DAQ-2024-008124

1/23/24, 11:20 AM State of Utah Mail - Pioneer Investments-Phillips 66- RACT Analysis
https://mail.google.com/mail/u/0/?ik=539c285453&view=pt&search=all&permmsgid=msg-f:1785304411268167894&simpl=msg-f:17853044112681678…1/1
Ana Williams <[e-mail]>
Pioneer Investments-Phillips 66- RACT Analysis
Bosch, Morgan N <[e-mail]>Thu, Dec 14, 2023 at 5:09 PM
To: "[e-mail]" <[e-mail]>
Hi Ana,

See the attached RACT Analysis for the Pioneer Investments' Phillips 66 North Salt Lake Pipeline and Distribution Terminal.

Please let me know if you have any questions.

Thank you,

Morgan Bosch
Environmental Specialist
M: ([phone]
Northwest Region | 2626 Lilian Avenue | Billings, MT 59101

P66_RACT_Analysis_121423.pdf
3053K

Morgan N. Bosch
Environmental Specialist
Phillips 66 Midstream Operations
Phillips 66 Company
2626 Lillian Avenue
Billings, MT 59101
Mobile: [phone]
Office: 406.255.5711
E-mail: [e-mail]

December 41, 2023

Ana Williams
Air Quality Policy Section
Utah Division of Air Quality
Department of Environmental Quality
[e-mail]

RE: AO DAQE-AN101330021-22, Pioneer Investments Corporation-Phillips 66 Company, North
Salt Lake Products Terminal, Serious Ozone Nonattainment Area Designation- RACT Analysis

Dear Ana Williams,

Pioneer Investment Corporation- Phillips 66 Company (P66) is submitting this RACT analysis for the
emission units at our North Salt Lake Pipeline Terminal (facility) located at 245 East 1100 North in
Davis County.
This RACT analysis discusses the information detailed in the letter from the Division of Air Quality
regarding the Next Steps and RACT Requirements (attached).
Please contact me at [e-mail] or [phone] with any questions or if you require
additional information.

Sincerely,

Morgan. N. Bosch
Environmental Specialist

Reasonably Available Control
Technology Analysis
North Salt Lake Products Terminal
Pioneer Investments Corporation – Phillips 66 Corporation
245 East 1100 North
North Salt Lake, Utah 84054
Prepared by:
SLR International Corporation
1612 Specht Point Road, Suite 119, Fort Collins, Colorado, 80525
SLR Project No.: 118.01357.00013
Report Issue Date: December 14, 2023
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
i
Reasonably Available Control Technology Analysis
North Salt Lake Products Terminal
Prepared for:
Pioneer Investments Corporation – Phillips 66
Corporation
245 East 1100 North
North Salt Lake, Utah 84054
This document has been prepared by SLR International Corporation. The material and data in this
report were prepared under the supervision and direction of the undersigned.
SLR International Corporation
Jamie Christopher
Senior Principal Engineer
Kenny Malmquist
Senior Principal Engineer
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
ii
Table of Contents
1.0 Introduction and Background ......................................................................................1-1
2.0 Facility Description .......................................................................................................2-1
3.0 Facility Baseline Actual Emissions and Current PTE .................................................3-1
4.0 RACT Methodology .......................................................................................................4-1
4.1 Top-Down RACT Analysis Approach ......................................................................4-1
4.1.1 Step 1: Identification of Available Control Technology Options .......................4-1
4.1.2 Step 2: Technical Feasibility of Control Options .............................................4-1
4.1.3 Step 3: Ranking of Technically Feasible Control Options ...............................4-2
4.1.4 Step 4: Energy, Environmental, and Economic Impacts .................................4-2
4.1.4.1 Cost Analysis Methodology ................................................................4-3
4.1.4.2 Capital Costs ......................................................................................4-4
4.1.4.3 Annualized Costs ...............................................................................4-4
4.1.4.4 Cost Effectiveness ..............................................................................4-5
4.1.5 Step 5: Select RACT ......................................................................................4-5
5.0 RACT Analysis NOx .......................................................................................................5-1
5.1 Diesel-Fired Emergency Engines NO x RACT Analysis............................................5-1
5.1.1 Step 1 – Identify all Reasonably Available NOx Control Technologies ............5-1
5.1.1.1 Federal O&M Practices ......................................................................5-2
5.1.1.2 Engine Design ....................................................................................5-2
5.1.1.3 Non-Selective Catalytic Reduction (NSCR) ........................................5-3
5.1.1.4 Selective Non-Catalytic Reduction (SNCR) ........................................5-3
5.1.1.5 Selective Catalytic Reduction (SCR)...................................................5-3
5.1.2 Step 2 & 3 - Technical Feasibility of NOx Controls ..........................................5-4
5.1.3 Step 4 – Evaluation of Feasible Control Options ............................................5-5
5.1.3.1 Selective Catalytic Reduction .............................................................5-5
5.1.4 Step 5 - CI-ICE NOx RACT Determination ......................................................5-5
6.0 RACT Analysis – VOCs .................................................................................................6-1
6.1 RACT for Loading Racks ........................................................................................6-1
6.2 RACT for Vertical Fixed Roof Storage Tanks ..........................................................6-3
6.2.1 Step 1 – Identify all Available VOC Control Technologies ..............................6-4
6.2.2 Step 2 – Technical Feasibility of VOC Control Technologies ..........................6-4
6.2.2.1 Closed Vent System/Vapor Recovery/Route to Control Device ..........6-4
6.2.2.2 Retrofitting VFRT with IFR ..................................................................6-4
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
iii
6.2.2.3 Application of Tank Standards ............................................................6-5
6.2.3 Step 5 – RACT Selection ...............................................................................6-7
6.3 RACT for Internal Floating Roof Storage Tanks ......................................................6-7
6.3.1 Step 1 – Identify all Available VOC Control Technologies ..............................6-8
6.3.1.1 NSPS Subpart Kb ...............................................................................6-8
6.3.1.2 40 CFR Part 63 Subpart WW Controls ...............................................6-8
6.3.1.3 Installation of a Vapor Recovery System ............................................6-9
6.3.2 Step 2 - Technical Feasibility of Control Technologies ...................................6-9
6.3.3 Step 3 - Effectiveness of Feasible Control Technologies ................................6-9
6.3.4 Step 4 – Evaluation of Feasible Control Technologies ...................................6-9
6.3.5 Step 5 – RACT Selection ...............................................................................6-9
6.4 RACT for External Floating Roof Storage Tanks ...................................................6-10
6.4.1 Step 1 – Identify all Available VOC Control Technologies ............................6-10
6.4.2 Step 2 - Technical Feasibility of Control Technologies .................................6-10
6.4.3 Step 3 - Effectiveness of Feasible Control Technologies ..............................6-11
6.4.4 Step 4 – Evaluation of Feasible Control Technologies .................................6-11
6.4.5 Step 5 – RACT Selection .............................................................................6-11
6.5 RACT for Equipment Leaks ..................................................................................6-11
7.0 Summary of NOx and VOC RACT Analyses .................................................................7-1
Tables
Table 2-1 Non-Tank Emission Sources
Table 2-2 NSL Terminal Storage Tanks
Table 3-1 P66 NSL Terminal Facility Emissions
Table 3-2 P66 NSL Terminal Facility PTE Emissions by Sources
Table 5-1 Technical Feasibility of Diesel-fired CI-ICE NOx Controls
Table 6-1 Vertical Fixed Roof Tanks at NSL Terminal
Table 6-2 Summary of NSPS Subpart Kb Applicability and Control Thresholds
Table 6-3 Internal Floating Roof Tanks at NSL Terminal
Table 6-4 External Floating Roof Tanks at NSL Terminal
Table 7-1 Summary of RACT Determinations for Each Source
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
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Appendices
Appendix A
2017 Emission Inventory
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
1-1
1.0 Introduction and Background
On May 31, 2023 the Utah Division of Air Quality (UDAQ) sent a letter to Pioneer Investments
Corporation – Phillips 66 Corporation (Phillips 66) regarding the opportunity to provide a
Reasonably Available Control Technology (RACT) analysis for sources of nitrogen oxides (NO x)
and volatile organic compounds (VOCs) at the Phillips 66 North Salt Lake Products Terminal
(NSL Terminal) in support of the Northern Wasatch Front (NWF) ozone nonattainment area (NAA)
Serious State Implementation Plan (SIP).
The NWF ozone NAA (includes all or part of Salt Lake, Davis, Weber, and Tooele counties) was
recently reclassified to moderate status on November 7, 2022. The NWF ozone NAA is required
to attain the ozone standard by August 3, 2024, for moderate classification. Recent monitoring
data indicates the NWF ozone NAA will not attain the standard, hence will be reclassified to
serious status in February of 2025.
The reclassification to serious status will trigger new control strategy requirements for major
sources in the NWF ozone NAA. The Clean Air Act (CAA), under Section 182(c) and (f) and more
specifically the Ozone Implementation Rule in 83 FR 62998 requires State Implementation Plans
(SIPs) for ozone NAAs classified as “Moderate” or higher to include requirements for existing
major sources of ozone precursor pollutants (NO x or VOCs) to apply RACT. A major stationary
source in a serious ozone NAA is defined as any stationary source that emits or has the potential
to emit 50 tons per year (tpy) or more of NOx or VOCs.
The UDAQ has identified the NSL Terminal as having the potential to emit 50 tpy or more of NO x
and/or VOCs. The current Approval Order DAQE-AN1013330021-22 (April 20, 2022), limits NO x
emissions to 11.9 tpy, and VOC emissions to 69.2 tpy. The NSL Terminal will be considered a
major stationary source when the NWF ozone NAA is reclassified to Serious in February 2025.
Therefore, according to the May 31, 2023, letter from UDAQ, Phillips 66 has two options:
1. Prepare and submit a RACT analysis for the emission units at the NSL Terminal by
January 2, 2024; or
2. Prepare and submit a Notice of Intent (NOI) application to lower the potential to emit from
the NSL Terminal to below 50 tpy for NO x and VOCs by July 31, 2023.
Phillips 66 notified UDAQ they would be preparing a RACT analysis for the NSL Terminal. This
document provides the results of the RACT analysis for NO x and VOC emissions from the NSL
Terminal. Section 2 contains information describing the facility, site location, and existing
equipment. Details of the baseline emissions used to conduct the analysis presented herein can
be found in Section 3. Section 4 provides a discussion of RACT methodology. The NO x and VOC
RACT analyses can be found in Sections 5 and 6. Section 7 provides a summary of the NO x and
VOC RACT analyses determinations per emission unit/source.
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
2-1
2.0 Facility Description
Phillips 66 owns and operates the NSL Terminal located in North Salt Lake, Utah (Davis County).
The NSL Terminal is a fuel distribution tank farm that sends gasoline and distillate fuel through
pipeline systems to Idaho and Nevada. The NSL Terminal also loads transport trucks for delivery
of fuel to various gasoline and distillate fueling stations throughout the area.
The NSL Terminal’s operating schedule is 24 hours per day, 7 days per week, 365 days per year
(8,760 hours per year [hr/yr]). Emissions of concern at the facility are VOCs emitted primarily from
product loading, storage tanks, and fugitive emissions from piping components. NO x emissions
are also emitted from the flares controlling the loading operations, and from a diesel-fired
emergency generator. The current Approval Order DAQE-AN1013330021-22, limits NO x
emissions to 11.9 tpy, and VOC emissions to 69.2 tpy. The loading racks are limited to 14,500,000
barrels of gasoline throughput per 12-month period, and the storage tanks are limited to
20,430,000 barrels of gasoline and 12,021,782 barrels of distillate fuel throughput per 12-month
period.
The total of all gasoline loading racks at the NSL Terminal is an “affected facility” for purposes of
Federal New Source Performance Standards (NSPS), 40 CFR Part 60, Subpart XX—Standards
of Performance for Bulk Gasoline Terminals ("NSPS XX”). The affected facility is equipped with a
vapor collection system designed to collect the total organic compound (TOC) vapors displaced
from tank trucks during product loading and TOC emissions from loading operations are limited.
For purposes of National Emission Standards for Hazardous Air Pollutants for Source Categories
(NESHAP), 40 CFR Part 63, the NSL Terminal is an area source of hazardous air pollutants
(HAP). The NSL Terminal is a Gasoline Bulk Terminal regulated by NESHAP Subpart BBBBBB
("NESHAP BBBBBB”). The NSL Terminal is subject to NESHAP BBBBBB emission limitations
and work practice standards for reducing emissions from gasoline storage tanks, storage tanks,
gasoline loading racks, vapor collection-equipped gasoline cargo tanks, and certain equipment
components in vapor or liquid gasoline service.
The emergency diesel-fired reciprocating internal combustion engine (RICE) is subject to work
practice standards for stationary emergency compression ignition RICE located at an area source
of HAP in Subpart ZZZZ—National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines (“NESHAP ZZZZ”).
Table 2-1 presents the primary sources of VOC and NO x emissions at the facility that are not
tanks as well as associated controls and/or regulatory requirements. The flares controlling the
loading racks account for 10.2 tpy of the total 11.9 tpy NO x emissions emitted at the facility. The
emergency generator limited to 100 hr/yr annual operation makes up the remainder (1.7 tpy) of
the total NOx emissions. Table 2-2 provides an inventory of the storage tanks by type, capacity,
and product stored that are permitted to operate at the NSL Terminal.
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
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Table 2-1 Non-Tank Emission Sources
Emission Source Description Control/Regulatory
Requirement
Loading Rack 1 Three Station, Bottom Load Two John Zink Flares
LHT-2-20-25-X-1/10-2/20-X
LHT-3-24-25-3/10-1/10-X
NSPS XX, NESHAP BBBBBB
Loading Rack 2 Three Station, Bottom Load
Fugitive Emissions Piping (connectors and flanges),
valves, pumps, and compressors
LDAR AVO per NESHAP
BBBBBB
Emergency Generator 1,118 hp diesel-fired emergency
stationary RICE
Good operating practices,
comply w/NESHAP ZZZZ,
100 hr/yr annual operation
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
2-3
Table 2-2 NSL Terminal Storage Tanks
Tank
Number
Tank Type Year of
Construction
Nominal
Capacity
Product
201 External Floating Roof 1953 80,000 bbl Gasoline
204 Geodesic Dome Enclosed
Floating Roof
1952 40,000 bbl Gasoline
211 External Floating Roof 1953 80,000 bbl Gasoline
214 External Floating Roof 1952 40,000 bbl Gasoline
221 External Floating Roof 1953 80,000 bbl Gasoline
225 Internal Floating Roof 1988 88,000 bbl Gasoline
228 Internal Floating Roof 2013 80,000 bbl Gasoline
202 Fixed Roof 1953 20,000 bbl Distillate
205 Fixed Roof 1953 30,000 bbl Distillate
206 Fixed Roof 1953 20,000 bbl Distillate/Renewable Diesel
215 Fixed Roof 1953 30,000 bbl Distillate
216 Fixed Roof 1953 20,000 bbl Distillate/Renewable Diesel
224 External Floating Roof 1953 20,000 bbl Distillate
227 Fixed Roof 2000 100,000 bbl Distillate
226 Internal Floating Roof 1992 9,400 bbl Transmix/Gasoline
212 Internal Floating Roof 1953 20,000 bbl Ethanol
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
3-1
3.0 Facility Baseline Actual Emissions and Current PTE
The baseline and current potential to emit (PTE) from the P66 NSL Terminal processes and
equipment are summarized in Table 3-1. The 2017 actual emissions were used as the baseline
emissions. The current PTE values for P66 NSL Terminal were established by the most recent
active Approval Order (AO) DAQE-AN101330021-22, issued April 20, 2022. Table 3-2 breaks the
NOx and VOC PTE emissions out by source type.
Table 3-1 P66 NSL Terminal Facility Emissions
Pollutant 2017 Baseline Emissions Potential to Emit
NOx 2.70 tpy 11.90 tpy
VOC 56.0 tpy 69.75 tpy
Table 3-2 P66 NSL Terminal Facility PTE Emissions by Sources
Emission Source Description NOx (tpy)VOC (tpy)
Loading Rack 1 Three Station, Bottom Load 10.17 25.4Loading Rack 2 Three Station, Bottom Load
Fugitive Equipment Leaks --2.70
EGen 1,118 hp diesel-fired RICE 1.73 0.04
TNK 201 80,000 bbl Gasoline EFR Storage Tank --4.97
TNK 204 40,000 bbl Gasoline GD EFR Storage Tank --1.34
TNK 211 80,000 bbl Gasoline EFR Storage Tank --9.46
TNK 214 40,000 bbl Gasoline EFR Storage Tank --4.22
TNK 221 80,000 bbl Gasoline EFR Storage Tank --4.97
TNK 225 88,000 bbl Gasoline IFR Storage Tank --5.71
TNK 228 80,000 bbl Gasoline IFR Storage Tank --4.57
TNK 202 20,000 bbl Distillate FR Storage Tank --0.40
TNK 205 30,000 bbl Distillate FR Storage Tank --0.61
TNK 206 20,000 bbl Distillate FR Storage Tank --0.40
TNK 215 30,000 bbl Distillate FR Storage Tank --0.61
TNK 216 20,000 bbl Distillate FR Storage Tank --0.40
TNK 224 20,000 bbl Distillate EFR Storage Tank --0.08
TNK 227 100,000 bbl Distillate FR Storage Tank --2.03
TNK 226 9,400 bbl Transmix IFR Storage Tank --1.60
TNK 212 20,000 bbl Ethanol IFR Storage Tank --0.24
Total 11.9 69.75
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
3-2
As discussed previously, the flares controlling the loading racks account for 10.2 tpy of the total
11.9 tpy NOx emissions emitted at the facility. Since these control devices meet NSPS XX and
NESHAP BBBBBB standards, the NOx emissions from the flares controlling the Loading Racks
will not be evaluated for RACT purposes, only the VOC emissions from the Loading Racks will be
evaluated. The emergency generator limited to 100 hr/yr annual operation makes up the
remainder (1.7 tpy) of the total NOx emissions.
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
4-1
4.0 RACT Methodology
RACT is defined as devices, systems, process modifications, or other apparatus or techniques
that are reasonably available taking into account social, environmental and economic impacts as
well as the necessity of imposing such controls in order to attain and maintain a national ambient
air quality standard.
4.1 Top-Down RACT Analysis Approach
To conduct the RACT analysis, a top-down analysis was used to rank all control technologies.
This approach, as outlined by the UDAQ1, consists of the following steps:
1. Identify All Reasonably Available Control Technologies
2. Eliminate Technically Infeasible Control Technologies
3. Rank Remaining Control Technologies Based on Capture and Control Efficiencies
4. Evaluate Remaining Control Technologies on Economic, Energy, and Environmental
Feasibility
5. Select RACT.
4.1.1 Step 1: Identification of Available Control Technology Options
The first step in a "top-down" RACT analysis is to identify all "available" control options. Available
control options are those air pollution control technologies or techniques with a practical potential
for application to the emissions unit and the regulated pollutant under evaluation.
Air pollution control technologies and techniques include the application of production processes
or available methods, systems, and techniques, including fuel cleaning or treatment or innovative
fuel combustion techniques for control of the affected pollutant. The control alternatives must
include not only existing controls for the source category in question, but also (through technology
transfer) controls applied to similar source categories and gas streams, and innovative control
technologies. Technologies required under lowest achievable emission rate (LAER)
determinations are available for best available control technology (BACT) purposes but are
inappropriate for RACT analyses purposes, but were still included as control alternatives,
representing the top alternative.
4.1.2 Step 2: Technical Feasibility of Control Options
In the second step, the technical feasibility of each control option identified in step one is evaluated
with respect to source-specific factors. A demonstration of technical infeasibility must be clearly
documented and show, based on physical, chemical, and engineering principles, that technical
difficulties would preclude the successful use of the control option on the emissions unit under
review. Technically infeasible control options are then eliminated from further consideration in the
1 https://deq.utah.gov/air-quality/reasonably-available-control-technology-ract-process-moderate-area-ozone-sip
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
4-2
RACT analysis. For example, in some cases the level of control in a permit is not achieved in
practice (e.g., a source has received a permit, but the project was canceled, or every operating
source at the permitted level has been physically unable to achieve compliance with the limit). If
supporting documentation has been provided which shows why such limits are not technically
feasible, then the level of control (but not necessarily the technology) may be eliminated from
further consideration.
4.1.3 Step 3: Ranking of Technically Feasible Control Options
In step 3, all remaining control alternatives not eliminated in step 2 are ranked and then listed in
order of over-all control effectiveness for the pollutant under review, with the most effective control
alternative at the top.
Rankings are based on the level of emission control expressed as emissions per unit of
production, emissions per unit of energy used, the concentration of a pollutant emitted from the
source, control efficiency, or a similar measure. The control effectiveness listed will be
representative of the level of emission control which can be achieved by the control technology
at the operating conditions of the emission unit being reviewed. If the most effective control
technology is selected as RACT, then Step 4 need not be completed.
4.1.4 Step 4: Energy, Environmental, and Economic Impacts
After the identification of available and technically feasible control technology options, the energy,
environmental, and economic impacts are considered to arrive at the final level of control. The
analysis presents the associated impacts of the most stringent control option in the listing. Both
beneficial and adverse impacts are discussed and quantified where possible. In general, the
RACT analysis focuses on the direct impact of the control alternative.
The analysis must consider whether impacts of unregulated air pollutants or non-air impacts such
as liquid, solid, or hazardous waste disposal impacts would justify selection of an alternative
control option. If there are no outstanding issues regarding collateral environmental impacts, the
analysis is ended, and the results proposed as RACT. In the event that the top candidate is shown
to be inappropriate, due to energy, environmental, or economic impacts, then the next most
stringent alternative in the listing becomes the new control candidate and is similarly evaluated.
This process continues until the technology under consideration cannot be eliminated by any
source-specific environmental, energy, or economic impacts which demonstrate that the
alternative is inappropriate as RACT. The most effective control option not eliminated is proposed
as RACT for the pollutant and emission unit under review. In no case can a RACT determination
be proposed that would exceed an applicable NSPS or National Emission Standard for Hazardous
Air Pollutants (NESHAPS) emission limit (40 CFR Parts 60 and 61).
The energy impact analysis considers whether use of an emission control technology results in
any significant or unusual energy penalties or benefits. Energy use may be evaluated on an
energy used per unit of production basis; energy used per ton of pollutant controlled or total annual
energy use. Energy impacts may consider whether use of an emission control technology will
have an adverse impact on local energy supplies due to increased fuel consumption or the loss
of fuel production or power generation. The energy impact analysis estimates the direct energy
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
4-3
impacts of the control alternatives in units of energy consumption (Btu, kW-hr, barrels of oil, tons
of coal, etc). Electrical, steam, fuel, and other utility requirements are quantified. In addition, some
of the potential control options may generate hazardous waste, in such an instance the hazardous
waste disposal cost would be debited to the net control cost.
The economic impact analysis involves assessing the costs associated with installation and
operation of each RACT alternative. Examples of costs that are included are: 1) capital and
interest charges, 2) engineering and installation costs, 3) operating and maintenance labor and
materials, 4) energy costs, 5) waste disposal costs, and 6) lost revenue due to equipment
downtime. Credit for tax incentives, product recovery costs, and by-product sales generated from
the use of control systems are included where applicable.
As a guide in determining excessive control costs, alternative control systems are compared in
terms of certain cost effectiveness ratios. Such ratios include the following:
 Cost per unit of pollution removed (for example, dollars per ton);
 Unit production costs (for example, costs per unit of product); and
 Cost per dollar of total sales.
The determination of what is economically feasible is a subjective, case-by-case assessment by
the regulatory agency. The objective is to establish an acceptable level of cost impact. As such,
the cost impact (dollars per tpy) of emissions reduced determined to be economically feasible can
simply be the value that another similar process operation agreed to spend. Details on the cost
estimating procedures utilized are outlined below.
4.1.4.1 Cost Analysis Methodology
The basis for comparison in the economic analysis of the control scenarios is the cost
effectiveness; that is, the value obtained by dividing the total net annualized cost by the tons of
pollutant removed per year for each control technique. Annualized costs include the annualized
capital cost plus the financial requirements to operate the control system on an annual basis,
including operating and maintenance labor, and such maintenance costs as replacement parts,
overhead, raw materials, and utilities. Capital costs include both the direct cost of the control
equipment and all necessary auxiliaries as well as both the direct and indirect costs to install the
equipment. Direct installation costs include costs for foundations, erection, electrical, piping,
insulation, painting, site preparation, and buildings. Indirect installation costs include costs for
engineering and supervision, construction expenses, start-up costs and contingencies.
To accurately estimate the total annualized cost of a particular control technology, a conceptual
design must be developed in sufficient detail to quantify all the direct capital and operating costs.
All costs are then expressed as an annualized cost as well as calculated cost-effectiveness
values. This approach of amortizing the investment into equal end-of-year annual costs is termed
the Equivalent Uniform Annual Cost (EUAC) (Grant, Ireson and Leavenworth 1990). It is very
useful when comparing the costs of two or more alternative control systems and is the U.S. EPA-
recommended method of estimating control costs. The EUAC costs and estimating methodology
used in this report are directed toward a "study" estimate of ±30 percent accuracy that is described
in the U.S. EPA's OAQPS Control Cost Manual (USEPA 2002/2019b). According to the Chemical
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
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Engineer's Handbook (Perry and Chilton 2008), a study estimate is "...used to estimate the
economic feasibility of a project before expending significant funds for piloting, marketing, land
surveys, and acquisition... [however] it can be prepared at relatively low cost with minimum data."
Capital and annual cost estimating methodology is described below.
4.1.4.2 Capital Costs
Several methods with varying degrees of accuracy are available for estimating capital costs of
pollutant control devices. Cost estimating techniques range from the simple "survey method"
whereby the total installed costs are equated to a basic operating parameter (e.g., gas flow rate)
to detailed cost estimates based on preliminary designs, systems drawings, and contractor
quotes. Survey method cost algorithms are derived from industry surveys of overall capital costs
of installed equipment and represent the average cost of many installations. Since there are no
provisions that permit normalization of the many site-specific parameters which affect both
equipment and installation costs, survey methods provide accuracies, at best, on the order of +50
percent to -30 percent (Vatavuk and Neveril 1980).
Detailed cost estimates on the other hand, including obtaining detailed vendor quotations against
detailed engineering bid packages, will provide better accuracies that are commensurate to the
level of design detail obtained and included in the bid package (i.e. 15/30/60/90/100% level). Each
higher level of design will require substantially more engineering work to develop with the cost
rising accordingly. Detailed designs are not generally obtained for BACT analyses due to the
substantial costs occurred and the speculative nature of the project. Generally, the approach
taken in a BACT analysis is to obtain vendor-supplied control equipment cost estimates for similar
facilities and apply a factored approach for estimating ancillary equipment and installation costs
to obtain reasonably accurate installed capital costs for controls.
4.1.4.3 Annualized Costs
Annualized costs are comprised of the direct operating costs of materials and labor for
maintenance, operation, supervision and utilities and waste disposal, and the indirect operating
charges, including plant overhead, general and administrative, and capital charges. These
generalized factors may in some cases be modified to provide more accurate, site-specific values.
Utility costs for the control device and auxiliary equipment are based on the total annual
consumption, unit costs, and vendor estimates.
Indirect operating costs include the cost of plant overhead, general and administrative (G&A), and
capital charges. G&A is a direct function of the total capital cost. Overhead is a function of both
labor (payroll and plant) and project capital cost. The capital recovery cost, or capital charge, is
based on the operational life of the system, interest and capital depreciation rates, and total capital
cost. These charges are based on the capital recovery factor (CRF) defined as:
CRF = i (1 +i)n / [(1 + i)n - 1]
where: i = the annual interest rate; and
n = equipment life (years).
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The basis for comparing the economic impacts of control scenarios is cost effectiveness. This
value is defined as the total net annualized cost of control, divided by the actual tons of pollutant
removed per year, for each control technique. Annualized costs include the capital cost plus the
financial requirements to operate the control system on an annual basis, including operating and
maintenance labor, replacement parts, overhead, raw materials, waste disposal and utilities.
Capital costs include both the direct and indirect costs of installing the equipment. Direct
installation costs include the costs for foundations, erection, electrical, piping, insulation, painting,
site preparation, and buildings. Indirect installation costs include costs for engineering and
supervision, construction expenses, startup costs and contingencies.
4.1.4.4 Cost Effectiveness
The economic impact incurred using each control alternative is measured by that alternative's
cost effectiveness. Cost effectiveness is the value obtained (in dollars per ton of pollutant
removed) by dividing the total annualized cost by the annual tons of pollutant controlled.
Cost effectiveness values provide a means to compare the economic feasibility of various control
alternatives. Although there is no single dollar per ton value which can be used to determine
whether or not a RACT alternative is economically viable, these values can be compared to other
determinations for similar sources or controls as a guide in the RACT selection.
4.1.5 Step 5: Select RACT
In Step 5 of the RACT analysis, the most effective control option not eliminated in Step 4, based
on adverse energy, economic or environmental impact is selected as RACT.
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5.0 RACT Analysis NOx
As discussed previously, the flares controlling Loading Rack 1 and Loading Rack 2 account for
10.2 tpy of the total 11.9 tpy NOx emissions emitted at the facility. The flares and associated vapor
collection system were installed to control the VOC vapors from the loading racks. The vapor
collection and flares meet NSPS XX and NESHAP BBBBBB standards. As such, the NO x
emissions from the flares controlling the Loading Racks will not be evaluated for RACT purposes,
only the VOC emissions from the Loading Racks will be evaluated further (see Chapter 6).
The emergency generator limited to 100 hr/yr annual operation makes up the remainder (1.7 tpy)
of the total NOx emissions.
5.1 Diesel-Fired Emergency Engines NOx RACT Analysis
The P66 NSL Terminal operates one (1) diesel-fired compression ignition internal combustion
engine (CI-ICE) rated at 1,118 bhp. The engine is classified as an emergency engine for purposes
of compliance with NESHAP ZZZZ. Per §63.6640(f), the engine is limited to operation during non-
emergency scenarios for up to 100 hr/yr (for maintenance and readiness testing purposes).
Furthermore, any operation other than emergency operation, maintenance and testing, and
operation in non-emergency situations for 50 hours per year, as described in 63.6640(f)(1) – (f)(4),
is prohibited.
Diesel engines are classified as compression ignition (CI) internal combustion engines. In diesel
engines, air is drawn into a cylinder as the piston creates space for it by moving away from the
intake valve. The piston’s subsequent upward swing then compresses the air, heating it at the
same time. Next, fuel is injected under high pressure as the piston approaches the top of its
compression stroke, igniting spontaneously as it contacts the heated air. The hot combustion
gases expand, driving the piston downward. During its return swing, the piston pushes spent
gases from the cylinder, and the cycle begins again with an intake of fresh air.
NOx are the gaseous nitrogen compounds created during combustion. NOx describes two main
types of nitrogen compounds, NO and NO2. The formation of NOx during combustion occurs by
two separate reaction mechanisms. The two mechanisms of formation are referred to as fuel NO x
and thermal NOx. Thermal NOx is created from the reaction between N2 and O2 supplied from the
combustion air. Fuel NOx is created from the reaction between organic nitrogen compounds within
the fuel and O2 present in the air. Diesel fuel typically contains little to no fuel bound nitrogen.
Thermal NOx is therefore the major contributor to the overall NOx emissions from an internal
combustion engine. CO and NOx are inversely related and therefore a decrease in CO emissions
will result in an increase in NOx formation, and vice versa. Therefore, the emission limits for CO
and NOx must be balanced appropriately.
5.1.1 Step 1 – Identify all Reasonably Available NOx Control Technologies
Available NOx control technologies evaluated for the existing emergency CI-ICE are summarized
below. Each technology can be classified as either a combustion control technique aimed at
reducing the formation of NOx or flue gas controls that reduce the NOx present in the exhaust
gases after formation.
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 Operation and maintenance (O&M) practices required by Federal NESHAP standards
 Engine Design (fuel injection timing retard / turbocharged / aftercooling);
 Non-Selective Catalytic Reduction (NSCR);
 Selective Non-Catalytic Reduction (SNCR); and
 Selective Catalytic Reduction (SCR).
5.1.1.1 Federal O&M Practices
The following work practices are required by NESHAP ZZZZ for stationary emergency RICE
located at an area source:
 At all times operate and maintain any affected source, including associated air pollution
control equipment and monitoring equipment, in a manner consistent with safety and
good air pollution control practices for minimizing emissions;
 Operate and maintain the stationary RICE and after-treatment control device (if any)
according to the manufacturer's emission-related written instructions or develop your
own maintenance plan which must provide to the extent practicable for the maintenance
and operation of the engine in a manner consistent with good air pollution control
practice for minimizing emissions;
 Minimize the engine's time spent at idle and minimize the engine's startup time at startup
to a period needed for appropriate and safe loading of the engine, not to exceed 30
minutes;
 Change oil and filter every 500 hours of operation or annually, whichever comes first;
 Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first,
and replace as necessary; and
 Inspect all hoses and belts every 500 hours of operation or annually, whichever comes
first, and replace as necessary.
5.1.1.2 Engine Design
NOx reductions associated with engine design include fuel injection timing retard and
turbocharged aftercooling.
Fuel injection timing retard within a combustion engine affects the formation of NO x. When the
ignition timing is advanced, the ignition occurs earlier in the power cycle and results in peak
combustion. Peak combustion is a result of the maximum pressure and temperature within the
combustion chamber. The high pressure and temperature in the combustion chamber causes an
increase in NOx formation. Conversely, when the injection timing is retarded, the ignition occurs
later in the power cycle, resulting in lower NO x emissions.
Injection timing retardation may reduce NO x formation by 20 to 30 percent on average. The NO x
emissions are reduced by decreasing the operating pressure, temperature, and residence time
within the combustion chamber. Injection timing retardation is capable of reducing NO x emissions
without adversely affecting performance such as decreased power output, increased exhaust
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temperatures, misfiring, and elevated opacity during engine startup. The engine manufacturer
should recommend the degree of injection timing retardation based on tests of similar size and
type engines. Injection timing is a technically feasible and demonstrated NO x control technology
for a diesel-fired CI-ICE.
Aftercooling is a technology to lower the intake charge air temperature thereby lowering peak
cylinder temperatures and NO x formation.
5.1.1.3 Non-Selective Catalytic Reduction (NSCR)
Non-Selective Catalytic Reduction (NSCR) uses a three-way catalyst to promote the reduction of
NOx to nitrogen and water. NSCR is applicable only to rich burn engines (i.e., those with exhaust
oxygen concentration below about 1 percent). NSCR, in addition to the catalyst and catalyst
housing, requires an oxygen sensor and air-fuel ratio controller to maintain an appropriate air to
fuel ratio. Some ammonia can be produced particularly as the catalyst ages. The simplified
reactions governing NSCR are as follows:
2N2COCOxNO
2NO2H2COHCxNO
The exhaust passes over the catalyst, usually a noble metal (platinum, rhodium or palladium)
which reduces the reactants to N 2, CO2, and H2O. Typical exhaust temperatures for effective
removal of NOx are 800-1,200 degrees Fahrenheit (°F).
5.1.1.4 Selective Non-Catalytic Reduction (SNCR)
SNCR is applicable to lean burn diesel engines. SNCR involves injecting ammonia or urea into
regions of the exhaust with temperatures greater than 1,400-1,500°F. The nitrogen oxides in the
exhaust are reduced to nitrogen and water vapor.
5.1.1.5 Selective Catalytic Reduction (SCR)
SCR is applicable to lean burn diesel engines and is a post-combustion gas treatment technique
for the reduction of NO and NO2 in the exhaust stream to molecular nitrogen, water, and oxygen.
Ammonia is used as the reducing agent. The basic reactions are:
O2H3/22N2O1/4NO3NH 
O2H3/22N3/42O1/42NO1/23NH 
The catalyst’s active surface is usually either a noble metal or base metal (titanium or vanadium
oxide, or a zeolite-based material). Metal-based catalysts are usually applied as a coating over a
metal or ceramic substrate. These catalysts have a typical active range between 550°F and
750°F. Zeolite catalysts are typically a homogeneous material that forms both the surface and the
substrate. The most common catalyst body configuration is a monolithic, “honeycomb” design.
An ammonia injection grid is located upstream of the catalyst body and is designed to disperse
the ammonia uniformly across the exhaust flow before it enters the catalyst unit. In a typical
ammonia injection system, anhydrous ammonia is drawn from a storage tank and evaporated
using a steam or electric-heated evaporator. The vapor is mixed with a pressurized carrier gas to
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provide both sufficient momentum through the injection nozzles and effective mixing of the
ammonia with the exhaust gases. The carrier gas is usually compressed air or steam.
An alternative to using anhydrous ammonia is to vaporize an aqueous ammonia solution. This
system reduces the potential safety hazards associated with transporting and storing anhydrous
ammonia.
A more recent advance is to produce gaseous NH3 from urea. Urea, in granular form, is not a
hazardous material and can be safely transported to the site and converted to NH 3 based on
demand. The hazards associated with storing either anhydrous or aqueous ammonia are
eliminated. Depending on NH 3 requirements, two approaches for utilizing urea are available. For
relatively small amounts of NH3, hot gases from the exhaust are mixed in a chamber with a urea
solution where NH3 is released. The gases are then routed to the injection grid. For higher flows,
the urea solution is directed over a catalyst bed to speed the conversion process.
As indicated by the chemical reaction equations listed above, it takes one mole of NH 3 to reduce
one mole of NO, and two moles of NH3 to reduce one mole of NO2. SCR systems generally
operate with a molar NH3 /NO ratio greater than stoichiometric to achieve optimal conversion
efficiencies, resulting in the passage of unreacted NH3 to the atmosphere, which is commonly
referred to as ammonia slip.
5.1.2 Step 2 & 3 - Technical Feasibility of NOx Controls
Technologies and practices that have been assessed as part of this analysis are summarized in
Table 5-1 . Of the five options identified, only Federal O&M practices and SCR is considered
technically feasible other than the base case controls implemented through engine design.
NSCR is applicable only to rich burn engines (oxygen contents less than approximately 1
percent). The diesel-fired CI-ICE is a lean burn engine which cannot utilize the technology.
Therefore, NSCR is not technically feasible and will not be considered further for RACT.
SNCR requires an operating temperature in the 1,400 to 1,500°F range. This temperature range
is much greater than the exhaust temperature of a typical CI-ICE. Additional fuel would need to
be combusted in the exhaust to elevate the temperature. This would create additional emissions
and greatly increase the cost of the exhaust system. Therefore, SNCR is not considered a viable
technology for RACT.
Table 5-1 Technical Feasibility of Diesel-fired CI-ICE NO x Controls
Controls Technically
Feasible?
Meet Federal O&M practices Yes
Engine Design - (fuel injection timing retard / turbocharged / aftercooling)Yes
NSCR No
SNCR No
SCR Yes
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The technology assessment above identifies only Engine Design and SCR as viable technologies
for reducing NOx emissions. Most if not all the engine design features are already incorporated
into the engine to meet the EPA Tier II emission standards. Therefore, only SCR will be evaluated
as a potential option to further reduce NOx emissions.
5.1.3 Step 4 – Evaluation of Feasible Control Options
5.1.3.1 Selective Catalytic Reduction
Since SCR systems require an operating temperature between 260°C and 540°C, reaching these
temperatures may be difficult in routine maintenance and testing operations where the engine is
typically operated at low load for a short period of time. If the critical temperatures are not met
while the engine is running, there will be no NO x reduction benefit. To have NOx reduction benefit,
the engine would need to be operated with higher loads and for a longer period. This would be a
challenge since the engine is limited to 100 hr/yr.
Urea handling and maintenance must also be considered. Urea crystallization in the lines can
damage the SCR system and the engine itself. Crystallization in the lines is more likely in
emergency standby engines due to their periodic and low hours of usage.
There are several downsides to using SCR. First, an improperly functioning SCR system can
create excess ammonia emissions. SCR systems also add significant equipment to the engine
system which increases the possibility of failures and increases on-going maintenance costs.
The use of SCR can reduce NOx emissions in the range from 70 to 90%, or by approximately 0.5
to 1.5 tpy (from 1.7 tpy to 1.2 or 0.2 tpy) for the diesel-fired CI-ICE. The economic costs associated
with installing a SCR system for such a small reduction in NOx emissions are prohibitive, not to
mention its highly unlikely the engine would be at proper operating temperature for the SCR to be
effective due to the limited operating hours, and the extra maintenance and disposal costs if urea
were used. Therefore, SCR will not be considered further.
5.1.4 Step 5 - CI-ICE NOx RACT Determination
Periodic maintenance is performed on the engine in accordance with manufacturer specifications.
Since the engine is subject to Subpart ZZZZ, the oil is changed, and hoses/belts are inspected
every 500 hours or annually. Therefore, RACT for the diesel-fired CI-ICE emergency generator
engine is 100 hr/yr annual operating limit, good operational practices according to the
manufacturer’s recommendations and design, proper maintenance and operation, and
compliance with applicable Subpart ZZZZ requirements. These requirements have been
determined to be RACT. These control strategies are technically feasible and will not cause any
adverse energy, environmental, or economic impacts.
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6.0 RACT Analysis – VOCs
RACT was evaluated for VOC emissions from the following emission units in operation at the NSL
Terminal.
 Two (2) Loading Racks
 Storage Tanks
o Six (6) Vertical Fixed Roof Storage Tanks (VFRT)
o Four (4) Internal Floating Roof Storage Tanks (IFRT)
o Six (6) External Floating Roof Storage Tanks (EFRT)
 Fugitive Emissions/Equipment Leaks
VOC emissions from the emergency diesel-fired CI-ICE were not reviewed for RACT as the
potential to emit VOC emissions from the emergency engine total 0.04 tpy.
6.1 RACT for Loading Racks
VOC emissions are displaced to the atmosphere when cargo tank trucks are filled with gasoline.
The vapors can be controlled by one or more of the following methods:
1. Load only to vapor-tight cargo tank trucks compatible with the terminal’s vapor collection
system (VCS)
2. Design a VCS to collect total VOCs displaced from cargo tank truck loading to route vapors
collected from loading operations to a vapor processing system (VPS) including:
 refrigeration based control system;
 vapor recovery unit (VRU) with carbon adsorption; or
 thermal oxidation system (open or enclosed flare)
3. Employ top-submerged or bottom loading of cargo tank trucks.
4. Minimize spills and clean up any spills expeditiously.
The NSL Terminal operates two (2) loading racks used for gasoline and diesel product loading.
VOC vapors are discharged from the tankers as they are filled. Each of the loading racks are
operated with a vapor recovery unit with two (2) John Zink flares as their control devices.
The loading racks are each subject to NSPS XX and NESHAP BBBBBB. The intent of NSPS XX
is to minimize the emissions of VOC from loading racks at bulk gasoline terminals which deliver
liquid product into gasoline tank trucks through the application of best demonstrated technologies
(BDT). NESHAP BBBBBB establishes emission limitations and management practices for HAPs
emitted from gasoline storage tanks, loading racks, and equipment leaks at area source gasoline
distribution bulk terminals, bulk plants, and pipeline facilities.
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NSPS XX establishes VOC emission limits from the NSL bulk gasoline terminal as follows:
§60.502(a) requires each affected facility to be equipped with a vapor collection system (VCS)
designed to collect total organic compounds (TOC) vapors displaced from tank
trucks during project loading.
§60.502(c) Limits the emissions to the atmosphere from the VCS to 80 milligrams of TOC per
liter (L) of gasoline loaded (80 mg TOC/L).
§60.502(e) Limits loading of liquid product into gasoline trucks to vapor-tight gasoline trucks.
§60.502(j)Requires that each calendar month, the VCS, vapor processing system, and each
loading rack handling gasoline be inspected during loading of gasoline trucks for
TOC, liquids or vapor leaks.
NESHAP BBBBBB established emission limits and management practices for gasoline storage
tanks, gasoline loading racks, and equipment leaks at the NSL bulk gasoline terminal as follows:
Gasoline Storage Tanks (§63.11087)
§63.11087(a) Equip each internal floating roof gasoline storage tank according to the
requirements in §60.112b(a)(1) of this chapter, except for the secondary seal
requirements under §60.112b(a)(1)(ii)(B) and the requirements in
§60.112b(a)(1)(iv) through (ix) of this chapter; and
Equip each external floating roof gasoline storage tank according to the
requirements in §60.112b(a)(2) of this chapter, except that the requirements of
§ 60.112b(a)(2)(ii) of this chapter shall only be required if such storage tank
does not currently meet the requirements of §60.112b(a)(2)(i) of this chapter.
Bulk Gasoline Terminal Loading Rack (§63.11088)
§63.11088(a) Equip your loading rack(s) with a vapor collection system designed to collect
the TOC vapors displaced from cargo tanks during product loading; and
Reduce emissions of TOC to less than or equal to 80 mg/l of gasoline loaded
into gasoline cargo tanks at the loading rack; and
Design and operate the vapor collection system to prevent any TOC vapors
collected at one loading rack or lane from passing through another loading rack
or lane to the atmosphere; and
Limit the loading of gasoline into gasoline cargo tanks that are vapor tight using
the procedures specified in § 60.502(e) through (j) of this chapter. For the
purposes of this section, the term “tank truck” as used in § 60.502(e) through (j)
of this chapter means “cargo tank” as defined in §63.11100.
Bulk Gasoline Terminal Equipment Leak Inspections (§63.11089)
§63.11088(a) Perform a monthly leak inspection of all equipment in gasoline service, as
defined in § 63.11100. For this inspection, detection methods incorporating
sight, sound, and smell are acceptable.
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In summary, Phillips 66 NSL Terminal maintains compliance with the applicable provisions to
these rules as part of its good process management practices to limit emissions. This includes:
 Utilizing a vapor collection system to collect vapors during truck loading.
 Limiting loading of product into tank trucks that are vapor tight.
 Maintaining emissions below 10 mg TOC/L of product loaded.
It should be noted that the Phillips 66 NSL Terminal has a TOC limit from each of the loading
racks of 10 mg TOC/L, which is eight (8) times lower than the NSPS XX and NESHAP BBBBBB
emission standard of 80 mg TOC/L as discussed above.
The existing loading racks are controlled by two John Zink air-assisted flares, model LHT-2-20-
25X1/10-2/20-X and model LHT-3-24-25-3/10-1/10-X. The use of flares is considered best
available control technology (BACT) for loading racks. Further, the loading rack NO x and VOC
emission rates (4.0 mg/liter and 10.0 mg/liter of gasoline loaded respectively) are lower than the
performance criteria for a controlled products loading facility found in NSPS XX and NESHAP
BBBBBB regulations, which also constitutes BACT.
The NSL Terminal loading racks already employ the highest level of control. Therefore, RACT for
the loading racks is the use of the existing VCS and flares, compliance with the work practice
standards of NSPS XX and NESHAP BBBBBB, including loading to certified vapor-tight cargo
tank trunks, and use of the VCS and flares to attain emission rates for NO x and VOC (4.0 mg
NOx/liter and 10.0 mg TOC/liter gasoline loaded respectively).
6.2 RACT for Vertical Fixed Roof Storage Tanks
The NSL Terminal operates six (6) vertical fixed roof storage tanks (VFRT). Emissions from fixed
roof tanks are a result of evaporative losses during storage (known as breathing losses or
standing losses) and evaporative losses during filling operations (known as working losses).2
Working losses occur during filling of the tank, where the rising liquid level displaces vapors in the
tank headspace (vapor volume above the liquid level), which may be vented from breather vents.
Breathing losses, also called standing losses, occur as a result of temperature fluctuations that
cause expansion of vapors in the tank headspace and venting from the breather vents. For tanks
that are insulated and heated, and operated at a near-constant temperature, breathing losses are
zero or very low. The VFRTs at the NSL Terminal are only used to store heavy distillates with low
vapor pressures due to the low VOC emissions resulting from storing heavy distillates. The VFRTs
operated at the NSL Terminal that reported emissions in 2017 are presented in Table 6-1.
2 EPA Publication AP 42, Fifth Edition, Volume I Chapter 7: Liquid Storage Tanks, 2020.
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Table 6-1 Vertical Fixed Roof Tanks at NSL Terminal
Tank ID Tank Size / Year Constructed Product Stored / True
Vapor Pressure
PTE VOC
(tpy)
2017 VOC
(tpy)
TNK 202 20,000 bbl (880,000 gals) / 1953
Distillate /
< 0.0085 psia
(< 0.0586 kPa)
0.40 0.11
TNK 205 30,000 bbl (1,260,000 gals) / 1953 0.61 0.56
TNK 206 20,000 bbl (880,000 gals) / 1953 0.40 0.11
TNK 215 30,000 bbl (1,260,000 gals) / 1953 0.61 0.46
TNK 216 20,000 bbl (880,000 gals) / 1953 0.40 0.11
TNK 227 100,000 bbl (4,200,000 gals) / 2000 2.03 1.59
Total 4.45 2.94
6.2.1 Step 1 – Identify all Available VOC Control Technologies
Potential control technologies for VOC emissions from vertical fixed roof storage tanks include:
 Closed Vent System/Vapor Recovery/Route to Control Device,
 Retrofit Tank with an Internal Floating Roof Tank, and
 Application of Tank Standards.
6.2.2 Step 2 – Technical Feasibility of VOC Control Technologies
6.2.2.1 Closed Vent System/Vapor Recovery/Route to Control Device
Evaporative vapor volumes generated by very low vapor pressure liquid distillates stored in the
VFRTs are low and intermittent. Vapor would only be emitted from a VFRT during periods when
the pressure within the tank headspace exceeds pressure relief vent set points. There is
insufficient pressure differential to move vapor to a control device without compression. It is
technically infeasible to install vapor recovery compression because the compressors would be
continually shutting down or recycling due to low and intermittent flow conditions.
6.2.2.2 Retrofitting VFRT with IFR
The primary technical drawback with retrofitting a fixed roof tank with an internal floating roof (IFR)
is that storage tanks lose approximately 6-8 feet of working capacity, including 3-5 feet at the top
of the tank to support the installation and operations of the IFR, and approximately 3 feet at the
bottom of the tank to ensure that landing of the IFR does not occur (resulting in excess emissions).
The loss of capacity is estimated to range from 20-40%. This loss of tank capacity could potentially
require installation of additional storage tanks to support operational requirements. Given the age
of these tanks (1953) an additional concern would be tank integrity and the ability to sustain an
IFR retrofit. Several modifications may be necessary on a VFRT before it can be equipped with
an IFR. Tank shell deformations and obstructions may require correction, and special structural
modifications such as bracing, reinforcing, and plumbing vertical columns may be necessary.
Antirotational guides should be installed to keep floating roof openings in alignment with fixed roof
openings. In addition, special vents may be installed on the fixed roof or on the walls at the top of
the shell to minimize the possibility of VOL vapors approaching the explosive range in the vapor
space.
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Installation of an IFR in an existing VFRT includes the following at a minimum:
• Identification and procurement of a floating roof and rim seals,
• Ladder, roof negotiator, and fixed roof view hatch,
• Verticality survey,
• Door sheet,
• Gauge pole and gauge pole cover,
• Floating roof leg covers, and
• Hydrotesting.
6.2.2.3 Application of Tank Standards
New Source Performance Standards (NSPS) for petroleum liquid storage vessels are covered by
three separate subparts of 40 CFR Part 60. Subpart K pertains to storage vessels constructed or
modified after June 11, 1973, but before May 19, 1978. Subpart Ka pertains to storage vessels
constructed or modified after May 19, 1978, but before July 23, 1984. Subpart Kb pertains to
storage vessels constructed or modified after July 23, 1984.
Subpart K applies to petroleum liquid storage vessels with storage capacities greater than 40,000
gallons, as well as storage vessels with capacities between 40,000 and 65,000 gallons that were
constructed or modified after March 8, 1974, and before May 19, 1978. Storage vessels for
petroleum or condensate stored, processed, and/or treated at a drilling and production facility
prior to custody transfer are exempt from this subpart. Subpart K requires storage vessels that
store petroleum liquids with true vapor pressures between 1.5 and 11.1 psia to be equipped with
a floating roof and a vapor recovery system, or other equivalent equipment. For petroleum liquids
with a true vapor pressure greater than 11.1 psia, a vapor recovery system or equivalent
equipment is required.
Subpart Ka applies to petroleum liquid storage vessels with storage capacities greater than
40,000 gallons, however storage vessels with storage capacities less than 420,000 gallons used
for petroleum or condensate stored, processed or treated prior to custody transfer are exempt.
Storage vessels containing petroleum liquids with true vapor pressures between 1.5 and 11.1
psia should be equipped with either an external floating roof, a fixed roof with an internal floating
type cover, a vapor recovery system that collects all VOC vapors and discharged gases, or an
equivalent system. Storage vessels containing petroleum liquids with true vapor pressures greater
than 11.1 psia should be equipped with a vapor recovery system to collect all discharged gases
and a vapor return or disposal system to reduce VOC emissions by at least 95% by weight.
NSPS Kb applies to volatile organic liquid (VOL) storage vessels, which includes petroleum liquid
storage vessels, with capacities greater than or equal to 75 m 3 (~20,000 gals). However, this
subpart excludes storage vessels with capacities greater than 151 m 3 (~40,000 gals) storing a
liquid with a maximum true vapor pressure less than 3.5 kPa (0.5 psia) or vessels with capacities
between 75 and 151 m3 storing a liquid with a maximum true vapor pressure less than 15.0 kPa
(2.18 psia). For storage vessels greater than 151 m 3 in size containing a VOL with a maximum
true vapor pressure between 5.2 kPa (0.75 psia) and 76.6 kPa (11.1 psia) and vessels sized
between 75 and 151 m 3 storing a VOL with a maximum true vapor pressure between 27.6 kPa
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(4.0 psia) and 76.6 kPa (11.1 psia) should be equipped with either a fixed roof with an internal
floating roof, an external floating roof, a closed vent system and control device, or an equivalent
system. Storage vessels with capacities greater than 75 m 3 containing a VOL with a maximum
true vapor pressure greater than or equal to 76.6 kPa should be equipped with a closed vent
system and control device or equivalent system.Table 6-2 summarizes NSPS Kb standards.
Table 6-2 Summary of NSPS Subpart Kb Applicability and Control Thresholds
Design Capacity3 Maximum True Vapor
Pressure4
Standards for VOC Citation
1. < 75 cubic meters
(~20,000 gals)n/a Not regulated § 60.110b(a)
2. ≥ 75 cubic meters
(~20,000 gals), but <151
cubic meters (~40,000
gals)
< 15.0 kPa (2.18 psia)Not regulated § 60.110b(b)
≥ 27.6 kPa (4.0 psia), but
< 76.6 kPa (11.1 psia)IFR, EFR or CVS/CD § 60.112b(a)
3. ≥ 151 cubic meters
(~40,000 gals)
< 3.5 kPa (0.5 psia)Not regulated § 60.110b(b)
≥ 5.2 kPa (0.75 psia), but
< 76.6 kPa (11.1 psia)IFR, EFR or CVS/CD § 60.112b(a)
4. ≥ 75 cubic meters
(~20,000 gals)≥ 76.6 kPa (11.1 psia)CVS/CD or equivalent § 60.112b(b)
40 CFR 63 Subpart WW applies to the control of air emissions from storage vessels for which
another subpart references the use of Subpart WW for air emission control. EPA promulgated 40
CFR Part 63 Subpart WW as part of the generic MACT standards program. Subpart WW was
developed for the purpose of providing consistent EFR and IFR requirements for storage vessels
that could be referenced by multiple NESHAP subparts. Like the NSPS Subpart Kb standards for
floating roof tanks, Subpart WW is comprised of a combination of design, equipment, work
practice, and operational standards. Both rules specify monitoring, recordkeeping, and reporting
for storage vessels equipped with EFR and IFR and both include requirements for inspections to
occur within defined timeframes. The inspections required by Subpart WW are intended to
achieve the same goals as those inspections required by Subpart Kb. Subpart WW allows for the
visual inspection of the floating roof deck, deck fittings, and rim seals while the tank remains in
service if physical access is possible. Subpart WW does not require the tank to be taken out of
service to inspect the floating roof, rim seals and deck fittings which contrasts with Kb
requirements.
Utah Administrative Code R307-327 presents the requirements of petroleum liquid storage in
ozone nonattainment and maintenance areas. R307 -327-4 states (1) Any existing stationary
storage tank, with a capacity greater than 40,000 gallons (150,000 liters) that is used to store
volatile petroleum liquids with a true vapor pressure greater than 10.5 kilo pascals (kPa) (1.52
psia) at storage temperature shall be fitted with control equipment that will minimize vapor loss to
the atmosphere. Storage tanks, except for tanks erected before January 1, 1979, which are
equipped with external floating roofs, shall be fitted with an internal floating roof that shall rest on
3 Based on internal shell diameter and height.
4 Defined in § 60.111b.
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
6-7
the surface of the liquid contents and shall be equipped with a closure seal or seals to close the
space between the roof edge and the tank wall, or alternative equivalent controls. The owner/
operator shall maintain a record of the type and maximum true vapor pressure of stored liquid.
(2) The owner/operator of a petroleum liquid storage tank not subject to (1) above but containing
a petroleum liquid with a true vapor pressure greater than 7.0 kPa (1.0 psia), shall maintain
records of the average monthly storage temperature, the type of liquid, throughput quantities, and
the maximum true vapor pressure.
6.2.3 Step 5 – RACT Selection
Under NSPS regulations, control equipment is generally required when storing volatile organic
liquids with vapor pressures of 1.5 psia or greater. Tanks storing volatile organic liquids below the
vapor pressure threshold are required to keep records of types of products stored and their vapor
pressures, periods of storage and tank design specifications.
Distillate products are stored in the six (6) fixed roof tanks at the NSL Terminal. NSPS Kb
specifically exempts storage tanks storing a volatile organic liquid with a true vapor pressure less
than 3.5 kPa (0.5 psia) as the emissions are minimal and hence why VFRTs are used to store
these products at the NSL Terminal. Compliance with Subpart Kb is not applicable to the VFRTs
at the NSL Terminal as the tanks are exempt from the rule due to commenced construction date,
size and the vapor pressure of product stored.
Total VOC emissions from the six (6) VFRTs at the NSL Terminal are 4.5 tpy (PTE) and 3.0 tpy
(2017 actual). Potential control efficiencies for a vapor recovery system, thermal oxidizer, and
retrofitting to IFR range from 60% to 98%, or a reduction in VOC emissions from all the fixed roof
tanks ranging from 1.8 tpy to 2.9 tpy from 2017 actual emissions. However, the installed capital
and annual operating costs to install additional controls on each of the tanks would be cost
prohibitive and not economically feasible for the very small reduction in VOC emissions.
Therefore, RACT for VOC emissions from the six (6) fixed roof tanks at the NSL Terminal is good
design methods and operating procedures, and keeping records of the type and maximum true
vapor pressure of stored liquid in each VFRT as additional control technology is not economically
feasible.
6.3 RACT for Internal Floating Roof Storage Tanks
The NSL Terminal operates four (4) internal floating roof storage tanks (IFRT). An internal floating
roof tank has both a permanently affixed roof and a roof that floats inside the tank on the liquid
surface (contact deck) or is supported on pontoons several inches above the liquid surface
(noncontact deck). The internal floating roof rises and falls with the liquid level. Emissions from a
floating roof tank come from both withdrawal losses and standing losses. Withdrawal losses are
generally due to liquid level fluctuations associated with adding material into the tank and
removing material from the tank and standing storage losses originate from the rim seal(s),
floating roof deck fittings, and the deck seams (for non-welded tanks). IFRTs operated at the NSL
Terminal that reported emissions in 2017 are presented in Table 6-3.
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
6-8
Table 6-3 Internal Floating Roof Tanks at NSL Terminal
Tank ID Tank Size / Year Constructed Product Stored / True
Vapor Pressure
PTE VOC
(tpy)
2017 VOC
(tpy)
TNK 225 88,000 bbl (3,696,000 gals) / 1988 Gasoline /
< 4.68 psia
(< 32.27 kPa)
5.71 3.56
TNK 228 80,000 bbl (3,360,000 gals) / 2013 4.57 7.46
TNK 2261 9,400 bbl (394,800 gals) / 1992 1.60 0.62
TNK 212 20,000 bbl (880,000 gals) / 1953
Ethanol /
< 0.8 psia
(< 5.5 kPa)
0.24 0.33
Total 12.12 11.97
1 –Switched from transmix service to gasoline in 2021
6.3.1 Step 1 – Identify all Available VOC Control Technologies
Potential control technologies for VOC emissions from internal floating roof storage tanks include:
 NSPS Subpart Kb,
 40 CFR 63 Subpart WW Controls, and
 Installation of a Vapor Recovery System with Vapor Combustion.
6.3.1.1 NSPS Subpart Kb
NSPS Subpart Kb applies to volatile organic liquid (VOL) storage vessels, which includes
petroleum liquid storage vessels, with capacities greater than or equal to 75 m 3 (~20,000 gals).
However, this subpart excludes storage vessels with capacities greater than 151 m 3 (~40,000
gals) storing a liquid with a maximum true vapor pressure less than 3.5 kPa (0.5 psia) or vessels
with capacities between 75 and 151 m3 storing a liquid with a maximum true vapor pressure less
than 15.0 kPa (2.18 psia). For storage vessels greater than 151 m 3 in size containing a VOL with
a maximum true vapor pressure between 5.2 kPa (0.75 psia) and 76.6 kPa (11.1 psia) and vessels
sized between 75 and 151 m 3 storing a VOL with a maximum true vapor pressure between
27.6 kPa (4.0 psia) and 76.6 kPa (11.1 psia) should be equipped with either a fixed roof with an
internal floating roof, an external floating roof, a closed vent system and control device, or an
equivalent system. Storage vessels with capacities greater than 75 m 3 containing a VOL with a
maximum true vapor pressure greater than or equal to 76.6 kPa should be equipped with a closed
vent system and control device or equivalent system.
6.3.1.2 40 CFR Part 63 Subpart WW Controls
40 CFR Part 63, Subpart WW was written to be reference by other regulations to control air
emissions from storage vessels and is considered by EPA as the standard for EFR and IFR
requirements under NESHAP. Subpart WW was developed for the purpose of providing
consistent EFR and IFR requirements for storage vessels that could be referenced by multiple
NESHAP subparts. Like the NSPS Subpart Kb standards for floating roof tanks, Subpart WW is
comprised of a combination of design, equipment, work practice, and operational standards. Both
rules specify monitoring, recordkeeping, and reporting for storage vessels equipped with EFR and
IFR and both include requirements for inspections to occur within defined timeframes. The
inspections required by Subpart WW are intended to achieve the same goals as those inspections
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
6-9
required by Subpart Kb. Subpart WW allows for the visual inspection of the floating roof deck,
deck fittings, and rim seals while the tank remains in service if physical access is possible. Subpart
WW does not require the tank to be taken out of service to inspect the floating roof, rim seals and
deck fittings which contrasts with Kb requirements.
6.3.1.3 Installation of a Vapor Recovery System
The function of a vapor recovery system is to collect VOC emissions from storage tanks that can
be routed to a fuel gas system for combustion as fuel. Vapor recovery can be achieved through
carbon adsorption, condensation, or absorption.
6.3.2 Step 2 - Technical Feasibility of Control Technologies
The above control technologies are technically feasible. All three tanks are currently subject and
in compliance with NSPS Kb standards and NESHAP BBBBBB standards.
6.3.3 Step 3 - Effectiveness of Feasible Control Technologies
All the above control options, degassing controls when storage tanks are taken out of service,
installation of a vapor recovery system and NSPS Subpart Kb controls have equivalent control
efficiencies.
6.3.4 Step 4 – Evaluation of Feasible Control Technologies
Utah Administrative Code R307-327 presents the requirements of petroleum liquid storage in
ozone nonattainment and maintenance areas. R307 -327-4 states (1) Any existing stationary
storage tank, with a capacity greater than 40,000 gallons (150,000 liters) that is used to store
volatile petroleum liquids with a true vapor pressure greater than 10.5 kPa (1.52 psia) at storage
temperature shall be fitted with control equipment that will minimize vapor loss to the atmosphere.
Storage tanks, except for tanks erected before January 1, 1979, which are equipped with external
floating roofs, shall be fitted with an internal floating roof that shall rest on the surface of the liquid
contents and shall be equipped with a closure seal or seals to close the space between the roof
edge and the tank wall, or alternative equivalent controls. The owner/ operator shall maintain a
record of the type and maximum true vapor pressure of stored liquid. (2) The owner/operator of a
petroleum liquid storage tank not subject to (1) above but containing a petroleum liquid with a true
vapor pressure greater than 7.0 kPa (1.0 psia), shall maintain records of the average monthly
storage temperature, the type of liquid, throughput quantities, and the maximum true vapor
pressure. The NSL Terminal IFR Tanks listed in Table 6-3 meet the requirements of R307-327.
Since Phillips 66 is currently using the highest-ranking control options for the IFR tanks, energy,
environmental and economic impact analyses are not required.
6.3.5 Step 5 – RACT Selection
Internal floating roof tanks currently meeting NSPS Kb is considered RACT. In addition, IFR tanks
that are currently meeting NESHAP BBBBBB [§63.11087(a)] control requirements are considered
to meet RACT Thus, the existing IFR tanks at Phillips 66 NSL Terminal meet RACT requirements.
IFR tanks at the NSL Terminal utilize mechanical shoe seals. During tank shutdown and
degassing, the NSL Terminal lands the roofs and empties/degases the IFR tanks in a continuous
operation.
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
6-10
6.4 RACT for External Floating Roof Storage Tanks
The NSL Terminal operates six (6) external floating roof storage tanks (EFRT). An external
floating roof tank consists of an open-top cylindrical steel shell equipped with a roof that floats on
the surface of the stored liquid. There are two types of floating roofs, a double-deck roof and a
pontoon roof. Both types of roofs rise and fall with the liquid level in the tank. Emissions from
external floating roof tanks are due to standing storage losses from the rim seal system and deck
fittings and withdrawal losses from the evaporation of exposed liquid on the tank walls. Withdrawal
losses are generally due to liquid level fluctuations and standing storage losses originate from the
rim seal and deck fittings. EFRTs operated at the NSL Terminal that reported emissions in 2017
are presented in Table 6-4.
Table 6-4 External Floating Roof Tanks at NSL Terminal
Tank ID Tank Size / Year Constructed Product Stored / True
Vapor Pressure
PTE VOC
(tpy)
2017 VOC
(tpy)
TNK 201 80,000 bbl (3,360,000 gals) / 1953
Gasoline /
< 4.68 psia
(< 32.27 kPa)
4.97 0.68
TNK 204 40,000 bbl (1,680,000 gals) / 1952 1.34 0.01
TNK 211 80,000 bbl (3,360,000 gals) / 1953 9.46 3.81
TNK 214 40,000 bbl (1,680,000 gals) / 1952 4.22 2.22
TNK 221 80,000 bbl (3,360,000 gals) / 1953 4.97 3.43
TNK 224 1 20,000 bbl (840,000 gals) / 1953
Distillate /
< 0.0085 psia
(< 0.0586 kPa)
0.08 6.51
Total 25.04 16.66
1 – Tank 224 was storing Transmix in 2017, new PTE is based on storing distillate, hence emissions decrease for current PTE.
6.4.1 Step 1 – Identify all Available VOC Control Technologies
Potential control technologies for VOC emissions from internal floating roof storage tanks include:
 NSPS Subpart Kb,
 40 CFR 63 Subpart WW Controls,
 Degassing controls when storage tanks taken out of service,
 Dome Retrofit, and
 Installation of a Vapor Recovery System with Vapor Combustion.
6.4.2 Step 2 - Technical Feasibility of Control Technologies
The Phillips 66 NSL Terminal is in an earthquake zone as well as an area that consistently gets
considerable snowfall year over year. As such, the retrofit of external floating roof tanks with dome
roofs is technically infeasible. Since a dome to capture emission is technically infeasible, the
installation of a vapor recovery system with vapor combustion is also technically infeasible. The
remaining control technologies are technically feasible. All six (6) EFR tanks currently meet
NSPS Kb control requirements and are subject and in compliance with NESHAP BBBBBB control
requirements and standards.
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
6-11
6.4.3 Step 3 - Effectiveness of Feasible Control Technologies
The remaining control options, NSPS Kb controls/NESHAP BBBBBB, and degassing controls
when storage tanks are taken out of service, have equivalent control efficiencies, and will vary by
tank.
6.4.4 Step 4 – Evaluation of Feasible Control Technologies
As stated previously, all six (6) EFR tanks listed in Table 6-4 currently meet NSPS Kb control
requirements and are subject and in compliance with NESHAP BBBBBB control requirements
and standards.
6.4.5 Step 5 – RACT Selection
All six (6) of the NSL Terminal EFR tanks currently meet NSPS Kb control requirements which is
considered to meet RACT. In addition, EFR tanks that are currently meeting NESHAP BBBBBB
[§63.11087(a)] control requirements are considered to meet RACT Thus, the existing EFR tanks
at Phillips 66 NSL Terminal meet RACT requirements. EFR tanks at the NSL Terminal utilize
primary mechanical shoe seals and continuous rim-mounted secondary seals. During tank
shutdown and degassing, the NSL Terminal lands the roofs and empties/degases the EFR tanks
in a continuous operation.
6.5 RACT for Equipment Leaks
The NSL Terminal is a small source of VOC emissions associated with onsite equipment
components such as valves, flanges, compressors, and piping in gasoline services. As with most
facilities that are sources of fugitive VOC emissions from equipment leaks, the NSL Terminal has
implemented onsite maintenance procedures to identify and eliminate equipment leaks. In
addition, the facility is subject to NESHAP BBBBBB §63.11089 that requires the facility to perform
monthly leak detection and repair (LDAR) inspections of all equipment in gasoline service, thereby
minimizing VOC emissions. The monthly LDAR inspections consist of audio, video, olfactory
(AVO) which includes conducting site surveys for equipment leaks and relying on sight, sound,
and smell to identify and locate equipment leaks and qualitatively assess the concentration of the
leak [§63.11089(a)]. Each detection of a liquid or vapor leak is recorded in a logbook and an initial
attempt to repair the leak is made as soon as possible, but no later than 5 calendar days after the
leak is detected. Repair or replacement of leaking equipment is completed within 15 calendar
days, unless the repair is not feasible within 15 days [§63.11089(c) & (d)].
An LDAR instrument-based monitoring program typically includes conducting site survey for
equipment leaks using an instrument (flame ionization detector, photoionization detector, or
infrared camera, etc.) to identify and locate equipment leaks and quantitatively assess the
concentration of the leak. The implementation of an instrument based LDAR program requires
hiring external contractors to support the proper implementation of the program considering
personnel availability, training, instrumentation requirements, etc.
Considering the additional investment needed by the NSL Terminal to support an instrument
based LDAR program either supported by external contractor or by site personnel for minimal
additional reduction in VOC emissions, RACT is determined to be to continue to comply with
NESHAP BBBBBB §63.11089.
Pioneer Investments Corporation – Phillips 66 Corporation
Reasonably Available Control Technology Analysis
Report Issue Date: December 14, 2023
SLR Project No.: 118.01357.00013
7-1
7.0 Summary of NOx and VOC RACT Analyses
At the request of the UDAQ, a NOx and VOC RACT analysis was prepared for the following
emission units in operation at the NSL Terminal:
 One (1) Diesel-Fired Emergency Engine (NOx RACT)
 Two (2) Loading Racks (VOC RACT)
 Storage Tanks (VOC RACT)
o Six (6) Vertical Fixed Roof Storage Tanks
o Four (4) Internal Floating Roof Storage Tanks
o Six (6) External Floating Roof Storage Tanks
 Fugitive Emissions/Equipment Leaks (VOC RACT)
VOC emissions from the emergency diesel-fired CI-ICE were not reviewed for RACT as the
potential to emit VOC emissions from the emergency engine total 0.04 tpy. The flares and
associated vapor collection system at the NSL Terminal were installed to control the VOC vapors
from the loading racks per 40 CFR 63 BBBBBB. As such, the NO x emissions from the flares
controlling the Loading Racks were also not evaluated for NOx RACT purposes as they already
meet RACT and were installed to meet BACT and NSPS XX and NESHAP BBBBBB
requirements.Table 7-1 summarizes the RACT determinations for each emission unit/source.
Table 7-1 Summary of RACT Determinations for Each Source
Source RACT Determination
Diesel-Fired
Emergency CI ICE
Good operational practices according to the manufacturer’s recommendations
and design, proper maintenance and operation, and compliance with applicable
NESHAP ZZZZ requirements.
Loading Racks Use of the existing VCS and flares, compliance with the work practice standards
of NSPS XX and NESHAP BBBBBB, including loading to certified vapor-tight
cargo tank trunks, and use of the VCS and flares to attain emission rates for
NOx and VOC (4.0 mg NOx/liter and 10.0 mg TOC/liter gasoline loaded
respectively).
VFRT Good design methods and operating procedures and keeping records of the
type and maximum true vapor pressure of stored liquid in each VFRT.
IFRT Compliance with NSPS Kb and NESHAP BBBBBB. The IFR tanks utilize
mechanical shoe seals. During tank shutdown and degassing, the NSL Terminal
lands the roofs and empties/degases the IFR tanks in a continuous operation
EFRT Continue to meet NSPS Kb control requirements and compliance with NESHAP
BBBBBB. The EFR tanks utilize primary mechanical shoe seals and continuous
rim-mounted secondary seals. During tank shutdown and degassing, the NSL
Terminal lands the roofs and empties/degases the EFR tanks in a continuous
operation.
Equipment Leaks Comply with NESHAP BBBBBB §63.11089 (LDAR - AVO).
.
Appendix A
2017 Emission Inventory
Reasonably Available Control Technology Analysis
North Salt Lake Products Terminal
Pioneer Investments Corporation – Phillips 66 Corporation
SLR Project No.: 118.01357.00013
Report Issue Date: December 14, 2023
Phillips 66 Company Products Terminal Report Year 2017
First day of current year:1/1/2017
Site: North Salt Lake Terminal, UT Number of days in current year:365
POINT NAME
ANNUAL
PROCESS
RATE
PROCESS
RATE UNITS
EMISSION
FACTOR
EMISSION
FACTOR UNITS POUNDS TONS Pollutant
BULK TERMINALS- LOADING
Loading Rack 373,197 1000 gallons 0.0543 lbs/1000 gallons 20,251 10.1257 VOC
373,197 1000 gallons 0.0145 lbs/1000 gallons 5,403 2.7016 NOx
373,197 1000 gallons 0.0287 lbs/1000 gallons 10,696 5.3482 CO
373,197 1000 gallons 0.0002 lbs/1000 gallons 58 0.0290 SOx
373,197 1000 gallons 0.0000 lbs/1000 gallons 1 0.0006 PM
373,197 1000 gallons 16.2669 lbs/1000 gallons 6,070,778 3,035.3891 CO2
373,197 1000 gallons 0.0007 lbs/1000 gallons 258 0.1288 CH4
373,197 1000 gallons 0.0001 lbs/1000 gallons 51 0.0257 N2O
373,197 1000 gallons 16.3252 lbs/1000 gallons 6,092,528 3,046.2642 CO2e
Loading Not Captured (if controlled)373,197 1000 gallons 0.0685 lbs/1000 gallons 25,573.87 12.7869 VOC
VCU,Pilot Gas Emissions 373,197 1000 gallons 0.0000 lbs/1000 gallons 3 0.0017 VOC
Fugitive Components 373,197 1000 gallons 0.0019 lbs/1000 gallons 727.22 0.3636 VOC
Miscellaneous Emissions 373,197 1000 gallons 0.0061 lbs/1000 gallons 2,265.17 1.1326 VOC
Tank 201 59,132 1000 gallons 0.0229 lbs/1000 gallons 1,351.33 0.6757 VOC
Tank 202 2,209 1000 gallons 0.0959 lbs/1000 gallons 211.82 0.1059 VOC
Tank 203 0 1000 gallons 0.0000 lbs/1000 gallons 0.00 0.0000 VOC
Tank 204 2,312 1000 gallons 0.0048 lbs/1000 gallons 11.10 0.0056 VOC
Tank 205 77,464 1000 gallons 0.0145 lbs/1000 gallons 1,122.82 0.5614 VOC
Tank 206 1,749 1000 gallons 0.1204 lbs/1000 gallons 210.63 0.1053 VOC
Tank 211 83,043 1000 gallons 0.0918 lbs/1000 gallons 7,622.22 3.8111 VOC
Tank 212 24,422 1000 gallons 0.0274 lbs/1000 gallons 669.11 0.3346 VOC
Tank 214 17,365 1000 gallons 0.2554 lbs/1000 gallons 4,434.36 2.2172 VOC
Tank 215 40,955 1000 gallons 0.0227 lbs/1000 gallons 929.55 0.4648 VOC
Tank 216 2,718 1000 gallons 0.0832 lbs/1000 gallons 226.09 0.1130 VOC
Tank 221 83,297 1000 gallons 0.0825 lbs/1000 gallons 6,869.67 3.4348 VOC
Tank 224 5,769 1000 gallons 2.2562 lbs/1000 gallons 13,016.87 6.5084 VOC
Tank 225 54,412 1000 gallons 0.1309 lbs/1000 gallons 7,121.32 3.5607 VOC
Tank 226 0 1000 gallons 0.0000 lbs/1000 gallons 1,244.42 0.6222 VOC
Tank 227 140,311 1000 gallons 0.0227 lbs/1000 gallons 3,179.39 1.5897 VOC
Tank 228 80,847 1000 gallons 0.1847 lbs/1000 gallons 14,930.46 7.4652 VOC
55.99 tpy VOC
2.70 tpy NOx
5.35 tpy CO
0.000 tpy SO2
0.001 tpy PM
3,035.39 tpy CO2
0.13 tpy CH4
0.03 tpy N2O
3,046.26 tpy CO2e
Site Wide Emissions Totals, TPY
State of Utah
SPENCERJ. COX
Govemor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DTVISION OF AIR QUALITY
Bryce C. Bird
Director
DAQPf42-23
Ill4:ay 31,2023
Morgan Bosch
Pioneer lnvestments Corporation - Phillips 66 Corporation
245 East 1100 North
North Salt Lake, utah 84054
morgan.n.bosch@p66. com
Dear Morgan.Bosch:
RE: Serious Ozone Nonattainment Area Designation - Potential tmpact to Pioneer Inveftments
Corporation - Phillips 66 Corporation
The Division of Air Quality (DAQ) has identified your facility as having the potentiat to U.[orn. u
major stationary source located in the Ozone Nonattainment Area (NAA) in the Wasatch Fr]ont.
DAQ anticipates that the Environmental Protection Agency (EPA) will redesignate the Northern
Wasatch Front ozone NAA to serious classification in February of 2025. A serious nonattaifrment
classification will trigger requirements for major stationary sources and new thresholds for tnajor
stationary sources that will potentially apply to your facility.
This letter provides a background of the requirements for ozone nonattainment areas, a sumpary
of the requirements that will apply to major stationary sources in or impacting these areas, dnd
upcoming next steps. Action will be required from Pioneer Investments Corporation -
fLiUips OO Co.poration, as detailed in the "Next Steps and RACT Requirements" sectfon of
this letter.
Background
On August 3,2018,EPA designated the Northern Wasatch Front as marginal nonattainmenf for
the 2015 eight-hour ozone standard. The Northern Wasatch Front NAA includes all or part gf Salt
Lake, Davis, Weber, and Tooele counties.
195 North 1950 West . Salt take City, Lrf
Mailing Address: P.O. Box 144820 . Salt lake City, UT 84114-4820
Telephone [phone] . Fax [phone]. T.D.D. [phone]
w.deq.utah.gov
Printed on l00o/o recycled paper
DAQP-042-23
Page2
The Northern Wasatch Front was required to attain the ozone standard by August 3,2021, for
marginal classification. However, the Northern Wasatch Front NAA did not attain the ozone
standard by the attainment date and was reclassified to moderate status on November 1,2022.The
Northern Wasatch Front NAA is required to attain the ozone standard by August 3,2024,for
moderate classification based on data fuom2021,2022, and2023. Recent monitoring data
indicates the Northem Wasatch Front NAA will not attain the standard and will be reclassified to
serious status in February of 2025.
This anticipated reclassification from moderate to serious status will trigger new control strategy
requirements for major sources in the Northern Wasatch Front NAA. Specifically, the Ozone
Implementation Rule in 83 FR 62998 requires the State Implementation Plan (SIP) to include
Reasonably Available Control Technologies (RACT) for all major stationary sources in
nonattainment areas classified as moderate or higher. The requirements for RACT in a serious
ozone nonattainment area are found in Clean Air Act (CAA) Section 182(c). A major stationary
source in a serious ozone nonattainment area is defined as any stationary source that emits or has
the potential to emit 50 tons per year or more of nitrogen oxides lNOr) or volatile organic
compounds (VOCs).
The exact dates for the submittal of SIP RACT and RACT implementation will be announced
when EPA publishes the notice of reclassification in the federal register. However, based on the
general timeline provided in the Ozone Implementation Rule, DAQ anticipates the following
schedule:
1) Reclassification to serious February of 2025.
2) Serious SIP is due to EPA January l,2026,within 12 months from the effective date of
reclassification.
3) RACT measures will be required to be implemented as expeditiously as practicable but
likelybefore May of 2026.
Nert Steps and RACT Requirements
DAQ has identified your facility as having the potential to emit 50 tons per year or more of NO*
and/or VOCs. After the Northern Wasatch Front NAA is reclassified to serious status in February
of 2025, your facility will be considered a major stationary source. As a major stationary source,
you will be required to submit a RACT analysis for the emission unit(s) at your facility, as well as
apply for a Title V permit within 12 months ofbecoming a Title V source.
To meet the RACT requirements of the Ozone Implementation Ru1e, DAQ is soliciting RA.CT
analyses for the control of NO* and VOC emissions from all major stationary sources or potential
major stationary sources located in or impacting the Northern Wasatch Front NAA. DAQ will
review the RACT analyses submitted and make a RACT determination for each affected emission
unit.
DAQP-042-23
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The requirements for RACT in CAA Section 182(c) and (f) are specific to major stationary
sources of VOCs and NO* in a nonattainment area. Major stationary sources located outside a
nonattainment area but impacting the nonattainment area are required to submit a RACT analysis
under the provisions of CAA 172(c)(6\ Other Measures. This provision states that other measures
may be implemented if attainment cannot be demonstrated by the applicable attainment date with
the controls implemented within the nonattainment area. DAQ is soliciting RACT analyses from
sources with the potential to impact the Wasatch Front NAA; however, RACT will only be
required for these sources ifnecessary.
DAQ has identified your facility as having the potential to become a major stationary source
located in or impacting the Northem Wasatch Front NAA. Due to the location and potential to
emit from your facility, DAQ is requesting either:
1) a RACT analysis for the emission units at your facility; or
2) a Notice of Intent (NOI) application to lower the potential to emit from your fac{lity to
below 50 tons per year of NO* and VOCs.
If choosing to lower the potential to emit from your facility, please submit a NOI application
to DAQ by July 31,2023. Otherwise, please submit a RACT analysis to DAQ by January 2,
2024. The RACT submittal requirements are listed in the attachment to this letter. NOI
applications and RACT analyses shall be submitted to Ana Williams at
an arv illiams (ri u tah. gov.
Inventorv and Modeling Data
The SIP process requires that DAQ perform a modeling demonstration to evaluate attainment. As
part of this evaluation, DAQ will model baseline emissions based on the 2017 emissions inyentory
and projected emissions for future years.
DAQ anticipates preparing the modeling emissions inventory for point sources in early 2024.This
emission inventory data will incorporate RACT to existing equipment and any anticipated changes
to the facility. DAQ will work with major stationary sources to prepare the emission inventgry
data for each affected facility that will be included in the model.
DAQ will contact major sources in late 2023 to develop emissions inventory data. No action is
required at this time.
DAQP-042-23
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Additional Information
Additional information regarding major source requirements and timelines can be found here:
sip-development
You can also sign up for the ozone SIP email list on the website above.
Informational Meeting
DAQ invites you to attend an informational meeting June 13, 2023, from 1:00pm-2:00pm. The
meeting will be held at the DAQ ofEces in the Multi-Agency State Office Building first floor
Boardroom 1015 with an option to attend virtually. You will receive an email with a meeting
invitation in the coming weeks.
At this meeting DAQ staffwill provide information regarding regulatory timelines and the actions
DAQ will be obligated to take to meet the new requirements for a serious classification.
We will provide an opportunity during the meeting for you to ask questions. You may also submit
written questions to DAQ after the meeting.
Please contact Ana Williams at [phone] with any questions.
Sincerely,
4*clil
Bryce C. Bird
Director
BCB:AW:my
DAQP-042-23
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ATTACHMENT - RACT Submittal Requirements
The RACT proposals to be submitted to DAQ must include the following:
1) A list of each NO* and VOCs emission unit at the facility. All emission units with a
potential to emit either NO* or VOCs must be evaluated.
2) Aphysical description of each emission unit and its operating characteristics, including but
not limited to: the size or capacity of each affected emission unit; types of fuel combusted;
the types and quantities of materials processed or produced in each affected emissioh unit.
3) Estimates of the potential and actual NO* and VOC emissions from each affected source,
and associated supporting documentation.
4) The actual proposed alternative NO* RACT requirement(s) or NO* RACT emissionq
limitation(s), and/or the actual proposed VOC requirement(s) or VOC RACT emissions
limitation(s) (as applicable).
5) Supporting documentation for the technical and economic considerations for each affected
emission unit.
6) A schedule for completing implementation of the RACT requirement or RACT emissions
limitation by May of 2026, including start and completion of project and schedule for
initial compliance testing.
7) Proposed testing, monitoring, recordkeeping, and reporting procedures to demonstrate
compliance with the proposed RACT requirement(s) and/or limitation(s).
8) Additional information requested by DAQ necessary for the evaluation of the RACT
analyses.
RACT analyses due to DAQ bv Januarv 2.2024.