                          Technical Support Document
           VOC RACT Source Specific SIP Revision State of New Jersey
                                      for
                  Paulsboro Refining in Paulsboro, New Jersey
                                      and
       Buckeye Port Reading Terminal in Woodbridge Township, New Jersey
                                      and
        Buckeye Pennsauken Terminal in Pennsauken Township, New Jersey
                                      and
                   Phillips 66 Company in Linden, New Jersey

                                       
 INTRODUCTION

Title I of the Clean Air Act Amendments of 1990 (Act or CAA) contains many requirements for areas that have not attained the national ambient air quality standards (NAAQS) for six criteria air pollutants, one of which is ground level ozone. Nonattainment for ground level ozone is defined as an area that is not meeting (or that contributes to ambient air quality in a nearby area that does not meet) the national primary or secondary ambient air quality standard for eight-hour ozone and is classified as either marginal, moderate, serious, severe, or extreme.  CAA § 182 requires states with area classified as marginal or above to include in their State implementation plans, among other things, provisions to require the implementation of reasonably available control technology (RACT), and for areas classified as moderate and above the RACT shall be revised to include each category of volatile organic compound (VOC) sources in the area covered by a Control Techniques Guideline (CTG) and an Alternative Control Technique (ACT). The entire state of New Jersey is nonattainment for ozone and is comprised of two multi-state eight-hour ozone nonattainment areas; the Philadelphia-Wilmington-Atlantic City (PA-NJ-MD-DE) area is currently designated as a marginal nonattainment area, and the New York-Northern New Jersey-Long Island (NY-NJ-CT) area is currently designated as a moderate nonattainment area. 

   This technical support document (TSD) outlines the New Jersey Department of Environmental Protection's (NJDEP's) State Implementation Plan (SIP) revisions to the eight-hour ozone SIP. Four source-specific SIPs  -  for Paulsboro Refining, Buckeye Port Reading Terminal, Buckeye Pennsauken Terminal, and Phillips 66 Company's Linden facility (Linden facility)  -  were submitted to address the VOC RACT requirements for installing domes on external floating roof tanks (EFRTs) in Range III that were in existence on May 18, 2009 and that store VOC with vapor pressure three (or greater) pounds per square inch absolute (psia). Specifically, the NJDEP submitted the source-specific SIPs for EPA approval to allow the facilities to not dome certain EFRTs in Range III that would otherwise be required to do so under N.J.A.C. 7:27-16.2(l)(4), which is approved into the NJDEP SIP. The EPA would need to approve those EFRT control requirements that are deviating from the regulations into the SIP in order for the four facilities to remain in SIP compliance without doming their Range III EFRTs.  The source-specific SIPs also require EPA approval to allow the facilities to install some required EFRT domes after the otherwise-applicable regulatory deadline.  

   The NJDEP reviewed and approved each of the four facilities' alternative VOC control plans and respective RACT, i.e. the lowest economically feasible emission limitation for their EFRTs. The respective alternative VOC control plans include proposals for doming 25 out of 51 EFRTs it covers, and leaving the remaining 26 EFRTs without domes despite the requirements of NJAC 7:27-16.2(l)(4), based on the facilities' RACT cost analyses, and to install 8 domes after the regulatory due date. 

   In its source-specific SIP submittals for all four facilities, the NJDEP also identified non-doming VOC and NOx emission reduction strategies intended to achieve additional reductions at these facilities beyond what will be achieved by doming the 25 EFRTs. This is detailed in the facilities' alternative VOC control plans. However, the NJDEP did not request that the EPA approve these additional non-doming measures into the New Jersey SIP, therefore the EPA did not evaluate them for approvability. Detailed information on these additional measures is discussed below.
      
II.	CLEAN AIR ACT REQUIREMENTS FOR OZONE ATTAINMENT AND RACT REQUIREMENTS
      
 Federal Ozone Requirements  

In 1997, the EPA revised the health-based NAAQS for eight-hour ozone, setting it at 0.084 parts per million (ppm) averaged over an eight-hour time frame. See 62 FR 38856. This rulemaking was based on scientific evidence demonstrating that ozone causes adverse health effects at lower ozone concentrations and over longer periods of time than was understood when the 1-hour ozone standard was set in 1979.  On April 30, 2004, the EPA finalized attainment/nonattainment designations for areas across the country with respect to the 1997 eight-hour ozone standard and set design values based on fourth-highest daily maximum, averaged across three consecutive years. See 69 FR 23951.  These designations became effective on June 15, 2004.  

   On November 29, 2005, the EPA finalized rules regarding emissions control and planning obligations applicable to areas designated nonattainment for eight-hour ozone, including RACT measures and attainment demonstrations among other elements. See 70 FR 71612.

   The EPA has revised the eight-hour ozone standard twice since 1997. First, on March 27, 2008, the standard was revised to 0.075 ppm. 73 FR 16436. On May 21, 2012, the EPA finalized the air quality thresholds that define the classifications assigned to all nonattainment areas for the 2008 ozone NAAQS. See 77 FR 30088.

   Then, the EPA revised the eight-hour ozone standard again on October 26, 2015, down to 0.070 ppm, but retained the 2008 ozone indicators, design value (i.e., fourth-highest daily maximum, averaged across three consecutive years) and averaging times (eight hours). See 80 FR 65292. That rule became effective December 28, 2015. On March 9, 2018, the EPA finalized the air quality thresholds that define the classifications assigned to all nonattainment areas for the 2015 ozone NAAQS. See 83 FR 10376.

B.	Federal RACT Requirements   

Reasonably available control technology (RACT) is defined as the lowest emission limit that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility. CAA sections 172(c)(1), 182(b)(2) and 182(f) require nonattainment areas that are designated as moderate or above to adopt RACT. All the state of New Jersey is subject to this requirement due to nonattainment area designations for the eight-hour ozone standard at 40 CFR 81.331. In addition, the entire state of New Jersey is located within the Ozone Transport Region (OTR), which also triggers the RACT requirement. In accordance with CAA section 182(b), New Jersey must, at a minimum, adopt RACT-level controls for sources covered by a Control Techniques Guidelines (CTG) document and for any major non-CTG sources.

   On November 29, 2005, the EPA published a "Phase 2 Rule" that discusses the RACT requirements for the 1997 eight-hour ozone standard. See 70 FR 71612. Among other things, the Phase 2 Rule outlines the SIP requirements and deadlines for various areas designated as moderate nonattainment. The Phase 2 Rule states, in part, that where a RACT SIP is required, SIPs implementing the eight-hour ozone standard generally must ensure that RACT is met, either through a certification that previously required RACT controls represent RACT for eight-hour ozone implementation purposes or, where necessary, through a new RACT determination. Under EPA guidance, States should consider in their RACT determinations technologies that achieve 30 - 50 percent reduction within a cost range of $160 - 1300 per ton of NOx removed (70 FR 71652). The EPA also considers NOx reductions to be near or equal with VOC through substitutions. 

C. 	NJ RACT Requirements

The state of New Jersey chose a uniform applicability level for RACT analysis for the entire state based on the New Jersey's previous classification under the 1979 one-hour ozone standard as in severe nonattainment, which resulted in a statewide definition of major sources of NOx and VOC as those emitting 25 tons per year or more of VOC and/or NOx. New Jersey could have chosen to apply, for example, the major source threshold (50 tons per year VOC, 100 tons per year NOx), for areas classified as moderate nonattainment, since one of its areas is currently classified as moderate under the eight-hour standard.  Instead, New Jersey chose to retain the more stringent one-hour ozone limits statewide (25 tons per year or more of VOC and/or NOx) for RACT analysis purposes. The state of New Jersey's use of 25 tons per year major source threshold for RACT is consistent with the anti-backsliding provisions of the Act.

   On August 1, 2007, the NJDEP finalized RACT revisions to its SIP to address the eight-hour ozone NAAQS (2007 NJ RACT plan) and on May 15, 2009 the EPA approved it. See 74 FR22837. On September 2, 2010, the EPA approved New Jersey's revised SIP incorporating several amendments to the New Jersey Administrative Code Title 7, Chapter 27, including an updated version of Subchapter 16, "Control and Prohibition of Air Pollution by Volatile Organic Compounds" (N.J.A.C. 7:27-16). See 75 FR 45483. Subchapter 16 includes control measures needed to meet the state's commitment to adopt additional RACT rules. The Subchapter 16 RACT rules outlined below were intended to reduce emissions from petroleum and VOC storage tanks, to help New Jersey attain the eight-hour ozone standard:  

 N.J.A.C. 7:27-16.1A(a)(1) requires any stationary source operation, or group of source operations, located at a facility to utilize reasonably available control technology (RACT) to control VOC emissions.
 N.J.A.C. 7:27-16.2(l)(4) requires that EFRTs in Range III storing any VOC with vapor pressure 3 psia or greater shall be equipped with a domed roof before the tank is refilled after the first time the tank is degassed after May 19, 2009, but no later than May 1, 2020 if the tank was in existence on May 18, 2009, or on initial fill if the tank is constructed on or after May 19, 2009.
 N.J.A.C. 7:27-16.2(p) requires that the owner/operator of any floating roof tank submit a VOC control plan.
 N.J.A.C. 7:27-16.2(r)(1) requires that the findings of any tank inspection be recorded on Inspection Form at N.J.A.C. 7:27-16 Appendix II.
 N.J.A.C. 7:27-16.2(r)(5) details visual inspection requirements for EFRTs in Range III.
 N.J.A.C. 7:27-16.2(r)(6) requires domed EFRTs in Range III to annually measure organic vapor concentrations using an explosimeter and visual inspections.
 N.J.A.C. 7:27-16.2(r)(7) requires domed EFRTs in Range III to demonstrate compliance with 7:27-16.2(l)(6) by following 7:27-16.2(r)(6). 
 N.J.A.C. 7:27-16.17 Alternative and facility-specific VOC control requirements for a major VOC facility whose owner or operator seeks approval of a facility-specific VOC control plan that would apply to any source operation or equipment that has the potential to emit at least three pounds per hour
         16.17(a) establishes procedures and standards for the establishment of VOC control requirements for any source operation that: 
               1. Is located at a major VOC facility whose owner or operator seeks approval of a facility-specific VOC control plan that would apply to any source operation or equipment that has the potential to emit at least three pounds per hour (potential batch cycle emission rate of three pounds per hour for batch processes), and: 
                     i. Is not regulated elsewhere in this subchapter; and 
                     ii. Is not specifically exempted elsewhere in this subchapter because the source operation is within a category that is exempted or because the source operation operates below exclusion rates or threshold levels for control; or 
               2. Is regulated under N.J.A.C. 7:27-16.2 through 16.16 or 16.18 through 16.21, whose owner or operator seeks approval of an alternative VOC control plan, which would apply to the equipment or source operation notwithstanding any control requirement or emission limit which would otherwise apply under subchapter 16; or 
               3. Was issued an alternative or facility-specific VOC control plan prior to May 19, 2009.


 EPA'S ANALYSIS OF STATE SUBMITTAL 

The NJDEP reviewed and approved each of the four facilities' alternative VOC control plans and respective RACT, and submitted them to EPA for consideration of approval. The respective alternative VOC control plans include proposals for doming 25 out of 51 current EFRTs covered by the plans. The plans include proposals to leave the remaining 26 EFRTs without domes based on the facilities' RACT cost analysis, and install eight domes after the regulatory due date both despite the requirements of NJAC 7:27-16.2(l)(4). In addition, one EFRT was converted to an internal floating roof tank not subject to doming requirements. All four facilities' EFRTs were in existence on May 18, 2009.  
   In its SIP revision submittals for all four facilities, the NJDEP also identified non-doming VOC and NOx emission reduction strategies intended to achieve additional reductions at these facilities beyond what will be achieved by doming the 25 EFRTs. This is detailed in the facilities' alternative VOC control plans. However, the NJDEP did not request that the EPA approve these additional non-doming measures into the New Jersey SIP, therefore the EPA did not evaluate them for approvability.
    
   Since the time of the SIP revision submittals (December 2015 for Paulsboro, August 2014 for the two Buckeye facilities, and June 2016 for the Linden facility), the EPA has confirmed with the state the doming status of each facility's EFRTs. Furthermore, the EPA has determined that the doming analyses identified in the source-specific SIP revisions are consistent with New Jersey's VOC RACT regulation and the EPA's rules and guidance as discussed above. 

    RACT Cost Analysis for the Four Facilities

The August 1, 2007 NJ RACT plan, found the EPA guidance's definition of reasonable cost for ozone nonattainment areas (i,e., $160 - 1300) to be too low. New Jersey stated that it intends to consider the following in determining what is economically feasible for RACT:
 past New Jersey costs for retrofitting a given control;
 average RACT cost (dollars per tons reduced) for a control technology and maximum RACT cost. The idea is that once a reasonable number of sources in a source category achieve a lower emission level, other sources should do the same;
 the seriousness of the Region's ozone air quality exceedance. For nonattainment areas with higher ozone levels higher cost for controls are reasonable;
 the seriousness of the need to reduce transported air pollution. As an OTR state, higher costs for RACT are justified; and
 the NJDEP plan for addressing economic feasibility in RACT rules. The NJDEP intends to specify RACT at the lowest emission limit that a reasonable number of similar industries had already successfully implemented for each source category
2007 NJ RACT plan, at pages 18-21.

   It is not uncommon for states to set RACT thresholds above the federal RACT levels.  For example, the current New York RACT threshold is $5,000 to $5,000 per ton VOC reduced per year.  See NYSDEC DAR-20 Economical and Technical Analysis for RACT (Aug. 8, 2013), available at https://www.dec.ny.gov/chemical/91851.html

   In performing their RACT analyses, Paulsboro, Buckeye Port Reading, Buckeye Pennsauken, and Phillips 66 Company's Linden facility reviewed the cost of doming tanks with similar diameter and similar emission reductions when deciding which tanks are optimal for doming. Initial costs of doming tanks with similar diameter are very close. The cost to dome the largest tank was estimated not to exceed $60,000 per ton VOC emissions reduced per year. Doming costs for some tanks at the Linden facility are higher compared to those at Paulsboro because the Linden facility uses smaller tanks that store organic liquids with lower annual VOC emissions. As a result, doming of those tanks would result in much smaller reduction of VOC emissions and much higher cost per ton.   
   
   The EPA compared estimated doming costs provided by the NJDEP for Paulsboro, the two Buckeye facilities, and the Linden facility with the Mid-Atlantic Regional Air Management Association (MARAMA), Assessment of Control Technology Options for Petroleum Refineries in the Mid-Atlantic Region, Final Report, January 2007, where the cost (in 2007) to dome a 40-foot diameter EFRT is $21,640 and a 131-foot diameter EFRT was $240,500.  Although this dollar amount is actual cost to dome, not the tons VOC emissions reduced as under RACT, it is helpful because the dollar amount provides a general sense on price to dome a EFRT. In the case of the four facilities, their average diameter for their EFRT is 80-foot.   


    Paulsboro Refining, 800 Billingsport Road, Paulsboro, NJ 08066, Program Interest Number 55829, Activity Number BOP 130002

In a letter dated December 10, 2015 from Bob Martin, Commissioner NJDEP, to Regional Administrator Judith Enck, U.S. EPA Region 2, New Jersey requested EPA's approval of a revision to the New Jersey SIP for ozone that incorporates an alternative VOC control plan not to dome eleven out of 21 EFRTs, and to dome ten EFRTs but to allow the facility to complete doming of five EFRTs beyond the regulatory deadline of May 1, 2020.

 EPA's Evaluation

OVERVIEW
EPA reviewed Paulsboro's application and the NJDEP's source-specific SIP revision for completeness and approvability and consulted with the state. Documents that were provided to the EPA for review include the following:
 December 10, 2015 NJDEP submission to EPA Administrator (Judith Enck), "Revision to the NJ SIP for Paulsboro Refining Company LLC"
 Enclosure 1, SIP Completeness Checklist
 Enclosure 2, ACP Approval Summary and Compliance Plan 
 Enclosure 3, Response to Comments Document
 Enclosure 4, State of Basis
 Enclosure 5, A copy of the Public Notice and Opportunity for Public Hearing
 Enclosure 6, A copy of the Affidavit of Publication of Public Notice
 Enclosure 7, A copy of the application package from the applicant and other supporting documentation 

DOMING MEASURES 
Paulsboro Refining owns and operates an inventory of 21 EFRTs in Range III storing VOC with vapor pressure 3 psia or greater. The 21 tanks are the following: Tanks 724 (dome complete), 1319 (dome complete), 1115 (dome complete), 1064, 2173, 1063, 1116, 1320, 1065, 1066, 725, S02, 1023, 1027, 2869, 2940, 2941, 3174, SSO, SSI, and SS2. The EPA is proposing to approve a source-specific SIP revision allowing the facility not to dome eleven of its 21 EFRTs that are in Range III, and to allow the facility to complete doming of five EFRTs beyond the regulatory deadline of May 1, 2020.

   The Paulsboro Refining's analyses demonstrate that it is not cost effective to dome all 21, and thus the NJDEP reached an agreement with the facility, now being submitted to the EPA for approval as a SIP revision, to not dome eleven tanks. The tanks that would not be domed are: Tanks 725, S02, 1023, 1027, 2869, 2940, 2941, 3174, SSO, SSI, and SS2. In addition, Paulsboro's standard procedure is to take storage tanks out of service every 15-20 years for inspection, maintenance and repairs. The NJDEP has thus provided in the source-specific SIP revision submitted for approval that five of the storage tanks may remain in service until Paulsboro next plans to take the tanks out of service for maintenance in accordance with the doming schedule outlined in the CAA Title V permit, even though this would mean the domes will be installed after the regulatory deadline of May 1, 2020. Thus, the 10 EFRTs receiving domes will have domes installed according to the following schedule:

 Tank 724: doming complete
 Tank 1319: doming complete 
 Tank 1115: doming complete
 Tank 1064: already taken out of service and rebuilt, and is scheduled for doming by the end of 2018* 
 Tank 2173 dome by 12/31/2019
 Tank 1063 dome by 12/31/2021 (beyond the regulatory deadline)
 Tank 1116 dome by 12/31/2023 (beyond the regulatory deadline)
 Tank 1320 dome by 12/31/2025 (beyond the regulatory deadline)
 Tank 1065 dome by 12/31/2026 (beyond the regulatory deadline)
 Tank 1066 dome by 21/31/2028 (beyond the regulatory deadline)

*The facility's Title V permit indicates that Tank 1064 was scheduled for doming by December 31, 2024. However, NJDEP recently confirmed that the facility's plans changed and Tank 1064 was taken out of service for rebuilding and doming early.

Once the total of 10 EFRTs are domed, they will achieve 28.1 TPY VOC emissions reductions.

COST TO DOME
Paulsboro estimates that the cost to dome all 21 EFRTs would be $19,000 to $149,000 per ton of VOC emissions reduced, thus exceeding the normally expected cost threshold for reasonably available control technology.  

OTHER VOC and NOx REDUCTION MEASURES
The alternative VOC control plan includes non-doming measures to address the foregone 41.1. TPY VOC emission reductions that would have been achieved if all 21 EFRTs were domed. The facility reports that these non-doming VOC reduction measures are cost effective and will result in greater reductions. Paulsboro represents that it would achieve 18.9 TPY VOC emission reductions through the following non-doming measures: 
 4.3 TPY VOC emission reduction  -  Install leak-tight connectors on liquid petroleum gas (LPG) loading racks to prevent 1.3-pound loss of LPG vapor that typically occurs when disconnecting from the tanker truck during delivery. The facility reports that leaks from connectors and other truck rack components are detected using the refinery's leak detection and repair program.  
 4.2 TPY VOC emission reduction  -  Vent 15 continuous process analyzers to a flare header, to prevent venting to atmosphere. The process gases captured in the flare header under normal operating conditions are captured by compressors and sent to the refinery fuel system for combustion in heaters and boilers.
 4.9 TPY VOC + 10 TPY NOx emission reductions  -  The refinery operates a gas turbine as part of its co-generation facility. The fire duty of the gas turbine is 450 MMBtu/hr.  The facility would replace the gas turbine burners with dry low-NOx burners to eliminate the need for 40,000 lbs/hr of steam injection. The existing gas turbine NOx limit will remain at 0.15 lbs/MMBtu, but the VOC emissions from the boilers will be reduced because 40,000 pounds of steam will no longer be used. This will also result in associated reductions of annual gross heat input for Boilers 2A, 2B, and 2C.  
 5.5 TPY VOC emission reduction  -  There are 17 light gray color fixed roof aboveground storage tanks that will be painted white by December 2015.  The facility reports the 17 tanks are not subject to the white coating requirement. 

VOC and NOx EMISSION REDUCTIONS
The facility reports that doming ten EFRTs under the proposed SIP revision before EPA for approval would result in an emissions reduction of 28.1 TPY VOC.  Doming all 21 EFRTs would have resulted in a 41.1 TPY VOC emissions reduction; thus, not doming 11 EFRTs would results in 13 fewer TPY of VOC emissions reductions (41.1  -  28.1 = 13).

   The EPA notes that, according to the facility, the non-doming VOC and NOx reduction measures would reduce annual VOC emissions by 28.9 TPY, which is 15.9 TPY more than installing all 21 domes would have achieved (28.9  -  13 = 15.9) (including 10 TPY NOx reductions from the dry low NOx burner, since the EPA considers NOx reductions to be near or equal with VOC through substitutions).  However, these non-doming measures were not submitted to EPA for approval as part of the source-specific SIP revision, and so cannot be and are not being considered in determining the approvability of the source-specific SIP revision's doming-related measures.

 EPA's Approvability Recommendation

The EPA is suggesting full approval for the Paulsboro source-specific SIP revision, allowing the facility not to dome eleven of its 21 EFRTs that are in Range III, and to allow the facility to dome 10 EFRTs but to complete doming of five EFRTs beyond the regulatory deadline of May 1, 2020. The NJDEP did not request that the EPA approve the other VOC and NOx non-doming emission reduction strategies, therefore, the EPA did not evaluate them for approvability and proposes no action on these measures today. 

    Buckeye Port Reading Terminal, 750 Cliff Road, Woodbridge NJ, Program Interest Number 17996, Activity Number BOP 130002; Buckeye Pennsauken Terminal, 123 Derousse Avenue, Pennsauken NJ, Program Interest Number 51606, Activity Number BOP 130002

In a letter dated August 15, 2014 from Bob Martin, Commissioner NJDEP, to Regional Administrator Judith Enck, U.S. EPA Region 2, New Jersey requested EPA's approval of a revision to the New Jersey SIP for ozone that incorporates alternative VOC control plans for two Buckeye facilities (the Port Reading and Pennsauken Terminals).  For the Port Reading Terminal, the proposed SIP revision would allow Buckeye not to dome four out of eight EFRTs; to dome four EFRTs but allow the facility to complete doming of two EFRTs beyond the regulatory deadline of May 1, 2020; and to convert one EFRT to an internal floating roof tank not subject to doming requirements.  The proposed SIP revision for the Pennsauken Terminal would allow Buckeye to not dome the facility's single EFRT.

 EPA's Evaluation
OVERVIEW
The EPA reviewed Buckeye's applications and the NJDEP's submitted source-specific SIP revisions for completeness and approvability and consulted with the state.  Note that the Port Reading and Pennsauken terminals were acquired by Buckeye Energy Services LLC from Hess in 2013. Documents that were provided to the EPA for review include the following: 
 August 22, 2014 letter from NJDEP to Buckeye Port Reading regarding an Alternative VOC Control Plan for EFRT (and Attachments I, II, III)
 August 22, 2014, letter from NJDEP to Buckeye Pennsauken regarding an Alternative VOC Control Plan for EFRT (and Attachments I, II, III)
 August 15, 2014, letter from NJDEP to EPA Regional Administrator Judith Enck, regarding a Revision to the NJ SIP for Buckeye Port Reading and Pennsauken (to incorporate an Alternative VOC Control Plan)
 February 11, 2014, letter from Hess to NJDEP, Alternative VOC Control Plan for Port Reading and Pennsauken
 December 12, 2013, Notice of Opportunity for Public Comment for Buckeye Port Reading
 December 12, 2013 Statement of Basis for Buckeye Port Reading
 December 12, 2013 Statement of Basis for Buckeye Pennsauken 
 October 17, 2012, letter from Hess to NJDEP containing the Supplement to Alternative VOC Control Plan Submitted 9/4/2012 for Port Reading and Pennsauken 
 October 17, 2012, letter from Hess to NJDEP with Supplement to Alternative VOC Control Plan submitted on 9/4/2012
 September 4, 2012, letter from Hess to NJDEP with Alternative VOC Control Plan for Port Reading and Pennsauken
 July 30, 2012, letter from Hess to NJDEP with Significant Modification Application for Port Reading (BOP 110001, PI 17996)
 July 26, 2012, letter from Hess to NJDEP with Significant Modifications Application for Pennsauken (BOP 100001 PI 51606)
 June 28, 2012, letter from Hess to NJDEP with Application for Significant Modification of title V Permit DRAFT, Port Reading Refinery (BOP 110001, PI 17996) 
 June 28, 2012, letter from Hess to NJDEP with Application for Significant Modification of title V Permit, Pennsauken New Jersey Terminal (BOP 110001, PI 51606)
 April 18, 2012, letter from Hess to NJDEP with Port Reading Refinery 
 August 20, 2007, NESCAUM Onboard Refueling Vapor Recovery Systems Analysis of Widespread Use (published 8/20/2007) 
 November 16, 2017, letter from NJDEP to EPA Air Programs Branch with a Supplement to Revision to NJ SIP for Buckeye Energy Services LLC, Port Reading and Pennsauken Terminals.  (This document was submitted regarding the gasoline transfer operations rule.)

PORT READING TERMINAL DOMING MEASURES
The Buckeye Port Reading Terminal owns and operates an inventory of eight EFRT's in Range III storing VOC with vapor pressure 3 psia or greater that are part of this proposed SIP revision. The eight Port Reading EFRTs are Tanks 7935 (dome compete), 1222, 1219, 1178, 7930, 7934, 7937, 7945. The Port Reading Terminal previously had one additional EFRT not included in the eight, Tank 1177, but under this SIP revision Buckeye retrofitted Tank 1177 with an internal floating roof due to changes in facility operational needs, and an internal floating roof does not require a dome. In addition, the Port Reading terminal has at least two EFRTs (Tanks 7943 and 7944) that are not part of the proposed SIP revisions; the company fitted these two EFRTs with domes in approximately 2012.

   The Port Reading Terminal analysis demonstrates that it is not cost effective to dome all eight EFRTs, and thus the NJDEP reached an agreement with the facility, now being submitted to the EPA for approval as a SIP revision, not to dome four EFRTs. The four tanks not being domed are Tanks 7930, 7934, 7937, and 7945.
   The facility's procedure is to take storage tanks out of service every 15-20 years for inspection, maintenance and repairs.  The NJDEP has thus provided in the source-specific SIP revision submitted for approval that two of the storage tanks may remain in service until Port Reading Terminal next plans to take the tanks out of service for maintenance in accordance with the doming schedule outlined in the CAA Title V permit, even though this would mean the domes will be installed after the regulatory deadline of May 1, 2020.
   
   The following four Port Reading EFRTs are identified in the proposed SIP revision for doming to achieve 7.57 TPY VOC emissions reductions, according to the following schedule: 
 Port Reading tank 7935: doming complete
 Port Reading tank 1222: dome by Sept. 5, 2018
 Port Reading tank 1219: dome by March 8, 2027 (beyond the regulatory deadline)
 Port Reading tank 1178: dome by Sept. 25, 2028 (beyond the regulatory deadline)

PENNSAUKEN TERMINAL DOMING MEASURES
The Buckeye Pennsauken Terminal owns and operates one EFRT in Range III storing VOC with vapor pressure 3 psia or greater that are part of this proposed SIP revision, that is Tank 2018. 

   The Pennsauken Terminal analysis demonstrates that it is not cost effective to dome Tank 2018, and thus the NJDEP reached an agreement with the facility, now being submitted to the EPA for approval as a SIP revision, not to dome Tank 2018. 


OTHER VOC REDUCTION MEASURES
The alternative VOC control plans includes non-doming measures to address the foregone VOC emission reductions (17.82 TPY) that would have been achieved if all nine EFRTs at the two facilities were domed. Since it was not cost effective to dome all nine, Buckeye told the NJDEP it would achieve 13.58 TPY VOC emission reductions by retrofitting 19 retail gas stations with Stage II Onboard Refueling Vapor Recovery (ORVR) compatible nozzles. Six were installed near Pennsauken Terminal in 2012, and 13 near Port Reading Terminal in 2013 and 2014. The VOC emission reduction is based on 0.5 pounds VOC reduced/1,000-gallon gas throughput. 

   The NJDEP adopted revisions to its gasoline transfer operations rules on October 24, 2017 that allow, among other things, existing facilities with ORVR-compatible Phase II vapor recovery systems an option to decommission the systems within three years, though if the system is left in place the facility must continue to maintain the system. The EPA received a letter from the NJDEP on November 16, 2017 concluding that decommissioning of Phase II vapor recovery systems is consistent with the Buckeye facilities' alternative VOC control plan, and decommissioning would achieve the same emission reductions as ORVR-compatible Stage II nozzles since it would eliminate excess emissions due to incompatibility.   
   
VOC EMISSION REDUCTIONS
The EPA notes that, according to Buckeye, retrofitting 19 retail gas stations with Stage II ORVR compatible nozzles would reduce annual VOC emissions by 13.58 TPY.  However, these non-doming measures were not submitted to EPA for approval as part of the source-specific SIP revision, and so cannot be and are not being considered in determining the approvability of the source-specific SIP revision's doming-related measures.

COST TO DOME
The cost to dome the largest EFRT is estimated to be $60,000 per ton of VOC emissions reduced and exceed the normally expected cost threshold for reasonably available control technology. 

 EPA's Approvability Recommendation 

The EPA is suggesting full approval for the Buckeye Port Reading and Buckeye Pennsauken source-specific SIP revisions allowing the facilities not to dome five of their nine EFRTs that are in Range III, and to allow the Port Reading facility to dome four EFRTs but to complete doming of two EFRTs beyond the regulatory deadline of May 1, 2020. NJDEP did not request that the EPA approve the other VOC and NOx non-doming emission reduction strategies, therefore, the EPA did not evaluate them for approvability and proposes no action on these measures today. 
 

    Phillips 66 Company, 1400 Park Avenue, Linden NJ, Program Interest Number 41805, Activity Number BOP 120011

In a letter dated June 15, 2016 from Bob Martin, Commissioner NJDEP, to Regional Administrator Judith Enck, U.S. EPA Region 2, New Jersey requested EPA's approval of a revision to the New Jersey SIP for ozone that incorporates an alternative VOC control plan not to dome ten out of 21 EFRTs, and to allow the facility to dome eleven EFRTs but to complete doming of one EFRT beyond the regulatory deadline of May 1, 2020. 

 EPA's Evaluation

OVERVIEW
The EPA reviewed the Phillips 66 Company's application for its Linden facility (Linden facility) and the NJDEP's source-specific SIP revision for completeness and approvability and consulted with the state. Documents that were provided to EPA for review include the following:
 June 15, 2016 letter from NJDEP to the EPA Administrator (Judith Enck), with the Revision to the NJ SIP for Phillips 66 Bayway Refinery
 Enclosure 1, SIP Completeness Checklist
 Enclosure 2, ACP approval Summary and Compliance Plan 
 Enclosure 3, Response to Comments Document
 Enclosure 4, State of Basis
 Enclosure 5, A copy of the Public Notice and Opportunity for Public Hearing
 Enclosure 6, A copy of the Affidavit of Publication of Public Notice
 Enclosure 7, A copy of the application package from the applicant and other supporting documentation 

DOMING MEASURES
The Linden facility owns and operates an inventory of 21 EFRT's in Range III storing VOC with vapor pressure 3 psia or greater. The 21 tanks are Tanks T233 (dome complete), T239 (dome complete), T250, T243, T351, T241, T352, T235, T249, T353, T234, T52, TI05, TI19, TI43, T224, T349, T350, T354, T355, and T356. 

   The Linden facility analysis demonstrates that it is not cost effective to dome all 21 EFRTs, and thus the NJDEP reached an agreement with the facility, now being submitted to the EPA for approval as a SIP revision, not to dome ten EFRTs. Thus, the NJDEP reached an agreement with the facility under this SIP revision to not dome Tanks T52, TI05, TI19, TI43, T224, T349, T350, T354, T355, and T356. In addition, the Linden facility's standard procedure is to take storage tanks out of service every 15-20 years for inspection, maintenance and repairs. The NJDEP has thus provided in the source-specific SIP revision submitted for approval that one storage tanks may remain in service until the Linden facility next plans to take the tanks out of service for maintenance in accordance with the doming schedule outlined in the CAA Title V permit, even though this would mean the domes will be installed after the regulatory deadline of May 1, 2020.

   The following eleven EFRTs are identified in this SIP revision for doming, to achieve 28.1 TPY VOC emissions reductions, according to the following schedule:
 Tank T233: doming complete
 Tank T239: doming complete 
 Tank T250: Out of service, ready for doming, will be domed before further use
 Tank T243: Out of service, ready for doming, will be domed before further use
 Tank T351: Out of service, ready for doming, will be domed before further use
 Tank T241: Out of service, ready for doming, will be domed before further use
 Tank T352: dome by Dec. 31, 2018
 Tank T235: dome by Dec. 31, 2020
 Tank T249: dome by Dec. 31, 2020
 Tank T353: dome by Dec. 31, 2020
 Tank T234: dome by Dec. 31, 2024 (beyond the regulatory deadline)

OTHER VOC and NOx REDUCTION MEASURES
The alternative VOC control plan includes non-doming measures to address the foregone VOC emission reductions of 44.7 TPY that would have been achieved if all 21 EFRT's were domed. 
   Since it was not cost effective to dome all 21, the Linden facility will achieve 21.4 TPY emission reductions through the following measures: 
 VOC emissions reductions of 3.8 TPY  -  Connected the Hydrogen Plant steam vent to the Hydrogen Plant heater F-500.  The NJDEP confirms that the vent was rerouted to the furnace in 2014-15 and removed from the operating permit. 
 NOx emissions reductions of 17.6 TPY  -  Installed Selective Catalytic Reduction (SCR) to reduce NOx emissions from the Crude Pipestill heaters F-701 and F-751 as required by Consent Decree H-05-0258. The NJDEP confirms that the SCR was installed in 2012-13 and is included in the operating permit as control device CD65. The two boilers (F-701 and F-751) are equipped with a continuous emission monitoring system (CEMS) that continuously monitors NOx emissions during each hour of operation. The following Consent Decree language refers to SCR activity at the Phillips 66 Company Linden facility (i.e., Bayway):
 page 16: I. "Bayway Crude Pipestill Heater'' shall mean Heaters F-701 and F-751 at the Bayway Refinery which are connected through common ducting to a single stack. J. "Bayway Refinery" shall mean the refinery owned and operated by COPC in the City of Linden, New Jersey.
 page 81:  109. Installation of SCR on the Bayway Crude Pipestill Heater. COPC will install and operate an SCR system on the Bayway Crude Pipestill Heater by no later than December 31, 2010. COPC will design the SCR system to achieve at least a 90% control efficiency for NOx emissions from the Bayway Crude Pipestill Heater. The 90% control efficiency will apply to the equipment comprising the Bayway Crude Pipestill Heater at the time of the design of the SCR System and to the concentration and amount of NOx emissions released to the atmosphere at the time of that design. Beginning no later than one-hundred eighty (180) days after installing the SCR System, COPC will monitor emissions from the Bayway Crude Pipestill Heater by means of a NOx CEMS. COPC will certify, calibrate, maintain, and operate the NOx CEMS in accordance with the requirements of Paragraph 101. COPC will demonstrate compliance with state permit limits for the Bayway Crude Pipestill Heater at the time and in the manner established by the NJDEP. . . 

VOC and NOx EMISSION REDUCTIONS
The facility reports that doming 11 EFRTs under the proposed SIP revision before EPA for approval would result in an emissions reduction of 28.1 TPY VOC. Doming all 11 EFRTs would have resulted in a 44.7 TPY VOC emissions reduction; thus, not doming 10 EFRTs would result in 16.6 fewer TPY of VOC emissions reductions (44.7  -  28.1 = 16.6).

   The EPA notes that, according to the facility, the non-doming VOC and NOx reduction measures would reduce annual VOC emissions by 21.4 TPY (VOC + NOx), which is 4.8 TPY more than installing all 11 domes would have achieved (21.4  -  16.6 = 4.8) (since the EPA considers NOx reductions to be near or equal with VOC through substitutions).  However, these non-doming measures were not submitted to EPA for approval as part of the source-specific SIP revision, and so cannot be and are not being considered in determining the approvability of the source-specific SIP revision's doming-related measures.

COST TO DOME
The cost to dome all 21 EFRTs is estimated to be $29,000 - $440,000 per ton of VOC emissions reduced and exceed the normally expected cost threshold for reasonably available control technology. 

 EPA's Approvability Recommendation 

The EPA is suggesting full approval for the Phillips 66 Linden facility source-specific SIP revision allowing the facility not to dome ten of its 21 EFRTs that are in Range III, and to allow the facility to dome eleven EFRTs but to complete doming of one EFRT beyond the regulatory deadline of May 1, 2020. NJDEP did not request that the EPA approve the other VOC and NOx non-doming emission reduction strategies, therefore, the EPA did not evaluate them for approvability and proposes no action on these measures today.



Note this Technical Support Document summarizes the state submission and EPA/State consultations.  The related correspondence and State Implementation Plan (SIP) revision are available for inspection and review at the EPA regional office located at 290 Broadway, floor 25, NY, N Y and the NJDEP state office and on the Regulations.gov website.


