Date: May 18, 2009 

To: Docket ID No. EPA-HQ-OAR-2007-0011 

From: Kristin Parrish 

Subject: NSPS Subpart J Review: Meeting Minutes for January 29, 2009, Conference Call 

Between the U.S. EPA and Representatives of Flint Hills Resources 

On January 29, 2009, representatives of the U.S. Environmental Protection Agency 

(EPA) and their contractor (RTI International) participated in a stakeholder conference call with 

representatives of Flint Hills Resources (FHR) regarding alternative monitoring options for flares 

with flare gas recovery. The names and affiliations of the participants are included in 

Attachment 1. The information provided by FHR prior to the call is included as Attachment 2. 

The representatives from FHR described the current flow and sulfur monitoring practices 

for the flares under their consent decree. The EPA representatives asked clarifying questions to 

better understand the monitoring alternatives. They asked the representatives from FHR to 

include as much detail as possible in their forthcoming public comments on the subpart Ja 

amendments. They noted that if the FHR alternative has nationwide applicability, they could 

consider adding it to the regulatory text. If the monitoring technique is more site-specific, then 

the rule allows FHR the opportunity to apply for an alternative monitoring plan and prove that 

their monitoring methods are equivalent to the requirements in subpart Ja. 

For more detail on the alternative monitoring methods, see Attachment 2 and FHR’s 

public comments in the docket at EPA-HQ-OAR-2007-0011-0303. 
Attachment 1 

Participants in January 29, 2009, Conference Call 

FHR Representatives

Michele Pugh, Director, Environmental Affairs, FHR 

Eric Kaysen, Vice President, EHS, FHR 

John Seitz, Partner, ES&P, LLC 

U.S. EPA Representatives

Bob Lucas 

Brenda Shine 

RTI International (EPA contractor)

Jeff Coburn 

Kristin Parrish 
Attachment 2 

FHR Background Information 

 

"Pugh, Michele" 

<Michele.Pugh@fhr.com> 

01/28/2009 10:13 AM 

To: Bob Lucas/RTP/USEPA/US@EPA 

cc: "Kaysen, Eric" <Eric.Kaysen@fhr.com>, "John Seitz" 

<JSeitzesp@atmc.net> 

Subject: FHR Background Information 

As requested, attached is some background information on the FHR Consent Decree and flare system for 

our meeting tomorrow regarding an alternative monitoring option as part of NSPS Subpart Ja. 

Michele Pugh 

Director, Environmental Affairs> 

Flint Hills Resources 

Phone: 316-828-8412 

Fax: 316-828-8405 

michele.pugh@fhr.com 

(See attached file: FHR Background_Subpart Ja.doc) 
Background For Meeting Between Flint Hills Resources and the Environmental 

Protection Agency – Proposed NSPS Subpart Ja 

Flint Hills Resources, LP (FHR) operates refineries in Pine Bend, Minnesota, Corpus 

Christi, Texas, and North Pole Alaska. In Corpus Christi there are two refineries, the 

East Refinery and the West Refinery. 

In 2000 Flint Hills Resources’ predecessor company, Koch Petroleum Group, LP, entered 

in to a Consent Decree which includes the refineries in Pine Bend and Corpus Christi. As 

part of this Consent Decree FHR agreed to a flare policy that would minimize flaring 

events by following good engineering practices. This includes flare gas recovery systems 

designed and operated to capture most anticipated loads to the flare system, a 

management system to keep the base load into the flare system within the system’s 

recovery capacity, and a management system designed to minimize, and if feasible, 

prevent, unexpected loads or unexpected failures of the flare gas recovery system. FHR 

also agreed to conduct root cause failure analysis on significant flaring events, defined as 

any single event from which SO2 emissions exceed 500 pounds in a 24-hour period and 

which were not associated with a planned startup, shutdown, or maintenance activity. 

Under the Consent Decree FHR has installed three flare gas recovery units, one at the 

Pine Bend refinery and one each at the Corpus Christi East and West refineries. These 

flare gas recovery systems run well below their capacities and capture normal process 

flows. Essentially, only process upset gases are routed to the flare. The only exception 

in 2008 was maintenance on the flare gas recovery system itself. In order to determine 

whether a root cause failure analysis is required FHR currently calculates sulfur 

emissions from the flare based on gas sampling and flow calculations. 

FHR believes that continuous sulfur and flow monitoring as proposed in Subpart Ja 

(proposed §60.107a(e) and proposed §60.107a(f), respectively) is not justified in cases 

where only process upset gas is going to the flare and therefore only the root cause 

analysis/corrective action triggers are applicable. In cases were maintenance on the flare 

gas recovery system would cause non-process upset gases to be sent to the flare the 3-

hour and 365-day H2S limits could still be calculated. 

FHR is recommending an alternative monitoring plan that, in place of continuous flow 

and sulfur monitors, would allow refineries; to monitor pressure drop across the flare seal 

drum in order to calculate flow rates, sample the flare gases to determine H2S 

concentration, and monitor flare gas recovery unit capacity to verify that normal process 

flows are being captured.