CHEMTRADE WEST US LLC – Permit to Operate with Changes to Permit Conditions and Exemption Determinations, (Air District Application 710209)
Summary
SCH Number
2026080035
Public Agency
Bay Area Air Quality Management District
(BAAQMD)
Document Title
CHEMTRADE WEST US LLC – Permit to Operate with Changes to Permit Conditions and Exemption Determinations, (Air District Application 710209)
Document Type
NOE - Notice of Exemption
Received
Posted
8/3/2026
Document Description
This permit action includes issuance of an exemption determination for sources deemed to be exempt from requiring a Permit to Operate and issuance of a revised Permit to Operate with changes to permit conditions.
The proposed scope of the Permit to Operate revisions includes exemption determinations for Sources 2, 5, 11, 20, 28, 29, 30, and 31, revisions of descriptions of Sources 1, 3, 10, 13, 16, 32 and Abatement device 5, and revisions to existing permit conditions. Sources 2, 5, 11, 20, 28, 29, 30, and 31 were determined to be exempt from requiring an Air District Permit to Operate per the exemption in Air
District Regulation 2, Rule 1, Section 123.2.1 (District Regulation 2-1-123.2 .1). The scope of Application 710209 consists of only administrative changes because the proposed permit changes do not include any physical changes to equipment or changes in the method of operation of any equipment.
Contact Information
Name
Kevin Perez
Agency Name
BAAQMD
Job Title
Senior Air Quality Engineer
Contact Types
Lead/Public Agency
Phone
Email
Name
Bashar Alwash
Agency Name
Chemtrade West US LLC
Job Title
Plant Manager
Contact Types
Project Applicant
Phone
Location
Cities
Richmond
Counties
Contra Costa
Regions
Citywide, Northern California
Cross Streets
Nearest Cross Street: Richmond Lane.
Other Location Info
525 Castro Street, Richmond, Contra Costa County, CA 94801. Nearest Cross Street: Richmond Lane.
Notice of Exemption
Exempt Status
Ministerial
Type, Section or Code
Sec. 21080(b)(1); 15268
Reasons for Exemption
Finding of Exemption:
The Air District has determined that the issuance of the revised Permit to Operate with changes to permit conditions, and exemption determinations under Application 710209 are exempt from CEQA for the following reasons:
• The Air District's administrative revisions to Permit Conditions 2051, 13215, and 20580, revisions to device descriptions, and exemption determinations do not constitute a "project" as defined in California Public Resources Code§ 21065, and CEQA Guidelines§ 15378; and/or
• The Air District has also determined that this approval is ministerial within the meaning of Public Resources Code§ 21080(b)(1), and CEQA Guidelines§ 15268(a).
Basis for Exemption:
The Air District's administrative revisions to Permit Conditions 2051, 13215, and 20580, revisions to device descriptions and exemption determinations do not constitute a "project" subject to CEQA. The California Public Resources Code §21065 defines a "project" as an activity which may cause either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the
environment, and which is any of the following: (a) An activity directly undertaken by any public agency; (b) an activity undertaken by a person which is supported, in whole or in part, through contracts, grants, subsidies, loans, or other forms of assistance from one or more public agencies; (c) an activity that involves the issuance to a person of a lease, permit, license, certificate, or other entitlement for use by
one or more public agencies. Neither the administrative revisions to Permit Conditions 2051, 13215, and 20580, revisions to device descriptions, nor the exemption determinations cause either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment.
Therefore, the administrative revisions under Application 710209 are not a project within the meaning of California Public Resources Code §21065 and CEQA Guidelines§ 15378 and not subject to CEQA.
In addition, the revisions in Application 710209 fit within fixed and objective standards, which did not allow for or require any subjective judgment or discretion to interpret or apply. Therefore, the Air District does not have discretion to deny the requested changes. The requested changes do not increase the potential to emit and do not amount to an increase over the actual emissions baseline, and are thus alterations, not modifications, within the meaning of District Regulations 2-1-233 and 2-1-234. Approval of Application 710209, issuance of the revised Permit to Operate, and the exemption determinations fit the criteria for approval of ministerial permit applications under District Regulation 2-1-428, and are ministerial and not subject to CEQA. (Public Resources Code§ 21080(b)(1); CEQA Guidelines§ 15268(a)).
County Clerk
Contra Costa
Attachments
Notice of Exemption
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