Air Quality Plan Approval Application 
Petrochemicals Complex 
Shell Chemical Appalachia LLC 
Beaver County, Pennsylvania ...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Table of Cont...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
4.1.7 25 Pa. ...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
5.6 Evaluatio...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
List of Table...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Table 5-22. R...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Table 5-51. S...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
1-1 
1.0 Intr...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
availability ...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
contribute to...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Table 1-1. Su...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Under non-att...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
 low-density...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
storage tanks...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Figure 1-1. G...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
1-9 
Figure 1...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
annual precip...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Section 3.0 c...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
2.0 Permit Ap...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
the results f...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
3.0 Process a...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
 Plastic bot...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
3-3 
Figure 3...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
seven crackin...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
After the que...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
refrigerant. ...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
startup/shutd...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Furnace Emiss...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Figure 3-2. P...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
The following...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Slurry cataly...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Product Purge...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Figure 3-3. P...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
slurry is pum...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
fed into the ...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
3-16 
3.3.1.4...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
3.4 Combustio...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
3.5 Utilities...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Table 3-1. Su...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Service Tank/...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
these tanks w...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
3-22 
3.5.4 C...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
flares (HP gr...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
The flares an...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
3-25 
 Retur...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
4.0 Air Regul...
Shell Chemical Appalachia LLC Plan Approval Application 
Beaver County, Pennsylvania Petrochemicals Complex 
Table 4-1. Su...
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
Shell Air Quality Plan Approval application for PA Ethane Cracker Plant
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Shell Air Quality Plan Approval application for PA Ethane Cracker Plant

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A detailed air pollution application from Shell to build an ethane cracker plant in Beaver County, PA. The plan reveals that the plant's output of VOCs and carbon dioxide will exceed federal Clean Air Act standards, triggering necessary approvals from the federal government. The application is currently under review with the PA Dept. of Environmental Protection, a process expected to take 4-6 months.

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Shell Air Quality Plan Approval application for PA Ethane Cracker Plant

  1. 1. Air Quality Plan Approval Application Petrochemicals Complex Shell Chemical Appalachia LLC Beaver County, Pennsylvania May 2014 Prepared for Submittal to: Pennsylvania Department of Environmental Protection Bureau of Air Quality Southwest Regional Office 400 Waterfront Drive Pittsburgh, PA 15222-4745 Prepared by: RTP Environmental Associates, Inc. 304-A West Millbrook Rd. Raleigh, NC 27609
  2. 2. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex Table of Contents 1.0 Introduction ..................................................................................1-1 1.1 Project Description ........................................................................................................1-1 1.2 Overview of Process......................................................................................................1-5 1.3 Site Description .............................................................................................................1-7 1.4 Project Schedule ..........................................................................................................1-10 1.5 Document Overview ...................................................................................................1-10 2.0 Permit Application Requirements ..............................................2-1 3.0 Process and Emission Source Descriptions ............................3-1 3.1 Ethylene Manufacturing Process ..................................................................................3-2 3.1.1 Process Description ................................................................................................3-2 3.1.2 Ethylene Manufacturing Emissions Sources ........................................................3-6 3.2 Polyethylene Manufacturing – Gas Phase Technology ...............................................3-8 3.2.1 Process Description ................................................................................................3-8 3.2.2 Gas Phase Technology Process Emissions .........................................................3-11 3.3 Polyethylene Manufacturing – Slurry Technology....................................................3-12 3.3.1 Process Description ..............................................................................................3-12 3.3.2 Slurry Technology Process Emissions ................................................................3-16 3.4 Combustion Turbines and Duct Burners (Cogen Units) ...........................................3-17 3.5 Utilities and General Facilities Process Descriptions ................................................3-18 3.5.1 Diesel Engines ......................................................................................................3-18 3.5.2 Storage Tanks.......................................................................................................3-18 3.5.3 Product Loading ...................................................................................................3-21 3.5.4 Cooling Towers ....................................................................................................3-22 3.5.5 VOC Control Systems (Flares and Incinerators) ................................................3-22 3.5.6 Wastewater Treating ............................................................................................3-24 4.0 AIR REGULATORY REQUIREMENTS ........................................4-1 4.1 Pennsylvania Air Pollution Control Regulations .........................................................4-1 4.1.1 25 Pa. Code Ch. 121. General Provisions .............................................................4-1 4.1.2 25 Pa. Code Ch. 122 National Standards of Performance for New Stationary Sources ....................................................................................................................4-7 4.1.3 25 Pa. Code Ch. 123. Standards for Contaminants .............................................. 4-7 4.1.4 25 Pa. Code Ch. 124. National Emissions Standards for Hazardous Air Pollutants ................................................................................................................ 4-7 4.1.5 25 Pa. Code Ch. 127. Construction, Modification, Reactivation and Operation of Sources ............................................................................................4-10 4.1.6 25 Pa. Code Ch.129. Standards for Sources .......................................................4-13 ii
  3. 3. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex 4.1.7 25 Pa. Code Ch. 131. Ambient Air Quality Standards.......................................4-17 4.1.8 25 Pa. Code Ch. 135. Reporting of Sources .......................................................4-17 4.1.9 25 Pa. Code Ch. 137. Air Pollution Episodes .....................................................4-18 4.1.10 25 Pa. Code Ch. 139. Sampling and Testing ......................................................4-18 4.1.11 25 Pa. Code Ch. 145. Interstate Pollution Transport Reduction........................4-19 4.2 Federal Regulations .....................................................................................................4-19 4.2.1 40 CFR Part: New Source Performance Standards ...........................................4-19 4.2.2 40 CFR Part 61: National Emissions Standards for Hazardous Air Pollutants (NESHAP) ..........................................................................................4-37 4.2.3 40 CFR Part 63: National Emissions Standards for Hazardous Air Pollutants for Source Categories (NESHAP) .....................................................4-40 4.2.4 40 CFR Part 64: Compliance Assurance Monitoring ........................................4-46 4.2.5 40 CFR Part 68: Chemical Accident Prevention Provisions ............................4-46 4.2.6 40 CFR Parts 72, 73, 74, 75, and 76: Acid Rain Programs ................................4-47 4.2.7 40 CFR Part 82: Protection of Stratospheric Ozone ...........................................4-47 4.2.8 40 CFR Part 98: Mandatory Greenhouse Gas Reporting ..................................4-48 5.0 Control Technology Analysis .....................................................5-1 5.1 Control Technology Background .................................................................................5-1 5.1.1 Control Technology Analyses Definitions ...........................................................5-1 5.1.2 Methodology for LAER and BACT Analyses .....................................................5-2 5.1.3 Achieved in Practice and Technical Feasibility Criteria ......................................5-4 5.1.4 Control Technology Analysis Organization .........................................................5-7 5.1.5 Summary of Proposed BACT/LAER ...................................................................5-8 5.2 Ethane Cracking Furnaces ..........................................................................................5-21 5.2.1 Cracking Furnace NOx/NO2 LAER/BACT Analysis ........................................5-21 5.2.2 Cracking Furnace VOC LAER Analysis ............................................................5-50 5.2.3 Cracking Furnace PM/PM10/PM2.5 BACT/LAER Analyses .............................5-53 5.2.4 Cracking Furnace CO BACT Analysis...............................................................5-57 5.2.5 Cracking Furnace Greenhouse Gas (GHG) Emissions BACT ..........................5-61 5.3 Combustion Turbines & Duct Burners ......................................................................5-70 5.3.1 Combustion Turbine NOx/NO2 LAER/BACT Analyses ..................................5-70 5.3.2 Combustion Turbine VOC LAER Analysis .......................................................5-78 5.3.3 Combustion Turbine PM/PM10/PM2.5 BACT/LAER Analyses ........................5-82 5.3.4 Combustion Turbine CO BACT Analysis ..........................................................5-87 5.3.5 Combustion Turbine GHGBACT Analyses ......................................................5-93 5.4 Diesel Engines ...........................................................................................................5-102 5.4.1 Diesel Engine NOx and VOC LAER Analyses ...............................................5-102 5.4.2 Diesel Engine PM/PM10/PM2.5 BACT/LAER Analyses .................................5-110 5.4.3 Diesel Engine Carbon Monoxide BACT Analysis ..........................................5-123 5.4.4 Diesel Engine GHG BACT Analysis................................................................5-132 5.5 Equipment Leaks .......................................................................................................5-134 5.5.1 Equipment Leaks of VOC LAER Analysis ......................................................5-134 5.5.2 Equipment Leaks of GHG BACT Analysis .....................................................5-139 iii
  4. 4. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex 5.6 Evaluation of the Potential Use of Carbon Capture and Sequestration (CCS) as BACT for CO2 ....................................................................................................................5-143 5.6.1 Technical Feasibility of Potential CCS Process Alternatives ..........................5-144 5.6.2 Step 3: CCS Control Technology Hierarchy ...................................................5-160 5.6.3 Step 4: Evaluate the Most Effective Controls. .................................................5-161 5.6.4 Step 5: Proposed CO2 BACT ...........................................................................5-165 5.7 Polyethylene Process, Storage, and Handling Vents ...............................................5-167 5.7.1 Polyethylene Process, Storage and Handling Vent VOC LAER Analysis .....5-167 5.7.2 Polyethylene Process, Storage, and Handling Vent PM/PM10/PM2.5 LAER/BACT Analysis ......................................................................................5-176 5.8 VOC Emissions from Storage Tanks and Vessels...................................................5-184 5.8.1 Tank Emissions Control Technology Baseline ................................................5-184 5.8.2 Step 1: Identify Tank VOC Control Options ...................................................5-184 5.8.3 Step 2: Eliminate Technically Infeasible Tank VOC Controls .......................5-188 5.8.4 Step 3: Establish Tank VOC LAER ................................................................. 5-188 5.9 PM and VOC Emissions from Cooling Towers ......................................................5-192 5.9.1 Cooling Tower PM/PM10/PM2.5 BACT/LAER Analysis ................................5-192 5.9.2 Cooling Tower VOC LAER..............................................................................5-198 5.10 VOC Emissions from Wastewater Treatment Plant ..............................................5-204 5.10.1 VOC LAER Analysis ........................................................................................5-204 5.11 Loading Operations ................................................................................................. 5-210 5.11.1 Polyethylene Loading PM/PM10/PM2.5 BACT/LAER Analysis .....................5-210 5.11.2 VOC LAER Analysis For Liquids Loading Operations ..................................5-214 5.12 VOC Control Systems.............................................................................................5-220 5.12.1 VOC Control Systems LAER Analyses ...........................................................5-223 5.12.2 VOC Control System CO, NOx, PM, and GHG BACT/LAER Analyses .....5-243 5.13 Plant Roads ..............................................................................................................5-247 5.13.1 Plant Road Fugitive PM LAER/BACT Analysis .............................................5-248 5.14 PaBAT Analyses for Pollutants Not Subject to BACT or LAER ........................5-250 5.14.1 SO2......................................................................................................................5-251 5.14.2 Ammonia (NH3) ................................................................................................. 5-256 5.14.3 Hazardous Air Pollutants (HAPs) .....................................................................5-258 6.0 Air Quality Modeling Analysis ....................................................6-1 7.0 Additional Impacts Analysis .......................................................7-1 7.1 Analysis of Impacts Due to Growth .............................................................................7-1 7.1.1 Overview ................................................................................................................7-1 7.1.2 Growth in Population .............................................................................................7-2 7.1.3 Growth in Air Pollutant Emissions .......................................................................7-3 7.1.4 Air Quality Impacts ................................................................................................7-4 7.2 Analysis of Impacts to Visibility ..................................................................................7-5 7.3 Analysis of Impacts to Soils and Vegetation ...............................................................7-5 7.3.1 Overview ................................................................................................................7-5 7.3.2 Effects on Soil ........................................................................................................7-5 iv
  5. 5. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex List of Tables Table 1-1. Summary of the Proposed Project’s Annual Potential to Emit Pollutants (tons) 1 ........................................................................................................... 1-4 Table 3-1. Summary of Project Tanks and Vessels ...................................................... 3-19 Table 4-1. Summary of Regulatory Applicability .......................................................... 4-2 Table 4-2. Summary of Compliance with the Standards of Containment at 25 Pa.Code Ch. 123. .......................................................................................... 4-8 Table 4-3. Summary of Federal Regulatory Applicability ........................................... 4-20 Table 4-4. Tanks Not Subject to Control Under NSPS Subpart Kb ............................. 4-30 Table 5-1. Proposed Control Technology Evaluation Limits ......................................... 5-9 Table 5-2. Summary of RBLC Ethylene Cracking Furnace NOx Emissions Limits (prior to the past two years) ........................................................................ 5-34 Table 5-3. Summary of Recent Ethylene Cracking Furnace NOx Emission Limits .... 5-35 Table 5-4. Summary of VOC BACT/LAER Limits for Ethylene Cracking Furnaces ...................................................................................................... 5-52 Table 5-5. Summary of Proposed PM/PM10/PM2.5 BACT Limits for Ethylene Cracking Furnaces ...................................................................................... 5-55 Table 5-6. Summary of CO BACT Limits for Ethylene Cracking Furnaces ................ 5-60 Table 5-7. CO2e Formed When Combusting Fossil Fuels ............................................ 5-62 Table 5-8. Summary of Texas Ethylene Cracking Furnace GHG BACT Determinations ........................................................................................... 5-67 Table 5-9. Summary of NOx BACT Precedent Found in the RBLC Database For 40 to 50 MW Turbines ............................................................................... 5-72 Table 5-10. Summary of Recent NOx BACT Precedents ............................................. 5-73 Table 5-11. BAAQMD BACT Review for Authority to Construct Plant Number 13289 ............................................................................................ 5-74 Table 5-12. Regulatory Agencies with NOx BACT Guidelines/Requirements for Combustion Turbines ................................................................................. 5-77 Table 5-13. Summary of VOC BACT/LAER Precedents for Turbines with Oxidation Catalyst ...................................................................................... 5-79 Table 5-14. Regulatory Agencies with VOC BACT Guidelines/Requirements for Combustion Turbines ................................................................................. 5-82 Table 5-15. Summary of Particulate Matter BACT Precedents for Combustion Turbines with Oxidation Catalyst ............................................................... 5-84 Table 5-16. Regulatory Agencies with PM BACT Requirements/Guidelines for Combustion Turbines ................................................................................. 5-87 Table 5-17. Summary of CO BACT Precedent for Turbines with Oxidation Catalyst ....................................................................................................... 5-89 Table 5-18. GHG Emissions for Combustion Turbine Fuels ....................................... 5-94 Table 5-19. Summary of Combustion Turbine Cogeneration GHG BACT Determinations ........................................................................................... 5-98 Table 5-20. RBLC Summary of NOx and VOC Precedents for Emergency Generator Diesel Engines ......................................................................... 5-104 Table 5-21. RBLC Summary of NOx and VOC Precedents for Emergency Firewater Diesel Engines .......................................................................... 5-106 v
  6. 6. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex Table 5-22. Regulatory Agencies with NOx and VOC Guidelines/Requirements for Emergency Stationary Diesel Engines .............................................. 5-111 Table 5-23. RBLC Summary of PM BACT Precedents for Emergency Generator Diesel Engines ........................................................................................ 5-113 Table 5-24. RBLC Summary of PM BACT Precedent for Emergency Firewater Diesel Engines ........................................................................................ 5-115 Table 5-25. Regulatory Agencies with PM Guidelines/Requirements for Emergency Stationary Diesel Engines .................................................... 5-119 Table 5-26. Basis for Removing PM Precedents from Consideration ........................ 5-121 Table 5-27. RBLC Summary of CO BACT Precedents for Emergency Diesel Engines .................................................................................................... 5-125 Table 5-28. RBLC Summary of CO BACT Precedent for Firewater Emergency Diesel Engines ........................................................................................ 5-127 Table 5-29. Regulatory Agencies with CO Guidelines/Requirements for Emergency Stationary Diesel Engines .................................................... 5-130 Table 5-30. LAER Components and References ............................................................138 Table 5-31. SCAQMD Rule 1173 Equipment Leak Rates and Repair Periods 1 ....... 5-140 Table 5-32. TCEQ LAER Equipment Leak Rates and Repair Periods 1 .................... 5-140 Table 5-33. BAAQMD Best Available Control Technology Guideline ..................... 5-141 Table 5-34. Summary of Texas Ethylene/Polyethylene Manufacturing GHG BACT Determinations ............................................................................ 5-142 Table 5-35. Amine Based CO2 Capture Plants ≥ 200 TPD 1 ...................................... 5-150 Table 5-36. CO2 BACT Hierarchy and Emissions ..................................................... 5-162 Table 5-37. Summary of CCS Impacts Analysis for the Cracking Furnaces and Cogen Units ............................................................................................ 5-164 Table 5-38. Summary of VOC BACT Precedents for Polyethylene Unit Vents ........ 5-169 Table 5-39. Summary of Recent Determinations for Polyethylene Process Vents .... 5-178 Table 5-40. Summary of BACT Guidelines for Bay Area Air Quality Management District and Texas Pertaining to Manufacturing Process Particulate Emissions ................................................................................................ 5-183 Table 5-41. Summary of Storage Tanks and Vessels in VOC Service ....................... 5-185 Table 5-42. Summary of VOC BACT/LAER Precedents for Tanks .......................... 5-190 Table 5-43. RBLC Summary of Cooling Tower Emission Limits for PM ................. 5-194 Table 5-44. RBLC Summary of Cooling Tower Emission Limits for VOC .............. 5-200 Table 5-45. RBLC Summary of VOC RACT/BACT/LAER Precedent for Wastewater Treatment ............................................................................ 5-205 Table 5-46. Summary of the State Implementation Plan Review for Loading Operations PM Requirements ................................................................. 5-213 Table 5-47. Summary of the State Implementation Plan Review for Loading Operations VOC Requirements for Loading of Low Organic Vapor Pressure Liquid ....................................................................................... 5-218 Table 5-48. Summary of the State Implementation Plan Review for Loading Operations VOC Requirements for Loading of C3+ or LPG ................... 5-220 Table 5-49. Summary of RBLC and Other Flare Related Permitting Precedents and Regulatory Requirements .................................................................. 5-224 Table 5-50. Summary of RBLC Incinerator Related Permitting Precedents .............. 5-236 vi
  7. 7. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex Table 5-51. Summary of SIP Regulations for Plant Road Particulate ........................ 5-248 Table 5-52. Summary of RBLC Survey Results for Plant Road Particulate .............. 5-250 Table 5-53. Proposed Limitations to Meet SO2 BAT ................................................. 5-252 Table 5-54. Summary of Proposed PaBAT for HAP from the Proposed Project Sources ..................................................................................................... 5-258 Table 7-1. Nine Counties Considered in Population Growth Impact Area .................... 7-3 Table 7-2. Other Area Source Emissions Increases Compared to Current Inventory .... 7-4 Table 7-3. Commercially Significant Vegetation in Ten-County Study Area (Acres) ............................................................................................................12 Table 7-4. Pennsylvania-Listed Plant Species with Potential to Occur in Vicinity of Beaver Valley Nuclear (BVN) Plant (7 miles from the Proposed Project Site) ................................................................................................ 7-15 List of Figures Figure 1-1. General Location of the Shell Facility ......................................................... 1-8 Figure 1-2. Proposed Facility Location .......................................................................... 1-9 Figure 3-1. Ethane Cracker Process Flow....................................................................... 3-3 Figure 3-2. Polyethylene Gas Phase Technology Process Flow Diagram ..................... 3-9 Figure 3-3. PE Unit 3 - Polyethylene Slurry Technology Simplified Process Flow Diagram ...................................................................................................... 3-13 Figure 5-1. CO2 Capture and Concentration System .................................................. 5-147 vii
  8. 8. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex 1-1 1.0 Introduction 1.1 Project Description Shell Chemical Appalachia LLC (Shell) is proposing to construct a petrochemicals complex (the Project) near Pittsburgh, Pennsylvania that will convert ethane (derived as a byproduct from shale gas production in the region) into ethylene and subsequently polyethylene, which is the key building block for many plastic products used every day. The proposed complex will be the first major U.S. project of its type built outside the Gulf Coast region in 20 years. The facility will leverage the plentiful new supplies of ethane in the region to produce polyethylenes used extensively by the area’s manufacturing base. This will reduce economic and environmental transportation costs while providing regional manufacturers with more flexibility, shorter supply chains, and enhanced supply dependability. The proposed Project site is located within an industrial area adjoining the Ohio River in Potter and Center Townships in Beaver County, Pennsylvania. The site offers strategic advantages including access to marine, rail and road transportation, and pipelines; proximity to both ethane supply and polyethylene markets; access to a skilled workforce; a prior history of industrial use; appropriate zoning and compatible adjoining land uses; and a positive business climate. Shell Chemical Appalachia LLC is committed to keeping people safe, protecting the environment and being a good neighbor. The proposed manufacturing facility would deliver a number of benefits for the community including employment, economic growth, and redevelopment of an existing industrial site. As the company continues with project planning, it is working with the community and other interested parties to enhance the proposed project’s potential benefits while identifying and addressing potential impacts. With the increase in North American shale gas production, particularly in the “wet gas” portions of the Marcellus and Utica shale in western Pennsylvania, West Virginia and Ohio, there has been an accompanying increase in ethane production. The resultant
  9. 9. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex availability of increased supplies of ethane at favorable prices has caused ethane to become a highly competitive feedstock for use by the petrochemical industry. The proposed Project, expected to employ 400 workers, will be comprised of an ethylene manufacturing plant with an average capacity of 1,500,000 metric tons per year.1 The ethylene that is produced will be used to supply feed to three polyethylene manufacturing units with a combined annual production of approximately 1,600,000 metric tons of polyethylene.2 Steam and electricity required for the process will be supplied by natural-gas- fired combined cycle cogeneration units (Cogen Units). The Project includes all of the ancillary units needed to support a new standalone complex including effluent treatment, storage, logistics, cooling water facilities, emergency flares, buildings, and warehouses. Excess electricity produced by the cogeneration units at the Project will be sold for distribution within the PJM grid for regional use. Shell is submitting an Air Quality Plan Approval pursuant to the Pennsylvania Air Pollution Control Act and 25 Pa. Code Ch. 127, Subch. B, to obtain approval for construction of an “air contamination source” and installation of associated air cleaning devices, including review pursuant to the pre-construction permitting requirements under the PSD and NSR programs. The analysis provided in this application addresses the requirements governing air emissions from the proposed facility including: 1) New Source Performance Standards (“NSPS”), 2) National Emission Standards For Hazardous Air Pollutants (“NESHAPS”); 3) Prevention Of Significant Deterioration (PSD)/ Best Available Control Technology (BACT) analysis for applicable pollutants for which the Project is classified as a major source located within an attainment area for such pollutant; 4) Nonattainment New Source Review (NNSR) / Lowest Achievable Emission Rate (LAER) analysis for those applicable pollutants for which the Project is classified as a major source located within a non-attainment area for such pollutant; 5) demonstration that the Project will not cause or 1 Assumes 7,500 hours per year of operation at the design capacity. 2 Assumes each of the polyethylene units will operate 8,000 hours per year at their design capcity. 1-2
  10. 10. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex contribute to an exceedance of an applicable air quality standard or increment; 6) quantification of the emissions reduction credits (i.e., offsets) required for certain pollutants in accordance with the nonattainment NSR requirements; 7) demonstration that emissions from the new sources will be the minimum attainable through use of best available technology pursuant to 25 Pa. Code §127.12(a)(5) (“PaBAT”), 8) an additional impacts analysis under 40 C.F.R. §52.21(o), and 9) an analysis as required by 25 Pa. Code §127.205(5) of alternative sites, sizes, production processes and environmental control techniques, showing that Project benefits outweigh the Project’s environmental and social costs. The Project site is located within an area that is designated as nonattainment for SO2 (1- hr), PM2.5 (annual), ozone,3 and lead (Pb) and attainment or unclassified for all other criteria pollutants under the Clean Air Act. A summary of the proposed facility’s potential to emit regulated NSR pollutants is presented in Table 1-1. As shown, emissions of NOx, PM2.5, and VOC, which are nonattainment pollutants, are above the major facility thresholds of 100, 100, and 50 tons per year, respectively. As a result, the proposed Project is subject to the nonattainment NSR requirements at 25 Pa. Code §127.201 for NOx, PM2.5, and VOC. The Project is a major facility and emissions of PM, PM10, NO2, and CO are above their respective significance thresholds of 25, 15, 40, and 100 tons per year. As a result, the Project is subject to the prevention of significant deterioration (PSD) requirements at 25 Pa. Code §127.81 for PM, PM10, NO2, and CO. The proposed Project will have CO2e emissions above the major facility threshold of 100,000 tons per year and greenhouse gas (GHG) emissions greater than the significance threshold; and as a result, the Project is subject to the PSD/BACT requirements for GHGs. Increases in sulfur dioxide (SO2) and lead (Pb) emissions are less than the major source threshold (100 tons/yr) and emissions of sulfuric acid mist are less than the PSD significance threshold (7 tons/yr). 3 All of Pennsylvania is designated nonattainment for ozone because it is a part of the Northeast Ozone Transports Region (NOTR), that was defined in the 1990 Clean Air Act Amendments. 1-3
  11. 11. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex Table 1-1. Summary of the Proposed Project’s Annual Potential to Emit Pollutants (tons) 1 1-4 Pollutant Cracking Furnaces PE Units Cogen Units Flares & Incinerators Tanks & Loading Fugitives Support Units Total Significance Threshold Subject to NSR/PSD Carbon Monoxide 670 - 43.5 277 - - 0.6 991 100 Yes Nitrogen Oxides 181 - 67.9 74.8 - - 2.8 327 100/40 Yes PM 34.1 15.3 16.9 4.6 - - 8.3 79 25 Yes PM10 86.8 4.9 59.8 8.2 - - 4.7 164 15 Yes PM2.5 86.8 4.9 59.8 8.2 - - 0.1 160 100 Yes Sulfur Dioxide 3.6 - 13.3 5.0 - - 0.0 22 100 No VOC 32.4 96.6 31.9 219 14.1 47.5 42.7 484 50 Yes CO2e 1,048,668 - 1,061,680 147,708 - 138 1,272 2,259,466 100,000 Yes Sulfuric Acid Mist 0.1 - 0.5 0.2 - - 0.0 0.9 7.0 No Total HAP 18.2 0.0 9.3 3.4 1.8 5.4 3.9 41.9 N/A N/A Polyethylene (PE) Units: includes emissions from PE processing equipment but not fugitives, flare, and thermal incinerator emissions. Support Units: includes emissions from firewater pump and emergency generator engines, cooling tower, wastewater treatment and plant roads 1. This Project may also increase emissions of other pollutants, but in minimal quantities. Appendix B includes the detailed emissions increase calculations for the proposed Project.
  12. 12. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex Under non-attainment NSR regulations, the proposed Project’s emissions of NOx, PM2.5, and VOC will be subject to the emissions offset requirement at 25 Pa. Code §127.205(3). As a result, in accordance with the offset ratios of 1.15, 1.1, and 1.15, respectively, at 25 Pa. Code §127.210(a), Shell will secure the following amounts of emissions reduction credits (ERCs): 1-5 NOx: 376 tons = (1.15) x (327 tons) PM2.5: 176 tons = (1.1) x (160 tons) VOC: 557 tons = (1.15) x (484 tons) In accordance with 25 Pa. Code §127.206(d)(1), Shell will not operate the sources until the required ERCs are provided to and processed through the ERC registry, and the Department certifies the required ERCs. A summary of the potential to emit for hazardous air pollutant (HAP) emissions is presented in Table 1-1. As shown, the total annual HAP emissions from the Project are estimated to be approximately 42 tons. The largest individual source of HAP will be the Cracking Furnaces, which will have the potential to emit 18.2 tons of total HAP. 1.2 Overview of Process Ethane, the primary raw material for the proposed Project, is a natural gas liquid, or NGL, that exists in certain natural gas deposits including the Marcellus and Utica Shales. (Propane and butane are examples of other NGLs.) Natural gas companies remove NGLs from natural gas, with the natural gas (mainly methane) to be shipped by pipeline for use as a fuel by residences, power plants, and industry. The NGLs are used for a variety of industrial, residential, and commercial uses. Ethane’s primary use is as a feedstock used to create ethylene. Ethylene is an important first step in creating many of the products in everyday use. This facility will process the ethylene to make different types of polyethylene. Different grades of polyethylene are used to make different types of products:
  13. 13. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex  low-density polyethylene (LDPE) and linear low density polyethylene (LLDPE) are the raw materials for flexible items like food packaging, film, trash bags, diapers, toys, and housewares;  high density polyethylene (HDPE) is used to create “stiffer” products such as crates, drums, bottles, food containers, and other types of housewares. The proposed Project will consist of an ethylene manufacturing process, three (3) polyethylene manufacturing units, three Cogen Units, and a variety of ancillary equipment required to support the overall plant operations. The proposed Project’s cracking funaces units will “crack” ethane (C2H6) to create ethylene (C2H4). This is accomplished by heating the ethane to very high temperatures, greater than 1500°F (800°C). “Tail gas,” a byproduct from the cracker furnaces that contains methane and a high percentage of hydrogen, will be recycled to fuel the process, with natural gas used to supplement the process’s energy requirements. The ethylene manufacturing process will consist of seven (7) cracking furnaces that will be capable of converting ethane into ethylene at a maximum rate of 1,500,000 metric tons per year.4 The ethylene that is produced will be used to feed two gas phase polyethylene manufacturing units and one slurry technology unit. The two gas phase units will be designed to produce 550,000 metric tons per year of polyethylene each, while the slurry unit will be designed to produce 500,000 metric tons per year.5 Both technologies employ catalyst, but use different equipment and operating parameters to produce each specific grade of polyethylene. Each unit will have separate pellet handling systems prior to blending. Common storage equipment, rail car, and truck loading operations will follow the blending. To support the overall plant operations, three on-site natural gas-fired combustion turbines/duct burners and heat recovery steam generators (HRSGs) will be used to generate electricity and steam. Other ancillary equipment will include four emergency diesel generators and three diesel-driven firewater pumps, two cooling towers, numerous 4 Assumes 7,500 hours per year of operation at the design capacity. 5 Each polyethylene unit is assumed to operate 8,000 hours per year at its design capcity. 1-6
  14. 14. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex storage tanks and pressure vessels for raw materials and by-products, and a wastewater treatment facility. Additionally, the Project will include the necessary air pollution control devices to meet all applicable federal and state requirements. For a more detailed description of the processes and supporting equipment proposed for this Project, please refer to Section 3.0. 1-7 1.3 Site Description The Shell facility will occupy approximately 400 acres on the site of the zinc smelter currently owned by the Horsehead Corporation. The site is located adjacent to the Ohio River in Beaver County, Pennsylvania.. The approximate Universal Transverse Mercator (UTM) coordinates of the facility are 556,129 meters east and 4,502,450 meters north (UTM Zone 17, NAD 83). Figure 1-1 shows the general location of the facility. Figure 1-2 shows the specific facility location on a 7.5-minute U.S. Geological Survey (USGS) topographic map. Beaver County is located in western Pennsylvania, with its western boundary bordering the Ohio State line. The Ohio River generally runs through the center of the county and flows in a westerly direction. The Beaver River drains the northern portion of the county, converging with the Ohio approximately 5km upstream of the proposed site location. The cutting of these rivers has formed the hills and valleys of this region, whose local difference in elevation constitutes the relief of the county. Thus, north of the Ohio the highest land, or main divide, rises about 600 feet above the river. The relief of the area lying between Beaver River and Crow Run is about 550 feet above the Ohio River. The tributaries south of the Ohio form a main divide which rises at most 650 feet above the river. Winters are cold and snowy at high elevations in Beaver and Lawrence Counties. In the valleys it is also frequently cold, but intermittent thaws preclude a long-lasting snow cover. Summers are fairly warm on mountain slopes and very warm with occasional very hot days in the valleys. Rainfall is evenly distributed throughout the year, but it is appreciably heavier on the windward, west facing slopes than in the valleys. Normal
  15. 15. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex Figure 1-1. General Location of the Shell Facility 1-8
  16. 16. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex 1-9 Figure 1-2. Proposed Facility Location
  17. 17. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex annual precipitation is adequate for all crops, although summer temperature and growing season length, particularly at higher elevations, may be inadequate. The lowest temperature on record, which occurred at New Castle on January 29, 1963, is -23 degrees. In summer the average temperature is 70 degrees, and the average daily. maximum temperature is 80 degrees. The highest recorded temperature, which occurred at New Castle on September 2, 1953, is 100 degrees. The total annual precipitation is 38 inches. Of this, 22 inches, or 60 percent, usually falls in April through September, which includes the growing season for most crops. In two (2) years out of 10, the rainfall in April through September is less than 17 inches. The heaviest 1-day rainfall during the period of record was 3.70 inches at New Castle on October 16, 1954. Thunderstorms occur on about 36 days each year and most occur in summer. Heavy rains, which occur at any time of the year, and severe thunderstorms in summer sometimes cause flash flooding, particularly in narrow valleys. Average seasonal snowfall is 42 inches. The greatest snow depth at any one time during the period of record was 19 inches. On average, there are 24 days a year with at least 1 inch of snow on the ground. The number of such days varies greatly from year to year. The average relative humidity in mid afternoon is about 60 percent. Humidity is higher at night, and the average at dawn is about 80 percent. The sun shines 60 percent of the time possible in summer and 35 percent in winter. The prevailing wind is from the southwest. Average wind speed is highest, 12 miles per hour, in winter. 1-10 1.4 Project Schedule Construction activities are planned to start in late 2015 and to continue for approximately 24 months. Operation is planned to commence in 2018. 1.5 Document Overview The contents of this document are organized as follows: Section 1.0 provides an overview of the Project, a description of the proposed site’s location and surrounding terrain and local climate in Beaver County, Pennsylvania, and a summary of the pollutant-by-pollutant emissions increases. Section 2.0 contains a summary of the permit application requirements.
  18. 18. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex Section 3.0 contains the process description. Each of the manufacturing processes which comprise the proposed Project are described along with the points and types of emissions from each point. Also included is a description of the various outside the boundary limits (OSBL) elements of the Project. Section 4.0 contains an overview of all of the air regulatory requirements to which the proposed Project is subject. This includes a description of both state and federal requirements. Section 5.0 contains the Lowest Achievable Emissions Rate (LAER), Best Available Control Technology (BACT) and Pennsylvania Best Available Technology (PaBAT) analyses required in support of the plan approval process. Section 6.0 contains a summary of the results from the air dispersion modeling analysis performed in support of the plan approval process for the PSD criteria pollutant for which the Project is subject to review (i.e., NO2, CO, and PM10). Section 7.0 contains the additional impacts analysis required under 40 CFR §52.21(o). Appendices A – Plan Approval Application Forms B – Detailed Emissions Increase Calculations C – Air Dispersion Modeling Report D – Trade Secret and/or Confidential Proprietary Information (Not in 1-11 Public Version) E – 25 Pa. Code §127.205(5) Analysis F – Additional Support Material G – Summary of Compliance Demonstration
  19. 19. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex 2.0 Permit Application Requirements Pursuant to the requirements of Title 25 of the Pennsylvania Code Chapter 127, Construction, Modification, Reactivation, and Operation of Sources, this application contains the following:  Identification of the location of the source and the name, title, address, and telephone number of the individual responsible for the operation of the source. This general information is provided in Section 1.0, in the Plan Approval forms located in Appendix A, and in the General Information Form located in Appendix F.  Information that is requested by the Department and is necessary to perform a thorough evaluation of the air contamination aspects of the source is provided in the Plan Approval forms located in Appendix A or in this document as referenced within the forms.  A demonstration that the source will be equipped with reasonable and adequate facilities to monitor and record the emissions of air contaminants and operating conditions which may affect the emissions of air contaminants and that the records are being and will continue to be maintained and that the records will be submitted to the Department at specified intervals or upon request. Compliance information is provided in the Plan Approval forms, as well as, Appendix G. Specific equipment in many cases is still to be determined, however, the criteria for the design and/or purchase of equipment is set forth by the compliance requirements of the applicable regulations noted in Section 4.0.  A demonstration that the source will comply with applicable requirements of this article and requirements promulgated by the Administrator of the EPA under the Clean Air Act (42 U.S.C.A. §§ 7401-7706). The applicability of Federal regulations under the Clean Air Act are presented in Section 4.0. A detailed listing of the compliance requirements and demonstration cited by each applicable regulation is provided in Appendix G on an affected source basis. This listing also provides citations for recordkeeping and reporting requirements.  A demonstration that the emissions from a new source will meet the control technology and emission limitations of applicable federal and state regulations is presented in Section 5.0. This section contains a full control technology review for all pollutants and contaminants subject to PSD/NSR, BACT/LAER and PaBAT, respectively.  A demonstration that the source will not prevent or adversely affect the attainment or maintenance of ambient air quality standards. A summary of 2-1
  20. 20. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex the results from an air quality analysis performed for the proposed Project is presented in Section 6.0. A report detailing the analysis is included as Appendix C;  A plan of action for the reduction of emissions during each level specified in Chapter 137 (relating to air pollution episodes), when required by the Department. As noted in Section 4.0, a plan will be developed and implemented when requested by the Department.  Copies of letters of notification to local municipalities and proof that the notices were received are contained in Appendix F.  A plan for dealing with air pollution emergencies, when requested by the Department, or when required by the Clean Air Act. A plan will be developed and implemented as required.  A demonstration that the source and the air cleaning devices are capable of being and will be operated and maintained in accordance with good air pollution control practices. As described in Section 5.0, Shell proposes to satisfy the applicable BACT, LAER, and PaBAT requirements through the design,installation, and operation of air cleaning devices capable of achieving the proposed limits and/or the operation of process equipment to minimize air contamination through accepted work practices.  A completed compliance review form is presented in Appendix F. In addition to the requirements of 25 Pa. Code § 127, the DEP plan approval application must also include a completed Cultural Resource Notice (CRN) and return receipt. The Pennsylvania State History Code (Title 37, § 507) requires a completed Cultural Resource Notice and return receipt as part of the DEP plan approval process where more than 10 acres of earth will be disturbed. To meet this criteria, URS Coprporation on behalf of Horsehead Corporation and Shell previously filed a CRN for a joint water permit amendment. A copy of this CRN and return receipt are provided in Appendix F. 2-2
  21. 21. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex 3.0 Process and Emission Source Descriptions This section presents the process description and emission source descriptions for the proposed Project. The description is organized by processing areas as follows:  Ethylene Manufacturing  Polyethylene Manufacturing  Combustion Turbines and Duct Burners  Utilities & General Facilities The objective of the Project is to convert ethane into ethylene and then to convert ethylene into linear, low density polyethylene (LLDPE) and high-density polyethylene (HDPE) pellets that can be shipped to plastic manufacturing facilities. Typical manufacturing uses for LLDPE include: 3-1  Plastic bags and sheets,  Plastic wrap,  Stretch wrap,  Toys,  Covers and lids,  Pipes,  Buckets and containers,  Covering of cables,  Geo-membranes, and  Flexible tubing. Typical manufacturing uses for HDPE include:  3-D printer filament,  Arena board (puck board),  Bottle caps,  Chemical resistant piping systems,  Coax cable inner insulator,  Food storage containers,  Fuel tanks for vehicles,  Electrical and plumbing boxes,  Folding chairs and tables,  Hard hats,  Plastic bags,
  22. 22. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex  Plastic bottles suitable both for recycling (such as milk jugs) or re-use,  Storage sheds, and  Water pipes for domestic water supply and agricultural processes The manufacturing process for LLDPE and HDPE begins with pyrolysis of a hydrocarbon to make ethylene. Ethylene is then converted into LLDPE and HDPE pellets. The Project will take ethane, a product of shale gas production in Pennsylvania and neighboring states, and convert it to ethylene by pyrolysis in large furnaces. Ethylene in the pyrolysis gas exiting the furnaces will be separated from the pyrolysis gas and purified for the manufacture of LLDPE and HDPE. A number of utilities are required to support these processes including: steam, electricity, process water, cooling water, wastewater treatment, tanks, flares, storage and loading operations. The following subsections describe each process in more detail and characterize the air emissions sources. 3.1 Ethylene Manufacturing Process 3-2 3.1.1 Process Description Figure 3-1 presents the process flow diagram for the ethylene manufacturing process. Ethane is thermally cracked into ethylene, propylene, methane, hydrogen, and other by-products in the pyrolysis furnaces at temperatures up to ~1560°F in the presence of steam. The furnaces act as pyrolysis reactors in which a wide range of mainly light hydrocarbons are produced. The general chemical reaction scheme is: C2H6 + heat → C2H4 + H2 Ethane conversion in the furnaces is typically 65-72% and is optimized depending on the availability of ethane. Any methane that is contained in the feedstock is not pyrolyzed and travels through the furnaces unchanged. Thus, it is not included in the equation. Steam is used as a diluent to control the pyrolysis reactions and is also not shown in the equation. Several byproducts are produced as part of the ethane cracking process including carbon, which is deposited as coke in the furnace tubes, unreacted ethane and polymerized carbon compounds (C3+, gasoline, tar/coke/pitch). The Project includes
  23. 23. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex 3-3 Figure 3-1. Ethane Cracker Process Flow
  24. 24. Shell Chemical Appalachia LLC Plan Approval Application Beaver County, Pennsylvania Petrochemicals Complex seven cracking furnaces, which will be operated in parallel. One hundred percent of the plant’s annual ethylene production rate (1,500,000 metric tons)6 will be achieved through six furnaces in cracking operation while the seventh furnace is in either decoking, in hot-standby 3-4 or off-line for maintenance. After leaving each furnace radiant section, the hot cracked gases are cooled while generating super high pressure (SHP) steam. The SHP-steam is used to drive the cracker’s main compressor. Next, the cooled cracked gases are quenched with water to reduce the volume of gas that must be compressed prior to cryogenic separation and purification of the ethylene product. The quench water is also used to partially absorb acidic components formed in the furnaces from traces of additives used for equipment protection and impurities present in the ethane feedstock. In the quench tower the cracked gas is cooled to ambient temperature. Gasoline as well as process steam is condensed. The purified and cold cracked gas exiting through the top of the quench tower is directed to the compression section. Circulating quench water is withdrawn from the bottom of the quench tower and pumped to the process sections for heat recovery. Excess water and gasoline are separated by gravity. The water is cleaned in the process steam system and then reused as dilution steam. Solid components (coke/pitch/tar) are removed from the process water by gravitational deposition and sent offsite for either use or disposal. The pyrolysis tar and light gasoline7 are stored in separate tanks before being shipped offsite for further processing into products. The possibility of combining the pyrolysis tar with the coke/pitch/tar is being considered. The combined stream would be stored in the pyrolysis tar tank prior to being shipped offsite. 6 Assumes 7,500 hours per year of operation at the design capacity. 7 Pyrolysis tar is primarily heavy oil (>85%) with less amounts of C9+ components (4-14 %), water, and traces of benzene, toluene and styrene (all <0.1%). Light gasoline is primarily benzene, toluene xylene, ethyl benzene, and styrene (40-45%) with the remainder being compounds in the C2-C5 range.