E [C]/R Incorporated
                  Providing Environmental Technical Support Since 1989




MEMORANDUM   

DATE:		February 16, 2011

TO:		Melanie King, EPA OAQPS/SPPD/ESG

FROM:	Tanya Parise, EC/R, Inc.

SUBJECT:	Summary of the February 7, 2011 Meeting with API Regarding Requirements in the RICE NESHAP

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INTRODUCTION

      A meeting was held between EPA and the American Petroleum Institute (API) to follow-up on earlier meetings and issues related to the current requirements for stationary reciprocating internal combustion engines subject to 40 CFR part 63, subpart ZZZZ.  Summaries of the previous meetings between EPA and API are available in the docket (EPA-HQ-OAR-2008-0708-0693, 0696, and 0743).  
      
ATTENDEES

Michael Horowitz, EPA
Kyle Jantzen, Exterran
Bob Wayland, EPA
Michael McBride, Van Ness Feldman
Melanie King, EPA (by phone)
Jenny Yang, Marathon
Peter Westlin, EPA (by phone)
Dan Regan, INGAA
Colin Boswell, EPA (by phone)
Jeff Panek, IES (by phone)
Barrett Parker, EPA (by phone)
Jim McCarthy, IES (by phone)
Tanya Parise, EC/R (by phone)
Ellen Collins, Chevron (by phone)
Matt Todd, API
Clay Freeberg, Chevron (by phone)
John Wagner, API
Janet Bounds, Chevron (by phone)
Jeff Adams, BP
Rebecca Rentz, Bracewell & Giuliani (by phone)
Bill Wehrum, Hunton & Williams
Tom Monohan, ExxonMobil (by phone)
Joshua Epel, DCP Midstream

Bill Grygar, Anadarko



SUMMARY OF MEETING 

	Prior to the meeting, EPA provided draft regulatory language concerning revisions to the continuous parameter monitoring system (CPMS) requirements currently in 40 CFR part 63, subpart ZZZZ.  During the meeting, API raised two concerns with the draft CPMS regulatory language.  First, API was concerned with the term "approved" as it appeared in 63.6625(b)(2) of the draft language, which read as follows:

"You must install, operate, and maintain each CPMS in continuous operation according to the procedures in your approved site-specific monitoring plan."

In API's opinion, the term "approved" might be extraneous and could cause confusion, and API therefore recommended that the term not be included in the rule.  Secondly, API recommended that EPA include a brief paragraph in the preamble explaining how the hour averages should be reduced and calculated in order to demonstrate compliance.  

	Regarding the current requirements for stationary engines located at area sources, API reiterated from prior meetings that EPA consider providing regulatory alternatives.  EPA asked API to provide specific recommendations for alternative provisions and flexibility for area source engines.  API indicated that it would provide various alternatives for EPA to consider.  EPA and API plan to meet again to discuss the specific suggestions that API will provide for area source engines.  


