Attachment 5 

E-mail correspondence between the EPA and HOVENSA regarding meeting planning and 

background information 
From: Colman, Christopher

Sent: Wednesday, April 08, 2009 12:32 PM

To: 'Hustvedt.Ken@epamail.epa.gov'

Cc: shine.brenda@epa.gov; Waibel, Dick; Lucas.Bob@epamail.epa.gov; cob@rti.org; 

Kparrish@rti.org

Subject: RE: April 17 meeting

Yes, you have two distinct configurations and Dr. Waibel and the HOVENSA reps will discuss both, but I 

will give you my non-technical two cents in advance. The two major oil firing applications at HOVENSA 

are:

1. A combined oil and gas firing burner unit comprised of oil "spud" surrounded by gas burners- sample 

diagram attached above. The oil goes to the burner which you can see in the center of the drawing, and 

gas goes to the gas burners on the side. You can't effectively burn oil on a burner designed for gas and 

vice-versa. 

2. A standard gas fired burner with emergency oil backup burner. 

The first application is not common in US refineries. All refineries generate fuel gas in some amounts, 

depending on their configuration it can be most or all of the refinery supply of fuel. To balance the fuel 

needs of the refinery, you need a secondary source of fuel. On the mainland, refineries balance their fuel 

needs by use of natural gas.

Thus, they use a single type of burner, designed to burn gas only. The only instance in which a mainland 

refinery would burn oil would be an emergency curtailment, when little or no natural gas is available. In 

this case, a refinery process heater may be equipped with a backup oil gun, which may not be designed 

to operate at the same time as the gas fired burners.

As long as the main fuel gas generating units (FCCU and Delayed Coker) are operating at HOVENSA, a 

very high percentage of HOVENSA's fuel needs are met by the use of fuel gas. This fuel gas does not 

have quite as good a NOx profile as natural gas, but is fairly similar. The remainder must be met by using 

oil. However, when the gas generating units are down or operating at lower rates, the amount of oil that 

HOVENSA burns goes up to balance the fuel supply. Conversely, if the fuel gas supply is larger than 

typical (as it can be in summer) HOVENSA burns more gas and less oil. HOVENSA concentrates its oil 

use on a limited number of heaters and boilers. To make sure that the refinery can use the gas that it 

makes, these oil firing units have to have burners that can burn variable quantities of oil and gas, often at 

the same time. Thus, you will design the overall burner so that the heater has both oil burners and gas 

burners in the same "package" and still be able to deliver the needed BTUs to the process. For example, 

if the coker is offline, the heater or boiler may burn nearly 100% oil to make up for the fuel gas shortfall. 

Conversely, if the refinery is fuel gas rich as a result of excess butanes or propanes, the heater unit might 

burn almost all gas.

HOVENSA also uses the emergency backup configuration for units where oil is not typically burned. 

For the EMERGENCY FIRING case, I am pretty certain (but the HOVENSA team will speak to this) based 

on the white paper that the performance of gas burners at HOVENSA should be at or near as good as 

any other Low Nox burner, save for the fuel gas NOx effects of having higher propanes and olefins. In 

other words, the emergency oil gun does not impose any real design constraints on low NOx combustion 

techniques for fuel gas. I do not know what design limitations or cost effectiveness issues this 

configuration places on the emgergency oil gun, but if you do not regularly use oil on the heater, then it 

would be less of an issue.

From a Ja perspective, the proposed NOx limits are only applicable when burning at least some fuel gas, 

so in this case the only issue with a NOx limit might actually being during a gas to oil transition. I will have 

to verify this, but , if so, this transition can probably be handled in many of the typical NSPS ways for 

emergency or temporary applications so that a .035 NOx lbs/mmtbu limit does not apply during the 

transition to oil. 
On the combination oil and gas burner unit, the physical configuration of having oil and gas burners in 

close proximity imposes design limits on both the oil and the gas side in terms of effective NOx reduction 

strategies. The HOVENSA technical team will be better able to discuss feasible strategies. 

Hope this helps!

Christopher S. Colman

(See attached file: Gas and Oil burner.doc)

SECONDA

RY TILE
-----Original Message-----

From: Hustvedt.Ken@epamail.epa.gov [mailto:Hustvedt.Ken@epamail.epa.gov]

Sent: Wednesday, April 08, 2009 12:16 PM

To: Colman, Christopher

Cc: shine.brenda@epa.gov; Waibel, Dick; Lucas.Bob@epamail.epa.gov; cob@rti.org; 

Kparrish@rti.org

Subject: Re: April 17 meeting

thanks. will he be able to address the differences between heaters that have separate burners for oil and 

gas versus burners that co-fire oil and gas. My understanding was that your facilities have single burners 

for both fuels

kch

"Colman, Christopher"

<CColman@hess.com>

04/08/2009 11:45 AM

To: Ken Hustvedt/RTP/USEPA/US@EPA, Brenda 

Shine/RTP/USEPA/US@EPA

cc: "Waibel, Dick" <dick.waibel@johnzink.com>

Subject: April 17 meeting

KC and Brenda,

I will be at the meeting on April 17, with Dick Waibel from John Zink and either John Canegata or Vince 

D'Ippolito from HOVENSA. I have asked Dick to have an "oil firing NOx 101" slide show ready for 

discussion (not more than 30 minutes), which I think may help chart a path forward.

Vince or John can talk to HOVENSA specific operations issues and heater design, as needed. We can 

either wait until the end of the main discussion session and invite those who want to stay to remain, or we 

can schedule after lunch for oil firing. Your choice, and thanks for the opportunity.

Christopher S. Colman

Deputy General Counsel

-----Original Message-----

From: Colman, Christopher [mailto:CColman@hess.com] 

Sent: Friday, April 03, 2009 4:59 PM

To: Hustvedt.Ken@epamail.epa.gov

cc: shine.brenda@epa.gov; Lucas.Bob@epamail.epa.gov; Coburn, Jeff B.; Parrish, Kristin

Subject: RE: April 17 NSPS Ja Meeting w/ EPA

Thanks KC, we will be there. 

Christopher S. Colman

Deputy General Counsel
-----Original Message-----

From: Hustvedt.Ken@epamail.epa.gov [mailto:Hustvedt.Ken@epamail.epa.gov]

Sent: Friday, April 03, 2009 4:58 PM

To: Colman, Christopher

Cc: shine.brenda@epa.gov; Lucas.Bob@epamail.epa.gov; cob@rti.org; Kparrish@rti.org

Subject: Re: FW: April 17 NSPS Ja Meeting w/ EPA

I think that is a good idea. thanks

"Colman, Christopher"

<CColman@hess.com>

04/02/2009 01:43 PM

To: Ken Hustvedt/RTP/USEPA/US@EPA, Brenda 

Shine/RTP/USEPA/US@EPA

cc: "Waibel, Dick" <dick.waibel@johnzink.com>

Subject: FW: April 17 NSPS Ja Meeting w/ EPA

KC and Brenda,

I could probably bring a HOVENSA delegation to this to discuss oil cofiring issues, which might be more 

convenient for your team. We could even wait until after the meeting and spend maybe an hour or so if 

that works. Please let me know, as I have to pull together the appropriate people to attend.

Christopher S. Colman

Deputy General Counsel

-----Original Message-----

From: Ron Chittim [mailto:Chittim@api.org]

Sent: Thursday, April 02, 2009 1:34 PM

To: nspsjcore@listserve.api.org

Subject: April 17 NSPS Ja Meeting w/ EPA

Importance: High

Our next face-to-face meeting with EPA is scheduled for April 17th at EPA offices in RTP, NC. We will 

start the meeting at 10:30 am and we have asked them to set aside a couple of hours. I am arranging for 

a meeting room at the Courtyard Marriott near the airport so we can hold a pre-meeting at 8:00 until about 

9:30 am or so.
From: Colman, Christopher 

Sent: Thursday, March 19, 2009 5:13 PM

To: 'Hustvedt.Ken@epamail.epa.gov'

Subject: Ja/Oil Firing

Ken, I wondered if you had thought further about a meeting opportunity with HOVENSA on cofired 

heaters. I was having Dick Waibel from John Zink pull together a slideshow on the technical issues with 

NOx reduction in this application and to answer some of the questions (e.g. do I really need a separate 

category for emergency use?) you had posed. I was also planning on having HOVENSA's technical 

representative available as well. 

Christopher S. Colman

Deputy General Counsel

HOVENSA

From: Hustvedt.Ken@epamail.epa.gov [mailto:Hustvedt.Ken@epamail.epa.gov] 

Sent: Friday, February 06, 2009 4:43 PM

To: Colman, Christopher

cc: shine.brenda@epa.gov; Lucas.Bob@epamail.epa.gov

Subject: Re: FW: Attention-Docket ID No EPA-HQ-OAR-2007-0011

thanks for the note.

I appreciate your offer to discuss the issues with co-fired heaters. I think it would be a good idea to have 

a discussion once we have had a chance to review the comments. 

I don't have a need for the CBI report - Bob? Brenda?

kch

"Colman, Christopher"

<CColman@hess.com>

02/06/2009 10:30 AM

To: Ken Hustvedt/RTP/USEPA/US@EPA

cc: Brenda Shine/RTP/USEPA/US@EPA

Subject: FW: Attention-Docket ID No EPA-HQ-OAR2007-0011

KC and Brenda, I am forwarding HOVENSA's comments on the reproposal. I appreciate all of your hard 

work in putting the reproposal out and listening to endless litany of technical information. The consultant 

who studied this recommended cofired heater Nox numbers that were higher than I had expected they 

would be for the main type of cofired burner that HOVENSA uses (a "combined" burner), which may 

simply reflect the relative lack of real world information, but also seems to reflect inherent issues with 

burner design. If it would help, once I get up to technical speed, I would be happy to arrange a meeting 

or call.

I can send you the confidential version of the Zink white paper, if you need it, but the non-confidential 

version pretty much addresses the technical and performance issues. I can forward this to Bob Lucas, if 

you wish.
Christopher S. Colman

Deputy General Counsel

______________________________________________ 

From: Colman, Christopher 

Sent: Thursday, February 05, 2009 5:51 PM

To: a-and-r-Docket@epa.gov

Subject: Attention-Docket ID No EPA-HQ-OAR-2007-0011

Please find enclosed a copy of comments of HOVENSA LLC on the NSPS Ja rulemaking. 

Christopher S. Colman

Counsel to HOVENSA LLC

<<Ja reproposal comments v3.pdf>>

Note: This file is already located in the Refinery NSPS docket.

The Docket ID No. is EPA-HQ-OAR-2007-0011-0308.1.