November 2 , 2009

Melanie King Energy Strategies Group Sector Policies and Programs Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency

Mail Code D243

- 01 RTP, NC 27711

Re: Submittal of Additional Data for the Amendments to the RICE NESHAPs, Part 63, Subpart ZZZZ

Dear Ms. Melanie King,

The American Petroleum Institute ( API ) is a national trade association with nearly 400 member companies that are involved with all aspects of the oil and natural gas industry. We are pleased to submit additional information for your consideration for the above referenced proposed rulemaking in the form of the following three documents:

Support for Use of Management Practices in the National Emission Standards for

Hazardous Air Pollutants Standards for Reciprocating Internal Combustion Engines at

Area Sources in Rural Locations Reciprocating Internal Combustion Engine National Emission Standard for Hazardous Air Pollutants (RICE NESHAP) Proposed Revisions

– Emission Control Cost Analysis Background for “Above the Floor” Emission Controls for Natural Gas

- Fired RICE 50 to 500 HP Diesel Engines (CI RICE) Analysis

API would like to make the following points that are not included in the above documents.

1. Due to shortness of time

, A PI is unable to prepare cost effectiveness tables for diesel engines for either the Above the Floor or Rural Area Source documents. However, we believe the cost

- effectiveness for catalyst on diesel engines is likely to be comparable to Matthew Todd

1220 L St reet, NW Washington, DC 20005

USA

Telephone 202

- 682

- 8319
Email toddm@api.org www.api.orgthe general results in our attached report for gas

- fired engines. A few points on how cost

effectiveness relates to diesel engines are :

a. A large portion of the diesel engines in the oil & gas sector are located in Alaska. Due to their remoteness, costly catalyst add

- on contr ols can be significantly higher and warrant management practices. API supplied co st data for diesel engines with in prior comm ents submitted to the docket.

b. Like SI engines, a management practice alternative is also warranted for diesel engines located at a rea sources in rural locations.

c. Generally, diesel engines only operate a few weeks or months per year. This is comparable to the 1000 hr/year estimate that EPA assumed in docket document

#EPA

- HQ

- OAR

- 2008

- 0708

- 0017. However, API’s cost effectiveness resu lts are at least a factor of four, and typically a factor of ten or more, higher than the referenced proposed rule cost estimates. If API’s cost effectiveness values are used as a comparison, then adjustment from the 2,800 or 6,500 hr/year for SI to
1,000 hr/year for CI would be needed, which would make the cost per ton of reduction even higher.

d. For emergency and limited use diesel engines , the cost per ton of formaldehyde

reduce d would be much higher since these engines operate less than 100 h our s per

ye ar

. 2. EPA's above the floor emission limits included both a percent reduction threshold and an

emission threshold. Either of these values can be used to prove compliance. For the emission limit, EPA started the calculation from the MACT floor value. Durin g additional discussions with EPA, API mentioned that the above the floor emission limit should not have been calculated by reducin g the MACT floor emission limit by the percent reduction required across the catalyst. Instead, API suggested that the above the floor emission limit should start from a reasonably high emission value for existing engines exhaust pre

- catalyst. This emission level would allow engine operators with well designed and maintained engines to get longer life out of the catalyst, whi le allowing operators with older engines to maintain compliance via catalyst maintenance.

3. The above the floor economic analysis assumes that all engines can comply with the rule by simply adding a catalyst. However, industry does not have any experience with installing catalyst on many makes and sizes of engines. For example, many older and small engines use magneto style timing equipment. These engines may need to be retrofitted with new electronic ignitions systems to stabilize the combustion operatio ns sufficiently for the AFR controller and catalyst systems to function reliably. Overhauls may need to be completed more often to reduce oil consumption that will f oul the catalyst and require more frequent cleaning and replacement of the catalyst. Requ irements of this type are currently unknown for many existing engine types and most small engines. Thus, the economic analysis included in this paper has potential to be significantly under

estimated.

4. Even with a recently developed “premium catalyst”, t he catalyst manufacture can only guarantee an emission reduction of 73% (reference letter from Bruce Chrisman of Cameron to Melanie King) for the 2SLB RICE that has been tested. EPA should reduce the catalyst reduction efficiency for 2SLB RICE to 73% at m ost. Even if this recommendation is adopted, many 2SLB engines may still require significant additional expense to achieve compliance as discussed in item #3 above.We appreciat e the opportunity to submit this supplemental information and would welcome a

conference call to discuss further

.

Sincerely,

Matthew Todd

Cc Bob Wayland, EP A