UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	February 17, 2010

SUBJECT:	Technical Support Document for Delaware’s Amendment to
Regulation No. 1142 – Control of Nitrogen Oxide Emissions from
Industrial Boilers and Process Heaters at Petroleum Refineries

FROM:	Gregory Becoat, Environmental Scientist /s/

Office of Air Program Planning 

TO:		File

			

THRU: 	Cristina Fernandez, Associate Office Director /s/

Office of Air Program Planning

A.  BACKGROUND:  

On November 17, 2009, the Delaware Department of Natural Resources and
Environmental Control (DNREC) submitted a revision to the Delaware State
Implementation Plan (SIP) that consists of Delaware’s regulation for
controlling nitrogen oxide (NOx) emissions from industrial boilers
(Regulation No. 1142/SIP Regulation No. 42– Specific Emission Control
Requirements). The revision to Regulation No. 1142/SIP Regulation No. 42
adds a new section, Section 2 – Control of Nitrogen Oxide Emissions
from Industrial Boilers and Process Heaters at Petroleum Refineries, in
order to require new and/or additional controls on industrial boilers
and process heaters with heat input capacities of equal to or greater
than 200 million British thermal units per hour (mmBTU/hr) at petroleum
refining facilities in Delaware.  The effective date of this regulation
is November 11, 2009.   

Delaware is not in compliance with the national ambient air quality
standards (NAAQS) for the 1997 8-hour ozone standard.  Under the 1997
8-hour ozone standard, the State of Delaware is part of the
Philadelphia-Wilmington-Atlantic City non-attainment area.  Since NOx is
a major precursor to the formation of ozone in the lower atmosphere,
DNREC developed a regulation in order to reduce NOx emissions from
Delaware’s large industrial boilers and process heaters that are
located at petroleum refineries and to help Delaware attain and maintain
the NAAQS for the 1997 8-hour ozone standard by 2010.

B.  STATE SUBMITTAL:

Regulation No.1142/SIP Regulation No. 42 applies to any industrial
boiler or process heater with a maximum heat input capacity of equal to
or greater than 200 mmBTU/hr, which is operated or permitted to operate
within a petroleum refinery facility (except for any Fluid Catalytic
Cracking Unit carbon monoxide (CO) boiler).  The following nine units
are affected:

Crude Unit Vacuum Heater (Unit 21-H-2)

Crude Unit Atmospheric Heater (Unit 21-H-701)

Fluid Coking Carbon Monoxide boiler (Unit 22-H-3)

Steam Methane Reformer Heater (Unit 37-H-1)

Continuous Catalyst Regenerator Reformer Heater (Unit 42-H-1,2,3)

Boiler 1 (Unit 80-1)

Boiler 2 (Unit 80-2)

Boiler 3 (Unit 80-3)

Boiler 4 (Unit 80-4)

Regulation No.1142/SIP Regulation No. 42 requires compliance with the
requirements of Section 2 of this regulation on and after July 11, 2007
for the following units:

Crude Unit Atmospheric Heater (Unit 21-H-701)

Steam Methane Reformer Heater (Unit 37-H-1)

Boiler 2 (Unit 80-2)

Regulation No.1142/SIP Regulation No. 42 requires compliance with the
requirements of Section 2 of this regulation as soon as practicable, but
not later than:

December 31, 2008: Boiler 1 (Unit 80-1) and Crude Unit Vacuum Heater
(Unit 21-H-2)

May 1, 2011: Boiler 3 (Unit 80-3) and Boiler 4 (Unit 80-4)

December 31, 2012: Continuous Catalyst Regenerator Reformer Heater (Unit
42-H-1,2,3)

Regulation No.1142/SIP Regulation No. 42 establishes NOx emission
limitations for the owner or operator of any industrial boiler or
process heater as follows:

For the Fluid Coking Carbon Monoxide boiler (Unit 22-H-3) – Reserved.

For the Steam Methane Reformer Heater (Unit 37-H-1) – Reserved.

For Boiler 1 (Unit 80-1), Boiler 3 (Unit 80-3) and Boiler 4 (Unit 80-4)
– 0.015 lb/mmBTU, on a 24-hour rolling average basis.

For any unit other than the Fluid Coking Carbon Monoxide boiler (Unit
22-H-3), the Steam Methane Reformer Heater (Unit 37-H-1), Boiler 1 (Unit
80-1), Boiler 3 (Unit 80-3) and Boiler 4 (Unit 80-4) – 0.04 lb/mmBTU,
on a 24-hour rolling average basis.

The NOx emission limits established in this regulation do not apply to
the start-up and shutdown of equipment when emissions from such
equipment during a start-up and shutdown are addressed in an operation
permit issued pursuant to the provisions of Section 2 of Regulation
1102.

Regulation No.1142/SIP Regulation No. 42 establishes monitoring
requirements set forth in 40 CFR, Part 60, Appendix B, Performance
Specification 2, and the requirements in 40 CFR Part 60, Appendix F.

Regulation No.1142/SIP Regulation No. 42 establishes recordkeeping and
reporting requirements that no later than 180 days after the effective
date of this regulation, any person subject to Section 2 of this
regulation must develop and submit to DNREC a schedule for bringing the
affected emission units [Boiler 1 (Unit 80-1), Crude Unit Vacuum Heater
(Unit 21-H-2), Boiler 3 (Unit 80-3), Boiler 4 (Unit 80-4), and
Continuous Catalyst Regenerator Reformer Heater (Unit 42-H-1,2,3)] into
compliance with the NOx emission limits established in this regulation. 


Regulation No.1142/SIP Regulation No. 42 establishes that any person
subject to Section 2 of this regulation shall submit to DNREC an initial
compliance certification as follows:

September 10, 2007: Crude Unit Atmospheric Heater (Unit 21-H-701), Steam
Methane Reformer Heater (Unit 37-H-1), and Boiler 2 (Unit 80-2).

December 31, 2008: Boiler 1 (Unit 80-1) and Crude Unit Vacuum Heater
(Unit 21-H-2)

May 1, 2011: Boiler 3 (Unit 80-3) and Boiler 4 (Unit 80-4)

December 31, 2012: Continuous Catalyst Regenerator Reformer Heater (Unit
42-H-1,2,3)

Regulation No.1142/SIP Regulation No. 42 establishes that any person
subject to Section 2 of this regulation shall, for each occurrence of
excess emissions above the NOx emission limits established in this
regulation, within thirty calendar days of becoming aware of such
occurrence, supply DNREC with the following:

The name and location of the facility.

The subject source(s) that caused the excess emissions.

The time and date of first observation of the excess emissions.

The cause and expected duration of the excess emissions.

The estimated rate of emissions (expressed in the units of the
applicable emission limitation (and the operating data and calculations
used in determining the magnitude of the excess emissions.

The proposed corrective actions and schedule to correct the conditions
causing the excess emissions.

Regulation No.1142/SIP Regulation No. 42 establishes that any person
subject to Section 2 of this regulation shall maintain all information
necessary to determine and demonstrate compliance with the requirements
for a minimum period of five years.

C.  EPA EVALUATION:

With the provisions of Regulation No.1142/SIP Regulation No. 42, the
control of NOx emissions from industrial boilers and process heaters at
petroleum refineries will not cause or contribute to the existing air
quality problems with regard to ozone.  This revision will continue to
help Delaware attain and maintain NAAQS for ozone.  

E.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

Regulation No.1142/SIP Regulation No. 42 adopted by the State of
Delaware will result in the control of NOx emissions from industrial
boilers and process heaters at petroleum refineries and will help the
State in attaining compliance with the 1997 8-hour ozone NAAQS.  EPA
approval of the SIP revision is recommended.

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