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) 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 concerns regarding the startup and shutdown provisions for the fluid catal ytic cracking unit (FCCU). For this meeting, the API representatives included FCCU operators/e xperts 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 cau se an exceedance of the opacity limit due presence of steam in the exhaust).

 The ESP needs to be de-energized whenev er there are relativel y 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 sy stems used for different FCCU, the API representatives suggested basing the part iculate 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/shut down events; only one F CCU 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 le vels 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 ni ne of the FCCU operators surveyed bypass the2 CO boiler during startup; one had partial flow to the CO boiler and partia l flow to the bypass;
and two of the nine use the CO boiler to tr eat FCCU exhaust gas during startup. The API representatives stated that, due to the relativ ely 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 th eir recommendations fo r 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 star tup, 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 not ed that the proposed amendments are taking away the compliance option to m eet the Refinery NSPS (40 CFR pa rt 60, subpart J) limits. The API representatives noted that FCCU equipped w ith 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 percen t. 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 refine ry 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 measur e of mass PM emissions, the API representatives suggested that the 30 percent opacity limit (like in Refinery NSPS subpart J) should be provi ded 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