1 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 Fr i e d, EPA (b y pho ne) Russ Fry e, Fry eLaw Bradley Nelson, AGTI Jeff Panick

– IES (by phone) Jenny Yang (b y 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 regar ding the final new source performance standards (NSPS ) for stationary compression ignition ( CI ) engines. Summary of Meeting Michael Horowitz began the meeting b y providing EPA’s preliminary responses to the six main issues from the comments submitted by APIon the final NSPS for stationary CI engines . The six mai n issue topics are:

 M anufacturer O&M requirements,  T emporary

replacement engines,  E mission standards and testing requirements,  U seful life term,  NSPS exemptions, and  B est 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 owner s /operators to use their own O&M plan. Michael stated that EPA has proposed adding an option that will allow owner s /operators to maintain their engines using maintenance procedures that prevents engine deterioration and increased em issions. In addition engines greater than 200 h orsepower ( HP ) would have to meet the testing requirements for uncertified engines. Jeff Adams stated that British Petroleum ( BP ) alread y conducts engine integrit y tests and could be used as a surrogate for emissions testing. The integrit y tests provide predictive emissions. EPA asked for a list of the m aintenance protocols and Jeff Adams said he would check with the maintenance group and will provide examples. Michael indicated that2

EPA prefers emission testing rather than surrogate monitoring. Temporary Replacement Engines Michael stated that engines that are located at one place for 1 y ear are considered stationary . Jeff Adams asked for clarification in the rule regarding engines left on

- site seasonall y. 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 y ear will be considered stationary . EPA cannot pro vide 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 rep lacement 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 requireme nts 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 anal yz ers and that the data are compar able. 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 do es not have an y issues with the useful life term and will continue to discuss this issue with APIand 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 s tated that it is comfortable with the definition of emergency engines. Jeff Adams told the group that the requirements for engines covered b y both the NESHAP and NSPS rules is confusing and requires clarification. Best Demonstrated Technology EPA beli eves that the final emission standards are appropriate and achievable. The use of particulate matter traps and selective catal yt ic reduction are well demonstrated to meet the emission reductions for stationary engines.3

Other Issues Michael told the gro up that the s ettlement a greement requirements could be met through c hanges to the preamble. Jeff Adams asked if uncertifi ed engines would have to meet O& M requireme nts. Michael stated that the O& M requirements would be removed f or uncertified engines. J eff 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 an y alternatives. Action Items

 Jeff Adams will provide EPA with engine integrity data used in the maintenance that show emission compliance for stationary engines.  E PA will provide portable emissions data studies by request.