----- Forwarded by Melanie King/RTP/USEPA/US on 08/09/2010 11:15 AM

----- |------------> | From: | |------------>

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |"Bromberg, Kevin L." <kevin.bromberg@sba.gov> |

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |------------> | To: | |------------>

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |"Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>, "Kymn, Christine J." <Christine_J._Kymn@omb.eop.gov> |

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |------------> | Cc: | |------------>

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |"Maresca, Charles A." <Charles.Maresca@sba.gov>, RobertJ Wayland/RTP/USEPA/US@EPA, Melanie King/RTP/USEPA/US@EPA, Peter | |Tsirigotis/RTP/USEPA/US@EPA, "Johnson, Nancy" <Nancy.Johnson@hq.doe.gov>, "Zwicke, Greg - Portland, OR" <greg.zwicke@por.usda.gov> |

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |------------> | Date: | |------------>

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |08/09/2010 09:23 AM |

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |------------> | Subject: | |------------>

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |Limited Use Discussion - For your review - RICE SI |

>--------------------------------------------------------------------------- ---------------------------------------------------------------|

Limited Use Engines:

For limited use engines, the cost/ton for engines of less than 28 hours or less are 100X higher than the respective major or area source engines. It clearly would not be GACT or MACT to require catalysts AND testing, or testing alone.

I suggested that EPA could do anything that was reasonable - here's my reasonable suggestion for discussion.

From July 27th MACT Floor Memo:

For MACT:

EPA can make the SAME work practices finding that it made for Emergency SI Engines at Major Sources (numbered text below are quotes from July 27 memo): 1. EPA determined it was not feasible to prescribe or enforce an emission standard because the application of measure methodology to this class of engine is impracticable due to the technological and economic limitations. 2. Emergency engines typically operate only during emergencies or during periods of routine testing and maintenance. 3. It is impracticable to test emissions during [either of these periods] because it would increase the required number of hours of operation of the engine beyond the routinely scheduled reliability testing and maintenanceoperation, thereby increasing emissions.

4. It would be costly to test existing SI emergency engines at major sources. 5. Consequently, work practices are the MACT floor for existing stationary emergency SI engines located at major sources.

AND it can make similar findings as black start engines (with an adjustment of the hours): 1. The short time of operation makes testing of black start engines using the required procedures impracticable. 2. The limited operating time also makes applying aftertreatment to black start engines not effective. 3. Therefore, MACT is equivalent to the MACT floor for these engines.

For GACT:

EPA can make the same work practices finding it made for Emergency SI Engines at Area Sources. FYI - GACT means "generally available control technologies or management practices by such sources to reduce emissions of hazardous air pollutants" - EPA doesn't even need to start the analysis with MACT standards, although it could do so.

EPA can make the SAME work practices finding that it made for Emergency SI Engines at Area Sources: 1.For existing SI emergency engines located at area sources, EPA believes that it is appropriate to set GACT to the same requirements as is required for emergency engines at major sources because the same issues that were discussed above for stationary emergency SI engines at major sources apply to emergency SI engines at area sources. [See other major source findings above]

Suggestion: EPA should set the number of limited use hours to include an appropriate amount of time for routine reliability testing and maintenance, just as it did for emergency engines. That might mean 50 hours plus time for reliability testing and maintenance, in the CI rule – this was 100 hours. (See below text for CI emergency engines) I assume EPA put aside no limit on the reliability testing and maintenance on black start engines – but these limited use engines, I submit, should get the same treatment as CI emergency , by some explicit figures for testing and maintenance, in addition to the non-emergency allocation of hours.

CI Emergency Engine Rule:

As finalized, NESHAPs has three different hourly limits for emergency generators (40 CFR 63.6640 (f) (4)). First, there is an overall limit of 100 hours per year for testing and maintenance. Second, within that 100 hour limit, there is an allowance for up to 50 hours of "non-emergency operation" (not to include peak shaving). Third, of the 50 hours for non-emergency operation, only 15 can be used for emergency DR.