1 Attachment 

Brenda,

 

The responses to your DIAL data questions are in the pdf attached. 

 

As stated in an earlier email, all confidential information will be sent as hardcopy to the address you provided. 

Please let me know if you need any further information.

 

Thank you,

Jerry C. Duke, Jr.

Environmental Team Leader, LDAR 

Texas City Refinery Direct: (409) 942-4883 Mobile: (409) 771-0751 

 

Responses to your questions regarding the TCEQ/BP DIAL Study Data 

Duke, Jerry 

to: 

Brenda Shine 

06/03/2009 07:36 PM 

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From: "Duke, Jerry" <Jerry.Duke@bp.com> 

To: Brenda Shine/RTP/USEPA/US@EPA 

History: This message has been replied to and forwarded. 

BP Texas City Dial Response.pdf

Page 1 of 1

file://C:\Documents and Settings\bshine\Local Settings\Temp\notes87944B\~web5012.htm 1/24/2013
BP Texas City Dial Response:

Questions 1-3 were answered during the meeting on 4/23/2009.

4) On the hydrocracker flare data and the temporary flare data you sent, there are 2 flare flow

tags. We assume the flows should be added together, is this correct?

Answer:

No, they were separate tags. Both of the ULC flare and the temporary flare were in operation

during the time of the DIAL study.

5) Can you provide the steam or air assist quantities for both flares during the test?

Answer:

The temporary flare was steam assist and we do not have steam data for the temporary flare.

This flare is no longer being used at the site.

ULC Flare – The steam peaks line up with Regen activities

MPPH – Thousand Pounds Per Hour

4 1 5 # S TM TO FL A R E

U L F2 1 9 3 .PV

M PPH

A d - H o c Tr e n d

8 /7 /2 0 0 7 1 2 :0 0 :0 0 A M 5 .0 0 d a y s 8 /1 2 /2 0 0 7 1 2 :0 0 :0 0 A M

2 0

3 0

4 0

5 0

6 0

7 0

1 0

8 0

2 0 .1 0 5

6) Can you provide the tip diameter for the hydrocracker and temporary flare and also, any

information/schematics on their design? For example, are there any tubes for steam/air assist

within the barrel of the tip?

Answer:

The Schematics will be mailed as confidential business information.
7) Can you provide emission estimates for these flares as reported in the 2007 EIQ and also the

permitted emission limits. Can you also provide supporting documentation for these estimates?

Answer:

Description EPN FIN

Reported

2007 VOC

(tpy)

Reported

2007 CO

(tpy)

Reported

2007 SO2

(tpy)

Reported

2007 NOx

(tpy)

Temporary Flare 396 TCH-DDU 860.41 388.91 47.73 106.89

ULC Flare 351A TCH-UC 136.20 131.60 36.58 13.81

The total emissions represented as part of the 2007 EI data include normal, continuous and

periodic streams and flows due to start-up, shutdown, and malfunctions. Additionally, the flows to

the temporary flare included the sweet hydrogen stream from the UU4 (as discussed in the EPA

presentation) while the electrical conversion of the 100-J compressor was taking place. The

temporary flare was authorized using a standard permit and registered with the TCEQ. The ULC

flare is authorized under the refinery Flex Permit 47256.
8) Can you provide material composition data for the tanks, VOC and HAP emission estimates as

reported in the 2007 EIQ and also the permitted emission limits. Can you also provide supporting

documentation for these estimates. (Maybe TANKS runs)?

Answer:

EPN FIN Reported 2007 VOC

(tpy)

Permitted VOC

(tpy)

280-1020 T280-1020 7.55

Permitted under

Flexible Permit

47256

280-1021 T280-1021 7.66

Permitted under

Flexible Permit

47256

280-1024 T280-1024 7.50

Permitted under

Flexible Permit

47256

280-1025 T280-1025 7.67

Permitted under

Flexible Permit

47256

280-1052 T280-1052 6.15 7.3

280-1053 T280-1053 5.51 7.3

280-1055 T280-1055 6.80

Permitted under

Flexible Permit

47256

280-127 T280-127 3.02

Permitted under

Flexible Permit

47256

280-128 T280-128 13.34

Permitted under

Flexible Permit

47256

280-22 T280-22 12.96

Permitted under

Flexible Permit

47256

280-23 T280-23 13.96

Permitted under

Flexible Permit

47256

280-53 T280-53 3.11

Permitted under

Flexible Permit

47256

280-55 T280-55 0.06

Permitted under

Flexible Permit

47256

280-56 T280-56 2.73

Permitted under

Flexible Permit

47256
Of note, all tanks that are permitted under the flexible permit do not have individual permit limits

assigned to each source. The permit limit is an overall hourly (lb/hr) and annual cap (tpy).

Additionally, the Tank 4.09 output file has been attached as an excel spreadsheet which is being

mailed as confidential business information.

Tanks 27, 28, and 29 are actually Tanks 127, 128, 129. These were discrepancies within the

DIAL report.

9) Can you provide VOC and HAP emission estimates as reported in the 2007 EIQ and permitted

emission limits for the wastewater treatment system. Can you provide supporting documentation

for these estimates (Maybe a WATER9 run)?

Answer:

Description EPN FIN

Reported

2007 VOC

(tpy)

Permitted

VOC (tpy)

ACTIVATED SLUDGE UNIT NO.

1

F-8 Status 30.28

ACTIVATED SLUDGE UNIT NO.2 F-9 BIO-2 30.28

Final Clarifier Tank No. 1 F-10 TK-F-10 0.23

FINAL CLARIFIER TANK NO. 2 F-11 TK-F11 0.23

CLARIFIER EFFLUENT TANK F-22 TK-F22 0.01

FCCU 3 FUGITIVES F-30 TK-F30 0.02

Permitted

under

Flexible

Permit

47256

Of note, these wastewater sources are permitted under the flexible permit and, therefore, do not

have individual permit limits assigned to each source. The permit limit is an overall hourly (lb/hr)

and annual cap (tpy).

An excel file that contains the water 9 output report for 2007 EI is being mailed as confidential

business information.