DEQ Basis For Decision Vol 1 - Murphy Oil Air Permit V5 - October 22, 2009

BOBBY JINDAL HAROLD LEGGETT, PH.D.
GOVERNOR SECRETARY
~tate of 1Louisiana
DEPARTMENT OF ENVIRONMENTAL QUALITY
ENVIRONMENTAL SERVICES
October 22, 2009
RE: Notification of final permit action

Permit No. 2500-0000l-V5
Murphy Oil U.S.A, Inc., Meraux Refinery, Meraux, St. Bernard Parish, Louisiana
Agency Interest (AI) No. 1238
Dear Sir or Madam:
Thank you for your interest in the referenced matter. The Louisiana Department of
Environmental Quality (LDEQ) has received and considered all public comments submitted
regarding this permit action. Please be advised that the referenced action was approved on
October 15,2009. .
A copy of the Basis for Decision and Public Comments Response Summary are attached;
these documents address significant public comments regarding this permit action. The final
permit and related documents are available for review at the LDEQ's Public Records Center,
Room 127, 602 North 5th Street, Baton Rouge, Louisiana. Viewing hours are from 8:00
a.m. to 4:30 p.m. Monday - Friday (except holidays).
The documents are also available for review by accessing LDEQ's Electronic Document
Management System (EDMS), the electronic repository of official records that have been
created or received by LDEQ. Persons may search and retrieve documents stored in EDMS
via the LDEQ's web application at http://www.deq.louisiana.gov/portal/tabid/2604/
Default.aspx.
If you would like to obtain copies of these documents, you may request them from LDEQ
Records Management by mail at P.O. Box 4303, Baton Rouge, LA 70821-4303 or by phone
at (225) 219-3168. Your request will be processed pursuant to LDEQ's procedures for
public record requests, LAC 33:1.2301, et seq., and a copy fee will be charged.
Pursuant to La. RS. 30:2050.21, an aggrieved person may appeal devolutively a final permit
action only to the Nineteenth Judicial District Court for the parish of East Baton Rouge. A
petition for review must be filed in the district court within thirty days after notice of the
action has been given.
If you have any questions, please contact Mr. Syed Quadri of the Office of Environmental
Services, Air Permits Division, at (225) 219-3123.
Sincerely,
e"el ••.•. O.
Bryan D. Johnston
~1A-
Administrator
Attachments
Post Office Box 4313 • Baton Rouge, Louisiana 70821-4313 • Phone 225-219-3181 • Fax 225-219-3309
www.deq.louisiana.gov
LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY
OFFICE OF ENVIRONMENTAL SERVICES
BASIS FOR DECISION
PART 70 OPERATING PERMIT NO. 2500-00001-V5
MERAUX REFINERY
AGENCY INTEREST NO. 1238
MURPHY OIL USA INC.
MERAUX, ST. BERNARD PARISH, LOUISIANA
The Louisiana Department of Environmental Quality (LDEQ), Office of Environmental Services

(OES), issues to Murphy Oil USA Inc. ("Murphy" or "company") a Part 70 (Title V) Operating
Permit, Permit No. 2500-00001-V5, for the const~uction and operation of the BenFree Unit at its
Meraux Refinery ("refinery" or "facility") located in Meraux, S1.Bernard Parish, Louisiana.
For the Meraux Refinery, the LDEQ finds that as a part of the "IT Requirements,") adverse
environmental impacts have been minimized or avoided to the maximum extent possible. Save
Ourselves v. La. Envtl. Control Commission, 452 So. 2d 1152, 1157 (La. 1984). To make this
determination, the LDEQ finds that the permit for Murphy Oil USA, Inc. 's Meraux Refinery
complied with all applicable federal and state statutes and regulations and has otherwise minimized
or avoided the environmental impacts to the maximum extent possible. Additionally, the LDEQ
finds that Meraux Refinery met the alternative projects, alternative sites, and mitigation measures
requirements of Save Ourselves. Id. at 1157.
In making this determination, the LDEQ finds that the submitted information complied with all
applicable federal and state statutes and regulations and have otherwise minimized or avoided the
environmental impacts to the maximum extent possible. Additionally, the LDEQ finds that Murphy
met the alternative projects, alternative sites, and mitigation measures requirements of Save
Ourselves. Id. at 1157.
After the LDEQ determined that adverse environmental impacts of the permit had been minimized
or avoided to the maximum extent possible, it balanced social and economic factors with
environmental impacts. Notably, the Louisiana constitution does not establish environmental
IThe "IT Requirements" or "IT Questions" are five requirements [see Save Ourselves v. Envtl. Control Comm'n,
452 So. 2d at 1152, 1157 (La. 1984)] that both the permit applicant and the LDEQ consider during certain permit
application processes. Although the five requirements have been expressed as three requirements (see Rubicon
Inc., 670 So. 2d at 475, 483 (La. App. 1 eir 1996), rehearing denied), the requirements remain basically the same
whether stated as five or as three. The "IT Requirements" must satisfy the issues of whether:
1) the potential and real adverse environmental effects of the proposed project have been avoided to the
maximum extent possible;
2) a cost benefit analysis of the environment impact costs balanced against the social and economic benefits of
the project demonstrate that the latter outweighs the former;
3) there are alternative projects or alternative sites or mitigating measures, which would offer more protection
to the environment than the proposed project without unduly curtailing non environmental benefits to the
extent applicable.
Basis for Decision
Murphy Oil USA, Inc., Meraux Refinery
AII238,PER20090002
Page 2 of 16
protection as an exclusive goal, but instead, requires a balancing process in which environmental
costs and benefits must be given full and careful consideration along with economic, social, and
other factors. Id. Accordingly, the LDEQ finds that the social and economic benefits of the
proposed permit will outweigh greatly its adverse environmental impacts.
The details of the LDEQ's reasoning are s~t forth below:2
FINDINGS OF FACT
1. BACKGROUND
A. Description of Facility
Murphy owns and operates a petroleum refinery in Meraux, Louisiana. Murphy

produces propane, motor gasoline, kerosene, diesel, No. 6 fuel oil, and other
miscellaneous petroleum products. The refinery consists of the following processes
and operations: Crude Distillation Unit, Rose Unit, Hydrofluoric Acid Alkylation
Unit, Hydrobon Unit, Platformer Unit, Amine Unit, Sulfur Recovery Units, Distillate
Hydrotreating Unit, C3/C4 Splitter Unit, Middle Distillate Hydrotreating Unit, Merox
Process, Sour Water Stripper Process, Liquid Petroleum Gas Recovery Unit, Fluid
Catalytic Cracking Units, Wastewater Treatment System, and Steam Generation Unit.
The petroleum refining process separates crude oil into different fractions based upon
their respective boiling point ranges. Light hydrocarbon fractions may undergo
catalytic reforming to rearrange short chain hydrocarbon streams for use in gasoline
blending. Heavier fractions may undergo catalytic cracking to break up the large
hydrocarbon compounds into useful gasoline blending components. Various process
streams are also treated to remove sulfur before further processing takes place.
Petroleum refinery operations typically include auxiliary systems such as hydrogen
production, wastewater treating, and steam production.
B. Proposed Permit Action
Murphy proposes to construct and operate a BenFree Unit (BFU) in order to comply
with the U.S. Environmental Protection Agency's. (EPA's) Mobile Source Air
Toxics (MSAT) Phase 2 Rule promulgated on February 26, 2007. This rule will
limit the benzene con~ent of the gasoline produced to an annual average of 0.62
percent by volume. The BFU will saturate benzene-rich reformate into
cyclohexane-rich gasoline. Reformate from the Catalytic Reformer (Platformer
Unit) will enter the Reformate Splitter, which will be fired by a reboiler. The
Splitter will separate reformate into two streams. The heavy reformate (toluene and
2Any finding of fact more appropriately designated as a conclusion of law shall be considered also a conclusion of
law; and any conclusion of law more appropriately designated as a finding of fact shall be considered also as a
finding of fact.
Basis for Decision
AI1238,PER20090002
Page 3 of 16
heavier) will be piped to gasoline storage tanks, while the light reform ate will be
routed to the reactor. Benzene in the light reform ate will be selectively saturated
when the light reform ate is mjxed with hydrogen on a fixed catalyst bed in the
Reactor. Fjnally, the BenFree product will be blended wjth gasoline in storage
tanks.
The BFU will receive feed djrectly from the Platformer Uillt and will operate only
when the Platformer is jn operatjon. The BFU is qn addition to the Platformer Unit
and wjll not result in any debottlenecking of any other units at the facility. Also,
there will not be any pure benzene streams in the unjt or in any storage tanks. The
offgas from the BFU will be routed to the fuel gas system. In an emergency or
during maintenance activities, emissions from the BFU will be controlled by
routing the vent to the existing North Flare via the Area 6 Flare Knockout Drum.
The BFU will comply with 40 CFR 60, Subpart QQQ arid 40 CFR 61, Subpart FF.
The BFU Reboiler will comply with 40 CFR 60, Subpart J (or Subpart Ja should the
stay be lifted); this source will be· equipped with ultra-low NOx burners and its
emissions shall be reported under an existing cap for heaters and boilers, Emission
Point CAP-Heaters. Murphy shall incorporate the fugitives associated with the
BFU into the Leak Detection and Repair (LDAR) program under 40 CFR 60,
Subpart GGGa (which refers to Subpart VVa). The BFU's turnaround emissions
shall also be included in the overall faciljty turnaround emissions.
In addition to permitting the BFU Unit, Murphy proposes to modify the permit as
shown below:
1. Update the Crude, Middle Distillate, Heavy Oil, and Slop Oil Tank caps,
which will result in a reduction of VOC emissjons due to the replacement,
reconstruction, or reinstatement of tanks approved in previous permits (2500-
00001-V3 and V4);
2. Consolidate the Gasoline and Naphtha CAPs into one Gasoline/Naphtha CAP;
3. Update fugitive emissions associated with tank changes and the BFU Project;
4. Update the facility turnaround emissions to include the BFU project and the
NO.2 Amine Unit;
5. Cancel the rerouting of the Oily Water Stripper vent stream to the fuel gas
system. The Oily Water Stripper vent stream shall continue to be routed to
the North Flare, Emission Point 20-72;
6. Incorporate Boiler B-7 as a permanent source in order to meet the steam
demand at the facility;
7. Update Refinery Turnaround Emissions, Emission Point TRND, based on the
planned turnarounds for the duration of this permit term, whjch expjres on
November 20,2012; and
8. Update the "Specific Requirements" and "Inventories" sections of the permh,
as approprjate.
Emissions increases due to the BFU Project (Reboiler, Fugitives, Cooling Tower, North
Basis for Decision
AII238,PER20090002
Page 4 of 16
Flare, Storage, BFU Turnaround, Startup/Shutdown, etc.), evaluated on an "actual to

potential" basis, in tons per year (TPY), are shown in the following table:
PSD De
16.27
52.98
36.89
58.73
9.75
40
100
40
2.04
4.34
2.10
15
2.30
23.25
28.95
BFU Minimis
Potential
Emissions
Emissions
35.48
16.09
6.52
26.85
Increase
Project Post-Project
Baseline Actual
Emissions increases due to the project are below Prevention of Significant Deterioration
(PSD) significance levels; therefore, further PSD review (i.e., netting) is not required.
Permitted emissions from the Meraux Refinery, in TPY, are as follows:
Pollutant Before After Change*

PMJO 206.40 206.86 + 0.46
S02 684.49 725.02 + 40.53
NOx 1220.06 1224.91 +4.85
CO 1960.70 2018.47 + 57.77
VOC 600.30 637.52 + 37.22
* Includes emISSIOns increases associated with the BFU Project and the addition of
refinery turnaround and startup/shutdown emissions (5 years) not associated with the
BFU Project. Turnaround and startup/shutdown emissions, in the past, used to be
authorized under variances. Including such emissions in the permit will greatly assists
in air quality planning by clearly identifying, quantifying, and limiting them where
necessary. Turnaround and startup/shutdown emissions are not subject to PSD review,
as they are existing and not in any way associated with a physical change or change in
the method of operation. A specific condition has been added to this permit to limit
turnaround and startup/shutdown emissions, Emission Point TRND.
II. PUBLIC COMMENT
Request for public comment and notice of a public hearing on the proposed permit was
published in The Advocate, Baton Rouge, Louisiana; and in The St. Bernard Voice, Arabi,
Louisiana on May 29, 2009. The public notice was also mailed and e-mailed to persons
included in the LDEQ mailing list on May 28,2009. The public hearing was held on July
7, 2009, at the Nunez Community College Auditorium, 3710 Paris Road, Chalmette,
Louisiana. A second public notice was published in The Advocate, Baton Rouge,
Louisiana; and in The St. Bernard Voice, Arabi, Louisiana on July 17,2009, to extend the
-- -- ---- ----
Basis for Decision
AI l238,PER20090002
Page 5 of 16
comment period to August 6, 2009,' in response to a request received bye-mail and at the
hearing. The comment period and public hearing afforded the public an opportunity to
provide comments on the proposed Part 70 (Title V) Operating Permit Number 2500-
00001-V5.
The LDEQ received written and oral comments on the proposed permit at the hearing on
July 7, 2009; during the first comment period ending on July 9, 2009; and during the
second comment period ending on August 6, 2009.
III. PUBLIC COMMENTS RESPONSE SUMMARY
A "Public Comment Response Summary" was prepared for all significant comments and is
attached and made a part of this Basis for Decision.
IV. ALTERNATIVE SITES: Are there alternative sites which would offer more
protection to the environment than the proposed facility site without unduly curtailing
non-environmental benefits?
While the LDEQ recognizes that the concepts of alternative sites, alternative projects, and
mitigative measures are closely interrelated and overlap, each concept is addressed
separately in this document for purposes of emphasis and clarity. However, the LDEQ
stresses the interrelation of the three; for example, the choice of a particular site could
involve mitigative factors and possibly alternative project considerations; likewise, selection
of an alternative project could invoke mitigative factors and impact site selection.
Apparently, the Louisiana First Circuit Court of Appeal has also recognized this
interrelationship and now considers the three requirements as one. Matter of Rubicon, Inc.,
95-0108 (La. App. I Cir. 2/14/96), 670 So. 2d 475, 483.
Therefore, because of this interrelationship, the LDEQ adopts any and all of its findings on
all of the three factors under each of the specific designated areas -- alternative sites (Section
IV), alternative projects (Section V), and mitigative measures (Section VI). Additionally,
the assessment and findings set forth below in Section VII (Avoidance of Adverse
Environmental Effects) also interrelate and have been considered relative to these facts.
Portions of the existing Meraux Refinery were built and operated by Sinclair Oil in the
1920's. Murphy has owned and operated the facility since 1962. Gasoline fuel is one of
the products of the refinery. The proposed BenFree Unit is required to lower the benzene
content of gasoline to meet the U.S. EPA's Mobile Source Air Toxics (MSAT) Phase 2 Rule
promulgated on February 26,2007. This rule will limit the benzene content of the gasoline
produced at the refinery to an annual average of 0.62 percent by volume.
Because the Meraux Refinery is an existing facility, a traditional alternative site analysis is
not appropriate. Consideration of an alternate site would involve the construction of a
new facility, possibly on a "greenfield" site, which would by its nature involve an
"alternate projects" analysis. Moreover, the BenFree Unit can only be constructed in
Basis for Decision
AI1238,PER20090002
Page 6 of 16
close proximity to the Platformer Unit. There are no known offsite facilities which
would accept the platformate for treatment. Also, such activity would result in greater
exposure to the public due to unnecessary transportation hazards.
Nevertheless, in considering the permit applications, the LDEQ reviewed the existing
operations and compliance record.
The Meraux Refinery has a compliance history at the present location. The following
enforcement actions remain open:
Action Type Tracking No. Date

Consolidated Compliance Order & Notice of MM -CN-02-00 15 April 9, 2006
Potential Penalty
Consolidated Compliance Order & Notice of WE-CN-08-0410 August 27, 2008
Potential Penalty
Consolidated Compliance Order & Notice of AE-CN-08-0122 August 29, 2008
Potential Penalty
Amended Consolidated Compliance Order & Notice AE-CN-08-0122A December 22,
of Potential Penalty 2008
Consolidated Compliance Order & Notice of AE-CN-08-0294 January 9,2009
Potential Penalty
The refinery is working with LDEQ to resolve the issues addressed in the aforementioned
documents.
CONCLUSION: For the foregoing reasons, the LDEQ fmds there are no alternative sites
which would offer more protection to the environment than the proposed site without
unduly curtailing non-environmental benefits.
v. ALTERNATIVE PROJECTS: Are there alternative projects which would offer more
protection to the environment than the proposed facility without unduly curtailing
The LDEQ finds that the proposed BenFree Unit (BFU) at the Meraux Refinery offers
more protection to the environment than any other possible alternative without unduly
curtailing nonenvironmental benefits. Additionally, the LDEQ recognizes that selection
of the most environmentally sound project or existing facility usually also serves as a
mitigative measure because the two considerations overlap considerably.
One alternative to the existing Meraux Refinery would be to construct on a "greenfield"

(undeveloped) site. A greenfield site would produce significantly more adverse
environmental impacts than the existing facility (e.g., put more land into industrial
manufacturing and use more resources for the construction of a new facility, including
the construction of associated roadways, rail and dock access, gas and liquid pipelines,
etc.). LDEQ accepts the fact that the costs of changing sites would be economically
Basis for Decision
AI1238,PER20090002
Page 7 of 16
infeasible.
In addition, the Meraux Refinery exists as a heavy industrial site, and its location allows
Murphy to utilize existing access to transportation via highways, rail, and water with
minimal potential for transportation incidents.
Murphy will utilize the BFU to reduce benzene content in the produced gasoline as
mandated by U.S. EPA requirements. Please refer to the details of the BFU in Section I.B
of this Basis for Decision. The BFU is a standard industrial process to reduce benzene
concentrations in gasoline. In this process, the benzene in reformate is converted to
cyclohexane.
The proposed project offers Murphy the opportunity to use existing infrastructure and
resources. As an existing facility, much of the equipment needed to service the proposed
project is currently in operation and readily available. An example of this is the
Platformer Unit, which is the source of feed to the BFU. This use is a significant factor
when evaluating the project's efficient management of resources and its effect on the
environment.
CONCLUSION: For the foregoing reasons, the LDEQ finds there are no alternative projects
which would offer more protection to the environment than that proposed without unduly
curtailing non-environmental benefits.
VI. MITIGATING MEASURES: Are there mitigating measures which would offer more
protection to the environment than the facility as proposed without unduly curtailing
LDEQ accepts the fact that the facility is designed and must be operated to maximize
environmental protection and prevent adverse environmental impacts. The facility
utilizes state-of-the-art refining technology and is permitted to operate under stringent
operational guidelines and requirements.
In addition to the requirements of LAC 33:III.Chapter 59 and 40 CFR 68 requirements

discussed in Section VILA of this Basis for Decision, the Meraux Refinery has in place
numerous protective measures to deal with emergency situations and an existing safety and
quality control training program for its personnel.
The proposed Part 70 (Title V) permit meets all applicable federal and state regulations.
Emissions from the projects will be controlled as required by applicable regulations, such as
LAC 33:III.Chapters 11, 13, 15, 21, 56, 59; New Source Performance Standards (NSPS)
under 40 CFR 60; National Emission Standards under 40 CFR 61; and the Maximum
Achievable Control Technology (MACT) requirements of LAC 33 :III. Chapter 51 and the
National Emission Standards for Hazardous Air Pollutants under 40 CFR 63. The permit
limits have been determined to be acceptable and protective of the environment.
Basis for Decision
AI1238,PER20090002
Page 8 of 16
In addition, numerous protective measures are on-site to deal with emergency situations.
The facility has a Spill Prevention Control and Countermeasures (SPCC) Plan and an
Emergency Response Plan. The site has also in place:
• emergency first aid facilities;
• a fire fighting brigade;
• a fire water supply system;
• a Halon fire protection system;
• portable fire extinguishers; and
• built-in sumps, dikes, and pumps to deal with spills and other secondary containment
measures.
Also, the facility is protected from unauthorized infiltration by a security system consisting
of:
1. 24-hour guards;
2. a seven (7) foot high fence;
3. TV security cameras; and
4. perimeter and process lighting.
Murphy recruits qualified personnel and fully trains them in the operation of the facility. All
personnel are mandated to participate in training programs on safety and quality
assurance/quality control and site-specific written procedures prior to on-the-job training.
CONCLUSION: For the foregoing reasons, the LDEQ finds there are no mitigating
measures which would offer more protection to the environment than the facility as
proposed without unduly curtailing non-environmental benefits.
VII. AVOIDANCE OF ADVERSE ENVIRONMENTAL EFFECTS: Have the potentia]

and rea] adverse environmental effects of the proposed facility been avoided to the
maximum extent possible?
As part of the permitting process, potential and real adverse environmental impacts of
pollutant emissions from the proposed new permitted sources are assessed by the LDEQ
prior to construction to ensure that they are minimized to the maximum extent possible
The proposed permit will require that all emission sources be controlled through technology
to meet or exceed the requirements of applicable federal and state emissions regulations,
such as the National Ambient Air Quality Standards (NAAQS) and MACT. Even though
the applicable requirements do not prevent sources from increasing emissions, they do
function to protect public health and welfare, protect the areas of historic value, and ensure
economic growth consistent with the preservation of existing clean air resources. Any
increase in emissions will not cause or contribute to an exceedance of a health-based or
technology-based standard, which is protective of human health and the environment.
Basis for Decision
AII238,PER20090002
Page 9 of 16
As part of the permitting process, potential and real adverse environmental impacts of
pollutant emissions from the proposed sources are assessed to ensure that they are
minimized. The following paragraphs describe the assessment by type of impact:
A. Air Emissions
The emissions from this proposed project shall be controlled to meet or exceed the
requirements of all applicable regulations and defined permit conditions. Emissions from
Meraux Refinery are based on conservative engineering design calculations,
manufacturers' guarantees, and established, approved emission factors.
Air emissions from operation of the refinery include particulate matter (pM 10), carbon
monoxide (CO), sulfur dioxide (S02), nitrogen oxides (NOx), and volatile organic
compounds (VOCs). Existing emissions of these air pollutants are controlled pursuant to
various control requirements, including Best Available Control Technology (BACT) as
required by the Prevention of Significant Deterioration (PSD) program, Maximum
Achievable Control Technology (MACT) as required by the National Emission Standards
for Hazardous Air Pollutants (NESHAP) and LAC 33:III.Chapter 51, and New Source
Performance Standards (NSPS). The Meraux Refinery is an existing facility and the
proposed project will not emit any new or different pollutants to the atmosphere.
Emissions associated with the proposed project were reviewed by the Air Quality
Assessment Division to ensure compliance with the NAAQS and Louisiana Ambient Air
Standard (AAS). LDEQ did not require the applicant to model emissions, as the BenFree
Unit does not result in a significant increase of any pollutant and can be considered as a
control device for reducing benzene.
Previous screening modeling performed indicates that emissions from the Meraux Refinery
will not cause or contribute to any NAAQS or AAS exceedances beyond the industrial
property; therefore, emissions from the refinery will not cause any air quality impacts that
will adversely affect human health or the environment in St. Bernard Parish. The previous
screen modeling results are as follows:
Calculated Maximum Louisiana Ambient

Ground Level Cone. Air Standard or
Pollutant Time Period (Ug/m3) (NAAQS) (l-lg/m3)
PM 10 24 hr. avg. 75 (150)
S02 Annual 25 (80)
24 hr. avg. 321 (365)
3 hr. avg. 885 (1300)
NOx Annual 15 (100)
CO 8 hr. avg. 2608 (10,000)
1 hr. avg. 7475 (40,000)
Ammonia 8 hr. avg. 0.2 640
Basis for Decision
AI1238,PER20090002
Page 10 of 16
Calculated Maximum Louisiana Ambient

Ground Level Conc. Air Standard or
Pollutant Time Period Cgg/m3) (NAAQS) Cgg/m3)
l,3-Butadiene Annual 0.35 0.92
Benzene Annual 9.6 12
Formaldehyde Annual 0.004 7.69
Hydrogen Fluoride 8 hr avg. 36.00 61.90
Hydrogen Sulfide 8 hr avg. 50.5 330
n-Hexane 8 hr avg. 759.3 4,190
Naphthalene 8 hr avg. 199.7 1,190
PAH Annual 0.03 0.06
Toluene 8 hr avg. 1,211.6 8,900
Xylene 8 hr avg. 1485.6 10,300
The accidental air release prevention program is mandated by Section 112(r) of the Clean
Air Act Amendments and codified in 40 CFR 68 (see also LAC 33:III.Chapter 59). As
documented in the permit application, as accepted by the LDEQ, Meraux Refinery has
developed a Risk Management Plan (RMP) as required by the regulations.3 According to
the EP A, the purpose of the RMP is to "prevent accidental releases of substances that can
cause serious harm to the public and the environment from short-term exposures and to
mitigate the severity of releases that do occur.,,4 The RMP describes actions that the
facility must do to "prevent accidental releases of hazardous chemicals into the
atmosphere and reduce their potential impact on the public and the environment."s
The Meraux Refinery has protective measures on-site to handle emergency situations.
Murphy has an emergency response plan that is coordinated with the Local Emergency
Planning Committee. The refinery complies with all state and federal regulations which
have been promulgated specifically to address the accidental release and offsite
consequences for toxic and/or flammable substances. These rules contain requirements for
hazard assessment, release prevention, emergency response, and risk management. The
design of the proposed process and equipment will be subjected to a detailed Process Hazard
Analysis to further reduce the likelihood of accidental airborne emissions.
B. Wastewater Discharges and Groundwater
LPDES wastewater permit LA0003646 was issued to Murphy on September 28, 2004,
with an effective date of October 1, 2004, and expiration date of September 30, 2009.
This permit was last modified on October 12, 2005 (effective November 1, 2005) and
authorizes the permittee to discharge treated process wastewater and process area
3 See EDMS Document 40169977 (pgs. 38 & 51 of 435)

4 EPA's General Risk Management Plan Program Guidance, April 2004
http://yosemite.epa. gov/oswer/ceppoweb. nsf/vw Resources ByFilename/lntro final.pdf/$FileJI ntro final.pdf
5 Ibid.
Basis for Decision
AII238,PER20090002
Page I I of 16·
stormwater, utility wastewater, treated sanitary wastewater, and low contamination

potential stormwater runoff to the Mississippi River (Outfalls 001 and 002) [subsegment
070301]; stormwater and hydrostatic test wastewater to Twenty Arpent Canal (Outfalls
003, 004, 015-019) [subsegment 041801]; and stormwater and hydrostatic test
wastewater to Twenty Arpent Canal via Meraux Canal (Outfall 020) [subsegment
041801]. In issuing the LPDES permit, the department determined that the permitted
discharges will have no adverse impact on the existing uses of the receiving waterbodies.
The subsegments identified are not currently impaired for any pollutants.
Groundwater protection is an integrated part of the design for the BenFree project.
Equipment and procedures are in place to avoid any potential adverse impacts to
groundwater. Process piping will be above ground to allow early detection and containment
of any potential leaks or spills. The BFU will be constructed with a concrete foundation to
capture and direct any oily Water or spills to the refinery sewer. system for treatment at the
onsite Wastewater Treatment Plant. Murphy has had various groundwater assessments and
monitoring programs over the years which indicate that the refmery does not have
groundwater contamination issues.6
c. Solid and Hazardous Waste Generation
According to the LDEQ's records, the Meraux Refinery does not have a hazardous waste
permit. The refinery has three solid waste permits for surface impoundments for treating
and/or disposing of solid waste. The proposed project will not substantially change the
Meraux Refinery's management of solid and hazardous waste.
The Storm water Pollution Prevention Plan will ensure that the potential adverse
environmental effects associated with the generation of solid or hazardous wastes resulting
from spills of oil or hazardous substances are minimized to the maximum extent possible.
Murphy will implement a plan to ensure that general debris generated during the
construction activities is disposed in accordance with applicable regulatory requirements.
Potential and real adverse environmental effects associated with the generation of solid and
hazardous wastes will be avoided to the maximum extent possible.
D. Other Releases
Murphy will avoid potential adverse effects, such as the release of hazardous chemicals, by
designing systems and training personnel to:
• reduce the possibility ofleakage of hazardous chemicals;
• minimize the amount of leakage should it occur;
• promptly inform the public and relevant agencies regarding the possible offsite
impacts as required by law; and
• quickly respond to mitigate any adverse effects of the leaks.
6 EDMS Document 40 I 69977 (pg. 269 of 435)

Basis for Decision
AII238,PER20090002
Page 12 of 16
To reduce the possibility of leakage of hazardous chemicals to the environment, Murphy

designed and selected compounds and systems to properly contain hazardous chemicals in
accordance with good engineering practices. Materials of construction will be compatible
with process fluids to prevent failure from corrosion, stress cracking, or fatigue. Periodic
inspections and preventative maintenance of all equipment will be performed to keep all
process and safety systems in optimum operating condition.
No wetlands will be impacted by the permit, as the refinery is an existing facility located in
an industrial area.
CONCLUSION: Accordingly, the LDEQ finds that Meraux Refinery has avoided to the
maximum extent possible adverse environmental impacts without unduly curtailing non-
environmental benefits.
VIII. COSTIBENEFIT ANALYSIS (BALANCING): Does a cost benefit analysis of the

environmental impact costs balanced against the social and economic benefits of the
proposed facility demonstrate that the latter outweighs the former?
As previously stated, the BenFree Project is being undertaken to comply with the U.S.
EP A's MSA T Rule, which requires reductions in certain hazardous air pollutants (here
benzene) from gasoline. The project by itself is a minor modification and mandated by U.S.
EP A. Therefore, an Environmental Assessment Statement (BAS) was not required.
However, LDEQ has evaluated the issue of cost/benefit analysis (balancing) with regard
to the proposed permit. The details of LDEQ's consideration of this issue are provided
below.
A. Environmental Impact Costs
In developing the mandate, U.S. EPA determined that the social and economic
benefits to the public outweigh the cost of implementation borne by each refinery.
In the preamble of the MSA T Rule, the U.S. EPA stateS that mobile sources are a
significant source of benzene exposure to the public. These exposures include
proximity of homes to major roadways, refueling of vehicles, and loading of portable
fuel containers. The agency estimates that, through the implementation of this rule,
public exposure to hydrocarbons, including benzene, l,3-butadiene, formaldehyde,
acetaldehyde, acrolein, and naphthalene,will be reduced by 330,000 tons in 2030,
including 61,000 tons of benzene. 7
7 72 FR 8430, February 26, 2007

Basis for Decision
AI1238,PER20090002
Page 13 of 16
B. Social and Economic Benefits
The BenFree Project is vital to the ongoing business of the Meraux Refinery, as the
reduction on benzene content in gasoline is a regulatory mandate. On the other hand
the economic impact of the refinery is as follows:8
• $282 million in operating and maintenance expenses, including $58.2 million in
labor expenses (wages, benefits, taxes, etc.);
• $275 million in capital expenses;
• $3.88 million in property taxes;
• $1.5 million in sales and use taxes for the Louisiana Department of Revenue;
and
• 0.8 million in sales and use taxes for the St. Bernard Parish Government.
This tax revenue to the state and local government will continue only as long as
Murphy remains a viable business. There will be no increased costs to the
community as a result of the BenFree Project. As determined by U.s. EPA, the
reduced emissions from mobile sources will outweigh any potential negative impacts
at or around the refinery.
CONCLUSION: Based on the reasoning above, the LDEQ finds that the social and
economic benefits outweigh the environmental impact costs.
IX. ENVIRONMENTAL JUSTICE CONSIDERATIONS
EPA's Office of Civil Rights in the Michigan Select Steel Title VI Complaint (EPA File No.
5R-98-R5, The Office of Civil Rights dated October 30, 1998) determined as follows in
"Allegation Regarding Air Quality Impacts," pages 25 and 26:
The environmental laws that EPA and the states administer do not prohibit
pollution outright; rather, they treat some level of pollution as "acceptable"
when pollution sources are regulated under individual, facility-specific,
permits recognizing society's demand for such things as power plants, waste
treatment systems, and manufacturing facilities. In effect, Congress-and,
by extension, society-has made a judgment that some level of pollution and
possible associated risk should be tolerated for the good of all, in order for
Americans to enjoy the benefits of a modem society-to have heat in our
homes, and the products we use to clean dishes or manufacture our wares.
The expectation and belief of the regulators is that, assuming the facilities
comply with their permit limits and terms; the allowed pollution levels are
acceptable and low enough to be protective of the environment and human
health.
8See EDMS Document 40169977 (pg. 272 of 435)

Basis for Decision
AI1238,PER20090002
Page14ofl6
EP A and the states have promulgated a wide series of regulations to

effectuate these protections. Some of these regulations are based on
assessment of public health risks associated with certain levels of pollution
in the ambient environment. The National Ambient Air Quality Standards
established under the Clean Air Act (CAA) are an example of this kind of
health-based ambient standard setting. Air Quality that adheres to such
standards is presumptively protective of public health. Other standards are
"technology-based," requiring installation of pollution control equipment
that has been determined to be appropriate in view of pollution reduction
goals. In the case of hazardous air pollutants under the CAA, EPA sets
technology-based standards for industrial sources of toxic air pollution, the
maximum achievable control technology standards for industrial sources of
toxic air pollution. The maximum achievable control technology standards
under the Clean Air Act are examples of this kind of technology-based
standards; an assessment of the remaining or residual risk is undertaken and
additional controls implemented where needed. [Clean Air Act I
112(f)(2)(A)(1) states " ... If standards promulgated pursuant to subsection
(d) and applicable to a category or subcategory of sources emitting a
pollutant (or pollutants) classifies as a known, probable, or possible human
carcinogen, do not reduce lifetime excess cancer risks to the individual most
exposed to emissions from a source in the category or subcategory to less
than one in a million, the Administrator shall promulgate standards under
this subsection for such category." 42 USe. § 74l2(f)(2)(A)(1).)
Title VI and EPA's implementing regulations set out a requirement

independent of the environmental statutes that all recipients of EPA financial
assistance ensure that they implement their environmental programs in a
manner that does not have discriminatory effect based on' race, color, or
national origin. If recipients of EPA funding are found to have implemented
their EPA-delegated or authorized federal environmental programs in a
manner which distributes the otherwise acceptable residual pollution or other
effects in ways that result in a harmful concentration of those effects in racial
or ethnic communities, then a finding of an adverse disparate impact on
those communities within the meaning of Title VI may, depending on the
circumstance may be appropriate. .
Importantly, to be actionable under Title VI, an impact must be both

"adverse" and "disparate." The determination of whether the distribution of
effects from regulated sources to racial or ethnic communities is "adverse"
within the meaning of Title VI will necessarily turn on the facts and
circumstances of each case and nature of the environmental regulation
designed to afford protection. As the United States Supreme Court stated in
the case of Alexander v. Choate, 469 U.S. 287 (1995), the inquiry for
federal agencies under Title VI is to identify the sort of disparate impacts
upon racial or ethnic groups which constitute "sufficiently significant social
Basis for Decision
AII238,PER20090002
Page 15 of 16
problems, and [are] readily enough remediable, to warrant altering the

practices of the federal grantees that had produced those impacts." Id at 293-
94.
The complaint in this case raises air quality concerns regarding several
NAAQS-covered pollutants, as well as several other pollutants. With respect
to the NAAQS-covered pollutants, EPA believes that where, as here, an air
quality concern is raised regarding a pollutant regulated pursuant to an
ambient, health-based standard, and where the area in question is in
compliance with, and will continue after the operation of the challenged
facility to comply with, that standard, the air quality in the surrounding
community is presumptively protective and emissions of that pollutant
should not be viewed as "adverse" within the meaning of Title VI. By
establishing an ambient, public health threshold, standards like the NAAQS
contemplate multiple source contributions and establish it protective limit on
cumulative emissions that should ordinarily prevent an adverse air quality
impact.
With respect to the pollutants of concern that are not covered by the
NAAQS, Title VI calls for an examination of whether those pollutants have
become so concentrated in a racial or ethnic community that the addition of a
new source will pose a harm to that community. If there is no "adverse"
impact for anyone living in the vicinity of the facility, it is unnecessary to
reach the question of whether the impacts are "disparate."
[Reference: Letter from Ann E. Goode, Director ofEPA's Office of Civil Rights to Father
Phil Schmitter and Sister Joanne Chiaverni, Co-Directors, St. Francis Prayer Center, G-2381
East Carpenter Road, Flint Michigan 48909-7973].
Also note that the United States Supreme Court held in Alexander v. Sandoval (532 U.S.
(2001) [No. 99-1908, decided April 24, 2001] that there is no private cause of action to
enforce Section 602 of Title VI of the Civil Rights Act of 1964, 78 Stat. 252, as amended,
42 U.S.C. §2000d et. seq.
LDEQ accepts the EPA's assessment and reasoning. Emissions associated with the
proposed project, as limited by the terms and conditions of the permit, were reviewed by
the Air Quality Assessment Division to ensure compliance with the NAAQS and Louisiana
AAS for toxic air pollutants. Further, previous screening modeling shows emissions from
facility are not expected to impact air quality so as to cause or contribute exceedances of
the primary or secondary NAAQS or the Louisiana AAS. Accordingly, there will be no
"adverse" and "disparate" impact in the surrounding area.
Basis for Decision
AI1238,PER20090002
Page 16 of 16
x. CONCLUSION
The LDEQ, Office of Environmental Services, Air Permits Division has conducted a review
ofthe information submitted and has determined that the Part 70 (Title V) Operating Permit
should be issued to Murphy Oil USA, Inc. for the construction and operation of the
BenFree Unit at its Meraux Refinery.
The permit will require that the Meraux Refinery's operations meet or exceed the
requirements of all applicable regulations and defined permit conditions. The estimated
emissions from the project are based on conservative engineering design calculations,
manufacturers' guarantees, and established, approved emission factors. The application
details the emission calculations and state and federal regulatory requirements for the air
emISSIon sources.
Emissions from the Meraux Refinery, including the proposed project, will not cause or
contribute to any NAAQS and Louisiana AAS exceedances beyond the industrial property;
therefore, emissions from the refinery will not cause any air quality impacts that will
adversely affect human health or the environment in St. Bernard Parish.
The local economy benefits from the continued operations of the existing refinery. The
proposed modification to the existing refinery will help to sustain the existing positive
aspects, such as providing personal income for the refinery's permanent and contract
employees; increasing the tax revenues for St. Bernard Parish, surrounding parishes, the
State of Louisiana, and the federal government; and facilitating the purchase of goods and
services by the refinery and its employees from other businesses. These benefits are major,
significant, and tangible. They outweigh the environmental impact costs of operation of the
Meraux Refinery.
Based on a careful review and evaluation of the entire administrative record, which includes
the permit application and Emission Inventory Questionnaires (EIQs) submitted February
25, 2009, the proposed permit, and all public comments, the Louisiana Deparhnent of
Environmental Quality, Office of Environmental Services fmds that the Meraux Refinery's
proposed Part 70 permit will comply with all applicable federal and state statutes and
regulations and will comply with the requirements of Save Ourselves v. La. Envtl. Control
Commission, 452 So. 2d 1152, 1157 (La. 1984). Particularly, the LDEQ fmds that the
proposed permit has minimized or avoided potential and real adverse environmental impacts
to the maximum extent possible and that social and economic benefits of the proposed
facility outweigh adverse environmental impacts. Id.
0Aj~
che~l~er Nolan 15~~//1tEl
Assistant Secretary Date
Office of Environmental Services
LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY
OFFICE OF ENVIRONMENTAL SERVICES
PUBLIC COMMENTS RESPONSE SUMMARY
PART 70 OPERATING PERMIT 2500-00001-V5
MERAUX REFINERY
AGENCY INTEREST NO. 1238
MURPHY OIL USA, INC.
MERAUX, ST. BERNARD PARISH, LOUISIANA
Request for public comment and notice of a public hearing on the proposed permit was published
in The Advocate, Baton Rouge, Louisiana; and in The Sf. Bernard Voice, Arabi, Louisiana on
May 29, 2009. The public notice was also mailed and e-mailed to persons included in the LDEQ
mailing list on May 28, 2009. The public hearing was held on July 7, 2009, at the Nunez
Community College Auditorium, 3710 Paris Road, Chalmette, Louisiana. A second public
notice was published in The Advocate, Baton Rouge, Louisiana; and in The St. Bernard Voice,
Arabi, Louisiana on July 17, 2009, to extend the comment period to August 6, 2009, in response
to a request received bye-mail and at the hearing. The comment period and public hearing
afforded the public an opportunity to provide comments on the proposed Part 70 (Title V)
Operating Permit No. 2500-00001-V5.
The permit application, proposed Part 70 Operating Permit, and Statement of Basis (SOB) were
available for review at the LDEQ, Public Records Center, Room 127, 602 North 5th Street, Baton
Rouge, LA. Viewing hours were from 8:00 a.m. to 4:30 p.m., Monday through Friday (except
holidays). The available information could also be accessed electronically on the Electronic
Document Management System (EDMS) on the DEQ publie website at vvww.deg.louisiana.gov.
The proposed air permit and the related SOB were also sent to the U.S. EPA Region 6.
The LDEQ received written and oral comments on the proposed permit at the hearing on July 7,
2009; during the first comment period ending on July 9, 2009; and during the second comment
period ending on August 6, 2009.
This document responds to pertinent statements (questions and/or comments) received regarding the
impact of emissions on air quality. The following public comments, together with the Office of
Environmental Services, Air Permits Division's responses, are relevant to the Part 70 (Title V)
Operating Permit for Murphy Oil USA Ine.'s Meraux Refmery, located in Meraux, 81. Bernard
Parish, Louisiana.
Comments addressing the same issue have been grouped and summarized from the public hearing
transcript and written statements. Documents containing the commenters' complete statements
Response to Public Comments
AII238,PER20090002
Page 2 of39
are located in EDMS.1 The issues have been numbered in this document for reference.
COMMENT NO.1
The proposed permit is a request to cancel the use of a pollution control device for the oil
water stripper (part of an earlier modification to their air permit in 2007), and instead seeks
to use the flare as the pollution control device. This step is backwards towards clean air and
should no be allowed. Murphy Oil must be required to operate under the terms of their
existing air permit modification agreed to when applied for.
Murphy Oil has demonstrated they cannot control what they have now and should not be
allowed to change a previous permit to use the flare as a pollution device.
RESPONSE TO COMMENT NO.1
There was no permit issued in 2007 for controlling emissions from the Oily Water Stripper (OWS).
Murphy proposed in Part 70 Operating Permit No. 2500-00001-V4 to route the existing Oily
Water Stripper vent stream, at that time being routed to the North Flare, Emission Point 20-72, to
the fuel gas system. Murphy has decided not to move forward with this project, and the Oily
Water Stripper vent stream will continue to be routed to the North Flare. There is no change in
the current status of the OWS.2 The OWS is subject to the control requirements of 40 CFR 61,
Subpart FF.
COMMENT NO.2
Murphy Oil's proposed permit will also emit more toxic air pollutants int [sic] an area which
is already subjected to intolerable levels of different chemical odors. LA DEQ must require
Murphy to install the best available pollution control technology in order to protect the
community's air and not undermine protection of public health. Last week the smell was so
bad on East Judge Perez Drive as you passed the refinery it burned your throat and nose.
We recently moved away from Murphy Oil because the smell was so bad, at times, we
could not go outside. We noticed the smell was associated with the flaring. The disturbing
noise and vibrations for Murphy would rattle the windows in my home, the ground would
vibrate, and I would hear cracking in the walls. The noise was so bad it sounded like we
live inside an airport. Sometimes we couldn't even hear our TV and it would wake us up at
night. Now, at the new house there are still days when we are effected [sic] by the burnt
rubber and other obnoxious chemical smells from the refinery and I can still hear the noise
when I am outside even living 8 blocks away.3
I EDMS stands for Electronic Document Management System, the LDEQ's electronic repository of official records
that have been created or received by LDEQ. Employees and members of the public can search and retrieve
documents stored in the EDMS via this web application. (See http://edms.deq.louisiana.gov/app/doc/querydef.aspx).
2 See EDMS Document 39426921
AI1238,PER20090002
Page 3 of39
The air quality in the fence line neighborhood is so poor at times that residents shelter
themselves in place or hold their noses when they are on the roads that pass through the
Murphy Oil facility.4
Regarding public health, see LDEQ's Response to Comment No. 21.
Regarding pollution control technology, the Part 70 (Title V) permit meets all applicable federal and
state regulations. Emissions from the projects will be controlled as required by applicable
regulations, such as LAC 33 :III.Chapters 11, 13, 15, 21, 56, 59; New Source Performance Standards
(NSPS) under 40 CFR 60; National Emission Standards under 40 CFR 61; and the Maximum
Achievable Control Technology (MACT) requirements of LAC 33 :III.Chapter 51 and the National
Emission Standards for Hazardous Air Pollutants under 40 CFR 63. The permit limits have been
determined to be acceptable and protective of the environment.
Prior to the start of the St. Bernard Air Monitoring Project in May 2006, LDEQ received and
investigated numerous odor complaints from citizens living in the Chalmette, Louisiana area. At
the request of the local citizens and through negotiation with the Chalmette Refinery, an
Administrative Order on Consent was signed on May 24, 2005. Under the terms of the Order,
the refinery installed fixed ambient monitors at three locations designed in accordance with
department directives as shown in Figure 1. Two of these sites, Chalmette High School and
Chalmette Vista, are in St. Bernard Parish and the third one, Algiers Entergy, is located across
the Mississippi River in Orleans Parish.
The primary purpose of this project was to investigate what caused odors, if odor causing
compounds are air toxic and if their concentrations in the ambient air in the Chalmette area are in
compliance with the state and federal ambient air quality standards. In addition, the DEQ was
fully to use its facilities to monitor for ozone and fine particulate matter PM25 and investigate
other compounds such as benzene and 1, 3-butadiene that cause no odors at lower
concentrations, but are of great health concern for long time exposure even in lower
concentrati ons.
Odors can be caused by a single chemical compound or by a combination of compounds. Some

odor causing chemicals such as hydrogen sulfide and carbon disulfide are air toxics and
regulated either by the U. S. Environmental Protection Agency (EP A) and/or by LDEQ. Other
odor-causing chemicals are not air toxic or not a health concern in moderate concentrations.
Nearly all state and federal. air quality regulations are based on health impacts because
compounds that pose known health risks are a more imminent concern to public welfare than
those that are solely an odor issue. Although an odor may be offensive to a particular individual,

AI1238,PER20090002
Page 4 of39
it is more scientifically justifiable to establish limits based on the protection of public health than
to try to establish more subjective odor standards. People can have markedly different
perceptions about the magnitude and offensiveness of an odor. Although research is being
conducted nationally on developing techniques to measure odors, LDEQ does not believe current
methods are precise.
LDEQ investigates odor complaints received from the public and uses ambient air data collected
at the monitoring stations to make compliance determinations. Permit limits and upset releases
are also evaluated during these investigations.5
LDEQ does not regulate noise, but understands that Murphy monitors the fenceline to demonstrate
compliance with the S1. Bernard Parish ordinance requiring noises to be less than 65 decibel (db)
between 10:00 p.m. and 7:00 a.m. Murphy sometimes detects a low frequency, low db noise in the
two blocks immediately to the west of the refinery. The noise is due to cavitation, resulting from
the installation of ultra-low NOx burners in Boilers B-5 and B-6 in December 2008. With the help
of the boiler manufacturer, Murphy conducted the recommended modifications as expeditiously as
possible, including the strengthening of the boiler ductwork and burner adjustments. Murphy is
monitoring the situation closely to avoid any noise problems to the maximmn extent possible.
COMMENT NO.3
I am sending this letter about the Murphy Oil Reference AI# 1238 Permit 2500-0001-V5
Activity PER2009002 how the refinery effects our quality of life the odor-fume, fire big
trucks broken streets lighting. If and when we may have to evacuate6
Regarding odors, see LDEQ's Response to Comment NO.2. The issues of big trucks and broken
streets are not under the jurisdiction ofLDEQ.
COMMENT NO.4
I have been living in close proXImIty to the refinery since hurricane Katrina. On
numerous occasions I have experienced foul odors, burning eyes and nostrils, catalyist
[sic] fallout, large plumes of smoke and the noise being emitted. There are times when
one is a prisoner inside your own home. You carmot be outside enjoying your own
property because of the odors present. Forbid you if you have a window or door open. It
trespasses into your home. It has been a nuisance for some time now. Now the gov. is
requiring the removal of these toxins at the refineries so they are not spewed out of
vehicles throughout the country. So now what happens is that it is concentrated to the
areas surrounding the refinieries [sic] and released into the atmosphere increasing the
5 St. Bernard Air Monitoring Project Final Report, July 30, 2009
AI1238,PER20090002
Page 5 of39
amount every living breathes. Where is the logic? They are asking for a permit for
something that they have been doing for years without one. Laws have been in place for
sometime now and they were not followed or enforced. Just like the unit which dries the
sludge. Installed and operated without a permit. My belief is that the DEQ was created
to protect the environment and not big business. There is technology out there to address
the problems which are occurring but it takes money which they won't spend until forced
to do so. It takes away from the bottom line [profits]. . They 'should be forced to clean
their act up first before any expansions are allowed. It is rumored they might be putting
in coker unit in the future. More foul odors and dust for the residents to deal with. So I
am asking for your assistance to clean up the air we have to breathe and not make it more
toxic for the residents residing along their fence lines. There are times it feels like
someone or something removed the oxygen from the air. Some odors can be described
and some carmot. Any help would be appreciated. 7
Regarding odors, see LDEQ's Response to Comment NO.2.
Regarding the Meraux Refinery's sludge management unit, see LDEQ's Response to Comment
No. 25.
The EPA has considered the potential negative environmental impacts at refinery locations and
has promulgated the Mobile Source Air Toxics (MSA T) Rule to reduce benzene in the produced
gasoline at the refineries.8 The BenFree project is being undertaken to comply with this rule,
which will reduce toxic emissions from the vehicles operated in and around 8t. Bernard Parish.
In the BenFree Unit, benzene will be converted to cyclohexane, which will ultimately be blended
into gasoline. Benzene removed from the gasoline will not be emitted to the atmosphere.
Overall emissions from the Meraux Refinery have been reduced considerably due to the
implementation and enforcement of the environmental laws in place. The table shown below
reflects the reductions in potential emissions achieved at the refinery over the past 13 years.9
Permitted Emissions Permitted Emissions

Permit No. 2500-00001-06 Permit No. 2500-00001-V4
Pollutant (2/7/1996) (1/15/2009) Change
PM 10 320.00 206.40 - 113.60
802 2251.30 684.49 -1566.81
NOx 1972.10 1220.06 - 752.04
CO 22,509.50 1960.70 - 20,548.80
VOC 1781.20 600.30 - 1180.90
7 See EDMS Documents 42229896 & 42229884

8 72 FR 8428, February 26, 2007
9 See EDMS Documents 27180314 & 39426921
AII238,PER20090002
Page 60f39
COMMENT NO.5
I am again writing you about Murphy oil Meraux they are at it again with more ways to
pollute or [sic] air in our neighborhood!! Murphy Oil has applied for another
modification to their air permits to construct a benzene saturation unit so the Meraux
refinery can adhere to new EPA mandates for lower benzene in gasoline products.
However, the proposed permit seeks to cancel use of a pollution control device for the
oily water stripper (part of an earlier modification to their air permit in 2007). This oily
water stripper vent stream is rich in H2S.
Murphy seeks to use the flare instead. This is a step backwards towards clean air and
should not be allowed. Murphy Oil must operate under the 'terms of their existing air
permits agreed to when applied for, or reopen the permits!"IO
Murphy has demonstrated they cannot control what they have now and should not be
allowed to change a previous permit to use the flare as a pollution control device. II
On a meeting we had with our niighborhood [sic] association, the parish and Carl Zornes
from Murphy Mr Zornes told us and the parish officals [sic] that they already had a
permit from the DEQ we caled [sic] the same day and they said they did not have one!
We are wondering why don't the DEQ stop them from continuing from building at once!
I
This is the second time am writing you and have not received a single word from you! I
would really like to hear something from you this time!!! 12
Regarding the Oily Water Stripper vent stream, please see LDEQ's Response to Comment No.1.
Murphy did not commence construction of any project addressed in Permit No. 2500-00001- V 5
prior to issuance of the permit. LDEQ responds to comments from the public at the time a final
decision is made, not upon receipt of a public comment.
COMMENT NO.6
On behalf of CCAM, Tulane Environmental Law Clinic requested LA DEQ provide the
information on which Murphy Oil or LA DEQ based its emission calculation for the
proposed permit modification. Without that information, it is difficult, if not impossible,
10 See EDMS Documents 42220250, 42395018, and 42557391

AI1238,PER20090002
Page 7 of39
to comment on PSD review and BACT applicability without seeing the basis of the
emissions calculations.l3
As stated above, the permit application, Statement of Basis, proposed permit, and associated
documents were available for review at the local library and on DEQ's website. The calculations
for the BenFree Unit and the PSD analysis are documented in Appendix D of the permit
application (volume 2), dated February 2009.
Estimated emission increases due to the BFU Project, based on baseline actual emissions to
potential emissions in tons per year, are shown in the following table: 14
Baseline58.73
Emissions*
35.48
16.09
2.10
2.30
6.52
28.95
16.27
4.34
Emissions
Actual
52.98
Post Project BFU Project PSDDe
Increases** Minimis
2.04 15
26.85 40
9.75 40
23.25 100
36.89 40
Emissions increases due to the project are insignificant. Therefore, PSD review (netting) is not
required.
*Existing emISSIOns originate from the Cooling Tower and North Flare. For new sources,
baseline actual emissions equal zero.
**The "BFU Project Increases" represent increases without respect to decreases.
The information in the application is sufficient to duplicate the calculations and document the
non-applicability of the PSD program.15 See also LDEQ's Response to Comment Nos. 19 and
20.
COMMENT NO.7
I write on behalf of our client, Concerned Citizens Around Murphy (CCAM), requesting
that Louisiana department of Environmental Quality extend the public comment period

14 Includes EPNs 1-09,4-00,20-72,300-4, 300-6A, 300-3A, 250-8, T-5, 1-3A, 80-5A, 80-9, 80-10A, BFU
turnaround emissions, and fugitives.
15 See EDMS Documents 40127062,40169977, and 42374352
AI1238,PER20090002
Page 80f39
on the proposed modified Part 70/Title V air operation permit for Murphy Oil Meraux
Refinery for at least 20 days. We request this extension because the neither the materials
associated with the proposed permit, nor the application materials or any other publically
available documents provide the information on which Murphy Oil or LDEQ based its
emission calculations for the modification-i.e., the BenFree Unit. Instead, the application
materials state that Murphy Oil based the emission calculations "personal communication
email[s]" and "personal communication phone conversation[s]" between Murphy Oil
employees and Murphy Oil's consultant between 2004 and sometime within the last year.
One example (and there are many) is as follows: "The annual emissions rates for NOx
and sax are based on an email from Lee Vail (Murphy) to Valerie Barth (Trinity) on
February 27.2007.,,16
The request for the extension of comment period was granted for 30 days instead of 20 days, as
requested.
As for the comment regarding the "personal communication email[ s]" and "personal
communication phone conversation[ s]," these references appear in the footnotes in Appendix D
(calculation section) of the permit application. These footnotes were created to record
correspondence between Murphy and Trinity Consultants, the firm which assisted Murphy in
preparing its application. These footnotes were simply carried forward from previous
applications. The specific footnote referenced relates to the reduction of NOx and sax
emissions from the NO.2 Fluid Catalytic Cracking Unit (FCCU); this project is not addressed in
the current modification (BenFree Project).
See also LDEQ's Response to Comment No. 20.
COMMENT NO.8
Throughout the recent past, hot boiler leaks have been a source of ear-splitting noise.
Boiler No. 5 has been a source of exceedingly high noise levels and has caused entire
houses to shake, which has on some occasions cracked sheetrock. What alternatives has
Murphy examined to siting the new boiler NO.7 so that it does not cause further damage
to our homes. 17
. RESPONSE TO COMMENT NO.8
The hot boiler leaks referred in the comment concern Boilers NO.5 and NO.6, which were
modified with ultra-low NOx burners in an ongoing effort to reduce NOx emissions. The noise
problem was analyzed, and it was determined that ducting vibration, burners, and forced draft
J6 See EDMS Document 42088733

17 See EDMS Documents 40127062, 40169977, and 42374352
AJ 1238,PER20090002
Page 9 of39
fans were the cause. Both Boilers NO.5 and No.6 were taken out of service and remedial
actions have been undertaken to solve the problem.
As for Boiler No.7, Murphy is not actually adding a new boiler, but permitting an existing boiler
that has in the past been used only when required to meet the steam demands of the facility.
Boiler No.7, when needed, was operated under the terms and conditions of a yariance.
However, LDEQ's position is that while a variance may be justified in emergencies, this
mechanism is no longer appropriate to address operation of this source. With this modification,
Murphy is adding Boiler No. 7 as a permanent source. This project is independent of the
BenFree Project.
Murphy investigated the complaints regarding vibration and "shake" and found that only two
houses had some very minor cracks that could not be directly associated to the vibrations or
"shake" caused by the refinery. Murphy informs LDEQ that the residents were offered
assistance with repairs, but the offer was rejected by the residents.
COMMENT NO.9
1. THE NETTING ANALYSIS FAILS TO INCLUDE THE FOLLOWING

EMISSION SOURCES.
A. Emergency Flaring Emissions.
The netting calculations included routine releases to the North Flare from the new
BenFree Unit. These vent releases occur about five times a year with each incident
lasting 30 minutes. Exh. 2, footnote 11. According to the permit engineer and our
understanding of the process, these venting emissions are part of the normal operation of
the BenFree Unit. The netting calculations did not include emergency release emissions
due to malfunctions at the BenFree Unit for any subject pollutant.
Louisiana air regulations require Murphy Oil to include emergency flaring emissions in
the netting analysis for all regulated pollutants. The regulations specifically require
Murphy Oil to include emergency emissions for calculating both "Baseline Actual
emission" and Projected Annual Emissions." See LAC 33:III.llI (definition for
"Baseline Actual Emissions" and "Projected Annual Emissions" require inclusion of
authorized emissions associated with start-ups, shutdowns, and malfunctions) (emphasis
added). See also, id. (definition of "Malfunction" - "any sudden and unavoidable failure
of air pollution control equipment or process equipment or of process to operate in a
normal or usual manner.,,).18
The primary purpose of the flare is to handle "emergency" releases which are not planned
or anticipated for safety reasons, e.g., to relieve pressure inside vessels to prevent
18 See EDMS Document 42539789 (pg. 3)

AII238,PER20090002
Page 100f39
explosion. These emergency releases occur when there are process and other types of
malfunctions. The most severe emergency releases usually occur during power outages.
The emissions from these events were not included in the netting analysis. LDEQ must
require Murphy Oil to supplement its Application with emergency release emissions data
and republish the draft permit for public comment with the updated information.
The reference to the definition of "baseline actual emissions" and "projected actual emissions" is
erroneously stated as LAC 33:III.ll1. These terms are found in LAC 33:III.509.B. Both
definitions state that the rates "shall include fugitive emissions to the extent quantifiable, and
authorized emissions associated with startups, shutdowns, and malfunctions" (emphasis added).
LDEQ does not permit or authorize emissions resulting from malfunctions. Such emissions must
be reported as deviations and are subject to enforcement action.
Further, because "emergency releases" are not permitted, excluding such emiSSIOns from a
netting analysis is consistent with federal and state PSD regulations. When calculating baseline
actual emissions, both federal and state rules require the average rate to be adjusted downward to
exclude any non-compliant emissions that occurred while the source was operating above any
emission liinitation that was legally enforceable during the consecutive 24-month period.
LDEQ has further discussed use of the word "malfunctions" in the definitions of "baseline actual
emissions" and "projected actual emissions"in the Louisiana Guidance for Air Permitting
Actions. 19
COMMENT NO. 10
B. Updated Facility-wide Turnaround Emissions and NO.2 Amine Unit Turnaround.
The proposed permit covers the "reconciliation" of turnaround emissions for facility wide
turnaround or startup/shutdown emissions, changing current one-year startup/shutdown
emissions to a yearly estimate based on five year emission total. 2/09 Ap., pp. 2-3;
Briefing Sheet, p. 9. In addition, the proposed permit includes No. 2 Amine Unit
turnaround or startup/shutdown emissions. However, the netting analysis does not
include these emissions because "the turnaround and startup/shutdown emissions are not
subject to New Source Review as they are existing emissions and no new modification is
triggering an increase in the associated emissions. Air Permit Briefing Sheet, pp 9-10, p.
9 note (**). There are three major problems with the treatment of these emissions.
First, the increase in S02 emissions due to these reconciliation issues, 40.53 ton/yr,
exceeds the PSD significance threshold for S02 by themselves. Thus, regardless of how
LDEQ classifies them, the resulting increases are a significant PSD modification
19 Available at http://www.deq.louisiana.gov/portaVtabid/64/Default.aspx
AI1238,PER20090002
Page II of39
triggering PSD review.
Second, these emissions are not "existing" as they are projections of future emissions
over the term of the Title V permit. A portion of them, for example, include startup,
shutdown, and turnaround emissions from the new BenFree Unit.
Third, as discussed above, Louisiana air regulations require Murphy Oil to include
startup, shutdown, and turnaround emissions in the potential to emit for purposes of
determining NSR applicability. The fact that Murphy Oil has not included these
emissions in prior NSR analyses for this facility is contrary to the law.2o
RESPONSE TO COMMENT NO. 10
Permit No. 2500-00001-V2, dated November 20, 2007, included startup and shutdown
emissions. As referenced in the proposed permit,21 these emissions were based on an arumal
period (i.e., 12 calendar months). With this modification, LDEQ proposes to permit these same
emissions as a five year total to give the facility some flexibility in performing turnarounds
dictated by consumer demand, production, and operational flexibility. The overall emissions
permitted for startup/shutdown, Emission Point TRND, represent a five year total. See the
"Specific Requirements" section in the proposed permit under EQT0095. The PSD analysis
considers maximum emissions allowed for on an annual basis.
Murphy did determine that startup/shutdown emissions from the existing NO.2 Amine Unit were
inadvertently omitted from previous estimat~s. However, the contribution from the NO.2 Amine
Unit turnaround (startup/shutdown) emissions to the overall facility startup/shutdown emissions
is negligible on an annual basis as shown below:22
Startup/Shutdown Emissions
Pollutant (tons/5 years)
PMIO <0.01
NOx 0.03
CO 0.] 7
VOC 0.49
As stated above, the startup/shutdown emissions for the facility are existing emissions, and the
inclusion of the NO.2 Amine Unit turnaround emissions do not contribute to any increase related
to a modification (a physical change or change in method of operation). These emissions are a
result of the reconciliation of the overall existing startup/shutdown emissions for the facility.
Therefore, the increase does not trigger PSD review. The facility has been reporting such
emissions under startup/shutdown in its Emissions Inventory (LAC 33 :III.919) reporting.
20 See EDMS Document 42539789 (pg. 3)

21 See EDMS Document41456805, Briefmg Sheet pp. 9 (**)
22 See EDMS Document 41458096, Appendix D - Refinery Turnaround Emission Summary (Table)
AII238,PER20090002
Page 12 of39
The startup/shutdown emissions for the BenFree Unit were included in the netting analysis.23
COMMENT NO. 11
D?4 Boiler 7
The Applicant submitted an addendum to the 2/09 Application, requesting that emissions
from a temporary boiler formerly used during planned maintenance activities be
permitted and included in the Title V operating permit as Boiler B-7. As some portion of
the increase will service the new BenFree Unit, LDEQ must require the netting analysis
to include that portion of these emissions?5
See LDEQ's Response to Comment No.8. Boiler NO.7 does not and will not service the new
BenFree Unit. Moreover, the BenFree Reboiler does not require any steam because it is fired
with refinery fuel gas. Therefore, LDEQ did not include any portion of the emissions from the
boiler in the PSD analysis associated with the BenFree Project.
COMMENT NO. 12
E. Hydrogen Generation
The Project includes a new 27,000 BPD BenFree Unit. This unit, licensed technology of
Axens, will use hydrogen and a fixed bed catalyst to convert Platform ate benzene into
cyclohexane. The Application incorrectly suggests that it will use hydrogen as a fuel in
the reboiler (Ap., p. 4) and fails to recognize that hydrogen is one of the inputs to the
process itself. The netting analysis did include increases in cooling tower emissions from
increases in cooling water, another input to the BenFree Unit. Ap., p. 2 and Exh. 3.
Hydrogen production generates emissions of NOx, SOx, CO, PM10, and VOC that
Murphy Oil did not include in netting analysis. However, Murphy Oil must include
emissions that result from the hydrogen production if: 1. the entity that produces the
hydrogen shares a boundary with Murphy Oil, 2. shares -common control, or 3. if the
entity the produces the hydrogen sends more than 50 percent of the hydrogen it produces
to Murphy Oil. Concerned Citizens Around Murphy asks LDEQ to investigate all three
of these issues and provide answers in its response to comments.
Furthermore, the Application does not contain any of the BenFree process information
required to estimate the amount of hydrogen that would be required, or the increase in
23 See EDMS Document 41458096, Appendix D - Calculations, Emission Point North Flare (20-72), footnote II
24 Note that there is no Item "C" in the Comments Document.
AI1238,PER20090002
Page 13 of39
emISSIons from this increase in hydrogen production. Concerned Citizens Around

Murphy also asks LDEQ to provide determine the amount of hydrogen required and
increased emissions from the hydrogen production.26
It is correct that the BenFree unit is a licensed technology ofAxens. The hydrogen used by the
BenFree Unit will conservatively be 8.4 MM standard cubic feet (scf) per day. Hydrogen will be
imported from Air Products, which does not share a boundary with Murphy and is a wholly
separate entity. Thus, the two sites are not under common control. Further, Murphy does not
import more than 50 percent of Air Products' hydrogen production. Also, the Air Products New
Orleans facility producing the hydrogen is located in the Almonaster Industrial District in
Orleans Parish, not in St. Bernard Parish. For the location, see Agency Interest No. 2062, EDMS
Document 39396270, page ] 8. Therefore, the emissions due to the increased utilization of
hydrogen for the BenFree Unit were not and should not be included in the netting analysis
associated with the BenFree Project.
COMMENT NO. 13
II. THE PROJECT TRIGGERS NSR REVIEW FOR SULFUR DIOXIDE AND
VOLITILE ORGANIC COMPOUNDS.
A. Murphy Oil Underestimated Sulfur Dioxide Emissions.
Murphy Oil's netting analysis concluded that the project would increase emissions of
sulfur dioxide ("S02") by 26.85 ton/yr, which is less than the PSD significance threshold
of 40 ton/yr. Briefing Sheet, p. 9 (LDEQ-EDMS Doc. 4]456805, p. 13 of 786). S02
emission sources include: (l) the reboiler in the BenFree Unit; (2) the North Flare to
which the BenFree Unit vents; and (3) Boiler B-7. Ap., Appx. D.
As a preliminary matter, Murphy Oil improperly excluded emissions from Boiler B-7 in
its netting calculations, which we explain in section II below.
In addition, Murphy Oil incorrectly based S02 emissions ·calculations solely on the H2S
content of combusted gas. 7/7/09 Quadri Email; Ap., p. 1 (fuel gas monitored by H2S
CEMS), Appx. D, Emission Calculations, North Flare, footnote 7 (H2S content is 159
ppmv); Ap., Appx. F, 10/8/08 Bourgeois Letter (requiring only monitoring of H2S in
flare vent gases). Because H2S is not the only sulfur compound found in refinery fuel
gas, Murphy Oil has significantly underestimated the S02 emissions.
The combustion process converts essentially 100% of the sulfur in a fuel gas to S02.
Thus, Murphy Oil should have calculated the S02 emissions from fuel sulfur content

AII238,PER20090002
Page 14 of39
based on total sulfur in the fuel, not just H2S. Additional sulfur compounds include
mercaptans and oxidized sulfur compounds, such as thiophenes and carbonyl sulfide.
These other compounds make up most of th~ sulfur that is present in refinery fuel gas,
generally well over half of the total sulfur. Thus, assuming that LDEQ is correct as to
how Murphy Oil calculated the S02 emissions factor, the netting analysis has
significantly underestimated S02 emissions. Nearly all of the S02 emissions from the
project arise from burning refinery fuel gas in either the reboiler, Boiler B-7 (erroneously
excluded), or the North Flare. The unaccounted for sulfur in the refinery fuel gas is at
least double the claimed S02 emissions, pushing the project's S02 emissions over the
PSD significance threshold, thus triggering NSR review for S02. The reported S02
increase is 26.85 ton/yr. Adopting the reasonable and conservative assumption that total
sulfur is double LDEQ's calculation based on only H2S, S02 emissions rise to 53.7
ton/yr, which exceeds the 40 ton/yr significance threshold.
Regarding Boiler No.7, see LDEQ's Response to Comment Nos. 8 and 11.
Murphy complies with the requirements of 40 CFR 60, Subpart J - Standards of Performance for
Petroleum Refineries. 40 CFR 60.104 - Standards for Sulfur Oxides requires the refinery to
limit the H2S content of fuel gas burned in fuel gas combustion devices. The facility maintains
the H2S concentration in the refinery fuel gas at 0.10 gr/dscf27 or less as required by 40 CFR
60. 104(a) (1) and monitors H2S continuously as required by 40 CFR 60. 105(a)(4).
The emissions calculations were conducted using the maximum H2S limit of 0.10 gr/dscf. The
resultant emission factor for S02, again based on the NSPS limit for H2S, is 0.0296 lb/MM BTU,
derived as follows:
(0.10 gr H2S/dscf)*(l Ib/7000 gr)*(l scf/909.1 BTU)*(l0/\6) = 0.0157 lb H2S/MM BTU

Converting to S02: 0.0157 * (64/34) = 0.0296 lb S02/MM BTU
The BTU value of the refinery fuel gas is stated in the Appendix D - Emissions Calculation of
the Application.
The conservative H2S limit of 160 ppmv takes into account the other sulfur compounds'
contribution to the formation of S02. The reported S02 emissions increase of 26.85 tons/yr due
to the inclusion of Ben Free Unit is quantifiable and justified.
Use of the 160 ppmv factor for H2S in estimating S02 emissions is conservative in Murphy Oil's
case as the average H2S emissions monitored by Murphy Oil have been less than 40 ppmv over
the past year. EPA data contained in the rulemaking record for the NSPS Ja rule indicated that
27 Converts to ~ 160 ppm

AII238,PER20090002
Page 15 of39
sulfur compounds are expected to exist in the fuel gas of refineries that do not have coker units at
only a fraction of the concentrations of H2S. In a response to comment on that issue, EPA stated:
"Our data indicate that non-H2S sulfur compounds are only a very small fraction
of the total sulfur content of fuel gas streams produced by units other than the
coking unit. The commenter provided no data to support that other gas streams
contain appreciable concentrations of non-H2S sulfur compoUnds. Based on the
data available, we cannot justify the expense of replacing all existing monitors,
and we can only estimate the costs and emission reductions of reducing TRS from
fuel gas generated by coking units. Weare interested in determining the total
amount of sulfur emissions from fuel gas combustion devices and are considering
the best way to obtain accurate measurements outside of these NSPS.,,28
As the Murphy Oil refinery does not have a coker, the non-H2S sulfur compounds are expected
to be only a fraction of the total sulfur content of the fuel gas streams and would make no
material difference to the S02 estimated emissions.
As explained in the Appendix E of the application,29 Murphy monitors H2S content in the North
Flare gases via gas chromatograph on weekdays and supplements that data with Drager tube
sampling on weekends. Murphy calculates S02 emissions at the North Flare, Emission Point 20-
72, using the H2S content results and the flue gas flow metering system.
COMMENT NO. 14
B. Netting Analysis Underestimates Volatile Organic Compound Emissions.
The netting analysis concluded that the project would increase emissions of volatile
organic compounds ("VOCs") by 37.22 ton/yr, which is just 2.78 ton/yr shy of the PSD
significance threshold of 40 ton/yr. Briefing Sheet, p. 9 (LDEQ-EDMS Doc. 41456805,
p. 13 of 786). As demonstrated below, the netting analysis underestimated flaring
emissions and excluded several sources ofVOC emissions.
J. Routine Flaring Emissions
The netting analysis includes emissions from routine flaring. Routine flaring emissions
include emissions from burning flare pilot gas, flare sweep gas (for purging the flare
system), and BenFree vent gases. Murphy Oil calculated the increase in flaring VOC
emissions due to the project (0.44 ton/yr) as the difference between projected future
28 Response to comments at 27, Standards of Performance for Petroleum Refineries, Background Information for
Final Standards, Summary of Public Comments and Responses, April 2008. See also MEMORANDUM TO:
Petroleum Refinery NSPS Docket No. EPA-HQ-OAR-2007-0011, FROM: Bob Lucas, EPA/SPPD, DATE:
November 18, 2008, SUBJECT: Documentation of Revised Flare Recovery and Fuel Gas System Impact
Estimates.
AI1238,PER20090002
Page 160[39
flaring emissions (13.860 ton/yr) and baseline flaring emissions (13.420 ton/yr). See
Application, Appendix C, Table 1, attached here as Exh. 3. This small increase, 0.44
ton/yr, is gross underestimate. The estimated increase in routine flaring emissions is
wrong because Murphy calculated its projected future flaring emissions using an
emission factor that does not apply to flaring of refinery fuel gases. When the project
future emissions are estimated using the more accurate Ideal Gas Law, the resulting
increase in emission is to exceed the PSD significance threshold of 40 ton/yr.
VOC emissions were calculated using the emission factor set forth in AP-42, Section 13.5 -
Industrial Flares. AP-42 emissions factors have been utilized to develop emissions estimates in
the past, and the same emission factors were utilized for flares in the Consent Decrees issued by
U.S. EPA to the major refineries across the United States.
Regarding use of the Ideal Gas Law, LDEQ does not dispute that such is a viable method for
calculating emissions. However, what the commenter fails to consider is that if potential and
projected actual emissions are calculated using the Ideal Gas Law, then baseline actual emissions
should also be calculated using the Ideal Gas Law.
See also LDEQ's Response to Comment No. 15.
COMMENT NO. 15
(a) Murphy Oil Used Wrong Emission Factor Used to Calculate Project Flaring
Emissions.
Murphy Oil based its baseline emissions on permitted emissions, since actual emissions
exceeded permitted limits, i.e., actual emissions violated existing permit limits. Exh. 3,
footnote 3. This is correct - a permit applicant cannot avoid significance levels by
claiming credit emissions that violate legal limits. However, Murphy Oil calculated the
projected future flaring emissions from an emission factor that does not apply to flares
that bum refinery fuel gas streams.
Murphy Oil estimated projected future flaring VOC emissions using the AP-42 emission
factor for flares of 0.16 Ib/Moto and an assumed maximum heat input of 20.0 Motolhr.
Ap. Appx. D, Emissions Calculations, North Flare, Footnote 11 (Exh.2).3° This emission
factor underestimates routine flaring VOC emissions because it does not take into
account the specific fuel that Murphy Oil will bum. EPA developed the flare AP-42
emission factor from tests in which a mixture of propylene and propane was burned.31
The gases sent to the North Flare are not similar to this mixture.
30 See EDMS Document 42539789, footnote 5

AI 1238, PER20090002
Page 17 of39
The Application indicates that the fuels that Murphy Oil will burn in the North Flare are
natural gas (15.2 Moto/hr) and vent gases (4.8 Moto/hr). Ap. EIQ, North Flare. Natural
gas is nearly 100% methane and contains very little propylene and propane. The
Application does not disclose the composition of vent gas beyond indicating that it is
mostly refinery fuel gas. Exh. 2. However, composition data for other refinery fuel
gases indicates that it also contains very little propylene and propane.
Thus, the fuel mixture burned by the North Flare are not similar to a mixture of propylene
and propane, the mixture assumed by the AP-42 emission factor used in the netting
calculations. VOC emissions from burning a fuel gas depend upon the composition of
the gas, specifically, the molecular weight of the gas. Thus, the AP-42 emission factor
relied on in the Application is not accurate for routine flaring emissions.
(b) Revised Projected Future Flaring Emissions
A more accurate and direct method of calculating VOC emissions is the Ideal Gas Law.
The Ideal Gas Law is a fundamental statement of the relationship among the pressure,
temperature, volume, and number of molecules in a mole of gas. It is one of the most
commonly used methods to estimate VOC emissions from flares. The Texas
Commission on Environmental Quality (TCEQ), for example, has published New Source
Review emission calculation procedures to determine VOC emissions from flaring. The
TCEQ guidance is widely used in the refinery industry to calculate VOC emissions from
flaring.
Using the Ideal Gas Law consistent with TCEQ's guidance and the preponderance of
evidence, VOC emissions are calculated from the molecular weight of the flared gas and
the flare VOC destruction efficiency. The VOC destruction efficiency is the percent of
the VOCs in the gases sent to the flare that is burned to CO2 and water. The standard
destruction efficiency used in flaring calculations is 98%. The molecular weight for
refinery fuel gases typically ranges from 15 to 30 lb/lb-moI. A molecular weight of 16
corresponds to pure methane and the midpoint of this range corresponds to a typical
refinery fuel gas such as that vented to the North Flare.
The resulting calculations in indicate that future VOC emissions are 55.11 ton/yr for pilot
and purge gases and 24.72 ton/yr for vent gases. The total VOC emissions from
projected future flaring are thus 79.83 ton/yr ton/yr [sic). The resulting increase in VOC
emissions due to the modifications, from 13.42 ton/yr (Exh. 1) to 79.83 ton/yr, is 66.4
tons/yr. This increase is sufficient by itself to cause the project net increase in emissions
to exceed the PSD significance threshold of 40 ton/yr. Thus, the project triggers NSR
review for VOCs.
The above calculations assume that flare destruction efficiency never goes below 98
percent on average for the lifetime of the project. But this is will not be the result under
AII238,PER20090002
Page 18 of39
actual conditions. If flare combustion efficiency drops to 95 percent on average, Murphy

Oil will emit 5 percent of VOCs in the flared gases, and VOC emissions will be 2.5 times
higher that at 98 percent efficiency. Destruction efficiency will, more likely than not, go
far lower, causing VOC emissions to increase drastically.
For example, the VOC destruction efficiency drops significantly when crosswinds are
greater than 5 mph. The average annual wind speed in the vicinity of the Meraux
Refinery is 8.2 mph. As significant crosswinds, i.e., greater than 5 mph, are usually
present in this area, LDEQ must account for these wind effects in estimating flaring
emissions. Further, as Murphy Oil reduces Btu content of the flare gas, it will also
reduce its combustion efficiency. Recent studies have suggested that lower Btu flares
may have efficiencies as low as 65 percent. The Btu content of refinery fuel gases sent to
the North Flare can vary widely. Thus, our estimate of the increase in emissions from
routine flaring is very conservative. Actual emissions could be substantially higher.
See LDEQ's Response to Comment No. 14. Regarding flare efficiencies, the TCEQ guidance
referenced by the commenter contemplates "applying 98 percent destruction efficiency for
butane+ and hydrogen, and 99 percent destruction efficiency for propylene, propane, ethylene,
and ammonia."
Only a small portion of the VOC increase is due to flaring emissions (~ 0.5 TPY). Thus, if a
flare efficiency of 98% was assumed, uncontrolled emissions would be 25 TPY (0.5 TPY / 0.02).
Even if one applied a control efficiency of 90%, VOC increases due to flaring would be only 2.5
TPY (25 TPY* 0.10), and the total VOC increase would still be below 40 TPY.
The commenter's argument is off point for yet another reason. Though the commenter goes to
great lengths to suggest why PSD review for VOC is appropriate, the consequences of triggering
PSD review have not been discussed. Properly operated flares are acceptable control devices for
control of HAP emissions under MACT standards promulgated pursuant to Section 112 of the
Clean Air Act. Venting periodic releases to the North Flare would be BACT had PSD review
been required. The BenFree Unit, however, did not trigger PSD review. See LDEQ's Response
to Comment NO.6.
The North Flare is subject to 40 CFR 60.18 and 40 CFR 63.11. Murphy monitors the status of
the pilot via a monitor in the control room. Further, Murphy also monitors gas flow and steam
flow to the flare. It is generally understood that the addition of excess steam results in a
reduction in control efficiency. However, it is not appropriate in this i~stance to set a specific
steam to vent gas ratio because, unlike a process such as a synthetic organic chemical
manufacturing plant, the composition of the vent gas is variable.
AI1238,PER20090002
Page 19 of39
COMMENT NO. 16
2. Tank Emissions
The Application includes updates to existing permitted Tanks Caps, which Murphy Oil
claims will result in a net decrease in VOC emissions. Ap., p. 1; 7/7/09 Murphy Public
Comments, p. 4 (claiming a 10% decrease in VOCs). However, the netting analysis
includes 11.78 ton/yr of VOC increase from nine tanks. Murphy Oil fails to explain the
origin of these increases. Concerned Citizens Around Murphy ask that LDEQ explain
this apparent discrepancy, i.e., the claim that Murphy Oil will reduce tank emissions by
10%, while the netting calculations show an increase. Without an explanation of this
inconsistency in the record, LDEQ cannot lawfully issue the permit.
Murhpy's [sic] supporting calculations have underestimated tank emISSIOns. First,

Murphy Oil failed to include tank cleaning emissions. Sludges build up inside of tanks,
reducing their working capacity. Therefore, facilities typically clean tanks once every
five to ten years, or more frequently to facilitate inspections to fix leaks and address
subsurface contamination. These sludges can contain up to 90 percent hydrocarbon (i.e.,
VOC) and significant amounts of H2S. The netting analysis did not include increases in
VOC emissions due to tank cleaning emissions.
Second, some of the subject tanks included in the proposed modifications are floating
roof tanks. Murphy Oil calculated the V OC emissions from these tanks using the EP A
TANKS 4.0 model. This model assumes that the floating roof tank roof is always
floating and thus does not include VOC losses during roof landings. Thus, the netting
analysis did not include increases in VOC emissions due to roof landing emissions.
The nine tanks in question were included in netting analyses associated with Permit Nos. 2500-
00001-V3 and V4, dated May 8,2008 and January 15,2009, respectively.32 These tanks were
replaced or reconstructed after the flooding of Hurricane Katrina. The changes affecting the
tanks are changes in service and a different utilization scheme due to the BenFree Unit are shown
below:33
Permits -V2, Requested

-V3, and -V4 Permit -VS
CAP Requested Tank CAPs
CAP CAP
(t t
Crude 9.91 10.89 200-4,200-5,300-1,300-2, 300-
3A, 300-4, 300-6A
32 See EDMS Document 41456805, Briefmg Sheet, page 8

33 See EDMS Document 40127062, 1ntroduction, page 6
AlI238,PER20090002
Page 20 of39
42.43
Merge with ----
30.94
7.89
3.15Naphtha
95.30Gasoline --CAP
12.03
30.41
42.61
7.23
2.35 Cap
Gasoline 1-3A,5-3
150-1,250-4, 80-2,
200-1,200-2,200-3,55-7,
200-7,80-1,80-4, 250-5,250-6,250-
80-5A, 80-7,
-1 OA, 80-11, 80-12,7,250-8,
14,80-16,80-18
80-6,
80- 80-7,
80-12, 300-1,
80-10A,80-15 80-8,80-9,
80-14, 300-2, 300-3A,
80-18 80-10A,
Comparing the emissions authorized under Permit Nos. 2500-00001-V2, V3, and V4 with those
to be authorized under Permit No. 2500-00001-V5, it is obvious that there is a reduction in
potential emissions of 9.24 TPY (l04.54 TPY - 95.30 TPY). These reductions will not be
considered creditable decreases for netting purposes. Murphy conservatively included all
emission changes due to new caps (re-combination) in the netting analysis. Conservatively,
VOC increases attributed to the tanks included in the netting analysis are 11.78 TPY, irrespective
of any decreases.
Tank cleaning emissions are permitted separately under the General Condition XVII Activity
List (Sludge Removal, Taking Floating Roof Tank Out of Service, Taking Fixed Roof Tank Out
of Service). These activities and emissio.ns are existing emissions and will not change due to the
BenFree Unit. Therefore, the emissions from tank cleaning should not be included in the netting
analysis.
Murphy complies with 40 CFR 60, Subpart Kb provisions, which require that floating roof tanks
be operated in such a manner that the roof is floating on the liquid surface at all times. A roof
landing situation may arise in an upset condition or during planned cleaning operations only.
LDEQ does not permit upset conditions or malfunctions. As stated earlier, such emissions must
be reported as deviations.
COMMENT NO. 18
III. THE NETTING ANALYSIS RELIES ON LIMITATIONS THAT ARE NOT

PRACTICALLY ENFORCEABLE.
Our analysis indicates that the netting analysis is flawed and that the increase in
emissions of at least S02 and VOC do exceed emission thresholds for PSD analysis.
Regardless, however, the permit must contain sufficient operating limits, emission limits,
monitoring, and recordkeeping to assure that Murphy Oil achieves in practice the
calculations in the netting analysis. The draft permit does not contain these required
AII238,PER20090002
Page 21 of39
checks.
Title V of the Clean Air Act requires that LDEQ issue a comprehensive operating permit
to Murphy Oil that will "identifY all emission limits for the source," and also include
"enforceable emission limitations and standards" and "requirements to assure compliance
with the permit terms and conditions." Sierra Club v. Environmental Protection Agency,
536 F. 3d 673, 674 (D.C. Cir. 2008); 42 U.S.C. § 7661c (a) and (c).
Both the Title V statutory provisions and the implementing regulations expressly require
the operating permits contain sufficient conditions to ensure compliance. 42 U.S.C.
7661 c(c)(" [sic] Each permit issued under this subchapter shall set forth inspection,
entry, monitoring, compliance certification, and reporting requirements to assure
compliance with the permit terms and conditions."); 40 C.F:R. 70.6(c)(1) ("Consistent
with paragraph (a)(3) of this section, compliance certification, testing, monitoring,
reporting, and recordkeeping requirements sufficient to assure compliance with the terms
and conditions of the permit."); LAC 33:III.507(H) ("Each permit issued to a Part 70
source shall include ... compliance certification, testing, monitoring, reporting, and
recordkeeping requirements sufficient to assure compliance with the terms and conditions
of the permit as required by 40 CFR 70.6(a)(3».
Here, the draft permit fails to provide mechanisms to ensure compliance with the most
fundamental requirement: that net emissions remain below significance threshold.34 If
net emissions are above significance thresholds, then LDEQ must require stringent
BACT and/or LAER pollution controls, and the less stringent minor source limits
contained in the permits are invalid. Thus, it is critical that the draft permit contain
sufficient enforceable terms and conditions to ensure that Murphy Oil does not exceed
those thresholds. Similarly, the underlying requirements governing the netting process
specifically require that any limits on the potential to emit assumed in the netting analysis
be enforceable as a practical matter, to ensure that limits on the potential to emit are not
illusory.
Specifically, the draft permit does not require Murphy Oil to monitor S02 from any of
the fired sources. Further, the draft permit does not require Murphy Oil to monitor total
sulfur in the fuel gas. Thus, the requirement that the 'project would increase S02
emissions by only 26.85 ton/yr is unenforceable as a practical matter. In addition, the
draft permit does not require any monitoring of flaring VOC emissions. Thus, there is no
way to verify that the subject modifications do not result in a significant increase in VOC
emissions. Therefore, the requirement that the project would increase VOC emissions by
37.22 ton/yr is unenforceable as a practical matter.
The general provisions purportedly limiting overall net emissions to below significance
thresholds are inadequate, as they do not require actual measurement of emissions, but

Murphy Oil USA, 1nc., Meraux Refinery
Al1238,PER20090002
Page 22 of39
rather are unenforceable blanket limits and circular calculations. Additionally, the draft
permit netting analysis is rife with assumptions regarding facts and circumstances that
will supposedly limit project's potential to emit emissions that are either incorrect and/or
not based on any permit limits that would ensure their accuracy.
It is first important to note that the increases (without respect to decreases) associated with the
BFU are below PSD significance thresholds. See page 9 of Permit No. 2500-00001-V5. The
contention that the permit fails to provide sufficient conditions to ensure compliance is not
accurate.
First, Murphy complies with the requirements of 40 CFR 60, Subpart J - Standards of
Performance for Petroleum Refineries. 40 CFR 60.104 - Standards for Sulfur Oxides requires
the refinery to limit the H2S content of fuel gas burned in fuel gas combustion devices. The
facility maintains the H2S concentration in the refinery fuel gas at 0.10 gr/dscf or less as required.
by 40 CFR 60.104(a)(1) and monitors H2S continuously as required by 40 CFR 60.105(a)(4).
All the fuel gas drums that supply fuel gas to combustion devices at the refinery are monitored
for H2S concentration; these requirements are clearly identified in the proposed permit.35
Moreover, the facility is required to report the BenFree Reboiler emissions under a cap as stated
in the proposed permit.36 This cap, identified as Emission Point CAP-HEATERS, specifically
requires Murphy to monitor the heat input to all the boilers, heaters, and reboilers and calculate
emissions based on individual heat inputs and combustion unit-specific emission factors. In
addition, the cap limits total heat input to 1869.07 MM BID/hr and overall emissions to 67.75
TPY ofPMIO, 242.15 TPY ofS02, 893.49 TPY of NO x, 869.37 TPY of CO, and 49.03 TPY of
VOc. Records must be kept on site and reported to LDEQ as per the specific condition in the
permit.
Finally, the fired sources and the flares, including the BenFree Reboiler, have maximum hourly
emission limits in the permit for S02, VOC and other criteria pollutants. The EPA's policy is
that the practical enforceability of emission limits requires such limits to be as "short term as
possible and should generally not exceed one month. ,,37 EP A has also indicated that practical
enforceability may exist in some situations where the emissions limits are stated in terms of up to
a 12-month rolling average.
In conclusion, the application and proposed permit contain sufficient information, operating
limits, emission limits, monitoring, and recordkeeping requireemnts to assure compliance with
state and federal regulations, as well as to ensure emissions do not exceed the PSD significance
level for any pollutant.
35 See Document 41456805, Draft Permit, Specific Requirement Nos. 2, 12,36, 71,81,200,231,280,602, etc.
36 See Document 41456805, Draft Permit, Briefing Sheet, page 8, last sentence of third paragraph
37 "Guidance on Limiting Potential to Emit in New Source Permitting," dated June 13, 1989

DEQ Basis For Decision Vol 1 - Murphy Oil Air Permit V5 - October 22, 2009

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

DEQ Basis For Decision Vol 1 - Murphy Oil Air Permit V5 - October 22, 2009

Uploaded by

Copyright:

Available Formats

BOBBY JINDAL HAROLD LEGGETT, PH.D.

RE: Notification of final permit action

Dear Sir or Madam:

BASIS FOR DECISION

PART 70 OPERATING PERMIT NO. 2500-00001-V5

The Louisiana Department of Environmental Quality (LDEQ), Office of Environmental Services

The details of the LDEQ's reasoning are s~t forth below:2

Murphy owns and operates a petroleum refinery in Meraux, Louisiana. Murphy

B. Proposed Permit Action

Flare, Storage, BFU Turnaround, Startup/Shutdown, etc.), evaluated on an "actual to

Permitted emissions from the Meraux Refinery, in TPY, are as follows:

Pollutant Before After Change*

II. PUBLIC COMMENT

III. PUBLIC COMMENTS RESPONSE SUMMARY

Action Type Tracking No. Date

One alternative to the existing Meraux Refinery would be to construct on a "greenfield"

In addition to the requirements of LAC 33:III.Chapter 59 and 40 CFR 68 requirements

VII. AVOIDANCE OF ADVERSE ENVIRONMENTAL EFFECTS: Have the potentia]

Calculated Maximum Louisiana Ambient

Calculated Maximum Louisiana Ambient

B. Wastewater Discharges and Groundwater

3 See EDMS Document 40169977 (pgs. 38 & 51 of 435)

stormwater, utility wastewater, treated sanitary wastewater, and low contamination

c. Solid and Hazardous Waste Generation

6 EDMS Document 40 I 69977 (pg. 269 of 435)

To reduce the possibility of leakage of hazardous chemicals to the environment, Murphy

VIII. COSTIBENEFIT ANALYSIS (BALANCING): Does a cost benefit analysis of the

A. Environmental Impact Costs

7 72 FR 8430, February 26, 2007

B. Social and Economic Benefits

IX. ENVIRONMENTAL JUSTICE CONSIDERATIONS

8See EDMS Document 40169977 (pg. 272 of 435)

EP A and the states have promulgated a wide series of regulations to

Title VI and EPA's implementing regulations set out a requirement

Importantly, to be actionable under Title VI, an impact must be both

problems, and [are] readily enough remediable, to warrant altering the

PUBLIC COMMENTS RESPONSE SUMMARY

PART 70 OPERATING PERMIT 2500-00001-V5

RESPONSE TO COMMENT NO.1

RESPONSE TO COMMENT NO.2

Regarding public health, see LDEQ's Response to Comment No. 21.

Odors can be caused by a single chemical compound or by a combination of compounds. Some

4 See EDMS Document 42107180

RESPONSE TO COMMENT NO.3

RESPONSE TO COMMENT NO.4

Regarding odors, see LDEQ's Response to Comment NO.2.

Permitted Emissions Permitted Emissions

7 See EDMS Documents 42229896 & 42229884

RESPONSE TO COMMENT NO.5

10 See EDMS Documents 42220250, 42395018, and 42557391

RESPONSE TO COMMENT NO.6

**The "BFU Project Increases" represent increases without respect to decreases.

13 See EDMS Document 42107180

RESPONSE TO COMMENT NO.7

See also LDEQ's Response to Comment No. 20.

. RESPONSE TO COMMENT NO.8

J6 See EDMS Document 42088733

1. THE NETTING ANALYSIS FAILS TO INCLUDE THE FOLLOWING

A. Emergency Flaring Emissions.

18 See EDMS Document 42539789 (pg. 3)

RESPONSE TO COMMENT NO.9

B. Updated Facility-wide Turnaround Emissions and NO.2 Amine Unit Turnaround.

(0.10 gr H2S/dscf)(l Ib/7000 gr)(l scf/909.1 BTU)*(l0/\6) = 0.0157 lb H2S/MM BTU