To: Melanie King/RTP/USEPA/US@EPA 
From: "Tanya Parise" <tparise@alpha-gamma.com> 
Date: 08/19/2009 10:15AM 
cc: "Brad Nelson" <Nelson.Brad@Ecrweb.Com> 
Subject: SSM Recommendations

Melanie, 
 
I went through the RTC document, looked at some engine manufacturers operating manuals, 
and some other information we've gotten on the SSM issue and summarized the 
recommendations in the attachment.  I was waiting to see if EMA, API, and INGAA would 
provide some more information on this topic and I would include that, but we've only heard 
back from EMA.  
 
Based on the information we have, for startup, it seems that specifying a time limit of 30 
minutes might be appropriate and include the provision to petition the Administrator if 
additional time is needed in special cases.  
 
I can formalize the information into a memo if you want.  Just let me know, but I just 
wanted to get the information out to you. 
 
Tanya 
 
Tanya Parise 
Senior Chemical Engineer 
Alpha-Gamma Technologies, Inc. 
3301 Benson Drive, Suite 535 
Raleigh, NC 27609 
Phone : (919) 954-0033 ext: 109 
Fax : (919) 954-0379 
Email : tparise@alpha-gamma.com 
URL : http://www.alpha-gamma.com 


