Field Office Compliance - Assistance

Assistance ID - 119102
John Deere Dubuque Works - 310201475
18600 S John Deere Rd Dubuque, IA 52001
Dubuque County

FO 1

Report
File Name File Type File Date Note
Comments
6/11/2021 6-11-2021 After speaking with Dan Mai I spoke with AQB. I spoke with Mr. Mai and told him it would be best not to use the generator with no dp unit, but if he must he should know it will be a violation. I relayed to him that this violation must be reported in the next compliance plan including action plan, etc. We also discussed if the hours used is exceeded for this generator he must report that on the semi-annual report that is due the end of July 2021. (I also discussed this with S. Mousel of AQB) BRENDA STREICHER
6/11/2021 Phone call with the below follow up email on 6-11-2021: Hi Brenda, As discussed on the phone, Dubuque Works was curtailed by Aliant Energy yesterday around 2:00 P.M. Our powerhouse staff initiated the curtailment plan, which includes supplying power to the factory using our standby diesel generators. We have a CPMS to monitor catalyst differential pressure and temperature per the RICE NESHAP. Differential pressure gauges and temperature gauges were recently calibrated as part of our annual preventive maintenance program. During the curtailment operation, the CPMS was showing high temp alarms and differential pressure alarms (hardware faults) on several engines. Troubleshooting has been ongoing today. With the extreme temperatures looming today, we are at risk of being curtailed again. If we are curtailed today, we plan to run engines 8, 9, and 10. The only alarms received on these three engines yesterday were high temp on #9 and high DP on #8. Our electricians are checking functionality of the temp gauge on #9 and we replaced the #8 catalyst with a clean (like for like) catalyst today. The DP gauges on #5, 6 and 7 have malfunctioned (hardware faults). #5 was experiencing high temp alarms and the catalyst was replaced with a clean (like for like) catalyst today. #6 and #7 did not experience any high temp alarms. My question is can we run #5, 6 and/or 7 if we are not able to get the DP gauges repaired prior to curtailment today (i.e., are we allowed to run during a known monitoring malfunction)? Let me know if you have any questions. Per the RICE NESHAP, these engines are categorized as existing stationary RICE >500hp. I did not see any language in the NESHAP that requires us to shut down the engines if we have a monitoring system issue. Thanks for your help. Please call me with any questions. Dan Mai Lead Environmental Engineer John Deere Dubuque Works Phone: 563-589-5082 Mobile: 563-213-0588 BRENDA STREICHER
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