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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 obtained through fenceline monitoring with 

the emission expected from well-controlled sources? 

3. Do you still expect all refineries will have to provide 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 revised 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 will 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 two-year compliance period for coker depressurization 

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

 What kind of cost per VOCs are you finding 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 question 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 address 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 statutory 8-year review cycle for Ja? 
Uniform Standards 

 Still an indefinite delay on all aspects? 

Refinery GHG NSPS 

 

 Is this a 2014 possibility or more likely 2015?