# 1 Summary of Meeting with NTSP

Regarding the Proposed Statio nary Existing RICE NESHAP

July 27, 2009

Attendees

Bob Wayland, EPA Michele Blazek, AT&T

Melanie King, EPA Barbara Patton, AT&T

Tanya Parise, AGTI Andy Mekelburg, Verizon

Chet Thompson, Crowell & Moring LLP Julianne Barnum, Verizon

Larry Bernson, Alcatel-Lucent Kathleen Tobin, Verizon (by phone)

Robin Seguin, Qwest (by phone)

Purpose of Meeting

The purpose of this meeting was to di scuss the proposed national emission

standards for hazardous air po llutants (NESHAP) for existing stationary reciprocating

internal combustion engines (RICE). The proposed NESHAP for existing stationary

RICE was published in the Federal Re gister on March 5, 2009 (74 FR 9698).

Summary of Meeting

General

The National Telecommunications Safety Pa nel (NTSP) requested to meet with

EPA to discuss the recently proposed NESH AP for stationary engines. NTSP was

represented at the meeting by a consulta nt with Crowell & Moring and various

telecommunications companies. A presen tation was provided by NTSP and is included

as Attachment 1 to this meeting summar y. The summary of this meeting will be

available in the docket for this rulema king (Docket ID No. EPA-HQ-OAR-2008-0708).

The main issues that NTSP discussed during the meeting are shown in Attachment 1 and

the specific issues addressed are pr esented in the following sections.

1. Emergency Engines

Representatives of NTSP indicated th at the telecommunica tions industry has

numerous stationary emergency engines. Th e majority of these emergency engines are

located at area sources and are all differen t sizes. EPA told NTSP that it has more

latitude with respect to stationary engines lo cated at area sources versus major sources.

NTSP said that it was exclusively meeting with EPA to discuss issues related to engines

at area sources. It is cri tical for the telecommunications industry to have reliable power,

which serves important functions including phone networks such as land lines, cell

phones, and 911 emergency service, voice-ov er-internet protocol, which many people

rely on, internet connection, wh ich services financial units , airlines and the Federal

Aviation Administration, as well as other systems.

EPA indicated that the rule is on a cour t-ordered scheduled to be finalized by

February 10, 2010. EPA has had discussions with various industr y groups, including

# 2 folks representing the pipeline i ndustry. The option of splitting the rule into two separate

rulemakings for diesel and gas engines has been discussed, but it is unl ikely that separate

rules will be developed, according to EPA.

Members from the telecommunications i ndustry indicated that the stationary

emergency engines they operate are typical ly run for less than 50 hours per year and

usually that is only for maintenance and testi ng purposes. EPA pointed out that if owners

operate under bona fide emergency situations there is no time limit of such operation.

EPA said that its primary concern is regardi ng peak shaving units and does not wish for

owners to be selling power to the grid. NTSP stated that under certain State rules,

stationary emergency generators are permitted so they cannot operate more than a certain

number of hours per year, but noted that it understands that EPA allows unlimited hours

for emergency operation.

2. Standards for Emergency Engines

NTSP indicated that there is some conf usion related to performance testing for

stationary emergency engines. Stationary emergency engi nes are expected to meet

emission standards without adding aftertreatme nt and since no performance testing is

required, members of NTSP questioned the point of having numerical emission limits.

NTSP also noted that engines may not be able to meet the proposed 40 parts per million

carbon monoxide limit and pointed out that other groups like the E ngine Manufacturers

Association and Caterpillar ha ve indicated the same concer ns. NTSP indicated that it

believed EPA could carve out emergency engine s located at area sources from the Urban

Air Toxics Strategy. Alternatively, it was recommended by NTSP that EPA explore

Generally Available Control Technology fo r emergency engines greater than 500

horsepower located at area sources and possi bly implement work pr actice standards.

EPA noted that it would explore these op tions and that it has received numerous

comments on this issue. EPA indicated that it might be possible to finalize requirements

that would be less onerous.

3. Performance Testing

Even if EPA does not require performa nce testing for stationary emergency

engines under the final rule, NTSP was con cerned that some regulatory agencies will

require it. The engines are not designed to r un at high load so owners would be required

to bring in load banks in order to conduc t testing and this is a concern to NTSP.

4. Recordkeeping

NTSP recommended that EPA allow affected sources to keep records of

compliance and other necessary documentation in a central location as opposed to onsite. Many sites are remotely located, plus more and more facilities are moving to

electronic recordkeeping, NTSP said. EPA noted that it is thinking a bout this and did not

foresee it being a problem to implemen t this provision in the final rule.

# 3 5. Emergency Definition

The current definition of emergency engine does not allow for participation in an

emergency demand response program since it is considered a financial agreement, NTSP

said. However, this type of operation is not peak shaving, NTSP added. In many cases,

the owner of the building has an agreement w ith the tenant to supply power within the

building, if needed, but the power is not sold back to the grid, according to NTSP. EPA

indicated that it needs to clarify this issue in the final rule and that it did not intend to

exclude such operation.

6. Cost Impact

In the handout provided by NTSP, exampl es of oxidation cata lyst capital costs

obtained from an engine dist ributor are provided on page 11. NTSP also provided the

quote letter from the engine di stributor, which is included as Attachment 2 to these

meeting minutes. NTSP made the point that EPA’s costs are far below actual costs and

that the financial impact on th e telecommunications industry is significant. EPA said that

it received numerous comments on this issue and that it will redo the cost analysis for the

final rule.

7. Feasibility of Controls

There may be an issue with the feasib ility of applying add-on controls to

stationary emergency engine s, NTSP said. In addition, there may also be issues

preventing application of aftertreatment ba sed on problems with older buildings, space

limitations, code issues, and so on. Also, th ere is a concern over the availability of

controls, NTSP said.

Recommendation by NTSP

Based on the concerns raised during th is meeting, NTSP recommended that EPA

exempt emergency engines at area sources fr om the final rule or adopt management

practices for these engines. EPA indicated that it will talk to the Office of General

Counsel on some of the issues raised by NTSP. EPA pointed out that it needs to have

something specific for management practices, if that is to be a valid option. Members of

NTSP indicated that it could submit more in formation to EPA on this and EPA responded

that it would be glad to get more information to support the rulemaking.

# 4 Attachment 1ProposedNationalEmissionStandardsforHazardousAirPollutantsforReciprocatingInternalCombustionEngines2WhoWeAreNationalTelecommunicationsSafetyPanel•Alcatel‐Lucent,AT&T,Embarq,SprintNextelCorporation,VerizonCommunications,Qwest,WindstreamCommunications,Inc.•Wireline,WirelessandDataServiceProvidersthroughouttheU.S.•Owners/OperatorsoftensofthousandsofemergencyRICEusedtosupportcriticalinfrastructureandmaintainservicecontinuityintheeventofcommercialpowerdisruptions3Agenda•Background–Howweusetheseengines–Proposedrule•IssuesofConcern–Inclusionofemergencyengines–GACTv.MACT–COstandardforemergencyengines–Recordkeepingrequirements–DefinitionofEmergencyStationaryRICE•Impact•Recommendations4Background‐HowWeUseTheseEngines•Providebackuppowerto:–DataCommunicationServices–VoiceCommunication•Wireline•Wireless•911Service–Otheremergencyservices•ReliablecommunicationisacriticalsupportfunctioninHomelandSecurityNationalResponseFramework5Background– ProposedRule•ProposedamendmentstotheRICENESHAP(40CFR63SubpartZZZZ)publishedintheFederalRegisteronMarch5,2009–proposesstandardsforexistingstationaryRICEofanypowerratinglocatedatanareasourceofHAPemissions–proposesstandardof40ppmvdCOat15%O2foremergencyCIengines>500hpatareasources–includeson‐siterecordkeepingrequirementsforareasources–includesdefinitionofemergencyRICEthatcouldexcludethoseparticipatinginregionalemergencydemandresponseprograms6ConcernswiththeProposedRule(1of5)Proposedemissionlimitof40ppmvdCOat15%O2foremergencyCIengines>500hpatareasources•Inclusionofemergencyengines•EPAhasdiscretiontosetstandardsateitherMACTorGACTlevels.–GACTallowsforworkpracticestandardsforareasources–GACTanalysisnotconductedforstationaryemergencyCI>500hpatareasources•Numericlimitbasedonnon‐representativedata7ConcernswiththeProposedRule(2of5)•Existingenginesmaynotbeabletomeetthe40ppmvdat15%O2limitwithoutadd‐oncontrol–Caterpillar(DocketIDNo.EPA‐HQ‐OAR‐2008‐0708‐0099)statesthat“thenumericallimitsmustbesufficienttoallowallproperlymaintainedenginestocomply”andthat“currentproposedvaluesareinsufficienttoaccommodatethisresult”–EngineManufacturersAssociation(DocketIDNo.EPA‐HQ‐OAR‐2008‐0708‐0091)statesthat“mostemergencyengineswouldneedtoinstallsomeformofadd‐onemissionscontrolsorwouldneedtobereplacedwithanewengine”8ConcernswiththeProposedRule(3of5)Performancetesting•Preamblestatesthatareasourcessubjecttonumericemissionlimitsmustconductinitialperformancetests•ProposedRulestates:–ExistingemergencyRICE>500hpatareasourceshavenumericemissionlimit–ExistingstationaryemergencyRICElocatedatmajorsourcesnotrequiredtotest•CreatesAmbiguity9ConcernswiththeProposedRule(4of5)On‐siterecordkeepingrequirementsforareasources•Requiresrecordsbekeptreadilyaccessibleon‐siteforatleast2yearsafterthedateofeachoccurrence•ManyNTSPsitesareunmannedandhavenopracticalstorageareaon‐siteformaintainingrecords10ConcernswiththeProposedRule(5of5)DefinitionofEmergencyStationaryRICEdoesnotallowforparticipationinEmergencyDemandResponse•EmergencyDemandResponseisnoteconomicdemandresponse,andenginesarenotusedas:–Peakingpowerproductionunitprovidingpowertothegridduringtimesofhighdemand–Peakshavingunitsgeneratingelectricityforthesitewhenthecostofcommercialpowerexceedsthecostofoperatinggenerators11ImpactonTelecommunications(1of4)Costofinstallingadd‐onoxidationcatalystcontroltechnologyonexistingenginesissignificant,andtheactualperenginecostofcontrolsishigherthanEPAestimates.Perenginecostestimates749HP1,818HP2,876HPEngineDistributor(Caterpillar)estimatedminimumcapitalcost$36,000$53,000$110,000EPAestimatedcapitalcost($11.3xHP‐$170,DocketIDNo.EPA‐HQ‐OAR‐2008‐0708‐0017))$8,294$20,373$32,32912ImpactonTelecommunications(2of4)•Estimatedcostfromenginedistributordoesnotinclude:–Annualoperatingcost,includingperiodiccatalystmaintenance&replacement–Exhaustsystemresizing&mufflerreplacementifadditionofcatalystcausesbackpressureoftheexhaustsystemtoexceedfactoryguidelines–Structuralchangestoaccommodateadditionalweightofthecatalyst–Expensefortemporarygenerator‐setifrequiredduringtheconversion•ForoneNTSPmemberwithapprox.1,750engines>500HP,ifallemergencyCIengineswererequiredtoinstalladd‐oncontrols,theinitialcapitalcostwouldrangefromatleast$83milliontomorethan$150million•Additionalcostsassociatedwithtesting13ImpactonTelecommunications(3of4)Feasibilityofengineretrofit•AmericanPetroleumInstitute(DocketIDNo.EPA‐HQ‐OAR‐2008‐0708‐0242)statesthat“Enginesusedincyclicaldutyapplicationssuchas...emergencygenerators,... oftendonotachievestableoperatingtemperatureasaresultoffrequenton/offcycledemands.Therefore,itisnotfeasibletoexpectreasonableperformancefrompost‐combustioncontrolsystems.”•Sitecharacteristicsmayphysicallypreventtheadditionofcontroltechnologiesandtheassociatedsupportstructures14ImpactonTelecommunications(4of4)Availabilityofcontrolequipment–AmericanPetroleumInstitute(DocketIDNo.EPA‐HQ‐OAR‐2008‐0708‐0242)statesthat“Thehighdemandforcatalyticcontrolsthatwouldbeinitiatedbytheruleinitscurrentproposedformhasseriousimplicationsformarketdemand/capacityimbalance,feasibilityofinstallingcontrolswithinthemandatedtimeframe,andtherulecosteffectivenessanalysis”15Recommendations•Exemptfromregulationallemergencygeneratorsoperatedatareasources•Alternatively,deletethenumericstandard&adoptGACTmanagementpracticesforemergencyCIengines>500hplocatedatareasources–GACTmanagementpracticesshouldbedefinedasfollowingmanufactureroperation&maintenanceguidelinesorownerdevelopedmaintenanceplans16Recommendations•Modify40CFR63.6660(c)toaddaclauseforareasourcesstating“recordscanbemaintainedon‐siteoroff‐sitefortherequiredretentionperiod”•AmenddefinitionofemergencystationaryRICE,toincludeunitsthatparticipateinemergencydemandresponseprograms

# 5 Attachment 2

# 259 Lee Industrial Blvd., Austell, GA TEL: (770) 941-2424 FAX: (770) 941-2411



# 1 April 16 th 

# , 2009

Bo Godwin

Senior Project Manager/Design & Construction

ATT Corporate Real Estate

300 Northpoint Parkway

Alpharetta, GA 30005

Ref: Emissions Control Equipment Additions

Dear Bo,

In follow-up to our earlier conversations, I have eval uated the addition of Oxidation Catalyst to three

different sized gensets and have provided you with breakdowns on some budget costs for the addition of

this equipment. Please be aware, that costs will vary from jobsite to jobsite depending on whether the

gensets are indoor or outdoor and whether the ex haust systems will have to be redesigned to reduce

excessive backpressures upon addition of this equipment.

The gensets I evaluated are typical of units that were installed within the last 10 years and would also be

comparative of units installed within the last 15-20 y ears, given that emissions control technology of engines

has not significantly changed from the 1990’s to early 2000. For your benefit, I have also included copies of

typical emissions levels of some gensets that were installed in the last 10 years,.

Prior to addition of this equipment, each site will hav e to be individually evaluated to verify the required

design modifications required to add the Oxidation Ca talyst. In order to help you understand the process

involved in this evaluation, I have included a list of items that will have to be reviewed and evaluated for

each site prior to selecting the size and specifics of the catalyst.

I hope this information is beneficial and please let me know how else I can be of assistance.

Sincerely,



# Romey Schwieterman

Romey Schwieterman, M.E.

Senior Sales Engineer

Yancey Power Systems

Direct: 770-419-0677

Cell: 770-778-9018

# 259 Lee Industrial Blvd., Austell, GA TEL: (770) 941-2424 FAX: (770) 941-2411



# 2 

# Budget Costing

Cat 3412 Cat 3512 Cat 3516

Item 500kW 1250kW 2000kW

Cost of Catalyst $22,000 $35,000 $87,000

(80% - 90% CO Reduction)

Installation for Outdoor Unit $7,000 - $10,000 - $15,000 -

$20,000 $35,000 $45,000

Installation Costs for Indoor Unit $7,000 - $10,000 - $15,000 -

$30,000 $40,000 $50,000

Costs for Consultant $3,000 – $3,000 - $3,000 -

$10,000 $15,000 $20,000

Costs to test equipment $4,000 – $5,000 - $5,000 -

$7,500 $10,000 $10,000

Costs for Genset Technician

Notes:

1. Costs for the catalyst include the catalyst, ty pical mounting hardware and freight to the jobsite.

2. Installation cost is based on an average estimated best case to worst case scenario. Costs do not

include any expense for a temporary genset.

3. Consultant costs are the costs associated with re-engineering the genset exhaust system, enclosure

or indoor installation. This includes the costs to properly size/calculate the proper size of

components.

4. Costs to test the equipment include te chnician time and emissions measurements.

5. All costs are estimates, based on limited information and no specific jobsite information.

6. All costs are based on obtaining the product or se rvice from Yancey Power Systems. Additional

Contractor mark-ups are not included.

# 259 Lee Industrial Blvd., Austell, GA TEL: (770) 941-2424 FAX: (770) 941-2411



# 3 Project Site Evaluation Criteria

1. Determine whether the genset is indoor or outdoor.

2. Identify the CO level of reduction required for each specific site.

3. Research the CO level of the genset at production.

4. Measure the CO levels of the genset in the field to obtain a baseline.

5. Measure the backpressure of each genset to obtain a baseline.

6. Size a catalyst system based on emissi ons requirements and engine backpressure limits.

7. Evaluate the exhaust system backpressure limits for each genset and determine whether the

exhaust system will have to be r eplaced and redesigned to accommodate the addition of a catalyst.

8. Evaluate the support mechanisms for the exhaust system and catalyst. If indoor, evaluate the

location and space to accommodate the addition of the new (and upsized) equipment. If outdoor in

an enclosure, evaluate the enclosure strength or addition of support frame to mount the new

equipment.

9. Verify backpressure with the new exhaust system.

10. Verify emissions levels.



# Project Consideration Parameters

1. How disruptive will the addition of a catalyst be to the facility?

2. In the event the addition of the catalyst causes the backpressure of the exhaust system to exceed

factory guideline limits, the exhaust system will hav e to be resized and replaced with a new muffler

and/or exhaust piping. This procedure can be very di sruptive to the jobsite and result in the genset

being taken out of service for several days, w eeks or even months. Replacing a muffler on an

outdoor unit may result in the enclosure having to be removed and taken off site to access a typical

“spacesaver” type of silencer, which are typica lly mounted inside the enclosure. Replacing an

exhaust system for an indoor installation may result in sever modifications to the muffler and exhaust

piping runs.

3. Will a temporary genset be required during the conver sion? What modifications/additions to the site

will have to be performed to accommodate connecting a rental genset?

4. What structural changes will have to be made to accommodate the additional weight of the catalyst

and additional changes required?

5. Will the site accommodate cranes or other lifting devices to remove or install equipment?

6. Will work be done during normal business hours or off hours?

7. Will the system have to be retested? If so , how will this impact the facilities operations?