DAQ-2024-005184

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DAQC-197-24
Site ID 10123 (B1)

MEMORANDUM

TO: FILE – HF SINCLAIR WOODS CROSS REFINING, LLC (HF Sinclair)

THROUGH: Harold Burge, Major Source Section Manager

FROM: Joe Rockwell, Environmental Scientist

DATE: October 16, 2023

SUBJECT: Partial Compliance Evaluation (PCE #2 of #4) – MACT I – Tanks and WWTP, Major,
Davis County, FRS ID# UT0000004901100013

INSPECTION DATES: September 18-20, 2023

SOURCE LOCATION: 393 South 800 West, Woods Cross, Utah 84087

MAILING ADDRESS: 1070 West 500 South, West Bountiful, Utah 84087

SOURCE CONTACTS: Eric Benson – Environmental Manager,
Office: [phone]
Mobile: [phone]
[e-mail]

F. Travis Smith – Environmental Specialist,
Office: [phone]
Mobile: [phone]
[e-mail]

Richmond Thornley – Environmental Engineer,
Office: [phone]
Mobile: [phone]
[e-mail]

Al Vargas – Environmental Specialist,
Office: [phone]
Mobile: [phone]
[e-mail]

Matt Howes – Environmental Engineer,
Office: [phone]
Mobile: [phone]
[e-mail]

OPERATING STATUS: Operating. The SDA unit # 10 was not operating.

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PROCESS DESCRIPTION:

The HF Sinclair refinery processes crude petroleum. The process capacity is 60,000 barrels/day of crude oils. The
raw materials feed through a network of process units to produce fuels and asphalt oil. Various types of storage
tanks and vessels are used. Process tanks, vessels, and pipes allow the raw materials to be exposed to various
temperatures, pressures, vacuums, or catalysts resulting in the separation or transformation of raw materials into
intermediate or final products. Two flares are used to control emergency and other captured emissions from
process units. Storage tank emissions are controlled under 40 CFR 63 Subpart CC.

Waste Water Treatment Plant:

The Waste Water Treatment Plant (WWTP), (Unit 56) treats plant wastewater and storm water runoff from
process areas. Wastewater is collected and routed through a grit collector then to a main process lift station. The
main process lift station supplies process waste water to two American Petroleum Institute (API) separators. Oil is
skimmed off the separators and gravity fed to an API oil collection drum then to Tank 118. The sludge from the
API separators is collected and dewatered in a sludge thickening vessel and later sent for reuse.

The effluent water from the API separators is pumped to two equalization tanks (Tanks 155 and 158). From the
equalization tanks, waste water is pumped into two dissolved gas floatation units (DGF). The DGFs works to
remove emulsified oil from the waste water by adding a polymer and inducing small air bubbles into the water to
bring oil to the surface. This skimmed oil, or float, is gravity fed to a storage tank before being pumped to the
sludge thickening vessel.

Finally, the waste water is sent to a series of moving bio-film reactors (MBBR) for biological polishing before
being discharged to the Davis County Public Owned Treatment Works (POTW). All process tanks and equipment
at the WWTP are covered to control fugitive emissions.

West Tank Farm:

The West Tank Farm (WTF) consists of the storage tanks located west of the refinery unit area. Light petroleum
products, including crude oil, gasolines, jet fuel, gas oil, NGL, propane, and butanes are stored at the WTF.
Gasoline intermediates and products are stored in floating roof tanks. Compressed propane and butane gas, also
known as Liquefied Petroleum Gas (LPG), are stored in horizontal, pressurized tanks, commonly referred to as
“bullet” tanks because of their shape. The tank farm blends gasoline for shipment via truck and pipeline. There are
truck loading spots for propane, butane, and spent caustics.

East Tank Farm:

East Tank Farm (ETF) consists of the tanks located east of 800 West and north of 500 South. Mainly heavy
products such as diesel and fuel oil are stored at in the ETF. There are 10 plant gas fired stab-in furnaces that are
used to heat asphalt. Loading operations to rail tankers are also located in this area. The loading racks are located
adjacent to 800 West.

APPLICABLE REGULATIONS:

STATE REGULATIONS:

Letter DAQE-GN101230048-16 – Notification of Company Name Change

UAC R307-326, Control of Hydrocarbon Emissions in Petroleum Refineries.

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UAC R307-327, Petroleum Liquid Storage

UAC R307-328, Gasoline Transfer and Storage

PM10 SIP Section IX.H.1.a

PM2.5 SIP Section IX.H.11

Title V (Part 70) Major Source

FEDERAL REGULATIONS:

NSPS (Part 60), A: General Provisions

NSPS (Part 60), Db: Standards of Performance for Industrial-Commercial-Institutional
Steam Generating Units
NSPS (Part 60), Dc: Standards of Performance for Small Industrial -Commercial-
Institutional Steam Generating Units
NSPS (Part 60), GGG: Standards of Performance for Equipment Leaks of VOC in
Petroleum Refineries for which Construction, Reconstruction, or Modification Commenced
After January 4, 1983, and on or Before November 7, 2006
NSPS (Part 60), GGGa: Standards of Performance for Equipment Leaks of VOC in
Petroleum Refineries for Which Construction, Reconstruction, or Modification Commenced
After November 7, 2006
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition
Internal Combustion Engines
NSPS (Part 60), J: Standards of Performance for Petroleum Refineries
NSPS (Part 60), Ja: Standards of Performance for Petroleum Refineries for
Which Construction, Reconstruction, or Modification Commenced After May
14, 2007
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition
Internal Combustion Engines
NSPS (Part 60), K: Standards of Performance for Storage Vessels for Petroleum Liquids
for Which Construction, Reconstruction, or Modification Commenced After June 11,
1973, and Prior to May 19, 1978
NSPS (Part 60), Ka: Standards of Performance for Storage Vessels for Petroleum Liquids
for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978,
and Prior to July 23, 1984
NSPS (Part 60), Kb: Standards of Performance for Volatile Organic Liquid Sto rage
Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction,
Reconstruction, or Modification Commenced After July 23, 1984
NSPS (Part 60), QQQ: Standards of Performance for VOC Emissions From
Petroleum Refinery Wastewater Systems
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NSPS (Part 60), UU: Standards of Performance for Asphalt Processing and Asphalt
Roofing Manufacture
NSPS (Part 60), VVa: Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic
Chemicals Manufacturing Industry for Which Construction, Reconstruction, or Modification Commenced After
November 7, 2006

NESHAP (Part 61), A: General Provisions

NESHAP (Part 61), FF: National Emission Standard for Benzene

MACT (Part 63), A: General Provisions
MACT (Part 63), CC: National Emission Standards for Hazardous Air Pollutants from
Petroleum Refineries
MACT (Part 63), DDDDD: National Emission Standards for Hazardous Air Pollutants
for Major Sources: Industrial, Commercial, and Institutional Boilers Heaters
MACT (Part 63), UUU: National Emission Standards for Hazardous Air Pollutants
for Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and
Sulfur Recovery Units
MACT (Part 63), WW: National Emission Standards for Storage Vessels (Tank s) -
Control Level 2
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants
for Stationary Reciprocating Internal Combustion Engines

SOURCE EVALUATION:
Current tank status at time of the inspection:

Tanks 64, 85, 95, 96, 97, 98, 173, and 174 have been removed from the refinery. Tanks 87, 89, 91, 93, and 94
were never and will never be constructed. There are plans to construct tanks 90, 92, and 170. Also, the
roofs of tanks 139 and 140 were modified.

Note: The above-mentioned tank status will be in the equipment list of the new Title V Permit 1100013001.

NSPS (Part 60), K: Standards of Performance for Storage Vessels for Petroleum Liquids for
Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and
Prior to May 19, 1978

Status: In compliance – Tanks that fall within the dates of June 11, 1973, to May 19, 1978, and required
size requirements: Tanks 145 and 146 both have capacities of 167,370 gallons. Both tanks are equipped
with external floating roofs and primary and secondary seals for meeting the VOC storage requirements of
60.112(a). The vapor pressure of the material stored is 5 psia. Thus, the floating roofs meet the standard for
VOC and does not require a VRU. Under 60.113, HF Sinclair is not required to maintain records to show
compliance.

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NSPS (Part 60), Ka: Standards of Performance for Storage Vessels for Petroleum Liquids for Which
Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984

Status: N/A – Tanks that fall within the date and size requirements listed in HF Sinclair’s Tank
Information Sheet: Tank 77 has a capacity of less than 1,589,873 liters (420,000 gallons) and is used for
petroleum or condensate stored, processed, or treated prior to custody transfer it is not an affected facility
and, therefore, is exempt from the requirements of this subpart.

NSPS (Part 60), 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 – Subpart Kb applies to Group 1 and Group 2 storage vessels, at an existing source,
that meet the applicability requirements of the Subpart. The company submitted a spreadsheet showing
each tank with type of service, date of install, type of tank, and applicable regulations.

60.112b Standard for volatile organic compounds (VOC).

Status: In compliance – All required tanks have floating roofs (pontoon type). Filling, emptying, or refilling
is continuous and accomplished as rapidly as possible. A 30-day notice is required under this Subpart.
Reports are submitted to DEQ as required.

60.113b Testing and procedures.

Status: In compliance – Subpart Kb requires inspecting the primary seal once every 5 years and the
secondary seal once per year. Records show gap measurements on primary and secondary seals are taken
as required for all tanks. Gaps in primary seals are measured at least once every 5 years and gaps in
secondary seals are measured annually. Records show primary seals are inspected annually and secondary
seals every six months per UACR. Notification of gap seal measurements are submitted 30 days prior to the
measurement date and are in the HF Sinclair Refining file. Probes are used to determine the size of gaps.
All repairs required on the seals have been made within the 45-day time limit. Any time a tank is emptied
and degassed, inspections are conducted, and all needed repairs are made.

60.115b Reporting and record keeping requirements.

Status: In compliance – Tank seal measurement result notifications have been submitted. Notifications
contain all raw data obtained in the measurement and calculations of gap area. Copies of all reports are
maintained for a minimum two-year period. All electronic records observed contained the information
required under this section and appeared to be complete for each tank.

60.116b Monitoring of operations.

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

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MACT (Part 63), A: NESHAP General Provisions

Status: In compliance – HF Sinclair complies with the General Provisions as it is applicable to Subpart CC.
Notifications and reports are submitted on time. A SSM plan has been developed and an SSM Log is
submitted with the quarterly LDAR report. Reports are sent when required. Maintenance requirements
appeared to be met. Records are kept on electronically.

MACT (Part 63), CC: NESHAP for Petroleum Refineries

63.640 Applicability and designation of affected sources.

Status: In compliance – Subpart CC applies to Group 1 and 2 storage vessels, at an existing source, that
meet the applicability requirements of the subpart. HF Sinclair operates petroleum refining process units
that are a major source. Affected sources are miscellaneous process vents, storage vessels, wastewater
streams and treatment operations, equipment leaks, and heat exchange systems.

63.640(l)

If an additional petroleum refining process unit is added to a plant site or if a miscellaneous process vent, storage
vessel, gasoline loading rack, marine tank vessel loading operation, heat exchange system, or decoking operation
that meets the criteria in paragraphs (c)(1) through (9) of this section is added to an existing petroleum refinery or
if another deliberate operational process change creating an additional Group 1 emissions point(s) (as defined in §
63.641) is made to an existing petroleum refining process unit, and if the addition or process change is not subject
to the new source requirements as determined according to paragraph (i) or (j) of this section, the requirements in
paragraphs (l)(1) through (4) of this section shall apply. Examples of process changes include, but are not limited
to, changes in production capacity, or feed or raw material where the change requires construction or physical
alteration of the existing equipment or catalyst type, or whenever there is replacement, removal, or addition of
recovery equipment. For purposes of this paragraph (l) and paragraph (m) of this section, process changes do not
include: Process upsets, unintentional temporary process changes, and changes that are within the equipment
configuration and operating conditions documented in the Notification of Compliance Status report required by §
63.655(f).

Status: In compliance – Plant changes are subject to NSR. A new AO was issued in June 9, 2023, for
equipment changes and adjustments in emissions.

63.640(n)

Overlap of Subpart CC with other regulations for storage vessels.

Status: In compliance – HF Sinclair has submitted a spreadsheet that shows which regulation applies to
each of their tanks. They also submit semi-annual reports which outline where the source stands on all
applicable MACT, NESHAP, NSPS, and UACR standards. In addition, they submit numerous reports
under an EPA Consent Decree. These are reviewed by EPA Region VIII. These reviews are not shared with
DAQ.

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63.640(o)

Overlap of Subpart CC with other regulations for wastewater.

Status: In compliance – At this time, only the provisions of 40 CFR 60 Subpart QQQ (and the State
regulations) apply to HF Sinclair because there are no Group I wastewater streams. Benzene rates are
under 10 Mg per year.

63.640(q)

Overlap of Subpart CC with local or State regulations.

Status: Consolidation of monitoring, record keeping, and reporting requirements are allowed.

63.642 General standards.

Status: In compliance – An operating permit application has been submitted by HF Sinclair. A Title V
application and update has been submitted. Records are kept on-site for 5 years. Performance testing is
evaluated by the DAQ stack test auditor. All records are available either electronically or in hard copy. All
reports appeared to have been submitted for this evaluation period. Subpart (k)(2) states that annual
emission rate calculations are not required if the source is complying with (k) and (k)(1).

63.643 Miscellaneous process vent provisions (MPV).

Status: In compliance – This section applies to Group 1 miscellaneous process vents (MPV). HF Sinclair
reports Group I MPVs. The refinery complies by using flares and flare gas recovery (FGR). The flares
meet the applicable requirements as of January 30, 2019 (see FY 2020 inspection memo 2).

63.644 Monitoring provisions for miscellaneous process vents.

Status: In compliance – HF Sinclair complies with this provision by venting to a flare that meets the
requirements of 40 CFR 63.670. There is no on-site equipment subject to 63.644(a)(4).

63.645 Test methods and procedures for miscellaneous process vents.

Status: In compliance – As part of the operations checklist, Engineer Analysis are conducted on process
vents to determine if miscellaneous process vents are Group I or Group II. Repairs have not been required
but the company is aware of the compliance dates. Reports are submitted as required.

63.646 Storage vessel provisions.

Status: N/A – This is because of a Federal rule change. See 63.660 below.

63.647 Wastewater provisions.

Status: In compliance – This provision requires the owner or operator of a Group 1 wastewater stream to
comply with 40 CFR 61 Subpart FF (see below).

63.648 Equipment leaks standards.

Status: See LDAR memo (3 of 4).
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63.655 Reporting and recordkeeping requirements (wastewater, storage vessels, tanks, misc. process vents)

63.655(a)

Each owner or operator subject to the wastewater provisions in §63.647 shall comply with the recordkeeping and
reporting provisions in §§61.356 and 61.357 of 40 CFR part 61, subpart FF unless they are complying with the
wastewater provisions specified in paragraph (o)(2)(ii) of §63.640. There are no additional reporting and
recordkeeping requirements for wastewater under this subpart unless a wastewater stream is included in an
emissions average. Recordkeeping and reporting for emissions averages are specified in §63.653 and in
paragraphs (f)(5) and (g)(8) of this section.

Status: In compliance – For wastewater, there are no additional reporting or recordkeeping requirements
under Subpart CC, other than those required under 40 CFR 61 Subpart FF. The Total Annual Benzene
NESHAP (TAB) report required under Subpart FF was last submitted on October 14, 2022, for calendar
year 2021. The TAB was reported as 5.78 Mg. For calendar year 2021 the report is due October 2022.

63.655(b)

Each owner or operator subject to the gasoline loading rack provisions in §63.650 shall comply with the
recordkeeping and reporting provisions in §63.428 (b) and (c), (g)(1), (h)(1) through (h)(3), and (k) of subpart R.
These requirements are summarized in table 4 of this subpart. There are no additional reporting and recordkeeping
requirements for gasoline loading racks under this subpart unless a loading rack is included in an emissions
average. Recordkeeping and reporting for emissions averages are specified in §63.653 and in paragraphs (f)(5)
and (g)(8) of this section.

Status: In compliance – For gasoline loading racks, there are no additional reporting or recordkeeping
requirements under Subpart CC other than those required under 40 CFR 63 Subpart R. There is no
emissions averaging. See the memo for Holly Energy Partners (HEP) for compliance status.

63.655(d)

Each owner or operator subject to the equipment leaks standards in §63.648 shall comply with the recordkeeping
and reporting provisions in paragraphs (d)(1) through (d)(6) of this section.

Status: In compliance – Regarding LDAR, HF Sinclair complies with this provision by complying with
Subparts VV, VVa, GGG and GGGa. Records required by this Subpart are maintained and evaluated
during the LDAR inspection.

63.655(e)

Each owner or operator of a source subject to this subpart shall submit the reports listed in paragraphs (e)(1)
through (e)(3) of this section except as provided in paragraph (h)(5) of this section, and shall keep records as
described in paragraph (i) of this section.

Status: In compliance – The Semi-annual MACT Reports are submitted on time.

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63.655(f) Notification of Compliance Status Report

Status: In Compliance – Due to recent revisions to the refinery sector rule, HF Sinclair submitted a NOC to
fulfill the requirements of 63.655(f)(1)(i) for storage vessels on June 6, 2019, and 63.655(f)(ii) for
miscellaneous process vents on May 24, 2019. On October 21, 2020, HF Sinclair submitted a NOC for Tank
128 that was placed into gasoline service on September 28, 2020. This Tank 128 is reflected in the AO
issued October 8, 2020. On April 29, 2021, HF Sinclair submitted a NOC for 63.655(f)(1)(ii)-(iii)-
Miscellaneous Process Vents. On August 3, 2020, a NOC was submitted for Adding Tank 70 as a Group 1
Storage Vessel due to change in stored liquid. On January 31, 2022, HF Sinclair submitted an updated
NOC for Tank 70 stating Tank 70 was no longer a Group I tank based on change of stored material. On
January 11, 2022, HF Sinclair submitted a NOC to update compliance dates under 40 CFR 1063.

63.655(g)
The owner or operator of a source subject to this subpart shall submit Periodic Reports no later than 60 days after
the end of each 6-month period when any of the information specified in paragraphs (g)(1) through (7) of this
section or paragraphs (g)(9) through (14) of this section is collected. The first 6-month period shall begin on the
date the Notification of Compliance Status report is required to be submitted. A Periodic Report is not required if
none of the events identified in paragraphs (g)(1) through (7) of this section or paragraphs (g)(9) through (14) of
this section occurred during the 6-month period unless emissions averaging is utilized. Quarterly reports must be
submitted for emission points included in emission averages, as provided in paragraph (g)(8) of this section. An
owner or operator may submit reports required by other regulations in place of or as part of the Periodic Report
required by this paragraph (g) if the reports contain the information required by paragraphs (g)(1) through (14) of
this section.

Status: In compliance – Previous annual reports and semi-annual MACT reports have been submitted. 40
CFR 63.655(g) requires periodic reports to be submitted each 6-month period (see table below). 40 CFR
63.660 became effective on February 1, 2018, causing 63.655(g)(3) to become the applicable provision. The
periodic reports included the inspection results required by 40 CFR 63.1065(b) of Subpart WW for floating
roof inspections (as required by 63.660). 63.655(g)(4) is reserved. No exceptions noted in periodic reports
under 63.655(g)(5). Periodic reports also included the requirements of 63.655(g)(6) – (13).

63.655(h)

Other reports shall be submitted as specified in subpart A of this part and as follows:

Status: In compliance – Federal and State storage vessel notifications have been submitted for the past
year. These notices are submitted when tanks are emptied, degassed, and refilled. No requests for
alternatives have been submitted in the past year.

63.655(i) Recordkeeping

Each owner or operator of a source subject to this subpart shall keep copies of all applicable reports and records
required by this subpart for at least 5 years except as otherwise specified in paragraphs (i)(1) through (12) of this
section. All applicable records shall be maintained in such a manner that they can be readily accessed within 24
hours. Records may be maintained in hard copy or computer-readable form including, but not limited to, on paper,
microfilm, computer, flash drive, floppy disk, magnetic tape, or microfiche.

Status: In compliance – Records are maintained for at least 5 years.

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63.660 Storage vessel provisions.

On and after the applicable compliance date for a Group 1 storage vessel located at a new or existing source as
specified in § 63.640(h), the owner or operator of a Group 1 storage vessel that is part of a new or existing source
shall comply with the requirements in subpart WW or SS of this part according to the requirements in paragraphs
(a) through (i) of this section.

Status: In compliance – HF Sinclair complies with Subpart CC by meeting the requirements of Subpart
WW, as applicable. Tank 70 is no longer subject to Subpart SS due to change in stored material. The
refinery does use flexible enclosure devices and/or gasketed or welded caps on the tops of guide poles.

NESHAP (Part 61), FF: National Emission Standards for Benzene Waste Operations

61.340 Applicability.

Status: In compliance – HF Sinclair submits TAB and quarterly reports for each calendar year. The last
TAB report was submitted in October 2023, for calendar year 2022, and shows that the total annual
benzene emissions were 5.78 Mg/yr. This is below the threshold of 10 Mg/yr. Because this is below the
threshold, no other requirements of 40 CFR 61 Subpart FF - Benzene NESHAP General Standards apply
at this time. It was noted that an updated BWON sampling plan for the TAB calculation was submitted, as
required by the Consent Decree, on May 25, 2023. HF Sinclair is using the requirements of the Consent
Decree for annual sampling and review of waste water quantities to determine TAB.

NSPS (Part 60), QQQ: Standards of performance for VOC Emissions from Petroleum Refinery
Wastewater Systems

60.692-2 Standards: Individual drain systems.

Status: In compliance – Individual drain systems constructed after the applicability date must comply with
this Subpart. All of the drains have the required liquid seals. Monthly Drain Inspection Sheets showed that
individual drain inspections were made, which included detailed monthly inspections of each drain’s water
level. HF Sinclair currently does not have any drains “out of active service.” Junction boxes have manhole
covers installed that are sealed. Only one junction box has a vent pipe installed. The Semi-Annual Junction
Box Inspection Sheet indicated that junction boxes are inspected semi-annually. Sewer lines are buried.
There are no unburied sewer lines, so inspections are not required. Reports show that if a drain is not full,
it will be listed as dry. The dry drains are filled by the staff. According to the last Subpart QQQ
Semi-Annual report, dated March 13, 2023, the junction boxes were inspected in March 2023.

60.692-3 Standards: Oil-water separators.

Status: In compliance – A new WWTP was installed and became operational on April 1, 2016 (see letter in
file dated June 13, 2016, and October 10, 2016). The upgraded WWTP meets the requirements of this
condition by having a fixed roof that completely covers the tanks. It has a design capacity of 880 gpm. The
access doors are gasketed and remain in a closed position. The installed closed vent system vents to carbon
canisters meeting option 60.695(a)(3)(ii). Semi-annual WWTP (Method 21) inspections are conducted. The
last inspection was conducted on March 2023, and will be conducted in September 2023. Oil from the slop
oil tank is processed and returned to production.

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60.695 Monitoring of operations.

Status: In compliance – HF Sinclair is currently using option 40 CFR 695(a)(3)(ii) using a carbon
adsorption system that does not regenerate the carbon bed directly onsite (ie carbon canister). The canister
is monitored weekly (Method 21) by Think Environmental, under the LDAR program.

60.696 Performance test methods and procedures and compliance provision.

Status: In compliance – Method 21 is used for monitoring, under the LDAR program.

60.697 Recordkeeping requirements.

Status: In compliance – Records of inspections for the individual drain systems, junction boxes and the
carbon canister are maintained for at least three years.

60.698 Reporting requirements.

(a) An owner or operator electing to comply with the provisions of § 60.693 shall notify the Administrator of the
alternative standard selected in the report required in § 60.7.

Status: N/A – No alternative standards have been requested.

(b)(1) Each owner or operator of a facility subject to this subpart shall submit to the Administrator within 60 days
after initial startup a certification that the equipment necessary to comply with these standards has been installed
and that the required initial inspections or tests of process drains, sewer lines, junction boxes, oil-water separators,
and closed vent systems and control devices have been carried out in accordance with these standards. Thereafter,
the owner or operator shall submit to the Administrator semiannually a certification that all of the required
inspections have been carried out in accordance with these standards.

Status: In compliance – On June 13, 2016, and October 19, 2016, HF Sinclair submitted a letter for the
upgraded WWTP. The upgraded WWTP became operational on April 1, 2016. The refinery submitted a
certification for the individual drain system in the new lab building.

(c) A report that summarizes all inspections when a water seal was dry or otherwise breached, when a drain cap or
plug was missing or improperly installed, or when cracks, gaps, or other problems were identified that could
result in VOC emissions, including information about the repairs or corrective action taken, shall be submitted
initially and semiannually thereafter to the Administrator.

Status: In compliance – Semiannual reports are submitted covering affected facilities under subpart QQQ.
Corrective actions were included in the semiannual reports. The latest semi-annual QQQ report, dated
March 13, 2023, has been submitted.

(d) As applicable, a report shall be submitted semiannually to the Administrator that indicates:

(d)(3)(ii) Each occurrence when the carbon in a carbon adsorber system that is not regenerated directly onsite in
the control device is not replaced at the predetermined interval specified in § 60.695(a)(3)(ii).

Status: In compliance – No occurrences of breakthrough have been reported in the past year.

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UAC R307-326-5 Wastewater (oil-water) Systems

Any wastewater separator handling VOCs shall be equipped with:
(1) covers and seals approved by the Director on all separators and forebays,
(2) lids or seals on all openings in covers, separators, and forebays. Such lids or seals shall be in the closed
position at all times except when in actual use.

Status: In compliance – The WWTP covers and seals are installed and are inspected (Method 21)
semi-annually.

UAC 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 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 – HF Sinclair tanks are fitted with internal or external floating roofs. All of the above
tank information (#1 and #2) is tracked monthly.

UAC 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.
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(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.
(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 – External or internal roofs are installed on tanks subject to this rule. Holly’s records
show that routine inspections from the top of the tank for external floating roofs and through the roof
hatches for internal floating roofs are performed at six-month intervals. During each inspection, a checklist
is filled out for each tank which includes: the condition of the seals sun shield, and secondary wiper blade
for cracks and tears or missing sections, wiper blade gaps, the size of the gaps, the condition of the water
drain butterfly diaphragms, the condition of the gauge well and gauge well bucket, and to check for any
abnormalities in the roof components. Primary seals are also thoroughly inspected whenever the tank is
degassed or brought down for repairs. All openings, except for vents and drains, are covered, except when
in use. Notification of tank degassing and refilling is sent to the DAQ, when required.

UAC 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
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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 retrofits have been completed and verified during previous inspections.

UAC 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 testings 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 – To date, no alternate methods have been requested.

UAC 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: N/A – This was previously completed

PM 2.5 SIP H.11. General Requirements: Control Measures for Area and Point
Sources, Emission Limits and Operating Practices, PM2.5

g. Petroleum Refineries

vi. Requirements on Tank Degassing
A. Beginning January 1, 2017, the owner or operator of 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)) shall not allow it 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).

B. These degassing provisions shall not apply while connecting or disconnecting
degassing equipment.
15
C. 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:

I. Start date and time;
II. Tank owner, address, tank location, and applicable tank permit numbers;
III. Degassing operator’s name, contact person, telephone number;
IV. Tank capacity, volume of space to be degassed, and materials stored;
V. Description of vapor control device.

Status: In compliance – Notifications of degassing are submitted in accordance with this rule. Notifications are
in the source’s file.

MACT (Part 63), SS: National Emission Standards for Closed Vent Systems, Control Devices, Recovery
Devices and Routing to a Fuel Gas System or a Process

Status: N/A – 40 CFR Subparts CC, SS, and WW points to this regulation. On August 3, 2021, HF Sinclair
submitted a NOC for Tank 70. The NOC included a vapor control design evaluation for the combustion
device controlling the tank. On January 31, 2022, the refinery submitted an updated NOC for Tank 70.
Tank 70 now stores gas oil.

MACT (Part 63), WW: National Emission Standards for Storage Vessels (Tanks) - Control Level 2

63.1063 Floating roof requirements.

The owner or operator who elects to use a floating roof to comply with the requirements of § 63.1062 shall
comply with the requirements in paragraphs (a) through (e) of this section.

(a) Design requirements –

(2) Deck fittings. Openings through the deck of the floating roof shall be equipped as described in paragraphs
(a)(2)(i) through (a)(2)(viii) of this section.

Status: In compliance – NOCs are submitted on an as needed basis. The latest NOC, dated January 27,
2022, has been submitted. It concerned removing tank 70 from wax crude service to gas oil service.

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EMISSIONS INVENTORY: The HF Sinclair Woods Cross Refinery submitted their 2022 annual emission
inventory on March 29, 2023.

PREVIOUS ENFORCEMENT
ACTIONS: January 23, 2018 – ESA
March 13, 2019 – ESA
June 4, 2019 – ESA
June 16, 2020 – ESA
February 11, 2021 – Warning

COMPLIANCE STATUS &
RECOMMENDATIONS: In compliance with the Federal and State regulations evaluated at time of
inspection.

HPV STATUS: Yes, for exceedance of the NSPS Boiler and Heater limit. AGO and Holly
currently have a tolling agreement until September 14, 2020.

COMPLIANCE
ASSISTANCE: None

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual.

ATTACHMENT: VEO Form