1 Summary of Meeting with EMA Regarding the Final Stationary C I NSPS

February 9 , 200 9
Attendees Jaime Pagán, EPA Gordon Gerber, Caterpillar Michael Horowitz, EPA (by phone) Johan Boij, Wartsila Tany a Parise, AGTI Tim French, EMA (b y phone) Joe Suchecki , EMA Brad y Winkleman, Caterpillar (by phone) Purpose of Meeting The purpose of this meeting was to discuss issues the Engine Manufacturers Association (EMA) has with the final new source performance standards (NSPS) for stationary compression ig nitio n (C I) internal combustion engines

. Summary of Meeting
EMA requested to meet with EPA to discuss the final stationary C I NSPS mostly related to engines greater than 30 liters per cy linder (l/cyl)

. EPA has also met with EMA on previous occasions where similar issues were discussed. On December 4, 2008, EMA sent a letter to EPA reiterating the stationary CI NSPS issues. The letter is included as Attachment 1 to these meeting minutes. EMA also provided an agenda , which is included as Attachment 2. In addition, further information was provided b y Wartsila by email after the meeting, which is available from the docket (EPA

- HQ

- OAR

- 2010

- 0295).
CI NSPS Exemption for Emergency Engines EMA believes that the same provisions that were provided for stationar y emergency

engines in the NSPS rules for engines less than 30 l/cyl should also be provided for stationary

CI engines greater than 30 l/cy l. EPA noted that it was not aware of an y emergency stationary engines of that size at the time of the rulemakings a nd therefore did not find it necessary to establish separate subcategories for prime vs. emergency

engines. EPA added that the emission standards under the CI NSPS for greater than 30 l/cy l engines are based on the use of selective catal yt ic reduction (SC R). EPA asked EMA what the technical limitations of using SCR are and indicated that it is necessary to evaluate whether there are technical limitations associated with apply add

- on controls for engines of that size. EMA said that it is more than an issu e with just SCR, but that relief is also necessary for the particulate matter (PM) standards. EMA indicated that stationary

emergency

CI engines greater than 30 l/cy l provide critical backup for the nuclear industry . It is not a big market, EMA said, but since the engines are used with nuclear industry

it requires several megawatt (MW) of power and it is a new market. EMA expressed that it would like to see a level play ing field and added that 80 to 90 new engines in the 6 to 9 MW range are expected in the nuclear market. EMA indicated that it has previously

told EPA that the emergency engine standards in the CI NSPS for2

greater than 30 l/cy l should not be aftertreatment

- forcing and that emergency engines greater than 30 l/cy l should be treated similarl y to emergency engines below 30 l/cy l. Details on EMA’s rationale for requesting an exemption f or less stringent standards for emergency

engines greater than 30 l/cy l can be found in Attachment 1. Fuel Sulfur Levels Regarding fuel sulfur levels, EMA b elieves that requirements affecting diesel fuel quality should be consistent across technologies and geographic areas. Again, EMA believes it is a level play ing field issue. EPA indicated that Alaska is going to 15 parts per million sulfur fuel in 2011 e very where and that it does not make sense to lower the fuel standards for engines. I t may be more appropriate if the fuel standards for other technologies like turbine and boilers become more stringent. EMA pointed out that diesel particulate filters (DP F), which is the technology EPA relied upon for PM standards under the CI NSPS for some of the engines less than 30 l/cy l is not a feasible technique for these large engines. EMA said that the large engines above 30 l/cy l need to use electrostatic precipi tators and other technologies similar to the controls used by boilers and turbines. PM Testing Methods
EMA said that the CINSPS needs to allow alternative methods for testing PM emissions from large engines . There are issues related to the condensation of hy drocarbons, according to EMA, who added that the boiler standards allow for a modified Method 5. There are also problems with higher sulfur fuel and sulfate formation. EMA stated that EPA Method 17 is a better option and should be allowed along with EPA Method 5b. EPA indicated that it would be worthwhile to discuss the PM testing method issue with the Emissions Monitoring Center and agreed to look into the issue. EMA pointed out that its members need relief fairl y quickl y and suggested that a gui dance document be published by EPA. Larger engines are different and they need to be allowed to used different methods, EMA said. Emission Standards/BDT EMA said that it believes that EPA should account for flexibility within the size of engines greate r than 30 l/cy l and that the framework is there in the upcoming standards for marine C3 engines. EMA pointed out that EPA needs to consider the variet y in these engines and stated that there is a problem with getting all size engines and applications to m eet the same standards. EMA recommend ed that EPA review the BREF document as a first start to determine the best demonstrated technology for engines above 30 l/cy l. EMA said that perhaps including a size threshold within the above than 30 l/cy l engines i s appropriate, e.g., the European Union uses 50 MW as a threshold for more stringent standards. EPA noted that it is difficult to lower the stringency of standards, but that it will need to look at OTAQ’s rule and other information.
Other Issues3

Engin e Incentives EMA said that EPA should develop and include high efficiency /low carbon dioxide incentives for engines in the NSPS to allow a level playing field with other energy conversion technologies . EMA stated that it seems logical that similar ince ntives be provided for engines that has been provided for combustion turbines and boilers. Definition of Installation EMA thinks that a definition of “installed” needs to be developed to be consistent with the current industry

and site regulatory

practi ces. EPA indicated that it will look into this issue and provide a resolution either b y having OECA issue something in the applicability

document or by

adding a definition in the revised rule. Upcoming MACT Regulations EMA was interested in finding out about the upcoming MACT regulation, startup, shutdown, malfunction ruling, and Environmental Defense Fund settlement for existing diesel engines. EPA indicated that it is working on a regulation that will address these issues. There is a consent decree to have the proposed regulation for existing engines at area sources, existing engines less than or equal to 500 HP, and existing diesel engines greater than 500 HP signed by 2/25/2009 . The rule is supposed to be finalized by 2010.4 Attachment 1 EMA December 4, 2008 Letter to EPA5

December 4, 2008 Mr. Jaime Pagan Energy Strategies Group US Environmental Protection Agency D243

- 01 Research Triangle Park, NC 27711
RE: Resolution of Outstanding Issues in 40 CFR 60 Subpart IIII, Standards of Performanc e for Stationary Compression Ignition Internal Combustion Engines, as Applied to Larger CI engines. Dear Mr. Pagan: The Engine Manufacturers Association (EMA) represents the major manufacturers of internal combustion engines used in stationary sources that are now regulated b y the recently promulgated Compression Ignition (CI) NSPS (40 CFR 60 Subpart IIII). EMA worked closel y with you and your office during the development of the proposed and final rules, and EMA member companies are now working to ens ure final compliance to the standards established in the rule. Although EMA believes that the CINSPS final rule generally adopts a technically feasible level of control for most categories of stationary CI engines, we have continuing concerns regarding the final NSPS rule as it applies to very large engines, those over 30 liters per cy linder (30 l/cy l). The requirements and emissions standards for those engines are identified in Section 60.4204 (c) and Section 60.4205 (d) of the final regulation. Manuf acturers’ concerns include several issues that previously have been discussed with yo u in both written submittals and meetings over the last y ears. That correspondence included letters and comments submitted by EMA and Euromot dated 29 September 2006, 27 November 2006, 13 April 2007, and 29 June 2007. We last addressed the issues at an EPA/EMA meeting at y our offices on 27 August 2007. Specificall y, the previously identified issues that need resolution include the following:

 The NSPS establishes a singl e set of emission standards for engines greater than 30 l/cy l that do not recognize nor address the broad and diverse facility categories that utilize such engines. Further, these standards do not reflect best demonstrated technology

.

 The NSPS exemption related to the use of aftertreatment technology on emergency engines also should apply to engines greater than 30 l/cy l.

 The geographic areas where higher sulfur fuels are allowed or that are subject to alternative emission requirements in the NSPS should be the same as allowed in other NSPS regulations.

 EPA Method 5 is not adequate to measure PM from engines larger than 30 l/cy l, and alternative methods are needed to improve accuracy

.6

 The EPA should include provisions in the NSPS that incentivize and pr omote engines with high energy efficiency . EPA has included such provisions in final NSPS rules for other combustion technologies such as turbine and boilers. This issue applies to all engines and not only those with displacement greater than 30 l/cy l
T he following text provides additional details and discussion on the above issues. The emissions standards for engines greater than 30 l/cyl are not Best Demonstrated Technology and should be changed. EMA believes that some of the requirements imposed on engines greater than 30 l/cy l go bey ond EPA’s stated objective of the NSPS which is to “require all new, modified, and reconstructed stationary CI ICE to use best demonstrated s ystems of continuous emission reduction, considering cost, non

- air qualit y hea lth, and environmental and energy impacts, not just with add

- on controls, but also by eliminating or reducing the formation of these pollutants” (Final Rule, CII CE NSPS, FR 71: 39154, Summary). As applied to very large engines, the final NSPS exceed that objective b y adopting emissions standards that require the use of sy stems that are not best demonstrated technology or that significantly adversely

affect costs, non

- air quality health, the effects of the standards on local air quality , and energy impacts . Specificall y, the final emission standards for engines over 30 l/cy l do not provide flexibility to address local infrastructure, energy , or air qualit y conditions but mandate costly aftertreatment control sy stems for PM and NOx reductions. As mentione d above, EPA has established a single set of emission standards for owners and operators for all stationary CI engines greater than 30 l/cy l. Owners and operators of such engines must reduce NOx emissions by 90% or achieve an emissions standard of 1.6 g/kW

- hr, and must reduce PM b y 60% or achieve an emissions standard of 0.15 g/kW

- hr. Attaining the proposed standards will likely require the use of both NOx and PM aftertreatment technology . The rule does not provide sufficient transition time to develop an d demonstrate the required technologies for these very large engines. Furthermore, the wide range of facility and engine sizes, the application and location of a specific facility , the availability of low

- sulfur diesel fuel in territories, and operating c onditions are extremely varied. Aftertreatment to meet the final standards may not be technically

or economicall y feasible under a given set of site conditions. Many remote applications that depend on very large stationary

diesel engines will be severel y disadvantaged if products are not available. As a solution for this issue, EMA proposes that the emission standards for stationary engines greater than 30 l/cy l should be harmonized with the recently approved International Maritime Organization (I MO) em issions regulations. Although there are technical differences between very large marine engines and stationary engines created for specific applications and duty cy cles, there are correlations between the required engine development and demonstration prog rams.7 First, the IMO, of which EPA is a key contributor and the US is now signatory , has approved at MEPC58 on October 9 th 2008 both Tier II standards and Tier III aftertreatment forcing standards covering engines of this size. The Tier III NOx standar ds will mandate compliance starting with new ship construction in 2016 to allow time for development of the required technologies. Engines and aftertreatment sy stems will need to be developed and available at that time to meet the IMO standards. Secondly , a stand

- alone US EPA proposed rulemaking is currentl y underway for Marine engines greater than or equal to 30 l/cy l (Reference the EPA Federal Register release. [EPA

– HQ

– OAR

– 2007

– 0121; FRL

– 8502

– 5] RIN 2060

–AO38 Control of Emissions From New Marine Compr ession

- Ignition Engines at or Above 30 Liters per Cylinder). This US EPA proposed rulemaking is expected to harmonize with I MO requirements as well. EMA believes a similar approach is warranted for very large stationary

engines, which are nearly

all der ived from those somewhat higher volume, very large marine engines. Often the same engine ty pes (with different turbo specifications) are used in both stationary

and marine applications. One difference is that very large marine engines are IMO certified u sing lighter fuels whereas very large stationary

engines meet World Bank/IFC standards using fuels available at the site. Another difference is that very large marine engines are developed with a focus on part

- load performance and load

acceptance requir ements and are t ypically optimized at an 85

- 90% Maximum Continuous Rating(MCR) load range, whereas very large stationary

engines are optimized for 100 % MCR load with less development at partial loads. One resulting difference is that marine and stationary plant engines have different turbo charger matching (different components in turbo chargers). Since manufacturers are now required to meet IMO regulations for very large marine engines, the US is now a signatory to IMO, and EPA has promoted the I MO re gulations for several ye ars, EMA believes that the EPA should revise the NSPS for greater than 30 l/cy l engines to harmonize with IMO requirements for stationary engines. Engine manufacturers make both marine and stationary versions of these engine t ypes. If EPA were to harmonize the requirements, manufacturers will be able to leverage development of solutions for both applications. The NSPS exemption related to the use of aftertreatment technology on emergency CI engines should be applied to engines gre ater than 30 l/cyl to allow their use in emergency applications such as nuclear power system back
- up, firefighting, flood control, and national security. In order to prevent potential performance and start

- up problems when CI engines are used for emergenc y power generation, the final NSPS does not require owners or operators to use aftertreatment emissions control equipment on emergency generators. However, this critical exemption is not applied to engines greater than 30 l/cy l in the current rule.
For e xample, the nuclear power generation industry must provide back

- up emergency

power in order to assure the safe shut

- down of the reactor in case of an emergency

or disruption of off

- site power. Due to their excellent performance and8

reliability characteris tics, large diesel generators are the preferred option for such back

- up power s ys tems. In man y cases, the nuclear industry requires back

- up power sources capable of generating 10 MW or more of power, and such generators will generall y require IC engines w ith a 30 l/cy l displacement. However, in order to meet the emissions standards for greater than 30 l/cy l engines established in the final CI NSPS, aftertreatment controls for PM and NOx will be needed. As in the case of smaller engines, the addition of s uch aftertreatment s ys tems to meet current NSPS emission standards will jeopardize the ability of the engines to meet their primary safety function and performance standards required for emergency safet y s ys tems. The primary

function of emergency

generato rs is to guarantee the power supply in case of loss of external electricit y. EMA believes it is critical that the CI NSPS emissions standards do not interfere or jeopardize this critical function or prevent the use of large CI engines in emergency

applications. As in the case of smaller emergency generators, large emergency

generators will only

be run for periodic and required safet y tests and in the case of an emergency

. Since EPA has adopted an exemption to the emissions limits for emergency diesel generators where meeting the emissions limits would require the use of aftertreatment devices and EPA has provided an exemption from NOx emissions limits for combustion turbines used in emergency situations 1 , it follows that the same exemption should be al lowed for engines greater than 30 l/cy l that are used to provide emergency back

- up power. In order to address this situation, the final CINSPS should be amended to establish emissions standards for emergency engines with a displacement greater than 30 l/ cy l that can be achieved during emergency operating conditions and during limited maintenance & readiness testing (as defined in the final CINSPS paragraph 60.4211 e) without the addition of aftertreatment PM or NOx controls. A s stated above, EMA recomme nds harmonization with the I MO standards. For emergency

- use stationary CI engines greater than 30 l/cy l, we recommend that a slightly

modified IMO Tier II standard be adopted and become effective in January 2011 and that the IMO Tier 1standards be adopt ed until that time The current requirement in the CI NSPS (40 CFR 60.4213) to conduct tests within 10% of 100 percent peak load (or the highest achievable load) is appropriate since it reflects the actual operations and usage of the stationary engine. EMA recommends that the CI NCPS be amended to state that performance tests for slightly modified IMO Tiers I and II also be conducted within 10 % of 100 percent peak load or the highest achievable load of the engine. The CI NSPS ruling also requires an annual performance test to demonstrate compliance with the set emission limits. EMA recommends that the simplified measurement method and allowances stipulated in Sections 6.3.11 and 6.4.15.2 of the IMO MEPC58 Revised Marpol Annex VI October 2008 be used fo r emissions measurements of engines at the site.

1 US EPA 2006. F inal Rule. S tandards of Performance for Stationary Combustion Turbines. Federal Register, 78: p 38497.9 The geographic areas allowed to use higher sulphur content fuels or that are subject to alternative emissions requirements in the CI NSPS should be the same as allowed in other NSPS regulations. EPA ha s recognized that certain geographical areas, because of their isolation from the mainland US or environmental conditions, warrant exceptions to the provisions in the CINSPS governing fuel quality or permissible emissions. For example, the CI NSPS exclud es the American territories of Guam, America Samoa and the Northern Mariana Islands from the fuel sulfur content requirement. Consequently , emissions standards from engines in such locations should not be as stringent since the quality of fuel in those lo cations is different. Although EMA believes such exceptions are necessary and commendable, we are concerned that various EPA NSPS rules are not consistent in defining such areas or in allowing alternative emission standards for such areas. Specificall y, in both the combustion turbine rule and the steam generator boiler rule, the geographic areas defined as non

- continental or territories are expanded to include the Hawaiian Islands, Virgin Islands, and Puerto Rico and offshore platforms. The same defini tion and allowances for different fuel quality available in those locations should be applied to the CINSPS as well, i.e., the geographic exemptions should be the same in all rules and thus expanded in the CI NSPS rule. In addition, EMA believes that re mote areas that experience harsh environmental conditions, such as remote areas in Alaska, require additional exemptions from the fuel and emissions limits in the CINSPS. The harsh environmental conditions in those locations make compliance to the curren t NSPS emissions extremely problematic since they affect the applicability

of aftertreatment technology such as SCR sy stems. In those areas, EMA recommends that secondary abatement techniques not be required due to the problems associated with reagent ava ilability and equipment and sy stem freezing. As an example, EPA established alternative and less stringent emissions standards for gas turbines operating north of the artic circle, in off

- shore applications or operating at temperatures below zero degrees F. Similar provisions need to be incorporated into the CINSPS. Alternative emissions standards should be adopted that are appropriate and achievable given the harsh environmental conditions present. A s recommended previousl y, EMA supports harmonizati on with I MO standards for areas where higher fuel sulfur or fuels blended with used lubrication oil are allowed. In those areas, stationary CI engines >30 l/cy l should harmonize with a slightly modified IMO Tier II and Tier I that reflects the design rati ng of stationary

engines (testing at steady state loads within 10 % of 100 percent peak load or the highest achievable load). For the particulate limit we propose the same particulate limits (steady state load within 10 % of 100 percent peak load or the highest achievable load of the stationary engine) of the EU L CP BREF document (available at h ttp://www.jrc.es/pub/english.cgi/d1254325/19Reference Document on Best Available Techniques for Large Combustion Plants (adopted July 2006)

- 22Mb page 405, table10

6.47) 30 mg/Nm 3 (15 % O 2 ) for light fuel oil and distillates and 50 mg/Nm 3 (15 % O 2 ) for heavy fuel oils with measurement modified US EPA Method 5 or EPA 17.
EPA Method 5 is not an adequate method to measure PM from large engines. EPA requires owners and operators of engines greater than 30 l/cy l to use EPA Method 5 to measure PM for performan ce and compliance demonstrations (NSPS Table 7(d) (IV)). Method 5 requires that the PM sample be taken at a cooled exhaust temperature of about 120 degrees C (248 degree F). The flue gas temperature of larger CII CE is t ypicall y in the range of 250

- 350 d egree C (480

– 660 degree F). Consequently , owners and operators will have to cool flue gas from such engines in order to reach the Method 5 described filter holder temperature. According to the CI MAC document 2 this will result in large uncertainties (no n - reproducible sampling): Appendix 2 “. The cooling of the exhaust gas cannot be considered as a controlled process and will not yield reproducible sampling. The main reason for this is the uncontrolled condensation of semi

- volatile components from the e xhaust gas on the cold surfaces needed to cool the gas. According to ISO 9096 and EN 13284

- 1, more reproducible results are achieved if volatile compounds are not trapped during sampling or further evaporated during sample drying. Considering the above i ssues it is concluded that to yield repeatable particulate matter measurement data from the hot exhaust gas of a diesel engine, the particulate sampling has to be performed at exhaust gas temperature, i.e. using in

- stack sampling ”. Measurement methods E N 13284

- 1 (EU), J IS Z 8808 (Japan) and ISO 9096 apply in

- stack sampling of particulate in the case of flue gas temperatures greater than 160 degree C (320 degree F). US EPA Method 17 provides an option similar in principal to those methods. In the case of flue gas temperatures less than 160 degree C (320 degree F), stack

- out particulate sampling is used, and the filter holder temperature is maintained at minimum 160 degree C (320 degree F) in order to avoid risk of condensation and absorption of sulphur co mpounds, water, etc. on the sampling filter. In order to avoid the problems associated with use of Method 5 for engines greater than 30 l/cy l, EMA believes that the NSPS should provide flexibility and allow the use of Method 17 to measure particulate m atter. EPA has allowed such flexibility in other rules, specificall y t he NSPS rule for electric utility steam generating units and industrial

- commercial steam generating units as published in the Federal Register on June 13, 2007. 3 Inthat rule, EPA has specified an “own specific” particulate filter holding temperature and thus approved a higher filter holder temperature than 120 +/

- 14 degree C (248 +/

- 25 degree F) for the US EPA Method 5. The rule also provides flexibility and

2 CI MAC Recommendatio n 23. Standards and Methods for Sampling and Analyzing Emission Components in Non

- automotive Diesel Engine Exhaust Gases

– Marine and Land

- based Power

Plant Sources. CIMAC working group on Exhaust Emissions, 2005.

3 US EPA. F ederal Register Notice Final Rule Amendments to NSPS Standards, Ju ne 13. 2007. FR 72: Page 32738.11

the use of Method 17, and indicates that steam generating units shall use particulate measurement methods 5, 5B or 17. Different prime mover technologies should have fair and equal treatment under EPA regulations, and if flexibility and alternative filter holding temperatures ar e provided for one prime mover technology , than a similar and applicable requirement should be allowed for other prime mover technologies. EMA recommends that the requirements of the CI NSPS be amended to allow owners and operators to use Method 17, and w here engine stack temperatures are less than 160 degree C (320 degree F) (in wet flue gas desulphurization stacks, etc.) to allow the use of Method 5B instead of Method 5 in order to get reproducible measurement results and avoid uncontrollable/difficult measuring conditions. Such procedures also align with applicable regulations in Japan and European countries.
EPA should encourage energy efficiency and fuel savings technology by adding an energy efficiency provision in the CI NSPS. The impact of EPA regulations on energy use should be a key

consideration when developing and finalizing emission standards as described in the recent EPA ANPRM on greenhouse gas emissions. The NSPS should include provisions promoting energy and fuel efficiency , reducing f uel use through the use of combustion sources with high fuel

energy conversion rates is a key element of federal energy policy to reduce the nation’s dependence on imported petroleum. Further, the use of high efficiency engines also results in lower greenhouse gas emissions and can be an effective way to reduce greenhouse gas emissions. EPA should include a provision within the CINSPS that provides an energy efficiency incentive allowing increases in the emission of criteria pollutants for engines and generation sy stems that meet certain thresholds of energy efficiency . EPA has alread y adopted such incentives for other technology in NSPS regulations governing steam generator boilers, and stationary combustion turbines as follows:
US Steam

- generatin g (boiler) unit NSPS, page 32739: “For the purposes of determining compliance with the emission limits in paragraph 60.45Da the owner or operator of generating unit which is also a cogeneration unit shall .. calculate emission rates based on electrical output to the grid plus 75 percent of the equivalent electrical energy (measured relative to ISO conditions) in the unit’s process stream .” Note paragraph 60.45Da is for the Hg emission, i.e., a 75 % bonus for the recovered heat. US stationary

combustio n turbine NSPS, page 38499: “... For combined

- cycle and combined heat and power complying with the output

- standard ...gross energy output is calculated as the sum of the total electrical and mechanical energy generated by the combustion turbine, the additiona l electrical or mechanical energy (if any) generated by the steam turbine .. and 100 percent of the total12 useful thermal energy output that is not used to generate additional electricity or mechanical output expressed in equivalent MW ..” Note Emission bonus is applied on the regulated emissions: NOx and SO 2 , i.e., a 100 % bonus for the recovered heat and full bonus for extra generated electrical/mechanical energy  (e.g. a 30 % electrical + 60 % heat recovery = 90 % efficiency  emission limit 3 times higher compared to the electricit y production only

case). EMA requests that EPA develop and incorporate a similar efficiency provision for CIengines. Adoption of such as program will recognize the importance of energy efficiency and the benefits of redu cing fuel use and greenhouse gas emissions. Moreover, incorporating efficiency considerations in the regulation will provide a level play ing field for engine

- based s ys tems compared to boilers and turbine that can already take advantage of such energy effi ciency

provisions in NSPS regulations governing those technologies. EMA is prepared to work out an efficiency provision together with US EPA. Summary EMA appreciates the opportunity to bring the above issues with the CINSPS to yo ur attention and to pro vide some additional background information on these topics. With the finalization of the SINSPS, we believe it is an appropriate time to resolve these issues and ask that EPA consider making the necessary revisions to the CI NSPS as soon as possible. W e would be happ y to discuss these items with y ou and suggest that we set up a meeting date in January to discuss and resolve these issues. Please feel free to call me if y ou have any questions. Respectfully

submitted, Josep h L. Suchecki Joseph L . Suchecki Director, Public Affairs13 Attachment 2 Meeting Agenda14 EPA/EMA Stationary Engine Meeting

February 9, 2009 1:00 PM Eastern Time EPA Offices, Research Triangle Park, NC

AGENDA
I. Introduc tion and Purpose of Meeting

– EMA

EPA feedback on the status of outstanding issues from the 4 December 2008 EMA Letter to EPA

– Compression Ig nition Engines Greater Than 30 l /cyl II. Outstanding Issues
- > 30 l/cyl Engines A. Exemption for Emergency Engines

The s ame exemption granted emergency engines in the CI and SI NSPS regulations for engines < 30 l/cyl also needs to apply to emergency engines > 30 l/cyl B. Harmonized Fuel Sulfur Levels

– Territories and Applications

Allowable fuel sulfur levels for engines >30 l /cyl needs to be harmonized across energy conversion technologies and geographic areas C. PM Testing Methods

The CI NSPS regulation needs to allow alternative methods for testing PM emissions from large engines D. Emission Standards and Best Demonstrated Technol ogy

The existing CI NSPS em ission standards for engines > 30 l/cyl needs to be changed to account for the very low volume of diverse applications, using a leveraged approach from best demonstrated control technology III. Outstanding Issues

– CI and SI NSPS A. Stat ionary Engine High Efficiency/Low CO 2 Incentives

EPA needs to develop and include high efficiency/low CO 2 incentives for engines in the NSPS to allow a level playing field with other energy conversion technologies B. Definition of Installed for Stationary Eng ine s

Discussion on a definition of “installed” as it applies to stationary engines, relative to current industry and site regulatory practices IV

. Updates on Other Issues/Status A. Upcoming MACT Regulations B. Start
- Up, Shutdown, and Malfunction Court Ruling

– Poten tial Impact on E ngines C. Environmental Defense Settlement
- Existing Diesel Engine Controls V. Summary and Next Steps