(AE-17J)

Mr. Kari Lorch

Senior Technical Advisor
Flint Hills Resources Pine Bend Refinery
P.O. Box 64596
Saint Paul, Minnesota 55164
Re: Request for Approval - Alternative Monitoring Plan New Source Performance
Standards 40 C.F.R. Part 60 Subparts NNN
Dear Mr. Kari Lorch:
This letter is in response to your request for approval of an alternative monitoring
plan (AMP), dated October 14, 2009. The AMP request seeks approval from the EPA in
order to use certain monitoring, recordkeeping, and reporting provisions of 40 C.F.R. Part
60, Subpart RRR as an alternative to certain monitoring, recordkeeping, and reporting
requirements in 40 C.F.R. Part 60, Subpart NNN; approval of a waiver of initial
performance tests for certain boilers and heaters; and approval of alternate flare reporting
requirements. Your request is for specific units which are affected facilities subject to
New Source Performance Standards (NSPS) Subpart NNN, 40 C.F.R. 60.663(c)(2).
These affected facilities are located at the Pine Bend Refinery at the Saint Paul facility,
owned and operated by Flint Hills Resources (FHR).
Pursuant to NSPS Subpart A at 40 C.F.R. 60.13(i), EPA approves your request
to comply with the monitoring requirements of NSPS Subpart RRR, specifically, 40
C.F.R. 60.703(c)(1), (c)(1)(i), and (c)(1)(ii) as an alternative means of demonstrating
compliance with the requirements of NSPS Subpart NNN 60.663(b)(2), (c)(1), (c)(2),
and (c)(3) for the boilers and process heaters which are fired with fuel gas containing a
vent stream from the Poly Unit De-Propanizer (43V-5), Saturates Gas De-Propanizer
(43V-19), and Alky Unit De-Propanizer (35V-2). Additionally, pursuant to NSPS
Subpart A at 40 C.F.R. 60.8(b)(4), EPA approves the waiver of the requirement for your
facility to conduct performance testing due to previous performance test which
demonstrated compliance with the emission standards under 40 C.F.R. 60.662(a) of

NSPS Subpart NNN for the boilers and process heaters which are fired with fuel gas
containing a vent stream from the Poly Unit De-Propanizer (43V-5), Saturates Gas DePropanizer (43V-19), and Alky Unit De-Propanizer (35V-2). This waiver is applicable
for boilers and process heaters which meet the definitions of a boiler or process heater
under NSPS Subpart RRR at 40 C.F.R 60.701. Both the alternative monitoring and the
waiver of performance testing are contingent upon the vent streams being vented to a fuel
gas system and introduced into the flame zone with the primary fuel. Finally, EPA
approves your request to report on the status of the pilot flame to FHR's flare required by
40 C.F.R. 60.665(l)(4) as part of the flare performance reports FHR submits per 40
C.F.R. 63.654(g)(6)(i)(B).
For affected facilities that comply with 40 C.F.R. 60.662(a) by using a boiler or
a process heater, NSPS Subpart NNN at 40 C.F.R. 60.663(c)(1) requires the installation
of a flow indicator that provides a record of vent stream flow to the boiler or process
heater at least once every hour. The corresponding section under NSPS Subpart RRR at
40 C.F.R. 60.703 (c)(1), requires a flow indicator only on any bypass line that may
divert the vent stream from the boiler or process heater. That section of 40 C.F.R. Part 60,
Subpart RRR also states that no flow indicator is required if the bypass line is secured in
the closed position with a car-seal or lock-and- key type configuration. FHR stated in its
October 14, 2009 letter that it would be car-sealing any bypass lines in lieu of installing
flow indicators. The car-seals would be visually inspected at least monthly to ensure that
any bypass line valves are maintained in the proper position.
Additionally, for affected facilities that comply with 40 C.F.R 60.662(a) by
using a boiler or a process heater with a design heat input capacity of less than 150
million Btu per hour, Subpart NNN at 40 C.F.R. 60.663(c)(2) requires a temperature
monitoring device in the firebox. The corresponding section under Subpart RRR, 40
C.F.R. 60.703(c)(2) does not require a temperature monitoring device if the vent stream
is introduced with the primary fuel. FHR stated in its October 13, 2009 letter to the EPA
that vent streams from the Poly Unit De-Propanizer (43V-5), Saturates Gas DePropanizer (43V-19), and Alky Unit De-Propanizer (35V-2) are routed into the Flare Gas
Recovery Unit where they are either recovered and recycled for use as feedstock/product,
or sent to the refinery fuel gas system
Lastly, for these affected facilities, under NSPS Subpart NNN at 40 C.F.R.
60.664 (b)(5), an initial performance test is required if the vent stream is combusted in a
boiler or process heater with a design heat input capacity of less than 150 million Btu per
hour. Under NSPS Subpart RRR at 40 C.F.R. 60.704(b)(5), the requirement for an
initial performance test is waived when a vent stream is introduced into a boiler or
process heater with the primary fuel. FHR further stated that there are times during

periods of unit maintenance, startup, and shutdown that the gas is routed to the refinerys
flare which has been performance tested for compliance with 40 C.F.R. Part 60.18.
Based on this approval, FHR must comply with the applicable recordkeeping
requirements in NSPS Subpart RRR at 60.705(d), including (d)(1) and (d)(2), as an
alternative to those required under NSPS Subpart NNN at 60.665(d); and FHR must
comply with the reporting requirements for flow indicators in NSPS Subpart RRR at
60.705(l), including (l)(2) and (l)(7), as an alternative to those required under NSPS
Subpart NNN at 60.665(l).
As a condition of approval of the requested AMP, FHR shall also meet the
following requirement under NSPS Subpart RRR at 60.705(s):
"(s) Each owner or operator who seeks to demonstrate compliance
with 60.702 (a) or (b) using a control device must maintain on file
a schematic diagram of the affected vent streams, collection
system(s), fuel systems, control devices, and bypass systems as
part of the initial report. This schematic diagram must be retained
for the life of the system."
The schematic diagram documentation shall include the identification, location,
and function of all monitoring systems and devices required under NSPS Subpart RRR at
60.703(b) and (c).
If any information is found that would reverse this determination, the
determination would become invalid and a new determination request would be needed.
If you have any questions concerning this determination, please contact Shilpa
Patel, of my staff, at (312) 886-0120.
Sincerely yours,

George T. Czerniak, Chief

Air Enforcement and Compliance Assurance Branch