E Providing Environmental Technical Support Since 1989 C

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MEMORANDUM 

TO: Melanie King, EPA OAQPS/SPPD/ESG 

FROM: Tanya Parise, EC/R, Inc. 

DATE: September 8, 2009 

SUBJECT: Summary of the August 27, 2009 Teleconference with the Environmental Defense 

Fund and the U.S. Environmental Protection Agency to discuss the Proposed 

NESHAP for Existing Stationary RICE 

1.0 INTRODUCTION 

A teleconference between the Environmental Defense Fund (EDF) and the U.S. 

Environmental Protection Agency was held on August 27, 2009. The purpose of this 

teleconference was to discuss the proposed national emission standards for hazardous air 

pollutants (NESHAP) for existing stationary reciprocating internal combustion engines (RICE). 

The proposed NESHAP for existing stationary RICE was published in the Federal Register on 

March 5, 2009 (74 FR 9698). A previous teleconference was held between EPA and EDF on 

June 30, 2009, and the purpose of this meeting was to follow-up on issues discussed in June. 

This meeting summary will be available in the docket for this rulemaking (Docket ID No. EPAHQ-OAR-2008-0708). 

2.0 ATTENDEES 

U.S. Environmental Protection Agency

Bob Wayland, OAQPS/SPPD/ESG 

Melanie King, OAQPS/SPPD/ESG 

Michael Horowitz, OGC 

Environmental Defense Fund

Hilary Sinnamon, Consultant to EDF 

Elizabeth Paranhos, Consultant to EDF 

Alpha-Gamma, Technologies Inc. (subcontractor to EC/R, Inc.)

Tanya Parise, Consultant to EPA 
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3.0 SUMMARY OF MEETING 

EDF requested this meeting with EPA to further discuss their comments on the proposed 

rule for existing stationary RICE. In particular, EDF wanted to reiterate why it believes it is 

important to set a particulate matter (PM) standard. In EDF’s opinion, establishing requirements 

for PM is critical to public health. 

The State of California and others have shown that technologies are available to reduce 

PM emissions from stationary diesel engines, according to EDF. EPA asked if California is 

attempting to apply PM filters on existing stationary diesel engines that are older (20 years). 

EDF thought this was the case and that the California rule is designed to make older engines 

retire. The existing RICE NESHAP is a technology-based standard and EPA has concerns about 

the technical feasibility of applying catalyzed PM filters to existing diesel engines. EDF said 

that it recently had a conversation with the Manufacturers of Emission Controls Association 

(MECA), who indicated that that PM filters can be applied to older engines, but that there is an 

increased cost in retrofitting the engines. EDF said that according to MECA, PM filters are 

currently being applied to older engines dating back to the pre-1990s. EDF recommended that 

EPA talk directly to MECA regarding this issue. 

EDF had stated in its original written comments on the proposed rule that PM is a more 

appropriate surrogate than carbon monoxide (CO). Additional research conducted since 

submitting their original comments has led EDF to conclude that CO is an appropriate surrogate 

for gaseous toxics. However, EDF also urged EPA to consider PM as an additional surrogate. 

EPA noted that it does not have speciated PM data to link the emissions of HAP to PM. EPA 

indicated that it would be necessary to establish a quantitative relationship between HAP and PM 

emissions. If EPA could determine that HAP emissions are invariably present in the potential 

surrogate, which in this case would be PM emissions, EPA could consider using PM as a 

surrogate for HAP and establish a PM standard. EDF asked if EPA could base a relationship on 

scientific studies. EPA responded that it could likely use a scientific study to establish a 

relationship, but that for floor-setting purposes, EPA would need emissions data from existing 

sources. EDF said that it could help provide information indicating that HAP is in PM and that it 

would check with the State of California in order to obtain some supporting information for 

EPA. EPA told EDF that mid to the end of October would be acceptable for submitting 

additional information, but that the sooner EDF can send information the better, especially if 

EDF plans to submit test data.