----- Forwarded by Melanie King/RTP/USEPA/US on 05/16/2011 08:49 AM

----- |------------> | From: | |------------>

>--------------------------------------------------------------------------- -----------------------------------------------------------------| |"Matt Todd" <ToddM@api.org> |

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

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

>--------------------------------------------------------------------------- -----------------------------------------------------------------| |------------> | Cc: | |------------>

>--------------------------------------------------------------------------- -----------------------------------------------------------------| |Michael Horowitz/DC/USEPA/US@EPA, "John Wagner" <Wagner@api.org> |

>--------------------------------------------------------------------------- -----------------------------------------------------------------| |------------> | Date: | |------------>

>--------------------------------------------------------------------------- -----------------------------------------------------------------| |05/13/2011 09:44 AM |

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

>--------------------------------------------------------------------------- -----------------------------------------------------------------| |RE: final amendments to CI engine NSPS |

>--------------------------------------------------------------------------- -----------------------------------------------------------------|

Melanie,We agree with the proposed fix but, for your consideration, a slight change to the wording is attached that I don't think changes the intent.

Matt

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

Sent: Wednesday, May 11, 2011 11:37 AM
To: Matt Todd Cc: horowitz.michael@epamail.epa.gov Subject: final amendments to CI engine NSPS

Hi Matt, As we are drafting the final amendments to the NSPS for stationary CI engines (subpart IIII), I noticed something that I think was an oversight on our part on the proposal, but I wanted to check with you to make sure you wouldn't have any issue with us correcting the oversight in the final rule, because it is part of the amendments we are making as part of our settlement agreement with API. The text in question is in the proposed amendment to 60.4211(g)(3), which is on p. 32625 of the June 8, 2010 FR notice. We said in the proposal that if you did not install, configure, and operate the engine per the manufacturer's recommendations, or you changed the emission-related settings beyond what is permitted by the manufacturer, you have to do an initial performance test, and in 60.4211(g)(3), we said that test had to be done within 1 year after engine startup. I think that we should account for the possibility that the change to the engine's certified configuration or settings could happen later than one year after the engine startup (so for example in 2015 you might decide you needed to change the settings for a certified engine you had originally installed in 2011). We accounted for this situation in 60.4211(g)(2) with the inclusion of the text " . . . or within 1 year following the change in emission-related settings or configuration . . ." I think we need to add similar text to 60.4211(g)(3), so that it would read as shown below. I also edited 60.4211(g)(2) slightly from the proposal, because it was pointing to a paragraph that didn't exist, and also I thought the intent of the language in (g)(2) and (3) needed to be made more clear and easier to understand. I'm not trying to change the intent of the proposed language, I'm just trying to make it more clear and readable. Please take a look and let me know if you have concerns with this language by COB on Friday, May 13. Thanks.

(2) If you are an owner or operator of a stationary CI internal combustion engine greater than or equal to 100 HP and less than or equal to 500 HP, you must keep a maintenance plan and records of conducted maintenance and must, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, you must conduct an initial performance test to demonstrate compliance with the applicable emission standards within 1 year of startup, or within 1 year after you fail to install, configure, operate, and maintain your engine and control device according to the manufacturer’semission-related written instructions, or within 1 year after you change emission-related settings in a way that is not permitted by the manufacturer.

(3) If you are an owner or operator of a stationary CI internal combustion engine greater than 500 HP, you must keep a maintenance plan and records of conducted maintenance and must, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, you must conduct an initial performance test to demonstrate compliance with the applicable emission standards within 1 year of startup, or within 1 year after you fail to install, configure, operate, and maintain your engine and control device according to the manufacturer’s emission-related written instructions, or within 1 year after you change emission-related settings in a way that is not permitted by the manufacturer. You must conduct subsequent performance testing every 8,760 hours of engine operation or 3 years, whichever comes first, thereafter to demonstrate compliance with the applicable emission standards.

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: Edits to EPA proposed language NSPS IIII.pdf)(2) If you are an owner or operator of a stationary CI internal combustion engine greater than or equal to 100 HP and less than or equal to 500 HP, you must keep a maintenance plan and records of conducted maintenance and must, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, you must conduct an initial performance test to demonstrate compliance with the applicable emission standards within 1 year of startup, or within 1 year after an engine and
control device is no longer installed, configured, operated, and maintained in
accordance with after you fail to install, configure, operate, and maintain your engine and control device according to t he m anufacturer’s emission

- related written instructions, or within 1 year after you change emission

- related settings in a way that is not permitted by the manufacturer.

(3) If you are an owner or operator of a stationary CI internal combustion engine greater than 500 HP, you must keep a maintenance plan and records of conducted maintenance and must, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, you must conduct an initial performance test to demonstrate compliance with the applicable emission standards within 1 year of startup, or within 1 year after after an engine and control device is no longer installed, configured, operated, and maintained in accordance with the you fail to install, configure, operate, and maintain your engine and control device according to the
manufacturer’s emission

- related written instructions, or within 1 year after you change emission

- related settings in a way that is not permitted by the manufacturer. You must conduct subsequent performance testing every 8,760 hours of engine operation or 3 years, whichever comes first, thereafter to demonstrate compliance with the applicable
emission standards.