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Home My WebLink AboutDAQ-2024-0051791 DAQC-192-24 Site ID 10119 (B1) MEMORANDUM TO: FILE – CHEVRON PRODUCTS COMPANY – Salt Lake Refinery THROUGH: Harold Burge, Major Source Section Manager FROM: Joe Rockwell, Environmental Scientist DATE: August 21, 2023 SUBJECT: PARTIAL COMPLIANCE EVALUATION (PCE #1 of #4) – LDAR – Major, Davis County, FRS ID# UT0000004901100003 ______________________________________________________________________ INSPECTION DATE: August 15 and 16, 2023 SOURCE LOCATION: 2351 North 1100 West, North Salt Lake, Utah MAILING ADDRESS: 685 South Chevron Way, North Salt Lake, UT 84054 SOURCE CONTACT: Lauren Vander Werff, Environmental Team Lead, 801-539-7386 lvanderwerff@chevron.com OPERATING STATUS: Operating PROCESS DESCRIPTION: Chevron Products Company is required to monitor components such as valves, pumps, compressors, drains, and vents for VOC and VHAP leaks. Regulations require visual monitoring as well as portable analyzer monitoring following EPA Method 21. Chevron keeps records of all results, repairs, and monitoring conducted, and is required to submit quarterly and semi-annual reports to comply with the regulations. Currently, Chevron is conducting monitoring as required by the state rule and federal regulations. Additionally, Chevron has entered into a Consent Decree (C.D.) with the EPA to perform an LDAR enhancement program to further minimize fugitive emissions of VOC and VHAP from equipment in light liquid and/or gas/vapor service. APPLICABLE REGULATIONS: Utah Administration Code (UAC) R307-326 – Control of Hydrocarbons in Refineries 40 CFR 63 Subpart CC – Equipment Leaks Standard, Reporting and Recordkeeping 40 CFR 60 Subpart GGGa – Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries for Which Construction, Reconstruction, or Modification Commenced After November 7, 2006 40 CFR 60 Subpart VVa – Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry for Which Construction, Reconstruction, or Modification Commenced After November 7, 2006 2 SOURCE INSPECTION EVALUATION: UAC R307-326 Control of Hydrocarbon Emissions at Refineries R307-326-9 Leaks from Petroleum Refinery Equipment. (1) The owner or operator of a petroleum refinery complex shall develop and conduct a VOC monitoring program and shall follow the recording, reporting, and operating requirements consistent with R307-326-9. The monitoring program shall be submitted 30 days prior to start up of the petroleum refinery complex or as determined necessary by the executive secretary. Status: In compliance – A VOC monitoring program has been developed and is conducted in accordance with R307-326-9. Quarterly and annual VOC reports have been submitted. (2) Any affected component within a petroleum refinery complex found to be leaking shall be repaired and retested as soon as practicable, but not later than fifteen (15) days after the leak is detected. A leaking component is defined as one that has a concentration of VOCs exceeding 10,000 parts per million by volume (ppmv) when tested by a VOC detection instrument at the leak source in the manner described in 40 CFR 60, Appendix A, Reference Method 21, using methane or hexane as the calibration gas. Components not subject to New Source Performance Standards Subpart GGG shall use methane or hexane as calibration gas, provided a relative response factor for each individual instrument is determined for the calibration gas used. Those leaks that cannot be repaired until the unit is shut down for turnaround shall be identified with a tag and recorded as per (6) below and shall be reported as per (7) below. The executive secretary, in coordination with the refinery owner or operator, may require early unit turnaround based on the number and severity of tagged leaks awaiting turnaround. Status: In compliance – First attempts of leak repairs are made immediately by contractor Hydrochem PSC. If a component is not repairable immediately it is reported and repaired within 15-days unless it needs to be placed on the delay of repair list. The leak definitions in the EPA’s Consent Decree are more stringent than state or federal regulations. (3) Monitoring Requirements. (a) In order to ensure that all existing VOC leaks are identified and that new VOC leaks are located as soon as practicable, the refinery owner or operator shall perform necessary monitoring using visual observations when specified or the method described in 40 CFR 60, Appendix A, Reference Method 21, as follows: (i) Monitor at least one time per year (annually) all pump seals, valves in liquid service, and process drains; (ii) Monitor four times per year (quarterly) all compressor seals, valves in gaseous service, and pressure relief valves in gaseous service; (iii) Monitor visually 52 times per year (weekly) all pump seals; (iv) Monitor within 24 hours (with a portable VOC detection device) or repair within 15 days any pump seal from which liquids are observed dripping; (v) Monitor any relief valve within 24 hours after it has been vented to the atmosphere; (vi) Monitor immediately after repair any component that was found leaking; (vii) For all other valves considered "unsafe-to-monitor" or inaccessible during an annual inspection, the owner or operator shall document to the executive secretary the number of valves considered "unsafe-to- monitor" or inaccessible, the dangers involved or reasons for inaccessibility, the location of these valves, and the procedures that the owner or operator shall follow to ensure that the valves do not leak. The documentation for each calendar year shall be submitted for approval to the executive secretary 15 days after the last day of each calendar year. At a minimum, the inaccessible valves shall be monitored at least 3 once per year (annually). (b) For the purpose of R307-326, gaseous service for pipeline valves and pressure relief valves is defined as the VOCs being gaseous at conditions that prevail in the components during normal operations. Pipeline valves and pressure relief valves in gaseous service and other components subject to leaks shall be noted or marked so that their location within the refinery complex is obvious to the refinery operator performing the monitoring and to the State of Utah, Division of Air Quality. Status: In compliance – Leak monitoring is performed and recorded in the Skybridge database as required. Annual Difficult-to-Monitor (DTM) reports are submitted. See status of condition (1). (4) Exemptions. The following are exempt from the monitoring requirements of (3) above: (a) Pressure relief devices that are connected to an operating flare header, firebox, or vapor recovery devices, storage tank valves, and valves that are not externally regulated; (b) Refinery equipment containing a stream composition less than 10 percent by weight VOCs; and (c) Refinery equipment containing natural gas supplied by a public utility as defined by the Utah Public Service Commission. Status: In compliance – Pressure relief devices are vented to the flares (except at crude units, LPG spheres, boilers, HDN, TCLR, and the Tank Field) and are exempt from this rule. However, Chevron is monitoring flare headers. Product streams meeting the requirements of b and c above are not monitored, such as heavy liquid equipment. Refinery equipment listed in (b) and (c) are exempt. (5) Alternate Monitoring Methods and Requirements. (a) If at any time after two complete liquid service inspections and five complete gaseous service inspections, the owner or operator of a petroleum refinery can demonstrate that modifications to (3) above are in order, he may apply in writing to the Air Quality Board for a variance from the requirements of (3) above. (b) This submittal shall include data that have been developed to justify the modification to (3) above. As a minimum, the submittal should contain the following information: (i) the name and address of the company; (ii) the name and telephone number of the responsible company representative; (iii) a description of the proposed alternate monitoring procedures; and (iv) a description of the proposed alternate operational or equipment controls. Status: In compliance – Chevron previously operated under the skip monitoring plan that was approved by the Air Quality Board on June 9, 1994. Chevron is now operating under an EPA consent decree. Quarterly-skip-monitoring, that is applicable with Federal regulations, is currently being utilized. 4 (6) Recording Requirements. Identified leaks shall be noted and affixed with a readily visible and weatherproof tag bearing the identification of the leak and the date the leak was detected. The tag shall remain in place until the leaking component is repaired. The presence of the leak shall also be noted in a log maintained by the operator or owner of the refinery. The log shall contain, at a minimum, the name of the process unit where the component is located, the type of component, the tag number, the date the leak is detected, the date repaired, and the date and instrument reading when the recheck of the component is made. The log should also indicate those leaks that cannot be repaired until turnaround, and summarize the total number of components found leaking. The operator or owner of the refinery complex shall retain the leak detection log for two years after the leak has been repaired and shall make the log available to the executive secretary upon request. Status: In compliance – Identified leaks are tagged with a readily visible and weatherproof tag that meets the requirements of this condition. Leaks are logged into the SkyBridge database, which is used to track all leak information. The leak information gathered in this database exceeds the requirements of this condition. (7) Reporting Requirements. The operator or owner of a petroleum refinery complex shall submit a report to the executive secretary by the 15th day of January, April, July, and October of each year listing the total number of components inspected, all leaks that have been located during the previous 3 calendar months but not repaired within 15 days, all leaking components awaiting unit turnaround and the total number of components found leaking. In addition, the refinery operator or owner shall submit a signed statement with each report that all monitoring has been performed as stipulated in R307-326-9. Status: In compliance – Leak monitoring is performed and recorded in the Skybridge database as required. Quarterly reports are submitted. See status of condition (1). (8) Additional Requirements. Any time a valve, with the exception of safety pressure relief valves, is located at the end of a pipe or line containing VOCs, the end of the line shall be sealed with one of the following: a second valve, a blind flange, a plug or a cap. This sealing device shall only be removed when the line is in use for sampling. Status: In compliance – Open ended valves or lines are sealed with caps, plugs, or a second valve. 40 CFR 63 Subpart CC – National Emission Standards for Hazardous Air Pollution for Petroleum Refineries 63.648 Equipment Leak Standards (in organic HAP service) (a) Each owner or operator of an existing source subject to the provisions of this subpart shall comply with the provisions of 40 CFR part 60 subpart VV and paragraph (b) of this section except as provided in paragraphs (a)(1), (a)(2), and (c) through (i) of this section. Each owner or operator of a new source subject to the provisions of this subpart shall comply with subpart H of this part except as provided in paragraphs (c) through (i) of this section. (1) For purposes of compliance with this section, the provisions of 40 CFR part 60, subpart VV apply only to equipment in organic HAP service, as defined in §63.641 of this subpart. 5 (2) Calculation of percentage leaking equipment components for subpart VV of 40 CFR part 60 may be done on a process unit basis or a sourcewide basis. Once the owner or operator has decided, all subsequent calculations shall be on the same basis unless a permit change is made. Status: In compliance – Chevron is an existing refinery choosing to comply with Subparts VVa and more stringent consent decree requirements. Semi-annual reports are submitted. 40 CFR 60 Subpart GGGa - Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries 60.590a Applicability and designation of affected facility. (a) (1) The provisions of this subpart apply to affected facilities in petroleum refineries. (2) A compressor is an affected facility. (3) The group of all the equipment (defined in § 60.591a) within a process unit is an affected facility. (b) Any affected facility under paragraph (a) of this section that commences construction, reconstruction, or modification after November 7, 2006, is subject to the requirements of this subpart. (c) Addition or replacement of equipment (defined in § 60.591a) for the purpose of process improvement which is accomplished without a capital expenditure shall not by itself be considered a modification under this subpart. (d) Facilities subject to subpart VV, subpart VVa, subpart GGG, or subpart KKK of this part are excluded from this subpart. (e) Stay of standards. Owners or operators are not required to comply with the definition of “process unit” in § 60.590 of this subpart until the EPA takes final action to require compliance and publishes a document in the Federal Register. While the definition of “process unit” is stayed, owners or operators should use the following definition: Status: N/A – On June 13, 2014, Chevron submitted a notification to the DAQ to voluntarily accept the applicability of NSPS Subpart GGGa for all refinery process units at the facility. Currently the refinery is not applicable to the rule. The SkyBridge database, used by the refinery, lists Subpart GGGa compressors and equipment. Semi-annual reports are submitted. 60.592a Standards. (a) Each owner or operator subject to the provisions of this subpart shall comply with the requirements of §§ 60.482–1a to 60.482–10a as soon as practicable, but no later than 180 days after initial startup. Status: See below for compliance status. 60.592a(a) requires Chevron to comply with the standards set forth in 40 CFR 60 Subpart VVa, Standards for equipment leaks of VOC in Synthetic Organic Chemical Manufacturing Industry. 6 60.592a (b) For a given process unit, an owner or operator may elect to comply with the requirements of paragraphs (b)(1), (2), or (3) of this section as an alternative to the requirements in § 60.482–7a. (1) Comply with § 60.483–1a. (2) Comply with § 60.483–2a. (3) Comply with the Phase III provisions in § 63.168, except an owner or operator may elect to follow the provisions in § 60.482–7a(f) instead of § 63.168 for any valve that is designated as being leakless. Status: In compliance – 60.592(b) gives Chevron the option to comply with an alternative to the requirements of 60.482-7a (valves in gas vapor and light liquid service). Chevron is using the alternative monitoring plan approved under the consent decree. It is based on the percent leak rate of 2% on a unit-by-unit basis. 60.592a (c) An owner or operator may apply to the Administrator for a determination of equivalency for any means of emission limitation that achieves a reduction in emissions of VOC at least equivalent to the reduction in emissions of VOC achieved by the controls required in this subpart. In doing so, the owner or operator shall comply with requirements of § 60.484a. Status: N/A 60.592a (d) Each owner or operator subject to the provisions of this subpart shall comply with the provisions of § 60.485a except as provided in § 60.593a. (e) Each owner or operator subject to the provisions of this subpart shall comply with the provisions of §§ 60.486a and 60.487a. Status: See below for compliance status. Chevron must comply with the testing methods and procedures, recordkeeping and reporting requirements of 40 CFR 60 Subpart VV. 60.593a Exemptions. (b) Compressors in hydrogen service are exempt from the requirements of 60.592a if an owner or operator demonstrates that a compressor is in hydrogen service. Status: In compliance – The UACR requires quarterly monitoring of all compressor seals and has no exemptions as allowed in this subpart. Thus, Chevron is monitoring all compressors at this time. Records required by 40 CFR 63.655a(d)(3) are kept in the SkyBridge database regarding compressors in hydrogen service. Quarterly, semi-annual, and annual reports are submitted. 7 60.593a (c) Any existing reciprocating compressor that becomes an affected facility under provisions of § 60.14 or § 60.15 is exempt from § 60.482–3(a), (b), (c), (d), (e), and (h) provided the owner or operator demonstrates that recasting the distance piece or replacing the compressor are the only options available to bring the compressor into compliance with the provisions of § 60.482–3(a), (b), (c), (d), (e), and (h). Status: In compliance – Chevron is currently not using this exemption. 60.593a (d) An owner or operator may use the following provision in addition to § 60.485a(e): Equipment is in light liquid service if the percent evaporated is greater than 10 percent at 150 ° C as determined by ASTM Method D86–78, 82, 90, 95, or 96 (incorporated by reference as specified in § 60.17). Status: N/A 60.593a (e) Pumps in light liquid service and valves in gas/vapor and light liquid service within a process unit that is located in the Alaskan North Slope are exempt from the requirements of § 60.482–2a and § 60.482–7a. Status: N/A 60.593a (f) Open-ended valves or lines containing asphalt as defined in § 60.591 are exempt from the requirements of § 60.482–6(a) through (c). Status: N/A 40 CFR 60 Subpart VVa-Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry This NSPS parallels the 40 CFR 60, Subpart VV standards and also includes different standards for pumps in light liquid service (2,000 ppm instead of 10,000 ppm) and valves in gas/vapor or light liquid service (leak definition is 500 ppm instead of 10,000 ppm) as well as additional instrument calibration changes and recordkeeping requirements. Furthermore, this NSPS includes monitoring and repair requirements for connectors. 60.482-1a Standards: General. (b) Compliance with 60.482-1a to 60.482-10a will be determined by review of records and reports, review of performance test results, and inspection using the methods and procedures specified in 60.485a. Status: In compliance – Chevron is going on an action level of 100 ppm for leaking components. Records maintained in the SkyBridge database were reviewed at time of the inspection. Semi-annual reports are submitted. 8 60.482-2a Standards: Pumps in light liquid service. Status: In compliance – Pumps are monitored on a monthly basis under a leak definition of 2,000 ppm VOC. Records maintained in the SkyBridge database show that pumps are monitored and repaired as required. Some pumps have a VOC collection system while others have dual mechanical seals. 60.482-3a Standards: Compressors. Status: In compliance – Compressors are equipped as required and are monitored for leaks. Pumps are vented to a nitrogen purge system (doghouse). The emissions are drawn off the doghouse and sent to the new FVR which is then vented back into the plant gas system. Records are maintained in the SkyBridge database. 60.482-4a Standards: Pressure relief devices in gas/vapor service. Status: In compliance – Some pressure relief devices (PRDs) are piped to the flare system and are exempt from monitoring requirements. Other PRDs vent to the air and are monitored in accordance with the standard. These are monitored within 24 hours after release. Flare headers are monitored and are not considered vacuum systems. Records are maintained in the SkyBridge database. 60.482-5a Standards: Sampling connection systems. Status: In compliance – A closed purge system using nitrogen is utilized. Most sampling connection systems are a closed loop system or double needle or double gate valve system. No VOC emissions exit to the atmosphere from the closed systems. 60.482-6a Standards: Open-ended valves or lines. Status: In compliance – Open ended valves or lines are equipped with caps, plugs, or a second valve. 60.482-7a Standards: Valves in gas/vapor service and in light liquid service. Status: In compliance – Valves in gas/vapor and light liquid service are monitored and repaired as required. DTM reports are submitted annually. Records are maintained in the SkyBridge database. 60.482-8a Standards: Pumps and valves in heavy liquid service, pressure relief devices in light liquid or heavy liquid service, and flanges and other connectors. Status: In compliance – Pumps and valves in heavy liquid service, pressure relief devices in light liquid or heavy liquid service, and flanges and other connectors are monitored and repaired as required. Records are maintained in the SkyBridge database. 60.482-9a Standards: Delay of repair. Status: In compliance – Delay of repair records are kept in the Skybridge database and were reviewed. Leaking valves all contain weatherproof tags and all reporting requirements have been met. 9 60.482-10a Standards: Closed vent systems and control devices. Status: In compliance – The SWS, Ammine Plant, HDS, SRU, VGO, Coker, and HDN vent to Flare #1. The jet fuel treater plant, GRU, FCC, LPG, SWS2, Amine2, SRU2, TGU2, FLR, and alky pilot plant vent to Flare #2. The reformer ISO alky and Isom vent to Flare #3. The plants that vent to flares #1 and #2 pass through the FVR first to reroute relief products into the fuel gas system. The plants that tie into Flare #3 do not pass through the FVR due to potential for HF in the relief. Flare #1 and #2 will only flare product when the flare vapor recovery system is non-operational. Closed vent systems are monitored and have an allowed leak rate of 500 ppm. The flares operate a pilot flame at all times. Monitoring cameras and a flame sensor ensure proper operation of the flares. Chevron is not claiming an exemption due to any vapor collection or closed vent system operating under a vacuum. The flare headers are monitored. 60.483-1a Alternative standards for valves-allowable percentage of valves leaking. Status: N/A 60.483-2a Alternative standards for valves-skip period leak detection and repair. Status: In compliance – Chevron currently uses a skip monitoring plan, as outlined above. Also, as mentioned above, the LDAR requirements of the consent decree are more stringent than this condition. 60.485a Test methods and procedures. Status: In compliance – EPA Method 21 is used for monitoring VOC emissions on all components. Chevron contracts HydroChem PSC to perform the LDAR program. Instrument calibrations are recorded and available upon request. Records are maintained in the SkyBridge database. 60.486a Record keeping requirements. Status: In compliance – As mentioned above. Weatherproof identification tags are tied to all components which are designated as leakers. All components subject to the regulations are identified with a metal tag and identification number. After repairs are made, the component is re-monitored with results recorded in the Skybridge database. 60.487a Reporting requirements. Status: In compliance – Subpart VVa reporting requirements have been included in the semi-annual Subpart CC reports. EMISSIONS INVENTORY: 2022 annual emission inventory summary: Pollutant Tons/yr PM10 61.47 PM2.5 41.30 SOx 34.55 NOx 245.16 VOC 337.03 CO 252.59 10 PREVIOUS ENFORCEMENT ACTIONS: None within the previous 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: Chevron Products Company should be considered to be in compliance with the LDAR requirements under UAC R307-326, 40 CFR 63 Subpart CC, 40 CFR 60 Subpart GGGa, and 40 CFR 60 Subpart VVa at the time of this inspection. HPV STATUS: N/A COMPLIANCE ASSISTANCE: None RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual. ATTACHMENT: VEO Form Correspondence 11/30/22, 2:07 PM State of Utah Mail - Re: Chevron Oil Refinery https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f%3A1750877542245482425&simpl=msg-f%3A1750877542…1/2 Joe Rockwell <jrockwell@utah.gov> Re: Chevron Oil Refinery 1 message Harold Burge <hburge@utah.gov>Tue, Nov 29, 2022 at 5:08 PM To: Hao Zhu <hzhu@utah.gov>, kacee.voldness@gmail.com, Joe Rockwell <jrockwell@utah.gov> Hao asked that I answer your question. I'm the manager at the Division of Air Quality that oversees compliance for Chevron and the other refineries in the area. The clouds that you see are condensed water vapor (man-made clouds). Some of these are visible all the time, others become more visible/pronounced when temperatures drop and humidity is higher. That's probably why you're noticing them more now. Chevron operates around-the-clock and emits pollution around the clock. Some pollution, like particulate matter (black smoke), is visible, some is invisible. Chevron has permits that limit how much pollution they can emit on hourly, daily, monthly, and annual bases. We monitor pollution emitted by Chevron with continuous emission monitors, stack tests, hand-held monitors, fence-line monitors, video cameras, and parametric monitoring to make sure they are not exceeding their emission limits. We also do unannounced onsite compliance inspections. They are also required to submit reports to us and EPA quarterly, semi-annually, and annually. If an exceedance is found we make them return to compliance and pay penalties. The rules/limits are enforced by us and EPA. In addition, we monitor air pollution levels in the community 24/7 with our network of ambient air monitors. Here is a link to the network: https://airmonitoring.utah.gov/ We have two air monitoring stations in your area at 1400 West Goodwin Ave. and at our office at 240 North 1950 West. As far as pollution emitted by Chevron refinery, here is an estimate of their total annual potential emissions at maximum production. Their permits are designed to keep emissions from Chevron at, or below these levels: Criteria Pollutant (tons per year) Carbon Monoxide 991.06 Nitrogen Oxides 766.50 Particulate Matter - PM10 260.98 Particulate Matter - PM2.5 110.00 Sulfur Dioxide 383.30 Volatile Organic Compounds 1,242.09 Flaring from the refinery makes people nervous, but it is a good thing. Flares are used to minimize emissions and as safety control devices. Many people are bothered by the odors and noise associated with refineries. We do not regulate odors or noise. Those are handled at the city/county level. I hope this helps. If you have any more questions or concerns, please feel free to reach out to us. On Tue, Nov 29, 2022 at 3:15 PM Hao Zhu <hzhu@utah.gov> wrote: Hello, Harold: Would you please contact Kacee Voldness, a resident of Rose Park, who has questions about the air quality at the Chevron Salt Lake Refinery? Please see Kacee's email. Thanks, Hao Hao Zhu, P.E. Environmental Engineer | Corrective Action Section | 11/30/22, 2:07 PM State of Utah Mail - Re: Chevron Oil Refinery https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f%3A1750877542245482425&simpl=msg-f%3A1750877542…2/2 Division of Waste Management and Radiation Control Office: (801) 536-0249 | Front Desk: (801) 536-0200 wasteandradiation.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. Statements made in this email do not constitute the official position of the Director of the Division of Waste Management and Radiation Control. If you desire a statement of the Division Director’s position, please submit a written request to the Director, including copies of documents relevant to your request. ---------- Forwarded message --------- From: Kacee Voldness <kacee.voldness@gmail.com> Date: Mon, Nov 28, 2022 at 8:29 PM Subject: Chevron Oil Refinery To: <hzhu@utah.gov> Hi, I am a resident of rose park in Salt Lake City. I see the clouds produced by the Chevron Oil refinery, especially on cold days. I was curious if this contributes to poor air? Is it pollution that is coming out of those pipes? Thanks, Kacee Sent from my iPhone