Cherry Point Refinery – Blaine, Washington 2011 - 2013

Cherry Point Refinery – Blaine, Washington

2011 - 2013 Environmental Statement

October 2014

2011 - 2013 Environmental Statement Page 2 of 25



Foreword

The BP Cherry Point Refinery (Cherry Point) is proud of an outstanding record of environmental (HSE) leadership during forty three years of operation in Whatcom County. Within refining operations, Cherry Point seeks to achieve a competitive advantage through many efforts, including reducing environmental impacts. Leading the industry in producing environmentally friendly fuels and continuously reducing refinery emissions to air, land, and water is a priority. At Cherry Point, the commitment to protecting the environment in which employees work and the surrounding communities is taken very seriously. Obtaining International Standards Organization (ISO) 14001 Certification in 2002 and re-certification every 3 years is one of the ways that this commitment is demonstrated. Also, some regulatory requirements have helped drive environmental performance improvements. This 2011 - 2013 statement serves as the external communication of Cherry Point’s environmental performance.

Environmental Achievements

Cherry Point has accomplished many Environmental Achievements and Awards over the years, including:

1992 Washington State Department of Ecology, Certificate of Recognition, Five Year Pollution Prevention Plan

1993 Governor's Award for Outstanding Achievement in Pollution Prevention

1997 Whatcom County Land Trust, Conservation Partner

1999 Washington State Department of Natural Resources, Recognition Award for new ways of doing business to protect our natural resources.

1999 Washington State Department of Fish and Wildlife, Landowner of the Year for work enhancing fish and wildlife by pond development, planting food plots and leaving natural cover.

2000 U.S. EPA Clean Air Excellence Award for voluntary RVP reductions in Seattle, Washington

2001 Nooksack Salmon Enhancement Association, Certificate of Appreciation

2002 Nooksack Salmon Enhancement Association, Certificate of Appreciation, Business of the Quarter, Fall 2002

2003 U.S. Environmental Protection Agency and U.S. Department of Transportation award as one of the Best Workplaces for Commuters, helping to reduce traffic and air pollution

2003 Automation Services "Above & Beyond" award for participation in controls reclamation program.

2004 Clean Air Partner Award, August 5, 2004 from Puget Sound Clean Air Agency and from Whatcom County for producing clean fuels.

2004 – 2005

Landowner of the Year, 2004 & 2005 - Nooksack Salmon Enhancement Association

2005 PNWIS - A&WMA Environmental Achievement Award

2005 Association of Washington Business (AWB) Community Service Award for efforts to restore a salmon run

2006 Washington Waterfowl Association Corporate Wildlife Stewardship Award


2009 Nooksack Recovery Team - Salmon Summit Sponsor 2006 - 2009

2008 BP developed a migratory waterfowl habitat on refinery property in cooperation with WDFW and Ducks Unlimited.

2010 Wildlife Habitat Council - Wildlife at Work Certification 2009 - 2010

2009 Ducks Unlimited / Wildlife Habitat Council - Wings Over Wetlands Award

2002 to present

BP employees actively work to restore Terrell Creek on refinery property for reintroduction of salmon in conjunction with Nooksack Salmon Enhancement Association

2013 to present

In 2013 BP developed the Citizen Science Amphibian Monitoring Program. This is a multi-year program designed to learn more about wildlife and wildlife habitat on our property and to educate the public about some of the wildlife enhancement activities that are taking place on BP land. So far over 50 members of the community have participated in the program.

Community Involvement and Partnership

In addition, Cherry Point participates in many Community Involvement and Partnership activities that benefit the environment, including:

BP purchased and donated 180 acres of land to the Whatcom Land Trust in 2006 as a permanent conservation easement to maintain the third largest Great Blue Heron colony in the region.

BP donated spill response equipment in 2005 to the Birch Bay Village Community Club to help protect Birch Bay.

BP partners with Birch Bay State Park to provide environmental seminars, programs, and guided beach walks to the community after donating more than $100,000 in 2009 to help build an environmental classroom on State Park property called the BP Heron Center.

Cherry Point uses a communications and external affairs plan and relationship map to identify and manage relationships. We update the plan yearly to reflect new goals and to identify opportunities to build new relationships. We communicate with stakeholders on topics including: new projects, operational issues, safety training, and legislative and regulatory issues. Our stakeholders include local communities, non-governmental organizations (NGOs), local government, and media.


Introduction

In order to meet the goals of the BP Cherry Point Refinery Environmental Policy, the refinery has implemented an Environmental Management System (EMS) that is aligned to ISO 14001. Elements of the EMS are represented in the diagram below.

ISO 14001 is an international standard that provides a set of management principles. The overall goal is to provide continual improvement in environmental performance through a plan-do-check-act process and keeping the facility profitable and complying with legal requirements. The ultimate pursuit is no damage to the environment as stated in the environmental policy.

Cherry Point’s Environmental Policy speaks to our goals for continual improvement, which includes the refinery’s commitment to identify, evaluate, and implement pollution prevention opportunities regularly.

Reviewing results of the previous year’s performance and planning for the next year occurs at our environmental planning meetings; in Environmental Summit Series meetings; through our self-assessment program (internal audits); and at environmental management reviews with the refinery leadership team. Implementing improvement projects and operating the facility according to established procedures and training constitute implementation of the EMS.

Beginning in 2012, Cherry Point adopted the refinery’s Local Operating Management System (LOMS), which covers all of the site’s operations, as the management system to ensure the site meets the requirements of ISO 14001. It incorporates the same plan-do-check-act process formerly defined by the site in separate EMS procedures. Managing environmental programs as defined by the refinery’s LOMS provides for better alignment between environmental planning, implementation, and monitoring efforts and other refinery activities and processes.

The BP Cherry Point Refinery tracks progress in environmental performance consistent with the ISO 14001 standard by focusing on environmental aspects and impacts. This statement identifies several significant environmental aspects for Cherry Point operations and describes the significant impacts Cherry Point has on the environment. Environmental performance and planning is discussed in terms of these aspects and impacts in this statement.


Operations

BP Cherry Point Refinery began operating in 1971. The refinery was originally designed to process Alaska North Slope crude. The refinery has grown to be the largest in Washington State and has a nominal crude processing throughput of 165,000 barrels per day.

The refinery footprint encompasses 1.25 square miles and the total property owned by BP is 5.2 square miles (3,300 acres). At the time of our most recent ISO surveillance audit (Oct. 2013), there were 726 full time employees and approximately 1133 contractor jobs provided by the refinery. Cherry Point products include:

Gasoline — five grades for different locations

Jet Fuel — commercial and military

Diesel — three grades

Other Products — propane, butane, calcined coke, sulfur, carbon dioxide (CO2)

Cherry Point’s ISO 14001 certification includes activities associated with crude oil refining processes such as: dock and rail shipping and receiving activities, maintenance, waste management, contractor activities, and wastewater treatment. Truck loading racks not operated by the refinery, the Praxair Station, and off-site pipeline operations are excluded from the certification.



Environmental Aspects

Originally, in 2002, twenty three categories of environmental aspects were identified. These environmental aspects were ranked based on consideration of the frequency or likelihood of their occurrence and the potential severity of the associated impacts on the environment, public health, legal compliance, and corporate reputation. For each VES reporting period, the site identifies several significant aspects toward which our improvement efforts are focused. Identifying these significant aspects is initiated at environmental group planning meetings, periodically has included a survey of refinery personnel, and includes input from site management. For the period 2011 – 2013, four significant aspects are highlighted. The table below lists these significant environmental aspects and their associated environmental impact. In pursuit of the goal of no damage to the environment, the environmental management system provides a framework to manage and minimize these impacts.

2011 - 2013 Significant Environmental Aspects Environmental Impact

Discharge to Surface Water Environmental Damage (Waterways)

Atmospheric Relief Valves Reduced Air Quality

Carbon Dioxide (CO2) Emissions Climate Change GHG

Flare Emissions Environmental Damage (Air)

A description of each of the above significant aspects and associated impacts, methods of management, projects completed to improve performance in relation to the aspect, and future plans is included in Annex 1. Refinery performance in relation to each of these significant aspects, as well as other environmental aspects of interest, is discussed in the following sections.


Performance

Cherry Point is proud of the environmental performance on site. A number of programs and initiatives are in progress. This section discusses the refinery’s performance with regard to the significant environmental aspects highlighted for this VES reporting period and several other environmental aspects of interest. Each item is discussed under the heading of its associated area of potential environmental impact. Management system improvements are also occurring on a regular basis through the continuous improvement cycle described by our local operating management system (LOMS).

Air Quality

Cherry Point is committed to reducing air emissions. Three of the four significant environmental aspects focused on for this reporting period are related to air emissions: atmospheric release valves, CO2 emissions (GHG’s), and flare emissions. These environmental aspects are a top priority for Cherry Point. Some projects underway that address these environmental aspects can be found in Annex 1. Cherry Point also prioritizes reducing impacts from other pollutants that affect air quality.

Acid Rain

Burning fossil fuels and other refining operations result in emissions of air pollutants, which include sulfur dioxide and nitrogen oxide (SO2 and NOx). These gases react with chemicals in the atmosphere to form acids that fall back to the earth as “acid rain.” This acidification can damage rivers and lakes, vegetation, and even buildings. At Cherry Point, SO2 results from the combustion of fuels that contain sulfur. NOx emissions are generated from boilers and heaters, the calciners, crude tankers, and flares. In 2009, selective cataytic reduction was implemented on our new Boilers #6 and #7 resulting in reduced NOx emissions since that time. NOx emissions have been reduced since 2011 due to crude heater efficiency improvements (new convection section and new metallugy in fired section) and ultra-low NOx burners (ULNB) in several units. NOx emissions have been reduced


further with the construction of #2 H2 Plant. The new H2 Plant has a more efficient H2 heater that has reduced the load on the older H2 heaters.

CO emissions were up in 2012 due to significant repairs, maintenance, and project work planned and completed as part of a major TAR in multiple units and due to a fire in the crude unit. The February 2012 fire impacted all downstream units by the loss of feed from the crude unit. NOX and SO2 were emitted from the fire within the crude unit as well as from the high and low pressure flares. The estimated emissions from these sources were SO2 (2480 lbs from fire and 3571 lbs from flares) and NOX (740 lbs from fire and 1377 lbs from flares) for a total of 6231 lbs SO2 and 2117 lbs NOX. The actions necessary to shut down and/or circulate downstream units also resulted in an exceedance of the 1000 ppm SO2 (@ 7% O2)limit at the low pressure flare. No ambient air quality exceedance was logged at the on-site meteorological station. All required reporting obligations were met. See the Oil and Chemical Spills section of this statement for additional information about the crude oil release. Tanker ships in berth utilize their engines to provide power for the crude pumps and the ship’s hotel load. Due to the higher sulfur content of the fuels burned in the ship engines, tankers have historically contributed significant SO2 emissions to the overall refinery emissions profile. Marine SO2 emissions have been decreasing each year since 2007 as ships have begun using low sulfur fuels. The SO2 marine contribution for 2013 is down to 200 tons from 793 tons in 2007. Regulations that further limit marine fuel sulfur content are scheduled to go into effect in 2015. Also, Cherry Point is engaged with other Northwest stakeholders in establishing effective strategies to further reduce marine ship emissions. Emissions associated with marine activities at Cherry Point are shown in the chart below.

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Contribution of 2013 Marine Emsisions to Facility-wide Emissions

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Ozone

Volatile organic compound (VOC) and NOx emissions promote ozone formation. Ozone can trigger a variety of health problems and can damage plants and ecosystems. Ozone also contributes to visibility impairment or haze. The main sources of VOC emissions in the refinery are storage tanks, process equipment, pumps, compressors, piping components including valves and flanges, process wastewater transportation, and treatment systems. As previously stated, NOx emissions are generated from boilers and heaters, the calciner, crude tankers, and flares.

Climate Change

Greenhouse gas (GHG) traps heat and contributes to climate change. Cherry Point’s largest source of GHG emissions is carbon dioxide, followed by methane. Since 2001, Cherry Point has been tracking its GHG emissions and compiling a GHG emission inventory on an annual basis. The GHG emission trends and planned projects are discussed in the “Climate Change and Energy Consumption” section of this report.

Haze

As part of BP’s commitment to provide clean fuels, Cherry Point completed a new Ultra Low Sulfur Diesel Unit in 2013. This unit allows the refinery to produce diesels with lower benzene and sulfur contents for the West Coast.

Oil and Chemical Spills

Oil and chemical spills can cause serious damage to the environment, cause business and reputational impacts, and negatively affect operations. Therefore, it is very important for Cherry Point to minimize the occurrence and impact of spills and optimize spill prevention measures.

At Cherry Point, the Oil Spill Response Team manages spill events. The Team practices on-water equipment deployment at least two times a year. These drills help ensure the integrity of facilities that are used to transport, load, and unload oil and chemicals, as well as the infrastructure to respond to spills and their impacts. In addition, dock procedures for loading and unloading ships and the Oil Spill Response Plan are in place. These documents are maintained and updated regularly.

In the period 2011 – 2013, there were 3 marine spills, each significantly less than 1 gallon. Two were small leaks of hydraulic fluid and one was fire-fighting foam inadvertently discharged during the testing of a firewater monitor. There have been no marine spills in the last two years. Oil spill response drills are performed on an annual basis to assess refinery and agency response to a simulated spill. Other documents that are regularly updated with new ship information and operational procedures include the Port Information and Terminal Manual, Individual Load Plan for each ship, and the Oil Handling Facility Manual, which meets both Department of Ecology and Coast Guard requirements. A Cargo Safety Advisor is present during all loading and transfer activities on the north dock, as well as for new ships on the south dock. This advisor improves ship to shore communication and is trained to identify spill and safety hazards. Also, spill response kits are located throughout the facility to contain and clean any spills that occur before they can reach water.

Efforts to reduce marine spills have included, during previous VES reporting periods, replacing all dock lines over marine water and installing a surge system to reduce the possibility of a line rupture.


The sump at the south dock was replaced with a double walled sump with radar gauges to provide better secondary containment and leak protection. A firewater system was implemented to help remotely contain any fires that occur at the docks, and all the seals on the loading arms over the water were replaced. Annual inspections of the pipeline occur and the lines are also repainted as needed. Finally, a boom system is in place with the capacity to fully surround offloading ships, and a pressurized emergency release coupling device is used to help prevent spills during adverse weather conditions.

The categories “Marine Spills” and “Oil Spills > 1 BBL” are the same as previously reported in our VES. The category formerly reported as “Other Spills” was changed in name only to “Oil Spills > 1 BBL” to match the name of the same KPI that is regularly tracked by internal corporate reporting (aka Orange Book). Loss of primary containment (LOPC) is a KPI that the site began reporting internally in 2010 that captures additional lower impact spills.

The category “Marine Spills” includes any release to open marine waters and includes those as small as a drop or a cup. Each of the marine spills during this 3 year reporting period were significantly less than 1 gallon and were releases of hydraulic fluid that leaked from equipment or fire fighting foam accidentally released during testing of equipment. As seen in the above chart, there have been no marine spills in the last two years. The annual target for marine spills has been 0 for several years and is again our target for 2014. The category “Oils Spills > 1 barrel” is self descriptive. None of the spills reported above in this category were spills to water, and in fact in most cases they are spills contained in secondary containment within the process units. There is overlap between this category

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and the category “LOPC”, described below. In 2010, we began reporting the new metric “LOPC” in our Orange Book. This metric is loss of primary containment (LOPC), which includes all Spills > 1BBL, not only hydrocarbon but other substances as well. A target has been set for this KPI each year beginning in 2011.

Annual LOPC Target & Actual 2011 – 2013

Year Target Actual

2011 5 4

2012 4 4 (See Note 1 below)

2013 3 6

Note 1: As described in the Air Quality section, in February 2012 a fire occurred in the refinery crude unit that resulted in a release of approximately 33,100 gallons of crude oil in the unit. The response was timely and effective and there were no offsite impacts from the material released. The investigation determined that the failuire was a result of high temperature sulphidation on the 6” vacuum bottoms recirculation line.

Climate Change and Energy Consumption

Cherry Point’s principle metric for measuring energy performance is the Energy Intensity Index (EIITM) as defined by Solomon Associates Inc. and used worldwide as a standard method. This index allows comparison of the relative energy efficiency across the refining industry. Energy efficiency improvements result in a reduced EII score, indicating more efficient refinery production. Cherry Point’s energy efficiency has consistently been in the 1st or 2nd quartile of all US refineries, indicating the relatively high energy efficiency of the refinery. The Solomon Study is conducted bi-annually with the 2012 results published mid-2013. The 2012 Solomon Report shows that Cherry Point scored a 96 on the Energy Intensity Index, placing it in the 2nd quartile among US Refineries surveyed. Significant maintenance and project work in 2012 throughout the refinery caused much larger unit down times than normal. This was the primary reason for the drop to 2nd Quartile performance.


Cherry Point identified CO2 as a significant environmental impact, the production of which leads to greenhouse gas emissions. In 1997, BP as a corporation accepted that, while the scientific understanding of climate change and the impact of greenhouse gas emissions is still emerging, precautionary action is justified. Since then BP has been actively involved in policy debate, worked with others on mitigating technologies, and reduced the emissions from facilities.

At Cherry Point, quantifying and reducing, as feasible, greenhouse gas emissions are a part of operations. Cherry Point manages its greenhouse gas reduction program through energy efficiency improvements. Cherry Point’s process engineering and operations teams actively seek out and investigate potential energy efficiency projects around the refinery. The new Hydrogen plant and Diesel Hydrotreater, both commissioned in 2013, will help improve energy efficiency. Additional projects completed in the last 3 years include twisted tube exchanger bundle installation, upgrading large motors to more efficient models, and improving refinery-wide steam management and condensate recovery. Additionally, progress has been made enhancing process unit Key Energy Indicators, which will serve to help prioritize and in some cases quantify improvements that could be expected by proposed projects. Other energy efficiency projects already underway or planned for the future are identified in Annex 3.

86.6 (1st Quartile) 85.9 (1st Quartile)

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* Data for 2004-2008 are calculated using 2006 methodology. * Data for 2010-2012 are calculated using 2010 methodology.


Starting in 2010, the refinery began reporting GHG CO2 production values to EPA, as prescribed by 40 CFR 98. The new federal methodology for calculating CO2 for calciners is more conservative than the calculation used by the refinery in prior years. This led to the noticeable increase observed in overall CO2 emissions beginning in reporting year 2011.

Significant maintenance and project work in 2012 throughout the refinery contributed to decreased overall CO2 emissions due to heaters being down for extended periods. However, during the same period there was a smaller increase in “Total Natural Gas and Flare Combustion”.

Emissions from the hydrogen heaters were included above in the category “Net CO2 Produced in H2 Plant” for 2011 - 2013. Previously they were included in the category “Total Mixed Refinery Fuel Gas”. In 2013, a new Hydrogen plant and Diesel Hydrotreater were commissioned.

Waste Generation

Two environmental aspects are related to waste generation: hazardous waste management and resource use. Cherry Point manages hazardous waste in accordance with applicable regulations and looks for opportunities to reduce waste through its pollution prevention program. In order to reduce non-hazardous waste, the Cherry Point Refinery actively promotes a recycling program.


Recycling Program

Cherry Point promotes an active recycling program. Approximately 15 color-coded recycling centers are located throughout the refinery to manage aluminum cans, small metal scrap, harnesses, respirators, gauges, and plastic and glass.

The amount of materials collected through this program is continuing to grow. A large amount of the materials recycled are paper from office operations and cardboard from incoming shipment containers from the storehouse. Also included in the recycling program is paper towel debris. This is gathered and brought to a compositing facility where it is made into garden mulch and other products, including stormwater pollution reduction devices (BMPs).

Since its introduction, the recycling program has become a core concept in the way Cherry Point does business. The workforce has the ability to highlight any areas where we can increase recycling opportunities on-site. This includes everything from cans, paper, glass, and cardboard, to recycling materials such as scrap metal, asphalt, concrete, batteries, gauges, and even leather gloves.

Hazardous Waste Management

The majority of hazardous waste generated at the refinery is from catalyst replacement and solids removed from the oily water sewer.

Hazardous waste management is heavily regulated with respect to its handling and final disposal. Recycling and reclaiming of hazardous waste is a priority at Cherry Point, and waste minimization is an important consideration for the refinery. Hazardous waste that cannot be recycled or reclaimed is destroyed by incineration at out-of-state facilities that must adhere to strict EPA requirements. A third party auditing program is in place to assure that treatment and disposal facilities appropriately manage waste on our behalf.

Waste generation amounts fluctuate with corresponding years of major turnarounds and/or maintenance events. The graph below shows hazardous waste disposal rates from 2003 to 2013. The majority of reclaimed hazardous waste was spent catalyst, and the majority of the disposed or incinerated hazardous waste was sewer sludge and waste sludge. Reduction of hazardous waste generation is achieved by continuously striving for reclamation or recycling options for hazardous wastes and substitution of toxic chemicals with ones having less toxic properties. In 2012, we began regenerating spent carbon off-site as opposed to treating by thermal desorption off-site.

2012 produced an increased volume of hazardous waste derived from our largest ever cycle-ending turnaround event and also from additional maintenance activities performed in the refinery’s Crude Unit. The volume of hazardous waste dropped considerably in 2013 following completion of these unique activities.


BP personnel and contractors are trained annually on hazardous waste management. Waste planning is also a portion of planning for capital construction projects and turnaround planning.

Orange Book

The "Orange Book" is used by the BP Board of Directors to monitor the HSSE performance of all sites in the company. Incidents for Cherry Point that are recorded in the Orange Book include safety incidents (i.e., MIA’s, HiPOs, recordable injuries, vehicle accidents, Loss of Primary Containment, Fires, etc.) and environmental incidents (i.e. Spills, exceedances, etc.). The Orange Book defines quarterly reporting requirements and targets, and also promotes the identification of trends and the need for strategic interventions.

Employee Training & Knowledge

Employee training and knowledge contributes to Cherry Point’s record of protecting the environment. Proper training ensures that environmental releases are prevented and responded to quickly and appropriately.

BP Cherry Point has 731 full-time employees and an average of 300 contractors on site whose actions directly impact daily operations.


Training programs include:

Initial training for BP employees using computer based training and lecture. Annual computer based training for all BP employees on environmental issues. Initial and annual Environmental Handbook Training for BP employees. Initial training for contractors during HSSE Orientation. Annual contractor HSSE refresher training.

Feedback

Tell us what you think. Are our statements easy to understand, not detailed enough or perhaps too complicated?

Is there any further information in which you are interested? Let us know what you think so we can improve our environmental reporting. If you have any queries about this report or general operations, please contact Pamela Brady at [email protected] and she will be happy to assist.

The next BP Cherry Point Environmental Statement will be issued in 2017 and will cover the three year period 2014 – 2016.

mailto:[email protected]



ANNEX – Detailed Environmental Aspect Updates

There were nine significant environmental aspects identified during the risk ranking process. BP Cherry Point seeks to improve the refinery performance for these aspects, which are as follows:

1. Discharge to Surface Water

2. Releases from Atmospheric Relief Valves

3. Carbon Dioxide (CO2)/ GHG Emissions

4. Emissions from Flaring


Annex 1 - Discharge to Surface Water

Oil and chemical spills can be highly damaging to the environment, cause business and reputational impacts, and negatively affect operations.

Impact

Many different aspects of daily operations can contribute to discharges to surface water. Cherry Point operates a dock for ships to berth during loading and unloading of crude and refined oil products. In addition, piping and vessels contain hydrocarbons and oily wastewater.

Management

BP conducts oil spill drills as specified in WAC 173.182 and 33 CFR 154 every year. The Oil Spill Response Team practices on-water equipment deployment a minimum of two times per year.

Operate in accordance with strict procedures focused on preventing unpermitted releases from entering the water.

Operate with safety controls such as leak detectors, warning alarms, and automatic system shutdowns.

Record incidents and set targets to reduce the number of spills. Update the dock procedures periodically to improve management of loading and

unloading of oil from ships. Boom system will fully surround ships offloading at the dock. Surge system reduces possibilty of a line rupture. Ensure the integrity of facilities used to transport, load, and unload oil and chemicals. Ensure that an infrastructure is in place to deal effectively with spills and their impacts.

Performance

There were 3 spills to marine water in 2011 - 2013. Each of the marine spills during this 3 year reporting period were significantly less than 1 gallon and were releases of hydraulic fluid that leaked from equipment or fire fighting foam accidentally released during testing of equipment.

Conducted oil spill drills to assess refinery and agency response to a simulated spill. Replaced seals in loading arms at dock. Conducted inspection and integrity testing of dock pipelines and loading arms. Updated Oil Spill Response Plan and Spill Prevention Control and Countermeasure

Plan. In 2012 – 2013 new valving was installed to divert SW when needed to reduce the

potential for overloading of the wastewater treatment plant if we were to experience a historical rain event(s).

In 2012 the treatment efficiency of the wastewater treatment plant was increased after completing a study and implementing recommendations.

Addressed Environmental Concerns at Fire Training Grounds (Project #563)

Future Plans

Project #721 – 724 – Tank Seals / Inspection Double Bottom Improvement. Address Parking Lot Sheen (EAP #3) Catch Basin Labeling Program (EAP #10)


Annex 2 - Releases from Atmospheric Relief Valves

Atmospheric relief valves (ARVs) are safety devices that relieve pressure to the atmosphere during unit upsets.

Impact

The gases that atmospheric relief valves release can pose environmental and health hazards. Atmospheric relief valves are located throughout the process units at the refinery. Although ARVs cannot be eliminated from refinery operations, the potential for atmospheric releases can be decreased through instrumentation.

Management

Minimization of atmospheric releases through the Relief System Improvement Project. Routine LDAR monitoring of ARVs. Risk evaluation using Layers of Protection Analysis (LOPA).

Performance

Over 400 ARVs at the refinery. Dispersion modeling and LOPA of ARVs were used to determine if ARV releases

should be routed to a closed system or mitigated with measures such as basic process control systems and safety instrumented systems.

Removed #1 DHDS atmospheric blowdown. Mitigation of ARV releases in the Crude and Coker units during the 2011 Turnaround

(Project #1099) Mitigation of ARV releases in the Hydrocracker, Light Ends, and Reformer units for the

2012 Turnaround. (Project #1099) Mitigation of #1 DHDS ARV releases in 2013 tournaround. (Project #1099)

Future Plans

Continued Relief System Improvement Project #1119


Annex 3 - Carbon Dioxide (CO2) / GHG Emissions

Carbon dioxide is one of the greenhouse gasses (GHG) as identified by the Intergovernmental Panel on Climate Change (IPCC). Global warming potential (GWP) is a measure of how much a given mass of GHG is estimated to contribute to global warming. Greenhouse gases contribute to climate change, which may lead to a number of human and ecological health hazards.

Impact

Sources of CO2 emissions from the refinery include combustion processes (heaters, boilers for producing process steam, coke production and coke calcining). CO2 represents over 99.9% of Cherry Point’s greenhouse emissions.

Management

High precedence is given to energy efficiency projects at the refinery. Compliance with fast-changing federal and state climate change policies.

Performance

Significant maintenance and project work in 2012 in the Crude unit contributed to decreased overall CO2 emissions due to heaters being down for extended periods. However, during the same period there was a smaller increase in “Total Natural Gas and Flare Combustion”. See GHG graph on page 16.

Selective catalytic reduction on our new Boilers #6 and #7 have reduced SO2 emissions from those sources.

Prepared for the management of GHG in accordance with the EPA GHG Mandatory Reporting Rule, which included assurance of fuel measuring device calibrations, and continued development of the GHG Monitoring Plan.

Negotiated a determination of non-significance (CO2) for #3 Diesel Unit. Pursued a number of energy efficiency projects. Updated the GHG Monitoring Plan as necessary. Continue to manage GHG to be in compliance with fast-changing federal and state

climate change policies.

Future Plans

Boilerhouse Optimization (Project #650) - 2014 Advanced Control Systems – 2013 through 2015 #1 Reformer – Added HX area – 2015 Crude Preheat HX cleaning – 2017 New Coker Heater – 2017 #1 Reformer Compressor Overhaul - 2018 Heater – Boiler MACT implementation (EAP #20) WA Greenhouse Gas RACT (EAP #24)


Annex 4 - Emissions from Flaring

Flaring is a necessary safety device to relieve pressure in the refinery. Flaring prevents atmospheric releases of various refinery fuel gases.

Impact

Flaring contributes to NOx, SO2, and particulate emissions.

Management

The Hydrocarbon Flaring Pollution Minimization Plan is used when planning turnarounds to reduce flaring.

Energy engineer works to determine / communicate total energy demand so that refinery can work to reduce fuel gas usage.

Performance

Significant maintenance and project work in 2012 in the Crude unit contributed to an increase in flare combustion during that period, otherwise flare combustion has remained relatively flat. See GHG graph on page 16 for data.

Future Plans

Relief System Improvement Project to optimize the flaring system and reduce unnecessary flaring events.

Continue to identify flare reduction projects. NSPS Ja Implementation (EAP #21) Add CEMS units to flares

Documents

Cherry Point Refinery – Blaine, Washington 2011 - 2013