August 5, 2014
EPA Docket Center William Jefferson Clinton West Building Attention: Docket ID Number EPA-HQ-OAR-2010-0682 U.S. Environmental ProtectionAgency Mail-code 28221T 1200 PennsylvaniaAvenue, NW Washington, D.C. 20460
Dear U.S. Environmental ProtectionAgency (EPA),
Enclosed are my personal comments about the Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards (air quality), 40 Code of Federal Regulations (CFR), Parts 60 and 63. 1) Page 116of813, Iagree that directatmospheric releases from decoking units (DCU) are unregulated emissions, must be regulated, and the emissions must be reduced. A common thread throughout this discussion, but never stated, is that decoking units are archaic and obsolete. The EPA mustencourage the refinery industryto conduct research to develop a continuous decoking operation where emissions can be more easily reduced or captured. The current, slow, discontinuous, air pollution generating process requires de-heading, draining, coke cutting, and depressurization that should be conducted in an enclosed system where air pollutantsare either recycled orcaptured and destroyed. 2) Page 135 of 813, I support adding a requirement that a visible emissions test be conducted each day and whenever visible emissions are observed from a flare. I also agree that anytime there are visual emissions from aflare that another 5 minute visible emissions observation period must be performed and that if visible emissions are observed for greater than one continuous minute that the monitoring period shall be extended to 2 hours. In no case should visible emissions be allowed for more than 5 minutes in any2 hour period. Unlessthere isan actual emergencythatcould result in extreme plant damage or imminent threat to people who live or work nearby that no visible emissions from flares should be allowed. Ifflares are as efficient as isstated (98%) thenvisibleemissionsshould notoccur. 3) Page 151 of 813, I support using an on-line gas chromatograph and vent gas and assist gas flow rate monitoring to determine whether combustion zone operating limits are met. We need to bring flares in from the Stone Age and require monitoring commensurate with the massive amounts of air pollutants, hazardous or otherwise, thatare burned oremitted from flares. Ido notsupportthe useofgrab samples since a continuous method to determinewhetherflares actually destroy airpollutantsand measurementofairpollutantsthatflares doemitis needed.

14) Page 164 of 813, I do not agree with EPA that wind does not affect flare performance. The information that EPA presents is notconvincing on this issue and atbestsuggeststhatadditional appropriate data collection is needed. 5) Page 170 of813, I do notsupport bypassing ofanyairpollution. Any bypassing of air pollution should be a violation of CFR 60 and 63, whether an emergency has occurred or not because bypassing means that citizens, other life forms, and building materials are automatically in danger. An actual monitoring system is needed which determines how much ofwhat air pollutants have been released in any bypass. 6) Pages 184 and 191 of813, I oppose using optical gas imaging devices in place of portable hydrocarbon analyzers (Method 21) which provide an actual instantaneous concentration of volatile organic compounds (VOC). Optical gas imaging devices are good for initial determinations that a leak might have occurred but provide no definitive proof that a leak actually has occurred. These devices detect infrared heat waves and not air pollutant concentrations. Only a portable hydrocarbon analyzer can determine if a leak has occurred by measurement of VOCs in ppm and comparison ofthis VOC concentration with the leakdefinition orstandard. 7) Pages 195, 202, and 204 of813, I do not agree that $3,900 is too much to pay for add-on air pollution control technology

. Twenty thousand dollars per ton should be the limit for ton of VOC/HAP removed

. . In the 1970's $3,900 was considered a cost effective amountfor the recovery ofa ton ofVOC. The EPA fails to state clearly whatiscosteffectiveandwhatcriteriathis determination is based upon. It makes no sense to rely upon "industry-reported emissions inventories" to determine cost effectiveness because industries have shown time aftertime that they underestimate their emissions. This is a conflict of interest. There is an incentive for industry to underestimate its air emissions since it can then avoid air pollution control by affecting EPA cost effectiveness determinations. It is a shame that EPA falls for this industry trick. I do support putting more controls on wastewater facilities. 13) Pages 206 through 247 of 813, I support monitoring at the fence-line by the refinery industry but Ido not support use ofa passive diffusivetube monitoring network. EPA must rethink the fence-line monitoring requirements and make them continuous, state-of-the art, immediate, and inclusive ofall significant HAPs, not just benzene but also ethyl benzene, xylene, toluene, and 1,3-butadiene at a minimum. The passive method, which EPA proposes to use, is the least accurate (from a quality assurance and quality control standpoint) and least sophisticated monitoring method of the six monitoring methods that EPA chooses from. The passive diffusive tube monitoring network as proposed by EPA does not provide continuous data for HAPs and VOCs, allows 2,000 feet between monitoring sites (this could allow large fugitive sources and the clouds of VOC or HAPs that are emitted to remain unmonitored),

2allows for 1-year rolling annual average and 2-week sampling interval which delays discovery ofair pollution concentrations that are over the fence-line limit and therefore makes it much more difficultto determinethe source and cause ofair pollution. Something much quicker for sampling, like instantaneous sampling, is needed. The present proposal does not require sufficientelevation of monitoring stations so thatfugitive emissions from towers and other elevated equipmentare reliably monitored.
EPA chooses the passive diffusive tube monitoring network because it is cheap and little training is needed. The refinery industry can afford the best equipment and its cost. One-halfmillion dollars is "chump change" forthe refinery industry. Usually, after the refinery industry operates with new regulatory requirements, like the monitoring that EPA proposes, it figures out how to comply correctly in an easier manner and for less money

. EPA should not "poor-boy" this first attempt at refinery fence-line monitoring

. If EPA gets this wrong there may not be another opportunity to require fence-line monitoring for a long time. The public has a rightto knowwhattypes of HAPs are crossing the fence-line and in what the concentrations instantaneously. Monitoringthatdeterminesthis iswhatthe refinery industrymustdo. 14) Pages 249 through 256 and page 321 of813, I do not support a 30% opacity limitforfluidized catalytic cracking units. Today'stechnology is good enoughfor a 10-20% opacity limit. EPA states on page 252 of813, that "This 30-percent opacity limit has been shown to be lenient and high in comparison to recent federal rules that have included more stringent opacity limit (e.g., 40 CFR part 60, subpart Db with 20- percent opacity), and recent state and local agency rules that omit opacity limits altogether in favor ofoperating limitsforthe emission control systems."
EPA must push the refinery industry to ensure it uses the best available control technology. There is no reason to give the refinery industry a break since oil companies are making incredible amounts of money (tens of billions of dollars) each quarter. · Iappreciatethis opportunityto comment. Thankyou. Sincerely,

# fJJ~(j-**~~** Brandt Mannchen 5431 Carew**Hou~on,Texas77096** 713-664-5962 brandtshnfbt@juno

.com

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