STATE OF WASHINGTON


### DEPARTMENT OF ECOLOGY

PO Box 47600 • Olympia, WA 98504-7600 • 360-407-6000

711 for Washington Relay Service • Persons with a speech disability can call 877-833-6341

May 13,2015

Mr

. Bob Allendorfer

Business Unit Leader

BP Cherry Point Refmery

4519 Grandview Road
Blaine, W A 98230

Re: Regional Haze Best Available Retrofit Technology (BART) Determination, Revision 2,

Inclusion of BART Alternative

Dear Mr. Allendorfer:

BART is required to reduce the regional haze impacts of emissions of your facility. The

enclosed order #7836, Revision 2, contains our BART determination for your facility revised as requested.

If you have questions or requests relating to this order, please contact Alan Newman at (360) 407

- 6810 or at the address above.

Sincerely,

## ~r{J6r•~ c::::_-

# =:=-**--** Ranil Dhammapala, Ph.D. Acting Science and Engineering Section Manager

Air Quality Program

rdlte

Enclosure

By certified mail

cc: Agata Mcintyre, NWCAA

Jim Chalfant, BP Cherry Point Refinery

Alan Newman, EcologySTATE OF WASHINGTON

DEPARTMENT OF ECOLOGY

IN THE MATTER OF AN ]

ADMINISTRATIVE ORDER AGAINST: ] ] ORDER NO. 7836 BP Cherry Point Refinery ] Revision 2

, Inclusion of ] BART Alternative

T O : Mr. Bob Allendorfer BP Cherry Point Refinery
4519 Grandview Road Blaine, WA 98230

This is an Administrative Order requiring your company to comply with WAC 173

- 40 0

- 151 by taking the a ctions which are described below. Chapter 70.94 RCW authorizes the Washington

State Department of Ecology ’s Air Quality Program (Ecology) to issue Administrative Orders to require compliance with the requirements of Chapter 70.94 RCW and regulations issued to implement it

.

Ecology has determined that portions of your facility are subject to the provisions of the federal

and state visibility protection program (WAC 173

- 400

- 151 and 40 CFR Part 51, Subpart P)

. The

r ules requir e th at the S tate determin e what technologies and level of emission control constitutes Best Available Retrofit Technology (BART) for the eligible emission units at your facility

. T he rules also require the installation and use of those emission controls on th e BART

- eligible

emission units

. The emission controls are to be installed as expeditiously as possible, but in no

even t can the State allow them to start operatio n later than five years after the S tate’s Regional Haze SIP amendment is approved by the United States Environmental Protection Agency ( EPA )

.

FINDINGS

The BP Cherry Point Refinery operate s an oil refinery near Blaine , W ashington

, that contains

emission units that are subject to BART.

A. The BART

- eligible emission units at the BP Cherry Point R efinery are:

a. Process heaters and boilers:

1. 30

- 1601 , Boiler #1

2. 30

- 1603 , Boiler #3

3. 10

- 1401 , Crude Charge Heater

4. 10

- 1451 , South Vacuum Heater

5. 11

- 1401 , Naphtha HDS Charge Heater

6. 11

- 1402 , Naphtha HDS St ripper Reboiler

7. 11

- 1403

- 1406 , #1 Reformer Heater sBP Cherry Point Refinery Page 2 of 10 BART Compliance Order No. 7836, Revision 2 May 13, 2015

8. 12

- 1401

- 01 , Coker Charge Heater (#1 North)

9. 12

- 1401

- 02 , Coker Charge Heater (#2 South)

10. 13

- 1401 , #1 Diesel HDS Charge Heater

11. 13

- 1402 , #1 Diesel HDS Stabilizer Reboiler

12. 14

- 1401 , Steam Reforming Furnace #1

- (North Hydrogen (H2) Plant)

13. 14

- 1402 , Steam Reforming Furnace #2

- (South H2 Plant)

14. 15

- 1401 , R

- 1 HC Reactor Heater

15. 15

- 1402 , R

- 4 HC Reactor Heater

16. 15

- 1451 , 1st Stage HC Fractionator Reboiler

17. 15

- 1452 , 2nd Stage HC Fractionator Reboiler

b. Other units:

1. 17, 19, SRU & TGU

2. 29.110, High Pressure Flare

3. 29

- 111 , Low Pressure Flare

4. Green Coke Load out

B. BART emission limitations for the BART

- eligible emission units is a combination of :

a. Use of existing burners on process heaters and reboilers

.
b. Continued use of the current refinery fuel gas sulfur scrubbing system for control of sulfur dioxide ( SO 2 ) emissions.

C. Treatment of Specif ic Units

a. Boilers #1 and # 3 were decommissioned on December 11, 2009

.

Additional information and analysis is available in the BART Dete rmi nation Support Document for the BP Cherry Point Refinery, Blaine, Washington , by Ecology, March 2009

, and the Best Available Retrofit Technology Determination, BP Cherry Point Refinery, prepared by Geomatrix Consultants, March 2008. Information on Revision 1 to this Order can be found in the Bart Determination Support Document for Revision 1, dated May 2013. Information on Revision 2 to

this Order can be found in the B ART Determination Support Document for Revision 2, dated

June 2014

.BP Cherry Point Refinery Page 3 of 10 BART Compliance Order No. 7836, Revision 2 May 13, 2015

YOU ARE ORDERED : To install and operate emission control equipment in accordance with the following condition s.

BART E mission L imitations

1. Particulate M atter E missions

1.1. A ll BART

- eligible unit s listed in Finding A meet the emission limitations for particulate matter found in NWCAA’s Regulation 455.1 given below.

1.1.1. Emissions shall not exceed 0.10 grain/dscf (corrected to 7 percent oxygen (O 2 ) ) , except from all gaseous and distillate fuel burning equipment (the definition of fuel burning equipment does not include internal combustion engines), emissions shall not exceed 0.05 grain/dscf (0.11 g/m 3 ) corrected to 7
percent O 2

.

1.2. Compliance with the particulate emission limits a bov e will be determined as follows:

1.2.1. Burn only gaseous fuels

.
1.2.2. For all BART

- eligible units, perform particulate emissions testing to determine compliance when requested in writing by NWCAA or Ecology. Particulate testing is performed using EPA Test M ethod 5 in 40 CFR Part 60 Appendix A,

and Method 202 in 40 CFR 51 Appendix M

.

2. Nitrogen O xide s (NO X ) E missions

2.1. South Vacuum Heater, Unit 10

- 1451

2.1.1. NO X emissions shall not exceed 10.5 pounds per hour ( lb/hr ) based on a calendar day average.

2.1.2. Compliance with this condition shall be determined by a CEM installed, calibrated, maintained

, and operated to measure NO X and O 2 in the stack.

2.1.3. Each monitor shall meet the appropriate sections of NWCAA Section 366 and NWCAA Appendix A.

2.1.4. Hourly emission rates for NO X shall be recorded

. On

- site documentation shall be kept showing the method of calculating the mass emission rate.

2.1.5. Report data in monthly monitoring report.

2.2. Coker Charge Heater (#1 North), 12

- 1401

- 01BP Cherry Point Refinery Page 4 of 10 BART Compliance Order No. 7836, Revision 2 May 13, 2015

2.2.1. NO X emissions shall not exceed 15.2 lb/hr and 66 tons per year (tpy)

.
2.2.2. Compliance shall be determined by biennial performance tests on one of two

identical heaters (#2 North or #2 South) using 40 CFR 60 Appendix A Method

7A or 7E

.

2.3. Coker Charge Heater (#2 South), 12

- 1401

- 02

2.3.1. NO X emissions shall not exceed 15.2 lb/hr and 66 tpy

.
2.3.2. Compliance shall be determined by biennial performance tests on one of two identical heaters using 40 CFR 60 Appendix A Method 7A or 7E.

2.4. #1 Diesel HDS Charge Heater, 13

- 1401 and Diesel HDS Stabilizer Rebo iler, 13

- 1402

2.4.1. NO X emissions from the #1 Diesel Hydrotreater Charge Heater shall not exceed 0.040 lb/MMBtu (higher heating value) , or if this emission limit is exceeded, 1.9 lb/hr

.
2.4.2. NO X emissions from the Stabilizer Reboiler Heater shall not exceed 26 ppmv (dry basis corrected to 7 percent O 2 ) based on a 24

- hour rolling average

. If this concentration is exceeded, a secondary limit to demonstrate compliance is 2.2

lb/hr based on a 24

- hou r rolling average.

2.4.2.1. Ongoing compliance with this condition shall be determined by a continuous emission monitor (CEM) installed, calibrated, maintained, and operated to measure NO X and O 2 in the stack by no later than December 1, 2008. Each monitor shall m eet the appropriate specifications of 40 CFR 60 Appendices B and F, NWCAA Section 367 and NWCAA Appendix A.

2.5. R

- 1 HC Reactor Heater, 15

- 1401

2.5.1. NO X from the Hydrocracker R

- 1 Heater shall not exceed the following

emission limits

.
2.5.1.1. 26 ppm by volume, dry basis, corrected to 7 percent O 2 , based on a

24

- hour rolling average. Or, if this concentration based limit is exceeded, the following mass emission rate limit shall be used to demonstrate compliance.

2.5.1.2. 4.9 lb/hr based on a 24

- hour ro lling average.

2.5.2. Biennial source testing shall be completed within two months of the anniversary date of the initial test. The test shall be performed underBP Cherry Point Refinery Page 5 of 10 BART Compliance Order No. 7836, Revision 2 May 13, 2015

representative operating conditions and at a heater firing rate that corresponds to the operating c ondition of the Hydrocracker Unit on the scheduled test day. The test shall be conducted in accordance with USEPA Reference Method 7E, NWCAA Regulation Section 367 and NWCAA Appendix A.

2.5.3. NO X emissions shall be continuously monitored by a certified continuous emission monitoring system (CEMS) for NO X and O 2

. The CEMS shall be installed, calibrated, maintained, and operated in accordance with appropriate specifications of 40 CFR 60 Appendices B and F, NWCAA Section 367 and NWCAA Appendix A.

2.5.4. An operating and maintenance manual that contains O&M information on the

ultra

- low NO X burners shall be maintained on site.

2.6. 1st Stage HC Fractionator Reboiler, 15

- 1451

2.6.1. NO X emissions from the boiler st a ck shall not exceed 0. 0 5 lb/MMBtu or 9.9 lb/hr, both limits based on a 24

- hour rolling average

.
2.6.2. A c ontinuous emission monitor or eq uival ent method approved by the

NWCAA shall be used to measure NO X emissions.

2.6.3. An operating and maintenance manual that conta ins O&M information on the

low NO X burners shall be maintained on site.

2.7. 2nd Stage HC Fractionator Reboiler, 15

- 1452

2.7.1. Emission of NO X from the heater stack shall not exceed 0.07 lb/MMBtu based

on a 24

- hour average and shall not exceed 56.2 tpy on a calend ar year rolling

average.

2.7.2. Report NO X emissions based on firing rates on a calendar month basis within 30 days after the end of the previous month.

2.7.3. Conduct periodic source testing once every five years within three months of the anniversary of the initial test. Follow 40 CFR 60 Appendix A Method 20.

2.7.4. An operating and maintenance manual that contains O&M information on the

low NO X burners shall be mai ntained on site.

2.8. No NO X emission limitations are applicable to the following units.

2.8.1. Crude Charge Heater Unit 10

- 1401 , the Naphtha HDS Charge Heater Unit 11

- 1401

2.8.2. Naphtha HDS Stripper Reboiler U nit 11

- 1402BP Cherry Point Refinery Page 6 of 10 BART Compliance Order No. 7836, Revision 2 May 13, 2015

2.8.3. #1 Reformer Heaters 11

- 1403

- 1406

2.8.4. Steam Reforming Furnace #1 (North Hydrogen (H 2 ) Plant Unit 14

- 1401

2.8.5. Steam Reforming Furnace #2 (South H 2 Plant) U nit 14

- 1402

2.8.6. R 4 HC Reactor Heater, Unit 15

- 1402

3. SO 2 E missions

3.1. Coker Charge Heater s #1 North and #1 South

3.1.1. SO 2 emissions s hall not exceed 14.9 lb/hr and 66 tpy per heat e r

.
3.1.2. Compliance shall be determined by biennial performance tests on one of two

iden t ical heaters using 40 CFR 60 Method 6 or 6C or Fuel Gas Analysis using

Method 11 or 15.

3.2. Plant

- wide refinery fuel gas requirements

3.2.1. All units identified in Fin ding A(a) and A(b)(1) shall meet the emissions limitations for fuel gas contained in the NWC A A ’s Agreed Compliance Order

No. 5 Section IV, dated October 23, 2012

.
3.2.1.1. Fuel gas is l imited to a composition of H 2 S <230 mg/dscm (0.10 gr/dscf)

. Equivalent to 162 ppm H 2 S, 3

- hour rolling average.

3.2.2. Operate CEM for H 2 S concentration at the fuel feed line in accordance with NWCAA 367 and Appendix A

- “Ambient Monitoring, Emission Testing, and Continuous Emission and Opacity Monitoring

, ” 40 CFR 60 Subpart J and 40

CFR 60 Appendices B and F.

3.2.3. Periods of excess emissions that shall be determined and reported are defined

as follows

. All rolling 3

- hour periods during which the average concentration

of H 2 S as measured by the H 2 S continuous monitoring system under §60.105(a)(4) exceeds 162 ppmv.

3.2.4. Report average H 2 S content (3

- hour rolling average) in monthly report.

4. All Other BART Units

4.1. SRU and TGU

4.1.1. SO 2 emissions from TGU stacks 1 and 2 shall not exceed any of the following

emission limits.BP Cherry Point Refinery Page 7 of 10 BART Compliance Order No. 7836, Revision 2 May 13, 2015

4.1.1.1. 250 (2.50 x l0 2 ) ppm by volume, dry basis, corrected to zero percent

O 2 , based on a 12

- hour rolling average

. The 12

- hour rolling average shall be calculated based on corrected hourly averages for the twelve, most recent, consecutive clock hours.

4.1.1.2. 1500 (1.50 x l0 3 ) ppm by volume, dry basis, corrected to zero percent

O 2 , based on a one

- hour rolling average

.
4.1.1.3. Compliance with this condition shall be determined by a continuous emission monitor (CEM) installed, calibrated, maintained, and operated to measure SO 2 and O 2 in each T GU stack. Each monitor shall meet the appropriate specifications of 40 CFR 60 Appendices B and F, NWCAA Regulation Section 367 and NWCAA Appendix A

.
4.1.1.4. Total tons of SO 2 emitted from the sulfur recovery unit shall not

exceed 135 tons based on each consecutive 12

- month rolling period.

The most recent 12

- month rolling total shall be reported to the NWCAA on each monthly emissions report

.

Schedule for Compliance

5. Complian ce with Conditions 1 through 4:

5.1. For all requirements in Conditions 1, 2, 3 and 4, except Conditions 2.5.1 and 2.6.1, compliance is required by August 7, 2009

.
5.2. For all requirements in Conditions 2.5.1 and 2.6.1, compliance is required by July 1,

2014.

Monitoring and Recordkeeping Requirements

6. SO 2 E missions

6.1. SO 2 performance tests required by Conditions 3.1.2 shall be submitted to NWCAA and Ecology upon request.

6.2. Operate CEMS measuring H 2 S concentration in accordance with NWCAA 367 and NWCAA Appendix A, and 40 CFR 60 Subpart J and 40 CFR 60 Appendices B and F.

6.3. CEMS data including daily average H 2 S concentrations of the refinery fuel gas shall be recorded and retained at the facility available for review by NWCAA or Ecology inspectors.BP Cherry Point Refinery Page 8 of 10 BART Compliance Order No. 7836, Revision 2 May 13, 2015

Other Requirements

7. Boilers #1 and #3 shall be decommi ssioned by no later than March 27, 2010

. NW CAA shall be notified in writing of the decommissioning date of each boiler. Notifications shall be postmarked no later than 15 days after each decommissioning event.

8. BP may request this compliance Order be res cinded a fter all of the following occur.

8.1. All BART units at the plant have continuously complied with the emissions limit ations

in Conditions 1 through 4 for a period of three years

.
8.2. The emission limitations in this Order have been incorporated into one or more enforceable orders or permits issued under the criteria of RCW 70.94.152 or 70.94.153 and NWCAA regulations implementing these provisions.

8.3. The emission limitations in the enforceable orders or permits have been incorporated into the Air Operating Per mit issued by NWCAA to BP.

9. The BART requirements for an emission unit specifically listed in this Order do not apply after the BP Cherry Point Refinery has certified in writing to the Ecology and NWCAA that the named BART emission unit has been permanently taken out of service and dismantled

.

10. Ecology may, by regulatory order, revise the monitoring, reporting

, and recordkeeping requirements specified in this O rder. The revised monitoring, r eporting

, and recordkeeping methods must provide equal or better information on the compliance status of the source or emission unit subject to the revised monitoring, reporting

, or recordkeeping methods.

11. Issuance of this O rder indicates requirements of O rder 5069 have been complied with.

Within 2 0 days of receipt of this Order, you may request a delay in the submittal date. Any such request must be accompanied by a written justification for the delay.

Failure to comply with this Order may result in the issuance of civil penalties or other actions, whether administrative or judicial, to enforce the terms of this Order.

You have a right to appeal this Order

. To appeal you must:

• File your appeal with t he Pollution Control Hearing Board within 30 days of the “date of receipt” of this document . Filing means actual receipt by the Board during regular office

hours

.BP Cherry Point Refinery Page 9 of 10 BART Compliance Order No. 7836, Revision 2 May 13, 2015

• Serve your appeal on the Department of Ecology within 30 days of the “date of receipt”

of this document . Service may be accomplished by any of the procedures identified in

WAC 371

- 08

- 305(10). “Date of receipt” is defined at RCW 43.21B.001(2)

.

If you appeal

, you must:

• Include a copy of this document with your Notice of Appeal

.

• Serve and file your appeal in paper form; electronic copies are not accepted

.

To file your appeal with the Pollution Control Hearing Board:

Mail appeal to:

The Pollution Control Hearings Board

P

. O

. Box 40903 Olympia, WA 98504

- 0903 OR Deliver your appeal in person to:

The Pollution Control Hearings Board

4224

– 6th Ave nue SE Rowe Six, Bldg 2 Lacey, WA 98503

To serve your appeal on the Department of Ecology:

Mail appeal to:

Department of Ecology Appeals Coordinator

P.O. Box 47608 Olympia, WA 98504

- 7608 OR Deliver your appeal in person to:

Department of Ecology Appeals Coordinator

300 Desmond Dr ive SE Lacey, WA 98503

And send a copy of your appeal packet to:

Alan Newman Department of Ecology Air Quality Program

P. O. Box 47600 Olympia, WA 98504

- 7600

For additional information , go to the Environmental Hearings Office w ebsite at http://www.eho.wa.gov

.

To find laws and agency rules , go to the Washi ngton State Legislature website at http://www1.leg.wa.gov/CodeReviser

.BP Cherry Point Refinery

BART Compliance Order No. 7836, Revision 2 May 13,2015 Page 10 oflO

Your appeal alone will not stay the effectiveness of this Order. Stay requests must be submitted
in accordance with RCW 43.21B.320. These procedures are consistent with Chapter 43.21B

RCW.

t' DATED this \3 day of**JVl~** 20 IS at Olympia, Washington.

Ranil1Jliammapala, Ph.D.

, Acting Science and Engineering Section Manager
Air Quality Program