From: "Higgins, Cortney" < Cortney_Higgins@omb.eop.gov >

To: Brenda Shine/RTP/USEPA/US@EPA

Cc: Ann Johnson/DC/USEPA/US@EPA

Date: 11/15/2011 02:34 PM

Subject: RE: Heat exchanger Package-- 2 revisions we want to make

Hi Brenda,

These changes are fine. Thanks for checking with me. I’ll make a note in my files that the signed version is

different from the one we concluded review of.

In the future, though, we want to make sure that the Administrator’s office review is concomitant with OMB

review, to avoid these post

‐ review changes.

Regards,

Cortney

From: Shine.Brenda@epamail.epa.gov [ mailto:Shine.Brenda@epamail.epa.gov ]

Sent: Tuesday, November 15, 2011 2:30 PM

To: Higgins, Cortney

Cc: Johnson.Ann@epamail.epa.gov Subject: Heat exchanger Package-- 2 revisions we want to make

Cortney:

Per my voice mail, here are the 2 changes we woul d like to make to the package that you already

cleared.

In the summary,



### SUMMARY: This action proposes amendments to the heat exchange system requirements of the national emission standards for hazardous air pollutant (NESHAP) for petroleum refineries in response to a petition for reconsideration filed by the American Petroleum Institute on the maximum achievable control technology standards we promulgated on October 28, 2009. We are also proposing other clarifications and technical corrections, and we are creating national uniform standards for heat exchange systems, largely based on the heat exchange system provisions that we adopted for petroleum refineries, and accompanying general provisions. We are proposing to revise the existing petroleum refinery NESHAP to cross-reference the uniform standard to allow an alternative option for complying with the standards for heat exchange systems. As a result, instead of retaining these heat exchanger requirements in the Refinery

### NESHAP, we are proposing to cross reference those provisions as they would be included in the new uniform standards. The proposed uniform standards would allow refiners to reduce monitoring frequency and burden by meeting a lower leak definition. If finalized, these national uniform standards would also be referenced, as appropriate, as we revise in the future NESHAP or new source performance standards (NSPS) for individual source categories that have heat exchange systems. Establishing a uniform standard for heat exchange systems is consistent with the objectives of Executive Order 13563, “Improving Regulation and Regulatory Review,” issued on January 18, 2011. We are also proposing other clarifications and technical corrections to the petroleum refineries NESHAP.

Also, on page 58 of the package-- we noticed we still had a paragraph that refere nces to other uniform standards, which you requested we take out of the pac kage earlier--so to be consistent- we would take out the following paragraph:



### As described previously in this preamble, we are also planning to propose uniform standards for other emission points, including storage vessels and transfer operations, equipment leaks and ancillary systems, wastewater collection and treatment systems, and control devices. We believe that the uniform standards will promote the EPA's ability to simplify, clarify and improve implementation of the rules with which source owners or operators must comply.

Brenda Shine Environmental Engineer US Environmental Protection Agency Research Triangle Park, NC 27711 (919) 541-3608, Mail Drop E143-01