Providing Environmental Technical Support Since 1989 

# E C 

# /

R Incorporated

1 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 Telec onference with the Environmental Defense

Fund and the U.S. Environmental Protect ion Agency to discuss the Proposed NESHAP for Existing Stationary RICE

1.0 INTRODUCTION

A teleconference between th e 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 nati onal emission standards for hazardous air pollutants (NESHAP) for existing stationary reci procating internal combustion engines (RICE). The proposed NESHAP for existing stationary RI CE was published in the Federal Register on March 5, 2009 (74 FR 9698). A previous tel econference was held between EPA and EDF on June 30, 2009, and the purpose of this meeting wa s 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 EPA2 3.0 SUMMARY OF MEETING

EDF requested this meeting with EPA to fu rther discuss their comments on the proposed rule for existing stationary RICE. In particul ar, EDF wanted to reiterate why it believes it is important to set a particulate matter (PM) sta ndard. In EDF’s opinion, establishing requirements for PM is critical to public health.

The State of California and others have show n 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 stationa ry diesel engines that are older (20 years). EDF thought this was the case and that the California rule is de signed to make older engines retire. The existing RICE NESHAP is a technol ogy-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 Ma nufacturers 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. ED F said that according to MECA, PM filters are currently being applied to olde r 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 comme nts on the proposed rule that PM is a more appropriate surrogate than carbon monoxide (C O). Additional research conducted since submitting their original comments has led EDF to c onclude 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 da ta to link the emissions of HAP to PM. EPA indicated that it would be necessary to estab lish a quantitative relationship between HAP and PM

emissions. If EPA could determine that HAP emi ssions are invariably present in the potential surrogate, which in this case would be PM em issions, 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 coul d 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 he lp provide information indicating th at 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.