MEMORANDUM  SEQ CHAPTER \h \r 1    

TO:		Melanie King, EPA OAQPS/SPPD/ESG

FROM:	Bradley Nelson, EC/R, Inc.

DATE:		August 31, 2009

SUBJECT:	Summary of the August 18, 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 their comments on
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.
EPA-HQ-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

Melanie King, OAQPS/SPPD/ESG

Michael Horowitz, OGC (by phone)

Exterran

Gerald Meinecke

Mike Wasson

Bill Bowes

James Harrison (by phone)

Kyle Jantzen (by phone)

Bracewell & Giuliani

Jeff Holmstead

Rebecca Rentz

Richard Alonso (by phone)

JW Power Co.

John Dutton

Compressor Systems Inc.

Levent Caglar

David O’Leary

EC/R Incorporated

Bradley Nelson

3.0	SUMMARY OF MEETING

The companies provided an agenda summarizing the issues that they wanted
to discuss with EPA.  A copy of the agenda is included in Attachment 1
of these meeting minutes.  Jeff Holmstead began the meeting by stating
that the companies represent small (<500 horsepower (HP)) natural gas
fired engines located mostly at rural locations.    

The first topic of discussion was the subcategorization of engines
located in rural areas.  The industry representatives asked if EPA was
considering using the urban and rural guidelines that were used for the
Oil & Gas Production NESHAP.  EPA responded that it is looking at the
issue, but that no final decisions had been made.        

The industry group asked what management practices are being are being
considered for the final rule for engines less than 500 HP at area
sources.  EPA stated it was looking at management practices that were
provided in the comments, and asked industry which management practices
reduce emissions from the engines.  The industry group responded that
the companies already have an operator defined management program used
to prolong the life of the engine.  These practices include: monitoring
of the spark plugs and changing of the oil.  Industry stated that many
of the facilities test the oil to make sure the oil properties are
sufficient for lubrication of the engine.  Industry also stated that
replacement of the oxygen sensor could also be used as a management
practice.  EPA agreed that these management practices are viable
options, but stated that the management practices must have objective
criteria that can be measured.  Industry responded that there are a lot
of variations in the type of engines and the operations associated with
each engines so it is difficult to propose objective criteria.  Industry
stated that the management programs should be operator defined. 
Industry asked if oil sweetening would be allowed in the final rule. 
EPA responded that the facility can petition for alternative compliance
to the permitting authority by providing technical justification for oil
sweetening.  EPA asked that industry provide recommendations for
management practices by October.

The next issue that was discussed was startup, shutdown, and malfunction
(SSM).  Industry estimated that their engines have 3-4 shutdowns per
month, and engines typically take approximately 15 minutes to heat up to
temperature during startup.  However, some engines in cold areas may
take up to 45 minutes for startup.  To address the SSM issue, industry
suggested using the de minimis language from the Alabama Power court
decision for natural gas RICE less than 500 HP.  Other options suggested
for SSM include: accounting for SSM emissions in the floor calculations;
subcategorizing the SSM events and establishing separate limits; or work
practices.  Industry suggested that EPA could address the SSM issue by
setting a not-to-exceed limit for SSM events for each month, or set a
pound per hour limit for SSM events.  EPA responded that no additional
test information was received for these engines during the comment
period.

The next issue that was discussed was the test protocol letter that was
sent to EPA by Bracewell & Giuliani that outlines the proposed
collection of emissions test data for natural gas-fired engines less
than 500 HP to support the RICE NESHAP (See Attachment 2).  Industry
stated that they had three options: 

Option 1 - provide as much test data as possible before October; 

Option 2 - request and receive an extension of the rule and collect
additional data; or

Option 3 - collect no data and challenge the final rule.  

Industry wants to ensure that if they choose Option 1 that the collected
test data will be used by EPA to establish new limits.  EPA responded
that any data received in October would be included in the MACT floor
analysis for the engines.  Industry asked if the emission data should be
provided in grams per brake horsepower-hour at full load.  EPA stated
that the tests should consider variability and provide data that is
achieved in practice.

Industry stated that most of the 2-stroke lean burn engines less than
500 HP are Ajax engines and that these engines do not produce enough
heat to allow an oxidation catalyst to operate effectively.  Industry
stated that they currently have 14 engines that use a catalyst, but the
use of a catalyst increases nitrogen oxides emissions.  



Attachment 1

Agenda for Exterran Meeting with EPA

August 18, 2009



Attachment 2

Test Protocol Letter

August 17, 2009

E C/R Incorporated	Providing Environmental Technical Support Since 1989



	

  PAGE   \* MERGEFORMAT  2 

