Phillips 66 San Francisco Refinery

Phillips 66 San Francisco Refinery

[PROJECT TITLE CONTINUED: Issuance of Temporary Permit to Operate for Addition of Temporary Organic Vapor Abatement Device, Abatement 1011 (Air District Application 712566) and for Alteration to S-13, S-139, S-140, S-307, S-434. ] The Air District has issued a Temporary Permit to Operate for the following new abatement device: A-1011 Vapor Control Skid System One Split Box Vapor Sorb Scrubber followed by Two Parallel Systems consisting of one 10,000 Pound Carbon Vessel and One 5,000 Pound Carbon Vessel in series A-1011 will be used to provide further abatement to S-600 (Pretreatment Unit). S-600 is serially abated by A-622/624 Biofilter A-623/625 Activated Carbon Vessel, 4,670 pounds The following new temporary storage tank was deemed to be exempt by the Air District: S-630 Renewable Diesel Storage Tank, 8,400 gallons (Exempt) In addition to the equipment above, the Air District has issued a Temporary Permit to Operate for alterations to existing sources S-13 (U240 B-301 Process Heater), S-139 (Tank No. 204), S-140 (Tank No. 205), S-307 (U240 Unicracking Unit), and S-434 (U 246 High Pressure Reactor Train). Phillips 66 San Francisco Refinery has proposed the installation of temporary additional abatement equipment (A-1011) at S-600, Pretreatment Unit (PTU), to extend the performance of their existing abatement system. This equipment will be provided by Vapor Point, Plant# 23187, which has permitted abatement devices and supply their rental kits to refineries in multiple locations throughout California. This rental unit will capture organic vapors emitted from S-600. S-600 removes the impurities from the raw renewable feedstocks before it can be refined at the hydrotreaters. This results in organic compound emissions from this source. Currently, the abatement process relies on two biofilters and two activated carbon adsorption vessels. However, the runtime for the activated carbon vessels has proven to be significantly less than initially anticipated by Phillips 66, necessitating the addition of further abatement equipment to maintain emissions within the limits specified in the facility's Air District Permit to Operate. The pre-project process flow for S-600 consisted of the vapors being sent through the biofilters A-622/624 and then through the 4,670 pounds activated carbon vessels (A-623/625). Upon adsorption by activated carbon, the resultant clean stream was routed to the atmosphere through a stack with an emission limit of 10 ppm. Post-project, vapors will continue through the biofilter, from where they will then be routed through the rental vapor control skid (A-1011). The rental vapor control skid consists of a closed loop system which includes adsorption in a scrubber followed by more adsorption in sequential carbon beds of 5,000 pounds and 10,000 pounds carbon capacity. After exiting the rental vapor control skid, the resulting stream of vapors will go through the facility's activated carbon vessels and then out through a stack. The proposed alterations will not affect the throughput capacities of the PTU or any associated upstream and downstream equipment. Renewable Diesel (RD) produced at the facility will be used as the scrubber solvent at A-1011 to capture volatile organic compounds (VOCs). The applicant expects to replace the spent RD once per day. This involves loading and unloading 15 barrels, or 630 gallons, from the scrubber daily. The new RD will be stored in a temporary storage tank (S-630) and will be directly loaded into the scrubber after the spent RD is transferred to a vacuum truck. The vacuum truck will then unload the spent RD into existing permitted tanks, S-139 and/or S-140, for temporary storage. From there, it will be fed into S-307 and/or S-434 for reprocessing to remove any impurities absorbed by the scrubber. A portion of the now-purified RD will then be transported back to S-630 to restart the cycle. Facility emissions are not expected to increase, as the 15 barrels of RD processed at the specified sources above will be accounted for within the existing permitted emission limits. There is one process heater (5-13) associated with the U240 unicracking unit (S-307). No physical modifications will be made to the existing heater, and the permitted throughput and emission limits will remain unchanged. Due to the sources now handling a small fraction of spent RD, there will be additional material to be processed, hence, all these sources (S-13, S-139, S-140, S-307, S-434) will be considered altered. S-630 is deemed exempt in accordance with Regulation 2-1-123.3.3.2 because RD has an initial boiling point above 302°F and the initial boiling point exceeds the actual storage temperature by 180°F and did not exceed any of the backstop provisions in Regulation 2-1-319. With the addition of A-1011, Phillips 66 will add 293 unpermitted fugitive components. As a result, fugitive VOC emissions from S-600 will increase by 1.21 pounds/day. Also, the facility has installed 667 additional fugitive components at S-600 as part of their routine operation. The unpermitted fugitive emissions from these components are 1.88 pounds/day. This level of emissions fits within the permit exemption provided by Regulation 2-1-128.21 because the total unpermitted fugitive emissions of 3.09 pounds/day {1.21 pounds/day + 1.88 pounds/day) from S-600 is less than 10 pounds/day within a 12-month period and because the source will not exceed any of the backstop provisions contained in Regulation 2-1-319. However, due to the change in the method 2/3 of operation and the fact that the new abatement equipment may affect air pollutant emissions, S-600 is considered altered. Furthermore, to comply with the permit exemption in Regulation 2-1-128.21, the additional components must meet the standard control technologies outlined in the Best Available Control Technology (BACT)/TBACT Workbook. The facility has confirmed that only fugitive components meeting BACT standards will be installed, thereby fulfilling the BACT requirements. Additionally, in accordance with 128.21.5, any additional emissions from new components will be subject to offsets, which the facility will be responsible for providing. These additional components do not modify or debottleneck S-600 or any other source at this facility.

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