From: Donald Evans <DOEV@statoil.com> 
To: Melanie King/RTP/USEPA/US@EPA 
Date: 09/27/2012 03:50 PM 
Subject: RE: Offshore Operators Committee Comment Letter - Docket ID EPA-HQ-OAR-2008-0708
 
 
 
 
Yes, the practices stated in table 2d #1 (including the footnote: Sources have the option to utilize an oil analysis 
program as described in § 63.6625(i) in order to extend the specified oil change requirement in Table 2d of this 
subpart) will be appropriate for the larger engines. 
 
From: Melanie King [mailto:King.Melanie@epamail.epa.gov]  
Sent: Thursday, September 27, 2012 12:31 PM 
To: Donald Evans 
Subject: RE: Offshore Operators Committee Comment Letter - Docket ID EPA-HQ-OAR-2008-0708
Okay, thanks. So just to be clear, you're saying that the management practices in item #1 in Table 2d for 
smaller CI engines would also be appropriate for the larger engines?  
 
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 
 
 Donald Evans ---09/27/2012 01:24:54 PM---OK. I was unaware of that decision. In that case, the criteria 
in 2d is preferred vs. the performanc 
 
From: Donald Evans <DOEV@statoil.com> 
To: Melanie King/RTP/USEPA/US@EPA 
Date: 09/27/2012 01:24 PM 
Subject: RE: Offshore Operators Committee Comment Letter - Docket ID EPA-HQ-OAR-2008-0708
 
 
 
 
 
OK. I was unaware of that decision. In that case, the criteria in 2d is preferred vs. the performance standards. 
Maintenance schedules already in place for these engines can be modified to incorporate the maintenance 
frequencies stated in table 2d. 
 
Don 
 
From: Melanie King [mailto:King.Melanie@epamail.epa.gov]  
Sent: Thursday, September 27, 2012 12:12 PM 
To: Donald Evans 
Subject: RE: Offshore Operators Committee Comment Letter - Docket ID EPA-HQ-OAR-2008-0708 
Hi, 
Thank you for providing this information. However, we cannot use "in accordance with manufacturer 
specifications" as our standard. We got similar suggestions for the 2010 rulemaking and discussed why 
we cannot use that for our standard. Below is an excerpt from the response to comment document 
discussing the issue. This is on p. 238 of the document 
(http://www.epa.gov/ttn/atw/rice/existing_si_rice_rtc.pdf). 
 
"EPA does not agree with the commenters that it would be appropriate to simply specify that owners and 
operators follow the manufacturers recommended maintenance practices for the engine. EPA 
cannot delegate to manufacturers the final decision regarding the proper management practices 
required by section 112(d) of the CAA; nor can EPA allow management practices to change 
from engine to engine based on the views of multiple manufacturers." 
 
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 
 
 Donald Evans ---09/26/2012 06:20:28 PM---Melanie, Per our phone conversation on Friday, Sept 14th, I 
have some information I’d like to provid 
 
From: Donald Evans <DOEV@statoil.com> 
To: Melanie King/RTP/USEPA/US@EPA 
Date: 09/26/2012 06:20 PM 
Subject: RE: Offshore Operators Committee Comment Letter - Docket ID EPA-HQ-OAR-2008-0708
 
 
 
 
 
 
Melanie, 
 
Per our phone conversation on Friday, Sept 14th, I have some information I’d like to provide to you regarding the 
subject comment letter and , more specifically, maintenance schedules for CI engines (> 500 HP) located on 
offshore platforms and exploratory drilling rigs that may become subject to the Subpart ZZZZ area source standards. 
 
Table 2d of the proposed rule specifies the following management practices for CI categories: 
a. Change oil and filter every 500 hours of operation or annually, whichever comes first; [Sources have the option to utilize 
an oil analysis program as described in § 63.6625(i) in order to extend the specified oil change requirement in Table 2d of 
this subpart.] 
 
b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary; and 
c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. 
 
Since the maintenance schedules vary from one engine manufacturer to another (i.e., Wartsila, Caterpillar, etc.) and 
include the same items already provided in the rule above, requiring adherence to the manufacturer specifications 
for these maintenance items will meet the intent of the proposed rule and help assure good engine performance. 
a. Change oil and filter in accordance with manufacturer specifications; [Sources have the option to utilize an oil analysis 
program as described in § 63.6625(i) in order to extend the specified oil change requirement in Table 2d of this subpart.][ 
 
b. Inspect air cleaner in accordance with manufacturer specifications and replace as necessary; and 
c. Inspect all hoses and belts in accordance with manufacturer specifications and replace as necessary. 
 
Even though these engines can range in size up to several thousand horsepower, maintenance items and engine 
care are similar. Most engine owners will probably insist on following manufacturer specifications for engine 
maintenance in order to fulfill warranty obligations. 
 
I hope this provides a little more perspective for you from the operator’s view. Please reply or call me at your 
earliest convenience if you would like to discuss further. 
 
 
Donald P. Evans 
Chairperson, Air Quality Subcommittee 
Offshore Operators Committee 
 
t: 713 485 2203 
m: 832 788 9282 
e: doev@statoil.com 
 
From: Donald Evans  
Sent: Thursday, September 13, 2012 4:21 PM 
To: 'Melanie King' 
Subject: RE: Offshore Operators Committee Comment Letter - Docket ID EPA-HQ-OAR-2008-0708 
 
Hi Melanie. My schedule is open tomorrow, but I’m also available next week. Is there a particular day/time that 
works better for you? 
 
From: Melanie King [mailto:King.Melanie@epamail.epa.gov]  
Sent: Thursday, September 13, 2012 1:46 PM 
To: Donald Evans 
Subject: Re: Offshore Operators Committee Comment Letter - Docket ID EPA-HQ-OAR-2008-0708 
Mr. Evans, 
I would like to discuss your comment if you have time. Is there a good time to call you? 
 
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 
 
 Donald Evans ---08/09/2012 03:09:53 PM---Melanie, Please find attached a comment letter submitted 
to Docket ID No. EPA-HQ-OAR-2008-0708 from 
 
From: Donald Evans <DOEV@statoil.com> 
To: Melanie King/RTP/USEPA/US@EPA 
Date: 08/09/2012 03:09 PM 
Subject: Offshore Operators Committee Comment Letter - Docket ID EPA-HQ-OAR-2008-0708
 
 
 
 
 
 
 
Melanie, 
 
Please find attached a comment letter submitted to Docket ID No. EPA–HQ–OAR–2008–0708 from the Offshore 
Operators Committee regarding the proposed rule for NESHAPS for Reciprocating Internal Combustion Engines 
published June 7, 2012. 
 
If you need additional information or would like to discuss, please reply to this email or call me at 713-485-2203. 
 
Sincerely, 
 
Donald P. Evans 
Chairperson, Air Quality Subcommittee 
Offshore Operators Committee 
 
t: 713 485 2203 
m: 832 788 9282 
e: doev@statoil.com 
 
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