Date: September 15, 2014 

To: Brenda Shine, EPA/OAQPS/SPPD 

From: Jeff Coburn 

Subject: Meeting Minutes for August 8, 2014, Meeting Between the U.S. EPA and 

Representatives of Marathon Petroleum Company 

On August 8, 2014, representatives of the U.S. Environmental Protection Agency (EPA) 

and their contractor (RTI International) participated in a meeting with representatives of the 

Marathon Petroleum Company LP (MPC). The names and affiliations of the participants are 

included in Attachment 1. The purpose of the meeting was to discuss MPC’s concerns and 

issues with the proposed refinery sector rule. 

The MPC representatives first described their concerns with the pressure relief device 

(PRD) requirements. According to the MPC representatives, PRDs are required for safety, they 

do not release to atmosphere often, and emissions related to these releases are minimal. The 

MPC representatives also noted that the “ban” on atmospheric PRDs becomes effective upon 

promulgation and refineries would need more time to comply with this requirement. The EPA 

representatives noted that the proposed rule does not “ban” atmospheric PRDs; it only states that 

atmospheric releases of PRDs in organic hazardous air pollutants (HAP) service would be a 

violation of the standard. In addition, the preamble to the proposed rule noted that the EPA 

could use its discretion on whether to file enforcement actions for rare and small PRD releases. 

The MPC representatives noted that they would still be liable to civil suits and that the rule does 

effectively ban atmospheric PRD based on their corporate policy, given that an atmospheric 

release could be construed as a “knowing and willful violation.” 

The MPC representatives stated that they had reviewed their refineries to assess the 

number of atmospheric PRDs. Most of the MPC refineries have a limited number of 

atmospheric PRDs and most of these PRDs are on liquefied petroleum gas (LPG) tanks or 

vacuum systems. LPG tanks are often remote and could not be easily tied to an existing flare. 

The EPA representatives noted that LPG tanks generally do not contain HAP. As such, it is 

unlikely that LPG storage tanks would be “in organic HAP service” and subject to Refinery 

MACT 1 (40 CFR part 63, subpart CC). MPC representatives noted that vacuum systems could 

be “in organic HAP service and they considered routing vacuum systems to a flare to be 

technically infeasible. First, there is concern about pulling air into the flare header system. 

Second, vacuum systems often use steam ejectors, and if steam gets pulled into the flare header, 

it can condense (and possibly freeze in northern refineries), blocking the flare header piping and 

limiting the system’s ability to relieve pressure. The MPC representatives noted that significant 
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engineering analysis is needed to determine if existing PRDs can be tied into an existing flare or 

if a new flare would be needed. 

The MPC representatives noted that they had recently purchased a refinery with 227 

atmospheric PRD. When asked by the EPA representatives about the disparity between the 

number of atmospheric PRDs at this refinery compared to other MPC refineries, the MPC 

representatives first noted that this was a very large refinery, so it would be expected to have 

more atmospheric PRDs. However, they also introduced the concept of a “layers of protection 

analysis” (LOPA) and “process safety management standard” (PSM) that were part of the 

Occupational Safety and Health Administration (OSHA)’s and the EPA’s risk management plan 

standards. Under these standards, a facility could choose to implement a number of different 

process controls that would greatly limit the probability of having an atmospheric release rather 

than controlling the atmospheric PRD. 

The MPC representatives then discussed the historical PRD releases from MPC refineries 

(excluding the newly purchased refinery). Since 2009, MPC has had four HAP service 

atmospheric releases from PRDs, only one of which exceeded the reportable quantities threshold. 

The total emissions from these releases were less than 5 tons of volatile organic compounds 

(VOC). According to the MPC representatives, controlling atmospheric PRDs at their historical 

refineries would require installation of two new flares. The capital costs of the flares and new 

piping systems was estimated to be $25-million and would increase operating costs by $1.1-

million per year. Given these high costs for small emissions reductions, the MPC representatives 

suggested that the EPA should consider work practice standards, such as quarterly monitoring of 

atmospheric PRD or continual improvement standards such as those in the EPA’s risk 

management plan standards. 

The second key discussion topic for the MPC representatives was the proposed flare 

provisions. The MPC representatives noted that they were the first company to enter into a 

consent decree with the EPA and that they have already established operating limits to ensure 

good flare performance at their refineries. However, the proposed flare requirements would 

require significant changes to their current flaring operations. First, the MPC representatives 

stated that the hydrogen (H2)-olefin interaction criterion was too broadly applied. The MPC 

representatives stated that the effect is limited to propylene only (rather than all olefin) and 

should apply only when the propylene concentration is greater than the hydrogen concentration. 

Second, the MPC representatives stated that the 15-minute averaging time for the operating limit 

is too small. They noted that, since the GC measurement results are only available once every 

10 to 15 minutes, one is always controlling based on historical concentrations, which may not be 

appropriate for the current flare gas composition. The MPC representatives suggested that a 

3-hour average, similar to the provisions in their consent decree, would be more reasonable. 

They also noted that, for high hydrogen streams, the net heating value limit (especially at the H2-

olefin interaction operating limit) would be difficult to achieve even though these high hydrogen 

streams have been demonstrated to achieve high combustion efficiency. The MPC 

representatives noted that they are allowed to use a higher net heating value for hydrogen in their 

consent decree. The EPA representatives noted that the proposed rule would allow compliance 

with any of the applicable operating limits and that a high hydrogen stream would be able to 

comply with the combustibles concentration limit and/or the lower flammability limit. The MPC 

representatives stated that the control algorithms based on the proposed operating limits are too 
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complicated and that most operators would elect to comply with only the net heating value limit. 

The MPC representatives suggested that the EPA should allow flares that are subject to consent 

decrees to comply with their consent decrees as an alternative to complying with the proposed 

flare operating limits. 

The MPC representatives also expressed concern about several other proposed 

requirements for flares, as indicated below: 

 Daily EPA Method 22 visual readings needed to be clarified. According to the MPC 

readings, the best combustion occurs at the insipient smoke point. Some black soot may 

appear in the flame but then is further combusted. The visual observations should be 

made two flame lengths from the flame tip to allow any soot that is temporarily produced 

within the flame to burn off; only soot (black smoke) that persists well downstream of the 

flame should be considered as visible emissions. 

 The GC calibration requirements cited in Performance Specification (PS) 9 are 

inappropriate. PS 9 requires speciation through C7 hydrocarbons. This requires too 

much time (more than 15-minutes) for analyses. The EPA should allow quantification of 

C5+ compounds in aggregate rather than speciation of specific C5, C6, and C7 

hydrocarbons. 

 The ban on halogenated vent streams may be problematic. Currently, flares are included 

as controls for catalytic reforming units under Refinery MACT 2 (40 CFR part 63, 

subpart UUU), but these streams may contain halogenated compounds. 

 The EPA should allow for the use of pressure-assisted flares. These flares generally 

cannot meet the flare velocity limits. 

 Flares associated with marine vessel loading, loading racks, or wastewater treatment 

systems should have reduced monitoring requirements. 

 
Attachment 1 

Participants in August 8, 2014 EPA/MPC Meeting 

Marathon Petroleum Company LP (MPC) Representatives 

Charlie Bennett 

Ruth Cade 

Jacob Fournier 

Nik Larsen 

Jeff Sexton 

Joe Stevens 

Scott Evans (Clean Air Engineering) 

U.S. EPA Representatives 

Eric Goehl 

Penny Lassiter 

Brenda Shine 

RTI International (EPA contractor) 

Jeff Coburn