PERMIT REVIEW SUMMARY

Permit Writer:	Audra Sandifer 			Date:	December 27, 2016	

Company Name:	Chevron Products Company, Pascagoula Refinery

Facility Location:	250 Industrial Road
Pascagoula, MS  39581

Source Number:	1280-00058

County: 		Jackson

PROJECT DESCRIPTION -- ISO II Reactor Replacement Project

Chevron is proposing the ISO II Reactor Replacement Project in order to ensure long term reliability of the ISO II plant by replacing the reactor R-6210.  The project will not increase the feed rate of any processing unit but is expected to reduce unit shutdown frequencies and provide incremental improvement in run time.  The project will not include the installation of any new emissions sources.  However, the new reactor is expected to allow increased annual production in the ISO I and ISO II plants which will result in increased utilization of process heaters in the ISO I Plant (Plants 12 and 13) and the ISO II Plant (Plant 62).  In addition, operation of the F-2102 boiler (Plant 21) and F-6410/KGT6410 in the Hydrogen II Plant (Plant 64) are assumed project-affected (worst case emissions) in order to provide increased steam and hydrogen production, respectively to support the longer run periods.  Sulfur recovery units II and III (Plant 27) are also assumed to be affected due to a small increase in sour gas/sulfur production.  Also, there will be increased make of intermediates and products that will effect storage tank throughputs as well as shipment operations in the marketing terminal and wharf areas.  The project will also include some piping modifications to route to and from the new reactor.  The project will not affect the refinery crude feed rate, or the operation of any upstream or downstream process unit.  

The project-related emission increases exceed the Prevention of Significant Deterioration (PSD) significance thresholds for greenhouse gases (GHG) only.  Therefore, the project is not subject to PSD and the refinery is not required to conduct a netting analysis.  

Chevron is requesting MDEQ to issue a permit-to-construct for the ISO II Reactor Replacement Project.  Emission changes are the result of the increased utilization of the existing ISO I and ISO II process units along with the support units, tankage and product loading facilities that are not being physically modified (Project-affected units), piping modifications, and a revision to the F-6250 NOx annual emission limit.  Also, Chevron has included the following non-project related actions for inclusion in the permit-to-construct:
•	Enhanced monitoring requirements for listed pumps and compressors as “leak-less” technology to make federally enforceable and the resulting emission reductions creditable.
•	Fugitive emissions monitoring requirements for Plant 84 Refinery Fuel Gas piping system valves to make federally enforceable and the resulting emission reductions creditable.  
•	Modify the FCC Regenerator Vent (F-1603, AH-051) PM10/PM2.5 tons/year emission limit to correspond to the change in test method from Method 5F to Methods 201 and 202.
•	Modify the F-5380A/B (BB-193/BB-194) CO limits to 4.88 lb/hr to be on a consistent basis with similar other refinery furnaces for accommodating start-up and shutdown conditions.  

The project will result in an increase in actual annual air emissions from the Refinery.  Except for the F-6250 process heater and fugitive VOC emissions from piping modifications, the air emissions increases for the project are due to affected units.  For F-6250, Chevron is proposing to increase the unit’s NOx annual emission limit to accommodate the increased utilization.  Almost all emission changes were based on a caparison of baseline actual emissions for a continuous 24-month period that occurred during the previous 10 years versus future projected actual emissions for the affect sources.  In a few cases, emission changes were based on incremental changes.  The emission increase is summarized below:

Pollutant	PSD Significance Threshold (1) (tpy)	Project-related Increase in Emissions (tpy)	
NOx	40	33.45	
SO2	40	22.9	
PM/PM10/PM2.5	25/15/10	1.84/1.84/1.84	
VOC	40	34.90	
CO	100	76.41	
H2SO4	7	1.02	
H2S	10	0.03	
TRS	10	0.03	
Fluorides	3	0	
Lead	3	0	
GHG	75,000(2)	357,402	
(1) PSD significant emission rates based on 40 CFR 52.21
(2) The PSD significant emission rate for GHG only applies if the project is subject to PSD for at least one other pollutant.  

SPECIFIC EMISSION LIMITATIONS, MONITORING, RECORDKEEPING, AND REPORTING

AQ-32201A, AQ-32201B, AQ-32202A, AQ-32201B, AQ-32203A, AQ-32203B, AQ-32204A,  and AQ-32204B -- 422 hp Diesel Firewater Pumps.
•	The firewater pumps shall be subject to the following requirements regarding maintenance and readiness testing:
a.	Testing on the pump engines shall not be conducted simultaneously (or overlap).
b.	Weekly testing shall be conducted between the hours of 10 am and 4 pm.
•	The firewater pumps are subject to and shall comply with the applicable requirements of the New Source Performance  Standards for Stationary Compression Ignition Internal Combustion Engines (40 CFR 60, Subpart IIII) and the General Provisions (40 CFR 60, Subpart A).  
•	The permittee shall continue to comply with those requirements outlined in the most recent version of the Title V Operating Permit.  
•	In addition to the requirements of NSPS Subpart IIII, the permittee shall keep records of the date and time each engine is tested for maintenance and readiness.  Any time that the engines are tested simultaneously or outside of the hours of 10 am to 4 pm shall be noted as a deviation from the permit.  

Emission Point AR-003 – Coke Conveyor and Storage
•	The permittee shall truck no more and 243,930 tons of coke to coke storage each calendar year.
•	The permittee shall record and maintain a log (hard copy or electronic) of the date and tons of coke trucked to the storage area.  The total tons of coke transported to storage via truck shall be calculated each calendar year to demonstrate compliance with the permit limit.  

Emission Point BR-003 – Plant 84 – Vacuum Distillation Unit (VDU) – Equipment Leaks
•	For equipment leak components in VOC service (as defined in §60.481a) in the Plant 84 refinery fuel gas system, the permittee shall use the following internal leak definition for valves in light liquid or gas/vapor service (as defined in §60.485a(e)), unless specified more stringent in an applicable federal standard:  No greater than 500 ppmv VOC for each valve and pressure relief device.
•	In addition to any applicable federal requirements, the permittee shall monitor the components specified above in light liquid or gas/vapor service for leaks once per quarter using an approved gas analyzer conforming to the requirements of §60.485a(a)-(b).  (Those valves meeting the definition of inaccessible or unsafe-to-monitor, as defined in §60.482-7a(g), or any equipment designated for no detectable emissions are excluded from this requirement.)
•	Any equipment found to be leaking shall be tagged and repaired within 15 days after the leak is found.  If the repair would require a unit shutdown, the repair may be delayed until a scheduled shutdown is identified for such repair.  Repaired components shall be re-monitored within 15 days of being placed back into service.
•	For any equipment designated for no detectable emissions, the permittee shall conduct a compliance test in accordance with §60.485a(c).
•	For the monitoring specified above, the permittee shall record and report the information required by the existing refinery-wide Leak Detection and Repair (LDAR) program, as specified in Condition 5.C.3.3 of the Title V Operating Permit issued October 1, 2009.

Emission Point CG-004 – Plant 5171 – Pascagoula Marketing Terminal (PMT) – Fugitive Dust Emission from Roadways in the PMT
•	The permittee shall ensure that all roadways in Plant 5171 are paved and maintained to minimize fugitive dust emissions.  The permittee shall sweep the roads twice per week using a broom street sweeper.
•	The permittee shall record and maintain a log (hard copy or electronic) of the date and time street sweeping occurred and shall also note the personnel who conducted the street sweeping.  Any roads within the PMT that were not swept and the reason they were not swept shall be recorded.

Enhanced Equipment Leak Monitoring for electric pumps and compressors
•	Complete list on pages 13 and 14 of the permit.
•	These pumps are being equipped with and shall maintain dry gas seal systems, with an inert barrier gas at higher pressure than the fluid being pumped, considered a “leakless” technology.
•	For the listed pumps and compressors which are in VOC service (as defined in §60.481a), the permittee shall use the following internal leak definition, unless specified more stringent in an applicable federal standard:  If an instrument reading of 500 ppm above background or greater is measured, a leak is detected.
•	In addition to any applicable federal requirements, the permittee shall monitor the pumps and compressors listed for leaks initially upon designation, annually, and at other times requested by the Administrator using an approved gas analyzer conforming to the requirements of §60.485a(a)-(b).
•	Any equipment found to be leaking shall be tagged and repaired within 15 days after the leak is found. A first attempt at repair shall be made no later than 5 calendar days after each leak is detected.   If the repair would require a unit shutdown, the repair may be delayed until a scheduled shutdown is identified for such repair.  Repaired components shall be re-monitored within 15 days of being placed back into service.
•	For any equipment designated for no detectable emissions, the permittee shall conduct a compliance test in accordance with §60.485a(c).
•	For the monitoring specified above, the permittee shall record and report the information required by the existing refinery-wide Leak Detection and Repair (LDAR) program, as specified in Condition 5.AC.3.3 of the Title V Operating Permit issued October 1, 2009.

OTHER REQUIREMENTS

Records:
1)	The permittee shall maintain on-site records of all required monitoring data and support information required by this permit for a period of at least five (5) years from the date of the monitoring sample, measurement, report, or application.  These records shall be made available for review upon request from DEQ personnel.

Reporting Deviations:
2)	The permittee shall report any deviations from the permit requirements, including deviations attributable to upsets, within five (5) working days of such deviation.  The report shall also include the cause of the deviation(s) and any corrective action(s) or preventive measure(s) taken.  A copy of the report shall be maintained in accordance with Part III, Condition 1.

Semiannual Reports:
3)	The permittee shall submit semiannual reports of any required monitoring by September 30 for the preceding six-month period of January 1 through June 30, and by March 31 for the preceding six-month period of July 1 through December 31.  All instances of deviations from permit requirements must be clearly identified in such reports and a responsible official must certify all required reports.  These reports may be included in the reports submitted per the Title V Operating Permit.

Fenceline Security:
4)	To preclude access by the public to refinery property for purposes of defining ambient air, the permittee shall develop and maintain a security plan addressing the following, at a minimum:
a.	Maintenance of the security fencing; 
b.	Additional security measures including patrols or cameras where there are no physical barriers (i.e., a fence or dike); and
c.	Maintenance of signage.

This “Fenceline Security Plan” shall be developed and implemented prior to startup of the Iso II Reactor Replacement Project.  The Plan shall be maintained on site and available for review by MDEQ personnel. 

Projected Actual Emissions Recordkeeping for Product Loading:
5)	For Loading Operations, including loading via pipeline, marine vessels, railcar, and truck, the permittee shall record the amount of each of the following products loaded in each calendar month: Gasoline, Jet A, Diesel, and Paraxylene.  The permittee shall calculate the VOC emissions from the loading operations for each calendar month using the same basis as in the Iso II Reactor Replacement Project PSD Application.  The permittee shall calculate and maintain a record of the annual VOC emissions, in tons per year on a calendar year basis, for a period of five (5) years following resumption of regular operations after startup of the Iso II Reactor Replacement Project. (Ref.: 40 CFR 52.21(r)(6)(iii))

6)	The permittee shall submit a report to the DEQ if the annual emissions, in tons per year, from the projects covered by this permit, exceed the baseline actual emissions (as documented in the project application), by a significant amount for any regulated NSR pollutant, and if such emissions differ from the preconstruction projection as documented and maintained in the Iso II Reactor Replacement Project PSD Application. Such report shall be submitted to the DEQ within 60 days after the end of such year. The report shall contain the following:

a.	The name, address, and telephone number of the major stationary source;
b.	The annual emissions as calculated pursuant to §52.21(r)(6)(iii); and
c.	Any other information that the owner or operator wishes to include in thereport (e.g., an explanation as the why the emissions differ from the preconstruction projection).
(Ref.: 40 CFR 52.21(r)(6)(v))

7)	The permittee shall make the information required to be documented and maintained pursuant to §52.21(r)(6) available for review upon a request for inspection by DEQ or the general public pursuant to the requirements contained in §70.4(b)(3)(viii) of this chapter. (Ref.: 40 CFR 52.21(r)(7))

NOx, PM/PM10/PM2.5, CO, and VOC Permit Limit Revisions:
8)	Upon certification of construction for the Iso II Reactor Replacement Project, the permittee shall meet the emission limits established in the following table for the given pollutants.  These limits shall supersede any limits established in a previous permit.  Where no limit is provided, as indicated by a “--“, any limit established for the pollutant in a previous permit shall continue to apply.  Compliance with the ton per year (tpy) limits shall be demonstrated 12 months from certification of construction.  

9)	Initial compliance with the limits in the following table shall be demonstrated within 18 months of certification of construction for the Iso II Reactor Replacement Project.  For those Emission Points equipped and required to operate and maintain a CEMS, the permittee may forego the initial demonstration of compliance required herein.  Compliance for the given pollutant shall be demonstrated by stack testing using the EPA Test Methods listed below, or an alternative EPA-approved method:

Pollutant 	EPA Test Method	
NOx	Method 7	
PM	Methods 1-5	
PM10/PM2.5	Method 201 or 201A and Method 202	
VOC	Method 25	
CO	Method 10 or 10A	

Stack testing shall be done with the emission unit(s) operating at or near maximum capacity.  Testing for multiple emission units with common stack(s) shall be done such that it is representative of the way in which the units are limited.       
			
For all required testing, the permittee shall submit a written test protocol at least thirty (30) days prior to the intended test date(s) to ensure that all test methods and procedures are acceptable to the DEQ.  Also, the permittee shall notify the DEQ in writing at least ten (10) days prior to the intended test date(s) so that an observer may be afforded the opportunity to witness the test.  A stack test report containing the results of the test shall be submitted within 60 days of completion of the required test.

Emission Point	Chevron Ref. ID	Heat Duty (MMBtu/hr)	NOx	PM/PM10/PM2.5	VOC	CO	SO24	
			lb/hr	ton/yr	lb/hr	ton/yr	lb/hr	ton/yr	lb/hr	ton/yr	lb/hr	
AE-013	F-1101/ 1102		--	--	5.70	19.96	--	--	--	--	--	
AF-021	F-1201/ 1301/1302	120	17.82	57.81	0.98	3.93	0.64	1.90	14.83	28.48	7.38	
AF-024	F-1304		15.95	48.18	0.83	3.29	0.54	1.58	12.36	23.74	--	
AF-025	F-1305	130	22.43	85.41	1.07	4.27	0.70	2.05	16.07	30.86	8.00	
AF-026	F-1306	55	7.62	24.09	0.45	1.81	0.30	0.87	6.80	13.06	--	
AG-041	F-1531	55	--	--	0.52	1.81	--	--	--	--	--	
AG-042	F-1532		--	--	0.35	1.38	--	--	--	--	--	
AG-043	F-1501/ 1502/1503		--	--	4.43	16.20	--	--	--	--	--	
AH-051,	F-1603		--	--	50.00	200	--	--	--	--	--	
AH-0526,7	F-1601		--	--	1.54	5.38	--	--	--	--	--	
AL-1046,7	F-2101		13.25	46.43	2.37	8.65	1.43	4.18	--	--	--	
AL-1056,7	F-2102		13.25	46.43	2.37	8.65	1.43	4.18	--	--	--	
AL-1066,7	F-2103		13.25	46.43	2.37	8.65	1.43	4.18	--	--	--	
AM-111	F-2201		13.20	46.25	0.44	1.27	--	--	--	--	--	
AN-752	F-2410		--	--	0.30	1.30	--	--	--	--	--	
AN-753	F-2440		--	--	4.18	18.31	--	--	--	--	--	
AO-0047	F-2745		6.46	18.86	0.29	1.01	--	--	--	--	--	
AO-0057	F-2765		6.46	18.86	0.29	1.01	--	--	--	--	--	
AS-011	F-34300		--	--	0.09	0.31	--	--	--	--	--	
BB-163	F-5327A/B		8.03	26.06	1.50	5.25	--	--	--	--	--	
BB-165	F-5327C		8.81	27.55	1.58	5.55	--	--	--	--	--	
BB-174	F-5337C		10.86	33.98	1.95	6.85	--	--	--	--	--	
BB-191	F-5337A		5.02	15.72	0.91	3.17	--	--	--	--	--	
BB-192	F-5337B		4.70	14.72	0.85	2.96	--	--	--	--	--	
BB-193	F-5380A		7.74	24.22	0.37	1.29	--	--	4.88	--	--	
BB-194	F-5380B		7.74	24.22	0.37	1.29	--	--	4.88	--	--	
BB-195	F-5387		--	--	0.33	1.14	--	--	--	--	--	
BE-2116,7	F-6101/ 6102		39.60	157.68	4.95	19.71	--	--	--	--	--	
BF-221	F-6210	60	9.00	31.50	0.56	1.97	0.32	0.95	7.40	--	--	
BF-222	F-6230		8.25	28.91	0.52	1.81	0.30	0.87	6.80	13.06	--	
BF-2235	F-6250		7.95	34.82	2.48	8.71	1.43	4.18	71.75	62.91	--	
BF-224	F-6260		17.16	57.82	1.03	3.61	0.59	1.73	13.60	26.11	--	
BH-231/ BH-232	F-6410/ KGT-6410		105.0	459.9	8.88	21.80.	2.04	5.96	102.56	141.68	--	
BI-245	F-6531		--	--	0.42	1.48	--	--	--	--	--	
BI-246	F-6532		6.11	17.83	0.335	1.22	--	--	--	--	--	
BK-261	F-6701		2.40	10.51	0.38	1.31	--	--	--	--	--	
BP-511	F-8110		--	--	0.61	2.14	--	--	--	--	--	
BP-512	F-8120		--	--	0.61	2.14	--	--	--	--	--	
BP-513	F-8130		--	--	0.61	2.14	--	--	--	--	--	
BQ-521	F-8300A		--	--	1.90	6.64	--	--	--	--	--	
BQ-522	F-8300B		--	--	1.90	6.64	--	--	--	--	--	
BQ-523	F-8300C		--	--	1.90	6.64	--	--	--	--	--	
BR-531	F-8400	330	15.0	52.56	3.09	10.84	2.67	7.81	74.44	104.36	--	
BS-501	F-8510		--	--	0.51	1.79	--	--	--	--	--	
BS-502	F-8560		--	--	0.75	2.63	--	--	--	--	--	
BT-541	F-8620/ KGT-8650		--	--	9.68	33.91	--	--	--	--	--	
BT-542	F-8610		--	--	0.43	1.25	--	--	--	--	--	
CH-0036,7	F-7910/ 7920/ 7930/ 7940		--	--	7.97	27.92	--	--	--	--	--	
CI-0036,7	F-8007		5.28	21.02	1.32	5.26	--	--	--	--	--	
CK-0036	F-8210		--	--	0.48	1.70	--	--	--	--	--	
CK-0046	F-8220		--	--	0.81	2.83	--	--	--	--	--	
CK-0056	F-8250		--	--	0.41	1.45	--	--	--	--	--	
CK-0066	F-8280		--	--	0.66	2.30	--	--	--	--	--	

PUBLIC PARTICIPATION

The 30-day public notice period began on December 28, 2016, with the publication of a notice in the Sun Herald and ends January 27, 2017.

RECOMMENDATION

The staff has preliminarily decided to recommend issuance of the permit to the Mississippi Environmental Quality Permit Board as shown in the draft permit.  However, the staff recommendation to the Board will be made only after a thorough consideration of all public comments.