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Phillips 66 Company - Issuance of a modified Permit to Operate for Three External Floating Roof Tanks, Sources 180, 341 and 342 (Air District Application 724166

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The Bay Area Air Quality Management District has issued a modified Permit to Operate for three external floating roof tanks at the Phillips 66 facility—S-180, S-341, and S-342—to accommodate changes in storage and throughput operations. Tanks S-341 and S-342, each with a capacity of 4,326 thousand gallons and a 120-foot diameter, are authorized to increase their daily throughput to 20,750 barrels and annual throughput to 7.57 million barrels, primarily for renewable jet fuel, replacing previous gasoline storage. Tank S-180, previously exempt and with a capacity of 1,974 thousand gallons and a 100-foot diameter, is now permitted as a backup storage unit during maintenance outages of the other two tanks. Although the modifications are expected to raise potential precursor organic compound emissions—S-341 from 1.38 to 1.55 tons per year, S-342 from 0.39 to 1.55 tons per year, and S-180 from zero to 1.41 tons per year—the facility will comply with Regulation 8, Rule 5, which mandates best available control technology including primary and secondary rim seals, controlled deck fittings, and regular inspections to limit evaporative losses. The switch from gasoline to renewable jet fuel will result in a net reduction of toxic air contaminants despite higher POC emissions, and the projected levels remain below thresholds established under Regulation 2, Rule 5. No physical changes to the tanks are required, nor will new fugitive emission sources be added. Phillips 66 will offset the increased POC emissions using 3.14 tons per year of previously banked emission reduction credits from certificate #1706.

General Info

Phillips 66 permitted to store renewable jet fuel in three tanks with increased throughput, using emission credits and control tech to offset higher VOCs.

Agency

California → Bay Area Air Quality Management District

NAICS

541620 - Environmental Consulting ServicesView NAICS

Place of Performance

Internal Road 8 and Road J, CA, 94572

Set-Aside

NONE

Documents

(1)

Notice of Exemption for Phillips 66 Permit Modification 724166

PDFnotice-of-exemption

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Organization & Contact Information

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AgencyCalifornia → Bay Area Air Quality Management District
Contacts2 people available
OfficeN/A
Organization / Agency
California → Bay Area Air Quality Management District
Office AddressN/A
Contacts
Ali RoohaniSenior Air Quality Engineer
Brent EastepEnvironmental Specialist

Full Description

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The Air District has issued a modification to the Permit to Operate for the following existing sources: S-180 Tank# 292 External Floating Roof Tank, Maximum Capacity: 1,974 thousand Gallons; Diameter:100 feet Materials Stored : Renewable Jet; Maximum Throughput: 22,500 barrels per day, 8,212,500 barrels per year; Maximum True Vapor Pressure~ 2.5 psia S-341 Tank# 208 External Floating Roof Tank, Maximum Capacity: 4,326 thousand Gallons; Diameter: 120 feet; Materials Stored: Renewable Jet; Maximum Throughput: 20,750 barrels per day, 7,573,750 barrels per year; Maximum True Vapor Pressure~ 2.5 psia S-342 Tank# 209 External Floating Roof Tank, Maximum Capacity:4,326 thousand gallons, 120.feet diameter, Materials Stored : Renewable Jet; Maximum Throughput: 20,750 barrels per day, 7,573,750 barrels per year; Maximum True Vapor Pressure~ 2.5 psia 1/2 Phillips 66 has proposed increasing the permitted daily and annual throughput limits for tanks S-341 and S-342, as described above. In addition, tank S-180, previously classified as exempt, will be permitted to function as a backup storage tank during maintenance outages of S-341 and S-342. Although the proposed changes are expected to increase precursor organic compound (POC) emissions, Phillips 66 has stated that gasoline will no longer be stored in tanks S-341 and S-342. The potential POC emissions of S- 341 will increase from 1.38 to 1.55 tpy and for S-342, the potential POC emissions will increase from 0.39 to 1.55 tpy. S-180 does not have any permitted emissions because it was previously exempt but it will see an increase in potential emissions from O tpy to 1.41 tpy as it changes to a permitted source. The tanks will comply with the best available control technology (BACT) requirement for POCs by complying with Regulation 8, Rule 5, which establishes standards for storage tanks containing organic liquids, including external floating roof tanks. The rule requires primary and secondary rim seals, controlled deck fittings, and routine inspection and maintenance to minimize gaps, leaks, and evaporative losses, thereby reducing POC emissions. While the POC emissions are expected to increase, the overall toxic air contaminants (TACs) are expected to decrease because the previous TAC emissions were based on gasoline. However, since gasoline will no longer be stored and will be replaced with renewable jet fuel TACs are projected to decrease post project. The proposed modifications do not exceed the acute and/or chronic thresholds established under Regulation 2, Rule 5 for TACs. No physical modifications will be made to the tanks, and the throughput increase will not result in the addition of new fugitive emission components. Phillips 66 will provide 3.14 tpy of POC emission reduction credits (ERC) from banking certificate# 1706 to offset the POC emission increase in this application.

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