PDF_NEED_TO_BE_RENDERED_Cortney_Higgins_to_Melanie_King_1-11-13-2[1].txt From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov> To: Melanie King/RTP/USEPA/US@EPA Cc: RobertJ Wayland/RTP/USEPA/US@EPA, Paula VanLare/DC/USEPA/US@EPA

Date: 01/11/2013 12:55 PM Subject: RE: RICE Interagency Comments

Hi Melanie,

Here is more information for Comment 1: From a practical perspective, the most common issue that some Navy facilities experience with within their local grid is undervoltage "sags." Other Services in the same region likely have similar experiences. This occurs because locally both the utility's and the Navy's own electrical distribution corridor is heavily forested, therefore, during storms it is not uncommon for trees or tree branches to intermittently contact the lines within the power distribution corridor which tends to cause intermittent voltage drops or "sags" to be experienced upon the electrical grid. These events are very short in duration (milliseconds) but during certain storm events can happen frequently (multiple times on a shift).

Typically the tolerance of electronic devices to voltage fluctuations is dependent upon the magnitude and duration of the power quality event, this is oftentimes graphically represented by the CBEMA curve. The power from the local utility is capable of exhibiting much wider voltage fluctuation transients upon their grid than can typically be tolerated by most modern electronic devices, that's why you utilize a power conditioning strip for your expensive home electronics. Most of the government's critical sensitive loads are protected utilizing some sort of power conditioning or UPS systems. However, there are many loads that are too large or sensitive to be easily protected that way.

To illustrate this point, a critical example for the Navy is that of a warship moored at a pier. If a ship is on shore power, the shore power system which connects utility shore power to the ship has a much tighter under voltage trip point tolerance than that of the utility. There are times during storms where the utility electrical grid is experiencing power quality fluctuations where power from the utility is being maintained to the facility's fenceline, but power to the moored ship itself may be lost due to power quality fluctuations being experienced on the utility grid. For example, utility power to a critical end load (a warship) may be interrupted
multiple times during an eight hour work shift due to the Navy's internal protective shore power circuit breaker's tripping open on under voltage from the utility, even though utility power to the facility's fenceline is not completely interrupted. Typically these types of events, if isolated are

inconvenient but are dealt with. However, there are situations where multiple power interruptions cannot occur. In those instances, in the event that they occur during a storm, the Navy may employ a local operational procedure to shift the ship off of the commercial utility grid while the power quality issues are being experienced and utilize facility emergency generators to provide power to the ship in lieu of utility power. Utility power is then restored to the ship after the weather event or critical event has passed. Because this type of event represents generator operation during a loss of usable power from the utility, and based on the RICE NESHAP regulations as currently published, our local legal support reviewed those types of operations and at the time were of the opinion that we were probably safe in considering generator operations to be "emergency" in nature in such instances as long as they were associated with a tangible and documentable power quality event from the local utility (for example, two documented protective breaker trips on under voltage during an 8-hour shift)

and thus operation in such instances would not capped under the RICE NESHAP. However, the proposed amendments to the RICE NESHAP language implies that

Page 1PDF_NEED_TO_BE_RENDERED_Cortney_Higgins_to_Melanie_King_1-11-13-2[1].txt this sort of operation should be considered non-emergency in nature and operations for maintenance and testing, emergency demand response, and power quality degradation must be aggregated and cumulatively limited to 100 hours/year.

The distinction drawn by EPA (the distinction of limiting operations when power from the utility is not usable) will have a large impact on whether
the Navy is able to safely classify some of its larger utility emergency generators (in the 1.5-2.5 MW range) as emergency engines without a risk of
non-compliance due to the need to operate engines during time periods of degraded power quality due to inclement weather conditions outside of the Navy's control. In practical terms, the units in question are emergency generators. They are not utilized for prime power or peak shaving purposes and our data shows that they typically operate about 25-50 hours/year for maintenance and testing and for about 25-75 hours/year to provide power during situations where utility power is either completely lost or in situations where utility power is available but power quality is poor (typically during storms as described above). Some of this operational time
will be brought down by more active operational management and tweaking existing site Standard Operating Procedures and it is believed that with current mission requirements, in most years these types of sites will be below the 50/100 hr emergency engine operational limits and thus able to maintain status as Emergency engines. However, if operation during times of unreliable power quality is capped, the possibility exists that during a bad weather year or if a several day storm coincides with a critical operation, a given unit could conceivably violate the "Emergency" engine runtime limits established in the regulation even though the site itself would only operate during periods of maintenance and testing and when usable power from the utility was not available. Power quality events are caused by the weather or the local utility and are outside of the end-user's control, thus it would seem that operation in such instances should by definition be "emergency" operation.

In order to avoid possible instances of non-compliance the Navy is investigating upgrading many of what we considered emergency engines into compliance with the non-emergency engine standards. Upgrading these types of engines will not result in significant emission reductions, as these units are ostensibly emergency engines. Additionally, our research has shown that the cost to upgrade many of these units is considerable.

Depending upon site specific considerations we estimate a cost of approximately $200-350K per engine to upgrade an engine in the 1.5-2.5 MW
range into compliance with the RICE NESHAP emission standards for existing "non-emergency" engines. The increased estimated cost beyond EPA estimates is due to a) Cost escalators due to site security requirements and the federal acquisition process b) Many of the Navy's existing large stationary
utility generators utilize engines common in marine or locomotive applications that require specialized Diesel Oxidation Catalyst retrofit kits that must be installed pre-turbocharger due to technical issues related to backpressure caused by the catalyst. Since most of the sites in question employ 3-5 engines, bringing a site into compliance with the RICE NESHAP requirements for existing Non-Emergency Engines will cost the Navy approximately to $750K-1.25 M per site. The risk of non-compliance for
these sites if classified as "emergency" engines is largely based on the issue of how the EPA has capped the operation of generators during time periods of degraded power quality within the proposed RICE NESHAP

amendments.

From: Higgins, Cortney Sent: Thursday, January 10, 2013 2:25 PM To: King.Melanie@epamail.epa.gov Cc: Bob Wayland (Wayland.Robertj@epamail.epa.gov); VanLare.Paula@epamail.epa.gov

Page 2PDF_NEED_TO_BE_RENDERED_Cortney_Higgins_to_Melanie_King_1-11-13-2[1].txt Subject: RE: RICE Interagency Comments

Here they are – my apologies.

From: King.Melanie@epamail.epa.gov [mailto:King.Melanie@epamail.epa.gov] Sent: Thursday, January 10, 2013 1:53 PM To: Higgins, Cortney Subject: Re: RICE Interagency Comments I think you might have sent the wrong file, these are comments on the proposal.

"Higgins, Cortney" ---01/10/2013 01:49:22 PM---Hi Melanie, Attached are comments on

the RICE rule. I'll be sending over the RIA comments in an hou

From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov> To: Melanie King/RTP/USEPA/US@EPA Cc: RobertJ Wayland/RTP/USEPA/US@EPA, Paula VanLare/DC/USEPA/US@EPA

Date: 01/10/2013 01:49 PM Subject: RICE Interagency Comments

Hi Melanie, Attached are comments on the RICE rule. I’ll be sending over the RIA comments in an hour or so (it’s taking longer than I anticipated to look through the redlines).

Please let me know if you have any questions.

Regards, Cortney [attachment "RICE NESHAP Reconsideration Proposal 2060-AQ58 5-21-12 pm_InteragencycommentsunderEO13563.docx" deleted by Melanie King/RTP/USEPA/US]

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