### From: Brenda Shine/RTP/USEPA/US@EPA Sent: 02/ 14 /2012 11 : 15 A M To: "Higgins, Cortney" < Cortney_Higgins@omb.eop.gov > Cc: Penny Lassiter/RTP/USEPA/US@EPA, Susan Stahle/DC/USEPA/US@EPA Subject: RE: Invit ation: E.O. 12866 Petrleum Refineries Subpart J 2060

- AN72 Final Rule (Feb 14 03:00 PM EST in PLO Call

- in # 919

- 541

- 4332)

Hi Cortney,
Attached are materials for today's call.

<< Refinery NSPS Subpart Ja OMB Briefing.ppt >>

From: "Higgins, Co rtney" < Cortney_Higgins@omb.eop.gov > Sent: 02/ 14 /2012 10 : 16 A M To: Penny Lassiter/RTP/USEPA/US@EPA Cc: Brenda Shine/RTP/USEPA/US@EPA Subject: RE: Invitation: E.O. 12866 Petrleum Refineries Subpart J 2060

- AN72 Final Rule (Feb 14 03:00 PM EST in PLO Call

- in # 919

- 541

- 4332)

Hi, Can you send slides or briefing materials ahead of this call?

Thanks, Cortney

----- Original Appointment

----- 

### From: Penny Lassiter/RTP/USEPA/US@EPA Sent: Friday, February 10, 2012 5:00 PM To: Penny Lassiter /RTP/USEPA/US@EPA

, Brenda Shine/RTP/USEPA/US@EPA

, "Higgins, Cortney" < Cortney_Higgins@omb.eop.gov >, Susan Stahle/DC/USEPA/US; SPPD Phone Line x4332/Phone Line/RTP OAQPS BLDG C Subject: RE: Invitation: E.O. 12866 Petrleum Refineries Subpart J 2060

- AN72 Final Rule (Feb 14 03:00 PM EST in PLO Call

- in # 919

- 541

- 4332)

When: Tuesday, February 14, 2012 3:00 PM

- 4:00 PM Eastern.
Where: PLO Call

- in # 919

- 541

- 4332

### 1 

# Final Petroleum Refinery Flare and Process Heater NSPS

Briefing for OMB February 14, 2012

### 2 

# Refinery NSPS Overview

 

# Final court

- ordered action on comprehensive changes and additions to the Refinery NSPS on 6/24/2008

 

# Petitions for review/reconsideration received from Industry petitioners, Hovensa, and Environmental petitioners

 

# Ten major issues identified

 

# An additional list of 82 other issues from API

 

# Granted reconsideration for process heaters and flares

 

# Stayed the requirements until final action

 

# Proposed amendments 12/22/08

 

# Ready to take final action on these amendments

 

# Granted reconsideration of all remaining issues, including consideration of GHG standards, on 12/29/09

### 3 

# Flare System Provisions

 

# Best Demonstrated System of Emission Reduction

 

# Minimize or eliminate flaring (reduce SO 2 

# , NOx, CO, PM and VOC emissions and energy consumption)

 

# Quick modifications trigger

 

# Any physical or operational change to the flare that increases emissions from the flare makes a flare an affected source

 

# We proposed a limited number of exclusions

 

# Reasonable requirements

 

# Flare management plan to identify and minimize routine flow, but no hard flow limits

 

# Continuous flow and sulfur monitoring in flare header, except for flares that are used very infrequently

 

# Root cause analysis and corrective action for flaring events

 

# Because small routine changes will catch existing sources, they will have 3 years to comply with the rule

### 4 

# Process Heaters

 

# Best Demonstrated System of Emission Reduction

 

# Based on combustion controls

 

# Add

- on NOx reduction control devices not considered because:

 

# Combustion controls substantially reduce emissions

 

# Add

- ons for this application create fine PM

 

# Add

- ons use substantial amounts of energy while NOx combustion controls save energy

 

# Limits recognize differences in design and operation

 

# Allow case

- by

- case standards for certain heaters that:

 

# Operate at substantially reduced firing rates (turndown)

 

# Cannot retrofit controls (modified/reconstructed only)

 

# Co

- fire oil and gas in same burner

### 5 

# Appendix

 

# Refinery Subpart Ja Emission Sources

 

# Petition Issues

 

# Exclusions for Flare Modifications

 

# History of Subpart Ja Amendments

### 6 

# Refinery Subpart Ja Emission Sources

Emission sources Pollutants addressed Fluid Catalytic Cracking Units PM, SO 2 

# , NOx, CO Fluid Coking Units PM, SO 2 

# , NOx , CO Delayed Coking Units VOC, SO 2 

# Flare systems SO 2 

# , VOC, NOx , PM, CO

Process Heaters NOx
Fuel gas systems SO 2 

# Sulfur Plants SO 2 

# , H 2 

# S

### 7 

# Petition Issues

1. The definition of “modification” for flares 2. The definition of “flare” 3. The fuel gas combustion device sulfur limits for flares 4. The flow limit for flare systems 5. The total reduced sulfur and flow monitoring requirements for flares 6. The nitrogen oxide (NOx) limit for process heaters 7. The depressurization work practice standard for cokers 8. The NOx limit for fluid catalytic cracking units (FCCU) 9. The particulate matter limit for FCCU 10. EPA’s decision not to promulgate standards for greenhouse gas emissions

### 8 

# Exclusions for Final Flare Modifications

 

# Proposed to exclude connections to install monitoring systems, to install flare gas recovery systems, and to replace or upgrade existing relief valves with equal or lower instantaneous release potential

 

# Additional exclusions per API comments include connections to interconnect flares, to allow flare gas sulfur removal, to install redundant equipment, and to upgrade or enhance recovery systems

 

# Other API connection exclusions were not adopted

 

# Any connections that do not result in a net increase in emissions

 

# Use of the flare as a control device, including from tanks used to store sweet products

 

# Pressure relief valves

 

# Additions of “unregulated gases” such as hydrogen, nitrogen, ammonia

 

# New connections that do not exceed a flare gas recovery system capacity

 

# Temporary connections

### 9 Emission

Point Aspect Proposal (May 14, 2007) Final (June 24, 2008) Proposal (December 22, 2008) Final (Draft)

Process Heaters Applicability > 20 MM BTU/hr, M/R/N after May 14, 2007 > 40 MM BTU/hr, M/R/N after May 14, 2007 Same as 6/24/08 final rule Same as 6/24/08 final rule

Averaging time 24

- hour rolling average 24

- hour rolling average 365

- day rolling average 30

- day rolling average

Continuous Compliance CEMS for all CEMS for > 100 MM Btu/hr, others CPMS Same as 6/24/08 final rule (allow CEMS for all) Same as 12/22/08 proposal

Natural Draft NOx Emission Limits 80 ppmv 40 ppmv 40 ppmv or 0.035 lb/MM BTU 40 ppmv or 0.04 lb/MM BTU

Forced Draft NOx Emission Limits 80 ppmv 40 ppmv New : 40 ppmv or 0.035 lb/MM BTU M/R: 60 ppmv or 0.055 lb/MM BTU 60 ppmv or 0.06 lb/MM BTU

Cofired Burner (oil and gas) NOx Emission Limits 80 ppmv 40 ppmv 150 ppmv; Weighted average based on oil at 0.27 lb/MM BTU and gas at 0.08 lb/MM BTU 150 ppmv; Weighted average based on oil at 0.40 lb/MM BTU and gas at 0.11 lb/MM BTU forced draft and weighted

average based on oil at 0.35 lb/MM BTU and gas at 0.06 lb/MM BTU for natural draft

Alternative emissions standards None None Alternative limit petition for M/R or cofired units Same as 12/22/08 proposal except adding turndown 

# History of Subpart Ja Amendments

### 10 

# History of Subpart Ja Amendments

Emission

Point Aspect Proposal (May 14, 2007) Final (June 24, 2008) Proposal (December 22, 2008) Final (Draft)

Fuel Gas Combustion Devices Other Than Flares SO2 Standard and averaging time 160 ppmv H2S (TRS for cokers) (3

- hour); 60 ppmv H2S (TRS for cokers) (annual rolling average) 162 ppmv H2S (3

- hour); 60 ppmv H2S (annual rolling average) Same as 6/24/08 final rule Same as 6/24/08 final rule

Flares Applicability Flares that service N/M/R individual fuel
gas

- producing units New or reconstructed flare systems or existing flare systems that are physically altered to increase flow or to add new connections. Applicability moved to final rule date rather than proposal Same as 6/24/08 final rule, except exclude: 1) connections to install monitoring systems, 2) connections to install flare gas recovery systems, 3) connections to replace pressure relief valves Same as 12/22/08 proposal except added more exclusions : 1) flare interconnects 2) connections for flare gas sulfur removal 3) connections for redundant equipment 4) connections to upgrade or enhance recovery systems

SO2 Standard and averaging time 160 ppmv H2S (TRS for cokers) (3

- hour); 60 ppmv H2S (TRS for cokers) (annual rolling average) 162 ppmv H2S (3

- hour); 60 ppmv H2S (annual rolling average) Same as 6/24/08 final rule

- short term concentration limit 162 ppmv H2S (3

- hour)

- drop the 60 ppmv H2S annual limit

### 11 

# History of Subpart Ja Amendments

Emission

Point Aspect Proposal (May 14, 2007) Final (June 24, 2008) Proposal (December 22, 2008) Final (Draft)

Flares Compliance date New sources at startup. M/R sources at startup New/reconstructed flares: all substantive requirements apply at start

- up. Modified flares: comply with SO2 standard at start

- up, and all other requirements 1 year after triggering applicability New/reconstructed flares: same as 6/24/08 final rule. Modified flares: comply with SO2 standard at start

- up, and all other requirements 18 months or up to 2 years if recovery system is installed New/reconstructed flares: same as 6/24/08 final rule. Modified flares: 3 years to install controls

Flow limits No Routine Flaring for the individual FGPU. Flare system

- wide flow limit of 250,000 SCFD No limits Same as 12/22/08 proposal

Plans SSM plan for individual FGPU General Flare Management Plan (FMP) More detailed FMP

– including timetables for conducting RCA and corrective action Same as 12/22/08 proposal except must establish base load for RCA and SS planning and reporting
Upsets and Malfunctions Flared gases resulting from malfunctions or relief valve leakage exempt from SO2 standards and routine flaring prohibition Same as May 14, 2007 except malfunctions and relief valve leakage also exempt from the flow limit. Flared gases resulting from malfunctions or relief valve leakage exempt from SO2 standards Same as 12/22/08 proposal.

Startup and shutdown
events SS events not excluded from SO2 standards or from the flaring prohibition SS events not excluded from SO2 standards (same as 5/14/2007 proposal) or from the flow limit SS events exempt from SO2 standards Same as 12/22/08 proposal.

### 12 

# History of Subpart Ja Amendments

Emission

Point Aspect Proposal (May 14, 2007) Final (June 24, 2008) Proposal (December 22, 2008) Final (Draft)

Flares Root Cause Analysis for SO2 All events over 500 lbs/day SO2 Same as May 14, 2007 proposal RCA for over 500 lbs SO2 in a 24

- hour period Same as 12/22/08 proposal

Root Cause Analysis for flow Not addressed RCA required on all process upsets or malfunctions in excess of 500,000 scfd. RCA required on all discharges in excess of 500,000 scfd Same as 12/2/08 proposal except 500,000 scfd flow limit is above base load and added water seal monitoring allowance for intermittent flares

Sulfur Monitoring H2S or TRS monitoring for fuel gas; excludes upsets H2S and continuous reduced sulfur monitoring Same as 6/24/08 final rule; allow option to use H2S monitor and sampling to get ratio of H2S to total sulfur Same as 12/22/08 proposal, except no sulfur monitoring for intermittent or emergency only or “inherently low sulfur” flares

Flow monitoring Not addressed Continuous flare flow monitoring Same as 6/24/08 final rule. Same as June 24, 2008 final rule except added limited alternative monitoring and exemptions (i.e., 100 percent recovery systems)

Coke Calciners Applicability to fuel gas sulfur limits. Not addressed. Coke calciners create fuel gas subject to sulfur limits. (RTC) Exempts coke calciners from the definition of fuel gas Same as 12/28/08 proposal

Coke Gasifiers Applicability to fuel gas sulfur limits No addressed. Coke gasifiers create fuel gas subject to sulfur limits. (RTC) Same as 6/24/08 final rule and defines gasifier as a refinery process unit Same as 6/24/08 final rule except gasifiers are not refinery process units