### Page 1 Follow

-up to August 12 Call Regarding Process Heaters
September 10, 2009

Mr. K. C. Hustvedt US EPA Office of Air Quality Planning and Standards Mail Drop E143

-01 Research Triangle Park, NC 27711 Hustvedt.Ken@epamail.epa.gov

Dear Mr. Hustvedt:
On December 22, 2008, in response to petitions for reconsideration submitted by the American Petroleum Institute (API), the National Petrochemical and Refiners Association (NPRA) and the Western States Petroleum Association (WSPA) among others, EPA issued proposed amendments (73 Fed. Reg. 78522) to the New Source Performance Standards (NSPS) for the Petroleum Refinery source category, 40 C.F.R. Part 60 Subparts J and Ja. API, NPRA and WSPA filed comments on the proposed amendments on February 5, 2009 (Docket document EPA

-HQ

-OAR

-2007

-0011

-0311.1) and supplemented those comments on April 8, 2009 (Docket Document EPA

-HQ

-OAR

-2007

-0011

-315.1)

.
On August 12, 2009 we had a conference call with you and other EPA staff to clarify on our concerns relative to meeting the NOx emission limitation proposed for process heaters during turndown operation

. During that call you asked us to provide additional information on process heater turndown. This letter responds to that request.
The following items are attached for your consideration as you complete your process heater NOx considerations.
Attachment 1

– Review of Process Heater Information in the Refinery Consent Decrees.
Attachment 2

– Copy of a Valero NSR permit application for a mass emission limit for turndown operation of two Benecia Refinery process heaters, since approved. (Attached as a separate .pdf file)
Attachment 3

– Data files for a number of process heaters, showing CEM

-measured hourly NOx concentrations (raw and corrected to 0% O2

### ) and associated hourly process heater firing rates. (Attached as separate .xls files)
Attachment 4

– Data files for four process heaters, showing CEM

-measured daily average NOx concentrations (raw and corrected to 0% O2

### ) and associated daily firing rates. (Attached as separate .xls files) Should you have any questions, please contact me. As always, we would be happy to meet with the Agency to clarify any of these items.

### API/NPRA/WSPA Follow

-up to August 12, 2009 Call Page 2

Regards,

Ron Chittim API 202/682

-8176 Chittim@api.org

### API/NPRA/WSPA Follow

-up to August 12, 2009 Call Page 3

cc R. B. Lucas US EPA Office of Air Quality Planning and Standards Mail Drop E143

-01 Research Triangle Park, NC 27711 lucas.bob@epa.gov

Brenda Shine US EPA Office of Air Quality Planning and Standards Mail Drop E143

-01 Research Triangle Park, NC 27711 Shine.Brenda@epa.gov

### API/NPRA/WSPA Follow

-up to August 12, 2009 Call

Page A

- 1 Attachment 1 Analysis of Refinery Consent Decree Process Heater Data

September 3, 2009

Introduction
Many of the Refinery Consent Decrees contain tabulations of combustion sources for each covered site. Where the information was adequate, the process heater information in those tabulations was reviewed and is summarized here. Valero, BP, Shell, Coastal, Koch, Navajo, Montana, Frontier, Holly, Lion, Total, and Wyoming Consent Decrees do not contain adequate detail for inclusion in this analysis.
The tabulations represent the industry in the 1999

-2002 timeframe, depending on when the particular consent decree was finalized. Data from the Consent Decrees of the following companies are summarized in this report. The number of sites covered for each company is shown in parenthesis.
ConocoPhillips (9) Chalmette Refining (1) ExxonMobil (6) Marathon (7) Chevron (5) Sunoco (5) Hunt (2) Ergon (2) Cenex (1) Giant (2) Citgo(3)
With the exception of Marathon and Giant, Consent Decree tabulations did not include information on process heaters with a design firing rate of <40 MMBTU/hr. In a very few cases it was not clear whether a particular combustion source was a process heater or another type of combustion device (e.g., a boiler or an incinerator). If unclear, the combustion device was assumed to be a process heater.
Analysis
A total of 800 process heaters with design firing over 40 MMBTU/hr were identified in the Consent Decrees reviewed. Of these, 378 (47%) had design firings ≥100 MMBTU/hr. 1 

### While the analysis did not quantitatively consider refinery or company size, it is clear qualitatively that smaller and less complex refineries have significantly fewer and smaller process heaters than

1 In 28 cases, multiple process heaters (up to 5, but typically two or three) were identified as sharing an emission point. In those cases, it is assumed the stated design firing for that emission point is equally shared among the process heaters and they were assigned accordingly. In a few cases, firing was indicated to be limited by permit, but that was not considered in this analysis. In general, the permit limit would not have changed the classification of the process heater.

### API/NPRA/WSPA Follow

-up to August 12, 2009 Call

Page A

- 2 larger, more complex refineries. Thirty four of the 800 process heaters were identified as firing both gas and oil, though only one island refinery (Chevron Hawaii) is covered in the data.
For the 36 refineries owned or operated by ConocoPhillips, Chalmette Refining, ExxonMobil, Marathon, Chevron, Citgo and Sunoco, the number of process heaters with design firing ≥40 MMBTU/hr averaged 22.6 per refinery and the number ≥100 MMBTU/hr averaged 10.4. For the 7 refineries owner or operated by Hunt, Cenex, Giant, and Ergon the number of process heaters ≥40 MMBTU/hr averaged 6.9 per refinery and the number ≥100 MMBTU/hr averaged 0.7.
Based on the data for the 7 Marathon sites, the number of process heaters with design firing <40 MMBTU/hr roughly equals the number with design firings ≥100 MMBTU/hr for larger refineries. The data for the two Giant refineries suggests the number of process heaters with design firing <40 MMBTU/hr is four times the number above 40 MMBTU/hr, though the total number of process heaters is still very small compared to larger refineries.

Based on a review of the tabulated operating data for each process heater, it appears that 30% (231 of 776) of the process heaters for which operating data was available operated at <50% of design firing for a year, 56 of those process heaters operated at <25% of design firing for the year and 16 operated at <10% of design firing for a year. The Consent Decrees generally contained operating data for two years and, in general, operating rates appear to track from year to year.
Because the operating data is annual averages, it not only represents process heaters that normally operate at turndown rates, but also process heaters that operate intermittently and process heaters that were shutdown for periods during the year because of commercial considerations or process heater or process unit outages (e.g., turnarounds, malfunctions, etc.), though it would take a long shutdown to significantly impact the annual average firing for a process heater that typically operates at high firings. For this reason, the annual operating data analysis could be significantly overstating the percentage of process heaters that operate at turndown rates.
On the other hand, the annual operating data analysis is likely to be significantly understating the percentage of process heaters that operate at turndown rates for short, but significant periods of time, relative to the 30 day averaging time being discussed for the NOx emission limitation, because such cutbacks would not significantly impact the annual average. For instance, if a process heater were operated at 10% of capacity for one month and 90% the rest of the year, the annual average firing would be 83%. Yet, during this month of turndown operation, the process heater would not be able to meet the same emission limitation that could be met during normal operation. Process heater turndown operation for short periods (e.g., days and weeks) are common due to operating and demand variability, process heater and unit maintenance needs, operations malfunctions, and weather conditions.

### From: "Ron Chittim" <Chittim@api.org>

To: Ken Hustvedt/RTP/USEPA/US@EPA, Bob Lucas/RTP/USEPA/US@EPA, Brenda

Shine/RTP/USEPA/US@EPA Date: 09/10/2009 09:35 AM Subject: 2nd Email

- API/NPRA/WSPA Comments

Here is the 2nd of 4 emails.

Ron Chittim API 202/682

-8176 Chittim@api.org

(See attached file: Attachment 2.pdf)

# *vum.o 

# -Z BENICIA nDNERY
3400 East Second Street • Benicia, California 94510-1005· Telephone (707) 745-7011 • Facsimile (707) 745-7514

October 29, 2007
Bay Area Air Quality Management District 939 Ellis Street San Francisco, CA 94109

Attn: Ms. Thu Bui Air Quality Engineer

Re. NSR Application to Revise Condition 22949 to Include Mass Emission Limits for ULSD Heaters

Dear Ms. Bui:

Valero received an Authority to Construct (ATC) an Ultra Low Sulfur Diesel (ULSD) Unit on March 22, 2006 under Application Number 13009, with equipment subject to Condition Number 22949. The ULSD Unit includes two small process heaters, S-247 Reactor Charge Heater (F-5401) and S-248 Stripper Reboiler Heater (F-5402), which are both equipped with ultra-low NOx burners. Both heaters share a common stack which is monitored with a 

### NOxlCO CEM. The ULSD Unit, which processes a combination of diesel, Coker naphtha, and light cracked slop (LCS), started up on July 16, 2007.

Since startup, preliminary data from the CEM indicate ongoing difficulty in meeting the NOx and CO concentration limits, especially at low firing rates. However, NOx and CO mass emissions have rarely exceeded the equivalent "implicir mass limits, even at high NOx and CO concentration levels.

On October 15, 2007, Valero met with District staff to discuss heater operating performance and the possibility of converting the current BACT concentration limits for NOx and CO to equivalent mass emission limits. Valero believes mass emission limits will ensure compliance and provide operating flexibility especially at low firing rates, while meeting the intent of BACT concentration limits for these small heaters.

Valero will initiate payment of permit application fees upon receipt of the invoice for this application.

Valero plans to conduct the initial performance test and performance evaluation of the 

### NOxlCO CEM in late November in order to submit the test report to the District by December 13, 2007, as required by the ULSD permit. Accordingly, Valero would appreciate expeditious processing of this permit application in order to receive a revised permit with mass emission limits by mid-November.

File: AI-12-02 doc: 20065 AD-2 Condition Change 8247/248 Owned by Valero Refining Company

- CaliforniaIf you have any questions about this application, please contact Mr. Eric Hengst at (707) 745-7385 or myself at (707) 745-7203.
Sincerely,

VALERO REFING COMPANY

- CALIFORNIA

# ~~ Todd Lopez Environmental Manager

cc (w/attachments): Mr. Douglas W. Hall- BAAQMD Mr. Eric Hengst

- Valero

File: AJ-12-02 doc: 20065 AD-2 Condition Change 8247/248

### BAY AREA AIR QUALITY MANAGEMENT DISTRICT 939 Ellis Street, San Francisco, CA 94109 Engineering Division (415) 749-4990 www.baaqmd.gov fax (415) 749-5030 Form P-101B Authority to Constructl

_____ Permit to Operate



# __I ,--

1. Application Information

BAAQMD Plant No. B2626 Company Name Valero Refining Company

- California
EqUipment/Project Description 8-247 and 8-248 UL8D Heaters, Mass Emission Limits



### 2. Plant Information If you have notpreviouslybeen assigned

### a Plant Numberby the District orif you want to update anyplant data thatyou have previouslysupplied to the District, please complete this section.

Equipment Location
City

Mail Address
City State



## --- Zip Code

_

Zip Code

_
Plant Contact
Telephone Fax --'-_...4-

_ Title



# -------------- Email



# --------------- NAIC8 (North American Industry Classification System) see www.census.gov/epcd/naics02/naic0602.htm



### 3. PrOXimity to a School (K-12)

The sources in this permit application (check one) 

## 0 Are 

## I:8J Are not within 1,000 

### ft of the outer boundary of the nearest school. 

### 4. Application Contact Information All co"espondence from the District regarding this application will be sent to the plant contact unless you wish to designate 

### a different contact for this application.

Application Contact

Mail Address Title

_

City State



# ---- Zip Code

_ Telephone Fax --'-(_-1--

_ Email



# -------------- 5. Additional Information The ;ollowing additional information is required for allpermit applications andshouldbe included with yoursubmittal. Failure to provide this information maydelay the review of yourapplication. Please indicate that each item has been addressedbychecking the box. Contact the Engineering Division if you needassistance. 

# D If a new Plant, a local street map showing the location of your business
A facility map, drawn roughly to scale, that locates the equipment and its emission points Completed data form(s) and a pollutant flow diagram for each piece of equipment. (See www.baagmd.gov/pmt/forms/ ) Project/equipment description, manufacturer's data
Discussion and/or calculations of the emissions of air pollutants from the equipment


### 6. Trade Secrets Under the California Public Records Act, all information in yourpermit application will be considered

### a matterof public record and maybe disclosed to 

### a thirdparty. If you wish to keep certain items separate as specifiedin RegUlation 2, Rule 1, Section 202.7, please complete the following steps. 

# D Each page containing trade secret information must be labeled "trade secret" with the trade secret information clearly marked. 

## D A second copy, with trade secret information blanked out, marked "public copy" must be provided. 

# D For each item asserted to be trade secret, you must provide a statement which provides the basis for your claim.

-1-

### 7. Small Business Certification You are entitled to 

### a reducedpermit fee if you qualify as 

### a small business as defined in Regulation 

### 3. In orderto qualify, you must certify thatyourbusiness meets all ofthe following criteria:

D The business does not employ more than 1

# ° persons and its gross annual income does not exceed $600,000.

D And the business is not an affiliate of a non-small business. (Note: a non-small business employs more than 1

# °persons and/or its gross income exceeds $600,000.)


### 8. Accelerated Permitting The Accelerated Permitting Program entitles you to install andoperate qualifying sources ofair pollution and abatement equipment without waiting for the District

### to issue 

### a Permit

### to Operate. To participate in this program you must certify thatyourproject will meetall ofthe following criteria. Please acknowledge each item by checking each box.

D Uncontrolled emissions of any single pollutant are each less than 10 Ib/highest day, or the equipment has been precertified by the BAAQMD.
D Emissions of toxic compounds do not exceed the trigger levels identified in Table 2-5-1 (see Regulation 2, Rule 5).
D The project is not subject to public notice requirements (the source is either more than 1000 ft. from the nearest school, or the
source does not emit any toxic compound in Table 2-5-1).

- D For replacement of abatement equipment, the new equipment must have an equal or greater overall abatement efficiency for all pollutants than the equipment being replaced.
D For alterations of existing sources, for all pollutants the alteration does not result in an increase in emissions.
D Payment of applicable fees (the minimum permit fee to install and operate each source). See RegUlation 3 or contact the Engineering Division for help in determining your fees. 

### 9. CEQA Please answer the following questions pertaining to CEQA (California Environmental QualityAct).

A. Has another public agency prepared, required preparation of, or issued a notice regarding preparation of a California Environmental Quality Act (CECA) document (initial study, negative declaration, environmental impact report, or other CECA document) that analyzes impacts of this project or another project of which it is a part or to which it is related? DYES I8INO If no, go to section 9B.

Describe the document or notice, preparer, and date of document or expected date of completion:



### B. List and describe any other permits or agency approvals required for this project by city, regional, state or federal agencies:

C. List and describe all other prior or current projects for which either of the following statements is true: (1) the project that is the subject of this application could not be undertaken without the project listed below, (2) the project listed below could not be undertaken without the project that is the subject of this application:



### 10. Certification I hereby certify that allinformation contained herein is true 

## Todd Lopez

Name of person certifying (print) 

## Env. Manager

Title of person certifying 

### 10/29/07

Date
Send all application materials to the BAAQMD Engineering Division, 939 Ellis Street, San Francisco, CA 94109.

-2 02/14/06Valero Ultra Low Sulfur Diesel (ULSD) Unit Proposed Mass Limits for S-247 and S-248 Heaters
Background:

Valero received an Authority to Construct (ATC) an Ultra Low Sulfur Diesel (ULSD) Unit on March 22, 2006 under original Application Number 13009, with equipment subject to Condition Number 22949. The ULSD Unit includes two small process heaters, S-247 Reactor Charge Heater (F-5401) and S-248 Stripper Reboiler Heater (F-5402), which are both equipped with the same model of Callidus ultra-low NOx burners. Both heaters share a common stack which is monitored with a 

### NOxlCO CEM. The ULSD Unit processes a combination of diesel, Coker naphtha, and light cracked slop (LCS). Initial startup began
on July 16, 2007, when diesel was introduced into the Unit.

The ULSD Unit is an energy-efficient process unit which is equipped with heat exchangers to increase heat recovery and decrease heater fired duty requirements. Heater duty can vary significantly with the olefin content of the feedstocks. For example, diesel has a low olefin content, whereas Coker naphtha and LCS have high olefin contents.

When olefins are contacted with hydrogen in the ULSD Unit, heat is released in the reactors from the olefin saturation reaction and recovered in feed-effluent heat exchangers, thereby reducing heater fired duty requirements. When Coker naphtha and/or LCS are fed to the Unit during normal operation, heater duty requirements are lower because more olefins are saturated. When the ULSD Unit is feeding primarily diesel, such as during startup or shutdown, heater duty requirements are higher because less olefins are saturated.

Condition 22949 requires that an initial performance test and performance evaluation of the NOxlCO CEM be conducted to demonstrate compliance with the emission limits for NOx, CO, POC, PM 1o, and S02, and to certify the accuracy of the NOxlCO CEM. Originally, Condition 22949 required that the source test be conducted within 60 days of initial startup. However, preliminary operating data from the uncertified CEM indicated potential problems meeting the NOx and CO concentration limits. On September 18,2007 in response to Valero's request, the District modified Condition 22949 to extend the ATC start-up period from 60 days up to 180 days, in order to further evaluate unit performance and conduct the initial source test. Valero plans to conduct the initial source test in late November so that a test report can be submitted by no later than December 13, 2007, as required by Condition 22949 part 14.
Operating Problems:
Preliminary CEM data indicate higher-than-expected NOx and CO concentrations from the heaters. At low fired duties (high turndown), high excess air from incidental firebox leakage results in high NOx levels. In addition, low firebox (bridgewall) temperatures at low fired duties result in high CO levels most likely due to incomplete combustion, in spite of high excess air present. Even at higher fired duties, NOx and CO concentration limits are difficult to meet continually. Since startup on July 16, evaluation of maximum NOx and CO concentrations has been periodically limited due to the initial narrow ranges of the CEM (0-30 ppm for NOx, and 0-80 ppm for CO). On October 2, Valero expanded the CEM ranges for NOx (0-50 ppm) and CO (0-250 ppm) to improve monitoring.

NOx concentrations are also impacted by changes in fuel gas quality from diurnal effects. The Benicia Refinery was designed to conserve water by minimizing cooling water usage and maximizing air fin cooling. However, air fin cooling is impacted more by hot weather and diurnal effects than water cooling. In particular, the efficiency of air fin cooling decreases during the heat of the day, resulting in more heavy material entering the fuel gas system and increasing the heating value of fuel gas. At constant fired duty, fuel gas flow rate decreases as fuel gas heating value increases.

The ULSD heaters are equipped with ultra 10w-NOx burners which are designed for internal flue gas recirculation in the firebox to reduce NOx emissions. When less fuel gas is used in the burners during the heat of the day at higher fuel gas heating values, less internal flue gas recirculation occurs. Accordingly,

File: AI-12-02 doc: 20065 AD-2 Condition Change 8247/248NOx concentrations increase at higher flame temperatures due to less internal flue gas recirculation (mass flow) available to dissipate combustion heat release. Valero has observed variations in NOx concentrations of up to 6 ppm due to diurnal effects, which makes NOx compliance more difficult.
Although an initial source test has not yet been conducted, Valero is also concerned about meeting the POC and PM10 emission factor limits, since these emissions may vary with combustion efficiency similar to CO emissions.

Current Heater Limits:

Condition 22949 includes the following emission and duty limits for S-247 (F-5401) and S-248 (F-5402):



### Condition Description Limit Compliance Method 4 S02 emissions 45 ppmv TRS, 365-day Fuel Gas CEM, rolling average (0.0061 Source test at stack Ibs S02/MMBTU) 

### 8 PM 10 emissions 0.00501bs/MMBTU Source test at stack 

### 8 POC emissions 0.0026 Ibs/MMBTU Source test at stack 11 NOx emissions 17 ppmv at 3% 02 Stack CEM, source (0.0200 Ibs/MMBTU), test at stack 3-hr average 12 CO emissions 50 ppmv at 30/0 02 Stack CEM, source (0.0357 Ibs/MMBTU), test at stack 3-hr average 15 F-5401 fired duty 21.95 MMBTU/HR, 1-hr Fuel gas flow meter maximum 15 F-5402 fired duty 35.10 MMBTU/HR, 1-hr Fuel gas flow meter maximum

In addition to the above "explicit" permit limits, the combinations (products) of emission limits and fired duty limits result in equivalent "implicit" mass emission limits, as follows:

Pollutant Concentration Emission Total Fired Duty "Implicit" Mass Limit, ppmvd 

### @ Factor Limit, Limit, Emission 3% 02 Lbs/MMBTU MMBTU/HR Limit, Lbs/HR NOx 17, 3-hr avg. 0.0200 57.05 1.14, 3-hr avg. 

## CO 50, 3-hr avg. 0.0357 57.05 2.04, 3-hr avg. PM 10 0.0050 57.05 0.29 POC 0.0026 57.05 0.15 S02 0.0061 57.05 0.35
Proposed Mass Limits

Since initial startup on July 16, 2007, operating data from the uncertified CEM indicate difficulty in continually meeting the NOxlCO concentration limits. NOxlCO concentrations are especially high at low firing rates, when high olefin Coker naphtha and LCS are fed to the unit and exchanger heat recovery is maximized to reduce heater fired duty. In spite of high NOx and CO concentrations, NOx and CO mass emissions have rarely exceeded the equivalent "implicit" mass emission limits.

To ensure comgUance and provide operating flexibility for the new heaters especially at (normal) low firing rates, Valero proposes to convert the concentration limits for NOx and CO, and the emission factor limits for PM 10 and 

## poe, to equivalent mass emission limits. Valero does not propose any changes to the permit condition for S02 emissions, based on the TRS concentration in refinery fuel gas.

File: AI-12-02 doc: 20065 AD-2 Condition Change 5247/248

### NOx and CO mass emissions can be calculated from total fired duty, F d 

### factor for refinery fuel gas (D8CF flue gas/MMBTU), and CEM data. In addition, POC and PM 10 

### mass emissions can be calculated from total fired duty and emission factors.

The current concentration limits for NOx and CO are based on a rolling average over any 3 consecutive hours. Valero proposes an equivalent NOx mass emission limit of 1.14 Ibs/hour (based on 17 ppmvd at 3% 02), averaged over any 3 consecutive hours.

Due to: (1) the variability in CO levels from attempting to meet the NOx limit as first priority, (2) the uncertainty in measuring maximum CO levels until the CEM for NOx and CO was re-ranged on October 2, and (3) the inherently more volatile nature of CO concentrations, Valero proposes the following two options for a CO mass emission limit:
Option 1: 2.04 Ibs/hour (based on 50 ppmvd at 3% 02), averaged over any 8 consecutive hours; or Option 2: 3.06 Ibs/hour (based on 75 ppmvd at 3% 02), averaged over any 3 consecutive hours.


### Option 1 (CO 

### mass limit based on 50ppmv 8-houraverage, andmass limits for POC 

### andPM 10

):



### Since CO concentrations and mass emissions vary more than NOx, Valero proposes to increase the averaging period for CO mass emissions from 3 hours to 8 hours, if the underlying CO concentration limit is maintained at 50 ppmv. In the past, the District has issued BACT permits to Valero with CO limits based on averaging periods of 8 hours. For example, Condition 20820 part 12 of the VIP permit includes
a CO limit for a new process heater (8-1046) with an averaging period of 8 hours. For reference, the UL8D Unit is part of the VIP. In addition, Condition 16027 part 13 for a new boiler (S-237) includes a CO limit with an averaging period of 8 hours.

In summary, the proposed mass emission limits for Option 1 include:

Pollutant Mass Basis for Mass Emission Emission Limit Limit, Lbs/Hr NOx 1.14, 3-hr aVQ. 17 ppmv (ii) 

### 3% 02 CO 2.04, 8-hr avg. 50 ppmv @ 

### 3% 02 PM 10 

### 0.29 0.0050 Ibs/MMBTU 

## poe 0.15 0.0026 ibsiMMBTU 802 N/A N/A

Since mass emissions do not change for Option 1, a BACT analysis and emission offsets are not required.
Proposed revisions to Condition 22949 for Option 1 include:

4. The Owner/Operator shall fire refinery low-pressure fuel gas in 8-247 and 8-248 heaters at a concentration at or below 45 ppmv of total reduced sulfur (TRS), averaged over any rolling consecutive 365 day period. (equivalent to 0.00610 Ib 802/MMBtu fuel gas). [Basis: BACT, Cumulative Increase] [No change. Included for completeness only.)



### 8. Total combined combustion emissions from 5-247 and 5-248 shall not exceed the following annual limits in any calendar year: [Basis: Cumulative Increase, Offsets]

Pollutant Annual (tons) NOx 5.00 CO 8.92 802 1.52 PM10 1.25 POC 0.65

File: AI-12-02 doc: 20065 AD-2 Condition Change 5247/248a. The Owner/Operator shall determine annual emissions using fuel consumption, fuel heating value, continuous emission monitor (CEM) data for TRS, NOx and CO, and the following emission factors for PM10 and POC [Basis: Monitoring] PM10: 0.0050 Ibs/MMBTU POC: 0.0026 Ibs/MMBTU

b. The Owner/Operator shall submit an annual report to the Compliance and Enforcement Division and Permit Services Division no later than 45 days following the end of each calendar year. The report shall include the actual daily emissions based on CEM data for NOx and CO, the actual daily emissions of SOx based on the CEM data for TRS, and the estimated daily emissions of PM10 and POC based on the above emission factors. Also, the report shall include the annual totals of each pollutant to demonstrate compliance with the above limits. The report shall also include the total daily heat input for S-247 and S-248 heaters and the total daily fuel consumption at S-247 and S-248. [Basis: Reporting Requirements]

11. Except during periods of startup and shutdown, the Owner/Operator shall maintain combined emissions of nitrogen oxides in the common stack of S-247 and S-248 Furnaces at or below 17 ppmv,-€lf.y,€0rrectedto 3% oxygen 

### (0.0200 Ib/MM-B-tH)1.14 Ibs/hr, averaged over any 3 consecutive hours. [Basis: BACT]

12. Except during periods of startup and shutdown, the Owner/Operator shall maintain combined emissions of CO in the common stack of S-247 and S-248 Furnaces at or**below-eG-wmv-,--€lf.y,GBfFe€-ted-t&-3-%-&~-Q.3.&7-.J.lliMM-B-kl-t2.** 04, averaged over**3~** hours. [Basis: BACT]

13. Except during periods of startup and shutdown, the Owner/Operator shall maintain combined mass emissions of PM10 and POC in the common stack of 8-247 and 8-248 Furnaces at or below: PM10: 0.29 Ibs/hr POC: 0.15 Ibs/hr [Basis: Monitoring]**1-3-:-~For** S-247 and S-248, the Owner/Operator shall install, calibrate, maintain, and operate District=approved continuous emission monitors and recorders for NOx, CO and 02 on the common stack. [Basis: CEM Monitoring]**l+~** The startup period for this Authority to Construct has been extended up to 180 days until January 12, 2008. No later than 150 days from the startup of S-247 and S-248, the Owner/Operator shall submit to the District all approved source tests on the common stack to determine initial compliance with the limits in parts 11 and 12 for NOx and CO, the limits in part 

## gH for PM10 and POC, and the limit in part 4 for S02. Thus, all source test results must be submitted to the District by December 13, 2007. The Owner/Operator shall conduct the source test in accordance with part-l61L [Basis: Compliance determination via source tests]



### 16;1Z The Owner/Operator shall obtain approval for all source test procedures from the District's Source Test Section prior to conducting any tests. The Owner/Operator shall comply with all applicable testing requirements for continuous emissions monitors as specified in Volume V of the District's Manual of Procedures. The Owner/Operator shall notify the District's Source Test Section, in writing, of the source test protocols and projected test dates at least 7 days prior to testing. [Basis: Source test compliance verification and accuracy] [No change. Included for completeness only.]

The Owner/Operator shall conduct a source test every five years to demonstrate subsequent compliance with the POC and PM10 mass rates specified in part 

## BaH. The

File: AI-12-02 doc: 20065 AD-2 Condition Change 5247/248Owner/Operator shall conduct the source test in accordance with part 

### +ej1. The Owner/Operator shall submit the source test results to District staff no later than 60 days after the source test. [Basis: Periodic Monitoring, Title V Compliance Verification]


### option 2 

### (CO mass limit based

### on 75 

### ppmv3-houraverage, andmass limits for

## poe andPM1

### o):

5ince CO concentrations and mass emissions vary more than NOx, Valero proposes to increase the CO
mass emission limit by 50% to 3.06 Ibs/hr based on a CO concentration of 75 ppmvd, if the averaging period is maintained at 3 hours.

In summary, the proposed mass emission limits for Option 2 include:

Pollutant Mass Basis for Mass Emission Emission Limit Limit, Lbs/Hr NOx 1.14, 3-hr aVQ. 17 ppmv 3% 02 CO 3.06, 3-hr avg. 75 ppmv @ 3% 02 PM 10 0.29 0.0050 Ibs/MMBTU POC 0.15 0.0026 Ibs/MMBTU 502 N/A N/A

A BACT analysis is required for CO, since the proposed increase in CO emissions for Option 2 is greater than 10 Ibs per highest day (increase is 24.5 Ibs/day

# = 4.46 tons/year), as follows:

Pollutant Current "Implicit" Proposed Mass Increased Mass Increased Mass Mass Limit, Ibs/hr Limit, Ibs/hr Emissions, Ibs/hr Emissions, Ibs/day CO 2.04 3.06 1.02 24.5

Based on the UL5D evaluation report for AN 13009 dated 3/15/05, BACT 1 for CO has not been determined for a natural draft heater. Based on the District's BACT Guidelines for (water tube) boilers in the range of 5-33.5 MMBTU/HR (5-247 

# = 21.95 MMBTU/HR) and 33.5-50 MMBTU/HR (8-248 

# = 35.10 MMBTU/HR) heat input, BACT 2 for CO is 100 ppmvd 

### @ 3% 02 based on good combustion practices. Therefore, Valero believes that a CO mass emissions limit of 3.06 Ibs/hr based on a CO concentration of 75 ppmvd 

### @ 3% 02 is reasonable and consistent with BACT Guidelines.

Offsets are not required for increased CO emissions. For reference, in 1003 Valero shut down two large package boilers (8-38 and 8-39) as required by AN 2488, part 47 for Cogen Phase I, which net reduced refinery CO emissions by about 65 tons/year and mitigates any increased CO emissions from the ULSD heaters.
Proposed revisions to Condition 22949 for Option 2 include:

4. The Owner/Operator shall fire refinery low-pressure fuel gas in 5-247 and 5-248 heaters at a concentration at or below 45 ppmv of total reduced sulfur (TR8), averaged over any rolling consecutive 365 day period. (equivalent to 0.00610 Ib 502/MMBtu fuel gas). [Basis: BACT, Cumulative Increase] [No change. Included for completeness only.]



### 8. Total combined combustion emissions from 8-247 and 5-248 shall not exceed the following annual limits in any calendar year: [Basis: Cumulative Increase, Offsets]

Pollutant Annual (tons) NOx 5.00 CO &9213.38 502 1.52 PM10 1.25

File: AI-12-02 doc: 20065 AD-2 Condition Change 5247/248POC 0.65

a. The Owner/Operator shall determine annual emissions using fuel consumption, fuel heating value, continuous emission monitor (CEM) data for TRS, NOx and CO, and the following emission factors for PM10, and POC [Basis: Monitoring] PM10: 0.0050 Ibs/MMBTU POC: 0.0026 Ibs/MMBTU

b. The Owner/Operator shall submit an annual report to the Compliance and Enforcement Division and Permit Services Division no later than 45 days following the end of each calendar year. The report shall include the actual daily emissions based on CEM data for NOx and CO, the actual daily emissions of SOx based on the CEM data for TRS, and the estimated daily emissions of PM10 and POC based on the above emission factors. Also, the report shall include the annual totals of each pollutant to demonstrate compliance with the above limits. The report shall also include the total daily heat input for S-247 and S-248 heaters and the total daily fuel consumption at S-247 and S-248. [Basis: Reporting Requirements]

11. Except during periods of startup and shutdown, the Owner/Operator shall maintain combined emissions of nitrogen oxides in the common stack of S-247 and S-248 Furnaces at or**below-++-wm-v.d-ry,-€Offfi€te4-~~fb/MM** Btu )1.14 Ibs/hr, averaged over any 3 consecutive hours. [Basis: BACT]

12. Except during periods of startup and shutdown, the Owner/Operator shall maintain combined emissions of CO in the common stack of S-247 and S-248 Furnaces at or below 50 ppmv, ci-f:y,B**~3.06,** averaged over 3 hours. [Basis: BACT]

13. Except during periods of startup and shutdown, the Owner/Operator shall maintain combined mass emissions of PM1 0 and POC in the common stack of 8-247 and 8-248 Furnaces at or below: PM10: 0.29 Ibs/hr POC: 0.15 Ibs/hr [Basis: Monitoring]



### 13: 14. For S-247 and S-248, the Owner/Operator shall install, calibrate, maintain, and operate District-approved continuous emission monitors and recorders for NOx, CO and 02 on the common stack. [Basis: CEM Monitoring]

14;15. The startup period for this Authority to Construct has been extended up to 180 days until January 12, 2008. No later than 150 days from the startup of S-247 and S-248, the Owner/Operator shall submit to the District all approved source tests on the common stack to determine initial compliance with the limits in parts 11 and 12 for NOx and CO, the limits in part 81J for PM10 and POC, and the limit in part 4 for S02. Thus, all source test results must be submitted to the District by December 13,2007. The Owner/Operator shall conduct the source test in accordance with part·-161L [Basis: Compliance determination via source tests]

Hh

## lL..-The Owner/Operator shall obtain approval for all source test procedures from the District's Source Test Section prior to conducting any tests. The Owner/Operator shall comply with all applicable testing requirements for continuous emissions monitors as specified in Volume V of the District's Manual of Procedures. The Owner/Operator shall notify the District's Source Test Section, in writing, of the source test protocols and projected test dates at least 7 days prior to testing. [Basis: Source test compliance verification and accuracy] 

### [No change. Included forcompleteness only.]

File: AI-12-02 doc: 20065 AD-2 Condition Change 8247/248

### l7-:.11L-The Owner/Operator shall conduct a source test every five years to demonstrate subsequent compliance with the POC and PM10 mass rates specified in part 8a13. 

### The Owner/Operator shall conduct the source test in accordance with part 4-61Z. The Owner/Operator shall submit the source test results to District staff no later than 60 days after the source test. [Basis: Periodic Monitoring, Title V Compliance Verification]

File: AI-12-02 doc: 20065 AD-2 Condition Change 5247/248

### From: "Ron Chittim" <Chittim@api.org>

To: Ken Hustvedt/RTP/USEPA/US@EPA, Bob Lucas/RTP/USEPA/US@EPA, Brenda

Shine/RTP/USEPA/US@EPA Date: 09/10/2009 09:38 AM Subject: 3rd email: API/NPRA/WSPA Information

This is the 3rd of 4 emails

. Ron Chittim API 202/682

-8176 Chittim@api.org

(See attached file: Heater Data Refinery 1.xls) (See attached file: Heater Data Refinery 2.xls) (See attached file: Heater Data Refinery 3.xls) (See attached file: Heater Data Refinery 4.xls) (See attached file: Heater Data Refinery 5.xls) (See attached file: Heater Data Refinery 6.xls) (See attached file: Heater Data Refinery 7.xls)

### From: "Ron Chittim" <Chittim@api.org>

To: Ken Hustvedt/RTP/USEPA/US@EPA, Bob Lucas/RTP/USEPA/US@EPA, Brenda

Shine/RTP/USEPA/US@EPA Date: 09/10/2009 09:39 AM Subject: 4th Email: API/NPRA/WSPA Information

This is the 4th 

### of 4 emails

. Ron Chittim API 202/682

-8176 Chittim@api.org

(See attached file: PH 1.xls) (See attached file: PH 2 Regeneration.xls) (See attached file: PH 2.xls) (See attached file: PH 3 Regeneration.xls) (See attached file: PH 3.xls) (See attached file: PH 4.xls)