Date: June 17, 2010

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

From: Kristin Sroka

Subject: NSPS Subpart J Review: Meeti ng Minutes for November 19, 2009, Meeting Between the U.S. EPA and Representative s of the Petroleum Refining Industry

Introduction

On November 19, 2009, representa tives of the U.S. Environmental Protection Agency (EPA) and their contractor (RTI International) participated in a stakeholder meeting with representatives of the American Petroleum Ins titute (API), National Petrochemical & Refiners Association (NPRA), and others from the petroleum refining industry. The names and affiliations of the participants are included in A ttachment 1. A copy of the presentation slides used in Dr. Richard Waibel’s presentation is pr ovided in Attachment 2. Other handouts provided by the industry representatives are included in At tachments 3 and 4. The purpose of the meeting
was to discuss various issues re garding EPA’s petroleum refinery rulemaking efforts, and one of the topics was reconsideration of the NSPS subpart Ja process heater and fl are provisions. This memorandum documents the portion of the meeti ng that was relevant to NSPS subpart Ja.

Discussion

The EPA representatives indicated that th ey had analyzed the additional continuous emissions monitoring system (CEMS) data for NO X from process heaters submitted by industry representatives. They noted th at turndown did not appear to be as much of an issue for poor

NO X performance as operating at high excess oxygen c oncentrations. They al so noted that they
had evaluated a mass-based emission limit alternativ e as a potential means to address periods of turndown; however, it did not appear to be helpfu l. Most of the process heaters could meet the concentration limit already, and those that did no t could not meet the a lternative mass limit being considered either. The EPA representatives in dicated that they are considering including a method for requesting an alternat ive limit on a case-by-case basis for process heaters that have
the latest ultra-low NO X burner technology installed but still cannot meet the emission limit while in turndown. Industry representatives indi cated that they thought the issue related to turndown is more pervasive than a case-by-case alternative would indicate, but having a case-bycase alternative would be an acceptable option.

Dr. Waibel presented some of John Zink’s test facility resear ch results for burner studies firing at turndown (see Attachment 2). He noted that, at turndown, they mix furnace gas with fuel to get NO X reductions and moderate peak flame temp eratures. The cool furnace gas affects flame stability, so they generally need to run at higher excess oxygen conc entrations – typically2

3 percent excess oxygen. The EP A representatives asked why ma ny process heaters operate at excess oxygen levels of 5 to 10 percent. One industry representative noted that they could typically operate at exce ss oxygen concentrations as low as 3 to 4 percent without running into flame stability issues, but the furnace temperat ure decreases as oxygen co ncentration decreases, and they do not want the process heater temperature to get too lo w. Dr. Waibel noted that John Zink conducted recent testing to assess the effects of controll ing excess oxygen concentration, and they found that at low oxygen concentrations , the carbon monoxide concentration increases (as the furnace temperature decreases, the combusti on quality of the fuel d ecreases). He stated
that if the carbon monoxide c oncentration gets to o high, it can extinguish the flame in the burners, which would cause safety issues. It was also noted that, wh en excess (outlet) oxygen concentrations are high, the burners are not really operating as low NO X burners any more.

The industry representatives provided a positi on paper giving examples of units that operate in turndown and options for emissions limits that could be applied to those situations (see Attachment 3). The industry representatives then summarized circumstances that may lead to a process heater operating at turndown conditions. The following circumstances were
described:

 Startup or shutdown of a process un it served by that process heater.

 Amount of heat needed by the process: Certain processes, partic ularly hydrotreaters, do not require as much heat when the catalys t is fresh. As the catalyst gets old and begins to deactivate, then more heat is needed to support the reaction.

 Change in process feed material: The pr ocess heater may be designed to accept cold intermediates from off-site, so if it begins processing warm intermediate from on-site, the amount of heat input required from the process heater would decrease.

 Re-purposed process heater: An old process heater from one application may be used for a different application requiring less heat input.

 Energy efficiency project: Recovering heat fr om one process to partially preheat feed reduces the heat input needed from the existing process heater.

The discussion then turned to flare provisi ons. Industry represen tative re-iterated the need to be able to use cylinder gas audits (rat her than trying to perfor m a RATA for the sulfur monitors during actual flaring ev ents). They also suggested th at monitoring of the flare water seal be used to eliminate false positives when the installed flow monitor registers very small flows. When asked why this small flow would be an issue, the industr y representatives noted that they are concerned with tripping the ro ot cause analysis (RCA ) threshold of 500 pounds SO 2 per 24 hours for very large flares. See Attachme nt 4 for copies of the handouts they provided detailing their positions on these two issues. Finally, the industry representatives noted that the top of a dual range H 2 S monitor is typically 3-5 percent. They expressed concern that they may be required to install two monitors to cover the ra nge of potential H 2 S concentrations, and they
indicated that a sec ond monitor was not need to show that an RCA is needed.Attachment 1 Participants in November 19, 2009 Meeting

Industry Representatives Charlie Bennett, Marathon Petroleum Company Ron Chittim, API Clay Freeburg, Chevron David Friedman, NPRA Bob Hermanson, BP Matt Hodges, Valero Energy Corp. Jan Laughlin, ConocoPhillips Jack McClure, The JLM Group Bob Morehouse, ExxonMobil Norman Morrow, Fresh Air Consulting Matt Todd, API Doug Van Pelt, ExxonMobil John Wagner, API Richard Waibel, John Zink Bill Wehrum, Hunton & Williams

U.S. EPA Representatives
Bob Lucas
Brenda Shine
Nick Parsons Pat Foley

RTI International (EPA contractor)
Jeff Coburn
Kristin Sroka