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 Phila delphia 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 techno logy (RACT) controls on all major sources of Volatile Organic Compounds (VOC) and Nitrogen Oxides (NOx). Phila delphia County is part of the PhiladelphiaWilmington-Atlantic City moderate ozone nonatt ainment 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 Marke ting 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 NO x 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 VO C 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 determin ation (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) – Phil adelphia. 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 refi nery fuel gas-fired process heat ers, 3 refinery fuel gas-fired boilers, 2 Fluid Catalytic Crack ing Units (FCCUs), 5 diesel-fir ed non-emergency reciprocating internal combustion engines (RICE), 11 emergenc y generators and fire pumps, storage tanks, cooling towers, 2 loading operations , oil-water separators, and degreas ers. 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 24.33 10/30/15 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:4 10/30/15 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 15.2 1

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 followi ng seven (7) process heaters:

 Unit 231 B101 Heater (rat ed 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 (rat ed capacity 192.0 MMBTU/hr)

 Unit 210 H201A/B Heater (r ated capacity 254.0 MMBTU/hr)

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

 Unit 868 8H101 Heater from (rate d 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 th ese heaters are existing sources, th ey 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 emissi ons were calculated based on the rated capacity and either AP-42 emission factors or Tier 1 or Ti er 2 standards, if applicable. Based on AMS permitting and engineering knowledge, AMS determin es 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 PE S’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 pr evious RACT submission dated August 31, 2012, as listed above.

A. NOx RACT

Table 3 below lists the 1-hour RACT requirement s 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 fu el 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 incorporat ed (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

NO x 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/6 10/30/15 Location Source Permitted Capacity (MMBTU/hr unless noted) Fuel 1-hour RACT

NO x 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/A 2 N/A 2 N/A 2

Point Breeze Unit 870-H02 53 Refinery gas N/A 2 N/A 2 N/A 2

Point Breeze Unit 859-1H1 98 Refinery gas N/A 2 N/A 2 N/A 2

Girard Point Unit 137 F-1 415 1 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-2 155 1 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 Re finery 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 186 1 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/ MMBTU7 10/30/15 Location Source Permitted Capacity (MMBTU/hr unless noted) Fuel 1-hour RACT

NO x 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-1 243 1 Refinery gas Case-by-case ULNB and Combustion

Tuning 0.060 lb NOx/ MMBTU

Girard Point Unit 1232 B104 70 1 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 #37 495 1 Refinery oil and refinery gas Case-by-case ULNB 0.330 lb NOx/ MMBTU for both fuels

Girard Point #3 Boilerhouse Boiler #39 495 1 Refinery oil and refinery gas Case-by-case ULNB 0.330 lb NOx/ MMBTU for both fuels

Girard Point #3 Boilerhouse Boiler #40 660 1 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/A 2 N/A 2

Point Breeze/Girard Point Engine IC-005 0.2 Diesel N/A N/A 2 N/A 2

Point Breeze/Girard Point Engine IC-006 0.8 Diesel N/A N/A 2 N/A 2

Point Breeze/Girard Point Engine IC-007 0.7 Diesel N/A N/A 2 N/A 2

Point Breeze/Girard Point Engine IC-008 1.5 Diesel N/A N/A 2 N/A 2

Point Breeze/Girard Point 11 Emergency Generators and

Fire Pumps 856 HP or less 3 Diesel
8 ULSD N/A N/A 2 N/A 2

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 oz one standard contains only caseby-case requirements for the emi ssions units identified as such in Table 3 above. Under 1-hour8 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 requir ements were required to have annual combustion tuning (CT). Some boilers and he aters have heat input caps in MMBTU/hr (as iden tified 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 combusti on units above 50 MMBTU/hr have lbs NOx/MMBTU limits, in some cases one num erical 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, re gular oil use by boilers and heaters wa s phased out of the facility by the end of 2010 as a requirement in a May 24, 2 005 Consent Decree between EPA, several states, the City of Philadelphia, and Sunoco, Inc. (C ivil Action No.05-02866). Wh ile 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 rem oval of the ability to burn oil for its 8-hour RACT. AMS is removing any limita tion for burning fuel oil in these boilers and heaters as part of the RACT SIP for PES.

Additionally, the following units we re subject to case-by-case re quirements 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 bei ng 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 un its and requesting that the applicable RACT requirements be removed from the SIP.

The following units were subject to presump tive RACT and have si nce been shut down:

 860 Heater 2H1

 860 Heater 2H6

 864 Heater PH2

 1332 Heater H-600 These are being listed for informational purpos es. No changes to the SIP are required.9 10/30/15 

### The following units were installe d 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 followi ng 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 revi sions 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 pe r 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 emergenc y 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 permitt ed after the 1-hour RACT approval.

The following incinerators and flares are contro l 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 su bject to the presumptive RACT requirements of 25 PA Code Sections 129.93(b)(2)-(5). An annual adju stment or tune-up shall be performed on each unit.

Each of the eleven emergency generators or fi re 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/St ate Operating Permit N o. V06-016 and must be installed, maintained, and operated in accord ance 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 In cinerator, North Flare, South Flare, Acid Gas Flare, SWS Flare, LPG Flare, Marine Vapor Recovery Un it, 1231/1232 Flare, 433 Flare, and 1232 FCCU CO Boiler. Each unit must be installed, maintain ed, 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 me ntioned 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 a nd 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 fo llowing control options ar e available, including estimated NOx reduction, and were evaluated:

 Ultra Low NOx Burners (ULNBs) and Sel ective 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 Reci rculation (FGR) – 55%

 SNCR – 40%

Control Device Descriptions:

 ULNBs and LNBs are burners de signed 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) r eact on the surface of the catalyst to form11 10/30/15 

### nitrogen (N2) and water (H20).

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

A summary of the available cont rols evaluated as RACT for th e 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 installe d 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 Cont rols 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 Infeasib le 3,151 9,998 Infeasible 13,921
Unit 860-2H2 CT Infeasible Infeasible In feasible Infeasible Infeasible 5,631
Unit 860-2H3 CT Infeasible Infeasible In feasible Infeasible Infeasible 9,552
Unit 860-2H4 CT Infeasible Infeasib le 2,999 16,808 Infeasible 6,641
Unit 860-2H5 CT Infeasible Infeasible In feasible Infeasible Infeasible 9,786
Unit 860-2H7 CT Infeasible Infeasible In feasible Infeasible Infeasible 12,605
Unit 864-PH1 CT Infeasible Infeasib le 9,528 7,796 Infeasible 11,045
Unit 864-PH11 CT Infeasible Infeasib le 12,967 9,070 Infeasible 1,898
Unit 864-PH12 CT Infeasible Infeasib le 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 13,22112 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 PE S RACT Update, the bluepr ints in Attachment B and AMS inspections show a lack of space to in stall SCR at the heaters located at Units 210, 860, and 864. The open space that is near these units is must remain ope n for emergency and maintenance vehicle access. Additionally, all of these heat ers have exhaust temperatures outside the 650 0 

### F to 780 0 

### 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 th e ductwork necessary for FGR at these units.

ULNB and LNB are technically infeasible fo r the Unit 860 Heaters 2H 2, 2H3, 2H5, and 2H7 because their fireboxes are not big enough to accommodate the longer flame length of these technologies. According to th e John Zink Combustion Handbook, LN Bs typically have a flame length of 0.8-2.5 feet per MMBTU capacity. Based on ULNB installa tions 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 st ates that the visible flame length shall be a maximum of two-thirds of the radiant section heig ht. These parameters cannot be met in these heaters.

For each boiler and heater, all additional NOx cont rols are either techni cally infeasible or economically unreasonable based on the current existi ng 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. Thes e 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 gas13 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 ULNB 1 0.035 lb NOx/MMBTU

Unit 870- Heater H02 53 N/A N/A ULNB 1 0.035 lb NOx/MMBTU

Unit 859- Heater 1H1 98 N/A N/A ULNB 1 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 ULNB 1 0.060 lb NOx/MMBTU for gas
Unit 1332 Heater H-2 60 Combustion Tuning 0.300 lb NOx/ MMBTU for gas ULNB 1 0.040 lbs/MMBTU

Unit 1332 Heater H-400 186 Combustion Tuning 0.156 lb NOx/ MMBTU for gas SCR 1 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 SCR 1 0.06 lb/MMBTU on a rolling 365-day basis

Unit 433 - Heater H-1 260 2 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 + FGR 1 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 + FGR 1 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 + FGR 1 0.040 lb/MMBTU on a rolling 365-day basis14 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 w ith reduction in NOx emission lim it in AMS Plan Approval 06050 dated December 4, 2006 and is being pr oposed 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 sha ll 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 lis ted 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. (match es 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 cataly st or to do maintenance to the SCR/air pre-heater system or to operate the heater s at low firing rate dur ing reformer catalyst regenerations, as per Plan Approval 09040. PE S 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 shal l 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 requi red to have NOx CEMS as part of the 1- hour RACT.

 Removal of all conditions referri ng 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. Un der 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 barrel s per day on a rolling 365-day average permit limit from AMS Plan Approval No. 00184 date d March 22, 2002 and a 50 ppmdv @ 0% oxygen on a rolling 365-day average lim it 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, althoug h it has not been appr oved 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 w ith a waste heat CO Boiler. It did not have any specific requirements under 1-hour RACT. It had SCR in stalled 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.

 LoTOx TM 

### – This technology works in conjunction with a wet scrubber. It is a selective, low temperature oxidation technology that uses ozon e 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 scrubbe r’s alkali reagent. Estimated 90% NOx control efficiency for FCCUs.16 10/30/15 

###  SNCR – Estimated 40% NOx cont rol efficiency for FCCUs.

SCR, SNCR, and LoTOx TM 

### were evaluated as evaluated as tec hnically feasible control options for the 868 FCCU.

Table 6 - Summary of NOx Contro ls Evaluated as RACT – FCCUs
Technical Feasibility and Cost Effectiveness ($/Ton) Source Existing Control SCR SNCR LoTOx TM

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 LoTOx TM 

### are all economically unreasonable for the 868 FCCU based on cost per ton of NOx controlled.

Since no NOx control is more effective than S CR 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% O 2 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% O 2 on a 7-day rolling average and 208.28 tons per rolling 365- day period



### The 100 ppmdv @ 0% O 2 

### 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 St udy" to comply with the Second Amendment of Civil Action No.05-02866 Consent Decree. The 30 ppmdv @ 0% O 2 

### 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-da y period limit come from the poten tial emissions in Table 1 for each unit, calculated as described above.

Conclusions and Recommendations: AMS determines that adding a 100 ppmdv @ 0% O 2 

### on a 7-day rolling average NOx limit and modifying the annual NOx limit to 130.2 tons per rol ling 365-day period sha ll be NOx RACT for the 1997 8-hour for Unit 868 FCCU. AMS determines th e existing SCR shall be NOx RACT for the 1997 8-hour ozone standard for Unit 1232 FCCU . In addition, a 30 ppmdv @ 0% O 2 

### 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 th e Unit 868 FCCU and the Unit 1232 FCCU.

B. VOC RACT

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

Table 8 – Summary of 1-hour a nd 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 practices18 10/30/15 1 The combustion units are the same boilers a nd 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 Nu mber 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 applicab le 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 b een 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 a pplicable 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 fac ility must conduct a m onitoring 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 §129.9319 10/30/15 

### equipment leaks. Under 1-hour case- by-case RACT, the facility must ha ve a quarterly leak detection and repair (LDAR) program for all valves, pumps, fl anges, 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 le ak standards, the quarterly LDAR program is being removed from the RACT plan approval.

Wastewater Treatment Plant Oil/W ater Separators are subject to 25 PA Code Section 129.55, which satisfies EPA’s CTG RACT requirements for the c ontrol of VOC emissions for VOC controls of refinery vacuum producing systems, wastewater se parators, and process tu rnarounds. In accordance with 25 PA Code Section 129.55, c ontainers, pumps, and compresso rs 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 ar e subject to 25 PA Code Sections 129.56 and 129.57, which satisfy EPA’s CTG RACT requirement s 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 cont rol device if the tank is greater than 40,000 gallons and a pressure relief valve meeting certain requ irements 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 orga nic materials with a RVP of 4.0 or greater are subject to the CTG RACT requirements of Air Manageme nt Regulation V, Section V. Lo ading organic materials with a RVP of 4.0 or greater requires a va por recovery system. Truck Load ing 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 determ ines that installing any c ontrol technology on such small sources is both technically a nd economically unreasonable.

ii. Presumptive RACT: Combustion units (boilers and heaters) with a ra ted 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 operati ng 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 MMB TU/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 ha ve not been demonstrated at refineries and are considered technically infeasible because the sulfur compounds f ound in refinery fuel gas poisons the catalyst. Most combustion uni ts at the facility have potentia l VOC emissions below 5 tons per
year.

Conclusions and Recommendations: AMS determines that there are no VOC RA CT controls for the combustion units.

Cooling Towers

The cooling towers emit fugitive VOC emissions wh en leaks in refinery heat exchangers allow VOCs to enter the cooling water streams and b ecome volatilized when the cooling water passes through the cooling towers. The potential emissions listed in Tabl e 2 were calculated using AP-42 emissions factors (AP-42 Table 5.1-2 for controlled em issions) and the circula tion rate of the units. The SIP-approved 1-hour RACT plan approval requi res 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 minimi zing leaks and monitoring cooling water for hydrocarbons. PES currently does this through the insp ection 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, freq uencies, 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 pr ogram for heat exchange systems required by 40 CFR 63, subpart CC shall be VOC RACT for th e 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 leve ls (potential VOC emissions are21 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 RA CT 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 exhaus t 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 c ontrolling the level of excess oxygen and CO promoter in the regenerator for NOx RACT, which al so 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 concentra tions to make CO boilers technologica lly 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 partia l-burn mode. A CO bo iler is not technically feasible for the Unit 868 FCCU because it is a fu ll-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 bo iler when in partialburn mode for Unit 1232 FCCU shall be VOC RA CT for the 1997 8-hour ozone standard. AMS determines that good combustion practices contro lling 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) pro cesses materials with a RV P of 4 psi or greater and is controlled by a thermal oxidizer (CD011, descri bed as a flare in the Title V operating permit) consistent with the requirements of 25 PA C ode Section 129.81. At the time of 1-hour RACT, the Point Breeze Marine Barge Loading (P636) processe d organic materials with an RVP of 4 psi or greater and consequently had a Marine Vapor Collection and Control Sy stem (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 materi als with a RVP of 4 psi or greater and the MVCACS has been shut down ( it was only required for thes e 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 su ch, these two sources were required to have a thermal oxidation/combustion unit installed with at least 90% VOC cap ture and destruction efficiency. In 2001, EPA has issued new RACT re quirements for marine vessel loading found in 40 CFR Part 60, Subpart Y that require a capture and destruction efficien cy 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 sin ce 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 contro l 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 Therma l 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 cons idered RACT for loading these mate rials at Girard Poinnt. Point Breeze Barge Loading is being given a limit to restri ct 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 un it. A condenser was determined technically feasible for Point Breeze Marine Loading, although the maximum VO C 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 Evalua ted 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



### A

l l c o n t r o l s f o r b o t h p r o c e s s e s w e r e d e t e r m i n e d t e c h n i c a l l y i n f e a s i b l e o r e c o n o m i c a l l y

u n r e a s o n a b l e

.

A M S d e t e r m i n e s t h e f o l l o w i n g r e q u i r e m e n t s t o b e R A C T :

G i r a r d P o i n t B a r g e L o a d i n g o f V O C m a t e r i a l s w i t h a R e i d V a p o r P r e s s u r e o f 4 p s i o r g r e a t e r s h a l l v e n t t o a T h e r m a l O x i d i z e r w i t h a V O C d e s t r u c t i o n e f f i c i e n c y o f a t l e a s t 9 8 % o r c o n t r o l t o a n o u t l e t o f 2 0 p p m v V O C o r l e s s

. T h e T h e r m a l O x i d i z e r s h a l l h a v e a c o n t i n u o u s t e m p e r a t u r e m o n i t o r a n d r e c o r d e r

.23 10/30/15 P o i n t B r e e z e M a r i n e B a r g e L o a d i n g s h a l l n o t l o a d a n y V O C m a t e r i a l s w i t h a R e i d V a p o r P r e s s u r e o f 4 p s i

o r g r e a t e r

. V O C e m i s s i o n s f r o m P o i n t B r e e z e M a r i n e B a r g e L o a d i n g s h a l l n o t e x c e e d 2 5

. 9 9 t o n s p e r r o l l i n g 1 2

- m o n t h p e r i o d

.



### The 20 ppmv VOC outlet concentration option has b een 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 altern ative 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 material s with a RVP of 4 psi or greate r. 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 Poin t Breeze Marine Barge Loading.

1 0 / 3 0 / 1 5



### Edward Wiener, Chief of Source Registration Date