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|"Dave Warner" <dave.warner@valleyair.org> |

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|Melanie King/RTP/USEPA/US@EPA |

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|09/21/2011 12:06 PM |

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|RE: IC engine inventory |

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Hi Melanie,

Please see my answers below...

Dave Warner

Director of Permit Services

San Joaquin Valley APCD

-----Original Message-----

From: King.Melanie@epamail.epa.gov [mailto:King.Melanie@epamail.epa.gov]

Sent: Wednesday, September 21, 2011 7:38 AM

To: Dave Warner

Subject: RE: IC engine inventory

Hi Dave,

Thanks so much for providing the engine inventory. As you may have heard, we

had a discussion with some of the ag industry stakeholders from California

last week, and they raised some concerns about EPA's air toxics rule for

stationary engines. We're trying to gather as much information as possible to

help us understand their concerns, so If you don't mind, I have some

additional questions for you (or if there is someone else on your staff I

should talk to, let me know).

1) One of the issues that the ag industry stakeholders raised when we spoke

with them last week is that EPA's rule would impact engines in

2013 that the engine owners were intending to replace in 2014 or 2015 to

comply with CARB or SJVAPCD rules. Do you have a sense as to whether some or

all of those 409 engines are scheduled to be replaced in the next few years?
Is there a schedule in place for replacing them? Are any of those engines

currently exempted from the CARB or SJVAPCD rules?

Yes, our District Rule 4702 requires replacement of all of these

engines with Tier III or IV by the later of 1/1/2015 or 12 years

after installation date, but not later than 6/1/2018. None of

these particular engines would be exempt.

2) Another issue that was raised during the discussion last week was that

EPA's regulation might impact engines that had been installed over the last

decade as replacements for older, dirtier (Tier 0) engines.

There seemed to be a feeling from the stakeholders that it was unreasonable to

require further reductions from engines that had been installed as

replacements for Tier 0 or Tier1/2 engines. Do you know whether any of these

engines are ones that have been installed under any of the diesel replacement

programs (like Carl Moyer) to replace older, dirtier engines? I had a

discussion about this with CARB last week and they seemed to think that most

of the replacements for stationary engines didn't really get started until

around 2006, prior to that they indicated that the focus of many of those

programs was on nonroad and onroad engines.

All of these engines are Tier 1 and 2 (Tier 0 is already illegal

in SJV and California, and all of these engines were replacements

for existing Tier 0 engines). I don’t know who you talked to at

ARB, but they are wrong. We were using Moyer program to replace

agricultural Tier 0 irrigation pump engines long before 2006, and

in fact, Tier 3 became available in 2006, so we haven’t given

money since then for Tier 1 and 2 installations.

3) Also, one concern seemed to be whether Tier 3 engines that had been

installed to replace Tier 0-2 engines would be able to meet the requirements

of the rule. As far as I know, the earliest that Tier 3 engines were available

was the 2006 model year. Since the applicability of this rule is for engines

installed mid-2006 and earlier, I'm wondering how many Tier 3 engines were

installed before June 12, 2006.

Does your inventory have any information on the Tier level of the engines?

We have records of 17 Tier 3 engines installed before June 12,

2006. These 17 units are NOT included in the 409 Tier 1 and 2

units installed before June 12, 2006.

Just one comment on the summary table: there is a row that says "All engines

report deviations or statements indicating no deviation, semiannually or

annually" - it might be a good idea to note that requirement only applies to

the engines that have to meet a numeric CO or formaldehyde limit. Engines that

are subject to the work or management practices (change oil etc.) don't have

to submit compliance reports.

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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|"Dave Warner" <dave.warner@valleyair.org>

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|Melanie King/RTP/USEPA/US@EPA

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|09/20/2011 05:08 PM

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|RE: IC engine inventory

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Hi Melanie,

Sorry that we haven't sent these numbers to you prior to this - they are just

now available:

We know of at least 409 diesel agricultural irrigation engines that are

greater than 300 bhp, and were installed prior to 6/12/06.

This is a partial list, though, because under our rules smaller farms are not

yet obligated to fully inform us of their engine inventory.

At to our understanding of ZZZZ, please review the attached summary of

requirements for existing engines, and let me know if we are missing

something.

Thanks!

Dave Warner

Director of Permit Services

San Joaquin Valley APCD
-----Original Message-----

From: King.Melanie@epamail.epa.gov [mailto:King.Melanie@epamail.epa.gov]

Sent: Tuesday, September 20, 2011 11:14 AM

To: Dave Warner

Subject: IC engine inventory

Hi,

I left you a voice mail about this, but I thought I'd try email as well.

I'm the EPA staff contact for our air toxics regulation for stationary

engines. I believe your staff is working on providing an inventory of the

number of engines in the SJV that are potentially subject to the rule. I was

asked to check with you to see if you had an idea of when you would be able to

provide that information.

Also, I wanted to make sure you are aware that the RICE NESHAP that were

promulgated last year for "existing" engines apply to engines that were

installed before June 12, 2006 (the date is installed before December 19, 2002

for non-emergency diesel engines >500 HP at major sources of hazardous air

pollutants). We already promulgated the regulations that apply to engines

installed on or after June 12, 2006 a few years ago.

Just wanted to make sure that information is getting across to folks that may

have engines subject to the rule.

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

(See attached file: 40 CFR 63 ZZZZ requirements summary.xls)