1 12/20/13

CITY OF PHILADELPHIA

Department of Public Health

Public Health Services

Air Management Services

Statement of Basis

To: File

From: Edward Wiener, Chief of Source Registration

Date: 12/20/13

Subject: Modification of RACT Plan Approval and SIP in Conjunction with Plan 

Approval No. 12195 – Philadelphia Energy Solutions Refining and 

Marketing LLC (PES)

Company Information:

Philadelphia Energy Solutions Refining and Marketing LLC (PES) owns and operates a

petroleum refinery at 3144 Passyunk Avenue, Philadelphia, PA 19145. The refinery was 

previously owned by Sunoco, Inc. (R&M). 

Project Description:

PES has submitted Plan Approval Application No. 12195 which will modify the 

Reasonably Available Control Technology (RACT) plan approval issued to the facility 

on August 1, 2000 and the State Implementation Plan (SIP):

• Unit 231 B101 Heater (rated capacity 104.5 MMBTU/hr)

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

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

• Unit 210 H101 Heater (rated capacity 192.0 MMBTU/hr)

• Unit 210 H201A/B Heater (rated capacity 254.0 MMBTU/hr)

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

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

The application proposes replacing the MMBTU per hour heat input limit with a 

MMBTU per rolling 365-day period heat input limit for each heater. The application 

includes the installation of ultra-low NOx burners (ULNB) on the Unit 231 B101 Heater 

and the Unit 865 11H1 Heater. 

The increases do not require any physical modifications to the heaters. The MMBTU/hr

heat input limits originally came from the Reasonably Available Control Technology 

(RACT) plan approval issued to the facility on August 1, 2000. The rolling 365-day

limits were used in the case-by-case RACT evaluations in Attachment A of the 

September 2013 application. Each heater burns refinery fuel gas.
2 12/20/13

Case-by-Case RACT

Section 182(b)(2) and (f) of the CAA requires that moderate (or worse) ozone 

nonattainment areas implement reasonably available control technology (RACT) controls 

on all major sources of VOC and NOx. RACT has been defined as the lowest emission 

limit that a particular source is capable of meeting by the application of the control 

technology that is reasonably available considering technological and economic 

feasibility. EPA requires that states meet the CAA RACT requirements for the 1997 8-

hour ozone national ambient air quality standard (NAAQS), either through a certification 

that previously adopted RACT controls in their SIP approved by EPA under the 1-hour 

ozone NAAQS continue to represent adequate RACT control levels for 8-hour ozone 

NAAQS attainment purposes, or through the adoption of new or more stringent 

requirements that represent RACT control levels.

Philadelphia County was designated under the 1-hour ozone NAAQS as part of the 

Philadelphia-Wilmington-Trenton severe ozone nonattainment area and under the 1997 

8-hour ozone NAAQS as part of the Philadelphia-Wilmington-Atlantic City moderate 

ozone nonattainment area. See 56 FR 56694, at 56822 (November 6, 1991) and 69 FR 

23858, at 23931 (April 30, 2004). PES (formerly Sunoco) has facility-wide potential 

emissions of over 100 tons per year for NOx and over 50 tons per year for VOC, making 

it as a major source of both pollutants. AMS submitted a case-by-case RACT 

determination for PES for the 1-hour ozone NAAQS, and EPA approved this RACT 

determination into the Pennsylvania SIP on October 31, 2001. See 66 FR 54942. The 1-

hour ozone RACT determination included NOx controls for various emissions sources in 

the refinery that were not subject to other RACT regulations in the Pennsylvania SIP, as 

required under Pa. Code 129.91 – 92.

Since PES has requested to modify heat input limits and NOx emissions rates for 7 

heaters previously included in SIP-approved 1-hour RACT determination, AMS is hereby 

providing an updated RACT determination for NOx controls on these heaters. AMS is 

requesting EPA to approve these changes to the previously approved RACT 

determination as a revision to the Pennsylvania SIP in order to meet the CAA RACT 

requirements for PES (formerly Sunoco) under the 1997-8-hour ozone NAAQS. The new 

RACT determination will result in the adoption of more stringent NOx controls and 

emissions rates than the ones currently approved in the SIP as RACT for the 1-hour 

ozone NAAQS. Thus, this SIP revision will not interfere with any applicable 

requirement concerning attainment of the 1997 8-hour ozone standard in Philadelphia 

County or reasonable further progress or any other applicable requirement of the CAA

Case-by-Case RACT Analysis for NOx

Attachment A of the September 2013 plan approval application includes a full case-bycase RACT analysis for the heaters. AMS accepted this analysis, which is being 

incorporated by reference. 
3 12/20/13

The following control options are available, including estimated NOx reduction:

• Ultra Low NOx Burners (ULNBs) and Selective Catalytic Reduction (SCR) –

96%

• SCR – 85%

• ULNBs – 66-76%

• Low NOx Burners (LNBs) and Selective Non-Catalytic Reduction (SNCR) – 70%

• LNBs and Flue Gas Recirculation (FGR) – 55%

• SNCR – 40%

SCR was determined technologically infeasible for the 865 Heater 11H1 and the 210

Heater H201 because it would not physically fit the plot space and there is not adequate 

pressure to overcome the SCR pressure drop. FGR was determined technologically 

infeasible for the 865 Heater 11H1 and the Unit 210 Heater H201 because it would 

require the installation of mechanical draft burners, a major re-design of the units. FGR 

was determined technologically infeasible for the Unit 210 Heater H101 because it would 

not physically fit the plot space. 

The table below summarizes the cost per ton of NOx controlled for each control option. 

Since the Unit 210 H201A/B Heater already has ULNBs and the Unit 231 B101 Heater 

and the Unit 865 11H1 Heater are proposed to have ULNBs installed, only control 

options that are more efficient than ULNBs were evaluated for these heaters. For these 

heaters, SCR and SNCR were evaluated based on the units having ULNBs in place (NOx 

reductions achieved adding SCR or SNCR to a heater already achieving a 0.03 lbs 

NOx/MMBTU emission rate). 

Source Control Device Options ($ per ton NOx controlled)

ULNB & 

SCR

LNB & 

SNCR

SCR ULNB SNCR LNB & FGR

210 Heater 

H101

30,796 57,667 27,397 9,477 10,825 Tech. 

infeasible

210 Heater 

H201A/B

Has 

ULNB, 

SCR Tech. 

infeasible

162,271 Tech. 

infeasible

Installed 28,098

(after 

ULNB)

Tech. 

infeasible

865 Heater 

11H1

Installing 

ULNB, 

SCR Tech. 

infeasible

Less 

effective 

than 

ULNB

Tech. 

infeasible

Installing 42,874

(after 

ULNB)

Tech. 

infeasible/Less 

effective than 

ULNB

865 Heater 

11H2

34,287 11,045 32,909 6,737 13,132 8,704
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866 12H1 

Heater

34,831 11,331 33,524 6,737 13,379 8,960

868 8H101 

Heater

35,060 14,513 33,782 6,737 13,482 12,965

231 Heater 

B101

Installing 

ULNB

Less 

effective 

than 

ULNB

102,243

(after 

ULNB)

Installing 39,924

(after 

ULNB)

Less effective 

than ULNB

While some of these heaters were able to burn fuel oil in the original RACT plan 

approval, this is no longer allowed. Each heater can only burn refinery fuel gas. 

 

Under the new capacities and control efficiencies, AMS has determined adding new NOx 

control technologies would be either technologically infeasible or economically 

unreasonable for the heaters. The existing ULNBs were determined RACT for the 210 

Heater H201. The installation of ULNBs was determined RACT for the 231 Heater

B101 and the 865 Heater 11H1. Combustion tuning was determined RACT for the other 

heaters.

AMS had determined RACT to be the following:

• Unit 231 B101 Heater – Installation of ULNBs

• Unit 865 11H1 Heater – Installation of ULNBs

• Unit 865 11H2 Heater – Combustion Tuning

• Unit 210 H101 Heater – Combustion Tuning

• Unit 210 H201A/B Heater – Existing ULNBs

• Unit 866 12H1 Heater – Combustion Tuning

• Unit 868 8H101 Heater – Combustion Tuning

Additionally, the lbs/MMBTU NOx emission rates and MMBTU/rolling 365-day period 

heat input levels used in the case-by-case RACT analysis will become RACT limits for 

the heaters. The analysis was based solely on the burning of refinery fuel gas, so the 

ability to burn fuel oil will be removed. 

Initial performance tests are required to determine compliance with the lbs/MMBTU 

NOx emission limits for all heaters except for the Unit 210 Heater H201A/B, which is 

required to have a NOx Continuous Emissions Monitoring System (CEMS). 

The tables below show the effect of the proposed changes on potential NOx emissions for 

each heater in both pounds per hour and tons per year. 
5 12/20/13

Current RACT 

Firing Limit 

(MMBTU/hr)1

Existing 

Annual Firing 

Limit 

(MMBTU/yr)2

Current RACT 

NOx Emission 

Limit 

(lbs/MMBTU)3

Current 

RACT 

Hourly 

NOx PTE 

(lbs/hr)4

Current 

RACT 

Annual 

NOx PTE 

(tons/yr)5

231 B101 Heater 91.0 797160 0.122 11.10 48.63

865 11H1 Heater 72.2 632472 0.4 28.88 126.49

865 11H2 Heater 49.9 437124 0.4 19.96 87.42

210 H101 Heater 183.0 1603080 0.4 73.20 320.62

210 H201 Heater 242.0 2119920 0.4 96.80 423.98

866 12H1 Heater 43.0 376680 0.4 17.20 75.34

868 8H101 Heater 47.9 419779 0.113 5.41 23.72

Total 252.56 1106.20

Rated 

Capacity 

(MMBTU/hr)6

Proposed 

RACT Annual 

Firing Limit 

(MMBTU/yr)7

Proposed 

RACT NOx

Emission Limit 

(lbs/MMBTU)8

Proposed 

RACT 

Hourly 

NOx PTE 

(lbs/hr)9

Proposed 

RACT 

Annual 

NOx PTE 

(tons/yr)10

231 B101 Heater 104.5 915420 0.03 3.14 13.73

865 11H1 Heater 87.3 764748 0.03 2.62 11.47

865 11H2 Heater 64.2 562392 0.113 7.25 31.78

210 H101 Heater 192.0 1681920 0.089 17.09 74.85

210 H201 Heater 254.0 2225040 0.03 7.62 33.38

866 12H1 Heater 61.2 536112 0.113 6.92 30.29

868 8H101 Heater 60.0 525600 0.113 6.78 29.70

Total 51.41 225.19

Net Change -201.14 -881.01

Footnotes in Tables:

1

Limit in current RACT Plan Approval.

2

Operation at current RACT hourly heat input limit for 8,760 hrs/yr.
6 12/20/13

3

Limit in current RACT Plan Approval. Assumes the worst-case fuel allowed in the 

current RACT Plan Approval. For heaters without a lbs NOx/MMBTU limit in the 

current RACT Plan Approval, 0.4 lbs NOx/MMBTU was used if they can burn oil in the 

current RACT Plan Approval (865 11H2 and 866 12H1 Heaters), 0.113 lbs 

NOx/MMBTU was used if they can only burn gas (868 8H101 Heater).

4

Current RACT Firing Limit multiplied by Current RACT NOx Emission Limit 

5

Proposed RACT Annual Firing Limit multiplied by Current RACT NOx Emission Limit 

6

Physical rated capacity, not a permit limit.

7

Operation at Rated Capacity for 8,760 hrs/yr. These annual firing rates were used in the 

case-by-case RACT economic analysis for the different control device options. 

8

Proposed limits for refinery fuel gas burning. Some limits are modifications to existing 

limits or new limits for heaters that do not have them in the existing RACT Plan 

Approval. The proposed revisions to the RACT Plan Approval do not allow oil burning 

for any of these heaters.

9

Rated Capacity multiplied by Proposed RACT NOx Emission Limit 

10Proposed RACT Annual Firing Limit multiplied by Proposed RACT NOx Emission 

Limit

The proposed changes will results in an overall reduction in the allowable NOx emissions 

from these heaters both on an hourly basis and a potential basis. As a result, they are not 

a relaxation of the current RACT limits (actually more stringent).

RACT/SIP Modifications

The following heat input limits are being removed from Sections 1.A and 2.C of the 

RACT Plan Approval:

• Unit 231 B101 Heater (91 MMBTU/hr)

• Unit 865 11H1 Heater (72.2 MMBTU/hr)

• Unit 865 11H2 Heater (49.9 MMBTU/hr)

• Unit 210 H101 Heater (183 MMBTU/hr)

• Unit 210 H201A/B Heater (242 MMBTU/hr)

• Unit 866 12H1 Heater from (43 MMBTU/hr)

• Unit 868 8H101 Heater from (49.5 MMBTU/hr)

The following rolling 365-day heat input limits are being added to Section 4.H as a 

replacement: 
7 12/20/13

• Unit 231 B101 Heater shall not exceed 915,420 MMBTU on a rolling 365-

day basis.

• Unit 865 11H1 Heater shall not exceed 764,748 MMBTU on a rolling 365-

day basis.

• Unit 865 11H2 Heater shall not exceed 562,392 MMBTU on a rolling 365-

day basis.

• Unit 210 H101 Heater shall not exceed 1,681,920 MMBTU on a rolling 

365-day basis.

• Unit 210 H201A/B Heater shall not exceed 2,225,040 MMBTU on a rolling 

365-day basis.

• Unit 866 12H1 Heater shall not exceed 536,112 MMBTU on a rolling 365-

day basis.

• Unit 868 8H101 Heater shall not exceed 525,600 MMBTU on a rolling 365-day 

basis

Note: These rolling 365-day heat input limits are less stringent than the limits in Plan 

Approval No. 12195, which are based on the projected actual emissions calculations used 

in that application.

The following Nitrogen Oxides (NOx) emission limits for gas burning are being added or 

modified in Section 4.B and 4.C: 

• 0.03 lbs/MMBTU for Unit 231 B101 Heater

• 0.03 lbs/MMBTU for Unit 865 11H1 Heater

• 0.113 lbs/MMBTU for Unit 865 11H2 Heater

• 0.03 lbs/MMBTU for Unit 210 H201A/B 

• 0.113 lbs/MMBTU for Unit 866 12H1 Heater 

• 0.113 lbs/MMBTU for Unit 868 8H101 Heater 

Note: 0.089 lbs/MMBTU remains the limit for Unit 210 H101 Heater 

The ability to burn refinery fuel oil is being removed from Section 1.A of the RACT Plan 

Approval for the following heaters (the other heaters did not have the capability in the 

RACT plan approval):

• Unit 865 11H1 Heater 

• Unit 865 11H2 Heater 

• Unit 210 H101 Heater 

• Unit 210 H201A/B Heater

• Unit 866 12H1 Heater 

Emission limits of 0.4 lbs NOx/MMBTU are being removed from Section 4.C of 

the RACT Plan Approval for the following heaters:
8 12/20/13

• Unit 210 H101 Heater 

• Unit 210 H201A/B Heater

The installation of ULNBs on 210 H201A/B Heater has been added as an existing RACT 

control in Section 4.B. ULNBs were added to this heater as part of a past plan approval.

The installation of ULNBs on 231 B101 Heater and 865 11H1 Heater within 18 months

of the amendment of this plan approval is being added as a RACT requirement in Section 

4.B. The heaters must comply with their existing MMBTU/hr heat input limits until the 

ULNBs are installed. The heaters do not need to comply with their new 0.03 

lbs/MMBTU NOx emission limits until after the ULNBs have been installed.