Response to Public Comments

Murphy Oil USA, lnc., Meraux Refinery

Al1238,PER20090002
Page 23 of39

COMMENT NO. 19

IV. THE PSD NETTING ANAL YSIS LACKS ADEQUATE SUPPORT AND
CANNOT BE VERIFIED.

As explained in detail below, neither the Application nor the draft permit provide
adequate support for Murphy Oil's PSD netting analysis. Therefore, LDEQ should
require Murphy Oil to provide data supporting all emission calculations, including the
S02 emission factor discussed here, and reopen the public comment period so that the
public can submit additional comments with the benefit of this information. LDEQ
cannot lawfully issue the permit on an inadequate record.

A. Support for S02 emissions is Inadequate.

The Application reports S02 emissions from the relevant sources in pounds per hour
(lb/hr) and tons per year (ton/yr), but does not disclose the emission factor (in lb/Moto)
used to calculate these emissions. While the emission factor can be backcalculated from
firing rates reported in Appendix D, Murphy Oil did not disclose the backcalculated
emission factor beyond references to e-mail correspondence and phone conversations that
LDEQ did not produce in response to our request. Ap., Appx. D, Combustion
Calculations and Emission Calculations, North Flare. This is true also for VOC, NOx,
PM10, and CO. However, this comment focuses only on S02.

For example, it is possible to calculate the S02 emission factor for the reboiler from the
Combustion Calculations table in Appendix D as: 1.841 Ib/hr/70 Moto/hr = 0.0263
lb/Moto. Exh. 1. However, Murphy Oil has provided no basis for this factor beyond
footnote 9, which states: "Per email correspondence (sic) between Matt Dobbins (Murphy
Oil) and Cheri Kwasi (Trinity) on December 4, 2008 and January 14, 15, 26, 2009 and
personal communication phone conversations on December 17, 2008 and January 22,
2009." Neither LDEQ nor Concerned Citizens Around Murphy can evaluate the assumed
S02 emission factor without the data that explains the basis for factor.

We discussed this matter with LDEQ, who informed us that with respect to the reboiler,
that Murphy Oil based the S02 emissions on a maximum value of 160 ppm hydrogen
sulfide ("H2S") in the fuel gas. In addition, LDEQ informed us that the reboiler vendor
determined this value of 160 ppm H2S to result in an emission factor of 0.0263 IblMoto.
7/7/09 Quadri email. However, the record does not contain the calculations supporting
this conclusion, nor does it contain the vendor inputs. Thus, we cannot verify the
accuracy of the emission factor.

In further discussions, LDEQ informed us that we could figure out the accuracy of the
emission factor from the data provided in the Emission Inventory Questionnaire ("EIQ")
submitted with the Application. However, this information is not correct since we cannot
 Response to Public Comments
Murphy Oil USA, Inc., Meraux Refinery
AII238,PER20090002
Page 24 of39

make this calculation without the assumed
Neither the EIQ nor any other available
Application contains no actual measurements
fuel gas at the Meraux Refinery. Thus,
emISSIOns.
molecular weight of the refinery fuel gas.
document reports this value. Further, the
of H2S or any other sulfur compound in the
there is no adequate support for the S02

RESPONSE TO COMMENT NO. 19

LDEQ will demonstrate how the emission factor (EF) for S02 can be derived usmg only
information provided in the application.

The heat input capacity of the Reboiler 70 MM BTU/hour

H2S concentration limit (40 CFR 60.1 04(a)(1)) 0.1 gr/dscf(~ 160ppm)
Lower Heating Value of Refinery Fuel Gas 909.1 BTU/scf
Higher Heating Value of Refinery Fuel Gas 1009.7 BTU/scf
Heating Value of H2S 647 BTU/scf
Molecular Weight of H2S ~ 341b/cf
Molecular Weight of S02 ~ 641b/cf
Million (MM) 10/\6

H2S EF = (0.1 gr/dscf)*(1lbI7000 gr)*(1 dscf/909.1 BTU)*(10/\6) = 0.0157Ib/MM BTU

S02 EF = 0.0157Ib/MM BTU * 64/34 = 0.0296 lb/MM BTU (~ 0.03 lb/MM BTUi8

COMMENT NO. 20

B. Other Missing Emission Support.

The netting calculations in the Application consist of about 1,000 pages of calculations,
many illegible, supported only by footnotes, most of which are emails or personal
communications that LDEQ has not provided in response to our records request.
Required information includes:

vendor support for emission factors alleged to be based on vendor information (e.g., a
vendor guarantee),
copies of stack tests that support emission factors based on tests or the use of outdated
AP-42 emission factors, and
a process flow diagram and vendor information describing the proposed BenFree
Unit, including quantification of any utilities (steam, hydrogen) required to support
the process and the resulting increase in emissions to supply these utilities; and
copies of the emails, correspondence, notes and calculations documenting the claimed
emISSIOns.

38 See Document 41458096, Appendix D, Table "Combustion Calculation (lb/hr)"

 Response to Public Comments
Murphy Oil USA, Inc., Meraux Refinery
AI1238,PER20090002
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RESPONSE TO COMMENT NO. 20

The footnotes, emails, and personal communications do not reflect the absence of any essential
information needed to review the permit application and proposed permit. These notes were
entered by Murphy's consultant to assist in keeping track of information related· to prior
modifications and revisions addressed via previously approved permit modifications. The
applicable requirements, emission factors, emission calculations, and the PSD analysis
associated with this proposed permit are clearly disclosed in the permit application.

A description of the BenFree Unit (BFU) is available in the permit application and proposed
permit. As mentioned previously, the BFU is a licensed technology ofAxens. Information is
available on Axens' website, www.axens.net, and at http://www.unep.org/pcfv/PDF/
SSADuprazPres.pdf. Information regarding hydrogen use is contained in LDEQ's Response to
Comment No. 12. The BFU does not require any steam to operate; the BenFree Reboiler will be
fired with refinery fuel gas.

COMMENT NO. 21

I own property at 2513 Ventura dr in Chalmette La just 3 blocks from Murphy Oil
refinery. I had a kidney transplant on May 8th and can not live at my house on Ventura
Dr because of the toxic land and the pollution that they put out daily. Since Katrina they
have dug up some property but not all, they have bought most houses but not all, they
constantly put out sulphur [sic] and don't tell anyone!! Now they want to put up a flare
device and add more pollution!! I have had my boxer die of a brain tumor, and my wife
has toxic poison and now with me just getting the kidney transplant I can know [sic]
longer live there!! I can't sell my property and they will not by me out, my grandkids
live two doors away and my son can't just move because he has all his money invested in
his home!! This just is not right this company gets away with what ever they want
because the parish officials will not do or say anything because they ~et plenty of money
from the Refinery!!! Please do not allow them to pollute anymore!!!3

RESPONSE TO COMMENT NO. 21

A new flare is not associated with the BenFree Unit or this permit modification.

The Clean Air Act required the Environmental Protection Agency (EP A) to establish health-
based National Ambient Air Quality Standards (NAAQS) for pollutants considered harmful to
public health and the environment. The Clean Air Act established two types of national air
quality standards. Primary standards set limits to protect public health, including the health of
"sensitive" populations such as asthmatics, children, and the elderly. Secondary standards set
limits to protect public welfare, including protection against decreased visibility, damage to

39 See EDMS Document 42294749

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Murphy Oil USA, Inc., Meraux Refinery
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animals, crops, vegetation, and buildings. According to EPA, air quality that adheres to such
standards is protective of public health, animals, soils, and vegetation. Health-based standards
have been established for particulate matter (PMIO and PM2.s), sulfur dioxide (S02), nitrogen
dioxide (N02), carbon monoxide (CO), ozone, and lead. Note that volatile organic compounds
(VOC) and Nitrogen Oxides (N0x) are regulated in place of ozone.

Louisiana has also established Ambient Air Standards (AAS) for a group of compounds known
as Toxic Air Pollutants (TAPs). TAPs include the federally-regulated hazardous air pollutants
(HAPs), as well as a few other compounds, such as ammonia and hydrogen sulfide. The AAS
for TAPs were established to be protective of human health and the environment.

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. See LDEQ's Basis for Decision, Section VILA.

Since the St. Bernard Air Monitoring Project commenced in May 2006, over 100,000 individual
air quality measurements have been collected. Ozone and PM2.5 measurements are consistent
with the measurements collected at the Kenner monitoring site and seem to be typical of New
Orleans and most other urban areas of the state. No exceedances of the eight-hour or the one-
hour ozone standard have been observed at the Chalmette High School Site.

The average levels of VOCs are consistent with the levels observed in most other urban areas of
the state where the VOC profiles are dominated by mobile source emissions. Some periodic
spikes of VOCs have been observed at all three monitoring sites. Most of these VOC spikes are
very characteristic of evaporative gasoline emissions and are typical of the emissions found in
the area near refineries and fuel storage areas. The levels of benzene, 1,3-butadiene,
chloromethane and other air toxics are well below the state air toxics standards, and are all equal
to or below the levels measured statewide.

The levels of H2S are consistent with other H2S measurement collected at other locations in the
state. An analysis of the monitoring data with the meteorological data collected has determined
there are multiple small sources ofH2S emissions in the area including some natural sources. No
exceedances of the state 8-hour H2S standard have been observed ...

An analysis of the monitoring data with the meteorological data collected has identified the area
where most of the S02 emissions appear to come from. Some spikes of S02 and H2S have been
periodically observed at all three monitoring sites. These spikes are occasionally high enough to
be a possible cause of some odor complaints from citizens living in the area. No exceedance of
any of the ambient air standards was observed during the course of the study. The data
distribution indicates only a very remote possibility of the 24-hour NAAQS for S02 being
exceeded at any of the monitoring stations.
 Response to Public Comments
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In conclusion, the data collected in this project indicates that the air quality in the Chalmette area
of St. Bernard Parish is meeting all EPA and state ambient air standards. The readings at the
Algiers Entergy and the Chalmette High School site have been very consistent throughout this
project and have not demonstrated any elevated readings that would give cause for concern.
While the S02 readings at the Vista site do not pose a significant risk to the surrounding
community, the occasional elevated readings do warrant further monitoring.4o

COMMENT NO. 224]

Murphy Oil's proposed permit application is deficient: it fails to include the basis of the
emissions calculations. Without such information, it is difficult, if not impossible, to comment
on PSD review or BACT applicability. The Louisiana DEQ has a constitutional duty to make an
objective third party review and must not rely exclusively on data by Murphy Oil or its
consultant.

PSD review and BACT applicability decisions for the proposed permit must be for all emissions
and shall not be allowed on the BenFree Unit as a stand alone project.

Murphy Oil is a major source of TAPs. Murphy Oil's proposed permit seeks to emit toxic air
pollutants (TAPs) with minimum emission rate (MER's) greater than the rates in applicable
LAC: 33 Chapter 51 Tables. When a major source of TAP's applies to emit additional TAP's at
a rate greater than Chapter 51's MER's, BACT must apply for all TAP's. Murphy Oil's
proposed permit does not meet this standard. Therefore, Louisiana DEQ must deny the
application.

Best Available Control Technology (BACT) and Lowest Achievable Emission Rate (LAER):
The existing condition of the plant infrastructure at the Murphy OilMer~ux refinery, recently
issued CO/NOPP(s), various violations oflocal zoning regulations, and the citizen's enforcement
suit should all be considered in the analyses for BACT and LAER. The Louisiana DEQ should
require Murphy Oil install the most effective control mechanisms to achieve the lowest
emissions; effectively lowering the emission limits of Murphy Oil's Title V air permit and
significantly reducing emissions from malfunction, shutdown and startup activity (MSS).

RESPONSE TO COMMENT NO. 22

Regarding the alleged deficiencies in the permit application, see LDEQ's Response to Comment
No. 20.

Prevention of Significant Deterioration (PSD) regulations generally require that each physical
change or change in the method of operation be evaluated independently. For example, the
BenFree Unit (BFU) and any associated upstream or downstream impacts to other sources at the

40 S1. Bernard Air Monitoring Project Final Report, July 30, 2009
41 For Comments 22 - 43, see EMDS Document 42522940
 Response to Public Comments
Murphy Oil USA, Inc., Meraux Refinery
AI1238,PER20090002
Page 28 of39

refinery were evaluated to determine whether or not the project constituted a "major
modification." In this case, emissions associated with the BFU do not exceed PSD significance
levels, so the project did not trigger PSD review. See LDEQ's Response to Comment NO.6.

As stated in LDEQ's Response to Comment No. 11, Boiler NO.7 does not and will not service
the new BFU. 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.

Murphy is a major source of LAC 33:III.Chapter 51-regulated toxic air pollutants (TAP); thus,
Maximum Achievable Control Technology (MACT), not Best Available Control Technology
(BACT), must be applied to each source that emits a Class I or II TAP when emissions of that
TAP exceed its Minimum Emission Rate (MER) on a facility-wide basis. BACT is associated
with the PSD program. The proposed permit requires application ofMACT as appropriate.

Regarding application of BACT, because the BFU is not a "major modification," BACT is not
appropriate.

Lowest Achievable Emission Rate (LAER) technology is associated with Nonattainment New
Source Review (NNSR) permitting. Because St. Bernard Parish is in attainment with the
NAAQS for all criteria pollutants, application ofNNSR procedures in not appropriate.

COMMENT NO. 23

Comprehensive enforceable compliance plan: Given the current condition of Murphy Oil
Meraux refinery's infrastructure, recently issued COINOPPs, the citizen's enforcement suit
(alleging violations of the clean air act), and various violations of local zoning regulations, the
proposed permit should not be issued until a comprehensive, achievable, and enforceable
compliance plan is formulated.

RESPONSE TO COMMENT NO. 23

Regarding the recently-issued enforcement orders, see Section IV ofLDEQ's Basis for Decision.
Outstanding compliance issues do not preclude issuance of a Part 70 permit. See, for example,
LAC 33:III.507.H.3, 507.H.4, and 517.E.4.

An enforceable plan to achieve compliance with local parish ordinances IS not a required
component of an air permit application.

COMMENT NO. 24

Flaring Reduction in Neighborhood. Murphy Oil promised residents, over two years ago, a
flaring reliability program at the Meraux refinery. Now, Murphy Oil seeks to route the BenFree
Unit (BFU) to an inadequate gas recovery system (GRS) (EDMS 38894488, EDMS 42227489).
 Response to Public Comments
Murphy Oil USA, Inc., Meraux Refinery
AII238,PER20090002
Page 29 of39

Further, Murphy Oil seeks to route two of its highest H2S rich vent streams to the flare,
canceling the oily water stripper (OWS) vent stream route, as applied for in modification 2500-
001- V2. Instead, Louisiana DEQ must require Murphy Oil comply with its existing Title V air
permit, as applied for, or reopen the permit applications.

The proposed permit cannot assure compliance and is not enforceable, as the inability of the
GRS to achieve air permit limits is still under analysis (EDMS 42227489). Louisiana DEQ does
not have the authority to issue such a permit.

RESPONSE TO COMMENT NO. 24

According to Murphy, at the referenced meeting, refinery representatives discussed the basis of
flaring and what types of events could result in flaring. At that time, Murphy noted that it was
engaged in an effort to improve the overall reliability of the refinery,· which could have positive
impacts on safety, environmental, and production performance.

Regarding the Oily Water Stripper vent stream, please see LDEQ's Response to Comment No.1.
Routing this vent to a flare is allowed by 40 CFR 61, Subpart FF.

The proposed permit contains adequate terms and conditions needed for LDEQ to ensure
compliance with permit limits.

COMMENT NO. 25

Murphy Oil constructed and operates, without a Louisiana DEQ solid waste permit, and
industrial waste (sludge) processing, treatment and storage facility. Murphy Oil failed to notify
residents of the type and amount of chemical emissions and denied the public an opportunity to
comment. This is a violation of the Clean Air Act and of local parish code Chapter 5 and
Chapter 11. Yet, in a recently submitted odor abatement plan (EDMS 41464076) Murphy Oil
prioritized odors associated with the chemical releases from the sludge press facility.

Murphy Oil emits toxic air pollutants from this sludge facility, along with the benzene streams
and other chemicals emitted from both the open sewer system and open treatment tanks of the
wastewater management units. These chemical emissions must be included in the Title V air
permit emissions calculations and the air model.

RESPONSE TO COMMENT NO. 25

Emissions from the Meraux Refinery's sludge management unit are addressed under the
wastewater treatment plant (WWTP). This unit is used to dewater biosolids from the WWTp·
bioreactors prior to shipment offsite to an industrial landfill. This unit is also used to centrifuge
sludge from the API Separator; recovered oil is returned to the refinery, whereas oily solids are
shipped to a BIF unit for proper disposal.
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Murphy Oil USA, Inc., Meraux Refinery
AI1238,PER20090002
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COMMENT NO. 26

Murphy Oil reported VOC emissions from Tank 200-7 at nearly 500 times the permitted level
(page 286 EDMS 38894488). How are these emissions included in the Title V Permit and in air
modeling? School bus stops are within close distance to Tank 200-7. To better protect our
school children, the Louisiana DEQ should require more frequent monitoring of VOC emissions
from Tank 200-7, with public alerts and notification.

RESPONSE TO COMMENT NO. 26

In response to this issue, a Consolidated Compliance Order & Notice of Potential Penalty was
issued.42 Murphy subsequently noted that "emissions estimates provided in the March 2008
notification were conservative high estimates and that subsequent investigation indicates that
emissions are much 10wer.,,43

LDEQ's review of this matter is ongoing.

COMMENT NO. 27

Murphy Oil allegedly omitted H2S emissions from its Title V air permit (EDMS 38108188).
Murphy Oil must be required to reopen the previous permit, recalculating netting analysis for
PSD review and BACT applicability.

Given the totality of H2S emissions from all its Meraux facilities, Murphy Oil must be made to
install the best available controls which result in the lowest achievable emissions.

Murphy Oil's Meraux refinery has over 190 vent streams (EDMS 42227489). Of all these vents
streams, three contribute more than 10 lbs/day of H2S to the flare, and all three are used in
continuous mode. Two of these three vent streams are for the OWS unit; the same vent streams
Murphy Oil seeks to flare (canceling the vent streams route previously applied for in
modification "V2").

Frequent and routine flaring practices are not considered 'good pollution control practice' and
'may violate clean air act' (EPA Enforcement Alert, October 2000,. Volume 3, Number 9 Office
of Regulatory Enforcement).

RESPONSE TO COMMENT NO. 27

All applicable federal and state regulations which pertain to limiting and monitoring H2S
emissions have been included in the proposed permit.

42 See EDMS Document 38042519 (pg. 5-6 of 14)

43 See EDMS Document 38894488 (pg. 296 of307)
 Response to Public Comments
Murphy Oil USA, Inc., Meraux Refinery
AI1238,PER20090002
Page 31 of39

Regarding the Oily Water Stripper vent stream, please see LDEQ's Response to Comment Nos.
1 and 24.

The flaring associated with the BenFree Unit is not in violation of the Clean Air Act.

COMMENT NO. 28

As public health trustee, Louisiana DEQ must identify mitigating measures which could be
implemented to protect residents' health to a higher standard. Louisiana DEQ must consider the
totality of emissions from all of Murphy Oil's facilities in Meraux, including, but not limited to;
the entire processing campus, marketing terminal, loading dock and dock flare, various pipelines
(EXXON-Houston, Chalmette Refinery, LLC, Collins Pipeline, and Air Products), tanks and
tank farms, tank construction, open tanks and sewer system ditches of waste water treatment
plant, and industrial waste (sludge) processing, treatment and storage facility. The totality of
emissions must be included in an updated air model.

Air Modeling
CCAM requests an updated air model for Murphy Oil's Meraux facility(s). Louisiana DEQ must
require the updated air modeling, before the agency can make any determinations on this permit.

In February, 2009 (EDMS 40169977) Murphy Oil USA, Inc submitted a "significant
modification" application to its Tile V Part 70 air permit to construct and operate a benzene
saturation unit. "The toxics modeling results listed ... were submitted in March 2002 and are the
only facility-wide modeling submitted since the issuance of Title V Permit N02500-0000 I-Va".

Air modeling must be updated every five (5) years and include the current levels of S02, H2S,
VOCs and other TAPs and criteria pollutants emitted into our neighborhoods' air. Air modeling
must include emission from all aspects of the Murphy Oil Meraux facilities (as mentioned
before) and take into consideration the present capacity and efficiency of control devices.

RESPONSE TO COMMENT NO. 28

Regarding air quality, emissions associated with the proposed project were reviewed by the Air
Quality Assessment Division to ensure compliance with the NAAQ.S and Louisiana Ambient Air
Standard (AAS). 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. See Section VILA of LDEQ's Basis for Decision and LDEQ's Response to
Comment No. 21 for more information.

There are no federal or state regulations which mandate air modeling to be performed every five
years.
 Response to Public Comments
Murphy Oil USA, Inc., Meraux Refinery
AI1238,PER20090002
Page 32 of39

COMMENT NO. 29

Abatement Plans
Before issuance of this permit, the Louisiana DEQ must require independent abatement studies
for both the chemical releases and associated chemical odors, and the noise and vibrations
emanating from the refinery into the neighborhoods. A comprehensive, achievable and
enforceable plan must be developed, before issuance of this permit. .

RESPONSE TO COMMENT NO. 29

Chemical releases are addressed by 40 CFR 68 and LAC 33:IILChapter 59, which are applicable
to the Meraux Refinery. See Section VILA ofLDEQ's Basis for Decision. Regarding odors, see
LDEQ's Response to Comment NO.2. Regarding noise and vibrations, see LDEQ's Response to
Comment Nos. 2 and 8.

COMMENT NO. 30

Tanks and tank farms.

The mixing, blending, sampling and dispatching of different processing batches to and from
storage tanks leads to increased tank activity and a greater propensity to leak, spill or emit VOCs
and other chemicals. Given the community still remains concerned about spills and soil
contamination in the tank farms, the Louisiana DEQ should required more frequent tank
inspections, for all tanks. The results of the ongoing tank inspections should be made public,
including the gasoline tanks' status.

RESPONSE TO COMMENT NO. 30

The proposed permit requires Murphy to install and maintain appropriate controls, as well as
conduct tank inspections in accordance with 40 CFR 60, Subpart Kb and 40 CFR 63, Subpart
CC. In addition, Murphy complies with the federal and state Spill Prevention, Control, and
Countermeasures (SPCC) rules. The recently installed tanks meet all SPCC rules, including
secondary containment, dikes, and use of proper materials of construction along with compatible
equipment, piping, and accessories to prevent failure from corrosion, stress cracking, and fatigue.
These tanks also meet API standards.

It is important to note, however, that no new tanks are associated with the BenFree Unit or this
permit modification.

COMMENT NO. 31

COMMENTS ON EAS
Louisiana DEQ must required Murphy Oil to resubmit the proposed permit with adequate
answers to the five IT Questions (EAS).
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Murphy Oil USA, Inc., Meraux Refinery
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RESPONSE TO COMMENT NO. 31

Louisiana Revised Statutes, R.S. 30:2018(A), requires that an "applicant for a new permit or a
major modification of an existing permit as defined in rules and regulations that would authorize
the treatment, storage, or disposal of hazardous wastes, the disposal of solid wastes, or the
discharge of water pollutants or air emissions in sufficient quantity or concentration to constitute
a major source under the rules of the department shall submit an environmental assessment
statement as a part of the permit application."

The BenFree Unit (BFU) does not constitute a "major modification of an existing permit as
defined in rules and regulations." As such, an EAS was not required.

Further, R.S. 30:2018(E)(1) specifies that an "application for a minor modification, minor
variance, or exemption from or administrative amendment to a permit, license, registration,
variance, or compliance schedule authorized by this Subtitle" is not subject to Section 2018.

COMMENT NO. 32

We have an unfortunate zoning situation with heavy industry adjacent to our residential
neighborhoods. No neighborhood should be subjected to chemical releases, yet the associated
odors continue to disturb us. Therefore, measures that are appropriate for normal industry
practice may be inadequate under these circumstances. Murphy Oil must recognize the need to
do more than other refineries which are properly buffered from residences.

RESPONSE TO COMMENT NO. 32

The commenter's specific issue with regard to the proposed permit is not clear, but implies
Murphy should be required to go "above and beyond" based on its location. The Part 70 (Title V)
permit requires Murphy to comply with 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 detepnined to be acceptable and
protective of the environment.

COMMENT NO. 33

The proposed permit is a major modification. Murphy Oil's Meraux refinery seeks to change its
batch processing of gasoline to include blending, mixing, and dispatching of different processing
batches of gasoline in the tanks and tank farms. The proposed permit substantially changes
previously issued tank permits from storage to include processing. This change in processing is
a major modification.
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AI1238,PER20090002
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RESPONSE TO COMMENT NO. 33

The proposed permit does not constitute a "major modification" as defined in LAC 33:III.509.
Murphy does not seek to add blending OJ mixing equipment or other "processing" equipment of
any kind. The "blending" referenced in the description of the BenFree Unit is accomplished via
the interaction of the two liquids (i.e., the BenFree product and gasoline).

COMMENT NO. 34

Murphy Oil fails to identify an enforceable plan to achieve compliance with local parish
performance standards for noise, vibration, radiation~ fire and explosive hazards and local parish
requirements for industrial parking lots (St. Bernard Parish Zoning Regulations Codes 22-9-10
and 22-9-8, noted in EDMS 41045636).

RESPONSE TO COMMENT NO. 34

An enforceable plan to achieve compliance with local parish ordinances IS not a required
component of an air permit application.

COMMENT NO. 35

CCAM requests a fenceline and neighborhood air monitoring program similar to the Baton
Rouge area's successful "HRVOC AOC" program.

RESPONSE TO COMMENT NO. 35

Based on the magnitude of emissions associated with the BenFree Unit, it is not LDEQ's
position that a fence line air monitoring program is warranted. See Section VILA of LDEQ's
Basis for Decision and LDEQ's Response to Comment No. 21 for more information.

COMMENT NO. 36

The older gasoline tanks located on the refinery's eastern boundary are within close proximity of
residential trailers, mobile homes and adjacent residential neighbor400ds. Yet, these are some of
the few tanks to receive a post Katrina upgrade for air emissions controls. To fulfill its
constitutional duty as public trustee of the environment, Louisiana DEQ must require Murphy
Oil to install internal floating roof(s) with external domed roof(s) and other more protective air
emissions controls on the gasoline tanks.

The tank farm expansion, permitted in November 2007, could be placed at an alternative site,
instead of the National Historical Area of the Villere brick ruins and historical tree line. The
National Historical Villere Area is also a location of a natural waterway, the Panel Ditch. Soil
subsidence is prevalent in this area and should be addressed for all tanks and containment berms.
 Response to Public Comments
Murphy Oil USA, Inc., Meraux Refinery
AI1238,PER20090002
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RESPONSE TO COMMENT NO. 36

There are no new tanks associated with the BenFree Unit, nor are any physical modifications to
the tank farm addressed in the proposed permit.

COMMENT NO. 37

Given the community still remains concerned about spills and soil contamination in the tank
farms, Murphy Oil should make drainage improvements for storm water and process water
discharges. Discharges from the tank farm should be rerouted for treatment or detoured so they
no longer foul the neighborhood canals and nearby wetlands. Process water discharge capacities
should be increased to reflect the common five to eight inch rain events in the community.

Murphy Oil's containment and drainage systems donot [sic] filter the contaminated tank farm's
stonn water runoff, which fouls our neighborhood canals and nearby wetlands.

Murphy Oil's WWTP doesnot [sic] avoid the real adverse effects experienced III our
neighborhood from the open sewer systems and open treatment tanks.

RESPONSE TO COMMENT NO. 37

Regarding wastewater, see Section VII.B of LDEQ's Basis for Decision. Again, there are no
physical modifications to the tank farm associated with the BenFree Unit (BFU) or proposed
permit. There are no open sewer systems and open treatment tanks located at the refinery.

Further, the BFU will be constructed with pilings in an area known to have no groundwater or
soil contamination.44

COMMENT NO. 38

Murphy Oil's proposed permit seeks to use tanks with fixed roof(s), to route the BFU unit to an
inadequate gas recovery system, and to route H2S rich vent gas streams to the flare. These are
not state of the art emission controls. Louisiana DEQ should require stringent application of the
best available controls to protect public health and safety.

RESPONSE TO COMMENT NO. 38

There are no new tanks associated with the BenFree project; see LDEQ's Response to Comment
No. 30. See LDEQ's· Response to Comment No.1 regarding the OWS stream routed to the
North Flare.

44 EDMS Document 40169977 (pg. 269 of 435)

 Response to Public Comments
Murphy Oil USA, Inc., Meraux Refinery
AI1238,PER20090002
Page 36 of39

COMMENT NO. 39

Murphy Oil has not provided enough information on the BenFree Unit project and how it will
adversely effect [sic] our homes, health and safety.
What will it sound and smell like when the BenFree Unit is operating?
What will it sound and smell like when the re boiler is fuel by natural gas?
What will it sound and smell like when the re boiler is fuel by refinery fuel gas?
What will it sound and smell like when the BenFree Unit shuts down?
What are the expected shutdown emissions?
What will this do to our homes, swimming pools, gardens and health?
What alternatives has Murphy Oil examined to siting all the different boilers so not to cause
further damage to our homes?

RESPONSE TO COMMENT NO. 39

Local residents should perceive no change in the sounds or smells associated with the Meraux
Refinery after the BenFree Unit (BFU) becomes operational. Turnaround emissions for the BFU
are detailed in the following table.45

Startup/Shutdown Emissions
Pollutant (TPY)
PM 10 <0.01
NOx 0.08
CO 0.46
VOC 2.70

The BenFree Unit will have no adverse impact on the homes, swimming pools, or gardens
located in the vicinity of the refinery. Regarding health impacts, see LDEQ's Response to
Comment No. 21. No new boilers are associated with the BenFree Project. Regarding Boiler No.
7, see LDEQ Response to Comment NO.8.

COMMENT NO. 40

The EAS fails to quantify

an economic impact analysis, including how increased TAPs and criteria air pollutants will
cause St. Bernard Parish to lose its ability to attract other industry and more families to
locate to the community
medical bills, hearing loss, effects of sleep deprivation on school children, and other health
costs
loss of what good air quality may be left in our neighborhood
fire and explosion hazards
adverse quality of life effects

45 See EDMS Document 40169977 (pg. 383 of 435)

 Response to Public Comments
Murphy Oil USA, Inc., Meraux Refinery
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Page 37 of39

RESPONSE TO COMMENT NO. 40

Regarding an economic impact analysis, see Section VIILB ofLDEQ's Basis for Decision.

Regarding air quality, 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). 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. See Section VILA ofLDEQ's Basis for Decision for more information.

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

Regarding accident prevention, see Section VILA of LDEQ's Basis for Decision. For a general
description of the Meraux Refinery's accident prevention program, see EDMS Document 40169977
(pg. 270 of435).

COMMENT NO. 41

(3-4-5) alternative projects or sites or mitigating measures: Alternative projects, which would
comply with EP A MSA T II, do exist. The EAS fails to provide the necessary information for the
Louisiana DEQ to make appropriate comparisons of any. The BenFree Unit itself could make
varying usage of steam and hydrogen.

Alternatives to the proposed permit's benzene hydrogenation may include addition of a benzene
splitter which would send feed to the platformer or prefractionation of the reformer feed and / or
benzene extraction facilities as described in "Cost Effective Solutions for Reduction of Benzene
in Gasoline" By Maarten J. Almering, Kerry L. Rock, Arvids Judzis - CDTECH

Alternative projects, which could comply with the EPA mandate, maybe located at alternative
sites with the existing processing campus, offering greater protection of public health, hearing
loss, sleep deprivation, noise and vibrations, fire and explosion hazards. What are the alternate
locations for each steaming source and boiler, which would prevent sleep deprivation and
structural damage to our homes? Louisiana DEQ must identify the' alternative sites and projects
before a decision can be made.

RESPONSE TO COMMENT NO. 41

A formal Environmental Assessment Statement (EAS) was not required for this permit action.
See LDEQ's Response to Comment 31. LDEQ's analysis of alternative sites, projects, and
mitigating measures can be found in Sections IV, V, and VI, respectively, of the accompanying
Basis for Decision.
 Response to Public Comments
Murphy Oil USA, Inc., Meraux Refinery
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Within the refinery, the BenFree Unit (BFU) will receive feed directly from the Platformer Unit
and will operate only when the Platformer is in operation. Thus, it must be constructed in close
proximity to the Platformer Unit.

There are other mechanisms to remove benzene from gasoline; however, some of these
mechanisms result in a concentrated benzene stream. The BFU will convert benzene' to
cyclohexane, which is less toxic in nature than benzene and, unlike benzene, not classified as a
federal hazardous air pollutant or state toxic air pollutant.

There are no new boilers associated with the BenFree Unit.

COMMENT NO. 42

There are alternatives to use of flares as a pollution control device and these alternative methods
must be evaluated. Alternative methods may include a more adequate gas recovery system,
vapor combustors/thermal combustors, use of staged flaring or other flaring minimization
projects. Each project has its own advantages and disadvantages, emission amounts and effects
on the neighboring community. Louisiana DEQ must require Murphy Oil identify alternative
pollution control devices, other than flaring, before the agency can make a determination.

The EAS failed to identify the mitigating measures which could be implemented in the plant to
protect the residents' health and safety. As public health trustee, Louisiana DEQ can not make a
determination on this permit until such mitigating measures are identified.

RESPONSE TO COMMENT NO. 42

Flaring is not the primary mechanism to control emissions from the BenFree Unit (BFU). Offgas
from the BFU will be routed to the refinery's fuel gas system. Emissions from the BFU will be
controlled by routing the vent to the existing North Flare via the Area 6 Flare Knockout Drum
only in emergencies and during maintenance activities.

COMMENT NO. 43

Mitigating measures which would be more protective of public health, may include:
air monitoring in the neighborhood and at the fenceline .
more frequent inspections of tanks and monitoring of tank emissions
explosion resistant windows at the nearby local high school
chemical release, chemical odor and noise abatement measures
testing and adjusting the H2S, 24 hours / 7 days a week
allowing process changes only if simultaneously couple with adequate pollution control
devices
drainage improvements to storm water and process waste water discharges
siting alternatives for all the boilers and burners
 Response to Public Comments
Murphy Oil USA, Inc., Meraux Refinery
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Page 39 of39

RESPONSE TO COMMENT NO. 43

Regarding air monitoring, see LDEQ's Response to Comment No. 35.

Regarding monitoring and inspections of tanks, see LDEQ's Response to Comments 30.

Regarding accident prevention, see LDEQ's Response to Comment 40.

The commenter's concern regarding H2S is not clear. Certainly, the concentration of H2S in a
stream can be monitored (see, for example, LDEQ's Response to Comment No. 13), but it
cannot be "adjusted" on a continuous basis as the comment implies.

Regarding pollution control technology, see LDEQ's Response to Comment 2. Any future
process changes would be required to comply with all applicable federal and state requirements.

Regarding water discharges, see LDEQ's Response to Comment 37.

Regarding siting alternatives, see LDEQ's Response to Comment No. 41. There are no new
boilers associated with the BenFree Unit (BFU). Other than the Reboiler for the BFU, there are
no new boilers or burners associated with this permit modification.