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/R Incorporated Providing Environmental Technical Support Since 1989

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MEMORANDUM 

TO: Bruce Moore, EPA/OAQPS/SPPD/CCG

FROM: Bradley Nelson, EC/R, Inc.

DATE: November 30, 2011

SUBJECT: Summary of the November 29, 2011, Meeting with the Gas Compressor 

Association (GCA) and the U.S. Environmental Protection Agency to Discuss 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, 

subparts HH and HHH). This meeting summary will be available in the docket for this 

rulemaking (Docket ID No. EPA-HQ-OAR-2010-0505). The proposed rule for the oil and 

natural gas sector was published in the Federal Register on August 23, 2011 (76 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

David Hendricks

Bradley Nelson 
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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 these issues with EPA. The GCA is a trade organization that 

represents manufacturers of natural gas compression technologies. The compressor system 

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 Air 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 packing 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 controllers. 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 organic 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 that the high bleed flow rate used in EPA’s cost analysis is too 
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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 

replacement 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 

centrifugal 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 compressors. 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 

should 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 other 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.