TECHNICAL SUPPORT DOCUMENTThe maximum processing capacity of the facility will be 4,200 BPD UMO. The facility is designed to produce primarily a Marine Fuel Oil (MFO) product, a High

DRAFT PERMIT # 85587

Page 1 of 17

DRAFT TECHNICAL SUPPORT DOCUMENT

TECHNICAL REVIEW AND EVALUATION

OF APPLICATION FOR

AIR QUALITY PERMIT No. 85587

I. INTRODUCTION

This Class II new permit is for the construction and operation of Arizona Fuel Operations I LLC’s

Arizona Fuel Operation facility.

A. Company Information

Facility Name: Arizona Fuel Operation

Mailing Address: 19991 N. 97th Place, Scottsdale, AZ 85255

Facility Location: 10387 S. Ave. 4E, Yuma, AZ 85365

B. Attainment Classification

This facility is located in Yuma PM10 Nonattainment Area and right on the boundary of

Yuma ozone nonattainment Area.

II. PROCESS DESCRIPTION

A. Process Description

Arizona Fuel Operations I LLC is proposing to construct and operate a Used Motor Oil

(UMO) re-refining facility located at 10387 South Avenue 4E, Yuma, Arizona. The base

elevation of the site is 215 feet above sea level.

The maximum processing capacity of the facility will be 4,200 BPD UMO. The facility is

designed to produce primarily a Marine Fuel Oil (MFO) product, a High Sulfur Fuel Oil

(HSFO) product, a treated stabilized naphtha, and a treated fuel gas. The annual maximum

production rate of the product is listed in Table 1:

Table 1: Annual Maximum Capacity of the Product

Product MFO

(gallons/year)

HSFO

(gallons/year)

Naphtha Product

(gallons/year)

Annual

Maximum

Production 52,000,615 1,533,269 8,542,694

The UMO will arrive at the facility by rail and tanker truck. Rail deliveries will unload into

one of the two UMO tanks. Tanker truck deliveries will unload into one of the eight guard

tanks. The guard tanks will pipe the UMO into one of two 1,137,103 gallon above ground

storage tanks (ASTs). UMO from the ASTs is then sent to a feed flash drum and loaded into the Visbreaker heater and Soaker Reactor to crack the hydrocarbons in the UMO. After

the Visbreaker, the hydrocarbons are sent to a fractionator where they are separated into


Page 2 of 17

December 3, 2020

products, process gas, and wastewater. The naphtha and process gas are treated with a

caustic (sodium hydroxide) solution to remove the hydrogen sulfide and light mercaptans.

Wastewater from this process is considered Sour Water. The wastewater will be sent to an

above ground storage tank and then shipped off-site for disposal.

Supporting equipment and activities for this process include a steam boiler, rail and truck

unloading operations, rail and truck product loading, storage tanks, a vapor combustion

unit, a cooling water tower, and an emergency flare.

B. Control Devices

To minimize emissions, two air pollution control devices are proposed for the project: a

vapor combustion unit (VCU) and an elevated flare.

1. Vapor Combustion Unit (VCU)

The VCU will be an enclosed John Zinc (or equivalent) unit. Based on information

provided by the vendor, 60 standard cubic feet per hour (SCFH) of natural gas will

be required for the pilot and an additional 4,800 SCFH natural gas will be required

to assist with combustion of the VOCs. The emissions from UMO transfer, MFO

transfer, HSFO transfer, Naphtha transfer, wastewater transfer, MFO above

ground storage tanks, HSFO above ground storage tanks, and wastewater tanks,

will exhaust to the VCU to eliminate the emissions into the ambient atmosphere.

The maximum estimated heat release is 12.5 MMBtu/hour. The destruction

efficiency for the VCU is 99 percent.

2. Flare

The flare will be used to control emissions from the pressure relief devices, to burn

off process gas during start-up or upset conditions where there may be excess

process gas, and for emergency release of pressure relief valves during upset

conditions. The Visbreaker is being designed to produce the required process gas

to run the heater. Under normal operations, no excess process gas is expected. At

worst case conditions, the flow rate of process gas to the flare is 19,121 SCFH.

The maximum gas loading into the flare at maximum conditions (pressure relief

valves during upset) is expected to be 78,451 pounds. This gas will be comprised

of heavy hydrocarbons with a molecular weight of 223.5. Flare operation will be

limited to a maximum of 300 hours per year for process gas flaring. The pressure

relief valves will exhaust to the flare 8,760 hours under normal operations. The

flare will have a 98 percent destruction efficiency.

C. Process Flow Diagram

A process flow diagram for this facility is attached as Appendix A.

III. LEARNING SITE EVALUATION

In accordance with ADEQ’s Environmental Permits and Approvals near Learning Sites Policy, the

Department is required to conduct an evaluation to determine if any nearby learning sites would be

adversely impacted by the facility. Learning sites consist of all existing public schools, charter


Page 3 of 17

December 3, 2020

schools and private schools the K-12 level, and all planned sites for schools approved by the

Arizona School Facilities Board. The learning sites policy was established to ensure that the

protection of children at learning sites is considered before a permit approval is issued by ADEQ.

The nearest school is located approximately 1.8 miles west of this facility. A refined modeling

analysis was conducted and it was determined that the school would not be adversely impacted by

this facility. A detailed discussion of the screen modeling analysis can be found in Section IX

below.

IV. EMISSIONS

The potential-to-emit (PTE) is calculated based on EPA AP-42, Vendor guarantee documentation,

40 CFR 98 Subpart C, and design parameters from this facility. The facility has a PTE more than

the permitting exemption threshold for VOCs. The facility’s PTE is provided in Table 2 below:

Table 2: Potential to Emit (tpy)

Pollutant

Capacity to

Emit without

Control

Capacity to

Emit with

Control (VCU

and Flare)

Permitting

Exemption

Threshold

Significant

Level

Minor NSR

Triggered?

PM2.5 2.2 2.2 5 10 No

PM10 2.2 2.2 7.5 15 No

SO2 5.2 5.2 20 40 No

NOx 12.9 12.9 20 40 No

CO 18.4 18.4 50 100 No

VOC 33.9 3.8 20 40 Yes

HAPs 1.3 0.5 -- -- N/A

V. MINOR NEW SOURCE REVIEW (NSR)

Minor new source review is required if the emissions of a new source have the potential to emit

any regulated air pollutant at an amount greater than or equal to the permitting exemption threshold

(PET) in Table 1 above. The potential to emit for VOC is greater than the permitting exemption

threshold of 20 tons per year. Thus, the facility is subject to minor NSR requirements.

The facility elected to undergo screen modeling to demonstrate compliance with minor NSR

Requirements. A detailed discussion of the screen modeling analysis can be found in Section IX

below.

VI. APPLICABLE AND NON-APPLICABLE REGULATIONS

A. Table 3 identifies applicable regulations and verification as to why that standard applies.


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December 3, 2020

Table 3: Applicable Regulations

Unit & year Control

Device

Rule Discussion

Steam Boiler N/A 40 CFR 60 Subpart Dc:

Standards Of Performance For

Small Industrial-Commercial-

Institutional Steam Generating

Units

The natural gas boiler

capacity is greater than 10

MMBtu/hr and less than 100

MMBtu/hr and is subject to

Subpart Dc.

Emergency Diesel Fire

Pump

N/A 40 CFR 60 Subpart IIII:

Standards Of Performance For

Stationary Compression

Ignition Internal Combustion

Engines

The emergency diesel fire

pump is subject to Subpart

IIII.

Visbreaker Heater Flare A.A.C. R18-2-724: Standards

of Performance for Fossil-fuel

Fired

Industrial and Commercial

Equipment

The Visbreaker Heater is

subject to A.A.C. R18-2-

724.

Cooling Tower N/A A.A.C. R18-2-730: Standards

of Performance for

Unclassified

Sources

The Cooling Tower is

subject to Unclassified

Sources A.A.C. R18-2-730.

Petroleum Liquid

Storage Tanks

VCU A.A.C. R18-2-710: Standards

of Performance for Existing

Storage

Vessels for Petroleum Liquids

Petroleum Liquid Storage

Tanks are subject to A.A.C.

R18-2-710.

Vapor Combustion

Unit and Emergency

Flare

-- A.A.C. R18-2-730: Standards

of Performance for

Unclassified

Sources

The Vapor Combustion Unit

and Emergency Flare is

subject to Unclassified

Sources A.A.C. R18-2-730.

Fugitive dust sources Water

Trucks,

Dust

Suppressants

A.A.C. R18-2 Article 6:

Emissions From Existing And

New

Nonpoint Sources

A.A.C. R18-2-702: General

Provisions

These standards are

applicable to all fugitive

dust sources at the facility.

Abrasive Blasting Wet

blasting;

Dust

collecting

equipment;

Other

approved

methods

A.A.C. R-18-2-702: General

Provisions

A.A.C. R-18-2-726: Standards

of Performance for

Sandblasting

Operations

These standards are

applicable to any abrasive

blasting operation.


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December 3, 2020

Unit & year Control

Device

Rule Discussion

Spray Painting Enclosures A.A.C. R18-2-702: General

Provisions

A.A.C. R-18-2-727: Standards

of Performance for Spray

Painting

Operations

These standards are

applicable to any spray

painting operation.

Demolition/renovation

Operations

N/A A.A.C. R18-2-1101.A.8:

Radionuclides Other Than

Radon from

Department of Energy

Facilities

This standard is applicable

to any asbestos related

demolition or renovation

operations.

B. The regulations that were reviewed but not applicable to this facility are shown in Table 4:

Table 4: Non-applicable Regulations

Regulation Description Discussion

40 CFR 60 Subpart Kb Standards of Performance for

Volatile Organic Liquid Storage

Vessels (Including Petroleum Liquid

Storage Vessels) for Which

Construction, Reconstruction, or

Modification Commenced

After July 23, 1984

UMO (Used motor oil), MFO (Marine

fuel oil) and HSFO (High sulfur fuel oil)

storage tanks are not applicable because

their vapor pressure is lower than 3.5 kPa

(Subpart 60.110.b). The naphtha tank is

not applicable as it is a pressured tank

(Subpart 60.110.d(2)).

40 CFR 60 Subpart Ja Standards of Performance for

Petroleum Refineries for Which


Modification Commenced After May

14, 2007

Not applicable because this facility does

not process crude oil and is not a

petroleum refinery.

40 CFR 60 Subpart

VVa

Standards of Performance for

Equipment Leaks of VOC in the

Synthetic Organic Chemicals

Manufacturing Industry for Which


Modification Commenced After

November 7, 2006


not process raw materials or have

intermediate or final products chemicals

on the list in Subpart 60.489.

40 CFR 60 Subpart

QQQ

Standards of Performance for VOC

Emissions from Petroleum Refinery

Wastewater Systems



petroleum refinery.

40 CFR 60 Subpart

GGGa

Standards of Performance for

Equipment Leaks of VOC in

Petroleum Refineries for Which


Modification Commenced After November 7, 2006



petroleum refinery.

40 CFR 60 Subpart JJJJ Standards of Performance for Not applicable because this facility does


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December 3, 2020

Regulation Description Discussion

Stationary Spark Ignition Internal

Combustion Engines

not have stationary spark ignition (SI)

internal combustion engines (ICE).

40 CFR 60 Subpart

NNN

VOC Emissions from Synthetic

Organic Chemical Manufacturing

Industry (SOCMI) Distillation

Operations

Not applicable because none of the

chemicals listed in Subpart 60.667 is a

product of this facility.

40 CFR 60 Subpart

RRR

VOC Emissions from SOCMI

Reactor Processes

Not applicable because none of the

chemicals listed in Subpart 60.707 is a

product of this facility.

40 CFR 60.18 General Control Device And Work

Practice Requirements

Not applicable because the units using

control devices are not subject to NSPS.

40 CFR 63 Subpart G National Emission Standards for

Organic Hazardous Air Pollutants

From the Synthetic Organic Chemical

Manufacturing Industry for Process

Vents, Storage Vessels, Transfer

Operations, and Wastewater.


not meet the source category definition

and is not a major HAP source.

40 CFR 63 Subpart H National Emission Standards for

Organic Hazardous Air Pollutants for

Equipment Leaks

Not applicable because this facility is not

subject to any subparts referenced in

Subpart H.

40 CFR 63 Subpart Q National Emission Standards for

Hazardous Air Pollutants for

Industrial Process Cooling Towers


not use chromium based chemicals and is

not a major HAP source.

40 CFR 63 Subpart CC National Emission Standards for

Hazardous Air Pollutants From

Petroleum Refineries


a major HAP source.

40 CFR 63 Subpart

EEEE

National Emission Standards for

Hazardous Air Pollutants: Organic

Liquids Distribution (Non-Gasoline)


a major HAP source.

40 CFR 63 Subpart

DDDDD

Industrial, Commercial, and

Institutional Boilers and Process

Heaters


a major HAP source.

40 CFR 63 Subpart

JJJJJJ

National Emission Standards for

Hazardous Air Pollutants for

Industrial, Commercial, and

Institutional Boilers Area Sources

Not applicable to natural gas fired boilers

and this facility only has a natural gas

fired boiler.

40 CFR 63 Subpart R National Emission Standards For

Gasoline Distribution Facilities (Bulk

Gasoline Terminals And Pipeline

Breakout Stations)


a major HAP source.

40 CFR 63 Subpart CC National Emission Standards For

Hazardous Air Pollutants From

Petroleum Refineries



petroleum refinery.

40 CFR 63.11 Control Device And Work Practice

Requirements

Not applicable because the units using

control devices are not subject to NESHAP.


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December 3, 2020

VII. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS

Table 5 contains an inclusive but not an exhaustive list of the monitoring, recordkeeping and

reporting requirements prescribed by the air quality permit. The table below is intended to provide

insight to the public for how the Permittee is required to demonstrate compliance with the emission

limits in the permit.

Table 5: Permit No. 85587

Emission

Unit

Pollutant and

Emission Limit

Monitoring

Requirements

Recordkeeping

Requirements

Reporting

Requirements

Steam

Boiler

Burn only pipeline

quality natural gas in

the steam boiler

Record and

maintain

records of the

amount of each

fuel combusted

Record and maintain

records of the amount of

each fuel combusted

Submit the

reports to the

Director every

six months

Emergency

Diesel Fire

Pump

Displacement of < 30

liters per cylinder

(g/KW-hr):

NMHC + NOX ≤ 4.0;

CO ≤ 3.5;

PM ≤ 0.2;

Purchase an

engine certified

to the emission

standards;

install and

configure

according to the

manufacturer's

specifications;

operate and

maintain

according to the

manufacturer's

emission-related

written

instructions;

change settings

permitted by the

manufacturer;

meet the

requirements of

40 CFR parts

89, 94 and/or

1068, as they

apply.

Keep records of

performance test results;

keep records of engine

manufacturer data

indicating compliance with

the standards; keep records

of control device vendor

data indicating compliance

with the standards

Displacement of ≥ 30

liters per cylinder

(g/KW-hr):

NOX ≤ 14.4

(maximum engine

speed <130 rpm);

NOX ≤ 44·n-0.23 (130

≤ maximum engine

speed < 2000 rpm, n

is maximum engine

speed);

NOX ≤ 7.7

(maximum engine

speed ≥ 2000 rpm);

PM ≤ 0.40


Page 8 of 17

December 3, 2020

Emission

Unit

Pollutant and

Emission Limit

Monitoring

Requirements

Recordkeeping

Requirements

Reporting

Requirements

Visbreaker

Heater SO2 ≤ 1

pound/MMBtu

Conduct initial

performance

test and at least

once every

permit term,

using Method 6.

Keep records of

performance test results

Submit

performance

test results.

Cooling

Tower

PM ≤ E = 55.0 P0.11 –

40 (E = the

maximum allowable

particulate emissions

rate in pounds-mass

per hour, P = the

process weight rate

in tons-mass per

hour);

Opacity ≤ 20%;

SO2 ≤ 1 ppm;

NOX ≤ 500 ppm NO2

Conduct a

monthly EPA

Reference

Method 9

observation of

emissions.

Keep a record of the name

of the observer, date and

time of Method 9

observation the EPA

Method 9 observation, and

the results of the

observation. If the

observation results in an

exceedance of the opacity,

take corrective action and

log all such actions.

If the

observation

results in an

exceedance of

the opacity,

report as

excess

emissions.

Petroleum

Liquid

Storage

Tanks

When capacity ≥

40,000 gallons, if not

a pressure tank, or if

not equipped vapor

loss control devices,

the vapor pressure

should be ≤ 1.5

pounds per square

inch.

Equipped with a

submerged

filling device;

for dock loading

of petroleum

products, if

loading pressure

≥ 1.5 pounds

per square inch,

provide for

submerged

filling; pumps

and

compressors be

equipped with

mechanical

seals or other

equipment of

equal

efficiency.

For each storage vessel

maintain a file of each type

of petroleum liquid stored,

of the typical Reid vapor

pressure of each type of

petroleum liquid stored

and of dates of storage;

show dates on which the

storage vessel is empty;

determine and record the

average monthly storage

temperature and true vapor

pressure.

Vapor

Combustio

n Unit (VCU) and

Opacity ≤ 20%;

VCU destruction

efficiency ≥ 99%;

Flare destruction

efficiency ≥ 98%;

Conduct

monthly survey

of visible

emissions using

EPA Reference

Keep records of the

monthly visible emissions

survey; maintain, on-site,

records of the

manufacturer supplied


Page 9 of 17

December 3, 2020

Emission

Unit

Pollutant and

Emission Limit

Monitoring

Requirements

Recordkeeping

Requirements

Reporting

Requirements

Emergency

Flare

Method 9;

monitor the

Vapor

combustion

Unit and

Emergency

Flare to ensure

it is operated

and maintained

in conformance

with its design

operations and

maintenance instructions

or Operation and

Maintenance Plan for

minimizing emissions

Fugitive

Dust 40% Opacity

A Method 9

observer is

required to

conduct a

monthly survey

of visible

emissions.

Record of the dates and

types of dust control

measures employed, and if

applicable, the results of

any Method 9

observations, and any

corrective action taken to

lower the opacity of any

excess emissions.

Abrasive

Blasting 20% Opacity

Record the date, duration

and pollution control

measures of any abrasive

blasting project.

Spray

Painting

20% Opacity

Control 96% of the

overspray

Maintain records of the

date, duration, quantity of

paint used, any applicable

MSDS, and pollution

control measures of any

spray painting project.

Demolition

/

Renovation

Maintain records of all

asbestos related demolition

or renovation projects

including the “NESHAP

Notification for

Renovation and

Demolition Activities”

form and all supporting

documents


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December 3, 2020

VIII. ENVIRONMENTAL JUSTICE ANALYSIS

EPA defines Environmental Justice (EJ) to include the fair treatment and meaningful involvement

of all people regardless of race, color, national origin, or income with respect to the development,

implementation, and enforcement of environmental laws, regulations, and polices. The goal of

completing an EJ assessment in permitting is to provide an opportunity for overburdened

populations or communities to allow for meaningful participation in the permitting process.

Overburdened is used to describe the minority, low-income, tribal and indigenous populations or

communities that potentially experience disproportionate environmental harms and risks due to

exposures or cumulative impacts or greater vulnerability to environmental hazards.

EPA developed EJSCREEN, a publicly available tool that uses nationally consistent data to

produce maps and reports detailing environmental and demographic indicators that can be used to

evaluate EJ concerns. EPA selected an 80th percentile threshold for this action to evaluate the

potential for EJ concerns in a community, meaning that if the area of interest exceeds the 80th

percentile for one or more of the EJ indexes, the EPA considers that area to have a high potential

for EJ concerns. ADEQ mapped the location of Arizona Fuel Operation and reviewed a five-mile

radius around the facility for potential environmental justice concerns (see Figure 1).

Figure 1. A Five-mile Radius around Arizona Fuel Operation for Potential Environmental Justice Concerns

A. Demographics

The EJSCREEN report shows that all the Demographic Indicators, for such as Minority

Population, Low Income Population, Linguistically Isolated Population, Population With

Less Than High School Education, Population Under 5 years of age, and Population over 64 years of age, are all below the 80th percentile threshold, so the issuance of the Air Quality


Page 11 of 17

December 3, 2020

Permit for the Arizona Fuel Operation does not have a high potential for EJ concerns in the

community.

B. Air Quality

ADEQ conducted air quality dispersion modeling to determine if emissions from Arizona

Fuel Operation will contribute to a NAAQS or AAAQG exceedance. A complete review

of the air quality analysis can be found in Section IX below. Based on the modeling

analysis results, ADEQ has determined that the issuance of the Air Quality Permit for the

Arizona Fuel Operation will not interfere with attainment and maintenance of the NAAQS,

and will not have an adverse impact on the community.

C. Conclusion

ADEQ concludes that the protections afforded by A.R.S. § 49-426, which is imposed

through the permit, ensure that the public health and environment in Arizona are protected

and that the public notice and comment opportunities afforded to the community on this

new permit application satisfy the public participation component of the EPA EJ Guidance.

The dispersion modeling ADEQ conducted further concludes that Arizona Fuel Operation

demonstrates compliance with the NAAQS and the AAAQGs.

IX. AMBIENT AIR IMPACT ANALYSIS

ADEQ performed dispersion modeling to determine whether the proposed project’s emissions will

interfere with attainment and maintenance of the National Ambient Air Quality Standards

(NAAQS) or not. Although the potential to emit (PTE) for all criterial pollutants are below the

permitting exemption thresholds, ADEQ assessed PM10 and ozone impacts because the project site

is located in the Yuma PM10 Nonattainment Area and right on the boundary of Yuma ozone

Nonattainment Area. Since the proposed project is subject to the Learning Site Policy, ADEQ

performed additional dispersion modeling to estimate the hazardous air pollutants (HAPs) ambient

concentrations and compared them against Acute/Chronic Ambient Air Concentrations (AAAC

and CAAC) or the Arizona Ambient Air Quality Guidelines (AAAQG) for listed air toxics.

ADEQ performed the ambient air impact analysis following the Environmental Protection Agency

(EPA)’s Guideline on Air Quality Models (40 CFR Part 51 Appendix W) and ADEQ’s Modeling

Guidelines for Arizona Air Permits. Based on the modeling analysis results, ADEQ has determined

that the issuance of the Air Quality Permit for the Arizona Fuel Operation will not interfere with

attainment and maintenance of the NAAQS and will not have an adverse impact on the community.

A. Model Selection

The American Meteorological Society/Environmental Protection Agency Regulatory

Model (AERMOD) model is the EPA-preferred model for estimating impacts at receptors

located in simple terrain and complex terrain (within 50 km of a source) due to emissions

from industrial sources. ADEQ used AERMOD for the ambient impact analysis.

The AERMOD Modeling System consists of three major components: AERMAP, used to

process terrain data and develop elevations for receptors; AERMET, used to process the

meteorological data; and AERMOD, used to estimate the ambient pollutant concentrations.


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December 3, 2020

ADEQ used AERMAP version 19191; AERMET version 19191; and AERMOD version

19191. These are the most recent versions of the AERMOD Modeling System.

B. Emission Sources

The proposed source is a new Used Motor Oil (UMO) re-refining facility that will produce

primarily a Marine Fuel Oil (MFO) product, a High Sulfur Fuel Oil (HSFO) product, a

treated stabilized naphtha product, and a treated fuel gas. The emission sources include a

steam boiler, a Visbreaker heater, an emergency flare, a cooling water tower and a vapor

combustion unit. The potential air pollutants include particulate matters (PM), CO, NOx,

SO2, VOCs, and HAPs.

Emissions for varied air pollutants were estimated based on the maximum production rates.

For detailed emission calculations, please see the Application. ADEQ modeled all emission

sources as point sources. ADEQ obtained the stack release parameters (height, diameter,

gas temperature, and gas exit velocity) from Arizona Fuel Operation.

C. Meteorological Data

ADEQ used AERMET meteorological preprocessor to process five-years (2014-2018) of

surface meteorological data obtained from Yuma Marine Corps Air Station/Yuma

International Airport along with concurrent upper air radiosonde data obtained from

Tucson International Airport. The Yuma International Airport is located approximately

two miles away from the project site. ADEQ determined that the airport data were

representative of transport and dispersion conditions around the project site.

D. Building Downwash

ADEQ evaluated building downwash effects based on building/tanks and stack locations

and dimensions, and the EPA’s Building Profile Input Program Plume Rise Model

Enhancements (BPIP-PRME). For each tank, ADEQ created a circular building to

represent the tank structure.

E. Ambient Air Boundary and Receptor Network

ADEQ used the facility fence line as the ambient air boundary. To model PM10, ADEQ

set up a nested grid receptor network to determine areas of maximum predicted

concentrations. A denser receptor grid with 25-meter spacing was placed closer to the

sources, and a less dense grid (100 or 200-meter spacing) was further from the sources.

The receptor network covered an area of 10 kilometer by 10 kilometer. To model HAPs,

ADEQ set up a dense grid receptor network with 25-meter spacing covering the school’s

footprint. ADEQ used the AERMAP terrain processor to process the National Elevation

Data (NED) data to generate the receptor elevations and hill heights.

F. Results and Conclusions

1. PM10

Per R18-2-334(C)(2)(b) of the A.C.C., the modeling analysis should demonstrate

either of the following:


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December 3, 2020

a. The emissions from the source or minor modification will have an ambient

impact below the significant levels (SILs) as defined in R18-2-401 of the

A.C.C.;

b. The ambient concentrations resulting from the source or modification

combined with representative background concentrations of minor NSR

pollutants will not interfere with attainment or maintenance of a NAAQS.

The project site is located in the Yuma PM10 Nonattainment Area. The most recent

three years of ambient monitoring data indicate that the background concentrations

for the project site area are above the NAAQS. Therefore, Arizona Fuel Operation

must demonstrate that the emissions from the proposed project will have an

ambient impact below the SILs.

Table 6 summarizes the modeled results for PM10. As shown in Table 5, both the

modeled 24-hour average concentrations and annual average concentrations are

below their corresponding SILs. Therefore, ADEQ concludes that the emissions

from the proposed project will not interfere with attainment or maintenance of

NAAQS for PM10.

Table 6. Modeled Results for PM10

Pollutant Averaging

Period

Modeled

Concentration

(μg/m3)

SIL (μg/m3)

PM10 24‐hour 1.52 5

Annual 0.08 1

2. Ozone

ADEQ used the EPA’s Model Emissions Rates for Precursors (MERPs) tool for

the ozone impact analysis. MERPs represent emission rates of VOCs and or NOx

(precursors for ozone) that are expected to result in a change in ambient ozone that

would be less than a SIL. Based on a SIL of 1.0 parts per billion (ppb) for the 8-

hour ozone NAAQS, the EPA investigated single source impacts on ozone from

some hypothetical sources and provided most conservative illustrative MERP

values for VOCs and NOx. The most conservative illustrative MERP values for

VOCs and NOx in Southwest (Arizona, Colorado, New Mexico and Utah) are

1,097 tpy and 204 tpy, respectively.

The total emissions of VOCs and NOx from the proposed project are 17.5 tpy

(including fugitive emissions) and 12.9 tpy, respectively, which are significantly

less than the most conservative MERP values as discussed above. Therefore,

ADEQ concludes that the proposed project will not cause or contribute to a

violation of the NAAQS for ozone.

3. HAPs


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December 3, 2020

Table 7 summaries the modeled results for HAPs. ADEQ compared the modeled

maximum hourly concentrations against AAAC and compared the modeled annual

concentrations against CAAC. As shown in Table 6, the modeled concentrations

for HAPs are well below the AAAC and CAAC.

Table 7. Comparison of Modeled Concentrations versus AAC for HAPs

HAPs

1-hour

Modeled

Concentration

(µg/m3)

Acute AAC

(µg/m3)

Annual

Modeled

Concentration

(µg/m3)

Chronic

AAC (µg/m3)

1,1,2,2-

Tetrachloroethane 1.17E-07 1.80E+04 1.42E-09 3.27E-02

1,3-Butadiene 5.49E-05 7.51E+06 1.32E-06 6.32E-02

Acetaldehyde 1.08E-03 3.06E+05 2.60E-05 8.62E-01

Acrolein 1.30E-04 2.30E+02 3.13E-06 2.09E-02

Antimony 3.99E-08 1.30E+04 4.85E-10 1.46E+00

Arsenic 2.08E-05 2.50E+03 4.67E-07 4.41E-04

Benzene 1.53E-03 1.28E+06 3.65E-05 2.43E-01

Beryllium 1.25E-06 1.30E+01 2.80E-08 7.90E-04

Cadmium 1.15E-04 2.50E+02 2.57E-06 1.05E-03

Chlorobenzene 1.17E-07 1.00E+06 1.42E-09 1.04E+03

Chromium 1.46E-04 1.00E+02 3.27E-06 1.58E-04

Cobalt 8.75E-06 1.00E+04 1.96E-07 6.86E-04

Dichloromethane 6.35E-07 3.47E+05 7.72E-09 4.03E+00

Diethylene glycol 2.86E-03 2.50E+05 3.48E-05 3.14E+00

Ethylene glycol 2.50E-04 5.00E+04 3.03E-06 4.17E+02

Formaldehyde 9.47E-03 1.70E+04 2.15E-04 1.46E-01

Hexane 1.88E-01 1.16E+07 4.21E-03 2.21E+03

Manganese 3.96E-05 2.50E+03 8.88E-07 5.21E-02

Mercury 2.71E-05 1.00E+03 6.07E-07 3.13E-01

Naphthalene 8.15E-04 7.50E+04 1.20E-05 5.58E-02

Nickel 2.19E-04 5.00E+03 4.91E-06 7.90E-03

Selenium 2.50E-06 5.00E+02 5.61E-08 1.83E+01

Toluene 8.59E-03 1.92E+06 1.15E-04 5.21E+03

Xylene 8.06E-03 1.74E+06 1.03E-04 1.04E+02

For HAPs that are not listed in Acute/Chronic AAC, ADEQ compared the modeled

concentrations against the AAAQG. As shown in Table 8, the modeled

concentrations for HAPs are well below the AAAQG.


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December 3, 2020

Table 8. Comparison of Modeled Concentrations versus AAAQG for HAPs

HAPs

1-hour

Modeled

Concentration

(µg/m3)

AAAQG

1-hour

(µg/m3)

Annual

Modeled

Concentration

(µg/m3)

AAAQG

Annual

(µg/m3)

1,1,2-Trichloroethane 1.18E-07 7.50E+02 1.44E-09 8.20E-02

1,2,4-Trichlorobenzene 1.17E-07 1.20E+03 1.42E-09

3-Methylcholanthrene 1.88E-07 7.90E-01 4.21E-09 5.70E-04

Barium 4.58E-04 1.50E+01 1.03E-05

Benz(a)anthracene 1.41E-06 7.90E-01 1.91E-08 5.70E-04

Benzo(a)pyrene 2.64E-07 7.90E-01 6.37E-09 5.70E-04

Dibenzo(a,h)anthracene 1.25E-07 2.80E-09 5.70E-04

Ethylbenzene 7.66E-03 4.50E+03 9.30E-05

Vanadium 2.40E-04 1.50E+00 5.37E-06

X. LIST OF ABBREVIATIONS

AAAC ......................................................................................... Acute Ambient Air Concentrations

AAAQG ............................................................................ Arizona Ambient Air Quality Guidelines

AAB ............................................................................................................... Ambient Air Boundary

A.A.C. ..................................................................................................Arizona Administrative Code

ADEQ ...................................................................... Arizona Department of Environmental Quality

AERMAP ........................................................................... Terrain data preprocessor for AERMOD

AERMET ........................................................................... AERMOD Meteorological Preprocessor

AERMOD ........................................................................................... AMS/EPA Regulatory Model

AMS .............................................................................................. American Meteorological Society

A.R.S. ........................................................................................................ Arizona Revised Statutes

BPIP ................................................................................................. Building Profile Input Program

BPD .......................................................................................................................... Barrels per day

CAAC ..................................................................................... Chronic Ambient Air Concentrations

CFR ....................................................................................................... Code of Federal Regulations

CO .......................................................................................................................... Carbon Monoxide

EPA ............................................................................................. Environmental Protection Agency

g ................................................................................................................................................. Gram

HAP ............................................................................................................. Hazardous Air Pollutant

HSFO ................................................................................................................. High Sulfur Fuel Oil

hr ................................................................................................................................................. Hour

IC ....................................................................................................................... Internal Combustion

kW ........................................................................................................................................ Kilowatt

MERP ....................................................................................Model Emissions Rates for Precursors

MFO .......................................................................................................................... Marine Fuel Oil

MMBtu/hour ........................................................................ Million British Thermal Units per hour

NAAQS ...............................................................................National Ambient Air Quality Standard

NED ........................................................................................................ National Elevation Dataset

NOX ......................................................................................................................... Nitrogen Oxides

NO2 ......................................................................................................................... Nitrogen Dioxide

NSPS ......................................................................................... New Source Performance Standards


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December 3, 2020

O3 ............................................................................................................................................ Ozone

PM ......................................................................................................................... Particulate Matter

PM10 .......................................... Particulate Matter less than 10 μm nominal aerodynamic diameter

PM2.5 ........................................ Particulate Matter less than 2.5 μm nominal aerodynamic diameter

PRIME ......................................................................................... Plume Rise Model Enhancements

PTE .......................................................................................................................... Potential to Emit

SIL .............................................................................................................. Significant Impact Level

SO2 .............................................................................................................................. Sulfur Dioxide

TPY .............................................................................................................................. Tons per Year

UMO ..........................................................................................................................Used Motor Oil

VOC ...................................................................................................... Volatile Organic Compound

yr ................................................................................................................................................. Year


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December 3, 2020

Appendix A. Process Flow Diagram

Documents

TECHNICAL SUPPORT DOCUMENTThe maximum processing capacity of the facility will be 4,200 BPD UMO. The facility is designed to produce primarily a Marine Fuel Oil (MFO) product, a High