TELEPHONE CONTACT SUMMARY – 0210426.004.015

FROM: Karen Schaffner, RTI International

DATE OF CONTACT: May 20, 2010

ORGANIZATION CONTACTED:

American Petroleum Institute and Members

Participants:

Matt Todd, API Jeff Adams, BP Charlie Bennett, Marathon Carol Butero, KinderMorgan Clay Freeberg, Chevron

Bill Fritz Bob Hermanson, BP John Lowe, Chevron Jack McClure, Shell John Wagner
Peter Weaver, ILTA

Peter Weichart

Other API members

Steve Shedd, EPA Karen Schaffner, RTI

SUMMARY OF CONTACT

The purpose of the conference call was to follow up on t he risk and technology review (RTR) project at EPA for the marine vessel loading sourc e category. EPA continues to work on the RTR project, however the schedule for RTR is still being negotiated and so no announcement has been made on the re-proposal date. Current EPA activities related to the re-proposal are startup, shutdown, and malfunctio ns (SSM) issues, the petition from NRCS related to the missing standards that need addres sing, and rerunning the risk analysis for the approximately 230 facilities in the NEI database (original proposal was 135 facilities). EPA is also looking at the whole facil ity risk in addition to the source category risk. For the preliminary risk assessment res ults, there are several facilities with risk greater than 1 in 1 million maximum individual risk (MI R). EPA is intending to

conduct site visits to several facilities to see the MVL operations and discuss the HAP

emissions data.2

Certain parts of 40 CFR part 63, General Provisions, subpart A that are related to SSM provisions were vacated. EPA is addressing startup and shutdow n provisions in the reproposal package.

EPA reviewed the 2005 NEI dataset and identified additional f acilities in the MVL source category based on a source classification code (S CC) analysis. These facilities have been included in the risk analysis. API members as ked about seeing the data for the

additional facilities that have been included in the MVL source category and offered to verify applicability of the rule and to review the data an d provide corrections. There was discussion on whether the SCCs are specific enough to al low determination of loading that would not be part of the source category, for exam ple, dry product bulk loading.

EPA indicated that the two missing standards identified in NRDC’s petition will be addressed, including: existing major sources with MVL emiss ions less than 10 or 25 tons of HAP, and existing major offshore facilities. EPA is reviewing use of submerged fill as a control technique for the subcategories. API members not ed that use of submerged fill varies from facility to facility: is done for barges but not certain about tanker ships. API members indicated they would have to follow up on tanker ve ssels. EPA asked that API provide information on the use of submerged fill including num ber of vessels, age of vessel, commodity loaded, vapor pressures, etc. EPA in dicated that cost information for retrofitting vessels with submerged fill would be apprecia ted as well. EPA continues to talk with other groups about the use of submerged fill, inc luding the Coast Guard and the American Waterways Alliance. API members noted that di scussions with the American Chemistry Council (ACC) may also be beneficial. API m embers also noted that they did not see EPA’s obligation to address the subcategories beca use there has been no ruling by the court on the MVL NESHAP. EPA noted that they are addressing standards for all emission points under this source category.