EPA-HQ-OAR-2008-0708-DRAFT-1528.txt From: "Joseph L. Suchecki" <jsuchecki@emamail.org> To: Melanie King/RTP/USEPA/US@EPA

Date: 09/28/2012 04:24 PM Subject: RE: Questions on Engines for NESHAP

Yes – that is correct

Joe

From: Melanie King [mailto:King.Melanie@epamail.epa.gov] Sent: Friday, September 28, 2012 2:02 PM To: Joseph L. Suchecki Subject: Re: Questions on Engines for NESHAP Thanks Joe. One thing I want to make sure I'm understanding correctly, you indicated

for the third question that your members think the same requirements would be appropriate for OCS

sources as those for land-based engines. We don't really have management practices in the RICE NESHAP for large non-emergency CI engines, we have requirements for smaller non-emergency engines and for emergency engines. So are you saying the management practices for smaller non-emergency CI engines (item 1 in Table 2d of subpart ZZZZ) are also appropriate for large non-emergency CI engines?

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

"Joseph L. Suchecki" ---09/28/2012 02:52:36 PM---TO: Melanie King US EPA

From: "Joseph L. Suchecki" <jsuchecki@emamail.org> To: Melanie King/RTP/USEPA/US@EPA

Date: 09/28/2012 02:52 PM Subject: Questions on Engines for NESHAP

TO: Melanie King

US EPA

FROM: Joe Suchecki

EMA

DATE: September 28, 2012

RE: Responses to Questions Regarding Engine Issues for NESHAP

In response to three of your recent questions on stationary engine issues and proposed changes to the stationary engine NESHAP and NSPS regulations, EMA

Page 1EPA-HQ-OAR-2008-0708-DRAFT-1528.txt submits the following. 1 How can owners determine sited-rated horsepower of an engine? It appears that is most cases the site-rated horsepower of a stationary engine is indicated on the engine nameplate. However, in some cases, and depending on engine manufacturer practice, the maximum engine horsepower or family horsepower is indicated on the nameplate rather than the specific site-rated horsepower. If the owner/operator is uncertain, they can use the nameplate horsepower which will always be higher or equal to the actual site-rated horsepower of the engine. Alternatively, the owner/operator can contact the engine manufacturer with the serial number of the engine, and most, if not all, manufacturers will be able to supply to needed information.

2 Do all rich-burn engines emit uncontrolled CO at levels between 1000- 1500 ppm? Although many stationary rich-burn engines may emit CO at levels somewhere in that range, engine manufacturers provided examples of engines that emit either above or below that level. So, while that is a good benchmark for many rich-burn engines, it is not an absolute range. Uncontrolled emissions from stationary rich-burn engines can be both above and below that range.

Having said that, EMA believes it would be appropriate to establish a PPM CO standard for rich burn engines based upon a 75% reduction in emissions, or alternatively to harmonize with the NSPS for new engines and use a value of 270 ppm as a standard. Given the variability of engine CO emissions, a 270 standard would likely result in some engines having to reduce CO more than 75% and some engines would have to reduce CO less than 75%.

. 3 Are different maintenance practices needed for Outer Continental Shelf engines if EPA were to adopt EMA’s recommendations to align requirements of OCS engines with those of remote-area land based engines? The basic answer is no – no additional or different maintenance practices are required for offshore/OCS engines. EMA would recommend the same requirements for those engines as for land-based engines.

Please let me know if you need additional information or if you have questions

on the above.

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