United States        Air and Radiation       EPA420-R-03-004
          Environmental Protection                January 2003
          Agency
&EPA    Final Regulatory Support
          Document: Control of
          Emissions from New Marine
          Compression-Ignition
          Engines at or Above
          30 Liters per Cylinder
                                 > Printed on Recycled Paper

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                                            EPA420-R-03-004
                                               January 2003
  Final Regulatory Support Document: Control of
Emissions from New Marine Compression-Ignition
    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 Executive Summary  	1-1
       1.1.1 Standards Adopted  	1-1
       1.1.2 Projected Impacts and Costs	1-3
       1.1.3 Future Rulemaking	1-3
   1.2 Organization of This Document	1-6
   1.3 Categories of Marine  Diesel Engines	1-6
   1.4 The International Maritime Organization and MARPOL 	1-7
       1.4.1 International Maritime Organization  	1-7
       1.4.2 MARPOL Annex VI  	1-7
       1.4.3 The MARPOL Annex VINOXLimits	1-8
       1.4.4 MARPOL SOx  Limits	1-9
       1.4.5 Continuing Action at the IMO  	1-9

CHAPTER 2: Health and Welfare Concerns  	2-1
   2.1 Inventory Contributions	2-1
       2.1.1 National Inventory - Category 3 Marine Diesel Engines	2-1
       2.1.2 Category 3 Inventories for Specific Ports	2-7
       2.1.3 Category 3 Emissions  in Nonport Areas	2-11
       2.1.4 Category 3 Contribution by flag	2-11
       2.1.5 Category 1 and Category 2 Inventory Estimates	2-12
   2.2 Ozone	2-13
       2.2.1 General Background  	2-13
       2.2.2 Health and Welfare Effects of Ozone and Its Precursors	2-14
       2.2.3 Ozone Nonattainment and Contribution to Ozone Nonattainment	2-17
       2.2.4 Additional Health and Welfare Effects of NOx Emissions	2-18
   2.3 Particulate Matter	2-19
       2.3.1 General Background	2-19
       2.3.2 Health and Welfare Effects of PM  	2-20
       2.3.3 PM Nonattainment  	2-22
       2.3.4 Diesel Exhaust  	2-23
   2.4 Carbon Monoxide   	2-24
       2.4.1 General Background	2-24
       2.4.2 Health Effects of CO	2-25
       2.4.3 CO Nonattainment  	2-25
   2.5 Visibility Degradation 	2-26
       2.5.1 General Background	2-26
       2.5.2 Visibility Impairment Where People Live, Work and Recreate 	2-27

CHAPTER 3: Industry Characterization	3-33
   3.1 Description of Category 3 Marine Engines 	3-33
   3.2 Category 3 Marine Engine Manufacturers	3-35
       3.2.1 Companies That Make Category 3 Marine Engines	3-35

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       3.2.2 Production of Category 3 Marine Engines  	3-36
       3.2.3 Relationship Among Worldwide Engine Manufacturers 	3-38
   3.3 Vessel Manufacturers	3-39
       3.3.1 United States Vessel Manufacturers	3-39
       3.3.2 International Vessel Manufacturers  	3-47
   3.4 U.S. Fleet Characterization  	3-47
       3.4.1 Background	3-47
       3.4.2 U.S. Fleet  	3-47
       3.4.3 Foreign Vessels that Enter U.S. Ports	3-48
       3.4.4 Cruise Vessels	3-48
   3.5 U.S. Port Activity	3-49
       3.5.1 Background	3-49
       3.5.2 Cruise Ship Activity	3-51
   3.6 Conclusion	3-52

CHAPTER 4: Tier 1 Standards  	4-1
   4.1 Marine Engine Technology	4-1
       4.1.1  Diesel Engine Emission Formation	4-1
       4.1.2 Category 3 Marine Engine Design and Use  	4-2
       4.1.3  Anticipated Technology to Meet Emission Standards	4-4
       4.1.4  Description of Technology	4-5
   4.2 Technology Costs	4-13
   4.3 Emission Reductions	4-13
   4.4 Impact on Noise, Energy, and Safety 	4-14
   4.5 Category 1 and 2 Marine Engines Greater Than 2.5 Liters/Cylinder	4-14

CHAPTER 5: Advanced Emission-Control Technologies  	5-1
   5.1 Water Introduction into the Combustion Process	5-1
       5.1.1  Description of the Technology	5-1
       5.1.2  Issues to Resolve  	5-3
   5.2 Selective Catalytic Reduction	5-3
       5.2.1  Description of the Technology	5-4
       5.2.2  Issues to Resolve  	5-5
   5.3 Fuel Cells  	5-7
   5.4 Other Engine Technologies	5-8
   5.5 Category 1 and Category 2 Marine Diesel Engines  	5-9
   5.6 PM Emission Control from Category 3 Marine Diesel Engines	5-9
   Appendix to Chapter 5:  Current DWI and SCR Installations	5-11

CHAPTER 6: Estimated Costs  for Advanced Technologies	6-1
   6.1 Methodology	6-1
   6.2 Technology Costs	6-2
       6.2.1  Fuel Injection Improvements	6-2
       6.2.2  Engine Modifications	6-3
       6.2.3  Direct Water Injection	6-5
       6.2.4  Selective Catalytic Reduction  	6-8

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       6.2.5 Fuel Costs	6-12
   6.3 Total Engine Costs  	6-15
       6.3.1 Distribution of Category 3 Marine Engines 	6-15
       6.3.2 Projected Composite Costs for Category 3 Engines  	6-15

CHAPTER 7: Inventory Baseline and Projections for Advanced Technology	7-1
   7.1 Baseline Inventories 	7-1
       7.1.1 Geographic Boundaries	7-1
       7.1.2 Ports Inventories	7-2
       7.1.3 Non-Port Inventories	7-4
   7.2 Future Year Baseline Inventory Projections	7-5
   7.3 Estimated Effects of Advanced Technology Standards on Inventories	7-7
   7.4 Per-Vessel Emission Reductions  	7-10
   7.5 Cost Per Ton	7-10

CHAPTER 8:  Test Procedure	8-1
   8.1 Certification Test Procedures  	8-1
       8.1.1 Duty Cycle	8-1
       8.1.2 TestFuel	8-2
       8.1.3 Sampling Procedures and Calculations  	8-4
       8.1.4 Modifications to the NOx Technical Code Test Procedures	8-4
   8.2 Shipboard NOx Emission Measurement System	8-5
       8.2.1 System Description and Component Specifications	8-6
       8.2.2 Emission Targets	8-10
                                          in

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IV

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List of Acronyms
 Hg/m3
 ASTM
 BSFC
 CIMAC
 CO
 COHb
 cSt
 DI
 DWT
 EF
 EGR
 EIAPP
 EPA
 g/kW-hr
 GmbH
 HC
 IAPP
 IMO
 kPa
 m/s
 MARAD

 MARPOL

 MEPC
 NAAQS
 NIST
 NO2
 NOx
 NPV
 NIC
 OAQPS
 OMB
 OPA90
 PM
micrograms per cubic meter
American Society for Testing and Materials
brake-specific fuel consumption
Conseil International Des Machines A Combustion (International
Council on Combustion Engines)
carbon monoxide
carboxyhemoglobin
centi stokes
direct injection
dead-weight tonnage
emission factor
exhaust gas recirculation
Engine International Air Pollution Prevention
U.S. Environmental Protection Agency
grams per kilowatt-hour
Gesellschaft mit beschrankter Haftung
hydrocarbon
International Air Pollution Prevention
International Maritime Organization
kilopascals
meters per second
Maritime Administration
the International Convention on the Prevention of Pollution from
Ships, 1973, as Modified by the Protocol of 1978 Relating Thereto
Marine Environment Protection Committee
National Ambient Air Quality Standards
National Institute of Standards and Technology
nitrogen dioxide
oxides of nitrogen
net present value
NOx Technical Code
Office of Air Quality Planning and Standards
Office of Management and Budget
Oil Pollution Act of 1990
particulate matter

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ppm                  parts per million
ppmS                 parts per million sulfur
R&D                 research and development
RPE                  retail-price equivalent
RSZ                  Reduced-speed zones
SAE                  Society of Automotive Engineers
SCR                  selective catalytic reduction
SECA                SOx Emission Control Area
SIC                   Standard Industrial Classification
SIP                   State Implementation Plan
SO2                   sulfur dioxide
SOx                  oxides of sulfur
VOC                 volatile organic compound
wt%                  weight percent
                                         VI

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                                                              Chapter 1: Introduction
                        CHAPTER 1: Introduction

   At the Environmental Protection Agency (EPA), we are adopting national emission standards
for the first time for new marine diesel engines with per-cylinder displacement of 30 liters or
more that are installed on vessels flagged or registered in the United States.3 These engines, also
known as Category 3 marine diesel engines, are very large engines used primarily for propulsion
power on ocean-going marine vessels such as container ships, tankers, bulk carriers, and cruise
ships. Category 3 marine diesel engines have not previously been regulated under our nonroad
engine programs.  This Final Regulatory Support Document provides technical, economic, and
environmental analyses for this emission-control program.

   We are  also adopting standards for new marine diesel engines with per-cylinder displacement
of 2.5 to  30 liters installed on vessels flagged or registered in the United States. These engines,
also known as Category 1 and Category 2 marine diesel engines, are already subject to more
stringent Tier 2 standards beginning in 2007, pursuant to a rule we finalized in 1999 (64 FR
73300, December 29, 1999; 40  CFR part 94). The standards we are finalizing, which are
currently voluntary for these engines, will be mandatory for new engines manufactured from
2004 through 2006. Our technical, economic, and environmental analysis for the standards for
these engines can be found in the Final Regulatory Impact Analysis for our  1999 rule and is not
repeated  in  this document.1

1.1  Executive Summary

1.1.1 Standards Adopted

   The near-term Tier 1  standards we are adopting are equivalent to the internationally
negotiated NOx standards established 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 (more commonly referred to as MARPOL or
MARPOL 73/78; the standards  are referred to as the Annex VI NOx standards).2  The standards
are set out in Table 1.1-1. These standards are achievable almost immediately, with less than one
year of lead time, because manufacturers are already achieving and certifying to these standards
under our Voluntary Statement  of Compliance program for Annex VI.  These near-term
standards are being achieved through the application of currently available technology, including
optimized turbocharging, higher compression ratios, and optimized fuel injection.
       "Today's rule applies to "new" marine diesel engines and to "new" marine vessels that
include marine diesel engines. In general, a "new" marine diesel engine or a "new" marine
vessel is one that is produced for sale in the United States or that is imported into the United
States.  The emission standards established in today's rule, therefore, will typically apply to
marine diesel engines that are installed on vessels flagged or registered in the United States.

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Final Regulatory Support Document
   The near-term standards in this final rule will be enforceable under U.S. law for new engines
built on or after January 1, 2004. These standards will apply until we adopt a second tier of
standards in a future rulemaking. In developing that future rulemaking, which will be completed
no later than April 27, 2007, we will consider both the state of technology that may permit deeper
emission reductions and the status of international action for more stringent standards.  We will
also consider whether to apply such a second tier of standards to engines on foreign vessels that
enter U.S. ports.

                                       Table 1.1-1
       	NOx Emission Standards (g/kW-hr)	
                                     Engine Speed (n)
              n > 2000 rpm	|     2000 > n > 130 rpm     |	n<130rpm
                                        45.0xn-°-2
17.0
   We are not adopting emission standards for paniculate matter (PM) from Category 3 engines
in this final rule. The majority of PM emissions from large marine diesel engines comes directly
from the high concentration of sulfur in the residual fuel they use,  so the simplest way to reduce
these  emissions is by removing sulfur from the fuel.  Annex VI provides a mechanism to control
the sulfur content of fuels used by vessels that operate in specially designated SOx Emission
Control Areas (SECAs). After the Annex goes into force, ships operating in these  designated
areas  must use marine fuel with a sulfur content below 15,000 ppm or aftertreatment technology
to achieve equivalent emission reductions (for comparison, sulfur levels in marine  residual fuels
may be as high as 45,000 ppm). We intend to investigate this special designation for one or more
areas  in the United States.  We will also reconsider this issue in our future rulemaking.

   To implement these standards in an effective way, we are adopting a certification and
compliance program for Category 3 marine diesel engines that is similar but not identical to the
internationally negotiated program contained in the Technical Code on the Control of Emissions
of Nitrogen Oxides from Marine  Diesel Engines (also known as the NOx Technical Code).3  The
differences between the two programs are intended to ensure that test data be representative of
actual in-use conditions and that manufacturers demonstrate that the emission controls will be
durable for the full useful life of the engine. We specify that this useful life  for Category 3
engines is three years, based on the time that engines operate before being rebuilt for the first
time.  To allow manufacturers time to incorporate these changes in their testing and certification
procedures, we are adopting a provision that will allow manufacturers to certify their engines
with EPA by using the international procedures on an interim basis, after which they must use the
procedures in this final rule.

   For Category 1  and Category  2 engines, we specify certification and testing requirements
based on the requirements we adopted for these engines when we set the Tier 2 standards in
1999.  Similar to the provisions for Category 3 engines, we allow manufacturers to certify their
engines using the international procedures until the Tier 2  standards apply.

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                                                               Chapter 1: Introduction
   We are also adopting voluntary low-emission standards, consistent with the approach we
have taken in several other programs, to encourage the introduction and more widespread use of
low-emission technologies. To be designated as a Blue Sky engine, an engine must have
emissions at least 80 percent below Annex VI NOx levels (excluding a nitrogen adjustment).
The specific voluntary low-emission NOx standard is expressed as 9.0>
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Final Regulatory Support Document
reassess the standards in place at the time using information about the feasibility of optimizing
in-cylinder controls and applying advanced NOx and PM control technologies described in
Chapter 5 to Category 3 marine diesel engines.  These advanced technologies would also lead us
to consider the need for several additional provisions, such as an enhanced compliance program
and new standards to address HC, CO, and particulate-matter emissions.  We intend to consider
the application of these standards to engines on foreign vessels that enter U.S. ports. We will
also include in our evaluation an assessment of the status of international action to set more
stringent standards.  The standards in this final rule will remain in effect unless modified by a
future rulemaking. We are committing to take final action on appropriate standards for marine
diesel engines by April 27, 2007, and to issue a proposal no later than approximately one year
before.  EPA considers this time as necessary and appropriate to properly take into consideration
additional information expected to become available about emerging technologies, as well as any
developments in the international negotiations for more stringent emission limits.

   Chapter 5 of this Final Regulatory Support Document contains a description of some of the
advanced technologies we will consider in our future rulemaking. Table  1.1-3 provides a
summary of our current understanding of the potential per-engine costs for several emission
control scenarios, as detailed in Chapter 6.  Table 1.1-4 summarizes the projected emission
inventories under various scenarios of adopting more stringent standards based on advanced
technologies.

   We intend to use the future rulemaking as an opportunity also to reconsider Tier 3 emission
standards for Category 1 and Category 2 standards. We proposed Tier 3 standards for these
engines on  December 11, 1998 (63 FR 68508), but chose not to finalize the Tier 3 standards in
that rulemaking.  Given the current and expected advances in emission-control technologies for
land-based  diesel  engines and the need to coordinate standards for all categories of marine
engines, we believe this may be the appropriate context and timing to reopen the proposed Tier 3
standards.
                                           1-4

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                                                                 Table 1.1-3
                                    Summary of Projected Costs per Engine for Advanced Technology"
Technology
Package
Direct
Water
Injection
SCR
Scope of
Standards
U.S. vessels
only
U.S. and
foreign
vessels
U.S. vessels
only
U.S.- and
foreign
vessels
Cost Parameter
Total cost per engine
(yr. 1)
Total cost per engine
(yr. 6 and later)
Operating costs (NPV)
Total cost per engine
(yr. 1)
Total cost per engine
(yr. 6 and later)
Operating costs (NPV)
Total cost per engine
(yr. 1)
Total cost per engine
(yr. 6 and later)
Operating costs (NPV)
Total cost per engine
(yr. 1)
Total cost per engine
(yr. 6 and later)
Operating costs (NPV)
Medium-speed Engines
6cyl.
$119,105
$26,486
$55,912
$49,157
$26,486
$9,749
$241,160
$124,155
$435,240
$198,709
$124,155
$90,500
9cyl.
$139,153
$39,317
$84,029
$69,205
$39,317
$14,651
$335,899
$184,788
$642,579
$293,448
$184,788
$126,651
12 cyl.
$159,201
$52,148
$111,824
$89,253
$52,148
$19,497
$433,863
$247,485
$852,782
$391,412
$247,485
$163,302
Slow-speed Engines
4 cyl.
$156,579
$50,470
$111,824
$86,631
$50,470
$19,497
$435,153
$248,310
$861,574
$392,702
$248,310
$172,094
8 cyl.
$239,391
$103,469
$223,971
$169,443
$103,469
$39,051
$821,847
$495,795
$1,668,952
$779,396
$495,795
$312,868
12 cyl.
$319,582
$154,792
$335,794
$249,634
$154,792
$58,549
$1,208,542
$743,279
$2,504,036
$1,166,091
$743,279
$458,472
Composite
$188,617
$70,974
$153,887
$118,669
$70,974
$26,832
$579,647
$340,787
$1,161,373
$537,196
$340,787
$221,463
aThese estimated costs reflect our understanding of the current state of technology development for these emission-control strategies.  We will revisit these estimates
before proposing emission standards based on these technologies.

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Final Regulatory Support Document
                                       Table 1.1-4
                           Estimated 2030 Emission Inventories
                under Scenarios of Applying Long-Term Emission Standards
Scenario
Baseline (Annex VI)
50% Reduction — U.S. vessels only
50% Reduction — All vessels
80% Reduction — U.S. vessels only
80% Reduction — All vessels
NOx (1000 tons)
531
519
301
511
160
percent reduction
--
2.3%
43%
3.7%
70%
1.2 Organization of This Document

   The remainder of this Chapter 1 contains the definitions of the categories of marine diesel
engines and a brief description of the International Maritime Organization and MARPOL Annex
VI.

   As noted above, the analysis in this Final Regulatory Support Document focuses on Category
3 marine diesel engines.  Chapter 2 reviews information related to the health and welfare effects
of the pollutants of concern and presents the estimated contribution of Category 3 marine diesel
engines to the nationwide inventory of these pollutants. Chapter 3 contains an overview of
Category 3 marine diesel 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 manufacturers are applying to meet the
internationally negotiated standards and the expected environmental benefits from those
standards. Chapter 5 presents the available information about advanced technologies that could
be used to achieve greater emission reductions from these engines.  These technologies hold out
the potential for emission improvements in the future, after constraints on their application to
marine engines are resolved.  Chapter 6 provides estimated costs of applying these technologies
to Category 3 marine diesel engines and Chapter 7 provides estimated inventory impacts of
applying them. These costs and benefits are tentative, and will be revisited in our future
rulemaking. Finally, Chapter 8 discusses issues related to new test procedures for these engines.

1.3  Categories of Marine Diesel Engines

   In our 1999 final rule for commercial marine diesel engines, we defined a marine engine as
one 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 the 1999 rule, this approach is
necessary because marine diesel engines are typically derivatives of land-based diesel engines
that are subject to different emission standards, testing procedures, and effective dates. The
                                          1-6

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                                                              Chapter 1: Introduction
definitions for the different categories of marine diesel engines are contained in 40 CFR 94.2 and
are summarized in Table 1.3-1.

                                      Table 1.3-1
                           Marine Engine Category Definitions
Category
1
2
3
Displacement per cylinder
disp. < 5 liters
(and power > 37 kW)
5 < disp. < 30 liters
disp > 30 liters
power range (kW)
37-2,300
1,500-8,000
2,500 - 80,000
rpm range
1,800-3,000
750 - 1,500
60 - 900
1.4 The International Maritime Organization and MARPOL

1.4.1 International Maritime Organization

   The International Maritime Organization (IMO) is an international organization created by
the United Nations in 1948.  According to the convention that established it, the IMO's purpose
is "to provide machinery for cooperation among Governments in the field of governmental
regulation and practices relating to technical matters of all kinds affecting shipping engaged in
international trade; to encourage and facilitate the general adoption of the highest practicable
standards in matters concerning maritime safety, efficiency of navigation and prevention and
control of marine pollution from ships." The Organization also provides administrative and legal
support for the committees of Member States that develop the international marine programs.4

   One of the important conventions adopted by the Member States of the IMO is the
International Convention on the Prevention of Pollution from Ships, 1973, as Modified by the
Protocol of 1978 Relating Thereto (more commonly referred to as MARPOL or MARPOL
73/78).5 This Treaty addresses several types of pollution associated with ships.  The
requirements for each of these are contained in Annexes to the Treaty. They are:

       •   Annex I - discharge of oil
       •   Annex II - noxious liquid substances
       •   Annex in - packaged goods
       •   Annex IV - sewage (the U.S. has not ratified this Annex)
       •   Annex V - garbage
       •   Annex VI - air emissions

1.4.2 MARPOL Annex VI

   In response to growing international concern about air pollution and  in recognition of the
highly international nature of maritime transportation, the International Maritime Organization
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Final Regulatory Support Document
initiated development of international standards forNOX, SOx, and a variety of other air
emissions arising from marine vessel operations.  As a result of these discussions Annex VI was
drafted between 1992 and 1997 and was adopted by the Parties to MARPOL at a Diplomatic
Conference on September 26, 1997. Annex VI covers several kinds of air pollutants from ships,
including NOX, SOx, volatile organic compound (VOC) emissions from tanker-loading
operations, ozone-depleting chemicals (i.e., halons), and emissions from shipboard incinerators.
As part of that conference, the Parties also passed a resolution adopting the Technical Code on
the Control of Emissions of Nitrogen Oxides from Marine Diesel Engines (also known as the
NOX Technical Code).  Through Annex VI and the NOX Technical Code, the EVIO created a
legal framework to control emissions from marine diesel engines and a procedure to test engines
and demonstrate compliance with the engine standards.

   The Annex VI requirements are not enforceable until the Annex enters into force. As
specified in Article 6 of the  Annex, it will enter into force twelve months after the date on which
not less than fifteen member states, the  combined merchant fleets of which constitute not less
than 50 percent of the gross  tonnage of the world's merchant shipping, have ratified the
agreement. To date, more than four years after it was adopted, the Annex has been ratified by
only 6 countries representing about 26 percent of the world's merchant shipping. The countries
that have ratified Annex VI  are Sweden, Norway, Bahamas, Singapore,  Marshall Islands, and
Liberia.6

1.4.3 The MARPOL Annex VI NOX Limits

   The MARPOL Annex VI NOX limits are set out in Table 1.1-1, above. These standards
cover only NOX emissions;  there are currently no international restrictions on particulate matter
(PM), HC, or CO emissions. The standards are based on engine speed and apply to engines
above 130 kW.  These standards were expected to reduce NOX emissions by 30 percent when
fully phased in. More recent analysis by EPA, based on newly estimated emission factors for
these engines, indicates an expected reduction on the order of about 20 percent by 2030 when the
standards are fully phased-in, when compared with uncontrolled emissions.

   The Annex VI NOX limits apply to each diesel engine with a power output of more than 130
kW installed on a ship constructed on or after January 1, 2000, or that undergoes a major
conversion on or after January 1, 2000.  The Annex does not distinguish between marine diesel
engines installed on recreational  or commercial vessels and applies to engines on vessels engaged
only in domestic service as well as to engines on vessels engaged in international voyages.  All
marine diesel engines above 130 kW would be  subject to the standards regardless of their use.
The test procedures for demonstrating compliance are set out in the NOX Technical Code7.  They
are based on ISO 8178 and are performed using distillate fuel.  Engines  can be pre-certified or
certified after they are installed onboard. After demonstrating compliance, pre-certified engines
would receive an Engine International Air Pollution Prevention (EIAPP) certificate. This
document, to be issued by the Administration of the flag country, is needed by the ship owner as
part of the process of demonstrating compliance with all the provisions  of Annex VI and
obtaining an International Air Pollution Prevention (LAPP) certificate for the vessel once the

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                                                              Chapter 1: Introduction
Annex goes into force.  The Annex also contains engine compliance provisions based on a
survey approach according to which engines must be periodically inspected. These survey
requirements would apply after the Annex goes into force. An engine is surveyed right after it is
installed, every five years after installation, and at least once between 5-year surveys. Engines
are not required to be tested as part of a survey, however. The surveys can be done by a
parameter check, which can be as simple as reviewing the Record Book of Engine Parameters
that must be maintained for each engine and verifying that current engine settings are within
allowable limits.

   The Annex requires that engines installed on a ship constructed on or after January 1, 2000
must comply with the specifications set forth in Regulation 13 of the Annex and the NOX
Technical Code. In addition,  a ship owner must bring an existing engine into compliance if the
engine undergoes a major conversion on or after that date.8  Although the Annex has not yet
entered into force and is not yet legally binding, it is widely recognized that the vast majority of
marine diesel engines manufactured and installed after January 1, 2000 meet the requirements of
the Annex. To facilitate implementation while the Annex is not yet in force and to allow engine
manufacturers to certify their engines before the Annex goes into force, we have  set up a process
for manufacturers to obtain a  Statement of Voluntary Compliance.9 After Annex VI goes into
effect for the United States, we will develop a process by which an EPA-issued Statement of
Voluntary Compliance can be exchanged for an EIAPP. It should be noted that an engine
certificate (EIAPP) or Statement of Voluntary Compliance for an engine installed on a U.S.
vessel must be issued by the U.S. EPA. Marine classification or survey societies are not
authorized to issue  such certificates on behalf of the U.S. government for U.S. vessels.

1.4.4  MARPOL SOx Limits

   MARPOL Annex VI contains requirements for fuels used onboard marine vessels. These
requirements, which will take effect when the Annex goes into force, consist of two parts. First,
Annex VI specifies that the sulfur content of fuel used onboard ships may not exceed 45,000  ppm
(4.5 percent).  Information  gathered in an  international monitoring program indicates refiners are
currently complying with this requirement and that the current sulfur level of marine bunker fuels
ranges between 5,000 and 45,000 ppm, with an average sulfur content of about 27,000 ppm.
Second, the Annex provides a mechanism to designate SOx Emission Control Areas, within
which ships must either use fuel with a sulfur content not to exceed 15,000 ppm or an exhaust
gas cleaning system to reduce SOx emissions. To date, two SOx Emission Control Areas have
been designated: the North East Atlantic (North Sea, Irish Sea and English Channel) and the
Baltic Sea.

1.4.5 Continuing Action at the IMO

   At the time the Annex VI NOX limits were adopted, in September 1997, several Member
States expressed concern that the NOX limits were not stringent enough and would not result in
the emission reductions they were intended to achieve. Due to the efforts of these Member
States, the Conference of the Parties adopted a resolution that provides for review of the emission

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limits with the aim of adopting more stringent limits taking into account the adverse effects of
such emissions on the environment and any technological developments in marine engines. The
Marine Environment Protection Committee (MEPC) is to review the standards at a minimum of
five-year intervals after entry into force of the Annex and, if appropriate, amend the NOX limits
to reflect more stringent controls.

   In March 2000, the United States requested the Marine Environment Protection Committee
(MEPC) to begin consideration of more stringent emission limits for marine diesel engines.10
EPA's analysis of emission-control technology for our 1999 rulemaking indicated that more
stringent standards were feasible for all Category 1 and Category 2 marine diesel engines.
Engine manufacturers were also beginning to investigate applying these emission-control
strategies to  Category 3 marine diesel engines, as well as more advanced strategies such as water
emulsification and selective catalytic reduction. Reflecting the potential emission reductions that
could be obtained from applying these strategies to all marine diesel engines, the U.S.
recommended Annex VI Tier 2 NOX limits be set at 25 to 30 percent below the existing Annex
VI NOX limits for all engines subject to the regulation (engines above 130 kW), to go into effect
in 2007.  This recommendation was discussed at the 44th session of the MEPC (London, March
2000), but the committee took no action.

   The United States will continue to promote more stringent standards at EVIO and encourage
MEPC to adopt a second tier of emission limits that will reflect available technology and reduce
the impact of marine diesel engines on air quality around the world.  Technology has continued
to advance since we made our request for review in 2000.  We now believe that the Member
States of the EVIO should consider further reductions of 50 percent or more from the NOX limits
currently stipulated under Regulation 13 of the Annex, to be applicable to engines installed on
vessels constructed on or after a date to be determined.
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                                                             Chapter 1: Introduction
Chapter 1 References

1.Final Regulatory Impact Analysis: Control of Emissions from Marine Diesel Engines,
November, 1999. EPA420-R-99-026. A copy of this document can be found in Docket
A-97-50, Document No. V-B-01.

2. Annex VI was adopted by a Conference of the Parties to MARPOL on September 26, 1997, but
has not yet entered into force. Copies of the conference versions of the Annex and the NOx
Technical  Code on the Control of Emissions of Nitrogen Oxides from Marine Diesel Engines
(also known as the NOx Technical Code, which contains certification and compliance
procedures) can be found in Docket A-97-50, Document II-B-01. Copies of updated versions can
be obtained from the International Maritime Organization (www.imo.org)

3.See Endnote 2.

4.More information about the EVIO can be found on its website, http://www.imo.org on the
"About IMO" tab.

5.More information about the MARPOL convention can be found on the EVIO website,
http://www.imo.org ; go to the "About EVIO" tab and click on "Conventions," then "MARPOL
73/78."

6. Information about Annex VI ratification can be found at www.imo.org (look under
Conventions, Status of Conventions - Complete List).

7. To obtain copies of this document,  see Endnote 2, above.

8. As defined in Regulation 13 of Annex VI, a major conversion means the engine is replaced by
a new engine, it is substantially modified, or its maximum continuous rating is increased by more
than 10 percent.

9.For more information about our voluntary certification program, see "Guidance for Certifying
to MARPOL Annex VI," VPCD-99-02.  This letter is available on our website:
http://www.epa.gov/otaq/regs/nonroad/marine/ci/imolettr.pdf and in Docket A-2001-11,
Document No. n-B-01.

10.MEPC  44/11/7, Prevention of Pollution from Ships, Revision of the NOx Technical Code,
Tier 2 Emission Limits for Marine Diesel Engines at or Above 130 kW, submitted by the United
States. This document is available at Docket A-2001-11, Document No. II-A-16.
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                                            Chapter 2: Health and Welfare Concerns
           CHAPTER 2:  Health  and Welfare Concerns

   The engines that are subject to the standards in this final rule generate NOX, PM, CO, and
HC emissions that contribute to ozone and CO nonattainment as well as adverse health effects
associated with ambient concentrations of PM.  They also contribute to visibility impairment and
regional haze.  This chapter presents our estimates of the contribution these engines make to our
national air inventory.  We include in this chapter estimates of pre- and post-control inventory
contributions.  These estimates are described in greater detail in Chapter 7.

   This chapter also describes the health and environmental effects related to these emissions.
These pollutants cause a range of adverse health and welfare effects, especially in terms of
respiratory impairment and related illnesses and visibility impairment.  Air quality modeling and
monitoring data presented in this chapter indicate that a large number of our citizens continue to
be affected by these emissions.

2.1 Inventory Contributions

2.1.1  National Inventory - Category 3 Marine Diesel Engines

   We developed baseline Category 3 vessel emission inventories under contract with E. H.
Pechan & Associates, Inc.1 Inventory estimates were developed separately for vessel traffic
within 25 nautical miles of port areas (called "in-port" emissions) and vessel traffic outside of
port areas but within 175 nautical miles of the coastline (called "non-port" emissions).  This two-
part method allows us to take advantage of both the detailed port-specific information maintained
by commercial port administrations rather than relying simply on cargo movement data
maintained by the U.S. Army Corps of Engineers and the Maritime Administration. More
detailed information regarding the development of the baseline emission inventories can be
found in Chapter 7.

   The in-port inventories are based on detailed emission estimates for nine specific ports for a
baseline year of 1996.  The inventories were estimated using activity data for that port (number
of port calls, vessel types and typical times in different operating modes) and an emission factor
for each mode. Emission estimates for  all other commercial ports (120 ports) were developed by
matching each  of the other commercial  ports to one of the nine specific ports. Matching was
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 for the other commercial
ports based on  relative port activity. This inventory accounts for emissions that occur within a
radius of 25 miles of the port.

   Because we do not have detailed information about the nature of non-port vessel traffic, we
developed the non-port emission inventories using information about cargo movements  and
waterways data for 1996.  In this case, the estimates are based on vessel speeds, average dead
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Final Regulatory Support Document
weight tonnage per ship, assumed cargo capacity factors and an emission factors (in grams per
nautical mile) developed using cruise mode emission factors and total freight tonnage from the
nine specific ports discussed above.  This inventory accounts for emissions that occur in the area
beginning at 25 nautical miles from the coasts and extending to sea 175 nautical miles.

    The impact on coastal areas of emissions from marine diesel engines on vessels operating at
sea depends on the extent to which those emissions actually reach 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; and how far away from shore a ship is operating. There has been
little study of the transport of marine vessel NOX emissions off U.S. coasts.

    In our inventory estimates work for the proposal we included all Category 3 vessel emissions
within 175 nautical miles of the U.S. coastline on the assumption that emission transport would
bring these emissions on to shore and affect U.S. ambient air quality.  We requested comment on
the transport issue, including whether 175 nautical miles was the appropriate distance from shore
to consider or whether we should consider a range different from 175 nautical miles as our
primary scenario, and whether we should consider different distances from the coast for different
areas of the country. We  also asked if there was additional information available to help us
assess the emission transport issue. In general, the comments received were supportive of
including all emissions within 175 nautical miles of the coast in the national emission inventory.
While some commenters questioned this distance, we received no substantial new data or
information suggesting that a different distance would be more appropriate or that would help us
determine what distance from shore we should use in our inventory analysis.

    For the purpose of this final rule, we  are including all Category 3 vessel emissions within 175
nautical miles of the U.S. coast in our emission inventory estimates. However, we acknowledge
that this emission transport issue is complex and requires further investigation.  For example, as
we  noted in the proposal for this rule, the U.S. Department of Defense (DoD) has presented some
information to us that suggests a different, shorter (offshore distance) 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. DoD's modeling work on the marine vessels issue in
Southern California led them to conclude 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.  They note that
this distance seems to be confirmed by satellite  data showing 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 that 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 a narrower (perhaps 30 nautical miles) region of "coastal influence." Nevertheless,
commenters from California support a 175 nautical-mile boundary.

    Because of the continued data and modeling uncertainties surrounding this issue, we intend to
investigate this issue as part of our future rule. As part of this investigation, we will consider the

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                                             Chapter 2: Health and Welfare Concerns
special characteristics of emission transport in separate parts of the country. For example, we
expect that the Gulf Coast and East Coast areas of the United States would have their own unique
meteorological conditions that might call for different lines of demarcation between on-shore and
off-shore effects due to different prevailing winds in those parts of the country.

   The 1996 NOX and PM emission inventories for the in-port and non-port areas are shown in
Table 2.1-1. 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.

                                       Table 2.1-1
   Category 3 Marine Diesel Engine 1996 Baseline Emission Inventories (thousand short tons)
Scenario
In-port (within 25 nautical miles of coast)
Non-port (between 25 and 175 nautical miles of
coast)
Total (within 175 nautical miles of coast)
NOX
101
89
190
PM
9.3
7.7
17
   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 fleet turnover based on 25 years as the average age of the world fleet at time of scrappage.
We also take the internationally negotiated 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 emission inventories are based on the assumption that all vessels built
after 1999 (both U.S. and foreign) will comply with the MARPOL NOX limits.  Table 2.1-2
shows the future year Category 3 marine diesel engine NOX and PM inventories for selected
years out to 2030, accounting for the implementation of Tier I/ MARPOL Annex VI NOX limits.
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 emission
inventories can be found in Chapter 7.
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Final Regulatory Support Document
                                       Table 2.1-2
                         Future Year NOX and PM Inventories for
                   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 reported in Table 2.1-3.  This table shows the relative
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 2030 for Category 3 marine diesel engines show how
emissions from these engines are expected to increase over time after  implementation of Tier I/
MARPOL Annex VI NOX limits. The projections for 2030 are reported in Table 2.1-4 and
indicate that Category 3 marine diesel engines  are expected to contribute 8.9 percent NOX and
7.3 percent of PM emissions in the year 2030.  Population growth and the  effects of other
regulatory control programs are factored into these projections. The relative importance of
uncontrolled nonroad engines in 2030 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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                        Chapter 2: Health and Welfare Concerns
                   Table 2.1-3
       Modeled Annual Emission Levels for
Mobile-Source Categories in 2000 (thousand short tons)
Category
Total for engines subject to
new standards (Category 3
engines on U.S. vessels)
Commercial Marine Diesel -
Category 3
Commercial Marine Diesel -
Categories 1 and 2
Highway Motorcycles
Nonroad Industrial SI > 19 kW
Recreational SI
Recreation Marine Diesel
Marine SI Evap
Marine SI Exhaust
Nonroad SI< 19 kW
Nonroad Diesel
Locomotive
Total Nonroad
Total Highway
Aircraft
Total Mobile Sources
Total Man-Made Sources
Mobile Source percent of Total
Man-Made Sources
NOX
tons
28
214
703
8
308
5
38
0
32
106
2,625
1,192
5,231
7,981
178
13,389
24,532
55%
percent
of mobile
source
0.2%
1.6%
5.2%
0.1%
2.3%
0.0%
0.3%
0.0%
0.2%
0.8%
19.6%
8.9%
39%
60%
1%
100%
-
-
HC
tons
1
9
22
84
226
418
1
100
708
1,460
316
47
3,391
3,811
183
7,385
18,246
40%
percent of
mobile
source
0.0%
0.1%
0.3%
1.1%
3.1%
5.7%
0.0%
1.4%
9.6%
19.8%
4.3%
0.6%
46%
52%
3%
100%
-
-
CO
tons
2
19
103
331
1,734
1,120
6
0
2,144
18,359
1,217
119
25,152
49,813
1,017
75,982
97,735
78%
percent of
mobile
source
0.0%
0.02%
0.1%
0.4%
2.3%
1.5%
0.0%
0.0%
2.8%
24.2%
1.6%
0.2%
33%
66%
1%
100%
-
-
PM
tons
2.5
19.7
20
0.4
1.6
12.0
1
0
38
50
253
30
426
240
39
705
3,102
23%
percent
of
mobile
source
0.4%
2.8%.
2.9%
0.1%
0.2%
1.7%
0. 1%
0.0%
5.4%
7. 1%
35.9%
4.3%
60%
34%
6%
100%
-
-
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Final Regulatory Support Document
                                        Table 2.1-4
                            Modeled Annual Emission Levels for
                   Mobile-Source Categories in 2030 (thousand short tons)
Category
Total for engines subject to
new standards (Category 3
engines on U.S. vessels)3
Commercial Marine Diesel -
Category 3
Commercial Marine Diesel -
Categories 1 and 2
Highway Motorcycles
Nonroad Industrial SI > 19 kW
Recreational SI
Recreation Marine Diesel
Marine SI Evap
Marine SI Exhaust
Nonroad SI< 19 kW
Nonroad Diesel
Locomotive
Total Nonroad
Total Highway
Aircraft
Total Mobile Sources
Total Man-Made Sources
Mobile Source percent of Total
Man-Made Sources
NOX
tons
28
531
680
17
44
20
52
0
64
126
1,994
531
4,059
1,648
262
5,969
16,177
37%
percent
of
mobile
source
0.5%
8.9%
11.4%
0.3%
0.7%
0.3%
0.9%
0.0%
1.1%
2.1%
33.4%
8.9%
68%
28%
4%
100%
-
-
HC
tons
1
26
26
172
17
294
2
122
269
1,200
158
30
2,316
2,496
262
5,074
16,094
32%
percent
of
mobile
source
0.0%
0.5%
0.5%
3.4%
0.3%
5.8%
0.0%
2.4%
5.3%
23.7%
3.1%
0.6%
46%
49%
5%
100%
-
-
CO
tons
2
57
137
693
265
1,843
11
0
2,083
32,310
1,727
119
39,245
56,303
1,502
97,050
121,428
80%
percent
of
mobile
source
0.0%
0.05%
0.1%
0.7%
0.3%
1.9%
0.0%
0.0%
2.1%
33.3%
1.8%
0.1%
40%
58%
2%
100%
-
-
PM
tons
2.5
54.0
20.0
1.0
2.0
10.5
1.4
0
29
93
306
18
535
158
43
736
3,297
22%
percent
of mobile
source
0.3%
7.3%
2.7%
0.1%
0.3%
1.4%
0.2%
0.0%
3.9%
12.6%
41.6%
2.4%
73%
22%
6%
100%
-
-
aThese inventories are the same as for 2000 because, based on comments received, we assumed no future increase in
U.S. domestic trade.
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                                             Chapter 2: Health and Welfare Concerns
2.1.2 Category 3 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 certain
port areas, particularly those with large commercial ports or those where the commercial port
activity is a large share of the economic activity of the area.  Using the port-specific Category 3
inventories developed for use in our national inventory and the inventories for specific areas
developed in support of the  heavy-duty on-highway 2007 rule, we developed estimates of the
contribution of Category 3 marine diesel engines to both the mobile source and total man made
NOX and PM inventories for several selected port areas, including several located in ozone
nonattainment areas. The NOX results are shown in Table 2.1-5 and the PM results are shown in
Table 2.1-6.  As can be seen from these tables, the relative contribution of Category 3 marine
diesel engine pollution to mobile source and total man made pollution for these areas is expected
to increase in the future, even in the presence of the Tier 1/MARPOL Annex VI NOX limits.
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. Consequently, we expect
Category 3 marine diesel engines to continue to be significant contributors to ozone and PM
inventories in these areas in 2020.
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                                         Table 2.1-5
                      Category 3 Marine Diesel Engines NOX Inventories
       as a Percentage of Total Man Made and 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 Total Man-Made
NOX from C3 Engines
1996
4.0
1.7
0.9
0.9
1.3
1.1
0.7
3.7
4.4
1.7
2.4
2.2
1.7
2020
6.7
6.4
1.6
2.3
5.2
3.0
3.2
17.3
19.5
9.3
6.9
3.8
6.0
% of Mobile-Source
NOX from C3 Engines
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
2020"
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
 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 2.1-6
                         Modeled PM Inventories as a Percentage of
                Total Man Made and Mobile Source PM in Selected Port Areas
Port Area
Baton Rouge and New Orleans, LA
Los Angeles/Long Beach, CAb
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 Total Man-Made
PM from C3 Engines
1996
4.0
1.8
2.3
2.0
1.0
0.7
0.5
3.4
7.5
1.4
2.1
3.3
2.0
2020
5.9
4.4
4.1
3.8
3.0
1.2
1.9
10.6
19.9
4.4
3.3
3.6
4.6
% of Mobile-Source
PM from C3 Engines
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
2020"
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
Tor reference, the nationwide contribution of Category 3 marine diesel engines to mobile source PM in 2020 is projected
to be 5.8 percent.
bPM nonattainment area.
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Final Regulatory Support Document
   Note that many of these ports, and other commercial ports, are in or near Class I Areas, as
shown in Figure 2.1-1.  Category 3 marine diesel engines on vessels that use these ports or the
sea lanes near them contribute to visibility degradation in these areas, particularly through their
PM emissions. The importance of Class I Areas is described in Section 2.5, below.
                                     Figure 2.1-1
                     Map of 156 Mandatory Class I Federal Areas
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                                             Chapter 2: Health and Welfare Concerns
2.1.3 Category 3 Emissions in Nonport Areas

   Emissions from Category 3 marine diesel engines can also have a significant impact on
inventories in areas without large commercial ports. For example, Santa Barbara estimates that
engines on ocean-going marine vessels contribute about 37 percent of total NOx in their area (see
Table 2.1-7). 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.2 By 2015 these
emissions are expected to increase 67 percent, contributing 61 percent of Santa Barbara's total
NOx emissions.  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.

                                       Table 2.1-7
                     NOx Emissions, Santa Barbara County, California
Source
1999
Tons/Day
percent of total
2015
Tons/day
percent of total
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
—
2.1.4  Category 3 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 applying emission standards
only to U.S. flagged vessels. We estimated the relative contribution of U.S. and foreign flagged
vessels separately for port areas and nonport areas due to the fact the we had different data sets
available for each.

   We estimated the proportion of total Category 3 emissions in-port attributable to 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
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1000 gross registered tons engaged in foreign trade, including the country in which they are
flagged and the number of port calls each vessel made, but did not include port calls of vessels
engaged in U.S. domestic trade. We estimated the number of port calls made by U.S. flagged
vessels engaged in domestic trade and added those to those taken from the MARAD database.
An analysis of the port call data shows that U.S. flagged vessels only account about 10 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.

   As just described, we estimated that 10 percent of Category 3 vessel calls to U.S. ports are
made by U.S. flagged vessels. However, we note that this estimate is a national average, and that
the percentage of port calls made by U.S. flagged vessels in any given port may well be different
than this.  Such factors as the size of the port and the nature of the commodities being shipped in
and out of a given port would affect the percentage of calls made by U.S. versus foreign flagged
vessels. For example, in 1997 U.S. flagged vessels made up less than 10 percent of port calls by
ocean going vessels in the Houston-Galveston area but around 15 percent of port calls in the
South Coast of California.3 4

   To estimate the proportion of total Category 3 non-port emissions attributable to U.S. vessels,
we used new port call information provided by MARAD.5 This data showed not only whether a
vessel was U.S. or foreign flagged, but whether the vessels came from other U.S. ports or from
foreign ports. The data provided by MARAD was summary data and did not include any detailed
background information. However, given the small number of Category 3 vessels engaged in
U.S. domestic trade and the large number of port calls listed in this data as being from vessels
engaged in U.S. domestic trade, we believe the data contained a significant number of Category 2
vessels in the U.S. domestic trade category. Nonetheless, this data gives us a much better picture
of the nature of vessel traffic between ports than we had for the proposal, and we used it to
estimate that roughly 20 percent of non-port emissions come from U.S. flagged vessels.

   We intend to continue researching the issue of U.S. versus foreign flagged vessel emissions
and plan to further refine our analysis in any future rulemaking efforts aimed at Category 3
vessels.

2.1.5 Category 1 and Category 2 Inventory Estimates

   Inventory estimates for Category 1 and Category 2 marine diesel engines were developed for
our 1999 rulemaking and can be found in the Final Regulatory Impact Analysis for that rule.6
The standards we are adopting for engines with in-cylinder displacement of 2.5 to  30 liters are
equivalent to the internationally-negotiated NOx standards and are currently voluntary for those
engines.  To comply with Annex VI, engines installed on ships since January 1, 2000 are widely
understood to already comply with those standards. Therefore, we are not adjusting our previous
emission inventory estimates for those engines.
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2.2 Ozone

2.2.1  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. 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.  Oxides of nitrogen
are emitted largely from motor vehicles, off-highway equipment, power plants, and other sources
of combustion. Hydrocarbons (HC) are a large subset of VOC, and to reduce mobile source
VOC levels we set maximum emission standards for hydrocarbons. VOCs can also be part of the
secondary formation of PM.

   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.7 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."
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.
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   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.

   As described in Section 2.1, Category 3 engines currently account for about 1.6 and 0.1
percent of the national mobile source NOx and HC inventories, respectively. This is expected to
increase to 8.9 and 0.5 percent, respectively, by 2030  even when considering the presence of the
internationally negotiated NOx limits.

2.2.2 Health and Welfare Effects of Ozone and Its Precursors

   Based on a large number of 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.8'9 Short-
term exposures (1 to 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 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.

   Ozone can aggravate asthma and can cause coughs and chest pain, lung inflammation and
cell damage, decreases in lung function, and increased susceptibility to respiratory infection.
Ozone has been associated with increased hospitalizations and emergency room visits for
respiratory causes. Repeated exposure over time may permanently damage lung tissue.

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   The 8-hour standard, issued by EPA in 1997, is based on well-documented science
demonstrating that more people are experiencing adverse health effects at lower levels of
exertion, over longer periods, and at lower ozone concentrations than addressed by the one-hour
ozone standard. The 8-hour standard greatly limits ozone exposures of concern for the general
population and populations most at risk, including children active outdoors, outdoor workers, and
individuals with pre-existing respiratory disease, such as asthma.

   Since the ozone national ambient air quality standards (NAAQS) were promulgated in 1997,
over fifteen hundred new health and welfare studies have been published. Many of these studies
have investigated the impact of ozone exposure on  such health effects as changes in lung
structure and biochemistry, inflammation of the lungs, exacerbation and causation of asthma,
respiratory illness-related school absence, hospital and emergency room visits for asthma and
other respiratory causes, and premature mortality. Although these studies have been published in
peer reviewed journals, they have not yet been incorporated into a revised Air Quality Criteria
Document for Ozone and Other Photochemical Oxidants. Key new health information falls into
four general  areas: development of new-onset asthma, hospital admissions for young children,
school absence rate, and premature mortality.

   Aggravation of existing asthma resulting from ambient ozone exposure was reported prior to
the 1997 decision and has been observed in studies published since (Thurston et al., 1997; Ostro
et al., 2001).  Although preliminary, an important  new finding is evidence suggesting that air
pollution and outdoor exercise could contribute to the development of new-onset asthma.  In
particular, a  relationship between long-term ambient ozone concentrations and the incidence of
asthma in adults was reported by McDonnell et al. (1999).  Subsequently, McConnell et al.
(2002) suggested that incidence of new diagnoses of asthma in children is associated with heavy
exercise in communities with high concentrations of ozone.

   Previous studies have shown relationships between ozone and hospital admissions in the
general population.  A new study in Toronto found  a significant relationship between  1-hour
maximum ozone concentrations and respiratory hospital admissions in children under two
(Burnett et al. 2001). Given the relative vulnerability of children in this age category, this is an
important addition to the literature on  ozone and hospital admissions.

   Increased school absence rate caused by respiratory illness has been associated with 1-hour
daily maximum and 8-hour average ozone concentrations in studies conducted in Nevada (Chen
et al., 2000)  in grades K-6 and in Southern California (Gilliland et al., 2001) in grades 4-6.
These studies suggest that higher ambient ozone levels may result in increased school
absenteeism.

   The air pollutant most clearly associated with premature mortality is particulate matter, with
dozens of studies reporting such an association. Repeated ozone exposure is a likely contributing
factor for premature mortality, causing an inflammatory response in the lungs which may
predispose elderly and other sensitive  individuals to become more susceptible. The findings of
three recent analyses provide consistent data suggesting that ozone exposure is associated with

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increased mortality. Although the National Morbidity, Mortality, and Air Pollution Study did not
find an effect of ozone on total mortality across the full year, Samet et al. (2000), who conducted
the study, did observe an effect after limiting the analysis to summer when ozone levels are
highest.  Similarly, Thurston and Ito (1999) have shown associations between ozone and
mortality. Toulomi et al. (1997) found that 1-hour maximum ozone levels were associated with
daily numbers of deaths in 4 cities (London, Athens, Barcelona, and Paris), and a quantitatively
similar effect was found in a group of 4 additional cities (Amsterdam, Basel, Geneva, and
Zurich).

    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 at
low levels.  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.10  Monitoring data indicates that 291 counties have  design values that
exceed these levels based on 1999-2001 data in 1997-99.n

    Ozone can have other welfare effects, with damage to plants and ecosystems being of most
concern. 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). 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.

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Ozone effects on vegetation are discussed in Section 2.2.4 below and presented in more detail in
Chapter 5, Volume II of the 1996 Criteria Document. In addition, 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.

2.2.3  Ozone Nonattainment and Contribution to 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.

   EPA is replacing the previous 1-hour ozone standard with a new 8-hour standard.  The new
standard is set at a concentration of 0.08 parts per million (ppm). The measurement period is 8
hours.  Areas are allowed to disregard their three worst measurements every year and average
performance over three years to determine if they meet the standard. That is, the standard is set
by the 4th highest maximum 8-hour concentration.

   Ground level ozone today remains a pervasive pollution problem in the United States.  About
51 million people live in areas with design values above the level of the 1-hour ozone standard
based on three years of data (1999-2001). In addition, about 111 million people live in areas
with design values  above the 8-hour ozone standard based on those three years of data.
Approximately 61 million of these people live in areas with design values above the 8-hour
standard but are below the design standard for the 1-hour ozone standard (i.e., they are  attaining
the 1-hour standard). The remainder of these people live in areas with design values above the 8-
hour ozone standards but are above the design value for the 1-hour ozone standard (i.e., they are
not attaining the  1-hour standard).12 This represents 222 counties with design values above the
level of the 8-hour  standard.

   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.13  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.
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2.2.4  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.14'15  Nitrogen dioxide can irritate the lungs and reduce
resistance to respiratory infection (such as influenza). Nitrogen dioxide and airborne nitrate also
contribute to pollutant haze, which impairs visibility and can reduce residential property values
and the value placed on scenic views.  Elevated levels of nitrates in drinking water pose
significant health risks, especially to infants.  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"). Deposition of nitrogen-
containing compounds also affects terrestrial ecosystems.

   2.2.4.1  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.16  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 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 National Surface Water Survey 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 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.

   2.2.4.2  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

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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.17
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.

   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.18 Nitrogen is the primary cause of eutrophication in most coastal waters and
estuaries.19 On the New England coast, for example, the number of red and brown tides 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.20 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.

2.3 Particulate Matter

2.3.1 General Background

   Particulate pollution is a problem affecting urban and non-urban localities in all regions of
the United States.  Particulate matter (PM) represents a broad class of chemically and physically
diverse substances. It can be principally characterized as discrete particles that exist in the

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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 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 crop land, 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, oxides of nitrogen or
volatile organic compounds (secondary particles). 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.

   As described in Section 2.1, Category 3  engines currently account for about 2.8 percent of the
national mobile source PM inventory; this is expected to increase to 7.3 percent by 2030 if left
uncontrolled.

2.3.2 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.21

   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

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   deposition in the extrathoracic (head) region. Maximum particle penetration to the thoracic
   regions occurs during oronasal or mouth breathing.

c.  Published peer-reviewed studies have reported 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.

   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

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   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.

2.3.3 PM Nonattainment

   There are two indicators related to PM NAAQS.  The first indicator is PM10, and the second
is PM2 5.  Concentrations above the PM2 5 standard are much more widespread than are violations
of the PM10 standard, and emission reductions needed to attain the PM25 standards will also lead
to attainment of the PM10 standards.

       2.3.3.1 PM10 Concentrations and Nonattainment

   The NAAQS for PM10 was established in 1987. According to these standards, the short term
(24-hour) standard of 150 |ig/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 |ig/m3 over three years. Recent PM10 monitoring data indicates that there are 8 serious and 58
moderate PM10 nonattainment areas with about 30 million people in 63 mainly western counties.

       2.3.3.2 PM2 5 Concentrations

   The NAAQS for PM25 indicator was established in 1997.  According to these standards, the
short term (24-hour) standard is set at 65 |ig/m3 based on the 98th percentile averaged over three
years.  The long-term standard specifies an expected annual arithmetic mean not to exceed 15
|ig/m3 over three years.

   Fine particle concentrations contribute to both health effects and visibility impairment. We
have monitored air quality data that establishes a present widespread nonattainment problem, and
modeling results that indicate a continuing problem plus visibility needs. Current PM2.5
monitored values  for 1999-2001, which cover about a quarter of the nation's counties, indicate
that at least 65 million people in 129 counties live in areas where design values of ambient fine
particulate matter levels are at or above the PM2.5 NAAQS. Three years of complete data are
required to make regulatory determinations of attainment or nonattainment but, based on more
limited available data, there are an additional 9 million people in 20 counties where levels
exceeding the NAAQS are being measured, but there are insufficient data at this time to make an
official estimate of the design value. In total, this represents 39 percent of the population in the
areas with monitors.22  To estimate the current number of people who live in areas where long-

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term ambient fine particulate matter levels are at or above 16 |ig/m3 but for which there are no
monitors, we can use modeling performed for the Heavy-Duty Engine and Vehicle Standards and
Highway Diesel Fuel Sulfur Control rule (also called the "HD07" rule) described elsewhere.23 At
that time, we conducted 1996 base year modeling to reproduce the atmospheric processes
resulting in formation and dispersion of PM25 across the U.S. This 1996 modeling included
emissions subject to this final rule. According to our national model predictions, there were a
total of 76 million people (1996 population) living in areas with modeled annual average PM25
concentrations at or above 16 |ig/m3 (29 percent of the population).24

   While the final implementation process for bringing the Nation's air into attainment with the
PM25 NAAQS is still being completed, the basic framework is well defined. EPA's current plans
call for designating PM2 5 nonattainment areas in late-2004.  Following designation, Section
172(b) of the Clean Air Act allows states up to three years to submit a revision to their state
implementation plan (SIP) that provides for the attainment of the PM25  standards. We expect
states to submit these SIPs in late-2007.  Section 172(a)(2) of the Clean Air Act requires that
these SIP revisions demonstrate that the nonattainment areas will attain the PM2 5 standards as
expeditiously as practicable but no later than five years from the date that the area was designated
nonattainment.  However, based on the severity of the air quality problem and the availability and
feasibility of control measures, the Administrator may extend the attainment date "for a period of
no greater than 10 years from the date of designation as  nonattainment." Therefore, we expect
that areas will be ultimately be required to attain the PM2 5 air quality standard in the 2009 to
2014 time frame.

2.3.4  Diesel Exhaust

   In addition to its contribution to ambient PM inventories, diesel exhaust PM is of special
concern because it has been implicated in an  increased risk of lung cancer and respiratory disease
in human studies, and an increased risk of noncancer health effects as well.

   EPA recently  released its final "Health Assessment Document for Diesel Engine Exhaust"
(the Diesel HAD).25 There, we concluded that diesel exhaust is likely to be carcinogenic to
humans by inhalation and environmental exposures in accordance with the revised draft
1996/1999 EPA cancer guidelines. A number of other agencies (e.g., National Institute for
Occupational Safety and Health, the International Agency for Research  on Cancer, the World
Health Organization, California EPA, and the US Department of Health and Human Services)
have made similar determinations.

   The EPA Diesel HAD states that the conclusions of the document apply to diesel exhaust as a
whole including both on-road and non-road engines as well as older and newer  engines.

   EPA generally derives cancer unit risk estimates to more precisely estimate  risk from
exposure to carcinogens. The cancer unit risk is that increased risk associated with average
lifetime exposure of 1 |ig/m3.  EPA concluded in the Diesel HAD that it is not possible to
currently calculate a cancer unit risk for diesel particles  due to a variety of factors that limit the

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Final Regulatory Support Document
current studies such as lack of adequate dose-response relations between exposure versus cancer
incidence. However, in the absence of a cancer unit risk, the Diesel HAD made estimates about
the possible magnitude of risk from exposure to diesel exhaust by comparing the environmental
exposure levels to the occupational exposure levels. This analysis suggests a range for
environmental risk between 10"3 and 10"5. While these risk estimates are exploratory and not
intended to provide a definitive characterization of cancer risk, they are useful in gauging the
possible range of risk based on reasonable judgement. It is important to note that the possible
risks could also be lower and a zero risk cannot be ruled out. Some individuals in the population
may have a high tolerance to exposure from diesel exhaust and low cancer susceptibility. Also,
there could be a threshold of exposure below which there is no cancer risk although evidence has
not been seen or substantiated on this point.

   Even though EPA does not have a carcinogenic potency with which to accurately estimate the
carcinogenic impact of diesel exhaust, the likely hazard to humans together with the potential for
significant environmental risks leads us to conclude that diesel exhaust emissions should be
reduced from nonroad engines in order to protect public health. The following factors lead to our
determination:

   •   EPA has officially designated diesel exhaust has been designed a likely human
       carcinogen.  Other organizations have made similar determinations.
   •   The entire population is exposed to various levels of diesel exhaust.
       The possible range of risk for the general US population due to exposure to diesel exhaust
       is 10"3 to 10"5 although the risk could be lower and a zero risk cannot be ruled out.

   Thus, the concern for a carcinogenicity hazard resulting from diesel exhaust exposures is
longstanding and widespread.

2.4    Carbon Monoxide

2.4.1   General Background

   Unlike many gases, CO is odorless, colorless, tasteless, and nonirritating.  Carbon monoxide
results from incomplete combustion of fuel and is emitted directly from vehicle tailpipes.
Incomplete combustion is most likely to occur  at low air-to-fuel ratios in the engine. These
conditions are common during vehicle starting when air supply is restricted ("choked"), when
vehicles are not tuned properly, and at high altitude, where "thin" air effectively reduces the
amount of oxygen available for combustion (except in engines that are designed or adjusted to
compensate for altitude).  Carbon monoxide emissions increase dramatically in cold weather.
This is because engines need more fuel to start at cold temperatures and because some emission
control devices (such as oxygen  sensors and catalytic converters) operate less efficiently when
they are cold.  Also, nighttime inversion conditions are more frequent in the colder months of the
year.  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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                                             Chapter 2: Health and Welfare Concerns
   As described in Section 2.1, Category 3 engines currently account for about 0.02 percent of
the national mobile source CO inventory; this is expected to increase to 0.05 percent by 2030 if
left uncontrolled.

2.4.2   Health Effects of CO

   Carbon monoxide enters the bloodstream through the lungs and forms carboxyhemoglobin
(COHb), a compound that inhibits the blood's capacity to carry oxygen to organs and tissues.26
Carbon monoxide has long been known to have substantial adverse effects on human health,
including toxic effects on blood and tissues, and effects on organ functions. Although there are
effective compensatory increases in blood flow to the brain, at some concentrations of COHb,
somewhere above 20 percent, these compensations fail to maintain sufficient oxygen delivery,
and metabolism declines.27 The subsequent hypoxia in brain tissue then produces behavioral
effects, including decrements in continuous performance and reaction time.28

   Carbon monoxide has been linked to increased risk for people with heart disease, reduced
visual perception, cognitive functions and aerobic capacity, and possible fetal  effects. Persons
with heart disease are especially sensitive to carbon monoxide poisoning and may experience
chest pain if they breathe the gas while exercising. Infants, elderly persons, and individuals with
respiratory diseases are also particularly sensitive. Carbon monoxide can affect healthy
individuals, impairing exercise capacity, visual perception, manual dexterity, learning functions,
and ability to perform complex tasks.

   Several recent epidemiological studies have shown a link between CO and premature
morbidity (including angina,  congestive heart failure, and other cardiovascular diseases. Several
studies in the United States and Canada have also reported an association of ambient CO
exposures with frequency of cardiovascular hospital  admissions, especially for congestive heart
failure (CHF).  An association of ambient CO exposure with mortality has also been reported in
epidemiological studies, though not as consistently or specifically as with CHF admissions. EPA
reviewed these studies as part of the Criteria Document review process.29 There is emerging
evidence suggesting that CO is linked with asthma exacerbations.

2.4.3   CO Nonattainment

   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.30

   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,

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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.31 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.32 CO standards for passenger cars and other
light-duty trucks and heavy-duty vehicles did not change as a result of other recent rulemakings.

2.5    Visibility Degradation

2.5.1   General Background

   Visibility can be defined as the degree to which the atmosphere is transparent to visible
light.33  Visibility impairment has been considered the "best understood and most easily
measured effect of air pollution."34 Visibility degradation is often directly proportional to
decreases in light transmittal in the atmosphere. Scattering and absorption by both gases and
particles decrease light transmittance.  It is an easily noticeable effect of fine PM present in the
atmosphere, and fine PM is the major cause of reduced visibility in parts of the United States,
including many of our national parks and in places where people live, work, and recreate.  Fine
particles with significant light-extinction efficiencies include organic matter,  sulfates,  nitrates,
elemental carbon (soot), and soil.  The engines subject to this rule contribute to visibility
degradation through their contribution to the national PM inventory.

   Visibility is an important effect because it has direct significance to people's enjoyment of
daily activities in all parts of the country. Individuals value good visibility for the well-being it
provides them directly, both where they live and work and in places where they enjoy
recreational opportunities. Visibility is highly valued in significant natural areas such as national
parks and wilderness areas because of the special emphasis given to protecting these lands now
and for future generations. Visibility can be described in terms of visual  range, light extinction
or deciview.b

   In addition to limiting the distance that one can see, the scattering and absorption of light
caused by air pollution can also degrade the color, clarity, and contrast of scenes.  Visibility
impairment also has a temporal dimension in that impairment might relate to  a short-term
excursion or to longer periods  (e.g., worst 20 percent of days or annual average levels).  More
detailed discussions of visibility effects are contained in the EPA Criteria Document for PM.
       bVisual range can be defined as the maximum distance at which one can identify a black
object against the horizon sky. It is typically described in miles or kilometers. Light extinction is
the sum of light scattering and absorption by particles and gases in the atmosphere.  It is typically
expressed in terms of inverse megameters (Mm"1), with larger values representing worse
visibility. The deciview metric describes perceived visual changes in a linear fashion over its
entire range, analogous to the decibel scale for sound.  A deciview of 0 represents pristine
conditions. Under many scenic conditions, a change of 1  deciview is considered perceptible by
the average person.

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                                             Chapter 2: Health and Welfare Concerns
   Visibility effects are manifest in two principal ways: (1) as local impairment (e.g., localized
hazes and plumes) and (2) as regional haze.  The emissions from engines covered by this rule
contribute to both types of visibility impairment.

   Local-scale visibility degradation is commonly in the form of either a plume resulting from
the emissions of a specific source or small group of sources, or it is in the form of a localized
haze such as an urban "brown cloud."  Plumes are comprised of smoke, dust, or colored gas that
obscure the sky or horizon relatively near sources. Impairment caused by a specific source or
small group  of sources has been generally termed as "reasonably attributable."

   The second type of impairment, regional haze, results from pollutant emissions from a
multitude of sources located across a broad geographic region. It impairs visibility in every
direction over a large area, in some cases over multi-state regions.  Regional haze masks objects
on the horizon and reduces the contrast of nearby objects.  The formation, extent, and intensity of
regional haze is a function of meteorological and chemical processes, which sometimes cause
fine particulate loadings to remain suspended in the atmosphere for several  days and to be
transported hundreds of kilometers from their sources.35

   On an annual average basis, the concentrations of non-anthropogenic fine PM are generally
small when compared with concentrations of fine particles from anthropogenic sources.36
Anthropogenic contributions account for about one-third of the average extinction coefficient in
the rural West and more than 80 percent in the rural East.37 Because of significant differences
related to visibility conditions in the eastern and western U.S., we present information about
visibility by  region.  Furthermore,  it is important to note that even in those areas with relatively
low concentrations of anthropogenic fine particles, such as the Colorado plateau, small increases
in anthropogenic fine particle concentrations can lead to significant decreases in visual range.
This is one of the reasons Class I areas have been given special consideration under the Clean Air
Act.

2.5.2 Visibility Impairment Where  People Live, Work and Recreate

   Visibility impairment occurs in many areas throughout the country, where people live, work,
and recreate, including Class I Areas.  As described in Section 2.12 above, the engines covered
by this rule contribute to PM2.5  levels in areas across the country with unacceptable visibility
conditions.

   The secondary PM NAAQS is designed to protect against adverse welfare effects such as
visibility impairment.  In  1997, the secondary PM NAAQS was set as equal to the primary
(health-based) PM NAAQS (62 Federal Register No. 138,  July 18, 1997). EPA concluded that
PM can and  does produce adverse effects on visibility in various locations,  depending on PM
concentrations and factors such as chemical composition and average relative humidity.  In 1997,
EPA demonstrated that visibility impairment is an important effect on public welfare and that
visibility impairment is experienced throughout the U.S., in multi-state regions, urban areas, and
remote Federal Class I areas.

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Final Regulatory Support Document
   EPA recently finalized a finding that nonroad engines contribute significantly to adverse
visibility effects (67 FR 68251, November 8, 2002). Category 3 engines contribute to these
effects.  They are estimated to emit 54 tons of direct PM in 2030, which is 7.3 percent of total
mobile source anthropogenic PM emissions. They also contribute to visibility degradation
through their NOx and HC emissions.
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                                           Chapter 2: Health and Welfare Concerns
References for Chapter 2

1."Commercial Marine Emission Inventory Development." E. H. Pechan and Associates, Inc.
and ENVIRON International Corporation. April 2002. Air Docket A-2001-11, item U-A-67.

2.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. U-A-47.

3."Houston-Galveston Area Vessel Emissions Inventory." Prepared by Starcrest Consulting
Group, LLC for the Port of Houston Authority.  November 2000. Air Docket A-2001-11,
Document No. IV-A-17.

4."Marine Vessels Emissions Inventory - Update to 1996 Report: Marine Vessel Emissions
Inventory and Control Strategies, Final Report." Prepared by Arcadis, Geraghty & Miller for the
South Coast Air Quality Management District. September 23, 1999.  Air Docket A-2001-11,
Document No. IV-A-18.

5.Letter from Bruce J. Carlton, Acting Deputy Maritime Administrator, U.S. Department of
Transportation, Maritime Administration to Jeffrey R. Holmstead, U.S. EPA, August 29, 2002.
Air Docket A-2001-11, item IV-G-04.

6. "Final Regulatory Impact Analysis: Control of Emissions from Marine Diesel Engines," U.S.
EPA, November 1999.

7.Carbon monoxide also participates in the production of ozone, albeit at a much slower  rate than
most VOC and NOx compounds.

8.U.S. EPA, 1996, Review of National Ambient Air Quality Standards for Ozone, Assessment of
Scientific and Technical Information, OAQPS Staff Paper, EPA452-R-96-007.  A copy of this
document can be obtained from Air Docket A-99-06, Document No. U-A-22.

9.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-99-
06, Document Nos. II-A-15, II-A-16, II-A-17.

10. 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-99-06, Documents Nos. II-A-15, II-A-16, II-A-17.

11 .Memorandum to Docket  A-2001-11 from Fred Dimmick, Group Leader, Air Trends Group,
"Summary of Currently Available Air Quality Data and Ambient Concentrations for Ozone and
Paniculate Matter,"  January 7, 2003, Air Docket A-2001-11, Document No. IV-B-05.
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Final Regulatory Support Document
12.Memorandum to Docket A-2001-11 from Fred Dimmick, Group Leader, Air Trends Group,
"Summary of Currently Available Air Quality Data and Ambient Concentrations for Ozone and
Paniculate Matter," January 7, 2003, Air Docket A-2001-11, Document No. IV-B-05.

IS.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.

14.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.

15.U.S.EPA, 1993, Air Quality Criteria for Oxides of Nitrogen, EP A/600/8-9 l/049aF.

16.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-2000-01, Document No. U-A-32.

IT.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.

18. National Research Council, 1993. Protecting  Visibility in National Parks and Wilderness
Areas. National Academy of Sciences Committee on Haze in National Parks and Wilderness
Areas. National Academy Press, Washington, DC.  This document is available on the internet at
http://www.nap.edu/books/0309048443/html/.

19.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, EPA453-R-97-011.

20.Terrestrial nitrogen deposition can act as a fertilizer. In some agricultural areas, this effect can
be beneficial.

21.EPA (1996) Review of the National Ambient Air Quality Standards for Particulate Matter:
Policy Assessment of Scientific and Technical Information OAQPS Staff Paper. EPA452-R-96-
013. Docket Number A-2001-11, Document No.  U-A-52. The parti culate matter air quality
criteria documents are also available at http://www.epa.gov/ncea/partmatt.htm.

22.Memorandum to Docket A-2001-11 from Fred Dimmick, Group Leader, Air Trends Group,
"Summary of Currently Available Air Quality Data and Ambient Concentrations for Ozone and
Particulate Matter," January 7, 2003, Air Docket A-2001-11, Document No. IV-B-05.
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                                           Chapter 2: Health and Welfare Concerns
23.See the Final Regulatory Impact Analysis: Heavy-Duty Engine and Vehicle Standards and
Highway Diesel Fuel Sulfur Control Requirements, Document EPA420-R-00-026, December
2000. Docket A-2000-01, Document No. U-A-13.  This document is also available at
http://www.epa.gov/otaq/diesel.htm#documents.

24.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. Air Docket A-2001-11, Document No. II-A-61.

25.U.S. EPA (2000) Health Assessment Document for Diesel Exhaust: SAB Review Draft.
EPA/600/8-90-057E Office of Research and Development, Washington DC. This document is
available electronically at http://cfpub.epa.gov/ncea/cfm/dieslexh.cfm.

26. Coburn, R.F. (1979) Mechanisms of carbon monoxide toxicity. Prev. Med. 8:310-322.

27.Helfaer, M.A., and Traystman, RJ.  (1996) Cerebrovascular effects of carbon monoxide.  In:
Carbon Monoxide (Penney, D.G., ed). Boca Raton, CRC Press, 69-86.

28. Benignus, V.A.  (1994) Behavioral effects of carbon monoxide: meta analyses and
extrapolations.  J. Appl. Physiol. 76:1310-1316. Docket A-2000-01, Document IV-A-127.

29.The CO Criteria Document (EPA 600/P-99/001F) contains additional information about the
health effects of CO, human exposure, and air quality. It was published as a final document and
made available to the public in August 2000 (www.epa. gov/ncea/co/).  A copy of this document
is also available in Docket A-2000-01, Document A-U-29.

SO.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. U-A-59.

31. 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 (EPA454-R-00-002), March, 2000.  These documents are available at Docket No.
A-2000-01, Document No. U-A-72. See also Air Quality Criteria for Carbon Monoxide, U.S.
EPA, EPA 600/P-99/001F, June 2000, at 3-10. Air Docket A-2001-11, Document Number
II-A-58.  This document is also available at http://www.epa.gov/ncea/coabstract.htm.

32.The more stringent standards refer to light light-duty trucks greater than 3750 pounds loaded
vehicle weight, up through 6000 pounds gross vehicle weight rating (also known as LDT2).

33.Oldendnote36.

34.Old endnote 37.

35. National Research Council, 1993 (Ibid).

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Final Regulatory Support Document
36.National Research Council, 1993 (Ibid).

37. National Acid Precipitation Assessment Program (NAPAP), 1991.  Office of the Director.
Acid Deposition: State of Science and Technology. Report 24, Visibility: Existing and Historical
Conditions - Causes and Effects.  Washington, DC. Cited in US EPA, Review of the National
Ambient Air Quality Standards for Particulate Matter: Policy Assessment of Scientific and
Technical Information. OAQPS Staff Paper. EPA452-R-96-013.  This document is available in
Docket A-99-06, Document U-A-23. Also, US EPA.  Review of the National Ambient Air
Quality Standards for Particulate Matter: Policy Assessment  of Scientific and Technical
Information, OAQPS Staff Paper. Preliminary Draft.  June 2001. Docket A-2000-01, Document
IV-A-199.
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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 or registered in other countries. We do not attempt to perform this analysis  on a
port-specific basis. However, given the small number of U.S. vessels in comparison with the
world fleet, it is likely that the contribution of U.S. vessels with Category 3 engines to local air
pollution in any given port is likely to be small  compared with that of foreign 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.

   We provided an industry characterization for Category 1 and Category 2 marine diesel
engines in the Final Regulatory Impact Analysis document for our 1999 rule.1

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 of 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.
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   EPA defines Category 3 marine engines as compression-ignition (i.e., diesel) engines 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).  Low-speed engines
are two-stroke models which are connected to a direct drive propulsion system. The medium-
speed engines are typically four-stroke engines (a very small percentage are two-cycle).  These
engines are commonly 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 characteristic 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. Because of its high level
of paraffins, bunker fuel is solid at ambient 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.  This is
described  in greater detail in Section 8.1.2 of Chapter 8.

    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.2
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.

   Category  3 marine diesel engines are unique among engines  in the sense  that they are very
large and are  not typically 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 built specifically for that vessel.

   Once a vessel manufacturer has determined the size and output of the engine necessary for a
particular  vessel 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

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                                                Chapter 3: Industry Characterization
the engine starts and operates properly.  Certification testing to demonstrate compliance with the
MARPOL Annex VI NOx limits may also occur at this time. The engine 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 and connects it the propulsion system.
This is typically done 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

   Category 3 engine manufacturers are generally large, multi-national, diversified companies
which also produce smaller marine engines, marine propulsion and marine electric generation
equipment. In addition, these companies produce engines for other uses such as locomotives and
power plants. Many have divisions which manufacture vessels and operate shipyards.

   We have identified 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.

   Category 3 diesel engine manufacturers are located primarily in Europe and Japan. Only one
engine company (Caterpillar) which manufactures Category 3 diesel engines is headquartered in
the United States. Caterpillar 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 produce Category 3 engines. This list was
compiled from the Directory of Marine Diesel Engines^
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Final Regulatory Support Document
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 vary 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 for 1998.4 The Annual
Analysis data are based on a survey of ships with dead weight tonnage (DWT) greater than 2,000
that were delivered in that year.  These data are presented in Table 3.2-2. 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 3.2-3 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
Manufacturer
MANB&W
Sulzer
Mitsubishi
















Total
LOW-SPEED El
Engines
515
150
100
















765
^GINES
Percent of Total
67.3%
19.6%
13.1%

















M
Manufacturer
Wartsila
MANB&W
MaK
Caterpillar
Sulzer
Bergen
Deutz MWM
GMT
Ruston
Hanshin
MTU
Niigata
Yanmar
Pielstick
Akasaka
Unknown
SKL
Daihatsu
Russki
Total
EDIUM-SPEED E>
Enpines
135
92
75
32
24
21
20
19
15
13
9
9
7
6
6
5
4
3
2
497
JGINES
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%
04%
Source: Motorship, Annual Analysis
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Final Regulatory Support Document
                                       Table 3.2-3
              Top 10 Licensees of Category 3 Engines for Years 1999 and 2000
Yard Nationality

JAPAN
S. KOREA
JAPAN
JAPAN
JAPAN
S. KOREA
NORWAY
S. KOREA
FINLAND
CHINA
Licensee
1999
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
Manufacturer

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
No of Engines

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
3.2.3   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
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.
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                                                 Chapter 3: Industry Characterization
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 this final rule. 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.

3.3.1   United States Vessel Manufacturers

   3.3.1.1 Description of Vessels

   This section characterizes 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 2,000 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 (ro ro), 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 part of the shipbuilding process and can take up to 18 months. 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 the design process that the owner and architects decide
what engines to use.  In determining the appropriate propulsion 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 and 14 months.

   3.3.1.3 Background of the U.S. Shipbuilding Industry and Global Competition

   Shipbuilding has historically been an important industry in the United States.  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.
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   The vast majority of commercial ships used throughout the world are built in other countries.
A major shift in shipbuilding market share began in the 1960s with Japan's entry into the market.
South Korea entered the market in thel970s, and China entered in 1980.  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.
                 Figure 3.3-1: World Commercial Shipbuilding Tonnage
                      1979
                                                              2001
                                                    United States Cni
   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).
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                                                 Chapter 3: Industry Characterization
   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 3.3-1 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

                                      Table 3.3-1
                       Deliveries from U.S. Shipyards, 1990 to 2000
            (Merchant ships over 1000 Gross Tons 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 Colton 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") refers 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 in more than 40 nations with significant ocean-going fleets,  are designed
to ensure a strong national merchant marine fleet for  defense, employment, and general economic
purposes by reserving a country's domestic maritime transportation for its  own citizens.
Cabotage laws are designed to guarantee the participation of a country's citizens in  its own
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Final Regulatory Support Document
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.

   Cabotage laws in the U.S. date back to 1789, when 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. Currently, U.S. maritime cabotage laws
include a number of different statutes that govern the transportation of cargo and passengers
between two points in 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.
•  A foreign vessel can pick up or deliver cargo at a U.S. port, but it can't pick up cargo in one
   U.S. port and deliver the same cargo to another U.S. port, even if the vessel stops at a foreign
   port in the mean time.
•  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 being U.S.-flagged, 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 performed 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.
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                                                  Chapter 3: Industry Characterization
   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. vessels. In other words, all Jones Act
vessels are U.S.-flagged, but not all U.S.-flagged vessels are 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, 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 uses the Major Shipbuilding Base (MSB) to track the U.S. shipbuilding industry.
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; many of these 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.  Only three of these shipyards are
currently building vessels. Table 3.3-2 lists the eight shipyards that have most recently been
involved in building large commercial vessels.
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Final Regulatory Support Document
                                       Table 3.3-2
                    U.S. Shipyards Building Large Commercial Vessels
Shipyard
National Steel & Shipbuilding Co.
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., Avondale Industries, Inc., and Ingalls Shipyard. A fourth shipyard, Kvaerner
Philadelphia Shipyard, Inc. had a long history of producing large oceangoing vessels, primarily
for the Navy, but was closed in 1996. 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 major shipbuilding facilities tracked by the MSB 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
3.3-3 presents the employment and sales for the largest U.S. shipyards still active (or with
capacity) to build large commercial vessels by yard.  Table 3.3-4 presents similar information
related to the parent companies.
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                                 Chapter 3: Industry Characterization
Table 3.3-3 Employment and Sales for the Largest U.S. Shipyards
Active (or With Capacity) in Building Large Commercial Vessels
Shipyard
National Steel & Shipbuilding Co.
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 200 1
Has commercial capability, but
focuses on military construction
Has commercial capability, but
focuses on ferry construction
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Final Regulatory Support Document
    Table 3.3-4 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.,
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 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 Brewery
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

   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
OPA-90, U.S. shipyards have built 10 double-hulled tankers with options for two more. United
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                                                 Chapter 3: Industry Characterization
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 due 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 ocean-going, self-propelled merchant vessels of 1,000 gross
tons and over that are flagged or registered in the U.S. The vessel name, ship type, engine type,
the year and country in which the operator (government or private) vessel was built, gross
tonnage, 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

   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 II. The United States now
ranks  17th in number of oceangoing vessels, having fallen from a top-ten ranking just a few years
ago. The U.S. 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. 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. 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.
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Final Regulatory Support Document
        Table 3.4-1  MARAD Summary of U.S. Fleet Vessels for Vessels >2,000 DWT
         Total
Commercial
Government
Jones Act
200
163
37
* 1
3.4.3 Foreign Vessels that Enter U.S. Ports

   The current estimate that 7,600 foreign vessels with Category 3 engines enter U.S. ports.
There are over 25 different types of foreign 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. The largest cruise ships can
exceed 1,000 feet in length, hold up to 5,000 passengers and crew, contain over 1,600 cabins, and
have up to 14 decks. There are twelve companies that account for the majority of cruise ship
activity in U.S.  waters. Table 3.4-2 lists these twelve companies.

                         Table 3.4-2 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 cruise ships flagged or registered in the United States.  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 plan 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
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                                                Chapter 3: Industry Characterization
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
Fransico. 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 the U.S. through Los Angeles, New York
and San Fransico,  while the majority of oil and other tanker-carried products entered and left the
U.S. primarily through Houston and New Orleans.

            Table 3.5-1 Top Five U.S. Commercial Ports in 2000 - Based on Calls
Port
Los Angeles
Houston
New Orleans
New York
San Fransico
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 7,600 foreign vessels with Category 3 engines visited U.S.
ports in 1999. When the U.S. fleet of 200 vessels is added, this means that about 97 percent of
the total number of Category 3-powered vessels that made calls to U.S. ports were by foreign
vessels. U.S. vessels accounted for only about three percent of the total number of vessels
visiting U.S. ports. Table 3.5-2 lists U.S. vessel types for 1999 and the number of each type.
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             Table 3.5-2 MARAD Summary of U.S. 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 vessels. As stated above, 7,800 vessels visited
U.S. ports in 1999. These vessels made a total of 75,700 entrances to U.S. ports. Of these
entrances, 67,500 or 89 percent, were made by foreign vessels.  Only 8,200 entrances or 11
percent were made by U.S. 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 U.S. and foreign 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) for
1999.
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                                                Chapter 3: Industry Characterization
             Figure 3.5-1: Vessel Entrances for 1999 - All Vessels
                              Illlliui
              12345
                             10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30
                                    Number Entrances
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 had an adverse impact on the U.S. tourism
industry.  The September 11th attacks exacerbated this impact, and 2001 was the first year in a
decade in which embarkations  actually decreased.  According to the Cruise Lines International
Association, the cruise industry has rebounded dramatically since the tragic events of September
2001, and the number of embarkations in 2002 have increased over 2001.  The cruise industry is
responding to consumer confidence by continuing to expand its fleet.  More than 20 ships are
slated to enter the cruise fleet between fall of 2002 and the end of 2003.14
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3.6 Conclusion

   The Category 3 marine diesel engine and vessels industry is relatively concentrated. 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 flagged or  registered outside
the United States. Approximately 200 U.S. vessels with Category 3 engines used U.S. ports in
1999. 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. vessels is small in comparison with the world fleet,  it is
likely that the contribution of U.S. vessels with Category 3 engines to local air pollution in any
given port is small compared with that of foreign vessels.
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                                                Chapter 3: Industry Characterization
Chapter 3 References

1.      EPA420-R-99-026, November 1999.

2.      IPC Industrial Press Ltd., Motorship, Jan. 2000.

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.

14.    Cruise Lines  International Association. Article in Cruise News.  September 10, 2002.
       www.cruising.org.
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                                                          Chapter 4: Tier 1 Standards
                     CHAPTER 4: Tier 1 Standards
   This chapter describes the current state of technology for marine diesel engines greater than
2.5 liters per cylinder.  This includes a discussion of the feasibility of meeting the Tier 1
standards. The combustion process and potential technologies are basically the same for all the
marine engine types in this rule including slow-speed, two-stroke engines and medium-speed
four-stroke engines, and will be differentiated only where significant differences exist.

4.1  Marine Engine Technology

4.1.1  Diesel Engine Emission Formation

   Marine diesel engines, like their land-based counterparts, operate by compressing and cooling
the charge air before it fills the cylinder where fuel is injected, which auto-ignites under pressure.
In marine engines, 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,
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.

   The majority of PM emissions from these engines comes from running on heavy fuel oil
(residual fuel) and the high level of sulfur in the fuel.  The highest portion of PM (by weight) is
from ash, metal, oxides, and sulfates (see Table 4.1-1). 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
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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 emissions of both pollutants through the use of common rail and
electronic controls.

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. 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.
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                                                           Chapter 4: Tier 1 Standards
           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,
Liters/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 diesel 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, roll-on roll-off vessels, 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 diesel  engines burn heavy fuel oil, also known as residual
fuel. Residual fuel is make up of the heavier  components of crude oil, including contaminants
such as sulfur, that remain after the crude oil has been processed to obtain gasoline, number 2
diesel, kerosene, and other lighter fuels.  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 undesirable solids. In addition, vessel
operators must verify proper engine operation 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.

   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).
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    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.
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 MARPOL,  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.

4.1.3 Anticipated Technology to Meet Emission Standards

    Engine manufacturers are meeting the Tier 1 standards today using a variety of emission-
control  technologies.  Table 4.1-3 summarizes technology being used by manufacturers to meet
these levels. 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.

	Table 4.1-3:  Summary of NOx Reduction Techniques Used to Meet EVIO Standards	
          Manufacturer
                       In-Engine changes
 Wartsila6
Retard injection
Miller cycle valve timing Higher compression ratio Increased turbo efficiency
Higher max cyl pressure Common rail injection
 Caterpillar7 (MaK)
Higher compression ratio
Higher cylinder pressure
Higher charge pressure
Flexible injection system
 FMC8
Two stage injection
Miller cycle valve timing Greater stroke/bore ratio
Adjustable compression
Two stage turbocharger
Low intake temperature
 Yanmar9
Retard injection
Shorter combustion time
Higher compression ratio
Higher boost pressure
Reduced nozzle hole size
Increased number of holes
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                                                          Chapter 4: Tier 1 Standards
4.1.4  Description of Technology

   4.1.4.1  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

   4.1.4.1.1 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.  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.10 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.

   4.1.4.1.2 Combustion Chamber Geometry

   Parameters within the combustion chamber geometry that yield reduced emissions include
the shape of the chamber and reduced crevice volumes.  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

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favorable effect on the possible utilization of the air during operation under conditions with low
excess air ratios."11

    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.12 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.13

    4.1.4.1.3 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.14 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.15
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.

    4.1.4.1.4 Valve Timing

    Medium-speed four-stroke engines employ valves in their design whereas two-stroke
generally operate with ports. This technology is only relevant for designs with valves.  The
efficiency of a diesel engine generally increases with its expansion ratio because more work is
generated by the engine for a given stroke.16 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

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                                                          Chapter 4: Tier 1 Standards
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.17
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.18  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.19

   4.1.4.1.5  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.20

   4.1.4.2 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 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 section 5.1.2).
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   4.1.4.3 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.

   4.1.4.3.1 Fuel Injection Pressure

   Particle emissions and fuel consumption generally go down with increasing injection
pressure.21  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.22

   Manufacturers continue to investigate new injector configurations for nozzle geometry and
higher injection pressure (in excess of 2300 bar (34,000 psi)).23'24  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.25  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.26

   4.1.4.3.2 Nozzle Geometry

   Nozzle geometry is  a very important parameter for combustion development.27 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
piston bowl used. This technology,  in combination with engine tuning, was used by one engine
manufacturer to achieve EVIO 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.28
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                                                          Chapter 4: Tier 1 Standards
   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. Test-bed 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."29  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.

   4.1.4.3.3 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.30

   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.31 This strategy is most effective in conjunction with retarded timing, which leads to
reduced NOx emissions without the attendant increase in PM.

   4.1.4.3.4 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.32 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.

   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

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Final Regulatory Support Document
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.33 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 lengthen the life of the
solenoid armature which can be affected by high temperatures such as the temperature of heavy
fuel oils  (150°C+) This also ensures that the injection will not be affected by erosion wear and
clogging of the small drillings.  The  design does not have the rail (accumulator) pressure
prevailing at the nozzle seat in between the injection events, mainly to avoid leaking nozzles.
Otherwise, 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 engines 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 provisionfor damping pressure waves.  The common-
    rail inj ection system is fed by heated fuel oil at the usual high pressure (nominally 1000 bar) ready for inj ection.
    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 valves by the engine manufacturer, regulate the timing of fuel injection, control the volume
    of fuel injected, and set the shape of the inj ection pattern. The three fuel inj ection 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.34

    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

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                                                            Chapter 4: Tier 1 Standards
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."35

    The system is controlled and monitored through the electronic control system developed by
the manufacturer. The modular system has separate microprocessor control units for each
cylinder and overall control and supervision by duplicated microprocessor control units. This
provides the interface for the electronic governor, the shipboard remote control, and the 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.

    4.1.4.3.5 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.36 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, and engine side control console.  The items added
to the engine include a hydraulic power supply, hydraulic cylinder unit with electronic fuel
injection and electronic exhaust valve activation, electronic alpha cylinder lubricator,
electronically controlled starting valve, local  control panel, control system with governor, and
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
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.37 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 that may be seen in

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Final Regulatory Support Document
common rail fuel systems.  The manufacturer includes a discussion on closed loop NOx control,
stating 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.

   4.1.4.4 Lube Oil Consumption

   Many of the Category 3 marine diesel engine manufacturers are working to reduce the
consumption of lubricating oil from their engines, to address customer's demand for reduced
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.

   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 Table 4.1-1).  Reducing oil consumption in Category 3 marine engines
will decrease PM emissions by a lesser percentage than the same kind of improved oil control in
highway diesel engines.

   4.1.4.5 Emission-Controls and System Approaches

   Table 4.1-4 identifies several technologies that individual manufacturers have already
incorporated to reduce emissions and may likely be used to meet the near-term standards.  All
these different approaches together would reduce emissions at least 10 or 15 percent below the
near-term  standards. The table also identifies several technologies that are beginning to gain
field experience on engines in-use and may be available as the basis for the eventual long-term
standards.
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                                                          Chapter 4: Tier 1 Standards
         Table 4.1-4:  "In-Engine" Combustion Process Changes Currently In-Use or
      Being Investigated by Marine Diesel Engine Design and Manufacturing Companies38
Component or
Operation Changed
turbocharger
intercooler
air inlet port
cylinder head
piston crown
injection pressure
injectors
nozzle
exhaust valve timing
electronic control
common rail injection
injection timing
Change
improved efficiency, variable
flow
improved efficiency
redesign shape
redesign shape
redesign piston crown shape
increase
redesign
hole geometry & number
"Miller cycle" timing
replaces mechanical control
replace unit injection
retard and/or vary with load
Parameter Affected
BSFC, intake pressure
air inlet temperature
swirl
swirl, compression ratio
swirl, compression ratio
atomization
low sac, injection rate
shaping
spray pattern changes
peak cylinder temperature
engine operation, BSFC
higher fuel pressure (all
loads)
peak cylinder temperature
Slow-
Speed 2-
Stroke
Yes
Yes
Maybe
Maybe
No
Yes
Yes
Possibly
Yes
Yes
Yes
Yes
Medium
Speed 4-
Stroke
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
4.2  Technology Costs

   The standards in this rule align with these internationally negotiated standards, so we expect
manufacturers to incur only negligible costs to meet the EPA requirements. These costs will
likely be limited to administrative expenses, such as applying for certification, updating training
manuals, and revising engine labels.

4.3  Emission Reductions

   The standards in this rule align with the internationally negotiated MARPOL Annex VI NOx
standards.  Engine manufacturers have been manufacturing engines in compliance with these
internationally negotiated NOx standards for the last few years, and we expect that they will
continue to do so. Thus, we do not expect that there will be any emission reductions associated
with this rule. Table 4.3-1  shows the national Category 3 NOx inventories, with and without the
internationally negotiated NOx standards. The no control scenario was developed by taking the
baseline emissions  case (compliance with the internationally negotiated NOx limits, as described
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Final Regulatory Support Document
in Chapter 7) and applying to all new vessels the ratio of pre-control emission factors to emission
factors under the internationally negotiated NOx limits.

                                      Table 4.3-1
               Category 3 Marine Vessel NOx National Emission Inventories

No control baseline (thousand short tons)
EPA/
MARPOL
Annex VI
(thousand short tons)
Percent reduction (relative to no control)
1996
190
190
—
2010
303
274
9.6%
2020
439
367
16.2%
2030
659
531
19.5%
4.4  Impact on Noise, Energy, and Safety

   The Clean Air Act requires that we 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 manufacturers
control NOx emissions by incorporating a combination of engine technologies. Some of these
changes in isolation may increase fuel consumption, but these are generally offset by other
changes that decrease fuel consumption. Moreover, given the fact that we do not expect the
standards in this final rule to change engine technologies, we expect no change in fuel efficiency
to result from the near-term standards.

   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.

4.5  Category 1 and 2 Marine Engines Greater  Than 2.5 Liters/Cylinder

   As with Category 3 marine engines, manufacturers are designing their Category 1 and 2
marine engines greater than 130 kW to meet the MARPOL Annex VI NOx limits.
Manufacturers have met these limits through in-cylinder combustion optimization. In our final
rule for Tier 2 standards for Category 1  and 2 marine  engines, we only attributed costs and for
NOx reductions beyond the negotiated international NOx limit (64 FR 73300, December 29,
1999).  In the Final Regulatory Impact Analysis for that rule, we discussed in-cylinder emission-
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                                                         Chapter 4: Tier 1  Standards
control strategies such as those used by manufacturers today to meet the negotiated international
NOx limit.39
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Final Regulatory Support Document
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.  Paro, Daniel, "Development of the Sustainable Engine," International Council on Combustion
Engines, CIMAC Congress 2001, Docket A-2001-11, Item II-A-13.

7.  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.

8.  Fiedler, Hugo, "Shaping the Combustion Process by Utilisation of High Pressure Injection,"
International Council on Combustion Engines, CIMAC Congress 2001, Docket A-2001-11, Item
II-A-50.

9.  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 II-A-04.

10. 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 II-A-04.

11. 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.

12. 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.

13. 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

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                                                        Chapter 4: Tier 1 Standards
A-2001-11, Item II-A-05.

14. Acurex Environmental Corporation, "Estimated Economic Impact of New Emissions
Standards for Heavy-Duty Highway Engines," prepared for U.S. EPA, March 26, 1996, Docket
A-2001-11, Item m-B-01.

15.  Schlemmer-Kelling, U., Rautenstrauch, M., "The New Low-Emission Heavy Fuel Oil
Engines of Caterpillar Motoren," International Council on Combustion Engines, CEVIAC
Congress 2001, Docket A-2001-11, Item H-A-02.

16.  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.

17. Sato, Takeyuki, et. al., "Development of'NEO' Medium Speed Diesel Engines,"
International Council on Combustion Engines, CEVIAC, 2001 Congress, Docket A-2001-11, Item
II-A-06.

18.  Okada, Shusuke, et. al., "The Development of a Very Low Fuel Consumption Medium
Speed Diesel Engine," International Council on  Combustion Engines, CEVIAC, Congress 2001,
Docket A-2001-11, Item H-A-04.

19.  Schlemmer-Kelling, U., Rautenstrauch, M., "The New Low-Emission Heavy Fuel Oil
Engines of Caterpillar Motoren," International Council on Combustion Engines, CEVIAC
Congress 2001, Docket A-2001-11, Item H-A-02.

20.  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.

21.  Philipp, Schneemann, Willmann, Kurreck, "Advanced Optimisation of Common Rail Diesel
Engine Combustion," International Council on Combustion Engines, CEVIAC Congress 2001,
Docket A-2001-11, Item H-A-03.

22.  Heider, G., Eilts, P., "Improving the Soot-NOx-BSFC Trade-Off of Medium Speed, 4-Stroke
Diesel Engine," International Council on Combustion Engines, CEVIAC Congress 2001, Docket
A-2001-11, Item II-A-05.

23.  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.

24.  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.

25.  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.
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Final Regulatory Support Document
26. 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.

27. 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.

28. 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.

29. 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.

30. 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.

31. Piepont, D., Montgomery, D., Reitz, R., "Reducing Particulate and NOx Using Multiple
Injections and EGR in a DI Diesel," SAE Paper 950217, 1995, Docket A-2001-11, H-A-44.

32. 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.

33. 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.

34. 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.

35. 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.

36. Sorensen,Per and Pedersen, Peter, "The Intelligent Engine Design Status and Service
Experience", International Council on Combustion Engines, CIMAC Congress  2001, Docket
A-2001-ll,ItemII-A-15.

37. Moncelle, M.E., "Fuel Injection System & Control Integration", International Council on
Combustion Engines, CIMAC Congress 2001, Docket A-2001-11, Item II-A-14.

38. 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 II-A-08.
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                                                       Chapter 4: Tier 1 Standards
39.  "Final Regulatory Impact Analysis:  Control of Emissions from Marine Diesel Engines,"
U.S. Environmental Protection Agency, November 1999, EPA-420-R-99-026, Docket
A-2001-11 TV-A-05.
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                              Chapter 5: Advanced Emission-Control Technologies
   CHAPTER 5:  Advanced  Emission-Control Technologies

   This chapter focuses on technologies under development which could be used to achieve
further emission reductions beyond current  standards for Category 3 marine engines. These
technologies will be considered as we develop standards for our future rule.  Section 5.1
discusses the introduction  of water into the  combustion process to reduce emissions. Sections
5.2 and 5.3 discuss selective catalytic reduction and fuel cells. Section 5.4 discusses other engine
technologies that could be used in conjunction with water strategies or SCR.

   The discussion in this chapter focuses on Category 3 marine diesel engines.  Similar
information about the technology associated with applying these standards to Category 1 and
Category 2 marine diesel engines are contained in the Final Regulatory Impact Analysis for our
1999 rule.1 Section 5.5 briefly discusses those technologies.

   Section 5.6 discusses PM emission control from Category 3 marine diesel engines.

5.1 Water Introduction into the Combustion Process

   Water can be used in the combustion process to lower maximum combustion temperature,
and therefore lower NOx formation, without increasing 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. Data on water-based emission-control technologies suggest that this technology has
the potential to reduce NOx emissions by more than 50 percent from the standards we are
finalizing. However, there are several problems with this technology that must be resolved
before it can be applied generally.  These issues are discussed below.

5.1.1 Description of the Technology

   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-to-fuel ratio of
50 percent0 with only a slight increase in smoke.2 Two power plants with slow-speed diesel
engines are using water emulsification today to reduce NOx.3 In the referenced 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 that are similar in
design  and operation. Water emulsification requires changes to the engine and fuel system.
       c 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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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 its 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.4 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.5  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 percent of rated), no water is added, from 30-40 percent of rated power, 20
percent water is added,  above  40 percent 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 that
was eroded by cavitation and water wear after 900 hours.  An example of stratified injection was
developed for a slow-speed diesel  engine.6  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).7 Further
work on another engine achieved a NOx reduction of 70 percent with 90 percent water (6 g/kW-
hr).8 With only 50 percent water, a 40 percent reduction in NOx from this engine was observed.
Wartsila has installed direct water injection systems on engines in  14 vessels. These are
primarily ferries and ro-ro  vessels  operating in European waters  where there are economic
incentives for reducing NOx emissions.  In addition, Wartsila plans to install direct water
injection on engines in another 8 vessels by the end of 2003.9  A list of these applications is
contained in the appendix following this chapter.

    Wartsila is also evaluating two other methods introducing water into the combustion
process.10  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

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                               Chapter 5: Advanced Emission-Control Technologies
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-to-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 an 85
percent NOx reduction with a 3.0-3.5  water-to-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.

5.1.2 Issues to Resolve

   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.

   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.

5.2  Selective  Catalytic Reduction

   SCR is one of the most effective means of reducing NOx from large  diesel engines. This
technology is already being developed for land-based diesel engines and has been used in some
marine demonstration projects. Data  suggests that SCR has the potential to reduce NOx
emissions by more than 80 percent from the standards we are finalizing.  However, there are still
several problems with this technology that must be resolved before it can be applied generally.
These issues are  discussed below.
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Final Regulatory Support Document
5.2.1  Description of the Technology

   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.11 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 many stationary applications, which generally
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.  The Royal Navy has developed a demonstration system that was tested on a replica
exhaust system for a Type 23 Frigate.12  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.13

   Wartsila 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.14'15 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 Category 3 marine engines operating on both residual
and distillate fuel oil at the end of 2000.16 Lists of the systems are contained in the appendix
following this chapter. The majority of these engines were in ferries and ro-ro vessels operating
in European waters where there are economic  incentives to use SCR.  In addition, these engines
are four-stroke medium-speed engines which have higher exhaust temperatures than two-stroke
low-speed engines which better enables the use of SCR.  To prevent sulfur poisoning  of the
catalysts, the fuel used by these vessels ranges from 0.1 to 1 percent sulfur.

   In one case, SCR was equipped on vessels with two-stroke low-speed engines. More than ten
years ago, MAN B&W worked with California Agencies and Hyundai Heavy Industries to
produce four vessels equipped with SCR.17  The goal of this program was to reduce the emissions
emitted during the transportation of steel to a facility in Pittsburg, California.  The first ship was
completed in 1989 and the fourth ship was completed in 1992. Because the vessels were
equipped with low-speed engines (6S50MC, 10,680 hp), the exhaust temperatures were low. In
addition,  the vessels operate at low load near the coast; therefore, certain modifications to the
system were necessary. Primarily, the exhaust system was reconfigured to provide the maximum
heat to the reactor which had negative impacts on transient response and efficiency. Also, the
catalyst was formulated to be effective at temperatures as low as 270°C. Because such a reactive
catalyst is vulnerable to sulfur poisoning, the vessels only operate on 0.05 percent sulfur fuel

                                          5-4

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                               Chapter 5: Advanced Emission-Control Technologies
when the SCR unit is active.  MAN B&W estimates that these vessels only make about 6 calls to
California per year and that the SCR unit is only active for about 12 hours per call.

   Generally, SCR systems available today are effective only above 300°C. To date, these
systems have been applied to four-stroke medium speed engines which have exhaust
temperatures above 300°C at high load.  Two-stroke slow speed engines have lower exhaust
temperatures and are discussed later in this section. The effectiveness of the SCR system is
decreased during engine operation at partial loads due to decreased exhaust temperatures.  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, engines may operate at
less than 25 percent power in a reduced speed zone. During this low-load operation, little or no
NOx reduction would be expected; SCR would therefore be less effective 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.

5.2.2  Issues to Resolve

   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.  SCR units in
service today are operating of fuel ranging from 500 to 10,000 ppmS. Even if these  systems can
be made to operate on 15,000 ppmS fuel, an infrastructure would be necessary to ensure that
ships could refuel with 15,000 ppmS fuel at ports they visit. 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.

     Slow-speed marine engines generally have 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, these
four in-service engines use highway diesel fuel (0.05 percent S). In addition, these ships only
operate with the exhaust routed through the  SCR unit when they enter port areas 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

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Final Regulatory Support Document
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.

    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.18
Depending on the precious metals used in the SCR unit, it may 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 sulfur to  direct sulfate PM. Direct sulfate PM
emissions could be reduced by using lower sulfur fuel.

    SCR  systems traditionally have required a significant amount of space on a vessel;  in some
cases the SCR unit is as large as the engine itself.  However, at least one manufacturer is
developing a compact system with 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 sulfur to direct sulfate PM.  NOx
reductions of 85 to 95 percent have been demonstrated with an extraordinary sound attenuation
of25to35dB(A).19

    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.  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 also increase operating costs. The operation
characteristics of ocean going vessels may interfere with correct maintenance of the SCR system.
Ferries that use SCR today 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 which often do not have regular down time.

    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 catalyst downstream of the reactor could burn off the
excess ammonia.

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                               Chapter 5: Advanced Emission-Control Technologies
    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 automatically sounds
for a period of time periodically during the operation of the engine.  The air pulsation from the
horn prevents dirt from building up on the catalyst without requiring engine shut down for
maintenance. The horn may be driven by air from the normal air system installed on the vessel.
Compressed air cleaning requires a period of engine shut down, during which 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 can  operate for about 20,000 hours before needing replacement.

5.3 Fuel Cells

    Another approach to achieve large reductions in emissions 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 1997.20  The U.S.
Navy in early 2000 sponsored an effort to continue the development of the molten carbonate fuel
cell for marine use.21  The Society of Naval Architects and Marine Engineers released the
technical report "An Evaluation of Fuel  Cells for Commercial Ship Applications."22 This report
examines fuel cells for application in commercial ships of all types for electricity generation for
ship services and for propulsion.

    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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Final Regulatory Support Document
5.4  Other Engine Technologies

   Chapter 4 discusses several in-cylinder technologies that are being used to meet levels the
internationally negotiated NOx standards.  These technologies can be used in conjunction with
water introduction strategies or selective catalytic reduction to optimize the engine/exhaust
systems for further reductions.  This section describes two other in-cylinder control strategies that
could be used in conjunction with advanced technology for further emission reduction: exhaust
gas recirculation and electronic control.

   5.4.1 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.23'24

   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.25 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.26 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.27

   Exhaust gas recirculation has also  been shown on a slow-speed two-stroke engine, in
conjunction with direct water injection, to achieve a 70 percent reduction in NOx.28 Without
EGR, only a 50 percent 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.29 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, internal EGR avoids
some problems associated with external EGR. For example, 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
lubricating oil, which can lead to increased engine wear.  Another concern with routing the

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                               Chapter 5: Advanced Emission-Control Technologies
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.

   5.4.2 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 better balanced to minimize any negative effects. 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.  It can also be used with a feedback loop to optimize the exhaust conditions for effective
selective catalytic reduction of NOx. Electronic control is already used in limited marine
applications.

5.5  Category 1 and Category 2 Marine Diesel Engines

   We also intend to reconsider Tier 3 emission standards for Category 1 and Category 2
standards in a future rulemaking.  We proposed Tier 3 standards for these engines on December
11, 1998 (63 FR 68508), but chose not to finalize the Tier 3 standards at that time.  Further
analysis of potential Tier 3 standards for Category 1 and Category 2 marine diesel engines may
be found in the draft Regulatory Impact Analysis prepared for the proposal for our 1999 rule.30
Those standards relied on the types of in-cylinder controls described in 5.1 above.

   In determining the proposed Tier 3 standards for Category 1 and Category 2 marine engines,
we considered the application of technology being used for land-based nonroad and locomotive
engines to marinized engines. We recently published a report on technology that we believe can
be used by nonroad engines to meet Tier 3 standards.31'32 We will consider the application of this
technology to marinized engines as well. We will also consider the feasibility of using more
advanced technologies than in-cylinder control for Category 1 and Category 2 marine engines.
For instance, water-injection and SCR may also be applied to these engines.

5.6  PM Emission Control  from Category 3 Marine Diesel Engines

   For typical diesel engines operating on distillate fuel, particulate matter formation is
primarily the result of incomplete combustion of the fuel (and lube oil). The traditional in-
cylinder technologies discussed in section 4.1.4 can be used to reduce this type of PM formation
while simultaneously reducing NOx emissions. If aftertreatment, such as  SCR, is used to control
NOx, then the in-cylinder technologies can be used primarily for PM reductions. However,
because Category 3 marine engines generally use high-sulfur residual fuel, two issues arise.
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Final Regulatory Support Document
    The first issue is that the majority of PM emissions in engines burning residual fuel comes
directly from the high concentration of sulfur in the fuel. As discussed in Chapter 4, metal
oxides and sulfur in the fuel can make up 65 percent of the PM in the exhaust compared with
only 15 percent in highway diesel engines. The emission-control technology discussed above
would only have an impact on the non-sulfur PM exhaust emissions. A more effective control
strategy would be to reduce the amount of sulfur in the fuel used by Category 3 marine engines.
In addition, engines calibrated and tested for PM on distillate fuel would not necessarily see the
same reduction in PM when operated on residual fuel due to the differences in the fuel
characteristics.  This leads to the second issue.

    The second issue is that no acceptable procedure exists for measuring PM from engines
operating on fuels with a sulfur level greater than 0.8 percent, as specified by ISO 8178.  This is
supported by correlation testing performed on a Category 3 engine at four laboratories.33
Residual fuels typically have sulfur levels on the order of 2-4 percent and even distillate fuels
used by Category 3 marine diesel engines generally have sulfur levels over 1 percent.
Established PM test methods collect PM on a filter with a specification for maximum
temperature.  This maximum temperature is intended to ensure that the soluble organic fraction
of the PM will condense and be collected on the filter. While non-sulfate PM is made up of
hydrocarbons from the fuel and lube oil, the direct sulfate portion of the PM is made up of sulfate
ions bonded with water.  As a result, the measured mass of the sulfate portion of the PM is
sensitive to test conditions such as temperature and humidity.  This causes unacceptable
variability in PM test results from engines operating on high sulfur fuels.  In addition, when
testing on residual fuel, the particulate concentration can ten times higher than when testing on
distillate fuel. At these high PM levels, the PM in the exhaust can unpredictably deposit on the
walls of the dilution tunnel and re-entrain into the exhaust stream.  This adds some further
uncertainty to the measured results.
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Appendix to Chapter 5:  Current DWI and SCR Installations
            Wartsila DWI Reference List 2001
                                          34
Ship
Ro ro
Ro ro
Ro ro
Ro ro
Ro ro
Ro ro
Ro ro
Silja Symphony
Silja Serenade
Finnmarken
Trolfjord
Superfast XI
Superfast XII
Coral Princess
Island Princess
Diamond Princess
Saphire Princess
Chrystal Serenity
Chemical Tanker
Chemical Tanker
Car Ferry
Chemical Tanker
Chemical Tanker
Owner
Goby Shipping AB
Goby Shipping AB
Ernst Russ GmbH & Co
Ernst Russ GmbH & Co
Bror Husell Chartering AB Ltd
Ernst Russ GmbH & Co
Ernst Russ GmbH & Co
Silja Line
Silja Line
OVDS, Norway
TFDF, Norway
Superfast Ferries
Superfast Ferries
P&O Princess Cruises
P&O Princess Cruises
P&O Princess Cruises
P&O Princess Cruises
NYKLine
Fortum Oil and Gas Oy
Fortum Oil and Gas Oy
TFDF, Norway
Fortum Oil and Gas Oy
Fortum Oil and Gas Oy
Engine
12V46C
12V46C
12V46C
12V46C
16V46B
16V46B
16V46B
4x9L46A
4x9L46A
2xW6L32, 2xW9L32
2xW9L32
4xl2V46
4xl2V46
2xl6V46
2xl6V46
2xW846, 2xW9L46
2xW846, 2xW9L46
6xl2V38B
9L46C
9L46C
2xW9L32
8L46
8L46
In Service
Jan 1999
Feb 1999
Mar 1999
Apr 1999
May 1999
Jun 1999
Dec 1999
Jun 1999
Jun 1999
Nov2001
End 2001
End 2001
Spring 2002
Sep 2002
Sep 2002
Jul 2003
End 2003
Apr 2002
May 2003
July 2003
End 2003
Jan 2003
July 2003
                          5-11

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Final Regulatory Support Document
                          Wartsila SCR Reference List 200135
Vessel
Aurora af
Helsingborg
Silja
Serenade
Silja
Symphony
Gabriella
Thjelvar
Birka
Princess
M/V
Spaarneborg
M/V
Schieborg
M/V
Slingeborg
Gotland
Rederi
Gotland
Rederi
M/V Grano
Newbuilding
Application
Double
ended ferry
Cruise ferry
Cruise ferry
Cruise ferry
Ferry
Cruise ferry
Ro-Ro
Ro-Ro
Ro-Ro
RoPax
RoPax
Ro-Ro
Special
Engines
1 x WV6R32
1 x WV8R32
1 x WV8R32
1 x WV6R32
2 x WV4R32
4 x WV12R32
4 x WV12R32
2 x WV6R32
1 x WV4R32
1 x 7RTA52U
2 x W6L20
1 x 7RTA52U
2 x W6L20
1 x 7RTA52U
2 x W6L20
4 x 12V46
3 x 9L20
4 x 12V46
3 x 9L20
lxWV1632
2 x W6L32
2xW12V32
Fuel
MDO
0.1%S
HFO
0.5%S
HFO
0.5%S
HFO
0.5%S
HFO
0.5%S
HFO
0.5%S
HFO
MDO
HFO
MDO
HFO
MDO
HFO
<1%S
HFO
<1%S
HFO
LFO
Reduction
Agent
40% urea
water
40% urea
water
40% urea
water
40% urea
water
40% urea
water
40% urea
water
40% urea
water
40% urea
water
40% urea
water
40% urea
water
40% urea
water
40% urea
water
40% urea
water
Delivery
Date
1992
1995
1995
1997
1997
1999
1999
1999
2000
2000
2000
2000
2002
Notes



Retrofit
Compact
SCR, retrofit
Compact
SCR, retrofit



Compact
SCR
Compact
SCR
Compact
SCR, retrofit
Compact
SCR
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                 Chapter 5: Advanced Emission-Control Technologies
SIEMENS SINOx Marine Exhaust Gas Treatment Plants and Systems
                                                       36,37
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
WartsilaNSD
MS Ortviken(S)
SEA PARTNER
MS Baltic 2
MS Baltic 3
MS Baltic 4
MS Timbus(S)
Roerd Braren
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
Ship propulsion
1 main engine
Ship propulsion
1 main engine
1 aux engines
Field of
Application
Fuel
MDO
MDO
MDO
MDO
MDO
MDO
HFO
MDO
HFO
MDO
HFO
MDO
HFO
HFO
HFO
HFO
MDO
Fuel
Capacity
inkW
4,500
920
2,000
4x3,720
2x1,240
4x5,200
3x1,435
4x7,000
3x450
3,840
540
4x4,500
2x2,250
2x4,050
3x610
3,360
3,360
3,360
3,840
540
Capacity in
kW
Volume
flow in
NrnVh
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
19,000
21,000
3,000
Volume
flow in
Nm3/h
Extent of
Delivery
SINOx
SINOx
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
1999
1999
Delivery
Date
                           5-13

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Final Regulatory Support Document
Customer
Operator
MS Forester(S)
Roerd Braren
Silja Line
1600 LM
RoPax(S)
Gotland Rederi
Field of
Application
Ship propulsion
1 main engine
2 aux engines
Ship propulsion
4 main engines
Ship propulsion
4 main engines
3 auxiliary engines
Fuel
HFO
MDO
HFO
HFO
Capacity
inkW
3,840
2x239
4x7,950
4x12,600
3x1,530
Volume
flow in
NmVh
21.000
2x1,200
48,500
4x63,000
3 x 9,000
Extent of
Delivery
SINOx
SINOx
SINOx
Delivery
Date
1999
2000
2000
                                      5-14

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                             Chapter 5: Advanced Emission-Control Technologies
Chapter 5 References

1.  Final Regulatory Impact Analysis: Control of Emissions from Marine Diesel Engines,
November 1999. EPA420-R-99-026. Docket A-2001-11, Item IV-A-05.

2.  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, Docket A-2001-11, Item IV-A-07.

3.  Ohtsu, M., "Recent Development of Slow Speed Diesel Power Plants," International Council
on Combustion Engines, CEVIAC Congress 2001, Docket A-2001-11, Item IV-A-09.

4.  Paro, D., "Effective, Evolving, and Envisaged Emission Control Technologies for Marine
Propulsion Engines," presentation from Wartsila to EPA on September 6, 2001, Docket
A-2001-1 l,II-A-72.

5.  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, CEVIAC Congress 2001, Docket A-2001-11, Item IV-A-10.

6.  Sakabe, H., Okabe, M., "The UEC-LS II/LSE Engine Development Program," International
Council on Combustion Engines, CEVIAC Congress 2001, Docket A-2001-11, Item IV-A-08.

7.  Aeberli, K., Mikulicic, N., "The Sulzer RTA-Low Speed Engine Range: Today and In the
Future," International Council on Combustion Engines, CEVIAC Congress 2001, Docket
A-2000-11, Document H-A-07.

8.  Paro, D., "Effective, Evolving, and Envisaged Emission Control Technologies for Marine
Propulsion Engines," presentation from Wartsila to EPA on September 6, 2001, Docket
A-2001-1 l,II-A-72.

9. E-mail from Fred Danska of Wartsila to Cheryl Caffrey of EPA on April 22, 2002, Docket
A-2001-11, Document IV-A-12.

10. Paro, D., "Effective, Evolving, and Envisaged Emission Control Technologies for Marine
Propulsion Engines," presentation from Wartsila to EPA on September 6, 2001, Docket
A-2001-1 l,II-A-72.

11. Schafer-Sindlinger, A., "NOx Reduction for Diesel Vehicles," Degussa, Presentation at
Coming's Clean Diesel Workshop, September, 1999, Docket A-2001-11, Item H-A-29.

12. Hughes, D., McAdams, R., Non-Thermal Plasma  for Marine Diesel Engines," International
Council on Combustion Engines, CEVIAC Congress 2001, Docket A-2001-11, Document
IV-A-13.
                                        5-15

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Final Regulatory Support Document
13. 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 U-A-08.

14. E-mail from Fred Danska of Wartsila to Cheryl Caffrey of EPA on April 22, 2002, Docket
A-2001-11, Document IV-A-12.

15. 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-2001-11, Document
II-A-01.

16. 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 U-A-08.

17. MAN B&W, "Emission  Control Two-Stroke Low-Speed Diesel Engines," Docket
A-2001-11, Document IV-A-14.

18. "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, Docket A-2001-11, U-A-49.

19. Paro, D., "Effective, Evolving, and Envisaged Emission Control Technologies for Marine
Propulsion Engines," presentation from Wartsila to EPA on September 6, 2001, Docket
A-2001-1 l,II-A-72.

20. 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.

21. 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.

22. 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.

23. 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.

24. Piedpont, D., Montgomery, D., Reitz, R., "Reducing Particulate and NOx Using Multiple
Injections and EGR in a DI Diesel," SAE Paper 950217, 1995, Docket A-2001-11, Item U-A-46.

25. 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 U-A-43.

                                         5-16

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                             Chapter 5: Advanced Emission-Control Technologies
26. 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.

27. 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.

28. 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-2001-11, Item II-A-07.

29. Mikulicic, N. "Exhaust Emissions: Next Steps for Low-speed Two-stroke Engines," Marine
News, 1999, No. 3, Docket A-2001-11, II-A-01.

30. Draft Regulatory Impact Analysis: Control of Emissions from Marine Diesel Engines,
November 1998.  EPA420-R-98-017.  Docket A-2001-11, Item IV-A-06.

31. "Nonroad Diesel Emission Standards; Staff Technical Paper," U.S. Environmental
Protection Agency, EPA420-R-01-052, October 2001, Docket A-2001-11, IV-A-03.

32. Memorandum from Chet France, Director ASD to Margo Tsirigotis Oge, Director OTAQ,
"Comments on Nonroad Diesel Emissions Standards Staff Technical Paper," June 4, 2002,
Docket A-2001-11, IV-A-02.

33. Bastenhof, D., "Exhaust Gas Emission Measurements;  A Contribution to  a Realistic
Approach," CIMAC, May 1995.

34. E-mail from Fred Danska of Wartsila to Cheryl Caffrey of EPA on April 22, 2002.

35. E-mail from Fred Danska of Wartsila to Cheryl Caffrey of EPA on April 22, 2002.

36. SINOx Exhaust Gas Treatment Plants and Systems, Marine, Sales brochure from Siemens
Westinghouse Power Corp.

37. 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 U-A-08.
                                        5-17

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Final Regulatory Support Document
                                      5-18

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                            Chapter 6: Estimated Costs for Advanced Technologies
  CHAPTER 6: Estimated  Costs for Advanced Technologies

   This chapter presents estimated costs for several of the emission-control technologies
described in Chapter 5 for reducing emissions below the levels necessary to meet this first tier of
EPA emission standards. While the technologies can be applied generally to marine diesel
engines, we analyze the costs of these technologies only for engines over 30 liters per cylinder.

   These estimated costs are based on our current understanding of the changes necessary to
incorporate the advanced technologies on marine diesel engines. We start with a general
description of the approach for estimating costs, then  describe the various technologies and
assess the projected costs of each approach.  We developed the costs for individual technologies
in cooperation with ICF, Incorporated and A.D. Little.1  When we propose emission standards in
the future, we will revisit the cost estimates presented in this chapter. We intend to use any
information that becomes available in the meantime to update the cost estimates as needed to
most accurately project the anticipated economic impacts of the standards we eventually propose.

6.1  Methodology

   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 6.1-1 highlights the key operating characteristics of these representative engines.

   Costs of control include variable costs (for incremental hardware and assembly) and fixed
costs (for tooling and R&D). 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.

   The impact of fixed costs on the per-engine costs  depends on the number of engines produced
using the advanced technologies.  We consider two cost scenarios: applying the advanced
technologies only to Category 3 engines on U.S. vessels, and  applying them to Category 3
engines on all vessels that use U.S. ports.
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Final Regulatory Support Document
                                      Table 6.1-1
                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
6.2  Technology Costs

   Total estimated costs are 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.

6.2.1  Fuel Injection Improvements

   Fuel-injection improvements can be made in at least two ways.  First, manufacturers might
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.  Second, common rail technology
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.

   Table 6.2-1 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 be the same whether the standards apply to engines on
U.S. vessels  or whether they also apply to engines on foreign vessels.  Fixed costs for
development and tooling are considered in the next section.
                                          6-2

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                            Chapter 6: Estimated Costs for Advanced Technologies
                                      Table 6.2-1
                   Projected Costs per Engine for Fuel Injection Upgrade

Medium-speed Engines
6cyl.
9cyl.
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
6.2.2  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.

   The kind of changes addressed in this section do not necessarily involve variable costs
(except for changes to fuel injection, as noted above).  Changing valve timing and redesigning
the geometry of engine components, for example, would generally not involve cost increases
beyond those considered for development time and tooling.  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 5. Manufacturers could use this development 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
                                          6-3

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Final Regulatory Support Document
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 redesign 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. 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
two main reasons. First, even if the standards were to apply only to Category 3 engines on U.S.
vessels, manufacturers may 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, it is possible that new ship construction for the U.S. market may increase in the future.
Currently, new ship  construction rates in the U.S. are below the rate necessary for ongoing
replacement of vessels, resulting in an overall aging of the U.S. fleet. Requirements related to
double-hull tanker designs may also lead ship owners to consider retrofitting or replacing
existing ships. Together, these factors may 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
engines on foreign 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.
Setting international standards that apply globally would roughly double the assumed sales
volumes and halve the estimated fixed cost per engine, but this would be a very small effect
compared with assigning costs only to engines on U.S. vessels.

   These costs are summarized in Table 6.2-2.  Estimated costs are about $64,000 per engine.  If
the standards apply to engines on both U.S. and foreign vessels, the estimated cost per engine
drops nearly to $6,000.
                                           6-4

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                             Chapter 6: Estimated Costs for Advanced Technologies
                                       Table 6.2-2
                    Projected Costs per Engine for Engine Modifications

Total fixed
costs
U.S. vessels
only
Including
foreign vessels
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
6.2.3  Direct Water Injection

   Table 6.2-3 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.  This includes substantial
time for manufacturers to optimize in-cylinder controls in their efforts to produce an overall
system solution to incorporating water-injection technology.  Total costs range from about
$120,000 to $320,000 depending on engine size. If emission standards apply also to engines on
foreign vessels, the estimated cost range is $50,000 to $250,000.

   In addition, any ship using direct water injection would incur operating costs to keep the
system functioning.  These operating costs are best quantified on an hourly basis.  Total costs
depend on how long the systems run.  This cost analysis is based on the expectation that ship
operators will activate the water-injection systems during the time that the ships are within 175
nautical miles of the U.S. coast. We estimate this annual operating rate to be 975 hours for U.S.
vessels and 149 hours for foreign vessels. Considering the population of these types of vessels
leads to a composite figure of 170 hours per year for all vessels.

   We consider two types of operating costs—water and fuel.  At a cost of $0.10 per gallon for
distilled water, total estimated costs per year for U.S. vessels range from $4,000 to $23,000.
Since foreign vessels spend less of their total operating time near the U.S., their estimated annual
water costs range from $600 to $3,600. Calculated as a net present value, with 7 percent
discounting to the point of sale, estimated composite costs are $120,000 for U.S. vessels and
                                           6-5

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Final Regulatory Support Document
$21,000 if we apply the standards to Category 3 engines on all vessels (see Table 6.2-4). Note
that 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 desalination unit).

   We also estimate a 2-percent increase in fuel consumption for engines using direct water
injection for operation within 175 miles of the U.S. coast. This involves annual costs of $900 to
$5,500 per year for engines on U.S. vessels.3 Applying standards to Category 3 engines on all
vessels would result in estimated average per-engine costs of $200 to $1,000.

   As a sensitivity analysis, we consider the effect of operating a water-injection unit  at all  times
that the propulsion engine is running. To quantify this, we calculate revised operating costs for
increased fuel consumption and the greater amount of water used to control NOx emissions. The
composite calculation of operating costs yields an estimated net present value of $630,000, based
on an operating rate of 4,000 hours per year (see Table 6.3-2 to compare with other scenarios).
This estimated cost applies equally to all vessels, regardless of their flag state.  We would expect
no additional fixed or variable costs associated with producing a system designed to operate
continuously. On the other hand, a ship owner may substantially reduce operating costs by
investing in onboard water-production capability, as described above.
                                           6-6

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        Chapter 6: Estimated Costs for Advanced Technologies
                 Table 6.2-3
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
Including foreign vessels
Total Hardware RPE
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

$41,386
$7,772
$49,158
$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

$61,432
$7,772
$69,204
$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
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

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Final Regulatory Support Document
                                       Table 6.2-4
                           Water costs for Direct Water Injection
Parameter
BSFC (g/kW-hr)
load factor
water/fuel ratio
water use (kg/hr)
water cost per kg
water cost per hour
total cost per year
(U.S. vessels only) —
@ 975 hours/yr.
Present value
(U.S. vessels only)
total cost per year
(foreign vessels only) —
@ 149 hours/yr.
Present value
(foreign vessels only)
total cost per year
(composite) —
@ 170 hours/yr.
Present value
(composite)
Medium-speed Engines
6cyl.
190
50%
40%
152
$0.0264
$4
$3,900
$43,962
$596
$6,718
$680
$7,665
9cyl.
190
50%
40%
228
$0.0264
$6
$5,850
$65,942
$894
$10,077
$1,020
$11,498
12 cyl.
190
50%
40%
304
$0.0264
$8
$7,800
$87,923
$1,192
$13,436
$1,360
$15,330
Slow-speed Engines
4 cyl.
190
50%
40%
304
$0.0264
$8
$7,800
$87,923
$1,192
$13,436
$1,360
$15,330
8 cyl.
190
50%
40%
608
$0.0264
$16
$15,600
$175,846
$2,384
$26,873
$2,720
$30,660
12 cyl.
190
50%
40%
912
$0.0264
$24
$23,400
$263,769
$3,576
$40,309
$4,080
$45,991
6.2.4  Selective Catalytic Reduction

    Selective Catalytic Reduction (SCR) can be designed to operate at different levels of NOx -
reduction efficiency.  Increasing NOx reductions correspond with higher costs. For this analysis,
system parameters are based on settings to allow an 80-percent reduction in NOx emissions.
Later in this section, we consider the effect on costs of installing and operating a system set for
less effective NOx reduction.

    Variable costs include 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.
                                           6-8

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	Chapter 6: Estimated Costs for Advanced Technologies

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. This includes substantial time for manufacturers to optimize in-cylinder
controls in their efforts to produce an overall system solution to incorporating SCR technology.
Total costs range from about $260,000 to $1.23 million, depending on engine  size. The expected
costs for very high-volume reactors for the largest engines involve oversize components and
additional engineering that substantially increase total estimated costs for those units. If
emission standards apply also to engines on foreign vessels, the estimated cost range is $220,000
to $1.18 million. Table 6.2-5 summarizes the estimated costs for such an SCR system.

   As described in Section 6.2.3, SCR units can be managed so that they operate only within
175 nautical miles of the U.S. coast, which leads us to calculate operating costs on an hourly
basis. For SCR, we consider three kinds of operating costs.  First, a ship using SCR must
provide urea to the engine.  At  a cost of $1.30 per gallon for aqueous urea, total estimated costs
per year for U.S. vessels range  from $9,000 to $53,000.  Since foreign vessels spend  less of their
total operating time near the U.S., their estimated annual urea costs range from $1,300 to $8,000.
Calculated as a net present value, with 7 percent discounting to the point of sale, estimated
composite costs are $270,000 per engine for U.S. vessels and $48,000 per engine if we include
foreign vessels (see Table 6.2-5).

   Second, SCR operation is more durable when engines operate on fuels with low
concentrations of sulfur. This may involve operation with a low-sulfur residual fuel, distillate
fuel, or a blend of these two fuel types.  Further investigation would help us establish the specific
fuel requirements for maintaining SCR systems in the field.  This analysis presents the estimated
costs associated with operation on distillate fuel  within 175 nautical miles of the U.S. coast.  We
believe that most vessels already have dedicated tanks available for storing distillate fuel. If a
vessel would need a new tank or an additional tank devoted to carrying distillate fuel, that would
involve an additional cost beyond what we consider in this analysis. Calculating the  cost of
using a marine distillate fuel depends on an estimated  load factor of 50 percent. Current prices
for the different fuel types shows an increase of about $75 per ton of fuel for switching to marine
distillate.  This results in annual costs ranging from $28,000 to $170,000 per engine for U.S.
vessels. Including foreign vessels would drop these costs to a range of $5,000 to $29,000 per
engine.  Fuel costs are discussed in Section 6.2.5.

   Third, the analysis considers costs related to  system maintenance.  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 periodically while the engine is operating. The air
pulsation from the horn prevents soot from building up in the catalyst. The horn may be driven
by air from the normal air system installed on the vessel.  This method requires no engine
shutdown. Using compressed air to  clean the reactor would require a period of engine shut
down.  In this method, a soot-blowing probe is inserted into the catalyst unit to remove soot. As
manufacturers gain experience with these systems, it will become clearer which of these cleaning
operations is preferred. For this analysis, we anticipate ten cleaning steps per year, taking 4

                                           6-9

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Final Regulatory Support Document
person-hours for medium-speed engines and 6 person-hours for low-speed engines.  This results
in net-present value maintenance costs ranging from $18,000 to $26,000, as shown in Table
6.2-7.  SCR reactors generally would need to be rebuilt or replaced after about 20,000 hours of
operation; however, we do not expect SCR units to operate so long over the life of a Category 3
marine diesel engine.

   We consider two sensitivity analyses regarding SCR. First, similar to that described for water
injection, we calculate costs based on continuous operation of the SCR unit when the propulsion
engine is running.  Increasing the annual operating rate to 4,000 hours and increasing to 25
cleaning steps in a year raises the composite operating costs to a net present value of $4.7 million
(see Table 6.3-2 to compare with other scenarios).  This estimated cost applies equally to all
vessels, regardless of their flag state. We would expect no additional fixed or variable costs
associated with producing a system designed to operate continuously.

   For the second sensitivity scenario, we consider the cost effect of installing an SCR unit
designed to reduce emissions by only 50 percent.  The less aggressive NOx reductions translate
into lower capital and operating  costs based on published estimates for commercially available
systems.4  This leads us to estimate a 10-percent lower level of fixed costs and a 30-percent lower
level for variable (or component) costs.  This lower costs result mainly from designing and
producing a smaller, simpler reactor. The estimated composite cost per engine for an SCR unit
achieving a 50-percent NOx reduction is $415,000 for engines on U.S.  vessels and $375,000 if
we include all vessels. Operating costs for urea would decrease approximately in proportion to
the NOx reduction. It is unclear whether a 50-percent SCR system would be more tolerant of
fuel sulfur or whether it would need the same fuel quality as an 80-percent system. If we make
fuel costs also proportional to percent reductions over 975 hours of operation (for U.S. vessels
only), we calculate a composite operating cost of $735,000 (net present value).
                                          6-10

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 Chapter 6: Estimated Costs for Advanced Technologies
          Table 6.2-5
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
Including foreign vessels
Total Hardware RPE
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

$193,993
$4,717
$198,710
$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

$288,730
$4,717
$293,447
$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

$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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Final Regulatory Support Document
                                      Table 6.2-6
                                   Urea costs for SCR
Parameter
BSFC (g/kW-hr)
load factor
aqueous urea rate
aqueous urea use (kg/hr)
aqueous urea cost per kg
total cost per year
(U.S. vessels only) —
@ 975 hours/yr.
Present value
(U.S. vessels only)
total cost per year
(foreign vessels only) —
@ 149 hours/yr.
Present value
(foreign vessels only)
total cost per year
(composite) —
@ 170 hours/yr.
Present value
(composite)
Medium-speed Engines
6cyl.
190
50%
7.5%
29
$0.3173
$8,775
$98,913
$1,341
$15,116
$1,530
$17,246
9cyl.
190
50%
7.5%
43
$0.3173
$13,650
$153,865
$2,086
$23,514
$2,380
$26,828
12 cyl.
190
50%
7.5%
57
$0.3173
$17,550
$197,827
$2,682
$30,232
$3,060
$34,493
Slow-speed Engines
4 cyl.
190
50%
7.5%
57
$0.3173
$17,550
$197,827
$2,682
$30,232
$3,060
$34,493
8 cyl.
190
50%
7.5%
114
$0.3173
$35,100
$395,654
$5,364
$60,464
$6,120
$68,986
12 cyl.
190
50%
7.5%
171
$0.3173
$52,650
$593,481
$8,046
$90,696
$9,180
$103,479
                                      Table 6.2-7
                               Maintenance costs for SCR
Parameter
Cleaning — per event
Cleaning— NPV
Medium-speed Engines
6 cyl.
$157
$1,570
9 cyl.
$157
$1,570
12 cyl.
$157
$1,570
Slow-speed Engines
4 cyl.
$235
$2,350
8 cyl.
$235
$2,350
12 cyl.
$235
$2,350
6.2.5  Fuel Costs

   Table 6.2-8 presents the fuel costs we use in our analyses of various emission-control
approaches.  These analyses include the costs of reducing fuel sulfur to enable SCR technology
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                            Chapter 6: Estimated Costs for Advanced Technologies
and baseline fuel costs for a fuel consumption sensitivity analysis.  Prices for residual fuel and
marine diesel oil come from Marine Bunker News.5 Note that these costs represent about a 50%
increase compared with the costs from January 2002 that were used in the analysis supporting the
proposal.6 Given the volatility of fuel prices, it is clear that fuel-related cost estimates may
change significantly when we reconsider emission standards for Category 3 engines. Table 6.2-9
shows how these prices translate into increased operating costs when switching from the least
expensive residual fuel to marine distillate.

                                      Table 6.2-8
                   Bunker Fuel Costs per Metric Ton (October 23, 2002)
Port
Rotterdam
Fujairah
Singapore
Houston
Residual Fuel
380 centistokes
$141-142
$155-157
$153-154
$144-145
Residual Fuel
180 centistokes
$145-146
$160-161
$157-158
$147-148
Marine Distillate
$212-213
$255-256
$232-236
$218-220
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Final Regulatory Support Document
                                     Table 6.2-9
  Costs of Switching from Residual Fuel to Marine Distillate Fuel to Enable SCR Technology
Parameter
BSFC (g/kW-hr)
load factor
increased fuel cost per
hour
total cost per year
(U.S. vessels only) —
@ 975 hours/yr.
Present value
(U.S. vessels only)
total cost per year
(foreign vessels only) —
@ 149 hours/yr.
Present value
(foreign vessels only)
total cost per year
(composite) —
@ 170 hours/yr.
Present value
(composite)
Medium-speed Engines
6cyl.
190
50%
$29
$28,267
$318,629
$4,320
$48,693
$4,929
$55,556
9cyl.
190
50%
$43
$41,786
$471,016
$6,386
$71,981
$7,286
$82,126
12 cyl.
190
50%
$58
$56,534
$637,257
$8,639
$97,386
$9,857
$111,112
Slow-speed Engines
4 cyl.
190
50%
$58
$56,534
$637,257
$8,639
$97,386
$9,857
$111,112
8 cyl.
190
50%
$113
$110,609
$1,246,808
$16,903
$190,538
$19,286
$217,392
12 cyl.
190
50%
$171
$167,143
$1,884,066
$25,543
$287,924
$29,143
$328,504
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                            Chapter 6: Estimated Costs for Advanced Technologies
6.3  Total Engine Costs

6.3.1 Distribution of Category 3 Marine Engines

   We can use the cost estimates presented above to develop an estimated composite cost for
applying advanced technologies to Category 3 marine diesel engines.  This estimate is based on
the characteristics of the current fleet.  Population data show that 60 percent of these are two-
stroke engines.7 The average power rating for vessels using Category 3 marine engines is 11,000
kW.  This average kW is based on data collected on seven U.S. ports that are available to ocean-
going vessels.8 Using these parameters, we  estimated the distribution of engines shown in Table
6.3-1. While the actual distribution clearly covers a much wider range of engines and may
change before we propose emission standards requiring advanced technologies, this analysis
provides an initial estimate to assess the costs of incorporating advanced technologies.

                                      Table 6.3-1
                     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%
6.3.2 Projected Composite Costs for Category 3 Engines

   We estimated composite costs for two of the technology approaches described in this
chapter—direct water injection and selective catalytic reduction.  These costs are summarized in
Table 6.3-2. For direct water injection, the total estimated composite costs for U.S. vessels is
about $190,000.  Annual operating costs are estimated at $14,000, with discounted lifetime
operating expenses estimated to be just over $150,000. Including foreign vessels would decrease
estimated composite engine costs to around $120,000 and lifetime operating expenses to
$26,000.

   For SCR, the total estimated composite costs for U.S. vessels is about $580,000, based on
parameters that would allow for NOx emission reductions of about 80 percent. Annual operating
costs are estimated at $103,000, with discounted lifetime operating expenses estimated to be $1.2
million. Including foreign vessels would decrease estimated composite engine costs to $540,000
and lifetime operating expenses to $220,000.

   The analysis is based on manufacturers recovering their fixed costs over a five-year period.
Once these costs are fully amortized, they are removed from the analysis.  Since fixed costs are
large and sales volumes are small, removing the fixed costs substantially reduces the estimated
long-term costs, as shown in Table 6.3-2. Long-term costs may also decrease as manufacturers
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Final Regulatory Support Document
learn to produce emission-control technologies at a lower cost.  We have not quantified the
learning effect in this analysis.
                                         6-16

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                        Table 6.3-2
Summary of Projected Costs per Engine for Advanced Technology
Technology
Package
Direct
Water
Injection
SCR
Scope of
Standards
U.S. vessels
only
U.S. and
foreign
vessels
U.S. vessels
only
U.S. and
foreign
vessels
Cost Parameter
Total cost per engine
(yr. 1)
Total cost per engine
(yr. 6 and later)
Operating costs (NPV)
Total cost per engine
(yr. 1)
Total cost per engine
(yr. 6 and later)
Operating costs (NPV)
Total cost per engine
(yr. 1)
Total cost per engine
(yr. 6 and later)
Operating costs (NPV)
Total cost per engine
(yr. 1)
Total cost per engine
(yr. 6 and later)
Operating costs (NPV)
Medium-speed Engines
6cyl.
$119,105
$26,486
$55,912
$49,157
$26,486
$9,749
$241,160
$124,155
$435,240
$198,709
$124,155
$90,500
9cyl.
$139,153
$39,317
$84,029
$69,205
$39,317
$14,651
$335,899
$184,788
$642,579
$293,448
$184,788
$126,651
12 cyl.
$159,201
$52,148
$111,824
$89,253
$52,148
$19,497
$433,863
$247,485
$852,782
$391,412
$247,485
$163,302
Slow-speed Engines
4 cyl.
$156,579
$50,470
$111,824
$86,631
$50,470
$19,497
$435,153
$248,310
$861,574
$392,702
$248,310
$172,094
8 cyl.
$239,391
$103,469
$223,971
$169,443
$103,469
$39,051
$821,847
$495,795
$1,668,952
$779,396
$495,795
$312,868
12 cyl.
$319,582
$154,792
$335,794
$249,634
$154,792
$58,549
$1,208,542
$743,279
$2,504,036
$1,166,091
$743,279
$458,472
Composite
$188,617
$70,974
$153,887
$118,669
$70,974
$26,832
$579,647
$340,787
$1,161,373
$537,196
$340,787
$221,463

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Final Regulatory Support Document
Chapter 6 References

1."Emission Reduction Technology Costs for Category 3 Marine Diesel Engines," Draft Report
from Louis Browning et al, Arthur D. Little-Acurex Environmental, March 2002.

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.The methodology for calculating costs (or savings) related to changes in fuel consumption are
documented in "Estimated Cost Impacts of Changing Fuel Consumption Rates for Category 3
Marine Diesel Engines," EPA memorandum from Alan Stout to Docket A-2001-11, November
15, 2002 (Document IV-B-03).

4."SCR Economics for Diesel Engines," Ravi Krishnan, Diesel & Gas Turbine Worldwide, July-
August 2001 (Docket A-2001-11; document IV-A-04).

5. Bunker News, "Bunker Prices," www.bunkernews.com. October 23, 2002.

6. Bunker News, "Bunker Prices," www.bunkernews.com.
January 4, 2002 (Docket A-2001-11, document U-A-31).

1 Motor Ship., Annual Analysis, June 1999, pp. 49-50.

8. "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.
                                        6-18

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	Chapter 7: Inventory Baseline and Projections for Advanced Technology


     CHAPTER 7: Inventory Baseline and Projections for

                           Advanced Technology

   This chapter presents our analysis of emissions from Category 3 marine diesel engines. It
was developed under contract with E. H. Pechan & Associates, Inc.1  The first section contains a
description of the methodology used to develop the baseline emission inventories for the base
year (1996).  The second section contains a description of the methodology used to develop
inventory projections for future years. The next two sections contain the expected emission
reductions that would result from the long-term emission standards that reflect use of the
advanced technologies, both in the national inventories and on a per-vessel basis. We
investigated two advanced control scenarios: a 50 percent and an 80 percent reduction from the
standards we are finalizing.

   This chapter is devoted entirely to emissions from Category 3 marine diesel engines. Our
analysis of emissions from Category 1 and 2 marine diesel engines was done in support of our
1999 rulemaking and can be found in the Final Regulatory Impact Analysis for that rule.2

7.1 Baseline Inventories

7.1.1 Geographic Boundaries

   In developing emission inventories for Category 3 marine diesel engines, it is important to
consider the geographic area in which they operate.  This is important because, unlike other
nonroad engines like trucks or locomotives, marine vessels may not operate all of the time within
the U.S. air shed. Therefore, we need to determine what portion of their operating time occurs
within the U.S., during which they contribute to U.S. air quality problems.  For ships that operate
on the Great Lakes or inland waterways, our analysis counts all Category 3 marine diesel
emissions as occurring within the United States. For ocean-going vessels, we  count only
emissions that occur while the vessel is operating within 175 nautical miles from the U.S. coasts.
This 175-mile area is based on an estimate of the distance NOx molecules could travel in one day
(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, or 200 statute miles, from the  coast could reach the coast in less than a day).

   As noted in Chapter 2 and described in more detail below, the inventories were estimated in
two parts: in-port emissions are based on information for specific ports and are estimated for a
radius of 25 miles from port; non-port emissions are based on cargo movement data and cover
the area from 25 to  175 miles from the coasts.

   In our proposal we requested comment on the issue of pollutant transport and additional data
that would help us better understand the issue and thus develop a better estimate of how far off of
the coast we should be  considering. We received some comments in favor of using the 175

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Final Regulatory Support Document
nautical mile limit and no new data that would allow us to develop a better estimate.  Thus, for
the purposes of this analysis the 175 nautical mile limit will be used. However, in support of
future rulemaking efforts we plan to continue researching the pollutant transport issue in an effort
to better understand how offshore emissions affect air quality on land.

7.1.2 Ports Inventories

   For port areas we developed detailed emission 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 (ro ro)
tanker, vehicle carrier, and other miscellaneous vessels.

   Emission 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 vessel movement while in port (berthing or moving
from one berth to  another).  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.
                                           7-2

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	Chapter 7: Inventory Baseline and Projections for Advanced Technology

   The ports emissions were calculated by associating and summing the product of the 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 x Power x LF in mode x Time in mode x 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 7.1-1.

                                      Table 7.1-1
      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,
emission factors developed from emissions measured at full load were used as the cruise and
RSZ emission factors as well. However, at low loads the emission factors tend to increase as
compared with higher loads. The emission factors shown in Table 7.1-1 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.3  The adjustments we
applied to the emission factors shown in Table 7.1-1 to develop maneuvering emission factors
are shown in Table 7.1-2.

                                      Table 7.1-2
   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 7.1-3.
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                                       Table 7.1-3
         Total U.S. Category 3 Emission Inventories for Port Areas in 1996 (short tons)
HC
5,230
CO
1,944
NOx
101,137
PM
9,299
SOx 1
97,390 1
7.1.3 Non-Port Inventories

       We developed non-port emission 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
7.1.1 was moved by tow and push boats powered by Category 2 engines. Thus, with the
exception of California, 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 and, in
some cases likely that some Category 3 vessel traffic occurs within 25 nautical miles of the coast.
However, the data did not include the type or size of vessel that the cargo was being transported
on, only the cargo tonnage.  Thus, we were unable to discriminate between cargo carried on
Category 2 vessels and cargo carried on Category 3 vessels. 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.  Conversely,
excluding vessel traffic within 25 nautical miles of the coast likely excludes some Category 3
traffic. However, given that we could not separate  Category 2 traffic from Category 3 traffic we
needed to err on one side or the other. We believe that  excluding all non-port traffic within 25
miles of the coast gives us a more accurate estimate of non-port Category 3 emissions than
including it.

       The U.S. Army Corp of Engineers provided activity estimates of total and domestic
tonnage by waterway links.  A map of the waterway links is shown in Figure 7.1-1, 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 7.1.1 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 emission inventories for base year are shown in Table 7.1-4.
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          Chapter 7: Inventory Baseline and Projections for Advanced Technology

                                       Table 7.1-4
      Total U.S. Category 3 Emission Inventories for Non-Port Areas in 1996 (short tons)
HC
2,060
CO
4,186
NOx
88,837
PM
7,840
SOx 1
58,856 1
       We are fairly confident in the accuracy of our ports emission inventory estimates given
that they were developed from the ground up using accurate port call information as well as
information on vessels types, etc. However, our non-port inventory estimate contains a greater
level of uncertainty than the in-port inventory estimates due to the exclusion of most Category 3
vessel traffic within 25 nautical miles of the coast.  Thus, in support of future rulemaking efforts
we plan to continue  researching the non-port emissions issue in an effort to further refine our
non-port emission inventories.

7.2  Future Year Baseline Inventory Projections

       In order to project future year emission 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 internationally negotiated NOx emission limits 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 rely on 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 to show
the possible impact of long-term standards on emission inventories. Given that Category 3
vessels typically last for several decades before being scrapped it is 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.
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       In addition to the effects of increased freight tonnage and future changes in fleet makeup,
the effects of the internationally negotiated NOx limits 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. It is widely believed that most new vessels constructed beginning in 2000 have been built
in compliance with the internationally negotiated NOx limits.  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 internationally negotiated NOx limits.  The internationally negotiated NOx
limits are related to rated engine speed as shown in Table 1.1-1. This means that compliance
with the standards we are finalizing is incorporated into our baseline inventory, and we expect no
inventory benefits from our standards.

       These NOx emission limits are for vessels tested on distillate fuel.  However, Category 3
vessels use residual fuel in use.  The use of residual fuel results in higher emissions than the use
of distillate fuel, and using the NOx limits without correcting for differences in fuels would result
in underestimating actual in-use emissions from vessels complying with the internationally
negotiated NOx limits.  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 emission deterioration we used the actual internationally
negotiated NOx limits as the emission factors for future vessels in the growth projections.

       The projected future emission inventories for the port areas are shown in Table 7.2-1.
The non-ports inventory projections are shown in Table 7.2-2. Finally, the total national
inventory projections are shown in Table 7.2-3.

                                       Table 7.2-1
                            Projected Emission 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
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          Chapter 7: Inventory Baseline and Projections for Advanced Technology
                                      Table 7.2-2
                           Projected Emission 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
                                      Table 7.2-3
                             Projected Emission 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
7.3 Estimated Effects of Advanced Technology Standards on Inventories

       This section presents estimated NOx inventory reductions that could occur from
standards that reflect the advanced emission-control technologies described in Chapter 5.  We
examine two scenarios: standards set at 50 percent and 80 percent below the NOx standards we
are adopting in this rule (i.e., the internationally-negotiated NOx limits). Our estimated
inventory reductions are based on our current understanding of the U.S. fleet characteristics and
an effective date of 2007 for the new standards. We will revisit these estimates in our future rule.
We are not estimating the benefits of potential PM, HC, or CO standards, but will revisit
standards for those pollutants and associated inventory reductions in our future rule.

       To model the benefits of NOx standards that reflect application of the advanced
technologies, we applied an engine replacement schedule and the potential emission standards to
our inventory projections based on the standards we are finalizing in this rule (our baseline
inventory). For the purpose of estimating ship turnover rates, we used an average vessel age of
23 years.  This is based on a study done by Corbett and Fishbeck in support of our 1999 rule
which estimated the average age of the U.S. fleet as 23 years.4 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. vessels in 1999 was 24.2 years, with a median age of 22 years. The results of
this analysis are shown in Figure 7.3-1. It should be noted that the Corbett and Fishbeck study
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suggests that the average age of the world fleet is lower than that of the U.S. fleet, which would
result in a faster turnover rate in the U.S. fleet than the in the world fleet.  For the sake of this
study, however, we applied the U.S. turnover rate to all vessels, representing a worst-case
scenario.  We intend to revisit this issue in our future rule.

       Table 7.3-1 shows the Category 3 marine diesel engine NOx emission inventory estimates
for the two advanced technology standard scenarios, a 50 percent and 80 percent NOx reduction
from the levels we are finalizing in this rule, applied to U.S. vessels only and to foreign vessels.
According to these estimates, standards that reflect a 50 percent reduction from the standards we
are finalizing in this rule would result in an additional 2 percent reduction by 2030 when applied
to Category 3 marine diesel engines on U.S. vessels only, and an additional 43 percent reduction
when applied to Category 3 marine diesel engines on all vessels that enter U.S. ports. Standards
that reflect an 80 percent reduction from the standards we are finalizing would result in an
additional 4 percent reduction by 2030 if applied to Category 3 marine diesel engines on U.S.
vessels only and nearly 70 percent reduction if applied to Category 3 marine diesel engines on all
ships that  enter U.S. ports.  The reductions associated with all vessels would be even larger if a
faster vessel turnover is assumed.

       These estimates illustrate the importance of applying advanced technology standards to
engines on the broad group of vessels that use U.S. ports.

                                       Table 7.3-1
                    Estimated 2030 Emission Inventories under Various
                   Scenarios of Applying Long-Term Emission Standards
Scenario
Baseline (Annex VI)
50% Reduction— U.S.
vessels only
50% Reduction— All
vessels
80% Reduction— U.S.
vessels only
80% Reduction— All
vessels
2020
NOx
(1000 tons)
367
360

266

355

204

percent
reduction
--
2.1%

27.7%

3.4%

44.6%

2030
NOx
(1000 tons)
531
519

301

511

160

percent
reduction
--
2.3%

43.3%

3.7%

69.8%

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Chapter 7: Inventory Baseline and Projections for Advanced Technology

                          Figure 7.3-1
                         Table 7.3-2
        Number of Category 3 Vessels in the U.S. Fleet by Age
Age (years)
0-9
10-19
20-29
30-39
40-49
50+
Number of vessels
32
65
130
40
11
15
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7.4  Per-Vessel Emission Reductions

       This section describes our estimates of the emission reductions over the lifetime of an
average vessel for the two scenarios discussed above. These scenarios are a 50% reduction
beyond Tier 1 based on water injection and an 80% NOx reduction beyond Tier 2 based on
selective catalytic reduction. Under the 80% reduction scenario, we consider the use of distillate
fuel to be necessary to enable the use of SCR technology.  Therefore, we calculate reductions in
PM (primarily direct  sulfate PM) and SOx emissions due to the use of distillate fuel with a sulfur
content of 1.0% rather than residual fuel with a sulfur content of 2.7%.

       To calculate the baseline per vessel annual emissions, we divide the total emissions
inventory presented in section 7.2 by our estimates of the number of vessels presented in Chapter
3.  Emission reductions are determined by applying a percent reduction to the baseline emissions.
Lifetime reductions are presented in Table 7.4-1 for applying future standards to U.S. vessels
only and for applying future standards to all vessels. The emission reductions are discounted at
7% and are based on  the useful life discussed in section 7.3. Note that lifetime reductions are
lower for the entire fleet than for U.S. vessels.  This is because we only count the emission
reductions within 175 miles of the U.S. coast. We estimate that the average U.S. vessel spends
about six times as much operation near our coast than the average foreign vessel.

 Table 7.4-1:  Discounted Per Vessel Lifetime Emission Reductions Beyond Tier 1 [short tons]

50% Beyond Tier 1
80% Beyond Tier 1
Pollutant
NOx
NOx
PM
SOx
U.S. Vessels Only
639
1,022
32
451
All Vessels
112
179
6
79
7.5  Cost Per Ton

       Because we are not adopting long-term standards at this time, we have not calculated cost
per ton estimates for the future approaches. However this discussion gives guidelines on how
calculations could be made to provide information to facilitate comparison of options we will
consider in the future rulemaking.  We will re-evaluate the costs and emission reductions of
specific standards and emission-control technologies when we propose the long-term standards.

       The cost per ton is generally the per-engine costs divided by the per-engine emission
reductions. This analysis would examine 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.  This cost information is provided in Chapter 6 and the and emission information is provided
above. In calculating net present values that were used in our cost per ton estimates, we
generally use discount rates of 7 percent and 3 percent.  OMB Circular A-94 directs us to
generate benefit and cost estimates reflecting a 7 percent rate.  The 3 percent rate is consistent
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	Chapter 7: Inventory Baseline and Projections for Advanced Technology

with that recommended by the Science Advisory Board's 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).
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Chapter 7 References

1.  "Commercial Marine Emission Inventory Development," E.H. Pechan and Associates, Inc.
and ENVIRON International Corporation, April, 2002. Air Docket A-2001-11, Document No.
II-A-67.

2.  "Final Regulatory Impact Analysis: Control of Emissions from Marine Diesel Engines," U.S.
EPA, November 1999.  Air Docket A-2001-11, Document No. IV-A-05.

3. "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. Air
Docket A-2001-11, Document No. II-A-64.

4. "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. Air Docket A-2001-11,
Document No. U-A-65.
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                                                           Chapter 8: Test Procedure
                      CHAPTER 8:   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 specified in this rulemaking for the Tier 1
standards. It also includes information related to test procedure issues discussed in the Draft
Regulatory Support Document and likely to be considered again in the process of setting Tier 2
standards.

8.1  Certification Test Procedures

       We are specifying MARPOL NOx Technical Code (NTC) engine test procedures with
some modifications. These modifications are described in Section 8.1.4. Other sections describe
issues such as the duty cycle, test fuel and sampling procedures, which are not significantly
different from the NTC requirements.  These procedures will be required for certification testing.
We may allow other procedures to be used in the future if we adopt production testing and in-use
testing requirements.

8.1.1  Duty Cycle

       We are specifying the same duty cycles as are used for testing NOx emissions under the
NTC requirements.  These test cycles are designated by the International Organization for
Standardization (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 8.1-1 presents duty cycles for main drive engines as
discussed above.
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                                         Table 8.1-1
                                 Test Cycle Types E2 and E3
Test Cycle Type E2a
Speed
Power
Weighting Factor
100%
100%
0.2
100%
75%
0.5
100%
50%
0.15
100%
25%
0.15
Test Cycle Type E3b
Speed
Power
Weighting Factor
100%
100%
0.2
91%
75%
0.5
80%
50%
0.15
63%
25%
0.15
 aE2: 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
8.1.2 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. However they can also burn distillate fuel. In order to harmonize with
the NIC testing provisions in the near term, we are specifying distillate fuel for Tier 1 testing.
However, this section provides additional information regarding residual fuels, and discusses
why we may need to specify one or more residual fuels when we consider more stringent
standards in the future.

       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 8.1-2 summarizes current ASTM standards for a
marine distillate oil, residual fuel,  and these two common IF blends.
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                                                            Chapter 8: Test Procedure
                                       Table 8.1-2
                         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
20b
0.15
5
IF 380
RMH-35
991
-710
380
35
22b
0.2
5
Residual fuel
RML-55
no max
—
—
55
no max
0.2
5
       Ramsbottom test
       Conradson test
       The use of residual fuel has two important consequences. First, it is more difficult to
handle.  Because of its 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 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). Based on the currently available information, it is
appropriate to assume 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 amount of NH3 or N2O would be produced. The primary
uncertainty is related to the formation of elemental nitrogen (N2). One commenter suggested that
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some of the combustion occurs at equilibrium conditions, where a significant fraction of the fuel-
bound nitrogen would be converted to N2.

       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.

       We recognize that the effects of fuel-bound nitrogen are not yet fully understood, and we
are not aware of any accurate corrections for fuel effects other than the effect of fuel nitrogen.
Thus we believe that it is appropriate to specify distillate fuel as an interim provision limited to
Tier 1 testing.  However, we believe that for the longer term, it will probably be necessary to base
our standards on more representative test fuels.  We expect to work with manufacturers to
develop more accurate corrections for nitrogen and other fuel effects.

8.1.3 Sampling Procedures and Calculations

       The NTC 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 analyzer.
CO2 concentrations are measured using a Non-Dispersive Infrared analyzer.  These analyzers are
the same as the analyzers specified by EPA for other nonroad standards.

       The NTC 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.

8.1.4 Modifications to the NOx Technical Code Test Procedures

       We are adopting test procedures with several modifications and additions relative to the
NTC test procedures to better ensure that the emission measurements will accurately represent
in-use performance. We require that inlet air and exhaust restrictions be set at the average in-use
levels.  Similarly, engine coolant and engine oil temperatures must be equivalent to the
temperatures that will  occur in-use under ambient conditions identical to the test conditions.
Measurements must be valid only 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.  Manufacturers
may measure emissions within larger discrepancies, but may not use those measurements  to
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                                                           Chapter 8: Test Procedure
demonstrate compliance with these regulations.  The NTC procedures allow manufacturers
significantly more discretion with respect to these parameters.

       The NTC 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 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. Exhaust flow rates must therefore be calculated
using measured fuel flow rates.

       The duty cycle used for NTC testing specifies the test points based on the manufacturer's
specified rated speed. We have concerns  about the subjective nature of the NTC requirement and
believe that the test cycle needs to be defined more objectively. Test cycles must therefore be
denormalized based on the maximum test speed described in §94.107, which is derived from the
lug curve for the engine. This maximum test speed is not intended to fundamentally change the
test procedure, but merely makes the procedure less subjective. We are including an option for
manufacturers to use the maximum in-use engine speed for governed engines.

8.2    Shipboard NOx Emission Measurement System

       We proposed that Category 3 diesel engines have a direct exhaust NOx monitoring
system. This system was to be used to verify that engines are adjusted properly in use. It could
also be used for production testing.  We are not finalizing this requirement for Tier 1, but expect
to adopt such a requirement when we consider more  stringent standards in the future.

       Category 3 engines typically have  fuel injection timing and other  adjustments that are
optimized to accommodate a range of fuel qualities and environmental conditions.  Since these
engine adjustments also affect NOx emissions, it would be valuable to have a shipboard means of
monitoring NOx to ensure that the engine is adjusted to remain in 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. Onboard measurements
would also be necessary for other treatment technologies that can be adjusted to operate at
different emission-control efficiencies,  such as water injection. Another  one of the reasons we
proposed to require these measurement systems was to enable operators to effectively turn
emission controls off under certain conditions by adjusting the engine.

       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 with emission limits (or targets) for an engine's operating conditions. These targets
would be determined by the engine manufacturer, and would vary with operating conditions and
fuel quality.  The system would display the NOx concentration and the respective specified

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Final Regulatory Support Document
emission limit at the engine control room. This kind of system 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 should 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, it should be designed to require tedious calibration or frequent maintenance, since that
would likely discourage operators from using it properly.

       The system should 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.

8.2.1 System Description and Component  Specifications

       The NOx monitoring system that we proposed consisted of several components, and the
system is illustrated in the figure below.
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                                                          Chapter 8: Test Procedure
                                     Figure 8.2-1
                     Stack
                           N
                 Engine Room
                       •*	
Analyzer Exhaust
      •«-
                                                       .Cable.
                                                 \
                                                   NO Analyzer
                                    Sample Conditioning
                                    System (as required)
               Engine
                                                                  Control Room
                                                                          Display/
                                                                     /Controller  /
                                                                   /      	i.
                                                                            Data
                                                                          Recorder
       8.2.1.1 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 each fuel injection pump and after-cooler may be adjusted individually on a
typical Category 3 engine. 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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Final Regulatory Support Document
(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.

       8.2.1.2 Sample conditioning system

       Depending on which NOx detection method is used, a sample conditioning system may
be needed.  The sample conditioning system could 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.

       8.2.1.3 NOx Analyzer

       To quantify total 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 (20) 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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                                                            Chapter 8: Test Procedure
system. Analyzer manufacturers would have to use care when selecting certain materials and
detectors for use in this application.

       Analyzers based on chemiluminescent, non-dispersive ultra-violet, zirconia cell, or
Fourier transform infra-red measurement techniques could likely work for shipboard use.
However, the instrument manufacturer would have to ensure that an analyzer meets the necessary
specifications. 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 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.

       8.2.1.4 Programmable Controller

       A programmable electronic controller should be able to 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.

       8.2.1.5 Engine Control Room Display

       In a well-designed system, an engine control room display would probably 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.

       8.2.1.6 Data Recorder

       To make the system reliable as an enforcement tool,  a data recorder would be needed to
permanently document all of the NOx monitoring system's measured and calculated parameters,

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Final Regulatory Support Document
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.

8.2.2   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 will likely
need to require the engine manufacturer to develop NOx-ppm emission targets for each set of
conditions if we adopt in a future rule the kind of adjustability allowances that we proposed.
These targets would be indicative of equivalent emission-control performance.

       Equivalent emission-control performance could be defined relative to optimal engine
performance that could be achieved in the absence of emission standards (i.e., the calibration that
result in the lowest fuel consumption and/or maximum firing pressure). This approach would
work for NOx controls in which there would be a tradeoff between NOx emissions and fuel
consumption rates. The  most obvious example of this would be fuel injection timing. In this
case, equivalent performance could mean the same  percent reduction in NOx emissions from the
optimal calibration as is  achieved under the test conditions. Alternatively, the manufacturer
could achieve equivalent performance by specifying that the timing be retarded the same number
of degrees from the optimal calibration as was done under the test conditions. In this alternative
approach, the calibration would be conceptually equivalent to a mechanically-controlled engine.
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Chapter 8 References


1.  International Organization for Standardization, 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 Organization for Standardization, 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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