Rule 3.22 Internal Combustion Engines
Public Workshop April 16 th , 2009

Public Comments

Q. Where can we get a copy of the presentation?
A. Tim Mitro (Mitro), Air Quality Engineer for the District, noted that the handouts were available at the meeting and said he would also post them on- line.

Q. Regarding the replacement of the non-compliant e ngines, with some involved in Natural Gas well sites, the engine is an integral part of the u nit. Therefore, the costs for replacing some engine s would be high.
A. Mitro explained that the emission limits in the draft rule are consistent with surrounding air districts as well as statewide.

Q. I’ve heard of cost being a factor in determining what is feasible for compliance with other district’s Stationary I.C. Engine Rules. Will this be a factor in this district?
A. Mitro and David A. Valler Jr. (Valler), Air Poll ution Control Officer, discussed the differences between Best Available Control Technology (BACT) fo r new installations and this rule for NOx reduction s on a day-to-day basis. We evaluated the costs and t he “feasible” emissions reductions expected for the daily operations.

Q. If we make the investment to bring the engines i nto compliance with the emission limits proposed in this Rule, are the emission limits goin g to change in a couple years and require additiona l costs?
A. Valler explained that the District does not inte nd to modify this rule, once adopted, at this time. Mitro explained that the District bases emission li mits on Best Available Control Technology, which agencies re-evaluate continually as technology adva nces.

Q. What is the possibility of issuing a horsepower (hp) restrictive permit? For example, if I have an engine that usually runs at 80 hp to perform regula r work load, but it is rated a 200 hp engine, could I have a permit that states that the engine will only operate at 80 hp?A. Karla Sanders (Sanders), Air Quality Compliance Supervisor, responded that a horsepower

restrictive permit is acceptable if the restriction s were certified by the manufacturer and verifiable in the field. Mitro responded that companies should do the source test at normal operating load. Therefore, they should test the engine at 80 hp if the normal operating load is 80 hp. Sanders questioned the reason for placing hp restrictions on the permit be cause the rule does not have different limits for different hp engines. The only reason to restrict h p is if you wanted to exempt the engine from the ru le. For example, a 60-hp engine that has hp restriction s on the permit allowing 45-hp for normal operation s would be exempt from the limits in the rule.

Q. Regarding the hp restrictive permits, have you heard of adding a governor to the engine that restricts the hp to a maximum level? There are oth er technologies, such as one used in Santa Barbara, that inserts a plate into the engine that limits hp

. A. The District is not familiar with this technolog y, but is willing to look at examples provided. St aff will follow up on this comment.

Q. Is submitting the Authority to Construct in comp liance with Rule 3.22 like starting over on a new permit?
A. Mitro responded that the ATC is not like startin g a new permit, it is a modification of an existing permit. The ATC is to document the plan intended fo r the engine to meet the deadline.

Q. Would the District have to apply BACT as part of the ATC modification?
A. Mitro responded that BACT would not be required since the engine is already installed and there is no increase in emissions.

Q. Will the District accept comments on this draft Rule by email?
A. Mitro responded that the District would accept c omments by regular mail or email before May 18, 2009.

Q. The cost to comply with the source test requirem ent of this Rule will be about $200,000.00 because I have 67 engines over 50 hp in North Sutte r County as of 2008. Hiring a company to conduct the source test, paying District staff to witness t he source test, at a max of three engines per day, plus the shut down and start up of the engines will be a significant financial burden. Can we just use the NOx analyzer to show compliance rather than the source test every five years?A. Valler stated that the NOx analyzer is not a leg al standard, nor EPA approved. Mitro stated that

while Districts to the North use the NOx analyzer o nly, the Districts to the South require source test ing, some every year rather than every 5 years that the District is proposing. The source test is required to verify that the engine is still meeting the standar d after years of use. Mitro also stated that there are other options to show initial compliance, such as s ubmitting the results of a source test performed within the past three years in another District, or if new, manufacturer supplied emissions informatio n, at the discretion of the APCO.

Q. Would there be a possibility that the source tes t requirement could be spread across the five years for facilities that have a large number of en gines?
A. The District will consider this option.

Q. Would there be a possibility for a sliding scale for multiple engine facilities?

A. The District will consider this comment.

Q. The District should consider only source testing larger engines, like over 250 hp, and only require NOx analyzer for 50-249 hp engines.

A. The District will take this comment under consid eration.

Q. What does “most cost-effective” measures mean on the presentation?
A. Mitro explained that cost-effective considers th e amount of pollutants reduced per dollar spent on controls. The District considers what source typ es could reduce the most emissions with the least amount of money. Engine emission reductions in the draft rule are the most cost effective reductions f or all the source types in the District.

Q. Many of the engine sites cannot use electric mot ors since the infrastructure is not available. Is there a lesser compliance option for engines that c annot be converted to electric motors?
A. Mitro explained that many sites would not be abl e to use electric power, but there is no lesser compliance option for these engines. The District e ncourages electric conversion for facilities that h ave existing electric power as this option results in t he most emission reductions. Valler commented that the availability of electricity increases as the area g rows.Q. Since a source test is required to measure VOC, and rich burn engines have a much lower level

of VOC than NOx, can we remove the requirement for source testing and just use the NOx analyzer to demonstrate compliance?
A. The District is not considering removing the req uirement for source testing, nor removing the emission limits for VOC, from the draft Rule.

Q. Is a lean burn Ajax engine that meets the 150-pp mv limit for NOx permissive to operate?

A. Mitro stated that it was.