MEMORANDUM   

DATE:		November 20, 2012

TO:		RICE NESHAP Docket, EPA-HQ-OAR-2008-0708

FROM:	Melanie King, EPA OAQPS/SPPD/ESG

SUBJECT:	November 19, 2012 Meeting Regarding Proposed Amendments to the RICE NESHAP and RICE NESHAP/NSPS Implementation Q&A Document
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SUMMARY

      A meeting was held between the EPA and the attendees listed below on November 19, 2012 to discuss INGAA's comments on the proposed amendments to the National Emission Standards for Hazardous Air Pollutants for stationary Reciprocating Internal Combustion Engines (RICE), the rulemaking schedule, and the Questions and Answers Document published in July 2012. The amendments were proposed on June 7, 2012. The meeting agenda is attached.
      
ATTENDEES

Bob Wayland, EPA
Lisa Beal, INGAA
Melanie King, EPA
Jim McCarthy, IES
Michael Horowitz, EPA (by phone)
Charles Wait, Energy Transfer
	
Agenda
Interstate Natural Gas Association of America and EPA
Meeting on RICE NESHAP Status and Implementation Q&A Document
12:30  -  1:00, Monday, November 19, 2012 

   1. RICE NESHAP Rulemaking Schedule Status (December 14, 2012 signature deadline)
         oo       Comments received and implications for schedule and final rule content
   2. INGAA Comments on Proposed Subpart ZZZZ
         oo       Any EPA questions on INGAA Comments?
         oo       INGAA comments 6 and 7 on emergency engines  -  operator defined procedures for maintenance tests and readiness testing; "deviation" from 100 hour operating limit. 
         oo       Potential for other minor technical corrections (INGAA comment 9)  -  several items listed, including SSMP, onsite records, ΔP measurements, etc. 
   3. EPA RICE NESHAP and NSPS Implementation Q&A Document
         oo       Potential for additional EPA revisions to the document  -  INGAA may provide comments and list additional items that could be added to facilitate implementation
         oo       Example INGAA issues:  
                 oo       INGAA August 9 comments did not address "onsite buildings" for remote engine definition.  Will this be addressed in Final Rule or in Q&A document?
                 oo       Q&A #21 and inconsistencies with typical CPMS programming for units complying with Subpart ZZZZ.
                 oo       Q&A #12 appears to conflict with §63.10(b) and minor rule revision may be warranted  -  see INGAA comment 9 regarding onsite records
                 oo       Several Q&A's related to ΔP measurement, and timing and approval process for catalyst replacement tests and temporary catalysts 
   4. Plans for any "next steps" (e.g., INGAA comments on Q&A document)
   
Planned INGAA Attendees 
Lisa Beal
Charles Wait (Energy Transfer)
Jim McCarthy (IES Inc.)





