Date: August 25, 2014

To: Brenda Shine, EPA/OAQPS/SPPD

From: Jeff Coburn

Subject: Meeting Minutes for July 23, 2014, Meeting Between the U.S. EPA and Representatives of API

On July 23, 2014, representatives of the U.S. Environmental Protection Agency (EPA) and their contractor (RTI International) particip ated in a meeting with representatives of the American Petroleum Institute (API). The names and affiliations of the participants are included
in Attachment 1 . The purpose of the meeting was to discuss API’s key concerns with the proposed sector rule. Discussion topics are summarized below.

API representatives first requested that th e EPA provide an extension to the comment period, noting the fact that the package included numerous rule s and several new significant provisions. The EPA stated that they were evaluating the request.

API’s first key issue with the proposed sector rule was the applicability of the flare velocity and visible emissions at all times. A ccording to the industry re presentatives, flares are typically designed to operate in a smokeless manner up to about 20 percent of their “full hydraulic load” and the flares are not designed to meet the flare velocity and visible emissions limits during “full hydraulic load.” The industry representatives explained that “full hydraulic
load” was the total maximum flow that the flar e header system could handle. Full hydraulic loads could occur during significant periods of upse t, such as a loss of electrical power that triggers emergency shutdown for numerous processes or the entire refinery. Flares are sized to handle full hydraulic loads during these safety events . New flares are only added if the full relief rate needed exceeds the existing flare’s hydrauli c load capacity. However, flares may only operate at these load rates once every 2 to 5 year s; during normal operations , flare vent rates are well below the 20 percent full hydr aulic load rate, and can opera te in a smokeless manner with discharge rates below the maximum allowed flare tip velocity. If refineri es were required to meet the visible emissions limit and flare tip velo city limit at all times, they would need to effectively increase the number of flares per refine ry by 3 to 5 times. The cost of this would be in the billions of dollars; the environmental impa cts of this would be a net increase natural gas consumption and emissions from flares due to the need to continually maintain pilot flames and purge gas flow in these flares so they can be ready to receive emergency relief gas once every few years. Thus, API representatives stated that some exclusion is needed from the flare velocity
and visible emissions limitations du ring periods of emergency relief.2 API’s second key issue with the proposed sect or rule was the prohi bition on atmospheric pressure relief device (PRD) discharges. The in dustry representatives cited a study done as part of the 2005 Bay Area rule for pressure relief devi ces, which indicated that there were 329 PRDs at 5 refineries, which would require 7 new flares and cost approximately $17-million to control. Extrapolating these costs nationwide suggests that the costs associated with the proposed PRD requirements are significantly more than projected by the EPA.

API representatives then disc ussed a number of other issu es that they had with the proposed sector rule. These include:

 Alternative standards for FCCU startup/s hutdown - the 30 percent opacity limit is
not achievable.

 Flare operating limits – the EPA should have a single limit and eliminate the H 2

- olefin interaction limit as it is difficult to determine and will cause operators to target the 380 Btu/scf limit to avoid bei ng out of compliance. API representatives prefer a 200 Btu/scf limit and suggested that , since most of the data were from steam-assisted flares, the operating limits for unassisted and air-assisted flares
should not be revised.

 Miscellaneous process vents – revised defi nition appears to include bleeder valves that need to be opened when preparing a vessel for entry or maintenance. Need maintenance/startup/shutdown provisi ons, perhaps based on work practice procedures, for these rarely used vents.

 Fenceline monitoring – API described thei r pilot study (9 refineries of various sizes in 7 states). They noted that they saw significant variability between duplicate samples sent to different labs a nd suggested that the concentration limit threshold needs to account for this variability.

 Delayed coking units – source is already regul ated, so no standard is necessary. If a limit is established, the limit should be 5 psig.

 Flare pilots – the rule should not require auto-ignition for flare pilot gas. Autoignition systems have been very unreliable so very few refineri es have them; most refineries use manual ignition systems.

 QA/QC requirements are not appropriat e (e.g., can’t do quarterly QA checks on pilot flame monitors); the EPA should require a monitoring plan and follow manufacturer’s guidelines.

 Equipment leaks – disagree with the defi nition of seal for open-ended lines.

 No halogen to the flare requirement – was not specifically described in the preamble and the 1 lb/hr limit is too low.Attachment 1 Participants in July 23, 2014 EPA/API Meeting

API Representatives Charlie Bennett, Marathon Petroleum Jacob Fournier, Marathon Petroleum Bob Hermanson, BP Tom Gilmartin, BP Charles Feerick, ANS Tyler Kruzich, Chevron Kris Battleson, Chevron Bill Henning, Phillips 66 Michael Wardinsky, Phillips 66 Tim Goedeker, Phillips 66 Erin Tullos, Phillips 66 Shari Keller, Shell John Wagner, API Matt Todd, API Norm Morrow, Fresh Air Consulting George Graham, ExxonMobil

U.S. EPA Representatives
Andrew Bouchard
Art Diem
Gerri Garwood
Eric Goehl
Jodi Howard Penny Lassiter
Brenda Shine Peter Tsirigotis

RTI International (EPA contractor)
Jeff Coburn