### PHILADELPHIA**E~ERGY** 

### SOLUTIONS REFINING AND MARKETING LLC HEATEREXPANSION PROJECT PLAN APPROVAL APPLICATION NO. 12195
CITY OF PHILADELPHIA DEPARTMENT OFPUBLIC HEALTH AIR MANAGEMENT SERVICES
COMMENTAND RESPONSE DOCUMENT February 12,2014

2112/14PREAMBLE Air Management Services (AMS) received a permit application from PhiladelphiaEnergy Solutions Refining and Marketing LLC (PES), formerly Sunoco, Inc. (R&M), to replace hourly heat input capacity limits on seven (7) heaters with annual heat input limits and install Ultra Low-NOx Burners (ULNBs) on two (2) ofthe heaters. The heaters are limited to refinery fuel gas with individual heat input limits that combine to 730.6 MMBTUIhr. The proposed annual heat input limits total 6,806,000 MMBTU perrolling 12-monthperiod. The application also included the following proposed changes, which are intended to meet the reasonably available control technology requirements (RACT) ofthe Clean Air Act (CAA) for the 1997 8-hourozoneNational Ambient Air Quality Standard (NAAQS): the removal ofthe million BTU perhourheat input limit for each heater, the addition of million BTU heat input and Nitrogen Oxides emission limits per rolling 12-monthperiod limit for each heater, the requirement to bumonly refinery fuel gas for each heater, and the installation ofthe addition ofUltra Low-NOx Burners (ULNBs) ontwo heaters. These changes are proposedto be made to the State Implementation Plan (SIP). On December 2nd through 4th

, 2013, a notice was placed in the PhiladelphiaDaily News announcing thatthe PhiladelphiaDepartment ofPublic Health, Air Management Services Division (AMS), intended to issue PlanApproval No. 12195 to PES to replace hourly heat input capacity limits on seven (7) heaters with annual heat input limits and install Ultra Low-NOx Burners (ULNBs) ontwo (2) ofthe heaters. The notice also included proposed changes to the SIP intendedto meetthe RACT requirements ofthe CAA for the 1997 8-hourNAAQS. An equivalent notice was published in the Pennsylvania Bulletin onDecember 14,2013. The notices informed the public that AMS was accepting written public comments onthe proposed permit issuance and set 30 days from the publication date as the closing date (AMS used latest notice to setthe closing date). The notices also informed the public that a public hearing would be held onJanuary 13,2014, if requested. The public hearing was held as scheduled due to the timing ofthe Pennsylvania Bulletin notice (it was expectedto be published inthe December7,2014edition). AMS did not receive any public comments during the public hearing. During the public comment period, AMS received comments from one (l)commentator.

2 2112/14List ofCommentators 1. \Villiam O'Sullivan Director, Division ofAir Quality, New Jersey Department of Environmental Protection



### 3 2112114COMMENTS AND RESPONSES

Comment 1: An increase in 140 tpy ofNOx should be subjectto nonattainmentNSR, including offsets and LAER. The lowest emissionrate that is required (and achieved) at otherrefineries should be required here. Response 1: NSRis a two step applicability determination. In the first step only increases in the project are considered. In the second step all contemporaneous increases and decreases are added to the emissions in step one. Whilethe project has an increase of 140 tons per year (tpy) ofNOx, there is a net decrease of 180.7 tpy when all contemporaneous increases and decreases are included. As a result, the net emissions increase, as determined under 25 PaCode §127.203a(a)(1) is not significant and NSRis not applicable totheprojectunder 25 Pa Code 

### §127.203(c). Comment 2: Increase in potential emissions triggers NSPS. How do the heater emission limits compare to the NSPS? Response 2: Capacity limits are beingremoved so the heaters can operate up to their rated capacity on a short-term basis. Under40 CFR 60.14(e)(2), the definition ofa modification excludes an increase in production rate at an existing facility, ifthat increase canbe accomplished without a capital expenditure on that facility. There is no physical modification orcapital expenditureto any ofthe heaters that result in an increase in emissions (the installation ofULNBsontwo heaters decreases emissions). As a result, there is no Part 60 modificationto any oftheheaters and none ofthe heaters are applicable to NSPS. Comment 3: What are the emission limits for each heater? A Ib NOx permillion btu limit averaged over 24 hours for each heater wouldbe appropriate. RACT, BACTor LAER NOx emission limits should not have an averaging time over 24 hours. An annual limit is neitherpractically enforceable orprotective ofair quality. Response 3: Theproject does not triggerrequirements for LAER or BACT. The emission limits are included in the enclosed plan approval. Each heater has NOx emission limits in both Ibs/ MMBTU and tons per rolling 12-monthperiod. Compliance for six (6) ofthe heaters is determinedbased on AMS-approved stack tests consisting of three 60-minutetest runs. Compliance for the Unit 210 H201A/B Heater Ibs/MMBTU NOx limit is on a rolling 365-day average. This limit was carried over from a previous plan approval that included the installation ofULNBsand a NOx Continuous Emission Monitoring System (CEMS). The new emission limit will be added to the RACT plan approval and SIP. This limit is a fraction ofthe 0.173 Ibs/MMBTU NOx limit for gas burning and 0.4 Ibs/MMBTU NOx limit for oil burning (no longer allowed) in the original RACT plan approval and current SIP. Modeling conducted by AMS shows thatthe project will cause a worst-case

4 2/12/14ambient I-hour Nitrogen Dioxide level of73.52 ppb, well below the I-hour NAAQS level of 100 ppb. Comment4: How are the NOx emissions monitored? Continuous emission monitoring for NOx is reasonable for large heaters such as these, and needed ifthe limit is based on any limit with over a 3 hour averaging time. Response 4: The Unit 210 H20lA/B Heaterhas a NOx CEMS. The otherheaters are requiredto monitorNOx compliance through AMS-approved stack tests and quarterly portable analyzertests. All heaters are only allowedto burn refinery fuel gas. PES must perform and annual adjustment or tune-up on each heater. 

# I Comment 5: Will the increases in fine particle (PM2.5) and sulfur dioxide exacerbate ambient fine particle levels in the Philly area, which are already higher than the 12 ug/m3 

# I NAAQS for PM2.5? Response 5: The project does not triggerthe NSR requirements for PM2.5. There is a contemporaneous 5-year decrease in PM2.5 emissions. AMS does not believe this project will exacerbate the ambient PM2.5 levels in the Philadelphiaarea. Comment 6: Should nonattainmentNSR apply to the over 10 tpy PM2.5 increase? Response 6: Similarto Response 1for NOx, there is a net decrease in PM2.5 overthe contemporaneous 5-yearperiod, so the net increase is not significant and NSRis not applicable to the projectfor PM2.5. Comment7: Hourly heat input limits shouldremain. Substitutionofannual heat input 

# I limits is insufficient for control ofozone (and insufficient to protect other short term NAAQS). Annual averaging would allow higher NOx emissions onhot summerdays when ozone is already high, leading to exacerbation ofozone levels. Response 7: The project proposesto install ULNBs ontwo heaters, a reduction in shortterm emissions, in addition to the annual heat input limits. The proposed project reduces the combinedpotential NOx emissions for the heaters by 7.30 pounds perhour. The proposed changes to the RACT Plan Approval and SIP remove the capability of burning refinery fuel oil from five (5) heaters (part ofa past consent decree, but currently not included in the SIP). Comparing the existing SIP to the proposed modifications of the SIP, combined potential NOx emissions from the heaters are reduced by 201.14 pounds per hour. Comment 8: Why are ULNB (ultra low NOx burners) not required as RACT on all the heaters? 

# 1

5 2112/14Response 8: PES proposed installing ULNBs on the two heaters in the application. In the Best Available Technology (BAT) and case-by-case RACT analyses for the other heaters, ULNBs were determined to be economically unreasonable. Comment 9: Why are SCR's (selective catalytic reduction) notrequired as LAER on all the heaters? Response 9: The project did not trigger LAER requirements.

The final Plan Approval includes the following revisions:

• The NOx emission limit in Condition 3.e for the Unit 210 H201A1B Heaterwas changed from 0.03 Ibs/MMBTU to 0.030 Ibs/MMBTU to match the limit in Plan Approval No. 10180. This change was also made to Condition4.B inthe modification ofthe RACT PlanApproval.

• Condition 3.h was modifiedto remove making the NOx Ibs/MMBTU limits on a rolling 365-daybasis for heaters that install a certifiedNOx CEMS in the future. This would inadvertentlymake the emission limits less stringent.

This Plan Approval was issued on February 19.2014. The modificationto the RACT Plan Approval was issued on February 19, 2014.



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