BART ORDER

SUPPORT DOCUMENT ADDENDUM FOR

INCORPORATING A BART ALTERNATIVE IN

REVISION 2 TO BART ORDER #7836

ISSUED TO THE BP CHERRY POINT REFINERY

BLAINE, WASHINGTON

Prepared by

Washington State Department of Ecology

Air Quality Program

October 2014
ii

Contents

Summary of Proposal...................................................................................................................... 1

The Revision Request ..................................................................................................................... 1

Analysis of Emission Limitation Change Request ......................................................................... 2

Resolution of Other Requested Changes ........................................................................................ 3

Proposed BART Order Revisions................................................................................................... 4

State Implementation Plan Issues ................................................................................................... 5
BART Order Revision Support Document Page 1 of 4

BP Cherry Point Refinery

August 2014

Summary of Proposal

The BP Cherry Point Refinery (BP) has requested a revision to the BART Order to incorporate a 

BART Alternative measure. The meausure reflects the actual nitrogen oxides (NOX) capability 

of the Hydrocracker 1st Stage Reactor Heater (R-1 Heater) and the future replacement of BART 

units with new units. 

BP has proposed to have their federally approved BART Order modified to incorporate a Bart 

Alternative measure that when implemented will reduce emissions and lead to greater progress to 

meeting the Regional Haze visibility goal than the orignal BART requirements. 

The alternative reflects a higher heat input rate for the R-1 Heater resulting from its 

debottlenecking by the recently completed “Clean Fuels Project.” To offset the higher potential 

emissions from the R-1 Heater, the emission limitations on the Hydrocracker 1st Stage 

Fractionator Reboiler (R-1 Reboiler) will be reduced to reflect actual operating capabilities. The 

R-1 Reboiler is also an emission unit subject to BART control requirements. The higher heat 

rate is used when calculating the maximum lb NOX/hr emission limit on the R-1 heater. The 

potential emission increase from this change is offset by reducing the maximum emissions 

allowed for the R-1 Reboiler. The R-1 Reboiler emissions decrease is based on the ultra-low 

NOX (ULN) burners that have been installed on the R-1 Reboiler as part of the Clean Fuels 

Project.

The company is also requesting that there be language added to their Order which:

 Clarify what emissions limitations apply when a BART emission unit is replaced with a 

new unit, and

 To include a provision included in other Washington State Department of Ecology

(Ecology) BART Orders allowing monitoring, recordkeeping, and reporting requirements 

to be modified by a separate Ecology-issued regulatory order. 

The Revision Request

BP has requested Ecology to revise BART Order #7836 Revision 1 as follows.

1. BP has requested that BART Emission Limitations 2.5.1.2 and 2.6.1 of the BART Order

be modified to reflect the effects of the installation of ULN burners on two process 

heaters and debottlenecking of the hydrocracker unit by the Clean Fuels Project. The 

request is to provide a better than BART reduction in emissions by the company revising 

the BART limits for one of the heaters on the hydrocracker downward. 

2. To reduce the need for amending the Washington Regional Haze State Implementation 

Plan (RH-SIP) to remove decommissioned equipment from the BART Order, the 

company has also requested that language be added to the BART Order recognizing that 

when a named emission unit is permanently taken out of service, the BART limits no 
BART Order Revision Support Document Page 2 of 4

BP Cherry Point Refinery

August 2014

longer apply to the decommissioned unit or any replacement unit. A replacement unit 

would be subject to New Source Review requirements and Best Available Control 

Technology requirements.

3. Removal of all text in the Order related to Boilers #1 and #3. These two subject to 

BART boilers have been replaced and decommissioned.

4. To reduce the need for amending the RH-SIP to reflect improvements to monitoring 

recordkeeping and reporting requirements by allowing Ecology to issue a regulatory 

order to modify those requirements. The modified requirements must provide equal or 

better information on the compliance status of the covered sources and emission units 

than the original requirements.

Analysis of Emission Limitation Change Request

In 2006 BP installed new ULN burners in the R-1 Heater. As part of permitting for installation 

of the R-1 ULN burner, a new heat exchanger was also installed. The pair of actions was

anticipated to reduce the needed maximum firing rate for the R-1 Heater from 120 MMBtu/hr to 

88 MMBtu/hr, while operating the hydrocracker at its full operating capability. 

In 2010 BP applied for permits to construct and operate their “Clean Fuels Project.” The Clean 

Fuels Project was done to produce diesel fuel meeting the revised federal standards for the 

maximum sulfur content of diesel fuel used in land based off road engines. This project 

consisted of a number of projects. Those directly affecting the operation of the R-1 Heater were

the new diesel fuel treatment capacity (the #3 Diesel Hydrotreater) and new hydrogen production 

capacity (the Hydrogen Plant #2). Applications for preconstruction air quality approvals for this 

project was submitted to the Northwest Clean Air Agency (NWCAA) and Ecology in 2010 and 

permits issued in 2011. 

The Clean Fuels Project resulted in debottlenecking of the hydrocracker, allowing the 

hydrocracker to operate at the previous, higher throughput rates (but not above unit design 

capacity). The higher throughput rates have required the R-1 Heater to periodically operate at 

higher heat input rates (up to its rated capacity of 120 MMBtu/hr) than anticipated in 2006 and 

the emission limitations incorporated in the BART Order.

BP has requested a change to only the 24-hour maximum mass emission limit for the R-1 Heater. 

The current concentration limit, which is based on the emissions capability of the installed 

burners, is not proposed to change. The current limitation on this heater is 3.6 lb NOX/hr 

reflecting operating the burners at 88 MMBtu/hr. The requested emission limitation is 4.9 lb

NOX/hr (based on operating the burners at 120 MMBtu/hr) resulting in a requested increase in 

hourly average emission of 1.3 lb NOX/hr. The annual increase in emissions due to the requested 

change in the hourly maximum limit is 5.7 tons NOX per year.
BART Order Revision Support Document Page 3 of 4

BP Cherry Point Refinery

August 2014

To offset the increase in NOX from the revision to the R-1 Heater limitation, BP has requested 

that the emission limit for the R-1 Reboiler be adjusted downward to reflect the 2011–12

installation of ULN burners in the R-1 Reboiler. The emission limits are requested to go from 

the current 0.07 lb/MMBtu and 56.2 tons per year (tpy) (12.8 lb/hr) to 0.05 lb/MMBtu and 9.9 

lb/hr (40.1 tpy) for a decrease of 16.1 tpy. 

The net emission reduction as a result of these changes is a decrease in the allowable emissions 

of 1.6 lb/hr, on a 24-hour average and 10.4 tpy. This net emission reduction at these two subject 

to BART units results in a better than BART NOX emission improvement from these two subject 

to BART heaters and greater reasonable progress than the currently approved emission 

limitations on these heaters. 

Resolution of Other Requested Changes

BP has requested clarification on the applicability of BART emission limits for named BART 

emission units when they are decommissioned. BP is proposing a project to take two existing 

coking unit charge heaters out of service and replace them with new charge heaters. The existing 

coking units are subject to BART. BP wants to assure that the new BACT emission limits 

developed and required on the new units are the only emission limits that apply to the new 

equipment. 

Ecology’s view is that if the equipment has been decommissioned and replaced with new 

equipment subject to NSR requirements, the BART limits do not apply to the new emission 

units. This is because the new units did not commence construction or operation during the 15-

year time period to be subject to BART. This is the same reason that the emission limits for 

Boilers #6 and #7 were removed from this Order in Revision 1. 

Ecology is proposing to clarify this position by adding a new Condition 8 to the BART Order. 

This clarification could be specifically attached to each listed emission unit, or could be drafted 

to apply to any listed emission unit. The proposal is to use a single condition that applies to any 

unit specifically named in the BART Order.

BP requested that text in the Findings and in the Compliance Schedule sections of the BART 

Order related to replacement of the subject to BART Boilers #1 and #3. The BART emission 

requirement for these boilers is their decommissioning. Decommissioning occurred in December

2009. While removing these decommissioned units from the BART Order would simplify their 

inclusion in the Air Operating Permit issued to the plant, we are retaining the existing text to 

recognize the BART requirement on the boilers. 

The company has requested an amendment to the Order allowing for Ecology to modify the 

monitoring, recordkeeping, and reporting requirements in this Order by issuance of a new Order 

containing the revised requirements. An identical condition is included in other Washington 

State issued BART Orders, but have not been approved into the SIP. This new condition will 

allow for more rapid modification of monitoring, recordkeeping, and reporting requirements in 
BART Order Revision Support Document Page 4 of 4

BP Cherry Point Refinery

August 2014

the future to accommodate new monitoring methods and future requirements on the listed subject 

to BART emission units. If approved by Ecology, revised monitoring recordkeeping, and 

reporting requirements will need to be submitted to EPA as a revision to the SIP inorder to be 

federally enforceable. The presence of 2 sets of enforceable reporting, recordkeeping, and 

reporting requirements will require both sets of requirements be included in the Air Operating 

Permit and the source to demonstrate it complies with both. This situation will exist until such 

time as EPA approves the revised requirements into the SIP.

Proposed BART Order Revisions

Condition 2.5.1.2. is being proposed to be revised as follows:

2.5.1.2. 4.9 lb/hr based on a 24-hour rolling average.

Condition 2.6.1. is being proposed to be revised as follows:

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

both limits based on a 24-hour rolling average.

Condition 5 is proposed to be revised as follows:

5. Compliance with Conditions 1 through 4:

5.1 For all requirements in Conditions 1, 2, 3 and 4, except Conditions 2.5.1 and 2.6.1, 

compliance is required by August 7, 2009.

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

2014.

A new Condition 9. is being proposed as follows:

9. The BART requirements for an emission unit specifically listed in this Order do not apply

after the BP Cherry Point Refinery has certified in writing to Ecology and NWCAA that 

the named BART emission unit has been permanently taken out of service and dismantled. 

A new Condition 10. is being proposed as follows:

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

requirements specified in this Order. The revised monitoring, reporting, and 

recordkeeping methods must provide equal or better information on the compliance status 

of the source or emission unit subject to the revised monitoring, reporting, or 

recordkeeping methods.
BART Order Revision Support Document Page 5 of 4

BP Cherry Point Refinery

August 2014

Existing Condition 9. is being renumbered to be Condition 11. 

State Implementation Plan Issues

The proposed modifications to hourly NOX limitations for the Hydrocracker 1st Stage Reactor 

Heater (R-1 Heater) and the Hydrocracker 1st Stage Fractionator Reboiler (R-1 Reboiler) reduce 

the total NOX emissions allowed to be emitted by BP by 10.4 tpy. As discussed above, the R-1 

Heater will have a small increase in emissions. The new ULNB installed in the R-1 Reboiler 

will result in a decrease in emissions. The decrease in emissions is larger than the increase 

proposed to be allowed. The small increase of emissions allowed by the increase in hourly 

emission rate from the R-1 Heater is offset by the larger reduction occurring at the R-1 Reboiler.

The proposed change reflects a net decrease of 1.6 lb NOX/hr and 10.4 tons NOX per year of 

allowable emissions from the refinery. This results in a better than BART result for emissions

reductions from subject to BART emission units at the refinery. 

The reduction in emission rates of 1.6 lb NOX/hr results in a daily emission rate decrease of 

38.4lb NOX/day, which is too small to model a Class I area effect. As a result, no dispersion

modeling was done. However, in general, a reduction in NOX emissions will result in a decrease 

in modeled visibility impairment within nearby Class I areas. 

Specific changes to the BART Order proposed for submittal to EPA for approval as 

modifications to the approved BP Cherry Point Refinery BART Order:

Condition 2.5.1 (replacing SIP approved Condition 2.5.1)

Condition 2.6.1 (replacing SIP approved Condition 2.6.1)

Condition 3.2.1 (replacing SIP approved Condition 3.2.1)

Condition 5 (replacing SIP approved Condition 5

Condition 9 of the Order Revision 2 (new Condition)

EPA did not approve the following conditions into the SIP. We are not requesting EPA approval 

of the following conditions in the revised BART Order:

Condition 8

Condition 10 (renumbered Condition 9)

Condition 11 (renumbered Condition 10)