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 

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EPA-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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