~6764694.txt From: "John Pertgen" <john.pertgen@iadc.org> To: Melanie King/RTP/USEPA/US@EPA Cc: "'Robertson, Dougie \(Houston\)'" <Dougie.Robertson@deepwater.com>,

<DOEV@statoil.com>

Date: 11/09/2012 03:36 PM Subject: RE: see below

Melanie:

We have below the proposed maintenance plan, modeled after those in Table 2d, that

should meet the maintenance requirements that you are seeking for the OCS source CI RICE for offshore drilling vessels on the US OCS. The highlighted portion is because we were uncertain of which table this was going to be place within.

*************************************************************************** 1. Change oil every 1000 hrs of operation or annually, whichever occurs first. Note (1) 2. Inspect and clean air filters every 750 hrs of operation or annually and/or replace as necessary 3. Inspect fuel filters every 750 hrs of operation or annually and replace as

necessary. 4. Inspect all flexible hoses every 1000 hrs of operation or annually and replace as

necessary 5. Inspect all belts, if installed, every 750 hrs of operation or annually and replace as necessary

Note (1) - Sources have the option to utilize an oil analysis program as described in §63.6625(i) in order to extend
the specified requirement in Table XX of this subpart.

*************************************************************************** Please advise if this will meet the requirements that you are seeking from our industry.

John Pertgen Director, Offshore Technical & Regulatory Affairs International Association of Drilling Contractors

10370 Richmond Ave., Suite 760

Houston, Texas 77042

PH: 713-292-1945 Ext 203

Direct: 713-292-1973

FAX: 713-292-1946

"When you get to the end of your rope, tie a knot and hang on!"

From: King.Melanie@epamail.epa.gov [mailto:King.Melanie@epamail.epa.gov] Sent: Friday, November 09, 2012 9:23 AM To: john.pertgen@iadc.org; Robertson, Dougie (Houston); DOEV@statoil.com Subject: see below

----- Forwarded by Melanie King/RTP/USEPA/US on 11/09/2012 10:20 AM -----

From: Melanie King/RTP/USEPA/US

To: Donald Evans <DOEV@statoil.com>

Date: 09/27/2012 01:11 PM Subject: RE: Offshore Operators Committee Comment Letter - Docket ID

EPA-HQ-OAR-2008-0708

Page 1~6764694.txt

Hi, Thank you for providing this information. However, we cannot use "in accordance with

manufacturer specifications" as our standard. We got similar suggestions for the 2010 rulemaking and discussed why we cannot use that for our standard. Below is an excerpt from the response to

comment document discussing the issue. This is on p. 238 of the document (http://www.epa.gov/ttn/atw/rice/existing_si_rice_rtc.pdf).

"EPA does not agree with the commenters that it would be appropriate to simply specify that owners and operators follow the manufacturers recommended maintenance practices for the engine.

EPA cannot delegate to manufacturers the final decision regarding the proper management practices required by section 112(d) of the CAA; nor can EPA allow management practices to change from engine to engine based on the views of multiple manufacturers."

Melanie King Energy Strategies Group Sector Policies and Programs Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency

Mail Code D243-01

RTP, NC 27711 Phone: (919) 541-2469 Fax: (919) 541-5450 king.melanie@epa.gov

Donald Evans ---09/26/2012 06:20:28 PM---Melanie, Per our phone conversation on Friday, Sept 14th, I have some information I’d like to provid

From: Donald Evans <DOEV@statoil.com> To: Melanie King/RTP/USEPA/US@EPA

Date: 09/26/2012 06:20 PM Subject: RE: Offshore Operators Committee Comment Letter - Docket ID

EPA-HQ-OAR-2008-0708

Melanie,

Per our phone conversation on Friday, Sept 14th, I have some information I’d like to provide to you regarding the subject comment letter and , more specifically, maintenance schedules for CI engines (> 500 HP) located on offshore platforms and exploratory drilling rigs that may become subject to the Subpart ZZZZ area source standards.

Table 2d of the proposed rule specifies the following management practices for CI categories: a. Change oil and filter every 500 hours of operation or annually, whichever comes first; [Sources have the option to utilize an oil analysis program as described in § 63.6625(i) in order to extend the specified oil change requirement in Table 2d of
Page 2~6764694.txt this subpart.]

b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary; and c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary.

Since the maintenance schedules vary from one engine manufacturer to another (i.e., Wartsila, Caterpillar, etc.) and include the same items already provided in the rule above, requiring adherence to the manufacturer specifications for these maintenance items will meet the intent of the proposed rule and help assure good engine performance. a. Change oil and filter in accordance with manufacturer specifications; [Sources have the option to utilize an oil analysis program as described in § 63.6625(i) in order to extend the specified oil change requirement in Table 2d of this subpart.][

b. Inspect air cleaner in accordance with manufacturer specifications and replace as necessary; and c. Inspect all hoses and belts in accordance with manufacturer specifications and replace as necessary.

Even though these engines can range in size up to several thousand horsepower, maintenance items and engine care are similar. Most engine owners will probably insist on following manufacturer specifications for engine maintenance in order to fulfill warranty obligations.

I hope this provides a little more perspective for you from the operator’s view. Please reply or call me at your earliest convenience if you would like to discuss further.

Donald P. Evans Chairperson, Air Quality Subcommittee Offshore Operators Committee

t: 713 485 2203

m: 832 788 9282

e: doev@statoil.com

From: Donald Evans Sent: Thursday, September 13, 2012 4:21 PM To: 'Melanie King' Subject: RE: Offshore Operators Committee Comment Letter - Docket ID

EPA-HQ-OAR-2008-0708

Hi Melanie. My schedule is open tomorrow, but I’m also available next week. Is there a particular day/time that works better for you?

From: Melanie King [mailto:King.Melanie@epamail.epa.gov] Sent: Thursday, September 13, 2012 1:46 PM

To: Donald Evans Subject: Re: Offshore Operators Committee Comment Letter - Docket ID

EPA-HQ-OAR-2008-0708

Mr. Evans, I would like to discuss your comment if you have time. Is there a good time to call you?

Melanie King Energy Strategies Group
Page 3~6764694.txt Sector Policies and Programs Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency

Mail Code D243-01

RTP, NC 27711 Phone: (919) 541-2469 Fax: (919) 541-5450 king.melanie@epa.gov

Donald Evans ---08/09/2012 03:09:53 PM---Melanie, Please find attached a comment

letter submitted

to Docket ID No. EPA-HQ-OAR-2008-0708 from

From: Donald Evans <DOEV@statoil.com> To: Melanie King/RTP/USEPA/US@EPA

Date: 08/09/2012 03:09 PM Subject: Offshore Operators Committee Comment Letter - Docket ID

EPA-HQ-OAR-2008-0708

Melanie,

Please find attached a comment letter submitted to Docket ID No.

EPA–HQ–OAR–2008–0708 from the Offshore Operators Committee regarding the proposed rule for NESHAPS for Reciprocating Internal Combustion Engines published June 7, 2012.

If you need additional information or would like to discuss, please reply to this

email or call me at 713-485-2203.

Sincerely,

Donald P. Evans Chairperson, Air Quality Subcommittee Offshore Operators Committee

t: 713 485 2203

m: 832 788 9282

e: doev@statoil.com

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