MEMORANDUM  SEQ CHAPTER \h \r 1    

TO:		Melanie King, EPA OAQPS/SPPD/ESG

FROM:	Bradley Nelson, EC/R, Inc.

DATE:		January 19, 2010

SUBJECT:	Summary of the November 17, 2009 Teleconference with the
American Petroleum Institute and the U.S. Environmental Protection
Agency to discuss API’s supplemental analyses for the  Proposed NESHAP
for Existing Stationary Reciprocating Ignition Internal Engines

1.0	INTRODUCTION

The American Petroleum Institute (API) requested this teleconference
with EPA to discuss the supplemental analyses that it sent to EPA on
November 2, 2009.  The analyses included cost effectiveness of control
options in the proposed national emission standards for hazardous air
pollutants (NESHAP), a support paper for management practices at area
sources located in rural areas, and a summary of stationary compression
ignition engine test data.  The supplemental analyses can be found in
the docket as Document ID Nos. EPA-HQ-OAR-2008-0708-0272, 0279 and 0280.
 This meeting summary will be available in the docket for this
rulemaking (Docket ID No. EPA-HQ-OAR-2008-0708).  The proposed NESHAP
for existing stationary RICE was published in the Federal Register on
March 5, 2009 (74 FR 9698).  

2.0	ATTENDEES

U.S. Environmental Protection Agency

Melanie King, OAQPS/SPPD/ESG

Michael Horowitz, OGC

American Petroleum Institute

Matt Todd, API

Jeff Panek, IES

Roger Zygmunt, Shell

Jenny Yang, Marathon

Tom McGrath, IES

Paul Little, Air Hygiene

Jeff Adams, BP

Tom Monahan, ExxonMobil

Jim McCarthy, IES

Lynn Reed, ONEOK

Janet Bounds, Chevron

Tim Helbig, ONEOK

EC/R Incorporated

Bradley Nelson 

3.0	SUMMARY OF MEETING

API indicated that review of the emissions data used to develop the
maximum achievable control technology (MACT) floor for stationary spark
ignition (SI) engines found test data using invalid test methods and the
wrong classification of SI engines between rich-burn and lean-burn
engines.  API also found the same kind of issues with the test data used
to develop the MACT floor for stationary CI engines.  API stated that
the MACT floor for CI engines between 50 and 500 horsepower (HP) was
based on data for CI engines greater than 1,000 HP.  API noted that
these 50 to 500 HP engines are not like the larger engines and have
different emission characteristics.  EPA asked why 50 to 500 HP CI
engines are different than larger CI engines.  API responded that these
engines are designed differently to operate at variable loads, whereas
larger engines are designed to operate at a steady-state load.

API asked if EPA intended to subcategorize cyclic duty engines, such as
air compressors or welding equipment.  API does not believe that
catalytic controls are effective on these engines.  EPA noted that
catalytic controls have been installed on mobile engines for many years.
 API responded that mobile engines are different than mobile engines and
those mobile engines have a shorter life cycle than stationary engines. 
EPA responded that no final decisions have been made in terms of
subcategories for CI engines.   

The next topic of discussion was API’s proposal to require management
practices for area source SI engines less than or equal to 500 HP
located in rural areas.  API stated that many of these engines are
located in rural areas and do not affect public health.  API stated that
it is generally supportive of the oil change and air filter requirements
in the proposed rule; however API indicated that it would like a
provision that allows an oil analysis to be done to see if the oil needs
to be changed.  EPA asked for more information on the oil analysis
proposal.  API stated that engine manufacturers or lube oil dealers can
provide information on oil analysis plans.  EPA responded that it needed
more specifics for an oil analysis program.  API stated that it would
provide EPA with the information.

E C/R Incorporated	Providing Environmental Technical Support Since 1989



	

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