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 

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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 

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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 

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