1 Summary of Meeting with ICAC Regarding the Proposed Statio nary 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 di scuss the proposed national emission standards for hazardous air po llutants (NESHAP) for existing stationary reciprocating internal combustion engines (RICE). The proposed NESHAP for existing stationary RICE was published in the Federal Re gister 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 Ma nufacturers of Emission Controls Association (MECA), as well as other individual contro l technology manufactur ers and individuals from other companies with a stake in the pr oposed 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 presenta tion of the proposed rulemaking to ICAC and MECA. The presentation is included as A ttachment 2 to these meeting minutes. The purpose of the presentation was to provide IC AC, MECA and other emissions control and monitoring equipment companies who particip ated 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 ma jority of stationary di esel 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 been2 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 pollu tant 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-emergenc y engines that will likely not require aftertreatment. Stationary engines us ed for demand-response programs are not considered emergency engines.

EPA is interested getting at the remaining particulate matter (PM) emissions from stationary engines and provide s 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 su ccessfully retrofitted on older engines, EPA

would be interested in obtaini ng 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 th e filters could be catalyzed. Participants on the call also

asked if EPA had considered selective catal ytic reduction (SCR) to which EPA responded that SCR is primarily targeted at nitroge n 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 th at 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 th e proposed compliance requirements and limits will help achieve the reductions required, but is interested in obtaining specific information from industry on appropriate op eration and maintenance procedures. EPA added that information on the feasibility and costs associated with the emission controls proposed would be helpful to ensure that th e best available information is used for developing the final rule.3 Attachment 1 List of Participants45 Attachment 2 EPA – Energy Strategies Group Presentation to ICAC March 25, 20096