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10. All engines built after 6/12/2006 must be built to include the new standards. <br />None of ERMU's diesels comply with the new standards. <br />11. The new regulations state that by 8/3/2010 an Initial Notification to the EPA was <br />required regarding the affected sources. ERMU did meet this requirement. <br />12. The new regulations state that if the diesel is not upgraded to meet the new <br />standards, it can be designated an Emergency Unit, and can run up to 100 <br />hours/year for readiness testing, but only 15 hours (which is part of the 100 <br />hours) for defined emergency running. It can run 50 hours/year for non- <br />emergencies, but 50 hours must be part of the 100 hours, and the unit can <br />receive no financial accreditation for the running. The Emergency Unit can run <br />for unlimited hours during an outage on the interconnection. <br />13. If the ERMU diesels are to continue to be able to operate the number of hours <br />permitted by the current MPCA permit, emissions controls must be placed on <br />whichever diesels are selected to operate that way. The given diesel must be <br />retrofitted with a direct oxidation catalyst (DOC), which can be placed in line <br />with the existing exhaust silencer, or the exhaust silencer can be replaced with a <br />combination exhaust silencer and DOC. The new system must include <br />installation of a closed crankcase ventilation system or filtered open crankcase <br />system. An emissions monitoring system must be installed with ongoing <br />emissions records kept at the job site. Approved low sulfur fuel oil must be used <br />in the diesel. After the conversion is complete, testing needs to be done to <br />assure emissions are reduced by 70%, or to 23 ppmvd. All units must be <br />compliant with NESHAP by 5/3/2013. <br />14. In 2010, the diesels allowed ERMU to receive a $352,440 in capacity credits plus <br />fuel, labor, maintenance, and overhead costs for URGE tests <br />15. Under the proposed rules, municipals in an Emergency Demand Response (EDR) <br />program could not run their diesels for the EDR, more than 15 hours per year, <br />and could not receive capacity credits for this capability. <br />17 <br />