Date: October 30, 2009 

To: Docket ID No. EPA-HQ-OAR-2007-0011 

From: Kristin Parrish Sroka 

Subject: NSPS Subpart J Review: Meeting Minutes for April 23, 2009, Meeting Between 

the U.S. EPA and Representatives of BP Products North America, Inc. 

Introduction

On April 23, 2009, representatives of the U.S. Environmental Protection Agency (EPA) 

and their contractor (RTI International) participated in a stakeholder meeting with 

representatives of BP Products North America, Inc. (BP), including representatives from the 

Cherry Point and Texas City refineries. The names and affiliations of the participants are 

included in Attachment 1. The purpose of the meeting was to discuss various issues regarding 

the EPA’s reconsideration of flares in NSPS subpart Ja. Attachment 2 contains the presentation 

slides used by the Cherry Point representatives, and Attachment 3 contains the presentation 

slides used by the Texas City representatives during the meeting. Attachment 4 is the transmittal 

letter that accompanied the electronic copies of the presentation slides, and Attachment 5 

provides correspondence between the EPA and BP regarding meeting planning. 

Discussion

The discussion mainly centered around the presentation slides in Attachments 2 and 3. 

Additional points made by the BP representatives are described below. 

Flare Monitoring 

The Cherry Point representatives described the water seal on their flare. They stated that 

it has 5 feet of water during normal operation, and flare gas is not normally bleeding through the 

seal. The system is constantly adding water to the seal to maintain the 5 foot level. When there 

is a flaring event, the flare gas blows the water out of the seal, and the seal refills as soon as the 

gas flow is low enough that the water is no longer being forced out of the seal. The operators 

know that the water seal has been blown and that there is a flaring event through use of several 

methods, including a gas flow meter, pressure indicator, and a camera that provides a visual 

picture of the flare. 
 

2

Alternative Compliance Technique 

The Cherry Point representatives noted that they are planning to test a new sulfur 

treatment technique to meet proposed subpart Ja fuel gas standards at their refinery. As shown 

on Slide 19 of Attachment 2, they plan to inject chemicals referred to as hydrogen sulfide (H2S) 

scavengers into the lines between three units that generate the majority of the fuel gas and the 

overhead system. The Cherry Point representatives noted that the concept came from experience 

in Alaska. They noted that through this process, the H2S is bound to long-chain amines and 

diverted to the wastewater treatment plant with sour water. The technique requires a good 

wastewater treatment plant with different bacteria than is normally present at refineries, and the 

feed to the wastewater treatment plant must be slow to avoid an exceedance. The Cherry Point 

representatives noted that they plan to test the technique during the upcoming turnaround. One 

option for permanent use might be to inject the chemicals between the condensate tank and the 

flare. 

Other 

The Texas City refinery participated in a test of the Differential Absorption Lidar (DIAL) 

instrument, and the EPA representatives noted that they are still trying to obtain process 

operation data so that they can correctly interpret the results of that study. The Texas City 

representatives agreed to look into the matter and try to help the EPA get the data. 
Attachment 1 

Participants in April 23, 2009, Meeting 

Industry Representatives

Ken Comey, BP – U.S. Refining 

Elizabeth Daly, BP – Cherry Point Refinery 

Robert Hermanson, BP – U.S. Refining 

Richard Huff, BP – Cherry Point Refinery 

Steven Mrazek, BP – Cherry Point Refinery 

Carrie Phillips, BP – Texas City Refinery 

Ross Vail, BP – Texas City Refinery 

U.S. EPA Representatives

KC Hustvedt 

Brenda Shine 

Susan Stahle 

U.S. EPA Representatives – Region 5

Erik Hardin 

Bill Wagner 

RTI International (EPA contractor)

Jeff Coburn 

Kristin Parrish 
Attachment 2 

Presentation Slides 

Cherry Point Refinery 

NSPS Subpart Ja Flare Briefing 

EPA Office of Air Quality Planning & Standards 
Cherry Point Refinery

NSPS Subpart Ja FlarEPA Office of Air Qua& Standards

April 23, 2009
Who we are...

• Elizabeth Daly Environmental Superintendent, Cherry P• Richard Huff Process Development Superintendent, C• Robert Hermanson Senior Regulatory Advisor, US Refining• Steven Mrazek Senior Environmental Engineer, Cherry P
Purpose/Agenda

• Review flare provisions of proposed NSPS Subpart Ja• Discuss RCA requirements for events >500 scfd• Discuss corrective action requirements for events >500 scfd• Review technological & safety issues associated with these events• Discuss options to address concerns
Cherry Point Refinery

• Large single train refinery built in 1970-71• 2 steam assisted, smokeless flares 

designated high & low pressure flares 

• Flare Gas Recovery Unit added in1984 

− Reduced SO2 emissions by 780 tpy− Two 80,000 scfh 3-stage reciprocating compressors

− Shared MDEA absorber for H2S control

− Baseload is a small fraction of capacity (approx. 15,000 scfh eac

• Coker Blowdown Vapor Recovery added in phases in 2003 & 2005

− Reduced SO2 by 106 tpy

− Separate 6-stage 5,000 HP centrifugal compressor

− Backup plan, use FGRU w/ both compressors on LP flare heade
Cherry Point Process Flow 

Crude

Vacuum

Diesel

Frac.

Vacuum

Tower

NHDS

Unit

Coker

Coker

Dehex

Hydrocracker

H/C 

Dehex

#1 Calciner#2 Calciner#3 Calciner

#1 DHDS

#1 Reformer#2 Reformer

Reformate

Splitter

G

B

Butane

Splitter

LEU & 

LPG

H2 Plant HRU

South SRU

North SRU

#1 TGU

LRF

Flare Gas

Recovery 

C5’s

Crude

Dehex

ISOM

HDS

(IHT)

BenSat Penex

LEU

De-isobutanizer

#2 DHDS

C5 – C6

C5 – C6

LEU

LEU

LEU

Isomerate

#2 TGU
Flare Gas Recovery Unit(25-year cumulative impact - 19,500 tons SO

2 reduced – so far)

L.P. Suction

Drum Pump

H.P. Flare Gas

L.P. Flare Gas

L.P. CompressorDisch. K.O. Drum

Recovered GK.O. Drum

Utility Water

Natural Gas

H.P. Suction

Drum Pump

H S Absorber

Sour Water to 

Blowdown/D-3 or 

Fractionator OVHD

H.P. 2ndStageK.O.Drum

1803 COMPRESSOR

H.P. 3rdStageK.O.Drum

L.P. 2ndStageK.O.Drum

1804 COMPRESSOR

L.P. 3rdStageK.O.Drum

H.P. CompressorDisch. K.O. Drum

H.P. 1st 

Stage K.O. 

Drum

L.P. 1st 

Stage K.O. 

Drum

H.P. Flare Gas

K.O. Drum

L.P. Flare Gas

K.O. Drum

H.P. Flare Gas

Seal Drum

1538

1222

1537 1218

1326

CW

1223

CW

1327

1224

CW

1328

1225

1503

L.P. Flare Gas 

K.O. Drum 

Pump

1202

2 1107

1226

2808

1201

1502

H.P. Flare Gas 

K.O. Drum 

Pump

1325

1221 CW

CW CW

1324

1220

1323
Flare Schematic
Cherry Point Flares - Normal OperationLP on the left, HP on the right
Low Pressure Flare

(less than 200 psig units)

• Butane/Propane Load Out• Crude Unit• Chem Treater• #1 DHDS• Boilerhouse• Light Ends Unit• Hydrocracker• Hydrogen• Flare Gas Recovery Unit• Coker• Calciner (fuel gas knock out pot)• Amine Regeneration, Sour Water, Sulfur Recovery & Tail Gas

• ISOM
High Pressure Flare(more than 200 psig units)• #2 Reformer• #1 Reformer• Light Ends Unit• Hydrocracker• #1 DHDS• Hydrogen• #2 DHDS
SO2 Emissions from Cherry Point Flares(For Context - Roughly 2.5 - 3.5% of Total Annual SO2)

05

101520253035404550

2006 2007 200

(Tons SO2/ Year)

HP LP Total
Recent Flare Flow History(Please refer to annotated handout for peak identification)

0

100200300400500600700

1/1/2006

3/1/2006

5/1/2006

7/1/2006

9/1/2006

11/1/2006

1/1/2007

3/1/2007

5/1/2007

7/1/2007

9/1/2007

11/1/2007

1/1/2008

3/1/2008

5/1/2008

7/1/2008

9/1/2008

(MSCFD)

LP FLARE (CORR FLOW) HP FLARE (CORR FLOW)
Events > 500,000 SCFD

In the last three years...• Low Pressure Flare (14 days total)

− 10 days - LEU TAR− 2 days – LEU upset, reboiler repair− 2 days – LEU upset, repair rundown line to sphere

• High Pressure Flare (15 days total)

− 9 days – #1 Reformer, catalyst regeneration− 4 days - Hydrocracker TAR (SD & SU)− 1 day – Hydrocracker upset, compressor relay failure− 1 day - #1 Reformer upset, compressor stator failure
#1 Reformer

• Original equipment• World’s largest box-type heater in 1971• Semi-regen type, 6-month cycle length• Subject to MACT Subpart UUU, HP Flare used as control device• Process is extremely vulnerable to sulfur contamination• Only hydrotreated feeds accepted, unit includes sulfur guard bed• Estimated SO2 emissions < 1 lb./event

• RCA would be req’d since flow exceeds 500,000 scfd• Majority of volume is H2 sweep, N2 purge & steam cleaning

• Low gravity gases not suitable for recovery as fuel gas – creates 

instability for ULNB that are in use at numerous units
Reformer Process Flow Diagram

Reformer StabilizerOVHD Liquid to LEU

Reformate

Splitter

600# StmHeavy Reformate

Commingler

Reformer

Reactor No.2

Reformer 

Heater No.1

Reactor No. 1

Sulfur Guard

Hot Hux

From H/C 

Dehexanizer

Hux From

Tank 31 

Recycle Booster

Compressor

(Electric)

To 

Reformate 

Stabilizer (A)

SplitteAccum

Compressor

K.O.Drum

H.P. Flare or Fuel Gas

Recycle 

Compressor

(Steam Turbine)

H.P. Flare

Methanol

Chloride

Trap

Off G

BFW/Chemical

Injection 

ReformateStabilizer

Cold Hux Pump

Splitter Btms Pump

Splitter Ref

Stabilizer Reflux Pump

Condensate

From #2 Ref.Debut. Btms

140# 

Steam

Condensate

LRF Btms Pump

LightReformateFractionator(LRF) 

Gasoline

BFW & Coalescer

Neutralizing 

Amine

Make Gas to Naphtha HDS Unit Recycle CompressorNet Make GasH.P. FlareFuel GasTo HRU

Reformer 

Heater No.2

Reformer

Reactor No.3

Reformer 

Heater No.3

Reformer

Reactor No.5

Reformer 

Heater No.4

Reformer

Reactor No.4

To HRU 

Commingler

From HRU 

Commingler

600# 

Steam

PreHeater

Condensate

ENGINEERING CONTRACTOR

DATE

PROJECT NO:

OPER.

APPROVALS #1 

REACTION & 

PRO

ANVIL CORP BE8190

WO 18800

12/4/02 

bp 

YW

WS

PM

PCE PCE

(A) From

K.O. Drum

Stabilizer OVHD

Accumulator

LR

Ac

CW

1206

1322

1803 1802

1506

1309

1308

2503

1403

2504

1404

2505

1405

2507

1406

2506

1310

1207 1232

1311

1314

1317

1337

1102

1316 CW

1208

1339

1338

1318

CW

CW

1103

1319

1321

1510

1209

CW 1340

1536

2508

1508

1509

1544 

LRF 

Reboilers

Flare

1105

To Sour Water

NC

NC

NO

NC

Low 

Pressure

Flash Drum

Make Gas

Compressor

LP Flash Drum

Bottoms Pump

1804 1315

CW

1507

CW

1313

1205 1312

H.P. FlareNitrogen

Recycle

Gas

1346 Dryer

Reactivation

Gas

Heater 600#

Steam 

Clean Condensate

To Return Unit 

1233

7

HC

FI

NC

FC

NC

NC

(NOTE 1)

FO

HC

FL

98765

REV

10/07 19001378 TAYLOR FIELD UPDATES PER DR4055 RDM AF ST09/07 19001378 O’REILLY CORRECTED COMPRESSOR K.O. DRUM TO 1206 PER DR4687 RDM AF KO03/07 1106AA WOODS RECYCLE GAS DRYER PROJECT ISSUE FOR CLIENT APPROVAL SRO BAS TRP12/04 R811 ALVA DELETED PUMPS 1345 & 1535, ADDED PUMP 1544 SCB AF VA01/03 WO18800 CHRISTENSEN FIELD VERIFIED & CONVERTED TO VISIO YW WS PM

DATE AUTH PROJ ENGR DESCRIPTION BY CKD APP

8

9
Options to address high volume H

2 sweeps

N

2 purges and steam cleaning:

• Suggest removing flow-based RCA provisions:

− Cannot be applied fairly across all refineries− Penalize large refineries w/ centralized flares, even those w/ flare gas 

recovery systems – multiple flares w/o flare gas recovery not affected

− More stringent provision than H

2S limit, yet not subject to Best 

Demonstrated Technology Determination

• Options to consider: 

− Do not include volume contribution from steam, H

2 & N

2

− Calculate 500,000 SCFD from Baseline Condition which may vary 

depending on operating mode – normal productions vs. regeneration

− Establish cost effectiveness threshold for corrective action− Exempt flaring required to comply w/ MACT standards

− Limit RCA requirements to events that exceed the H

2S standard
Hydrocracker/LEU Turnaround

• LEU TAR coincides w/ Hydrocracker TAR – the minimum emissi• Hydrocracker streams contain majority of sulfur sent to LEU• LEU out of service for 10 days every 30 months• Must debutanize streams that have no down stream unit availab

to tankage (MACT TVP limits) 

• Injection system ensures continuous compliance w/ H

2S standar

• Corrective action options:

− Build second LEU - $70MM minimum− Conduct refinery-wide TAR – same emissions w/ far greater s

environmental risk and still would have flaring between unit st

− Gases not suitable for recovery due to butane content (will co

form liquid)
Options to address LEU TAR:

• Suggest removing flow-based RCA provision

− Cannot be applied fairly across all refineries− Penalizes large refineries w/ centralized flares, even those w/ 

recovery systems

− More stringent provision than H

2S limit, yet not subject to Bes

Demonstrated Technology Determination

• Clarify that corrective action is limited to running existing kit bett

Establish cost effectiveness threshold for corrective action

• Limit RCA requirements to events that exceed the H

2S standard

• Limit RCA requirement to events that exceed SARA/CERCLA thr

− 160 ppm H

2S * 500,000 SCF/Day = 15.5 lbs. SO

2/Day
NSPS Subpart Ja Compliance Plan(Concept will be tested next week)

Desalter 

Water 

Stripper

1537

Steam

Flare

Tail Gas

1104

Utility Water

Oily Water 

Sewer

Stripped Water Surge Drum

1252

1551-01/02

13601359

OVHD 

Conds.

Crude Pre-frac 

Exchanger

To H/C

Fuel Gas

CW

CW CW

CW

1321

1309

OVHD 

Condensers

CW

Crude Ovhd 

Accumulator

1201

Fuel Gas

H/C 1858

Sour Water

1511

H/C

Fuel Gas

CW

1311

Crude Tower

10-1101 Debut 

Tower

1153

Pre-Fract

1152

13631364

Waste Water

And/or

Sewer

PhenolicWater Stripper

Non PhenolicWater Stripper

From

Desalters

H2S 

Scavenger

Injection

NC

Debut Ovhd 

Accumulator

1203

PreFrac Ovhd 

Accumulator

1154

Compressor

Sep. Drum

LP Flare Gas

KO Pot

1202

LP Flare Gas

KO Pot Pump

1503

LP Flare Gas

Skim Pot

1203

LP F

Pump 

1

To Sour Water

LP Flare Gas

KO Pot Surge Pump

1504

HP Flare Gas

KO Pot Surge Pump

1504

LP Flare 

Header

To FGRU

H2S 

Scavenger

Injection

H2S 

Scavenger

Injection
Typical New Tie-In Examples• MACT CC Compliance• Site Technical Practice• Engineering Technical Practice• BP Recommended Best Practices• Process Safety Management Expectations• Safety Audit Findings• Employee Exposure Reduction• Process Control• Product Quality Control• Monitoring Instrumentation• Sulfur Scavenger Injection System• Capital Projects

− Sour Water Handling Upgrade 2009-2010− Clean Diesel Project (H

2 + #3DHDS + EGF?) 2011-2012

For CP Refinery these tie-ins will be made upstream o

flare gas recovery unit and won’t increase emission

Preamble fro

proposal specsought comm

the types 

connections 

should be allo

w/o trigger

Subpart J
For your consideration:

• Process or operational changes must increase emissions on a 

lbs./hour basis to trigger Ja consistent with FCAA 

§111

• Changes made upstream of recovery compressors are not 

modifications since emissions don’t increase – Provided capacity remains

• Rule should “incentivize” new recovery systems while 

acknowledging the environmental benefits of existing systems
Annotated Handout that Accompanies Slide 12
Attachment 3 

Presentation Slides 

NSPS Ja Proposed Root Cause Analysis Flow Trigger Review with EPA 

BP Products North America, Inc. 

Texas City Refinery 
NSPS Ja Proposed Root Cause Analysis 

Flow Trigger Review with EPA

BP Products North America, Inc.Texas City Refinery
Texas City Refinery Information

• Complex, multi-train refinery with integrated flare systems

− Began operation in 1934.− Refinery is capable of processing over 460,000 barrels of crud

oil and other feedstocks per day, equivalent to 7.6 Bn gallons year 

− 33 process units, 13 flares− One of the most complex refineries in the world − 3% of U.S. gasoline supply− Produces primarily transportation fuels (77%) and chemical 

feedstocks (20%)
BP Texas City Refinery Manufacturing Flow

Hydrogen
Ultracracker (ULC) Flare

• Serves as a control device for ULC, Ultraformers 

and 4 (UU3 and UU4), and ARU

• Continuous and periodic streams vent to flare fro

all four units including but not limited to, 

− Natural gas purges on process vessels and relief heade− Regeneration vent depressures and purges (UU3 and U

regeneration vents routed to control due to MACT UUU

− Nitrogen purges to prepare equipment for maintenance 

to be put back in service

− Control of start-up, shutdown and malfunction emission− Flows from various process units during Turnarounds
ULC Flare Flows for the BP NSPS Ja 

Comments

ULC Flare Flows

(10,000,000)

(5,000,000)

-

5,000,000

10,000,00015,000,00020,000,00025,000,00030,000,000

4/17/2008

5/1/2008

5/15/2008

5/29/2008

6/12/2008

6/26/2008

7/10/2008

7/24/2008

8/7/2008

8/21/2008

9/4/2008

9/18/2008

10/2/2008

10/16/2008

10/30/2008

11/13/2008

11/27/2008

12/11/2008

12/25/2008

1/8/2009

1/22/2009

Date

Flow , SCF/day Tota

RecyNet U
Cyclical Regeneration of UU3/UU4 Reactor

• Cyclical regeneration for 6 reactors at each unit 

− Typically one reactor is regenerated every day

• Depressurizations, nitrogen purges, and hydroge

purge all route to flare

− About 400,000 scf/day in total− Required to route to control per MACT UUU− 98% of total flow is nitrogen or hydrogen, no measurab

H2S

− Heating value too low for use as fuel gas
Natural Gas used for purging and for heatin

value controls

• Used as purges on RV headers• Used as purges on flare knock-out drums• Used to ensure safety of the flare system

− Keeps a positive flow to ensure oxygen can’t back into 

flare header

• Used to increase the heating value of gas to 

ensure compliance with 40 CFR NSPS 60.18 requirements (300 BTU/scf)

− Offset nitrogen and hydrogen purges

• Average 1,680,000 scf/day (70,000 scf/hr) of 

natural gas flow
Sweet Hydrogen Stream during Ultracracke

Turnaround

• Sweet Hydrogen from Ultraformer reaction process typically rout

Ultra cracker (ULC)

− 87% by volume hydrogen, average 2 ppm H2S− About 2 MMscf/hr from each reformer exported to ULC for compres

use in other parts of the refinery

• During Turnarounds (TAR) of Ultracracker, sweet hydrogen may b

to fuel gas, subject to volume and composition constraints

− Fuel gas system can be limited by volume and composition− Volume limit based on fuel gas system capacity (there are other prod

fuel gas)

− Economic penalties are taken by cutting the FCCUs back to main

balance

− Composition limit is usually high hydrogen content. This can be a pro

safety hazard for some of our fired heaters.

• Stream is controlled by flare once fuel gas constraints are met

− Cannot put all of this hydrogen in the fuel gas system
Attachment 4 

Transmittal e-mail accompanying presentation slides 
"Hermanson, Robert W" 

<robert.hermanson@bp.com> 

04/30/2009 01:28 PM

To: Ken Hustvedt/RTP/USEPA/US@EPA, Brenda 

Shine/RTP/USEPA/US@EPA 

cc 

Subject: BP Visit on NSPS Ja Flaring on April 23

KC, Brenda - 

On behalf of the entire BP delegation, thank you for meeting with us last week on the NSPS Ja flaring 

issues. We were happy to have the opportunity of telling our stories, and I hope you found the discussion 

as useful as we did. Please pass our thanks along to Kristin and Jeff (I don't have their email addresses). 

Attached are the presentations we gave. Neither contains any confidential business information. (One of 

the presentations was modified slightly from the version we presented in order to remove confidential 

business information.) Accordingly, you may use them as you would any other non-CBI submittal. 

Should you have any questions about our discussion, or about the presentations, please don't hesitate to 

contact me. I'll put you in touch with the person who can answer the question. 

Thanks again. 

Regards,

Bob Hermanson

Senior Environmental Advisor - Air Advocacy

BP Products North America, Inc.

US Refining Central Environmental Compliance & Advocacy Team

150 W. Warrenville Rd., Mail Code 600-1WA

Naperville IL 60563

Voice 630-961-7650 Cell 630-649-0314 Fax 630-420-5375 Email hermanrw@bp.com 

(See attached file: EPA_Flare_Brief_Cherry_Point_20090417.pdf) 

(See attached file: EPA_Flare_Brief_Texas_City_20090417.pdf) 
Attachment 5 

E-mail correspondence between the EPA and BP regarding meeting planning 
From: Shine.Brenda@epamail.epa.gov [mailto:Shine.Brenda@epamail.epa.gov] 

Sent: Wednesday, April 22, 2009 10:32 AM 

To: Hermanson, Robert W 

Cc: Hustvedt.Ken@epamail.epa.gov 

Subject: Re: BP Visit Thursday 23 April 9am 

Hi Bob, 

We plan on seeing you tomorrow at 9 am. We have a conference line set up at (919) 541-4486. If you 

want the BP Texas City presentation to be confidential, we can treat it that way and place the meeting 

materials in our CBI files. However, our phone lines are not secure. 

Brenda Shine 

Environmental Engineer 

US Environmental Protection Agency 

Research Triangle Park, NC 27711 

(919) 541-3608, Mail Drop E143-01 

"Hermanson, Robert W" 

<robert.hermanson@bp.com> 

04/22/2009 09:33 AM 

To: Ken Hustvedt/RTP/USEPA/US@EPA, Brenda 

Shine/RTP/USEPA/US@EPA 

cc: 

Subject: BP Visit Thursday 23 April 9am 

KC, Brenda - 

We will plan to be at the main desk a few minutes before 9am tomorrow, Thurs 23 April (which will be 

"Talk Like Shakespeare" day in Chicago, forsooth). I will give the desk guard Brenda's name as contact. 

One of our number is down with a cold and would rather not attend in person. Is a conference call hookup 

feasible? 

Last, our Texas City refinery attorney asks that the Texas City presentation be held as business 

confidential. Please advise the necessary steps. 

I will be available on my cell phone today, 630-649-0314, except, of course, while traveling. 

Regards, 

Bob 

Bob Hermanson 

Senior Environmental Advisor - Air Advocacy 

BP Products North America, Inc. 

US Refining Central Environmental Compliance & Advocacy Team 

150 W. Warrenville Rd., Mail Code 600-1WA 

Naperville IL 60563 

Voice 630-961-7650 Cell 630-649-0314 Fax 630-420-5375 Email hermanrw@bp.com 
-----Original Message----- 

From: Hermanson, Robert W [mailto:robert.hermanson@bp.com] 

Sent: Monday, April 13, 2009 9:45 AM 

To: Shine.Brenda@epamail.epa.gov 

cc: Coburn, Jeff B.; Hustvedt.Ken@epamail.epa.gov; Parrish, Kristin 

Subject: RE: BP Visit Re NSPS Ja Flaring / Hermanson Reply 

Sounds good. We'll try to arrive at the front desk around 8:50 or so. I'll assume you'll have an LCD 

projector in the conference room. 

I exchanged emails with a somewhat sheepish Jerry Duke, who says he'll have the data to you this week. 

And I haven't kept up with it, but I thought I heard the report was (finally) issued by TCEQ. 

Regards, 

Bob Hermanson 

Senior Environmental Advisor - Air Advocacy 

BP Products North America, Inc. 

US Refining Central Environmental Compliance & Advocacy Team 

150 W. Warrenville Rd., Mail Code 600-1WA 

Naperville IL 60563 

Voice 630-961-7650 Cell 630-649-0314 Fax 630-420-5375 Email hermanrw@bp.com 

-----Original Message----- 

From: Shine.Brenda@epamail.epa.gov [mailto:Shine.Brenda@epamail.epa.gov] 

Sent: Monday, April 13, 2009 8:37 AM 

To: Hermanson, Robert W 

cc: cob@rti.org; Hustvedt.Ken@epamail.epa.gov; kparrish@rti.org 

Subject: RE: BP Visit Re NSPS Ja Flaring / Hermanson Reply 

Sounds like we're all set. We'll have a conference room available for the morning. Start time around 9? 

Brenda Shine 

Environmental Engineer 

US Environmental Protection Agency 

Research Triangle Park, NC 27711 

(919) 541-3608, Mail Drop E143-01 
"Hermanson, Robert W" 

<robert.hermanson@bp.com> 

04/11/2009 11:25 AM 

To: Brenda Shine/RTP/USEPA/US@EPA 

cc: Ken Hustvedt/RTP/USEPA/US@EPA, 

<cob@rti.org>, <kparrish@rti.org> 

Subject: BP Visit Re NSPS Ja Flaring / Hermanson 

Reply 

Brenda - Thanks. The morning of the 23rd will suit us just fine. I expect we could say what we have to say 

in 2 hours or so, although I suspect we can productively use whatever time you can devote to us. 

Please advise the meeting time, and I'll assume we'll meet at the front desk a few minutes before that. 

Our contingent will likely consist of: 

Elizabeth (Liz) Daly, Environmental Manager, BP Cherry Point Refinery, Blaine WA 

Steven Mrazek, Senior Environmental Engineer, Cherry Point 

Richard Huff, Project Engineer, Cherry Point 

Carrie Phillips, Environmental Engineer, BP Texas City Refinery, Texas City TX 

Ross Vail, Hydroprocessing Technical Superintendent, Texas City 

Ken Comey, Environmental Advisor, BP US Refining Central Team, Austin TX 

and me. 

I will check in with you later in the week. 

Regards, 

Bob Hermanson 

Senior Environmental Advisor - Air Advocacy BP Products North America, 

Inc. 

US Refining Central Environmental Compliance & Advocacy Team 150 W. 

Warrenville Rd., Mail Code 600-1WA 

Naperville IL 60563 

Voice 630-961-7650 Cell 630-649-0314 Fax 630-420-5375 Email 

hermanrw@bp.com 

-----Original Message----- 

From: Hermanson, Robert W [mailto:robert.hermanson@bp.com] 

Sent: Friday, April 10, 2009 11:36 AM 

To: Shine.Brenda@epamail.epa.gov 

cc: Hustvedt.Ken@epamail.epa.gov; Coburn, Jeff B.; Parrish, Kristin 

Subject: RE: BP Visit Re NSPS Ja Flaring 

Brenda - 

 

Thanks for quick response. I've offered your date(s) to our contingent. One of them had earlier said he 

had a conflict for the 23rd, so I'm waiting to see if he can resolve it. If he can't, we'd likely ask for the next 

week, or, alternately, come in two groups, one on the 23rd, one the following week. 

Will advise ASAP, probably once the west coasters get the coffee moving around their bloodstreams. 

Again, please advise if you'd like to hear something in particular in addition to us telling you about: 
- Flaring issues related to TAR at our modern, integrated, single-train refinery at Cherry Point (WA). 

- Flaring quantities and compositions at the "Ultracracker" at our Texas City refinery (older, complex, less 

integrated). 

We will have two process experts (one from each site), along with site environmental staffers and 

assorted ne'er-do-wells (like me). 

Regards, 

Bob 

Bob Hermanson 

Senior Environmental Advisor - Air Advocacy 

BP Products North America, Inc. 

US Refining Central Environmental Compliance & Advocacy Team 

150 W. Warrenville Rd., Mail Code 600-1WA 

Naperville IL 60563 

Voice 630-961-7650 Cell 630-649-0314 Fax 630-420-5375 Email 

hermanrw@bp.com 

-----Original Message----- 

From: Shine.Brenda@epamail.epa.gov [mailto:Shine.Brenda@epamail.epa.gov] 

Sent: Friday, April 10, 2009 7:41 AM 

To: Hermanson, Robert W 

Cc: Hustvedt.Ken@epamail.epa.gov; cob@rti.org; kparrish@rti.org 

Subject: RE: BP Visit Re NSPS Ja Flaring 

Hi Bob, 

It looks like Thursday the 23rd would work for us, or we could try for the week following (the week of the 

27th), although Mon and Tuesday (27, 28) are out, but Wed, Thursday would be okay. 

"Hermanson, Robert W" 

<robert.hermanson@bp.com> 

04/09/2009 05:17 PM 

To: Brenda Shine/RTP/USEPA/US@EPA 

cc 

Subject: RE: BP Visit Re NSPS Ja Flaring 

Thanks. Airfares shoot up as departure date approaches. Call cell 630-649-0314 if you have questions 

("soft" vacation at home this week as #2 son is spending spring break studying for Academic Decathlon 

Nationals in two weeks). 

Regards, 

Bob 
-----Original Message----- 

From: Shine.Brenda@epamail.epa.gov [mailto:Shine.Brenda@epamail.epa.gov] 

Sent: Thursday, April 09, 2009 4:00 PM 

To: Hermanson, Robert W 

Subject: Fw: BP Visit Re NSPS Ja Flaring 

Hi Bob, 

This slipped through the cracks-- let me check on availability and I'll get back to you asap. 

Brenda Shine 

Environmental Engineer 

US Environmental Protection Agency 

Research Triangle Park, NC 27711 

(919) 541-3608, Mail Drop E143-01 

"Hermanson, Robert W" 

<robert.hermanson@bp.com> 

04/09/2009 11:59 AM 

To: Ken Hustvedt/RTP/USEPA/US@EPA 

cc 

Subject: RE: BP Visit Re NSPS Ja Flaring 

KC - Thought any more about a date? We need to set up our travel arrangements, earlier notice is better. 

From: Hustvedt.Ken@epamail.epa.gov [mailto:Hustvedt.Ken@epamail.epa.gov] 

Sent: Friday, April 03, 2009 5:13 PM 

To: Hermanson, Robert W 

Cc: Lucas.Bob@epamail.epa.gov; Shine.Brenda@epamail.epa.gov; Coburn, Jeff B.; Parrish, 

Kristin 

Subject: Re: BP Visit Re NSPS Ja Flaring 

we will need to coordinate with you on this next week. thanks for the quick reply, we are now meeting 

with the Hovensa folks after the 4/17 API meeting. 

kch 
"Hermanson, Robert W" 

<robert.hermanson@bp.com> 

04/03/2009 03:56 PM 

To: Ken Hustvedt/RTP/USEPA/US@EPA 

cc 

Subject: BP Visit Re NSPS Ja Flaring 

KC - Thanks for agreeing to meet with a contingent of BP staff to discuss information related to flaring at 

BP refineries. 

After checking schedules, it appears our group could visit you on Tues 21 April or Weds 22 April. As a 

less-preferred alternate, we could be available on Mon 20 April or Thursday 23 April. 

Our first choice would be Tuesday morning, but any time during the window above would suit. If none of 

these dates work for you, please advise soonest and I'll investigate alternates. 

Unless you advise otherwise, we'll plan to meet you at the reception area at OAQPS in RTP a few 

minutes before our assigned time. I will furnish you a list of visitors as soon as we decide who's 

appropriate. 

As you and I discussed, and if you're still in agreement, I'd like to cover three topics: 

• More detail about the flare flow data I included in the BP comments to the 22 Dec 08 proposal. 

That data was from our Texas City refinery's Ultracracker unit. 

• Information about flare flows during turnarounds and other extraordinary events. This will relate to 

our Cherry Point (Blaine, WA) refinery, which is a modern, highly-integrated, single-train refinery. 

• And, of course, any questions you would like to ask our delegation, which will include process 

experts in addition to plant environmental staffers. 

Please advise if you'd like us to attempt to address other topics. I am not aware that any of the 

information we might present is business confidential. If that situation arises, I'll let you know beforehand 

and you can advise on the appropriate protocols. 

To minimize our travel costs, I'd appreciate it if you could set a date and time as soon as it's convenient. 

Regrettably, owing to other internal meetings, I will not be attending the Friday 17 April meeting of you 

and the industry group. 

Please don't hesitate to call or email if you have questions or comments. 

Regards, 

Bob 

Bob Hermanson 

Senior Environmental Advisor - Air Advocacy 

BP Products North America, Inc. 

US Refining Central Environmental Compliance & Advocacy Team 

150 W. Warrenville Rd., Mail Code 600-1WA 

Naperville IL 60563 

Voice 630-961-7650 Cell 630-649-0314 Fax 630-420-5375 Email hermanrw@bp.com