----- Forwarded by Melanie King/RTP/USEPA/US on 11/13/2009 08:49 AM
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  |"Antonio Santos" <asantos@meca.org>                                                                                                       
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  |Melanie King/RTP/USEPA/US@EPA                                                                                                             
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  |11/12/2009 07:07 PM                                                                                                                       
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  |RE: Your questions regarding MECA's stationary engine comments                                                                            
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Hi again, Melanie.  Per your questions, see below.

1) MECA is currently only aware of one manufacturer of CCV systems for 
stationary diesel engines -- Racor (www.parker.com/racor).  MECA members 
Donaldson Company
(www.donaldson.com/en/exhaust/support/datalibrary/061798.pdf) and Engine 
Control Systems (www.enginecontrolsystems.com/prod-cvv.aspx) both sell CCV 
systems but only for mobile source applications.  (Note:  ECS's CCVs are Racor 
units produced for ECS.)  In conversations with these two MECA members, they 
said they would both consider offering products for existing stationary diesel 
engines should EPA promulgate requirements in this market area.  Regarding 
limitations, one MECA member said the limit to the size of CCVs, in terms of 
commercial availability, is typically no larger than 30 L.

2) Regarding the feasibility of DPFs for existing stationary diesel engines, 
the best guideline is the information contained in the list of ARB Level 3 
verified technologies for stationary diesel engines 
(www.arb.ca.gov/diesel/verdev/vt/stationary.htm).  The specifications for the 
type of engine, minimum temperature for filter regeneration, fuel type, and 
other operating conditions can be found in the individual Executive Order 
letters.  Essentially, stationary diesel engines certified to ARB Tier 1, 2, 
or 3 off-road standards would be suitable candidates for retrofit.  These same 
parameters (e.g., minimum temperature for filter regeneration) would apply as 
a general guideline to pre-1996 engines as well.  Also, some Level 3 systems 
verified for mobile off-road (www.arb.ca.gov/diesel/verdev/vt/cvt.htm) could 
be suitable for stationary applications as one of the test cycles used for 
mobile off-road verification (ISO8178-C1, a steady-state cycle) is very 
similar to the test cycle for stationary verification (ISO8178-D2).

In terms of examples of older engines that have been retrofitted with DPFs, as 
noted in our testimony, the most comprehensive information on the application 
of PM exhaust emission control technology to in-use stationary diesel engines 
can be found in ARB's September 2003 Staff Report in support of its ATCM for 
stationary compression-ignition engines.  In the report, ARB provides a 
thorough list of in-use emergency standby engines and prime stationary engines 
using emission control systems (mostly DPFs) in California.  The retrofit 
devices were installed on stationary engines ranging from model years 1993 to 
2002.
The list shows numerous DPF installations on large engines rated above 600 kW, 
including Caterpillar 3516 engines rated in the 1490-2120 kW range.

I have also attached a short case study of two pre-1996 stationary diesel 
engines that were retrofit with DPFs (this case study was also noted in our 
testimony).

Hope this helps.  If I get further information from our members, I will 
forward it along to you.

Antonio


-----Original Message-----
From: King.Melanie@epamail.epa.gov [mailto:King.Melanie@epamail.epa.gov]

Sent: Tuesday, October 20, 2009 2:49 PM
To: Antonio Santos
Subject: Re: Your questions regarding MECA's stationary engine comments

Hi,
Thanks for getting back to me.  There were two issues that I wanted to talk to 
you guys about:

1) Closed crankcase ventilation - we asked for comment on CCV systems in the 
proposed NESHAP revisions.  There was a paragraph in MECA's comments on CCV 
systems and in that paragraph it stated that there was one manufacturer of CCV 
systems that had been selling them for stationary diesel engines in the mid-
1990s.  I wanted to get more information regarding CCV systems for stationary 
diesel engines.  I'm wondering about the applicability of CCV systems for 
existing diesel engines - are there any limitations on what types of 
stationary diesel engines the systems could be applied to (for example can all 
sizes of diesel engines use them, all different applications, etc.)?  Is there 
only one manufacturer who has the CCV systems available for stationary 
engines?

2) Diesel particulate filters - specifically their feasibility for older 
engines.  As discussed in the comments, there are DPF systems that are 
verified by CARB for stationary engines and they are verified for 1996 and 
newer engines.  How about for pre-1996 engines?  On page 4 of the MECA comment 
letter there are some bulleted parameters that are considered, but what I 
don't know is how many older engines would meet those parameters and be able 
to be retrofit with DPF?  Also, can you be a little more specific about the 
parameters, for example the second bullet talks about the need for the engine 
operating temperature to be hot enough for regeneration - how hot does the 
temperature need to be and do most existing stationary diesels reach that 
temperature?  On page 10 of the MECA comments it says "MECA believes DPFs 
should be installed on in-use stationary diesel engines wherever technically 
feasible . . .
."  What I'm trying to get at is figuring out for a nationwide regulation, 
where could the line be drawn as to what engines can feasibly be retrofit?  
What are the oldest age engines that you have been able to install DPF and 
demonstrate reductions (also what size were they and what reductions were 
demonstrated)?

Melanie King
Energy Strategies Group
Sector Policies and Programs Division
Office of Air Quality Planning and Standards U.S. Environmental Protection 
Agency

Mail Code D243-01
RTP, NC  27711

Phone:  (919) 541-2469
Fax:       (919) 541-5450
king.melanie@epa.gov


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  |"Antonio Santos" <asantos@meca.org>
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  |Melanie King/RTP/USEPA/US@EPA
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  |10/19/2009 10:23 AM
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  |Your questions regarding MECA's stationary engine comments
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Hi, Melanie.  Joe Kubsh forwarded to me your voice mail you left for him last 
week re: MECA's comments on EPA's NESHAP for existing stationary engines 
proposed rulemaking.

He is out of the office and wanted me to follow up with you regarding your 
questions.  Feel free to call me (202/296-4797 x108) or e-mail me (e-mail is 
better, so I can forward your questions to Joe).

Thanks,
Antonio




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Antonio Santos
Manufacturers of Emission Controls Association
(202) 296-4797 x108
asantos@meca.org









(See attached file: Application Fact Sheet 703 - J Cloud.pdf)