Tulsa Refinery (
Sunoco, Inc.

# ~ PO Box 2039 Tulsa OK 74102-2039 November 28,2006 Mr. Eddie Terrill Division Director, Air Quality Division Oklahoma Department ofEnvironmental Quality 707 North Robinson, P.O. Box 1677 Oklahoma City, Oklahoma 73101-1677 Subject: Applicationfor a Best Available Retrofit Technology (BART) Waiver (OAC 252:100-8-73) for the Sunoco Tulsa, Oklahoma Refinery Dear Mr. Terrill: This is inresponse to your letter of March 22, 2006, dealing with Best Available RetrofitTechnology (BART) Determinations, Waivers, and Exemptions. Sunoco has reviewed BART eligibility ofeach source atthe Tulsa refinery, and has conducted air quality modeling of BART-eligible sources in accordance with the guidelines contained inthe Central Regional Air Planning Association (CENRAP) Protocol, as directed inyour letter. The modeling results show that predicted maximum impacts from BART-eligible sources at the Tulsa refinery are less than 0.5 deciviews at the closest Class I area. Accordingly, Sunoco requests a waiver under OAC 252:100-8-73, so that the Sunoco Tulsa refinery will not be subject to further BART analysis or requirements.

# Z::Z11~ RECEIVED AndrewHaar Environmental Manager 

# I NOV

# ~! 2006

# 1

enclosures: BART Exemption Modeling Report 

# AIR 

# QUALITY cd-ROM

cc: 

## \Lee Warden 

### QQ]jQ

W:\ENVIRONMENTAL\AIR\BART\SUNTULSA_BART_WAIVER.DOC n 1706FINAL REPORT



### Sunoco, Inc. 

# Visibility Modeling Analysis 

# Sunoco Tulsa, OKRefinery BARTExemption Modeling

13 November 2006

0021048 

# RECEIVED NOV 292006

# A'~ 

# QUALXiV

Environmental Resources Management 350 Eagleview Boulevard Suite 200 Exton, Pennsylvania 19341

W:\**ENVIRON~IENTAL\t\lR\** BAKI\SU1\OC0_TULS,UlARTjINAL.DOC II 1706 !TABLE OF CONTENTS

EXECUTIVE SUMMARY 1.0 BACKGROUNDAND OVERVIEW 1 1.1 Tlze Regional Haze Rule and BART 1 1.2 The Sunoco Tulsa Refinenj andApplicability of BART 2 1.3 Report Organization 3 2.0 MODELING METHODOLOGY 4 2.1 BARTEligible Sources and Emissions Modeled 4 2.2 Modeling and Meteorological Domain 8 2.4 CALPUFF Modeling Setup 10 2.5 CALPOSTPost Processing 11 3.0 RESULTSANDDISCUSSION 

### 13

LISTOF TABLES Table 2-1 Summary of BART Sources Considered in CALPUFF Modeling Table 2-2 Summary of Sources Included in IIMiscellaneous ll Source Table 2-3 Summary of Sources Not Included in BART Modeling Analysis Table 2-4 Relative Humidity Correction Factors Table 2-5 Natural Background Concentrations Table 2-6 Monthly Average Ozone and Ammonia Concentrations Table 3-1 Summary of Maximum Visibility Impacts (in Delta-Deciviews) LISTOFFIGURES Figure 2-1 Locations ofClass I Areas Relative to the Sunoco Tulsa Refinery

APPENDIXA CD-ROM With ModelingFiles

ERM SUNOCO**TULSA/002JO~8-03** 13 NOVHIBER 2006EXECUTIVE SUMMARY Regulations developed by the USEPA under the Clean Air Act, related to the protection ofvisibility incertainnational parks and wilderness areas (referred to as Class I Areas), will require the installation ofthe Best Available Retrofit Technology (BART) for some categories of existing air emissions sources. The SunocoTulsa Refinery was notified by the Oklahoma Department ofEnvironmental Quality (ODEQ) that some sources at the refinery may be subject to the BART rule, adopted in Oklahoma as a regulationunder the Oklahoma AdministrativeCode (OAC), Subchapter 8, Part 11. BART requirements apply to sources that were installed and commenced operationbetween August 1962 and August 1977. Several sources at the Tulsa Refinery meet this definition, and are therefore considered "BART-eligible". The ODEQ notification stated thatfacilities with BART-eligible sources may request an exemptionfrom the BART requirements. The exemption must be based on air quality modeling that demonstrates aninsignificant impact onvisibility inClass I areas. The exemption modeling is to be performed, using the CALPUFF model, in accordance with a strict protocol spelled outinguidance documents provided by the Central Regional Air Planning Association (CENRAP), ofwhichOklahomais a member. Sunoco has conducted modeling, using the CALPUFF model in accordance with the CENRAP protocol, and has evaluated the impacts of BART-eligible sources at the SunocoTulsa Refinery on visibility infour Class I areas: the Wichita Wilderness inOklahoma; the Caney Creek Wilderness and Upper Buffalo Wilderness Areas in Arkansas; and the Hercules Wilderness Area in Missouri. Meteorological datafor three years (2001, 2002, and 2003), as provided by CENRAP, were used inthe modeling. This report provides a description of the methodology and results of the BART exemption modeling. Model results for all four Class I areas, over all three years modeled, show thatthe maximum visibility impacts are less than 67% of the BART exemption threshold. Based on these results, upon submittal and acceptance ofthe modelingreportby ODEQ, the Sunoco Tulsa Refinery, will be exemptfrom further BART requirements.

SUNOCO**TULSf\f0021O~8-03** 13 NOVHIBER 2006 ERM

### 1.0 BACKGROUNDAND OVERVIEW This report describes the methodology andresults of a modeling analysis, using the CALPUFF screening approach as outlined in the CENRAP BART modeling guidelines. The analysis was conducted to determine if 

### the Sunoco Refinery located inTulsa, OK, owned and operated by Sunoco, Inc. (Sunoco) is subject to the BART rule. The results ofthe analysis, discussed further in this report, demonstrate thatmaximum facility impacts, using conservative approaches in the modeling and in specifying facility emissions, are substantially less than the visibility exemption threshold of0.5 deciviews, inall Class I areas modeled. The Sunoco Refinery should therefore be exemptfrom further BART review. 

### 1.1 The RegionalHazeRuleandBART On 6 July 2005 a final rule regarding Regional Haze Regulations and Guidelines for Best Available Retrofit Technology (BART) Determinations was published inthe federal register. The final rule requires certain sources affected by the rule to install and operate BART controls. The BART provision oftherule affects facilities belonging to one of28 source categories defined in the Clean Air Act (CAA) and emitting greaterthan 250 tons per year ofvisibility impairing pollutants which include nitrogen dioxide (NOx), sulfur dioxide (502), and particulate matter (PMI0). Individual sources within these facilities, which were installed and commenced operationbetween 1962 and 1977, are subject to the BART process. The BART guidelines specify a step-wise approachfor the states and other regulatory agencies to determine and establish emission limits for affected sources. For sources located in the Central United States, the

. . 

### Central Region Air Planning Association (CENRAP) provides guidelines for BART affected sources. The individual states, however, are responsible for regulating the BART-subject sources and establishing source-specific emission limits. The Oklahoma DepartmentofEnvironmental Quality (ODEQ) has developed a regulation, Oklahoma Administrative Code (OAC), Subchapter 8, PartII, to address the requirements ofthe BART rule. Under the regulation, a facility canrequest exemptionfrom the BART rule as per OAC 252: 100-8-73, based on the following conditions: 1. If 

### the SOx and NOx emissions from the facility are less than40 tpy and the PMI0 emissions are less than 15 tpy; or

ERM 1 SUNOCO TULSA/0021Q·18·03 13 NOVEMBER 2006

### 1.2 2. If

### the facility demonstratesby modeling that the BART-eligible sources at the facility do not contribute to visibility impairment in any mandatory Class I federal areas. The ODEQ requires sources who intend to conduct dispersion modeling for the exemption from BART requirements to submit the modeling analysis by 1 December 2006. The exemption will be granted by EPA uponwrittenconcurrence from the AQD director. If

### the facility does not qualify for the exemptionbased onmodeling, a BART determinationis required to be submitted to the Departmentby 30 March 2007. ODEQ notified Sunoco about the applicability of BART for sources at the Tulsa Refinery by a letter dated 22 March 2006. The first step in the BART process is identifying sources which are subject to the BART process. BART-eligible sources atthe Tulsa Refinery were identified based ona review ofthe Title V permit.

. These "BART-eligible" sources are responsible for demonstrating if they qualify for anexemption from the rule based onestimates ofvisibility impacts inClass I areas. CENRAPhas provided BART modeling guidelines which specify the requirements for individualsources to qualify for an exemptionby conducting a visibility modeling analysis. The sources canconduct the analysis using the regulatory model, CALPUFF, to show that the impacts onvisibility atClass I areas potentially affected by the source are less than the significance level established inthe guidelines and adoptedby the State. 

### The Sunoco Tulsa Refinery andApplicability of BART The Sunoco refinery inTulsa, OK, is owned and operated by Sunoco, Inc. The Tulsa refinery is operated primarily to producehigh quality lubricating oils by blendinga mixture ofcrude oils from different sources. Refinery fuel gases, propane, butane, isobutane, normal butane, gasolines, kerosene, No.2 fuel oil, paraffin wax, petroleumcoke, and Lube Extracted Feedstock (LEF) are some ofthe currentby-products from making the lube oils. LEF is a mixture ofunfinished streams that may also be transferred to third party purchasers. The operations at theFacility fit the description ofthe Petroleum Refineries category

- one ofthe 28 sources categories listed inthe BART rule. The potential emissions of NOx, SOx, and PM from all BART-eligible sources at the Facility are equal to 845 tpy, 1,210 tpy, and 38 tpy, respectively. More than halfofthe units at the facility werebuilt either before 1962 or after 1977. Only those units which were constructed and began operation within this time period are subject to the BART process. However, ODEQ has providedthe opportunity to all BART-eligible sources through the regulation under Subchapter 8, Part 11, to evaluate the visibility impacts resulting from the emissions from the

ERM 2 SUNOCO**TU1~SA/0021Q48·()3** B NOVHIBEH 2U06

### 1.3 BART-eligible sources onClass I areas to determine whether thefacility is subject to the BART rule.

,This report discusses the methodology adopted by Sunoco to**~etermine**

impacts onClass I areas, and summarizes the results ofthe air dispersion modeling. The Oklahoma regulations referred to the CENRAP modeling protocol to conduct the dispersion modeling analysis. Since Sunoco has followed the CENRAP modeling guidelines, no additional modeling protocol is required, according to ODEQ. 

### Report Organization Section 2 of the reportdiscusses the methodology adopted by Sunoco to conductthe dispersionmodeling analysis. The BART eligible sources are identified and a summary of emissions and stack information is presented in this section. This section describes the modeling domain and the meteorological dataused in the analysis. A discussion of the background visibility conditions atthe Class I areas ofconcern is presented. Section 3 presents the results and the conclusions whichcanbe drawn from the analysis.



### 3 5Ul\OCO**TULSt\/oa21O~8.{j3** 13 NOVEMBER 2006 ERM

### 2.0 MODELINGMETHODOLOGY The CENRAPmodeling guidelines describe three categories ofdispersion modeling: screening modeling, source-specific refined modeling, and alternative modeling analysis. This reportpresents the results ofa screening modeling analysis for the Facility. The CALPUFF dispersion model and CALPOST post-processor, as recommended in the CENRAP BART guidelines, and the meteorological data developed and made available by CENRAP, were used in this analysis. The model impacts are to be compared with the visibility threshold ofa 0.5 deciview change established by ODEQfor qualifying for anexemptionfrom further BART evaluation. The model versions used inthis analysis were those recommended by CENRAP: CALPUFF version 5.711a and CALPOST version 5.51. 

### 2.1 BARTEligible Sources andEmissions Modeled Sunoco has a total of 16 emissions units atthefacility which are BARTeligible. These emissions units are BART-eligible becausethey werebuilt and began operationsbetween 1962-1977. Emissions units, the potential to emit (PTE), and the stack parameters associated with the emissionunits are summarized'inTable 2-1. The PTE values presented in the table were obtained from the existing Title 

### V permitfor the Tulsa Refinery; actual emissions for these sources have historically been considerably lower than the PTE. Stack parameters for some sources were notreadily available; therefore emissions from these sources were combined into a single representative stack (noted as the "miscellaneous" stack inTable 2-1). Table 2-2 provides information onthe emission units modeled withthe representative stack. It shouldbe noted that treating these sources by modeling a single stack will have an insignificant effect onthe model predictions, because the closestClass I area tothe facility is at a distance of greater than 230 kilometers from the facility. Table 2-3 prOVides information on the emissionunits which are not BART-eligible as they fall outside of the time period between 1962 and 1977. The CENRAP BART modelingguidelines specify that the 1/

..24-hour average actual emission rate withnormal operations from the highest emitting day ofthe year shouldbe modeled" (Section 6.4.4). ForSunoco, this rate is likely to be lower than the rate represented by the PTE. Nonetheless, for the sake ofsimplicity, emission rates corresponding to the PTE for each source were modeled.

ERM 4 Sl,;NQCO**TULSA/00210~8·03** 13 NOVEMBER 2,106Table 2-1 Summary of BARTSources CO/lsidered ill CALPUFFModelillg
Base Exit Stack Elevation Stack Temperature Velocity Diameter Installation Source ID Source Description (m) UTME UTMN Height (m) (K) (m,ls) (m) Date Potential Emissions (tpy) NOx PM S02

---­**-U28··~** t-­ 214 #2 PlatPH-7 636.2 768136 4003693 30.78 1039.26 11.403 1971 11.4 0.85 89.7 240 PDA B-40 640.1 768699 4003511 1262 587.04 9.955 0.914 1%2 11.4 0.85 90.1 242 ILEUHI01 640.1 769101 4003453 27.43 543.15 6.527 0.914 1963 9.6 0.75 78.5 244 LEU H-201 640.1 769101 4003445 3Q.48

. 619.26 2402 1.615 1%3**9~·** 0.75 78.5 109 #7 boiler 640.1 768565 4003597 18.29 429.82 29.362 1.524 1975 131.4 4.9 0.44 110 #8 Boiler 640.1 768565 4003605 18.29 480.37 32.814 1.524 1976 131.4 4.9 0.44 111 #9 Boiler 640.1 768571 4003560 24.38 403.15 27.541 1.524 1976 131.4 4.9 0.44 245 MEKH-I01 640.4 769125 4003459 34.14 478.15 12.096 1.829 1977 35.5 2.7 1.45 269 LEU Flare 638.1 769031 4OO3461L,**,.-35:Q~** 92204 0.001**0.3~~** 1976 0.19 

### - 0.51

_. 266 WPUFlare 638.5 768850 4003750 4237 92204 0.001 0.381 - 0.12 - 0.1 268 CokerRare 633.9 768268 4003881 44.5 922.04 0.001 0.381

- 0.18 - 0.1 267 #2 AlkylFlare (plat) 632.5 768008 4003799 43.89 1273 20 1

- 2.2

- 13 241 PDA Propane CompEng 640.1 768666 4003507 6.71 588.71 2064 0.152

- 56.04 0.14 0.01 243N LEU H-I02 N 640.1 769109 4003460 38.1 558.15 8.013 1.615 1963 65.7 5.87 854 257 #6 CT Circulation Pump 640.1 768515 4003593 5.49 616.48 15.396 0.305 - 19.5 0.49 om



### - Miscellaneous 640.1 768600 4003598 30.48 405.65**5:2~** 3.2
- 229.36 11.03 i-­ 3.09
TOTAL 845 38 1,210

---­ ._­**ER~l** 5 SUNOCO TULSA/002104&-ll3 13 NOVEMlJER 2006Table 2-2 Summary orSources Included in "Miscellaneous" Source Base Exit Elevation Stack VellKity Stack Source lD Source Description (m) UTME UTMN Height(m) Temperature (K) (mls) Diameter (m) Installation Date Potential Emissions (tpv) NOx PM S02 208 UnifinerH2 CompEng 

### - - - 

### - 47.18 0.12 0.01 - 

### - - 

### - 254 #2Q?prav Pump Eng 

### - - 

### - - - - 

### - - 42.17 0.10 0.01 255 #2 crCirc Pump Eng 

### - - - - - - - - 66.48 0.16 0.01 258 #6 crSpray Pump Engine - 

### - - - - - - - 35.03 0.09 om

..... EG6217
-------­ Emergency 

### - - - - 

### - 

### - - - 3.62 0.11 0.61 EG6218 Emergency - 

### - - - - - - - 3.62 0.11 0.61 EG6312 Emergency - - - - - - - - 3.62 0.11 0.61 EG6289 Emergency - - 

### - - - . - - 3.62 0.11 0.61 EG6290 Emergency

- - - - - - - - 3.62 0.11 0.61

256 #3 crCirculation Pump - - - 

### - 

### - - - - 20.40 0.51 om CoolingTowers - - - - 

### - - - - - 9.50 

### - TOTAL 229 11 3

::>**.~ .ER~I**  6 SUNOCOTULSAjOO2I().18"()313 NOVEMBER 2006Table 2-3 Summary ofSources notconsidered ill CALPUFFModeling (Installation Date Outsideofthe BARTtimeframe of Aug 1962 toAug. 1977)
Base Exit Slack Elevation Stack Temperature Velocity Diameter Installation Source ID SourceDescription (m) UTME UTMN Height(m) (K) (m/s) (m) Date PotentialEmissions (tpy) NOx PM S02 105A #1 Boiler 640.1 768600 4003598 30.48 405.65 5.925 3.2 1948 184 4.99 526 1058 #2 Boiler 640.1 ·768600 4003598 30.48 405.65 5.925 3.2 1948 184 4.99 526 106A #3 Boiler 640.1 768582 4003598 33.53 404.15 5.967 .3.2 . 1954 184 4.99 526 238 PDA 8-30 640.1 768700 4003500 16.46 547.04 2558 0.914 1956 4.8 0.37 38.5 1068 #4 Boiler 640.1 768582 4003598 33.53 404.15 5.967 3.2 1957 184 4.99 526 206 UnifinerH-2 638.5 768139 4003649 20.12 573.71 6.362 1.372 1957 16.2 1.22 129 207 Unifiner H-3 637.5 768137 4003661 23.47 522.04 50.604 0.61 1957 26.3 1.98 208

------­ 1--­ 38 -­**~2.89** 209 #2Plat**PH~1/2** 636.2 768134 4003700 27.74 884.26 10.341 2134 1957 304 210 #2PlatPH-3 637.1 768137 4003668 15.24 672.59 7.202 1.372 1957 15.8 1.22 U7 211 #2 Plat PH-4 637.1 768136 4003675 15.24 454.82 4.928 1.524 1957 19.7 1.49 157 213 #2 Plat PH-6 636.2 768141 I-------=-c_-------­ 1--------­

---------­ (1) 4003709 25.91 768.71 1.64 1.524 1957 (1) (1) 246 IMEKH-2 640.4 769130**400345~** ------­ 483.15 12.957 Ul67 1960 21.5 1.63 172 18.95 201N CDUH-1,N#7 63--ZS­ 768162 4003517 41.15 521.48 7.279 2256 1961 171 4.66 491 2015 CDU H-1,5#8 637.5 768163 4003502 41.15 518.15 7.232 2256 1961 171 4.66 491 202 CDUH-2 638.1 768182 4003504 38.1 713.36 12.932 2134 1961 29.4 2.63 745 203 CDUH-3 638.1 768182 4003504 38.1 713.36 12932 2134 1961 18.9 1.71 479 212 #2Plat PH-5 636.2 768148 4003711 27.43 731.48 2147 2134 1990 56.5 2 0.5 225 Coker 8-1 640.1 768395 4003829 34.14 620.37 11.914 1.676 1992 26.28 2**~** 224 CokerH-3 640.1 768393 4003820 27.74 550.93 11.261 1.219 1995 9.17 2.12 8.76 TOTAL 1,361 51 5,456
(1) Emissions included with#2PlatPH-5

ERM 7 SUNOCO TUlSAI0021048..(13 13 NOVEMBER 2006

### 2.2 ModelingandMeteorologicalDomain The Sunoco Refinery inTulsa, OKis located in north-east Oklahoma,just west of Interstate 75 (1-75). The CENRAP modeling guidelines define three separate slightly overlapping modelingdomains

- north, central, and south

- each ofwhichhave a grid resolution of 6 km. The extent of the central domain and the facility location is shown in Figure 2-1. Class 1 areas within orclose to CENRAP are also shownin this figure. The Tulsa Refinery is located at the center of the CENRAP central domain. The closest Class 1area is approximately 230 kilometers from Tulsa. The CENRAP modeling guidelines state thatClass 1areas within 300 kilometers ofa facility should be modeled (Section 6.4.3). Atdistances greater than 300 kilometers, the capability ofCALPUFF to accurately simulate individual source impacts is diminished. Options within CALPUFF, including the capability to split puffs atlarge distances, are available to address transportdistances greater than300 kilometers, however, the CENRAP guidelines recommend againstusingthese options. Four ClassI areas were selected for modeling, all ofwhich arebetween 200 and 300 kilometers ofSunoco. These Class 1areas include Caney CreekWilderness and Upper Buffalo Wilderness in Arkansas; Hercules Wilderness in Missouri; and Wichita Wilderness in Oklahoma. For each Class I area, receptor locations and elevations were developed based on the National ParkService receptor files. A total of 291 receptors were included in the modeling analysis. Figure 2-1 shows the location ofGass 1 areas modeled to evaluate the impact ofemissions from the Sunoco facility.

ERM 8 SUNOCOTULSA/0021048.U3 BNOVEMllER2006

.

# °1 Figu,.. 2-1 Map Showing

# th~ L""'fionofCia" , M

...
-100

·200

·300

·400

-500**l11ill~Wild ~--.-~--t-~---f-----**  _____**-~---i** Sunoco Tulsa 

## *

·600

·700

-800 200 km

.Map coordinates are in R.ia'" .•to the Sun",oTu'

.., 0 K R.nn.

·300 -200 ·100 o· 100 200 300 400 500 600 

### The background visibility conditions to be used in screening analyses are defined inthe CENRAP modeling guidelines (Table 6-3 inthe guidelines). These conditions are specified for the eastern and western U.S., where the dividing line betweeneast and west is defined in the guidelines to be in the middle ofthe CENRAP region, e.g. Oklahoma is in the west and Arkansas is inthe east. The Class I area inOklahoma (the Wichita Wilderness) is in the west based onthis definition, while the other Class I areas modeled are in the east. The monthly relative humidity adjustment factors, used in calculating visibility impairmentfor hygroscopic species, were obtained from EPA's 2003 document "Guidance for Estimating Natural Visibility Conditions under the Regional Haze Rule", as directed inCENRAP's guidance document. The relative humidity correction factors, and the natural background concentrationvalues, are summarized inTables 2-4 and 2-5, respectively, for each Class I area.

ERM 9 SUNOCO TUISA/01l2104S·03 B**NOVE~IBER** 2006Table 2-4 Relative Humidity Correction Factors Class I Area Jan Feb Mar Apr Relative Humidity Factor (fRH) May Jun Jul Aug Sep Oct Nov Dec Caney Creek Wilderness 3.3 3.0 2.7 2.8 3.2 3.2 3.0 3.0 3.2 3.2 3.1 3.3 Hercules Glades Wilderness 3.2 2.9 2.6 2.6 3.0 3.0 3.0 3.0 3.2 2.9 3.0 3.2 UpperBuffalo Wilderness 3.2 2.9 2.6 2.7 3.1 3.1 3.0 3.0 3.2 3.0 3.0 3.2 Wichita Mountains Wilderness 2.8 2.4 2.4 2.7 2.5 2.2 2.4 2.7 2.5 2.6 2.8

Table 2-5 Natural Backgrolllld Concentratiolls Class I Area Average NaturalBackgroundConcenh'ations (ug/m3) West or Ammonium Ammonium Organic Elemental

East Sulfate Nitrate carbon mass carbon Soil Coarse Mass Caney Creek Wilderness E 0.23 0.10 1.40 0.02 0.50 3.00 Hercules Glades Wilderness E 0.23 0.10 1.40 0.02 

# = 0.50 3.00 Upper Buffalo Wilderness E 0.23 0.10 1.40 0.02 0.50 3.00 Wichita Mountains Wilderness W 0.12 0.10 0.47 0.02 0.50 3.00

2.4 

### CENRAP has developed the meteorological data for conducting sourcespecific BART analysis for eligible sources within the CENRAPregion. The datacovers the three-year time period from 2001 through 2003, and covers different extents for the three modeling domains described above. The grid spacingfor each ofthe meteorological domains is 6 kilometers. The CALMET meteorological pre-processor was used by CENRAP to generate these data sets, and

- consistent with the screening approach­

. CALMET wasnot used to re-create meteorological data sets inthe present

analysis. 5unoco obtained the central domain meteorological data sets for use inthis BART exemption modeling. The CALMET meteorological data sets were evaluated by creating summaries of domain-wide meteorological parameters for each year. A review ofthis summary indicates thatranges and averages ofall parameters appear to be reasonable. The diurnal pattern ofthe stability category and temperature values, however, indicates that the CALMET runs were conducted with the base time zone set to 0 instead ofa value thatreflects the location ofthe CENRAP states. This settingis not expected to affect the results ofthe modeling. CALPUFFModeling Setup 

### This section describes the input parameters and the setup used for conducting the CALPUFF modeling analysis. Emissions of NOx, 502, and PM10 from sources at the 5unoco facility emission sources were modeled at the PTE rates shownin Table 2-1. Downwash due to on-site structures was notmodeled, since downwash impacts are important primarily in the immediate vicinity ofthe source and not at distances of several hundred kilometers. The parameter settings shownin the

SUNOCO TULSA!0021048·03 13 NOVEMBER 2006 ERM 

### 10CENRAP modeling guidelines Appendix Bfi.e. the recommended settings for CALPUFF screeningmodeling, were used in this analysis with only a few changes. Somechanges were necessary to ensurethat thecentral domain settings were used. Otherchanges were as follows: XBTZ: the base time zone was set to 0 instead of 6, to allow use of the CALMET files developedby CENRAP; NSPEC: the number of species modeled was set to 6 instead ofthe recommended 10 to reflect the Sunoco facility emissions; NSE: the number of species emitted was set to 3 instead ofthe recommended 6 to reflect the Sunoco facility emissions; IVIS: visibility optionwas setto 0 (do not generate a relative humidity file) since post-processing for CALPUFF screening applications does not use this file; ICPRT: the print option was setto 0 (do not printto list file) to conserve output disk space. Ozone and ammonia concentrations are required in order for CALPUFF to simulate the S02 and NOx transformation chemistry that forms sulfates and nitrates, and subsequently the formation ofparticulate nitrate thatis used to estimate visibility impacts. The domain-wide, monthly average ammoniaconcentrations providedby CENRAP were used inCALPUFF. Ozone concentrations were specified intwo different ways, and CALPUFF was runwitheachoption. The first used hourly ozone concentrations across the domain, based onCAMx model runs, as provided onthe CENRAPftp site. The hourly ozone file was providedfor calendar year 2002, and this file was used to create hourly files for 2001 and 2003 by simply changing the date. The second option utilized domain-wide monthly averages that werecreated from the hourly ozone file, where only daytime values (hours 6 amto:6 pm)were used to create the p.verages. Table 2-5 displays the monthly average ozone and ammonia concentrations used inCALPUFF.
Table 2-6MonthlyAverage Ozone andAmmonia Concentrations Concentrations (ppb)**~ ~** **~ A~/~** **~** 

### M**~ ~** **~ ~** **~ -,::O-zo-n-e--------+-2::-;;4~.1-,......-;**  1-T"""":;1:fsTT::::': 44.6 I 46.1 I 52.5 I 52.6 I 50.3 I 45.3 I 35.3 I 27.5 I 24.0 13:-;:0-7. Ammonia 0.90 I 0.93 I 

## i:18l 1.37 

### J 0.99 1 1.24 

### 1 1.08 

### 1 1.06 

### 1 1.35 

### 1 1.29 I 1.58 I 1.16


### CALPOSTPostProcessing The EPA and CENRAP BART guidancerecommends that visibility impacts be evaluated against natural background conditions. Visibility impairment canbe expressed ina number ofdifferent ways; the most

ERM 11 SUNOCOTULSA/0021048-03n NOVEMBER 2006 

### 2.5common and relevantto BART determinations include light extinction, deciviews, and visual range. Light extinction (Bext) is a measure oflight scattered from the line of sight; this is related to visual range by: VR (km) = 3912/Bext (mm-1) 

### e.g. Bext of 20 

### (good visibilihj) corresponds to avisual range of about 200 km; Bext of200 (poor visibilihj), about 20 

### km Deciviews provide a scale where equal changes in the numerical value represent equal changes in perception; deciviews are related to light extinction as follows:

. dv=10*ln(Bext/10) 

### e.g. Bext of20 (good visibilihj) corresponds to adv of6.9; 

### Bextof200 (poor visibility), about 29.2 Light extinction can be calculated from predicted or measured concentrations ofvisibility impairing pollutants

.. The calculation is carried out as follows: Bext = [chi] x [fRH) x [EE]

. 

### where Bext: is the light extinction; chi: is the 24-hr average compound concentration; fRH: is the growthfactor for hygroscopic compounds (e.g. sulfates and nitrates); EE: is the extinction efficiency ofthe compound. Compounds relevantto the 5unoco's evaluation are nitrates (formed from emissions of NOx), sulfates (formed from emissions of502), and PM10 (emitted directly). Total extinction due to source emissions are calculated from the concentrations predicted by CALPUFF, and total extinction due to natural background is calculated from the concentrations identified inTable 2-4 (with a value of 10.0 added to accountfor clear air scattering). The total deciview value correspondingto source plus background is compared to background alone, and the difference is reported as the source impact. If the source impact is less than 0.5 deciviews for all Class I areas over all

ERM 

### 12 SUNOCO**TUL5A/00210~8-0313** NOVEMBER 2006

### 3.0 years modeled, then the source qualifies for anexemptionfrom BART requirements. The CALPOST processor was used to calculate light extinction due to source emissions and due to background, and the resultantchange in deciviews. Parametersrecomni.ended inthe CENRAP modeling guidelines, Appendix D, were used in this analysis with appropriate adjustments madeto the domain settings and to the species modeled.

RESULTSANDDISCUSSION The CALPUFF modelwas run to evaluate the impacts of emissions from BART-eligible sources atthe SunocoTulsa Refinery onvisibility infour Class I areas. The model was runfor three full years (2001-2003) ofcentral domainmeteorology. Two different approaches to the specification of ozone concentrations wereused, with the full set ofmeteorology and Class I areas for each approach. CALPOST was used to calculate the

. maximumchange invisibility due to emissions from Sunoco sources,

expressed as a change in deciviews. A summary ofthe CALPUFF visibility modelingresults is presented inTable 3·1. The results reported inTable 3-1 representthe maximum predicted impact over eachyear atall receptors. The maximumchange in visibility values resultingfrom the emissions of BART eligible sourcesfrom the Sunoco facility is 0.335 deciviews for the year2001 atCaney CreekWilderness. Therefore, the viSibility impacts were less than the threshold of0.5 deciview at all Class I areas within 300 Kilometers from the facility. Itshould be noted thatEPA guidance allows for usingthe 98th percentile prediction (i.e., the 8thhighvalue outof a full year) to evaluate visibility impacts. The CENRAP CALPUFF screeningprocedure, however, calls for comparison of the maximumimpact to the 0.5 deciview threshold. The 98th percentile impactsfrom Sunoco would be substantially lower than shown in Table 3-1. ODEQ notified SunocoTulsa Refinery that some of the sources at the facility mightbe eligible for BART based onthe source categoryto which the refinery belongs, potential emissions of NOx, SOx, and PMfrom the refinery, and the dates onwhich the sources started operating. Based on the dispersion modeling analysis using CALPUFF, the impacts from the BART eligible sources are less than the guideline thresholds

- therefore the Sunoco Tulsa Refinery is exemptfrom further BART evaluation.



### 13 5UNOCO TUL5A/002104S-03 13 NOVEMBER 2006Table 3-1 Summary ofVisibility Impacts from Sunoco Tulsa Refinery BART Eligible Sources Class I Area 2001 2002 2003**Cane~** Creek Wilderness Hercules-Glades Wilderness 0.335 0.128 0.273 0.075 0.139 0.122 UI!l!er Buffalo Wilderness Wichita Mountains Wilderness 0.107 0.139 0.155 0.203 0.210 0.197

Model results are expressed in terms ofthe visibility change from natural background conditions in deciviews. No predicted values exceed the BART threshold of0.5 deciview change

ERM 14 SUNOCO**TUl_~t\/0021048-0313** NOVEMBER 2006