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MEMORANDUM 

DATE: December 6, 2010

TO: Melanie King, EPA OAQPS/SPPD/ESG

FROM: Tanya Parise, EC/R, Inc.

SUBJECT: Summary of the November 19, 2010 Teleconference with the Engine 

Manufacturers Association Regarding Dresser Waukesha’s Petition for 

Reconsideration – Formaldehyde as HAP Surrogate

INTRODUCTION

The Engine Manufacturers Association (EMA) requested this teleconference with EPA to 

discuss the petition for reconsideration submitted by Dresser Waukesha on the National 

Emission Standards for Hazardous Air Pollutants (NESHAP) for stationary reciprocating internal 

combustion engines (RICE). The most recent amendments to the NESHAP for stationary RICE 

were published in the Federal Register on August 20, 2010 (75 FR 51570). 

ATTENDEES

Melanie King, EPA Brady Winkleman, Caterpillar

Bob Wayland, EPA Gordon Gerber, Caterpillar

Michael Horowitz, EPA Michael Brand, Cummins

Tanya Parise, EC/R Mike Itsell, Cummins

Tim French, EMA Lynn Palmer, Dresser Waukesha

Bob Stachowicz, Dresser Waukesha

SUMMARY OF TELECONFERENCE

Dresser Waukesha had previously submitted a petition for reconsideration on the RICE 

NESHAP (EPA-HQ-OAR-2008-0708-0583). EMA indicated that it fully supports Dresser 

Waukesha’s petition for reconsideration, which requests that EPA reconsider using 

formaldehyde as a surrogate for hazardous air pollutants (HAP). EMA requested this 

teleconference to discuss the petition and to clarify misconceptions it believes EPA has regarding 

previously submitted data that form the basis for Dresser Waukesha’s petition. 

EMA contended that formaldehyde is not a suitable surrogate for stationary rich burn 

engines. According to EMA, total hydrocarbons (THC) is a much better alternative because at a 

minimum level of THC destruction efficiency virtually all formaldehyde emissions are removed, 

plus THC emissions are less costly to measure. Further, EMA said that the use of formaldehyde 

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as a surrogate for HAP could become a deterrent for deploying stationary rich burn engines, 

given that formaldehyde is only used as a surrogate for HAP for stationary rich burn engines and 

not for lean burn engines under the current RICE NESHAP. EPA said that it does not have a 

response on this issue as of right now, but that it has shared the petition for reconsideration with 

EPA’s Measurement Policy Group and will discuss the information contained in the petition 

internally. 

EPA stated that it seemed that the information that has been provided by Dresser 

Waukesha focused on percent reduction and that the information indicated that some engines are 

expected to meet the formaldehyde limits without the use of a catalyst. EPA asked if in EMA’s 

opinion THC would also be an appropriate surrogate for formaldehyde in those cases. Members 

of EMA contended that most stationary rich burn engines in the field would not be able to meet 

the formaldehyde limits without adding aftertreatment. EMA said that there is no way to alter a 

stationary rich burn engine in order to reach the 10.3 parts per million formaldehyde limit that 

applies to smaller existing rich burn engines at major sources. The engine would need nonselective catalytic reduction (NSCR) in order to meet that level, according to EMA. EPA 

pointed out that the formaldehyde standards for existing stationary engines 500 horsepower (HP) 

or below at major sources are based on uncontrolled levels, plus the most recent rule published 

only deals with existing engines. Therefore, EPA was curious as to the timing of the petition as 

it seems to relate more to engines that are subject to standards that are expected to require 

aftertreatment, i.e., primarily new stationary engines greater than 500 HP at major sources. 

Those standards have been in place since 2004, so EPA questioned why the surrogate issue is 

being brought up now. EMA explained that Dresser Waukesha recently obtained laboratory test 

data for a rich burn engines with NSCR, which partly explains the timeframe. Also, there were 

not as many stationary rich burn engines affected before under the original 2004 regulation since 

that only covered stationary engines greater than 500 HP at major sources so it was not such a 

big issue at that time, EMA said. However, now there are many more affected engines, EMA 

added. EMA clarified that it is not solely focusing on the most recent additions to 40 CFR part 

63, subpart ZZZZ, but is asking for relief for all stationary rich burn engines covered under the

subpart. 

EPA said that the information submitted by Dresser Waukesha primarily presented 

destruction efficiency data for THC and formaldehyde. However, based on recent court cases, 

EPA emphasized that it is important that the focus is on emissions. EMA said that THC could 

also be used as a surrogate for formaldehyde for engine-out emissions and available data indicate 

proportionality of THC and formaldehyde. EPA indicated that it would need substantial 

evidence to show that such proportionate surrogacy exists universally. EMA responded that it 

felt that it had already submitted sufficient information to that point with data and references to 

other publications. EMA contended that the percent reduction data is better than proportional 

because of virtual total destruction of formaldehyde and argued that because THC emissions are 

not consistent should not be a reason to reject THC as a surrogate. 
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EMA stated that it would submit to EPA the information that highlights the pre-catalyst 

data for uncontrolled engines. In EMA’s opinion, that dataset would suffice in establishing the 

proportional relationship between engine-out THC and formaldehyde emissions. Secondly, 

EMA cited a paper that demonstrated the proportional relationship between THC and 

formaldehyde for five engine families. EMA indicated that it would send the paper to EPA to 

determine if the information presented would be sufficient to demonstrate universal applicability

of THC as a surrogate for formaldehyde.