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




MEMORANDUM   

DATE:		March 21, 2011

TO:		Melanie King, EPA OAQPS/SPPD/ESG

FROM:	Tanya Parise, EC/R, Inc.

SUBJECT:	Summary of the March 8, 2011 Teleconference with API Regarding Issues Related to the SI NSPS

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INTRODUCTION

      A teleconference was held between EPA and the American Petroleum Institute (API) to discuss issues related to the new source performance standards (NSPS) for stationary spark ignition (SI) engines, 40 CFR part 60, subpart JJJJ.  EPA proposed minor amendments 40 CFR part 60, subpart JJJJ along with amendments to 40 CFR part 60, subpart IIII on June 8, 2010 (75 FR 32612).  
      
ATTENDEES

Michael Horowitz, EPA
Matt Todd, API
Melanie King, EPA
Jeff Adams, BP
Tanya Parise, EC/R
Jeff Panek, IES

Tom Monahan, ExxonMobil

SUMMARY OF TELECONFERENCE 

	On March 10, 2010, API submitted a letter to EPA containing a list of issues related to the SI NSPS  and on December 21, 2010, EPA provided a response to API on these issues.  In addition, EPA provided a follow-up response to API on one additional issue on March 3, 2011.    	
	API asked what the status was of EPA's consideration of the Engine Manufacturers Association's (EMA) recommendation on the proposed definition of "installed."  EMA's specific recommendation was provided in EMA's comments on the proposed amendments (see pages 20-21 of EPA-HQ-OAR-2010-0295-0037).  EPA indicated that it is still contemplating the recommendations received on the proposed definition, but noted that it does not see a reason why EMA's suggestions would not be included in the final rule.  API indicated that it concurs with EMA's recommendation on the definition of "installed."
	
	API asked what other changes EPA is considering making to the SI NSPS.  EPA indicated that it will address the typographical errors in the mathematical symbols and other minor mistakes.  EPA said that it is not making any substantive changes to the SI NSPS at this time because any substantive changes to the rule would require notice and comment.  

	API requested that EPA consider making changes to the flowrate issue that is described on pages 8 and 9 of EPA's December 21, 2010 response letter.  API indicated that a flowrate measurement is not necessary when complying with a concentration-based standard and subsequently asked EPA to revise Table 2 in the SI NSPS to clarify that such measurement is not needed.  EPA noted API's concern regarding flowrate measurements and indicated it would discuss this issue internally.

	According to API, there is significant confusion surrounding the initial notification requirements, and asked if there was anything that EPA could do at this point, perhaps in the form of clarifying preamble language in the final rule.  Supposedly, there are double, triple and even quadruple notifications being submitted for the same engine, API said.  

	Regarding requirements related to load specifications, which are discussed in EPA's response letter, API expressed that it would be helpful to include language in the preamble clarifying the requirements according to EPA's responses in the letter. 

 	API asked if EPA would be willing to consider including concentration-based standards in the rule at this time for engines between 25 and 100 horsepower (HP).  EPA indicated it would consider adding concentration-based alternative standards, but that is a substantial change that would require notice and comment, EPA said.  

	API asked if EPA was considering adding any new definitions to the rule, for instance, a definition for "major repair."  EPA indicated that it did not believe so.  

	Finally, API explained that the State of Wyoming is urging the use of natural gas units on drill rigs.  According to API, however, natural gas engines above 300 HP suitable for drill rigs are not being produced by manufacturers.  Typically, drill rig engines are between 600 and 800 HP or 1,000 HP and above.  API asked that a provision be added to 40 CFR part 60, subpart JJJJ, allowing engines to elect to comply with 40 CFR part 60, subpart JJJJ instead of nonroad standards.  EPA noted API's concern, but indicated that such a request cannot be addressed under this rule because these are mobile source engines.  API expressed that it wanted EPA to be aware of this issue and that manufacturers are not going to be certifying engines for this service. 
