-----Forwarded by Melanie King/RTP/USEPA/US on 02/15/2010 10:53PM -----
To: Melanie King/RTP/USEPA/US@EPA 
From: "Eleonora Kats" <Eleonora.Kats@dep.state.nj.us> 
Date: 09/02/2009 02:46PM 
Subject: Re: NJDEP comment letter- proposed RICE NESHAP 
 
Melanie,  
 
we have the compliance stack test summary reports for each facility that are 
prepared by the NJDEP Bureau of Technical Services.  Attached is the example 
of such a report for natural gas fired lean burn engines (for Homasote). 
 
In New Jersey, we have only three tests for formaldehyde.  One more is planned 
by the end of this year.  
 
I understand that you need test methods listed. I will ask our Bureau of 
Technical Services to help.  I am not sure if we have those papers in 
electronic form. 
 
Eleonora 
 
 
>>> <King.Melanie@epamail.epa.gov> 9/2/2009 11:42 AM >>> 
Hi, 
In the NJDEP comment letter there was an attachment that provided some 
stack test results for diesel engines and natural gas 4SLB engines. 
Would it be possible for us to obtain copies of the actual test reports 
for those tests?  In order for us to incorporate stack test data in our 
analysis, we typically require the test report so that we can verify the 
test methods that were use and that type of thing. 
 
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  
 
 
|------------> 
| From:      | 
|------------> 
  >---------------------------------------------------------------------------
---------------------------------------------------------------| 
  |"Eleonora Kats" <Eleonora.Kats@dep.state.nj.us>                             
                                                              | 
  >---------------------------------------------------------------------------
---------------------------------------------------------------| 
|------------> 
| To:        | 
|------------> 
  >---------------------------------------------------------------------------
---------------------------------------------------------------| 
  |Melanie King/RTP/USEPA/US@EPA                                               
                                                              | 
  >---------------------------------------------------------------------------
---------------------------------------------------------------| 
|------------> 
| Date:      | 
|------------> 
  >---------------------------------------------------------------------------
---------------------------------------------------------------| 
  |06/01/2009 10:42 AM                                                         
                                                              | 
  >---------------------------------------------------------------------------
---------------------------------------------------------------| 
|------------> 
| Subject:   | 
|------------> 
  >---------------------------------------------------------------------------
---------------------------------------------------------------| 
  |NJDEP comment letter- proposed RICE NESHAP                                 
                                                               | 
  >---------------------------------------------------------------------------
---------------------------------------------------------------| 
 
 
 
 
 
Melanie, 
 
here's the NJDEP comment letter.  The hard copy is in the mail.  We did 
not comment on emergency engines testing as we discussed, we were trying 
to make a short letter. 
 
Please let me know if your have any questions, 
Thanks, 
Eleonora 
 
>>> <King.Melanie@epamail.epa.gov> 5/7/2009 1:59 PM >>> 
I've had lots of phone calls from people asking what is the point of 
having an emission limit if you don't require a test to demonstrate 
compliance so I expect we'll get a lot of comments on that. 
 
Thanks, 
Melanie 
 
 
 
             "Eleonora Kats" 
             <Eleonora.Kats@d 
             ep.state.nj.us>                                         To 
                                      Melanie King/RTP/USEPA/US@EPA 
             05/07/2009 01:52                                        cc 
             PM 
                                                                Subject 
                                      Re: Proposed MACT ZZZZ 3/5/09 
 
 
 
 
 
 
 
 
 
 
Melanie, thanks for the thorough explanation. 
Eleonora 
 
>>> <King.Melanie@epamail.epa.gov> 5/7/2009 1:47 PM >>> 
The only compliance requirements for the emergency engines would be to 
operate and maintain the engine per the manufacturer's instructions and 
record the hours of operation.  There is no test required to directly 
show compliance with the emission limit. 
 
One of the main reasons for not requiring testing on emergency engines 
is because the cost of the rule would be really high if we required 
emergency units to be tested, and since they don't operate very 
frequently the decision was made to only require testing for 
non-emergency engines. 
 
 
 
 
             "Eleonora Kats" 
             <Eleonora.Kats@d 
             ep.state.nj.us>                                         To 
                                      Melanie King/RTP/USEPA/US@EPA 
             05/07/2009 11:49                                        cc 
             AM 
                                                                Subject 
                                      Re: Proposed MACT ZZZZ 3/5/09 
 
 
 
 
 
 
 
 
 
 
Melanie, thanks, that's very helpful. 
 
As to emergency engines, the proposed Table 2d line 7 and 14 have 
numerical lifts  for emergency SI and CI engines.  If there is no tests, 
then what are the means of compliance? 
 
Thanks, 
Eleonora 
 
>>> <King.Melanie@epamail.epa.gov> 5/7/2009 11:39 AM >>> 
Hi, 
Emergency engines are not required to do an initial stack test.  That 
sentence is misleading and probably should have read "Owners and 
operator of existing non-emergency stationary RICE . . . " 
 
A landfill gas engine that is >500 HP would have to do an initial test. 
It would fall under line 9 in table 5 as an existing stationary 
non-emergency RICE >=100 HP located at an area source complying with the 
requirement to limit the CO concentration.  Only the area source 
landfill gas engines >500 HP have a CO limit so those are the ones that 
have to do a test. 
 
Melanie 
 
 
 
 
             "Eleonora Kats" 
             <Eleonora.Kats@d 
             ep.state.nj.us>                                         To 
                                      Melanie King/RTP/USEPA/US@EPA 
             05/07/2009 11:27                                        cc 
             AM 
                                                                Subject 
                                      Proposed MACT ZZZZ 3/5/09 
 
 
 
 
 
 
 
 
 
 
Melanie, 
 
I am reviewing the proposed MACT for RICE engines, and I've got a 
question.  In a preamble (FR page 9704), it is said that "Owners and 
operators of existing stationary RICE subject to numerical emission 
standards and that are located at area sources, as shown in Table 2 of 
this preamble, must conduct an initial performance test to demonstrate 
that they are achieving the required emission standards." 
 
My question - are emergency engines and landfill engines with numerical 
limits  subject to  an initial stack testing, similar to non-emergency 
engines? Emergency engines and landfill engines are not included in the 
proposed Table 5 that lists sources subject to testing. 
 
If no stack testing is proposed how emergency and landfill engines would 
demonstrate compliance with the limits? 
 
Please advise, 
Thanks, 
Eleonora Kats 
Principal Environmental Engineer, 
NJ DEP, Air Quality Permitting Element 
Ph: (609) 984-5932; Fax: (609) 984-6369 
E-mail: Eleonora.Kats@dep.state.nj.us  
401 East State Street, 2nd Floor  P.O. Box 027 
 Trenton NJ 08625 
 
 
 
 
 
 
 
 
 
 
 
[attachment "NESHAPZZZZ RICE DEP comments Final 5-29-09.doc" deleted by 
Melanie King/RTP/USEPA/US]