February 4 , 2011

Melanie King Energy Strategies Group

Sector Policies and Programs Division (D243

- 01) U.S. Environmental Protection Agency Research Triangle Park North Carolina, 27711

Re: Reciprocating IC Engine NESHAP, 40 CFR Part 63 Subpart ZZZZ

– Proposed Redlines to Continuous Parameter Monitoring Systems (CPMS) Specifications in § §63.6625(b) and (k)

Dear Melanie:

On August 20, 2010, amendments to the Reciprocating Internal Combustion Engine (RICE) NESHAP , 40 CFR Part 60, Subpart ZZZZ were published in the Federal Register. The amendments included continuous parameter monitoring system (CPMS) specifications that were not in the proposed rule. API and others petitioned EPA to reconsider a number of issues in the amended RICE NESHAP . In add ition, since these new CPMS requirements would affect RICE already subject to Subpart ZZZZ, a stay of CPMS performance requirements was requested . I n a letter dated January 19, 2011, EPA issued a stay of the requirements of § §63.6625(b) and (k) for 90 day s. On January 25, 2011, EPA met with API and othe r petitioners to discuss

issues with the CPMS requirements and potential remedies . To assist as EPA addresses issues with § §63.6625(b) and (k)

, API and other petitioners have prepared suggested redline edi ts for your consideration

.

Presented in the attachment below are suggested “redline” edits to §§63.6625(b) and (k). The recommended revisions are based on meeting discussions and subsequent petitioner gr oup discussion s

.

Recognizing the time constraint s imposed by the stay, we welcome your thoughts and comments in advance of our scheduled meeting on February 9 th . Thank you in advance for your attention to this matter.

Sincerely,

/s/ Matthew Todd

Matthew Todd

cc: Michael Horowitz, USEPA, Office of G eneral Counsel Peter T. Tsirigotis, USEPA, Office of Air Quality, Planning and Standards Robert Wayland

, USEPA, Office of Air Quality, Planning and Standards

Attachment: Recommended Revisions to Subpart ZZZZ Amended CPMS Requirements Matthew Todd

Regulatory and Scientific Affairs

1220 L Street, NW Washington, DC 20005

- 4070
USA Telephone 202

- 682

- 8319

Fax 202

- 682

- 8270
Email toddm@api.org www.api.orgAttachment:

Recomm ended Revisions to Subpart ZZZZ Amended CPMS Requirements

Recommended deletions in strikethrough and additions in bold underline :

§63.6625 What are my monitoring, installation, collection, operation, and maintenance requirements?

* * * * *

(b) If you are required to install a continuous parameter monitoring system (CPMS) as specified in Table 5 of this subpart, you must install, operate, and maintain each CPMS according to the requirements in paragraphs (b)(1) through (8) of this section. For an aff ected unit under §63.6595 complying with applicable emission limitations and operating limitations on [INSERT DATE OF FEDERAL REGISTER PUBLICATION], these requirements are effective [INSERT DATE 180 DAYS AFTER FEDERAL REGISTER PUBLICATION].

(1) The CPMS mu st complete a minimum of one cycle of operation for each successive 15

- minute period. You must have a minimum of three of the four successive cycles of operation within an hour, or 75% or more of the data if operating cycles are more frequent, to have a va lid hour of data. You

must have at least three valid hours to have a valid four

- hour rolling average. You must operate the CPMS consistent with good practices for maximizing data recovery and use all valid data collected when calculating hourly averages and 4

- hour rolling averages.

(2) Except for monitoring malfunctions, associated repairs, and required performance evaluations, and quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments) , you must conduct all monitoring in continuous operation at all times that the unit is operating. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions.

(3) For purposes of calculating data averages, you must not use data recorded during monitoring malfunctions, associated repairs, out of control periods, or required performance evaluations, or quality assurance or control activities. You must use all the data collected during all other periods in assessing compliance. Any 15

- minute period for which the monitoring system is out

- of

- control and data are not available for required c alculations constitutes a deviation from the monitoring requirements.

(4) Determine the 3 4

- hour block rolling average from hourly average data using of all recorded readings, except as provided in paragraph (b)(3) of this section.

(5) Record the results o f each inspection and performance evaluation , calibration, and validation

check

. (6) You must develop a site

- specific monitoring plan that addresses paragraphs (b)(6)(i) through (vi) of

this section.

(i) Installation of the CPMS sampling probe or other int erface at the appropriate location to obtain representative measurements;

(ii) Performance and equipment specifications for the sample interface, parametric signal analyzer, and the data collection and reduction systems;

(iii) Performance evaluation proced ures and acceptance criteria ( e.g. , procedures and acceptance criteria consistent with §63.6625(k)(3) calibrations );

(iv) Ongoing operation and maintenance procedures in accordance with the general requirements of §63.8(c)(1)

, and (c)(3) , and (c)(4)(ii) ;(v ) Ongoing data quality assurance procedures in accordance with the general requirements of

§63.8(d) except that calibration requirements do not apply and quality is assured by the performance evaluation (e.g., thermocouple may be replaced rather than calib rat ed ) ; and

(vi) Ongoing recordkeeping and reporting procedures in accordance with the general requirements of §63.10(c) for hourly and 4

- hour rolling average data
, and §63.10 (e)(1)

, and (e)(2)(i).

(7) You must conduct a performance evaluation of each CPMS in accordance with your site

- specific monitoring plan.

(8) You must operate and maintain the CPMS in continuous operation according to the site

- specific monitoring plan.

********

(k) If you are required to install a CPMS for catalyst inlet temperature as specified in Table 5 of this subpart have an operating limitation that requires the use of a temperature measurement device , you must meet the requirements in paragraphs (k)(1) through (3) (4) of this section.

(1) Locate the temperature sensor and other ne cessary equipment in a position that provides a representative temperature.

(2) Use a temperature sensor with a minimum tolerance of 2.8 degrees Celsius (5 degrees Fahrenheit), or 1.0 percent of the temperature value, whichever is larger , for a noncryogeni c temperature range

. (3) Use a temperature sensor with a minimum tolerance of 2.8 degrees Celsius (5 degrees Fahrenheit), or 2.5 percent of the temperature value, whichever is larger, for a cryogenic temperature range.

(4) Conduct a The temperature measure ment device performance evaluation specified in section (b)(7)

must be conducted calibration check at least annually and meet the minimum tolerance specified in (k)(2) every 3 months

. This evaluation could include but is not limited to : use of a redundant temperature measurement; a separate catalyst inlet temperature measurement that is compared to the temperature measurement device; or, ensuring the temperature measurement device meets the minimum tolerance specified in (k)(2) at two known temperatures (e. g., ice water, boiling water, ambient temperature).