Date: July 28, 2010

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

From: Kristin Sroka

Subject: NSPS Subpart J Review: Meeti ng Minutes for December 22, 2009, Conference Call Between the U.S. EPA and Representa tives of the Petroleum Refining Industry

Introduction

On December 22, 2009, representa tives of the U.S. Environmental Protection Agency (EPA) and their contractor (RTI International) pa rticipated in a stakehol der conference call with representatives of the American Petroleum In stitute (API), the West ern States Petroleum Association (WSPA), and others from the petroleum refining industry. The names and affiliations of the participants are included in Attachment 1. The purpose of the conference call
was to discuss various issues regarding the hydrogen sulfide (H 2 S)/sulfur monitoring requirements in EPA’s reconsid eration of NSPS subpart Ja.

Discussion

The first issue raised by industry representati ves was that the monitors to demonstrate compliance with the 162 ppm H 2 S concentration requirement and to identify flare discharges of

more SO 2 than the flare sulfur root cause analysis (RCA) threshold of 500 pounds have different spans. The industry representatives asked whethe r that means two analyzers might be required. The EPA representatives agreed that it is possible that two monitors might be needed to cover the range of possible concentrations.

The second issue raised by industry representatives was the span value for the H 2 S/sulfur monitor required for RCA purposes. In particular , the industry representa tives noted that there were no span values specified in the current provisions of NSPS subpart Ja. The EPA representatives stated that they expected the span to be determined on a site-specific basis based
on the maximum H 2 S concentration of a stream that is routed to that flare. The industry representatives asked if there we re any specific accuracy requirem ents. The EPA representatives noted that the relative accuracy te st audits (RATA) requirement is ± 15%. The industry representatives noted th at if they use a dual range monitor with ranges of 0-300 ppmv and 0- 10,000 ppmv (to demonstrate compliance with both requirements), readings between 300 and 1,000 would be less certain than values closer to the center of eac h individual range. Additionally, they expressed sa fety concerns with perfor ming RATA on streams with concentrations in the high range, as well as pract ical issues with titrat ing large quantities of H 2 S.2

They noted that Performance Specification 7 sa ys to use EPA Method 11 and EPA Method 11 is impractical for flares, particularly when the flow to the flare is rare or sporadic; they suggested cylinder gas audits be allowed.

The need for continuous flow monitors fo r flares was also discussed. Industry representatives noted that flow monitors are not necessary for certain flares. For example, if a flare has a flare gas recovery system or is an em ergency flare that maintains a water seal most of the time, water seal monitoring should be adequate . The industry representatives suggested that if the water seal monitor shows flow, that coul d automatically trigger RCA without the need for
a flow monitor.

The industry representatives asked how a modi fication to one flare in an interconnected flare system would affect the requirements on the other flares. The EPA representatives indicated that they would have to consider the issue.

At the conclusion of the call, the EPA repr esentatives noted that they expected the amendments to subpart Ja to be signed in early 2010.Attachment 1 Participants in December 22, 2009 Conference Call

Industry Representatives Charlie Bennett, Marathon Petroleum Company Dennis Bolt, Western States Petroleum Association (WSPA) Khary Cauthen, API Ron Chittim, API Luis Comas, Sunoco Inc. Howard Goldman, Hess Corp. Theron King, ConocoPhillips Jan Laughlin, ConocoPhillips Norman Morrow, Fresh Air Consulting Matt Todd, API Bill Wehrum, Hunton & Williams

U.S. EPA Representatives
Bob Lucas
Brenda Shine

RTI International (EPA contractor)
Kristin Sroka