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)

A ttachments (3): Comments Letter TR-4858 Dresser-Waukesha Report #10845-R1 CAE Report

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