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### 3**~**From: David Friedman <DFriedman@afpm.org> Sent: Monday, November 11, 2013 5:22 PM To: Shine, Brenda; Lassiter, Penny; Bouchard, Andrew Cc: Person Subject: Issues List for November 14 EPA/AFPM Meeting

Penny, Brenda and Andrew, Attached is an outline of potential discussion issues for our meeting on Thursday from 9-12. We appreciate your taking the time to meet with us and look forward to our discussion.

David N. Friedman Vice President Regulatory Affairs
American Fuel & Petrochemical Manufacturers 1667 K Street NW Suite 700 Washington, DC 20006 202.457.0480 office 202.552.8461 direct 202.457.0486 fax dfriedman@afpm.org

<< EPA1114MeetingOutline.docx >>AFPM Meeting with EPA OAQPS Staff November 14, 2013 9-12 AM Refinery Risk and Technology Rules

 Schedule- Will all portions be ready by February 14, 2014? 1. Is it possible the schedule may still be modified?

 Fenceline Monitoring: 1. Will recent testing and results change the approach? 2. How is EPA correlating the reading obta ined through fenceline monitoring with the emission expected from well-controlled sources? 3. Do you still expect all refi neries will have to prov ide fenceline monitoring?

 Residual Risk
o Is the multi-pathway analysis completed?

 Will we be able to see the results?

 Will the proposed rule preamble include refinery-by-refinery specific risk as determined by the ICR process?
o What is the mechanism for submitting re vised data for use in the modeling?
o We understand the AERMOD model has some flaws that need to be corrected. Has that correction occurred and wi ll it be ready by February 14, 2014?
o How have the model revisions changed the overall analysis of the industry?
o Cumulative impacts: Modeled risk vs. Monitoring risk.
o Are we now looking at a tw o-year compliance period for coker depressurization

 What is the basis for the two-year compliance period

 What kind of cost per VOCs are you fi nding to arrive at that decision?

 Other Requirements
o Flaring thermal efficiency regulatory language?

 Similar to OECA proposal?
o Changes to MACT CC/UUU?
o NSPS Ja fixes? Subpart Ja Reconsideration

 Where do we stand on the issues raised in the Petition for Reconsideration and Review?

 What is the status of addressing those que stion NOT included in the recently released guidance document?

 Flare gas Flow meters: Accuracy vs. Sensitivity

 Flare gas Flow meters: Definition of Total Reduced Sulfur (TRS)

 What mechanism(s) will EPA use to addre ss the remaining industry issues and the NGOs?
o Apart from GHGs, what is the status of addressing the NGO reconsideration requests?

 Where do we now stand on the statut ory 8-year review cycle for Ja?Uniform Standards

 Still an indefinite delay on all aspects? Refinery GHG NSPS

 Is this a 2014 possibili ty or more likely 2015?