Date: September 1 6 , 2014

To: Brenda Shine, EPA/OAQPS/SPPD

From: Jeff Coburn

Subject: Meeting Minutes for August 26 , 2014

, Meeting Between the U.S. EPA and Representative s of Valero

On August 26

, 20 14 , representatives of the U.S. E nvironmental Pro tection Agency (EPA) and their contractor (RTI International) participated in a meeting with representative s of Valero Energy Corporation (Valero)

. The names and affiliations of the participants are included in

Attachment 1

. The purpose of the meeting wa s to discuss Valero ’s concerns and issues with the proposed refinery sector rule

. A copy of the presentation provided by Valero outlining their

issues is included as Attachment 2

. A summary of the key issues discussed is provided below.

The Valero repres entatives expressed the need for separate flare standards during startup, shutdown, and malfunction (SSM) events. The EPA representative s noted that, as stated in the preamble to the proposed rule , the E PA is not set ting standards during malfunction event s because, by definition, these are unpredictable releases. The EPA representatives encourage d the industry representatives to identify things that can be do ne to prevent releases rather than to rely

on separate sta ndards for malfunction events.

The Valer o representatives noted that the proposed change in definition of miscellaneous

process vent (MPV) would further complicate the SSM issue because startup, shutdown, and maintenance events were previously excluded from the definition

, and now it appears rel eases from pressure relief devices (PRDs) may be subject to the MPV control requirements. The EPA representatives noted that the proposed rule specifically excluded “relief valve discharges regulated under §63.648” from the definition of MPV. The Valero representatives also noted that the change in definition of MPV would include vessel degassing that would be needed prior to opening up a vessel for maintenance, for example, to repair or replace distillation column trays or heat exchangers. According to the Valero representatives, these events are rare, have low emissions, and are already regulated under state or local requirements

, and it would be very

burdensome to determine a priori if a given maintenance event would trigger the Group 1 MPV

emissions t hreshold.

The Valero representatives noted that the 30 percent opacity limit could not be met at all times during startup and shutdown of fluid catalytic cracking units (FCCU) equipped with electrostatic precipitators (ESP)

. The Valero representatives sug gested that the EPA allow for up

to four 6

- minute averages of no more than 65 percent opacity over 30 minutes during startup and

shutdown. The Valero representatives also requested clarification that the operating limits forFCCU wet gas scrubbers c ould b e used to comply with the standard emissions limits, if elected, during startup and shutdown. The Valero representatives also suggested that the 1 percent oxygen ( O 2 ) limit should be available for all FCCU, not just those that do not have a post

combustio n device.

The Valero representatives then discussed their concerns with the flare provisions. They noted that Valero has installed flare gas recovery systems at many of their refineries. In their experience, flow meters and composition monitors are not r eliable and cannot handle the wide range of flow conditions that a flare can experience

. They also noted that, with the time delay for obtaining compositional data and highly variable flare gas flow/composition, the flare operating limits may not yield th e results that the EPA expects. The Valero representatives also noted that the daily calibration checks for the composition monitors would require too much time to perform and that refiner s would not be able to get the data needed to comply with the

opera ting limits during these daily calibration checks.

The Valero representatives argue d that the delayed coking units were already controlled under the existing maximum achievable control technology (MACT) standard and that additional requirements under the C lean Air Act s ection 112(d)(2) we re not warranted. They also encouraged the EPA to review the units that are listed as subject to a 2 pounds per square inch gauge ( psig ) limit to confirm whether these units are currently meeting that limit in practice. T he Valero representatives indicated that some of the units listed are not yet required to meet that

limit and modifications to the unit s may be necessary in order to comply with the 2 psig limit (so the unit is not currently m eeting the limit in practice).

The Valero representatives briefly discussed concerns regarding the fenceline monitoring requirements. The Valero representatives suggested that the action level appeared to be set based on normal operating conditions and the action level should be incre ased to account for

SSM events. The Valero representatives indicated that air flow meters should be allowed to determine compliance with the sulfur plant O 2 concentration limit. Finally, the Valero representatives indicated that the compliance times prov ided in the proposed rule were insufficient. Many of the proposed requirements will require equipment shutdowns to install monitoring or control equipment and the rule should allow time to perform these activities during a planned sh utdown or refinery tur naround.

2Attachment 1 Participants in August 26 , 2014 EPA/ Valero Meeting

Valero Representatives Christopher Abshire

Elizabeth Bourbon Deepak Garg Matt Hodges

Paula LaRocca Shelly Williamson

Christi Wilson

U.S. EPA Representatives

Andrew Bouchard

Art Diem

Eric Goehl Penny Lassiter

Brenda Shine

RTI International (EPA contractor)

Jeff CoburnAttachment 2

Copy of Presentation Material for EPA/Valero Meeting August 26, 2014