Prepared for: BP-Husky Refining LLC 4001 Cedar Point Road Oregon, Ohio Prepared by:

Transcription

1 BP-HUSKY REFINING LLC REVISION TO FCCU WET GAS COMPRESSOR RECONSTRUCTION PERMIT TO INSTALL ( ) TO INCORPORATE FINAL FCCU NO X EMISSIONS LIMITS Prepared for: BP-Husky Refining LLC 4001 Cedar Point Road Oregon, Ohio Prepared by: URS Corporation Waterfront Plaza Tower One 325 West Main Street, Suite 1200 Louisville, Kentucky URS Project No January 11, 2010

2 BP-HUSKY REFINING LLC FCCU FINAL NO X EMISSIONS LIMIT REVISED PTI Prepared For: BP-Husky Refining LLC 4001 Cedar Point Road Oregon, Ohio Prepared by: URS Corporation Waterfront Plaza Tower One 325 West Main Street, Suite 1200 Louisville, Kentucky Ph This document was prepared and reviewed by the following key URS Personnel: Project Manager Date: January 11, 2010 Mary Stuart Peace, P.E. Principal in Charge Date: January 11, 2010 Todd P. Royer, P.E.

3 Table of Contents Page Executive Summary... iii 1.0 Details of Final FCCU NOx Limits Permit Application Forms Appendices Appendix A: November 6, 2009 EPA Letter Establishing NOx Limits i 1/11/10

4 Acronyms and Abbreviations BP-Husky Consent Decree EAC FCCU NO X OAC OEPA ppmvd PTI U.S. EPA BP-Husky Refining LLC United States and State of Indiana, et al. v. BP Exploration & Oil Co., et al., Civil No. 2:96 CV 095 RL (N.D. Ind.). Emissions Activity Category Fluidized Catalytic Cracking Unit oxides of nitrogen Ohio Administrative Code Ohio Environmental Protection Agency Parts per million vapor (dry basis) Permit to Install United States Environmental Protection Agency ii 1/11/10

5 Executive Summary This permit application requests a revision to PTI (issued 9/18/2007) in order to incorporate the final NO x emissions limits on BP-Husky s fluidized catalytic cracking unit (FCCU, OEPA ID P007). These limits are requested to formally establish the short-term and long-term NOx emissions limits for the Toledo FCCU pursuant to Paragraph 14 of the Consent Decree entered in United States and State of Indiana, et al. v. BP Exploration & Oil Co., et al., Civil No. 2:96 CV 095 RL (N.D. Ind.). PTI is the most recent permit to install addressing BP-Husky s FCCU and was issued on September 18, 2007 for the reconstruction of a wet gas compressor at the FCCU. This PTI included all of the requirements for the FCCU that have been established for this emissions unit. On November 6, 2009, BP-Husky received a letter from the United States Environmental Protection Agency (U.S. EPA) that formally established the long-term and short-term NOx limits for the subject FCCU pursuant to Paragraph 14 of the Consent Decree. Appendix A includes a copy of U.S. EPA s letter. In Summary, the NOx emissions limits are as follows: 58.1 ppmvd 0% O 2 on a 365-day rolling average 93.4 ppmvd 0% O 2 on a 7-day rolling average basis Certain alternative scenarios and exceptions do apply Compliance with these emissions limits is required beginning December 1, 2009 and details of specific compliance requirements are outlined in the following sections. In accordance with the Consent Decree pursuant to Paragraph 26, BP-Husky is required to file an application requesting a revision to any applicable permits, including any new emissions limits established pursuant to Paragraph 14. Accordingly, BP-Husky requests that the new short and long-term NOx emissions limits be incorporated into the existing PTI ( issued 9/18/07) governing the operations of the FCCU (P007). Revised Ohio PTI forms were completed in Ohio EPA s web-based Air Services program. Once the revised PTI has been issued, BP-Husky will submit a Minor Permit Modification (MPM) to implement these limits into their Title V Permit (Facility ID ). This PTI revision application details the necessary revisions iii 1/11/10

6 1.0 Details of Final FCCU NOx Limits The final long-term and short-term NOx limits for the BP-Husky Toledo FCCU were established in the November 6, 2009 letter from U.S. EPA. A copy of this letter has been included in Appendix A of this application for reference. The compliance requirements for the short and long-term NOx limits are specific and depend on the operating scenario at the FCCU. Based on the conditions of the actual NO x emissions limits established in the November 6, 2009 letter, BP-Husky proposes the following language to be included in the revised permit to install: Final Long-Term FCCU NOx Limit (1) Final Long-Term NOx Limit: Beginning no later than December 1, 2009, BP- Husky shall comply with a long-term limit of 58.1 ppmvd 0% 0 2 on a 365- day rolling average basis. This long-term limit shall apply at all times when the FCCU is operating, including during periods of startup, shutdown and malfunction. The limit also shall apply during periods of scheduled maintenance of equipment other than the FCCU. (2) Alternate Operating Scenario: (a) For no more than 20 days over a rolling 2-year (730-day) period, when the CO boiler is operating and the FCCU is down, the long-term limit shall not apply if BP-Husky elects to retire NOx allowances to account for NOx emissions (in tons or portion thereof) that occur on any such days. BP-Husky must retire said NOx allowances at a: rate of not less than 1.5 to 1. (b) A "NOx Allowance" means an authorization or credit to emit a specified amount of NOx that is allocated or issued under an emissions trading or marketable permit program that has been established under the Clean Air Act. (c) For all NOx Allowances to be surrendered pursuant to Paragraph 2(a), BP- Husky shall first submit a NOx Allowance transfer request form to U.S. EPA s Office of Air and Radiation s Clean Air Markets Division directing the transfer of such NOx Allowances to the U.S. EPA Enforcement Surrender Account. As part of submitting this transfer request, BP-Husky shall irrevocably authorize the transfer of these NOx Allowances and identify - by name of account and any applicable serial or other identification numbers or station names the source and location of the NOx Allowances being surrendered. (d) Mitigation. To qualify for the alternate operating scenario, BP-Husky shall surrender all NOx allowances that are required pursuant to this Paragraph by no later than March 15 th of the year following the calendar year in which the longterm emissions limit is exceeded /4/2010

7 Final Short-Term Toledo FCCU NOx Limit (3) Final Short Term NOx Limit: Beginning no later than December 1, 2009, and except as provided in Paragraph (4) below, BP-Husky shall comply with a shortterm limit of 93.4 ppmvd 0% 02 on a 7-day rolling average basis. This short-term limit shall apply at all times when the FCCU is operating except during periods of startup, shutdown, and malfunction. (4) Emissions During Periods of FCCU Shutdown and CO Boiler Operation: The short term (7-day) emission limit established in Paragraph (3) above shall not apply during periods when the CO Boiler is operating but the FCCU is shut down. During such periods, BP-Husky shall minimize NOx emissions from the CO Boiler to the extent practicable consistent with good air pollution control practices for minimizing emissions by continuing to treat the off gases in the selective non-catalytic reduction equipment installed pursuant to the Consent Decree. In addition, BP-Husky shall monitor NOx emissions from the CO Boiler using a continuous emissions monitor meeting the requirements of Paragraph 14.G. of the Consent Decree. General Provisions for Toledo FCCU NOx Limits (1) Determinations of compliance with the limits established in Paragraphs (1) and (3) above shall be based on data generated after the limits go into effect. December 1, 2009 is the first day used in the 365-day rolling average subject to the 58.1 ppmvd emission limit with the first complete 365-day average being on November 30, December 1, 2009 is the first day used in the 7-day rolling average subject to the 93.4 ppmvd limit with the first complete 7-day average being on November 7, These limits should be incorporated verbatim into PTI , except for appropriate format and internal paragraph references. This new language does not replace or require deletion of any existing PTI language. This will be the first reference to any FCCU NOx emissions limits in a PTI /4/2010

8 2.0 Permit Application Forms The Section I and Section II PTI forms and an EAC form for the BP-Husky FCCU P007 are included in the Ohio EPA web based software Air Services for reference /4/2010

9 Appendix A Copy of November 6, 2009 Letter to Finalize NOx Emissions Limits for BP-Husky Toledo FCC