Summary of ICCR Source Work Group Meeting
September 18, 1997
Internal Combustion Engines Work Group Meeting
I. Purpose
The main objectives of the meeting were to select a co-chair
and alternate for the RICE WG, assess the progress of each of the
subgroups and identify new tasks which need to be addressed by
the work group.
II. Location and Date
The meeting was organized by the Environmental Protection
Agency (EPA) and was held at the Omni Hotel in Durham, North
Carolina. The meeting took place on September 18, 1997.
III. Attendees
Meeting attendees included representatives of the OAQPS
Emission Standards Division, trade associations, universities,
and state agencies. A complete list of attendees, with their
affiliations, is included as Attachment I.
IV. Summary of Meeting
The meeting consisted of discussions between WG members on
selected issues which are listed below. The order of the meeting
followed the agenda provided in Attachment II. A bullet point
summary of the meeting is presented as Attachment III.
The topics of discussion included the following:
Selection of Co-Chair and Alternate
Highlights of the Recent Coordinating Committee Meeting
Emissions Subgroup Report on Test Plan
Population Subgroup Report on MACT Floor
WG Development of Recommendations to Move from MACT Floor
and Test Plan to MACT Standard
Identification of Next Steps and Formation of Subgroups
Next Meeting
Selection of Co-Chair and Alternate
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Since the request at the last WG meeting for feedback on a
new co-chair and a new alternate, Amanda Agnew received no
suggestions from the Work Group. Consensus was reached on Vick
Newsom to continue as Work Group Co-Chair and Sam Clowney to
proceed as Co-Chair Alternate.
Highlights of the Recent Coordinating Committee Meeting
Vick Newsom relayed highlights from the Coordinating
Committee Meeting and the Dioxin Primer. The flash minutes for
the CC Meeting and the slides for the presentation of the Dioxin
Primer can be downloaded from the TTN.
One important highlight of the Dioxin Primer, pointed out by
Vick Newsom, is that the information presented by Randy Seeker
shows that there is very low to moderate potential for dioxin to
be formed by IC engines.
A Tracking Subgroup was formed on the Coordinating Committee
to track the progress of each of the source work groups. They
will require a timeline of the RICE WG's activities and
deadlines.
The Information Collection Request (ICR) was recently
completed. Engine emission data was one aspect covered by the
ICR. However, the data collected may be ambiguous, due to vague
wording on the ICR form regarding HAP emissions data.
The dates for the future CC Meetings are tentatively
scheduled as follows:
2/24-25 Greensboro, NC
4/28-29 Colorado
7/21-22 California
9/22-23 Raleigh, NC
12/8-9 Houston, TX
Emissions Subgroup Report on Test Plan
Sam Clowney presented a report on the RICE Test Plan drafted
by the Emissions Subgroup. A copy of this presentation is
included as Attachment IV. A copy of the Draft Test Plan under
discussion, which was sent out prior to the meeting, is included
as Attachment V. Laura Kinner of EMI also made a presentation
regarding the comments received on the pollutant lists, and it is
included as Attachment VI.
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The topics of discussion which followed included the basis
for testing, the focus of testing, the applicability of the test
plan to MACT floor determination, and the pollutant list.
Basis for Testing
Amanda Agnew raised the concern that the Coordinating
Committee will ask why testing is even necessary when there are
existing emissions test reports available in the RICE emissions
database. Sam Clowney responded that these test reports were
inadequate, since they lack documentation of engine engineering
parameters during testing. It was brought to a consensus that
another appendix should be added to the Test Plan, giving
justification for additional testing instead of using the
existing data.
Focus of Testing
Bill Passie stated that the chosen engines for the Test Plan
should reflect the distribution of engines in the RICE Population
Database. Several WG members agreed with this statement. Ed
Torres felt that the testing priority should reflect the
tendencies of the MACT floor. The current number one engine to
be tested in the Test Plan is a Clark TLA Turbocharged engine,
which represents the 2-stroke gaseous fuel subcategory. The
subcategory which currently reflects a MACT floor is four stroke
rich burn gaseous fuel.
Ed Torres also disagreed with the statement under section
2.2 of the Test Plan. The wording states that "The efficiency of
the control devices tested for natural gas will be achievable by
the other gaseous fuels." Ed Torres argued that catalytic
control for digester gas fired engines may not be technically
feasible. Fouling of the catalyst can occur at a very high rate
when applied to digester gas fired engines. Other members also
disagreed with the wording under section 2.2. Bryan Willson
stated that the catalyst should do the same job for digester gas
as for natural gas until the catalyst starts fouling. He noted
that the current Test Plan does not address performance over time
or fouling. Maintenance and operating issues will not be
addressed in the current Test Plan. It was decided by the WG
that Ed Torres should submit suggested language for section 2.2
of the Test Plan, addressing the concern about digester gas. Sam
Clowney requested that Ed Torres provide data to support his
statement that oxidation catalysts may not work well on units
fired by digester gas. The Emissions Subgroup will determine how
to modify the Test Plan once the data is reviewed.
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Amanda Agnew inquired whether or not engines would be tested
before and after control devices. Sam Clowney confirmed that
both before and after control devices would be tested for all
engines in the Test Plan.
Applicability of Test Plan to MACT Floor Determination
The priority of MACT floor determinations were presented by
Reese Howie. These were as follows:
1) Set a numerical emission limit (the basis of which is a
control technology). This provides greatest
flexibility for all sources.
If number one is infeasible, then
2) Set a performance standard (a percent reduction in
emissions across the board, regardless of the current
emissions of any particular source).
If number two is also unattainable, then
3) Set a control device standard, (e.g. oxidation
catalyst). This is not ideal, since regardless of the
emission level, a certain control device would be added
across the board for all engines in this subcategory.
Linda Coerr stated that the Emissions Subgroup developed the
Test Plan to look at efficiencies of possible MACT control
devices. In this sense, the current Test Plan focuses on a
performance standard (the second priority stated above). If the
primary focus of the WG is to set a numerical emission limit, the
Test Plan's focus should be reconsidered. Linda Coerr noted that
the Emissions Subgroup has not discussed the possible use of the
results from the testing to set a numerical emission limit as
MACT.
Pollutant List
With regards to metals, J. Darrell Bowen questioned whether
fuel testing would be sufficient to account for emissions of
metals from IC engines. Laura Kinner indicated that an in-stack
metals test would take two to four hours to conduct, and
suggested that such testing would not be practical given the
operating test matrix that the WG is proposing. Laura Kinner
stated that particulate matter from sources often indicates the
presence of metals.
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With regards to chlorinated compounds, the WG discussed the
possibility that the compounds are reported in the laboratory
test results due to laboratory contamination, not presence of
these compounds in the IC engine exhaust. Laura Kinner noted that
methylene chloride was consistently reported in the highest
concentrations out of all of the chlorinated compounds. She also
pointed out that methylene chloride is a common contaminant in
laboratory analyses, since it is often used to clean glassware
and is in the ambient air of many laboratories. Wayne Hamilton
added that in his experience at Shell, the labs indicated that
methylene chloride is a contaminant present in the lab and it is
very difficult to keep methylene chloride from getting into any
sample that is analyzed in a lab. Laura Kinner suggested that it
is therefore best to use a direct interface method of analysis,
such as the GC/MS, to prevent contamination from laboratories
rather than the laboratory method of TO-14. A GC/MS method would
draw the sample directly from the stack and analyze the sample
on-site. Laura Kinner also suggested that as a compromise, the
RICE WG could add methylene chloride only to the list of
pollutants, since it was the greatest detected chlorinated
compound. Amanda Agnew asked about the cost for testing
chlorinated compounds. Laura Kinner responded that chlorinated
compounds can be tested on the GC/MS at little additional cost.
It is only a matter of calibrating the machine to look for these
pollutants, and this cost is nominal compared to the cost of the
entire test. Michael Horowitz stated that methylene chloride is
the chlorinated compound of principal concern, since it is the
only chlorinated compound that was reported above the detection
limit in more than one test.
With regards to particulate matter, the WG discussed the use
of Method 5 for detecting particulate matter. Representatives
from the Engine Manufacturer's Association suggested that Method
5 is inappropriate for the Test Plan. The EMA representatives
suggested that the WG consider a real-time test method, such as
the Sierra or the ISO method. Laura Kinner noted that sampling
for Method 5 can take several hours, which may be impractical
given the operating test matrix that the WG has proposed.
Bryan Willson presented Dick Van Frank's data on mercury
emissions from landfill gas fired engines. Two tests were
performed on the Fresh Kills Landfill in Staten Island, New York,
for mercury in June of 1996. The first report reflected
emissions of roughly 300 pounds per year, and the second
reflected emissions of about 2.3 pounds per year. Reasoning for
this discrepancy was not explained in the reports.
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Population Subgroup Report on MA.CT Floor
Wayne Hamilton presented a report on the Population Subgroup
activities. This is included as Attachment VII. The basis for
discussion was the handout that was emailed out prior to the
meeting, entitled "Population Subgroup Topics to be Discussed at
the September 18 Meeting," and it is included as Attachment VIII.
The topics of discussion which followed included the statistical
adequacy of the data, feasibility of engine subcategorization,
blanks and anomalies in the control device field, engine
efficiencies, and providing the RICE Population database to the
RICE WG.
Statistical Adequacy of the Data
Wayne Hamilton noted that the Population Subgroup needs
assistance in determining whether the data in the Population
database is representative of the existing population of engines.
He suggested that one possible solution is to have an EPA or
industry statistian review the database. EPA has agreed to look
into this issue since it will affect all source work groups.
Some WG members regarded the data in the Population Database as
not representative of the real world.
Bryan Willson stated that the numbers presented in the RICE
Population Database, which reflects that four stroke engines are
twice as populous as two stroke engines, are inaccurate. This
number should reflect that four stroke engines are ten times as
populous as two stroke engines.
Charles Elder stated that Power Systems Research has a
database of combustion sources, and suggested that the RICE WG
compare the RICE population database with that of Power Systems
Research.
It was suggested that a comparison also be performed between
the API database and the RICE population database. Vick Newsom
felt this would not be a good comparison, since API did not
consider any engines below 150 HP. Wayne Hamilton will contact
Glenda Smith of API to set up a meeting between her and
Alpha-Gamma, to see how the databases compare.
Bill Passie stated that Oil and Gas Production was too
highly represented in the RICE Population Database, based on
numbers presented on SIC distributions.
WG members decided that a breakdown by industry for each
state and a horsepower distribution by fuel type would each
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provide a better look at the statistical representation of the
RICE Population Database. This work will be performed by
Alpha-Gamma before the next WG meeting.
Feasibility of Engine Subcategorization
Many work group members voiced their opinions that it was
premature to determine engine subcategories, based on the general
consensus about the lack of data in the current RICE Population
Database.
Vick Newsom stated that since the population numbers are not
currently representative of the real world, MACT should be based
on strictly liquid or gaseous fuels.
Ed Torres requested that Alpha-Gamma further subcategorize
the spark ignition gaseous fuel fired engines by specific fuel
type. This would assist the WG in better understanding the
application of control technologies to each fuel type.
Blanks and Anomalies in the Control Device Code Field
Consensus was reached on the issue of blanks being no
controls, based on the information presented in the handout
emailed out prior to the meeting.
It was noted by engine manufacturers that many control
devices presented from the database did not make intuitive
technical sense. During lunch, Chuck Elder and Bob Stachowicz,
with the consensus of the other engine manufacturers present,
went through the control devices presented for spark ignition
engines and marked those of which made no sense as actual control
devices for reciprocating internal combustion engines.
Engine Efficiencies
Bill Passie brought up the possibility that the engine
efficiencies that were used for the HP distribution/unit
conversion may be inaccurate, since the numbers presented
demonstrate that rich burn engines are more efficient than lean
burn engines. Alpha-Gamma was assigned to research this topic
before the next meeting.
Provide RICE Population Database to RICE WG
The RICE WG came to a consensus that the RICE Population
database should be uploaded to the TTN by October 1st. This will
be performed by Alpha-Gamma Technologies.
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WG Development of Recommendations to Move from MACT Floor and
Test Plan to MACT Standard
The WG had a brainstorming session on this topic. The
results are listed below:
Existing Source MACT
Determine subcategories
Determine definition of "source"
Identify applicable control technology and availability (Is
the technology available only for certain subcategories or
sizes of engines?)
Identify possible work practices
Develop model units to evaluate cost-effectiveness of
controls and work practices
Determine effects of controls and work practices on HAP
emissions (some pollutants increase, some pollutants
decrease, some stay the same)
Determine emission reductions achievable with control
technology and work practices
Determine typical emissions for each subcategory
Determine costs for applicable control technology
Determine durability/life/feasibility of controls
Determine which pollutants will be regulated under MACT
Develop the test protocol to go with the MACT standard
(baseline and as-controlled)
Determine compliance monitoring, inspection, reporting and
recordkeeping requirements
Determine size cutoffs
Determine national impacts - total number of regulated
sources
New Source MACT
Identify applicable control technology and availability
(must be demonstrated in full-scale application)
Determine MACT floor for new sources (best performing
similar source)
Determine if new source MACT should be equivalent to
existing source MACT
Evaluate impact of standards for criteria pollutants at time
MACT is promulgated
Define criteria for "new source" - if move an existing
engine, is that a new source?
Address pollutant tradeoffs - what is the best performing
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similar source when there are multiple pollutants - is it
the one with the least formaldehyde, the least PAH, or the
least total HAPs?
Identification of Next Steps and Formation of Subgroups
Emissions Subgroup
Before the next meeting, the Emissions Subgroup will add
three appendices to the Test Plan. These will be 1) a commentary
on the review of the existing emissions database, including why
additional testing is needed; 2) the test protocol; and 3) a
response to comments. The Emissions Subgroup will respond in
writing to issues provided by WG members, and will provide the
revised Test Plan to the WG before October 30th.
Other issues of focus for the Emissions Subgroup are the
following: l)cost effectiveness, based on efficiency of controls,
typical emissions, and cost of controls; and 2)identification of
applicable control technologies.
Population Subgroup
Before the next meeting, the Population Subgroup will:
1. Eliminate unrealistic control devices in the RICE database
2. Draft a MACT Floor, including determination of subcategories
3. Compare the EPA database with the Power Systems Research
database
4. Provide the RICE database to the WG by October 1
5. Compare the EPA database with the American Petroleum
Institute database
Other issues of focus for the population subgroup will include
model plants and inventories.
New Source MACT Subgroup
To address the issue of new source MACT, a new subgroup was
formed, called the New Source MACT Subgroup. It will be headed
by Bill Passie, and its members will include Bryan Willson and
Mike Brand. The focus of this group will be to identify
pollutant tradeoffs (determining the best performing similar
source when there are multiple pollutants), and to identify the
best existing control.
Schedule Subgroup
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In order to accommodate the CC Tracking Subgroup's needs, a
Schedule Subgroup was formed, headed by Amanda Agnew. Members
will include the chairs for each of the other subgroups: Sam
Clowney, Wayne Hamilton and Bill Passie. They will determine the
timeline for all RICE WG activities, and correspond with the
Tracking Subgroup of the Coordinating Committee.
Other Issues
Amanda Agnew mentioned that a Satisfaction Survey for the
ICCR has been submitted for response from the entire ICCR. Work
group members can submit their surveys to Amanda Agnew by
September 30, 1997. This survey was provided to the WG as a
handout, and is available through Amanda Agnew.
John Blair also gave notice that he can no longer serve as a
RICE WG Member. Amanda Agnew pointed out that there is no longer
any environmental group representation on the WG, and requested
input from the WG concerning this matter.
Next Meeting
The next Internal Combustion Work Group Meeting will be in
Chicago, IL on Thursday, October 30, 1997, starting at 9:00 a.m.
EST. The meeting will run until 4 p.m., and there will be a
working lunch. On the agenda for the next meeting are the
following topics:
* Presentation by Population Subgroup on MACT floor
* Reach consensus on the subcategorization and MACT floor
* Presentation by Emissions Subgroup on Test Plan
* Reach consensus on Test Plan and appendices, (including
dioxins, mercury, metals and chlorinated hydrocarbons)
* Presentation by Schedule Subgroup on timeline/Tracking
Subgroup requirements
* Next Steps
These minutes represent an accurate description of matters
discussed and conclusions reached and include a copy of all reports
received, issued, or approved at the September 18, 1997 meeting of
the Reciprocating Internal Combustion Engines Work Group.
Amanda Agnew
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ATTACHMENT I
LIST OF ATTENDEES
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Stationary Internal Combustion Engines Work Group Meeting
September 18, 1997
List of Attendees
Amanda Agnew
Alec Atanas
Darrell Bowen
Michael Brand
Sam Clowney
Donald Dowdall
Charles Elder
Wayne Hamilton
William Heater
Michael Horowitz
Jed Mandel
Jay Martin
EPA OAQPS Emissions Standards Division
Englehard Corporation
CNG Transmission Corporation
Cummins Engine Co., Inc.
Tenneco Energy
Engine Manufacturers Association
General Motors Corporation
Shell E&P Technology Company
Cooper Energy Services
U.S. Environmental Protection Agency
Engine Manufacturers Association
University of Wisconsin-Madison
Michael Milliet Texaco E&P Inc.
Vick Newsom
William Passie
Donald Price
Bob Stachowicz
Ed Torres
Bryan Willson
Jan Connery
Reese Howie
Amoco Production Section
Caterpillar, Inc.
Ventura County Air Pollution Control District
Waukesha Engine Division
Orange County Sanitation District
Colorado State University
Eastern Research Group
Alpha Gamma Technologies
Jennifer Snyder Alpha Gamma Technologies
Linda Coerr Coerr Environmental
Jim Wright Testing and Monitoring Protocol Work Group
Pamela Lacey American Gas Association
Laura Kinner EMI
I - 1
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Mahesh Gundappa Radian International
Jim McCarthy GRI
1-2
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ATTACHMENT II
SEPTEMBER 18, 1997 MEETING AGENDA
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Agenda
Reciprocating Internal Combustion Engine Work Group
September 18,1997 WG Meeting - Durham, NC
8:00-8:15 Welcome, Meeting Goals (A. Agnew)
Agenda Review (J. Connery)
Meeting Goals:
1. Selection of Co-chair and Alternate
2. Population Subgroup:
-Agreement on MACT Floor
-Identification of Questions about MACT Floor that Need to be Addressed before
Presentation to CC in November
3. Emissions Subgroup:
-Agreement on Test Plan
-Identification of Questions about Test Plan that Need to be Addressed before Presentation
to CC in November
8:15 - 8:30 Selection of Co-Chair and Alternate
8:30 -8:45 Outcome of the CC Meeting (V. Newsom and A. Agnew)
- Dioxin Primer as it applies to engines
8:45 - 9:00 Review of MACT Floor Timeline (W. Hamilton)
9:00 - 9:30 Emissions Subgroup Report on Test Plan and WG Feedback on Issues (S. Clowney)
9:30 -10:00 Population Subgroup Report on MACT Floor and WG Feedback on Issues (W. Hamilton)
10:00-10:15 BREAK
10:15-11:30 WG Discussion of Remaining Issues on MACT Floor and Test Plan
11:30- 12:45 LUNCH
12:45 - 2:45 WG Development of Recommendations to Move from MACT Floor and Test Plan to MACT
Standard for IC Engines
- Overview of ICCR Schedule for MACT Development (A. Agnew)
- MACT Standard Scenarios (A. Agnew and S. Clowney)
- Tools to Evaluate Scenarios and Backup Materials Required for MACT
2:45 -3:00 BREAK
3:00 - 4:00 WG Development of Recommendations to Move from MACT Floor and Test Plan to MACT
Standard for IC Engines (continued)
4:00- 4:30 WG Identification of Next Steps and Formation of New Subgroups
4:30 - 4:45 Next Meeting (A. Agnew and J. Connery)
- Schedule
- Tentative agenda items
4:45 - 5:00 Review of Flash Minutes (J. Connery and J. Snyder)
5:00 ADJOURN
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II - 2
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ATTACHMENT III
BULLET POINT SUMMARY
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Summary of ICCR Source Work Group Meeting, September 18,1997
Internal Combustion Engines Work Group Meeting
Omni Hotel, Durham, NC
Decisions
Consensus on keeping the current co-chair and alternate, Vick Newsom and Sam Clowney.
Consensus on assuming that blanks = no control device in the Population database.
A New Source MACT Subgroup was formed, headed by Bill Passie. Its members will include Mike Brand and
Bryan Willson. Others will be recruited.
A Schedule Subgroup was formed, headed by Amanda Agnew. Its members will include the heads of the other 3
subgroups, Bill Passie, Sam Clowney and Wayne Hamilton.
The RICE WG will ask the Coordinating Committee to pass on ICE HAP data/emissions data collected from the
Information Collection Request.
Next Meeting
The next Internal Combustion Work Group Meeting will be held in Chicago, IL on Thursday, October 30, 1997
from 9:00 a.m. to 4:00 p.m. CST. (There will be a working lunch.)
On the agenda for the next meeting are the following:
*Presentation by Population Subgroup on MACT floor
*Reach consensus on the subcategorization and MACT floor
*Presentation by Emissions Subgroup on Test Plan
*Reach consensus on Test Plan and appendices, (including dioxins and mercury)
*Presentation by Schedule Subgroup on timeline/Tracking Subgroup requirements
*Next Steps
For Your Information:
The 1998 CC Meetings are tentatively scheduled as follows:
2/24-25 Greensboro, NC
4/28-29 Colorado
7/21-22 California
9/22-23 Raleigh, NC
12/8-9 Houston, TX
Action Items
WG: feedback on ICCR Satisfaction Survey to Amanda Agnew by September 30.
WG: keep a lookout for environmental representation for the RICE WG
Emissions Subgroup: Add 3 appendices to the Test Plan:
*review of database
*test protocol
*response to comments
Provide this revised Test Plan to the WG by 10/30/97.
Population Subgroup: Get rid of nonsense controls in subcategory breakdown of control devices
Population Subgroup: Determine preliminary MACT floor (and subcategories). Provide to WG in writing by
10/23/97.
Population Subgroup: Compare RICE Database with Power Systems Research Database.
Population Subgroup: Provide cleaned up database to WG on TTN by 10/1/97.
Population Subgroup: Compare RICE Database with API Database. (Glenda Smith)
Ed Torres: Provide footnote for Section 2.2 of Test Plan regarding applicability/efficiency wording as applied to
Digester Gas and Natural Gas.
Alpha-Gamma: Check on efficiencies given for Rich Burn and Lean Burn engines
Alpha-Gamma: Horsepower distribution by fuel type (Diesel vs. Natural Gas, and past 2/4 stroke, rich/lean burn)
Alpha-Gamma: Provide diesel fired engine control devices to WG
Alpha-Gamma: Provide combined Geographical and Industrial distribution to WG
S. Clowney and A. Agnew: Determine deliverables for subgroups
V. Newsom: Provide status report to CC by 11/3/97.
Ill - 1
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ATTACHMENT IV
REPORT ON THE RICE TEST PLAN FROM THE EMISSIONS SUBGROUP
PRESENTED BY SAM CLOWNEY
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RICE Test Plan
presented to:
Reciprocating IC Engine Work Group
Durham, North Carolina
presented by:
Sam Clowney, Tennessee Gas Pipeline,
on behalf of the Emissions Subgroup
September 18,1997
iv - 1
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RICE Test Plan
Ķ Components of the Test Plan:
1 Engines, Fuels, and Emission Controls to be Tested
2 Matrix of Operating Conditions to be Tested
3 Pollutants to be Measured During testing
4 Test Methods to Quantify Emissions
5 Prioritization
Ķ Draft Test Plan Complete
distributed to Work Group on Monday, September 15, 1997
intent of draft is to gain Work Group consensus on
specifics related to 5 components of test plan
two appendices anticipated to address:
ŧ additional testing specifications and protocols
ŧ response to Coordinating Committee comments on pollutant lists
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Goals for Test Plan
Ķ Emissions Subgroup identified 3 possible goals:
1 determine effectiveness of after-treatment control devices
to reduce formaldehyde
2 determine the effectiveness of combustion modifications
to reduce formaldehyde
3 determine typical emissions for engines throughout
the operating range
Ķ Draft Test Plan designed around Goal #1:
emissions data on control device efficiency is a data gap in the
ICCR Emissions Database
little understanding of effects of combustion modifications on HAPs
EPA has endorsed the use of ICCR emissions testing dollars to
achieve this goal
IV - 3
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Engines, Fuels and Controls
Four Tests
Engine to be Tested
Engine
Subcategory
Fuel
Control Device
Clark TLA
2-stroke,
Natural Gas
CO catalyst
Turbocharged
gaseous fuel
Caterpillar 3500 Series
Turbocharged
liquid-fuel
Diesel
CO catalyst
Waukesha 7042 GL
4-stroke, lean-burn,
Natural Gas
CO catalyst
Turbocharged
gaseous fuel
Ingersoll Rand KVG
4-stroke, rich-burn,
Natural Gas
NSCR 3-way
Naturally Aspirated
gaseous fuel
catalyst
IV - 4
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Matrix of Operating Conditions
Ķ Four corners of torque/speed
envelope (runs 1-4)
Ķ Air-to-fuel ratio sensitivity
(runs 1, 5-6)
Ķ High speed and low load
(run 7)
Ķ Low speed and high load
(run 8)
Ķ Air manifold temperature
sensitivity (runs 1, 9-10)
Ķ Jacket water temperature
sensitivity (runs 13-14)
Ķ Engine balance sensitivity
(runs 1, 15-16)
Run
Speed
Torque
Air to Fuel
Ratio
Timing
Air Manifold
Temperature
Jacket Water
Temperature
1
H
H
N
S
S
S
2
H
L
N
S
S
S
3
L
L
N
S
S
S
4
L
H
N
S
S
S
5
H
H
L
S
S
S
6
H
H
H
S
S
S
7
H
L
H
S
S
S
8
L
H
L
S
S
S
9
H
H
N
S
L
S
10
H
H
N
S
H
S
11
H
H
N
S
S
L
12
H
H
N
S
S
H
13
H
H
N
L
S
S
14
H
H
N
H
S
S
15
H
H
N
S
S
S
16
H
H
N
S
S
S
*Notes:
H, L
to be
determined
based on
operating
range and
control
flexibility.
rv - s
H, L
to be
determined
based on
operating
range and
control
flexibility.
N = Nominal
reqd. to satisfy
emissions
H, L
to be
determined
based on
operating
range and
control
flexibility.
S = Set point
H, L
to be
determined
based on
operating
range and
control flexibility.
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Test Methods
Ķ Methods that provide data on-site selected (when possible)
Ķ Criteria Pollutants
~ FTIR for CO and NOx
EPA Method 25A for THC
EPA Method 5 for PM
Ķ HAPs
~ Portable GCMS for: Method 429:
ŧ BTEX ŧ Naphthalene
ŧ 1,3-butadiene ŧ PAHs
ŧ n-Hexane
~ FTIR for:
Fuel Testing for Metals:
ŧ formaldehyde
ŧ acetaldehyde
ŧ acrolein
ŧ Beryllium, Cadmium,
Chromium, Lead, Manganese
Mercury, Nickel, Selenium
IV - 6
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Prioritization
Priority to testing one engine from each
subcategory identified thus far
Priority to testing those emission control devices
which have been identified thus far as possible
controls for MACT
IV - 7
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Proposal for Consensus
Ķ Emissions Subgroup proposes that:
The test plan for four emissions tests be approved,
as proposed in the draft test plan.
That two appendices be added to the document to address:
ŧ specifics necessary for testing contractors to estimate costs,
and
ŧ response to comments received on pollutant lists.
That the Work Group present the test plan and request
funding for testing at the November Coordinating Committee.
IV - 8
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ATTACHMENT V
DRAFT TEST PLAN
-------
PLAN FOR EMISSIONS TESTING OF
RECIPROCATING INTERNAL COMBUSTION ENGINES
presented to:
Reciprocating Internal Combustion Engine (RICE) Work Group
Industrial Combustion Coordinated Rulemaking
presented by:
Emissions Subgroup of the RICE Work Group
Industrial Combustion Coordinated Rulemaking
September 1997
v - l
-------
TABLE OF CONTENTS
1.0 INTRODUCTION 1
1.1 Components of the Test Plan 1
1.2 Emissions Testing Goals Identified by RICE Work Group 1
2.0 ENGINES, FUELS, AND EMISSION CONTROLS TO BE TESTED . . . 3
2.1 Engines 3
2.2 Fuels 3
2.3 Emission Controls 4
3.0 MATRIX OF OPERATING CONDITIONS TO BE TESTED 5
4.0 POLLUTANTS TO BE MEASURED DURING TESTING 7
5.0 TEST METHODS TO QUANTIFY EMISSIONS DURING TESTING ... 8
6.0 PRIORITIZATION 9
7.0 SUMMARY OF PROPOSED EMISSIONS TESTS 10
7.1 Test #1: Clark TLA 10
7.2 Test #2: Caterpillar 3500 Series 11
7.3 Test #3: Waukesha 7042 GL 12
7.4 Test #4: Ingersoll Rand KVG 13
V - 2
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DRAFT
1.0 INTRODUCTION
The Reciprocating Internal Combustion Engine (RICE) Work Group has
determined that additional emissions data is necessary to support the
rulemaking development for RICE, as a part of the Industrial Combustion
Coordinated Rulemaking (ICCR). The Work Group has developed this
emissions test plan for future emissions testing (both air toxics and criteria
pollutants) of stationary reciprocating internal combustion engines (RICE). The
results of this test plan will provide additional emissions data and will address
key data gaps that are present in the EPA ICCR Emissions Database for RICE.
1.1 Components of the Test Plan
The test plan has five components:
Engines, Fuels, and Emission Controls to be Tested
Matrix of Operating Conditions to be Tested
Pollutants to be Measured During Testing
Test Methods to Quantify Emissions
Prioritization
Each of these components is discussed in the sections that follow. A summary
of each emissions test proposed is provided in the final section of this test plan.
RICE Emissions Test Plan
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DRAFT
1.2 Emissions Testing Goals Identified by RICE Work Group
The RICE Work Group has identified the following possible goals for emissions
testing under ICCR:
determine the effectiveness of after-treatment control devices to reduce
formaldehyde;
determine the effectiveness of combustion modifications to reduce
formaldehyde;
determine typical emissions for engines throughout the operating range.
The Work Group has designed the emissions test plan principally around Goal
#1, for the following reasons:
Emissions data to demonstrate the effectiveness of possible MACT
control devices for existing RICE is a data gap in the ICCR
Emissions Database for RICE.
Understanding of the effects of combustion modifications on HAPs
is in its infancy, and would require a very extensive research
program to identify potential control techniques, along with
confirming testing.
EPA has endorsed the use ICCR emissions testing dollars to
achieve this goal.
RICE Emissions Test Plan
V - 4
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DRAFT: September 1997
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DRAFT
2.0 ENGINES, FUELS, AND EMISSION CONTROLS TO BE TESTED
2.1 Engines
The RICE Work Group recommends that a minimum of four engines be tested
under ICCR. Each of the engines represents one of the four subcategories of
engines that have been identified thus far by the Work Group (see Table 1).
The subcategories have been determined principally based on the viability of
possible MACT controls.
Table 1. Engines to be Tested
Engine to be Tested
Engine Subcategory
Clark TLA Turbocharged
2-stroke, gaseous fuel
Caterpillar 3500 Series Turbocharged
liquid-fuel
Waukesha 7042 GL Turbocharged
4-stroke, lean-burn, gaseous fuel
Ingersoll Rand KVG Naturally Aspirated
4-stroke, rich-burn, gaseous fuel
2.2 Fuels
Diesel fuel has been selected as the liquid fuel to be tested. The Work Group
selected diesel fuel for the following reasons:
Most stationary RICE that use liquid fuels use diesel.
The efficiency of the control devices tested for diesel will be
achievable by the other liquid fuels.
Natural gas has been selected as the gaseous fuel to be tested. The Work
Group selected natural gas for the following reasons:
Most stationary RICE that use gaseous fuels use natural gas.
The efficiency of the control devices tested for natural gas will be
achievable by the other gaseous fuels (propane, landfill gas,
digester gas).
RICE Emissions Test Plan
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DRAFT: September 1997
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DRAFT
2.3 Emission Controls
The Work Group recommends that the engines be tested with emissions control
devices that have been identified as possible controls for the Maximum
Achievable Control Technology (MACT) standard. To date, the Work Group has
identified CO catalysts (carbon monoxide catalysts) as possible MACT controls
for lean-burn engines. For rich-burn engines, the Work Group has identified
non-selective catalytic reduction (NSCR) three-way catalysts as possible MACT
controls. The Clark, Waukesha, and Caterpillar will be tested with CO (carbon
monoxide) catalysts. The Work Group recommends that the Ingersoll Rand be
tested with an NSCR three-way catalyst.
Engine to be Tested
Control Device
Clark TLA Turbocharged
carbon monoxide (CO) catalyst
Caterpillar 3500 Series Turbocharged
carbon monoxide (CO) catalyst
Waukesha 7042 GL Turbocharged
carbon monoxide (CO) catalyst
Ingersoll Rand KVA Naturally Aspirated
non-selective catalytic reduction (NSCR)
three-way catalyst
RICE Emissions Test Plan
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DRAFT: September 1997
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DRAFT
3.0 MATRIX OF OPERATING CONDITIONS TO BE TESTED
The Work Group recommends that the engines be tested throughout the entire
operating envelope. The Work Group has developed a 16-point test matrix of
operating conditions to be tested (see Table 2). The test matrix includes varied
speed, torque, air-to-fuel ratio, air manifold temperature, jacket water temperature,
timing, and combustion balance as applicable to the specific engine's operating
envelope. The tests are organized as follows:
Four corners of the torque / speed envelope (runs 1-4)
Air-to-fuel ratio sensitivity (runs 1, 5-6)
High speed and low load (run 7)
Low speed and high load (run 8)
Air manifold temperature sensitivity (runs 1, 9-10)
Jacket water temperature sensitivity (run s1, 11-12)
Injection or spark timing sensitivity (runs 13-14)
Engine balance sensitivity (runs 1, 15-16)
An abbreviated matrix will apply to the engine subcategory for liquid fuels due to a
reduced ability to vary parameters. Specific settings for the four engines selected
are presented in the summary tables in the final section of this test plan.
The Work Group recommends that runs 1-14 be conducted with engine balance
within the OEM (original equipment manufacturer) specification of good balance.
The Work Group recommends that an engine "expert" be on-site during all
testing to ensure that the engine is properly balanced and is being tested in a
well-maintained condition. It is estimated that the test matrix will require
approximately three days of emissions testing for each engine.
RICE Emissions Test Plan
V - 7
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DRAFT: September 1997
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DRAFT
Table 2. Matrix of Operating Conditions to be Tested
Run
Speed
Torque
Air to Fuel
Ratio
Timing
Air Manifold
Temperature
Jacket Water
Temperature
1
H
H
N
S
S
S
2
H
L
N
S
S
S
3
L
L
N
S
S
S
4
L
H
N
S
S
S
5
H
H
L
S
S
S
6
H
H
H
S
S
S
7
H
L
H
S
S
S
8
L
H
L
S
S
S
9
H
H
N
S
L
S
10
H
H
N
S
H
S
11
H
H
N
S
S
L
12
H
H
N
S
S
H
13
H
H
N
L
S
S
14
H
H
N
H
S
S
15
H
H
N
S
S
S
16
H
H
N
S
S
S
I
'Notes:
H, L
H, L
N = Nominal
S = Set point
to be
to be
reqd. to satisfy
determined
determined
emissions
H, L
based on
based on
to be
operating
operating
H, L
determined
range and
range and
to be
based on
control
control
determined
operating
flexibility.
flexibility.
based on
range and
operating
control flexibility.
range and
control
flexibility.
RICE Emissions Test Plan
V - 8
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DRAFT: September 1997
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DRAFT
4.0 POLLUTANTS TO BE MEASURED DURING TESTING
The Work Group recommends that emissions data for both hazardous air
pollutants (HAPs) and criteria pollutants be collected during the emissions
testing. The Work Group identified the principal pollutants that are reasonably
anticipated to be emitted from the RICE.
Emissions data for the following criteria pollutants will be collected:
carbon monoxide (CO)
nitrogen oxides (NOx)
total hydrocarbons (THC)
particulate matter (PM)
Seven HAP pollutants are included in the test plan for all engines, regardless of
fuel:
BTEX (benzene, toluene, ethylbenzene, and xylene) and
three aldehydes (formaldehyde, acetaldehyde, and acrolein).
Naphthalene, 1-3, butadiene, and PAHs are included for natural gas and diesel
fuel. Metals are included for the diesel fuel tests. Chlorinated compounds that
were originally included on the pollutant list for natural gas have been removed
based on further review of the emissions test data in the ICCR Emissions
Database and industry data related to the absence of chlorine in natural gas. A
list of HAP pollutants for each proposed test are provided in the final section of
this test plan.
RICE Emissions Test Plan
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DRAFT: September 1997
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DRAFT
5.0 TEST METHODS TO QUANTIFY EMISSIONS DURING TESTING
The Work Group recommends the use of emissions test methods that will
provide direct measurement of pollutants on-site. This approach to the test
methods has been selected since it will be necessary to have on-site data to
fully evaluate and conduct the matrix of engine operating conditions.
The Testing and Monitoring Work Group provided advice on the available
methods to provide on-site data. Based on the T&M information, the aldehydes,
BTEX compounds, n-Hexane, and 1-3, butadiene can be measured with test
methods that will provide on-site data. There is no test method for naphthalene
and PAHs that will provide on-site data. Therefore, the Work Group
recommends that naphthalene and PAH data be collected for laboratory
analysis.
The Work Group recommends that FTIR be used to collect data on aldehydes,
NOx, and CO. The Work Group recommends that a portable GCMS be used to
collect BTEX, n-Hexane, and 1-3, butadiene data. The Work Group
recommends that metals for diesel fuel be evaluated through fuel testing.
The proposed test methods for each proposed emissions test are provided in the
summaries of proposed emissions tests in the final section of this test plan.
RICE Emissions Test Plan
V- 10
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DRAFT: September 1997
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DRAFT
6.0 PRIORITIZATION
The Work Group recommends that priority be given to testing one engine from
each subcategory that has been identified thus far by the RICE Work Group.
The Work Group also recommends that priority be given to testing those
emission control devices which have been identified thus far as possible controls
for the Maximum Achievable Control Technology (MACT) standard. The four
emission tests proposed in this test plan are consistent with this prioritization.
RICE Emissions Test Plan
V- 11
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DRAFT: September 1997
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DRAFT
7.0 SUMMARY OF PROPOSED EMISSIONS TESTS
7.1 Test #1: Clark TLA
Engine Subcategory:
2-stroke, lean-burn, gaseous fuel
Engine to be Tested:
Clark TLA Turbocharged
Fuel:
Natural Gas
Control Device:
Carbon Monoxide (CO) Catalyst
Pollutants to be Measured:
Criteria Pollutants:
NOx, CO, THC
Hazardous Air Pollutants:
Benzene, Toluene, Ethylbenzene, and Xylene(s)
Formaldehyde, Acetaldehyde, Acrolein
1-3, Butadiene, Naphthalene, PAHs
Test Methods to be Used:
Method 18 / TO-14 with Portable GCMS for:
Benzene, Toluene, Ethylbenzene, and Xylene(s)
1-3, Butadiene
FTIR for:
Formaldehyde, Acetaldehyde, Acrolein
NOx, CO
Method 429 for:
Naphthalene, PAHs
Method 25 for:
THC
Operating Conditions to be
Tested:
Speed
Torque
Air-to-
Fuel
Ratio
Timing
Air
Manifold
Temp.
Jacket
Water
Temp.
Run 1
H
H
N
S
S
S
Run 2
H1
L1
N1
S1
S1
s1
Run 3
L2
L2
N2
s2
s2
s2
Run 4
L1-2
H1,2
N1-2
s1-2
s1-2
s1-2
Run 5
H
H
L
s
s
s
Run 6
H
H
H
s
s
s
Run 7
H2
L2
H2
s2
s2
s2
Run 8
L2
H2
L2
s2
s2
s2
Run 9
H
H
N
s
L
s
Run 10
H
H
N
s
H
s
Run 11
H
H
N
s
s
L
Run 12
H
H
N
s
s
H
Run 13
H
H
N
L
s
s
Run 14
H
H
N
H
s
s
Run 15
H3
H3
N3
s3
s3
s3
Run 16
H3
H3
N3
s3
s3
s3
L4= 270
H4= 300
L4'5 = 70
H4'5 = 100
N6 = 0.25
L6 = 0.22
H6 = 0.28
S =4.5
L = 2
H = 7
S7 = 100
L7 = 80
H7 = 120
S8= 150
L8 = 140
H8= 160
Runs #2 and #4 are not applicable if the engine at the test site is running a pump or blower, since the torque absorbed by a pump or blower is generally
determined by speed.
Runs #3, #4, #7, and #8 are not applicable if the engine at the test site is running a synchronous generator, since synchronous generators do not vary speed.
Same as Run #1 except with engine at limit of acceptable imbalance.
Depending on site and operating conditions, speed and torque range may vary.
If unit has ambient rating controls capability, high torque value may be up to 124%.
Fuel/air equivalence ratio for this two-stroke cycle engine is based on total airflow through engine, not trapped air.
JWT setpoint is based on normal operating practices, but may vary depending on site-specific conditions.
IT setpoint is based on pipeline quality natural gas. IT is a function of engine speed and AMT.
RICE Emissions Test Plan
V- 12
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DRAFT: September 1997
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DRAFT
7.2 Test #2: Caterpillar 3500 Series
Engine Subcategory:
Liquid Fuel
Engine to be Tested:
Caterpillar 3500 Series Turbocharged
Fuel:
Diesel Fuel
Control Device:
Carbon Monoxide (CO) Catalyst
Pollutants to be Measured:
Criteria Pollutants:
NOx, CO, THC, and PM
Hazardous Air Pollutants:
Benzene, Toluene, Ethylbenzene, Xylene(s)
Formaldehyde, Acetaldehyde, Acrolein
n-Hexane, 1-3, Butadiene, Naphthalene, PAHs
Metals: Beryllium, Cadmium, Chromium, Lead, Manganese,
Mercury, Nickel, Selenium
Test Methods to be Used:
Method 18 / TO-14 with Portable GCMS for:
Benzene, Toluene, Ethylbenzene, Xylene(s),
n-Hexane, 1-3, Butadiene
FTIR for:
Formaldehyde, Acetaldehyde, Acrolein, NOx, and CO
Method 429 for Naphthalene, PAHs
Method 25A for THC
EPA Method 5 for Particulate Matter
Fuel Testing for Metals
Operating Conditions to be
Tested:
Speed
Torque
Air-to- Fuel
Ratio
Timing
Air
Manifold
Temp.
Jacket
Water
Temp.
Run 1
H
H
N
s
s
s
Run 2
H1
L1
N1
s1
s1
s1
Run 3
L2
L2
N2
s2
s2
s2
Run 4
L1-2
H1,2
N1-2
s1-2
s1-2
s1-2
Run 5
Not Applicable
Run 6
Not Applicable
Run 7
Not Applicable
Run 8
Not Applicable
Run 9
H
H
N
s
L
s
Run 10
H
H
N
s
H
s
Run 11
H
H
N
s
s
L
Run 12
H
H
N
s
s
H
Run 13
Not Applicable
Run 14
Not Applicable
Run 15
H3
H3
N3
s3
s3
s3
Run 16
H3
H3
N3
s3
s3
s3
L4'5 = 1000
H4-5 = 1200
L5 = 70
H5 = 100
N = 0.68 (7.5%
02)
L = 0.63 (8.5%
02)
H = 0.74 (6.5%
02)
S = 28
L = 26
H = 30
SŪ = 130
LŪ = 120
HŪ = 140
S7 = 160
V = 155
H7 = 165
Runs 2 and 4 are not applicable if the engine at the test site is running a pump or blower, since the torque absorbed by a pump or blower is generally determined by
speed.
Runs 3, 4, 7, and 8 are not applicable if the engine at the test site is running a synchronous generator, since synchronous generators do not vary speed.
Same as Run #1 except with engine at limit of acceptable imbalance.
Depending on rating of separable compressor unit, speed values may vary between 700 - 1200 rpm.
Depending on site and operating conditions, speed and torque range may vary.
AMT totally depends on type of cooler configuration.
JWT setpoint is based on normal operating practices, but may vary depending on site-specific conditions.
IT setpoint is based on diesel fuel.
RICE Emissions Test Plan
V- 13
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DRAFT: September 1997
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DRAFT
7.3 Test #3: Waukesha 7042 GL
Engine Subcategory:
4-stroke, lean-burn, gaseous fuel
Engine to be Tested:
Waukesha 7042 GL Turbocharged
Fuel:
Natural Gas
Control Device:
Pollutants to be Measured:
Carbon Monoxide (CO) Catalyst
Criteria Pollutants:
NOx, CO, THC
Hazardous Air Pollutants:
Benzene, Toluene, Ethylbenzene, Xylene(s)
Formaldehyde, Acetaldehyde, Acrolein
1-3, Butadiene, Naphthalene, PAHs
Test Methods to be Used:
Method 18 / TO-14 with Portable GCMS for:
Benzene, Toluene, Ethylbenzene, Xylene(s)
1-3, Butadiene
FTIR for:
Formaldehyde, Acetaldehyde, Acrolein, NOx, CO
Method 429 for Naphthalene, PAHs
Method 25A for THC
Operating Conditions to be
Tested:
Speed
Torque
Air-to- Fuel
Ratio
Timing
Air
Manifol
d Temp.
Jacket
Water
Temp.
Run 1
H
H
N
S
S
S
Run 2
H1
L1
N1
S1
S1
S1
Run 3
L2
L2
N2
s2
s2
s2
Run 4
L1-2
H1,2
N1-2
s1-2
s1-2
s1-2
Run 5
H
H
L
s
s
s
Run 6
H
H
H
s
s
s
Run 7
H2
L2
H2
s2
s2
s2
Run 8
L2
H2
L2
s2
s2
s2
Run 9
H
H
N
s
L
s
Run 10
H
H
N
s
H
s
Run 11
H
H
N
s
s
L
Run 12
H
H
N
s
s
H
Run 13
H
H
N
L
s
s
Run 14
H
H
N
H
s
s
Run 15
H3
H3
N3
s3
s3
s3
Run 16
H3
H3
N3
s3
s3
s3
O O
o o
O
-------
DRAFT
7.4 Test #4: Ingersoll Rand KVG
Engine Subcategory:
4-stroke, rich-burn, gaseous fuel
Engine to be Tested:
Ingersoll Rand KVG Naturally Aspirated
Fuel:
Natural Gas
Control Device:
Non-Selective Catalytic Reduction (NSCR) 3-Way Catalyst
Pollutants to be Measured:
Criteria Pollutants:
NOx, CO, THC
Hazardous Air Pollutants:
Benzene, Toluene, Ethylbenzene, Xylene(s)
Formaldehyde, Acetaldehyde, Acrolein
1-3, Butadiene, Naphthalene, PAHs
Test Methods to be Used:
Method 18 / TO-14 with Portable GCMS for:
Benzene, Toluene, Ethylbenzene, Xylene(s)
1-3, Butadiene
FTIR for:
Formaldehyde, Acetaldehyde, Acrolein, NOx, CO
Method 429 for:
Naphthalene, PAHs
Method 25A for THC
Operating Conditions to
be Tested:
Speed
Torque
Air-to- Fuel
Ratio
Timing
Air
Manifold
Temp.
Jacket
Water
Temp.
Run 1
H
H
N
s
s
s
Run 2
H1
L1
N1
s1
s1
s1
Run 3
L2
L2
N2
s2
s2
s2
Run 4
L1-2
H1,2
N1-2
s1-2
s1-2
s1-2
Run 5
H
H
L
s
s
s
Run 6
H
H
H
s
s
s
Run 7
H2
L2
H2
s2
s2
s2
Run 8
L2
H2
L2
s2
s2
s2
Run 9
H
H
N
s
L
s
Run 10
H
H
N
s
H
s
Run 11
H
H
N
s
s
L
Run 12
H
H
N
s
s
H
Run 13
H
H
N
L
s
s
Run 14
H
H
N
H
s
s
Run 15
H3
H3
N3
s3
s3
s3
Run 16
H3
H3
N3
s3
s3
s3
L4 = 270
H4 = 300
L4 = 70
H4= 100
S = 1.00
L = 0.95
H= 1.05
S7= 15
L7= 12
H7= 18
See Note5
S6 = 155
L6 = 145
H6= 165
Runs 2 and 4 are not applicable if the engine at the test site is running a pump or blower, since the torque absorbed by a pump or blower is
generally determined by speed.
Runs 3, 4, 7, and 8 are not applicable if the engine at the test site is running a synchronous generator, since synchronous generators do not vary
speed.
Same as Run 1 except with engine at limit of acceptable imbalance.
Depending on site and operating conditions, speed and torque range may vary.
AMT totally dependent on ambient temperatures. 20 degree swing in temperature desirable for testing.
JWT setpoint is based on normal operating practices, but may vary depending on site-specific conditions.
IT setpoint is based on pipeline quality natural gas and may vary with certain ambient and operating parameters.
RICE Emissions Test Plan
V- 15
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DRAFT: September 1997
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ATTACHMENT VI
COMMENTS ON POLLUTANT LIST
PRESENTED BY LAURA KINNER
V - 16
-------
Comments on Pollutant Lists
presented to:
Reciprocating IC Engine Work Group
Durham, North Carolina
presented by:
Sam Clowney, Tennessee Gas Pipeline,
on behalf of the Emissions Subgroup
September 18,1997
vi - 1
-------
Overview of Comments
7 comments on pollutants received from members of
ICCR outside RICE Work Group
Only one provided a reference to data to support the
comment (mercury)
General sense in Subgroup that lists should not get
longer - if possible, should be shorter
Preliminary response to comments prepared by
Subgroup with assistance from Dr. Laura Kinner,
Emissions Monitoring, Incorporated (EMI) and
Dr. Bryan Willson, Colorado State University (CSU)
VI - 2
-------
Comments Received &
Preliminary Responses (1)
Ķ All fuels:
Add criteria pollutants (Comment #3)
ŧ Added CO, NOx, THC, and PM (diesel only)
Test fuels for anticipated inorganic HAPs by fuel
testing (Comment #3)
ŧ Added fuel tests for metals from diesel fuel
Compare lists to any future list of potential HAPs
formed during combustion developed by the
Coordinating Committee (Comment #2)
VI - 3
-------
Comments Received &
Preliminary Responses (2)
Ķ Diesel Fuel:
Add all HAPs detected in tests for natural gas
(Comment #2)
ŧ No Additional Pollutants
All HAPs detected for natural gas on the diesel list, except
chlorinated compounds - chlorinated compounds for natural gas
called into question
Remove all Metals (Comment #7)
ŧ Response not yet decided
Fuel testing could be used in lieu of stack testing
VI - 4
-------
Comments Received &
Preliminary Responses (3)
Ķ Digester Gas:
Add all HAPs detected in test for natural gas, except
chlorinated compounds (Comment #5)
ŧ No Additional Pollutants
1,3-butadiene, Naphthalene, and PAHs only pollutants on natural
gas list that are not on digester gas list - 1,3-butadiene tested for
multiple times and never detected if no 1,3-butadiene,
reasonable to assume no naphthalene or PAHs
Add Methanol (Comment #4)
ŧ No Additional Pollutants
Orange Co. tested for methanol in 1995, no methanol detected
Add Chlorobenzene (Comment #2)
ŧ No Additional Pollutants
Of 10 tests for chlorobenzene, 9 times reported as non-detect
VI - 5
-------
Comments Received &
Preliminary Responses (4)
Ķ Landfill Gas:
Add Mercury (Comment #1)
ŧ Response not yet decided
Bryan Willson reviewing this issue for Subgroup
Add all HAPs detected in tests for natural gas
(Comment #2), except chlorinated compounds (#5)
ŧ Response not yet decided
1,3-butadiene, Naphthalene, and PAHs only pollutants on natural
gas list that are not on digester gas list (except chlorinated
compounds). No tests for 1,3-butadiene, Naphthalene or PAHs
Add chlorinated compounds detected in tests for other
fuels (Comment #2)
ŧ Response not yet decided
1,1,2,2-tetrachloroethane, chlorobenzene, ethyl chloride,
methylene chloride, 1,4-dichlorobenzene (p), vinyl chloride
VI - 6
-------
Comments Received &
Preliminary Responses (5)
Ķ Propane:
Add all HAPs detected in tests for natural gas
(Comment #2), except chlorinated compounds (#5)
ŧ Add pollutants (except chlorinated compounds)
1,3-butadiene and PAHs only pollutants on natural gas list that are
not on propane list (except chlorinated compounds) - since
Naphthalene detected for propane, 1,3-butadiene and PAHs may
be present
Add PAH, since Naphthalene detected (Comment
#2)
ŧ Add pollutant
PAHs may be present since naphthalene detected
VI - 7
-------
Comments Received &
Preliminary Responses (6)
Ķ Natural Gas:
Remove chlorinated compounds (Comment #6 & 7)
ŧ Compounds removed
based on additional review of data in database, and industry
information about absence of chlorine in natural gas, compounds
removed - source of chlorinated compounds likely laboratory
contamination
VI - 8
-------
Summary of Preliminary Response
Ķ Diesel Fuel: no HAP pollutants added, fuel testing for metals,
NOx, CO, THC, and PM added
Ķ Digester Gas: no HAP pollutants added,
NOx, CO, and THC added
additional HAPs to be determined,
NOx, CO, and THC added
1,3-butadiene and PAHs added,
NOx, CO, and THC added
4 chlorinated compounds removed,
NOx, CO, and THC added
~ Final response to comments will be circulated to Work Group and
included in test plan as an appendix
VI - 9
Ķ Landfill Gas:
Ķ Propane:
Ķ Natural Gas:
-------
ATTACHMENT VII
POPULATION SUBGROUP REPORT
PRESENTED BY WAYNE HAMILTON
-------
Reciprocating Internal Combustion
Engines Work Group
Population Database - Refinement
September 18, 1997
VII - 1
-------
A) IC Engine Make and Model
Information
VII - 2
-------
B) Subcategory Tree
Total number of engines: 28,162
Engines
28162
X
Spark Ignition
19050
Includes: all fuels from Liquid Fuel Spark Ignition
and Gaseous Fuel Spark Ignition
Non-Fossil Fuel
58
Non-Fossil/Waste
=L
Compression Ignition
9418
Includes: Crude Oil, Distillate Oil (diesel), Dual Fuel
No. 1, 4 & 6 Fuel Oils, Residual/Crude Oil
r I
Liquid Fuel
Gaseous Fuel
668
18382
Includes: Gasoline, Kerosene/Naphtha (Jet Fuel)
Includes: Digester Gas, Landfill Gas, Propane,
LPG, Natural Gas, and Process Gas
Liquid Fuel
Dual Fuel
9197
1015
Includes: Crude Oil, Distillate Oil (diesel),
Includes: Multiple Segment Numbers
No. 1, 4 & 6 Fuel Oils, Residual/Crude Oil
2-stroke
4-stroke
Lean Burn
Rich Burn
Lean Burn
833
874
659
Natural Gas
Natural Gas
Natural Gas
by SCO: 20200252
by SCO: 20200253
by SCO: 20200254
VII - 3
-------
C) Update SCCs Based on New
Make and Model Information
VII - 4
-------
D) Capacity Unit Conversion
Convert engine size to a standard unit
Engine size units provided in energy input units or power
output units
WG needs to get consensus on this issue.
From the 1993 ACT, the following efficiencies are provided;
Rich-Burn SI Engines: 34.4% (31 - 38)
Lean-Burn SI Engines: 33.8% (29 - 38)
Diesel Engines: 38.4% (38 - 41)
Dual-Fuel Engines: 37.6% (37 - 41)
WG member information reflect lower efficiencies:
2 Stroke SI Engines: 28% (20 - 36)
4 Stroke SI Engines: 29% (21 - 35)
VII - 5
-------
E) Engine Distribution by
Geography, HP and SIC
Engine Distribution by Geography
VII - 6
-------
Draft Distribution of Engines by HP
TjC "'v I:.n-T - !.. r,-a|
~3 Ķ=*. a
<1 1 to 9 10 to 99 100 to 500 to 1000 to 2000 to 5000 to 10,000 >
499 999 1999 4999 9999 to 20,000
19,999
Ranges of Engines (HP)
VII - 7
-------
SIC Distribution
ICCR RICE Population Database
Other
23%
Eectric
Services
4%
National
Security
5%
Natural Gas
Liquids
10%
Natural Gas
Transmission
20%
Unknown
19%
Crude
Petroleum &
Natural Gas
19%
VII - 8
-------
F) Subcategory Statistical
Representation
How representative are the subcategorization data?
. Are the data adequately representative in order to
extrapolate the rest of the engine population?
VII - 9
-------
G) Use of Blanks in the Control
Device Code Field
Control Device Information Summary:
Criteria I: Only "000" considered as "No Equipment"
Criteria II: "000" or "Null" as "No Equipment"
Notes:
Need to check on some of the referenced control devices
(e.g., bag filters for NG unit, catalytic reduction for 4
stroke lean bum engines)
VII - 10
-------
G) Use of Blanks in the Control
Device Code Field (cont'd.)
Control Device Information Summary (cont'd):
Top Eight States (68% of population)
Texas (18%) blanks = no control devices
California (14%) not a required field, therefore not reliable
Louisiana (10%) blanks = no control devices
New Mexico (7%) blanks = no control devices
Colorado (5%) blanks = no control devices
Oklahoma (5%) blanks = no control devices
New Jersey (4%) blanks = no control devices
Michigan (4%) blanks = no control devices (unconfirmed)
VII - 11
-------
H) Benchmarking Data with
Other Databases
API information
INGAA information
VII - 12
-------
I) Summary and Action Items
VII - 13
-------
ATTACHMENT VIII
TOPICS TO BE DISCUSSED AT THE SEPTEMBER 18 MEETING
POPULATION SUBGROUP
(All information should be considered in draft form)
-------
OUTLINE OF POPULATION SUBGROUP INFORMATION
TO BE DISCUSSED AT
THE SEPTEMBER 18 RICE WORK GROUP MEETING
A) IC Engine Make and Model Information
Alpha-Gamma incorporated additional make and model information submitted by Mike
Milliet, Vick Newsom, Don Dowdall and Bob Stachowicz into the current Make and Model
Lookup table in the RICE Population database. The current numbers are as follows:
Populated Make and Model fields by number of engines: 3022 (10.7%)
Populated model, unpopulated make by number of engines: 86 (0.305%)
868 engines in Make and Model Lookup Table
503 of engines in database match with make and model in lookup table
544 of engines in database match with model in lookup table, but 28 of these makes don't
match
Therefore, 516 engines match with model and unconflicting make
B) Suhcategorv Tree Based on New Information
Based on newly submitted make and model information, the engines are
subcategorized as follows (number of engines is given in parentheses):
All Engines (28162)
Spark Ignition (19050)
Liquid fuel (668)
Gaseous fuel (18382)
Two Stroke
Lean Burn (833)
Four Stroke
Lean Burn (659)
Rich Burn (874)
Compression Ignition (9418)
Liquid fuel (9197)
Dual fuel (1015)
C) Revise and Update SCCs hased on new Make and Model information
Since new make and model information was obtained, additional parameters were known
about hundreds of engines in the database. This allowed us to assign new SCCs, particularly
to those engines which are now known as 2 or 4 stroke and rich or lean burn. This was
performed in order to get a better data distribution for the proposed subcategories as well as
to gain the ability to assign capacity conversion efficiencies, described below.
D) Run Code for Capacity Unit Conversion
A code was written to convert all engine operating capacities in the population database to
horsepower. In the raw version 2 database, capacities were given in various units, including
heat input units (MMBTU/hr, tons/hr, scfm, gal/yr) and power output units (HP, MW, boiler
HP). For comparison purposes, there is a need to convert these units to a standard format.
Horsepower was selected as the standard capacity unit. The 1994 ACT document was used
VIII - 1
-------
as the basis for the capacity conversion. Alpha-Gamma proposes using the thermal efficiency
averages pulled from the ACT document:
* Rich burn spark ignition: 34.4% efficient
* Lean burn spark ignition: 33.8%
* Diesel: 38.4%
* Duel Fuel: 37.6%
E) Develop Engine Distrihution hv Horsepower and Geography
Alpha-Gamma determined engine distributions by horsepower, geography, and SIC in order
to better determine whether the database information is representative of the current industry.
These tables and graphs are attached.
F> Identified Suhcategorv Statistical Representation
* Questions:
1. How representative is the subcategorization data?
2. Is the statistical sampling adequately representative to "ramp up" engine population?
* Answers:
1. Need statistical assistance and expertise
2. Use USEPA or industry statistician subcontractor to review the database
Since all ICCR Source Work Groups will be facing similar problems with statistical
representation, the USEPA will be looking into providing assistance to review the statistical
significance of the database. Wayne Hamilton will also contact Mark Dunn, Shell Statistician,
to determine if he is available to review the USEPA database.
G) The Use of "Blank" Data Records in the "Control Device Code" field
The subgroup recommended that Alpha-Gamma contact two-thirds of the engines population
in the database (top eight states) to understand the "blank" data records in the "Control
Device Code" field. Alpha-Gamma has contacted state regulatory personnel for the eight
states with the highest engine populations (representing 68% of the engines in the population
database) in order to understand the "blanks" in database.
Results are as follows:
TOP EIGHT STATES (68% of population)
Texas:
California:
Louisiana:
New Mexico:
Colorado:
Oklahoma:
New Jersey:
Michigan:
blank)
18.12%
blanks equal
no
14.06%
unknown (not a
10.29%
blanks equal
no
7.27%
blanks equal
no
5.46%
blanks equal
no
4.87%
blanks equal
no
4.12%
blanks equal
no
3.94%
blanks equal
no
control devices
required field)
control devices
control devices
control devices
control devices
control devices
control devices
(4691/5104 are blank)
(2904/4007 are blank)
(1372/3016 are blank)
(1017/2049 are blank)
(1345/1572 are blank)
(323/1392 are blank)
(2/1377 are blank)
(unconfirmed) (97/1245 are
Control devices breakdown by subcategory are attached.
11) Benchmarking Data with API & INGAA
VIII - 2
-------
The population subgroup agreed to compare the results of the EPA ICCR RICE population
database to other databases provided by WG members, as they become available. Mike
Milliet plans to contact API about the use of the IC engine survey data as benchmark
information by September 10, 1997.
VIII
- 3
-------
Number of Engines by State
State Code State Abbreviation Number of Engines Percent of Population
48
TX
5103
18.12%
06
CA
3960
14.06%
22
LA
2899
10.29%
35
NM
2046
7.27%
08
CO
1538
5.46%
40
OK
1372
4.87%
34
NJ
1160
4.12%
26
Ml
1109
3.94%
49
UT
880
3.12%
27
MN
663
2.35%
42
PA
573
2.03%
56
WY
529
1.88%
17
IL
499
1.77%
20
KS
451
1.60%
31
NE
424
1.51%
29
MO
400
1.42%
55
Wl
385
1.37%
51
VA
378
1.34%
54
WV
315
1.12%
01
AL
289
1.03%
04
AZ
285
1.01%
30
MT
262
0.93%
72
PR
260
0.92%
05
AR
260
0.92%
18
IN
204
0.72%
1
VIII - 4
-------
State Code
State Abbreviation
Number of Engines
Percent of Population
25
MA
190
0.67%
09
CT
174
0.62%
12
FL
170
0.60%
02
AK
147
0.52%
33
NH
146
0.52%
15
HI
139
0.49%
16
ID
133
0.47%
39
OH
111
0.39%
38
ND
108
0.38%
78
VI
86
0.31%
53
WA
78
0.28%
24
MD
74
0.26%
50
VT
68
0.24%
23
ME
52
0.18%
37
NC
50
0.18%
36
NY
41
0.15%
45
SC
32
0.11%
66
GU
31
0.11%
44
Rl
26
0.09%
19
IA
23
0.08%
28
MS
15
0.05%
41
OR
7
0.02%
13
GA
6
0.02%
21
KY
5
0.02%
10
DE
3
0.01%
32
NV
2
0.01%
46
SD
1
0.00%
Total Number of Enaines:
28162
2
Note: No engines are currently in the database for DC or TN. Tennessee has been contacted and has submitted
additional engines which were previously missing.
VIII - 5
-------
Distribution of Engines by HP (Draft as of 9/10/97)
Ranges of HP
<1
1 to 9
10 to 99
100 to 499
500 to 999
1000 to 1999
2000 to 4999
5000 to 9999
10,000 to 19,999
20,000 to 2MM
TOTAL
Engines
VIII - 6
No. of
64
58
1039
3071
2941
2847
1301
218
80
171
11790
-------
ENGINE DISTRIBUTION BY SIC
Corresponding Industry
Percentage
Natural Gas Transmission
20.12
Unknown/Multiples
18.86
Crude Petroleum & Natural Gas
18.62
Natural Gas Liquids
9.79
National Security
5.24
Electric Services
4.49
Other
22.88
100
VIII - 7
-------
Spark Ignition Gaseous Fuels
Criteria I: Without blanks
Control Device Description Count Percentage
No Equipment
5987
83.40%
Catalytic Reduction
806
11.23%
Catalytic Afterburner
114
1.59%
Miscellaneous Control Devices
47
0.65%
Control of % 02 in Comb. Air
27
0.38%
Flaring
24
0.33%
Staged Combustion
24
0.33%
Direct Flame Afterburn
20
0.28%
Tray-Type Gas Absorption Column
17
0.24%
Vapor Recovery System
14
0.20%
Modif. Furnace/Burner Design
12
0.17%
Steam or Water Injection
12
0.17%
Mist Eliminator High Veloc.
8
0.11%
Mist Eliminator Low Veloc.
7
0.10%
Gas Scrubber, General
6
0.08%
Low Excess-Air Firing
6
0.08%
Electro. Prec. High Efficien.
5
0.07%
Ammonia Injection
4
0.06%
Dust Suppess-Water Spray
4
0.06%
Fabric Filter Low Temp
4
0.06%
Catal. Oxide.-Flue Gas Desulf.
3
0.04%
Lean Burn (includes Clean-Burn)
3
0.04%
Reduc. Combustion-Air Preheat
3
0.04%
Bottom Filling
2
0.03%
Centrif. Coll. Low Efficien.
2
0.03%
Electro. Prec. Low Efficien.
2
0.03%
Fabric Filter Med Temp
2
0.03%
Process Change
2
0.03%
Air injection
1
0.01 %
Annular Ring Filter
1
0.01 %
Cat. Afterburn-Heat Exch.
1
0.01 %
11 -Sep-97
Page
VIII - 8
-------
Control Device Description Count Percentage
Chemical Oxidation 1 0.01 %
Chemical Reduction 1 0.01 %
Conversion to Variable Vapor Space Tank 1 0.01%
Electro. Prec. Med Efficien. 1 0.01%
Fabric Filter High Temp 1 0.01%
Flue Gas Recirculation 1 0.01 %
Fuel-Low Nitrogen Content 1 0.01%
Multiple Cyclone W/O Fly Ash Reinjection 1 0.01 %
Wet Scrubber High Efficien. 1 0.01%
Total (Without Blanks) 7179
11 -Sep-97 Page 2
VIII - 9
-------
Spark Ignition Gaseous Fuels
Criteria II: With blanks
Control Device Description Count Percentage
No Equipment
17434
93.60%
Catalytic Reduction
806
4.33%
Catalytic Afterburner
114
0.61 %
Miscellaneous Control Devices
47
0.25%
Control of % 02 in Comb. Air
27
0.14%
Flaring
24
0.13%
Staged Combustion
24
0.13%
Direct Flame Afterburn
20
0.11%
Tray-Type Gas Absorption Column
17
0.09%
Vapor Recovery System
14
0.08%
Modif. Furnace/Burner Design
12
0.06%
Steam or Water Injection
12
0.06%
Mist Eliminator High Veloc.
8
0.04%
Mist Eliminator Low Veloc.
7
0.04%
Gas Scrubber, General
6
0.03%
Low Excess-Air Firing
6
0.03%
Electro. Prec. High Efficien.
5
0.03%
Ammonia Injection
4
0.02%
Dust Suppess-Water Spray
4
0.02%
Fabric Filter Low Temp
4
0.02%
Catal. Oxide.-Flue Gas Desulf.
3
0.02%
Lean Burn (includes Clean-Burn)
3
0.02%
Reduc. Combustion-Air Preheat
3
0.02%
Bottom Filling
2
0.01 %
Centrif. Coll. Low Efficien.
2
0.01 %
Electro. Prec. Low Efficien.
2
0.01 %
Fabric Filter Med Temp
2
0.01 %
Process Change
2
0.01 %
Air injection
1
0.01 %
Annular Ring Filter
1
0.01 %
Cat. Afterburn-Heat Exch.
1
0.01 %
11 -Sep-97
Page
VIII - 10
-------
Control Device Description Count Percentage
Chemical Oxidation 1 0.01 %
Chemical Reduction 1 0.01 %
Conversion to Variable Vapor Space Tank 1 0.01%
Electro. Prec. Med Efficien. 1 0.01%
Fabric Filter High Temp 1 0.01%
Flue Gas Recirculation 1 0.01 %
Fuel-Low Nitrogen Content 1 0.01%
Multiple Cyclone W/O Fly Ash Reinjection 1 0.01 %
Wet Scrubber High Efficien. 1 0.01%
Total (With Blanks) 18626
11 -Sep-97 Page 2
VIII - 11
-------
Spark Ignition Gaseous Fuels - Natural Gas : 2-Stroke and Lean Burn
Criteria I: Without blanks
Control Device Description Count Percentage
No Equipment 334 97.09%
Mist Eliminator High Veloc. 8 2.33%
Centrif. Coll. Low Efficien. 1 0.29%
Electro. Prec. High Efficien. 1 0.29%
Total (Without Blanks) 344
11 -Sep-97 Page 1
VIII - 12
-------
Spark Ignition Gaseous Fuels - Natural Gas : 2-Stroke and Lean Burn
Criteria II : With blanks
Control Device Description Count Percentage
No Equipment 825 98.80%
Mist Eliminator High Veloc. 8 0.96%
Centrif. Coll. Low Efficien. 1 0.12%
Electro. Prec. High Efficien. 1 0.12%
Total (With Blanks) 835
11 -Sep-97 Page 1
VIII - 13
-------
Spark Ignition Gaseous Fuels - Natural Gas : 4-Stroke and Lean Burn
Criteria I: Without blanks
Control Device Description
Count
Percentage
No Equipment
156
70.91 %
Catalytic Reduction
53
24.09%
Miscellaneous Control Devices
1.82%
Staged Combustion
1.36%
Catalytic Afterburner
0.45%
Control of % 02 in Comb. Air
0.45%
Low Excess-Air Firing
0.45%
Modif. Furnace/Burner Design
0.45%
Total (Without Blanks)
220
11 -Sep-97
DRAFT ONLY: THIS INFORMATION IS BEING REVISED
Page
VIII - 14
-------
Spark Ignition Gaseous Fuels - Natural Gas : 4-Stroke and Lean Burn
Criteria II: With blanks
Control Device Description
Count
Percentage
No Equipment
598
90.33%
Catalytic Reduction
53
1.01 %
Miscellaneous Control Devices
0.60%
Staged Combustion
0.45%
Catalytic Afterburner
0.15%
Control of % 02 in Comb. Air
0.15%
Low Excess-Air Firing
0.15%
Modif. Furnace/Burner Design
0.15%
Total (With Blanks)
662
11 -Sep-97
DRAFT ONLY: THIS INFORMATION IS BEING REVISED
Page
VIII - 15
-------
Spark Ignition Gaseous Fuels - Natural Gas : 4-Stroke and Rich Burn
Criteria I: Without blanks
Control Device Description
Count
Percentage
Catalytic Reduction
163
47.94%
No Equipment
152
44.71 %
Catalytic Afterburner
20
Control of % 02 in Comb. Air
0.59%
Fabric Filter High Temp
0.29%
Miscellaneous Control Devices
0.29%
Modif. Furnace/Burner Design
0.29%
Total (Without Blanks)
340
11 -Sep-97
Page
VIII - 16
-------
Spark Ignition Gaseous Fuels - Natural Gas : 4-Stroke and Rich Burn
Criteria II: With blanks
Control Device Description Count Percentage
No Equipment 697 78.76%
Catalytic Reduction 163 18.42%
Catalytic Afterburner 20 2.26%
Control of % 02 in Comb. Air 2 0.23%
Fabric Filter High Temp 1 0.11%
Miscellaneous Control Devices 1 0.11%
Modif. Furnace/Burner Design 1 0.11%
Total (With Blanks) 885
11 -Sep-97 Page
VIII - 17
-------
Spark Ignition Liquid Fuel
Criteria I: Without blanks
Control Device Description
Count
Percentage
No Equipment
Catalytic Reduction
Steam or Water Injection
Catalytic Afterburner
Ammonia Injection
Total (Without Blanks)
11 -Sep-97
293 91.56%
15 4.69%
6 1.88%
4 1.25%
2 0.63%
320
Page 1
VIII - 18
-------
Spark Ignition Liquid Fuel
Criteria II: With blanks
Control Device Description Count Percentage
No Equipment 547 95.30%
Catalytic Reduction 15 2.61 %
Steam or Water Injection 6 1.05%
Catalytic Afterburner 4 0.70%
Ammonia Injection 2 0.35%
Total (With Blanks) 574
11 -Sep-97
Page
1
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