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MEMORANDUM DATE: February 11 , 2011 TO: Melanie King, EPA OAQPS/SPPD/ESG FROM: Tany a Parise , EC/R, Inc. SUBJECT: Summary

of the January 26, 2011 Meeting with APIRegarding CPMS Requirements in the RI CE NESHAP

INTRODUCTION The American Petroleum I nstitute (API) requested this meeting to follow

- up on earlier meetings with EPA. Summaries of the two previous meetings between EPA and API on this issue are available in the docket (EPA

- HQ
- OAR
- 2008
- 0708
- 0693 and 0696 ). APIwanted to discuss the specific issues it has with the continuous parameter monitoring sy stem (CPMS) requirements in the National Emission Standards for Hazardous Air Pollutants (NESHAP) for stationary reciprocating internal combustion engines (RI CE). T he most recent amendments to the NESHAP for stationary RICE were pub lished in the Federal Register on August 20, 2010 (75 FR 51570 ). ATTENDEES Melanie King, EPA Jeff Adams, BP Michael Horowitz, EPA (by phone) Jeff Panek, IES Peter Westlin, EPA James Harrison, Exterran Barrett Parker, EPA Rebecca Rentz, Bracewell & Giuliani (by phone) Jason Dewees, EPA Tom Monahan, ExxonMobil (by phone) Colin Boswell , EPA John Wagner, API (b y phone) Tany a Parise, EC/R Clay Freeberg, Chevron (by

phone) Matt Todd, API Jenny Yang, Marathon (by

phone) John Admire, DCP Midstream Bill Wehrum, Hunton & Williams (by phone) Rex War, DCP Midstream Jim McCarthy , IES (b y phone) 

# E C 

# / R Incorporated Providing Environmental Technical Support Since 19892

S UMMARY OF MEETING APIexpressed that it wished to have a comprehensive discussion with EPA to explore in detail possible solutions to the issues related to the CPMS requirements. APIprovided a rough agenda for the meeting consisting of the following , which is loosel y followed in this meeting summary :

 Introduction and Purpose  Major Source CPMS Performance Specifications o Temperature Monitoring o Data Availabilit y, Validity and Averaging  Area Source Monitoring and Compliance Assurance Concerns o Unmanned rural area source technical challenges and issues o Alternatives to continuous monitoring at area sources APIreiterated tha t it has raised significant issues in earlier meetings related to the CPMS requirements in the rule and it is particularly urgent to resolve these issues as they relate to major sources. API’s request for an administrative stay on the CPMS requirements wa s granted; however, the stay

will run out shortly

and API indicated it is primarily focusing on try ing to resolve the CPMS issues in time for major sources to comply with the rule. Temperature Monitoring Language currently

in the rule requires that so urces conduct a temperature calibration check at least every

90 day s, and API indicated that there is a lot of uncertainty about that requirement. API expressed that the thermocouple either works or not, and although over time it might fail, it is more im portant, in API’s opinion, to verify the performance of temperature measurement equipment as opposed to calibrating the thermocouple. EPA said that redundant thermocouples could be used for the calibration and further said that it seems like it would be a ppropriate to allow the owner/operator the discretion to determine what temperature calibration means to use. API noted that the language in the rule might have been clearer if the requirement stated that sources needed to “verify performance.” Further, API said that if sources have the flexibility in their monitoring plans to define how to verify devices this might be something that would be appropriate in covering a variet y of different scenarios. API also expressed that the requirement to conduct perf ormance checks quarterly is excessive because temperature measurement technology is stable. APIadded that the personnel needed to conduct performance checks would be different than the normal staff/operator and would necessitate a technical expert. E PA asked what API proposed as an alternative period. API responded that though the temperature might drift, it is generall y stable and therefore proposed a ye ar, reiterating again that quarterl y/ every

3 months is too much in API ’s opinion.3

Data Availabilit y APIargued that the 100 percent data capture requirement is too high and is higher than what is required in other rules. EPA noted that some situations are excluded from data capture. For instance, data during malfunctions, calibrations che cks, and repairs are not required to be collected. Therefore, since these are exceptions, it is not a 100 percent data capture, EPA said. The goal is to keep the monitoring s ys tem operating at all times when the equipment is running, EPA emphasized. API added that it may have periods without data for a number of reasons, e.g., loss of power, and may

have deviations bey ond its control that it might not be able to document. In other words, there may be situations where data is missing, but the cause for t he data gap may remain unknown. API was concerned that missed 15

- minute periods could lead to Title V permit deviations and asked EPA to allow compliance to be demonstrated without having all periods. EPA asked what API recommended for an alternative. I n response, API proposed that perhaps two 15
- minute periods would be an appropriate data capture amount to represent 1 hour. API further recommended that EPA look at the 4

- hour rolling period onl y and consider allowing a certain number of data gaps. Spec ificall y, API suggested that a valid 4

- hour average consist of 3 hours worth of data or that a valid 1

- hour period consist of 30 minutes of data. Area Sources APIasked for more flexibility in demonstrating cataly st activity for area sources under the rule and recommended an assurance method to indicate that the cataly st is working in conjunction with carbon monoxide (CO) portable measurements. API indicated that it believes such methods would provide a good indication of catal ys t performance. EPA as ked what API specificall y recommended and API suggested a work practice standard or a limit with a work practice standard for compliance purposes. APIexpressed that it would like to move away from reference method stack testing (Method 320/FTIR) since th ere is no portable option to measure formaldeh yde. EPA noted that the Engine Manufacturers Association (EMA) has asked EPA to consider using total hy drocarbons (THC) as an indicator of catal ys t performance or having THC as a limit . APIindicated that it has reviewed the information from the EMA, but said that the information from EMA focused on THC because, according to API, EMA did not believe that EPA was open to the idea of allowing the use of CO. I n fact, according to API , CO is more indicative of ca taly st activity and how well formaldehy de is being reduced than THC. Further, APIadded that portable analy zers do not measure THC, it is more problematic to measure THC emissions, and methane dominates the THC measurement in engines burning natural gas. API clarified that it was not suggesting that CO be used as a surrogate; only as a pollutant that would show catal ys t activit y after which the source would follow

- up with a performance test or replacement of the catal yst. EPA asked about the frequency of performance testing, specificall y what APIthought of quarterl y and semi

- annual tests. API responded that it would prefer annual testing, but was okay with semi

- annual testing as well, adding that coordinating the timing of performance testing becomes important with a quarterly test schedule. APIexpressed concerns with the pressure checks, which are required to be performed monthly , because during these checks, operators also have to conduct a load determination,4

which is especiall y problematic at a rea sources. APImade the point that if a CO test is being done, that would essentially do the same thing as what the pressure drop is intended to do, i.e., indicate catal ys t activity

. As it relates to area sources, API reiterated from previous meetin gs with EPA that there are problems with the CPMS requirements because of communication issues, end

- of

- line power issues, and so on. The meeting closed with API indicating that it would provide specific material to EPA in short order with recommendation s on CPMS language that API believes would be appropriate.