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 Refinery 

4519 Grandview Road 

Blaine, WA 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, 

~ra~ 

Ranil Dhammapala, Ph.D. 

Acting Science and Engineering Section Manager 

Air Quality Program 

rd/te 

Enclosure 

By certified mail 

cc: Agata Mcintyre, NW CAA 

Jim Chalfant, BP Cherry Point Refinery 

Alan Newman, Ecology 
STATE 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

TO: 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 173-400-151 by 

taking the actions 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 

rules require that the State determine what technologies and level of emission control constitutes 

Best Available Retrofit Technology (BART) for the eligible emission units at your facility. The

rules also require the installation and use of those emission controls on the BART-eligible

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

event can the State allow them to start operation later than five years after the State’s Regional 

Haze SIP amendment is approved by the United States Environmental Protection Agency (EPA).

FINDINGS

The BP Cherry Point Refinery operates an oil refinery near Blaine, Washington, that contains 

emission units that are subject to BART. 

A. The BART-eligible emission units at the BP Cherry Point Refinery 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 Stripper Reboiler

7. 11-1403-1406, #1 Reformer Heaters
BP 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 (SO2) emissions. 

C. Treatment of Specific Units

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

Additional information and analysis is available in the BART Determination 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 BART 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 conditions.

BART Emission Limitations

1. Particulate Matter Emissions

1.1. All BART-eligible units 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

(O2)), 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/m3) corrected to 7

percent O2.

1.2. Compliance with the particulate emission limits above 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 Method 5 in 40 CFR Part 60 Appendix A, 

and Method 202 in 40 CFR 51 Appendix M.

2. Nitrogen Oxides (NOX) Emissions

2.1. South Vacuum Heater, Unit 10-1451

2.1.1. NOX 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 NOX and O2 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 NOX 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), 12-1401-01
BP Cherry Point Refinery Page 4 of 10

BART Compliance Order No. 7836, Revision 2

May 13, 2015

2.2.1. NOX 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. NOX 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 Reboiler, 13-1402

2.4.1. NOX 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. NOX emissions from the Stabilizer Reboiler Heater shall not exceed 26 ppmv 

(dry basis corrected to 7 percent O2) 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-hour 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 NOX and O2 in the stack by no 

later than December 1, 2008. Each monitor shall meet 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. NOX 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 O2, 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 rolling 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 under 
BP 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 condition 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. NOX emissions shall be continuously monitored by a certified continuous 

emission monitoring system (CEMS) for NOX and O2. 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 NOX burners shall be maintained on site.

2.6. 1st Stage HC Fractionator Reboiler, 15-1451

2.6.1. NOX emissions from the boiler stack shall not exceed 0.05 lb/MMBtu or 9.9 

lb/hr, both limits based on a 24-hour rolling average. 

2.6.2. A continuous emission monitor or equivalent method approved by the 

NWCAA shall be used to measure NOX emissions. 

2.6.3. An operating and maintenance manual that contains O&M information on thelow NOX burners shall be maintained on site.

2.7. 2nd Stage HC Fractionator Reboiler, 15-1452

2.7.1. Emission of NOX 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 calendar year rolling 

average. 

2.7.2. Report NOX 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 thelow NOX burners shall be maintained on site.

2.8. No NOX 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 Unit 11-1402
BP 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 (H2) Plant Unit 14-1401

2.8.5. Steam Reforming Furnace #2 (South H2 Plant) Unit 14-1402

2.8.6. R 4 HC Reactor Heater, Unit 15-1402

3. SO2 Emissions

3.1. Coker Charge Heaters #1 North and #1 South

3.1.1. SO2 emissions shall not exceed 14.9 lb/hr and 66 tpy per heater.

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

identical 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 Finding A(a) and A(b)(1) shall meet the emissions 

limitations for fuel gas contained in the NWCAA’s Agreed Compliance Order 

No. 5 Section IV, dated October 23, 2012.

3.2.1.1. Fuel gas is limited to a composition of H2S <230 mg/dscm (0.10 

gr/dscf). Equivalent to 162 ppm H2S, 3-hour rolling average.

3.2.2. Operate CEM for H2S 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 H2S as measured by the H2S continuous monitoring system under 

§60.105(a)(4) exceeds 162 ppmv.

3.2.4. Report average H2S content (3-hour rolling average) in monthly report.

4. All Other BART Units

4.1. SRU and TGU

4.1.1. SO2 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 l02) ppm by volume, dry basis, corrected to zero percent 

O2, 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 l03) ppm by volume, dry basis, corrected to zero percent 

O2, 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 SO2 and O2 in each TGU 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 SO2 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. Compliance 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. SO2 Emissions

6.1. SO2 performance tests required by Conditions 3.1.2 shall be submitted to NWCAA and 

Ecology upon request. 

6.2. Operate CEMS measuring H2S 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 H2S 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 decommissioned by no later than March 27, 2010. NWCAA 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 rescinded after all of the following occur.

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

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 Permit 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 Order. The revised monitoring, reporting, 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 Order indicates requirements of Order 5069 have been complied with.

Within 20 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 the 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 Avenue 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 Drive 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 website at 

http://www.eho.wa.gov.

To find laws and agency rules, go to the Washington 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 10of10 

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 Mlt.;1;;) 20 IS at Olympia, Washington. 

Ranil1Jliammapala, Ph.D. , 

Acting Science and Engineering Section Manager 

Air Quality Program