----- Forwarded by Melanie King/RTP/USEPA/US on 02/23/2011 03:50 PM

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 |"Walker, Jon" <jwalke1@wyo.gov> 

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 |"Hanify, Chris" <CHanif@wyo.gov>, "O'Dell, Jamie" <JO'Del@wyo.gov>, "Gill, 

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 |02/23/2011 02:23 PM 

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 |Re: FW: NSPS Subpart JJJJ 

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Hi,

I believe that is a typo and it should read ". . . petroleum refining or 
natural gas production." Many of the definitions we use in subparts ZZZZ, 

IIII, and JJJJ were developed by an EPA Work Group during the late 1990s and 

early 2000s called the ICCR (Industrial Combustion Coordinated Rulemaking), 

and we looked back at some of the old ICCR memos, and it looks like it was 

"or" in those memos. See attached. I'll add this to my list of corrections 

that need to be made to ZZZZ and JJJJ, thank you for pointing it out.

(See attached file: EPA-HQ-OAR-2002-0059-0047 (3).pdf)(See attached

file: EPA-HQ-OAR-2002-0059-0334.pdf)

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

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Robert" <RGill@wyo.gov> |

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 |02/17/2011 03:49 PM 

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 |FW: NSPS Subpart JJJJ 

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(Embedded image moved to file: pic11837.gif) Hi Melanie,

A quick question on the definition of LPG in Subpart JJJJ, From below:

NSPS subpart JJJJ says that “Liquefied petroleum gas means any liquefied 

hydrocarbon gas obtained as a by-product in petroleum refining of natural gas 

production.”

For propane, under NSPS subpart JJJJ it will be LPG if it comes from petroleum 

refining whereas it would be natural gas if it came straight from a gas plant 

(sans petroleum refining) based on some of the background information.

So, is the definition in the standard a typo (should read “. . .

by-product in petroleum refining or natural gas production.”) or does the 

process used to extract the propane affect its definition under this standard?

In other words, is propane that results from processing natural gas considered 

LPG under JJJJ?

Thanks for all of the help,

Jon

Jon Walker

Air Quality Engineer

WDEQ/AQD Lander Field Office

510 Meadowview Drive

Lander, WY 82520

jwalke1@wyo.gov

Ph. 307-335-6960

Fx. 307-332-7726

Cell: 307-349-0006
OAR-2002-0059 

I I-B-25 

:ALPHA-GAMMA 

-r E c H N o L o G I E s , I N c . 

MEMORANDUM 

DATE: July 21,2000 

SUBJECT: Preliminary Compilation of Definitions Used in the Reciprocating Internal 

Combustion Engines NESHAP 

FROM: Jennifer Snyder and Brahim Richani 

Alpha-Gamma Technologies, Inc. 

TO: Sims Roy, EPA OAQPS ESD Combustion Group 

The purpose of this memorandum is to document the definitions used in the National 

Emission Standard for Hazardous Air Pollutants (NESHAP) for Reciprocating Internal 

Combustion Engines (RICE), and its supporting documents. 

The following definitions were compiled from a variety of sources. These definitions are 

consistent with definitions used in existing federal, state, and local rules and permits. 

They are also intended to be consistent with the terms being used within affected 

indusitries using large, stationary, internal combustion engines. An initial compilation of 

definitionis was formulated by the Reciprocating Internal Combustion Engine Work 

Group of the Industrial Combustion Coordinated Rulemaking. Many of those definitions 

are included in the following list either in their original form or a somewhat modified 

form. EPA anticipates that the definitions in the following list will be used in the RICE 

N ES HAF'. 

Air-to--Fuel Ratio means the ratio of the air mass flow rate to the fuel mass flow rate. 

Brakealecific Fuel ConsumDtion means the input heat rate of the engine, based on 

the lower heating value of the fuel, expressed on the basis of power output (Le., kJNVhr.). 

-- Clean Gaseous Fuel means any fuel which is either natural gas, propane, process gas, 

or liquid petroleum gas. 

Compression Ignition Engine means any stationary RICE in which a high boiling point 

liquid fuel injected into the combustion chamber ignites when the air charge has been 

1 
compressed to a temperature sufficiently high for auto-ignition, including diesel engines 

and dual-fuel engines. 

Diesel Einaine means any stationary RICE in which a high boiling point liquid fuel 

injected iinto the combustion chamber ignites when the air charge has been 

compressed to a temperature sufficiently high for auto-ignition. This process is also 

known as compression ignition. 

--- Diesel Fuel means a liquid obtained from the distillation of petroleum with a boiling point 

of approximately 150 to 360 OC. One commonly used form is fuel oil number 2. 

Disester- means a gaseous by-product of wastewater treatment, formed through 

the anaerobic decomposition of organic waste materials, and composed principally of 

methane and CO,. Other constituents may include, but are not limited to, trace 

amounts of hydrogen sulfide, ammonia, volatile organic compounds, particulate matter, 

chlorinatled compounds, and siloxanes. 

-- Dual-Fuel Engine means any stationary RICE in which a liquid fuel (typically diesel fuel) 

is used for compression ignition and gaseous fuel (typically natural gas) is used as the 

primary fuel. 

Emeraencv Power Unit means any stationary RICE that operates as a mechanical or 

electrical power source when the primary power source for a facility has been rendered 

inoperable by an emergency situation. Examples include (1) when electric power from 

the local utility is interrupted or becomes unreliable and (2) to pump water in the case of 

fire or flood. This subcategory would not include (1) peaking units at electric facilities 

and (2) engines at industrial facilities that typically operate at low capacity factors, but 

are not cohfined to emergency purposes. 

~- Exhaust Gas Recirculation means a method of NO, reduction that dilutes the fresh 

air/fuel mixture by recycling a fraction of the engine exhaust gas into the intake 

manifold. 

-- Four-Stroke Enaine means a type of engine which completes the power cycle in two 

crankshaft revolutions, with intake and compression strokes in the first revolution and 

power arid exhaust strokes in the second revolution. 

Gas EInqb means any stationary RICE in which a gaseous fuel is ignited by an electric 

spark. This process is also known as spark ignition. 

--___. Gaseous) Fuel means a material used for combustion which is normally a gas with a 

heating value at standard temperature and pressure. 

2 
-- Kerosene/Nashtha means a liquid fuel containing refined, partly refined or unrefined, 

petroleum products and liquid products of natural gas not less than IO percent of which 

distill below 347 OF and not less than 95 percent of which distill below 464 OF. 

--- Landfill Gas means a gaseous by-product of the land application of municipal refuse, 

formed tlhrough the anaerobic decomposition of waste materials, and composed 

principally of methane and CO,. Other constituents may include, but are not limited to, 

trace amiounts of hydrogen sulfide, ammonia, volatile organic compounds, particulate 

matter, chlorinated compounds, and siloxanes. 

-- Lean Burn Enaine means any two-stroke or four-stroke engine where the 

manufaciyrers recommended operating aidfuel ratio divided by the stoichiometric 

aidfuel ratio is greater than 1 .I. 

Liquid Fuel means fuels in liquid form at standard temperature and pressure, including 

but not limited to diesel, residuakrude oil, kerosenelnaphtha (jet fuel), and gasoline. 

Liquefied Petroleum Gas means a liquefied hydrocarbon gas obtained as a by-product 

in petroleum refining or natural gas production. 

-- Natural Aspiration means a method of air intake using negative cylinder pressure and 

exhaust elimination using positive cylinder pressure. 

-~- Natural Gas means a naturally occurring mixture of hydrocarbon and non-hydrocarbon 

gases found in geologic formations beneath the Earth’s surface, of which the principal 

constituent is methane. May be field or pipeline quality. 

-- Non-Selective Catalytic Reduction (NSCR] means an add-on catalytic NO, control 

device for rich burn engines that, in a two step reaction, promotes the conversion of 

excess oxygen, NO,, CO, and VOC into CO,, nitrogen, and water. 

Oxidation Catalvst means an add-on catalytic control device for lean burn engines that 

controls CO and volatile organic compounds by oxidation. 

Peakina Unit or Enaine means a standby engine intended for use during periods of high 

demand that are not emergencies. 

Pre-Combustion Chamber means a method of NO, reduction for lean burn engines in 

which the combustion of a fuel-rich mixture in an auxiliary combustion chamber 

propagates to the main combustion chamber, stabilizing main chamber combustion. 

-- Pre-Stratified Charue means an add-on NO, control device applicable to rich burn 

engines that lowers combustion temperatures by injecting addition air into the intake 

manifold next to the intake valve as it opens at the start of a new cycle. 

3 
ProDane means a colorless gas derived from petroleum and natural gas, with the 

mo1ec:ular structure C,H, suitable for use in spark-ignited internal combustion engines. 

~- Reference Ambient Conditions means a standard air temperature (29.4 "C, or 85 OF), 

humidity (17 grams H,O/kg dry air, or 75 grains H,O/lb dry air), and pressure (101.3 

kilopascals, or 29.92 in. Hg). 

-- ResiduallCrude Oil means a liquid or semi-liquid fuel resulting from the distillation of 

petroleum and containing largely asphaltic hydrocarbons. Also known as asphaltum oil, 

liquid asphalt, black oil, petroleum tailings, and residuum. 

-~ Rich L3srrn Enaine means any four-stroke spark ignited engine where the manufacturers 

recommended operating aidfuel ratio divided by the stoichiometric aidfuel ratio is less 

than or equal to I .I. 

Scavenainq means the combined intake and exhaust process where the cylinder is 

cleared of burned gases, and filled with a fresh mixture or with air. 

-- Selective! Catalvtic Reduction (SCR) means an add-on catalytic NO, control device for 

lean burn engines that promotes the conversion of NO, and a reducing agent, typically 

ammonia, into nitrogen and water. 

-- SmallEngrne means any stationary engine with a manufacturer's nameplate rating of 

less than or equal to 500 brake horsepower. 

Spark Ignition Engine means a type of engine in which a compressed aidfuel mixture is 

ignited by a timed electric spark generated by a spark plug. 

-- Stationary Reciprocating Internal Combustion Engine means any internal combustion 

engine which uses reciprocating motion to convert heat energy into mechanical work 

and which is not mobile. Stationary RICE differ from mobile RICE in that stationary 

RICE are! not self propelled, intended to be propelled while performing their function, or 

portable lor transportable as that term is identified in the definition of non-road engine at 

40 CFR 139.2 (located in the RICE NESHAP Docket A-95-35, Document Number 11-A-8). 

Stoichiometric means the theoretical air to fuel ratio required for complete combustion. 

Two-StrQke Engine means a type of engine which completes the power cycle in single 

crankshaft revolution by combining the intake and compression operations into one 

stroke! anid the power and exhaust operations into a second stroke. This system 

requires auxiliary scavenging and inherently runs lean of stoichiometric. 

Turbo charging means a method of air induction, using an exhaust gas driven turbine to 

power an1 auxiliary air compressor to increase the charge density of the air at the engine 

inlet. 

4 
A-95-35 

ll-K-6 

MEM 0 R A N D U M: 

DATE: September 3, 1998 

SUBJECT: Summary of Proposed Definitions for Stationary Internal Combusti 

Engines 

FROM: Reciprocating Internal Combustion Engine Work Group 

TO: ICCR Coordinating Committee 

The Reciprocating Internal Combustion Engine Work Group (RICE WG) compiled a list of 

recommended definitions which may pertain to the development of a MACT standard for RICE. 

The definitions have been divided into two sections: 

1. Definitions On Which Consensus Was Reached: These are definitions on which WIG 

members reached consensus. 

2. Definitions On Which Consensus Could Not Be Reached: These are definitions to which WG 

members had a greater amount of disagreement. This includes cases where certain members 

stated that the definition should not be forwarded, and other members felt the definition was 

important for the rulemaking. 

The comments on “rich burn” are listed in a separate document, entitled “Definition of ‘Rich 

Burn Engiine’ for the RICE MACT Standard,” because of the importance and length of comments 

of this definition. The definition for “lean burn” will be based on that of “rich burn.” 

i 
DEFINITIONS ON WHICH CONSENSUS WAS REACHED 

1. Stationary Reciprocating Internal Combustion Engine: any internal combustion engine 

which uses reciprocating motion to convert heat energy into mechanical work, that is not 

mobile. Stationary RICE differ from mobile RICE in that stationary RICE are not self 

propelned, intended to be propelled while performing their function, or portable or 

transportable as that term is identified in the definition of non-road engine at 40 CFR 

Section 89.2. 

2. Emergency Power Unit: any stationary reciprocating internal combustion engine that 

operates as a mechanical or electrical power source during emergencies, or for scheduled 

maintenance checks or operator training. Examples include 1) when electric power from 

the local utility is interrupted or becomes unreliable and 2) to pump water in the case of 

fire or flood. This subcategory would not include 1) peaking units at electric utilities; and 

2) engines at industrial facilities that typically operate at low capacity factors, but are not 

confined to emergency purposes. 

3. Dual-Fuel Engine: any stationary RICE in which a liquid fuel (typically diesel fuel) is 

used for compression ignition and gaseous fuel (typically natural gas) is used as the 

primary fuel. 

4. Brake Specific Fuel Consumption: the input heat rate of the engine, based on the lower 

heating value of the fuel, expressed on the basis of power output (i.e., kJNV-hr.)). 

5. Spark 1:gnition Engine: a type of engine in which a compressed aidfuel mixture is 

ignited by a timed electric spark generated by a spark plug. Also known as Otto Cycle. 

6. Two Stroke Engine: a type of engine which completes the power cycle in a single 

crankshaft revolution by combining the intake and compression operations into one stroke 

and the power and exhaust operations into a second stroke. This system requires auxiliary 

scavenging and inherently runs lean of stoichiometric. 

7. Four Stroke Engine: a type of engine which completes the power cycle in two 

crankshaft revolutions, with intake and compression strokes in the first revolution and 

power and exhaust strokes in the second revolution. 

8. Digester Gas: a gaseous by-product of wastewater treatment, formed through the 

anaerobic decomposition of organic waste materials, and comprised principally of methane 

and CO;. Other constituents may include, but are not limited to, trace amounts of 

hydrogen sulfide, ammonia, volatile organic compounds, particulate matter, chlorinated 

compounds, and siloxanes. 

9. Landfill Gas: a gaseous by-product of the land application of municipal refuse, formed 

2 
through tlhe anaerobic decomposition of waste materials, and comprised principally of 

methane and CO,. Other constituents may include, but are not limited to, trace amounts of 

hydrogen sulfide, ammonia, volatile organic compounds, particulate matter, chlorinated 

compounds, and siloxanes. 

10. Liquilfied Petroleum Gas: a liquefied hydrocarbon gas obtained as a by-product in 

petroleum refining or natural gas production. 

11. Propane: a colorless gas derived from petroleum and natural gas, with the molecular 

structure C,H,, suitable for use in spark-ignited internal combustion engines. 

12. Liquid Fuel: fuels in liquid form at standard temperature and pressure, including but 

not limited to diesel, residualkrude oil, kerosendnaphtha (jet fuel), and gasoline. 

13. Natural Gas: a naturally occurring mixture of hydrocarbon and non-hydrocarbon 

gases fsuntd in geologic formations beneath the Earth’s surface, of which the principal 

constituent is methane. May be field or pipeline quality. 

14. ResidiuaVCrude Oil: a liquid or semi-liquid fuel resulting from the distillation of 

petroleum and containing largely asphaltic hydrocarbons. Also known as asphaltum oil, 

liquid asplhalt, black oil, petroleum tailings, and residuum. 

15. KeroslenelNaphtha: a liquid fuel containing refined, partly refined or unrefined, 

petroleum products and liquid products of natural gas not less than 10 percent of which 

distill belolw 347 OF and not less than 95 percent of which distill below 464 O F. 

16. Small Engine: any stationary engine with a manufacturer’s nameplate rating of less 

than or equal to 200 brake horsepower. 

17. Stoichiometric: the theoretical air to fuel ratio required for complete combustion. 

18. NSCR.: non-selective catalytic reduction; an add-on catalytic NO, control device for 

rich burn lengines that, in a two step reaction, promotes the conversion of excess oxygen, 

NO,, CO and VOC into CO,, nitrogen and water. 

19. SCR: selective catalytic reduction; an add-on catalytic NO, control device for lean 

burn engines that promotes the conversion of NO, and a reducing agent, typically 

ammonia, into nitrogen and water. 

20. Oxidation Catalyst: an add-on catalytic control device for lean burn engines that 

controls CO and volatile organic compounds by oxidation. 

21. Air do Fuel Ratio: the ratio of the air mass flow rate to the fuel mass flow rate. 

3 
22. Natuiral Aspiration: a method of air intake using negative cylinder pressure and 

exhaust ellimination using positive cylinder pressure. 

23. Turbocharging: a method of air induction, using an exhaust gas driven turbine to 

power an auxiliary air compressor to increase the charge density of the air at the engine 

inlet. 

4 
DEFINITIONS ON WHICH CONSENSUS COULD NOT BE REACHED 

1. Refeseince Ambient Conditions: standard air temperature (29.4 C, or 85 OF), humidity 

(17 grams H,O/kg dry air, or 75 grains H,O/lb dry air), and pressure (101.3 kilopascals, or 

29.92 in. Hg.). 

0 Sam Clowney: The Work Group should forward only definitions where the group can 

provide technical input or where the group has discussed the use of the definition in the 

rule. This definition has not been discussed, it is not dear how it would be used in the 

rule, and therefore it should NOT be forwarded. 

0 Bob S tachowicz teleconference comment: It is important to include this definition. 

2. Peak Lload: operation at 100 percent of the manufacturer's design capacity. 

0 Bob Stachowicz: It is important to include this definition. While the phrase 'I ... operation 

at 100 percent of the manufacturer's design capacity" seems clear it may be open to 

interpretation. Many manufacturers define a maximum engine load at each available 

engine speed. This could result in several "peak" loads being available. If you mean the 

maximum rating the engine is capable of, the definition may read better as "...operation at 

1001 percent of the manufacturer's design capacity at the maximum rated engine speed." 

0 Sam Clowney: The Work Group should forward only definitions where the group can 

provide technical input or where the group has discussed the use of the definition in the 

rule. This definition has not been discussed, it is not clear how it would be used in the 

rule:, and therefore it should NOT be forwarded. 

0 Don Price: It is important to include this definition. In place of 100 percent of the 

manufacturer's design capacity, use maximum instantaneous operating load. 

3. Diesel Engine: means any stationary reciprocating internal combustion engine which 

utilizes compression ignition as the firing initiator and burns a high boiling point liquid 

fuel. 

0 Bob Stachowicz: EPA is adding language to the final rulemaking for tiers 2 and 3 of the 

Noriroad CI (37 kW) rule to define a CI engine as follows: "Compression ignition engine 

means an engine with operating characteristics significantly similar to the theoretical 

diesel combustion cycle. The non-use of a throttle to regulate intake air flow for 

controlling power during normal operation is indicative of a CI engine.'' See also the 

"Compression Ignition" definition, #16, on page 6. EPA should choose one consistent 

5 
definition for a diesel, or CI, engine. 

Some of the fuels definitions appear to be inconsistent. See # 5, #7, and API suggested 

definitions on page 5. In #5, a diesel engine bums "a high boiling point liquid fuel". The 

AF'I suggested definition for a high boiling point liquid fuel is a fuel 'I... which has a 

boiling point equal to or greater than diesel fuel" These are circular definitions. 

Don Price: any stationary RICE in which a high boiling point liquid fuel injected into the 

combustion chamber ignites when the air charge has been compressed to a temperature 

Sufficiently high for auto-ignition. 

4. Compression Ignition: means a type of ignition which utilizes a relatively high 

compression ratio and resultant high temperatures to produce auto-ignition of fuel in the 

cylinder. Also known as Diesel Cycle. 

Don Price: see diesel engine definition: any stationary RICE in which a high boiling 

point liquid fuel injected into the combustion chamber ignites when the air charge has 

been compressed to a temperature sufficiently high for auto-ignition. 

5. Diesel: fuel for diesel engines obtained from distillation of petroleum. Also known as 

fuel oil number 2. 

Bo'b Stachowicz: I would suggest that diesel fuel be more explicitly defined as 

"substantially equivalent to fuel oil #2" (see #30 on page 7) or incorporate an actual 

ASTM definition, or use cut points to define high temperature (see the definition for 

kerosene on page 7 -- which may have been extracted from an ASTM definition). 

Don Price: (add fuel to the defined word: diesel fuel). a liquid obtained from the 

distillation of petroleum with a boiling point of approximately 150 to 360 "C. Also 

known as fuel oil number 2. 

Bill Walker: If diesel engines are defined according to the fuel they use, defining diesel 

fuel as fuel oil #2 or higher doesn't work. In Alaska, and I expect in northern tier states 

such as Minnesota or North Dakota, lighter weight fuels may be used, especially but not 

only in the winter time. #1 or Jet A is used here. So is DFA, which is an arctic grade 

which I believe is based on military specifications, and is similar to #l. Lighten: grades 

are used here because: 

#2 gels in extreme cold; 

#2 diesel made in Alaska still contains up to 0.5% sulfur; if an operator uses a lower 

6 
sulfur fuel to avoid causing violations of the ambient SO2 standard or increment, the 

lower sulfur content may be achieved by blending with Jet A; 

On the North Slope, the topping plants probably don't make diesel fuel as heavy as #2. 

6. Gas Engine: means any stationary reciprocating internal combustion engine burning a 

gaseous fuel and ignited by an electric spark. 

8 Doin Price: any stationary RICE in which a gaseous fuel is ignited by an electric spark. 

7. Unmanned Engine: means any stationary engine installed and operating at a location 

which does not have an operator regularly present at the site for 24 hour intervals. 

8 Bob S tachowicz: Definitions #8, Unmanned Engine, and #, Non-Remote Operation, 

appear to be the inverse of each other. I suggest that # be titled "Manned Engine" as 

whether or not an engine is "remote" (meaning distant) does not indicate if it will be 

manned or not. 

8 Mike Milliet: It appears to me that these are complimentary definitions. Why not rename 

"NcmRemote Operation" to "Manned Engine" and define "Manned Engine" as "any 

engine installed and operating at a location which has an operator regularly present at the 

site for some portion of each 24-hour day". "Unmanned engine": "any engine installed 

and operating at a location which does not have an operator regularly present at the site 

ffor !some portion of each 24-hour day". 

8 Sam Clowney: The Work Group should forward only definitions where the group can 

provide technical input or where the group has discussed the use of the definition in the 

rule. This definition has not been discussed, it is not clear how it would be used in the 

rule, and therefore it should NOT be forwarded. 

e Don Price: any stationary RICE installed and operating at a location for which an 

opeirator is not regularly present at intervals of 24 hours or more. 

8. Non-Remote Operation: means any engine installed and operating at a location which 

has an operator regularly present at the site for some portion of a 24-hour day. 

8 Bob1 Stachowicz: Definitions #8, Unmanned Engine, and #El, Non-Remote Operation, 

appear to be the inverse of each other. I suggest that #9 be titled "Manned Engine" as 

whether or not an engine is "remote" (meaning distant) does not indicate if it will be 

manned or not. 

7 
Mike Milliet: It appears to me that these are complimentary definitions. Why not rename 

"Non-Remote Operation" to "Manned Engine" and define "Manned Engine" as "any 

engine installed and operating at a location which has an operator regularly present at the 

site: for some portion of each 24-hour day". "Unmanned engine": "any engine installed 

and operating at a location which does not have an operator regularly present at the site 

for some portion of each 24-hour day". 

Sam Clowney: The Work Group should forward only definitions where the group can 

provide technical input or where the group has discussed the use of the definition in the 

rule. This definition has not been discussed, it is not clear how it would be used in the 

rule, and therefore it should NOT be forwarded. 

Doin Price: any stationary RICE installed and operating at a location for which an 

operator is regularly present at intervals of less than 24 hours. 

9. Rotary Engine: means any Wankel type engine where energy from the combustion of 

fuel is converted directly to rotary motions instead of reciprocating motion. 

Sann Clowney: The Work Group should forward only definitions where the group can 

provide technical input or where the group has discussed the use of the definition in the 

rule:. This definition has not been discussed, it is not clear how it would be used in the 

rule, and therefore it should NOT be forwarded. 

0 Don Price: means any Wankel type engine where energy from the combustion of fuel is 

Converted directly to rotary motions using rotary pistons. 

10. Rich Blurn: (see supplementary document for these comments) 

11. Lean Burn: (will be defined subsequent to drafting the rich burn definition) 

Bob S tachowicz: "Lean burn" should reflect that lean burn engines manufactured today 

typically have 7% or more exhaust oxygen content. 

Don Price: (add "engine" to the defined word: lean burn enpine). any two or four stroke 

spark ignited engine that is not a rich burn engine. 

12. Peaking Engine: means an engine whose intended usage time is primarily standby 

operation, only for times of high demand. 

8 
a Bob Stachowicz: Waukesha has no problem with these as written. If more elaborate 

definitions should be needed, however, I would refer you to Waukesha’s Power Rating 

Chart (a copy of which you should.have). This document contains several ratings 

definitions which could be used or adopted for ICCR purposes. 

a Sam Clowney: The Work Group should forward only definitions where the group can 

prowide technicd input or where the group has discussed the use of the definition in the 

rule. This definition has not been discussed, it is not clear how it would be used in the 

rule, and therefore it should NOT be forwarded. 

a Don Price: a standby engine intended for use during periods of high demand that are not 

emlergencies. 

a Mike Horowitz: We should keep definitions of peaking unit and baseload unit because 

the:y are relevant to the definition of emergency power unit. 

a Billl Walker: This is an important definition. If an engine is used at all for peaking, then it 

should not be considered an emergency generator. Suggestion: “Peaking unit means a 

standby engine used during periods of high demand that are emergencies.” Do not use 

“only for times of high demand.” If an engine is actually used during high demand and at 

, other times then it should not be considered an emergency unit. 

13. Baselalad Engine: means an engine whose intended usage time is continuous operation. 

a Bob Stachowicz: Waukesha has no problem with these as written. If more elaborate 

definitions should be needed, however, I would refer you to Waukesha‘s Power Rating 

Chart (a copy of which you should have). This document contains several ratings 

definitions which could be used or adopted for ICCR purposes. 

a Sam Clowney: The Work Group should forward only definitions where the group can 

provide technical input or where the group has discussed the use of the definition in the 

mule. This definition has not been discussed, it is not clear how it would be used in the 

rule, and therefore it should NOT be forwarded. 

a Don Price: an engine intended for continuous operation. 

a 1Mik:e Horowitz: We should keep definitions of peaking unit and baseload unit because 

they are relevant to the definition of emergency power unit. 

14. Exhaust Gas Recirculation: means a fraction of the engine exhaust gases are recycled 

to the intake to dilute the fresh mixture for control of NO, emissions. 

9 
Sam Clowney: The Work Group should forward only definitions where the group can 

provide technical input or where the group has discussed the use of the definition in the 

rule. This definition has not been discussed, it is not clear how it would be used in the 

rule, and therefore it should NOT be forwarded. 

Don Price: a method of NO, reduction that dilutes the fresh aidfuel mixture by recycling 

a fraction of the engine exhaust gas into the intake manifold. 

15. Pre-Combustion Chamber: means an antechamber that ignites a relatively fuel rich 

mixture that propagates to the main combustion chamber and promotes thorough air to 

fuel mixing and complete combustion of the lean air to fuel ratio in the main chamber. 

Bob Stachowicz: A PCC is not designed or intended to "promotes thorough air-to-fuel 

snixing" as stated in the proposed definition. If it did it would be by coincidence. The 

purpose of the PCC is to enhance ignition of the very lean air-to-fuel mixtures used by 

many lean bum engines. See the Rationale Document, page 4, Section 1.1.2.1.1. I would 

suggest text along these lines: "means an antechamber in which a spark plug ignites a 

relatively fuel rich mixture. These burning gasses propagate into the main chamber 

through one or more smdl orifices to consistently ignite the lean air-to-fuel bulk mixture 

and lead to complete combustion." 

Sam1 Clowney: The Work Group should forward only definitions where the group can 

provide technical input or where the group has discussed the use of the definition in the 

rule. This definition has not been discussed, it is not clear how it would be used in the 

rule, and therefore it should NOT be forwarded. 

Bob S tachowicz teleconference comment: It is important to include this definition. 

Don Price: a method of NO, reduction for lean burn engines in which the combustion of 

a fuel-rich mixture in an auxiliary combustion chamber propagates to the main 

combustion chamber, stabilizing main chamber combustion. 

16. Operator: means an individual whose work duties indude the operation, evaluation, 

and/or adjustment of the combustion system, i.e. internal combustion engine. 

Sam Clowney: The Work Group should forward only definitions where the group can 

provide technical input or where the group has discussed the use of the definition in the 

rule. This definition has not been discussed, it is not clear how it would be used in the 

rule, and therefore it should NOT be forwarded. 

Bob Stachowicz teleconference comment: It is important to include this definition. 

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e Don Price: not needed. 

17. Pre-Stratified Charge: means an add-on control device applicable to lean burn engines 

which utilizes an increased air content to act as a heat sink in order to lower combustion 

temperatures. 

e Bob Stachowicz: First, "Pre-Stratified Charge" is a trademarked name similar to CooperSulperior's "Clean Bum" designation for their family of lean combustion engines. Second, 

PSC is applied to RICH burn engines to give them the operating characteristics of lean 

bum designed engines. Very briefly, in a PSC system, air (or a combination of air and 

EG;R) is injected into the intake runners of an engine immediately upstream of the intake 

valves using special tubes. When this air is drawn into the combustion chamber -- along 

with the normally rich or just lean aidfuel mixture -- it "pre-stratifies" the charge and 

gives an OVERALL lean air-to-fuel ratio. Over 7% exhaust oxygen is not uncommon. 

Thiis system allows an engine to retain its normally rich fuel system (cost saving) and still 

operate as a lean bum with attendant low NO,. The definition would be acceptable if the 

words "lean burn" were changed to "rich bum". A final phrase 'I... to reduce NO, 

emission." could be added to further clarify the purpose of this system. 

Sam Clowney: The Work Group should forward only definitions where the group can 

provide technical input or where the group has discussed the use of the definition in the 

rule. This definition has not been discussed, it is not clear how it would be used in the 

rule, and therefore it should NOT be forwarded. 

a Don Price: an add-on NO, control device applicable to rich burn engines that lowers 

combustion temperatures by injecting addition air into the intake manifold next to the 

intake valve as it opens at the start of a new cycle. 

18. Gaseous Fuel: a material used for combustion which is normally a gas with a heating 

value at standard temperature and pressure. 

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