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 would 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 references to other uniform 

standards, which you requested we take out of the package 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