3-28-13 Communication EPA/Tesoro

Steve –

Please call to discuss.

Thanks,

Rebecca 

Attachment:

BART Modeling Protocol (draft v1 3-28-13 ras)

Apply “Modeling Protocol for Washington, Oregon and Idaho: Protocol for the Application of 

the CALPUFF Modeling System Pursuant to the Best Available Retrofit Technology (BART) 

Regulation (7/21/06).”

The CALPUFF modeling system would be applied using the exact same meteorological data set 

(2003-2005), model versions, and options as specified in the original Protocol used in the 

February 2008 “BART Determination Modeling Analysis, Tesoro Anacortes Refinery.” The 

results would be summarized contrasting the number of days with predicted changes to the 

haze index greater than 0.5 dv and the 98th percentile change to the daily haze index. The 

design day extinction budgets would also be presented for each Class I area, emission case, and 

year. 

Model the following cases: 

1. Baseline

2. EPA BART

3. Tesoro’s “Better-than-BART” Proposal

Baseline: 

 Include all sources involved in the EPA BART and Tesoro “Better-than-BART” cases as listed 

in Attachment 1.

 Apply estimated maximum 24-hour emission rates during 2004-2006 for each pollutant for 

all EPA BART and Tesoro “Better-than-BART” sources. (*)
 Apply meteorological (met) conditions previously prepared during initial BART modeling 

(2003-2005).

 Post-control for SO2 and PM emission rates will be used for F-302 and F-304 to account for 

the installation of the Flue Gas Scrubber at the CCU in 2005. This will remain constant for all 

three cases.

EPA BART:

Using the “Baseline” furnace firing rate, apply the emission reduction benefit of: 

1. BART controls (as agreed to in Ecology’s BART Order #7838)

2. EPA additional BART NOX controls at the following sources: 

F-6650, F-6651, F-6652, F-6654 and F-304.

Tesoro “Better-Than-BART”:

Using the “Baseline” furnace firing rate, apply the emission reduction benefit of:

1. BART controls (as agreed to in Ecology’s BART Order #7838) 

2. Tesoro RFG Project to non-BART sources: 

F-101, F-102, F-301, F-6652, F-751, F-752.

EPA to Tesoro communication 3-28-13

Rebecca... we need to talk. I assume you’ve read the comments on our proposed Washington Regional 

Haze action and our failure to demonstrate that the alternative BART is ‘Better than BART’ using the 

emission test. Would TESORO be willing to conduct CALPUFF modeling for this demonstration?

I’m pretty available Monday, March 18.. except at 10:00-11:00 am

EPA to Tesoro communication 3-28-13

Rebecca... thanks. This V2 of the modeling protocol looks good. Let’s move forward.
From: Spurling, Rebecca [mailto:Rebecca.A.Spurling@tsocorp.com] 

Sent: Thursday, March 28, 2013 2:41 PM

To: Body, Steve; Rose, Keith

Subject: Tesoro BART Modeling Protocol v2 (3-28-13)

Updated

EPA to Tesoro communication 5/1/13

Rebecca... 

We have reviewed your “TESORO Better than BART Modeling” report in which you describe CALPUFF 

modeling results under a baseline BART, an EPA BART and a TESORO Better-Than-BART analysis. For the 

public record, we would like TESORO to provide us with the following on a CD:

1. Stack parameters, emission rates, calculation methodology, and references used in the three 

modeled BART cases. Spreadsheet is preferred.

2. Please confirm that emission rates are real and federally enforceable.

3. CALPUFF input and output files.

4. Identification of any assumptions outside the 2006 three state modeling protocol.

Let me know when to expect the information so I won’t continue to ‘bug’ you.

Thank you in advance for this information.

Steve

Attachment 1 : 

BART Modeling Protocol to Compare EPA BART vs. Tesoro “Better-Than-BART” proposal

BASELINE EPA 

BART

Tesoro 

Better-Than-BART

SOX, NOX, PM10 SOX, NOX, PM10 SOX, NOX, PM10

Estimated 24-hour max 

emission rate, unless o/w 

specified.

Emissions estimated using same 

furnace firing rate as Baseline.

PM – same as baseline unless o/w 

specified

Emissions estimated using same 

furnace firing rate as Baseline.

PM – same as baseline unless o/w 

specified

EPA 

BART SOURCES

F-103 X SOX/PM: No oil Burning

NOX: 59.1 tpy (post contol limit)

SOX: 1000 ppm RFG H2S

SOX/PM: No oil Burning

NOX: 59.1 tpy (post contol limit)

SOX: 1000 ppm RFG H2S S

F-104 X SOX: 1000 ppm RFG H2S SOX: 1000 ppm RFG H2S

F-654 X SOX: 1000 ppm RFG H2S SOX: 1000 ppm RFG H2S

F-6600 X SOX: 1000 ppm RFG H2S SOX: 1000 ppm RFG H2S

F-6601 X SOX: 1000 ppm RFG H2S SOX: 1000 ppm RFG H2S

F-6602 X SOX: 1000 ppm RFG H2S SOX: 1000 ppm RFG H2S

F-6650 & 51 (CR) X NOX: 72% reduction in baseline

SOX: 1000 ppm RFG H2S

NOX: equal to baseline

SOX: 1000 ppm RFG H2S

F-6652&53 (CR) X NOX: 72% reduction in baseline

SOX: 1000 ppm RFG H2S

NOX: equal to baseline

SOX: 1000 ppm RFG H2S

F-6654 X SOX: 1000 ppm RFG H2S SOX: 1000 ppm RFG H2S

F-6655 X SOX: 1000 ppm RFG H2S SOX: 1000 ppm RFG H2S

F-304 (via CCU Flue 

Gas Scrubber Stack: V348)

NOX: 58% of the actual FGS 

NOX Emissions (1)

SOX/PM: 50% post-FGS 

control

NOX: 39% reduction in baseline 

SOX/PM: 50% post-FGS control

NOX: equal to baseline

SOX/PM: 50% post-FGS control

Flare X-819 X Equal to baseline Equal to baseline

Cooling Water #2 X Equal to baseline Equal to baseline

Cooling Water #2A X Equal to baseline Equal to baseline

Tesoro 

Better-Than-BART Sources

F-101 X SOX: equal to baseline SOX: 1000 ppm RFG H2S

F-102 X SOX: equal to baseline SOX: 1000 ppm RFG H2S

F-201 X SOX: equal to baseline SOX: 1000 ppm RFG H2S

F-301 X SOX: equal to baseline SOX: 1000 ppm RFG H2S

F-652 X SOX: equal to baseline SOX: 1000 ppm RFG H2S

F-751 X SOX: equal to baseline SOX: 1000 ppm RFG H2S

F-752 X SOX: equal to baseline SOX: 1000 ppm RFG H2S

(1) F-302 and F-304 share a common stack. F-304 contributes ~ 58% of the total FGS NOX and 50% of the total FGS SOX and PM.

(2) For the purpose of comparing EPA BART and Tesoro Better-than-BART, the baseline 24-hour maximum emission rate is being estimated 

using the maximum monthly emission rate between 2004 - 2006. Furthermore for the non-BART sources F-751 and F-752, the maximum 

monthly period was selected from months whereby only RFG was burned (no oil burning).

(3)Tesoro is subject to a federally enforceable RFG H2S limit of 1,000 ppm, 365-day rolling average, applied in the Ecology BART Order #7838. 

(4) The original BART Modeling 24-hour emission rates for the Flare X-819, Cooling Water #2, Cooling Water #2A will be applied to all three 

modeling cases due to the relatively low emission rates and that there are no proposed emissions changes in either the EPA BART or Tesoro 

Better-Than-BART scenarios.