1. Facility Information: BP Cherry Point Refinery 2. Location: Northwestern Whatcom County, 7 miles southeast of Blaine, Washington. 3. Distance from U.S./Canada border: 8 miles 4. Type and Size of Facility: Large complex petroleum refinery (225,000 barrels crude processed per day) is proposing a Clean Gasoline Project. The project consists of a Straight Run Naphtha Dehexanizer, a Naphtha Hydrotreater, and a Benzene Saturation - Isomerization Unit (UOP Penex-Plus™). The purpose of the project is to process light naphtha feedstocks to produce a gasoline blend component that has essentially no benzene, olefins, or sulfur, and is higher in octane than its feed. The project will allow the refinery to meet the 2005 federal standard for sulfur in gasoline and will decrease benzene in all gasoline produced at the refinery. 5. Source of Emissions: New Isomerization Unit (process heaters and fugitive emissions from equipment leaks), Existing Boilers, Existing Hydrogen Heaters, Existing Storage Tanks, Existing Sulfur Recovery Unit. 6. Type of fuel: Refinery Fuel Gas. 7. Type and Quantity of Emissions & 8. Emission Control Technology: BP is required to install best available control technology (BACT) on new Isomerization Unit process heaters. For the two new process heaters (100 MMBtu/hr & 18 MMBtu/hr), BP estimates the following potential emissions and proposes the following controls as BACT: Pollutant Quantity of Emissions Emission Control Technology (tons / yr) NOx 18.1 Callidus Ultra BLUE Low NOx burners (or equivalent) PM10 3.9 Proper combustion SO2 28.9 NSPS Subpart J compliant refinery fuel gas VOC 2.8 Proper combustion CO 23.7 Proper combustion • VOC emissions from new Isomerization Unit equipment leaks will be controlled through compliance with EPA's Refinery MACT requirements at 40 CFR Part 63, Subpart CC. This MACT is considered BACT for this project. • BACT is not required of units simply experiencing an increase in utilization. These units include existing boilers and hydrogen heaters. • BP anticipates increased feed to the Sulfur Recovery Unit by less than 1 percent, and no detectable increase in emissions is anticipated. • BP estimates that evaporative VOC emissions from existing tanks will decrease by 2 tons annually as a result of this project. The overall project's emissions increases (not considering contemporaneous emissions increases and decreases) are as follows: Pollutant Quantity of Emissions (tons / yr) NOx 166 PM10 11 SO2 84 VOC 31 CO 47 H2SO4 2 9. Application Received: July 25, 2002. 10. Stack height and diameter: Stack 1 (100 MMBtu/hr Isom Heater): Height: 165 feet Diameter: 7 feet Stack 2 (18 MMBtu/hr Isom Heater): Height: 165 feet Diameter: 3.97 feet For additional stack (including emissions) information for units experiencing increased utilization, please contact permitting authorities noted below. 11. Permitting Authority: State of Washington Department of Ecology Air Quality Program Attn: Robert Burmark P.O. Box 47600 Olympia, WA 98504-7600 Phone: 360.407.6812 Northwest Air Pollution Authority Attn: Lynn Billington 1600 South Second Street Mt. Vernon, WA 98273-5202 Phone: 360.428.1617, ext 213