National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Legacy Docket ID #: A-95-35

The American Petroleum Institute (API) is pleased to have the opportunity to submit the following comments on EPA’s proposed national emission standards for hazardous air pollutants (NESHAP) for stationary reciprocating internal combustion engines (RICE). The proposed regulation of major sources of hazardous air pollutants (HAP) is intended to reflect the application of the maximum achievable control technology (MACT) for RICE. API represents more than 400 member companies involved in all aspects of the oil and natural gas industry. API members are subject to the regulations as proposed, and therefore are strongly interested in this rulemaking. API member companies have been working with the U.S. EPA Office of Air Quality Planning and Standards (OAQPS) since 1996 with regards to the combustion MACT standards. Representatives from API member companies served on the Federal Advisory Committee, known as the Coordinating Committee, which was established for the Industrial Combustion Coordinated Rulemaking (ICCR), as well as the Work Groups for Internal Combustion Engines. API’s comments support aspects of EPA’s RICE MACT proposal, as well as identify concerns which require additional attention by the agency. The concerns are grouped in the following major issues: ?Emission Limitations ?Initial Performance & On-going Compliance Testing / Monitoring ?Affected Source Definition and Exemptions API supports EPA setting a “no control” floor and exemptions for existing RICE units. We object, however, to several specifics as currently outlined in the proposed rule. In addition to the support and major issues raised in the attached comments, please find information on technical corrections and certain other issues we noticed during the review of this proposal. Contact information is included in the comments.