|------------> | From: | |------------> >----------------------------------------------------------------------------- --------------------------------------------------------------| |"Dave Warner" <dave.warner@valleyair.org> | >----------------------------------------------------------------------------- --------------------------------------------------------------| |------------> | To: | |------------> >----------------------------------------------------------------------------- --------------------------------------------------------------| |Melanie King/RTP/USEPA/US@EPA | >----------------------------------------------------------------------------- --------------------------------------------------------------| |------------> | Date: | |------------> >----------------------------------------------------------------------------- --------------------------------------------------------------| |09/21/2011 12:06 PM | >----------------------------------------------------------------------------- --------------------------------------------------------------| |------------> | Subject: | |------------> >----------------------------------------------------------------------------- --------------------------------------------------------------| |RE: IC engine inventory | >----------------------------------------------------------------------------- --------------------------------------------------------------|

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

>----------------------------------------------------------------------------- --------------------------------------------------------------| |------------> | To: | |------------>

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

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>----------------------------------------------------------------------------- --------------------------------------------------------------| |09/20/2011 05:08 PM |

>----------------------------------------------------------------------------- --------------------------------------------------------------| |------------> | Subject: | |------------>

>----------------------------------------------------------------------------- --------------------------------------------------------------| |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)