Date: August 27, 2014 

To: Brenda Shine, EPA/OAQPS/SPPD 

From: Jeff Coburn 

Subject: Meeting Minutes for August 7, 2014, Meeting Between the U.S. EPA and 

Representatives of API 

On August 7, 2014, representatives of the U.S. Environmental Protection Agency (EPA) 

and their contractor (RTI International) participated 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 concerns regarding the 

startup and shutdown provisions for the fluid catalytic cracking unit (FCCU). For this meeting, 

the API representatives included FCCU operators/experts to discuss technical issues with the 

meeting various requirements during startup and shutdown. 

The following issues were noted or discussed: 

 Steam is often used to circulate catalyst at start-up and this steam interferes with 

automated opacity measurements (can cause an exceedance of the opacity limit due 

presence of steam in the exhaust). 

 The ESP needs to be de-energized whenever there are relatively high carbon monoxide 

(CO) levels for safety reasons (prevent fires or explosions). 

 Operators will often need to bypass the SCR to prevent plugging during start-up. 

 Due to the differences in the control systems used for different FCCU, the API 

representatives suggested basing the particulate matter (PM)/metal hazardous air 

pollutant (HAP) limit on the primary cyclone operation, since all FCCU have primary 

cyclones. 

After discussing these issues, the API representatives presented a typical timeline for 

FCCU startup. Startups generally require 24 to 48 hours to dry out the refractory prior to adding 

feed to the unit; torch oil is used to heat the system during this time. The API representatives 

presented data summaries for 26 startup/shutdown events; only one FCCU met the 30 percent 

opacity limit for the entire startup. In order to limit thermal stress on the unit and refractory, 

most FCCU will operate in the hot standby mode (using torch oil) when there is a temporary 

issue with an upstream or downstream unit. High levels of CO exist whenever torch oil is used. 

The API representatives also presented the results of an informal survey of operators that have 

FCCU that are followed by CO boilers. Six of nine of the FCCU operators surveyed bypass the 
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CO boiler during startup; one had partial flow to the CO boiler and partial flow to the bypass; 

and two of the nine use the CO boiler to treat FCCU exhaust gas during startup. The API 

representatives stated that, due to the relatively large volume of gas from the FCCU and the 

variability of the heat content of that gas (due to fluctuating CO levels), most facilities cannot 

effectively operate the CO boiler during the FCCU startup. 

The API representatives then presented their recommendations for FCCU startup and 

shutdown provisions. These were: 

 Apply the 1 percent oxygen concentration limit to all FCCU (regardless of whether or not 

there is a CO boiler on the unit). 

 Use a minimum face velocity (suggested 20 feet per second) for the first stage (primary) 

cyclones internal to the FCCU regenerator. 

 Apply these limits to all startup, shutdown, or hot standby events. These events can be 

defined as times when torch oil is used in the FCCU regenerator. 

As a last point, the API representatives noted that the proposed amendments are taking 

away the compliance option to meet the Refinery NSPS (40 CFR part 60, subpart J) limits. The 

API representatives noted that FCCU equipped with tertiary cyclones were no longer allowed to 

comply with the 30 percent opacity limit, but had to comply with a site-specific opacity limit, 

which was often close to 10 percent. The representatives noted that opacity is influenced by 

particle size. If there are more small particles, the opacity will increase, but the mass emissions 

would not. Data were presented for one refinery showing that it met the PM mass limit during 

annual testing but that the FCCU did not meet a 10 percent opacity limit at all times. Because 

opacity is an imperfect measure of mass PM emissions, the API representatives suggested that 

the 30 percent opacity limit (like in Refinery NSPS subpart J) should be provided in the rule as a 

means to demonstrate compliance with the PM limit for FCCU with tertiary cyclones. 

 
Attachment 1 

Participants in August 7, 2014 EPA/API Meeting 

MPC Representatives 

Matthew Todd, API 

Charles Feerick, ANS 

J. W. Wilson, BP 

John Lowe, Chevron 

Thomas Holden, ExxonMobil 

Charlie Bennett, Marathon Petroleum 

Nik Larsen, Marathon Petroleum 

Jeff Sexton, Marathon Petroleum 

Tim Goedeker, Phillips 66 

Michael Wardinsky, Phillips 66 

Norm Morrow, Fresh Air Consulting 

U.S. EPA Representatives 

Andrew Bouchard 

Art Diem 

Eric Goehl 

Penny Lassiter 

Brenda Shine 

RTI International (EPA contractor) 

Jeff Coburn