300 Stutes Rd.

Duson, LA 70529

Office: (337) 406-8028

Fax: (888) 241-9237

VIA ELECTRONIC EMAIL AND CERTIFIED MAIL

January 20, 2015

Ms. Gina McCarthy

Office of the Administrator

U.S. Environmental Protection Agency

Room 300

William Jefferson Clinton West Building

1200 Pennsylvania Ave., N.W.

Washington, D.C. 20460

Mccarthy.Gina@epa.gov

Re: EPA Docket No. EPA–HQ–OAR–2010–0505; FRL – 9921-03-OAR

Oil and Natural Gas Sector: Reconsideration New Source Performance Standards and National

Emission Standards for Hazardous Air Pollutants Reviews, 79 Fed. Reg. 79017 (Dec. 31, 2014)

PETITION FOR RECONSIDERATION

Dear Administrator McCarthy:

M-Squared Products & Services, Inc. / M-Squared is an environmental solutions company, with an 

emphasis on air emissions solutions. M-Squared has a proven track record of providing technology

solutions to oil and gas operating companies in the U.S. and Canada to help them meet their

environmental compliance objectives.

M-Squared respectfully submits the enclosed petition for reconsideration of EPA’s Final Rule, Oil and 

Natural Gas Sector: New Source Performance Standards and National Emission Standards for 

Hazardous Air Pollutants Reviews, 79 Fed. Reg. 79017 (Dec. 31, 2014). As explained in the enclosure,

the petition addresses a single issue – the failure to allow environmentally beneficial technology 

solutions that detect and measure reciprocating compressor rod packing vented emissions as an 

alternative to the operational standard that prescribes rod packing replacement frequency.

Thank you for your consideration of this petition. If you have any questions, please contact me at

(337) 501-8028, jmiguez@m-squaredinc.com or my partner Jonathan Mann at (337) 280-8977, 

jmann@m-squaredinc.com

Sincerely,

John P. Miguez Founder and Sr. Partner 

Enclosure: PLD Brochure

cc (by email): Bruce Moore, EPA

David Cozzie, EPA

Peter Tsirigotis, EPA

Jonathan Mann, M-Squared
BEFORE THE UNITED STATES ENVIRONMENTAL PROTECTION 

AGENCY

Oil and Natural Gas Sector: New Source )

Performance Standards and National Emission ) Docket No. EPA-HQ-OAR-2010-

0505 Standards for Hazardous Air Pollutants Reviews ) FRL-9921-03

79 Fed. Reg. 79017 (December 31, 2104) )

PETITION FOR RECONSIDERATION

Pursuant to Clean Air Act (CAA) section 307(d)(7)(B), 42 U.S.C. § 7607(d)(7)(B), and for the reasons 

set forth below, M-Squared Products & Services, Inc. petitions the Administrator of the United States 

Environmental Protection Agency (EPA) to reconsider specific provisions of its Final Rule, “Oil and 

Natural Gas Sector: New Source Performance Standards and National Emission Standards for 

Hazardous Air Pollutants Reviews,” 79 Fed. Reg. 79017 (December 31, 2104) (Final Rule). The Final

Rule includes amendments to existing National Emission Standards for Hazardous Air Pollutants 

(NESHAPs) for oil and gas operations, and new Standards of Performance for Crude Oil and Natural

Gas Production, Transmission and Distribution (40 CFR, Part 60, Subpart OOOO).

This petition is associated with Subpart OOOO of the Final Rule and related to a single item in the rule.

That issue, related to the CAA section 111 standard for reciprocating compressors, significantly impacts

the outcome of the rulemaking, and reconsideration should be granted. Because we anticipate that 

further technical discussion may be warranted, we welcome the opportunity to meet with EPA personnel 

to discuss our concerns.

Subpart OOOO requires operators of affected reciprocating compressors to replace rod packing seals 

every 26,000 operating hours or 36 calendar months. The Amended Rule (Dec 31, 2014) is based solely 

on this operational standard and precludes alternatives with one exception. The EPA granted REM

Technology Inc.’s proposal to route reciprocating compressor vented emissions to a “combustion device” 

(i.e., in this case an engine), to provide emission reductions as an alternative to changing packing on a 

time schedule.

M-Squared is filing this petition to request that the EPA consider a fourth alternative to the Subpart 

OOOO operational standard for reciprocating compressors. M-Squared believes the Final Rule 

reciprocating compressor standard is unnecessarily limiting and excludes a simple but viable, proven

alternative. The EPA already allows engine operators to choose between changing oil at a prescribed 

number of hours or using an approved oil analysis program.2 The EPA has recognized the limitation 

imposed in its original ruling by allowing the REM Technology control method. However, neither of 

the two solutions allow the operator to know when and by how much a compressor’s packing is 

leaking.

___________________________________________________________________________________

1 77 FR 49494

2 Table 2c to Subpart ZZZZ of Part 63—Requirements for Existing Compression Ignition Stationary RICE Located at 

a Major Source of HAP Emissions and Existing Spark Ignition Stationary RICE ≤500 HP Located at a Major Source 

of HAP Emissions “Sources have the option to utilize an oil analysis program as described in §63.6625(i) or (j) 

in order to extend the specified oil change requirement in Table 2c of this subpart.”

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M-Squared’s Packing Leak Detector ® is an inexpensive, available alternative that would reduce

reciprocating compressor emissions to levels equivalent to, or better than, the emission levels achieved by

the operational standard. It would also save producers’ and operators’ money by cutting down on lost 

gas production and help the environment by reducing methane emission into the atmosphere.

The following explains the basis of this reconsideration request:

• In April of 2011, John Miguez of M-Squared Products & Services, Inc., attended the EPA Natural 

Gas Star Conference in Denver, CO. He also attended the conference held in Austin, TX during May 

of 2013. At both meetings he met with Mr. Roger Fernandez and Mr. Jerome Blackwell with the 

EPA’s Natural Gas Star Program and discussed the M-Squared Packing Leak Detector® (PLD) and

how it could help cut down on the amount and duration of packing leaks. 

• June of 2013 M-Squared spoke with Louisiana Sen. David Vitter via a phone conference where he 

was introduced to the PLD and its implications to the environment. He put us in touch with Dr. 

Michael Moore of the EPA’s Dallas office, and through Dr. Moore we were introduced to Mr. 

Bruce Moore, with whom we had a telephone conference concerning the PLD.

• M-Squared also spoke with Senator Mary Landrieu’s office about the benefits of the PLD. She in 

turn wrote a letter to the EPA’s director recommending the PLD.

• At a workshop on July 23, 2008, the EPA’s Natural Gas STAR Program presented data from a 1999 

PRCI report which showed that new compressor packing could leak as much as 60 ft3

/hour, and worn 

packing as much as 900 ft3

/hour, with the average running compressor leaking 99 ft3/hour.3 In the 

same EPA presentation, it was suggested that operators use an Economic Replacement Point to 

determine packing replacement in order to save the operator money in lost production and the 

environment in methane escaping into the atmosphere. 

• A recent EPA study published in April of 2013 estimates that natural gas compression in the pipeline 

and production/storage sectors release over 67.7 Billion Standard Cubic Feet of Methane into the 

atmosphere each day due to leaks. Packing leaks account for approximately 26.7 Billion to 37.6 

Billion Standard Cubic Feet of the 67.7 BCF of Methane. The more recent EPA’s white paper4 on the 

O&G sectors (April 2014) estimated a savings of 3.6 BCF (74,934 tons) of methane if rod packing 

was replaced on a timely basis. From the same report it can be estimated that the average annual 

methane loss per compressor could be cut by 13.82 tons/compressor-year.

• While the EPA assumes compressor packing will last three years, this is not always the case. Newly 

installed packing and/or packing cases have been known to leak, because the piston rod is too smooth, 

or the packing was the wrong type for the application, or it was installed incorrectly. Packing case or 

rods which are beyond their useful life or damaged can also leak before the three year period. In all of

the situations stated above, the packing can start leaking much sooner than three years. The PLD 

identifies immediately whether new or old packing is leaking. For the first time, with the PLD, a 

“Real-Time Baseline” can be established to identify and quantify any new packing seepage and set 

unacceptable packing leaking levels.

3 EPA Presentation Lessons Learned: Reducing Methane Emissions from Compressor Rod Packing Systems, October 2006 

4 Report for Oil and Natural Gas Sector Compressors Review Panel April 2014 Prepared by U.S. EPA Office of Air Quality 

Planning and Standards (OAQPS)

Page 2 of 3
• Most of these leaks continue for weeks or months because the operators have no easy and inexpensive 

way of telling the compressor packing is leaking. Consequently, the leak continues until it reaches a 

point where it is obvious to the operator. At this time, the packing can possibly have been leaking for 

months. M-Squared’s Packing Leak Detector® (PLD) is an inexpensive device that will tell the 

operator when his packing is leaking and give him an approximate amount of the leakage. This will 

provide him the “Real-Time Baseline” from which to determine the economic loss from leakage and 

allow him to change the packing before it becomes excessive and economically unfeasible.

• By having the knowledge of which packing case is leaking and by how much it is leaking, the 

operator and/or producer can determine the Economic Replacement Point, the point at which the 

packing should be changed.

• Having this knowledge of when packing is leaking, rather than using a set time limit, will not only 

help the operator save on the lost production that he is venting or flaring (while the RTI recapturing 

and consuming the leaking gas in an engine is a worthwhile method, it is limited by cost and only 

works for specific applications) it will also help limit the methane escaping into the atmosphere. 

• Lastly, the Packing Leak Detector® (PLD) is inexpensive and simple to use. There are other 

measuring devices available that could also be used. An operator using such a device will be 

prepared for the day, if and when, packing leaks must be measured and reported.

• Failing to provide the PLD and other similar detecting devices as a recommended option puts 

operators and the environment at a disadvantage. It has been shown that “condition based

maintenance” can extend the life of rod packing beyond the 26,000 hour life prescribed in the

Final Rule. However, with a mandate to replace rod packing, operators have less incentive to

install technology, such as the PLD technology, that continuously detects, measures, and 

quantifies rod packing emissions while also offering economic, environmental, and operational 

advantages.

M-Squared formally petitions that the language in Subpart OOOO be changed to allow the use of a 

packing leak measuring devices, such as the Packing Leak Detector® (PLD) as a fourth alternative.

M-Squared strongly believes that this record supports the assertion that the Final Rule failed to

adequately consider optional alternatives to the reciprocating compressor operational standard, and thus it 

would be in the best interest of all to add packing leak detection. 

In conclusion, M-Squared Products & Services, Inc., urges the EPA to reconsider the Final Rule and 

promulgate revisions consistent with the arguments in this Petition.

Respectfully submitted,

John P. Miguez 

Founder & Sr. Partner 

M-Squared P&S, Inc. 

300 Stutes Rd.

Duson, LA 70529

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