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Summary of Meeting with ICAC 

Regarding the Proposed Stationary Existing RICE NESHAP 

March 25, 2009 

Attendees 

Jaime Pagán, EPA Carolyn Slaughter, ICAC 

Michael Horowitz, EPA Rasto Brezny, MECA 

Tanya Parise, AGTI Wilson Chu, Johnson Matthey 

Chad Whiteman, ICAC Clyde Bergemann, EEC 

David Foerter, ICAC Participants from various companies (see Attachment 1) 

 

Purpose of Meeting 

 The purpose of this meeting 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). 

Summary of Meeting

The Institute of Clean Air Companies (ICAC) requested this meeting with EPA. 

Also represented at this meeting was the Manufacturers of Emission Controls Association 

(MECA), as well as other individual control technology manufacturers and individuals 

from other companies with a stake in the proposed rule. This summary will be available 

in the docket for this rulemaking (Docket ID No. EPA-HQ-OAR-2008-0708). 

Jaime Pagán of EPA provided a presentation of the proposed rulemaking to ICAC 

and MECA. The presentation is included as Attachment 2 to these meeting minutes. The 

purpose of the presentation was to provide ICAC, MECA and other emissions control and 

monitoring equipment companies who participated an overview of the proposed rule. 

Initially, there was a 60 day comment period, but EPA will be providing an additional 30 

days for stakeholders and interested parties to submit comments to EPA on the proposal. 

The proposed rule covers existing stationary RICE of all types, but mostly 

stationary diesel engines are affected. The majority of stationary diesel engines are used 

for emergency purposes. Stationary engines in general are used in several different 

industries. 

The proposed rule targets emissions of hazardous air pollutants (HAP), but will 

also reduce emissions of other compounds such as criteria pollutants. Slide 3 of the 

presentation presents the baseline emissions for HAP and criteria pollutants for gas and 

diesel-fired stationary RICE. Slide 8 of the presentation shows the expected emission 

reductions. 

EPA has previously issued regulations that cover emissions from stationary 

engines, but is with this proposal addressing stationary engines that have not been 
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covered before. Slide 4 of the presentation shows which regulations EPA has issued in 

the past for stationary engines. 

EPA is proposing emission limits in terms of formaldehyde and carbon monoxide 

(CO). Formaldehyde is the hazardous air pollutant emitted in the largest quantity from 

stationary engines and EPA has for other rulemakings determined that CO is an 

appropriate surrogate for HAP from certain types of engines. The proposed limits are 

based on the use of oxidation catalyst and non-selective catalytic reduction although not 

all the limits are expected to require aftertreatment controls. Also, owners and operators 

subject to the rule may use any technology they want to comply with the emission 

standards. Stationary emergency engines are not exempt from the rule, but are subject to 

less stringent standards than non-emergency engines that will likely not require 

aftertreatment. Stationary engines used for demand-response programs are not 

considered emergency engines. 

EPA is interested getting at the remaining particulate matter (PM) emissions from 

stationary engines and provides a discussion on this subject in the preamble. There are 

issues associated with older engines (pre-1996 model year) where a diesel particulate 

filter retrofit may be challenging due to high engine-out PM emissions. If industry has 

information showing that devices can be successfully retrofitted on older engines, EPA 

would be interested in obtaining data and cost information. Participants on the call asked 

if EPA has considered partial filters that could reduce 50 percent of PM emissions. EPA 

responded that it has primarily looked at HAP technologies for this proposal. Members 

of industry pointed out that the filters could be catalyzed. Participants on the call also 

asked if EPA had considered selective catalytic reduction (SCR) to which EPA responded 

that SCR is primarily targeted at nitrogen oxides, which is not the focus of this 

regulation. 

Regarding the other requirements of the rule beyond emission limits, certain 

members of industry expressed that the proposed rule is missing a good maintenance 

practice requirement. EPA recognizes that proper maintenance and operation is 

important, but noted that there is tremendous variation from engine to engine based on 

make, model, size, etc. EPA feels that the proposed compliance requirements and limits 

will help achieve the reductions required, but is interested in obtaining specific 

information from industry on appropriate operation and maintenance procedures. EPA 

added that information on the feasibility and costs associated with the emission controls 

proposed would be helpful to ensure that the best available information is used for 

developing the final rule. 

 
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Attachment 1 

List of Participants 
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Attachment 2 

EPA – Energy Strategies Group Presentation to ICAC 

March 25, 2009 
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