Phillips 66 Company - Issuance of an Altered Permit to Operate for One Internal Roof Tank, Source 18 (Air District Application 703147).

The Air District has issued an alteration to the Permit to Operate for the following existing source: S:18 TANK #3951 Internal Floating RoofTank, Volume: 634,000 Gallons, Organic Liquid Stored: Ethanol, Maximum Annual Throughput: 61,320,000 gallons per year, Maximum Daily Throughput: 168,000 gallons per day, Maximum True Vapor Pressure: 0.84 psia. Phillips 66 has proposed installing a new ethanol pump (PMP-7000) at the newly proposed ethanol truck offloading area, located directly in front of the S-18. S-18 was historically permitted to store both ethanol and gasoline, however, with this application the facility is proposing to store only ethanol in S-18. According to the facility, the current pump (PMP-51() can no longer operate at its intended capacity and therefore requires replacement; however, it will remain in service as a backup unit until the end of its operational life. The addition of a new pump at the ethanol offloading site at S-18 will introduce fugitive emission components. However, even with the addition of associated precursor organic compound (POC) fugitive emissions, the total annual post-project POC emissions from S-18 will be lower than pre-project emissions because S-18 will no longer store gasoline. To keep this application as an alteration, the facility agreed to a daily throughput limit of 168,000 gallons per day. This throughput limit is the historical maximum throughput observed at 5-18. Using this maximum daily throughput, the annual throughput will also get reduced from the existing 75,598,160 gallons per year limit to 61,320,000 gallons per year. This results in an annual POC emission reduction from 1,340.0 pounds per year to 521.8 pounds per year. 5-18 does not trigger best available control technology (BACT) review since daily emissions are estimated to be at 1.43 pounds per day which is below the 10 pounds per day threshold for BACT review. Offsets will not be necessary for this project since there is no emission increase associated with the proposed changes. There are no toxic air contaminants (TACs) associated with this project and a health risk assessment is not required.