1

Site Visit Report

Sunoco—Philadelphia Refinery

3144 Passyunk 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 requirements 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 (CWIS) technologies in use at facilities, including the sitespecific characteristics of each facility and how these affect the selection and 

performance of CWIS 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 refining of petroleum products.

2.0 Facility Description

Sunoco’s Philadelphia Refinery is located on a 1000 acre site in southwestern 

Philadelphia along the Schuylkill River. The site originally began operations in 

the 1860s (processing whale oil), began processing crude oil in 1900, and 

eventually merged with an adjacent refinery; accordingly, Sunoco considers the 

site as two separate entities1from a water use perspective and has retained 

separate NPDES permits for each.2 The site employs approximately 1000 people.

3.0 Manufacturing Information

The Philadelphia Refinery processes petroleum into a variety 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 According to facility representatives, the facility 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 was 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/operations center and single air 

emissions and solid waste permits) but is treated as separate sites for water-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 between Point Breeze and Girard Point, as well as the Marcus Hook 

refinery.
2

Typically, the refinery operates 24 hours a day.

4

 Production may fluctuate 

depending upon product demand, which can be impacted by outside factors such 

as industry capacity. At the time of the visit, the site was producing at 

approximately 70-80% capacity. Production does not vary greatly on a seasonal 

basis, but the mix of products may change.5

Crude oil is supplied by the Fort Mifflin Terminal Complex on the Delaware 

River 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 

facility where ships unload crude oil to storage tanks and pipelines. Point Breeze 

processes approximately 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 CWISs, each with a shoreline intake.6 Point Breeze operates 

one CWIS near the boat dock; it feeds a fully recirculating cooling water system 

(CWS) with mechanical draft cooling towers.7 The other 2 CWISs (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 mechanical draft cooling 

towers. The following table summarizes the information for these intakes; more 

information is below.

Point Breeze Girard Point Total

# CWIS 1 2 3

# traveling 

screens

0 3 3

Design Intake 

Flow (DIF)

20.7 MGD 31.7 & 15.8 MGD 68.2 MGD

Actual Intake 

Flow (AIF)

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 process unit may share capacity or products with 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 place for some time; they were 

unaware of the rationale for constructing them instead of using once-through cooling.
3

Point Breeze’s CWIS had coarse mesh fixed screens located in the bulkhead near 

the dock (at a depth of approximately 15-20 feet) but they had been removed from 

service many years ago. 

The screens are periodically cleaned by 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 CWISs 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 CWIS is used to provide non-contact, boiler, and 

process water to the plant and uses the intake 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 facility representatives stated that they have 

proven to be expensive to operate. These screens are rotated 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 layer of 

screening in front of the trash racks.

The other CWIS for Girard Point (located just to the north of the CWIS 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 typically 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 oncethrough cooling water before some process lines were converted to recirculating 

systems in the 1980s. (See Section 5.0 below.)

In sum, the DIF for the entire refinery is 68.2 MGD and the total AIF 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 

seasonally, as the capacity of the cooling tower, evaporative potential, and drift 

change with the weather. In the summer, the facility typically withdraws 15.0

MGD to 20.0 mgd, with approximately <5% being used as once-through noncontact cooling water.

Typically, one operator is charged with 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 cycles.

 

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 withdrawals have decreased.
4

Aside from the two halves of the refinery, there are no other major users of 

cooling water nearby, thereby reducing the viability of sharing steam, reclaimed 

water, or other approaches to reduce intake withdrawals.

5.0 Flow Diagram

The facility withdraws 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 facility’s water withdrawals are dedicated to 

providing makeup water for cooling towers or for supplying treated water for 

boiler feed or other process uses. The remaining <5% is used for non-contact, 

once-through cooling.

Facility representatives noted that the refinery previously used much higher 

quantities of water--especially once-through cooling water. During the 1980’s, it 

significantly reduced once-through cooling. For example, it added new cooling 

towers to handle cooling loads. The facility continues to reduce water usage. 

Facility 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. Stripping steam is typically recycled 

as process water, largely 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 recently constructed a wet gas scrubber to 

control air emissions, which increased water usage at the site by approximately

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 operates on gas produced by 

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

Facility representatives were unaware of any source water characterization, 

impingement, or entrainment studies conducted at 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. Facility representatives stated that there are no 

problems with drift, noise, or plume/visibility,

10 as the towers are located well 

inside the plant property. They did state that two towers have been replaced in 

recent years. One tower partially collapsed a few years ago and was rebuilt,11

while the other was replaced 2-3 years ago.12 The new tower has high efficiency

fill and facility representatives have not experienced any difficulty in operating 

the tower; it operates at approximately 4-5 cycles 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 of 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 hydrogen desulfurizing unit, the 

fluid/cracking unit, and at the hydrogen 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 tower (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 recently built at the fluid unit and crackers, 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 

Airport.

11 The rebuilt tower was constructed while the facility continued to operate. Facility representatives stated 

that the facility operated with a temporary cooling water tower and at a lower production capacity, but did 

not experience any plant-wide shutdowns as a result of the rebuilding process. The affected process unit 

was 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 oldest and least efficient cooling towers 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 

construction took place during a major maintenance outage of 6-9 months (unrelated to the conversion to 

closed-cycle cooling). Major outages typically occur every 4-5 years and last approximately 6 weeks, 

although a recent outage lasted 3 months due to low demand. 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 weeks might not have provided enough time to 

complete tie-in and startup activities.

13 Other towers at the refinery typically operate at 4-8 cycles, 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 blowdown, and can reject approximately 330 million BTUs of heat.
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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 cell tower 

at the Au-433 alkylation unit.

In considering a retrofit to cooling towers for the remaining once-through flows at 

Girard Point, facility representatives noted that these are relatively small flows 

(0.4 mgd, as noted above), even compared to other process flows within the 

refinery. The process units also typically result in a relatively 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 

conversion to closed-cycle cooling is not justified by the cost. They added 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

Facility representatives were not aware of any plans for major renovations, plant 

expansion, or production changes. Presently, the facility’s only investments are 

for required upgrades or general maintenance.

10.0 Cooling Ponds

There are no cooling ponds onsite.

11.0 316(a)

The NPDES permit contains temperature discharge limits (110°F) including 

requirements for a mixing zone. The facility has never had any problems meeting 

its thermal limits.

12.0 Ash Handling

There is no ash produced onsite.

13.0 Air Emissions Controls

Aside from the increased water usage from the wet gas scrubber (see Section 2.0), 

EPA did not collect any data on air emissions.

 

15 Note that this tower was 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 production period to 

allow construction workers to prepare for demolition of the old tower.
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14.0 Issues with Debris

The Schuylkill River carries a high debris load, especially after large storms, and 

has a high tidal variation (4-5 feet). However, the facility did not discuss any

problems with handling the debris loading, even though many 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 cycles may increase during high debris 

loading periods.

Attachments

Attachment A List of Attendees

Attachment B Aerial Photos
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Attachment A--List of Attendees

Paul Shriner, USEPA

Jan Matuszko, USEPA

Steve Geil, Tetra Tech

Kelly Meadows, Tetra Tech

Jim Disario, Sunoco

Chuck Barksdale, Sunoco

Bob Gallagher, Sunoco
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