April 27 , 2009

VIA E - MAIL Mr. Jaime Pagan Energy Strategies Group U
. S
. Environmental Protection Agency D243

- 01 Research Triangle Park, NC 27711 Re: EMA Recommendations Regarding Emergency CI Engines Greater Than 30 Liters/Cylinder and Definition of Installed Dear Mr. Pagan : At th e meet ing held between EPA and EMA at your offices on February 9, 2009, one of th e topi cs discussed was the need to revise the New Source Performance Standards (NSPS) for Com pressi on Igni

ti on (CI) engines as the regulati o n applies to engines wit h a displacement greater than 30 liters per cylinder (l/cyl). When finalized in 2006, the NSPS required owners and operators of large engines used in emergency back

- up applicat io ns to meet the same emissio ns standards as engines us ed in non - emergency, prime power applicat io ns . That regulatory approach is in contrast to the regulat io n of engines less than 30 l/cyl where the NSPS recognized th at emergency engines cannot use aftertreatment to meet emissions limits due to the potential degradation o f cri

ti cal engine performance parameters during emergency operations or natural di sasters
. To correct the above discrepancy, EMA requested that y ou consider revising the CI NSPS to apply t he same approach to emissions control for emergency engines larger than 30 l/cyl as you do for engines less than 30 l/cyl. That approach would assure that the emissions limits for emergency engines greater than 30 l/cyl would not trigger the need for aftertreatment. After that meet ing, you requested that EMA provide a proposal for the emissio n limits for large emergency

- only engines. EMA has the following recommendatio n fo r a revised set of emissio n limits for emergency engines larger than 30 l/cyl. In the United States, the predominant market for such engines is likely to be nuclear power installat io ns, but other applicat io n such as flood control or government/public safet y o perations centers also are possible.Mr. Jaime Pagan

April 7, 2009 Page 2

EMA reco mmends that owners and operators of stati onary CI engines greater than 30 l/ cyl th at are used only in emergency back

- up applicat io ns meet the fo llo wing emissi ons limit s using the referenced test methods and condit io ns. FUEL Low Sulfur Fuels should be used for all tests, i.e., fuel less than 500 ppm sulfur PM 0.40 g/kw

- hr, US EPA Methods 5B or 17 NOx IMO Tier II or Tier I levels, determined by IMO curve and installation date . NOTE: IMO Tier III is aftertreatment forcing and would not apply. TEST CONDITIONS All tests to be run at factory test bed or certification si te and steady lo ad condit io ns at 85% and 100% of nameplate rated lo ad and at a constant rated speed. For PM tests, average test results from three, 0.5 hour or longe r values at each load condi ti on wi th th e result compared direct ly t o the emissio n standard. For NOx tests, average test results from three, 0.5 hour or longer values at each load condi ti on . Include correcti ons fo r ambient humidit y a nd tem perature as st ipulated in Sect io n 5.12.4 IMO MEPC58 revised Marpo l Annex VI, October 2008. Co mpare the resul t s direct ly wi th th e NOx emissions standard specified by the IMO curves . If emissio ns co mp liance measurement s are to be performed at the site, the allowances sti pulated in Sect io ns 6.3.11.1 , 6.3.11.2, and 6.3.11.3 of th e same document should be applied in addi ti on to the corrections stated in Section 5. 12.4. LABELING Similar to requi

rements for other CI emergency engines in the NSPS, EMA proposes that engines larger than 30 l/ cyl that are destined for emergency operations be specifically labeled by th e manufacturer with the phrase “FOR EMERGENCY USE ONLY ”
. By adopting the above emissions standards for emergency engines l arger than 30 l/cyl, EPA will be revising the current ly applicable PM and NOx standards so that regulatoryMr. Jaime Pagan

April 7, 2009 Page 3
emissio ns limits can be met wi thout the use of aftertreatment that may adversely affect emergency engine performance. Moreover, this will rect ify the inconsistent treatment of large emergency engines in the current CI NSPS and will allow the continued use of engines greater th an 30 l/cyl for emergency applications wit hout increasing the likelihood of safet y perf ormance degradation or f

ailure during emergency operations. Secondly, a s we discussed during our February 9 th 2009 meet ing , EMA requested that EPA clarify the term “installe d” as it applies to stationary engine installat io ns . T his term drives significant industry act ivit y t oward com pliance with the emissio ns standards
. Thus, EMA requests that EPA define this term in the rule making package : “Installed” means a stati onary engine th at is delivered to th e owner/operator and is permanent ly a ffixed to it s mo unt ing posit io n where it is intended to be operated. Finally, as we also di scussed at our February 9 th meet ing, EMA would like to open a di scussio n wi

th appropri ate EPA st aff on alternat ive test methods relative to PM measurements of stati onary diesel engines. EMA does not believe that EPA Test Method 5, currently required in the NSPS, is the most appropriate method for lar ger stationary engines. You ment io ned that one of th e EPA staff, Mr. Ron Myers, could be available to discuss such alternative test methods. EMA requests confirmat io n of Mr. Myers availabilit y and contact informat io n t o begin these di scussio ns. EMA would be pleased to discuss these issue s wi th yo u furth er, and look forward to seeing a final reso lut io n t hrough a corrective rule

- making process.
Pl ease do not hesitate to call me at 312

- 827

- 8734.

Respect ively submi

tted, 

## Joseph L. Suchecki Joseph L. Suchecki Di rector, Publ ic Affairs