HomeMy WebLinkAbout2015-04-08 PACKET 05.5.lA
SEH
Building a Better World
for All of Us
TO: Jennifer Levitt, PE, City of Cottage Grove
FROM: Tom Henning, PE, SEH
DATE: January 15, 2015
MEMORANDUM
RE: Review of Draft Air Permit for Flint Hills Resources Pine Bend Refinery
SEH No. 122701 COTTG
At your request, Short Elliot Hendrickson Inc. (SEHO) reviewed the Draft/Proposed Air Emission Permit
for the Flint Hills Resources Pine Bend Refinery (Flint Hills) (Permit No. 03700011 -012). The Minnesota
P ollution Control Agency (MPCA) is accepting comments on the draft permit through January 21, 2015.
In addition to needed an air permit, the proposed projects at Flint Hills triggered the need to conduct
Environmental Assessment Worksheets (EAWs). Separate EAWs were prepared for each of the two
permitting actions described below. MPCA is accepting comments on the two EAWs until January 21,
2015.
Flint Hills is an oil refinery which processes heavy, sour crude oil from Western Canada and other parts of
the world. Oil is delivered to the refinery via pipeline. Products produced by Flint Hills include gasoline,
diesel fuel, heating oil, jet fuel, petroleum coke, asphalt, and elemental sulfur.
OVERVIEW OF DRAFT PERMIT
The draft air permit is a major amendment to the refinery's current Title V air operation permit. The
amendment combines two unrelated permit actions and two permit corrections.
• The first action is for the construction of a natural gas based combined heat and power
cogeneration facility, which will generate up to 49.9 megawatts of electricity and up to 290,000
pounds per hour steam. The refinery will utilize the electricity and steam on -site, reducing its.
dependence on the power grid and providing a more efficient source of steam for its processes.
Fuel usage by existing boilers at the site is expected to be lowered with the new source of steam.
The second action is for proposed process changes in order for Flint Hills to meet the EPA's Tier
3 gasoline sulfur standard by 2017. With the proposed change, Flint Hills will be able to remove
additional sulfur from intermediate fuel products. One new process unit is proposed, which will
convert gas containing sulfur and nitrogen into a non - hazardous liquid fertilizer (ammonium
thiosulfate). Along with increases in process emissions, emissions from haul road truck traffic will
increase as a result of this project.
• Permit corrections include: lowering a nitrogen oxides (NOx) emission limit related to a federal
rule for petroleum refineries, and clarifying the pressure drop monitoring and recordkeeping
requirements for a coke drum system.
Engineers I Architects I Planners I Scientists
Short Elliott Hendrickson Inc., 809 North 8th Street, Suite 205, Sheboygan, WI 53081 -4032
SEH is 100% employee -owned I sehinc.com 1 920.452.6603 1 888.908.8166'fax
Review of Draft Air Permit for Flint Hills Resources Pine Bend Refinery
January 15, 2015
Page 2
POLLUTION CONTROL EQUIPMENT AND EMISSIONS INCREASES
Flint Hills is proposing to use several pollution control strategies to minimize emissions from the proposed
projects. The combined heat and power project will use "Low -NOx" turbines and duct burners (i.e.
turbines and duct burners designed to generate less NOx) to minimize NOx generation. In addition,
selective catalytic reduction technology will be used to further reduce NOx emissions from the combustion
equipment. An oxidation catalyst will be used to reduce carbon monoxide (CO), volatile organic
compounds (VOC) and organic hazardous air pollutants such as formaldehyde from the turbine and duct
burners. Flint Hills will use filters to minimize particulate matter and acid mist emissions from the EPA
Tier 3 project.
Emissions increases are proposed for both the combined heat and power project and the EPA Tier 3
clean fuels project. A summary of emission increases by project and for the total facility are presented in
Table 1 below.
Table 1. Permitted Emission Rates
*Facility -wide Sulfur Dioxide limit remains the same.
IMPACTS ON THE PUBLIC AND THE ENVIRONMENT
The MPCA has evaluated the potential environmental impacts from the proposed projects. The
evaluations include estimating the health impacts on persons living near the facility and the broader
environmental impacts such as impacts on water quality, wetlands, noise, and specific ecosystems (e.g.
fish, wildlife, plants, and rare ecosystems). As part of the air permitting process MPCA uses computer
modeling to calculate the air quality impacts from the project and compares the results to state and
federal standards. The results of this evaluation show the proposed projects will not exceed applicable
standards.
Proposed
Combined
Permitted
Permitted
Heat and
EPA Tier 3
Total Facility
Pollutant
Emission Rate,
Emission Rate,
Power
Increases,
Increases,
ton /yr
tonlyr
Increases,
ton /yr
ton /yr
ton/ r
Particulate
1,032.7
1,061.2
16.8
11.7
28.5
Matter PM
PM less than 10
641.1
667.5
16.8
9.6
26.4
microns (PM1o)
PM less than 2.5
627.6
652.8
16.8
8.4
25.2
microns (PM2.5)
Sulfur Dioxide
3,770
3,770
4.1
36.4
No Change*
Nitrogen Oxides
3,952.6
4,013.8
27.7
33.5
61.2
Carbon
2,391
2,476.3
66.9
18.4
85.3
Monoxide
Carbon Dioxide
7837,536
8,221,963
345,263
39,164
384,427
Equivalents
Volatile Organic
2,610.5
2,674
28.0
35.5
63.5
Compounds
Total Hazardous
855
864.6
6.8
2.8
9.6
Air Pollutants
*Facility -wide Sulfur Dioxide limit remains the same.
IMPACTS ON THE PUBLIC AND THE ENVIRONMENT
The MPCA has evaluated the potential environmental impacts from the proposed projects. The
evaluations include estimating the health impacts on persons living near the facility and the broader
environmental impacts such as impacts on water quality, wetlands, noise, and specific ecosystems (e.g.
fish, wildlife, plants, and rare ecosystems). As part of the air permitting process MPCA uses computer
modeling to calculate the air quality impacts from the project and compares the results to state and
federal standards. The results of this evaluation show the proposed projects will not exceed applicable
standards.
Review of Draft Air Permit for Flint Hills Resources Pine Bend Refinery
January 15, 2015
Page 3
As part of the EAW process, MPCA further evaluates the potential health impacts on the community.
MPCA uses the actual pollutant concentrations measured near the Flint Hills facility (several monitors are
operated near the plant) and the predicted additional impacts from the project and compares the results
with state and federal standards. The results of this evaluation also show the proposed impacts are
acceptable.
Flint Hills will be required to operate continuous emission monitors for NOx and CO (to continuously
measure emissions from the stacks) and a series of emission tests to demonstrate they comply with the
emission limits in the air permit.
SUMMARY AND CONCLUSIONS
Flint Hills is proposing to implement two projects at the plant that will generate new air emissions. One
project is to install a turbine and duct burner to generate electricity and steam to be used at the plant.
This project will reduce the amount of electricity purchased by the plant. The second project is a process
to remove sulfur from fuels needed to meet EPA's Tier 3 gasoline sulfur standard. This project will
provided the environmental benefit of reducing sulfur dioxide emissions from automobiles and other
gasoline driven engines. Flint Hills proposes to use several pollution control strategies including
equipment designed to generate low emission and post - process pollution control equipment to reduce the
impacts on the environment.
The MPCA has evaluated the potential air quality impacts as part of the air permitting process and
determined the projects will comply with environmental regulations and will not exceed state and federal
air quality standards. MPCA is also evaluating potential multimedia environmental impacts as part of the
EAW process. Based on these reviews, the Flint Hills projects will not have a significant impact on the
citizens of Cottage Grove.
KHB /tah
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