AIR EMISSION PERMIT NO. 04500004- 002 IS ISSUED TO BP ... · AIR EMISSION PERMIT NO. 04500004- 002...

AIR EMISSION PERMIT NO. 04500004- 002 IS ISSUED TO

BP Amoco

BP Amoco - Spring Valley Terminal

RR 2 Spring Valley, Fillmore County, MN 55975

The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type – Action Number Application Date Issue Date Total Facility Operating Permit - 001 07/25/2000 07/24/2000 Major Amendment - 002 06/15/1996 09/07/2000

This permit authorizes the permittee to operate and modify the stationary source at the address listed above unless otherwise noted in Table A. The permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: State; Limits to avoid Part 70/Limits to avoid NSR/Limits to avoid Part 63 Amendment Issue Date: September 7, 2000 Expiration: Permit does not expire All Title I Conditions do not expire. Ann M. Foss Manager North/South Major Facilities for Karen A. Studders Commissioner Minnesota Pollution Control Agency BJN:ais

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendix I: Insignificant Activities

Air Emission Permit No. 04500004-002

NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area (651) 296-6300 Outside Metro Area 1-800-657-3864 TTY (651) 282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. APPLICABLE REQUIREMENTS CLARIFICATION: The Permittee shall comply with the emission limitations contained in the permit. Consult the appropriate sections of the Code of Federal Regulations and Minnesota Rules for the full text and extent of the applicable requirements. FACILITY DESCRIPTION: The facility is a bulk gasoline terminal consisting of product storage tanks, a truck loading rack and a vapor combustion unit. The terminal receives petroleum products through a pipeline distribution network. On-site remediation activities are authorized to be installed and operated as needed. The facility has accepted limits on Volatile Organic Compound (VOC) emissions from the gasoline loading process and remediation system operations to remain a non-major source for 40 CFR Section 52.21, 40 CFR Section 70.2 and 40 CFR Section 63.2. MODIFICATION DESCRIPTION: This permit action modifies the VOC emission calculation method for Group 3 (Truck loading rack and remediation systems) to include hours of operation and operation of pollution control equipment.

TABLE A: LIMITS AND OTHER REQUIREMENTS 09/07/00

Amoco Oil Co - Spring Valley Terminal

04500004 - 002

Facility Name:

Permit Number:

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column ofthe table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you musttake and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it)lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facilityrequirements.

Subject Item: Total Facility

What to do Why to do itAlternative Operating Scenario: This permit contains terms and conditions foralternative operating scenarios in accordance with Minn. R. 7007.0800, subp. 11.

Minn. R 7007.0800, subp. 11

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment.

Minn. R. 7007.0800, subp. 14 and Minn. R. 7007.0800,subp. 16(J)

Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A, B, and/or C.

Minn. R. ch. 7017

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as specified by Minn. R. 7017.2025 followingformal review of a subsequent performance test on the same unit.

Minn. R. 7017.2025

Monitoring Equipment: Install or make needed repairs to monitoring equipmentwithin 60 days of issuance of the permit if monitoring equipment is not installed andoperational on the date the permit is issued.

Minn. R. 7007.0800, subp. 4(D)

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

Minn. R. 7011.0020

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of aplanned shutdown of any control equipment or process equipment if the shutdownwould cause any increase in the emissions of any regulated air pollutant. If theowner or operator does not have advance knowledge of the shutdown, notificationshall be made to the Commissioner as soon as possible after the shutdown.However, notification is not required in the circumstances outlined in Items A, Band C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner ofthe cause of the shutdown and the estimated duration. The owner or operator shallnotify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

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Facility Name:

Permit Number:

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise noted in Table A. Air Pollution Control Equipment associated with theremediation system is not required during operation.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,subp. 16(J)

Fugitive Emissions: Do not cause or permit the handling, use, transporting, orstorage of any material in a manner which may allow avoidable amounts ofparticulate matter to become airborne. Comply with all other requirements listed inMinn. R. 7011.0150.

Minn. R. 7011.0150

Application for Permit Amendment: If a permit amendment is needed, submit anapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

Minn. R. 7007.1150 through Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendmentto extend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

Minn. R. 7007.1400, subp. 1(H)

Record keeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007. 1250, subp. 3) or changes contravening permit terms(as required by Minn. R. 7007.1350 subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007. 0800, subp. 5(B)

Record keeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal strip-chart recordings for continuous monitoring instrumentation, and copiesof all reports required by the permit. Records must conform to the requirementslisted in Minn. R. 7007.0800, subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)

Noise: The Permittee shall comply with the noise standards set forth in Minn. R.7030.0010 to 7030.0080 at all times during the operation of any emission units.This is a state only requirement and is not enforceable by the EPA Administrator orcitizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

The Permittee shall comply with the General Conditions listed in Minn. R.7007.0800, subp. 16.

Minn. R. 7007.0800, subp. 16

Inspections: Upon presentation of credentials and other documents as may berequired by law, allow the Agency, or its representative, to enter the Permittee'spremises to have access to and copy any records required by this permit, to inspectat reasonable times (which include any time the source is operating) any facilities,equipment, practices or operations, and to sample or monitor any substances orparameters at any location.

Minn. R. 7007.0800, subp. 9(A)

Emissions Inventory Report: due 91 days after end of each calendar year followingJuly 24, 2000. To be submitted by April 1st on a form approved by theCommissioner.

Minn. R. 7019.3000 through Minn. R. 7019.3010

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 through Minn. R. 7002.0095

Emergency Provisions: The affirmative defense of emergency shall bedemonstrated through properly signed, contemporaneous operating logs and otherrelevent data in accordance with Minn. R. 7007.1850.

Minn. R. 7007.1850

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Facility Name:

Permit Number:

Subject Item: GP 002 Ethanol Storage Tanks 012 through 014

Associated Items: TK 012 Ethanol

TK 013 Ethanol

TK 014 Ethanol

What to do Why to do itRecordkeeping: Maintain records showing the dimensions of the tank and ananalysis showing the tank capacity. These records shall be maintained for the life ofthe source.

40 CFR Section 60.116b(b), Minn. R. 7011.1520(C)

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04500004 - 002

Facility Name:

Permit Number:

Subject Item: GP 003 Gasoline Loading and Remediation Systems

Associated Items: EU 001 Truck Loading Rack

EU 002 Remediation System

What to do Why to do itA. POLLUTANT LIMIT hdr

Volatile Organic Compounds: less than or equal to 74.3 tons/year using 12-monthRolling Sum calculated by the 15th day of each month for the previous 12-monthperiod using the calculation method below. For the first 11 months, the limits in therequirement labeled FIRST-YEAR LIMITS shall be met.

Title I Condition: limit taken to avoid major sourceclassification under 40 CFR Section 52.21, 40 CFRSection 70.2, and 40 CFR Section 63.2

FIRST-YEAR LIMITS beginning July 24, 2000

Month 1: 19.3 tons/1 month Month 7: 49.3 tons/7 monthsMonth 2: 24.3 tons/2 months Month 8: 54.3 tons/8 monthsMonth 3: 29.3 tons/3 months Month 9: 59.3 tons/9 monthsMonth 4: 34.3 tons/4 months Month 10: 64.3 tons/10 monthsMonth 5: 39.3 tons/5 months Month 11: 69.3 tons/11 monthsMonth 6: 44.3 tons/6 months

Title I Condition: limit taken to avoid major sourceclassification under 40 CFR Section 52.21, 40 CFRSection 70.2, and 40 CFR Section 63.2

B. OTHER LIMITS AND REQUIREMENTS hdr

CALCULATION METHOD (Summary)

The Permittee shall calculate, by the 15th of each month for the previouscompliance period, the VOC emissions for Group 003. After the first year ofoperation, the compliance period is 12 months.

VOC emissions = Gasoline Loading Emissions (Part 1) + Uncontrolled RemediationEmissions (Part 2) + Thermal Oxidizer Controlled Remediation Emissions (Part 3) +Catalytic Oxidizer Controlled Remediation Emissions (Part 4) < 74.3 tpy VOC

Title I Condition: Limit to avoid classification as amajor source under 40 CFR Section 52.21, 40 CFRSection 70.2 and 40 CFR Section 63.2

CALCULATION METHOD (Part 1):

Gasoline Loading Emissions = A x B x [8.34 x 10(-6)]

where:A = VOC concentration (mg/l) from most recent VCU stack performance test[Performance test 10/3/96 = 5.56 mg/l]

B = cumulative gallons of gasoline loaded during previous compliance period(either monthly limit according to FIRST-YEAR LIMITS section, or 12-month rollingsum limit after first year).

Note: This calculation does not include truck fugitive emissions

Title I Condition: Limit to avoid classification as amajor source under 40 CFR Section 52.21, 40 CFRSection 70.2, and 40 CFR Section 63.2

CALCULATION METHOD (Part 2)

Uncontrolled Remediation System Emissions (for each system) =C x D x [7.11 x 10(-5)] x [hours operated / 8760]

* where: C = VOC concentration from most recent bag sample in ppmv

D = average of weekly air flow measurements from remediation system in scfmover previous compliance period



Thermal Oxidizer Controlled Remediation System Emissions (for each system) =C x D x [7.11 x 10(-5)] x [hours operated / 8760] x [(100 - %control)/100]



%control is as listed in Group 004 - air pollution control equipment


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Facility Name:

Permit Number:


Catalytic Oxidizer Controlled Remediation System Emissions (for each system) =C x D x [7.11 x 10(-5)] x [hours operated / 8760] x [(100-%control)/100]



%control is as listed in Group 004 - air pollution control equipment

Title I Condition: Limit to avoid classification as amajor source under 40 CFR Section 52.21, 40 CFRSection 70.2 and 40 CFR Section 63.2

Recordkeeping: Records of gasoline throughput shall be kept on a daily basis. Title I Condition: Recordkeeping to avoid classificationas a major source for 40 CFR Section 52.21, 40 CFRSection 70.2 and 40 CFR Section 63.2

Monitoring: Record air flow through each remediation system once every week. Ifthe remediation system was not in operation during the week, note that in the airflow monitoring record.

Title I Condition: Monitoring to avoid classification as amajor source for 40 CFR Section 52.21, 40 CFRSection 70.2 and 40 CFR Section 63.2

Monitoring: For each remediation system, an airbag sample shall be taken monthlyusing EPA Method TO-3, EPA Method TO-14 or equivalent and analyzed todetermine the concentration of Benzene, Toluene, Ethylbenzene, Xylenes (BTEX)and Total Hydrocarbons (THC). A sample does not need to be taken if theremediation system was not operated at any time during the month.

Title I Condition: Monitoring to avoid classification as amajor source for 40 CFR Section 52.21, 40 CFRSection 70.2 and 40 CFR Section 63.2

Daily Recordkeeping Log: Each remediation system shall be equipped with ameter recording the total hours of operation. Each day that an operator is on site,the Permittee shall use the information from the hours meter to determine andrecord, in a log, the hours of operation for each day that each remediation unit is inuse. The log must provide a unique system for identifying each remediationsystem. If no remediation system is used, that should be noted as well.

Title I Condition: Recordkeeping to avoid classificationas a major source for 40 CFR Section 52.21, 40 CFRSection 70.2, and 40 CFR Section 63.2

Pre-authorized Changes: The Permittee is authorized to install and operateremediation systems under this permit, provided they meet the requirements ofGroup 003 (GP003). Prior to installation and operation of a new remediationsystem, the Permittee shall submit, on MPCA forms, the following information to theMPCA for its records:

1. Emission Unit information2. Stack/Vent information3. Control Equipment information, if appropriate4. Site Map with location of emission unit

Copies of these forms shall be maintained at the facility for the life of the permit.

Title I Condition: Limit to avoid classification as amajor source for 40 CFR Section 52.21, 40 CFRSection 70.2 and 40 CFR Section 63.2

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04500004 - 002

Facility Name:

Permit Number:

Subject Item: GP 004 Air Pollution Control Equipment for Remediation

Associated Items: CE 002 Direct Flame Afterburner

What to do Why to do itOPERATIONAL LIMITS for OPTIONAL AIR POLLUTION CONTROL EQUIPMENT hdr

Pre-authorized Changes: The Permittee is authorized to install and operate airpollution control equipment under this permit, provided they meet the requirementsof Group 004 (GP004).

Minn. R. 7007.0800, subp. 2

The Permittee may take credit for the operation of the control equipment describedin this section and in the emissions calculations section under Group 003, underthe following conditions:

1) The emissions from the emission unit are vented to the control equipmentduring the entire time period for which credit is taken; and2) The control equipment meets the requirements of this section

During time periods when credit is not taken, the requirements of this section do notapply.

Minn. R. 7007.0800, subp. 2

The Permittee shall operate and maintain each oxidizer any time the respectiveremediation equipment is in operation and credit is taken in the emissionscalculations detailed under Group 003.

Minn. R. 7007.0800, subp. 2

Operation and Maintenance of Oxidizers: The Permittee shall operate andmaintain each fabric filter in accordance with the Operation and Maintenance(O&M) Plan. The Permittee shall keep copies of the O&M Plan available onsite foruse by employees and MPCA staff.

Minn. R. 7007.0800, subp. 2

Alternative Operating Scenarios: The air pollution control equipment (APCE) usedby the Permittee can operate in two different modes - either as a thermal oxidizer oras a catalytic oxidizer. The terms and conditions for each scenario are listed belowand includes that the Permittee must record in a log a record of the scenario underwhich it is operating.

Minn. R. 7007.0800, subp. 11

Daily Recordkeeping Log: The Permittee must record daily, in a log, the hours ofoperation that the thermal oxidizer or catalytic oxidizer is in use. The log mustprovide a unique system for identifying each oxidizer (thermal or catalytic) andremediation system. If no oxidizer is in use, that should be noted as well.

Minn. R. 7007.0800, subp. 5 and 11

THERMAL OXIDIZER REQUIREMENTS (Scenario 1) hdr

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Volatile Organic Compounds greater thanor equal to 95 percent control efficiency.

Minn. R. 7007.0800, subp. 2 and 14

Combustion Temperature: Greater than or equal to 1380 degrees F (absoluteminimum), unless a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3,based on the average temperature recorded during the most recent MPCAapproved performance test where compliance for VOC emissions wasdemonstrated. If the temperature drops below the minimum temperature limit, theVOC used during that time shall be considered uncontrolled until the minimumtemperature limit is once again achieved.

Minn. R. 7007.0800, subp. 2 and 14

The Permittee shall maintain a continuous hard copy readout or computer disk fileof the temperature readings for the combustion chamber..

Minn. R. 7007.0800, subp. 4 and 5

Daily Monitoring: The Permittee shall physically check the temperature recordingdevice at least once each day that an operator is on site, to verify that it is workingand recording properly.

Minn. R. 7007.0800, subp. 4 and 5

Monitoring Equipment: The Permittee shall install and maintain thermocouples toconduct temperature monitoring required by this permit. The monitoring equipmentmust be installed, in use, and properly maintained whenever operation of themonitored control equipment is required.

Minn. R. 7007.0800, subp. 4

The Permittee shall maintain and operate a thermocouple monitoring device thatcontinuously indicates and records the combustion chamber temperature of thethermal oxidizer. The monitoring device shall have a margin of error less than thegreater of +/- 0.75 percent of the temperature being measured or +/- 2.5 degreesCelsius.

Minn. R. 7007.0800, subp. 4 and 5

Quarterly Inspections: At least once per calendar quarter, the Permittee shallinspect the control equipment internal and external system components, includingbut not limited to the refractory, heat exchanger, and electrical systems. ThePermittee shall maintain a written record of the inspection and any correctiveactions taken resulting from the inspection.

Minn. R. 7007.0800, subp. 4, 5, and 14

Annual Calibration: The Permittee shall calibrate the temperature monitor at leastannually and shall maintain a written record of the calibration and any actionresulting from the calibration.

Minn. R. 7007.0800, subp. 4, 5, and 14

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04500004 - 002

Facility Name:

Permit Number:

For periods when the thermal oxidizer is operated above the minimum combustionchamber temperature, the Permittee shall use either one of the following whencompleting calculations as required elsewhere in this permit:a. The overall control efficiency limit specified in this permit for this equipment(95%); orb. The overall control efficiency determined during the most recent MPCA approvedperformance test. If the tested efficiency is less than the efficiency limit in thispermit, the Permittee must use the tested value in all calculations until theefficiency is demonstrated to be above the permit limit through a new test.

Minn. R. 7007.0800, subp. 4 and 5

Corrective Actions: If the temperature is below the minimum specified by this permitor if the thermal oxidizer or any of its components are found during the inspectionsto need repair, the Permittee shall follow the O & M Plan for the oxidizer and takecorrective action as soon as possible. The Permittee shall keep a record of thetype and date of any corrective action taken.

Minn. R. 7007.0800, subp. 4, 5 and 14

CATALYTIC OXIDIZER REQUIREMENTS (Scenario 2) hdr

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Volatile Organic Compounds: greater thanor equal to 95 percent control efficiency.

Minn. R. 7007.0800, subp. 2 and 14

Temperature: Greater than or equal to 650 degrees F (absolute minimum) at theinlet unless a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3, basedon the average temperature recorded during the most recent MPCA approvedperformance test where compliance for VOC emissions was demonstrated. If thetemperature drops below the minimum temperature limit, the VOC used during thattime shall be considered uncontrolled until the minimum temperature limit is onceagain achieved.

Minn. R. 7007.0800, subp. 2 and 14

Sample Analysis: due before the end of each 24-month period following initiation ofoperation in the catalytic oxidizer mode. The Permittee shall send a representativesample of the catalyst to a laboratory to test the catalyst's destruction efficiency. Iftest results show a destruction efficiency of less than 95%, the Permittee shallfollow the corrective actions contained in the Operation and Maintenance Plan.

Minn. R. 7007.0800, subp. 4, 5 and 14

The Permittee shall maintain a continuous hard copy readout or computer disk fileof the inlet and outlet temperatures.

Minn. R. 7007.0800, subp. 4 and 5

Daily Monitoring: The Permittee shall physically check the temperature recordingdevice at least once each day that an operator is on site to verify that it is workingand recording properly.

Minn. R. 7007.0800, subp. 4 and 5

Monitoring Equipment: The Permittee shall install and maintain thermocouples formeasuring the temperatures as required by this permit. The monitoring equipmentmust be installed, in use, and properly maintained whenever the monitored controlequipment is required to be operated.

Minn. R. 7007.0800, subp. 4

The Permittee shall maintain and operate a thermocouple monitoring device thatcontinuously indicates and records both the inlet and outlet temperatures of thecatalytic oxidizer. The monitoring device shall have a margin of error less than thegreater of +/- 0.75 percent of the temperature being measured or +/- 2.5 degreesCelsius.

Minn. R. 7007.0800, subp. 4 and 5

Monthly Monitoring: At least once each month during normal operation, thePermittee shall record the temperature rise across the catalyst (outlet temp. - inlettemp.) while the process is running. If it is determined that the catalyst reactivityhas been impaired, by comparison of the observed temperature rise to the pasttemperature rise records, the Permittee shall follow the corrective actions in theOperation and Maintenance Plan. The Permittee shall maintain written records ofthe monitoring and any corrective actions taken.

Minn. R. 7007.0800, subp. 4, 5 and 14

Quarterly Inspections: At least once per calendar quarter, or more frequently ifrequired by the manufacturer specifications, the Permittee shall inspect the controlequipment internal and external system components, including but not limited to therefractory, heat exchanger, and electrical systems. The Permittee shall maintain awritten record of the inspection and any corrective actions taken resulting from theinspection.

Minn. R. 7007.0800, subp. 4, 5 and 14

Annual Calibration: The Permittee shall calibrate the temperature monitor at leastannually and shall maintain a written record of the calibration and any actionresulting from the calibration.

Minn. R. 7007.0800, subp. 4, 5 and 14

For periods when the catalytic oxidizer is operated above the minimum inlettemperature, the Permittee shall use either one of the following when completingcalculations as required elsewhere in this permit:a. The overall control efficiency limit specified in this permit for this equipment(95%); orb. The overall control efficiency, if determined during an MPCA approvedperformance test. If the tested efficiency is less than the efficiency limit in thispermit, the Permittee must use the tested value in all calculations until theefficiency is demonstrated to be above the permit limit through a new test.

Minn. R. 7007.0800, subp. 4 and 5

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04500004 - 002

Facility Name:

Permit Number:

Corrective Actions: If the temperature is below the minimum specified by this permitor if the catalytic oxidizer or any of its components are found during the inspectionsto need repair, the Permittee shall follow the O & M Plan for the oxidizer and takecorrective action as soon as possible. The Permittee shall keep a record of thetype and date of any corrective action taken

Minn. R. 7007.0800, subp. 4, 5 and 14

FUEL-BURNING REQUIREMENTS for OXIDIZER OPERATION hdr

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0610, subp. 1(A)(1)

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.

Minn. R. 7011.0610, subp. 1(A)(2)

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04500004 - 002

Facility Name:

Permit Number:

Subject Item: EU 001 Truck Loading Rack

Associated Items: CE 001 Flaring

GP 003 Gasoline Loading and Remediation Systems

SV 001 Loading Rack

What to do Why to do itA. POLLUTANT LIMIT hdr

Total Organic Compounds: less than or equal to 35 milligrams/liter of gasolineloaded. Compliance shall be determined in accordance with 40 CFR Section60.503(c).

40 CFR Section 60.502(b);Minn. R. 7011.1550

B. OTHER LIMITS AND REQUIREMENTS hdr

Loadings: Loadings of liquid product into gasoline tank trucks shall be limited tovapor-tight gasoline trucks using the following procedures. The Permittee shall:

1. Obtain the vapor tightness documentation described in 40 CFR Section60.505(b) for each gasoline tank truck which is to be loaded at the facility.2. Require the tank identification number to be recorded as each gasoline tanktruck is loaded at the facility.3. Cross-check each tank identification number with the file of tank vapor tightnessdocumentation within 2 weeks after the corresponding tank is loaded.4. Notify the owner or operator of each nonvapor-tight gasoline tank truck loaded atthe facility within 3 weeks after the loading has occurred.5. Take steps assuring that the nonvapor-tight gasoline tank truck will not bereloaded at the facility until vapor tightness documentation for that tank is obtained.6. Alternate procedures may be used upon application to, and approval by, theAdministrator.

40 CFR Section 60.502(e);Minn. R. 7011.1550

The Permittee shall act to assure that loadings of gasoline tank trucks at the facilityare made only into tanks equipped with vapor collection equipment that iscompatible with the terminal's vapor collection system.

40 CFR Section 60.502(f);Minn. R. 7011.1550

The Permittee shall act to assure that the terminal's and the tank truck's vaporcollection systems are connected during each loading of a gasoline tank truck atthe affected facility. This includes training drivers in the hookup procedures andposting visible reminder signs at the affected loading racks.

40 CFR Section 60.502(g);Minn. R. 7011.1550

The vapor collection and liquid loading equipment shall be designed and operatedto prevent gauge pressure in the delivery tank from exceeding 4,500 pascals (450mm of water) during product loading. This level is not to be exceeded during theperformance test when measured by the procedures specified in 40 CFR Section60.503(d).

40 CFR Section 60.502(h);Minn. R. 7011.1550

No pressure-vacuum vent in the bulk gasoline terminal's vapor collection systemshall begin to open at a system pressure less than 4,500 pascals (450 mm ofwater).

40 CFR Section 60.502(i);Minn. R. 7011.1550

Inspect: Each calendar month the vapor collection system, the vapor processingsystem, and each loading rack handling gasoline shall be inspected during theloading of gasoline tank trucks for total organic compounds liquid or vapor leaks.For purposes of this requirement, detection methods incorporating sight, sound, orsmell are acceptable.

40 CFR Section 60.502(j);Minn. R. 7011.1550

Recordkeeping and Repair: Each detection of a leak shall be recorded and thesource of the leak repaired within 15 days after each inspection.

40 CFR Section 60.502(j);Minn. R. 7011.1550

During performance testing, a pressure measurement device capable of measuringup to 500 mm of water gauge pressure with +/- 2.5 mm of water precision, shall becalibrated and installed on the terminal's vapor collection system. During theperformance test, the pressure shall be recorded every 5 minutes while a gasolinetruck is being loaded; the highest instantaneous pressure that occurs during eachloading shall also be recorded. Every loading position must be tested at least onceduring the performance test.

40 CFR Section 60.503(d)

The tank truck vapor tightness documentation shall be kept on file at the terminal ina permanent form available for inspection.

40 CFR Section 60.505(a);Minn. R. 7011.1550

A-9



04500004 - 002

Facility Name:

Permit Number:

The documentation file for each gasoline tank truck shall be updated at least onceper year to reflect current test results as determined by Method 27 or equivalentmethod. Trucks tested in accordance with 40 CFR Section 63.425(e) areconsidered to meet this requirement. This documentation shall include, as aminimum, the following information:

(1) Test title: Gasoline Delivery Tank Pressure Test -EPA Reference Method 27.(2) Tank owner and address.(3) Tank identification number.(4) Testing location.(5) Date of test.(6) Tester name and signature.(7) Witnessing inspector, if any: Name, signature, and affiliation.(8) Test results: Actual pressure change in 5 minutes, mm of water (average for 2runs).

40 CFR Section 60.505(b);Minn. R. 7011.1550

A record of each monthly leak inspection shall be kept on file at the terminal for atleast five (5) years and shall include, at a minimum:

1. Date of inspection2. Findings (no leaks, or nature and severity of leaks)3. Leak determination method4. Corrective action (date each leak repaired, reasons for the repair interval >15days)5. Inspector name and signature.

40 CFR Section 60.505(c);Minn. R. 7011.1550;Minn. R. 7007.0800, subp. 5

The Permittee shall keep documentation of all notifications required under 40 CFRSection 60.502(e)(4) on file at the terminal for at least five (5) years.

40 CFR Section 60.505(d);Minn. R. 7011.1550

The Permittee shall keep records of all replacements or additions of componentsperformed on an existing vapor processing system on site for at least five (5) years.

40 CFR Section 60.505(f);Minn. R. 7011.1550

Operation Requirement: At all times, including periods of startup, shutdown, andmalfunction, owners and operators shall maintain and operate any affected facilityincluding associated air pollution control equipment in a manner consistent withgood air pollution control practice for minimizing emissions. Determination ofwhether acceptable operating and maintenance procedures are being used will bebased on information which may include, but is not limited to, monitoringresults,opacity observations, review of operating and maintenance procedures andinspection.

40 CFR Section 60.11(d)

PERFORMANCE TESTING hdr

Performance Test: due before 07/24/2005 for Total Organic Compounds Minn. R. 7017.2020, subp. 1; 40 CFR Section60.502(h)

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See TableB for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy: due 105 days after each PerformanceTest

Minn. R. 7017.2030, subp. 1-4 and Minn. R.7017.2035, subp. 1-2

A-10



04500004 - 002

Facility Name:

Permit Number:

Subject Item: CE 001 Flaring

Associated Items: EU 001 Truck Loading Rack

What to do Why to do itFlares shall be operated at all times when emissions from gasoline loading may bevented to them.

Title I Condition: Limit to avoid classification as majorsource under 40 CFR Section 52.21; to avoid majorsource classification under 40 CFR Section 70.2; andto avoid major source classification under 40 CFRSection 63.2

Flares shall be operated with a flame present at all times during gasoline loading.The presence of a flare pilot flame shall be monitored using an ultraviolet sensor orany other equivalent device to detect the presence of a flame

Title I Condition: Monitoring of limit to avoidclassification as major source under 40 CFR Section52.21; 40 CFR Section 70.2; and 40 CFR Section 63.2

A-11

TABLE B: SUBMITTALSFacility Name: Amoco Oil Co - Spring Valley Terminal

Permit Number: 04500004 - 002

09/07/00

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table Aor, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately listone-time only and recurrent submittal requirements.

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send any application for a permit or permit amendment to:

Permit Technical AdvisorPermit SectionAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- changes that contravene a permit term.

Unless another person is identified in the applicable Table, send all other submittals to:

SupervisorCompliance Determination UnitAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George CzerniakAir and Radiation BranchEPA Region V77 West Jackson BoulevardChicago, Illinois 60604

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection AgencyClean Air Markets Division1200 Pennsylvania Avenue NW (6204N)Washington, D.C. 20460

B-1

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Amoco Oil Co - Spring Valley Terminal


09/07/00

What to send When to send Portion of Facility AffectedNotification of the date of EquipmentRemoval/Dismantlement

due 15 days after Equipment Removal and/orDismantlement . Submit the name andnumber of each unit and the date the unit wasremoved and/or dismantled.

Total Facility

B-2

TABLE B: RECURRENT SUBMITTALSFacility Name: Amoco Oil Co - Spring Valley Terminal


09/07/00

What to send When to send Portion of Facility AffectedSemiannual Deviations Report due 30 days after end of each calendar

half-year starting 07/24/2000. The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31.

Total Facility

Compliance Certification due 31 days after end of each calendar yearstarting 07/24/2000 (for the previous calendaryear). To be submitted on a form approvedby the Commissioner. This report covers alldeviations experienced during the calendaryear.

Total Facility

B-3

APPENDIX MATERIAL Facility Name: Amoco Oil Co - Spring Valley Terminal Permit Number: 04500004-002

APPENDIX I Insignificant Activities and General Applicable Requirements

The table below lists the insignificant activities that are currently at the facility and their associated general applicable requirements.

Minn. R. 7007.1300

, subp. Rule Description of the Activity

General Applicable Requirement

4(B) Potential emissions of 2.28 pounds per hour or actual emissions of one ton per year for particulate matter, particulate matter less than ten microns, nitrogen oxide, sulfur dioxide, and VOCs. The facility has 11 tanks at the facility which are considered insignificant sources. The combined PTE of these tanks is less than 2 tpy of VOCs.

Minn. R. 7011.2300

Under Minn. R. 7007.1250, subp. 1(A), the Permittee may add insignificant activities to the stationary source throughout the term of the permit without getting permit amendments. Certain exclusions apply and are listed in Minn. R. 7007.1250, subp. 2. In addition, this permit specifically prohibits the Permittee from making any modifications that would make the source major under NSR. The following table is a listing of the insignificant activities that the Permittee is somewhat likely to add and their associated applicable requirements.

Minn. R. 7007.1300



3(A) Fuel use: space heaters fueled by, kerosene, natural gas, or propane.

Minn. R. 7011.0510/0515

Minn. R. 7007.1300



3(H)

Miscellaneous:

1. total usage of less than 200 gallons of VOC (including hazardous air pollutant-containing VOC) combined in any consecutive 12 months period at a stationary source;

Minn. R. 7011.0710/0715 OR

Minn. R. 7011.0105/0110

3. equipment used for hydraulic or hydrostatic testing;

Minn. R. 7011.0710/0715

4. brazing, soldering or welding equipment; Minn. R. 7011.0510/.0515, Minn. R. 7011.0610 and Minn. R. 7011.0710/0715 (PM and opacity)

5. blueprint copiers and photographic processes; Minn. R. 7011.0105/0110 (opacity)

8. cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners.

Minn. R. 7011.0510/.0515, Minn. R. 7011.0610 and Minn. R. 7011.0710/0715 (PM and opacity)

3(J) Fugitive Emissions from roads and parking lots. Minn. R. 7011.0150 (PM)

3(K) Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source, such as spray painting of buildings, machinery, vehicles, and other supporting equipment.

Minn. R. 7011.0710/0715 (VOC)

Permit Action Number: Date: 1/6/2004

TECHNICAL SUPPORT DOCUMENT For

DRAFT AIR EMISSION PERMIT NO. 04500004-002 This technical support document is for all the interested parties of the draft permit. The purpose of this document is to set forth the legal and factual basis for the draft permit conditions, including references to the applicable statutory or regulatory provisions. 1. General Information 1.1. Applicant and Stationary Source Location:

Owner/Operator Address and Phone Number (list both if different)

Facility Address (SIC Code: 5171 )

BP Amoco

BP Amoco – Spring Valley Terminal

28100 Torch Parkway, Suite 4N

East Hwy 16, P.O. Box 47

Warrenville, IL 60555

Spring Valley, MN 55975

Attn: Yvan Beausoleil

Attn: Mr. Wayne Venter, terminal mgr

1.2. Description Of The Facility

BP Amoco owns and operates a bulk petroleum storage, pipeline distribution and truck distribution facility in Spring Valley, Minnesota. The facility has approximately 56 million gallons storage capacity and an annual capacity of approximately 440 million gallons through the 2-bay loading rack. The Title V permit for this facility was issued July 24, 2000. The pollutant emitted in greatest quantity from this facility is volatile organic compounds (VOCs). The emission unit that contributes most of VOC emissions from this facility is the loading rack, which is connected to a vapor recovery unit. Additional contributing emission units are remediation activities, product storage tanks, and fugitive emissions from the piping and trucks. Since the VOCs emitted contain hazardous air pollutants (HAPs), HAPs are also emitted from these emission units. Due to product releases at the facility, there are hydrocarbon impacts to the soil and groundwater. Remediation systems were authorized to be installed in the Title V permit and will consist of a system that utilizes air extraction from the subsurface. Monthly VOC limits, which also limit HAP emissions are in the permit for the loading rack and remediation systems.


1.3 Description of the Activities Allowed By This Permit Action

This is a major modification because it changes recordkeeping and monitoring for a Title I Condition. More variables were added to the VOC calculation for Group 003; hours of operation and optional credit for APCE. The permit contains daily recordkeeping for hours of operation for each remediation system, and each piece of APCE. As each piece of APCE can operate in two modes (thermal or catalytic oxidation), there is an alternative operating scenario to accommodate this. The permit pre-authorizes the installation and operation of oxidizers, either in the thermal mode or the catalytic mode of operation. Slight emissions increases are authorized for supplemental fuel-burning in the oxidizers. The Permittee does not expect to use supplemental fuel, as it would shut down the oxidizers if the waste stream was dilute enough to require additional fuel to operate.

1.4. Facility Emissions:

Table 1. Emissions Associated With the Modification

Pollutant

PTE from the modification (lb/hr)

PTE from the modification

(TPY)

Emission Increases or Decreases

Authorized with this Permit Action

NSR/ MACT Review Required (Yes or No)

Total Facility PTE (tpy)

PM 0.0059 0.026 0.026 No 0.026 PM10 0.0059 0.026 0.026 No 0.026 SO2 0.00047 0.002 0.002 No 0.002 NOx 0.073 0.32 0.32 No 7.69 VOC 0.0043 0.02 0.02 No 97.52 CO 0.031 .0136 0.136 No 18.56

Lead - - - No - HAPs

- - - No 19.10


Table 2. Permit Action Classification

Classification (put x in appropriate box)

Major/Affected Source

*Synthetic Minor *Minor

PSD (list pollutant)

VOC, HAPs

All others

NAAR (list pollutant)

All

Part 70 Permit Program (list pollutant)

VOC, HAPs All others

* Refers to potential emissions that are less than those specified as major by 40 CFR 52.21, 40 CFR pt. 51 Appendix S, and 40 CFR pt. 70. 2. Regulatory and/or Statutory Basis Table 4. Regulatory Overview

*EU, GRP, or

SV #

Applicable Regulations

**Comments

GP 003 Title I Condition Added hours of operation and optional use of APCE to VOC emission calculation.

GP 004 Minn. R. 7007.0800 Optional installation of APCE, pre-authorization for future APCE, alternative operating scenario would allow use of APCE in either thermal or catalytic oxidizer mode

3. Technical Information Group 004: Fuel-burning emission calculations from the supplemental fuel that could be used with the APCE are attached. Direct-heating equipment rule is met by equipment design, burning natural gas. Therefore, use default 0.3 grains/dry standard cubic foot PM limit. 4. Conclusion Based on the information provided by BP Amoco, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 04500004-002 and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Bonnie J. Nelson, Peggy Bartz (technical assistance) Attachment: General Information Forms, CD-01 Forms, Fuel-burning calculations.

AIR EMISSION PERMIT NO. 04500004- 002 IS ISSUED TO BP ... · AIR EMISSION PERMIT NO. 04500004- 002...

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