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R Incorporated Providing Environmental Technical Support Since 1989

1 MEMORANDUM

TO: Melanie King, EPA OAQPS/SPPD/ESG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the February 23, 2010 Meeting between the U.S. Environmental Protection Agency and Exterran to disc uss the NESHAP for Existing Stationary Spark Ignition Reciprocating Internal Combustion Engines

1.0 INTRODUCTION

Exterran requested this meeting with EPA to discuss the national emission standards for hazardous air pollutants (NESHAP) for existing stationary spar k ignition (SI) reciprocating internal combustion engines (RIC E), which are to be finalized in August 2010. This meeting summary will be available in the docket for this rulemaking (Docket ID No. EPA-HQ-OAR2008-0708). The proposed NESHAP for existing stat ionary RICE was published in the Federal Register on March 5, 2009 (74 FR 9698). Th e final NESHAP for existing stationary compression ignition (CI) RICE was signed on February 17, 2010.

2.0 ATTENDEES

Bob Wayland, EPA Jeff Holmstead, Bracewell & Giuliani Melanie King, EPA Rebecca Rentz, Bracewell & Giuliani Michael Horowitz, EPA (by phone) John Dutton, J-W Power Co. Bradley Nelson, EC/R Inc. David O’Leary, Compressor Systems, Inc. Kyle Jantzen, Exterran Lewis Sweazy, Compressor Systems, Inc. Bill Bowes, Exterran Tom McGrath, IES Mike Wasson, Exterran Jeff Panek, IES Gerald Meinecke, Exterran Jim McCarthy, IES James Harrison, Exterran (by phone)2 3.0 SUMMARY OF MEETING

Urban/Rural Distinction

Exterran provided an agenda, which is in cluded as Attachment A to this meeting summary. Exterran submitted comments requesti ng a rural area source subcategory for engines less than 500 horsepower similar to what was done in the Oil and Gas rule. Exterran asked if EPA could provide any informati on regarding what direction EPA is headed towards on this issue. In the final NESHAP for existing CI engi nes, EPA determined that it was not appropriate to distinguish between stationary existing CI engi nes at area sources loca ted in urban and rural locations. EPA will determine whether a rural area source subcategory is appropriate for existing stationary SI engines, a nd may consider engine size and type as part of this analysis. EPA stated that geographical information close to population centers using Urban-1/Urban-2 (U1/U2) information will be used in the analys is. The U1/U2 definitions are based on the definitions of urban/rural for the Urban Air Toxics Program and are defined as follows:

 U1 counties which include a metropolitan statistical area (MSA ) with a population greater than 250,000;

 U2 counties that do not include a MSA w ith a population greater than 250,000, but the Bureau of the Census designates more th an 50 percent of the county population as

“urban.” These counties incl ude areas which comprise one or more centra l places and adjacent densely settled surrounding urban fr inge. The urban fringe consists of contiguous territory having a density of at least 1,000 persons per square mile; and

 Rural counties that do not include an MS A with a population gr eater than 250,000 and the Bureau of the Census designates more th an 50 percent of the county population as

“rural.”

Exterran indicated that it thought that EPA w ould use the same urban area/urban cluster

classifications that were used in the Oil and Gas rule and asked whet her the decision to use U1/U2 categorization was a policy or legal issue. EPA stated that the Urban Air Toxics Program definitions clearly distinguishes between urba n and rural using the U1/U2 classifications

Exterran stated that it needed to review the definitions and w ould provide comments at a later date. Exterran also added that it provided a small sample of sites in Texas in earlier comments that shows how sparse the populations around th ese sites are. EPA requested additional

information on the distance from businesses and re sidences to these stationary SI engines.

Work/Management Practices

Exterran stated that it provided a paper to EPA with recommendations for management practices for engines at area sources for the fina l rule. Exterran’s recommendations are included as Attachment B to this meeting summary. Exte rran stated that SI e ngines burn cleaner fuel,

therefore maintenance activities su ch as oil changes and spark plug replacements are not needed every 500 or 1,000 hours of operation. Exterran r ecommended that the oil change be required every 1,440 hours of operation for 4-st roke SI engines. Exterran said that spark plugs can be3 cleaned and re-gapped a few times before needing to be replaced. In the case of oil changes,

Exterran indicated that facilities should be al lowed to perform an oil analysis. In Exterran’s opinion, if the analysis shows th at the oil has reached the cond emning limits, an oil change should be required within 30 days. Exterran indi cated that this will reduce waste oil from the facilities and still allow the engine to operate efficiently. For inspec tion of belts and hoses, Exterran indicated that the inspection frequency should coincide with th e frequency requirements of the spark plug replacement and oil change, i. e., every 1,440 hours of operation for 4-stroke SI engines. For 2-stroke SI engines, Exterran recommended that the oil change and spark plug replacement frequency be extended to 4,320 hours of operation. Exterran stated that these engines are low speed, which reduces wear on the engine, and the combustion chamber is sealed from the oil, which eliminates oil contamina tion. Therefore, Exterran indicated that the maintenance frequency for 2-stroke engines can be longer than for 4-stroke engines. EPA indicated that it will review the information Exterran provided.

EPA asked for clarification of skip or exte nded period monitoring that were included in

Exterran’s recommendations. Exterran stated th at the skip or extended period monitoring would

allow facilities to increase the intervals between inspections based on the maintenance history of the SI engine without having to get approval fr om EPA. Exterran adde d that the skip or extended period monitoring would allow owners/ope rators to take advantage of premium oils and new spark plug technology, which extend the need for replacement. Exterran also added that the skip period would reduce the amount of waste oil generated by a facility. For an example, Exterran stated that if the oil analysis and sp ark plug inspection showed the change levels were not exceeded after two inspection periods, then the inspection interval could be extended by 1,440 hours after the next oil change. EPA said it would take Exterran’s recommendations into consideration for the final rule and asked for additional information supporting this

recommendation.

Crankcase Emissions

Exterran stated that crank case emissions are the product of diesel fuel combustion and asked if EPA plans to require crankcase emission control for stationary SI engines. EPA stated that the requirement to use crankcase emissions c ontrol was included in the final rule for existing stationary CI engines to redu ce particulate hazardous air poll utant (HAP) emissions. EPA has

not reviewed crankcase HAP emi ssions data from stationary SI engines at this point.

MACT Floor/Variability

Exterran stated that it has spent approx imately $500,000 on testing of stationary SI engines, which included testing at different loads and other conditi ons that may affect emissions.

Exterran indicated that it could not test for all conditions, such as natural gas composition variability or altitude, but believed that the data collected include variability. Exterran thought

that the maximum achievable cont rol technology (MACT) floor s hould be derived by identifying the top 12 percent of engines and using the highes t value from these top 12 percent of engines to

set the MACT floor. Exterran i ndicated that this approach wi ll provide a reasonable operating scenario as recently approved by th e District of Columbia Courts. EPA indicated that it is open to ideas for ways to account for variability. EPA suggested that Exterran provide a subset of the4 data showing the recommended MACT floor calculation and EPA would review the recommendation. For engines at hi gh altitudes, EPA stated it c ould look at data and consider a special provision for these engines.

Cost Analysis

Exterran indicated that it believed the control cost estimates in the proposed rule are too low and the HAP emission factors are too high. Exterran asked if the control costs were

calculated based on cost data from vendors. EPA stated that the control costs were calculated using costs from both vendors and state collection re quests from facilities. EPA also stated that additional cost information was received during the comment period, which will be reviewed in addition to new data received during the developm ent of the final CI rule. Exterran would be willing to provide additional cost information if needed.

Startup/Shutdown/Malfunction

Exterran reviewed the startup, shutdown a nd malfunction (SSM) requirements in the final rule for stationary existing CI engines and expr essed that it had concer ns certifying compliance

with the rule and the issue of credible evidence for stationary SI engines. EPA stated that compliance is based on three 1-hour runs, and EP A expects that malfunctioning engines will be shutdown. Exterran questioned the scenario wh ere there is a malfunctio ning oxidation catalysts leading to the engine exceeding the standards and being out of co mpliance for the period since it was last tested. EPA agreed th at the engine would be out of compliance for that period, but added if there is a malfunction, then the engine should be shutdown. EPA further added that certifying compliance means that the engine meets the requirements based on three 1-hour tests.

EPA stated that if Exterran has alternativ e suggestions on compliance to please provide

recommendations to EPA.

Method 323

Exterran stated that IES will be providing side-b y-side testing of three to four engines for formaldehyde using Method 323 and Fourier Tran sform Infrared Spectroscopy. EPA responded

that this data will be helpful in determining if the Method 323 should be validated. Exterran believed that a checklist should be developed to assist the tester in performing Method 323.5 Attachment A

Exterran Agenda for February 23, 2010 Meeting6 EPA Research Triangle Park

SI RICE February 23, 2010

1:30

I. Rural Area Sources Subcategory

II. Management Practices

III. MACT Floor/Variability

IV. Revised Cost Analysis

V. SSM/Work Practices7 Attachment B

Memorandum to Melanie King, EPA January 27, 2010 Management Practices for SI RICE Area Sources < 500 HP