-----Forwarded by Melanie King/RTP/USEPA/US on 02/15/2010 09:44PM -----
To: Melanie King/RTP/USEPA/US@EPA 
From: <Sarah.Merrill@CH2M.com> 
Date: 10/19/2009 12:24PM 
cc: <scheng@ebmud.com>, <Jim.Sandoval@CH2M.com>, <Jacqueline.Kepke@CH2M.com> 
Subject: RE: NESHAP Comments (Docket ID No. EPA-HQ-OAR-2008-0708)
Hello Ms. King,
 
I am submitting the BACWA AIR Committee response to your questions, as listed below, on behalf of 
the Committee Chair, Stephanie Cheng.
 
Please see the attached letter and attachments.
 
Thank you again for this opportunity to comment on the proposed NESHAP for RICE.
Our committee looks forward to further discussion with the EPA on this topic.
 
Regards,
 
Sarah Merrill 
Staff Engineer 
CH2M HILL
Tel: (408)436-4936 x37437
 
 
-----Original Message-----  
From: King.Melanie@epamail.epa.gov [ mailto:King.Melanie@epamail.epa.gov]  
 
Sent: Thursday, August 20, 2009 8:18 AM  
To: Cheng, Stephanie  
Cc: Jim.Sandoval@CH2M.com; rschmidt@centralsan.dst.ca.us  
Subject: Re: NESHAP Comments (Docket ID No. EPA-HQ-OAR-2008-0708)  
 
Hi,  
Thank you for your comments on the proposed rule.  I have a few  
questions:  
 
1) Do your member agencies have any stack test data from their engines  
that they would be willing to share with EPA?  In order to change the  
emission limit from what was proposed, we really need additional  
emissions data that supports the comments that the limit is not  
achievable.  
2) Are the engines that are operated by your members located at a major  
source of HAP emissions or an area source of HAP emissions?  A major  
source is a plant site that emits >10 tons/year of a single HAP or >25  
tons/year of combined HAPs.  Anything that is not a major source is an  
area source.  
3) We are exploring the possibility of requiring work practice standards  
rather than an emission limitation for these engines.  Can you provide  
any information on work/operational practices that are used for these  
engines in order to minimize emissions?  
 
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  
 
 
|------------>  
From:   Cheng, Stephanie" <scheng@ebmud.com>  
To:  Melanie King/RTP/USEPA/US@EPA  
Date:  08/19/2009 04:52 PM  
Subject:   NESHAP Comments (Docket ID No. EPA-HQ-OAR-2008-0708)  
Dear Melanie -  
 
Please find attached a letter on behalf of the Air Issues and  
Regulations Committee of the Bay Area Clean Water Agencies regarding the  
proposed national emission standards for hazardous air pollutants for  
stationary reciprocating internal combustion engines. If you have any  
questions on the content of the letter, please feel free to contact me.  
 
 
Stephanie Cheng, P.E.| Resource Recovery Program | East Bay Municipal  
Utility District | phone 510.287.1337 | fax 510.287.0621  
[attachment "AIR Letter - NESHAP RICE (2009-08-19).pdf" deleted by  
Melanie King/RTP/USEPA/US] 


