Phillips 66 San Francisco Refinery - Issuance of Alteration of Fixed Roof Tank, Source 140 (Air District Application 32248).


SCH Number
Public Agency
Bay Area Air Quality Management District (BAAQMD)
Document Title
Phillips 66 San Francisco Refinery - Issuance of Alteration of Fixed Roof Tank, Source 140 (Air District Application 32248).
Document Type
NOE - Notice of Exemption
Document Description
This permit action was to issue an Air District Permit to Operate to alter the following source: S-140 TANK #205 Fixed Roof Tank, 2,226,000 Gallon Capacity Phillips 66 San Francisco Refinery requested to replace the pressure relief valve (PRV) for S-140 Fixed RoofTank. The PRV is a safety and emergency pressure relief device that opens to let vapors out when the pressure inside the tank exceeds the PRV set pressure limit to prevent the tank from potentially exploding or an emergency release event at the tank or its associated equipment/piping. For S-140, the PRV opens and releases the vapors to a fuel recovery system if its set pressure is exceeded. The existing PRV needs to be replaced due to mechanical issues. The tank is currently permitted to operate with a minimum set pressure of 1.9 inches of water while the replacement valves currently available in the market have a recommended 1.5 inches of water set pressure rating. Decreasing set pressure from 1.9 to 1.5 inches of water is not expected to result in increased emissions or other impacts. The facility operates the tank at pressure levels close to 0.1 inches of water, so the valve only opens during upset conditions, which are rare and in short duration. Also, it is unlikely that there will be a significant difference in the frequency at which the replacement PRV will be triggered compared to the existing PRV. In addition, the organic liquids stored in S-140 are also blanketed by a layer of natural gas which acts as an abatement and controls the normal losses (i.e., minimizes fugitive emissions) that occur from the 1/2 loading/unloading of the tank. Furthermore, this tank is abated by a vapor recovery system, A-7, which routes any displaced organic vapors to a fuel system (S-338). The proposed change does not involve any physical changes resulting in pump capacity increases, changes to compressors, or changes to upstream and downstream equipment that result in any increases in capacities or criteria pollutant emissions.

Contact Information

Ali Roohani
Agency Name
Bay Area Air Quality Management District (Air District)
Job Title
Air Quality Engineer
Contact Types
Lead/Public Agency

Andrea Fabio
Agency Name
Phillips 66 San Francisco Refinery
Job Title
Environmental Specialist
Contact Types
Project Applicant


Contra Costa
Citywide, Countywide, San Francisco Bay Area
Cross Streets
8 and J Street
Other Location Info
1380 San Pablo Ave., Rodeo, Contra Costa County, CA 94572

Notice of Exemption

Exempt Status
Type, Section or Code
Sec. 21080(b)(1); 15268
Reasons for Exemption
Approval of this permit is not subject to CEQA because it is ministerial. The Air District's regulatory requirements that governed the approval of this project did not allow for any subjective judgement related to whether or how the project may be carried out. The project must comply with objective numerical standards in air permitting/engineering reference materials including permitting handbook Chapter 5.1 and permitting guidance documents from AP-42 Chapter 7.1. These fixed standards do not allow for or require any subjective judgment or discretion to interpret or apply. Additionally, the Air District is legally compelled to approve the project where it complied with these standards. Furthermore, this project did not trigger Best Available Control Technology (BACT) or BACT for toxics. Thus, the Air District's action was ministerial. Furthermore, the Air District's permit action is exempt because it permits an existing use and does not authorize any expansion of that existing use. 5-140 is an existing storage tank storing hydrocarbon materials and will continue to be in this service with no change or expansion in use. Further, the permit application materials, including the Engineering Evaluation and Appendix H to the application, demonstrate that the project has no potential for resulting in any new or increased impacts relative to existing operations.
County Clerk
Contra Costa


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