← American Petroleum Institute
EPARulemakingEPA-HQ-OAR-2002-0058

National Emission Standards for Hazardous Air Pollutants for Industrial / Commercial, and Institutional Boilers and Process Heaters Legacy Docket ID #: A-96-47

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Last modified
Sep 9, 2024
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closed 2104d ago
American Petroleum Institute filings
8

Activity

American Petroleum Institute filed 8 comments on this docket between Mar 14, 2003 and Sep 11, 2023. 480 other organizations filed here. The comment window closed 2104d ago.

What American Petroleum Institute filed (8)

Sep 11, 2023· Comment submitted by American Petroleum Institute (API) [OAR-2002-0058-IV-D-184]· EPA-HQ-OAR-2002-0058-4316

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Mar 1, 2012· Comment submitted by Matthew Todd, American Petroleum Institute (API) and David Friedman, American Fuel and Petrochemical Manufacturers (AFPM)· EPA-HQ-OAR-2002-0058-3677

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Sep 1, 2010· Comment submitted by Matthew Todd, American Petroleum Institute (API) and David Friedman, National Petrochemical and Refiners Association (NPRA)· EPA-HQ-OAR-2002-0058-2960

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Aug 31, 2010· Comment submitted by Matthew Todd, American Petroleum Institute (API) and David Friedman, National Petrochemical and Refiners Association (NPRA)· EPA-HQ-OAR-2002-0058-2935

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Jul 7, 2010· Comment submitted by Michael Todd, American Petroleum Institute (API) and David Friedman, National Petrochemical and Refiners Association (NPRA)· EPA-HQ-OAR-2002-0058-0851

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Aug 11, 2005· Comment submitted by Erik G. Milito, Senior Attorney, Office of General Counsel, American Petroleum Institute· EPA-HQ-OAR-2002-0058-0668

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Feb 23, 2004· Supplemental Comments referring to definitions of ?distillate oil? and ?residual oil.? submitted by American Petroleum Institute· EPA-HQ-OAR-2002-0058-0562

Supplemental Comments of the American Petroleum Institute on USEPA's (USEPA) Proposed Industrial Boiler and Procewss Heater National Emissions Standards for Hazardous Air Pollutants (NESHAP)

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Mar 14, 2003· EPA-HQ-OAR-2002-0058-0410

?API supports EPA?s legal authority in setting a ?no control? floor for existing B/PHs. Please see Section I.B. of the Comments for our detailed discussion. ?API recommends that EPA remove requirements for notification, record-keeping and reporting for those B/PHs without any emission limitation or work practice standards. Please see Section I.C. ?API recommends EPA exempt both existing and new liquid and gas-fired B/PHs with heat inputs less than 100 mmBTU/hr from this proposed MACT. Upon evaluation, these sources are likely to have an insignificant public health impact. Please see Section II.A. ?API recommends EPA exempt existing and new gas-fired B/PHs from having to comply with liquid-fired control requirements during periods of natural gas curtailment when these B/PHs would need to burn liquids. These periods of curtailment to accommodate ?National Needs? are typically quite short. Therefore, the cost of the pollution control and monitoring equipment is not warranted for the short-term impact that would occur. Please see Section II.B. ?API recommends EPA clarify in this rulemaking that, for purposes of reconstruction, the ?affected source? be defined as the entire assemblage of components comprising the B/PHs, i.e., inclusively from the pump inlet on the feed system to the steam outlet. This clarification will facilitate an appropriate determination whether sufficient reconstruction has occurred to trigger new source standards. Further, unless it is EPA?s intent, for this rulemaking, that an ?affected source? be defined as all of the B/PHs at a site (i.e., within a contiguous area), then EPA must justify why it is proposing to use a narrower definition than provided in the General Provisions [40 CFR 63.2]. Please see Sections II.C. and II.D. ?API recommends EPA clarify in this rulemaking the various B/PHs that are controlled under other MACT standards (e.g., Refinery MACT II), and thus, are not covered by this rulemaking. Further, EPA needs

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Abstract

Contact: Lisa Thompson, Office of Air Quality Planning and Standards, (919) 541-9775, thompson.lisa@epa.gov

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Co-filers (480)

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