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|"Dave Warner" <dave.warner@valleyair.org> | 
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|Melanie King/RTP/USEPA/US@EPA | 
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|09/21/2011 12:06 PM | 
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|RE: IC engine inventory | 
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Hi Melanie, 
 
Please see my answers below... 
 
Dave Warner 
Director of Permit Services 
San Joaquin Valley APCD 
 
-----Original Message----- 
From: King.Melanie@epamail.epa.gov [mailto:King.Melanie@epamail.epa.gov] 
 
Sent: Wednesday, September 21, 2011 7:38 AM 
To: Dave Warner 
Subject: RE: IC engine inventory 
 
Hi Dave, 
Thanks so much for providing the engine inventory. As you may have heard, we 
had a discussion with some of the ag industry stakeholders from California 
last week, and they raised some concerns about EPA's air toxics rule for 
stationary engines. We're trying to gather as much information as possible to 
help us understand their concerns, so If you don't mind, I have some 
additional questions for you (or if there is someone else on your staff I 
should talk to, let me know). 
 
1) One of the issues that the ag industry stakeholders raised when we spoke 
with them last week is that EPA's rule would impact engines in 
2013 that the engine owners were intending to replace in 2014 or 2015 to 
comply with CARB or SJVAPCD rules. Do you have a sense as to whether some or 
all of those 409 engines are scheduled to be replaced in the next few years? 
Is there a schedule in place for replacing them? Are any of those engines 
currently exempted from the CARB or SJVAPCD rules? 
 
Yes, our District Rule 4702 requires replacement of all of these 
engines with Tier III or IV by the later of 1/1/2015 or 12 years 
after installation date, but not later than 6/1/2018. None of 
these particular engines would be exempt. 
 
2) Another issue that was raised during the discussion last week was that 
EPA's regulation might impact engines that had been installed over the last 
decade as replacements for older, dirtier (Tier 0) engines. 
There seemed to be a feeling from the stakeholders that it was unreasonable to 
require further reductions from engines that had been installed as 
replacements for Tier 0 or Tier1/2 engines. Do you know whether any of these 
engines are ones that have been installed under any of the diesel replacement 
programs (like Carl Moyer) to replace older, dirtier engines? I had a 
discussion about this with CARB last week and they seemed to think that most 
of the replacements for stationary engines didn't really get started until 
around 2006, prior to that they indicated that the focus of many of those 
programs was on nonroad and onroad engines. 
 
All of these engines are Tier 1 and 2 (Tier 0 is already illegal 
in SJV and California, and all of these engines were replacements 
for existing Tier 0 engines). I don’t know who you talked to at 
ARB, but they are wrong. We were using Moyer program to replace 
agricultural Tier 0 irrigation pump engines long before 2006, and 
in fact, Tier 3 became available in 2006, so we haven’t given 
money since then for Tier 1 and 2 installations. 
 
3) Also, one concern seemed to be whether Tier 3 engines that had been 
installed to replace Tier 0-2 engines would be able to meet the requirements 
of the rule. As far as I know, the earliest that Tier 3 engines were available 
was the 2006 model year. Since the applicability of this rule is for engines 
installed mid-2006 and earlier, I'm wondering how many Tier 3 engines were 
installed before June 12, 2006. 
Does your inventory have any information on the Tier level of the engines? 
 
We have records of 17 Tier 3 engines installed before June 12, 
2006. These 17 units are NOT included in the 409 Tier 1 and 2 
units installed before June 12, 2006. 
 
Just one comment on the summary table: there is a row that says "All engines 
report deviations or statements indicating no deviation, semiannually or 
annually" - it might be a good idea to note that requirement only applies to 
the engines that have to meet a numeric CO or formaldehyde limit. Engines that 
are subject to the work or management practices (change oil etc.) don't have 
to submit compliance reports. 
 
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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|"Dave Warner" <dave.warner@valleyair.org> 
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|09/20/2011 05:08 PM 
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|RE: IC engine inventory 
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Hi Melanie, 
 
Sorry that we haven't sent these numbers to you prior to this - they are just 
now available: 
 
We know of at least 409 diesel agricultural irrigation engines that are 
greater than 300 bhp, and were installed prior to 6/12/06. 
 
This is a partial list, though, because under our rules smaller farms are not 
yet obligated to fully inform us of their engine inventory. 
 
At to our understanding of ZZZZ, please review the attached summary of 
requirements for existing engines, and let me know if we are missing 
something. 
 
Thanks! 
 
Dave Warner 
Director of Permit Services 
San Joaquin Valley APCD 
 
 
 
-----Original Message----- 
From: King.Melanie@epamail.epa.gov [mailto:King.Melanie@epamail.epa.gov] 
 
Sent: Tuesday, September 20, 2011 11:14 AM 
To: Dave Warner 
Subject: IC engine inventory 
 
 
Hi, 
I left you a voice mail about this, but I thought I'd try email as well. 
I'm the EPA staff contact for our air toxics regulation for stationary 
engines. I believe your staff is working on providing an inventory of the 
number of engines in the SJV that are potentially subject to the rule. I was 
asked to check with you to see if you had an idea of when you would be able to 
provide that information. 
 
Also, I wanted to make sure you are aware that the RICE NESHAP that were 
promulgated last year for "existing" engines apply to engines that were 
installed before June 12, 2006 (the date is installed before December 19, 2002 
for non-emergency diesel engines >500 HP at major sources of hazardous air 
pollutants). We already promulgated the regulations that apply to engines 
installed on or after June 12, 2006 a few years ago. 
Just wanted to make sure that information is getting across to folks that may 
have engines subject to the rule. 
 
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 
 
(See attached file: 40 CFR 63 ZZZZ requirements summary.xls)
