From: "Joseph L. Suchecki" <jsuchecki@emamail.org> 
To: Melanie King/RTP/USEPA/US@EPA 
Date: 09/28/2012 04:24 PM 
Subject: RE: Questions on Engines for NESHAP
 
 
 
 
Yes – that is correct 
 
Joe 
 
From: Melanie King [mailto:King.Melanie@epamail.epa.gov]  
Sent: Friday, September 28, 2012 2:02 PM 
To: Joseph L. Suchecki 
Subject: Re: Questions on Engines for NESHAP
Thanks Joe. One thing I want to make sure I'm understanding correctly, you indicated for the third 
question that your members think the same requirements would be appropriate for OCS sources as 
those for land-based engines. We don't really have management practices in the RICE NESHAP for large 
non-emergency CI engines, we have requirements for smaller non-emergency engines and for emergency 
engines. So are you saying the management practices for smaller non-emergency CI engines (item 1 in 
Table 2d of subpart ZZZZ) are also appropriate for large non-emergency CI 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 
 
 "Joseph L. Suchecki" ---09/28/2012 02:52:36 PM---TO: Melanie King US EPA 
 
From: "Joseph L. Suchecki" <jsuchecki@emamail.org> 
To: Melanie King/RTP/USEPA/US@EPA 
Date: 09/28/2012 02:52 PM 
Subject: Questions on Engines for NESHAP
 
 
 
 
 
TO: Melanie King 
US EPA 
 
FROM: Joe Suchecki 
EMA 
 
DATE: September 28, 2012 
 
RE: Responses to Questions Regarding Engine Issues for NESHAP 
 
 
In response to three of your recent questions on stationary engine issues and 
proposed changes to the stationary engine NESHAP and NSPS regulations, EMA 
submits the following. 
1 How can owners determine sited-rated horsepower of an engine? 
It appears that is most cases the site-rated horsepower of a stationary 
engine is indicated on the engine nameplate. However, in some cases, 
and depending on engine manufacturer practice, the maximum engine 
horsepower or family horsepower is indicated on the nameplate rather 
than the specific site-rated horsepower. If the owner/operator is uncertain, 
they can use the nameplate horsepower which will always be higher or 
equal to the actual site-rated horsepower of the engine. Alternatively, the 
owner/operator can contact the engine manufacturer with the serial 
number of the engine, and most, if not all, manufacturers will be able to 
supply to needed information. 
 
2 Do all rich-burn engines emit uncontrolled CO at levels between 1000-
1500 ppm?
Although many stationary rich-burn engines may emit CO at levels somewhere 
in that range, engine manufacturers provided examples of engines that emit 
either above or below that level. So, while that is a good benchmark for many 
rich-burn engines, it is not an absolute range. Uncontrolled emissions from 
stationary rich-burn engines can be both above and below that range. 
 
Having said that, EMA believes it would be appropriate to establish a PPM CO 
standard for rich burn engines based upon a 75% reduction in emissions, or 
alternatively to harmonize with the NSPS for new engines and use a value of 
270 ppm as a standard. Given the variability of engine CO emissions, a 270 
standard would likely result in some engines having to reduce CO more than 
75% and some engines would have to reduce CO less than 75%. 
 
. 
3 Are different maintenance practices needed for Outer Continental Shelf 
engines if EPA were to adopt EMA’s recommendations to align requirements of 
OCS engines with those of remote-area land based engines?
The basic answer is no – no additional or different maintenance practices are 
required for offshore/OCS engines. EMA would recommend the same 
requirements for those engines as for land-based engines. 
 
 
Please let me know if you need additional information or if you have questions 
on the above.
