MEMORANDUM

DATE:  7/29/15

FROM:  Ken Mitchell/EPA Region 4

TO:   Clean Power Plan for Existing Power Plants; Docket Id: OAR - 2013-0602

SUBJECT:  Discussion of the Clean Power Plan at the American Petroleum Institute Southern Region Meeting
SUMMARY:        
REGION 4 PROVIDED INFORMATION ON THE CLEAN POWER PLAN at the American Petroleum Institute Southern Region Meeting in Charleston, SC, on May 19, 2015.  The Clean Power Plan for Existing Power Plants was proposed on June 2, 2014.  
ATTENDEES:

EPA
Ken Mitchell/EPA R4

External Stakeholders
Approximately 50 participants (meeting organizer is Tom Parker, API Southern Region)

ATTACHMENT



Follow-up answers to meeting participants' questions provided by Ken Mitchell/EPA Region 4 to Tom Parker/API Southern Region via email on 5/27/15.

   1. Is methane regulated as a VOC?

This question was raised in the context of our discussion of ozone regulations.  In that context, the term "VOC - Volatile Organic Compounds" is defined in 40 CFR 51.100(s) as follows: 

"(s) Volatile organic compounds (VOC) means any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate, which participates in atmospheric photochemical reactions. 

(1)  This includes any such organic compound other than the following, which have been determined to have negligible photochemical reactivity: methane; ethane..."  (Emphasis added)
      
   2. Are additional refinery regulations in the works or anticipated?

From the conversation at the Charleston API meeting, I understood this to be specifically related to a greenhouse gas (GHG) rule for refineries pursuant to a 2010 settlement agreement between EPA and various petitioners (see:  http://www2.epa.gov/carbon-pollution-standards/2010-proposed-settlement-agreements-address-greenhouse-gas-emissions).  The Agency is focused on finalizing the proposed Clean Power Plan.
      
   3. When were the current ozone implementation standards completed?  

      There are two main rules related to implementing the 2008 ozone NAAQS.  The first (the Classification Rule) was issued on April 30, 2012.  The second (the SIP Requirements Rule) was issued on February 13, 2015 (see:  http://epa.gov/airquality/ozonepollution/actions.html#impl).  Note that implementation activities undertaken to meet the 2008 ozone NAAQS are expected to help many areas make progress toward meeting any future revised ozone standards.  On November 25, 2014, the EPA proposed to strengthen the ozone NAAQS in order to ensure that the standards meet the requirements of the CAA.  The EPA will complete that proposed rulemaking by October 1, 2015.  In the event EPA takes final action to revise the current (2008) NAAQS, EPA would issue a new implementation rule specific to that future revised NAAQS.



