Phillips 66 Company - Modification of Permit to Operate for Silt Loading Factor, Sources 602, 603, and 605 (Air District Application 730535).
Summary
SCH Number
2026070734
Public Agency
Bay Area Air Quality Management District
(BAAQMD)
Document Title
Phillips 66 Company - Modification of Permit to Operate for Silt Loading Factor, Sources 602, 603, and 605 (Air District Application 730535).
Document Type
NOE - Notice of Exemption
Received
Posted
7/17/2026
Document Description
The Air District has issued a modification to the Permit to Operate for the following sources: S-602 Filter Aid Storage Silos (9) S-603 Polyethylene Removal Filter Aid Day Hoppers (4) S-605 Filter Aid Adsorption Day Hoppers (3)
Air District Application 31157 authorized the Rodeo Renewed Project (RRP), which proposed repurposing theRodeo Refinery to process renewable feed stocks into renewable fuels. As part of that application, Phillips 66 was required to conduct a test to demonstrate compliance with the 0.32 g/m2 silt loading factor for fugitive dust emissions from traffic on paved roads. The test was conducted on December 6, 2024, and the results indicated that the silt loading factor exceeded the permitted limit of 0.32 g/m2. Therefore, Phillips 66 submitted Air District Application 730535 to revise the permitted silt loading factor in Part 17 of Permit Condition 27646 to 0.62 g/m2. Emissions include fugitive dust which are a type of particulate matter (PM10 and PM2.5). The new silt loading factor increases PM10 emissions from 0.200 to 0.365 tons per year (tpy) and PM2.s emissions from 0.050 to 0.091 tpy. The initial estimates of the contemporaneous emission reduction credits (CERCs) from Air District Application 31157 equaled more than the full incremental cumulative increase for the RRP project for PM emissions. Therefore, there was an excess of 3.836 tpy of PM10 and 3.985 tpy on PM2.5. The initial estimates of CERCs were verified by Air District staff. However, the actual CERCs are based on the future shutdown dates and per Permit Condition 27646, the final CERCs will be adjusted based on the baseline period ending date when the emission reduction becomes enforceable. The final estimated CERCs from the shutdown sources (S-29, S-30, S-36, S-351, S-1002, and S-1002) are 5.808 tpy of PM10 and 5.808 tpy of PM2.5. Thus, the increase in PM10 and PM2.5 emissions will be offset using these CERCs. While S-602, S-603, and S-605, have toxic air contaminant (TAC) emissions, specifically of respirable silica, from material handling operations, there are no TACs associated with fugitive dust from vehicle travel on paved roads. Therefore, a Health Risk Assessment (HRA) is not required.
Contact Information
Name
Emily Schwartz,
Agency Name
Bay Area Air Quality Management District (Air District),
Job Title
Air Quality Engineer
Contact Types
Lead/Public Agency
Phone
Email
Name
Amit Palkar
Agency Name
Phillips 66 Company
Job Title
Senior Environmental Consultant
Contact Types
Project Applicant
Phone
Email
Location
Coordinates
Cities
Rodeo
Counties
Contra Costa
Regions
Countywide, Northern California, San Francisco Bay Area
Cross Streets
Road 8 and M Street
Zip
94572
Other Location Info
1380 San Pablo Avenue, Rodeo, Contra Costa County, CA, 94572
Nearest cross street is (internal) Road 8 and M Street.
Notice of Exemption
Exempt Status
Ministerial
Type, Section or Code
Sec. 21080(b)(1); 15268
Reasons for Exemption
Approval of this permit application 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 complied with objective numerical standards in air permitting/engineering reference materials. These fixed standards do not allow for or require any subjective judgment or discretion to interpret or apply. The Air District is legally compelled to approve the project where it complies with such standards. In addition, a Best Available Control Technology (BACT) determination was not required, since BACT was not triggered. Thus, the Air District's action was ministerial.
County Clerk
Contra Costa
Attachments
Notice of Exemption
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