Date: September 16, 2014

To: Brenda Shine, EPA/OAQPS/SPPD

From: Jeff Coburn

Subject: Meeting Minutes for September 9, 2014, Meeting Between the U.S. EPA and Representatives of API

On September 9, 2014, representatives of th e U.S. Environmental Protection Agency (EPA) and their contractor (RTI International) pa rticipated in a meeting with representatives of the American Petroleum Institute (API). The names and affiliations of the participants are
included in Attachment 1 . The purpose of the meeting was to further discuss some of API’s concerns regarding the proposed sector rule . Discussion topics are summarized below.

API representatives discussed the need for a standard for atmospheric pressure relief devices (PRDs) instead of the rele ase prohibition in the proposal. It was noted that the Bay Area
and South Coast both have rules concerni ng atmospheric PRD releases. The EPA representatives suggested that if the industry planned to comment on the need for a PRD standard, they should also consider how monito ring and compliance data should be recorded and reported.

API representatives next suggested that the pr oposed visibility and velocity provisions for flares be deleted. According to API representa tives, recent flare studies at Marathon Garyville indicate that, as long as there is a visible flame, exit velocity is not important. Therefore, according to API representatives, a visible flame requirement can be used rather than an exit velocity limit. With respect to the visible emissi ons limit, API representatives suggested that this is not a relevant parameter for hazardous air po llutant (HAP) control. A smoking flare does not necessarily indicate that one is ge tting poor HAP destructi on. In fact, the formation of soot is an indication that HAP are being destroyed, according to API representatives. Therefore, according to API representatives, smoking flare provisi ons are more appropriate in the new source performance standards (NSPS). The NSPS provisions will ensure the flares are operated without smoking and below the velocity limits during norm al operations, but allow smoking and velocity exceedances during startup, shutdown, and malfunction (SSM) events.

API representatives noted concern regard ing the 1 pound per hour limit for halogenated streams sent to the flare. API representatives not ed that this limit might be workable if the mass flow rate was determined on an annual average ba sis. The EPA representatives noted that this provision was taken from the Hazardous Organi c NESHAP (HON) and that the limits were generally evaluated on an annual average basis rath er than an instantane ous or hourly basis.2 API representatives then disc ussed the need for a “bright-l ine” when equipment can be opened up for maintenance. API representatives noted that these sources were previously
excluded from the definition of miscellaneous process vents (MPV), but this exclusion was removed in the proposed definition of MPV. API representatives suggested that these vents be
excluded from the definition of MPV. If the EPA wants to set requirements related to these periodic maintenance activities, the EPA should se t separate requirements for these, such as reducing concentrations to below 10 percent of the lower explos ive limit. API representatives noted that Texas and Louisiana have good st ate standards that cover these sources.

API representatives then discussed issues related to the site-specific opacity limit for fluid catalytic cracking units (FCCU) that us e tertiary cyclones. According to API representatives, these cyclones consistently meet the PM emissions limit when tested, but generally end up with a 10 percent opacity limit based on the site-specific opacity limit calculations. However, these units do not con tinuously meet a 10 percent opacity limit. API representatives argued that opacity is not a direct correlation with PM emissions and that a higher opacity limit (30 percent) should be allo wed. The EPA representatives noted that the proposed rule included provisions for PM CEMS . The API representatives believed that provision was only available to units subject to the Refinery NSPS subpart Ja. Furthermore, the API representatives noted that the PM CEMS were expensive and were not considered reliable for refinery operations (only one PM CEMS is currently used at a refinery). The API representatives stated that owners or operators of facilities with tertiary cyclones on their FCCU would be willing to test annually to demonstrat e continued compliance with the PM/metal HAP emissions limit if they could keep the 30 per cent opacity limit (that was in Refinery NSPS subpart J).

API representatives presented cyclone effi ciency curves for primary cyclones at a Marathon facility. The cyclone efficiency curves showed that PM rem oval efficiencies of 98 percent or higher were achieved with cyclone en trance (face) velocities of 20 feet per second or greater. API representatives were still collecti ng additional information, but the stated that the face velocity requirement would ensure good PM removal during FCCU startup and shutdown and would be more achievable than the pr oposed 30 percent opacity limit. The API representatives also noted th at the oxygen and temperature provisions provided for sulfur recovery unit (SRU) shutdowns should also be allowed during SRU startup. According to the API representatives, during forced shutdowns, su ch as shutdowns due to hurricanes or power outages, the units will not be completely purged of sulfur. When the unit starts up, the sulfur remaining in the unit will get purged from the unit as gases begin to flow through the SRU reactors. During this startup, the SRU incinera tor can ensure the sulfur HAP compounds are destroyed, but the SO 2 concentrations will exceed the SO 2 concentration limits that were established for normal operations.Attachment 1 Participants in September 9, 2014 EPA/API Meeting

API Representatives Matt Todd, API Dave Pavlich, Phillips 66 Kris Battleson, Chevron Charlie Bennett, Marathon Petroleum Charles Feerick, ANS Erin Tullos, ExxonMobil George Graham, ExxonMobil

U.S. EPA Representatives
Andrew Bouchard
Art Diem
Eric Goehl Penny Lassiter
Brenda Shine Peter Tsirigotis

RTI International (EPA contractor)
Jeff Coburn