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(c) 50 hours/year for non-emergencies, but the 50 hours cannot generate income, <br />and the 50 hours must count towards the above 100 hours; or <br />(d) a maximum of 15 hours per year, which would count towards the above 100 <br />hours, as part of an Emergency Demand Response EDR) program. <br />This would be in a situation such as when a grid failure was imminent, but had not yet <br />occurred. ERMU could not continue its present programs of credits on wholesale power <br />purchases, under the proposed regulations. The IAMU, MMUA, and CMMPA have asked <br />that the 15 hours be increased to 100 hours, which would be a three-year rolling <br />average, and which would be beyond the 100 hours for readiness testing, including the <br />right for municipals to negotiate with their power suppliers for financial accreditation, <br />for these emergency units. If EPA agrees to the revised 100 hours, or even to 60 hours, <br />then ERMU could continue to receive capacity credits without installing emissions <br />controls. <br />If the unit is to be used for its present operation then, under the presently proposed <br />rules, the engine must be tested for emissions levels. The system must be retrofitted <br />with a Direct Oxidation Catalyst (DOC) silencer, which can be installed in place of the <br />existing exhaust silencer, or must re-use the existing exhaust silencer with an in-line <br />DOC. The new system must include installation of a closed crankcase ventilation <br />system, or a filtered open crankcase ventilation system, to prevent or diminish oil mist <br />in the atmosphere. <br />An emissions monitoring system must be installed, and emissions records must be kept <br />at the job site. An approved maintenance system must be implemented for each new <br />system. Approved low sulfur fuel oil must be used in the retrofitted engine. <br />After the conversions are completed, testing needs to be done to assure that CO <br />emissions are reduced by 70°~, or the CO level is reduced to 23 ppmvd (parts per million <br />