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R Incorporated Providing Environmental Technical Support Since 1989

1 MEMORANDUM

TO: Melanie King, EPA OAQPS/SPPD/ESG
FROM: Bradley Nelson, EC/R, Inc.
DATE: January 19, 2010
SUBJECT: Summary of the November 17, 2009 Teleconference with the American Petroleum Institute and the U.S. Environmental Protection Agency to discuss API’s supplemental analyses for the Proposed NESHAP for Existing Stationary Reciprocating Ignition Internal Engines

1.0 INTRODUCTION The American Petroleum Institute (API) requested this teleconference with EPA to discuss the supplemental analyses that it sent to EPA on November 2, 2009. The analyses included cost effectiveness of control options in the proposed national emission standards for hazardous air pollutants (NESHAP), a support paper for management practices at area sources located in rural areas, and a summary of stationary compression ignition engine test data. The supplemental analyses can be found in the docket as Document ID Nos. EPA-HQ-OAR-2008- 0708-0272, 0279 and 0280. This meeting summary will be available in the docket for this rulemaking (Docket ID No. EPA-HQ-OAR-2008-0708). The proposed NESHAP for existing stationary RICE was published in the Federal Register on March 5, 2009 (74 FR 9698).

2.0 ATTENDEES U.S. Environmental Protection Agency Melanie King, OAQPS/SPPD/ESG Michael Horowitz, OGC
American Petroleum Institute Matt Todd, API Jeff Panek, IES Roger Zygmunt, Shell Jenny Yang, Marathon Tom McGrath, IES Paul Little, Air Hygiene2 Jeff Adams, BP Tom Monahan, ExxonMobil Jim McCarthy, IES Lynn Reed, ONEOK Janet Bounds, Chevron Tim Helbig, ONEOK EC/R Incorporated Bradley Nelson 3.0 SUMMARY OF MEETING API indicated that review of the emissions data used to develop the maximum achievable control technology (MACT) floor for stationary spark ignition (SI) engines found test data using invalid test methods and the wrong classification of SI engines between rich-burn and lean-burn engines. API also found the same kind of issues with the test data used to develop the MACT floor for stationary CI engines. API stated that the MACT floor for CI engines between 50 and 500 horsepower (HP) was based on data for CI engines greater than 1,000 HP. API noted that these 50 to 500 HP engines are not like the larger engines and have different emission characteristics. EPA asked why 50 to 500 HP CI engines are different than larger CI engines. API responded that these engines are designed differently to operate at variable loads, whereas larger engines are designed to operate at a steady-state load. API asked if EPA intended to subcategorize cyclic duty engines, such as air compressors or welding equipment. API does not believe that catalytic controls are effective on these engines. EPA noted that catalytic controls have been installed on mobile engines for many years. API responded that mobile engines are different than mobile engines and those mobile engines have a shorter life cycle than stationary engines. EPA responded that no final decisions have been made in terms of subcategories for CI engines. The next topic of discussion was API’s proposal to require management practices for area source SI engines less than or equal to 500 HP located in rural areas. API stated that many of these engines are located in rural areas and do not affect public health. API stated that it is generally supportive of the oil change and air filter requirements in the proposed rule; however API indicated that it would like a provision that allows an oil analysis to be done to see if the oil needs to be changed. EPA asked for more information on the oil analysis proposal. API stated that engine manufacturers or lube oil dealers can provide information on oil analysis plans. EPA responded that it needed more specifics for an oil analysis program. API stated that it would provide EPA with the information.