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MEMORANDUM DATE: March 21 , 2011 TO: Melanie King, EPA OAQPS/SPPD/ESG FROM: Tany a Parise , EC/R, Inc. SUBJECT: Summary

of the March 8 , 2011 Teleconference with API Regarding Issues Related to the SINSPS

INTRODUCTION A teleconference was held between EPA and the American Petroleum Institute (API) to discuss issues related to the new source performance standards (NSPS) for stationary spark ignition (SI) engines, 40 CFR part 60, subpart JJJJ. EPA proposed minor ame ndments 40 CFR part 60, subpart JJJJ along with amendments to 40 CFR part 60, subpart IIII on Ju ne 8, 2010 (75 FR 32612). ATTENDEES Michael Horowitz, EPA Matt Todd, API Melanie King, EPA Jeff Adams, BP Tany a Parise, EC/R Jeff Panek, IES Tom M ona han, E xxonMobil S UMMARY OF TELECONFERENCE On March 10, 2010, API submitted a letter to EPA containing a list of issues related to the SINSPS 1 and on December 21, 2010, EPA provided a response to APIon these issues. 2 In addition, EPA provided a follow

- up response to API on one additional issue on March 3, 2011. 3 APIasked what the statu s was of EPA’s consideration of the Engine Manufacturers Association’s (EMA) recommendation on the proposed definition of “installed.” EMA’s specific recommendation was provided in EMA’s comments on the proposed amendments (see pages 20

- 21 of EPA

- HQ
- OAR
- 2010
- 0295
- 0037). EPA indicated that it is still contemplating the

1 Letter from Stephanie R. Meadow s, Senior Policy Advisor, API , to Michael Horow itz, Office of General Counsel, U.S. EPA . March 10, 2010. 2 Letter from Peter Tsirigotis, Director, Sector Policies and Programs Division, EPA to Matt Todd, API. Response to March 10, 2010 Letter. December 21, 2010. 3 Em ail from Melanie King, EPA to Matt Todd, API. API Comment 1.6 on June 2010 Engine NSPS Amendments. March 3, 2 011. 

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recommendations received on the proposed definition, but noted that it does not see a reason wh y EMA’s suggestions would not be included in the final rule. API indicated that it co ncurs with EMA’s recommendation on the definition of “installed.” APIasked what other changes EPA is considering making to the SI NSPS. EPA indicated that it will address the ty pographical errors in the mathematical sy mbols and other minor mistakes . EPA said that it is not making any substantive changes to the SINSPS at this time because an y substantive changes to the rule would require noti ce and comment. APIrequested that EPA consider making changes to the flowrate issue that is described on pages 8 and 9 of EPA’s December 21, 2010 response letter. API indicated that a flowrate measurement is not necessary when comply ing with a concen tration

- based standard and subsequently

asked EPA to revise Table 2 in the SI NSPS to clarify that such measurement is not needed. EPA noted API’s concern regarding flowrate measurements and indicated it would discuss this issue internally
. According to API, there is significant confusion surrounding the initial notification requirements , and asked if there was any thing that EPA could do at this point, perhaps in the form of clarify ing preamble language in the final rule
. Supposedly , there are double, t riple and even quadruple notifications being submitted for the same engine, API said. Regarding requirements related to load specifications, which are discussed in EPA’s response letter, API expressed that it would be helpful to include language in the preamble clarify ing the requirements according to EPA’s responses in the letter. APIasked if EPA would be willing to consider including concentration

- based standards in the rule at this time for engines between 25 and 100 horsepower (HP). EPA indica ted it would consider adding concentration

- based alternative standards, but t hat is a substantial change that would require notice and comment, EPA said. APIasked if EPA was considering adding any new definitions to the rule, for instance, a definitio n for “major repair.” EPA indicated that it did not believe so. Finally , API explained that the State of Wy oming is urging the use of natural gas units on drill rigs . According to API , h owever, natural gas engines above 300 HP suitable for drill rigs are not being produced by manufacturers. Ty pically , drill rig engines are between 600 and 800 HP or 1,000 HP and above. API asked that a provision be added to 40 CFR part 60, subpart JJJJ, allowing engines to elect to comply with 40 CFR part 60, subpart JJJJ instead of nonroad standards. EPA noted API ’s concern, but indicated that such a request cannot be addressed under this rule because these are mobile source engines. API expressed that it wanted EPA to be aware of this issue and that manufacturers are not going to be certify ing engines for this service.