1 

CITY OF PHILADELPHIA 

Department of Public Health 

Public Health Services 

Air Management Services 

InterOffice Memo 

To: File 

From: Edward Wiener, Chief of Source Registration 

Date: October 30, 2015 

Subject: 1997 8-Hour RACT Analysis for Philadelphia Energy Solutions Refining 

and Marketing LLC (PES) 

I. Introduction: 

The Clean Air Act (CAA) requires that moderate (or worse) ozone nonattainment areas implement 

reasonably available control technology (RACT) controls on all major sources of Volatile Organic 

Compounds (VOC) and Nitrogen Oxides (NOx). Philadelphia County is part of the PhiladelphiaWilmington-Atlantic City moderate ozone nonattainment area for the 1997 8-hour ozone NAAQS. 

This document presents the findings of a RACT evaluation for the 1997 8-hour ozone standard for 

this facility.

II. 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). PES – Tank Farm is part of the main refinery, although it has a different AMS 

Plant ID and Title V operating permit, however it is included in this RACT determination. 

III. Applicability for NOx and VOC RACT: 

PES is a major source of NOx having potential NOx emissions greater than 100 tons per year, the 

major source threshold in Philadelphia County that is applicable to NOx RACT for the 1997 8-hour 

ozone NAAQS. 

PES is a major source of VOC having potential VOC emissions greater than 50 tons per year, the 

major source threshold in Philadelphia County that is applicable to VOC RACT for the 1997 8-hour 

ozone NAAQS. 

IV. 1-hour RACT: 

PES is subject to the 1-hour RACT determination (PA Permit Numbers 51-1501 and 51-1517) dated 

August 1, 2000, and approved into the SIP by EPA on October 31, 2001, 66 FR 54942 under the 

facility’s former name Sunoco Inc. (R&M) – Philadelphia. This RACT determination includes both 

PES Refinery (Plant ID 01501, PA Permit Number 51-1501) and PES – Tank Farm (Plant ID 01517, 

PA Permit Number 51-1517). 
2 10/30/15

 

V. Process Descriptions: 

PES’ emission sources include 27 refinery fuel gas-fired process heaters, 3 refinery fuel gas-fired 

boilers, 2 Fluid Catalytic Cracking Units (FCCUs), 5 diesel-fired non-emergency reciprocating 

internal combustion engines (RICE), 11 emergency generators and fire pumps, storage tanks, 

cooling towers, 2 loading operations, oil-water separators, and degreasers. More details about these 

processes can be found below. 

Table 1 - NOx Sources 

Location Source Permitted 

Capacity 

(MMBTU/hr 

unless noted) 

NOx Emission 

Rate 

(lbs/MMBTU) 

Reference Potential NOx 

Emissions 

(TPY) 

Point Breeze Unit 210-13H1 235.4 0.104 1-hour RACT 107.2

Point Breeze Unit 860-2H2 69.8 0.350 1-hour RACT 107.0

Point Breeze Unit 860-2H3 174.7 0.163 1-hour RACT 124.7

Point Breeze Unit 860-2H4 99.4 0.270 1-hour RACT 117.6

Point Breeze Unit 860-2H5 155 0.163 1-hour RACT 110.7

Point Breeze Unit 860-2H7 59 0.157 1-hour RACT 40.6

Point Breeze Unit 860-2H8 49.6 0.113 AP-42 24.5

Point Breeze Unit 864-PH1 80 0.167 1-hour RACT 58.5

Point Breeze Unit 864-PH7 45.5 0.113 AP-42 22.5

Point Breeze Unit 864-PH11 74 0.145 1-hour RACT 47.0

Point Breeze Unit 864-PH12 85.1 0.119 1-hour RACT 44.4

Point Breeze Unit 870-H01 97 0.035 PA 02184 14.9

Point Breeze Unit 870-H02 53 0.035 PA 02184 8.1

Point Breeze Unit 859-1H1 98 0.02 PA 06144 8.6

Girard Point Unit 137 F-1 415 0.23 1-hour RACT 418.1

Girard Point Unit 137 F-2 155 0.257 1-hour RACT 174.5

Girard Point Unit 137 F-3 60 0.06 PA 07163 15.8

Girard Point Unit 1332 H-1 45 0.113 AP-42 22.3

Girard Point Unit 1332 H-2 60 0.04 PA 05124 10.5

Girard Point Unit 1332 H-3 43 0.113 AP-42 21.3

Girard Point Unit 1332 H-400 186 0.06 PA 09040 48.9

Girard Point Unit 1332 H-401 233 0.06 PA 09040 61.2

Girard Point Unit 1332 H-601 48 0.113 AP-42 23.8

Girard Point Unit 1332 H-602 49 0.113 AP-42 24.3
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Girard Point Unit 433 H-1 260 0.035 PA 06050 39.9

Girard Point Unit 1232 B-104 70 0.177 1-hour RACT 54.3

Point Breeze Unit 868 FCCU

50,000 BPD feed 

rate (day)1 

47,500 BPD (365-

day avg.) 

50 ppmdv@ 0% 

oxygen. 

Low NOx CO 

Promoter 130.2

Girard Point Unit 1232 FCCU

100,000 BPD feed 

rate (day)1 

90,000 BPD 

(rolling 365-day 

avg.)

10 ppmdv @ 0% 

oxygen 

PA 11353 208.3

Girard Point #3 Boilerhouse 

Boiler #37 495 0.04 PA 08080 86.7

Girard Point #3 Boilerhouse 

Boiler #39 495 0.04 PA 08080 86.7

Girard Point #3 Boilerhouse 

Boiler #40 660 0.04 PA 08080 115.6

Point 

Breeze/Girard 

Point

Engine IC-002 1.4 4.4 AP-42 1.4

Point 

Breeze/Girard 

Point

Engine IC-005 0.2 4.4 AP-42 1.0

Point 

Breeze/Girard 

Point

Engine IC-006 0.8 2.2 Tier 1 1.0

Point 

Breeze/Girard 

Point

Engine IC-007 0.7 0.7 Tier 3 0.7

Point 

Breeze/Girard 

Point

Engine IC-008 1.5 1.1 Tier 2 0.3

BPD = barrels per day 

1

Each FCCU has maximum permitted throughput limits for both a single day and . for a rolling 365-day average. 

Table 2 – VOC Sources 

Location Source Permitted 

Capacity 

VOC Emission 

Rate 

(lbs/MMBTU) 

Reference Potential VOC 

Emissions 

(TPY) 

Point 

Breeze/Girard 

Point

Combustion Units 

(All sources listed 

in Table 1 except 

the 2 FCCUs)

See Table 1 0.0054 

lbs/MMBTU 

AP-42 109.8 

combined 

Point Cooling Towers: 
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Breeze/Girard 

Point

210 Crude - 29,600 

gpm 

868 - 19,700 gpm 

Complex - 35,000 

gpm 

864 - 18,000 gpm 

137 - 36,300 gpm 

433 - 35,300 gpm 

490 - 75,000 gpm 

1232 - 57,000 gpm

See Source 

column 

0.7 lbs/MMgal AP-42 56.3 

combined 

Point Breeze Unit 868 FCCU 50 MBPD 5 lbs/hr PA 00184 23.0 

Girard Point Unit 1232 FCCU 100 MBPD 1.88 lbs/hr PA 11353 8.24 

Point Breeze

Loading 

Operations 

(Wharf) 

Non-gasoline

Varies based on 

material loaded

AP-42 1,482,000 bbl/yr 25.99 

Girard Point

Loading 

Operations 

(Wharf) 

Gasoline and Nongasoline

Varies based on 

material loaded

AP-42 17,902,000 

bbl/yr 

15.21 

Point 

Breeze/Girard 

Point

 

5 Engines Each 1.4 

MMBTU/hr or 

less 

0.00251 lbs/hphr AP-42 Each 0.39 or less 

1

PTE represents 1.4 TPY VOC from gasoline materials controlled by the thermal oxidizer and 13.9 TPY VOC form nongasoline materials that are uncontrolled, for a total of 15.2 TPY VOC 

Sources Evaluated for RACT Separately

On August 31, 2012 PES submitted Plan Approval Application No. 12195 to replace the existing 

RACT limits for the following seven (7) process heaters: 

 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 from (rated capacity 61.2 MMBTU/hr) 

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

As part of the application, PES revised RACT requirements and re-evaluated RACT for each of 

these 7 heaters. AMS has submitted a RACT determination for these 7 heaters to EPA for approval 

separately. As a result, while these heaters are existing sources, they are not part of this RACT 

evaluation. 

 
5 10/30/15

 

De Minimis Sources

Engines IC-002, IC-005, IC-006, IC-007, and IC-008 each have potential emissions below 2 tons per 

year for both NOx and VOC. These potential emissions were calculated based on the rated capacity 

and either AP-42 emission factors or Tier 1 or Tier 2 standards, if applicable. Based on AMS 

permitting and engineering knowledge, AMS determines that installing any control technology on 

such small sources is both technically and economically unreasonable. 

VI. RACT Evaluation

On July 24, 2015, PES submitted to AMS the “PES RACT Update July 2015 – Revision E,” which 

includes a full case-by-case RACT analysis for the remaining NOx emission sources listed as “Caseby-case” in Table 3 below. AMS has reviewed and concurs with PES’s analysis, which is attached 

to this document and submitted to EPA as part of the SIP revision. All costs per ton of pollutant 

controlled listed in this memo come from this document. This analysis excludes the seven (7) 

process heaters addressed in previous RACT submission dated August 31, 2012, as listed above. 

A. NOx RACT

Table 3 below lists the 1-hour RACT requirements for the existing NOx sources. The permitted 

capacity includes any 1-hour RACT limits. Since the 1-hr RACT plan approval was issued in 

August 2000, permitted capacities and fuel types have changed. Therefore current emission limits, 

fuel types, and capacities may not match the EPA-approved 1-hr RACT plan approval. Moving 

forward, these various changes are being incorporated (or modified where appropriate) for RACT for 

the 1997 8-hr ozone standard. 

Table 3- List of NOx Sources and Applicable 1-hour RACT Requirements 

Location Source 

Permitted 

Capacity 

(MMBTU/hr 

unless noted) 

Fuel 

 1-hour RACT 

NOx RACT 

Category 

RACT 

Requirement Emission Limit 

Point Breeze Unit 210-13H1 235.4 Refinery oil and 

refinery gas Case-by-case Combustion 

tuning 

0.104 lb NOx/ 

MMBTU for gas 

and 0.4 lb NOx/ 

MMBTU for oil 

Point Breeze Unit 860-2H2 69.8 Refinery oil and 

refinery gas Case-by-case Combustion 

Tuning 

0.350 lb NOx/ 

MMBTU for gas 

and 0.4 lb NOx/ 

MMBTU for oil 

Point Breeze Unit 860-2H3 174.7 Refinery oil and 

refinery gas Case-by-case Combustion Tuning 

0.163 lb NOx/ 

MMBTU for gas 

and 0.4 lb NOx/ 

MMBTU for oil 

Point Breeze Unit 860-2H4 99.4 Refinery oil and Case-by-case Combustion 0.270 lb NOx/ 
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Location Source 

Permitted 

Capacity 

(MMBTU/hr 

unless noted) 

Fuel 

 1-hour RACT 

NOx RACT 

Category 

RACT 

Requirement Emission Limit 

refinery gas Tuning MMBTU for gas 

and 0.4 lb NOx/ 

MMBTU for oil 

Point Breeze Unit 860-2H5 155 Refinery oil and 

refinery gas Case-by-case Combustion 

Tuning 

0.163 lb NOx/ 

MMBTU for gas 

and 0.4 lb NOx/ 

MMBTU for oil 

Point Breeze Unit 860-2H7 59 Refinery oil and 

refinery gas Case-by-case Combustion Tuning 

0.157 lb NOx/ 

MMBTU for gas 

and 0.4 lb NOx/ 

MMBTU for oil 

Point Breeze Unit 860-2H8 49.6 Refinery oil and 

refinery gas Presumptive 25 Pa Code 

§129.93(b)(2)-(5) Annual Tune-up 

Point Breeze Unit 864-PH1 80 Refinery oil and 

refinery gas Case-by-case Combustion 

Tuning 

0.167 lb NOx/ 

MMBTU for gas 

and 0.4 lb NOx/ 

MMBTU for oil 

Point Breeze Unit 864-PH11 74 Refinery oil and 

refinery gas Case-by-case Combustion 

Tuning 

0.145 lb NOx/ 

MMBTU for gas 

and 0.4 lb NOx/ 

MMBTU for oil 

Point Breeze Unit 864-PH12 85.1 Refinery oil and 

refinery gas Case-by-case Combustion Tuning 

0.119 lb NOx/ 

MMBTU for gas 

and 0.4 lb NOx/ 

MMBTU for oil 

Point Breeze Unit 870-H01 97 Refinery gas N/A2 N/A2 N/A2 

Point Breeze Unit 870-H02 53 Refinery gas N/A2 N/A2 N/A2 

Point Breeze Unit 859-1H1 98 Refinery gas N/A2 N/A2 N/A2 

Girard Point Unit 137 F-1 4151 Refinery oil and 

refinery gas Case-by-case Combustion 

Tuning 

0.230 lb NOx/ 

MMBTU on a 

rolling 30-day 

average for gas and 

oil. 

Girard Point Unit 137 F-2 1551 Refinery oil and 

refinery gas Case-by-case Combustion Tuning 

0.257 lb NOx/ 

MMBTU for gas 

and 0.4 lb NOx/ 

MMBTU for oil 

Girard Point Unit 137 F-3 60 Refinery oil Case-by-case Combustion 

Tuning 

0.4 lb NOx/ 

MMBTU 

Girard Point Unit 1332 H-1 45 Refinery gas Presumptive 25 Pa Code 

§129.93(b)(2)-(5) Annual Tune-up 

Girard Point Unit 1332 H-2 60 Refinery gas Case-by-case Combustion 

Tuning 

0.300 lb NOx/ 

MMBTU 

Girard Point Unit 1332 H-3 43 Refinery gas Presumptive 25 Pa Code 

§129.93(b)(2)-(5) Annual Tune-up 

Girard Point Unit 1332 H400 1861 Refinery gas Case-by-case Combustion 

Tuning 

0.156 lb NOx/ 

MMBTU 

Girard Point Unit 1332 H401 233 Refinery gas Case-by-case Combustion 

Tuning 

0.156 lb NOx/ 

MMBTU 
7 10/30/15

 

Location Source 

Permitted 

Capacity 

(MMBTU/hr 

unless noted) 

Fuel 

 1-hour RACT 

NOx RACT 

Category 

RACT 

Requirement Emission Limit 

Girard Point Unit 1332 H601 48 Refinery gas Presumptive 25 Pa Code 

§129.93(b)(2)-(5) Annual Tune-up 

Girard Point Unit 1332 H602 49 Refinery gas Presumptive 25 Pa Code 

§129.93(b)(2)-(5) Annual Tune-up 

Girard Point Unit 433 H-1 2431 Refinery gas Case-by-case 

ULNB and 

Combustion 

Tuning 

0.060 lb NOx/ 

MMBTU 

Girard Point Unit 1232 B104 701 Refinery gas Case-by-case 

ULNB and 

Combustion 

Tuning 

0.177 lb NOx/ 

MMBTU 

Point Breeze Unit 868 FCCU 50,000 BPD 

feed rate Refinery gas Case-by-case 

Good 

Combustion and 

CO Promoter 

569 tons NOx per 

year on a 365-day 

rolling avg. 

Girard Point Unit 1232 

FCCU 

100,000 BPD 

feed rate Refinery gas Case-by-case - - 

Girard Point #3 Boilerhouse 

Boiler #37 4951 Refinery oil and 

refinery gas Case-by-case ULNB 

0.330 lb NOx/ 

MMBTU for both 

fuels 

Girard Point #3 Boilerhouse 

Boiler #39 4951 Refinery oil and 

refinery gas Case-by-case ULNB 

0.330 lb NOx/ 

MMBTU for both 

fuels 

Girard Point #3 Boilerhouse 

Boiler #40 6601 Refinery oil and 

refinery gas Case-by-case ULNB 

0.330 lb NOx/ 

MMBTU for both 

fuels 

Point 

Breeze/Girard 

Point

Engine IC-002 1.4 Diesel N/A N/A2 N/A2 

Point 

Breeze/Girard 

Point

Engine IC-005 0.2 Diesel N/A N/A2 N/A2 

Point 

Breeze/Girard 

Point

Engine IC-006 0.8 Diesel N/A N/A2 N/A2 

Point 

Breeze/Girard 

Point

Engine IC-007 0.7 Diesel N/A N/A2 N/A2 

Point 

Breeze/Girard 

Point

Engine IC-008 1.5 Diesel N/A N/A2 N/A2 

Point 

Breeze/Girard 

Point

11 Emergency 

Generators and 

Fire Pumps 

856 HP or less 

3 Diesel 

8 ULSD 

N/A N/A2 N/A2 

1

 Indicates a “capped” heat input, rather than maximum capacity, which were approved as part of the 1-hour RACT. 

2

 Units were not part of 1-hour RACT 

The RACT plan approval approved in the SIP under the 1-hour ozone standard contains only caseby-case requirements for the emissions units identified as such in Table 3 above. Under 1-hour 
8 10/30/15

 

RACT, some boilers and heaters are required to have ULNB as RACT. Combustion units without 

NOx controls and not subject to presumptive requirements were required to have annual combustion 

tuning (CT). Some boilers and heaters have heat input caps in MMBTU/hr (as identified with the 

footnote “1” in Table 3). To determine compliance with these caps, the facility is required to monitor 

fuel input for these boilers in a daily basis. In addition, all combustion units above 50 MMBTU/hr 

have lbs NOx/MMBTU limits, in some cases one numerical limit is applied to both gas burning and 

oil burning. While most units at the time of the 1-hour RACT evaluation could burn both refinery 

fuel gas and refinery fuel oil, regular oil use by boilers and heaters was phased out of the facility by 

the end of 2010 as a requirement in a May 24, 2005 Consent Decree between EPA, several states, 

the City of Philadelphia, and Sunoco, Inc. (Civil Action No.05-02866). While the Consent Decree 

allows PES to burn oil in certain circumstances, such as gas curtailments, PES has completely 

stopped burning oil in these heaters and boilers and is requesting removal of the ability to burn oil 

for its 8-hour RACT. AMS is removing any limitation for burning fuel oil in these boilers and 

heaters as part of the RACT SIP for PES. 

Additionally, the following units were subject to case-by-case requirements under the 1-hour RACT 

determination, but have since been shut down: 

 #3 Boiler House Boiler #38 

 22 Boiler House Boilers #1 

 22 Boiler House Boilers #2 

 22 Boiler House Boilers #3 

 859 Heater 1H1 (76 MMBTU/hr) – This is a different unit from the 98 MMBTU/hr 859 

Heater 1H1 listed below as being installed after 1-hour RACT. 

 859 Heater 1H2 

 859 Heater 1H3 

 864 Heater PH3 

 864 Heater PH4 

 864 Heater PH5 

 861 Heater 3H1S 

 861 Heater 3H1N 

 860 Boiler 2H9 

Thus, AMS is not evaluating RACT for these units and requesting that the applicable RACT 

requirements be removed from the SIP. 

The following units were subject to presumptive RACT and have since been shut down: 

 860 Heater 2H1 

 860 Heater 2H6 

 864 Heater PH2 

 1332 Heater H-600 

These are being listed for informational purposes. No changes to the SIP are required. 
9 10/30/15

 

The following units were installed after the 1-hour RACT approval: 

 PB Unit 870 Heater H01 (97 MMBTU/hr, refinery gas) 

 PB Unit 870 Heater H02 (53 MMBTU/hr, refinery gas) 

 PB Unit 859 Heater 1H1 (98 MMBTU/hr, refinery gas) – This unit was installed in 2009 as 

part of the Unit 859 reactivation project and is a different unit from the 76 MMBTU/hr 859 

Heater 1H1 listed above. 

Unit 433 H-1 Heater was subject to the following 1-hour case-by-case RACT requirements as 

approved into the SIP: a firing rate cap of 243 MMBTU/hr and an emissions limit of 0.060 

lbs/MMBTU. In 2006, AMS approved the following revisions to the heater in AMS Plan Approval 

No. 06050 dated December 6, 2006: the heater’s capacity limit was increased to 260 MMBTU/hr 

and its NOx emission limit was reduced to 0.035 lbs/MMBTU. These changes resulted in a 

reduction of potential NOx emissions of 24 tons per year (63.9 - 39.9 tons per year). This permit 

modification is now being submitted as a revision to the SIP to address RACT for Unit 433 H-1 

Heater. 

No internal combustion engines were evaluated in the 1-hour RACT determination as none were 

permitted at that time. The facility has the following internal combustion engines: 

 Eleven (11) emergency generators or emergency fire pumps. The largest unit is 896 HP. 

Three (3) units burn diesel, eight (8) burn ultra low sulfur diesel (ULSD). 

 Five (5) non-emergency units used with pumps or compressors. The largest unit is 214 HP. 

Each unit burns diesel and were permitted after the 1-hour RACT approval. 

The following incinerators and flares are control devices that emit NOx when burning/controlling 

VOCs: 

 Unit 867 Sulfur Recovery Unit (SRU) Flare 

 North Flare 

 South Flare 

 Acid Gas Flare 

 SWS Flare 

 LPG Flare (Propane Loading Station) 

 Marine Vapor Recovery Unit (40 MMBTU/hr) 

 1231/1232 Flare 

 433 Flare 

 1232 FCCU CO Boiler (580 MMBTU/hr) 
10 10/30/15

 

i. Presumptive RACT for NOx: 

Each heater listed as Presumptive in Table 3 is subject to the presumptive RACT requirements of 25 

PA Code Sections 129.93(b)(2)-(5). An annual adjustment or tune-up shall be performed on each 

unit. 

Each of the eleven emergency generators or fire pumps are subject to the presumptive RACT 

requirements of 25 PA Code Section 129.93(c)(5). Each unit is limited to operating less than 500 

hours per rolling 12-month period in Title V/State Operating Permit No. V06-016 and must be 

installed, maintained, and operated in accordance with manufacturer’s specifications. 

The following control devices are subject to the presumptive RACT requirements of 25 PA Code 

Section 129.93(c)(4): Unit 867 SRU Incinerator, North Flare, South Flare, Acid Gas Flare, SWS 

Flare, LPG Flare, Marine Vapor Recovery Unit, 1231/1232 Flare, 433 Flare, and 1232 FCCU CO 

Boiler. Each unit must be installed, maintained, and operated in accordance with manufacturer’s 

specifications. 

ii. Case-by-case RACT Analysis for NOx: 

Boilers and Heaters

 

PES has 27 heaters and three (3) boilers. As mentioned above, seven (7) of the heaters were 

evaluated for RACT separately and are not being addressed in this document. The potential NOx 

emissions listed in Table 1 for the heaters and boilers are based on the rated capacity and the 

permitted lbs/MMBTU NOx emission limit for each unit. 

For these case-by-case heaters and boilers, the following control options are available, including 

estimated NOx reduction, and were evaluated: 

 Ultra Low NOx Burners (ULNBs) and Selective Catalytic Reduction (SCR) – 96% 

 SCR – 85% 

 ULNBs – 50-86% (Assumes modern ULNBs control emissions to 0.03 lbs/MMBTU. The 

NOx emission reduction varies, depending on the unit’s current NOx emission rate.) 

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

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

 SNCR – 40% 

Control Device Descriptions: 

 ULNBs and LNBs are burners designed to create a larger, lower temperature flame, which 

reduces thermal NOx. 

 SCR injects a nitrogen based reagent such as ammonia into the exhaust upstream of a 

catalyst. NOx, ammonia (NH3), and oxygen (O2) react on the surface of the catalyst to form 
11 10/30/15

 

nitrogen (N2) and water (H20). 

 SNCR is similar to SCR, but does not use a catalyst. 

 

A summary of the available controls evaluated as RACT for the heaters and boilers and their 

technical and economic feasibility are provided in Table 4 below. Baseline potential NOx emissions 

were used for all cost analyses provided. Some units had controls installed after 1-hour RACT, as 

identified in the Existing Control column in Table 4 below. Emissions from existing controls were 

considered as baseline for the RACT evaluation. 

Table 4 - Summary of Feasibility of NOx Controls Evaluated as RACT – Boilers and Heaters 

 Technical Feasibility and Cost Effectiveness ($/Ton) 

Source Existing 

Control 

ULNB & 

SCR 

SCR ULNB LNB & 

SNCR 

LNB & 

FGR

SNCR 

Unit 210-13H1 CT Infeasible Infeasible 3,151 9,998 Infeasible 13,921 

Unit 860-2H2 CT Infeasible Infeasible Infeasible Infeasible Infeasible 5,631 

Unit 860-2H3 CT Infeasible Infeasible Infeasible Infeasible Infeasible 9,552 

Unit 860-2H4 CT Infeasible Infeasible 2,999 16,808 Infeasible 6,641 

Unit 860-2H5 CT Infeasible Infeasible Infeasible Infeasible Infeasible 9,786 

Unit 860-2H7 CT Infeasible Infeasible Infeasible Infeasible Infeasible 12,605 

Unit 864-PH1 CT Infeasible Infeasible 9,528 7,796 Infeasible 11,045 

Unit 864-PH11 CT Infeasible Infeasible 12,967 9,070 Infeasible 1,898 

Unit 864-PH12 CT Infeasible Infeasible 17,680 11,561 Infeasible 15,135 

Unit 870-H01 ULNB 1 ULNB 

installed 73,298 ULNB installed 

ULNB 

installed 

ULNB 

installed 49,070 

Unit 870-H02 ULNB 1 ULNB 

installed 92,541 ULNB 

installed 

ULNB 

installed 

ULNB 

installed 56,784 

Unit 859-1H1 ULNB 1 ULNB 

installed 127,640 ULNB installed 

ULNB 

installed 

ULNB 

installed 85,399 

Unit 137 F-1 CT 9,648 6,578 4,331 8,232 7,224 5,883 

Unit 137 F-2 CT 14,897 8,492 8,203 13,023 13,228 6,340 

Unit 137 F-3 ULNB 1 ULNB 

installed 51,523 ULNB installed 

ULNB 

installed 

ULNB 

installed 32,261 

Unit 1332 H-2 ULNB 1 ULNB 

installed 77,200 ULNB installed 

ULNB 

installed 

ULNB 

installed 48,210 

Unit 1332 

H-400 SCR 1 SCR 

installed SCR installed 11,337 SCR 

installed 

SCR 

installed 

SCR 

installed 

Unit 1332 

H-401 SCR 1 SCR 

installed SCR installed 9,051 SCR 

installed 

SCR 

installed 

SCR 

installed 

Unit 433 H-1 ULNB ULNB 

installed 50,368 ULNB installed 

ULNB 

installed 

ULNB 

installed 39,879 

Unit 1232 B-104 ULNB ULNB 

installed 16,570 ULNB 

installed 

ULNB 

installed 

ULNB 

installed 10,772 

#3 Boilerhouse 

Boiler #37 

ULNB + 

FGR 1

ULNB & 

FGR 

installed 

32,829 

ULNB & 

FGR 

installed 

ULNB & 

FGR 

installed 

ULNB & 

FGR 

installed 

13,221 

#3 Boilerhouse 

Boiler #39 

ULNB + 

FGR 1 ULNB & 

FGR 32,829 ULNB & FGR 

ULNB & 

FGR 

ULNB & 

FGR 13,221 
12 10/30/15

 

installed installed installed installed 

#3 Boilerhouse 

Boiler #40 

ULNB + 

FGR 1

ULNB & 

FGR 

installed 

30,139 

ULNB & 

FGR 

installed 

ULNB & 

FGR 

installed 

ULNB & 

FGR 

installed 

11,823 

1

 Controls were installed after the 1-hour RACT determination, thus are not approved as RACT 

In addition to the information contained in the PES RACT Update, the blueprints in Attachment B 

and AMS inspections show a lack of space to install SCR at the heaters located at Units 210, 860, 

and 864. The open space that is near these units is must remain open for emergency and maintenance 

vehicle access. Additionally, all of these heaters have exhaust temperatures outside the 6500 F to 

7800

 F range PES has found to be necessary for proper catalyst operation for units in similar service. 

AMS inspections confirm a lack of space for the ductwork necessary for FGR at these units. 

ULNB and LNB are technically infeasible for the Unit 860 Heaters 2H2, 2H3, 2H5, and 2H7 

because their fireboxes are not big enough to accommodate the longer flame length of these 

technologies. According to the John Zink Combustion Handbook, LNBs typically have a flame 

length of 0.8-2.5 feet per MMBTU capacity. Based on ULNB installations on similar heaters, PES 

estimates the flame length would be in the 2.0-2.5 feet per MMBTU capacity for these heaters. The 

John Zink Combustion Handbook also states that the visible flame length shall be a maximum of 

two-thirds of the radiant section height. These parameters cannot be met in these heaters. 

For each boiler and heater, all additional NOx controls are either technically infeasible or 

economically unreasonable based on the current existing level of control. AMS is revising the SIP to 

update to the RACT applicable requirements for each emissions unit based on the current level of 

control and most recent permit modifications. These revisions are summarized in Table 5 below. 

Table 5 – Comparison of Approved 1-hour and Proposed 8-hour Case-by-Case RACT 

Requirements for Boilers and Heaters 

Source 

Permitted 

Capacity 

(MMBtu/

hr unless 

noted) 

Approved 1-hour RACT Proposed 8-hour RACT 

RACT 

Control Emission Limit RACT 

Control Emission Limit 

Unit 210CHeater 13H1 235.4 Combustion 

tuning 

0.104 lb NOx/ MMBTU 

for gas and 0.4 lb NOx/ 

MMBTU for oil 

Combustion 

tuning 

0.104 lb NOx/ MMBTU 

for gas 

Reformer 

860- Heater 

2H2 

69.8 Combustion 

Tuning 

0.350 lb NOx/ MMBTU 

for gas and 0.4 lb NOx/ 

MMBTU for oil 

Combustion 

Tuning 

0.350 lb NOx/ MMBTU 

for gas 

Reformer 

860- Heater 

2H3 

174.7 Combustion 

Tuning 

0.163 lb NOx/ MMBTU 

for gas and 0.4 lb NOx/ 

MMBTU for oil 

Combustion 

Tuning 

0.163 lb NOx/ MMBTU 

for gas 

Reformer 

860- Heater 

2H4 

99.4 Combustion 

Tuning 

0.270 lb NOx/ MMBTU 

for gas and 0.4 lb NOx/ 

MMBTU for oil 

Combustion 

Tuning 

0.270 lb NOx/ MMBTU 

for gas 
13 10/30/15

 

Source 

Permitted 

Capacity 

(MMBtu/

hr unless 

noted) 

Approved 1-hour RACT Proposed 8-hour RACT 

RACT 

Control Emission Limit RACT Control Emission Limit 

Reformer 

860- Heater 

2H5 

155 Combustion 

Tuning 

0.163 lb NOx/ MMBTU 

for gas and 0.4 lb NOx/ 

MMBTU for oil 

Combustion 

Tuning 

0.163 lb NOx/ MMBTU 

for gas 

Reformer 

860- Heater 

2H7 

59 Combustion 

Tuning 

0.157 lb NOx/ MMBTU 

for gas and 0.4 lb NOx/ 

MMBTU for oil 

Combustion 

Tuning 

0.157 lb NOx/ MMBTU 

for gas 

Reformer 

864- Heater 

PH1 

80 Combustion 

Tuning 

0.167 lb NOx/ MMBTU 

for gas and 0.4 lb NOx/ 

MMBTU for oil 

Combustion 

Tuning 

0.167 lb NOx/ MMBTU 

for gas 

Reformer 

864- Heater 

PH11 

74 Combustion 

Tuning 

0.145 lb NOx/ MMBTU 

for gas and 0.4 lb NOx/ 

MMBTU for oil 

Combustion 

Tuning 

0.145 lb NOx/ MMBTU 

for gas 

Reformer 

864- Heater 

PH12 

85.1 Combustion 

Tuning 

0.119 lb NOx/ MMBTU 

for gas and 0.4 lb NOx/ 

MMBTU for oil 

Combustion 

Tuning 

0.119 lb NOx/ MMBTU 

for gas 

Unit 870- 

Heater H01 97 N/A N/A ULNB1

 0.035 lb NOx/MMBTU 

Unit 870- 

Heater H02 53 N/A N/A ULNB1

 0.035 lb NOx/MMBTU 

Unit 859- 

Heater 1H1 98 N/A N/A ULNB1

 0.035 lb NOx/MMBTU 

Unit 137 

Heater F-1 415 Combustion Tuning 

0.230 lb/ MMBTU on a 

30-day rolling average 

Combustion 

Tuning 

0.230 lb/ MMBTU on a 

30-day rolling average 

Unit 137 

Heater F-2 155 Combustion 

Tuning 

0.257 lb NOx/ MMBTU 

for gas and 0.4 lb NOx/ 

MMBTU for oil 

Combustion 

Tuning 

0.257 lb NOx/ MMBTU 

for gas 

Unit 137 

Heater F-3 60 Combustion Tuning 

0.4 lb NOx/ MMBTU for 

oil ULNB1 0.060 lb NOx/MMBTU 

for gas 

Unit 1332 

Heater H-2 60 Combustion 

Tuning 

0.300 lb NOx/ MMBTU 

for gas ULNB1

 0.040 lbs/MMBTU 

Unit 1332 

Heater H-400 186 Combustion 

Tuning 

0.156 lb NOx/ MMBTU 

for gas SCR1 0.06 lb/MMBTU on a 

rolling 365-day basis 

Unit 1332 

Heater H-401 233 Combustion Tuning 

0.156 lb NOx/ MMBTU 

for gas SCR1 0.06 lb/MMBTU on a 

rolling 365-day basis 

Unit 433 - 

Heater H-1 2602 

ULNB and 

Combustion 

Tuning 

0.060 lb NOx/ MMBTU 

for gas 

ULNB and 

Combustion 

Tuning 

0.035 lb NOx/ MMBTU 

for gas 

Unit 1232 - 

Heater B-104 70 

ULNB and 

Combustion 

Tuning 

0.177 lb NOx/ MMBTU 

for gas 

ULNB and 

Combustion 

Tuning 

0.177 lb NOx/ MMBTU 

for gas 

#3 Boiler 

House Boiler 

#37 

495 

ULNB and 

Combustion 

Tuning 

0.330 lbs NOx/MMBTU 

on a 30-day rolling 

average 

ULNB + 

FGR1

0.040 lb/MMBTU on a 

rolling 365-day basis 

#3 Boiler 

House Boiler 

#39 

495 

ULNB and 

Combustion 

Tuning 

0.330 lbs NOx/MMBTU 

on a 30-day rolling 

average 

ULNB + 

FGR1

0.040 lb/MMBTU on a 

rolling 365-day basis 

#3 Boiler 

House Boiler 

#40 

660 

ULNB and 

Combustion 

Tuning 

0.330 lbs NOx/MMBTU 

on a 30-day rolling 

average 

ULNB + 

FGR1

0.040 lb/MMBTU on a 

rolling 365-day basis 
14 10/30/15

 

1

 Controls were installed after the 1-hour RACT determination, thus are not approved as RACT 

2

Capacity increased from 243 MMBTU/hr to 260 MMBTU/hr along with reduction in NOx emission limit in AMS Plan Approval 

06050 dated December 4, 2006 and is being proposed as a SIP revision for 8-hour RACT

Conclusions and Recommendations 

AMS determines that the following updates to the current 1-hr RACT determination shall be NOx 

RACT for the 1997 8-hr ozone standard: 

 Removing the ability to burn oil for all boilers and heaters. Emissions limits for burning oil 

will be removed. 

 ULNB shall be the RACT control for the following heaters: Unit 870-H01, Unit 870-H02, 

Unit 859-1H1, Unit 137 F-3, and Unit 1332 H-2. 

o Unit 870-H01 and Unit 870 H02 Heaters shall be given NOx emission limits of 0.035 

lbs/MMBTU (consistent with limit in AMS Plan Approval 02184 dated May 12, 

2004). 

o Unit 859-1H1 Heaters shall be given a NOx emission limit of 0.02 lbs/MMBTU 

(consistent with limit in AMS Plan Approval 06144 dated January 29, 2008). 

o Unit 137 F-3 Heater shall be listed as burning refinery fuel gas and shall be given a 

NOx emission limit of 0.060 lbs/MMBTU (consistent with limit in AMS Plan 

Approval 07163 dated February 5, 2008). 

o Unit 1332 H-2 Heater shall be given a NOx emission limit of 0.040 lbs/MMBTU 

(consistent with limit in AMS Plan Approval 05124 dated October 4, 2005). 

o Unit 433 H-1 Heater shall be given NOx emission limits of 0.035 lbs/MMBTU and a 

capacity limit of 260 MMBTU/hr. (matches limits in AMS Plan Approval 06050 

dated December 4, 2006). 

 SCR shall be the RACT control for Unit 1332 H-400 and Unit 1332 H-401 Heaters. The 

NOx limit for each heater shall be changed from 0.156 lbs/MMBTU to 0.06 lbs/MMBTU on 

a rolling 365-day basis (consistent with limit in AMS Plan Approval 09040 dated February 1, 

2010) and 0.15 lbs/MMBTU on a daily basis. These units have a NOx Continuous Emission 

Monitoring System (CEMS) on their combined stack at the SCR outlet. The SCR may be 

bypassed during times required to replace SCR catalyst or to do maintenance to the SCR/air 

pre-heater system or to operate the heaters at low firing rate during reformer catalyst 

regenerations, as per Plan Approval 09040. PES must take a daily NOx sample when the 

SCR and CEMS are bypassed. The daily and rolling 365-day emission limits still apply 

during the bypasses. 

 FGR in addition to existing ULNB shall be the RACT control for #3 Boilerhouse Boilers 

#37, 39 & 40. The NOx limit for each boiler shall be changed from 0.330 lbs/MMBTU on a 

rolling 30-day to 0.040 lbs/MMBTU on a rolling 365-day basis (consistent with limit in 

AMS Plan Approval 08080 dated 11/2/10). They have been given an additional daily NOx 

limit of 0.10 lbs/MMBTU. These boilers were required to have NOx CEMS as part of the 1-

hour RACT. 

 Removal of all conditions referring to the following shutdown units: 
15 10/30/15

 

o #3 Boiler House Boiler #38 

o 22 Boiler House Boilers #1 

o 22 Boiler House Boilers #2 

o 22 Boiler House Boilers #3 

o 859 Heater 1H1 (76 MMBTU/hr unit) 

o 859 Heater 1H2 

o 859 Heater 1H3 

o 864 Heater PH3 

o 864 Heater PH4 

o 864 Heater PH5 

o 861 Heater 3H1S 

o 861 Heater 3H1N 

o 860 Boiler 2H9 

Fluid Catalytic Cracking Units (FCCU)

PES has two (2) FCCUs. The 868 FCCU is a full-burn unit that is permitted under AMS Plan 

Approval No. 00184 dated March 22, 2002 to operate up to 50,000 barrels in a single day and 47,500 

barrels per day on a rolling 365-day average. Under 1-hour RACT the unit has a NOx emission limit 

of 569 tons per rolling 12-month period and must follow good combustion practices and use a CO 

promoter in the regenerator. It did not have any barrels per day limits at that time. Potential NOx 

emissions in Table 1 are based on the 47,500 barrels per day on a rolling 365-day average permit 

limit from AMS Plan Approval No. 00184 dated March 22, 2002 and a 50 ppmdv @ 0% oxygen on 

a rolling 365-day average limit proposed by PES in a February 2013 "868 Low NOx CO 

Combustion Promoter Study" to comply with the Second Amendment of Civil Action No.05-02866 

Consent Decree. This study involved operating the unit over a period of time with an additive which 

provides more complete oxidation of CO to CO2 at and reduced NOx emissions. The unit has been 

complying with the proposed emission, although it has not been approved by EPA yet. 

The 1232 FCCU is a partial–burn unit that is permitted under AMS Plan Approval No. 11353 dated 

July 30, 2012 to operate up to 100,000 barrels in a single day and 90,000 barrels per day on a rolling 

365-day average. It is equipped with a waste heat CO Boiler. It did not have any specific 

requirements under 1-hour RACT. It had SCR installed after the 1-hour RACT determination. 

Potential NOx emissions in Table 1 come from a rolling 365-day NOx permit limit from Plan 

Approval No. 11353 dated July 30, 2012. 

The following control devices are available for controlling NOx emissions from FCCUs: 

 SCR – Estimated 90% NOx control efficiency for FCCUs. 

 LoTOxTM – This technology works in conjunction with a wet scrubber. It is a selective, low 

temperature oxidation technology that uses ozone to oxidize NOx to water soluble nitric 

pentoxide (N2O5), which, inside the wet scrubber, forms nitric acid that is subsequently 

scrubbed by the scrubber nozzles and neutralized by the scrubber’s alkali reagent. Estimated 

90% NOx control efficiency for FCCUs. 
16 10/30/15

 

 SNCR – Estimated 40% NOx control efficiency for FCCUs. 

SCR, SNCR, and LoTOxTM were evaluated as evaluated as technically feasible control options for 

the 868 FCCU. 

 

Table 6 - Summary of NOx Controls Evaluated as RACT – FCCUs

 Technical Feasibility and Cost 

Effectiveness ($/Ton) 

Source Existing 

Control 

SCR SNCR LoTOxTM

868 FCCU 

Good 

Combustion 

and CO 

Promoter 

30,794 10,679 13,328 

1232 FCCU SCR SCR 

Installed 

SCR 

Installed 

SCR 

Installed 

SCR, SNCR, and LoTOxTM are all economically unreasonable for the 868 FCCU based on cost per 

ton of NOx controlled. 

Since no NOx control is more effective than SCR for an FCCU, no further control evaluation was 

performed on the 1232 FCCU. The SCR will be considered RACT for the unit under the 1997 8-

hour ozone standard. 

Table 7 – 1-hour and 8-hour Case-by-Case RACT Requirements for FCCUs

Source 

Permitted 

Capacity 

(MBPD) 

Approved 1-hour RACT 8-hour RACT 

RACT 

Control Emission Limit RACT Control Emission Limit 

868 FCCU 50 

Good 

Combustion 

and CO 

Promoter 

569 tons per rolling 12-

month period 

Good 

Combustion 

and CO 

Promoter 

100 ppmdv @ 0% O2 on a 

7-day rolling average, and 

130.2 tons per rolling 365-

day period 

1232 FCCU 100 N/A N/A SCR 

30 ppmdv @ 0% O2 on a 

7-day rolling average and 

208.28 tons per rolling 365-

day period 

The 100 ppmdv @ 0% O2 on a 7-day rolling average emission limit for the 868 FCCU is a proposed 

limit by PES in a February 2013 "868 Low NOx CO Combustion Promoter Study" to comply with 

the Second Amendment of Civil Action No.05-02866 Consent Decree. The 30 ppmdv @ 0% O2 on 

a 7-day rolling average limit for the 1232 FCCU is from Plan Approval No. 11353 dated July 30, 
17 10/30/15

 

2012. The tons per rolling 365-day period limit come from the potential emissions in Table 1 for 

each unit, calculated as described above. 

Conclusions and Recommendations: 

AMS determines that adding a 100 ppmdv @ 0% O2 on a 7-day rolling average NOx limit and 

modifying the annual NOx limit to 130.2 tons per rolling 365-day period shall be NOx RACT for the 

1997 8-hour for Unit 868 FCCU. AMS determines the existing SCR shall be NOx RACT for the 

1997 8-hour ozone standard for Unit 1232 FCCU. In addition, a 30 ppmdv @ 0% O2 on a 7-day 

rolling average NOx emission limit and a 208.28 tons per rolling 365-day period NOx emission limit 

(matches limits in AMS Plan Approval No. 11353 dated July 30, 2012). AMS is also adding a 

requirement to operate a NOx CEMS on the Unit 868 FCCU and the Unit 1232 FCCU. 

B. VOC RACT

The facility’s air emissions sources contributing to VOC emissions include the following: 

Table 8 – Summary of 1-hour and 8-hour RACT for VOC Sources 

Location Source Name RACT Category VOC RACT Summary 

Point Breeze/Girard 

Point 

Combustion Units 1 

<50 MMBtu/hr 

Presumptive meets PA Code §129.93 

Combustion Units 1 

≥50 MMBtu/hr Case-by-case 

No technically feasible 

control option for controlling 

VOC emissions, both 1-hour 

and 8-hour RACT 

Point Breeze/Girard 

Point Cooling Towers Case-by-case 

1-hour RACT: Inspection 

and maintenance/monitoring 

program for VOC fugitive 

emissions 

8-hour RACT: 40 CFR 63 

Subpart CC equipment 

monitoring program 

Point Breeze 868 Fluid Catalytic Cracking 

Unit Case-by-case 

Full-burn unit, no VOC 

RACT control options for 1-

hour or 8-hour RACT 

Girard Point 1232 Fluid Catalytic Cracking 

Unit 

Case-by-case 

Partial-burn unit 

1-hour RACT: No specific 

requirements 

8-hour RACT: Vent to CO 

Boiler when operating as 

partial-burn unit and good 

combustion practices 
18 10/30/15

 

1

 The combustion units are the same boilers and heaters listed in the NOx RACT section. 2

 The diesel-fired RICE are the same units listed in the NOx RACT section. 

The RACT plan approvals (PA Permit Number 51-1501 and 51-1517 dated August 1, 2000) 

approved in the SIP for the 1-hour ozone standard contain only case-by-case requirements for a few 

VOC emissions units as identified in Table 8. AMS is re-evaluating RACT for sources identified as 

case-by-case and summarizing RACT applicable requirements for remaining sources. 

i. CTG RACT [i.e. Applicable to EPA Control Technique Guideline (CTG)]: 

The following sources are subject to RACT regulations that have been SIP-approved in accordance 

with EPA’s Control Technique Guidelines (CTGs) for controlling VOC emissions. In addition, each 

regulation has been recertified by Pennsylvania as meeting the applicable CTG requirements for 

RACT for the 1997 8-hour ozone standard. 

Equipment leaks are subject to 25 PA Code Section 129.58, which satisfies EPA’s CTG RACT 

requirements for the control of VOC emissions in leaks from petroleum refinery equipment. In 

accordance with 25 PA Code Section 129.58, the facility must conduct a monitoring program for 

Point Breeze/Girard 

Point/Schuylkill River 

Tank Farm 

Equipment Leaks Case-by-case 1-hour 

CTG 8-hour 

1-hour RACT: quarterly 

LDAR program 

8-hour RACT: meets PA 

Code §129.58 

Point Breeze/Girard 

Point/ Schuylkill 

River Tank Farm 

Wastewater Treatment Plant 

Oil/Water separators (Carbon 

canisters) 

CTG meets PA Code §129.55 

Point Breeze/Girard 

Point/ Schuylkill 

River Tank Farm 

Storage Tanks CTG 

meets PA Code §§129.56 

and 129.57 

Point Breeze Stormwater Tank 7308, 7300 CTG 

meets PA Code §§129.56 

and 129.57 

Girard Point Degreasers CTG meets PA Code §129.63 

Point Breeze/Girard 

Point Loading Operations (Wharf) 

Case-by-case 

(CTG for RVP > 4 for 

1-hour RACT) 

1-hour RACT: CTG/ meets 

PA Code §129.81 for RVP 

> 4, no requirements for 

RVP < 4 

8-hour RACT: PB limited to 

RVP < 4 and 25.99 tpy 

VOC. GP thermal oxidizer 

and 98% control or 20 ppm 

outlet for RVP >= 4, de 

minimis/no control for RVP 

< 4. 

Girard Point/ 

Schuylkill River Tank 

Farm 

Loading Operations (Truck 

Rack) 

CTG for RVP > 4 

Case-by-case for RVP 

< 4 

RVP > 4 meets meets AMR 

V, Section V 

RVP < 4 (cumene) de 

minimis, no controls in 1-

hour and 8-hour RACT 

Point Breeze/Girard 

Point 

11 Diesel-Fired Emergency and 

Fire Pumps RICE Presumptive meets PA Code §129.93 
19 10/30/15

 

equipment leaks. Under 1-hour case-by-case RACT, the facility must have a quarterly leak detection 

and repair (LDAR) program for all valves, pumps, flanges, and compressors in VOC service. Since 

these requirements are less stringent than 25 PA Code Section 129.58, which has more frequent 

monitoring for some equipment and has additional leak standards, the quarterly LDAR program is 

being removed from the RACT plan approval. 

Wastewater Treatment Plant Oil/Water Separators are subject to 25 PA Code Section 129.55, which 

satisfies EPA’s CTG RACT requirements for the control of VOC emissions for VOC controls of 

refinery vacuum producing systems, wastewater separators, and process turnarounds. In accordance 

with 25 PA Code Section 129.55, containers, pumps, and compressors in the refinery handling 

VOCs with a vapor pressure greater than 1.5 psia shall have mechanical seals. 

Storage Tanks and Stormwater Tank 7308 and7300 are subject to 25 PA Code Sections 129.56 and 

129.57, which satisfy EPA’s CTG RACT requirements for the control of VOC emissions from 

petroleum liquid storage. Tanks storing VOCs with a vapor pressure greater than 1.5 psia must have 

a floating roof or vapor recovery system and control device if the tank is greater than 40,000 gallons 

and a pressure relief valve meeting certain requirements if they are between 2,000 gallons and 

40,000 gallons. 

Degreasers are subject to 25 PA Code Section 129.63, which satisfies EPA’s CTG RACT 

requirements for the control of VOC emissions from solvent metal cleaning. Degreasers must meet 

certain equipment standards and operating requirements. 

Truck Loading Operations for organic materials with a RVP of 4.0 or greater are subject to the CTG 

RACT requirements of Air Management Regulation V, Section V. Loading organic materials with a 

RVP of 4.0 or greater requires a vapor recovery system. Truck Loading of cumene, which has a RVP 

below 4.0, has potential VOC emissions of 2 tons per year. Based on AMS permitting and 

engineering knowledge, AMS determines that installing any control technology on such small 

sources is both technically and economically unreasonable. 

ii. Presumptive RACT: 

Combustion units (boilers and heaters) with a rated heat input greater than or equal to 20 

MMBTU/hr but less than 50 MMBTU/hr are subject to 25 PA Code Sections 129.93(b)(2)-(5). An 

annual adjustment or tuneup shall be performed on each unit. 

The eleven emergency generators and fire pumps are subject to 25 PA Code Section 129.93(c)(5). 

Each unit is limited to operating less than 500 hours per rolling 12-month period in Title V/State 

Operating Permit No. V06-016 and must be installed, maintained, and operated in accordance with 

manufacturer’s specifications. 

 
20 10/30/15

 

iii. Case-by-case RACT Analysis for VOC: 

The PES RACT Update July 2015 – Revision E submittal includes a full case-by-case RACT 

analysis for the VOC emission sources listed above. AMS accepted this analysis, which is being 

incorporated by reference. 

Combustion Units Rated 50 MMBTU/hr and Greater

There are no 1-hour VOC RACT requirements for the combustion units (boilers and heaters) with a 

rated heat input of 50 MMBTU/hr or greater because there were no technically feasible VOC control 

options for these combustions units. It is not technically feasible to vent combustion unit exhausts to 

control devices like flares. Oxidation catalysts have not been demonstrated at refineries and are 

considered technically infeasible because the sulfur compounds found in refinery fuel gas poisons 

the catalyst. Most combustion units at the facility have potential VOC emissions below 5 tons per 

year. 

Conclusions and Recommendations:

AMS determines that there are no VOC RACT controls for the combustion units. 

Cooling Towers

The cooling towers emit fugitive VOC emissions when leaks in refinery heat exchangers allow 

VOCs to enter the cooling water streams and become volatilized when the cooling water passes 

through the cooling towers. The potential emissions listed in Table 2 were calculated using AP-42 

emissions factors (AP-42 Table 5.1-2 for controlled emissions) and the circulation rate of the units. 

The SIP-approved 1-hour RACT plan approval requires an inspection and maintenance/monitoring 

program for VOC fugitive emissions from cooling towers. There are no add-on control devices for 

VOC emissions from cooling towers as all emissions are fugitives. As is noted in AP-42, controlling 

emissions from cooling towers involves minimizing leaks and monitoring cooling water for 

hydrocarbons. PES currently does this through the inspection and maintenance/monitoring program 

for VOC fugitive emissions from cooling towers as required in 1-hour RACT plan approval and an 

equipment monitoring program for heat exchange systems as required by 40 CFR 63, subpart CC, 

(National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries. This 

program sets specific monitoring locations, frequencies, methods, leak levels, and repair 

requirements. This specificity makes it more stringent than the program in 1-hour RACT. 

Conclusions and Recommendations: 

AMS determines that the equipment monitoring program for heat exchange systems required by 40 

CFR 63, subpart CC shall be VOC RACT for the 1997 8-hour ozone standard, replacing the 

maintenance/monitoring program required in 1-hour RACT.. 

 

Fluid Catalytic Cracking Units (FCCUs)

The Unit 1232 FCCU at the Girard Point Refinery is a partial-burn unit that uses a carbon monoxide 

(CO) waste heat boiler to reduce VOC emissions to very low levels (potential VOC emissions are 
21 10/30/15

 

8.2 tons per year). It is capable of operating in full-burn mode when there is a problem with the CO 

boiler. There are no 1-hour VOC RACT requirements for this unit. 

The Unit 868 FCCU at the Point Breeze Refinery is in operation as a full-burn unit, where relatively 

low VOC and CO emissions are emitted in the exhaust gas after thermal regeneration of the catalyst. 

There are no specific 1-hour VOC RACT requirements for this unit. The 868 FCCU is required to 

have good combustion practices controlling the level of excess oxygen and CO promoter in the 

regenerator for NOx RACT, which also helps to reduce VOC emissions. 

The only VOC control device available for FCCUs is a CO Boiler, which can only be used with 

partial burn units. CO boilers burn the CO in exhaust gases as fuel, converting it into CO2, and 

producing steam. Full-burn FCCUs do not emit CO in high enough concentrations to make CO 

boilers technologically feasible. 

The Unit 1232 FCCU already has a CO boiler, the only VOC control option. This is determined 

VOC RACT when the FCCU is operating in partial-burn mode. A CO boiler is not technically 

feasible for the Unit 868 FCCU because it is a full-burn unit or during full-burn mode for the 1232 

FCCU. 

Conclusions and Recommendations for VOC RACT: 

AMS determines that good combustion practices and operation with the CO boiler when in partialburn mode for Unit 1232 FCCU shall be VOC RACT for the 1997 8-hour ozone standard. AMS 

determines that good combustion practices controlling the level of excess oxygen and CO promoter 

in the regenerator for Unit 868 FCCU shall be VOC RACT for the 1997 8-hour ozone standard. 

Marine Loading Operations (Wharf)

The Girard Point Barge Loading Process (P130) processes materials with a RVP of 4 psi or greater 

and is controlled by a thermal oxidizer (CD011, described as a flare in the Title V operating permit) 

consistent with the requirements of 25 PA Code Section 129.81. At the time of 1-hour RACT, the 

Point Breeze Marine Barge Loading (P636) processed organic materials with an RVP of 4 psi or 

greater and consequently had a Marine Vapor Collection and Control System (MVCACS) which 

collected and fed vapors to process heaters and boilers as fuel, in accordance with 25 PA Code 

Section 129.81. Point Breeze Marine Barge Loading no longer processes materials with a RVP of 4 

psi or greater and the MVCACS has been shut down (it was only required for these materials). 

At the time of the 1-hour RACT analysis, 25 PA Code 129.81 was the presumptive RACT regulation 

for marine vessel loading in Pennsylvania. As such, these two sources were required to have a 

thermal oxidation/combustion unit installed with at least 90% VOC capture and destruction 

efficiency. In 2001, EPA has issued new RACT requirements for marine vessel loading found in 40 

CFR Part 60, Subpart Y that require a capture and destruction efficiency of at least 98% when using 

a destruction device and at least 95% when using a recovery device. Neither marine loading process 

at the facility is applicable to Subpart Y since their maximum throughputs have never exceeded the 

applicability thresholds of 10 million barrels of gasoline or 200 million barrels of crude on a 24-

month annual average, 
22 10/30/15

 

For the 1997 8-hour ozone NAAQS, AMS is not recertifying 25 PA Code 129.81 as meeting the 

RACT requirements for marine vessel loading since there is only one applicable source remaining in 

Philadelphia. As a result, these sources are subject to a case-by-case RACT analysis 

The following are potential control options for barge loading: 

 Thermal Incinerator (est. up tp 98% VOC control) 

 Flare (up to 98%) 

 Carbon Adsorption (up to 98%) 

 Condenser (up to 90%) 

Girard Point Barge Loading already has a Thermal Oxidizer with a 98% control efficiency for 

loading materials with a RVP of 4 psi or greater. Since the thermal oxidizer is the most stringent 

control option available, it is considered RACT for loading these materials at Girard Poinnt. Point 

Breeze Barge Loading is being given a limit to restrict loading of organic liquid materials with a 

RVP of 4 psi or greater. 

A case-by-case RACT analysis was done for both Girard Point Barge Loading and Point Breeze 

Barge Loading for materials with a RVP below 4 psi. A condenser was determined technically 

infeasible for Girard Point Barge Loading because VOC condensation would not occur for the 

composition of the VOC being captured for this unit. A condenser was determined technically 

feasible for Point Breeze Marine Loading, although the maximum VOC reduction achievable is only 

estimated to be 61% based on the composition of the VOC being captured for this unit. 

 

Table 9 - Summary of VOC Controls Evaluated as RACT – Marine Loading RVP < 4 psi

 Technical Feasibility and Cost 

Effectiveness ($/Ton) 

Source PTE Thermal 

Incinerator 

Flare Carbon 

Adsorption 

Condenser

GP Marine 

Loading 13.9 116,267 62,828 59,489 Infeasible 

PB Marine 

Loading 25.99 23,365 19,254 14,798 41,525 

All controls for both processes were determined technically infeasible or economically

unreasonable.

AMS determines the following requirements to be RACT:

Girard Point Barge Loading of VOC materials with a Reid Vapor Pressure of 4 psi or greater shall vent to a

Thermal Oxidizer with a VOC destruction efficiency of at least 98% or control to an outlet of 20 ppmv

VOC or less. The Thermal Oxidizer shall have a continuous temperature monitor and recorder.
23 10/30/15

 

Point Breeze Marine Barge Loading shall not load any VOC materials with a Reid Vapor Pressure of 4 psi

or greater. VOC emissions from Point Breeze Marine Barge Loading shall not exceed 25.99 tons per rolling

12-month period.

The 20 ppmv VOC outlet concentration option has been added for Girard Point Barge Loading of 

VOC materials with a RVP of 4 psi or greater in the event where the inlet concentration is very low, 

making it very difficult to achieve the alternative 98% destruction efficiency. 

Conclusions and Recommendations for VOC RACT: 

AMS determines that a Thermal Oxidizer with a 98% VOC control efficiency or controls outlet 

emissions to 20 ppmdv VOC shall be VOC RACT for the 1997 8-hour ozone standard for Girard 

Point Barge Loading of VOC materials with a RVP of 4 psi or greater. AMS determines that a limit 

prohibiting loading materials with a RVP of 4 psi or greater and a 25.99 tons of VOC per rolling 12-

month period limit to be VOC RACT for the 1997 8-hour standard for Point Breeze Marine Barge 

Loading. 

10/30/15

Edward Wiener, Chief of Source Registration Date