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Crude Flexibility and Modernization Project – Initial Permit Application

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Crude Flexibility and Modernization Project – Initial Permit Application Crude Flexibility and Modernization Project – Initial Permit Application Prepared For Texas Commission on Environmental Quality On behalf of Phillips 66 Company – Borger Refinery April 2020 Proj ec t No. P2060 TRICORD Consulting, LLC 402A West Palm Valley Blvd., PMB348 888.900.0746 TABLE OF CONTENTS 1 Introduction .................................................................................................. 1-1 1.1 Facility Information .................................................................................................... 1-1 1.2 Purpose of Request ..................................................................................................... 1-2 1.3 Federal New Source Review Permitting Applicability ......................................... 1-3 1.4 Application Fees .......................................................................................................... 1-4 1.5 Application Content ................................................................................................... 1-5 2 Process Description ..................................................................................... 2-1 2.1 Overview of Refinery Operations ............................................................................. 2-1 2.2 Detailed Process Description – Crude Units (Units 9, 10, 28, and 32) ................. 2-1 2.3 Intermediate Processing ............................................................................................. 2-2 2.4 Overview of Ancillary Operations ........................................................................... 2-6 3 Project Description ...................................................................................... 3-1 3.1 Crude Flexibility and Modernization Project – Physical and Operational Changes ................................................................................................................................... 3-1 3.2 Upstream and Downstream Affects ......................................................................... 3-4 4 Emission Calculation Methodology ........................................................ 4-1 4.1 Process Heater Emissions (EPNs: 28-H3, 28-H4, and 88-H1) ............................... 4-1 4.2 Continuous Catalytic Reformer Vent (EPN: 88-V1) ............................................... 4-3 4.3 Equipment Leak Fugitives (EPN: F-CRUDEFLEX) ............................................... 4-3 4.4 Planned Maintenance, Startup, and Shutdown (EPN: MSS) ................................ 4-4 4.5 Process Unit Sump (EPNs: F-SUMPCCR) ............................................................... 4-6 5 Best Available Control Technology – Criteria Pollutants ................... 5-1 5.1 Process Heaters (EPNs: 28-H3, 28-H4, and 88-H1) ................................................ 5-3 5.2 CCR Regeneration Vent (EPN: 88-V1) ..................................................................... 5-6 5.3 Fugitive Piping Components (EPN: F-CrudeFlex) ................................................ 5-8 5.4 Planned MSS Activities (EPN: MSS) ........................................................................ 5-9 5.5 Wastewater Collection (EPN: F-SUMPCCR) ........................................................ 5-10 6 Best Available Control Technology – Greenhouse Gas Pollutants ... 6-1 PERMIT AMENDMENT FOR FLEXIBLE PERMIT 9868A – PHILLIPS 66 BORGER REFINERY i 6.1 Process Heaters (EPNs: 28-H3, 28-H4, and 88-H1) ................................................ 6-1 6.2 CCR Regeneration Vent (88-V1) ............................................................................... 6-2 6.3 Fugitive Piping Components (EPN: F-CrudeFlex) ................................................ 6-3 6.4 Planned MSS Activities (EPN: MSS) ........................................................................ 6-3 7 Regulatory Applicability ............................................................................ 7-1 7.1 General Application Requirements – §116.111(a)(2)(A) ........................................ 7-1 8 Air Quality Analysis ................................................................................... 8-1 LIST OF FIGURES Figure 1-1 Area Map ................................................................................................................. 1-7 Figure 1-2 Plot Plan ................................................................................................................... 1-8 Figure 2-1 Refinery Block Flow Diagram .............................................................................. 2-8 Figure 2-2 Simplified Process Flow Diagram - CCR ............................................................ 2-9 Figure 2-3 Simplified Process Flow Diagram – Methanator ............................................. 2-10 Figure 2-4 Simplified Process Flow Diagram – Naphtha Splitter .................................... 2-11 LIST OF TABLES Table 1-1: PTE Comparison ..................................................................................................... 1-3 Table 4-1: List of New/Modified Sources .............................................................................. 4-1 Table 5-1: BACT Summary ...................................................................................................... 5-2 Table 8-1: Summary of Modeling Results (Non-PSD) ......................................................... 8-1 LIST OF APPENDICES Appendix A: TCEQ Forms and Tables Appendix B: BACT Analyses - Supporting Documentation Appendix C: Criteria Pollutant Emission Calculations Appendix D: PSD Applicability Determination – Criteria Pollutants Appendix E: GHG Pollutant Emission Calculations Appendix F: Air Quality Analysis INITIAL PERMIT APPLICATION – CRUDE FLEXIBILITY AND MODERNIZATION PROJECT ii 1 INTRODUCTION WRB Refining, LP is a 50/50 partnership between the Phillips 66 Company (Phillips 66) and Cenovus Energy. WRB Refining, LP owns the Borger Refinery, which is operated by Phillips 66. Phillips 66 Borger Refinery is requesting an initial New Source Review (NSR) Permit to authorize the construction of new emission sources and the modification of existing emission sources associated with a planned p roject to modernize the refinery and allow for more variability in refinery crude slates. Phillips 66 Borger Refinery is applying for an initial NSR permit under the requirements of Title 30 of the Texas Administrative Code (30 TAC), Chapter 116, Subchapter B. Phillips 66 Borger Refinery plans to construct a new Continuous Catalytic Reformer (CCR) Unit and a new Naphtha Splitter Unit, install new and more efficient crude charge heaters to replace the existing crude charge heaters, and make modifications in other selected r efinery p rocess units, including shutting down certain older process units. The ph ysical changes will increase overall refinery efficiency and accommodate more crude slate variability. For example, the new CCR Unit will replace existing semi-regenerative reforming units, which operate with older and less efficient technology. Annual site-wide emissions for most pollutants will decrease a result of the c hanges. This project is her ein referred to as the “Crude Flexibility and Modernization Project.” 1.1 Facility Information The Phillips 66 Borger Refinery is an integrated petroleum refinery. Crude oil is delivered to the refinery and then processed and r efined into various petrochemical products and commercial petroleum products s uch as propane, gasoline, jet fuel, diesel fuel, and petroleum coke. The TCEQ Customer Number (CN) for Phillips 66 Company is CN604065912. The Regulated Entity Number (RN) for t he Borger Ref inery is RN102495884. The facility TCEQ account number is HW-0018-P. The Phillips 66 Borger Refinery is located on State Spur 191 i n Borger, Hutchinson County, Texas. Figure 1-1 is an area map showing the refinery l ocation relative to nea rby t opographic features. This map is based on Google Earth imagery, and it indicates the property line and a 3,000-foot radius and 1-mile radius from the permitted facility. There are no schools within 3,000 feet of the permitted facility. The facility plot plan, Figure 1-2, includes the north direction, and indicates the new equipment associated with the project. A more detailed plot plan will also be included in the Air Quality Analysis (AQA), which will be submitted subsequent to this initial application. The Phillips 66 Borger Refinery currently operates under the following case-by-case construction and operating permits. Construction Permits • Flexible Permit 9868A – normal emissions from most refinery sources INITIAL PERMIT APPLICATION – CRUDE FLEXIBILITY AND MODERNIZATION PROJECT 1-1 • NSR Permit 71385 – Unit 45 (Mercaptan Unit) • NSR Permit 80799 – planned maintenance, startup, and shutdown (MSS) emissions for refinery sources • NSR Permit 85872 – Boilers • NSR Permit 155341 –Johnson Tank Farm (JTF) sources The refinery also has several active standard exemptions, permits by rule (PBRs), and standard permits (SPs). Operating Permits • Standard Operating Permit (SOP) O1440 – most refinery sources • SOP O2166 – Unit 45 (Mercaptan Unit) • SOP O4130 – JTF sources Phillips 66 Borger Refinery is proposing to authorize the emission increases associated with the Crude Flexibility and Modernization Project under a new Subchapter B NSR permit and a new SOP. 1.2 Purpose of Request The Phillips 66 Borger Refinery is currently able to process up to 165 thousand barrels per day (MBPD) of crude oil. The refinery currently processes primarily
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