1

Summary of Meeting with EMA

Regarding the Final Stationary CI NSPS

February 9, 2009

Attendees

Jaime Pagán, EPA Gordon Gerber, Caterpillar

Michael Horowitz, EPA (by phone) Johan Boij, Wartsila

Tanya Parise, AGTI Tim French, EMA (by phone)

Joe Suchecki, EMA Brady 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 ignition (CI) internal combustion engines. 

Summary of Meeting

EMA requested to meet with EPA to discuss the final stationary CI NSPS mostly

related to engines greater than 30 liters per cylinder (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 by 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 stationary 

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/cyl. EPA noted that it was not aware 

of any emergency stationary engines of that size at the time of the rulemakings and 

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/cyl engines are based on the use of selective catalytic reduction (SCR). 

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 issue 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/cyl 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 playing 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 for 
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greater than 30 l/cyl should not be aftertreatment-forcing and that emergency engines 

greater than 30 l/cyl should be treated similarly to emergency engines below 30 l/cyl. 

Details on EMA’s rationale for requesting an exemption for less stringent standards for 

emergency engines greater than 30 l/cyl can be found in Attachment 1. 

Fuel Sulfur Levels

Regarding fuel sulfur levels, EMA believes that requirements affecting diesel fuel 

quality should be consistent across technologies and geographic areas. Again, EMA 

believes it is a level playing field issue. EPA indicated that Alaska is going to 15 parts 

per million sulfur fuel in 2011 everywhere and that it does not make sense to lower the 

fuel standards for engines. It 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 (DPF), which is the technology EPA relied upon for PM 

standards under the CI NSPS for some of the engines less than 30 l/cyl is not a feasible 

technique for these large engines. EMA said that the large engines above 30 l/cyl need to 

use electrostatic precipitators and other technologies similar to the controls used by

boilers and turbines.

PM Testing Methods

EMA said that the CI NSPS needs to allow alternative methods for testing PM 

emissions from large engines. There are issues related to the condensation of 

hydrocarbons, 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 fairly quickly and suggested that 

a guidance 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 greater than 30 l/cyl and that the framework is there in the upcoming standards 

for marine C3 engines. EMA pointed out that EPA needs to consider the variety in these 

engines and stated that there is a problem with getting all size engines and applications to 

meet the same standards. EMA recommended that EPA review the BREF document as a 

first start to determine the best demonstrated technology for engines above 30 l/cyl. 

EMA said that perhaps including a size threshold within the above than 30 l/cyl engines 

is 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 Issues
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Engine 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 incentives 

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 practices. EPA indicated that it will look 

into this issue and provide a resolution either by 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.
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Attachment 1

EMA December 4, 2008 Letter to EPA
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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 Performance 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 by the recently promulgated Compression Ignition (CI) NSPS (40 CFR 60 

Subpart IIII). EMA worked closely with you and your office during the development of 

the proposed and final rules, and EMA member companies are now working to ensure 

final compliance to the standards established in the rule. 

Although EMA believes that the CI NSPS 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 cylinder (30 l/cyl). The requirements and emissions standards for those engines 

are identified in Section 60.4204 (c) and Section 60.4205 (d) of the final regulation. 

Manufacturers’ concerns include several issues that previously have been discussed with 

you in both written submittals and meetings over the last years. 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 your offices on 27 August 2007.

Specifically, the previously identified issues that need resolution include the following:

 The NSPS establishes a single set of emission standards for engines greater than 30 

l/cyl 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/cyl.

 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/cyl, and 

alternative methods are needed to improve accuracy.
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 The EPA should include provisions in the NSPS that incentivize and promote 

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/cyl

The 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/cyl go beyond EPA’s stated objective of the NSPS which is to “require all new, 

modified, and reconstructed stationary CI ICE to use best demonstrated systems of 

continuous emission reduction, considering cost, non-air quality health, and 

environmental and energy impacts, not just with add-on controls, but also by eliminating 

or reducing the formation of these pollutants” (Final Rule, CI ICE NSPS, FR 71: 39154, 

Summary). As applied to very large engines, the final NSPS exceed that objective by 

adopting emissions standards that require the use of systems 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. Specifically, 

the final emission standards for engines over 30 l/cyl do not provide flexibility to address 

local infrastructure, energy, or air quality conditions but mandate costly aftertreatment 

control systems for PM and NOx reductions. 

As mentioned above, EPA has established a single set of emission standards for 

owners and operators for all stationary CI engines greater than 30 l/cyl. 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 by 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 and 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 conditions are extremely varied. Aftertreatment to meet the final standards 

may not be technically or economically feasible under a given set of site conditions. 

Many remote applications that depend on very large stationary diesel engines will be 

severely 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/cyl should be harmonized with the recently approved 

International Maritime Organization (IMO) emissions regulations. Although there are 

technical differences between very large marine engines and stationary engines created 

for specific applications and duty cycles, there are correlations between the required 

engine development and demonstration programs. 
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First, the IMO, of which EPA is a key contributor and the US is now signatory, 

has approved at MEPC58 on October 9th 2008 both Tier II standards and Tier III 

aftertreatment forcing standards covering engines of this size. The Tier III NOx 

standards will mandate compliance starting with new ship construction in 2016 to allow 

time for development of the required technologies. Engines and aftertreatment systems 

will need to be developed and available at that time to meet the IMO standards. 

Secondly, a stand-alone US EPA proposed rulemaking is currently underway for Marine 

engines greater than or equal to 30 l/cyl (Reference the EPA Federal Register release. 

[EPA–HQ–OAR–2007–0121; FRL–8502–5] RIN 2060–AO38 Control of Emissions 

From New Marine Compression-Ignition Engines at or Above 30 Liters per Cylinder). 

This US EPA proposed rulemaking is expected to harmonize with IMO requirements as 

well.

EMA believes a similar approach is warranted for very large stationary engines, 

which are nearly all derived from those somewhat higher volume, very large marine 

engines. Often the same engine types (with different turbo specifications) are used in 

both stationary and marine applications. One difference is that very large marine engines 

are IMO certified using 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 loadacceptance requirements and are typically 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 IMO 

regulations for several years, EMA believes that the EPA should revise the NSPS for 

greater than 30 l/cyl engines to harmonize with IMO requirements for stationary engines. 

Engine manufacturers make both marine and stationary versions of these engine types. 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 greater 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 emergency 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/cyl in the 

current rule.

For example, 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 and 
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reliability characteristics, large diesel generators are the preferred option for such back-up 

power systems. In many cases, the nuclear industry requires back-up power sources 

capable of generating 10 MW or more of power, and such generators will generally 

require IC engines with a 30 l/cyl displacement. However, in order to meet the emissions 

standards for greater than 30 l/cyl 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 such aftertreatment systems 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 safety systems.

The primary function of emergency generators is to guarantee the power supply in 

case of loss of external electricity. 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 safety 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 situations1, it follows that the same exemption should be 

allowed for engines greater than 30 l/cyl that are used to provide emergency back-up 

power. In order to address this situation, the final CI NSPS should be amended to 

establish emissions standards for emergency engines with a displacement greater than 30 

l/cyl that can be achieved during emergency operating conditions and during limited 

maintenance & readiness testing (as defined in the final CI NSPS paragraph 60.4211 e) 

without the addition of aftertreatment PM or NOx controls. As stated above, EMA 

recommends harmonization with the IMO standards. 

For emergency-use stationary CI engines greater than 30 l/cyl, 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 adopted 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 for emissions 

measurements of engines at the site. 

 

1 US EPA 2006. Final Rule. Standards of Performance for Stationary Combustion Turbines. 

Federal Register, 78: p 38497.
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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 has recognized that certain geographical areas, because of their isolation 

from the mainland US or environmental conditions, warrant exceptions to the provisions 

in the CI NSPS governing fuel quality or permissible emissions. For example, the CI

NSPS excludes 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 locations 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.

Specifically, 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 definition and allowances for different fuel quality available in those locations 

should be applied to the CI NSPS 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 remote areas that experience harsh environmental 

conditions, such as remote areas in Alaska, require additional exemptions from the fuel 

and emissions limits in the CI NSPS. The harsh environmental conditions in those 

locations make compliance to the current NSPS emissions extremely problematic since 

they affect the applicability of aftertreatment technology such as SCR systems. In those 

areas, EMA recommends that secondary abatement techniques not be required due to the 

problems associated with reagent availability and equipment and system 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 CI NSPS. Alternative 

emissions standards should be adopted that are appropriate and achievable given the 

harsh environmental conditions present. As recommended previously, EMA supports 

harmonization with IMO standards for areas where higher fuel sulfur or fuels blended 

with used lubrication oil are allowed. In those areas, stationary CI engines >30 l/cyl 

should harmonize with a slightly modified IMO Tier II and Tier I that reflects the design 

rating 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 LCP BREF document (available at 

http://www.jrc.es/pub/english.cgi/d1254325/19Reference Document on Best Available 

Techniques for Large Combustion Plants (adopted July 2006) -22Mb page 405, table 
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6.47) 30 mg/Nm3(15 % O2) for light fuel oil and distillates and 50 mg/Nm3(15 % O2) 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/cyl to use EPA 

Method 5 to measure PM for performance 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 

CI ICE is typically in the range of 250-350 degree 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 CIMAC 

document2this will result in large uncertainties (non-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 exhaust 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 issues 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 EN 13284-1 (EU), JIS Z8808 (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 compounds, water, etc. on the sampling filter. 

In order to avoid the problems associated with use of Method 5 for engines 

greater than 30 l/cyl, EMA believes that the NSPS should provide flexibility and allow 

the use of Method 17 to measure particulate matter. EPA has allowed such flexibility in 

other rules, specifically the 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 In that 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 CIMAC Recommendation 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. Federal Register Notice Final Rule Amendments to NSPS Standards, June 13. 2007. 

FR 72: Page 32738.
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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 are 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 where 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 fuel use through the use of combustion sources with high fuelenergy 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 CI NSPS that provides an energy

efficiency incentive allowing increases in the emission of criteria pollutants for engines 

and generation systems that meet certain thresholds of energy efficiency. EPA has 

already adopted such incentives for other technology in NSPS regulations governing 

steam generator boilers, and stationary combustion turbines as follows:

US Steam-generating (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 combustion 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 additional electrical or mechanical 

energy (if any) generated by the steam turbine .. and 100 percent of the total 
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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 SO2, 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 electricity 

production only case).

EMA requests that EPA develop and incorporate a similar efficiency provision for 

CI engines. Adoption of such as program will recognize the importance of energy

efficiency and the benefits of reducing fuel use and greenhouse gas emissions. 

Moreover, incorporating efficiency considerations in the regulation will provide a level 

playing field for engine-based systems compared to boilers and turbine that can already

take advantage of such energy efficiency 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 CI NSPS to 

your attention and to provide some additional background information on these topics. 

With the finalization of the SI NSPS, 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. We would be happy to discuss these items with you and suggest that we set 

up a meeting date in January to discuss and resolve these issues.

Please feel free to call me if you have any questions.

Respectfully submitted,

Joseph L. Suchecki

Joseph L. Suchecki

Director, Public Affairs 

 
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Attachment 2

Meeting Agenda
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EPA/EMA Stationary Engine Meeting

February 9, 2009

1:00 PM Eastern Time

EPA Offices, Research Triangle Park, NC

AGENDA

I. Introduction and Purpose of Meeting – EMA

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

EMA Letter to EPA – Compression Ignition Engines Greater Than 30 l/cyl

II. Outstanding Issues - > 30 l/cyl Engines

A. Exemption for Emergency Engines

The same 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 Technology

The existing CI NSPS emission 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. Stationary Engine High Efficiency/Low CO2 Incentives

EPA needs to develop and include high efficiency/low CO2 incentives for 

engines in the NSPS to allow a level playing field with other energy conversion 

technologies

B. Definition of Installed for Stationary Engines

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 – Potential Impact on 

Engines

C. Environmental Defense Settlement- Existing Diesel Engine Controls

V. Summary and Next Steps