DEPARTMENT OF PUBLIC BEALTB 

Donald F. Schwarz, MD, MPH 

Depllfl' MororjiJr Heaith & Oppo/'llilli!," 

CITY OF PHILADELPHIA Heallh Cnmmissioner 

Nan Feyler, JD, MPH 

Chie/o/Sh!fl 

Air Management Services 

Thomas Huynh 

Direc'lor 

Source Registration 

321 University Avenue, 2nd Floor 

Philadelphia, PA 19104 

Telephone (215) 685-7572 

Fax (215) 685-7593 

February 19,2014 

Mr. Charles Barksdale 

Philadelphia Energy Solutions Refining and Marketing LLC (PES) 

3144 Passyunk Avenue 

Philadelphia, P A 19145 

PUD: 01501 

RE: 	 Plan Approval Application No. 12195 and RAeT Plan Approval Amendment for the 

Modification of Seven (7) Heaters 

Dear Mr. Barksdale, 

The comment period has ended for Plan Approval Application No. 12195 and the RACT Plan 

Approval Amendment for the modification of seven (7) heaters. Enclosed are the final issued plan 

approval, amended RACT plan approval. and comment response document. 

If you have any questions, please contact me at (215) 685-9426 or edward. wienerrmphila.gov . 

Sincerely, 

c;:u~ t~ Edward Wiener 

Environmental Engineer 
CITY OF PHILADELPHIA 


DEPARTMENT OF PUBLIC HEALTH 


AIR MANAGEMENT SERVICES 


Plan Approval 

Approval No: 12195 Source: Philadelphia Energy Solutions 

Refining and Marketing LLC (PES) 

Plant ID: 01501 

Owner: Philadelphia Energy Solutions Refining 

and Marketing LLC (PES) Location: 3144 Passyunk Avenue 

Address: 3144 Passyunk Avenue Philadelphia, PA 19145 

Philadelphia, PA 19145 

Attention: 	 Mr. Charles Barksdale 

Manager, Environmental Department 

(215) 339-2074 

In accordance with provisions of Title 3 of the Philadelphia Code, the Air Management Code of 

February 17. 1995. as amended, and after due consideration of an application received under the 

rules and regulations of Philadelphia Air Pollution Control Board and the Pennsylvania Department 

of Environmental Protection (PADEP), the City of Philadelphia, Department of Public Health, Air 

Management Services (AMS) on February 19, 2014, approved plans for the modification and 

temporary operation of the air contamination device(s) described below: 

• 	 Replace the MMBTU per hour firing rate limits with MMBTU per rolling 365-day period limits 

for the following seven (7) process heaters: 

o Unit 231 	B101 Heater (rated capacity 104.5 MMBTUlhr) 

o 	 Unit 865 11 H1 Heater (rated capacity 87.3 MMBTU/hr) 

o 	 Unit 865 11 H2 Heater (rated capacity 64.2 MMBTU/hr) 

o 	 Unit 210 H101 Heater (rated capacity 192.0 MMBTUlhr) 

o 	 Unit 210 H201NB Heater (rated capacity 254.0 MMBTU/hr) 

o Unit 866 	12H1 Heater (rated capacity 61.2 MMBTU/hr) 

o 	 Unit 868 8H101 Heater (rated capacity 60.0 MMBTU/hr) 

• 	 Install Ultra Low-NOx Burners (ULNBs) on the following process heaters: 

o Unit 231 	B101 Heater 

o Unit 865 	11 H1 Heater 

This plan approval expires August 19, 2015. 

This plan approval is subject to conditions prescribed in the attachment. 

( , 

I Edward Wiener 

Chief, Source Registration. 

I 

PLAN APPROVAL CONDITIONS 


PLAN APPROVAL NO. 12195 


COMPANY: Philadelphia Energy Solutions 


1. 	 The heaters and crude units listed on the cover shall be operated in accordance with the 

specifications in the application (as approved herein). 

2. 	 Emissions from the heaters shall not exceed the following limits in tons per rolling 12-month 

period, calculated monthly: [Application] 

NOx S02 TPM/PM10/PM2.5 CO VOC GHG 

231 B101 Heater 12.8 0.8 3.1 34.4 2.3 49,243 


865 11 H 1 Heater 10.5 0.7 2.6 28.5 1.9 40,777 


865 11 H2 Heater 28.3 0.5 1.8 20.4 1.3 29,168 


210 H1 01 Heater 73.1 2.7 6.1 66.9 4.4 95,847 


2 10 H201 Heater 32.6 3.2 8.0 88.5 5.8 126,707 


866 12H1 Heater 25.8 0.5 1.7 18.6 1.2 26,601 


868 8H101 Heater 27.1 0.6 1.7 18.9 1.2 27,054 


Total Particulate Matter (TPM), PM10, and PM2.5 emissions include both filterable (Method 51 

201A) and condensable particulate (Method 202) for this condition. 

Greenhouse Gas (GHG) emissions are expressed in terms of Carbon Dioxide Equivalent 

(C02e), based upon a global warming potential of CH4 =21 and N20 =310. 

3. 	 Nitrogen Oxides (NOx) emissions shall not exceed the following: [Application] 

a. 	 0.03Ibs/MMBTU for Unit 231 B101 Heater. 

b. 	 0.03 Ibs/MMBTU for Unit 865 11 H 1 Heater. 

c. 	 0.113 Ibs/MMBTU for Unit 865 11 H2 Heater. 

d. 	 0.089Ibs/MMBTU for Unit 210 H101 Heater. [Case-by-case RACT Plan Approval dated 

August 1, 2000] 

e. 	 0.030 Ibs/MMBTU for Unit 210 H201A1B Heater. [AMS Plan Approval No. 10180, dated 

2/3/11 ] 

f. 	 0.113Ibs/MMBTU for Unit 86612H1 Heater. 

g. 	 0.113 Ibs/MMBTU for Unit 868 8H 101 Heater. 

h. 	 Compliance determination shall be based on a 365-day rolling average and NOx 

Continuous Emission Monitoring System (CEMS) data for Unit 210 H201A1B Heater. 

Compliance determination shall be based on three 60-minute test runs during an AMSapproved stack test for the other heaters. 

4. 	 Particulate Matter (PM) emissions shall not exceed the following: 

a. 	 0.20 Ibs/MMBTU for Unit 231 B101 Heater. [AMR II, Section V.1 - assures compliance 

with 25 Pa. Code §123.11] 

b. 	 0.10 Ibs/MMBTU for Unit 865 11 H1 Heater. [AMR II. Section V.2 - assures compliance 

with 25 Pa. Code §123.11] 

c. 	 0.10 Ibs/MMBTU for Unit 865 11 H2 Heater. [AMR II, Section V.2 - assures compliance 

2 	 2119/14 
PLAN APPROVAL CO.NDITIONS 


PLAN APPROVAL NO. 12195 


COMPANY: Philadelphia Energy Solutions 


with 25 Pa. Code § 123.11 J 

d. 	 0.19 Ibs/MMBTU for Unit 210 H101 Heater. [25 Pa. Code §123.11 - assures 

compliance with AMR II, Section V.1J 

e. 	 0.10 Ibs/MMBTU for Unit 210 H201A1B Heater. [AMR II, Section V.2 - assures 

compliance with 25 Pa. Code §123.11] 

f. 	 0.10 Ibs/MMBTU for Unit 866 12H1 Heater. [AMR II, Section V.2 - assures compliance 

with 25 Pa. Code §123.11] 

g. 	 0.10 Ibs/MMBTU for Unit 868 8H101 Heater. [AMR II. Section V.2 - assures compliance 

with 25 Pa. Code §123.11] 

PM emissions include only filterable particulate (EPA Method 5) for this condition. 

5. 	 Carbon Monoxide (CO) emissions from each heater shall not exceed the following on an 

hourly basis. Application - Ensures compliance with AMR VIII, Section 11.6 for each heater 

and AMS Installation Permit. 03054 dated July 29,2003 for Unit 868 8H101 Heater] 

a. 	 8.6 Ibs/hour for Unit 231 B101 Heater. 

b. 	 7.2 Ibs/hour for Unit 865 11 H1 Heater. 

c. 	 5.3 Ibs/hour for Unit 865 11 H2 Heater. 

d. 	 15.7lbs/hourfor Unit 210 H101 Heater. 

e. 	 20.8 Ibs/hour for Unit 210 H201A1B. 

f. 	 5.0 Ibs/hour for Unit 866 12H1 Heater. 

g. 	 4.9 Ibs/hour for Unit 868 8H101 Heater. 

h. 	 Compliance determination shall be based on three 60-minute test runs during an AMSapproved stack test. 

6. 	 Sulfur Dioxide (S02) emissions from each heater shall not exceed 500 ppmvd. [25 Pa. Code 

§123.21(b)] 

7. 	 Each heater shall only burn refinery fuel gas. 

a. 	 Each heater shall not burn any fuel gas that contains hydrogen sulfide (H2S) in excess 

of 230 mg/dscm (0.10 gr/dscf) [40 CFR 60.1 04(a)(1), Consent Decree Order 05-CV2866] 

8. Each heater shall be limited to the following rolling 365-day heat input limits: [Application] 

a. 	 Unit 231 B101 Heater shall not exceed 856,000 MMBTU on a rolling 365-day 

basis. 

b. 	 Unit 865 11 H1 Heater shall not exceed 699,000 MMBTU on a rolling 365-day 

basis. 

c. 	 Unit 865 11 H2 Heater shall not exceed 500,000 MMBTU on a rolling 365-day 

basis. 

d. 	 Unit 210 H101 Heater shall not exceed 1,643,000 MMBTU on a rolling 365-day 

basis. 

e. 	 Unit 210 H201A1B Heater shall not exceed 2,172,000 MMBTU on a rolling 365-day 

basis. 

3 	 2/19/14 
PLAN APPROVAL CONDITIONS 


PLAN APPROVAL NO. 12195 


COMPANY: Philadelphia Energy Solutions 


f. 	 Unit 866 12H1 Heater shall not exceed 456,000 MMBTU on a rolling 365-day 

basis. 

g. 	 Unit 868 8H101 Heater shall not exceed 480,000 MMBTU on a rolling 365-day 

basis. 

9. 	 The Permittee shall Install Ultra Low-NOx Burners (ULNBs) on the Unit 231 B101 

Heater and the Unit 865 11 H1 Heater within 18 months of the issuance of this plan 

approval. Each heater must comply with its existing MMBTU/hr firing rate limit until it 

has ULNBs installed and has demonstrated compliance with the 0.03 Ibs/MMBTU NOx 

emission limit through an AMS-approved stack test. The NOx emission limits in 

Conditions 2 and 3 for these heaters are not applicable until the ULNBs have been 

installed. [Application] 

10. The Permittee shall operate the facility consistent and within the projected future actual 

emissions basis contained in the plan approval application. [Application] 

11. The Permittee shall perform an annual adjustment or tuneup on each heater. This adjustment 

shall include, at a minimum, the following: [Case-by-case RACT, 25 Pa. Code §§129.91-95, 

Section 2E; 25 Pa. Code §129.93(b)(2) and (5)] 

a. 	 Inspection, adjustment, cleaning or replacement of fuel-burning equipment, including the 

burners and moving parts necessary for proper operation as specified by the 

manufacturer. 

b. 	 Inspection of the flame pattern or characteristics and adjustments necessary to minimize 

total emissions of NOx, and to the extent practicable minimize emissions of CO. 

c. 	 Inspection of the air-to-fuel ratio control system and adjustments necessary to ensure 

proper calibration and operation as specified by the manufacturer. 

d. 	 For gas fired units requiring an annual adjustment or tuneup on the combustion process, 

the Permittee shall make the annual adjustment in accordance with the EPA document 

"Combustion Efficiency Optimization Manual for Operators of Oil and Gas-fired BOilers," 

September 1983 (EPA-340/1-83-023) or equivalent procedures approved in writing by 

the AMS. 

12. Each heater shall comply with 40 CFR 63 Subpart 00000 by no later than January 31, 2016. 

[40 CFR 63.7495(b)] 

13. Within 180 days of the installation of ULNBs for the Unit 231 B101 Heater and the Unit 865 

11 H1 Heater and within 180 days of the issuance of this plan approval for the other heaters, 

the Permittee shall conduct the following performance tests: 

a. 	 NOx for each heater besides the Unit 210 H201A1B Heater, to determine compliance 

with NOx emission limits in Condition 2 of this plan approval and to use for determining 

compliance with the rolling 12-month NOx emission limit in Condition 3. 

4 	 2'19114 
PLAN APPROVAL CONDITIONS 


PLAN APPROVAL NO. 12195 


COMPANY: Philadelphia Energy Solutions 


b. 	 CO for each heater to determine compliance with the CO emission limits in Condition 5 

and to use for demonstrating compliance with the rolling 12-month CO emission limit in 

Condition 3. 

c. 	 The NOx and CO tests must be conducted simultaneously. 

d. 	 Testing shall be conducted in accordance with 25 Pa. Code Chapter 139. The 

Permittee shall submit a test protocol to AMS for approval at least 30 days prior to the 

first test and shall submit a test report with the results no later than 60 days after 

completion of the last test. If at any time AMS has cause to believe that air contaminant 

emissions from the heaters for any pollutant may be in excess of the limitations 

specified in this plan approval, or established pursuant to, any applicable rule or 

regulation contained in 25 Pa. Code Article III, the Permittee shall be required to 

conduct whatever test are deemed necessary by AMS to determine the actual emission 

rate(s). 

14. The Unit 210 Heater 201A1B shall be equipped with continuous monitors and recorders for 

NOx and 02. The continuous monitors and recorders shall meet the requirements of 25 Pa. 

Code Chapter 139. [Consent Decree Order 05-CV-2866, 25 Pa. Code §123.51] 

15. Compliance with the NOx limits in Condition 3 shall be based on a rolling 365-day average and 

NOx CEMS data for heaters with certified NOx CEMS and AMS-approved stack test data for 

the other heaters. 

16. Compliance with the rolling 12-month limits in Condition 2 shall be monitored and recorded on 

a monthly basis for each heater and shall be based on heat input and the following: 

a. 	 NOx CEMS data for heaters with certified NOx CEMS and the most recent AMSapproved stack test data for the other heaters. An AMS-approved method may be used 

for the period prior to the completion of the stack tests. 

b. 	 CO limits shall be based on the most recent AMS-approved stack test data for each 

heater. An AMS-approved method may be used for the period prior to the completion of 

the stack tests. 

c. 	 For the other pollutants, AMS-approved stack test data if a stack test is ever required. 

Otherwise, AP-42 or other or other AMS-approved emission factors shall be used. 

17. Compliance with the NOx Ibs/MMBTU emission limits for the heaters listed in Condition 3 shall 

be monitored by quarterly stack sampling with a portable NOx analyzer for any heater without 

a certified NOx CEMS. After one year of sampling, the Permittee may petition AMS for 

semiannual monitoring. AMS may, at any time, require three one-hour stack tests. 

18. The Permittee shall utilize an instrument for continuously monitoring and recording the 

concentration (dry basis) of H2S in fuel gases before being burned in any ofthe heaters that 

meets the requirements of 25 Pa. Code Chapter 139. [40 CFR 60.1 05(a)(4)] 

a. 	 The span value for this instrument is 425 mg/dscm H2S. 

5 	 2/191\4 
PLAN APPROVAL CONDITIONS 


PLAN APPROVAL NO. 12195 


COMPANY: Philadelphia Energy Solutions 


b. 	 Fuel gas combustion devices having a common source of fuel gas may be monitored at 

only one location, if monitoring at this location accurately represents the concentration 

of H2S in the fuel gas being burned. 

c. 	 The performance evaluations for the H2S monitor shall use Performance Specification 7. 

Method 11 shall be used for conducting the relative accuracy evaluations. 

d. 	 H2S shall be monitored at the locations listed in their Title V operating permit. 

19. The Permittee shall operate a parametric emissions monitoring system (PEMS) on the 868 8H 

101 heater (CU-129) for Carbon Monoxide. The chosen parameters and software CEM shall 

accurately predict the emissions. Accuracy of the system shall be demonstrated during a 

stack test. The parameters and predicted emissions shall be monitored and recorded 

continuously to ensure compliance with the Carbon Monoxide emission limitation of 400 

ppmdv at 3% oxygen. [AMS Installation Permit. 03054 dated July 29, 2003] 

20. The Permittee shall monitor and record the refinery fuel gas heating value and consumption 

daily, when each heater is in operation. 

21. The Permittee shall monitor and record the MMBTU heat input for each heater hourly and on a 

rolling 365-day basis, calculated daily, to verify compliance with Condition 8. 

a. 	 Fuel gas BTU content shall be continuously monitored and recorded using the 

continuous heat input monitor at the 862 Unit or tested and recorded daily. The 862 

Unit continuous heat input monitor shall meet the requirements of 25 Pa. Code Chapter 

139. 

22. The Permittee shall monitor and record compliance with the rolling 12-month limits in Condition 

2 on a monthly basis. 

a. 	 Compliance with NOx limits for heaters with a certified NOx CEMS shall be based on 

CEM data. Missing or invalid data shall be handled using the missing data substitution 

procedures of 40 CFR Part 75. 

b. 	 Compliance with NOx limits for the other heaters and CO limits for all heaters shall be 

based on the most recent AMS-approved stack test and heat input or other AMSapproved method for periods prior to the AMS-approved stack test. 

c. 	 Compliance with other limits shall be based on AP-42 or other AMS-approved emission 

factors and heat input. 

23. 	The Permittee shall monitor and record the operating information and estimated emissions for 

all target heaters and ancillary units daily and on a rolling 12-month basis, calculated monthly, 

to demonstrate compliance with Condition 10. Calculations shall be based on AMS-approved 

stack test or CEM data when available. Otherwise, calculations shall use the methods in the 

plan approval application unless approved by AMS. Records shall be kept in an AMSapproved format that includes the following for each unit: 

a. 	 The projected future actual emissions listed in the application. 

b. 	 The emissions during the previous rolling 12-month period, calculated monthly. 

c. 	 The calculation method. 

6 	 2/19114 
PLAN APPROVAL CONDITIONS 


PLAN APPROVAL NO. 12195 


COMPANY: Philadelphia Energy Solutions 


24. The Permittee shall keep records of all annual adjustments and tuneups required in Condition 

11. 

25. The Permittee shall submit quarterly reports to AMS for the continuous monitors required in 

Conditions 14. 18, and 21.a in accordance with 25 Pa. Code Chapter 139 and the 

Pennsylvania Continuous Source Monitoring Manual. 

26. The Permittee shall report excess emission from the process heaters defined as follows: [40 

CFR 60.105(e)] 

a. 	 All rolling 3-hour periods during which the average concentration of H2S as measured 

by the H2S continuous monitoring system 230 mg/dscm (0.10 gr/dscf), 

27. The Permittee shall submit quarterly reports on the compliance with Condition 10 in an AMSapproved format. 

7 	 2/19/14