~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

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~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 

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~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 

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~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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