EC

/R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Drive, Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919)484-0222  Fax: (919) 484-0122

MEMORANDUM

DATE: August 1, 2013

SUBJECT: Combustor Supply and Demand Analysis

FROM: Heather Brown, EC/R Incorporated

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

The purpose of this memorandum is to provide an estimate of the current and future supply of 

available combustors that may be used to reduce volatile organic compound (VOC) emissions 

from new storage vessels and the demand for combustors created by the new source performance 

standards (NSPS) for the oil and natural gas sector (40 CFR part 60, subpart OOOO), as well as 

state, local and tribal regulations.

On April 12, 2013, the U. S. Environmental Protection Agency (EPA) proposed amendments to 

the Oil and Natural Gas Sector NSPS (subpart OOOO) to address reconsideration of certain 

provisions of subpart OOOO. In the preamble to the proposed action, the EPA expressed its 

concern regarding the available supply of combustors by October 15, 2013, the first compliance 

date in the final subpart OOOO (78 FR 22130). Therefore, to alleviate these concerns, the EPA 

established, in the proposal, two groups of storage vessels with staggered compliance dates: (1) 

Group 1 storage vessels, defined as those storage vessels for which construction, modification, or 

reconstruction commenced after August 23, 2011 and on or before April 12, 2013; and (2) Group 

2 storage vessels, defined as those storage vessels for which construction, modification, or 

reconstruction commenced after April 12, 2013. To respond to comments on its rationale for 

establishing these storage vessel groups and their staggered compliance dates, the EPA further 

evaluated the availability of combustors and the expected combustor demand.

COMBUSTOR SUPPLY ANALYSIS

In the proposed action the EPA relied on information provided by the industry, which was based 

on a survey of six manufacturers.1 According to the survey, these six manufacturers could 

produce 3,680 combustors annually. To address comments on the proposed amendments, the 

EPA contacted several manufacturers to confirm their theoretical production capacity and 

understand what, if any, their plans were in the future to expand. Table 1 presents the results of 

this survey. As shown in Table 1, the current combustor capacity appears to be approximately

28,285 combustors per year, or about 2,199 per month. It was assumed that manufacturers would 

increase their capacity after August of 2013, which is the anticipated publication date of the final 

amendments (and corresponds to the month ABUTEC, LLC indicated that they would be 

operating at their increased capacity). The manufacturing capacity was determined to increase to 

about 39,430 per year, or about 3,284 per month.
2

Table 1. Results of Combustor Manufacturer Survey

Combustor 

Manufacturer

Included 

in API 

Estimate?

Current Combustor 

Capacity

Expected 

Combustor 

Capacitya

Monthly Annual Monthly Annual Reference

JW Williamsb,c Yes 51 613 107 1,288 1, 2

Cameronb Yes 51 613 107 1,288 1

Pescob Yes 51 613 107 1,288 1

TCIb

,c Yes 51 613 107 1,288 1, 3

John Zinkb Yes 51 613 107 1,288 1

Leedb Yes 51 613 107 1,288 1

MRW Technologiesd No 76 913 91 1,095 4

Calliduse No 78 933 171 2,047

Abutecf No 150 1,800 450 5,400 5

Cimmeron No 167 2,000 350 4,200 6

COMM Engineeringg No 1,422 17,064 1,580 18,960 7

Total 2,199 26,388 3,284 39,430

NOTE: Slight discrepancies are due to rounding.

a Expected capacity calculated as average of the increase in capacities provided by ABUTEC and MRW 

Technologies. Assumed to be effective August 2013, corresponding to the date ABUTEC expects to be operating at 

their increased capacity.

b For the six manufacturers included in the original survey provided by API (See Reference 1), the total combustor 

capacity of 3,860 combustors per year was divided evenly among each manufacturer (i.e., 613 per manufacturer). c Capacities for JW Williams and TCI were confirmed to be no greater than 613 per year (See References 2 and 3). d Estimate provided by manufacturer was 2 to 3 combustors per day. Therefore, the current capacity represents the 

midpoint of that range, extrapolated to an annual value. Expected capacity was assumed to be represented by the 

upper end of that range, extrapolated to an annual value (See Reference 4). e We were unable to establish contact with this manufacturer. Current and expected capacity was calculated as the 

average of all other manufacturers (excluding COMM Engineering, as the outlier). f ABUTEC LLC provided an estimate for the current capacity of 150 combustors per month and indicated that their 

production capacity would increase to 450 per month by August 2013. g COMM Engineering provided information indicating that their current combustor manufacturing as applied to the 

oil and natural gas sector comprises about 90 to 95 percent of their business. However, they also have the ability to 

ramp up production as needed. Therefore, current capacity was assumed to be represented by 90 percent of the 

maximum number provided (i.e., 90 percent of 18,960 combustors per year) and expected capacity was estimated to 

be equal to 18,960.
3

COMBUSTOR DEMAND UNDER AUGUST 2012, FINAL NSPS

To illustrate the necessity for a staggered compliance date, the demand for combustors under the 

August 2012, final NSPS was analyzed. The following assumptions were made for this analysis:

• Owners and operators of storage vessel affected facilities would most likely begin to 

install control devices no earlier than the publication date of the original NSPS (i.e., 

August 16, 2012) because of their uncertainty in what changes may be made between the 

proposed and final rules.

• The expanded capacity becomes effective in August 2013, corresponding to the 

timeframe under which ABUTEC, LLC indicated their expansion would be complete.5

• Demand includes the storage vessels installed each month that are subject to State 

regulations.

• Demand calculated on a monthly basis assuming equal distribution through the year.

The population of storage vessels with uncontrolled emissions greater than 6 tpy (i.e., those that 

would be affected facilities) was estimated in a previous memorandum.8 Table 2 summarizes the 

estimated number of storage vessels affected facilities predicted to be installed between 

August 23, 2011, and December 31, 2015.

Table 2. Number of Oil and Condensate Storage Vessels Affected Facilities Projected 

to be Installed between August 23, 2011, and December 31, 2015

Year

Number of Oil and 

Condensate Storage 

Vessels Subject to 

State Regulations

Number of Oil 

and Condensate 

Storage Vessels 

Subject to NSPS

2011 3,386 4,431

2012 8,727 11,319

2013 8,298 11,566

2014 9,443 12,568

2015a 10,224 13,395

Total 40,078 53,279 a NOTE: The number of tanks presented in this table differs slightly 

from the number of tanks presented in Reference 8 for the year 2015. 

This table presents the number of tanks projected to be installed in all 

of 2015, rather than up to October 15, 2015. 

Using the number of tanks per year presented in Table 2 and the assumptions listed above, the 

average number of storage vessels installed per month were estimated and then translated to the 

number of control devices that would be needed per month. Table 3 presents the monthly 

demand for combustors installed to control emissions from storage vessels subject to State 

regulations as well as the NSPS. Figure 1 illustrates the relationship between the theoretical 

monthly combustor supply from Table 2 and the monthly combustor demand from Table 3. As 

shown in Figure 1, the theoretical supply for each month is slightly lower than the demand for 

the first 12 months or so after the publication of the final NSPS. Just before October 15, 2013,
4

Table 3. Combustor Demand for Compliance with August 16, 2012, NSPS

Year Month

Number of Storage 

Vessels installed per 

Month Subject to 

State Regulationsa,b

Number of Storage 

Vessels Installed per 

Month subject to 

NSPSa

,b

Number of 

Control Devices 

needed per 

Monthc,d

2011 August 233 304 233

September 788 1032 788

October 788 1032 788

November 788 1032 788

December 788 1032 788

2012 January 727 943 727

February 727 943 727

March 727 943 727

April 727 943 727

May 727 943 727

June 727 943 727

July 727 943 727

August 727 943 1,590

September 727 943 2,484

October 727 943 2,511

November 727 943 2,484

December 727 943 2,511

2013 January 692 964 2,496

February 692 964 2,414

March 692 964 2,496

April 692 964 2,469

May 692 964 2,496

June 692 964 2,469

July 692 964 2,496

a Calculated by evenly distributing the number of storage vessels installed each year (see Table 2) across each 

month.

b The total number of storage vessels installed in 2011 between August 23, 2011, and December 31, 2011 was 

apportioned each month by first determining the number of storage vessels installed in August (between the 23rd and 

31st) and dividing the remaining number evenly between September through December. c The final subpart OOOO standards were published on August 16, 2012. It was assumed that storage vessels 

installed between August 23, 2011, and August 16, 2012 did not install controls until after August 16, 2012, because 

of the uncertainty in what changes may be made between the proposed and final rules. Therefore, between August 

23, 2011, and August 16, 2012, only storage vessels subject to state regulations were included in the demand for 

combustors. d There are 11,521 oil and condensate storage vessels estimated to be installed from August 23, 2011 through 

August 16, 2012 [the sum of the number of storage vessels subject to the NSPS installed each month from August 

2011 through July 2012, plus 52 percent (i.e., 16 out of 31 days in August) of the number of storage vessels subject 

to the NSPS installed in August 2012], or about 27 per day. These storage vessels are assumed to install control 

devices between August 16, 2012, and October 15, 2013, distributed evenly throughout the 425 days.
Table 3 (continued)

5

Year Month

Number of Storage 

Vessels installed per 

Month Subject to 

State Regulationsa,b

Number of Storage 

Vessels Installed per 

Month subject to 

NSPSa

,b

Number of 

Control Devices 

needed per 

Monthc,d

August 692 964 2,496

September 692 964 2,469

October 692 964 2,062

November 692 964 1,655

December 692 964 1,655

2014 January 787 1047 1,834

February 787 1047 1,834

March 787 1047 1,834

April 787 1047 1,834

May 787 1047 1,834

June 787 1047 1,834

July 787 1047 1,834

August 787 1047 1,834

September 787 1047 1,834

October 787 1047 1,834

November 787 1047 1,834

December 787 1047 1,834

2015 January 852 1116 1,968

February 852 1116 1,968

March 852 1116 1,968

April 852 1116 1,968

May 852 1116 1,968

June 852 1116 1,968

July 852 1116 1,968

August 852 1116 1,968

September 852 1116 1,968

October 852 1116 1,968

November 852 1116 1,968

December 852 1116 1,968

NOTE: Slight discrepancies are due to rounding.
6

0

500

1,000

1,500

2,000

2,500

3,000

3,500

Aug 16, 2012

2013

Oct 15, 2013

20142015

Number of Combustors

Year

Figure 1. Theoretical Combustor Supply and Demand for August 16, 2012 NSPS

THEORETICAL Number of Combustors Available per Month Number of Combustors Needed per Month
7

the theoretical combustor supply then becomes adequate for control of oil and condensate 

storage vessels. This indicates a potential issue with the availability of combustors based on the 

final NSPS. It should be noted that while the supply illustrated in Figure 1 is much higher than 

the demand just before October 15, 2013, it was assumed that since most of the combustor 

manufacturers build these units as they are ordered, there is not likely to be a stockpile of 

combustors available to be installed at any time.

COMBUSTOR DEMAND USING GROUP 1 AND GROUP 2 STORAGE VESSELS 

DESIGNATIONS

In the April 2013 proposed amendments, the EPA defined storage vessels installed after August 

23, 2011, and on or before April 12, 2013, as Group 1 storage vessels. Group 2 storage vessels 

are defined as those installed after April 12, 2013. Under the final amendments, Group 2 storage 

vessels affected facilities are required to install controls no later than April 15, 2014. Two 

compliance dates for Group 1 storage vessels were evaluated: (1) compliance date of April 15, 

2015; and (2) compliance date of April 15, 2014, which corresponds to the Group 2 storage 

vessel compliance date. The supply and demand was reanalyzed to determine whether the shortterm combustor supply would be sufficient to control all storage vessels being installed. Under 

both options, it was assumed that owners and operators would install combustors to control the 

population of Group 1 storage vessel affected facilities beginning on October 15, 2013 (the date 

by which the final amendments require the determination of the affected facility status), and that 

installation of control devices would be evenly distributed over the period from October 15, 2013 

to the April 15, 2014 and April 15, 2015 compliance dates. It was also assumed that Group 2 

storage vessel affected facilities would begin installing controls in August 2013 (after publication 

of the final amendments, assumed for the purposes of this analysis to be August 15th). Table 4 

presents the combustor demand for Group 2 storage vessels, both compliance options for 

Group 1 storage vessels, as well as those combustors installed to comply with State regulations.

Figure 2 illustrates the relationship between the two compliance date options as compared to the 

theoretical combustor supply.

As shown in Figure 2, with an April 15, 2014 compliance date for Group 1 and Group 2 storage 

vessels, after April 15, 2014, the supply significantly exceeds the demand. However, during the 

period from October 15, 2013, through April 15, 2014, the supply of control devices was 

significantly less than the demand. This supply deficiency appears to be alleviated under the 

second option, with a compliance date of April 15, 2015, for Group 1 storage vessels. As shown 

in Figure 2, the supply was either slightly less than demand or approximately equal to the 

demand for the period from August 2013 to April 15, 2014. The supply of control devices was 

somewhat greater than demand (by about 200-500 units) for the period between April 15, 2014, 

and April 15, 2015. After April 15, 2015, the supply significantly exceeds demand.
8

Table 4. Combustor Demand for Group 2 Storage Vessels with Compliance Date Options for Group 1 Storage Vessels

Year* Month

Number of Storage Vessels

Number of Combustors (with 

Group 1 Compliance Date of 

4/15/15)a

Number of Combustors (with 

Group 1 Compliance Date of 

4/15/14)

b

Installed per 

Month Subject 

to State 

Regulationsc,d

Installed 

per Month 

subject to 

NSPSn

,o

Installed on 

Group 2 

Storage 

Vesselse

Installed on 

Group 1 

Storage 

Vessels

Total 

Needed 

per 

month

Installed on 

Group 2 

Storage 

Vesselsp

Installed on 

Group 1 

Storage 

Vessels

Total 

Needed 

per 

month

2011 August 233 304 233 233

September 788 1032 788 788

October 788 1032 788 788

November 788 1032 788 788

December 788 1032 788 788

2012 January 727 943 727 727

February 727 943 727 727

March 727 943 727 727

April 727 943 727 727

May 727 943 727 727

June 727 943 727 727

July 727 943 727 727

a Group 1 storage vessels are defined as those that are installed after August 23, 2011, and on or before April 12, 2013. The final amendments require owners and 

operators to determine the affected facility status no later than October 15, 2013. Therefore it was assumed that owners and operators would begin installing 

combustors on October 15, 2013. There are 19,027 Group 1 storage vessels expected to be installed. Therefore the number of combustors estimated to be 

installed on these Group 1 storage vessels was distributed evenly between October 15, 2013, and April 15, 2015.

b The number of combustors estimated to be installed on these Group 1 storage vessels was distributed evenly between October 15, 2013, and April 15, 2014. c Calculated by evenly distributing the number of storage vessels installed each year (see Table 2) across each month.

d The total number of storage vessels installed in 2011 between August 23, 2011, and December 31, 2011 was apportioned each month by first determining the 

number of storage vessels installed in August (between the 23rd and 31st) and dividing the remaining number evenly between September through December. e Group 2 storage vessels are defined as those that are installed after April 12, 2013. It was assumed that owners and operators of Group 2 storage vessels would 

begin installing combustors after the publication date of the final amendments (assumed for this analysis to be August 15, 2013). There are 11,955 Group 2 

storage vessel affected facilities expected to be installed between April 12, 2013 and April 15, 2014 (the compliance date in the final amendments for Group 2 

storage vessels).
Table 4 (continued)

9

Year* Month

Number of Storage Vessels

Number of Combustors (with 

Group 1 Compliance Date of 

4/15/15)a

Number of Combustors (with 

Group 1 Compliance Date of 

4/15/14)

b

Installed per 

Month Subject 

to State 

Regulationsc,d

Installed 

per Month 

subject to 

NSPSn

,o

Installed on 

Group 2 

Storage 

Vesselse

Installed on 

Group 1 

Storage 

Vessels

Total 

Needed 

per 

month

Installed on 

Group 2 

Storage 

Vesselsp

Installed on 

Group 1 

Storage 

Vessels

Total 

Needed 

per 

month

August 727 943 727 727

September 727 943 727 727

October 727 943 727 727

November 727 943 727 727

December 727 943 727 727

2013 January 692 964 692 692

February 692 964 692 692

March 692 964 692 692

April 692 964 692 692

May 692 964 692 692

June 692 964 692 692

July 692 964 692 692

August 692 964 787 1,479 787 1,479

September 692 964 1,490 2,181 1,490 2,181

October 692 964 1,490 590 2,772 1,490 1,748 3,930

November 692 964 1,490 1,042 3,235 1,490 3,583 5,765

December 692 964 1,490 1,076 3,235 1,490 3,583 5,765

2014 January 787 1047 1,490 1,076 3,331 1,490 3,583 5,860

February 787 1047 1,490 972 3,331 1,490 3,583 5,860

March 787 1047 1,490 1,076 3,331 1,490 3,583 5,860

April 787 1047 1,262 1,042 3,102 1,262 1,543 3,591

May 787 1047 1,047 1,076 2,888 1,047 1,834
Table 4 (continued)

10

Year* Month

Number of Storage Vessels

Number of Combustors (with 

Group 1 Compliance Date of 

4/15/15)a

Number of Combustors (with 

Group 1 Compliance Date of 

4/15/14)

b

Installed per 

Month Subject 

to State 

Regulationsc,d

Installed 

per Month 

subject to 

NSPSn

,o

Installed on 

Group 2 

Storage 

Vesselse

Installed on 

Group 1 

Storage 

Vessels

Total 

Needed 

per 

month

Installed on 

Group 2 

Storage 

Vesselsp

Installed on 

Group 1 

Storage 

Vessels

Total 

Needed 

per 

month

June 787 1047 1,047 1,042 2,888 1,047 1,834

July 787 1047 1,047 1,076 2,888 1,047 1,834

August 787 1047 1,047 1,076 2,888 1,047 1,834

September 787 1047 1,047 1,042 2,888 1,047 1,834

October 787 1047 1,047 1,076 2,888 1,047 1,834

November 787 1047 1,047 1,042 2,888 1,047 1,834

December 787 1047 1,047 1,076 2,888 1,047 1,834

2015 January 852 1116 1,116 1,076 3,022 1,116 1,968

February 852 1116 1,116 972 3,022 1,116 1,968

March 852 1116 1,116 1,076 3,022 1,116 1,968

April 852 1116 1,116 521 2,489 1,116 1,968

May 852 1116 1,116 1,968 1,116 1,968

June 852 1116 1,116 1,968 1,116 1,968

July 852 1116 1,116 1,968 1,116 1,968

August 852 1116 1,116 1,968 1,116 1,968

September 852 1116 1,116 1,968 1,116 1,968

October 852 1116 1,116 1,968 1,116 1,968

November 852 1116 1,116 1,968 1,116 1,968

December 852 1116 1,116 1,968 1,116 1,968

NOTE: Slight discrepancies are due to rounding.
Table 4 (continued)

11

0

1,000

2,000

3,000

4,000

5,000

6,000

Aug 16, 2012

2013

Aug 15, 2013

Oct 15, 2013

2014

Apr 15, 2014

2015

15-Apr-15

Number of Combustors

Year

Figure 2. Theoretical Supply and Demand for NSPS-1 (Compliance Date Options for 

Group 1 Storage Vessels)

THEORETICAL Number of

control devices available

per month

Number of Control

Devices needed per

month (Group 1

Compliance Date of

4/15/15)

Number of Control

Devices needed per

month (Group 1

Compliance Date of

4/15/14)
12

REFERENCES

1. American Petroleum Institute. Oil and Gas NSPS and NESHAP. Presentation to the 

Office of Management and Budget. March 22, 2012. Docket No. EPA-HQ-OAR-2010-

0505-4520.

2. Telecon. Brown, H., EC/R Incorporated with G. Adams, JW Williams. June 13, 2013 

(See Attachment 1).

3. Telecon. Brown, H., EC/R Incorporated with T. Mark, TCI. June 13, 2013 (See 

Attachment 1).

4. Telecon. Brown, H., EC/R Incorporated with M. Dearinger, MRW Technologies. June 

27, 2013 (See Attachment 1).

5. Email from Smith, A., ABUTEC, LLC to R. Agnew, EPA/OAQPS/SPPD/MPG. June 19, 

2013 (See Attachment 2).

6. Email from Charlton, T., Cimarron, to R. Agnew, EPA/OAQPS/SPPD/MPG. June 13, 

2013 (See Attachment 2).

7. Summary of July 1, 2013, Conference Call with COMM Engineering (see Attachment 3).

8. Memorandum from Brown, H., EC/R Incorporated, to B. Moore, 

EPA/OAQPS/SPPD/FIG. Revised Analysis to Determine the Number of Storage Vessels 

Projected to be Subject to New Source Performance Standards for the Oil and Natural 

Gas Sector. April 8, 2013. EPA Docket No. EPA-HQ-OAR-2010-0505-4597.
ATTACHMENT 1

RECORDS OF COMBUSTOR MANUFACTURER CONTACTS
EC

/R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Drive, Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919)484-0222  Fax: (919) 484-0122

TELEPHONE CALL SUMMARY

PROJECT NO: MTL-111 CALL INCOMING:___ 

OUTGOING:__ 

EC/R STAFF: Heather Brown

DATE: June 13, 2013

CONVERSATION WITH: Greg Adams

TITLE: Operations Manager

COMPANY: JW Williams

ADDRESS:

TELEPHONE NO: 936-931-2424

SUMMARY:

The purpose of this conversation was to confirm combustor manufacturing capacities provided

by the American Petroleum Institute (API) in their March 12, 2012, meeting with the Office of 

Management and Budget (OMB).

According to Mr. Adams, precise capacity information was difficult to predict because combustor 

size impacts the number of combustors that could be produced. They could produce about 50 

combustors a month (about 600 per year) if they didn’t build any other type of unit. Typically, 

about 10 percent of their shop time is spent on combustors. They are an average sized shop and 

one of three within the company. Company-wide, they probably produce from 500 to 1000 

combustors a year.

Mr. Adams said that they are currently looking into upgrading to become compliant with 

“Quad O,” but was unable to provide a future expected capacity. A building expansion would take 

approximately 8 months. They could allocate additional space for production of combustors. 

Combustor production takes approximately 250 man-hours/unit and each combustor is welded 

by hand.
EC

/R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Drive, Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919)484-0222  Fax: (919) 484-0122

TELEPHONE CALL SUMMARY

PROJECT NO: MTL-111 CALL INCOMING:___ 

OUTGOING:___ 

EC/R STAFF: Heather Brown

DATE: June 13, 2013

CONVERSATION WITH: Tom Mark

TITLE:

COMPANY: TCI USA Inc.

ADDRESS:

TELEPHONE NO: 303-949-7214

SUMMARY:

The purpose of this conversation was to confirm combustor manufacturing capacities provided 

by the American Petroleum Institute (API) in their March 12, 2012, meeting with the Office of 

Management and Budget (OMB).

Mr. Mark said that they are a custom craft shop and that they usually build one combustor at a 

time depending on client need. They usually make about 200 per year. They do not have plans to 

build certified units because of the expense required for the use of propene. They also do not 

have any way to get propene and that it’s too expensive. If needed they could probably build 

more smaller-sized combustors. Most tank batteries would require a combustor sized for 

approximately 100 Mcf/day. Their combustors are designed for highly variable flow and high BTU 

gas. He said they could expand to manufacture about 400 combustors a year.
EC

/R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Drive, Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919)484-0222  Fax: (919) 484-0122

TELEPHONE CALL SUMMARY

PROJECT NO: MTL-111 CALL INCOMING:___ 

OUTGOING:___ 

EC/R STAFF: Heather Brown

DATE: June 14, 2013

CONVERSATION WITH: Kim Kruger

TITLE:

COMPANY: PESCO 

ADDRESS:

TELEPHONE NO: 505-327-2222

SUMMARY:

The purpose of this conversation was to confirm combustor manufacturing capacities provided 

by the American Petroleum Institute (API) in their March 12, 2012, meeting with the Office of 

Management and Budget (OMB).

Ms. Kruger stated that the testing criteria for the manufacturer’s certified combustors is too strict 

and that they do not wish to manufacture those types of combustors until the performance 

testing requirements are finalized. Ms. Kruger stated that a $30,000 performance test is too 

expensive to conduct more than one time.

According to Ms. Kruger, a only percent of their business is to manufacture combustors. 

Ms. Kruger also expressed concern about the approval process.

Before she would answer questions regarding their manufacturing capacity, Ms. Kruger 

requested an email request. (NOTE: An email was submitted but no reply was ever received.)
EC

/R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Drive, Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919)484-0222  Fax: (919) 484-0122

TELEPHONE CALL SUMMARY

PROJECT NO: MTL-111 CALL INCOMING:___ 

OUTGOING:_X_ 

 EC/R STAFF: Heather Brown

DATE: June 27, 2013

CONVERSATION WITH: Mike Dearinger

TITLE:

COMPANY: MRW Technologies

ADDRESS:

TELEPHONE NO: (918) 827-6030

SUMMARY:

The purpose of this conversation was to confirm combustor manufacturing capacities provided 

by the American Petroleum Institute (API) in their March 12, 2012, meeting with the Office of 

Management and Budget (OMB).

Mr. Dearinger stated that his company had been supplying combustors for years to oil and 

natural gas facilities but also manufacture combustors for other markets. They are a custom shop 

and make to order. According to Mr. Dearinger, the testing certification and pricing in the 

marketplace were key to the business decisions surrounding combustor manufacturing capacity. 

Depending on the pricing, etc., their company may end up making fewer combustors in the long 

run. Mr. Dearinger also stated that he expects to see the cost of combustors to increase because 

they would need to get more materials that are more expensive.

Mr. Dearinger stated that they are not planning on independent testing until the subpart OOOO 

requirements are finalized. They have a large range in sizes and the company does not have the 

ability to test the largest units in-house. 

Mr. Dearinger estimated that they make approximately 2 to 3 combustors a day (annually, they 

make a number of combustors in the “high hundreds” and “not in the thousands”). He also 

expressed concerns about equipment already being used to control VOC emissions from storage 

vessels that would not meet the requirements.
ATTACHMENT 2

EMAILS TO EPA FROM COMBUSTOR MANUFACTURERS
From: Agnew, Rachel

To: Cozzie, David; Moore, Bruce

Cc: Heather Brown; Branning, Amy; David Hendricks; Frantz, Chris; Parsons, Nick

Subject: FW: Combustor Production

Date: Wednesday, June 19, 2013 11:13:43 AM

Thanks!

Rachel

______________________________

US EPA, Measurement Policy Group

OAR/OAQPS/SPPD

Research Triangle Park, NC

Ph: 919-541-0328 Fax: 919-541-3207

From: Andy Smith [mailto:andy.smith@abutec.com] 

Sent: Wednesday, June 19, 2013 11:01 AM

To: Agnew, Rachel

Subject: Re: Combustor Production

Hi Rachel, we can currently produce 150 units per month and have an equivalent stock level.  We

have capabilities to make 450 per month by August 2013.

Andy Smith

ABUTEC LLC

andy.smith@abutec.com

Office Phone: (770) 846-0155

Mobile Phone: (770) 855-8632

Visit www.abutec.com for more info

Sent from handheld device.

On Jun 19, 2013, at 9:47 AM, "Agnew, Rachel" <Agnew.Rachel@epa.gov> wrote:

Hi Andy,

Could you tell me what your current production capacity is for combustors?

Thanks!

Rachel

______________________________

US EPA, Measurement Policy Group

OAR/OAQPS/SPPD

Research Triangle Park, NC

Ph: 919-541-0328 Fax: 919-541-3207
From: Agnew, Rachel

To: Moore, Bruce; Branning, Amy; Frantz, Chris; Macpherson, Alex; "brown.heatherlynn@ecrweb.com"; David

Hendricks

Subject: FW: Enclosed combustor availabilty

Date: Thursday, June 13, 2013 4:11:32 PM

Response from Cimarron...

Thanks!

Rachel

______________________________

US EPA, Measurement Policy Group

OAR/OAQPS/SPPD

Research Triangle Park, NC

Ph: 919-541-0328 Fax: 919-541-3207

From: Charlton, Tim [mailto:TCharlton@curtisswright.com] 

Sent: Thursday, June 13, 2013 11:38 AM

To: Agnew, Rachel

Subject: RE: Enclosed combustor availabilty

Rachel,

 I believe we sold around 2000 units last year, not sure how that broke down per model but I

could find out if you need to know. We build units for stock and sell units out of the stock supply,

replenishing stock as needed on a weekly basis (I believe). Most of the units are farmed out to third

party fabricators (we have several). I know we have room for increased production capacity but I am

not sure of how much, it really depends on the status of the units in stock.

The On a side note, would Marcia Mia be the contact person to talk to about the status of our

reports submitted for OOOO approval? I believe we submitted them around the week of May 6th.

Tim Charlton

Product Engineer

Cimarron

Curtiss-Wright Flow Control Company

405-928-7373 Office

405-515-8240 Direct

405-423-5296 Cell

tcharlton@curtisswright.com

From: Agnew, Rachel [mailto:Agnew.Rachel@epa.gov] 

Sent: Thursday, June 13, 2013 10:10 AM

To: Tim Charlton
Subject: Enclosed combustor availabilty

Hi Tim,

Could you predict your production capacity in terms of number of combustors made per year? We

expect that mfr’s will ramp up production (assuming they pass the test) and we’re trying to get some

numbers/estimates on availability.

Thanks!

Rachel

______________________________

US EPA, Measurement Policy Group

OAR/OAQPS/SPPD

Research Triangle Park, NC

Ph: 919-541-0328 Fax: 919-541-3207

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This e-mail and any files transmitted with it are proprietary and intended solely for the use of

the individual or entity to whom they are addressed. If you have reason to believe that you

have received this e-mail in error, please notify the sender and destroy this email and any

attached files. Please note that any views or opinions presented in this e-mail are solely those

of the author and do not necessarily represent those of the Curtiss-Wright Corporation or any

of its subsidiaries. Documents attached hereto may contain technology subject to government

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Curtiss-Wright Corporation and its subsidiaries accept no liability for any damage caused by

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From: Agnew, Rachel

To: Moore, Bruce; Cozzie, David

Cc: Heather Brown; Branning, Amy; David Hendricks; Frantz, Chris; Parsons, Nick

Subject: FW: Combustor Production

Date: Wednesday, June 19, 2013 11:13:13 AM

Thanks!

Rachel

______________________________

US EPA, Measurement Policy Group

OAR/OAQPS/SPPD

Research Triangle Park, NC

Ph: 919-541-0328 Fax: 919-541-3207

From: Steve Hogg [mailto:swhogg@commengineering.com] 

Sent: Wednesday, June 19, 2013 11:11 AM

To: Agnew, Rachel

Cc: Bill Schneider; Mark Goodyear; Andrew Bienvenu

Subject: RE: Combustor Production

Rachel,

We currently can produce 1,580 combustors a month.  (18,960 units a year)

We also have the ability to expand and increase that number as needed.

Thanks,

Steve Hogg

Project Manager

COMM Engineering

1319 W. Pinhook Rd., Suite 401

Lafayette, LA. 70503

Ph. 1.888.234.8061

Ph. 337.237.4373 ext. 135

Fx. 337.234.1805

Cell 205.253.7581

www.commengineering.com

From: Agnew, Rachel [mailto:Agnew.Rachel@epa.gov] 

Sent: Wednesday, June 19, 2013 9:48 AM

To: Steve Hogg

Subject: Combustor Production

Hi Steve,
Could you tell me what your current production capacity is for combustors?

Thanks!

Rachel

______________________________

US EPA, Measurement Policy Group

OAR/OAQPS/SPPD

Research Triangle Park, NC

Ph: 919-541-0328 Fax: 919-541-3207
ATTACHMENT 3

SUMMARY OF CONFERENCE CALL WITH COMM ENGINEERING
EC

/R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Drive, Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919)484-0222  Fax: (919) 484-0122

MEMORANDUM

DATE: July 26, 2013

SUBJECT: Summary of July 1, 2013, Teleconference with Representatives from COMM 

Engineering

FROM: Heather P. Brown, EC/R Incorporated

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

I. PURPOSE

This memorandum summarizes the July 1, 2013, teleconference between the Environmental 

Protection Agency (EPA) and COMM Engineering personnel. The intent of the teleconference 

was to confirm COMM Engineering’s theoretical combustor manufacturing capacity previously 

supplied to the EPA.

1

II. DATE

The meeting took place on July 1, 2013, via teleconference.

III. ATTENDEES

The following individuals participated in the teleconference:

COMM Engineering

Steve Hogg

Mark Goodyear

U.S. Environmental Protection Agency (EPA)

Bruce Moore, Office of Air Quality Planning and Standards (OAQPS)

Rachel Agnew, OAQPS

EC/R Incorporated

Heather Brown

IV. SUMMARY OF DISCUSSION

In June 2013, COMM submitted an email to the EPA indicating that their current manufacturing 

capacity was 1,580 combustors per month, or about 18,960 per year. The purpose of this meeting 
2

was to confirm COMM Engineering’s theoretical combustor manufacturing capacity and 

whether the number provided by COMM represented their current capacity. 

Mr. Hogg stated that 18,960 combustors per year was their current capacity, of which about 90 to 

95 percent is currently used in the oil and natural gas sector. However, they can ramp up their 

production as needed. The company is currently receiving shipments from outside the United 

States (specifically, Mexico and China) and has commitments from manufacturers ready to 

fabricate these on demand (which is included in the capacity provided to the EPA). According to 

Mr. Hogg, there is ample manufacturing capacity, but the hurdle is certification.

Mr. Hogg indicated that these combustors would meet the subpart OOOO requirements and that 

COMM manufactures the controls and the burners. The stacks are manufactured geographically 

and can be manufactured at a rate of 5,000 feet of pipe per week.

Mr. Hogg also confirmed that the lifespan of the combustors was a minimum of 5 years, up to 12 

years. Materials are typically used to extend the life as well as the quality of valves.

V. REFERENCES

1. Email from Hogg, S. COMM Engineering to R. Agnew, EPA/OAQPS/SPPD/MPG. 

June 19, 2013 (See Attachment)
3

ATTACHMENT

Email from COMM Engineering
4

From: Agnew, Rachel

To: Moore, Bruce; Cozzie, David

Cc: Heather Brown; Branning, Amy; David Hendricks; Frantz, Chris; Parsons, Nick

Subject: FW: Combustor Production

Date: Wednesday, June 19, 2013 11:13:13 AM

Thanks! 

Rachel

US EPA, Measurement Policy Group

OAR/OAQPS/SPPD 

Research Triangle Park, NC

Ph: 919-541-0328 Fax: 919-541-3207

From: Steve Hogg [mailto:swhogg@commengineering.com]

Sent: Wednesday, June 19, 2013 11:11 AM

To: Agnew, Rachel

Cc: Bill Schneider; Mark Goodyear; Andrew Bienvenu

Subject: RE: Combustor Production

Rachel,

We currently can produce 1,580 combustors a month. (18,960 units a year) 

We also have the ability to expand and increase that number as needed. 

Thanks,

Steve Hogg

Project Manager

COMM Engineering

1319 W. Pinhook Rd., Suite 401

Lafayette, LA. 70503

Ph. 1.888.234.8061

Ph. 337.237.4373 ext. 135

Fx. 337.234.1805

Cell 205.253.7581

www.commengineering.com

From: Agnew, Rachel [mailto:Agnew.Rachel@epa.gov]

Sent: Wednesday, June 19, 2013 9:48 AM

To: Steve Hogg

Subject: Combustor Production

Hi Steve,
1

Could you tell me what your current production capacity is for combustors?

Thanks! 

Rachel

US EPA, Measurement Policy Group

OAR/OAQPS/SPPD Research

Triangle Park, NC

Ph: 919-541-0328 Fax: 919-541-3207