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NOTiCE TO APPLY
You are hereby notified that you are operating equipment at the above location for which a permit is required
from the Air Pollution Control Officer pursuant to Rule 202 of the Rules and Regulations of the San Luis Obispo
County Air Pollution Control District.
Please return the completed application with a filing fee of $195.00 to the Air Pollution Control District by
May 24,2016-
Failure to submit an application by this date will constitute a violation of District Rule 202 and may result in
further enforcement action. l
iSSUED BY:
T 8057815912 F 805.781.1002 W slocleanair.org 3433 Roberto Court, San Luis Obispo, CA 9340'l
IOO% Posl Consumer Recycled Poper
Phillips 66 Company may operate the crude offioading operation described below at Phillips
66 Refinery,2555 Willow Road, Arroyo Grande under this authorization until512312017 or
until a Permit to Operate has been issued or denied whichever occurs first. Pursuant to
Rule 206 of the Rules and Regulations of the Air Pollution Control District, the operation of
the unit is subject to the conditions listed below.
CONDITIONS:
Trucks entering the refinery to offload crude oil shall meet the California Air
Resources Board emission standards for model year 2007 and newer diesel engines.
2. Trucks staged for offloading crude oil shall adhere to the idling limits in ARB Title 13,
Article 4.9, Chapter 9, Section 2449(d)(3), and the Santa Maria Facility Policy 9.12.14.
3. Only one truck may be offloaded at a time and the total number of crude oil, sulfur
and petroleum coke trucks entering the Santa Maria Refinery shall not exceed 52.5
per day, based on a monthly average.
4. lf the Air Pollution Control Officer (APCO) determines that the operation of this
equipment is causing a public nuisance, the owner/operator shall take immediate
action and eliminate the nuisance.
5. The APCO shall be notified and authorization obtained prior to making any changes
in operating procedures, equipment, or materials used which have the potential to
increase the emission of any air contaminant or which would change the equipment
description or the applicability of a permit condition.
6. Records shall be maintained by P66 to enable the APCO to estimate the facility air
pollution emissions. These records shall include: the daily amount and types of
trucks visiting the facility, their date of manufacture or modification, details of any
installed air pollution control equipment, crude unloading throughput data, and any
system upsets or spills.
r 805.781.5912 r 805.781 .1 002 * slocleanair.org 3433 Roberto Courr, San Luis Obispo, CA93401
P ri10s 66 COm y
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8. IssuanceofthistemporaryStartupAuthorizationdoesnotimplyAPCOapprovalofa
perrrlanent crude offloading operation. An application for Perrnit to(Dperate is required tO
be subrnitted and approved before crude offloading is authorized at the Santa Maria
Refinery beyond May 23 2017. his authorization is subiect tO revocation by the APCO
should the fu vOlume ofre nery crude input by pipe ne be restored.
OperatiOn is authorized only for the purpose of a owing operatlon until an AP D Perrlnit to Operate
has been issued or denied. Further requirements rnay be placed upon your Perrnit to Operate
based upon post constructlon review.
VI
GARY Eo W:LLEY
Manager, Engineering and Compliance Division, for ``: ``
Larry R. Allen
Air Pollution Control Officer
San Luis Obispo County Air Pollution Contro! District
Phillips 66 Company may operate the crude offloading operation described below at Phillips 65
Refinery, 2555 Willow Road, Arroyo Grande under this authorization until5/23/2017 or until a Permit
to Operate has been issued or denied whichever occurs first. Pursuant to Rule 206 of the Rules and
Regulations of the Air Pollution Control District, the operation of the unit is subject to the conditions
listed below.
EQUIPMENT DESCRIPTION: Temporary Crude Oil Offloading Operation at the Displacement Meters
station at the Santa Maria Refinery.
COND!T!ONS:
1) Trucks entering the refinery to offload crude oil shall meet the California Air Resources Board
emission standards for model year 2007 and newer diesel engines.
2) Trucks staged for offloading crude oil shall adhere to the idling limits in ARB Title 13, Article
4.9, Chapter 9, Section 2449(d)(3), and the Santa Maria Facility Policy 9.1.2.14.
3) Only one truck may be offloaded at a time and the total number of crude oil, sulfur and
petroleum coke trucks entering the Santa Maria Refinery shall not exceed 52.5 per day, based on
a monthly average.
4) If the Air Pollution Control Officer (APCO) determines that the operation of this equipment is
causing a public nuisance, the owner/operator shall take immediate action and eliminate the
nuisance.
5) The APCO shall be notified and authorization obtained prior to making any changes in
operating procedures, equipment, or materials used which have the potential to increase the
emission of any air contaminant or which would change the equipment description or the
applicability of a permit condition.
6) Records shall be maintained by P66 to enable the APCO to estimate the facility air pollution
emissions. These records shall include: the daily amount and types of trucks visiting the facility,
their date of manufacture or modification, details of any installed air pollution control
equipment, crude unloading throughput data, and any system upsets or spills.
Operation ls authorized only forthe purpose of a owing operation until an APCD Perrnit to Operate
has been issued or denied. Further requirements rnay be placed upon your Perrnit to(Dperate v
based upon post construction revlew.
GARY E.WiLLEY
Managerr Engineering and Comp ance Division,for
Larry Ro A:len
Air Po ution Contro1 0fficer
San Luis Obispo county Air Po ution Control District
Startup Authorization
ENGINEERING EVALUATION
I.PerIIlit Processing SunlIElary:
Rule 204, Requirements (New Source Review): RACT is required for <25lblday, BACT for
>=25lblday, and offsets for >=25 tpy. Unloading of crude oil will result in inconsequential
emissions from the stationary sources at the refinery. The only emissions would be from minor
drips or spills from the hoses used to hook up to the facility's Displacement Metering station.
P66 has set up an excellent housekeeping system where drips are contained and immediately
cleaned up. In effect there is no change to the facility stationary source emissions. The crude
offloading trucks do represent a new activity for the refinery.
To ensure that there will be no unacceptable adverse impact from this new activity P66 has
agreed to keep the total facility volume of trucks below the level that was analyzed in the
Throughput Increase Project EIR. The dispersion modeling and risk assessment performed for
that EIR determined that the facility would meet all applicable rules and regulations with a
baseline monthly average of 52.5 truck trips per day. That amount of trips would be the total
amount of haul trucks transporting sulfur and petroleum coke products if the facility crude
throughput was 48,950 bbls/day.
As part of the Throughput Increase Project EIR required mitigations, P66 has already made
operational changes that reduced emissions at the facility. Under Application 6047 P66 has
reduced emissions from Boilers 8504 and 8506. The requirement to use only 2007 and newer
diesel trucks is another mitigation measure for this project that has already been implemented.
Both of these changes have resulted in ongoing operational emission decreases, but the facility
crude throughput has not increased to the level envisioned in the EIR due to Plains All American
pipeline break. So the net effect is reduced emissions from those mitigation measures, with no
corresponding throughput increase. Therefore this temporary crude unloading activity is exempt
from Rule 204 and Rule 219 requirements since there is no net increase in emissions.
Rule 216, Federal Part70 Permits: Major sources emitting >100 tpy of a criteria air contaminant
are required to obtain a federally enforceable operating (Title V) permit. This rule includes
applicability criteria, application requirements, and procedures for permit content, review,
issuance, and revision. A District permit is being required for this temporary crude unloading
operation to allow for local oversight. However the operation meets the federal guideline
general definition of an insignificant activity used in California: criteria pollutants < 2 tonlyr and
HAP emissions < 0.5 ton/yr. Due to the relatively insignificant potential emissions and the
temporary nature of the operation, this activity does not affect the Title V permit.
Rule 219, Toxics New Source Review: Applies to permitted sources that increase toxic
emissions that result in >=1.0E-6 risk or >=0.10 HHI. Modified sources must increase toxic
emissions above permitted or normal operating values to be subject. As described in the Rule
204 evaluation above there is no net increase in emissions, therefore there are no applicable
requirements under this rule.
Rule 402, Nuisance: No source of air pollution is allowed to create a public nuisance. This
proposed new activity is not expected to create any substantial additional nuisance potential.
The total number of crude trucks offloading is expected tobe 12 to 24 per day. P66 has set up
good procedures to ensure that drips are minimized and immediately cleaned up. Excessive
idling is prohibited. Truck drivers are instructed on the site specific procedures. Continued
compliance with this rule is indicated.
California Environmental Quality Act: As part of the proposed throughput increase project
mitigations have already been implemented that have reduced emissions at the facility. Changes
made to Boilers 8504 and 8506 have reduced NOx emissions from those units. Another
V. Emissions: No net increase in emissions. The total facility truck trips will be below the
amount that has been evaluated and mitigated for the Throughput Increase Project EIR. The
crude throughput is far below the permit limit due to AA Pipeline break; the current production
is about 60%o of the maximum allowed. This offloading operation has the potential to increase
the crude throughput by less thanSVo. Compliance with the recommended operating conditions
below will minimize emissions from this operation.
VI. Basis for Conditions: 1 is a mitigation requirement for the throughput increase project;2
v lists idling limits; 3 is the maximum number of trucks evaluated in the throughput increase
project; 4-6 are standard operating conditions. 7 is a good housekeeping condition and 8 is a
specific statement of the limitations of this temporary permit.
1) Trucks entering the refinery to offload crude oil shall meet the California Air Resources Board
emission standards for model year 2OO7 and newer diesel engines.
2) Trucks staged for offloading crude oil shall adhere to the idling limits in ARB Title 13, Article
4.9,Chapter 9, Section 2449(d)(3), and the Santa Maria Facility Policy 9.L2.14.
3) Only one truck may be offloaded at a time, and the total number of crude oil, sulfur and
petroleum coke trucks entering the Santa Maria Refinery shall not exceed 52.5 per day, based on
a monthly average.
4) If the Air Pollution Control Officer (APCO) determines that the operation of this equipment is
causing a public nuisance, the owner/operator shall take immediate action and eliminate the
nuisance.
6) Records shall be maintained by P66 to enable the APCO to estimate the facility air pollution
emissions. These records shall include: the daily amount and types of trucks visiting the facility,
their date of manufacture or modification, details of any installed air pollution control
equipment, crude unloading throughput data, and any system upsets or spills.
8) Issuance of this temporary Startup Authorization does not imply APCO approval of a
permanent crude offloading operation. An application for Permit to Operate is required to be
submitted and approved before crude offloading is authorized at the Santa Maria Refinery
beyond May 23,2077. This authorization is subject to revocation by the APCO should the full
volume of refinery crude input by pipeline be restored.
D :5/25 /
Air Pollution Control Engineer
May 23,2016
In response to NOV 2943, Phillips 66 Company (Phillips 66) is filing this application for a
temporary Permit to Operate at its Santa Maria Refinery (SMR). For many years, SMR has had
the physical and operational capability to receive trucks delivering feedstock, including crude oil,
and has on occasion utilized that capability. Subsequent to the shutdown of the Plains All
American pipeline in May 2015, SMR has received crude oil via truck delivery to the refinery to
replace a portion of the feedstock lost due to the pipeline shutdown. We _{.o no! believe a pgrmit
is required to. c=gntinue this activity; however, the District has requested a permit application, and
fr are willing in this instance to acquiesce in that request. The enclosed application would
allow the continued offloading of crude oil via truck during the pipeline outage. The infbrmation
included in this application explains the need for the proposed activity for District consideration.
Backsround Information :
On May 19,2015, the Plains All American pipeline was shutdown as a result of a leak.
The pipeline was a major source of SMR's raw material, crude oil. As a result of the Plains
Pipeline shutdown, SMR was forced to significantly curtail operations due to lack of
feedstock. Initial projections indicated that the impact to the operation of the Santa Maria
Refinery would be short and temporary. Since the Plains Pipeline shutdown, SMR has
been in an extended period of maintenance and operated a single crude unit at a time.
Beginning in March 2016, after a final scheduled maintenance turnaround, SMR initiated
an operations campaign designed to achieve production targets allowed by the volume of
incoming crude, while ensuring equipment reliability. Currently, we operate one or two
crude units depending on crude inventory.
ENV16-092
ISE450
E+10Y
Permit to Operatc Application:Temporav Of oading of
Crudc Oil via Truck During Pipeline Outagc.
May 23,2016
Pagc 2 of3
Permit Arrplication
The enclosed application requests a permit for crude oil truck offloading as follows:
o 52.5 crude oil, sulfur and coke trucks per day, averaged monthly.
o Hours of operation would only be limited by maximum truck count; a typical unloading
event is completed in approximately one hour.
W o Vehicles staged for unloading of crude oil will adhere to ARB Title 13, Article 4.9,
Chapter 9, Section 2449(d)(3) and SMF 9.12.14.
. Trucks entering the refinery to offload crude oil will be required to meet CARB
standards for model year 2007 and newer engines, as required for current coke/sulfur
trucks entering the refinery. This condition as applied to coke/sulfur trucks is required
under the Throughput Increase Project Permit.
Operation as proposed in the application will not result in an increase in truck trips to the
refinery.
Phillips 66 Santa Maria Refinery Crude Throughput Increase Project EIR and Permit established
a baseline monthly average of 52.5 truck trips per day. This baseline truck trip count was
utilized by the District in approving the Air Quality Mitigation for the Santa Maria Refinery
Crude Throughput Increase Project (letter from APCD, dated March 4,2015).
SMR operated both crude units under normal conditions in2014. In 2015, however, as a result
of the Plains All American pipeline leak, SMR operated under normal operating conditions only
until May 19,2015. A further decline in 2016 throughput rates resulted in reduced truck traffic.
The monthly average for the period of February through May 2016 was 36 crude, sulfur and
coke trucks per day (Attachment 3). Because there is variability in operations that may not be
captured in this brief period, the application requests that the temporary permit allow a monthly
average of 52.5 trucks per day (crude, sulfur and coke trucks combined) to ensure consistency
with the traffic and air emissions analyses in the EIR for the Santa Maria Refinery Crude
Throughput Increase Project and subsequent implementation by the APCD.
Overall, there has been no net increase in emissions per day as a result of the combined effect of
the reduced coke/sulfur truck volume and the additional crude trucks, and the proposed limit will
ensure that remains the case.
Conclusion
Aggin, please note that Phillips 66 does not believe that the offloading of crude oil by truck at
SMR requires a permit. The offloading operation is not a change in operation, nor does it require
a change in equipment. Nor does the activity produce a net increase in emissions. However, at
the District's request, and because we understand that it can be processed promptly, we are
submitting this permit application.
ENVi6 092
HSE450 E+10Y
Permit to Opcratc Application:Telllporav Offloading of
Crudc Oil a Truck During Pipclille Outagc.
May 23,2016
Page 3 of3
Please find enclosed with this application appropriate Title V forms, relevant fugitive emission
calculations for the unloading activity and detailed facility truck count for 2016. A check,
number 81805, in the amount of $195 is enclosed to cover the cost of the application.
If you have any questions regarding this application, please contact me at (805) 343-3620.
\r Sincerely,
Patrick Sidun
Environmental Specialist
PJS:bes
ENV16-092
HSE450 E+10Y
ATTACHMENT l
3433 Roberto Court San Luis Obispo CA 93401
Air Pollution Control District Phone:(805)781 5912 FAX:(805)781 1002
San tuis Obispo County Emall:info@JOdeanar.org
Web Site:www_sloclean r ora
l Type of Apicatbn:(E ing pemt 44-52
Permt New Equipment Modfy Perrnit Condltion tr Emission Reduction Credits
Perlnt_Exi ing Equipment Modtt Authonty to COnstruct X Permit Exemption
Mod Pemt
2. Process Type: (A process specific supplemental permit form must be attached to complete this permit application.)
n Abrasive Blasting n Fuel Combustion tr Organic Liquid Storage
tr Concrete Processing tr Fuel Drspensing tr Surface Coating
tr DegreasingOperations ! Internal Combustion Engine X General (Describe in 7. below)
tr Dry Cleaning
4. Offner:
Contact Person: Darin Grandfield (Supt., Operations & Technical Work: 805-343-3273
Services)
5. Other Contacts:
(If contact is not the same as owner please attach the APCD Permit Contacts form with the information)
Facility Operations: X same as owner Inspections: n same as owner
Billing: X same as owner Legal/Enforcement Actions: tr sme as owner
4/sa
RECEiVED Fee: 19
Fee:
L
ltlq 7.f
2
o_
Fee:
Ch
MAY 23 20,6 1 Check No. Check No.
R Receipt No.
.
Receipt No.
AR PoLLUT!oN RefIApp. No. Extended Permit No.
Comments Previous No.
Page 1 ol2
3433 Roberto Court San Luls Obispo CA 93401
(1 fttTACHMENTl Phone:(805)781 5912 FAX:(805)781-1002
1:] 1, Email:inFo@slodeandr.org
Web 9te:www Jodeandr oro
8. Project Status:
Staft Date: 5/13/16 Completion Date: Startup of Plains All American Pipeline
9. Additional Questions:
a Direction and straight line distance to nearest school: 5780 feet School Name: Lopez Hiqh School
b. Straight line distance to nearest residence: 3 O feet
I hereby certify that all informatron provided on this application, and rts plans, attachments, and supplementd forms, rs true and correct, I
agree to pay any and all fees required by District rules for processing this application and for issuance of any Authority to Construct or
Permit to Operate. If I abandon this project and wihdravu my application, or should my 4plication be disapproved, I agree that the
o galon e sts to compens nNCt r.TSpmt ng m
10.SIGNATURE: _ E P//6
12 PRINtt NAME: _PatHCk Sidun Envlonmental Spcq] 805-343 3620
S SHAREIDJV IR permt ad ATCttCrude Tnlck A p AOCD Tmlp crllde mbadtt permt appp51316 doc
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ATTACHMENT 4
Pursuant to San Luis Obispo County Air Pollution Control District Rule 204.E:
Phillips 66 certifies that emission units at this Refinery, located in California, which
would be classifled as a major stationary source, as defined in District Rule 105. and
which are owned or operated by this applicant, or by any entity controlling, controlled by,
or under common control with such applicant, are in compliance or on a schedule for
compliance with all applicable emission limitations and standards.
5-a3-lL
Date
Superintendent, Operations & Technical Services
*