STATE OF MICHIGAN Rick Snyder, Governor

DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION CONSTITUTION HALL ● 525 WEST ALLEGAN STREET ● P.O. BOX 30260 ● LANSING, MICHIGAN 48909-7760

www.michigan.gov/air

PUBLIC PARTICIPATION DOCUMENTS For

Marathon Petroleum Company LP Detroit, Michigan

PERMIT APPLICATION NUMBER

63-08D

December 4, 2013

Marathon Petroleum Company LP Page 1 Permit No. 63-08D December 4, 2013

FACT SHEET December 4, 2013

Purpose and Summary The Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD), is proposing to act on Permit to Install (PTI) application No. 63-08D from Marathon Petroleum Company LP (Marathon). The permit application is for proposed modifications to and operation of the Detroit Heavy Oil Upgrade Project (DHOUP) at the Detroit Refinery. The proposed project is subject to permitting requirements of the Department’s Rules for Air Pollution Control and the federal New Source Performance Standards (NSPS). The proposed project is not subject to state and federal Prevention of Significant Deterioration (PSD) regulations or non-attainment review because the emission increases do not exceed the regulatory significance thresholds. Additionally, the AQD is proposing entry of a consent order with Marathon to resolve the noncompliant operation of the Detroit Refinery. The review of stack test reports for several process units revealed that Marathon exceeded its permit limits for particulate matter (PM) and carbon monoxide (CO) from the Fluidized Catalytic Cracking Unit (FCCU) Charge Heater and two Sulfur Recovery Thermal Oxidizer Units as well as the CO emission limit for the B&W Boiler. In addition, Marathon exceeded its annual heat input permit limit for the Distillate Hydrotreater Heater and daily and annual heat input permit limit for the Sulfur Block 2 thermal oxidizer. Prior to acting on this application, the AQD is holding a public comment period and a public hearing to allow all interested parties the opportunity to comment on the proposed PTI and consent order. All relevant information received during the comment period and hearing will be considered by the decision maker prior to taking final action on the application. Background Information Marathon operates a refinery at 1300 South Fort Street, along with nearby storage and transfer operations located at 301 Fort Street and 12700 Toronto Street, Detroit. The facilities are sited between Interstate Highway I-75, Fort Street, Oakwood Avenue and Dix Avenue and the Rouge River. The nearest residential area is approximately 100 feet west of Stocker Avenue near the Rouge River Terminal. Two operating entities divide control of the refinery and the nearby operations, but the facility is considered one stationary source for air quality purposes. The refinery processes approximately 140,000 barrels per day of crude oil which is refined into a product mix of liquefied petroleum gases, gasoline, fuel oil, asphalt, and other products. The makeup of this production will vary depending on the type of crude used as charge stocks. The finished products leave the facility via truck, lake tanker, railroad car, or pipeline. The refinery operates 24 hours per day, 7 days per week, and 52 weeks per year.

Marathon Petroleum Company LP Page 2 Permit No. 63-08D December 4, 2013 Significant Dates The following information provides a summary of permitting and enforcement activity that has occurred at the Detroit Refinery related to the DHOUP project since the public hearing for PTI No. 63-08C that was held on December 7, 2011. June 20, 2008 The AQD approved PTI No. 63-08 for the DHOUP. On that date, Marathon

commenced construction of the DHOUP. January 11, 2012 After a public comment period and public hearing, the AQD approved PTI

No. 63-08C for minor changes to the scope of the DHOUP. February 9, 2012 Marathon submitted PTI application No. 18-12 for a temporary boiler to be

used in the event one of the refinery’s permanent boilers needs to be shut down. The AQD approved PTI No. 18-12 on March 22, 2012.

June 1, 2012 Marathon submitted PTI application No. 81-12 to incorporate the

requirements of a United States Environmental Protection Agency (USEPA) Consent Decree affecting the fluidized catalytic cracking unit, the sulfur recovery plant, and the existing refinery flares into a permit. As a result of this consent decree, there were no emission increases at the facility. The AQD approved PTI No. 81-12 on September 7, 2012.

July 2, 2012 Marathon submitted PTI application No. 63-04B for the Light Products

Terminal located adjacent to the refinery to remove the daily gasoline throughput limit. This change did not increase hourly emissions or annual emissions from the terminal and all applicable regulations are still met without the daily throughput limit. The AQD approved PTI No. 63-04B on August 7, 2012.

September 5, 2012 Marathon submitted PTI application No. 63-04C for the Light Products

Terminal to change the required stack height of the backup loading rack control device. This change did not increase emissions from the terminal and all applicable regulations are still met with the changed stack height. The AQD approved PTI No. 63-04C on November 9, 2012

October 19, 2012 The AQD approved PTI 18-12A to allow Marathon to install the previously

permitted temporary boiler at a different location than originally proposed. November, 2012 Marathon commenced operation of the DHOUP by starting up the new

delayed coking unit. November 28 - December 2, 2012 Marathon conducted stack testing on the Complex 2 Sulfur Recovery Unit

Incinerator stack for PM, particulate matter less than 10 microns (PM10), Sulfuric Acid Mist, Sulfur Dioxide (SO2), Nitrogen Oxides, (NOx), CO, and Volatile Organic Compounds (VOC).

December 14 -17, 2012 Marathon conducted stack testing on the Complex 6 Sulfur Recovery Unit

Incinerator stack for PM, PM10, Sulfuric Acid Mist, SO2, NOx, CO, and VOC.

Marathon Petroleum Company LP Page 3 Permit No. 63-08D December 4, 2013 December 19-20, 2012 Marathon conducted stack testing on the FCCU charge heater for PM,

PM10, Sulfuric Acid Mist, SO2, CO, and VOC. February 14, 2013 The AQD received stack test results from Marathon’s testing of the Complex

2 Sulfur Recovery Unit Incinerator stack. February 25, 2013 Marathon conducted stack testing on the Complex 2 Sulfur Recovery Unit

Incinerator stack for CO. February 25, 2013 The AQD received stack test results from Marathon’s testing of the Complex

6 Sulfur Recovery Unit Incinerator stack. March 12, 2013 The AQD sent a Violation Notice to Marathon for violation of the CO

emission limit for both Complex 2 and Complex 6 Sulfur Recovery Unit Incinerators.

March 26, 2013 The AQD received stack test results from Marathon’s testing of the FCCU

charge heater. March 26-27, 2013 Marathon conducted stack testing on the Complex 6 Sulfur Recovery Unit

Incinerator stack for CO. March 28, 2013 Marathon submitted PTI application No. 54-13 to allow Marathon to install a

pentane/butane rail car loading operation in the Melvindale Tank Farm, which is part of the same stationary source as the refinery. This operation results in an additional 1 ton per year of VOC emissions. This emission increase is not “contemporaneous” with the DHOUP as the increase occurred after the DHOUP commenced operation. The AQD determined that the pentane/butane rail car loading operation meets all applicable regulations. The AQD approved PTI No. 54-13 on August 29, 2013.

April 23, 2013 The AQD received stack test results for CO from Marathon’s retesting of the

Complex 6 and Complex 2 Sulfur Recovery Unit Incinerator stack. April 26, 2013 The AQD sent a Violation Notice to Marathon for violation of the PM

emission limit for the FCCU charge heater. May 17, 2013 The AQD sent an Enforcement Notice to Marathon. May 30, 2013 The AQD staff met with representatives from Marathon to begin

enforcement negotiations. June 12, 2013 Marathon submitted PTI application No. 85-13 to incorporate the

requirements of a USEPA Consent Decree for all of the flares at the refinery into a permit. As a result of this consent decree, there were no emission increases at the facility. The AQD approved PTI No. 85-13 on September 11, 2013.

July 19, 2013 Marathon submitted PTI application No. 63-08D.

Marathon Petroleum Company LP Page 4 Permit No. 63-08D December 4, 2013 July 24, 2013 The AQD approved PTI 18-12B to allow Marathon to have a rain cap on the

previously permitted temporary boiler’s stack. Use of this temporary boiler does not increase air pollutant emissions from the facility because it is only allowed to operate when one of the permanent boilers is not operating.

November 5, 2013 Marathon submitted PTI application No. 157-13 to allow Marathon to install

a membrane biological reactor activated sludge process as an addition to the wastewater pre-treatment system. This process would result in less than 1 ton per year of VOC emissions. This emission increase is not “contemporaneous” with the DHOUP as the increase will occur after the DHOUP commenced operation. The AQD anticipates final action will be taken on PTI No. 157-13 within the next few months.

November 13, 2013 The AQD sent a Violation Notice to Marathon for exceeding the daily and

annual heat input limits for the Sulfur Block 2 thermal oxidizer, the annual heat input limit for the Distillate Hydrotreater Heater, and the CO emission limit for the B&W Boiler.

November 13, 2013 Marathon agreed to the terms and conditions of the proposed Consent

Order to resolve outstanding state and federal air quality violations. Compliance Issues Marathon exceeded the permit limits for PM and CO during recent test events for the FCCU Charge Heater and two Sulfur Recovery Thermal Oxidizer Units, the CO emission limit for the B&W Boiler, the daily and annual heat input limits for the Sulfur Block 2 thermal oxidizer, and the annual heat input limit for the Distillate Hydrotreater Heater. Proposed Facility and Present Air Quality The facility, in general: The Marathon refinery receives crude oil and produces a variety of oil-based products, including transportation fuels, asphalt, petroleum coke, and commodity chemicals. Marathon’s Rouge Asphalt Terminal includes storage tanks for asphalt cement, storage tanks for asphalt polymer mix, equipment to load barges and trucks, and natural gas-fired asphalt heaters. Marathon’s Melvindale Tank Farm includes storage tanks for asphalt cement, a railcar loading facility that is able to transfer asphalt cement to six railcars at once, and a pentane/butane rail car loading operation. Marathon’s Light Products Terminal includes storage tanks and a six lane loading rack for loading delivery trucks with gasoline. Present air quality: All of this equipment is located in an area that is considered to be an “attainment area” for all of the National Ambient Air Quality Standards (NAAQS) except for the standard for SO2. The area is considered to be a “nonattainment area” for SO2. Proposed changes to the DHOUP: Construction of the DHOUP is substantially complete and the new emission units associated with the DHOUP commenced operation in November 2012. According to Marathon, initial operation of the DHOUP has revealed several unanticipated operational constraints, including both physical and permit restrictions, that are keeping the project from meeting the original design objectives. Therefore, Marathon is proposing a number of changes to the permit requirements to address these operational constraints.

Marathon Petroleum Company LP Page 5 Permit No. 63-08D December 4, 2013 • Changes potentially affecting emissions include:

o modifying the kerosene hydrotreater (KHT) rundown piping to provide access to other tanks and allow KHT product to be used in diesel fuel blending,

o increasing the NOx emission limit for the B&W Boiler, o increasing the CO emission limits for the B&W Boiler and the new Vacuum Heater, o increase the gasoline blend tank throughput, o change the crude tank throughput limit to an annual average, o increase the annual average sulfur production limits for the sulfur recovery units, o increase the firing limits for the Alkylation Deisobutanizer Heater, Distillate Hydrotreater

Heater, new Vacuum Heater, Coker Charge Heater, and new sulfur recovery unit thermal oxidizer,

o decrease the projected NOx emissions for the Alkylation Deisobutanizer Heater, Distillate Hydrotreater Heater, and new Vacuum Heater,

o specify that the Zurn Boiler is no longer allowed to burn refinery fuel gas, o require control of the coker wet gas compressor seal vent, and o reduce the projected NOx, SO2, PM, PM10, CO, and VOC emissions from the FCCU.

• Changes to the permit requirements that do not affect facility emissions include: o modification or replacement of some valves that are incorrectly sized for their current service, o modification or replacement of several pumps to allow for a single pump to operate with a full

capacity spare, o modification of piping in the FCCU and coker gas plants to optimize propane/propylene

processing to allow the DHOUP to operate as designed, o clarifying that PM and PM10 emission limits for the FCCU Charge Heater apply only to

combusting refinery fuel gas, o replace the requirement to maintain coke produced in the Delayed Coker at a minimum

moisture content of 6% with a requirement to keep the coke adequately wetted to ensure that the opacity limit is met,

o require testing of coke moisture content at least three times per week rather than daily, o require sulfuric acid mist emission testing for the B&W Boiler instead of the Zurn Boiler

because the Zurn Boiler does not combust refinery fuel gas, o add several requirements of NSPS Ja, o require submittal of emission test plans 30 days prior to the test rather than 60 days prior, and o change sulfur recovery unit PM and PM10 emission limits from a pound per MMBtu basis to a

pound per hour basis. Pollutant Emissions The Marathon facility is an existing “major stationary source” for purposes of both the PSD requirements and the nonattainment new source review (NANSR) requirements. In order for the DHOUP to be subject to major New Source Review (NSR), the project has to result in both a “significant emissions increase” and a “significant net emissions increase”. The DHOUP was previously determined to “net out” of major NSR. The netting analysis was revised to account for the various changes requested in PTI application No. 63-08D, including all contemporaneous emission increases and decreases. The revised netting analysis shows the criteria pollutant emissions are still below the “significant” level. Table 1 below is a summary of the revised netting. Note that DHOUP emissions of CO, hydrogen sulfide (H2S) and total reduced sulfur (TRS) are below their respective significant thresholds, so a “net emissions” analysis is not required for these pollutants.

Marathon Petroleum Company LP Page 6 Permit No. 63-08D December 4, 2013 TABLE 1: NET EMISSION SUMMARY1

Pollutant

Detroit HOUP

Emissions tons/year

Contemporaneous Emission

Increase/Decrease tons/year

Consent Decree

Adjustment tons/year2

Net Emissions Increase tons/year

PSD Significance

Levels, tons/year

Does Major NSR

Apply? VOC -38.37 +33.4 - -4.97 40 No NOx +198 -609 +410 -1 40 No Sulfur Dioxide

+208 -784 +573 -3 40 No

PM +33 -127 +94 0 25 No PM10 -13.57 -9.45 +9.43 -13.59 15 No CO +85 - - +85 100 No Sulfuric Acid Mist

+11.94 -63.2 +46.21 -5 7 No

1 Some values in this table have been rounded. 2 Certain emission decreases that were required by a USEPA consent decree cannot be used as decreases

for the purposes of netting and therefore are shown as emission increases in this table. Key Permit Review Issues The AQD staff evaluated the proposed project to identify all state rules and federal regulations which are, or may be, applicable. The tables in Appendix 1 summarize these rules and regulations. • Minor Modification Determination for Regulated Pollutants – The AQD permit review

determined that the project is a minor modification for all regulated NSR pollutants and is not subject to any major source review requirements.

A physical change or change in the method of operation at the facility would be subject to major NSR requirements for a regulated NSR pollutant if both of the following were true for the pollutant:

1. The pollutant’s emissions increase due to the proposed project is greater than the significant level for that pollutant.

2. The pollutant’s net emissions increase due to the proposed project is greater than the significant level for that pollutant.

The proposed project is not subject to major NSR because the DHOUP project does not result in both a “significant emissions increase” and a “significant net emissions increase” for any regulated pollutant. Table 1 above summarizes the proposed changes of each regulated pollutant.

Marathon Petroleum Company LP Page 7 Permit No. 63-08D December 4, 2013 • Federal NSPS Regulations – NSPS were established under Title 40 of the Code of Federal

Regulations (40 CFR) Part 60. The refinery is subject to multiple NSPS, including those listed in the table below. The requirements of these regulations are included in the proposed permit conditions.

NSPS Title NSPS Subpart

Industrial-Commercial-Institutional Steam Generating Units Subpart Db Petroleum Refineries Subpart J Petroleum Refineries for Which Construction, Reconstruction, or Modification Commenced After May 14, 2007

Subpart Ja

Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984

Subpart Kb

Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry for which Construction, Reconstruction, or Modification Commenced After January 5, 1981, and on or Before November 7, 2006

Subpart VV

Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry for Which Construction, Reconstruction, or Modification Commenced After November 7, 2006

Subpart VVa

Equipment Leaks of VOC in Petroleum Refineries for which Construction, Reconstruction, or Modification Commenced After January 4, 1983, and on or Before November 7, 2006

Subpart GGG

Equipment Leaks of VOC in Petroleum Refineries for Which Construction, Reconstruction, or Modification Commenced After November 7, 2006

Subpart GGa

VOC Emissions From Petroleum Refinery Wastewater Systems Subpart QQQ • Federal NESHAP Regulations - National Emission Standards for Hazardous Air Pollutants

(NESHAP) were established under 40 CFR Part 61 and Part 63. The refinery is subject to multiple Part 63 NESHAP, including those listed in the table below. The requirements of these regulations are included in the proposed permit conditions.

NESHAP Title NESHAP Subpart

Heat Exchange Systems at Petroleum Refineries Subpart CC Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units

Subpart UUU

Industrial, Commercial, and Institutional Boilers and Process Heaters Subpart DDDDD • Rule 702 VOC Emissions – The only emission units that have an increase in VOC emissions due

to Marathon’s proposed changes are three heaters and the gasoline blend storage tanks. As shown in the following table, the emissions from these emissions units are low and the increases in emissions are small. These low emission rates comply with Rule 702.

Emission Unit Previous Projected

Emissions tons/year

Revised Projected Emissions tons/year

Increase in Emissions tons/year

EU04-VAC2HTR 1 2 1 EU70-COKERHTR 5 6 1 EU77-DHTHTR 1 2 1 Gasoline blend storage tanks 5.79 5.84 0.05

Marathon Petroleum Company LP Page 8 Permit No. 63-08D December 4, 2013

• Rule 224 Best Available Control Technology (BACT) for toxics (T-BACT) Analysis – Rule 224 requires T-BACT for toxic air contaminant (TAC) emissions from new or modified emission units that require a PTI. The rule provides that T-BACT does not apply to the emissions of TACs that are also VOCs, if the emission unit complies with BACT for VOCs. There are no new emission units associated with the proposed changes to the DHOUP. There are a few emissions units that are “modified” and therefore are subject to T-BACT. All emission units that are “modified” that emit TACs that are VOCs are not subject to T-BACT because the VOC emissions are in compliance with Rule 702 BACT. For the TACs emitted from “modified” emission units in the DHOUP that are not VOCs, the previous Rule 224 analysis for the DHOUP remains valid. T-BACT for the DHOUP includes use of flares, thermal oxidizers, and leak detection and repair procedures.

• Rule 225 Toxics Analysis – The MDEQ Rules for Air Pollution Control require the ambient air

concentration of TACs from new or modified emission units be compared against health-based screening levels. The AQD staff reviewed Marathon’s air quality modeling and evaluation of TAC impacts for those TACs that may have increased emissions due to the proposed changes. The review found that all TACs will comply with the requirements of Rule 225.

For the combustion sources with an increase in short term firing capacity, the modeled impact of each TAC is less than 5% of its respective screening level for all of the modified heaters combined. The gasoline emissions from the entire stationary source were evaluated using Rule 225(3)(b), which requires the maximum ambient impact on industrial property or public roadways to be less than or equal to ten times the secondary risk screening level (SRSL) and requires the maximum ambient impact on all property that is not industrial or public roadway to be less than or equal to the SRSL. The gasoline impact satisfies these two requirements. Compliance with Rule 225(3)(b) requires the applicant to monitor changes in land use, which is specified in the draft special conditions. The hydrogen sulfide emissions from the entire stationary source were evaluated. The modeled impact of the 24-hour average hydrogen sulfide emissions is less than 60% of the screening level and, therefore, comply with the applicable air toxics rules. The evaluation of the annual average hydrogen sulfide emissions determined that the emissions will not cause or contribute to a violation of the provisions of Rule 901 and, therefore, under the provisions of Rule 226(d), are in compliance with the applicable air toxics rules.

Key Aspects of Draft Permit Conditions • Emission Limits – The draft permit includes criteria pollutant emission limits for the DHOUP to

ensure that the project is a minor modification.

• Usage Limits - The draft permit includes limits on the amount of fuel that can be burned in the various combustion devices, limits on the amount of sulfur that can be produced in the sulfur recovery units, and limits on the throughput of a variety of materials in the storage tanks.

Marathon Petroleum Company LP Page 9 Permit No. 63-08D December 4, 2013 • Process/Operational Restrictions – The draft permit includes multiple process and operational

restrictions, including only burning natural gas in the Zurn Boiler, fuel usage limits, heat input limits, only venting coke drums to atmosphere when the drum pressure is 2 psig or less, a requirement to wet the coke to prevent visible emissions, a limit on coke drum cycles, and a requirement to have a coker blowdown gas recovery system.

• Federal Regulations – The DHOUP is subject to several NSPS, as listed above. The draft permit

includes numerous conditions to ensure that the DHOUP will be in compliance with the various NSPS. The DHOUP is also subject to three NESHAPs, as listed above. The draft permit includes numerous conditions to ensure that the DHOUP will be in compliance with these NESHAPs.

• Emission Control Device Requirements - The draft permit includes multiple emission control

device requirements, including flares, thermal oxidizers, and low NOx burners. • Testing & Monitoring Requirements - The draft permit includes the following requirements for

the DHOUP:

− Verify NOx, CO, PM, PM10, PM2.5, VOC, sulfuric acid mist, and hydrogen sulfide emission rates through performance testing for multiple emission units.

− Install Continuous Emission Monitoring Systems (CEMS) for NOx, CO, CO2, SO2, and oxygen for multiple emission units.

− Install a Continuous Opacity Monitoring System (COMS) on the FCCU. Compliance Program Under the agreed upon terms of the proposed Consent Order, Marathon agreed to comply with Permit to Install 63-08D, which is attached as Exhibit A of the proposed Consent Order. The proposed Consent Order incorporates a monetary settlement amount of $99,500.00 paid to the State of Michigan general fund. Failure to comply with the terms and conditions of the Consent Order could result in a maximum stipulated penalty of $10,000.00 per violation. Conclusion and Recommendation The AQD staff believes that the proposed Consent Order, as drafted, contains an appropriate compliance program for resolution of the federal and state air quality violations against Marathon Petroleum. The AQD staff recommends that the proposed Consent Order be entered, unless substantive adverse comments are received during the public comment period. Additionally, based on the analyses conducted to date, the AQD staff concludes that the project proposed by the PTI application would comply with all applicable state and federal air quality requirements. The AQD staff also concludes that this project, as proposed, would not violate the federal NAAQS or the state and federal PSD increments.

Marathon Petroleum Company LP Page 10 Permit No. 63-08D December 4, 2013 Based on these conclusions, the AQD staff has developed draft permit terms and conditions which would ensure that the proposed facility design and operation are enforceable and that sufficient monitoring, recordkeeping, and reporting would be performed by the applicant to determine compliance with these terms and conditions. If the permit application is deemed approvable, the delegated decision maker may determine a need for additional or revised conditions to address issues raised during the public participation process. If you would like additional information about the proposed permit, please contact Mr. Andrew Drury, AQD, at 517-284-6792. If you would like additional information about the proposed consent order, please contact Mr. Jason Wolf, AQD, at 517-284-6772.

Marathon Petroleum Company LP Page 11 Permit No. 63-08D December 4, 2013

Appendix 1 STATE AIR REGULATIONS

State Rule Description of State Air Regulations

R 336.1201

Requires an Air Use Permit for new or modified equipment that emits, or could emit, an air pollutant or contaminant. However, there are other rules that allow smaller emission sources to be installed without a permit (see Rules 336.1279 through 336.1290 below). Rule 336.1201 also states that the Department can add conditions to a permit to assure the air laws are met.

R 336.1205

Outlines the permit conditions that are required by the federal Prevention of Significant Deterioration (PSD) Regulations and/or Section 112 of the Clean Air Act. Also, the same types of conditions are added to their permit when a plant is limiting their air emissions to legally avoid these federal requirements. (See the Federal Regulations table for more details on PSD.)

R 336.1224

New or modified equipment that emits toxic air contaminants must use the Best Available Control Technology for Toxics (T-BACT). The T-BACT review determines what control technology must be applied to the equipment. A T-BACT review considers energy needs, environmental and economic impacts, and other costs. T-BACT may include a change in the raw materials used, the design of the process, or add-on air pollution control equipment. This rule also includes a list of instances where other regulations apply and T-BACT is not required.

R 336.1225 to R 336.1232

The ambient air concentration of each toxic air contaminant emitted from the project must not exceed health-based screening levels. Initial Risk Screening Levels (IRSL) apply to cancer-causing effects of air contaminants and Initial Threshold Screening Levels (ITSL) apply to non-cancer effects of air contaminants. These screening levels, designed to protect public health and the environment, are developed by Air Quality Division toxicologists following methods in the rules and U.S. EPA risk assessment guidance.

R 336.1279 to R 336.1290

These rules list equipment to processes that have very low emissions and do not need to get an Air Use permit. However, these sources must meet all requirements identified in the specific rule and other rules that apply.

R 336.1299(2)(b) Adopts by reference the provisions of 40 CFR 63.40 to 63.44 (2002) and 40 CFR 63.50 to 63.56 (2002), the federal hazardous air pollutant regulations governing constructed or reconstructed major sources.

R 336.1301 Limits how air emissions are allowed to look at the end of a stack. The color and intensity of the color of the emissions is called opacity.

R 336.1331 The particulate emission limits for certain sources are listed. These limits apply to both new and existing equipment.

R 336.1370 Material collected by air pollution control equipment, such as dust, must be disposed of in a manner, which does not cause more air emissions.

R 336.1401 and R 336.1402 Limit the sulfur dioxide emissions from power plants and other fuel burning equipment.

R 336.1601 to R 336.1651

Volatile organic compounds (VOCs) are a group of chemicals found in such things as paint solvents, degreasing materials, and gasoline. VOCs contribute to the formation of smog. The rules set VOC limits or work practice standards for existing equipment. The limits are based upon Reasonably Available Control Technology (RACT). RACT is required for all equipment listed in Rules 336.1601 through 336.1651.

R 336.1702

New equipment that emits VOCs is required to install the Best Available Control Technology (BACT). The technology is reviewed on a case-by-case basis. The VOC limits and/or work practice standards set for a particular piece of new equipment cannot be less restrictive than the Reasonably Available Control Technology limits for existing equipment outlined in Rules 336.1601 through 336.1651.

R 336.1801 Nitrogen oxide emission limits for larger boilers and stationary internal combustion engines are listed.

R 336.1901 Prohibits the emission of an air contaminant in quantities that cause injurious effects to human health and welfare, or prevent the comfortable enjoyment of life and property. As an example, a violation may be cited if excessive amounts of odor emissions were found to be preventing residents from enjoying outdoor activities.

Marathon Petroleum Company LP Page 12 Permit No. 63-08D December 4, 2013

STATE AIR REGULATIONS State Rule Description of State Air Regulations R 336.1910 Air pollution control equipment must be installed, maintained, and operated properly.

R 336.1911 When requested by the Department, a facility must develop and submit a malfunction abatement plan (MAP). This plan is to prevent, detect, and correct malfunctions and equipment failures.

R 336.1912 A facility is required to notify the Department if a condition arises which causes emissions that exceed the allowable emission rate in a rule and/or permit.

R 336.2001 to R 336.2060

Allow the Department to request that a facility test its emissions and to approve the protocol used for these tests.

R 336.2801 to R 336.2804

Prevention of Significant

Deterioration (PSD)

Regulations

Best Available Control

Technology (BACT)

The PSD rules allow the installation and operation of large, new sources and the modification of existing large sources in areas that are meeting the National Ambient Air Quality Standards (NAAQS). The regulations define what is considered a large or significant source, or modification.

In order to assure that the area will continue to meet the NAAQS, the permit applicant must demonstrate that it is installing the BACT. By law, BACT must consider the economic, environmental, and energy impacts of each installation on a case-by-case basis. As a result, BACT can be different for similar facilities.

In its permit application, the applicant identifies all air pollution control options available, the feasibility of these options, the effectiveness of each option, and why the option proposed represents BACT. As part of its evaluation, the Air Quality Division verifies the applicant’s determination and reviews BACT determinations made for similar facilities in Michigan and throughout the nation.

R 336.2901 to R 336.2903 and

R 336.2908

Applies to new “major stationary sources” and “major modifications” as defined in R 336.2901. These rules contain the permitting requirements for sources located in nonattainment areas that have the potential to emit large amounts of air pollutants. To help the area meet the NAAQS, the applicant must install equipment that achieves the Lowest Achievable Emission Rate (LAER). LAER is the lowest emission rate required by a federal rule, state rule, or by a previously issued construction permit. The applicant must also provide emission offsets, which means the applicant must remove more pollutants from the air than the proposed equipment will emit. This can be done by reducing emissions at other existing facilities.

As part of its evaluation, the AQD verifies that no other similar equipment throughout the nation is required to meet a lower emission rate and verifies that proposed emission offsets are permanent and enforceable.

FEDERAL AIR REGULATIONS

Citation Description of Federal Air Regulations or Requirements

Section 109 of the Clean Air Act –

National Ambient Air Quality Standards (NAAQS)

The United States Environmental Protection Agency has set maximum permissible levels for seven pollutants. These NAAQS are designed to protect the public health of everyone, including the most susceptible individuals, children, the elderly, and those with chronic respiratory ailments. The seven pollutants, called the criteria pollutants, are carbon monoxide, lead, nitrogen dioxide, ozone, particulate matter less than 10 microns (PM10), particulate matter less than 2.5 microns (PM2.5), and sulfur dioxide. Portions of Michigan are currently non-attainment for either ozone or PM2.5. Further, in Michigan, State Rules 336.1225 to 336.1232 are used to ensure the public health is protected from other compounds.

Marathon Petroleum Company LP Page 13 Permit No. 63-08D December 4, 2013

FEDERAL AIR REGULATIONS Citation Description of Federal Air Regulations or Requirements

40 CFR 52.21 – Prevention of

Significant Deterioration

(PSD) Regulations

Best Available Control

Technology (BACT)

The PSD regulations allow the installation and operation of large, new sources and the modification of existing large sources in areas that are meeting the NAAQS. The regulations define what is considered a large or significant source, or modification.

In order to assure that the area will continue to meet the NAAQS, the permit applicant must demonstrate that it is installing BACT. By law, BACT must consider the economic, environmental, and energy impacts of each installation on a case-by-case basis. As a result, BACT can be different for similar facilities.

In its permit application, the applicant identifies all air pollution control options available, the feasibility of these options, the effectiveness of each option, and why the option proposed represents BACT. As part of its evaluation, the Air Quality Division verifies the applicant’s determination and reviews BACT determinations made for similar facilities in Michigan and throughout the nation.

40 CFR 60 – New Source Performance

Standards (NSPS)

The United States Environmental Protection Agency has set national standards for specific sources of pollutants. These New Source Performance Standards (NSPS) apply to new or modified equipment in a particular industrial category. These NSPS set emission limits or work practice standards for over 60 categories of sources.

40 CFR 63—National

Emissions Standards for Hazardous Air

Pollutants (NESHAP)

The United States Environmental Protection Agency has set national standards for specific sources of pollutants. The National Emissions Standards for Hazardous Air Pollutants (NESHAP) (a.k.a. Maximum Achievable Control Technology (MACT) standards) apply to new or modified equipment in a particular industrial category. These NESHAPs set emission limits or work practice standards for over 100 categories of sources.

Section 112 of the Clean Air Act

Maximum

Achievable Control Technology

(MACT)

Section 112g

In the Clean Air Act, Congress listed 189 compounds as Hazardous Air Pollutants (HAPS). For facilities which emit, or could emit, HAPS above a certain level, one of the following two requirements must be met:

1) The United States Environmental Protection Agency has established standards for specific types of sources. These Maximum Achievable Control Technology (MACT) standards are based upon the best-demonstrated control technology or practices found in similar sources.

2) For sources where a MACT standard has not been established, the level of control technology required is determined on a case-by-case basis.

Notes: An “Air Use Permit,” sometimes called a “Permit to Install,” provides permission to emit air contaminants up to certain specified levels. These levels are set by state and federal law, and are set to protect health and welfare. By staying within the levels set by the permit, a facility is operating lawfully, and public health and air quality are protected. The Air Quality Division does not have the authority to regulate noise, local zoning, property values, off-site truck traffic, or lighting. These tables list the most frequently applied state and federal regulations. Not all regulations listed may be applicable in each case. Please refer to the draft permit conditions provided to determine which regulations apply.