Date: October 15

, 20 1 4

To: Brenda Shine, EPA/OAQPS/SPPD

From: Jeff Coburn

Subject: Meeting Minutes for October 8 , 2014

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

O n October 8 , 2014, representatives of the U.S. Environmental Protectio n Agency (EPA) and their contractor (RTI International) participated in a meeting with representative s 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 further discuss some of API’s concerns regarding the refinery sector rule proposal . Discussion topics included opacity standards for fluid catalytic cracking units (FCCUs), venting from atmospheric pressure relief devices (PRDs), and flare requirements

.

FCCU s

API representatives stated that there is no correlation between particulate matter (PM) emission rates and opacity. The API representatives claim ed they have supporting data for this

assertion and will submit it for the EPA to review. Based on the ir data, the API representatives do not believe site specific opacity limits for these units are appropriate and recommend ed changing the limit to 30 percent opacity. The API also requested the averaging period for opacity

measurements be increased from 6 minute averages to daily or 3 hour averaging periods. Finally, API representatives stated that more frequent testing could be performed (i.e, annually rather than once every 5 years) to ensure compliance.

PRDs

API representatives presented their ideas for requirements for PRD based on best industry practices and their review of the Bay Area and South Coast rules. The API representatives recommended the implementation 3 prevention measures for all process unit PRDs and recommended that the EPA provide a spe cific list of activities or systems that would be considered to a prevention measure. An atmospheric release from a process unit PRD would trigger a root cause analysis (RCA) and corrective action analysis (CAA) similar to the RCA/CAA requirements in the R efinery NSPS subpart Ja. API representatives suggested that, if 3 releases occur over a 5 year period, the EPA trigger should be to require implementation of a fourth prevention measure rather than requiring the PRD to be piped to a flare.

The API represe ntatives also noted that there are small PRDs throughout the refinery ( such as relieve valves on sampling lines to prevent over

- pressuring of analyzers) that should

have less stringent requirements. The API representatives suggested that PRDs less than 2inches in diameter, PRDs installed on portable or mobile devices (i.e, those regulated by the Department of Transportation (DOT) or the U.S. Coast Guard ) , and PRDs on units with vapor pressure less than 2.5 pounds per square inch gauge should not be requir ed to install flow monitoring systems or have 3 prevention measures. API representatives suggested that releases from these small PRDs would still be subject RCA/CAA requirements . API representatives plan to submit draft regulatory language for their propo sed approach in their comments . The EPA requested that cost data for this proposed approach also be included in their comment package

.

Flares

API representatives stated that the flare tip velocity requirement of 400 feet per second could be exceeded during upset conditions. API representatives also stated that the data supporting the correlation between the flare tip velocity and combustion efficiency were based

on an old and limited data set. They also asserted that heat content is a better indicator of

co mbustion efficiency. They requested maintaining only the heat content limits in the final rule and removing those related to flare tip velocity. Finally, API representatives discussed the visible emissions standards and requested that the final rulemaking have an allowance for periods of smoking during an emergency malfunction or upset.

2Attachment 1

Participants in October 8 , 2014 EPA/API Meeting

API Representatives Charlie Bennett, Marathon Petroleum Charles Feerick, ANS George Graham, ExxonMobil

Shari Keller, Shell Norm Morrow, Fresh Air Consulting

Dave Pa v lich, Phillips 66

Matt hew Todd, API Erin Tullos, ExxonMobil John Wagner, API

U.S. EPA Representatives

Andrew Bouchard

Eric Goehl Penny Lassiter

Brenda Shine

RTI International (EPA contractor)

Je ff Coburn

Leslie Pearce