INGAA Emissions Data Collection: CO Emissions from Lean Burn Reciprocating Internal Combustion Engines

A rule to amend the Reciprocating Internal Combustion Engines (RICE) National Emission Standards for Hazardous Air Pollutants (NESHAP) was proposed on March 5, 2009. The proposed rule addresses standards for existing major source engines 500 horsepower (hp) and smaller and existing area source engines of all sizes. The Interstate Natural Gas Association of America (INGAA) is a trade association of the interstate natural gas transmission industry, and INGAA member companies operate stationary natural gas-fired spark ignition internal combustion (IC) engines. These engines are installed at compressor stations along the pipelines to transport natural gas to residential, commercial, industrial and electric utility customers. INGAA submitted comments on the proposed rule on June 3, 2009, and a primary concern was the basis of proposed emission standards for gas-fired IC engines. This concern was primarily due to deficiencies in the data used to establish emission standards for a regulation that will impact thousands of engines. These deficiencies include both a lack of emissions data and data quality issues. INGAA’s concerns are detailed in its comments, which are available in the rule docket (Docket Document No. EPA-HQ-OAR-2008-0708-0155). Assess the availability of emissions data for the three primary natural gas-fired IC engine subcategories: 2-stroke lean burn (2SLB), 4-stroke lean burn (4SLB), and 4 stroke rich burn (4SRB) engines; Collect available emissions data, including CO data for 2SLB and 4SLB engines and formaldehyde data for 4SRB engines;