# E C 

# / R Incorporated Providing Environmental Technical Support Since 1989

1 MEMORANDUM

TO: Bruce Moore

, EPA/OAQPS/SPPD/CCG

FROM: Bradley Nelson, EC/R, Inc.

DATE: November 30 , 201 1

SUBJECT: Summary of the November 29

, 20 11

, Meeting with the Gas Compressor

Association (GCA) and the U.S. Environmental Protection Agency to D iscuss the Proposed Oil & Gas NSPS/NESHAP

I. INTRODUCTION

The GCA requested this meeting with EPA to discuss questions on the proposed Oil and Gas NSPS (40 CFR Part 60, subparts KKK, LLL, and OOOO) and NESHAP (40 CFR Part 63, subpart s HH and HHH ). This meeting summary will be available in the docket for this rulemaking (Docket ID No. EPA

- HQ

- OAR

- 20 1 0

- 0 505 ). The proposed rule for the oil and natural gas sector wa s published in the Federal Register on August 23, 20 11 (7 6 FR 52738 ).

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency

Bruce Moore Greg Nizich

David Cozzie

Gas Compressor Association John Dutton, JW Power Kyle Jantzen, Exterran Erin Badough, Exterran Mike Wasson, Exterran, by phone Brad Johnson, Compressor Systems Inc., by phone

EC/R Incorporated

D avid Hendricks Bradley Nelson2

III. SUMMARY OF DISCUSSION

Bruce Moore opened the meeting by stating that the proposed rules are currently still in the comment period and EPA could answer clarifying questions from the group, but could not provide any responses to comments on the proposed rules.

The GCA stated that they planned to submit their formal comments on the proposed rules tomorrow, but wanted to discuss the se issues with E PA. The GCA is a trade organization that represents manufacturers of natural gas compression technologies. The compressor sy stem consists of an engine, a compressor package, and a cooler. They stated that Exterran, JW Power, and Compressor Systems Inc. make up approximately 80% of these manufactured compressor systems, which represents approximately 15,000 rental units in the upstream and midstream segments in the oil and gas industry.

EPA asked how many of the compressor systems in the oil and gas industry are rental and how many are purchased. The group replied that on average , there are 2 purchased compressor systems for every 1 rental compressor system.

The first item that was discussed was the definition of an affected facility. The GCA noted that the affected source definition in the proposed rules for compressors was different from other

EPA rules under the Clean Ai r Act (CAA). The GCA noted that in earlier rules, the affected date

for a new source was the date that the compressor was constructed . The GCA argued that the current language in the proposed rules would bring many existing units that have been relocated

. The GCA recommended removing the installation date from the definition of new sources and making the definition of affected source the same as the definition in the subpart JJJJ rules. EPA asked what is the equipment life of these compressors. The GCA responded that these engines typically operate for 20 years.

The second topic of discussion was the replacement intervals for reciprocating engine compressor rod packing. The GCA stated that these engines are not typically equipped with hour

meters and measuring the number of hours would be difficult. In addition, the reporting of annual hours of operation is burdensome. The GCA recommends a calendar approach for replacement of the rod packing every three years the compressor is deployed in the field

. EPA

stated that it wanted to require a rod packing replacement program that facilities were already doing and requested comment on measurement of rod packing emissions to determine if the packing should be replaced. EPA asked what are the current rod pac king replacement practices that are performed by the group. The GCA responded that they replace rod packing during engine overhauls which typically occur every five years.

The third topic of discussion was the proposed rule definition for pneumatic contr ollers. The GCA believes that EPA needs to clarify this definition to include only controllers that emit 6 standard cubic feet per hour (scf/hr) or greater. The GCA also stated that controllers that only use air and controllers used for low volatile orga nic compound (VOC) streams should be excluded from the requirements. The GCA also stated that the recordkeeping and reporting requirements for these devices is onerous and needs to exclude controllers emitting less than 6

scf/hr. The GCA also believes th at the high bleed flow rate used in EPA’s cost analysis is too3

high and the cost justification may be in error. The GCA asked what was the environmental benefit of reporting of low bleed controllers. EPA stated that a record of high bleed controller

re placement was needed for enforcement and compliance personnel. EPA asked if GCA had any suggestions for determining compliance. The GCA stated if only a record of high bleed devices was required then facilities would have incentive to replace high bleed controllers so that would

not have to maintain a record of the devices.

The next topic of discussion was the understanding that rotary screw compressors are not included in the proposed rules. The GCA stated that rotary screw compressors are not

centrifu gal compressors and therefore should not be regulated as centrifugal compressors. EPA

asked GCA to submit comments on this issue.

The fifth topic of discussion was the use of Natural Gas STAR data for developing costs and emission reductions from compres sors. The GCA stated that the Natural Gas STAR data does not reflect actual costs and operations of facilities. The GCA noted that periodic testing can cost roughly $5,000 just for traveling to remote sites. They believe that compressor rod packing

shou ld be based on a calendar year of operation. The industry has incentive to replace these items because of the loss of product and safety issues. EPA stated that they asked for comment on periodic testing of rod packing.

The last issue that was discussed was the definition of owner and operator. In the compressor rental business the owner would be the rental company, but the operator would be the company renting the compressor. Depending on the contract, maintenance may be required by the owner

and othe r times by the operator. The GCA believes that the proposed rules needed to be more clearly defined to take these issues into account. They believe if the rules are clearly defined the industry will self

- comply with the requirements.

EPA thanked the GCA for providing these issues and will review their submitted comments to respond to these issues. EPA stated that they did not want these regulations to deter energy production.