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Technical Support Document for Prevention of Significant Deterioration (PSD) Permit No. 5, Amendment 3 BP Cherry Point Refinery North Vacuum Heater Project Blaine, Washington May 2019
Technical Support Document for Prevention of Significant Deterioration (PSD) Permit No. 5, Amendment 3
BP Cherry Point Refinery North Vacuum Heater Project Blaine, Washington
May 2019
Publication and Contact Information For more information contact:
Air Quality Program P.O. Box 47600 Olympia, WA 98504-7600 Phone: 360-407-6800
Washington State Department of Ecology — www.ecology.wa.gov
• Headquarters, Olympia
• Northwest Regional Office, Bellevue
• Southwest Regional Office, Olympia
• Central Regional Office, Union Gap
• Eastern Regional Office, Spokane
360-407-6000
425-649-7000
360-407-6300
509-575-2490
509-329-3400
To request ADA accommodation including materials in a format for the visually impaired, call Ecology at 360-407-6800 or visit https://ecology.wa.gov/accessibility. People with impaired hearing may call Washington Relay Service at 711. People with speech disability may call TTY at 877-833-6341.
Technical Support Document for Prevention of Significant Deterioration (PSD)
No. 5, Amendment 3
BP Cherry Point Refinery North Vacuum Heater Project
Blaine, Washington
Air Quality Program
Washington State Department of Ecology
Olympia, Washington
This page is purposely left blank
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Table of Contents Page
List of Figures and Tables.............................................................................................................. vi Figures...................................................................................................................................... vi Tables....................................................................................................................................... vi
1. Executive Summary.....................................................................................................................1 2. Introduction..................................................................................................................................2 2.1. The permitting process........................................................................................................2
3. Site and Project Description.........................................................................................................3 3.1. Site description....................................................................................................................3 3.2. Project description ..............................................................................................................3
4. PSD Applicability Review...........................................................................................................5 4.1. Overview and permitting history ........................................................................................5
5. Changes to the PSD Permit........................................................................................................12 5.1. Permit Condition No. 1 .....................................................................................................12 5.2. Permit Condition No. 2 .....................................................................................................12 5.3. Permit Conditions No. 3 & No. 6 .....................................................................................12 5.4. Permit Conditions No. 4 & No. 5 .....................................................................................13
6. State Environmental Policy Act (SEPA) ...................................................................................15 7. Environmental Justice (EJ) Review...........................................................................................16 8. Public Involvement ....................................................................................................................17 9. Agency Contact..........................................................................................................................18 Acronyms and Abbreviations ........................................................................................................19
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List of Figures and Tables Page
Figures Figure 1: Refinery Process Flow Diagram.......................................................................................9
Tables Table 1: Project Emission Rate Estimation .....................................................................................5 Table 2: Project Regulated Pollutant Emission Increases (tpy).....................................................10
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1. Executive Summary BP West Coast Products (BP) applied for an amendment of their Prevention of Significant Deterioration (PSD) permit to modify the North Vacuum Heater at the BP Cherry Point Refinery. The modification includes replacing the piping inside the North Vacuum Heater and the existing heater burners. Ecology proposes to approve this amendment.
The BP Cherry Point Refinery is located at 4519 Grandview Road near the community of Birch Bay in Whatcom County. The refinery produces products including gasoline, diesel, jet fuel, green coke, calcined coke, liquefied petroleum gas (LPG), butane, pentane, and elemental sulfur.
This technical support document shows Ecology’s analysis supporting our decision to approve this amendment.
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2. Introduction
2.1. The permitting process
2.1.1. The PSD process PSD permitting requirements in Washington State are established in Title 40, Code of Federal Regulations (CFR) §52.21; Washington Administrative Code (WAC) 173-400-700 through 750. Washington State implements its PSD program as a State Implementation Plan (SIP)-approved program. This SIP-approved program became effective May 29, 2015.
Federal and state rules require PSD review of all new or modified air pollution sources that meet certain criteria in an attainment or unclassifiable area with the NAAQS. The objective of the PSD program is to prevent significant adverse environmental impact from emissions into the atmosphere by a proposed new major source, or major modification to an existing major source. The program limits degradation of air quality to that which is not considered “significant.” PSD rules require the utilization of BACT for certain new or modified emission units, which is the most effective air pollution control equipment and procedures that are determined to be available after considering environmental, economic, and energy factors.
The PSD rules must be addressed when a company is adding a new emission unit or modifying an existing emission unit in attainment or unclassifiable area. PSD rules apply to pollutants for which the area is classified as attainment or unclassifiable with the NAAQS. PSD rules are designed to keep an area with “good” air in compliance with the NAAQS. The distinctive requirements of PSD are BACT, air quality analysis (allowable increments and comparison with the NAAQS), and analysis of impacts of the project on visibility, vegetation, and soils.
2.1.2. The NOC process This project is subject to NOC permitting requirements under state of Washington regulations Chapters 173-400 and 173-460 (and/or local air regulations where applicable). NWCAA is the permitting authority for air pollutants not included in PSD permitting. This includes the New Source Review (NSR) permitting of criteria pollutants that are not PSD-applicable, air toxics issues under federal maximum achievable control technology (MACT) and state 173-460 WAC, and Title V permitting requirements. The procedure for issuing an NOC permit was established in Chapter 70.94 RCW.
WAC 173-400-110 outlines the NSR procedures for permitting criteria pollutants. These procedures are further refined in WAC 173-400-113 (requirements for new sources located in attainment or unclassifiable areas) and/or local air requirements where applicable. WAC 173-460-040 NSR supplements the requirements contained in Chapter 173-400 WAC (and/or local air requirements where applicable) by adding additional requirements for sources of toxic air pollutants (TAPs).
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3. Site and Project Description
3.1. Site description The BP Cherry Point Refinery is located in the City of Blaine in Whatcom County, Washington. BP is situated in Sections 7 and 8, Township 39N, Range 1E Willamette Meridian. The proposed project will not increase the current footprint acreage of the site.
The BP facility is located in a Class II area that is designated as “attainment or unclassifiable” for the purpose of PSD permitting for all pollutants.
3.2. Project description BP West Coast Products LLC (BP) owns and operates the BP Cherry Point Refinery. BP proposes to make the following changes to the North Vacuum Heater:
• Replace the piping inside the North Vacuum Heater with higher alloy metallurgy to mitigate corrosion mechanism.
• Replace the existing burners with more efficient, higher capacity burners to improve the reliability and efficiency of the vacuum unit.
As part of an ongoing BP safety improvement initiative to prevent incidents, BP performed a site-wide risk review for high temperature sulfidation (HTS) and naphthenic acid corrosion (NAC) within its operating units. Corrosion failures related to HTS and NAC can be localized and difficult to predict. Industry incidents have proven both failure mechanism to have significant safety consequences. Use of higher alloy metals is the industry recommended long-term solution to improving resistance to these failure mechanism.
BP identified piping systems and equipment in the north vacuum heater requires metallurgical changes. These metallurgical changes are necessary to maintain safe and reliable operation.
BP proposes to replace the existing North Vacuum Heater burners with more efficient higher capacity burners. At intermittent times under certain process conditions, the North Vacuum Heater has been unable to consistently heat all available VDF bottoms to the level required for processing by the vacuum tower. To accommodate the reduced performance of the North Vacuum Heater, the South Vacuum Heater and the Vacuum Tower throughputs are typically adjusted.
The existing burners will be replaced with new ultra low NOX burners that will increase the rated heat input capacity of the North Vacuum Heater from 77 million British thermal units per hour (MMBtu/hr) to approximately 117 MMBtu/hr, on a higher heating value (HHV) basis. The burner replacement will make overall vacuum unit operation more efficient and consistent while operating in parallel with the existing larger South Vacuum Heater (222 MMBtu/hr, HHV).
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No other existing units will be physically or operationally modified as the result of the project.
The existing North Vacuum Heater was installed in the Crude and Vacuum Unit in 1983. BP proposes to revise the existing PSD No. 5, Amendment 2 to reflect the changes to the heater’s capacity and the NOX emission rate.
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4. PSD Applicability Review
4.1. Overview and permitting history
4.1.1. Permitting history The Atlantic Richfield Company (ARCO) originally built the refinery in 1970. In April 2000, BP acquired ARCO and effective January 1, 2002; ARCO transferred all of its retail and refining assets, including the Cherry Point Refinery, to BP.
The North Vacuum Heater was installed in 1983 and permitted by the Northwest Air Pollution Authority (NWAPA) to operate up to 56 MMBtu/hr using air preheater.
ARCO Petroleum Company (ARCO) submitted the original PSD application to increase the North Vacuum Heater maximum operating rate to 77 MMBtu/hr using air preheater. The project qualified as a major modification because of the NOX emissions from the North Vacuum Heater.
Table 1: Project Emission Rate Estimation
Air Pollutant Pound per MillionBritish Thermal Units
Tons Per Year
Carbon monoxide (CO) 0.028 9.5
Nitrogen oxides (NOX) 0.19 66
Hydrocarbons (HC) 0.0024 0.83
Sulfur dioxide (SO2) 0.0005 0.16
Particulate matter (PM) 0.0024 0.83
Ecology issued the original PSD No. 5 on December 17, 1985, which required that BP must install the staged-burner NOX controls or demonstrate 28 tons per year (tpy) offsets in NOX emissions within one year.
On December 10, 1986, Ecology recognized the March 18, 1986, regulatory order to BP from the NWAPA as satisfaction of offsetting NOX emission reductions. The staged-burner NOX control installation and the associated references in the original PSD No. 5 have been removed in PSD No. 5, Amendment 1.
In PSD No. 5, Amendment 2, BP requested that the heater firing rate limit be measured as a 30-day rolling average to account for necessary variations in the heater’s operating conditions. The existing heater firing rate was required to be determined on an hourly average. Ecology approved the request.
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4.1.2. PSD applicability The existing facility is a major PSD stationary source per 40 CFR 52.21(b)(1)(i). Under WAC 173-400-720 through 750, a project proposed at an existing major stationary source is subject to PSD review if the project either is a “major modification” to an existing “major stationary source,” or is a major stationary source unto itself.
Unless otherwise exempted by applicable regulation, a change to an existing major stationary source is a major modification if the change results in both a significant emissions increase and a significant net emissions increase at the source. “Significant emissions increase” means that the emissions increase for any regulated PSD pollutant is greater than the PSD significant emission rate (SER) threshold for that regulated pollutant.
BP conducted the PSD applicability analysis for the project and concluded that it does not trigger PSD review for any regulated pollutant.
4.1.3. Projects aggregation When undertaking multiple projects, the source must consider whether NSR applicability should be determined collectively or whether the emissions from each of the projects should be considered separately. Multiple projects that are interrelated should be grouped together and considered a single project for the purpose of the NSR applicability test. When interrelated projects are evaluated separately, they may circumvent the purposes of NSR. Ecology has reviewed information provided by BP in its November 14, 2018, permit application to revise PSD Permit No. 5, Second Amendment and has determined that the Coker Heaters Replacement Project, the Renewable Diesel Project, Coke Drum Compressor Project, ISOM LEU Project, and the North Vacuum Heater Project are not interrelated, and do not need to be evaluated as a single project for the purpose of the NSR applicability test.
BP’s aggregation analysis
BP conducted the aggregation analysis using the criteria set forth in EPA’s 1993 “3M-Maplewood” memorandum. Summary of BP’s analysis is as shown below.
1. Timing. Filing of more than one minor source or minor modification application associated with emissions increases at a single plant within a short time period.
Project Description
The Renewable Diesel Project
Additional tankage and pipe were installed to allow use of animal fat as refinery feedstock to comply with renewable energy requirements. Northwest Clean Air Agency concluded that an air permit was not needed because there would be no increase in emissions.
Coke Drum Compressor Project
Installation of a compressor to ensure compliance with NSPS Subpart Ja limit for venting coke drums to atmosphere as they depressurize. This project was driven by regulatory requirement and has no bearing of the North Vacuum Heater Project.
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Project Description
ISOM LEU Project
To install redundant equipment in the Light End Unit to reduce flaring events to ensure compliance with NSPS Subpart Ja requirements. This project was driven by regulatory requirement and has no bearing on the North Vacuum Heater Project.
2. Application of funding. Applications for commercial loans or, for public utilities, bond issues, should be scrutinized to see if the source has treated the projects as one modification for financial purposes. If the project would not be funded or if it would not be economically viable if operated on an extended basis (at least a year) without the other projects, this should be considered evidence of circumvention.
The project scope for the North Vacuum Heater Project was selected in November 2017 and the decision to fund the project was made in February 2018. The Coker Heater Replacement Project submitted the initial PSD permit application to Ecology in September 2014. The final PSD permit application was submitted in March 2016. The primary scope for the Coker Heaters Replacement Project was already defined, complete with engineering, and the initial PSD permit application had been submitted by the time the North Vacuum Heater Project was conceptualized.
According to BP, the decision to fund the North Vacuum Heater Project is a separate authorization from the Coker Heaters Project. BP made the funding decision for the North Vacuum Heater Project almost two years after the final PSD application for the Coker Heater Project.
3. Reports of consumer demand and project production levels. Stockholder reports, reports to the Securities and Exchange Commission, utility board reports, or business permit applications should be reviewed for projected operation or production levels. If reported levels are necessary to meet projected consumer demand but are higher than permitted levels, this is additional evidence of circumvention.
BP explained that the project is an incremental step and part of a continuing effort to improve refinery safety, efficiency, and productivity. The basis for the project is to update the North Vacuum Heater to current safety specifications and not projected consumer demand for refinery products. The secondary goal of the project is to equip the North Vacuum Heater with modern burners of increased capacity to improve heater availability and to better balance operation of the North and South Vacuum Heaters. BP explained that the project conservatively projected a two percent increase in the annual crude throughput because of the increased availability of the modified heater compared to baseline operations. BP anticipates the balancing of operation between the North and South Vacuum Heaters will not result in significant increased annual crude throughput compared to pre-project throughput.
4. Statements of authorized representatives of the source regarding plans for operation. Statements by representatives of the source to EPA or to State or local permitting agencies
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about the source's plans for operation can be evidence to show intent to circumvent preconstruction review requirements.
There are no statements that imply the North Vacuum Heater Project is a necessary component for successful operation of the coker unit, or vice versa. Each project was conceived, designed, and authorized on its own merit.
Ecology’s aggregation review
Petroleum refineries are complex integrated manufacturing processes. Ecology generally has considered the totality of all factors because relying on any single factor is unlikely to produce a conclusive determination.
Timing. In general, Ecology reviews the timing of the projects to question if projects are interrelated and should be aggregated. However, Ecology does not consider timing as a decisive, stand-alone factor in determining whether projects should be aggregated.
From a timing standpoint, Ecology believes that the Renewable Diesel Project, the Coke Drum Compressor Project, and the ISOM LEU Project should be considered in this aggregation analysis because of the relatively close timing when these projects occurred.
Due to the timing, Ecology also believes that further review is needed to see if the North Vacuum Heater Project is related to the Coker Heaters Replacement Project, which Ecology approved under PSD 16-01 on May 23, 2017.
Project Interrelationship. This analysis evaluates the interrelationship between projects regarding whether one project is incapable of performing as planned in the absence of the other project. For the purpose of this discussion, the process flow diagram of the facility is shown in Figure 1.
As described by BP, the Renewable Diesel Project, the Coke Drum Compressor Project, and the ISOM LEU Project are driven by NSPS and renewable energy requirements. Ecology did not see any evidence to suggest that there is any substantial relationship between these projects with each other, or with the Corker Heaters Replacement Project and the North Vacuum Heater Project.
Ecology also did not find any apparent interconnection between the North Vacuum Heater Project and the Coker Heaters Replacement Project. Based on the description provided by BP, both projects were planned independently and does not depend on the other in terms of decision-making and timing. Ecology did not see any evidence to suggest that one project is contingent on another project.
The Coker Heaters Replacement Project is expected to improve the efficiency of the coker heaters by reducing the time for periodic offline heater cleaning (decoking). The short-term throughput rate of the coker unit is not expected to change due to the new heaters, but the coker unit annual average feed rate is projected to increase to 61.9 kbpd (12-month average) from 50.6 kbpd (24-month average) due to less heaters downtime.
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To accommodate this crude oil throughput increase, the Coker Heaters Replacement Project estimates that the North and South Vacuum Heaters will experience an increase in heat input rate to 653,219 MMBtu/year and 1,634,607 MMBtu/year, respectively. The maximum heat input rate of the North Vacuum Heater is permitted at 77 MMBtu/hour and the South Vacuum Heater is rated at 207 MMBtu/hour. Based on this capacity, it appears that the North and South Vacuum Heaters should have sufficient capacity (2,414,000 MMBtu/year, assume 8,500 hours of operation/year) to provide additional heat that is needed to support the throughput increase. In other words, the North and South Vacuum Heaters can accommodate the increased utilization projected in the Coker Heaters Replacement Project without increase of the burner capacity of the North Vacuum Heater proposed in this application.
Therefore, Ecology finds that the Coker Heaters Replacement Project and the North Vacuum Heater Project are not interrelated, and do not need to be evaluated as a single project for the purpose of the NSR applicability test.
Figure 1: Refinery Process Flow Diagram
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4.1.4. Project emissions increase In order for a project to become subject to PSD review, a major stationary source must have a significant emission increase from the proposed project (Step 1 analysis). If a Step 1 analysis shows that the project does cause a significant emission increase, the emission increase is examined to see if the net emissions increase as calculated over the 5-year contemporaneous period will result in a significant increase (Step 2 analysis). The results of that test were compared to the PSD SER to determine PSD applicability.
BP has chosen to apply the projected emission increase to all refinery emission units instead of assuming specific process unit that are affected by the project and used the baseline period of 2014-2015 for all pollutants. BP has concluded that the project emission increase is not significant under Step 1 analysis, therefore the project is not subject to PSD review. BP has included PSD applicability analysis in this application and the summary of the project emission increase is presented in Table 2 below.
Table 2: Project Regulated Pollutant Emission Increases (tpy)
Pollutant Modified North Vacuum Heater*
Component Fugitives*
Refinery† Total Emission Increase
PSD SER‡
NOX 0 --- 31 31§ 40
CO 0 --- 8 8§ 100
SO2 12 --- 14 26 40
PM (filterable) 0.7 --- 3.1 4 25
PM10 (total) 2.9 --- 1.6 5 15
PM2.5 (total) 2.9 --- 1.6 5 10
VOC 1.4 0.03 7.7 9 40
Pb 1.2E-04 --- 1.7E-04 3.0E-04 0.6
H2SO4 1.3 --- 0.9 2 7
H2S 1.0E-03 2.6E-03 0.13 0.2 10
CO2e 30,765 6 43,154 73,924 75,000
Fluorides --- --- --- negligible 3
TRS --- --- --- negligible 10
Reduced Sulfur Compounds
--- --- --- negligible 10
MW Comb. – Organics --- --- --- 0 3.5E-6
MW Comb. – Metals --- --- --- 0 15
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Pollutant Modified North Vacuum Heater*
Component Fugitives*
Refinery† Total Emission Increase
PSD SER‡
MW Comb. – Acid Gases --- --- --- 0 40
MSW Landfill – NMOC Emissions
--- --- --- 0 50
Notes: ∗ Modified emission unit (Potential Annual Emission Rates minus baseline actual emissions). NOX and CO emissions from the North Vacuum Heater set to zero as there will be net decrease in emissions as result of the project, and emission decreases from heater also presented. Component fugitives include new north vacuum heater components.
† Increased utilization of existing emission units (Projected Actual Emissions minus Baseline Emission Rates).
‡ Prevention of Significant Deterioration (PSD) Significant Emission Rates 40 CFR 52.21(b)(23). § The Project will decrease annual NOX and CO emissions from the North Vacuum Heater by 12 tpy and 2 tpy, respectively. EPA’s March 2018 guidance confirms that emission increases and decreases resulting from a project are included in Step 1 “project emissions accounting” of the PSD applicability analysis. Even without the emission decreases resulting from this Project, the total increases in emissions are less than the PSD SERs.
BP is subject to post project emission monitoring to demonstrate that the North Vacuum Heater Project is not a major modification because:
1. BP elected to project post change emissions rather than use PTE.
2. There is a reasonable possibility that the project will result in a significant emissions increase.
3. BP determined that the project would not constitute a major modification.
BP must track the emissions for a period of 10 years after the completion of the project because of the increase in modified unit’s design capacity. For this purpose, BP must keep the records as required by WAC 173-400-720(4)(b)(iii).
BP is also obligated to ensure that the required records are available for examination upon request by Ecology, Northwest Clean Air Agency (NWCAA), or the public.
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5. Changes to the PSD Permit
5.1. Permit Condition No. 1 The existing condition limits the North Vacuum Heater to 14.6 lb NOX/hour (1-hour average, quantify as NO2) and 66 tons NOX in 12 consecutive months. The compliance method for the NOX limit is EPA Reference Method 7E. The limits were established based on emission factor of 0.19 lb NOX/MMBtu and permitted heat input rate of 77 MMBtu/hour.
BP proposes to revise the NOX limit to 7.0 lb/hour (calendar day basis). BP did not propose an annual NOX emission limit, however based on the proposed short-term emission limit, the annual NOX emission is 31 tpy, assuming continuous operation. BP also proposes to use NOX Continuous Emissions Monitoring System (CEMS) as the compliance method for the limit.
NWCAA issued OAC 273c to allow BP to replace the existing burners with ultra low NOX burners rated at 117 MMBtu/hour. Ecology is revising the short-term NOX limit consistent with the allowable emission established under OAC 273c, to update the performance of the modified heater.
Since BP has proposed using CEMS as the compliance method, Ecology finds that the long-term NOX limit in tpy will be unnecessary because the compliance method is capable of ensuring compliance on a continuous basis.
5.2. Permit Condition No. 2 The existing condition limits the maximum heat input rate of the North Vacuum Heater to 77 MMBtu/hour, based on higher heating value and 30-day rolling average. BP proposes to remove the maximum heat input rate. BP did not propose to establish a revised maximum heat input rate for the heater.
Ecology is revising the maximum heat input rate of the North Vacuum Heater to 117 MMBtu/hour, on a calendar day basis. Ecology finds that the maximum heat input rate of the heater shall be stated in the permit because of its importance to represent the basis of the approval and its relation to the unit’s emission rate estimation. Ecology proposes to establish the averaging period on a calendar day basis to be consistent with the short-term NOX emission limit averaging period.
5.3. Permit Conditions No. 3 & No. 6 The existing Condition No. 3 requires that a continuous oxygen monitor operated according to Performance Specification 3, Appendix B of 40 CFR 60. The existing Condition No. 6 requires annual compliance test for NOX emission limit using EPA Reference Method 7E.
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BP proposes to install, maintain, and operate a NOX CEMS to demonstrate compliance with the NOX limit.
Ecology finds that CEMS provides better compliance assurance for the NOX limit than the annual EPA Reference Method 7E test. CEMS can provide compliance assurance on a continuous basis (except for the period of monitor outage) compared to Method 7E, which is only capable of demonstrating compliance on an intermittent basis during the time the test is conducted.
Ecology is revising the permit conditions identifying CEMS as the compliance method, along with the requirements that ensure CEMS will be installed, operated, and maintained properly.
5.4. Permit Conditions No. 4 & No. 5 The existing permit Condition No. 4 limits the hydrogen sulfide (H2S) emission to 160 part per million on dry volume basis (ppmdv), on 3-hour basis, or 90 ppmdv on 30-day rolling average. The existing permit Condition No. 5 requires that the H2S concentration in the fuel to be monitored and recorded.
BP requested permit Condition No. 4 to be removed on the basis that H2S emission was never subject to PSD review and was in the permit due to the confusion in conversion of the NSPS Subpart J H2S limit.
Ecology agreed to remove the H2S emission limit in permit Condition No. 4 per BP’s request after reviewing the original PSD Permit No. 5 issued December 17, 1985, and the Technical Analysis document for the permit.
Based on the analysis conducted during 1985, only the NOX emission rate (66.1 tpy) exceeded the significant emission rate threshold, which is 40 tpy. The findings on the original Permit No. 5 pointed out that “oxides of the nitrogen are the only emission which are subject to PSD review,” consistent with the conclusion of the project emission rate estimation.
Ecology did not find any information that specifically explained the rational of establishing H2S emission limit in the permit at the time, however there is some evidence to suggest that it was established due to NSPS Subpart J - Standards of Performance for Petroleum Refineries.
The Technical Analysis conducted during 1985 discussed the NSPS Subpart J applicability to the North Vacuum Heater, and described 40 CFR 60.104(a)(1) requires that the H2S content of the fuel gas shall not exceed 230 mg/dscm (0.10 gr/dscf or 160 ppm). This review noted that 40 CFR 60.104(a)(1) only expresses H2S concentration limit in 230 mg/dscm (0.10 gr/dscf). As suggested by BP, 160 ppmdv H2S limit was a conversion based on NSPS Subpart J emission limit, and might have been included in the original PSD Permit No. 5 because of the permitting practice at the time.
More importantly, Ecology finds that the H2S emission from the North Vacuum Heater is below the SER of 10 tpy and should not be included in the PSD permit. According to the information
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provided in this application, BP’s emission factor for H2S is 5.8 E-05 lb/MMBtu. At 77 MMBtu/hour capacity permitted during 1985, the emission rate is approximately 39 lb/year.
Ecology also proposes to remove the existing permit Condition No. 5 because it becomes unnecessary once permit Condition No. 4 is removed.
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6. State Environmental Policy Act (SEPA) Under Washington State rules, a final PSD permit shall not be issued for a project until the applicant has demonstrated that SEPA review has been completed for the project.
Whatcom County was the SEPA lead for this project and issued a Mitigated Determination of Nonsignificance (MDNS) SEP 2018-00082 on February 1, 2019.
Ecology concludes that the applicant has adequately demonstrated compliance with SEPA requirements.
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7. Environmental Justice (EJ) Review EJ is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. Ecology conducts an EJ review to ensure no group of people bear a disproportionate share of the negative environmental consequences as the result of the permitting action.
Ecology uses EJSCREEN, an EPA’s environmental justice mapping and screening tool to obtain demographic and environmental information for the project area. The EJ screen area (five-mile radius from the facility) has population that approximately nine percent minority and one percent of the population age 5+ speak English “not well.” It does not appear that language barrier should be an issue for the local community residents as they search for environmental issues that may be of interest. Therefore, Ecology finds that enhanced outreach is not needed to further engage EJ populations in environmental decision-making.
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8. Public Involvement Ecology determines that the revisions involve more than administrative changes, therefore provides an opportunity for public comment.
This PSD permitting action was subject to a minimum 30-day public comment period under WAC 173-400-740. In accordance with WAC 173-400-740(2)(a), application materials and other related information were made available for public inspection at the:
Northwest Clean Air Agency 1600 S 2nd Street Mt Vernon, WA 98273
Washington State Department of Ecology Air Quality Program 300 Desmond Drive SE Lacey, WA 98503
The information will also be posted on Ecology’s website for the duration of the public comment period.
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9. Agency Contact MengChiu Lim, P.E. Washington State Department of Ecology Air Quality Program P.O. Box 47600 Olympia, WA 98504-7600 (360) 407-6314 [email protected]
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Acronyms and Abbreviations BACT Best Available Control Technology
CFR Code of Federal Regulations
CO carbon monoxide
Ecology Washington State Department of Ecology
EPA United States Environmental Protection Agency
hr/yr hours per year
MACT maximum achievable control technology
NAAQS National Ambient Air Quality Standards
NOC Notice of Construction
NOX nitrogen oxides
NSR New Source Review
NWCAA Northwest Clean Air Agency
PM particulate matter
PM10 particulate matter less than 10 micrometers in diameter
PM2.5 particulate matter less than 2.5 micrometers in diameter
ppm parts per million
PSD Prevention of Significant Deterioration
PTE potential to emit
SEPA State Environmental Policy Act
SER significant emission rate
SO2 sulfur dioxide
TAP toxic air pollutant
tpy tons per year
VOC volatile organic compound
WAC Washington Administrative Code
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