Comment submitted by R. H. Pankratz, Babcock & Wilcox Technical Services Pantex, LLC

40 CFR Part 63 [EPA-HQ-OAR-2007-0995; FRL-8581-6] Emission Standards of Stationary Diesel Engines Comments submitted by Babcock & Wilcox Technical Services Pantex, LLC the operating contractor of the DOE's Pantex Plant via on-line commenting option. Comment As the proposed rule exempts an emergency engine, the definition of an emergency engine needs to be clear and either referenced from existing regulations or defined in this regulation. This commenter prefers that the EPA define ?Emergency Engine? within this rule and that ?Emergency Engine? be defined as: In the event that there is a disruption in electrical service or other critical utility caused by events beyond the control of the owner or operator of the engine, an emergency engine is an engine that provides: ? Electrical service to critical functions; ? Pressure to potable water, wastewater systems, and critical utilities; or ? Fire support or system engines as defined by the National Fire Protection Association [NFPA]. The operations of such engines include running the engines for routine or preventative maintenance necessary to insure the reliability of the engine. Background Historically, EPA and other organizations (e.g., NFPA) have established categories for emergency engines, and within that group - Fire Support or System engines. This commenter recommends that this categorization by usage be continued. It is noted that the definitions for the engines between the two organizations are sometimes conflicting and therefore to clarify the definition, the definition provided meets the intent of the category of engines for both the regulator and regulated community. Similarly, both ?Emergency Engines? and ?Fire System Support Engines? are routinely operated more for testing the operability of the system, to assure that when the support is needed, it will function properly. In the past, EPA has issued guidance indicating the number of hours that such operations should be allowed in any 12-month period. Operation for more than those limited number of hours might then be considered for enforcement, either for the purposes of major/minor NSR or because of Federal Operating Permit 'event reporting' - even though the operations of the power units will likely result from events beyond the control of the owner (e.g., loss of electrical power from the 'grid', storm or other 'force majeure' events). This commenter has been advised that, in the State of Texas, public drinking water and wastewater treatment systems may soon be required to install un- interruptible power systems to assure the operation of these conveyances during events that cause the disruption of electrical services to the utilities. Thus, the number of emission units may soon increase significantly along the Gulf Coast. EPA should work with all appropriate program offices within the EPA and with other agencies within the various states to assure that any regulatory effort to set emission standards for diesel engines of the size proposed for regulation are developed with knowledge of the function that those engines will be expected to provide. This commenter does not believe that setting an absolute standard of operating time to define this category of engines is in the best interest of the regulator, the regulated community, the public, or the environment. Setting limits too stringent on operational testing of the units may impede regulated entities from assuring that their systems will be ready should they ever be called into full service. In addition, if there was an event that required extended operation of the engines, this commenter does not believe it is the intent of the proposed rule to change the classification of the engines based on that event. See also EPA-HQ-OAR-2007-0995-0024(09000064803ba135)