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HomeMy WebLinkAboutDAQ-2024-0051831 DAQC-196-24 Site ID 10119 (B1) MEMORANDUM TO: FILE – CHEVRON PRODUCTS COMPANY – Salt Lake Refinery THROUGH: Harold Burge, Major Source Compliance Section Compliance Manager FROM: Joe Rockwell, Environmental Scientist DATE: February 26, 2024 SUBJECT: PARTIAL COMPLIANCE EVALUATION (PCE #4 of #4) – Main Refinery – 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 S Chevron Way, North Salt Lake, UT 84054 SOURCE CONTACTS: Lauren Vander Werff, Environmental Team Lead, 801-539-7386 lvanderwerff@chevron.com OPERATING STATUS: Operating PROCESS DESCRIPTION: Chevron Refinery produces propane, jet fuel, gasoline, and diesel fuel at this facility. Crude oil is received at the plant by pipeline and stored in storage tanks. From the storage tanks, the crude oil is sent through a desalter and then heated in the crude unit heater. The crude oil is then separated into fractions in the distillation tower and vacuum tower. These fractions of oil are further refined through physical, thermal, catalytic, and chemical processes. The liquid propane gas (LPG) and gasoline are sent to the Gas Recovery Unit which further separates the streams. The gasoline is sent to storage tanks and the LPG is further processed through the Hydrofluoric Acid (HF) Alkylation Unit and then onto propane storage tanks. Jet fuel and diesel fuel are transferred from the fractionation column and sent directly to storage tanks. Some diesel fuel is processed through the Hydrodesulfurization Unit (HDS) to remove additional sulfur components. Gas oil from the vacuum column is fed to the Fluid Catalytic Cracker (FCC Unit) which exposes the product to a catalyst that further breaks down the heavy gas oil into more marketable products such as gasoline, jet fuel, and diesel fuel. Residual oil from the bottom of the distillation tower is fed to the Coker Unit. The Coker Unit heats the bottom oil to very high temperatures and then fractionates the products in a distillation tower and produces coke which is sold by rail car. 2 The following is a brief description of the main process equipment operated at the Chevron Refinery: Crude Unit: Crude oil is heated in furnaces and sent through an atmospheric distillation column for separation. The "bottoms" from the atmospheric column feed a vacuum distillation unit for further fractionation. Process streams are either sent directly to product storage or sent to other units for further processing. Fluid Catalytic Cracker (FCC) Unit: Oil is received from the Crude Unit vacuum column and is heated in two furnaces. The oil is heated to high temperatures and exposed to a catalyst that "cracks" the oil into smaller hydrocarbon chains. After the cracking process, the oil is separated into fractions and sent to product storage or onto other units for further processing. The FCC is equipped with a catalyst regenerator which burns off the coke deposited onto the catalyst during the cracking process. Emissions from the unit are routed through cyclones and an electrostatic precipitator and then discharged to the atmosphere through the CO boiler stack. Reformer Unit: Low octane hydrocarbons are sent through a series of furnaces and catalytic reactors to form higher octane molecules for blending into gasoline. The gas stream is sent through a distillation tower for separation after leaving the reformer. Isomerization Unit: Butane is exposed to a catalyst to produce isobutane which is required in the alkylation process. Alkylation Unit: Isobutane and propylene or butene is exposed to a catalyst (hydrofluoric acid). The reaction produces aviation gasoline and several blending components of motor gasoline. Coker Unit: The "heavy" oil from the Crude Unit vacuum column and FCC are heated, fractionated in a distillation tower, and "cracked" into coke. Any product recovered by the fractionation and cracking process is sent through other units for further processing or to product storage tanks. The remaining product is a solid coke product which is formed in the large coke vessels. The coke is removed from the vessels with a high pressure water drill and stored on train cars until it is shipped to the customer. Hydrodenitrification (HDN) and Hydrodesulfurization (HDS) Units: Liquid feed from the coker and diesel fuel are fed to these units where they are exposed to a catalyst and hydrogen gas. This exposure creates a chemical reaction that separates the nitrogen and sulfur products from the feed stream. The sulfur and nitrogen form hydrogen sulfide (H2S) and ammonia (NH3) rich streams which are fed to the Amine unit and sour water stripper for processing. Amine Unit: Sour gas from all process units are combined and exposed to Amine which absorbs the hydrogen sulfide from the fuel gas. The hydrogen sulfide is then stripped off of the Amine with steam and sent to the 3 Sulfur Recovery Unit for processing. The sweet gas (contains little or no hydrogen sulfide) is sent back to the V-113 mixing drum and used as plant gas. Sour Water Stripper: Water streams containing ammonia and hydrogen sulfide are sent through a packed column tower where high pressure steam strips the ammonia and hydrogen sulfide from the water streams. The ammonia and hydrogen sulfide are sent to the Sulfur Recovery Unit for processing and the water stream is sent to the Wastewater Treatment Plant. Sulfur Recovery Units (SRU): The ammonia and hydrogen sulfide acid gas streams from the Amine Unit and the Sour Water Stripper are fed to a thermal reactor and heated to high temperatures. The high temperatures destroy the ammonia and transform some of the hydrogen sulfide into sulfur dioxide (SO2). The hydrogen sulfide/sulfur dioxide stream is sent through a series of catalytic reactors and condensers where the sulfur compounds are converted into liquid elemental sulfur. The liquid sulfur flows into the sulfur pit and the acid gas remaining is sent through the Sulfur Recovery Unit incinerator where it is oxidized. Wastewater Treatment Plant: All industrial wastewater and storm water from the refinery property is sent through a series of tanks, oil/water separators, biological treatment disks, and filters for cleaning, before being discharged. Some emissions from this facility are vented to a thermal oxidizer and incinerated. Boiler Plant: There are three boilers (#5, #6, and #7) that produce steam for the processes described above. The boilers operate on natural gas or plant gas. APPLICABLE REGULATIONS: Approval Order DAQE-AN101190106-22, issued August 24, 2022. SOURCE INSPECTION EVALUATION: AO dated August 26, 2020 – DAQE-101190099-20: 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. 4 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. [R307-401-8] Status: In compliance – Records were made available 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 refinery appeared to be well operated and maintained at time of the inspection. All refinery maintenance records are tracked with the Maximo Maintenance System. I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In compliance – The refinery is aware of the breakdown rule and reports when necessary. Breakdowns are also covered under UAC R 307-170. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In compliance – Emission inventories have been submitted as required. The 2022 annual emission inventory was submitted on April 6, 2023. The DAQ requested that the inventory be resubmitted. The 2022 annual emission inventory is mentioned in the other partial compliance evaluations. I.8 The owner/operator shall submit documentation of the status of construction or modification of the new emergency engines listed in II.A.34 (the canal fire water system) 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 – Construction/installation notice regarding the installation of the two new generators was submitted. See status of condition II.A. 5 SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Main Refinery Chevron Salt Lake Refinery II.A.2 F-11005 Boiler #11005 (Boiler #5,) Rating:171 MMBtu/hr Control: Low-NOx II.A.3 F-11006 Boiler #11006 (Boiler #6) Rating:171 MMBtu/hr Control: Low-NOx II.A.4 F-11007 Boiler #11007 (Boiler #7) Rating: 225 MMBtu/hr Control: Low-NOx and FGR II.A.5 16001 Cooling Tower #16001 II.A.6 16002 Cooling Tower #16002 II.A.7 16003 Cooling Tower #16003 II.A.8 16004 Cooling Tower #16004 (Grandfathered) II.A.9 F-21001 Crude Unit Furnace #F-21001 Rating: 130 MMBtu/hr Control: Low-NOx II.A.10 F-21002 Crude Unit Furnace #F-21002 Rating: 115.1 MMBtu/hr Control: Low-NOx II.A.11 F-32021 FCC Furnace F-32021 Rating: 48.2 MMBtu/hr 6 II.A.12 F-32023 FCC Furnace F-32023 Rating: 48.2 MMBtu/hr II.A.13 F-71010 HDN Furnace F-71010 Rating: 15.6 MMBtu/hr II.A.14 F-71030 HDN Furnace F-71030 Rating: 36.3 MMBtu/hr II.A.15 F-35001 Reformer Furnace F-35001 Rating: 52.3 MMBtu/hr II.A.16 F-35002 Reformer Furnace F-35002 Rating: 45 MMBtu/hr II.A.17 F-35003 Reformer Furnace F-35003 Rating: 31.7 MMBtu/hr II.A.18 Alkylation Unit Includes: Alkylation Furnace F-36017 Rating: 108 MMBtu/hr Control: Low-NOx II.A.19 F-70001 Coker Furnace F-70001 Rating: 139.2 MMBtu/hr II.A.20 F-64010 HDS Furnace F-64010 Rating: 19 MMBtu/hr Control: Low -NOx II.A.21 F-64011 HDS Furnace F-64011 Rating: 27.3 MMBtu/hr Control: Low-NOx II.A.22 F-66100 VGO Furnace F-66100 Rating: 40 MMBtu/hr Control: Low-NOx 7 II.A.23 F-66200 VGO Furnace F-66200 Rating: 66 MMBtu/hr Control: Low-NOx II.A.24 SRU/TGTU/TGI #1 SRU and Tail Gas Incinerator #1 II.A.25 SRU/TGTU/TGI #2 SRU and Tail Gas Incinerator #2 II.A.26 Catalyst Regenerator FCCU and Catalyst Regenerator II.A.27 F61312 Flameless Thermal Oxidizer II.A.28 Coker Flare (Flare #1) Coker Flare (Control/Safety Device) II.A.29 FCCU Flare (Flare #2) FCCU Flare (Control/Safety Device) II.A.30 Alkylation Flare (Flare #3) Alkylation Flare (Control/Safety Device) II.A.31 Diesel-powered back-up equipment: Second North Substation Generator: One Emergency Generator Rating: 670 hp (500 kW) #1 CWT: One Emergency Cooling Water Pump Rating: 630 hp (470 kW) HDN Substation: One Emergency Generator Rating: 536 hp (400 kW) Two Fire Water Emergency Backup Pumps Rating: 375 hp (cont.)/400 hp (max) each VGO: One Emergency Generator Rating: 680 hp (prime) 755 hp (standby) 8 II.A.32 Diesel-powered back-up equipment (cont.) Two HF Mitigation Pumps Rating: 830 hp (619 kW) each Crude Substation: One Backup Generator Rating: 820 hp (611 kW) Third North Substation: One Backup Emergency Generator Rating: 1490 hp (1111 kW) Admin Building: One Backup Generator Rating: 1676 hp (1250 kW) TCLRr : One Backup Generator Rating:168 hp (125 kW) North Tank Field: One Backup Generator *NEW* Rating: 896 hp (600 kW) WWTP: One Backup Generator *NEW* Rating: 617 hp (400 kW) II.A.33 Diesel-powered back-up equipment (cont.) Alky: One Emergency Generator Rating: 670 hp (500 kW) Boiler Plant: Two Compressors Rating: 524 hp (391 kW) each Collection Box: One Backup Pump Rating: 109 hp (81.4 kW) FCC MCC: One Emergency Generator Rating: 805 hp (601 kW) Three Fire Water Pumps Rating: 755 hp (563.5 kW) each One Canal Fire Water Emergency Generator Rating: 369 hp (275 kW) II.A.34 Diesel-powered back-up equipment (new) Reformer substation generator: one (1) emergency generator Rating: 400 kW II.A.35 Natural gas-powered backup equipment One Emergency Generator Rated at 50 hp II.A.36 K35001, K35002, K35003 Three Reformer Compressor Drivers Rating: 16 MMBtu/hr each Fuel: Refinery Fuel Gas 9 II.A.37 Amine Unit #1 Amine Unit #1 II.A.38 Amine Unit #2 Amine Unit #2 II.A.39 K36067 Lime Loading Facility K36067 II.A.40 FCC Fines Bin Status: In compliance – No unapproved equipment was observed at time of the inspection. The new backup generators (item II.A.32) have been installed. See status of condition I.8. SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Source-wide Requirements II.B.1.a Except as otherwise stated in this AO, the owner/operator shall use only plant gas or purchased natural gas as a primary fuel. Plant Coke may be burned in the FCC Catalyst Regenerator. Torch oil may be burned in the FCC Catalyst Regenerator to assist in starting, restarting, hot standby, or to maintain regenerator heat balance. If any other fuel is to be used, an AO shall be required. [Consent Decree, R307-401] Status: In compliance. Only approved fuels are used. II.B.1.b All petroleum refineries in or affecting any PM2.5 nonattainment area or any PM10 nonattainment or maintenance area shall reduce the H2S content of the refinery plant gas to 60 ppm or less as described in 40 CFR 60.102a. Compliance shall be based on a rolling average of 365 days. The owner/operator shall comply with the fuel gas monitoring requirements of 40 CFR 60.107a and the related recordkeeping and reporting requirements of 40 CFR 60.108a. As used herein, refinery "plant gas" shall have the meaning of "fuel gas" as defined in 40 CFR 60.101a, and may be used interchangeably. For natural gas, compliance is assumed while the fuel comes from a public utility. [SIP Section IX.H.11.g.ii] Status: Not Evaluated – CEM requirements and CEMs Quarterly Report are evaluated by the DAQ’s CEM specialist. 10 II.B.1.c No petroleum refineries in or affecting any PM2.5 nonattainment area or PM10 nonattainment or maintenance area shall be allowed to burn liquid fuel oil in stationary sources except during natural gas curtailments or as specified below: A. The use of diesel fuel meeting the specifications of 40 CFR 80.510 in standby or emergency equipment is exempt from the limitation above and is allowed in standby or emergency equipment at all times. B. Plant coke may be burned in the FCC Catalyst Regenerator. [R307-401-8(1)(a), SIP Section IX.H.11.g.vii, SIP Section IX.H.12.d.iv] Status: N/A – Fuel oil is no longer burned at this facility. The fuel oil lines have been removed. II.B.1.d The owner/operator shall not allow visible emissions to exceed the opacity limits set in R307-309. [R307-309] Status: In compliance – No visible emissions were observed during this inspection. CEM requirements and CEMs Quarterly Report are evaluated by the DAQ’s CEM specialist. II.B.1.e The owner/operator shall ensure for all stack testing performed: The owner/operator shall provide a pre-test protocol at least 45 days prior to the test. A pretest conference between the owner/operator, the tester, and the Director shall be held at least 30 days prior to the test if directed by the Director. The emission point shall conform to the requirements of 40 CFR 60, Appendix A, Method 1. Occupational Safety and Health Administration (OSHA) approved access shall be provided to the test location. The throughput rate during stack testing shall be no less than 90% of the rated throughput or 90% of the highest monthly throughput achieved in the previous three years whichever is the least. If the desired throughput rate is not achieved at the time of testing, the achieved throughput rate +10% will become the maximum allowable throughput rate. Additional testing shall be required, following the same procedure, to establish a higher throughput rate if the existing maximum allowable throughput rate is to be exceeded. Where appropriate, the following test methods shall be used, although other EPA- approved test methods acceptable to the Director can be substituted and approved through the pre-test protocol: Volumetric flow rate - 40 CFR 60, Appendix A, Method 2 SO2 emissions - 40 CFR 60, Appendix A, Method 6C NOx emissions - 40 CFR 60, Appendix A, Method 7E PM10 and PM2.5 emissions - 40 CFR 51, Appendix M, Methods 201a and 202 11 To determine mass emission rates (lbs/hr, etc.), the pollutant concentration, as determined by the appropriate methods above, shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director to give the results in the specified units of the emission limitation. [R307-401] Status: In compliance – Emission Factors (EFs) for PM10 and PM2.5 are provided in the AO dated March 2020. EFs are determined using CEMs and Stack Test data. PM10 Stack Tests are no longer required to be conducted. The last PM10 stack test was conducted in 2017. DAQ has no outstanding compliance issues for stack test notifications. II.B.1.f Source-wide combined emissions of PM10 shall not exceed 0.715 tons per day (tpd). [SIP Section IX.H.2.d.i] II.B.1.f.1 Compliance with the source-wide PM10 Cap shall be determined for each day as follows: A. Total 24-hour PM10 emissions for the emission points shall be calculated by adding the daily results of the PM10 emissions equations listed below for natural gas, plant gas, and fuel oil combustion. These emissions shall be added to the emissions from the cooling towers, and the FCCU to arrive at a combined daily PM10 emission total. B. For purposes of this subsection a "day" is defined as a period of 24-hours commencing at midnight and ending at the following midnight. C. Daily natural gas and plant gas consumption shall be determined through the use of flow meters. D. Daily fuel oil consumption shall be monitored by means of leveling gauges on all tanks that supply combustion sources. E. The equation used to determine emissions for the boilers and furnaces shall be as follows: Emission Factor (lb/MMscf) * Gas Consumption (MMscf/24 hrs)/(2,000 lb/ton) F. Results shall be tabulated for each day, and records shall be kept which include the meter readings (in the appropriate units) and the calculated emissions. [SIP Section IX.H.2.d.i.C] 12 II.B.1.f.2 The emission factors derived from the most current performance test shall be applied to the relevant quantities of fuel combusted. Unless adjusted by performance testing, the default emission factors to be used are as follows: A. Natural gas: Filterable PM10: 1.9 lb/MMscf Condensable PM10: 5.7 lb/MMscf B. Plant gas: Filterable PM10: 1.9 lb/MMscf Condensable PM10: 5.7 lb/MMscf C. Diesel fuel: shall be determined from the latest edition of AP-42 or other EPA approved methods. D. Cooling Towers: shall be determined from the latest edition of AP-42 or other EPA approved methods. E. FCC Stack: The PM10 emission factors shall be based on the most recent stack test and verified by parametric monitoring. F. Where mixtures of fuel are used in a Unit, the above factors shall be weighted according to the use of each fuel. [SIP Section IX.H.2.d.i.A] II.B.1.f.3 The default emission factors listed above apply until such time as stack testing is conducted. Initial PM10 stack testing on the FCC stack has been performed and shall be conducted at least once every three (3) years from the date of the last stack test. Stack testing shall be performed as outlined in Condition II.B.1.e. [SIP Section IX.H.2.d.i.B] Status: In compliance – The AO dated March 2020 and PM10 SIP CAP the emissions. According to the reviewed spreadsheet, the daily maximum has not been exceeded since the September 2022 inspection. The last PM10 stack test was conducted in 2017. II.B.1.g Source-wide combined emissions of PM2.5 (filterable + condensable) shall not exceed 0.305 tons per day (tpd) and 110 tons per rolling 12-month period. [SIP Section IX.H.12.d.i] 13 II.B.1.g.1 Compliance with the source-wide PM2.5 Cap shall be determined for each day as follows: A. Total 24-hour PM2.5 emissions for the emission points shall be calculated by adding the daily results of the PM2.5 emissions equations listed below for natural gas, plant gas, and fuel oil combustion. These emissions shall be added to the emissions from the FCCU to arrive at a combined daily PM2.5 emission total. B. For purposes of this subsection a "day" is defined as a period of 24-hours commencing at midnight and ending at the following midnight. C. Daily natural gas and plant gas consumption shall be determined through the use of flow meters. D. Daily fuel oil consumption shall be monitored by means of leveling gauges on all tanks that supply combustion sources. E. The equation used to determine emissions for the boilers and furnaces shall be as follows: Emissions = Emission Factor (lb/MMscf) * Gas Consumption (MMscf/24 hrs)/(2,000 lb/ton) F. Results shall be tabulated for each day, and records shall be kept which include the meter readings (in the appropriate units) and the calculated emissions. [SIP Section IX.H.12.d.i.C] II.B.1.g.2 The emission factors derived from the most current performance test shall be applied to the relevant quantities of fuel combusted. Unless adjusted by performance testing, the default emission factors to be used are as follows: A. Natural gas: Filterable PM2.5: 1.9 lb/MMscf Condensable PM2.5: 5.7 lb/MMscf B. Plant gas: Filterable PM2.5: 1.9 lb/MMscf Condensable PM2.5: 5.7 lb/MMscf C. Diesel fuel: shall be determined from the latest edition of AP-42 or other EPA approved methods. D. FCC Stack: The PM2.5 emission factors shall be based on the most recent stack test and verified by parametric monitoring. E. Where mixtures of fuel are used in a Unit, the above factors shall be weighted according to the use of each fuel. [SIP Section IX.H.12.d.i.A] 14 II.B.1.g.3 The default emission factors listed above apply until such time as stack testing is conducted. Initial PM2.5 stack testing on the FCC stack has been performed and shall be conducted at least once every three (3) years from the date of the last stack test. Stack testing shall be performed as outlined in Condition II.B.1.e. [SIP Section IX.H.12.d.i.B] Status: In compliance – According to the reviewed spreadsheet, the daily maximum has not been exceeded since the September 2022 inspection. Records also indicated that during the 12-month period ending July 2023, 51.5 tons of PM2.5 were emitted from all stationary emission points. The last PM2.5 stack test was conducted on June 10 and 11, 2020. The most recent stack test was scheduled to be conducted on August 18, 2023. II.B.1.h Source-wide combined emissions of NOx shall not exceed 2.1 tons per day (tpd) and 766.5 tons per rolling 12-month period. [SIP Section IX.H.12.d.ii] II.B.1.h.1 Compliance with the source-wide NOx Cap shall be determined for each day as follows: A. Total 24-hour NOx emissions shall be calculated by adding the emissions for each emitting unit. B. The emissions for each emitting unit shall be calculated by multiplying the hours of operation of a unit, feed rate to a unit, or quantity of each fuel combusted at each affected unit by the associated emission factor, and summing the results. C. A NOx CEM shall be used to calculate daily NOx emissions from the FCCU. D. A NOx CEM shall be used to calculate daily NOx emissions from Boiler #7 E. For purposes of this subsection a "day" is defined as a period of 24-hours commencing at midnight and ending at the following midnight. F. Daily natural gas and plant gas consumption shall be determined through the use of flow meters. G. Daily fuel oil consumption shall be monitored by means of leveling gauges on all tanks that supply combustion sources. H. Results shall be tabulated for each day, and records shall be kept which include the meter readings (in the appropriate units) and the calculated emissions. [SIP Section IX.H.12.d.ii.C] 15 II.B.1.h.2 The emission factors derived from the most current performance test shall be applied to the relevant quantities of fuel combusted. Unless adjusted by performance testing, the default emission factors to be used are as follows: A. Natural gas: shall be determined from the latest edition of AP-42 or other EPA approved methods. B. Plant gas: shall be assumed equal to natural gas C. Alkylation polymer: shall be determined from the latest edition of AP-42 (as fuel oil #6) or other EPA approved methods. D. Diesel fuel: shall be determined from the latest edition of AP-42 or other EPA approved methods. E. Where mixtures of fuel are used in a Unit, the above factors shall be weighted according to the use of each fuel. [SIP Section IX.H.12.d.ii.A] II.B.1.h.3 The default emission factors listed above apply until such time as stack testing is conducted. Initial NOx stack testing on natural gas/refinery fuel gas combustion equipment above 100 MMBtu/hr has been performed and shall be conducted at least once every three (3) years from the date of the last stack test. At that time a new flow-weighted average emission factor in terms of: lbs/MMbtu shall be derived for each combustion type listed above. Stack testing shall be performed as outlined in Condition II.B.1.e. [SIP Section IX.H.12.d.ii.B] Status: In compliance – According to the reviewed spreadsheet, the daily maximum has not been exceeded since the September 2022 inspection. Records also indicated that during the 12-month period ending July 2023, 253.6 tons of NOx were emitted from all stationary emission points. The last NOx stack test for the boilers was November 1, 2021, and November 15, 2022. The most recent stack tests are scheduled to be conducted in 2023 and 2024. II.B.1.i Source-wide combined emissions of SO2 shall not exceed 1.05 tons per day (tpd) and 383.3 tons per rolling 12-month period. [SIP Section IX.H.12.d.iii] II.B.1.i.1 Compliance with the source-wide SO2 Cap shall be determined for each day as follows: A. Total daily SO2 emissions shall be calculated by adding the daily SO2 emissions for natural gas and plant fuel gas combustion, to those from the FCC and SRU stacks. B. Daily natural gas and plant gas consumption shall be determined through the use of flow meters. 16 C. Daily fuel oil consumption shall be monitored by means of leveling gauges on all tanks that supply combustion sources. D. Results shall be tabulated for each day, and records shall be kept which include CEM readings for H2S (averaged for each one-hour period), all meter readings (in the appropriate units), fuel oil parameters (density and wt% sulfur for each day any fuel oil is burned), and the calculated emissions. E. For purposes of this subsection a "day" is defined as a period of 24-hours commencing at midnight and ending at the following midnight. [SIP Section IX.H.12.d.iii.B] II.B.1.i.2 The emission factors derived from the most current performance test shall be applied to the relevant quantities of fuel combusted. The default emission factors to be used are as follows: A. FCCU: The emission rate shall be determined by the FCC SO2 CEM. B. SRUs: The emission rate shall be determined by multiplying the sulfur dioxide concentration in the flue gas by the flow rate of the flue gas. The sulfur dioxide concentration in the flue gas shall be determined by CEM. C. Natural gas: EF = 0.60 lb/MMscf D. Fuel oil: The emission factor to be used for combustion shall be calculated based on the weight percent of sulfur, as determined by ASTM Method D-4294-89 or EPA approved equivalent acceptable to the Director, and the density of the fuel oil, as follows: EF (lb SO2/k gal) = density (lb/gal) * (1000 gal/k gal) * wt.% S/100 * (64 lb SO2/32 lb S) E. Plant gas: the emission factor shall be calculated from the H2S measurement obtained from the H2S CEM. F. Where mixtures of fuel are used in a Unit, the above factors shall be weighted according to the use of each fuel. [SIP Section IX.H.12.d.iii.A] Status: In compliance – According to the reviewed spreadsheet, the daily maximum was exceeded only on one day since the September 2022 inspection. The one-day event had an SO2 value of 2.93 tons. This event is covered in the CEMs Quarterly Report and the Federal EPA CD. Records also indicated that during the 12-month period ending July 2023, 41.8 tons of SO2 were emitted from all stationary emission points. 17 II.B.2 Conditions on Boiler #11005 (Boiler #5) II.B.2.a NOx emissions shall not exceed the following rate on a 30-day rolling average basis: [NSPS Db §60.44b(b) and §60.44b(i)] En = ((0.1 x Hgo) + (0.2 x Hr)) / (Hgo + Hr) Where: En = NOx emission limit (lb/MMbtu) Hgo = 30-day heat input from combustion of natural gas or distillate oil Hr = 30-day heat input from combustion of any other fuel. [ 40 CFR 60 Subpart Db] II.B.2.a.1 The NOx emission rate shall be predicted based on excess O2 in the flue gas and by boiler loading as specified in a plan submitted to and approved by the Director [NSPS Db §60.48b(g)(2)]. Predicted NOx emission rate shall be evaluated at least every three (3) years through testing as outlined in Condition II.B.1.e. [40 CFR 60 Subpart Db] Status: In compliance – Only plant fuel gas and natural gas are burned. Plant fuel gas is mainly burned so the calculated NOx emission limit is usually between 0.022 – 0.050 lb/MMbtu. The last NOx stack test result, for boiler # 5, was 0.129 lb/MMBtu. No exceedances were found at the time of the inspection. See status of condition II.B.1.h. II.B.3 Conditions on Boiler #11006 (Boiler #6) II.B.3.a NOx emissions shall not exceed the following rate on a 30-day rolling average basis: [NSPS Db §60.44b(b) and §60.44b(i)] En = ((0.1 x Hgo) + (0.2 x Hr)) / (Hgo + Hr) Where: En = NOx emission limit (lb/MMbtu) Hgo = 30-day heat input from combustion of natural gas or distillate oil Hr = 30-day heat input from combustion of any other fuel. [ 40 CFR 60 Subpart Db] II.B.3.a.1 The NOx emission rate shall be predicted based on excess O2 in the flue gas and by boiler loading as specified in a plan submitted to and approved by the Director [NSPS Db §60.48b(g)(2)]. Predicted NOx emission rate shall be evaluated at least every three (3) years through testing as outlined in Condition II.B.1.e. [40 CFR 60 Subpart Db] Status: In compliance – Only plant fuel gas and natural gas are burned. Plant fuel gas is mainly burned so the calculated NOx emission limit is usually between 0.057 – 0.038 lb/MMbtu. The last NOx stack test result, for boiler # 6, was 0.099 lb/MMBtu. No exceedances were found at the time of the inspection. See status of condition II.B.1.h. 18 II.B.4 Conditions on the SRUs II.B.4.a All petroleum refineries in or affecting any PM2.5 nonattainment area or any PM10 nonattainment or maintenance area shall require: A. Sulfur removal units/plants (SRUs) that are at least 95% effective in removing sulfur from the streams fed to the unit; or B. SRUs that meet the SO2 emission limitations listed in 40 CFR 60.102a(f)(1) or 60.102a(f)(2) as appropriate. [SIP Section IX.H.1.g.iii.A] Status: Not Evaluated -- CEM requirements are evaluated by DAQ’s CEM specialist. II.B.4.b The owner/operator shall process amine acid gas and sour water stripper acid gas in the SRU(s). [SIP Section IX.H.1.g.iii.B] II.B.4.b.1 Compliance shall be demonstrated by daily monitoring of flows to the SRU(s). Compliance shall be determined on a rolling 30-day average. [SIP Section IX.H.1.g.iii.C] Status: Not Evaluated – CEM requirements are evaluated by DAQ’s CEM specialist. II.B.5 Conditions on SRU and Tail Gas Treatment Unit #1 II.B.5.a Emissions of SO2 from SRU #1 shall not exceed 0.242 tons/day. [R307-401] II.B.5.a.1 Daily sulfur dioxide emissions shall be determined by multiplying the sulfur dioxide concentration in the flue gas by the mass flow of the flue gas. The sulfur dioxide concentration in the flue gas shall be determined by a CEM that meets or exceeds the requirements contained in 40 CFR 60, Appendix B: Performance Specification 2. The monitor shall be maintained and calibrated in accordance with R307- 170, UAC. 40 CFR 60 Methods 2, 3A and 6C shall be used to determine relative accuracy. If a new monitor is installed, an initial performance evaluation shall be performed within 30 days of installation. The performance evaluation shall be conducted and data reduced in accordance with the methods and procedures contained in 40 CFR 60, Appendix B: Performance Specification 2. Notification must be made to the Director prior to conducting the performance evaluation. Whenever the SO2 CEM is bypassed for short periods, SO2 CEM data from the previous three (3) days will be averaged and used as an emission factor to determine emissions. 19 The mass flow rate of the flue gas shall be determined by a volumetric flow measurement device that meets or exceeds the requirements contained in 40 CFR 52 Appendix E. An annual relative accuracy test audit shall be conducted, and quarterly reports submitted, in accordance with the procedures outlined in R307-170, UAC, and 40 CFR 52 Appendix E. If a new volumetric flow measurement device is installed, an initial performance evaluation shall be performed within 30 days of installation. The performance evaluation shall be conducted and data reduced in accordance with the test methods and procedures contained in 40 CFR 52 Appendix E. Notification must be made to the Director prior to conducting the performance evaluation. The source shall maintain records of the SO2 concentration, the mass flow rate, and the resulting calculated emissions. Records of all CEM calibrations shall also be maintained. [R307-401] Status: Not Evaluated – CEM requirements are evaluated by DAQ’s CEM specialist. II.B.5.b Emissions of SO2 from SRU #1 shall not exceed 88.5 tons/yr. [R307-401] II.B.5.b.1 Compliance shall be determined on a 12-month rolling average. Each month, the SO2 emissions calculated to show compliance with the daily limitations for the previous month shall be summed to give a monthly emission total. This shall be added to the previous 11 months' emission totals to give the new 12-month rolling total. [R307-401] Status: In compliance – Records indicated that during the 12-month period ending July 2023, 8.1 tons of SO2 emissions were emitted from SRU and Tail Gas Treatment Unit 1. II.B.5.c The owner/operator shall continue to route or re-route all sulfur pit emissions so that they are eliminated, controlled, or included and monitored as part of the SRU's emissions subject to the emissions limits of II.B.5. [Consent Decree] Status: In compliance – Sulfur pit emissions are routed to an incinerator. The emissions are monitored as part of the SRU’s emissions. II.B.6 Conditions on SRU and Tail Gas Treatment Unit #2 II.B.6.a Emissions of SO2 from SRU #2 shall not exceed 0.268 tons/day. [R307-401] II.B.6.a.1 Daily sulfur dioxide emissions shall be determined by multiplying the sulfur dioxide concentration in the flue gas by the mass flow of the flue gas. The sulfur dioxide concentration in the flue gas shall be determined by a CEM that meets or exceeds the requirements contained in 40 CFR 60, Appendix B: Performance Specification 2. The monitor shall be maintained and calibrated in accordance with R307- 170, UAC. 40 CFR 60 Methods 2, 3A and 6C shall be used to determine relative accuracy. If a new monitor is installed, an initial performance evaluation shall be performed within 30 days of installation. The performance evaluation shall be conducted and data reduced in accordance with the methods and procedures contained in 40 CFR 60, Appendix B: Performance Specification 2. Notification must be made to the Director prior to conducting the performance evaluation. Whenever the SO2 CEM is bypassed for short periods, SO2 CEM data from the previous three days will be averaged and used as an emission factor to determine emissions. 20 The mass flow rate of the flue gas shall be determined by a volumetric flow measurement device that meets or exceeds the requirements contained in 40 CFR 52 Appendix E. An annual relative accuracy test audit shall be conducted, and quarterly reports submitted, in accordance with the procedures outlined in R307-170, UAC, and 40 CFR 52 Appendix E. If a new volumetric flow measurement device is installed, an initial performance evaluation shall be performed within 30 days of installation. The performance evaluation shall be conducted and data reduced in accordance with the test methods and procedures contained in 40 CFR 52 Appendix E. Notification must be made to the Director prior to conducting the performance evaluation. The source shall maintain records of the SO2 concentration, the mass flow rate, and the resulting calculated emissions. Records of all CEM calibrations shall also be maintained. [R307-401] Status: Not evaluated – CEM requirements are evaluated by DAQ’s CEM specialist. II.B.6.b Emissions of SO2 from SRU #2 shall not exceed 97.7 tons/yr. [R307-401] II.B.6.b.1 Compliance shall be determined on a 12-month rolling average. Each month, the SO2 emissions calculated to show compliance with the daily limitations for the previous month shall be summed to give a monthly emission total. This shall be added to the previous 11 months' emission totals to give the new 12-month rolling total. [R307-401] Status: In compliance – Records indicated that during the 12-month period ending July 2023, 13.7 tons of SO2 emissions were emitted from SRU and Tail Gas Treatment Unit 2. II.B.6.c The owner/operator shall continue to route or re-route all sulfur pit emissions so that they are eliminated, controlled, or included and monitored as part of the SRU's emissions subject to the emissions limits of II.B.6. [Consent Decree] Status: In compliance – Sulfur pit emissions are routed to an incinerator. The emissions are monitored as part of the SRU’s emissions. II.B.7 Conditions on the FCC and Catalyst Regenerator II.B.7.a Emissions of SO2 from the FCCU Regenerator Vent shall not exceed the following rates and concentrations: A. 25 ppmvd SO2 @ 0% O2 on a 365-day rolling average B. 50 ppmvd SO2 @ 0% O2 on a 7-day rolling average C. 50 tons of SO2 on a 12-month rolling average D. 0.28 tons of SO2 per day. SO2 emissions during periods of Startup, Shutdown, or Malfunction shall not be used in determining compliance with the emission limit of 50 ppmvd SO2 @ 0% O2 on a 7-day rolling average basis. 21 The SO2 short-term limit listed in B. above shall exclude FCCU feed hydrotreater outages if Chevron complies with an EPA-approved hydrotreater outage plan and is maintaining and operating the FCCU in a manner consistent with good air pollution control practices. It shall apply at all other times the FCCU is in operation. In addition, in the event that the source asserts that the basis for a specific Hydrotreater Outage is a shutdown (where no catalyst changeout occurs) required by ASME pressure vessel requirements or applicable state boiler requirements, the source shall submit a report to EPA that identifies the relevant requirements and justifies the permittee's decision to implement the shutdown during the selected time period. [Consent Decree, R307-401] II.B.7.a.1 The SO2 emission factor for the FCC and Catalyst Regenerator shall be determined by continuous emission monitor. The regenerator flow rate calculation established in 40 CFR 63 Subpart UUU (MACT UUU) shall be used in conjunction for this calculation. For continuous emission monitor calculations the monitor shall be operated, maintained, certified, and calibrated in accordance with R307-170, UAC. The provisions of 40 C.F.R. § 60.13 that are applicable to CEMS (excluding those provisions applicable only to Continuous Opacity Monitoring Systems) and Part 60 Appendices A and F, and the applicable performance specification test of 40 C.F.R. Part 60 Appendix B are applicable to the FCC/Catalyst Regenerator CEM. With respect to 40 C.F.R. Part 60, Appendix F, Chevron must conduct either a Relative Accuracy Audit ("RAA") or a Relative Accuracy Test Audit ("RATA") on each CEMS at least once every one (1) year. The source must also conduct Cylinder Gas Audits ("CGA") each calendar quarter during which a RAA or a RATA is not performed. With respect to the O2 CEMS, in lieu of the audit points specified in 40 C.F.R. Part 60, Appendix F § 5.1.2., the source may audit the O2 CEMS at 20-30% and 50-60% of the actual O2 CEMS span value. If a new monitor is installed, an initial performance evaluation shall be performed within 30 days of installation. The performance evaluation shall be conducted and data reduced in accordance with the test methods and procedures contained in 40 CFR 60, Appendix B: Performance Specification 2. Notification must be made to the Director prior to conducting the performance test. Whenever the SO2 CEM is bypassed for short periods, SO2 CEM data from the previous three (3) days will be averaged and used as an emission factor to determine emissions. For the stack test calculations to establish the FCC and Catalyst Regenerator SO2 emission factor, the owner/operator shall determine mass emission rates (lbs/hr, etc.) as follows: The pollutant concentration, as determined by the appropriate methods, shall be multiplied by the volumetric flow rate and any necessary conversion factors as determined by the Director. The owner/operator shall maintain a record of fuel meter identifiers and locations, conversion factors, and other information required to demonstrate the required calculations. Records shall be kept showing the daily fuel usage, fuel meter readings, required fuel properties, hours of equipment operation, and calculated daily emissions. [R307-170] Status: Not Evaluated – CEM requirements are evaluated by DAQ’s CEM specialist. 22 II.B.7.b Emissions of NOx from the FCCU Regenerator Vent shall not exceed the following rates: A. 100 tons of NOx per year on a rolling 12-month basis B. 0.55 tons per day C. 57.8 ppmvd @ 0% O2 on a 365-day rolling average D. 106.3 ppmvd @ 0% O2 on a 7-day rolling average The NOx long-term limit listed in C. above shall apply at all times the FCCU is in operation. The NOx short-term limit listed in D. above shall exclude periods of startup, shutdown, and malfunction. It shall also exclude FCCU feed hydrotreater outage if the owner/operator complies with an EPA-approved hydrotreater outage plan. It shall apply at all other times the FCCU is in operation. [R307-401] II.B.7.b.1 The NOx emission factor for the FCC and Catalyst Regenerator shall be determined by continuous emission monitor. The regenerator flow rate calculation established in 40 CFR 63 Subpart UUU (MACT UUU) shall be used in conjunction for this calculation. For continuous emission monitor calculations, the monitor shall be operated, maintained, calibrated, and certified in accordance with R307-170, UAC and the provisions of 40 C.F.R. § 60.13 that are applicable to CEMS (excluding those provisions applicable only to Continuous Opacity Monitoring Systems) and Part 60 Appendices A and F, and the applicable performance specification test of 40 C.F.R. Part 60 Appendix B. With respect to 40 C.F.R. Part 60, Appendix F, Chevron must conduct either a Relative Accuracy Audit ("RAA") or a Relative Accuracy Test Audit ("RATA") on each CEMS at least once every one (1) year. The source must also conduct Cylinder Gas Audits ("CGA") each calendar quarter during which a RAA or a RATA is not performed. With respect to the O2 CEMS, in lieu of the audit points specified in 40 C.F.R. Part 60, Appendix F § 5.1.2., the source may audit the O2 CEMS at 20-30% and 50-60% of the actual O2 CEMS span value. If a new monitor is installed, an initial performance evaluation shall be performed within 30 days of installation. The performance evaluation shall be conducted and data reduced in accordance with the test methods and procedures contained in 40 CFR 60, Appendix B: Performance Specification 2. Notification must be made to the Director prior to conducting the performance test. Whenever the NOx CEM is bypassed for short periods, NOx CEM data from the previous three (3) days will be averaged and used as an emission factor to determine emissions. For stack test calculations, mass emission rates (lbs/hr, etc.), the pollutant concentration, as determined by the appropriate methods, shall be multiplied by the volumetric flow rate and any necessary conversion factors as determined by the Director to establish the FCC and Catalyst Regenerator NOx emission factor. 23 The source shall maintain a record of fuel meter identifiers and locations, conversion factors, and other information required to demonstrate the required calculations. Records shall be kept showing the daily fuel usage, fuel meter readings, required fuel properties, hours of equipment operation, and calculated daily emissions. [R307-170] Status: Not Evaluated – CEM requirements are evaluated by DAQ’s CEM specialist. II.B.7.c Emissions of CO from the FCCU shall not exceed 500 ppmvd at 0% O2 on a 1-hour average basis. CO emissions during periods of startup, shutdown or malfunction shall not be used when determining compliance with this emission limit. [R307-401-8] II.B.7.c.1 The source shall use CO and O2 CEMS to monitor compliance with the CO emission limit for the FCCU and Catalyst Regenerator. The source shall install, certify, maintain, and operate the CEMS in accordance with the provisions of 40 C.F.R. § 60.13 that are applicable to CEMS (excluding those provisions applicable only to Continuous Opacity Monitoring Systems) and Part 60 Appendices A and F, and the applicable performance specification test of 40 C.F.R. Part 60 Appendix B. With respect to 40 C.F.R. Part 60, Appendix F, Chevron must conduct either a Relative Accuracy Audit ("RAA") or a Relative Accuracy Test Audit ("RATA") on each CEMS at least once every one (1) year. The source must also conduct Cylinder Gas Audits ("CGA") each calendar quarter during which a RAA or a RATA is not performed. With respect to the O2 CEMS, in lieu of the audit points specified in 40 C.F.R. Part 60, Appendix F § 5.1.2., the source may audit the O2 CEMS at 20-30% and 50-60% of the actual O2 CEMS span value. [R307-170] Status: Not Evaluated – CEM requirements are evaluated by DAQ’s CEM specialist. II.B.7.d The owner or operator of an FCCU shall comply with an emission limit of 1.0 pounds PM per 1000 pounds coke burn-off. [SIP Section IX.H.11.g.i.B.I] II.B.7.d.1 Compliance with this limit shall be determined by following the stack test protocol specified in 40 C.F.R. §60.106(b) to measure PM emissions on the FCCU. Each owner/operator shall conduct stack tests once every three (3) years at each FCCU. [SIP Section IX.H.11.g.i.B.II] Status In compliance – The refinery last tested the FCCU, for PM, on September 23, 2022. The result for PM was 0.149 lb/1000 lb coke burn-off. Results have been submitted to the DAQ. The latest stack test was scheduled for August 16, 2023. II.B.7.e Each owner or operator of an FCCU subject to NSPS Ja shall install, operate and maintain a continuous parameter monitor system (CPMS) to measure and record operating parameters from the FCCU and control devices as per the requirements of 40 CFR 60.105a(b)(1). Each owner or operator of an FCCU not subject to NSPS Ja shall install, operate and maintain a continuous opacity monitoring system to measure and record opacity from the FCCU as per the requirements of 40 CFR 63.1572(b) and comply with the opacity limitation as per the requirements of Table 7 to Subpart UUU of Part 63. [SIP Section IX.H.11.g.i.B.III] Status: In compliance – The refinery is not required to follow CPMS requirements regarding the FCCU (subject to NSPS Subpart J not Subpart Ja). CEM requirements are evaluated by DAQ’s CEM specialist. The FCCU is controlled by an electrostatic precipitator. Power input is measured and recorded. 24 II.B.7.f Opacity from the FCCU and Catalyst Regenerator shall be monitored by a continuous opacity monitoring system ("COMS"). The source shall install, certify, calibrate, maintain, and operate the COMS in accordance with 40 C.F.R. §§ 60.11, 60.13 and Part 60 Appendix A, and the applicable performance specification test of 40 C.F.R. Part 60 Appendix B. [Consent Decree] Status: Not Evaluated – CEM requirements are evaluated by DAQ’s CEM specialist. II.B.8 Conditions on Miscellaneous Diesel-fired Equipment II.B.8.a The owner/operator shall not operate each emergency engine, back-up pump or fire engine on site for more than 100 hours per calendar year during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60 Subpart ZZZZ, R307-401-8] II.B.8.a.1 To determine compliance with the above annual total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the equipment was used B. The duration of operation in hours C. The reason for the equipment usage. [40 CFR 60 Subpart ZZZZ, R307-401-8] II.B.8.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ] Status: In compliance – Non-resettable hour meters have been installed on all emergency generators. According to the records no engine has operated for more than 100 hours in a calendar year. The records also indicated that the engines are exercised weekly up to 30 minutes. II.B.8.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8] II.B.8.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.8.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] Status: In compliance – According to a Keller Strass invoice, dated February 2, 2021, only #2 ULSD was delivered. 25 II.B.8.c The following engines qualify under 40 CFR 63.6590(c) Stationary RICE subject to Regulations under 40 CFR Part 60: 1. North tank field generator: one (1) backup generator rated at 422 hp (315 kW) 2. Two (2) fire water emergency backup pumps rated at 375 hp (cont)/400 hp (max) each 3. TCLR generator: backup generator rated at 168 hp (125 kW) 4. Collection box backup pump: one (1) pump rated at 109 hp (81.4 kW) 5. One (1) canal fire water emergency generator rated at 369 hp (275 kW) These engines must meet the requirements of 40 CFR 63 Subpart ZZZZ, by meeting the requirements of 40 CFR 60 Subpart IIII. The requirements are listed at §60.4211(a), (c), (f), and (g). These engines are not subject to any additional requirements of 40 CFR 63 Subpart ZZZZ. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ] Status: In compliance – Engines are maintenance in-house at the maintenance shop. The Maximo database is used to track the maintenance. See status of condition II.B.8.a. II.B.9 Conditions on Reformer Compressor Engines II.B.9.a Emissions of NOx and CO at the three (3) listed reformer compressors shall not exceed the following concentration limits: K35001: 236 ppmvd NOx, 834 ppmvd CO K35002: 208 ppmvd NOx, 926 ppmvd CO K35003: 230 ppmvd NOx, 556 ppmvd CO. [R307-401-8(1)(a)] II.B.9.a.1 Demonstrating Compliance with Emission Limits A. Beginning no later than one (1) year after the Emission Limits Tests and every two (2) years thereafter, the owner/operator shall perform emission tests to demonstrate compliance with the emission limits established for the reformer compressor engines. The tests shall be conducted on each engine and shall be the average of three (3) one- hour tests on each engine. The tests shall be conducted, and the emissions shall be calculated, in accordance with 40 CFR § 60.4244. B. The owner/operator shall continuously measure and record the catalyst inlet temperature data in according to 40 CFR § 63.6625(b); reduce these data to 4-hour rolling averages, and maintain the 4-hour rolling averages within the operating limitations for the catalyst inlet temperature, except for periods of startup, shutdown, and malfunction, as those terms are defined in 40 CFR § 60.2. C. The owner/operator shall measure and record the pressure drop across each catalyst bed once per month. The owner/operator shall maintain each catalyst bed so that the pressure drop across each catalyst is within the operating limitation established during the Emission Limits Tests. 26 D. The owner/operator shall replace the O2 sensor on each reformer compressor engine in accordance with the vendor-recommended preventative maintenance schedule. Following each O2 sensor replacement, the owner/operator shall measure NOx and CO emissions once using a portable analyzer to determine the adequate set point of the AFRC to maintain operation of the reformer compressor engine near stoichiometric conditions. The owner/operator shall maintain records documenting sensor replacement and portable analyzer results. [R307-150] Status: In compliance – Stack test have been conducted and results submitted to the DAQ. Records of catalyst inlet temperatures, catalyst pressure drops, O2 sensor replacement, and portable analyzer results are maintained. See Table: Compressor Engines Limits (ppmvd) Results (ppmvd) Test Date K35001 236 NOx and 834 CO 116.5 NOx and 195.2 CO 8/31/2021 K35002 208 NOx and 926 CO 100.6 NOx and 55.1 CO 9/1/2021 K35003 230 NOx and 556 CO 154.8 NOx and 21.6 CO 12/21/2021 The latest stack test was scheduled for August 21 and 22, 2023. II.B.10 Miscellaneous SIP Conditions II.B.10.a The owner or operator shall comply with the requirements of 40 CFR 63.654 for heat exchange systems in VOC service. The owner or operator may elect to use another EPA-approved method other than the Modified El Paso Method if approved by the Director. The following applies in lieu of 40 CFR 63.654(b): A heat exchange system is exempt from the requirements in paragraphs 63.654(c) through (g) of this section if it meets any one of the criteria in the following paragraphs (1) through (2) of this section. 1. All heat exchangers that are in VOC service within the heat exchange system that either: A. Operate with the minimum pressure on the cooling water side at least 35 kilopascals greater than the maximum pressure on the process side; or B. Employ an intervening cooling fluid, containing less than 10 percent by weight of VOCs, between the process and the cooling water. This intervening fluid must serve to isolate the cooling water from the process fluid and must not be sent through a cooling tower or discharged. For purposes of this section, discharge does not include emptying for maintenance purposes. 2. The heat exchange system cools process fluids that contain less than 10 percent by weight VOCs (i.e., the heat exchange system does not contain any heat exchangers that are in VOC service). [SIP Section IX.H.11.g.iii.A] Status: LDAR requirements are evaluated in Partial Compliance Evaluation 1 of 4. 27 II.B.10.b For leak detection and repair, the owner/operator shall comply with the following: A. The owner/operator shall comply with the requirements of 40 CFR 60.590a to 60.593a B. For units complying with the Sustainable Skip Period, previous process unit monitoring results may be used to determine the initial skip period interval provided that each valve has been monitored using the 500 ppm leak definition. [SIP Section IX.H.11.g.iv] Status: LDAR requirements are evaluated in Partial Compliance Evaluation 1 of 4. II.B.10.c The owner/operator shall not allow any stationary tank of 40,000-gallon or greater capacity and containing or last containing any organic liquid, with a true vapor pressure equal or greater than 10.5 kPa (1.52 psia) at storage temperature (see R307-324-4(1)) to be opened to the atmosphere unless the emissions are controlled by exhausting VOCs contained in the tank vapor-space to a vapor control device until the organic vapor concentration is 10 percent or less of the lower explosion limit (LEL). These degassing provisions shall not apply while connecting or disconnecting degassing equipment. [SIP Section IX.H.11.g.vi] II.B.10.c.1 The Director shall be notified of the intent to degas any tank subject to the rule. Except in an emergency situation, initial notification shall be submitted at least three (3) days prior to degassing operations. The initial notification shall include: A. Start date and time; B. Tank owner, address, tank location, and applicable tank permit numbers; C. Degassing operator's name, contact person, and telephone number; D. Tank capacity, volume of space to be degassed, and materials stored; E. Description of vapor control device. [SIP Section IX.H.11.g.vi.C] Status: Tank requirements are evaluated in Partial Compliance Evaluation 2 of 4. II.B.10.d All hydrocarbon flares at petroleum refineries located in or affecting a PM2.5 nonattainment area or any PM10 nonattainment or maintenance area shall be subject to the flaring requirements of NSPS Subpart Ja (40 CFR 60.100a-109a), if not already subject under the flare applicability provisions of Ja. [SIP Section IX.H.11.g.v.A] 28 II.B.10.d.1 The owner/operator shall either: 1. Install and operate a flare gas recovery system designed to limit hydrocarbon flaring produced from each affected flare during normal operations to levels below the values listed in 40 CFR 60.103a(c), or 2) Limit flaring during normal operations to 500,000 scfd for each affected flare. Flare gas recovery is not required for dedicated SRU flare and header systems, or HF flare and header systems. [SIP Section IX.H.11.g.v.B] Status: Flare requirements are evaluated in Partial Compliance Evaluation 3 of 4. A flare gas recovery system has been installed for flares 1 and 2. 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 PREVIOUS ENVORCEMENT ACTIONS: None within the previous 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: Chevron Products Company should be considered to be in compliance with AO DAQE-AN1011901006-22, dated August 24, 2022, at time of the 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