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MEMORANDUM DATE: January 2 0, 2011 TO: Melanie King, EPA OAQPS/SPPD/ESG FROM: Tanya Parise , EC/R, Inc. SUBJECT: Summary

of the December 15 , 2010 Meeting with API Regarding CPMS I ssues in Petition to Reconsider on RI CE NESHAP

INTRODUCTION The American Petroleum Institute (API ) requested this meeting with EPA to discuss the petition for reconsideration submitted by API on the National Emission Standards for Hazardous Air Pollutants (NESHAP) for stationary reciprocating internal combustion engines (RICE) . T he most recent amendments to the NESHAP for s tationary RI CE were published in the Federal Register on August 20, 2010 (75 FR 51570 ). ATTENDEES Michael Horowitz, EPA Jeff Adams, BP Bob Wayland, EPA John Admire, DCP Midstream Melanie King, EPA (b y phone) Bill Grygar, Anadarko Tanya Parise, EC/R (b y phone) Rebecca Rentz, Bracewell & Giuliani (by phone) Michael McBride, Van Ness Feldman Mike Wasson, Exterran (by phone) Andrea Feldman, Van Ness Feldman Tom Monahan, ExxonMobil (by phone) Bill Wehrum, Hunton & Williams Jeff Panek, IES (b y phone) J ohn Wagner, API Clay Freeberg, Chevron (by

phone) Matt Todd, API S UMMARY OF MEETING API submitted a petition for reconsideration on October 19, 2010 on the stationary RI CE N ESHAP (EPA - HQ - OAR - 2008 - 0708 - 0582 ) . The petition included a request for reconsideration on the monitoring requirements that were included in the August 20, 2010 final rule. S pecificall y, API requested this meeting with EPA to discuss the continuous parametric monitoring sy stem (CPMS) requir ements that apply to existing stationary engines . API provided an agenda for the meeting of CPMS issues it wanted to discuss , which follows this meeting summary . 

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# / R Incorporated Providing Environmental Technical Support Since 19892

APIindicated that it has concerns with the short and long - term impacts of the CPMS require ments for stationary engines, particularl y with the short - term impacts because stationary engines at major sources that were originally cove red under the 2004 rule will have to comply with the se requirements in the near future. According to API, there is inadequate time to implement the CPMS requirements for major sources. API indicated that its long - term concerns are more related to existing stationary engines at area sources. API was eager to assess how to reach productive ne xt steps to resolve the issues associated with the CPMS requirements. According to API, 100 percent data capture is virtually impossible . API indicated that it is not aware of an y other EPA regulation that require s total data capture. For instance, pow er failures and s ys tem reboots alone will make total capture of monitoring data impossible. According to API, the 100 percent data capture requirement is impractical and the organization disagrees with this requirement . Man y EPA rules require 90 to 95 pe rcent data c apture and some require 70 percent data capture , according to API. Further, API asked if every 15 - minute increment would be a deviation and if the engine would be out of compliance if the data was not available. In API’s opinion, the lack of data does not necessaril y mean that the engine was actu all y out of compliance . API also indicated that the initial calibration of thermocouples would be problematic to complete within 90 day s. (This requirement relates to obtaining inlet catal ys t temperature readings.) In terms of issues related to CPMS requirements for engines at area sources, APIargued that there are a number of parameters at particularly rural area sources that are compelling reasons for not requiring CPMS at these locations. R ural sites are often not manned, they may lack electricity , and it may be difficult to install and maintain controls at these remote sites , according to API . Sites would necessitate reliable power sources in order to properl y fulfill CPMS requirements and som e rural sites do not have power at all . In addition, many rural sites do not have communication access , which is another limiting factor. Also, determining accurate load is not possible at many sites, e.g., in some cases an operator would be un able to me asure the flow per engine because the engine is grouped with other engines. Good infrastructure is needed and API indicated that it believes it is more of an issue with rural sources. APIindicated that it is technically

feasible, but that it is not econ omically feasib le and argued that EPA needs regulatory

and economic justification for the CPMS requirements . APInoted that it had provided comments on the original CPMS rule that have not been addressed. In addition, there was no opportunity for comment on the engine CPMS requirements since it was just added to the final rule. API recommended that EPA issue an administrative stay for the CPMS requirements specificall y and asked what it could provide to assist EPA delaying the requirements for maj or sources . EPA noted that it is open to continued discussion and a sked how the CPMS requirements in the final rule are different from how owners and operators of stationary engines are currently capturing monitoring data. API could not provide a speci fic answer, but indicated that based on OECA’s 2005 Questions and Answers document 1 , there are companies that are not monitoring 1 Memorandum from Michael S. Alushin, Director, Compliance Assessment and Media Program Division to Region Air Compliance Branch Chiefs (I - X). September 30, 2005. National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE)

– Questions and Answers.3

catal ys t inlet temperature at all or if they are capturing data, companies are capturing 95 percent of the data at most . API i ndicated that it would send a formal letter to EPA describing the specific issues it is reque sting an administrative stay . A follow - up meeting with APIis scheduled for January

6, 2011 to further discuss these issues.4 Meeting Agenda Date: December 15, 2010 Location: EPA, Washington D.C. Time: 1:00 p.m. to 2:00 p.m. ET Discussion of CPMS Issues in Petition to Reconsider Reciprocating Internal Combustion Engine NESHAP, Final Rule, 75 Fed. Reg. 51,570 1:00 Introductions & Meeting Objectives

– Elim inate CPMS Requirements for Area Sources Technical Concerns/Deficiencies  Data availability requirements (100% data capture)  “Deviation” implications  Thermocouple calibration requirements Area Source Monitoring Compliance Implementation Issues

 Area sources urban vs rural  Lack of site power  Site communication access is limited at area sources  Must be able to integrate with other monitoring equipment within a field.  Must be integrated with other field monitoring equipment and meet industry and co mpany standards  Installation in weatherproof containers  Determining load during monthly differential pressure monitoring is impractical at area sources Need / Justification for Inclusion of CPMS and monitoring in August 2010 Area Source Rule
 Addition of C PMS specifications without opportunity for public comment  CPMS specifications did not respond to ACC/API comments on CPMS of February 5, 2009 where applicable.  Maintenance and calibration of new data and monitoring equipment at remote area sources is diffi cult and costly.  Area source cost/benefit comment does not match actual O&G site limitations and CPMS specification. Inadequate Implementation Time for 2004 RICE MACT Systems at Major Sources and Need

for Administrative Stay of Performance Specifications and Calibration Standard Schedule Next Meeting to Discuss Other Issues Outlined in the Petition for Reconsideration 2:00 Conclude Meeting