From: Don DiCristofaro <DDiCristofaro@enernoc.com> 

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

Cc: Rick Counihan <RCounihan@enernoc.com> 

Date: 12/03/2012 02:42 PM 

Subject: RE: Testing Language in NESHAP r.e. DR Audits

Melanie, 

Regarding the testing language in the NESHAP and NSPS, I recommend that 

63.6640(f)(2)(i) (and the appropriate sections of 40 CFR 60 Subparts IIII and JJJJ) be 

changed as per the attached. We added the following from the emergency DR trigger 

language we sent to you last week: 

or by the entity with jurisdiction over the relevant demand response program 

to account for those ISOs that have CSPs (e.g., demand response providers) decide 

when the audit should occur (e.g., PJM) rather than calling the audit directly (e.g., ISO 

New England). Also, since there is not a separate testing clause for engines 

participating in non-emergency demand response, I believe 63.6640(f)(2)(i) covers 

audits for non-emergency DR programs also so long as the non-emergency DR use is 

less than 50 hours (through April 16, 2017) and the total non-emergency use is 100 

hours or less. 

Let me know if you have any questions or require additional information. 

Don 

From: Don DiCristofaro 

Sent: Sunday, December 02, 2012 7:28 PM 

To: 'king.melanie@epa.gov' 

Cc: Rick Counihan 

Subject: Testing Language in NESHAP r.e. DR Audits 

Melanie, 

I am still working on a recommendation regarding how the language in the testing portion of the NESHAP and NSPS 

should be modified to account for DR audits. It is not as easy as I thought to describe. Some ISOs (such as ISO NE) 

call 

their own audits (they like the surprise factor); whereas, other ISOs (such as PJM) have the DR provider call their 

own audits. It is the latter method that I am trying to get a description of in terms of how to describe who calls it. 

I will work to get you a response as soon as possible. 

Don 

Don DiCristofaro, CCM – Air Quality Meteorologist Consultant 

EnerNOC, Inc. | 101 Federal Street, Suite 1100 | Boston, MA 02110 

m: 617.834.8408 | f: 857.221.9464 

DDiCristofaro@EnerNOC.com| www.EnerNOC.com 
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attached file: NESHAP 40 CFR 63 - Testing Language with suggested change 120312.docx)
NESHAP 63.6640(f)(2) and 40 CFR 60 Subparts IIII and JJJJ:

(i) Emergency stationary RICE may be operated for maintenance checks

and readiness testing, provided that the tests are recommended by

federal, state or local government, the manufacturer, the vendor,

Reliability Coordinator or other authorized entity as determined by the

Reliability Coordinator or by the entity with jurisdiction over the

relevant demand response program or the insurance company

associated with the engine.

Deleted: the regional transmission authority

or equivalent balance authority and

transmission operator,

Deleted: