API Teleconference with EPA on July 10, 2009

Meeting Note to the Docket

Participant List

EPA:

Robert Wayland

Bill Maxwell

Mary Johnson

Sonja Rodman

Rebecca Kane

API:

Kristi Mitchum, Chevron			Gary McCutchen, RTP Environmental

Keisha Ragin, Kinder Morgan		Bruce Goddard, ConocoPhillips

Bob Tonti, RAIN CII				Jan Laughlin, ConocoPhillips

Keith Neyrey, RAIN CII			Kevin Calhoun, Providence Engineering

John Lowe, Chevron				David Friedman, NPRA

Charlie Bennett, Marathon			John Wagner, API

Bob Hermanson, BP				Matt Todd, API

Gary Saini, RTP Environmental

Discussion Topics

On July 10, 2009, representatives from the U.S. Environmental Protection
Agency participated in a conference call at the request of
representatives from the American Petroleum Institute (API) Air Toxics
Task Force.  API discussed their concerns regarding certain revisions to
the Standards of Performance for Coal Preparation and Processing Plants
(40 CFR part 60 subpart Y), as proposed in a May 27, 2009, supplemental
action.  The concerns raised by API relate to the revised definition of
“coal,” which as proposed, includes petroleum coke and, thus, API
believes would likely result in facilities that manufacture petroleum
coke becoming subject to subpart Y.  Specifically, API is concerned
about potential inclusion of the following sources:

coke calcining operations

coke drum operations (i.e., where coke that has built up is drilled out
and dumped onto a pit pad below the process unit)

coke handling and transfer operations

API explained that the above operations are “manufacturing” sources
rather than “processing” sources and, as such, should not be
regulated under subpart Y. 

