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) particip ated in a meeting with representatives of the Marathon Petroleum Company LP (MPC). The na mes 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 repres entatives, 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 pr oposed rule does not “ban” atmos pheric PRDs; it only states that atmospheric releases of PRDs in organic hazardous air polluta nts (HAP) service would be a violation of the standard. In addition, the prea mble to the proposed rule noted that the EPA

could use its discretion on whethe r to file enforcement actions for rare and small PRD releases. The MPC representatives noted that they would still be liable to ci vil 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 ha d reviewed their refineries to assess the number of atmospheric PRDs. Most of th e MPC refineries have a limited number of atmospheric PRDs and most of these PRDs ar e 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 or ganic HAP service” and subject to Refinery MACT 1 (40 CFR part 63, subpart CC). MPC repr esentatives noted that vacuum systems could be “in organic HAP service and they considered routing vacuum system s 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, a nd if steam gets pulled into the flare header, it can condense (and possibly freeze in northern refineries), blocki ng the flare header piping and limiting the system’s ability to relieve pressure. The MPC representatives noted that significant2 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 ha d recently purchased a refinery with 227 atmospheric PRD. When asked by the EPA repr esentatives 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 in troduced the concept of a “layers of protection analysis” (LOPA) and “process safety manageme nt standard” (PSM) that were part of the Occupational Safety and Health Administration (O SHA)’s and the EPA’s risk management plan

standards. Under these standard s, a facility could choose to imp lement a number of different process controls that would grea tly limit the probability of havi ng an atmospheric release rather than controlling the atmospheric PRD.

The MPC representatives then discussed the hi storical 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 whic h 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, c ontrolling atmospheric PRDs at their historical refineries would require installa tion of two new flares. The cap ital costs of the flares and new piping systems was estimated to be $25-milli on 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 cons ider work practice standards, such as quarterly monitoring of atmospheric PRD or continual improvement st andards 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 representati ves 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 re fineries. However, the prop osed flare requirements would require significant changes to their current flar ing operations. First, the MPC representatives stated that the hydrogen (H 2 )-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 concentrati on is greater than the hydrogen concentration. Second, the MPC representatives stated that th e 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 compositi on. The MPC representatives suggested that a 3-hour average, similar to the provisions in th eir consent decree, would be more reasonable. They also noted that, for high hydrogen streams, the net heating value lim it (especially at the H 2

- olefin interaction operating limit) would be di fficult to achieve even though these high hydrogen

streams have been demonstrated to achi eve high combustion efficiency. The MPC representatives noted that they are allowed to use a higher net he ating 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 pr oposed operating limits are too3 complicated and that most operators would elect to comply with onl y 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 c onsent decrees as an alternative to complying with the proposed flare operating limits.

The MPC representatives also expressed concern about severa l 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 in sipient smoke point. Some black soot may appear in the flame but then is further co mbusted. 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 th rough C7 hydrocarbons. This requires too much time (more than 15-minutes) for analys es. 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 pr oblematic. Currently, flares are included as controls for catalytic reforming units under Refinery MACT 2 (40 CFR part 63, subpart UUU), but these streams ma y 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 loadi ng, 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