# 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 C ontents ................................................................. iii

Emission Unit Ident ification .................................................. 1-1

Standard Terms and Condit ions (General) ........................... 2-1

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

Generally Applicable Requirement s ..................................... 4-1

Specifically Applicable Requiremen ts .................................. 5-1

Commonly Referenced Requirements

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

Inapplicable Require ments ................................................... 7-1

Compliance Pl ans.................................................................. 8-1BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-1SECTION 1 - EMISSION UNIT IDENTIFICATIONThis section provides a list of the airpollution emission units and their physical characteristics for each process or producthandling area. The numbers in brackets correspond to the emission point ID number for the piece of equipment listed.1.1 Crude and Vacuum Unit 1.11Boilers and Cooling Towers1.2 Naphtha HDS and Reformer Units1.11.1 Cooling Towers1.3 Hydrocracker 1.11.2 Boilers #1 and #31.4 Delayed Coker 1.11.3 Boiler #41.5 #1 Diesel HDS Unit 1.11.4 Boiler #51.6 #2 Diesel HDS Unit 1.12 Flares1.7 Hydrogen Plant 1.13 Sulfur Recovery Unit1.8 Calciner and Coke Loading 1.14 Wastewater Treatment1.8.1 Calciner Hearths #1& #2 1.15 Storage Tanks and Vessels1.8.2 Calciner Hearth #3 1.16 Shipping, Pumping and Receiving1.8.3 Coke Handling Operations 1.16.1Chemical Treater1.9 Light Ends Unit (LEU) and LPG 1.16.2 Truck Rack1.9.1 Light End Unit (LEU) 1.16.3 Marine Terminal1.9.2 LPG 1.16.4 LPG/LEU Loading1.10 Isomerization Unit 1.17 Non-Hazardous LandfarmBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-21.1 CRUDE ANDVACUUM UNITTable 1.1 - Emission Unit Identification Crude and Vacuum UnitEmissionUnit IDDescription[Emission Point]Constructed/ModifiedCommentsComponents in VOC/HAP Service(10)40 CFR 60 Subpart GGG, 40 CFR 63 Subpart CC, OAC #640Process Drains 40 CFR 60 Subpart QQQ, 40 CFR Subpart 63 CC10 Crude Heater [10] 1970/1975 720 MMBtu/hr,OAC #159, RO #28 (Subpart J), OAC #68910 North Vacuum Heater [11] 1985 77 MMBtu/hr, PSD 5, RO #28 (Subpart J),, OAC #273b,10 South Vacuum Heater [12] 1970/2005 222 MMBtu/hr, RO#28 (Subpart J),, OAC #902a, Ultra-low NOx burners10Non-condensable VOC, Hot wellswith contact condensersNWCAA 5801.2 NAPHTHA HDS AND REFORMER UNITSTable 1.2 - Naphtha HDS and Reformer UnitsEmissionUnit IDDescription[Emission Point]Constructed/ModifiedCommentsComponents in VOC/HAP Service 1996/200040 CFR 60 Subpart GGG, 40 CFR 63 Subpart CCProcess Drains 1996/2000 40 CFR 60 QQQ, 40 CFR 63 Subpart CCProcess Vents 40 CFR 63 Subpart CC11 Naphtha HDS Unit 1970Naphtha 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 Subpart UUU#1 Reformer Heater [20] 1970 1075 MMBtu/hr, RO #28 (Subpart J),Components in HAP Service 2000 40 CFR 61 Subpart FF21 #2 Reformer 1987 OAC #305; 40 CFR 61 Subpart FF, 40 CFR 63 Subpart UUU21 #2 Reformer Heater [21] 1987 340 MMBtu/hr , OAC #305, PSD 7, RO #28 (Subpart J)BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-31.3 HYDROCRACKERTable 1.3 - HydrocrackerEmissionUnit IDDescription[Emission Point]Constructed/ModifiedComments15R-1 Hydrocracker Reactor Heater[32]1970 89 MMBtu/hr, RO #28 (Subpart J),15R-4 Hydrocracker Reactor Heater[33]1970 79 MMBtu/hr, RO #28 (Subpart J),15 1stStage Fractionator Reboiler [30] 1970/1992150 MMBtu/hr, OAC #149, OAC #351d – Low NOx Burners, RO #28(Subpart J),15 2ndStage Fractionator Reboiler [31] 1970/1974/2003 183 MMBtu/hr, OAC #149, RO #28 (Subpart J),, OAC #847Components in VOC/HAP Service 1970 LDAR – 40 CFR 63 Subpart CCProcess Drains 1970 40 CFR 60 Subpart QQQ1.4 DELAYED COKERTable 1.4 - Delayed CokerEmissionUnit IDDescription[Emission Point]Constructed/ModifiedComments12 Coker Fractionator 1970 OAC #306, OAC #28112North Coker Charge Heater #1[40]1970 190 MMBtu/hr, OAC #689, RO #28 (Subpart J),12South Coker Charge Heater #2[41]1970 190 MMBtu/hr, OAC #689, Low NOx burner, RO #28 (Subpart J),12-V-130 Process Vent 1970 40 CFR 63 Subpart CC12-1801 Coker Compressor 1970 40 CFR 63 Subpart VVComponents in VOC/HAP Service 1970LDAR – 40 CFR 60 Subpart GGG, 40 CFR 63 Subpart VV, OAC 283, 40CFR 63 Subpart CCProcess Drains 1970 40 CFR 60 Subpart QQQBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-41.5 #1 DIESEL HDS UNITTable 1.5 - #1 Diesel Hydrodesulfurization UnitEmissionUnit IDDescription[Emission Point]Constructed/ModifiedComments13 #1 Diesel HDS Charge Heater [50] 1970 71 MMBtu/hr,RO #28 (Subpart J),, OAC #949, Ultra-low NOx Burners13 #1 Diesel HDS Stabilizer Reboiler [51] 1970 53 MMBtu/hr,RO #28 (Subpart J),, OAC #949, Ultra-low NOx BurnersComponents in HAP Service 1970 LDAR - OAC #281, 40 CFR 63 Subpart CCProcess Drains 1970 40 CFR 60 Subpart QQQ1.6 #2 Diesel HDS UNITTable 1.6 -#2Diesel Hydrodesulfurization UnitEmissionUnit IDDescription[Emission Point]Constructed/ModifiedComments26 #2 Diesel HDS Unit 2006 OAC #89226 #2 Diesel HDS Heater [52] 2006 25 MMBtu/hr, OAC #892Process Drains 2006 40 CFR 60 Subpart QQQComponents in VOC Service 2006 OAC #892, LDAR – 40 CFR 60 Subpart GGGComponents in HAP Service 2006 OAC#892, HAP 40 CFR 63 Subpart CC1.7 HYDROGEN PLANTTable 1.7 - Hydrogen PlantEmissionUnit IDDescription[Emission Point]Constructed/ModifiedComments14 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 1970Exempt from MACT by the definition of a miscellaneous process ventper 40 CFR 63.641(14).Majority of off-gas is routed to Praxair for CO2utilization.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-51.8 CALCINER AND COKER HANDLING1.8.1. Calciner Hearths 1 & 2Table 1.8.1 - Calciner Hearths 1 & 2EmissionUnit IDDescription[Emission Point]Constructed/ModifiedComments20Calciner Hearth 1 & 2 (CalcinerStack #1) [70]1978/199938 tons calcined coke/hr per hearth, OAC #211, OAC #689, OAC#246, WESP installed in 1998 - OAC #660, Calciner Bubble; OAC#689 - DEA Scrubber, 40 CFR 60 Subpart J (supplemental firingusing refinery fuel gas), HRSG produces #600 lb steamComponents in VOC Service 1978 LDAR – 40 CFR 60 Subpart GGG, 40 CFR 63 Subpart VVProcess Drains 1978 40 CFR 60 Subpart QQQ1.8.2. Calciner Hearth #3Table 1.8.2 - Calciner Hearths 3EmissionUnit IDDescription[Emission Point]Constructed/ModifiedComments20Calciner Hearth 3 (Calciner Stack#2) [71]198576 tons calcined coke/hr, OAC #299, PSD -3 (replaced by PSD 89-2),PSD 95-01 for WESP, RO #18, 40CFR 60 Subpart J (supplementalfiring using refinery fuel gas), HRSG produces #600 lb steamComponents in VOC Service 1985 LDAR – 40 CFR 60 Subpart GGG, 40 CFR 63 Subpart VVProcess Drains 1985 40 CFR 60 Subpart QQQ1.8.3. Coke Handling OperationsTable 1.8.3 - Coke Handling OperationEmissionUnit IDDescriptionConstructed/ModifiedComments20 Coke Handling Operation 1988/1990NOC #293 Construct Silos. Emissions from baghouses routed toSOx ControlsBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-61.9 LIGHT ENDS UNIT (LEU) AND LPG1.9.1. Light Ends Unit (LEU)Table 1.9.1- Light Ends UnitEmissionUnit IDDescriptionConstructed/ModifiedComments16 Light Ends Unit 1970 OAC #29816-V-012 Process Vent 1970 40 CFR 63 Subpart CCProcess Drains 1970 40 CFR 60 Subpart QQQComponents in VOC Service 1970 LDAR - OAC #2981.9.2. LPGTable 1.9.2 - LPGEmissionUnit IDDescriptionConstructed/ModifiedComments22 LPG 1987 OAC #293 – RVP22-1801 Compressor 1987 40 CFR 60 Subpart VVProcess Drains 1987 40 CFR 60 Subpart QQQComponents in VOC Service 1987 LDAR – 40 CFR 60 Subpart GGG1.10 ISOMERIZATION UNITTable 1.10 - Isomerization UnitEmissionUnit IDDescription[Emission Point]Constructed/ModifiedCommentsIsomerization Unit 2004 OAC #814aIsomerization ProcessHeater[106]2004 13 MMBtu/hr, OAC #814a, PSD-02-04, 40 CFR 60 Subpart JProcess Drains 2004 40 CFR 60 Subpart QQQComponents in VOC Service 2004 OAC #814a, LDAR – 40 CFR 60 Subpart GGGComponents In HAP Service 2004 OAC #814a, HAP – 40 CFR 63 Subpart CCBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-71.11 BOILERS AND COOLING TOWERS1.11.1. Cooling TowersTable 1.11.1 - Cooling TowersEmissionUnit IDDescription[Emission Point]Constructed/ModifiedComments30 Cooling Tower #1 1970Stopped using Chromium in 199430 Cooling Tower #2 1990 Stopped using Chromium in 1994, OAC #2891.11.2. Boilers #1and #3Table 1.11.2 – Boilers - #1 and #3EmissionUnit IDDescription[Emission Point]Constructed/ModifiedComments30 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 #4Table 1.11.3 - Boiler # 4EmissionUnit IDDescription[Emission Point]Constructed/ModifiedComments30 Boiler #4 [104] 1991/1993/1994/1999216 MMBtu/hr, OAC #351d, 40 CFR 60 Subpart Db, RO #28 (SubpartJ), OAC #298,Process Drains 40 CFR 60 Subpart QQQComponents in VOC Service LDAR – 40 CFR 60 Subpart GGGBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-81.11.4 Boiler #5Table 1.11.4 - Boiler # 5EmissionUnit IDDescription[Emission Point]Constructed/ModifiedCommentsBoiler #5 [105] 2004363 MMBtu/hr, OAC #814a, PSD-02-04, 40 CFR 60 Subpart J, 40CFR 60 Subpart DbProcess Drains 2004 40 CFR 60 Subpart QQQComponents in VOC Service 2004 LDAR – 40 CFR 60 Subpart GGG1.12 FLARESTable 1.12 - Low and High Pressure Flare SystemsEmissionUnit IDDescription[Emission Point]Constructed/ModifiedComments29 Low Pressure Flare [111] 1970 40 CFR 63 Subpart A, NWCAA 462, 40 CFR 63 Subpart CC29 High Pressure Flare [110] 1970 40 CFR 63 Subpart A, NWCAA 462, 40 CFR 63 Subpart CC28Flare Gas Recovery Systemand Associated Piping(Components in VOC/HAPService)40 CFR 60 Subpart GGG and 40 CFR 63 Subpart CC28-1803,28-1804Compressors 40 CFR 60 Subpart GGG29-V- 040,29-V-044Process Vents 40 CFR 63 Subpart CCBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-91.13 SULFUR RECOVERY COMPLEXTable 1.13 - Sulfur Recovery ComplexEmissionUnit IDDescription[Emission Point]Constructed/ModifiedComments17 and 19 Sulfur Recovery Complex 40 CFR 63 Subpart UUU17 Sulfur Recovery Unit 1970/1977OAC #290, RO #28 (Subpart J),17-V-047,17-V-067,17-V-074Process Vents 40 CFR 63 Subpart CCSulfur Pits & Sulfur Tanks1970/20011984RO #28, All sulfur pit emissions shall be treated, monitored, andincluded as part of the Sulfur Recovery Plant’s emissions.Sour Water Unit 1970/1977/2002The vent from the sour water stripper tank was routed from the sulfurrecovery plant incinerator to a pointupstream of the sulfur recoveryplant as a SO2reduction measure.19 Tail Gas Unit 1 [120] 1975/2006OAC #890a, 40 CFR 60 Subpart J (250 ppm SO2 incinerator stackand 162 H2S refinery fuel gas as supplimental fuel for incinerator), 40CFR 63 Subpart UUUTail Gas Unit 2 [121] 2006 OAC #890a, 40 CFR60 Subpart J, 40 CFR 63 Subpart UUUBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-101.14 WASTEWATER TREATMENTTable 1.14 - Wastewater TreatmentEmissionUnit IDDescriptionConstructed/ModifiedCommentsSewerSystemProcess Drains and JunctionBoxes40 CFR Subpart QQQDrain systems 40 CFR 63 Subpart CCGauging and SamplingDevices40 CFR 63 Subpart CCCovers & Openings 40 CFR 63 Subpart CCMiscellaneous Sewer Linesand Covers40 CFR 61 Subpart FF32 API Separators 1970/1991/199240 CFR 61 Subpart FF, OAC #34832API Effluent Sump-FloatingRoof40 CFR 61 Subpart FF and 40 CFR 60 Subpart QQQClosed Vent Systems 40 CFR 63 Subpart CC and 40 CFR Subpart FFCarbon Adsorption ControlDevices40 CFR 63 Subpart CC and 40 CFR Subpart FFContainers 40 CFR 61 Subpart FF320,321, 322,323Tanks 320, 321, 322, 32340 CFR 61 Subpart CC, 40 CFR 61 Subpart FF, NWCAA 560, NWCAA580BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-111.15 STORAGE TANKS AND VESSELSTable 1.15 - TanksTank#EmissionUnit IDTank ServiceMTVPSizeMbblsRoofType# SealsConstructedModifiedComments1 20.367.01 Petroleum Products >1.5 139.5 IFR 1 1970Group 1, OAC #562b2 21.367.01 Petroleum Products>1.5139.8IFR1 1970Group 1, OAC #562b3 22.367.01 Petroleum Products>1.5137.9IFR1 1970Group 1, OAC #562b4 23.367.01 Petroleum Products>1.5139.7IFR1 1970Group 1, OAC #562b5 24.367.01 Petroleum Products>1.5139.7IFR1 1970Group 1, OAC #562b6 25.367.01 Petroleum Products>1.5139.5IFR2 1970Group 1, OAC #562b7 26.367.01 Petroleum Products>1.5139.8IFR1 1970Group 1, OAC #562b8 27.367.01 Petroleum Products>1.5138.9IFR1 1970Group 1, OAC #562b9 28.367.01 Petroleum Products>1.599.54IFR1 1970Group 1, OAC #562b10 29.367.01 Petroleum Products>1.5142.8IFR1 1970Group 1, OAC #562b11 31.367.01 Petroleum Products>1.5142.7 IFR 1 1970Group 212 32.367.01 Petroleum Products<1.5142.8IFR1 1970Group 213 41.367.01 Petroleum Products<1.5137.4IFR1 1970Group 214 33.367.01 Petroleum Products>1.5142.3IFR1 1970Group 1, OAC #562b15 34.367.01 Petroleum Products<1.5141.7IFR1 1970Group 216 35.367.01 Petroleum Products<1.5142.4IFR1 1970Group 217 36.367.01 Petroleum Products>1.5140.0IFR2 1970Group 118 37.367.01 Petroleum Products>1.5194.4IFR2 1970Group 119 38.367.01 Petroleum Products<1.5140.3IFR1 1970Group 220 39.367.01 Petroleum Products<1.5139.5IFR1 1970Group 221 40.367.01 Petroleum Products>1.5201.0 IFR 1 1970Group 122 188.367.01 Petroleum Products>1.5138.8 IFR 1 1975Group 1, Subpart K(Service changed to Group 1 – 8/06)23 47.367.01 Petroleum Products <1.5 201.0 IFR 1 1970Group 224 211.367.01 Fin. Diesel or Gasoline <1.5 205.3 IFR - D 2 1994Subpart Kb, OAC #453b25 30.367.01 Petroleum Products >1.5 22.6 IFR 1 1970Group 1BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-12Table 1.15 - TanksTank#EmissionUnit IDTank ServiceMTVPSizeMbblsRoofType# SealsConstructedModifiedComments26 48.367.01 Petroleum Products >1.5 94.5 IFR 1 1970Group 127 45.367.01 Petroleum Products >1.5 139.8 IFR 1 1970Group 128 43.367.01 Coker Feed <1.5 144.2 C-NIFR 1970Group 229 58.367.01 Petroleum Products <1.5 49.7 IFR 1 1970Group 230 42.367.01 Coker Heavy Gas Oil <1.5 138.3 C-NIFR 1970Group 231 44.367.01 Petroleum Products >1.5 139.4 IFR 1 1970Group 132 46.367.01 Coker Feed <1.5 143.6 C-NIFR 1970Group 233 49.367.01 Petroleum Products <1.5 102.9 IFR 1 1970Group 234 50.367.01 Diesel <1.5 144.8 C-NIFR 1970Group 237 187.367.01 Diesel <1.5 138.4 C-NIFR 1975Group 238 51.367.01 Diesel <1.5 149.5 C-NIFR 1970Group 240 Crude >1.5 364.3 IFR 2 2004Group 1, Subpart Kb, OAC #89741 52.367.01 Crude >1.5 241.4 IFR 1 1970Group 142 53.367.01 Crude>1.5247.7IFR1 1970Group 143 54.367.01 Crude/Jet/Misc.>1.5248.3IFR1 1970Group 144 55.367.01 Crude>1.5249.3IFR1 1970Group 145 56.367.01 Crude/Diesel>1.5245.4IFR1 1970Group 146 57.367.01 Crude>1.5248.8IFR1 1970Group 147 185.367.01 Crude>1.5260.8IFR1 1973Group 1, Subpart K, OAC #116,OAC #12348 186.367.01 Crude>1.5260.2IFR1 1973Group 1, Subpart K, OAC #116,OAC #12349 277.367.01 Crude>1.5389.6IFR1 1998Group 1, Subpart Kb, OAC #620a50 190.367.01 Crude>1.5485.7IFR1 1989Subpart Kb, OAC #253a60 20.367.02 Butane/PentaneSphere 30.0 Sphere 1990Pressure vessel61 1.367.02 Butane/Pentane Sphere 30.0 Sphere 1970Pressure vessel62 21.367.02 Butane/PentaneSphere 30.0 Sphere 1990Pressure vesselBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-13Table 1.15 - TanksTank#EmissionUnit IDTank ServiceMTVPSizeMbblsRoofType# SealsConstructedModifiedComments63 2.367.02 Butane/Pentane Sphere 15.0 Sphere 1970Pressure vessel64 3.367.02 Butane/Pentane Sphere 15.0 Sphere 1970Pressure vessel654.367.02 Butane/Pentane Sphere 15.0 Sphere 1970Pressure Vessel70 102.367.01 Hydrocracker Recycle <1.5 102.6 C-NIFR 1970Group 271 225.367.01 Petroleum Prod. - TR >1.5 30.8 IFR 2 1991Subpart Kb, OAC #371a72 272.367.01 Gasoline/Diesel – TR* >1.5 18.4 IFR 2 1995Subpart Kb, OAC #527c73 273.367.01 Gasoline/Diesel – TR* >1.5 9.7 IFR 2 1995Subpart Kb, OAC #527c74 274.367.01 Gasoline/Diesel – TR* >1.5 9.7 IFR 2 1995Subpart Kb, OAC #527c81 5.367.02 LPG 1.8 Bullet 1986Pressure Vessel82 6.367.02 LPG 1.8 Bullet 1986Pressure Vessel83 7.367.02 LPG 1.8 Bullet 1986Pressure Vessel84 8.367.02 LPG 1.8 Bullet 1986Pressure Vessel85 11.367.02 LPG 1.8 Bullet 1986Pressure Vessel86 12.367.02 LPG 1.8 Bullet 1986Pressure Vessel87 13.367.02 LPG 1.8 Bullet 1986Pressure Vessel88 14.367.02 LPG 1.8 Bullet 1986Pressure Vessel89 5.367.02 LPG 1.8 Bullet 1986Pressure VesselComponents in VOC/HAP Service in Tank Farm and Off-Plot areasLDAR – 40 CFR 60 Subpart GGGProcess Drains40 CFR 60 Subpart QQQNotes: IFR – Internal Floating RoofIFR – D – Internal Floating Roof with Dome CoverC-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 timeBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-141.16 SHIPPING, PUMPING & RECEIVING1.16.1. Chemical TreatersTable 1.16.1 - Chemical TreaterEmissionUnit IDDescriptionConstructed/ModifiedComments18Process Drains & JunctionBoxes40 CFR 60 Part QQQComponents in VOC/HAP ServiceLDAR – 40 CFR 63 Subpart CC1.16.2. Truck RackTable 1.16.2 - Truck RackEmissionUnit IDDescriptionConstructed/ModifiedCommentsProcess Drains and JunctionBoxes in VOC Service40 CFR 60 Subpart QQQComponents in VOC Service 40 CFR 60 Subpart GGGProcess Drains in HAPService40 CFR 63 Subpart CCComponents in HAP Service 40 CFR 63 Subpart CC38 Truck Loading Rack1994/1996/200140 CFR 63 Subpart CC, OAC #527c, Associated Tanks Subpart Kb,(Gasoline limit of 26,000 BBL/day; Jet and Diesel combined limit of 76,000BBL./day), NWCAA 580, 40 CFR 60 Subpart J (recovered vapors only, thethermal oxidizer uses natural gas for supplemental firing )1.16.3. Marine TerminalTable 1.16.3 - Marine TerminalEmissionUnit IDDescriptionConstructed/ModifiedCommentsComponents in HAP Service 40 CFR 63 Subpart CC35Marine Terminal includingvapor combustor2001OAC#716a, 40 CFR 63 Subpart CC, 40 CFR 63 Subpart Y, natural gas usedfor supplemental firing of the vapor combustorBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20061-151.16.4. LPG/LEU LoadingTable 1.16.4 - LPG/LEU LoadingEmissionUnit IDDescriptionConstructed/ModifiedComments37 LPG Loading Rack 1970Components in VOC/HAPServiceLDAR – 40 CFR 60 Subpart GGG1.17 NON-HAZARDOUS WASTE LANDFARMTable 1.17 - Emission Unit Identification Non-hazardous Waste LandfarmEmissionUnit IDDescriptionConstructed/ModifiedCommentsLandfarm for non-hazardouswastes1992 OAC #382

# BP Cherry Point Refinery, AOP #015

Modification 1 – September 06, 2006

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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 f ederally 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.

# BP Cherry Point Refinery, AOP #015

Modification 1 – September 06, 2006

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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 c onfidential 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.

# BP Cherry Point Refinery, AOP #015

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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.

# BP Cherry Point Refinery, AOP #015

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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 emi ssions 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.

# BP Cherry Point Refinery, AOP #015

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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 sha ll 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 Opacit y 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 Accura cy 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.

# BP Cherry Point Refinery, AOP #015

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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.

# BP Cherry Point Refinery, AOP #015

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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 det ermines 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.

# BP Cherry Point Refinery, AOP #015

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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 requi rements 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.

# BP Cherry Point Refinery, AOP #015

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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 limi tation 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.

# BP Cherry Point Refinery, AOP #015

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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 mi sleading 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;

# BP Cherry Point Refinery, AOP #015

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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 manufacturi ng 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, PM 2.5 

# , 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 mo st 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 emi ssions 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 ac tions 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.

# BP Cherry Point Refinery, AOP #015

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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.

# BP Cherry Point Refinery, AOP #015

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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 potentia l 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.

# BP Cherry Point Refinery, AOP #015

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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 s hall 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.

# BP Cherry Point Refinery, AOP #015

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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.

# BP Cherry Point Refinery, AOP #015

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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 conditioni ng, 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.

# BP Cherry Point Refinery, AOP #015

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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).

# BP Cherry Point Refinery, AOP #015

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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 subst antially 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.

# BP Cherry Point Refinery, AOP #015

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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 hazar dous 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.

# BP Cherry Point Refinery, Air Operating Permit #015

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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 requirement s. The permittee must comply with the

requirements listed below for specific “affect ed 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 subjec t 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

# BP Cherry Point Refinery, Air Operating Permit #015

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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 wh ich 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:

# BP Cherry Point Refinery, Air Operating Permit #015

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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 cont inuous 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

# BP Cherry Point Refinery, Air Operating Permit #015

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# 1200 Sixth Avenue

Seattle WA 98101

# BP Cherry Point Refinery, Air Operating Permit #015

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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 A ffected 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, a nd 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

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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 30 th 

# 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 Acti vities 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, Shutdow n, 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

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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.

# BP Cherry Point Refinery, Air Operating Permit #015

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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.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20064-1SECTION 4 - GENERALLY APPLICABLE REQUIREMENTSThe cited requirements in the “Citation” column and incorporated herein by reference are applicable plantwide at the source, includinginsignificant emission units. These requirements are federally enforceable unless identified as “state only”. A requirement designated “stateonly” is enforceable only by the state or the NWCAA, and not by the EPA or through citizen suits. The “Description” column isa briefdescription of the applicable requirements for informational purposes only and is not enforceable. Periodic or continuous monitoringrequirements (including testing) are specified in the “Monitoring, Recordkeeping and Reporting” column, which identifies monitoring,recordkeeping and reporting (MR&R) obligations the source mustperform as required by WAC 173-401-605(1) and 615(1) and (2) ortheunderlying requirement. MR&R obligations donot apply to insignificant emission units.The requirements in the MR&R column labeled “directly enforceable” are legally enforceable requirements added under the NWCAA’s“gapfilling” authority. Other requirements not labeled “directly enforceable” are brief descriptions of the regulatory requirements for informationpurposes, and are not enforceable. Unless the text of the MR&R column is specifically identified to be directly enforceable, the language of thecited regulation takes precedence over a paraphrased requirement.The provisions of federally approved NWCAA Section 365, Section366 and the “Guidelines for Industrial Monitoring Equipment andDataHandling” have been replaced in this section by NWCAA Section 367 and Appendix A - "Ambient Monitoring, Emission Testing and ContinuousEmission and Opacity Monitoring". NWCAA Section 367 and Appendix A were adopted on July 14, 2005 with a provision that one year fromthe date of adoption would be allowed to achieve compliance with Appendix A. The new regulations are “State Only” until incorporated into theState Implementation Plan. Section 367 and Appendix A are not materially different from the previous rule and guideline, but have beenupdated to include current monitoring technology and methods.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20064-2Table 4 - Generally Applicable RequirementsBP Cherry Point RefineryPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting4.1GeneralNWCAA342.1(7/14/05)Same as4/14/93 SIPVersionOperation and MaintenanceSources are required to keep any processand/or air pollution control equipment ingood operating condition and repair.4.2GeneralNWCAA342.2(7/14/05)Same as4/14/93 SIPVersionOperating Instructions/MaintenanceSchedulesMake operating instructions andmaintenance schedules available tooperators.Monitor, keep records and report in accordance with the terms of this permit.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20064-3Table 4 - Generally Applicable RequirementsBP Cherry Point RefineryPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting4.3OpacityNWCAA451.1(5/11/95)and WAC173-400-040(1)(8/20/93)Same asState Only1/10/05Emission of Air Contaminant - VisualStandardOpacity shall not exceed 20% for anyperiod aggregating more than 3 minutes inany one hour.Excess emissions as a result of sootblowing or grate cleaning shall not occurfor more than 15 minutes in any 8 hourperiod, or another approved schedule.For combustion units burning oil, visually observe stacks on a daily basis toqualitatively assess whether emissions are visible. The frequency may bereduced to weekly if no visible emissions are observed for thirty consecutive days.The permittee shall revert to daily observations of individual stacks if any visibleemissions are noted during the observation.For combustion units burning gaseous fuels, visually observe stacks monthly toqualitatively assess whether emissions are visible. The frequency may bereduced to quarterly if no visible emissions are observed for six consecutivemonths. The permittee shall revert to monthly observations of individual stacks ifany visible emissions are noted during the observation.If visible emissions are observed, reduceto no visible emissions as soon aspossible. If visible emissions cannotbe reduced to zero, the permittee maymonitor by Ecology Method 9A no later than 24 hours after detection and dailythereafter until opacity is shown to be lessthan 20%. Otherwise visual emissionsshall be considered in excess of the opacity standard.Record observation results for stacks with visible emissions and any relatedequipment or operational failure, the occurrence dates and times, actions taken,and the type of fuel burned. Record thatan observation was performed, with date,time, background conditions, and identification of the observer. Keep records ofall observations available for inspection.Combustion units with specifically applicable permit terms in Section 5 for opacityand particulate matter shall be monitored in accordance with Section 5requirements only.Follow State of Washington Departmentof Ecology Source Test Method 9A -Visual Determination of Opacity for a three Minute Standard (Revised July 12,1990)- directly enforceableBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20064-4Table 4 - Generally Applicable RequirementsBP Cherry Point RefineryPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting4.4PMNWCAA455.1(5/11/95)Emission of Particulate MatterEmissions shall not exceed 0.10 grain/dscf(corrected to 7% oxygen), except, from allgaseous and distillate fuel burningequipment (the definition of fuel burningequipment does not include internalcombustion engines), emissions shall notexceed 0.05 grain/dscf (0.11 g/m3)corrected to 7% oxygen. For catalyticcracking units, emissions shall not exceed0.20 grains/dscf (corrected to 7% oxygen).4.5PMWAC 173-400-060(8/20/93)Same asState Only1/10/05Emission Standards for General ProcessUnitsParticulate emissions greater than 0.1grain/dscf prohibited.4.6PMWAC 173-400-050(1)(8/20/93)Same asState Only1/10/05Emission Standards for Combustion andIncineration UnitsParticulate emissions from combustionunits greater than 0.1 grains/dscfprohibited.For combustion units burning oil, visually observe stacks on a daily basis toqualitatively assess whether emissions are visible. The frequency may bereduced to weekly if no visible emissions are observed for thirty consecutive days.The permittee shall revert to daily observations of individual stacks if any visibleemissions are noted during the observation.For combustion units burning gaseous fuels, visually observe stacks monthly toqualitatively assess whether emissions are visible. The frequency may bereduced to quarterly if no visible emissions are observed for six consecutivemonths. The permittee shall revert to monthly observations of individual stacks ifany visible emissions are noted during the observation.If visible emissions are observed, reduceto no visible emissions as soon aspossible. If visible emissions cannotbe reduced to zero, the permittee maymonitor by Ecology Method 9A no later than 24 hours after detection and dailythereafter until opacity is shown to be lessthan 20%. Otherwise visual emissionsshall be considered in excess of the opacity standard.Record observation results for stacks with visible emissions and any relatedequipment or operational failure, the occurrence dates and times, actions taken,and the type of fuel burned. Record thatan observation was performed, with date,time, background conditions, and identification of the observer. Keep records ofall observations available for inspection.Combustion units with specifically applicable permit terms in Section 5 for opacityand particulate matter shall be monitored in accordance with Section 5requirements only.Follow 40 CFR 60 Appendix A Method 5- directly enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20064-5Table 4 - Generally Applicable RequirementsBP Cherry Point RefineryPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting4.7SOxNWCAA410(4/14/93)Sulfur Oxide StandardsUnlawful for any person to cause or permitsulfur oxides to be emitted into theambient air, calculated as sulfur dioxide,measured at an ambient air monitoringstation to exceed:•0.800 ppmv for any 5 minute average,not to be exceeded more than once peryear•0.400 ppmv for any hour average, notto be exceeded more than once per year•0.250 ppmv for any one hour average,not to be exceeded more than twice in any7 consecutive days•0.100 ppmv for any one day (24hours), not to be exceeded more thanonce per year.•0.020 ppmv for any one year (annualarithmetic mean).Monitor ambient air continuously and report to the NWCAA in accordancewith NWCAA 367 and Appendix A - “Ambient Monitoring, Emission Testing,and Continuous Emission and Opacity Monitoring” (7/14/05).- directly enforceable –4.8SO2NWCAA460(7/14/05)State OnlyWeight/Heat Rate Standard – Emission ofSulfur CompoundsSulfur compound emissions, as sulfurdioxide, shall not exceed 1.5 lbs/MMBtu ofheat input per hour, on a calendar monthaverage of hourly values for the facility..Report the refinery monthly average SO2lb/MMBtu on monthly reports.Follow 40 CFR 60 Appendix A Method 11 for hydrogen sulfide emissions andASTM D-4294 for sulfur content of refinery fuel oilBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20064-6Table 4 - Generally Applicable RequirementsBP Cherry Point RefineryPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting4.9SOxNWCAA462(3/13/97)Emission of Sulfur CompoundsSulfur compounds emitted greater than1000 ppm (corrected to 7% O2) averagedfor a sixty consecutive minute period fromany equipment prohibited. Thisrequirement is not violated if reasonableevidence is presented that concentrationswill not exceed ambient standards and thepermittee shows that no practical methodof reducing concentration exists.4.10SO2WAC 173-400-040(6)(8/20/93)The secondparagraphof thiscitation isstate only)Same asState Only1/10/05Sulfur DioxideSulfur compounds calculated as sulfurdioxide and corrected to 7% O2emittedgreater than 1000 ppmvd average for asixty consecutive minute period prohibited.Continuously monitor and record the concentration of hydrogen sulfide in refineryfuel gas, or alternatively stack SO2, in accordance with the applicable permit termslisted in Section 5.Burn only low sulfur diesel (0.05% by weight) as an alternative to gaseous fuel.When combusting diesel, sample the oil daily or with each batch and analyze forsulfur content as per ASTM D-4294. Retain records of the analysis on-site for fiveyears. The test results shall be traceableto each batch of diesel fuel combusted,the dates the fuel is combusted, and the date of each analysis.- directly enforceable -4.11SulfurNWCAA520(4/14/93)Sulfur Compounds in FuelProhibited to burn, sell, or make availablefor sale for burning in fuel burningequipment within the jurisdiction of theNWCAA, fuel containing sulfur in excess ofthe following: #1 distillate- 0.3 wt%; #2distillate-0.5 wt%; other fuel oils-2.0 wt%;solid fuels-2.0 wt% for a time period not toexceed 30 days in a 12-month period.Retain fuel specifications and purchaserecords verifying that fuel sold orcombusted in NWCAA’s jurisdiction has a sulfur content of no more than theallowable limits.Use the following test procedures:•Industrial and Marine Fuel Oils - ASTM D-4294•Distillate Fuel Oil - ASTM D-2622- directly enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20064-7Table 4 - Generally Applicable RequirementsBP Cherry Point RefineryPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting4.12SulfurNWCAA520 (5/9/96State Only)Sulfur Compounds in FuelProhibited to burn fuel containing sulfur inexcess of the following: #1 distillate- 0.3%;#2 distillate-0.5%; other fuel oils-2.0%;solid fuels-2.0%. This version exemptsocean-going vessels.Retain fuel specifications and purchaserecords verifying that fuel combusted atthe refinery has a sulfur content ofno more than the allowable limits.Use the following test procedures:•Industrial and Marine Fuel Oils - ASTM D-4294•Distillate Fuel Oil - ASTM D-2622- directly enforceable –4.13OdorWAC 173-400-040(4)(1/10/05State Only)OdorsOff-site nuisance odors prohibited.4.14OdorNWCAA535(3/09/00)State Only)Odor Control MeasuresAppropriate practices and controlequipment shall be installed and operatedto reduce odor-bearing gasses emitted intothe atmosphere to a reasonable minimum.Any person who shall cause thegeneration of any odor from any sourcewhich may reasonably interfere with anyother property owner’s use and enjoymentof their property must use recognized bestpractices and control equipment to reducethese odors to a reasonable minimum.No person shall cause or permit theemission of any odorous air contaminantfrom any source if it is detrimental to thehealth, safety, or welfare of any person, orcauses damage to property or business.Upon receiving an odor complaint from the NWCAA or the public, BP shallinvestigate the complaint and the operations of the refinery to determine whether(a) refinery emissions of odorous air contaminants are detrimental to the health,safety and welfare of any person, or causing damage to property of business and(b) the refinery is using recognized bestpractices and control equipment to reducethese odors to a reasonable minimum. If BP determines that emissions from therefinery caused or are causing a nuisancecondition, or that odor control measuresin are inadequate, and if the identifiedproblems cannot be repaired or correctedwithin four hours, action shall be taken to minimize odors until repairs can bemade and the NWCAA shall be notified within 12 hours with a description of thecomplaint and action being taken to resolve the problem.The results of the investigation, identification of any malfunctioning equipment oraberrant operation, and the date and time ofrepair or mitigation shall be recorded.A log of these records shall be maintained for inspection.Receipt of a nuisance complaint in itselfshall not necessarily be a violation.- directly enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20064-8Table 4 - Generally Applicable RequirementsBP Cherry Point RefineryPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting4.15NuisanceNWCAA530(3/09/00)State Only)General NuisanceNo person shall discharge from any sourcequantities of air contaminants, with theexception of odors, in sufficient amountsand of such characteristics and duration asis likely to be injurious or cause damage tohuman health, plant or animal life, orproperty; or which unreasonably interfereswith enjoyment of life and property.An air contaminant is defined as “dust,fumes, mist, smoke, other particulatematter, vapor gas, odorous substance, orany combination thereof.Upon receiving an air contaminant complaint from the NWCAA or the publicaddressing conditions other than odors, BPshall investigate the complaint and theoperations of the refinery to determine whether refinery emissions have caused orare causing injury or damage to human health, plant or animal life or property, orunreasonably interfere with enjoyment of life or property. If BP determines thatemissions from the refinery caused or arecausing a nuisance condition, and if theidentified problems cannot be repaired or corrected within four hours, action shallbe taken to minimize emissions until repairs can be made and the NWCAA shallbe notified within 12 hours with a description of the complaint and action beingtaken to resolve the problem.The results of the investigation, identification of any malfunctioning equipment oraberrant operation, and the date and time ofrepair or mitigation shall be recorded.A log of these records shall be maintained for inspection.Receipt of a nuisance complaint in itselfshall not necessarily be a violation.-directly enforceable –BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20064-9Table 4 - Generally Applicable RequirementsBP Cherry Point RefineryPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting4.16GeneralWAC 173-400-040(5)(8/20/93)Same asState Only1/10/05Emission Detrimental to Persons orPropertyEmissions detrimental to health or propertyprohibited.4.17PMNWCAA550.1-4(7/14/05)State OnlyPreventing Particulate Matter fromBecoming AirborneUse reasonably available controltechnology (RACT) to prevent the releaseof fugitive particulate matter and do notallow fugitive particulate matter to bedeposited beyond the property lines of thefacility.4.18PMWAC 173-400-040(2)(1/10/05)State OnlyFalloutNuisance particulate fallout prohibited.4.19PMWAC 173-400-040(3)(a)(8/20/93)Same asState Only1/10/05Fugitive Emissions for Attainment AreasTake reasonable precautions to preventrelease of air contaminants required.4.20DustWAC 173-400-040(8)(a)(8/20/93)Same asState Only1/10/05Fugitive Dust SourcesReasonable precautions to preventrelease of fugitive dust required. Maintainand operate source to minimize emissions.Upon receiving an air contaminant complaint from the NWCAA or the publicaddressing conditions other than odors, BPshall investigate the complaint and theoperations of the refinery to determine whether refinery emissions have caused orare causing injury or damage to human health, plant or animal life or property, orunreasonably interfere with enjoyment of life or property. If BP determines thatemissions from the refinery caused or arecausing a nuisance condition, and if theidentified problems cannot be repaired or corrected within four hours, action shallbe taken to minimize emissions until repairs can be made and the NWCAA shallbe notified within 12 hours witha description of the complaint.The results of the investigation, identification of any malfunctioning equipment oraberrant operation, and the date and time ofrepair or mitigation shall be recorded.A log of these records shall be maintained for inspection.(see above)Receipt of a nuisance complaint in itselfshall not necessarily be a violation.- directly enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20064-10Table 4 - Generally Applicable RequirementsBP Cherry Point RefineryPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting4.21ReportsWAC 173-401-615(3)(9/16/02)Required Monitoring ReportsSubmit reports of any required monitoringto the NWCAA at least once every sixmonths. All instances of deviations frompermit requirements must be clearlyidentified in such reports.Monthly, quarterly and semiannual reportsare scheduled on a calendar basis.The reports shall be submitted within 30days after the close of the period that thereports cover. VOC reports shall besubmitted within 60 days.Unless specifically required otherwise by a permit term, monthly reports shallcover a calendar month, quarterly reports shall cover a calendar quarter, sixmonth reports shall cover January through June and July through December, andannual reports shall cover a calendar year. The first period shall cover the timefrom permit issuance until the first month, quarter, six-month period, or yearfollowing permit issuance.The reports shall be submitted within 30 days or 60 days for VOC reports onlyafter the close of the periodthat the reports cover.- directly enforceable –4.22ReportsWAC 173-400-050 (3)(2/19/91)Same asState Only1/10/05Measured concentrations for combustionand incineration units shall be adjusted forvolumes corrected to seven percentoxygen, except when Ecology or NWCAAdetermines that an alternate oxygencorrection factor is morerepresentative ofnormal operations.Follow 40 CFR 60 Appendix A4.23VOCNWCAA580.24(2/8/96)Process TurnaroundsProcess units shall be depressurized toless than 5 psig (gauge) before venting tothe atmosphere. During depressurization,VOCs shall be routed through a closedvent system to a flare or other appropriatedisposal device.Keep records of each process unit turnaround listing the date the unit wasshutdown. Report emissions from turnarounds in the annual emissions inventory.A specific record shall be kept for any turnaround during which a vessel containingVOC was vented to the atmosphere at a pressure at or above 5 psig.4.24VOCNWCAA580.25(2/8/96)Equipment for the reduction, collection ordisposal of VOC shall be maintained andoperated in a manner commensurate withaccepted industrial practices.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20064-11Table 4 - Generally Applicable RequirementsBP Cherry Point RefineryPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting4.25SO2NWCAALetter3/9/95PSD-3Condition 7(12/20/84)(state only)Refinery-wide emissions of SO2shall notexceed 2,468 lbs/hour on a monthlyaverage.4.26PMNWCAALetter3/9/95PSD-3Condition 7(12/20/84)(state only)Refinery-wide emissions of PM shall notexceed 4,258 lbs/day on a monthlyaverage.Report monthly totals on monthly reportingBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-1SECTION 5 - SPECIFICALLY APPLICABLE REQUIREMENTSThe cited requirements in the “Citation” column of these tables incorporated herein by reference are applicable only to the sources identified inthe preceding table header. These requirements are federally enforceable unless identified as “state only”. A requirement designated “stateonly” is enforceable only by the state, and not by the EPA or through citizen suits. The “Description” column of Table 5 is abrief description of theapplicable requirements for informational purposes only and is not enforceable. Where there is a “test method” column in a table, the columnidentifies (when appropriate) the test method associated with the applicable requirement as required by WAC 173-401-615(1)(a).Periodic orcontinuous monitoring requirements (including testing) are specified in the “Monitoring/Recordkeeping/Reporting” column, whichidentifiesmonitoring, record keeping and reporting (MR&R) obligations thesource must perform as required by WAC 173-401-605(1) and 615(1) and (2) orthe underlying requirements.The requirements in the MR&R column labeled “directly enforceable” are legally enforceable requirements added under the NWCAA’s“gap-filling”authority. Other requirements not labeled “directly enforceable” are brief descriptions of the regulatory requirements for information purposes andare not enforceable, unless they are identical to the cited requirement. Unless the text of the MR&R column is specifically identified to be directlyenforceable, the language of the cited regulation takes precedence over a paraphrased requirement.The provisions of federally approved NWCAA Section 365, Section366 and the “Guidelines for Industrial Monitoring Equipment andDataHandling” have been replaced in this section by NWCAA Section 367 and Appendix A - "Ambient Monitoring, Emission Testing and ContinuousEmission and Opacity Monitoring". NWCAA Section 367 and Appendix A were adopted on July 14, 2005 with a provision that one year from thedate of adoption would be allowed to achieve compliance with Appendix A. The new regulations are “State Only” until incorporated into the StateImplementation Plan. Section 367 and Appendix A are not materiallydifferent from the previous rule and guideline, but have been updated toinclude current monitoring technology and methods.Section 5 is separated into the following refinery process and product handling areas:SectionPage No.SectionPage No.5.1 Primary Crude/Vacuum Process Area 2 5.12 Flares 595.2 Naphtha HDS and Reformer Units 8 5.13 Sulfur Complex 655.3 Hydrocracker Area 17 5.14 Wastewater Plant and Sewer System 715.4 Delayed Coker 21 5.15 Tanks and Storage Vessels 945.5 #1 Diesel HDS Unit 265.16Shipping, Pumping, and Receiving 1255.6 #2 Diesel HDS Unit 305.16.1 Chemical Treaters 1255.7 Hydrogen Plant 355.16.2 Truck Rack 1275.8 Calciners 365.16.3 Marine Terminal 1375.9 Light End (LEU)/LPG Unit 425.16.4. LPG/LEU/Butane/Pentane Loading 1415.10 Isomerization Unit 445.17 Non-Hazardous Waste Landfarm 1425.11 Cooling Towers and Utility Boilers 50BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-25.1 Primary Crude/Vacuum Process AreaTable 5.1 - Specifically Applicable Requirements for the Primary Crude Oil/Vacuum Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire Crude/Vacuum Process AreaComponents in VOC ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.1.1VOC40 CFR 60.692-2(11/23/88), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NWCAA OAC #640(5/1/98) Condition 1NSPS Subpart QQQ - Individual Drain SystemsEach affected individual drain system shall beequipped with a water seal and/or caps andplugs so that VOC emissions are not vented tothe atmosphere.Except where repair is technically impossiblewithout a unit shutdown, when a broken seal,gap, crack or other problem is identified, firstefforts at repair shall be made as soon aspracticable, but not later than 15 calendar daysafter identification.Conduct Inspections as specified in Permit Term 5.14.1.5.1.2VOC40 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 #640Condition 1(5/1/98)NSPS Subpart QQQ - Individual JunctionBoxesEach affected individual junction box shall beequipped with a sealed cover, may have anopen vent pipe or may be routed to a closedvent system with a control device such as acarbon canister with no detectable emissions.Conduct Inspections as specified in Permit Term 5.14.2.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-3Table 5.1 - Specifically Applicable Requirements for the Primary Crude Oil/Vacuum Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.1.3VOC40 CFR 60.590-60.593 (10/17/00)which references60.480-60.489(12/14/00)NWCAA OAC #640Condition 2-7(5/1/98)NSPS Subpart GGG - Equipment LeaksMonitor affected components for fugitive leaks,repair leaks in a timely manner, and reportmonitoring results semi-annually in accordancewith 40 CFR 60 Subpart VV.Components include: pumps in liquid service,pressure relief valves in gas/liquid service, allsampling connection systems, all open-endedvalves or lines, all valves in gas/vapor serviceor light liquid service, all pumps and valves inheavy liquid service, pressure relief valves inlight liquid service, flanges and connectors.Conduct an Equipment Leak program (LDAR) as specified in Section6.2.5.1.4VOCNWCAA 580.221and 580.25 (2/8/96)Non-condensable VOC shall be piped to anappropriate firebox, incinerator or to a closedrefinery system.Equipment for the reduction, collection or disposal of VOC shall bemaintained and operated in a manner commensurate with acceptedindustrial practices.5.1.5VOCNWCAA 580.222and 580.25 (2/8/96)Hot wells associated with contact condensersshall be tightly covered and the collected VOCintroduced into a closed refinery system.Components in HAP ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.1.6HAP40 CFR 63.648(a)and (b) (8/18/98)which references60.480-60.489(12/14/00)Refinery MACT - Equipment LeaksMonitor affected components for fugitive leaks,repair leaks in a timely manner and reportmonitoring results semi-annually in accordancewith 40 CFR 60 Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section6.2.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-4Table 5.1 - Specifically Applicable Requirements for the Primary Crude Oil/Vacuum Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.1.7HAP40 CFR 63.647(c),63.654(a),63.654(i)(4) whichreferences 40 CFR61.340 through61.355Refinery MACT - Process DrainsEach affected individual drain system shall beequipped with a water seal and/or caps andplugs so that VOC emissions are not vented tothe atmosphere.Conduct inspections as specified in Permit Term 5.14.3.Follow 40 CFR 60 Appendix A Method 21Crude HeaterNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities5.1.8SO2(H2S)NWCAA RO #28(5/15/02)which references40 CFR 60.104(a)(1),60.105(a)(4),60.105(e)(3)(ii), and60.106(e)(1)(10/17/00)NSPS Subpart J – Fuel GasFuel gas limited to a composition of H2S<230mg/dscm (0.10 gr/dscf). Equivalent to 162 ppmH2S, 3 hour rolling average.Operate CEMs measuring H2S concentration in accordance withNWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60 Subpart Jand 40 CFR 60 Appendices B and F.Follow 40 CFR 60 Appendix A Method 11 or 15Report average H2S content (3 hour rolling average) in monthly report.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-5Table 5.1 - Specifically Applicable Requirements for the Primary Crude Oil/Vacuum Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNorth Vacuum HeaterNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities5.1.9SO2(H2S)NWCAA RO #28(5/15/02)which references40 CFR 60.104(a)(1),60.105(a)(4),60.105(e)(3)(ii), and60.106(e)(1)NSPS Subpart J - Fuel GasFuel gas limited to a composition of H2S<230mg/dscm (0.10 gr/dscf). Equivalent to 162 ppmH2S, 3 hour rolling average.Operate CEM for H2S concentration at the refinery mix drum inaccordance with NWCAA 367 and NWCAA Appendix A - (7/14/05), 40CFR 60 Subpart J and 40 CFR 60 Appendices B and F.Report average H2S content (3 hour rolling average) in monthly report.Follow 40 CFR 60 Appendix A Method 11 or 155.1.10NOxWDOE PSD-5Condition 3(12/17/85)After installation of low NOx burners,NOx Emissions shall not exceed 0.08 lb/MMBtuor 38 tons/year based on the average of any 60consecutive minutes.Note: Emissions based on heating load.Report maximum hourly average heating load in monthly emissionsreport.Report hourly average NOx emissions in monthly emissions report.Report NOx and CO (tpy) emissions in yearly report.5.1.11CONWCAA OAC #273bConditions 1, 2 and 3(11/18/04)CO emissions shall not exceed 27.7 tpy.Use emission factor of 0.0823 lb/MMBtu. Arevised emission factor may be used if moreaccurate data is available and approved byNWCAA.Maintain monthly records of CO emissions for each previous 12-monthperiod and maintain onsite for five years.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-6Table 5.1 - Specifically Applicable Requirements for the Primary Crude Oil/Vacuum Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.1.12H2SWDOE PSD-5Condition 5 & 6(12/17/85)The fuel concentration of H2S in the vacuumheater shall not exceed 160 ppm, 3 hour rollingaverage or 90 ppm on a monthly average.Operate CEM for H2S concentration at the refinery mix drum inaccordance NWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR60 Subpart J and 40 CFR 60 Appendices B and F.Report average H2S content (3 hour rolling average) in monthly report.Follow 40 CFR 60 Appendix A Method 11 or 155.1.13O2WDOE PSD-5Condition 4(12/17/85)Continuously monitor oxygen on the heater. Records must be kept onsite for five years.Use Performance Specification 3 (40 CFR 60 App B)5.1.14GeneralWDOE PSD-5Condition 2(12/17/85)Firing rate is not to exceed 77 MM Btu/hr. Report maximum heater load and number of excursions in monthlyemissions report.South Vacuum HeaterNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities5.1.15SO2(H2S)NWCAA RO #28(5/15/02)which references40 CFR 60.104(a)(1),60.105(a)(4),60.105(e)(1),60.105(e)(3)(ii)NSPS Subpart J – Fuel GasFuel gas limited to a composition of H2S<230mg/dscm (0.10 gr/dscf). Equivalent to 162 ppmH2S, 3 hour rolling average.Operate CEM for H2S concentration at the refinery mix drum inaccordance with NWCAA 367 and NWCAA Appendix A - (7/14/05), 40CFR 60 Subpart J and 40 CFR 60 Appendices B and F.Report average H2S content (3 hour rolling average) in monthly report.Follow 40 CFR 60 Appendix A Method 11 or 155.1.16SO2(H2S)NWCAA OAC #902aCondition 1(10/26/05)Fuel combusted in the heater shall be limited topipeline grade natural gas and refinery fuelgas.Keep records of fuel usage.-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-7Table 5.1 - Specifically Applicable Requirements for the Primary Crude Oil/Vacuum Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.1.17NOxNWCAA OAC #902aCondition 3(11/01/05)NOx emissions shall not exceed 10.5 lbs/hrbased on a calendar day average.Compliance with this condition shall be determined by a CEM installed,calibrated, maintained and operated to measure NOx and oxygen in thestack.Each monitor shall meet the appropriate sections of NWCAA Section 366and NWCAA Appendix A (7/14/05).Hourly emission rates for NOx shall be recorded. On-site documentationshall be kept showing the method of calculating the mass emission rate.Report data in monthly monitoring report.-directly enforceable5.1.18CONWCAA OAC #902aCondition 4(11/01/05)CO emissions shall not exceed 11.8 lbs/hr..Compliance with this condition shallbe determined by an initial sourceperformance test following EPA Method 10 conducted within 120 daysof initial startup. Test Methods1 through 4 of 40 CFR 60 Appendix Ashall be used in conjunction with the method listed above. All testingshall be done under maximum operating rates that are at, or above,90% of the design firing rate.The source test shall be conductedin accordance with NWCAA Section367 and NWCAA Appendix A (7/14/05).5.1.19OpacityNWCAA OAC #902aCondition 2(10/26/05)Visual emissions shall not exceed 5% for morethan three minutes in any consecutive 60-minuteperiodMonitor opacity in accordance with the provisions of Section 6.1.5.1.20GeneralNWCAA OAC #902aCondition 5(10/26/05)An operating and maintenance manual thatcontains O&M information on the ultra-low NOxburners shall be maintained on site.Maintain O&M manual onsite for review.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-85.2 Naphtha HDS and Reformer UnitsTable 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer UnitsPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire Naphtha HDS and Reformers AreaComponents in VOC ServiceNote: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.2.1VOC40 CFR 60.692-2(11/23/88), 60.692-5(10/17/00), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Subpart QQQ - Individual JunctionBoxesEach affected individual junction box shall beequipped with a sealed cover, may have anopen vent pipe or may be routed to a closedvent system with a control device such as acarbon canister with no detectableemissions.Perform inspection according to Permit Term 5.14.2.Components in HAP ServiceNote: The Title 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities.5.2.2HAP40 CFR63.648(a) and (b)(8/18/98) whichreferences 40 CFR60.480-60.489(12/14/00)Refinery MACT - Equipment LeaksMonitor affected components for fugitiveleaks, repair leaks in a timely manner andreport monitoring results semi-annually inaccordance with 40 CFR 60 Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-9Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer UnitsPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.2.3HAP40 CFR 63.647(c),63.654(a),63.654(i)(4) whichreferences 40 CFR61.340 through61.355 (8/18/95)Refinery MACT - Process DrainsEach affected individual drain system shallbe equipped with a water seal and/or capsand plugs so that VOC emissions are notvented to the atmosphere.Conduct inspections as specified in Permit Term 5.14.3.Follow 40 CFR 60 Appendix A Method 21Group 1 Process Vents in the Naphtha HDS and Reformers Area (11V-008, 11V-009, 11V-124 & 11V-144)Note: 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities.5.2.4HAP40 CFR 63.643(a) (1)(8/18/95)Refinery MACT - Process VentsControl HAP emissions from applicable ventsby 98% or to 20 ppmv using a flare.Note: Does not apply to catalyst regenerationvents per 40 CFR 63.640(d)(4).Follow monitoring, recordkeeping and reporting requirements for flares inPermit Terms 5.12.1 through 5.12.10(Flare used as control device)Follow 40 CFR 60 Appendix A Method 18BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-10Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer UnitsPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNaphtha HDS UnitNote: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.2.5SO2(H2S)NWCAA RO #28(5/15/02)which references:40 CFR 60.104(a)(1),60.105(a)(4),60.105(a)(3)(ii), and60.106(e)(1)(10/17/00)NSPS Subpart J – Fuel GasFuel gas limited to a composition of H2S<230mg/dscm (0.10 gr/dscf). Equivalent to 162ppm H2S, 3 hour rolling average.Operate CEM for H2S concentration at the fuel feed line in accordance withNWCAA 367 and Appendix A (7/14/05), 40 CFR 60 Subpart J and 40 CFR60 Appendices B and F.Periods of excess emissions thatshall be determined and reported aredefined as follows. All rolling 3-hour periods during which the averageconcentration of H2S as measured by the H2S continuous monitoring systemunder §60.105(a)(4) exceeds 162 ppmv.Report average H2S content (3-hour rolling average) in monthly report.Follow 40 CFR 60 Appendix A Method 11 or 15#1 Reformer UnitNote: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.2.6SO2(H2S)NWCAA RO #28(5/15/02)which references:40 CFR 60.104(a)(1),60.105(a)(4),60.105(e)(3)(ii), and60.106(e)(1)(10/17/00)NSPS Subpart J – Fuel GasFuel gas limited to a composition of H2S<230mg/dscm (0.10 gr/dscf). Equivalent to 162ppm H2S, 3 hour rolling average.Operate CEM for H2S concentration at the fuel feed line in accordance withNWCAA 367 and Appendix A - “AmbientMonitoring, Emission Testing, andContinuous Emission and Opacity Monitoring” (8/15/05), 40 CFR 60Subpart J and 40 CFR 60 Appendices B and F.Periods of excess emissions thatshall be determined and reported aredefined as follows. All rolling 3-hour periods during which the averageconcentration of H2S as measured by the H2S continuous monitoring systemunder §60.105(a)(4) exceeds 162 ppmv.Report average H2S content (3-hour rolling average) in monthly report.Follow 40 CFR 60 Appendix A Method 11 or 15BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-11Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer UnitsPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNote: The Title 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities5.2.7HAPOAC #562b (3/17/03)which references:40 CFR 63.648(a) and(b) (8/18/98) whichreferences 40 CFR60.480-60.489(12/14/00)BACT - Equipment LeaksMonitor affected components for fugitiveleaks, repair leaks in a timely manner, andreport monitoring results semi-annually inaccordance with 40 CFR 60 Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2Follow 40 CFR 60 Appendix A Method 215.2.8HAP40 CFR63.648(a) and (b)(8/18/98) whichreferences 40 CFR60.480-60.489(12/14/00)Refinery MACT - Equipment LeaksMonitor affected components for HAP leaks,repair leaks in a timely manner, and reportmonitoring results semi-annually inaccordance 40 CFR 60 Subpart VV.Components include: pumps in liquid service,pressure relief valves in gas/liquid service, allsampling connections, all open-ended valvesor lines, all valves in gas/vapor service,pressure valves in light liquid service, flangesand other connectors.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2Follow 40 CFR 60 Appendix A Method 215.2.9HAPOAC #562b (3/17/03)which references:40 CFR 63.647(c),63.654(a), 63.654(i)(4)which references 40CFR 61.340 through61.355 (8/18/95)BACT/Refinery MACT - Process DrainsEach affected individual drain system shall beequipped with a water seal and/or caps andplugs so that VOC emissions are not ventedto the atmosphere.Conduct inspections as specified in Permit Term 5.14.3.Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-12Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer UnitsPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.2.10General40 CFR 63.1574(f),63.1575(a) and (b)and 63.1576(b)(2/9/05)Refinery MACT II - GeneralFollow appropriate work practice standardsand comply with any applicable emissionstandards.Prepare, maintain and implement anoperation, maintenance and monitoring plan(OMMP) for each control system and operateat all times according to procedures in theplan.Submit compliance report on a semi-annual basis that includes anydeviation from emission limitation or work practice standards and informationon whether any continuous monitoring system was inoperative, inactive,malfunctioning, out-of-control, repaired or adjusted.Keep records to demonstrate that procedures in the OM&M Plan (OMMP)were followed. Maintain records available for review for five years.Submit any revisions to the OMMP to the NWCAA.5.2.11VOC/HAP40 CFR63.1566, 63.1570(f)and 63.1576(h)(2/9/05)Refinery MACT II – Organic HAP EmissionsControl organic HAP emissions bydepressuring and purging to a combustiondevice or a flare that meets the requirementsof §63.11(b).These limits do not apply to depressuringand purging operations when the reactorvent pressure is 5 psig or less.Operate in accordance with the Operation, Maintenance and MonitoringPlan (OMMP) and report any instances of deviation from any emissionlimitation, operating limit or work practice standard.Follow the MR&R requirements specified in Permit terms 5.12.1 - 5.12.12,excluding 5.12.5Keep records for a minimum of 5 years.5.2.12VOC/HAP40 CFR 63.1567,63.1570(f) and63.1576(h) (2/9/05)(2/9/05Refinery MACT II - Inorganic HAPEmissionsDuring coke burn-off and catalystrejuvenation reduce uncontrolled emissionsof hydrogen chloride by 92% by weight or toa concentration of 30 ppmv (dry) corrected to3% O2.Operate in accordance with the Operation, Maintenance and MonitoringPlan (OMMP) and report any instances of deviation from any emissionlimitation, operating limit or work practice standard.Demonstrate compliance by measuring and recording the HCLconcentration at least 4 times duringa regeneration cycle or every 4 hours,whichever is more frequent, using a colorimetric tube sampling system.Calculate daily average HCl concentration as arithmetic average of allsamples collected during a 24 hour period.Keep records for a minimum of 5 yearsBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-13Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer UnitsPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting#2 Reformer UnitNote: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.2.13SO2(H2S)NWCAA RO #28(5/15/02) whichreferences40 CFR 60.104(a)(1),60.105(a)(4),60.105(e)(3)(ii), and60.106(e)(1)(10/17/00)NSPS Subpart J – Fuel GasFuel gas limited to a composition of H2S<230mg/dscm (0.10 gr/dscf). Equivalent to 162ppm H2S, 3 hour rolling average.Operate CEM for H2S concentration at the fuel feed line in accordance withNWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60 Subpart J and40 CFR 60 Appendices B and F.Periods of excess emissions thatshall be determined and reported aredefined as follows. All rolling 3-hour periods during which the averageconcentration of H2S as measured by the H2S continuous monitoring systemunder §60.105(a)(4) exceeds 162 ppmv.Report average H2S content (3-hour rolling average) in monthly report.Follow 40 CFR 60 Appendix A Method 11 or 155.2.14VOCOAC #305 (11/14/85)which references:40 CFR 60.590-60.593 (10/17/00)which references 40CFR 60.480-60.489(12/14/00)BACT/NSPS Subpart GGG - EquipmentLeaksMonitor affected components for fugitiveleaks, repair leaks in a timely manner, andreport monitoring results semi-annually inaccordance with 40 CFR 60 Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-14Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer UnitsPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.2.15General40 CFR 63.1574(f),63.1575(a) and (b) and63.1576(b) (2/9/05)Refinery MACT II - GeneralFollow appropriate work practice standardsand comply with any applicable emissionstandards.Prepare, maintain and implement anoperation, maintenance and monitoring plan(OMMP) for each control system and operateat all times according to procedures in theplan.Submit compliance report on a semi-annual basis that includes any deviationfrom emission limitation or work practice standards and information onwhether any continuous monitoring system was inoperative, inactive,malfunctioning, out-of-control, repaired or adjusted.Keep records to demonstrate that procedures in the OM&M Plan (OMMP)were followed. Maintain records available for review for five years.Submit any revisions to the OMMP to the NWCAA.5.2.16VOC/ HAP40 CFR 63.1566,63.1570(f) and63.1576(h) (2/9/05)Refinery MACT II – Organic HAP EmissionsControl organic HAP emissions bydepressuring and purging to a combustiondevice or a flare that meets the requirementsof §63.11(b).These limits do not apply to depressuring andpurging operations when the reactor ventpressure is 5 psig or less.Operate in accordance with the Operation, Maintenance and Monitoring Plan(OMMP) and report any instances of deviation from any emission limitation,operating limit or work practice standard.Follow the MR&R requirements specified in Permit terms 5.12.1 - 5.12.12,excluding 5.12.5Keep records for a minimum of 5 years.5.2.17VOC/HAP40 CFR 63.1567,63.1570(f) and63.1576(h) (2/9/05)(2/9/05Refinery MACT II - Inorganic HAPEmissionsDuring coke burn-off and catalystrejuvenation reduce uncontrolled emissionsof hydrogen chloride by 92% by weight or toa concentration of 30 ppmv (dry) corrected to3% O2.Operate in accordance with the Operation, Maintenance and MonitoringPlan (OMMP) and report any instances of deviation from any emissionlimitation, operating limit or work practice standard.Demonstrate compliance by measuring and recording the HCLconcentration at least 4 times duringa regeneration cycle or every 4 hours,whichever is more frequent, using a colorimetric tube sampling system.Calculate daily average HCl concentration as arithmetic average of allsamples collected during a 24 hour period.Keep records for a minimum of 5 yearsBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-15Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer UnitsPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingThe following conditions specified in OAC 305 and PSD-7 apply to the #2 Reformer Heater.5.2.18COWDOE PSD-7Condition 1a(3/13/86)NWCAA OAC # 305Condition 1(11/14/85)Emissions shall not exceed 11.0 lb/hr or 48.3tpy, based on the average of 60 consecutiveminutes.CO emission rate based on heating load.5.2.19NOxWDOE PSD-7Condition 1b(3/13/86)NWCAA OAC # 305Condition 1(11/14/85)Emissions shall not exceed 32.0 lb/hr or 140tpy (as NO2), based on the average of 60consecutive minutes.Note: Emissions based on heating load5.2.20GeneralWDOE PSD-7Condition 2 (3/13/86)NWCAA OAC # 305Condition 1(11/14/85)Firing of the heater shall not exceed 340MMBtu/hr, based on hourly averagecalculated heat content of the fuel.Note: Emissions based on heating load.Report hourly maximum heat load in monthly emissions report.Emissions calculations for CO based on EPA emission factor (0.028lb/MMBtu) when the PSD permit was issued.- directly enforceable -5.2.21O2WDOE PSD-7Condition 3(3/13/86)Continuously monitor oxygen on the heater. Records must be kept onsite for two years.Follow Performance Specification 3 (40 CFR 60 App B)5.2.22H2SNWCAA OAC #305Condition 3(11/14/85)The fuel concentration of H2S in the heatershall not exceed 160 ppm H2S, 3 hour rollingaverage or 90 ppm on a monthly average.Operate CEM for H2S concentration in the fuel feed line in accordance withNWCAA 367 and NWCAA Appendix A - (7/14/05), and 40 CFR 60 AppendixB.Follow 40 CFR 60 Appendix A Method 11 or 15BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-16Table 5.2 - Specifically Applicable Requirements for the Naphtha HDS and Reformer UnitsPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.2.23PM/PM10NWCAA OAC #305Condition 6(11/14/85)Emissions shall not exceed 0.01 gr/dscf,corrected to 7% oxygenFollow the MR&R requirements specified in Permit terms 6.1.Follow 40 CFR 60 Appendix A Method 55.2.24OpacityNWCAA OAC #305Condition 5(11/14/85)Opacity shall not exceed 5% opacity formore than three minutes in any one hour.Monitor opacity in accordance with Section 6.1BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-175.3 Hydrocracker AreaTable 5.3 - Specifically Applicable Requirements for the Hydrocracker AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire Hydrocracker AreaComponents in HAP ServiceNote: The Title 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities.5.3.1HAP40 CFR 63.648(a)and (b) (8/18/98)which references 40CFR 60.480-60.489(12/14/00)Refinery MACT - Equipment LeaksMonitor affected components for fugitive leaks,repair leaks in a timely manner and reportmonitoring results semi-annually in accordancewith 40 CFR 60 Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2Follow 40 CFR 60 Appendix A Method 215.3.2HAP40 CFR 63.647(c),63.654(a),63.654(i)(4) whichreferences 40 CFR61.340 through61.355Refinery MACT - Process DrainsEach affected individual drain system shall beequipped with a water seal and/or caps andplugs so that VOC emissions are not vented tothe atmosphere.Conduct inspections as specified in Permit Term 5.14.3.Follow 40 CFR 60 Appendix A Method 21Affected Process Vent 15-V-0575.3.3HAP40 CFR 63.643(a)(1)(6/18/95)Refinery MACT - Process VentsControl HAP emissions from applicable vents byusing a flare for Group I process vents.Follow monitoring, recordkeeping and reporting requirements for flaresin Permit Terms 5.12.1 through 5.12.10(Flare used as control device)Follow 40 CFR 60 Appendix A Method 18BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-18Table 5.3 - Specifically Applicable Requirements for the Hydrocracker AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire Hydrocracker AreaComponents in VOC ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.3.4VOC40 CFR 60.692-2(11/23/88), 60.692-5(10/17/00), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Subpart QQQ - Individual Junction BoxesEach affected individual junction box shall beequipped with a sealed cover, may have anopen vent pipe or may be routed to a closedvent system with a control device such as acarbon canister with no detectable emissions.Conduct inspections as specified in Permit Term 5.14.2.R-1 Hydrocracker Reactor Heater, R-4 Hydrocracker Reactor Heater, and 1stStage Fractionator Reboiler5.3.5SO2(H2S)NWCAA RO #28(5/15/02) whichreferences40 CFR60.104(a)(1),60.105(a)(4),60.105(e)(3)(ii) and60.106(e)(1)(10/17/00)NSPS Subpart J – Fuel GasFuel gas limited to a composition of H2S<230mg/dscm (0.10 gr/dscf). Equivalent to 162 ppmH2S, 3 hour rolling average.Operate CEM for H2S concentration at the fuel feed line in accordancewith NWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60Subpart J and 40 CFR 60 Appendices B and F.Periods of excess emissions thatshall be determined and reported aredefined as follows. All rolling 3-hour periods during which the averageconcentration of H2S as measured by the H2S continuous monitoringsystem under §60.105(a)(4) exceeds 162 ppmv.Report average H2S content (3 hour rolling average) in monthly report.Follow 40 CFR 60 Appendix A Method 11 or 155.3.6SO2(H2SNWCAA Permit toConstruct (6/8/70)This unit is required to use only fuel gas.Facility configured touse only fuel gasBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-19Table 5.3 - Specifically Applicable Requirements for the Hydrocracker AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting2ndStage Fractionator Reboiler Heater5.3.7SO2(H2S)NWCAA RO #28(5/15/02) whichreferences40 CFR60.104(a)(1),60.105(a)(4),60.105(e)(3)(ii) and60.106(e)(1)(10/17/00)NSPS Subpart J – Fuel GasFuel gas limited to a composition of H2S<230mg/dscm (0.10 gr/dscf). Equivalent to 162 ppmH2S, 3 hour rolling average.Operate CEM for H2S concentration at the fuel feed line in accordancewith NWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60Subpart J and 40 CFR 60 Appendices B and F.Periods of excess emissions thatshall be determined and reported aredefined as follows. All rolling 3-hour periods during which the averageconcentration of H2S as measured by the H2S continuous monitoringsystem under §60.105(a)(4) exceeds 162 ppmv.Report average H2S content (3 hour rolling average) in monthly report.Follow 40 CFR 60 Appendix A Method 11 or 155.3.8SO2(H2S)NWCAA OAC #847Condition 1(11/13/03)Fuel combusted in the heater shall be limited topipeline grade natural gas and refinery fuel gas.Keep records of fuel usage.-directly enforceable5.3.9NOxNWCAA OAC #847Conditions 4 and 5(11/13/03)Emission of NOx from the heater stack shall notexceed 0.07 lb/MMBtu based on a 24-houraverage and shall not exceed 56.2 tpy on acalendar year rolling average.Report NOx emissions based on firing rates on a calendar month basiswithin 30 days after the end of the previous month.Conduct periodic source testing once every five years within threemonths of the anniversary of the initial test.Follow 40 CFR 60 Appendix A Method 205.3.10OpacityNWCAA OAC #847Condition 2(11/13/03)Visual emissions shall not exceed 5% for morethan three minutes in any consecutive 60-minute periodMonitor opacity in accordance with provisions of Section 6.1.5.3.11GeneralNWCAA OAC #847Condition 3(11/13/03)The maximum firing rate of the reboiler heatershall not exceed 183.4 MMBtu/hr.Keep records of heater firing rate in MMBtu/hr.-directly enforceable5.3.12GeneralNWCAA OAC #847Condition 6(11/13/03)An operating and maintenance manual thatcontains O&M information on the-low NOxburners shall be maintained on site.Maintain O&M manual on site.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-20Table 5.3 - Specifically Applicable Requirements for the Hydrocracker AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingPiping Associated with Incremental Vacuum Gas Oil Recovery Project5.3.13VOC/HAPNWCAA OAC #850(12/1/03)Project valve components shall be subject tothe applicable portions of 40 CFR 63 SubpartCC.For valves that have the potential to leakhazardous organic pollutants installed as a partof this project:•leak detection and repair shall occur no lessfrequently than quarterly•the leak definition for block valves andcontrol valves is 500 ppmFollow procedures for an Enhanced Leak Detection Program asspecified in Section 6.3b.Follow 40 CFR 60 Appendix A Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-215.4 Delayed CokerTable 5.4 - Specifically Applicable Requirements for the Delayed Coker AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire Delayed Coker AreaComponents in HAP ServiceNote: The Title 40 CFR 63 General Provisions included in Section 3 apply5.4.1HAP40 CFR 63.648(a)and (b) (8/18/98)which references40 CFR 60.480-60.489 (12/14/00)Refinery MACT - Equipment LeaksMonitor applicable components for fugitive leaks,repair leaks in a timely manner and reportmonitoring results semi-annually in accordance with40 CFR 60 Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section6.2Follow 40 CFR 60 Appendix A Method 21Components in VOC ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.4.2VOC40 CFR 60.692-2(11/23/88) 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Subpart QQQ - Individual Drain SystemsEach applicable individual drain system shall beequipped with a water seal and/or caps and plugs sothat VOC emissions are not vented to theatmosphere.Except where repair is technically impossible withouta unit shutdown, when a broken seal, gap, crack orother problem is identified, first efforts at repair shallbe made as soon as practicable, but not later than15 calendar days after identification.Conduct Inspections as specified in Permit Term 5.14.1.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-22Table 5.4 - Specifically Applicable Requirements for the Delayed Coker AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.4.3VOC40 CFR 60.692-2(11/23/88),60.692-5(10/17/00), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Subpart QQQ - Individual Junction BoxesEach affected individual junction box shall beequipped with a sealed cover, may have an openvent pipe or may be routedto a closed vent systemwith a control device such as a carbon canister withno detectable emissions.Conduct Inspections as specified in Permit Term 5.14.2.5.4.4VOC40 CFR 60.590-60.593 (10/17/00)which references40 CFR 60.480-60.489 (12/14/00)NSPS Subpart GGG - Equipment LeaksMonitor applicable components for fugitive leaks,repair leaks in a timely manner, and reportmonitoring results semi-annually in accordance with40 CFR 60 Subpart VV.Applicable components include: pumps in liquidservice, pressure relief valves in gas/liquid service,all sampling connection systems, all open-endedvalves or lines, all valvesin gas/vapor service orlight liquid service, all pumps and valves in heavyliquid service, pressure relief valves in light liquidservice, flanges and other connectors.Conduct an Equipment Leak program (LDAR) as specified in Section6.2Coker Affected Process Vent 12-V-130Note: The Title 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities5.4.5HAP40 CFR63.643(a)(1)(6/18/95)Refinery MACT - Process VentsControl HAP emissions from applicable vents byusing a flareFollow monitoring, recordkeeping and reporting requirements forflares in Permit Terms 5.12.1 through 5.12.10(Flare used as control device.)Follow 40 CFR 60 Appendix A Method 18BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-23Table 5.4 - Specifically Applicable Requirements for the Delayed Coker AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNorth and South Coker Charge Heaters5.4.6OpacityNWCAA OAC#689Condition 1.1.4and 2.1.4(4/13/99)Opacity not to exceed 5% in 6 minutes Monitor opacity in accordance with Section 6.1Follow WDOE Method 95.4.7SO2NWCAA OAC#689Condition 1.1.2and 2.1.2(4/13/99)SO2emissions shall not exceed 101 lb/MMscf or anannual maximum of 72 tpy.Perform biennial performance test on one of two identical heatersusing EPA Method 6 or 6C or FuelGas Analysis using Method 11 or15.5.4.8CONWCAA OAC#689Condition 1.1.3and 2.1.3(4/13/99)CO emissions shall not exceed 29 lb/MMscf or anannual maximum of 19 tpy.Perform biennial performance test on one of two identical heatersusing 40 CFR 60 Appendix A Method 10, 10B or approvedalternative.5.4.9NOxNWCAA OAC#689Condition 1.1.1and 2.1.1(4/13/99)NOx emissions shall not exceed 0.08 lb/MMBtu oran annual maximum of 66 tpy.Perform biennial performance test on one of two identical heatersusing 40 CFR 60 Appendix A Method 7A or 7E.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-24Table 5.4 - Specifically Applicable Requirements for the Delayed Coker AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNote: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.4.10SO2(H2S)40 CFR60.104(a)(1),60.105 (a)(4),60.105(e)(3)(ii)and 60.106(e)(1)(10/17/00)NSPS Subpart J – Fuel GasFuel gas limited to a composition of H2S<230mg/dscm (0.10 gr/dscf). Equivalent to 162 ppmH2S, 3 hour rolling average.Operate CEM for H2S concentration at the fuel feed line inaccordance with NWCAA 367 and NWCAA Appendix A - (7/14/05),40 CFR 60 Subpart J and 40 CFR 60 Appendices B and F.Periods of excess emissions thatshall be determined and reportedare defined as follows. All rolling 3-hour periods during which theaverage concentration of H2S as measured by the H2S continuousmonitoring system under §60.105(a)(4) exceeds 162 ppmv.Report average H2S content of fuel gas (3-hour rolling average) inmonthly report.Follow 40 CFR 60 Appendix A Method 11 or 155.4.11H2SNWCAA OAC#689Condition 1.5.1and 2.5.1(4/13/99)Daily average of H2S for fuel gas supplies to Cokercharge heaters shall not exceed 50 ppmvd on a 24-hour average.Operate CEM for H2S concentration at the fuel feed line inaccordance with NWCAA 367 and NWCAA Appendix A - (7/14/05),40 CFR 60 Subpart J and 40 CFR 60 Appendices B and F.Report H2S content of fuel gas (maximum daily average) in monthlyreport.Follow 40 CFR 60 Appendix A Method 11 or 15BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-25Table 5.4 - Specifically Applicable Requirements for the Delayed Coker AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingCoker Compressor 12-1801Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.4.12VOC40 CFR 60.482-3(b)(2)NSPS Subpart VV - CompressorsEach compressor shall be installed with a sealsystem that includes a barrier fluid system thatprevents the leakage of VOC.Seal system is a barrier seal system that has the barrier fluiddegassing reservoir routed to a process or fuel gas system orconnected by a closed vent systemto a control device that complieswith 40 CFR 60.482-10.Follow 40 CFR 60 Appendix A Method 215.4.13VOCNWCAA OAC#890Condition8(2/22/05)Coker blowdown vapors shall be routed to andrecovered by compressor #12-1801.This condition provides emissions reduction for thepurpose of PSD netting to offset potential increasein SO2emissions associated with the SRUModification Project.The coker blowdown vapor recovery project shallbe completed and in operation prior to startup of thesecond Tail Gas Unit.Compliance shall be demonstrated by:•continuously monitoring and recording the position of remoteactivated valve #HV-331and the intake pressure of thecompressor,•following written standard operating procedures that assurethe coker blowdown vapors are properly routed to thecompressor except during times when the intake pressure ofthe compressor is near its suction pressure or during processupset or maintenance•records shall be kept of each process upset or maintenanceactivity when coker vapors are not recovered•keep records of time, date duration and description of eachevent and provide estimate of SO2emissions that otherwisewould have been recoveredBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-265.5 #1 Diesel HDS UnitTable 5.5 - Specifically Applicable Requirements for the #1 Diesel HDS Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire No. 1 Diesel HDS UnitComponents in VOC ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.5.1VOC40 CFR 60.692-2(11/23/88), 60.692-5(10/17/00), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Subpart QQQ - IndividualJunction BoxesEach affected individual junction boxshall be equipped with a sealedcover, may have an open vent pipeor may be routed to a closed ventsystem with a control device such asa carbon canister with no detectableemissions.Conduct Inspections as specified in Permit Term 5.14.2.Components in HAP ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities5.5.2HAPS40 CFR 63.648(a)and (b) (8/18/98)which references60.480-60.489(12/14/00)Refinery MACT - Equipment LeaksMonitor affected components forfugitive leaks, repair leaks in a timelymanner and report monitoringresults semi-annually in accordancewith 40 CFR 60 Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2No. 1 Diesel HDS Charge Heater & No. 1 Diesel HDS Reboiler Heater5.5.3H2S(SO2)NWCAA Permit toConstruct (6/8/70)This unit is required to use only fuelgas.Facility configured touse only fuel gas.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-27Table 5.5 - Specifically Applicable Requirements for the #1 Diesel HDS Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities5.5.4H2S(SO2)NWCAA RO #28(5/15/02) whichreferences40 CFR 60.104(a)(1),60.105(a)(4),60.105(e)(3)(ii) and60.106(e)(1)(10/17/00)NSPS Subpart J – Fuel GasFuel gas limited to a composition ofH2S<230 mg/dscm (0.10 gr/dscf).Equivalent to 162 ppm H2S, 3 hourrolling average.Operate CEM for H2S concentration at the refining mix drum in accordancewith NWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60 Subpart Jand 40 CFR 60 Appendices B and F.Periods of excess emissions that shall be determined and reported are definedas follows. All rolling 3-hour periods during which the average concentration ofH2S as measured by the H2S continuous monitoring system under§60.105(a)(4) exceeds 162 ppmv.Report average H2S content (3 hour rolling average) in monthly report.Follow 40 CFR 60 Appendix A Method 11 or 155.5.5H2S(SO2)NWCAA OAC #949Condition 1(3/31/06)Fuel combusted in the #1 DieselHydrotreater Charge Heater shall belimited to pipeline grade natural gasand treated refinery fuel gas.Keep a record of fuel burned at the Charge Heater.-directly enforceable5.5.6NOxNWCAA OAC #949Condition 3 and 7(3/31/06)NOx emissions from the #1 DieselHydrotreater Charge Heater shallnot exceed 1.9 lb/hour or 0.040lb/MMBtu (higher heating value).NOx emissions shall be determined by an initial source test with ongoingcompliance to be demonstrated by subsequent source tests to be conductedevery three years. Source tests mustbe performed within one month of theanniversary of the previous source test.Source tests shall be conducted above 70% of the heater’s maximum firingrate and in accordance with NWCAA Section 367 and NWCAA Appendix A.Use EPA Method 7EBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-28Table 5.5 - Specifically Applicable Requirements for the #1 Diesel HDS Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.5.7CONWCAA OAC #949Condition 4 and 7(3/31/06)CO emissions from the #1 DieselHydrotreater Charge Heater shallnot exceed 3.2 lb/hour or 0.068lb/MMBtu (higher heating value).CO emissions shall be determined by an initial source test with ongoingcompliance to be demonstrated by subsequent source tests to be conductedevery three years. Source tests mustbe performed within one month of theanniversary of the previous source test.Source tests shall be conducted above 70% of the heater’s maximum firingrate and in accordance with NWCAA Section 367 and NWCAA Appendix A.Use EPA Method 105.5.8NOxNWCAA OAC #949Condition 5 and 7(3/31/06)NOx emissions from the StabilizerReboiler Heater shall not exceed 26ppmv (dry basis corrected to 7%O2) based on a 24-hour rollingaverage.If this concentration is exceeded, asecondary limit to demonstratecompliance is 2.2 lb/hour based on a24-hour rolling average.NOx emissions shall be determined by an initial source test with ongoingcompliance demonstrated by a CEM installed, calibrated, maintained andoperated to measure NOx and O2in the stack by no later than December 1,2008. Each monitor shall meet the appropriate specifications of NWCAASection 367 and Appendix A and 40 CFR 60 Appendices B and F.Use EPA Method 7E for source testing. (To be completed 7/13/06)Source testing shall be conducted atabove 90% of the Stabilizer ReboilerHeater’s maximum firing rate.5.5.9CONWCAA OAC #949Condition 6 and 7(3/31/06)CO emissions from the StabilizerReboiler Heater shall not exceed 3.8lb/hr.CO emissions shall be determined by an initial source test with ongoingcompliance to be demonstrated by subsequent source tests to be conductedevery three years. Source tests mustbe performed within one month of theanniversary of the previous source test.Source tests shall be conducted above 90% Stabilizer Reboiler Heater’smaximum firing rate and in accordance with NWCAA Section 367 and NWCAAAppendix A.Use EPA Method 105.5.10VisualNWCAA OAC #949Condition 2(3/31/06)Visual emissions from the #1 DieselHydrotreater Charge Heater and theStabilizer ReboilerHeater shall notexceed 5% opacity for more than 3minutes in any 60-minute period.Use Department of Ecology Test Method 9A.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-29Table 5.5 - Specifically Applicable Requirements for the #1 Diesel HDS Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.5.11GeneralNWCAA OAC #949Condition 8(3/31/06)An operating and maintenance(O&M) manual shall be maintainedon site for the No. 1 DieselHydrotreater Charge Heater and theStabilizer Reboiler Heater thatincludes information on operationand maintenance of the ultra lowNOx burners.Keep operating and maintenance manuals on-site for each heater.5.5.12VOC/HAPNWCAA OAC #949Condition 9(3/31/06)New LDAR components associatedwith the #1 DHDS Heater ReliabilityProject that have the potential toleak VOCs or HAPs shall bemonitored using a leak definition of500ppm for block valves and controlvalves.Monitoring in accordance with Section 6.3b.Record, track, repair and remonitor all leaks greater than the leak definition.BP will have 30 days to make repairs andremonitor all leaks greater than the500 ppm leak definition but less than theapplicable leak definition specified inapplicable portions of 40 CFR 63 Subpart CC.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-305.6 #2 Diesel HDS UnitTable 5.6 - Specifically Applicable Requirements for the #2 Diesel HDS Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire No. 2 Diesel HDS UnitComponents in VOC ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.6.1VOC40 CFR 60.692-2(11/23/88) 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Subpart QQQ - IndividualDrain SystemsEach applicable individual drainsystem shall be equipped with awater seal and/or caps and plugs sothat VOC emissions are not ventedto the atmosphere.Except where repair is technicallyimpossible without a unit shutdown,when a broken seal, gap, crack orother problem is identified, firstefforts at repair shall be made assoon as practicable, but not laterthan 15 calendar days afteridentification.Conduct inspections as specified in Permit Term 5.14.1.5.6.2VOC40 CFR 60.692-2(11/23/88), 60.692-5(10/17/00), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Subpart QQQ - IndividualJunction BoxesEach affected individual junction boxshall be equipped with a sealedcover, may have an open vent pipeor may be routed to a closed ventsystem with a control device such asa carbon canister with no detectableemissions.Conduct inspections as specified in Permit Term 5.14.2.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-31Table 5.6 - Specifically Applicable Requirements for the #2 Diesel HDS Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingComponents in HAP ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities5.6.3HAP40 CFR 63.648(a)and (b) (8/18/98)which references60.480-60.489(12/14/00)Refinery MACT - Equipment LeaksMonitor affected components forfugitive leaks, repair leaks in a timelymanner and report monitoringresults semi-annually in accordancewith 40 CFR 60 Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2.Additional Requirements for Leak Detection and Repair for No. 2 Diesel HDS Unit5.6.4HAPNWCAA OAC # 892Condition 6(3/3/05)BACT – Enhanced LDARIn addition to 40 CFR 60 SubpartGGG requirements valves andpumps shall be monitored for leaksno less frequently than quarterly.Leak definition shall be 500 ppm forcontrol valves and block valves and2,000 ppm for pumps.Valves and pumps identified asleaking at this level, but less than theapplicable regulatory leak definitionshall be allowed 30 days for repairand re-monitoring.Follow procedures for an Enhanced Leak Detection Program as specified inSection 6.3a.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-32Table 5.6 - Specifically Applicable Requirements for the #2 Diesel HDS Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNo. 2 Diesel HDS Charge Heater5.6.5OpacityNWCAA OAC # 892Condition 2(3/3/05)Visual emissions for the heaterstack shall not exceed 5% opacityfor more than three minutes in any60-minute period.Monitor opacity in accordance with the provisions of Section 6.1.5.6.6SO2(H2S)NWCAA OAC # 892Condition 1(3/3/05)Fuel combusted shall be limited topipeline grade natural gas andrefinery fuel gas.Keep records of fuel usage.-directly enforceable5.6.7SO2(H2S)NWCAA OAC # 892Condition 3(3/3/05)NSPS Subpart J – Fuel GasThe H2S content of fuel gascombusted in the heater shall notexceed 162 ppm based on a 3-hourrolling average and +50 ppm basedon a 24-hour rolling average.Install and operate CEM to measure H2S concentration in the fuel gas to theheater. The monitor shall meet the appropriate requirements of 40 CFR 60Subpart J, 40 CFR 60 Appendices B and F, NWCAA 367 and NWCAAAppendix A - (7/14/05).Periods of excess emissions that shall be determined and reported are definedas follows: (1) all rolling 3-hour periods during which the averageconcentration of H2S as measured by the CEM exceeds 162 ppmv and (2) allrolling 24-hour periods during which the average concentration of H2S asmeasured by the CEM exceeds 50 ppmv.-directly enforceable5.6.8NOxNWCAA OAC # 892Condition 4a(3/3/05)NOx emissions shall not exceed0.035 lb/MMBtu. Tests to beconducted at or above 90% ofdesign firing rate.Conduct source test within 120 days of initial startup and then annuallythereafter. Annual source test shall be performed within 10 and 12 months ofprevious test. Conduct tests in accordance with NWCAA 367 and NWCAAAppendix A - (7/14/05).Follow 40 CFR 60 Appendix A Method 7EBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-33Table 5.6 - Specifically Applicable Requirements for the #2 Diesel HDS Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.6.9CONWCAA OAC #892Condition 4b(3/3/05)CO emissions shall not exceed 70ppmvd @7% O2. Tests to beconducted at or above 90% ofdesign firing rate.Conduct source test within 120 days of initial startup and then annuallythereafter. Annual source test shall be performed within 10 and 12 months ofprevious test. Conduct tests in accordance with NWCAA 367 and NWCAAAppendix A - (7/14/05).Follow 40 CFR 60 Appendix A Method 105.6.10CO40 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 HeatersCO emissions shall not exceed 400ppmv corrected to 3% O2(3-runaverage).Testing shall be conducted atmaximum normal operating loadand consist of three 1-hour runs.Submit site specific test plan for CO at least 60 days prior to the initialperformance test. Conduct initial performance testing within 180 days afterstartup and then annually thereafter between 10 and 12 months after thepreceding test.Provide results within 60 days after completion of source test. Keep recordsfor five years.Follow 40 CFR 60 Appendix A Method 105.6.11General(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 HeatersDevelop and implement a writtenstartup, shutdown and malfunction(SSM) plan that details proceduresfor operating and maintaining thesource during periods of startup,shutdown and malfunction. Theplan shall be adopted prior to initialstartup of the heater.Maintain current SSM Plan on site.If any action taken during a startup, shutdown or malfunction event is notconsistent with the SSM Plan, reportany deviation for that event within twoworking days to NWCAA.Keep records of any startup, shutdown oroccurrence of malfunction includingrequired maintenance performed on air pollution control and monitoringequipment. Maintain records for five years of which at least two years mustbe onsite.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-34Table 5.6 - Specifically Applicable Requirements for the #2 Diesel HDS Process AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.6.12General40 CFR 63.7550(c)(9/13/04)NESHAPS Subpart DDDDD -Process HeatersSubmit semi-annual compliancereport identifying source; deviationsfrom emission limits, operatinglimits or work practice standards;monthly fuel use; and summary ofannual performance test results.Submit semi-annual compliance report as indicated:•July 31 for the period January 1 through June 30•January 31 for the period July 1 through December 315.6.13GeneralNWCAA OAC # 892Condition 5(3/3/05)An operating and maintenancemanual that contains O&Minformation on the ultra-low NOxburners shall be maintained on site.Maintain O&M manual on site.Group 1 Process Vent on #2 DHDS UnitNote: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.6.14VOC40 CFR 63 SubpartCC 63.643(a)(1)(6/18/95)Refinery MACT Process VentsControl VOC emissions fromapplicable vents by using a flare forGroup I process vents.Follow monitoring, recordkeeping and reporting requirements for flares inPermit Terms 5.12.1 through 5.12.10(Flare used as control device)Follow 40 CFR 60 Appendix A Method 18BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-355.7 Hydrogen PlantTable 5.6 - Specifically Applicable Requirements for the Hydrogen PlantPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNorth Reforming Furnace #1 and South Reforming Furnace #25.7.1NWCAA Permit toConstruct (6/8/70)This unit is required to use only fuel gasFacility configured touse only fuel gas.Note: 40 CFR 60 General Provisions included inSection 3 apply to these affected facilities.5.7.2SO2(H2S)NWCAA RO #28(5/15/02) whichreferences40 CFR60.104(a)(1),60.105(a)(4),60.105(e)(3)(ii)and 60.106(e)(1)(10/17/00)NSPS Subpart J – Fuel GasFuel gas limited to a composition of H2S<230mg/dscm (0.10 gr/dscf). Equivalent to 162 ppmH2S, 3 hour rolling average.Operate CEM for H2S concentration at the fuel feed line in accordance withNWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60 Subpart J and40 CFR 60 Appendices B and F.Periods of excess emissions thatshall be determined and reported aredefined as follows. All rolling 3-hour periods during which the averageconcentration of H2S as measured by the H2S continuous monitoring systemunder §60.105(a)(4) exceeds 162 ppmv.Report average H2S content (3 hour rolling average) in monthly report.Follow 40 CFR 60 Appendix A Method 11 or 15BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-365.8 CalcinersTable 5.8 - Specifically Applicable Requirements for the Calciner AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingCalciner #1, #2, and #3Components in VOC ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.8.1VOC40 CFR 60.692-2(11/23/88) 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NWCAA OAC #689for Calciner Hearths 1& 2.(4/13/99)NSPS Subpart QQQ - Individual DrainSystemsEach applicable individual drain system shallbe equipped with a water seal and/or capsand plugs so that VOC emissions are notvented to the atmosphere.Except where repair is technically impossiblewithout a unit shutdown, when a broken seal,gap, crack or other problem is identified, firstefforts at repair shall be made as soon aspracticable, but not later than 15 calendardays after identification.Conduct Inspections as specified in Permit Term 5.14.1.5.8.2VOC40 CFR 60.692-2(11/23/88), 60.692-5(10/17/00), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NWCAA OAC #689for Calciner Hearths 1& 2.(4/13/99)NSPS Subpart QQQ - Individual JunctionBoxesEach affected individual junction box shall beequipped with a sealed cover, may have anopen vent pipe or may be routed to a closedvent system with a control device such as acarbon canister with no detectableemissions.Conduct Inspections as specified in Permit Term 5.14.2.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-37Table 5.8 - Specifically Applicable Requirements for the Calciner AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.8.3SO2(H2S)40 CFR 60.104(a)(1),60.105(a)(4),60.105(e)(3)(ii) and60.106(e)(1)(10/17/00)NSPS Subpart J – Fuel GasSupplemental fuel gas combusted in any ofthe Calciner hearths shall be limited to acomposition of H2S<230 mg/dscm (0.10gr/dscf). Equivalent t 162 ppm H2S, 3 hourrolling average.Operate CEM for H2S concentration at the fuel feed line in accordance withNWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60 Subpart Jand 40 CFR 60 Appendices B and F.Periods of excess emissions thatshall be determined and reported aredefined as follows. All rolling 3-hour periods during which the averageconcentration of H2S as measured by the H2S continuous monitoringsystem under §60.105(a)(4) exceeds 162 ppmv.Report average H2S content (3 hour rolling average) in monthly reporting.Follow 40 CFR 60 Appendix A Method 11 or 155.8.4VOC40 CFR 60.590-60.593 (10/17/00)which references 40CFR 60.480-60.489(12/14/00)NWCAA OAC #689for Calciner Hearths 1& 2 (4/13/99)NSPS Subpart GGG - Equipment LeaksMonitor applicable components for fugitiveleaks, repair leaks in a timely manner, andreport monitoring results semi-annually inaccordance with 40 CFR 60 Subpart VV.Applicable components include: pumps inliquid service, pressure relief valves ingas/liquid service, all sampling connectionsystems, all open-ended valves or lines, allvalves in gas/vapor service or light liquidservice, all pumps and valves in heavy liquidservice, pressure relief valves in light liquidservice, flanges and other connectors.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-38Table 5.8 - Specifically Applicable Requirements for the Calciner AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingHearths 1 & 2 (Calciner Stack #1)5.8.5OpacityNWCAA OAC #660Condition 4(12/7/98)NWCAA OAC #689Conditions 1.2.5,2.2.5 & 3.2.5(4/13/99)Opacity shall not exceed 20% for any 6minute period in any one hour.Conduct opacity observations in accordance with Section 6.1 exceptfrequency of opacity observations is tobe on a monthly basis as requiredby OAC #689.Use WDOE Method 9A and 9B5.8.6PM/PM10NWCAA OAC #689Condition 1.2.3 &2.2.3 (4/13/99)Maximum emissions rate of 34 tpy.Track operating parameters specified inapproved monitoring plan.Report annual particulate emissions for year.Monitor secondary voltageand secondary currenton WESPs. Providemonthly report that shows at least two WESPs in operation at all times witha secondary voltage greater than 35KV DC and a secondary currentgreater than 300 milliamps DC. These conditions originate from theWDOE/NWCAA Approved Monitoring Plan (10/7/99).Follow 40 CFR 60 Appendix A Method 55.8.7SO2NWCAA OAC #689Conditions 1.2.2, 2.2.2,& 3.2.2(4/13/99)NWCAA OAC #660Condition 3 & 6(12/7/98)Emissions shall not exceed 175 tpy on a 12-month rolling average. Concentration shall notexceed 35 ppmvd corrected to 7% O2on adaily average.Operate CEM for SO2concentration at Calciner Stack #1 following NWCAA367 and Appendix A - “Ambient Monitoring, Emission Testing, andContinuous Emission and Opacity Monitoring” (8/15/05), 40 CFR 60Appendices B and F.Provide maximum daily average SO2concentration in ppmv corrected to 7%O2in monthly report. In addition, include any excursions over 35ppmv (dailyaverage) along with monthly average of coke production, and 12-monthrolling average of SO2in tons per year. Report annual emission of SO2intons per year.Follow EPA Method 8BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-39Table 5.8 - Specifically Applicable Requirements for the Calciner AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.8.8NOxNWCAA OAC #689Conditions 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 notexceed 325 ppmvd corrected to 7% O2on adaily average.Operate CEM for NOx concentration atCalciner Stack #1 following NWCAA367 and Appendix A - “Ambient Monitoring, Emission Testing, andContinuous Emission and Opacity Monitoring” (8/15/05), 40 CFR 60Appendices B and F.Provide maximum daily average concentration of NOx in ppmv corrected to7% O2in monthly report. Also include annual NOx emissions (12-monthrolling average).Follow EPA Method 7 or 7A5.8.9H2SO4NWCAA OAC #660Condition 1(12/7/98)Emissions shall not exceed 15 lbs/hr on a dailyaverage basis.Track operating parameters specified inapproved monitoring plan.Operate emissions control equipment and monitor emissions and/or controlparameters in accordance with monitoring plan approved by NWCAA.Submit a monitoring plan for approval by NWCAA that provides operatinginstructions and control parameters for emission control equipment. Submita new monitoring plan each time control equipment is modified or replaced.Compliance with this limit shall be determined by an annual source testusing 40 CFR 60 Appendix A Method 8.5.8.10H2SO4NWCAA OAC #689Conditions 1.2.4 and2.2.4(4/13/99)Emissions shall not exceed 39 tpy on a 12-month rolling average. Concentration shall notexceed 14 ppmvd corrected to 7% O2on adaily average.Report annual H2SO4emissions for year.Follow EPA Method 8Hearth #3 (Calciner Stack #2)5.8.11OpacityPSD 89-2Condition 2(g)(1/30/89)Opacity shall not exceed 20%. Report opacity readings greater than 20% when they occur. Monitoropacity in accordance with Section 6.1Follow 40 CFR 60 Appendix A Method 95.8.12PM/PM10PSD 89-2Condition 2 (b) & (d)(1/30/89)Emissions shall not exceed 0.01 gr/dscfcorrected to 7% O2on any 60 consecutiveminutes and 26 tpy.Initial performance test required. Report annual emission of particulates intons per year.Follow 40 CFR 60 Appendix A Method 5BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-40Table 5.8 - Specifically Applicable Requirements for the Calciner AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.8.13SO2PSD 89-2Condition 2 (a) & (c)(1/30/89)Emissions shall not exceed 160 ppmvdcorrected to 7% O2based on a calendar dayaverage and 504 tpy.Operate CEM for SO2concentration at Calciner Stack #2 in accordancewith NWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60Appendices B and F.Provide daily average SO2concentration in ppmvd corrected to 7% O2inmonthly report.Include any excursions over 160 ppmvd (daily average) in monthly report.Report annual emission of SO2in tons per year.-directly enforceable5.8.14SO2PSD 89-2Condition 2 (f)(1/30/89)SO2scrubber efficiency shall be no less than90%.Perform an annual source test of scrubber inlet and scrubber outlet toquantify SO2concentrations and calculate removal efficiency using 40 CFR60 Appendix A Method 8.-directly enforceable5.8.15NOxPSD 89-2Condition 2 (e)(1/30/89)Emissions shall not exceed 509 tpy.Operate CEM for NOx concentration atCalciner Stack #2 in accordancewith NWCAA 367 and Appendix A - (7/14/05), 40 CFR 60 Appendices Band FReport emissions of NOx in tons per year in annual report.Follow 40 CFR 60 Appendix A Method 7EBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-41Table 5.8 - Specifically Applicable Requirements for the Calciner AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.8.16H2SO4PSD 95-01Conditions I, III, & V.(3/15/95)NWCAA RO.#018(6/30/98)Emissions shall not exceed 18.3 lb/hr or 50mg/m3on a 24-hour average.Track operating parameters specified inapproved monitoring plan.Monitor secondary voltage and secondarycurrent on WESP’s. Provide monthly reportthat shows at least four WESP’s in operationat all times with a secondary voltage greaterthan 40KV DC and a secondary currentgreater than 50 milliamps DC on the oldcells, and 35KV DC and 300 milliamps DC onthe new cell.Note: this text will need revising prior to theAOP going final in 2006 based on the newplan that should be approved by thenPerform an annual source test using EPA Method 8. Submit an emissionstesting plan 30 days prior to performing the test. Conduct emissionstesting in accordance with an approved test plan.Follow the conditions for demonstrating compliance in accordance with thecurrent WDOE/NWCAA Approved Calciner Hearth #3 Wet ElectrostaticPrecipitator (#2 WESP) Monitoring Plan.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-42Table 5.8 - Specifically Applicable Requirements for the Calciner AreaPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingCoke Handling – Silos, Baghouses, and Transfer Systems5.8.17OpacityNWCAA LetterConditions 2, 3 & 4(12/19/88)Coke Loadout FacilityOpacity from the baghouse stacks for the railloading equipment shall not exceed 10%. Allother points shall not exceed zero (0) percentopacity.Emissions from the two baghouses shall beless than 0.02 gr/dscfFollow the visual emissions monitoring methods and frequencies forcombustion units burning gaseous fuels found in Section 6.1- directly enforceable -5.8.18PMPSD 89-2Condition 3(1/30/89)Emissions of particulatematter from the newsilo, the rail car load out and the new hearthtransfer tower shall not exceed 0.01 g/dscf,21 tons per year and 20 % opacity.Report emissions of particulates in tons per year in annual report.Follow the visual emissions monitoring methods and frequencies forcombustion units burning gaseous fuels found in Section 6.1- directly enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-425.9 Light Ends (LEU)/LPG UnitTable 5.9 - Specifically Applicable Requirements for the Light Ends (LEU)/LPG UnitPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire LEU/LPG AreaComponents in VOC ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.9.1VOC40 CFR 60.692-2(11/23/88), 60.692-5(10/17/00), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Subpart QQQ - Individual Junction BoxesEach affected individual junction box shall beequipped with a sealed cover, may have anopen vent pipe or may be routed to a closedvent system with a control device such as acarbon canister with no detectable emissions.Conduct Inspections as specified in Permit Term 5.14.2.5.9.2VOC40 CFR 60.590-60.593 (10/17/00)which references 40CFR 60.480-60.489(12/14/00)NWCAA OAC #298(12/4/90)NSPS Subpart GGG - Equipment LeaksMonitor applicable components for fugitiveleaks, repair leaks in a timely manner, andreport monitoring results semi-annually inaccordance with 40 CFR 60 Subpart VV.Applicable components include: pumps in liquidservice, pressure relief valves in gas/liquidservice, all sampling connection systems, allopen-ended valves or lines, all valves ingas/vapor service or light liquid service, allpumps and valves in heavy liquid service,pressure relief valves in light liquid service,flanges and other connectors.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-43Table 5.9 - Specifically Applicable Requirements for the Light Ends (LEU)/LPG UnitPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingAffected Process Vent 16-V-012Note: The Title 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities.5.9.3VOC40 CFR 63.643(a)(1)(6/18/95)Refinery MACT - Process VentsControl VOC emissions from applicable ventsby using a flare for Group I process vents.Follow monitoring, recordkeeping and reporting requirements for flares inPermit Terms 5.12.1 through 5.12.10(Flare used as control device)40 CFR 60 Appendix A Method 18LPG Compressor 22-1801Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.9.4VOC40 CFR 60.482-3(b)(1)NSPS Subpart VV - CompressorsEach compressor shall be installed with a sealsystem that includes a barrier fluid system thatprevents the leakage of VOCs.Operate seal system with a barrier fluid at a pressure that is greater thanthe compressor stuffing box pressure.Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-445.10 Isomerization UnitTable 5.9 - Specifically Applicable Requirements for the Isomerization UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingEntire Isomerization UnitComponents in HAP ServiceNote: The 40 CFR 60 General Provisions in Section 3 apply to these affected facilities.5.10.1HAP40 CFR 63.648(a)and (b) (8/18/98)which references 40CFR 60.480-60.489(12/14/00)Refinery MACT - Equipment LeaksMonitor applicable components for fugitiveleaks, repair leaks in a timely manner andreport monitoring results semi-annually inaccordance with 40 CFR 60 Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2.5.10.2HAPNWCAA OAC#814a Condition 5(5/24/04)Project components shall be subject toapplicable portions of 40 CFR 60 SubpartGGG and 40 CFR 63 Subpart CC.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-45Table 5.9 - Specifically Applicable Requirements for the Isomerization UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingComponents in VOC ServiceNote: The 40 CFR 60 General Provisions in Section 3 apply to these affected facilities.5.10.3VOC40 CFR 60.692-2(11/23/88) 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Subpart QQQ - Individual DrainSystemsEach applicable individual drain systemshall be equipped with a water seal and/orcaps and plugs so that VOC emissions arenot vented to the atmosphere.Except where repair is technicallyimpossible without a unit shutdown, whena broken seal, gap, crack or other problemis identified, first efforts at repair shall bemade as soon as practicable, but not laterthan 15 calendar days after identification.Conduct Inspections as specified in Permit Term 5.14.1.5.10.4VOC40 CFR 60.692-2(11/23/88), 60.692-5(10/17/00), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Subpart QQQ - Individual JunctionBoxesEach affected individual junction box shallbe equipped with a sealed cover, mayhave an open vent pipe or may be routedto a closed vent system with a controldevice such as a carbon canister with nodetectable emissions.Conduct Inspections as specified in Permit Term 5.14.2.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-46Table 5.9 - Specifically Applicable Requirements for the Isomerization UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.10.5VOCNWCAA OAC#814a Condition 6(5/24/04)Leak Detection and Repair•Leak detection and repair shall occurnot less frequently than quarterly•The following leak definitions shall be ineffect:o500 ppm for block valves andcontrol valveso2,000 ppm for pumps•Facility shall record, track, repair and remonitor all leaks greater that thedefinitions above,but will have 30 daysto make repairs and re-monitor leaksgreater than the definitions above butless than the applicable regulatory leakdefinition.Follow procedures for an Enhanced Equipment Leak program as specified inSection 6.3a.Isomerization Process Heater (IHT Heater)Note: The 40 CFR 60 General Provisions in Section 3 apply to these affected facilities.5.10.6H2S(SO2)NWCAA OAC#814a Condition 1(5/24/04)PSD 02-04Amendment 1Condition 1(4/20/05)The IHT Heater shall combust only one ora combination of the following fuels:pipeline grade natural gas and/or refineryfuel gas.Maintain records showing that only allowed fuels were combusted in the heater.-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-47Table 5.9 - Specifically Applicable Requirements for the Isomerization UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.10.7SO2NWCAA OAC#814aCondition 3(5/24/04)The H2S content of fuel gas combusted inthe heater shall not exceed 162 ppmbased on a 3-hour rolling average and 50ppm based on a 24-hour rolling average.Install and operate CEM to measure H2S concentration in the fuel gas to the heater.The monitor shall meet the appropriate requirements of 40 CFR 60 Subpart J, 40CFR 60 Appendices B and F, NWCAA367 and NWCAA Appendix A - (7/14/05).Periods of excess emissions that shallbe determined and reported are defined asfollows: (1) all rolling 3-hour periods during which the average concentration of H2Sas measured by the CEM exceeds 162 ppmv and (2) all rolling 24-hour periodsduring which the average concentration of H2S as measured by the CEM exceeds50 ppmv.-directly enforceable5.10.8NOxPSD 02-04Amendment 1Conditions 2 and 7(4/20/05)The IHT Heater shall not exceed 0.10lb/MMBtu when averaged over a calendarday and 0.455 lbs/hr NOx when averagedover a calendar day.Testing of the heater shall be performedwhen heater is operating at a minimum of90% of maximum load.Compliance shall be monitored by annual source testing using 40 CFR 60 AppendixA Method7E. Submit test plan at least 30days before source testing and providenotification of test date at least two weeks in advance each test.Submit monthly report and include: monthly maximum of NOx emissions, days forwhich data were not collected, reasons formissing data and statement that no fuelsother than those allowed in Permit Term5.10.6 were used; and required informationfor each occurrence of excess emissions.Maintain records onsite for five years.5.10.9COPSD 02-04Amendment 1Condition 4 and 7(4/20/05)Emissions of CO from the IHT Heater shallnot exceed 70 ppmvd at 7% O2whenaveraged a calendar day or 1.1 lbs/hrwhen averaged over a calendar day.Testing of the heater shall be performedwhen heater is operating at a minimum of90% of maximum load.Compliance shall be monitored by annual source testing using 40 CFR 60 AppendixA Method 10, 10A or 10B. Submit test planat least 30 days before source testingand provide notification of the test date atleast two weeks in advance of each test.Submit monthly report and include: monthly maximum of CO emissions, days forwhich data were not collected, reasons formissing data and statement that no fuelsother than those allowed in Permit Term5.10.6 were used; and required informationfor each occurrence of excess emissions.Maintain records onsite for five yearsBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-48Table 5.9 - Specifically Applicable Requirements for the Isomerization UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.10.10CO40 CFR 63.7,63.7500(a),63.7515(e),63.7520(a), (b) and(f) and 63.7560(9/13/04)NESHAPS Subpart DDDDD - ProcessHeatersCO emissions shall not exceed 400 ppmvdcorrected to 3% O2(3-run average).Testing shall be conducted at maximumnormal operating load and consist of three1-hour runs.Conduct annual performance testing between 10 and 12 months after thepreceding test using 40 CFR 60 Appendix A Method 10.Provide results within 60 days after completion of source test. Keep records for fiveyears.5.10.11General(SSM Plan)40 CFR 63.6(e)(3),63.10(b),63.10(d)(5) and63.7560(9/13/04)NESHAPS Subpart DDDDD - ProcessHeatersDevelop and implement a written startup,shutdown and malfunction (SSM) plan thatdetails procedures for operating andmaintaining the source during periods ofstartup, shutdown and malfunction. Theplan shall be adopted prior to initial startupof the heater.Maintain current SSM Plan on site.If any action taken during a startup, shutdownor malfunction event is not consistentwith the SSM Plan, report any deviation for that event within two working days toNWCAA.Keep records of any startup, shutdown oroccurrence of malfunction includingrequired maintenance performed on air pollution control and monitoring equipment.Maintain records for five years of which at least two years must be onsite.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-49Table 5.9 - Specifically Applicable Requirements for the Isomerization UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.10.12General40 CFR 63.7550(c)(9/13/04)NESHAPS Subpart DDDDD - ProcessHeatersSubmit semi-annual compliance reportidentifying source; deviations fromemission limits, operating limits or workpractice standards; monthly fuel use; andsummary of annual performance testresults.Submit semi-annual compliance report as indicated:•July 31 for the period January 1 through June 30•January 31 for the period July 1 through December 315.10.13PM10&VOCPSD 02-04Amendment 1Condition 9(4/20/05)Facility shall identify “good combustionpractices” for this heater. Theseoperational practices and parameters shallbe included in the O&M manual for thefacility.Provide O&M manual within 90 days of startup of the heater.O&M manualshall be maintained, followed and be available onsite for review.5.10.14OpacityNWCAA OAC#814a Conditions 2and 7(5/24/04)Visible emissions shall not exceed 5%opacity for more than six minutes in anyhour.Monitor opacity in accordance with Section 6.1.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-505.11 Cooling Towersand Utility BoilersTable 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility BoilersPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire Cooling Tower and Utility Boiler AreasComponents in VOC ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.11.1VOC40 CFR 60.692-2(11/23/88), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NWCAA OAC #640Condition 1 (5/1/98)NSPS Subpart QQQ - Individual Drain SystemsEach affected individual drain system shall beequipped with a water seal and/or caps and plugsso that VOC emissions are not vented to theatmosphere.Except where repair is technically impossiblewithout a unit shutdown, when a broken seal,gap, crack or other problem is identified, firstefforts at repair shall be made as soon aspracticable, but not later than 15 calendar daysafter identification.Conduct Inspections as specified in Permit Term 5.14.1.5.11.2VOC40 CFR 60.692-2(11/23/88), 60.692-5(10/17/00), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Subpart QQQ - Individual Junction BoxesEach affected individual junction box shall beequipped with a sealed cover, may have an openvent pipe or may be routed to a closed ventsystem with a control device such as a carboncanister with no detectable emissions.Conduct Inspections as specified in Permit Term 5.14.2.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-51Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility BoilersPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.11.3VOC40 CFR 60.590-60.593 (10/17/00)which references 40CFR 60.480-60.489(12/14/00)NSPS Subpart GGG - Equipment LeaksMonitor applicable components for fugitive leaks,repair leaks in a timely manner, and reportmonitoring results semi-annually in accordancewith 40 CFR 60 Subpart VV.Applicable components include: pumps in liquidservice, pressure relief valves in gas/liquidservice, all sampling connection systems, allopen-ended valves or lines, all valves ingas/vapor service or light liquid service, all pumpsand valves in heavy liquid service, pressure reliefvalves in light liquid service, flanges and otherconnectors.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2No. 2 South Cooling Tower5.11.4VOCNWCAA OAC (8/23/90)Install and operate a hydrocarbon monitor inaccordance with manufacturer’s specifications perrequirements set forth in un-numbered OAC datedAugust 23, 1990.Provide maintenance and calibration of LEL (Lower Explosive Limit)monitor in accordance with manufacturer’s recommendations.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-52Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility BoilersPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingUtility Boilers #1 and #35.11.5SO2(H2S)NWCAA RO #28(5/15/02) whichreferences40 CFR 60.104(a)(1),60.105(a)(4),60.105(e)(3)(ii) and60.106(e)(1)(10/17/00)NSPS Subpart J – Fuel GasFuel gas limited to a composition of H2S<230mg/dscm (0.10 gr/dscf).Equivalent t 162 ppm H2S,3 hour rolling average.Operate CEM for H2S concentration at the fuel feed line in accordancewith NWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60Subpart J and 40 CFR 60 Appendices B and F.Periods of excess emissions thatshall be determined and reported aredefined as follows. All rolling 3-hour periods during which the averageconcentration of H2S as measured by the H2S continuous monitoringsystem under §60.105(a)(4) exceeds 162 ppmv.Report average H2S content (3 hour rolling average) in monthly reporting.Follow 40 CFR 60 Appendix A Method 11 or 155.11.6H2SNWCAA OAC #298Condition 4(12/4/90)Plant fuel gas at Boilers 1 and 3 shall be limited toa H2S concentration of 165 ppm.Operate CEM for H2S concentration at the refinery mix drum inaccordance NWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60Subpart J and 40 CFR 60 Appendices B and F.Report average H2S content (3 hour rolling average) in monthly reporting.Follow 40 CFR 60 Appendix A Method 11 or 15-directly enforceableUtility Boiler #4Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities5.11.7OpacityNWCAA OAC #351dCondition 2(6/28/02)Opacity shall not exceed 5% for more than 6minutes in any one hour periodReport visible emissions when they occur. Monitor opacity in accordancewith Section 6.1.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-53Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility BoilersPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.11.8NOxNWCAA OAC #351dConditions 3, 4, 5 & 9(6/28/02)Emissions shall not exceed 0.07 lb/MMBtu and amonthly average of 66 tons per year.5.11.9NOx40 CFR 60.44b,60.48b and 60.49b(g)(8/14/01)NSPS Subpart Db – Industrial BoilersEmissions shall not exceed 0.20 lbs NOx perMMBtu (based on burning fuel gas and high heatrelease rate).Operate CEM for NOx concentration atthe boiler #4 stack in accordancewith NWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60Subpart Db and 40 CFR 60 Appendices B and F.Report maximum 30-day rolling average and estimated tons per monthon monthly reporting.Report quarterly performance including average hourly NOx emissionrates (lb/MMBtu); 30-day average NOx emission rate (lb/MMBtu) at theend of each steam unit generating operating day from measured NOxemission rates for the preceding30 steam generating unit operatingdays; average NOx emission rate (lb/MMBtu) for each partial day ofoperation; daily CEM drift test data;RATA accuracy assessment; days inwhich the 30 day average NOx emission rate exceeded the emissionstandards specified in 60.44b including reasons; days during whichpollutant data was not obtained including reasons; times when emissiondata was excluded from the calculation of the average emission rateincluding reasons; “F” factor used forcalculations; method of calculation;type of fuel combusted; times when NOx concentration exceeded spanof CEM; description of modifications to CEM.Follow 40 CFR 60 Appendix A Method 7E5.11.10GeneralNWCAA OAC #351dCondition 6(6/28/02)Operation & MaintenanceDevelop and maintain an Operation &Maintenance manual for all equipment that mayaffect pollution emissions to the atmosphere.Follow O&M manual as developed. O&M manuals must be madeavailable for NWCAA inspection.Excess emissions resulting from afailure to follow the O&M procedures may be considered a proof that theequipment was not properly operated and/or maintained.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-54Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility BoilersPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.11.11SO2(H2S)40 CFR 60.104(a)(1),60.105(a)(4),60.105(e)(3)(ii) and60.106(e)(1)(10/17/00)NWCAA OAC #351Rev 3Condition 4(10/19/99)NSPS Subpart J – Fuel GasBoiler may only burn pipeline grade natural gasor refinery fuel gas limited to a composition ofH2S<230 mg/dscm (0.10 gr/dscf). Equivalent to162 ppm H2S, 3 hour rolling average.Operate CEM for H2S concentration at the refinery mix drum inaccordance NWCAA 367 and NWCAAAppendix A - (7/14/05), 40 CFR60 Subpart J and 40 CFR 60 Appendices B and F.Periods of excess emissions thatshall be determined and reported aredefined as follows. All rolling 3-hour periods during which the averageconcentration of H2S as measured by the H2S continuous monitoringsystem under §60.105(a)(4) exceeds 162 ppmv.Report average H2S content (3 hour rolling average) in monthlyreporting.Follow 40 CFR 60 Appendix A Method 11 or 15Utility Boiler #5Note: The Title 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities5.11.12SO2NWCAA OAC #814Condition 1(4/24/04)PSD 02-04Amendment 1Condition 1(4/20/05)Boiler #5 shall combust only one or a combinationof the following fuels: pipeline grade natural gasand/or refinery fuel gas.Maintain records showing that only allowed fuels were combusted in theboiler.5.11.13SO240 CFR 60.40b(c)(10/17/00) whichreferences 40 CFR60.104NSPS Subpart Db - Industrial BoilersAffected facilities that meet the applicabilityrequirements of Subpart J are subject to the sulfurdioxide standards under Subpart J.Meet requirements of Permit Term 5.11.11 to provide compliance withSubpart Db sulfur dioxide standards.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-55Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility BoilersPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.11.14SO2NWCAA OAC #814aCondition 3(4/24/04)Fuel combusted in Boiler #5 shall not exceed 162ppm H2S based on a 3-hour rolling average or 50ppm H2S based on a 24-hour rolling average. TheH2S content of fuel gas combusted shall becontinuously monitored in accordance with 40 CFR60 Subpart J, Subpart A and Appendix F.Operate CEM for H2S concentration at the fuel feed line in accordancewith NWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60Subpart J, Subpart A and 40 CFR 60 Appendices B and F.Report average H2S content (3-hour rolling average and 24-hour rollingaverage) in monthly report.-directly enforceable5.11.15NOxPSD 02-04Amendment 1Conditions 3 and 7(4/20/05)NOx emissions from Boiler #5 shall not exceed 10.1lbs/hr on a calendar day average.Continuous compliance for NOx and O2shall be monitored by a CEM inaccordance with NWCAA 367 and NWCAA Appendix A – (7/14/05), 40CFR 60 Subpart J, Subpart A and 40 CFR 60 Appendices B and F.Submit monthly report and include: (1) monthly maximum NOx emission;(2) days for which data were not collected, reasons for missing data andstatement that no fuels other than those allowed in Permit Term 5.11.12were used; and (3) required information for each occurrence of excessemissions.Maintain records onsite for five years.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-56Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility BoilersPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.11.16NOx40 CFR 60.44b(8/14/01)NSPS Subpart Db - Industrial BoilersNOx emissions from the boiler shall not exceed0.2lb/MMBTU.Operate CEM in accordance with Permit Term 5.11.15.5.11.17NOx40 CFR 60.49b(g)(7/7/04)NSPS Subpart Db - Industrial BoilersMaintain the following records for each steamgenerating day for the boiler:•Calendar date•Average hourly NOx emission ratesexpressed as NO2in lb/million Btu heat input•Thirty day rolling average NOx in lbs./millionBtu heat input•Number of days in excess of NOx standard•Number of days when pollutant data notobtained•Times when emission data not included incalculation of emission average•Identification of "F" factor used for calculations•Identification of times pollutant concentrationsexceeded span of monitoring system•Description of modifications to CEMs thatwould affect ability to comply withPerformance Specification 2 or 3.•Results of daily drift tests and quarterlyaccuracy assessments required underAppendix F, Procedure 1Monitoring, recordkeeping and reporting associated with Permit Term5.11.12 is considered an alternative reporting procedure for thisrequirement.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-57Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility BoilersPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.11.18COPSD 02-04Amendment 1Conditions 5, 6 and 7(4/20/05)CO emissions from Boiler #5 shall not exceed18.1 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 50lbs/hr averaged over the startup period;•Emissions of CO during startup shall bemonitored and included in the emissioninventory for the year;•Startup periods are limited to 12 hours,except, if refractory work has been doneduring a maintenance shutdown, the period islimited to 30 hours; and•Startups claiming use of these provisionsshall be limited to six per year.Testing of the heater shall be performed when boiler is operating at aminimum of 90% of maximum load. Submit copies of each requiredsource test performed.Continuous compliance shall be monitored by a CEM for CO and O2inaccordance withNWCAA 367 and NWCAA Appendix A - (7/14/05)and40 CFR 60 Appendices B and F.Submit monthly report and include: (1) monthly maximum CO emission;(2) days for which data were not collected, reasons for missing data andstatement that no fuels other than those allowed in Permit Term 5.11.13were used; and (3) required information for each occurrence of excessemissions.Maintain records onsite for five years.5.11.19CO40 CFR 63.7,63.7500(a),63.7505(d),63.7510(c),63.7525(a),63.7535(b) and (c),63.7555 and63.7560.(9/13/04)NESHAPS Subpart DDDDD - Industrial BoilersCO emissions shall not exceed 400 ppmvdcorrected to 3% O2(based on a 30-day rollingaverage).Compliance shall be demonstrated by installing, operating andmaintaining a CEM according to Performance Specification 4 of 40 CFR60 Appendix B and according to the site-specific monitoring plan.Data recorded during periods of monitoring malfunctions, associatedrepairs, out-of-control periods, required quality assurance and controlactivities, or when the boiler is operating at less than 50% of ratedcapacity may not be used for calculating data averages. Data collectedduring all other periods must be used to assess compliance.Maintain records for 5 years of which at least 2 years must be on-site.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-58Table 5.11 - Specifically Applicable Requirements for the Cooling Towers and Utility BoilersPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.11.20General(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 BoilersDevelop and implement a written startup, shutdownand malfunction (SSM) plan that details proceduresfor operating and maintaining the source duringperiods of startup, shutdown and malfunction. Theplan shall be adopted prior to initial startup of theheater.Maintain current SSM Plan on site.If any action taken during a startup, shutdown or malfunction event is notconsistent with the SSM Plan, reportany deviation for that event withintwo working days to NWCAA.Keep records of any startup, shutdown or occurrence of malfunctionincluding required maintenance performed on air pollution control andmonitoring equipment. Retain records for five years.5.11.21General40 CFR 7550(c)(9/13/04)NESHAPS Subpart DDDDD - Industrial BoilersSubmit semi-annual compliance report identifyingsource; deviations from emission limits, operatinglimits or work practice standards; monthly fuel use;and summary of annual performance test results.Submit semi-annual compliance report as indicated:•July 31 for the period January 1 through June 30•January 31 for the period July 1 through December 315.11.22PM10/VOCPSD 02-04Amendment 1Condition 10(4/20/05)Facility shall identify “good combustion practices”for this boiler. These operational practices andparameters shall be included in the O&M manualfor the facility.O&M manualshall be maintained and followed and be available onsite forreview.5.11.23OpacityNWCAA OAC #814aCondition 2 and 7(4/24/04)Visible emissions shall not exceed 5% opacity formore than six minutes in any hour.Monitor opacity in accordance with Section 6.1Follow40 CFR 60 Appendix A Method9BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-595.12 FlaresTable 5.12 - Specifically Applicable Requirements for the Flares AreaPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingHigh and Low Pressure FlaresNote: 40 CFR 60 and 63 General Provisions included in Section 3 apply to these affected facilities.5.12.1HAP40 CFR 63.11(b)(1) (10/17/00) and40 CFR 63.645(a) (8/18/98) whichreferences 63.116 (1/22/01)40 CFR 63.648 (8/18/98) whichreferences 40 CFR 60.482-10(12/14/00) which references60.18(d) (10/17/00)Refinery MACT - FlaresSources using flares to complywith Refinery MACT equipmentleak provisions shall monitorflares to assure they aremaintained and operated properlyto reduce the emissions oforganic HAPS from miscellaneousprocess vents by 98%w or to 20ppmv.5.12.2HAP40 CFR 63.11(b)(3) (10/17/00)40 CFR 63.648 (8/18/98) whichreferences 40 CFR 60 Subpart VVwhich includes 60.485(g)(2)(10/17/00) and 60.482) (12/14/00)and which references 60.18(10/17/00)Refinery MACT - FlaresFlares shall be operated at alltimes when emissions may bevented to them.Thermocouples, or any other equivalentdevice, to detect the presenceof a flame, shall continuously monitor each flare for the presence of aflame and the data recorded electronically in no less than 15-minuteaverages.In addition, video cameras and flow meters shall be used to assistoperators in reducing any visual emissions from flaring.Any exceedance of the applicable opacity limit or, operating a flare inthe absence of a pilot flame shall be reported to the NWCAA as anupset within 12-hours of the eventin accordance with NWCAA 340.Maintain hourly records of whether the monitor was continuouslyoperating and whether a pilot flame was continuously present.Record and report the presence of aflame at the pilot light over theperiod of compliance determination - per NCS report described in 40CFR 63.654Record the times and durations of all periods when all pilot flames for aflare are absent or the monitor is not operating.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-60Table 5.12 - Specifically Applicable Requirements for the Flares AreaPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.12.3HAP40 CFR 63.11(b)(5) (10/17/00)40 CFR 63.644(a)(2) (8/18/98) and63.648 (8/18/98) which references40 CFR 60.485(g)(2) (10/17/00)which references 60.18(c)(2)(10/17/00)Refinery MACT - FlaresFlares shall be operated with aflame present at all times.Use a thermocouple or otherequivalent device capable ofcontinuously detecting thepresence of a pilot flame.Thermocouples, or any other equivalentdevice, to detect the presenceof a flame, shall continuously monitor each flare for the presence of aflame and the data recorded electronically in no less than 15-minuteaverages.Record the times and durations of all periods when all pilot flames for aflare are absent or the monitor is not operating. Operating a flare in theabsence of a pilot flame shall be reported to the NWCAA as an upsetwithin 12-hours of the event in accordance with NWCAA 340.Maintain hourly records of whether the monitor was continuouslyoperating and whether a pilot flame was continuously present.Record and report the presence of aflame at the pilot light over theperiod of compliance determination - per NCS report described in 40CFR 63.654.5.12.4Opacity40 CFR 63.11(b)(4) (10/17/00)40 CFR 63.642(d) (6/12/96), and63.648 (8/18/98) which references40 CFR 60 Subpart VV whichincludes 60.485(g)(1) (10/17/00)and which references 60.18(c)(1)(10/17/00)Refinery MACT - FlaresFlares shall be designed for andoperated with no visibleemissions, except for periods notto exceed a total of 5 minutesduring any 2 consecutive hours.Visual opacity shall be monitored in accordance with Section 6.1In addition, video cameras and flow meters shall be used to assistoperators in reducing any visual emissions from flaring.Any exceedance of the applicable opacity limit shall be reported to theNWCAA as an upset within 12-hoursof the event in accordance withNWCAA 340.Follow 40 CFR 60 Appendix A Method 9 or 22.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-61Table 5.12 - Specifically Applicable Requirements for the Flares AreaPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.12.5SO2NWCAA 462(3/13/97)WAC 173-400-040 (6)(8/15/01)NWCAA OAC #890aCondition 8(10/5/05)SO2emissions shall not exceed1000 ppm (corrected to 7% O2)averaged over a 60 minuteperiod.Coker blowdown vapors shall be routed to and recovered by the cokerwet gas compressor #12-1801. Compliance with this condition shall bedemonstrated by:a)Continuously monitoring and recording the operating position ofremotely activated valve #HV-331 and the intake pressure of thecoker wet gas recovery compressor,b)Following written standard operatingprocedures that assure thatcoker blowdown vapors are routed to the wet gas compressor,except;•When the intake pressureto compressor #12-1801 isnear its suction pressure, or•During a process upset or when maintenance is required.c)Record each process upset or maintenance activity when cokerblowdown vapors are not recovered.Records shall include time,date, duration and description ofeach event and an estimates ofthe resulting SO2emissions that otherwise would have beenrecovered.5.12.6General40 CFR 63.644(e) (8/18/98) and63.654(g)(6)(B) (8/18/98)Refinery MACT - FlaresOperate flares consistent withrequired operating parametersand/or procedures.Thermocouples, or any other equivalent device to detect the presenceof a flame, shall continuously monitor each flare for the presence of aflame and the data recorded electronically in no less than 15-minuteaverages.Periods of excess emissions shall beidentified in the monthly report.Excess emissions are defined as an operating day when all pilot flamesof a flare are absent.5.12.7General40 CFR 63.644(a) (8/18/98),Refinery MACT - Control Devicesused for Process VentsMonitoring equipment shall beinstalled, calibrated, maintained,and operated according tomanufacturer’s specifications orother written procedures.A device capable of continuously monitoring the presence of a flame isrequired.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-62Table 5.12 - Specifically Applicable Requirements for the Flares AreaPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.12.8General40 CFR 63.11(b)(7)(iii) (10/17/00)40 CFR 63.648 (8/18/98) whichreferences 40 CFR 60 Subpart VVwhich includes 60.485(g)(3) andwhich references 60.18 (c)(4)(iii)(5/4/98)Refinery MACT – Flare ExitVelocityThe exit velocity of the flares shallnot exceed the lesser ofVmax, as determined in themethod specified in63.11(b)(7)(iii), but less than 122m/sec (400 ft/sec) are allowed.Inspect the flare flow metersannually per manufacturer’srecommendation. Keep records of all inspections.- directly enforceable -5.12.9General40 CFR 63.11(b)(6) (10/17/00)40 CFR 63.648 (8/18/98) whichreferences 40 CFR 60 Subpart VVwhich includes 60.485(g)(4)(10/17/00) and which references60.18(c)(3)(ii) (10/17/00)Refinery MACT – Flared GasHeating ValueThe net heating value of the gasbeing combusted shall be 11.2MJ/scm (300 Btu/scf) or greaterfor steam or air-assisted flares.The net heating value shall becalculated by the equation in63.11(b)(6), which is identical tothe equations in 60.18(f)(3) and60.485(g)(4)Inspect the flare flow metersannually per manufacturer’srecommendation. Keep records of all inspections.40 CFR 63.11 (b)(6)(ii) referencing40 CFR 60 Appendix A Method 18- directly enforceableBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-63Table 5.12 - Specifically Applicable Requirements for the Flares AreaPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.12.10Opacity/HAP40 CFR 63.654(e)-(h)(8/18/98)Refinery MACT – FlaresConduct reporting andrecordkeeping in accordance withthe provisions of Refinery MACT.Report exceedances/deviation on periodic reports. These includeoperation of a flare in the absence ofa pilot flame, an exceedance ofthe opacity standard and anytime that the flare does not meet thegeneral control requirements of 63.11(b).Record and report in a Periodic Report each occurrence when the flaredoes not meet the general control device requirements specified in 40CFR 63.11(b) and shall include: Identification of the flare that does notmeet the general requirements specified in 40 CFR 63.11(b), andreasons why the flare did not meet these requirements.Periods that constitute a startup,shutdown, or malfunction, as thoseterms are defined in 40 CFR 63.641 and 63.2, are exempt fromreporting. Please note that the recording requirements are notexempted.Flare Gas Recovery and Associated Piping SystemsNote: 40 CFR 60 and 40 CFR 63 General Provisions includedin Section 3 apply to these affected facilities.Components in VOC Service5.12.11VOC40 CFR 60.590-60.593 (10/17/00)which references 40 CFR 60.480-60.489 (12/14/00)NSPS Subpart GGG - EquipmentLeaksMonitor applicable componentsfor fugitive leaks, repair leaks in atimely manner, and reportmonitoring results semi-annuallyin accordance with 40 CFR 60Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section6.2Applicable components include: pumps in liquid service, pressure reliefvalves in gas/liquid service, all sampling connection systems, all openended valves or lines, all valves ingas/vapor service or light liquidservice, all pumps and valves in heavy liquid service, pressure reliefvalves in light liquid service, flanges and other connectorsBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-64Table 5.12 - Specifically Applicable Requirements for the Flares AreaPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingComponents in HAP Service5.12.12HAP40 CFR 63.648(a) and (b)(8/18/98) which references 40CFR 60.480-60.489 (12/14/00)Refinery MACT - EquipmentLeaksMonitor applicable componentsfor fugitive leaks, repair leaks in atimely manner and reportmonitoring results semi-annuallyin accordance with 40 CFR 60Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section6.2Affected Process Vents 29-V-040 & 29-V-044Note: The Title 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities.5.12.13HAP40 CFR 63.643(a)(1)(6/18/95)Refinery MACT - Process VentsControl HAP emissions fromapplicable vents by using a flarefor Group I process vents.Follow monitoring, recordkeeping and reporting requirements for flaresin permit Terms 5.12.1 through 5.12.10(Flare used as control device)Follow 40 CFR 60 Appendix A Method 18BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-65Table 5.12 - Specifically Applicable Requirements for the Flares AreaPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingFlare Gas Recovery Compressors 28-1803 and 28-1804Note: The Title 40 CFR 60 General Provisions included in Section 3 applyto these affected facilities.5.12.14VOC40 CFR 60.592(a) (10/17/00)which references 40 CFR60.482-3(b)(1) (12/14/00)NSPS Subpart GGG -CompressorsIn accordance with subpart VV,each compressor shall be installedwith a seal system that includes abarrier fluid system that preventsthe leakage of VOC to theatmosphere.Each seal system shall beoperated with a barrier fluidpressure that is greater than thecompressor stuffing box pressure.Each barrier fluid system shall be equipped with a sensor that willdetect failure of the seal system, barrier fluid system, or both. Eachsensor shall be equipped with an audible alarm. A leak is detectedwhen the sensor indicates a failure or the seal system, barrier system,or both.Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-665.13 Sulfur ComplexTable 5.13 - Specifically Applicable Requirements for the Sulfur ComplexPermit TermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire Sulfur ComplexNote: The Title 40 CFR 60 and 40 CFR 63 General Provisions included in Section 3 apply.5.13.1HAP40 CFR 63.1574-63.1576 (2/9/05)Refinery MACT II - GeneralPrepare and implement an operation,maintenance and monitoring plan(OMMP) for each control system.Develop and submit an OMMP to NWCAA for review and approvalwithin 120 days of initial startup. Submit any revisions to OMMP toNWCAA for approval.Keep records to demonstrate that procedures in the plan were followed.Maintain records available for review for five years.5.13.2HAP40 CFR 63.1568(a)(1)(2/9/05) whichreferences40 CFR 60.104(a)(2)(10/17/00)Refinery MACT II – Organic HAPEmissionsMeet a SO2limit of 250 ppmvd at 0%excess air for any discharge from aClaus sulfur recovery unit.Provide continuous emission monitoringsystem to measure and recordthe hourly average concentration of SO2for each exhaust stack. Thissystem must include an oxygen monitor for correcting the data forexcess air.5.13.3HAP40 CFR 63.1569(c)(1)(2/9/05) whichreferences 40 CFR63.11(b) and Tables 36and 39 to Subpart UUU(2/9/05)Refinery MACT II – Work PracticeStandards for HAP Emissions fromBypass LinesDemonstrate continuous compliancewith the work practice standards byusing: Option 2:Car-seal or lock and key device onmechanism that prevents flow throughbypass control deviceThe facility has elected to use a car-seal or lock to ensure that bypassvalves are closed and cannot be reopened without disabling the safedevice. The car-seal or lock shall be visually inspected on a monthlybasis to ensure there is no flow in the bypass lines.Keep records of bypass line valve inspections to assure valve ismaintained in the closed position and whether flow is present in the line.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-67Table 5.13 - Specifically Applicable Requirements for the Sulfur ComplexPermit TermCitationDescriptionMonitoring/Recordkeeping/ReportingSulfur Recovery Units5.13.4SO2NWCAA OAC #890aCondition 4(10/26/05)NWCAA 367 andAppendix A(7/13/05)Total tons of SO2emitted from the SulfurRecovery Unit shall not exceed 135 tonsbased on each consecutive 12-monthrolling period.Operate and maintain CEM to measure SO2and O2in each TGU stack.Monitors shall meet the appropriate specifications of 40 CFR 60Appendices B and F, NWCAA Section 367 and NWCAA Appendix A -(7/14/05).Provide the most recent12-month rolling total in the monthly report.5.13.5SO2NWCAA OAC #890aCondition 13(10/26/05)Emissions from the elemental sulfurstorage pits shall be controlled through aclosed vent system capable of meeting250 ppmvd corrected to 0% O2based ona 12-hour rolling average and 1500ppmvd based on a 1-hour average.Operate CEM for SO2 and O2 concentration (dry basis, zero percentexcess air) at the tail gas unit stack in accordance with NWCAA 367 andNWCAA Appendix A - (7/14/05), 40 CFR 60 Subpart J and 40 CFR 60Appendices B and F.During periods when the #1 Tail Gas Incinerator is off-line formaintenance and emissions from the sulfur pits and sulfur tank is nolonger routed to the CEM on the incinerator, the following alternativemonitoring plan (AMP) shall be utilized.•Once per shift, measure and record the vented scrubber overheademissions with a colorimetric detector tube to determine H2S andSO2concentrations in the vented gas.•Once per shift, check and record the pressure drop across thenorth and south sulfur pits and the sulfur tank to ensure flowthrough the system. These pressure drops shall be continuouslymonitored with readouts available at the SRU control board.•Report total mass emissions of H2S and SO2in monthly emissionsreports during periods when this AMP is utilized.Affected Process Vents 17-V-047, 17-V-067, & 17-V-074Note: The Title 40 CFR 63 General Provisions included in Section 3 apply.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-68Table 5.13 - Specifically Applicable Requirements for the Sulfur ComplexPermit TermCitationDescriptionMonitoring/Recordkeeping/Reporting5.13.6VOC40 CFR 63.643(a)(1)(6/18/95)Refinery MACT - Process VentsControl HAP emissions from applicablevents by using a flare for Group Iprocess vents.Follow monitoring, recordkeeping and reporting requirements for flaresin permit Terms 5.11.1 through 5.11.10(Flare used as control device)Follow 40 CFR 60 Appendix A Method 18No. 1 and 2 Tail Gas Units (TGU)5.13.7SO2(H2S)40 CFR 60.104(a)(1),60.105(a)(4),60.105(e)(3)(ii) and60.106(e)(1)(10/17/00)NSPS Subpart J – Fuel GasSupplemental fuel gas combusted inthe No. 1 Tail Gas Unit shall be limitedto a composition of H2S<230 mg/dscm(0.10 gr/dscf). Equivalent t 162 ppmH2S, 3 hour rolling average.Operate CEM for H2S concentration at the fuel feed line in accordancewith NWCAA 367 and NWCAA Appendix A - (7/14/05), 40 CFR 60Subpart J and 40 CFR 60 Appendices B and F.Periods of excess emissions thatshall be determined and reported aredefined as follows. All rolling 3-hour periods during which the averageconcentration of H2S as measured by the H2S continuous monitoringsystem under §60.105(a)(4) exceeds 162 ppmv.Report average H2S content (3 hour rolling average) in monthlyreporting.Follow 40 CFR 60 Appendix A Method 11 or 155.13.8GeneralNWCAA OAC #890aCondition 1(10/26/05)Supplemental fuel gas combusted inthe No. 2 Tail Gas Unit shall be limitedto pipeline grade natural gas.Keep records of fuel usage.-directly enforceable5.13.9GeneralNWCAA OAC #890aCondition 6(10/26/05)40 CFR 63.1574(f)(2/9/05)Prepare an Operation, Maintenanceand Monitoring Plan (OMMP)according to the requirements of 40CFR 63.1574(f) and operate at alltimes according to the procedures inthe plan.Submit plan to NWCAA for review and approval within 120 days of initialstartup. Submit any revisions to OMMP to NWCAA for approval.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-69Table 5.13 - Specifically Applicable Requirements for the Sulfur ComplexPermit TermCitationDescriptionMonitoring/Recordkeeping/Reporting5.13.10GeneralNWCAA OAC #890aCondition 10(10/26/05)which references40 CFR 63 Subpart UUU§63.1569 (4/11/02)Any lines that allow a bypass of sulfurbearing compounds normally emittedfrom the No. 1 and No. 2 TGU stacksshall be monitored for the presence offlow.Report any instances of flow bypassin accordance with NWCAA Section340 or 341. These reportable events shall be considered a startup,shutdown or upset condition.5.13.11GeneralNWCAA OAC #890aCondition 9(10/25/05)The vent gas from the sour waterstripper tanks must continue to berouted upstream of the TGU incinerator.Report any instances when vent gas goes to flare system.5.13.12OpacityNWCAA OAC #890aCondition 2(10/26/05)Visual emissions from No. 1 and No. 2TGU Stacks shall not exceed 10%opacity for more than three minutes inany one hour period.Follow the visual emissions monitoring methods and frequencies forcombustion units burning gaseous fuels found in Section 6.1- directly enforceable -5.13.13SO2NWCAA OAC #890aCondition 5a(10/26/05)NWCAA 367 andAppendix A(7/13/05)SO2emissions from No. 2 TGU Stackshall not exceed 24.0 lbs/hr.Conduct initial performance test within 60 days of reaching maximumproduction rate, but no later than 180 days after startup. All testing shallbe done at or above 80% of full capacity.Follow test methods provided in 40 CFR 60 - Appendix A as follows:•SO2– Method 6C or 85.13.14NOxNWCAA OAC #890aCondition 5b(10/26/05)NWCAA 367 andAppendix A(7/13/05)NOx emissions from No. 2 TGU Stackshall not exceed 2.5 lbs/hr.•NOx – Method 7EThe source test shall be conductedin accordance with NWCAA Section367 NWCAA Appendix A - (7/14/05) .Any proposed alternative test methods shall be approved in advance bythe NWCAA.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-70Table 5.13 - Specifically Applicable Requirements for the Sulfur ComplexPermit TermCitationDescriptionMonitoring/Recordkeeping/Reporting5.13.15CONWCAA OAC #890aCondition 5c(10/26/05)NWCAA 367 andAppendix A(7/13/05)CO emissions from No. 2 TGU Stackshall not exceed 3.9 lbs/hr.Conduct initial performance test within 60 days of reaching maximumproduction rate, but no later than 180 days after startup. All testing shallbe done at or above 80% of full capacity.Follow test methods provided in 40 CFR - Appendix A as follows:•CO – 40 CFR 60 Appendix A Method 105.13.16H2SO4NWCAA OAC #890aCondition 5d(10/26/05)NWCAA 367 andAppendix A(7/14/05)H2SO4emissions from No. 2 TGUStack shall not exceed 1.23 lbs/hr.•H2SO4– 40 CFR 60 Appendix A Method 8•H2S - 40 CFR 60 Appendix A Method 15The source test shall be conductedin accordance with NWCAA Section367 and Appendix A – Ambient Monitoring, Emission Testing andContinuous Emission and Opacity Monitoring.5.13.17H2SNWCAA OAC #890aCondition 5e(10/26/05)NWCAA 367 andAppendix A(7/13/05)H2S emissions from No. 2 TGU Stackshall not exceed 0.43 lbs/hr.Any proposed alternative test methods shall be approved in advance bythe NWCAA.5.13.18SO2NWCAA OAC #890aCondition 3(10/26/05)which references40 CFR 60.104(2)(i)(10/17/00)In accordance with NSPS Subpart J,SO2emissions from the TGU stacksshall not exceed 250 ppm dry basiscorrected to 0% O2based on a 12-hourrolling average or 1500 ppm dry basiscorrected to 0% O2based on a 1-houraverage.Compliance shall be based on a CEM installed, calibrated, maintainedand operated in each TGU stack. Each monitor shall meet theappropriate specifications of 40CFR 60 Appendices B and F, NWCAASection 367 NWCAA Appendix A - (7/14/05).Report SO2emission data in monthly report.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-715.14 Wastewater Plant and Sewer SystemWastewater Plant and Sewer SystemThis part of this section presents the MR&Rs for individual drain systems togetherwith ancillary downstream sewer lines andoil-water separators, down to and including the secondary oil-water separator, forthose areas not already under regulatedunder 40 CFR 61.340 (Subpart FF). This sectioncovers the monitoring programs for individual drain systemsthat are subjectto Refinery MACT (HAP) and 40 CFR 60 Subpart QQQ standards (VOC). Refineries incompliance with 40 CFR 61 SubpartFF are considered to be in compliance with the Refinery MACT. Section 5.14 presents the MR&Rs associated withwastewater containers, tankage, and oil/water separators.Storage Tanks Handling WastewaterInternal Floating Roof Tanks – 320, 321, 322 and 323BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-72Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire Wastewater Treatment Plant, Sewer System and Storage TanksComponents in VOC Service not Group 1 Wastewater StreamsNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.14.140 CFR 60 SubpartQQQ 60.692-2(a)(11/23/88) 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Individual Drain SystemsEach applicable individual drain system shall beequipped with a water seal and/or caps andplugs so that VOC emissions are not vented tothe atmosphere.Except where repair is technically impossiblewithout a unit shutdown, when a broken seal,gap, crack or other problem is identified, firstefforts at repair shall be made as soon aspracticable, but not later than 15 calendar daysafter identification.Inactive Service Individual Drain SystemsEach applicable drain out of active service shallbe checked visually or physical inspectionweekly. Water levels will be maintained andrepairs made, when practical but no later than24 hours after detection.An alternative for inactivedrains is to installtightly sealed caps or plugs.Each active service drain shall be inspected visually or physically initiallyand monthly for indication of low water levels or other conditions thatwould reduce the effectiveness of the water seal controls.Whenever low water levels are identified water shall be added or firstefforts to repair shall be made as soon as practical but no later than 24hours after detection. A delay of repair is allowed per 40 CFR 60.692-6 ifrepair is technically impossible without a complete or partial refinery orprocess unit shutdown. If a delay of repair is utilized, the repair shall bemade before the end of the next refinery or process unit shutdown.Each inactive service drain shall be inspected visually or physically initiallyand weekly for indication of low water levels or other conditions that wouldreduce the effectiveness of the waterseal controls or problems that couldresult in VOC emissions. If a cap orplug is used an alternative for out ofservice drains, each cap and plug shall be inspected semi-annually toensure caps or plugs are in place and properly installed.For each individual drain record the location, date, and corrective actionshall be recorded for each drain when the water seal is dry or otherwisebreached per 40 CFR 60.697. Records shall be retained for at least twoyears.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-73Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.14.2VOC40 CFR 60 SubpartQQQ 60.692-2(b)(11/23/88), 60.692-5(10/17/00), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Individual Junction BoxesEach affected individual junction box shall beequipped with a sealed cover, may have anopen vent pipe or may be routed to a closedvent system with a control device such as acarbon canister with no detectable emissions.Junction box covers shall have a tight sealaround the edge and shall be kept in place at alltimes except during inspection andmaintenance.Perform semi-annual visual inspections to ensure cover is in place and atight seal is maintained around the edge.When a defect is discovered the firstattempt at repair shall be made assoon as practicable but not later than 15 days unless a delay of repair isutilized. A delay of repair is allowed per 40 CFR 60.692-6 if repair istechnically impossible without a completeor partial refinery or process unitshutdown. If a delay of repair is utilized, the repair shall be made beforethe end of the next refinery orprocess unit shutdown.Report the date and type of defects found and the date and type ofcorrective action taken on the semi-annual periodic report per 40 CFR60.697. Records shall be retained for at least two years.Components in HAP Service (Group 1 Wastewater Streams)Note: The Title 40 CFR 63 General Provisions included in Section 3 apply.5.14.3HAP40 CFR 63 SubpartCC63.648(a) and (b)(8/18/98) whichreferences 40 CFR60.480-60.489(12/14/00)Refinery MACT Equipment LeaksMonitor applicable components for fugitiveleaks, repair leaks in a timely manner and reportmonitoring results semi-annually in accordancewith 40 CFR 60 Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2.Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-74Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.14.4HAP40 CFR 63 SubpartCC 63.647(a) whichreferences 40 CFR61.346(b)(1)(1/7/93) whichreferences 40 CFR61.349 (10/17/00)which references 40CFR 61.355(h)(10/17/00)40 CFR 63.654(a)which references 40CFR 61.356 and61.357 (10/17/00).Control of Emissions from Individual DrainSystemsInstall, operate, and maintain on eachapplicable drain system opening a cover andclosed-vent system that routes all organicvapors vented from the drain system to a controldevice that meets the requirements of 40 CFR61.349.The closed vent system shall be designed tooperate with no detectable emissions asindicated by an instrument reading less that 500ppmv above background.Each cover seal, access hatch and all other openings shall be checked byvisual inspection quarterly to ensure that no cracks or gaps occurs andthat access hatches and other openings are closed and gasketed properly.When a broken seal or gasket or other problem is identified or whendetectable emissions are measured, first attempts at repair shall be madeas soon as practicable but not laterthan 5 calendar days after detection.Repairs shall be completed within 15 calendar days. A delay of repair isallowed per 40 CFR 60.692-6 if repairis technically impossible without acomplete or partial refinery or process unit shutdown. If a delay of repair isutilized, the repair shall be made before the end of the next refinery orprocess unit shutdown.Records shall be maintained at the facility for a period of five years.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-75Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.14.5HAP40 CFR 63 SubpartCC 63.647(a) whichreferences 40 CFR61.346(b) (1/7/93)which references 40CFR 61.349(a)(1)(iii)(10/17/00) whichreferences 40 CFR61.355(h)(10/17/00)40 CFR 63.654(a)which references 40CFR 61.356 and61.357 (10/17/00).Applicable Gauging and Sampling DevicesShall be gas-tight except when gauging orsampling is taking place.Design to be gas-tight. Maintain records of all gauging and samplingdevice locations and identifications.Submit a quarterly certification thatall inspections have been carried out inaccordance with 40 CFR 61 Subpart FF.Retain all records for five years.Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-76Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.14.6HAP40 CFR 63 SubpartCC 63.647(a) whichreferences 40 CFR61.346 (b)(1) and61.355(h)(10/17/00)40 CFR 63.654(a)which references 40CFR 61.356 and61.357 (10/17/00).Covers and Openings – System operated at apressure greater than atmosphericApplicable covers and openings (e.g., accesshatches, sampling ports) shall be designed tooperate with no detectable emissions of lessthan 500 ppmv above background.Each opening shall be maintained in a closed,seal position (e.g., covered and gasketed) at alltimes waste is in the drain system except whennecessary for inspection, waste sampling,maintenance and/or repair.Initial testing followed by at leastonce a year testing using 40 CFR 60Appendix A Method 21 from 40 CFR 60 Appendix A.The detection equipment shall meet the performance criteria of EP Method21 and calibrated before each use on each day of its use by theprocedures described in 40 CFR 60 Appendix A Method 21. Calibrationgases shall be:•Zero air•A mixture of methane or n-hexane and air at a concentration ofapproximately 10,000 ppm methane or n-hexane.The following monitoring procedures shall be employed:•Background levels determined using 40 CFR 60 Appendix AMethod 21,•Probe to traverse around the potential leak interfaces as close aspossible per 40 CFR 60 Appendix A Method 21,•The arithmetic difference between the maximum concentrationindicated by the instrument and the background level is comparedto the 500 ppmv compliance limit.Records for visual inspections shall include date of inspection, wastemanagement unit and control equipment, location and type of problem,and description and date of corrective action.Records for each non-detectable emission test shall include date of test,background level maximum concentration measured for each measuredleak interface, waste management unitand control, description of problem,and description and date of corrective action.Submit a quarterly certification thatall inspections have been carried out inaccordance with 40 CFR 61 Subpart FF.Retain all records for five years.Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-77Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.14.7HAP40 CFR 63 SubpartCC 63.647(a) whichreferences 40 CFR61.346 (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 40CFR 61.356(g) and61.357(d)(6)(10/17/00).Alternative for Individual DrainsAn alternative is for each applicable drain to beequipped with water seal controls or a tightlysealed cap.Each active service drain shall be inspected visually or physically initiallyand quarterly for indication of low water levels or other conditions thatwould reduce the effectiveness of the water seal controls.Each drain using a tight seal or plug shall be visually inspected initially andquarterly thereafter to ensure caps and plugs are in place and properlyinstalled.When a broken seal, gap, crack or other problem is identified, first effortsat repair shall be made as soon as practical, but not later than 15 calendardays after identification.Records for visual inspections shall include date of inspection, wastemanagement unit and control equipment, location and type of problem,and description and date of corrective action.Records for each non-detectable emission test shall include date of test,background level maximum concentration measured for each measuredleak interface, waste management unitand control, description of problem,and description and date of corrective action.Submit a quarterly certification thatall inspections have been carried out inaccordance with 40 CFR 61 Subpart FF.Retain all records for five years.Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-78Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting15.14.8HAP40 CFR 63 SubpartCC 63.647(a) (c)which references 40CFR 61.346 (b)(5)(1/7/93).40 CFR 61.356 and61.357 (10/17/00)RepairsExcept as provided in Permit Term 15.14.9, firstefforts at repair applicable equipment andcomponents shall be made as soon as practical,but not later than 15 calendar days afteridentification.Records for visual inspections shall include date of inspection, wastemanagement unit and control equipment, location and type of problem,and description and date of corrective action.Retain all records for five years.15.14.9HAP40 CFR 63 SubpartCC 63.646(a)(3) &(b)(5) (1/7/93) whichreferences 4061.350 (3/7/90).40 CFR 61.356 and61.357 (10/17/00)Delay of RepairsDelay of repair applicable equipment andcomponents and facilities subject to 40 CFR 61Subpart FF will be allowed if the repair istechnically impossible without a complete orpartial facility or unit shutdown.Repairs shall occur before the end ofthe next facility or unit shutdownwhen the repair is technically impossible without a complete or partialfacility or unit shutdown.Retain all records for five years.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-79Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingBenzene Waste Management PracticesNote: 40 CFR 61 and 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities.5.14.10HAP40 CFR Subpart CC63.647 (8/18/95), whichreferences 40 CFR61.342 (c)(3)(ii) (10/17/00)and 61.355 (j) (10/17/00).Also, 40 CFR 61 SubpartFF directlyWritten Exemption ReportThebenzene waste streams from theseindividual drain systems shall meet therequirements of 40 CFR 61 SubpartFF through written certification on anannual basis that they meet theexemption requirement.Report annually to the NWCAA that the waste streams from these individualdrain systems are part of the totalannual benzene quantity that does notexceed 2.0 Mg/yr, as per 40 CFR 61.342(c)(3)(ii).5.14.11HAP/Benzene40 CFR 63 Subpart CC63.654(a) (8/18/98) whichreferences 40 CFR61.356(e) and (i)(10/17/00)40 CFR 61 Subpart FF61.340--61.355 directly(10/17/00)Management and Treatment RecordsKeep records documenting that thebenzene waste stream is beingmanaged and treated in accordancewith its design and operatingspecificationsMaintain records for the life of the unit certifying that the treatment processor wastewater treatment system unit is designed to operate at thedocumented performance level when thewaste stream entering the unit is atthe highest waste stream flow rate and benzene content that is expected tooccur. Maintain the records of thedesign analysis, test procedures used,unit startups and shutdowns and any periods when a unit is not operating asdesigned.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-80Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.14.12HAP/Benzene40 CFR Subpart CC63.647 (8/18/95), whichreferences 40 CFR61.348(d)(4) (10/17/00)and Subpart CC 63.654(a)(8/18/98), whichreferences40 CFR 61.356(a), (e),and (I) (10/17/00).Also, Title 40 CFRSubpart FF 61.340through 61.358 appliesdirectly.Operate treatment process in amanner consistent with the minimumor maximum (as appropriate)permitted concentration or operatingparameter value.Maintain records that the treatmentprocess and subjectwaste streams aretreated by a means or to a level that isin compliance with the facility’sNational Pollutant Discharge Emission Standard (NPDES) permit and Title40 CFR 419.Maintain records for the life of the unit certifying that the treatment processor wastewater treatment system unit is designed to operate at thedocumented performance level when thewaste stream entering the unit is atthe highest waste stream flow rate and benzene content that is expected tooccur. Maintain the complete design analysis and any test information, asper 40 CFR 61.356(e).•Records shall be maintained in a readily accessible location onsitefor not less than two years.•Note: Under WAC 173-401-615(2), records must be retained for fiveyears.•Maintain documentation that includes the following information:oDate of startup and shutdown of the unit.oPeriods when the unit is not operating as designed.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-81Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingAPI Oil Water SeparatorNote: 40 CFR 61 and 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities.5.14.13HAP/Benzene40 CFR 63 Subpart CC63.647 (8/18/95) whichreferences 40 CFR61.347 (1/7/93), 61.350(3/7/90) and 61.355(h)(10/17/00)40 CFR 63 Subpart CC63.654(a) (10/17/00),which references 40 CFR61.356(d), (g) and (h)(10/17/00) and61.357(d)(6) and (d)(8)(10/17/00)40 CFR 61 Subpart FF61.340 - 61.358 directly(10/17/00)Oil Water Separators - Fixed RoofWith the exception of bays equippedwith floating roof covers, each oilwater separator system shall becovered and vapors routed to a controldevice. The system shall operate withno detectable emissions equal to orgreater than 500 ppm abovebackground as measured by 40 CFR60 Appendix A Method 21.Each opening is to remain closed orsealed except during waste sampling,inspection or maintenance.Except where repair is technicallyimpossible without a unit shutdown, afirst attempt at repair shall be made assoon as practicable, but not later than15 calendar days after identifying aproblem with a seal or gasket or whena leak is detected using 40 CFR 60Appendix A Method 21. When repair isdelayed for a shutdown, repair shall bemade before end of the next unitshutdown.Perform quarterly visual inspections of each cover seal, access hatch, andall other openings to ensure there are no cracks or gaps and that openingsare properly closed and gasketed. If defects are found they shall be repairedas soon as practical and in no case later than within 15 days of discoveryunless repair requires a unit shutdown.Submit quarterly reports to theNWCAA certifying that required inspections have been completed.Annually, monitor for leaks using 40 CFR 60 Appendix A Method 21.Instrument calibration gases shall be zero air (<10 ppm HC) andapproximately 10,000 ppm methane or n-hexane. Submit an annual reportthat includes results of inspectionsand leak tests which indicates a 500 ppmleak above background or where or a problem such as a broken seal, gap,or other problem occurred. The report shall include a description of actiontaken to correct each problem and the date the action was complete.Maintain records of all leak testing and inspections performed. Maintainengineering design documentation for the life of the control equipment.Maintain records for each visual inspection that identifies a problem thatcould result in benzene emissions.Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-82Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingAPI Oil Water Separator Effluent Sump - Floating RoofNote: 40 CFR 60, 40 CFR 61 and 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities.5.14.14HAP/Benzene40 CFR 63 Subpart CC63.647 (8/18/95) whichreferences 40 CFR61.356(l) (10/17/00),61.357(g) (10/17/00) and61.352 (1/7/93) whichreferences 40 CFR60.693-2(a) (8/18/95),60.692-6 (8/18/95), and60.696(d) (8/18/95)40 CFR Subpart QQQ60.693-2(c)40 CFR Subpart FF61.350Oil Water Separators - Floating RoofThe floating roof shall have primaryand secondary seals. Primary sealgaps shall not to exceed 1.5 inches atany one point or 3.2 square inches perfoot of total gap area. Secondary sealgaps shall not exceed 0.5 inches atany one point or 0.32 square inchesper foot of total gap area.Access doors and other openings shallbe proper gasketing and sealing.Emergency roof drain fabric shallcover 90% of the drain area.Defects in gaps or seals shall berepaired within 30 days of discovery(Delay of repair offacilities subject to40 CFR Subpart FF 61.350 areallowed if the facilities cannot berepaired without a complete or partialshutdown of the facility. Repairs mustbe made before the end of the nextfacility shutdown.)Measure the secondary seal gaps annually and measure the primary sealgaps at least once every five years.Gaps shall be measured using various sized probes at all points where a1/8” diameter probe passes freely between the roof seal and separator wall.Gap areas shall be calculated by addingthe gap surface area of each gaplocation for the primary seal and the secondary seal individually and dividingthe sum for each seal by the nominal perimeter of the separator basin.Conduct quarterly visual inspections ofaccess doors, emergency roof drainsand other openings.Defects in gaps, hatch covers, gaskets, seals or other openings shall berepaired within 30 days of discovery unless repair is technically impossiblewithout a complete or partial refineryor process unit shutdown. If a delay ofrepair is utilized, repair shall be made before the end of the next refinery orprocess unit shutdown.Maintain records of visual inspections and gap testing that include the dateof inspection and/or gap measurement and the result. If repairs are made,the records shall include the date of the repair and repair method used.Submit quarterly reports that identify all seal gap measurements that arefound to exceed the prescribed limits.Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-83Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingClosed Vent SystemsNote: 40 CFR 61 and 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities.5.14.15HAP/Benzene40 CFR 63 Subpart CC63.647 (8/18/95) whichreferences 40 CFR61.349 (10/17/00),61.354(f) (10/17/00),61.355(h) (10/17/00) and61.350 (3/7/90)40 CFR 63 Subpart CC63.654(a) (8/18/98) whichreferences 40 CFR61.356(f)(1), (g), and (h)(10/17/00), and61.357(d)(6) and (d)(8)(10/17/00)40 CFR Subpart FF61.340 - 61.358Closed Vent SystemsDesign the system to operate with nodetectable emissions. If a bypass ventis used it shall be closed and securedduring normal operations andinspected monthly. Inspect quarterlyand monitor for leaks annually.First attempt at repair shall be madeas soon as practical but in no caselater than 5 days after detection.Repair shall be completed within 15days, unless a delay of repair isrequired by a unit shutdown.Visually inspect quarterly, or monthly,if bypass vents are used. Instrumentmonitor for leaks annually using 40 CFR 60 Appendix A Method 21 and aleak definition of 500 ppm above background. Instrument calibration gasesshall be zero air (<10 ppm HC) and approximately 10,000 ppm methane orn-hexane.Keep records on the location and date of defects found during inspectionsand/or leaks found during instrumentmonitoring. Records shall include thedate and description of corrective action taken. Maintain for the life of theequipment, certification that the systemwas designed for operations at thehighest estimated load rates.Submit quarterly certifications that required inspections were completed.Submit annual reports summarizing the results of visual inspections andinstrument monitoring.Follow 40 CFR 60 Appendix A Method 21-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-84Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingCarbon Adsorption Control DevicesNote: 40 CFR 61 and 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities.5.14.16HAP/Benzene40 CFR Subpart CC63.647 (8/18/95), whichreferences 40 CFR61.349(a)(2)(ii) and (c)(1)and (h) (10/17/00) and61.354(d) (10/17/00).Also, Subpart CC63.654(a) (8/18/98),which references 40 CFR61.356(a), (f)(2), and (j)(10/17/00)Also, Title 40 CFRSubpart FF 61.340through 61.358 appliesdirectlyCarbon Adsorption Control DevicesCarbon adsorption system shallcontrol organic emissions with at least95% by weight efficiency or controlbenzene emissions with at least 98%by weight efficiency.Operate the control device at all timesexcept during maintenance or repair ofthe waste management unit.Maintain a design analysis for thecontrol device and define a carbonreplacement interval based on thetotal carbon working capacity of thecontrol device andsource operatingschedule.Monitor the organic compound concentration level in the exhaust either on adaily basis or at intervals no greater than 20% of the design carbonreplacement interval, whichever is greater. Replace the carbon with freshcarbon when breakthrough (concentration of 500 ppmv above background)is indicated.Conduct quarterly visual inspect ions of the closed vent system and controldevice and make a first attempt at repair as soon practical but in no caselater than 5 calendar days after detection. Complete repair no later than 15days after emissions are detected or a visual defect is observed. A delay ofrepair can be utilized if the repair is technically impossible without a unitshutdown, however, repair must be completed by the end of the next unitshutdown.Maintain documentation that includes:•Dates of startup and shutdown ofthe closed-vent system and controldevice.•A description of the operating parameter to be monitored to ensurethat the control device will be operated in conformance with thestandards and the design specifications and an explanation of thecriteria used for selection of that parameter.•Periods when the closed-vent system and control device are notoperated as designed including all periods as the duration when anyvalve car-seal or closure mechanism is broken or the bypass linevalve position had changed.Maintain records of dates and times when the system is inspected andmonitored and when carbon beds are replaced.Submit quarterly certification to theNWCAA that the required inspectionshave been carried out.Note: Under WAC 173-401-615(2) records must be retained for five years.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-85Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingContainers (including Vacuum Trucks)Note: 40 CFR 61 General Provisions included inSection 3 apply to these affected facilities.5.14.17HAP/Benzene40 CFR 61 Subpart FF61.342(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), and61.357(d)(6) and (d)(8)(10/17/00)ContainersInstall, operate, and maintain a cover oneach container used to handle, transfer, orstore waste. The cover and all openingsshall be designed to operate with nodetectable emissions as indicated by lessthan 500 ppmv above background.Maintain each opening in a closed, sealedposition (e.g. covered by a lid that isgasketed and latched) at all times whenwaste is in the container, except whenloading, removing, sampling, or inspectingwastes. When waste is transferred bypumping, the fill pipe should besubmerged. During loading, the covershall remain in place and all openings shallbe closed and sealed, except for thoseopenings required for the submerged fillpipe, those openings required for ventingto prevent physical damage or permanentdeformation of the container or cover.Except where repair is technicallyimpossible without a complete or partialfacility or unit shutdown, if a broken seal orgasket or other problem is identified, firstefforts at repair shall be made as soon aspracticable, but not later than 15 calendardays after identification. If repair must bedelayed, the repair shall occur before theend of the next facility or unit shutdown.Annually, using 40 CFR 60 Appendix A Method 21 monitor using an OrganicVapor Analyzer. Calibration gases shall be zero air (less than 10 ppm ofhydrocarbon in air); and a mixture of methane or n-hexane and air at aconcentration of approximately 10,000 ppm methane or n-hexane. Maintainrecords for each test of no detectable emissions.Quarterly, visually inspect each cover and all openings to ensure that theyare closed and gasketed properly.Quarterly, certify to the NWCAA thatthe required inspections were carriedout.Annually, submit a report summarizing all inspections during whichdetectable emissions were measured or a problem (such as a broken seal,gap, or other problem) that could resultin benzene emissions was identified,including the repairs or corrective action taken.Maintain records for each visual inspection that identifies a problem thatcould result in benzene emissions.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-86Table 5.14-Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingInternal Floating Roof Tanks 320, 321, 322, 323 (Subject to NWCAA 560, 580 and 40 CFR CC and 40 CFR 61 Subpart FF)Note: 40 CFR 61 and 40 CFR 63 General Provisions included in Section 3 apply to this affected facility.5.14.18HAP/Benzene40 CFR 63 SubpartCC 63.647 (8/18/95),which references 40CFR 61.351 (9/10/90)40 CFR 61 SubpartFF 61.351 directlyAlternative Standards for Tanks40 CFR 61.351 allows as an alternative thattanks meet the internal floating roof requirementsof 40 CFR 60 Subpart Kb 60.112b(a)(1)Follow the monitoring, recordkeeping and reporting requirements forPermit Terms 15.14.21, 15.13.22,15.13.24, through 15.13.28.Note: 40 CFR 63 General Provisions included in Section 3 do not apply to Conditions 5.14.19, 5.14.20, and 5.14.21.5.14.19VOCNWCAA Section580.32 (12/13/89)High Vapor Pressure Volatile Organic CompoundStorage TanksThe storage tank shall meet theinternal floating roof equipment specifications andmaintenance requirements of 40 CFR 60 SubpartKb.5.14.20VOCNWCAA Section560 (4/14/93)Storage of Organic Liquids with a True VaporPressure greater than 1.5 psia and less than 11.1psiaDesign and equip the storage vessel with thefollowing vapor loss control device, properlyinstalled, in good working order and in operation:A floating roof, consisting of a pontoon type ordouble-deck type roof, resting on the surface ofthe liquid contents and equipped with a closureseal, or seals, to close the space between the roofedge and tank wall.The control equipment provided for in thisparagraph shall not be used if the gasoline orpetroleum distillate has a True Vapor Pressure of11.1 pounds per square inch or greater underactual storage conditions. All tank gauging andsampling devices shall be gas-tight except whengauging or sampling is taking place.Perform all monitoring and reporting as required in Permit Term5.14.21.Maintain records demonstrating that the stored VOL has a TVP lessthan 11.1 psia. Notify the NWCAA within 12 hours of discovering anexceedance of the 11.1 TVP limit.- directly enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-87Table 5.14-Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingInternal Floating Roof Tanks 320, 321, 322, 323 (Subject to NWCAA 560, 580 and 40 CFR CC and 40 CFR 61 Subpart FF)5.14.21VOCNWCAA Section580.33 (12/13/89)Seal ConditionAll seals are to be maintained ingood operating condition and the seal fabric shallcontain no visible holes, tears, or other openings.Annually, conduct a visual inspection of the internal floating roof andseal system through manholes and roof hatches. The inspection shalldocument any conditions where:•the floating roof is notresting on the VOL surface•there is liquid accumulated on the floating roof•a seal is detached or there are holes or tears in the seal fabricKeep a record of each inspection that includes the tank number, dateand any defects discovered.Defects shall be repaired within 45 days of discovery or the tank takenout of service. A delay of repair extension may be utilized for up to 60days with appropriate documentation justifying the delay.Submit in the Periodic Report thedate and description of any defectsfound and corrective action taken. The report shall include anydecision to use a delay of repair extension and documentation thatalternate storage capacity was unavailable that repair was completedas soon as possible.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-88Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.14.22HAP/Benzene40 CFR 63 SubpartCC 63.647 (8/18/95)which references 40CFR 61.351(9/10/90) whichreferences 40 CFR60.112b(a)(1)(i) and(ii) (10/8/97), and40 CFR 63 SubpartCC 63.654(a) and(g) (8/18/98), whichreferences 40 CFR61.356(k)(10/17/00), whichreferences 40 CFR60.115b(a)(2) and(a)(3) (12/14/00)Internal Floating Roof OperationThe internalfloating roof shall rest or float on the liquid surfaceat all times except whenit must be supported bythe leg supports during (i) the initial fill, (ii) afterthe vessel has been completely emptied, and (iii)when the vessel is completely emptied beforebeing subsequently refilled. When the floatingroof is resting on the leg supports, filling,emptying, or refilling shall be continuous and shallbe accomplished as rapidly as possible.If the internal floating roof is not resting on thesurface, or there is liquid accumulated on the roof,or the seal is detached, or there are holes or tearsin the seal fabric, repair the items or empty andremove the storage vessel from service within 45days. If a failure detected during inspectionscannot be repaired within 45 days and the vesselcannot be emptied within 45 days, a 30-dayextension may be requested. Such a requestmust document that alternate storage capacity isunavailable and specify a schedule that willassure that the control equipment will be repairedor the vessel will be emptied as soon as possibleAnnually, conduct a visual inspection of the internal floating roof andseal system through manholes and roof hatches. The inspection shalldocument any conditions where:•the floating roof is notresting on the VOL surface•there is liquid accumulated on the floating roof•a seal is detached or there are holes or tears in the seal fabricKeep a record of each inspection that includes the tank number, dateand any defects discovered.Defects shall be repaired within 45 days of discovery or the tank takenout of service. A delay of repair extension may be utilized for up to 30days with appropriate documentation justifying the delay.Submit in the Periodic Report thedate and description of any defectsfound and corrective action taken. The report shall include anydecision to use a delay of repair extension and documentation thatalternate storage capacity was unavailable that repair was completedas soon as possible.The periodic report shall be submitted no later than 60 days after theend of each 6-month period when any compliance exceptions occur.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-89Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.14.23HAP/Benzene40 CFR 63 SubpartCC 63.647 (8/18/95)which references 40CFR 61.351(9/10/90) whichreferences 40 CFR60.112b(a)(1)(i)(10/8/97),60.113b(a)(4) and(5) (8/11/89), and63.654(a)(10/17/00), whichreferences 40 CFR61.356(k)(10/17/00), whichreferences 40 CFR60.115b(a)(2)(12/14/00)Internal Roof Degassing InspectionIf, during the inspection after degassing, theinternal floating roof has defects, the primary sealor seal fabric has holes, tears, or other openings,the gaskets no longer closes off the liquidsurfaces from the atmosphere, or the slottedmembrane has more than 10% open area, repairas necessary so that none of these conditionsexist before refilling the storage vessel with VOL.Visually inspect the internal floating roof, the primary seal, the gaskets,the slotted membranes and sleeve seals (if any) each time the storagevessel is emptied and degassed, and at least every ten years.Notify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least7 days prior to refilling followed immediately by written notification.Keep records of each inspection identifying the storage vessel, theinspection date, and the observed condition of each component of thecontrol equipment (seals, internal floating roof, and fittings).If the inspection after degassing finds holes or tears in the seal or sealfabric, or defects in the internalfloating roof, or other controlequipment defects, a report shall be furnished to the NWCAA onperiodic reports. The report shall identify the storage vessel and thereason it did not meet the specifications, and list each repair made.5.14.24VOCNWCAA Section580.34 (12/13/89)OpeningsAll openings not related to safety are tobe sealed with suitable closures.Each time the vessel is emptied and degassed, and at least onceevery 10 years, conduct an internal inspection of the vessel. Ifinspection shows that the floatingroof has defects including, but notlimited to, improper gasketing or unsealed openings, repair the defectsprior to refilling.Notify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least7 days prior to refilling followed immediately by written notification.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-90Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.14.25HAP/Benzene40 CFR 63 SubpartCC 63.647(8/18/95)which references 40CFR 61.351(9/10/90) whichreferences 40 CFR60.112b(a)(1)(iv)(10/8/97)Covers or Lids Over OpeningsEach opening in the internal floating roof exceptfor leg sleeves, automatic bleeder vents, rimspace vents, column wells, ladder wells, samplewells, and stub drains is to be equipped with acover or lid which is to be maintained in a closedposition at all times (i.e., no visible gap) exceptwhen the device is in actual use. The cover or lidshall be equipped with a gasket. Covers on eachaccess hatch and automatic gauge float well shallbe bolted except when they are in use.5.14.26HAP/Benzene40 CFR 63 SubpartCC 63.647 (8/18/95)which references 40CFR 61.351(9/10/90) whichreferences 40 CFR60.112b(a)(1)(v)(10/8/97)Automatic Bleeder VentsEquip with a gasket andclose at all times when the roof is floating exceptwhen the roof is being floated off or is beinglanded on the roof leg supports.Each time the vessel is emptied and degassed, and at least onceevery 10 years, conduct an internal inspection of the vessel. Ifinspection shows that the floatingroof has defects including, but notlimited to, improper gasketing or unsealed openings, repair the defectsprior to refilling.Notify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least7 days prior to refilling followed immediately by written notification.5.14.27VOCNWCAASection 580.32(12/13/89)High Vapor Pressure Volatile Organic CompoundStorage TanksThe storage tank shall meet theinternal floating roof equipment specifications andmaintenance requirements of 40 CFR 60 SubpartKb.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-91Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.14.28VOCNWCAASection 560(4/14/93)Storage of Organic Liquids with a True VaporPressure Greater than 1.5 psia and Less Than11.1 psiaDesign and equip the storage vessel with thefollowing vapor loss control device, properlyinstalled, in good working order an in operation:A floating roof, consisting of a pontoon type ordouble-deck type roof, resting on the surface ofthe liquid contents and equipped with a closureseal, or seals to close the space between the roofedge and the tank wall. The control equipmentprovided for in this paragraph shall not be used ifthe gasoline of petroleum distillate has a TrueVapor Pressure of 11.1 pounds per square inch orgreater under actual storage conditions. All tankgauging and sampling devices shall be gas-tightexcept when gauging or sampling is taking place.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-92Table 5.14 - Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.14.29VOCNWCAASection 580.33(12/13/89)Seal ConditionAll seals are to be maintained ingood operating condition and the seal fabric shallcontain no visible holes, tears, or other openings.Annually, conduct a visual inspection of the internal floating roof andseal system through manholes and roof hatches. The inspection shalldocument any conditions where:•the floating roof is not resting on the VOL surface•there is liquid accumulated on the floating roof•a seal is detached or there are holes or tears in the seal fabricKeep a record of each inspection that includes the tank number, dateand conditions observed (including any failures discovered).Failures shall be repaired within 45 daysof discovery or the tank takenout of service. A delay of repair extension may be utilized for up to 60days with appropriate documentation justifying the delay.Submit in the Periodic Report thedate and description of any failuresfound and corrective action taken. The report shall include anydecision to use a delay of repair extension and documentation thatalternate storage capacity was unavailable that repair was completedas soon as possible.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-93Table 5.14: Specifically Applicable Requirements for the Wastewater Plant and Sewer SystemPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting5.14.30HAP/Benzene40 CFR 63 SubpartCC 63.647 (8/18/95)which references 40CFR 61.351(9/10/90) whichreferences 40 CFR60.112b(a)(1)(vi)(10/8/97)Rim Space VentsEquip with a gasket and setto open only when the internal floating roof is notfloating or at the manufacturer’s recommendedsetting.5.14.31HAP/Benzene40 CFR 63 SubpartCC 63.647 (8/18/95)which references 40CFR 61.351(9/10/90) whichreferences 40 CFR60.112b(a)(1)(vii)(10/8/97)Sampling WellEach penetration of the internalfloating roof for the purpose of sampling shall bea sample well. The sample well shall have a slitfabric cover that covers at least 90 percent of theopening.5.14.32HAP/Benzene40 CFR 63 SubpartCC 63.647 (8/18/95)which references 40CFR 61.351(9/10/90) whichreferences 40 CFR60.112b(a)(1)(viii)(10/8/97)Column Supporting Fixed RoofEachpenetration of the internal floating roof thatallows for passage of a column supporting thefixed roof shall have a flexible fabric sleeve sealor a gasketed sliding cover.5.14.33HAP/Benzene40 CFR 63 SubpartCC 63.647 (8/18/95)which references 40CFR 61.351(9/10/90) whichreferences 40 CFR60.112b(a)(1)(ix)(10/8/97)Gasketed Sliding CoverEach penetration ofthe internal floating roof that allows for passageof a ladder shall have a gasketed sliding cover.Each time the vessel is emptied and degassed, and at least onceevery 10 years, conduct an internal inspection of the vessel. Ifinspection shows that the floatingroof has defects including, but notlimited to, improper gasketing or unsealed openings, repair thedefects prior to refilling.Notify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally atleast 7 days prior to refilling followed immediately by writtennotification.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-945.15 Tanks and Storage VesselsInternal Floating Roof Tanks:•Tanks 1, 2, 3, 4, 5, 6, 7, 8,9, 10 and14 (NWCAA 560, NWCAA 580 and40 CFR 63 Subpart CC Group 1 StorageVessel and OAC #562b)•Tanks 17, 18, 21, 22, 25,26, 27, 31, 41, 42,43, 44, 45, 46, 47, and 48 (NWCAA560, NWCAA 580 and 40 CFR 63Subpart CC Group 1Storage 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 60Subpart 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 Vessel)Fixed Roof Tanks with No Internal Floating Roof:•Tanks 28, 30, 32, 34, 37, 38 and 70 (40CFR 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 JunctionBoxes (40 CFR 60 Subpart QQQ)NOTE - See Section 6.1 for monitoring requirements for valves in the tankfarm,pipeways and Off-Plot areasBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-95Table 5.15 -Specifically Applicable RequirementsInternal 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 OAC #562b)Permit TermCitationDescriptionMonitoring/Recordkeeping/ReportingNote: 40 CFR 63 General Provisions included in Section 3 apply to Subpart CC (affected sources).5.15.1VOCNWCAA Section 560(4/14/93)Storage of Organic Liquid with a True VaporPressure greater than 1.5 psia and less than 11.1psiaDesign and equip the storage vessel with thefollowing vapor loss control device, properlyinstalled, in good working order and in operation:A floating roof, consisting of a pontoon type ordouble-deck type roof, resting on the surface ofthe liquid contents and equipped with a closureseal, or seals, to close the space between the roofedge and tank wall.The control equipment provided for in thisparagraph shall not be used if the gasoline orpetroleum distillate has a True Vapor Pressure of11.1 pounds per square inch or greater underactual storage conditions. All tank gauging andsampling devices shall be gas-tight except whengauging or sampling is taking place.Maintain records demonstrating that the stored VOL has a TVPless than 11.1 psia. Notify the NWCAA within 12 hours ofdiscovering an exceedance of the 11.1 TVP limit averaging period.- directly enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-96Table 5.15 -Specifically Applicable RequirementsInternal 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 OAC #562b)Permit TermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.2VOCNWCAA Sections580.32 and 580.33(12/13/89) whichreference 40 CFR 60Subpart Kb60.112b(a)(1)(ii)(10/8/97) and60.113b(a)(2) (8/11/89)Seal Coverage – Annual InspectionA seal system shall be in place that completelycovers the annular space between the floatingroof and the storage vessel wall, except for whennecessary repairs are being made as provided in40 CFR 60.113b(a)(2). There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.5.15.3HAP40 CFR 63 Subpart CC63.646 (2/21/97) whichreferences 40 CFR63.119(b)(3) (1/17/97),63.120(a)(2)(i) and(a)(4) (1/17/97)Seal Coverage – Annual InspectionA seal system shall be in place that completelycovers the annular space between the floatingroof and the storage vessel wall, except for whennecessary repairs are being made as provided in40 CFR 63.120(a)(4). There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.Annually, conduct a visual inspection of the internal floating roof and sealsystem through manholes and roofhatches. The inspection shalldocument any conditions where:the floating roof is notresting on the VOL surfacethere is liquid accumulated on the floating roofa seal is detached or there are holes or tears in the seal fabricKeep a record of each inspection thatincludes the tank #, date and anyfailures discovered.Failures shall be repaired within 45 days of discovery or the tank taken outof service. A delay of repair extension may be utilized for up to 60 dayswith appropriate documentation justifying the delay.Submit in the Periodic Report documentation of any failures discoveredduring the inspection. The report shall include the date of inspection,vessel identification, description ofeach failure and the nature and date ofeach repair. The report shall include any decision to use a delay of repairextension and documentation thatalternate storage capacity wasunavailable and that repair was completed as soon as possible.5.15.4VOCNWCAA Section580.32 and 580.33(12/13/89) whichreferences 40 CFR 60Subpart Kb60.113b(a)(4) and(a)(5) (8/11/89)Seal Coverage – Inspection After DegassingThe primary seal shall completely cover theannular space between the floating roof and thestorage vessel wall. There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.5.15.5HAP40 CFR 63 Subpart CC63.646 (2/21/97) whichreferences 40 CFR63.119(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 DegassingThe primary seal shall completely cover theannular space between the floating roof and thestorage vessel wall. There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.Each time the vessel is emptied anddegassed, and at least once every 10years, conduct an internal visual inspection of the vessel. If the inspectionshows that the floating roof has failures including but not limited to, holes,tears or other openings in a seal orseal fabric, repair prior to refilling.Notify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least 7days prior to refilling followed immediately by written notification.Submit in the Periodic Report documentation of any failures discoveredduring the inspection.The report shall include the date of inspection, vessel identification,description of each failure and thenature and date of each repair. Thereport shall include any decision to use a delay of repair extension anddocumentation that alternate storage capacity was unavailable and thatrepair was completed as soon as possible.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-97Table 5.15 -Specifically Applicable RequirementsInternal 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 OAC #562b)Permit TermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.6VOCNWCAA Section580.34 (12/13/89)OpeningsAll openings not related to safety are tobe sealed with suitable closures.5.15.7HAP40 CFR 63 SubpartCC 63.646(f)(2/21/97) and63.119(b)(4)(1/17/97)Roof Openings – Inspection After DegassingExcept for automatic bleeder vents and rim spacevents, each opening in the roof shall have aprojection below the liquid surface. Except forautomatic bleeder vents, rim space vents, columnwells, ladder wells, sample wells, and stub drains,each opening in the roof shall be equipped with agasketed cover, seal, or lid that is to bemaintained 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 alltimes when the roof is floating except when theroof is being floated off or is being landed on theroof leg supports. Rim vents are to be set to openwhen the roof is being floated off the roof legsupports or at the manufacturer’s recommendedsetting. Automatic bleeder vents and rim spacevents are to be gasketed.Each time the vessel is emptied and degassed, and at least onceevery 10 years, conduct an internal visual inspection of the vessel.If inspection shows that the floating roof has failures including, butnot limited to, improper gasketing or unsealed openings, repairprior to refilling.Notify the NWCAA in writing at least 30 days prior to refilling. Ifthe inspection is unplanned, the notification may be made verballyat least 7 days prior to refilling followed immediately by writtennotification.5.15.8VOCNWCAA Section580.32 (12/13/89)which references40 CFR 60 SubpartKb 60.112b(a)(1)(i)(10/8/97)Roof Floating on SurfaceThe roof shall be floatingon the liquid at all times (i.e., off the roof legsupports) except during initial fill until the roof islifted off leg supports and when the tank iscompletely emptied and subsequently refilled.The process of filling, emptying, or refilling whenthe roof is resting on the leg supports shall becontinuous and shall be accomplished as rapidlyas possible.Keep records of periods when the floating roof is resting on the legsupports.-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-98Table 5.15 -Specifically Applicable RequirementsInternal 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 OAC #562b)Permit TermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.9HAP40 CFR 63 SubpartCC 63.646 (2/21/97)which references 40CFR 63.119(b)(1)and (b)(2) (1/17/97),and 63.646(f)(3)(2/21/97)Roof Floating on SurfaceThe floating roof shall befloating on the liquid surface at all times exceptwhen it must be supported by the leg supportsduring, initial fill, after the vessel has beencompletely emptied and degassed, and when thevessel is completely emptied before beingsubsequently refilled. When the floating roof isresting on the leg supports, the process of filling,emptying, or refilling shall be continuous and shallbe accomplished as soon as possible. Automaticbleeder vents are to be closed at all times whenthe roof is floating, except when the roof is beingfloated off or is being landed on the roof legsupports.Keep records of periods when the floating roof is resting on the legsupports.-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-99Table 5.15 -Specifically Applicable RequirementsInternal Floating Roof Tanks: 17, 18, 21, 22, 25, 26, 27, 31, 41, 42, 43, 44, 45, 46, 47 and 48(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 1 Storage Vessels)Permit TermCitationDescriptionMonitoring/Recordkeeping/ReportingNote: 40 CFR 63 General Provisions included in Section 3 apply to Subpart CC (affected sources).5.15.10VOCNWCAA Section 560(4/14/93)Storage of Organic Liquid with a True VaporPressure greater than 1.5 psia and less than 11.1psiaDesign and equip the storage vessel with thefollowing vapor loss control device, properlyinstalled, in good working order and in operation:A floating roof, consisting of a pontoon type ordouble-deck type roof, resting on the surface ofthe liquid contents and equipped with a closureseal, or seals, to close the space between the roofedge and tank wall.The control equipment provided for in thisparagraph shall not be used if the gasoline orpetroleum distillate has a True Vapor Pressure of11.1 pounds per square inch or greater underactual storage conditions. All tank gauging andsampling devices shall be gas-tight except whengauging or sampling is taking place.Maintain records demonstrating that the stored VOL has a TVPless than 11.1 psia. Notify the NWCAA within 12 hours ofdiscovering an exceedance of the 11.1 TVP limit averaging period.- directly enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-100Table 5.15 -Specifically Applicable RequirementsInternal Floating Roof Tanks: 17, 18, 21, 22, 25, 26, 27, 31, 41, 42, 43, 44, 45, 46, 47 and 48(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 1 Storage Vessels)Permit TermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.11VOCNWCAA Sections580.32 and 580.33(12/13/89) whichreference 40 CFR 60Subpart Kb60.112b(a)(1)(ii)(10/8/97) and60.113b(a)(2)(8/11/89)Seal Coverage – Annual InspectionA seal system shall be in place that completelycovers the annular space between the floating roofand the storage vessel wall, except for whennecessary repairs are being made as provided in40 CFR 60.113b(a)(2). There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.5.15.12HAP40 CFR 63 SubpartCC 63.646 (2/21/97)which references 40CFR 63.119(b)(3)(1/17/97),63.120(a)(2)(i) and(a)(4) (1/17/97)Seal Coverage – Annual InspectionA seal system shall be in place that completelycovers the annular space between the floating roofand the storage vessel wall, except for whennecessary repairs are being made as provided in40 CFR 63.120(a)(4). There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.Annually, conduct a visual inspection of the internal floating roofand seal system through manholes and roof hatches. Theinspection shall document any conditions where:the floating roof is not resting on the VOL surfacethere is liquid accumulated on the floating roofa seal is detached or there are holes or tears in the seal fabricKeep a record of each inspection that includes the tank #, date andany failures discovered.Failures shall be repaired within 45 days of discovery or the tanktaken out of service. A delay of repair extension may be utilized forup to 60 days with appropriate documentation justifying the delay.Submit in the Periodic Report documentation of any failuresdiscovered during the inspection.The report shall include the dateof inspection, vessel identification,description of each failure andthe nature and date of each repair.The report shall include anydecision to use a delay of repair extension and documentation thatalternate storage capacity wasunavailable and that repair wascompleted as soon as possible.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-101Table 5.15 -Specifically Applicable RequirementsInternal Floating Roof Tanks: 17, 18, 21, 22, 25, 26, 27, 31, 41, 42, 43, 44, 45, 46, 47 and 48(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 1 Storage Vessels)Permit TermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.13VOCNWCAA Section580.32 and 580.33(12/13/89) whichreferences 40 CFR60 Subpart Kb60.113b(a)(4) and(a)(5) (8/11/89)Seal Coverage – Inspection After DegassingThe primary seal shall completely cover theannular space between the floating roof and thestorage vessel wall. There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.5.15.14HAP40 CFR 63 SubpartCC 63.646 (2/21/97)which references40 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 DegassingThe primary seal shall completely cover theannular space between the floating roof and thestorage vessel wall. There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.Each time the vessel is emptied and degassed, and at least onceevery 10 years, conduct an internal visual inspection of the vessel.If the inspection shows that the floating roof has failures includingbut not limited to, holes, tears or other openings in a seal or sealfabric, repair prior to refilling.Notify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally atleast 7 days prior to refilling followed immediately by writtennotification.Submit in the Periodic Report documentation of any failuresdiscovered during the inspection.The report shall include the dateof inspection, vessel identification,description of each failure andthe nature and date of each repair.The report shall include anydecision to use a delay of repair extension and documentation thatalternate storage capacity wasunavailable and that repair wascompleted as soon as possible.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-102Table 5.15 -Specifically Applicable RequirementsInternal Floating Roof Tanks: 17, 18, 21, 22, 25, 26, 27, 31, 41, 42, 43, 44, 45, 46, 47 and 48(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 1 Storage Vessels)Permit TermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.15VOCNWCAA Section580.34 (12/13/89)OpeningsAll openings not related to safety areto be sealed with suitable closures.Each time the vessel is emptied and degassed, and at least onceevery 10 years, conduct an internal visual inspection of the vessel.If inspection shows that the floating roof has failures including, butnot limited to, improper gasketing or unsealed openings, repairprior to refilling.5.15.16HAP40 CFR 63 SubpartCC 63.646(f)(2/21/97) and63.119(b)(4)(1/17/97)Roof Openings – Inspection After DegassingExcept for automatic bleeder vents and rim spacevents, each opening in the roof shall have aprojection below the liquid surface. Except forautomatic bleeder vents, rim space vents, columnwells, ladder wells, sample wells, and stub drains,each opening in the roof shall be equipped with agasketed cover, seal, or lid that is to bemaintained in a closed position at all times (i.e., novisible gap) except when the device is in use.Automatic bleeder vents are to be closed at alltimes when the roof is floating except when theroof is being floated off or is being landed on theroof leg supports. Rim vents are to be set to openwhen the roof is being floated off the roof legsupports or at the manufacturer’s recommendedsetting. Automatic bleeder vents and rim spacevents are to be gasketed.Notify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally atleast 7 days prior to refilling followed immediately by writtennotification.5.15.17VOCNWCAA Section580.32 (12/13/89)which references40 CFR 60 SubpartKb 60.112b(a)(1)(i)(10/8/97)Roof Floating on SurfaceThe roof shall befloating on the liquid at all times (i.e., off the roofleg supports) exceptduring initial fill until the roofis lifted off leg supports and when the tank iscompletely emptied and subsequently refilled.The process of filling, emptying, or refilling whenthe roof is resting on the leg supports shall becontinuous and shall be accomplished as rapidlyas possible.Keep records of periods when the floating roof is resting on the legsupports.-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-103Table 5.15 -Specifically Applicable RequirementsInternal Floating Roof Tanks: 17, 18, 21, 22, 25, 26, 27, 31, 41, 42, 43, 44, 45, 46, 47 and 48(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 1 Storage Vessels)Permit TermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.18HAP40 CFR 63 SubpartCC 63.646 (2/21/97)which references 40CFR 63.119(b)(1)and (b)(2) (1/17/97),and 63.646(f)(3)(2/21/97)Roof Floating on SurfaceThe floating roof shallbe floating on the liquid surface at all times exceptwhen it must be supported by the leg supportsduring, initial fill, after the vessel has beencompletely emptied and degassed, and when thevessel is completely emptied before beingsubsequently refilled. When the floating roof isresting on the leg supports, the process of filling,emptying, or refilling shall be continuous and shallbe accomplished as soon as possible. Automaticbleeder vents are to be closed at all times whenthe roof is floating, except when the roof is beingfloated off or is being landed on the roof legsupports.Keep records of periods when the floating roof is resting on the legsupports.-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-104Table 5.15 - Specifically Applicable RequirementsInternal Floating Roof Tanks: 11(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 2 Storage Vessel)PermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNote: 40 CFR 63 General Provisions included in Section 3 apply to Subpart CC (affected sources).5.15.19VOC/HAPTitle 40 CFR SubpartCC 63.646(2/21/97),which references 40CFR 63.119(a)(3)(1/17/97)Dimensions and CapacitiesKeep readilyaccessible records of the dimensions andcapacities of each Group 2 storage vessel.Maintain records at the facility with dimensions and capacities.5.15.20VOCNWCAA Section 560(4/14/93)Storage of Organic LiquidDesign and equip thestorage vessel with the following vapor loss controldevice, properly installed, in good working orderand in operation: A floating roof, consisting of apontoon type or double-deck type roof, resting onthe surface of the liquid contents and equippedwith a closure seal, or seals, to close the spacebetween the roof edge and tank wall.The control equipment provided for in thisparagraph shall not be used if the gasoline orpetroleum distillate has a True Vapor Pressure of11.1 pounds per square inch or greater underactual storage conditions. All tank gauging andsampling devices shall be gas-tight except whengauging or sampling is taking place.Maintain records demonstrating that the stored VOL has a TVP lessthan 11.1 psia. Notify the NWCAA within 12 hours of discovering anexceedance of the 11.1 TVP limit.- directly enforceable -5.15.21VOCNWCAA Section580.32 (12/13/89)which references40 CFR 60 Subpart Kb60.112b(a)(1)(i)(10/8/97)Roof Floating on SurfaceThe roof shall befloating on the liquid at all times (i.e., off the roofleg supports) exceptduring initial fill until the roof islifted off leg supports and when the tank iscompletely emptied and subsequently refilled. Theprocess of filling, emptying, or refilling when theroof is resting on the leg supports shall becontinuous and shall be accomplished as rapidlyas possible.Keep records of periods when the floating roof is resting on the legsupports.- directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-105Table 5.15 - Specifically Applicable RequirementsInternal Floating Roof Tanks: 11(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 2 Storage Vessel)PermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.22VOCNWCAA Section580.34 (12/13/89)OpeningsAll openings not related to safety areto be sealed with suitable closures.Each time the vessel is emptied and degassed, and at least once every10 years, conduct an internal visual inspection of the vessel. Ifinspection shows that the floatingroof has failures including, but notlimited to, improper gasketing or unsealed openings, repair prior torefilling.Notify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least7 days prior to refilling followed immediately by written notification.5.15.23VOCNWCAA Sections580.32 and 580.33(12/13/89) whichreferences 40 CFR 60Subpart Kb60.112b(a)(1)(ii)(10/8/97) and60.113b(a)(2)(8/11/89)Seal Coverage – Annual InspectionA seal system shall be in place that completelycovers the annular space between the floating roofand the storage vessel wall, except for whennecessary repairs are being made as provided in40 CFR 60.113b(a)(2). There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.Annually, conduct a visual inspection of the internal floating roof andseal system through manholes and roof hatches. The inspection shalldocument any conditions where:the floating roof is not resting on the VOL surfacethere is liquid accumulated on the floating roofa seal is detached or there are holes or tears in the seal fabricKeep a record of each inspection thatincludes the tank #, date and anyfailures discovered.Failures shall be repaired within 45 daysof discovery or the tank takenout of service. A delay of repair extension may be utilized for up to 60days with appropriate documentation justifying the delay.Submit in the Periodic Report documentation of any failures discoveredduring the inspection. The report shall include the date of inspection,vessel identification, description ofeach failure and the nature and dateof each repair. The report shall include any decision to use a delay ofrepair extension and documentation that alternate storage capacity wasunavailable and that repair was completed as soon as possible.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-106Table 5.15 - Specifically Applicable RequirementsInternal Floating Roof Tanks: 11(subject to NWCAA 560, NWCAA 580 and 40 CFR 63 Subpart CC Group 2 Storage Vessel)PermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.24VOCNWCAA Section580.32 and 580.33(12/13/89) whichreferences 40 CFR 60Subpart Kb60.113b(a)(4) and(a)(5) (8/11/89)Seal Coverage – Inspection After DegassingThe primary seal shall completely cover theannular space between the floating roof and thestorage vessel wall. There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.Each time the vessel is emptied and degassed, and at least once every10 years, conduct an internal visual inspection of the vessel. If theinspection shows that the floatingroof has failures including but notlimited to, holes, tears or other openings in a seal or seal fabric, repairprior to refilling.Notify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least7 days prior to refilling followed immediately by written notification.Submit in the Periodic Report documentation of any failures discoveredduring the inspection. The report shall include the date of inspection,vessel identification, description ofeach failure and the nature and dateof each repair. The report shall include any decision to use a delay ofrepair extension and documentation that alternate storage capacity wasunavailable and that repair was completed as soon as possible.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-107Table 5.15 - Specifically Applicable RequirementsInternal Floating Roof Tanks: 24, 50, 71(subject to NWCAA 560, NWCAA 580, 40 CFR 60 SubpartKb)PermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNote: 40 CFR 60 General Provisions included in Section 3 apply to Subpart K (affected sources).5.15.25VOC40 CFR 60Subpart Kb60.112b(a)(1)(ii)(10/8/97),60.113b(a)(2)(8/11/89) and60.115b(a)(2) and(a)(3) (4/8/87) asmodified by 40CFR63.640(n)(8)(v)(5/25/01)NWCAA Sections580.32 and 580.33(12/13/89) whichreferences 40 CFR60 Subpart KbSeal Coverage – Annual InspectionA seal system shall be in place that completelycovers the annular space between the floating roofand the storage vessel wall, except for whennecessary repairs are being made as provided in40 CFR 60.113b(a)(2). There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.Annually, conduct a visual inspection of the internal floating roof andseal system through manholes and roof hatches. The inspection shalldocument any conditions where:the floating roof is not resting on the VOL surfacethere is liquid accumulated on the floating roofa seal is detached or there are holes or tears in the seal fabricKeep a record of each inspection that includes the tank #, date andconditions observed (including any failures discovered).Failures shall be repaired within 45 days of discovery or the tanktaken out of service. A delay of repair extension may be utilized forup to 60 days with appropriate documentation justifying the delay.Submit in the Periodic Report thedate and description of any failuresfound and corrective action taken. The report shall include anydecision to use a delay of repair extension and documentation thatalternate storage capacity was unavailable that repair was completedas soon as possible.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-108Table 5.15 - Specifically Applicable RequirementsInternal Floating Roof Tanks: 24, 50, 71(subject to NWCAA 560, NWCAA 580, 40 CFR 60 SubpartKb)PermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.26VOC40 CFR 60Subpart Kb60.113b(a)(4) and(a)(5) (8/11/89),and 60.115b(a)(2)and (a)(4) (4/8/87)as modified by 40CFR63.640(n)(8)(v)(5/25/01)NWCAA Section580.32 and 580.33(12/13/89) whichreferences 40 CFR60 Subpart KbSeal Coverage – Inspection After DegassingThe primary seal shall completely cover theannular space between the floating roof and thestorage vessel wall. There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.Each time the vessel is emptied and degassed, and at least onceevery 10 years, conduct an internal visual inspection of the vessel. Ifthe inspection shows that the floating roof has failures including butnot limited to, holes, tears or other openings in a seal or seal fabric,repair prior to refilling. Keep a record of each inspection that includesthe tank number, date and conditions observedNotify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least7 days prior to refilling followed immediately by written notification.Submit in the Periodic Report thedate and description of any failuresfound and corrective action taken. The report shall include anydecision to use a delay of repair extension and documentation thatalternate storage capacity was unavailable that repair was completedas soon as possible.5.15.27VOC40 CFR 60Subpart Kb60.112b(a)(1)(ii)(B)through (a)(1)(ix)(10/8/97) and60.113b(a)(4) and(a)(5) (8/11/89),and 60.115b(a)(2)and (a)(4) (4/8/87)as modified by 40CFR63.640(n)(8)(v)(5/25/01)Roof Openings – Inspection after DegassingExcept for automatic bleeder vents and rim spacevents, each opening in the non contact roof shallhave a projection below the liquid surface. Exceptfor automatic bleeder vents, rim space vents,columns wells, ladder wells, sample wells, andstub drains, each opening in the roof shall beequipped with a gasketed cover, seal, or lid that isto be maintained in a closed position at all times(i.e., no visible gaps) except when the device is inuse.Automatic bleeder vents are to be closed at altimes when the roof is floating except when theroof is being floated off or is being landed on theleg supports. Rim vents are to be set to openwhen the roof is being floated off the roof legsupports or at the manufacturer’s recommendedsetting. Automatic bleeder vents and rim spacevents are to be gasketed.Each time the vessel is emptied and degassed, and at least onceevery 10 years, conduct an internal visual inspection of the vessel. Ifinspection shows that the floatingroof has failures including, but notlimited to, improper gasketing or unsealed openings, repair prior torefilling. Keep a record of eachinspection that includes the tanknumber, date and conditions observedNotify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least7 days prior to refilling followed immediately by written notification.Submit in the Periodic Report thedate and description of any failuresfound and corrective action taken. The report shall include anydecision to use a delay of repair extension and documentation thatalternate storage capacity was unavailable that repair was completedas soon as possible.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-109Table 5.15 - Specifically Applicable RequirementsInternal Floating Roof Tanks: 24, 50, 71(subject to NWCAA 560, NWCAA 580, 40 CFR 60 SubpartKb)PermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.28VOCNWCAA Section580.34 (12/13/89)OpeningsAll openings not related to safety are tobe sealed with suitable closures.5.15.29VOCNWCAA Section580.32 (12/13/89)which references40 CFR 60 SubpartKb 60.112b(a)(1)(i)(10/8/97)Roof Floating on SurfaceThe roof shall be floatingon the liquid at all times (i.e., off the roof legsupports) except during initial fill until the roof islifted off leg supports and when the tank iscompletely emptied and subsequently refilled. Theprocess of filling, emptying, or refilling when theroof is resting on the leg supports shall becontinuous and shall be accomplished as rapidly aspossible.Keep records of periods when the floating roof is resting on the legsupports.-directly enforceable5.15.30VOC/HAP40 CFR 60 SubpartKb 60.116b(c) and(e) (12/14/00)Maximum True Vapor PressureMaintain a recordof the VOL stored, the period of storage, and themaximum true vapor pressure of that VOL duringthe respective storage period.Calculate the maximum true vapor pressure using known Reid VaporPressure and the maximum expected storage temperature based onthe highest expected calendar-month average temperature of thestored product.Maintain records at the facility with this information.5.15.31VOCNWCAA Section560 (4/14/93)Storage of Organic Liquid of True Vapor Pressureof greater than 1.5 psia and less than 11.1 psiaDesign and equip the storage vessel with thefollowing vapor loss control device, properlyinstalled, in good working order and in operation: Afloating roof, consisting of a pontoon type ordouble-deck type roof, resting on the surface of theliquid contents and equipped with a closure seal, orseals, to close the space between the roof edgeand tank wall. The control equipment provided for inthis paragraph shall not be used if the gasoline orpetroleum distillate has a True Vapor Pressure of11.1 pounds per square inch or greater underactual storage conditions. All tank gauging andsampling devices shall be gas-tight except whengauging or sampling is taking place.Maintain records demonstrating that the stored VOL has a TVP lessthan 11.1 psia. Notify the NWCAA within 12 hours of discovering anexceedance of the 11.1 TVP limit averaging period.-directly enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-110Table 5.15 - Specifically Applicable RequirementsInternal Floating Roof Tank 40 and 49(subject to NWCAA 560, NWCAA 580, 40 CFR Subpart Kb, OAC #897 and OAC #620a)PermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNote: 40 CFR 60 General Provisions included in Section 3 apply to Subpart Kb (affected sources).The following conditions apply to Tanks 40 and 495.15.32VOC40 CFR 60Subpart Kb60.112b(a)(1)(ii)(10/8/97),60.113b(a)(2)(8/11/89) and60.115b(a)(2)and (a)(3)(4/8/87) asmodified by 40CFR63.640(n)(8)(v)(5/25/01)NWCAASections 580.32and 580.33(12/13/89) whichreferences 40CFR 60 SubpartKbSeal Coverage – Annual InspectionA seal system shall be in place that completelycovers the annular space between the floatingroof and the storage vessel wall, except for whennecessary repairs are being made as provided in40 CFR 60.113b(a)(2). There should be noholes, tears, or other openings in the seal, sealfabric, or the seal envelope.Annually, conduct a visual inspection of the internal floating roof and sealsystem through manholes and roof hatches. The inspection shalldocument any conditions where:•the floating roof is not resting on the VOL surface•there is liquid accumulated on the floating roof•a seal is detached or there are holes or tears in the seal fabricKeep a record of each inspection that includes the tank #, date andconditions observed (including any failures discovered).Failures shall be repaired within 45 daysof discovery or the tank takenout of service. A delay of repair extension may be utilized for up to 60days with appropriate documentation justifying the delay.Submit in the Periodic Report thedate and description of any failuresfound and corrective action taken. The report shall include any decisionto use a delay of repair extensionand documentation that alternatestorage capacity was unavailable thatrepair was completed as soon aspossible.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-111Table 5.15 - Specifically Applicable RequirementsInternal Floating Roof Tank 40 and 49(subject to NWCAA 560, NWCAA 580, 40 CFR Subpart Kb, OAC #897 and OAC #620a)PermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.33VOC40 CFR 60Subpart Kb60.113b(a)(4)and (a)(5)(8/11/89), and60.115(a)(2) and(a)(4) (4/8/87)as modified by40 CFR63.640(n)(8)(v)(5/25/01)NWCAA Section580.32 and580.33(12/13/89) whichreferences 40CFR 60 SubpartKbSeal Coverage – Inspection After DegassingThe primary seal shall completely cover theannular space between the floating roof and thestorage vessel wall. There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.Each time the vessel is emptied and degassed, and at least once every10 years, conduct an internal visual inspection of the vessel. If theinspection shows that the floatingroof has failures including but notlimited to, holes, tears or other openings in a seal or seal fabric, repairprior to refilling. Keep a record of each inspection that includes the tanknumber, date and conditions observedNotify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least 7days prior to refilling followed immediately by written notification.Submit in the Periodic Report thedate and description of any failuresfound and corrective action taken. The report shall include any decisionto use a delay of repair extensionand documentation that alternatestorage capacity was unavailable thatrepair was completed as soon aspossible.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-112Table 5.15 - Specifically Applicable RequirementsInternal Floating Roof Tank 40 and 49(subject to NWCAA 560, NWCAA 580, 40 CFR Subpart Kb, OAC #897 and OAC #620a)PermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.34VOC40 CFR SubpartKb60.112b(a)(1)(iii)through (ix)(10/8/97)and60.113b(a)(4)and (a)(5)(8/11/89), and60.115b(a)(2)and (a)(4)(4/8/87) asmodified by 40CFR63.640(n)(8)(v)(5/25/01)Roof Openings Inspection After DegassingExcept for automatic bleeder vents, rim spacevents, roof drains, and leg sleeves, each openingin the non contact roof is to be equipped with agasketed cover, seal, or lid that is to bemaintained in a closed position at all times (i.e.,no visible gap) except when the device is inactual use.Automatic bleeder vents are to be closed at alltimes when the roof is floating except when theroof is being floated off or is being landed on theroof leg supports. Rim vents are to be set toopen when the roof is being floated off the roofleg supports or at the manufacturer’srecommended setting. Automatic bleeder ventsand rim space vents are to be gasketed. Eachpenetration of the internal floating roof for thepurpose of sampling shall have a sample well.The sample well shall have a slit fabric cover thatcovers at least 90 percent of the area of theopening.Each time the vessel is emptied and degassed, and at least once every10 years, conduct an internal visual inspection of the vessel. If inspectionshows that the floating roof has failures including, but not limited to,improper gasketing or unsealed openings, repair prior to refilling. .Keep a record of each inspection that includes the tank #, date andconditions observedNotify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least 7days prior to refilling followed immediately by written notification.Submit in the Periodic Report thedate and description of any failuresfound and corrective action taken. The report shall include any decisionto use a delay of repair extensionand documentation that alternatestorage capacity was unavailable thatrepair was completed as soon aspossible.5.15.35VOCNWCAA Section580.34(12/13/89)OpeningsAll openings not related to safety are to be sealedwith suitable closures.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-113Table 5.15 - Specifically Applicable RequirementsInternal Floating Roof Tank 40 and 49(subject to NWCAA 560, NWCAA 580, 40 CFR Subpart Kb, OAC #897 and OAC #620a)PermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.35VOCNWCAA Section580.32 and580.33(12/13/89) whichreferences 40CFR 60 SubpartKb60.113b(a)(4)and (a)(5)(8/11/89)Seal Coverage – Inspection After DegassingThe primary seal shall completely cover theannular space between the floating roof and thestorage vessel wall. There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.Each time the vessel is emptied and degassed, and at least once every10 years, conduct an internal visual inspection of the vessel. If theinspection shows that the floatingroof has failures including but notlimited to, holes, tears or other openings in a seal or seal fabric, repairprior to refilling.Notify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least 7days prior to refilling followed immediately by written notification.Submit in the Periodic Report documentation of any failures discoveredduring the inspection. The report shall include the date of inspection,vessel identification, description ofeach failure and the nature and dateof each repair. The report shall include any decision to use a delay ofrepair extension and documentation that alternate storage capacity wasunavailable and that repair was completed as soon as possible.5.15.37VOCNWCAA Section580.34(12/13/89)OpeningsAll openings not related to safety areto be sealed with suitable closures.Each time the vessel is emptied and degassed, and at least once every10 years, conduct an internal visual inspection of the vessel. If inspectionshows that the floating roof has failures including, but not limited to,improper gasketing or unsealed openings, repair prior to refilling.Notify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least 7days prior to refilling followed immediately by written notification.5.15.38VOCNWCAA Section580.32(12/13/89) whichreferences40 CFR 60Subpart Kb60.112b(a)(1)(i)(10/8/97)Roof Floating on SurfaceThe roof shall befloating on the liquid at all times (i.e., off the roofleg supports) exceptduring initial fill until the roofis lifted off leg supports and when the tank iscompletely emptied and subsequently refilled.The process of filling, emptying, or refilling whenthe roof is resting on the leg supports shall becontinuous and shall be accomplished as rapidlyas possible.Keep records of periods when the floating roof is resting on the legsupports.-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-114Table 5.15 - Specifically Applicable RequirementsInternal Floating Roof Tank 40 and 49(subject to NWCAA 560, NWCAA 580, 40 CFR Subpart Kb, OAC #897 and OAC #620a)PermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.39VOC/HAPTitle 40 CFRSubpart Kb60.116b(c) and(e) (12/14/00)Maximum True Vapor PressureMaintain a record of the VOL stored, the period ofstorage, and the maximum true vapor pressure ofthat VOL during the respective storage period.Calculate the maximum true vapor pressure on a monthly basis usingknown Reid Vapor Pressure andthe maximum expected storagetemperature based on the highestexpected calendar-month averagetemperature of the stored product.Maintain records at the facility with this information.The following Specific Conditions apply to Tank 495.15.40VOCNWCAA OAC#620aCondition 2(7/26/02)The storage vessel may be used to store crude oilonly.Keep records of material stored in tank.5.15.41GeneralNWCAA OAC#620aCondition 5Maintain records of the number of tank turnoversper year, and material stored for a period of atleast twoyears.Keep records of material stored in tank on site.5.15.42GeneralNWCAA OAC#620aCondition 2(7/26/02)Provide a report of an upset condition within 12hours when defects are found during inspectionsof the storage vessel with a written follow-upreport.Report upsets conditions within 12 hours when defects are found duringinspections. Provide a written follow-up report within 30 days describingeach defect and the corrective action taken to assure compliance. Awritten 30 day extension may be submitted to NWCAA if repairs of thetank cannot be completed within 45 days.The following Specific Conditions apply to Tank 405.15.43GeneralNWCAA OAC#897Condition 1(11/15/04)Maintain records of the number of tank turnoversper calendar year, and the types and dates ofliquids stored.Keep records onsite for a minimum of five years.5.15.44GeneralNWCAA OAC#897Condition 2(11/15/04)Provide a report of an upset condition within 12hours when defects are found during inspectionsof the storage vessel with a written follow-upreport.Provide a written follow-up report within 30 days describing each defectand the corrective action taken to assure complianceBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-115Table 5.15- Specifically Applicable RequirementsInternal Floating Roof Tank 72, 73, 74 (subject to NWCAA 560, NWCAA 580, 40 CFR 60 Subpart Kb and OAC #527c)PermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNote: 40 CFR 60 General Provisions included in Section 3 apply to Subpart Kb (affected sources).5.15.45VOCNWCAA Section 560(4/14/93)Storage of Organic Liquid of True Vapor Pressuregreater than 1.5 psia and less than 11.1 psiaDesign and equip the storage vessel with thefollowing vapor loss control device, properlyinstalled, in good working order and in operation:A floating roof, consisting of a pontoon type ordouble-deck type roof, resting on the surface ofthe liquid contents and equipped with a closureseal, or seals, to close the space between theroof edge and tank wall.The control equipment provided for in thisparagraph shall not be used if the gasoline orpetroleum distillate has a True Vapor Pressure of11.1 pounds per square inch or greater underactual storage conditions. All tank gauging andsampling devices shall be gas-tight except whengauging or sampling is taking place.Maintain records demonstrating that the stored VOL has a TVP lessthan 11.1 psia. Notify the NWCAA within 12 hours of discovering anexceedance of the 11.1 TVP limit averaging period.- directly enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-116Table 5.15- Specifically Applicable RequirementsInternal Floating Roof Tank 72, 73, 74 (subject to NWCAA 560, NWCAA 580, 40 CFR 60 Subpart Kb and OAC #527c)PermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.45VOC40 CFR 60 SubpartKb 60.112b(a)(1)(ii)(10/8/97),60.113b(a)(2)(8/11/89) and60.115b(a)(2) and(a)(3) (4/8/87) asmodified by 40 CFR63.640(n)(8)(v)(5/25/01)NWCAA Sections580.32 and 580.33(12/13/89) whichreferences 40 CFR60 Subpart KbSeal Coverage – Annual InspectionA seal system shall be in place that completelycovers the annular space between the floatingroof and the storage vessel wall, except for whennecessary repairs are being made as provided in40 CFR 60.113b(a)(2). There should be noholes, tears, or other openings in the seal, sealfabric, or the seal envelope.Annually, conduct a visual inspection of the internal floating roof andseal system through manholes and roof hatches. The inspection shalldocument any conditions where:•the floating roof is not resting on the VOL surface•there is liquid accumulated on the floating roof•a seal is detached or there are holes or tears in the seal fabricKeep a record of each inspection that includes the tank number, dateand conditions observed (including any failures discovered).Failures shall be repaired within 45 days of discovery or the tanktaken out of service. A delay of repair extension may be utilized for upto 60 days with appropriate documentation justifying the delay.Submit in the Periodic Report thedate and description of any failuresfound and corrective action taken. The report shall include anydecision to use a delay of repair extension and documentation thatalternate storage capacity was unavailable that repair was completedas soon as possible.5.15.47VOC40 CFR 60 SubpartKb 60.113b(a)(4)and (a)(5) (8/11/89),and 60.115(a)(2) and(a)(4) (4/8/87) asmodified by 40 CFR63.640(n)(8)(v)(5/25/01)NWCAA Section580.32 and 580.33(12/13/89) whichreferences 40 CFR60 Subpart KbSeal Coverage – Inspection After DegassingThe primary seal shall completely cover theannular space between the floating roof and thestorage vessel wall. There should be no holes,tears, or other openings in the seal, seal fabric, orthe seal envelope.Each time the vessel is emptied and degassed, and at least onceevery 10 years, conduct an internal visual inspection of the vessel. Ifthe inspection shows that the floating roof has failures including butnot limited to, holes, tears or other openings in a seal or seal fabric,repair prior to refilling. Keep a record of each inspection that includesthe tank number, date and conditions observedNotify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least7 days prior to refilling followed immediately by written notification.Submit in the Periodic Report thedate and description of any failuresfound and corrective action taken. The report shall include anydecision to use a delay of repair extension and documentation thatalternate storage capacity was unavailable that repair was completedas soon as possible.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-117Table 5.15- Specifically Applicable RequirementsInternal Floating Roof Tank 72, 73, 74 (subject to NWCAA 560, NWCAA 580, 40 CFR 60 Subpart Kb and OAC #527c)PermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.48VOCNWCAA Section580.34 (12/13/89)OpeningsAll openings not related to safety are to be sealedwith suitable closures.5.15.49VOC40 CFR 60 SubpartKb60.112b(a)(1)(ii)(B)through (a)(1)(ix)(10/8/97) and60.113b(a)(4) and(a)(5) (8/11/89), and60.115b(a)(2) and(a)(4) (4/8/87) asmodified by 40 CFR63.640(n)(8)(v)(5/25/01)Roof Openings - Inspection After DegassingExcept for automatic bleeder vents and rim spacevents, each opening in the non contact roof shallhave a projection below the liquid surface.Except for automatic bleeder vents, rim spacevents, column wells, ladder wells, sample wells,and stub drains, each opening in the roof shall beequipped with a gasketed cover, seal, or lid thatis to be maintained in a closed position at alltimes (i.e., no visible gap) except when the deviceis in use.Automatic bleeder vents are to be closed at alltimes when the roof is floating except when theroof is being floated off or is being landed on theroof leg supports. Rim vents are to be set toopen when the roof is being floated off the roofleg supports or at the manufacturer’srecommended setting. Automatic bleeder ventsand rim space vents are to be gasketed.Each time the vessel is emptied and degassed, and at least onceevery 10 years, conduct an internal visual inspection of the vessel. Ifinspection shows that the floatingroof has failures including, but notlimited to, improper gasketing or unsealed openings, repair prior torefilling. Keep a record of each inspection that includes the tank #,date and conditions observedNotify the NWCAA in writing at least 30 days prior to refilling. If theinspection is unplanned, the notification may be made verbally at least7 days prior to refilling followed immediately by written notification.Submit in the Periodic Report thedate and description of any failuresfound and corrective action taken. The report shall include anydecision to use a delay of repair extension and documentation thatalternate storage capacity was unavailable that repair was completedas soon as possible.5.15.50VOCNWCAA Section580.32 (12/13/89)which references40 CFR 60 SubpartKb 60.112b(a)(1)(i)(10/8/97)Roof Floating on SurfaceThe roof shall be floating on the liquid at all times(i.e., off the roof leg supports) except during initialfill until the roof is lifted off leg supports and whenthe tank is completely emptied and subsequentlyrefilled. The process of filling, emptying, orrefilling when the roof is resting on the legsupports shall be continuous and shall beaccomplished as rapidly as possible.Keep records of periods when the floating roof is resting on the legsupports.-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-118Table 5.15- Specifically Applicable RequirementsInternal Floating Roof Tank 72, 73, 74 (subject to NWCAA 560, NWCAA 580, 40 CFR 60 Subpart Kb and OAC #527c)PermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.15.51VOC/HAPTitle 40 CFR SubpartKb 60.116b(c) and (e)(12/14/00)Maximum True Vapor PressureMaintain a record of the VOL stored, the period ofstorage, and the maximum true vapor pressure ofthat VOL during the respective storage period.Calculate the maximum true vapor pressure during the storage periodusing known Reid Vapor Pressureand the maximum expected storagetemperature based on the highestexpected calendar-month averagetemperature of the stored product.Maintain records at the facility with this information.5.15.52VOCNWCAA OAC #527cCondition 2(12/12/01)Two of the three tanks may be in gasoline serviceat any given time.Maintain records of material stored in tanks.-directly enforceable5.15.53VOCNWCAA OAC #527cCondition 2 and 3(12/12/01)Tanks shall follow Subpart Kb.Tanks are subject all applicable NSPS Subpart Kb requirementsincluding monitoring, performance testing, reporting and recordkeeping.5.15.54GeneralNWCAA OAC #527cCondition 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 material stored in tank for 5 years.Maintain records of dimensions and capacity for the life of the facility.-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-119Table 5.15 - Specifically Applicable RequirementsInternal Floating Roof Tanks: 12, 13, 15, 16, 19, 20, 23, 29, 33 and(subject to 40 CFR 63 Subpart CC Group 2 Storage Vessel)PermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNote: 40 CFR 63 General Provisions included in Section 3 apply to Subpart CC (affected sources).5.15.55VOC/HAP40 CFR SubpartCC63.646(2/21/97),which references40 CFR63.119(a)(3) whichreferences 40 CFR63.123(a)(1/17/97)Dimensions and CapacitiesKeep readilyaccessible records of the dimensions andcapacities of each Group 2 storage vessel.Maintain records at the facility with dimensions and capacities.Table 5.15 - Specifically Applicable RequirementsFixed 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)PermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingNote: 40 CFR 63 General Provisions included in Section 3 apply to Subpart CC (affected sources).5.15.56VOC/HAP40 CFR SubpartCC63.646(2/21/97),which references40 CFR63.119(a)(3) whichreferences 40 CFR63.123(a)(1/17/97)Dimensions and CapacitiesKeep readily accessible records of the dimensionsand capacities of each Group 2 storage vessel.Maintain records at the facility with dimensions and capacities.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-120Table 5.15 – Miscellaneous Tankfarm RequirementsPermit TermCitationDescriptionMonitoring/Recordkeeping/ReportingComponents in HAP ServiceNote: 40 CFR 61 General Provisions included in Section 3 apply to this affected facility.5.15.57HAPNWCAA OAC No.562b (3/17/03),Condition 4 and 7which references40 CFR 61 Subpart J61.112(a) whichreferences 40 CFR61.240 (a), 61.242 -1through -11(12/14/00)NESHAP Equipment LeaksMonitor applicable components for fugitive leaks,repair leaks in a timely manner, and reportmonitoring results semi-annually in accordancewith 40 CFR 60 Subpart VV. Componentsinclude: pumps in liquid service, pressure reliefvalves in gas/liquidservice, all samplingconnection systems, all open-ended valves orlines, all valves in gas/vapor service or light liquidservice, all pumps and valves in heavy liquidservice, pressure relief valves in light liquidservice, flanges and other connectors.Conduct an Equipment Leak program (LDAR) as specified inSection 6.2Applies to the storage vessel associated with the light reformatesplitter tower only.Note: 40 CFR 63 General Provisions included in Section 3 apply Subpart CC (affected sources).5.15.58HAP40 CFR 63 SubpartCC 63.648 (a) and(b) (8/18/98) whichreferences 40 CFR60.480-60.489(12/14/00)Refinery MACT Equipment LeaksMonitor applicable components for fugitive leaks,repair leaks in a timely manner and reportmonitoring results semi-annually in accordancewith 40 CFR 60 Subpart VV.Conduct an Equipment Leak program (LDAR) as specified inSection 6.2BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-121Table 5.15 – Miscellaneous Tankfarm RequirementsPermit TermCitationDescriptionMonitoring/Recordkeeping/ReportingComponents in VOC ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to this affected facility5.15.59VOC40 CFR 60 SubpartQQQ 60.692-2(11/23/88) 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Individual Drain SystemsEach applicable individual drain system shall beequipped with a water seal and/or caps and plugsso that VOC emissions are not vented to theatmosphere.Except where repair is technically impossiblewithout a unit shutdown,when a broken seal, gap,crack or other problem is identified, first efforts atrepair shall be made as soon as practicable, butnot later than 15 calendar days after identification.Conduct Inspections as specified in Permit Term 5.14.1.Follow 40 CFR 60 Appendix A Method 215.15.60VOC40 CFR 60 SubpartQQQ 60.692-2(11/23/88) 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Individual Junction BoxesEach applicable individual junction box shall beequipped with a cover and may have open ventpipe. The vent pipe shall be at least 3 ft in lengthand not exceed 4-inches in diameter.Conduct Inspections as specified in Permit Term 5.14.2.Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-1225.16 Shipping, Pumping, and Receiving5.16.1 Chemical TreatersTable 5.16 - Specifically Applicable Requirements for the Chemical Treater UnitPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire Chemical Treater AreaNote: 40 CFR 60 General Provisions included in Section 3 applyto these affected facilities.Components in VOC Service5.16.1VOC40 CFR 60 SubpartQQQ 60.692-2(11/23/88), 60.692-5(10/17/00), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NSPS Individual Junction BoxesEach affected individual junction box shall beequipped with a sealed cover, may have anopen vent pipe or may be routed to a closedvent system with a control device such as acarbon canister with no detectable emissions.Conduct Inspections as specified in Permit Term 5.14.2.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-123Table 5.16 - Specifically Applicable Requirements for the Chemical Treater UnitPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.16.2VOC40 CFR 60 SubpartGGG60.590-60.593(10/17/00) whichreferences 40 CFR60.480-60.489(12/14/00)BP Consent DecreeParagraph 20NSPS Equipment LeaksMonitor applicable components for fugitiveleaks, repair leaks in a timely manner, andreport monitoring results semi-annually inaccordance with 40 CFR 60 Subpart VV.Components include: pumps in liquid service,pressure relief valves in gas/liquid service, allsampling connection systems, all open-endedvalves or lines, all valvesin gas/vapor service orlight liquid service, all pumps and valves inheavy liquid service, pressure relief valves inlight liquid service, flanges and otherconnectors.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2Follow 40 CFR 60 Appendix A Method 21Components in HAP ServiceNote: The Title 40 CFR 63 General Provisions included in Section 3 apply5.16.3HAP40 CFR 63 SubpartCC63.648(a) and (b)(8/18/98) whichreferences 40 CFR60.480-60.489(12/14/00)Refinery MACT Equipment LeaksMonitor applicable components for fugitiveleaks, repair leaks in a timely manner and reportmonitoring results semi-annually in accordancewith 40 CFR 60 Subpart VV.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-1245.16.2 Truck RackTable 5.16: Specifically Applicable Requirements for the Truck RackPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingEntire Truck Rack AreaComponents in VOC ServiceNote: The Title 40 CFR Parts 60 General Provisions included in Section 3 apply to these affected facilities.5.16.4VOC40 CFR 60 SubpartQQQ 60.692-2(11/23/88) 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NWCAA OAC #527cCondition 19(12/12/01)NSPS Individual Drain SystemsEach individual drain system shall beequipped with a water seal and/or caps andplugs so that VOC emissions are not ventedto the atmosphere.Except where repair is technically impossiblewithout a unit shutdown, when a broken seal,gap, crack or other problem is identified, firstefforts at repair shall be made as soon aspracticable, but not later than 15 calendardays after identification.Conduct Inspections as specified in Permit Term 5.14.1.5.16. 5VOC40 CFR 60 SubpartQQQ 60.692-2(11/23/88), 60.692-5(10/17/00), 60.697(10/17/00), and60.698(b) and (c)(8/18/95)NWCAA OAC #527cCondition 19(12/12/01)NSPS Individual Junction BoxesEach affected individual junction box shall beequipped with a sealed cover, may have anopen vent pipe or may be routed to a closedvent system with a control device such as acarbon canister with no detectable emissions.Conduct Inspections as specified in Permit Term 5.14.2.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-125Table 5.16: Specifically Applicable Requirements for the Truck RackPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.16.6VOC40 CFR 60 SubpartGGG60.590-60.593(10/17/00) whichreferences 40 CFR60.480-60.489(12/14/00)NWCAA OAC #527c(12/12/01) Conditions13 & 18NSPS Equipment LeaksMonitor components for fugitive leaks, repairleaks in a timely manner, and reportmonitoring results semi-annually inaccordance with 40 CFR 60 Subpart VV.Components include: pumps in liquid service,pressure relief valves in gas/liquid service, allsampling connection systems, all open-endedvalves or lines, all valves in gas/vapor serviceor light liquid service, all pumps and valves inheavy liquid service, pressure relief valves inlight liquid service, flanges and otherconnectors.Conduct an Equipment Leak program (LDAR) as specified in Section6.2 with the following additions:Each calendar month, the vapor collection system, vapor processingsystem, and each loading rack handling gasoline shall be inspectedduring loading gasoline tank trucks for total organic compounds liquid orvapor leaks. For each detection of a leak shall be recorded and thesource of the leak repaired within 15 calendar days after it is detected.A record of each monthly leak inspection shall be kept on file at theterminal for at least 2 years.Follow 40 CFR 60 Appendix A Method 21-directly enforceableComponents in HAP ServiceNote: The Title 40 CFR 63 General Provisions included in Section 3 apply5.16.7HAP40 CFR 63 Subpart CC63.648(a) and (b)(8/18/98) whichreferences 40 CFR60.480--60.489(12/14/00)Refinery MACT Equipment LeaksMonitor applicable components for fugitiveleaks, repair leaks in a timely manner andreport monitoring results semi-annually inaccordance with 40 CFR 60 Subpart VVConduct an Equipment Leak program (LDAR) as specified in Section6.2Follow 40 CFR 60 Appendix A Method 215.16.8HAP40 CFR 63 Subpart CC63.647(c), 63.654(a),63.654(i)(4) whichreferences 40 CFR61.340 through 61.355Refinery MACT Process DrainsEach applicable individual drain system shallbe equipped with a water seal and/or capsand plugs so that VOC emissions are notvented to the atmosphere.Conduct inspections as specified in Permit Term 5.14.3.Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-126Table 5.16: Specifically Applicable Requirements for the Truck RackPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.16.9VOC/HAP40 CFR 63 Subpart CC63.650(a) (6/12/96)which references 40CFR 63.422(b)(6/26/95), 63.427(a)(3)and (b) (2/28/97),63.425 (6/26/95) and63.428,(c), and (h)(1).(2/28/97)40 CFR 63 Subpart CC63.654(b) (8/18/98)which references 40CFR 63.428(c) and(h)(1) (2/28/97)NWCAA OAC #527cCondition 9(12/12/01)Emissions to the atmosphere from the vaporcollection and processing systems shall notexceed 10 milligrams of total organiccompounds per liter of gasoline loaded.The vapor control system shall prevent theemission of at least 90% by weight of VOC’s.A thermal oxidation system must have a continuous parametermonitoring system (CPMS) capable of measuring temperature. TheCPMS shall be installed in the firebox or in the ductwork immediatelydownstream of the firebox.Compliance shall be demonstrated biennially by conducting testingaccording to EPA Method 25 or another method approved by theControl Officer. Thirty day advancenotice of the test date is required.Submit an excess emissions report tothe NWCAA in accordance with63.10(e)(3). The report shall include each exceedance or failure tomaintain, as appropriate, the monitoring parameter value, the days theexceedance or failure occurred, and a description and timing of thesteps taken to repair or perform maintenance on the vapor collectionand processing systems.40 CFR 60 Appendix A Method 21 and EPA Method 25A or 25B asmodified by 40 CFR 60.503 and 63.425BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-127Table 5.16: Specifically Applicable Requirements for the Truck RackPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingTruck Rack5.16.10VOCNWCAA OAC #527cCondition 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 theemission of at least 90 percent by weight of theVOC and shall limit the emission to no morethan 35 milligrams VOC per liter of gasolinetransferred.Comply with AOP Terms 5.16.9.In addition, perform biennial testing in accordance with 40 CFR 60.503(2/14/89), and 40 CFR 63.425(a) & (b)(6/26/95) except a reading of 500ppm shall be used to determine the level of leaks to be repaired under60.503(b).Continuously monitor the combustion chamber of the vapor combustorProvide the NWCAA 30 days notice prior to testing (unless waived by theNWCAA) and submit the test results to the NWCAA not less than 45days after testing is completed.40 CFR 60 Appendix A Method 21 and EPA Method 25A or 25B asmodified by 40 CFR 60.503 and 63.425- directly enforceable -5.16.11VOC40 CFR 63 Subpart CC63.427(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 amanner not to go below the operatingparameter determined during performancetesting, supplemented by engineeringassessments and manufacturer’srecommendations that demonstrate continuouscompliance with the emission standard.Monitor combustion chamber temperature of the vapor combustor toensure an average temperature of not less than 1200oF during theloading cycle in order to maintain VOC destruction to meet AOP Term5.16.10. Operation of the combustion chamber below 1200oF willconstitute a violation of the emission standard AOP Terms 5.16.9 and5.16.10.Operation at an average temperature of 1200oF will ensure that theemission standard of 10 milligrams of total organic compounds per literof gasoline loaded will be met. This temperature was determined inbiannual testing to meet the standard and was conveyed to NWCAA in aDecember 27, 1995 letter from BP.Maintain records onsite for 5 years.40 CFR 60 Appendix A Method 21 and EPA Method 25A or 25B asmodified by 40 CFR 60.503 and 63.425BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-128Table 5.16: Specifically Applicable Requirements for the Truck RackPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.16.12SO240 CFR 60 Subpart J60.104(a)(1),60.105(a)(4), 60.105(e)(3)(ii)Truck Rack – Fuel GasFuel gas used in the combustor shall bepipeline grade natural gas or treated fuel gasmeeting the requirements of Subpart J.Treated fuel gas is limited to a concentration ofH2S<230 mg/dscm (0.10 gr/dscf). Equivalent to162 ppm H2S, 3 hour rolling average.Retain records of fuel used for pilot gas. Retain records to assure thatfuels loaded meet the sulfur specifications for that finished product.Report to EPA Region 10 and the NWCAA, any change in the type offuels loaded, type of gaseous fuelused as a pilot fuel in the vaporcombustor or any change in their sulfurspecifications. In addition, reportany failures to meet the sulfur specifications of products loaded or fuelused for the pilot. Reports shall be submitted within 30 days of thechange or failure to meet sulfur specifications a product or fuel.Follow 40 CFR 60 Appendix A Method 11 or 15Truck Rack Terminal5.16.13GeneralNWCAA OAC #527c(12/12/01) Condition 20Loadout CapacityMaximum loadout of gasoline through theterminal shall be limited to 26,000 barrels perday. Total loadout of diesels and jet fuel shallbe limited to 76,000 barrels per day combinedMaintain loadout records for the terminal on-site.5.16.14VOC40 CFR 63 Subpart CC63.650(a) (6/12/96)which references 40CFR 63.422(a)(6/26/95) whichreferences 40 CFR60.502(a) and (d)(2/12/99)Equip with a vapor collection systemdesigned to collect the total organiccompounds vapors displaced from tank trucksduring product loading and to prevent anytotal organic compounds vapors collected atone loading rack from passing to anotherloading rack.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-129Table 5.16: Specifically Applicable Requirements for the Truck RackPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.16.15VOCNWCAA OAC #527cCondition 10(12/12/01)NWCAA 580.425(12/13/89)The vapor control system shall be equippedwith an appropriate alarm system to alertpersonnel when the system is not incompliance with 580.424.Operate a functioning interlock system that prevents loading when acargo tank is not in compliance or when the vapor recovery system is notin operation.- directly enforceable -5.16.16VOCNWCAA OAC #527cConditions 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 submergedor bottom loading for all transport tanks and beequipped with a vapor control system.Keep written operation and maintenance procedures onsite specifyingthat all product loading will besubmerge loaded and that the vaporcombustor shall be operating at all times when gasoline vapors are beingrouted to the device.- directly enforceable -5.16.17VOCNWCAA OAC #527cCondition 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 equippedwith vapor-tight fittings which closeautomatically upon disconnect. The point ofclosure shall be on the tank side of any hoseor immediate connecting line.Keep written procedures onsite specifying that all product loading andvapor control lines shall be equipped with vapor-tight fittings that closeautomatically and that the linesare designed to prevent leaks.- directly enforceable -5.16.18VOCNWCAA OAC #527cConditions 12 & 15(12/12/01)40 CFR 63 Subpart CC63.650(a) (6/12/96)which references 40CFR 63.422(a) (6/26/95)which references 40CFR 60.502(h) and (i)(2/12/99)Equipment shall be operated to prevent gaugepressure in the delivery tank from exceeding4,500 pascals (450 mm of water) duringproduct loading and pressure-vacuum vent inthe bulk gasoline terminal's vapor collectionsystem shall not begin to open at a systempressure less than 4,500 pascals.Use 40 CFR 60.503(d) (system pressure test)BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-130Table 5.16: Specifically Applicable Requirements for the Truck RackPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.16.19VOCNWCAA OAC #527cCondition 8(12/12/01)NWCAA 580.423 and580.424 (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 suchthat all displaced volatile organic compoundsare vented to the vapor recovery system.Excludes emissions from pressure reliefvalves when the back pressure in thecollection lines is lower than the reliefpressure setting of the transport tank's reliefvalves.Perform biennial testing required by NWCAA 580.424 in accordance with 40CFR 60.503(b) and (d) (2/14/89) except areading of 500 ppm as required by 40CFR 63.425 (a)(1)(i) shall be used to determine the level of leaks to be repairedunder 40 CFR 60.503(b).Provide the NWCAA 30 days notice priorto testing (unless waived by theNWCAA) and submit the test results tothe NWCAA not less than 45 days aftertesting is completed.Follow 40 CFR 60.503 and 40 CFR 63.425(a)- directly enforceable -5.16.20VOCNWCAA 580.104 and580.1033 (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 gasolinevapor concentration is less than the lowerexplosive limit at a distance of 2.5 cm orgreater from any potential leak source; andliquid leaks must be less than 3 drops perminute and no more than 10 ml perdisconnect (4 drops per minute per WAC 173-491-040). Repair and retest a vapor collectionsystem that exceeds these limits within tendays (15 days per WAC 173-491-040).5.16.21VOCNWCAA OAC #527cCondition 11(12/12/01)NWCAA 580.426(12/13/89)All loading arms shall be designed,maintained and operatedto prevent overfill,fugitive liquid or vapor leaks, and excessgasoline drainage during disconnect.5.16.22VOCWAC 173-491-040(6)(b)(iii)(A)(1) and(b)(iii)(B) (12/23/97-state only)Transport tank pressure shall not exceed apressure of eighteen inches of water or avacuum of six inches of water. Repair andretest a vapor collection system that exceedsthis limit within fifteen days.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-131Table 5.16: Specifically Applicable Requirements for the Truck RackPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.16.23VOCWAC 173-491-040(2)(c)(iii) (12/23/97-state only)The backpressure in the vapor collectionsystem shall not exceedthe transport tank’spressure relief settings.5.16.24VOC/HAPNWCAA OAC #527cCondition 14(12/12/01)NWCAA 580.102,1031, 1032 & 1033(12/13/89) NWCAA580.105 (12/13/89)WAC 173-491-040(6)(b)(i ) and WAC173-491-040(6)(d)(12/23/97) (State only)WAC 173-491-030(4)(7/2/91) (State only)Gasoline transport tanks have to be leaktested annually. Ensure that gasoline isloaded only into cargo tanks that pass annualleak checks performed in accordance withTitle 40 CFR Appendix A Method 27 and thecriteria of NWCAA 580.105.Keep a copy of a valid leak tightness test certification for each cargotank loaded. In addition, maintain annual throughput records for theloading terminal.Follow EPA Method 27- directly enforceable -5.16.25VOCNWCAA OAC #527c(Condition 16(12/12/01)Maintain a record of all replacements andadditions of components performed on anexisting vapor processing systemKeep records of replacements and additions to components on theexisting vapor processing system onsite at the terminal available forinspection.- directly enforceable -5.16.26VOCNWCAA OAC #527cCondition 17(12/12/01)Calculate emissions from the truck rack on anannual basis.Report emissions from truck rack to NWCAA on an annual basis nolater than 105 days following the end of the calendar year.-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-132Table 5.16: Specifically Applicable Requirements for the Truck RackPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.16.27VOC/HAP40 CFR 63 Subpart CC63.650(a) (6/12/96)which references 40CFR 60.502(f) and (g)(2/12/99) and,60.502(e) (2/12/99)which is modified by 40CFR 63.422(c)40 CFR 63 Subpart CC63.650(a) (6/12/96)which references 40CFR 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 CC63.654(b) (8/18/98)which references 40CFR 63.428(b),63.428(g)(1) and63.428(h)(2)-(h)(3)(2/28/97)Loading of liquid product into gasoline tanktrucks shall be limited to vapor-tight gasolinetank trucks using the procedures specified at40 CFR 60.502(e) (as modified by 40 CFR63.422(c). Assure that loading of gasolinetank trucks is made only into tanks equippedwith vapor collection equipment that iscompatible with the terminal's vapor collectionsystem and that the terminal's and the tanktruck's vapor collection systems areconnected during each loading of a gasolinetank truck at the affected facility.Ensure that gasoline is loaded only into cargo tanks that pass annual leakchecks performed in accordance with the criteria of 40 CFR 63.425(e), (f), (g)and (h).Obtain the vapor tightness documentation described in 40 CFR 60.505(b) foreach gasoline tank truck loaded at the affected facility. Record the tankidentification number as each gasoline tank truck is loaded at the facility. Crosscheck each tank identification number with the file of tank vapor tightnessdocumentation within 2 weeks after the corresponding tank is loaded, unlesseither less than an average of one gasoline tank truck per month over the last26 weeks is loaded without vaportightness documentation then thedocumentation cross-check shall be performed each quarter; or less than anaverage of one gasoline tank truck per month over the last 52 weeks is loadedwithout vapor tightness documentation then the documentation cross-checkshall be performed semi-annually. Returnto biweekly crosschecks if theseconditions are not maintained. Notify the owner or operator of each non-vaportight gasoline tank truck loaded at theaffected facility within 1 week of thecrosscheck. Ensure that the nonvapor-tight gasoline cargo tank will not bereloaded until vapor tightness documentation is obtained.Maintain records in accordance with 40 CFR 63.428(b) of cargo tank annualcertification and continuousperformance testing. The records shall include thename of test, the tank owner's name and address, tank identification number,test location and date, tester name and signature, witnessing inspector, if any:name, signature, and affiliation, nature of repair work and when performed inrelation to vapor tightness testing. And test results. Include in a semi-annualreport to the NWCAA each loading of a cargo tank for which vapor tightnessdocumentation had not been previously obtained by the facility.Submit an excess emissions report to the NWCAA in accordance with 40 CFR63.10(e)(3), when a nonvapor-tight gasoline cargo tank is loaded and there wasa failure to take steps to assure that the cargo tank would not be reloadedbefore vapor tightness documentation was obtained. Also report each reloadingof a nonvapor-tight gasoline cargo tank before vapor tightness documentationfor is obtained in accordance with 40 CFR 63.422(c)(2).Follow 40 CFR 63.425(e), (f), (g) and (h)BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-133Table 5.16: Specifically Applicable Requirements for the Truck RackPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.16.28VOCWAC 173-491-040(6)(a) (12/23/97-state only)During the months of May, June, July,August, and September any failure of a vaporcollection system to comply with WAC 173-491-040 requires the discontinuation ofgasoline transfer operations for the failed partof the system.Record any periods during these months when the vapor collectionsystem failed and actions taken.- directly enforceable -5.16.29VOCWAC 173-491-040(6)(e) (12/23/97-state only)Take reasonable measures to prevent thespilling, discarding sewers, storing in opencontainers, or handling of gasoline in amanner that will result in evaporation to theambient air.Follow the MRR in this table.- directly enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-1345.16.3 Marine TerminalTable 5.16 - Specifically Applicable Requirements for the Marine TerminalPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingMarine TerminalComponents in HAP ServiceNote: 40 CFR 63 General Provisions included in Section 3 apply to these affected facilities.5.16.30HAP40 CFR 63 Subpart CC63.651(a) (8/18/95)which references 40CFR 63.560 –60.567(9/19/95) and63.653(c) (8/18/98)NWCAA OAC #716aCondition 6(5/3/02)Refinery MACT Equipment LeaksMonitor applicable components forfugitive leaks, repair leaks in a timelymanner and report monitoring resultssemi-annually in accordance with 40CFR 60 Subpart VVConduct an Equipment Leak program (LDAR) as specified in Section 6.2Follow 40 CFR 60 Appendix A Method 215.15.31VOCNWCAA OAC #716aCondition 1(5/3/02)40 CFR 63 Subpart CCwhich references63.562(a) & (b)(9/19/95)The dock shall be equipped with a vaporcollection system that is designed tocollect VOC vapors displaced frommarine terminal loading of all refinerylight products.Note: “light petroleum product” isdefined as products with vaporpressures greater than or equal to 1.5psia at standard conditions, 20 C and760 mmHg.Install vapor collection system and perform performance test per AOP Terms5.16.36 through 5.16.38.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-135Table 5.16 - Specifically Applicable Requirements for the Marine TerminalPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.16.32VOCNWCAA OAC #716aConditions 2 & 10(5/3/02)40 CFR 63 Subpart CCwhich references40 CFR 63.563(a)(2),63.567 (f)-(i), (k)(9/19/95)Marine tank vessel loading of lightrefinery products at the loadingterminals shall be limited to thosevessels equipped with vapor collectionequipment that is compatible with theterminal’s vapor collection system.Maintain onsite records ofvessel certificationsdemonstrating compatibilityfor 5-years.5.16.33VOC.NWCAA OAC #716aConditions 3 & 10(5/3/02)40 CFR 63 Subpart CCwhich references40 CFR 63.563(a)(4),63.567 (f)-(i),(k)(9/19/95)Marine tank vessel loading shall belimited to those vessels that are vaportight and connected to the vaporcollection system.Maintain onsite records of vessel certifications demonstrating vaportightness and loading only while connection to vapor collection system for 5-years.5.16.34VOCNWCAA OAC #716aConditions 5 & 10(5/3/02)LoadingLoading of light refinery products maybe performed at the dock withoutemission control for a period not toexceed 14 days on a rolling 12 monthaverage to allow for maintenance of thevapor collection and control equipment.Note: A “day” is defined is defined asany portion of a calendar day in whichloading of light petroleum product isperformed without emission control dueto maintenance of the vapor collectionor control equipment.Maintain records onsite for all maintenance performed on the air pollutioncontrol equipment. Records shall include date of maintenance activity,duration, other activities being performed at the north berthing terminal,cause of maintenance activity and corrective actions taken.-directly enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-136Table 5.16 - Specifically Applicable Requirements for the Marine TerminalPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingVapor Combustion ControlNote: The Title 40 CFR Parts 60 and 63 General Provisions included in Section 3 apply to these affected facilities.5.16.35SO2(H2S)40 CFR 60 Subpart J60.104(a)(1),60.105(a)(4), 60.105(e)(3)(ii)NWCAA OAC #716aCondition 11(5/3/02)NSPS Subpart J – Fuel GasFuel gas limited to a composition ofH2S<230 mg/dscm (0.10 gr/dscf).Equivalent to 162 ppm H2S, 3 hourrolling average.NOTE: The vapor combustor at theMarine Terminal is only supplied withpipeline grade natural gas as itssupplementary fuel.Use natural gas at vapor combustor to ensure that Subpart J H2Srequirement is not exceeded.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-137Table 5.16 - Specifically Applicable Requirements for the Marine TerminalPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.16.36VOC/ HAP40 CFR 63 Subpart CCwhich references40 CFR63.563(b)(4)(ii),63.564(e)(2) & (4),63.567 (f)-(k) (9/19/95)NWCAA OAC #716aConditions 8 & 10(5/3/02)OperationTemperature within the vaporcombustor (as measured at BP pointTT-35-261) shall not be below 50 F ofthe baseline temperature of 1400 F.Temperatures are to be taken nogreater than in 15-minute cycles with anaccuracy of +/-10 F.Temperature within the vapor combustor (as measured at BP point TT-35-261) shall not be below 50oF of the 1400oF. A data acquisition system shallrecord the temperature every 15 minutes and shall compute and record anaverage temperature each cycle.Install, calibrate, operate and maintain a temperature monitor with anaccuracy of +/- 10oF. Temperatures are to be taken at no greater than in 15-minute cycles The monitor shall be installed at the exhaust point of thecombustion device but not within the combustion zone. The accuracy of thetemperature monitor shall be verified once each calendar year with areference temperature monitor (traceable to the National Institute ofStandards and technology (NIST) standards or an independent temperaturemeasurement device dedicated for thispurpose) During the accuracychecking, the probe of the reference device shall be at the same location asthat of the temperature monitor being tested .Maintain records of vapor combustor temperature at TT-35-261 onsite for 5years.5.16.37VOC/ HAPNWCAA OAC #716aConditions 4, 8 & 10(5/3/02)40 CFR 63 Subpart CCwhich references40 CFR 63.563(a)(3),63.563(b)(1), 63.567(f)-(k) (9/19/95)OperationThermal oxidation of captured vaporsshall reduce VOC by 98% by weightCompliance with this term is demonstrated through AOP Term 5.16.37above.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-1385.16.4 LPG/LEU/Butane/Pentane LoadingTable 5.16: Specifically Applicable Requirements for the LPG/LEU LoadingPermitTermCitationDescriptionMonitoring/Recordkeeping/ReportingLPG/LEU Components in VOC ServiceNote: 40 CFR 60 General Provisions included in Section 3 apply to these affected facilities.5.16.38VOC40 CFR 60 SubpartGGG60.590-60.593(10/17/00) whichreferences 40 CFR60.480-60.489(12/14/00)NWCAA 580.8(3/13/97)NSPS Equipment LeaksMonitor applicable components for fugitiveleaks, repair leaks in a timely manner, andreport monitoring results semi-annually inaccordance with 40 CFR 60 Subpart VV.Applicable components include: pumps inliquid service, pressure relief valves ingas/liquid service, all sampling connectionsystems, all open-ended valves or lines,all valves in gas/vapor service or lightliquid service, all pumps and valves inheavy liquid service, pressure relief valvesin light liquid service, flanges and otherconnectors.Conduct an Equipment Leak program (LDAR) as specified in Section 6.2.Follow 40 CFR 60 Appendix A Method 21BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20065-1395.17 Non-Hazardous Waste LandfarmTable 5.17: Specifically Applicable Requirements for the Non-Hazardous Waste LandfarmPermitTermCitationDescriptionMonitoring/Recordkeeping/Reporting5.17.1VOCNWCAA NOC #382Condition 2(7/30/92)Estimate area emissions from landfarmingactivitiesReport emissions from landfarm on an annual basis as part of the emissionsinventory report.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-1SECTION 6 - SPECIFICALLY APPLICABLE COMMON REQUIREMENTSSection 6 of this AOP contains requirements that are common to various emission unitsat the source. Section 6.1 states themonitoring, recordkeeping and reporting requirements for visualemissions from combustion units at the refinery. Therequirements specified in Section 6.2 areapplicable to the applicable process unit components in VOC/HAP service as listed inSection 5 of the AOP. Section 6.3 is applicable to newly constructed process units that were required to meet enhancedmonitoring provisions included in their Orders of Approval to Construct (OAC).The requirements specified in the “Citation” column, and incorporated herein by reference, are federally enforceable unlessidentified as “state only”. “State only” requirements are not enforceable by EPA or citizensunder the CAA. The “Description”column is a brief description of the applicable requirements for informational purposes only and is not enforceable. Periodicorcontinuous monitoring requirements(including testing) are specified in the “Monitoring, Recordkeeping and Reporting” column,which identifies monitoring, recordkeepingand reporting (MR&R) obligations the source must perform as required by WAC 173-401-605(1) and 615(1) and (2) or the underlying requirement. MR&R obligations do not apply to insignificant emission units.The requirements in the MR&R column labeled “directly enforceable”are legally enforceablerequirements added under theNWCAA’s “gap-filling” authority. Other requirements not labeled “directly enforceable” are brief descriptions of the regulatoryrequirements for information purposes, and arenot enforceable. Unless the text of theMR&R column is specifically identifiedtobe directly enforceable, the language ofthe cited regulation takes precedence over a paraphrased requirement.The commonly referenced requirements are listed as follows.6.1Visual Emissions Monitoring6.2Equipment Leak Program (LDAR)6.3 Enhanced Leak Detection ProgramBP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-26.1 Visual Emissions MonitoringMonitoring recordkeeping and reporting for combustion units is as follows:Combustion units burning oil, visually observe stacks on a dailybasis to qualitatively assess whether emissions are visible.The frequencymay be reduced to weekly if no visible emissions are observed for thirty consecutive days. The permittee shall revert to dailyobservationsof individual stacks if any visible emissions are noted during the observation. Daily quantitative assessments are not requiredwhen oilburning is conducted for the purpose of testing or training and doesnot exceed four hours per calendar month, per emission unit.For combustion units burning gaseous fuels, visually observe stacks monthly to qualitatively assess whether emissions are visible. Thefrequency may be reduced to quarterly if no visible emissions are observed for six consecutive months. The permittee shall revert tomonthly 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 be reduced to zero, thepermittee may monitor by Ecology Method 9A no later than 24 hours after detection and daily thereafter until opacity is shown to be lessthan the applicable opacity standard. Otherwise visual emissions shall be considered in excess of the opacity standard.Record observation results for stacks with visible emissionsand any related equipment or operational failure, the occurrence dates andtimes, actions taken, and the type of fuel burned. Record that an observation was performed, with date, time, background conditions, andidentification of the observer. Keep records of all observations available for inspection.- Directly Enforceable -BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-36.2 Equipment Leak Program (LDAR)The BP Cherry Point Refinery is regulated under several fugitive emission MR&R requirements that together, comprise the LDAR for therefinery. These are 40 CFR 60.480 (NSPS Subpart VV), 40 CFR 60.590 (NSPS Subpart GGG), 40 CFR 61.110 (BenzeneSubpart J), 40 CFR 61.240 (NESHAP Subpart V), and 40 CFR 63.640 (NESHAP Subpart CC). In order to demonstrate compliance, theseregulations 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 the methodologies describedin 40 CFR 60.480 (NSPS Subpart VV) as allowed under 40 CFR 60.592 and 40 CFR 63.640(p) for the applicable existing sources. Thefollowing presents the LDAR MR&Rs as required under 40 CFR 60.480 (NSPS Subpart VV).6.2 - Commonly Referenced Monitoring Recordkeeping and Reporting RequirementsEquipment Leak Program (LDAR) for Following Units:Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hydrogen Plant, Calciners,Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving Areas)PermitTermCitationDescriptionMonitoring, Recordkeeping and ReportingNote: The Title 40 CFR Parts 60, 61 and 63 General Provisionsincluded in Section 3 apply to these affected facilities.6.2.1VOC/ HAP40 CFR 60Subpart VV60.482-2(a), (b),and (c)(12/14/00), 60.485(b) (10/17/00),60.486(b), (c) and(e) (12/14/00) and60.487(c), and (e)(10/17/00)40 CFR 63.648(a)which references40 CFR 60Subpart VV(8/18/98)Pumps in Light Liquid Service, Without Dual MechanicalSealsMonitor each applicable pump monthly to detect leaks.Visually inspect each calendar week.If an instrument reading of 10,000 ppm or greater ismeasured, a leak is detected.If there are indications ofliquids dripping from the pumpseal, a leak is detected.When a leak is detected, it shall be repaired as soon aspracticable, but not later than 15 calendar days after it isdetected, except as providedin 40 CFR 60.482-9. A firstattempt at repair shall be made no later than 5 calendardays after each leak is detected.When a leak is detected,a weatherproof and readilyvisible identification, marked with the equipmentidentification number, shall be attached.The identificationmay be removed after it has been repaired.Each calendar week, visually inspect each pump for indications of liquidsdripping from the pump seal.Monthly, instrument monitor using40 CFR Part 60 Method 21. Theinstrument shall be calibrated before use each day. The followingcalibration gases shall be used: Zero air (less than 10 ppm ofhydrocarbon in air); and a mixture ofmethane or n-hexane and air at aconcentration of about 10,000 ppm methane or n-hexane.When a leak is detected, record the information in required in 40 CFR60.486(c)For all equipment subject to this permit term, record in a log in a readilyaccessible location the information required in 40 CFR 60.486(e).Submit a semi-annual report including the appropriate items in 40 CFR60.487(c).Report the results of all performance tests in accordance with 60.8 of theGeneral Provisions.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-46.2 - Commonly Referenced Monitoring Recordkeeping and Reporting RequirementsEquipment Leak Program (LDAR) for Following Units:Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hydrogen Plant, Calciners,Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving Areas)PermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.2.2VOC/ HAP40 CFR 60Subpart VV60.482-2(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 references40 CFR 60Subpart VV(8/18/98)Applicable Pumps in Light Liquid Service, With DualMechanical Seals Including A Barrier Fluid SystemOperate the barrier fluid at a pressure that is at all timesgreater than the pump stuffing box pressure, or purge thebarrier fluid into a process stream with zero VOCemissions to the atmosphere.The barrier fluid system should be in heavy liquid serviceor not in VOC service.Equip each barrier fluid system with a sensor that willdetect failure of the seal system, the barrier fluid system,or both. Check each sensor daily or equip the sensor withan audible alarm. Determine, based on designconsiderations and operating experience, a criterion thatindicates failure of the seal system, the barrier fluidsystem, or both.If there are indications of liquids dripping from the pumpseal, or the sensor indicates failure of the seal system, thebarrier fluid system, or both, a leak is detected. Repair aleak as soon as practicable, but not later than 15 calendardays after it is detected,except as provided in 40 CFR60.482-9. A first attempt at repair shall be made no laterthan 5 calendar days after each leak is detected.When a leak is detected,a weatherproof and readilyvisible identification, marked with the equipmentidentification number,shall be attached.Each calendar week, visually inspect each pump for indications of liquidsdripping from the pump seal.When a leak is detected, record the information required in 40 CFR60.486(c).If the sensor is not equipped with an audible alarm, check sensor daily.For all equipment subject to this permit term, record in a log in a readilyaccessible location the information required in 40 CFR 60.486(e).The design criterion required must berecorded in a log and kept readilyaccessible. An explanation of the design criterion and any changes to thecriterion ( and reasons for the changes) must be kept as well.Submit a semi-annual report including the appropriate items in 40 CFR60.487(c).Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-56.2 - Commonly Referenced Monitoring Recordkeeping and Reporting RequirementsEquipment Leak Program (LDAR) for Following Units:Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hydrogen Plant, Calciners,Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving Areas)PermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.2.3VOC/ HAP40 CFR 60Subpart VV60.482-3(12/14/00), and60.486(b), (c), (e)and (h)(12/14/00), and60.487(c), and (e)(10/17/00)40 CFR 63.648(a)which references40 CFR 60Subpart VV(8/18/98)CompressorsEquip each applicable compressor with a seal system thatincludes a barrier fluid system and that prevents leakageof VOC to the atmosphere. Operate the seal system witha barrier fluid at a pressure that is greater than thecompressor stuffing box pressure, or, purge the barrierfluid into a process stream with zero VOC emissions tothe atmosphere. The barrier fluid system shall be inheavy liquid service or shall not be in VOC service.Equip each barrier fluid system with a sensor that willdetect failure of the seal system, the barrier fluid system,or both.Check each sensor daily or equip the sensor with anaudible alarm. Determine, based on designconsiderations and operating experience, a criterion thatindicates failure of the seal system, the barrier fluidsystem, or both.If the sensor indicates failure of the seal system, thebarrier fluid system, or both, a leak is detected. When aleak is detected, a weatherproof and readily visibleidentification, marked with the equipment identificationnumber, shall be attached. The identification may beremoved after it has been repaired. When a leak isdetected, it shall be repairedas soon as practicable, butnot later than 15 calendar days after it is detected, exceptas provided in 40 CFR 60.482-9. A first attempt at repairshall be made no later than 5 calendar days after eachleak is detected.When a leak is detected, record the information required in 40 CFR60.486(c).For all equipment subject to this permit term, record in a log in a readilyaccessible location the information required in 40 CFR 60.486(e)The design criterion must be recorded in a log and kept readilyaccessible. An explanation of the design criterion and any changes to thecriterion (and reasons for the changes) must be kept as well.Submit a semi-annual report including the appropriate items in 40 CFR60.487(c).If the sensor is not equipped with an audible alarm, check sensor daily.Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-66.2 - Commonly Referenced Monitoring Recordkeeping and Reporting RequirementsEquipment Leak Program (LDAR) for Following Units:Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hydrogen Plant, Calciners,Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving Areas)PermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.2.4VOC/ HAP40 CFR 60Subpart VV60.482-4(12/14/00), 60.485(c) (10/17/00),60.486( d) and (e)(12/14/00), and60.487(c) and (e)(10/17/00)40 CFR 63.648(a)which references40 CFR 60Subpart VV(8/18/98)Pressure Relief DevicesExcept during pressure releases, each applicablepressure relief device in gas/vapor service shall beoperated with no detectable emissions, as indicated by aninstrument reading of less than 500 ppm abovebackground. After each pressure release, the pressurerelief device shall be returned to a condition of nodetectable emissions as soon as practicable, but no laterthan 5 calendar days after the pressure release, except asprovided in 40 CFR 60.482-9.Any pressure relief device routed to the fuel gas system orequipped with a closed vent system a control device isexempt from this requirement.Any pressure relief device equipped with a rupture diskupstream of the pressure relief device is exempt from thisrequirement, provided that after each release a newrupture disk is installed as soon as practicable, but nolater than 5 calendar days after each pressure release,except as provided in 40 CFR 60.482-9.For pressure relief devices not routed to the fuel gas system or a closedvent system/control device, and without a rupture disk, if a release occurs,monitor the pressure relief device no later than 5 calendar days after therelease.For pressure relief devices required to comply with this condition, record alist of equipment identification numbersin a log in a readily accessiblelocation. Also recordthe date of each compliance test, the backgroundlevel measured during the compliance test, and the maximum instrumentreading.Submit a semi-annual report with the facts explaining each delay of repairas per 40 CFR 60.482-9, and the datesof process unit shutdowns whichoccurred within the semi-annual reporting period.Report the results of all performance tests in accordance with 40 CFR60.8 of the General Provisions.The instrument used to monitor leaks shall be calibrated before use eachday of use. The following calibration gases shall be used: Zero air (lessthan 10 ppm of hydrocarbon in air);and a mixture of methane or n-hexaneand air at a concentration of about10,000 ppm methane or n-hexane.Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-76.2 - Commonly Referenced Monitoring Recordkeeping and Reporting RequirementsEquipment Leak Program (LDAR) for Following Units:Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hydrogen Plant, Calciners,Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving Areas)PermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.2.5VOC/ HAP40 CFR 60Subpart VV60.482-5(12/14/00) and60.486(e)(12/14/00)40 CFR 63.648(a)which references40 CFR 60Subpart VV(8/18/98)Sampling Connection SystemsEach applicable sampling connection system shall beequipped with a closed-purged, closed-loop, or closedvent system (except for in situ sampling systems andsampling systems without purges). Gases displacedduring sample container filling are not required to becollected or captured.The purged process fluid must be returned directly to theprocess line; or collected and recycled to a process; or,transported to a control device that complies with therequirements of 60.482-10, or collected and transported toa waste management unit subject to 40 CFR Part 63Subpart G, or a treatment, storage, or disposal facilitysubmit to 40 CFR part 262, 264, 265, or 266, or a facilitypermitted, licensed, or registered by a State to managemunicipal or industrial solid waste, if the process fluids arenot hazardous waste.The permittee shall maintain a list ofidentification numbers for equipmentsubject to the requirements of this condition.Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-86.2 - Commonly Referenced Monitoring Recordkeeping and Reporting RequirementsEquipment Leak Program (LDAR) for Following Units:Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hydrogen Plant, Calciners,Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving Areas)PermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.2.6VOC/ HAP40 CFR 60Subpart VV60.482-6(12/14/00), and60.486(e)(12/14/00)40 CFR 63.648(a)which references40 CFR 60Subpart VV(8/18/98)Open-ended Valves or LinesEach applicable open-ended valve or line shall beequipped with a cap, blind flange, plug, or a second valvethat seals the open end at all times except duringoperations requiring process fluid flow.Each open-ended valve or line equipped with a secondvalve shall be operated in a manner such that the valveon the process fluid end is closed before the second valveis closed.When a double block-and-bleed system is being used, thebleed valve or line may remain open during operationsthat require venting the linebetween the block valves, butshall remain closed at other times.Open-ended valves or lines in an emergency shutdownsystem which are designed to open automatically in theevent of a process upset are exempt. Likewise, openended valves or lines containing materials which wouldpolymerize or would present an explosion, seriousoverpressure, or other safety hazard if capped orequipped with a double block and bleed system isexempt.For all equipment subject to this permit term, record in a log in a readilyaccessible location a list of identification numbers for equipment subject tothe requirements of this condition.Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-96.2 - Commonly Referenced Monitoring Recordkeeping and Reporting RequirementsEquipment Leak Program (LDAR) for Following Units:Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hydrogen Plant, Calciners,Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving Areas)PermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.2.7VOC/ HAP40 CFR 60Subpart VV60.482-8(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 LiquidService, and Flanges and Other ConnectorsIf evidence of a potential leak is found by visual, audible,olfactory, or any other detection method, either monitorwithin 5 days or eliminate thevisual, audible, olfactory, orother indication of potential leak. If an instrument readingof 10,000 ppm or greater is measured, a leak is detected.When a leak is detected, it shall be repaired as soon aspracticable, but not later than 15 calendar days after it isdetected, except as provided in 40 CFR 60.482-9. Thefirst attempt at repair shall be made no later than 5calendar days after each detected leak. First attempts atrepair include, but are notlimited to, (1) tightening ofbonnet bolts, (2) replacement of bonnet bolts, (3)tightening of packing gland nuts; and (4) injection oflubricant into lubricated packing.When a leak is detected,a weatherproof and readilyvisible identification, marked with the equipmentidentification number, shall be attached.The identificationmay be removed after it has been repaired.When a leak is detected, record the information required in 40 CFR60.486(c). For all equipment subject tothis permit term, record in a log ina readily accessible location a list ofidentification numbers for equipmentsubject to this requirement..The instrument used to monitor for leaks shall be calibrated before useeach day of use. The following calibration gases shall be used: Zero air(less than 10 ppm of hydrocarbon in air); and a mixture of methane or nhexane and air at a concentration ofabout 10,000 ppm methane or nhexane.Submit a semi-annual report with the facts explaining each delay of repairas per 40 CFR 60.482-9, and the datesof process unit shutdowns whichoccurred within the semi-annual reporting period.Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-106.2 - Commonly Referenced Monitoring Recordkeeping and Reporting RequirementsEquipment Leak Program (LDAR) for Following Units:Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hydrogen Plant, Calciners,Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving Areas)PermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.2.8VOC/ HAP40 CFR 60Subpart VV60.482-9(12/14/00) and60.487(c)(vii)(10/17/00)40 CFR 63.648(a)which references40 CFR 60Subpart VV(8/18/98)Delay of RepairDelay of repair of applicable equipment for which leakshave been detected will be allowed if repair within 15 daysis technically infeasible without a process unit shutdown.Repair shall occur before the end of the next process unitshutdown. Delay is also allowed for equipment isolatedfrom the process and which does not remain in VOCservice.Valves: Delay of repair will be allowed if (1) it isdemonstrated that purged material resulting fromimmediate repair are greaterthan the fugitive emissionslikely to result from delay of repair, and (2) when repairprocedures are effected, the purged material is collectedand destroyed or recovered in a control device complyingwith 40 CFR 60.482-10. Delay of repair beyond aprocess unit shutdown will be allowed if valve assemblyreplacement is necessary, valve assembly supplies havebeen depleted, and supplies had been sufficiently stockedbefore they were depleted. Delay of repair beyond thenext process unit shutdownwill not be allowed unless thenext process unit shutdownoccurs sooner than 6 monthsafter the first process unit shutdown.Pumps: Delay of repair will be allowed if (1) repairrequires the use of a dual mechanical seal system thatincludes a barrier fluid system, and (2) repair is completedas soon as practicable, but not later than 6 months afterthe leak was detected.Report, in a semi-annual report, the facts that explain each delay of repairand, where appropriate, why a process unit shutdown was technicallyinfeasible.Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-116.2 - Commonly Referenced Monitoring Recordkeeping and Reporting RequirementsEquipment Leak Program (LDAR) for Following Units:Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hydrogen Plant, Calciners,Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving Areas)PermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.2.9VOC/ HAP40 CFR 60Subpart VV60.482-7(12/14/00),60.483-2(12/14/00),60.486(e)(12/14/00), and60.487(c), (d) and(e) (10/17/00)40 CFR 63.648(a)which references40 CFR 60Subpart VV(8/18/98)Standards for Valves in Gas and Light Liquid Service andAlternative Standards for Valves – Skip Period LeakDetection and RepairMonitor 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 readingof 10,000 ppm or greater.)BP shall make a “first attempt” at repair for any valve aftereach leak is detected according to the provisions in 40CFR 60.482-7 (d)(2).When a leak is detected, it shall be repaired as soon aspracticable, but not later than 15 calendar days after it isdetected, except as provided in 40 CFR 60.482-9.The first attempt at repair shall be made no later than 5calendar days after each detected leak. First attempts atrepair include, but are notlimited to, (1) Tightening ofbonnet bolts, (2) Replacement of bonnet bolts, (3)Tightening of packing gland nuts; and (4) Injection oflubricant into lubricated packing.Instrument monitor valves on a monthly schedule in accordance with 40CFR 60.482-7.A. The facility may elect to follow a less frequent monitoring scheduleusing the criteria:1) At process units that have less than 2% leaking valves for 2consecutive months, monitor each valve once every quarter,beginning with the next quarter.2) After 2 consecutive quarterlyleak detection periods with thepercent leaking less than or equal to 2%, monitor each valveonce every 2 quarters.3) After 5 consecutive semi-annual leak detection periods with thepercent of valves leaking is less than or equal to 2.0%, monitoreach valve once every 4 quarters.B. Facility must return to a more frequent monitoring schedule using thefollowing criteria:1) If a process unit on a quarterly, semi-annual or annual schedulehas a leak percentage greater than or equal to 2% in any singledetection period, monitor valvesevery month until again meetingthe criteria listed in A. above.The leak percentage shall be determined bydividing the number of valvesfor which leaks are detected by the number of valves in gas/vapor andlight liquid service within the affected facility.The instrument shall be calibrated before use each day of use by Method21. The following calibration gases shall be used: Zero air (less than 10ppm of hydrocarbon in air); and a mixture of methane or n-hexane and airat a concentration of about 10,000 ppm methane or n-hexane.For all equipment subject to this permit term, record in a log in a readilyaccessible location the information required in 60.486(e).Submit a semi-annual report includingthe appropriate items in 60.487(c)and report the results of all performance tests in accordance with 60.8 ofthe General Provisions.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-126.2 - Commonly Referenced Monitoring Recordkeeping and Reporting RequirementsEquipment Leak Program (LDAR) for Following Units:Crude/Vacuum Unit, #1 Reformer, #2 Reformer and Naphtha HDS, Delayed Coker, #1 DHDS, Hydrocracker, Hydrogen Plant, Calciners,Utility Boilers, Sulfur Complex, Wastewater Plant, and Shipping, Pumping and Receiving Areas)PermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.2.10VOC/ HAP40 CFR 60Subpart VV60.485(d)(10/17/00) and60.486(j)(12/14/00)40 CFR 63.648(a)which references40 CFR 60Subpart VV(8/18/98)Process Units Not in VOC ServiceEach piece of equipment shall be tested unless the owneror operator demonstrates thata process unit is not inVOC service, i.e., that theVOC content would never bereasonably expected to exceed 10 % by weight.To demonstrate that a process unit is notin VOC service, either follow (1)procedures that conform to the general methods in ASTM E-260, E-68, E69 (incorporated by reference in 40CFR 60.7), or, (2) demonstrate thatthe organic compoundsare considered by the EPA to have negligiblephotochemical reactivity, or, (3) use engineering judgment to estimate theVOC content, if a piece of equipmenthas not been shown previously tobe in service.Information and data used to demonstrate that a piece of equipment is notin VOC service shall be recorded ina log that is kept in a readilyaccessible location.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-136.3 Enhanced Equipment Leak Program (Enhanced LDAR)6.3a New Processing Units Subject to Enhanced LDARTable 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requirements -Enhanced Equipment Leak Program (Enhanced LDAR) for the following Units:Isomerization Unit, #2 DHDS UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.3.1VOC/HAP40 CFR 60 SubpartVV 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) and60.487(c),and (e)(10/17/00)as modified byOAC #814aCondition 6 issued3/24/04 for theIsomerization Unitand by OAC #892Condition 6 issued3/3/05 for the #2Diesel HDU.Enhanced Standards for Pumps in Light LiquidService on the Hydrocracker (for the incrementalVGO Project) and the #2 DHDUMonitor each pump no less frequently than quarterlyto detect leaks. Visually inspect each calendarweek.If an instrument reading of 2,000 ppm or greater ismeasured, a leak is detected. If there areindications of liquids dripping from the pump seal, aleak is detected.If a pump is a leak is detected at a level between2000 ppm and 10,000 ppm , it shall be repaired andre-monitored within 30 calendar days after it isdetected.If a leak greater than 10,000 ppm is detected, followprovisions detailed in Subpart VV.When a leak is detected, a weatherproof and readilyvisible identification, marked with the equipmentidentification number, shall be attached. Theidentification may be removed after it has beenrepaired.Instrument monitor valves in accordance with 60.482-7 asmodified by the associated OAC.Each calendar week, visually inspect each pump for indications ofliquids dripping from the pump seal.Monthly, instrument monitor using 40 CFR Part 60 Method 21.The instrument shall be calibrated before use each day. Thefollowing calibration gases shall be used: Zero air (less than 10ppm of hydrocarbon in air); and amixture of methane or n-hexaneand air at a concentration of about, but not less than, 10,000 ppmmethane or n-hexane.When a leak is detected, record the information required in60.486(c).For all equipment subject to this permit term, record in a log in areadily accessible location the information required in 60.486(e).Submit a semi-annual report including the appropriate items in60.487(c).Report the results of all performance tests in accordance with 60.8of the General Provisions.-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-14Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requirements -Enhanced Equipment Leak Program (Enhanced LDAR) for the following Units:Isomerization Unit, #2 DHDS UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.3.2VOC/HAP40 CFR 60 SubpartVV 60.482-7(12/14/00), 60.483-2 (12/14/00),60.486(e)(12/14/00), and60.487(c) (d) and(e) (10/17/00)as modified byOAC #814aCondition 6 issued3/24/04 for theIsomerization Unitand by OAC #892Condition 6 issued3/3/05 for the #2Diesel HDU.Enhanced Standards for Block Valves and ControlValves on the Isomerization Unit, the HydrocrackerUnit (for the Incremental VGO Project), the #2DHDUand the #1 DHDUIf an instrument reading of 500 ppm or greater ismeasured, a leak is detected.Monitor valves no less frequently than quarterly todetect leaks.When a leak is detected at a level between 500 ppmand 10,000 ppm, it shall be repaired and remonitored within 30 calendar days after it isdetected.If a leak greater than 10,000 ppm is detected, followprovisions detailed in Subpart VV.First attempts at repair include, but are not limitedto: (1) tightening of bonnet bolts, (2) replacement ofbonnet bolts, (3) tightening of packing gland nuts;and (4) injection of lubricant into lubricated packing.Instrument monitor valves in accordance with §60.482-7 asmodified by the associated OAC.The instrument shall be calibrated before use each day of use byMethod 21. The following calibration gases shall be used: Zeroair (less than 10 ppm of hydrocarbon in air); and a mixture ofmethane or n-hexane and air at a concentration of approximately500 ppm methane or n-hexane.For all equipment subject to this permit term, record in a log in areadily accessible location the information required in 60.486(e).Submit a semi-annual report including the appropriate items in60.487(c).Report the results of all performance tests in accordance with 60.8of the General Provisions.-directly enforceable-BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-15Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requirements -Enhanced Equipment Leak Program (Enhanced LDAR) for the following Units:Isomerization Unit, #2 DHDS UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.3.3VOC/HAP40 CFR 60 SubpartVV 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) and60.487(c), and (e)(10/17/00)40 CFR 63.648(a)which references40 CFR 60 SubpartVV (8/18/98)Pumps in Light Liquid Service, Without DualMechanical SealsMonitor each applicable pump monthly to detectleaks. Visually inspect each calendar week.If an instrument reading of 10,000 ppm or greater ismeasured, a leak is detected. If there areindications of liquids dripping from the pump seal, aleak is detected.When a leak is detected, it shall be repaired as soonas practicable, but not later than 15 calendar daysafter it is detected, except as provided in 40 CFR60.482-9. A first attempt at repair shall be made nolater than 5 calendar days after each leak isdetected.When a leak is detected, a weatherproof and readilyvisible identification, marked with the equipmentidentification number, shall be attached. Theidentification may be removed after it has beenrepaired.Each calendar week, visually inspect each pump for indications ofliquids dripping from the pump seal.Monthly, instrument monitor using 40 CFR Part 60 Method 21.The instrument shall be calibrated before use each day. Thefollowing calibration gases shall be used: Zero air (less than 10ppm of hydrocarbon in air); and amixture of methane or n-hexaneand air at a concentration of about 10,000 ppm methane or nhexane.When a leak is detected, record the information in required in 40CFR 60.486(c)For all equipment subject to this permit term, record in a log in areadily accessible location the information required in 40 CFR60.486(e).Submit a semi-annual report including the appropriate items in 40CFR 60.487(c).Report the results of all performance tests in accordance with 60.8of the General Provisions.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-16Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requirements -Enhanced Equipment Leak Program (Enhanced LDAR) for the following Units:Isomerization Unit, #2 DHDS UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.3.4VOC/HAP40 CFR 60 SubpartVV 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 references40 CFR 60 SubpartVV (8/18/98)Applicable Pumps in Light Liquid Service, With DualMechanical Seals Including A Barrier Fluid SystemOperate the barrier fluid at a pressure that is at alltimes greater than the pump stuffing box pressure,or purge the barrier fluid into a process stream withzero VOC emissions to the atmosphere.The barrier fluid system should be in heavy liquidservice or not in VOC service.Equip each barrier fluid system with a sensor thatwill detect failure of the seal system, the barrier fluidsystem, or both. Check each sensor daily or equipthe sensor with an audible alarm. Determine, basedon 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 thepump seal, or the sensor indicates failure of the sealsystem, the barrier fluid system, or both, a leak isdetected. Repair a leak as soon as practicable, butnot later than 15 calendar days after it is detected,except as provided in 40 CFR 60.482-9. A firstattempt at repair shall be made no later than 5calendar days after each leak is detected.When a leak is detected, a weatherproof and readilyvisible identification, marked with the equipmentidentification number, shall be attached.Each calendar week, visually inspect each pump for indications ofliquids dripping from the pump seal.When a leak is detected, record the information required in 40CFR 60.486(c).If the sensor is not equipped with an audible alarm, check sensordaily.For all equipment subject to this permit term, record in a log in areadily accessible location the information required in 40 CFR60.486(e).The design criterion required must be recorded in a log and keptreadily accessible. An explanation of the design criterion and anychanges to the criterion ( and reasons for the changes) must bekept as well.Submit a semi-annual report including the appropriate items in 40CFR 60.487(c).Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-17Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requirements -Enhanced Equipment Leak Program (Enhanced LDAR) for the following Units:Isomerization Unit, #2 DHDS UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.3.5VOC/HAP40 CFR 60 SubpartVV 60.482-3(12/14/00), and60.486(b), (c), (e)and (h) (12/14/00),and 60.487(c), and(e) (10/17/00)40 CFR 63.648(a)which references40 CFR 60 SubpartVV (8/18/98)CompressorsEquip each applicable compressor with a sealsystem that includes a barrier fluid system and thatprevents leakage of VOC to the atmosphere.Operate the seal system with a barrier fluid at apressure that is greater than the compressor stuffingbox pressure, or, purge the barrier fluid into aprocess stream with zero VOC emissions to theatmosphere. The barrier fluid system shall be inheavy liquid service or shall not be in VOC service.Equip each barrier fluid system with a sensor thatwill detect failure of the seal system, the barrier fluidsystem, or both.Check each sensor daily or equip the sensor with anaudible alarm. Determine, based on designconsiderations and operating experience, a criterionthat indicates failure of the seal system, the barrierfluid system, or both.If the sensor indicates failure of the seal system, thebarrier fluid system, or both, a leak is detected.When a leak is detected, a weatherproof and readilyvisible identification, marked with the equipmentidentification number, shall be attached. Theidentification may be removed after it has beenrepaired. When a leak is detected, it shall berepaired as soon as practicable, but not later than15 calendar days after it is detected, except asprovided in 40 CFR 60.482-9. A first attempt atrepair shall be made no later than 5 calendar daysafter each leak is detected.When a leak is detected, record the information required in 40CFR 60.486(c).For all equipment subject to this permit term, record in a log in areadily accessible location the information required in 40 CFR60.486(e)The design criterion must be recorded in a log and kept readilyaccessible. An explanation ofthe design criterion and anychanges to the criterion (and reasons for the changes) must bekept as well.Submit a semi-annual report including the appropriate items in 40CFR 60.487(c).If the sensor is not equipped with an audible alarm, check sensordaily.Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-18Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requirements -Enhanced Equipment Leak Program (Enhanced LDAR) for the following Units:Isomerization Unit, #2 DHDS UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.3.6VOC/HAP40 CFR 60 SubpartVV 60.482-4(12/14/00), 60.485(c) (10/17/00),60.486( d) and (e)(12/14/00), and60.487(c) and (e)(10/17/00)40 CFR 63.648(a)which references40 CFR 60 SubpartVV (8/18/98)Pressure Relief DevicesExcept during pressure releases, each applicablepressure relief device in gas/vapor service shall beoperated with no detectable emissions, as indicatedby an instrument reading of less than 500 ppmabove background. After each pressure release,the pressure relief device shall be returned to acondition of no detectable emissions as soon aspracticable, but no later than 5 calendar days afterthe pressure release, except as provided in 40 CFR60.482-9.Any pressure relief device routed to the fuel gassystem or equipped with a closed vent system acontrol device is exempt from this requirement.Any pressure relief device equipped with a rupturedisk upstream of the pressure relief device isexempt from this requirement, provided that aftereach release a new rupture disk is installed as soonas practicable, but no later than 5 calendar daysafter each pressure release, except as provided in40 CFR 60.482-9.For pressure relief devices not routed to the fuel gas system or aclosed vent system/control device,and without a rupture disk, if arelease occurs, monitor the pressure relief device no later than 5calendar days after the release.For pressure relief devices required to comply with this condition,record a list of equipment identification numbers in a log in areadily accessible location. Also record the date of eachcompliance test, the background level measured during thecompliance test, and the maximum instrument reading.Submit a semi-annual report withthe facts explaining each delayof repair as per 40 CFR 60.482-9,and the dates of process unitshutdowns which occurred within the semi-annual reportingperiod.Report the results of all performance tests in accordance with 40CFR 60.8 of the General Provisions.The instrument used to monitor leaks shall be calibrated beforeuse each day of use. The following calibration gases shall beused: Zero air (less than 10 ppm of hydrocarbon in air); and amixture of methane or n-hexane and air at a concentration ofabout 10,000 ppm methane or n-hexane.Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-19Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requirements -Enhanced Equipment Leak Program (Enhanced LDAR) for the following Units:Isomerization Unit, #2 DHDS UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.3.7VOC/HAP40 CFR 60 SubpartVV 60.482-5(12/14/00) and60.486(e)(12/14/00)40 CFR 63.648(a)which references40 CFR 60 SubpartVV (8/18/98)Sampling Connection SystemsEach applicable sampling connection system shallbe equipped with a closed-purged, closed-loop, orclosed-vent system (except for in situ samplingsystems and sampling systems without purges).Gases displaced during sample container filling arenot required to be collected or captured.The purged process fluid must be returned directlyto the process line; or collected and recycled to aprocess; or, transported to a control device thatcomplies with the requirements of 60.482-10, orcollected and transported to a waste managementunit subject to 40 CFR Part 63 Subpart G, or atreatment, storage, or disposal facility submit to 40CFR part 262, 264, 265, or 266, or a facilitypermitted, licensed, or registered by a State tomanage municipal or industrial solid waste, if theprocess fluids are not hazardous waste.The permittee shall maintain a list of identification numbers forequipment subject to the requirements of this condition.Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-20Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requirements -Enhanced Equipment Leak Program (Enhanced LDAR) for the following Units:Isomerization Unit, #2 DHDS UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.3.8VOC/HAP40 CFR 60 SubpartVV 60.482-6(12/14/00), and60.486(e)(12/14/00)40 CFR 63.648(a)which references40 CFR 60 SubpartVV (8/18/98)Open-ended Valves or LinesEach applicable open-ended valve or line shall beequipped with a cap, blind flange, plug, or a secondvalve that seals the open end at all times exceptduring operations requiring process fluid flow.Each open-ended valve or line equipped with asecond valve shall be operated in a manner suchthat the valve on the process fluid end is closedbefore the second valve is closed.When a double block-and-bleed system is beingused, the bleed valve or line may remain openduring operations that require venting the linebetween the block valves, but shall remain closed atother times.Open-ended valves or lines in an emergencyshutdown system which are designed to openautomatically in the eventof a process upset areexempt. Likewise, open-ended valves or linescontaining materials which would polymerize orwould present an explosion, serious overpressure,or other safety hazard if capped or equipped with adouble block and bleed system is exempt.For all equipment subject to this permit term, record in a log in areadily accessible location a list of identification numbers forequipment subject to the requirements of this condition.Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-21Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requirements -Enhanced Equipment Leak Program (Enhanced LDAR) for the following Units:Isomerization Unit, #2 DHDS UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.3.9VOC/HAP40 CFR 60 SubpartVV 60.482-8(12/14/00),60.485(b)(10/17/00),60.486(b), (c) and(e) (12/14/00), and60.487(c)(10/17/00)Applicable Pumps and Valves in Heavy LiquidService, Pressure Relief Devices in Light Liquid orHeavy Liquid Service, and Flanges and OtherConnectorsIf 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 potentialleak. If an instrument reading of 10,000 ppm orgreater is measured, a leak is detected.When a leak is detected, it shall be repaired as soonas practicable, but not later than 15 calendar daysafter it is detected, except as provided in 40 CFR60.482-9. The first attempt at repair shall be madeno later than 5 calendar days after each detectedleak. First attempts at repair include, but are notlimited to, (1) tightening of bonnet bolts, (2)replacement of bonnet bolts, (3) tightening ofpacking gland nuts; and (4) injection of lubricant intolubricated packing.When a leak is detected, a weatherproof and readilyvisible identification, marked with the equipmentidentification number, shall be attached. Theidentification may be removed after it has beenrepaired.When a leak is detected, record the information required in 40CFR 60.486(c). For all equipmentsubject to this permit term,record in a log in a readily accessible location a list of identificationnumbers for equipment subject to this requirement..The instrument used to monitor for leaks shall be calibrated beforeuse each day of use. The following calibration gases shall beused: Zero air (less than 10 ppm of hydrocarbon in air); and amixture of methane or n-hexane and air at a concentration ofabout 10,000 ppm methane or n-hexane.Submit a semi-annual report withthe facts explaining each delayof repair as per 40 CFR 60.482-9,and the dates of process unitshutdowns which occurred within the semi-annual reportingperiod.Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-22Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requirements -Enhanced Equipment Leak Program (Enhanced LDAR) for the following Units:Isomerization Unit, #2 DHDS UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.3.10VOC/HAP40 CFR 60 SubpartVV 60.482-9(12/14/00) and60.487(c)(vii)(10/17/00)40 CFR 63.648(a)which references40 CFR 60 SubpartVV (8/18/98)Delay of RepairDelay of repair of applicable equipment for whichleaks have been detected will be allowed if repairwithin 15 days is technically infeasible without aprocess unit shutdown. Repair shall occur beforethe end of the next process unit shutdown. Delay isalso allowed for equipment isolated from theprocess and which does not remain in VOC service.Valves: Delay of repair will be allowed if (1) it isdemonstrated that purged material resulting fromimmediate repair are greater than the fugitiveemissions likely to resultfrom delay of repair, and(2) when repair procedures are effected, the purgedmaterial is collected and destroyed or recovered in acontrol device complying with 40 CFR 60.482-10.Delay of repair beyond a process unit shutdown willbe allowed if valve assembly replacement isnecessary, valve assembly supplies have beendepleted, and supplies had been sufficiently stockedbefore they were depleted. Delay of repair beyondthe next process unit shutdown will not be allowedunless the next process unit shutdown occurssooner than 6 months after the first process unitshutdown.Pumps: Delay of repair will be allowed if (1) repairrequires the use of a dual mechanical seal systemthat includes a barrier fluid system, and (2) repair iscompleted as soon as practicable, but not later than6 months after the leak was detected.Report, in a semi-annual report, the facts that explain each delayof repair and, where appropriate, why a process unit shutdownwas technically infeasible.Use 40 CFR Part 60 Method 21.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-23Table 6.3a - Commonly Referenced Monitoring Recordkeeping and Reporting Requirements -Enhanced Equipment Leak Program (Enhanced LDAR) for the following Units:Isomerization Unit, #2 DHDS UnitPermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.3.11VOC/HAP40 CFR 60 SubpartVV 60.485(d)(10/17/00) and60.486(j) (12/14/00)40 CFR 63.648(a)which references40 CFR 60 SubpartVV (8/18/98)Process Units Not in VOC ServiceEach piece of equipment shall be tested unless theowner or operator demonstrates that a process unitis not in VOC service, i.e., that the VOC contentwould never be reasonably expected to exceed 10% by weight.To demonstrate that a process unit is not in VOC service, eitherfollow (1) procedures that conform to the general methods inASTM E-260, E-68, E-69 (incorporated by reference in 40 CFR60.7), or, (2) demonstrate that the organic compounds areconsidered by the EPA to have negligible photochemical reactivity,or, (3) use engineering judgment to estimate the VOC content, if apiece of equipment has not been shown previously to be inservice.Information and data used to demonstrate that a piece ofequipment is not in VOC service shall be recorded in a log that iskept in a readily accessible location.BP Cherry Point Refinery, Air Operating Permit #015Modification 1 – September 06, 20066-246.3 Enhanced Equipment Leak Program (Enhanced LDAR) - continuedTable 6.3b - Valves on Selected Portions of Operating Units Subject to Enhanced LDARTable 6.3b - Commonly Referenced Monitoring Recordkeeping and Reporting Requirements -Enhanced Equipment Leak Program (Enhanced LDAR) for Valves in the following units:#1 DHDS (Heater Reliability Project), Hydrocracker Unit (Incremental VGO Project)PermitTermCitationDescriptionMonitoring, Recordkeeping and Reporting6.3.12VOC/HAP40 CFR 60 SubpartVV 60.482-7(12/14/00), 60.483-2 (12/14/00),60.486(e)(12/14/00), and60.487(c) (d) and(e) (10/17/00)as modified byOAC #850Condition 1 issued12/1/03 for theIncremental VGOProject, and byOAC #949Condition 9 issued3/3/06 for the #1Diesel HDU.Enhanced Standards for Block Valves and ControlValves 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 ismeasured, a leak is detected.Monitor valves no less frequently than quarterly todetect leaks.When a leak is detected at a level between 500 ppmand 10,000 ppm, it shall be repaired and remonitored within 30 calendar days after it isdetected.If a leak greater than 10,000 ppm is detected, followprovisions detailed in Subpart VV.First attempts at repair include, but are not limitedto: (1) tightening of bonnet bolts, (2) replacement ofbonnet bolts, (3) tightening of packing gland nuts;and (4) injection of lubricant into lubricated packing.Instrument monitor valves in accordance with §60.482-7 asmodified by the associated OAC.The instrument shall be calibrated before use each day of use byMethod 21. The following calibration gases shall be used: Zeroair (less than 10 ppm of hydrocarbon in air); and a mixture ofmethane or n-hexane and air at a concentration of approximately500 ppm methane or n-hexane.For all equipment subject to this permit term, record in a log in areadily accessible location the information required in 60.486(e).Submit a semi-annual report including the appropriate items in60.487(c).Report the results of all performance tests in accordance with 60.8of 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 Re finery 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 Facilit y 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 Fa cility does not have this source category.

NWCAA 511 Refuse Burning – Time Restriction Fac ility 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 doe s 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 ot her 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 activiti es, 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 enforceabl e 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 Refi nery - Blaine, WA.

Emission

Unit Requirement/Limit Schedule Consent Decree

Reference

Sulfur

Recovery

Unit 40 CFR 60 Subpart J

1. 250 ppmvd SO 2 

# @ 0% excess air

2. 300 ppmvd of reduced sulfur compounds

3. Fuel gas limited to a composition of

H 2 

# S<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

SO 2



# .

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

H 2 

# S<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 H 2 

# S in

fuel gas burned. 1. 24 months (This has

been completed.) Paragraph 17 D