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  |"Johnson, Nancy" <Nancy.Johnson@hq.doe.gov>                                                                                               
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  |"'Bromberg, Kevin L.'" <kevin.bromberg@sba.gov>, Melanie 
King/RTP/USEPA/US@EPA, RobertJ Wayland/RTP/USEPA/US@EPA                          
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  |"Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>, "Kymn, Christine J." 
<Christine_J._Kymn@omb.eop.gov>                                    |
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  |08/04/2010 03:57 PM                                                                                                                       
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  |RE: SI Limited Use engines- Question for Group                                                                                            
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I would agree that some practical form of relief should be provided for these 
engines.

Nancy

From: Bromberg, Kevin L. [mailto:kevin.bromberg@sba.gov]
Sent: Wednesday, August 04, 2010 2:30 PM
To: King.Melanie@epamail.epa.gov; Wayland.Robertj@epamail.epa.gov
Cc: Higgins, Cortney; Kymn, Christine J.; Johnson, Nancy
Subject: FW: SI Limited Use engines- Question for Group

These are the comments on limited use engines (see below).  To respond to 
EPA’s question about how limited use engines operate, this is all that we 
know:  API Comments 5.4.4, 6.2 and 6.18; INGAA Comment #7.

I can’t justify  requiring performance tests for these engines when it is not 
required for black start engines.
As stated below, some of these other engines “as a fire pumps or other 
existing units located at a facility that may operate very little depending 
upon demand”  which are seldom if ever operated, appear to be
equally deserving of coverage as black start engines.   And “some
transmission lines include small stations that run very infrequently – i.e., 
only operate when there is significant gas demand (or for routine engine 
checks) and may not run at all or only a few hours in some years.”  Again, the 
emissions that result from testing could exceed the operating emissions for 
these engines.

Kevin

From: Jim McCarthy [mailto:jamesmccarthy@comcast.net]
Sent: Thursday, July 22, 2010 7:26 PM
To: Bromberg, Kevin L.
Cc: 'Lisa Beal'; 'Jeffrey Panek'; toddm@api.org
Subject: RE: SI Limited Use engines- Question for Group

Kevin,

This email follows-up on my brief response earlier this morning, and 
references to API and INGAA comments on “limited use” follow. Comments were 
submitted recommending Management / Work Practices rather than emission 
standards and these engines DO exist.

API June 2009 comments (detailed comments are docket document no.
0242.2) include several references to “limited use” and “intermittent use” 
engines, including comments 5.4.4, 6.2 and 6.18.  If you search for “limited 
use” in the attached file, you will find those comments, which note that EPA 
should retain the limited use subcategory from the original NESHAP, and 
recommend exemptions or work practices rather than emissions limits due to the 
low operating time for these types of installations.  The comments also note 
that EPA has not adequately considered costs, control technology and emission 
standard viability, etc for engines that run intermittently.

INGAA June 2009 comments (docket document no. 0155.1) only briefly discuss 
“limited use” engines. Comment 7 discusses the need for additional 
subcategories (see pdf page 38 of 94 in the attached INGAA
Comments) and includes the following regarding new a subcategory for limited 
use engines:

   “Other examples include existing engines with very little run time,
   such as a fire pumps or other existing units located at a facility
   that may operate very little depending upon demand. Depending on the
   engine size, an emission standard will likely apply, – thus requiring
   installation of controls on units that seldom if ever operate. Or, if
   management practices apply, a frequency based on calendar hours would
   require maintenance for an engine that has not operated (discussed
   further in Comment 23). Thus, a subcategory may be warranted for
   engines with limited use.”

The limited used category was in the original NESHAP and EPA appears to be 
backing away from that subcategory.  In addition to the comments, I believe 
the issue has been raised in discussions with EPA, but it has been a lower 
priority item as MACT floor, above the floor, urban versus rural, etc have 
been higher priority during the limited time available in 
meetings/discussions.  The scenario discussed in the email this morning 
discusses one example…  some transmission lines include small stations that 
run very infrequently – i.e., only operate when there is significant gas 
demand (or for routine engine checks) and may not run at all or only a few 
hours in some years.  Those stations are important on high demand days, but 
would require emission tests, potentially add-on controls, etc if emission 
limits are included in the rule rather than work practices.

Thanks.





