EC

/R Incorporated Providing Environmental Technical Support Since 1989

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MEMORANDUM 

TO: Melanie King, EPA OAQPS/SPPD/ESG 

FROM: Bradley Nelson, EC/R, Inc. 

DATE: August 28, 2009 

SUBJECT: Summary of the May 20, 2009 Meeting in Research Triangle Park, NC with 

Exterran and the U.S. Environmental Protection Agency to discuss the Proposed 

NESHAP for Existing Stationary RICE 

1.0 INTRODUCTION 

Exterran requested this meeting with EPA to discuss the proposed national emission 

standards for hazardous air pollutants (NESHAP) for existing stationary reciprocating internal 

combustion engines (RICE). Also at this meeting were representatives from Compressor 

Systems, Inc. and J-W Power Company, and their legal counsel from the law firm of Bracewell 

& Giuliani. Exterran, J-W Power, and Compressor Systems, Inc. are the three largest operators 

of contract compression to the U.S. oil and gas industry. The companies estimate that contract 

compression comprises approximately one-third of the compression in the oil and gas industry. 

This meeting summary will be available in the docket for this rulemaking (Docket ID No. EPAHQ-OAR-2008-0708). The proposed NESHAP for existing stationary RICE was published in 

the Federal Register on March 5, 2009 (74 FR 9698). 

2.0 ATTENDEES 

U.S. Environmental Protection Agency

Bob Wayland, OAQPS/SPPD/ESG 

Penny Lassiter, OAQPS/SPPD 

Jaime Pagán, OAQPS/SPPD/ESG 

Melanie King, OAQPS/SPPD/ESG 

Michael Horowitz, OGC (by phone) 

Larry Sorrels, OAQPS/HEID/ABCG 
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Exterran

Jack Maley 

Gerald Meinecke 

Donald Wayne 

Bracewell & Giuliani

Jeff Holmstead 

Rebecca Rentz 

Richard Alonso 

J-W Power Co.

John Dutton 

Don Bizzell 

Compressor Systems, Inc.

Tim Knox 

Gary George 

Levent Caglar 

EC/R Incorporated

Bradley Nelson 

3.0 SUMMARY OF MEETING 

The companies provided a handout presentation summarizing the issues that they wanted 

to discuss with EPA. A copy of the presentation is included in Attachment 1 of these meeting 

minutes. 

The first issue discussed was the recommendation for a rural subcategory for existing 

rural spark ignition (SI) RICE less than 500 HP. The representatives from the contract 

compression companies stated that rural RICE are typically small rich-burn engines located at 

unmanned sites. The representatives also stated that they believe the formaldehyde emission 

factors that were used by EPA to estimate formaldehyde emissions from rich-burn engines 

overestimate emissions by a factor of four. They noted that EPA used the same emission factor 

for all SI engines, which also includes lean-burn engines. EPA asked for test data for these 

engines for inclusion into the emission factor calculation. 

The next issue that was discussed was the startup, shutdown, and malfunction (SSM) 

requirements that are included in the proposed rule. The industry representatives at the meeting 

believed that there is not enough data to support the proposed SSM requirements. The 
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representatives stated that their engines operate 95-98 percent of the time, and only have 2-3 

startups per month. The industry representatives also stated that if a malfunction occurs, the 

engines have controls in place that immediately shut down the engine. This protects the engine 

from further damage caused by the malfunction. 

The next issue that was discussed was management practices. The industry 

representatives at the meeting believed that the proposed management practices that require 

periodic oil changes and spark plug replacements are not appropriate for their engines. Industry 

was of the opinion that because their engines operate continuously, the proposed management 

practices would increase maintenance costs without providing any environmental benefit. In 

addition, the industry representatives stated they already have a strict management practices 

program in place to protect their investments. 

The next issue that was discussed was the control costs estimates that EPA used to 

estimate the cost of the proposed rule. The industry representatives present at the meeting 

believed that the capital cost of non-selective catalytic reduction for smaller engines is too high 

and can provide specific examples to show this. Exterran estimated the cost per ton of HAP 

reduced to be greater than $50,000 for rich-burn engines between 175 and 299 HP. Industry also 

believed that costs for performing compliance tests were not included in the annual cost 

calculation. 

The industry representatives asked EPA if there was a chance of extending the deadline 

for issuing the final rule. Industry stated they will need additional time to gather test data, 

especially data for the SSM requirements. EPA pointed out that it may be difficult to extend the 

deadline for the final rule and asked the representatives how much data could be provided 

between now and October 1, 2009. The representatives responded that they can provide some 

data, but will need additional time to gather data for SSM. EPA asked the group to point out the 

data deficiencies in their comments, and provide an estimate of the time required to gather 

additional test data to address these deficiencies. 

 
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Attachment 1 

Handout Provided by Exterran at Meeting with EPA 

May 20, 2009