ENV-14-50 Establishing a Site-Specific NOX Emission Limit under NSPS Ja: A Case Study

Description:

On May 14, 2007, U.S. EPA proposed New Source Performance Standard (NSPS) Subpart Ja which is applicable to certain petroleum refinery sources constructed, reconstructed or modified after that date. U.S. EPA promulgated the final rule on June 24, 2008; but, due to a number of concerns with the final rulemaking, granted reconsideration of several elements of the final rule. Amendments were proposed on December 22, 2008 and the rule was revised September 12, 2012. Among the issues that arose under NSPS Ja development was the establishment of NOX emission limits for process heaters. This paper will briefly summarize the history of process heater NOX limits under the NSPS Ja rulemaking and the unique issues associated with meeting NOX limits for these sources (e.g., heater turndown, limit averaging period, forced vs. natural draft combustion). This paper will provide a summary of the final NSPS Ja NOX limits applicable to process heaters and the various challenges associated with meeting these requirements, particularly for older existing heaters that trigger these requirements through reconstruction or modification.