Date: October 14
, 20 1 4

To: Brenda Shine, EPA/OAQPS/SPPD

From: Jeff Coburn Subject: Meeting Minutes for October 7
, 20 14 , Meeting Between the U.S. EPA and Representative s of Marathon Petroleum Company

On October 7
, 20 14 , representatives of the U.S. E nvironmental Protection Agency (EPA) and their contractor (RTI International) participated in a meeting with representative s of the Marathon Petroleum Company LP (MPC )

. The names and affiliations of the participants are included in Attachment 1

. The purpo se of the meeting was to discuss MPC’s concerns over various requirements in the refinery sector rule proposal . The agenda focused on the following sections of the proposed rule : atmospheric pressure relief devices (PRDs), halogenated vent streams, reforme r standard revisions
, fenceline monitoring, startup
, shutdown and malfunction (SSM) provisions, a s well as the proposed revisions to NSPS Ja

. The memorandum is organized by these areas of concern. The MPC representative s provided a presentation summarizing the ir

concerns ; the presentation is included as Attachment 2 to this memorandum. Additional supporting information related to fenceline monitoring provided by the MPC representatives is included as Attachment 3 to this memorandum. Atmospheric Pressure Rel ief Devices : The MPC representatives expressed their concerns over the equipment monitoring and emissions control requirements as well as the compliance date for atmospheric PRDs in the EPA’s current sector rule proposal. MPC representatives assert ed that the frequency and emissions related to PRD releases in HAP service are small

. Based on their company records, MPC had only 5 PRD releases (in HAP service) considering all 7 of its refineries over the most recent 5 year period ; 2 of these 5 releases exceede d the reportable quantity (RQ) for hydrogen sulfide (H 2 S). The MPC representatives presented an alternate work practice based compliance approach and alternate compliance dates for atmospheric PRDs

. The work practice based approach would require atmosphe ric PRDs to have 3 layers of prevention as described on page 5 of Attachment 2. In addition to requiring 3 layers of prevention, the work practice based compliance approach would require the operator to perform root cause analysis and corrective action for each release. MPC representatives also presented several different examples of the 3 layers of prevention on pages 6

- 9 of Attachment 2. During the discussion of the layers of prevention, the EPA representatives asked why a rupture disk would be considered a prevention method

. MPC representatives explained that these devices were not prone to leaking or“ cha ttering” when the pressure is near, but not necessarily exceeding the pressure set point of the PRD.

MPC representatives also stated that more time woul d be needed to bring these devices into compliance, even under the work practice based compliance approach . MPC proposed a n alternate compliance date of 3 years after rule promulgation or the first plant TAR, whichever is longer.

MPC representatives indica t ed that they follow rigorous design standards governed by EPA’s Risk Management Program (RMP) and Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standards for ensuring the safety of their employees and minimizing rele ases from atmospheric PRDs

. The EPA representatives requested a copy of one of MPC ’s RMP plans to review the existing design standards.

MPC representatives also pointed out that release reporting is currently governed by the requirements of the Comprehens ive Environmental Response, Compensation, and Liability Act ( CERCLA ) and Emergency Planning and Community Right

- to

- Know Act ( EPCRA ) programs. MPC representatives described the reporting requirements of these two programs and requested that the reporting re quirement s in the refinery sector rule proposal be adjusted to coincide with the semiannual MACT report rather than another separate reporting scheme

. The EPA representatives noted that there are community concerns about the availability of the information reported through the CERCLA/EPCRA programs, and that some stakeholders want an immediate, publicly available resource (such as a website, or twitter feed) to receive notifications of releases

. Halogenated Vent Streams : The MPC representative s noted that the provisions for halogenated vent streams in the refinery sector rule proposal do not provide details on the method for demonstrating compliance

. Additionally, MPC requested clarity on the 1 lb/hr limit by asking if this limit is per stream or per the to tal volume of gas to the flare at a given time. MPC also requested clarification on the averaging period for the emissions related to this limit (i.e., hourly or annual averaging). The EPA representatives stated that their intent was to allow process knowl edge and engineering estimate to assess compliance with the limit and that the limit was expected to be evaluated on an annual averaging period.

Reformer Standard Revisions :
The MPC representatives expressed concern that the removal of the exemption from active purging going to the atmosphere during de

- pressurization of the unit prevents the ability to vent nitrogen gas during catalyst dumping or air freeing the system during periods of startup or shutdown . MPC representatives stated that little to no HAP emissions are expected during these events and requested clarification that the proposed rule provisions were not intended to regulate these types of purges.

2Fenceline Monitoring :
The MPC representatives presented the results of ambient monitoring performe d at some of their refineries

. MPC representatives requested that
, in cases where existing monitoring systems exist, the rule should provide some flexibility to utilize those systems. The EPA representatives expressed concerns with relying solely on the ex isting monitoring sites as they do not provide full coverage around the facility

. The MPC representatives asserted that sampling stations should only be required on borders sharing sensitive areas such as schools, residential, hospitals, etc. The historica l readings at the MPC monitors we re all below the EPA ’s proposed action level ; however, the MPC representatives expressed concern s rega rding the proposed action level, particularly for facilities in more industrialized areas where background and other emis sion sources may contribute to the total ambient concentration s measured by the monitors.

SSM Provisions :
MPC representatives discussed the use of Safety Instruments Systems (SIS) on the fluid catalytic cracking unit (FCCU) . This system automatically shu t s the unit down based on pre

defined criteria. MPC representatives presented a list of examples of times when the SIS initiated a system shutdown to demonstrate that these occurrences are not always caused by an equipment malfunction. MPC representatives stated that there have been 40 SIS activations in a 19 month timespan (January 2013 to July 2014) at MPC refineries

. The MPC representatives asserted that the shutdown and subsequent startup related to the SIS activation meet s the definition of startup and shutdown in the MACT general provisions and
, therefore, the EPA should revise the proposed rule to allow the alternate emissions standards for startup and shutdown to apply during these events

. Monitoring Requirements of FCCU : The refinery sector rule pro posal removes the provision for existing FCCUs to comply with the provisions in NSPS J for PM control and, according to the MPC representatives , will force existing FCCU to comply with the monitoring requirements in NSPS Ja . MPC operates one FCCU with a te rtiary cyclone control device in Canton, OH and one FCCU with a baghouse for emissions control in Catlettsburg, KY. MPC representatives provided test data from the Canton, OH FCCU to support their assertion that there is a poor correlation between opacity and PM for this emissions source

. Based on their emissions data, MPC representatives recommend ed removing the site

- specific opacity limit in the MACT rule and replacing it with an annual stack test requirement for cyclone control devices. The EPA represent atives requested that the full test report be submitted. MPC also stated that ther e would be significant challenges with installing a baghouse leak detection system (BLD S ) because of the design of their baghouse and requested that EPA add an option for an alternate monitoring plan for baghouse s in the MACT and N SPS to include pressure drop monitoring and annual emissions testing in lieu of the BLD S

. The EPA representatives noted that the general provisions in 40 CFR parts 60 and 63 allow facilities to requ est the use of an alternative monitoring plan.

3Attachment 1 Participants in October 7 , 2014 EPA/ MPC Meeting

MPC Representatives Charl e s Bennett Nicole Brien Ruth Cade Jacob Fournier Joe Stevens

U.S. EPA Representatives Andrew Bouchard Eric Goehl Penn y Lassiter Brenda Shine

RTI International (EPA contractor) Jeff Coburn Leslie PearceAttachment 2

Presentation Slides
Proposed Refinery Sector Rule Marathon Petroleum Company LP

# Proposed Refinery Sector Rule

October 7, 2014

# Agenda

 Atmospheric Pressure Relief Devices

 Work Practice and Equipment Standard

 Refinery Release Reporting



#  Halogenated Vent Streams

 Reformer Standard Revisions

 Fence Line Monitoring

 Overview of data

 Discussion of alternative monitoring



#  Startup and Shutdown

 SIS systems discussion

 Other concerns



#  NSPS Ja Revisions

2

# Atmospheric Pressure Relief Devices

3

# Atmospheric Pressure Relief Devices EPA Proposal

 Prohibition of relief to atmosphere from gas/vapor pressure relief devices in HAP service

 Installation of monitoring system to detect reliefs to the atmosphere

 Effective at promulgation



## MPC Concerns

 Relief valves are safety devices to protect equipment from significant damage during malfunctions

 Emissions from atmospheric relief events are minimal and existing reporting requirements are in place to capture the events

 Technical reasons why certain atmospheric relief valves can not be connected to a flare system (or other control device).

 Timing of proposal is inadequate, at least 3 years for implementation would be needed.

 Work practices and equipment standards could be implemented to minimize events

# Atmospheric PRD Work Practices & Equipment Standards

 Atmospheric PRD relief standard should be a work practice

 Work practice and equipment standard recommendation:

 Require sufficient prevention methods in a PRD standard

 Require Root Cause Analysis / Corrective Action procedures

 Implementation at 3 years, or at next TAR (whichever is longer)

 Reporting of Atmospheric PRD relief should be done in a semi

- annual report


##  Prevention methods may include any three of the following:

 Rupture disks

 Level monitoring, alarms, and corrective action at high priority alarms

 Pressure monitoring, alarms, and corrective action at high priority alarms

 Staged venting to flare

 Automatic SIS system that would initiate heat source removal or shut down feed supply to equipment

 Mechanical testing of PRV during TAR and installation

 Operator training

5

# ARV Discharge Prevention Scenario 1

6 

### • Rupture Disks are installed under some ATM Relief Valves to prevent malfunctioning relief valves from leaking to the atmosphere needlessly

• Level indication with alarm in bottom of Vessels allow operators to have knowledge of normal liquid level and trends

. Typical installation is a local sight glass and an electronic level signal to the control room

• High pressure alarms to control room trigger differing operator action depending on the level of urgency associated with the alarm ATM

ARV
Set @ Vessel MAWP

Rupture Disk Set @ Vessel

MAWP PAH Multiple alarm set points with elevating

sense of urgency Control Room

Tiered alarm Philosophy

• High Pressure alarm is high priority alarm set below MAWP that triggers troubleshooting guidelines for operators to use in an effort to find and fix the problem

• Not to Exceed Alarm is an urgent alarm set at MAWP that triggers a prescribed set of operator actions that must be taken to bring the situation under control as quickly as possible LI

# ARV Discharge Prevention Scenario 2

7 • Level Switches are installed on some vessels to prevent over pressure by liquid overfill by stopping flow of liquid into the vessel

. Corporate standards do not allow discharge of liquid through atmospheric relief valves

. • Level indication with alarm in bottom of Vessels allow operators to have knowledge of normal liquid level and trends

. Typical installation is a local sight glass and an electronic level signal to the control room

• High pressure alarms to control room trigger differing operator action depending on the level of urgency associated with the alarm ATM

Equipment

Charge LS ARV
Set @ Vessel MAWP

PAH Control Room

Tiered alarm Philosophy

• High Pressure alarm is high priority alarm set below MAWP that triggers troubleshooting guidelines for operators to use in an effort to find and fix the problem

• Not to Exceed Alarm is an urgent alarm set at MAWP that triggers a prescribed set of operator actions that must be taken to bring the situation under control as quickly as possible LI

# ARV Discharge Prevention Scenario 3

8 • Automated pressure Controlled Vents to the flare allow the refiner to vent over pressure events to the flare before the ATM relief valve discharges

. Corporate standards require that a relief valve still be present as a last line of defense in case instrumentation malfunctions

. • Level indication with alarm in bottom of Vessels allow operators to have knowledge of normal liquid level and trends

. Typical installation is a local sight glass and an electronic level signal to the control room

• High pressure alarms to control room trigger differing operator action depending on the level of urgency associated with the alarm ATM

PC
Flare ARV
Set @ Vessel MAWP

Set Below Vessel MAWP

LI PAH Control Room

Tiered alarm Philosophy

• High Pressure alarm is high priority alarm set below MAWP that triggers troubleshooting guidelines for operators to use in an effort to find and fix the problem

• Not to Exceed Alarm is an urgent alarm set at MAWP that triggers a prescribed set of operator actions that must be taken to bring the situation under control as quickly as possible

# ARV Discharge Prevention Scenario 4

9 ATM

PS ARV
Set @ Vessel MAWP

Set Below Vessel MAWP

Fuel Gas PAH Control Room

Tiered alarm Philosophy

• High Pressure alarm is high priority alarm set below MAWP that triggers troubleshooting guidelines for operators to use in an effort to find and fix the problem

• Not to Exceed Alarm is an urgent alarm set at MAWP that triggers a prescribed set of operator actions that must be taken to bring the situation under control as quickly as possible

LI

• Automated Pressure trips will stop the supply of heating medium to some distillation towers to stop pressure build before the ATM relief valve discharges

. Corporate standards require that a relief valve still be present as a last line of defense in case instrumentation malfunctions

. • Level indication with alarms in bottom of Vessels allow operators to have knowledge of normal liquid level and trends

. Typical installation is a local sight glass and an electronic level signal to the control room

• High pressure alarms to control room trigger differing operator action depending on the level of urgency associated with the alarm

# Atmospheric PRDs Summary

 MPC has existing systems in place that adequately address HAP reliefs to atmosphere and believes these should not be addressed as violations in the refinery sector rule

 MPC follows rigorous existing design standards governed by EPA’s RMP and OSHA PSM regulations.

– MPC already has a policy in place that incorporates API 521 for safe relief of atmospheric PRDs

– This includes appropriate dispersion modeling to ensure community and plant individuals will not be harmed by release when installing new PSVs


##  Equipment standards and work practices should be implemented

 Work practice and equipment standard recommendation:

 Require at least 3 defined prevention methods in a PRD standard

 Require RCA/CA analysis

 Implementation at 3 years, or at next TAR (whichever is longer)

 Reporting of atmospheric PRD relief should be done in a semi

- annual MACT report

10

# EPA Release Reporting Flow Chart

11

# MPC Notification Process

 A release occurs

 Refinery personnel evaluate what has been released and make estimates on the quantities

 At the same time personnel are working to mitigate the release if it has not yet been secured

 Refinery personnel make calls to proper agencies (local, state, federal) within 15 minutes of discovery

 Once event has been secured, an investigation occurs to determine the cause of the release

 Written follow

- up notifications are submitted and include the final emissions estimate from the event and often a cause

12

# Halogenated Vent Streams

13

# Halogens

 The proposed refinery sector rule includes a ban on halogenated streams going to the flare

 Compliance demonstration not included in the proposed rule

 MPC has reviewed our systems and identified some streams that may be above the 1 lb / hr limit on a short

- term basis during Startup, Shutdown, or Malfunction activities.

 Halogenated streams in a refinery are corrosive. Refineries have incentives to minimize concentrations due to metallurgy and corrosion concerns.

 Due to moisture in flare header, believe that these drop out with water in the flare knock

- out drum.



##  Monitoring for some of these streams may be unsafe and systems may be costly to install

 Location of 1 lb / hr limit compliance point is not defined

14

# Sources at a Refinery: CRUs and Isom Units

 Catalytic Reforming Units and Isomerization Units

 CRUs and Isomerization units use perchloroethylene

 Use in reactors results in chlorinated compounds that meet the definition of halogenated streams in the proposed rule



##  Streams identified:

 Recycle hydrogen

 Turnaround and maintenance activities



##  Current controls for chlorides:

 Chloride guard beds



##  Current monitoring for hydrogen:

 Dragger testing for HCl

 Levels monitored for breakthrough



##  May not be measurable in total flare gas volume in the flare header

15

# General Reformer

16 

# Flare

# Sources at a Refinery: HF Alkylation

 HF Alky

 HF Alky units have hydrocarbon streams that contain amounts of HF

 Streams that have a potential to have HF are scrubbed

 Scrubbers are monitored using based on caustic strength

 Keeping HF out of the flare is in a refineries best interest

– HF service piping is much more expensive that piping used for normal flare systems

– HF will cause damage to piping and quickly lead to leaks in the lines if not scrubbed adequately

– HF will also destroy columns in the GCs for the flare systems at fairly low concentrations fairly quickly if they get to the system



##  Monitoring for HF specifically requires multiple safety precautions

17

# General Alky

18 

# Flare

# Compliance Recommendations

 Provide exemptions if scrubbers or chloride guard beds are used on stream prior to flare.

 Establish a 1 lb / hr compliance standard on an annual basis.

 Clarify compliance determined by
1. Engineering estimate and process knowledge
2. Monitor on a unit by unit basis where treatment beds are already found

– Compliance at the flare tip would require additional monitoring

19

# Reformer Standard Revisions

20

# Reformer Standard Revision
 The proposed rule removes the exemption from active purging going to atmosphere during de

- pressuring of the unit

 The proposed rule also removes the maintenance vent exemption under the miscellaneous process vents section

 Concerns with shutdown of continuous catalytic reformers (CCRs)

 Catalyst dumping

 Air freeing the system on startup

21

# Reformer Standard Proposed Revisions

 Continuous nitrogen purge needed for safety while catalyst dumping from reactor

 Pyrophoric material in reactors could cause unsafe conditions in the reactor

 Routing to flare could potentially cause the same issue in the flare line



##  Nitrogen purge is also needed to air

- free the unit on startup

 Whole system purged with nitrogen to atmosphere to remove air

 Routing this purge to flare could cause safety issues in the flare lines

 Issue when catalyst change out has not occurred

22

# CCR Shutdown Process
 Regenerator shutdown

 Feed Pulled from Unit

 Hot hydrogen sweep

 De

- pressure reactor to flare

 Nitrogen purge to flare

 Blind Reactor

 Open reactor to atmosphere with purge

 Begin catalyst dump

23 

# Feed

N 2


# H 2 

# Catalyst Flare

Regen

Reactor

# Recommendations

 Nitrogen purges to atmosphere are needed during shutdown activities to prevent pyrophoric ignition and little to no HAP expected

 Use engineering knowledge to e xempt from MPV standard during unit catalyst dumping and initial air freeing of the unit

 MPC wants to ensure periods of catalyst dumping and initial air freeing of the unit are still permitted to go to atmosphere as they are not part of the normal operation of the unit and fall after the initial depressuring of the unit

 MPC also wants to ensure maintenance venting events such as this remain to be allowed under the miscellaneous process vents section

 If these are not correct assumptions, MPC would suggest language be added to the rule to allow for these events

24

# Fenceline Monitoring

25

# Diffusion Tube Fenceline Monitoring Systems

 MPC has collaborated with EPA with diffusion tube studies at our Texas City Refinery. We have also implemented studies at Robinson Refinery, as well as developing plans to collect additional diffusion tube samples in late 2014/2015 system

- wide.

 In general, we support API & AFPM; however, our concerns & comments will focus on the technical aspects of implementation

 Ability to utilize existing fence

- line monitors in lieu of diffusion tubes

 Protocol for diffusion tubes located on common fence

- lines between 2 industrial

sources

 Investigation procedures that tie diffusion tube results back to a regulated MACT source and underlying standard

 Cost

- effectiveness demonstration and thresholds for implementing corrective actions

26

# Fenceline Monitoring Discussion

 MPC passive monitoring

 Results similar to EPA NATTS national ambient air monitoring



#  Need for alternative monitoring

 Texas City industrial area

 Garyville

 Detroit



#  Need for work practice

2728 

# Refinery Passive Monitoring Results
– Robinson

Results are below EPA’s proposed levels of concern.29 

# Follow

- up Monitoring Results

# Refinery Fenceline Monitoring Results

 Results are below EPA levels of concern

 Permitted tank cleaning operation during initial monitoring

 Lower results in follow

- up monitoring when tank cleaning was complete



#  Benzene loading rack may be influenced by idling train engines spotting railcars

 Monitoring at property line can result in lower concentrations (concentration is an inverse cubic relation: double the distance and concentration goes down by about 1/8).

30

# Need for Alternative Monitoring

 States have implemented ambient air monitoring that meets the needs of the local community

 History of monitoring below action level should qualify for alternative compliance demonstration

 MPC’s existing systems use either continuous GC monitoring, summa canisters or trigger sample analysis

31

# Texas City Area 2011 Benzene Concentrations

32 MPC Galveston Bay Refinery 11 th St 0.8 31 st St 0.3 Logan St 0.5 Ball Park 0.5 2 nd Ave 0.4 34 th St 0.2

Avenue A 0.2

GBR On

- site 0.8

Source: TCEQ March 11, 2013 Air Pollutant Watch List Proposed Change 

### Monitoring Meets State and Community Needs33 

# MPC Monitoring at Garyville ( 7 VOC trigger samples; 1.7 ppb 24

- hour maximum )

0.27 ppb



### Monitoring Meets State and Community Needs

# MPC Monitoring Results at Detroit annual ppb canister samples

34 0.68 ppb @ 4

- E 0.47 @ 2A

- N 0.46 ppb @ 1

- N

0.48 ppb @ Mark Twain Middle School 

### Monitoring Meets State and Community Needs

# Need for Work Practice

 EPA proposed:

 “... a HAP concentration to be monitored in the ambient air around a refinery, that if exceeded, would trigger corrective action to minimize fugitive emissions ”

 “... may need to take some corrective action to minimize fugitive emissions.”

 Fugitive emissions include: tank seals, water seals from wastewater equipment, equipment leaks



#  Purpose of passive monitoring is to enhance MACT standards

35

# Monitoring is Influenced by non

- Refining Sources Reported Levels of Benzene ( μ 

## g/m3)


## EPA proposed annual RCA/CA trigger: 9

 EPA Ambient 1994: 1.5 to 5.0

 EPA Ambient 2010: 0.3 to 2.0

 EPA Near roadway : 2.0 @ 40 meters to 1.0 @ 100 meters

 World Health Organization (WHO) Background indoor air (non

- smoker): 7.0+

 WHO Background indoor air (smoker): 10.5+

 Municipal fires: 11.0

 AWMA Agricultural burning: 11.2

 WHO Inside cars while driving: 12 +

36

### No

Yes Yes RCA/CA Analysis

EPA list of possible impacts Annual Monitoring

> Trigger level μg/m3: Check Fugitives

Check Perimeter • Violation if no RCA/CA Analysis

• Possible fugitives violation

• Transportation : rail, auto, truck or marine

• Agricultural burning

• Retail operation

• Wood burning fireplaces

• Other 

# Fenceline Monitoring Process Flow Chart

Fugitives include: tanks, LDAR, and wastewater components

# Fenceline Monitoring Process

 Fenceline results include non

- refinery emissions (agricultural burning, wood burning fireplaces, transportation sources, nearby facilities, etc.)

 Enhanced monitoring can help identify areas of concern in existing programs (LDAR, Tanks, etc.)

 RCA/CA Analysis may be triggered by exceedance of annual threshold

 Work practice standard

38

# Fenceline Monitoring Recommendations

 Fenceline monitoring has the potential to detect non

- refining sources of benzene; therefore, it should be limited to only shared borders of sensitive areas, such as:

 Residential areas

 Schools, daycares, hospitals

 Churches, temples, synagogues

 Retail businesses



##  Existing ambient air monitoring systems should be allowed as alternative monitoring to the proposed standard

 Exceedances of “action levels” at the fenceline should only result in investigations of the underlying MACT programs (tanks, fugitives, etc.)

 Corrective action analysis, performed once an action level is triggered, should include a cost

– effectiveness and threshold determination

 Refineries with low benzene monitoring results should be permitted to have a reduced fenceline monitoring schedule, similar to LDAR regulations

# Startup and Shutdown

40

# FCCU Safety Instrumented Systems

 Safety Instruments Systems (SIS) are automatic shutdown systems that engage based upon a pre

- defined set of conditions to minimize potential impact to process equipment, employee safety, or environmental impact.

 FCCUs are very complex, relying upon maintaining heat & pressure balance.

 Operates between 1000

– 1400 F & 25

– 35 psig.

 Oxygen & hydrocarbon atmospheres separated by only catalyst standpipes and differential pressure.


###  For example, SIS will engage upon the following:

 Wet Gas Compressor shutdown

 Main air blower shutdown

 Slide valve differential pressure

 Loss of feed to the unit


###  18 variables are a prescribed set of triggers, set via a thorough technical analysis by subject matter experts & industry best practices.

 The goal is to automatically shutdown in a safe, controlled manner than to leave the decision in the hands of an operator.

 Stop energy inputs into Reactor/Regenerator like feed, recycles, and quenches; closed slide valves; and introduce quenching steam to the Riser/Reactor.


###  Not all SIS activations will be caused by malfunctions.

 Experienced 40 SIS activations from January 2013

– July 2014 for a variety of reasons.


###  The alternative emission standards need to apply during the shutdown or re

- start period following the SIS activation.

41

# Safety Instrumented Systems (Cont’d)

Refinery Cause Potential Impact the SIS Prevented

Robinson Wet gas compressor variable frequency drive electronics failure caused the compressor to shutdown Extended flaring of fractionator offgases

Garyville Wet gas compressor shutdown on due to high vibrations. Extended flaring of fractionator offgases
Robinson Light feed from Gas Oil Hydrotreater caused feed pump to cavitate and lose flow to unit. Reactor pressure loss could have caused reversal from Regen to Reactor, allowing air to enter a hydrocarbon rich environment.
Detroit Reactor thermocouple read false high, causing slide valve to close and lower the differential pressure across the slide valve to < 3%. Low dP across slide valve could have caused reversal from Regen to Reactor, allowing air to enter a hydrocarbon rich environment. Texas City Feed pump developed a seal leak during period that the spare was out for maintenance. Loss of flow could have caused reactor pressure loss could have caused reversal from Regen to Reactor, allowing air to enter a hydrocarbon rich environment.

Texas City Power blip caused main air blower and wet gas compressor to shutdown. Extended flaring of fractionator offgases ; reactor/regenerator pressure imbalance.

42

# Safety Instrumented Systems (Cont’d)

 MPC believes that the automatic shutdown and ensuing startup caused by an SIS activation meets the definition of startup and shutdown within the MACT general provisions.

 Startup means the setting in operation of an affected source or portion of an affected source for any purpose.

 Shutdown means the cessation of operation of an affected source or portion of an affected source for any purpose.

 Malfunction means any sudden, infrequent, and not reasonably preventable failure of air pollution control and monitoring equipment, process equipment, or a process to operate in a normal or usual manner which causes, or has the potential to cause, the emission limitations in an applicable standard to be exceeded. Failures that are caused in part by poor maintenance or careless operation are not malfunctions

.

43

# Revisions to NSPS Ja

44

# NSPS Ja Revisions
– FCCU PM Monitoring

 EPA is proposing to require existing FCCUs apply the NSPS Subpart Ja PM monitoring requirements to all FCCUs regardless of whether Ja has been triggered.

 Cyclones

– Utilize opacity monitor & a site specific opacity limit via last stack test

 Baghouses

– Utilize a Bag Leak Detection System



##  MPC operates one TSS (Cyclone) FCCU at Canton, Oh, and the only FCCU with a Baghouse at Catlettsburg, Ky.

 For these two systems, MPC recommends changes be made to the monitoring requirements in both the MACT RTR proposal and the NSPS Subpart Ja to address:

 Opacity is a poor correlation to PM emission rates. Opacity correlations to stack test data poorly reflect impact of fine particle size distribution to opacity values.

 Sophisticated baghouse leak detection systems as written will be problematic for installation on this baghouse design.

45

# 2004 Study at Canton comparing opacity and PM Emissions

46 

### y = 0.0791x R2 = 0.0684

0.00 0.20 0.40 0.60 0.80 1.00 1.20 1.40 1.60

0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0Particulate Matter (#/M#coke)

Opacity (%) 

# PM vs Opacity

- No Correlation

# 2004 Study at Canton comparing opacity and PM Emissions

47 

### R2 = 0.0488

R2 = 0.1402

0.0 20.0 40.0 60.0 80.0 100.0 120.0 140.0

0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0PM Mass Emission Rate (lbs/hr)



### Opacity (%) 

# Opacity vs. PM

- No Correlation

Pre-TSS Data Post-TSS Data

# NSPS Ja Revisions
– FCCU PM Monitoring (Cont’d)

 Cyclones

 10% opacity limit will force installation of add

- on control device

 Canton currently meets standard

– 0.63 lb / Mlb coke burn (2/4/14 stack test)

 Not cost

- effective

– Addition of an ESP at Canton would result in a ~32 TPY reduction in PM and a cost

- effectiveness of $121,000/ton



## MPC recommends for TSS (Cyclone Systems):

 Removing the stack test correlation to opacity limit in both MACT RTR & NSPS Subpart Ja

.

 Replacing it with an annual stack test requirement.

48

# NSPS Ja Revisions
– FCCU PM Monitoring (Cont’d)

 MPC operates the only bag house used for PM control subject to NSPS J in the US and has very low emissions

 0.025 lbs / Mlbs cokeburn (July 2014)



##  Baghouse unit was originally designed to control PM emissions from a fluidized limestone bed boiler on old RCC. MPC converted the RCC to an FCC and removed limestone injection in 2004.

 MACT RTR Proposal requires installation of baghouse leak detection (BLD) system within 18 months after promulgation. A BLD consists of:

 A baghouse leak detection sensor & alarm on each baghouse

 Site specific monitoring plan with alarm set

- point justification.

 Corrective action to an alarm within 3 hours, or explanation of why action is not feasible.

 Monitoring of pressure drop across baghouse cells.

49

# Catlettsburg FCCU Baghouse

50 

### From Boiler Exhaust Stack
COMS 

###  2 Baghouse Systems

– North & South

 Each Baghouse Contains 12 Baghouse Modules.

 Each module is equipped with over 400 bags.

BAGHOUSE MODULE DIAGRAM

# NSPS Ja Revisions
– FCCU PM Monitoring (Cont’d)

 Installation of a baghouse leak sensors will be technically challenging and cost prohibitive.

 Minimum of at least 24 sensors for both baghouses (1 per module).

 With bag layout configuration, no guarantee that the sensor placement will detect an individual bag leak.


##  3

- hour corrective action is not technically feasible.

 Bag replacement requires module isolation and shutdown of the whole baghouse (either North or South).


##  Performance of baghouse is exceptional due to it being over

- designed for the service. Opacity COMS is performing very well in this application.

 Additional bells and whistles for pressure drop and sensor alarms will not reduce PM emissions from the baghouse

. 

##  MPC requests EPA add the option to submit an Alternative Monitoring Plan for Baghouse systems under both NSPS Ja and MACT RTR proposal.

 Believe existing baghouse pressure drop monitoring is sufficient & identifies issues with bag performance well before the emission standard is exceeded.

 Annual stack tests could also be part of AMP.

51

# MPC Conclusions
 The requirements for atmospheric pressure relief devices should be changed to a work practice standard with an appropriate implementation period.

 Marathon Petroleum recommends that EPA withdraw provisions for the ban on halogenated vent streams to the flare.

 Marathon Petroleum recommends that additional alternative compliance standards for MACT units during startup and shutdown be added to fully address safety concerns and monitoring (source testing) issues.

 Marathon Petroleum recommends that ambient air monitoring programs established to meet state and community needs be determined to be acceptable alternative monitoring options to adhere to the proposed enhanced monitoring standard.

 Marathon Petroleum recommends that an alternative monitoring plan be an acceptable option to the mandatory bag leak detection systems in NSPS Ja

.Attachment 3
Detroit Refinery

– VOC Monit oring Data Marathon Petroleum Company LP

# Detroit Refinery VOC Monitoring Data

April 11, 2014

# 2 Ambient Air Monitoring Stations Site 1 “North”

Site 4 “East” DHOUP Site

Marathon Detroit Refinery”

(Site 3) South Boynton School Site 2 “West”

# Benzene by Air Monitoring Station

3 0.00 1.00 2.00 3.00 4.00 5.00 6.00 7.00 8.00 9.00 10.00Benzene Concentration (ppb)

Date

1-North Benzene (ppb) 2-A West Benzene (ppb) 4-East Benzene (ppb) MTMS Benzene (ppb) Benzene ITSL (ppb)

# M&P Xylenes by Air Monitoring Station

4 0.00 5.00 10.00 15.00 20.00 25.00m&p-Xylenes Concentration (ppb)

Date
1-North m&p-xylenes (ppb) 2-A West m&p-xylenes (ppb) 4-East m&p-xylenes (ppb) MTMS m&p-xylenes (ppb) m&p-Xylenes ITSL (ppb)

# O

- Xylene by Air Monitoring Station

5 0.00 5.00 10.00 15.00 20.00 25.00o-Xylene Concentration (ppb)

Date 1-North o-xylene (ppb) 2-A West o-xylene (ppb) 4-East o-xylene (ppb) MTMS o-xylene (ppb) o-Xylene ITSL (ppb)

# Toluene by Air Monitoring Station

6 0 200 400 600 800 1000 1200 1400Toluene Concentration (ppb)

Date 

## Toluene By Station

1-North Toluene (ppb) 2-A West Toluene (ppb) 4-East Toluene (ppb) MTMS Toluene (ppb) Toluene ITSL (ppb)

# Hexane by Air Monitoring Station

7 0.00 50.00 100.00 150.00 200.00Hexane Concentration (ppb)

Date
1-North Hexane (ppb) 2-A West Hexane (ppb) 4-East Hexane (ppb) MTMS Hexane (ppb) Hexane ITSL (ppb)

# Ethylbenzene by Air Monitoring Station

8 0.00 50.00 100.00 150.00 200.00 250.00Ethylbenzene Concentration (ppb)

Date 

## Ethylbenzene By Station

1-North Ethylbenzene (ppb) 2-A West Ethylbenzene (ppb) 4-East Ethylbenzene (ppb) MTMS Ethylbenzene (ppb) Ethylbenzene ITSL (ppb)

# Questions

9