EC

/R Incorporated Providing Environmental Technical Support Since 1989

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MEMORANDUM 

TO: Melanie King, EPA OAQPS/SPPD/ESG 

FROM: Tanya Parise, EC/R, Inc. 

SUBJECT: Summary of the March 22, 2010 Meeting between EPA and API to discuss the 

NESHAP for Existing Stationary SI RICE 

1.0 INTRODUCTION 

The American Petroleum Institute (API) requested this meeting with EPA to discuss the 

national emission standards for hazardous air pollutants (NESHAP) for existing stationary spark 

ignition (SI) reciprocating internal combustion engines (RICE), which are to be finalized in 

August 2010. 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). The final NESHAP for 

existing stationary compression ignition (CI) RICE was published in the Federal Register on 

March 3, 2010 (75 FR 9648). 

2.0 ATTENDEES 

Bob Wayland, EPA Matt Todd, API 

Melanie King, EPA Clint Gill, ConocoPhillips 

Michael Horowitz, EPA (by phone) Tom Monahan, ExxonMobil 

Gary McAlister, EPA (by phone) Jim McCarthy, IES (by phone) 

Tanya Parise, EC/R Inc. Jason Clark, Devon (by phone) 

Jeff Panek, IES George Deeley, Shell (by phone) 

Jeff Adams, BP 

 
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3.0 SUMMARY OF MEETING 

Introduction

API provided an agenda, which is included as Attachment A to this meeting summary. 

Material that had been previously submitted to EPA was discussed and referred to during this 

meeting, and can be located in the rulemaking docket as Document ID Numbers EPA-HQ-OAR2008-0708-0279, 0300, and 0354. 

Area Source Engines

 API inquired about EPA’s position on the treatment of existing stationary SI engines 

located at area sources, both in terms of alternatives to numerical emission limits and regarding 

the definition of urban areas. EPA has been reviewing supporting documentation for the Oil and 

Natural Gas Production rule (40 CFR part 63, subpart HH), but EPA has not begun discussing 

these issues yet. At this point, EPA is primarily focusing on emissions data. API indicated that 

it had received EPA’s request for more information on the area source issue and that it is 

working on providing a response. EPA stressed that the issues related to existing stationary SI 

engines at area sources go along with the emissions data and that it is difficult to move forward 

without emissions data. (Note: EPA is expecting to receive a significant amount of emissions 

test data for testing conducted by API and others on stationary SI engines). 

API emphasized that it is eager to resolve this issue and believe that there is a lack of 

consistency between regulations. According to API, it would be confusing to affected sources if 

EPA used a different definition of urban areas in subpart ZZZZ than what was used in subpart 

HH. Stationary SI engines affected under the subpart ZZZZ could be located at the same facility 

as units affected under subpart HH, and being classified as an urban area source under one rule 

and not the other could lead to significant compliance complexities. EPA urged API to submit 

rationale explaining why the urban areas/urban clusters (UA/UC) definition is most appropriate. 

API indicated that it would prepare such rationale and submit to EPA. Based on a rough 

estimate, API said that with respect to the distribution of major and area sources that about 90 

percent of engines are located at area sources. 

Limited Use

 API said that there was no limited use subcategory in the final NESHAP for existing 

stationary CI engines. There is a bigger difference within stationary SI engines as opposed to CI 

engines because non-emergency SI engines operate two to three times more than emergency SI 

engines, according to API. This is contrary to stationary CI engines where there is not as big a 

difference in the number of hours of operation between non-emergency and emergency engines, 

API said. EPA asked API what percentage of the population of existing stationary SI engines 

would be limited use. According to API, only a small number of stationary SI engines would be 

limited use because the majority of stationary SI engines are for normal operation. There are 

some gasoline compressors that would be limited use, API said. API would estimate that the 

total percentage of existing stationary SI engines that are for limited use purposes is in the single 

digits. 
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Above-the-Floor

 API inquired about the status of the above-the-floor analysis. EPA indicated that it is 

currently in the process of assembling cost information and reviewing what information is 

available and would be appropriate to use for the final rule. EPA has reviewed cost data 

submitted during the proposal and the additional cost analysis that API and other groups 

submitted more recently. API indicated a concern with some of the vendor costs that EPA has 

available and said that some of the costs appeared to be low. API urged EPA to ask questions if 

there are any disparities with any of the cost data that EPA is looking at. In terms of analyzing 

emissions data, there are different ways of looking at the emissions in order to incorporate 

variability, EPA said. No decisions have been made at this point and EPA will be continuing to 

review information. API asked if co-benefits of the rule will be considered, specifically those 

related to potential reductions of nitrogen oxides emissions. EPA said that it will be looking at 

the potential reductions and benefits associated with non-HAP pollutants for the final rule. 

Management Practices

 In terms of appropriate management practices for existing stationary SI engines, API 

indicated that it concurs with the recommendations submitted by Exterran (EPA-HQ-OAR-2008-

0708-0354). API encouraged EPA to coordinate the maintenance frequencies of all engines 

subject to maintenance practices, i.e., the time schedules for maintenance of CI and SI engines 

should be the same. Again, API stressed that EPA should contact API is there is information that 

EPA is reviewing that is inconsistent. API would like the opportunity to clear any discrepancies 

EPA might identify and would also like EPA feedback on the recommended management 

practices. 

 API asked if there would be an opportunity with the final rule for existing stationary SI 

engines to make changes to the rule for existing CI engines. EPA said that any significant 

changes to the final rule for existing stationary CI engines would require notice and comment. 

Startup, Shutdown, Malfunction

 There is concern among affected sources with respect to the final requirements related to 

periods of malfunction in the promulgated rule for existing stationary CI engines. API indicated 

that there are problems with certifying compliance during these periods and expressed that it 

does not agree with final requirements for periods of malfunction. According to API, there is 

concern that engines would automatically be in violation without a chance to address the 

malfunction issue. One example mentioned was on the monthly pressure drop requirement. API 

was concerned that if the pressure drop that is recorded monthly is outside the acceptable range, 

the engine would be considered to have been out of compliance for 30 days. EPA noted that it is 

likely that the approach promulgated for existing CI engines will be followed for the final rule 

for existing stationary SI engines. 

MACT Floor/Variability
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 API asked if there had been any development on how variability would be taken into 

account in establishing the maximum achievable control technology (MACT) floors. EPA 

indicated that it needs to receive all emissions data first before a MACT floor analysis can take 

place. EPA will only look at emissions variability from the 12 percent best performing engines. 

Test Methods

 API said that it has conducted comparison testing of Method 323 and EPA Method 320 

for a variety of engines, including lean burn and rich burn SI engines at different locations. 

Preliminary reports of industry’s side-by-side testing with Method 323 and EPA Method 320 

indicate that the results are favorable, API said, but that it will be several weeks before the final 

report will be available. EPA would consider including Method 323 if the final results are 

consistent with preliminary reports. 

Wrap-Up

API plans to submit various materials to EPA in the next several weeks, including 

information on area sources and the report of Method 323 and EPA Method 320 side-by-side 

testing, in addition to emissions test data. EPA reiterated the importance and urgency of API 

submitting the emissions test data as soon as possible. API committed to submitting the rich 

burn emissions test data by April 2, 2010, and the lean burn emissions test data, which will 

include 2-stroke and 4-stroke lean burn data around April 8-9, 2010. 
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Attachment A 

API Agenda 

for March 22, 2010 Meeting
Proposed Meeting Agenda

EPA – API Meeting on IC Engine NESHAP Rule Revisions

EPA Offices - RTP, NC

Date: March 22, 2010

Location: EPA Research Triangle Park

Time: 1:00 p.m. to 3:00 p.m. EDT

Call-in Number: 919-541-4486

I. Introductions

II. Treatment of Area source engines – Alternative(s) to emission limits for SI engines

III. “Above the Floor” analysis –API/INGAA Cost Effectiveness Report

IV. Management Practices

V. SSM compliance requirements

VI. MACT Floor Determination / Variability Analysis

VII. Method 323 versus Method 320 Test Status

VIII. Review of information needs, schedule, and next steps/action items

IX. Follow-on meeting or conference call