Appendix A - Washington State Department of Ecology

Alcoa has not requested an enforceable limitation on the lifetime of the Alcoa Wenatchee Works.
Ecology assumes that it will continue to operate into the future.
• Summary
Based on the above, it is Ecology’s opinion that there is currently no reasonable control
technology to reduce SO2 emissions from the Wenatchee Works facility.
2. Petroleum Industry Process Heaters
Process heaters are similar to hot water heaters, but they heat petroleum, not water. In
Washington, most process heaters are found at the 5 petroleum refineries, principally the 4
largest refineries 4 located in Skagit and Whatcom counties. Process heaters heat the crude
petroleum oil and intermediate distillation products to produce specific products such as
gasoline, aviation fuels, on- and off-road specification diesel fuel, some home heating oil, marine
diesel, ship bunker (residual) fuel oil, petroleum coke, and other gaseous and liquid fuels derived
from petroleum.
The process heaters at the refineries primarily use refinery waste gas as fuel. The refinery gas
may be supplemented by natural gas or an alternative back-up fuel may be utilized at specific
heaters when refinery gas supply is inadequate to operate all heaters and boilers at a refinery.
The age of process heaters at the refineries range from original equipment installed between 38
and 55 years ago to less than 5 years old. Three of the 5 refineries in Washington date from the
mid 1950s 5 . The fourth refinery 6 dates from about 1972. The fifth and smallest refinery 7 has
been completely rebuilt with new heaters over the course of the last 20 years. Over the course of
the last 10 years, all of the refineries have been subject to emission reduction requirements.
Three of the 4 large refineries have been required to implement emission reduction projects as
the result of Environmental Protection Agency (EPA) led national enforcement actions against
the parent companies. All of the refineries have had to comply with hydrocarbon emission
reductions, SO2 reductions, particulate reductions, and Hazardous Air Pollutant (HAP)
reductions as the result of federal New Source Performance Standards (NSPS) or National
Emission Standards for Hazardous Air Pollutants (NESHAP)/Maximum Available Control
Technology (MACT) regulations.
• Available emission controls
SO2 controls on process heaters are primarily limited to reduction in the sulfur content of the
refinery gas or fuel oil used as fuel. All 5 refineries meet the refinery gas sulfur content
requirements in the NSPS for refineries and thereby minimize SO2 emissions from refinery gas.
Installation of new or additional refinery gas sulfur reduction systems involve the installation or
4
BP Cherry Point Refinery, Conoco-Phillips, Tesoro, and Shell (Puget Sound Refining)
5
Shell, Tesoro, and Conoco Phillips
6
BP Cherry Point
7
US Oil in Tacoma
F-13
Final December 2010