1 Site Visit Report Sunoco

—Philadelphia Refinery 3144 Passy

unk Avenue Philadelphia, PA 19145 July 14, 2009 1.0 Background and Objectives The Environmental Protection Agency (EPA) is in the process of developing 316(b) cooling water intake structure requir ements that reflect the best technology available (BTA) for minimizing adverse environmental impact for all existing power plants and manufacturing facilities. As part of this process, EPA staff is visiting electric generators and manufacturers to better understand the cooling water intake structure (CWI S) technologies in use at facilities, including the site

specific characteristics of each facility and how these affect the selection and performance of CWI S technologies. EPA is also visiting facilities to better understand cooling water use and specific issues or technologies that can affect 316(b) compliance. Sunoco’s Philadelphia Refinery was selected for a site visit because it utilizes cooling water in refin ing of petroleum products

. 2 .0 Facility Des cription Sunoco’s Philadelphia Refinery is located on a 1000 acre site in southwestern Philadelphia along the Schuy lkill River . The site originall y began operations in the 1860s (processing whale oil), began processing crude oil in 1900, and eventuall y m erged with an adjacent refinery ; accordingl y, Sunoco considers the site as two separate entities 1 from a water use perspective and has retained separate NPDES permits for each. 2 The site employs approximately 1000 people. 3 .0 Manufacturing Information T he Philadelphia Refinery processes petroleum into a variet y of fuels, chemicals, and other products. Point Breeze produces gasoline, diesel, and a small amount of other products, while Girard Point produces a similar mix of products plus benzene. 3 Accord ing to facility representatives, the facilit y is typical of a midsize refinery

.

1 Point Breeze (formerly the Atlantic Refinery) is the original refinery and was purchased by Sunoco in 1988; the adjacent Girard Point w as acquired in 1994. Since the facilities previously operated independently, each site has much of the same equipment, increasing operational flexibility. The site is generally operated as a single refinery (it has one central management/op erations center and single air em issions and solid waste permits) but is treated as separate sites for w ater
- related functions. The sites share some water and steam, but are largely independent for water usage. 2 Point Breeze’s permit number is PA0012629 and Girard Point’s is PA0011533. Girard Point’s permit is due to expire on February 28, 2011 and Point Breeze’s is due to expire on January 31, 2011. 3 Intermediate products can be shared betw een Point Breeze and Girard Point, as w ell as the Marcus Hook r efinery.2 Ty pically , the refinery

operates 24 hours a day

. 4 Production may fluctuate depending upon product demand, which can be impacted b y outside factors such as industry

capacity

. At the time of the visit, the site was producing at approximately

70

- 80% capacit y. Production does not vary greatly on a season al basis , but the mix of products may change. 5 Crude oil is supplied by

the Fort Mifflin Terminal Complex on the Delaware Rive r in Philadelphia to the Point Breeze Facility , and by Hog Island Wharf Dock in Tinicum Township and Fort Mifflin Terminal Complex to the Girard Point f acility where ships unload crude oil to storage tanks and pipelines. Point Breeze processes approximate ly

130,000 barrels per day (bpd), while Girard Point processes approximately

210,000 bpd. 4 .0 Cooling Water System and Intake Structure The site has 3 active CWI Ss, each with a shoreline intake. 6 Point Breeze operates one CWI S near the boat dock; it fee ds a full y recirculating cooling water system (CWS) with mechanical draft cooling towers. 7 The other 2 CWI Ss (on the shoreline of the inside bend of the river) service Girard Point ’s CWS; it uses both once - through cooling and recirculating cooling via mec hanical draft cooling towers. The following table summarizes the information for these intakes; more information is below.

Point Breeze Girard Point Total # CWI S 1 2 3 # traveling screens 0 3 3 Design Intake Flow ( DI F ) 20.7 MGD 31.7 & 15.8 MGD 68.2 M GD Actual Intake Flow ( AI F ) 4.2 MGD 11.8 & 0.4 MGD 16.4 MGD Through

- screen velocity 1.5 fps 1.5 fps

4 The entire refinery is never taken offline at the same time. Individual process units may close for maintenance, with sufficient storage of intermediate products to enable continued production at the other process units. Alternatively, the pro cess unit may share capacity or products w ith the adjacent equipment or the Marcus Hook refinery or may purchase the needed products commercially. Some unit closures may require that additional associated units also be closed. 5 For example, the facility may increase the production of heating oil in the winter. 6 Point Breeze’s North Yard CWIS is out of service. Girard Point also has one CWIS that has been out of service for decades. 7 Facility representatives noted that the cooling towers have been in pl ace for some time; they were una ware of the rationale for constructing them instead of using once

- through cooling.3 Point Breeze’s CWI S ha d coarse mesh fixed screens located in the bulkhead near the dock ( at a depth of approximately 15

- 20 feet) but they had been rem oved from service man y ye ars ago . The screens are periodically cleaned b y divers, as debris and silt are much less problematic at this intake. The only cooling water uses are for makeup water for the cooling towers. Girard Point’s CWI Ss are located on the shoreline of the inside bend of the river at a depth of approximately 14

- 16 feet. They

are fitted with rotating coarse mesh (3/8”) traveling screens. One CWI S is used to provide non

- contact, boiler, and process water to the plant and uses the intak e structure for a former onsite water treatment plant and has two 6 foot wide coarse mesh traveling screens. These screens were rebuilt in 1990 and facilit y representatives stated that they have proven to be expensive to operate. These screens are rotate d twice per shift and the combined fish/debris return trough discharges just outside the pumphouse into the river. A chain link fence submerged in the river acts as an additional lay er of screenin g in front of the trash racks. The other CWI S for Girard P oint (located just to the north of the CWI S described above ) is largely

used for supplemental (service water) flows and has one functional 6 foot wide traveling screen. (A second screen is non

- functional.) Two circulating pumps are installed, but ty pical ly only one is used. This screen is rotated once per shift. Dredging in front of both Girard Point intakes occurs on an occasional basis. The Girard Point intakes previously supplied a much larger volume of once

through cooling water before some process lines were converted to recirculating sy ste ms in the 1980s. (See Section 5 .0 below.) In sum, the DIF for the entire refinery is 68.2 MGD and the total AI F for both sites is approximately 16.4 MGD , according to facility representatives. At the time of the site visit, approximately 12.9 mgd was being withdrawn, with approximately

3.6 mgd as makeup water for the various cooling towers; the remaining flows are largely dedicated to boiler feed water. 8 Water usage varies seasonall y, as the capacity of the coo ling tower, evaporative potential, and drift change with the weather. In the summer, the facility ty picall y withdraws 15.0 MGD to 20.0 mgd, with approximately <5% being used as once - through non contact cooling water. Ty pically , one operator is charged wi th multiple duties at a process unit , including operating the cooling tower or operating the traveling screens. The worker may conduct visual inspections, basic chemical tests to ensure proper tower functioning, and manually triggering screenwash cy cles.

8 Facility representatives stated that the facility produces less steam than in the past, as it is cheaper to buy electricity than to produce it onsite; as such the water withdraw als have decreased.4 Aside from the two halves of the refinery , there are no other major users of cooling water nearb y, thereb y reducing the viability of sharing steam, reclaimed water, or other approaches to reduce intake withdrawals. 5 .0 Flow Diagram The facility

withdraw s surface water for once - through non

- contact cooling, cooling tower makeup, boiler feed water, process water, and for fire suppression. A significant portion of the facilit y’s water withdrawals are dedicated to providing makeup water for cooling towers or for supply ing treated water for boiler feed or other process uses. The remaining <5% is used for non

- contact, once - through cooling. F acilit y representatives noted that the refinery previously used much higher quantities of water

-- especially once - through cooling water. During the 1980’s, it significant ly reduc ed once - through cooling. For example, it added new cooling towers to handle cooling loads. The facility continues to reduce water usage. Facilit y representatives noted that engineers were making a concerted effort to recover condensate and identify other opportunities for process optimization, as the water recovered is of very high quality , has already been treated, or retains some amount of heat that can be recovered. S tripping steam is t ypicall y recycled as process water, largel y as wash water for desalters. The fluid cat cracking units also collect steam and reuse the water as sour water. Boiler water is treated and softened, and is then injected into the process unit as steam. However, the facility noted that while it strives to reduce water usage, some activities lead to increased water usage. For example, the facility recentl y constructed a wet gas scrubber to control air emissions, which increased water usage at the site b y ap proximately 10

- 15%. 6 .0 Electricity Generation and Transmission Point Breeze has a one 2.5 MW generating unit and Girard Point has three generators. 9 The Point Breeze generating unit operate s on gas produced b y offgassing and produce power to be used onsite

. The Girard Point generators operate on 680# steam. The units use river water for cooling. 7 .0 Impingement and Entrainment Information Facilit y representatives were unaware of an y source water characterization, impingement , or entrainment studies conducted a t the site. Neither NPDES permit contains requirements for 316(b). The facility does, however, have a water use permit with the Delaware River Basin Commission (DRBC), which assesses a fee for water withdrawals.

9 The turbines typically generate approximately 4 MW each, but have a capacity of 30 MW.5

8 .0 Cooling Tower Feasibility As noted in Section 3.0, the Sunoco Philadelphia site uses numerous mechanical cooling towers. The towers are built from either fiberglass or redwood , depending on the age of the tower . Facilit y representatives stated that there are no problems with drift, noise, o r plume/visibility , 10 as the towers are located well inside the plant propert y. They did state that two towers have been replaced in recent ye ars. O ne tower partially collapsed a few y ears ago and was rebuilt, 11 while the o ther was replaced 2

- 3 y ears ago. 12 The new tower has high efficiency fill and facility

representatives have not experienced any difficult y in operating the tower; it operates at approximately 4

- 5 cy cles of concentration. 13 An onsite vendor maintains the chemical additives (antifouling and antiscaling chemical feeds) and there has been no noticeable change in chemical usage over the previous cooling tower designs

. Four towers are process
- specific and can be taken out of service for maintenance when the associated process unit is also out o f service. Other towers serve more than one process unit and essentially never stop operating; individual cells are taken offline and serviced separately

. Point Breeze has 4 cooling towers that serve the entire cooling needs for the site. The towers are located at the crude unit, 14 the hy drogen desulfurizing unit, the fluid/cracking unit, and at the hy drogen complex. Girard Point has 4 cooling towers, including the largest tower at the refinery

. This tower has 20 cells and is 55 feet tall. A second tow er (serving the Girard Point crude unit) has 12 cells; facility representatives noted that this was amongst the least efficient towers on the site and may be upgraded or replaced in the future. A third tower was recentl y built at the fluid unit and cracke rs, a process line which is a large user of water at the refinery . The 14 cell tower is much

10 The facility also noted that some of the towers are located approximately 2 miles from the Philadelphia Air port. 11 The rebuilt tow er w as constructed w hile the facility continued to operate. Facility representatives stated that the facility operated with a temporary cooling water tower and at a low er production capacity, but did not experience any plant

- wide shutdowns as a result of the rebuilding process. The affected process unit wa s only taken fully offline during the tie

- in; the facility could not recall the length of the outage for the tie

- in. 12 The replacement tower was constructed to replace one of the o ldest and least efficient cooling tow ers on the property. Facility representatives noted that they were able to adjust production rates and share (or purchase) intermediate products to minimize any construction

- related downtime. The majority of construct ion took place during a major maintenance outage of 6

- 9 m onths (unrelated to the conversion to closed

- cy cle cooling). Major outages typically occur every 4

- 5 y ears and last approximately 6 w eeks, although a recent outage lasted 3 months due to low dem and. Facility representatives stated if the extended outage had not occurred, much of the construction of the replacement tower would have been done while the unit was operating; they stated that the standard 6 w eeks might not have provided enough time to com plete tie

- in and startup activities. 13 Other tow ers at the refinery typically operate at 4

- 8 cy cles, 3.2 cycles, and 3.8 cycles. 14 Facility representatives noted that this tower loses approximately 864,000 gpd to evaporation and 504,000 gpd for blow down, a nd can reject approximately 330 million BTUs of heat.6 shorter than the other towers due to the use of high efficiency fill material. It cost approximately

$10 million to construct. 15 The fourth tower is a small 4 ce ll tower at the Au

- 433 alk yl ation unit

. In considering a retrofit to cooling towers for the remaining once - through flows at Girard Poi nt, facility

representatives noted that these are relativel y small flows ( 0.4 mgd, as noted above), even compared to othe r process flows within the refinery . The process units also ty picall y result in a relativel y low delta T (10

- 15 °F)

. From a spatial perspective, the two process units are far from each other, making a single cooling tower problematic; the facility would likely

evaluate other options, such as reconfiguring the equipment in the process units . Facility representatives also noted that, for Girard Point, the realized benefit derived from conver sion to closed

- cy cle cooling is not justified by the cost. They

a dded that much of the flow is used to cool an air compressor; construction of a cooling tower would be far more expensive than the compressor itself. 9 .0 Future Activities Facilit y representatives were not aware of an y plans for major renovations, plant expansion, or production changes. Presently , the facility ’s onl y investments are for required upgrades or general maintenance. 10 .0 Cooling Ponds There are no cooling ponds onsite. 1 1 .0 316(a) The NPDES permit contains temperature discharge limits ( 1 10°F ) including requirements for a mixing zone. The facilit y has never had an y problems meeting its thermal limits. 1 2 .0 Ash Handling There is no as h produced onsite. 1 3 .0 Air Emissions Controls Aside from the increased water usage from the wet gas s crubber (see Section 2.0) , EPA did not collect any

data on air emissions.

15 Note that this tower w as able to use the existing piping and concrete basin, thereby significantly reducing the overall capital costs. Temporary cooling towers were brought in at the end of the produ ction period to allow construction workers to prepare for demolition of the old tow er.7

1 4 .0 Issues with Debris The Schu yl kill River carries a high debris load, especiall y after large storms , and has a high tidal variation (4

- 5 feet) . However, the facility did not d iscuss any problems with handling the debris loading, even though man y of its screens are older (i.e., less efficient at screening and removing material). Facility representatives did state that the screens are normally rotated once or twice per shift, but that the frequency of wash cy cles may

increase during high debris loading periods.

Attachments Attachment A List of Attendees Attachment B Aerial Photos8

Attachment A
-- List of Attendees Paul Shriner, USEPA Jan Matuszko, USEPA Steve Geil, Tetra Tec h Kelly Meadows, Tetra Tech Jim D i s ario, Sunoco Chuck Barksdale, Sunoco Bob Gallagher, Sunoco

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