EPA-HQ-OAR-2008-0708-DRAFT-0357

From: King.Melanie@epamail.epa.gov

Sent: Monday, October 05, 2009 9:34 PM

-----Forwarded by Melanie King/RTP/USEPA/US on 10/05/2009 09:26PM -----

To: Melanie King/RTP/USEPA/US@EPA 

From: "Stachowicz, Bob" <bob.stachowicz@dresser.com> 

Date: 10/05/2009 03:53PM 

cc: "Palmer, Lynn" <lynn.palmer@dresser.com>, "Siehoff, Jack" 

<jack.siehoff@dresser.com>, "Towner, Stephen" <stephen.towner@dresser.com>, 

"McDowell, Bob" <bob.mcdowell@dresser.com>, "Boeh, Cynthia" 

<cynthia.boeh@dresser.com>, "Spaulding, Dennis" <dennis.spaulding@dresser.com> 

Subject: Additional Dresser-Waukesha RICE NESHAP Test Data and Comments

References: EPA Proposed NESHAP Rule for RICE -- 74FR9698; Docket ID No. EPA-HQ-OAR-2008-

0708 

 Waukesha comments dated June 2, 2009 

 Waukesha e-mail; R. Stachowicz to M. King dated August 12, 2009 

 

Dear Ms. King, 

 

 In my previous e-mail to you, dated August 12, 2009, Dresser-Waukesha said that we had decided to 

acquire additional data in our Engineering Laboratory on the formaldehyde - THC relationship in the 

exhaust of a 4SRB SI, natural gas engine and across a catalyst in the exhaust stream to support our 

comments to Docket ID No. EPA-HQ-OAR-2008-0708 that THC was a much more suitable surrogate for 

HAP for 4SRB engines than the currently specified formaldehyde. Dresser-Waukesha and our third party 

testing firm, Clean Air Engineering (CAE) of Palatine, IL, ran a substantial program of 46 distinct 

operating conditions and obtained performance and emissions data both before (engine out) and after a 

commercially available, non-selective catalytic reduction, NSCR or 3-way, catalyst. Our two reports of 

the testing and a cover letter with additional comments are attached for your use and inclusion in the 

docket. 

 

 Dresser-Waukesha believes that these data and reports strongly support our recommendation to use 

THC as a suitable, cost effective surrogate for HAP for 4SRB engines in all RICE NESHAP rules. 

 

 For expediency, I have sent these documents as electronic attachments to this e-mail. Can you 

please confirm to me that you received everything? If you would like hard copies please let me know 

and Waukesha will send them by express delivery. If you need anything else please do not hesitate to 

contact me. 

 

 

Sincerely, 

Robert S tachowicz 

___________________________________________________________________________________________

_____________

______________________ 

Robert Stachowicz, PE | Staff Engineer | Dresser, Inc., Dresser Waukesha | 1101 West St. Paul Avenue, 

Waukesha, WI, 53188 | 

262.549.2753 | 262.549.2705 (fax) 

 

Attachments (3): Comments Letter 

 TR-4858 Dresser-Waukesha Report 

 #10845-R1 CAE Report 

 

 

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