BP WEST COAST PRODUCTS, LLC 

CHERRY POINT REFINERY 

BLAINE, WASHINGTON 

AIR OPERATING PERMIT 

FINAL MODIFICATION 

September 06, 2006
BP Cherry Point Refinery, Air Operating Permit #015 

Modification 1 – September 06, 2006

ii 

AIR OPERATING PERMIT 

INFORMATION PAGE 

BP Cherry Point Refinery 

4519 Grandview Road, Blaine, Washington 98230 

SIC: 2911 

EPA AFS: 53-073-10007 NWCAA ID: 011-V-W 

Responsible Corporate Official Corporate Inspection Contact 

Mr. Rick Porter, Business Unit Leader 

Mr. Dennis Bays, Alternate RCO 

Mr. Terry Golden, Alternate RCO 

4519 Grandview Road 

Blaine, Washington 98230 

(360) 371-1500 

Ms. Elizabeth Daly 

Environmental Supervisor 

4519 Grandview Road 

Blaine, Washington 98230 

(360) 371-1437 

Northwest Clean Air Agency Prepared by 

1600 South Second Street 

Mount Vernon, Washington 98273-5202 

(360) 428-1617 

Dan Mahar, P.E. 

Air Quality Engineer 

Extension 203 

Air Operating Permit Number: Issuance Date: 

015 June 16, 2003 

Permit Modifications: Modification Date: 

Modification 1 September 06, 2006 

Supersedes Permit Number: Expiration Date: 

N/A June 16, 2008 

Application Date: Renewal Application Due: 

October 30, 2003 (modification) December 16, 2007 
BP Cherry Point Refinery, Air Operating Permit #015 

Modification 1 – September 06, 2006 

iii 

Attest

This operating permit is issued in accordance with the provisions of the Washington 

Clean Air Act Chapter 70.94 Revised Code of Washington and the Clean Air Act 42 

United States Code, Section 7401 et seq. 

 

BP West Coast Products, LLC is authorized to operate subject to the terms and 

conditions of this operating permit. 

This operating permit has been reviewed by the undersigned Northwest Clean Air Agency staff. 

 

Date: Date: 

Lynn Billington, P. E. 

Manager of Technical Services 

 

James Randles 

Director 
BP Cherry Point Refinery, Air Operating Permit #015 

Modification 1 – September 06, 2006

iv 

Table of Contents 

 Page

Permit Information ................................................................. i

Attest ..................................................................................... ii

Table of Contents ................................................................. iii

Emission Unit Identification .................................................. 1-1

Standard Terms and Conditions (General) ........................... 2-1

Standard Terms and Conditions (NSPS and NESHAP) ....... 3-1

Generally Applicable Requirements ..................................... 4-1

Specifically Applicable Requirements .................................. 5-1

Commonly Referenced Requirements 

(Opacity and LDAR) ............................................................. 6-1

Inapplicable Requirements ................................................... 7-1

Compliance Plans.................................................................. 8-1
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SECTION 1 - EMISSION UNIT IDENTIFICATION This section provides a list of the air pollution emission units and their physical characteristics for each handling area. The numbers in brackets correspond to the emission point ID number for the piece of e1.1 Crude and Vacuum Unit 1.11 Boilers and Cooling Towers 1.2 Naphtha HDS and Reformer Units 1.11.1 Cooling Towers 1.3 Hydrocracker 1.11.2 Boilers #1 and #3 1.4 Delayed Coker 1.11.3 Boiler #4 1.5 #1 Diesel HDS Unit 1.11.4 Boiler #5 1.6 #2 Diesel HDS Unit 1.12 Flares 1.7 Hydrogen Plant 1.13 Sulfur Recovery Unit 1.8 Calciner and Coke Loading 1.14 Wastewater Treatment  1.8.1 Calciner Hearths #1 & #2 1.15 Storage Tanks and Vessels  1.8.2 Calciner Hearth #3 1.16 Shipping, Pumping and Rece 1.8.3 Coke Handling Operations 1.16.1 Chemical Treater 

1.9 Light Ends Unit (LEU) and LPG 1.16.2 Truck Rack  1.9.1 Light End Unit (LEU) 1.16.3 Marine Terminal  1.9.2 LPG 1.16.4 LPG/LEU Loading 1.10 Isomerization Unit 1.17 Non-Hazardous Landfarm 
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1.1 CRUDE AND VACUUM UNIT 

Table 1.1 - Emission Unit Identification Crude and Vacuum Unit

Emission Unit ID 

Description 

[Emission Point] 

Constructed/

Modified Comments

Components in VOC/HAP Service (10) 40 CFR 60 Subpart GGG, 40 CFR 63 Subpart CC, O

 Process Drains 40 CFR 60 Subpart QQQ, 40 CFR Subpart 63 CC 

10 Crude Heater [10] 1970/1975 720 MMBtu/hr, OAC #159, RO #28 (Subpart J), OA10 North Vacuum Heater [11] 1985 77 MMBtu/hr, PSD 5, RO #28 (Subpart J),, OAC #210 South Vacuum Heater [12] 1970/2005 222 MMBtu/hr, RO #28 (Subpart J),, OAC #902a, U10 Non-condensable VOC, Hot wells with contact condensers NWCAA 580 

1.2 NAPHTHA HDS AND REFORMER UNITS 

Table 1.2 - Naphtha HDS and Reformer Units 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/

Modified Comments 

 Components in VOC/HAP Service 1996/2000 40 CFR 60 Subpart GGG, 40 CFR 63 Subpart CC  Process Drains 1996/2000 40 CFR 60 QQQ, 40 CFR 63 Subpart CC  Process Vents 40 CFR 63 Subpart CC 

11 Naphtha HDS Unit 1970 

 Naphtha HDS Charge Heater [22] 1970 110 MMBtu/hr, RO #28 (Subpart J)  Naphtha HDS Stripper Rebr. [23] 1970 86 MMBtu/hr, RO #28 (Subpart J), 

11 #1 Reformer 1970 OAC #562b, Offsets in NOx from PSD 7, 40 CFR 63 

 #1 Reformer Heater [20] 1970 1075 MMBtu/hr, RO #28 (Subpart J),  Components in HAP Service 2000 40 CFR 61 Subpart FF 

21 #2 Reformer 1987 OAC #305; 40 CFR 61 Subpart FF, 40 CFR 63 Sub21 #2 Reformer Heater [21] 1987 340 MMBtu/hr , OAC #305, PSD 7, RO #28 (Subpa
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1.3 HYDROCRACKER 

Table 1.3 - Hydrocracker 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/ 

Modified Comments 

15 R-1 Hydrocracker Reactor Heater [32] 1970 89 MMBtu/hr, RO #28 (Subpart J), 15 R-4 Hydrocracker Reactor Heater [33] 1970 79 MMBtu/hr, RO #28 (Subpart J), 15 1st Stage Fractionator Reboiler [30] 1970/1992 150 MMBtu/hr, OAC #149, OAC #351d – Low NOx 

(Subpart J), 

15 2nd Stage Fractionator Reboiler [31] 1970/1974/2003 183 MMBtu/hr, OAC #149, RO #28 (Subpart J),, OA

 Components in VOC/HAP Service 1970 LDAR – 40 CFR 63 Subpart CC  Process Drains 1970 40 CFR 60 Subpart QQQ 

1.4 DELAYED COKER 

Table 1.4 - Delayed Coker 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/ 

Modified Comments 

12 Coker Fractionator 1970 OAC #306, OAC #281 12 North Coker Charge Heater #1 [40] 1970 190 MMBtu/hr, OAC #689, RO #28 (Subpart J), 12 South Coker Charge Heater #2 [41] 1970 190 MMBtu/hr, OAC #689, Low NOx burner, RO #2

12-V-130 Process Vent 1970 40 CFR 63 Subpart CC 

12-1801 Coker Compressor 1970 40 CFR 63 Subpart VV 

 Components in VOC/HAP Service 1970 LDAR – 40 CFR 60 Subpart GGG, 40 CFR 63 Subp

CFR 63 Subpart CC 

 Process Drains 1970 40 CFR 60 Subpart QQQ 
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1.5 #1 DIESEL HDS UNIT 

Table 1.5 - #1 Diesel Hydrodesulfurization Unit 

Emission 

Unit ID 

Description 

[Emission Point]

Constructed/ 

Modified Comments 

13 #1 Diesel HDS Charge Heater [50] 1970 71 MMBtu/hr, RO #28 (Subpart J),, OAC #94913 #1 Diesel HDS Stabilizer Reboiler [51] 1970 53 MMBtu/hr, RO #28 (Subpart J),, OAC #949

 Components in HAP Service 1970 LDAR - OAC #281, 40 CFR 63 Subpart CC  Process Drains 1970 40 CFR 60 Subpart QQQ 

1.6 #2 Diesel HDS UNIT 

Table 1.6 - #2 Diesel Hydrodesulfurization Unit

Emission 

Unit ID 

Description 

[Emission Point]

Constructed/ 

Modified Comments 

26 #2 Diesel HDS Unit 2006 OAC #892 26 #2 Diesel HDS Heater [52] 2006 25 MMBtu/hr, OAC #892 

 Process Drains 2006 40 CFR 60 Subpart QQQ  Components in VOC Service 2006 OAC #892, LDAR – 40 CFR 60 Subpart GGG  Components in HAP Service 2006 OAC #892, HAP 40 CFR 63 Subpart CC 

1.7 HYDROGEN PLANT 

Table 1.7 - Hydrogen Plant 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/ 

Modified Comments 

14 North Reforming Furnace #1 [60] 1970 325 MMBtu/hr, RO #28 (Subpart J), 14 South Reforming Furnace #2 [61] 1970 325 MMBtu/hr, RO #28 (Subpart J), 

 Hydrogen Plant Vent 1970 

Exempt from MACT by the definition of a miscper 40 CFR 63.641(14). Majority of off-gas is routed to Praxair for CO2 
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1.8 CALCINER AND COKER HANDLING 

1.8.1. Calciner Hearths 1 & 2 

Table 1.8.1 - Calciner Hearths 1 & 2 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/ 

Modified Comments 

20 Calciner Hearth 1 & 2 (Calciner Stack #1) [70] 1978/1999 

38 tons calcined coke/hr per hearth, OAC #21#246, WESP installed in 1998 - OAC #660, Ca#689 - DEA Scrubber, 40 CFR 60 Subpart J (susing refinery fuel gas), HRSG produces #600 

 Components in VOC Service 1978 LDAR – 40 CFR 60 Subpart GGG, 40 CFR 63  Process Drains 1978 40 CFR 60 Subpart QQQ 

1.8.2. Calciner Hearth #3 

Table 1.8.2 - Calciner Hearths 3 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/ 

Modified Comments 

20 Calciner Hearth 3 (Calciner Stack #2) [71] 1985 76 tons calcined coke/hr, OAC #299, PSD -3 (

PSD 95-01 for WESP, RO #18, 40 CFR 60 Sufiring using refinery fuel gas), HRSG produces 

 Components in VOC Service 1985 LDAR – 40 CFR 60 Subpart GGG, 40 CFR 63  Process Drains 1985 40 CFR 60 Subpart QQQ 

1.8.3. Coke Handling Operations 

Table 1.8.3 - Coke Handling Operation 

Emission 

Unit ID Description Constructed/ Modified Comments 

20 Coke Handling Operation 1988/1990 NOC #293 Construct Silos. Emissions from b

SOx Controls 
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1.9 LIGHT ENDS UNIT (LEU) AND LPG 

1.9.1. Light Ends Unit (LEU) 

Table 1.9.1- Light Ends Unit 

Emission 

Unit ID Description Constructed/ Modified Comments 

16 Light Ends Unit 1970 OAC #298 

16-V-012 Process Vent 1970 40 CFR 63 Subpart CC 

 Process Drains 1970 40 CFR 60 Subpart QQQ  Components in VOC Service 1970 LDAR - OAC #298 

1.9.2. LPG 

Table 1.9.2 - LPG 

Emission 

Unit ID Description Constructed/ Modified Comments 

22 LPG 1987 OAC #293 – RVP 

22-1801 Compressor 1987 40 CFR 60 Subpart VV 

 Process Drains 1987 40 CFR 60 Subpart QQQ  Components in VOC Service 1987 LDAR – 40 CFR 60 Subpart GGG 

1.10 ISOMERIZATION UNIT

Table 1.10 - Isomerization Unit 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/ 

Modified Comments 

 Isomerization Unit 2004 OAC #814a 

Isomerization Process Heater[106] 2004 13 MMBtu/hr, OAC #814a, PSD-02-04, 40 CFR 

 Process Drains 2004 40 CFR 60 Subpart QQQ  Components in VOC Service 2004 OAC #814a, LDAR – 40 CFR 60 Subpart GGG  Components In HAP Service 2004 OAC #814a, HAP – 40 CFR 63 Subpart CC 
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1.11 BOILERS AND COOLING TOWERS 

1.11.1. Cooling Towers 

Table 1.11.1 - Cooling Towers 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/ 

Modified Comments 

30 Cooling Tower #1 1970 Stopped using Chromium in 1994 30 Cooling Tower #2 1990 Stopped using Chromium in 1994, OAC #289 

1.11.2. Boilers #1and #3 

Table 1.11.2 – Boilers - #1 and #3 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/ 

Modified Comments 

30 Boiler #1[101] 1970/1990 225 MMBtu/hr, OAC #298, RO #28 (Subpart J)30 Boiler #3 [103] 1970/1990 225 MMBtu/hr, OAC #298, RO #28 (Subpart J)

1.11.3. Boiler #4 

Table 1.11.3 - Boiler # 4 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/ 

Modified Comments 

30 Boiler #4 [104] 1991/1993/1994/1999 216 MMBtu/hr, OAC #351d, 40 CFR 60 Subpar

J), OAC #298, 

 Process Drains 40 CFR 60 Subpart QQQ  Components in VOC Service LDAR – 40 CFR 60 Subpart GGG 
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1.11.4 Boiler #5 

Table 1.11.4 - Boiler # 5 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/ 

Modified Comments 

Boiler #5 [105] 2004 363 MMBtu/hr, OAC #814a, PSD-02-04, 40 CF

CFR 60 Subpart Db 

Process Drains 2004 40 CFR 60 Subpart QQQ Components in VOC Service 2004 LDAR – 40 CFR 60 Subpart GGG 

1.12 FLARES 

Table 1.12 - Low and High Pressure Flare Systems 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/ 

Modified Comments 

29 Low Pressure Flare [111] 1970 40 CFR 63 Subpart A, NWCAA 462, 40 CFR 629 High Pressure Flare [110] 1970 40 CFR 63 Subpart A, NWCAA 462, 40 CFR 628 

Flare Gas Recovery System and Associated Piping (Components in VOC/HAP Service) 

 40 CFR 60 Subpart GGG and 40 CFR 63 Subp

28-1803, 

28-1804 Compressors 40 CFR 60 Subpart GGG 

29-V- 040, 

29-V-044 Process Vents 40 CFR 63 Subpart CC 
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1.13 SULFUR RECOVERY COMPLEX 

Table 1.13 - Sulfur Recovery Complex 

Emission 

Unit ID 

Description 

[Emission Point] 

Constructed/ 

Modified Comments 

17 and 19 Sulfur Recovery Complex 40 CFR 63 Subpart UUU 

17 Sulfur Recovery Unit 1970/1977 OAC #290, RO #28 (Subpart J), 

17-V-047, 17-V-067, 

17-V-074 

Process Vents 40 CFR 63 Subpart CC 

 Sulfur Pits & Sulfur Tanks 1970/2001 1984 RO #28, All sulfur pit emissions shall be treated

included as part of the Sulfur Recovery Plant’s 

 Sour Water Unit 1970/1977/2002 

The vent from the sour water stripper tank was 

recovery plant incinerator to a point upstream oplant as a SO2 reduction measure. 

19 Tail Gas Unit 1 [120] 1975/2006 

OAC #890a, 40 CFR 60 Subpart J (250 ppm Sand 162 H2S refinery fuel gas as supplimental fCFR 63 Subpart UUU 

 Tail Gas Unit 2 [121] 2006 OAC #890a, 40 CFR 60 Subpart J, 40 CFR 63 
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1.14 WASTEWATER TREATMENT 

Table 1.14 - Wastewater Treatment 

Emission 

Unit ID Description Constructed/ Modified Comments 

Sewer 

System 

Process Drains and Junction Boxes 40 CFR Subpart QQQ 

 Drain systems 40 CFR 63 Subpart CC 

Gauging and Sampling Devices 40 CFR 63 Subpart CC 

 Covers & Openings 40 CFR 63 Subpart CC 

Miscellaneous Sewer Lines and Covers 40 CFR 61 Subpart FF 

32 API Separators 1970/1991/1992 40 CFR 61 Subpart FF, OAC #348 32 API Effluent Sump-Floating Roof 40 CFR 61 Subpart FF and 40 CFR 60 Subpart 

 Closed Vent Systems 40 CFR 63 Subpart CC and 40 CFR Subpart FF 

Carbon Adsorption Control Devices 40 CFR 63 Subpart CC and 40 CFR Subpart FF 

 Containers 40 CFR 61 Subpart FF 

320,321, 322, 

323 Tanks 320, 321, 322, 323 40 CFR 61 Subpart CC, 40 CFR 61 Subpart FF

580 
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1.15 STORAGE TANKS AND VESSELS 

Table 1.15 - Tanks 

Tank 

# 

Emission 

Unit ID Tank Service MTVP Size Mbbls Roof Type # Seals Constructed Modified 

1 20.367.01 Petroleum Products >1.5 139.5 IFR 1 1970 Grou

2 21.367.01 Petroleum Products >1.5 139.8 IFR 1 1970 Grou

3 22.367.01 Petroleum Products >1.5 137.9 IFR 1 1970 Grou4 23.367.01 Petroleum Products >1.5 139.7 IFR 1 1970 Grou5 24.367.01 Petroleum Products >1.5 139.7 IFR 1 1970 Grou6 25.367.01 Petroleum Products >1.5 139.5 IFR 2 1970 Grou7 26.367.01 Petroleum Products >1.5 139.8 IFR 1 1970 Grou8 27.367.01 Petroleum Products >1.5 138.9 IFR 1 1970 Grou9 28.367.01 Petroleum Products >1.5 99.54 IFR 1 1970 Grou

10 29.367.01 Petroleum Products >1.5 142.8 IFR 1 1970 Grou11 31.367.01 Petroleum Products >1.5 142.7 IFR 1 1970 Grou12 32.367.01 Petroleum Products <1.5 142.8 IFR 1 1970 Grou13 41.367.01 Petroleum Products <1.5 137.4 IFR 1 1970 Grou14 33.367.01 Petroleum Products >1.5 142.3 IFR 1 1970 Grou15 34.367.01 Petroleum Products <1.5 141.7 IFR 1 1970 Grou16 35.367.01 Petroleum Products <1.5 142.4 IFR 1 1970 Grou17 36.367.01 Petroleum Products >1.5 140.0 IFR 2 1970 Grou18 37.367.01 Petroleum Products >1.5 194.4 IFR 2 1970 Grou19 38.367.01 Petroleum Products <1.5 140.3 IFR 1 1970 Grou20 39.367.01 Petroleum Products <1.5 139.5 IFR 1 1970 Grou21 40.367.01 Petroleum Products >1.5 201.0 IFR 1 1970 Grou22 188.367.01 Petroleum Products >1.5 138.8 IFR 1 1975 Group 

(Serv

23 47.367.01 Petroleum Products <1.5 201.0 IFR 1 1970 Grou24 211.367.01 Fin. Diesel or Gasoline <1.5 205.3 IFR - D 2 1994 Subp25 30.367.01 Petroleum Products >1.5 22.6 IFR 1 1970 Grou
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Table 1.15 - Tanks 

Tank 

# 

Emission 

Unit ID Tank Service MTVP Size Mbbls Roof Type # Seals Constructed Modified 

26 48.367.01 Petroleum Products >1.5 94.5 IFR 1 1970 Grou27 45.367.01 Petroleum Products >1.5 139.8 IFR 1 1970 Grou28 43.367.01 Coker Feed <1.5 144.2 C-NIFR 1970 Grou29 58.367.01 Petroleum Products <1.5 49.7 IFR 1 1970 Grou30 42.367.01 Coker Heavy Gas Oil <1.5 138.3 C-NIFR 1970 Grou31 44.367.01 Petroleum Products >1.5 139.4 IFR 1 1970 Grou32 46.367.01 Coker Feed <1.5 143.6 C-NIFR 1970 Grou33 49.367.01 Petroleum Products <1.5 102.9 IFR 1 1970 Grou34 50.367.01 Diesel <1.5 144.8 C-NIFR 1970 Grou37 187.367.01 Diesel <1.5 138.4 C-NIFR 1975 Grou38 51.367.01 Diesel <1.5 149.5 C-NIFR 1970 Grou40 Crude >1.5 364.3 IFR 2 2004 Grou41 52.367.01 Crude >1.5 241.4 IFR 1 1970 Grou42 53.367.01 Crude >1.5 247.7 IFR 1 1970 Grou43 54.367.01 Crude/Jet/Misc. >1.5 248.3 IFR 1 1970 Grou44 55.367.01 Crude >1.5 249.3 IFR 1 1970 Grou45 56.367.01 Crude/Diesel >1.5 245.4 IFR 1 1970 Grou46 57.367.01 Crude >1.5 248.8 IFR 1 1970 Grou47 185.367.01 Crude >1.5 260.8 IFR 1 1973 Grou

OAC 

48 186.367.01 Crude >1.5 260.2 IFR 1 1973 Grou

OAC 

49 277.367.01 Crude >1.5 389.6 IFR 1 1998 Grou50 190.367.01 Crude >1.5 485.7 IFR 1 1989 Subp60 20.367.02 Butane/Pentane Sphere 30.0 Sphere 1990 Pres61 1.367.02 Butane/Pentane Sphere 30.0 Sphere 1970 Pres62 21.367.02 Butane/Pentane Sphere 30.0 Sphere 1990 Pres
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Table 1.15 - Tanks 

Tank 

# 

Emission 

Unit ID Tank Service MTVP Size Mbbls Roof Type # Seals Constructed Modified 

63 2.367.02 Butane/Pentane Sphere 15.0 Sphere 1970 Pres64 3.367.02 Butane/Pentane Sphere 15.0 Sphere 1970 Pres65 4.367.02 Butane/Pentane Sphere 15.0 Sphere 1970 Pres70 102.367.01 Hydrocracker Recycle <1.5 102.6 C-NIFR 1970 Grou71 225.367.01 Petroleum Prod. - TR >1.5 30.8 IFR 2 1991 Subp72 272.367.01 Gasoline/Diesel – TR* >1.5 18.4 IFR 2 1995 Subp73 273.367.01 Gasoline/Diesel – TR* >1.5 9.7 IFR 2 1995 Subp74 274.367.01 Gasoline/Diesel – TR* >1.5 9.7 IFR 2 1995 Subp81 5.367.02 LPG 1.8 Bullet 1986 Pres82 6.367.02 LPG 1.8 Bullet 1986 Pres83 7.367.02 LPG 1.8 Bullet 1986 Pres84 8.367.02 LPG 1.8 Bullet 1986 Pres85 11.367.02 LPG 1.8 Bullet 1986 Pres86 12.367.02 LPG 1.8 Bullet 1986 Pres87 13.367.02 LPG 1.8 Bullet 1986 Pres88 14.367.02 LPG 1.8 Bullet 1986 Pres89 5.367.02 LPG 1.8 Bullet 1986 Pres

Components in VOC/HAP Service in Tank Farm and Off-Plot areas LDAR – 40 CFR 60 Subp

Process Drains 40 CFR 60 Subpart Q

Notes: IFR – Internal Floating Roof  IFR – D – Internal Floating Roof with Dome Cover  C-NIFR – Cylindrical Tank (Not Internal Floating Roof)  TR – Located at Truck Rack  * - Only two of these three tanks may be in gasoline service at one time 
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1.16 SHIPPING, PUMPING & RECEIVING 

1.16.1. Chemical Treaters 

Table 1.16.1 - Chemical Treater 

Emission 

Unit ID Description Constructed/ Modified Comments 

18 Process Drains & Junction Boxes 40 CFR 60 Part QQQ 

Components in VOC/ HAP Service LDAR – 40 CFR 63 Subpart CC 

1.16.2. Truck Rack 

Table 1.16.2 - Truck Rack 

Emission 

Unit ID Description Constructed/ Modified Comments 

Process Drains and Junction Boxes in VOC Service 40 CFR 60 Subpart QQQ 

 Components in VOC Service 40 CFR 60 Subpart GGG 

Process Drains in HAP Service 40 CFR 63 Subpart CC 

 Components in HAP Service 40 CFR 63 Subpart CC 

38 Truck Loading Rack 1994/1996/ 2001 

40 CFR 63 Subpart CC, OAC #527c, Associated Tan(Gasoline limit of 26,000 BBL/day; Jet and Diesel comBBL./day), NWCAA 580, 40 CFR 60 Subpart J (recovthermal oxidizer uses natural gas for supplemental firi

1.16.3. Marine Terminal 

Table 1.16.3 - Marine Terminal 

Emission 

Unit ID Description Constructed/ Modified Comments 

 Components in HAP Service 40 CFR 63 Subpart CC 

35 Marine Terminal including vapor combustor 2001 OAC#716a, 40 CFR 63 Subpart CC, 40 CFR 63 Subp

for supplemental firing of the vapor combustor 
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1.16.4. LPG/LEU Loading 

Table 1.16.4 - LPG/LEU Loading 

Emission 

Unit ID Description Constructed/ Modified Comments 

37 LPG Loading Rack 1970 

Components in VOC/HAP Service LDAR – 40 CFR 60 Subpart GGG 

1.17 NON-HAZARDOUS WASTE LANDFARM 

Table 1.17 - Emission Unit Identification Non-hazardous Waste Landfarm 

Emission 

Unit ID Description Constructed/ Modified Comments 

Landfarm for non-hazardous 

wastes 1992 OAC #382 
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SECTION 2 - STANDARD TERMS AND CONDITIONS 

Standard terms and conditions are administrative and/or other requirements that typically have no 

ongoing compliance monitoring requirements. The permittee must comply with the requirements 

listed below. All listed terms and conditions are federally enforceable unless identified as a “state 

only” requirement. A requirement designated “state only” is enforceable only by the state or the 

NWCAA, and not by EPA or through citizen suits. Unless the text of the term is specifically identified 

to be directly enforceable, the language of the cited regulation takes precedence over a paraphrased 

requirement. A permit condition labeled “Directly Enforceable” is a legal requirement, and the permit 

shield in condition 2.3.1 of this permit applies to those conditions. 

2.1 Compliance Requirements

2.1.1 Duty to Comply 

2.1.1.1 WAC 173-401-620(2)(a) (10/4/93) 

The permittee shall comply with all terms and conditions of this permit. Any permit 

noncompliance constitutes a violation of RCW 70.94 and, for federally enforceable 

provisions, a violation of the FCAA. Such violations are grounds for enforcement 

action; for permit termination, revocation and re-issuance, or modification; or for 

denial of a permit renewal application. 

2.1.1.2 NWCAA 322.3 (11/12/99) 

It shall be unlawful for any person to operate a source that is subject to the 

requirements of Chapter 173-401 WAC without complying with the provisions of 

Chapter 173-401 WAC and any permit issued under its authority. 

2.1.2 Civil and Criminal Penalties

2.1.2.1 WAC 173-400-230(2) (2/17/93), WAC 173-400-240 (2/19/91), NWCAA 

132 & 133 (10/13/94), and Section 113 of the FCAA

Civil and criminal penalties may be issued in accordance with the applicable 

regulations listed above. 

2.1.2.2 State Only: NWCAA 132 (3/13/97) and NWCAA 133 (7/14/05)

Civil and criminal penalties may be issued in accordance with the applicable 

regulations listed above. Under this “State Only” version of NWCAA 132, criminal 

penalties may be assessed on a “per day, per violation” basis. 

Any person who violates the provisions of the applicable chapters of the RCW or the 

Regulation of the Northwest Clean Air Agency or aids and abets in a violation shall 

be subject to civil penalties as stated in the above regulations. 

 
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2.1.3 Need to Halt or Reduce Activity Not a Defense 

WAC 173-401-620(2)(b) (10/4/93)

It shall not be a defense for a permittee in an enforcement action that it would have 

been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the terms and conditions of this permit. 

2.1.4 Duty to Provide Information 

WAC 173-401-620(2)(e) (10/4/93)

The permittee shall furnish to the NWCAA, within a reasonable time, any information 

that the NWCAA may request in writing to determine whether cause exists for 

modifying, revoking and reissuing, or terminating the permit or to determine 

compliance with the permit. Upon request, the permittee shall also furnish to the 

NWCAA copies of records required to be kept by the permit or, for information 

claimed to be confidential, the permittee may furnish such records directly to the EPA 

Administrator along with a claim of confidentiality. The NWCAA shall maintain 

confidentiality of such information in accordance with RCW 70.94.205 and the 

NWCAA Regulation. 

2.1.5 Confidential Information 

2.1.5.1 NWCAA 114.1 (4/14/93)

Whenever the permittee requests that records or information eligible for confidentiality 

status be made confidential, the NWCAA shall maintain confidentiality of such 

information in accordance with NWCAA 114. The records or information shall be only 

for the confidential use of the Board, the Advisory Council, and the NWCAA staff, but 

may not be accessed if, in the opinion of the Board, there is a conflict of interest. 

2.1.5.2 State Only: NWCAA 114.1 (3/13/97)

Whenever any records or other information other than ambient air quality data or 

emission data furnished to or obtained by the Agency, relates to processes or 

production unique to the owner or operator, or are likely to affect adversely the 

competitive position of such owner or operator if released to the public or to a 

competitor, and the owner or operator of such processes or production so certifies, 

such records or information shall be only for the confidential use of the NWCAA. 

Nothing herein shall be construed to prevent the use of records or information by the 

NWCAA in compiling or publishing analyses or summaries relating to the general 

condition of the outdoor atmosphere: PROVIDED, that such analyses or summaries 

do not reveal any information otherwise confidential under the provisions of this 

section: PROVIDED FURTHER, that emission data furnished to or obtained by the 

Board shall be correlated with applicable emission limitations and other control 

measures and shall be available for public inspection during normal business hours at 

offices of the Board. 
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2.1.6 Inspection and Entry 

WAC 173-400-105(3)(1/10/05), WAC 173-401-630(2) (10/4/93) NWCAA 110 & 111 

(1/8/69)

Upon presentation of credentials and other documents as may be required by law, 

the permittee shall allow Ecology, NWCAA or an authorized representative to perform 

the following: 

(i) enter upon the permittee's premises where a Chapter 401 source is located or 

emissions-related activity is conducted, or where records must be kept under 

the conditions of the permit; 

(ii) have access to and copy, at reasonable times, any records that must be kept 

under the condition of the permit; 

(iii) inspect at reasonable times any facilities, equipment (including monitoring and 

air pollution control equipment), practices, or operations regulated or required 

under the permit; and 

(iv) sample or monitor, at reasonable times, substances or parameters for the 

purpose of assuring compliance with the permit or applicable requirements. 

No person shall willfully interfere with or obstruct the Control Officer or any NWCAA 

employee and/or assigned agent in carrying out any lawful duty. 

2.1.7 Investigation and Studies 

NWCAA 110 (1/8/69)

The Control Officer and/or his qualified agents may make any reasonable 

investigation or study which is necessary for the purpose of standards or any 

amendments to reduce the amount or kind of contaminant. 

When investigating conditions specific to the control, recovery or release of air 

contaminants, the Control Officer or his duly authorized representatives shall have 

the power to enter at reasonable times upon any private or public property, except 

non-multiple unit private dwellings housing two families or less. 

If an authorized employee of the Agency, during the course of an inspection desires 

to obtain a sample of air contaminant, he shall notify the owner or lessee of the time 

and place of obtaining a sample so the owner or lessee has the opportunity to take a 

similar sample at the same time and place. A receipt shall be given to the owner or 

lessee for the sample obtained. 
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2.1.8 Source Testing 

2.1.8.1 WAC 173-400-105(4) (8/20/93)

To demonstrate compliance, Ecology or the NWCAA may conduct or require that a 

test be conducted of the source using approved EPA methods from 40 CFR Parts 51, 

60, 61 and 63 (in effect on February 20, 2001), or approved procedures contained in 

“Source Test Manual – Procedures for Compliance Testing,” State of Washington, 

Department of Ecology, as of July 12, 1990. The operator of a source may be 

required to provide the necessary platform and sampling ports for ecology personnel 

or others to perform a test of an emissions unit. Ecology shall be allowed to obtain a 

sample from any emissions unit. The operator of the source shall be given an 

opportunity to observe the sampling and to obtain a sample at the same time. 

2.1.8.2 State Only: WAC 173-400-105(4) (1/10/05)

To demonstrate compliance, the required test must be conducted using approved 

EPA methods from 40 CFR 60 Appendix A, adopted by reference. All other language 

is the same as 2.1.8.1. 

2.1.8.3 State Only: NWCAA 367 and Appendix A (7/14/05)

Source tests required by NWCAA (not RATAs) to assess compliance with an air 

emission standard shall be conducted according to the following provisions: 

(i) A source test plan shall be submitted to the NWCAA for approval for all 

compliance source tests at least 30 days prior to scheduled testing. A summary 

of the test shall accompany the test plan and be submitted on a template provided 

by NWCAA. 

(ii) Once a test plan has been approved, any changes in test dates or methodology 

shall require NWCAA approval. 

(iii) Results of required source tests must be submitted within sixty days of completion 

of the test unless prior approval is granted by NWCAA. 

2.1.9 Testing and Sampling 

2.1.9.1 NWCAA 360.1 (3/13/97) 

Any person operating or using any article, machine, equipment or other contrivance 

shall provide and maintain such sampling and testing facilities as specified in the 

approval to construct or an air operating permit. 

2.1.9.2 State Only: NWCAA 367 and Appendix A (7/14/05)

All ambient monitoring, compliance testing, continuous monitoring systems and 

continuous opacity monitoring systems required by a regulation, order of approval or 

permit issued by the NWCAA shall comply with the applicable requirement of this 

(subject) regulation. The applicable requirements of this Section and Appendix A are 

in addition to any monitoring testing, calibration or quality assurance/quality control 

requirements that otherwise apply. 
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Any person operating an air operating permit source may, at any time, be required to 

monitor the ambient air, process emissions or conduct emission tests as deemed 

necessary by the Control Officer: 

The Control Officer may take such samples and make any tests and investigations 

deemed necessary to determine the accuracy of the monitoring reports and tests 

submitted to the Agency, and evaluate the validity of the data. The owner or operator 

may also be required by the Control Officer to take a sample using an approved 

procedure and submit the results thereof within a reasonable period of time. 

Once initiated, a compliance test shall be completed unless interrupted by severe 

weather, test equipment failure or other conditions beyond control of the facility. 

Failure to complete a test shall be a violation of the requirement to test, and, in cases 

where the initial data indicate a non-compliance of the applicable emission standard, 

the results may be considered a violation of that standard. 

2.1.10 Ambient Air and Continuous Emission Monitoring 

2.1.10.1 NWCAA 365.1 (11/12/99)

Any person operating an air contaminant source or an air operating permit source 

may, at any time, be required to monitor the ambient air, process emissions or 

conduct emission tests as deemed necessary by the Control Officer under the 

following provisions: 

The Board or Control Officer may require any person operating any source to conduct 

a monitoring program on site or adjacent off site for emissions, ambient air 

concentrations or any other pertinent special studies deemed necessary. 

All monitoring data shall be submitted in a form which the Board or Control Officer 

may require. Averaging time and collection periods will be determined by the Control 

Officer. Failure to record and/or report data as specified in the “Guidelines for 

Industrial Monitoring Equipment and Data Handling” may be cause for a Notice of 

Violation to be issued. 

All data and records shall be kept for a period of at least one year and made available 

to the Control Officer upon request. 

All required continuous emission monitors or required opacity monitors used to 

monitor compliance must meet appropriate EPA performance specifications (40 CFR 

60, Appendix B) and shall be calibrated and maintained in accordance with the 

“Guidelines for Industrial Monitoring Equipment and Data Handling” procedures 

approved by the Control Officer. 

The Control Officer may take such samples and make any tests and investigations 

deemed necessary to determine the accuracy of the monitoring reports and tests 

submitted to the Authority, and evaluate the validity of the data. The owner or 

operator may also be required by the Control Officer to take a sample using an 

approved procedure and submit the results thereof within a reasonable period of time. 

The Board or the Control Officer may require additional reasonable monitoring be 

undertaken at any appropriate time to insure compliance with this regulation. 
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2.1.10.2 State Only: NWCAA 367 and Appendix A (7/14/05)

All ambient air monitors shall be operated and maintained as required by the 

appropriate Sections of 40 CFR Parts 50 and 58. 

A Quality Assurance (QA) manual and station log book shall be kept for all stations. 

Written calibration and precision/span check procedures shall be included in the QA 

manual. A station audit shall be conducted by NWCAA at least once per year. 

Unless subject to acid rain regulations (40 CFR Part 72 and 75), all continuous 

emissions monitoring (CEM) systems shall be capable of meeting appropriate EPA 

performance specifications using procedures outlined in 40 CFR Part 60 Appendix B. 

CEMs subject to acid rain regulations shall be capable of meeting the specifications 

outlined in the appropriate Section 40 CFR Part 75. 

All CEMs shall be operated in accordance with the appropriate section of 40 CFR 

Part 60 Appendix F, and the operator shall assess the operation of each CEM daily. 

Continuous opacity monitors shall be maintained according to “Recommended 

Quality Assurance Procedures for Opacity Continuous Monitoring Systems” (EPA 

340/1-86-10) and the manufacturer’s procedures. All gaseous CEMs shall be 

maintained using the QA criteria of 40 CFR Part 60 Appendix F and the 

manufacturer’s procedures. 

Auditing of opacity monitors shall be conducted according to recommended 

procedures. Data accuracy assessments shall be conducted at least once every 

calendar quarter for gaseous monitors and at appropriate periodic intervals. Relative 

Accuracy Tests (RATA’s), Relative Accuracy Audits (RAA’s) and Cylinder Gas Audits 

(CGA’s) shall be employed as described in 40 CFR Part 60. 

Strip charts and approved data acquisition systems shall be used to capture and 

store data. All data must be retained for a period of at least five years and be 

available to the NWCAA upon request. 

CEMs are required to maintain greater than 90% data availability on a monthly basis. 

A supplemental report shall be submitted if during any calendar month a CEM fails to 

produce 90% data availability stating the reasons for the low data availability. 

2.2 Permit Terms

2.2.1 Permit Expiration and Renewal 

WAC 173-401-610 (10/4/93) and WAC 173-401-710 (9/16/02)

This permit is issued for a fixed term of five years from date of issuance. Permit 

expiration terminates the source's right to operate unless a timely and complete 

renewal application has been submitted. A complete permit renewal application shall 

be submitted to the NWCAA no more than eighteen months and no later than six 

months prior to expiration. 
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2.2.2 Permit Actions 

WAC 173-401-620(2)(c) (10/4/93)

This permit may be modified, revoked, reopened, reissued, or terminated for cause. 

The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated 

noncompliance does not stay any permit condition. 

2.2.3 Emissions Trading 

WAC 173-401-620(2)(g) (10/4/93)

No permit revision shall be required, under any approved economic incentives, 

marketable permits, emissions trading, and other similar programs or processes, for 

changes that are provided for in this permit. 

2.2.4 Emission Reduction Credits 

State Only: WAC 173-400-136 (1/10/05)

An emission reduction credit may be used in accordance with the applicable 

regulation listed above. 

2.2.5 Severability 

WAC 173-401-620(2)(h) (10/4/93)

If any provision of this permit is held to be invalid, all unaffected provisions of the 

permit shall remain in effect and be enforceable. 

2.2.6 Permit Appeals 

WAC 173-401-620(2)(i) (10/4/93) and WAC 173-401-735 (4/2/97)

The permit or any conditions in it may be appealed only by filing an appeal with the 

pollution control hearings board and serving it on the NWCAA within thirty days of 

receipt. This provision for appeal is separate from and in addition to any federal 

rights to petition and review under §505(b) of the FCAA. 

2.2.7 Permit Continuation 

WAC 173-401-620(2)(j) (10/4/93)

This permit and all terms and conditions contained therein, including any permit 

shield provided under WAC 173-401-640, shall not expire until the renewal permit has 

been issued or denied if a timely and complete application has been submitted. If a 

timely and complete application has been submitted, an application shield granted 

pursuant to WAC 173-401-705(2) shall remain in effect until the renewal permit has 

been issued or denied. 
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2.2.8 Reopening for Cause 

WAC 173-401-730(10/4/93)

The permit shall be reopened and revised under any of the following circumstances: 

(i) Additional requirements become applicable to the source with a remaining permit 

term of three or more years. Such a reopening shall be completed not later than 

eighteen months after promulgation of the applicable requirement. No such 

reopening is required if the effective date of the requirement is later than the date 

on which the permit is due to expire, unless the original permit or any of its terms 

and conditions have been extended pursuant to WAC 173-401-620(2)(j); 

(ii) Additional requirements (including excess emissions requirements) become 

applicable to an affected source under the acid rain program. Upon approval by 

the EPA Administrator, excess emissions offset plans shall be deemed to be 

incorporated into the permit; 

(iii) The NWCAA or the EPA Administrator determines that the permit contains a 

material mistake or that inaccurate statements were made in establishing the 

emissions standards or other terms or conditions of the permit; or 

(iv) The NWCAA or the EPA Administrator determines that the permit must be revised 

or revoked to assure compliance with the applicable requirements. 

2.2.9 Changes Not Requiring Permit Revisions/Off-Permit Changes 

WAC 173-401-722 (9/16/02) and WAC 173-401-724 (10/4/93)

The permittee may make the changes described in WAC 173-401-722 and WAC 173-

401-724 without revising this permit, provided that the changes satisfy the criteria set 

forth in those sections. 

2.2.10 Permit Modifications 

WAC 173-401-720 (10/4/93) and WAC 173-401-725 (10/4/93)

This permit may be revised as provided in WAC 173-401-720 (administrative permit 

amendments) and 173-401-725 (permit modifications). 

2.2.11 Property Rights 

WAC 173-401-620(2)(d) (10/4/93)

This permit does not convey any property rights of any sort, or any exclusive 

privilege. 
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2.2.12 Definitions 

2.2.12.1 NWCAA Section 200 (11/13/93)

Particular references to terms not otherwise defined in this permit or the associated 

Statement of Basis have the meaning assigned to them in the specific regulation 

being cited. The terms NWCAA, Ecology, and EPA shall mean the Northwest Clean 

Air Agency, the Washington State Department of Ecology, and the United States 

Environmental Protection Agency, respectively. FCAA means the Federal Clean Air 

Act. 

2.2.12.2 State Only: NWCAA 200 (7/14/05)

In the new version of the NWCAA Regulation some of the definitions have been 

modified slightly to provide clarification and some have been revised to include an 

expanded definition of the term. 

2.2.13 Compliance Schedule 

WAC 173-401-630(3) (10/4/93) 

The permittee shall continue to comply with all applicable requirements with which the 

source was in compliance as of the date of permit issuance. The permittee shall 

meet on a timely basis any applicable requirements that become effective during the 

permit term. 

2.2.14 Permit Fees 

2.2.14.1. WAC 173-401-620(2)(f) (10/4/93)

The permittee shall pay fees as a condition of this permit in accordance with the 

NWCAA fee schedule. 

2.2.14.2 NWCAA 322.4 (11/12/98)

NWCAA shall assess and collect annual air operating permit fees for sources in its 

jurisdiction that are required to have Title V Air Operating Permits (excluding sources 

regulated by WDOE directly). The total fees required to administer the program shall 

be determined by a workload analysis conducted by NWCAA staff and approved 

annually by the NWCAA Board of Directors. 

2.3 Permit Shield

2.3.1 Shield Requirement 

WAC 173-401-640(1) (10/4/93)

Compliance with a permit condition shall be deemed compliance with the applicable 

requirements upon which that condition is based, as of date of permit issuance. The 

permit shield does not apply to any insignificant emissions unit or activity designated 

under WAC 173-401-530. 
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2.3.2 Inapplicable Requirements 

WAC 173-401-640(2) (10/4/93)

As of the date of permit issuance, the requirements listed in Section 7 of the permit do 

not apply to the permittee. The permit shield applies to all requirements so identified. 

2.3.3 Exclusions 

WAC 173-401-640(4) (10/4/93)

Nothing in this section or in this permit shall alter or affect the following: 

(i) the provisions of Section 303 of the FCAA (emergency orders), including the 

authority of the EPA Administrator under that section; 

(ii) the liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance; 

(iii) the ability of EPA to obtain information from a source pursuant to Section 114 of 

the FCAA; or 

(iv) the ability of the permitting authority to establish or revise requirements for the 

use of reasonably available control technology as provided in RCW 70.94.154. 

2.3.4 Reasonably Available Control Technology 

2.3.4.1 WAC 173-401-605(3) (10/4/93)

Emission standards and other requirements contained in rules or regulatory orders in 

effect at the time of operating permit issuance shall be considered RACT for 

purposes of permit issuance or renewal. 

2.3.4.2 WAC 173-400-040 (8/20/93)

All emissions units are required to use reasonably available control technology 

(RACT) which may be determined for some sources or source categories to be more 

stringent than the applicable emission limitations of any chapter of Title 173 WAC. 

Where current controls are determined to be less than RACT, Ecology or the NWCAA 

shall, as provided in Section 8, Chapter 252, Laws of 1993, define RACT for each 

source or source category and issue a rule or regulatory order requiring the 

installation of RACT. 

2.3.4.3 State Only: WAC 173-400-040 (1/10/05)

All emissions units are required to use reasonably available control technology 

(RACT) which may be determined for some sources or source categories to be more 

stringent than the applicable emission limitations of any chapter of Title 173 WAC. 

Where current controls are determined to be less stringent than RACT, Ecology or the 

NWCAA shall, as provided in RCW 70.194.154, define RACT for each source or 

source category and issue a rule or regulatory order requiring the installation of 

RACT. 
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2.3.5 Emergencies 

WAC 173-401-645 (10/4/93)

An emergency, as defined in WAC 173-401-645(1), constitutes an affirmative defense 

to an action brought for noncompliance with a technology-based emission limitation if 

conditions of WAC 173-401-645 (3) and (4) are met. This provision is in addition to 

the affirmative defense for unavoidable excess emissions found in any applicable 

requirement. 

The permittee shall submit a notice of emergency to the Agency within two working 

days of the time when the emission limitation was exceeded due to an emergency or 

shorter periods of time specified in an applicable requirement. 

2.4 Recordkeeping and Reporting

2.4.1 Compliance Certification 

2.4.1.1 WAC 173-401-630(5) (10/4/93)

The Permittee shall submit ongoing certifications of compliance with permit terms and 

conditions. The first such certification shall cover the period from the last compliance 

certification until issuance of this revised permit. The following compliance 

certification shall cover the period from permit issuance to December 31, 2005. 

Subsequent compliance certifications shall be made on a yearly basis. Each 

certification shall include: 

(i) The identification of each term and condition of the permit that is the basis of the 

certification; 

(ii) The compliance status; 

(iii) Whether the compliance was continuous or intermittent; 

(iv) The methods used for determining the compliance status of the source, currently 

and over the reporting period. These methods must be consistent with the permit 

Monitoring, Recordkeeping, and Reporting requirements. 

All compliance certifications shall be submitted to EPA Regions 10 and the Northwest 

Clean Air Agency at the following addresses, by February 28 for the previous 

calendar year: 

Environmental Protection Agency Northwest Clean Air Agency 

Mail Stop OAQ-107 Attn: Air Operating Permits 

Attn: Air Operating Permits 1600 South Second Street 

1200 Sixth Avenue Mount Vernon, WA 98273-5202 

Seattle, WA 98101 

2.4.1.2 WAC 173-401-520 (10/4/93)

Any application form or compliance certification that is submitted pursuant to this 

permit shall contain certification by a responsible official of truth, accuracy, and 

completeness. This certification and any other certification required under this permit 

shall state that, based on information and belief formed after reasonable inquiry, the 

statements and information in the document are true, accurate, and complete. 
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2.4.1.3 WAC 173-401-615 (9/16/02) and 630 (10/4/93) 

Directly Enforceable Text 

All required monitoring reports must be certified by a responsible official consistent 

with WAC 173-401-520. All semiannual monitoring certifications are due as follows: 

• January 31 for reports from July through December 

• July 31 for reports from January through June 

2.4.1.4 WAC 173-401-530(2)(d) (9/16/02) 

Where a permit does not require testing, monitoring, recordkeeping and reporting for 

insignificant emissions units or activities, the permittee may certify continuous 

compliance if there were no observed, documented, or known instances of 

noncompliance during the reporting period. Where a permit requires testing, 

monitoring, recordkeeping and reporting for insignificant emission units or activities, 

the permittee may certify continuous compliance when the testing, monitoring and 

recordkeeping required by the permit revealed no violations during the period, and 

there were no observed, documented or known instances of noncompliance during 

the reporting period. 

2.4.2 False and Misleading Oral Statement: Unlawful Reproduction or Alteration of 

Documents 

2.4.2.1 NWCAA 112 (2/14/73) 

No person shall willfully make a false or misleading oral statement to the Board as to 

any matter within the jurisdiction of the Board. 

No person shall reproduce or alter or cause to be reproduced or altered any order or 

other paper issued by the Agency if the purpose of such reproduction or alteration is 

to evade or violate any provision or regulation of this Agency, or any other law. 

2.4.2.2 State Only: NWCAA 112 (11/12/99)

No person shall willfully make a false or misleading oral statement to the NWCAA 

Board, Control Officer, or their duly authorized representatives as to any matter within 

the jurisdiction of the Board. 

No person shall reproduce or alter or cause to be reproduced or altered any order or 

other paper issued by the Agency if the purpose of such reproduction or alteration is 

to evade or violate any provision or regulation of this Agency, or any other law. 

2.4.3 Required Recordkeeping 

2.4.3.1 WAC 173-401-615(2)(9/16/02)

Records of required monitoring information shall include, where applicable, the 

following: 

(i) The date, time, and location of sampling or measurements; 

(ii) The operating conditions existing at the time of sampling or measurement; 
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(iii) If analyses were performed, the date, company or entity performing the analyses, 

the analytical techniques or methods used, and the results of such analyses; 

A record shall be kept describing changes made that result in emissions of a 

regulated air pollutant subject to an applicable requirement, but not otherwise 

regulated under the permit, and the emissions resulting from those changes. 

Records of all required monitoring data and support information will be retained for a 

period of five years from the date of the monitoring sample, measurement, report, or 

application. Support information includes all calibration and maintenance records and 

all original strip-chart recordings for continuous monitoring instrumentation, and 

copies of all reports required by this permit. 

2.4.3.2 WAC 173-401-615 (9/16/02) and 630 (10/4/93) 

 Directly Enforceable Text 

Monitoring and associated recordkeeping is not required when an emission unit is not 

operating and there are no emissions to the atmosphere. The facility must record the 

time periods that the unit is shut down and not monitored, and include the time 

periods and a summary of why the emission unit was shut down in the periodic report 

of monitoring required by WAC 173-401-615(3)(a). 

 

2.4.4 Pollutant Disclosure - Reporting by Air Contaminant Sources 

2.4.4.1 NWCAA 150 (9/8/93) and WAC 173-400-105(1) (8/15/01)

The permittee shall file annually at a time determined by the NWCAA and on forms 

furnished by the NWCAA a report setting forth: 

(i) the nature of the enterprise; 

(ii) a list of process materials which are potentially significant sources of emissions 

used in, and incidental to, its manufacturing processes, including any by-products 

and waste products; 

(iii) the estimated annual total production of wastes discharged into the air in units 

and contaminants designated by the NWCAA. 

Annual emission reports shall be submitted to the NWCAA within 105 days after the 

end of the previous calendar year. If the emission report is not submitted by the 

required date and the emissions are used to determine operating permit fees as 

described in NWCAA Regulation 324.126 then potential to emit will be used to 

determine said fees. 

The permittee shall maintain records of information necessary to substantiate any 

reported emissions, consistent with the averaging times for the applicable standards. 

2.4.4.2 State Only: WAC 173-400-105(1)(1/10/05)

The difference between this latest version of WAC 173-400-105(1) and the (8/15/01) 

version is the requirement to include oxides of nitrogen, PM2.5, and ammonia to the 

list of emissions that must be reported. In addition, the new version states that 

emission estimates may be based on the most recent published EPA emission factors 

or other information available to the source, whichever is the better estimate. 
 BP Cherry Point Refinery, AOP #015 

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2.4.4.3 State Only: NWCAA 150 (11/12/99)

The difference between the 11/12/99 version of NWCAA 150 and the 9/8/93 version 

consists in the citation of operating permit fees in NWCAA 322.4, rather than NWCAA 

324.126. 

 

2.4.5 Reporting to Verify Emissions from Potential PSD Sources 

 WAC 173-400-720(4)(b)(iii) (1/10/05)(State Only) 

 

The owner of operator shall monitor the emissions of any regulated pollutants from 

all projects for which PSD applicability was determined according to the provisions 

40 CFR 52.21(b)(41)(ii)(a) through (c), and calculate and maintain a record of annual 

emissions on a calendar year basis. 

The owner or operator shall submit a report to NWCAA within 60 days after the end of 

the year in which the emissions occurred. The report shall include the emissions in 

tons per year for the project, the baseline actual emissions and the pre-construction 

projected emissions. 

2.4.6 Reporting of Deviations from Permit Conditions 

WAC 173-401-615(3)(b) (9/16/02) Directly Enforceable Text

Prompt Reporting of Deviations: The permittee shall promptly report all deviations 

from permit requirements, including those attributable to upset conditions as defined 

in this permit. The report shall include a description of the probable cause of such 

deviations, if known, and any corrective actions or preventive measures taken. 

Prompt means reporting according to the shortest time period listed below which 

applies to the situation: 

(i) In the case where the deviation represents a potential threat to human health or 

safety “prompt” means as soon as possible, but in no case later than twelve hours 

after the deviation is discovered. A follow up report on the deviation shall be 

included in the next monthly report. 

(ii) For all other deviations, the deviation shall be reported as part of the next routine 

monitoring report, but no later than 30 days after the end of the month during 

which the deviation is discovered, whichever is sooner. 

2.4.7 Report of Breakdown and Upset 

2.4.7.1 NWCAA 340.1, 340.2 and 340.3 (10/13/94)

If a breakdown or upset condition occurs which results in or may have resulted in an 

emission and/or ambient air quality standard being exceeded, the owner or operator 

of the source shall take the following actions: 

(i) The upset or breakdown shall be reported as promptly as possible and in no 

event later than 12 hours to the NWCAA. 

(ii) The person responsible shall, upon the request of the Control Officer, submit a full 

report within 10 days including the known causes, corrective measures taken, and 

preventive measures to be taken to minimize or eliminate a recurrence. 
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Compliance with the requirements of this section does not relieve the owner or 

operator of the source from the responsibility to maintain continuous compliance with 

all the requirements of this regulation nor from the resulting liabilities for failure to 

comply. 

It shall be prima facie evidence of violation of this regulation if any control equipment 

is turned off, broken down or otherwise inoperative, and a notice of breakdown has 

not been filed, under 340.1, or any other equipment creates new or increased 

emissions to the atmosphere as the result of being turned off, broken down or 

otherwise inoperative, and a notice of breakdown has not been filed under Section 

340.1. 

2.4.7.2 State Only: NWCAA 340.1, 340.2, and 340.3 (7/14/05)

If a breakdown or upset condition occurs which results in or may have resulted in an 

emission and/or ambient air quality standard being exceeded, the owner or operator 

of the source shall take the following actions: 

(i) The upset or breakdown shall be reported as promptly as possible and in no 

event later than 12 hours to the NWCAA. 

(ii) The responsible official or his designee shall, submit a full report on forms 

provided by NWCAA within 30 days after the end of a calendar month in which 

the upset occurred and must include as a minimum the known causes, corrective 

action taken, preventive measures put in place to reduce the possibility of or 

eliminate a recurrence and an estimate of the quantity of emissions above the 

applicable limit caused by the event. 

In addition to the reporting requirements of the 10/13/94 version of NWCAA Section 

340, the permittee must also report to the NWCAA if the emission release to the air 

requires agency notification as specified in 40 CFR 302 (CERCLA) or 40 CFR 355 

(SARA). 

It shall be prima facie evidence of violation of this regulation if any other equipment 

creates new or increased emissions to the atmosphere as the result of being turned 

off, broken down or otherwise inoperative, and a notice of breakdown has not been 

filed under NWCAA Section 340.1. 

2.4.8 Report of Shutdown or Startup 

2.4.8.1 NWCAA 341.1, 341.2, 341.3 (9/8/93)

If the permittee schedules a total or partial shutdown or startup of control or process 

equipment which may result in emissions or any additional emissions to the 

atmosphere which may temporarily exceed the emission standards of this regulation; 

the permittee shall notify the NWCAA prior to the shutdown or startup. 

Prompt notification shall be made and in no event less than 24 hours before the 

scheduled shutdown or startup. The permittee shall submit a general schedule of 

steps to be taken to minimize the release of air contaminants to the atmosphere 

including the reasons for and duration of the proposed shutdown or startup, the 

nature of the action to be taken, the date and time for the action and an estimate of 

the anticipated rate and concentration of emission. 
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Compliance with the requirements of this section does not relieve the owner or 

operator of the source from the responsibility to maintain continuous compliance with 

the requirements of this regulation nor from the resulting liabilities for failure to 

comply. 

2.4.8.2 State Only: NWCAA 341.1. 341.2, 341.3 and 341.5 (7/14/05)

If the permittee schedules a total or partial shutdown or startup of control or process 

equipment that the source reasonably believes would result in emissions which may 

temporarily exceed an emissions standard of this regulation, the permittee shall notify 

the NWCAA in advance of the shutdown or startup. 

The advance notification shall include a general schedule of steps to be taken to 

minimize the release of air contaminants to the atmosphere including the reason for 

and the duration of the proposed shutdown or startup, the nature of the action to be 

taken, the date and time for the action and an estimate of the anticipated rate and 

concentration of the emission. 

2.4.9 Operation and Maintenance 

2.4.9.1 NWCAA 342.3 (9/8/93)

If a breakdown or violation occurs and is due to the improper operation or 

maintenance of equipment, the owner or operator of the source will, in addition to 

filing a report of breakdown under NWCAA Regulation 340, submit a report on what 

measures will be taken in training or re-orienting personnel to prevent a recurrence of 

the breakdown 

2.4.9.2 State Only:NWCAA 342.1 and 2 (7/14/05)

All air contaminant stationary sources are required to keep any process and/or air 

pollution control equipment in good operating condition and repair. Operating 

instructions and maintenance schedules for this equipment must be available on the 

site. 

2.4.10 Excess Emissions 

2.4.10.1 WAC 173-400-107 1, 2, 3, 4, 5, and 6 (8/20/93)

The permittee shall have the burden of proving to Ecology or the NWCAA or the 

decision-making authority in an enforcement action that excess emissions were 

unavoidable. Excess emissions determined to be unavoidable under the procedures 

and criteria of this section shall be excused and not subject to penalty. 

Excess emissions which represent a potential threat to human health or safety or 

which the owner or operator of the source believes to be unavoidable shall be 

reported to ecology or the NWCAA as soon as possible. Other excess emissions 

shall be reported within thirty days after the end of the month during which the event 

occurred or as part of the routine emission monitoring reports. Upon request by 

Ecology or the NWCAA, the permittee shall submit a full written report including the 

known causes, the corrective actions taken, and the preventive measures to be taken 

to minimize or eliminate the chance of recurrence. 
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Excess emissions due to startup or shutdown shall be considered unavoidable 

provided the source reports as required and adequately demonstrates that the excess 

emissions could not have been prevented through careful planning and design and if 

a bypass of control equipment occurs, that such bypass is necessary to prevent loss 

of life, personal injury, or severe property damage. 

Excess emissions due to scheduled maintenance shall be considered unavoidable 

provided the source reports as required and adequately demonstrates that the excess 

emissions could not have been prevented through reasonable design, better 

scheduling for maintenance or through better operation and maintenance practices. 

Excess emissions due to upsets shall be considered unavoidable provided the source 

reports as required and adequately demonstrates that: 

(i) The event was not caused by poor or inadequate design, operation, 

maintenance, or any other reasonably preventable condition; 

(ii) The event was not of a recurring pattern indicative of inadequate design, 

operation, or maintenance; and 

(iii) The permittee took immediate and appropriate corrective action in a manner 

consistent with good air pollution control practice for minimizing emissions during 

the event, taking into account the total emissions impact of the corrective action, 

including slowing or shutting down the emission unit as necessary to minimize 

emissions, when the operator knew or should have known that an emission 

standard or permit condition was being exceeded. 

2.4.10.2 State Only: NWCAA 340.4 (7/14/05), and 341.4 (7/14/05) 

Excess emissions due to breakdowns and upsets shall be considered unavoidable, 

and not subject to penalty, provided the source adequately demonstrates that: 

(i) The event was not caused by poor or inadequate design, operation, maintenance, 

or any other reasonably preventable condition. 

(ii) The event was not of a recurring pattern indicative of inadequate design, 

operation, or maintenance; and 

(iii) The permittee took immediate and appropriate corrective action in a manner 

consistent with good air pollution control practice. 

(iv) The emissions did not result in a violation of an ambient air quality standard. 

Excess emissions due to shutdown or startup shall be considered unavoidable, and 

not subject to penalty, provided the source adequately demonstrates that the excess 

emissions could not have been prevented through careful planning and design, the 

emissions did not result in a violation of an ambient air quality standard and if a 

bypass of control equipment occurs, that such bypass is necessary to prevent loss of 

life, personal injury, or severe property damage. 

The Responsible Official or his designee shall submit a full report on forms provided 

by NWCAA no later than 30 days after the end of the month in which the startup, 

shutdown, breakdown or upset occurred that resulted in the exceedance of an 

ambient or emission standard and must include at a minimum the known causes, 

corrective action taken, preventative measures put in place to reduce the possibility of 

or eliminate a recurrence an estimate of the quantity of emissions above the 

applicable limit caused by the event. 
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2.4.11 Duty to Supplement or Correct Information 

WAC 173-401-500(6) (9/16/02)

Upon becoming aware that the source has failed to submit any relevant facts in a 

permit application or that information submitted in a permit application is incorrect, the 

source shall promptly submit such supplementary facts or corrected information. 

2.5 Prohibitions

2.5.1 Concealment and Masking 

2.5.1.1 WAC 173-400-040(7) (1/10/05)

No person shall cause or permit the installation or use of any means, which conceals 

or masks an emission of an air contaminant, which would otherwise violate the 

provisions of this chapter. 

2.5.1.2 State Only: NWCAA 540 (1/8/69)

It shall be unlawful for any person to willfully cause or permit the installation or use of 

any device or use of any means which, without resulting in a reduction in the total 

amount of air contaminant emitted, conceals an emission of air contaminant which 

would otherwise violate the emission standards of this regulation. 

It shall be unlawful for any person to cause or permit the installation or use of any 

device or use of any means designed to mask the emission of an air contaminant, 

which causes detriment to health, safety, or welfare of any person. 

2.5.2. Adjustment for Atmospheric Conditions 

WAC 173-400-205 (2/19/91)

The permittee shall not vary the rate of emission of a pollutant according to 

atmospheric conditions or ambient concentrations of that pollutant except as directed 

according to air pollution episode regulations. 

2.5.3 Outdoor Burning 

2.5.3.1 WAC 173-425-036 (9/17/90) and WAC 173-425-045 (1/3/89), WAC 

173-435-050(2) (01/3/89) Although SIP-Approved, WAC 173-425-036 

and –045 have been repealed. 

No person shall conduct outdoor burning during an air pollution episode or a declared 

period of impaired air quality. Except as provided in WAC 173-425-055, the following 

materials shall not be burned in any open fire: (1) garbage, (2) dead animals, (3) 

asphaltic products, (4) waste petroleum products, (5) paints, (6) rubber products, (7) 

plastics, (8) treated wood, and (9) any substance, other than natural vegetation, 

which normally emits dense smoke or obnoxious odors. 
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2.5.3.2 State Only: WAC 173-425-040, 050, and 060(3/13/00), NWCAA 502 

(7/14/05)

No person shall conduct outdoor burning except in accordance with the applicable 

regulations listed above. Outdoor burning shall be conducted under a valid fire permit 

and shall not contain prohibited materials, unless specifically exempted. Emissions 

from burning shall not create a nuisance and/or interfere with visibility on any public 

road. 

 

2.5.4 Asbestos 

2.5.4.1 State Only: NWCAA 570 (7/14/05)

The permittee shall conduct all renovation or demolition projects in accordance with 

the applicable asbestos control standards listed in NWCAA Section 570. 

2.5.4.2 40 CFR 61.145(1/16/91), 61.148(11/20/90) and 61.150(1/16/91)

The permittee shall comply with Title 40 CFR Sections 61.145, 61.148 and 61.150 

when conducting any renovation or demolition at the facility. 

2.5.5 Stratospheric Ozone and Climate Protection 

2.5.5.1 40 CFR 82 Subpart F (As amended through 8/20/2001)

The permittee shall comply with the standards for recycling and emissions reduction 

in accordance with the requirements listed in 40 CFR 82 Subpart F. 

2.5.5.2 State Only: RCW 70.94.970 (1991 c 199 §602)

A person who services or repairs or disposes of a motor vehicle air conditioning 

system; commercial or industrial air conditioning, heating, or refrigeration system; or 

consumer appliance shall use refrigerant extraction equipment to recover regulated 

refrigerant that would otherwise be released into the atmosphere. This subsection 

does not apply to off-road commercial equipment. 

The willful release of regulated refrigerant from a source listed in this section is 

prohibited. 

2.5.6 Display of Orders, Certificates and Other Notices: Removal or Mutilation 

 Prohibited 

NWCAA 124 (2/14/73) 

Any order or other certificate obtained from the NWCAA shall be available at the 

facility. If the NWCAA requires a notice to be displayed, it shall be posted. No one 

shall mutilate, obstruct or remove any notice unless authorized to do so by the 

NWCAA. 
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2.5.7 Obstruction of Access 

State Only: RCW 70.94.200, (1987 c 109 §38)

The permittee shall not obstruct, hamper or interfere with any authorized 

representative of the NWCAA who requests entry for the purposes of inspection and 

who presents appropriate credential; nor shall any person obstruct, hamper, or 

interfere with any such inspection. 

2.5.8 Notice of Construction and Application for Approval/New Source Review 

2.5.8.1. WAC 173-400-110 (8/20/93), NWCAA 300, 301, 302 & 324.2 (10/13/94), 

and NWCAA 303 (8/9/78)

No person shall construct, install, establish, modify or alter an air contaminant source 

or an emission unit without filing a “notice of construction and Application for 

Approval” and receiving approval for the Agency in accordance with the cited 

regulations. 

2.5.8.2 State Only: WAC 173-400-560 (1/10/05) and NWCAA 300.14 (7/14/05)

An owner or operator may apply for an applicable general order for approval to 

construct certain specified sources as defined in this part. A general order of 

approval shall identify criteria by which an emission unit or source may qualify for 

coverage under a general order of approval and shall include terms and conditions for 

installing and/or operating the source. 

2.5.8.3 State Only: NWCAA 300.15 (7/14/05) 

It shall be unlawful for an owner or operator of a source or emission unit to not abide 

by the operating and reporting conditions in the Order of Approval. 

2.5.8.4 State Only: WAC 173-400-710, 720, 730, 740 and 750 (1/10/05), WAC 

173-460-040(1/14/94),WAC 273-400-141 (8/15/01) NWCAA 300.1-

300.13, 301 (7/14/05), 303 (11/12/98), and 324.2 (7/14/05)

A Notice of Construction or PSD permit application must be filed by the owner or 

operator and an Order of Approval or PSD permit issued by the Agency prior to the 

establishment of any new source in accordance with the cited regulations. For 

purposes of this section “establishment” shall mean to “begin actual construction” as 

that term is defined in NWCAA Section 200, and “new source” shall include any 

“modification” to an existing “stationary source” as those terms are defined in NWCAA 

Section 200. 

No major stationary source or major modification as defined in the cited regulation 

shall begin actual construction without having received a PSD permit. Allowable 

emissions from the new source of major modification shall not cause or contribute to 

a violation of any ambient air quality standard. 

An applicant for a PSD permit must submit an application that provides complete 

information for Department of Ecology to determine compliance with all PSD program 

requirements. The procedures for submitting a complete application, for public review 

and involvement, and for revisions to an existing PSD permit are provided in detail in 

the cited regulations (WAC 173-400-710 through 750). 
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2.5.9 Replacement or Substantial Alteration of Control Technology at an Existing 

Source 

State Only: WAC 173-400-114 (8/15/01), NWCAA 300.13 (7/14/05)

Any person proposing to replace or substantially alter emission control technology 

installed on an existing stationary source or emission unit shall file a notice of 

construction application with the NWCAA. 

2.5.10 Controls for New Sources of Toxic Air Pollutants 

State Only WAC 173-460-030(1)

The owner or operator of a new toxic air pollutant source shall notify the NWCAA prior 

to the construction, installation, or establishment of the source and shall file a notice 

of construction application for the proposed emission unit(s) as per WAC 173-460-

040, -050, -080, -110, -150, and -160 (1/14/94) and WAC 173-460-070 and -140 

(6/18/91). 

2.5.11 Creditable Stack Height and Dispersion Techniques 

State Only: WAC 173-400-200 (1/10/05)

For stacks for which construction or reconstruction commenced, or for which major 

modifications were carried out, after December 31, 1970, no source may use 

dispersion techniques or excess stack height to meet ambient air quality standards or 

PSD increment limitations. 

2.5.12 False Statement, Representation or Certification 

State Only: WAC 173-400-105(7) (1/10/05)

No person shall make any false material statement, representation or certification in 

any form, notice or report required under Chapter 70.4 or 70.120 RCW, or any 

ordinance, resolution, regulation, permit, or order in force pursuant thereto. 

2.5.13 Inaccurate Monitoring 

State Only: WAC 173-400-105(8) (1/10/05)

No person shall render inaccurate any monitoring device or method required under 

Chapter 70.94 or 70.120 RCW, or any ordinance, resolution, regulation, permit, or 

order in force pursuant thereto. 
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2.5.14 Prevention of Accidental Release 

40 CFR 68 Subpart F (As amended through 8/20/2001)

The permittee shall not produce, process, handle or store any substance listed in 40 

CFR 68.130 or any other extremely hazardous substance unless they identify 

hazards that might result from accidental releases using appropriate hazard 

assessment techniques, design and maintain a safe facility taking such steps as are 

necessary to prevent releases, and minimize the consequences of accidental 

releases that do occur. 

2.5.15 Cutback Asphalt Paving 

NWCAA 580.7 (4/14/93)

The application of cutback asphalt in paving during the months of June, July, August 

and September is limited to use as prime coatings and patch mixes, or when the 

temperature is less than 50 degrees F. 
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SECTION 3 - STANDARD TERMS AND CONDITIONS FOR NEW SOURCE 

PERFORMANCE STANDARDS AND NATIONAL EMISSION STANDARDS 

FOR HAZARDOUS AIR POLLUTANT REQUIREMENTS 

Standard terms and conditions are administrative and/or other requirements that typically 

have no ongoing compliance monitoring requirements. The permittee must comply with the 

requirements listed below for specific “affected facilities” as defined in the New Source 

Performance Standards (NSPS) in 40 CFR Part 60.2 and “affected sources” defined in the 

National Emission Standards for Hazardous Air Pollutants (NESHAP) in 40 CFR Part 63.2. 

The affected facilities and affected sources subject to these requirements are identified in 

Section 5 of the permit. The conditions in this section do not apply generally to all emission 

units at the facility. 

3.1 Part 60 - New Source Performance Standard Requirements 

3.1.1 Address for Reports, Notifications and Submittals 

Title 40 CFR 60.4(a) and (b) (4/25/75) (as amended by Delegation Letter of 2/5/03

from Betty Wiese, EPA Region X to James Randles, Control Officer of NWCAA)

Notifications, reports, and applications for delegated NSPS shall be sent to the 

NWCAA at the following address: 

 Northwest Clean Air Agency 

 1600 S. Second Street 

 Mount Vernon, WA 98273-5202 

Authority to approve major changes in emission units, test methods and monitoring 

methods prescribed by Part 60 has not been delegated to NWCAA. Prior to filing an 

application under any NSPS regulation that authorizes EPA to approve alternate 

emission limits, test methods, or monitoring methods, the permittee shall consult with 

NWCAA to determine whether the application falls within the scope of NWCAA’s 

delegated authority. 

Applications under NSPS authorities that have been excluded from delegation shall 

be submitted to the NWCAA at the above address and to the EPA at the following 

address: 

Director 

Air and Waste Management Division 

U.S. Environmental Protection Agency 

1200 Sixth Avenue 

Seattle, WA 98101 
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3.1.2 Compliance with Opacity Standards 

Title 40 CFR 60.11(b) and (c) (10/17/00)

Compliance with opacity standards in Part 60 shall be determined by EPA Method 9 

in appendix A. For purposes of determining initial compliance, the minimum total time 

of observations shall be 3 hours (30 6-minute averages) for the performance test. 

The opacity standards set forth in this part shall apply at all times except during 

periods of startup, shutdown, malfunction, and as otherwise provided in the 

applicable standard. 

3.1.3 Operation and Maintenance 

Title 40 CFR 60.11(d) (10/17/00)

At all times, including periods of startup, shutdown, and malfunction, owners and 

operators shall, to the extent practicable, maintain and operate any affected facility, 

including associated air pollution control equipment, in a manner consistent with good 

air pollution control practices for minimizing emissions. 

3.1.4 Credible Evidence 

Title 40 CFR 60.11(g) (10/17/00)

For the purpose of submitting compliance certifications or establishing whether or not 

a person has violated or is in violation of any standard in this part, nothing in this part 

shall preclude the use, including the exclusive use, of any credible evidence or 

information, relevant to whether a source would have been in compliance with 

applicable requirements if the appropriate performance or compliance test or 

procedure had been performed. 

3.1.5 Circumvention 

Title 40 CFR 60.12 (3/8/74)

No owner or operator subject to the provisions of this part shall build, erect, install, or 

use any article, machine, equipment or process, the use of which conceals an 

emission which would otherwise constitute a violation of an applicable standard. 

Such concealment includes, but is not limited to, the use of gaseous diluents to 

achieve compliance with an opacity standard or a standard which is based on the 

concentration of a pollutant in the gases discharged to the atmosphere. 

3.1.6 Notification 

Title 40 CFR 60.7(a) (2/12/99) (as amended by Delegation Letter of 2/5/03 from Betty 

Weise, EPA Region X to James Randles, Control Officer of NWCAA

Furnish written notification to NWCAA of the following: 
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(i) The date construction (or reconstruction as defined by 60.15) of an affected 

facility commenced postmarked no later than 30 days after such date. 

(ii) Notification of the actual date of initial startup of an affected facility postmarked 

within 15 days after such date. 

(iii) Notification of any physical or operational change to an existing facility which may 

increase the emission rate of any air pollutant to which a standard applies, unless 

that change is specifically exempted under an applicable subpart or in 60.14(e). 

This notice shall be postmarked 60 days or as soon as practicable before the 

change is commenced and shall include information describing the precise nature 

of the change, present and proposed emission control systems, productive 

capacity of the facility before and after the change, and the expected completion 

date of the change. 

(iv) Notification of the date upon which demonstration of the continuous monitoring 

system performance commences in accordance with 60.13(c). Notification shall 

be postmarked not less than 30 days prior to such date. 

(v) Notification of the anticipated date for conducting the opacity observations 

required by 60.11(e)(1) of this part. The notification shall be postmarked not less 

than 30 days prior to such date. 

(vi) Notification that continuous opacity monitoring system data results will be used to 

determine compliance with the applicable opacity standard during a performance 

test required by 60.8 in lieu of Method 9 observation data as allowed by 

60.11(e)(5) of this part. This notification shall be postmarked not less than 30 

days prior to the date of the performance test. 

3.1.7 Startup, Shutdown, and Malfunction Records 

Title 40 CFR 60.7(b) (2/12/99)

Maintain records of the occurrence and duration of any startup, shutdown, or 

malfunction in the operation of an affected facility; any malfunction of the air pollution 

control equipment; or any periods during which a continuous monitoring system or 

monitoring device is inoperative. 

3.1.8 Excess Emission Records 

Title 40 CFR 60.7(c) and (d) (2/12/99) (as amended by Delegation Letter of 2/5/03 

from Betty Wiese, EPA Region X to James Randles, Control Officer of NWCAA)

Each owner or operator required to install a continuous monitoring device shall 

submit excess emissions (as defined in applicable subparts) and monitoring systems 

performance and/or summary report form to the NWCAA semiannually, except when: 

more frequent reporting is specifically required in any subpart; or the NWCAA 

determines that more frequent reporting is necessary. Written reports of excess 

emissions shall include the information in 60.7(c)(1) through (4). All semiannual 

monitoring certifications are due as follows: 
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• January 31 for reports from July through December 

• July 31 for reports from January through June 

3.1.9 Maintenance of Records 

Title 40 CFR 60.7(f) (2/12/99)

Maintain a file of all measurements, including continuous monitoring system, 

monitoring device, and performance testing measurements; all continuous monitoring 

system performance evaluations; all continuous monitoring system or monitoring 

device calibration checks; adjustments and maintenance performed on these systems 

or devices; and all other information required by this part recorded in a permanent 

form be retained for at least two years following the date of such measurements, 

maintenance, reports, and records, except as described in 60.7(f)(1) through (3). 

Note: Under WAC 173-401-615(2), records of required monitoring data and support 

information will be retained for a period of five years from the date of the monitoring 

sample, measurement, report, or application. 

3.2 Part 63 National Emission Standard for Hazardous Air Pollutant 

Requirements

3.2.1 Address for Reports, Notifications and Submittals 

Title 40 CFR 63.9(a)(5/30/03) and 63.10(a) (4/22/04) (as amended Federal Register 

delegation notice dated 3/14/02) (pp. 11417-11424).

Notifications, reports, and applications for delegated Part 63 NESHAPS shall be sent 

to the NWCAA at the following address: 

 Northwest Clean Air Agency 

 1600 S. Second Street 

 Mount Vernon, WA 98273-5202 

All NESHAPS Subparts referenced in this permit have been delegated to NWCAA. 

Authority to approve major changes in emission units, test methods and monitoring 

methods prescribed by Part 60 has not been delegated to NWCAA. Prior to filing an 

application under any NESHAPS regulation that authorizes EPA to approve alternate 

emission limits, test methods, or monitoring methods, the permittee shall consult with 

NWCAA to determine whether the application falls within the scope of NWCAA’s 

delegated authority. 

Applications under NESHAPS authorities that have been excluded from delegation 

shall be submitted to the NWCAA at the above address and to the EPA at the 

following address: 

 Director 

 Air and Waste Management Division 

 U.S. Environmental Protection Agency 
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 1200 Sixth Avenue

 Seattle WA 98101 
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3.2.2 Requirements for Existing, Newly Constructed, and Reconstructed Part 

63 NESHAPS Sources 

40 CFR Part 63.5(b)(1), (3), (4), (6) (4/5/02)

A new affected source for which construction commences after proposal of a relevant 

standard is subject to relevant standards for new affected sources, including 

compliance dates. An affected source for which reconstruction commences after 

proposal of a relevant standard is subject to relevant standards for new sources, 

including compliance dates, irrespective of any change in emissions of hazardous air 

pollutants from that source. 

After the effective date of any relevant standard promulgated by the EPA under Part 

63, no person may, without obtaining written approval in advance from the NWCAA in 

accordance with the procedures in paragraphs (d) and (e) of this Part 63.5, do any of 

the following: 

(i) Construct a new affected source that is major-emitting and subject to such 

standard; 

(ii) Reconstruct an affected source that is major-emitting and subject to such 

standard; or 

(iii) Reconstruct a major source such that the source becomes an affected source that 

is major-emitting and subject to the standard. 

After the effective date of any relevant standard promulgated by the EPA under this 

part, an owner or operator who constructs a new affected source that is not majoremitting or reconstructs an affected source that is not major-emitting that is subject to 

such standard, or reconstructs a source such that the source becomes an affected 

source subject to the standard, must notify the Administrator of the intended 

construction or reconstruction. The notification must be submitted in accordance with 

the precedures in 63.9(b). 

After the effective date of any relevant standard promulgated by the Administrator 

under this part, equipment added (or a process change) to an affected source that is 

within the scope of the definition of affected source under the relevant standard must 

be considered part of the affected source and subject to all provisions of the relevant 

standard established for that affected source. 

3.2.3 Notification Requirements for New or Reconstructed Affected Sources for 

Which an Application for Approval of Construction or Reconstruction is 

Required 

 Title 40 CFR Part 63.9(b)(4) (5/30/03)

 The owner or operator of a new or reconstructed major affected source for 

which an application for approval of construction or reconstruction is required under 

63.5(d) must provide the following information in writing to the NWCAA: 

A notification of intention to construct a new major-emitting affected source, 
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reconstruct a major-emitting affected source, or reconstruct a major source such that 

the source becomes a major-emitting affected source with the application for approval 

of construction or reconstruction as specified in 63.5(d)(1)(i); and 

A notification of the actual date of startup of the source delivered or postmarked 

within 15 calendar days after that date. 

3.2.4 Notification Requirements for Affected Sources with Initial Startup 

 Prior to a Standard’s Effective Date

 Title 40 CFR Part 63.9(b)(2) and (j) (5/30/03)

 The owner or operator of an affected source that has an initial startup before the 

effective date of a relevant standard under this part shall notify the NWCAA in writing 

that the source is subject to the relevant standard. The notification, which shall be 

submitted not later than 120 calendar days after the effective date of the relevant 

standard (or within 120 calendar days becomes subject to the relevant standard) shall 

provide the following information: 

(i) The name and address of the owner or operator; 

(ii) The address (i.e., physical location) of the affected source; 

(iii) An identification of the relevant standard, or other requirement that is the 

basis of notification and the source’s compliance date; 

(iv) A brief description of the nature, size, design, and method of operation of the 

source and an identification of the types of emission points within the affected 

source subject to the relevant standard and the types of hazardous air 

pollutants emitted; and 

(v) A statement of whether the affected source is a major source or an area 

source. 

Any change in the information provided under this section shall be provided to the 

Administrator in writing within 15 calendar days after the change. 

3.2.5 Startup, Shutdown, and Malfunction Record Retention

Title 40 CFR 63.6(e)(3)(iii), 63.10(b)(2) and (d)(5) (4/20/06)

The owner or operator of the source shall maintain relevant records of the occurrence 

and duration of each startup, shutdown, or malfunction of operation (i.e., process 

equipment), the occurrence and duration of each malfunction of the required air 

pollution control and monitoring equipment, all required maintenance performed on 

the air pollution control and monitoring equipment, actions taken during periods of 

startup, shutdown, and malfunction (including corrective actions to restore 

malfunctioning process and air pollution control and monitoring equipment to its 

normal or usual manner of operation) when such actions are different from the 

procedures specified in the affected source’s startup, shutdown and malfunction plan 

(SSMP). All information necessary to demonstrate conformance with the SSMP 

when all actions taken during periods of startup, shutdown, malfunction (including 

corrective actions to restore malfunctioning process and air pollution control and 

monitoring equipment to its normal or usual manner of operation) are consistent with 

the procedures specified in the plan. (The information needed to demonstrate 
BP Cherry Point Refinery, Air Operating Permit #015 

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conformance with the startup, shutdown, and malfunction plan may be recorded using 

a “checklist,” or some other effective form of recordkeeping, in order to minimize the 

recordkeeping burden for conforming events), each period during which a continuous 

monitoring system (CMS) is malfunctioning or inoperative (including out-of-control 

periods). 

 

If actions taken by an owner or operator during a startup, shutdown, or malfunction of 

an affected source (including actions taken to correct a malfunction) are consistent 

with the procedures specified in the source’s startup, shutdown, and malfunction plan 

(SSMP), the owner or operator shall state such information in a SSMP report. 

Reports and recordkeeping are only required when a startup or shutdown causes an 

applicable emissions standard to be exceeded or for any malfunction that results in a 

potential exceedance of a standard. Such recordkeeping and reporting must include 

all information on actions taken to minimize emissions during the startup, shutdown or 

malfunction event. The report shall consist of a letter, containing the name, title, and 

signature of the owner or operator or other responsible official who is certifying its 

accuracy, that shall be submitted to the NWCAA semiannually (or on a more frequent 

basis if specified otherwise in a relevant standard or as established otherwise by the 

permitting authority in the source’s title V permit). The report shall be delivered or 

postmarked by the 30th day following the end of each calendar half (or other calendar 

reporting period, as appropriate). If the owner or operator is required to submit 

excess emissions and continuous monitoring system performance (or other periodic) 

reports under this part, the startup, shutdown, and malfunction reports required under 

this paragraph may be submitted simultaneously with the other reports. 

Any time an action taken by an owner or operator during a startup, shutdown, or 

malfunction (including actions taken to correct a malfunction) is not consistent with 

the procedures specified in the affected source’s SSMP, the owner or operator shall 

report the actions taken for that event within 2 working days after commencing 

actions inconsistent with the plan followed by a letter within 7 working days after the 

end of the event. The immediate report required under this paragraph shall consist of 

a telephone call (or a facsimile transmission) to the NWCAA within 2 working days 

after commencing actions inconsistent with the plan, and it shall be followed by a 

letter, delivered or postmarked within 7 working days after the end of the event, that 

contains the name, title, and signature of the owner or operator or other responsible 

official who is certifying its accuracy, explaining the circumstances of the event, the 

reasons for not following the SSMP, and whether any excess emission and/or 

parameter monitoring exceedances are believed to have occurred. 

3.2.6 Prohibited Activities and Circumvention 

Title 40 CFR 63.4(4/5/02) 

No owner or operator subject to the provisions of this part must operate any affected 

source in violation of the requirements of this part. Affected sources subject to and in 

compliance with either an extension of compliance or an exemption from compliance 

is not in violation of the requirements of this part. An extension of compliance can be 

granted by the Administrator under this part; by a State with an approved permit 

program; or by the President under section 112(i)(4) of the Act. 

No owner or operator subject to the provisions of this part shall fail to keep records, 
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notify, report, or revise reports as required under this part. 

No owner or operator subject to the provisions of this part shall build, erect, install, or 

use any article, machine, equipment, or process to conceal an emission that would 

otherwise constitute noncompliance with a relevant standard. Such concealment 

includes, but is not limited to: 

(i) The use of diluents to achieve compliance with a relevant standard based on the 

concentration of a pollutant in the effluent discharged to the atmosphere; 

(ii) The use of gaseous diluents to achieve compliance with a relevant standard for 

visible emissions. 

Fragmentation after November 15, 1990 which divides ownership of an operation, 

within the same facility among various owners where there is no real change in 

control, will not affect applicability. The owner and operator must not use 

fragmentation or phasing of reconstruction activities (i.e., intentionally dividing 

reconstruction into multiple parts for purposes of avoiding new source requirements) 

to avoid becoming subject to new source requirements. 

3.2.7 Operation and Maintenance 

40 CFR Part 63.6(e)(1)(i), and (e)(1)(ii) (4/20/06)

At all times, including periods of startup, shutdown, and malfunction, the owner or 

operator must operate and maintain any affected source, including associated air 

pollution control and monitoring equipment, in a manner consistent with safety and 

good air pollution control practices for minimizing emissions. During a period of 

startup, shutdown, or malfunction, this general duty to minimize emissions requires 

that the owner or operator reduce emissions from the affected source to the greatest 

extent which is consistent with safety and good air pollution control practices. The 

general duty to minimize emissions during a period of startup, shutdown, or 

malfunction does not require the owner or operator to achieve emission levels that 

would be required by the applicable standard at other times if this is not consistent 

with safety and good air pollution control practices, nor does it require the owner or 

operator to make any further efforts to reduce emissions if levels required by the 

applicable standard have been achieved. Determination of whether such operation 

and maintenance procedures are being used will be based on information available to 

the Administrator which may include, but is not limited to, monitoring results, review of 

operation and maintenance procedures (including the SSMP), review of operation 

and maintenance records, and inspection of the source. 

Malfunctions must be corrected as soon as practicable after their occurrence in 

accordance with the startup, shutdown, and malfunction plan. To the extent that an 

unexpected event arises during a startup, shutdown, or malfunction, an owner or 

operator must comply by minimizing emissions during such an event consistent with 

safety and good air pollution control practices. 

3.2.8 Startup, Shutdown, and Malfunction Plan 

40 CFR Part 63.6(e)(3) (4/20/06)
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The owner or operator of an affected source must develop and implement a written 

startup, shutdown, and malfunction plan (SSMP) that describes, in detail, procedures 

for operating and maintaining the source during periods of startup, shutdown, and 

malfunction; a program of corrective action for malfunctioning process; and air 

pollution control and monitoring equipment used to comply with the relevant standard. 

This plan shall be developed by the source’s compliance date for the relevant 

standard. 

During periods of startup, shutdown, and malfunction, the owner or operator of an 

affected source must operate and maintain such source (including associated air 

pollution control and monitoring equipment) in accordance with the procedures 

specified in the SSMP. However, the source may deviate from the plan when 

necessary for safety considerations or unanticipated operational events. 

When actions taken by an owner or operator during a startup, shutdown, or 

malfunction (including actions taken to correct a malfunction) are consistent with the 

procedures specified in the affected source’s SSMP, the owner or operator must keep 

records for that event which demonstrate that the procedures specified in the plan 

were followed. These records may take the form of a “checklist” or other effective 

form of recordkeeping that confirms conformance with the SSMP for that event. In 

addition, the owner or operator must keep records of these events as specified in 

63.10(b). Furthermore, the owner or operator shall confirm that actions taken were 

consistent with the SSMP in the semi-annual (or more frequent) startup, shutdown 

and malfunction report required in 63.10(d)(5). 

If an action taken by the owner or operator during a startup, shutdown, or malfunction 

(including an action taken to correct a malfunction) is not consistent with the 

procedures specified in the affected source’s SSMP, and the source exceeds the 

relevant emission standard, then the owner or operator must record the actions taken 

for that event and must report such actions within 2 working days after commencing 

actions inconsistent with the plan, followed by a letter within 7 working days after the 

end of the event, in accordance with 63.10(d)(5) (unless the owner or operator makes 

alternative reporting arrangements, in advance, with the Administrator). 

The owner or operator must maintain at the affected source a current SSMP and 

must make the plan available upon request for inspection and copying by the 

NWCAA. In addition, if the SSMP is subsequently revised, the owner or operator 

must maintain at the affected source each previous (i.e., superceded) version of the 

SSMP, and must make each such previous version available for inspection and 

copying by the NWCAA for a period of 5 years after revision of the plan. If at any time 

after adoption of a SSMP the affected source ceases operation or is otherwise no 

longer subject to the provisions of this part, the owner or operator must retain a copy 

of the most recent plan for 5 years from the date the source ceases operation or is 

otherwise no longer subject to the provisions of this part, the owner or operator must 

retain a copy of the most recent plan for 5 years from the date the source ceases 

operation or is no longer suject to this part and must make the plan available upon 

request for inspection and copying by the NWCAA. 

To satisfy the requirements of this section to develop a SSMP, the owner or operator 

may use the affected source’s standard operating procedures (SOP) manual, or an 

Occupational Safety and Health Adminstrations (OSHA) or other plan, provided the 

alternative plans meet all the requirements of this section and are made available for 
BP Cherry Point Refinery, Air Operating Permit #015 

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inspection when requested by the NWCAA. 

Based on the results of a determination made under paragraph 63.6(e)(2) of this 40 

CFR 63 Subpart, the Administrator may require that an owner or opreator of an 

affected source make changes to the SSMP for that source. The NWCAA may 

require reasonable revisions to a SSMP if the NWCAA finds that the plan: 

(i) Does not address a startup, shutdown, or malfunction event that has occurred; 

(ii) Fails to provide for the operation of the source (including associated air pollution 

control and monitoring equipment) during a startup, shutdown, or malfunction 

event in a manner consistent with safety and good air pollution control practices 

for minimizing emissions to the levels required by the relevant standard; 

(iii) Does not provide adequate procedures for correcting malfunctioning process 

and/or air pollution control and monitoring equipment as quickly as practicable; or 

(iv) Includes an event that does not meet the definition of startup, shutdown, or 

malfunction listed in §63.2. 

If the SSMP fails to address or inadequately addresses an event that meets the 

characteristics of a malfunction but was not included in the SSMP, the plan shall be 

revised within 45 days after the event to include detailed procedures for operating 

and maintaining the source during similar malfunction events and a program of 

corrective action for similar malfunctions of process or air pollution control and 

monitoring equipment. 

3.2.9 Compliance With Nonopacity Emission Standards 

40 CFR Part 63.6(f) (5/30/03)

The nonopacity emission standards set forth in this part shall apply at all times except 

during periods of startup, shutdown, and malfunction, and as otherwise specified in 

an applicable subpart. If a startup, shutdown, or malfucntion of one portion of an 

affected source does not affect the ablity of particular emission points within other 

portions of the affected source to comply with the non-opacity emission standards set 

forth in this part, then that emission point must still be required to comply with the 

non-opacity emission standards and other applicable requirements. 

3.2.10 Compliance With Opacity and Visible Emission Standards 

40 CFR Part 63.6(h) (5/30/03)

The opacity and visible emission standards set forth in this part must apply at all 

times except during periods of startup, shutdown, and malfunction, and as otherwise 

specified in an applicable subpart. If a startup, shutdown, or malfunction of one 

portion of an afected source does not affect the ability of particular emission points 

whithin other portions of the affected source to comply with the opacity and visible 

emission standards set forth in this part, then that emission point shall still be required 

to comply with the opacity and visible emission standards and other applicable 

requirements. 

The owner or operator shall make available, upon request by the NWCAA, such 

records that the NWCAA deems necessary to determine the conditions under which 
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the visual observations were made and shall provide evidence indicating proof of 

current visible observer emission certification. 
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3.2.11 Extension of Compliance for Early Reductions and Other Reductions 

40 CFR Part 63.6(i)(5/30/03) and 63.9(c) (5/30/03)

Until an extension of compliance has been granted by the NWCAA under this 

paragraph, the owner or operator of an affected source subject to the requirements of 

this section shall comply with this part’s applicable requirements. A compliance 

extension may be possible if it meets 63.6(i)(4) through 63.6(i)(6). 

 3.2.12 Conduct of Performance Tests 

40 CFR Part 63.7(e) (4/5/02)

Performance tests shall be conducted under such conditions as the NWCAA specifies 

to the owner or operator based on representative performance (i.e. performance 

based on normal operating conditions) of the affected source. Operations during 

periods of startup, shutdown, and malfunction shall not constitute representative 

conditions for the purpose of a performance test, nor shall emissions in excess of the 

level of the relevant standard during periods of startup, shutdown, and malfunction be 

considered a violation of the relevant standard unless otherwise specified in the 

relevant standard or a determination of noncompliance is made under 63.6(e). Upon 

request, the owner or operator shall make available to the NWCAA such records as 

may be necessary to determine the conditions of the performance tests. 

3.2.13 Maintenance of Records 

40 CFR Part 63.10(b)(1) (4/22/04)

 

The owner or operator of an affected source subject to the provisions of this part shall 

maintain files of all information (including all reports and notifications) required by this 

part recorded in a form suitable and readily available for expeditious inspection and 

review. The files shall be retained for at least 5 years following the date of each 

occurrence, measurement, maintenance, corrective action, report, or record. At a 

minimum, the most recent 2 years of data shall be retained on site. The remaining 3 

years of data may be retained off site. Such files may be maintained on microfilm, on 

a computer, on computer floppy disks, on magnetic tape disks, or on microfiche. 
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SECTION 4 - GENERALLY APPLICABLE REQUIREMENTS The cited requirements in the “Citation” column and incorporated herein by reference are applicable plantwide at thinsignificant emission units. These requirements are federally enforceable unless identified as “state only”. A requonly” is enforceable only by the state or the NWCAA, and not by the EPA or through citizen suits. The “Descriptiondescription of the applicable requirements for informational purposes only and is not enforceable. Periodic or cont

requirements (including testing) are specified in the “Monitoring, Recordkeeping and Reporting” column, which idenrecordkeeping and reporting (MR&R) obligations the source must perform as required by WAC 173-401-605(1) and 

underlying requirement. MR&R obligations do not apply to insignificant emission units. The requirements in the MR&R column labeled “directly enforceable” are legally enforceable requirements added u

filling” authority. Other requirements not labeled “directly enforceable” are brief descriptions of the regulatory requipurposes, and are not enforceable. Unless the text of the MR&R column is specifically identified to be directly enfo

cited regulation takes precedence over a paraphrased requirement. 

The provisions of federally approved NWCAA Section 365, Section 366 and the “Guidelines for Industrial Monitorin

Handling” have been replaced in this section by NWCAA Section 367 and Appendix A - "Ambient Monitoring, EmisEmission and Opacity Monitoring". NWCAA Section 367 and Appendix A were adopted on July 14, 2005 with a prthe date of adoption would be allowed to achieve compliance with Appendix A. The new regulations are “State OnState Implementation Plan. Section 367 and Appendix A are not materially different from the previous rule and gui

updated to include current monitoring technology and methods. 
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Table 4 - Generally Applicable Requirements 

BP Cherry Point Refinery

Permit 

Term Citation Description Monitoring, Recordkeeping a

4.1 

General 

NWCAA 342.1 (7/14/05) Same as 4/14/93 SIP Version 

Operation and Maintenance

Sources are required to keep any process and/or air pollution control equipment in good operating condition and repair. 

4.2 

General 

NWCAA 342.2 (7/14/05) Same as 4/14/93 SIP Version 

Operating Instructions/Maintenance 

Schedules

Make operating instructions and maintenance schedules available to operators. 

Monitor, keep records and report in accordance w
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Table 4 - Generally Applicable Requirements 

BP Cherry Point Refinery

Permit 

Term Citation Description Monitoring, Recordkeeping a

4.3 

Opacity 

NWCAA 451.1 (5/11/95) and WAC 173-400-040(1) (8/20/93) Same as State Only 1/10/05 

Emission of Air Contaminant - Visual 

Standard

Opacity shall not exceed 20% for any period aggregating more than 3 minutes in any one hour. Excess emissions as a result of soot blowing or grate cleaning shall not occur for more than 15 minutes in any 8 hour period, or another approved schedule. 

For combustion units burning oil, visually observe 

qualitatively assess whether emissions are visiblereduced to weekly if no visible emissions are obse

The permittee shall revert to daily observations of emissions are noted during the observation. For combustion units burning gaseous fuels, visuaqualitatively assess whether emissions are visiblereduced to quarterly if no visible emissions are obsmonths. The permittee shall revert to monthly obsany visible emissions are noted during the observaIf visible emissions are observed, reduce to no vispossible. If visible emissions cannot be reduced to monitor by Ecology Method 9A no later than 24 hothereafter until opacity is shown to be less than 20shall be considered in excess of the opacity standRecord observation results for stacks with visible eequipment or operational failure, the occurrence d

and the type of fuel burned. Record that an obsertime, background conditions, and identification of t

all observations available for inspection. Combustion units with specifically applicable permand particulate matter shall be monitored in accordrequirements only. Follow State of Washington Department of Ecolog

Visual Determination of Opacity for a three Minute 1990) - directly enforceable 
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Table 4 - Generally Applicable Requirements 

BP Cherry Point Refinery

Permit 

Term Citation Description Monitoring, Recordkeeping a

4.4 

PM 

NWCAA 455.1 (5/11/95) 

Emission of Particulate Matter

Emissions shall not exceed 0.10 grain/dscf (corrected to 7% oxygen), 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% oxygen. For catalytic cracking units, emissions shall not exceed 0.20 grains/dscf (corrected to 7% oxygen). 

4.5 

PM 

WAC 173-400-060 (8/20/93) Same as State Only 1/10/05 

Emission Standards for General Process 

Units

Particulate emissions greater than 0.1 grain/dscf prohibited. 

4.6 

PM 

WAC 173-400-050(1) (8/20/93) Same as State Only 1/10/05 

Emission Standards for Combustion and 

Incineration Units

Particulate emissions from combustion units greater than 0.1 grains/dscf prohibited. 

For combustion units burning oil, visually observe qualitatively assess whether emissions are visiblereduced to weekly if no visible emissions are obseThe permittee shall revert to daily observations of emissions are noted during the observation. For combustion units burning gaseous fuels, visuaqualitatively assess whether emissions are visiblereduced to quarterly if no visible emissions are obsmonths. The permittee shall revert to monthly obsany visible emissions are noted during the observaIf visible emissions are observed, reduce to no vispossible. If visible emissions cannot be reduced to monitor by Ecology Method 9A no later than 24 hothereafter until opacity is shown to be less than 20shall be considered in excess of the opacity standRecord observation results for stacks with visible eequipment or operational failure, the occurrence dand the type of fuel burned. Record that an obsertime, background conditions, and identification of tall observations available for inspection. Combustion units with specifically applicable permand particulate matter shall be monitored in accordrequirements only. Follow 40 CFR 60 Appendix A Method 5 - directly enforceable - 
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Table 4 - Generally Applicable Requirements 

BP Cherry Point Refinery

Permit 

Term Citation Description Monitoring, Recordkeeping a

4.7 

SOx

NWCAA 410 (4/14/93) 

Sulfur Oxide Standards

Unlawful for any person to cause or permit sulfur oxides to be emitted into the ambient air, calculated as sulfur dioxide, measured at an ambient air monitoring station to exceed: • 0.800 ppmv for any 5 minute average, not to be exceeded more than once per year • 0.400 ppmv for any hour average, not to be exceeded more than once per year • 0.250 ppmv for any one hour average, not to be exceeded more than twice in any 7 consecutive days • 0.100 ppmv for any one day (24 hours), not to be exceeded more than once per year. • 0.020 ppmv for any one year (annual arithmetic mean). 

Monitor ambient air continuously and report to with NWCAA 367 and Appendix A - “Ambient Mand Continuous Emission and Opacity Monitor- directly enforceable – 

4.8 

SO2 

NWCAA 460 (7/14/05) State Only 

Weight/Heat Rate Standard – Emission of 

Sulfur Compounds

Sulfur compound emissions, as sulfur dioxide, shall not exceed 1.5 lbs/MMBtu of heat input per hour, on a calendar month average of hourly values for the facility. . 

Report the refinery monthly average SO2 lb/MMBt

Follow 40 CFR 60 Appendix A Method 11 for hydroASTM D-4294 for sulfur content of refinery fuel oil 
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Table 4 - Generally Applicable Requirements 

BP Cherry Point Refinery

Permit 

Term Citation Description Monitoring, Recordkeeping a

4.9 

SOx

NWCAA 462 (3/13/97) 

Emission of Sulfur Compounds

Sulfur compounds emitted greater than 1000 ppm (corrected to 7% O2) averaged 

for a sixty consecutive minute period from any equipment prohibited. This requirement is not violated if reasonable evidence is presented that concentrations will not exceed ambient standards and the permittee shows that no practical method of reducing concentration exists. 

4.10 

SO2

WAC 173-400-040(6) (8/20/93) The second paragraph of this citation is state only) Same as State Only 1/10/05 

Sulfur Dioxide

Sulfur compounds calculated as sulfur dioxide and corrected to 7% O2 emitted 

greater than 1000 ppmvd average for a sixty consecutive minute period prohibited. 

Continuously monitor and record the concentration fuel gas, or alternatively stack SO2, in accordance 

listed in Section 5. Burn only low sulfur diesel (0.05% by weight) as aWhen combusting diesel, sample the oil daily or wsulfur content as per ASTM D-4294. Retain recordyears. The test results shall be traceable to each the dates the fuel is combusted, and the date of ea- directly enforceable -

4.11 

Sulfur 

NWCAA 520 (4/14/93) 

Sulfur Compounds in Fuel

Prohibited to burn, sell, or make available for sale for burning in fuel burning equipment within the jurisdiction of the NWCAA, fuel containing sulfur in excess of the following: #1 distillate- 0.3 wt%; #2 distillate-0.5 wt%; other fuel oils-2.0 wt%; solid fuels-2.0 wt% for a time period not to exceed 30 days in a 12-month period. 

Retain fuel specifications and purchase records ve

combusted in NWCAA’s jurisdiction has a sulfur coallowable limits. Use the following test procedures: 

• Industrial and Marine Fuel Oils - AST• Distillate Fuel Oil - ASTM D-2622 

- directly enforceable - 
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Table 4 - Generally Applicable Requirements 

BP Cherry Point Refinery

Permit 

Term Citation Description Monitoring, Recordkeeping a

4.12 

Sulfur 

NWCAA 520 (5/9/96 State Only) 

Sulfur Compounds in Fuel

Prohibited to burn fuel containing sulfur in excess of the following: #1 distillate- 0.3%; #2 distillate-0.5%; other fuel oils-2.0%; solid fuels-2.0%. This version exempts ocean-going vessels. 

 Retain fuel specifications and purchase records vthe refinery has a sulfur content of no more than thUse the following test procedures: 

• Industrial and Marine Fuel Oils - AST• Distillate Fuel Oil - ASTM D-2622 

- directly enforceable – 

4.13 

Odor 

WAC 173-400-040(4) (1/10/05 State Only) 

Odors

Off-site nuisance odors prohibited. 

4.14 

Odor 

NWCAA 535 (3/09/00) State Only) 

Odor Control Measures

Appropriate practices and control equipment shall be installed and operated to reduce odor-bearing gasses emitted into the atmosphere to a reasonable minimum. Any person who shall cause the generation of any odor from any source which may reasonably interfere with any other property owner’s use and enjoyment of their property must use recognized best practices and control equipment to reduce these odors to a reasonable minimum.  No person shall cause or permit the emission of any odorous air contaminant from any source if it is detrimental to the health, safety, or welfare of any person, or causes damage to property or business. 

Upon receiving an odor complaint from the NWCAinvestigate the complaint and the operations of the (a) refinery emissions of odorous air contaminants safety and welfare of any person, or causing dama(b) the refinery is using recognized best practices these odors to a reasonable minimum. If BP deterefinery caused or are causing a nuisance conditioin are inadequate, and if the identified problems cawithin four hours, action shall be taken to minimize made and the NWCAA shall be notified within 12 hcomplaint and action being taken to resolve the prThe results of the investigation, identification of anaberrant operation, and the date and time of repaiA log of these records shall be maintained for inspReceipt of a nuisance complaint in itself shall not n- directly enforceable - 
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Table 4 - Generally Applicable Requirements 

BP Cherry Point Refinery

Permit 

Term Citation Description Monitoring, Recordkeeping a

4.15 

Nuisance 

NWCAA 530 (3/09/00) State Only) 

General Nuisance

No person shall discharge from any source quantities of air contaminants, with the exception of odors, in sufficient amounts and of such characteristics and duration as is likely to be injurious or cause damage to human health, plant or animal life, or property; or which unreasonably interferes with enjoyment of life and property. An air contaminant is defined as “dust, fumes, mist, smoke, other particulate matter, vapor gas, odorous substance, or any combination thereof. 

Upon receiving an air contaminant complaint from addressing conditions other than odors, BP shall ioperations of the refinery to determine whether refare causing injury or damage to human health, plaunreasonably interfere with enjoyment of life or proemissions from the refinery caused or are causing identified problems cannot be repaired or correctebe taken to minimize emissions until repairs can bbe notified within 12 hours with a description of the taken to resolve the problem. The results of the investigation, identification of anaberrant operation, and the date and time of repaiA log of these records shall be maintained for insp

Receipt of a nuisance complaint in itself shall not n-directly enforceable – 
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Table 4 - Generally Applicable Requirements 

BP Cherry Point Refinery

Permit 

Term Citation Description Monitoring, Recordkeeping a

4.16 

General 

WAC 173-400-040(5) (8/20/93) Same as State Only 1/10/05 

Emission Detrimental to Persons or 

Property

Emissions detrimental to health or property prohibited. 

4.17 

PM 

NWCAA 550.1-4 (7/14/05) State Only 

Preventing Particulate Matter from 

Becoming Airborne

Use reasonably available control technology (RACT) to prevent the release of fugitive particulate matter and do not allow fugitive particulate matter to be deposited beyond the property lines of the facility. 

4.18 

PM 

WAC 173-400-040(2) (1/10/05) State Only 

Fallout

Nuisance particulate fallout prohibited. 

4.19 

PM 

WAC 173-

400-040 

(3)(a) 

(8/20/93) 

Same as State Only 1/10/05 

Fugitive Emissions for Attainment Areas

Take reasonable precautions to prevent release of air contaminants required. 

4.20 

Dust 

WAC 173-400-040(8)(a) (8/20/93) Same as State Only 1/10/05 

Fugitive Dust Sources

Reasonable precautions to prevent release of fugitive dust required. Maintain and operate source to minimize emissions. 

Upon receiving an air contaminant complaint from addressing conditions other than odors, BP shall i

operations of the refinery to determine whether refare causing injury or damage to human health, plaunreasonably interfere with enjoyment of life or proemissions from the refinery caused or are causing identified problems cannot be repaired or correctebe taken to minimize emissions until repairs can bbe notified within 12 hours with a description of the The results of the investigation, identification of anaberrant operation, and the date and time of repaiA log of these records shall be maintained for insp(see above) Receipt of a nuisance complaint in itself shall not n- directly enforceable -
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Table 4 - Generally Applicable Requirements 

BP Cherry Point Refinery

Permit 

Term Citation Description Monitoring, Recordkeeping a

4.21 

Reports 

WAC 173-401-615(3) (9/16/02) 

Required Monitoring Reports

Submit reports of any required monitoring to the NWCAA at least once every six months. All instances of deviations from permit requirements must be clearly identified in such reports. Monthly, quarterly and semiannual reports are scheduled on a calendar basis. The reports shall be submitted within 30 days after the close of the period that the reports cover. VOC reports shall be submitted within 60 days. 

Unless specifically required otherwise by a permit cover a calendar month, quarterly reports shall covmonth reports shall cover January through June aannual reports shall cover a calendar year. The fifrom permit issuance until the first month, quarter, 

following permit issuance. The reports shall be submitted within 30 days or 6after the close of the period that the reports cover. 

- directly enforceable – 

4.22 

Reports 

WAC 173-400-050 (3) (2/19/91) Same as State Only 1/10/05 

Measured concentrations for combustion and incineration units shall be adjusted for volumes corrected to seven percent oxygen, except when Ecology or NWCAA determines that an alternate oxygen correction factor is more representative of 

normal operations. 

Follow 40 CFR 60 Appendix A 

4.23 

VOC 

NWCAA 580.24 (2/8/96) 

Process Turnarounds

Process units shall be depressurized to less than 5 psig (gauge) before venting to the atmosphere. During depressurization, VOCs shall be routed through a closed vent system to a flare or other appropriate disposal device. 

Keep records of each process unit turnaround listishutdown. Report emissions from turnarounds in tA specific record shall be kept for any turnaround VOC was vented to the atmosphere at a pressure 

4.24 

VOC 

NWCAA 580.25 (2/8/96) 

Equipment for the reduction, collection or disposal of VOC shall be maintained and operated in a manner commensurate with accepted industrial practices. 
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Table 4 - Generally Applicable Requirements 

BP Cherry Point Refinery

Permit 

Term Citation Description Monitoring, Recordkeeping a

4.25 

SO2

NWCAA Letter 3/9/95 PSD-3 Condition 7 (12/20/84) (state only) 

Refinery-wide emissions of SO2 shall not 

exceed 2,468 lbs/hour on a monthly average. 

4.26 

PM 

NWCAA Letter 3/9/95 PSD-3 Condition 7 (12/20/84) (state only) 

Refinery-wide emissions of PM shall not exceed 4,258 lbs/day on a monthly average. 

Report monthly totals on monthly reporting 
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SECTION 5 - SPECIFICALLY APPLICABLE REQUIREMENTS The cited requirements in the “Citation” column of these tables incorporated herein by reference are applicable only the preceding table header. These requirements are federally enforceable unless identified as “state only”. A requironly” is enforceable only by the state, and not by the EPA or through citizen suits. The “Description” column of Tablapplicable requirements for informational purposes only and is not enforceable. Where there is a “test method” coluidentifies (when appropriate) the test method associated with the applicable requirement as required by WAC 173-4continuous monitoring requirements (including testing) are specified in the “Monitoring/Recordkeeping/Reporting” comonitoring, record keeping and reporting (MR&R) obligations the source must perform as required by WAC 173-401

the underlying requirements. 

The requirements in the MR&R column labeled “directly enforceable” are legally enforceable requirements added un

authority. Other requirements not labeled “directly enforceable” are brief descriptions of the regulatory requirements are not enforceable, unless they are identical to the cited requirement. Unless the text of the MR&R column is specenforceable, the language of the cited regulation takes precedence over a paraphrased requirement. 

The provisions of federally approved NWCAA Section 365, Section 366 and the “Guidelines for Industrial Monitoring 

Handling” have been replaced in this section by NWCAA Section 367 and Appendix A - "Ambient Monitoring, EmissEmission and Opacity Monitoring". NWCAA Section 367 and Appendix A were adopted on July 14, 2005 with a provdate of adoption would be allowed to achieve compliance with Appendix A. The new regulations are “State Only” unImplementation Plan. Section 367 and Appendix A are not materially different from the previous rule and guideline, 

include current monitoring technology and methods. Section 5 is separated into the following refinery process and product handling areas:

Section Page No. Section 

5.1 Primary Crude/Vacuum Process Area 2 5.12 Flares 5.2 Naphtha HDS and Reformer Units 8 5.13 Sulfur Complex 5.3 Hydrocracker Area 17 5.14 Wastewater Plant and Sewer System 5.4 Delayed Coker 21 5.15 Tanks and Storage Vessels 5.5 #1 Diesel HDS Unit 26 5.16 Shipping, Pumping, and Receiving 

5.6 #2 Diesel HDS Unit 30 5.16.1 Chemical Treaters 5.7 Hydrogen Plant 35 5.16.2 Truck Rack 5.8 Calciners 36 5.16.3 Marine Terminal 

 5.9 Light End (LEU)/LPG Unit 42 5.16.4. LPG/LEU/Butane/Pentane Lo 5.10 Isomerization Unit 44 5.17 Non-Hazardous Waste Landfarm  5.11 Cooling Towers and Utility Boilers 50 
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5.1 Primary Crude/Vacuum Process Area 

Table 5.1 - Specifically Applicable Requirements for the Primary Crude Oil/Vacuum Proce

Permit 

Term Citation Description Monitoring/Recordkee

Entire Crude/Vacuum Process Area 

Components in VOC Service 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.1.1 

VOC 

40 CFR 60.692-2 (11/23/88), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) NWCAA OAC #640 (5/1/98) Condition 1 

NSPS Subpart QQQ - Individual Drain Systems

Each affected individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. Except where repair is technically impossible without a unit shutdown, when a broken seal, gap, crack or other problem is identified, first efforts at repair shall be made as soon as practicable, but not later than 15 calendar days after identification. 

Conduct Inspections as specified in Perm

5.1.2 

VOC 

40 CFR 60.692-2 (11/23/88), 60.692-5 (10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) NWCAA OAC #640 Condition 1 (5/1/98) 

NSPS Subpart QQQ - Individual Junction 

BoxesEach affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. 

Conduct Inspections as specified in Perm
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Table 5.1 - Specifically Applicable Requirements for the Primary Crude Oil/Vacuum Proce

Permit 

Term Citation Description Monitoring/Recordkee

5.1.3 

VOC 

40 CFR 60.590-60.593 (10/17/00) which references 60.480-60.489 (12/14/00) NWCAA OAC #640 Condition 2-7 (5/1/98) 

NSPS Subpart GGG - Equipment Leaks

Monitor affected components for fugitive leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. Components include: pumps in liquid service, pressure relief valves in gas/liquid service, all sampling connection systems, all open-ended valves or lines, all valves in gas/vapor service or light liquid service, all pumps and valves in heavy liquid service, pressure relief valves in light liquid service, flanges and connectors. 

Conduct an Equipment Leak program (L6.2. 

5.1.4 

VOC 

NWCAA 580.221 and 580.25 (2/8/96) 

Non-condensable VOC shall be piped to an appropriate firebox, incinerator or to a closed refinery system. 

Equipment for the reduction, collection o

maintained and operated in a manner coindustrial practices. 

5.1.5 

VOC 

NWCAA 580.222 and 580.25 (2/8/96) 

Hot wells associated with contact condensers shall be tightly covered and the collected VOC introduced into a closed refinery system. 

Components in HAP Service

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.1.6 

HAP 

40 CFR 63.648(a) and (b) (8/18/98) which references 60.480-60.489 (12/14/00) 

Refinery MACT - Equipment Leaks

Monitor affected components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program (L6.2. 
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Table 5.1 - Specifically Applicable Requirements for the Primary Crude Oil/Vacuum Proce

Permit 

Term Citation Description Monitoring/Recordkee

5.1.7 

HAP 

40 CFR 63.647(c), 63.654(a), 63.654(i)(4) which references 40 CFR 61.340 through 61.355 

Refinery MACT - Process Drains

Each affected individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. 

Conduct inspections as specified in PermFollow 40 CFR 60 Appendix A Method 2

Crude Heater 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.1.8 

SO2

(H2S) 

NWCAA RO #28 (5/15/02) which references 40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(3)(ii), and 60.106(e)(1) (10/17/00) 

NSPS Subpart J – Fuel Gas

Fuel gas limited to a composition of H2S<230 

mg/dscm (0.10 gr/dscf). Equivalent to 162 ppm H2S, 3 hour rolling average. 

Operate CEMs measuring H2S concentra

NWCAA 367 and NWCAA Appendix A - and 40 CFR 60 Appendices B and F. Follow 40 CFR 60 Appendix A Method 1Report average H2S content (3 hour rollin
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Table 5.1 - Specifically Applicable Requirements for the Primary Crude Oil/Vacuum Proce

Permit 

Term Citation Description Monitoring/Recordkee

North Vacuum Heater 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.1.9 

SO2

(H2S) 

NWCAA RO #28 (5/15/02) which references 40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(3)(ii), and 60.106(e)(1) 

NSPS Subpart J - Fuel Gas

Fuel gas limited to a composition of H2S<230 

mg/dscm (0.10 gr/dscf). Equivalent to 162 ppm H2S, 3 hour rolling average. 

Operate CEM for H2S concentration at th

accordance with NWCAA 367 and NWCCFR 60 Subpart J and 40 CFR 60 AppeReport average H2S content (3 hour rolli

Follow 40 CFR 60 Appendix A Method 1

5.1.10 

NOx 

WDOE PSD-5 Condition 3 (12/17/85) 

After installation of low NOx burners, NOx Emissions shall not exceed 0.08 lb/MMBtu or 38 tons/year based on the average of any 60 consecutive minutes. Note: Emissions based on heating load. 

Report maximum hourly average heating report. Report hourly average NOx emissions in Report NOx and CO (tpy) emissions in y

5.1.11 

CO 

NWCAA OAC #273b Conditions 1, 2 and 3 (11/18/04) 

CO emissions shall not exceed 27.7 tpy. Use emission factor of 0.0823 lb/MMBtu. A revised emission factor may be used if more accurate data is available and approved by NWCAA. 

Maintain monthly records of CO emissioperiod and maintain onsite for five years
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Table 5.1 - Specifically Applicable Requirements for the Primary Crude Oil/Vacuum Proce

Permit 

Term Citation Description Monitoring/Recordkee

5.1.12 

H2S 

WDOE PSD-5 Condition 5 & 6 (12/17/85) 

The fuel concentration of H2S in the vacuum 

heater shall not exceed 160 ppm, 3 hour rolling average or 90 ppm on a monthly average. 

Operate CEM for H2S concentration at th

accordance NWCAA 367 and NWCAA A60 Subpart J and 40 CFR 60 AppendiceReport average H2S content (3 hour rolli

Follow 40 CFR 60 Appendix A Method 1

5.1.13 

O2

WDOE PSD-5 Condition 4 (12/17/85) 

Continuously monitor oxygen on the heater. Records must be kept onsite for five yea

Use Performance Specification 3 (40 CF

5.1.14 

General 

WDOE PSD-5 Condition 2 (12/17/85) 

Firing rate is not to exceed 77 MM Btu/hr. Report maximum heater load and numbe

emissions report. 

South Vacuum Heater 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.1.15 

SO2

(H2S) 

NWCAA RO #28 (5/15/02) which references 40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(1), 60.105(e)(3)(ii) 

NSPS Subpart J – Fuel Gas

Fuel gas limited to a composition of H2S<230 

mg/dscm (0.10 gr/dscf). Equivalent to 162 ppm H2S, 3 hour rolling average. 

Operate CEM for H2S concentration at th

accordance with NWCAA 367 and NWCCFR 60 Subpart J and 40 CFR 60 AppeReport average H2S content (3 hour rolli

Follow 40 CFR 60 Appendix A Method 1

5.1.16 

SO2

(H2S) 

NWCAA OAC #902a Condition 1 (10/26/05) 

Fuel combusted in the heater shall be limited to pipeline grade natural gas and refinery fuel gas.

Keep records of fuel usage. -directly enforceable- 
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Table 5.1 - Specifically Applicable Requirements for the Primary Crude Oil/Vacuum Proce

Permit 

Term Citation Description Monitoring/Recordkee

5.1.17 

NOx 

NWCAA OAC #902a Condition 3 (11/01/05) 

NOx emissions shall not exceed 10.5 lbs/hr based on a calendar day average. 

Compliance with this condition shall be dcalibrated, maintained and operated to mstack. Each monitor shall meet the appropriate and NWCAA Appendix A (7/14/05). Hourly emission rates for NOx shall be reshall be kept showing the method of calcReport data in monthly monitoring report-directly enforceable5.1.18 

CO 

NWCAA OAC #902a Condition 4 (11/01/05) 

CO emissions shall not exceed 11.8 lbs/hr. 

. 

Compliance with this condition shall be performance test following EPA Methoof initial startup. Test Methods 1 througshall be used in conjunction with the mshall be done under maximum operatin90% of the design firing rate. The source test shall be conducted in ac367 and NWCAA Appendix A (7/14/05).

5.1.19 

Opacity 

NWCAA OAC #902a Condition 2 (10/26/05) 

Visual emissions shall not exceed 5% for more than three minutes in any consecutive 60-minute period 

Monitor opacity in accordance with the p

5.1.20 

General 

NWCAA OAC #902a Condition 5 (10/26/05) 

An operating and maintenance manual that contains O&M information on the ultra-low NOx burners shall be maintained on site. 

Maintain O&M manual onsite for review. 
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5.2 Naphtha HDS and Reformer Units 

Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer U

Permit 

Term Citation Description Monitoring/Recordkeep

Entire Naphtha HDS and Reformers Area 

Components in VOC Service

Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected fa

5.2.1 

VOC 

40 CFR 60.692-2 (11/23/88), 60.692-5 (10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Subpart QQQ - Individual Junction 

Boxes

Each affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. 

Perform inspection according to Permit Ter

Components in HAP Service 

Note: The Title 40 CFR 63 General Provisions included in Section 3 apply to these affected fa

5.2.2 

HAP 

40 CFR 63.648(a) and (b) (8/18/98) which references 40 CFR 60.480-60.489 (12/14/00) 

Refinery MACT - Equipment Leaks

Monitor affected components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program (LDA
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Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer U

Permit 

Term Citation Description Monitoring/Recordkeep

5.2.3 

HAP 

40 CFR 63.647(c), 63.654(a), 63.654(i)(4) which references 40 CFR 61.340 through 61.355 (8/18/95) 

Refinery MACT - Process Drains

Each affected individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. 

Conduct inspections as specified in Permit Follow 40 CFR 60 Appendix A Method 21 

Group 1 Process Vents in the Naphtha HDS and Reformers Area (11V-008, 11V-009, 11V-124 

Note: 40 CFR 63 General Provisions included in Section 3 apply to these affected facilitie

5.2.4 

HAP 

40 CFR 63.643(a) (1) (8/18/95) 

Refinery MACT - Process Vents

Control HAP emissions from applicable vents by 98% or to 20 ppmv using a flare. Note: Does not apply to catalyst regeneration vents per 40 CFR 63.640(d)(4). 

Follow monitoring, recordkeeping and repoPermit Terms 5.12.1 through 5.12.10 (Flare used as control device) Follow 40 CFR 60 Appendix A Method 18 
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Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer U

Permit 

Term Citation Description Monitoring/Recordkeep

Naphtha HDS Unit 

Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected fa

5.2.5 

SO2 

 (H2S) 

NWCAA RO #28 (5/15/02) which references: 40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(a)(3)(ii), and 60.106(e)(1) (10/17/00) 

NSPS Subpart J – Fuel Gas

Fuel gas limited to a composition of H2S<230 

mg/dscm (0.10 gr/dscf). Equivalent to 162 ppm H2S, 3 hour rolling average. 

Operate CEM for H2S concentration at the f

NWCAA 367 and Appendix A (7/14/05), 40 60 Appendices B and F. Periods of excess emissions that shall be ddefined as follows. All rolling 3-hour periods concentration of H2S as measured by the H

under §60.105(a)(4) exceeds 162 ppmv. Report average H2S content (3-hour rolling 

Follow 40 CFR 60 Appendix A Method 11 o

#1 Reformer Unit 

Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected fa

5.2.6 

SO2

(H2S) 

NWCAA RO #28 (5/15/02) which references: 40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(3)(ii), and 60.106(e)(1) (10/17/00) 

NSPS Subpart J – Fuel Gas

Fuel gas limited to a composition of H2S<230 

mg/dscm (0.10 gr/dscf). Equivalent to 162 ppm H2S, 3 hour rolling average. 

Operate CEM for H2S concentration at the f

NWCAA 367 and Appendix A - “Ambient MContinuous Emission and Opacity MonitorinSubpart J and 40 CFR 60 Appendices B anPeriods of excess emissions that shall be ddefined as follows. All rolling 3-hour periods concentration of H2S as measured by the H

under §60.105(a)(4) exceeds 162 ppmv. Report average H2S content (3-hour rolling 

Follow 40 CFR 60 Appendix A Method 11 o
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Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer U

Permit 

Term Citation Description Monitoring/Recordkeep

Note: The Title 40 CFR 63 General Provisions included in Section 3 apply to these affected fa

5.2.7 

HAP 

OAC #562b (3/17/03) which references: 40 CFR 63.648(a) and (b) (8/18/98) which references 40 CFR 60.480-60.489 (12/14/00) 

BACT - Equipment Leaks

Monitor affected components for fugitive leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program (LDAFollow 40 CFR 60 Appendix A Method 21 

5.2.8 

HAP 

40 CFR 63.648(a) and (b) (8/18/98) which references 40 CFR 60.480-60.489 (12/14/00) 

Refinery MACT - Equipment Leaks

Monitor affected components for HAP leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance 40 CFR 60 Subpart VV. 

Components include: pumps in liquid service, pressure relief valves in gas/liquid service, all sampling connections, all open-ended valves or lines, all valves in gas/vapor service, pressure valves in light liquid service, flanges and other connectors. 

Conduct an Equipment Leak program (LDAFollow 40 CFR 60 Appendix A Method 21 

5.2.9 

HAP 

OAC #562b (3/17/03) which references: 40 CFR 63.647(c), 63.654(a), 63.654(i)(4) which references 40 CFR 61.340 through 61.355 (8/18/95) 

BACT/Refinery MACT - Process Drains

Each affected individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. 

Conduct inspections as specified in Permit TFollow 40 CFR 60 Appendix A Method 21 
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Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer U

Permit 

Term Citation Description Monitoring/Recordkeep

5.2.10 

General 

40 CFR 63.1574(f), 63.1575(a) and (b) and 63.1576(b) (2/9/05) 

Refinery MACT II - General 

Follow appropriate work practice standards and comply with any applicable emission standards.Prepare, maintain and implement an operation, maintenance and monitoring plan (OMMP) for each control system and operate at all times according to procedures in the plan. 

Submit compliance report on a semi-annuadeviation from emission limitation or work pon whether any continuous monitoring systmalfunctioning, out-of-control, repaired or a

Keep records to demonstrate that procedurwere followed. Maintain records available fSubmit any revisions to the OMMP to the N

5.2.11 

VOC/ 

HAP 

40 CFR  63.1566, 63.1570(f) and 63.1576(h) (2/9/05) 

Refinery MACT II – Organic HAP Emissions

Control organic HAP emissions by depressuring and purging to a combustion device or a flare that meets the requirements of §63.11(b). These limits do not apply to depressuring and purging operations when the reactor vent pressure is 5 psig or less.

Operate in accordance with the Operation, Plan (OMMP) and report any instances of dlimitation, operating limit or work practice stFollow the MR&R requirements specified in excluding 5.12.5 Keep records for a minimum of 5 years. 

5.2.12 

VOC/ 

HAP 

40 CFR 63.1567, 63.1570(f) and 63.1576(h) (2/9/05) (2/9/05 

Refinery MACT II - Inorganic HAP 

EmissionsDuring coke burn-off and catalyst rejuvenation reduce uncontrolled emissions of hydrogen chloride by 92% by weight or to a concentration of 30 ppmv (dry) corrected to 3% O2. 

Operate in accordance with the Operation, Plan (OMMP) and report any instances of dlimitation, operating limit or work practice st

Demonstrate compliance by measuring and concentration at least 4 times during a regewhichever is more frequent, using a colorimCalculate daily average HCl concentration asamples collected during a 24 hour period. Keep records for a minimum of 5 years 
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Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer U

Permit 

Term Citation Description Monitoring/Recordkeep

#2 Reformer Unit 

Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected fa

5.2.13 

SO2 (H2S) 

NWCAA RO #28 (5/15/02) which references 40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(3)(ii), and 60.106(e)(1) (10/17/00) 

NSPS Subpart J – Fuel Gas

Fuel gas limited to a composition of H2S<230 

mg/dscm (0.10 gr/dscf). Equivalent to 162 ppm H2S, 3 hour rolling average. 

Operate CEM for H2S concentration at the f

NWCAA 367 and NWCAA Appendix A - (7/40 CFR 60 Appendices B and F. Periods of excess emissions that shall be ddefined as follows. All rolling 3-hour periods concentration of H2S as measured by the H

under §60.105(a)(4) exceeds 162 ppmv. Report average H2S content (3-hour rolling 

Follow 40 CFR 60 Appendix A Method 11 o

5.2.14 

VOC 

OAC #305 (11/14/85) which references: 40 CFR 60.590-60.593 (10/17/00) which references 40 CFR 60.480-60.489 (12/14/00) 

BACT/NSPS Subpart GGG - Equipment Leaks

Monitor affected components for fugitive leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program (LDAFollow 40 CFR 60 Appendix A Method 21 
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Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer U

Permit 

Term Citation Description Monitoring/Recordkeep

5.2.15 

General 

40 CFR 63.1574(f), 63.1575(a) and (b) and 63.1576(b) (2/9/05) 

Refinery MACT II - General 

Follow appropriate work practice standards and comply with any applicable emission standards.Prepare, maintain and implement an operation, maintenance and monitoring plan (OMMP) for each control system and operate at all times according to procedures in the plan. 

Submit compliance report on a semi-annual from emission limitation or work practice stawhether any continuous monitoring system wmalfunctioning, out-of-control, repaired or ad

Keep records to demonstrate that procedurewere followed. Maintain records available foSubmit any revisions to the OMMP to the NW

5.2.16 

VOC/ HAP 

40 CFR 63.1566, 63.1570(f) and 63.1576(h) (2/9/05) 

Refinery MACT II – Organic HAP Emissions

Control organic HAP emissions by depressuring and purging to a combustion device or a flare that meets the requirements of §63.11(b). These limits do not apply to depressuring and purging operations when the reactor vent pressure is 5 psig or less. 

Operate in accordance with the Operation, M

(OMMP) and report any instances of deviatioperating limit or work practice standard. Follow the MR&R requirements specified in excluding 5.12.5 

Keep records for a minimum of 5 years. 

5.2.17 

VOC/ 

HAP 

40 CFR 63.1567, 63.1570(f) and 63.1576(h) (2/9/05) (2/9/05 

Refinery MACT II - Inorganic HAP 

EmissionsDuring coke burn-off and catalyst rejuvenation reduce uncontrolled emissions of hydrogen chloride by 92% by weight or to a concentration of 30 ppmv (dry) corrected to 3% O2. 

Operate in accordance with the Operation, Plan (OMMP) and report any instances of dlimitation, operating limit or work practice st

Demonstrate compliance by measuring and concentration at least 4 times during a regewhichever is more frequent, using a colorimCalculate daily average HCl concentration asamples collected during a 24 hour period. Keep records for a minimum of 5 years 
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Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer U

Permit 

Term Citation Description Monitoring/Recordkeep

The following conditions specified in OAC 305 and PSD-7 apply to the #2 Reformer He

5.2.18 

CO 

WDOE PSD-7 Condition 1a (3/13/86) NWCAA OAC # 305 Condition 1 (11/14/85) 

Emissions shall not exceed 11.0 lb/hr or 48.3 tpy, based on the average of 60 consecutive minutes. CO emission rate based on heating load. 

5.2.19 

NOx 

WDOE PSD-7 Condition 1b (3/13/86) NWCAA OAC # 305 Condition 1 (11/14/85) 

Emissions shall not exceed 32.0 lb/hr or 140 tpy (as NO2), based on the average of 60 

consecutive minutes. Note: Emissions based on heating load 

5.2.20 

General 

WDOE PSD-7 Condition 2 (3/13/86) NWCAA OAC # 305 Condition 1 (11/14/85) 

Firing of the heater shall not exceed 340 MMBtu/hr, based on hourly average calculated heat content of the fuel. Note: Emissions based on heating load. 

Report hourly maximum heat load in month

Emissions calculations for CO based on EPlb/MMBtu) when the PSD permit was issue- directly enforceable -

5.2.21 

O2

WDOE PSD-7 Condition 3 (3/13/86) 

Continuously monitor oxygen on the heater. Records must be kept onsite for two years. 

Follow Performance Specification 3 (40 CF

5.2.22 

H2S 

NWCAA OAC #305 Condition 3 (11/14/85) 

The fuel concentration of H2S in the heater 

shall not exceed 160 ppm H2S, 3 hour rolling 

average or 90 ppm on a monthly average. 

Operate CEM for H2S concentration in the f

NWCAA 367 and NWCAA Appendix A - (7/B. Follow 40 CFR 60 Appendix A Method 11 o
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Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer U

Permit 

Term Citation Description Monitoring/Recordkeep

5.2.23 

PM/PM10 

NWCAA OAC #305 Condition 6 (11/14/85) 

Emissions shall not exceed 0.01 gr/dscf, corrected to 7% oxygen 

Follow the MR&R requirements specified in Follow 40 CFR 60 Appendix A Method 5 

5.2.24 

Opacity 

NWCAA OAC #305 Condition 5 (11/14/85) 

Opacity shall not exceed 5% opacity for more than three minutes in any one hour. 

Monitor opacity in accordance with Section 
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5.3 Hydrocracker Area 

Table 5.3 - Specifically Applicable Requirements for the Hydrocracker Area 

Permit 

Term Citation Description Monitoring/Recordke

Entire Hydrocracker Area 

Components in HAP Service 

Note: The Title 40 CFR 63 General Provisions included in Section 3 apply to these affected fa

5.3.1 

HAP 

40 CFR 63.648(a) and (b) (8/18/98) which references 40 CFR 60.480-60.489 (12/14/00) 

Refinery MACT - Equipment Leaks

Monitor affected components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program (Follow 40 CFR 60 Appendix A Method 

5.3.2 

HAP 

40 CFR 63.647(c), 63.654(a), 63.654(i)(4) which references 40 CFR 61.340 through 61.355 

Refinery MACT - Process Drains

Each affected individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. 

Conduct inspections as specified in PerFollow 40 CFR 60 Appendix A Method 

Affected Process Vent 15-V-057

5.3.3 

HAP 

40 CFR 63.643(a)(1) (6/18/95) 

Refinery MACT - Process Vents

Control HAP emissions from applicable vents by using a flare for Group I process vents. 

Follow monitoring, recordkeeping and rin Permit Terms 5.12.1 through 5.12.10 

(Flare used as control device) Follow 40 CFR 60 Appendix A Method 
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5-18 

Table 5.3 - Specifically Applicable Requirements for the Hydrocracker Area 

Permit 

Term Citation Description Monitoring/Recordke

Entire Hydrocracker Area

Components in VOC Service

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.3.4 

VOC 

40 CFR 60.692-2 (11/23/88), 60.692-5 (10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Subpart QQQ - Individual Junction Boxes

Each affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. 

Conduct inspections as specified in Pe

R-1 Hydrocracker Reactor Heater, R-4 Hydrocracker Reactor Heater, and 1st Stage Fractionat

5.3.5 

SO2

(H2S) 

NWCAA RO #28 (5/15/02) which references 40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(3)(ii) and 60.106(e)(1) (10/17/00) 

NSPS Subpart J – Fuel Gas

Fuel gas limited to a composition of H2S<230 

mg/dscm (0.10 gr/dscf). Equivalent to 162 ppm H2S, 3 hour rolling average. 

Operate CEM for H2S concentration at 

with NWCAA 367 and NWCAA AppendSubpart J and 40 CFR 60 Appendices Periods of excess emissions that shall defined as follows. All rolling 3-hour peconcentration of H2S as measured by t

system under §60.105(a)(4) exceeds 1Report average H2S content (3 hour ro

Follow 40 CFR 60 Appendix A Method 

5.3.6 

SO2

(H2S 

NWCAA Permit to Construct (6/8/70) 

This unit is required to use only fuel gas. Facility configured to use only fuel gas 
BP Cherry Point Ref

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Table 5.3 - Specifically Applicable Requirements for the Hydrocracker Area 

Permit 

Term Citation Description Monitoring/Recordke

2nd Stage Fractionator Reboiler Heater 

5.3.7 

SO2

(H2S) 

NWCAA RO #28 (5/15/02) which references 40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(3)(ii) and 60.106(e)(1) (10/17/00) 

NSPS Subpart J – Fuel Gas

Fuel gas limited to a composition of H2S<230 

mg/dscm (0.10 gr/dscf). Equivalent to 162 ppm H2S, 3 hour rolling average. 

Operate CEM for H2S concentration at 

with NWCAA 367 and NWCAA AppendSubpart J and 40 CFR 60 Appendices Periods of excess emissions that shall defined as follows. All rolling 3-hour peconcentration of H2S as measured by t

system under §60.105(a)(4) exceeds 1Report average H2S content (3 hour ro

Follow 40 CFR 60 Appendix A Method 

5.3.8 

SO2

(H2S) 

NWCAA OAC #847 Condition 1 (11/13/03) 

Fuel combusted in the heater shall be limited to pipeline grade natural gas and refinery fuel gas. 

Keep records of fuel usage. 

-directly enforceable5.3.9 

NOx 

NWCAA OAC #847 Conditions 4 and 5 (11/13/03) 

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. 

Report NOx emissions based on firing within 30 days after the end of the prev

Conduct periodic source testing once emonths of the anniversary of the initial Follow 40 CFR 60 Appendix A Method 

5.3.10 

Opacity 

NWCAA OAC #847 Condition 2 (11/13/03) 

Visual emissions shall not exceed 5% for more than three minutes in any consecutive 60-minute period 

Monitor opacity in accordance with prov

5.3.11 

General 

NWCAA OAC #847 Condition 3 (11/13/03) 

The maximum firing rate of the reboiler heater shall not exceed 183.4 MMBtu/hr. 

Keep records of heater firing rate in MM

-directly enforceable5.3.12 

General 

NWCAA OAC #847 Condition 6 (11/13/03) 

An operating and maintenance manual that contains O&M information on the-low NOx burners shall be maintained on site. 

Maintain O&M manual on site. 
BP Cherry Point Ref

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5-20 

Table 5.3 - Specifically Applicable Requirements for the Hydrocracker Area 

Permit 

Term Citation Description Monitoring/Recordke

Piping Associated with Incremental Vacuum Gas Oil Recovery Project

5.3.13 

VOC/ 

HAP 

NWCAA OAC #850 (12/1/03) 

Project valve components shall be subject to the applicable portions of 40 CFR 63 Subpart CC. 

For valves that have the potential to leak hazardous organic pollutants installed as a part of this project: 

• leak detection and repair shall occur no less 

frequently than quarterly 

• the leak definition for block valves and 

control valves is 500 ppm 

Follow procedures for an Enhanced Lespecified in Section 6.3b. Follow 40 CFR 60 Appendix A Method 
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5-21 

5.4 Delayed Coker 

Table 5.4 - Specifically Applicable Requirements for the Delayed Coker Area 

Permit 

Term Citation Description Monitoring/Recordke

Entire Delayed Coker Area 

Components in HAP Service 

Note: The Title 40 CFR 63 General Provisions included in Section 3 apply 

5.4.1 

HAP 

40 CFR 63.648(a) and (b) (8/18/98) which references 40 CFR 60.480-60.489 (12/14/00) 

Refinery MACT - Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program 6.2 Follow 40 CFR 60 Appendix A Metho

Components in VOC Service

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.4.2 

VOC 

40 CFR 60.692-2 (11/23/88) 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Subpart QQQ - Individual Drain Systems

Each applicable individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. Except where repair is technically impossible without a unit shutdown, when a broken seal, gap, crack or other problem is identified, first efforts at repair shall be made as soon as practicable, but not later than 15 calendar days after identification. 

Conduct Inspections as specified in P
BP Cherry Point Ref

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5-22 

Table 5.4 - Specifically Applicable Requirements for the Delayed Coker Area 

Permit 

Term Citation Description Monitoring/Recordke

5.4.3 

VOC 

40 CFR 60.692-2 (11/23/88), 60.692-5 (10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Subpart QQQ - Individual Junction Boxes

Each affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. 

Conduct Inspections as specified in P

5.4.4 

VOC 

40 CFR 60.590-60.593 (10/17/00) which references 40 CFR 60.480-60.489 (12/14/00) 

NSPS Subpart GGG - Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Applicable components include: pumps in liquid service, pressure relief valves in gas/liquid service, all sampling connection systems, all open-ended valves or lines, all valves in gas/vapor service or light liquid service, all pumps and valves in heavy liquid service, pressure relief valves in light liquid service, flanges and other connectors. 

Conduct an Equipment Leak program 6.2 

Coker Affected Process Vent 12-V-130 

Note: The Title 40 CFR 63 General Provisions included in Section 3 apply to these affected fa

5.4.5 

HAP 

40 CFR 63.643(a)(1) (6/18/95) 

Refinery MACT - Process Vents

Control HAP emissions from applicable vents by using a flare 

Follow monitoring, recordkeeping and flares in Permit Terms 5.12.1 through (Flare used as control device.) Follow 40 CFR 60 Appendix A Metho
BP Cherry Point Ref

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5-23 

Table 5.4 - Specifically Applicable Requirements for the Delayed Coker Area 

Permit 

Term Citation Description Monitoring/Recordke

North and South Coker Charge Heaters 

5.4.6 

Opacity 

NWCAA OAC #689 Condition 1.1.4 and 2.1.4 (4/13/99) 

Opacity not to exceed 5% in 6 minutes Monitor opacity in accordance with Se

Follow WDOE Method 9 

5.4.7 

SO2

NWCAA OAC #689 Condition 1.1.2 and 2.1.2 (4/13/99) 

SO2 emissions shall not exceed 101 lb/MMscf or an 

annual maximum of 72 tpy. 

Perform biennial performance test on using EPA Method 6 or 6C or Fuel Ga15. 

5.4.8 

CO 

NWCAA OAC #689  Condition 1.1.3 and 2.1.3 (4/13/99) 

CO emissions shall not exceed 29 lb/MMscf or an annual maximum of 19 tpy. 

Perform biennial performance test on using 40 CFR 60 Appendix A Method alternative.

5.4.9 

NOx 

NWCAA OAC #689  Condition 1.1.1 and 2.1.1 (4/13/99) 

NOx emissions shall not exceed 0.08 lb/MMBtu or an annual maximum of 66 tpy. 

Perform biennial performance test on using 40 CFR 60 Appendix A Method 
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5-24 

Table 5.4 - Specifically Applicable Requirements for the Delayed Coker Area 

Permit 

Term Citation Description Monitoring/Recordke

Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected fa

5.4.10 

SO2 (H2S) 

40 CFR 60.104(a)(1), 60.105 (a)(4), 60.105(e)(3)(ii) and 60.106(e)(1) (10/17/00) 

NSPS Subpart J – Fuel Gas

Fuel gas limited to a composition of H2S<230 

mg/dscm (0.10 gr/dscf). Equivalent to 162 ppm H2S, 3 hour rolling average. 

Operate CEM for H2S concentration a

accordance with NWCAA 367 and NW40 CFR 60 Subpart J and 40 CFR 60 Periods of excess emissions that shaare defined as follows. All rolling 3-hoaverage concentration of H2S as mea

monitoring system under §60.105(a)(Report average H2S content of fuel g

monthly report. Follow 40 CFR 60 Appendix A Metho

5.4.11 

H2S 

NWCAA OAC #689 Condition 1.5.1 and 2.5.1 (4/13/99) 

Daily average of H2S for fuel gas supplies to Coker 

charge heaters shall not exceed 50 ppmvd on a 24-hour average. 

Operate CEM for H2S concentration a

accordance with NWCAA 367 and NW40 CFR 60 Subpart J and 40 CFR 60 Report H2S content of fuel gas (maxim

report. Follow 40 CFR 60 Appendix A Metho
BP Cherry Point Ref

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5-25 

Table 5.4 - Specifically Applicable Requirements for the Delayed Coker Area 

Permit 

Term Citation Description Monitoring/Recordke

Coker Compressor 12-1801 

Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected fa

5.4.12 

VOC 

40 CFR 60.482-3(b)(2) 

NSPS Subpart VV - Compressors

Each compressor shall be installed with a seal system that includes a barrier fluid system that prevents the leakage of VOC. 

Seal system is a barrier seal system tdegassing reservoir routed to a proceconnected by a closed vent system to with 40 CFR 60.482-10. Follow 40 CFR 60 Appendix A Metho

5.4.13 

VOC 

NWCAA OAC #890 Condition 8 

(2/22/05)

Coker blowdown vapors shall be routed to and recovered by compressor #12-1801. This condition provides emissions reduction for the purpose of PSD netting to offset potential increase in SO2 emissions associated with the SRU 

Modification Project. The coker blowdown vapor recovery project shall be completed and in operation prior to startup of the second Tail Gas Unit. 

Compliance shall be demonstrated by

• continuously monitoring and re

activated valve #HV-331and thcompressor, 

• following written standard ope

the coker blowdown vapors arcompressor except during timethe compressor is near its suctupset or maintenance 

• records shall be kept of each p

activity when coker vapors are 

• keep records of time, date dur

event and provide estimate of 

would have been recovered
BP Cherry Point Ref

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5-26 

5.5 #1 Diesel HDS Unit 

Table 5.5 - Specifically Applicable Requirements for the #1 Diesel HDS Process Are

Permit 

Term Citation Description Monitoring/Recordkeepin

Entire No. 1 Diesel HDS Unit 

Components in VOC Service 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.5.1 

VOC 

40 CFR 60.692-2 (11/23/88), 60.692-5(10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Subpart QQQ - Individual 

Junction Boxes

Each affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. 

Conduct Inspections as specified in Permit Ter

Components in HAP Service 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.5.2 

HAPS 

40 CFR 63.648(a) and (b) (8/18/98) which references 60.480-60.489 (12/14/00) 

Refinery MACT - Equipment Leaks

Monitor affected components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program (LDAR) 

 No. 1 Diesel HDS Charge Heater & No. 1 Diesel HDS Reboiler Heater

5.5.3 

H2S 

(SO2) 

NWCAA Permit to Construct (6/8/70) 

This unit is required to use only fuel gas. 

Facility configured to use only fuel gas. 
BP Cherry Point Ref

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5-27 

Table 5.5 - Specifically Applicable Requirements for the #1 Diesel HDS Process Are

Permit 

Term Citation Description Monitoring/Recordkeepin

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.5.4 

 H2S 

(SO2) 

NWCAA RO #28 (5/15/02) which references 40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(3)(ii) and 60.106(e)(1) (10/17/00) 

NSPS Subpart J – Fuel Gas

Fuel gas limited to a composition of H2S<230 mg/dscm (0.10 gr/dscf). 

Equivalent to 162 ppm H2S, 3 hour 

rolling average. 

Operate CEM for H2S concentration at the refin

with NWCAA 367 and NWCAA Appendix A - (7and 40 CFR 60 Appendices B and F. Periods of excess emissions that shall be deteas follows. All rolling 3-hour periods during whiH2S as measured by the H2S continuous monit

§60.105(a)(4) exceeds 162 ppmv. Report average H2S content (3 hour rolling ave

Follow 40 CFR 60 Appendix A Method 11 or 15 

5.5.5 

H2S 

(SO2) 

NWCAA OAC #949 Condition 1 (3/31/06) 

Fuel combusted in the #1 Diesel Hydrotreater Charge Heater shall be limited to pipeline grade natural gas and treated refinery fuel gas. 

Keep a record of fuel burned at the Charge He-directly enforceable5.5.6 

NOx 

NWCAA OAC #949 Condition 3 and 7 (3/31/06) 

NOx emissions from the #1 Diesel Hydrotreater Charge Heater shall not exceed 1.9 lb/hour or 0.040 lb/MMBtu (higher heating value). 

NOx emissions shall be determined by an initiacompliance to be demonstrated by subsequent every three years. Source tests must be perfoanniversary of the previous source test. Source tests shall be conducted above 70% of rate and in accordance with NWCAA Section 3Use EPA Method 7E 
BP Cherry Point Ref

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5-28 

Table 5.5 - Specifically Applicable Requirements for the #1 Diesel HDS Process Are

Permit 

Term Citation Description Monitoring/Recordkeepin

5.5.7 

CO 

NWCAA OAC #949 Condition 4 and 7 (3/31/06) 

CO emissions from the #1 Diesel Hydrotreater Charge Heater shall not exceed 3.2 lb/hour or 0.068 lb/MMBtu (higher heating value). 

CO emissions shall be determined by an initial compliance to be demonstrated by subsequent every three years. Source tests must be perfoanniversary of the previous source test. Source tests shall be conducted above 70% of rate and in accordance with NWCAA Section 3Use EPA Method 10 

5.5.8 

NOx 

NWCAA OAC #949 Condition 5 and 7 (3/31/06) 

NOx emissions from the Stabilizer Reboiler Heater shall not exceed 26 ppmv (dry basis corrected to 7% O2) based on a 24-hour rolling 

average. If this concentration is exceeded, a secondary limit to demonstrate compliance is 2.2 lb/hour based on a 24-hour rolling average. 

NOx emissions shall be determined by an initiacompliance demonstrated by a CEM installed, operated to measure NOx and O2 in the stack 

2008. Each monitor shall meet the appropriate Section 367 and Appendix A and 40 CFR 60 AUse EPA Method 7E for source testing. (To be Source testing shall be conducted at above 90Heater’s maximum firing rate. 

5.5.9 

CO 

NWCAA OAC #949 Condition 6 and 7 (3/31/06) 

CO emissions from the Stabilizer Reboiler Heater shall not exceed 3.8 lb/hr. 

CO emissions shall be determined by an initial compliance to be demonstrated by subsequent every three years. Source tests must be perfoanniversary of the previous source test. Source tests shall be conducted above 90% Stmaximum firing rate and in accordance with NWAppendix A. Use EPA Method 10 

5.5.10 

Visual 

NWCAA OAC #949 Condition 2 (3/31/06)

Visual emissions from the #1 Diesel Hydrotreater Charge Heater and the Stabilizer Reboiler Heater shall not exceed 5% opacity for more than 3 minutes in any 60-minute period. 

Use Department of Ecology Test Method 9A. 
BP Cherry Point Ref

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5-29 

Table 5.5 - Specifically Applicable Requirements for the #1 Diesel HDS Process Are

Permit 

Term Citation Description Monitoring/Recordkeepin

5.5.11 

General 

NWCAA OAC #949 Condition 8 (3/31/06) 

An operating and maintenance (O&M) manual shall be maintained on site for the No. 1 Diesel Hydrotreater Charge Heater and the Stabilizer Reboiler Heater that includes information on operation and maintenance of the ultra lowNOx burners. 

Keep operating and maintenance manuals on-

5.5.12 

VOC/HAP 

NWCAA OAC #949 Condition 9 (3/31/06) 

New LDAR components associated with the #1 DHDS Heater Reliability Project that have the potential to leak VOCs or HAPs shall be monitored using a leak definition of 500ppm for block valves and control valves. 

Monitoring in accordance with Section 6.3b. Record, track, repair and remonitor all leaks grBP will have 30 days to make repairs and remo500 ppm leak definition but less than the applicapplicable portions of 40 CFR 63 Subpart CC. 
BP Cherry Point Ref

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5-30 

5.6 #2 Diesel HDS Unit 

Table 5.6 - Specifically Applicable Requirements for the #2 Diesel HDS Process Ar

Permit 

Term Citation Description Monitoring/Recordkeepin

Entire No. 2 Diesel HDS Unit 

Components in VOC Service 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.6.1 

VOC 

40 CFR 60.692-2 (11/23/88) 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Subpart QQQ - Individual Drain Systems

Each applicable individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. 

Except where repair is technically impossible without a unit shutdown, when a broken seal, gap, crack or other problem is identified, first efforts at repair shall be made as soon as practicable, but not later than 15 calendar days after identification. 

Conduct inspections as specified in Permit Ter

5.6.2 

VOC 

40 CFR 60.692-2 (11/23/88), 60.692-5 (10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Subpart QQQ - Individual 

Junction Boxes

Each affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. 

Conduct inspections as specified in Permit Ter
BP Cherry Point Ref

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5-31 

Table 5.6 - Specifically Applicable Requirements for the #2 Diesel HDS Process Ar

Permit 

Term Citation Description Monitoring/Recordkeepin

Components in HAP Service 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.6.3 

HAP 

40 CFR 63.648(a) and (b) (8/18/98) which references 60.480-60.489 (12/14/00) 

Refinery MACT - Equipment Leaks

Monitor affected components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program (LDAR) 

Additional Requirements for Leak Detection and Repair for No. 2 Diesel HDS Unit 

5.6.4 

HAP 

NWCAA OAC # 892 Condition 6 (3/3/05) 

BACT – Enhanced LDAR

In addition to 40 CFR 60 Subpart GGG requirements valves and pumps shall be monitored for leaks no less frequently than quarterly. Leak definition shall be 500 ppm for control valves and block valves and 2,000 ppm for pumps. 

Valves and pumps identified as leaking at this level, but less than the applicable regulatory leak definition shall be allowed 30 days for repair and re-monitoring. 

Follow procedures for an Enhanced Leak DeteSection 6.3a. 
BP Cherry Point Ref

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5-32 

Table 5.6 - Specifically Applicable Requirements for the #2 Diesel HDS Process Ar

Permit 

Term Citation Description Monitoring/Recordkeepin

No. 2 Diesel HDS Charge Heater 

5.6.5 

Opacity 

NWCAA OAC # 892 Condition 2 (3/3/05) 

Visual emissions for the heater stack shall not exceed 5% opacity for more than three minutes in any 60-minute period. 

Monitor opacity in accordance with the provisio

5.6.6 

SO2

(H2S) 

NWCAA OAC # 892 Condition 1 (3/3/05) 

Fuel combusted shall be limited to pipeline grade natural gas and refinery fuel gas. 

Keep records of fuel usage. -directly enforceable5.6.7 

SO2

(H2S) 

NWCAA OAC # 892 Condition 3 (3/3/05) 

NSPS Subpart J – Fuel Gas

The H2S content of fuel gas 

combusted in the heater shall not exceed 162 ppm based on a 3-hour rolling average and +50 ppm based on a 24-hour rolling average. 

Install and operate CEM to measure H2S conce

heater. The monitor shall meet the appropriate Subpart J, 40 CFR 60 Appendices B and F, NWAppendix A - (7/14/05). Periods of excess emissions that shall be deteas follows: (1) all rolling 3-hour periods during concentration of H2S as measured by the CEM 

rolling 24-hour periods during which the averag

measured by the CEM exceeds 50 ppmv.  -directly enforceable5.6.8 

NOx 

NWCAA OAC # 892 Condition 4a (3/3/05) 

NOx emissions shall not exceed 0.035 lb/MMBtu. Tests to be conducted at or above 90% of design firing rate. 

Conduct source test within 120 days of initial sthereafter. Annual source test shall be performprevious test. Conduct tests in accordance witAppendix A - (7/14/05). Follow 40 CFR 60 Appendix A Method 7E 
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5-33 

Table 5.6 - Specifically Applicable Requirements for the #2 Diesel HDS Process Ar

Permit 

Term Citation Description Monitoring/Recordkeepin

5.6.9 

CO 

NWCAA OAC #892 Condition 4b (3/3/05) 

CO emissions shall not exceed 70 ppmvd @7% O2. Tests to be 

conducted at or above 90% of design firing rate. 

Conduct source test within 120 days of initial sthereafter. Annual source test shall be performprevious test. Conduct tests in accordance witAppendix A - (7/14/05). Follow 40 CFR 60 Appendix A Method 10 

5.6.10 

CO 

40 CFR 63.7, 63.7500(a), 63.7515(e), 63.7520(a), (b) and (f) and 63.7560 (9/13/04) 

NESHAPS Subpart DDDDD -

Process Heaters

CO emissions shall not exceed 400 ppmv corrected to 3% O2 (3-run 

average). Testing shall be conducted at maximum normal operating load and consist of three 1-hour runs. 

Submit site specific test plan for CO at least 60 performance test. Conduct initial performance startup and then annually thereafter between 1preceding test. Provide results within 60 days after completion for five years. Follow 40 CFR 60 Appendix A Method 10 

5.6.11 

General 

(SSM Plan) 

40 CFR 63.6(e)(3), 63.10(b), 63.10(d)(5) and 63.7560 (9/13/04) 

NESHAPS Subpart DDDDD -

Process Heaters

Develop and implement a written startup, shutdown and malfunction (SSM) plan that details procedures for operating and maintaining the source during periods of startup, shutdown and malfunction. The plan shall be adopted prior to initial startup of the heater. 

Maintain current SSM Plan on site. If any action taken during a startup, shutdown oconsistent with the SSM Plan, report any deviaworking days to NWCAA. 

Keep records of any startup, shutdown or occurequired maintenance performed on air pollutioequipment. Maintain records for five years of be onsite. 
BP Cherry Point Ref

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Table 5.6 - Specifically Applicable Requirements for the #2 Diesel HDS Process Ar

Permit 

Term Citation Description Monitoring/Recordkeepin

5.6.12 

General 

40 CFR 63.7550(c) (9/13/04) 

NESHAPS Subpart DDDDD -

Process Heaters

Submit semi-annual compliance report identifying source; deviations from emission limits, operating limits or work practice standards; monthly fuel use; and summary of annual performance test results. 

Submit semi-annual compliance report as indic

• July 31 for the period January 1 throu• January 31 for the period July 1 throu

5.6.13 

General 

NWCAA OAC # 892 Condition 5 (3/3/05) 

An operating and maintenance manual that contains O&M information on the ultra-low NOx burners shall be maintained on site. 

Maintain O&M manual on site. 

Group 1 Process Vent on #2 DHDS Unit 

Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected fa

5.6.14 

VOC

40 CFR 63 Subpart CC 63.643(a)(1) (6/18/95) 

Refinery MACT Process Vents

Control VOC emissions from applicable vents by using a flare for Group I process vents. 

Follow monitoring, recordkeeping and reporting Permit Terms 5.12.1 through 5.12.10 

(Flare used as control device) Follow 40 CFR 60 Appendix A Method 18 
BP Cherry Point Ref

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5-35 

5.7 Hydrogen Plant 

Table 5.6 - Specifically Applicable Requirements for the Hydrogen Plant 

Permit 

Term Citation Description Monitoring/Recordkeep

North Reforming Furnace #1 and South Reforming Furnace #2 

5.7.1 NWCAA Permit to 

Construct (6/8/70) 

This unit is required to use only fuel gas Facility configured to use only fuel gas. 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities. 

5.7.2 

SO2

(H2S) 

NWCAA RO #28 (5/15/02) which references 40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(3)(ii) and 60.106(e)(1) (10/17/00) 

NSPS Subpart J – Fuel Gas

Fuel gas limited to a composition of H2S<230 

mg/dscm (0.10 gr/dscf). Equivalent to 162 ppm H2S, 3 hour rolling average. 

Operate CEM for H2S concentration at the fu

NWCAA 367 and NWCAA Appendix A - (7/140 CFR 60 Appendices B and F. Periods of excess emissions that shall be dedefined as follows. All rolling 3-hour periods concentration of H2S as measured by the H2

under §60.105(a)(4) exceeds 162 ppmv. Report average H2S content (3 hour rolling a

Follow 40 CFR 60 Appendix A Method 11 or 
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5-36 

5.8 Calciners 

Table 5.8 - Specifically Applicable Requirements for the Calciner Area 

Permit 

Term Citation Description Monitoring/Recordkee

Calciner #1, #2, and #3 

Components in VOC Service

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.8.1 

VOC 

40 CFR 60.692-2 (11/23/88) 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) NWCAA OAC #689 for Calciner Hearths 1 & 2. (4/13/99) 

NSPS Subpart QQQ - Individual Drain 

Systems

Each applicable individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. Except where repair is technically impossible without a unit shutdown, when a broken seal, gap, crack or other problem is identified, first efforts at repair shall be made as soon as practicable, but not later than 15 calendar days after identification. 

Conduct Inspections as specified in Perm

5.8.2 

VOC 

40 CFR 60.692-2 (11/23/88), 60.692-5 (10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) NWCAA OAC #689 for Calciner Hearths 1 & 2. (4/13/99) 

NSPS Subpart QQQ - Individual Junction 

Boxes

Each affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. 

Conduct Inspections as specified in Perm
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Table 5.8 - Specifically Applicable Requirements for the Calciner Area 

Permit 

Term Citation Description Monitoring/Recordkee

5.8.3 

SO2 (H2S) 

40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(3)(ii) and 60.106(e)(1) (10/17/00) 

NSPS Subpart J – Fuel Gas

Supplemental fuel gas combusted in any of the Calciner hearths shall be limited to a composition of H2S<230 mg/dscm (0.10 

gr/dscf). Equivalent t 162 ppm H2S, 3 hour 

rolling average. 

Operate CEM for H2S concentration at the 

NWCAA 367 and NWCAA Appendix A - (and 40 CFR 60 Appendices B and F. 

Periods of excess emissions that shall be defined as follows. All rolling 3-hour perioconcentration of H2S as measured by the 

system under §60.105(a)(4) exceeds 162 

Report average H2S content (3 hour rollinFollow 40 CFR 60 Appendix A Method 11 

5.8.4 

VOC 

40 CFR 60.590-60.593 (10/17/00) which references 40 CFR 60.480-60.489 (12/14/00) NWCAA OAC #689 for Calciner Hearths 1 & 2 (4/13/99) 

NSPS Subpart GGG - Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. Applicable components include: pumps in liquid service, pressure relief valves in gas/liquid service, all sampling connection systems, all open-ended valves or lines, all valves in gas/vapor service or light liquid service, all pumps and valves in heavy liquid service, pressure relief valves in light liquid service, flanges and other connectors. 

Conduct an Equipment Leak program (LD
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Table 5.8 - Specifically Applicable Requirements for the Calciner Area 

Permit 

Term Citation Description Monitoring/Recordkee

Hearths 1 & 2 (Calciner Stack #1) 

5.8.5 

Opacity 

NWCAA OAC #660 Condition 4 (12/7/98) NWCAA OAC #689 Conditions 1.2.5, 2.2.5 & 3.2.5 (4/13/99) 

Opacity shall not exceed 20% for any 6 minute period in any one hour. 

Conduct opacity observations in accordanfrequency of opacity observations is to be by OAC #689. 

Use WDOE Method 9A and 9B 

5.8.6 

PM/PM10 

NWCAA OAC #689 Condition 1.2.3 & 2.2.3 (4/13/99) 

Maximum emissions rate of 34 tpy. Track operating parameters specified in approved monitoring plan. 

Report annual particulate emissions for ye

Monitor secondary voltage and secondary 

monthly report that shows at least two WEa secondary voltage greater than 35KV Dgreater than 300 milliamps DC. These coWDOE/NWCAA Approved Monitoring Pla

Follow 40 CFR 60 Appendix A Method 5 

5.8.7 

SO2

NWCAA OAC #689 Conditions 1.2.2, 2.2.2, & 3.2.2 (4/13/99) 

NWCAA OAC #660 Condition 3 & 6 (12/7/98) 

Emissions shall not exceed 175 tpy on a 12-month rolling average. Concentration shall not exceed 35 ppmvd corrected to 7% O2 on a 

daily average. 

Operate CEM for SO2 concentration at Ca

367 and Appendix A - “Ambient MonitoringContinuous Emission and Opacity MonitorAppendices B and F. 

Provide maximum daily average SO2 conc

O2 in monthly report. In addition, include a

average) along with monthly average of corolling average of SO2 in tons per year. Re

tons per year. 

Follow EPA Method 8 
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Table 5.8 - Specifically Applicable Requirements for the Calciner Area 

Permit 

Term Citation Description Monitoring/Recordkee

5.8.8 

NOx 

NWCAA OAC #689 Conditions 1.2.1, 2.2.1 & 3.2.1 (4/13/99) 

Emissions shall not exceed 509 tpy on a 12-month rolling average. Concentration shall not exceed 325 ppmvd corrected to 7% O2 on a 

daily average. 

Operate CEM for NOx concentration at Ca367 and Appendix A - “Ambient MonitoringContinuous Emission and Opacity MonitorAppendices B and F. 

Provide maximum daily average concentra7% O2 in monthly report. Also include ann

rolling average). 

Follow EPA Method 7 or 7A 

5.8.9 

H2SO4

NWCAA OAC #660 Condition 1 (12/7/98) 

Emissions shall not exceed 15 lbs/hr on a daily average basis. Track operating parameters specified in approved monitoring plan. 

Operate emissions control equipment and parameters in accordance with monitoring Submit a monitoring plan for approval by Ninstructions and control parameters for ema new monitoring plan each time control eqCompliance with this limit shall be determiusing 40 CFR 60 Appendix A Method 8. 

5.8.10 

H2SO4

NWCAA OAC #689 Conditions 1.2.4 and 2.2.4 (4/13/99)

Emissions shall not exceed 39 tpy on a 12-month rolling average. Concentration shall not exceed 14 ppmvd corrected to 7% O2 on a 

daily average. 

Report annual H2SO4 emissions for year. 

Follow EPA Method 8 

Hearth #3 (Calciner Stack #2) 

5.8.11 

Opacity 

PSD 89-2 Condition 2(g) (1/30/89) 

Opacity shall not exceed 20%. Report opacity readings greater than 20% 

opacity in accordance with Section 6.1 

Follow 40 CFR 60 Appendix A Method 9 

5.8.12 

PM/PM10 

PSD 89-2 Condition 2 (b) & (d) (1/30/89) 

Emissions shall not exceed 0.01 gr/dscf corrected to 7% O2 on any 60 consecutive 

minutes and 26 tpy. 

Initial performance test required. Report tons per year. Follow 40 CFR 60 Appendix A Method 5 
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Table 5.8 - Specifically Applicable Requirements for the Calciner Area 

Permit 

Term Citation Description Monitoring/Recordkee

5.8.13 

SO2

PSD 89-2 Condition 2 (a) & (c) (1/30/89) 

Emissions shall not exceed 160 ppmvd corrected to 7% O2 based on a calendar day 

average and 504 tpy. 

Operate CEM for SO2 concentration at Ca

with NWCAA 367 and NWCAA Appendix Appendices B and F. 

Provide daily average SO2 concentration 

monthly report. Include any excursions over 160 ppmvd (Report annual emission of SO2 in tons pe

-directly enforceable5.8.14 

SO2

PSD 89-2 Condition 2 (f) (1/30/89) 

SO2 scrubber efficiency shall be no less than 

90%. 

Perform an annual source test of scrubbequantify SO2 concentrations and calculate 60 Appendix A Method 8. 

-directly enforceable5.8.15 

NOx 

PSD 89-2 Condition 2 (e) (1/30/89) 

Emissions shall not exceed 509 tpy. Operate CEM for NOx concentration at C

with NWCAA 367 and Appendix A - (7/14and F 

Report emissions of NOx in tons per year Follow 40 CFR 60 Appendix A Method 7E 
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Table 5.8 - Specifically Applicable Requirements for the Calciner Area 

Permit 

Term Citation Description Monitoring/Recordkee

5.8.16 

H2SO4

PSD 95-01 Conditions I, III, & V. (3/15/95) 

NWCAA RO.#018 (6/30/98) 

Emissions shall not exceed 18.3 lb/hr or 50 mg/m3 on a 24-hour average. 

Track operating parameters specified in approved monitoring plan. Monitor secondary voltage and secondary current on WESP’s. Provide monthly report that shows at least four WESP’s in operation at all times with a secondary voltage greater than 40KV DC and a secondary current greater than 50 milliamps DC on the old cells, and 35KV DC and 300 milliamps DC on the new cell. Note: this text will need revising prior to the AOP going final in 2006 based on the new plan that should be approved by then 

Perform an annual source test using EPA testing plan 30 days prior to performing thtesting in accordance with an approved teFollow the conditions for demonstrating ccurrent WDOE/NWCAA Approved CalcinePrecipitator (#2 WESP) Monitoring Plan.
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Table 5.8 - Specifically Applicable Requirements for the Calciner Area 

Permit 

Term Citation Description Monitoring/Recordkee

Coke Handling – Silos, Baghouses, and Transfer Systems 

5.8.17 

Opacity 

NWCAA Letter Conditions 2, 3 & 4 (12/19/88) 

Coke Loadout FacilityOpacity from the baghouse stacks for the rail loading equipment shall not exceed 10%. All other points shall not exceed zero (0) percent opacity. Emissions from the two baghouses shall be less than 0.02 gr/dscf 

Follow the visual emissions monitoring mcombustion units burning gaseous fuels fo- directly enforceable - 

5.8.18 

PM 

PSD 89-2 Condition 3 (1/30/89) 

Emissions of particulate matter from the new silo, the rail car load out and the new hearth transfer tower shall not exceed 0.01 g/dscf, 21 tons per year and 20 % opacity. 

Report emissions of particulates in tons pFollow the visual emissions monitoring mcombustion units burning gaseous fuels fo- directly enforceable - 
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5.9 Light Ends (LEU)/LPG Unit 

Table 5.9 - Specifically Applicable Requirements for the Light Ends (LEU)/LPG Unit 

Permit 

Term Citation Description Monitoring/Recordkeepi

Entire LEU/LPG Area 

Components in VOC Service

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities

5.9.1 

VOC 

40 CFR 60.692-2 (11/23/88), 60.692-5 (10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Subpart QQQ - Individual Junction Boxes

Each affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. 

Conduct Inspections as specified in Permit T

5.9.2 

VOC 

40 CFR 60.590-60.593 (10/17/00) which references 40 CFR 60.480-60.489 (12/14/00) NWCAA OAC #298 (12/4/90) 

NSPS Subpart GGG - Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. Applicable components include: pumps in liquid service, pressure relief valves in gas/liquid service, all sampling connection systems, all open-ended valves or lines, all valves in gas/vapor service or light liquid service, all pumps and valves in heavy liquid service, pressure relief valves in light liquid service, flanges and other connectors. 

Conduct an Equipment Leak program (LDA
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Table 5.9 - Specifically Applicable Requirements for the Light Ends (LEU)/LPG Unit 

Permit 

Term Citation Description Monitoring/Recordkeepi

Affected Process Vent 16-V-012 

Note: The Title 40 CFR 63 General Provisions included in Section 3 apply to these affected fac

5.9.3 

VOC 

40 CFR 63.643(a)(1) (6/18/95) 

Refinery MACT - Process Vents

Control VOC emissions from applicable vents by using a flare for Group I process vents. 

Follow monitoring, recordkeeping and reporPermit Terms 5.12.1 through 5.12.10 

(Flare used as control device) 40 CFR 60 Appendix A Method 18 

LPG Compressor 22-1801 

Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected fac

5.9.4 

VOC 

40 CFR 60.482-3(b)(1) 

NSPS Subpart VV - Compressors

Each compressor shall be installed with a seal system that includes a barrier fluid system that prevents the leakage of VOCs. 

Operate seal system with a barrier fluid at a the compressor stuffing box pressure. Follow 40 CFR 60 Appendix A Method 21 
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5.10 Isomerization Unit 

Table 5.9 - Specifically Applicable Requirements for the Isomerization Unit

Permit 

Term Citation Description Monitoring, Recordkeeping 

Entire Isomerization Unit 

Components in HAP Service 

Note: The 40 CFR 60 General Provisions in Section 3 apply to these affected facilities

5.10.1 

HAP 

40 CFR 63.648(a) and (b) (8/18/98) which references 40 CFR 60.480-60.489 (12/14/00) 

Refinery MACT - Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program (LDAR) 

5.10.2 

HAP 

NWCAA OAC #814a Condition 5 (5/24/04) 

Project components shall be subject to applicable portions of 40 CFR 60 Subpart GGG and 40 CFR 63 Subpart CC. 
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Table 5.9 - Specifically Applicable Requirements for the Isomerization Unit

Permit 

Term Citation Description Monitoring, Recordkeeping 

Components in VOC Service 

Note: The 40 CFR 60 General Provisions in Section 3 apply to these affected facilities

5.10.3 

VOC 

40 CFR 60.692-2 (11/23/88) 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Subpart QQQ - Individual Drain 

Systems

Each applicable individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. 

Except where repair is technically impossible without a unit shutdown, when a broken seal, gap, crack or other problem is identified, first efforts at repair shall be made as soon as practicable, but not later than 15 calendar days after identification. 

Conduct Inspections as specified in Permit Term 

5.10.4 

VOC 

40 CFR 60.692-2 (11/23/88), 60.692-5 (10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Subpart QQQ - Individual Junction 

Boxes

Each affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. 

Conduct Inspections as specified in Permit Term 
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Table 5.9 - Specifically Applicable Requirements for the Isomerization Unit

Permit 

Term Citation Description Monitoring, Recordkeeping 

5.10.5 

VOC 

NWCAA OAC #814a Condition 6 (5/24/04) 

Leak Detection and Repair

• Leak detection and repair shall occur 

not less frequently than quarterly 

• The following leak definitions shall be in 

effect: 

o 500 ppm for block valves and 

control valves 

o 2,000 ppm for pumps 

• Facility shall record, track, repair and remonitor all leaks greater that the 

definitions above, but will have 30 days to make repairs and re-monitor leaks greater than the definitions above but less than the applicable regulatory leak definition. 

Follow procedures for an Enhanced Equipment LSection 6.3a. 

Isomerization Process Heater (IHT Heater) 

Note: The 40 CFR 60 General Provisions in Section 3 apply to these affected facilities

5.10.6 

H2S 

(SO2) 

NWCAA OAC #814a Condition 1 (5/24/04) 

PSD 02-04 Amendment 1 Condition 1 (4/20/05) 

The IHT Heater shall combust only one or a combination of the following fuels: pipeline grade natural gas and/or refinery fuel gas. 

Maintain records showing that only allowed fuels -directly enforceable- 
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Table 5.9 - Specifically Applicable Requirements for the Isomerization Unit

Permit 

Term Citation Description Monitoring, Recordkeeping 

5.10.7 

SO2

NWCAA OAC #814a Condition 3 (5/24/04) 

The H2S content of fuel gas combusted in 

the heater shall not exceed 162 ppm based on a 3-hour rolling average and 50 ppm based on a 24-hour rolling average. 

Install and operate CEM to measure H2S concen

The monitor shall meet the appropriate requiremeCFR 60 Appendices B and F, NWCAA 367 and N

Periods of excess emissions that shall be determfollows: (1) all rolling 3-hour periods during which 

as measured by the CEM exceeds 162 ppmv anduring which the average concentration of H2S as 

50 ppmv. 

 -directly enforceable5.10.8 

NOx 

PSD 02-04 Amendment 1 Conditions 2 and 7 (4/20/05) 

The IHT Heater shall not exceed 0.10 lb/MMBtu when averaged over a calendar day and 0.455 lbs/hr NOx when averaged over a calendar day. Testing of the heater shall be performed when heater is operating at a minimum of 90% of maximum load. 

Compliance shall be monitored by annual source A Method 7E. Submit test plan at least 30 days b

notification of test date at least two weeks in adva

Submit monthly report and include: monthly maxiwhich data were not collected, reasons for missinother than those allowed in Permit Term 5.10.6 wfor each occurrence of excess emissions. Maintain records onsite for five years. 

5.10.9 

CO 

PSD 02-04 Amendment 1 Condition 4 and 7 (4/20/05) 

Emissions of CO from the IHT Heater shall not exceed 70 ppmvd at 7% O2 when 

averaged a calendar day or 1.1 lbs/hr when averaged over a calendar day. Testing of the heater shall be performed when heater is operating at a minimum of 90% of maximum load. 

Compliance shall be monitored by annual source A Method 10, 10A or 10B. Submit test plan at leaand provide notification of the test date at least tw

Submit monthly report and include: monthly maxiwhich data were not collected, reasons for missinother than those allowed in Permit Term 5.10.6 wfor each occurrence of excess emissions. Maintain records onsite for five years 
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Table 5.9 - Specifically Applicable Requirements for the Isomerization Unit

Permit 

Term Citation Description Monitoring, Recordkeeping 

5.10.10 

CO 

40 CFR 63.7, 63.7500(a), 63.7515(e), 63.7520(a), (b) and (f) and 63.7560 (9/13/04) 

NESHAPS Subpart DDDDD - Process 

Heaters

CO emissions shall not exceed 400 ppmvd corrected to 3% O2 (3-run average). 

Testing shall be conducted at maximum normal operating load and consist of three 1-hour runs. 

Conduct annual performance testing between 10 preceding test using 40 CFR 60 Appendix A MethProvide results within 60 days after completion of years. 

5.10.11 

General 

(SSM Plan) 

40 CFR 63.6(e)(3), 63.10(b), 63.10(d)(5) and 63.7560 (9/13/04) 

NESHAPS Subpart DDDDD - Process 

Heaters

Develop and implement a written startup, shutdown and malfunction (SSM) plan that details procedures for operating and maintaining the source during periods of startup, shutdown and malfunction. The plan shall be adopted prior to initial startup of the heater. 

Maintain current SSM Plan on site. If any action taken during a startup, shutdown or with the SSM Plan, report any deviation for that eNWCAA. Keep records of any startup, shutdown or occurrerequired maintenance performed on air pollution Maintain records for five years of which at least tw
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Table 5.9 - Specifically Applicable Requirements for the Isomerization Unit

Permit 

Term Citation Description Monitoring, Recordkeeping 

5.10.12 

General 

40 CFR 63.7550(c) (9/13/04) 

NESHAPS Subpart DDDDD - Process 

Heaters

Submit semi-annual compliance report identifying source; deviations from emission limits, operating limits or work practice standards; monthly fuel use; and summary of annual performance test results. 

Submit semi-annual compliance report as indicat

• July 31 for the period January 1 through 

• January 31 for the period July 1 through 

5.10.13 

PM10 & 

VOC 

PSD 02-04 Amendment 1 Condition 9 (4/20/05) 

Facility shall identify “good combustion practices” for this heater. These operational practices and parameters shall be included in the O&M manual for the facility. 

Provide O&M manual within 90 days of startup oO&M manual shall be maintained, followed and 

5.10.14 

Opacity 

NWCAA OAC #814a Conditions 2 and 7 (5/24/04) 

Visible emissions shall not exceed 5% opacity for more than six minutes in any hour. 

 Monitor opacity in accordance with Section 6.1. 
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5.11 Cooling Towers and Utility Boilers 

Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility B

Permit 

Term Citation Description Monitoring/Recordk

 Entire Cooling Tower and Utility Boiler Areas 

Components in VOC Service 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.11.1 

VOC 

40 CFR 60.692-2 (11/23/88), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) NWCAA OAC #640 Condition 1 (5/1/98) 

NSPS Subpart QQQ - Individual Drain Systems

Each affected individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. Except where repair is technically impossible without a unit shutdown, when a broken seal, gap, crack or other problem is identified, first efforts at repair shall be made as soon as practicable, but not later than 15 calendar days after identification. 

Conduct Inspections as specified in Pe

5.11.2 

VOC 

40 CFR 60.692-2 (11/23/88), 60.692-5 (10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Subpart QQQ - Individual Junction Boxes

Each affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. 

Conduct Inspections as specified in Pe
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Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility B

Permit 

Term Citation Description Monitoring/Recordk

5.11.3 

VOC 

40 CFR 60.590-60.593 (10/17/00) which references 40 CFR 60.480-60.489 (12/14/00) 

NSPS Subpart GGG - Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. Applicable components include: pumps in liquid service, pressure relief valves in gas/liquid service, all sampling connection systems, all open-ended valves or lines, all valves in gas/vapor service or light liquid service, all pumps and valves in heavy liquid service, pressure relief valves in light liquid service, flanges and other connectors. 

Conduct an Equipment Leak program 

No. 2 South Cooling Tower 

5.11.4 

VOC 

NWCAA OAC (8/23/90) Install and operate a hydrocarbon monitor in 

accordance with manufacturer’s specifications per requirements set forth in un-numbered OAC dated August 23, 1990. 

Provide maintenance and calibration of monitor in accordance with manufactur
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Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility B

Permit 

Term Citation Description Monitoring/Recordk

Utility Boilers #1 and #3 

5.11.5 

SO2 (H2S) 

NWCAA RO #28 (5/15/02) which references 40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(3)(ii) and 60.106(e)(1) (10/17/00) 

NSPS Subpart J – Fuel Gas

Fuel gas limited to a composition of H2S<230 

mg/dscm (0.10 gr/dscf). Equivalent t 162 ppm H2S, 

3 hour rolling average. 

Operate CEM for H2S concentration at 

with NWCAA 367 and NWCAA AppendSubpart J and 40 CFR 60 Appendices 

Periods of excess emissions that shall defined as follows. All rolling 3-hour peconcentration of H2S as measured by t

system under §60.105(a)(4) exceeds 1

Report average H2S content (3 hour roFollow 40 CFR 60 Appendix A Method 

5.11.6 

H2S 

NWCAA OAC #298 Condition 4 (12/4/90) 

Plant fuel gas at Boilers 1 and 3 shall be limited to a H2S concentration of 165 ppm. 

Operate CEM for H2S concentration at 

accordance NWCAA 367 and NWCAA Subpart J and 40 CFR 60 Appendices 

Report average H2S content (3 hour roFollow 40 CFR 60 Appendix A Method -directly enforceableUtility Boiler #4 

Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected fa

5.11.7 

Opacity 

NWCAA OAC #351d Condition 2 (6/28/02) 

Opacity shall not exceed 5% for more than 6 minutes in any one hour period 

Report visible emissions when they ocwith Section 6.1. 
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Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility B

Permit 

Term Citation Description Monitoring/Recordk

5.11.8 

NOx 

NWCAA OAC #351d Conditions 3, 4, 5 & 9 (6/28/02) 

Emissions shall not exceed 0.07 lb/MMBtu and a monthly average of 66 tons per year. 

5.11.9 

NOx 

40 CFR 60.44b, 60.48b and 60.49b(g) (8/14/01) 

NSPS Subpart Db – Industrial Boilers Emissions shall not exceed 0.20 lbs NOx per MMBtu (based on burning fuel gas and high heat release rate). 

Operate CEM for NOx concentration awith NWCAA 367 and NWCAA AppenSubpart Db and 40 CFR 60 AppendiceReport maximum 30-day rolling averagon monthly reporting. 

Report quarterly performance including rates (lb/MMBtu); 30-day average NOx end of each steam unit generating opeemission rates for the preceding 30 stedays; average NOx emission rate (lb/operation; daily CEM drift test data; RAwhich the 30 day average NOx emissistandards specified in 60.44b including pollutant data was not obtained includdata was excluded from the calculation including reasons; “F” factor used for ctype of fuel combusted; times when NOof CEM; description of modifications tFollow 40 CFR 60 Appendix A Method 

5.11.10 

General 

NWCAA OAC #351d Condition 6 (6/28/02) 

Operation & Maintenance

Develop and maintain an Operation & Maintenance manual for all equipment that may affect pollution emissions to the atmosphere. 

Follow O&M manual as developed. Oavailable for NWCAA inspection. Excefailure to follow the O&M procedures mequipment was not properly operated 
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Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility B

Permit 

Term Citation Description Monitoring/Recordk

5.11.11 

SO2 (H2S) 

40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(3)(ii) and 60.106(e)(1) (10/17/00) NWCAA OAC #351 Rev 3 Condition 4 (10/19/99) 

NSPS Subpart J – Fuel Gas

Boiler may only burn pipeline grade natural gas or refinery fuel gas limited to a composition of H2S<230 mg/dscm (0.10 gr/dscf). Equivalent to 

162 ppm H2S, 3 hour rolling average. 

Operate CEM for H2S concentration at 

accordance NWCAA 367 and NWCAA 60 Subpart J and 40 CFR 60 AppendicPeriods of excess emissions that shall defined as follows. All rolling 3-hour peconcentration of H2S as measured by 

system under §60.105(a)(4) exceeds 1Report average H2S content (3 hour ro

reporting. Follow 40 CFR 60 Appendix A Method 

Utility Boiler #5 

Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected fa

5.11.12 

SO2

NWCAA OAC #814 Condition 1 (4/24/04) 

PSD 02-04 Amendment 1 Condition 1 (4/20/05) 

Boiler #5 shall combust only one or a combination of the following fuels: pipeline grade natural gas and/or refinery fuel gas. 

Maintain records showing that only alloboiler. 

5.11.13 

SO2

40 CFR 60.40b(c) (10/17/00) which references 40 CFR 60.104 

NSPS Subpart Db - Industrial Boilers

Affected facilities that meet the applicability requirements of Subpart J are subject to the sulfur dioxide standards under Subpart J. 

Meet requirements of Permit Term 5.1Subpart Db sulfur dioxide standards. 
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Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility B

Permit 

Term Citation Description Monitoring/Recordk

5.11.14 

SO2

NWCAA OAC #814a Condition 3 (4/24/04) 

Fuel combusted in Boiler #5 shall not exceed 162 ppm H2S based on a 3-hour rolling average or 50 

ppm H2S based on a 24-hour rolling average. The H2S content of fuel gas combusted shall be 

continuously monitored in accordance with 40 CFR 60 Subpart J, Subpart A and Appendix F. 

Operate CEM for H2S concentration at 

with NWCAA 367 and NWCAA AppendSubpart J, Subpart A and 40 CFR 60 A

Report average H2S content (3-hour ro

average) in monthly report. 

-directly enforceable5.11.15 

NOx 

PSD 02-04 Amendment 1 Conditions 3 and 7 (4/20/05) 

NOx emissions from Boiler #5 shall not exceed 10.1 lbs/hr on a calendar day average. 

Continuous compliance for NOx and O2 

accordance with NWCAA 367 and NWCCFR 60 Subpart J, Subpart A and 40 C

Submit monthly report and include: (1) (2) days for which data were not collectstatement that no fuels other than those were used; and (3) required informatioemissions.Maintain records onsite for five years. 
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Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility B

Permit 

Term Citation Description Monitoring/Recordk

5.11.16 

NOx 

40 CFR 60.44b (8/14/01) 

NSPS Subpart Db - Industrial Boilers

NOx emissions from the boiler shall not exceed 0.2lb/MMBTU. 

Operate CEM in accordance with Perm

5.11.17 

NOx 

40 CFR 60.49b(g) (7/7/04) 

NSPS Subpart Db - Industrial Boilers

Maintain the following records for each steam generating day for the boiler: 

• Calendar date • Average hourly NOx emission rates 

expressed as NO2 in lb/million Btu heat input 

• Thirty day rolling average NOx in lbs./million 

Btu heat input 

• Number of days in excess of NOx standard • Number of days when pollutant data not 

obtained 

• Times when emission data not included in 

calculation of emission average 

• Identification of "F" factor used for calculations• Identification of times pollutant concentrations 

exceeded span of monitoring system 

• Description of modifications to CEMs that 

would affect ability to comply with Performance Specification 2 or 3. 

• Results of daily drift tests and quarterly 

accuracy assessments required under Appendix F, Procedure 1 

Monitoring, recordkeeping and reporting 5.11.12 is considered an alternative reporequirement. 
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Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility B

Permit 

Term Citation Description Monitoring/Recordk

5.11.18 

CO 

PSD 02-04 Amendment 1 Conditions 5, 6 and 7 (4/20/05) 

CO emissions from Boiler #5 shall not exceed 18.1 lbs/hr on a calendar day average. Startup conditions for Boiler #5 : 

• Emission limits are relieved on startup; • Emissions of CO during startup shall be 50 

lbs/hr averaged over the startup period; 

• Emissions of CO during startup shall be 

monitored and included in the emission inventory for the year; 

• Startup periods are limited to 12 hours, 

except, if refractory work has been done during a maintenance shutdown, the period is limited to 30 hours; and 

• Startups claiming use of these provisions 

shall be limited to six per year. 

Testing of the heater shall be performminimum of 90% of maximum load. Ssource test performed. 

Continuous compliance shall be monit

accordance with NWCAA 367 and NW40 CFR 60 Appendices B and F.

Submit monthly report and include: (1) (2) days for which data were not collecstatement that no fuels other than thoswere used; and (3) required informatioemissions.

Maintain records onsite for five years. 

5.11.19 

CO 

40 CFR 63.7, 63.7500(a), 63.7505(d), 63.7510(c), 63.7525(a), 63.7535(b) and (c), 63.7555 and 63.7560. (9/13/04) 

NESHAPS Subpart DDDDD - Industrial Boilers

CO emissions shall not exceed 400 ppmvd corrected to 3% O2 (based on a 30-day rolling 

average). 

Compliance shall be demonstrated by 

maintaining a CEM according to Perfo60 Appendix B and according to the siData recorded during periods of monitrepairs, out-of-control periods, required activities, or when the boiler is operatincapacity may not be used for calculatinduring all other periods must be used tMaintain records for 5 years of which a
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Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility B

Permit 

Term Citation Description Monitoring/Recordk

5.11.20 

General 

(SSM Plan) 

40 CFR 63.6(e)(3), 63.10(b), 63.10(d)(5) and 63.7560 (9/13/04) 

NESHAPS Subpart DDDDD - Industrial Boilers

Develop and implement a written startup, shutdown and malfunction (SSM) plan that details procedures for operating and maintaining the source during periods of startup, shutdown and malfunction. The plan shall be adopted prior to initial startup of the heater. 

Maintain current SSM Plan on site. If any action taken during a startup, shuconsistent with the SSM Plan, report antwo working days to NWCAA. Keep records of any startup, shutdown including required maintenance performmonitoring equipment. Retain records 

5.11.21 

General 

40 CFR 7550(c) (9/13/04) 

NESHAPS Subpart DDDDD - Industrial Boilers

Submit semi-annual compliance report identifying source; deviations from emission limits, operating limits or work practice standards; monthly fuel use; and summary of annual performance test results. 

Submit semi-annual compliance report 

• July 31 for the period January • January 31 for the period July 

5.11.22 

PM10/VOC 

PSD 02-04 Amendment 1 Condition 10 (4/20/05) 

Facility shall identify “good combustion practices” for this boiler. These operational practices and parameters shall be included in the O&M manual for the facility. 

O&M manual shall be maintained and f

review.

5.11.23 

Opacity 

NWCAA OAC #814a Condition 2 and 7 (4/24/04) 

Visible emissions shall not exceed 5% opacity for more than six minutes in any hour. 

Monitor opacity in accordance with SecFollow 40 CFR 60 Appendix A Method 
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5.12 Flares 

Table 5.12 - Specifically Applicable Requirements for the Flares Area 

Permit 

Term Citation Description Monitoring, Recordkeep

High and Low Pressure Flares 

Note: 40 CFR 60 and 63 General Provisions included in Section 3 apply to these affected fac

5.12.1 

HAP 

40 CFR 63.11(b)(1) (10/17/00) and 40 CFR 63.645(a) (8/18/98) which references 63.116 (1/22/01) 40 CFR 63.648 (8/18/98) which references 40 CFR 60.482-10 (12/14/00) which references 60.18(d) (10/17/00) 

Refinery MACT - FlaresSources using flares to comply with Refinery MACT equipment leak provisions shall monitor flares to assure they are maintained and operated properly to reduce the emissions of organic HAPS from miscellaneous process vents by 98%w or to 20 ppmv. 

5.12.2 

HAP 

40 CFR 63.11(b)(3) (10/17/00) 40 CFR 63.648 (8/18/98) which references 40 CFR 60 Subpart VV which includes 60.485(g)(2) (10/17/00) and 60.482) (12/14/00) and which references 60.18 (10/17/00) 

Refinery MACT - Flares 

Flares shall be operated at all times when emissions may be vented to them. 

Thermocouples, or any other equivalenof a flame, shall continuously monitor eaflame and the data recorded electronicaaverages. 

In addition, video cameras and flow meoperators in reducing any visual emissioAny exceedance of the applicable opacthe absence of a pilot flame shall be repupset within 12-hours of the event in acMaintain hourly records of whether the moperating and whether a pilot flame was Record and report the presence of a flaperiod of compliance determination - peCFR 63.654 Record the times and durations of all peflare are absent or the monitor is not op
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Table 5.12 - Specifically Applicable Requirements for the Flares Area 

Permit 

Term Citation Description Monitoring, Recordkeep

5.12.3 

HAP 

40 CFR 63.11(b)(5) (10/17/00) 40 CFR 63.644(a)(2) (8/18/98) and 63.648 (8/18/98) which references 40 CFR 60.485(g)(2) (10/17/00) which references 60.18(c)(2) (10/17/00) 

Refinery MACT - FlaresFlares shall be operated with a flame present at all times. 

Use a thermocouple or other equivalent device capable of continuously detecting the presence of a pilot flame. 

Thermocouples, or any other equivalen

of a flame, shall continuously monitor eaflame and the data recorded electronicaaverages. 

Record the times and durations of all peflare are absent or the monitor is not opabsence of a pilot flame shall be reportewithin 12-hours of the event in accordanMaintain hourly records of whether the moperating and whether a pilot flame was Record and report the presence of a flaperiod of compliance determination - peCFR 63.654.

5.12.4 

Opacity 

40 CFR 63.11(b)(4) (10/17/00) 40 CFR 63.642(d) (6/12/96), and 63.648 (8/18/98) which references 40 CFR 60 Subpart VV which includes 60.485(g)(1) (10/17/00) and which references 60.18(c)(1) (10/17/00) 

Refinery MACT - FlaresFlares shall be designed for and operated with no visible emissions, except for periods not to exceed a total of 5 minutes during any 2 consecutive hours. 

Visual opacity shall be monitored in accIn addition, video cameras and flow meoperators in reducing any visual emissioAny exceedance of the applicable opacNWCAA as an upset within 12-hours of NWCAA 340. Follow 40 CFR 60 Appendix A Method 9 
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Table 5.12 - Specifically Applicable Requirements for the Flares Area 

Permit 

Term Citation Description Monitoring, Recordkeep

5.12.5 

SO2

NWCAA 462 (3/13/97) WAC 173-400-040 (6) 

(8/15/01) NWCAA OAC #890a  Condition 8  (10/5/05) 

SO2 emissions shall not exceed 

1000 ppm (corrected to 7% O2) averaged over a 60 minute period. 

Coker blowdown vapors shall be routed wet gas compressor #12-1801. Complidemonstrated by: 

a) Continuously monitoring and reco

remotely activated valve #HV-331 coker wet gas recovery compress

b) Following written standard operat

coker blowdown vapors are routeexcept; 

• When the intake pressure 

near its suction pressure, 

• During a process upset o

c) Record each process upset or ma

blowdown vapors are not recoverdate, duration and description of ethe resulting SO2 emissions that o

recovered.

5.12.6 

General 

40 CFR 63.644(e) (8/18/98) and 63.654(g)(6)(B) (8/18/98)

Refinery MACT - FlaresOperate flares consistent with required operating parameters and/or procedures. 

Thermocouples, or any other equivalenof a flame, shall continuously monitor eaflame and the data recorded electronicaaverages. 

Periods of excess emissions shall be idExcess emissions are defined as an opof a flare are absent. 

5.12.7 

General 

40 CFR 63.644(a) (8/18/98), Refinery MACT - Control Devices 

used for Process Vents

Monitoring equipment shall be installed, calibrated, maintained, and operated according to manufacturer’s specifications or other written procedures. 

A device capable of continuously monitorequired. 
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Table 5.12 - Specifically Applicable Requirements for the Flares Area 

Permit 

Term Citation Description Monitoring, Recordkeep

5.12.8 

General 

40 CFR 63.11(b)(7)(iii) (10/17/00) 40 CFR 63.648 (8/18/98) which references 40 CFR 60 Subpart VV which includes 60.485(g)(3) and which references 60.18 (c)(4)(iii) (5/4/98) 

Refinery MACT – Flare Exit 

Velocity 

The exit velocity of the flares shall not exceed the lesser of Vmax, as determined in the method specified in 63.11(b)(7)(iii), but less than 122 m/sec (400 ft/sec) are allowed. 

Inspect the flare flow meters annually precommendation. Keep records of all in- directly enforceable -

5.12.9 

General 

40 CFR 63.11(b)(6) (10/17/00) 40 CFR 63.648 (8/18/98) which references 40 CFR 60 Subpart VV which includes 60.485(g)(4) (10/17/00) and which references 60.18(c)(3)(ii) (10/17/00) 

Refinery MACT – Flared Gas 

Heating Value 

The net heating value of the gas being combusted shall be 11.2 MJ/scm (300 Btu/scf) or greater for steam or air-assisted flares. The net heating value shall be calculated by the equation in 63.11(b)(6), which is identical to the equations in 60.18(f)(3) and 60.485(g)(4) 

Inspect the flare flow meters annually precommendation. Keep records of all in

40 CFR 63.11 (b)(6)(ii) referencing 40 CFR 60 Appendix A Method 18 - directly enforceable 
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Table 5.12 - Specifically Applicable Requirements for the Flares Area 

Permit 

Term Citation Description Monitoring, Recordkeep

5.12.10 

Opacity/ 

HAP 

40 CFR 63.654(e)-(h) (8/18/98) 

Refinery MACT – Flares

Conduct reporting and recordkeeping in accordance with the provisions of Refinery MACT. 

Report exceedances/deviation on periooperation of a flare in the absence of a the opacity standard and anytime that thgeneral control requirements of 63.11(b

Record and report in a Periodic Report does not meet the general control devicCFR 63.11(b) and shall include: Identificmeet the general requirements specified reasons why the flare did not meet thesPeriods that constitute a startup, shutdoterms are defined in 40 CFR 63.641 and reporting. Please note that the recordinexempted. 

Flare Gas Recovery and Associated Piping Systems

Note: 40 CFR 60 and 40 CFR 63 General Provisions included in Section 3 apply to these affected fac

Components in VOC Service 

5.12.11 

VOC

40 CFR 60.590-60.593 (10/17/00) which references 40 CFR 60.480-60.489 (12/14/00)

NSPS Subpart GGG - Equipment 

Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program (L6.2 

Applicable components include: pumps valves in gas/liquid service, all samplinended valves or lines, all valves in gas/vservice, all pumps and valves in heavy valves in light liquid service, flanges and 
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Table 5.12 - Specifically Applicable Requirements for the Flares Area 

Permit 

Term Citation Description Monitoring, Recordkeep

Components in HAP Service 

5.12.12 

HAP 

40 CFR 63.648(a) and (b) (8/18/98) which references 40 CFR 60.480-60.489 (12/14/00) 

Refinery MACT - Equipment 

Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program (L6.2 

Affected Process Vents 29-V-040 & 29-V-044 

Note: The Title 40 CFR 63 General Provisions included in Section 3 apply to these affected faciliti

5.12.13 

HAP 

40 CFR 63.643(a)(1) (6/18/95) 

Refinery MACT - Process Vents

Control HAP emissions from applicable vents by using a flare for Group I process vents. 

Follow monitoring, recordkeeping and rin permit Terms 5.12.1 through 5.12.10 (Flare used as control device) Follow 40 CFR 60 Appendix A Method 
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Table 5.12 - Specifically Applicable Requirements for the Flares Area 

Permit 

Term Citation Description Monitoring, Recordkeep

Flare Gas Recovery Compressors 28-1803 and 28-1804 

Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected fa

5.12.14 

VOC 

40 CFR 60.592(a) (10/17/00) which references 40 CFR 60.482-3(b)(1) (12/14/00) 

NSPS Subpart GGG -

Compressors

In accordance with subpart VV, each compressor shall be installed with a seal system that includes a barrier fluid system that prevents the leakage of VOC to the atmosphere. 

Each seal system shall be operated with a barrier fluid pressure that is greater than the compressor stuffing box pressure. 

Each barrier fluid system shall be equipdetect failure of the seal system, barrier sensor shall be equipped with an audibwhen the sensor indicates a failure or thor both. Follow 40 CFR 60 Appendix A Method 2
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5.13 Sulfur Complex 

Table 5.13 - Specifically Applicable Requirements for the Sulfur Complex 

Permit Term Citation Description Monitoring/Recordkee

Entire Sulfur Complex 

Note: The Title 40 CFR 60 and 40 CFR 63 General Provisions included in Section 3 app

5.13.1 

 HAP 

40 CFR 63.1574-63.1576 (2/9/05) 

Refinery MACT II - General 

Prepare and implement an operation, maintenance and monitoring plan (OMMP) for each control system. 

Develop and submit an OMMP to NWCwithin 120 days of initial startup. SubmiNWCAA for approval. Keep records to demonstrate that proceMaintain records available for review fo

5.13.2 

HAP 

40 CFR 63.1568(a)(1) (2/9/05) which references 40 CFR 60.104(a)(2) (10/17/00) 

Refinery MACT II – Organic HAP Emissions

Meet a SO2 limit of 250 ppmvd at 0% 

excess air for any discharge from a Claus sulfur recovery unit. 

Provide continuous emission monitoring 

the hourly average concentration of SO

system must include an oxygen monitoexcess air. 

5.13.3 

HAP

40 CFR 63.1569(c)(1) (2/9/05) which references 40 CFR 63.11(b) and Tables 36 and 39 to Subpart UUU (2/9/05) 

Refinery MACT II – Work Practice 

Standards for HAP Emissions from Bypass LinesDemonstrate continuous compliance with the work practice standards by using: Option 2: Car-seal or lock and key device on mechanism that prevents flow through bypass control device 

The facility has elected to use a car-seavalves are closed and cannot be reopendevice. The car-seal or lock shall be visbasis to ensure there is no flow in the bKeep records of bypass line valve inspemaintained in the closed position and w
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Table 5.13 - Specifically Applicable Requirements for the Sulfur Complex 

Permit Term Citation Description Monitoring/Recordkee

Sulfur Recovery Units 

5.13.4 

SO2

NWCAA OAC #890a Condition 4 (10/26/05) NWCAA 367 and Appendix A (7/13/05) 

Total tons of SO2 emitted from the Sulfur 

Recovery Unit shall not exceed 135 tons based on each consecutive 12-month rolling period. 

Operate and maintain CEM to measure 

Monitors shall meet the appropriate specAppendices B and F, NWCAA Section 3(7/14/05). 

Provide the most recent 12-month rolling 

5.13.5 

SO2

NWCAA OAC #890a Condition 13 (10/26/05) 

Emissions from the elemental sulfur storage pits shall be controlled through a closed vent system capable of meeting 250 ppmvd corrected to 0% O2 based on 

a 12-hour rolling average and 1500 ppmvd based on a 1-hour average. 

Operate CEM for SO2 and O2 concentraexcess air) at the tail gas unit stack in ac

NWCAA Appendix A - (7/14/05), 40 CFR Appendices B and F. During periods when the #1 Tail Gas Incmaintenance and emissions from the sulonger routed to the CEM on the incineramonitoring plan (AMP) shall be utilized. 

• Once per shift, measure and reco

emissions with a colorimetric dete

SO2 concentrations in the vented 

• Once per shift, check and record t

north and south sulfur pits and the through the system. These pressumonitored with readouts available 

• Report total mass emissions of H2

reports during periods when this A

Affected Process Vents 17-V-047, 17-V-067, & 17-V-074

Note: The Title 40 CFR 63 General Provisions included in Section 3 apply. 
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Table 5.13 - Specifically Applicable Requirements for the Sulfur Complex 

Permit Term Citation Description Monitoring/Recordkee

5.13.6 

VOC 

40 CFR 63.643(a)(1) (6/18/95) 

Refinery MACT - Process Vents

Control HAP emissions from applicable vents by using a flare for Group I process vents. 

Follow monitoring, recordkeeping and rin permit Terms 5.11.1 through 5.11.10 

(Flare used as control device) Follow 40 CFR 60 Appendix A Method 

No. 1 and 2 Tail Gas Units (TGU) 

5.13.7 

SO2 (H2S) 

40 CFR 60.104(a)(1), 60.105(a)(4), 60.105(e)(3)(ii) and 60.106(e)(1) (10/17/00) 

NSPS Subpart J – Fuel Gas

Supplemental fuel gas combusted in the No. 1 Tail Gas Unit shall be limited to a composition of H2S<230 mg/dscm 

(0.10 gr/dscf). Equivalent t 162 ppm H2S, 3 hour rolling average. 

Operate CEM for H2S concentration at t

with NWCAA 367 and NWCAA AppendSubpart J and 40 CFR 60 Appendices B 

Periods of excess emissions that shall bdefined as follows. All rolling 3-hour perconcentration of H2S as measured by th

system under §60.105(a)(4) exceeds 16

Report average H2S content (3 hour rol

reporting. 

Follow 40 CFR 60 Appendix A Method 

5.13.8 

General 

NWCAA OAC #890a Condition 1 (10/26/05) 

Supplemental fuel gas combusted in the No. 2 Tail Gas Unit shall be limited to pipeline grade natural gas. 

Keep records of fuel usage. 

-directly enforceable5.13.9 

General 

NWCAA OAC #890a Condition 6 (10/26/05) 40 CFR 63.1574(f) (2/9/05) 

Prepare an Operation, Maintenance and Monitoring Plan (OMMP) according to the requirements of 40 CFR 63.1574(f) and operate at all times according to the procedures in the plan. 

Submit plan to NWCAA for review and astartup. Submit any revisions to OMMP 
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Table 5.13 - Specifically Applicable Requirements for the Sulfur Complex 

Permit Term Citation Description Monitoring/Recordkee

5.13.10 

General 

NWCAA OAC #890a Condition 10 (10/26/05) which references 40 CFR 63 Subpart UUU §63.1569 (4/11/02) 

Any lines that allow a bypass of sulfur bearing compounds normally emitted from the No. 1 and No. 2 TGU stacks shall be monitored for the presence of flow. 

Report any instances of flow bypass in a340 or 341. These reportable events shshutdown or upset condition. 

5.13.11 

General 

NWCAA OAC #890a Condition 9 (10/25/05) 

The vent gas from the sour water stripper tanks must continue to be routed upstream of the TGU incinerator.

Report any instances when vent gas goe

5.13.12 

Opacity 

NWCAA OAC #890a Condition 2 (10/26/05) 

Visual emissions from No. 1 and No. 2 TGU Stacks shall not exceed 10% opacity for more than three minutes in any one hour period. 

Follow the visual emissions monitoring mcombustion units burning gaseous fuels - directly enforceable - 

5.13.13 

SO2

NWCAA OAC #890a Condition 5a (10/26/05) 

NWCAA 367 and Appendix A (7/13/05) 

SO2 emissions from No. 2 TGU Stack 

shall not exceed 24.0 lbs/hr. 

Conduct initial performance test within 6production rate, but no later than 180 dabe done at or above 80% of full capacityFollow test methods provided in 40 CFR 

• SO2 – Method 6C or 8 

5.13.14 

NOx 

NWCAA OAC #890a Condition 5b (10/26/05) 

NWCAA 367 and Appendix A (7/13/05) 

NOx emissions from No. 2 TGU Stack shall not exceed 2.5 lbs/hr. 

• NOx – Method 7E 

The source test shall be conducted in ac367 NWCAA Appendix A - (7/14/05) . Any proposed alternative test methods sthe NWCAA. 
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Table 5.13 - Specifically Applicable Requirements for the Sulfur Complex 

Permit Term Citation Description Monitoring/Recordkee

5.13.15 

CO 

NWCAA OAC #890a Condition 5c (10/26/05) 

NWCAA 367 and Appendix A (7/13/05) 

CO emissions from No. 2 TGU Stack shall not exceed 3.9 lbs/hr. 

Conduct initial performance test within 6production rate, but no later than 180 dabe done at or above 80% of full capacit

Follow test methods provided in 40 CF

• CO – 40 CFR 60 Appendix A 

5.13.16 

H2SO4

NWCAA OAC #890a Condition 5d (10/26/05) 

NWCAA 367 and Appendix A (7/14/05) 

H2SO4 emissions from No. 2 TGU 

Stack shall not exceed 1.23 lbs/hr. 

• H2SO4 – 40 CFR 60 Appendix 

• H2 S - 40 CFR 60 Appendix A 

The source test shall be conducted in a367 and Appendix A – Ambient MonitorContinuous Emission and Opacity Mon

5.13.17 

H2S 

NWCAA OAC #890a Condition 5e (10/26/05) 

NWCAA 367 and Appendix A (7/13/05) 

H2S emissions from No. 2 TGU Stack 

shall not exceed 0.43 lbs/hr. 

Any proposed alternative test methods the NWCAA. 

5.13.18 

SO2

NWCAA OAC #890a Condition 3 (10/26/05) which references 40 CFR 60.104(2)(i) (10/17/00) 

In accordance with NSPS Subpart J, SO2 emissions from the TGU stacks 

shall not exceed 250 ppm dry basis corrected to 0% O2 based on a 12-hour 

rolling average or 1500 ppm dry basis corrected to 0% O2 based on a 1-hour average. 

Compliance shall be based on a CEM iand operated in each TGU stack. Each appropriate specifications of 40 CFR 60 Section 367 NWCAA Appendix A - (7/1Report SO2 emission data in monthly re
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5.14 Wastewater Plant and Sewer System 

Wastewater Plant and Sewer System

This part of this section presents the MR&Rs for individual drain systems together with ancillary dow

oil-water separators, down to and including the secondary oil-water separator, for those areas not a

under 40 CFR 61.340 (Subpart FF). This section covers the monitoring programs for individual drai

to Refinery MACT (HAP) and 40 CFR 60 Subpart QQQ standards (VOC). Refineries in compliance 

FF are considered to be in compliance with the Refinery MACT. Section 5.14 presents the MR&Rs wastewater containers, tankage, and oil/water separators. Storage Tanks Handling Wastewater

Internal Floating Roof Tanks – 320, 321, 322 and 323 
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Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring/Recordkeep

Entire Wastewater Treatment Plant, Sewer System and Storage Tanks 

Components in VOC Service not Group 1 Wastewater Streams 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.14.1 40 CFR 60 Subpart 

QQQ 60.692-2(a) (11/23/88) 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Individual Drain Systems

Each applicable individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. Except where repair is technically impossible without a unit shutdown, when a broken seal, gap, crack or other problem is identified, first efforts at repair shall be made as soon as practicable, but not later than 15 calendar days after identification. Inactive Service Individual Drain Systems

Each applicable drain out of active service shall be checked visually or physical inspection weekly. Water levels will be maintained and repairs made, when practical but no later than 24 hours after detection. An alternative for inactive drains is to install tightly sealed caps or plugs. 

Each active service drain shall be inspecteand monthly for indication of low water levwould reduce the effectiveness of the wate

Whenever low water levels are identified wefforts to repair shall be made as soon as hours after detection. A delay of repair is arepair is technically impossible without a coprocess unit shutdown. If a delay of repair made before the end of the next refinery oEach inactive service drain shall be inspecand weekly for indication of low water levereduce the effectiveness of the water seal result in VOC emissions. If a cap or plug iservice drains, each cap and plug shall be ensure caps or plugs are in place and propFor each individual drain record the locatioshall be recorded for each drain when the breached per 40 CFR 60.697. Records shyears. 
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Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring/Recordkeep

5.14.2 

VOC 

40 CFR 60 Subpart QQQ 60.692-2(b) (11/23/88), 60.692-5 (10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Individual Junction Boxes

Each affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. Junction box covers shall have a tight seal around the edge and shall be kept in place at all times except during inspection and maintenance.

Perform semi-annual visual inspections to tight seal is maintained around the edge. When a defect is discovered the first attemsoon as practicable but not later than 15 dutilized. A delay of repair is allowed per 40 technically impossible without a complete shutdown. If a delay of repair is utilized, ththe end of the next refinery or process unit Report the date and type of defects found corrective action taken on the semi-annua60.697. Records shall be retained for at le

Components in HAP Service (Group 1 Wastewater Streams) 

Note: The Title 40 CFR 63 General Provisions included in Section 3 apply. 

5.14.3 

HAP

40 CFR 63 Subpart CC 63.648(a) and (b) (8/18/98) which references 40 CFR 60.480-60.489 (12/14/00)

Refinery MACT Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program (LDAFollow 40 CFR 60 Appendix A Method 21 
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Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring/Recordkeep

5.14.4 

HAP 

40 CFR 63 Subpart CC 63.647(a) which references 40 CFR 61.346(b)(1) (1/7/93) which references 40 CFR 61.349 (10/17/00) which references 40 CFR 61.355(h) (10/17/00) 40 CFR 63.654(a) which references 40 CFR 61.356 and 61.357 (10/17/00). 

Control of Emissions from Individual Drain 

Systems

Install, operate, and maintain on each applicable drain system opening a cover and closed-vent system that routes all organic vapors vented from the drain system to a control 

device that meets the requirements of 40 CFR 61.349. 

The closed vent system shall be designed to operate with no detectable emissions as indicated by an instrument reading less that 500 ppmv above background. 

Each cover seal, access hatch and all othevisual inspection quarterly to ensure that nthat access hatches and other openings arWhen a broken seal or gasket or other prodetectable emissions are measured, first aas soon as practicable but not later than 5 

Repairs shall be completed within 15 calenallowed per 40 CFR 60.692-6 if repair is te

complete or partial refinery or process unit utilized, the repair shall be made before thprocess unit shutdown. Records shall be maintained at the facility 
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5-75 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring/Recordkeep

5.14.5 

HAP 

40 CFR 63 Subpart CC 63.647(a) which references 40 CFR 61.346(b) (1/7/93) which references 40 CFR 61.349(a)(1)(iii) (10/17/00) which references 40 CFR 61.355(h) (10/17/00) 40 CFR 63.654(a) which references 40 CFR 61.356 and 61.357 (10/17/00). 

Applicable Gauging and Sampling Devices

Shall be gas-tight except when gauging or sampling is taking place. 

Design to be gas-tight. Maintain records odevice locations and identifications. Submit a quarterly certification that all insp

accordance with 40 CFR 61 Subpart FF. Retain all records for five years. Follow 40 CFR 60 Appendix A Method 21 
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5-76 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring/Recordkeep

5.14.6 

HAP

40 CFR 63 Subpart CC 63.647(a) which references 40 CFR 61.346 (b)(1) and 61.355(h) (10/17/00) 40 CFR 63.654(a) which references 40 CFR 61.356 and 61.357 (10/17/00). 

Covers and Openings – System operated at a 

pressure greater than atmospheric

Applicable covers and openings (e.g., access hatches, sampling ports) shall be designed to operate with no detectable emissions of less than 500 ppmv above background. Each opening shall be maintained in a closed, seal position (e.g., covered and gasketed) at all times waste is in the drain system except when necessary for inspection, waste sampling, maintenance and/or repair. 

Initial testing followed by at least once a yeAppendix A Method 21 from 40 CFR 60 Ap

The detection equipment shall meet the pe21 and calibrated before each use on each procedures described in 40 CFR 60 Appengases shall be: 

• Zero air • A mixture of methane or n-hexane 

approximately 10,000 ppm methan

The following monitoring procedures shall 

• Background levels determined usi

Method 21, 

• Probe to traverse around the poten

possible per 40 CFR 60 Appendix 

• The arithmetic difference between 

indicated by the instrument and thto the 500 ppmv compliance limit. 

Records for visual inspections shall include management unit and control equipment, land description and date of corrective actioRecords for each non-detectable emission background level maximum concentration leak interface, waste management unit and and description and date of corrective actioSubmit a quarterly certification that all inspaccordance with 40 CFR 61 Subpart FF. Retain all records for five years. Follow 40 CFR 60 Appendix A Method 21 
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5-77 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring/Recordkeep

5.14.7 

HAP 

40 CFR 63 Subpart CC 63.647(a) which references 40 CFR 61.346 (b)(1) 61.346 (b)(4), 61.346 (b)(5) (1/7/93), 61.355(h) (10/17/00) 40 CFR 61.350 (10/17/00) 40 CFR 63.654(a) which references 40 CFR 61.356(g) and 61.357(d)(6) (10/17/00). 

Alternative for Individual Drains

An alternative is for each applicable drain to be equipped with water seal controls or a tightly sealed cap. 

Each active service drain shall be inspecteand quarterly for indication of low water levwould reduce the effectiveness of the wateEach drain using a tight seal or plug shall bquarterly thereafter to ensure caps and pluinstalled. When a broken seal, gap, crack or other pat repair shall be made as soon as practicadays after identification. Records for visual inspections shall include management unit and control equipment, land description and date of corrective actioRecords for each non-detectable emission background level maximum concentration leak interface, waste management unit and and description and date of corrective actioSubmit a quarterly certification that all insp

accordance with 40 CFR 61 Subpart FF. Retain all records for five years. Follow 40 CFR 60 Appendix A Method 21 
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5-78 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring/Recordkeep

15.14.8 

HAP 

40 CFR 63 Subpart CC 63.647(a) (c) which references 40 CFR 61.346 (b)(5) (1/7/93). 40 CFR 61.356 and 61.357 (10/17/00) 

Repairs

Except as provided in Permit Term 15.14.9, first efforts at repair applicable equipment and components shall be made as soon as practical, but not later than 15 calendar days after identification. 

Records for visual inspections shall include management unit and control equipment, land description and date of corrective actioRetain all records for five years. 

15.14.9 

HAP 

40 CFR 63 Subpart CC 63.646(a)(3) & (b)(5) (1/7/93) which references 40 61.350 (3/7/90). 40 CFR 61.356 and 61.357 (10/17/00) 

Delay of Repairs

Delay of repair applicable equipment and components and facilities subject to 40 CFR 61 Subpart FF will be allowed if the repair is technically impossible without a complete or partial facility or unit shutdown. 

Repairs shall occur before the end of the nwhen the repair is technically impossible wfacility or unit shutdown. Retain all records for five years. 
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5-79 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring, Recordkeepin

Benzene Waste Management Practices 

Note: 40 CFR 61 and 40 CFR 63 General Provisions included in Section 3 apply to these affected 

5.14.10 

HAP 

40 CFR Subpart CC 63.647 (8/18/95), which references 40 CFR 61.342 (c)(3)(ii) (10/17/00) and 61.355 (j) (10/17/00). Also, 40 CFR 61 Subpart FF directly 

Written Exemption Report The 

benzene waste streams from these individual drain systems shall meet the requirements of 40 CFR 61 Subpart FF through written certification on an annual basis that they meet the exemption requirement. 

Report annually to the NWCAA that the wast

drain systems are part of the total annual benexceed 2.0 Mg/yr, as per 40 CFR 61.342(c)(3

5.14.11 

HAP/ 

Benzene 

40 CFR 63 Subpart CC 63.654(a) (8/18/98) which references 40 CFR 61.356(e) and (i) (10/17/00) 40 CFR 61 Subpart FF 61.340--61.355 directly (10/17/00) 

Management and Treatment Records

Keep records documenting that the benzene waste stream is being managed and treated in accordance with its design and operating specifications 

Maintain records for the life of the unit certifyor wastewater treatment system unit is desigdocumented performance level when the wathe highest waste stream flow rate and benzeoccur. Maintain the records of the design anunit startups and shutdowns and any periods designed. 
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5-80 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring, Recordkeepin

5.14.12 

HAP/ 

Benzene 

40 CFR Subpart CC 63.647 (8/18/95), which references 40 CFR 61.348(d)(4) (10/17/00) and Subpart CC 63.654(a) (8/18/98), which references 40 CFR 61.356(a), (e), and (I) (10/17/00). Also, Title 40 CFR Subpart FF 61.340 through 61.358 applies directly. 

Operate treatment process in a manner consistent with the minimum or maximum (as appropriate) permitted concentration or operating parameter value. 

Maintain records that the treatment process a

treated by a means or to a level that is in comNational Pollutant Discharge Emission Stand40 CFR 419. Maintain records for the life of the unit certifyor wastewater treatment system unit is desigdocumented performance level when the wathe highest waste stream flow rate and benzeoccur. Maintain the complete design analysiper 40 CFR 61.356(e). 

• Records shall be maintained in a rea

for not less than two years. 

• Note: Under WAC 173-401-615(2), 

years. 

• Maintain documentation that include

o Date of startup and shutdow

o Periods when the unit is not 
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5-81 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring, Recordkeepin

API Oil Water Separator 

Note: 40 CFR 61 and 40 CFR 63 General Provisions included in Section 3 apply to these affected 

5.14.13 

HAP/ 

Benzene 

40 CFR 63 Subpart CC 63.647 (8/18/95) which references 40 CFR 61.347 (1/7/93), 61.350 (3/7/90) and 61.355(h) (10/17/00) 40 CFR 63 Subpart CC 63.654(a) (10/17/00), which references 40 CFR 61.356(d), (g) and (h) (10/17/00) and 61.357(d)(6) and (d)(8) (10/17/00) 40 CFR 61 Subpart FF 61.340 - 61.358 directly (10/17/00) 

Oil Water Separators - Fixed Roof

With the exception of bays equipped with floating roof covers, each oil water separator system shall be covered and vapors routed to a control device. The system shall operate with no detectable emissions equal to or greater than 500 ppm above background as measured by 40 CFR 60 Appendix A Method 21. Each opening is to remain closed or sealed except during waste sampling, inspection or maintenance. Except where repair is technically impossible without a unit shutdown, a first attempt at repair shall be made as soon as practicable, but not later than 15 calendar days after identifying a problem with a seal or gasket or when a leak is detected using 40 CFR 60 Appendix A Method 21. When repair is delayed for a shutdown, repair shall be made before end of the next unit shutdown. 

Perform quarterly visual inspections of each all other openings to ensure there are no craare properly closed and gasketed. If defects as soon as practical and in no case later than unless repair requires a unit shutdown. SubmNWCAA certifying that required inspections hAnnually, monitor for leaks using 40 CFR 60 Instrument calibration gases shall be zero aiapproximately 10,000 ppm methane or n-hexthat includes results of inspections and leak tleak above background or where or a probleor other problem occurred. The report shall intaken to correct each problem and the date tMaintain records of all leak testing and inspeengineering design documentation for the life Maintain records for each visual inspection thcould result in benzene emissions. Follow 40 CFR 60 Appendix A Method 21 
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5-82 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring, Recordkeepin

API Oil Water Separator Effluent Sump - Floating Roof 

Note: 40 CFR 60, 40 CFR 61 and 40 CFR 63 General Provisions included in Section 3 apply to these af

5.14.14 

HAP/ 

Benzene 

40 CFR 63 Subpart CC 63.647 (8/18/95) which references 40 CFR 61.356(l) (10/17/00), 61.357(g) (10/17/00) and 61.352 (1/7/93) which references 40 CFR 60.693-2(a) (8/18/95), 60.692-6 (8/18/95), and 60.696(d) (8/18/95) 40 CFR Subpart QQQ 60.693-2(c) 40 CFR Subpart FF 61.350 

Oil Water Separators - Floating Roof 

The floating roof shall have primary and secondary seals. Primary seal gaps shall not to exceed 1.5 inches at any one point or 3.2 square inches per foot of total gap area. Secondary seal gaps shall not exceed 0.5 inches at any one point or 0.32 square inches per foot of total gap area. Access doors and other openings shall be proper gasketing and sealing. Emergency roof drain fabric shall cover 90% of the drain area. Defects in gaps or seals shall be repaired within 30 days of discovery (Delay of repair of facilities subject to 40 CFR Subpart FF 61.350 are allowed if the facilities cannot be repaired without a complete or partial shutdown of the facility. Repairs must be made before the end of the next facility shutdown.) 

Measure the secondary seal gaps annually agaps at least once every five years. Gaps shall be measured using various sized 1/8” diameter probe passes freely between thGap areas shall be calculated by adding the location for the primary seal and the secondathe sum for each seal by the nominal perimeConduct quarterly visual inspections of accesand other openings. Defects in gaps, hatch covers, gaskets, seals repaired within 30 days of discovery unless rwithout a complete or partial refinery or procerepair is utilized, repair shall be made before process unit shutdown. Maintain records of visual inspections and gaof inspection and/or gap measurement and tthe records shall include the date of the repaSubmit quarterly reports that identify all seal found to exceed the prescribed limits. Follow 40 CFR 60 Appendix A Method 21 
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5-83 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring, Recordkeepin

Closed Vent Systems 

Note: 40 CFR 61 and 40 CFR 63 General Provisions included in Section 3 apply to these affected 

5.14.15 

HAP/ 

Benzene 

40 CFR 63 Subpart CC 63.647 (8/18/95) which references 40 CFR 61.349 (10/17/00), 61.354(f) (10/17/00), 61.355(h) (10/17/00) and 61.350 (3/7/90) 40 CFR 63 Subpart CC 63.654(a) (8/18/98) which references 40 CFR 61.356(f)(1), (g), and (h) (10/17/00), and 61.357(d)(6) and (d)(8) (10/17/00) 40 CFR Subpart FF 61.340 - 61.358 

Closed Vent Systems

Design the system to operate with no detectable emissions. If a bypass vent is used it shall be closed and secured during normal operations and inspected monthly. Inspect quarterly and monitor for leaks annually. First attempt at repair shall be made as soon as practical but in no case later than 5 days after detection. Repair shall be completed within 15 days, unless a delay of repair is required by a unit shutdown. 

Visually inspect quarterly, or monthly, if bypa

monitor for leaks annually using 40 CFR 60 Aleak definition of 500 ppm above backgroundshall be zero air (<10 ppm HC) and approximn-hexane. Keep records on the location and date of defand/or leaks found during instrument monitodate and description of corrective action takeequipment, certification that the system was highest estimated load rates. Submit quarterly certifications that required inSubmit annual reports summarizing the resuinstrument monitoring. Follow 40 CFR 60 Appendix A Method 21 -directly enforceable- 
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5-84 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring, Recordkeepin

Carbon Adsorption Control Devices 

Note: 40 CFR 61 and 40 CFR 63 General Provisions included in Section 3 apply to these affected 

5.14.16 

HAP/ 

Benzene 

40 CFR Subpart CC 63.647 (8/18/95), which references 40 CFR 61.349(a)(2)(ii) and (c)(1) and (h) (10/17/00) and 61.354(d) (10/17/00). Also, Subpart CC 63.654(a) (8/18/98), which references 40 CFR 61.356(a), (f)(2), and (j) (10/17/00) Also, Title 40 CFR Subpart FF 61.340 through 61.358 applies directly 

Carbon Adsorption Control Devices 

Carbon adsorption system shall control organic emissions with at least 95% by weight efficiency or control benzene emissions with at least 98% by weight efficiency. Operate the control device at all times except during maintenance or repair of the waste management unit. Maintain a design analysis for the control device and define a carbon replacement interval based on the total carbon working capacity of the control device and source operating schedule. 

Monitor the organic compound concentration daily basis or at intervals no greater than 20% replacement interval, whichever is greater. Rcarbon when breakthrough (concentration of is indicated. 

Conduct quarterly visual inspect ions of the cdevice and make a first attempt at repair as slater than 5 calendar days after detection. Codays after emissions are detected or a visuarepair can be utilized if the repair is technicalshutdown, however, repair must be completeshutdown. Maintain documentation that includes:

• Dates of startup and shutdown of the 

device. 

• A description of the operating parame

that the control device will be operated standards and the design specificationcriteria used for selection of that param

• Periods when the closed-vent system 

operated as designed including all pevalve car-seal or closure mechanism valve position had changed. 

Maintain records of dates and times when thmonitored and when carbon beds are replacSubmit quarterly certification to the NWCAA have been carried out. Note: Under WAC 173-401-615(2) records m
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5-85 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring, Recordkeepin

Containers (including Vacuum Trucks) 

Note: 40 CFR 61 General Provisions included in Section 3 apply to these affected facilities. 

5.14.17 

HAP/ 

Benzene 

40 CFR 61 Subpart FF 61.342(c)(3)(iii), 61.345(a), (b), and (c) (1/7/93), 61.350 (3/7/90) and 61.355(h) (10/17/00), and 61.356 (g) and (h) (10/17/00), and 61.357(d)(6) and (d)(8) (10/17/00) 

Containers

Install, operate, and maintain a cover on each container used to handle, transfer, or store waste. The cover and all openings shall be designed to operate with no detectable emissions as indicated by less than 500 ppmv above background. Maintain each opening in a closed, sealed position (e.g. covered by a lid that is gasketed and latched) at all times when waste is in the container, except when loading, removing, sampling, or inspecting wastes. When waste is transferred by pumping, the fill pipe should be submerged. During loading, the cover shall remain in place and all openings shall be closed and sealed, except for those openings required for the submerged fill pipe, those openings required for venting to prevent physical damage or permanent deformation of the container or cover. Except where repair is technically impossible without a complete or partial facility or unit shutdown, if a broken seal or gasket or other problem is identified, first efforts at repair shall be made as soon as practicable, but not later than 15 calendar days after identification. If repair must be delayed, the repair shall occur before the end of the next facility or unit shutdown. 

Annually, using 40 CFR 60 Appendix A MethVapor Analyzer. Calibration gases shall be zhydrocarbon in air); and a mixture of methanconcentration of approximately 10,000 ppm mrecords for each test of no detectable emissiQuarterly, visually inspect each cover and alare closed and gasketed properly. Quarterly, certify to the NWCAA that the requout. Annually, submit a report summarizing all insdetectable emissions were measured or a prgap, or other problem) that could result in beincluding the repairs or corrective action takeMaintain records for each visual inspection thcould result in benzene emissions.
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5-86 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer 

Permit 

Term Citation Description Monitoring, Recordkeep

Internal Floating Roof Tanks 320, 321, 322, 323 (Subject to NWCAA 560, 580 and 40 CFR CC and 40 

Note: 40 CFR 61 and 40 CFR 63 General Provisions included in Section 3 apply to this affecte

5.14.18 

HAP/ 

Benzene

40 CFR 63 Subpart CC 63.647 (8/18/95), which references 40 CFR 61.351 (9/10/90) 40 CFR 61 Subpart FF 61.351 directly 

Alternative Standards for Tanks

40 CFR 61.351 allows as an alternative that tanks meet the internal floating roof requirements of 40 CFR 60 Subpart Kb 60.112b(a)(1) 

Follow the monitoring, recordkeeping aPermit Terms 15.14.21, 15.13.22, 15.1

Note: 40 CFR 63 General Provisions included in Section 3 do not apply to Conditions 5.14.19, 5.14.2

5.14.19 

VOC 

NWCAA Section 580.32 (12/13/89) 

High Vapor Pressure Volatile Organic Compound 

Storage Tanks The storage tank shall meet the 

internal floating roof equipment specifications and maintenance requirements of 40 CFR 60 Subpart Kb. 

5.14.20 

VOC 

NWCAA Section 560 (4/14/93) 

Storage of Organic Liquids with a True Vapor 

Pressure greater than 1.5 psia and less than 11.1 psiaDesign and equip the storage vessel with the following vapor loss control device, properly installed, in good working order and in operation: A floating roof, consisting of a pontoon type or double-deck type roof, resting on the surface of the liquid contents and equipped with a closure seal, or seals, to close the space between the roof edge and tank wall. The control equipment provided for in this paragraph shall not be used if the gasoline or petroleum distillate has a True Vapor Pressure of 11.1 pounds per square inch or greater under actual storage conditions. All tank gauging and sampling devices shall be gas-tight except when gauging or sampling is taking place. 

Perform all monitoring and reporting as 5.14.21. Maintain records demonstrating that ththan 11.1 psia. Notify the NWCAA withexceedance of the 11.1 TVP limit. - directly enforceable - 
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5-87 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer 

Permit 

Term Citation Description Monitoring, Recordkeep

Internal Floating Roof Tanks 320, 321, 322, 323 (Subject to NWCAA 560, 580 and 40 CFR CC and 40 

5.14.21 

VOC 

NWCAA Section 580.33 (12/13/89) 

Seal Condition All seals are to be maintained in 

good operating condition and the seal fabric shall contain no visible holes, tears, or other openings. 

Annually, conduct a visual inspection oseal system through manholes and roodocument any conditions where: 

• the floating roof is not resting o• there is liquid accumulated on • a seal is detached or there are 

Keep a record of each inspection that and any defects discovered. Defects shall be repaired within 45 dayout of service. A delay of repair extensdays with appropriate documentation jSubmit in the Periodic Report the date found and corrective action taken. The decision to use a delay of repair extensalternate storage capacity was unavailas soon as possible. 
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5-88 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer 

Permit 

Term Citation Description Monitoring, Recordkee

5.14.22 

HAP/ 

Benzene

40 CFR 63 Subpart CC 63.647 (8/18/95) which references 40 CFR 61.351 (9/10/90) which references 40 CFR 60.112b(a)(1)(i) and (ii) (10/8/97), and 40 CFR 63 Subpart CC 63.654(a) and (g) (8/18/98), which references 40 CFR 61.356(k) (10/17/00), which references 40 CFR 60.115b(a)(2) and (a)(3) (12/14/00) 

Internal Floating Roof Operation The internal 

floating roof shall rest or float on the liquid surface at all times except when it must be supported by the leg supports during (i) the initial fill, (ii) after the vessel has been completely emptied, and (iii) when the vessel is completely emptied before being subsequently refilled. When the floating roof is resting on the leg supports, filling, emptying, or refilling shall be continuous and shall be accomplished as rapidly as possible. If the internal floating roof is not resting on the surface, or there is liquid accumulated on the roof, or the seal is detached, or there are holes or tears in the seal fabric, repair the items or empty and remove the storage vessel from service within 45 days. If a failure detected during inspections cannot be repaired within 45 days and the vessel cannot be emptied within 45 days, a 30-day extension may be requested. Such a request must document that alternate storage capacity is unavailable and specify a schedule that will assure that the control equipment will be repaired or the vessel will be emptied as soon as possible 

Annually, conduct a visual inspection seal system through manholes and rodocument any conditions where: 

• the floating roof is not resting • there is liquid accumulated on • a seal is detached or there ar

Keep a record of each inspection that and any defects discovered. Defects shall be repaired within 45 daout of service. A delay of repair extendays with appropriate documentation Submit in the Periodic Report the date found and corrective action taken. Thdecision to use a delay of repair extenalternate storage capacity was unavaas soon as possible. The periodic report shall be submitted end of each 6-month period when any 
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5-89 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer 

Permit 

Term Citation Description Monitoring, Recordkee

5.14.23 HAP/ Benzene 

40 CFR 63 Subpart CC 63.647 (8/18/95) which references 40 CFR 61.351 (9/10/90) which references 40 CFR 60.112b(a)(1)(i) (10/8/97), 60.113b(a)(4) and (5) (8/11/89), and 63.654(a) (10/17/00), which references 40 CFR 61.356(k) (10/17/00), which references 40 CFR 60.115b(a)(2) (12/14/00) 

Internal Roof Degassing Inspection

If, during the inspection after degassing, the internal floating roof has defects, the primary seal or seal fabric has holes, tears, or other openings, the gaskets no longer closes off the liquid surfaces from the atmosphere, or the slotted membrane has more than 10% open area, repair as necessary so that none of these conditions exist before refilling the storage vessel with VOL. 

Visually inspect the internal floating rothe slotted membranes and sleeve se

vessel is emptied and degassed, and Notify the NWCAA in writing at least 3inspection is unplanned, the notificatio7 days prior to refilling followed immeKeep records of each inspection identinspection date, and the observed concontrol equipment (seals, internal floaIf the inspection after degassing finds fabric, or defects in the internal floatinequipment defects, a report shall be fperiodic reports. The report shall idenreason it did not meet the specificatio

5.14.24 

VOC 

NWCAA Section 580.34 (12/13/89) 

Openings All openings not related to safety are to 

be sealed with suitable closures. 

Each time the vessel is emptied and devery 10 years, conduct an internal ininspection shows that the floating roof 

limited to, improper gasketing or unseprior to refilling. Notify the NWCAA in writing at least 3

inspection is unplanned, the notificatio7 days prior to refilling followed imme
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Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer 

Permit 

Term Citation Description Monitoring, Recordkee

5.14.25 

HAP/ 

Benzene

40 CFR 63 Subpart CC 63.647(8/18/95) which references 40 CFR 61.351 (9/10/90) which references 40 CFR 60.112b(a)(1)(iv) (10/8/97) 

Covers or Lids Over Openings

 Each opening in the internal floating roof except for leg sleeves, automatic bleeder vents, rim space vents, column wells, ladder wells, sample wells, and stub drains is to be equipped with a cover or lid which is to be maintained in a closed position at all times (i.e., no visible gap) except when the device is in actual use. The cover or lid shall be equipped with a gasket. Covers on each access hatch and automatic gauge float well shall be bolted except when they are in use. 

5.14.26 

HAP/

Benzene 

40 CFR 63 Subpart CC 63.647 (8/18/95) which references 40 CFR 61.351 (9/10/90) which references 40 CFR 60.112b(a)(1)(v) (10/8/97) 

Automatic Bleeder Vents Equip with a gasket and 

close at all times when the roof is floating except when the roof is being floated off or is being landed on the roof leg supports. 

Each time the vessel is emptied and devery 10 years, conduct an internal ininspection shows that the floating roof limited to, improper gasketing or unseprior to refilling. Notify the NWCAA in writing at least 3

inspection is unplanned, the notificatio7 days prior to refilling followed imme

5.14.27 

VOC 

NWCAA Section 580.32 (12/13/89) 

High Vapor Pressure Volatile Organic Compound 

Storage Tanks The storage tank shall meet the 

internal floating roof equipment specifications and maintenance requirements of 40 CFR 60 Subpart Kb. 
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Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer 

Permit 

Term Citation Description Monitoring, Recordkee

5.14.28 

VOC 

NWCAA Section 560 (4/14/93) 

Storage of Organic Liquids with a True Vapor 

Pressure Greater than 1.5 psia and Less Than 11.1 psia

Design and equip the storage vessel with the following vapor loss control device, properly installed, in good working order an in operation: A floating roof, consisting of a pontoon type or double-deck type roof, resting on the surface of the liquid contents and equipped with a closure seal, or seals to close the space between the roof edge and the tank wall. The control equipment provided for in this paragraph shall not be used if the gasoline of petroleum distillate has a True Vapor Pressure of 11.1 pounds per square inch or greater under actual storage conditions. All tank gauging and sampling devices shall be gas-tight except when gauging or sampling is taking place. 
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5-92 

Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer 

Permit 

Term Citation Description Monitoring, Recordkee

5.14.29 

VOC 

NWCAA Section 580.33 (12/13/89) 

Seal Condition All seals are to be maintained in 

good operating condition and the seal fabric shall contain no visible holes, tears, or other openings. 

Annually, conduct a visual inspection seal system through manholes and rodocument any conditions where: 

• the floating roof is not resting on t• there is liquid accumulated on the • a seal is detached or there are ho

Keep a record of each inspection that and conditions observed (including anFailures shall be repaired within 45 daout of service. A delay of repair extendays with appropriate documentation Submit in the Periodic Report the date found and corrective action taken. Thdecision to use a delay of repair extenalternate storage capacity was unavaas soon as possible. 
BP Cherry Point Ref

Mod

5-93 

Table 5.14: Specifically Applicable Requirements for the Wastewater Plant and Sewer S

Permit 

Term Citation Description Monitoring, Recordkeep

5.14.30 

HAP/ 

Benzene 

40 CFR 63 Subpart CC 63.647 (8/18/95) which references 40 CFR 61.351 (9/10/90) which references 40 CFR 60.112b(a)(1)(vi) (10/8/97) 

Rim Space Vents Equip with a gasket and set 

to open only when the internal floating roof is not floating or at the manufacturer’s recommended setting. 

5.14.31 

HAP/ 

Benzene

40 CFR 63 Subpart CC 63.647 (8/18/95) which references 40 CFR 61.351 (9/10/90) which references 40 CFR 60.112b(a)(1)(vii) (10/8/97) 

Sampling Well Each penetration of the internal 

floating roof for the purpose of sampling shall be a sample well. The sample well shall have a slit fabric cover that covers at least 90 percent of the opening. 

5.14.32 

HAP/ 

Benzene

40 CFR 63 Subpart CC 63.647 (8/18/95) which references 40 CFR 61.351 (9/10/90) which references 40 CFR 60.112b(a)(1)(viii) (10/8/97) 

Column Supporting Fixed Roof Each 

penetration of the internal floating roof that allows for passage of a column supporting the fixed roof shall have a flexible fabric sleeve seal or a gasketed sliding cover. 

5.14.33 

HAP/ 

Benzene

40 CFR 63 Subpart CC 63.647 (8/18/95) which references 40 CFR 61.351 (9/10/90) which references 40 CFR 60.112b(a)(1)(ix) (10/8/97) 

Gasketed Sliding Cover Each penetration of 

the internal floating roof that allows for passage of a ladder shall have a gasketed sliding cover. 

Each time the vessel is emptied and d

every 10 years, conduct an internal ininspection shows that the floating roof limited to, improper gasketing or unsedefects prior to refilling. Notify the NWCAA in writing at least 3inspection is unplanned, the notificatioleast 7 days prior to refilling followed inotification.
BP Cherry Point Ref

Mod

5-94 

5.15 Tanks and Storage Vessels 

Internal Floating Roof Tanks:

• Tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, 10 and14 (NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart 

Vessel and OAC #562b) 

• Tanks 17, 18, 21, 22, 25, 26, 27, 31, 41, 42, 43, 44, 45, 46, 47, and 48 (NWCAA 560, NWCA

Subpart CC Group 1 Storage Vessel) 

• Tank 11 (NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 2 Storage Vessel) 

• Tanks 24, 50, and 71 (NWCAA 560, NWCAA 580 and 40 CFR 60 Subpart Kb) • Tanks 40 and 49 

(NWCAA 560, NWCAA 580 and 40 CFR 60 Subpart Kb and OAC #620a – Tank 49) and 

(NWCAA 560, NWCAA 580 and 40 CFR 60 Subpart Kb and OAC #897 – Tank 40) 

• Tanks 72, 73, and 74 (NWCAA 560, NWCAA 580, 40 CFR 60 Subpart Kb and OAC #527c) 

• Tanks 12, 13, 15, 16, 19, 20, 23, 29 and 33 (40 CFR 63 Subpart CC Group 2 Storage Vess

Fixed Roof Tanks with No Internal Floating Roof:

• Tanks 28, 30, 32, 34, 37, 38 and 70 (40 CFR 63 Subpart CC Group 2 Storage Vessel) Miscellaneous Tankfarm Requirements:

• NSPS Equipment leaks (OAC #562b) • MACT Equipment leaks (40 CFR 63 Subpart CC) • NSPS Individual Drain systems (40 CFR 60 Subpart QQQ) • NSPS Individual Junction Boxes (40 CFR 60 Subpart QQQ) 

NOTE - See Section 6.1 for monitoring requirements for valves in the tankfarm, pipeways and 
BP Cherry Point Ref

Mod

5-95 

Table 5.15 -Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 14 

(subject to NWCAA 560, NWCAA 580, 40 CFR 63 Subpart CC Group 1 Storage Vessel and 

Permit Term Citation Description Monitoring/Reco

Note: 40 CFR 63 General Provisions included in Section 3 apply to Subpart CC (affected s

5.15.1 

VOC 

NWCAA Section 560 (4/14/93) 

Storage of Organic Liquid with a True Vapor 

Pressure greater than 1.5 psia and less than 11.1 psia

Design and equip the storage vessel with the following vapor loss control device, properly installed, in good working order and in operation: A floating roof, consisting of a pontoon type or double-deck type roof, resting on the surface of the liquid contents and equipped with a closure seal, or seals, to close the space between the roof edge and tank wall. The control equipment provided for in this paragraph shall not be used if the gasoline or petroleum distillate has a True Vapor Pressure of 11.1 pounds per square inch or greater under actual storage conditions. All tank gauging and sampling devices shall be gas-tight except when gauging or sampling is taking place. 

Maintain records demonstrating less than 11.1 psia. Notify the discovering an exceedance of t- directly enforceable - 
BP Cherry Point Ref

Mod

5-96 

Table 5.15 -Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 14 

(subject to NWCAA 560, NWCAA 580, 40 CFR 63 Subpart CC Group 1 Storage Vessel and 

Permit Term Citation Description Monitoring/Reco

5.15.2 

VOC 

NWCAA Sections 580.32 and 580.33 (12/13/89) which reference 40 CFR 60 Subpart Kb 60.112b(a)(1)(ii) (10/8/97) and 60.113b(a)(2) (8/11/89) 

Seal Coverage – Annual Inspection 

A seal system shall be in place that completely covers the annular space between the floating roof and the storage vessel wall, except for when necessary repairs are being made as provided in 40 CFR 60.113b(a)(2). There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

5.15.3 

HAP 

40 CFR 63 Subpart CC 63.646 (2/21/97) which references 40 CFR 63.119(b)(3) (1/17/97), 63.120(a)(2)(i) and (a)(4) (1/17/97) 

Seal Coverage – Annual Inspection

A seal system shall be in place that completely covers the annular space between the floating roof and the storage vessel wall, except for when necessary repairs are being made as provided in 40 CFR 63.120(a)(4). There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Annually, conduct a visual inspectiosystem through manholes and roof document any conditions where:  the floating roof is not resting o there is liquid accumulated on  a seal is detached or there are Keep a record of each inspection thfailures discovered. Failures shall be repaired within 45 of service. A delay of repair extenswith appropriate documentation jusSubmit in the Periodic Report docuduring the inspection. The report svessel identification, description of each repair. The report shall includextension and documentation that unavailable and that repair was com

5.15.4 

VOC 

NWCAA Section 580.32 and 580.33 (12/13/89) which references 40 CFR 60 Subpart Kb 60.113b(a)(4) and (a)(5) (8/11/89) 

Seal Coverage – Inspection After Degassing

The primary seal shall completely cover the annular space between the floating roof and the storage vessel wall. There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

5.15.5 

HAP 

40 CFR 63 Subpart CC 63.646 (2/21/97) which references 40 CFR 63.119(b)(3) (1/17/97), 63.120(a)(2)(ii), (a)(5) and (a)(6) (1/17/97) and 63.654(g)(2)(ii) and 63.654(h)(2)(i) (8/18/98) 

Seal Coverage – Inspection After Degassing

The primary seal shall completely cover the annular space between the floating roof and the storage vessel wall. There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Each time the vessel is emptied anyears, conduct an internal visual inshows that the floating roof has failtears or other openings in a seal or Notify the NWCAA in writing at leasinspection is unplanned, the notificdays prior to refilling followed immeSubmit in the Periodic Report docuduring the inspection. The report shall include the date of description of each failure and the report shall include any decision to documentation that alternate storagrepair was completed as soon as p
BP Cherry Point Ref

Mod

5-97 

Table 5.15 -Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 14 

(subject to NWCAA 560, NWCAA 580, 40 CFR 63 Subpart CC Group 1 Storage Vessel and 

Permit Term Citation Description Monitoring/Reco

5.15.6 

VOC 

NWCAA Section 580.34 (12/13/89) 

Openings All openings not related to safety are to 

be sealed with suitable closures. 

5.15.7 

HAP 

40 CFR 63 Subpart CC 63.646(f) (2/21/97) and 63.119(b)(4) (1/17/97) 

Roof Openings – Inspection After Degassing

Except for automatic bleeder vents and rim space vents, each opening in the roof shall have a projection below the liquid surface. Except for automatic bleeder vents, rim space vents, column wells, ladder wells, sample wells, and stub drains, each opening in the roof shall be equipped with a gasketed cover, seal, or lid that is to be maintained in a closed position at all times (i.e., no visible gap) except when the device is in use. Automatic bleeder vents are to be closed at all times when the roof is floating except when the roof is being floated off or is being landed on the roof leg supports. Rim vents are to be set to open when the roof is being floated off the roof leg supports or at the manufacturer’s recommended setting. Automatic bleeder vents and rim space vents are to be gasketed. 

Each time the vessel is emptied every 10 years, conduct an inteIf inspection shows that the floanot limited to, improper gasketiprior to refilling. Notify the NWCAA in writing at the inspection is unplanned, the at least 7 days prior to refilling fnotification. 

5.15.8 

VOC 

NWCAA Section 580.32 (12/13/89) which references 40 CFR 60 Subpart Kb 60.112b(a)(1)(i) (10/8/97) 

Roof Floating on Surface The roof shall be floating 

on the liquid at all times (i.e., off the roof leg supports) except during initial fill until the roof is lifted off leg supports and when the tank is completely emptied and subsequently refilled. The process of filling, emptying, or refilling when the roof is resting on the leg supports shall be continuous and shall be accomplished as rapidly as possible. 

Keep records of periods when thsupports. -directly enforceable- 
BP Cherry Point Ref

Mod

5-98 

Table 5.15 -Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 14 

(subject to NWCAA 560, NWCAA 580, 40 CFR 63 Subpart CC Group 1 Storage Vessel and 

Permit Term Citation Description Monitoring/Reco

5.15.9 

HAP 

40 CFR 63 Subpart CC 63.646 (2/21/97) which references 40 CFR 63.119(b)(1) and (b)(2) (1/17/97), and 63.646(f)(3) (2/21/97) 

Roof Floating on Surface The floating roof shall be 

floating on the liquid surface at all times except when it must be supported by the leg supports during, initial fill, after the vessel has been completely emptied and degassed, and when the vessel is completely emptied before being subsequently refilled. When the floating roof is resting on the leg supports, the process of filling, emptying, or refilling shall be continuous and shall be accomplished as soon as possible. Automatic bleeder vents are to be closed at all times when the roof is floating, except when the roof is being floated off or is being landed on the roof leg supports. 

Keep records of periods when thsupports. -directly enforceable- 
BP Cherry Point Ref

Mod

5-99 

Table 5.15 -Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 17, 18, 21, 22, 25, 26, 27, 31, 41, 42, 43, 44, 45, 46, 47 

(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 1 Storage V

Permit Term Citation Description Monitoring/Reco

Note: 40 CFR 63 General Provisions included in Section 3 apply to Subpart CC (affected s

5.15.10 

VOC 

NWCAA Section 560 (4/14/93) 

Storage of Organic Liquid with a True Vapor

Pressure greater than 1.5 psia and less than 11.1 

psia

Design and equip the storage vessel with the following vapor loss control device, properly installed, in good working order and in operation: A floating roof, consisting of a pontoon type or double-deck type roof, resting on the surface of the liquid contents and equipped with a closure seal, or seals, to close the space between the roof edge and tank wall. The control equipment provided for in this paragraph shall not be used if the gasoline or petroleum distillate has a True Vapor Pressure of 11.1 pounds per square inch or greater under actual storage conditions. All tank gauging and sampling devices shall be gas-tight except when gauging or sampling is taking place. 

Maintain records demonstratinless than 11.1 psia. Notify the discovering an exceedance of 

- directly enforceable - 
BP Cherry Point Ref

Mod

5-100 

Table 5.15 -Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 17, 18, 21, 22, 25, 26, 27, 31, 41, 42, 43, 44, 45, 46, 47 

(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 1 Storage V

Permit Term Citation Description Monitoring/Reco

5.15.11 

VOC 

NWCAA Sections 580.32 and 580.33 (12/13/89) which reference 40 CFR 60 Subpart Kb 60.112b(a)(1)(ii) (10/8/97) and 60.113b(a)(2) (8/11/89) 

Seal Coverage – Annual Inspection 

A seal system shall be in place that completely covers the annular space between the floating roof and the storage vessel wall, except for when necessary repairs are being made as provided in 40 CFR 60.113b(a)(2). There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

5.15.12 

HAP 

40 CFR 63 Subpart CC 63.646 (2/21/97) which references 40 CFR 63.119(b)(3) (1/17/97), 63.120(a)(2)(i) and (a)(4) (1/17/97) 

Seal Coverage – Annual Inspection

A seal system shall be in place that completely covers the annular space between the floating roof and the storage vessel wall, except for when necessary repairs are being made as provided in 40 CFR 63.120(a)(4). There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Annually, conduct a visual inspand seal system through manhinspection shall document any 

the floating roof is not resting othere is liquid accumulated on ta seal is detached or there are Keep a record of each inspectioany failures discovered. Failures shall be repaired within taken out of service. A delay oup to 60 days with appropriate Submit in the Periodic Report ddiscovered during the inspectioof inspection, vessel identificatithe nature and date of each repdecision to use a delay of repaalternate storage capacity was completed as soon as possible
BP Cherry Point Ref

Mod

5-101 

Table 5.15 -Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 17, 18, 21, 22, 25, 26, 27, 31, 41, 42, 43, 44, 45, 46, 47 

(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 1 Storage V

Permit Term Citation Description Monitoring/Reco

5.15.13 

VOC 

NWCAA Section 580.32 and 580.33 (12/13/89) which references 40 CFR 60 Subpart Kb 60.113b(a)(4) and (a)(5) (8/11/89) 

Seal Coverage – Inspection After Degassing

The primary seal shall completely cover the annular space between the floating roof and the storage vessel wall. There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

5.15.14 

HAP 

40 CFR 63 Subpart CC 63.646 (2/21/97) which references 40 CFR 63.119(b)(3) (1/17/97), 63.120(a)(2)(ii), (a)(5) and (a)(6) (1/17/97) and 63.654(g)(2)(ii) and 63.654(h)(2)(i) (8/18/98) 

Seal Coverage – Inspection After Degassing

The primary seal shall completely cover the annular space between the floating roof and the storage vessel wall. There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Each time the vessel is emptieevery 10 years, conduct an inteIf the inspection shows that the but not limited to, holes, tears ofabric, repair prior to refilling. 

Notify the NWCAA in writing at inspection is unplanned, the noleast 7 days prior to refilling folnotification. Submit in the Periodic Report ddiscovered during the inspectioof inspection, vessel identificatthe nature and date of each redecision to use a delay of repaalternate storage capacity was completed as soon as possible
BP Cherry Point Ref

Mod

5-102 

Table 5.15 -Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 17, 18, 21, 22, 25, 26, 27, 31, 41, 42, 43, 44, 45, 46, 47 

(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 1 Storage V

Permit Term Citation Description Monitoring/Reco

5.15.15 

VOC 

NWCAA Section 580.34 (12/13/89) 

Openings All openings not related to safety are 

to be sealed with suitable closures. 

Each time the vessel is emptieevery 10 years, conduct an inteIf inspection shows that the flonot limited to, improper gasketprior to refilling. 

5.15.16 

HAP 

40 CFR 63 Subpart CC 63.646(f) (2/21/97) and 63.119(b)(4) (1/17/97) 

Roof Openings – Inspection After Degassing

Except for automatic bleeder vents and rim space vents, each opening in the roof shall have a projection below the liquid surface. Except for automatic bleeder vents, rim space vents, column wells, ladder wells, sample wells, and stub drains, each opening in the roof shall be equipped with a gasketed cover, seal, or lid that is to be maintained in a closed position at all times (i.e., no visible gap) except when the device is in use. Automatic bleeder vents are to be closed at all times when the roof is floating except when the roof is being floated off or is being landed on the roof leg supports. Rim vents are to be set to open when the roof is being floated off the roof leg supports or at the manufacturer’s recommended setting. Automatic bleeder vents and rim space vents are to be gasketed. 

Notify the NWCAA in writing at inspection is unplanned, the noleast 7 days prior to refilling folnotification. 

5.15.17 

VOC 

NWCAA Section 580.32 (12/13/89) which references 40 CFR 60 Subpart Kb 60.112b(a)(1)(i) (10/8/97) 

Roof Floating on Surface The roof shall be 

floating on the liquid at all times (i.e., off the roof leg supports) except during initial fill until the roof is lifted off leg supports and when the tank is completely emptied and subsequently refilled. The process of filling, emptying, or refilling when the roof is resting on the leg supports shall be continuous and shall be accomplished as rapidly as possible. 

Keep records of periods when tsupports. -directly enforceable- 
BP Cherry Point Ref

Mod

5-103 

Table 5.15 -Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 17, 18, 21, 22, 25, 26, 27, 31, 41, 42, 43, 44, 45, 46, 47 

(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 1 Storage V

Permit Term Citation Description Monitoring/Reco

5.15.18 

HAP 

40 CFR 63 Subpart CC 63.646 (2/21/97) which references 40 CFR 63.119(b)(1) and (b)(2) (1/17/97), and 63.646(f)(3) (2/21/97) 

Roof Floating on Surface The floating roof shall 

be floating on the liquid surface at all times except when it must be supported by the leg supports during, initial fill, after the vessel has been completely emptied and degassed, and when the vessel is completely emptied before being subsequently refilled. When the floating roof is resting on the leg supports, the process of filling, emptying, or refilling shall be continuous and shall be accomplished as soon as possible. Automatic bleeder vents are to be closed at all times when the roof is floating, except when the roof is being floated off or is being landed on the roof leg supports. 

Keep records of periods when thsupports. -directly enforceable- 
BP Cherry Point Ref

Mod

5-104 

Table 5.15 - Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 11 

 (subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 2 Storage Ve

Permit 

Term Citation Description Monitoring/Recordke

Note: 40 CFR 63 General Provisions included in Section 3 apply to Subpart CC (affected so

5.15.19 

VOC/ 

HAP 

Title 40 CFR Subpart CC 63.646(2/21/97), which references 40 CFR 63.119(a)(3) (1/17/97) 

Dimensions and Capacities Keep readily 

accessible records of the dimensions and capacities of each Group 2 storage vessel. 

Maintain records at the facility with dim

5.15.20 

VOC 

NWCAA Section 560 (4/14/93) 

Storage of Organic Liquid Design and equip the 

storage vessel with the following vapor loss control device, properly installed, in good working order and in operation: A floating roof, consisting of a pontoon type or double-deck type roof, resting on the surface of the liquid contents and equipped with a closure seal, or seals, to close the space between the roof edge and tank wall. The control equipment provided for in this paragraph shall not be used if the gasoline or petroleum distillate has a True Vapor Pressure of 11.1 pounds per square inch or greater under actual storage conditions. All tank gauging and sampling devices shall be gas-tight except when gauging or sampling is taking place. 

Maintain records demonstrating that ththan 11.1 psia. Notify the NWCAA withexceedance of the 11.1 TVP limit. - directly enforceable - 

5.15.21 

VOC 

NWCAA Section 580.32 (12/13/89) which references 40 CFR 60 Subpart Kb 60.112b(a)(1)(i) (10/8/97) 

Roof Floating on Surface The roof shall be 

floating on the liquid at all times (i.e., off the roof leg supports) except during initial fill until the roof is lifted off leg supports and when the tank is completely emptied and subsequently refilled. The process of filling, emptying, or refilling when the roof is resting on the leg supports shall be continuous and shall be accomplished as rapidly as possible. 

Keep records of periods when the floatinsupports. 

 - directly enforceable- 
BP Cherry Point Ref

Mod

5-105 

Table 5.15 - Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 11 

 (subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 2 Storage Ve

Permit 

Term Citation Description Monitoring/Recordke

5.15.22 

VOC 

NWCAA Section 580.34 (12/13/89) 

Openings All openings not related to safety are 

to be sealed with suitable closures. 

Each time the vessel is emptied and de10 years, conduct an internal visual insinspection shows that the floating roof hlimited to, improper gasketing or unsearefilling. Notify the NWCAA in writing at least 30 inspection is unplanned, the notification 7 days prior to refilling followed immedi

5.15.23 

VOC 

NWCAA Sections 580.32 and 580.33 (12/13/89) which references 40 CFR 60 Subpart Kb 60.112b(a)(1)(ii) (10/8/97) and 60.113b(a)(2) (8/11/89) 

Seal Coverage – Annual Inspection 

A seal system shall be in place that completely covers the annular space between the floating roof and the storage vessel wall, except for when necessary repairs are being made as provided in 40 CFR 60.113b(a)(2). There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Annually, conduct a visual inspection oseal system through manholes and roodocument any conditions where: 

the floating roof is not resting on the VOthere is liquid accumulated on the floata seal is detached or there are holes or Keep a record of each inspection that ifailures discovered. Failures shall be repaired within 45 dayout of service. A delay of repair extensdays with appropriate documentation juSubmit in the Periodic Report documenduring the inspection. The report shall vessel identification, description of eacof each repair. The report shall include repair extension and documentation thaunavailable and that repair was comple
BP Cherry Point Ref

Mod

5-106 

Table 5.15 - Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 11 

 (subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 2 Storage Ve

Permit 

Term Citation Description Monitoring/Recordke

5.15.24 

VOC 

NWCAA Section 580.32 and 580.33 (12/13/89) which references 40 CFR 60 Subpart Kb 60.113b(a)(4) and (a)(5) (8/11/89) 

Seal Coverage – Inspection After Degassing

The primary seal shall completely cover the annular space between the floating roof and the storage vessel wall. There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Each time the vessel is emptied and de10 years, conduct an internal visual insinspection shows that the floating roof h

limited to, holes, tears or other openingprior to refilling. Notify the NWCAA in writing at least 30 inspection is unplanned, the notification 7 days prior to refilling followed immediSubmit in the Periodic Report documenduring the inspection. The report shall vessel identification, description of eacof each repair. The report shall include repair extension and documentation thaunavailable and that repair was comple
BP Cherry Point Ref

Mod

5-107 

Table 5.15 - Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 24, 50, 71 

(subject to NWCAA 560, NWCAA 580, 40 CFR 60 Subpart Kb) 

Permit 

Term Citation Description Monitoring/Recordk

Note: 40 CFR 60 General Provisions included in Section 3 apply to Subpart K (affected so

5.15.25 

VOC 

40 CFR 60 Subpart Kb 60.112b(a)(1)(ii) (10/8/97), 60.113b(a)(2) (8/11/89) and 60.115b(a)(2) and (a)(3) (4/8/87) as modified by 40 CFR 63.640(n)(8)(v) (5/25/01) NWCAA Sections 580.32 and 580.33 (12/13/89) which references 40 CFR 60 Subpart Kb 

Seal Coverage – Annual Inspection 

A seal system shall be in place that completely covers the annular space between the floating roof and the storage vessel wall, except for when necessary repairs are being made as provided in 40 CFR 60.113b(a)(2). There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Annually, conduct a visual inspectioseal system through manholes and document any conditions where: 

the floating roof is not resting on the there is liquid accumulated on the floa seal is detached or there are holes Keep a record of each inspection thaconditions observed (including any fFailures shall be repaired within 45 dtaken out of service. A delay of repaup to 60 days with appropriate docuSubmit in the Periodic Report the dafound and corrective action taken. Tdecision to use a delay of repair extealternate storage capacity was unavas soon as possible. 
BP Cherry Point Ref

Mod

5-108 

Table 5.15 - Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 24, 50, 71 

(subject to NWCAA 560, NWCAA 580, 40 CFR 60 Subpart Kb) 

Permit 

Term Citation Description Monitoring/Recordk

5.15.26 

VOC 

40 CFR 60 Subpart Kb 60.113b(a)(4) and (a)(5) (8/11/89), and 60.115b(a)(2) and (a)(4) (4/8/87) as modified by 40 CFR 63.640(n)(8)(v) (5/25/01) NWCAA Section 580.32 and 580.33 (12/13/89) which references 40 CFR 60 Subpart Kb 

Seal Coverage – Inspection After Degassing

The primary seal shall completely cover the annular space between the floating roof and the storage vessel wall. There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Each time the vessel is emptied and every 10 years, conduct an internal the inspection shows that the floatinnot limited to, holes, tears or other orepair prior to refilling. Keep a recorthe tank number, date and condition

Notify the NWCAA in writing at least inspection is unplanned, the notifica7 days prior to refilling followed immSubmit in the Periodic Report the dafound and corrective action taken. Tdecision to use a delay of repair extealternate storage capacity was unavas soon as possible. 

5.15.27 

VOC 

40 CFR 60 Subpart Kb 60.112b(a)(1)(ii)(B) through (a)(1)(ix) (10/8/97) and 60.113b(a)(4) and (a)(5) (8/11/89), and 60.115b(a)(2) and (a)(4) (4/8/87) as modified by 40 CFR 63.640(n)(8)(v) (5/25/01) 

Roof Openings – Inspection after Degassing

Except for automatic bleeder vents and rim space vents, each opening in the non contact roof shall have a projection below the liquid surface. Except for automatic bleeder vents, rim space vents, columns wells, ladder wells, sample wells, and stub drains, each opening in the roof shall be equipped with a gasketed cover, seal, or lid that is to be maintained in a closed position at all times (i.e., no visible gaps) except when the device is in use. 

Automatic bleeder vents are to be closed at al times when the roof is floating except when the roof is being floated off or is being landed on the leg supports. Rim vents are to be set to open when the roof is being floated off the roof leg supports or at the manufacturer’s recommended setting. Automatic bleeder vents and rim space vents are to be gasketed. 

Each time the vessel is emptied and every 10 years, conduct an internal inspection shows that the floating rolimited to, improper gasketing or unsrefilling. Keep a record of each insp

number, date and conditions observ

Notify the NWCAA in writing at least inspection is unplanned, the notifica7 days prior to refilling followed immSubmit in the Periodic Report the dafound and corrective action taken. Tdecision to use a delay of repair extealternate storage capacity was unavas soon as possible. 
BP Cherry Point Ref

Mod

5-109 

Table 5.15 - Specifically Applicable Requirements 

 Internal Floating Roof Tanks: 24, 50, 71 

(subject to NWCAA 560, NWCAA 580, 40 CFR 60 Subpart Kb) 

Permit 

Term Citation Description Monitoring/Recordk

5.15.28 

VOC 

NWCAA Section 580.34 (12/13/89) 

Openings All openings not related to safety are to 

be sealed with suitable closures. 

5.15.29 

VOC 

NWCAA Section 580.32 (12/13/89) which references 40 CFR 60 Subpart Kb 60.112b(a)(1)(i) (10/8/97) 

Roof Floating on Surface The roof shall be floating 

on the liquid at all times (i.e., off the roof leg supports) except during initial fill until the roof is lifted off leg supports and when the tank is completely emptied and subsequently refilled. The process of filling, emptying, or refilling when the roof is resting on the leg supports shall be continuous and shall be accomplished as rapidly as possible. 

Keep records of periods when the floasupports. -directly enforceable5.15.30 

VOC/ 

HAP 

40 CFR 60 Subpart Kb 60.116b(c) and (e) (12/14/00) 

Maximum True Vapor Pressure Maintain a record 

of the VOL stored, the period of storage, and the maximum true vapor pressure of that VOL during the respective storage period. 

Calculate the maximum true vapor pPressure and the maximum expectethe highest expected calendar-montstored product. Maintain records at the facility with th

5.15.31 

VOC 

NWCAA Section 560 (4/14/93) 

Storage of Organic Liquid of True Vapor Pressure 

of greater than 1.5 psia and less than 11.1 psia

Design and equip the storage vessel with the following vapor loss control device, properly installed, in good working order and in operation: A floating roof, consisting of a pontoon type or double-deck type roof, resting on the surface of the liquid contents and equipped with a closure seal, or seals, to close the space between the roof edge and tank wall. The control equipment provided for in this paragraph shall not be used if the gasoline or petroleum distillate has a True Vapor Pressure of 11.1 pounds per square inch or greater under actual storage conditions. All tank gauging and sampling devices shall be gas-tight except when gauging or sampling is taking place. 

Maintain records demonstrating that than 11.1 psia. Notify the NWCAA wexceedance of the 11.1 TVP limit av-directly enforceable - 
BP Cherry Point Ref

Mod

5-110 

Table 5.15 - Specifically Applicable Requirements 

Internal Floating Roof Tank 40 and 49 

(subject to NWCAA 560, NWCAA 580, 40 CFR Subpart Kb, OAC #897 and OAC #6

Permit 

Term Citation Description Monitoring/Recordke

Note: 40 CFR 60 General Provisions included in Section 3 apply to Subpart Kb (affected s

The following conditions apply to Tanks 40 and 49 

5.15.32 

VOC 

40 CFR 60 Subpart Kb 60.112b(a)(1)(ii) (10/8/97), 60.113b(a)(2) (8/11/89) and 60.115b(a)(2) and (a)(3) (4/8/87) as modified by 40 CFR 63.640(n)(8)(v) (5/25/01) NWCAA Sections 580.32 and 580.33 (12/13/89) which references 40 CFR 60 Subpart Kb 

Seal Coverage – Annual Inspection 

A seal system shall be in place that completely covers the annular space between the floating roof and the storage vessel wall, except for when necessary repairs are being made as provided in 40 CFR 60.113b(a)(2). There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Annually, conduct a visual inspection osystem through manholes and roof hatdocument any conditions where: • the floating roof is not resting on th• there is liquid accumulated on the • a seal is detached or there are hole

Keep a record of each inspection that iconditions observed (including any failuFailures shall be repaired within 45 dayout of service. A delay of repair extensdays with appropriate documentation juSubmit in the Periodic Report the date found and corrective action taken. The to use a delay of repair extension and storage capacity was unavailable that possible. 
BP Cherry Point Ref

Mod

5-111 

Table 5.15 - Specifically Applicable Requirements 

Internal Floating Roof Tank 40 and 49 

(subject to NWCAA 560, NWCAA 580, 40 CFR Subpart Kb, OAC #897 and OAC #6

Permit 

Term Citation Description Monitoring/Recordke

5.15.33 

VOC 

40 CFR 60 Subpart Kb 60.113b(a)(4) and (a)(5) (8/11/89), and 60.115(a)(2) and (a)(4) (4/8/87) as modified by 40 CFR 63.640(n)(8)(v) (5/25/01) NWCAA Section 580.32 and 580.33 (12/13/89) which references 40 CFR 60 Subpart Kb 

Seal Coverage – Inspection After Degassing

The primary seal shall completely cover the annular space between the floating roof and the storage vessel wall. There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Each time the vessel is emptied and de10 years, conduct an internal visual insinspection shows that the floating roof 

limited to, holes, tears or other openingprior to refilling. Keep a record of each number, date and conditions observed Notify the NWCAA in writing at least 30 inspection is unplanned, the notification days prior to refilling followed immediatSubmit in the Periodic Report the date found and corrective action taken. The to use a delay of repair extension and storage capacity was unavailable that 

possible. 
BP Cherry Point Ref

Mod

5-112 

Table 5.15 - Specifically Applicable Requirements 

Internal Floating Roof Tank 40 and 49 

(subject to NWCAA 560, NWCAA 580, 40 CFR Subpart Kb, OAC #897 and OAC #6

Permit 

Term Citation Description Monitoring/Recordke

5.15.34 

VOC 

40 CFR Subpart Kb 60.112b(a)(1)(iii) through (ix) (10/8/97) and 60.113b(a)(4) and (a)(5) (8/11/89), and 60.115b(a)(2) and (a)(4) (4/8/87) as modified by 40 CFR 63.640(n)(8)(v) (5/25/01) 

Roof Openings Inspection After Degassing

Except for automatic bleeder vents, rim space vents, roof drains, and leg sleeves, each opening in the non contact roof is to be equipped with a gasketed cover, seal, or lid that is to be maintained in a closed position at all times (i.e., no visible gap) except when the device is in actual use. Automatic bleeder vents are to be closed at all times when the roof is floating except when the roof is being floated off or is being landed on the roof leg supports. Rim vents are to be set to open when the roof is being floated off the roof leg supports or at the manufacturer’s recommended setting. Automatic bleeder vents and rim space vents are to be gasketed. Each penetration of the internal floating roof for the purpose of sampling shall have a sample well. The sample well shall have a slit fabric cover that covers at least 90 percent of the area of the opening. 

Each time the vessel is emptied and de10 years, conduct an internal visual insshows that the floating roof has failures improper gasketing or unsealed openinKeep a record of each inspection that iconditions observed Notify the NWCAA in writing at least 30 inspection is unplanned, the notification days prior to refilling followed immediatSubmit in the Periodic Report the date found and corrective action taken. The to use a delay of repair extension and storage capacity was unavailable that possible. 

5.15.35 

VOC 

NWCAA Section 580.34 (12/13/89) 

 Openings

All openings not related to safety are to be sealed with suitable closures. 
BP Cherry Point Ref

Mod

5-113 

Table 5.15 - Specifically Applicable Requirements 

Internal Floating Roof Tank 40 and 49 

(subject to NWCAA 560, NWCAA 580, 40 CFR Subpart Kb, OAC #897 and OAC #6

Permit 

Term Citation Description Monitoring/Recordke

5.15.35 

VOC 

NWCAA Section 580.32 and 580.33 (12/13/89) which references 40 CFR 60 Subpart Kb 60.113b(a)(4) and (a)(5) (8/11/89) 

Seal Coverage – Inspection After Degassing

The primary seal shall completely cover the annular space between the floating roof and the storage vessel wall. There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Each time the vessel is emptied and de10 years, conduct an internal visual insinspection shows that the floating roof 

limited to, holes, tears or other openingprior to refilling. Notify the NWCAA in writing at least 30 inspection is unplanned, the notification days prior to refilling followed immediatSubmit in the Periodic Report documenduring the inspection. The report shall vessel identification, description of eacof each repair. The report shall include repair extension and documentation thunavailable and that repair was comple

5.15.37 

VOC 

NWCAA Section 580.34 (12/13/89) 

Openings All openings not related to safety are 

to be sealed with suitable closures. 

Each time the vessel is emptied and de10 years, conduct an internal visual insshows that the floating roof has failures 

improper gasketing or unsealed openinNotify the NWCAA in writing at least 30 

inspection is unplanned, the notification days prior to refilling followed immediat

5.15.38 

VOC 

NWCAA Section 580.32 (12/13/89) which references 40 CFR 60 Subpart Kb 60.112b(a)(1)(i) (10/8/97) 

Roof Floating on Surface The roof shall be 

floating on the liquid at all times (i.e., off the roof leg supports) except during initial fill until the roof is lifted off leg supports and when the tank is completely emptied and subsequently refilled. The process of filling, emptying, or refilling when the roof is resting on the leg supports shall be continuous and shall be accomplished as rapidly as possible. 

Keep records of periods when the floatinsupports. -directly enforceable- 
BP Cherry Point Ref

Mod

5-114 

Table 5.15 - Specifically Applicable Requirements 

Internal Floating Roof Tank 40 and 49 

(subject to NWCAA 560, NWCAA 580, 40 CFR Subpart Kb, OAC #897 and OAC #6

Permit 

Term Citation Description Monitoring/Recordke

5.15.39 

VOC/ 

HAP 

Title 40 CFR Subpart Kb 60.116b(c) and (e) (12/14/00) 

Maximum True Vapor Pressure

Maintain a record of the VOL stored, the period of storage, and the maximum true vapor pressure of that VOL during the respective storage period. 

Calculate the maximum true vapor preknown Reid Vapor Pressure and the mtemperature based on the highest exptemperature of the stored product. Maintain records at the facility with this 

The following Specific Conditions apply to Tank 49 

5.15.40 

VOC 

NWCAA OAC #620a Condition 2 (7/26/02) 

The storage vessel may be used to store crude oil only. 

Keep records of material stored in tank

5.15.41 

General 

NWCAA OAC #620a Condition 5 

Maintain records of the number of tank turnovers per year, and material stored for a period of at least two years. 

Keep records of material stored in tank 

5.15.42 

General 

NWCAA OAC #620a Condition 2 (7/26/02) 

Provide a report of an upset condition within 12 hours when defects are found during inspections of the storage vessel with a written follow-up report. 

Report upsets conditions within 12 hoinspections. Provide a written follow-ueach defect and the corrective action written 30 day extension may be subtank cannot be completed within 45 da

The following Specific Conditions apply to Tank 40

5.15.43 

General 

NWCAA OAC #897 Condition 1 (11/15/04) 

Maintain records of the number of tank turnovers per calendar year, and the types and dates of liquids stored. 

Keep records onsite for a minimum of f

5.15.44 

General

NWCAA OAC #897 Condition 2 (11/15/04) 

Provide a report of an upset condition within 12 hours when defects are found during inspections of the storage vessel with a written follow-up report. 

Provide a written follow-up report withand the corrective action taken to assu
BP Cherry Point Ref

Mod

5-115 

Table 5.15- Specifically Applicable Requirements 

Internal Floating Roof Tank 72, 73, 74 (subject to NWCAA 560, NWCAA 580, 40 CFR 60 Subpart Kb 

Permit 

Term Citation Description Monitoring/Recordke

Note: 40 CFR 60 General Provisions included in Section 3 apply to Subpart Kb (affected sou

5.15.45 

VOC 

NWCAA Section 560 (4/14/93) 

Storage of Organic Liquid of True Vapor Pressure 

greater than 1.5 psia and less than 11.1 psia

Design and equip the storage vessel with the following vapor loss control device, properly installed, in good working order and in operation: A floating roof, consisting of a pontoon type or double-deck type roof, resting on the surface of the liquid contents and equipped with a closure seal, or seals, to close the space between the roof edge and tank wall. The control equipment provided for in this paragraph shall not be used if the gasoline or petroleum distillate has a True Vapor Pressure of 11.1 pounds per square inch or greater under actual storage conditions. All tank gauging and sampling devices shall be gas-tight except when gauging or sampling is taking place. 

Maintain records demonstrating that ththan 11.1 psia. Notify the NWCAA withexceedance of the 11.1 TVP limit avera- directly enforceable - 
BP Cherry Point Ref

Mod

5-116 

Table 5.15- Specifically Applicable Requirements 

Internal Floating Roof Tank 72, 73, 74 (subject to NWCAA 560, NWCAA 580, 40 CFR 60 Subpart Kb 

Permit 

Term Citation Description Monitoring/Recordke

5.15.45 

VOC 

40 CFR 60 Subpart Kb 60.112b(a)(1)(ii) (10/8/97), 60.113b(a)(2) (8/11/89) and 60.115b(a)(2) and (a)(3) (4/8/87) as modified by 40 CFR 63.640(n)(8)(v) (5/25/01) NWCAA Sections 580.32 and 580.33 (12/13/89) which references 40 CFR 60 Subpart Kb 

Seal Coverage – Annual Inspection 

A seal system shall be in place that completely covers the annular space between the floating roof and the storage vessel wall, except for when necessary repairs are being made as provided in 40 CFR 60.113b(a)(2). There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Annually, conduct a visual inspection oseal system through manholes and roodocument any conditions where: • the floating roof is not resting on th• there is liquid accumulated on the • a seal is detached or there are holKeep a record of each inspection that and conditions observed (including any Failures shall be repaired within 45 dataken out of service. A delay of repair to 60 days with appropriate documentaSubmit in the Periodic Report the date found and corrective action taken. The decision to use a delay of repair extenalternate storage capacity was unavail

as soon as possible. 

5.15.47 

VOC 

40 CFR 60 Subpart Kb 60.113b(a)(4) and (a)(5) (8/11/89), and 60.115(a)(2) and (a)(4) (4/8/87) as modified by 40 CFR 63.640(n)(8)(v) (5/25/01) NWCAA Section 580.32 and 580.33 (12/13/89) which references 40 CFR 60 Subpart Kb 

Seal Coverage – Inspection After Degassing

The primary seal shall completely cover the annular space between the floating roof and the storage vessel wall. There should be no holes, tears, or other openings in the seal, seal fabric, or the seal envelope. 

Each time the vessel is emptied and deevery 10 years, conduct an internal visthe inspection shows that the floating rnot limited to, holes, tears or other operepair prior to refilling. Keep a record othe tank number, date and conditions oNotify the NWCAA in writing at least 30 inspection is unplanned, the notification 7 days prior to refilling followed immedSubmit in the Periodic Report the date found and corrective action taken. The decision to use a delay of repair extensalternate storage capacity was unavailas soon as possible. 
BP Cherry Point Ref

Mod

5-117 

Table 5.15- Specifically Applicable Requirements 

Internal Floating Roof Tank 72, 73, 74 (subject to NWCAA 560, NWCAA 580, 40 CFR 60 Subpart Kb 

Permit 

Term Citation Description Monitoring/Recordke

5.15.48 

VOC 

NWCAA Section 580.34 (12/13/89) 

Openings

All openings not related to safety are to be sealed with suitable closures. 

5.15.49 

VOC 

40 CFR 60 Subpart Kb 60.112b(a)(1)(ii)(B) through (a)(1)(ix) (10/8/97) and 60.113b(a)(4) and (a)(5) (8/11/89), and 60.115b(a)(2) and (a)(4) (4/8/87) as modified by 40 CFR 63.640(n)(8)(v) (5/25/01) 

Roof Openings - Inspection After Degassing

Except for automatic bleeder vents and rim space vents, each opening in the non contact roof shall have a projection below the liquid surface. Except for automatic bleeder vents, rim space vents, column wells, ladder wells, sample wells, and stub drains, each opening in the roof shall be equipped with a gasketed cover, seal, or lid that is to be maintained in a closed position at all times (i.e., no visible gap) except when the device is in use. Automatic bleeder vents are to be closed at all times when the roof is floating except when the roof is being floated off or is being landed on the roof leg supports. Rim vents are to be set to open when the roof is being floated off the roof leg supports or at the manufacturer’s recommended setting. Automatic bleeder vents and rim space vents are to be gasketed. 

Each time the vessel is emptied and devery 10 years, conduct an internal visinspection shows that the floating roof limited to, improper gasketing or unsearefilling. Keep a record of each inspecdate and conditions observed Notify the NWCAA in writing at least 3inspection is unplanned, the notificatio7 days prior to refilling followed immedSubmit in the Periodic Report the date found and corrective action taken. The decision to use a delay of repair extenalternate storage capacity was unavailas soon as possible. 

5.15.50 

VOC 

NWCAA Section 580.32 (12/13/89) which references 40 CFR 60 Subpart Kb 60.112b(a)(1)(i) (10/8/97) 

Roof Floating on Surface

The roof shall be floating on the liquid at all times (i.e., off the roof leg supports) except during initial fill until the roof is lifted off leg supports and when the tank is completely emptied and subsequently refilled. The process of filling, emptying, or refilling when the roof is resting on the leg supports shall be continuous and shall be accomplished as rapidly as possible. 

Keep records of periods when the floatisupports. -directly enforceable- 
BP Cherry Point Ref

Mod

5-118 

Table 5.15- Specifically Applicable Requirements 

Internal Floating Roof Tank 72, 73, 74 (subject to NWCAA 560, NWCAA 580, 40 CFR 60 Subpart Kb 

Permit 

Term Citation Description Monitoring/Recordke

5.15.51 

VOC/ 

HAP 

Title 40 CFR Subpart Kb 60.116b(c) and (e) (12/14/00) 

Maximum True Vapor Pressure

Maintain a record of the VOL stored, the period of storage, and the maximum true vapor pressure of that VOL during the respective storage period. 

Calculate the maximum true vapor presusing known Reid Vapor Pressure and temperature based on the highest expetemperature of the stored product. Maintain records at the facility with this 

5.15.52 

VOC 

NWCAA OAC #527c Condition 2 (12/12/01)

Two of the three tanks may be in gasoline service at any given time. 

Maintain records of material stored in ta-directly enforceable5.15.53 

VOC 

NWCAA OAC #527c Condition 2 and 3 (12/12/01)

Tanks shall follow Subpart Kb. Tanks are subject all applicable NS

including monitoring, performance testi

5.15.54 

General 

NWCAA OAC #527c Condition 4 (12/12/01)

Maintain records of the tank dimensions, capacity, number of turnovers per year, and material stored. 

Keep records of tank turnovers and maMaintain records of dimensions and ca-directly enforceable- 
BP Cherry Point Ref

Mod

5-119 

Table 5.15 - Specifically Applicable Requirements 

Internal Floating Roof Tanks: 12, 13, 15, 16, 19, 20, 23, 29, 33 and 

 (subject to 40 CFR 63 Subpart CC Group 2 Storage Vessel)

Permit 

Term Citation Description Monitoring/Recordke

Note: 40 CFR 63 General Provisions included in Section 3 apply to Subpart CC (affected so

5.15.55 

VOC/ 

HAP 

40 CFR Subpart CC 63.646(2/21/97), which references 40 CFR 63.119(a)(3) which references 40 CFR 63.123(a) (1/17/97) 

Dimensions and Capacities Keep readily 

accessible records of the dimensions and capacities of each Group 2 storage vessel. 

Maintain records at the facility with dim

Table 5.15 - Specifically Applicable Requirements 

Fixed Roof with No Internal Floating Roof Tanks: 28, 30, 32, 34, 37, 38, 70 

(subject to 40 CFR 63 Subpart CC Group 2 Storage Vessel) 

Permit 

Term Citation Description Monitoring/Recordke

Note: 40 CFR 63 General Provisions included in Section 3 apply to Subpart CC (affected so

5.15.56 

VOC/ 

HAP 

40 CFR Subpart CC 63.646(2/21/97), which references 40 CFR 63.119(a)(3) which references 40 CFR 63.123(a) (1/17/97) 

Dimensions and Capacities

Keep readily accessible records of the dimensions and capacities of each Group 2 storage vessel. 

Maintain records at the facility with dim
BP Cherry Point Ref

Mod

5-120 

Table 5.15 – Miscellaneous Tankfarm Requirements 

Permit Term Citation Description Monitoring/Record

Components in HAP Service 

Note: 40 CFR 61 General Provisions included in Section 3 apply to this affected facility

5.15.57 

HAP 

NWCAA OAC No. 562b (3/17/03), Condition 4 and 7 which references 40 CFR 61 Subpart J 61.112(a) which references 40 CFR 61.240 (a), 61.242 -1 through -11 (12/14/00) 

NESHAP Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. Components include: pumps in liquid service, pressure relief valves in gas/liquid service, all sampling connection systems, all open-ended valves or lines, all valves in gas/vapor service or light liquid service, all pumps and valves in heavy liquid service, pressure relief valves in light liquid service, flanges and other connectors. 

Conduct an Equipment Leak proSection 6.2 Applies to the storage vessel asssplitter tower only. 

Note: 40 CFR 63 General Provisions included in Section 3 apply Subpart CC (affected sou

5.15.58 

HAP 

40 CFR 63 Subpart CC 63.648 (a) and (b) (8/18/98) which references 40 CFR 60.480-60.489 (12/14/00) 

Refinery MACT Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak proSection 6.2 
BP Cherry Point Ref

Mod

5-121 

Table 5.15 – Miscellaneous Tankfarm Requirements 

Permit Term Citation Description Monitoring/Recordkeeping/R

Components in VOC Service 

Note: 40 CFR 60 General Provisions included in Section 3 apply to this affected facility 

5.15.59 

VOC 

40 CFR 60 Subpart QQQ 60.692-2 (11/23/88) 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Individual Drain Systems

Each applicable individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. Except where repair is technically impossible without a unit shutdown, when a broken seal, gap, crack or other problem is identified, first efforts at repair shall be made as soon as practicable, but not later than 15 calendar days after identification. 

Conduct Inspections as specified Follow 40 CFR 60 Appendix A M

5.15.60 

VOC 

40 CFR 60 Subpart QQQ 60.692-2 (11/23/88) 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Individual Junction BoxesEach applicable individual junction box shall be equipped with a cover and may have open vent pipe. The vent pipe shall be at least 3 ft in length and not exceed 4-inches in diameter. 

Conduct Inspections as specified Follow 40 CFR 60 Appendix A M
BP Cherry Point Ref

Mod

5-122 

5.16 Shipping, Pumping, and Receiving 5.16.1 Chemical Treaters 

Table 5.16 - Specifically Applicable Requirements for the Chemical Treater Unit 

Permit 

Term Citation Description Monitoring/Recordkeep

Entire Chemical Treater Area 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

Components in VOC Service 

5.16.1 

VOC 

40 CFR 60 Subpart QQQ 60.692-2 (11/23/88), 60.692-5 (10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) 

NSPS Individual Junction Boxes

Each affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. 

Conduct Inspections as specified in Permit 
BP Cherry Point Ref

Mod

5-123 

Table 5.16 - Specifically Applicable Requirements for the Chemical Treater Unit 

Permit 

Term Citation Description Monitoring/Recordkeep

5.16.2 

VOC 

40 CFR 60 Subpart GGG 60.590-60.593 (10/17/00) which references 40 CFR 60.480-60.489 (12/14/00) BP Consent Decree Paragraph 20 

NSPS Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. Components include: pumps in liquid service, pressure relief valves in gas/liquid service, all sampling connection systems, all open-ended valves or lines, all valves in gas/vapor service or light liquid service, all pumps and valves in heavy liquid service, pressure relief valves in light liquid service, flanges and other connectors. 

Conduct an Equipment Leak program (LDAFollow 40 CFR 60 Appendix A Method 21 

Components in HAP Service 

Note: The Title 40 CFR 63 General Provisions included in Section 3 apply 

5.16.3 

HAP 

40 CFR 63 Subpart CC 63.648(a) and (b) (8/18/98) which references 40 CFR 60.480-60.489 (12/14/00) 

Refinery MACT Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. 

Conduct an Equipment Leak program (LDA

Follow 40 CFR 60 Appendix A Method 21 
BP Cherry Point Ref

Mod

5-124 

 5.16.2 Truck Rack 

Table 5.16: Specifically Applicable Requirements for the Truck Rack 

Permit 

Term Citation Description Monitoring/Recordkee

Entire Truck Rack Area 

Components in VOC Service

Note: The Title 40 CFR Parts 60 General Provisions included in Section 3 apply to these affected 

5.16.4 

VOC 

40 CFR 60 Subpart QQQ 60.692-2 (11/23/88) 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) NWCAA OAC #527c Condition 19 (12/12/01) 

NSPS Individual Drain Systems

Each individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. Except where repair is technically impossible without a unit shutdown, when a broken seal, gap, crack or other problem is identified, first efforts at repair shall be made as soon as practicable, but not later than 15 calendar days after identification. 

Conduct Inspections as specified in Perm

5.16. 5 

VOC 

40 CFR 60 Subpart QQQ 60.692-2 (11/23/88), 60.692-5 (10/17/00), 60.697 (10/17/00), and 60.698(b) and (c) (8/18/95) NWCAA OAC #527c Condition 19 (12/12/01) 

NSPS Individual Junction Boxes

Each affected individual junction box shall be equipped with a sealed cover, may have an open vent pipe or may be routed to a closed vent system with a control device such as a carbon canister with no detectable emissions. 

Conduct Inspections as specified in Perm
BP Cherry Point Ref

Mod

5-125 

Table 5.16: Specifically Applicable Requirements for the Truck Rack 

Permit 

Term Citation Description Monitoring/Recordkee

5.16.6 

VOC 

40 CFR 60 Subpart GGG 60.590-60.593 (10/17/00) which references 40 CFR 60.480-60.489 (12/14/00) NWCAA OAC #527c (12/12/01) Conditions 13 & 18 

NSPS Equipment Leaks

Monitor components for fugitive leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. Components include: pumps in liquid service, pressure relief valves in gas/liquid service, all sampling connection systems, all open-ended valves or lines, all valves in gas/vapor service or light liquid service, all pumps and valves in heavy liquid service, pressure relief valves in light liquid service, flanges and other connectors. 

Conduct an Equipment Leak program (L6.2 with the following additions: Each calendar month, the vapor collectiosystem, and each loading rack handling during loading gasoline tank trucks for tovapor leaks. For each detection of a leasource of the leak repaired within 15 caleA record of each monthly leak inspection terminal for at least 2 years. Follow 40 CFR 60 Appendix A Method 2-directly enforceableComponents in HAP Service 

Note: The Title 40 CFR 63 General Provisions included in Section 3 apply 

5.16.7 

HAP 

40 CFR 63 Subpart CC 63.648(a) and (b) (8/18/98) which references 40 CFR 60.480--60.489 (12/14/00) 

Refinery MACT Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV 

Conduct an Equipment Leak program (L6.2 Follow 40 CFR 60 Appendix A Method 2

5.16.8 

HAP 

40 CFR 63 Subpart CC 63.647(c), 63.654(a), 63.654(i)(4) which references 40 CFR 61.340 through 61.355 

Refinery MACT Process Drains

Each applicable individual drain system shall be equipped with a water seal and/or caps and plugs so that VOC emissions are not vented to the atmosphere. 

Conduct inspections as specified in PermFollow 40 CFR 60 Appendix A Method 2
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Table 5.16: Specifically Applicable Requirements for the Truck Rack 

Permit 

Term Citation Description Monitoring/Recordkee

5.16.9 

VOC/ 

HAP 

40 CFR 63 Subpart CC 63.650(a) (6/12/96) which references 40 CFR 63.422(b) (6/26/95), 63.427(a)(3) and (b) (2/28/97), 63.425 (6/26/95) and 

63.428,(c), and (h)(1). (2/28/97) 40 CFR 63 Subpart CC 63.654(b) (8/18/98) which references 40 CFR 63.428(c) and (h)(1) (2/28/97) NWCAA OAC #527c Condition 9 (12/12/01)

Emissions to the atmosphere from the vapor collection and processing systems shall not exceed 10 milligrams of total organic compounds per liter of gasoline loaded. 

The vapor control system shall prevent the emission of at least 90% by weight of VOC’s. 

A thermal oxidation system must have a 

monitoring system (CPMS) capable of mCPMS shall be installed in the firebox or 

downstream of the firebox. Compliance shall be demonstrated biennaccording to EPA Method 25 or another Control Officer. Thirty day advance notic

Submit an excess emissions report to the 

63.10(e)(3). The report shall include eacmaintain, as appropriate, the monitoring exceedance or failure occurred, and a desteps taken to repair or perform maintenaand processing systems. 40 CFR 60 Appendix A Method 21 and Emodified by 40 CFR 60.503 and 63.425 
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Table 5.16: Specifically Applicable Requirements for the Truck Rack 

Permit 

Term Citation Description Monitoring/Recordkee

Truck Rack 

5.16.10 

VOC 

NWCAA OAC #527c Condition 9 (12/12/01) NWCAA 580.424 (12/13/89) WAC 173-491-040(2)(c)(i) and (2)(c)(ii) (12/23/97–state only) 

The vapor control system shall prevent the emission of at least 90 percent by weight of the VOC and shall limit the emission to no more than 35 milligrams VOC per liter of gasoline transferred. 

Comply with AOP Terms 5.16.9. 

In addition, perform biennial testing in ac(2/14/89), and 40 CFR 63.425(a) & (b) (6ppm shall be used to determine the level 60.503(b). Continuously monitor the combustion chaProvide the NWCAA 30 days notice prior NWCAA) and submit the test results to thdays after testing is completed. 40 CFR 60 Appendix A Method 21 and Emodified by 40 CFR 60.503 and 63.425 - directly enforceable - 

5.16.11 

VOC 

40 CFR 63 Subpart CC 63.427(a)(3) and (b) (2/28/97), 63.425 (6/26/95) and 63.428(c) and (h)(1) (2/28/97) 

Operate the vapor processing system in a manner not to go below the operating parameter determined during performance testing, supplemented by engineering assessments and manufacturer’s recommendations that demonstrate continuous compliance with the emission standard. 

 Monitor combustion chamber temperatuensure an average temperature of not les

loading cycle in order to maintain VOC de5.16.10. Operation of the combustion ch

constitute a violation of the emission stan5.16.10. 

Operation at an average temperature of 1

emission standard of 10 milligrams of totaof gasoline loaded will be met. This tempbiannual testing to meet the standard and December 27, 1995 letter from BP. 

Maintain records onsite for 5 years. 40 CFR 60 Appendix A Method 21 and Emodified by 40 CFR 60.503 and 63.425 
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Table 5.16: Specifically Applicable Requirements for the Truck Rack 

Permit 

Term Citation Description Monitoring/Recordkee

5.16.12 

SO2

40 CFR 60 Subpart J 60.104(a)(1),60.105 (a)(4), 60.105(e)(3)(ii) 

Truck Rack – Fuel Gas

Fuel gas used in the combustor shall be pipeline grade natural gas or treated fuel gas meeting the requirements of Subpart J. Treated fuel gas is limited to a concentration of H2S<230 mg/dscm (0.10 gr/dscf). Equivalent to 

162 ppm H2S, 3 hour rolling average. 

Retain records of fuel used for pilot gas. fuels loaded meet the sulfur specification Report to EPA Region 10 and the NWCAfuels loaded, type of gaseous fuel used acombustor or any change in their sulfur sany failures to meet the sulfur specificatioused for the pilot. Reports shall be submchange or failure to meet sulfur specificatFollow 40 CFR 60 Appendix A Method 11 

Truck Rack Terminal 

5.16.13 

General 

NWCAA OAC #527c (12/12/01) Condition 20 

Loadout Capacity

Maximum loadout of gasoline through the terminal shall be limited to 26,000 barrels per day. Total loadout of diesels and jet fuel shall be limited to 76,000 barrels per day combined 

Maintain loadout records for the terminal 

5.16.14 

VOC 

40 CFR 63 Subpart CC 63.650(a) (6/12/96) which references 40 CFR 63.422(a) (6/26/95) which references 40 CFR 60.502(a) and (d) (2/12/99) 

Equip with a vapor collection system designed to collect the total organic compounds vapors displaced from tank trucks during product loading and to prevent any total organic compounds vapors collected at one loading rack from passing to another loading rack. 
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Table 5.16: Specifically Applicable Requirements for the Truck Rack 

Permit 

Term Citation Description Monitoring/Recordkee

5.16.15 

VOC 

NWCAA OAC #527c Condition 10 (12/12/01)

NWCAA 580.425 (12/13/89) 

The vapor control system shall be equipped with an appropriate alarm system to alert personnel when the system is not in compliance with 580.424. 

Operate a functioning interlock system thcargo tank is not in compliance or when tin operation. - directly enforceable - 

5.16.16 

VOC 

NWCAA OAC #527c Conditions 6 & 9 (12/12/01)

NWCAA 580.421 (12/13/89) WAC 173-491-040(2)(b)(i) (12/23/97-state only) 

The loading terminal must employ submerged or bottom loading for all transport tanks and be equipped with a vapor control system. 

Keep written operation and maintenance that all product loading will be submerge combustor shall be operating at all times routed to the device. 

- directly enforceable - 

5.16.17 

VOC 

NWCAA OAC #527c Condition 7 (12/12/01)

NWCAA 580.422 (12/13/89) WAC 173-491-040(2)(b)(iv) (12/23/97-state only) 

All loading and vapor lines shall be equipped with vapor-tight fittings which close automatically upon disconnect. The point of closure shall be on the tank side of any hose or immediate connecting line. 

Keep written procedures onsite specifying vapor control lines shall be equipped with automatically and that the lines are desig- directly enforceable - 

5.16.18 

VOC 

NWCAA OAC #527c Conditions 12 & 15 (12/12/01)

40 CFR 63 Subpart CC 63.650(a) (6/12/96) which references 40 CFR 63.422(a) (6/26/95) which references 40 CFR 60.502(h) and (i) (2/12/99) 

Equipment shall be operated to prevent gauge pressure in the delivery tank from exceeding 4,500 pascals (450 mm of water) during product loading and pressure-vacuum vent in the bulk gasoline terminal's vapor collection system shall not begin to open at a system pressure less than 4,500 pascals. 

Use 40 CFR 60.503(d) (system pressure 
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Table 5.16: Specifically Applicable Requirements for the Truck Rack 

Permit 

Term Citation Description Monitoring/Recordkee

5.16.19 

VOC 

NWCAA OAC #527c Condition 8 (12/12/01) 

NWCAA 580.423 and 580.424 (12/13/89) WAC 173-491-040(2)(b)(ii) and (iii) (12/23/97-state only) 40 CFR 63.425(a) (12/19/03) 

Vapor return lines shall be connected such that all displaced volatile organic compounds are vented to the vapor recovery system. Excludes emissions from pressure relief valves when the back pressure in the collection lines is lower than the relief pressure setting of the transport tank's relief valves. 

Perform biennial testing required by NWCAA CFR 60.503(b) and (d) (2/14/89) except a reaCFR 63.425 (a)(1)(i) shall be used to determiunder 40 CFR 60.503(b). Provide the NWCAA 30 days notice prior to tNWCAA) and submit the test results to the Ntesting is completed. Follow 40 CFR 60.503 and 40 CFR 63.425(a- directly enforceable -

5.16.20 

VOC 

NWCAA 580.104 and 580.1033 (12/13/89) 

WAC 173-491-040(6)(b)(iii)(A)(II), (III), (IV) and (B) (12/23/97-state only) 

System must be operated such that gasoline vapor concentration is less than the lower explosive limit at a distance of 2.5 cm or greater from any potential leak source; and liquid leaks must be less than 3 drops per minute and no more than 10 ml per disconnect (4 drops per minute per WAC 173-491-040). Repair and retest a vapor collection system that exceeds these limits within ten days (15 days per WAC 173-491-040). 

5.16.21 

VOC 

NWCAA OAC #527c Condition 11 (12/12/01) 

NWCAA 580.426 (12/13/89) 

All loading arms shall be designed, maintained and operated to prevent overfill, fugitive liquid or vapor leaks, and excess gasoline drainage during disconnect. 

5.16.22 

VOC 

WAC 173-491-040(6)(b)(iii)(A)(1) and (b)(iii)(B) (12/23/97-state only) 

Transport tank pressure shall not exceed a pressure of eighteen inches of water or a vacuum of six inches of water. Repair and retest a vapor collection system that exceeds this limit within fifteen days. 
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Table 5.16: Specifically Applicable Requirements for the Truck Rack 

Permit 

Term Citation Description Monitoring/Recordkee

5.16.23 

VOC 

WAC 173-491-040(2)(c)(iii) (12/23/97-state only) 

The backpressure in the vapor collection system shall not exceed the transport tank’s pressure relief settings. 

5.16.24 

VOC/ 

HAP 

NWCAA OAC #527c Condition 14 (12/12/01) NWCAA 580.102, 1031, 1032 & 1033 (12/13/89) NWCAA 580.105 (12/13/89) WAC 173-491-040(6)(b)(i ) and WAC 173-491-040(6)(d) (12/23/97) (State only) WAC 173-491-030(4) (7/2/91) (State only) 

Gasoline transport tanks have to be leak tested annually. Ensure that gasoline is loaded only into cargo tanks that pass annual leak checks performed in accordance with Title 40 CFR Appendix A Method 27 and the criteria of NWCAA 580.105. 

Keep a copy of a valid leak tightness testank loaded. In addition, maintain annualoading terminal. Follow EPA Method 27 - directly enforceable - 

5.16.25 

VOC 

NWCAA OAC #527c (Condition 16 (12/12/01) 

Maintain a record of all replacements and additions of components performed on an existing vapor processing system 

Keep records of replacements and additexisting vapor processing system onsite inspection. - directly enforceable - 

5.16.26 

VOC 

NWCAA OAC #527c Condition 17 (12/12/01) 

Calculate emissions from the truck rack on an annual basis. 

Report emissions from truck rack to NWClater than 105 days following the end of t-directly enforceable- 
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Table 5.16: Specifically Applicable Requirements for the Truck Rack 

Permit 

Term Citation Description Monitoring/Recordkee

5.16.27 

VOC/ 

HAP 

40 CFR 63 Subpart CC 63.650(a) (6/12/96) which references 40 CFR 60.502(f) and (g) (2/12/99) and, 60.502(e) (2/12/99) which is modified by 40 CFR 63.422(c) 40 CFR 63 Subpart CC 63.650(a) (6/12/96) which references 40 CFR 63.425(e), (f), (g) and (h) (6/26/95), 63.428(b), 63.428(g)(1) and 63.428(h)(2)-(h)(3) (2/28/97) 40 CFR 63 Subpart CC 63.654(b) (8/18/98) which references 40 CFR 63.428(b), 63.428(g)(1) and 63.428(h)(2)-(h)(3) (2/28/97) 

Loading of liquid product into gasoline tank trucks shall be limited to vapor-tight gasoline tank trucks using the procedures specified at 40 CFR 60.502(e) (as modified by 40 CFR 63.422(c). Assure that loading of gasoline tank trucks is made only into tanks equipped with vapor collection equipment that is compatible with the terminal's vapor collection system and that the terminal's and the tank truck's vapor collection systems are connected during each loading of a gasoline tank truck at the affected facility. 

Ensure that gasoline is loaded only into cargo checks performed in accordance with the critand (h). Obtain the vapor tightness documentation deeach gasoline tank truck loaded at the affecteidentification number as each gasoline tank tcheck each tank identification number with thdocumentation within 2 weeks after the correeither less than an average of one gasoline ta26 weeks is loaded without vapor tightness ddocumentation cross-check shall be performeaverage of one gasoline tank truck per month without vapor tightness documentation then tshall be performed semi-annually. Return to bconditions are not maintained. Notify the owntight gasoline tank truck loaded at the affectecrosscheck. Ensure that the nonvapor-tight greloaded until vapor tightness documentation Maintain records in accordance with 40 CFR certification and continuous performance testname of test, the tank owner's name and addtest location and date, tester name and signaname, signature, and affiliation, nature of reprelation to vapor tightness testing. And test rereport to the NWCAA each loading of a cargo documentation had not been previously obtaiSubmit an excess emissions report to the NW63.10(e)(3), when a nonvapor-tight gasoline ca failure to take steps to assure that the cargbefore vapor tightness documentation was obof a nonvapor-tight gasoline cargo tank beforfor is obtained in accordance with 40 CFR 63Follow 40 CFR 63.425(e), (f), (g) and (h) 
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Table 5.16: Specifically Applicable Requirements for the Truck Rack 

Permit 

Term Citation Description Monitoring/Recordkee

5.16.28 

VOC 

WAC 173-491-040(6)(a) (12/23/97-state only) 

During the months of May, June, July, August, and September any failure of a vapor collection system to comply with WAC 173-491-040 requires the discontinuation of gasoline transfer operations for the failed part of the system. 

Record any periods during these months system failed and actions taken. - directly enforceable - 

5.16.29 

VOC 

WAC 173-491-040(6)(e) (12/23/97-state only) 

Take reasonable measures to prevent the spilling, discarding sewers, storing in open containers, or handling of gasoline in a manner that will result in evaporation to the ambient air. 

Follow the MRR in this table. - directly enforceable - 
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5.16.3 Marine Terminal 

Table 5.16 - Specifically Applicable Requirements for the Marine Terminal 

Permit 

Term 

Citation Description Monitoring/Recordkeep

Marine Terminal 

Components in HAP Service 

Note: 40 CFR 63 General Provisions included in Section 3 apply to these affected facilitie

5.16.30 

HAP 

40 CFR 63 Subpart CC 63.651(a) (8/18/95) which references 40 CFR 63.560 – 60.567(9/19/95) and 63.653(c) (8/18/98) NWCAA OAC #716a Condition 6 (5/3/02)

Refinery MACT Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV 

Conduct an Equipment Leak program (LDAR

Follow 40 CFR 60 Appendix A Method 21 

5.15.31 

VOC 

NWCAA OAC #716a Condition 1 (5/3/02)

40 CFR 63 Subpart CC which references 63.562(a) & (b) (9/19/95) 

The dock shall be equipped with a vapor collection system that is designed to collect VOC vapors displaced from marine terminal loading of all refinery light products. Note: “light petroleum product” is defined as products with vapor pressures greater than or equal to 1.5 psia at standard conditions, 20 C and 760 mmHg. 

Install vapor collection system and perform p5.16.36 through 5.16.38. 
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Table 5.16 - Specifically Applicable Requirements for the Marine Terminal 

Permit 

Term 

Citation Description Monitoring/Recordkeep

5.16.32 

VOC 

NWCAA OAC #716a Conditions 2 & 10 (5/3/02)

40 CFR 63 Subpart CC which references 40 CFR 63.563(a)(2), 63.567 (f)-(i), (k) (9/19/95) 

Marine tank vessel loading of light refinery products at the loading terminals shall be limited to those vessels equipped with vapor collection equipment that is compatible with the terminal’s vapor collection system. 

Maintain onsite records of vessel certification

for 5-years. 

5.16.33 

VOC. 

NWCAA OAC #716a Conditions 3 & 10 (5/3/02)40 CFR 63 Subpart CC which references 40 CFR 63.563(a)(4), 63.567 (f)-(i),(k) (9/19/95) 

Marine tank vessel loading shall be limited to those vessels that are vapor tight and connected to the vapor collection system. 

Maintain onsite records of vessel certificationtightness and loading only while connection 

years. 

5.16.34 

VOC 

NWCAA OAC #716a Conditions 5 & 10 (5/3/02)

Loading

Loading of light refinery products may be performed at the dock without emission control for a period not to exceed 14 days on a rolling 12 month average to allow for maintenance of the vapor collection and control equipment. Note: A “day” is defined is defined as any portion of a calendar day in which loading of light petroleum product is performed without emission control due to maintenance of the vapor collection or control equipment. 

Maintain records onsite for all maintenance pcontrol equipment. Records shall include daduration, other activities being performed at cause of maintenance activity and corrective -directly enforceable - 
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Table 5.16 - Specifically Applicable Requirements for the Marine Terminal 

Permit 

Term 

Citation Description Monitoring/Recordkeep

Vapor Combustion Control 

Note: The Title 40 CFR Parts 60 and 63 General Provisions included in Section 3 apply to these affe

5.16.35 

SO2 (H2S) 

40 CFR 60 Subpart J 60.104(a)(1),60.105 (a)(4), 60.105(e)(3)(ii) NWCAA OAC #716a Condition 11 (5/3/02)

NSPS Subpart J – Fuel Gas

Fuel gas limited to a composition of H2S<230 mg/dscm (0.10 gr/dscf). 

Equivalent to 162 ppm H2S, 3 hour 

rolling average. 

NOTE: The vapor combustor at the Marine Terminal is only supplied with pipeline grade natural gas as its supplementary fuel. 

Use natural gas at vapor combustor to ensu

requirement is not exceeded. 
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Table 5.16 - Specifically Applicable Requirements for the Marine Terminal 

Permit 

Term 

Citation Description Monitoring/Recordkeep

5.16.36 

VOC/ HAP 

40 CFR 63 Subpart CC which references 40 CFR 63.563(b)(4)(ii), 63.564(e)(2) & (4), 63.567 (f)-(k) (9/19/95) NWCAA OAC #716a Conditions 8 & 10 (5/3/02) 

Operation

Temperature within the vapor combustor (as measured at BP point TT-35-261) shall not be below 50 F of the baseline temperature of 1400 F. Temperatures are to be taken no greater than in 15-minute cycles with an accuracy of +/-10 F. 

Temperature within the vapor combustor (as 261) shall not be below 50oF of the 1400oF. 

record the temperature every 15 minutes anaverage temperature each cycle. Install, calibrate, operate and maintain a temaccuracy of +/- 10oF. Temperatures are to b

minute cycles The monitor shall be installed combustion device but not within the combustemperature monitor shall be verified once ereference temperature monitor (traceable to Standards and technology (NIST) standards measurement device dedicated for this purpchecking, the probe of the reference device that of the temperature monitor being tested Maintain records of vapor combustor temperyears. 

5.16.37 

VOC/ HAP 

NWCAA OAC #716a Conditions 4, 8 & 10 (5/3/02)40 CFR 63 Subpart CC which references 40 CFR 63.563(a)(3), 63.563(b)(1), 63.567 (f)-(k) (9/19/95) 

Operation

Thermal oxidation of captured vapors shall reduce VOC by 98% by weight 

Compliance with this term is demonstrated tabove. 
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5.16.4 LPG/LEU/Butane/Pentane Loading 

Table 5.16: Specifically Applicable Requirements for the LPG/LEU Loading 

Permit 

Term Citation Description Monitoring/Recordkeep

LPG/LEU Components in VOC Service 

Note: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilitie

5.16.38 

VOC 

40 CFR 60 Subpart GGG 60.590-60.593 (10/17/00) which references 40 CFR 60.480-60.489 (12/14/00) NWCAA 580.8 (3/13/97) 

NSPS Equipment Leaks

Monitor applicable components for fugitive leaks, repair leaks in a timely manner, and report monitoring results semi-annually in accordance with 40 CFR 60 Subpart VV. Applicable components include: pumps in liquid service, pressure relief valves in gas/liquid service, all sampling connection systems, all open-ended valves or lines, all valves in gas/vapor service or light liquid service, all pumps and valves in heavy liquid service, pressure relief valves in light liquid service, flanges and other connectors. 

Conduct an Equipment Leak program (LDARFollow 40 CFR 60 Appendix A Method 21
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5.17 Non-Hazardous Waste Landfarm 

Table 5.17: Specifically Applicable Requirements for the Non-Hazardous Waste Land

Permit 

Term Citation Description Monitoring/Recordkeep

5.17.1 

VOC 

NWCAA NOC #382 Condition 2 (7/30/92)

Estimate area emissions from landfarming activities 

Report emissions from landfarm on an annuinventory report. 
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SECTION 6 - SPECIFICALLY APPLICABLE COMMON REQUIREMENTS Section 6 of this AOP contains requirements that are common to various emission units at the source. 

monitoring, recordkeeping and reporting requirements for visual emissions from combustion units at threquirements specified in Section 6.2 are applicable to the applicable process unit components in VOCSection 5 of the AOP. Section 6.3 is applicable to newly constructed process units that were required 

monitoring provisions included in their Orders of Approval to Construct (OAC). The requirements specified in the “Citation” column, and incorporated herein by reference, are federall

identified as “state only”. “State only” requirements are not enforceable by EPA or citizens under the Ccolumn is a brief description of the applicable requirements for informational purposes only and is not econtinuous monitoring requirements (including testing) are specified in the “Monitoring, Recordkeeping which identifies monitoring, recordkeeping and reporting (MR&R) obligations the source must perform 

401-605(1) and 615(1) and (2) or the underlying requirement. MR&R obligations do not apply to insignThe requirements in the MR&R column labeled “directly enforceable” are legally enforceable requireme

NWCAA’s “gap-filling” authority. Other requirements not labeled “directly enforceable” are brief descrip

requirements for information purposes, and are not enforceable. Unless the text of the MR&R column be directly enforceable, the language of the cited regulation takes precedence over a paraphrased reqThe commonly referenced requirements are listed as follows. 6.1 Visual Emissions Monitoring6.2 Equipment Leak Program (LDAR)

6.3 Enhanced Leak Detection Program 
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6-2

6.1 Visual Emissions Monitoring  Monitoring recordkeeping and reporting for combustion units is as follows: Combustion units burning oil, visually observe stacks on a daily basis to qualitatively assess whether emissions 

may be reduced to weekly if no visible emissions are observed for thirty consecutive days. The permittee shall 

of individual stacks if any visible emissions are noted during the observation. Daily quantitative assessments are burning is conducted for the purpose of testing or training and does not exceed four hours per calendar month, 

For combustion units burning gaseous fuels, visually observe stacks monthly to qualitatively assess whether em

frequency may be reduced to quarterly if no visible emissions are observed for six consecutive months. The pe

monthly observations of individual stacks if any visible emissions are noted during the observation. If visible emissions are observed, emissions shall be reduced to zero as soon as possible. If emissions cannot 

permittee may monitor by Ecology Method 9A no later than 24 hours after detection and daily thereafter until opthan the applicable opacity standard. Otherwise visual emissions shall be considered in excess of the opacity sRecord observation results for stacks with visible emissions and any related equipment or operational failure, thtimes, actions taken, and the type of fuel burned. Record that an observation was performed, with date, time, bidentification of the observer. Keep records of all observations available for inspection.  - Directly Enforceable - 
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6-3

6.2 Equipment Leak Program (LDAR) The BP Cherry Point Refinery is regulated under several fugitive emission MR&R requirements that together, corefinery. These are 40 CFR 60.480 (NSPS Subpart VV), 40 CFR 60.590 (NSPS Subpart GGG), 40 CFR 61.110 Subpart J), 40 CFR 61.240 (NESHAP Subpart V), and 40 CFR 63.640 (NESHAP Subpart CC). In order to demregulations cross reference each other to avoid duplication of LDAR strategies and reporting. The BP Cherry Point Refinery has selected to demonstrate compliance with the above cited regulations using th

in 40 CFR 60.480 (NSPS Subpart VV) as allowed under 40 CFR 60.592 and 40 CFR 63.640(p) for the applicabfollowing presents the LDAR MR&Rs as required under 40 CFR 60.480 (NSPS Subpart VV). 

6.2 - Commonly Referenced Monitoring Recordkeeping and Reporting Requireme

Equipment Leak Program (LDAR) for Following Units: 

Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hy

 Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving A

Permit 

Term Citation Description Monitoring, Recordkee

Note: The Title 40 CFR Parts 60, 61 and 63 General Provisions included in Section 3 apply to these affe

6.2.1 

VOC/ HAP 

40 CFR 60 Subpart VV 60.482-2(a), (b), and (c) (12/14/00), 60.485 (b) (10/17/00), 60.486(b), (c) and (e) (12/14/00) and 60.487(c), and (e) (10/17/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Pumps in Light Liquid Service, Without Dual Mechanical 

Seals

Monitor each applicable pump monthly to detect leaks. Visually inspect each calendar week. If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. If there are indications of liquids dripping from the pump seal, a leak is detected. When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR 60.482-9. A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. When a leak is detected, a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached. The identification 

may be removed after it has been repaired. 

Each calendar week, visually inspect edripping from the pump seal. Monthly, instrument monitor using 40 Cinstrument shall be calibrated before uscalibration gases shall be used: Zero ahydrocarbon in air); and a mixture of mconcentration of about 10,000 ppm meWhen a leak is detected, record the inf60.486(c) For all equipment subject to this permit accessible location the information reqSubmit a semi-annual report including 60.487(c). Report the results of all performance te

General Provisions. 
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6.2 - Commonly Referenced Monitoring Recordkeeping and Reporting Requireme

Equipment Leak Program (LDAR) for Following Units: 

Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hy

 Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving A

Permit 

Term Citation Description Monitoring, Recordkee

6.2.2 

VOC/ HAP 

40 CFR 60 Subpart VV 60.482-2(d) (12/14/00), 60.485(b) (10/17/00), 60.486(b), (c), (e),(h) (12/14/00), and 60.487(c), and (e) (10/17/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Applicable Pumps in Light Liquid Service, With Dual 

Mechanical Seals Including A Barrier Fluid System

Operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box pressure, or purge the barrier fluid into a process stream with zero VOC emissions to the atmosphere. The barrier fluid system should be in heavy liquid service or not in VOC service. Equip each barrier fluid system with a sensor that will detect failure of the seal system, the barrier fluid system, or both. Check each sensor daily or equip the sensor with an audible alarm. Determine, based on design considerations and operating experience, a criterion that indicates failure of the seal system, the barrier fluid system, or both. If there are indications of liquids dripping from the pump seal, or the sensor indicates failure of the seal system, the barrier fluid system, or both, a leak is detected. Repair a leak as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR 60.482-9. A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. When a leak is detected, a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached. 

Each calendar week, visually inspect edripping from the pump seal. When a leak is detected, record the inf60.486(c). If the sensor is not equipped with an auFor all equipment subject to this permit accessible location the information reqThe design criterion required must be raccessible. An explanation of the desicriterion ( and reasons for the changesSubmit a semi-annual report including 60.487(c). Use 40 CFR Part 60 Method 21. 
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6.2 - Commonly Referenced Monitoring Recordkeeping and Reporting Requireme

Equipment Leak Program (LDAR) for Following Units: 

Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hy

 Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving A

Permit 

Term Citation Description Monitoring, Recordkee

6.2.3 

VOC/ HAP 

40 CFR 60 Subpart VV 60.482-3 (12/14/00), and 60.486(b), (c), (e) and (h) (12/14/00), and 60.487(c), and (e) (10/17/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Compressors

Equip each applicable compressor with a seal system that includes a barrier fluid system and that prevents leakage of VOC to the atmosphere. Operate the seal system with a barrier fluid at a pressure that is greater than the compressor stuffing box pressure, or, purge the barrier fluid into a process stream with zero VOC emissions to the atmosphere. The barrier fluid system shall be in heavy liquid service or shall not be in VOC service. Equip each barrier fluid system with a sensor that will detect failure of the seal system, the barrier fluid system, or both. Check each sensor daily or equip the sensor with an audible alarm. Determine, based on design considerations and operating experience, a criterion that indicates failure of the seal system, the barrier fluid system, or both. If the sensor indicates failure of the seal system, the barrier fluid system, or both, a leak is detected. When a leak is detected, a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached. The identification may be removed after it has been repaired. When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR 60.482-9. A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. 

When a leak is detected, record the inf60.486(c). For all equipment subject to this permit accessible location the information reqThe design criterion must be recorded accessible. An explanation of the desicriterion (and reasons for the changes) Submit a semi-annual report including 60.487(c). If the sensor is not equipped with an auUse 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

Mod

6-6

6.2 - Commonly Referenced Monitoring Recordkeeping and Reporting Requireme

Equipment Leak Program (LDAR) for Following Units: 

Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hy

 Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving A

Permit 

Term Citation Description Monitoring, Recordkee

6.2.4 

VOC/ HAP 

40 CFR 60 Subpart VV 60.482-4 (12/14/00), 60.485 (c) (10/17/00), 60.486( d) and (e) (12/14/00), and 60.487(c) and (e) (10/17/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Pressure Relief Devices

Except during pressure releases, each applicable pressure relief device in gas/vapor service shall be operated with no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background. After each pressure release, the pressure relief device shall be returned to a condition of no detectable emissions as soon as practicable, but no later than 5 calendar days after the pressure release, except as provided in 40 CFR 60.482-9. Any pressure relief device routed to the fuel gas system or equipped with a closed vent system a control device is exempt from this requirement. Any pressure relief device equipped with a rupture disk upstream of the pressure relief device is exempt from this requirement, provided that after each release a new rupture disk is installed as soon as practicable, but no later than 5 calendar days after each pressure release, except as provided in 40 CFR 60.482-9. 

For pressure relief devices not routed tvent system/control device, and withoumonitor the pressure relief device no larelease. For pressure relief devices required to list of equipment identification numbers location. Also record the date of each level measured during the compliance reading. Submit a semi-annual report with the faas per 40 CFR 60.482-9, and the dates 

occurred within the semi-annual reportReport the results of all performance te60.8 of the General Provisions. The instrument used to monitor leaks sday of use. The following calibration gathan 10 ppm of hydrocarbon in air); and 

and air at a concentration of about 10,0Use 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

Mod

6-7

6.2 - Commonly Referenced Monitoring Recordkeeping and Reporting Requireme

Equipment Leak Program (LDAR) for Following Units: 

Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hy

 Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving A

Permit 

Term Citation Description Monitoring, Recordkee

6.2.5 

VOC/ HAP 

40 CFR 60 Subpart VV 60.482-5 (12/14/00) and 60.486(e) (12/14/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Sampling Connection Systems

Each applicable sampling connection system shall be equipped with a closed-purged, closed-loop, or closedvent system (except for in situ sampling systems and sampling systems without purges). Gases displaced during sample container filling are not required to be collected or captured. The purged process fluid must be returned directly to the process line; or collected and recycled to a process; or, transported to a control device that complies with the requirements of 60.482-10, or collected and transported to a waste management unit subject to 40 CFR Part 63 Subpart G, or a treatment, storage, or disposal facility submit to 40 CFR part 262, 264, 265, or 266, or a facility permitted, licensed, or registered by a State to manage municipal or industrial solid waste, if the process fluids are not hazardous waste. 

The permittee shall maintain a list of idsubject to the requirements of this condUse 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

Mod

6-8

6.2 - Commonly Referenced Monitoring Recordkeeping and Reporting Requireme

Equipment Leak Program (LDAR) for Following Units: 

Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hy

 Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving A

Permit 

Term Citation Description Monitoring, Recordkee

6.2.6 

VOC/ HAP 

40 CFR 60 Subpart VV 60.482-6 (12/14/00), and 60.486(e) (12/14/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Open-ended Valves or Lines

Each applicable open-ended valve or line shall be equipped with a cap, blind flange, plug, or a second valve that seals the open end at all times except during operations requiring process fluid flow. Each open-ended valve or line equipped with a second valve shall be operated in a manner such that the valve on the process fluid end is closed before the second valve is closed. When a double block-and-bleed system is being used, the bleed valve or line may remain open during operations that require venting the line between the block valves, but shall remain closed at other times. Open-ended valves or lines in an emergency shutdown system which are designed to open automatically in the event of a process upset are exempt. Likewise, openended valves or lines containing materials which would polymerize or would present an explosion, serious overpressure, or other safety hazard if capped or equipped with a double block and bleed system is exempt. 

For all equipment subject to this permit accessible location a list of identificatiothe requirements of this condition. Use 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

Mod

6-9

6.2 - Commonly Referenced Monitoring Recordkeeping and Reporting Requireme

Equipment Leak Program (LDAR) for Following Units: 

Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hy

 Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving A

Permit 

Term Citation Description Monitoring, Recordkee

6.2.7 

VOC/ HAP 

40 CFR 60 Subpart VV 60.482-8 (12/14/00), 60.485(b) (10/17/00), 60.486(b), (c) and (e) (12/14/00), and 60.487(c) (10/17/00) 

Applicable Pumps and Valves in Heavy Liquid Service, 

Pressure Relief Devices in Light Liquid or Heavy Liquid Service, and Flanges and Other Connectors

If evidence of a potential leak is found by visual, audible, olfactory, or any other detection method, either monitor within 5 days or eliminate the visual, audible, olfactory, or other indication of potential leak. If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR 60.482-9. The first attempt at repair shall be made no later than 5 calendar days after each detected leak. First attempts at repair include, but are not limited to, (1) tightening of bonnet bolts, (2) replacement of bonnet bolts, (3) tightening of packing gland nuts; and (4) injection of lubricant into lubricated packing. When a leak is detected, a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached. The identification may be removed after it has been repaired. 

When a leak is detected, record the inf60.486(c). For all equipment subject to 

a readily accessible location a list of idesubject to this requirement.. The instrument used to monitor for leakeach day of use. The following calibrat(less than 10 ppm of hydrocarbon in aihexane and air at a concentration of abhexane. Submit a semi-annual report with the faas per 40 CFR 60.482-9, and the dates occurred within the semi-annual reportUse 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

Mod

6-10

6.2 - Commonly Referenced Monitoring Recordkeeping and Reporting Requireme

Equipment Leak Program (LDAR) for Following Units: 

Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hy

 Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving A

Permit 

Term Citation Description Monitoring, Recordkee

6.2.8 

VOC/ HAP 

40 CFR 60 Subpart VV 60.482-9 (12/14/00) and 60.487(c)(vii) (10/17/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Delay of Repair

Delay of repair of applicable equipment for which leaks have been detected will be allowed if repair within 15 days is technically infeasible without a process unit shutdown. Repair shall occur before the end of the next process unit shutdown. Delay is also allowed for equipment isolated from the process and which does not remain in VOC service. Valves: Delay of repair will be allowed if (1) it is demonstrated that purged material resulting from immediate repair are greater than the fugitive emissions likely to result from delay of repair, and (2) when repair procedures are effected, the purged material is collected and destroyed or recovered in a control device complying with 40 CFR 60.482-10. Delay of repair beyond a process unit shutdown will be allowed if valve assembly replacement is necessary, valve assembly supplies have been depleted, and supplies had been sufficiently stocked before they were depleted. Delay of repair beyond the next process unit shutdown will not be allowed unless the next process unit shutdown occurs sooner than 6 months after the first process unit shutdown. Pumps: Delay of repair will be allowed if (1) repair requires the use of a dual mechanical seal system that includes a barrier fluid system, and (2) repair is completed as soon as practicable, but not later than 6 months after the leak was detected. 

Report, in a semi-annual report, the facand, where appropriate, why a process infeasible. Use 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

Mod

6-11

6.2 - Commonly Referenced Monitoring Recordkeeping and Reporting Requireme

Equipment Leak Program (LDAR) for Following Units: 

Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hy

 Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving A

Permit 

Term Citation Description Monitoring, Recordkee

6.2.9 

VOC/ HAP 

40 CFR 60 Subpart VV 60.482-7 (12/14/00), 60.483-2 (12/14/00), 60.486(e) (12/14/00), and 60.487(c), (d) and (e) (10/17/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Standards for Valves in Gas and Light Liquid Service and 

Alternative Standards for Valves – Skip Period Leak Detection and Repair

Monitor valves according to one of the following options: 

1) Quarterly monitoring with no ability to skip periods. 2) Sustainable skip period program 

(A leak is defined as follows: an instrument reading of 10,000 ppm or greater.) 

BP shall make a “first attempt” at repair for any valve after each leak is detected according to the provisions in 40 CFR 60.482-7 (d)(2). When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR 60.482-9. The first attempt at repair shall be made no later than 5 calendar days after each detected leak. First attempts at repair include, but are not limited to, (1) Tightening of bonnet bolts, (2) Replacement of bonnet bolts, (3) Tightening of packing gland nuts; and (4) Injection of lubricant into lubricated packing. 

Instrument monitor valves on a monthly CFR 60.482-7. A. The facility may elect to follow a le

using the criteria: 1) At process units that have les

consecutive months, monitor 

beginning with the next quarte

2) After 2 consecutive quarterly l

percent leaking less than or eonce every 2 quarters. 

3) After 5 consecutive semi-annu

percent of valves leaking is leeach valve once every 4 quar

B. Facility must return to a more freque

following criteria: 1) If a process unit on a quarterly

has a leak percentage greater detection period, monitor valvthe criteria listed in A. above. 

The leak percentage shall be determinfor which leaks are detected by the numlight liquid service within the affected faThe instrument shall be calibrated befo21. The following calibration gases shappm of hydrocarbon in air); and a mixtuat a concentration of about 10,000 ppm For all equipment subject to this permit accessible location the information reqSubmit a semi-annual report including and report the results of all performancthe General Provisions. 
BP Cherry Point Ref

Mod

6-12

6.2 - Commonly Referenced Monitoring Recordkeeping and Reporting Requireme

Equipment Leak Program (LDAR) for Following Units: 

Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hy

 Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving A

Permit 

Term Citation Description Monitoring, Recordkee

6.2.10 

VOC/ HAP 

40 CFR 60 Subpart VV 60.485(d) (10/17/00) and 60.486(j) (12/14/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Process Units Not in VOC Service

Each piece of equipment shall be tested unless the owner or operator demonstrates that a process unit is not in VOC service, i.e., that the VOC content would never be reasonably expected to exceed 10 % by weight. 

To demonstrate that a process unit is n

procedures that conform to the genera69 (incorporated by reference in 40 CFthe organic compounds are considered photochemical reactivity, or, (3) use enVOC content, if a piece of equipment hbe in service. Information and data used to demonstrin VOC service shall be recorded in a loaccessible location. 
BP Cherry Point Ref

Mod

6-13

6.3 Enhanced Equipment Leak Program (Enhanced LDAR) 

6.3a New Processing Units Subject to Enhanced LDAR 

Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requi

Enhanced Equipment Leak Program (Enhanced LDAR) for the following Unit

Isomerization Unit, #2 DHDS Unit

Permit 

Term Citation Description Monitoring, Recordke

6.3.1 

VOC/ 

HAP 

40 CFR 60 Subpart VV 60.482-2(a), (b) and (c) (12/14/00), 60.485(b) (10/17/00), 60.486(b), (c) and (e) (12/14/00) and 60.487(c),and (e) (10/17/00) as modified by OAC #814a Condition 6 issued 3/24/04 for the Isomerization Unit and by OAC #892 Condition 6 issued 3/3/05 for the #2 Diesel HDU. 

Enhanced Standards for Pumps in Light Liquid 

Service on the Hydrocracker (for the incremental VGO Project) and the #2 DHDU

Monitor each pump no less frequently than quarterly to detect leaks. Visually inspect each calendar week. If an instrument reading of 2,000 ppm or greater is measured, a leak is detected. If there are indications of liquids dripping from the pump seal, a leak is detected. If a pump is a leak is detected at a level between 2000 ppm and 10,000 ppm , it shall be repaired and re-monitored within 30 calendar days after it is detected. If a leak greater than 10,000 ppm is detected, follow provisions detailed in Subpart VV. When a leak is detected, a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached. The identification may be removed after it has been repaired. 

Instrument monitor valves in accomodified by the associated OAC. Each calendar week, visually inspliquids dripping from the pump seaMonthly, instrument monitor using The instrument shall be calibrated following calibration gases shall bppm of hydrocarbon in air); and a and air at a concentration of aboumethane or n-hexane. When a leak is detected, record th60.486(c). For all equipment subject to this preadily accessible location the infoSubmit a semi-annual report inclu

60.487(c). Report the results of all performanof the General Provisions. -directly enforceable- 
BP Cherry Point Ref

Mod

6-14

Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requi

Enhanced Equipment Leak Program (Enhanced LDAR) for the following Unit

Isomerization Unit, #2 DHDS Unit

Permit 

Term Citation Description Monitoring, Recordke

6.3.2 

VOC/ 

HAP 

40 CFR 60 Subpart VV 60.482-7 (12/14/00), 60.483-2 (12/14/00), 60.486(e) (12/14/00), and 60.487(c) (d) and (e) (10/17/00) as modified by OAC #814a Condition 6 issued 3/24/04 for the Isomerization Unit and by OAC #892 Condition 6 issued 3/3/05 for the #2 Diesel HDU. 

Enhanced Standards for Block Valves and Control 

Valves on the Isomerization Unit, the Hydrocracker Unit (for the Incremental VGO Project), the #2DHDU and the #1 DHDU

If an instrument reading of 500 ppm or greater is measured, a leak is detected. Monitor valves no less frequently than quarterly to detect leaks. When a leak is detected at a level between 500 ppm and 10,000 ppm, it shall be repaired and remonitored within 30 calendar days after it is detected. If a leak greater than 10,000 ppm is detected, follow provisions detailed in Subpart VV. First attempts at repair include, but are not limited to: (1) tightening of bonnet bolts, (2) replacement of bonnet bolts, (3) tightening of packing gland nuts; and (4) injection of lubricant into lubricated packing. 

Instrument monitor valves in accomodified by the associated OAC. The instrument shall be calibrated Method 21. The following calibratair (less than 10 ppm of hydrocarbmethane or n-hexane and air at a 500 ppm methane or n-hexane. For all equipment subject to this preadily accessible location the infoSubmit a semi-annual report inclu60.487(c). Report the results of all performanof the General Provisions. -directly enforceable- 
BP Cherry Point Ref

Mod

6-15

Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requi

Enhanced Equipment Leak Program (Enhanced LDAR) for the following Unit

Isomerization Unit, #2 DHDS Unit

Permit 

Term Citation Description Monitoring, Recordke

6.3.3 

VOC/ 

HAP 

40 CFR 60 Subpart VV 60.482-2(a), (b), and (c) (12/14/00), 60.485 (b) (10/17/00), 60.486(b), (c) and (e) (12/14/00) and 60.487(c), and (e) (10/17/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Pumps in Light Liquid Service, Without Dual 

Mechanical Seals

Monitor each applicable pump monthly to detect leaks. Visually inspect each calendar week. If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. If there are indications of liquids dripping from the pump seal, a leak is detected. When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR 60.482-9. A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. When a leak is detected, a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached. The identification may be removed after it has been repaired. 

Each calendar week, visually inspliquids dripping from the pump seaMonthly, instrument monitor using The instrument shall be calibrated following calibration gases shall bppm of hydrocarbon in air); and a 

and air at a concentration of abouhexane. When a leak is detected, record thCFR 60.486(c) For all equipment subject to this preadily accessible location the info60.486(e). Submit a semi-annual report incluCFR 60.487(c). Report the results of all performanof the General Provisions. 
BP Cherry Point Ref

Mod

6-16

Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requi

Enhanced Equipment Leak Program (Enhanced LDAR) for the following Unit

Isomerization Unit, #2 DHDS Unit

Permit 

Term Citation Description Monitoring, Recordke

6.3.4 

VOC/ 

HAP 

40 CFR 60 Subpart VV 60.482-2(d) (12/14/00), 60.485(b) (10/17/00), 60.486(b), (c), (e),(h) (12/14/00), and 60.487(c), and (e) (10/17/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Applicable Pumps in Light Liquid Service, With Dual 

Mechanical Seals Including A Barrier Fluid System

Operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box pressure, or purge the barrier fluid into a process stream with zero VOC emissions to the atmosphere. The barrier fluid system should be in heavy liquid service or not in VOC service. Equip each barrier fluid system with a sensor that will detect failure of the seal system, the barrier fluid system, or both. Check each sensor daily or equip the sensor with an audible alarm. Determine, based on design considerations and operating experience, a criterion that indicates failure of the seal system, the barrier fluid system, or both. If there are indications of liquids dripping from the pump seal, or the sensor indicates failure of the seal system, the barrier fluid system, or both, a leak is detected. Repair a leak as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR 60.482-9. A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. When a leak is detected, a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached. 

Each calendar week, visually inspliquids dripping from the pump seaWhen a leak is detected, record thCFR 60.486(c). If the sensor is not equipped with daily. For all equipment subject to this preadily accessible location the info60.486(e). The design criterion required musreadily accessible. An explanatiochanges to the criterion ( and reaskept as well. Submit a semi-annual report incluCFR 60.487(c). Use 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

Mod

6-17

Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requi

Enhanced Equipment Leak Program (Enhanced LDAR) for the following Unit

Isomerization Unit, #2 DHDS Unit

Permit 

Term Citation Description Monitoring, Recordke

6.3.5 

VOC/ 

HAP 

40 CFR 60 Subpart VV 60.482-3 (12/14/00), and 60.486(b), (c), (e) and (h) (12/14/00), and 60.487(c), and (e) (10/17/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Compressors

Equip each applicable compressor with a seal system that includes a barrier fluid system and that prevents leakage of VOC to the atmosphere. Operate the seal system with a barrier fluid at a pressure that is greater than the compressor stuffing box pressure, or, purge the barrier fluid into a process stream with zero VOC emissions to the atmosphere. The barrier fluid system shall be in heavy liquid service or shall not be in VOC service. Equip each barrier fluid system with a sensor that will detect failure of the seal system, the barrier fluid system, or both. Check each sensor daily or equip the sensor with an audible alarm. Determine, based on design considerations and operating experience, a criterion that indicates failure of the seal system, the barrier fluid system, or both. If the sensor indicates failure of the seal system, the barrier fluid system, or both, a leak is detected. When a leak is detected, a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached. The identification may be removed after it has been repaired. When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR 60.482-9. A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. 

When a leak is detected, record thCFR 60.486(c). For all equipment subject to this preadily accessible location the info60.486(e) The design criterion must be recoaccessible. An explanation of the changes to the criterion (and reaskept as well. Submit a semi-annual report incluCFR 60.487(c). If the sensor is not equipped with daily. Use 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

Mod

6-18

Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requi

Enhanced Equipment Leak Program (Enhanced LDAR) for the following Unit

Isomerization Unit, #2 DHDS Unit

Permit 

Term Citation Description Monitoring, Recordke

6.3.6 

VOC/ 

HAP 

40 CFR 60 Subpart VV 60.482-4 (12/14/00), 60.485 (c) (10/17/00), 60.486( d) and (e) (12/14/00), and 60.487(c) and (e) (10/17/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Pressure Relief Devices

Except during pressure releases, each applicable pressure relief device in gas/vapor service shall be operated with no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background. After each pressure release, the pressure relief device shall be returned to a condition of no detectable emissions as soon as practicable, but no later than 5 calendar days after the pressure release, except as provided in 40 CFR 60.482-9. Any pressure relief device routed to the fuel gas system or equipped with a closed vent system a control device is exempt from this requirement. Any pressure relief device equipped with a rupture disk upstream of the pressure relief device is exempt from this requirement, provided that after each release a new rupture disk is installed as soon as practicable, but no later than 5 calendar days after each pressure release, except as provided in 40 CFR 60.482-9. 

For pressure relief devices not rouclosed vent system/control devicerelease occurs, monitor the presscalendar days after the release. For pressure relief devices requirerecord a list of equipment identificreadily accessible location. Also compliance test, the background lcompliance test, and the maximum Submit a semi-annual report with 

of repair as per 40 CFR 60.482-9, shutdowns which occurred within period. Report the results of all performanCFR 60.8 of the General ProvisionThe instrument used to monitor leuse each day of use. The followinused: Zero air (less than 10 ppm mixture of methane or n-hexane aabout 10,000 ppm methane or n-hUse 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

Mod

6-19

Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requi

Enhanced Equipment Leak Program (Enhanced LDAR) for the following Unit

Isomerization Unit, #2 DHDS Unit

Permit 

Term Citation Description Monitoring, Recordke

6.3.7 

VOC/ 

HAP 

40 CFR 60 Subpart VV 60.482-5 (12/14/00) and 60.486(e) (12/14/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Sampling Connection Systems

Each applicable sampling connection system shall be equipped with a closed-purged, closed-loop, or closed-vent system (except for in situ sampling systems and sampling systems without purges). Gases displaced during sample container filling are not required to be collected or captured. The purged process fluid must be returned directly to the process line; or collected and recycled to a process; or, transported to a control device that complies with the requirements of 60.482-10, or collected and transported to a waste management unit subject to 40 CFR Part 63 Subpart G, or a treatment, storage, or disposal facility submit to 40 CFR part 262, 264, 265, or 266, or a facility permitted, licensed, or registered by a State to manage municipal or industrial solid waste, if the process fluids are not hazardous waste. 

The permittee shall maintain a list equipment subject to the requiremUse 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

Mod

6-20

Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requi

Enhanced Equipment Leak Program (Enhanced LDAR) for the following Unit

Isomerization Unit, #2 DHDS Unit

Permit 

Term Citation Description Monitoring, Recordke

6.3.8 

VOC/ 

HAP 

40 CFR 60 Subpart VV 60.482-6 (12/14/00), and 60.486(e) (12/14/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Open-ended Valves or Lines

Each applicable open-ended valve or line shall be equipped with a cap, blind flange, plug, or a second valve that seals the open end at all times except during operations requiring process fluid flow. Each open-ended valve or line equipped with a second valve shall be operated in a manner such that the valve on the process fluid end is closed before the second valve is closed. When a double block-and-bleed system is being used, the bleed valve or line may remain open during operations that require venting the line between the block valves, but shall remain closed at other times. Open-ended valves or lines in an emergency shutdown system which are designed to open automatically in the event of a process upset are exempt. Likewise, open-ended valves or lines containing materials which would polymerize or would present an explosion, serious overpressure, or other safety hazard if capped or equipped with a double block and bleed system is exempt. 

For all equipment subject to this preadily accessible location a list oequipment subject to the requiremUse 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

Mod

6-21

Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requi

Enhanced Equipment Leak Program (Enhanced LDAR) for the following Unit

Isomerization Unit, #2 DHDS Unit

Permit 

Term Citation Description Monitoring, Recordke

6.3.9 

VOC/ 

HAP 

40 CFR 60 Subpart VV 60.482-8 (12/14/00), 60.485(b) (10/17/00), 60.486(b), (c) and (e) (12/14/00), and 60.487(c) (10/17/00) 

Applicable Pumps and Valves in Heavy Liquid 

Service, Pressure Relief Devices in Light Liquid or Heavy Liquid Service, and Flanges and Other Connectors

If evidence of a potential leak is found by visual, audible, olfactory, or any other detection method, either monitor within 5 days or eliminate the visual, audible, olfactory, or other indication of potential leak. If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR 60.482-9. The first attempt at repair shall be made no later than 5 calendar days after each detected leak. First attempts at repair include, but are not limited to, (1) tightening of bonnet bolts, (2) replacement of bonnet bolts, (3) tightening of packing gland nuts; and (4) injection of lubricant into lubricated packing. When a leak is detected, a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached. The identification may be removed after it has been repaired. 

When a leak is detected, record thCFR 60.486(c). For all equipmen

record in a log in a readily access

numbers for equipment subject to The instrument used to monitor fouse each day of use. The followinused: Zero air (less than 10 ppm mixture of methane or n-hexane aabout 10,000 ppm methane or n-hSubmit a semi-annual report with of repair as per 40 CFR 60.482-9, shutdowns which occurred within period. Use 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

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Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requi

Enhanced Equipment Leak Program (Enhanced LDAR) for the following Unit

Isomerization Unit, #2 DHDS Unit

Permit 

Term Citation Description Monitoring, Recordke

6.3.10 

VOC/ 

HAP 

40 CFR 60 Subpart VV 60.482-9 (12/14/00) and 60.487(c)(vii) (10/17/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Delay of Repair

Delay of repair of applicable equipment for which leaks have been detected will be allowed if repair within 15 days is technically infeasible without a process unit shutdown. Repair shall occur before the end of the next process unit shutdown. Delay is also allowed for equipment isolated from the process and which does not remain in VOC service. Valves: Delay of repair will be allowed if (1) it is demonstrated that purged material resulting from immediate repair are greater than the fugitive emissions likely to result from delay of repair, and (2) when repair procedures are effected, the purged material is collected and destroyed or recovered in a control device complying with 40 CFR 60.482-10. Delay of repair beyond a process unit shutdown will be allowed if valve assembly replacement is necessary, valve assembly supplies have been depleted, and supplies had been sufficiently stocked before they were depleted. Delay of repair beyond the next process unit shutdown will not be allowed unless the next process unit shutdown occurs sooner than 6 months after the first process unit shutdown. Pumps: Delay of repair will be allowed if (1) repair requires the use of a dual mechanical seal system that includes a barrier fluid system, and (2) repair is completed as soon as practicable, but not later than 6 months after the leak was detected. 

Report, in a semi-annual report, thof repair and, where appropriate, was technically infeasible. Use 40 CFR Part 60 Method 21. 
BP Cherry Point Ref

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Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requi

Enhanced Equipment Leak Program (Enhanced LDAR) for the following Unit

Isomerization Unit, #2 DHDS Unit

Permit 

Term Citation Description Monitoring, Recordke

6.3.11 

VOC/ 

HAP 

40 CFR 60 Subpart VV 60.485(d) (10/17/00) and 60.486(j) (12/14/00) 40 CFR 63.648(a) which references 40 CFR 60 Subpart VV (8/18/98) 

Process Units Not in VOC Service

Each piece of equipment shall be tested unless the owner or operator demonstrates that a process unit is not in VOC service, i.e., that the VOC content would never be reasonably expected to exceed 10 % by weight. 

To demonstrate that a process unfollow (1) procedures that conform ASTM E-260, E-68, E-69 (incorpo60.7), or, (2) demonstrate that the considered by the EPA to have neor, (3) use engineering judgment tpiece of equipment has not been service. Information and data used to demequipment is not in VOC service skept in a readily accessible locatio
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6.3 Enhanced Equipment Leak Program (Enhanced LDAR) - continued 

Table 6.3b - Valves on Selected Portions of Operating Units Subject to Enhanced LDAR 

Table 6.3b - Commonly Referenced Monitoring Recordkeeping and Reporting Requi

Enhanced Equipment Leak Program (Enhanced LDAR) for Valves in the following 

#1 DHDS (Heater Reliability Project), Hydrocracker Unit (Incremental VGO Proj

Permit 

Term Citation Description Monitoring, Recordke

6.3.12 

VOC/ 

HAP 

40 CFR 60 Subpart VV 60.482-7 (12/14/00), 60.483-2 (12/14/00), 60.486(e) (12/14/00), and 60.487(c) (d) and (e) (10/17/00) as modified by OAC #850 Condition 1 issued 12/1/03 for the Incremental VGO Project, and by OAC #949 Condition 9 issued 3/3/06 for the #1 Diesel HDU. 

Enhanced Standards for Block Valves and Control 

Valves on the Hydrocracker Unit (associated withthe Incremental VGO Project),and the #1 DHDU

(associated with the Heater Reliability project)

If an instrument reading of 500 ppm or greater is measured, a leak is detected. Monitor valves no less frequently than quarterly to detect leaks. When a leak is detected at a level between 500 ppm and 10,000 ppm, it shall be repaired and remonitored within 30 calendar days after it is detected. If a leak greater than 10,000 ppm is detected, follow provisions detailed in Subpart VV. First attempts at repair include, but are not limited to: (1) tightening of bonnet bolts, (2) replacement of bonnet bolts, (3) tightening of packing gland nuts; and (4) injection of lubricant into lubricated packing. 

Instrument monitor valves in accomodified by the associated OAC. The instrument shall be calibrated Method 21. The following calibratair (less than 10 ppm of hydrocarbmethane or n-hexane and air at a 500 ppm methane or n-hexane. For all equipment subject to this preadily accessible location the infoSubmit a semi-annual report inclu60.487(c). Report the results of all performanof the General Provisions. -directly enforceable- 
BP Cherry Point Refinery, Air Operating Permit #015 

Modification 1 – September 06, 2006 

7-1 

SECTION 7 - INAPPLICABLE REQUIREMENTS

The regulations identified in Table 7 do not apply to the BP Cherry Point Refinery as of the date 

of permit issuance. 

Citation Title Basis 

NWCAA Regulations 

NWCAA 320 – 321 General Requirements for Registration The registration requirements do not apply to 

sources or emission units subject to Air 

Operating Permits 

NWCAA 458 Incinerators – Wood Waste Burners Facility does not have this source category. 

NWCAA 465 Sulfuric Acid Plants Facility does not have this source category. 

NWCAA 466 Portland Cement Plants Facility does not have this source category. 

NWCAA 470 Fluorides – Forage Facility does not have this source category. 

NWCAA 480 Solid Fuel Burning Device Facility does not have this source category. 

NWCAA 504 Agricultural Burning The facility does not perform this activity. 

NWCAA 510 Incinerator Burning Facility does not have this source category. 

NWCAA 511 Refuse Burning – Time Restriction Facility does not have this source category. 

NWCAA 580.5 Bulk Gasoline Plants Facility does not have this source category. 

NWCAA 580.6 Gasoline Stations Throughput threshold not met. 

NWCAA 580.9 High Vapor Pressure VOC Storage in 

External Floating Roof Tanks 

Facility does not have this source category. 

NWCAA 590 Perchloroethylene Dry Cleaners Facility does not have this source category. 

State of Washington Regulations 

WAC 173-400-050 (2) Incinerator Facility does not have this source category. 

WAC 173-400-100 

through 104 

Registration The registration requirements do not apply to 

sources or emission units subject to Air 

Operating Permits 

WAC 173-400-105(6) Change in Raw Materials or Fuels This requirement does not apply to sources or 

emission units subject to Air Operating Permits 

WAC 173-430 Agricultural Open Burning Facility does not have this source category. 

WAC 173-434 Solid Waste Incineration Facility does not have this source category. 
BP Cherry Point Refinery, Air Operating Permit #015 

Modification 1 – September 06, 2006 

7-2 

Citation Title Basis 

Federal Regulations 

40 CFR 60 Subpart D 

Performance Standards for Fossil-FuelFired Steam Generators for Which 

Construction is Commenced After 

August 17, 1971 

Original refinery boilers and heaters were 

constructed in 1970. 

40 CFR 60 Subpart Da 

Performance Standards for Fossil-FuelFired Steam Generators for Which 

Construction is Commenced After 

September 18, 1978. 

Original refinery boilers constructed in 1970. 

Utility Boiler #4 is not subject to this subpart 

but to 40 CFR 60 Subpart J. And Utility Boiler 

#4 is not subject to the particulate standards of 

40 CFR 60 Subpart Db as it burns only 

gaseous fuel. 

40 CFR 60 Subpart Ka 

Performance Standards for Storage 

Vessels for Petroleum Liquids for Which 

Construction, Reconstruction, or 

Modification Commenced After May 18, 

1978 and Prior to July 23, 1984. 

Tanks 22, 37, 47 and 48 are subject to 40 CFR 

63 Subpart CC Group 1 requirements and are 

therefore exempt from this requirement. 

40 CFR 60 Subpart 

GG 

Standards of Performance for 

Stationary Gas Turbines 

No turbines at the refinery. 

40CFR 60 Subpart XX Performance Standards for Bulk 

Gasoline Terminal 

Truck rack now regulated under 40 CFR 63 

Subpart 63 (60.640(c)). 

40 CFR 61 Subpart J 

National Emission Standards for 

Equipment Leaks (Fugitive Emission 

Sources) of Benzene 

Light Reformate Stream in Reformer Unit and 

applicable tankage now must comply with 40 

CFR 63 Subpart CC. Tanks subject to the 

provision 40 CFR 61 Subpart J are only 

required to comply with the provisions of 40 

CFR 63 Subpart CC. 

40 CFR 61 Subpart V 

National Emission Standards for 

Equipment Leaks (Fugitive Emissions) 

Light Reformate Stream in Reformer Unit and 

applicable tankage now must comply with 40 

CFR 63 Subpart CC. 

40CFR 61 Subpart Y 

National Emission Standards for 

Benzene Emissions from Benzene 

Storage Devices 

Facility does not have this source category. 

40 CFR 61 Subpart BB 

National Emission Standards for 

Benzene Emissions from Benzene 

Storage Vessels 

Facility does not have this source category. 

40 CFR 63 Subpart F 

National Emission Standards for 

Organic Hazardous Air Pollutants From 

the Synthetic Organic Chemical 

Manufacturing Industry 

40 CFR 60.100(j) exempts the facility. 

40 CFR 63 Subpart G 

National Emission Standards for 

Organic Hazardous Air Pollutants From 

the Synthetic Organic Chemical 

Manufacturing Industry for Process 

Vents, Storage Vessels, Transfer 

Operations, and Wastewater 

40 CFR 60.100(j) exempts the facility. 

40 CFR 63 Subpart H 

National Emission Standards for 

Organic Hazardous Air Pollutants From 

Equipment Leaks 

40 CFR 60.100(j) exempts the facility. 
BP Cherry Point Refinery, Air Operating Permit #015 

Modification 1 – September 06, 2006 

7-3 

Citation Title Basis 

40 CFR 63 Subpart Q 

National Emission Standards for 

Hazardous Air Pollutants for Industrial 

Process Cooling Towers 

Facility eliminated the use of chromium in 

cooling towers in August, 1994. 

40 CFR 63 Subpart R 

National Emission Standards for 

Hazardous Air Pollutants for Gasoline 

Distribution Facilities (Bulk Gasoline 

Terminals and Pipeline Breakout 

Stations) 

Refinery not subject to this requirement per 40 

CFR 63.420(i). 

40 CFR 63 Subpart CC 

§ 63.644 (c) 

National Emissions Standards for 

Hazardous Air Pollutant from Petroleum 

Refineries. 

Refinery has no bypass lines and is exempt 

from this provision. 

40 CFR 63 Subpart 

OO 

National Emissions Standards for Tanks No other portion of the applicable sections of 

40 CFR 63 references this section, as 

required. 

40 CFR 63 Subpart 

QQ 

National Emissions Standards for 

Surface Impoundments 

No other portion of the applicable sections of 

40 CFR 63 references this section, as 

required. 

40 CFR 63 Subpart RR National Emission Standards for 

Individual Drain Systems 

No other portion of the applicable sections of 

40CFR63 references this section, as required.

40 CFR 63 Subpart VV 

National Emission Standards for Oilwater Separators and Organic-water 

Separators 

No other portion of the applicable sections of 

40 CFR 63 references this section, as 

required. 

40 CFR 63 Subpart 

YYYY 

National Emission Standards for 

Combustion Turbines 

No combustion turbines on site. 
BP Cherry Point Refinery, Air Operating Permit #015 

Modification 1 – September 06, 2006 

8-1 

SECTION 8 - CONSENT DECREE COMPLIANCE PLAN 

On January 22, 2001 a Consent Decree was filed in the following case that provides compliance 

requirements for the BP Cherry Point Refinery: 

 United States, et. al. v. BP Exploration & Oil, et. al. 

 Northern District of Indiana, Hammond Division 

 Civil Action No. 2:96CV 095 RL 

The Date of Lodging for the Consent Decree is June 18, 2001 and the Date of Entry is August 29, 

2001. These dates are significant in that provisions of the Consent Decree must be completed after a 

prescribed time period based on these dates. 

• Prevention of Significant Deterioration (PSD) - Part C of Title I, 42 U.S.C. § 7470-7492 

• New Source Review (NSR) - Section 173 of Part D, 42 U.S.C. § 7503-7515 

• New Source Performance Standards (NSPS) 

• 40 CFR 60 Subpart J - Standards of Performance for Petroleum Refineries 

• 40 CFR 60 Subpart GGG – Equipment Leaks (LDAR) 

• National Emission Standards for Hazardous Air Pollutants (NESHAP) 

• 40 CFR 61 Subpart FF – National Emission Standard for Benzene Waste Operations 

• The Washington State Implementation Plan (SIP) which incorporates and/or implements the 

federal regulations listed above 

In accordance with 40 CFR 70.5(c)(8) the permit contains a compliance plan that provides 

requirements and milestones for achieving compliance with activities related to the following Clean Air 

Act (CAA) statutory and regulatory requirements applicable to the petroleum refining industry. 

The table below constitutes the compliance plan and references paragraphs in the associated consent 

decree thereby defining specific required activities, their compliance dates, and associated reporting 

requirements. Until compliance is achieved for the items specified in the compliance plan below, BP 

Cherry Point Refinery shall submit certified quarterly progress reports to US EPA and NWCAA. 

Although only this compliance plan is incorporated into the air operating permit, it should be noted that 

the consent decree settlement is independently enforceable by the parties to the consent decree. As 

such, each of the two consent decree documents stand as separate documents in addition to the AOP. 

Because the consent decree often overlaps with requirements of the AOP, the two consent decree 

documents are provided in their entirety as a courtesy at the following internet location: 

http://nwcleanair.org/regulated/aop.html. 
BP Cherry Point Refinery, Air Operating Permit #015 

Modification 1 – September 06, 2006 

8-2 

Summary of Consent Decree Applicable Requirements 

BP Cherry Point Refinery - Blaine, WA. 

Emission 

Unit Requirement/Limit Schedule Consent Decree Reference 

Sulfur 

Recovery 

Unit 

40 CFR 60 Subpart J

1. 250 ppmvd SO2 @ 0% excess air 

2. 300 ppmvd of reduced sulfur compounds 

3. Fuel gas limited to a composition of 

H2S<230 mg/dscm (0.10 gr/dscf). 

Equivalent to 162 ppm, 3 hour rolling 

average. This requirement becomes 

effective except during periods of startup, 

shutdown or malfunction until the end of the 

turnaround in 2006. 

4. Install either a second tail gas unit or 

equivalent control technology to ensure 

compliance with 40CFR60 Subpart J NSPS. 

5. All sulfur pit emissions shall be treated, 

monitored, and included as part of the 

Sulfur Recovery Plant’s emissions which 

are subject to 40CFR60 Subpart J limit of 

SO2. 

6. Reroute the vent from the sour water 

stripper tank from the sulfur recovery plant 

incinerator to some other point upstream of 

the sulfur recovery plant. (This has been 

completed). 

1. January 17, 2003 

2. January 17, 2003 

3. Turnaround 2006 

4. Turnaround 2006 

5. First Claus Train 

Turnaround after 

January 18, 2001 

6. 18-months after the 

Date of Lodging of the 

BP Consent Decree 

(1/17/01) (Item 6 has 

been completed.) 

Paragraph 17 C(iv) 

Paragraph 21 

B(ii)(a), (c), (d), (f), 

(g) 

Paragraph 21 A 

Heaters & 

Boilers 

1. All heater and boilers considered affected 

facilities by 40CFR 60 Subpart J and 

comply with 40CFR 60 Subpart A and J 

requirements. 

2. Fuel gas limited to a composition of 

H2S<230 mg/dscm (0.10 gr/dscf). 

Equivalent to 162 ppm, 3 hour rolling 

average 

3. Condition #2 is valid except for periods of 

startup, shutdown, or malfunction of fuel 

gas system between 12/31/01 and 9/30/05 

4. The vacuum tower vent gas burned at the 

crude heater is exempt from the above 

stated requirements. 

5. Applicable heater and boilers at refinery can 

participate in company NOx Emissions 

reduction efforts. 

1. September 30, 2005 

2. September 30, 2005 

Paragraph 17 C(iv) 

Paragraph 17 C 

(v)(a) 

Paragraph 15 
BP Cherry Point Refinery, Air Operating Permit #015 

Modification 1 – September 06, 2006 

8-3 

Emission 

Unit Requirement/Limit Schedule Consent Decree Reference 

Truck 

Rack and 

Marine 

Terminal 

Measure or calculate concentrations of H2S in 

fuel gas burned. 

1. 24 months (This has 

been completed.) 

Paragraph 17 D