# 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 In ternational) participated in a stakeholder meeting with

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

Cherry Point and Texas City refi neries. The names and affilia tions of the participants are

included in Attachment 1. The purpose of the m eeting was to discuss va rious issues regarding

the EPA’s reconsideration of flar es in NSPS subpart Ja. Attachme nt 2 contains the presentation

slides used by the Cherry Point representative s, and Attachment 3 c ontains the presentation

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

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

provides correspondence between the EPA and BP regarding meeting planning.

Discussion

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

Additional points made by the BP re presentatives are described below.

Flare Monitoring

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

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

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

is a flaring event, the flare gas blows the water ou t 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 even t 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 propos ed subpart Ja fuel gas standard s at their refinery. As shown

on Slide 19 of Attachment 2, they plan to inject chemicals re ferred to as hydrogen sulfide (H 2 

# S)

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

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

in Alaska. They noted that through this process, the H 2 

# S is bound to long-chain amines and

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

wastewater treatment plant with di fferent 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 th at they plan to test the techni que during the upcoming turnaround. One

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

flare.

Other

The Texas City refinery participated in a te st 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 th e results of that st udy. The Texas City

representatives agreed to look into the ma tter 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 & StandardsCherry Point RefineryNSPS Subpart Ja Flare BriefingEPA Office of Air Quality Planning& StandardsApril 23, 20092Who we are...•Elizabeth Daly Environmental Superintendent, Cherry Point•Richard HuffProcess Development Superintendent, Cherry Point•Robert Hermanson Senior Regulatory Advisor, US Refining•Steven Mrazek Senior Environmental Engineer, Cherry Point3Purpose/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 concerns4Cherry Point Refinery•Large single train refinery built in 1970-71•2 steam assisted, smokeless flaresdesignated high & low pressure flares•Flare Gas Recovery Unit added in1984−Reduced SO2emissions 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 each)•Coker Blowdown Vapor Recovery added in phases in 2003 & 2005−Reduced SO2by 106 tpy−Separate 6-stage 5,000 HP centrifugal compressor−Backup plan, use FGRU w/ both compressors on LP flare header5Cherry Point Process FlowCrudeVacuumDieselFrac.VacuumTowerNHDSUnitCokerCokerDehexHydrocrackerH/CDehex#1 Calciner#2 Calciner#3 Calciner#1 DHDS#1 Reformer#2 ReformerReformateSplitterGasolineBlendingButaneSplitterLEU &LPGH2 PlantHRUSouth SRUNorth SRU#1 TGUCALCINEDCOKELPGI C4MIXED C4’sUNLEADEDREGULARUNLEADEDPREMIUMJET FUELDIESELHI SulfurDIESEL500ppmSULFURLRFFlare GasRecoveryFUEL GASC5’sCrudeDehexISOMHDS(IHT)BenSatPenexLEUDe-isobutanizer#2 DHDSDIESEL15ppmC5 – C6C5 – C6LEULEULEUIsomerateCARBOB#2 TGU6Flare Gas Recovery Unit(25-year cumulative impact - 19,500 tons SO2reduced – so far)Utility WaterNatural GasL.P. SuctionDrum PumpH.P. Flare GasL.P. Flare GasL.P. CompressorDisch. K.O. DrumRich DEA to H/CFlash DrumsLean DEA FromLean DEA PumpsRecovered Flare GasTo Fuel Gas Mixing DrumRecovered GasK.O. DrumUtility WaterNatural GasH.P. SuctionDrum PumpH SAbsorberTo BlowdownTo SourwaterSour Water toBlowdown/D-3 orFractionator OVHDH.P. 2ndStageK.O.Drum1803 COMPRESSORH.P. 3rdStageK.O.DrumL.P. 2ndStageK.O.Drum1804 COMPRESSORL.P. 3rdStageK.O.DrumH.P. CompressorDisch. K.O. DrumH.P. 1stStage K.O.DrumL.P. 1stStage K.O.DrumH.P. Flare GasK.O. DrumL.P. Flare GasK.O. DrumH.P. Flare GasSeal DrumL.P. Flare GasSeal Drum15381222153712181326CW1223CW13271224CW132812251503L.P. Flare GasK.O. DrumPump120228071540211071226280812011502H.P. Flare GasK.O. DrumPump13251221CWCWCW1324122013237Flare Schematic8Cherry Point Flares - Normal OperationLP on the left, HP on the right9Low Pressure Flare(less than 200psig 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•ISOM10High Pressure Flare(more than 200 psig units)•#2 Reformer•#1 Reformer•Light Ends Unit•Hydrocracker•#1 DHDS•Hydrogen•#2 DHDS11SO2Emissions from Cherry Point Flares(For Context - Roughly 2.5 - 3.5% of Total Annual SO2)051015202530354045502006 2007 2008

(Tons SO2/ Year)HPLPTotal12Recent Flare Flow History(Please refer to annotated handout for peakidentification)0100200300400500600700 

# 1 /1/2

006 3/1/2006 5 /1/

2006 7 /1/200 6 9/1/2006 1 1/

1/200 6 1 /1/20 07 3 /1/

2007 5 /1/20 07 7/1/2007 9 /1

/2007 1 1/1/2 00

7 1/1/2008 3 /1/

2008 5 /1/200 8 7 / 1/2008 9 /1/

2008 1 1/1/2 00

8 1/1/2009 3 /1/200 9

(MSCFD)LP FLARE (CORR FLOW)HP FLARE (CORR FLOW)13Events > 500,000 SCFDIn 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 failure14#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 SO2emissions < 1 lb./event•RCA would be req’d since flow exceeds 500,000 scfd•Majority of volume is H2sweep, N2purge & steam cleaning•Low gravity gases not suitable for recovery as fuel gas – createsinstability for ULNB that are in use at numerous units15Reformer Process Flow DiagramReformer StabilizerOVHD Liquid to LEUReformateSplitter600# StmHeavy ReformateComminglerReformerReactor No.2ReformerHeater No.1Reactor No. 1Sulfur GuardHot HuxFrom H/CDehexanizerHux FromTank 31Recycle BoosterCompressor(Electric)ToReformateStabilizer (A)Splitter OVHDAccumulatorCompressorK.O.DrumH.P. Flareor Fuel GasRecycleCompressor(Steam Turbine)H.P. FlareMethanolChlorideTrapOff GasBFW/ChemicalInjectionReformateStabilizerCold Hux PumpSplitter Btms PumpSplitter Reflux PumpStabilizer Reflux PumpCondensateFrom #2 Ref.Debut. BtmsLRF RefluxPump140#SteamCondensateLRF Btms PumpLRFBottomsCoolerLightReformateFractionator(LRF)LRF Btms(Mid-Ref)to StorageGasolineCoalescerBFW &NeutralizingAmineMake Gas to Naphtha HDSUnit Recycle CompressorNet Make GasH.P. FlareFuel GasTo HRUReformerHeater No.2ReformerReactor No.3ReformerHeater No.3ReformerReactor No.5ReformerHeater No.4ReformerReactor No.4FlareFlareTo HRUComminglerFrom HRUCommingler600#SteamPreHeaterCondensateREVISIONAUTHDWG. NO.SCALEENGINEERING CONTRACTORDATEPROJECT NO:OPER.APPROVALS#1 REFORMER UNIT 11REACTION & FRACTIONATION SECTIONSPROCESS FLOW DIAGRAMAB-1100-419ANVIL CORP BE8190WO 1880012/4/02NTSBP WEST COAST PRODUCTS LLC.bpCherry Point RefineryYWWSPMPCEPCE(A) FromK.O. DrumStabilizer OVHDAccumulatorLRF OVHDAccumulatorCW120613221803 1802150613091308250314032504140425051405250714062506131012071232131113141317133711021316CW1208133913381318CWCW1103131913211510134212091537CW1340122815361343CWLRFOto Isom250815081509LRFO ProductPump1544LRFO toStorageLRFReboilersFlare1105To SourWaterNCNCNONC1320Light ReformateCoolerLowPressureFlash DrumMake GasCompressorLP Flash DrumBottoms Pump18041315CW1507CW131312051312H.P. FlareNitrogenRecycleGasDryer1346ReactivationGasHeater600#SteamClean CondensateTo Return Unit12337HCFI NC

FC NCNC(NOTE 1)NOTES:1. ONLY TDC- BASEDINSTRUMENTS ARE SHOWN FORSIMPLICITY. LOCAL INSTRUMENTSARE NOT DISPLAYEDFOHCFL98765REV10/0719001378TAYLORFIELD UPDATES PER DR4055RDMAFST09/0719001378O’REILLYCORRECTED COMPRESSOR K.O. DRUM TO 1206 PER DR4687RDMAFKO03/071106AAWOODSRECYCLE GAS DRYER PROJECT ISSUE FOR CLIENT APPROVALSROBASTRP12/04R811ALVADELETED PUMPS 1345 & 1535, ADDED PUMP 1544SCBAFVA01/03WO18800CHRISTENSENFIELD VERIFIED & CONVERTED TO VISIOYWWSPMDATEAUTHPROJ ENGRDESCRIPTIONBYCKDAPP89N.C.916Options to address high volume H2sweeps,N2purges 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 gasrecovery systems – multiple flaresw/o flare gas recovery not affected−More stringent provision than H2S limit, yet not subject to BestDemonstrated Technology Determination•Options to consider:−Do not include volume contribution from steam, H2& N2−Calculate 500,000 SCFD from Baseline Condition which may varydepending on operating mode – normal productions vs. regeneration−Establish cost effectiveness threshold for corrective action−Exempt flaring required tocomply w/ MACT standards−Limit RCA requirements to events that exceed the H2S standard17Hydrocracker/LEU Turnaround•LEU TAR coincides w/ Hydrocracker TAR – the minimum emission case•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 available, cannot goto tankage (MACT TVP limits)•Injection system ensures continuous compliance w/ H2S standard•Corrective action options:−Build second LEU - $70MM minimum−Conduct refinery-wide TAR – same emissions w/ far greater safety andenvironmental risk and still would have flaring between unit startups−Gases not suitable for recovery due to butane content (will compress toform liquid)18Options 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/ flare gasrecovery systems−More stringent provision than H2S limit, yet not subject to BestDemonstrated Technology Determination•Clarify that corrective action is limited to running existing kit better,Establish cost effectiveness threshold for corrective action•Limit RCA requirements to events that exceed the H2S standard•Limit RCA requirement to events that exceed SARA/CERCLA threshold−160 ppm H2S * 500,000 SCF/Day = 15.5 lbs. SO2/Day19NSPS Subpart Ja Compliance Plan(Concept will be tested next week)DesalterWaterStripper1537SteamFlareTail Gas1104UtilityWaterOily WaterSewerStripped WaterSurge Drum12521551-01/0213601359OVHDConds.Crude Pre-fracExchangerTo H/CFuel GasCWCWCWCW13211309OVHDCondensersCWCrude OvhdAccumulator1201Fuel GasH/C 1858Sour Water1511H/CFuel GasCW1311Crude Tower10-1101DebutTower1153Pre-Fract115213631364Waste WaterAnd/orSewerPhenolicWaterStripperNon PhenolicWater StripperFromDesaltersH2SScavengerInjectionNCDebut OvhdAccumulator1203PreFrac OvhdAccumulator1154CompressorSep. DrumLP Flare GasKO Pot1202To Sour WaterTo BlowdownLP Flare GasKO Pot Pump1503LP Flare GasSkim Pot1203OWSLP Flare GasPump Out Pump1501-02To Sour WaterLP Flare GasKO Pot Surge Pump1504HPFlare GasSeal Drum2808OWSHP Flare GasKO Pot Surge Pump1504LP FlareHeaderTo FGRUH2SScavengerInjectionH2SScavengerInjection20Typical 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 (H2+ #3DHDS + EGF?) 2011-2012For CP Refinery these tie-inswill be made upstream of theflare gas recovery unit and won’t increase emissionsPreamble from reproposal specificallysought comment onthe types ofconnections thatshould be allowedw/o triggeringSubpart Ja21For your consideration:•Process or operational changes must increase emissions on albs./hour basis to trigger Ja consistent with FCAA§111•Changes made upstream of recovery compressors are notmodifications since emissions don’t increase – Provided capacityremains•Rule should “incentivize” new recovery systems whileacknowledging the environmental benefits of existing systems

# Attachment 3

Presentation Slides

NSPS Ja Proposed Root Cause Analys is Flow Trigger Review with EPA

BP Products North America, Inc.

Texas City RefineryNSPS Ja Proposed Root Cause AnalysisFlow Trigger Review with EPABP Products North America, Inc.Texas City RefineryTexas 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 crudeoil and other feedstocks per day, equivalent to 7.6 Bn gallons peryear−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 chemicalfeedstocks (20%)BP Texas City Refinery Manufacturing Flow Blending

Hydrogen BlendingUltracracker (ULC) Flare•Serves as a control device for ULC, Ultraformers 3and 4 (UU3 and UU4), and ARU•Continuous and periodic streams vent to flare fromall four units including but not limited to,−Natural gas purges on process vessels and relief headers−Regeneration vent depressures and purges (UU3 and UU4regeneration vents routed to control due to MACT UUU)−Nitrogen purges to prepare equipment for maintenance orto be put back in service−Control of start-up, shutdown and malfunction emissions−Flows from various process units during TurnaroundsULC Flare Flows for the BP NSPS JaCommentsULC Flare Flows(10,000,000)(5,000,000)-5,000,00010,000,00015,000,00020,000,00025,000,00030,000,000

4 /17/200 8 5/1/2 00 8 5 /15/200 8 5 /29/200 8 6 /1 2/200 8 6 /26/200 8 7 /10/20 0 8 7 /24/200 8 8/7/2 00 8 8 / 21/200 8 9/4/2 00 8 9 /18/ 200 8 1 0/2/200 8 10/16/2 00 8 10/30/200 8 11/13/200 8 11 /27/200 8 12/11/200 8 12/25 /200 8 1/ 8/2 009

1 /22/200 9Date

Flow , SCF/dayTotal ULC Flare FlowRecycle Hydrogen, 80% by volumeNet ULC Flare FlowCyclical Regeneration of UU3/UU4 Reactors•Cyclical regeneration for 6 reactors at each unit−Typically one reactor is regenerated every day•Depressurizations, nitrogen purges, and hydrogenpurge 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 measurableH2S−Heating value too low for use as fuel gasNatural Gas used for purging and for heatingvalue 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 theflare header•Used to increase the heating value of gas toensure compliance with 40 CFR NSPS 60.18requirements (300 BTU/scf)−Offset nitrogen and hydrogen purges•Average 1,680,000 scf/day (70,000 scf/hr) ofnatural gas flowSweet Hydrogen Stream during UltracrackerTurnaround•Sweet Hydrogen from Ultraformer reaction process typically routes toUltra cracker (ULC)−87% by volume hydrogen, average 2 ppm H2S−About 2 MMscf/hr from each reformerexported to ULC for compression anduse in other parts of the refinery•During Turnarounds (TAR) of Ultracracker, sweet hydrogen may be routedto fuel gas, subject to volume and composition constraints−Fuel gas system can be limited by volume and composition−Volume limit based on fuel gas systemcapacity (there are other producers offuel gas)−Economic penalties are taken by cutting the FCCUs back to maintainbalance−Composition limit is usually high hydrogen content. This can be a processsafety 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 accompan ying 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 contai ns any confidential business information. (One of

the presentations was modified slightly from the ve rsion 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_B rief_Cherry_Point_20090417.pdf)

(See attached file: EPA_Flare_B rief_Texas_City_20090417.pdf)

# Attachment 5

E-mail correspondence between the EPA and BP regarding meeting planning

# From: Shine.Brenda@epamail.epa.gov [m ailto: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 confidentia l, 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 ra ther 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 des k 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 Du ke, 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 produc tively 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 gro ups, one on the 23rd, one the following week.

Will advise ASAP, probably once the we st coasters get the coffee mo ving 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, int egrated, single-train refinery at Cherry Point (WA).

- Flaring quantities and compositions at the "Ultracracke r" 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) ar e 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 appro aches. 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 chec k 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 [m ailto: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 we ek. 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 visi t you on Tues 21 April or Weds 22 April. As a

less-preferred alternate, we could be avail able 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 a nd 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 y ou 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