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 addition, since these 

new CPMS requirements would affect RICE already subject to Subpart ZZZZ, a stay of CPMS performance 

requirements was requested. In a letter dated January 19, 2011, EPA issued a stay of the requirements of 

§§63.6625(b) and (k) for 90 days. On January 25, 2011, EPA met with API and other 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 edits 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 group discussions.

Recognizing the time constraints imposed by the stay, we welcome your thoughts and comments in advance 

of our scheduled meeting on February 9th. Thank you in advance for your attention to this matter.

Sincerely,

/s/ Matthew Todd

Matthew Todd

cc: Michael Horowitz, USEPA, Office of General 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.org
Attachment:

Recommended 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 affected 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 must 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 valid 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 calculations 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 of 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 interface 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 procedures 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 calibrated); 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 necessary 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 noncryogenic 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 measurement 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).