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PERMIT-TO-OPERATE (PO)
&
PERMIT-TO-CONSTRUCT (PC)

COMPANY NAME AND ADDRESS

ExxonMobil Corporation
3700 W. 190
TH
Street
Torrance, CA 90509-2929

Contact : Valerie Tse
Telephone: (310) 212-1781
Email : valerie.b.tse@exxonmobil.com
EQUIPMENT LOCATION

ExxonMobil Torrance Refinery
3700 W. 190
th
Street
Torrance, CA 90509-2929

Facility ID: 47882
Unitized ID: 800089


SECTION D: EQUIPMENT DESCRIPTION

Equipment

ID
No.
Connected
To
RECLAIM
Source Type/
Monitoring
Unit
Emission`
And
Requirements
Conditions
Process 6: HYDROGEN PRODUCTION UNITS

System 3: HYDROGEN PRODUCTION UNITS HEATERS

HEATER, HYDROGEN
REFORMING, 24F-1,
NATURAL GAS, PSA
GAS, REFINERY GAS,
931 MMBTU/HR WITH
A/N: 440468 483736

BURNER, NATURAL
GAS, PSA GAS,
REFINERY GAS,
WITH LOW NOX
BURNER, 108
TOTAL; 931
MMBTU/HR

D925 C395 D926 NOX:
MAJOR
SOURCE**
SOX:
MAJOR
SOURCE**
CO: 88.54 LBS/HR (7) [RULE
1303(b)(2)-Offset, 5-10-1996];
CO: 2000 PPMV (5) [RULE 407,
4-2-1982]; NOX: 9 PPMV AT 15
MINS. (4) [RULE 2005,
5-6-2005]; NOX: 42 LBS/HR (7)
[RULE 2005, 5-6-2005]; PM: (9)
[RULE 404, 2-7-1986]; PM: 0.1
GRAINS/SCF (5) [RULE 409, 8-
7-1981]; PM10: 24.94 LBS/HR
(7) [RULE 1303(b)(2)-Offset, 5-
10-1996]; ROG: 62.35 LBS/HR
(7) [RULE 1303(b)(2)-Offset,
5-10-1996]; SO2: 20 PPMV (8)
[40CFR 60 Subpart 1, 6-24-
2008; CONSENT DECREE
CIVIL CASE No. 05 C 5809,
12-13-2005]; SOX: 17.03
LBS/HR (7) [RULE 2005,
5-6-2005]
A99.xx,
A195.1,
B61.1,
B61.3,
C1.12,
D28.23,
D82.1,
D90.xx,
D90.yy,
D182.3,
D182.4,
E54.xx,
E193.16,
H23.33,
K171.5




Continue on the Next Page


J. Pan

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Process 6: HYDROGEN PRODUCTION UNITS

System 3: HYDROGEN PRODUCTION UNITS HEATERS

FUGITIVE EMISSIONS,
MISCELLANEOUS
A/N: 440468 483736
D1807 HAP: (10) [40CFR 63 Subpart
CC, #5A,5-25-2001]

H23.34

STACK, COMMON TO
GAS TURBINE 24J-01 &
HEATER 24F-1
A/N: 440468 483736
S1732 C395

SECTION H: EQUIPMENT DESCRIPTION

Equipment

ID
No.
Connected
To
RECLAIM
Source
Type/
Monitoring
Unit
Emission`
And Requirements
Conditions
Process 18: ELECTRICITY GENERATION
System 1: COGENERATION SYSTEM
S15.1,
S31.2
TURBINE, 24J-01,
COGENERATION
SYSTEM, (COMBINED
CYCLE), AIR
COMPRESSOR, BUTANE,
NATURAL GAS,
PROPANE, REFINERY
GAS, GE MODEL 52614P,
COMBUSTOR WITH
STEAM INJECTION, GAS
TURBINE, 316
MMBTU/HR WITH
A/N: 435110 483739
Permit to Construct Issued:
06/28/06 06/xx/2012

GENERATOR,
ELECTRIC, 22.83 MW
D926 D925 NOX: MAJOR
SOURCE**;
SOX: MAJOR
SOURCE**
CO: 88.54 LBS/HR (7) [RULE
1303(b)(2)-Offset, 5-10-1996];
NOX: 9 PPMV (4) [RULE
2005, 5-6-2005]; NOX: 42
LBS/HR (7) [RULE 2005, 5-6-
2005]; NOX: 210 160 PPMV
(8) [40CFR 60 Subpart GG, 2-
24-2006]; PM: 0.01
GRAINS/SCF (5) [RULE 475,
10-8-1976; RULE 475,8-7-
1978]; PM: 0.1
GRAINS/SCF (5B) [RULE
409, 8-7-1981]; PM: 11
LBS/HR (5A) [RULE 475,
10-8-1976; RULE 475,
8-7-1978]; PM10: 24.94
LBS/HR (7) [RULE 1303(b)(2)-
Offset, 5-10-1996]; ROG:62.35
LBS/HR (7) [RULE 1303(b)(2)-
Offset, 5-10-1996]; SO2: 20
PPMV (8A) [40CFR 60
Subpart 1, 6-24-2008];SO2:
150 PPMV (8) [40CFR 60
Subpart GG, 2-24-2006];SOX:
17.03 LBS/HR (7) [RULE 2005,
5-6-2005]



A99.xx,
A195.1,
A327.1,
B61.4,
B61.6,
D28.22,
D28.23,
D82.3,
D82.4,
D90.3,
D90.yy
D182.3,
D182.4,
H23.15,
K171.5

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Process 18: ELECTRICITY GENERATION
System 1: COGENERATION SYSTEM
S15.1,
S31.2
TURBINE, 24J-2,
UNFIRED, STEAM
TURBINE WITH
A/N: 435110 483739
Permit to Construct Issued:
06/28/06 12/xx/2012

GENERATOR,
ELECTRIC, 19.3 MW
D2239 K171.5

DEVICE CONDITIONS

SECTION D

A. Emission Limits

A99.xx The 42 lbs/hr NOX limit(s) shall not apply during startup, shutdown or malfunction.

For purpose of this condition, start-up and shutdown shall be defined as the time
period during the startup and shutdown of the heater unit when the temperature of the
exhaust gas at the inlet to SCR is below 550 degree F.

[RULE 2005 , 5-6-2005]

[Devices subject to this condition : D925]

A195.1 The 9 PPMV NOX emission limit(s) is averaged over 15 minutes corrected to 15%
excess oxygen, dry basis.

For purpose of this condition, the limit applies at all times except during startup,
shutdown, or malfunction when the temperature of the exhaust gas at the inlet to the
SCR is below 550 degrees F.

[RULE 2005 , 5-6-2005]

[Devices subject to this condition : D925]

B. Material/Fuel Type Limits


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B61.1 The operator shall only use fuel gas containing the following specified compounds:

Compound ppm by volume
total sulfur calculated as H2S less than 100

[RULE 2005, 5-9-2006]
[Devices subject to this condition : D925, D1236, D1239]

B61.3 The operator shall not use fuel gas containing the following specified compounds:

Compound ppm by volume
H2S greater than 160

[40CFR 60 Subpart J, 6-24-2008; CONSENT DECREE CIVIL CASE No. 05 C 5809,
12-13-2005]

[Devices subject to this condition : D925]

C. Throughput/Operating Limitation

C1.12 The operator shall limit the firing rate to no more than 931 MM Btu per hour.

[RULE 1303(b)(2)-Offset, 5-10-1996; RULE 2005, 5-6-2005]

[Devices subject to this condition : D925]

D. Monitoring/Testing Requirements

D28.23 The operator shall conduct source test(s) in accordance with the following
specifications:

The test shall be conducted yearly after the initial performance test using the test
protocol approved by the District.

The test shall be conducted to determine the emission rates (lb/hr) of ROG, CO &
PM emissions at the outlet.

The District shall be notified of the date and time of the test at least 10 days prior to
the test.


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[RULE 1303(b)(2)-Offset, 5-10-1996; RULE 3004(a)(4) - Periodic Monitoring,
12-12-1997]

[Devices subject to this condition : D925]

D82.1 The operator shall install and maintain a CEMS to measure the following parameters:

SOX concentration in ppmv

Oxygen concentration in percent volume

[RULE 2011, 5-6-2005; 40CFR 60 Subpart 1, 6-24-2008; CONSENT DECREE
CIVIL CASE No. 05 C 5809, 12-13-2005]

[Devices subject to this condition : D925, C952]

D90.xx The operator shall continuously monitor the total sulfur concentration in fuel gases
before being burned in this device according to the following specifications:

During times when the operator uses refinery fuel gas from 8C-5 (Device D500), the
operator will use Gas Chromatography (GC 33) to monitor total sulfur concentration
for the 8C-5 (Device D500) refinery fuel gas.

During times when the operator uses refinery fuel gas from 64C-4 (Device D838),
the operator will use a SOx CEMS on RECLAIM SOx reference source 75F-1
(Device D805) or 3F-3/4 (Device D930/D931 with common Device S1975) that
only use refinery fuel gas from fuel gas mix drum 64C-4 (Device D838) to calculate
total sulfur concentration in the 64C-4 (Device D838) refinery fuel gas.

For the purposes of this condition and with regards to total sulfur concentration,
natural gas and PSA waste gas used in 24F-1 (Device D925) shall be deemed to
meet SCAQMD Clean Fuels Policy BACT Guidelines (10-20-2000). As such, no
additional monitoring shall be required for these fuels.

The operator shall also install and maintain a device to continuously record the
parameter being monitored.

[SCAQMD Rule 2005, 5-6-2005]

[Devices subject to this condition: D925]

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D90.yy The operator shall periodically monitor the H2S concentration at the inlet of this
device according to the following specifications:

The Alternative Monitoring Plan (AMP) approved by the United States
Environmental Protection Agency (USEPA) on June 2, 2009 for the periodic
monitoring and reporting of H2S concentration for the off-gas streams from Heater
24F-1 (D925) in P6/S3 and Gas Turbine Generator 24J-1 (D926) in P18/S1.

The operator shall maintain records in a manner approved by the District, to
demonstrate compliance with the requirements specified under this section.

[40CFR 60 Subpart A, 6-13-2007; 40CFR 60 Subpart 1, 6-24-2008; CONSENT
DECREE CIVIL CASE No. 05 C 5809, 12-13-2005]

[Devices subject to this condition : D925]

D182.3 The operator shall test this equipment in accordance with the following specifications:

To determine the control efficiency of the SCR, after June 29, 2006, the operator
shall, prior to the first physical modification where a permit to construct is required,
file a permit application for that modification and include with the application a
method for determining the control efficiency of the SCR

Such method may include, sampling port at the inlet of the SCR, monitor/analyzer for
NOx concentration at the inlet of the SCR, or other equivalent method to determine
SCR efficiency as approved by the Executive Officer

Until the above method(s) is approved, the operator shall keep record of the ammonia
injection rate and shall make it available upon AQMD request

Once the above method(s) is approved, the operator shall conduct the SCR control
efficiency determination and annually thereafter

[RULE 2005, 5-6-2005; RULE 3004(a)(4)-Periodic Monitoring, 12-12-1997]

[Devices subject to this condition : D925]

D182.4 The operator shall test this equipment in accordance with the following specifications:


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To determine the PM10 emissions, after June 29, 2006, the operator shall, prior to the
first physical modification where a permit to construct is required, file a permit
application for that modification and include with the application a method for
determining the PM10 emissions. Such method shall be provided in compliance with
EPA or SCAQMD source test method

Until such time that a permit is issued for the modification, the PM10 emissions are
assumed to equal to the PM emissions

Once the above method(s) is approved, the operator shall conduct the PM10
emissions determination and annually thereafter

[RULE 1303(b)(2)-Offset, 5-10-1996; 3004(a)(4)-Periodic Monitoring, 12-12-
1997]

[Devices subject to this condition : D925]

E. Equipment Operation/Construction Requirements

E54.xx The operator is not required to vent this equipment to the following equipment if all
of the requirements listed below are met:

Device ID: C395 [SELECTIVE CATALYTIC REDUCTION REACTOR]

Requirement number 1: During startups and shutdowns. For the purpose of
this condition, start-up and shutdown shall be defined as the time period
during the startup and shutdown of the heater unit when the temperature of the
exhaust gas at the inlet to SCR is below 550 degree F.

Requirement number 2: The operator shall limit startups and shutdowns to no
more than 60 hours, not including the refractory dryout period. Refractory
dryout shall be permitted up to a total of 144 consecutive hours to allow the
curing of refractory materials.

Requirement number 3: During startup and shutdown, the operator shall use
244.05 lbs NOx per hour for reporting purposes under RECLAIM.

Requirement number 4: ExxonMobil shall submit a report to the District
annually with a summary of the number of hours for startups and shutdowns.


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[RULE 2012, 5-6-2005]

[Devices subject to this condition : D925]

E193.16 The operator shall operate and maintain this equipment according to the following
specifications:

The operator shall comply with all applicable requirements specified in
Subpart A of the 40CFR60

[40CFR 60 Subpart A, 5-16-2007; CONSENT DECREE CIVIL CASE No. 05 C
5809, 12-13-2005]

[Devices subject to this condition :. D925.]

H. Applicable Rules

H23.33 This equipment is subject to the applicable requirements of the following rules or
regulations:

Contaminant Rule Rule/Subpart
SOX 40CFR60, SUBPART J

[40CFR 60 Subpart 1, 10-4-1991]

[Devices subject to this condition : D925]

H23.34 This equipment is subject to the applicable requirements of the following rules or
regulations:

Contaminant Rule Rule/Subpart
VOC District Rule 1173
VOC 40CFR60, SUBPART GGGa

This equipment was subject to the applicable requirements of 40CFR60 Subpart GGG
per Consent Decree Civil Case No. 05 C 5809 dated 12-13-2005. This equipment is
now subject to the applicable requirements of 40CFR60 Subpart GGGa per
ExxonMobil's notification to EPA dated 08-24-2009.


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[Rule 1173, 5-13-1994; Rule 1173, 2-6-2009; 40CFR 60 Subpart GGGa, 6-2-2008;
CONSENT DECREE CIVIL CASE No. 05 C 5809, 12-13-2005]

[Devices subject to this condition : D1807.]

K. Recordkeeping/Reporting

K171.5 The operator shall provide to the District the following items:

Final designed P&ID within 60 days after construction is completed including, but
not limited to heating rate and fuel lines for heater 24F-1

[RULE 1301, 12-7-1995]

[Devices subject to this condition : D925]

Note: this is a P/C condition that is no longer applicable; same condition in Sec H still is tagged to Gas Turbine
device D926 and will remain as such

SECTION H

SYSTEM CONDITIONS

S15.1 The vent gases from all affected devices of this process/system shall be vented as
follows:

All emergency vent gases shall be directed to a blowdown flare system except
Devices IDs D35, D1250, D2145, D57 TO D62, D71, D68, D86-D91, D98, D152,
D237, D349, D360, D629, D630, D631, D657, D638, D668, D671 , D1503-D1505,
D1507 that vent to the atmosphere.

This process/system shall not be operated unless the blowdown flare system is in full
use and has a valid permit to receive vent gases from this system.

[RULE 1303(a)(1)-BACT, 5-10-1996; RULE 1303(b)(2)-Offset, 5-10-1996]

[Systems subject to this condition : Process 1, System 1 , 2 , 3 , 4 , 7; Process 2 ,
System 1 , 2 , 4 , 5; Process 3, System 1 , 5 , 7; Process 4, System 1 , 3 , 5; Process 5,
System 1 , 2; Process 6, System 1 , 2; Process 7, System 1; Process 8, System 1 , 2 , 3
,4 , 6; Process 9, System 1 , 2 , 5; Process 11, System 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 ,

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11 , 12; Process 12, System 1 , 2 , 3; Process 13, System 1 , 2 , 3 , 4; Process 17 ,
System 5 , 8 , 11; Process 18, System 1; Process 19, System 3; Process 23, System 1]

S31.2 The following BACT requirements shall apply to VOC service fugitive components
associated with the devices that are covered by application number(s) 280605,
384499, 385155, 389291, 389292, 411508, 411586, 422931, 435110, 435111 &
471343:

All valves shall be bellow-sealed except in the following applications: valves in
heavy liquid service, control valves, instrument piping/tubing valves, valves
requiring torsional stem motion, situations where valve failure could pose safety
hazard (e.g., drain valves with stems in the horizontal position), retrofit/special
application valves with space limitation and valves not commercially available .
District shall approve all exceptions to this requirement.

All valves and new major components shall be physically identified in the field
With special markings that distinguish the components from nonBACT components.
Additionally, all new components shall be identified as BACT components in the
record.

All valves shall be inspected monthly using EPA Reference Method 21. The
operator may revert to quarterly inspection upon District approval, after two
consecutive monthly inspections in which only two percent or less are found to
be leaking above 500 ppmv. For leaks greater than 500 ppmv above background,
repair shall be attempted within five (5) days of detection. Repair or replacement
shall be completed within 15 days, unless demonstrated otherwise.

The operator shall keep records of the monthly inspections, subsequent repairs
and reinspections, if any, in a manner approved by the District.

The operator shall provide the following information to the District no later than
60 days after initial startup of the equipment in the system:

a ) Piping and instrumentation diagrams (or some other equivalent District-approved
diagrams) that identify all valves. The operator shall also provide a listing of all
valves (bellows and non-bellows) categorized by location, type, size, accessibility,
and service; and


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b) Recalculation of fugitive emissions based on actual fugitive components installed
and removed from service. All valves shall be categorized by tag number, type, size,
body material, service, and reason(s) why bellow seal valves were not used.

[RULE 1303(a)(1)-BACT, 5-10-1996; RULE 1303(b)(2)-Offset, 5-10-1996]

[Systems subject to this condition : Process 4, System 1 , 3; Process 6, System 2 ;
Process 7, System 3; Process 9, System 6; Process 13, System 1 , 3 , 4 , 11; Process
18, System 1]

A. Emission Limits

A99.xx The 42 lbs/hr NOX limit(s) shall not apply during startup, shutdown or malfunction.

For purpose of this condition, start-up and shutdown shall be defined as the time
period during the startup and shutdown of the heater unit when the temperature of the
exhaust gas at the inlet to SCR is below 550 degree F.

[RULE 2005 , 5-6-2005]

[Devices subject to this condition : D925]

A195.1 The 9 PPMV NOX emission limit(s) is averaged over 15 minutes corrected to 15%
excess oxygen, dry basis.

For purpose of this condition, the limit applies at all times except during startup,
shutdown, or malfunction when the temperature of the exhaust gas at the inlet to the
SCR is below 550 degrees F.

[RULE 2005 , 5-6-2005]

[Devices subject to this condition : D925]

A327.1 For the purpose of determining compliance with District Rule 476, combustion
contaminant emissions may exceed the concentration limit or the mass emission limit
listed, but not both limits at the same time.

[RULE 475, 10-8-1976; RULE 475, 8-7-1978]

[Devices subject to this condition : D926.]

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B. Material/Fuel Type Limits

B61.4 The operator shall not use fuel gas containing the following specified compounds:

Compound ppm by volume
Total sulfur compounds 30
calculated as H2S greater
than

[RULE 2005, 5-6-2005]

[Devices subject to this condition : D926]

B61.6 The operator shall not use fuel gas containing the following specified compounds:

Compound ppm by volume
H2S greater than 160

[40CFR 60 Subpart 1, 6-24-2008]

[Devices subject to this condition : D926]

D. Monitoring/Testing Requirements

D28.22 The operator shall conduct source test(s) in accordance with the following
specifications:

The test shall be conducted within 90 days from the complete modification of the fuel
gas optimization project using the test protocol approved by the District.

The test shall be conducted to determine the CO, NOx, SOx, SO2 & O2 concentration
at the outlet.

The test shall be conducted to determine the NH3 emissions at the outlet.

The test shall be conducted to determine the emission rates (lb/hr) of ROG, CO, PM,
NOx & SOx emissions at the outlet.


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The District shall be notified of the date and time of the test at least 10 days prior to
the test.

[RULE 1303(b)(2)-Offset, 5-10-1996; RULE 2005, 5-6-2005; RULE 3004(a)(4)-
Periodic Monitoring, 12-12-1997]

[Devices subject to this condition : D926]

D28.23 The operator shall conduct source test(s) in accordance with the following
specifications:

The test shall be conducted yearly after the initial performance test using the test
protocol approved by the District.

The test shall be conducted to determine the emission rates (lb/hr) of ROG, CO & PM
emissions at the outlet.

The District shall be notified of the date and time of the test at least 10 days prior to
the test.

[RULE 1303(b)(2)-Offset, 5-10-1996; RULE 3004(a)(4)-Periodic Monitoring, 12-12-
1997]

[Devices subject to this condition : D926]

D82.3 The operator shall install and maintain a CEMS to measure the following parameters:

SOX concentration in ppmv.

Oxygen concentration in percent volume.

[RULE 2011, 5-6-2005; 40CFR 60 Subpart J, 6-24-2008]

[Devices subject to this condition : D926]

D82.4 The operator shall install and maintain a CEMS to measure the following parameters:

NOX concentration in ppmv

SOX concentration in ppmv

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Oxygen concentration in percent volume

[RULE 2011, 5-6-2005; RULE 2012, 5-6-2005; 40CFR 60 Subpart GG, 2-24-2006]

[Devices subject to this condition : D926]

D90.3 The operator shall continuously monitor the H2S concentration in the fuel gases before
being burned in this device according to the following specifications:

The operator shall monitor the concentration of the total sulfur compounds at the
outlet of the fuel gas mix drum/knockout pot 24C-1 (Device D2234).

The operator shall use Gas Chromatography (GC 61) to monitor the parameter.

The operator shall also install and maintain a device to continuously record the
parameter being monitored.

[RULE 2005, 5-6-2005; RULE 3004(a)(4)-Periodic Monitoring, 12-12-1997]

[Devices subject to this condition : D926]

D90.yy The operator shall periodically monitor the H2S concentration at the inlet of this
device according to the following specifications:

The Alternative Monitoring Plan (AMP) approved by the United States
Environmental Protection Agency (USEPA) on June 2, 2009 for the periodic
monitoring and reporting of H2S concentration for the off-gas streams from Heater
24F-1 (D925) in P6/S3 and Gas Turbine Generator 24J-1 (D926) in P18/S1.

The operator shall maintain records in a manner approved by the District, to
demonstrate compliance with the requirements specified under this section.

[40CFR 60 Subpart A, 6-13-2007; 40CFR 60 Subpart 1, 6-24-2008; CONSENT
DECREE CIVIL CASE No. 05 C 5809, 12-13-2005]

[Devices subject to this condition : D926]

D182.3 The operator shall test this equipment in accordance with the following
specifications:

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To determine the control efficiency of the SCR, after June 29, 2006, the operator
shall, prior to the first physical modification where a permit to construct is required,
file a permit application for that modification and include with the application a
method for determining the control efficiency of the SCR

Such method may include, sampling port at the inlet of the SCR, monitor/analyzer for
NOx concentration at the inlet of the SCR, or other equivalent method to determine
SCR efficiency as approved by the Executive Officer

Until the above method(s) is approved, the operator shall keep record of the ammonia
injection rate and shall make it available upon AQMD request

Once the above method(s) is approved, the operator shall conduct the SCR
control efficiency determination and annually thereafter

[RULE 2005, 5-6-2005; RULE 3004(a)(4)-Periodic Monitoring, 12-12-1997]

[Devices subject to this condition : D926]


D182.4 The operator shall test this equipment in accordance with the following
specifications:

To determine the PM10 emissions, after June 29, 2006, the operator shall, prior to the
first physical modification where a permit to construct is required, file a permit
application for that modification and include with the application a method for
determining the PM10 emissions. Such method shall be provided in compliance with
EPA or SCAQMD source test method

Until such time that a permit is issued for the modification, the PM10 emissions are
assumed to equal to the PM emissions

Once the above method(s) is approved, the operator shall conduct the PM10
emissions determination and annually thereafter

[RULE 1303(b)(2)-Offset, 5-10-1996; RULE 3004(a)(4)-Periodic Monitoring,
12-12-1997]

[Devices subject to this condition : D926]

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H. Applicable Rules

H23.15 This equipment is subject to the applicable requirements of the following rules or
regulations:

Contaminant Rule Rule/Subpart
NOx 40CFR60, Subpart GG
SOx 40CFR60, Subpart GG
SOx 40CFR60, Subpart J

[40CFR 60 Subpart GG, 2-24-2006; 40CFR60 Subpart 1, 6-24-2008]

[Devices subject to this condition : D926]


K. Recordkeeping/Reporting

K171.5 The operator shall provide to the District the following items:

Final designed P&ID within 60 days after construction is completed including, but
not limited to heating rate and fuel lines for heater 24F-1.

[RULE 1301, 12-7-1995]

[Devices subject to this condition : D926, D2239]


BACKGROUND

The ExxonMobil Oil Corporation (ExxonMobil) operates a refinery in the City of Torrance.
The South Coast Air Quality Management District (District) currently classifies this facility as
a Sulfur Oxides (SOx) and Nitrous Oxides (NOx) Regional Clean Air Market Incentives
Market (RECLAIM) facility and a Title V facility. The District has issued the final Title V
permit to ExxonMobil on January 25, 2010.

On June 10, 2008, ExxonMobil submitted 2 applications for Change of Conditions for two
existing equipment located at its Torrance refinery. Specifically, the company requests that
the District add a condition to its Process Heater 24F-1 (D925) and its Cogeneration Turbine
24J-1 (D926) to clarify that during startup of its heater and turbine, they do not need to

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operate its selective catalytic reduction (SCR) control (C395) identified in Process 6 of
System 4 of its facility permit and do not need to comply with the NOx concentration limit
imposed on its Turbine 24J-1 and Process Heater 24F-1 by permit condition A195.1.
ExxonMobil states in its applications that during startup its Process Heater 24F-1 needs time
to reach the 550 degrees Fahrenheit required by Condition E71.7 for Ammonia (NH3)
injection imposed on its SCR control. As a result, ExxonMobil requests that the District
clearly state that during startup NH3 cannot be injected (technologically infeasible) and that
the NOx concentration limit is not applicable during startup until the flue gas temperature of
the process heater reaches 550Fahrenheit and above. The two existing permit conditions that
implicitly allow the process heater to exceed the NOx limit during startup are as follows:

A195.1 The 9 PPMV NOX emission limit(s) is averaged over 15 minutes
corrected to 15% excess oxygen, dry basis.

[RULE 1303(a)(1)-BACT, 5-10-1996; RULE 1303(a)(1)-BACT,
12-6-2002]

[Devices subject to this condition : D925, D926]

E71.7 The operator shall only inject NH3 into this equipment if the flue gas
inlet temperature is at least 550 degrees F.

[RULE 1303(a)(1)-BACT, 5-10-1996]

[Devices subject to this condition: C301, C395, C916, C923, C1238, C1241]

Although the current permit allows ExxonMobil to bypass the SCR during start-up
(<550F), it does not implicitly states that ExxonMobil does not need to meet the NOx
limit in A195.1 during start-up, shut-down or malfunction when the SCR inlet
temperature is expected to be less than 550F. As a result, ExxonMobil has applied for a
Variance to the AQMD Hearing Board for planned start-ups and shutdowns, to allow
them to exceed the 9 ppmv limit in A195.1. Therefore, ExxonMobil submitted these
applications to allow them to exceed the NOx limits during start-ups or shutdown
without a variance.


PERMIT HISTORY

The ExxonMobils Process Heater 24F-1 and Turbine 24J-1 are existing devices that require
POs from the District for their operations. Therefore, the District has records of the permits

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for both devices past operations. The following table gives the permits that the District has
issued for the two devices:
Table 1: Permit History

HEATER 24F-1 (APPLICATION NO. 483736)
Application
No.
Permit No.]
Date
Submitted or
Issued
Application
Type

Application
Status
Purpose
483736 6/10/2008 60 20 Subject application to allow SCR bypass
during start-up and shut-down
455135 4/16/2010 60 20
(will be
cancelled)
Applicant submitted the applications to
include Subpart J requirements as
required under its consent decree. This
application has been merged with the
483736 and will be cancelled.
440468
[F82841]
6/28/2006 PO Active ExxonMobil submitted the application
the application as part of its fuel
optimization project to increase the
amount of waste recovered for use from
its hydrogen plant.
298485
[D95235]
12/28/1995 PO Inactive ExxonMobil submitted the application to
increase the rating of the heater from 788
to 931 MMBTU/HR.
133686 4/16/1987 PC Inactive New construction.

COGENERATION SYSTEM/TURBINE 241-1 (APPLICATION NO. 483739)
Application
No.
Permit No.]
Date
Submitted or
Issued
Application
Type

Application
Status
Purpose
500502 7/9/2009 63 21 Subsequent application to 483739,
currently open will be process after P/C
is issued to 483739
483739 6/10/2008 60 20 Subject application to allow SCR bypass
during start-up and shut-down
435110 6/29/2006 PC Active ExxonMobil submitted the application
the application as part of its fuel
optimization project to increase the
amount of waste recovered for use from
its hydrogen plant.
298671
[D95326]
12/28/1995 PO Active ExxonMobil submitted the application to
replace the existing turbine to
accommodate the increased air flow

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requirements from the increase in
capacity of Reformer Heater 24F-1.
175643 8/1/1989 PC Inactive ExxonMobil submitted the application to
modify combustor burner to have the
ability to burn natural gas, butane,
propane, and refinery gas.
139735 12/01/1987 PC Inactive New construction.

FEE ANALYSIS

The following table presents the Districts analysis of the required processing fees for the
subject two applications:
Table 2: Fee Analysis

Equipment Type Fee
Schedule
Required
Fee

A/N 455135 - Process Heater 24F-1 > 50 MMBTU/hr
BCAT 019605
E $3,318.36
A/N 483736 - Process Heater 24F-1 > 50 MMBTU/hr
BCAT 019605
E $4,015.22
A/N 483739 - Congeneration Turbine 24J-1 < 50 MW,
Other Fuel; BCAT 053708
D $2,734.71
Total Required Processing Fee $10,068.29
Requested Expedited Fee (483736/483739 only) $3,374.97
Total Fee Required $13,443.26
Total Permit Processing Fees Paid $13,443.26
Refund (Deficit) $0.00 ($0.00)
Note that ExxonMobil submitted its two applications to the District prior to 1 July 2008. Therefore,
2007 fee schedules apply, which is used to calculate the required fees.

The Districts fee analysis shows that ExxonMobil has paid the exact permit processing fees.
No additional fee or refund is required.


COMPLIANCE RECORD REVIEW

The District conducted a 3-year search in its Compliance Database to determine whether any
of the devices has any any open Notice-to-Comply (NTCs) or Notice-of-Violation (NOVs).
The results indicate that there were 11 NOVs and 3 NCs issued to this facility, but only one

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was issued to the subject Heater 24F-1. NOV #P56604 was issued on 12/30/09 to this heater
for operating contrary to condition #4, Section E, of the Facility Permit. This NOV has been
resolved and the equipment is in compliance. There are currently no open NTCs or NOVs for
any of the devices at this facility; they are either closed or in compliance. See Attachment A
for NOV/NC report.


PROCESS DESCRIPTION

The ExxonMobils cogeneration system is located in its hydrogen production/plant area of the
refinery. The companys cogeneration process has been recently upgraded and modified to
optimize the fuel/waste gas from that portion of the facility in ExxonMobils PC Application
No. 435110. This latest modification increases the amount of reclaimed hydrogen gas burned
in the turbine combustor and Heater 24F-1. ExxonMobil has completed its modification.
Because the PC is not converted to PO, a subsequent PC will be issued under A/N 483739.

The companys cogeneration process uses a combination waste gas from the hydrogen plant
area, refinery gas, and methane for both the turbine combustor and burners for Process Heater
24F-1. The process employs a gas turbine with a combustor that is rated at 316 mmBtu/hr
which drives an electric generator producing 22.83 megawatts electricity. This generated
electricity is used by compressors located in the hydrogen plant.

Once the gas is expanded through the gas turbine, it does not go directly to the atmosphere.
Instead, the hot gases from the gas turbine at 1,000F and 15% oxygen becomes the secondary
combustion air for the Process Heater 24F-1. This turbine exhaust eventually becomes part of
exhaust of Process Heater 24F-1 and flows to the SCR serving the heater. The following
process flow diagram shows the ExxonMobils cogeneration process.


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Gas Turbine
241-01
Combustor
316 MMBTU/HR
Generator
22.83 MW
Refinery
Gas
Condenser &
Knockout Pot
Water
Steam
Steam Turbine
241-2
SCR
Control
CEMS
NH3
Process Heater
24F-1
931 MMBTU/HR
Air
PSA Recovered
Gas
Refinery
Fuel
Combustion Air
and Flue Gas

EMISSION SUMMARY

The ExxonMobils requested changes do not affect criteria pollutant emissions for the Heater
24F-1 and Turbine 24F-1. ExxonMobil only requests that the District explicitly states the
company is allowed to bypass its SCR, which controls the NOx emissions from the process,
during the startup of its turbine and process heater. This operational request is not new as the
District already has allowed ExxonMobil to bypass its SCR during startup and shutdown
(condition E71.1). However, the amount of emission during startup and shutdown was not
quantified, nor was a condition requiring ExxonMobil to determine start-up NOx emissions
incorporated into the permit.

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Note that only start-up NOx emissions are affected by the requested start-up condition
emissions of all other criteria pollutants remain the same irrespective of start-up or normal
mode of operation.

The following table summarizes the emissions during startup (see next section for details on
the emission calculations):
Table 3: Emissions Summary

NOx
Hourly
Emissions
(lb/hr)
Daily
Emissions
(lb/day)
Annual
Emissions
(lb/yr)
30-Day Average
Emissions
(lb/day)
During Startup 244.05 5,857.2 14,643 --
During Normal Operations 42.03 1,008.7 365,654 1,016
Combined -- -- 380,297 1,056
ROG
Hourly
Emissions
(lb/hr)
Daily
Emissions
(lb/day)
Annual
Emissions
(lb/yr)
30-Day Average
Emissions
(lb/day)
During Startup 62.35 1,496.40 546,186.00 1,517.18
During Normal Operations 62.35 1,496.40 546,186.00 1,517.18
PM10
Hourly
Emissions
(lb/hr)
Daily
Emissions
(lb/day)
Annual
Emissions
(lb/yr)
30-Day Average
Emissions
(lb/day)
During Startup 24.94 598.56 218,474.40 606.87
During Normal Operations 24.94 598.56 218,474.40 606.87
SOx
Hourly
Emissions
(lb/hr)
Daily
Emissions
(lb/day)
Annual
Emissions
(lb/yr)
30-Day Average
Emissions
(lb/day)
During Startup 17.03 408.8 149,212 414.48
During Normal Operations 17.03 408.8 149,212 414.48
CO
Hourly
Emissions
(lb/hr)
Daily
Emissions
(lb/day)
Annual
Emissions
(lb/yr)
30-Day Average
Emissions
(lb/day)
During Startup 88.54 2,124.89 775,584.12 2,154.40
During Normal Operations 88.54 2,124.89 775,584.12 2,154.40

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EMISSION CALCULATIONS:

Table 4: Operational Data

Operating Hours
Per Day
Operating Days
Per Year
Normal Operations 24 365
Startup-Requested Changes to Permit Conditions 24 2.5 (60 hrs)
Total Hours in Normal Operations 24 362.5
Note: The start-up hours requested by ExxonMobil are 60 hrs per start-up. Assumed 1 start-
up each year.

Data used in Emissions Calculations:

Max heating rates, MMBtu/hr: 1,247 (total), 316 (gas turbine, 25%), 931 (heater, 75%)

Fuel gas (refinery/natural gas) HHV, MMBtu/MMscf: 1020

F dry factor for natural gas = 8710/+E6 scf/Btu

The following Emissions factors were developed in the previous application 440468/440469
(see Attachment B for the entire evaluation; relevant pages for 24F-1 calculations are on pages
22 to 24):
Table 5: Emission Factors/Limits

NOx
Emission
Factor/Limit
SOx
Emission
Factor/Limit`
ROG
Emission
Factor/Limit
PM10
Emission
Factor/Limit
CO
Emission
Factor/Limit
9 ppmv
@ 15% O2
Rule 2005 Limit
(4-40-2001)
87.5 ppmv
@ 0% O2
(combined
GTG/Heater)
0.050 lb/mmBtu
(Determined by
District - see
Attachment B)
0.02 lb/mmBtu
(Determined by
District - see
Attachment B)
0.071 lb/mmBtu
(Determined by
District - see
Attachment B)
*30 ppmv H2S limit/gas turbine &100 ppmv H2S limit/ heater
30 ppmv x 25% = 100 ppmv x 75% = 82.5 ppmv

Total NOx Emissions During Normal Operations:

See Attachment B (A/N 440468_69 evaluation) for details on the following calculations


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N0x _
lb
J
]
= FJ
sc
HHBtu
x ppm: x 1uc
-6
x
lbmolc
S79 c
x 46
lbN0x
lbmolc
x
HHBtu
br
x
sc
1u2u BIu
x 24
br
J
x
2u.9
2u.9 - %02


= 871u x 9x1uc
-6
x
46
379
x 1247 x
24
020 1
x
20.9
20.9-15


= 1,uu8.7
Ibs
du
= 42. 3 |hxhr

Total NOx Emissions During Startup When SCR Is Not Operating:

Based on source tests conducted during the 2009 start-up (w/o NH3 injection), the max NOx
concentration was determined to be 70 ppm uncontrolled (see Attachment C for CEMS data).
Based on this, the NOx emissions during start-up are calculated to be 244.05 lbs/hr (see
Attachment C for the details on start-up NOx calculations).

Rule 2012 for RECLAIM NOx, Protocol Chapter 2, Section G allows using source test data to
estimate the emission during start-up, in lieu of emissions factors established in Table 3-D.

Total Combined NOx Emissions:

Hourly Emissions during s/u = 244.05 lbs/hr
Daily Emissions during s/u = 5,857 lbs/day
Max allowed s/u hours = 60 hrs = 2.5 days
Yearly Emissions during s/u = = 14,643 lbs/yr

Hourly Emissions during Normal Operations = 42.03 lbs/hr
Daily Emissions during Normal Operations = 1,008 lbs/day
Normal operating hours = 362.5 days
Yearly Emissions during Normal Operations = 365,654 lbs/yr

Combined NOx Emissions (30 Day Average) = 380,297 12 mo/yr 30 days/mo
= 1056 lbs/day

Total S x Emissions Durin mal O tions a tup: O g Nor pera nd Star

S0x _
lb
J
] = ppm:x1uc
-6
x
lbmolc
S79 c
x64
lbS0x
lbmolc
x1247
HHBtu
br
x1uc
6
sc
1u2u BIu
x24
br
J


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= 82.Sx1uc x
379
-6
64
x 1247x1uc
6
x
24
1020


= 4u8.8 lbsJoy

Total ROG Emissions During Normal Operations and Startup:

ROG Emissions = 0.050 lb/mmBtu x 1247 mmBtu/hr
= 62.35 lb/hr x 24 hr/day
= 1,496.4 lb/day x 365 day/yr
= 546,186 lb/yr x 1 yr/12 months x 1 month/30day
= 1,517.18 lb/day (30-day avg.)

Total CO Emissions During Normal Operations and Startup:

CO Emissions = 0.071 lb/mmBtu x 1247 mmBtu/hr
= 88.54 lb/hr x 24 hr/day
= 2,124.89 lb/day x 365 day/yr
= 775,584.12 lb/yr x 1 yr/12 months x 1 month/30day
= 2,154.40 lb/day (30-day avg.)

Total PM10 Emissions During Normal Operations and Startup:

PM10 Emissions = 0.02 lb/mmBtu x 1247 mmBtu/hr
= 24.94 lb/hr x 24 hr/day
= 598.56 lb/day x 365 day/yr
= 218,474.40 lb/yr x 1 yr/12 months x 1 month/30day
= 606.87 lb/day (30-day avg.)


RULES AND REGULATORY ANALYSIS

California Environmental Quality Act (CEQA):

No Formal CEQA Document Is Required. CEQA applies to all applicants who apply with
the District for permits for their planned projects that may have significant environmental
impacts. If these significant impacts arise, CEQA requires project proponents to perform
formal analyses to identify the impacts, propose mitigation measures to minimize them,
and formalize the results as a CEQA document for the public to review and comment.

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To determine if a project must meet CEQA requirements, an applicant must perform a
prescreening analysis of its proposed project to determine whether or not that it may have
the potential to cause significant environmental impacts. To facilitate this prescreening
process, the District currently uses the 400-CEQA form as a tool to determine whether an
applicants project requires the preparation of a formal CEQA document. Based on the
ExxonMobils prescreening results for its turbine and process heater, no formal CEQA
document is required because the startup emissions was preexisting condition that wasnt
quantified, but allowed under the previous permit.

Regulation II: Permits

Rule 212: Standards for Approving Permits

The Districts Rule 212 specifies the conditions under which the District can issue a
requested permit to an applicants new or modified equipment. These conditions are set
in terms of the amount of air emission increase, the sources proximity to a public school,
and the level of health risk increases that arise from a toxic emission increase. These
requirements are specified in Rule 212, Subdivision (c).

When the applicants new or modified source triggers any of the conditions in Rule 212,
Subdivision (c), the applicants proposed new or modified emission source must undergo
public notification and review for a period of 30 days in advance of the Districts final
action on the requested permit as stated in Subdivision (d) of Rule 212. These specific
requirements of Subdivision (c) and the Districts analysis of compliance for
ExxonMobils turbine and process heater are as follows:

Rule 212 (a): Denial of Permit-to-Construct (PC) and Permit-to-Operate (PO)
Requirement

An equipment that requires a Permit-to-Construct (PC) or a Permit-to-Operate (PO)
must demonstrate that it can operate in compliance with all applicable District rules,
and Division 26 of the State Health Safety Code. If an applicant can not demonstrate
that his equipment can operate in compliance, the District needs to deny the requested
permit. The rules and regulatory analysis section in this evaluation report determines
whether ExxonMobil complies with the Rule 212, Subdivision (a), requirements. The
conclusion on the Districts regulatory analysis appears in the Recommendation
section of this evaluation report.

Rule 212 (b)(1): Conversion of PCs to POs

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Not applicable. None of ExxonMobils applications are a PC to PO conversion.

Rule 212 (c)(1): Minimum Distance to a Public School Requirement, and Rule 212
(c)(3): Increases in Toxic Air Contaminants Requirements

No Public Notification Is Required. Any new or modified source with an emission
increase that requires a District permit may need to go through public notification
before the District grants the requested permit, if the source is located within 1000
feet from the outer perimeters of any public schools. This notification requirement
only applies to new or modified sources that result in an emission increase, and/or
increase in health risks.

Although the ExxonMobils applications are for changes to its operating conditions,
these changes result in no change in toxic emissions. There are also no emission
increases from the ExxonMobils proposed operational changes since the company
does not propose changes to the fuels used by the two devices, nor increases in the
two devices heat ratings. Therefore, no public notification is required.

Rule 212 (c)(2): Emission Increase Limits/Requirements

No Public Notification Is Required. The Paragraph (c)(2) of Rule 212 establishes the
emission thresholds of Rule 212, the net increases in emissions that would trigger
public notification requirements in Subdivision (d). The following table, which is
from Rule 212 (g), gives the amount of emission increase for each criteria pollutant
that would require public notification before the District can issue an applicants
requested permit, and this table also includes the net emissions from ExxonMobils
turbine and process heater:

Table 8: Net Emission Summary

Air Pollutant Daily Maximum
(lb/day)
Net Emissions Increase From Turbine and
Process Heater (lb/day)
VOC 30 0
NOx 40 0
PM
10
30 0
SOx 60 0
CO 220 0
Lead 3 0

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There is no emissions increase from the proposed changes in condition for the two
applications. Therefore, no public notification is required.

Regulation IV: Prohibitions

Rule 401: Visible Emissions

Expect to Comply. Paragraph (b)(1) sets the opacity standards for emission sources. The
current standard is a shade that is equal or greater than No.1 on the Ringelmann Chart, or
any emission that causes the same degree of opacity as that of shade No.1 for more than
three minutes in any one hour. If ExxonMobil properly operates and maintains its turbine
and process heater, and only burns the gaseous fuels allowed in the permit, then District
expects ExxonMobil to comply with the requirements of Rule 401.

Rule 402: Nuisance

Expect to Comply. The Districts Rule 402 requirements prohibits emission source from
discharging pollutants that may cause injury or damage to persons or property, and public
nuisance. If ExxonMobil properly operates and maintains its turbine and process heater,
and only burns the gaseous fuels allowed in the permit, then District expects ExxonMobil
to comply with the requirements of Rule 402.

Rule 404: Particulate Matter (PM)-Concentration

Expect to comply. The Districts Rule 404 establishes limits on PM emissions. These PM
limits depend on the exhaust flow rate of the equipment and are listed in Table 404 (a).
Those limits are based on 15 minute averages. To determine if the ExxonMobils boiler
can comply with the PM limits of Rule 404, the PM concentration for the boiler was
calculated based on its maximum rating:

PM Emissions = 24.94 lb/hr x 1 hr/60 min x 7000 grains/lb = 2,909.667 grains/min
Boiler = 1247 mmbtu/hr
Fd = 8710 scf/mmbtu
Flue gas flowrate = 1247 mmbtu/hr x 8710 scf/mmbtu x 1 hr/60 min
= 181,022.83 scf/min

PM Conc. = (2,909.667 grains/min)/(181,022.83 scf/min) = 0.0161 grain/scf

Rule 404 Limit 0.0253 > PM Conc of 0.0161

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The Districts calculation shows that ExxonMobils process heater is expected to comply
with the limit established by Rule 404.

Rule 407: Liquid and Gaseous Contaminants

Expect to Comply. The Districts Rule 407 establishes the maximum limits for Carbon
Monoxide (CO), and Sulfur Oxides (SOx) for any equipment that discharges air
pollutants in the Districts jurisdiction. The following table gives the emission limits that
currently apply to any equipment:

CO (ppmv) SOx (ppmv)
2000 ppm (dry basis, 3% O2)
at 15 minute average
500 ppm (dry basis, 3% O2)
at 15 minute average

Because ExxonMobil is a RECLAIM facility for both NOx and SOx, the company only
has to comply with the CO concentration limit as it is exempt by Rule 2001 (j)(2) for
SOx. Therefore, the District only imposes a condition for CO under the Equipment
Description section of the permit under the emissions requirements. If ExxonMobil
properly operates and maintains its turbine and process heater, the District expects the
company to comply with the CO limit.

Rule 409: Combustion Contaminants

Expect to comply. The Districts Rule 409 imposes an overall pollutant limit of 0.10
grain per cubic foot of combustion contaminants from a combustion source at 12% CO2
(0 % O2). ExxonMobil complies with this limit, as shown in the annual source test reports
(see Attachment E for 2009 source test results).

Rule 429: Start-up & Shutdown Exemption Provisions for NOx

Not Applicable. Although the Districts Rule 429 specifically governs the startup and
shutdown of heaters and boilers, ExxonMobil is RECLAIM facility subject to the
Districts Regulation XX and therefore not subject to Rule 429 by Rule 2001 (j).

Rule 475: Electric Generating Equipment

Expect to Comply. ExxonMobils cogeneration unit is subject to the Districts Rule 475.
This rule imposes limits of 0.01 grain/scf and 11 lb/hr of PM emissions which has been
imposed as emission limits on the turbine and heater. ExxonMobil complies with this

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limit, as shown in the annual source test reports (see Attachment E for 2009 source test
results). Note that condition A327.1 has been added to indicate that only the mass or the
concentration limit apply at a given, not both. Compliance expected.

Regulation IX: Standards of Performance for New Stationary Sources (NSPS)

40CFR60, Subpart J: Standards of Performance for Petroleum Refineries

Expect to Comply. The ExxonMobils turbine and process heater run on fuel gas/waste
gas from the hydrogen plant area. Because both burn fuel/process gas, ExxonMobil must
comply with the requirements of Subpart J which has a limit of 160 ppmv H2S at the
inlet or 20 ppmv SO2 @ 0% at the outlet. Since ExxonMobil has a RECLAIM
continuous emission monitoring system for SOx at the outlet of the SCR, it has applied
for and received approval from EPA for an Alternative Monitorin Plan (AMP) to use the
RECLAIM monitor for Subpart J compliance determination. District will impose
condition D90.yy to indicate that ExxonMobil has an AMP for Subpart J monitoring and
compliance. Since the CEMS monitors SOx concentration at the common discharge
stack for both of the devices, the District has imposed outlet limit of 20 ppmv SO2 (0%
O2) for both permits at the stack of the SCR. Compliance expected.

40CFR60, Subpart GG: Standards of Performance for Stationary Gas Turbines

Expect to Comply. 40CFR, Subpart GG applies to stationary gas turbines. The regulation
sets standards for NOx and SOx emissions based on the combustor and turbine size.
Based on the size of ExxonMobils cogeneration unit, the NOx standard is determined by
60.322 (a)(2). See Attachment D for calculation details. The NOx emission calculated is
160 ppmv. The permit currently has 210 ppmv under the Emissions & Requirements.
This will be corrected to 160 ppm, as agreed by ExxonMobil (see their letter dated
October 27, 2010 in Attachment D).

In addition to NOx standards, Subpart GG also requires SOx emissions to be below
0.015% by volume @ 15% O2. Because ExxonMobils cogeneration unit is subject to
Subpart J which has a limit of 20 ppmv @ 0% O2 and is lower than the required limit for
Subpart GG (see calculation below). Therefore, ExxonMobil is expected to comply.

0.015 scf/100 scf x (20.9 -15)/(20.9) = 42 ppmv @ 0% O2

Since ExxonMobil is a RECLAIM facility, it already has a SOx and NOx CEMS that
meets the requirements.


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The District has imposed a condition on the turbine (condition H23.15) that requires the
company to comply with applicable requirements of Subpart GG. Compliance is
therefore expected.

40CFR60, Subpart GGG/GGGa: Standards of Performance for Equipment Leaks of VOC
in Petroleum Refineries for which Construction, Reconstruction, or Modification
Commenced after 1-4-83 and on or before 11-7-06 [GGG]; after 11-7-06 [GGGa]

Expected to Comply. ExxonMobil was subject to Subpart GGG during the previous
modifications see page 27 of the previous engineering evaluation in Attachment B. This
equipment was also subject to the applicable requirements Subpart GGG per Consent
Decree Civil Case No. 05 C 5809 dated 12-13-2005. Permit condition stating that
Subpart GGG was applicable was imposed in the prior permits. However, ExxonMobil
has voluntarily accepted Subpart GGGa for all equipment previously subject to Subpart
GGG (per ExxonMobil's notification to EPA dated 08-24-2009). Therefore, this
equipment is no longer subject to Subpart GGG but rather it is now subject to the
applicable requirements of Subpart GGGa. Adding start-up condition does not affect
Subpart GGGa applicability.

Condition H23.34 has been tagged to the heater process 6, system 3. EM is expected to
continue to follow the inspection, leak reporting, and repair protocols described in this
regulation. Continued compliance is expected.

Regulation X: National Emission Standards for Hazardous Air Pollutants

40CFR63, Subpart CC: National Emission Standards for Hazardous Air Pollutants from
Petroleum Refineries

Not Applicable. The cogeneration section is not in organic hazardous pollutants (HAPs)
service. The only HAP in the fuel gas stream is hexane, but its concentration is less than
5% by weight (see material balance in PC Application No.435110).

Regulation XI: Source Specific Standards

Rule 1173: Control of Volatile Organic Compound Leaks and Releases from
Components at Petroleum Facilities and Chemical Plants

Expect to Comply. ExxonMobils cogeneration process is in VOC service. It is therefore
subject to the applicable requirements of Rule 1173. The District will impose a permit

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condition requiring ExxonMobil to comply with all applicable requirements of Rule
1173. Compliance is expected.

Regulation XIII: New Source Review (NSR)-Emission Offsets, Modeling, and Best Available
Control Technology (BACT)

Not Applicable. The Districts NSR requirements only apply to sources with an increase in
emissions. The requested Change of Condition to allow for bypassing the SCR during startup
of the turbine and heater, does not affect any criteria pollutants, except NOx. Because
ExxonMobil is a NOx and SOx RECLAIM facility, the company does not need to comply
with Regulation XIII for NOx by Rule 1301 (b)(1) rather it need to comply with the NSR
requirements under Rule 2005 (see below for this rule evaluation). Since there is no other
emission increases from the requested changes, this rule does not apply.

Note that conditions D28.22 and D28.23 were added (in the previous permit) for initial source
test and yearly source test, respectively, to demonstrate compliance with the offset limits
imposed in the permit. Initial Source Test was completed on August 21, 2008 and a Source
Test report was submitted to the District showing compliance with this condition (included in
the folder); therefore, condition D28.22 is no longer applicable and was already removed from
the permit for the heater device D925 (section D), and will be removed for the turbine device
D926 upon conversion to P/O. The facility has been performing the annual source tests under
condition D28.23 to show compliance with the offset limits for ROG, CO and PM (see
Attachment E for source test results from the 2009 tests). Continued compliance is expected.

Regulation XIV: Toxic Air Contaminants
Rule 1401: New Source Review of Toxic Air Contaminants (3/7/08)
Not Applicable. This rule specifies limits for MICR, cancer burden, and noncancer
acute/chronic hazard index for new permit units, relocations, or modifications to existing
permit units which emit toxic air contaminants listed in Table I of this rule. These applications
are subject to the Rule 1401 version dated 3/7/08 (the current version at the time the
application was deemed complete on 6/30/08).

Since there is no increase in toxics emissions from the proposed changes, this rule does not
apply and health risk assessment is not required.

Regulation XVII: Prevention of Significant Deterioration (PSD)-Standard Prepared Statement
by the District

The goal of PSD is to ensure that air quality in clean areas does not significantly deteriorate
while maintaining a margin for future industrial growth. It applies to net emission increases of

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criteria air pollutants that are currently in attainment. The District recently signed a new
Limited PSD Delegation agreement with EPA (effective July 26, 2007) that gives the District
limited responsibility for PSD. The South Coast Air Basin is currently in attainment for NO2,
SO2, CO, and lead.

A recent EPA Endangerment Finding for greenhouse gases (GHG) means that emissions of
GHG need to be evaluated under PSD. Note that ambient air quality standards have not yet
been released for GHG. Therefore, as the South Coast Air Basin is not in nonattainment, GHG
emissions are also subject to PSD in South Coast.
The recently promulgated Tailoring Rule specifies that GHG emissions must be evaluated
under PSD for projects at existing PSD or Title V sources in South Coast according to a
phased-in applicability time frame. The subject equipment is located at a Title V facility. The
Tailoring Rule Step 2 is currently in effect, which means that a significant emission increase
of GHGs can itself trigger PSD for modifications (rather than only being evaluated as a part of
"anyway" modifications that trigger PSD due to increases in other regulated pollutants).

This application does not involve increases of any attainment air pollutant, and thus Reg XVII
does not apply.

Regulation XX: Regional Clean Air Incentive Market (RECLAIM)

Expect to Comply. The ExxonMobils requested changes do not add any additional or new
RECLAIM pollutants. The company requests that the a condition specifically states that
during startup and shutdown that the District allows the bypassing of the SCR when the flue
gas at the inlet of the SCR drops below 550 Fahrenheit in which the control is useless because
ammonia will not react with NOx at temperatures below 550 Fahrenheit. Permit condition
E71.7 already states this.

Although the current permit allows ExxonMobil to bypass the SCR during start-up (<550F),
it does not implicitly states that ExxonMobil does not need to meet the NOx limit in A195.1
during start-up, shut-down or malfunction when the SCR inlet temperature is expected to be
less than 550F. As a result, ExxonMobil has applied for a Variance to the AQMD Hearing
Board for planned start-ups and shutdowns, to allow them to exceed the 9 ppmv limit in
A195.1. Therefore, ExxonMobil submitted these applications to allow them to exceed the
NOx limits during start-ups or shutdown without a variance. The District will impose new
permit conditions for startup and shutdown and the method for reporting of NOx emissions
(conditions D99.xx, D195.1 and E54.xx).

The current RECLAIM CEMS used to monitor NOx emissions from the heater and turbine is
a single range monitor with a certified range of 0-25 ppmv. Since the NOx emissions during

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the start-up of the heater and turbine are expected to exceed the range of the current monitor,
ExxonMobil needs to use alternate methods for reporting, as described in Rule 2012, Protocol
Chapter 2. Section G allows using source test data to estimate the emission during start-up, in
lieu of emissions factors established in Table 3-D.

As shown in the Emissions Calculations section above, the NOx emissions during start-up are
based on source tests conducted during the 2009 start-up (w/o NH3 injection). The tests
showed that the max NOx concentration during start-up was 70 ppm uncontrolled (see
Attachment C for CEMS data). Based on this, the NOx emissions during start-up are
calculated to be 244.05 lbs/hr (see Attachment C for the details on start-up NOx calculations).
This limit has been incorporated in condition E54.xx.

Rule 2005 New Source Review for RECLAIM

As discussed above, adding conditions to allow ExxonMobil to start-up their heater and
turbine does not result in any increase of NOx emissions, as this was already allowed under
condition E71.7. The current NOx BACT limit in the permit is 9 ppmv at 15% O2.

It is also important to note that it is technologically not feasible to reduce NOx when the
temperature of the flue gas at the inlet to the SCR is below 550F (if ammonia is injected
during start-up, when the temperature is below 550F, it will not react with NOx and will
mostly come out of the stack, unreacted). The heaters are already equipped with low-NOx
burners. Thus, the District needs to allow ExxonMobil to exceed the 9 ppmv BACT limit
during start-up, when the temperature is expected to be below 550F. The District is
proposing to add a condition that will limit the start-up time to no more than 60 hours to
minimize the time that this equipment will exceed the 9 ppmv NOx BACT limit. This
alternate limit is expected to comply with the federal LAER requirements during the start-up
of the heater and turbine. The District also proposes to specify 244.05 lbs NOx/hr that
ExxonMobil will be required to use for its RECLAIM reporting, as shown in the calculation
above. Thus, compliance with the provision of this rule is expected.

Regulation XXX: Title V Permits

Applicable and Comply. Because ExxonMobil has received its final Title V permit on January
25, 2010, it has to comply with the requirements for facilities that have been issued final Title
V permits. Under Regulation XXX, there are different classifications for changes to Title V
permits. For ExxonMobil, the following revision applies to the subject applications:

Applicable and Comply. Minor Permit Revision: This type of revision is for
changes that do not result in any emission increases regulated by Regulation

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XXX, and hazardous air pollutants and rules, federal and local, and is not for
modification or reconstruction. Because ExxonMobils devices are existing
sources that are not being modified and has no increase of pollutants, the
changes are, therefore, considered a minor revision of its Title V permit.
Public notice is not required; however, the proposed permit and the
engineering evaluation will be submitted to the USEPA for a 45-day review as
required by Rule 3003(j)(1)(A).


RECOMMENDATIONS

Based on the evaluation above, ExxonMobils turbine and process heater are currently in
compliance and expected to remain in compliance with all applicable permit conditions and
AQMD, State, and Federal Rules and Regulations. Permit to Construct (turbine) and Permit to
Operate (heater) are recommended with the conditions listed in the Conditions Section of this
evaluation.

Following a summary of actions recommended under this evaluation:

A/N Equipment Description Device ID Recommended Action
483736 Heater 24F-1, hydrogen reforming D925 Approve P/O
483739 Turbine 24J-1, Cogen D926 Approve P/C
455135 Heater 24F-1, hydrogen reforming D925 Cancel application
TV Permit Amendment Minor TV Amendment



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Attachments

A.
Compliance Data
B.
Engineering Evaluation for Fuel Optimization Project
A/N 440468_69
C.
Start-up NOx Emissions Data and Calculations
D.
NOx ppmv Calculations for NSPS Subpart GG
E.
Source Test Results from 2009 annual test report