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MEMORANDUM DATE: December 6 , 2010 TO: Melanie King, EPA OAQPS/SPPD/ESG FROM: Tany a Parise , EC/R, Inc. SUBJECT: Summary

of the November 19 , 2010 Teleconference with the Engine Manufacturers Association Regarding Dresser Waukesha’s Petition for Reconsideration

– Formaldehy de 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) . T he 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 Brad y Winkleman, Caterpillar Bob Wayland, EPA Gordon Gerber, Caterpillar Michael Horowitz, EPA Michael Brand, Cummins Tany a Parise, EC/R Mike Itsell , Cummins Tim French, EMA Lyn n Palmer, Dresser Waukesha Bob Stachowicz, Dresser Waukesha S UMMARY OF TELECONFERENCE Dresser Waukesha had previously submitted a petition for reconsideration on the RI CE NESHAP (EPA

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. EMA indicated that it fully supports Dresser Waukesha’s petition for reconsideration, which requests that EPA reconsider using formaldeh yde 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 contend ed that formaldehy de is not a suitable surrogate for stationary rich burn engines. According to EMA, total hy drocarbons (THC) is a much better alternative because at a minimum level of THC destruction efficiency virtually all formaldehy de 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 f

ormaldehyde is only

used as a surrogate for HAP for stationary rich burn engines and not for lean burn engines under the current RI CE 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 stat ed 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 catal ys t. EPA asked if in EMA’s opinion THC would also be an appropriate surrogate for formaldehy de in those cases. Members of EMA contended that most stationary rich burn engines in the field would not be able to meet the formaldeh yd e 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 formaldehyd e limit that applies to smaller existing rich burn engines at major sources. The engine would need non selective catal yt ic reduction (NSCR) in order to meet that level, according to EMA. EPA pointed out that the formaldeh yde standards for existing statio nary 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 en gines 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 f or 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 origin al 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 man y more affected engines , EMA added

. EMA clarified that it is not solely f ocusing 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 formaldehy de for engine

- out emissions and availabl e 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 alread y submitted sufficient information t o 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.3

EMA stated that it would submit to EPA the information that highlights the pre

- catal ys t data for uncontrolled engines. InEMA’s opinion, that dataset would suffice in establishing the proportional relationshi p between engine

- out THC and formaldeh yd e emissions. Secondly , EMA cited a paper that demonstrated the proportional relationship between THC and formaldeh yde 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 formaldeh yd e.