SUBJECT: Technical Support Document for Delaware’s Amendment to the Control of

Nitrogen Oxides Emissions from Industrial Boilers and Process Heaters of

Petroleum Refineries

FROM: Asrah Khadr, Engineering Trainee Ovs-teJix \/-\..&_h2& I’

Office of Air Program Planning

TO: File

(2c / /1’ THRU: Cristina Fernandez, Associate Office Director

Office of Air Program Planning

A. BACKGROUND:

On April 27, 2011, the Delaware Department of Natural Resources and Environmental Control(DNREC) submitted a revision to their State Implementation Plan (SIP) amending Section 2.0 of7 DE Admin Code 1142, Control ofNitrogen Oxides (NO) Emissions from Industrial Boilers

and Process Heaters at Petroleum Refineries (Regulation No. 1142). Section 2.0 of Regulation

No. 1142 serves to provide NO emission control limits per unit as well as to provide an optional

facility-wide NO emission limitation compliance alternative.

Delaware first promulgated Section 2.0 of Regulation No. 1142 in July of 2007. In November of2009, Section 2.0 ofRegulation No. 1142 was revised due to a settlement agreement betweenDNREC and Premcor Refining Group Inc. (Premcor); on June 6, 2010 (75 FR 31711), Section2.0 of Regulation No. 1142 was approved into Delaware’s SIP by Environmental Protection

Agency (EPA). In 2009, operations at the Delaware City Refinery ceased and in 2010 refinery

ownership changed from Premcor to the Delaware City Refining Company (DCRC). An

agreement regarding the acquisition, restart and operation of the Delaware City Refinery was

struck between the DNREC and DCRC, this created two changes in Delaware’s SIP. The

changes provide for NO emission control ofthe fluid catalytic cracking unit carbon monoxide(CO) boiler (Unit 23-H-3) at the Delaware City Refinery as well as an optional facility-wide NOemission limitation compliance alternative.

B. EPA REQUIREMENTS:

NOx is a precursor for ozone since it interacts with volatile organic compounds (VOCs) under

heat and sunlight to form ozone. EPA’s 1997 primary ozone national ambient air quality
NAAQS, Delaware is designated as nonattainment. An attainment demonstration SIP for the

1997 PM2,5NAAQS was submitted by DNREC to EPA in April 2008. The attainment

demonstration SIP for the 2006 PM25NAAQS is due in December 2012.

PM2,5also impairs visibility under the federal regional haze program. NO emissions from

Delaware significantly impact one federal Class 1 area, the Brigantine National Wildlife Area

located in New Jersey. In September 2009, DNREC submitted to EPA a Visibility SIP; this SIP

relies heavily on SO2reductions because SO2was classified by the Regional Planning

Organizations to be the primary cause of visibility impairment in Class I areas. There are some

NO reductions in the Visibility SIP to help insure that Delaware meets its 2018 visibility goals.

NO emissions also directly impact nitrogen dioxide (NO 2)concentrations. Delaware is currently

in attainment of the annual NO2NAAQS. Designations have yet to be made for the 2010 revised

NO2NAAQS.

C. STATE SUBMITTAL:

DNREC submitted impact analysis regarding the facility-wide compliance alternative; thisanalysis is included in the SIP revision. The facility-wide compliance alternative runs on a 12

month rolling basis, hence this could allow for higher daily or seasonal emissions. Thus,additional analysis is necessary to prove that all applicable NAAQS and requirements will be

met. Below is a summary of the analysis submitted by DNREC.

Section 2.3 of Regulation No. 1142 allows facility-wide emissions of 2,525 tons per year (tpy)

for any 12 month rolling period ending on or prior to January 2014; the emission limitation then

decreases to 2,225 tpy for the 12 month period between December 31, 2013 and December 31,

2014, and finally decreases to 1,650 tpy for the 12 month period between December 31, 2014and December 31, 2015 (the facility-wide emission limitation or unit specific limitations apply at

all times, there is no gap in NO emission regulations for the refinery). The 2002 emissions from

the Delaware City Refinery were utilized as baselines for the 1997 ozone NAAQS SIP, 2008

PM2,5NAAQS SIP and Delaware’s 2009 Visibility SIP. The 2008 emissions from the Delaware

City Refinery are the most current in Delaware’s emissions inventory. The Delaware City

Refinery’s projected emissions for 2009 are utilized in Delaware’s attainment demonstration

plans for the 1997 ozone NAAQS and 1997 PM2.5NAAQS. The refinery’s projected emissions

for 2012 and 2018 are utilized in Delaware’s 2009 Visibility plans. All of Delaware’s plansdemonstrate attainment by the mandated attainment date. All ofthe baselines and projections

utilized to demonstrate attainment in various SIP revisions for the state of Delaware are higher

2
Table 1. Actual and Projected NOx EmissionsYear NOx (tpy)

2002 (actual) 3,5552008 (actual) 2,5252009 (projected) 2,8552012 (projected) 2,761

2018 (projected) 2,774

Seasonal emissions changes were also analyzed to ensure compliance with all applicable

NAAQS and requirements. Monthly percent throughputs in the crude tank farm were analyzed.

Percent throughput directly correlates with utilization of the refinery. The years 2005-2008 were

analyzed and the analysis indicates that there is a slightly higher throughput during the ozoneseason months: May, June, July, and August. The 36-month average is 8.3% which has astandard deviation (stdev) of 0.7. It is concluded that throughput from the refinery is essentially

uniform year round; therefore the annual facility-wide emissions limitation is consistent with the

NAAQS along with other applicable requirements. Table 2 shows the crude tank farm percent

throughputs.

Table 2. Crude Tank Farm Throughput (%)

2005 2006 2007 2008

January 8.4 7.6 8.7 10.2February 7.6 8 6.7 8.3March 6.9 8.1 8.2 9.8

April 8.2 8.5 8.2 8.3May 9.4 8.7 8.7 7.8June 9.1 8.4 8.6 9.4

July 9.4 8.6 9 10August 8.8 8.8 8.8 10

September 9.5 8.5 7.8 10

October 8.4 8.5 8.7 10.1

November 6.7 8.2 8.2 39*

December 7.7 8.3 8.4 2.2*

3
applicable NAAQS and requirements. The daily average NOx emissions between January 2005

and December 2007 are within one stdev from the annual daily average, except for June 2005

where the daily average is 1.03 stdevs from the annual daily average. The minuscule standard

deviations indicate that there is little variability in daily NOx emissions, especially during timesof bad air quality; hence an annual facility-wide emissions limitation will not cause monthlyfluctuations considering that during normal operations, there are minimal NO emissions

fluctuations. Therefore, Delaware will continue to meet all applicable NAAQS and requirements

with the annual facility-wide emission limitation in place. Table 3 shows the daily average NOemissions.

Table 3. Daily &verage NOx emissions Tons Per Day (tpd)

2005 2006 2007

January 8.6 5.7 7.3February 8.7 8.4 7.4March 8.1 8.3 6.8

April 8.2 8 6.7May 8.3 8.3 6.2

June 8.8 7.9 6.8July 7.7 6.2 7.1

August 7 5.7 7.6

September 7.5 6.3 6.7

October 6 8.2 7.2

November 5 7.9 7.2

December 6.2 6.1 7.5

Single day emissions were also taken into consideration for analysis. The highest single day

emissions evaluated on a monthly basis for all units for years 2005, 2006, and 2007 wererecorded. In general, the months ofJune, July, and August tend to have the worst air quality.The highest daily NOx emissions from the refinery were generally outside this period in the three

years analyzed. The highest emissions occurred in October 2005, April 2006, and April 2007,

and exceeded the annual daily average plus one stdev. These months were the months where the

4
January 11 7.5 8.8February 9.8 9.4 9.1March 10.5 9.5 8.2

April 9.4 11.4 13

May 10.8 9.4 7.2

June 11.1 9.1 7.9July 9.6 7.8 8.6

August 8.5 7.1 8.9

September 9.4 8.1 8.1

October 11.3 10.2 8.9

November 6.5 10 9

December 8.3 7.2 8.6

Daily NO emissions were also analyzed for compliance with applicable NAAQS. The numberof days where daily NOx emissions exceeded the annual average plus one stdev was recorded.Out of the three years recorded, the highest number of days with exceedances within one month

was 9 which occurred in January 2007. Only in 7 out of the 36 months recorded did exceedances

plus one stdev occur more than five times per month. Also, the number of times the NOx

emissions exceeded one stdev from the annual daily average was constant from month to month

throughout the 36 months. The number of days in which exceedances of the annual average plusone stdev occurred is minuscule, showing that during normal operations at the refinery there arevery little fluctuations ofNO emissions, therefore the facility-wide compliance alternative

would continue to ensure compliance with all applicable NAAQS and requirements. Thenumber of exceedences plus one stdev per month is recorded in the Table 5 below.

5
May 4 5 4

June 6 5 4July 5 2 5

August 4 7 3

September 6 8 4

October 5 3 4

November 5 5 4

December 3 6 4

The facility wide emission limitation provided as a compliance alternative in Section 2.0 of

Regulation No. 1142 allows for NO emissions much less than the 2002 emissions baseline used

for the 1997 ozone and 1997 PM2.5attainment demonstration plans as well as the projections

utilized for the 1997 ozone, 1997 PM25,and 2009 visibility plans. Analysis of the submittal by

the DNREC also demonstrates that there are very little fluctuations ofNO emissions undernormal operation of the refinery. Therefore, the facility-wide NO emissions limitation

alternative provided by Section 2.0 of Regulation No. 1142 will not affect the attainment of all

applicable NAAQS and requirements.

E. CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

The revisions to Section 2.0 of Regulation No. 1142 will not affect Delaware’s ability to comply

with applicable NAAQS and requirements. Therefore, the revisions to this regulation stillmaintain environmental protection and public health. It is recommended that EPA approve the

aforementioned SIP revision.

D. EPA EVALUATION

6