Document zEG3w73mRY8L18MyeXvQGanB

American Petroleum Institute 1220 L Street, Northwest Washington. D.C. 20005 202-682-8000 9 Liu A. Thoimu Senior Regulatory Auljal (202) 682.8323 DATE: November 27, 1989 TO: Members of me Ad Hoc Workgroup on the API Fugitive Emission Factors Project and All Other Interested API Members FROM: Lisa A. Thomas On December 13, 1989, the API Title in Task Force will be sponsoring a workshop in Houston, Texas. The workshop is designed to discuss an API project to develop improved inemission factors for fugitive sources applicable to SARA Title Section 313 reporting. Specifically, the workshop is aimed for company personnel responsible for estimating Title HI emissions and those responsible for collecting screening data in compliance with the Environmental Protection Agency's (EPA) benzene National Emission Standards for Hazardous Air Pollutants (NESHAPS) requirements and various State Volatile Organic Compound (VOCi regulations which require periodic inspections and maintenance of process equipment. In brief, the project itself stems from the industry's concern about the accuracy of the existing refinery factors - the AP-42 emission factors - which EPA developed in the early 1980s. Because the auvtnt factors do not take into account emissions from refineries with Inspection and Maintenance (I&M) programs or those with modern scaling technology, the industry members who use uncorrected AP-42 factors will be over-estimating fugitive emissions reported annually to F.PA, Thus, hy improving the accuracy of the footers, this project will provide more realistic emissions reported to me Agency under Section 313. This workshop involves two topics. The first is to explain how the existing data were used to develop the current factors. In addition, correlation equations derived from this data will be explained and attendees will learn how these equations may used to estimate emissions until the improved emission factors are developed. The second topic is to develop a workplan for updating the current emission factors. To accomplish this, we will need your help in collecting .screening" data -- mrainmd pollutant concentrations taken of individual leaking components. A significant sampling of refinery screening data critical to the success of this project. To help develop this wwkylou, wc icuucsl dim you invesdgatc the following questions before the workshop: Does ynnr company or ninety record the individual VOC careening value? Or, does your company only keep "Leak/No Leak" information? An equal opportuneemployer DTH 000033778 From AMERICAN petroleum INSTITUTE UDC head 11/29/99 12:19 If your company records the numerical measurements, would it b willing to provid* tlir.M- .n.unls to AM ana it3 contractor tor the analysis? if your company records only "Leak/No Leak" information, would it bo willing during a yio-spcclflcd dme penoo to record the readings and submit such data to API's contractor? What is the easiest mediuU fur recording and su omitting the data (e.g., a data collection sheet, a computer readable floppy disk, or other electronically readable means)? Additionally, the workshop will also cover such topics as: e How to develop a data sampling scheme that is representative of the industry (e.g., number and size of components screened. I&M versus non-I&M refineries, inclusion of appropriate equipment for sampling; Appropriate test measurement methods (e.g., EPA Method 21); Numbers and qualifications of refinery staff needed to collect or record the new data; Start and completion dates for collecting the data. In addition to the above quo3tion3, it would l>o vciy useful iu bring to the meeting examples or summaries of data from refineries that collect numerical readings. This will give us a basis of comparison for formatting, the amount of detail, etc. Where necessary, we would make a limited number of copies to distribute at the meeting for this discussion only; at the end of the discussion, we would collect all copies of any material each company felt was sensitive. If vour company is willing to make available such data, please call Lisa Thomas at (202) 682-8323. The planning meeting will be held from 8:30 a.m. until 2:00 p.ra. at the following address: Fours Seasons (Houston Center) 1300 Lamar Street Houston Texas (713) 650-1300 DTH 000033779 3 All attendees ant responsible for making their own hotel reservations by calling the Four Seasons directly. A block of rooms have been reserved at a room rate of $85.00. To take advantage of this rate, you must mention yon are attending the API meeting when making your reservation. For further information, plrasr contact Lina Thomaa at the. uu*Uci above. cc: Title III Task Force A. Ducca R. Stricter G. Laffley DTH 000033780