### Attachment 5

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

background informationFrom: 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 he ater 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 heat ers 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 heat er 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.

Conversel y, 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 p laces 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 wi th 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 limi t 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 reduct ion
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: Wedne sday, 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 h ave 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.co m>

04/08/2009 11:45 AM To : Ken Hustvedt/RTP/USEPA/US@EPA, Brenda

Shine/RTP/USEPA/US@EPA

c c : "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 heate r 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 Ge neral Counsel

----- Original Message

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

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

To: Hustvedt.Ken@epamail.epa.gov

c c: 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: F W: April 17 NSPS Ja Meeting w/ EPA

I think that is a good idea. thanks

"Colman

, Christopher"

<CColman@hess.co m>

04/0 2 /2009 0 1:4 3 P M 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 s o 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 a side 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 que stions (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: Frida y, February 06, 2009 4:43 PM

To: Colman, Christopher

c c: 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 heate rs. 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.co m>

0 2 /0 6 /2009 1 0 : 30 A M To : Ken Hustvedt/RTP/USEPA/US@EPA

cc : Brenda Shine/RTP/USEPA/US@EPA
Subject : FW: Attention

- Docket ID No EPA

- HQ

- OAR

2007

- 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 mai n 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 wou ld 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: Th is file is already located in the Refinery NSPS docket.

The Docket ID No

. is EPA

- HQ

- OAR

- 2007

- 0011

- 0 308. 1

.