marine operations and fishing. Two major enactments, The Merchant Marine Act of 1920
(46 U.S.C. 861) and the Passenger Vessel Services Act of 1886 (46 U.S.C. 289), in combination
provide the majority of U.S. cabotage provisions related to the transport of cargo or passengers.
Variations of these laws exist today in the U.S. transportation, communications, and utility
industries.
Section 27 of the Merchant Marine Act of 1920 (46 U.S.C. 883; 19 CFR 4.80 and 4.80b),
popularly known as the "Jones Act," essentially requires that domestic waterborne commerce
between two points within the U.S. and subject to coastwise laws must be transported in vessels
built in the U.S., documented under the laws of the U.S. (i.e., registered under the American
flag), and crewed and owned by U.S. citizens. The Passenger Vessel Services Act sets
essentially the same standards for passenger vessels as the Merchant Marine Act sets for cargo
vessels. Specifically, the primary requirements of the Jones Act state that:
No merchandise may be transported by water between points in the U.S., either directly or
via a foreign port, unless the transporting vessel is built in the U.S., documented under
the laws of the U.S., and owned by U.S. citizens.
• Vessels over 200 gross tons with domestic U.S. trading privileges that are sold to foreign
owners or registered under a foreign flag may return to the U.S. flag, but the vessel's
domestic U.S. trading privileges are forever forfeited.
Vessels with domestic U.S. trading privileges which are rebuilt may only retain those
privileges if the entire rebuilding is effected within the U.S.
In addition, Congress included some exceptions to the requirements of the Jones Act to deal with
special circumstances. These provisions include service on the Yukon River, established ferry
services owned by railroad companies, transport of empty cargo accessory equipment, transfers
of cargo between barges of the same owner, and transport offish processing supplies. The
provisions of the U.S. cabotage laws may be waived administratively by the Treasury Department
only in the interest of national defense. The only other way in which the provisions may be
waived and a non-qualifying vessel granted domestic trading privileges is via Congressional
action.
The Jones Act fleet, or those vessels engaged in or otherwise authorized to be engaged in
U.S. domestic commerce, is a subset of the fleet of U.S.-flagged and registered vessels. In other
words, all Jones Act vessels are U.S.-flagged, but all U.S.-flagged vessels are not necessarily
endorsed to engage in domestic commerce. For example, as noted above a formerly U.S.-flagged
vessel could, after a period of being registered under a foreign flag, return to being U.S.-flagged,
but that vessel will never be able to engage in U.S. domestic shipping.
There are tens of thousands of Jones Act vessels that operate in three major sectors of
U.S. domestic shipping: the Great Lakes, the inland waterways, and the domestic ocean trades
(along the coasts or non-contiguous trade between the U.S. mainland and Puerto Rico, Alaska,
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Hawaii, and other U.S. Pacific islands). The vast majority of these, however, are non-self-
propelled dry cargo barges and tanker barges that ply the U.S. internal waterways. As of July
1998 there were about 61 self-propelled merchant vessels of 1,000 gross registered tons with
unrestricted domestic trading privileges (i.e., Jones Act vessels).7
3.3.1.5 U.S. Vessel Manufacturers
MARAD states that the benchmark used to track the U.S. shipbuilding industry is the
U.S. Major Shipbuilding Base (MSB). The MSB is defined as those privately owned shipyards
that are open, and have at least one shipbuilding position capable of accommodating a vessel
122 meters (400 feet) in length or over (vessels of this size are generally considered by the
shipbuilding industry to be very large deep-sea vessels which would use Category 3 engines).
The shipyard must also have in place a long-term lease on the shipbuilding facility and there
must be no dimensional obstructions (i.e., locks, bridges) in the waterway leading to open water.
As of January 1, 1998, utilizing this definition, there were 18 major shipbuilding facilities in the
United States. However, the majority of these shipyards produce military vessels or smaller
commercial vessels that do not use category 3 engines.
According to the ASA, there are eight shipyards that have built large category 3 engine-
powered commercial vessels over the last several years. Currently, there are only three shipyards
building any of these vessels. Table 3.2-3 lists the eight shipyards that have most recently been
involved in building large commercial vessels.
Table 3.2-3
U.S. Shipyards Building Large Commercial Vessels
Shipyard
National Steel & Shipbuilding Co.
(NASSCO)
Avondale Industries, Inc.
Ingalls Shipyard
Newport News Shipyard
Kvaerner Philadelphia Shipyard, Inc.
Friede Goldman Halter
Alabama Shipyard, Inc.
Todd Shipyards
Location
San Diego, CA
Avondale, LA
Pascagoula, MS
Newport News, VA
Philadelphia, PA
Pascagoula, MS
Mobile, AL
Seattle, WA
The three shipyards currently building large commercial vessels are National Steel &
Shipbuilding Co. (NASSCO), Avondale Industries, Inc., and Ingalls Shipyard. A fourth
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Chapter 3: Industry Characterization
shipyard, Kvaerner Philadelphia Shipyard, Inc. has a long history of producing large oceangoing
vessels, primarily for the Navy. In 1996, the Philadelphia shipyard was closed. In 1997
Kvaerner signed an agreement with the city of Philadelphia and the state of Pennsylvania to re-
open the shipyard. While the shipyard is still sorting out who the owner will be, they have stated
that they plan to focus primarily on the domestic oceangoing cargo ship market. Thus, they may
soon be building large ships equipped with Category 3 engines.
The 18 MSB yards employ about 65 percent of the workforce engaged in shipbuilding
and/or boatbuilding (SIC 3731). About 43 percent of the workforce at MSB yards is engaged in
military ship construction and repair work. The largest six shipyards (known as the "big six")
account for over 90 percent of commercial shipbuilding dollars in the United States and over 98
percent of the U.S. Navy's shipbuilding budget.8 Table 3.2-4 presents the employment and sales
for the largest U.S. shipyards still active (or with capacity) to build large commercial vessels by
yard.
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Table 3.2-4 Employment and Sales for the Largest U.S. Shipyards
Active (or With Capacity) in Building Large Commercial Vessels
Shipyard
National Steel & Shipbuilding
Co. (NASSCO)
Avondale Industries, Inc.
Ingalls Shipyard
Newport News Shipyard
Kvaerner Philadelphia
Shipyard, Inc.
Friede Goldman Halter
Alabama Shipyard, Inc.
Todd Shipyards, Seattle
Shipyard
Total
Employment
5,000
5,000
10,000
18,000
n/a
n/a
n/a
500-1,000
Shipyard
Total Sales
(millions $)
$500
$625
$1,300
$1,800
n/a
n/a
n/a
n/a
Comments
currently engaged in
commercial shipbuilding; about
half of employment and sales is
commercial shipbuilding and
repair
currently engaged in
commercial shipbuilding
currently engaged in
commercial shipbuilding
In 2000 ended its commercial
shipbuilding practice, but has
capacity
Employment available for
parent company only
Filed for bankruptcy April
2001
Has commercial capability, but
focuses on military
construction
Has commercial capability, but
focuses on ferry construction
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Chapter 3: Industry Characterization
Table 3.2-5 Employment and Sales for the Parent Companies of Largest U.S. Shipyards
Active (or With Capacity) in Building Large Commercial Vessels
Parent Company
General
Dynamics
Northrop
Grumman
Kvaerner-Aker
Friede Goldman
Halter
Atlantic Marine
Todd Shipyards
Shipyard(s)
National Steel &
Shipbuilding Co.
(NASSCO), Bath Iron
Works, and Electric Boat
Avondale Industries, Inc.,
Ingalls Shipyard, and
Newport News
Shipbuilding
Kvaerner Philadelphia
Shipyard, Inc.
Halter Marine
Alabama Shipyard, Inc.
Todd Shipyards, Seattle
Parent Company
Total Employment
33,000
100,000
40,000
n/a*
n/a
500 - 1,000
Parent Company
Total Sales
(millions $)
$12,000
$18,000
$6,000
n/a*
n/a
n/a
*Filed for bankruptcy April 2001
3.3.1.6 U.S. Shipping Outlook
According to the ASA, two factors creating near-term commercial markets for U.S.
shipbuilding are the Jones Act, which requires ships transporting cargo between two U.S. points
to be U.S. built, owned and crewed, and the Oil Pollution Act of 1990 (OPA 90), which requires
all oil tankers calling in U.S. waters by the year 2015 to be equipped with double hulls.2
According to MARAD, shipbuilding analysts expect a significant rise in new orders for
commercial ships. This increase in new orders emanates from projections of high growth in the
seaborne trade for oil and dry bulk cargoes, as well as the continued demand for replacement
ships due to the aging of the world fleet. The average age of the world fleet was 19 years at the
end of 2000. Projected total new worldwide demand for new tonnage between 1998-2010 will
be approximately 339.0 million DWT.7 Another estimate is that worldwide new construction
demand over the 10 year period 2001-2010 may be 230 million DWT, according to Drewery
Shipping.9 Prior to September 2001, ASA believed that another commercial market opportunity
for U.S. shipbuilders was construction of large oceangoing cruise ships for U.S. domestic trade
as the demand for U.S. coastal cruises grows.2 In addition, the ASA projected demand over the
next 10 years for 30 dry cargo ships.10
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Worldwide shipyards are seeing and will continue to see an influx of orders for double
hulled tankers, as a result of the requirements of enactment OPA-90. OPA-90 requires that by
the year 2015 all tankers entering U.S. ports must be double-hull. According to ASA, since
enactment of OP A 90, U.S. shipyards have built 10 double-hulled tankers with options for two
more. United States shipbuilders anticipate orders for over 40 double hulled tankers over the
next 10 years. Recently, ASA projected demand over the next 10 years for 25 40,000-DWT
double-hulled tankers.11 Other analysts are less optimistic, estimating that the commercial
shipbuilding industry overall is over capacity by as much as 30 percent related to distortions from
foreign subsidies.12
3.3.2 International Vessel Manufacturers
There are just over 22 countries that build large Category 3 engine-powered commercial
vessels. In 1998, 1,080 commercial ships with a dead weight tonnage (DWT) of over 2,000 were
built worldwide, including U.S. production. Over 60 percent of those ships were built by three
countries: Japan, South Korea, and China. Germany and Poland round out the five leading
shipbuilding countries. These five countries produced over 70 percent of the large commercial
vessels built in 1998.
3.4 U.S. Fleet Characterization
3.4.1 Background
There are a number of data sources that have information on the U.S. fleet. Of these
sources, the MARAD's "Vessel Inventory Report" dated July, 2001 was the most reliable and
comprehensive. It contains data for U.S. flag oceangoing self-propelled merchant vessels of
1,000 gross tons and over. The vessel name, ship type, engine type, the year and country in
which the operator (government or private) vessel was built, GRT and DWT and whether the
vessel is classified a Jones Act vessel by the U.S. are all identified in the MARAD data.
3.4.2 U.S. Fleet
Vessels in the U.S. fleet are subject to the Jones Act and related cabotage laws which
require that cargo and passengers moving between U.S. ports, either directly or via a foreign
point, be transported on vessels which are owned by U.S. citizens, built in U.S. shipyards, and
manned by U.S. citizen crews. U.S. cabotage laws provide reliable domestic shipping, protect
the U.S. shipping industry from foreign competition, and ensure a maritime capability that is
subject to U.S. government control for national defense purposes. Many countries have cabotage
laws to protect both their shipping industry and for national defense purposes.
Despite the cabotage laws which protect the U.S. shipping industry, the U.S. fleet has
been declining in numbers of vessels and DWT since the end of World War U. The United
States now ranks 17th in number of oceangoing vessels, having fallen from a top-ten ranking just
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Chapter 3: Industry Characterization
a few years ago. The U.S.-flag merchant fleet ranks 11th on a deadweight tonnage basis.13
Today, the U.S. fleet's share of oceanborne commercial foreign trade, by weight, continues to be
less than five percent.
The current estimate for the size of the U.S. flagged fleet for vessels using Category 3
diesel engines is approximately 200 vessels. Table 3.4-1 presents the estimated number of
vessels in the U.S. Fleet with Category 3 diesel engines based on the MARAD data. The table
presents data for the number of privately-owned (commercial) vessels, government-owned
vessels, and Jones Act vessels. There are over 25 different types of U.S. flagged vessels that
visited U.S. ports in 1999. The average age for these vessels was 22.7 years, with the oldest
vessel being 95 years old.
Table 3.4-1 MARAD Summary of U.S. Fleet Vessels for Vessels >2,000 DWT
Total
200
Commercial
163
Government
37
Jones Act
67
3.4.3 Foreign Flag Fleet
The current estimate for the size of the foreign flagged fleet of vessels using Category 3
engines that entered U.S. ports is approximately 7,600 vessels. There are over 25 different types
of foreign flagged vessels that visited U.S. ports in 1999. The average age for these vessels was
14 years, with the oldest vessel being 96 years old.
3.4.4 Cruise Vessels
Cruise ships are very unique vessels. They are passenger vessels designed for extended
trips ranging from several days to weeks. They are quite literally floating towns. They are
equipped not only with overnight rooms, similar to hotel rooms, but they can also have pools,
recreational facilities, exercise clubs, restaurants, night clubs, and even casinos. These ships
range from very large passenger vessels that can exceed lengths of 1,000 feet, hold up to 5,000
passengers and crew, contain over 1,600 cabins, and have up to 14 decks to vessels half this size.
There are twelve companies that account for the majority of cruise ship activity in U.S. waters.
Table 3.3-2 lists these twelve companies.
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Table 3.3-2 Major Cruise Ship Companies
Carnival Cruises
Celebrity Cruises
Cunard
Holland American Line
International Shipping Partners
Norwegian Cruises
Princess Cruises
Royal Carribean International
Europa Cruises Corporation
Tropicana Cruises
La Cruise
Palm Beach Casino Line
According to an EPA published Cruise Ship White Paper, the worldwide cruise ship fleet
included more than 223 ships that carried an estimated 9.5 million passengers in 1998. There
are no U.S. flagged cruise ships. The vast majority of cruise ships that visit U.S. ports are
flagged under Liberia, Panama, the Bahamas, and Norway. This EPA White Paper also stated
that by 2003, cruise ship companies had planned to add 33 new and/or bigger cruise ships to the
market, which would increase passenger capacity by 35 percent.
According to ASA, the downturn of the U.S. economy which began in late 2000 started to
take it's toll on the U.S. tourism industry, and the September 11th attacks on the U.S. sent the
cruise market into a tailspin with decreased bookings, increased cancellations, and many
companies offering huge fare discounts. As a result, two smaller cruise lines, Renaissance
Cruises and American Classic Voyages have filed for Chapter 11 bankruptcy reorganization, and
the financial viability of other cruise lines are threatened by the free fall in bookings and stock
prices. U.S. shipbuilders began to feel the aftermath of the September 11th attacks on October
25, 2001, when Ingalls Shipbuilding announced that it had stopped work on Project America, a
cruise ship program to build two 1,900-passenger cruise ships.
3.5 U.S. Port Activity
3.5.1 Background
3.5.1.1 Major U.S. Ports
According to MARAD, the top five major U.S. commercial ports, based on the total
number of calls made to each port, are Los Angeles, Houston, New Orleans, New York, and San
Francisco. Table 3.5-1 lists the total number of calls for each of these five ports, their world
ranking, and the number of calls for the four most common ship types. This table indicates that
the majority of dry goods and products entered and left through Los Angeles, New York and San
Francisco, while the majority of oil and other tanker-carried products entered and left primarily
through Houston and New Orleans.
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Table 3.5-1 Top Five U.S. Commercial Ports in 2000 - Based on Calls
Port
Los
Angeles
Houston
New
Orleans
New York
San
Francisco
Total
Calls
5,326
5,129
5,090
4,605
3,575
World
Ranking
10
12
13
15
18
Tankers
911
2,988
1,371
1,271
787
Dry Bulk
783
748
2,676
301
626
Containership
2,955
614
388
2,172
1,936
Other
General
Cargo
677
779
655
861
226
3.5.1.2 Number of Vessels Visiting U.S. Ports Each Year
According to MARAD, about 7,800 vessels powered by or equipped with Category 3
engines visited U.S. ports in 1999. The vast majority of these ships were foreign flagged. In
fact, about 97 percent of the total number of Category 3-powered vessels that made calls to U.S.
ports were foreign flagged. U.S. flagged vessels accounted for about three percent of the total
Figure 3.5-1: Vessel Entrances for 1999 - All Vessels
OOoOOoooiooa
1234567
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
Number Entrances
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number of vessels visiting U.S. ports. Approximately 200 U.S. flagged vessels visited U.S.
ports in 1999. Table 3.5-2 lists the ten most common U.S. flagged vessel type for 1999 and the
number of each vessel.
Table 3.5-2 MARAD Summary of U.S. Flagged Vessels Visiting U.S. Ports
Vessel Type
Containership
RO/RO
Tanker
Tug Barge
Freighter
Bulk Carrier
Chemical Tanker
Combo Pass & Cargo
Heavy-Lift Carrier
Car Carrier
Total
Number of Vessels
59
41
39
15
14
12
10
5
4
2
200
3.5.1.3 Number of Entrances to U.S. Ports
The term "entrance" and "call" are often used interchangeably within the marine industry.
An "entrance" is often defined as a vessel entering a port/waterway area. A "call" is defined as
one entrance and one clearance by a vessel. Because the MARAD data set is the most
comprehensive and since they list the number of entrances and not calls, we looked at entrances
as a measure of how many visits were made by individual vessels. The number of entrances
made into U.S. ports is overwhelmingly dominated by foreign flagged vessels. As stated above,
7,800 vessels visited U.S. ports in 1999. These vessels made a total of 72,200 entrances to U.S.
ports. Of these entrances, 67,500 or 93 percent, were made by foreign flagged vessels. Only
4,700 entrances or seven percent were made by U.S. flagged vessels.
EPA analysis of MARAD data for vessel entrances into U.S. ports, indicates that a large
percentage of visits made to U.S. ports are made by a relatively small percentage vessels that
make many visits. For example, when looking at those vessels that made at least three entrances
into U.S. ports in 1999, 50 percent of the total entrances made into U.S. ports were made by only
12 percent of the total vessels making visits. Seventy five percent of all the entrances were made
by only 29 percent of the total vessels. This trend was apparent for both, foreign flagged and
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Chapter 3: Industry Characterization
U.S. flagged vessels. This indicates that the majority of the vessels visiting U.S. ports only make
a couple of visits per year, while a relatively small population of vessels are making numerous
visits each year. Figure 3.5-1 is a graph of the number of entrances versus the number of vessels
(U.S. and foreign flagged) for 1999.
3.5.2 Cruise Ship Activity
As stated earlier, in 2000 the worldwide cruise ship fleet included more than 223 ships
that carried an estimated 9.5 million passengers in 1998. In 2000, 8 million embarkations
occurred from ports worldwide. Embarkations from U.S. ports accounted for about 67 percent of
total worldwide embarkations. The port of Miami, Florida alone accounted for 21 percent of
worldwide embarkations. In fact, the port of Miami had more cruise ship embarkations than the
rest of the world combined. Of the top five U.S. ports, three are located in Florida: Miami, Port
Canaveral, and Port Everglades. The other two top U.S. ports are Los Angeles and New York.
These fives ports alone account for 54 percent of worldwide embarkations. Approximately
600,000 or 7.5 percent of worldwide embarkations occur from other U.S. ports located in Alaska,
Louisiana, Massachusetts, Puerto Rico, and Texas.
The cruise industry has seen a large increase in popularity over the last decade and the
number of U.S. embarkations has doubled since 1990. In early 2000, industry analysts were
projecting that the number of embarkations would continue to grow. However, as discussed
above, the recent downturn of the U.S. economy has had an adverse impact on the U.S. tourism
industry. The September 11th attacks exacerbated this impact, and 2001 is expected to be the first
year in a decade in which embarkations actually decrease. At this point it is difficult to predict
when the cruise industry and the number of embarkations will recover from these economic and
political events.
3.6 Conclusion
The Category 3 marine diesel engine and vessels industry is relatively small. In 1998
there were approximately 1,300 Category 3 marine diesel engines produced worldwide. Seventy-
five percent of those engines were manufactured by four companies. None of these engines are
built in the United States. The overwhelming majority of the vessels that use these engines are
built in South Korea, China, and Japan. U.S. shipyards build about one percent of these vessels.
This is mainly due to the shipyard subsidy programs of other countries. Because the U.S. does
not provide similar subsidies most, if not all, of U.S. ships produced are vessels required under
the Jones Act to be built in the United States.
The vast majority of Category 3 vessels that enter U.S. ports are foreign flagged.
Approximately 200 vessels entering U.S. ports in 1999 were U.S. flagged vessels. That
represents about three percent of the total number of vessels entering U.S. ports for that year.
Given that the number of U.S.-flagged vessels is small in comparison to the world fleet, it is
likely that the contribution of U.S. Category 3 vessels to local air pollution in any given port is
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likely to be small compared to that of foreign-flag vessels.
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Chapter 3: Industry Characterization
Chapter 3 References
1. IPC Industrial Press Ltd., Motorship, Jan. 2000.
2. U.S. Census Bureau, Manufacturing Industry Series, NAICS 336611 Ship Building and
Repair. 1997 Economic Census, July 15, 1999.
3. Directory of Marine Diesel Engines, Marine Engineer Review, (MER) April 2001.
4. Annual Analysis, Motorship, June 1999 p. 49-50.
5. ICF Incorporated 1998. "Industry Characterization: Commercial Marine Vessel
Manufacturers," ICF Incorporated, Contract No. 68-C5-00-10, WAN 211, September
1998, Docket A-97-50, Document II-A-03.
6. The Colton Company. Www.coltoncompany.com Accessed on July 26, 2001
7. MARAD. See http://www.marad.dot.gov/MARAD_statistics/Jact_Sum_0401.html
8. ICF Incorporated 1998. "Industry Characterization: Commercial Marine Vessel
Manufacturers," ICF Incorporated, Contract No. 68-C5-00-10, WAN 211, September
1998, Docket A-97-50, Document II-A-03
9. Potomac Institute for Policy Studies. "Maritech Program Impacts on Global
Competitiveness of the U.S. Shipbuilding Industry and Navy Ship Construction." PIPS-
98-4. July 1, 1998.
10. ASA 2001. American Shipbuilding Association. The Defense Shipbuilding Base - An
Industry At Risk. May 2001.
11. ASA 2001. American Shipbuilding Association. The Defense Shipbuilding Base - An
Industry At Risk. May 2001.
12. Potomac Institute for Policy Studies. "Maritech Program Impacts on Global
Competitiveness of the U.S. Shipbuilding Industry and Navy Ship Construction." PIPS-
98-4. July 1, 1998.
13. Transportation Institute, "Industry Profile," http//www.trans-inst.org/ind_profile.html
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Chapter 4: Technological Feasibility
CHAPTER 4: Technological Feasibility
This chapter describes the current state of compression-ignition technology for
Category 3 marine engines and the feasibility of achieving emission reductions for the proposed
Tier 1 NOx standard (which is equivalent to the Annex VI NOx limit) and an additional Tier 2
standard under consideration that would be 30 percent below the proposed Tier 1 standard.
Engine manufacturers are already producing engines that meet the Annex VI NOx limit and
therefore this chapter focuses on technologies under development for meeting the Tier 2 emission
standards under consideration. These technologies generally include internal engine
modifications, fuel injection, internal exhaust gas recirculation and electronic controls. The
combustion process and potential technologies described herein are basically the same for the
Category 3 marine engine types, slow-speed, two-stroke engines or medium-speed four-stroke
engines, and will be differentiated only where significant differences exist. The technologies
described in this Chapter apply to all Category 3 engines, regardless of the flag state of the vessel
in which the engines are ultimately installed. U.S.-flag vessels and foreign-flag vessels would
face the same issues and constraints regarding engines and emission-control technologies.
4.1 Overview of Category 3 Marine Engine Technology
4.1.1 Diesel Engine Emission Formation in Category 3 Marine Engines
Category 3 marine diesel engines operate by compressing and cooling the charge air
before it fills the cylinder where fuel is injected, which auto-ignites under pressure. The charge
air is compressed using a turbocharger under cruising and high loads and possibly a supercharger
driven by the crankshaft at low loads. The charge air is typically cooled in two stages, first with
jacket water and then with a second-stage aftercooler that relies on a seawater heat exchanger.
Fuel is injected with the use of fuel injection pumps on each cylinder. Individual injection
pumps are used so that each cylinder may be independently optimized for peak performance.
The amount of fuel to be injected and fuel injection timing are typically set at cruising speed with
mechanical fuel injection systems.
Many cylinder and injection parameters determine how the fuel and air mix to prepare for
ignition and combustion, including piston head geometry, injection timing and duration, droplet
sizes, and fuel jet momentum. NOx and PM are the emission components of most concern from
diesel engines. High temperatures and excess oxygen are necessary for the formation of NOx.
These conditions are found in a diesel engine as the fuel is injected into an oxygen rich
environment, auto-ignites under pressure and multiple flame fronts spread through the
combustion chamber. Typical diesel engine operation includes very high peak temperatures
shortly after the onset of combustion and the nitrogen in the air combines with available oxygen
to form NOx (the relatively high nitrogen content of fuels for Category 3 engines also contributes
directly to NOx emissions during combustion). Because of the presence of excess oxygen,
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hydrocarbons evaporating in the combustion chamber tend to be completely burned and HC
emission levels remain low. Similarly, CO emissions, which result from incomplete oxidation of
hydrocarbons from the fuel are kept low by the ample supply of oxygen in the cylinder.
As shown in Table 4.1-1, the majority of PM from engines running on heavy fuel oil
(residual fuel) comes from the high level of sulfur in the fuel. The highest portion of PM (by
weight) is from ash, metal, oxides, and sulfates. Carbon soot makes up about a quarter of the
overall PM content. It forms as a result of localized areas where there is not enough oxygen for
complete combustion of fuel droplets while cylinder temperatures are high enough to maintain
combustion. A small amount of PM is also from incomplete evaporation and burning of the fine
fuel droplets or vapor and from small amounts of lubricating oil that escape into the combustion
chamber. Engines that operate on distillate fuel generally have a much lower percentage sulfur
and corresponding lower contribution of sulfates, as shown in Table 4.1-1. Note that the total
amounts of PM in each chart are not the same for the different fuel types.
Table 4.1-1
Comparison of Particulate Emission Composition1
Parameter
Carbon soot
Hydrocarbons (fuel oil,
lubrication oil)
Ash metal (oxides, sulfates)
Typical value
Measurement method
Truck Diesel Engine
Operating on Diesel Oil*
35%
50%
15%
0.15g/kW-hr
ISO 8178
Medium-Speed Diesel Engine
Operating on Heavy Fuel Oil*
25%
10%
65%
0.4 g/kW-hr
ISO 9096
* Values are approximate.
In general, controlling both NOx and PM emissions requires different, sometimes
opposing strategies. The key to controlling NOx emissions is reducing peak combustion
temperatures, since NOx forms at high temperatures. In contrast, the key to controlling PM is
higher temperatures in the combustion chamber or faster burning. This reduces PM by
decreasing the formation of particulates and by oxidizing those particulates that have formed. To
control both NOx and PM, manufacturers need to combine approaches using many different
design variables to achieve optimum performance. However, in Category 3 marine engines,
whose fuel injection timing and fuel pressure is often set at cruising speeds, and not optimized at
lower loads, there may be a possibility of reducing both emissions through the use of common
rail and electronic controls.
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Chapter 4: Technological Feasibility
4.1.2 Category 3 Marine Engine Design and Use
Category 3 marine engines generally fall into one of two distinct types, as shown in
Table 4.1-2. They are either slow-speed, two-stroke engines or medium-speed four-stroke
engines. The slow-speed engines are usually coupled to the ship's propeller shaft without
reduction gears. In contrast, medium-speed engines are used with reduction gears or are used to
generate electricity for both ship propulsion and auxiliary power. Category 3 marine engines are
generally designed for commercial shipping vessels larger than 2,000 dead-weight tons (dwt).
Dead-weight tons is a measure of the weight of a ship at maximum cargo load. The engines are
so large, three stories tall for example, that they are an integral part of the ship's infrastructure.
One unique feature of slow-speed, two-stroke engines is that they generally use a crosshead
piston design. An additional linkage is used in the piston-crank assembly to allow for longer
stroke.
Table 4.1-2: General Characteristics of Category 3 Marine Diesel Engines
Engine Type
slow speed
2-stroke
medium speed
4-stroke
Fuel Type
residual
residual,
distillate
Size Range,
Liter s/cyl
57-2006
30 to 290
Rated Speed
Range, rpm
54 to 250
327 to 750
Stroke/Bore
Ratio
2.38 to 4.17
1.15 to 1171
Number of
Cylinders
4 to 14
5 to 20
Power Range,
Total kW
1,100 to
103,000
1,000 to
18,100
Source: Diesel & Gas Turbine Catalog 20012
Category 3 marine engines are designed for continuous operation, with total annual
operation often exceeding 5,000 hours. These engines are designed to maximize durability and
fuel efficiency, which results in low operating costs. Typical applications for C3 marine engines
include tankers, RO-ROs, container vessels, and cruise ships. The majority of ocean-going
vessels use Category 3 engines for propulsion. Great Lakes and Mississippi River vessels most
often use Category 2 propulsion engines, though some of these vessels continue to use Category
3 propulsion engines. Vessels with Category 3 engines are also used to a lesser extent in coast-
wise service.
The majority of Category 3 marine engines burn heavy fuel oil, also known as residual
fuel. Vessels with these engines have fuel heaters to raise fuel temperatures to 100° or 200° C so
that the fuel can flow through the fuel system for eventual combustion in the engine. Prior to
entering the combustion chamber, the heated fuel passes through a filtration system. Filtration
systems may be uniquely designed for each vessel, but generally include a centrifuge to remove
excess water and a filter to remove larger particles. In addition, vessel operators must verify
engine safety through adjustment of engine injection timing each time they refuel with heavy fuel
oil due to the wide range of fuel qualities in the marketplace.
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Category 3 engines are significantly different from Category 1 and Category 2
commercial marine engines in important ways that affect emissions and emission-control
technologies. Category 3 engine operation is typically characterized by extended operation under
cruising conditions. This high usage rate, combined with the very high power of Category 3
marine engines, makes fuel costs such a significant factor for these vessels. Category 3 engines
therefore have the lowest brake-specific fuel consumption rates (BSFC) of any internal-
combustion engine (as low as 176 g/kW-hr).3'4 Manufacturers achieve this with very high brake
mean-effective pressures (up to 2,200 kPa) and low mean piston speeds (7 to 9 m/s). These
engine parameters maximize mechanical and propeller efficiencies.5 Compared with Category 1
or Category 2 engines, these designs for optimum efficiency result in lower power density (power
output for a given engine weight or cylinder displacement).
This operating profile also has an effect on the tradeoff between NOx and PM emissions.
Maximum engine efficiency typically depends on managing engine and fuel injection parameters
to achieve very high combustion temperatures and pressures, which correspond to maximum
formation of NOx emissions, as described above. These same conditions provide for good
oxidation of any carbonaceous particulate matter remaining in the cylinder after combustion.6
Over the past ten or twenty years, NOx emissions from uncontrolled Category 3 marine engines
have tended to increase with BSFC improvements as engine manufacturers worked to address
ship owners' desire to reduce operating costs. In response to Annex VI, manufacturers have
reduced NOx emissions and have found they are able to keep the same BSFC whereas they may
have improved BSFC if not designing for NOx control.
4.2 General Description of Emission-Control Strategies
Manufacturers have already developed and implemented technologies to reach the Tier 1
standards on some if not most engines and will be shown later in this chapter. The following
sections focus on describing technologies to reach the Tier 2 levels under consideration. These
reflect NOx reductions 30 percent below the Tier 1 standards. The technologies available to
reduce exhaust emissions from Category 3 marine engines include better fuel and ignition
control, combustion optimization, and improved charge air characteristics. The costs associated
with applying these technologies to marine engines are considered in the next chapter. More
advanced technologies are discussed in Chapter 8 of this draft RSD.
4.2.1 Combustion Optimization
Several parameters in the combustion chamber of a heavy-duty diesel engine affect its
efficiency and emissions. These engine parameters include fuel injection timing, combustion
chamber geometry, compression ratio, valve timing, turbulence, injection pressure, fuel spray
geometry and rate, peak cylinder temperature and pressure, and charge air temperature and
pressure. Some strategies are not directly related to improving control of NOx emissions, but are
included in this discussion because of their potential to prevent increases in fuel consumption or
HC or PM emissions resulting from NOx-related emission controls
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4.2.1.1 Fuel Injection Timing and Electronic Control
Advanced timing is typically used for optimum fuel consumption. In advanced timing the
fuel is injected early and mixes substantially before ignition, resulting in very rapid initial
combustion and a sharp spike in cylinder temperatures and correspondingly high NOx emissions.
Once combustion begins, fuel injection continues while combustion changes to diffusion
burning, in which a relatively constant heat release results in significantly lower burn
temperatures. Retarded timing reduces NOx emissions because the premixed burning phase is
shortened and because cylinder temperature and pressure are lowered.7 Timing retard, however,
increases HC, PM, and fuel consumption, because the end of injection comes later in the
combustion stroke where the time for extracting energy from fuel combustion is shortened and
the cylinder temperature and pressure are too low for effective oxidation of PM. Timing retard in
combination with other fuel injection upgrades can delay the start of injection without changing
the end of the combustion event.8 This can be accomplished by using increased injection
pressure, optimized nozzle geometry, or rate shaping. Combining technologies in this way
allows for substantial NOx reductions while minimizing the negative impacts on fuel
consumption or HC and PM emissions.
Most Category 3 engines currently use mechanical systems to adjust injection timing.
Timing is set based on optimal performance and engine durability at the vessel's cruising speed,
where the ship operates most frequently and combustion pressure and temperature are the
highest. Optimizing fuel injection timing for NOx emissions at points other than cruising speed
is generally impractical unless the engine is electronically controlled or has a simplified
mechanical system which can be adjusted while the engine is in operation. Electronic controls
are being developed and have been implemented on at least one vessel. Section 4.2.4 describes
this in further detail.
As vessels move toward shore they begin to slow their engines. In the case of cruise
ships or other vessels with electric-drive propulsion from multiple engines, engines may be shut
down individually for decreased propulsion power approaching port. As vessels enter the
mileage limit for compliance with EPA NOx emissions, engines must meet emission standards.
Operators may show this by measuring NOx emissions at a known speed and power, comparing
the measured emission level with that required for that speed and power. An onboard NOx
measurement would enable operators to ensure compliance by adjusting injection timing or other
parameters as needed to keep emission levels controlled appropriately. For the engines that are
slowed from cruising speed where fuel injection timing is set, the engine cylinders may again
need to be adjusted. EPA assumes this is not currently common practice with engines that have
mechanical controls, but such an adjustment could be made easily for an engine with electronic
controls. For vessels in which engines are shut down one by one, the engines that continue
operating likely don't experience a big change in operating speeds, so readjusting may not be
necessary.
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4.2.1.2 Combustion Chamber Geometry
Parameters within the combustion chamber geometry that yield reduced emissions
include the shape of the chamber and reduced crevice volumes. Listed below are excerpts from
several sources which describe their experiences with this concept.
One manufacturer states, "Cylinder heads with flat bottoms were found to avoid the
danger of deposition of the fuel with its negative effects on soot emission at low load.
Combustion chambers with small dead volumes have a favorable effect on the possible
utilization of the air during operation under conditions with low excess air ratios."9
Others state that in comparison with a wide, open bowl, the smaller inner diameter bowls
are designed to generate jet/piston interaction that retards the combustion process.10 The slower
burning rate leads to lower NOx. At the end of combustion the piston bowls with smaller
diameter generate a faster burning rate due to a higher turbulence level generated during the
jet/piston interaction and therefore to more efficient soot oxidation. One researcher found also
found that a piston with a wide bowl and raised central hump, along with increased compression
ratio, represents the best compromise with regard to low-load smoke emission, full-load fuel
consumption and NOx emissions.11
4.2.1.3 Compression Ratio
Increasing the compression ratio can lower NOx levels by increasing the density of the
intake air in the combustion chamber. Redesigning the piston crown or increasing the length of
the connecting rod or piston pin-to-crown length could raise the compression ratio.12 There is a
limit to the benefit of higher compression ratios because of increased combustion pressure and
the limits on engine cylinder safety. One manufacturer demonstrated a 35-percent reduction in
NOx emissions without increasing fuel consumption by increasing peak cylinder pressure 10
percent.13 This increase in pressure was achieved with a compression ratio of 17. The authors
reported that a long-stroke engine has the ideal conditions for a compact combustion
space—smooth surfaces and no corners with difficult access for the fuel jet. Such high
compression ratios also demand reduced valve overlap to avoid valve pockets in the piston
crown. Reducing valve overlap increases the residual gas proportion in the combustion space
due to the lower scavenging efficiency. This further reduces NOx emissions by incorporating a
degree of internal exhaust gas recirculation, as described later in this chapter. The boost pressure
and therefore the firing pressure of the engine must be increased to maintain the low exhaust gas
temperatures necessary for reliable operation with heavy oil.
4.2.1.4 Valve Timing
Medium speed-four-stroke engines employ valves in their design whereas 2-stroke
generally operate with ports. This technology is only relative for designs with valves. The
efficiency of a diesel engine generally increases with its expansion ratio14 because more work is
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generated by the engine for a given stroke. If the intake and exhaust valves are closed during the
compression stroke, the compression ratio is equal to the expansion ratio. Although a high
expansion ratio is desirable, the corresponding compression ratio is limited by material strength
and NOx formation at high pressures and temperatures.
In an engine-design strategy known as the Miller (or Atkinson) cycle, valve timing is
planned to increase the expansion ratio without increasing the compression ratio. In a standard
diesel engine design, the intake valve opens shortly before the piston reaches top dead center and
stays open until the piston is near bottom dead center. This allows the most time to force air into
the cylinder, which helps maximize volumetric efficiency. In a Miller cycle engine, the intake
valve is kept open well beyond bottom dead center. This reduces the amount of pressure
generated during the compression stroke, thereby allowing a greater expansion ratio. Enhanced
turbocharging or supercharging is required to offset the resulting loss in volumetric efficiency,
Several engine manufacturers are using a "semi-Miller cycle" to reduce fuel consumption
and emissions from Category 2 and Category 3 propulsion engines by slowing the intake valve
seating and increasing the boost pressure. Coupled with timing retard, one manufacturer reduced
NOx by more than 10 percent while simultaneously reducing fuel consumption by 3 percent.15
This manufacturer reported that slowing the valve seating extended the life of the valve seat.
Another manufacturer uses intake and exhaust valve timing to reduce pumping losses, which
reduces fuel consumption without increasing NOx emissions in Category 1 and 2 auxiliary
engines.16 A third manufacturer retarded the intake valve closing by 20 degrees and increased the
boost pressure by 7 percent, resulting in a 10-percent reduction in NOx emissions and unchanged
fuel consumption rates.17
4.2.1.5 Swirl
Increasing the turbulence of the intake air entering the combustion chamber (i.e., inducing
swirl) can improve the mixing of air and fuel in the combustion chamber. Swirl can be induced
by routing the intake air to achieve a circular motion in the cylinder or by designing piston
geometry for increased turbulence during the compression stroke. Swirl generally has
advantages for reducing PM emissions and improving fuel consumption, but can be used in
combination with other fuel injection strategies for controlling NOx emissions. For example,
combining timing retard or rate shaping strategies to delay the onset of combustion can be done
with minimal negative effects by using swirl to increase the burn rate.18
4.2.2 Improving Charge Air Characteristics
Category 3 engines rely on turbochargers, sometimes in combination with superchargers,
to compress the charge air, improving the power capability of the engine. Cooling the
compressed charge air (aftercooling) increases its density, allowing further improvements in
power and fuel consumption. Aftercooling also lowers NOx emissions by reducing combustion
temperatures. Manufacturers have already incorporated extensive use of turbocharging and
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aftercooling. To the extent that manufacturers can improve aftercooling technologies, this would
serve to further reduce NOx emissions.
An additional factor related to aftercooling is the water that condenses out of the charge
air. Depending on the humidity of the ambient air and the amount of aftercooling, this can
involve very large quantities of water. Manufacturers have found ways to divert the water from
the engine for disposal, though this same water may be available for separate use for other
emission-control technologies (see Chapter 8).
4.2.3 Exhaust Gas Recirculation
Exhaust gas recirculation (EGR) is a recent development in diesel engine control
technology for obtaining significant NOx reductions. EGR reduces peak combustion chamber
temperatures by slowing reaction rates and absorbing some of the heat generated from
combustion. While NOx emissions are reduced, PM and fuel consumption can be increased,
especially at high loads, because of the reduced oxygen available and longer burn times during
combustion.19'20
There are several methods of controlling any increase in PM emissions attributed to EGR.
One method of minimizing PM increases is to reduce the flow of recirculated gases during high-
load operation, which would also prevent a loss in total power output from the engine. Recent
experimental work on a four-stroke high-speed diesel engine showed NOx reductions of about 50
percent, with little impact on PM emissions, using just six percent EGR in conjunction with a
strategy of multiple injections.21 Another method is to cool the exhaust gas recirculated to the
intake manifold. By cooling the recirculated gas, it takes up less volume allowing more room for
fresh intake air. With EGR cooling, a much higher amount of exhaust gas can be added to the
intake charge. At light loads, there can be a small NOx penalty due to increased ignition delay,
but at high loads, some additional NOx reduction may result from EGR cooling.22 A third
method to offset the negative impacts of EGR on PM is through the use of high intake air boost
pressures. By turbocharging the intake air, exhaust gas can be added to the charge without
reducing the supply of fresh air into the cylinder.23
Exhaust gas recirculation has also been shown on a slow-speed two-stroke engine, in
conjunction with direct water injection, to achieve a 70% reduction in NOx.24 Without EGR,
only a 50% reduction in NOx was achieved. In a separate engine, six percent EGR dilution with
a slow-speed two-stroke engine reduced NOx emissions by 22 percent.25 In these cases, internal
EGR was used by decreasing the efficiency of the scavenging process and trapping additional
exhaust gas in the cylinder. The use of internal EGR has two primary advantages. First, the
benefits of EGR can be achieved without any additional hardware such as lines and valves,
thereby reducing the costs and complexity of the system. Second, routing the exhaust gas into
the intake stream could cause soot to form deposits in the intake system, leading to wear on the
turbocharger or a decrease in the efficiency of the aftercooler. As the amount of soot in the
cylinder increases, so does the amount of soot that works its way past the piston rings into the
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lubricating oil, which can lead to increased engine wear. Another concern with routing the
exhaust into the intake stream, especially for engines operating on residual fuel, would be
corrosion in the intake system if the sulfur in the exhaust gas were to condense and form sulfuric
acid. Using internal EGR avoids these problems.
4.2.4 Fuel Injection
Control of the many variables involved in fuel injection is central to any strategy to
reduce diesel engine emissions. The principal variables being investigated are injection pressure,
nozzle geometry (e.g., number of holes, hole size and shape, and fuel spray angle), the timing of
the start of injection, and the rate of injection throughout the combustion process (e.g., rate
shaping). Common rail, with a control system that allows for electronic change of injection
timing, is also a useful technology that is currently being used to decrease NOx.
4.2.4.1 Fuel Injection Pressure
Particle emissions and fuel consumption generally go down with increasing injection
pressure.26 Increasing the injection intensity, combined with a NOx-neutral increase of
compression ratio and peak pressure, may best balance competing demands for controlling low-
load smoke emissions, fuel consumption, and NOx emissions.27
Manufacturers continue to investigate new injector configurations for nozzle geometry
and higher injection pressure (in excess of 2300 bar (34,000 psi)).28'29 Increasing injection
pressure achieves better atomization of the fuel droplets and enhances mixing of the fuel with the
intake air to achieve more complete combustion. Though HC and PM are reduced, higher
cylinder pressures can lead to increased NOx formation.30 However, in conjunction with
retarding the start of fuel injection, higher fuel injection pressures can lead to reduced NOx
because of lower combustion temperatures. HC, PM, or fuel economy penalties from this
strategy can be avoided because the termination of fuel injection need not be delayed. Nozzle
geometry is used to optimize the fuel spray pattern for a given combustion chamber design to
improve mixing with the intake air and to minimize fuel condensation on the combustion
chamber surfaces.31
4.2.4.2 Nozzle Geometry
Nozzle geometry is a very important parameter for combustion development.32 Injection
duration, droplet sizes and fuel jet momentum are responsible for the quality of the mixture
formation. The nozzle-hole intake is hydro-grinded to optimize the flow. Graphs can be made of
specific fuel consumption (number of holes and effective nozzle flow area) and particle emission
as a function of effective nozzle-flow area. This determines the fuel mass flow rate and therefore
the burning rate and mixture formation. Particle emission and fuel consumption show distinct
minima for slightly different nozzle flow areas. If mixture formation is supported by jet/piston
interaction, nozzle protrusion and spray-elevation angle have to be optimized in relation to the
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piston bowl used. This technology, in combination with engine tuning, was used by one engine
manufacturer to achieve IMO levels. The fuel injection nozzles were designed to optimize spray
distribution in the combustion chamber but without compromising on component temperatures
and thereby engine reliability. A graph supplied in the reference paper shows a maximum
reduction of approximately 18% NOx.33
The same manufacturer states their experience with testing of mini sac nozzles that they
had developed. "Tests have shown that the main source of smoke and soot deposits is the fuel
trapped into the fuel injector sac hole which enters the combustion chamber in an uncontrolled
way during the expansion stroke. One manufacturer has developed a new "mini sac hole" fuel
nozzle concept. Testbed results have shown, as expected, a remarkable reduction of smoke and
hydrocarbon (HC) emissions, slightly better fuel consumption and only a marginal influence on
NOx emissions."34 Results were 50-70% reduction in HC, 30-50% reduction in smoke with fuel
consumption slightly better (-0.5 g/kWh) and combustion chamber temperatures on the same
level as before. At the time of the paper (CEVIAC Congress 2001), such fuel injectors were in
field tests to confirm their reliability.
4.2.4.3 Controlling the Timing and Rate of Injection
The most recent advances in fuel injection technology are the systems that use rate
shaping or multiple injections to vary the delivery of fuel over the course of a single injection.
Igniting a small quantity of fuel initially limits the characteristic rapid increase in pressure and
temperature that leads to high levels of NOx formation. Injecting most of the fuel into an
established flame then allows for a steady burn that limits NOx emissions without increasing PM
emissions. Rate shaping may be done either mechanically or electronically. Rate shaping has
been shown to reduce NOx emissions by up to 20 percent.35
For electronically controlled engines, multiple injections may be used to shape the rate of
fuel injection into the combustion chamber. Recent advances in fuel system technology allow
high-pressure multiple injections to be used to reduce NOx by 50 percent with no significant
penalty in PM. Two or three bursts of fuel can come from a single injector during the injection
event. The most important variables for achieving maximum emission reductions with optimal
fuel economy using multiple injections are the delay preceding the final pulse and the duration of
the final pulse.36 This strategy is most effective in conjunction with retarded timing, which leads
to reduced NOx emissions without the attendant increase in PM.
4.2.4.4 Common Rail
The main advantages of common rail injection systems and corresponding engine control
system are the flexible injection timing and the high variable injection pressure within the whole
performance map.37 Common rail systems for Category 3 medium speed and low speed engines
are being designed and implemented by at least one of the engine manufacturers for this category.
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MEDIUM SPEED: A common rail system for medium speed engines basically consists
of four components: the pump, the common rail, the injector and the control unit. The pump is
used to fill the common rail with fuel and maintain the pressure at the level requested by the
control unit can vary between 900-1500 bar depending on the optimum for a specific operating
point. The pump can be either a single pump consisting of several pumping elements driven by
the crankshaft through a gear, or camshaft- driven jerk pumps similar to the conventional
injection pumps. The pumps can be speeded up by employing two or more cam lobes per pump
and this way the size and number of pumps can be reduced significantly. The accumulator
stores the pressurized fuel.
A design by one manufacturer has some unique features that will now be discussed.38
The common rail pipe is split into several smaller volumes interconnected with parts with a
relatively small flow area rather than one pipe. The advantages of this include 1) the
accumulator volume can be concentrated close to the injectors, 2) the accumulators can be
standardized and easy to manufacture, the accumulator and one pump serve two cylinders and,
3) the system can be easily shielded and any fuel leakages collected in a separate drain system.
The injector employs servo oil actuation for fuel injection control rather than direct fuel oil
actuation. This is done to assure the life of the solenoid armature which can be affected by high
temperatures such as the temperature of heavy fuel oils (150C+). In addition, to assure the
injection will not be affected by erosion wear and clogging of the small drillings. The design
also does not have the rail (accumulator) pressure prevailing at the nozzle seat in between the
injection events. The main reason is to avoid leaking nozzles for a large amount of fuel could
leak into the cylinder since the non-injection period represents more than 95% of the total. The
injector also has a "rail pressure aided needle closing" which ensures fast opening of the needle
when the pressure in the nozzle is high enough and equally fast closure of the needle at the end of
injection. This ensures combustion control and smokeless operation. The control unit controls
the timing and the quantity of the injected fuel and controls the refilling and pressure in the
accumulators. It also takes care of major safety functions like pre-circulation, over pressure
protection, pressure evacuation at emergency stop, etc. Software goes through several iterations
in parallel with testing and optimization on the engine to assure stable software that is easy to
configure for various application needs.
LOW SPEED: One common rail system for low speed engine has recently come into the
marketplace and is currently powering a low speed bulk carrier that completed its sea trials in
September 2001. As stated by the manufacturer in the reference material "The common rail is a
manifold running the length of the engine at just below the cylinder cover level. It provides a
certain storage volume for the fuel oil, and has provision for damping pressure waves. The
common-rail injection system is fed by heated fuel oil at the usual high pressure (nominally 1000
bar) ready for injection. The supply unit has a number of high pressure pumps running on multi-
lobe cams. The pump design is based on the proven injection pumps used in the manufacturer's
four-stroke engines. Fuel is delivered from the common rail through a separate injection control
unit for each engine cylinder to the standard fuel injection valves, which are hydraulically
operated in the usual way by the high pressure fuel oil. The control units, using quick acting rail
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valves by the engine manufacturer, regulate the timing of fuel injection, control the volume of
fuel injected, and set the shape of the injection pattern. The three fuel injection valves in each
cylinder cover are separately controlled so that they may be programmed to operate separately or
in unison as necessary. The common rail system is built for operation on the grades of heavy fuel
oil available today. The key features of the common rail system are thus: precise volumetric
control of fuel injection, with integrated flow-out security, variable injection rate shaping and
free selection of injection pressure, ideally suited for heavy fuel oil, well proven, high efficiency
supply pumps, lower levels of vibration and internal forces and moments, steady operation at
very low running speeds with precise speed regulation and no visible smoke at any operating
speed."39
In addition to fuel injection, the system incorporates exhaust valve actuation and starting
air control. The exhaust valves are operated with hydraulic pushrod, but with the actuating
energy combing from a servo oil rail at 200 bar pressure. "The servo oil is supplied by high
pressure hydraulic pumps incorporated in the supply unit with the fuel supply pumps. The
electronically controlled actuating unit for each cylinder gives full flexibility for valve opening
and closing patterns."40
The system is controlled and monitored through the manufacturer developed electronic
control system. The modular system with separate microprocessor control units for each cylinder
and overall control and supervision by duplicated microprocessor control units, which provides
the usual interface for the electronic governor and the shipboard remote control and alarm
system. The common rail system replaces some parts such as mechanical injection pumps
(setting the engine is simplified).
The manufacturer claims that this system may provide selective injection patterns to give
shipowners the option of 20% lower NOx emissions when NOx control is required (fuel
consumption increases) and may be set for fuel economy in areas where NOx control is not
required.
4.2.4.5. Electronic-Hydraulic Control of Fuel Injection and Exhaust Valve
Actuation
One manufacturer has installed an electronically controlled cam-less engine using an in-
house developed electronic-hydraulic platform on a 37,500 dwt deep sea chemical carrier.41 The
system allows for electronically controlled fuel injection and exhaust valve actuation which
permit individual and continuous adjustment of the timing for each cylinder. Parts that are
removed from the mechanical system include the chain drive for camshaft, camshaft with fuel
cams, exhaust cams and indicator cams, fuel pump actuating gear, including roller guides and
reversing mechanism, conventional fuel injection pumps, exhaust valve actuating gear and roller
guides, engine driven starting air distributor, electronic governor with actuator, regulating shaft,
mechanical, engine driven cylinder lubricators, engine side control console. The items added to
the engine include a hydraulic power supply, hydraulic cylinder unit with electronic fuel injection
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and electronic exhaust valve activation, electronic alpha cylinder lubricator, electronically
controlled starting valve, local control panel, control system with governor, condition monitoring
system. Two electronic control units are used to control the system with one being a backup for
the first. The manufacturer claims that the electronic version of the engine was very easy to
adjust to the prescribed setting values and was able to keep the very satisfactory setting values
without further adjustments since the vessel's sea trials in November of 2000.
A second manufacturer has further developed their mechanically-actuated electronically-
controlled unit injectors and hydraulically actuated electronically-controlled unit injectors to
provide the flexible fuel injection characteristics needed to optimize engine performance and
emissions.42 The manufacturer states that the design approach in both injector concepts is to
utilize a Direct Operated Check (DOC) to precisely control the pressure, timing and delivery of
fuel. The DOC is applicable to electronic unit injector or unit pump configurations with either
mechanical or hydraulic actuation of the pressurizing units. The manufacturer has claimed the
technology eliminates spray distortion and minimizes parasitic losses which may be seen in
common rail fuel systems. The manufacturer includes discussion on closed loop NOx control in
the reference paper. They state that ultra fast NOx sensors are a key part to closed-loop control
of NOx emissions. The sensors provide the benefits of minimized engine to engine variations,
minimized cylinder to cylinder variations and improved transient response with reduced emission
and reduced operational costs.
4.2.5 Electronic Control
Various electronic control systems are in use or under development for nonroad,
locomotive, highway, and marine diesel engines. Use of electronic controls enables designers to
implement much more precise control of the fuel injection system and is especially beneficial for
advanced concepts such as rate shaping. Through this precise control, trade-offs between various
control strategies can be minimized. In addition, electronic controls can be used to sense ambient
conditions and engine operation to maximize performance and minimize emissions over a wide
range of conditions such as transient operation of the engine. Electronic control is already used
in limited marine applications including vessels mentioned in the section above.
4.2.6 Lube Oil Consumption
Many of the Category 3 marine diesel engine manufacturers are working to reduce the
consumption of lubricating oil from their engines, because customers are pressing to reduce
operating costs. Highway diesel engines have greatly reduced HC and PM emissions by
decreasing oil consumption. This is especially relevant for highway engines, because half or
more of uncontrolled PM emissions can be attributed to lubricating oil.
This is not the case for Category 3 marine engines operating on residual fuel. The high
concentration of ash in residual fuel dominates PM emissions; therefore, a much smaller
percentage of the PM mass comes from the oil (see Figure 4.2-1). Reducing oil consumption in
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Category 3 marine engines will decrease PM emissions to a lesser degree than the same kind of
improved oil control in highway diesel engines.
4.2.7 Distillate Fuel
The use of distillate fuel has the potential to further increase NOx emissions. Residual
fuel typically has an amount of elemental nitrogen bound up in the fuel, which likely participates
more actively in the combustion reactions than airborne, molecular nitrogen. Also, poor ignition
quality of residual fuel leads to increased ignition delay and higher peak temperatures. Marine
fuels are discussed in more detail later in chapter 8.
4.2.8 Emission-Controls and System Approaches
Table 4.2-3 identifies several technologies that individual manufacturers have already
incorporated to reduce emissions and may likely be used to meet the proposed Tier 1 standards
and the second tier of emission standards currently under consideration. The table also identifies
several technologies that are beginning to gain field experience on engines in-use and can be
used to meet such a second tier of standards.
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Table 4.2-3: "In-Engine" Combustion Process Changes Currently In-Use or
Being Investigated by Marine Diesel Engine Design and Manufacturing Companies43
Component or
Operation Changed
Change
Parameter Affected
Slow-
Speed 2-
Stroke
Medium
Speed 4-
Stroke
Tier 1 and Tier 2
turbocharger
intercooler
air inlet port
cylinder head
piston crown
injection pressure
injectors
nozzle
exhaust valve timing
improved efficiency, variable
flow
improved efficiency
redesign shape
redesign shape
redesign piston crown shape
increase
redesign
hole geometry & number
"Miller cycle" timing
SFC, intake pressure
air inlet temperature
swirl
swirl, compression ratio
swirl, compression ratio
atomization
low sac, injection rate
shaping
spray pattern changes
peak cylinder temperature
Yes
Yes
Maybe
Maybe
No
Yes
Yes
Possibly
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Tier 2
electronic control
common rail injection
injection timing
replaces mechanical control
replace unit injection
retard and/or vary with load
engine operation, SFC
higher fuel pressure (all
loads)
peak cylinder temperature
Yes
Yes
Yes
Yes
Yes
Yes
Table 4.2-4 summarizes published results showing emission reductions associated with
application of specific combinations of emission-control technologies manufacturers have
adopted to reduce NOx emissions below Annex VI standards.
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Table 4.2-4: Summary of "In-Engine" NOx Reduction Techniques and NOx Reductions
Achieved from IMP Listed by Manufacturer from Selected 2001 References
Mfr.
Wartsila44
Caterpillar45
(MaK)
FMC46
Yanmar47
Engine
Model
4-stroke
4-stroke
4524
4-stroke
In-Engine changes
Retard injection
Miller cycle valve timing Higher
compression ratio Increased turbo
efficiency Higher max cyl
pressure Common rail injection
Higher compression ratio
Higher cylinder pressure
Higher charge pressure
Flexible injection system
Two stage injection
Miller cycle valve timing Greater
stroke/bore ratio
Adjustable compression
Two stage turbocharger
Low intake temperature
Retard injection
Shorter combustion time
Higher compression ratio
Higher boost pressure
Reduced nozzle hole size
Increased number of holes
NOx Red
from IMO
40%
33%
34%
met IMO std
SFC Change
unknown
0
-2%
5% or greater
4.3 Anticipated Technology to Meet Emission Standards
This section describes how we think manufacturers can draw from the catalog of
available technologies described above to meet emission standards.
4.3.1 Tier 1 (Annex VI) Standards
Engine manufacturers are meeting the MARPOL Annex VI standards today with a variety
of emission-control technologies. Table 4.2-4 identifies several technologies that individual
manufacturers have already incorporated to reduce emissions. No individual engine relies on all
the listed technologies, but manufacturers have shown that each of the technologies can be used
effectively. The most common approach has been to focus on increased compression ratio,
adapted fuel injection, valve timing and different fuel nozzles to trim NOx emissions.
Manufacturers have generally been able to do this with little or no increase in fuel consumption.
4-16
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Chapter 4: Technological Feasibility
4.3.2 Additional Tier 2 Standards
As listed in Table 4.2-3, manufacturers have a wide range of technologies and strategies
available to reduce emissions below Tier 1 standards. In making specific projections regarding
technologies that could be used to meet Tier 2 standards under consideration (30 percent NOx
reduction from Tier 1), many of these can be treated together for consideration of related
changes.
First, all manufacturers could upgrade their engines to better control fuel-injection
variables. This can be done through incorporation of common rail with electronic controls in
which the engine can have flexible injection timing with high injection pressure within the whole
engine map48. We expect manufacturers would implement a degree of timing retard, but
simultaneously making other changes to offset any negative effects of the delayed timing.
Electronic controls with rate-shaping capability would be one example.
Category 3 Marine engines are already operating with sophisticated turbocharging and
aftercooling systems, but some manufacturers would likely find ways to optimize both
turbochargers and aftercoolers to reduce emissions. The aftercooler especially provides a potent
means of controlling NOx emissions, without compromising engine performance.
Adjusting valve timing and the location of intake ports to vary expansion and
compression ratios is another air-handling approach that holds promise for reducing NOx
emissions. We expect that many manufacturers would pursue this technology to varying degrees.
These same parameters can be adjusted to recirculate small amounts of exhaust gases into the
cylinder, which alone can substantially reduce NOx emissions.
Reviewing the combustion chamber's design involves consideration of several different
variables, including higher compression ratios, piston geometry, and injector location. These
fundamental parameters affect the compression and mixing of the fuel-air mixture before and
during combustion, which may greatly affect emission formation during the combustion event.
Test data in Table 4.2-3 show that these technologies can reduce emissions up to 40
percent below Annex VI standards.49 We believe manufacturers could incorporate emission-
control technologies to achieve a 30-percent reduction below Annex VI standards for all their
Category 3 Marine engines. Engine manufacturers have affirmed that this level of control is
achievable.50 A 30-percent reduction would allow for a compliance margin for manufacturers to
ensure that they meet emission standards consistently with all the engines they produce in an
engine family. This would also allow for manufacturers to show that they meet emission
standards under the range of prescribed testing and operating conditions, as described above,
including measures to cap emission levels at low-power modes. These technologies, and
accompanying emission data, are described in more detail in the preceding sections of this
chapter. Chapter 5 adds specific detail regarding our estimated deployment of each of the
targeted control technologies to develop costs estimates related to the Tier 2 emission standards
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Draft Regulatory Support Document
under consideration.
4.4 Impact on Noise, Energy, and Safety
The Clean Air Act requires EPA to consider potential impacts on noise, energy, and
safety when establishing the feasibility of emission standards. One important source of noise in
diesel combustion is the sound associated with the combustion event itself. When a premixed
charge of fuel and air ignites, the very rapid combustion leads to a sharp increase in pressure,
which is easily heard and recognized as the characteristic sound of a diesel engine. The
conditions that lead to high noise levels also cause high levels of NOx formation. Fuel injection
changes and other NOx control strategies therefore typically reduce engine noise, sometimes
dramatically.
The impact of the new emission standards on energy is measured by the effect on fuel
consumption from complying engines. Many of the Marine engine manufacturers are expected
to retard engine timing which, by itself, increases fuel consumption somewhat. Most of the
technology changes anticipated in response to the new standards, however, have the potential to
reduce fuel consumption as well as emissions. Redesigning combustion chambers, incorporating
improved fuel injection systems, and introducing electronic controls provide the engine designer
with powerful tools for improving fuel efficiency while simultaneously controlling emission
formation.
There are no apparent safety issues associated with the new emission standards. Marine
engine manufacturers have or are currently proving the technologies in the field.
4-18
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Chapter 4: Technological Feasibility
Chapter 4 References
1. Paro, Daniel, "Development of the Sustainable Engine", International Council on
Combustion Engines, CIMAC Congress 2001, Docket A-2001-11 Item U-A-13.
2. Diesel & Gas Turbine Worldwide Catalog, 66th Annual Product & Buyer's Guide for Engine
Power Markets, 2001 Edition, Docket A-2001-11, Item U-A-48 .
3. Gilmer, Johnson, Introduction to Naval Architecture. U.S. Naval Institute, 1992, p. 251.
4. Taylor, C., The Internal Combustion Engine in Theory and Practice. MIT Press, 1990, p. 448.
5. Heywood, J., Internal Combustion Engine Fundamentals. McGraw-Hill, New York, 1988, p.
887.
6. Primus, R., Hoag, K., "Fundamentals of Reciprocating Engine Performance-Class Notes,"
Prepared August 1995.
7. Herzog,P., Burgler,L., Winklhofer, E., Zelenda, P., and Carterllieri, W., "NOx Reduction
Strategies for DI Diesel Engines," SAE Paper 920470, 1992, Docket A-2001-11, Item U-A-46.
8. Okada, S., et. al., "The Development of Very Low Fuel Consumption Medium Speed Diesel
Engine," International Council on Combustion Engines, CIMAC Congress 2001, Docket A-
2001-11, Item H-A-04.
9. Heider, Guenter and Eilts, Peter of MAN B&W "Improving the Soot-NOx-BSFC Trade-Off of
Medium Speed, 4-Stroke Diesel Engine", International Council on Combustion Engines, CIMAC
Congress 2001, Docket A-2001-11, Item U-A-05.
10. Philipp, Schneemann, Willmann, Kurreck, "Advanced Optimisation of Common-Rail Diesel
Engine Combustion", International Council on Combustion Engines, CIMAC Congress 2001,
Docket A-2001-11, Item U-A-03.
11. Heider, G., Eilts, P., "Improving the Soot-NOx-BSFC Trade-Off of Medium Speed, 4-Stroke
Diesel Engine," International Council on Combustion Engines, CIMAC Congress 2001, Docket
A-2001-11, Item II-A-05.
12. Acurex Environmental Corporation, "Estimated Economic Impact of New Emissions
Standards for Heavy-Duty Highway Engines," prepared for U.S. EPA, March 26, 1996.
13. Schlemmer-Kelling, U., Rautenstrauch, M., "The New Low-Emission Heavy Fuel Oil
Engines of Caterpillar Motoren," International Council on Combustion Engines, CIMAC
Congress 2001, Docket A-2001-11, Item U-A-02.
4-19
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Draft Regulatory Support Document
14. Heider, Guenter and Eilts, Peter of MAN B&W, "Improving the Soot-NOx-BSFC Trade-Off
of Medium Speed, 4-Stroke Diesel Engine", International Council on Combustion Engines,
CIMAC Congress 2001, Docket A-2001-11, Item II-A-05.
15. Sato, Takeyuki, et. al., "Development of'NEO' Medium Speed Diesel Engines,"
International Council on Combustion Engines, CIMAC, 2001 Congress, Docket A-2001-11, Item
II-A-06.
16. Okada, Shusuke, et. al., "The Development of a Very Low Fuel Consumption Medium
Speed Diesel Engine," International Council on Combustion Engines, CIMAC, Congress 2001,
Docket A-2001-11, Item H-A-04.
17. Schlemmer-Kelling, U., Rautenstrauch, M., "The New Low-Emission Heavy Fuel Oil
Engines of Caterpillar Motoren," International Council on Combustion Engines, CIMAC
Congress 2001, Docket A-2001-11, Item H-A-02.
18. Bazari, Z., French, B., "Performance and Emissions Trade-Offs for a HSDI Diesel Engine -
An Optimization Study," SAE Paper 930592, 1993, Docket A-2001-11, Item H-A-38.
19. Herzog, P., Burgler, L., Winklhofer, E., Zelenda, P., and Carterllieri, W., "NOx Reduction
Strategies for DI Diesel Engines," SAE Paper 920470, 1992, Docket A-2001-11, Item H-A-46.
20. Piedpont, D., Montgomery, D., Reitz, R., "Reducing Particulate and NOx Using Pilot
Injection," SAE Paper 950217, 1995.
21. Montgomery, D. and Reitz, R., "Six-Mode Cycle Evaluation of the Effect of EGR and
Multiple Injections on Particulate and NOx Emissions from a D.I. Diesel Engine," SAE Paper
960316, 1996, Docket A-2001-11, Item H-A-43.
22. Herzog, P., Burgler, L., Winklhofer, E., Zelenda, P., and Carterllieri, W., "NOx Reduction
Strategies for DI Diesel Engines," SAE Paper 920470, 1992, Docket A-2001-11, Item H-A-46.
23. Uchida, N., Daisho, Y., Saito, T., Sugano, H., "Combined Effects of EGR and Supercharging
on Diesel Combustion and Emissions," SAE Paper 930601, 1993, Docket A-2001-11, Item II-A-
42.
24. Aeberli, Kaspar, et. al., "The Sulzer RTA-Low Speed Engine Range: Today and in the
Future," International Council on Combustion Engines, CIMAC Congress 2001, Docket A-2001-
ll,ItemII-A-07.
25. Mikulicic, N. "Exhaust Emissions: Next Steps for Low-speed Two-stroke Engines," Marine
News, 1999, No. 3.
26. Philipp, Schneemann, Willmann, Kurreck, "Advanced Optimisation of Common Rail Diesel
Engine Combustion," International Council on Combustion Engines, CIMAC Congress 2001,
4-20
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Chapter 4: Technological Feasibility
Docket A-2001-11, Item H-A-03.
27. Heider, G., Eilts, P., "Improving the Soot-NOx-BSFC Trade-Off of Medium Speed, 4-Stroke
Diesel Engine," International Council on Combustion Engines, CIMAC Congress 2001, Docket
A-2001-11, Item II-A-05.
28. Bazari, Z., French, B., "Performance and Emissions Trade-Offs for a HSDI Diesel Engine -
An Optimization Study," SAE Paper 930592, 1993, Docket A-2001-11, Item H-A-38.
29. Pierpont, D., Reitz, R., "Effects of Injection Pressure and Nozzle Geometry on DI Diesel
Emissions and Performance," SAE Paper 950604, 1995, Docket A-2001-11, Item II-A-41.
30. Herzog, P., Burgler, L., Winklhofer, E., Zelenda, P., and Carterllieri, W., "NOx Reduction
Strategies for DI Diesel Engines," SAE Paper 920470, 1992, Docket A-2001-11, Item H-A-46.
31. Pierpont, D., Reitz, R., "Effects of Injection Pressure and Nozzle Geometry on DI Diesel
Emissions and Performance," SAE Paper 950604, 1995, Docket A-2001-11, Item II-A-41.
32. Philipp, Schneemann, Willmann, Kurreck, "Advanced Optimisation of Common Rail Diesel
Engine Combustion," International Council on Combustion Engines, CIMAC Congress 2001,
Docket A-2001-11, Item H-A-03.
33. Aeberli, Kaspar and Mikulicic, Nikola, "The Sulzer RTA-Low Speed Engine Range: Today
and in the Future", International Council on Combustion Engines, CIMAC Congress 2001,
Docket A-2001-11, Item H-A-07.
34. Aeberli, Kaspar, and Mikulicic, Nikola, "The Sulzer RTA-Low Speed Engine Range: Today
and in the Future", International Council on Combustion Engines, CIMAC Congress 2001,
Docket A-2001-11, Item H-A-07.
35. Ghaffarpour, M and Baranescu, R, "NOx Reduction Using Injection Rate Shaping and
Intercooling in Diesel Engines," SAE Paper 960845, 1996, Docket A-2001-11, Item H-A-40.
36. Piepont, D., Montgomery, D., Reitz, R., "Reducing Particulate and NOx Using Pilot
Injection," SAE Paper 950217, 1995.
37. Philipp, Schneemann, Wilmann, Kurreck, "Advanced Optimisation of Common Rail Diesel
Engine Combustion," International Council on Combustion Engines, CIMAC Congress 2001,
Docket A-2001-11, Item H-A-03.
38. Rosgren, Carl-Erik, "Common rail on Wartsila four-stroke engines", Marine News No 3-
2001, Wartsila Corporation, pgs 20-23, Docket A-2001-11, Item II-A-36.
39. S. Fankhauser, "World's first common-rail low-speed engine goes to sea", Marine News No
3-2001, Wartsila Corporation, pgs 12-15, Docket A-2001-11, Item H-A-37.
4-21
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Draft Regulatory Support Document
40. S. Fankhauser, "World's First common-Rail Low-Speed Engine Goes to Sea", Marine News
No 3-2001, Wartsila Corporation, pgs 12-15, Docket A-2001-11, Item II-A-37.
41. Sorensen,Per and Pedersen, Peter, "The Intelligent Engine Design Status and Service
Experience", International Council on Combustion Engines, CIMAC Congress 2001, Docket A-
2001-11, Item H-A-15.
42. Moncelle, M.E., "Fuel Injection System & Control Integration", International Council on
Combustion Engines, CIMAC Congress 2001, Docket A-2001-11, Item II-A-14.
43. Ingalls, M., Fritz S., "Assessment of Emission Control Technology for EPA Category 3
Commercial Marine Diesel Engines," Southwest Research Institute, September 2001, Docket A-
2001-11, Item H-A-08.
44. Paro, Daniel, "Development of the Sustainable Engine," International Council on
Combustion Engines, CIMAC Congress 2001, Docket A-2001-11, Item II-A-13.
45. Schlemmer-Kelling, Udo and Rautenstrauch, Malte, "The New Low-Emission Heavy Fuel
Oil Engines of Caterpillar Motoren," International Council on Combustion Engines, CIMAC
Congress 2001, Docket A-2001-11, Item U-A-02.
46. Fiedler, Hugo, "Shaping the Combustion Process by Utilisation of High Pressure Injection,"
International Council on Combustion Engines, CIMAC Congress 2001.
47. Okada,S., Hamaoka, S., Masakawa, S., Takeshita, K., Seki, M., Yoshikawa, S., and
Yonezawa, T., "The Development of Very Low Fuel Consumption Medium Speed Diesel
Engine," International Council on Combustion Engines, CIMAC Congress 2001, Docket A-
2001-11, Item H-A-04.
48. Philipp, Schneemann, Wilmann, Kurreck, "Advanced Optimisation of Common Rail Diesel
Engine Combustion," International Council on Combustion Engines, CIMAC Congress 2001,
Docket A-2001-11, Item U-A-03.
49.Ingalls, M., Fritz S., "Assessment of Emission Control Technology for EPA Category 3
Commercial Marine Diesel Engines," Southwest Research Institute, September 2001, Docket A-
2001-11, Item H-A-08.
50. Mayer, Hartmut, Euromot, e-mail response to EPA questions, January 31, 2002, Docket A-
2001-11 Item H-D-01.
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Chapter 5: Estimated Costs
CHAPTER 5: Estimated Costs
This chapter describes our approach to estimating the cost of complying with emission
standards. We start with a general description of the approach to estimating costs, then describe
the technology changes we expect and assign costs to them. We also present an analysis of the
estimated aggregate cost to society.
It should be noted that the costs of the proposed Tier 1 standards are negligible and reflect
certification and compliance costs only. We do not anticipate that there will be any engineering
or design costs associated with the Tier 1 standards because manufacturers are already certifying
engines to the Annex VI standards through our voluntary certification program (see Section E.2
of the preamble for this rule). While there will be certification and compliance costs, these costs
will be negligible. Specifically, we estimate the costs of certification and providing the
capability for onboard NOx measurement to be $18,000 per new engine, and $5,000 for annual
operating costs (calibrating, cleaning, and maintaining the onboard NOx measurement device;
see certification and compliance discussion below). These new engine costs would add less than
1 percent to the price of a new engine, which cost about 2.5 to 3 million dollars (and even less to
the price of a new vessel, which averages about $150 million, with container ships averaging $50
million and cruise ships averaging $500 million per vessel).1
The remainder of this chapter presents the estimated costs associated with a second tier of
NOx standards set 30 percent below Tier 1. We also present information for standards that
reflect the use of direct water injection and selective catalyst reduction.
5.1 Methodology
We have developed estimated costs for a variety of technologies available to reduce
emissions. We developed the costs for individual technologies in cooperation with ICF,
Incorporated and A.D. Little.
To simplify the analyses, costs were examined for one medium-speed engine and one
slow-speed engine. Each of these base engines is considered in three different cylinder
configurations to cover a wider range of power ratings. While these engines are drawn from real
product offerings, they are intended to represent a broader group of engines than just these two
models. Table 5-1 highlights the key operating characteristics of these engines.
Similarly, we developed cost estimates for a specific technology scenario. This approach
does not reflect the wide range of approaches that manufacturers might pursue in meeting
emission standards. We believe that the projections presented here provide a cost estimate
representative of the different approaches manufacturers may ultimately take. In fact, further
research may well lead to advances that involve simpler approaches or more cost-effective
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strategies, resulting in lower overall costs.
Costs of control include variable costs (for incremental hardware and assembly) and fixed
costs (for tooling, R&D, and certification). For technologies sold by a supplier to the engine
manufacturers, variable costs are marked up at a rate of 29 percent to account for the supplier's
overhead and profit.2 The analysis also includes consideration of operating costs where that
would apply. The result is a total estimated incremental cost for individual engines of various
sizes. Costs are presented in 2002 dollars.
Table 5-1
Power Ranges and Nominal Power for Estimating Costs (kW)
Specific
Displacement (L/cyl)
55
900
Maximum engine
speed (rpm)
600
80
Number of
Cylinders
6
9
12
4
8
12
Rated Power
(kW)
4,000
6,000
8,000
8,000
16,000
24,000
5.2 Technology Costs
The total estimated cost impact of a second tier of emission standards set 30 percent
below the Tier 1 NOx limits was developed by considering the development time and hardware
costs to design and integrate emission-control strategies into a marketable engine. The following
paragraphs describe these technologies and their application to Marine engines.
5.2.1 Fuel Injection Improvements
Fuel-injection improvements are one of the most important areas with potential to reduce
emissions from Category 3 Marine engines. Some manufacturers would redesign existing
systems for higher pressure, better control (including rate shaping), and adjusted injection timing.
Other manufacturers may make a design decision to make a step change in technology, switching
to common rail systems. Common rail allows the engine designer to maintain high-pressure
injection at all engine speeds and makes it easier to control injection timing, including the ability
to manage split injection. Common rail systems depend on incorporating electronic controls to
manage fuel delivery. In this cost analysis, we project that all manufacturers would need to adopt
common-rail technology to achieve a 30 percent reduction from the Tier 1 limits.
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Chapter 5: Estimated Costs
Table 5-2 details the variable costs associated with a common-rail system, including
estimated costs for the various controllers, pumps, and other necessary hardware. Total variable
costs range from $11,000 to $22,000 for medium-speed engines and from $24,000 to $71,000 for
slow-speed engines. These costs would not be affected whether the standards apply to U.S.-flag
vessels or whether they also apply to foreign-flag vessels. Fixed costs for development and
tooling are considered in the next section.
Table 5.2-1
Projected Costs per Engine for Fuel Injection Upgrade
Medium-speed Enj
6cyl.
9cyl.
;ines
12 cyl.
Slow-speed Engines
4 cyl.
8 cyl.
12 cyl.
Hardware cost to manufacturer
electronic control unit
common rail accumulator
low-pressure pump
high-pressure pump
modified injectors
wiring harness
Total component cost
Assembly @ $28/hr
Total Hardware cost
$350
$2,000
$1,600
$3,200
$2,100
$300
$9,550
$1,882
$11,432
$350
$3,000
$2,400
$4,800
$3,150
$300
$14,000
$2,822
$16,822
$350
$4,000
$3,200
$6,400
$4,200
$300
$18,450
$3,763
$22,213
$350
$4,000
$3,200
$6,400
$7,200
$600
$21,750
$2,509
$24,259
$350
$8,000
$6,400
$12,800
$14,400
$600
$42,550
$5,018
$47,568
$350
$12,000
$9,600
$19,200
$21,600
$600
$63,350
$7,526
$70,876
5.2.2 Engine Modifications
Engine modifications may include a wide range of strategies to improve the way an
engine handles air intake, fuel injection, or air-fuel mixing in the cylinder. Several different
strategies may work together to provide an optimum level of emission control while minimizing
any potential negative effects on performance, durability, or fuel consumption.
Projected costs in this section include the fixed costs associated with the fuel-injection
improvements described above. Since fuel-injection variables must be incorporated in the
context of other changes to the engine, it is appropriate to consider development time for fuel
injection together with the overall R&D effort for each engine model.
The estimated costs include a substantial time allowance for manufacturers to pursue
engine improvements. This would allow for further exploration beyond fuel-injection variables
into many of the strategies described in Chapter 4. Manufacturers could use this development
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time to pursue changes in valve timing, compression ratio, location of fuel injectors, piston head
geometry, and many other design variables. The cost projections generally contemplate
development time (including testing) for two engineers and three technicians to work on each
engine family for a full year. This development effort would apply for all the different available
cylinder configurations of a given engine family, which is consistent with our provision allowing
manufacturers to certify their engine families based on single-cylinder development engines. In
practice, manufacturers would likely need more time to meet emission standards to certify the
first engine family, while the lessons learned from early development efforts would lead to
reduced development time for later engine families.
An important variable in estimating fixed costs on a per-engine basis is identifying the
appropriate sales volumes. Sales volumes for U.S.-flag vessels are very small. For this analysis
we have estimated that manufacturers will be able to amortize fixed costs related to the emission
standards over four engines per year. This is somewhat higher than current sales volumes, for
several reasons. First, we believe that manufacturers meeting Tier 2 emission standards would
be able to market these engines on the global market as a superior product, thereby increasing the
sales volume over which they can recover development costs. Second, new ship construction in
the last several years has fallen behind the rate necessary for ongoing replacement of vessels,
resulting in an overall aging of the U.S. fleet. Also, requirements related to double-hull tanker
designs are leading many ship owners to consider retrofitting or replacing existing ships.
Together, these factors will likely lead to increased rates of ship construction over the next
several years. Costs are amortized over five years, consistent with previous cost estimates for
emission-control programs.
Amortizing fixed costs would involve a very different set of numbers if the standards
apply to foreign-flag vessels. Under this scenario, we would estimate annual sales of 40 engines
for each engine family. This comes from dividing the approximately 1200 total engines
produced world-wide by half (to exclude those that will never come to the U.S.), and dividing the
remaining engines over five companies, each with an average of three separate engine families.
The estimated costs for a second tier of standards at 30 percent below the Tier 1 NOx
limits are summarized in Table 5.2-2. Estimated costs are about $64,000 per engine. If the
standards were to apply to engines for both U.S.- and foreign-flag vessels, the estimated cost per
engine drops nearly to $6,000.
The kind of changes addressed in this section do not necessarily involve variable costs
(except fuel injection, as noted above). Changing valve timing, and redesigning the geometry of
engine components would generally not involve cost increases beyond those considered for
development time and tooling.
5-4
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Chapter 5: Estimated Costs
Table 5.2-2
Projected Costs per Engine for Engine Modifications
Total fixed
costs
U.S.-flagonly
Including
foreign-flag
Amortization parameter
R&D costs
Retooling costs
Engines per year
Fixed cost per engine
Engines per year
Fixed cost per engine
Medium-speed
Engine
$874,000
$40,000
4
$64,019
40
$6,402
Low-speed
Engine
$874,000
$40,000
4
$64,019
40
$6,402
5.2.3 Direct Water Injection
Table 5.2-5 presents estimated costs for injecting water directly into the engine's
cylinders. Variable costs consider the various components and labor required to assemble the
system, including the cost of separate injectors for fuel and water. The estimated variable costs
include a markup, which reflects the technology development and overhead involved for the
company manufacturing the components and assemblies that the engine manufacturer will buy
and integrate into the overall engine design. The analysis does not incorporate a cost related to
lost cargo space as a result of water storage needs. The engine manufacturer's fixed costs
associated with system integration allow for engineering time to optimize the control technology
for effective emission control while maintaining acceptable performance. Total costs range from
about $120,000 to $320,000 depending on engine size. If emission standards apply also to
engines on foreign-flag vessels, the estimated cost range is $50,000 to $250,000.
In addition, any ship using direct water injection would incur operating costs to provide a
supply of fresh water to the engine. At a cost of $0.10 per gallon for distilled water, total
estimated costs per year for U.S.-flag vessels range from $11,000 to $64,000. This is based on an
average of 2683 hours per year within!75 nautical miles of the U.S. Coast. Foreign-flag vessels
spend much less time operating near the U.S., so their estimated annual water costs range from
$400 to $2,500. Calculated as a net present value, with 7 percent discounting to the point of
sale, estimated composite costs are $360,000 for U.S.-flag vessels and $23,000 if we include
foreign-flag vessels (see Table 5.2-6). These estimated water costs might be significantly
reduced if a ship were designed to provide its own supply of fresh water by adding a desalination
plant (or increasing the capacity of an existing unit).
We also estimate a 2-percent increase in fuel consumption for engines using direct water
injection. As shown in Section 5.2-7, this involves annual costs of $6,000 to $10,000 per year
for U.S-flag vessels. Including foreign-flag vessels would drop these costs to $100 to $800. This
analysis considers increased operating costs only for operation near the U.S. coast.
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Table 5.2-5
Projected Costs per Engine for Direct Water Injection
Medium-speed Engines
6cyl.
9cyl.
12 cyl.
Hardware cost to manufacturer
water tank
low-pressure module
high-pressure module
flow fuses
water injectors
piping
control unit/wiring
Total component cost
Assembly @ $28/hr
Total variable cost
Markup @29%
Total Hardware RPE
Fixed costs
R&D
retooling
marine society approval
engines per year
years to recover
Fixed Cost per Engine
Total Costs per Engine
$2,600
$2,400
$4,800
$3,000
$15,000
$1,400
$1,000
$30,200
$1,882
$32,082
$9,304
$41,386
—
—
—
—
—
$77,720
$119,106
$3,900
$3,600
$7,200
$4,500
$22,500
$2,100
$1,000
$44,800
$2,822
$47,622
$13,810
$61,432
$874,000
$250,000
$5,000
4
5
$77,720
$139,152
$5,200
$4,800
$9,600
$6,000
$30,000
$2,800
$1,000
$59,400
$3,763
$63,163
$18,317
$81,480
—
—
—
—
—
$77,720
$159,200
Including foreign-flag vessels
Total Hardware RPE
Fixed Cost per Engine
Total Costs per Engine
$41,386
$7,772
$49,158
$61,432
$7,772
$69,204
$81,480
$7,772
$89,252
Slow-speed Engines
4 cyl.
$5,200
$4,800
$9,600
$6,000
$30,000
$2,800
$1,000
$59,400
$3,763
$63,163
$18,317
$81,480
—
—
—
—
—
$77,720
$159,200
$81,480
$7,772
$89,252
8 cyl.
$10,400
$9,600
$19,200
$12,000
$60,000
$5,600
$1,000
$117,800
$7,526
$125,326
$36,345
$161,671
$874,000
$250,000
$5,000
4
5
$77,720
$239,391
$161,671
$7,772
$169,443
12 cyl.
$15,600
$14,400
$28,800
$18,000
$90,000
$8,400
$1,000
$176,200
$11,290
$187,490
$54,372
$241,862
—
—
—
—
—
$77,720
$319,582
$241,862
$7,772
$249,634
5-6
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Chapter 5: Estimated Costs
Table 5.2-6
Water costs for Direct Water Injection
Parameter
BSFC (g/kW-hr)
load factor
water/fuel ratio
water use (kg/hr)
avg. hours per call
water used per call (kg)
avg. calls per year
water cost per kg
water cost per hour
total cost per year
(U.S.-flagonly)
Present value
(U.S.-flagonly)
total cost per year
(foreign-flag)
Present value
(foreign-flag)
total cost per year
(composite)
Present value
(composite)
Medium-speed Engines
6cyl.
190
50%
40%
152
17.0
2,584
10
$0.0264
$4
$10,732
$131,793
$416
$5,109
$680
$8,351
9cyl.
190
50%
40%
228
17.0
3,876
10
$0.0264
$6
$16,098
$197,690
$624
$7,663
$1,020
$12,526
12 cyl.
190
50%
40%
304
17.0
5,168
10
$0.0264
$8
$21,464
$263,587
$832
$10,217
$1,360
$16,701
Slow-speed Engines
4 cyl.
190
50%
40%
304
17.0
5,168
10
$0.0264
$8
$21,464
$263,587
$832
$20,217
$1,360
$16,701
8 cyl.
190
50%
40%
608
17.0
10,336
10
$0.0264
$16
$42,928
$527,174
$1,664
$20,435
$2,720
$33,403
12 cyl.
190
50%
40%
912
17.0
15,504
10
$0.0264
$24
$64,392
$790,761
$2,496
$30,652
$4,080
$50,104
5.2.4 Selective Catalytic Reduction
Table 5.2-7 presents estimated costs for selective catalytic reduction. Variable costs
consider the various components and labor required to assemble the system and integrate it into
the vessel. The estimated variable costs include a markup, which reflects the technology
development and overhead involved for the company manufacturing the components and
assemblies that the engine manufacturer will buy and integrate into the overall engine design.
The engine manufacturer's fixed costs associated with system integration allow for engineering
time to optimize the control technology for effective emission control while maintaining
5-7
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Draft Regulatory Support Document
acceptable performance. Total costs range from about $260,000 to$1.23 million depending on
engine size. If emission standards apply also to engines on foreign-flag vessels, the estimated
cost range is $220,000 to $1.18 million
In addition, any ship using selective catalytic reduction would incur operating costs to
provide urea to the engine. At a cost of $1.30 per gallon for aqueous urea, total estimated costs
per year for U.S.-flag vessels range from $24,000 to $144,000. This is based on an average of
2683 hours per year within 175 nautical miles of the U.S. Coast. Foreign-flag vessels spend
much less time operating near the U.S., so their estimated annual urea costs range from $1,500 to
$9,000. Calculated as a net present value, with 7 percent discounting to the point of sale,
estimated composite costs are $820,000 for U.S.-flag vessels and $52,000 if we include foreign-
flag vessels (see Table 5.2-6).
SCR operation also is more durable when engines operate on fuels of a higher grade than
residual fuel. Calculating the cost of using a 0.5 percent sulfur distillate fuel depends on an
estimated load factor of 50 percent. Using current prices for the different fuel types results in
annual costs ranging from $60,000 to $360,000 for U.S.-flag vessels. Including foreign-flag
vessels would drop these costs to $4,000 to $23,000. Fuel costs are discussed further below and
presented in Table 5.2-10. This analysis considers increased operating costs only for operation
within 175 nautical miles of the U.S. coast.
The analysis also considers two additional cost estimates related to system maintenance.
First, the SCR reactor may need routine cleaning for optimum operation. This is performed
through the use of either ultrasound or compressed air. Ultrasound is performed by the use of an
acoustic horn installed in the reactor. The horn automatically sounds for a period of time
periodically during the operation of the engine. The air pulsation from the horn will prevent soot
that is building up in the catalyst. The horn may be driven by air from the normal air system
installed on the vessel. While this method requires no engine shutdown, compressed air cleaning
does require a period of engine shut down. In this method, a soot-blowing probe is inserted into
the catalyst unit to remove soot. It is envisioned that the reactor will be cleaned during each port
call (10 per year) taking 4 person hours for medium speed engines and 6 person hours for low
speed engines. This results in net-present value costs ranging from $19,300 to $28,850, as
shown in Table 5.2-9.
The second maintenance-related item is for replacing reactor elements after 10 and 20
years of operation. This would likely occur during a substantial engine-rebuilding effort. We
estimate the hardware cost to be three-fourths of the estimated long-term cost for the whole
reactor, since the reactor elements are a central part of the overall reactor design. These
hardware costs are then increased by a factor three to account for the higher cost of aftermarket
parts, which is consistent with previous analysis of component cost estimates related to rebuild;
this accounts for the higher cost of aftermarket parts. The resulting SCR rebuilds are estimated
to cost from $175,000 to $1 million, with net-present values per engine (discounted to the point
of sale at a 7-percent discount rate) ranging from $134,000 to $800,000, as shown in Table 5.2-9.
5-8
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Chapter 5: Estimated Costs
Table 5.2-7
Projected Costs per Engine for
SCR
Medium-speed Engines
6cyl.
9cyl.
12 cyl.
Hardware cost to manufacturer
aqueous urea tank
reactor
dosage pump
urea injectors
piping
exhaust bypass valve
control unit/wiring
Total component cost
Assembly @ $28/hr
Total variable cost
Markup @29%
Total Hardware RPE
Fixed costs
R&D
retooling
marine society approval
engines per year
years to recover
Fixed Cost per Engine
Total Costs per Engine
$2,600
$120,000
$4,400
$7,500
$3,000
$10,000
$1,000
$148,500
$1,882
$150,382
$43,611
$193,993
—
—
—
—
—
$47,168
$241,161
$3,900
$180,000
$6,600
$10,000
$4,500
$15,000
$1,000
$221,000
$2,822
$223,822
$64,908
$288,730
$437,000
$250,000
$5,000
4
5
$47,168
$335,898
$5,200
$240,000
$8,800
$15,000
$6,000
$20,000
$1,000
$296,000
$3,763
$299,763
$86,931
$386,694
—
—
—
—
—
$47,168
$433,862
Including foreign-flag vessels
Total Hardware RPE
Fixed Cost per Engine
Total Costs per Engine
$193,993
$4,717
$198,710
$288,730
$4,717
$293,447
$386,694
$4,717
$391,411
Slow-speed Engines
4 cyl.
$5,200
$240,000
$8,800
$20,000
$6,000
$16,000
$1,000
$297,000
$3,763
$300,763
$87,221
$387,984
—
—
—
—
—
$47,168
$435,152
$387,984
$4,717
$392,701
8 cyl.
$10,400
$480,000
$17,600
$40,000
$12,000
$32,000
$1,000
$593,000
$7,526
$600,526
$174,153
$774,679
$437,000
$250,000
$5,000
4
5
$47,168
$821,847
$774,679
$4,717
$779,396
12 cyl.
$15,600
$720,000
$26,400
$60,000
$18,000
$48,000
$1,000
$889,000
$11,290
$900,290
$261,084
$1,161,374
—
—
—
—
—
$47,168
$1,208,542
$1,161,374
$4,717
$1,166,091
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Draft Regulatory Support Document
Table 5.2-8
Urea costs for SCR
Parameter
BSFC (g/kW-hr)
load factor
aqueous urea rate
aqueous urea use (kg/hr)
avg. hours per call
aqueous urea per call (kg)
avg. calls per year
aqueous urea cost per kg
total cost per year
(U.S.-flagonly)
Present value
(U.S.-flagonly)
total cost per year
(foreign-flag)
Present value
(foreign-flag)
total cost per year
(composite)
Present value
(composite)
Medium-speed Engines
6cyl.
190
50%
7.5%
29
17.0
485
10
$0.3173
$24,147
$296,535
$936
$11,494
$1,530
$18,789
9cyl.
190
50%
7.5%
43
17.0
727
10
$0.3173
$37,562
$461,276
$1,456
$17,880
$2,380
$29,227
12 cyl.
190
50%
7.5%
57
17.0
969
10
$0.3173
$48,294
$593,070
$1,872
$22,989
$3,060
$37,578
Slow-speed Engines
4 cyl.
190
50%
7.5%
57
17.0
969
10
$0.3173
$48,294
$593,070
$1,872
$22,989
$3,060
$37,578
8 cyl.
190
50%
7.5%
114
17.0
1,938
10
$0.3173
$96,588
$1,186,139
$3,744
$45,978
$6,120
$75,156
12 cyl.
190
50%
7.5%
171
17.0
2,907
10
$0.3173
$144,882
$1,779,209
$5,616
$68,967
$9,180
$112,734
5-10
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Chapter 5: Estimated Costs
Table 5.2-9
Maintenance costs for SCR
Parameter
Cleaning — per event
Cleaning— NPV
Rebuild — per event
Rebuild— NPV
Medium-speed Engines
6cyl.
$157
$19,300
$174,682
$133,941
9cyl.
$157
$19,300
$261,082
$200,189
12 cyl.
$157
$19,300
$347,482
$266,438
Slow-speed Engines
4 cyl.
$235
$28,850
$349,363
$267,880
8 cyl.
$235
$28,850
$694,963
$532,876
12 cyl.
$235
$28,850
$1,040,563
$797,871
5.2.5 Certification and Compliance
Manufacturers must generate test data and other information to demonstrate compliance
with emission standards. To estimate these costs, we have allocated $40,000 to conduct testing
to show that an engine family meets emission standards. An additional $20,000 per engine
family is estimated to cover the cost of engineering and clerical effort to prepare and submit the
required information.
The capability for onboard NOx measurement is estimated to cost $15,000, which
includes sensors, data logging, equipment, and installation. An additional $5,000 annually would
cover the cost of calibration, cleaning, and replacing any worn components. An estimated $1,000
per engine is allocated to cover the cost of onboard testing at the point of installation. Once the
system is operating, the ship's crew could perform periodic measurements at no significant
additional cost beyond that estimated for maintaining the unit.
Until engine designs are significantly changed, engine families can be recertified each
year using carryover of the original test data. Since these engines are currently not subject to any
emission requirements, the analysis includes a cost to recertify an upgraded engine model every
five years.
5.2.6 Fuel Costs
Table 5.2-10 presents the fuel costs we use in our analyses of various emission control
approaches. These analyses include the costs of reducing fuel sulfur for PM and SOx benefits,
using very low sulfur fuel to enable SCR technology, and baseline fuel costs for a fuel
consumption sensitivity analysis. These fuel costs come from two sources. The cost estimates
for residual fuel and Marine diesel oil come from Marine Bunker News.3 Costs for number 2
diesel and for on-highway diesel fuel are based on prices (excluding taxes) reported by the
Department of Energy.4
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Draft Regulatory Support Document
Table 5.2-10: Fuel Costs
Fuel Type
Residual
Marine diesel oil
Number 2 diesel
Highway diesel
Sulfur Level
27,000 ppm
1 5,000 ppm
3,000 ppm
500 ppm
Cost per Metric Tonne
$98
$158
$215
$245
5.2.7 Sensitivity
As described above, manufacturers have a wide range of technology options to reduce
emissions. We believe that manufacturers can combine technologies to meet NOx standards 30
percent below the proposed Tier 1 emission standards without increasing fuel consumption.
Table 5.2-11 shows a calculation of costs or savings associated with a one-percent change in fuel
consumption. If engines that meet standards set 30 percent below Tier 1 have changes in fuel
consumption, or if manufacturers need to rely on timing retard to achieve the last step of
controlling emissions to meet emission standards, the table provides a framework for quantifying
this cost or benefit. The calculation is presented for U.S. flagged vessels operating within!75
nautical miles of the U.S. coast. To calculate this effect for all vessels with Category 3 engines
operating within 175 nautical miles of the U.S. coast, an average annual operation of 170 hours
per year would be used. Also, the calculations are based on a one-percent change in fuel
consumption. Any bigger or smaller change in fuel consumption could be scaled from the results
in the table using a linear relationship.
5-12
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Chapter 5: Estimated Costs
Table 5.2-11
Costs or Savings for Each One-percent Change in Fuel Consumption
Parameter
baseline BSFC (g/kW-hr)
load factor
annual operating hours
baseline hourly fuel cost
delta hourly fuel cost per
1 -percent bsfc change
cost change per year
(U.S.-flagonly)
Present value
(U.S.-flagonly)
cost change per year
(foreign-flag)
Present value
(foreign-flag)
cost change per year
(composite)
Present value
(composite)
Medium-speed Engines
6cyl.
190
50%
170
$37
$0.37
$993
$12,263
$38
$475
$63
$777
9cyl.
190
50%
170
$56
$0.56
$1,502
$18,402
$58
$713
$95
$1,166
12 cyl.
190
50%
170
$74
$0.74
$1,985
$24,542
$77
$951
$127
$1,555
Slow-speed Engines
4 cyl.
190
50%
170
$74
$0.74
$1,985
$24,542
$77
$951
$127
$1,555
8 cyl.
190
50%
170
$149
$1.49
$3,998
$49,067
$155
$1,902
$253
$3,109
12 cyl.
190
50%
170
$223
$2.23
$5,983
$73,609
$232
$2,853
$380
$4,664
5.3 Total Engine Costs
5.3.1 Distribution of Category 3 Marine Engines
Before presenting the total costs for meeting the second tier of standards under
consideration, it is helpful to establish a distribution of the modeled engines for calculating a
composite cost for the category. Population data for vessels with Category 3 Marine engines
shows that 60 percent of these engines are two-stroke.5 As described in Chapter 7, the average
power rating for all Category 3 Marine engines is 11,000 kW. Using these parameters, we
estimated the distribution of engines shown in Table 5.3-1. While the actual distribution clearly
covers a much wider range of engines, this analysis provides an effective way of creating a
composite assessment of costs for comparison with the projected emission reductions.
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Draft Regulatory Support Document
Table 5.3-1
Estimated Distribution of Category 3 Engine Sizes
Medium-speed Engines
6cyl.
20%
9cyl.
10%
12 cyl.
10%
Slow-speed Engines
4 cyl.
25%
8 cyl.
20%
12 cyl.
15%
5.3.2 Projected Costs for Engines on U.S.-flag Vessels
Total projected costs for standards set 30 percent below the Tier 1 NOx limits are based
on combining the anticipated fuel injection improvements and other engine modifications to meet
emission standards, as described in Sections 5.2.1 and 5.2.2. Factoring in the estimated
compliance costs results in a total estimated cost impact ranging from $94,000 to $153,000 (see
Table 5.3-2). Using the engine distribution described above leads to a calculated composite cost
for all Category 3 engines of $115,000. The cost analysis also includes an estimated $5,000 of
annual expenses to maintain equipment for onboard emission measurement, which corresponds
with a net-present-value at the point of sale of $61,000. We believe that manufacturers would
integrate a combination of emission-control strategies to meet emission standards without
increasing fuel-consumption rates. The sensitivity of this assumption is explored in Section 5.2.6
above.
Long-term costs decrease due to two principal factors. First, the analysis anticipates that
manufacturers recover their initial fixed costs for tooling, R&D, and certification, after which
they are no longer applied as a per-engine cost for meeting emission standards. Second,
manufacturers are expected to learn over time to produce the engines with the new technologies
at a lower cost. Because of the very low sales volumes, manufacturers are less likely to put in
extra R&D effort for low-cost manufacturing. As production starts, assemblers and production
engineers will have great opportunities to fine-tune the designs and the production processes.
Consistent with analyses from other programs, we reduce estimated variable costs by 20 percent
beginning with the third year of production and an additional 20 percent beginning with the sixth
year of production.6 We believe it is appropriate to apply this factor here, given that the
industries are facing EPA emission regulations for the first time and it is reasonable to expect
learning to occur with the experience of producing and improving emission-control technologies,
especially with such low sales volumes.
5-14
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Chapter 5: Estimated Costs
Table 5.3-2
Summary of Projected Costs to a Second Tier of NOx Limits
30 Percent Below Tier 1 — U.S.-flag only
Cost Parameter
Total cost per engine
(yr. 1)
Total cost per engine
(yr. 6 and later)
Operating costs (NPV)
Medium-speed Engines
6cyl.
$93,587
$25,452
$5,000
9cyl.
$98,977
$28,902
$5,000
12 cyl.
$104,368
$32,352
$5,000
Slow-speed Engines
4 cyl.
$106,414
$33,661
$5,000
8 cyl.
$129,723
$48,579
$5,000
12 cyl.
$153,031
$63,496
$5,000
5.3.3 Cost Considerations Related to Including Engines on Foreign-Flag Vessels
If emission standards would apply to engines on foreign-flag vessels, we would estimate
no change in per-engine variable costs or operating costs. Amortizing fixed costs and
compliance costs over a wider set of engines decreases estimated per-engine costs to a composite
value of $57,000. See Table 5.3-3. However, as discussed in Chapter 7, per-ton costs would be
higher since only tons emitted near the U.S. are counted in the cost per ton estimates here.
Table 5.3-3
Summary of Projected Costs to Meet
a Second Tier of NOx Limits
30 Percent Below Tier 1 — Including Foreign-flag
Cost Parameter
Total cost per engine
(yr. i)
Total cost per engine
(yr. 6 and later)
Operating costs (NPV)
Medium-speed Engines
6 cyl.
$35,970
$25,452
$5,000
9 cyl.
$41,360
$28,902
$5,000
12 cyl.
$46,751
$32,352
$5,000
Slow-speed Engines
4 cyl.
$48,797
$33,661
$5,000
8 cyl.
$72,106
$48,579
$5,000
12 cyl.
$95,414
$63,496
$5,000
Including foreign-flag vessels would also affect Category 1 and Category 2 engines. In
general, the same cost estimates published for the December 1999 final rule for commercial
marine diesel engines apply equally to engines on foreign-flag vessels. Again, fixed costs are the
exception warranting further consideration. In many cases, foreign-flag vessels would be using
the same kind of engines that would go into U.S.-flag vessels. In these cases, engine
manufacturers would already be applying sufficient fixed costs to meet emission standards
5-15
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Draft Regulatory Support Document
(including certification and compliance costs). The only new costs for these engines is therefore
the variable costs involved in producing them to meet emission standards. Other foreign-flag
vessels may be using engines from manufacturers not selling engines into the U.S. market. These
engine manufacturers would need to produce compliant engines, likely with a smaller sales
volume than that projected for the average manufacturer selling engines for U.S.-flag vessels.
While these different factors are difficult to quantify, they are offsetting, so we estimate near-
term and long-term costs for these engines that are neither higher nor lower than that already
estimated for U.S.-flag vessels. These costs are summarized in Table 5.3-4.
Table 5.3-4
Estimated Costs to Include Category 1 and Category 2 Engines on Foreign-Flag Vessels
Cost Parameter
Total cost per engine
(yr. 1)
Total cost per engine
(yr. 6 and later)
Rebuild costs (NPV)
100 kW
$1,806
$486
$441
400 kW
$3,208
$846
$703
750 kW
$25,395
$856
$207
1500 kW
$22,818
$1,120
$635
3000 kW
$54,192
$13,019
$12,430
5.4 Aggregate costs
The above analysis presents unit cost estimates for each power category. With current
data for engine and vessel sales for each category and projections for the future, these costs can
be translated into projected direct costs to the nation for the new emission standards in any year.
Aggregate annual costs (based on a 20-year analysis) of a second tier of NOx limits under
consideration, set at 30 percent below the Tier 1 levels, are estimated to be about $1.6 million per
year. Applying the second tier of emission standards also to engines on foreign-flag vessels
would increase aggregate costs to about $54 million. In both cases, estimated aggregate costs fall
substantially after five years as manufacturers would no longer need to recover their amortized
costs. See Chapter 7 for further discussion of aggregate costs.
5-16
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Chapter 5: Estimated Costs
Chapter 5 References
1. See Chapter 7 references, note 4.
2. "Update of EPA's Motor Vehicle Emission Control Equipment Retail Price Equivalent (RPE)
Calculation Formula," Jack Faucett Associates, Report No. JACKFAU-85-322-3, September
1985 (Docket A-97-50; document IV-A-5).
3. Bunker News, "Bunker Prices," www.lloydslist.com/NASApp/cs/ContentServer?pagename=
BunkerNews/home, January 24, 2002 (Docket A-2001-11, document U-A-31).
4. U.S. Energy Information Administration, "International Petroleum Information,"
www.eia.doe.gov/emeu/international/petroleu.html, March 11, 2002 (Docket A-2001-11,
document U-A-30).
5.Motor Ship., Annual Analysis, June 1999, pp. 49-50.
6.For further information on learning curves, see Chapter 5 of the Economic Impact, from
Regulatory Impact Analysis - Control if Air Pollution from New Motor Vehicles: Tier 2 Motor
Vehicle Emissions Standards and Gasoline Sulfur Control Requirements, EPA420-R-99-023,
December 1999. The interested reader should also refer to previous final rules for Tier 2
highway vehicles (65 FR 6698, February 10, 2000), marine diesel engines (64 FR 73300,
December 29, 1999), nonroad diesel engines (63 FR 56968, October 23, 1998), and highway
diesel engines (62 FR 54694, October 21, 1997).
5-17
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Chapter 6: Emissions Inventory
CHAPTER 6: Emissions Inventory
This chapter presents our analysis of the emission impact of the regulatory program under
consideration. The first section contains a description of the methodology used to develop the
baseline emissions inventories for the base year (1996). The second section contains a
description of the methodology used to develop future year inventory projections. Finally, the last
section contains the expected emissions reductions that would result from the regulatory program
under consideration.
It should be noted that we are not claiming emission reductions for the proposed Tier 1
standards. These standards have already been adopted by the international community, although
they are not yet enforceable, and engine manufacturers are already producing engines that
achieve these standards. As a result, this rule will result in emission reductions only to the extent
that owners of U.S. vessels are not currently complying with the standards.
The remainder of this chapter presents the estimated emission reductions associated with
a second tier of NOx standards set 30 percent below Tier 1.
6.1 Baseline Inventories
We developed baseline Category 3 vessel emissions inventories under contract
with E. H. Pechan & Associates, Inc.1 An important part of this analysis is the geographic area
that we model for emissions. For other nonroad sectors we have typically modeled only
emissions that occur within the U.S. Sometimes we have modeled emissions on a county-by-
county basis, or based on whether the emission occur within an ozone nonattainment area.
However, for Category 3 Marine engines, the vast majority of the emissions that occur within the
territorial limits of the U.S. occur outside of the land boundaries of the U.S. Thus, it is essential
that we model emissions that occur in ocean and Great Lakes waters. Moreover, it is clear that
emissions that occur outside of our territorial seas (i.e., more than 12 miles from the U.S.
coastline) can affect U.S. air quality. NOx can be stable for days in the atmosphere. Assuming a
10 mile per hour wind traveling toward a coast, NOx molecules emitted 12 miles from the coast
could reach the coast in just over one hour. NOx molecules emitted 175 nautical miles (200
statute miles) from the coast could reach the coast in less than a day. We will continue to
investigate this issue throughout this rulemaking, and will incorporate any new information into
the final rule. For example, as discussed in Chapter 2, the U.S. Department of Defense (DoD)
has presented information to us recommending that a 60 nautical mile limit be established rather
than the proposed 175 nautical miles as the appropriate location where emissions from marine
vessels would affect on-shore air quality.
For this analysis, inventory estimates were developed separately for vessel traffic within
25 nautical miles of port areas and vessel traffic outside of port areas but within 175 nautical
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miles of the coastline. Different techniques were used to develop the port and non-port
inventories due to the availability of different types of data for each.
6.1.1 Ports Inventories
For port areas we developed detailed emissions estimates for nine specific port areas
using port activity data including port calls, vessel types and typical times in different operating
modes. The nine port areas analyzed in detail were the Lower Mississippi (New Orleans and
Baton Rouge), New York, Delaware River (Philadelphia area), Puget Sound, Corpus Christi,
Tampa, Baltimore, Coos Bay, Cleveland and Burns Harbor. Vessel types considered included
bulk carrier, container ship, general cargo, passenger, refrigerated (reefer), roll-on roll-off (roro)
tanker, vehicle carrier, and other miscellaneous vessels.
Emissions estimates for all other ports were developed by matching each of those ports to
one of the nine specific ports already analyzed based on characteristics of port activity, such as
predominant vessel types, harbor draft and region of the country. The detailed port emissions
were then scaled to the other ports based on relative port activity. Ports were looked at separately
for four main regions of the country; the Pacific Coast, the Gulf Coast, the Atlantic Coast, and
the Great Lakes.
For the port areas analysis three different types of vessel transit operation were
considered. Cruising is when the vessel is approaching the port but not yet required to reduce its
speed. The reduced speed zone (RSZ) is the portion of the vessel's approach to the port where it
is required to reduce its speed. Maneuvering includes any vessel movement from one berth to
another within the actual port. The relative amounts of these types of transit operation vary from
one port to another, depending on geography and traffic patterns. For example, port areas that
include some river transit have greater RSZ operation than other port areas. The load factor
(fraction of rated power) for cruise mode was assumed to be 80 percent. For RSZ operation the
load factor is generally between 15 and 35 percent, depending on vessel type and port geography.
However, there are a few port areas where the RSZ load factor can go as high as 70 percent for
some vessel types. The maneuvering load factor is between ten and 12 percent.
This analysis was intended to characterize emissions specifically from Category 3 Marine
diesel engines, rather than vessels powered by Category 3 engines. Emissions from Category 3
vessels also include hotelling emissions, which are emissions generated in the process of
generating electric power for the vessel. In general, we assumed that most hotelling emissions
from Category 3 vessels are actually generated by Category 1 and 2 auxiliary engines, rather than
the main Category 3 propulsion engine. However, in the case of passenger vessels and reefer
ships, where the demand for electric power is great, we assumed that the hotel power is generated
by the category 3 propulsion engine. Thus, hotelling emissions from passenger and reefer ships
are included in the inventories, but not hotelling emissions from any other vessel types.
The ports emissions were calculated by associating and summing the product of the
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Chapter 6: Emissions Inventory
vessel trips (port calls), vessel power, and average load factor by mode of operation and time in
mode for all modes of operation. The general equation used for calculating port emissions is
shown below.
Emissions = Trips * Power * LF in mode * Time in mode * EF
Where: Trips - number of trips or vessel calls by vessel and engine type
Power - rated power of propulsion engine by vessel and engine type
LF - load factor (fraction of rated power) by mode
Time - average time for each mode by vessel and engine type
EF - emission factor in mode and by engine type
Emission factors were developed separately for slow speed and medium speed Category 3
Marine diesel engines. The emission factors used are shown in Table 6.1-1.
Table 6.1-1
Emission Factors for Category 3 Marine Diesel Engine Transit Emissions (g/hp-hr)
Engine Type
Slow Speed
Medium Speed
HC
0.395
0.395
CO
0.82
0.52
NOx
17.60
12.38
PM
1.29
1.31
SOx
9.56
9.69
Emission factors tend to be relatively steady at loads greater than 20 percent. Thus,
emissions at full load were used to develop cruise and RSZ emission factors. However, at low
loads the emission factors tend to increase as compared with higher loads. The emission factors
shown in Table 6.1-1 were used for cruise and RSZ modes of operation. For maneuvering
operation we adjusted the emission factors based on relationships developed for us by Energy
and Environmental Analysis, Inc.2 The adjustments we applied to the emission factors shown in
Table 6.1-1 to develop maneuvering emission factors are shown in Table 6.1-2.
Table 6.1-2
Ratio of Maneuvering Emission Factors at 10 percent Load to Full Load Emission Factors
Engine Type
Slow Speed
Medium Speed
HC
5.28
5.50
CO
8.52
7.41
NOx
1.36
1.36
PM
1.69
1.68
SOx
1.57
1.55
The total national Category 3 Marine diesel inventories for within 25 nautical miles of all
U.S. ocean ports and 10 nautical miles of all U.S. Great Lakes ports are shown in Table 6.1-3.
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Table 6.1-3
Total U.S. Category 3 Emissions Inventories for Port Areas in 1996 (short tons)
HC
5,230
CO
1,944
NOx
101,137
PM
9,299
SOx
97,390
6.1.2 Non-Port Inventories
We developed non-port emissions inventories using cargo movements and waterways
data, vessel speeds, average dead weight tonnage per ship, and assumed cargo capacity factors.
We assumed that all river traffic was handled by vessels with smaller than Category 3 engines,
except in river ports serving ocean-going traffic. Further, we assumed that any coastwise cargo
movement within 25 nautical miles of the coast, but outside of the port areas analyzed in section
6.1.1 was moved by tow and push boats powered by Category 2 engines. Thus, only non-port
vessel traffic outside of 25 nautical miles from the coast was considered to be Category 3 traffic
for the purposes of this analysis. It is possible that some Category 3 vessel traffic occurs within
25 nautical miles of the coast. However, due to limitations in the data we were unable to
discriminate between cargo carried on Category 2 vessels and cargo carried on Category 3
vessels. Thus, including cargo movement within 25 nautical miles of the coast but outside of
ports areas would have resulted in the inclusion of Category 2 vessel emissions in our baseline
inventories for Category 3 vessels.
The U.S. Army Corp of Engineers (USAGE) provided activity estimates of total and
domestic tonnage by waterway links. A map of the waterway links is shown in Figure 6.1-1, at
the end of this chapter.
These estimates were converted to ton-miles of cargo by multiplying tonnage by link
distance to estimate overall link activity. In order to avoid double-counting the emissions
estimated in section 6.1.1 fractional links were estimated such that only traffic between 25 and
175 nautical miles from shore was considered. For Great Lakes links traffic outside of 10 miles
was considered. Emission factors in g/ton-nautical-mile were developed using cruise mode
emissions divided by the total freight tonnage from the detailed ports analysis. These emission
factors were then multiplied by the total links ton-miles to estimate total non-port emissions
inventories. The total non-port emissions inventories for base year are shown n Table 6.1-4.
Table 6.1-4
Total U.S. Category 3 Emissions Inventories for Non-Port Areas in 1996 (short tons)
HC
2,060
CO
4,186
NOx
88,837
PM
7,840
SOx
58,856
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Chapter 6: Emissions Inventory
6.2 Future Year Baseline Inventory Projections
In order to project future year emissions inventories for Category 3 Marine diesel engines
several factors were taken into account. These included the overall expected growth in cargo
movement, the type of vessel that would handle the increased freight movement (i.e., the future
makeup of the fleet, and the effect of the Annex VI emissions regulations on fleet emissions as
older vessels are scrapped and replaced with new vessels.
The expected increase in freight movement was projected from estimates of freight
forecasts done by the U.S. Maritime Administration (MARAD). MARAD supplied estimated
freight forecasts for several types of vessels. Thus, rather than a single growth rate for all vessel
traffic, we used separate growth rates for tankers, container ships, cruise ships and other bulk and
general cargo ships. The MARAD estimates relied upon historic freight growth from 1996 to
1999, and varied between 2.2 and 6.6 percent per year, depending on vessel type. The growth
rate from 1996 through 1999 was then projected beyond 1999 through 2004 by MARAD. For
this analysis the projections supplied by MARAD were used to project freight growth out to
2030. While there is a great deal of uncertainty in projecting growth this far into the future we
did so in order to show the long term impact of the emission control program under consideration
on the emissions inventories. Given that Category 3 vessels typically last for several decades
before being scrapped it was important to project inventories out this far.
In order to project future vessel activity based on these forecasts of freight growth, the
overall dead weight tonnage (DWT) calling annually at ports and traversing the waterways links
was increased in proportion to the projected freight increases. The additional vessel calls needed
to accommodate the increased tonnage were added to the largest DWT category by vessel type.
In other words, we assumed that the additional tonnage would be handled by the largest vessels
and powered by slow speed engines given that predominantly larger vessels are being constructed
to replace older vessels, and that ports are making an effort to accommodate larger vessels.
In addition to the effects of increased freight tonnage and future changes in fleet makeup,
the effects of the Annex VI NOx standards were included in the future year projections.
Although these standards have not been ratified and do not yet have the force of international
law, they were written to be retroactive to the year 2000 when they do go into effect. Thus, most
new vessels constructed beginning in 2000 have been built in compliance with the Annex VI
standards. This is a trend that we expect to continue. Thus, for this analysis we assumed that all
Category 3 vessels constructed in 2000 and later comply with the Annex VI standards. The
Annex VI NOx standards are related to rated engine speed as shown in the following
relationship.
Engine speed < 130 rpm; 17.0 g/kW-hr
130 rpm < Engine speed < 2,000 rpm; 45*n-°2 g/kW-hr
Engine speed >2,000 rpm; 9.8 g/kW-hr
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where "n" is the rated engine speed in rpm
These NOx emissions limits are for vessels tested on distillate fuel. However, Category 3 vessels
use residual fuel in use. Thus, the standards were increased by ten percent to account for the
difference in fuels. In the absence of information regarding certification compliance margins (the
practice of producing engines which emit somewhat below the standards in order to provide a
compliance cushion) and in-use emissions deterioration we used the actual Annex VI emissions
limits as the emission factors for future vessels in the growth projections.
The projected future emissions inventories for the port areas are shown in Table 6.2-1.
The non-ports inventory projections are shown in Table 6.2-2. Finally, the total national
inventory projections are shown in Table 6.2-3.
Table 6.2-1
Projected Emissions Inventories from Category 3 Marine Diesel Engines in Port Areas (short
tons)
Year
1996
2010
2020
2030
HC
5,230
8,501
12,486
19,146
CO
11,530
18,836
27,716
42,535
NOx
101,137
146,160
195,812
287,511
PM
9,299
14,199
20,258
30,447
SOx
97,390
104,540
148,575
222,640
Table 6.2-2
Projected Emissions Inventories from Category 3 Marine Diesel Engines in
Non-Port Areas (short tons)
Year
1996
2010
2020
2030
HC
2,060
3,295
4,729
7,005
CO
4,186
6,681
9,567
14,088
NOx
88,837
127,955
171,657
243,294
PM
7,840
11,797
16,443
23,784
SOx
58,856
88,261
122,637
177,106
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Chapter 6: Emissions Inventory
Table 6.2-3
Projected Emissions Inventories from Category 3 Marine Diesel Engines in All Areas (short
tons)
Year
1996
2010
2020
2030
HC
7,290
11,796
17,215
26,151
CO
15,716
25,517
37,283
56,623
NOx
189,974
274,115
367,469
530,805
PM
17,139
25,996
36,701
54,231
SOx
156,246
192,801
271,212
399,746
6.3 Inventory Effects
To model the benefits of the regulatory program under consideration we applied an
engine replacement schedule and the emissions standards to the baseline inventory. Our
proposed Tier 1 standards are based on the Annex VI NOx standards. Although these standards
have not been ratified by enough countries to be given the force of law, they are being largely
complied with around the world, and we expect this trend to continue. Thus, we are using the
proposed Tier 1 standards as the baseline, and showing the benefits of the second tier of NOx
reductions under consideration relative to this baseline.
For vessel turnover rates we were primarily concerned with the average age of the U.S.
fleet, since we are only proposing to apply the standards to U.S. flagged vessels. In a study done
by Corbett and Fishbeck in support of our previous rulemaking relating to emissions from
Categoryl and 2 Marine diesel engines the average age of the U.S. flagged fleet was 23 years.3 A
separate analysis of MARAD data on ship calls to U.S. ports, which contained vessel age and
flag information, showed that the average age of U.S. flagged vessels in 1999 was 24.2 years,
with a median age of 22 years. The results of this analysis are shown in Figure 6.3-1, at the end
of this chapter. Thus, we assumed that the average age of the U.S. fleet is 23 years old for
purposes of estimating fleet turnover rates. The Corbett and Fishbeck study showed evidence
that the average age of the world fleet is somewhat lower than that of the U.S. fleet. However,
we relied upon the U.S. flagged fleet information because our standards are proposed to apply
only to U.S. flagged vessels.
We are only proposing that standards apply to U.S. flagged vessels. Thus, we only
applied the expected emissions reductions to the portion of the national inventory attributable to
U.S. flagged vessels. Also, because the second tier of standards we are considering seek to
reduce only NOx emissions, we are claiming no emissions reductions in HC, CO, PM or SOx.
Table 6.3-1 shows our estimates of Category 3 vessel NOx emissions with and without the
second tier of standards currently under consideration.
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Table 6.3-1
Category 3 Marine Vessel NOx National Emissions Inventories
No control baseline (thousand short tons)
Tier 11
MARPOL
Annex VI
Tier 2 under
consideration
(30% below
Tier 1)
(thousand short tons)
Percent reduction (relative to no
control)
Control (thousand short tons)
Percent reduction (relative to
MARPOL Annex VI)
1996
190
190
—
190
—
2010
303
274
9.6%
269
2.0%
2020
439
367
16.2%
343
6.8%
2030
659
531
19.5%
475
10.5%
The effect of applying a second tier of NOx standards to both U.S. and foreign flagged
vessels is shown in Table 6.3-2. For modeling simplicity we assumed that the average age of all
vessels covered would be that same as that of the U.S. flagged fleet. However, as was previously
discussed, the average age of the world fleet is likely lower than that of the U.S. flagged fleet as a
result of faster turnover rates. Thus, the impact of applying the second tier of standards currently
under consideration to all vessels could possibly be seen somewhat sooner than Table 6.3-2
suggests. As can be seen from this table, the projected percentage of emissions reductions
would almost triple by 2030 if the application of the proposed standards is extended to foreign
flagged vessels.
Table 6.3-2
Effect of Application of Second Tier of NOx Limits
Based on Vessel Flag
(U.S. Flagged Vessels vs. All Vessels)
Scenario
Baseline (Annex VI)
U.S. Flagged Only
All Vessels
2020
NOx (1000 tons)
367
343
306
% reduction
—
6.8%
16.7%
2030
NOx (1000 tons)
531
475
392
% reduction
—
10.5%
26.1%
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Chapter 6: Emissions Inventory
Figure 6.1-1: USAGE Waterway Link Network
Figure 6.3-1
Number of C3 Vessels in U.S. Fleet by Age
30 -
25 -
20 -
•5 15-
10
-
5 ««-
20
40
60
'years)
100
120
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Draft Regulatory Support Document
Chapter 6 References
1. "Commercial Marine Emission Inventory Development," E.H. Pechan and Associates, Inc.
and ENVIRON International Corporation, April, 2002.
2. "Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data," EPA420-
R-00-002, Prepared for EPA by Energy and Environmental Analysis, Inc., February, 2000.
3. "Commercial Marine Emissions Inventory for EPA Category 2 and 3 Compression Ignition
Marine Engines in United Sates Continental and Inland Waterways," James J. Corbett, Jr. and
Paul S. Fishbeck, Carnegie Mellon University, August 21, 1998.
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Chapter 7: Cost Per Ton
CHAPTER?: Cost Per Ton
7.1 Methodology
This chapter assesses the cost per ton of emission reduction for the second tier of NOx
limits under consideration, set at 30 percent below the Tier 1 limits. This analysis relies in part
on cost information from Chapter 5 and emissions information from Chapter 6 to estimate the
cost per ton of such a second tier of NOx standards in terms of dollars per short ton of NOx
emission reductions (all costs are presented in 2002 dollars). This chapter also compares the cost
per ton of such standards with the cost per ton of other NOx control strategies from previous
EPA rulemakings. Finally, this chapter presents results of a screening level economic impact
analysis.
We are not performing a similar analysis for Tier 1. As indicated in Chapters 5 and 6, the
costs associated with this rule are negligible. These standards have already been adopted by the
international community, although they are not yet enforceable, and engine manufacturers are
already producing engines that achieve these standards. As a result, this rule will result in
emission reductions only to the extent that owners of U.S. vessels are not currently complying
with the standards.
The analysis presented in this chapter is performed for Category 3 Marine diesel engines
and vessels using the same engine types presented in Chapter 5. An estimate of the industry-
wide cost per ton of the new emission standards, combining all of the nominal engine sizes, is
also presented.
Two types of cost-per-ton analyses are performed in this chapter. The first analysis
focuses on individual engines and examines total costs and total emission reductions over the
typical lifetime of an average marine diesel engine discounted to the beginning of the engine's
life. The second method looks at the net present value (NPV) of a stream of costs and benefits
over a standardized period of time (30 years). Over this period, the calculation includes the
whole set of new requirements.
In calculating net present values that were used in our cost per ton estimates, we used a
discount rate of 7 percent, consistent with the 7 percent rate reflected in the cost per ton analyses
for other recent mobile source programs. OMB Circular A-94 requires us to generate benefit and
cost estimates reflecting a 7 percent rate. Using the 7 percent rate allows us to make direct
comparisons of cost per ton estimates with estimates for other, recently adopted, mobile source
programs.
However, we also calculated the primary cost and cost per ton estimates using a 3 percent
rate. The 3 percent rate is consistent with that recommended by the Science Advisory Board's
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Environmental Economics Advisory Committee for use in EPA social benefit-cost analyses, a
recommendation incorporated in EPA's new "Guidelines for Preparing Economic Analyses"
(November 2000). Therefore, we have also calculated the overall cost per ton of new emission
standards based on a 3 percent rate to facilitate comparison of the cost per ton of this rule with
future proposed rules which might use the 3 percent rate. The results using both a 3 percent and
7 percent discount rate are provided in this Chapter.
7.2 Engine Lifetime Cost per ton of the New Standards
The cost per ton of the second tier of NOx standards under consideration, set at 30
percent below the Tier 1 standards, was calculated for the engine types described in Chapter 5.
For this analysis, the entire cost of the program is attributed to the control of HC and NOx
emissions. As discussed in Chapter 5, the estimated cost of complying with the new emission
standards varies depending on the model year under consideration (i.e., year 1 versus year 6).
Therefore, this analysis includes the per-engine cost per ton results for the different model years
during which the costs are expected to change. This analysis focuses on costs and emissions
reductions for individual engine types; therefore, the costs presented in this section represent the
actual cost per ton as it affects a given engine. All of the costs and benefits are discounted at
seven percent to the model year of the Marine engine.
EPA calculated the costs and emissions reductions achieved from the second tier of NOx
standards under consideration beyond the Tier I/Annex VI requirements. To come up with an
average cost we looked at an engine with an average kW of 11,000. This average kW is based on
data collected on seven U.S. ports which accept ocean-going vessels.1 Table 7-1 presents the
cost per ton of a second tier of NOx standards for U.S. flagged category 3 Marine diesel engines
discounted at 3 and 7 percent.
Table 7-1
Cost per ton ($/short ton) of the Second Tier of NOx Standards
Under Consideration - U.S. Vessels Only
Discount Rate
3 percent
7 percent
Model Year
Grouping
Ito5
6 +
Ito5
6 +
NPV Benefits
(short tons)
1728
1150
NPV Operating
Costs
$99,000
$66,000
Engine & Vessel
Costs
$115,000
$39,000
$115,000
$39,000
Discounted Cost
Per Ton
$120
$78
$145
$87
Because we requested comment on applying the standards to all vessels operating within
175 miles of the U.S. coast, we also calculated the cost per ton of including foreign-flagged
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Chapter 7: Cost Per Ton
vessels. Table 7-2 presents the cost per ton including both U.S. and foreign-flagged vessels in
the program.
Table 7-2
Cost per ton ($/short ton) of the Second Tier of NOx Standards
Under Consideration - Including Foreign Flag Vessels
Discount Rate
Model Year
Grouping
NPV Benefits
(short tons)
NPV Operating
Costs
Engine & Vessel
Costs
Discounted Cost
Per Ton
Foreign Flag Only
3 percent
7 percent
Ito5
6 +
Ito5
6 +
67
45
$99,000
$66,000
$57,000
$39,000
$57,000
$39,000
$2,271
$2,017
$2,590
$2,235
All Vessels
3 percent
7 percent
Ito5
6 +
Ito5
6 +
110
73
$99,000
$66,000
$57,000
$39,000
$57,000
$39,000
$1,390
$1,234
$1,585
$1,368
7.3 Comparison with Cost Per Ton of Other Control Programs
In an effort to evaluate the cost per ton of the second tier of NOx standards currently
under consideration, we have summarized the cost per ton results for several other recent EPA
mobile source rulemakings that required reductions in NOx emissions from diesel engines.
Where NOx cost per ton was not reported, HC+NOx cost per ton figures are reported. HC+NOx
cost per ton figures should be close to NOx cost per ton figures because NOx is the primary
focus of most standards for diesel engines and because emissions (and emission reductions) for
NOx are generally much greater than for HC from diesel engines. Table 7-3 summarizes the cost
per ton results from the three highway heavy-duty vehicle programs, locomotive standards,
nonroad Tier 2 standards, and Category 1 and 2 commercial marine engine standards.
A comparison of the cost per ton numbers in Table 7-3 with the cost per ton results
presented throughout this chapter for marine diesel engines shows that the cost per ton of
applying the second tier of NOx standards under consideration to U.S. vessels only are favorable
in comparison. However, EPA is interested in addressing the emissions from foreign flav vessels
and believes that these can be most effectively addressed through the EVIO process. To be
consistent with the cost per ton values for other programs, the marine diesel numbers shown in
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Draft Regulatory Support Document
Table 7-3 reflect the aggregate cost per ton for the program rather than the high and low for
individual engines.
Table 7-3
Summary of Cost Per Ton for Recent EPA NOx Control Programs ($2001)
EPA Rule
Tier 2 Vehicle/Gasoline Sulfur
2004 Standards for
Highway Heavy-Duty Engines
2007 Standards for Highway Heavy-
Duty Engines/Diesel Sulfur
Locomotive Engine Standards
Nonroad Tier 2 Standards
Commercial Marine Standards
Pollutants Considered
in Calculations
NOx
NMHC*+NOx
HC+NOx
NOx
NMHC*+NOx
HC+NOx
Cost per ton
($/ton)
$1,400 - $2,400
$230 - $440
$1,600 - $2,000
$200 - $300
$460 - $720
$30 -$190
* nonmethane hydrocarbons (roughly equivalent to total HC for diesel engines)
7-4
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Chapter 7: Cost Per Ton
7.4 20-Year Cost Per Ton
Another tool that can be used to evaluate the cost per ton of a regulatory program is to
look at the costs incurred and the emissions benefits achieved over a fixed period of time. This
section presents the year-by-year cost and emission reductions for the 20-year period after
implementation of the second tier of NOx standards under consideration. Table 7-4 presents the
undiscounted stream of costs and benefits associated with the second tier of NOx standards
currently under consideration.
Table 7-4
20-Year Stream of Costs and Reductions for a Second Tier of NOx Limits
(30 Percent Below Tier 1)
Calendar Year
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
Costs
$1,242,702
$1,343,872
$1,450,937
$1,564,197
$1,683,971
$862,633
$960,420
$1,064,392
$1,174,880
$1,292,228
$1,416,798
$1,548,969
$1,689,139
$1,837,726
$1,995,166
$2,161,917
$2,338,461
$2,525,301
$2,722,963
$2,932,001
Reductions (tons)
1,219
2,533
3,946
5,465
7,021
8,658
10,377
12,182
14,075
16,058
18,135
20,308
22,580
24,955
27,495
30,165
32,971
35,922
39,025
42,318
Table 7-5 presents the sum of the costs and emission reductions over the 20-year period
after the second tier of NOx standards under consideration would take effect, on both an
undiscounted and 7-percent discounted basis. The annualized present value of the costs and NOx
reductions, assuming a 7 percent rate, are also presented. It should be noted that these cost per
ton figures are a little higher than those presented above for year 6 on a per-engine basis. This
difference is caused by the fact that the per-engine analysis relates costs to their resulting benefits
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Draft Regulatory Support Document
while the stream of costs analysis compares costs incurred to benefits achieved in a fixed time
frame. In other words, many of the costs incurred prior to 2026 would not achieve benefits until
after that time. This is, in part, due to the long lives and slow turnover of Marine diesel engines.
Table 7-5
Annualized Costs and Reductions
for the Period 2007-2026 due to a Second Tier of NOx Limits
Undiscounted 20 year value
Discounted 20 year value
Annualized value
NOx Reductions (tons)
375,000
161,000
15,200
Cost
$33,800,000
$17,400,000
$1,640,000
7.5 Potential Economic Impacts
The second tier of NOx limits under consideration for Category 3 Marine rule would
require controls on new vessel engines to reduce emissions. Chapter 8 provides details on the
development of other NOx levels for this rule. As described in Chapter 5, the costs to comply
with a second tier of standards would vary by engine type (number of cylinders and speed) and
across shipyards depending upon the number of Category 3 Marine vessels being manufactured
at any time. These regulatory costs may have financial implications for the affected producers,
and possibly broader implications as these effects are transmitted through market relationships to
other producers and consumers.
7.5.1 Summary of Compliance Costs
As described in Chapter 5, we estimate that the total net present value of the compliance
costs of a second tier of NOx standards set at 30 percent below Tier 1 would be $115,000 per
vessel (no monitoring costs) over a 30 year period during the first 5 years. After that time, the
compliance costs would likely fall after that as described in Chapter 5. Overall, in the first five
years, all U.S. shipyards could experience costs ranging from $0 to $1 million depending on the
number and type of Category 3 Marine vessels under construction at any given time. This range
reflects a given shipyard building no Category 3 Marine vessels at the low end to a given
shipyard building all the vessels in that year (e.g., projected seven vessels in 2007). There are
uncertainties regarding the projected growth in the industry and the number of orders any given
shipyard may secure in a given time period.
In 2007, the annualized cost of the Tier 2 program under consideration (not including
NOx monitoring operating costs) is estimated to be $1,000,000, which represents 0.17 percent of
total 1997 industry revenues (based on 1997 value of shipments forNAICS 3366115124 and
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assuming no corresponding revenue growth).2
7.5.2 Market Impacts
Typically, our economic analyses take several data elements as input to a model that
determines changes in market prices, output, and total social cost (via the change in producer and
consumer surplus). We are not projecting any costs or economic impacts associated with the
Tier 1 proposed standards; thus, this section focuses on the Tier 2 standards under consideration,
incremental to the Tier 1 proposed standards. In this screening analysis, we examine potential
financial impacts on engine manufacturers and vessel manufacturers.
7.5.2.1 Engine Manufacturers Impacts
The impacts of the Tier 2 standards under consideration applied to U.S. flagged vessels
are not expected to produce any measurable changes in an economic model of the Category 3
Marine diesel engine industry for the following reasons:
No Category 3 engines are currently produced in the US (although they are assembled in
U.S. shipyards).
Total U.S. flagged annualized compliance cost represents a small percentage (0.03 %) of
global annual Category 3 Marine engine revenue.3
The number of active new construction U.S. shipyards building large ocean-going vessels
was 3 in 2001.
• The Jones Act requirements will be a determining factor in decisions to contract with
U.S. shipyards (see Section 3.3.1.4).
We can conclude in general that because a model of the market is not likely to show any
changes resulting from the costs imposed by this regulation, the market as a whole will not show
adjustments in price and production. Because of the Jones Act requirements, it is likely that
affected producers will be able to recover any of the compliance costs incurred by raising prices.
Even if engine manufacturers were not able to do so, the costs are a small percentage of the
overall cost of a vessel for U.S. flagged vessels (on average 0.08 percent, ranging from about
0.23 percent for containerships and 0.02 percent for a cruise ship in the first five years).4 Thus, it
is unlikely that it would affect profitability. For these reasons, overall industry production is not
expected to change if these standards were adopted.
If the second tier of NOx standards under consideration were applied to all vessels,
including foreign flagged vessels, the costs would be 40 to 60 percent lower per engine, as
described in Section 5.3.3, Table 5.3-2 above. However, costs per ton are higher for foreign-
flagged vessels since we count only tons emitted near the U.S. We would anticipate that the total
compliance costs would be an even smaller percentage of the cost of a vessel. We would also
anticipate the annual compliance costs would be an even smaller percentage of annual global
revenues.
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7.5.2.2 Vessel Manufacturers Impacts
The impacts of the Tier 2 standards under consideration applied to U.S. flagged vessels
are not expected to produce any measurable changes in an economic model of the Category 3
Marine shipbuilding industry for the following reasons:
• Total annualized compliance cost represents a small percentage (0.17 percent) of total
annual shipments.
• The Jones Act requirements will be a determining factor in decisions to contract with
U.S. shipyards (see Section 3.3.1.4).
• The number of active new construction U.S. shipyards building large ocean-going vessels
was 3 in 2001.
• The largest producers account for a large percentage of market share (i.e., percentage of
total production).5
We can conclude in general that because a model of the market is not likely to show any
changes resulting from the costs imposed by this regulation, the market as a whole will not show
adjustments in price and production. Furthermore, because of the Jones Act requirements, it is
likely that affected producers will be able to recover any of the compliance costs incurred by
raising prices. Even if shipbuilders were not able to do so, the costs are such a small percentage
of the overall cost of a vessel that it is unlikely that it would affect shipyard profitability. Thus,
overall industry production is not change expected to change.
Rather than perform a full market analysis, we take a closer look at the firm-level impacts
assuming all costs will be absorbed by the owner of the shipyard. We do this by determining the
percentage of revenues that the compliance cost will consume. Using data presented in Chapter
3, the 8 facilities with capacity for building large commercial vessels are owned by 6 ultimate
parent firms. One of the eight shipyards filed for bankruptcy in 2001, and two other shipyards
focus on military and smaller vessel markets. Two parent companies own 3 each of the largest
commercial and military shipyards in the U.S. We were able to obtain employment data for 6 of
the 8 firms and revenues for 4 of the 8 firms, including the shipyards currently engaged in
commercial shipbuilding. For the shipyards engaged in building, the annualized compliance cost
(not including NOx monitor operating cost) as a percentage of annual firm revenues ranges from
0.05 to 0.2 percent.6 In addition, the annualized compliance cost as a percentage of parent
company revenue ranges from 0.005 to 0.016 percent. Therefore, the impacts presented by this
rule are likely to be minimal on all of the firms owning the affected shipyards.
If the second tier of NOx standards under consideration were applied to all vessels,
including foreign flagged vessels, the costs would be 40 to 60 percent lower per engine, as
described in Section 5.3.3, Table 5.3-2 above. However, costs per ton are higher for foreign-
flagged vessels since we count only tons emitted near the U.S. We would anticipate that the total
compliance costs would be an even smaller percentage of the overall cost of a vessel. We would
also anticipate the annual compliance costs would be an even smaller percentage of annual global
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revenues. In addition, the largest foreign shipyards receive substantial subsidies.7 Foreign
countries confer a variety of subsidies on their shipyards including grants, favorable loans, export
credits, restructuring aids, and even government ownership.8
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Chapter 7 References
1. "Commercial Marine Activity for Deep Sea Ports in the United States: Final Report,"
ARCADIS Geraghty & Miller, Inc., prepared for U.S. EPA, June 30, 1999.
2. U.S. Census Bureau. 1997 Economic Census. Manufacturing Industry Series, Shipbuilding
and Ship Repair. NAICS 336611. July 1999.
3. The annualized compliance cost is divided by an estimate of annual global engine revenue for
Category 3 marine engines. The annual global engine revenues were estimated by multiplying
range of engine costs ($2.5 to $3 million) by the number of worldwide engines produced in a
typical year (1,262 produced in 1998).
4. Although it is difficult to develop an average price for a custom-designed and built ship, we
estimate that the average price of a Category 3 vessel is $150 million, with containerships
averaging $50 million and cruise ships averaging $500 million per vessel. (See ASA 1993 report,
Revelt memo to docket 2002, and Koman memo to docket 2002).
5. U.S. EPA, Economic Impact Assessment of the Industrial Surface Coating of Shipbuilding
and Ship Repair National Emission Standard for Hazardous Air Pollutants (NESHAP). 1994.
6. This assumes that all of the compliance costs for the entire program falls on a single shipyard,
and thus this is a high end estimate. The upper bound calculation assumes the total annualized
cost is divided by the shipyard annual revenue (here using the shipyard annual revenues from
Table 3.2-4 and parent company annual revenues from Table 3.2-5).
7. American Shipbuilding Association. 1993. International Shipbuilding Aid: Shipbuilding Aid
Practices of the Top OECD Subsidizing Nations and Their Impact on U.S. Shipyards. June
1993.
8. Potomac Institute for Policy Studies. 1998. Maritech Program Impacts on Global
Competitiveness of the U.S. Shipbuilding Industry and Navy Ship Construction. PIPS-98-4. Dr.
James Richardson, Study Director. July 1, 1998.
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CHAPTER 8: Analysis of Alternatives
This chapter presents an analysis of three approaches that we considered as other
alternatives for a second tier of NOx standards. This analysis includes technological feasibility,
costs, emission reductions, and cost per ton and is performed using the same methodologies
described in earlier chapters.
8.1 Overview of Alternative Approaches
In addition to standards equivalent to a 30 percent reduction from Tier 1, we also
considered two other scenarios for a second tier of standards: 50 and 80 percent below the
proposed Tier 1 standards. In addition, we considered setting a fuel sulfur cap of 1.5 weight
percent for operation in U.S. waters. Table 8.1-1 presents these three scenarios and the
technology we considered in our analysis of these approaches. For all three of these alternative
approaches, this analysis uses an implementation date of 2007 so that a direct comparison can be
made to the 30 percent reduction scenario. However, additional lead time would likely be
necessary for manufacturers apply the technology needed for the more stringent NOx alternatives
compared with the implementation date under consideration for a second tier of NOx limits.
Also, we considered applying the two NOx control alternatives to just U.S. flagged vessels and to
all vessels operating near the U.S. coast. For the low sulfur fuel alternative, we only considered
applying this approach to all vessels operating near the U.S. coast.
Table 8.1-1: Alternative Approaches Considered in this Chapter
Alternative Standard
NOx 50% below Tier 1
NOx 80% below Tier 1
Fuel sulfur cap of 1.5 percent
Technology
Water introduction into the combustion process
Selective catalytic reduction or fuel cell technology
Low sulfur fuel use and fuel system modifications
The remainder of this chapter is divided into four sections. First is a discussion of the
technological feasibility of each of the alternative standards shown in Table 8.1-1. Second, we
present the emissions inventory impacts for each of the approaches. This is followed with a
comparison of the cost per ton estimates and a discussion of our conclusions.
8.2 Anticipated Technology for Alternative Approaches
This section describes several technologies that could be used to achieve additional NOx
reductions beyond 30 percent reduction from Tier 1 currently under consideration. In addition, it
discusses the feasibility of using low sulfur fuel to reduce PM, SOx, and NOx emissions.
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8.2.1 Water Introduction into the Combustion Process
To achieve 50 percent reduction beyond the proposed Tier 1 NOx standard, we believe
that introducing water into the combustion process could be an effective strategy. Water can be
used in the combustion process to lower maximum combustion temperature, and therefore lower
NOx formation, without an increase in fuel consumption. Water has a high heat capacity, which
allows it to absorb enough of the energy in the cylinder to reduce peak combustion temperatures.
Water may be introduced into the combustion process through emulsification with the fuel, direct
injection into the combustion chamber, or saturating the intake air.
Water emulsification refers to mixing water with the fuel as a stable suspension. Testing
on a high speed diesel engine has shown a 40 percent reduction in NOx with a water-fuel ratio of
50 percenta with only a slight increase in smoke.1 Two power plants with slow-speed diesel
engines are using water emulsification today to reduce NOx.2 In this case, they are achieving a
44 percent NOx reduction with 35 percent water emulsification. However, the fuel consumption
was increased by 1 to 2 percent. Although, these were not Marine engines, it is reasonable to
expect that similar results would be seen on Marine engines which are similar in design and
operation. Water emulsification requires changes to the engine and fuel system. Larger volume
fuel injectors and pumps are needed to handle the additional fuel/water volume. According to a
Marine engine manufacturer who investigated this technology on their engines, combining water
with fuel in the tank may introduce combustion problems due to unstable emulsion if more than a
30 percent NOx reduction is targeted.3 Also, this technique requires a significantly redesigned
fuel handling system to overcome the potential risk of corrosion and to maintain power output.
However, these problems may be overcome in the future as the strategy is refined.
As an alternative to storing emulsified fuel in the tank, water and fuel can be injected into
the combustion chamber using a common injector. The fuel and water can be mixed just prior to
injection or stratified in the injector. An example of the first strategy was developed for a
medium speed diesel engine, used in a power plant, in which the water is emulsified in the fuel
just prior to injection.4 The fuel/water is injected using solenoid controlled single injection units.
Through this system, the fuel/water mix can be changed under different conditions. At low
power (below 30% of rated), no water is added, from 30-40 percent of rated power, 20 percent
water is added, above 40% of rated power, about 35 percent water is added. This water dosage
strategy suggests that the engine may be less tolerant of water in the combustion chamber at
lower loads. Also, the water is shut off for about a minute when the engine load is increased and
the water dosage is significantly decreased prior to shutting off the engine. Using this strategy,
NOx was reduced by 52 percent at intermediate speed and 57 percent at rated speed. This report
stated that more work would be necessary to construct a durable injection pump which was
a For the purposes of this discussion the water to fuel ratio is expressed in percent. For
example, an engine using 50 percent water would use 50 gallons of water for every 100 gallons
of fuel oil consumed.
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Chapter 8: Analysis of Alternatives
eroded by cavitation and water wear after 900 hours. An example of stratified injection was
developed for a slow-speed diesel engine.5 In this case the injector alternates between fuel and
water. In this application, NOx was reduced 50 percent with about 70 percent water added. By
creating a multi-water layer in the fuel charge, this reduction was achieved without a significant
increase in fuel oil consumption.
More effective control of the water injection process can be achieved through the use of
an independent nozzle for water. Using a separate injector nozzle for the water allows larger
amounts of water to be added to the combustion process because the water is injected
simultaneously with the fuel, and larger injection pumps and nozzles can be used for the water
injection. In addition, the injection timing can be better optimized. On one slow-speed diesel
engine, a 45 percent NOx reduction was achieved with 60 percent water (9 g/kW-hr).6 Further
work on another engine achieved a NOx reduction of 70 percent with 90 percent water (6 g/kW-
hr).7 With only 50 percent water, a 40 percent reduction in NOx from this engine was observed.
One manufacturer is also evaluating two other methods introducing water into the
combustion process.8 These methods are combustion air humidification and steam injection.
With combustion air humidification, a water nozzle is placed in the engine intake and an air
heater is used to offset condensation. The result is saturated air at 70-90°C. Initial testing shows
that an 80 percent NOx reduction can be achieved with a water fuel ratio of two (4 g/kW-hr).
Corrosion at this high water to fuel ratio is not an issue due to the anti-polishing ring used on
newer engines. With steam injection, waste heat is used to vaporize water which is then injected
into the combustion chamber during the compression stroke. Initial tests have shown a 85
percent NOx reduction with a 3.0-3.5 steam fuel ratio (2.4-3.0 g/kW-hr). Fuel consumption was
improved by 2 g/kW-hr (roughly 1 percent). Although higher NOx reductions are seen with
combustion air humidification and steam injection than with direct water injection, more water is
needed for a given NOx reduction possibly due to the heating of the water prior to introduction
into the cylinder.
Fresh water is necessary for this NOx reduction strategy. Introducing salt water into the
engine could result in serious deterioration due to corrosion and fouling. For this reason, a ship
using water strategies would need to either produce fresh water through the use of a desalination
or distillation system or store fresh water on board. Cruise ships may already have a source of
fresh water that could be used to enable this technology. This water source is the "gray" water,
such as drainage from showers, which could be filtered for use in the engine. For other ocean-
going vessels, water storage tanks would likely displace either fuel storage which would limit the
range of the vessel or cargo space which would affect revenues. The alternative of using a
desalination or a distillation unit would include costs for the unit and would also require space
for the unit and for some water storage. Also, when and where a ship operates can have an effect
on the available water. A ship operating in cold weather uses all of the available steam heated by
the exhaust just to heat the fuel. Also, a ship operating in an area with low humidity would not
be able to condense water out of the air using the jacket water aftercooler.
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Durability issues may be a concern with water emulsification or injection systems. For
onboard water emulsifying units, cavitation is used to atomize the water and mix it into the fuel.
Although this works well at emulsifying the fuel, the water can cause significant wear of the
injection pump. For water injection systems, high pressure water is injected similar to in a fuel
injector. However, water does not have the inherent lubrication properties found in fuel.
Therefore, more research may be necessary on more durable materials.
Another concern with the use of water in the combustion process is the effect on PM
emissions. The water in the cylinder reduces NOx, which is formed at high temperatures, by
reducing the temperature in the cylinder during combustion. However, PM oxidation is most
efficient at high temperatures. At this time, we do not have sufficient information on the effect
of water emulsification and injection strategies on PM emissions to quantify this effect.
8.2.2 Selective Catalytic Reduction
We believe reductions of 80 percent beyond the proposed Tier 1 NOx standard could be
achieved through the use of selective catalytic reduction (SCR). SCR is one of the most effective
means of reducing NOx from large diesel engines. In SCR systems, a reducing agent, such urea
((NH2)C2O) is injected into the exhaust. This urea is mixed into a water solution and injected
into the exhaust where the heat decomposes the urea to produce ammonia and carbon dioxide
which is channeled through a reactor where NOx emissions are reduced. In a system known as
"compact SCR", oxidation catalysts are used in conjunction with the SCR reactor to increase the
effectiveness of the system. An oxidation catalyst upstream of the SCR reactor can be used to
convert NO to NO2. Because the reduction of NOx can be rate limited by NO reductions,
converting some NO to NO2 allows manufacturers to use a smaller reactor and/or operate at
lower temperatures.9 In addition, oxidation catalysts can be used downstream of the reactor to
oxidize any ammonia that "slips" through the SCR unit. SCR systems are being successfully
used for large stationary source applications, which operate under constant, high-load conditions.
In fact, emission reductions in excess of 90 percent can be achieved using SCR.
Manufacturers are demonstrating similar NOx reduction using SCR technology for
Marine applications.1041 One vessel with a MaK 8M32 engine, medium-speed Category 3, has
shown reduced NOx emissions by over 90 percent with no fuel consumption penalty with the
SCR system operating.12 Another manufacturer has demonstrated a standard SCR system on 8
vessels and a compact SCR system, which uses an oxidation catalyst upstream of the SCR
reactor to reduce reactor size, on four vessels.13 Combined, these twelve vessels are equipped
with a total of 40 medium-speed Category 3 Marine engines. Also, one manufacturer of SCR
systems under the trade name SINOx, had systems on 56 Category 2 or 3 Marine engines
operating on both residual and distillate fuel oil at the end of the year 2000.14 A list of the
systems is contained in Appendix A to this Chapter.
SCR systems available today are effective only over a narrow range of exhaust
temperatures (above 300°C). To date, these systems have primarily been applied to four-stroke
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medium speed engines which have exhaust temperatures above 300°C at least at high load.
Two-stroke slow speed engines have lower exhaust temperatures and are discussed later. The
effectiveness of the SCR system is decreased at reduced temperatures exhibited during engine
operation at partial loads. Most of the engine operation in and near commercial ports and
waterways close to shore is likely to be at these partial loads. In fact, reduced speed zones can be
as large as 100 miles for some ports. Because of the cubic relationship between ship speed and
engine power required, engines may operate at less than 25 percent power in a reduced speed
zone. During this low load operation, no NOx reduction would be expected, therefore SCR
would be less effective than standards based on in-engine controls (i.e., the 30 percent reduction
scenario) during low load operation near ports. Some additional heat to the SCR unit can be
gained by placing the reactor upstream of the turbocharger; however, this temperature increase
would not be large at low loads and the volume of the reactor would diminish turbocharger
response when the engine changes load. The engine could be calibrated to have higher exhaust
temperatures; however this could affect durability (depending on the fuel used) if this calibration
also increased temperatures at high loads. For an engine operating on residual fuel, vanadium in
the fuel can react with the valves at higher temperatures and damage the valves.
SCR systems traditionally have required a significant amount of space on a vessel; in
some cases the SCR was as large as the engine itself. However, at least one manufacturer is
developing a compact system which uses an oxidation catalyst upstream of the reactor to convert
some NO to NO2 thus reducing the reactor size necessary. The reactor size is reduced because
the NO2 can be reduced without slowing the reduction of NO. Therefore, the catalytic reaction is
faster because NOx is being reduced through two mechanisms. This compact SCR unit is
designed to fit into the space already used by the silencer in the exhaust system. If designed
correctly, this could also be used to allow the SCR unit to operate effectively at somewhat lower
exhaust temperatures. The oxidation catalyst and engine calibration would need to be optimized
to convert NO to NO2 without significant conversion of S to direct sulfate PM. NOx reductions
of 85 to 95 percent have been demonstrated with an extraordinary sound attenuation of 25 to 35
dB(A).15
Information from one manufacturer who has 40 installations of SCR reveals that the
engines using the technology are either using low sulfur residual fuel (0.5%-1% S) or distillate
fuel. Low sulfur residual fuel is available in areas which provide incentives for using such fuel,
including the Baltic Sea, however such fuel is not yet available at ports throughout the United
States. However, distillate fuel is available. Low sulfur fuel is necessary to assure the durability
of the SCR system because sulfur can become trapped in the active catalyst sites and reduce the
effectiveness of the catalyst. This is known as sulfur poisoning which can require additional
maintenance of the system. The operation characteristics of ocean going vessels may interfere
with correct maintenance of the SCR system. Ferries which have incorporated this technology to
date do not run continuously and therefore any maintenance necessary can be performed during
regular down times. The availability of time for repair can be an issue for ocean going vessels
for they do not have regular down times.
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Sulfur in the fuel is also a concern for systems using an oxidation catalyst because, under
the right conditions, sulfur can also be oxidized to form direct sulfate PM. At higher
temperatures, up to 20 percent of the sulfur could be converted to direct sulfate PM in an
oxidation catalyst. For a typical diesel engine without aftertreatment, the conversion rate is about
2 percent.16 Depending on the precious metals used in the SCR unit, it could be possible to
convert some sulfur to direct sulfate PM in the reactor as well. Manufacturers would have to
design their exhaust system (and engine calibration) such that temperatures would be high
enough to have good conversion of NO, but low enough to minimize conversion of S to direct
sulfate PM. Direct sulfate PM emissions could be reduced by using lower sulfur fuel such as
distillate.
A vessel using a SCR system would also require an additional tank to store ammonia (or
urea to form ammonia). The urea consumption results in increased operating costs. Also, if
lower sulfur diesel fuel were required to ensure the durability of the SCR system or to minimize
direct sulfate PM emissions, this lower sulfur fuel would increase operating costs.
If the combustion is not carefully controlled, some of the ammonia can pass through the
combustion process and be emitted as a pollutant. This is less of an issue for Category 3 Marine
engines, which generally operate under steady-state conditions, than for other mobile-source
applications. In addition, in ships where banks of engines are used to drive power generators,
such as cruise ships, the engines generally operate under steady-state conditions near full load. If
ammonia slip still occurred, an oxidation could be used downstream of the reactor to burn off the
excess ammonia.
Slow-speed Marine engines generally have even lower exhaust temperatures than
medium speed engines due to their two-stroke design. However, we are aware of four slow-
speed Category 3 Marine engines that have been successfully equipped with SCR units. Because
of the low exhaust temperatures, the SCR unit is placed upstream of the turbocharger to expose
the catalyst to the maximum exhaust heat. Also, the catalyst design required to operate at low
temperatures is very sensitive to sulfur. Especially at the lower loads, the catalyst is easily
poisoned by ammonium sulfate that forms due to the sulfur in the fuel. To minimize this
poisoning on these four in-service engines, highway diesel fuel (0.05% S) is required. In
addition, these ships only operate with the exhaust routed through the SCR unit when they enter
port in the U.S. which is about 12 hours of operation every 2 months. Therefore, the sulfur
loading on the catalyst is much lower than it would be for a vessel that continuously used the
SCR system. To prevent damage to the catalyst due to water condensation, this system needs to
be warmed up and cooled down gradually using external heating. Another issue associated with
the larger slow-speed engines and lower exhaust temperatures is that a much larger SCR system
would be necessary than for a vessel using a smaller medium-speed engine. Size is an issue
because of the limited space on most ships.
SCR reactors need constant cleaning using either ultrasound or compressed air.
Ultrasound is performed by the use of an acoustic horn installed in the reactor. The horn
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automatically sounds for a period of time periodically during the operation of the engine. The air
pulsation from the horn will prevent dirt that is building up on the catalyst. The horn may be
driven by air from the normal air system installed on the vessel. While this method requires no
engine shutdown, compressed air cleaning does require a period of engine shut down. In this
method, a soot blowing probe is inserted into the catalyst unit to remove soot. Inspection holes
are opened to allow the insertion of the probe. It is envisioned that the reactor will be cleaned
during each port call taking 4 person-hours for medium-speed engines and 6 person-hours for
low-speed engines. SCR reactors also will need to be replaced after about 20,000 hours of
operation.
8.2.3 Fuel Cells
Another approach for meeting a level of 80 percent below the proposed Tier 1 NOx
standard would be to use fuel cells to power the vessel in place of an internal combustion engine.
A fuel cell is like a battery, except a fuel cell generates electricity instead of storing it. The
electro-chemical reaction taking place between hydrogen and oxygen gases generate the
electricity from the fuel cell. The key to the energy generated in a fuel cell is that the hydrogen-
oxygen reaction can be intercepted to capture small amounts of electricity. The by-product of
this reaction is the formation of water. Current challenges include the storage or formation of
hydrogen for use in the fuel cell and cost of the catalyst used within the fuel cell.
Over the past 5 years several efforts to apply fuel cells to Marine applications have been
conducted. These include grants from the Office of Naval Research and the U.S. Navy. The
Office of Naval Research initiated a three-phase advanced development program to evaluate fuel
cell technology for ship service power requirements for surface combatants in 1997.17 The U.S.
Navy in early 2000 sponsored an effort to continue the development of the molten carbonate fuel
cell for Marine use.18 The Society of Naval Architects and Marine Engineers released the
technical report "An Evaluation of Fuel Cells for Commercial Ship Applications." This report
examines fuel cells for application in commercial ships of all types for electricity generation for
ship services and for propulsion.19
The concept of fuel cells is currently supported by several sources, including the U.S.
Maritime Administration (MARAD) and the state of California's Fuel Cell Partnership.
MARAD's Division of Advanced Technology has included the topic of fuel cells as a low-
emission technology that should be demonstrated. California's Fuel Cell Partnership seeks to
achieve four main goals which include 1) Demonstrate vehicle technology by operating and
testing the vehicles under real-world conditions in California; 2) Demonstrate the viability of
alternative fuel infrastructure technology, including hydrogen and methanol stations; 3) Explore
the path to commercialization, from identifying potential problems to developing solutions; and
4) Increase public awareness and enhance opinion about fuel cell electric vehicles, preparing the
market for commercialization.
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8.2.4 Low Sulfur Fuel
Another emission control standard we considered was to require that Category 3 Marine
engines operate on fuel with a sulfur level less than 1.5 percent (15,000 ppm) in U.S. waters.
This limit is the same as the requirement for SOx emission control areas under Regulation 14 of
MARPOL. Annex VI.
The majority of Category 3 engines are designed to run on residual fuel, which can have
sulfur levels as high as 4.5 percent although the global average is about 2.7 percent.20 Distillate
fuel, on the other hand, generally has a fuel sulfur level well below 1.5 percent. Operating on
lower sulfur fuel reduces both SOx emissions and direct sulfate PM emissions. In addition,
because residual fuel is made from the very end products of the oil refining process, formulated
from residues remaining from the primary distilling stages of the refining process, it has higher
contents of ash, metals, nitrogen, and other undesirable constituents than distillate fuel, especially
from an exhaust emission standpoint. Switching to distillate would reduce the fraction of PM
made up by ash and metals and, because of the lower density, could reduce soot emissions too.
NOx reductions may also result, because distillate fuel contains less nitrogen and has better
ignition qualities.
Alternatively, ships can use residual fuels produced to meet the 1.5 percent sulfur
requirement. Refiners can produce low-sulfur residual fuel from a low-sulfur crude oil or they
can put the fuel through a de-sulfonation step in the refinery process. They can also produce it by
blending Marine distillate fuel, which typically has fuel sulfur levels between 0.2 and 0.3 percent.
For a ship to operate on residual fuel, certain design requirements are necessary. First,
the fuel must be heated before it will flow through the fuel lines because residual fuel is a waxy
solid at room temperature. In addition, the fuel is processed through centrifuges and filters to
remove water and other impurities. Fuel pumps and injectors must be designed to operate well
with a high density fuel. In fact, these fuel pump designs generally rely on the higher density and
better lubrication properties of the residual fuel.
Engines designed to operate on residual fuel are generally also capable of operating on
distillate fuel. In fact, most ships have the ability to switch back and forth between distillate and
residual fuels. Although most ships have multiple fuel tanks, these tanks sized would likely have
to be modified to account for increased operation on low sulfur fuel. The amount of fuel carried
is small compared with the displacement of ship, so the ship can tolerate a wide range of fuel
levels and weight distributions. Because of this and because tankers are converting to double-
walled hulls (which provides more room for ballast tanks), commercial ships generally no longer
use fuel tanks to balance the weight of the ship. This is still done on some navy vessels.
Most ships have the ability to switch to distillate fuel. If the engine is to be shut down for
maintenance, distillate fuel is often used to flush out the fuel system. Switching to distillate fuel
generally requires 20 to 60 minutes and is governed by the time desired for fuel temperature
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Chapter 8: Analysis of Alternatives
cooldown. Switching from a heated residual fuel to a cool distillate fuel too fast could cause
damage to fuel pumps. Industry has claimed that there could be fuel pump durability problems if
the engine is operated on distillate fuel for more than a five or six days. In the Baltic Sea, which
is a SOx emission control area under Annex VI, ships often run up to two or three days on
distillate. For continued operation on distillate fuel, separate pumps and lines may be necessary.
In addition, modification to the fuel tanks may be necessary in some vessels to ensure proper
capacity for distillate fuel.
Today's Marine distillate fuel can be split into three subgroups: 1) Pure distillate , 2)
Distillate supplied via shore tanks, lines, and barges which may have contained some residual
fuel resulting in some contamination of the distillate fuel, and 3) Distillate intentionally blended
by the supplier with a residual fuel component up to 10 or 15 percent of the total supplied; the
overall product, however, does not require preheating to reduce viscosity prior to use in engines
or boilers. For the first of these two types of fuel, the ash content is generally below 0.01 percent
(the test reporting limit) unless some extraneous contamination (such as seawater) has occurred
during delivery or storage. In the case of third fuel type, the ash content could be up to 0.02
percent (again excepting unforeseen contamination) and that ash will normally be the product of
the vanadium and (to a lesser extent nickel) present in the residual fuel fraction.
Regulating fuel sold in the U.S. would not necessarily ensure that low sulfur fuel was
used near the U.S. coast because ships may choose to bunker before entering or after leaving the
U.S. However, regulation 14 of MARPOL Annex VI allows areas in need of SOx emission
reductions to petition to be designated as SOx Emission Control Areas (SECA). Within such
waters, the maximum sulfur content of the fuel will be limited to 1.5 percent.13 We intend to
work through the MARPOL process to designate certain areas in the U.S. as sulfur control areas
which would require the use of low sulfur fuel.
8.3 Emissions Inventory
This section presents our analysis of the potential environmental impacts of the
alternative standards. As with for the cost analysis, the emission reductions are only included for
operation within 175 nautical miles of the U.S. coast. Tier 1 inventories of NOx, PM, and SOx
are taken from Chapter 6.
NOx emission reductions for each of the alternative standards were calculated using the
same methodology as presented in Chapter 6. The only differences in this analysis are the
percent reductions in NOx from Tier 1 and an implementation date of 2010 instead of 2007.
Tables 8.3-1 and 8.3-2 present the potential NOx reductions from the two alternative NOx
standards applied to U.S. flagged ships and applied to all ships.
b Unless SOx emission controlled by secondary means which at present is not clear.
8-9
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Draft Regulatory Support Document
Table 8.3-1: Potential NOx Reductions from Alternative Tier 2 Standards
Applied to U.S. Flagged Vessels Only (1000 short tons)
Year
1996
2010
2020
2030
Tier 1
190.0
274.1
367.5
530.8
50% Below Tier 1
Control
190.0
265.6
326.8
439.1
% Reduction
—
3.1
11.1
17.3
80% Below Tier 1
Control
190.0
260.0
301.9
382.9
% Reduction
—
5.0
17.8
27.9
Table 8.3-2: Potential NOx Reductions from Alternative Tier 2 Standards
Applied to All Vessels (1000 short tons)
Year
2000
2010
2020
2030
Tier 1
190.0
274.1
367.5
530.8
50% Below Tier 1
Control
190.0
260.7
276.9
311.2
% Reduction
—
4.9
24.7
41.4
80% Below Tier 1
Control
190.0
252.5
221.4
176.7
% Reduction
—
7.9
39.8
66.7
For the 1.5 percent sulfur residual fuel scenario, our estimates of SOx and PM reductions
are based strictly on the reduction of sulfur in the fuel from 2.7 to 1.5 percent. In this case, no
NOx reductions are anticipated. Table 8.3-3 presents the emission reductions due to using this
low sulfur fuel for all vessel operation within 175 nautical miles of the U.S. coast from all
vessels with Category 3 Marine engines regardless of flag state.
8-10
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Chapter 8: Analysis of Alternatives
Table 8.3-3: Potential Emissions Reductions from Using 1.5% Sulfur Fuel for all Vessel
Operations Within 175 Nautical Miles of U.S. Coast (1000 short tons)
PM
SOx
Baseline case (thousand short tons)
Control case (thousand short tons)
Percent reduction from Tier 1
Baseline case (thousand short tons)
Control case (thousand short tons)
Percent reduction from Tier 1
1996
17.1
17.1
—
156.2
156.2
—
2010
26.0
21.3
18
192.8
108.0
44
2020
36.7
30.1
18
271.2
151.9
44
2030
54.2
44.5
18
399.7
223.9
44
For the 0.3 percent sulfur fuel case, our estimates of SOx reductions are based on a
reduction of sulfur in the fuel from 2.7 to 0.3 percent. We estimate that about 98 percent of the
sulfur in the fuel is converted to SOx while the rest is converted to direct sulfate PM.21 Our
estimates of PM reductions are based on this and changes to other fuel components. We estimate
that PM from a Marine engine operating on residual fuel is made up of 45 percent sulfate, 25
percent carbon soot, 20 percent ash, and 10 percent soluble organic hydrocarbons.22 Reducing
sulfur in the fuel would reduce direct sulfate PM by about 90 percent. In addition, if distillate
fuel is used, the ash content and the density of the fuel would be reduced. This analysis results in
a total PM reduction of 63 percent. Using residual fuel can lead to NOx increases due to nitrogen
in the fuel. For this analysis we use a NOx reduction often percent based on a reduction of
nitrogen in the fuel on the assumption that distillate fuel would be required to meet this sulfur
level. Table 8.3-4 presents the potential SOx, PM, and NOx reductions from using distillate fuel
for all vessel operation within 175 nautical miles of the U.S. coast from all vessels with Category
3 Marine engines regardless of flag state.
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Draft Regulatory Support Document
Table 8.3-4: Potential Emissions Reductions from Using 0.3% Sulfur Fuel for all Vessel
Operations Within 175 Nautical Miles of U.S. Coast (1000 short tons)*
NOx
PM
SOx
Baseline case (thousand short tons)
Control case (thousand short tons)
Percent reduction from Tier 1
Baseline case (thousand short tons)
Control case (thousand short tons)
Percent reduction from Tier 1
Baseline case (thousand short tons)
Control case (thousand short tons)
Percent reduction from Tier 1
1996
190.0
190.0
—
17.1
17.1
—
156.2
156.2
—
2010
274.1
246.7
10
26.0
9.6
63
192.8
21.2
89
2020
367.5
330.7
10
36.7
13.6
63
271.2
29.8
89
2030
530.8
477.7
10
54.2
20.1
63
399.7
44.0
89
*For standards applying only to U.S.-flagged vessels.
8.4 Cost per Ton
This section assesses the cost per ton of emission reduction for the two alternative NOx
emission standards and the low sulfur fuel standard using the methodology presented in
Chapter 7. This analysis relies in part on cost information from Chapter 5 and emissions
information from section 8.3 to estimate the cost per ton of the alternative standards in terms of
dollars per short ton of NOx emission reductions. All of the cost per ton estimates presented
here are based on the costs and benefits beyond Tier 1.
Table 8.4-1 presents aggregate cost per ton estimates for the three alternative NOx
standards for U.S. flagged ships only and then for all ships. By including foreign flagged vessels
under these alternative approaches, the cost per engine decreases because the development costs
can be distributed across more engines. However, the cost per ton actually increases because
U.S. flagged vessels spend about 16 times as much of their operating time within 175 nautical
miles of the U.S. coast. Therefore, the tons of NOx reduced per year in U.S. waters for an
average foreign flagged vessel (which make up about 97 percent of the vessels23) are lower.
Operating costs, which are proportional to the amount of time the ship operates in U.S. waters,
do not depend on the vessel's flag state. For water injection, the operating costs include the
effective cost of the water. For SCR, the operating costs include urea consumption as well as
ship operation on 0.05 percent sulfur fuel.
8-12
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Chapter 8: Analysis of Alternatives
Table 8.4-1
Cost per ton ($/short ton) of the Alternative NOx Standards Discounted at 7 Percent
Alternative
Standards
Model Year
Grouping
NPV Benefits
(short tons)
NPV Operating
Costs
Engine & Vessel
Costs
Discounted Cost
Per Ton
U.S. Flagged Vessels Only
50% below
Tier 1
80% below
Tier 1
Ito5
6 +
Ito5
6 +
1,915
3,064
$527,000
$9,543,000
$207,000
$89,000
$1,014,000
$776,000
$370
$316
$3,405
$3,337
Foreign Flagged Vessels Only
50% below
Tier 1
80% below
Tier 1
1 to 5
6 +
1 to 5
6 +
74
119
$84,000
$410,000
$137,000
$89,000
$972,000
$776,000
$2,737
$2,174
$10,607
$9,159
All Vessels
50% below
Tier 1
80% below
Tier 1
Ito5
6 +
Ito5
6 +
122
195
$95,000
$629,000
$137,000
$89,000
$972,000
$776,000
$1,768
$1,424
$7,618
$6,732
Table 8.4-2 presents aggregate cost per ton estimates for using low sulfur Marine diesel
oil for all ships (regardless of flag) operating within 175 nautical miles of the U.S. coast.
Although all of the costs could be applied to PM and the SOx reductions could be considered
"free," we recognize that there is benefit to reducing both PM and SOx. Therefore, we apply 10
percent of the cost to SOx reductions. If all the costs were applied to PM, the estimated $/ton for
PM control would be about 10 percent higher than shown below. No costs are applied to NOx
control, so a cost per ton value is not presented.
8-13
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Draft Regulatory Support Document
Table 8.4-2
Cost per ton ($/short ton) of Low Sulfur Approach Discounted at 7 Percent
Alternative
Standards
1.5% Sulfur
0.3% Sulfur
Pollutant
PM
SOx
PM
SOx
NPV Benefits
(short tons)
4.3
61
8.7
122
NPV Operating
Costs
$125,000
$14,000
$246,000
$27,000
Engine & Vessel
Costs
$45,000
$5,000
$45,000
$5,000
Discounted Cost
Per Ton
$38,066
$302
$32,968
$262
8.5 Summary
We considered two alternative approaches to reduce NOx emissions: 50 and 80 percent
below Tier 1. We also considered a third approach of using low sulfur (distillate) fuel in U.S.
waters.
For a 50-percent reduction, we considered water injection with 0.5 water to fuel ratio. At
the present time, the cost per ton for the water injection system ranges from $370 to $1,768
depending on if it applies to U.S. flagged vessels only or all vessels operating within 175 nautical
miles of the U.S. coast. This analysis does not consider the lost space on a vessel due to water
storage, nor does it consider the alternative of adding water distillation boilers which would add
cost to the vessel, require space, and require additional fuel consumption. Water storage would
either displace fuel storage and reduce the range of the vessel or reduce cargo space which would
slightly affect a vessel's profitability. This technology is in operation on a pilot basis, with
promising results so far. At the same time, we are aware that water injection would represent a
very significant departure from established technology. While this may have a continuing
presence in niche applications, we do not believe the technology has matured enough for us to
adopt standards that would effectively mandate its use on all Category 3 Marine engines. We
expect that this technology will continue to develop over time and that the various concerns
related to universal application of this technology will eventually be addressed. In addition, more
information is necessary on the effects of this technology on PM emissions. Therefore, we have
decided not to propose standards at this level at this time.
For the 80 percent NOx reduction case, we considered the use of selective catalytic
reduction with a urea consumption rate of about 8 percent of the fuel consumption rate. Our
estimated cost per ton for this approach ranges from $3,405 to $7,618 depending on if it applies
to U.S. flagged vessels only or all vessels operating within 175 nautical miles of the U.S. coast.
This is considerably higher than the cost per ton figures for the recent mobile source programs
presented in Chapter 7 (Table 7.3). The cost per ton estimate for the use of SCR includes the
cost of using lower sulfur fuel which we believe would be necessary for the durability of the
system and to prevent increases in direct sulfate PM. In the future, however, technological
8-14
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Chapter 8: Analysis of Alternatives
advances increase the effectiveness of these units at lower temperatures and may reduce the cost
of this system and may improve the durability of the system on higher sulfur fuels.
For SCR to be effective, an infrastructure would be necessary to ensure that ships could
refuel at ports they visit. We believe that it would take some time to set up a system for getting
fuel to ships that fill up using barges, especially if the standard were only to apply to U.S. flagged
ships due to the low production volume. SCR would require space for urea storage, but it would
likely be much less than that for water storage in the above approach because the volume of urea
needed is only 5-10 percent of the volume of water needed for the water injection case
considered above. In addition, at least one manufacturer is developing a compact SCR unit that
will minimize the space needed for this system. We also believe that there are technical issues
that need to be resolved such as effectiveness at low loads and the effect of the catalyst in the
exhaust on direct sulfate PM emissions. As with water injection, we believe SCR may be
appropriate for certain applications, but also believe that the remaining technology development
and system cost prevent us from expecting manufacturers to apply SCR to all Category 3 Marine
engines at this time. We are therefore proposing to designate 80-percent reductions as a target
for recognition as voluntary low-emission engines, rather than adopting mandatory standards
based on this technology.
We are not proposing low sulfur fuel requirements in this rule, in large part because
regulating fuel sold in the U.S. would not necessarily ensure that the cleaner fuel was used in
U.S. waters. The Clean Air Act limits us to setting requirements on fuel entered into commerce
in the U.S. It is not clear if fuel on ships operating in waters under U.S. jurisdiction is "entered
into commerce." If we can regulate only the fuel sold in the U.S., then a fuel sulfur standard
would be unlikely to have a significant impact on emissions because ships would likely choose to
bunker before entering or after leaving the U.S. However, Regulation 14 of MARPOL Annex VI
allows areas in need of SOx emission reductions to petition to be designated as SOx Emission
Control Areas. Within these designated areas, the maximum sulfur content of the fuel is limited
to 1.5 percent.0 We intend to work through the MARPOL process to designate certain areas in
the U.S. as sulfur control areas, which would require the use of distillate fuel by all vessels
operating there.
Unless SOx emission controlled by secondary means which at present is not clear.
8-15
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Draft Regulatory Support Document
Chapter 8 References
1. Konno, M., Chikahisa, T., Murayama, T., "Reduction of Smoke and NOx by Strong
Turbulence Generated During the Combustion Process in D.I. Diesel Engines," SAE Paper
920467, 1992.
2. Ohtsu, M., "Recent Development of Slow Speed Diesel Power Plants," International Council
on Combustion Engines, CIMAC Congress 2001.
3. Paro, D., "Effective, Evolving, and Envisaged Emission Control Technologies for Marine
Propulsion Engines," presentation from Wartsila to EPA on September 6, 2001.
4. Kamleitner, E., Haury, H., "Reduction of Emissions of a High Efficient Diesel Engine with
Solenoid Controlled Injection Pump by Means of Water Injection," International Council on
Combustion Engines, CIMAC Congress 2001.
5. Sakabe, H., Okabe, M., "The UEC-LS II/LSE Engine Development Program," International
Council on Combustion Engines, CIMAC Congress 2001.
6. Aeberli, K., Mikulicic, N., "The Sulzer RTA-Low Speed Engine Range: Today and In the
Future," International Council on Combustion Engines, CIMAC Congress 2001, Docket A-2000-
11, Document H-A-07.
7. Paro, D., "Effective, Evolving, and Envisaged Emission Control Technologies for Marine
Propulsion Engines," presentation from Wartsila to EPA on September 6, 2001.
8. Paro, D., "Effective, Evolving, and Envisaged Emission Control Technologies for Marine
Propulsion Engines," presentation from Wartsila to EPA on September 6, 2001.
9. Schafer-Sindlinger, A., "NOx Reduction for Diesel Vehicles," Degussa, Presentation at
Coming's Clean Diesel Workshop, September, 1999.
10. Hughes, D., McAdams, R., Non-Thermal Plasma for Marine Diesel Engines," International
Council on Combustion Engines, CIMAC Congress 2001.
11. Mikulicic, N., "Exhaust Emissions: Next Steps for Low-Speed Two-Stroke Engines," article
in Marine News, published by Wartsila NSD, NO. 3 -1999, Docket A-2000-11, Document H-A-
01.
12. Braren, Roerd, "Emissions reduction of HFO Operation," paper presented at the 21st Marine
Propulsion Conference, Athenaeum Inter-Continental Hotel Athens, Greece, March 23-24, 1999.
13. E-mail from Fred Danska of Wartsila to Cheryl Caffrey of EPA on April 22, 2002.
8-16
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Chapter 8: Analysis of Alternatives
14. Ingalls, M., Fritz S., "Assessment of Emission Control Technology for EPA Category 3
Commercial Marine Diesel Engines," Southwest Research Institute, September 2001, Docket A-
2000-11, Document II-A-08.
15. Paro, D., "Effective, Evolving, and Envisaged Emission Control Technologies for Marine
Propulsion Engines," presentation from Wartsila to EPA on September 6, 2001.
16. "Emission Factors for Compression Ignition Nonroad Engines Operated on No. 2 Highway
and Nonroad Diesel Fuel," U.S. Environmental Protection Agency, EPA420-R-98-001, March
1998.
17. Steinfeld, G., Sanderson, R., Ghezel-Ayah, H., and Abens, S., "Direct Carbonate Fuel Cell
for Ship Service Application", Energy Research Corporation, Danbury CT, Docket A-2001-11,
ItemII-A-33.
18. Kami, Z., Fontneau, P., Allen, S., Sedat, R., Ghezel-Ayagh, H., Abens, S., Sanderson, R.,
Steinfeld, G., Lukas, M., "Marine Application of Fuel Cells", www.ercc.com/marine_app.pdf
January 10, 2002, Docket A-2001-11, Item II-A-34.
19. The Society of Naval Architects and Marine Engineers, "Fuel Cells for Commercial Ships",
www.sname.org/tr_press_fuel.htm. January 10, 2002, Docket A-2001-11, Item U-A-35.
20. Sulphur Monitoring 2002. Report to Marine Environmental Protection Committee, 47th
Session. MEPC 47/INF.2, August 28, 2001. A copy of this document can be found in Docket A-
2000-11, Document No. XXXX.
21. "Emission Factors for Compression Ignition Nonroad Engines Operated on No. 2 Highway
and Nonroad Diesel Fuel," U.S. Environmental Protection Agency, EPA420-R-98-001, March
1998.
22. Daniel Paro, "Effective, Evolving and Envisaged Emission Control Technologies for Marine
Propulsion Engines," Presentation from Wartsila to EPA, September 6, 2001.
23. "Overview of the Foreign Traffic Vessel Entrances and Clearances Data," Database made
available by the U.S. Maritime Administration, http://www.itdb.bts.gov/download.
8-17
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Draft Regulatory Support Document
APPENDIX TO CHAPTER 8
SIEMENS SINOx Exhaust Gas Treatment Plants and Systems Marine
Customer
Operator
TT-Line(D)
Nils Dacke
Hertug
Skule(N)
Fosen
Trafikklag
Gabriella
(SF)
Viking Line
Thielvar (S)
Gotland
Rederi
Visby(S)
Gotland
Rederi
Fast Ferry(S)
Gotland
Rederi
MS Cellus
(S) Roerd
Braren
Birka
Princess
Wartsila
NSD
MS
Ortviken(S)
SEA
PARTNER
MS Baltic 2
MS Baltic 3
Customer
Operator
Field of
Application
Ship propulsion
Ship propulsion
Ship genset
Ship propulsion
4 main engines
2 aux engines
Ship propulsion
4 main engines
3 aux engines
Ship propulsion
4 main engines
3 aux engines
Ship propulsion
1 main engine
1 aux engine
Ship propulsion
4 main engines
2 aux engine
Ship propulsion
2 x main engines
3 x aux engines
Ship propulsion
1 main engine
Ship propulsion
1 main engine
Field of
Application
Fuel
MDO
MDO
MDO
MDO
MDO
MDO
HFO
MDO
HFO
MDO
HFO
MDO
HFO
HFO
Fuel
Capacity in
kW
4.500
920
2.000
4x3.720
2x1.240
4x5.200
3x11.435
4x7.000
3x450
3.840
540
4x4.500
2x2.250
2x4.050
3x610
3.360
3.360
Capacity in
kW
Volume flow
in Nm3/h
27.500
7.200
12.000
4x18.500
2x6.000
4x37.500
3x7.500
4x40.000
21.000
3.000
4x26.000
2x14.200
2x25.500
3x3.200
19.000
19.000
Volume flow
in Nm3/h
Extent of
Delivery
SINOx
SINOx
SINOx
SINOx
SINOx
SINOx
SINOx
SINOx
SINOx
SINOx
SINOx
Extent of
Delivery
Delivery
Date
1995
1997
1997
1997
1997
1998
1998
1998
1999
1999
1999
Delivery
Date
8-18
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Chapter 8: Analysis of Alternatives
Customer
Operator
MS Baltic 4
MS
Timbus(S)
Roerd Braren
MS
Forester(S)
Roerd Braren
Silja Line
1600 LM
RoPax(S)
Gotland
Rederi
Field of
Application
Ship propulsion
1 main engine
Ship propulsion
1 main engine
1 aux engines
Ship propulsion
1 main engine
2 aux engines
Ship propulsion
4 main engines
Ship propulsion
4 main engines
3 aux engines
Fuel
HFO
HFO
MDO
HFO
MDO
HFO
HFO
Capacity in
kW
3.360
3.840
540
3.840
239
4x7.950
4x12.600
3x1,530
Volume flow
in Nm3/h
19.000
21.000
3.000
21.000
1.200
48.500
4x63.000
3 x 9.000
Extent of
Delivery
SINOx
SINOx
SINOx
SINOx
SINOx
Delivery
Date
1999
1999
1999
2000
2000
Reference: SINOx Exhaust Gas Treatment Plants and Systems, Marine, Sales brochure from
Siemens Westinghouse Power Corp.
8-19
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Draft Regulatory Support Document
8-20
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Chapter 9: Test Procedure
Chapter 9: TEST PROCEDURE
In nonroad engine emission control programs, the test procedures we use to measure
emissions are as important as the standards we put into place. These test procedure issues
include duty cycle for certification, in-use verification testing, emission sampling methods, and
test fuels. This chapter describes the test procedures being proposed in this rulemaking.
9.1 Proposed Certification Test Procedures
We are proposing to use the Annex VI engine test procedures with some modification
exceptions. The Annex VI test procedures are set out in the NOx Technical Code. The
exceptions we are proposing are described in Subsection 9.1.4. The other subsections describe
issues such as the duty cycle, test fuel and sampling procedures. These procedures will be
required for certification testing. We will allow other procedures to be used for production
testing and in-use testing.
9.1.1 Duty Cycle
We are proposing to use the same duty cycles as are used for testing NOx emissions
under the Annex VI requirements. These test cycles are designated by the International
Standards Organization (ISO) as the E3, and E2 cycles.1 The E3 duty cycle is designated for
propulsion Marine diesel engines operating on a propeller curve. It represents heavy-duty diesel
Marine engine operation on vessels greater than 24 meters in length. Many larger propulsion
Marine engines do not operate on a propeller curve. These engines may run at a constant speed
and use a variable-pitch propeller to control vessel speed. The E2 constant-speed propulsion
Marine duty cycle applies to these engines. Tables 9.1-1 presents duty cycles for main drive
engines as discussed above.
9-1
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Draft Regulatory Support Document
Table 9.1-1
Test Cycle Types E2 and E3
Test Cycle Type E2
Speed
Power
Weighting
Factor
100%
100%
0.2
100%
75%
0.5
100%
50%
0.15
100%
25%
0.15
Test Cycle Type E3
Speed
Power
Weighting
Factor
100%
100%
0.2
91%
75%
0.5
80%
50%
0.15
63%
25%
0.15
E2: for constant-speed main propulsion application (including diesel-electric drive or variable-
pitch propeller installation)
E3: for propeller-law-operated main and propeller-law-operated auxiliary engine application
9.1.2 Test Fuel
Category 3 engines are typically designed to burn residual fuel, which is a heavy by-
product of the refining processes used to produce lighter petroleum products such as gasoline,
diesel fuel and kerosene. Therefore, we are proposing to specify residual fuels for certification
testing. This subsection provides additional information regarding residual fuels.
Residual fuel is a dense and viscous fuel that is a byproduct of distillate fuel productions.
It typically has higher ash, sulfur and nitrogen content than Marine distillate fuels. Some
Category 3 engines can burn straight residual fuel, but many burn a blend of residual and
distillate, which is called intermediate fuel (IF). The two most common IF blends burned in
Category 3 engines are IF 180, which contains about 88 percent residual fuel and IF 380 which
contains about 98 percent residual fuel.2 Table 9.1-2 summarizes current ASTM standards for a
Marine distillate oil, residual fuel, and the two most common IF blends.
9-2
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Chapter 9: Test Procedure
Table 9.1-2
Comparison of ASTM Fuel Specifications3
ISO-F symbol
Density @ 15C, max
Viscosity @ 40C
Viscosity @ 50C
Viscosity® 100C
Carbon Residue, max
Ash, max
Sulfur, max
Units
kg/m3
cSt
cSt
cSt
wt%
wt%
wt%
Distillate fuel
DMA
890
1.5-6.0
—
—
0.20*
0.01
1.5
IF 180
RMF-25
991
316
180
25
20**
0.15
5.0
IF 380
RMH-35
991
-710
380
35
22**
0.20
5.0
Residual fuel
RML-55
no max
—
—
55
no max
0.20
5.0
* Ramsbottom test
** Conradson test
The use of residual fuel has two important consequences. First, it is more difficult to
handle. Because of it's high viscosity and high impurities, the fuel must be heated and filtered
before it can be passed to the engine. This requires additional equipment and space. Bunker
fuel is kept in a main fuel tank where it is kept heated, generally using steam coils, to just above
its pour point. Prior to use, this fuel is pumped into a settling tank, where the heavier portions
settle to the bottom. Fuel is pumped from the top of the settling tank through heaters, centrifugal
separators, and filters before entering the fuel metering/injection pump(s). The centrifugal
separators and filters remove water and remaining sludge from the fuel. The sludge is then
routed to a sludge tank. In addition, a separate fuel tank is usually necessary to store a lighter
fuel which is used to start a cold engine.
Second, residual fuels can have detrimental effects on engine emissions. These fuels can
contain one percent or more nitrogen by weight, and fuel-bound nitrogen is almost completely
converted to NOx in diesel engines.4 Assuming complete conversion to NO2, one gram of
nitrogen in the fuel would result in 3.28 grams of NOx, based on the ratio of molecular weight of
NO2 (46.005) to the atomic weight of nitrogen(14.007). It is appropriate to assume to conversion
to NO2, since our proposed test procedures convert NO emissions to NO2 before measurement
and calculates the total NOx emissions assuming the molecular weight of NO2. It is possible that
some of the fuel nitrogen would be converted to other nitrogen compounds such as NH3
(ammonia) or N2O (nitrous oxide), or remain bound to organic molecules in the HC or PM
emissions. However, since about 99 percent of the fuel mass consumed by a Category 3 engine
is typically converted to CO or CO2, it is unlikely that a large amount of the fuel nitrogen remains
organically bound. Also, given the high air/fuel ratios, it seems unlikely that a significant
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amount of NH3 or N2O would be produced. Therefore, we are estimating that 99 percent of the
fuel nitrogen is converted into NOx during the combustion process. This means that one gram of
nitrogen in the fuel would result in 3.25 grams of NOx.
Residual fuel quality can effect emission in ways other than the effect of fuel nitrogen.
Bastenhof analyzed emission results for ISO E3 test results of a Category 3 engine that showed a
22 percent increase in ISO weighted NOx when residual fuel was substituted for distillate fuel.5
However, most of the difference could not be attributed to the effect of the fuel-bound nitrogen
(0.4 percent). A large fraction of the NOx increase was attributed to the fuel's poor ignition
quality, which caused excessive ignition delay at part load. At 25 percent load on residual fuel,
the engine produced 50 percent more NOx than on distillate, while at full load it produced only
25 percent more than on distillate. Since we are not aware of any accurate corrections for fuel
effects other than the effect of fuel nitrogen, we are not proposing to correct them. To a large
extent, we believe that manufacturers and ship operators will account for these other effects in
determining how to best adjust the engine. To the extent that they do not, we consider these
effects to be a part of the normal variability between tests. It is also important to note that our
proposed adjustment to the EVIO emission standard to correct for fuel nitrogen (1.4 g/kW-hr) is
comparable to the entire EVIO allowance for the difference between tests conducted using
distillate and tests conducted using residual fuel (10 percent).
9.1.3 Sampling Procedures and Calculations
The Annex VI test procedures use a conventional raw sampling system, in which a small
sample of the exhaust gases is drawn from the exhaust stack, and pumped through chemical
analyzers. NOx concentrations in the sample are measured using a chemiluminescence (CL)
analyzer. CO2 concentrations are measured using a Non-Dispersive Infrared (NDIR) analyzer.
These analyzers are the same as the analyzers specified by EPA for other nonroad standards.
The Annex VI provisions specify that NOx emissions be corrected to be equivalent to
measurements made at a reference humidity of 10.71 g of water per kg of dry air (g/kg). They
also specify that NOx emissions be corrected for the effect of seawater temperature on charge air
cooling.
9.1.4 Modifications to the Annex VI Test Procedures
We are proposing several modifications and additions to the Annex VI test procedures to
better ensure that the emission measurements will accurately represent in-use performance. We
would require that inlet air and exhaust restrictions be set at the average in-use levels. Similarly,
engine coolant and engine oil temperatures would need to be equivalent to the temperatures that
would occur in-use under ambient conditions identical to the test conditions. We are also
proposing that measurements would only be valid for sampling periods in which the temperature
of the charge air entering the engine is within 3°C of the temperature that would occur in-use
under ambient conditions (temperature, pressure, and humidity) identical to the test conditions.
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Manufacturers would be allowed to measure emissions within larger discrepancies, but would
not be allowed to use those measurements to demonstrate compliance with these regulations.
Annex VI allows g/kW-hr emission rates to be calculated using measured exhaust flow
rates. However, we do not believe that exhaust can be reliably measured for Category 3 engines.
Measuring exhaust flow rates in general is difficult due to the high temperatures and the
variability of exhaust temperatures. We believe that it would be even more difficult for very
large engines. Exhaust stacks for Category 3 engines can be over a meter in diameter, which
allows for significant spatial variation in the flow rate. Therefore, we are proposing that exhaust
flow rates be calculated using measured fuel flow rates.
We are proposing to allow tests to be performed at any representative pressure and
humidity levels, and at any ambient air temperature from 13°C to 30°C. The Annex VI
requirements specify a narrower range of conditions. We believe that the broader range of
conditions is necessary to ensure that the emission controls would be broadly effective. We are
also proposing to allow testing with charge air cooling water temperatures from 17°C to 27°C.
The duty cycle used for Annex VI testing specifies the test points based on the
manufacturer's specified rated speed. We have concerns about the subjective nature of the Annex
VI requirement and believe that the test cycle needs to be defined more objectively. Therefore,
we are proposing that the test cycles be denormalized based on the maximum test speed
described in §94.107. This maximum test speed is not intended to fundamentally change the test
procedure, but is merely being proposed to make the procedure less subjective.
9.2 Shipboard NOx Emission Measurement System
We propose that Category 3 diesel engines have a direct exhaust NOx monitoring system.
This system would be used to verify that engines are adjusted properly in use. It could also be
used for production testing. Category 3 engines typically have fuel injection timing and other
adjustments that are optimized to accommodate a range of fuel qualities and environmental
conditions. These engine adjustments also affect NOx emissions; therefore a shipboard means of
monitoring NOx is a prudent requirement to ensure compliance with the applicable standards.
Indirect methods for inferring NOx emissions based on engine operating temperatures, pressures
or flows will not ensure compliance with applicable standards due to the complex relationship
between these parameters and NOx emissions.
We are not proposing to require a specific type onboard NOx measurement system.
Rather, we are proposing general specifications for the systems. We envision that the NOx
monitoring system would perform the following functions. It would detect exhaust NOx
concentration in parts per million (ppm) and integrate this measurement with other shipboard
measurements so that the measured concentration may be compared to emission limits for an
engine's operating conditions.
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In addition, the system would display the NOx concentration and the respective specified
emissions limit at the engine control room. Such a provision is important as it would give the
Marine engineer immediate and specific feedback regarding any recent adjustments to the engine
or any recent changes in fuel quality or environmental conditions. Displaying actual values of
emissions rather than merely activating an alarm would serve to familiarize the Marine engineer
with the magnitude of the change in NOx emissions versus various changes in engine operation,
fuel quality, or environmental conditions. As the Marine engineer incorporates NOx monitoring
with the rest of the ship's engine monitoring, it is likely that NOx emissions may be incorporated
to troubleshoot or optimize the engine's operation. NOx is sensitive to combustion temperature
which is a function of engine load, fuel injection timing, fuel ignition delay, combustion air inlet
temperature, and a few other engine parameters to a lesser extent. Unusually high or low NOx
emissions might indicate to the Marine engineer that these parameters should be carefully
inspected to ensure proper engine operation.
The system would also provide automated calibration and error handling, including
audible and visual alarms to ensure proper operation with a minimum of maintenance. In order
for a system such as this to be well-received and properly used aboard ship, the system must not
significantly increase the day-to-day work load of the Marine engineer. It is expected that
periodic repair and maintenance would be required to keep the system in proper working order,
however, tedious calibration or frequent maintenance of the system would ensure that it is not
used properly.
The system would also permanently record the NOx concentration and any other
measured or calculated parameters, including the respective limit for the engine operating
conditions, the calibration results, plus any system alarms or malfunctions. This record would be
used to determine whether or not the engine is being operated consistent with its intended
operation (i.e. operation during engine certification.) This record would also be useful in
determining how well the NOx monitoring system is maintained.
9.2.1 System Description and Component Specifications
The proposed NOx monitoring system would consist of several components, and the
system is illustrated in the figure below.
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Stack
N
Engine Room
•4
Analyzer Exhaust
•«-
..Cable....,
NOX Analyzer
Sample Conditioning
System (as required)
Engine
Control Room
Display/
/Controller /
Data
Recorder
9.2.1.1 Location of Sample Extraction Point
A sensor or sampling probe would be located at a position in the exhaust stream where
the exhaust from all engine cylinders are well-mixed. It is important that the exhaust be
well-mixed because on Category 3 engines typically each fuel injection pump and after-cooler on
the engine may be adjusted individually. This means that some cylinders of the engine might be
producing more NOx than others. A well-mixed sample would not only help ensure compliance
to the applicable standard, but it would also prevent false positive indications that the engine is
emitting excessive NOx emissions. A multi-point transverse sampling probe would need to be
used only if the exhaust system does not provide for a single point location where the exhaust is
well-mixed. Sound engineering judgment must be used to determine this position in the exhaust
system, however, it is recommended that the Reynolds number of the exhaust flow at the
sampling position remain greater than 4000 and that the sensor or sampling position be in the
free stream flow at least five exhaust trunk diameters downstream of any trunk junctions or 90°
bends.
The sampling position should be selected to prevent periodic exhaust system cleaning
from adversely affecting the sensor or probe. Category 3 engines often have exhaust heat
recovery devices such as economizer boilers. These components require periodic steam cleaning
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(soot-blowing). The action of the soot blowers might damage a NOx sensor or sample probe
placed in the exhaust stream, therefore the sample location should be upstream of these devices.
This location must also be upstream of any other exhaust stream that might be introduced
into the exhaust system. Other engines or boilers might exhaust to the same system, and their
exhaust would most certainly cause the recording of erroneous data.
9.2.1.2 Sample conditioning system
A sample conditioning system may be used if the NOx detection method requires it. The
sample conditioning system may consist of filters, scrubbers, or chillers. However, no
component of the sampling system should affect the NOx concentration of the sample. For
example, if a sample conditioning system utilized unheated lines or a chiller that brings the
sample below its dewpoint, an NO2 to NO converter would have to be used upstream to prevent
the precipitation of NO2 as nitric acid.
9.2.1.3 NOx Analyzer
To quantify total NOx (NO + NO2) a NOx analyzer would be used to quantify the exhaust
NOx concentration in parts per million by volume (ppm). The performance specifications of the
NOx analyzer would be as follows: the detection range of the analyzer would be at least
100-5000 ppm with a NIST traceable accuracy of ±2% at each calibration point (i.e. ±10 ppm at
500 ppm concentration of an NIST traceable calibration gas), a precision of ±5% based on two
standard deviations (2a) and a 90% response time of less than 5 seconds to an 80% of full-scale
step change in NOx. These specifications ensure that the analyzer would be able to detect a
significant change in NOx emissions without over-specifying an analyzer that might require more
frequent maintenance or a more complicated calibration procedure.
In addition the analyzer must have an automated calibration subsystem that would
perform quality control and quality assurance checks to ensure that NOx is measured at the stated
specification. This level of automation is required to prevent an undue increase in the Marine
engineer's day-to-day workload. Automated calibration subsystems are commercially available
for gas detection systems and are already used aboard tankships that require gas detection
systems for safety purposes.
Any analyzer must be designed to perform under typical shipboard temperature, humidity,
shock, vibration, electromagnetic and radio frequency interference. It is also important that the
analyzer not have any cross-sensitivity to other exhaust constituents. Several different NOx
detectors have been used successfully to detect NOx of roadway diesel engine exhaust.
However, Category 3 engines frequently use residual fuel that contains high concentrations of
components not found in distillate diesel fuel. These components include sulfur at 100 times
distillate diesel concentrations plus metallic ash from crude oil and catalytic refining processes.
Such components might cause fouling or corrosion of wetted parts of the NOx monitoring
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system. Analyzer manufacturers would have to use care when selecting certain materials and
detectors for use in this application.
It is anticipated that analyzers based on chemiluminescent, non-dispersive ultra-violet,
zirconia cell, or fourier transform infra-red measurement techniques may be appropriate for
shipboard use, however any instrument manufacturer would have to ensure that an analyzer
meets the specifications outlined in this section. Except for the zirconia cells that can be inserted
directly into the free stream exhaust, all of these analyzers would require a sample of the exhaust
to be extracted. This means that these analyzers would have to include their own pumping
subsystem. In addition the analyzer exhaust would have to be routed back to the engine's
exhaust.
There is already an indication that one of the most cost-effective of these detectors, the
zirconia cell, shows promise in the harsh residual fuel exhaust. A report submitted to the
International Maritime Organization indicated that a zirconia cell sensor was used aboard three
different Category 3 engine-equipped vessels using seven different residual fuels, and after six
months of use the zirconia sensor continued to perform acceptably.7 Some of the advantages of
the zirconia sensor include its cost, currently in the several hundred U.S. dollar range for the
sensor, and under $4,000 for the entire analyzer. It is anticipated that a complete NOx
monitoring system might cost approximately $15,000 with annual operating costs (including
labor) of approximately $5,000. Cost of the complete system is minimal because the zirconia
cell does not require a sample conditioning system or pump. However, a pump and a sample
conditioning system might be used to prolong a zirconia cell's life.
9.2.1.4 Programmable Controller
It is anticipated that a programmable electronic controller would execute all of the system
functions such as sampling, calibrating, purging, and error handling. The controller would
integrate other shipboard measurements and make all necessary calculations. The controller
would also allow for manual operation of the system. Such a controller may vary in
sophistication depending upon the needs of the ship and the availability of other centralized
automation systems, which might be able to perform the NOx monitoring functions.
9.2.1.5 Engine Control Room Display
An engine control room display would provide the Marine engineer with a continuous
display of measured NOx concentration and the respective NOx limit for the engine operating
condition, plus any other relevant measurements or calculated values. The display would also
indicate any alarms or faults so that repair or maintenance could be promptly performed. The
display would also provide for remote control of the system.
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9.2.1.6 Data Recorder
A data recorder would permanently document on either magnetic or paper media all of
the NOx monitoring system's measured and calculated parameters, calibration results, and
system errors. All data would be recorded along with date and time stamps, and this record
would be used to determine compliance with applicable NOx emission requirements. It would
also be used by the marine engineer to determine day-to-day changes in NOx emissions or even
NOx trends over the life of the engine. This data would be permanently archived consistent with
shipboard practices for retaining records such as the course recorder logs or other similar
permanent records.
9.2.2 Emission Targets
We expect that the typical onboard measurement system would report the concentration
of NOx in the exhaust (ppm) along with other test conditions (e.g., engine speed, shaft torque,
fuel properties, ambient temperature and humidity, etc.). We do not expect that these results
would be directly comparable to the weighted g/kW-hr emission standards. Thus we would
require the engine manufacturer to develop NOx-ppm emission targets for any given set of
conditions.
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Chapter 9 References
1. International Standards Organization, 8178-4, "Reciprocating internal combustion
engines—Exhaust emission measurement—Part 4: Test cycles for different engine applications."
2. The Bunker News Daily, "Flashpoint," MRC Publications, July 17, 1997, Vol. 1 No. 137,
www.bunkernews.com.
3. International Standards Organization 8217, 1987.
4. Heywood, J., Internal Combustion Engines. McGraw-Hill, New York, p. 577, 1988.
5. Bastenhof, D., "Exhaust Gas Emission Measurements; A Contribution to a Realistic
Approach," CIMAC, May 1995.
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