PHILADELPHIA E~ERGY SOLUTIONS REFINING AND MARKETING LLC 

HEATER EXPANSION PROJECT 


PLAN APPROVAL APPLICATION NO. 12195 


CITY OF PHILADELPHIA 


DEPARTMENT OF PUBLIC HEALTH 


AIR MANAGEMENT SERVICES 


COMMENT AND RESPONSE DOCUMENT 


February 12,2014 


2112/14 

PREAMBLE 


Air Management Services (AMS) received a permit application from Philadelphia Energy 

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) of the 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 per rolling 

12-month period. 

The application also included the following proposed changes, which are intended to 

meet the reasonably available control technology requirements (RACT) of the Clean Air 

Act (CAA) for the 1997 8-hour ozone National Ambient Air Quality Standard (NAAQS): 

the removal of the million BTU per hour heat input limit for each heater, the addition of 

million BTU heat input and Nitrogen Oxides emission limits per rolling 12-month period 

limit for each heater, the requirement to bum only refinery fuel gas for each heater, and 

the installation ofthe addition of Ultra Low-NOx Burners (ULNBs) on two heaters. 

These changes are proposed to be made to the State Implementation Plan (SIP). 

On December 2nd through 4th, 2013, a notice was placed in the Philadelphia Daily News 

announcing that the Philadelphia Department of Public Health, Air Management Services 

Division (AMS), intended to issue Plan Approval 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) on two (2) ofthe heaters. The notice also included 

proposed changes to the SIP intended to meet the RACT requirements of the CAA for the 

1997 8-hour NAAQS. An equivalent notice was published in the Pennsylvania Bulletin 

on December 14,2013. The notices informed the public that AMS was accepting written 

public comments on the proposed permit issuance and set 30 days from the publication 

date as the closing date (AMS used latest notice to set the closing date). The notices also 

informed the public that a public hearing would be held on January 13,2014, if 

requested. 

The public hearing was held as scheduled due to the timing of the Pennsylvania Bulletin 

notice (it was expected to be published in the December 7,2014 edition). AMS did not 

receive any public comments during the public hearing. During the public comment 

period, AMS received comments from one (l) commentator. 

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List of Commentators 

1. \Villiam O'Sullivan 

Director, Division of Air Quality, New Jersey Department of 

Environmental Protection 

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COMMENTS AND RESPONSES 

Comment 1: An increase in 140 tpy of NO x should be subject to nonattainment NSR, 

including offsets and LAER. The lowest emission rate that is required (and achieved) at 

other refineries should be required here. 

Response 1: NSR is 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. While the project has an increase of 

140 tons per year (tpy) of NOx, 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 Pa Code § 127 .203a(a)(1) is not significant and NSR is 

not applicable to the project under 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 being removed so the heaters can operate up to their 

rated capacity on a short-term basis. Under 40 CFR 60.14( e )(2), the definition of a 

modification excludes an increase in production rate at an existing facility, if that increase 

can be accomplished without a capital expenditure on that facility. There is no physical 

modification or capital expenditure to any of the heaters that result in an increase in 

emissions (the installation ofULNBs on two heaters decreases emissions). As a result, 

there is no Part 60 modification to any ofthe heaters and none of the heaters are 

applicable to NSPS. 

Comment 3: What are the emission limits for each heater? A Ib NOx per million btu 

limit averaged over 24 hours for each heater would be appropriate. RACT, BACT or 

LAER NOx emission limits should not have an averaging time over 24 hours. An 

annual limit is neither practically enforceable or protective of air quality. 

Response 3: The project does not trigger requirements 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-month period. Compliance 

for six (6) of the heaters is determined based on AMS-approved stack tests consisting of 

three 60-minute test 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 ofULNBs and 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 that the project will cause a worst-case 

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ambient I-hour Nitrogen Dioxide level of73.52 ppb, well below the I-hour NAAQS 

level of 100 ppb. 

Comment 4: How are the NOx emissions monitored? Continuous emission monitoring 

for NOx is reasonable for large heaters such as these, and needed if the limit is based on 

any limit with over a 3 hour averaging time. 

Response 4: The Unit 210 H20lA/B Heater has a NOx CEMS. The other heaters are 

required to monitor NOx compliance through AMS-approved stack tests and quarterly 

portable analyzer tests. All heaters are only allowed to 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 trigger the 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 Philadelphia area. 

Comment 6: Should nonattainment NSR apply to the over 10 tpy PM2.5 increase? 

Response 6: Similar to Response 1 for NOx, there is a net decrease in PM2.5 over the 

contemporaneous 5-year period, so the net increase is not significant and NSR is not 

applicable to the project for PM2.5. 

Comment 7: Hourly heat input limits should remain. Substitution of annual heat input I limits is insufficient for control of ozone (and insufficient to protect other short term 

NAAQS). Annual averaging would allow higher NOx emissions on hot summer days 

when ozone is already high, leading to exacerbation of ozone levels. 

Response 7: The project proposes to install ULNBs on two heaters, a reduction in shortterm emissions, in addition to the annual heat input limits. The proposed project reduces 

the combined potential NOx emissions for the heaters by 7.30 pounds per hour. 

The proposed changes to the RACT Plan Approval and SIP remove the capability of 

burning refinery fuel oil from five (5) heaters (part of a 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 

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Response 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) not required 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 Heater was 

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 Condition 4.B in the 

modification of the RACT Plan Approval. 

• 	 Condition 3.h was modified to remove making the NOx Ibs/MMBTU limits on a 

rolling 365-day basis for heaters that install a certified NOx CEMS in the future. This 

would inadvertently make the emission limits less stringent. 

This Plan Approval was issued on February 19.2014. The modification to the RACT 

Plan Approval was issued on February 19, 2014. 

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