Summary of Meeting with API

Regarding the Final NSPS for CI Stationary RICE

February 12, 2007

Attendees

Jaime Pagán, EPA 				Stephanie Meadows, API

Robert Wayland, EPA 			Jeff Adams, BP

Michael Horowitz, EPA OGC 		John Wagner, API

Greg Fried, EPA (by phone)			Russ Frye, FryeLaw

Bradley Nelson, AGTI			Jeff Panick – IES (by phone)

Jenny Yang (by phone)			Janet Bounds (by phone)

Purpose of Meeting

	

The purpose of this meeting with the American Petroleum Institute (API)
was to discuss the main issues regarding the final new source
performance standards (NSPS) for stationary compression ignition (CI)
engines.

Summary of Meeting

	Michael Horowitz began the meeting by providing EPA’s preliminary
responses to the six main issues from the comments submitted by API on
the final NSPS for stationary CI engines.  The six main issue topics
are:

Manufacturer O&M requirements, 

Temporary replacement engines, 

Emission standards and testing requirements, 

Useful life term, 

NSPS exemptions, and 

Best demonstrated technology.  

A summary of the issues and discussions are provided in the following
sections.

Manufacturer O&M Requirements

	The API would like to remove the manufacturer operation and maintenance
(O&M) requirements, and allow owners/operators to use their own O&M
plan.  Michael stated that EPA has proposed adding an option that will
allow owners/operators to maintain their engines using maintenance
procedures that prevents engine deterioration and increased emissions. 
In addition engines greater than 200 horsepower (HP) would have to meet
the testing requirements for uncertified engines.  Jeff Adams stated
that British Petroleum (BP) already conducts engine integrity tests and
could be used as a surrogate for emissions testing.  The integrity tests
provide predictive emissions.  EPA asked for a list of the maintenance
protocols and Jeff Adams said he would check with the maintenance group
and will provide examples.  Michael indicated that EPA prefers emission
testing rather than surrogate monitoring.

Temporary Replacement Engines

	Michael stated that engines that are located at one place for 1 year
are considered stationary.  Jeff Adams asked for clarification in the
rule regarding engines left on-site seasonally.  Michael said that
language could be added to the preamble to address seasonal engines
on-site.  Janet Bounds asked for clarification with temporary generators
or pumps in Alaska.  Michael restated that engines that are located at a
facility for 1 year will be considered stationary.  EPA cannot provide
regulatory language to cover every scenario.  Robert Wayland stated that
EPA could add text to the preamble to clarify which engines are included
in the definition of mobile engines, which may help clarify some of
these issues.  Michael added that replacement engines will not be
required to meet NSPS requirements as long as mobile source requirements
are met.

Emission Standards and Testing Requirements

	Michael stated that 40 CFR section 60.4212 could be used for the in-use
emission testing requirements for stationary CI engines.  Jeff Adams
raised concerns with differences between certification bench testing,
and in-use portable analyzers results.  Michael stated that EPA has done
extensive testing with portable analyzers and that the data are
comparable.  EPA can provide the data to API if they request it.  Jeff
Panick asked if changes can be made to the engine and retest.  Michael
stated that if the engine fails, the owner/operator is obligated to get
the engine in compliance.

Useful Life

	EPA stated that it does not have any issues with the useful life term
and will continue to discuss this issue with API and the engine
manufacturers.  No decisions or changes have been made to the
regulations regarding this term.

NSPS Requirements

	EPA wants to regulate all stationary engines; however EPA will exempt
smaller engines from the NSPS requirements as long as those engines are
meeting mobile engine standards.  No size cutoff has been selected, but
it would be in the 50 to 100 HP size range.  EPA also stated that it is
comfortable with the definition of emergency engines.  Jeff Adams told
the group that the requirements for engines covered by both the NESHAP
and NSPS rules is confusing and requires clarification. 

Best Demonstrated Technology

	EPA believes that the final emission standards are appropriate and
achievable.  The use of particulate matter traps and selective catalytic
reduction are well demonstrated to meet the emission reductions for
stationary engines.

Other Issues

	Michael told the group that the settlement agreement requirements could
be met through changes to the preamble.  Jeff Adams asked if uncertified
engines would have to meet O&M requirements.  Michael stated that the
O&M requirements would be removed for uncertified engines.  Jeff Adams
noted that there was a 9-month period between when the rule becomes
effective and when certified engines are available.  EPA acknowledged
that this true, but cannot provide any alternatives.

Action Items

Jeff Adams will provide EPA with engine integrity data used in the
maintenance that show emission compliance for stationary engines.

EPA will provide portable emissions data studies by request.

 PAGE   

 PAGE   3 

