Phillips 66 Company - Issuance of Permit to Operate for Thermal Oxidizer A-1012 or Rental Thermal Oxidizer A-1013 (Air District Application 739256)

The Air District has issued an Air District Permit to Operate for the following new abatement devices: A-1012 Thermal Oxidizer Make: Envent, Model: EMTOS-4500, Maximum Firing Rate: 10.0 MMBtu/hr, Natural Gas Fired, Serial No.: 4500-18 A-1013 Temporary/Rental Thermal Oxidizer, Make: Envent, Model: EMTOS-4500 Maximum Firing Rate: 10.0 MMBtu/hr, Natural Gas Fired, Serial Number: 4500-9 or Other Air District Approved Thermal Oxidizer (To operate for a maximum of one week per year) A-1012 will be used as the primary abatement device for S-600 (Pretreatment Unit). A-1013 will be used as a rental unit for one week out of the year when A-1012 is down for maintenance. A-1012 and A-1013 will not abate S-600 concurrently at any given time. S-600 removes the impurities from the raw renewable feedstocks before it can be refined at the hydrotreaters. This results in organic compound emissions from this source. Currently, the permitted abatement process consists of two biofilters (A-622 and A-624) followed by two activated carbon adsorption vessels (A-623 and A- 625). However, the runtime for the activated carbon vessels has proven to be significantly less than what was initially anticipated by Phillips 66, necessitating the addition of further abatement equipment to maintain emissions within the limits specified in the source's permit conditions. The pre-project process flow for S-600 consisted of the vapors being sent through the biofilter A-622 and then through the 4,670 pounds activated carbon vessel, A-623. The source also had an identical pa rallel train, S-600 to biofilter A-624 to activated carbon vessel A-625. S-600 is limited to an emissions limit of 10 ppmv of total organic compounds at the exhaust of A-623/625. However, the facility began exceeding this limit soon after it started operations in June 2024. As a temporary solution, P66 has been using a rental thermal oxidizer since June 26, 2025, which has been successful in achieving compliance with the 10 ppmv limit at S-600. As a permanent solution, Phillips 66 proposed to install a stationary thermal oxidizer A-1012 as the primary abatement device to control organic vapors from the PTU. While A-1012 is offline for maintenance for one week in a year, A-1013 will be used as the backup control device for S-600. The emission limit at the stack downstream of S-600 will remain at 10 ppmv. The thermal oxidizers shall not concurrently abate S-600 at any given time. The Air District conducted a review to ensure the thermal oxidize rs meet the Reasonably Available Control Technology (RACT) standard. Based on this review, the Air District determined that emission limits of 25 ppmv at 15% oxygen for nitrogen oxides (NOx) and 33 ppmv at 15% oxygen for carbon monoxide (CO) are appropriate for combustion at A-1012. Phillips 66 will conduct a source test upon startup and annual testing thereafter to demonstrate compliance. The proposed modification will not change the throughput capacity of the PTU or any associated upstream or downstream equipment, and no additional fugitive emission components will be introduced with the installation of the thermal oxidizers. To offset combustion emissions generated by the thermal oxidize rs, Phillips 66 will provide Emission Reduction Credits (ERCs) from banking certificates Nos. 1610 and 1298 for NOx and Precursor Organic Compounds (POC). Contemporaneous ERC produced from the Rodeo Renewable Project or Air District Application 31157 will be used for Particulate Matter (PM1o and PMz.s) and Sulfur Dioxide (S02) respectively.