DAQ-2024-005181

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DAQC-194-24
Site ID 10119 (B1)

MEMORANDUM

TO: FILE – CHEVRON PRODUCTS COMPANY – Salt Lake Refinery

THROUGH: Harold Burge, Major Source Compliance Manager

FROM: Joe Rockwell, Environmental Scientist

DATE: August 30, 2023

SUBJECT: PARTIAL COMPLIANCE EVALUATION (PCE #2 of #4) – WWTP, Tanks, and
Rail Loading Rack – Major, Davis County, FRS #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
[e-mail]

OPERATING STATUS: Operating

PROCESS DESCRIPTION:

This inspection applies to the Waste Water Treatment Plant (WWTP), Tank Farm, and Crude Railcar
Loading Rack.

Chevron controls emissions from storage tanks by fitting tanks with either fixed roofs or external floating
roofs. The tanks are used for storage of feedstocks and intermediate products awaiting further processing
and/or blending. Tanks are also used for storing finished product. The roofs float on top of the product by
means of a pontoon. The design of a floating roof is to control emissions by eliminating the vapor space
in the tank and to minimize the amount of hydrocarbons exposed to the air. Roof seals on the edges of the
floating roof control the emissions. Periodic inspections ensure the roof seals are intact and against the
tank wall. Emissions from any gaps exceeding the limitations specified in the conditions below are
calculated and included in the annual emissions inventory.

The crude railcar loading rack has a design crude loading rate of 10,000 barrels per day. Railcars are
loaded with crude for export by rail. A vapor recovery unit (VRU) serves as the air pollution control
device to reduce VOC emissions during railcar loading.

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APPLICABLE REGULATIONS:

Approval Order (AO) DAQE-AN101190104-22, dated September 26, 2022

Utah Administration Code (UAC) R307-327 – Petroleum Liquid Storage
40 CFR 63 Subpart CC – MACT for Petroleum Refineries (portions applicable to storage tanks)
40 CFR 60 Subpart Kb – NSPS for Volatile Organic Liquid Storage Vessels
40 CFR 61 Subpart FF – NESHAP for Benzene Waste Operations

SOURCE INSPECTION EVALUATION:

Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

Status: This is a statement of fact and not an inspection item.

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

Status: In compliance – No limitations were noted to be exceeded at time of inspection.

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

Status: In compliance – No modifications to the equipment or processes were noted at time of
the inspection.

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept
by the owner/operator, shall be made available to the Director or Director's representative
upon request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five (5) years. [R307-415-6b]

Status: In compliance – Electronic records were made available, for review, at time of the
inspection.

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

Status: In compliance – The source appeared to be well maintained and operated at time of the
inspection. The Maximo database is used to track preventative maintenance (PM) and
as needed maintenance for the enterer facility.
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I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

Status: In compliance – All reported incidents and breakdowns fall under the UAC Rule
(R) 307-170 and other Federal Regulations.

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

Status: In compliance – The 2022 annual emission inventory was initially submitted on April 6,
2023. The DAQ requested a follow-up and resubmittal at a later date.

I.8 The owner/operator shall submit documentation of the status of construction or modification
of the new tank listed in II.A. 80 to the Director within 18 months from the date of this AO.
This AO may become invalid if construction is not commenced within 18 months from the
date of this AO or if construction is discontinued for 18 months or more. To ensure proper
credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

Status: In compliance – No notices are currently required.

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT

II.A.1 Tanks and WWTP

II.A.2 Wastewater Treatment Plant (WWTP)
Wastewater installations
Two (2) dissolved nitrogen flotation
units (NEW) Capacity: 3,000 gpm Each
Collection box
sump Drains
(approximately
513)
Junction boxes
(approximately 88)
Dewatering devices
Control: Regenerative thermal oxidizer
Rotating biological contactors
Submerged biological contactors
Carbon canister controls

II.A.3 Tank D09312
Capacity: 750 bbl
Type: vertical fixed roof
Contents: only sludge

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II.A.4 Tank D21016
Capacity: 50 bbl
Type: horizontal
Contents: chemical additive

II.A.5 Tank D61011
Capacity: 50 bbl
Type: vertical fixed roof
Contents: chemical additive tank
(not currently in use)

II.A.6 Tank D61012
Capacity: 50 bbl
Type: vertical fixed roof
Contents: chemical additive tank
(currently not in use)

II.A.7 Tank D61013
Capacity: 500 bbl
Type: vertical fixed roof
Contents: chemical additive
(not currently in use)

II.A.8 Tank D61014
Capacity: 500 bbl
Type: vertical fixed roof
Contents: chemical additive

II.A.9 Tank D61045
Capacity: 300 bbl
Type: internal floating roof
Contents: chemical additive

II.A.10 Tank T10085
Capacity: 10,000 bbl
Type: vertical fixed roof
Contents: petroleum distillates

II.A.11 Tank T10086
Capacity: 10,000 bbl
Type: vertical fixed roof
Contents: petroleum distillates

II.A.12 Tank T10094
Capacity: 10,000 bbl
Type: external floating roof
Contents: waste water/slop oil

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II.A.13 Tank T10095
Capacity: 10,000 bbl
Type: external floating roof
Contents: gasoline/blend components/feedstock storage

II.A.14 Tank T15088
Capacity: 15,000 bbl
Type: vertical fixed roof
Contents: petroleum distillates

II.A.15 Tank T15090
Capacity: 15,000 bbl
Type: vertical fixed roof
Contents: petroleum distillates

II.A.16 Tank T15093
Capacity: 15,000 bbl
Type: external floating roof
Contents: gasoline/blend components/feedstock storage

II.A.17 Tank T15098
Capacity: 15,000 bbl
Type: vertical fixed roof
Contents: petroleum distillates

II.A.18 Tank T15099
Capacity: 15,000 bbl
Content: vertical fixed roof
Contents: petroleum distillates

II.A.19 Tank T15103
Capacity: 15,000 bbl
Type: external floating roof
Contents: waste water/slop oil

II.A.20 Tank T15104
Capacity: 15,000 bbl
Type: external floating roof
Contents: waste water/slop oil

II.A.21 Tank T1511
Capacity: 1,500 bbl
Type: external floating roof
Content: caustic storage

II.A.22 Tank T1512
Capacity: 1,500 bbl
Type: external floating roof
Content: caustic storage

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II.A.23 Tank T20015
Capacity: 20,000 bbl
Type: external floating roof
Contents: waste water/slop oil

II.A.24 Tank T20016
Capacity 20,000 bbl
Type: external floating roof
Content: waste water/slop oil

II.A.25 Tank T20017
Capacity: 20,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.26 Tank T20018
Capacity: 20,000 bbl
Type: external floating roof
Contents: gasoline/blend components/feedstock storage

II.A.27 Tank T20019
Capacity: 20,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.28 Tank T20030
Capacity: 20,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.29 Tank T20031
Capacity: 20,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.30 Tank T20032
Capacity: 20,000 bbl
Type: vertical fixed roof
Contents: petroleum distillates

II.A.31 Tank T20033
Capacity: 20,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.32 Tank T20040
Capacity: 20,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

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II.A.33 Tank T2111
Capacity 2,300 bbl
Type: external floating roof
Content: waste water/slop oil

II.A.34 Tank T25108
Capacity: 25,000 bbl
Type: external floating roof
Content: waste water/slop oil

II.A.35 Tank T25109
Capacity: 25,000 bbl
Type: external floating roof
Content: waste water/slop oil
II.A.36 Tank T30020
Capacity: 30,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.37 Tank T30021
Capacity: 30,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.38 Tank T30022
Capacity: 30,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.39 Tank T30023
Capacity: 30,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.40 Tank T30024
Capacity: 30,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.41 Tank T30041
Capacity: 30,000 bbl
Type: vertical fixed roof
Contents: petroleum distillates

II.A.42 Tank T30042
Capacity: 30,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

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II.A.43 Tank T30043
Capacity: 30,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.44 Tank T30069
Capacity: 30,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.45 Tank T30074
Capacity: 30,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.46 Tank T30080
Capacity: 30,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.47 Tank T30081
Capacity: 30,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.48 Tank T30082
Capacity 30,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.49 Tank T30091
Capacity: 30,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.50 Tank T30092
Capacity: 30,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.51 Tank T30096
Capacity: 30,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.52 Tank T30097
Capacity: 30,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

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II.A.53 Tank T30107
Capacity: 30,000 bbl
Type: external floating roof
Content: waste water

II.A.54 Tank T3350
Capacity: 5,000 bbl
Type: external floating roof
Content: oily sludge

II.A.55 Tank T35110
Capacity: 35,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.56 Tank T40050
Capacity: 40,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.57 Tank T40051
Capacity: 40,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.58 Tank T40052
Capacity: 40,000 bbl
Type: vertical fixed roof
Content: petroleum distillates
II.A.59 Tank T40070
Capacity 40,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.60 Tank T40071
Capacity 40,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.61 Tank T40072
Capacity: 40,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.62 Tank T40073
Capacity: 40,000 bbl
Type: external floating roof
Content petroleum distillates/gasoline blend components storage
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II.A.63 Tank T40075
Capacity: 40,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.64 Tank T40076
Capacity 40,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.65 Tank T40100
Capacity: 40,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage
II.A.66 Tank T40112
Capacity: 40,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.67 Tank T50078
Capacity: 50,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.68 Tank T50079
Capacity 50,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.69 Tank T50113
Capacity: 50,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.70 Tank T5038
Capacity: 5,000 bbl
Type: external floating roof
Content: slop oil

II.A.71 Tank T5083
Capacity: 5,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.72 Tank T5084
Capacity: 5,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

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II.A.73 Tank T60059
Capacity: 60,000 bbl
Type: external floating roof
Content: crude oil storage

II.A.74 Tank T60060
Capacity: 60,000 bbl
Type: external floating roof
Content: crude oil storage

II.A.75 Tank T60061
Capacity: 60,000 bbl
Type: external floating roof
Content: crude oil storage

II.A.76 Tank T60062
Capacity: 60,000 bbl
Type: external floating roof
Content: crude oil storage

II.A.77 Tank T60063
Capacity: 60,000 bbl
Type: external floating roof
Content: crude oil storage

II.A.78 Tank T60077
Capacity: 60,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.79 T60114
60,000 bbl vertical fixed (cone) roof petroleum distillates storage tank
II.A.80 Tanks T60118
Capacity: 60,000 bbl
Type: vertical fixed roof
Content: petroleum distillates

II.A.81 Tank T90116
Capacity: 90,000 bbl
Type: external floating roof
Content: crude oil storage

II.A.82 Tank T90117
Capacity: 90,000 bbl
Type: external floating roof
Content: crude oil storage

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II.A.83 Tank T7513
Capacity: 7,000 bbl
Type: external floating roof
Content: slop oil service storage

II.A.84 Tank T7514
Capacity: 7,000 bbl
Type: internal floating roof
Content: gasoline/blend components/feedstock storage

II.A.85 Tank T7539
Capacity: 7,000 bbl
Type: external floating roof
Content: slop oil

II.A.86 Tank T80115
Capacity: 80,000 bbl
Type: external floating roof
Content: gasoline/blend components/feedstock storage

II.A.87 Tank T934
Capacity: 900 bbl
Type: vertical fixed roof
Content: caustic storage

II.A.88 Tank V12684
Capacity: 1,300 bbl
Type: horizontal pressure vessel
Content: propane

II.A.89 Tank V12685
Capacity: 1,300 bbl
Type: horizontal pressure vessel
Content: propane

II.A.90 Tank V2567
Capacity: 2,500 bbl
Type: pressurized sphere
Content: butane

II.A.91 Tank V31159
Capacity: 150 bbl
Type: horizontal
Content: chemical additive

II.A.92 Tank V5064
Capacity 5,000 bbl
Type: pressurized sphere
Content: butane

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II.A.93 Tank V5065
Capacity: 5,000 bbl
Type: pressurized sphere
Content: butane

II.A.94 Tank V5066
Capacity: 5,000 bbl
Type: pressurized sphere
Content: olefin

II.A.95 Tank V76801
Capacity: 650 bbl
Type: horizontal pressure vessel
Content: propane

II.A.96 Tank V76802
Capacity: 650 bbl
Type: horizontal pressure vessel
Content: propane

II.A.97 Tank V76803
Capacity: 650 bbl
Type: horizontal pressure vessel
Content: propane

II.A.98 Loading Rack
Railcar loading/unloading rack
Controlled by vapor combustor unit

Status: In compliance – No unapproved tanks were noted at time of the inspection. There
are nine tanks that are considered to be Waste Water Treatment Tanks (items II.A3,
II.A.4, II.A.5, II.A.6, II.A.7, II.A.8, II.A.24, II.A35, and II.A.53). The remaining
tanks are tank farm tanks. The two dissolved nitrogen flotation units (item II.A.2)
have not been installed to date.

SECTION II: SPECIAL PROVISIONS

II.B Requirements and Limitations

II.B.1 Site-Wide Requirements

II.B.1.a The owner/operator shall not exceed the following as listed under SIP Section
IX.H.2.d, and Section IX.H.12.d:
A. PM10 0.715 tons per day (tpd) and
B. PM2.5 0.305 tons per day and 110 tons per rolling 12-month period
C. SO2 1.05 tons per day (tpd) and 383.3 tons per rolling 12-month period

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D. NOx 2.1 tons per day (tpd) and 766.5 tons per rolling 12-month period.
[SIP Section IX.H.12, SIP Section IX.H.2]

II.B.1a.1 Compliance shall be demonstrated as outlined in SIP Section IX.H.2.d and Section
IX.H.12.d. [SIP Section IX.H.12, SIP Section IX.H.2]

Status: In compliance – Emissions for the following pollutants, for the 12-month period
August 2022 through July 2023:

Pollutant Emission
Limits (Tons
Per Day)
Emission
Limits
(Tons Per 12-
Month Period)
Actual
Emissions
(Tons Per
Day)
Actual
Emissions
(Tons Per 12-
Month Period)
PM10 0.715 - <0.175 -
PM2.5 0.305 110 <0.305 51.5
SO2 1.05 383.3 < 1.05 41.8
NOx 2.1 766.5 <2.1 253.6

Note: See status of conditions II.B.1.f, II.B.1.g, II.B.1.h, and II.B.1.i of AO
DAQE-AN101190106-22, dated August 24, 2022.

II.B.2 Conditions on Tank and Wastewater Process
II.B.2.a The owner/operator shall operate the wastewater installation in accordance with the
requirements of 40 CFR 61, Subpart FF. [40 CFR 61]

Status: In compliance – The required quarterly Benzene Waste Operations NESHAP
(BWON) reports and Total Annual Benzene (TAB) reports are submitted as required.
See Chevron Inspection Memo (3 of 4).

II.B.2.b The owner/operator shall not exceed a throughput feed rate of 3,000 gpm of process
wastewater through the dissolved nitrogen flotation system. [R307-401-8]

II.B.2.b.1 Compliance shall be demonstrated through a flow meter and recorded in operator logs.
[R307-401-8]

Status: N/A – The two dissolved nitrogen flotation units have not been installed to date. See
status of condition II.A.

II.B.2.c The following storage vessels/tanks are subject to specific federal regulations, which are
listed here for convenience. The source must comply with the latest version of the CFR and
applicable subparts.

Tanks subject to 40 CFR 63, Subparts A and CC:

7514, 10095, 15093, 20017, 20018, 20019, 30020, 30021, 30022, 30024, 30091,
30092, 30096, 30097, 35110, 40075, 40076, 40100, 50078, 50079, 60059, 60077, 80115,
90116, and 90117.

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Tanks subject to 40 CFR 60, Subparts A and Kb:

1512, 2111, 3350, 7513, 10094, 20017, 20018, 30024, 30092, 30096, 35110, 40100, 50078,
60077, 80115, 90116, 90117, and 7514

Tanks subject to 40 CFR 61, Subparts A and FF:

1511, 1512, 2111, 3350, 5038, 7513, 7514, 7539, 10094, 15103, 15104, 20015, 20016,
25108, 25109, and 30107

[40 CFR 60 Subpart CC, 40 CFR 61 Subpart FF, 40 CFR 63 Subpart A, R307-401]

Status: In compliance – No unapproved tanks were noted. See applicable sections below for
evaluation of 40 CFR 60-63 requirements.

II.B.3 Requirements on the Loading Rack

II.B.3.a

The owner/operator shall operate the crude oil loading rack in accordance with the
requirements of 40 CFR 63 Subpart EEEE. The owner/operator shall limit VOC emissions
from the crude oil loading rack to 10 milligrams per liter of crude oil. [40 CFR 63 Subpart
EEEE, R307-401-8]

II.B.3.a.1 Compliance with the VOC emission limit shall be demonstrated as outlined in 40 CFR
63.2354 and 63.2362. [40 CFR 63 Subpart EEEE]

Status:

In compliance – Additional rail loading rack controls are currently not required,
according to semi-annual checks. This condition is evaluated during a separate
inspection.

II.B.3.b The owner/operator shall not exceed 10,000 bbls/day of total material loading in the loading
rack. Materials include crude oil, desulfurized gas oil (DGO), vacuum gas oil (VGO) or
naphtha. [R307-401-8]

II.B.3.b.1 To demonstrate compliance with the daily limitation the owner/operator shall maintain a log
of daily materials loaded. Records shall include the type and volume of material loaded.
Records shall be kept for all periods when the plant is in operation. [R307-401-8]

Status: In compliance – Railcar rack daily material loading is monitored by a flow meter.
Flow meter readings are electronically recorded. Review the records indicated that the
above permitted limit has not been exceeded.

UAC R307-327 Petroleum Liquid Storage

R307-327-4 General Requirements.

(1) Any existing stationary storage tank, reservoir or other container with a capacity greater than 40,000
gallons (150,000 liters) that is used to store volatile petroleum liquids with a true vapor pressure greater
than 10.5 kilo pascals (kPa) (1.52 psia) at storage temperature shall be fitted with control equipment that
will minimize vapor loss to the atmosphere. Storage tanks, except those erected before January 1, 1979,
which are equipped with external floating roofs, shall be fitted with an internal floating roof that shall rest
on the surface of the liquid contents and shall be equipped with a closure seal or seals to close the space
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between the roof edge and the tank wall, or alternative equivalent controls, provided the design and
effectiveness of such equipment is documented and submitted to and approved by the director. The owner
or operator shall maintain a record of the type and maximum true vapor pressure of stored liquid.

(2) The owner or operator of a petroleum liquid storage tank not subject to (1) above, but containing a
petroleum liquid with a true vapor pressure greater than 7.0 kPa (1.0 psia), shall maintain records of the
average monthly storage temperature, the type of liquid, throughput quantities, and the maximum true
vapor pressure.

Status: In compliance – This rule contains language considered by some to be ambiguous,
and is being updated by DAQ’s rules section working with the engineering section.
Three external floating roof tanks at Chevron have been approved by DAQ after
this rule was enacted. Chevron has been operating under the assumption that
retrofitting these newly constructed tanks must be performed on each tank during
the next tank turnaround. However, new rule language is expected to clarify that
these tanks approved after promulgation of this rule will not require this
retrofitting.

The remainder of the tanks at the Chevron refinery are in compliance with the
requirements of R307-327.

R307-327-5 Installation and Maintenance.

(1) The owner or operator shall ensure that all control equipment on storage vessels is properly installed
and maintained.
(a) There shall be no visible holes, tears or other openings in any seal or seal fabric and all openings,
except stub drains, shall be equipped with covers, lids, or seals.
(b) All openings in floating roof tanks, except for automatic bleeder vents, rim space vents, and leg
sleeves, shall provide a projection below the liquid surface.
(c) The openings shall be equipped with a cover, seal, or lid.
(d) The cover, seal, or lid is to be in a closed position at all times except when the device is in actual use.
(e) Automatic bleeder vents shall be closed at all times except when the roof is floated off or landed on
the roof leg supports. Rim vents shall be set to open when the roof is being floated off the leg supports or
at the manufacturer's recommended setting.
(f) Any emergency roof drain shall be provided with a slotted membrane fabric cover or equivalent cover
that covers at least 90 percent of the area of the opening.
(2) The owner or operator shall conduct routine inspections from the top of the tank for external floating
roofs or through roof hatches for internal floating roofs at six month or shorter intervals to insure there are
no holes, tears, or other openings in the seal or seal fabric.
(a) The cover must be uniformly floating on or above the liquid and there must be no visible defects in the
surface of the cover or petroleum liquid accumulated on the cover.
(b) The seal(s) must be intact and uniformly in place around the circumference of the cover between the
cover and tank wall.
(3) A close visible inspection of the primary seal of an external floating roof is to be conducted at least
once per year from the roof top unless such inspection requires detaching the secondary seal, which
would result in damage to the seal system.

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(4) Whenever a tank is emptied and degassed for maintenance, an emergency, or any other similar
purpose, a close visible inspection of the cover and seals shall be made.
(5) The director must be notified 7 days prior to the refilling of a tank that has been emptied, degassed for
maintenance, an emergency, or any other similar purpose. Any non-compliance with this rule must be
corrected before the tank is refilled.

Status: In compliance – Chevron conducts monthly and annual seal inspections. Annual inspections
entail measuring and visually inspecting seals for gaps and tears. All floating roof tanks, regardless
of Federal Subpart applicability, are inspected. Monthly visual seal inspections are also conducted.
Probes are used to determine the size of gaps. Anytime a tank is emptied and degassed, inspections
are conducted and all needed repairs are made. Control devices have been installed as required.
Reports are submitted as required.

R307-327-6 Retrofits for Floating Roof Tanks.

(1) Except where specifically exempted in (3) below, all existing external floating roof tanks with
capacities greater than 950 barrels (40,000 gals) shall be retrofitted with a continuous secondary seal
extending from the floating roof to the tank wall (a rim-mounted secondary seal) if:
(a) The tank is a welded tank, the true vapor pressure of the contained liquid is 27.6 kPa (4.0 psia) or
greater and the primary seal is one of the following:
(i) A metallic type shoe seal, a liquid-mounted foam seal, a liquid-mounted liquid-filled seal, or
(ii) Any other primary seals that can be demonstrated equivalent to the above primary seals.
(b) The tank is a riveted tank, the true vapor pressure of the contained liquid is 10.5 kPa (1.5 psia) or
greater, and the primary seal is as described in (a) above.
(c) The tank is a welded or riveted tank, the true vapor pressure of the contained liquid is 10.5 kPa (1.5
psia) or greater and the primary seal is vapor-mounted. When such primary seal closure device can be
demonstrated equivalent to the primary seals described in (a) above, these processes apply.
(2) The owner or operator of a storage tank subject to this rule shall ensure that all the seal closure devices
meet the following requirements:
(a) There shall be no visible holes, tears, or other openings in the seals or seal fabric.
(b) The seals must be intact and uniformly in place around the circumference of the floating roof between
the floating roof and the tank wall.
(c) For vapor mounted primary seals, the accumulated area of gaps between the secondary seal and the
tank wall shall not exceed 21.2 cm2 per meter of tank diameter (1.0 in2 per ft. of tank diameter) and the
width of any gap shall not exceed 1.27 cm (1/2 in.). The owner or operator shall measure the secondary
seal gap annually and make a record of the measurement.
(3) The following are specifically exempted from the requirements of (1) above:
(a) External floating roof tanks having capacities less than 10,000 barrels (420,000 gals) used to store
produced crude oil and condensate prior to custody transfer.
(b) A metallic type shoe seal in a welded tank that has a secondary seal from the top of the shoe seal to
the tank wall (a shoe mounted secondary seal).
(c) External floating roof tanks storing waxy, heavy pour crudes.
(d) External floating roof tanks with a closure seal device or other devices installed that will control
volatile organic compounds (VOC) emissions with an effectiveness equal to or greater than the seals
required in (1) above. It shall be the responsibility of the owner or operator of the source to demonstrate
the effectiveness of the alternative seals or devices to the director. No exemption under (3) shall be
granted until the alternative seals or devices are approved by the director.

Status: In compliance – All external floating roof tanks are equipped with mechanical shoe style
primary seals and secondary wiper seals

18
R307-327-7 Alternate Methods of Control.

(1) Any person may apply to the director for approval of an alternate test method, an alternate method of
control, an alternate compliance period, an alternate emission limit, or an alternate monitoring schedule.
The application must include a demonstration that the proposed alternate produces an equal or greater air
quality benefit than that required by R307-327, or that the alternate test method is equivalent to that
required by these rules. The director shall obtain concurrence from EPA when approving an alternate test
method, an alternate method of control, an alternate compliance period, an alternate emission limit, or an
alternate monitoring schedule.
(2) Manufacturer's operational specifications, records, and testing of any control system shall use the
applicable EPA Reference Methods of 40 CFR Part 60, the most recent EPA test methods, or EPA-
approved state methods, to determine the efficiency of the control device. In addition, the owner or
operator must meet the applicable requirements of record keeping for any control device. A record of all
tests, monitoring, and inspections required by R307-327 shall be maintained by the owner or operator for
a minimum of 2 years and shall be made available to the director or the director's representative upon
request. Any malfunctioning control device shall be repaired within 15 calendar days after it is found by
the owner or operator to be malfunctioning, unless otherwise approved by the director.
(3) For purposes of determining compliance with emission limits, VOCs and nitrogen oxides will be
measured by the test methods identified in federal regulation or approved by the director. Where such a
method also inadvertently measures compounds with negligible photochemical reactivity, an owner or
operator may exclude these negligibly reactive compounds when determining compliance with an
emissions standard.

Status: N/A – No alternate methods are used.

R307-327-8 Compliance Schedule.

All sources within any newly designated nonattainment area for ozone shall be in compliance with this
rule within 180 days of the effective date of designation to nonattainment.

Status: In compliance – Chevron met the compliance deadline.

40 CFR 63 Subpart CC – National Emission Standards for Hazardous Air Pollutants From
Petroleum Refineries

63.640 Applicability and designation of effected source.

Status: In compliance – Chevron meets the most stringent standards for all tanks except the
two internal floating roof slop oil tanks.

40 CFR 60 Subpart Kb – Standards of Performance for Volatile Organic Liquid Storage Vessels
(Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or
Modification Commenced after July 23, 1984

60.110b Applicability and designation of affected facility.

Status: In compliance – See information below, regarding Subpart Kb.

19
60.112b Standard for volatile organic compounds (VOC).

Status: In compliance – All external floating roof tanks have primary and secondary seals.
The primary seals are mechanical shoe seals and the secondary seals are rim
mounted wipers or double wipers. All openings are kept closed with lids at all times
except when in use, and have a projection below the liquid surface. Filling,
emptying, or refilling is continuous and accomplished as rapidly as possible.
According to Chevron, vapor pressures of all materials in NSPS Kb tanks were less
than 11 psi (76.6 kPa). The tanks are set to alarm prior to it sitting on its legs. The
legs are only extended for maintenance purposes.

60.113b Testing and procedures.

Status: In compliance – Records show that Chevron measures and inspects primary seals
for gaps and tears annually, on all floating roof tanks regardless of applicability of
the various regulations. Secondary seals are visually inspected monthly. Probes are
used to determine the size of gaps. All repairs required on the seals have been made
within the 45 day time limit, unless an extension has been granted. Any time a tank
is emptied and degassed, inspections are conducted and all needed repairs are made.
Reports are submitted as required.

60.115b Reporting and record keeping requirements.

Status: In compliance – Chevron keeps records and submits reports as required by this
subpart. Annual Tank Seal Inspection reports, Tank Degas notices, and Tank
Refilling notices are submitted as required.

60.116b Monitoring of operations.

Status: In compliance – Records are maintained for the required 2 year period. Records of
vessel dimensions and capacity are maintained in each tank file. The monthly
inventory report shows the stock being stored. The vapor pressure is determined by
the maximum expected storage temperatures.

40 CFR 63 Subpart CC - National Emission Standards for Hazardous Air Pollutants From
Petroleum Refineries

63.640 Applicability.

Status: In compliance – Chevron meets the most stringent standards for all tanks except the
two internal floating roof slop oil tanks. See comments below.

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
20

PREVIOUS ENFORCEMENT
ACTIONS:

None within the previous five years.
COMPLIANCE STATUS &
RECOMMENDATIONS:

Chevron Products Company should be
considered to be in compliance with AO
DAQE-AN101190104-22, dated September
26, 2022. Also, the tank requirements under
UAC R307-327, 40 CFR 63 Subpart CC, 40
CFR 60 Subpart Kb, and 40 CFR 61 Subpart
FF 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 <[e-mail]>
Re: Chevron Oil Refinery
1 message
Harold Burge <[e-mail]>Tue, Nov 29, 2022 at 5:08 PM
To: Hao Zhu <[e-mail]>, [e-mail], Joe Rockwell <[e-mail]>
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 <[e-mail]> 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: [phone] | Front Desk: [phone]
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 <[e-mail]>
Date: Mon, Nov 28, 2022 at 8:29 PM
Subject: Chevron Oil Refinery
To: <[e-mail]>

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