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Summary of Meeting with API

Regarding the Final NSPS for CI Stationary RICE

February 12, 2007

Attendees

Jaime Pagán, EPA Stephanie Meadows, API

Robert Wayland, EPA Jeff Adams, BP

Michael Horowitz, EPA OGC John Wagner, API

Greg Fried, EPA (by phone) Russ Frye, FryeLaw

Bradley Nelson, AGTI Jeff Panick – IES (by phone)

Jenny Yang (by phone) Janet Bounds (by phone)

Purpose of Meeting

The purpose of this meeting with the American Petroleum Institute (API) was to discuss 

the main issues regarding the final new source performance standards (NSPS) for stationary

compression ignition (CI) engines.

Summary of Meeting

Michael Horowitz began the meeting by providing EPA’s preliminary responses to the 

six main issues from the comments submitted by API on the final NSPS for stationary CI

engines. The six main issue topics are:

 Manufacturer O&M requirements, 

 Temporary replacement engines, 

 Emission standards and testing requirements, 

 Useful life term, 

 NSPS exemptions, and 

 Best demonstrated technology. 

A summary of the issues and discussions are provided in the following sections.

Manufacturer O&M Requirements

The API would like to remove the manufacturer operation and maintenance (O&M)

requirements, and allow owners/operators to use their own O&M plan. Michael stated that EPA 

has proposed adding an option that will allow owners/operators to maintain their engines using 

maintenance procedures that prevents engine deterioration and increased emissions. In addition 

engines greater than 200 horsepower (HP) would have to meet the testing requirements for 

uncertified engines. Jeff Adams stated that British Petroleum (BP) already conducts engine 

integrity tests and could be used as a surrogate for emissions testing. The integrity tests provide 

predictive emissions. EPA asked for a list of the maintenance protocols and Jeff Adams said he 

would check with the maintenance group and will provide examples. Michael indicated that 
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EPA prefers emission testing rather than surrogate monitoring.

Temporary Replacement Engines

Michael stated that engines that are located at one place for 1 year are considered 

stationary. Jeff Adams asked for clarification in the rule regarding engines left on-site 

seasonally. Michael said that language could be added to the preamble to address seasonal 

engines on-site. Janet Bounds asked for clarification with temporary generators or pumps in 

Alaska. Michael restated that engines that are located at a facility for 1 year will be considered 

stationary. EPA cannot provide regulatory language to cover every scenario. Robert Wayland 

stated that EPA could add text to the preamble to clarify which engines are included in the 

definition of mobile engines, which may help clarify some of these issues. Michael added that 

replacement engines will not be required to meet NSPS requirements as long as mobile source 

requirements are met.

Emission Standards and Testing Requirements

Michael stated that 40 CFR section 60.4212 could be used for the in-use emission testing 

requirements for stationary CI engines. Jeff Adams raised concerns with differences between 

certification bench testing, and in-use portable analyzers results. Michael stated that EPA has 

done extensive testing with portable analyzers and that the data are comparable. EPA can 

provide the data to API if they request it. Jeff Panick asked if changes can be made to the engine 

and retest. Michael stated that if the engine fails, the owner/operator is obligated to get the 

engine in compliance.

Useful Life

EPA stated that it does not have any issues with the useful life term and will continue to 

discuss this issue with API and the engine manufacturers. No decisions or changes have been 

made to the regulations regarding this term.

NSPS Requirements

EPA wants to regulate all stationary engines; however EPA will exempt smaller engines 

from the NSPS requirements as long as those engines are meeting mobile engine standards. No 

size cutoff has been selected, but it would be in the 50 to 100 HP size range. EPA also stated 

that it is comfortable with the definition of emergency engines. Jeff Adams told the group that 

the requirements for engines covered by both the NESHAP and NSPS rules is confusing and 

requires clarification. 

Best Demonstrated Technology

EPA believes that the final emission standards are appropriate and achievable. The use 

of particulate matter traps and selective catalytic reduction are well demonstrated to meet the 

emission reductions for stationary engines.
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Other Issues

Michael told the group that the settlement agreement requirements could be met through 

changes to the preamble. Jeff Adams asked if uncertified engines would have to meet O&M 

requirements. Michael stated that the O&M requirements would be removed for uncertified 

engines. Jeff Adams noted that there was a 9-month period between when the rule becomes 

effective and when certified engines are available. EPA acknowledged that this true, but cannot 

provide any alternatives.

Action Items

 Jeff Adams will provide EPA with engine integrity data used in the maintenance that 

show emission compliance for stationary engines.

 EPA will provide portable emissions data studies by request.