Engineering Evaluation

ConocoPhillips Company, Plant 16

Ultra Low Sulfur Diesel / Strategic Modernization Project

Application 5814

Prepared By: Julian Elliot, Senior Air Quality Engineer

**TABLE OF CONTENTS**

[**1.0 BACKGROUND** 1](#background)

[**2.0 NEW AND MODIFIED SOURCES** 2](#__RefHeading___Toc39114831)

[**2.1 New S-460 ULSD Hydrotreater and Heater**
2](#__RefHeading___Toc39114832)

[**2.2 S-304 Hydrotreater Service Change**
3](#__RefHeading___Toc39114833)

[**2.3 Crude Unit and Crude/Coker Unit and Heater Modifications**
3](#__RefHeading___Toc39114834)

[**2.4 Amine Scrubbers / Strippers** 5](#__RefHeading___Toc39114835)

[**2.5 Sulfur Recovery Plants S-1002, S-1003**
5](#__RefHeading___Toc39114836)

[**2.6 Sour Water Strippers** 7](#__RefHeading___Toc39114837)

[**2.7 Butane and Fuel Gas Caustic Treatment**
8](#__RefHeading___Toc39114838)

[**2.8 Wastewater Treatment System** 9](#__RefHeading___Toc39114839)

[**2.9 ULSD Cooling Tower (Exempt)** 9](#__RefHeading___Toc39114840)

[**2.10 Fugitive Components** 10](#__RefHeading___Toc39114841)

[**2.11 Relief and Flare System** 10](#__RefHeading___Toc39114842)

[**2.12 Steam / Power Plant** 11](#__RefHeading___Toc39114843)

[**2.13 Storage Tanks** 11](#__RefHeading___Toc39114844)

[**2.14 Shipping Activity** 13](#__RefHeading___Toc39114845)

[**3.0 EMISSIONS CALCULATIONS** 14](#__RefHeading___Toc39114847)

[**3.1 Annual Average Emissions:** 14](#__RefHeading___Toc39114848)

[**3.2 Daily Emissions** 21](#__RefHeading___Toc39114849)

[**4.0 FACILITY CUMULATIVE INCREASE** 22](#__RefHeading___Toc39114850)

[**5.0 TOXIC RISK MANAGEMENT** 22](#__RefHeading___Toc39114851)

[**5.1 S-461, S-36 Combustion Emissions**
24](#__RefHeading___Toc39114852)

[**5.2 Ammonia Slip Emissions from A-461, A-36**
25](#__RefHeading___Toc39114853)

[**5.3 Organic Compounds in Fugitive Emissions**
26](#__RefHeading___Toc39114854)

[**5.4 Toxic Risk Assessment** 28](#__RefHeading___Toc39114856)

[**6.0 NEW SOURCE REVIEW** 28](#__RefHeading___Toc39114857)

[**6.1 Best Available Control Technology (BACT)**
28](#__RefHeading___Toc39114858)

[**6.2 Emission Offsets** 32](#__RefHeading___Toc39114859)

[**6.3 Prevention of Significant Deterioration (PSD)**
34](#__RefHeading___Toc39114860)

[**7.0 CEQA** 35](#__RefHeading___Toc39114861)

[**8.0 REFINERY SO2 BUBBLE** 35](#__RefHeading___Toc39114862)

[**9.0 DISTRICT PROHIBITORY RULES** 36](#__RefHeading___Toc39114863)

[**9.1 Regulation 6 (Particulate Matter and Visible Emissions)**
36](#__RefHeading___Toc39114864)

[**9.2 Regulation 8, Rule 5 (Storage of Organic Liquids)**
36](#__RefHeading___Toc39114865)

[**9.3 Regulation 8, Rule 18 (Equipment Leaks)**
36](#__RefHeading___Toc39114866)

[**9.4 Regulation 8, Rule 28 (Episodic Releases)**
37](#__RefHeading___Toc39114867)

[**9.5 Regulation 9, Rule 1 (Sulfur Dioxide)**
37](#__RefHeading___Toc39114868)

[**9.6 Regulation 9, Rule 2 (Ground Level Hydrogen Sulfide
Concentration)** 38](#__RefHeading___Toc39114869)

[**9.7 Regulation 9, Rule 10 (NOx and CO in Petroleum Refineries)**
38](#__RefHeading___Toc39114870)

[**9.8 Regulation 10 (Standards of Performance for New Stationary
Sources)** 38](#__RefHeading___Toc39114871)

[**9.9 Regulation 11, Rule 7 (Benzene)**
38](#__RefHeading___Toc39114872)

[**9.10 Regulation 2-1-412 (Public Notification/K-12 Schools)**
38](#__RefHeading___Toc39114873)

[**10.0 FEDERAL REQUIREMENTS** 39](#__RefHeading___Toc39114874)

[**10.1 New Source Performance Standards (NSPS)**
39](#__RefHeading___Toc39114875)

[**10.2 National Emission Standards for Hazardous Air Pollutants
(NESHAPS)** 39](#__RefHeading___Toc39114876)

[**10.3 Maximum Achievable Control Technology (MACT)**
40](#__RefHeading___Toc39114877)

[**11.0 PERMIT CONDITIONS** 40](#__RefHeading___Toc39114878)

[**11.1 Sources with Modified Conditions**
40](#__RefHeading___Toc39114879)

[**11.2 New/Modified Sources** 43](#refheading___toc39114880)

[**12.0 RECOMMENDATION** 48](#__RefHeading___Toc39114881)

#### 1.0 BACKGROUND

ConocoPhillips Petroleum (ConocoPhillips) has submitted an application
to install new sources and modify existing sources and processes at the
San Francisco Refinery in Rodeo. This project will accomplish three
objectives: 1) allow production of ultra low sulfur diesel (ULSD)
through increased hydrotreating, 2) allow the refinery to process a
greater range of crude oils, and 3) maintain gasoline production level
at current levels while increasing diesel production and crude
processing capacity. After modifications are complete gasoline
production may increase by a nominal amount of approximately 500
bbl/day, while gas oil and diesel production are expected to increase by
approximately 4,000 bbl/day each, and crude oil processing capacity will
increase by 10,000 bbl/day. \[Gas oil is a generic term for a medium
distillate with a boiling point above 350 degrees F, which is used as an
intermediate feedstock.\]

ULSD is defined as diesel fuel with a sulfur content of no more than 15
ppmw. The use of ULSD fuel in motor vehicles is required by existing
federal regulations, and expected state regulations, by June 1, 2006.
ConocoPhillips expects to produce ULSD as much as 2 years in advance of
this deadline through this project.

The additional crude oil processed at the refinery will come primarily
from the Central Valley of California. This crude has a relatively high
sulfur content.

In addition to the production of ULSD (at higher levels than the current
production of low-sulfur diesel), the proposed project will result in
increased production of butane, fuel gas, sulfur and coke. There will be
no net increase in water consumption or wastewater discharge although
the composition of discharged water may change as discussed in the
project EIR. The existing facility steam/power plant will meet
additional electrical requirements.

ConocoPhillips has estimated increased sour gas production of up to 1.7
million standard cubic feet per day, as well as increased production of
sour water. The systems which remove sulfur compounds from sour gas and
sour water streams will be upgraded to increase their removal capacity,
as will the sulfur plants which convert these sulfur compounds to
elemental sulfur (see Sections 2.4, 2.5 and 2.6). Nonetheless, increased
sulfur compound emissions are a concern, especially SO2 emissions
resulting from increased combustion of fuel gas (since increased sour
gas production will ultimately result in higher volumes of fuel gas) or
from higher levels of sulfur compounds in fuel gas. This concern is
addressed by the existing sulfur bubble in Condition 1694. This
condition requires analysis of sulfur compounds in fuel gas three times
per day, and includes an SO2 emission limit from fuel gas combustion for
all refinery combustion sources except the steam/power plant. The SO2
bubble ensures that increased processing of crude oil, and the
processing of crude stocks containing higher sulfur levels, will not
result in SO2 emissions beyond permitted levels.

[]{#__RefHeading___Toc39114831 .anchor}**2.0 NEW AND MODIFIED SOURCES**

This section addresses the new sources, modified sources and operational
changes which may result in emission increases. Where an emission
increase is identified, the increase is quantified in Section 3.0
("Emissions Calculations").

In addition to the new and modified sources discussed below, the project
EIR quantifies emission increases to existing sources resulting from
operational changes caused by the proposed project. Specifically,
existing tanks will undergo service changes which will result in a net
reduction in emissions (EIR, Appendix C, Section A.7), and existing
heaters will undergo firing duty changes and changes in the level of
sulfur compounds in fuel gas (EIR, Appendix C, Section A.3) which will
result in a net emission increase. These emission changes are summarized
in the project EIR (Appendix C, Table A-22). These operational changes
and resulting emission increases are within the scope of existing
permits and therefore do not represent source "modifications" as
described in Regulation 2-1-234.

[]{#__RefHeading___Toc39114832 .anchor}**2.1 New S-460 ULSD Hydrotreater
and Heater**

S-460 is a new ULSD hydrotreater (Unit 250). A hydrotreater reacts
petroleum compounds with hydrogen in the presence of a catalyst to
remove sulfur from the petroleum in the form of H2S gas, and to
hydrogenate unsaturated compounds. S-460 will be the primary mechanism
for removal of additional sulfur to meet ULSD standards. S-460 will
hydrotreat diesel cuts from the various processing units, including the
S-350 crude unit (Unit 267) and the S-300 crude/coker (Unit 200).

S-460 will have a capacity of 35,000 bbl/day, and will consist of two
towers, both about 14 feet in diameter, with heights of about 70 feet
and 85 feet. S-460 will include a new 50.2 MM BTU/hr charge heater which
will be permitted as S-461, and which will be abated by the A-461 SCR
system. S-461 will burn refinery gas, with natural gas as a backup fuel.
In addition to a reduced-sulfur diesel stock, S-460 will produce fuel
gas and a naphtha stock. S-460 will utilize an existing, but unused,
refinery cooling tower (S-500) to provide required cooling water.

**2.1.1 New ULSD Hydrotreater Emissions**

Processing units like S-460, which have no discrete emission points are
not charged emissions directly. Instead, emissions are quantified for
fugitive components (which are not assigned source numbers) and for
associated combustion sources (which are permitted as separate sources).
Fugitive emissions are considered in Section 2.10.

The ULSD Hydrotreater will have the capability of being purged with
nitrogen during removal from service. The vaporizer will use indirect
contact with steam and ambient air to vaporize the liquid nitrogen.
Thus, the nitrogen vaporizer is not a combustion source and will not be
considered further in this evaluation.

**2.1.2 New ULSD Hydrotreater Charge Heater (S-461) Emissions**

Emissions from the new S-461 Heater are quantified in Section 3.1.1.

[]{#__RefHeading___Toc39114833 .anchor}**2.2 S-304 Hydrotreater Service
Change**

The new S-460 hydrotreater will replace the existing S-304 diesel
hydrotreater (Unit 229) in diesel service. S-304 will be switched to
naphtha hydrotreating service, to supplement the naphtha hydrotreating
capacity of the existing S-305 hydrotreater (Unit 230). S-304 will be
modified to treat light naphtha streams, while S-305 will treat medium
naphtha streams. Together, the two naphtha hydrotreaters will allow
additional removal of sulfur from gasoline feedstocks. S-304 will be
modified by replacement of the hydrotreater reactor and by modification
of heat exchangers, and will have a naphtha processing capacity of
12,198 bbl/day. Converting S-304 to naphtha service will allow the
retirement of one S-305 distillation tower.

**2.2.1 S-304 Hydrotreater Service Change Emissions**

Processing units like S-304, which have no discrete emission points are
not charged emissions directly. Instead, emissions are quantified for
fugitive components (which are not assigned source numbers) and for
associated combustion sources (which are permitted as separate sources).
Fugitive emissions are considered in Section 2.10.

[]{#__RefHeading___Toc39114834 .anchor}**2.3 Crude Unit and Crude/Coker
Unit and Heater Modifications**

Currently, crude oil may be processed at either the S-350 crude unit
(Unit 267) or the S-300 crude/coker (Unit 200), with S-350 handling
light foreign crudes and S-300 handling heavy or sour crudes, as well as
semi-refined crude stocks. S-350 consists of a desalter followed by
vacuum and atmospheric distillation towers, while S-300 consists of
vacuum and atmospheric distillation towers followed by a delayed coker.
Currently, bottoms streams from both the S-350 and S-300 distillation
towers are processed as parallel feedstreams at the S-300 coker. The
proposed units will modify this flow by processing the S-350 bottoms at
the S-300 vacuum tower, with the S-300 bottoms continuing to the S-300
coker.

Currently, Condition 476 limits the feed rate at S-300, while Condition
383 limits the feed rate at S-350. No change has been proposed to the
feed rate limit for S-350 (33,000 bbl/ highest day, 30,000 bbl/annual
average day). The total feed rate for S-300 is proposed to increase from
56,000 bbl/highest day (52,000 bbl/annual average day) to 81,000
bbl/highest day. This total increase of 25,000 bbl/day is expected to
consist of the following:

  --------------------------------------------------- -------------------
  **Increased S-300 feedstream**                      **Feed Rate
                                                      (bbl/day)**

  imported crude oil                                  10,000

  imported diluent                                    6,000

  facility bottoms streams                            9,000

  **Total**                                           **25,000**
  --------------------------------------------------- -------------------

The proposed modifications include internal modification of S-350 to
allow the unit to process a greater range and increased amount of crude
oil. Also, the vacuum and atmospheric distillation towers at S-300 are
at the end of their service lives and will be replaced with new towers
with increased capacity. The secondary distillation tower will be about
12.5 feet in diameter and 125 feet tall, while the vacuum tower will be
about 15 feet in diameter and 58 feet tall.

A new 82.1 MM BTU/hr process heater will be added to S-300. This heater
will be permitted as S-36 and will be abated by the A-36 SCR system.
S-36 will be used to heat the feed stream to the crude unit vacuum
tower. S-36 will burn refinery gas, with natural gas as a backup fuel.

Two operational changes involve the flow of diesel streams and
wastewater from S-350. Currently, diesel streams from S-350 flow
directly to blending units. As noted above, diesel streams are proposed
to be treated at the new S-460 hydrotreater. However, these diesel
streams may flow to storage tanks from S-350, prior to treatment at
S-460. Existing tankage will be used for this purpose. Wastewater from
S-350 currently flows directly to the refinery sewer system. After
modification, S-350 wastewater will flow to a storage tank, and then
will be processed at the sour water strippers and the selenium plant
prior to discharge into the sewer system. Existing tankage will be used
for intermediate storage of wastewater. Storage tanks are discussed in
Section 2.13.

**2.3.1 Crude Unit and Crude/Coker Unit Modification Emissions**

Processing units like S-350 and S-300, which have no discrete emission
points are not charged emissions directly. Instead, emissions are
quantified for fugitive components (which are not assigned source
numbers) and for associated combustion sources (which are permitted as
separate sources). Fugitive emissions are considered in Section 2.10.

Increased coker activity will result in increased production of coke
(186 ton/day). Also, truck traffic associated with coke removal will
increase about 17%, from 48 truckloads per day to 56 truckloads per day.
Emissions from truck traffic are considered in Section 2.14. Emissions
from coke handling are quantified in Section 3.1.6.

**2.3.2 Crude Unit Vacuum Tower Heater (S-36) Emissions**

Emissions from the new S-36 Heater are quantified in Section 3.1.2.

[]{#__RefHeading___Toc39114835 .anchor}**2.4 Amine Scrubbers /
Strippers**

H2S-rich gas from hydrotreaters and other sources is currently processed
at two amine scrubbers. The scrubbers use diglycolamine (DGA) as a
solvent to scrub H2S from these gases. Then, the H2S-rich scrubbing
solution is processed at three amine strippers where heat is used to
drive the H2S from the amine solution. The stripped H2S-rich gas is
treated at the refinery sulfur recovery plants where H2S is converted to
elemental sulfur.

The proposed modifications will not affect the two amine scrubbers.
However, the heat exchangers in two of three amine strippers will be
replaced to increase the effectiveness of the strippers.

**2.4.1 Amine Scrubbers / Strippers Emissions**

Processing units like the amine strippers and scrubbers, which have no
discrete emission points are not charged emissions directly. Instead,
emissions are quantified for fugitive components (which are not assigned
source numbers). Fugitive emissions are considered in Section 2.10.

The two refinery hydrogen plants will provide steam required by the
amine strippers. Specifically, heaters S-14 and S-438 will produce this
steam. All facility steam sources, including S-14 and S-438 in Condition
1694, have existing permit conditions limiting fuel use. Therefore,
increased production of steam will not be considered a modification and
an emission increase will not be quantified. It should be noted that
some aspects of the project, most notably the removal from service of a
distillation tower at S-305 will result in substantial steam savings.

[]{#__RefHeading___Toc39114836 .anchor}**2.5 Sulfur Recovery Plants
S-1002, S-1003**

The refinery currently operates three sulfur recovery plants that use
the Claus process to convert sulfur-containing acid gas to elemental
sulfur. Acid gas is produced by hydrotreaters, the hydrogen plants, fuel
gas treatment unit and butane treatment units. The first step of the
conversion process involves the thermal reaction of one third of the H2S
with oxygen to form SO2. This thermal reaction occurs at temperatures
ranging from 1,800 to 2,800 degrees F, with the reaction furnace heated
by burners. The oxygen is typically provided by introducing air to the
reaction chamber. However, the process can be made more efficient by
using pure oxygen instead of air. The thermal reaction equation is:

2H~2~S + 3O~2~ → 2SO~2~ + 2H~2~O + heat of reaction

Because air is only 21% oxygen by volume, with the balance nitrogen and
traces of argon, the substitution of oxygen for air dramatically reduces
the volume of reaction gas, or allows the processing of more acid gas at
the same furnace heat load and size. The proposed modifications include
the conversion of two of the sulfur recovery plants (S-1002, S-1003) to
use pure oxygen. Sulfur plant S-1001 will not be modified. Liquid oxygen
will be imported by tanker truck and stored onsite. This modification is
expected to increase the sulfur recovery capacity by 15% at each of the
modified plants, without increasing the fuel requirements for the
thermal reaction at these plants.

The sulfur plant has a daily capacity of 245 long tons of sulfur per day
(nominal capacities of 70, 75 and 100 long ton/day at S-1001, S-1002 and
S-1003, respectively). \[Note: Sulfur plant capacity is expressed in
"long" or "metric" tons. The equivalent nominal capacities of each
sub-plant in "short" or "U.S." tons are 78, 84 and 112 short ton/day, or
a total capacity of 274 short ton/day.\] The sulfur plant will require
an increased sulfur-removal capacity of about 25 long ton/day (expressed
as sulfur) to handle the increased sulfur load from the increased crude
feed rate, additional hydrotreating of diesel, and the processing of
alternate crude stocks. A 15% increase in capacity at S-1002 and S-1003
represents a total increase of over 26 long ton/day. Thus, overall
capacity would increase from 245 long ton/day to 271 long ton/day.

The oxygen vaporizers will use indirect contact with ambient air to
vaporize the liquid oxygen. Thus, these vaporizers are not combustion
sources and will not be considered further in this evaluation.

In addition to molten sulfur, the sulfur plants produce a tailgas stream
that contains residual H2S. The tailgas stream from each sulfur plant is
treated at a dedicated treatment plant that uses the Beavon Stretford
process. The Beavon Stretford process uses a catalytic reaction to
convert both H2S and SO2 in the tailgas to H2S, which is then removed in
a liquid absorber. The absorbing liquid stream undergoes a reaction to
convert H2S to elemental sulfur.

**2.5.1 Sulfur Recovery Plants S-1002, S-1003 Emissions**

The exhaust stream from each Beavon Stretford treatment plant contains a
residual amount of H2S. If the increased processing of crude or the
increased sulfur load increases the residual H2S concentration and/or
increases the volume of the exhaust stream(s), then the overall
emissions of H2S would increase. As discussed above, ConocoPhillips has
indicated that the use of pure oxygen at the two modified sulfur plants
will increase the capacity of these plants by about 15%. This capacity
increase is estimated to exceed the actual increase in sulfur loading.
However, if the two plants were loaded to capacity, approximately 15%
more sulfur would be produced and 15% more H2S and SO2 would remain in
the tailgas. However, the volume of tailgas would decrease because the
replacement of air with oxygen would eliminate the nitrogen in the
combustion air. Therefore, emissions of H2S and S02 are not expected to
increase at these sources.

Sulfur plants S-1001, S-1002 and S-1003 currently have separate implied
throughput limits of 70, 75 and 100 long tons/day, respectively, based
on data forms submitted to the District. In reality, these limits
represent nominal capacities for each plant. In the event that a single
plant is removed from service, the remaining plants could exceed these
nominal capacities. However, the current total capacity of the three
plants is equivalent to the total of these nominal capacities: 245 long
tons/day. Each sulfur plant discharges molten sulfur to an associated
sulfur pit (S-301, S-302, S-303). The three pits are interconnected, and
all share a common truck loading point. Thus, the sulfur pits are most
accurately described as also having a total capacity of 245 long
tons/day. The proposed modifications to S-1002 and S-1003 are expected
to increase the nominal capacity of each 15%. The overall increase in
sulfur capacity would be:

(75 + 100) long tons/day (0.15) = 26 long ton/day

Thus, the new overall sulfur production limit would be:

(245 + 26) long ton/day = 271 long ton/day

[]{#__RefHeading___Toc39114837 .anchor}**2.6 Sour Water Strippers**

Sour water contains sulfur compounds or ammonia, and is produced
whenever steam is condensed in the presence of gases containing these
compounds, including hydrotreating and sulfur plant tailgas treatment
(both discussed above). Sour water is odorous and must be treated to
remove sulfur compounds and ammonia prior to discharge into the refinery
sewer system. The refinery currently operates two sour water strippers
with a combined processing capacity of 280 gallons per minute. The
proposed modifications include the addition of a new stripper with a
capacity of 230 gallons per minute. The new stripper would be used with
one of the existing strippers, to provide an increased processing
capacity of about 360 gallons per minute. The other existing stripper
would be available as a backup, but would not normally be in service.

Sour water strippers use steam to strip contaminants from sour water
into a gas phase, that is condensed to produce a contaminant-rich,
non-condensable gas stream and a condensate stream. Condensate liquid is
recycled to the stripper, while the non-condensable stream is vented to
a sulfur recovery plant.

**2.6.1 Sour Water Stripper Emissions**

The sour water strippers have no discrete emission points. Fugitive
emissions are considered in Section 2.10.

The two refinery hydrogen plants will provide steam required by the sour
water strippers. Specifically, heaters S-14 and S-438 will produce this
steam. All facility steam sources, including S-14 and S-438 in Condition
1694, have existing permit conditions limiting fuel use. Therefore,
increased production of steam will not be considered a modification and
an emission increase will not be quantified. It should be noted that
some aspects of the project, most notably the removal from service of a
distillation tower at S-305, will result in substantial steam savings.

Sulfur compounds in the non-condensable gas stream are included in the
emission increase from the sulfur recovery plant (discussed above).

[]{#__RefHeading___Toc39114838 .anchor}**2.7 Butane and Fuel Gas Caustic
Treatment**

The proposed modifications, as a result of the increased processing of
crude stocks, will result in greater production of organic gases. One of
these gases, butane, is a saleable product. Other gases are used as fuel
for refinery combustion sources. Both butane and fuel gases require
treatment to reduce sulfur content prior to sale or combustion onsite.
ConocoPhillips has proposed to install two additional gas caustic
scrubber systems, one to treat butane gas at the butane distillation
unit (S-463) and one to provide additional treatment of fuel gas from
the fuel gas center (S-462) prior to combustion at S-36 and S-461. Each
system will include a new caustic scrubber, and both systems will share
a caustic solution stripper (to recycle caustic solution) and a storage
tank for caustic solution.

**2.7.1 Butane and Fuel Gas Caustic Treatment Emissions**

The butane and fuel gas treatment systems have no discrete emission
points. Fugitive emissions are considered in Section 2.10.

The two refinery hydrogen plants will provide steam required by the two
new caustic strippers. Specifically, heaters S-14 and S-438 will produce
this steam. All facility steam sources, including S-14 and S-438 in
Condition 1694, have existing permit conditions limiting fuel use.
Therefore, increased production of steam will not be considered a
modification and an emission increase will not be quantified. It should
be noted that some aspects of the project, most notably the removal from
service of a distillation tower at S-305, will result in substantial
steam savings.

In addition to treated butane and fuel gas streams, the caustic
treatment systems produce a sour gas stream (the non-condensable
overhead stream from the caustic recycling stripper) that is processed
at the sulfur recovery plants. Indirect emissions of sulfur compounds
from this stream are included in the emission increase from the sulfur
recovery plant (discussed above).

[]{#__RefHeading___Toc39114839 .anchor}**2.8 Wastewater Treatment
System**

The existing wastewater treatment facility has a capacity of
approximately 10 MM gal/day. Average refinery wastewater production is
about 2.5 MM gal/day. Since the project is not designed to increase
wastewater discharge, the existing facility will continue to have excess
capacity and is not proposed to be modified. No changes are proposed to
existing permit condition limits associated with the wastewater
treatment facility.

**2.8.1 Wastewater Treatment System Emissions**

Because there will be no physical modification to the wastewater
treatment facility, and because existing throughput limits in Condition
1440 will not be modified, no emission increase will be quantified.

[]{#__RefHeading___Toc39114840 .anchor}**2.9 S-500 ULSD Cooling Tower
(Exempt)**

An existing facility cooling tower, currently unused, is proposed to be
renovated and used to cool and condense products at the proposed S-460
ULSD hydrotreater. The cooling tower will handle only water provided by
the local water utility and pumped through S-460 heat exchangers, and
will not directly handle process water. The tower will have a
circulation rate of 11 MM gal/day.

Regulation 2-1-128.4 provides a permit exemption for cooling towers
which do not perform evaporative cooling of process water or water from
barometric jets or barometric condensers. Sources which are exempt from
permits must comply with the requirements of Regulation 2-1-319. These
requirements include an emission rate less than 5 tons per year. Also
exempt sources must not be subject to Regulations 2-1-316 (Toxic Air
Contaminants or Hazardous Air Pollutants), Regulation 2-1-317 (Public
Nuisance) or Regulation 2-1-318 (Hazardous Substances).

The application includes an estimate of particulate emissions in
accordance with the procedure in Chapter 11.4 of the District Permit
Handbook Chapter for cooling towers. The estimated emissions are 3.75
ton/yr of PM10. Therefore, this cooling tower is exempt from permit
requirements and will not be considered further in this evaluation.
Thus, Regulation 2-1-319 is satisfied.

Because this cooling tower will not handle process water, the only
potential source of toxic emissions is from water-quality additives.
This tower will use sodium hypochlorite as an additive. The project EIR
(response to comment C4-76) estimated a chloroform emission rate of 14.5
lb/yr, based on the amount of sodium hypochlorite that will be added to
the cooling tower water. This is less than the chloroform trigger level
of 36 lb/yr. Thus, no risk screening is required and the requirements of
Regulation 2-1-316 do not apply. None of the compounds listed in
Regulation 2-1-318 will be emitted, so the requirements of this
regulation do not apply.

The nuisance requirements of 2-1-317 will be assumed to not apply since
cooling towers are not typically the source of nuisance complaints.

[]{#__RefHeading___Toc39114841 .anchor}**2.10 Fugitive Components**

Fugitive sources of organic emissions include valves, flanges,
connectors, pumps and other devices that may leak organic gases or
liquids. New process units and auxiliary equipment will include the
following fugitive components (from application Appendix B-1). These
equipment counts are estimates pending construction and may be modified
as described in the proposed permit conditions:

  -------------------------- -------------------------- -------------------------- ----------------------------- ------------------------------ --------------------------- -------------------------------
  **[source]{.smallcaps}**                                                         **[component]{.smallcaps}**   **[counts]{.smallcaps}**                                   

                             **[stream]{.smallcaps}**   **[valves]{.smallcaps}**   **[pumps]{.smallcaps}**       **[connectors]{.smallcaps}**   **[flanges]{.smallcaps}**   **[compressors]{.smallcaps}**

  S-460 ULSD                 Gas                        605                        0                             210                            140                         7

  Hydrotreater               l liquid                   323                        4                             138                            92                          0

                             h liquid                   1081                       7                             387                            258                         0

  S-304 Naphtha              Gas                        605                        0                             210                            140                         7

  Hydrotreater               l liquid                   323                        4                             138                            92                          0

                             h liquid                   1081                       7                             387                            258                         0

  S-462 Fuel Gas             Gas                        696                        0                             1044                           696                         0

  Caustic                    l liquid                   0                          2                             3                              2                           0

  Treatment                  h liquid                   0                          0                             0                              0                           0

  S-463 Butane               Gas                        696                        0                             1044                           696                         0

  Caustic                    l liquid                   0                          2                             3                              2                           0

  Treatment                  h liquid                   0                          0                             0                              0                           0
  -------------------------- -------------------------- -------------------------- ----------------------------- ------------------------------ --------------------------- -------------------------------

**2.10.1 Fugitive Component Emissions**

Fugitive emissions are quantified in Section 3.1.3.

[]{#__RefHeading___Toc39114842 .anchor}**2.11 Relief and Flare System**

The new and modified refinery units will connect all new relief devices
to the existing relief and blowdown system. This system has a gas
recovery capacity of 200,000 scf/hr, which is set by the amount of
compressor capacity available. If this gas volume is exceeded, excess
gas would be diverted to one of the 2 existing refinery flares for
release. No additional flares will be installed, and no modification
will be made to the existing flares.

Flaring is not a necessary step during unit shutdowns or complete
refinery shutdowns, and flaring usually does not occur during these
events. However, flaring may occur during unit upsets, and these upsets
are more likely to occur during a unit startup than during a shutdown.

Although any process unit, including the new ULSD hydrotreater, is
subject to upset conditions that could result in an unplanned shutdown,
the refinery modifications have been designed to not increase the
flaring load during the design event for the facility flares (a total
power outage). In the event of an unplanned shutdown, the new
hydrotreater has been designed to close its process isolation valves and
stop heat input from its heaters, with no need to relieve internal
pressure. Also, the new secondary distillation tower at S-350 will have
a higher pressure rating (75 psig) than the current tower (47 psig),
although the normal operating pressure of 10 psig will not increase.
Thus, this secondary tower will be less likely to experience an
overpressure event. Finally, the distillation tower to be removed from
S-305 will no longer be a potential cause of flaring.

**2.11.1 Relief System Emissions**

Because this facility does not perform routine flaring, and because
routine flaring will not result from any of the proposed new or modified
sources, no emission increase will be quantified from flaring.

[]{#__RefHeading___Toc39114843 .anchor}**2.12 Steam / Power Plant**

Although the proposed project will result in an increase in electrical
demand, that demand will be satisfied by the existing refinery
steam/power plant. The steam/power plant currently operates at an
average availability of 95%, providing all the refinery electrical
demand and exporting approximately 7 MW of surplus power. After the
proposed modifications, the average refinery electrical load will
increase by about 5.5 MW, such that surplus power will drop to about 1.5
MW. No increase is proposed to the fuel consumption limits at the
existing turbines, and no additional emissions are expected from the
steam/power plant.

[]{#__RefHeading___Toc39114844 .anchor}**2.13 Storage Tanks**

**2.13.1 Inorganic Storage Tanks**

New tanks will be constructed to store liquid oxygen for use in the
modified sulfur plants, and liquid nitrogen for use in purging new
process units. Liquid oxygen and nitrogen tanks are exempt from permit
requirements in accordance with Regulation 2-1-123.3.1. Therefore, these
tanks will not be considered further in this evaluation.

Caustic and amine storage tanks will be constructed at the proposed
butane and fuel gas caustic treatment systems. These inorganic storage
tanks are exempt from permit requirements in accordance with Regulation
2-1-123.1 and 2-1-123.2. Therefore, these tanks will not be considered
further in this evaluation.

Wastewater from S-350 currently flows directly to the refinery sewer
system. After modification, S-350 wastewater will flow to a storage
tank, and possibly to pre-treatment, prior to discharge into the sewer
system. Existing tankage will be used for this purpose. The storage of
process water, including sour water, is typically exempt from permit
requirements in accordance with Regulation 2-1-123.2. Therefore, storage
of this wastewater will not be considered further in this evaluation.

**2.13.2 Organic Storage Tanks**

No new organic storage tanks are proposed for this project. However,
some existing tanks will experience service changes resulting from
increases in crude oil processing, increases in production of gasoline,
diesel and gas oil, and from operational changes.

First, the proposed increase in crude processing (10,000 bbl/day) will
result in an increase in utility at existing crude tanks. Most of this
additional crude oil will be sour crude. Sour crude has higher levels of
sulfur, nitrogen and metals than sweet crude. However, sour crude is not
sufficiently different from sweet crude that the storage of sour crude
in a tank which had previously stored sweet crude should be considered a
modification of the tank (assuming that additional control requirements
in Regulation 8, Rule 5 are not triggered). This is consistent with
previous treatment of tanks at this facility and other refineries, where
no distinction is made between sweet and sour crude when permitting a
crude oil storage tank. Further, because the increased crude processing
will be accommodated without modification of storage tank pumps or other
auxiliaries, no modification will be considered to result from the
increased processing.

Second, nominal increases in gasoline production and more significant
increases in gas oil and diesel production will result in an increase in
utility at existing tanks used to store these materials. Each of these
is an existing product, and storage is available for each. Because
increased storage demands will be accommodated without modification of
storage tank pumps or other auxiliaries, no modification will be
considered to result from the increased storage of these materials. Gas
oil and diesel oil tanks are typically exempt from permit requirements
based on their low vapor pressures.

Finally, diesel streams from the S-350 crude unit will be combined and
held in storage tanks, prior to treatment at S-460. Currently, these
streams are not stored prior to hydrotreating and final blending.
Existing tanks S-179 and S-180 will be used to store these diesel
streams. These tanks are currently designated as exempt sources, in
accordance with District Regulation 2-1-123.3.2 (initial boiling point
greater than 302 degrees F and greater than 180 degrees F over storage
temperature). The diesel stocks that will be stored are expected to
continue to satisfy this exemption criteria. Thus, tanks S-179 and S-180
will not be considered further in this evaluation.

The project EIR (Appendix C, Section A.7) notes that there will be an
overall decrease in emissions from storage tanks because of changes in
existing tank utilization.

[]{#__RefHeading___Toc39114845 .anchor}**2.14 Shipping Activity**

The proposed modification will result in additional vehicle traffic at
the refinery, including trucks and marine vessels. This traffic consists
of the categories listed below.

+---------------------+----------------------------------+-------------+
| **[commo            | **[increased                     | **[         |
| dity]{.smallcaps}** | traffic]{.smallcaps}**           | vehicle]{.s |
|                     |                                  | mallcaps}** |
+---------------------+----------------------------------+-------------+
| **[Raw material     | [365 trip/year]{.smallcaps}      | [Truck]{    |
| deliv               |                                  | .smallcaps} |
| ery:]{.smallcaps}** | [37 trip/year]{.smallcaps}       |             |
|                     |                                  |             |
| [liquid             | [37 trip/year]{.smallcaps}       |             |
| oxygen]{.smallcaps} |                                  |             |
|                     | [183 trip/year]{.smallcaps}      |             |
| [liquid             |                                  |             |
| ni                  | [110 trip/year]{.smallcaps}      |             |
| trogen]{.smallcaps} |                                  |             |
|                     |                                  |             |
| [spent              |                                  |             |
| c                   |                                  |             |
| austic]{.smallcaps} |                                  |             |
|                     |                                  |             |
| [feedstock          |                                  |             |
| add                 |                                  |             |
| itives]{.smallcaps} |                                  |             |
|                     |                                  |             |
| [                   |                                  |             |
| others]{.smallcaps} |                                  |             |
+---------------------+----------------------------------+-------------+
| **[Product          | [2,716 trip/year (to marine      | [Truck]{    |
| shipp               | terminal)]{.smallcaps}           | .smallcaps} |
| ing:]{.smallcaps}** |                                  |             |
|                     | [1,207 trip/year]{.smallcaps}    |             |
| [petroleum          |                                  |             |
| coke]{.smallcaps}   |                                  |             |
|                     |                                  |             |
| [molten             |                                  |             |
| sulfur]{.smallcaps} |                                  |             |
+---------------------+----------------------------------+-------------+
| **[Product          | [4 trip/year]{.smallcaps}        | [Barge]{    |
| shipp               |                                  | .smallcaps} |
| ing:]{.smallcaps}** | [1 trip/year]{.smallcaps}        |             |
|                     |                                  | [           |
| [gas                |                                  | Freighter]{ |
| oil]{.smallcaps}    |                                  | .smallcaps} |
|                     |                                  |             |
| [petroleum          |                                  |             |
| Coke]{.smallcaps}   |                                  |             |
+---------------------+----------------------------------+-------------+

The bulk of additional raw materials and additional products will be
shipped by pipeline, including the additional 10,000 bbl/month of feed
crude oil, as well as all additional gasoline and diesel fuel exports.
The only petroleum liquid products that will not be shipped by pipeline
are gas oil and petroleum coke. Gas oil will be shipped via barge. The
barges that will be used will have a capacity of 80,000 barrels and will
be driven by a single tugboat. Petroleum coke will be shipped via
freighter. The freighters that will be used will have a capacity of
60,000 dead weight tons and will be guided by two tugboats. Emissions
from marine carriers handling are quantified in Section 3.1.4.

In accordance with the definition of a "facility" in Regulation 2-2-215,
facility emissions do not include those from motor vehicles (such as
truck engines), but do include emissions from "cargo carriers" such as
marine vessels, and particulate emissions from truck traffic on refinery
roads, which are all paved.

Pipeline operations are not considered in this evaluation since no
expansion of pipeline infrastructure is proposed.

**2.14.1 Increased Cargo Carrier Emissions**

Emissions from the increased marine vessel activity are quantified in
Section 3.1.4.

**2.14.2 Increased Truck Traffic Emissions**

Emissions of particulate matter raised by additional truck traffic on
refinery roads are quantified in Section 3.1.5.

[]{#__RefHeading___Toc39114847 .anchor}**3.0 EMISSIONS CALCULATIONS**

[]{#__RefHeading___Toc39114848 .anchor}**3.1 Annual Average Emissions:**

Annual average emissions are calculated to determine the facility
cumulative increase, the required amount of emission offsets and the
applicability of PSD requirements.

**3.1.1 New ULSD Hydrotreater Charge Heater (S-461)**

**3.1.1.1 Assumptions and Emission Factors**

The following assumptions will be used to estimate S-461 emissions:

fuel: refinery fuel gas (natural gas backup)

proposed utility: 100% (8,760 hr/yr)

maximum firing rate: 50.2 MM BTU/hr

nat. gas heat value: 1,050 BTU/scf (BAAQMD standard value)

fuel gas heat value: 1,516 BTU/scf HHV (ConocoPhillips)

annual fuel use: 439,800 MM BTU

abatement device: selective catalytic reduction (SCR)

ammonia slip from SCR: 10 ppmv @ 3% O2

emission factors (controlled):

  ----------------------------- --------------------------- --------------------------------
  **[pollutant]{.smallcaps}**   **[emission                 **[source]{.smallcaps}**
                                factor]{.smallcaps}**       

  NOx                           10 ppmvd @ 3% O2            BAAQMD BACT Workbook,
                                                            Determination 94.3.1 (8/12/94)

  CO                            50 ppmvd @ 3% O2            BACT Determination, Section 6.1

  POC                           5.5 lb/MM ft3               U.S. EPA AP-42 Table 1.4-2 for
                                                            natural gas

  SO2                           45 ppmv total reduced       BACT Determination, Section 6.1
                                sulfur (TRS) in fuel gas    

  PM10                          7.6 lb/MM ft3               U.S. EPA AP-42 Table 1.4-2 for
                                                            natural gas

  NPOC                          Negligible                  U.S. EPA AP-42
  ----------------------------- --------------------------- --------------------------------

Notes:

1\. Ammonia emissions are quantified in Section 5.0 (Toxic Risk
Management)

2\. POC and PM10 emission factors are taken from AP-42 data for natural
gas.

3\. a CO emission factor is conservatively used, even though S-461 is
subject to a tiered exhaust limit for CO which sets a limit of 28 ppmv
at firing rates of 50% of more, and a limit of 50 ppmv at firing rates
less than 50%.

**Convert NOx, CO and SO2 \"ppm\" to \"lb/MM BTU\":**

For NOx and CO, this conversion may be done using the EPA \"Fd\" factor
from 40 CFR Part 60 test methods, for example Method 19, Table 19-1-F.
Fd is the ratio of the volume of dry flue gas to the heat value of the
fuel used to produce the flue gas. Fd for natural gas is 8,710 dscf/MM
BTU (from Method 19), Fd for refinery fuel gas is 8,831 dscf/MM BTU
(from application Appendix B-2). Emission factors will be based on
refinery fuel gas since this yields the higher emission factor. The
conversion assumes that the flue gas is ideal (since flue gas molar
volume is assumed to be 359 cf/lbmole) which is a valid assumption
because of the relatively high temperature and low pressure of the flue
gas. The conversion includes a correction of the pollutant
concentrations from 3% O2 to 0% O2 (in accordance with District
procedure ST-13A) since the flue gas volume assumes stoichiometric
combustion (zero excess air and O2).

**NOx** (molecular weight 46.01):

(10/MM)(20.95%-0%/(20.95%-3%))(8,831 ft3/MM BTU)

(lbmole/359 ft3)(46.01 lb/lbmole) = **0.013 lb/MM BTU**

**CO** (molecular weight 28.01):

(28/MM)(20.95%-0%/(20.95%-3%))(8,831 ft3/MM BTU)

(lbmole/359 ft3)(28.01 lb/lbmole) = **0.023 lb/MM BTU for 28 ppmv**

(50/MM)(20.95%-0%/(20.95%-3%))(8,831 ft3/MM BTU)

(lbmole/359 ft3)(28.01 lb/lbmole) = **0.040 lb/MM BTU for 50 ppmv**

For SO2, the applicable emission limit actually addresses the
concentration of total reduced sulfur (TRS) in any sulfur compounds in
the fuel gas, and not the concentration of SO2 in the exhaust gas.
Therefore, the TRS concentration limit must be converted to an
equivalent SO2 limit. This is done by assuming that each TRS compound
has one sulfur atom (as is true for the most common TRS compounds --
dimethyl sulfide, hydrogen sulfide, methyl mercaptan), in which case the
number of SO2 atoms (or moles) would be the same as the number of TRS
atoms (or moles) in the fuel gas. This calculation is performed on the
basis of 1 standard cubic foot (ft3) of refinery fuel gas and associated
heating value of the fuel gas, with the assumption that the gas is
ideal(since flue gas molar volume is assumed to be 359 cf/lbmole) which
is a valid assumption because of the relatively low pressure of the fuel
gas.

**SO2** (molecular weight 64.07):

(1 ft3/1,516 BTU)(lbmole/359 ft3)(45/MM)(64.07 lb/lbmole)

> = **0.0053 lb/MM BTU**

**Convert POC and PM10 \"lb/MM ft3\" to \"lb/MM BTU\":**

This conversion may be done by applying the heating value of fuel gas.

**POC:** (5.5 lb/MM ft3)(1 ft3/1,516 BTU) = **0.0036 lb/MM BTU**

**PM10:** (7.6 lb/MM ft3)(1 ft3/1,516 BTU) = **0.0050 lb/MM BTU**

**3.1.1.2 S-461 Emission Calculations**

**NOx:** (439,800 MM BTU/yr)(0.013 lb/MM BTU)/(365 day/yr)

> = **15.66 lb/day** = **2.86 ton/yr**

**CO:** (439,800 MM BTU/yr)(0.040 lb/MM BTU)/(365 day/yr)

> = **48.20 lb/day** = **8.80 ton/yr**

**SO2:** (439,800 MM BTU/yr)(0.0053 lb/MM BTU)/(365 day/yr)

> = **6.39 lb/day** = **1.17 ton/yr**

**POC:** (439,800 MM BTU/yr)(0.0036 lb/MM BTU)/(365 day/yr)

> = **4.34 lb/day** = **0.79 ton/yr**

**PM10:** (439,800 MM BTU/yr)(0.0050 lb/MM BTU)/(365 day/yr)

> = **6.02 lb/day** = **1.10 ton/yr**

**3.1.2 Crude Unit Vacuum Tower Heater (S-36)**

**3.1.2.1 Assumptions and Emission Factors**

The following assumptions will be used to estimate S-36 emissions:

fuel: refinery fuel gas (natural gas backup)

proposed utility: 100% (8,760 hr/yr)

maximum firing rate: 82.1 MM BTU/hr

nat. gas heat value: 1,050 BTU/scf (BAAQMD standard value)

fuel gas heat value: 1,516 BTU/scf HHV (ConocoPhillips)

annual fuel use: 719,200 MM BTU

abatement device: selective catalytic reduction (SCR)

ammonia slip from SCR: 10 ppm @ 3% O2

emission factors (controlled):

+----------+--------------------------+--------------------------------+
| **[      | **[emission              | **[source]{.smallcaps}**       |
| pollutan | factor]{.smallcaps}**    |                                |
| t]{.smal |                          |                                |
| lcaps}** |                          |                                |
+----------+--------------------------+--------------------------------+
| NOx      | 10 ppmvd @ 3% O2         | BAAQMD BACT Workbook,          |
|          |                          | Determination 94.3.1 (8/12/94) |
|          | \[0.013 lb/MM BTU\]      |                                |
+----------+--------------------------+--------------------------------+
| CO       | 28 ppmvd @ 3% O2         | BACT Determination, Section    |
|          |                          | 6.1                            |
|          | \[0.023 lb/MM BTU\]      |                                |
+----------+--------------------------+--------------------------------+
| POC      | 5.5 lb/MM ft3            | U.S. EPA AP-42 Table 1.4-2 for |
|          |                          | natural gas                    |
|          | \[0.0036 lb/MM BTU\]     |                                |
+----------+--------------------------+--------------------------------+
| SO2      | 45 ppmv total reduced    | BACT Determination, Section    |
|          | sulfur (TRS) in fuel gas | 6.1                            |
|          |                          |                                |
|          | \[0.0053 lb/MM BTU\]     |                                |
+----------+--------------------------+--------------------------------+
| PM10     | 7.6 lb/MM ft3            | U.S. EPA AP-42 Table 1.4-2 for |
|          |                          | natural gas                    |
|          | \[0.0050 lb/MM BTU\]     |                                |
+----------+--------------------------+--------------------------------+
| NPOC     | Negligible               | U.S. EPA AP-42                 |
+----------+--------------------------+--------------------------------+

Notes:

1\. Ammonia emissions are quantified in Section 5.0 (Toxic Risk
Management)

2\. POC and PM10 emission factors are taken from AP-42 data for natural
gas.

**3.1.2.2 S-36 Emission Calculations**

**NOx:** (719,200 MM BTU/yr)(0.013 lb/MM BTU)/(365 day/yr)

> = **25.62 lb/day** = **4.67 ton/yr**

**CO:** (719,200 MM BTU/yr)(0.023 lb/MM BTU)/(365 day/yr)

> = **45.32 lb/day** = **8.27 ton/yr**

**SO2:** (719,200 MM BTU/yr)(0.0053 lb/MM BTU)/(365 day/yr)

> = **10.44 lb/day** = **1.91 ton/yr**

**POC:** (719,200 MM BTU/yr)(0.0036 lb/MM BTU)/(365 day/yr)

> = **7.09 lb/day** = **1.29 ton/yr**

**PM10:** (719,200 MM BTU/yr)(0.0050 lb/MM BTU)/(365 day/yr)

> = **9.85 lb/day** = **1.80 ton/yr**

**3.1.3 Fugitive Components**

ConocoPhillips has proposed to estimate fugitive emissions from new
fugitive sources by using the "correlation equation" method from the
1999 document "California Implementation Guidelines for Estimating Mass
Emissions of Fugitive Hydrocarbon Leaks at Petroleum Refineries". This
document, prepared by the California Air Resource Board and the
California Air Pollution Control Officers Association, is the accepted
District standard for estimating fugitive emissions. The correlation
equation method is one of four methods described in this document, and
is intended to be used to estimate emissions from an actual population
of sources, using the measured emission concentrations from each source,
and a corresponding emission factor. There are three possible types of
emission factors: one corresponds to components with no measured leak,
the second corresponds to non-pegged detected leaks, and the third
corresponds to leaks that peg the analyzer high. Different sets of
factors are provided for valves, pump seals, connectors, flanges,
open-ended lines and "others" (a category which includes compressor
seals). However, the service for each type of component (light liquid,
heavy liquid or gas) is not considered.

In this case, the intent is to estimate the emissions from fugitive
sources that are not yet in service. ConocoPhillips has proposed to
implement the correlation equipment method by assuming that each
fugitive component will have a leak with the maximum allowed
concentration ("screening value") in ppm, as specified in District
Regulation 8, Rule 18 ("Equipment Leaks"). Thus, the correlation
equations that apply to non-pegged detected leaks will be used.

+--------------+------------------------------------+------------------+
| **[          | **[correlation equation (kg/hr),   | **[screening     |
| component]{. | per component]{.smallcaps}**       | valu             |
| smallcaps}** |                                    | e]{.smallcaps}** |
|              |                                    |                  |
|              |                                    | **[(ppm          |
|              |                                    | )]{.smallcaps}** |
+--------------+------------------------------------+------------------+
| **[valves]{. | 2.27E-6(screening value)0.747      | 100              |
| smallcaps}** |                                    |                  |
+--------------+------------------------------------+------------------+
| **[pump      | 5.07E-5(screening value)0.622      | 500              |
| seals]{.     |                                    |                  |
| smallcaps}** |                                    |                  |
+--------------+------------------------------------+------------------+
| **[other     | 8.69E-6(screening value)0.642      | 500              |
| (compressor  |                                    |                  |
| seals)]{.    |                                    |                  |
| smallcaps}** |                                    |                  |
+--------------+------------------------------------+------------------+
| **[c         | 1.53E-6(screening value)0.736      | 100              |
| onnectors]{. |                                    |                  |
| smallcaps}** |                                    |                  |
+--------------+------------------------------------+------------------+
| *            | 4.53E-6(screening value)0.706      | 100              |
| *[flanges]{. |                                    |                  |
| smallcaps}** |                                    |                  |
+--------------+------------------------------------+------------------+

Notes:

1\. Screening values are taken from District Regulation 8, Rule 18.

2\. All emissions from fugitive components are assumed to be POC
compounds.

All new fugitive components have been grouped into four locations:

  ----------------------------- -------------------------- ---------------------- ---------------------- ------------------------------ ---------------------------
  **[location]{.smallcaps}**    **[valves]{.smallcaps}**   **[pump                **[compressor          **[connectors]{.smallcaps}**   **[flanges]{.smallcaps}**
                                                           seals]{.smallcaps}**   seals]{.smallcaps}**                                  

  **[S-460 ULSD                 2,009                      11                     7                      735                            490
  hydrotreater]{.smallcaps}**                                                                                                           

  **[S-304 naphtha              2,009                      11                     7                      735                            490
  hydrotreater]{.smallcaps}**                                                                                                           

  **[S-462 fuel gas caustic     696                        2                      0                      1,047                          698
  treatment]{.smallcaps}**                                                                                                              

  **[S-463 butane caustic       696                        2                      0                      1,047                          698
  treatment]{.smallcaps}**                                                                                                              
  ----------------------------- -------------------------- ---------------------- ---------------------- ------------------------------ ---------------------------

Notes:

1\. Fugitive component counts appear in Appendix B-1 of the application

**3.1.3.1 Fugitive Components Emission Calculations**

**S-460 ULSD Hydrotreater:**

\[(2,009)(2.27E-6(100)0.747) + (11)(5.07E-5(500)0.622) +

(7)(8.69E-6(500)0.642) + (735)(1.53E-6(100)0.736) +

(490)(4.53E-6(100)0.706\] kg/hr (2.205 lb/kg) (24 hr/day)

> = **13.91 lb/day POC**

**S-304 Naphtha Hydrotreater:**

\[(2,009)(2.27E-6(100)0.747) + (11)(5.07E-5(500)0.622) +

(7)(8.69E-6(500)0.642) + (735)(1.53E-6(100)0.736) +

(490)(4.53E-6(100)0.706\] kg/hr (2.205 lb/kg) (24 hr/day)

> = **13.91 lb/day POC**

**S-462 Fuel Gas Caustic Treatment:**

\[(696)(2.27E-6(100)0.747) + (2)(5.07E-5(500)0.622) +

(1,047)(1.53E-6(100)0.736) + (698)(4.53E-6(100)0.706\] kg/hr

(2.205 lb/kg) (24 hr/day) **=** **9.70 lb/day POC**

**S-463 Butane Caustic Treatment:**

\[(696)(2.27E-6(100)0.747) + (2)(5.07E-5(500)0.622) +

(1,047)(1.53E-6(100)0.736) + (698)(4.53E-6(100)0.706\] kg/hr

(2.205 lb/kg) (24 hr/day) **=** **9.70 lb/day POC**

Total Fugitive Component Emissions:

(13.91 + 13.91 + 9.70 + 9.70) lb/day = **47.22 lb/day POC**

> = **8.62 ton/yr POC**

**3.1.4 Cargo Carriers**

As discussed in Section 2.14, there will be an increase in marine
shipping of gas oil by barge and petroleum coke by freighter. Both
barges and freighters require tugboats to guide them to and from the
marine terminal. A single tugboat is required for barges; freighters
require two tugboats. In addition to emissions from the use of main
tugboat engines during maneuvering and cruising, emissions will also be
produced by tugboat auxiliary engines while they are on standby, and by
freighter auxiliary engines during hotelling.

Emissions from these marine operations are quantified in the project EIR
(Appendix C, Section A.1.2) using emission factors and correlations from
the EPA document "Analysis of Commercial Marine Vessel Emissions and
Fuel Consumption Data" (February 2000). This is an acceptable method of
quantifying these emissions. A copy of Appendix C of the EIR is
attached.

Calculated total emission increases are as follows:

+-----------+---------------------+--------------------+--------------+
| #####     | ##### [Gas Oil      | #####              | #            |
|           | Export]{.smallcaps} |  [Petroleum Coke E | #### [Total] |
|           |                     | xport]{.smallcaps} | {.smallcaps} |
|           | **(4 trip/year)**   |                    |              |
|           |                     | **(1 trip/year)**  | **Ton/Year** |
|           | **Ton/Year**        |                    |              |
|           |                     | **Ton/Year**       |              |
+-----------+---------------------+--------------------+--------------+
| ###### PM | [0.03]{.smallcaps}  | [0.11]{.smallcaps} | [0.14]       |
|           |                     |                    | {.smallcaps} |
+-----------+---------------------+--------------------+--------------+
| **[       | 1.05                | 4.32               | 5.37         |
| NOx]{.sma |                     |                    |              |
| llcaps}** |                     |                    |              |
+-----------+---------------------+--------------------+--------------+
| **[       | 1.32                | 5.35               | 6.67         |
| SO2]{.sma |                     |                    |              |
| llcaps}** |                     |                    |              |
+-----------+---------------------+--------------------+--------------+
| **        | 0.12                | 0.39               | 0.51         |
| [CO]{.sma |                     |                    |              |
| llcaps}** |                     |                    |              |
+-----------+---------------------+--------------------+--------------+
| **[       | 0.01                | 0.03               | 0.04         |
| POC]{.sma |                     |                    |              |
| llcaps}** |                     |                    |              |
+-----------+---------------------+--------------------+--------------+

**3.1.5 Paved Road Emissions**

As described in the project EIR (Appendix C, Section A.1.1), 13
additional heavy-duty truck round trips per day will be necessary to
import additional raw materials and to export additional products and
waste. Based on the size of the refinery and the layout of access roads,
ConocoPhillips has estimated a round-trip distance of 4 miles within the
refinery.

Emissions are estimated with Equation 2 (with precipitation correction
factor) from Chapter 13.2.1 ("Paved Roads") of U.S. EPA's AP-42:

E (lb/VMT) = k (sL/2)^0.65^(W/3)^1.5^(1-P/4N)

E = emission rate

VMT = "vehicle miles traveled" = (4 mile/trip)(13 trip/day)

= 52 mile/day

k = particle size multiplier from Table 13.2.1-1

= 0.016 lb/VMT for PM10

sL = road surface silt loading from Table 13.2.1-2

= 0.4 g/m2 (default value for normal conditions on roads

with less than 5,000 vehicles/day)

W = average weight (tons) of vehicles

= 30 tons based on the most common additional trip (coke

transport), where a shipment is approximately 23 tons and a

truck is assumed to weigh approximately 7 tons

P = number of "wet days" from Figure 13.2.1-2

= 60 days for the San Francisco Bay Area

N = number of days in the P averaging period

= 365 days

E (lb/VMT) = \[(0.016)(0.4/2)^0.65^(30/3)^1.5^(1-60/4(365))\]

= 0.17 lb/mile

E (lb/day) = (0.17 lb/mile)(52 mile/day) = 8.84 lb/day

= 1.61 ton/yr

**3.1.6 Coke Handling Emissions**

U.S. EPA's AP-42 document includes a discussion of coking operations in
Chapter 5.1 (Petroleum Refining). This chapter notes that delayed coking
results in fugitive organic emissions (considered in Section 2.10), as
well as particulate emissions from coke handling operations. However, it
is also noted that particulate emission data is not available and no
emission factors are provided for coke handling operations in Table
5.1.1 of this chapter. In the project EIR (Appendix C, Section A.8), the
applicant estimated emissions from coke handling using the emission
factors and procedures from U.S. EPA's AP-42, Chapter 13.2.4 ("Aggregate
Handling and Storage Piles"). This is an acceptable method of
quantifying these emissions. Assuming four un-covered transfer points
for coke between the coker and the freighter used to ship the coke, and
186 ton/day of increased coke production, the total increase in PM10
emissions was calculated to be 0.02 ton/yr.

**3.1.7 Total Annual Average Emissions**

+--------------------+----------+--------+---------+----------+-------+
| **[Sou             | **[NO    | **     | **[SO2] | **[PO    | **    |
| rce]{.smallcaps}** | x]{.smal | [CO]{. | {.small | C]{.smal | [PM10 |
|                    | lcaps}** | smallc | caps}** | lcaps}** | ]{.sm |
|                    |          | aps}** |         |          | allca |
|                    | **       |        | **[(t   | **       | ps}** |
|                    | [(ton/yr | **     | on/yr)] | [(ton/yr |       |
|                    | )]{.smal | [(ton/ | {.small | )]{.smal | *     |
|                    | lcaps}** | yr)]{. | caps}** | lcaps}** | *[(to |
|                    |          | smallc |         |          | n/yr) |
|                    |          | aps}** |         |          | ]{.sm |
|                    |          |        |         |          | allca |
|                    |          |        |         |          | ps}** |
+--------------------+----------+--------+---------+----------+-------+
| **[Heater          | 2.86     | 8.80   | 1.17    | 0.79     | 1.10  |
| S-                 |          |        |         |          |       |
| 461]{.smallcaps}** |          |        |         |          |       |
+--------------------+----------+--------+---------+----------+-------+
| **[Heater          | 4.67     | 8.27   | 1.91    | 1.29     | 1.80  |
| S                  |          |        |         |          |       |
| -36]{.smallcaps}** |          |        |         |          |       |
+--------------------+----------+--------+---------+----------+-------+
| **[Fugitive        |          |        |         | 8.62     |       |
| Compone            |          |        |         |          |       |
| nts]{.smallcaps}** |          |        |         |          |       |
+--------------------+----------+--------+---------+----------+-------+
| **[Paved Road      |          |        |         |          | 1.61  |
| Traf               |          |        |         |          |       |
| fic]{.smallcaps}** |          |        |         |          |       |
+--------------------+----------+--------+---------+----------+-------+
| **[Marine          | 5.37     | 0.51   | 6.67    | 0.04     | 0.14  |
| Carri              |          |        |         |          |       |
| ers]{.smallcaps}** |          |        |         |          |       |
+--------------------+----------+--------+---------+----------+-------+
| **[Coke            |          |        |         |          | 0.02  |
| Handl              |          |        |         |          |       |
| ing]{.smallcaps}** |          |        |         |          |       |
+--------------------+----------+--------+---------+----------+-------+
|                    |          |        |         |          |       |
+--------------------+----------+--------+---------+----------+-------+
| **[To              | 12.90    | 17.58  | 9.75    | 10.74    | 4.67  |
| tal]{.smallcaps}** |          |        |         |          |       |
+--------------------+----------+--------+---------+----------+-------+

[]{#__RefHeading___Toc39114849 .anchor}**3.2 Daily Emissions**

Daily emissions are calculated to determine if best available control
technology (BACT) requirements are triggered. In accordance with
District Regulation 2-2-301, BACT is triggered for any new or modified
source with the potential to emit 10 pounds of emissions or more of any
class of regulated pollutant (NOx, CO, POC, SO2, PM10) on any day.

**3.2.1 New ULSD Hydrotreater Charge Heater (S-461)**

Because S-461 is proposed to operate at 100% utility, it will typical
operate 24 hr/day and the daily emissions are equivalent to the
calculated annual average emissions. BACT is triggered for NOx and CO.

**3.2.2 Crude Unit Vacuum Tower Heater (S-36)**

Because S-36 is proposed to operate at 100% utility, it will typical
operate 24 hr/day and the daily emissions are equivalent to the
calculated annual average emissions. BACT is triggered for NOx, CO and
SO2.

**3.2.3 Fugitive Components**

Fugitive emissions are assumed to leak at the same rate, continuously.
Therefore, the daily emissions are equivalent to the calculated annual
average emissions. BACT is triggered for POC emissions from fugitive
components at the S-460 and S-304 hydrotreaters.

**3.2.4 Paved Road Traffic**

Estimated road emissions from truck traffic are 8.84 lb/day on an annual
average basis. However, since this emission rate reflects an adjustment
for rain, and because some shipments do not occur every day, it appears
that emissions are likely to exceed 10 lb/day on some days, for example
on dry days when some less frequent shipments occur. Therefore, BACT
will be assumed to be triggered. For unpaved road, BACT consists of
water spray or chemical suppression of dust, as described in BACT
determinations for rock and aggregate processing. No BACT determination
has been made for paved roads, although obvious control measures would
include sweeper trucks or watering trucks. Unfortunately, each of these
measures would result in road emissions of their own, as well as
additional engine emissions. Therefore, although dust control measures
may be justified on unpaved road, they appear to be counter-productive
on paved roads. Therefore, the use of paved roads will constitute BACT
for truck road emissions.

**3.2.5 Marine Cariers**

Regulation 2-2-206 excludes cargo carriers from BACT requirements,
therefore daily emissions from barge tugs and locomotives are irrelevant
and will not be quantified.

**3.2.6 Coke Handling**

The calculated annual average emission increase represents 17% increase
in coke production. Thus, total PM10 emissions from all coke handling
operations are estimated to be:

(0.02 ton/yr)/(0.17) = 0.12 ton/yr

This is equivalent to less than 1 lb/day on an annual average basis.
Since coke is produced every day, usually at the same rate, maximum
daily emissions are not expected to be significantly higher than this
annual average amount. Thus, total emissions from coke handling, even if
considered as a single source, do not trigger BACT.

[]{#__RefHeading___Toc39114850 .anchor}**4.0 FACILITY CUMULATIVE
INCREASE**

Current cumulative increase values are taken from the District database
(copies attached). Proposed increases are as calculated in Section 3.1
and summarized in Section 3.1.7.

+------------+-------------+-------------+-------------+-------------+
| **[Poll    | **[         | **[P        | **[Offset   | **[New      |
| utant]{.sm | Current]{.s | roposed]{.s | Amount]{.s  | Total]{.s   |
| allcaps}** | mallcaps}** | mallcaps}** | mallcaps}** | mallcaps}** |
|            |             |             |             |             |
|            | **[(        | **[(        | **[(note    | **[(        |
|            | ton/yr)]{.s | ton/yr)]{.s | 2)]{.s      | ton/yr)]{.s |
|            | mallcaps}** | mallcaps}** | mallcaps}** | mallcaps}** |
|            |             |             |             |             |
|            |             |             | **[(        |             |
|            |             |             | ton/yr)]{.s |             |
|            |             |             | mallcaps}** |             |
+------------+-------------+-------------+-------------+-------------+
| **POC**    | 0.002       | 10.74       | 10.742      | 0.00        |
+------------+-------------+-------------+-------------+-------------+
| **NOx**    | 0.00 (note  | 12.90       | 12.90       | 0.00        |
|            | 1)          |             |             |             |
+------------+-------------+-------------+-------------+-------------+
| **SO2**    | 0.00        | 9.75        | 9.75        | 0.00        |
+------------+-------------+-------------+-------------+-------------+
| **CO**     | 142.620     | 17.58       | 0.00        | 160.20      |
+------------+-------------+-------------+-------------+-------------+
| **PM10**   | 9.67        | 4.67        | 0.00        | 14.34       |
+------------+-------------+-------------+-------------+-------------+

Notes:

1\. The database entry for NOx is actually -0.003. However, in
accordance with the definition in Regulation 2-2-212, a cumulative
increase is a positive number or zero. Therefore, a value of zero is
used here.

2\. Offsets are addressed in Section 7.0.

[]{#__RefHeading___Toc39114851 .anchor}**5.0 TOXIC RISK MANAGEMENT**

In accordance with District Regulation 2-1-316, if "project emissions"
of any compound that is identified in Table 2-1-316 of Regulation 2,
Rule 1 exceeds the indicated "trigger level", then a risk analysis is
required. "Project emissions" include emissions from new sources and
increased emissions from modified sources. The purpose of a risk
analysis is to verify that the resulting toxic risk is not excessive.
The District Toxic Risk Management Policy requires that emissions of all
toxic air contaminants (TACs) associated with a project be included in
the risk analysis if any single TAC exceeds its trigger level. Because
trigger levels are expressed in units of "lb/yr", the annual average
emission rates from new and modified sources are the appropriate basis
for project emissions. Also, emissions from "related projects" must also
be considered. Related projects, according to the District Toxic Risk
Management Policy, include all projects within the two-year period
preceding an application, unless the emissions are demonstrated to be
unrelated to those in the application. The following applications were
processed in the two-year period (7/16/00-7/16/02) preceding the
submittal of the application:

  ------------------------------- --------------------------- ------------------------------------
  **[application]{.smallcaps}**   **[Project]{.smallcaps}**   **[Related Project?]{.smallcaps}**

  **2076**                        Modify S-300 coker permit   Possibly, but this application
                                  conditions to revise daily  resulted in no increase in annual
                                  throughput limits.          toxic emissions.

  **2454**                        Retrofit combustion sources No. The modifications in this
                                  to comply with Regulation   application were required by
                                  9, Rule 10.                 District regulations.

  **3449**                        Permit a new                Yes. Although the older tank had
                                  gasoline/naphtha storage    reached the end of its service life,
                                  tank, which replaced a      it was replaced with a larger tank.
                                  smaller tank. Both tanks    Therefore, the increase in emissions
                                  had floating roofs,         from the new tank will be considered
                                  although the older tank was to be related to this project, since
                                  riveted, while the new tank this project may result in an
                                  was welded.                 increase in gasoline production.

  **4984**                        Permit existing IC engines  No. This application included no new
                                  as required by a change in  or modified sources, and was
                                  District regulations.       required by District regulations,
  ------------------------------- --------------------------- ------------------------------------

As shown in this table, the only related project is the new tank in
Application 3449. A risk analysis was performed in Application 3449 that
estimated an increased excess cancer risk of 0.1 in a million.
Therefore, an additional risk of 0.1 in a million will be added to any
toxic risk for the sources in this application.

Total emissions from new and modified sources are identified and
quantified in Section 3.1. Emissions of specific TACs are derived from
overall emissions as shown in this table:

  --------------------------- --------------------------- -------------------------
  **[Source]{.smallcaps}**    **[TAC                      **[Specific TAC Emission
                              categories]{.smallcaps}**   Factors]{.smallcaps}**

  **[Heaters S-461 and        Miscellaneous combustion    WSPA/API report "Air
  S-36]{.smallcaps}**         products and non-combusted  Toxic Emission Factors
                              components of refinery fuel for Combustion Sources
                              gas                         Using Petroleum Based
                                                          Fuels", Final Report
                                                          Volume 2, Appendix B,
                                                          April 14, 1998

                              ammonia slip from heater    ammonia slip emission
                              SCR systems                 factor is calculated in
                                                          Section 5.2 based on the
                                                          proposed emission rate
                                                          limit of 10 ppmv

  **[Fugitive                 organic compounds in        CARB's California
  Components]{.smallcaps}**   process streams where       Emission Inventory
                              fugitive components are     Development and Reporting
                              located                     System, Organic Gas
                                                          Speciation Profiles,
                                                          11/20/01 draft
  --------------------------- --------------------------- -------------------------

[]{#__RefHeading___Toc39114852 .anchor}**5.1 S-461, S-36 Combustion
Emissions**

As noted in Section 5.0, the toxic emission factors for these heaters
are taken from the referenced WSPA/API report. Specifically, emission
factors are used for heaters using refinery gas fuel and abated with
SCR. Four emission factors are provided based on the population of data
in the specified source group: mean, median, maximum and minimum.
ConocoPhillips has proposed to use the mean factor, which is acceptable.
Eight compounds have emission factors in the report even though they
were not detected in any source test conducted for the report (indicated
with a "detect ratio" of 0.00 in the report). For these compounds,
ConocoPhillips has proposed to use an emission factor of zero, rather
than the factor from the report that is based on the detection limit of
the analytical methods used, which is acceptable. Emissions in the
report include ammonia slip emissions. Since these are calculated in
Section 5.2 for the specific slip level that will be permitted, the
ammonia factor in the report is not used.

The factors appear in Table A-12 of Appendix C of the project EIR and
are as follows (excluding compounds with a detect ratio of zero and
excluding ammonia):

+-------------------+-------------+---------------------+------------+
| **[compou         | **[emission | **[comp             | *          |
| nd]{.smallcaps}** | factor]{.s  | ound]{.smallcaps}** | *[emission |
|                   | mallcaps}** |                     | f          |
|                   |             |                     | actor]{.sm |
|                   | **[(note    |                     | allcaps}** |
|                   | 2)]{.s      |                     |            |
|                   | mallcaps}** |                     | **[(note   |
|                   |             |                     | 2)]{.sm    |
|                   | **[(lb/MM   |                     | allcaps}** |
|                   | BTU)]{.s    |                     |            |
|                   | mallcaps}** |                     | **[(lb/MM  |
|                   |             |                     | BTU)]{.sm  |
|                   |             |                     | allcaps}** |
+-------------------+-------------+---------------------+------------+
| acenaphthene      | 2.36E-09    | formaldehyde        | **         |
|                   |             |                     | 1.11E-04** |
+-------------------+-------------+---------------------+------------+
| acenaphthylene    | 1.55E-09    | Ind                 | **         |
|                   |             | eno(1,2,3-cd)pyrene | 1.03E-07** |
+-------------------+-------------+---------------------+------------+
| acetaldehyde      | *           | lead                | **         |
|                   | *1.53E-05** |                     | 4.89E-06** |
+-------------------+-------------+---------------------+------------+
| antimony          | 5.17E-07    | manganese           | **         |
|                   |             |                     | 6.81E-06** |
+-------------------+-------------+---------------------+------------+
| arsenic           | *           | mercury             | **         |
|                   | *8.50E-07** |                     | 1.80E-07** |
+-------------------+-------------+---------------------+------------+
| benzene           | *           | naphthalene         | **         |
|                   | *6.47E-05** |                     | 3.13E-07** |
+-------------------+-------------+---------------------+------------+
| b                 | *           | nickel              | **         |
| enzo(a)anthracene | *3.21E-08** |                     | 9.42E-06** |
+-------------------+-------------+---------------------+------------+
| benzo(a)pyrene    | *           | phenanthrene        | 1.46E-08   |
|                   | *8.96E-08** |                     |            |
+-------------------+-------------+---------------------+------------+
| ben               | *           | phenol              | **         |
| zo(b)fluoranthene | *4.04E-08** |                     | 5.63E-06** |
+-------------------+-------------+---------------------+------------+
| ben               | *           | propylene           | 2.17E-06   |
| zo(k)fluoranthene | *2.41E-08** |                     |            |
+-------------------+-------------+---------------------+------------+
| cadmium           | *           | pyrene              | 2.48E-09   |
|                   | *9.88E-07** |                     |            |
+-------------------+-------------+---------------------+------------+
| chromium (note 1) | 1.07E-06    | selenium            | **         |
|                   |             |                     | 1.96E-08** |
+-------------------+-------------+---------------------+------------+
| chrysene          | 1.63E-09    | silver              | 1.61E-06   |
+-------------------+-------------+---------------------+------------+
| copper            | *           | toluene             | **         |
|                   | *4.21E-06** |                     | 1.07E-04** |
+-------------------+-------------+---------------------+------------+
| ethylbenzene      | 3.02E-05    | xylene (total)      | **         |
|                   |             |                     | 3.73E-05** |
+-------------------+-------------+---------------------+------------+
| fluoranthene      | 3.06E-09    | zinc                | **         |
|                   |             |                     | 2.08E-05** |
+-------------------+-------------+---------------------+------------+
| fluorene          | 1.08E-08    |                     |            |
+-------------------+-------------+---------------------+------------+

Notes:

1\. No hexavalent chromium was detected, chromium (total) represents
non-hexavalent chromium compounds.

2\. Emission factors in bold are for compounds with assigned risk
screening trigger levels in District Table 2-1-316.

Total annual fuel usage in Section 3.1 for heaters S-461 and S-36 is
1,159,000 MM/BTU. Therefore, the annual emissions of these compounds
are:

+-------------------+-------------+---------------------+------------+
| **[compou         | **[annual   | **[comp             | **[annual  |
| nd]{.smallcaps}** | em          | ound]{.smallcaps}** | emis       |
|                   | issions]{.s |                     | sions]{.sm |
|                   | mallcaps}** |                     | allcaps}** |
|                   |             |                     |            |
|                   | **[         |                     | **[(l      |
|                   | (lb/yr)]{.s |                     | b/yr)]{.sm |
|                   | mallcaps}** |                     | allcaps}** |
+-------------------+-------------+---------------------+------------+
| acenaphthene      | 2.74E-03    | formaldehyde        | **         |
|                   |             |                     | 1.29E+02** |
+-------------------+-------------+---------------------+------------+
| acenaphthylene    | 1.80E-03    | ind                 | **         |
|                   |             | eno(1,2,3-cd)pyrene | 1.16E-01** |
+-------------------+-------------+---------------------+------------+
| acetaldehyde      | 1.77E+01    | lead                | 5.67E+00   |
+-------------------+-------------+---------------------+------------+
| antimony          | 5.99E-01    | manganese           | 7.89E-00   |
+-------------------+-------------+---------------------+------------+
| arsenic           | *           | mercury             | 2.09E-01   |
|                   | *9.85E-01** |                     |            |
+-------------------+-------------+---------------------+------------+
| benzene           | *           | naphthalene         | 3.63E-01   |
|                   | *7.50E+01** |                     |            |
+-------------------+-------------+---------------------+------------+
| b                 | 3.72E-02    | nickel              | **         |
| enzo(a)anthracene |             |                     | 1.09E+01** |
+-------------------+-------------+---------------------+------------+
| benzo(a)pyrene    | *           | phenanthrene        | 1.69E-01   |
|                   | *1.04E-01** |                     |            |
+-------------------+-------------+---------------------+------------+
| ben               | *           | phenol              | 6.25E+00   |
| zo(b)fluoranthene | *4.68E-02** |                     |            |
+-------------------+-------------+---------------------+------------+
| ben               | 2.79E-02    | propylene           | 2.52E+00   |
| zo(k)fluoranthene |             |                     |            |
+-------------------+-------------+---------------------+------------+
| cadmium           | *           | pyrene              | 2.87E-03   |
|                   | *1.15E+00** |                     |            |
+-------------------+-------------+---------------------+------------+
| chromium (note 1) | 1.24E+00    | selenium            | 2.27E-02   |
+-------------------+-------------+---------------------+------------+
| chrysene          | 1.88E-03    | silver              | 1.87E+00   |
+-------------------+-------------+---------------------+------------+
| Copper            | 4.88E+00    | toluene             | 1.24E+02   |
+-------------------+-------------+---------------------+------------+
| ethylbenzene      | 3.50E+01    | xylene (total)      | 4.32E+01   |
+-------------------+-------------+---------------------+------------+
| fluoranthene      | 3.55E-03    | zinc                | 2.41E+01   |
+-------------------+-------------+---------------------+------------+
| fluorene          | 1.25E-02    |                     |            |
+-------------------+-------------+---------------------+------------+

Notes:

1\. Emission rates in bold are for compounds with emission rates that
exceed the assigned risk screening trigger levels in District Table
2-1-316.

As shown in the table above, eight compounds have estimated emissions
that exceed the assigned risk screening trigger levels. Therefore, a
risk analysis is required for the toxic emissions in this application.

[]{#__RefHeading___Toc39114853 .anchor}**5.2 Ammonia Slip Emissions from
A-461, A-36**

Ammonia is present in the exhaust streams of the SCR systems (A-461,
A-36) associated with the two new heaters, since the aqueous ammonia
used in these devices is not completely reacted, resulting in some
amount of ammonia "slip". ConocoPhillips has proposed to limit slip to
10 ppmv @ 3% O2. Although ammonia may be present in trace concentrations
in some fugitive emissions and in locomotive engine emissions, the
exhaust streams from A-461 and A-36 are the predominant ammonia source
related to this project, and no other ammonia sources are considered.

**Convert ammonia \"ppm\" to \"lb/MM scf\":**

This conversion may be done using the EPA \"Fd\" factor from 40 CFR Part
60 test methods, for example Method 19, Table 19-1-F. Fd is the ratio of
the volume of dry flue gas to the heat value of the fuel used to produce
the flue gas. Fd for natural gas is 8,710 dscf/MM BTU (from Method 19),
Fd for refinery fuel gas is 8,700 dscf/MM BTU (from application Appendix
B-2). Emission factors will be based on refinery fuel gas since this
yields the higher emission factor. The conversion assumes that the flue
gas is ideal (since flue gas molar volume is assumed to be 359
cf/lbmole) which is a valid assumption because of the relatively high
temperature and low pressure of the flue gas. The conversion includes a
correction of the pollutant concentrations from 3% O2 to 0% O2 (in
accordance with District procedure ST-13A) since the flue gas volume
assumes stoichiometric combustion (zero excess air and O2).

Ammonia Emission Factor (molecular weight 17.03):

(10/MM)(20.95%-0%/(20.95%-3%))(8,700 ft3/MM BTU)

(lbmole/359 ft3)(17.03 lb/lbmole) = **0.0048 lb/MM BTU**

Total annual fuel usage at S-461 and S-36:

(439,800 + 719,200) MM BTU/yr = **1,159,000 MM BTU/yr**

Annual Ammonia Emissions:

(0.0048 lb/MM BTU)(1,159,000 MM BTU/yr) = **5,563 lb/yr**

The trigger level for ammonia in Table 2-1-316 of Regulation 2, Rule 1
is 19,000 lb/yr. Therefore, a risk analysis is not triggered by project
ammonia emissions. However, as shown in Section 5.1, a risk analysis is
triggered by heater combustion emissions and will include these ammonia
emissions.

[]{#__RefHeading___Toc39114854 .anchor}**5.3 Organic Compounds in
Fugitive Emissions**

As noted in Section 5.0, the toxic emission factors for fugitive
components are taken from the California Air Resources Board document
Organic Gas Speciation Profiles. Specifically, speciation profiles are
taken from the spreadsheet ORGPROF~-~11~-~20~-~01.xls. This spreadsheet
includes profiles for many classes of sources. ConocoPhillips has
proposed to apply profiles 531, 316 and 760, depending on the type of
service each component is in, as shown in Section 2.10. These profiles
are described below, with the speciation data for all components with
assigned risk screening trigger levels. Profile 531 is proposed,
although it is for oil and gas extraction operations because no
refinery-specific profile is provided. ConocoPhillips has proposed to
apply either profile 316 or 760 to pump seals, even though profile 321
is a refinery-specific profile. Although profile 760 is appropriate for
diesel cuts from the S-460 hydrotreater, profile 321 is more appropriate
for pumps at the light naphtha streams at S-304 and the light liquid
streams at the fuel gas and butane treatment units.

+------+-----+------------------------+------+-------+------+--------+
| **[s | *   | **[profile             | *    | *     | *    | **     |
| trea | *[p | desc                   | *[be | *[n-h | *[to | [total |
| m]{. | rof | ription]{.smallcaps}** | nzen | exane | luen | xyl    |
| smal | ile |                        | e]{. | ]{.sm | e]{. | ene]{. |
| lcap | \#  |                        | smal | allca | smal | smallc |
| s}** | ]{. |                        | lcap | ps}** | lcap | aps}** |
|      | sma |                        | s}** |       | s}** |        |
|      | llc |                        |      | *     |      | **[(wt |
|      | aps |                        | **   | *[(wt | **   | %)]{.  |
|      | }** |                        | [(wt | %)    | [(wt | smallc |
|      |     |                        | %    | ]{.sm | %    | aps}** |
|      |     |                        | )]{. | allca | )]{. |        |
|      |     |                        | smal | ps}** | smal |        |
|      |     |                        | lcap |       | lcap |        |
|      |     |                        | s}** |       | s}** |        |
+------+-----+------------------------+------+-------+------+--------+
| **G  | 531 | oil & gas extraction   | 0.7  | 1.4   | 0.4  | 0.0    |
| as** |     | -- compressor seals    |      |       |      |        |
+------+-----+------------------------+------+-------+------+--------+
| **L  | 316 | Refinery               | 0.1  | 3.4   | 0.5  | 0.2    |
| ight |     | pipes/valves/flanges   |      |       |      |        |
| liqu |     | -- composite           |      |       |      |        |
| id** |     |                        |      |       |      |        |
+------+-----+------------------------+------+-------+------+--------+
| **H  | 760 | evaporative emissions  | 0.0  | 9.0   | 0.0  | 0.0    |
| eavy |     | -- distillate oil      |      |       |      |        |
| liqu |     |                        |      |       |      |        |
| id** |     |                        |      |       |      |        |
+------+-----+------------------------+------+-------+------+--------+
|      |     |                        |      |       |      |        |
+------+-----+------------------------+------+-------+------+--------+
| **   | 321 | refinery pump seals -  | 0.5  | 11    | 3.0  | 1.3    |
| Liqu |     | composite              |      |       |      |        |
| id** |     |                        |      |       |      |        |
+------+-----+------------------------+------+-------+------+--------+

Therefore, the following profiles shall be applied.

+--------------+-------+-------+--------+--------+--------+--------+
| **[source]{. | **[s  | **[pr | *      | **     | *      | **     |
| smallcaps}** | tream | ofile | *[benz | [n-hex | *[tolu | [total |
|              | ]{.sm | \#    | ene]{. | ane]{. | ene]{. | xyl    |
|              | allca | ]{.sm | smallc | smallc | smallc | ene]{. |
|              | ps}** | allca | aps}** | aps}** | aps}** | smallc |
|              |       | ps}** |        |        |        | aps}** |
|              |       |       | **[(wt | **[(wt | **[(wt |        |
|              |       |       | %)]{.  | %)]{.  | %)]{.  | **[(wt |
|              |       |       | smallc | smallc | smallc | %)]{.  |
|              |       |       | aps}** | aps}** | aps}** | smallc |
|              |       |       |        |        |        | aps}** |
+--------------+-------+-------+--------+--------+--------+--------+
| #######      | Gas   | 531   | 0.7    | 1.4    | 0.4    | 0.0    |
| [S-460 ULSD] |       |       |        |        |        |        |
| {.smallcaps} |       |       |        |        |        |        |
+--------------+-------+-------+--------+--------+--------+--------+
| ##### [H     | l     | 321   | 0.5    | 11     | 3.0    | 1.3    |
| ydrotreater] | l     |       |        |        |        |        |
| {.smallcaps} | iquid |       |        |        |        |        |
+--------------+-------+-------+--------+--------+--------+--------+
|              | h     | 760   | 0.0    | 9.0    | 0.0    | 0.0    |
|              | l     |       |        |        |        |        |
|              | iquid |       |        |        |        |        |
+--------------+-------+-------+--------+--------+--------+--------+
| **[S-304     | Gas   | 531   | 0.7    | 1.4    | 0.4    | 0.0    |
| Naphtha]{.   |       |       |        |        |        |        |
| smallcaps}** |       |       |        |        |        |        |
+--------------+-------+-------+--------+--------+--------+--------+
| **[Hyd       | l     | 321   | 0.5    | 11     | 3.0    | 1.3    |
| rotreater]{. | l     |       |        |        |        |        |
| smallcaps}** | iquid |       |        |        |        |        |
+--------------+-------+-------+--------+--------+--------+--------+
|              | h     | 321   | 0.5    | 11     | 3.0    | 1.3    |
|              | l     |       |        |        |        |        |
|              | iquid |       |        |        |        |        |
+--------------+-------+-------+--------+--------+--------+--------+
| **[S-462     | Gas   | 531   | 0.7    | 1.4    | 0.4    | 0.0    |
| Fuel         |       |       |        |        |        |        |
| Gas]{.       |       |       |        |        |        |        |
| smallcaps}** |       |       |        |        |        |        |
+--------------+-------+-------+--------+--------+--------+--------+
| **[Caustic   | l     | 316   | 0.1    | 3.4    | 0.5    | 0.2    |
| Treatment]{. | l     |       |        |        |        |        |
| smallcaps}** | iquid |       |        |        |        |        |
+--------------+-------+-------+--------+--------+--------+--------+
|              | h     | 316   | 0.1    | 3.4    | 0.5    | 0.2    |
|              | l     |       |        |        |        |        |
|              | iquid |       |        |        |        |        |
+--------------+-------+-------+--------+--------+--------+--------+
| **[S-463     | Gas   | 531   | 0.7    | 1.4    | 0.4    | 0.0    |
| Butane]{.    |       |       |        |        |        |        |
| smallcaps}** |       |       |        |        |        |        |
+--------------+-------+-------+--------+--------+--------+--------+
| **[Caustic   | l     | 316   | 0.1    | 3.4    | 0.5    | 0.2    |
| Treatment]{. | l     |       |        |        |        |        |
| smallcaps}** | iquid |       |        |        |        |        |
+--------------+-------+-------+--------+--------+--------+--------+
|              | h     | 316   | 0.1    | 3.4    | 0.5    | 0.2    |
|              | l     |       |        |        |        |        |
|              | iquid |       |        |        |        |        |
+--------------+-------+-------+--------+--------+--------+--------+

Emissions of toxic compounds are calculated in the spreadsheet in
Attachment 1. The results are:

+----------------+--------+---------+---------+---------+-----------+
| **[source]     | **[str | **[b    | **[n-   | **[t    | **[total  |
| {.smallcaps}** | eam]{. | enzene] | hexane] | oluene] | xyl       |
|                | smallc | {.small | {.small | {.small | ene]{.sma |
|                | aps}** | caps}** | caps}** | caps}** | llcaps}** |
|                |        |         |         |         |           |
|                |        | **[(    | **[(    | **[(    | **[(lb/   |
|                |        | lb/yr)] | lb/yr)] | lb/yr)] | yr)]{.sma |
|                |        | {.small | {.small | {.small | llcaps}** |
|                |        | caps}** | caps}** | caps}** |           |
+----------------+--------+---------+---------+---------+-----------+
| ####           | Gas    | 9.74    | 19.48   | 5.56    | 0.00      |
| ### [S-460 ULS |        |         |         |         |           |
| D]{.smallcaps} |        |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
| ####           | l      | 4.79    | 105.32  | 28.72   | 12.45     |
| # [Hydrotreate | liquid |         |         |         |           |
| r]{.smallcaps} |        |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
|                | h      | 0.00    | 245.48  | 0.00    | 0.00      |
|                | liquid |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
|                |        |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
| **[S-304       | Gas    | 9.74    | 19.48   | 5.56    | 0.00      |
| Naphtha]       |        |         |         |         |           |
| {.smallcaps}** |        |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
| **             | l      | 4.79    | 105.32  | 28.72   | 12.45     |
| [Hydrotreater] | liquid |         |         |         |           |
| {.smallcaps}** |        |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
|                | h      | 13.64   | 300.03  | 81.83   | 35.46     |
|                | liquid |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
|                |        |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
| **[S-462 Fuel  | Gas    | 24.07   | 48.15   | 13.76   | 0.00      |
| Gas]           |        |         |         |         |           |
| {.smallcaps}** |        |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
| **[Caustic     | l      | 0.10    | 3.42    | 0.50    | 0.20      |
| Treatment]     | liquid |         |         |         |           |
| {.smallcaps}** |        |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
|                | h      | 0.00    | 0.00    | 0.00    | 0.00      |
|                | liquid |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
|                |        |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
| **[S-463       | Gas    | 24.07   | 48.15   | 13.76   | 0.00      |
| Butane]        |        |         |         |         |           |
| {.smallcaps}** |        |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
| **[Caustic     | l      | 0.10    | 3.42    | 0.50    | 0.20      |
| Treatment]     | liquid |         |         |         |           |
| {.smallcaps}** |        |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
|                | h      | 0.00    | 0.00    | 0.00    | 0.00      |
|                | liquid |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
|                |        |         |         |         |           |
+----------------+--------+---------+---------+---------+-----------+
| **[Total]      |        | **      | **8     | **1     | **60.75** |
| {.smallcaps}** |        | 91.04** | 98.24** | 78.92** |           |
+----------------+--------+---------+---------+---------+-----------+

Benzene emissions exceed the risk screening trigger level. As shown in
Section 5.1, a risk analysis is already triggered by heater combustion
emissions. These toxic emissions from fugitive components will be
considered along with other project toxic emissions.

[]{#__RefHeading___Toc39114856 .anchor}**5.4 Toxic Risk Assessment**

A risk analysis has been performed (see memo dated May 8, 2003) which
estimated the following excess cancer risks and chronic hazard indexes:

+----------------------------+---------------------+-------------------+
| #                          | **[residen          | **[non-residenti  |
| ### [receptor]{.smallcaps} | tial]{.smallcaps}** | al]{.smallcaps}** |
+----------------------------+---------------------+-------------------+
| **[cancer                  | 0.8 in a million    | 0.2 in a million  |
| risk]{.smallcaps}**        |                     |                   |
+----------------------------+---------------------+-------------------+
| **[cancer risk (AN         | 0.1 in a million    | 0.03 in a million |
| 3449)]{.smallcaps}**       |                     |                   |
+----------------------------+---------------------+-------------------+
| **[total cancer            | 0.9 in a million    | 0.23 in a million |
| risk]{.smallcaps}**        |                     |                   |
+----------------------------+---------------------+-------------------+
|                            |                     |                   |
+----------------------------+---------------------+-------------------+
| **[chronic hazard          | 0.01                | 0.006             |
| index]{.smallcaps}**       |                     |                   |
+----------------------------+---------------------+-------------------+
| **[chronic hazard index    | 0                   | 0                 |
| (AN 3449)]{.smallcaps}**   |                     |                   |
+----------------------------+---------------------+-------------------+
| **[total chronic hazard    | 0.01                | 0.006             |
| index]{.smallcaps}**       |                     |                   |
+----------------------------+---------------------+-------------------+

As the risk analysis concludes, this risk is acceptable because the
limiting cancer risk (residential) is less than 1.0 in a million, and
because the limiting chronic hazard index (residential) is less than
1.0, even after considering the additional risk from the related project
in Application 3449.

[]{#__RefHeading___Toc39114857 .anchor}**6.0 NEW SOURCE REVIEW**

[]{#__RefHeading___Toc39114858 .anchor}**6.1 Best Available Control
Technology (BACT)**

As determined in Section 3.2, BACT is triggered for NOx and CO at the
S-461 heater, NOx, CO and SO2 at the S-36 heater, and POC at fugitive
components.

**6.1.1 NOx and CO at the S-461 heater**

**6.1.1.1 NOx**

District BACT Guideline 94.3.1, last updated on August 12, 1994,
specifies BACT 2 (achieved in practice) for a process heater with a heat
input greater than 50 MM BTU/hr. BACT 2 is a maximum NOx emission
concentration of 10 ppmvd @ 3% O2 (dry), averaged over any consecutive
3-hour period. This emission level will be met by the S-461 heater
through the use of a combination of low NOx burners and the A-461
selective catalytic reduction (SCR) System using aqueous ammonia
injection. No BACT 1 (technologically feasible) level is listed, which
is consistent with listings from other agencies. The emission factors
used in the Alternative Compliance Plan by the refineries to comply with
Regulation 9, Rule 10 requirements are not below 10 ppmvd @ 3% O2.
Therefore, BACT is a concentration not to exceed 10 ppmv at 3 percent
O~2~, dry.

**6.1.1.2 CO**

District BACT Guideline 94.3.1, last updated on August 12, 1994,
specifies BACT 2 (achieved in practice) for CO, for a process heater
with a heat input greater than 50 MM BTU/hr. BACT 2 is a CO
concentration not to exceed 50 ppmvd @ 3% O2 (dry), averaged over any
consecutive 3-hour period. No BACT 1 (technologically feasible) level is
listed.

The Valero refinery (Plant 12626) has demonstrated in practice that a CO
concentration limit of 28 ppmv at 3% O2 can be achieved in conjunction
with a 10 ppmv NOx limit. This emission rate was achieved at the S-220
Hot Oil Furnace, permitted in Application 10392. A CO limit of 28 ppmv
is also the proposed BACT level for new heaters in the application for
refinery modernization currently under review (Application 5814).

ConocoPhillips has indicated that while a 28 ppmv CO limit is achievable
at high firing rates at S-461, this heater will not operate at
steady-state at full-load. ConocoPhillips has proposed a tiered CO
standard, with firing rates of 50% or more subject to a 28 ppmv CO
standard, and lower firing rates subject to a 50 ppmv CO standard,
except during startup and shutdown periods not exceeding 24 hours.
Because the 28 ppmv standard has been applied on a limited basis, this
tiered standard will be adopted as BACT for S-461.

**6.1.2 NOx, CO and SO2 at the S-36 heater**

**6.1.2.1 NOx**

District BACT Guideline 94.3.1, last updated on August 12, 1994,
specifies BACT 2 (achieved in practice) for a process heater with a heat
input greater than 50 MM BTU/hr. BACT 2 is a maximum NOx emission
concentration of 10 ppmvd @ 3% O2 (dry), averaged over any consecutive
3-hour period. This emission level will be met by the S-36 heater
through the use of a combination of low NOx burners and the A-36
selective catalytic reduction (SCR) System using aqueous ammonia
injection. No BACT 1 (technologically feasible) level is listed, which
is consistent with listings from other agencies. The emission factors
used in the Alternative Compliance Plan by the refineries to comply with
Regulation 9, Rule 10 requirements are not below 10 ppmvd @ 3% O2.
Therefore, BACT is a concentration not to exceed 10 ppmv at 3 percent
O~2~, dry.

**6.1.2.2 CO**

District BACT Guideline 94.3.1, last updated on August 12, 1994,
specifies BACT 2 (achieved in practice) for CO, for a process heater
with a heat input greater than 50 MM BTU/hr. BACT 2 is a CO
concentration not to exceed 50 ppmvd @ 3% O2 (dry), averaged over any
consecutive 3-hour period. No BACT 1 (technologically feasible) level is
listed.

The Valero refinery (Plant 12626) has demonstrated in practice that a CO
concentration limit of 28 ppmv at 3% O2 can be achieved in conjunction
with a 10 ppmv NOx limit. This emission rate was achieved at the S-220
Hot Oil Furnace, permitted in Application 10392. A CO limit of 28 ppmv
is also the proposed BACT level for new heaters in the application for
refinery modernization currently under review (Application 5814).
Therefore, BACT 2 (achieved in practice) for S-36 will be set at 28 ppmv
at 3% O2.

**6.1.2.3 SO2**

District BACT Guideline 94.3.1, last updated on August 12, 1994, for a
process heater with a heat input greater than 50 MM BTU/hour specifies:

**•** BACT 1 (technologically feasible and cost effective) is natural
gas or treated refinery gas with the following sulfur limit:

> hydrogen sulfide (H2S) [\<]{.underline} 50 ppmv

total reduced sulfur (TRS) [\<]{.underline} 100 ppmv

**•** BACT 2 (achieved in practice) is natural gas or treated refinery
gas with a TRS level [\<]{.underline} 100 ppmv.

The requirement to use only natural gas fuel as a BACT measure at
ConocoPhillips is not applicable. Fuel gas is a waste material that
would be flared if not combusted in the refinery furnaces and heaters.
When fuel gas is available, it is preferable that it be treated and
combusted rather than flared. S-36 is proposed to be operated normally
on refinery fuel gas, with natural gas as a back-up fuel when
insufficient refinery fuel gas is available.

ConocoPhillips uses a caustic scrubber system to treat recovered gases
for use as refinery fuel gas. A similar system at the Valero refinery
has consistently maintained TRS levels below 45 ppmv on a consecutive
365-day average basis. Therefore, BACT for SO2 for this project will be
a TRS level not to exceed the "achieved in practice" level of 45 ppmv on
a consecutive 365-day average basis. In addition, the 100 ppmv BACT 1
limit will be imposed as a daily average limit. A separate hydrogen
sulfide (H2S) concentration limit is not needed since sulfur in H2S
would be included in a TRS measurement. The District assumes that all of
the sulfur compounds present in the refinery fuel gas, measured as TRS,
is converted to SO2.

**6.1.3 POC at fugitive components**

As determined in Section 3.2, BACT is triggered for POC emissions from
fugitive components at the S-460 and S-304 hydrotreaters. These sources
include valves, flanges/connectors, and pump and compressor seals.

For S-460 and S-304, the emission contribution from each class of
component is as follows:

+------------------+--------------------------+-----------------------+
| **[componen      | **[S-460]{.smallcaps}**  | **                    |
| t]{.smallcaps}** |                          | [S-304]{.smallcaps}** |
|                  | **                       |                       |
|                  | [(lb/day)]{.smallcaps}** | **[(l                 |
|                  |                          | b/day)]{.smallcaps}** |
+------------------+--------------------------+-----------------------+
| **[valve         | 7.53                     | 7.53                  |
| s]{.smallcaps}** |                          |                       |
+------------------+--------------------------+-----------------------+
| **[pump          | 1.41                     | 1.41                  |
| seal             |                          |                       |
| s]{.smallcaps}** |                          |                       |
+------------------+--------------------------+-----------------------+
| **[compressor    | 0.17                     | 0.17                  |
| seal             |                          |                       |
| s]{.smallcaps}** |                          |                       |
+------------------+--------------------------+-----------------------+
| **[connector     | 1.76                     | 1.76                  |
| s]{.smallcaps}** |                          |                       |
+------------------+--------------------------+-----------------------+
| **[flange        | 3.03                     | 3.03                  |
| s]{.smallcaps}** |                          |                       |
+------------------+--------------------------+-----------------------+
| **[total         | 13.91                    | 13.91                 |
| emission         |                          |                       |
| s]{.smallcaps}** |                          |                       |
+------------------+--------------------------+-----------------------+

**6.1.3.1 Valves**

District BACT Guideline 136.1, last updated on June 30, 1995, specifies
a BACT 2 (achieved in practice) emission standard of 100 ppm (as
methane, measured at 1 cm from the component surface) for POC emissions
from valves, and also requires that the valve be included in an approved
inspection and maintenance program. No BACT 1 (technologically feasible)
level is listed, nor is a stricter standard known to have been imposed
elsewhere. Therefore, BACT 2 for valves will consist of a leak standard
of 100 ppm, which corresponds to the standard in Regulation 8, Rule 18,
plus inclusion in the Regulation 8, Rule 18 inspection and maintenance
program.

**6.1.3.2 Flanges / Connectors**

District BACT Guideline 78.1, last updated on August 12, 1994, specifies
a BACT 2 (achieved in practice) emission standard of 100 ppm (as
methane, measured at 1 cm from the component surface) for POC emissions
from flanges, and also requires that the flange be included in an
approved inspection and maintenance program. No BACT 1 (technologically
feasible) level is listed, nor is a stricter standard known to have been
imposed elsewhere. Therefore, BACT 2 for flanges and connectors will
consist of a leak standard of 100 ppm, which corresponds to the standard
in Regulation 8, Rule 18, plus inclusion in the Regulation 8, Rule 18
inspection and maintenance program.

**6.1.3.3 Pump Seals**

District BACT Guideline 137.1, last updated on June 30, 1995, specifies
the following:

**•** BACT 1 (technologically feasible and cost effective) is a leak
standard of 100 ppm (as methane, measured at 1 cm from the component
surface), and a quarterly inspection and maintenance program

**•** BACT 2 (achieved in practice) is a leak standard of 500 ppm (as
methane, measured at 1 cm from the component surface), and a quarterly
inspection and maintenance program

As shown in the table above, pumps seals contribute only 10% of the
total fugitive emissions for both S-460 and S-304, based on a leak rate
of 500 ppm. In fact, if pump seal emissions were eliminated entirely,
both sources would continue to trigger BACT. Implementation of BACT 1
leak limits would require the use of non-standard seal technology and
would complicate the inspection and monitoring program by imposing
different standards on these pumps seals compared to all of the others
at the refinery. Given the low emission contribution from pump seals,
this is not considered justified. Therefore, BACT for pump seals will
consist of the BACT 2 leak standard of 500 ppm, plus inclusion in the
Regulation 8, Rule 18 inspection and maintenance program.

**6.1.3.3 Compressor Seals**

District BACT Guideline 48.B.1, last updated on June 30, 1995, specifies
the following:

**•** BACT 1 (technologically feasible and cost effective) is a leak
standard of 100 ppm (as methane, measured at 1 cm from the component
surface), and a quarterly inspection and maintenance program

**•** BACT 2 (achieved in practice) is a leak standard of 500 ppm (as
methane, measured at 1 cm from the component surface), and a quarterly
inspection and maintenance program

As shown in the table above, compressor seals contribute only 1% of the
total fugitive emissions for both S-460 and S-304, based on a leak rate
of 500 ppm. Implementation of BACT 1 leak limits would require the use
of non-standard seal technology and would complicate the inspection and
monitoring program by imposing different standards on these compressor
seals compared to all of the others at the refinery. Given the
negligible emission contribution from compressor seals, this is not
considered justified. Therefore, BACT for compressor seals will consist
of the BACT 2 leak standard of 500 ppm, plus inclusion in the Regulation
8, Rule 18 inspection and maintenance program.

[]{#__RefHeading___Toc39114859 .anchor}**6.2 Emission Offsets**

**6.2.1 Offset Applicability**

The most recent (2002) annual emissions inventory in the District's
database for ConocoPhillips is as follows:

NOx 1,647 ton/yr

VOC 766 ton/yr

PM10 87 ton/yr

SO2 760 ton/yr

CO 316 ton/yr

The emissions inventory was determined using actual throughput data from
the refinery and source-specific emission factors. Based on this
inventory, offsets are required for NOx and VOC emission increases (and
pre-existing cumulative increase balances) in accordance with Regulation
2-2-302, since emissions of these pollutants exceed 15 ton/yr.

Also, offsets are required for SO2 emission increases (and pre-existing
cumulative increase balances) in accordance with Regulation 2-2-303
since ConocoPhillips is a major facility for this pollutant, with
facility emissions exceeding 100 ton/yr.

Although ConocoPhillips proposed to provide PM10 offsets, PM10 offsets
are not required because modified facility emissions are not projected
to exceed 100 ton/yr, after the proposed emission increases are
considered. It should be noted that facility-wide PM10 emissions have
never been estimated to exceed 100 ton/yr. Facility-wide PM10 emissions
were estimated to be 87 ton/yr in 2002, the highest estimated total for
this facility.

District regulations do not require offsets for CO emissions.

**6.2.2 Required Offsets**

ConocoPhillips has proposed to satisfy offset requirements by provided
banking certificates for NOx, VOC and SO2 in the required quantities.
Offsets are required at a ratio to the amount of offset emissions, as
described in Regulations 2-2-302 (for POC and NOx) and 2-2-303 (for
SO2).

+----------------+-----------------+-----------------+-----------------+
| **[Pollutant]  | **[Offset       | **[Offset       | **[Required     |
| {.smallcaps}** | Amount          | Ratio           | Offsets         |
|                | ]{.smallcaps}** | ]{.smallcaps}** | ]{.smallcaps}** |
|                |                 |                 |                 |
|                | **[(note        |                 | **[(ton/yr)     |
|                | 1)              |                 | ]{.smallcaps}** |
|                | ]{.smallcaps}** |                 |                 |
|                |                 |                 |                 |
|                | **[(ton/yr)     |                 |                 |
|                | ]{.smallcaps}** |                 |                 |
+----------------+-----------------+-----------------+-----------------+
| **POC**        | 10.742          | 1.15            | 12.35           |
+----------------+-----------------+-----------------+-----------------+
| **NOx**        | 12.90           | 1.15            | 14.84           |
+----------------+-----------------+-----------------+-----------------+
| **SO2**        | 9.75            | 1.0             | 9.75            |
+----------------+-----------------+-----------------+-----------------+
| **CO**         | not required    | not required    | not required    |
+----------------+-----------------+-----------------+-----------------+
| **PM10**       | not required    | not required    | not required    |
+----------------+-----------------+-----------------+-----------------+

Notes:

1\. The offset amount is the sum of the proposed emission increases,
plus the pre-existing cumulative increase, as determined in Section 4.0.

ConocoPhillips has proposed to use the following banking certificates to
provide the required offsets:

+----------------+-----------------+-----------------+---------------+
| #####          | **[POC          | **[NOx          | **[SO2        |
| [Certificate \ | available       | available       | available]{   |
| #]{.smallcaps} | ]{.smallcaps}** | ]{.smallcaps}** | .smallcaps}** |
+----------------+-----------------+-----------------+---------------+
| 131            | 0.38            |                 |               |
+----------------+-----------------+-----------------+---------------+
| 495            | 0.528           |                 | 2.15          |
+----------------+-----------------+-----------------+---------------+
| 580            | 1.290           | 21.230          | 4.190         |
+----------------+-----------------+-----------------+---------------+
| 581            | 3.170           | 6.880           | 0.010         |
+----------------+-----------------+-----------------+---------------+
| 862            |                 |                 | 3.500         |
+----------------+-----------------+-----------------+---------------+
| 876            | 76.860          |                 |               |
+----------------+-----------------+-----------------+---------------+
| **total        | 82.228          | 28.110          | 9.85          |
| available**    |                 |                 |               |
+----------------+-----------------+-----------------+---------------+
| **required     | 12.350          | 14.840          | 9.75          |
| offsets**      |                 |                 |               |
+----------------+-----------------+-----------------+---------------+
| **balance**    | 69.878 (Cert.   | 6.39 (Cert.     | 0.10 (Cert.   |
|                | 876)            | 580)            | 862)          |
|                |                 |                 |               |
|                |                 | 6.88 (Cert.     |               |
|                |                 | 581)            |               |
+----------------+-----------------+-----------------+---------------+

Notes:

1\. Some of the indicated certificates also have available credits for
CO and PM10, which are not required for this application. Those credits
will remain on those certificates.

[]{#__RefHeading___Toc39114860 .anchor}**6.3 Prevention of Significant
Deterioration (PSD)**

PSD includes the requirements of Regulations 2-2-304, 2-2-305 and
2-2-306.

**6.3.1 Regulation 2-2-304 (PSD Modeling)**

Regulation 2-2-304.1 applies to new major facilities. The ConocoPhillips
refinery is a major facility for NOx, POC, SO2 and CO emissions, with
each class of pollutant exceeding 100 ton/yr. The refinery is not a
major facility for PM10, and will not be a major facility for PM10 after
the proposed modifications. Therefore, the refinery is not a **new**
major facility for any class of pollutant.

Regulation 2-2-304.2 applies to major modifications (emission increases
exceeding 40 ton/yr) of major facilities of SO2 and NOx. The proposed
emission increases of SO2 and NOx are both less than 40 ton/yr and are
not major modifications.

Therefore, no provision of this regulation is applicable.

**6.3.2 Regulation 2-2-305 (CO Modeling)**

The proposed emission increase of CO is less than 100 ton/yr and is not
a major modification. Therefore, the CO modeling provision of this
regulation is not applicable.

**6.3.3 Regulation 2-2-306 (Non-Criteria Analysis)**

The ConocoPhillips refinery is a major facility for more than one of the
following pollutants: NOx, POC, SO2, CO, PM10. Therefore, the emission
increase from this project may not exceed the following limits, since no
PSD air quality analysis or visibility, soils and vegetations analysis
has been performed:

+---------------+------------+------------+--------------+-------------+
| *             | **[annual  | **[emi     | **[daily]{.  | **[e        |
| *[pollutant]{ | av         | ssion]{.sm | smallcaps}** | mission]{.s |
| .smallcaps}** | erage]{.sm | allcaps}** |              | mallcaps}** |
|               | allcaps}** |            | **[limit]{.  |             |
|               |            | **[emi     | smallcaps}** | **[e        |
|               | **[        | ssion]{.sm |              | mission]{.s |
|               | limit]{.sm | allcaps}** | **           | mallcaps}** |
|               | allcaps}** |            | [(lb/day)]{. |             |
|               |            | **[(to     | smallcaps}** | **[(        |
|               | **[(to     | n/yr)]{.sm |              | lb/day)]{.s |
|               | n/yr)]{.sm | allcaps}** |              | mallcaps}** |
|               | allcaps}** |            |              |             |
+---------------+------------+------------+--------------+-------------+
| lead          | 0.6        | 0.003      | 3.2          | 0.016       |
+---------------+------------+------------+--------------+-------------+
| asbestos      | 0.007      | 0          | 0.04         | 0           |
+---------------+------------+------------+--------------+-------------+
| beryllium     | 0.0004     | 0          | 0.002        | 0           |
+---------------+------------+------------+--------------+-------------+
| mercury       | 0.1        | 0.0001     | 0.5          | 0.0006      |
+---------------+------------+------------+--------------+-------------+
| fluorides     | 3          | 0.00005    | 16           | 0.00025     |
|               |            |            |              |             |
|               |            | (note 1)   |              | (note 1)    |
+---------------+------------+------------+--------------+-------------+
| sulfuric acid | 7          | 0          | 38           | 0           |
| mist          |            |            |              |             |
+---------------+------------+------------+--------------+-------------+
| hydrogen      | 10         | (note 2)   | 55           | (note 2)    |
| sulfide       |            |            |              |             |
+---------------+------------+------------+--------------+-------------+
| total reduced | 10         | (note 2)   | 55           | (note 2)    |
| sulfur        |            |            |              |             |
+---------------+------------+------------+--------------+-------------+
| reduced       | 10         | (note 2)   | 55           | (note 2)    |
| sulfur        |            |            |              |             |
| compounds     |            |            |              |             |
+---------------+------------+------------+--------------+-------------+

Notes:

1\. Fluorides include fluorine-containing compounds emitted in traces at
heaters S-461 and S-36.

2\. Reduced sulfur compounds emitted from refinery sources are emitted
to the atmosphere as SO2 when they are collected and used as fuel gas.
There is not emission increase for untreated or unreacted reduced sulfur
compounds.

As shown in this table, no PSD analysis is required for the specified
non-criteria pollutants.

[]{#__RefHeading___Toc39114861 .anchor}**7.0 CEQA**

The California Environmental Quality Act (CEQA) calls for a review of
potential significant environmental impacts from proposed projects. This
project has been determined to be subject to CEQA by the Contra Costa
County Community Development Department (CCCCDD). The CCCCDD is the Lead
Agency for CEQA for this project. In accordance with Regulation
2-1-310.3, the District may not issue an Authority to Construct for this
project until final action has been taken by the Lead Agency. A draft
Environmental Impact Report (EIR) was prepared by the CCCCDD in May
2003. This EIR includes all sources and activities that are the subject
of this application. The District is a responsible agency under CEQA and
has provided comments to the CCCCDD on the draft EIR. These comments, as
well as others received by CCCCDD have been addressed in a revised EIR.

On December 2, 2003, the final EIR was certified by the Contra Costa
County Planning Commission. On December 12, 2003, a mandatory 10-day
appeal period for the EIR ended. Thus, the District may issue an
Authority to Construct for this project.

[]{#__RefHeading___Toc39114862 .anchor}**8.0 REFINERY SO2 BUBBLE**

The ConocoPhillips refinery operates under an "SO2 bubble" included in
Condition 1694, Part 4. Since the new SO2 emissions in this application
will be offset, the cap could be managed in two ways: 1) the cap amount
could be increased by the amount of offset emissions, with emissions
from the new sources included under the cap, or 2) the cap amount could
be left unchanged, with emissions from new sources not required to be
included under the cap. Since the first option will result in the
simplest recordkeeping, this option will be implemented and the cap
amount will be increased.

[]{#__RefHeading___Toc39114863 .anchor}**9.0 DISTRICT PROHIBITORY
RULES**

[]{#__RefHeading___Toc39114864 .anchor}**9.1 Regulation 6 (Particulate
Matter and Visible Emissions)**

Regulation 6 includes the Ringelmann 1 opacity limit in Regulation
6-301, the emission rate limit of 0.15 gr/dscf in 6-310, the nuisance
fallout prohibition in 6-305 and the process rate limits in 6-311. New
heaters will burn only gaseous fuels and are not likely to violate
visible emission standards. Other new and modified sources, including
fugitive components, also do not produce particulate emissions in
quantities likely to result in result in violations. Sulfur is shipped
in a molten state and is unlikely to result in a violation of this rule.
Product coke is shipped offsite in a wet state and is also unlikely to
result in a violation of this rule. This refinery has logged only 2
complaints in the last 10 years (both unconfirmed) for dust emissions.
90 visible emission complaints (34 confirmed) have been logged in the
last 10 years. However, most of these complaints appear to be related to
flaring events.

[]{#__RefHeading___Toc39114865 .anchor}**9.2 Regulation 8, Rule 5
(Storage of Organic Liquids)**

No new tanks are proposed for this project. Some tanks, currently exempt
from the requirements of Regulation 8, Rule 5 by virtue of the low vapor
pressure of their contents, will see increased throughput of crude oil,
gas oil and diesel oil. These tanks are expected to retain their exempt
status. Existing gasoline tanks are also expected to see a nominal
increase in throughput. No gasoline tank requires modification to
accommodate this increase, and will continue to be subject to the design
and operating requirements of Regulation 8, Rule 5. Un-modified tanks
subject to Regulation 8, Rule 5 are assumed to be in compliance pending
inspection.

[]{#__RefHeading___Toc39114866 .anchor}**9.3 Regulation 8, Rule 18
(Equipment Leaks)**

Regulation 8, Rule 18 applies to equipment leaks at most refinery
equipment, except for leaks at devices which are regulated by other
rules (tank appurtenances, relief devices vented to control systems) and
leaks at devices which handle low vapor pressure (initial boiling point
greater than 302 degrees F). This regulation includes leak criteria,
repair requirements for leaks and monitoring requirements. New fugitive
devices associated with this project will largely be subject to this
rule and will be incorporated into the maintenance and inspection
program for fugitive devices and are assumed to be in compliance pending
inspection.

[]{#__RefHeading___Toc39114867 .anchor}**9.4 Regulation 8, Rule 28
(Episodic Releases)**

No new pressure relief devices are proposed for this project.

[]{#__RefHeading___Toc39114868 .anchor}**9.5 Regulation 9, Rule 1
(Sulfur Dioxide)**

This regulation includes several requirements applicable to this
project, as discussed below.

**9.5.1 Regulation 9-1-301 (Ground Level SO2 Concentration)**

Regulation 9-1-301 includes a limit on the ground level concentration of
SO2. Because the facility sulfur-removal capacity will be increased to
handle additional sulfur compounds in the crude oil feedstocks, ground
level SO2 concentrations are not expected to increase.

9.5.2 Regulation 9-1-302 (SO2 Emission Limitations)

The 300 ppm SO2 emission limit in Regulation 9-1-302 applies to new
heaters S-461 and S-36. These heaters will be limited (indirectly) to a
lower SO2 emission rate by the proposed limit of 45 ppmv on TRS
compounds in the feed gas. Because S02 and most of the reduced sulfur
species contain a single sulfur molecule, the volumetric concentration
of TRS in the feed gas should be roughly equivalent to the concentration
in the exhaust gas, if the effect of combustion air is neglected. Thus,
exhaust SO2 concentrations are expected to be less than 45 ppmv.

9.5.3 Regulation 9-1-303 (Emissions from Ships)

The 2,000 ppm SO2 emission limit in Regulation 9-1-303 applies to ships
that begin their journey outside the District. Thus, it may apply to
some tugboats if they operate entirely within the District. Tugboats
will be assumed to comply with this requirement rending an inspection.

9.5.4 Regulation 9-1-307 (Sulfur Recovery Plants)

The 250 ppm SO2 emission limit in Regulation 9-1-307 does not apply to
plants with SO2 emissions less than 100 lb/day. The three sulfur plants
at this refinery are estimated to have emissions below this level, based
on emission inventory records, and therefore are assumed to not be
subject to this limit.

**9.5.5 Regulation 9-1-313.2 (Sulfur Recovery Operations at Petroleum
Refineries)**

This refinery is subject to the refinery--wide 95% H2S recovery
requirement for fuel gas and process water, and the refinery--wide 95%
ammonia recovery requirement for process water. Compliance verification
methods for this requirement are currently under consideration as part
of the Title V permitting requirement for the refineries. The final
permits are expected to contain a compliance monitoring provision.
Compliance will be assumed pending implementation of this monitoring.

9.5.6 Regulation 9-1-501 (Area Monitoring)

Area monitoring is already required, at the request of the APCO, as
described in this regulation.

[]{#__RefHeading___Toc39114869 .anchor}**9.6 Regulation 9, Rule 2
(Ground Level Hydrogen Sulfide Concentration)**

Regulation 9, Rule 2 includes a limit on the ground level concentration
of H2S. Because the facility sulfur-removal capacity will be increased
to handle additional sulfur compounds in the crude oil feedstocks,
ground level H2S concentrations are not expected to increase.

[]{#__RefHeading___Toc39114870 .anchor}**9.7 Regulation 9, Rule 10 (NOx
and CO in Petroleum Refineries)**

Regulation 9, Rule 10 (NO~x~ and CO from Boilers, Steam Generators, and
Process Heaters in Petroleum Refineries) applies only to heaters that
were permitted prior to January 5, 1994, in accordance with Regulation
9-10-220. Thus, new heaters S-461 and S-36 are not subject to this rule.

[]{#__RefHeading___Toc39114871 .anchor}**9.8 Regulation 10 (Standards of
Performance for New Stationary Sources)**

Regulation 10 adopts the federal New Source Performance Standards by
reference. These are addressed in Section 10.1.

[]{#__RefHeading___Toc39114872 .anchor}**9.9 Regulation 11, Rule 7
(Benzene)**

Regulation 11, Rule 7 applies only to equipment "in benzene service"
which contains a gas or liquid which is at least 10% benzene by weight,
in accordance with Regulation 11-7-207. There is no equipment in benzene
service in this project.

[]{#__RefHeading___Toc39114873 .anchor}**9.10 Regulation 2-1-412 (Public
Notification/K-12 Schools)**

This facility is over 1,000 feet from the nearest school and therefore
is not subject to the public notification requirements of Regulation
2-1-412.

[]{#__RefHeading___Toc39114874 .anchor}**10.0 FEDERAL REQUIREMENTS**

Federal requirements include NSPS (40 CFR 60), NESHAP (40 CFR 61) and
MACT (40 CFR 63) standards, which are discussed below.

[]{#__RefHeading___Toc39114875 .anchor}**10.1 New Source Performance
Standards (NSPS)**

NSPS standards apply to emissions from new or modified sources for which
a specific standard has been written.

**10.1.1 Subpart J (Petroleum Refineries)**

Subpart J includes requirements for combustion devices and sulfur
recovery plants in 40 CFR 60.104. Combustion devices, including the two
new heaters (S-461 and S-36), are subject to a limit on H2S
concentration in the fuel gas (230 mg/dscm). The proposed BACT limits on
TRS are stricter than this limit. The fuel gas system header will
continue to be sampled to verify compliance. Sulfur plants are subject
to a 250 ppmv SO2 emission limit. The sulfur plants at this refinery are
not subject to the NSPS because they were installed prior to the NSPS
effective date. Because the two modified sulfur plants will not have
increased emissions, they are not modified in the sense of the NSPS and
continue to be exempt from its provisions. Nonetheless, it should be
noted that the three sulfur plants comply with this limit.

10.1.2 Subpart GGG (Equipment Leaks of VOC in Petroleum Refineries)

Subpart GGG includes leak criteria, repair requirements for leaks and
monitoring requirements. The refinery currently operates an inspection
and maintenance program to comply with both Subpart GGG and District
Regulation 8, Rule 18. New fugitive components will be included in this
inspection and maintenance program and are assumed to be in compliance
pending inspection.

[]{#__RefHeading___Toc39114876 .anchor}**10.2 National Emission
Standards for Hazardous Air Pollutants (NESHAPS)**

NESHAPS apply to eight specific pollutants, including benzene. A review
of these standards shows that most are obviously not applicable, and
only two standards require detailed discussion.

**10.2.1 Subpart BB (Benzene transfer Operations)**

Subpart BB applies to loading racks for benzene. No loading racks are
proposed as part of this project. Further, the regulation specifically
excludes transfer of the types of liquids that are associated with this
project (40 CFR 61.300), including gasoline, crude oil and petroleum
distillates.

**10.2.2 Subpart FF (Benzene Waste)**

Subpart FF applies to petroleum refineries and includes waste-handling
requirements for several categories of sources. Because this refinery
handles less than 10 megagram/yr of benzene waste (40 CFR 61.300), none
of these operating requirements are applicable, and the refinery is
subject only to recordkeeping provisions. The proposed new sources and
modifications will not change this status.

[]{#__RefHeading___Toc39114877 .anchor}**10.3 Maximum Achievable Control
Technology (MACT)**

MACT standards apply to toxic emissions from specific operations, as
described below.

**10.3.1 Subpart CC**

Subpart CC (Petroleum Refineries) applies to various refinery
operations, including: miscellaneous process vents, wastewater streams,
equipment leaks, and marine vessel loading operations. Compliance with
these requirements is addressed in detail in the proposed Title V permit
for this facility. Miscellaneous process vents are required to either be
controlled, or else limited to 15 lb/day of VOC emissions. Since
Regulation 8, Rule 2 limits vents to 15 lb/day, compliance with this
standard is assured. No controls are proposed in this MACT for
wastewater streams at facilities like this refinery with less than 10
megagram/yr of benzene loading. For equipment leaks, compliance with the
standards of this MACT is assured by compliance with the more strict
requirements of District Regulation 8, Rule 18.

**10.3.2 Subpart UUU**

Subpart UUU applies to catalytic cracking units, catalytic reforming
units and sulfur plants. The only affected sources in this application
are the sulfur plants. This standard requires that all vents from sulfur
plants not exceed a TRS emission equivalent to 300 ppmv SO2 (0% oxygen).
The compliance date for this requirement is April 11, 2005.

[]{#__RefHeading___Toc39114878 .anchor}**11.0 PERMIT CONDITIONS**

[]{#__RefHeading___Toc39114879 .anchor}**11.1 Sources with Modified
Conditions**

**11.1.1 Crude Unit S-300**

Crude Unit S-300 is currently subject to Condition 476. In addition to
the throughput increase in Part B.1, some editorial changes are
proposed, including:

• deletion of Part A: the terms defined in this section were previously
deleted from this condition

• deletion of Part D since the annualized limit referred to is deleted

• deletion of unnecessary headings, renumbering and addition of standard
text regarding the owner/operator

**CONDITION 476**

APPLICATION 5814; CONOCOPHILLIPS SF REFINERY; PLANT 16

CONDITIONS FOR S-300

1\. The owner/operator of S-300 shall not exceed a total charging rate
to S-300 (Coking Unit 200) of 81,000 barrels on any day.

\[Cumulative Increase\]

2\. The owner/operator shall maintain a file which contains (1) all
measurements, records, charts and other data which must be collected
pursuant to the provisions of this conditional permit and (2) such other
data and calculations necessary to determine actual emissions from
emission points covered by this permit. This file (which may contain
confidential or proprietary data) shall include, but not be limited to:
records of quantities of crude oil and other hydrocarbons processed on
an actual daily basis. This material shall be kept available for
District inspection for a period of at least 5 years following the date
on which such measurements, records or other data are made or recorded.

\[BACT, Cumulative Increase\]

3\. Each month, within 30 days of the end of the month an operational
report shall be made to the APCO. Each monthly report shall include the
following information for the month being reported:

a\. S-300 daily charging rate for all feed streams

\[BACT, Cumulative Increase\]

**11.1.2 Crude Unit S-350**

As discussed in Section 2.3, only editorial changes are proposed to
Condition 383:

**CONDITION 383**

APPLICATION 5814; CONOCOPHILLIPS SF REFINERY; PLANT 16

CONDITIONS FOR S-350

1a. The owner/operator of S-350 (Crude Unit 267) shall not process crude
oil at S-350 with a sulfur content in excess of 1.5 wt %.

\[Cumulative Increase\]

1b. The owner/operator shall sample and analyze the crude feed to S-350
to determine the sulfur content each time a new tanker shipment or
pipeline delivery of crude is introduced into the S-350 feed tanks.
\[Cumulative Increase\]

2\. The owner/operator of S-350 shall not exceed an S-350 feed rate of
30,000 bbl per day on a 12 month rolling average basis. The S-350 feed
rate shall never exceed 33,000 bbl on any calendar day. The 33,000
bbl/day limit and 30,000 bbl/day 12 month rolling average limit are
absolute limits and may not be corrected for instrument error.
\[Cumulative Increase\]

3\. The owner/operator of S-350 shall maintain monthly records of
\"calendar day\" throughput and \"12 month rolling average\" throughput
at S-350 in a District-approved log. The owner/operator shall also
maintain records of all sulfur content analyses required by Part 1b.
These records shall be kept for at least five years and shall be made
available to the District upon request. \[Cumulative Increase\]

**11.1.3 SO2 Bubble**

As discussed in Section 8.0, the SO2 Bubble in Condition 1694, Part 4
will be revised to include new SO2 emissions that are offset. Because
this condition is lengthy only the section related to the bubble is
shown. Since the only liquid fuel burned at the facility is naphtha (see
Major Facility Permit), references to fuel oil and diesel fuel will be
replaced by a reference to liquid fuel. The offset amount of SO2
emissions is:

9.75 ton/yr = 53 lb/day

And the new cap amount is:

(1,558 lb/day) + (53 lb/day) = 1,611 lb/day

APPLICATION 5814; CONOCOPHILLIPS SF REFINERY; PLANT 16

CONDITIONS FOR COMBUSTIONS SOURCES, INCLUDING NON-COGEN SO2 CAP

4\. Emissions of SO2 shall not exceed 1,611 lb/day on a monthly average
basis from non-cogeneration sources burning fuel gas or liquid fuel.
\[SO2 Bubble\]

[]{#refheading___toc39114880 .anchor}**11.2 New/Modified Sources**

**11.2.1 S-460 ULSD Hydrotreater**

APPLICATION 5814; CONOCOPHILLIPS SF REFINERY; PLANT 16

CONDITIONS FOR S-460 HYDROTREATER

1\. The owner/operator of S-460 shall not exceed a feed rate of 35,000
bbl/day

on a monthly average basis at this unit. \[Regulation 2-1-234\]

2\. The owner/operator of S-460 shall maintain the following records in
a District-approved log. These records shall be kept for at least 5
years and shall be made available to the District upon request.

a\. Daily records of feed throughput

b\. Average daily feed rate for each calendar month \[Regulation
2-1-234\]

**11.2.2 S-461 Hydrotreater Charge Heater**

APPLICATION 5814, CONOCOPHILLIPS REFINERY; PLANT 16

CONDITIONS FOR S-461 HEATER

1\. The owner/operator of the S-461 heater shall fire only refinery fuel
gas or natural gas at this unit. \[BACT, Cumulative Increase\]

2\. Based on refinery gas HHV, the owner/operator of S-461 shall not
exceed the following firing rates:

a\. 50.2 million BTU/hr

b\. 439,800 million BTU in any consecutive 12-month period.

\[Cumulative Increase\]

3a. The owner/operator of S-461 shall abate emissions from S-461 at the
A-461 SCR system whenever S-461 is operated. \[BACT, Cumulative
Increase\]

3b. The owner/operator of A-461 shall not exceed the following emission
rates from S-461/A-461 except during startups and shutdowns. Startups
and shutdowns shall not exceed 24 consecutive hours. The
24-consecutive-hour startup period is in addition to heater
dryout/warmup periods, which shall not exceed 72 consecutive hours.

NOx 10 ppmv @ 3% oxygen (3 hr average) \[BACT, Cumulative Increase\]

CO 28 ppmv @ 3% oxygen (8 hr average) at 25.1 MM BTU/hr and higher

firing rates, 50 ppmv @ 3% oxygen (8 hr average) at firing rates

below 25.1 MM BTU/hr \[BACT, Cumulative Increase\]

POC 5.5 lb/MM ft3 \[Cumulative Increase\]

PM10 7.6 lb/MM ft3 \[Cumulative Increase\]

ammonia 10 ppmv @ 3% oxygen (8 hr average) \[Toxic Management\]

Note: Part 3b shall not apply until after the conclusion of the initial
startup of S-461.

4\. The owner/operator shall equip S-461 with a District-approved
continuous fuel flow monitor and recorder in order to determine fuel
consumption. A parametric monitor as defined in Regulation 1-238 is not
acceptable. The owner/operator shall keep continuous fuel flow records
for at least five years and shall make these records available to the
District upon request.

\[Cumulative Increase\]

5a. The owner/operator shall install, calibrate, maintain, and operate a
District-approved continuous emission monitor and recorder for NOx and
O2. The owner/operator shall keep NOx and O2 data for at least five
years and shall make these records available to the District upon
request.

\[BACT, Cumulative Increase\]

5b. Following the initial source test required in Part 8, the
owner/operator shall monitor compliance with the CO emission rate limit
in Part 3b with a District-approved semi-annual source test, with at
least one source test per year deemed by the District to be
representative of normal operation. The owner/operator shall submit the
source test results to the District staff no later than 60 days after
the source test. The time interval between source tests shall not exceed
8 months. CO source tests performed by the District may be substituted
for semi-annual CO source tests. If two or more CO source tests, over
any consecutive five year period, indicate a CO emission rate of 200
ppmv @ 3% O2 or higher, the owner/operator shall install and operate a
District-approved continuous CO monitor/recorder within the time period
specified in the District Manual of Procedures.

\[BACT, Cumulative Increase\]

6\. The owner/operator shall use only refinery fuel gas at S-461 which
does not exceed the following limits:

a\. 100 ppmv totaled reduced sulfur (TRS), averaged over a calendar day

b\. 45 ppmv TRS, averaged over any rolling consecutive 365-day period.

\[BACT, Cumulative Increase\]

7a. The owner/operator shall test refinery fuel gas prior to combustion
at S-461 to determine total reduced sulfur (TRS) concentration by GC
analysis at least once per 8 hour shift (3 times per calendar day). At
least 90% of these samples shall be taken each calendar month. No
readable samples or sample results shall be omitted. TRS shall include
hydrogen sulfide, methyl mercaptan, methyl sulfide, dimethyl disulfide.
If the TRS value, averaged over any rolling consecutive 365-day period,
exceeds 35 ppmv, the owner/operator shall install and operate a
District-approved continuous monitor/recorder to determine the total
reduced sulfur content of the refinery fuel gas prior to combustion in
S-461 within the time period specified in the District Manual of
Procedures. \[BACT, Cumulative Increase\]

7b. To demonstrate compliance with Part 6, the owner/operator shall
measure and record the 24-hour average TRS content and the 365-day
average TRS content of the refinery fuel gas fired in S-461, unless
required to operate a District-approved continuous monitor/recorder by
Part 7a. The owner/operator shall keep TRS records, whether they are the
results of GC analysis or continuous analyzer data, for at least five
years and shall make these records available to the District upon
request. \[BACT, Cumulative Increase\]

8\. No later than 90 days from the startup of the S-461, the
owner/operator shall conduct District-approved source tests to determine
initial compliance with the limits in Part 3b for NOx, CO, POC, PM10 and
ammonia. The owner/operator shall conduct the source tests in accordance
with Part 9. The owner/operator shall submit the source test results to
the District staff no later than 60 days after the source test.

\[BACT, Cumulative Increase, Toxic Management\]

9\. The owner/operator shall obtain approval for all source test
procedures from the District's Source Test Section prior to conducting
any tests. The owner/operator shall comply with all applicable testing
requirements for continuous emissions monitors as specified in Volume V
of the District's Manual of Procedures. The owner/operator shall notify
the District's Source Test Section, in writing, of the source test
protocols and projected test dates at least 7 days prior to testing.

\[BACT, Cumulative Increase, Toxic Management\]

**11.2.3 S-304 Hydrotreater**

APPLICATION 5814; CONOCOPHILLIPS REFINERY; PLANT 16

CONDITIONS FOR S-304 HYDROTREATER

1\. The owner/operator of S-304 shall not exceed a feed rate of 12,198
bbl/day on a monthly average basis. \[Regulation 2-1-234\]

2\. The owner/operator of S-304 shall maintain the following records in
a District-approved log. These records shall be kept for at least 5
years and shall be made available to the District upon request.

a\. Daily records of feed throughput

b\. Average daily feed rate for each calendar month

\[Regulation 2-1-234\]

**11.2.4 S-36 Crude Unit Vacuum Tower Heater**

APPLICATION 5814, CONOCOPHILLIPS REFINERY; PLANT 16

CONDITIONS FOR S-36 HEATER

1\. The owner/operator of the S-36 heater shall fire only refinery fuel
gas or natural gas at this unit. \[BACT, Cumulative Increase\]

2\. Based on refinery gas HHV, the owner/operator of S-36 shall not
exceed the following firing rates:

a\. 82.1 million BTU/hr

b\. 719,200 million BTU in any consecutive 12-month period.

\[Cumulative Increase\]

3a. The owner/operator of S-36 shall abate emissions from S-36 at the
A-36 SCR system whenever S-36 is operated. \[BACT, Cumulative Increase\]

3b. The owner/operator of S-36 shall not exceed the following emission
rates from S-36/A-36 except during startups and shutdowns. Startups and
shutdowns shall not exceed 24 consecutive hours. The 24-consecutive-hour
startup period is in addition to heater dryout/warmup periods, which
shall not exceed 72 consecutive hours.

NOx 10 ppmv @ 3% oxygen (3 hr average) \[BACT, Cumulative Increase\]

CO 28 ppmv @ 3% oxygen (8 hr average) \[BACT, Cumulative Increase\]

POC 5.5 lb/MM ft3 \[Cumulative Increase\]

PM10 7.6 lb/MM ft3 \[Cumulative Increase\]

ammonia 10 ppmv @ 3% oxygen (8 hr average) \[Toxic Management\]

Note: Part 3b shall not apply until after the conclusion of the initial
startup of S-36.

4\. The owner/operator shall equip S-36 with a District-approved
continuous fuel flow monitor and recorder in order to determine fuel
consumption. A parametric monitor as defined in Regulation 1-238 is not
acceptable. The owner/operator shall keep continuous fuel flow records
for at least five years and shall make these records available to the
District upon request.

\[Cumulative Increase\]

5a. The owner/operator shall install, calibrate, maintain, and operate a
District-approved continuous emission monitor and recorder for NOx and
O2. The owner/operator shall keep NOx and O2 data for at least five
years and shall make these records available to the District upon
request.

\[BACT, Cumulative Increase\]

5b. Following the initial source test required in Part 8, the
owner/operator shall monitor compliance with the CO emission rate limit
in Part 3b with a District-approved semi-annual source test, with at
least one source test per year deemed by the District to be
representative of normal operation. The owner/operator shall submit the
source test results to the District staff no later than 60 days after
the source test. The time interval between source tests shall not exceed
8 months. CO source tests performed by the District may be substituted
for semi-annual CO source tests. If two or more CO source tests, over
any consecutive five year period, indicate a CO emission rate of 200
ppmv @ 3% O2 or higher, the owner/operator shall install and operate a
District-approved continuous CO monitor/recorder within the time period
specified in the District Manual of Procedures.

\[BACT, Cumulative Increase\]

6\. The owner/operator shall use only refinery fuel gas at S-36 which
does not exceed the following limits:

a\. 100 ppmv totaled reduced sulfur (TRS), averaged over a calendar day

b\. 45 ppmv TRS, averaged over any rolling consecutive 365-day period.

\[BACT, Cumulative Increase\]

7a. The owner/operator shall test refinery fuel gas prior to combustion
at S-36 to determine total reduced sulfur (TRS) concentration by GC
analysis at least once per 8 hour shift (3 times per calendar day). At
least 90% of these samples shall be taken each calendar month. No
readable samples or sample results shall be omitted. TRS shall include
hydrogen sulfide, methyl mercaptan, methyl sulfide, dimethyl disulfide.
If the TRS value, averaged over any rolling consecutive 365-day period,
exceeds 35 ppmv, the owner/operator shall install and operate a
District-approved continuous monitor/recorder to determine the total
reduced sulfur content of the refinery fuel gas prior to combustion in
S-36 within the time period specified in the District Manual of
Procedures. \[BACT, Cumulative Increase\]

7b. To demonstrate compliance with Part 6, the owner/operator shall
measure and record the 24-hour average TRS content and the 365-day
average TRS content of the refinery fuel gas fired in S-36, unless
required to operate a District-approved continuous monitor/recorder by
Part 7a. The owner/operator shall keep TRS records, whether they are the
results of GC analysis or continuous analyzer data, for at least five
years and shall make these records available to the District upon
request. \[BACT, Cumulative Increase\]

8\. No later than 90 days from the startup of the S-36, the
owner/operator shall conduct District-approved source tests to determine
initial compliance with the limits in Part 3b for NOx, CO, POC, PM10 and
ammonia. The owner/operator shall conduct the source tests in accordance
with Part 9. The owner/operator shall submit the source test results to
the District staff no later than 60 days after the source test.

\[BACT, Cumulative Increase, Toxic Management\]

9\. The owner/operator shall obtain approval for all source test
procedures from the District's Source Test Section prior to conducting
any tests. The owner/operator shall comply with all applicable testing
requirements for continuous emissions monitors as specified in Volume V
of the District's Manual of Procedures. The owner/operator shall notify
the District's Source Test Section, in writing, of the source test
protocols and projected test dates at least 7 days prior to testing.

\[BACT, Cumulative Increase, Toxic Management\]

**11.2.5 Fugitive Components**

APPLICATION 5814; CONOCOPHILLIPS REFINERY; PLANT 16

CONDITIONS FOR ULSD PROJECT FUGITIVE COMPONENTS

1\. The owner/operator shall equip all light hydrocarbon control valves
installed as part of the USLD Project with live loaded packing systems
and polished stems, or equivalent. \[BACT\]

2\. The owner/operator shall equip all flanges/connectors installed in
the light hydrocarbon piping systems as part of the USLD Project with
graphitic-based gaskets unless the service requirements prevent this
material. \[BACT\]

3\. The owner/operator shall equip all new hydrocarbon centrifugal
compressors installed as part of the USLD Project with "wet" dual
mechanical seals with a heavy liquid barrier fluid, or dual dry gas
mechanical seals buffered with inert gas. \[BACT\]

4\. The owner/operator shall equip all new light hydrocarbon centrifugal
pumps installed as part of the USLD Project with a seal-less design or
with dual mechanical seals with a heavy liquid barrier fluid, or
equivalent. \[BACT\]

5\. The owner/operator shall integrate all new fugitive equipment
installed as part of the USLD Project, in organic service, into the
facility fugitive equipment monitoring and repair program. \[BACT\]

6\. The Owner/Operator shall submit a count of installed pumps,
compressors, valves, and flanges/connectors every 180 days until
completion of the project. For flanges/connectors, the owner/operator
shall also provide a count of the number of graphitic-based and
non-graphitic gaskets used. The owner/operator has been permitted to
install fugitive components (5,410 valves, 2,376 flanges, 3,564
connectors, 26 pumps, 14 compressors) with a total POC emission rate of
8.62 ton/yr. If there is an increase in the total fugitive component
emissions, the plant's cumulative emissions for the project shall be
adjusted to reflect the difference between emissions based on predicted
versus actual component counts. The owner/operator shall provide to the
District all additional required offsets at an offset ratio of 1.15:1 no
later than 14 days after the submittal of the final POC fugitive
equipment count. If the actual component count is less than the
predicted, at the completion of the project, the total will be adjusted
accordingly and all emission offsets applied by the owner/operator in
excess of the actual total fugitive emissions will be credited back to
owner/operator prior to issuance of the permits.

\[BACT, Cumulative Increase, Toxic Management\]

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**12.0 RECOMMENDATION**

Grant Authority to Construct to ConocoPhillips for the following:

**Issue an Authority to Construct to ConocoPhillips Petroleum for:**

**S-460 ULSD Hydrotreater (Unit 250): 35,000 bbl/day of diesel stock**

**S-461 ULSD Hydrotreater Charge Heater: 50.2 MM BTU/hr (HHV); refinery
gas-fired; abated by A-461 SCR system**

**A-461 SCR: aqueous ammonia, to abate S-461 heater**

**S-462 Fuel Gas Caustic Treatment System (Unit 215): caustic scrubber,
a caustic solution stripper, storage tanks for caustic solution and
amine solution (MEA) used for caustic recycling; 4.2 million standard
cubic feet per day of fuel gas from Unit 233**

**S-463 Butane Caustic Treatment System (Unit 215): caustic scrubber, a
caustic solution stripper, storage tanks for caustic solution and amine
solution (MEA) used for caustic recycling; 1,000 bbl/day of butane stock
from Unit 215**

**S-304 Light Naphtha Hydrotreater (Unit 229): Service change from
diesel hydrotreating with reactor and heat exchanger modifications;
naphtha processing capacity of 12,198 bbl/day.**

**S-350 Crude Unit (Unit 267): Change bottoms flow from S-300 coker to
S-300 vacuum tower; internal modification to towers**

**S-300 Crude/Coker Unit (Unit 200): Replace vacuum and atmospheric
towers; total processing capacity of 81,000 bbl/day**

**S-36 Crude Unit Vacuum Tower Feed Heater: 82.1 MM BTU/hr (HHV);
refinery gas-fired; abated by A-36 SCR system**

**A-36 SCR: aqueous ammonia, to abate S-36 heater**

**S-1002 Sulfur Recovery Plant: Modify to use pure oxygen; 86 LTD
nominal sulfur removal capacity; 271 long ton/day total sulfur plant
capacity at S-1001, S-1002 and S-1003**

**S-1003 Sulfur Recovery Plant: Modify to use pure oxygen; 115 LTD
nominal sulfur removal capacity; 271 long ton/day total sulfur plant
capacity at S-1001, S-1002 and S-1003**

**Miscellaneous Modifications:**

**• Replace amine stripper heat exchangers**

**• Install new 230 gpm sour water stripper**

Issue a permit exemption to ConocoPhillips Petroleum for:

**S-500 ULSD Cooling Tower: 11 MM gal/day; exempt in accordance with
Regulation 2-1-128.4**

**By:**
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

**J. Julian Elliot**

**Senior Air Quality Engineer**

JE:je

5814.doc