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R Incorporated

1 MEMORANDUM

TO: Melanie King, EPA OAQPS/SPPD/ESG

FROM: Bradley Nelson, EC/R, Inc.

DATE: September 21, 2009

SUBJECT: Summary of the September 15, 2009 Meeting with the Operators of Landfill Gas Engines and the U.S. Environmental Prot ection Agency to discuss the Proposed NESHAP for Existing Stationary Recipr ocating Internal Combustion Engines

1.0 INTRODUCTION

Several companies that operate landfill gas (LFG) engines requested this meeting with EPA to discuss issues with the proposed nationa l emission standards for hazardous air pollutants (NESHAP) for existing stationary reciprocating internal com bustion engines (RICE). This meeting summary will be available in the docke t for this rulemaking (Docket ID No. EPA-HQOAR-2008-0708). The proposed NESHAP for existi ng 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 (by phone) Swarupa Ganguli, Landfill Methane Outreach Program (by phone) Victoria Ludwig, Landfill Methan e Outreach Program (by phone)

Landfill Gas Engine Operators

Mike LaFramboise, Landfill Energy Systems Bill Deckert, Energy Developments Inc. Mike Dae, Energy Developments Inc. Steve King, PNGC Power Dennis Plaster, Innovative Energy Systems Pete Zeliff, Innovative Energy Systems Ben Benson, Energyneering William Song, Energyneering2 Billy Malone

EC/R Incorporated (EPA Contractor)

Bradley Nelson

3.0 SUMMARY OF MEETING

Industry representatives opened the meeting by stating that they represent a small segment of the landfill gas-to-ene rgy operators in the U.S. I ndustry had requested the meeting with EPA to help understand how decisions rega rding landfill gas engines were made for the proposed rule. EPA responded that the RICE NESHAP was promulgated in 2004 for engines greater than 500 horsepower (HP) lo cated at major sources. In th at rule, EPA determined that the maximum achievable control technology (MAC T) floor for landfill gas engines was no

control. EPA noted that the landf ill gas engines were not exempt in that rule, but that there were no emissions requirements. EPA stated that in March 2007, the courts ruled that “no control”

MACT floors are not emission stan dards, and required EPA to es tablish emission requirements for major sources. The ruling is commonly refe rred to by EPA as the Brick MACT ruling. Therefore, for this proposed rule, EPA was requi red to establish emission requirements for the landfill gas engines less than 500 HP located at major sources. EPA asked industry if landfill gas engines are mainly located at areas sources or major sources. Industry responded that it varies and that the determining factor is the size of the landfill.

Industry representatives stated that the proposed carbon monoxide (CO) emission limit (177 parts per million (ppm)) for landfill gas engines is not achievable and that a CO emission

standard similar to the spark ignition NSPS of 610 ppm of CO would be more appropriate. EPA stated that the approach and criteria used to develop emission standards under the NSPS program are different than those used for developing emission standards under the NESHAP program.

EPA stated that it relied on the test data from the emission database for determining the top 12 percent for setting the MACT standard. I ndustry responded that it cannot use control technologies to reduce CO and indicated that there are no landfill ga s engines capable of achieving 177 ppm CO. Industry fu rther stated that the only op tion would be to shut down the engines, which would cause a problem with many facilities due to long term power agreements. Industry noted that Caterpillar and Jenbacher on ly guarantee emissions fo r the first 100 hours of operation for landfill gas engines. Industry al so referred to a study done by the Bay Area Air Quality Management District 1 , which determined based on sour ce test results and operator experience that it is impractical to exp ect reductions in both nitrogen oxides (NO X ) and CO emission levels simultaneously, without the use of downstream controls. Therefore, if engines

are turned to achieve low CO emissions, the emissions of NO X increase beyond NO X permit limits, according to industry.

1 Revisiting BACT for Lean Burn Landfill Gas Fired Internal Combustion Engines, Bay Area Air Quality Management District, February 26, 2009. http://hank.baaqmd.gov/pmt/b actworkbook/white_paperlb_lfg_ice_bact_2-26-09_final.pdf3 Industry asked EPA if only 12 percent of the landfill gas engine can achieve the proposed 177 ppm CO limit, how are the othe r 88 percent of landfill gas engine s expected to comply with this standard. EPA responded that it is required by Congress to establish the standards based on the requirements in the Clean Air Act. EPA ca n, however, consider variab ility when setting the

emission standards. EPA also stated that it co uld consider management practice standards for engines greater than 500 HP at area sources. For engines le ss than 500 HP located at area sources, EPA required management practices in the proposed rule. The already promulgated 2004 NESHAP has no emission requirements for la ndfill gas engines greater than 500 HP located at major sources. However, EPA noted that the promulgated RICE NESHAP will be

reviewed in 2012. EPA recommende d that industry provide new test data to show the current emissions from landfill gas engines. EPA al so asked industry to provide information on management practice standards for landfill gas en gines. EPA stated that the management practice standards must measurable and enforceable.

EPA stated that it would need the manageme nt practice information and test data by the end of September to be able to include the inform ation in the final rule, which is scheduled to be signed on February 10, 2010. EPA also stated th at it would look at the variability of CO emissions from the landfill gas engines. Industry stated that most engines are overhauled before the compliance tests, and that the reported emis sions should be considered as the best case

scenario.