Id 800264 Edgington Oil Company - Engr Eval An 383221

SOUTH COAST AIR QUALITY MA AGEME T DISTRICT E G EERI G A D COMPLIA CE APPLICATIO PROCESSI G A D CALCULATIO S
PAGES 37 APPL. O. 336128, 339741, 357907, 367625, 368878, 383221, 471236 PROCESSED BY
Johnny Pan Thomas Lee
PAGE 1 DATE 10/19/12 CHECKED BY
PERMITS-TO-OPERATE (PCs to POs) (Change of Condition) COMPA Y AME A D ADDRESS Edgington Oil Company 2400 E. Artesia Blvd. Long Beach, 90805 Contact : Rebecca Nolan (Envr. Engr) Telephone: (562) 748-4706 Email : rnolan@ppcla.com EQUIPME T LOCATIO Edgington Oil Company 2400 E. Artesia Blvd. Long Beach, 90805 Facility: 800264
EQUIPME T DESCRIPTIO Additions are noted in underlines. Deletions are noted in strikeouts. Section D of Facility Permit, ID# 800264 (The following equipment in P1/S5, P2/S8, P3/S4 and P7, will be moved from Section H to Section D of the facility permit.)
Equipment ID o. Connected RECLAIM To Source Type/ Monitoring Unit Emission* And Requirements Conditions
Process 1: DISTILLATIO PROCESS System 5: CRUDE U IT HEATER SYSTEM HEATER, VACUUM, H-201, D187 NATURAL GAS, 18 MMBTU/HR WITH A/N: 336128 Permit to Construct Issued: 02/13/98 BURNER, THREE (3), NATURAL GAS, JOHN ZINK, MODEL PSMR-16SP WITH VENT INSERTS AND PILOTS, WITH LOW NOX BURNER, 18 MMBTU/HR
NOX: LARGE SOURCE**
CO: 400 PPMV (5) [RULE 1146, 11-17-2000]; CO: 2000 PPMV (5A) [RULE 407, 4-21982]; OX: 37 PPMV (3) [RULE 2012, 56-2005]; PM: (9) [RULE 404, 2-71986]; PM: 0.1 GRAINS/SCF (5) [RULE 409, 8-7-
D328.1
PAGES 37 APPL. O. 336128, 339741, 357907, 367625, 368878, 383221, 471236 PROCESSED BY Thomas Lee
1981] PROCESS 2: ASPHALT OXIDIZI G SYSTEM 8: ASPHALT PROCESS HEATI G SYSTEM HEATER, SOUTH ASPHALT, H-53, D280 NATURAL GAS, 5 MMBTU/HR WITH A/N 357907 Permit to Construct Issued: 08/19/99 BURNER, NATURAL GAS, GORDON-PIATT, WITH LOW NOX BURNER, STEAM OR WATER INJECTION, 5 MMBTU/HR
NOX: LARGE SOURCE**
CO: 400 PPMV (5) [RULE 1146, 11-17-2000]; CO: 2000 PPMV (5A) [RULE 407, 4-21982]; OX: 37 PPMV (3) [RULE 2012, 56-2005]; PM: (9) [RULE 404, 2-71986]; PM: 0.1 GRAINS/SCF (5) [RULE 409, 8-71981]
D332.1 D328.1
PROCESS 3: TREATI G/STRIPPI G SYSTEM 4: REFI ERY FUEL GAS TREATI G SYSTEM
KNOCK OUT POT, D453, VENT GAS, HEIGHT: 6 FT; DIAMETER: 5 FT A/N: 367625 471236 Permit to Construct Issued: 10/04/00 SCRUBBER, PACKED BED, D455, CAUSTIC, PACKED BED, VENT GAS, HEIGHT: 20 FT; DIAMETER: 6 FT A/N: 367625 471236 Permit to Construct Issued: 10/04/00 KNOCK OUT POT, D404, HEIGHT: 6 FT; DIAMETER: 3 FT A/N: 367625 471236 Permit to Construct Issued: 10/04/00 SCRUBBER, PACKED BED, D402, CAUSTIC, PACKED BED, HEIGHT: 20 FT; DIAMETER: 6 FT A/N: 367625 471236 Permit to Construct Issued: 10/04/00 COMPRESSOR, C-202 A/B, OFF GAS, CENTRIFUGAL TYPE, 7. 5 H. P. A/N: 471236 Permit to Construct Issued: 11/15/07 FUGITIVE EMISSIONS, MISCELLANEOUS D19
S18.1, S31.1 C8.2, C8.3
D20
C8.2, C8.3
D201
D300
C8.2, C8.4
D295
H23.13
Dxxx
H23.13
A/N: 471236
PROCESS 7: STEAM GE ERATIO

BOILER, B-301, NATURAL GAS, FOSTER WHEELER TYPE D, 35 MMBTU/HR WITH A/N: 339741 Permit to Construct Issued: 07/21/98 BURNER, NATURAL GAS, GORDON PIATT WIND BOX LOW NOX BURNER, MODEL WDV-G-25-1FG, 35 MMBTU/HR BOILER/INCINERATOR, WASTE HEAT, B-501, NATURAL GAS, PROCESS GAS, REFINERY GAS, WITH LOW NOX BURNER, 26 MMBTU/HR WITH A/N: 368878 383221 Permit to Construct Issued: 09/27/00 BURNER, NATURAL GAS, REFINERY GAS, WITH LOW NOX BURNER, 26 MMBTU/HR D196 NOX: LARGE SOURCE** CO: 400 PPMV NATURAL GAS (5); CO: 2000 PPMV (5A) [RULE 407, 42-1982]; OX: 37 PPMV (3) [RULE 2012, 5-62005]; PM: 0. 1 GRAINS/ SCF (5) RULE 409, 8-71981] NOX: LARGE CO: 400 PPMV SOURCE **; (5A) [RULE 1146, SOX: MAJOR 11-17-2000] ; CO: 2000 PPMV (5) SOURCE PROCESS [RULE 407, 4-2UNIT 1982]; OX: 37 SUPER PPMV (3) 0.104 COMPLIANT LBS/MSCF (1) [RULE 2012, 5-6-2005]; PM: 0. 1 GRAINS/SCF (5) [RULE 409, 8-71981] ; SOX: 16.9 LBS/MMSCF (1) 0.0299 LBS/BBL (1) [RULE 2011, 56-2005] D328. 1
D38
A63.1, B61.2, C8.1, D28.1, D90.1, D297.1, D323.1, D328.1, H23.3, K40.1
Section D of Facility Permit, ID# 800264 The below permit for H3A/B (D179) in P1/S5 of Section D has been corrected to reflect the changes approved under A/N 309885 in 1996 for SOx Supercompliant status. In 2000, EOC submitted subsequent A/N 372730 to change the classification of D179 from SOx Supercompliant to Compliant under the Districts RECLAIM program but later cancelled the application in 2001. However, this change was made in FP by the permit engineer and was not rolled back after A/N 372730 was cancelled. This change should not be viewed as a relaxation of monitoring, recordkeeping or reporting requirements but as an administrative correction. Attachment 1 contains a copy of EOCs request letter to cancel A/N 372730 and Districts memo to file.
Equipment
ID o.
Connected To
RECLAIM Source Type/ Monitoring Unit
Emission* And Requirements
Conditions
Process 1: DISTILLATIO PROCESS System 5: CRUDE U IT HEATER SYSTEM HEATER, VACUUM, H3A/B, D179 NATURAL GAS, WITH LOW NOX BURNER, 20 MMBTU/HR WITH A/N: 309885
NOX: LARGE SOURCE**; SOX: MAJOR SOURCE**
CO: 400 PPMV(5) [RULE 1146, 11-172000]; CO: 2000 PPMV (5A) [RULE 407, 4-2-1982]; OX: 37 PPMV (3) [RULE 2012, 5-6-2005]; PM: (9) [RULE 404, 2-71986]; PM: 0.1 GRAINS/SCF (5) [RULE 409, 8-71981]; SOX: 16.9 LBS/MMSCF (1) [RULE 2011, 5-62005]
D328.1
CO DITIO S
S31.1 The following BACT requirements shall apply to VOC service fugitive components associated with the devices that are covered by application number(s) 408951 and 367625:
[Devices subject to this condition: D19, D20, D300, C376]
[Devices subject to this condition: D19, D20] C8.4 The operator shall use this equipment in such a manner that the flow rate being monitored, as indicated below, is not less than 15 gpm. The operator shall monitor the flow rate of the scrubbing solution twice a day
The operator shall maintain records in a manner approved by the District, to demonstrate compliance with this condition [RULE 3004(a)(4) Periodic Monitoring, 12-12-1997; 40CFR 60 Subpart J, 6-24-2008] [Devices subject to this condition: D300]
[Devices subject to this condition: D38, D187, D196, D280] D332.1 The operator shall determine compliance with the CO emission limit(s) by conducting a test at least once every five years using a portable analyzer and AQMD-approved test method or, if not available, a non-AQMD approved test method. The test shall be conducted when the equipment is operating under normal conditions to demonstrate compliance with CO concentration limits. The operator shall comply with all general testing, reporting, and recordkeeping requirements in Sections E and K of this permit. [RULE 1146, 11-17-2000; RULE 3004(a)(4)-Periodic Monitoring, 12-12-1997; RULE 407, 4-2-1982] [Devices subject to this condition: D280] Condition D332.1 has been deleted from the permit. Due to similarities with condition D328.1, device D280 is now tagged to condition D328.1 for streamlining purposes.
[Devices subject to this condition: D295, Dxxx] K40.1 The operator shall provide to the District a source test report in accordance with the following specifications: Source test results shall be submitted to the District no later than 60 days after the source test was conducted. Emission data shall be expressed in terms of lbs/MM cubic feet. [RULE 463, 5-6-2005] [Devices subject to this condition: D38]
COMPLIA CE RECORD REVIEW There are no outstanding compliance issues at Edgington Oil Company as of September 2012. The facilitys 5-year compliance history in CLASS data base shows the last NOV, issued in 2010, has been resolved.
Table 1 List of Edgington OVs Issued Since September 2007 Notice No. P53777 Notice Type NOV Violation Date 6/19/09 Status In Compliance Violation
OPERATION OF A PORTABLE AIR COMPRESSOR WITHOUT A VALID PERMIT.
BACKGROU D Edgington Oil Company (EOC) is a topping refinery located in the city of Long Beach that produces asphalt, which is sold as the primary product, and intermediate distillates which are
sold to other refineries for further processing into high value gasoline and diesel products. The refinery operates in a batch mode where it only operates to fulfill asphalt sales requirement and then shutdown until its inventory of asphalt is depleted. Because the refinery does not crack, hydrotreat or reform any crude oil fractions, it does not have the ability to produce large quantities of refinery/waste/flare gases which require large flare systems common in typical refineries. As such, there is no flare system at ECO but instead a waste heat boiler/incinerator that disposes the waste gases generated from its batch operation. The refinery is identified as a RECLAIM/Title V facility. The initial Title V permit was issued to EOC on October 1, 2009. In late 1995, EOC submitted change of condition applications 309884 and 309885 to reclassify its waste heat boiler/incinerator B-501 (D38) and vacuum charge heater H3A/B (D179) as Process Unit instead of Major Source under the District RECLAIM program pursuant to Rule 2011(c)(4). Under the provision of subparagraph (c)(4), which became possible only with the amendment of Rule 2011 on 9/8/95, EOC was able to be classified as a Supercompliant Facility because it has demonstrated the facilitys SOx emissions was at or below its adjusted 2003 SOx allocation as of their 1994 compliance year. As a Super Compliant Facility, the Major SOx sources at EOC may be reclassified as Process Units. This reclassification was suggested to EOC by the District as a way to avoid the costs of installing CEMS for these two devices, which was determined (by source test at the time) to emit only ~ 5 lbs/day of SOx and deemed not cost effective. The PCs, granting provisional Supercompliant status to D38 and D179, were issued in January 1996. Please see file 309884 for additional background information. Concurrently, around the same time frame in 1995, EOC also was granted POs 301529, 301530, 301527 to operate three of its combustion devices, heater H-201 (D187), boiler B301 (D196), heater H-53 (D280), to run exclusively on NG as part of the facilitys effort to attain SOx Supercompliant status. In the late 1990s, EOC submitted A/Ns 336128, 339741 and 357907 for D187, D196 and D280, respectively, to install low-NOx burners to comply with Rule 1146 NOx emissions limit. The PCs for D187, D196 and D280 were issued on 2/13/98, 7/21/98 and 8/19/99, respectively. Since the burner modifications for these combustion devices have been completed and source test results have demonstrated compliance with Rule 1146 limits and permit requirements, part of this evaluation is for PO issuance for D187, D196 and D280. A copy of the source test report and email response from EOC on the completion of the low-NOx burner installation are contained in the application folder of 336128, 339741 and 357907 for reference. In early 2000, EOC submitted applications 367625 and 368878 to secure permits to modify the refinery fuel gas treating system and B-501 to finalize its plan to attain SOx
Supercompliant status under the Districts Reg XX. The project entailed a change in the routing of the vacuum units tail gas from vacuum feed heaters H3A/B (D179) and H-201 (D187) to boiler/incinerator B-501 (D38) for disposal. As part of this project, two new compressors, C-202 A/B (D295), were installed under A/N 367625 to boost the vacuum units overhead gas pressure so the gas can be routed to the firebox of D38 for incineration. A/N 368878 was for modification of D38 to receive vacuum unit tail gas along with the other refinery fuel gases in the header system. PCs 367625 and 368878 were issued on 10/4/00 and 9/27/00, respectively. During this time, D38 had provisional supercompliant status under A/N 309884 and final supercompliant status was anticipated after construction is completed and the boiler is source tested. EOC notified the District on 6/7/02 that this project was completed and source tests have resumed to comply with the requirements to attain final supercompliant status for SOx. In 2001, change of condition A/N 383221 (subsequent to 368878) was submitted by EOC requesting to change the RECLAIM NOx emission factor for D38 from 37 ppmv to 81 ppmv to accurately reflect that it operates as a boiler/incinerator, operating at a minimum temperature of 1400F (pursuant to permit condition C8.1), and not a boiler/fired heater. Additionally, a change to the RECLAIM SOx emission factor from 16.9 lbs/MMScf to 0.0299 lbs/bbl (of feed) was requested based on initial source test pursuant to Rule 2011 (c)(4)(C). Part of this evaluation will cover the PO issuance for the modification of D38 under A/N 368878 along with the change in NOx/SOx emission factors and will be made under A/N 383221. A/N 368878 will be cancelled. Later in 2007, A/N 471236 (subsequent to 367625) was submitted by EOC to administratively change the description of compressors C-202 A/B (D295) to be identified as an off-gas compressor instead of a vent gas compressor. This administrative change was issued on 4/11/08 under PC 471236. Note that when PC 471236 was issued, only D295 was tagged with A/N 471236 instead of the entire permit unit (P3/S4) in Section H of the permit. This anomaly will be corrected under this PO evaluation and the entire permit unit will be tagged to A/N 471236 when it is moved to Section D of the facility permit. A/N 367625 will be cancelled. PERMIT HISTORY The permitting history of the affected permit units under this evaluation are summarized in the tables below:
Permit History for Vacuum Heater H-201 (D187) (A/ 336128) Permit to Construct No. Issue Date 284208 301529 336128 2/13/98 Permit to Operate No. Issue Date D76449 D89536 8/31/93 3/30/95 Description of Modification Change of Ownership. PAATs database shows no previous to this application. Modification to operate heater burning NG exclusively in effort to attain SOx Supercomplaint Facility status. Modification to install low NOx burner to comply with R1146 emission limit. EOC submitted this appl to remove the heater from provisional Supercompliant status on 8/8/00 but later cancelled this request on 4/19/01. A/N 372731 was cancelled.
372731
cancelled
n/a
n/a
Permit History for Boiler B-301 (D196) (A/ 339741) Permit to Construct No. Issue Date 165751 282428 301530 339741 7/21/98 Permit to Operate No. Issue Date M63613 D74412 D89537 5/26/88 6/21/93 3/30/95 Description of Modification Shown as a change of ownership application in PAATs database without any tracking information and no records in ONBASE. Change of ownership. Modification to operate heater burning NG exclusively in effort to attain SOx Supercomplaint Facility status. Modification to install low NOx burner to comply with R1146 emission limit.
Permit History for Heater H-53 (D280) (A/ 357907) Permit to Construct No. Issue Date C06535 165825 301527 Permit to Operate No. Issue Date P69289 M63674 D91217 1/19/77 5/31/88 3/30/95 Description of Modification No tracking information in PAATs database and no records in ONBASE. Shown as a change of ownership application in PAATs database without any tracking information and no records in ONBASE. Modification to operate heater burning NG
357907
8/19/99
exclusively in effort to attain SOx Supercomplaint Facility status. Modification to install low NOx burner to comply with R1146 emission limit.
Permit History for Refinery Fuel Gas Treating System (A/ 367625, 471236) Permit to Construct No. Issue Date C06547 165769 282438 Permit to Operate No. Issue Date P68437 11/19/76 M63628 D74422 5/27/88 6/21/93 Description of Modification No records in ONBASE. Shown as a change of ownership application in PAATs database without any tracking information and no records in ONBASE. Change of ownership. As part of the facility modification to attain final Supercompliant status, two new compressors were added to the refinery fuel gas treating system to boost the vacuum units overhead gas pressure so the gas can be routed to B-501 for disposal instead of previously sent to H3A/B and H-201. Administratively changed equipment description to correctly identify compressors are for off-gas, not vent gas.
367625
10/4/00
471236
4/11/08
Note that the tagging of conditions C8.2 and C8.4 to device D300 and the removal of conditions C8.2 and C8.3 from device D19 for this permit unit (P3/S4) are not new requirements, nor are they relaxation of monitoring requirements. These changes are now made to merely correct errors that were made (inadvertently removed C8.2, C8.4 from D300 and added C8.2, C8.3 to D19) by District permit engineer during the issuance of Sec H under revision #19 on June 3, 2011. It was when this permit unit had to be reinstated in Section H of the TV Facility Permit, as explained on Page 2 of the attached District cover letter to EOC dated June 3, 2011 (contained in Appendix A for reference), was when the tagging of these conditions were inadvertently made in error.
Permit History for Boiler/Incinerator B-501 (D38) (A/ 368878, 383221) Permit to Construct No. Issue Date 165745 Permit to Operate No. M63608 Issue Date 5/26/88 Description of Modification Change of ownership.
280295
D280295
4/16/93
309884
D95327
1/2/96
368878
9/27/00
383221
Change of ownership. Change of condition to reclassify B-501 as process unit under the provisions of Reg XX Supercompliant status for SOx. Provisional Supercompliant status was granted. As part of the facility modification to attain final Supercompliant status, D38 was modified to receive off gas from the vacuum units instead of previously routing it to H3A/B and H-201 for disposal. Application submitted to change RECLAIM NOx emission factor from 37 ppmv to 81 ppmv because factor reflects process heater instead actual operation as an incinerator.
APPLICATIO SUMMARY Table 6 below summarizes the applications and fees submitted by EOC:
Table 6
AQMD Applications and Fee Submitted A/ 336128 339741 357907 367625 368878 383221 471236 Equipment Description Heater Boiler Heater Fuel Gas Treating Boiler Boiler Fuel Gas Treating BCAT/CCAT 019003 011004 019003 354950 011604 011604 354950 Fee Schedule C D C D D D D Type Alteration Alteration Alteration Alteration Alteration Change of Condition Admin Change of Condition Status 26 26 26 26 26 20 26 Total Fee $1,214.30 $2,174.90 $1,265.80 $2,267.10 $2,267.10 $1,890.79 $489.20 $11,569.19 Total Fee Paid $1,214.30 $2,174.00 $1,265.80 $2,267.10 $2,267.10 $1,890.79 $489.20 $11,568.29
PROCESS DESCRIPTIO As mentioned, EOC is a topping refinery that produces asphalt from heavy local crude oils. Crude oil is fed to the atmospheric/vacuum units where it is separated into various fractions.
The overhead liquid fraction is sold to oil refineries for further processing into gasoline, diesel and jet fuel. The heavy bottoms are sent to the refinerys asphalt blowing (oxidizing) stills, where air is use to blow the asphalt at 400-500F to produce different consistencies of asphalt product for sale to the roofing and road paving industries. The light ends stream from the atmospheric/vacuum units, together with the fumes from the asphalt blowing plant, are now all routed through caustic scrubbers to the firebox of boiler/incinerator B-501 (D38) for disposal. Prior to modification of the facility to attain final SOx Supercompliant status, the offgas from the atmospheric/vacuum units was routed solely to the vacuum tower heaters, H3A/B (D179) and H-201 (D187), for disposal and B-501 (D38) was used to incinerate the gas fumes from the asphalt blowing plant. Post modification, the consolidation of the atmospheric/vacuum units offgas with the asphalt blowing plant fumes has enabled D179 and D187 to operate exclusively on NG, resulting in D38 being the only combustion device in the refinery that runs on Refinery Gas, Process Gas and NG. The simplified pre and post modification PFDs below summarize the changes made by EOC. Pre-Modification PFD o.1: H3A/B and H-201 for refinery fuel gas treating/disposal: In addition to the two heaters, caustic scrubber D-402 (D300), knockout drum D-404 (D201) and two ejectors EJ-202A/B (D301) were located on the two vacuum tower overhead systems upstream of the two heaters. PFD o.1 H3A/B and H-201
Vacuum Distillation Column T-3A/B (D3) KO Drum D404 (D201) Sour Gas Fuel Gas
Heavy Product Fuel Oil Asphalt
Caustic Scrubber D402 (D300)
Heavy Product
Process Heaters H3A/B, H-201 Vacuum Distillation Column T-201 (D10) Asphalt Sour Water to Waste Water Plant
Pre-Modification PFD o.2 - B-501 for asphalt blowing stills gas treating/disposal: Although B-501 treated a different type of emissions than process heaters H3A/B and H-201, both systems shared similarities. As with the H3A/B and H-201 system above, a caustic scrubber D-455 (D20) and knockout drum D-453 (D19) are installed upstream of B-501. Both control systems are designed for the removal of hydrogen sulfide with caustic solution to reduce SOx emissions. PFD o.2 B-501
Asphalt Blowing Still o.1 to o.6 Water Seal Pots D22, D27, D29, D31, D33, D36 Sour Gas Caustic Scrubber D455 (D20) Boiler/Incinerator B-501 (D38)
Fuel Gas
Air
Supplemental Fuel ( G)
Sour Water to Waste Water Plant Knockout Pot D37
Post Modification PFD: Combined Gas Treating/Disposal System: In its effort to attain final supercompliant status for SOx, EOC combined the above two systems into one system which allowed H3A/B and H-201 to run exclusively on NG and routed all refinery fuel gas to B-501 for disposal. This was accomplished by adding a new caustic scrubber D-522 (C376) to handle sour gas from the asphalt blowing stills and dedicating existing caustic scrubbers D20 and D300 (configured in series) to treat the offgas from the vacuum/atmospheric units instead of just D300. The reconfiguration resulted in an increase in pressure drop which required the installation of two new compressors to boost the pressure to 5 psig to enable the offgas to reach B-501. The new compressors (each rated at 7.5 HP) were installed under A/N 367625 as discussed. Under normal operations, only one compressor is in use while the other acts as a backup. In the event excess offgas is produced
from the vacuum units, both units would be in operations. Please see PFD No. 3 below for the combined system. PFD o. 3 Combined Gas Disposal and Emissions Control System
Air
ASPHALT BLOWI G STILLS O.1- O.6
D-522 Caustic Scrubber
ew Offgas Compressors C-202A/B Caustic Scrubber D-402 Blocked Valve, C*
BOILER/ I CI ERATOR B-501
Caustic Scrubber D-455 PROCESS HEATER H-201 ( G O LY) PROCESS HEATER H-3 A/B ( G O LY)
VACUUM DISTILLATIO COLUM S T-3A/B (D3) & T201 (D10) A D ATMOSPHERIC DISTILLATIO COLUM S O.1 & O.2
EMISSIO S An increase in fugitive emissions resulted from the addition of fugitive components associated with the new compressors C-202 A/B in the refinery fuel gas treating system. In additions, the emissions from H3A/B, H-201 and B-501 also changed with the change in fuel characteristic to these combustion devices as described earlier. However, the overall net emissions change from this entire project is minimal as shown below in Table 9. This PO emissions analysis takes into account the final (as-built) fugitive components actually installed and includes the concurrent emissions change for H3A/B and H-201, which was not accounted for during the PC evaluation.
A/ s 367625, 471236 (P3/S4) The emissions increase from project 367625 was estimated to be 2.4 lbs of ROG per day during the PC stage and are solely from new fugitive components. The emission factors used at the time were based on a memorandum from Jay Chen dated 4-2-99 for fugitive emissions that included BACT and LAER. Table 7 below summarizes the total pre and post project fugitive count and emissions calculation for this project using PC emission factors and also emission factors derived from the Correlation Equation Method. The PC emissions analysis is contained in Attachment 1, 2 and 3 of the PC 367625 evaluation. EOC provided ERC to offset the 1 lb/day increase during the PC stage and the modification complied with BACT.
Table 7 - Fugitive Emissions Summary Estimated Fugitive Emissions (PC Stage) VOC VOC Increase Increase (lbs/yr) (lbs/day) 514 1.4 9.09 0.03 Final Fugitive Emissions Count (As-built) VOC VOC Increase Increase (lbs/yr) (lbs/day) 1,620 4.4 580.2 1.59 Net Change (PC to PO) VOC (lb/day) 3.0 1.56
A/N
Process/System
367625
P3/S4
Using Correlation Equation Method*. See Appendix 1 for analysis.
*Since the issuance of the PC in 2000, the refinery permitting unit has adopted the Correlation Equation Method for calculating fugitive emissions pursuant to AQMDs Guideline for Fugitive Emissions Calculations (June 2003, Method 2). The emission factors derived from this method is believed to be more accurate than the emissions factors used during the PC stage. Therefore, fugitive emissions for this project were recalculated using this method for NSR update (see Attachment 2). As shown above, the PC emissions should be 0.03 lb/day instead of the 1.4 lbs/day that was entered in NSR during the PC stage. Since EOC has already provided 1 lb/day of ROG ERC during the PC stage using previous emission factors, EOC will only need to provide an additional 1 lb/day of ERC to offset the 2 lb/day (1.56 x 1.2 offset ratio = 1.87 = 2 lb/day) increase in fugitive ROG emissions using the Correlation Equation Method. As explained earlier, the entire permit unit (P3/S4) will be moved to Sec D of the facility permit under A/N 471236 (subsequent administrative PC to PC 67625) and A/N 367625 will be cancelled. A/ s 368878, 383221 for B-501 (D38) After combining the two systems, B-501 will now combust the refinery offgas portion that previously was combusted by H3A/B and H-201 and these two heaters will fire exclusively on
NG. Emissions calculations were based on the heat input balance provided by EOC during the PC stage and default emissions factors from AEIS, Appendix B. Basis: Natural Gas Heating Value = 1050 MMBtu/mmdscf Refinery Gas Heating Value = 1976 MMBtu/mmdscf
EMISSIO FACTORS1 (lb/MMScf) G 45.6 7.00 7.50 35.0 0.83 Refinery Gas 90.1 7.00 21.0 4.10 16.9
POLLUTA T
Ox ROG PM CO SOx
1
Based on AEIS Appendix B data HEAT I PUT2 Before Modification

Heater H-3 A/B Heater H-201 Waste Heat B-501 Heat Rating, MMBTU/Hr 20 18 26 % atural Gas 95.875 79.87 % Refinery Gas 4.125 20.13
After Modification
Heater H-3 A/B Heater H-201 Boiler/Incinerator B-501
2
Heater Rating, MMBTU/Hr 20 18 26
atural Gas 100 79.87
% Refinery Gas 0 20.13
Based on heat input balance from EOC. ote that PC emissions for B-501 were based on 75% G, 25% refinery gas and will be used in this evaluation for consistency.
Post-Modification Emissions Amount of refinery gas normally combusted by B-501 (pre-mod): = (26 MMBTU/Hr) (.25) / 1976 MMBTU/mmdscf = 3,289 scf/hr Amount of refinery gas diverted to B-501 from H3A/B and H-201: = (38 MMBTU/Hr) (0.04125) / 1976 MMBTU/mmdscf = 793.3 scf/hr Therefore, amount of refinery gas combusted by B-501 (post-mod): = 3,289 + 793 = 4,802 scf/hr = 0.0048 MMScf/hr @ 1976 MMBTU/MMScf Heat input for this refinery gas portion is 9.49 MMBTU/hr Therefore, the NG usage for B-501: = (26 9.49) MMBTU/Hr / 1050 MMBTU/MMScf = 0.0157 MMScf/hr B-501 emissions from NG portion: NOx = (0.0157 MMScf/hr) (45.6 lb/MMScf) = 0.72 lb/hr ROG = (0.0157 MMScf/hr) (7 lb/MMScf) = 0.11 lb/hr PM = (0.0157 MMScf/hr) (7.5 lb/MMScf) = 0.12 lb/hr CO = (0.0157 MMScf/hr) (35 lb/MMScf) = 0.55 lb/hr SOx = (0.0157 MMScf/hr) (0.83 lb/MMScf) = 0.01 lb/hr B-501 emissions from refinery gas portion: NOx = (0.0048 MMScf/hr) (90.1 lb/MMScf) = 0.43 lb/hr ROG = (0.0048 MMScf/hr) (7 lb/MMScf) = 0.03 lb/hr PM = (0.0048 MMScf/hr) (21 lb/MMScf) = 0.10 lb/hr CO = (0.0048 MMScf/hr) (4.1 lb/MMScf) = 0.02 lb/hr SOx = (0.0048 MMScf/hr) (16.9 lb/MMScf) = 0.08 lb/hr B-501 total emissions (post mod): NOx = 0.72 + 0.43 = 1.15 lb/hr ROG = 0.11 + 0.03 = 0.14 lb/hr PM = 0.12 + 0.10 = 0.22 lb/hr CO = 0.55 + 0.02 = 0.57 lb/hr SOx = 0.01 + 0.08 = .09 lb/hr H3A/B and H-201 emissions from NG operations (post mod): NOx = (38 MMBTU/Hr) (45.6 lb/MMScf) / 1050 MMBTU/MMScf = 1.65 lb/hr ROG = (38 MMBTU/Hr) (7 lb/MMScf) / 1050MMBTU/MMScf = 0.25 lb/hr PM = (38 MMBTU/Hr) (7.5 lb/MMScf) / 1050 MMBTU/MMScf = 0.27 lb/hr
CO = (38 MMBTU/Hr) (35 lb/MMScf) / 1050 MMBTU/MMScf = 1.27 lb/hr SOx = (38 MMBTU/Hr) (0.83 lb/MMScf) / 1050 MMBTU/MMScf = 0.008 lb/hr Total post-modification emissions from affected combustion devices B-501, H3A/B & H-201: NOx = 1.15 + 1.65 = 2.8 lb/hr ROG = 0.14 + 0.25 = 0.39 lb/hr PM = 0.22 + 0.27 = 0.49 lb/hr CO = 0.57 + 1.27 = 1.84 lb/hr SOx = 0.09 + 0.008 = 0.10 lb/hr Pre-Modification Emissions H3A/B and H-201 emissions from NG & refinery gas operations: NOx = (38 MMBTU/Hr) (0.959) (45.6 lb/MMScf) / (1050 MMBTU/MMScf) + (38 MMBTU/Hr) (0.041) (90.1 lb/MMScf) / (1976 MMBTU/MMScf) = 1.65 lb/hr ROG = (38 MMBTU/Hr) (0.959) (7 lb/MMScf) / (1050 MMBTU/MMScf) + (38 MMBTU/Hr) (0.041) (7 lb/MMScf) / (1976 MMBTU/MMScf) = 0.25 lb/hr PM = (38 MMBTU/Hr) (0.959) (7.5 lb/MMScf) / (1050 MMBTU/MMScf) + (38 MMBTU/Hr) (0.041) (21 lb/MMScf) / (1976 MMBTU/MMScf) = 0.28 lb/hr CO = (38 MMBTU/Hr) (0.959) (35 lb/MMScf) / (1050 MMBTU/MMScf) + (38 MMBTU/Hr) (0.041) (4.1 lb/MMScf) / (1976 MMBTU/MMScf) = 1.22 lb/hr SOx = (38 MMBTU/Hr) (0.959) (0.83 lb/MMScf) / (1050 MMBTU/MMScf) + (38 MMBTU/Hr) (0.041) (16.9 lb/MMScf) / (1976 MMBTU/MMScf) = 0.04 lb/hr B-501 emissions from NG & refinery gas operations (Recalculated because previous emissions under A/N 309884 used 1000 BTU/Scf instead of 1050 BTU/Scf for HHV of NG): NOx = (26 MMBTU/Hr) (0.75) (45.6 lb/MMScf) / (1050 MMBTU/MMScf) + (26 MMBTU/Hr) (0.25) (90.1 lb/MMScf) / (1976 MMBTU/MMScf) = 1.14 lb/hr ROG = (26 MMBTU/Hr) (0.75) (7 lb/MMScf) / (1050 MMBTU/MMScf) + (26 MMBTU/Hr) (0.25) (7 lb/MMScf) / (1976 MMBTU/MMScf) = 0.15 lb/hr PM = (26 MMBTU/Hr) (0.75) (7.5 lb/MMScf) / (1050 MMBTU/MMScf) + (26 MMBTU/Hr) (0.25) (21 lb/MMScf) / (1976 MMBTU/MMScf) = 0.21 lb/hr CO = (26 MMBTU/Hr) (0.75) (35 lb/MMScf) / (1050 MMBTU/MMScf) + (26 MMBTU/Hr) (0.25) (4.1 lb/MMScf) / (1976 MMBTU/MMScf) = 0.66 lb/hr SOx = (26 MMBTU/Hr) (0.75) (0.83 lb/MMScf) / (1050 MMBTU/MMScf) + (26 MMBTU/Hr) (0.25) (16.9 lb/MMScf) / (1976 MMBTU/MMScf) = 0.07 lb/hr
Total pre-modification emissions from affected combustion devices B-501, H3A/B & H-201: NOx = 1.14 + 1.65 = 2.79 lb/hr ROG = 0.15 + 0.25 = 0.40 lb/hr PM = 0.21 + 0.28 = 0.49 lb/hr CO = 0.66 + 1.22 = 1.88 lb/hr SOx = 0.07 + 0.04 = 0.11 lb/hr Table 8 Emissions Summary for B-501 Previous Emissions*, A/N 309884 Pollutant NG Ref Gas Total Total Total Total Total Total (lb/hr) (lb/hr) (lb/hr) (lb/day) (lb/hr) (lb/day) (lb/hr) (lb/day) NOx 0.72 0.43 1.15 27.6 1.66 39.8 1.14 27.4 ROG 0.11 0.03 0.14 3.36 0.17 4.1 0.15 3.6 PM 0.12 0.10 0.22 5.28 0.33 7.9 0.21 5.0 CO 0.55 0.02 0.57 13.68 0.54 12.8 0.66 15.8 SOx 0.01 0.08 0.09 2.16 0.19 4.6 0.07 1.68 *Recalculated emissions using HHV of 1050 BTU/Scf instead of 1000 BTU/Scf for G portion. Table 9 Emissions Summary for Project (Process Heater H3 A/B, H-201 and Boiler B-501) Post Modification PC to PO Emissions, A/N 368878 PC Emissions, A/N 368878 Pollutant NOx ROG PM CO SOx Post Modification Total (lb/hr) Total (lb/day) 2.80 67.2 0.39 9.36 0.49 11.76 1.84 44.16 0.10 2.4 Pre Modification Total (lb/hr) Total (lb/day) 2.79 67.0 0.40 9.60 0.49 11.76 1.88 45.12 0.11 2.64 Net change (lb/day) 0.20 -0.24 0 -0.96 -0.24
A/ s 336128, 339741, 357907 The installation of low NOx burners for heaters H-201 (D187), H-53 (D280) and boiler B-301 (D196) under applications 336128, 339741 and 357907, respectively, have been completed in accordance with the approved PCs and post modification source test results are summarized in Table 10 below. Compliance with rule and permit emissions limit for CO and NOx has been
verified. The full source test reports are contained in each respective application folder for reference. Table 10 Source Test Summary for H-201, H-53, B-301 Heater/Boiler Parameter/Condition ID NOx @ 3% O2 H-201 CO @ 3% O2 NOx @ 3% O2 H-53 CO @ 3% O2 NOx @ 3% O2 B-301 CO @ 3% O2 Units ppmv ppmv ppmv ppmv ppmv ppmv Results 21.16 9.87 30.40 91.13 24.26 4.14 Limits 37 400 37 400 37 400 Pass/Fail P P P P P P
EVALUATIO : PART 1 Rule 212 SCAQMD REGULATIO S Standards for Approving Permits ovember 14, 1997 The subject permit units in this evaluation met all criteria in Rule 212 for PC issuance and were expected to operate without emitting air contaminants in violation of Division 26 of the State H&SC or in violation of AQMD rules and regulations. Public notice was not required per Rule 212 because it was determined in the PC evaluations that: R212(c)(1) The subject permit units are well beyond 1000 feet from the outer boundary of a school. R212(c)(2) The emissions increase was determined to be well below the daily maximum specified in R212(g). Rule 212(c)(3) There was no increase in exposure to TAC such that the MICR is greater than 1 in a million.
The adjustment in fugitive emissions for the Refinery Fuel Gas Treating System (P3/S4) based on final fugitive counts (using the Correlation Equation Method) resulted in an increase of 2 lb/day of ROG from the PC stage, which is well below the 30 lb/day limit specified in R212(g). The recalculation of B-501 emissions from the rerouting of offgas from the vacuum units resulted in a decrease in emissions and the low NOx burner upgrade made to D187, D196 and D280 all resulted in a reduction of NOx emissions. Since the subject permit units
have all been modified in accordance with its approved PCs, with no emissions impact beyond R212(g) limits, the POs can be issued pursuant to R212(b). Rule 401 Visible Emissions ovember 9, 2001 Visible emissions are not expected under normal operating conditions. Compliance is expected. uisance May 7, 1976 Odor problems and nuisance complaints are not expected under normal operating conditions. Compliance is expected. Particulate Matter - Concentration February 7, 1986 The subject heaters, boiler and boiler/incinerator are subject to this rule, which specifies a maximum PM concentration limit for an exhaust gas flow rate calculated as dry gas at standard conditions. The firing rate, fuel type, HHV and PM emissions factor of the fuel used are listed below:
Device Rating, (MMBTU/Hr) Fuel Type HHV, (MMBTU/MMScf) 1050 1050 1050 1745 (1976 PM Emission Factor (lb/MMScf) 7.5 7.5 7.5 17.6 BTU/Scf, 21 lb/MMScf
Rule 402
Rule 404
H-201 (D187) 18 NG H-53 (D280) 5 NG B-301 (D196) 35 NG B-501 (38) 26 NG/RG* *25% G (1050 BTU/Scf, 7.5 lb/MMScf PM), 75% RG PM).
Based on these specifications, the maximum PM concentration for each device are calculated for comparison to the limits specified in Table 404a of this rule and the results are shown in Table 11 below. As shown, compliance with Rule 404 is expected for the subject combustion devices.
Table 11 Rule 404 Analysis Summary

Device D187 D280 D196 D38 Stack Temp*, Avg F 440 750 235 320 Calculated Exhaust Rate, (dscfm) 5,186 1,942 7,809 9,515 Rule 404 PM Concentrated Limit (grains/dscf) 0.101 0.145 0.086 0.081 Calculated PM Concentration (grains/dscf) 0.003 0.002 0.004 0.005
*Based on source test data. The following formulas and flue gas factor (F-factor) were used: F-factor dry = 8710 x , PM Rate, grain/hr =
,/ ,/, ,/

Exhaust Rate @ 3% O2, dscf/hr = (Rating, MMBTU/Hr) (F-factor, dscf/MMBTU ) (20.9/20.9-3) PM Concentration, grain/dscf = ,/
Rule 407 Liquid and Gaseous Air Contaminants April 2, 1982
,/
This rule limits carbon monoxide (CO) emissions to less than or equal to 2000 ppmv and gas/liquid sulfur compound emissions, calculated as SO2, to 500 ppmv. Pursuant to Rule 2001(j), Table 2, EOC does not need to comply with sulfur emissions limit of Rule 407 since it is a RECLAIM facility. The following table summarizes the CO emissions from the subject combustion sources based on the most recent source test submitted by EOC. The source test reports are contained in each respectively application folder for reference.
Device D187 D280 D196 D38 Test Date 1/29/07 12/31/08 1/30/06 8/13/02 CO concentration (ppmv @ 3% O2 9.87 91.1 4.14 232
Rule 407 Compliance is expected.

Rule 409 Combustion Contaminants August 7, 1981
The combustion devices are subject to District Rule 409 which specifies a PM emission limit of 0.1 grains/scf corrected to 12% CO2. The calculated PM emission rates are calculated as follow: PM, grain/scf =
,
, ,
x %
F-factor = 8710
Device D187 D280 D196 D38 Calculated PM Emissions, grain/scf 0.006 0.006 0.006 0.008
Compliance is expected.
Rule 431.1 Sulfur Content of Gaseous Fuels June 12, 1998
The subject devices are RECLAIM sources for SOx that are subject to Rule 2001. In accordance with Rule 2001(j), the requirement(s) pertaining to SOx emissions for the rules listed in Table 2 of Rule 2001(j) are not applicable to RECLAIM sources. Rule 431.1 is one of the listed rules. Therefore, this rule does not apply to the subject heaters, boilers and boiler/incinerator.
Rule 466 Pumps and Compressors February 6, 2009
The new compressors (C-202A/B) under this evaluation are subject to District Rule 1173. As such, they are exempt from the requirements of Rule 466 by the provision in (l)(3) of Rule 1173.
Rule 466.1 Valves and Flanges March 16, 1984
Fugitive components such as valves and flanges are subject to District Rule 1173. As such, they are exempt from the requirements of Rule 466.1 by the provision in (l)(3) of Rule 1173.
REG IX
40CFR 60,
SPS
Standard of Performance for Petroleum Refineries
Subpart J
With the exception of B-501, the other combustion devices (H-201, H-53, B301) under this evaluation are not subject to this subpart pursuant to 60.101(d) because they combust NG exclusively. In regards to B-501, conditions B61.2, D90.1 and H23.3 have been imposed to ensure compliance with Subpart J is met. Note that in lieu of complying with the requirements of 60.105(a)(3) to install CEMS to continuously monitor and record the SO2 emissions at the outlet or H2S content of the fuel gas at the inlet to ensure it meets the H2S limit of 0.10 gr/dscf in the fuel gas being combusted, EOC has obtained an approved Alternative Monitoring Plan (AMP) from the USEPA pursuant to 60.105(b) on May 30, 2006. Condition D90.1 has been tagged to B-301 to ensure this Subpart J requirement is met. Attachment 3 contains a copy of the approved AMP by EPA.
40CFR 60, Subpart GGG
Standard of Performance for Equipment Leaks of VOC in Petroleum Refineries
The modification to the refinery fuel gas treating system (P3/S4) with the addition of two new compressors, C-202A/B (D295), was designed and constructed in accordance with this NSPS. EOC has and will continue to follow the inspection, leak reporting and repair protocols described in this regulation as required by the tagging of condition H23.13 to D295 and Dxxx. Note that Dxxx is a new miscellaneous fugitive emissions device that was added to account for all the fugitive components that are part of this permit unit. Compliance is expected. REG X
40CFR 63, Subpart CC
ESHAP
ational Emission Standards for Hazardous Air Pollutants from Petroleum Refineries
EOC has provided data to the District to show that the Long Beach facility is not a major HAP source, which is defined as a source emitting 10 tons per year of any single HAP or 25 tons per year of all HAPs combined. As an area HAP source emitting less than these thresholds, the facility is not subject to any major source Maximum Achievable Control Technology (MACT) Standards, including 40CFR 63, Subpart CC, except for the reporting and recordkeeping requirements of 40CFR 61, Subpart FF National Emission Standard for Benzene Waste Operation. The Subpart FF requirements have been incorporated into the Title V permit as facility condition F16.1. Compliance is expected.
40CFR 63, Subpart A7
ational Emission Standards for Hazardous Air Pollutants for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing This rule limits PAH emissions to 0.003 lb/ton or PM emissions to 1.2 lb/ton of asphalt charged to the blowing stills at EOC. Pursuant to Table 4 of this subpart, ECO is utilizing B-501 to comply with this requirement and has indicated source test will be performed to demonstrate compliance as soon as asphalt blowing operations are resumed. According to an email from EOC dated 10/19/12 (contained in application folder), the facility has not blown asphalt since the compliance date of 12/2/10. The upcoming source test will verify whether the current combustion zone temperature requirement of 1400F set forth in condition C8.1 is sufficient to satisfy the monitoring requirement of 63.11563. Compliance is expected.
REG XI
Rule 1109 Emissions of Oxides of itrogen from Boilers and Process Heaters in Petroleum Refineries August 5, 1988
The subject heaters and boilers are RECLAIM sources for NOx and subject to Rule 2001. In accordance with Rule 2001(j), the requirement(s) pertaining to NOx emissions for the rules listed in Table 1 of Rule 2001(j) are not applicable to RECLAIM sources. Rule 1109 is one of the listed rules. Therefore, this rule does not apply.
Rule 1146 September 5, Emissions of Oxides of itrogen from Industrial, 2008 Institutional, and Commercial Boilers, Steam Generators, and Process Heaters Subparagraphs (1) to (3): The subject combustion devices under this evaluation have rated heat input capacities between 5 and 40 MMBtu/hr. However, as RECLAIM sources that are also subject to Rule 2001, the requirements of these paragraphs do not apply to these sources for NOx pursuant to Table 1 of Rule 2001(j). Subparagraph (4) : This rule limits carbon monoxide emissions from the heaters to less than or equal to 400 ppmv. Compliance with this 400 ppmv CO limit has been demonstrated by source tests as shown under Rule 407 discussion. Continued compliance is expected. Control of Volatile Organic Compound Leaks and Releases from Components at Petroleum Facilities and Chemical Plants February 6, 2009
Paragraph (c)
Paragraph (c)
Rule 1173
The new compressors and associated fugitive components (valves, flanges)
installed under A/N 367625 for modification of the refinery fuel gas treating system complied with BACT and the requirements of this rule. EOC will continue to follow the inspection, leak reporting and repair protocols described in this regulation as referenced by system condition S31.1. Additionally, new miscellaneous fugitive emissions device, Dxxx, has been added to this permit unit and tagged with condition H23.13 for Rule 1173 compliance. Continued compliance is expected. Reg XIII
Rule 1301
SR
December 7, 1995 General Paragraph (b) The combustion devices under this evaluation are RECLAIM sources for SOx Applicability and NOx that are subject to Rule 2001. In accordance with Rule 2001(j), the requirement(s) pertaining to SOx or NOx for the rules listed in Tables 1 and 2 are not applicable to RECLAIM sources. Reg XIII is one of the listed rules. Therefore, the requirements specified by this regulation apply to criteria pollutants other than SOx and NOx.
A/N 368878, 383221 (for B-501) During the PC stage for B-501 under A/N 368878 [see PC evaluation dated 9-2000 by ET01 in application folder], it was calculated an increase in ROG, CO and PM emissions was expected but the increases were exempt from the offsets and modeling requirements of Reg XIII pursuant to Rule 1304(c)(4). However, during this PC to PO evaluation, it was discovered that the baseline emissions calculation for A/N 368878 (from previous A/N 309884) used a different HHV value (1000 instead of 1050 BTU/Scf) for NG. Hence, a recalculation of the emissions impact from this project was conducted along with the concurrent emissions change for H3A/B and H-201, which was not accounted for during the PC evaluation. As shown in Table 8 on page 24 of this evaluation, there is no increase in ROG, CO and PM emissions as a result of the modification to B-501. Note that the increase of 0.28 lb/day in PM from baseline (previous A/N 309884) does not constitute a true emissions increase pursuant to Reg XIII (because it is less than 1.0 lb/day). Hence, no offsets and modeling are required. Table 9 on page 24 shows the overall emissions impact from the three affected device for this entire project (of rerouting the offgas to B-501 from H3A/B and H-201) to be negligible. A/N 336128, 339741, 357907 (for H-201, B-301, H-53, respectively) As RECLAIM sources under Rule 2001, only criteria pollutants ROG, CO and
PM emissions are subject to Reg XIII. Nonetheless, this regulation is not applicable because the modification to retrofit the headers and boiler with BARCT (low NOx burner) resulted in an overall emissions decrease for NOx and no change in emissions for SOx, ROG, CO and PM. Therefore, Reg XIII requirements (BACT, offset and modeling) for ROG, CO and PM are not applicable. A/N 367625, 471236 (for C-202A/B in P3/S4) EOC complied with the requirements of Reg XIII by installing all bellow seal valves (BACT) for this project and providing ERC to offset the ROG fugitive emissions increase during the PC stage (see PC 367625 evaluation in application folder). Post modification emissions from the addition of C-202A/B in P3/S4 resulted in a 1.56 lb/day increase from the PC stage as shown in Table 7 on page 20 of this evaluation. Using a 1.2 offset ratio pursuant to Rule 1303(b)(2)(A), the facility needs to provide 2 lb/day of EOC to offset this increase in ROG emissions for PO issuance. PO emissions were based on final fugitive component count by EOC. As discussed in the Emissions section of this evaluation, the change in methodology in calculating emissions (using the Correlation Equation Method) resulted in ROG emissions of 0.02 lb/day instead of 1.4 lb/day in the PC stage. EOC only needs to provide 1 lb/day of ROG ERC now since they already provided 1 lb/day of ROG ERC during the PC stage. Reg XIV
Rule 1401 SR of Toxic Air Contaminants September 10, 2010
There is no increase in ROG emissions for the heaters, boiler and boiler/incinerator from PC to PO under this evaluation. However, there is a small increase in ROG emissions of 0.19 lb/day from the PC stage for the addition of two new compressors for the refinery fuel gas treating system under A/N 367625. This is because post modification emissions, based on final fugitive component count from EOC, is 1.59 lbs/day (using Correlation Equation Method) and the PC emissions was calculated as 1.4 lb/day (using Jay Chen emission factors). The 0.19 lb/hr increase in ROG is expected to increase TAC emissions proportionately. Therefore, post modification TAC emission can be estimated from the TAC emissions calculated during the PC stage, which was 0.0044 lb/yr for Benzene (based on 3 ppm concentration in the offgas stream from applicants
lab analysis). The following calculations show post modification TAC emissions to be 0.005 lb/hr, which is significantly less than the most conservative Tier 1 Screening Emissions Level of 1.14 lb/yr for Benzene at 25 meters. The Tier 1 screening levels can be found in Table 1A of Attachment F, Version 6.0 (for applications deemed complete date of 8/13/99 thru 8/17/00) of Rule 1401s Risk Assessment Procedures. Compliance is expected and no further screening risk assessment is necessary. % Increase in TAC (Benzene) emissions =
. / . /
= 13.5%
Post modification TAC (Benzene) emissions = 1.135 x 0.0044 lb/yr = 0.005 lb/yr Reg XX
Rule 2005 SR for RECLAIM June 3, 2011
EOC is designated as a NOx and SOx RECLAIM facility. Since there is no increase in NOx and SOx emissions for B-501, H3A/B and H-201 as shown in Emissions section of this evaluation and no increase for H-53, B-301 and H-201 from the modification to retrofit with low NOx burners, the provisions of this rule do not apply. Note that the project to install C-202A/B under A/N 367625 and subsequent admin A/N 471236 have no bearing on NOx and SOx emissions.
Rule 2011 Paragraph (c) Requirements for Monitoring, Reporting, and Recordkeeping for Oxides of Sulfur (SOx) Emissions May 6, 2005
Subparagraph (4): This subparagraph of the rule allows facilities who meet specific requirements to attain approval from the District for SOx super compliant status. Such classification would enable its major source to be redesignated as process unit for SOx pursuant to Rule 2011(c)(4)(A)(i). This change in designation would exempt the source from having to install CEMS to monitor SOx emissions. Background Recap As explained in the background section of this evaluation, EOC filed for this supercomplaint status by submitting an application in 1995 for H3A/B and B501. Both were granted provisional supercompliant status at the time the applications were approved. It was expected that after modification of B-501 (to receive the vacuum offgas which previously was sent to H3A/B and H-201 for disposal under subsequent A/N 368878) was completed and source tested, final
supercompliant status would be granted. While final supercompliant status was still pending, EOC submitted subsequent A/N 383221 to change the NOx RECLAIM emissions limit listed in the permit from 37 ppm to 81 ppm. This request was made because the 37 ppm limit listed in the permit does not reflect the operation of the unit as an incinerator but that of a process heater . Please see ECO letter submitted with A/N 383221 dated March 2, 2001 and follow-up letter from ECO dated September 13, 2004 in Attachment 3. The following subsections give the applicable requirements that must be met by ECO to gain final approval from the District for Supercompliant status of B-501. Subsection (A)(i): This subsection requires a facilitys reported SOx emissions to be already at or below its 2003 SOx allocation as of compliance year 1994 and an application be submitted to the District for Supercompliant status no later than December 2, 1996. As summarized below, ECOs SOx APEP emissions are below its 2003 SOx allocation (13,900 lbs/yr) as of 1994 and A/Ns 309884 and 309885 were submitted by EOC on December 13, 1995 for B-501 and H3A/B. Compliance Year 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 EOCs SOx APEP Emissions*, (lbs/yr) 100 783 745 1,091 1,773 3,737 4,103 13,568 8,871 7,209 13,473 13,463 7,258 5,787 4,360 1,107 161 6 SOx Emissions RTC Allocations, (lbs/yr) 18,257 18,257 18,257 18,257 18,257 18,257 18,257 16,805 15,352 13,900 13,900 13,900 13,900 13,900 13,900 13,900 13,900 13,900
*Data provided by Districts RECLAIM Admin Team (Don guyen and Susan Tsai).
Information is contained in A/ 383211 folder for reference.
Compliance of this subsection for Supercompliant status is met. Subsection (A)(ii): Pursuant to the requirements of this subsection, EOC conducted source tests in accordance to subsection (C) of this rule to establish an equipment specific emission rate for B-501. An emission rate of 0.0299 lbs SOx/bbl asphalt feed has been established and will be incorporated in the permit as part of the PO issuance for B-501 under A/N 383221. The Districts evaluation of the source tests conducted from 1998 through 2003 to establish this equipment specific emission rate is contained in Attachment 4 for reference. Additionally, the facilitys total annual SOx emissions as reported under APEP has not exceeded its adjusted compliance year 2003 Allocation of 13,900 lbs/yr as shown above. Compliance with this subsection has been met and final Supercompliant status for B-501 is recommended. Note that subsequently in October 2005, EOC requested the emission rate be adjusted to 0.01 lbs SOx/bbl feed to reflect the addition of a new caustic scrubber upstream of B-501 to treat the AB product fumes for H2S removal in an effort to further reduce SOx emissions. Source test data was provided to STE but no official approval has been made yet. In the event EOC is granted approval of a new emission rate for B-501 by District STE, a permit application will need to be submitted to incorporate this change in the permit. Subsection (D): The requirement to conduct minimally annual source test to maintain SOx Supercomplaint status has been incorporated in the permit by the tagging of condition D297.1 to B-501. Compliance is expected.
Rule 2012 Paragraph (d) Requirements for Monitoring, Reporting, and Recordkeeping for Oxides of itrogen ( Ox) Emissions May 6, 2005
Paragraph (f)
Subparagraph (2): B-501 is classified as a NOx large source in EOCs Title V facility permit. The provision of this subparagraph allows facilities of large NOx sources to use different approved alternatives to monitor and report NOx emissions. The current approved method listed in EOCs permit for B-501 is a stack NOx concentration limit of 37 ppm, which is typical for a process heater/boiler as referenced in Rule 2002, Table 1. Subparagraph (3): Through the submittal of application A/N 383221, EOC has requested the stack NOx concentration limit be raised to 81 ppmv to more accurately reflect the operation of B-501 as an incinerator instead of a boiler. As noted in the Background section of this evaluation, EOC does not have a flare
system at its facility to combust the vent gases from its operation but instead route the gases to the firebox of B-501 for disposal. Hence, B-501 operates at a much higher temperature (> 1400F) as compared to process heaters/boilers and NOx emissions is therefore expected to be much higher. As truly an incinerator and not a boiler, EOC proposes to reclassify the unit as such and use the RECLAIM emission factor of 0.104 lbs NOx/MScf (equivalent to ~81 ppmv concentration limit) fuel gas consumed in the unit as referenced in Rule 2002 for incinerators. Attachment 5 is a copy of Table 1 from Rule 2002 for reference. As required under subparagraph (3) of Rule 2012 (f), EOC has conducted source test to demonstrate the proposed emission factor of 0.104 lbs NOx/MScf is reliable, accurate and representative for the purpose of calculating NOx emissions. Attachment 6 contains the source test summary for the test conducted on March 27, 2001. The full report is contained in application folder 383221 for reference. Compliance is expected and reclassification of B-501 as incinerator with NOx RECLAIM emission factor of 0.104 lbs NOx/MScf fuel gas consumed is recommended. Reg XXX
Rule 3002 Requirements ovember 14, 1997
EOC has been designated as a Title V facility. The initial Title V permit was issued on October 1, 2009. Per AQMD guidelines for Title V permits, the redesignation of B-501 as a Process Unit under the Districts RECLAIM program with new SOx emission factor (pursuant to Rule 2011(c)(4)(A)(ii)(C) discussed above) and new emissions factor for NOx (from the reclassification of B-501 as an incinerator) constitute a Minor Title V permit revision. Therefore, a copy of the proposed permit and engineering evaluation will be submitted to EPA for review. Please note that the RECLAIM redesignation for B-501 is not a relaxation of monitoring/reporting requirements since B-501 was already granted provisional Supercompliant status (without having to install CEMS) and the current permit action is merely to grant final Supercompliant status after the facility has demonstrated compliance with Rule 2011(c). Continued compliance is expected. The issuance of PO (from PC) for the two compressors in the refinery fuel gas
treating system and low NOx burner installation for D187, D196 and D280 qualifies as Administrative Revision as they meet the definition pursuant to Rule 3000(b)(1)(D), which includes the issuance of a final PO for equipment previously issued a PC, with no change in permit terms and conditions. For administrative revisions, AQMD does not need to notify the public nor the EPA prior to permit issuance. However, AQMD is required to submit a copy of the permit revision to EPA within five (5) days of issuance. Compliance is expected. STATE REGULATIO S
CEQA
California Environmental Quality Act CEQA requires that the environmental impact of proposed projects be evaluated and that feasible measures to reduce, avoid or eliminate identified significant adverse impacts be considered. The CEQA Applicability Form (400-CEQA) submitted by the applicant indicated the projects under this evaluation do not have any impacts which would trigger the preparation of a CEQA document. Hence, CEQA analyses are not required.
CO CLUSIO Based on this evaluation, the subject permit units under this evaluation are expected to operate in compliance with all AQMD, State and Federal Rules and Regulations. Therefore, Permits to Operate are recommended with the conditions listed on pages 4 through 11 of this evaluation. The following is a summary of the permit actions under this evaluation:
A/N * 336128 339741 357907 367625 368878 383221 471236 Equipment Description Title V Permit Revision Heater, Vacuum, H-201, NG, 18 MMBTU/HR, with Low NOx burner Boiler, B-301, NG, Foster Wheeler Type D, 35 MMBTU/HR, with Low NOx burner Heater, South Asphalt, H-53, NG, 5 MMBTU/HR with low NOx burner Refinery Fuel Gas Treating System Boiler, Waste Heat, B-501, NG, PG, RG, 26 MMBTU/HR with low NOx burner Boiler/Incinerator, Waste Heat, B-501, NG, PG, RG, 26 MMBTU/HR with low NOx burner Refinery Fuel Gas Treating System Device ID N/A D187 D196 D280 All D38 D38 All Recommended Action Approve Approve PO Approve PO Approve PO Cancel and incorporated changes under A/N 471236 Cancel and incorporated changes under A/N 383221 Approved PO with changes from A/N 368878 Approve PO with changes from A/N 367625
*Pending submittal by EOC.

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SOUTH COAST AIR QUALITY MA AGEME T DISTRICT E G EERI G A D COMPLIA CE APPLICATIO PROCESSI G A D CALCULATIO S

PAGE 1 DATE 10/19/12 CHECKED BY

NOX: LARGE SOURCE**

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NOX: LARGE SOURCE**

S18.1, S31.1 C8.2, C8.3

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PROCESS 7: STEAM GE ERATIO

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RECLAIM Source Type/ Monitoring Unit

Emission* And Requirements

NOX: LARGE SOURCE**; SOX: MAJOR SOURCE**

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[Devices subject to this condition: D19, D20, D300, C376]

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Heavy Product Fuel Oil Asphalt

Caustic Scrubber D402 (D300)

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Sour Water to Waste Water Plant Knockout Pot D37

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ASPHALT BLOWI G STILLS O.1- O.6

D-522 Caustic Scrubber

ew Offgas Compressors C-202A/B Caustic Scrubber D-402 Blocked Valve, C*

BOILER/ I CI ERATOR B-501

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Using Correlation Equation Method*. See Appendix 1 for analysis.

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Based on AEIS Appendix B data HEAT I PUT2 Before Modification

Heater Rating, MMBTU/Hr 20 18 26

atural Gas 100 79.87

% Refinery Gas 0 20.13

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Table 11 Rule 404 Analysis Summary

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Rule 407 Compliance is expected.

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40CFR 60, Subpart GGG

Standard of Performance for Equipment Leaks of VOC in Petroleum Refineries

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40CFR 63, Subpart A7

The new compressors and associated fugitive components (valves, flanges)

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NOX: LARGE SOURCE; SOX: MAJOR SOURCE