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MEMORANDUM 

DATE: June 8, 2011

TO: Melanie King, EPA OAQPS/SPPD/ESG

FROM: Tanya Parise, EC/R, Inc.

SUBJECT: Summary of the May 9, 2011 Teleconference with AEA Regarding Issues Related 

to Remote Areas of Alaska Subject to the CI NSPS

INTRODUCTION

A follow-up meeting was held between EPA and the Alaska Energy Authority (AEA) to 

further discuss AEA concerns related to stationary compression ignition (CI) engines located in 

remote areas of Alaska that are subject to new source performance standards (NSPS) in 40 CFR 

part 60, subpart IIII. EPA proposed amendments to the NSPS on June 8, 2010 (75 FR 32612)

and has to finalize amendments by June 8, 2011. 

ATTENDEES

Michael Horowitz, EPA Kris Noonan, Alaska Industrial Development and Export Authority

Bob Wayland, EPA Chris Mello, Alaska Industrial Development and Export Authority

Melanie King, EPA Steve Stassel, Alaska Energy and Engineering

Tanya Parise, EC/R

SUMMARY OF TELECONFERENCE

EPA had a prior discussion with representatives from AEA on March 23, 2011 (see 

summary of that meeting available from the docket EPA-HQ-OAR-2010-0295). During that 

meeting, EPA and AEA discussed the unique issues facing stationary diesel engines located in 

remote areas of Alaska in terms of complying with the requirements under the CI NSPS. 

Specifically, the cost of purchasing, installing and maintaining diesel particulate filters (DPF) is 

a concern according to AEA. 

EPA asked if additional information had been obtained from DPF vendors since the 

previous meeting. AEA indicated that it had talked with DPF vendors since the last meeting 

with EPA and was quoted a price between $5,000 and $30,000 depending on the size and 

manufacturer of the DPF. AEA explained that DPF installation would be unlike pre-engineered 

solutions such as Tier 4i original engine manufacturer (OEM) options, for instance from 

manufacturer John Deere, which has been tested in a research and development environment. 

According to AEA, installing DPF in remote Alaska is not cost effective, and opposed to the 

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compact solutions offered directly from the OEM, DPF would not be favorable because each 

power plant would require a unique installation and design. AEA noted that it does not know 

what the installation costs would be because it would have to be assessed on a case-by-case basis 

and would depend on the number of engines at the plant. According to AEA each power plant 

has three to four engines. AEA estimated, however, that the installation would cost at least 

$15,000 for a $5,000 DPF and perhaps up to $40,000 or $50,000 for other sites. AEA 

emphasized that the installation cost is much higher than the capital cost of the DPF unit and the 

cost would be multiplied by the number of engines at the power plant so the cost would be three 

to four times higher per plant. In addition, modifications to the plant may also be necessary to 

accommodate the installation and maintenance of the DPF, according to AEA. Plus, the majority

of power plants in remote Alaska have size concerns due to space issues. 

AEA expressed concern regarding the blended oil issue and said that none of the vendors 

it contacted could speak to that. In California, AEA said that the material from the DPF is 

considered hazardous waste. In remote Alaska, there are no permitted waste facilities. Also,

none of the 140 power plants have air compressors on site to vacuum the waste.

AEA stressed the point that the inventory of stationary diesel engines is much higher in 

the continental United States and questioned how it is determined that a single engine should be 

treated the same as thousands of engines in urban areas.

AEA questioned the definition of rural areas in Alaska and expressed that it did not 

believe the current criteria of basing it upon accessibility to the Federal Aid Highway System 

(FAHS) was appropriate. 

Finally, AEA inquired about the definition of reconstruction in the proposal, which was a 

departure from how the term has previously been defined. According to AEA, rebuilds and 

overhauls are performed in order to achieve 60,000 or more hours from the engine.