### MEMORANDUM

TO: Docket EPA

- HQ

- OAR

- 2009

- 0174

FROM: Gerri G. Garwood

, P.E., EPA/ OAR/ OAQPS/SPPD

DATE: May 1 , 2015

SUBJECT: Summary of Meeting with A CC Representatives on April 22 , 2015

On April 22 , 2015 at 1 2:30 p .m., the EPA held a meeting with members of the American

Chemistry Council (A CC ). A list of attendees is included at Attachment A to this memo. The

proposed agenda is included as Attachment B to this memo. The first hour of the meeting

covered topics related to electronic reporting and emissions factors. During this portion of the

meeting, the proposed Electronic Reporting an d Recordkeeping Requirements for NSPS

rulemaking was discussed. Specifically:

• The EPA clarified the types of reports that are proposed to be collected

electronically and stated that each subpart varies as to what is required.

• The EPA clarified that the Co mpliance and Emissions Data Reporting Interface

(CEDRI) is our portal on the Central Data Exchange (CDX) for collecting reports

electronically.

• The EPA clarified that in general, Notification of Compliance Status (NOCS)

reports and Electronic Reporting Too l (ERT) files are uploads while other reports

require filling out a form in CEDRI.

• The EPA clarified that the system will be designed with the ability to import data

from spreadsheets, as well as extensible markup language (XML) data upload.

• ACC members qu estioned when the CEDRI forms would be available and if there

would be an opportunity for beta testing. The EPA stated that it plans to have all

forms available by the time the rule is promulgated. In development of past

forms, beta testing was used, and the EPA envisions such opportunities going

forward.

### • The EPA clarified that whatever facilities are required to report now is still what

will be required for reporting

– no more, no less. Only the form of reporting has

changed, not the data elements.

• The ACC members mention ed that when the Greenhouse Gas Program developed

its electronic reporting, it developed sandboxes for users to test the program. The

ACC members stressed that testing needs to be at least a couple of months long.

• The EPA mentioned the possibility of development of a web

- based ERT, as

proposed in the preamble of the rule.

• The EPA clarified that the ERT performs standard calculations for users.

• The EPA clarified that the stack test data goes to WebFIRE for emissions factor

development. T he EPA further clarified that while WebFIRE is being automated

to perform the emissions factor calculations, there will still be a public review

process for any new emissions factors.

• The EPA asked attendees to please submit comments formally.

At the end of the meeting, the newly finalized emissions factors for refineries, adding Method 18

to the ERT, and the Next Gen Toolkit were discussed. Discussion on this topic ended, and the

meeting then moved to the next agenda item.

# Appendix A

List of Attendees

### The following people were present for the meeting in Research Triangle Park:

EPA/ OAR/ OAQPS

Michael Ciolek

Gerri Garwood

Barrett Parker

Ketan Patel

Bob Schell

A CC

Lorraine Gershman

Ashland

Patty Hemmelgarn

Bayer CropScience

Scott Munk

Chemours

Rick Vickery

Dupont

Bruce Davis Dow

Jarod Davis

Russell Wozniak

Eastman

Steve Gossett

ExxonMobil

Derek Reese

Gindi Vincent

LyondellBasell

Ro Sharma

Steve Smith

Shell

Shari Keller

The following people participated by phone:

EPA/OAR/OAQPS

Steffan Johnson

Oxychem

Fred Fedri

Merck

Anu Kunapuli C PChem

Carrie Phillips

Evonik

Teresa Reksel

# Section B

Proposed AgendaACC

– EPA Meeting

April 22 and 23, 2015

Conference Room

– C

- 300A

Conference Call #1

- 888

- 240

- 4148, PIN 980746

Day 1

11:00 am Arrive at EPA security desk, eat lunch in EPA cafeteria

12:30

– 1:30 pm Topic: Monitoring, Reporting and Emissions Factors (SPPD schedule)

• E

- Enterprise

• Emission factors

• Consent decree for refineries

• Method 18 and E

- Reporting

• OECA Monitoring efforts

EPA invitees: Barrett Parker, Bob Schell, Mike Ciolek, Colin Boswell, Steve Fruh and

Foston Curtis

cc: Fred Thompson, Marguerite McLamb, Kevin Culligan

1:3 0

- 3 pm Topic: NAAQS Standards and Implementation (AQPD schedule)

• 2015 Ozone NAAQS

• 2008 Ozone implementation

• 2013 PM NAAQS implementation

• 2010 NOx, SOx standards

– implementation issues, guidance, reconsideration

petitions

• CSAPR

EPA invited: AQPD: Anna Wood, Michael Ling, Scott Mathias

AQAD: Chet Wayland, James Hemby

HEID: Erika Sasser, Kimber Scavo

3

– 4 pm Topic: Title V/Permitting (AQPD schedule)

• Permitting status/backlog

• Improvements?

• Title V Task Force

EPA invited: AQPD: Anna Wood, Juan Santiago, Vera Kornylak, Raj Rao

AQAD: Chet Wayland, Tyler Fox

Cc: James Hemby

Day 2

8:30 am Arrive at security desk

9 am

– 10:30 pm Topic: RTR/NSPS/NESHAP (SPPD schedule)

• 3Ps RTR final rule

• AMF/PC/APR final rule

• Ethylene 114 requests• PVC MACT reconsideration

• Timeline for next rulemakings?

• SSM SIP call

EPA invitees: Penny Lassiter, Nick Parsons, Brenda Shine, Jodi Howard, Andrew

Bouchard, Brian Shrager, Kelly Rimer

cc: Marguerite McLamb, Fred Thompson, Peter Tsirigotis, Kevin Culligan, Ravi

Srivastava

10:30

– 11:15 pm Topic: Boiler MACT, Boiler GACT, CISWI (SPPD schedule)

• Reconsideration

• Next steps

• NSPS KKKK

• MATS

EPA invitees: Jim Eddinger, Mary Johnson, Toni Jones, Christian Fellner, Steve Fruh,

Bob Wayland, David Cozzie

11:15

- 12 pm Topic: Greenhouse Gas (SPPD schedule)

• 111(d) and 111(b) rules

– timing, model FIP plan

• Other sectors?

EPA invitees: Bob Wayland, Nick Hutson, Ravi Srivastava, Lisa Conner, Penny Lassiter,

Douglas Solomon, David Cozzie, Dale Evarts, Steve Fruh, Marguerite McLamb, Kevin

Culligan and Matthew Witosky

AQPD invitee: Juan Santiago

cc: Fred Thompson, Neil Frank , Bill Lamason

12 pm Adjourn