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Home My WebLink AboutAQ_F_2100073_20130402_CMPL_Fac-Ltr 1?CU &TORU THE FINEST IN OFFSHORE SPORTFISHING BOATS April 2, 2013 Mr. Robert Fisher Regional Air Quality Supervisor North Carolina Department of Environment and Natural Resources Division of Air Quality,Washington Regional Office 943 Washington Square Mall Washington, North Carolina 27889 Re: 40 CFR Part 63,Subpart ZZZZ(RICE MALT)Applicability and Compliance Plan Regulator Marine, Inc. Edenton,Chowan County, North Carolina Facility ID:2100073 Dear Mr. Fisher: 0n Tuesday March 23, 2013, Mr. Erik Wiborg and myself of Regulator Marine, Inc. along with Mr.Gary Yoder of Resolute Environmental, LLC met with you, Mr. Robert Bright, and Mr.Steven Dan ieIs of your staff in the Washington, North Carolina office. Regulator Marine requested the meeting to meet North Carolina Division of Air Quality(NCDAQ)staff for the following reasons: 1. Discuss general compliance and reporting 2. To meet with Division of Water Quality personnel During the general discussions phase of the meeting,the NCDAQ communicated that while preparing for the meeting,they had become aware of a potential 40 CFR Part 63, Subpart ZZZZ(RICE NESHAP) compliance issue with respect to Regulator Marine's 500 kW(764 bhp) diesel-fired emergency/peak generator. RICE NESHAP APPLICABILITY PER NCDAQ-MARCH 23,2013 MEETING According to §63-6585 of the RICE NESAHP, "You are subject to this subpart if you own or operate a stationary RICE at a major source of HAP emissions" (FR,Vol.69,June 15, 2004).The 2004 RICE NESHAP is applicable to engines greater than 500 bhp. Engines subject to this rule are considered new if construction commenced after December 19, 2002. Regulator Marine is a major source of hazardous air pollutants(HAP).The 764 bhp engine was constructed at the site January 2006 as a Tier 1 certified engine only(i.e., not equipped with controls to limit carbon monoxide (CO)or formaldehyde). As we understand from the March 23, 2013 discussions,the NCDAQ considers Regulator Marine noncompliant with the RICE NESHAP for installing the 500 kW engine without the CO or formaldehyde controls after December 19, 2004. www.regulatormarine.com 187 Peanut Drive•P.O. Box 49•Edenton,North Carolina 27932.252.482.3837 z.of RICE NESHAP APPLIMLITY PER NCDAQ GUIDANCE-SEPTEMBER 23,2005 to MARCH 23,2013 Prior to installing the engine in January 2006, Regulator Marine was given 2004 RICE NESHAP applicability guidance from the NCDAQ contrary to that stated above. Referring again to§63.6585 of the RICE NESAHP,"You are subject to this subpart if you own or operate a stationary RICE at a major source of HAP emissions."The operative word for applying§63.6585 subjectivity is"or." Regulator Marine purchased the engine and is therefore the owner; however, PowerSecure, Inc. has complete operational control of the unit for purposes of peak shaving. In this case, both Regulator Marine, Inc.and PowerSecure, Inc.are responsible for RICE NESHAP compliance. In discussions with NCDAQ personnel in 2005 regarding planned installation of the engine, Regulator Marine was informed that since PowerSecure, Inc.controlled operation of the engine,the 2004 RICE NESHAP was not applicable to Regulator Marine.This applicability guidance is supported by Exhibits 1 and 2 attached to this letter. Exhibit 1 is an August 22, 2005 letter(unsigned)from Mr.Chris Edge of PowerSecure, Inc.to Mr. Robert Fisher of the NCDAQ. Mr. Edge requests, as PowerSecure, Inc. being the operator of the engine,confirmation that installation of the engine is exempt from North Carolina's requirements to receive a permit to construct and operate. Exhibit 2 is the September 23,2005 response from Mr. Robert Fisher of the NCDAQ to Mr. Chris Edge of PowerSecure,Inc.Confirmation is provided from the NCDAQ that the engine is exempt from North Carolina's permitting requirements.The letter also references impending MALT applicability and that PowerSecure, Inc. may be required to apply for an air permit once the regulation is promulgated.This MACT applicability refers to the future Area Source RICE NESHAP for compression engines.The RICE NESHAP for engines>500 hp at major HAP sources was already promulgated. Regulator Marine continued to communicate our understanding that the 2004 RICE NESHAP did not apply to our facility after the engine was installed as indicated in the attached Exhibit 3 Exhibit 3, is the October 29, 2009 Title V renewal application cover letter to Dr. Donald Van der Vaart of the NCDAQ.The second paragraph references the engine and operation by ElectriCities (PowerSecure, Inc. is contracted by ElectriCities).The Title V permit was renewed effective March 2,2010 with the engine listed as an insignificant source, There was no communication from the NCDAQ to Regulator Marine regarding RICE MALT applicability and compliance during the renewal process. In addition,there was no RICE NESHAP language incorporated into the new Title V operating permit. ACTUAL ENGINE EMISSIONS For reference, Regulator Marine presents the actual hours of operation of the engine over the past five years: Yearf s) Hours of Operation 2008 158 2009 0 2010 199 2011 176 2012 148 2008-2012 681 (There are no weekly tests conducted) Attached to this letter is a performance data cut sheet provided by Caterpillar.As a Tier I engine,the carbon monoxide(CO)emission rate at 100% load is 0.81 lb/hr. In the last five years,the maximum annual CO emission rate was 0.08 ton/yr in 2010. Using the 5-year annual average,the engine has emitted about 0.5 total tons of CO since it was installed in January 2005. DIESEL OXIDIZING CATALYST(DOC)INSTALLATION PROCESS ❑n July 25,2012, Mr.Arni Hopkins of the NCDAQ conducted an inspection of the Regulator Marine facility. Mr. Hopkins inquired about RICE NESHAP applicability during his inspection.This prompted a telephone conversation between Mr. Hopkins and Mr.Gary Yoder of Resolute Environmental, LLC on July 30, 2012. Based on this discussion and consultation with Mr.Yoder, Regulator Marine believed that the NCDAQ has changed its position regarding the corporate entity responsible for compliance with the 2004 RICE NESHAP rule.This was confirmed by a telephone conversation with Ms. Betsy Huddleston of your office on September 4, 2012 following submittal of the NCDAQ's August 30, 2012 Subpart ZZZZ questionnaire. Regulator Marine obtained a quote in August 2012 from the Gregory Poole Caterpillar dealership for installation of DOC and crankcase ventilation enclosure systems on the engine. Due to the considerable capital cost of the control systems in this quote, Regulator Marine weighed the options of 1.removing the engine from the site,2. restricting the engine to emergency use only or 3.restricting it to limited use. It was decided that the long term benefits of having peak shaving capabilities remained the best option for the facility even though the payback on the expenditure approached four years.Though the cost may not be significant for many manufacturers, being a small manufacturer in a struggling industry, the expenditure is very significant for us,so an additional quote was entertained from PowerSecure, Inc. on October 26,2012. Regulator Marine signed the contract with Gregory Poole on December 21, 2012. Based on our understanding of compliance as stated herein, Regulator Marine's goal was to bring the engine into compliance by the May 3, 2013 compliance date for existing RICE NESHAP engines. As requested by the NCDAQ, Regulator Marine is providing the following schedule to proceed with demonstrating compliance with the RICE NESHAP. The controlling factor at this time is delivery of the unit from Caterpillar. As you know,they have struggled to keep up with demand in the industry. We have worked with them to obtain their commitment to meet this schedule: Regulator Marine RICE NESHAP Compliance Milestone Compliance Milestones Dates Performance Test Protocol April 2, 2013 Air Permit Application April 17, 2013 Catalyst Equipment Leaves Manufacturing Facility May 9, 2013 Catalyst Equipment Arrives On Site May 15, 2013 Construction Completed May 31, 2013 Testing Completed June 15, 2013 Test Report Received June 28, 2013 Notice of Compliance Determination Report July 12, 2013 As you know,Regulator Marine has been aggressively pushing to bring our diesel-fired engine into compliance with the 2004 RICE NESHAP prior to our March 23, 2013 meeting. As our history with NCDAQ has indicated, Regulator Marine has worked tirelessly over the years to meet or exceed ail requirements. We desire to remain in good favor with NCDACI, but we were very surprised by the possibility of being out of compliance in the March 23, 2013 meeting. I hope the exhibits enclosed clearly indicate that Regulator Marine followed the NCDA(Xs RICE NESHAP applicability guidance prior to and following the installatiion of the engine in January 2006.Considering this and the small amount of actual CO emissions since the engine has been operational, Regulator Marine's position is that there should be no issuance of a Notice of Violation,and we ask for your approval to move forward with the plan outlined in this letter. Regulator Marine, Inc.strives to comply with all regulations applicable to the operations to manufacture quality sport fishing boats,which is supported by our historical compliance record. We and our industry have been working to recover in recent years and we appreciate your support in this manner. If you have any questions or need additional information, please call me at(252)482-3837. Sincerely, REGU T RINE, INC. Bobby ensmor Vice President of Operations CC Gary Yoder—Resolute Environmental, LLC Attachments: Exhibits Z, 2, and 3 Caterpillar engine performance data Performance Testing Protocol �,.e Q EXHIBIT 1 i August 22, 2005 Robei t Fisher,Regional Super►isor Washington regional Office 943 Washington Square Mall Washington, NC 2'889 Subject. Installation of One (1)Diesel Peaking Generator Permit Exemption Po►►erSecu re, I rn. Edenton.Chonan County, North Carolina Dear Nlr. Fisher: Pon erSecure, Inc. I Po►cerSecuIC)respectfully requests a written determination►►tth respect to the planned installation and operation of one(1)500 kW peaking diesel generator to be located on property at 187 Peanut Dri►a in Edenton, NC (site of Regulator Marine,hicorporated). Pon erSecure►►ill be the operator of this facility and n ill not be employing full-time petsoiartel at the ph}sical site. Po►►-er5ecure will have complete functional control of the unit via remote communications and will dispatch the unit based on economic incentives provided by the local utilit). As the operator,we will also have responsibility for full service functions including preventative maintenance, emergency repairs,and fueling. The nen peaking generator will nieet the permit exemption level under 15A NCAC 2Q .0102(c)(2)(H)(►•i) [325,000 BNAir per 12-month period]. Also, the associated sub-basin fuel oil storage tank is exempt from per mitting pursuant to 15A NCAC 2Q.0102(c)(1)(D)(i). If you ha►a any questions or require further information, please contact me at 919-556-3056 (ext. 231). We look fora and to your response. Thank you for your attention in this matter. Yours ►cry truly, Chris Edge Vice President EXHIBIT 2 r - t A*3"Av HCDEHR North Carolina Department of Environment and Natural Resources DMSION OF AIR QUALlrY Michael F.Easley,Governor William G.Rasa Jr.,Secretary B.Keith Ovemash,P.E.,Director September 23,2005 Mr.Chris Edge Vice President PowerSecure,Inc 230 Capcom Ave.Suite 107 Wake Forest,NC 27587 Dear Mr.Edge: SUBJECT: Permit Applicability Determination Applicability Determination Application No.639 PowerSecure,Inc Edenton,Chowan County The Division of Air Quality received your application on September 9,2005 requesting that this Office determine whether an Air Quality Permit is necessary for one 500 kW diesel peaking generator to be located at 187 Peanut Drive in Edenton,Chowan County,North Carolina. In light of the information provided,personnel of the Division of Air Quality have reviewed your letter relative to applicability to Air Quality Permits,and our determinations are listed as follows: The peaking generator will meet the permit exemption requirement under 15A NCAC 2Q. 0102(a)(2)(B)(vi).The associated fuel oil storage tank will meet the permit exemption requirement under 15A NCAC 2Q.0102(c)(1)(D)(i). Therefore,this Office Isar determined that an Air Quality Permit is Not required. It should be noted that this exemption from the permitting requirement does not exempt PowerSecure,Inc from complying with the applicable emission control standards. It should be noted that any emissions resulting for the emission source must be accounted for on all facility wide emission summaries. washington Regional Dtriee 943 Washington Square hall,Waehingbn,North Carolina 27689 Phone:(M 90441111 FAX 9M)975.37191 Interne!:http:Hdagalaie.nc.usl 4e EMW 0=donftl AaMOaw AW=EemkRw.Z%GomeW Mr.Edge Page 2 September 23,2005 Furthermore,should you decide to modiry the process such that the result is an increase of emissions of air pollutants including toxic air pollutants,an Air Quality Permit may be required and PowerSecure,Inc sbould submit a permit application to this Office prior to such actions. It should also be noted that future Regulations including Federal Maximum Achievable Control Technology(MACT)for hazardous air pollutant(HAP)may be promulgated and adopted by the Division which apply to this type of manufacturing facility. If so PowerSecure,Inc may be required to apply for an Air Quality Permit for this equipment at that date. This exemption from the permitting requirement is based upon your statement that equipment has been and will be operated under the threshold levels as outlined in the Regulation. Please be advised that the operation of any air pollution emission sources which results in emissions in excess of the threshold levels without an Air Quality Permit is a violation of 15A NCAC 2Q.0101, "Required Air Quality Permits." If this facility is required to obtain an Air Quality Permit for this equipment in the future because of required emissions,each day of operation of the emission sources without an Air Quality Permit represents a separate violation. Such violations may be subject to enforcement action,including a civil penalty of up to$10,000 per violation andtor injunctive relief,pursuant to NCGS 143-215.114A. If you have any questions,with reference to the above matter,please do not hesitate to contact Yongcheng Chen at(252)948-3831. Sincerely,.;F,r Robert P.Fisher Regional Air Quality Supervisor cc: Washington Regional Office Central Files EXHIBIT 3 RESULATOR THE FINEST IN OFFSMUtE SPORTFISNING 80AT5 October 29,2009 Donald Van Der Vaart,PhD.,P.E., DAQ Permits Chief North Carolina Department of Environment and Natural Resources Division of Air Quality,Mooresville Regional Office 610 East Center Street,Suite 301 Mooresville,NC 28115 Re: Title V Air Permit Renewal Applicarion Regulator Marine,Inc. Edenton,Chowan County,North Carolina Facility ID:2100073 Dear Dr.Van Der Vaart: In accordance with Part 1,Section 3,Item K of our air quality permit(No.07132TO8)issued by the North Carolina Department of Environment,and Natural Resources,Division of Air Quality(NCDAQ),Regulator Marine,Inc.(Regulator Marine)is requesting a renewal of the permit for our facility located in Edenton, North Carolina. )i:ACIWTY BACKGROUND The Regulator Marine facility has the capacity to manufacture up to 365 fiberglass, sport fishing boats per year using open molding, injection molding, gel coating, sandinglgrinding, and assembly processes. The current permit includes the following emission sources: • ES-1: one fiberglass larninatinglgel coating operation [subject to 40 CFR Part 63, Subpart VVW: National Emissions Standards for Hazardous Air Pollutants (NESIiAP) from goat Manufacturing (also referred to as the goat Manufacturing MACI'standard] ■ ES-2: trimming, routing, and sanding of gelcoat, resins and fiberglass, which includes a central vacuum system consisting of cartridge filters in series with dual cyclones.To date,this source has not been installed. • Insignificant sources 1-1 (resin and gel coat storage) and I-2 and I-3 (mold release, bonding, and contact glue) The only significant combustion source on-site is a 500 kW diesel-fired emergency and peak generator.It is operated by Electricities,and is therefore not on Regulator Marine's air permit. There are no 15A NCAC 2Q.0523 changes (502(b)(10),off-permit,emission trading] requiring incorporation into the renewed air permit 187 Peanut Drive,Edenton,North Carolina 27932 • 252-482-3837 • www.reWlatoirmaritm.com REGULATOR TNF FINEST IN OFFSNORI SPORTFISNIN6 #OATS Dr. Donald Van der Vaaft,Ph.D.,P.E. October 29,2009 Page 2 EtKISSms Regulator Marine's processes emit volatile organic compounds(VOCs), which include federal hazardous air pollutants MAN and North Carolina (state-only) toxic air pollutants (TAPS) and particulate matter (PM). The organic HAPs emitted include styrene, toluene, hexane, dirnethylaniline, and methyl methacrylate. PM HAP emissions consist of cobalt compounds from gel coat materials.VOC emissions from gel coat and resin application in the lamnation process are grouped into two categories: volatile organic HAP (VOHAP) and non-HAP VOC. VOHAP emissions are estimated by calculating emission factors included in the current air permit. Non-HAP VOC emissions are estimated using a material balance approach, based on an assumption of 100% volatilization of the VOC content of a material. PM emissions from overspray in the lamination process were conservatively estimated assuming that 1% of the mechanically applied gel coats and resins are captured by the air handling system. Regulator Marine understands that this approach is consistent with similar boat building operations in North Carolina. Cobalt emissions were estimated by assuming that the average cobalt content from Material Safety Data Sheets from gel coat materials used by Regulator Marine. REGULATORY APPLICABILITY Each regulation applicable to Regulator Marine's operations is discussed in the attached Title V renewal application forms.Applicable regulations requiring additional discussion are addressed as follows: 15A NCAC 2D.1111(40 CFR Part 63, Subpart VVVV)—NESHAPs Regulator Marine is a major source of HAPs since the facility emits or has the potential to emit more than 14 tons per year of a single HAP or more than 25 tons per year of aggregate HAPs.As a result,Regulator Marine is subject to 40 CFR Part 63,Subpart WV V,National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing. This regulation applies to the fiberglass laminating/gel coating operations(ES-1)at the Edenton facility. Compliance with NESHAP is based on monthly material usage and emissions calculations as described in Subpart WVV and through prescribed work practice standards(including inspections)for mixing and equipment cleaning operations. As an existing facility in operation as a major HAP source prior to August 22,2001,Regulator Marine demonstrated compliance with Subpart WV V by August 23,2004.Regulator Marine currently operates in compliance with Subpart WW. 15A NCAC 2Q.0317-Avoidance Conditions The Edenton facility is located in Chowan County, which is in attainment for criteria pollutants,and its operations do not belong to one of the 28 Prevention of Significant Deterioration(PSD)source categories with a major source threshold of 100 tons per year.To avoid PSD applicability,Regulator Marine has a facility-wide VOC emission limit of 250 tons per consecutive 12-month period. Regulator Marine currently operates in compliance with this emission limit. 187 peanut Drive,Edenton,North Carolina 27932 ■ 252-482-3837 ■ www.regulaftrnmrine.com REGULATOR THE FINEST IN OFFSHORE SPORTFISNING 18M Dr.Donald Van der Vaart,Ph.D.,P.E. October 29,2009 Page 3 40 CFR Part 64—Compliance Assurance Monitoring(CAM)Rule Pursuant to CAM Rule guidance,a Title V operating permit application must address the applicability of the CAM Rule to the emissions sources at the Edenton facility.The rule was developed to provide reasonable assurance that large emissions units that employ air pollution control devices comply with established air emission standards.There is no add-on air pollution control device used at the Edenton facility,and therefore the CAM Rule does not apply. 15A NCAC 2Q.0700-Toxic Air Pollutant Procedures(state only) The current air quality permit includes facility-wide emission limits for the North Carolina TAP compounds methyl ethyl ketone,toluene,xylene,chromium VI.benzene,aniline,hexane,and styrene.All compounds, except styrene,cannot be emitted above the permitting thresholds established in 15A NCAC 2Q.0711. Styrene emissions are limited to 313 lb1hr based on a previous air dispersion modeling analysis.Regulator Marine currently operates in compliance with these emission limits. To satisfy the renewal application requirement,Forms AA and ES are included in Attachment 1 to this letter. Since there are no requested modifications to the existing permit, a zoning consistency determination and an application processing fee do not apply. Please contact me at(252)482-3837 or Mr. Crary Yoder of Resolute Environmental LLC at(919) 701-0009, with any questions you may have conceming the information presented herein. Very truly yours, REGULATOR MARINE,INC. Erik R<�fiboZrg Facilities Manager Attachment CC., Gary Yoder,Resolute Environmental LJ C 187 Peanut Drive,Edenton,Nodh Carolina 27932 • 252-482-3837 a www.regulatermarine.com Caterpillar Engine Performance Data Performance Data Page 1 of 7 CATERPILLAR a GEN SET PACKAGE PERFORMANCE DATA f 3PG415821 MARCH 27, 2013 (3PG0814)-ENGINE(C4G00310)-GE►rSET(G6800938)-GENE-RATOR For Help Desk Phone Numbers Click here Performance Number:DM9098 Change Level: 01 Sales Model:3456 D1TA Combustion-, DI Aspr:TA Engine Power: 500 W/F 521 W/O F Speed, 1,800 RPM After Cooler:ATAAC EKW EKW 764 HP ManiraW Type: DRY Gavernor Type:ELEC After Cooler Temp(F):- Turbo Quantity: I Engine App:GP Turbo Arrangement: Hertz:60 Application Type: PACKAGE-DIE Engine Rating:PG5 Strategy: Rating Type: STANDBY Certification:STAT-USE EPA-T 12006-2006 General Performance Data 1 FUEL INTAKE INTAKE EXH EXH ENGINE ENGINE FUEL INTAKE INTAKE GAS GEN WIF PERCENT POWER BMEP BSFC RATE MFLD MFLD P AIR MFLD STACK FLOW EKW LOAD SHP PSI LBIBHP- OPH TEMP IN-HG FLOW TEMr TEMP CFM HR DEG F CFM DEG F DEG F 500 100 764 349.69 0.33 36.32 121.1 70.18 1,384.34 1,30I.I8 990,96 3,919.93 450 90 681 311.4 0.33 32.12 II6.06 65.5 I,341.96 I,I97,68 890.42 3,552.66 400 80 602 275.43 0.32 27.82 109.22 58.34 I,253.67 1,096.16 823.46 3,I35.95 375 75 565 258.17 0.32 25.84 105.8 54.07 I,197.17 1,056.02 802.76 2,945.25 350 70 528 24I.49 0.32 24.01 102.56 49.57 I,137.13 1,025.42 788.9 2,765.I4 300 60 456 208.7I 0.32 20.66 96.62 40.78 1,017.06 966.02 761.9 2,429.65 250 50 387 176.8 0.32 I7.54 91.04 32.22 904.06 907.88 735.44 2,111.82 200 40 318 145.48 0.32 14.66 87.8 24.7 794,58 945.42 702.32 1,804.58 150 30 248 I13.57 0.33 I1.78 84.92 17.74 692.17 774.32 659.I2 1,504.41 125 25 213 97.32 0.34 10.36 83.66 14.45 639.2 735.26 633.56 1,356.08 100 20 177 80.79 0.35 8.93 82.58 I1.49 593.29 687.02 599.28 1,214.83 50 10 103 47.28 0.41 6.02 80.24 6.51 519.I3 556.16 492.98 953.5 General Performance Data 2 GEN ENGINE COMPRESS COMPRESS PERCENT OUT OUT EKW LOAD POWER R PRESS TEMP IN+IG DEG F 500 100 764 73.92 429.09 450 90 681 %94 395.78 400 80 602 61.6 356.36 375 75 565 57.15 337.1 350 70 528 52.47 318.2 300 60 456 43.32 281.66 250 50 387 34.38 245.84 200 40 318 26.56 213.44 ISO 30 248 19.28 182.12 125 25 213 15.87 167 100 20 I77 12.79 152.78 50 10 103 7.67 126.68 http:lltmiwebclassic.cat.comltmilservletlTMIDirectur?Action=huildtab&refkind=RNTNQRefNum&tab=P... 3/27/2013 Performance Data Page 2 of 7 Engine Heat Rejection Data GEH W!F PERCENT REJ TO REJ TO REJ TO R[.�d�V 70 FROM FROM WORT( LHV HHV JW ATMOS EXHAUST OIL CLR AFT CLR ENERGY ENERGY ENERGY EKW LOAD BTUIMN BTUIMN BTUIMN BTUIMN BTUIMN BTUIMN BTUIMN BTUIMN BTUIMN 500 100 11,3I7.I 4,339.2 28,491.8 16,435.4 4,185.6 7,165.6 32,415.8 78,594.2 83,712.5 450 90 9,326.7 4,634.9 24,624.7 I3,478.2 3,690.9 6,3I2.6 28,889.9 69,267.5 73,760.2 400 80 8,I32.4 4,037.8 20,928.1 10,9I9.0 3,190.4 5,232.0 25,534.6 59,940.9 63,864.9 375 75 7,677.4 3,628.3 19,335.8 9,895.4 2,962.9 4,663.3 23,942.2 55,675.6 59,315.3 350 70 7,336.2 3,298.4 I7,970.9 9,099.2 2,758.2 4,151.5 22,406.7 51,751.6 55,163.8 300 60 6,653.8 2,746.8 15,468.6 7,620.6 2,371.5 3,184.7 19,335.8 44,472.2 47,372.6 250 50 6,028.2 2,337.4 13,080.1 6,312.6 2,013.2 2,388.5 I6,378.5 37,761.6 40,263.9 200 40 5,800.7 1,740.2 I0,919.0 5,061.4 I,683.3 I,706.1 13,478.2 3I,562.8 33,610.1 150 30 6,369.4 244.5 8,758.0 3,810.3 1,347.8 1,137.4 10,520.9 25,364.0 27,013.2 125 25 6,653.8 -534.6 7,677.4 3,241.6 1,188.6 909.9 9,042.3 22,293.0 23,714.7 100 20 6,938.1 -1,336.4 6,653.9 2,616.0 I,023.7 682.4 7,506.8 19,165.2 20,416.3 50 10 7,506.8 -3,036.9 4,492.7 1,308.0 688.1 398.1 4,379.0 12,966.3 13,819.4 http://tmiwebelassic.cat.com/tmilservleuTMIDireetor?Action=buildtab&.refkind=Rl°+1TMRefNum&.tab=P... 3/27/2013 Performance Data Page 3 of 7 EMISSIONS DATA STAT-USE EPA-T1 2006-2008 P2 This engine meets EPA Tier 1 Equivalent Emission Levels for stationary use in 2006. Gaseous emissions data measurements are consistent with those described in EPA 40 CFR PART 89 SUBPART D and iSG 8178 for measuring HC,CO,PM, and NOx. Gaseous emissions values are WEIGHTED CYCLE AVERAGES and are capable of meeting the following non-road emission levels: LOCALITY AGENCYILEVEL MAX LIMITS-g/KVV-hr U.S. (Ind Calif) EPAITIER-1 CO:11.4 HC:1.3 NOx:9.2 PM:0.5 REFERENCE EXHAUST STACK DIAMETER 6 IN WET EXHAUST MASS 6,375.8 LBIHR WET EXHAUST FLOW(980.60 F STACK TEMP) 3,9I9.93 CFM WET EXHAUST FLOW RATE(32 DEG F AND 29.98 IN HG} 1,307.00 STD CFM DRY EXHAUST FLOW RATE(32 DEG F AND 29.98 fNl HG) 1,197.52 STD CFM FUEL FLOW RATE 36 GALIHR http:/hmiwebciassic.cat.com/tmi/servlettMDirector?Action=buildtab&refkind=RNIMRefNum&tab=P... 3/27/2013 Performance Data Page 4 of 7 RATED SPEED"Potential site variation" GEN ENGINE TOTAL TOTAL TOTAL PART OXYGEN PWR PERCENT POWER NOX iAS CO HC MATTER IN EKW LOAD SHP N021 LEAiR LEAiR LBIHR EXHAUST LBIHR PERCENT 500 100 764 10.2300 .8100 .1000 .0700 8.6000 375 75 565 8.0300 .5300 .1300 .0800 I0.9000 250 50 387 7,4000 .4600 .1200 .0800 11.90D4 125 25 213 4.3600 .4200 .1100 .0700 I3.50D4 50 10 103 2.3900 .5400 .I100 .0500 15.7000 RATED SPEED"Nominal Data" GEN PERCENT ENGINE TOTHOT AL TOTAL TOTAL TOTAL PART OX IN GENEN PWR LOAD POWER N ( CO HC CO2 MATTER EXHAUST BK BHP LEMR. L81HR LBIHR LBlHR LSJHR PERCENT 500 100 764 8.4500 .4300 .0500 819.9 .0400 8.60D0 375 75 565 6.6400 .2800 .0700 590.4 .0400 10.9000 250 5o 387 6.1100 .2400 .0600 403.9 .0400 1I.9000 125 25 213 3.6000 .2200 .0600 237.2 .0400 13.5000 50 10 103 1.9700 .2900 .0600 139 .0300 15,7000 http:ddtmiwebclassic.cat.cord=VservletrrNUDirector7Action=buildtab&refkind=RNTMIRefNurn&tab=P... 3/27/2013 Performance Data Page 5 of 7 Altitude Capability Data(Corrected Power Altitude Capability) Ambient Operating Temp. so F 98 F 09 F too F 122 F NORMAL Attitude 0 F 764.38 hp 764.38 hp 764.38 hp 764.38 hp 764.38 hp 764.38 hp 984.25 F 764.38 hp 764.38 hp 764.38 hp 764.38 hp 764.38 hp 764.38 hp 1,640.42 F 764.38 hp 764.38 hp 764.38 hp 764.38 hp 748.29 hp 764.38 hp 3,280.84 F 764.38 hp 764.38 hp 750.97 hp 726.83 hp 705.38 hp 764.38 hp 4,92I.26 F 756.34 hp 730.86 hp 706.72 hp 683.92 hp 662.46 hp 729.51 hp 6,56I.68 F 712.08 hp 687.94 hp 665.I5 hp 643.69 hp 623.57 hp 693.31 hp 8,202.1 F 669.17 hp 646.37 hp 624.92 hp 604.8 hp 586.03 hp 658A4 hp 9,842.52 F 627.6 hp 606.I4 hp 586.03 hp 567.25 hp 549.82 hp 624.92 hp 10,498.69 F 611.51 hp 59I.39 hp 571.27 hp 553.84 hp 536.41 hp 612.85 hp The powers listed above and all the Powers displayed are Corrected Powers Identification Reference and Notes Engine Arrangement: 2921911 Lube Oil Press @ Rated Spd(PSI): 66.7 Effective Serial No: 3PGO2I67 Piston Speed @ Rated Eng SPD(FTIMin): 1,974.4 Primary Engine Test Spec: OK2702 Max Operating Altltude(F'C): 3,395.7 Performance Parm Ref: TM5739 PEEC Elect Control Module Ref Performance Data Ref: DM9098 PEEC Personality Cont Mod Ref Aux Coolant Pump Perr Ref: Cooling System Perf Ref: Turbocharger Model GT500802 1.60VTF Certification Ref: STAT USE EPA Tl Fuel Injector Certification Year: 2006 Timing-Static(DEC): -- Compression Ratio: 16.1 Timinotatic Advance(DEG): -- Combustion System: dl Timing-Static(MM): -- Aftercooler Temperature(F): -- Unit Injector Timing(MM): -- Crankcase Blowby Rate(CFH): -- Torque Rise(percent) -- Fuel Rate(Rated RPM)No Load(GaItHR): -- Peak Torque Speed RPM - Lube Oil Press @ Low Idle Spd(PSI): 65.6 Peak Torque(LB/FT): -- http:lltiniwebclassic.cat.com/tmilservIeVTMIDirector?Action=buildtab&refkind=RNTMIRefNum&tab--P... 3/27/2013 Performance Data Page 6 of 7 Reference STAT-USE EPA-TI 20062006P2 Number:DM9098 Paramet Referencee:TM5739 GEN SET - PACKAGED - DIESEL TOLERANCES: AMBIENT AIR CONDITIONS AND FUEL USED WILL AFFECT THESE VALUES. EACH OF THE VALUES MAY VARY IN ACCORDANCE WITH THE FOLLOWING TOLERANCES. Power +1-3% Exhaust Stack Temperature +1-8% Generator Power +1-5% Inlet Airflow +1-5% Intake Manifold Pressure-gage +1- 10% Exhaust Flow +1-6% Specific Fuel Consumption +1-3% Fuel Rate Heat Rejection Heat Rejection-Exhaust Only +1- 10% T4i Tolerance Exceptions C 5:PowerTolerence +4%,-0`Y6 C27:PowerTolerance +0%,-4% CONDITIONS: ENGINE PERFORMANCE IS CORRECTED TO INLET AIR STANDARD CONDITIONS OF 99 KPA(a9.31 IN HGj AND 25 DEG C(77 DEG F). THESE VALUES CORRESPOND TO THE STANDARD ATMOSPHERIC PRESSURE AND TEMPERATURE IN ACCORDANCE WITH SAE J1349. ALSO INCLUDED IS A CORRECTION TO STANDARD FUEL GRAVITY OF 35 DEGREES API HAVING A LOWER HEATING VALUE OF 42,780 KJ/KG(18,390 BTUILB)WHEN USED AT 29 DEG C(64.2 DEG F)WHERE THE DENSITY IS 838.9 GIL(7.002 LBIGAL). THE CORRECTED PERFORMANCE VALUES SHOWN FOR CATERPILLAR ENGINES WILL APPROXIMATE THE VALUES OBTAINED WHEN THE OBSERVED PERFORMANCE DATA IS CORRECTED TO SAE J1349,ISO 3046-2&8665&2266&0249& 1585,EEC 80/1289 AND DIN70020 STANDARD REFERENCE CONDITIONS. ENGINES ARE EQUIPPED WITH STANDARD ACCESSORIES,LURE OIL,FUEL PUMP AND JACKET WATER PUMP. THE POWER REQUIRED TO DRIVE AUXILIARIES MUST BE DEDUCTED FROM THE GROSS OUTPUT TO ARRIVE AT THE NET POWER AVAILABLE FOR THE EXTERNAL(FLYWHEEL)LOAD. TYPICAL AUXILIARIES INCLUDE COOLING FANS,AIR COMPRESSORS,AND CHARGING ALTERNATORS. RATINGS MUST BE REDUCED TO COMPENSATE FOR ALTITUDE ANDIOR AMBIENT TEMPERATURE CONDITIONS ACCORDING TO THE APPLICABLE DATA SHOWN ON THE PERFORMANCE DATA SET, ALTITUDE: http://tmiwebclassic.cat.com/tmi/servIeVTNHDirector?Action=buildtab&refkind=RNTNURefNum&tab=P... 3/27/2013 Performance Data Page 7 of 7 ALTITUDE CAPABILITY-THE RECOMMENDED REDUCED POWER VALUES FOR SUSTAINED ENGINE OPERATION AT SPECIFIC ALTITUDE LEVELS AND AMBIENT TEMPERATURES. COLUMN"N"DATA-THE FLYWHEEL POWER OLITPUT AT NORMAL AMBIENT TEMPERATURE. AMBIENT TEMPERATURE-TO BE MEASURED AT THE AIR CLEANER AIR INLET DURING NORMAL ENGINE OPERATION. NORMAL TEMPERATURE-THE NORMAL TEMPERATURE AT VARIOUS SPECIFIC ALTITUDE LEVELS IS FOUND ON TM2001. THE GENERATOR POWER CURVE TABULAR DATA REPRESENTS THE NET ELECTRICAL POWER OUTPUT OF THE GENERATOR. GENERATOR SET RATINGS EMERGENCY STANDBYPOWER(ESP) OUTPUT AVAILABLE WITH VARYING LOAD FOR THE DURATION OF AN EMERGENCY OUTAGE. AVERAGE POWER OUTPUT IS 70%OF THE ESP RATING. TYPICAL OPERATION IS 50 HOURS PER YEAR,WITH MAXIMUM EXPECTED USAGE OF 200 HOURS PER YEAR. STANDBY POWER RATING OUTPUT AVAILABLE WITH VARYING LOAD FOR THE DURATION OF AN EMERGENCY OUTAGE. AVERAGE POWER OUTPUT IS 70%OF THE STANDBY POWER RATING. TYPICAL OPERATION IS 200 HOURS PER YEAR,WITH MAXIMUM EXPECTED USAGE OF 500 HOURS PER YEAR. PRIME POV&R RA TING OUTPUT AVAILABLE WITH VARYING LOAD FOR AN UNLIMITED TIME. AVERAGE POWER OUTPUT IS 70%OF THE PRIME POWER RATING. TYPICAL PEAK DEMAND IS 100%OF PRIME RATED EKW WITH 10%OVERLOAD CAPABILITY FOR EMERGENCY USE FOR A MAXIMUM OF 1 HOUR IN 12. OVERLOAD OPERATION CANNOT EXCEED 25 HOURS PER YEAR. CONTINUOUS POWER RATING OUTPUT AVAILABLE WITH NON-VARYING LOAD FOR AN UNLIMITED TIME. AVERAGE POWER OUTPUT IS 70-100%OF THE CONTINUOUS POWER RATING. TYPICAL PEAK DEMAND IS 100%OF CONTINUOUS RATED EKW FOR 100%OF OPERATING HOURS, SOUND DEFINITIONS: Sound Power:DMS702 Sound Pressure:TM7080 Date Raleaaed:03114M Caterpillar Confidential:Green Content Owner.Shane Gilles Web Masters):PSG Web Based Systems Support Current Date:Wednesday,March 27,2013 3:08:53 PM m Caterpillar Inc.2013 All Rights Reserved. Data Privacy Statement http:lltmiwebclassic.cat.comltmilservlet/TNflDirector?Action=buiidtab&refkind=RNTMIRefNum&tab=P... 3/27/2013 Certify Rerate Page 1 of 1 EMISSIONS DATA[3PG018141 MARCH 27, 2013 (3PG0l894)•ENGINE(C4G00310).GENSEr(G6800938)-GENERATOR For Help Desk Phone Numbers Click licrelicre Engine Emissions Data For Emissions feedback and questions contact: engine certificatiQnCo�cat.g M "This link is case sensitive." his emission data is Caterpillar's best estimate for this rating. If actual emissions are required hen an emission test needs to be run on your engine. Serial Number(Machine) Serial Number (Engine) 113PGO1814 Sales Model 13456 Build Date 2005-07-18 Interlock Code Progression JINo Interlock Code Progression s Shipped Data Engine Arrangement Number 2379567 Certification Arrangement [Test Spec Number 0K2702 Certification EPA 1 CARB wl PM FEL @ Constant S eed Labeled Model Year lFamily Code Flash File 2628918 Flash File Progression 2828918 CORR FL Power at RPM 72 HP (576.0 KW) at 1800 rpms dvertised Power JJ764hp 1,800RPM Total Displacement This is not an official emission certificate. This is for emission data information Caterpillar Confidential:Green Content Owner:Shane Gilles Web Master(s):PSG Web Based Systems Support Current Date:Wednesday,March 27,2013 3:14:10 PM Q Caterpillar Inc.2013 All Rights Reserved. Data Privacy StftJCMWL http://hniwebclassic.cat.com/tmi/servlet/TNUDirector?Action=buildtab&refkind=RNTNMefNwn&tab=C... 3/27/2013 Page 1 of 1 C4000310 PIPsIPSPs Product Con lguratlon Product Coverage OPTIESC Customer Name and Address Arrangement No: 237-9567 Build Dote: 12Aug2005 Engine Information Mfg Model: 3456 Factory ship Date: Not Applicable Specifications Mktg Model Year: 2005 Dealernnvolced Ship Date: 17Aug2005 Prod Family: ZJ 34561C16 Engines sales Date: 30No►r2005 Application Sims Prod Family: 61 Generator Set Engines Delivery Date: 2&len20D6 F Standby Power Source Faclilty: LE Grfffln Packaging Facility Selling Dir. am Principle Work: C72 Commercial Business Owner Cie: A https://sims.cat.couVsimstservlet/cat.dcs.ssd.simsi.salesandservice.5alesInformationServlet?serialnumber... 3/27/2013 Performance Testing Protocol Original Date:eJ6/2012 Dates Revised: i PROTOCOL SUBMITTAL FORM (RECIPROCATING INTERNAL COMBUSTION ENGINES) FOR COMPRESSION IGNITION ENGINES ONLY The purpose of this Protocol Submittal Form is to initiate communication between representatives of the facility to be tested,the testing consultants,and the DAQ as well as to identify and resolve any specific testing concerns prior to testing. This form is to be used only for testing engines for the purpose of complying with RICE emission standards. For other testing,please submit the standard Protocol Submittal Form Regional Office: ❑Asheville ❑Fayetteville ❑Mooresville ❑ Raleigh MrWashington ❑Wilmington ❑Winston-Salem Facility name: Tasting Company: Facility ID No: Facility Contact PersanlMailing address&email Testing Company Contact Person Mailing Address r&email I I I Email Address: Email Address: Phone: ------ -T - _ Fax: Phone: Fax: I Mobile No: �W _ Mobile No: T ENGINE INFORMATION Engine Name or Description: T Engine Use: ❑Fmergency Stationary ❑Black Start ❑Flre Pump If Peak Shaving ❑Other Non-Emergency,Non Black Start W Engine Size:^ ❑ e 100 HP ❑ 100 s HP 5 300 HP �_O 3D0 HP t HP 5 500 HP ®`a 500 HP ❑ 100 HP S HP s 500 HP Digester gas ❑ 100 HP s HP s S00 HP Landfill gas Other Engine Type and Description Not Listed Above(Please specify): Y �^ Note:Existing emergency and black start stationary engines do not require emissions testing. Other requirements may apply. Reason(s)For Testing: - To verify compliance with 40 CFR Part 63,Subpart ZM after addition of diesel oxidizing catalyst to reduce mrbon monoxide emissions. Is this engine. UrNew or Reconstructed ❑Existing Is this engine located at a(n) dMajor(MALT)source - �._ 0 Area(GACT)Source Process and Operations Data: Describe how process operating rate and other proms and operating parameters will be gathered TESTING WILL NOT BE ACCEPTED WITHOUT APPROPRIATE PROCESS OPERATIONS AND OTHER APPRORIATE OPERATING PARAMETER DATA. New DOC data logging system In addition to current monitoring(load,operating time,etc} TESTING METHODS AND METHODOLOGY POLLUTANTS Carbon Monoxide Emissions and Portable CO and 02 Analyzer using ASTM 06522 00(2005)at outlet? Dyes eNo Reduction(Cl RICE) k If yes, what kind? Measurements of CO and 02 must be made at the same time corrected to 15%} Inlet and outlet testing of control device? w OYes VNa Inlet and outlet testing using A"D6522-00(2005)? T OYes IdNo Inlet and outlet CO testing using Reference Method UP OYes; IONo Length of runs - �.�- Stationary RICE Sampling port location by Reference Method 1(or 1A)? 6ifes 13No (Limit Concentration of Formaldehyde Determine 02 Concentration by Reference Method 3,3A,or 36? or CO in the Exhaust) _— __ __._ _._W.-- — &rPes []No Determine CO Concentration by ASTM D6522-00(2005)? OYes 511ho Determine CO Concentration by Reference Method 10 dues ❑No Determine Moisture Content?Specify Method ? T OYes �9flo Determine Formaldehyde by Reference Method 320 or 323 []Yes 19(No Determine Formaldehyde by A5TM D6348-03 with analyte spiking per I Annex A5 OYes S(No Proposed test schedule(DAQ Supervisor must be notified at least 15 days prior to the actual test date). THIS FORM DOES NOT CONSTITUTE 15 DAY REGIONAL OFFICE NOTIFICATION: Will all testing be conducted in strid accordance with the applicable kest method? If no,attach complete documentation of all if Yes ❑ No test method modifications Has all testing equipment been calibrated in accordance with EPA or ASTM requirements. If no,attach explanation lir Yes ❑ No Is this test the Initial performance test to demonstrate compliance d Yes ❑ No Signatures: Representatives from the facility and the contracted testing company must provide signatures below Certifying that the Information Provided on this form and any attached information is accurate and com lete. Lanceeo �m•abq,. _ ^ Ferguson Facility Representative Date Testing Company Representative Date Name: grelle AP dJ,,dojeC Name, Lance Ferguson Title: .i4eoc.4 f�tl 119�,rL+ Tide: Director,Sales and Markebng Company; re6,gv,-* a��,�� e-. Company:Analytical Testing Consultants,Inc.