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November 7, 1995 Proposal Submission

CITGO Petroleum Corporation

Corpus Christi Refinery

P.O. Box 9176
1801 Nueces Bay Blvd. PH - 512-844-4000
Corpus Christi, Texas 78469-0321 FAX - 512 844-5108

November 7, 1995

P 373 571 909

Regulatory Reinventing Pilot Project
Water Docket
U.S. Environmental Protection Agency
Mail Code 4101
401 M Street, S.W.
Washington, D.C. 20460

Attention: Water Docket

As a follow-up to our August 16, 1995 letter proposing an XL Project for monitoring and controlling emissions from fired sources in a refinery we would like to clarify the anticipated environmental benefits and the regulatory flexibility that are required by this program.

The "cleaner" part of the project is that by using computer models we are able to determine what influences NOx and CO production from a unique source. From our preliminary work these process variables are not always the same, but vary from source to source. It is evident that once a set of variables are identified they can be manipulated to minimize the formation of the undesired emissions. It also follows that for any set of sources a computer optimization can be developed to produce minimum emissions for each process operational scenario. This will assure that fired sources in the refinery will be producing the lowest emission for any set of circumstances.

For this to be attractive for the facility, two things will be necessary. First agreement on an NOx and Co bubble will be necessary so that maximum flexibility of operations can be attained to take advantage of economic conditions. For instance, if one unit has better margins, then permitted emissions can be exceeded by the reduction of emissions at another less profitable unit. Secondly, as part of the PSD program CITGO will be required to install a ground level NOx monitor to demonstrate that the NAAQS for NOx is not exceeded. This is a very costly and time consuming exercise. We propose that the results from the models be used to demonstrate that emissions are better controlled so that ground level monitoring devices would not be needed.

Water Docket

Page 2

November 7, 1995

CITGO has long maintained that government/industry partnerships such as proposed by this project are far preferable to command and control regulations. We look forward to working with the EPA, the Texas Natural Resource Conservation Commission, and local government who are interested in achieving the goals of the XL Program. Additionally, since the Corpus Christi area is a "ozone non-attainment area", minimizing NOx, an ozone precursor, will have a positive impact on the governmental entities efforts to maintain the attainment of the area.

We hope these clarifications are helpful and will assist in moving our proposal forward. If you have any questions or require additional information, please contact me at (512) 844-4112.


Philip Vrazel

Manager of Environmental Affairs


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