EC

/R Incorporated Providing Environmental Technical Support Since 1989

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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 Hygiene
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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.