MEMORANDUM  SEQ CHAPTER \h \r 1    

TO:		Melanie King, EPA OAQPS/SPPD/ESG

FROM:	Tanya Parise, EC/R, Inc.

DATE:		September 8, 2009

SUBJECT:	Summary of the August 27, 2009 Teleconference with the
Environmental Defense  Fund and the U.S. Environmental Protection Agency
to discuss the Proposed NESHAP for Existing Stationary RICE

1.0	INTRODUCTION

A teleconference between the Environmental Defense Fund (EDF) and the
U.S. Environmental Protection Agency was held on August 27, 2009.  The
purpose of this teleconference was to discuss the proposed national
emission standards for hazardous air pollutants (NESHAP) for existing
stationary reciprocating internal combustion engines (RICE).  The
proposed NESHAP for existing stationary RICE was published in the
Federal Register on March 5, 2009 (74 FR 9698).  A previous
teleconference was held between EPA and EDF on June 30, 2009, and the
purpose of this meeting was to follow-up on issues discussed in June. 
This meeting summary will be available in the docket for this rulemaking
(Docket ID No. EPA-HQ-OAR-2008-0708).

2.0	ATTENDEES

U.S. Environmental Protection Agency

Bob Wayland, OAQPS/SPPD/ESG

Melanie King, OAQPS/SPPD/ESG

Michael Horowitz, OGC

Environmental Defense Fund

Hilary Sinnamon, Consultant to EDF

Elizabeth Paranhos, Consultant to EDF

Alpha-Gamma, Technologies Inc. (subcontractor to EC/R, Inc.)

Tanya Parise, Consultant to EPA

3.0	SUMMARY OF MEETING

EDF requested this meeting with EPA to further discuss their comments on
the proposed rule for existing stationary RICE.  In particular, EDF
wanted to reiterate why it believes it is important to set a particulate
matter (PM) standard.  In EDF’s opinion, establishing requirements for
PM is critical to public health.    

The State of California and others have shown that technologies are
available to reduce PM emissions from stationary diesel engines,
according to EDF.  EPA asked if California is attempting to apply PM
filters on existing stationary diesel engines that are older (20 years).
 EDF thought this was the case and that the California rule is designed
to make older engines retire.  The existing RICE NESHAP is a
technology-based standard and EPA has concerns about the technical
feasibility of applying catalyzed PM filters to existing diesel engines.
 EDF said that it recently had a conversation with the Manufacturers of
Emission Controls Association (MECA), who indicated that that PM filters
can be applied to older engines, but that there is an increased cost in
retrofitting the engines.  EDF said that according to MECA, PM filters
are currently being applied to older engines dating back to the
pre-1990s.  EDF recommended that EPA talk directly to MECA regarding
this issue.

EDF had stated in its original written comments on the proposed rule
that PM is a more appropriate surrogate than carbon monoxide (CO). 
Additional research conducted since submitting their original comments
has led EDF to conclude that CO is an appropriate surrogate for gaseous
toxics.  However, EDF also urged EPA to consider PM as an additional
surrogate.  EPA noted that it does not have speciated PM data to link
the emissions of HAP to PM.  EPA indicated that it would be necessary to
establish a quantitative relationship between HAP and PM emissions.  If
EPA could determine that HAP emissions are invariably present in the
potential surrogate, which in this case would be PM emissions, EPA could
consider using PM as a surrogate for HAP and establish a PM standard. 
EDF asked if EPA could base a relationship on scientific studies.  EPA
responded that it could likely use a scientific study to establish a
relationship, but that for floor-setting purposes, EPA would need
emissions data from existing sources.  EDF said that it could help
provide information indicating that HAP is in PM and that it would check
with the State of California in order to obtain some supporting
information for EPA.  EPA told EDF that mid to the end of October would
be acceptable for submitting additional information, but that the sooner
EDF can send information the better, especially if EDF plans to submit
test data.

E C/R Incorporated	Providing Environmental Technical Support Since 1989



	

 PAGE   

 PAGE   1 

 PAGE   2 

