DAQ-2024-005185

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DAQC-198-24
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 30, 2023

SUBJECT: Partial Compliance Evaluation (PCE #3 of #4) – LDAR, Major, Davis County,
FRS# UT0000004901100013

INSPECTION DATE: 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 Holly 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. Flares are used to
control emergency and other captured emissions from process units. Gasoline and diesel fuel from the
refinery are dispensed from a loading rack.

APPLICABLE REGULATIONS:

STATE REGULATIONS:

Approval Order (AO) DAQE-AN101230055-23, dated June 9, 2023

AO DAQE-AN101230052-20

AO DAQE-AN101230053-22

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

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

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), Dc: Standards of Performance for Small Industrial-
Commercial -Institutional Steam Generating Units
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
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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
40 CFR 60 Subpart Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels
(Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification
Commenced After July 23, 1984

NSPS (Part 60), QQQ: Standards of Performance for VOC Emissions From Petroleum refinery
Wastewater Systems

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 Waste Operations

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), GGGGG: National Emission Standards for Hazardous Air
Pollutants: Site Remediation
MACT (Part 63), R: National Emission Standards for Gasoline Distribution
Facilities (Bulk Gasoline Terminals and Pipeline Breakout Stations)
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), ZZZZ: National Emissions Standards for Hazardous Air
Pollutants for Stationary Reciprocating Internal Combustion Engines

SOURCE EVALUATION:

MACT (Part 63), A: General Provisions

Status: In compliance – Holly complies with the General Provisions as it is applicable to Subpart
CC. Notifications and reports are submitted on time. An SSM plan has been developed and
semi-annual MACT reports are sent as required. Maintenance requirements appeared to be met.
Records are kept on Holly’s electronic file system

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

63.640 Applicability

Status: In compliance – Holly 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 flares.

63.640(l)(4) If pumps, compressors, pressure relief devices, sampling connection systems, open-ended
valves or lines, valves, or instrumentation systems are added to an existing source, they are subject to the
equipment leak standards for existing sources in §63.648. A notification of compliance status report shall
not be required for such added equipment.

Status: In compliance – Holly is aware of this condition, regarding adding equipment subject to
equipment leak standards. See 63.648 Equipment Leak Standards

63.640 (p)(1) Overlap of Subpart CC with other regulations for equipment leaks. After the compliance
dates specified in paragraph (h) of this section equipment leaks that are also subject to the provisions of
40 CFR parts 60 and 61 are required to comply only with the provisions specified in this Subpart.

63.640(p)(2) Equipment leaks that are also subject to the provisions of 40 CFR part 60, subpart GGGa,
are required to comply only with the provisions specified in 40 CFR part 60, subpart GGGa.
63.640(q) For overlap of Subpart CC with local or State regulations, the permitting authority for the
affected source may allow consolidation of the monitoring, recordkeeping, and reporting requirements
under this Subpart with the monitoring, recordkeeping, and reporting requirements under other applicable
requirements in 40 CFR parts 60, 61, or 63, and in any 40 CFR part 52 approved State implementation
plan provided the implementation plan allows for approval of alternative monitoring, reporting, or
recordkeeping requirements and provided that the permit contains an equivalent degree of compliance and
control.

Status: In compliance – The overlap provisions state the sources need only comply with Subpart
CC and for equipment leaks subject to Subpart GGGa, comply only with Subpart GGGa. Subpart
GGGa applies to construction after November 7, 2006. Table 11 specifies compliance dates. The
latest compliance date is construction after June 30, 2014. Subparts CC, GGGa, and SIP are
included in the quarterly LDAR reports. Currently, there is no monitoring, recordkeeping, and
reporting (MRR) requirements under Title V. The source does consolidate its MRR with State
regulations and federal rules.

63.648 Equipment Leak Standards

(a) Each owner or operator of an existing source subject to the provisions of this subpart shall comply
with the provisions of 40 CFR part 60, subpart VV, and paragraph (b) of this section except as provided
in paragraphs (a)(1) and (2), (c) through (i), and (j)(1) and (2) of this section. Each owner or operator of a
new source subject to the provisions of this subpart shall comply with subpart H of this part except as
provided in paragraphs (c) through (i) and (j)(1) and (2) of this section.

(1) For purposes of compliance with this section, the provisions of 40 CFR part 60, subpart VV apply
only to equipment in organic HAP service, as defined in §63.641 of this subpart.

(2) Calculation of percentage leaking equipment components for subpart VV of 40 CFR part 60 may be
done on a process unit basis or a sourcewide basis. Once the owner or operator has decided, all
subsequent calculations shall be on the same basis unless a permit change is made.
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(3) If a flare is used as a control device, on and after January 30, 2019, the flare shall meet the
requirements of §63.670. Prior to January 30, 2019, the flare shall meet the applicable requirements of
part 60, subpart VV of this chapter, or the requirements of §63.670.

Status: In compliance – For equipment in organic HAP service, Holly complies with Subpart VV.
Paragraph (b) is not applicable, Holly never uses less frequent monitoring. Holly calculates percent
leaking equipment on a process unit basis. The North and South flares must comply with 63.670
Flare Controls (see below). Also, the 2008 PM 10 SIP and Consent Decree requires Holly to comply
with the more stringent Subpart VVa for all its components subject to the leak detection and repair
program.

(b) The use of monitoring data generated before August 18, 1995 to qualify for less frequent monitoring
of valves and pumps as provided under 40 CFR part 60 subpart VV or subpart H of this part and
paragraph (c) of this section (i.e., quarterly or semiannually) is governed by the requirements of
paragraphs (b)(1) and (b)(2) of this section.

(1) Monitoring data must meet the test methods and procedures specified in §60.485(b) of 40 CFR part
60, subpart VV or §63.180(b)(1) through (b)(5) of subpart H of this part except for minor departures.

(2) Departures from the criteria specified in §60.485(b) of 40 CFR part 60 subpart VV or §63.180(b)(1)
through (b)(5) of subpart H of this part or from the monitoring frequency specified in subpart VV or in
paragraph (c) of this section (such as every 6 weeks instead of monthly or quarterly) are mi nor and do not
significantly affect the quality of the data. An example of a minor departure is monitoring at a slightly
different frequency (such as every 6 weeks instead of monthly or quarterly). Failure to use a calibrated
instrument is not considered a minor departure.

Status: N/A – This is a skip monitoring provision. Holly is not skip monitoring. The PM10 SIP also
makes the whole facility subject to Subparts GGGa and VVa.

(c) In lieu of complying with the existing source provisions of paragraph (a) in this section, an owner or
operator may elect to comply with the requirements of §§63.161 through 63.169, 63.171, 63.172, 63.175,
63.176, 63.177, 63.179, and 63.180 of subpart H except as provided in paragraphs (c)(1) through (12) and
(e) through (i) of this section.

(1) The instrument readings that define a leak for light liquid pumps subject to §63.163 of subpart H of
this part and gas/vapor and light liquid valves subject to §63.168 of subpart H of this part are specified in
table 2 of this subpart.

(2) In phase III of the valve standard, the owner or operator may monitor valves for leaks as specified in
paragraphs (c)(2)(i) or (c)(2)(ii) of this section.

(i) If the owner or operator does not elect to monitor connectors, then the owner or operator shall monitor
valves according to the frequency specified in table 8 of this subpart.

(ii) If an owner or operator elects to monitor connectors according to the provisions of §63.649,
paragraphs (b), (c), or (d), then the owner or operator shall monitor valves at the frequencies specified in
table 9 of this subpart.

(3) The owner or operator shall decide no later than the first required monitoring period after the phase I
compliance date specified in §63.640(h) whether to calculate the percentage leaking valves on a process
unit basis or on a sourcewide basis. Once the owner or operator has decided, all subsequent calculations
shall be on the same basis unless a permit change is made.
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(4) The owner or operator shall decide no later than the first monitoring period after the phase III
compliance date specified in §63.640(h) whether to monitor connectors according to the provisions in
§63.649, paragraphs (b), (c), or (d).

(5) Connectors in gas/vapor service or light liquid service are subject to the requirements for connectors
in heavy liquid service in §63.169 of subpart H of this part (except for the agitator provisions). The leak
definition for valves, connectors, and instrumentation systems subject to §63.169 is 1,000 parts per
million.

(6) In phase III of the pump standard, except as provided in paragraph (c)(7) of this section, owners or
operators that achieve less than 10 percent of light liquid pumps leaking or three light liquid pumps
leaking, whichever is greater, shall monitor light liquid pumps monthly.

(7) Owners or operators that achieve less than 3 percent of light liquid pumps leaking or one light liquid
pump leaking, whichever is greater, shall monitor light liquid pumps quarterly.

(8) An owner or operator may make the election described in paragraphs (c)(3) and (c)(4) of this section
at any time except that any election to change after the initial election shall be treated as a permit
modification according to the terms of part 70 of this chapter.

(9) When complying with the requirements of §63.168(e)(3)(i), non-repairable valves shall be included in
the calculation of percent leaking valves the first time the valve is identified as leaking and non-
repairable. Otherwise, a number of non-repairable valves up to a maximum of 1 percent per year of the
total number of valves in organic HAP service up to a maximum of 3 percent may be excluded from
calculation of percent leaking valves for subsequent monitoring periods. When the number of non-
repairable valves exceeds 3 percent of the total number of valves in organic HAP service, the number of
non-repairable valves exceeding 3 percent of the total number shall be included in the calculation of
percent leaking valves.

(10) If in phase III of the valve standard any valve is designated as being leakless, the owner or operator
has the option of following the provisions of 40 CFR 60.482-7(f). If an owner or operator chooses to
comply with the provisions of 40 CFR 60.482-7(f), the valve is exempt from the valve monitoring
provisions of §63.168 of subpart H of this part.

(11) [Reserved]

(12) If a flare is used as a control device, on and after January 30, 2019, the flare shall meet the
requirements of §63.670. Prior to January 30, 2019, the flare shall meet the applicable requirements of
§§63.172 and 63.180, or the requirements of §63.670.

Status: N/A – The facility chose to be incompliance with Subparts VVa and GGGa, not Subpart H.

(d) Upon startup of new sources, the owner or operator shall comply with §63.163(a)(1)(ii) of subpart H
of this part for light liquid pumps and §63.168(a)(1)(ii) of subpart H of this part for gas/vapor and light
liquid valves.

Status: N/A – The facility installs low leak technology on all new valves according to AP 622. Holly
also complies with the more stringent Subpart VVa standard for new sources per the Consent
Decree and PM10 SIP. The facility chooses not to be incompliance Subpart H.

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(e) through (g) are exemption descriptions.

Status: In compliance – Holly complies with any applicable exemption in Subparts GGGA and
VVa, which are also listed here in sec. 63.648.

(h) Each owner or operator of a source subject to the provisions of this subpart must maintain all records
for a minimum of 5 years.

Status: In compliance – Holly maintains equipment leak records for 5 years.

(i)Reciprocating compressors are exempt from seal requirements if recasting the distance piece or
compressor replacement is required.

Status: In compliance – See sec. 63.648 (g) below for compressor in hydrogen service exemption
verification. The refinery has one exempt compressor.

(j) Except as specified in paragraph (j)(4) of this section, the owner or operator must comply with the
requirements specified in paragraphs (j)(1) and (2) of this section for pressure relief devices, such as relief
valves or rupture disks, in organic HAP gas or vapor service instead of the pressure relief device
requirements of §60.482-4 or §63.165, as applicable. Except as specified in paragraphs (j)(4) and (5) of
this section, the owner or operator must also comply with the requirements specified in paragraph (j)(3) of
this section for all pressure relief devices.

(1) Operating requirements. Except during a pressure release, operate each pressure relief device in
organic HAP gas or vapor service with an instrument reading of less than 500 ppm above background as
detected by Method 21 of 40 CFR part 60, appendix A-7.

(2) Pressure release requirements. For pressure relief devices in organic HAP gas or vapor service, the
owner or operator must comply with the applicable requirements in paragraphs (j)(2)(i) through (iii) of
this section following a pressure release.

(i) If the pressure relief device does not consist of or include a rupture disk, conduct instrument
monitoring, as specified in §60.485(b) or §63.180(c), as applicable, no later than 5 calendar days after the
pressure relief device returns to organic HAP gas or vapor service following a pressure release to verify
that the pressure relief device is operating with an instrument reading of less than 500 ppm.

(ii) If the pressure relief device includes a rupture disk, either comply with the requirements in paragraph
(j)(2)(i) of this section (not replacing the rupture disk) or install a replacement disk as soon as practicable
after a pressure release, but no later than 5 calendar days after the pressure release. The owner or operator
must conduct instrument monitoring, as specified in §60.485(b) or §63.180(c), as applicable, no later than
5 calendar days after the pressure relief device returns to organic HAP gas or vapor service following a
pressure release to verify that the pressure relief device is operating with an instrument reading of less
than 500 ppm.

(iii) If the pressure relief device consists only of a rupture disk, install a replacement disk as soon as
practicable after a pressure release, but no later than 5 calendar days after the pressure release. The owner
or operator may not initiate startup of the equipment served by the rupture disk until the rupture disc is
replaced. The owner or operator must conduct instrument monitoring, as specified in §60.485(b) or
§63.180(c), as applicable, no later than 5 calendar days after the pressure relief device returns to organic
HAP gas or vapor service following a pressure release to verify that the pressure relief device is operating
with an instrument reading of less than 500 ppm.

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(3) Pressure release management. Except as specified in paragraphs (j)(4) and (5) of this section, the
owner or operator shall comply with the requirements specified in paragraphs (j)(3)(i) through (v) of this
section for all pressure relief devices in organic HAP service no later than January 30, 2019.

(i) The owner or operator must equip each affected pressure relief device with a device(s) or use a
monitoring system that is capable of:

(A) Identifying the pressure release;

(B) Recording the time and duration of each pressure release; and

(C) Notifying operators immediately that a pressure release is occurring. The device or monitoring system
may be either specific to the pressure relief device itself or may be associated with the process system or
piping, sufficient to indicate a pressure release to the atmosphere. Examples of these types of devices and
systems include, but are not limited to, a rupture disk indicator, magnetic sensor, motion detector on the
pressure relief valve stem, flow monitor, or pressure monitor.

(ii) The owner or operator must apply at least three redundant prevention measures to each affected
pressure relief device and document these measures. Examples of prevention measures include:

(A) Flow, temperature, level and pressure indicators with deadman switches, monitors, or automatic
actuators.

(B) Documented routine inspection and maintenance programs and/or operator training (maintenance
programs and operator training may count as only one redundant prevention measure).

(C) Inherently safer designs or safety instrumentation systems.

(D) Deluge systems.

(E) Staged relief system where initial pressure relief valve (with lower set release pressure) discharges to
a flare or other closed vent system and control device.

(iii) If any affected pressure relief device releases to atmosphere as a result of a pressure release event, the
owner or operator must perform root cause analysis and corrective action analysis according to the
requirement in paragraph (j)(6) of this section and implement corrective actions according to the
requirements in paragraph (j)(7) of this section. The owner or operator must also calculate the quantity of
organic HAP released during each pressure release event and report this quantity as required in
§63.655(g)(10)(iii). Calculations may be based on data from the pressure relief device monitoring alone
or in combination with process parameter monitoring data and process knowledge.

Status: In compliance – The notice of compliance (NOC) status report was submitted on May 24,
2019.

(iv) The owner or operator shall determine the total number of release events occurred during the calendar
year for each affected pressure relief device separately. The owner or operator shall also determine the
total number of release events for each pressure relief device for which the root cause analysis concluded
that the root cause was a force majeureevent, as defined in this subpart.

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(v) Except for pressure relief devices described in paragraphs (j)(4) and (5) of this section, the following
release events are a violation of the pressure release management work practice standards.

Status: In compliance – This is in the Semi-Annual MACT report.

(A) Any release event for which the root cause of the event was determined to be operator error or poor
maintenance.

(B) A second release event not including force majeure events from a single pressure relief device in a 3-
calendar year period for the same root cause for the same equipment.

(C) A third release event not including force majeure events from a single pressure relief device in a 3-
calendar year period for any reason.

Status: In compliance – No root cause analysis (RCA) is required.

(4) Pressure relief devices routed to a control device. If all releases and potential leaks from a pressure
relief device are routed through a closed vent system to a control device, back into the process or to the
fuel gas system, the owner or operator is not required to comply with paragraph (j)(1), (2), or (3) (if
applicable) of this section. Both the closed vent system and control device (if applicable) must meet the
requirements of §63.644. When complying with this paragraph (j)(4), all references to “Group 1
miscellaneous process vent” in §63.644 mean “pressure relief device.” If a pressure relief device
complying with this paragraph (j)(4) is routed to the fuel gas system, then on and after January 30, 2019,
any flares receiving gas from that fuel gas system must be in compliance with §63.670.

Status: In compliance – Monitoring provisions for flare controls and controlling process vents.

(5) Pressure relief devices exempted from pressure release management requirements. The following
types of pressure relief devices are not subject to the pressure release management requirements in
paragraph (j)(3) of this section.

(i) Pressure relief devices in heavy liquid service, as defined in §63.641.

(ii) Pressure relief devices that only release material that is liquid at standard conditions (1 atmosphere
and 68 degrees Fahrenheit) and that are hard-piped to a controlled drain system (i.e., a drain system
meeting the requirements for Group 1 wastewater streams in §63.647(a)) or piped back to the process or
pipeline.

(iii) Thermal expansion relief valves.

(iv) Pressure relief devices designed with a set relief pressure of less than 2.5 psig.

(v) Pressure relief devices that do not have the potential to emit 72 lbs/day or more of VOC based on the
valve diameter, the set release pressure, and the equipment contents.

(vi) Pressure relief devices on mobile equipment.

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(6) Root cause analysis and corrective action analysis. A root cause analysis and corrective action analysis
must be completed as soon as possible, but no later than 45 days after a release event. Special
circumstances affecting the number of root cause analyses and/or corrective action analyses are provided
in paragraphs (j)(6)(i) through (iv) of this section.

Status: In compliance – This is in the Semi-Annual MACT report appendix.

(i) You may conduct a single root cause analysis and corrective action analysis for a single emergency
event that causes two or more pressure relief devices installed on the same equipment to release.

(ii) You may conduct a single root cause analysis and corrective action analysis for a single emergency
event that causes two or more pressure relief devices to release, regardless of the equipment served, if the
root cause is reasonably expected to be a force majeure event, as defined in this subpart.

(iii) Except as provided in paragraphs (j)(6)(i) and (ii) of this section, if more than one pressure relief
device has a release during the same time period, an initial root cause analysis shall be conducted
separately for each pressure relief device that had a release. If the initial root cause analysis indicates that
the release events have the same root cause(s), the initially separate root cause analyses may be recorded
as a single root cause analysis and a single corrective action analysis may be conducted.

(7) Corrective action implementation. Each owner or operator required to conduct a root cause analysis
and corrective action analysis as specified in paragraphs (j)(3)(iii) and (j)(6) of this section shall
implement the corrective action(s) identified in the corrective action analysis in accordance with the
applicable requirements in paragraphs (j)(7)(i) through (iii) of this section.

(i) All corrective action(s) must be implemented within 45 days of the event for which the root cause and
corrective action analyses were required or as soon thereafter as practicable. If an owner or operator
concludes that no corrective action should be implemented, the owner or operator shall record and explain
the basis for that conclusion no later than 45 days following the event.

(ii) For corrective actions that cannot be fully implemented within 45 days following the event for which
the root cause and corrective action analyses were required, the owner or operator shall develop an
implementation schedule to complete the corrective action(s) as soon as practicable.

(iii) No later than 45 days following the event for which a root cause and corrective action analyses were
required, the owner or operator shall record the corrective action(s) completed to date, and, for action(s)
not already completed, a schedule for implementation, including proposed commencement and
completion dates.

Status: In compliance – Holly operates each pressure relief device in organic HAP gas or vapor
service with an instrument reading of less than 500 ppm above background as detected by Method
21 of 40 CFR part 60, appendix A-7. Instrument monitoring occurs within 5 days after release
except for rupture disc. Replacement and monitoring of ruptured discs occurs on the schedule
listed above. No pressure releases have been reported in the past year.

63.649 Alternative means of emission limitation: Connectors in gas/vapor service and light liquid service.

Status: N/A

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63.655 Reporting and Recordkeeping

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 – Holly keeps leak detection and repair (LDAR) records and submits reports
in accordance with 40 CFR 60 Subpart VV (see below). Holly maintains lists required by this
paragraph. Think Environmental maintains a database with all monitoring results. Holly submits
additional reports per an EPA Consent Decree.

63.655(g)(10) For pressure relief devices subject to the requirements § 63.648(j), Periodic Reports must
include the information specified in paragraphs (g)(10)(i) through (iii) of this section.

Status: In compliance – Periodic reports include the items listed under this paragraph. Periodic
reports for Subpart CC have been submitted in the past year, as required. Sec. 63.655(g)(10) is
effective January 30, 2019. This is included in the Semi–Annual MACT report.

63.655(i)(9) For each flare subject to § 63.670, each owner or operator shall keep the records specified in
paragraphs (i)(9)(i) through (xii) of this section up-to-date and readily accessible, as applicable.

Status: In compliance – This regulation for flares became effective January 30, 2019. Records are
maintained as of that date. Holly submitted a self-disclosure letter that flare videos were
maintained now for 5 years (see letter DAQC-957-21).

63.655(i)(11) For each pressure relief device subject to the pressure release management work practice
standards in § 63.648(j)(3), the owner or operator shall keep the records specified in paragraphs (i)(11)(i)
through (iii) of this section.

Status: In compliance – 63.655(i)(11) is effective January 30, 2019, and is reviewed with the first
periodic report after the effective date. When flare became subject to Subpart CC.

63.670 Requirements for flare control devices.

On or before January 30, 2019, the owner or operator of a flare used as a control device for an emission
point subject to this subpart shall meet the applicable requirements for flares as specified in paragraphs (a)
through (q) of this section and the applicable requirements in § 63.671. The owner or operator may elect
to comply with the requirements of paragraph (r) of this section in lieu of the requirements in paragraphs
(d) through (f) of this section, as applicable.

Status: This is a statement of fact. Holly has not requested to comply with the alternative standards
of paragraph (r).

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63.670(a) [Reserved]

63.670(b) Pilot flame presence.

The owner or operator shall operate each flare with a pilot flame present at all times when regulated
material is routed to the flare. Each 15-minute block during which there is at least one minute where no
pilot flame is present when regulated material is routed to the flare is a deviation of the standard.
Deviations in different 15-minute blocks from the same event are considered separate deviations. The
owner or operator shall monitor for the presence of a pilot flame as specified in paragraph (g) of this
section.

Status: In compliance – A pilot flame is installed and monitoring occurs. The pilot monitor is
connected to the Data Control System (DCS) for the refinery. Pilot flame presence is recorded every
15 minutes.

63.670(c) Visible emissions.

The owner or operator shall specify the smokeless design capacity of each flare and operate with no
visible emissions, except for periods not to exceed a total of 5 minutes during any 2 consecutive hours,
when regulated material is routed to the flare and the flare vent gas flow rate is less than the smokeless
design capacity of the flare. The owner or operator shall monitor for visible emissions from the flare as
specified in paragraph (h) of this section.

Status: In compliance – The flare operates with no visible emissions, except during upset
conditions. The flares are monitored via video surveillance using method 22.

63.670(d) Flare tip velocity.

For each flare, the owner or operator shall comply with either paragraph (d)(1) or (2) of this section,
provided the appropriate monitoring systems are in-place, whenever regulated material is routed to the
flare for at least 15-minutes and the flare vent gas flow rate is less than the smokeless design capacity of
the flare.

Status: In compliance – Records show flare tip (Vtip) velocity is calculated every 15 minutes on
both flares.

63.670(e) Combustion zone operating limits.

For each flare, the owner or operator shall operate the flare to maintain the net heating value of flare
combustion zone gas (NHVcz) at or above 270 British thermal units per standard cubic feet (Btu/scf)
determined on a 15-minute block period basis when regulated material is routed to the
flare for at least 15-minutes. The owner or operator shall monitor and calculate NHVcz as specified in
paragraph (m) of this section.

Status: In compliance – Combustion zone operating limits are monitored and readings are
maintained for both the North and South flares. The operating limits include combustion of flare
gas, BTUs, and the flow of steam.

63.670(f) Dilution operating limits for flares with perimeter assist air.

Status: N/A

13
63.670(g) Pilot flame monitoring.

The owner or operator shall continuously monitor the presence of the pilot flame(s) using a device
(including, but not limited to, a thermocouple, ultraviolet beam sensor, or infrared sensor) capable of
detecting that the pilot flame(s) is present.

Status: In compliance – The North and South flares are equipped with a Williamson Pilot Monitor
to detect the presence of a pilot flame. A camera system is used to monitor the flares.

63.670(h) Visible emissions monitoring.

The owner or operator shall monitor visible emissions while regulated materials are vented to the flare.
An initial visible emissions demonstration must be conducted using an observation period of 2 hours
using Method 22 at 40 CFR part 60, appendix A-7. Subsequent visible emissions observations must be
conducted using either the methods in paragraph (h)(1) of this section or, alternatively, the methods in
paragraph (h)(2) of this section. The owner or operator must record and report any instances where visible
emissions are observed for more than 5 minutes during any 2 consecutive hours as specified in §
63.655(g)(11)(ii).

Status: In compliance – Visible emissions from the flares are monitored 24/7 Holly complies with
paragraph (h)(2) with video surveillance. Per EPA comments on page 86 of the NESHAP from
Petroleum Refineries Background Information for Final Amendments, the “initial visible emissions
demonstration” is only for newly-affected flares.” Thus, Holly’s existing flares are not required to
have an initial visible emissions test.

63.670(i) Flare vent gas, steam assist and air assist flow rate monitoring.

The owner or operator shall install, operate, calibrate, and maintain a monitoring system capable of
continuously measuring, calculating, and recording the volumetric flow rate in the flare header or headers
that feed the flare as well as any supplemental natural gas used. Different flow monitoring methods may
be used to measure different gaseous streams that make up the flare vent gas provided that the flow rates
of all gas streams that contribute to the flare vent gas are determined. If assist air or assist steam is used,
the owner or operator shall install, operate, calibrate, and maintain a monitoring system capable of
continuously measuring, calculating, and recording the volumetric flow rate of assist air and/or assist
steam used with the flare. If pre-mix assist air and perimeter assist are both used, the owner or operator
shall install, operate, calibrate, and maintain a monitoring system capable of separately measuring,
calculating, and recording the volumetric flow rate of premix assist air and perimeter assist air used with
the flare. Continuously monitoring fan speed or power and using fan curves is an acceptable method for
continuously monitoring assist air flow rates.

Status: In compliance – The North and South flares are equipped with a Flare Gas Ultrasonic Flow
Meters to monitor the flow rate of the total vent gas to the flare. They are also equipped with
temperature and pressure sensors, which correct the flow measurements to standard conditions.

63.670(j) Flare vent gas composition monitoring.

The owner or operator shall determine the concentration of individual components in the flare vent gas
using either the methods provided in paragraph (j)(1) or (2) of this section, to assess compliance with the
operating limits in paragraph (e) of this section and, if applicable, paragraphs (d) and (f) of this section.
Alternatively, the owner or operator may elect to directly monitor the net heating value of the flare vent
gas following the methods provided in paragraphs (j)(3) of this section and, if desired, may directly
measure the hydrogen concentration in the flare vent gas following the methods provided in paragraphs
14
(j)(4) of this section. The owner or operator may elect to use different monitoring methods for different
gaseous streams that make up the flare vent gas using different methods provided the composition or net
heating value of all gas streams that contribute to the flare vent gas are determined.

Status: In compliance – This paragraph allows four monitoring options. The North and South
flares are equipped with a mass spectrometer which satisfies the requirements of 63.670(j)(1). The
mass spectrometer is used to Analise Flare Gas. Because the supplemental gas addition point is
upstream of the mass spectrometer, the value reported by the instrument accounts for the
supplemental gas added to the flare header.

63.670(k) Calculation methods for cumulative flow rates and determining compliance with Vtip operating
limits.

Status: In compliance – Vtip velocities are determined on 15 minutes basis. The time periods
comply with 670(k)(2)(i). Calculation methods are described in the Continuous Parameter
Monitoring (CPMs) monitoring plan dated January 2019.

63.670(l) Calculation methods for determining flare vent gas net heating value.

Status: In compliance – Flare vent gas net heating values are determined on 15 minutes basis. The
time periods comply with 670(l)(3). Calculation methods are described in the CPMS monitoring
plan dated January 2019.

63.670(m) Calculation methods for determining combustion zone net heating value.

Status: In compliance – The flare vent gas flow meters are used to determine combustion zone net
heating values. Combustion zone net heating values are determined on 15 minutes basis.
Calculation methods are described in the CPMS monitoring plan dated January 2019.

63.670(o) Emergency flaring provisions.

The owner or operator of a flare that has the potential to operate above its smokeless capacity under any
circumstance shall comply with the provisions in paragraphs (o)(1)
through (8) of this section.

Status: In compliance – A flare management plan was submitted to the DAQ on February 4, 2019,
for the North and South flares.

63.670(p) Flare monitoring records.

Status: In compliance – Flare monitoring records are available on-site for review.

63.670(q) Reporting.

The owner or operator shall comply with the reporting requirements specified in § 63.655(g)(11).

Status: In compliance – See above conditions.

63.670(r) Alternative means of emissions limitation.

Status: N/A

15
63.671 Requirements for flare monitoring systems.

63.671(a) Operation of CPMS.

Status: In compliance – Information required by this paragraph is contained in the CPMS
Monitoring Plan dated January 2019. CPMS were found to be accessible onsite for inspection by
the operator of the source.

63.671(b) CPMS monitoring plan.

Status: In compliance – Holly has developed and implemented a CPMS quality control program
documented in CPMS monitoring plan dated January 2019 that covers the North and South flares.
The CPMS monitoring plan is readily available and a copy of the CPMS monitoring plan was
submitted to the DAQ upon request. The CPMS monitoring plan contains the information listed in
paragraphs (b)(1) through (5) of this section.

63.671(c) Out-of-control periods.

Status: In compliance – Both the North and South Flares are monitored by CEMs, cameras, and
flow meters, which are used to report out-of-control periods.

63.671(d) CPMS data reduction.

Status: In compliance – Data is reduced per this paragraph.

UAC R307-326-9: Monitoring of Leaks from Petroleum Refinery Equipment

(1) The owner or operator of a petroleum refinery complex shall develop and conduct a VOC
monitoring program and shall follow the recording, reporting, and operating requirements
consistent with R307-326-9. The monitoring program shall be submitted 30 days prior to startup of
the petroleum refinery complex or as determined necessary by the Executive Secretary.

Status: In compliance – A LDAR program is in place and complies with this regulation.

16
(2) Any affected component within a petroleum refinery complex found to be leaking shall be repaired
and retested as soon as practicable, but not later than fifteen (15) days after the leak is detected. A
leaking component is defined as one that has a concentration of VOCs exceeding 10,000 parts per
million by volume (ppmv) when tested by a VOC detection instrument at the leak source in the
manner described in 40 CFR 60, Appendix A, Reference Method 21, using methane or hexane as
the calibration gas. Components not subject to New Source Performance Standards Subpart GGG
shall use methane or hexane as calibration gas, provided a relative response fact or for each
individual instrument is determined for the calibration gas used. Those leaks that cannot be
repaired until the unit is shut down for turnaround shall be identified with a tag and recorded as per
(6) below and shall be reported as per (7) below. The director, in coordination with the refinery
owner or operator, may require early unit turnaround based on the number and severity of tagged
leaks awaiting turnaround.

Status: In compliance – When a leak is detected at 200 ppm (per consent decree), the VOC monitor
technician will make a first attempt at repair. Otherwise, a work order is submitted to have the
leaking equipment repaired. The work order is followed up within five days if it has not been
completed, and again at 15 days to ensure that the leak is repaired. If the component cannot be
repaired because of location, replacement parts, etc. the leaker is placed on the delay of repair
(DOR) list and is reported as such on the quarterly LDAR report submitted to DAQ. Method 21 is
used to detect leaks. The director has not required early unit turnaround based on the number of
tagged leaks.

(3) Monitoring Requirements:

(a) In order to ensure that all existing VOC leaks are identified and that new VOC leaks are located as
soon as practicable, the refinery owner or operator shall perform necessary monitoring using visual
observations when specified or the method described in 40 CFR 60 Appendix A, Reference
Method 21, as follows:

(i) Monitor at least one time per year (annually) all pump seals, valves in liquid service, and process
drains;

Status: In compliance – Light liquid pumps are monitored monthly, heavy liquid pumps are
exempt, light liquid valves are monitored quarterly, process drains are monitored annually.
Exemptions apply.

(ii) Monitor four times per year (quarterly) all compressor seals, valves in gaseous service, and
pressure relief valves in gaseous service.

Status: In compliance – Compressors are monitored quarterly and valves in gas service are
monitored quarterly. All pressure relief valves are monitored quarterly.

(iii) Monitor visually fifty-two (52) times per year (weekly) all pump seals;

Status: In compliance – Weekly visual pump seal inspections are performed by plant operators and
recorded on a log. If a leak is noticed, they are monitored during the VOC LDAR monitoring.
Pumps in heavy liquid service are exempt from monitoring.

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(iv) Monitor within 24 hours (with a portable VOC detection device) or repair within 15 days any
pump seal from which liquids are observed dripping;

Status: In compliance – Any visible leaking pump seals found during visual inspection are
documented. The information is forwarded to the VOC technician for inspection using a portable
OVA instrument. If a visible leak is confirmed as a leaker, a work order is written and entered into
the LDAR system for repair.

(v) Monitor any relief valve within 24 hours after it has been vented to the atmosphere.

Status: In compliance – Several pressure relief valves (PRV) vent to the atmosphere. Most PRV’s
vent to a flare. If a PRV was activated, it is standard procedure to monitor the valve seat within 24
hours and entered into the LDAR information tracking system, Guideware.

(vi) Monitor immediately after repair any component that was found leaking;

Status: In compliance – Monitoring information is recorded in the LDAR information tracking
system, Guideware, by Holly. Components found leaking are monitored immediately after repair.
If a good repair has been confirmed, the Operations Section is notified and the component is
returned to service.

(vii) For all other all other valves considered "unsafe-to-monitor" or inaccessible during an annual
inspection, the owner/operator shall document to the Executive Secretary the number of valves
considered "unsafe-to-monitor" or inaccessible, the dangers involved or reasons for inaccessibility,
the location of these valves, and the procedures that the owner/operator shall follow to ensure that
the valves do not leak. At a minimum, the inaccessible valves shall be monitored at least once per
year (annually).

Status: In compliance – The inaccessible valves are scheduled for annual monitoring during the
period of July 1, 2021, to December 31, 2021, according to the LDAR plan. This inspection is always
scheduled for the last part of the calendar year.

(b) For the purpose of R307-326, gaseous service for pipeline valves and pressure relief valves is
defined as the VOCs being gaseous at conditions that prevail in the components during normal
operations. Pipeline valves and pressure relief valves in gaseous service and other components
subject to leaks shall be noted or marked so that their location within the
refinery complex is obvious to the refinery operator performing the monitoring and to the State of
Utah, Division of Air Quality.

Status: In compliance – The company uses Guideware to track all LDAR information. Tags are
hung on applicable components. Quarterly inspection are conducted of components and tag
numbers and comparing them to the information in Guideware.

(4) Exemptions. The following are exempt from the monitoring requirements of (3) above:
(a) Pressure relief devices that are connected to an operating flare header, firebox, or vapor recovery
devices, storage tank valves, and valves that are not externally regulated;
(b) Refinery equipment containing a stream composition less than 10 percent by weight VOCs; and
(c) Refinery equipment containing natural gas supplied by a public utility as defined by the Utah
Public Service Commission.

Status: In compliance – PRV’s that vent to the flare are monitored. Most of the equipment is
supplied by mixed plant and natural gas and is not exempt from the regulation.
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(5) Alternative Monitoring Methods and Requirements.
a) If at any time after two complete liquid service inspections and five complete gaseous service
inspections, the owner or operator of a petroleum refinery can demonstrate that modifications to
(3) above are in order, he may apply in writing to the Air Quality Board for a variance from the
requirements of (3) above.
(b) This submittal shall include data that have been developed to justify the modification to (3)
above. As a minimum, the submittal should contain the following information:
(i) the name and address of the company;
(ii) the name and telephone number of the responsible company representative;
(iii) a description of the proposed alternate monitoring procedures; and
(iv) a description of the proposed alternate operational or equipment controls.

Status: N/A – Holly applied for alternative monitoring procedures on May 22, 1996. The following
alternative monitoring procedure was granted by the DAQ on July 12, 1996: monitor annually all
valves in gas service and monitor annually NSPS Units 13 and 16 gas valves. The company never
started the skip monitoring program. The EPA Consent Decree does not allow any skip monitoring.

(6) Recording Requirements: Identified leaks shall be noted and affixed with a readily visible and
weatherproof tag bearing the identification of the leak and the date the leak was detected. The tag
shall remain in place until the leaking component is repaired. The presence of the leak shall also be
noted in a log maintained by the operator or owner of the refinery. The log shall contain, at a
minimum, the name of the process unit where the component is located, the type of component,
the tag number, the date the leak was detected, the date repaired, and the date and instrument
reading when the recheck of the component is made. The log should also indicate those leaks
which cannot be repaired until turnaround, and summarize the total number of components found
leaking. The operator or owner of the refinery complex shall retain the leak detection log for two
years after the leak has been repaired and shall make the log available to the Director upon request.

Status: In compliance – Holly’s environmental office maintains all field copies of the LDAR
program and spreadsheets of the above required information. Field copies contain the tag number,
description, unit number, valve size, type, and leak rate. Shut down logs contain date, meter
reading, and comments. The leak repair log spreadsheets contain the tag number, unit number,
location, check date, repair due date, date completed, instrument reading, and if it was transferred
to the shutdown log. As per the Consent Decree, Holly submits quarterly reports that detail all of
the information noted above.

(7) Reporting Requirements: The operator or owner of a petroleum refinery complex shall submit a
report to the Executive Secretary, Utah Air Quality Board, by the 15th day of January, April, July,
and October of each year listing the total number of components inspected, all leaks that have been
located during the previous 3 calendar months but have not been repaired within fifteen (15) days,
all leaking components awaiting unit turnaround and the total number of components found
leaking. In addition, the refinery operator or owner shall submit signed statement with each report
that all monitoring has been performed as stipulated in R307-326-9.

Status: In compliance – Quarterly monitoring reports have been submitted on time in the past year
(see source file). They are signed by the refinery manager and contain all required information.
Valves may show several readings due to readings and re-readings done based on lower ppm limits
contained in the Consent Decree or post repair. These are listed and tracked in the Guideware
system.

19
(8) Additional Requirements. Any time a valve, with the exception of safety pressure relief valves, is
located at the end of a pipe or line containing VOC, the end of the line shall be sealed with one of
the following: a second valve, a blind flange, a plug or a cap. This sealing device shall only be
removed when the line is in use for sampling.

Status: In compliance – This is Holly’s standard operating procedure. Think Environmental VOC
monitoring technicians notify refinery operators of any deficiencies discovered and if any open
valve ends need to be plugged.

NSPS (Part 60), GGGa: NSPS for Equipment Leaks of VOC in Petroleum Refineries for Which
Construction, Reconstruction, or Modification Commenced After November 7, 2006

60.590a Applicability and designation of affected facility.

Status: In compliance – Holly’s refinery is subject to this regulation. The Utah PM10 SIP requires
Holly to comply with Subpart GGGa. Sec. 60.590a(d) states that facilities subject to Subpart GGG
are excluded from this subpart.

60.592a Standards.

60.592a(a)

Each owner or operator subject to the provisions of this subpart shall comply with the requirements of
60.482–1a to 60.482–10a as soon as practicable, but no later than 180 days after initial startup.

Status: In compliance – Holly has complied upon start-up with its LDAR program. This has been
evaluated during previous inspections.

60.592a(b)

For a given process unit, an owner or operator may elect to comply with the requirements of paragraphs
(b)(1), (2), or (3) of this section as an alternative to the requirements in 60.482–7a.

60.592a(b)(1)

Comply with 60.483–1a.

60.592a(b)(2)

Comply with 60.483–2a.

60.592a(b)(3)

Comply with the Phase III provisions in 63.168, except an owner or operator may elect to follow the
provisions in 60.482–7a(f) instead of 63.168 for any valve that is designated as being leakless.

Status: N/A – Holly has no detectable emission valves.

20
60.592a(c)

An owner or operator may apply to the Administrator for a determination of equivalency for any means of
emission limitation that achieves a reduction in emissions of VOC at least equivalent to the reduction in
emissions of VOC achieved by the controls required in this subpart. In doing so, the owner or operator
shall comply with requirements of 60.484a.

Status: N/A

60.592a(d)

Each owner or operator subject to the provisions of this subpart shall comply with the provisions of
60.485a except as provided in 60.593a.

Status: In compliance – Method 21 is used to determine the presence of leaks.

60.592a(e)

Each owner or operator subject to the provisions of this subpart shall comply with the provisions of
60.486a and 60.487a.

Status: In compliance - Holly complies with the recordkeeping and reporting requirements of 40
CFR 60 Subpart VVa. Quarterly LDAR reports are submitted.

60.593a Exceptions.

60.593a(a)

Each owner or operator subject to the provisions of this subpart may comply with the following
exceptions to the provisions of subpart VVa of this part.

60.593a(b)

60.593a(b)(1)

Compressors in hydrogen service are exempt from the requirements of 60.592a if an owner or operator
demonstrates that a compressor is in hydrogen service.

Status: In compliance – The refinery has one compressor in hydrogen service.

60.593a(b)(2)

Each compressor is presumed not to be in hydrogen service unless an owner or operator demonstrates that
the piece of equipment is in hydrogen service. For a piece of equipment to be considered in hydrogen
service, it must be determined that the percent hydrogen content can be reasonably expected always to
exceed 50 percent by volume. For purposes of determining the percent hydrogen content in the process
fluid that is contained in or contacts a compressor, procedures that conform to the general method
described in ASTM E260–73, 91, or 96, E168–67, 77, or 92, or E169–63, 77, or 93 (incorporated by
reference as specified in 60.17) shall be used.
60.593a(b)(3)

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60.593a(b)(3)(i)

An owner or operator may use engineering judgment rather than procedures in paragraph (b)(2) of this
section to demonstrate that the percent content exceeds 50 percent by volume, provided the engineering
judgment demonstrates that the content clearly exceeds 50 percent by volume. When an owner or operator
and the Administrator do not agree on whether a piece of equipment is in hydrogen service, however, the
procedures in paragraph (b)(2) of this section shall be used to resolve the disagreement.

60.593a(b)(3)(ii)

If an owner or operator determines that a piece of equipment is in hydrogen service, the determination can
be revised only after following the procedures in paragraph (b)(2).

60.593a(c)

Any existing reciprocating compressor that becomes an affected facility under provisions of 60.14 or
60.15 is exempt from 60.482–3a(a), (b), (c), (d), (e), and (h) provided the owner or operator demonstrates
that recasting the distance piece or replacing the compressor are the only options available to bring the
compressor into compliance with the provisions of 60.482–3a(a), (b), (c), (d), (e), and (h).

60.593a(d)

An owner or operator may use the following provision in addition to 60.485a(e): Equipment is in light
liquid service if the percent evaporated is greater than 10 percent at 150 ° C as determined by ASTM
Method D86–78, 82, 90, 93, 95, or 96 (incorporated by reference as specified in § 60.17).

60.593a(e)

Pumps in light liquid service and valves in gas/vapor and light liquid service within a process unit that is
located in the Alaskan North Slope are exempt from the requirements of 60.482–2a and 60.482–7a.

60.593a(f)

Open-ended valves or lines containing asphalt as defined in 60.591a are exempt from the requirements of
60.482–6a(a) through (c).

60.593a(g)

Connectors in gas/vapor or light liquid service are exempt from the requirements in § 60.482-11a,
provided the owner or operator complies with § 60.482-8a for all connectors, not just those in heavy
liquid service

Status: In compliance – All listed components have determinations made on exemption status. The
one compressor that is in hydrogen service as shown in piping diagrams. Service is determined by
engineering and testing of component streams. One exception is noted for the Unit 20 compressor.
It is 100% serviced from the Linde Hydrogen Plant. Holly is using analytical data to verify H2S
content. Holly does not monitor connectors gas/vapor or light liquid service as they are exempt
from monitoring.

22
NSPS (Part 60), VVa: NSPS for Equipment Leaks of VOC in the Synthetic Organic Chemicals
Manufacturing Industry for Which Construction, Reconstruction, or Modification Commenced
After November 7, 2006

60.480a Applicability and designation of affected facility

Status: In compliance – Holly complies with this subpart as referenced by 40 CFR 60 Subpart
GGGa.

60.482-1a Standards: General.

Status: In compliance – Holly does not perform alternate monitoring or exemption methods. Holly
completes monitoring and internal audits at least once every 2 years which is required by the EPA
Consent Decree. Holly is currently completing audits every 4 years by a third party. Shared
components are based on predominate use.

60.482-2a Standards: Pumps in light liquid service.

60.482-2a(a)

60.482-2a(a)(1)

Each pump in light liquid service shall be monitored monthly to detect leaks by the methods specified in
§ 60.485a(b), except as provided in 60.482–1a(c) and (f) and paragraphs (d), (e), and (f) of this section. A
pump that begins operation in light liquid service after the initial startup date for the process unit must be
monitored for the first time within 30 days after the end of its startup period, except for a pump that
replaces a leaking pump and except as provided in 60.482–1a(c) and paragraphs (d), (e), and (f) of this
section.

60.482-2a(a)(2)

Each pump in light liquid service shall be checked by visual inspection each calendar week for indications
of liquids dripping from the pump seal, except as provided in 60.482–1a(f).

60.482-2a(b)

60.482-2a(b)(1)

The instrument reading that defines a leak is specified in paragraphs (b)(1)(i) and (ii) of this section.

60.482-2a(b)(1)(i)

5,000 parts per million (ppm) or greater for pumps handling polymerizing monomers;

60.482-2a(b)(1)(ii)

2,000 ppm or greater for all other pumps.

60.482-2a(b)(2)

If there are indications of liquids dripping from the pump seal, the owner or operator shall follow the
procedure specified in either paragraph (b)(2)(i) or (ii) of this section. This requirement does not apply to
23
a pump that was monitored after a previous weekly inspection and the instrument reading was less than
the concentration specified in paragraph (b)(1)(i) or (ii) of this section, whichever is applicable.

60.482-2a(b)(2)(i)

Monitor the pump within 5 days as specified in 60.485a(b). A leak is detected if the instrument reading
measured during monitoring indicates a leak as specified in paragraph (b)(1)(i) or (ii) of this section,
whichever is applicable. The leak shall be repaired using the procedures in paragraph (c) of this section.

60.482-2a(b)(2)(ii)

Designate the visual indications of liquids dripping as a leak, and repair the leak using either the
procedures in paragraph (c) of this section or by eliminating the visual indications of liquids dripping.

60.482-2a(c)

60.482-2a(c)(1)

When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days
after it is detected, except as provided in 60.482–9a.

60.482-2a(c)(2)

A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. First
attempts at repair include, but are not limited to, the practices described in paragraphs (c)(2)(i) and (ii) of
this section, where practicable.

60.482-2a(c)(2)(i)

Tightening the packing gland nuts;

60.482-2a(c)(2)(ii)

Ensuring that the seal flush is operating at design pressure and temperature.

60.482-2a(d)

Each pump equipped with a dual mechanical seal system that includes a barrier fluid system is exempt
from the requirements of paragraph (a) of this section, provided the requirements specified in paragraphs
(d)(1) through (6) of this section are met.

60.482-2a(d)(1)

Each dual mechanical seal system is:

60.482-2a(d)(1)(i)

Operated with the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure; or

60.482-2a(d)(1)(ii)

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Equipped with a barrier fluid degassing reservoir that is routed to a process or fuel gas system or
connected by a closed vent system to a control device that complies with the requirements of 60.482–10a;
or

60.482-2a(d)(1)(iii)

Equipped with a system that purges the barrier fluid into a process stream with zero VOC emissions to the
atmosphere.

60.482-2a(d)(2)

The barrier fluid system is in heavy liquid service or is not in VOC service.

60.482-2a(d)(3)

Each barrier fluid system is equipped with a sensor that will detect failure of the seal system, the barrier
fluid system, or both.

60.482-2a(d)(4)

60.482-2a(d)(4)(i)

Each pump is checked by visual inspection, each calendar week, for indications of liquids dripping from
the pump seals.

60.482-2a(d)(4)(ii)

If there are indications of liquids dripping from the pump seal at the time of the weekly inspection, the
owner or operator shall follow the procedure specified in either paragraph (d)(4)(ii)(A) or (B) of this
section prior to the next required inspection.

60.482-2a(d)(4)(ii)(A)

Monitor the pump within 5 days as specified in 60.485a(b) to determine if there is a leak of VOC in the
barrier fluid. If an instrument reading of 2,000 ppm or greater is measured, a leak is detected.

60.482-2a(d)(4)(ii)(B)

Designate the visual indications of liquids dripping as a leak.

60.482-2a(d)(5)

60.482-2a(d)(5)(i)

Each sensor as described in paragraph (d)(3) is checked daily or is equipped with an audible alarm.

60.482-2a(d)(5)(ii)

The owner or operator determines, based on design considerations and operating experience, a criterion
that indicates failure of the seal system, the barrier fluid system, or both.

60.482-2a(d)(5)(iii)
25

If the sensor indicates failure of the seal system, the barrier fluid system, or both, based on the criterion
established in paragraph (d)(5)(ii) of this section, a leak is detected.

60.482-2a(d)(6)

60.482-2a(d)(6)(i)

When a leak is detected pursuant to paragraph (d)(4)(ii)(A) of this section, it shall be repaired as specified
in paragraph (c) of this section.

60.482-2a(d)(6)(ii)

A leak detected pursuant to paragraph (d)(5)(iii) of this section shall be repaired within 15 days of
detection by eliminating the conditions that activated the sensor.

60.482-2a(d)(6)(iii)

A designated leak pursuant to paragraph (d)(4)(ii)(B) of this section shall be repaired within 15 days of
detection by eliminating visual indications of liquids dripping.

60.482-2a(e)

Any pump that is designated, as described in 60.486a(e)(1) and (2), for no detectable emissions, as
indicated by an instrument reading of less than 500 ppm above background, is exempt from the
requirements of paragraphs (a), (c), and (d) of this section if the pump:

60.482-2a(e)(1)

Has no externally actuated shaft penetrating the pump housing;

60.482-2a(e)(2)

Is demonstrated to be operating with no detectable emissions as indicated by an instrument reading of less
than 500 ppm above background as measured by the methods specified in 60.485a(c); and

60.482-2a(e)(3)

Is tested for compliance with paragraph (e)(2) of this section initially upon designation, annually, and at
other times requested by the Administrator.

60.482-2a(f)

If any pump is equipped with a closed vent system capable of capturing and transporting any leakage
from the seal or seals to a process or to a fuel gas system or to a control device that complies with the
requirements of § 60.482–10a, it is exempt from paragraphs (a) through (e) of this section.
60.482-2a(g)

Any pump that is designated, as described in 60.486a(f)(1), as an unsafe-to-monitor pump is exempt from
the monitoring and inspection requirements of paragraphs (a) and (d)(4) through (6) of this section if:

60.482-2a(g)(1)
26

The owner or operator of the pump demonstrates that the pump is unsafe-to-monitor because monitoring
personnel would be exposed to an immediate danger as a consequence of complying with paragraph (a) of
this section; and

60.482-2a(g)(2)

The owner or operator of the pump has a written plan that requires monitoring of the pump as frequently
as practicable during safe-to-monitor times, but not more frequently than the periodic
monitoring schedule otherwise applicable, and repair of the equipment according to the procedures in
paragraph (c) of this section if a leak is detected.

60.482-2a(h)

Any pump that is located within the boundary of an unmanned plant site is exempt from the weekly visual
inspection requirement of paragraphs (a)(2) and (d)(4) of this section, and the daily
requirements of paragraph (d)(5) of this section, provided that each pump is visually inspected as often as
practicable and at least monthly.

Status: In compliance – Dual seal pumps are monitored annually. All other pumps are monitored
weekly by the VOC technicians as noted on the weekly pump inspection checklist. Any visible leak
is treated as a leak. Review of the records show all reported leaks are repaired by a technician by
the methods specified within five days, if possible. First attempts are completed by the VOC
technician when the leak is detected during monitoring. Those still leaking are reported and repairs
are completed within 15 days or the component is put on the Delay of Repair (DOR) list. The DOR
list is signed by the refinery manager.

60.482-3a Standards: Compressors.

60.482-3a(a)

Each compressor shall be equipped with a seal system that includes a barrier fluid system and that
prevents leakage of VOC to the atmosphere, except as provided in 60.482–1a(c) and paragraphs (h), (i),
and (j) of this section.

60.482-3a(b)

Each compressor seal system as required in paragraph (a) of this section shall be:

60.482-3a(b)(1)

Operated with the barrier fluid at a pressure that is greater than the compressor stuffing box pressure; or

60.482-3a(b)(2)

Equipped with a barrier fluid system degassing reservoir that is routed to a process or fuel gas system or
connected by a closed vent system to a control device that complies with the requirements of 60.482–10a;
or

60.482-3a(b)(3)

27
Equipped with a system that purges the barrier fluid into a process stream with zero VOC emissions to the
atmosphere.

60.482-3a(c)

The barrier fluid system shall be in heavy liquid service or shall not be in VOC service.

60.482-3a(d)

Each barrier fluid system as described in paragraph (a) shall be equipped with a sensor that will detect
failure of the seal system, barrier fluid system, or both.

60.482-3a(e)

60.482-3a(e)(1)

Each sensor as required in paragraph (d) of this section shall be checked daily or shall be equipped with
an audible alarm.

60.482-3a(e)(2)

The owner or operator shall determine, based on design considerations and operating experience, a
criterion that indicates failure of the seal system, the barrier fluid system, or both.

60.482-3a(f)

If the sensor indicates failure of the seal system, the barrier system, or both based on the criterion
determined under paragraph (e)(2) of this section, a leak is detected.

60.482-3a(g)

60.482-3a(g)(1)

When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days
after it is detected, except as provided in 60.482–9a.

60.482-3a(g)(2)

A first attempt at repair shall be made no later than 5 calendar days after each leak is detected.

60.482-3a(h)

A compressor is exempt from the requirements of paragraphs (a) and (b) of this section, if it is equipped
with a closed vent system to capture and transport leakage from the compressor drive shaft back to a
process or fuel gas system or to a control device that complies with the requirements of § 60.482–10a,
except as provided in paragraph (i) of this section.

60.482-3a(i)

Any compressor that is designated, as described in 60.486a(e)(1) and (2), for no detectable emissions, as
indicated by an instrument reading of less than 500 ppm above background, is exempt from the
requirements of paragraphs (a) through (h) of this section if the compressor:
28

60.482-3a(i)(1)

Is demonstrated to be operating with no detectable emissions, as indicated by an instrument reading of
less than 500 ppm above background, as measured by the methods specified in § 60.485a(c); and

60.482-3a(i)(2)

Is tested for compliance with paragraph (i)(1) of this section initially upon designation, annually, and at
other times requested by the Administrator.

60.482-3a(j)

Any existing reciprocating compressor in a process unit which becomes an affected facility under
provisions of 60.14 or 60.15 is exempt from paragraphs (a) through (e) and (h) of this section, provided
the owner or operator demonstrates that recasting the distance piece or replacing the compressor are the
only options available to bring the compressor into compliance with the provisions of paragraphs (a)
through (e) and (h) of this section.

Status: In compliance – Compressors are monitored quarterly. All pressure relief valves vent to a
flare or have visible indicators. Three of the valves are exempt. A visible leak is treated as a leak.
Review of the records show all reported leaks are repaired by the VOC technician by the methods
specified within five days, if possible. Those still leaking are reported and repairs are completed
within 15 days or the component is put on the DOR list. The delay of repair is signed by the
refinery manager.

60.482-4a Standards: Pressure relief devices in gas/vapor service.

60.482-4a(a)

Except during pressure releases, each pressure relief device in gas/vapor service shall be operated with no
detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as
determined by the methods specified in 60.485a(c).

60.482-4a(b)

60.482-4a(b)(1)

After each pressure release, the pressure relief device shall be returned to a condition of no detectable
emissions, as indicated by an instrument reading of less than 500 ppm above background, as soon as
practicable, but no later than 5 calendar days after the pressure release, except as provided in 60.482–9a.
60.482-4a(b)(2)

No later than 5 calendar days after the pressure release, the pressure relief device shall be monitored to
confirm the conditions of no detectable emissions, as indicated by an instrument reading of less than 500
ppm above background, by the methods specified in 60.485a(c).

60.482-4a(c)

Any pressure relief device that is routed to a process or fuel gas system or equipped with a closed vent
system capable of capturing and transporting leakage through the pressure relief device to a
control device as described in 60.482–10a is exempted from the requirements of paragraphs (a) and (b) of
29
this section.

60.482-4a(d)

60.482-4a(d)(1)

Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief device is
exempt from the requirements of paragraphs (a) and (b) of this section, provided the owner or operator
complies with the requirements in paragraph (d)(2) of this section.

60.482-4a(d)(2)

After each pressure release, a new rupture disk shall be installed upstream of the pressure relief device as
soon as practicable, but no later than 5 calendar days after each pressure release, except as provided in §
60.482–9a.

Status: In compliance – All pressure relief valves, accept the exempt valves, vent to a flare or have
visible indicators. This list may change due to new equipment being added and recent changes to
subpart CC and UUU. Any ruptures noted are monitored within 24 hours and are repaired or reset
and monitored to show less than 500 PPM.

60.482-5a Standards: Sampling connection systems.

60.482-5a(a)

Each sampling connection system shall be equipped with a closed-purge, closed-loop, or closed-vent
system, except as provided in 60.482–1a(c) and paragraph (c) of this section.

60.482-5a(b)

Each closed-purge, closed-loop, or closed-vent system as required in paragraph (a) of this section shall
comply with the requirements specified in paragraphs (b)(1) through (4) of this section.

60.482-5a(b)(1)

Gases displaced during filling of the sample container are not required to be collected or captured.

60.482-5a(b)(2)

Containers that are part of a closed-purge system must be covered or closed when not being filled or
emptied.

60.482-5a(b)(3)

Gases remaining in the tubing or piping between the closed-purge system valve(s) and sample container
valve(s) after the valves are closed and the sample container is disconnected are not required to be
collected or captured.

60.482-5a(b)(4)

Each closed-purge, closed-loop, or closed-vent system shall be designed and operated to meet
requirements in either paragraph (b)(4)(i), (ii), (iii), or (iv) of this section.
30
60.482-5a(b)(4)(i)

Return the purged process fluid directly to the process line.

60.482-5a(b)(4)(ii)

Collect and recycle the purged process fluid to a process.

60.482-5a(b)(4)(iii)

Capture and transport all the purged process fluid to a control device that complies with the requirements
of 60.482–10a.

60.482-5a(b)(4)(iv)

Collect, store, and transport the purged process fluid to any of the following systems or facilities:

60.482-5a(b)(4)(iv)(A)

A waste management unit as defined in 40 CFR 63 Subpart.111, if the waste management unit is subject
to and operated in compliance with the provisions of 40 CFR part 63, subpart G, applicable to Group 1
wastewater streams;

60.482-5a(b)(4)(iv)(B)

A treatment, storage, or disposal facility subject to regulation under 40 CFR part 262, 264, 265, or 266;

60.482-5a(b)(4)(iv)(C)

A facility permitted, licensed, or registered by a state to manage municipal or industrial solid waste, if the
process fluids are not hazardous waste as defined in 40 CFR part 261;

60.482-5a(b)(4)(iv)(D)

A waste management unit subject to and operated in compliance with the treatment requirements of 40
CFR 61.348(a), provided all waste management units that collect, store, or transport the purged process
fluid to the treatment unit are subject to and operated in compliance with the management requirements of
40 CFR 61.343 through 40 CFR 61.347; or

60.482-5a(b)(4)(iv)(E)

A device used to burn off-specification used oil for energy recovery in accordance with 40 CFR part 279,
subpart G, provided the purged process fluid is not hazardous waste as defined in 40 CFR part 261.

60.482-5a(c)

In-situ sampling systems and sampling systems without purges are exempt from the requirements of
paragraphs (a) and (b) of this section.

Status: In compliance – All purge and sampling systems appear to comply as stated above. Lines
are closed when not in active use. All lines feed back to the process or fluids are contained as
required.
31
60.482-6a Standards: Open-ended valves or lines.

60.482-6a(a)

60.482-6a(a)(1)

Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a second valve, except
as provided in § 60.482–1a(c) and paragraphs (d) and (e) of this section.

60.482-6a(a)(2)

The cap, blind flange, plug, or second valve shall seal the open end at all times except during operations
requiring process fluid flow through the open-ended valve or line.

60.482-6a(b)

Each open-ended valve or line equipped with a second valve shall be operated in a manner such that the
valve on the process fluid end is closed before the second valve is closed.

60.482-6a(c)

When a double block-and-bleed system is being used, the bleed valve or line may remain open during
operations that require venting the line between the block valves but shall comply with paragraph (a) of
this section at all other times.

60.482-6a(d)

Open-ended valves or lines in an emergency shutdown system which are designed to open automatically
in the event of a process upset are exempt from the requirements of paragraphs (a), (b), and (c) of this
section.

60.482-6a(e)

Open-ended valves or lines containing materials which would autocatalytically polymerize or would
present an explosion, serious overpressure, or other safety hazard if capped or equipped with a double
block and bleed system as specified in paragraphs (a) through (c) of this section are exempt from the
requirements of paragraphs (a) through (c) of this section.

Status: In compliance – Check for open-ended valves and lines show all have double closures with
either two valves or a valve and cap system. Open-ended valves and lines are tracked in 3 ways. An
incident report is created whenever an open-ended valve or line is discovered. Think
Environmental VOC monitoring technicians notify refinery operators of any deficiencies
discovered and if any open valve ends need to be plugged.

60.482-7a Standards: Valves in gas/vapor service and in light liquid service.

60.482-7a(a)

60.482-7a(a)(1)

Each valve shall be monitored monthly to detect leaks by the methods specified in 60.485a(b) and shall
comply with paragraphs (b) through (e) of this section, except as provided in paragraphs (f), (g), and (h)
32
of this section, 60.482–1a(c) and (f), and 60.483–1a and 60.483–2a.

60.482-7a(a)(2)

A valve that begins operation in gas/vapor service or light liquid service after the initial startup date for
the process unit must be monitored according to paragraphs (a)(2)(i) or (ii), except for a valve that
replaces a leaking valve and except as provided in paragraphs (f), (g), and (h) of this section, 60.482–
1a(c), and 60.483–1a and 60.483–2a.

60.482-7a(a)(2)(i)

Monitor the valve as in paragraph (a)(1) of this section. The valve must be monitored for the first time
within 30 days after the end of its startup period to ensure proper installation.

60.482-7a(a)(2)(ii)

If the existing valves in the process unit are monitored in accordance with 60.483–1a or 60.483–2a, count
the new valve as leaking when calculating the percentage of valves leaking as described in 60.483–
2a(b)(5). If less than 2.0 percent of the valves are leaking for that process unit, the valve must be
monitored for the first time during the next scheduled monitoring event for existing valves in the process
unit or within 90 days, whichever comes first.

60.482-7a(b)

If an instrument reading of 500 ppm or greater is measured, a leak is detected.

60.482-7a(c)

60.482-7a(c)(1)

60.482-7a(c)(1)(i)

Any valve for which a leak is not detected for 2 successive months may be monitored the first month of
every quarter, beginning with the next quarter, until a leak is detected.

60.482-7a(c)(1)(ii)

As an alternative to monitoring all of the valves in the first month of a quarter, an owner or operator may
elect to subdivide the process unit into two or three subgroups of valves and monitor each subgroup in a
different month during the quarter, provided each subgroup is monitored every 3 months. The owner or
operator must keep records of the valves assigned to each subgroup.

60.482-7a(c)(2)

If a leak is detected, the valve shall be monitored monthly until a leak is not detected for 2 successive
months.

60.482-7a(d)

60.482-7a(d)(1)

When a leak is detected, it shall be repaired as soon as practicable, but no later than 15 calendar days after
33
the leak is detected, except as provided in 60.482–9a.

60.482-7a(d)(2)

A first attempt at repair shall be made no later than 5 calendar days after each leak is detected.

60.482-7a(e)

First attempts at repair include, but are not limited to, the following best practices where practicable:

60.482-7a(e)(1)

Tightening of bonnet bolts;

60.482-7a(e)(2)

Replacement of bonnet bolts;

60.482-7a(e)(3)

Tightening of packing gland nuts;

60.482-7a(e)(4)

Injection of lubricant into lubricated packing.

60.482-7a(f)

Any valve that is designated, as described in 60.486a(e)(2), for no detectable emissions, as indicated by
an instrument reading of less than 500 ppm above background, is exempt from the requirements of
paragraph (a) of this section if the valve:

60.482-7a(f)(1)

Has no external actuating mechanism in contact with the process fluid.
60.482-7a(f)(2)

Is operated with emissions less than 500 ppm above background as determined by the method specified in
60.485a(c), and

60.482-7a(f)(3)

Is tested for compliance with paragraph (f)(2) of this section initially upon designation, annually, and at
other times requested by the Administrator.

60.482-7a(g)

Any valve that is designated, as described in 60.486a(f)(1), as an unsafe-to-monitor valve is exempt from
the requirements of paragraph (a) of this section if:

60.482-7a(g)(1)

34
The owner or operator of the valve demonstrates that the valve is unsafe to monitor because monitoring
personnel would be exposed to an immediate danger as a consequence of complying with paragraph (a) of
this section, and

60.482-7a(g)(2)

The owner or operator of the valve adheres to a written plan that requires monitoring of the valve as
frequently as practicable during safe-to-monitor times.

60.482-7a(h)

Any valve that is designated, as described in 60.486a(f)(2), as a difficult-to-monitor valve is exempt from
the requirements of paragraph (a) of this section if:

60.482-7a(h)(1)

The owner or operator of the valve demonstrates that the valve cannot be monitored without elevating the
monitoring personnel more than 2 meters above a support surface.

60.482-7a(h)(2)

The process unit within which the valve is located either:

60.482-7a(h)(2)(i)

Becomes an affected facility through 60.14 or 60.15 and was constructed on or before January 5, 1981; or

60.482-7a(h)(2)(ii)

Has less than 3.0 percent of its total number of valves designated as difficult-to-monitor by the owner or
operator.

60.482-7a(h)(3)

The owner or operator of the valve follows a written plan that requires monitoring of the valve at least
once per calendar year.

Status: In compliance – All accessible valves are monitored quarterly unless a leak is noted. When a
leak is detected the VOC monitor technician will make a first attempt at repair on simple items.
Otherwise, a work order is submitted to have the leaking equipment repaired. The work order is
followed up within five days if it has not been completed, and again at 15 days to ensure that the
leak is below the leak limit. If the component cannot be repaired because of location, replacement
parts, etc., the leaker is placed on the shutdown (delay of repair) list and is reported as such on the
quarterly report. First repair attempts come from leaks greater than 200 ppm as required in the
EPA Consent Decree. Records are maintained on leaks in excess of 500 ppm as required by this
regulation. The difficult to monitor list has been updated to reflect less than 3% of total count.

60.482-8a Standards: Pumps, valves, and connectors in heavy liquid service and pressure relief devices
in light liquid or heavy liquid service.

60.482-8a(a)

35
If evidence of a potential leak is found by visual, audible, olfactory, or any other detection method at
pumps, valves, and connectors in heavy liquid service and pressure relief devices in light liquid or heavy
liquid service, the owner or operator shall follow either one of the following procedures:

60.482-8a(a)(1)

The owner or operator shall monitor the equipment within 5 days by the method specified in 60.485a(b)
and shall comply with the requirements of paragraphs (b) through (d) of this section.

60.482-8a(a)(2)

The owner or operator shall eliminate the visual, audible, olfactory, or other indication of a potential leak
within 5 calendar days of detection.

60.482-8a(b)

If an instrument reading of 10,000 ppm or greater is measured, a leak is detected.

60.482-8a(c)

60.482-8a(c)(1)

When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days
after it is detected, except as provided in 60.482–9a.

60.482-8a(c)(2)

The first attempt at repair shall be made no later than 5 calendar days after each leak is detected.
60.482-8a(d)

First attempts at repair include, but are not limited to, the best practices described under 60.482–2a(c)(2)
and 60.482–7a(e).

Status: In compliance – Weekly visual pump seal inspections are performed by plant operators and
recorded on a log. The information is forwarded to the VOC monitor technician for inspection
using a portable Toxic Vapor Analyzer (TVA) instrument. If a visible leak is confirmed as a leaker,
a work order is written and entered into the Guidewear system.

60.482-9a Standards: Delay of repair.

60.482-9a(a)

Delay of repair of equipment for which leaks have been detected will be allowed if repair within 15 days
is technically infeasible without a process unit shutdown. Repair of this equipment shall occur before the
end of the next process unit shutdown. Monitoring to verify repair must occur within 15 days after startup
of the process unit.

60.482-9a(b)

Delay of repair of equipment will be allowed for equipment which is isolated from the process and which
does not remain in VOC service.

36
60.482-9a(c)

Delay of repair for valves and connectors will be allowed if:

60.482-9a(c)(1)

The owner or operator demonstrates that emissions of purged material resulting from immediate repair are
greater than the fugitive emissions likely to result from delay of repair, and

60.482-9a(c)(2)

When repair procedures are affected, the purged material is collected and destroyed or recovered in a
control device complying with 60.482–10a.

60.482-9a(d)

Delay of repair for pumps will be allowed if:

60.482-9a(d)(1)

Repair requires the use of a dual mechanical seal system that includes a barrier fluid system, and

60.482-9a(d)(2)

Repair is completed as soon as practicable, but not later than 6 months after the leak was detected.

60.482-9a(e)

Delay of repair beyond a process unit shutdown will be allowed for a valve, if valve assembly
replacement is necessary during the process unit shutdown, valve assembly supplies have been depleted,
and valve assembly supplies had been sufficiently stocked before the supplies were depleted. Delay of
repair beyond the next process unit shutdown will not be allowed unless the next process unit shutdown
occurs sooner than 6 months after the first process unit shutdown.

60.482-9a(f)

When delay of repair is allowed for a leaking pump, valve, or connector that remains in service, the
pump, valve, or connector may be considered to be repaired and no longer subject to delay of repair
requirements if two consecutive monthly monitoring instrument readings are below the leak definition.

Status: In compliance – All non-repairable components are listed on the DOR list which is signed
by refinery manager.

60.482-10a Standards: Closed vent systems and control devices.

60.482-10a(a)

Owners or operators of closed vent systems and control devices used to comply with provisions of this
subpart shall comply with the provisions of this section.

60.482-10a(b)

37
Vapor recovery systems (for example, condensers and absorbers) shall be designed and operated to
recover the VOC emissions vented to them with an efficiency of 95 percent or greater, or to an exit
concentration of 20 parts per million by volume (ppmv), whichever is less stringent.

60.482-10a(c)

Enclosed combustion devices shall be designed and operated to reduce the VOC emissions vented to them
with an efficiency of 95 percent or greater, or to an exit concentration of 20 ppmv, on a dry basis,
corrected to 3 percent oxygen, whichever is less stringent or to provide a minimum residence time of 0.75
seconds at a minimum temperature of 816 ° C.

60.482-10a(d)

Flares used to comply with this subpart shall comply with the requirements of 60.18.

60.482-10a(e)

Owners or operators of control devices used to comply with the provisions of this subpart shall monitor
these control devices to ensure that they are operated and maintained in conformance with their designs.
60.482-10a(f)

Except as provided in paragraphs (i) through (k) of this section, each closed vent system shall be
inspected according to the procedures and schedule specified in paragraphs (f)(1) and (2) of this section.

60.482-10a(f)(1)

If the vapor collection system or closed vent system is constructed of hard-piping, the owner or operator
shall comply with the requirements specified in paragraphs (f)(1)(i) and (ii) of this section:

60.482-10a(f)(1)(i)

Conduct an initial inspection according to the procedures in 60.485a(b); and

60.482-10a(f)(1)(ii)

Conduct annual visual inspections for visible, audible, or olfactory indications of leaks.

60.482-10a(f)(2)

If the vapor collection system or closed vent system is constructed of ductwork, the owner or operator
shall:

60.482-10a(f)(2)(i)

Conduct an initial inspection according to the procedures in 60.485a(b); and

60.482-10a(f)(2)(ii)

Conduct annual inspections according to the procedures in 60.485a(b).

60.482-10a(g)

38
Leaks, as indicated by an instrument reading greater than 500 ppmv above background or by visual
inspections, shall be repaired as soon as practicable except as provided in paragraph (h) of this section.

60.482-10a(g)(1)

A first attempt at repair shall be made no later than 5 calendar days after the leak is detected.

60.482-10a(g)(2)

Repair shall be completed no later than 15 calendar days after the leak is detected.

60.482-10a(h)

Delay of repair of a closed vent system for which leaks have been detected is allowed if the repair is
technically infeasible without a process unit shutdown or if the owner or operator determines that
emissions resulting from immediate repair would be greater than the fugitive emissions likely to
result from delay of repair. Repair of such equipment shall be complete by the end of the next process unit
shutdown.

60.482-10a(i)

If a vapor collection system or closed vent system is operated under a vacuum, it is exempt from the
inspection requirements of paragraphs (f)(1)(i) and (f)(2) of this section.

60.482-10a(j)

Any parts of the closed vent system that are designated, as described in paragraph (l)(1) of this section, as
unsafe to inspect are exempt from the inspection requirements of paragraphs (f)(1)(i) and (f)(2) of this
section if they comply with the requirements specified in paragraphs (j)(1) and (2) of this section:

60.482-10a(j)(1)

The owner or operator determines that the equipment is unsafe to inspect because inspecting personnel
would be exposed to an imminent or potential danger as a consequence of complying with paragraphs
(f)(1)(i) or (f)(2) of this section; and
60.482-10a(j)(2)

The owner or operator has a written plan that requires inspection of the equipment as frequently as
practicable during safe-to-inspect times.

60.482-10a(k)

Any parts of the closed vent system that are designated, as described in paragraph (l)(2) of this section, as
difficult to inspect are exempt from the inspection requirements of paragraphs (f)(1)(i) and (f)(2) of this
section if they comply with the requirements specified in paragraphs (k)(1) through (3) of this section:

60.482-10a(k)(1)

The owner or operator determines that the equipment cannot be inspected without elevating the inspecting
personnel more than 2 meters above a support surface; and

60.482-10a(k)(2)
39
The process unit within which the closed vent system is located becomes an affected facility through
60.14 or 60.15, or the owner or operator designates less than 3.0 percent of the total number of closed
vent system equipment as difficult to inspect; and

60.482-10a(k)(3)

The owner or operator has a written plan that requires inspection of the equipment at least once every 5
years. A closed vent system is exempt from inspection if it is operated under a vacuum.

60.482-10a(l)

The owner or operator shall record the information specified in paragraphs (l)(1) through (5) of this
section.

60.482-10a(l)(1)

Identification of all parts of the closed vent system that are designated as unsafe to inspect, an explanation
of why the equipment is unsafe to inspect, and the plan for inspecting the equipment.

60.482-10a(l)(2)

Identification of all parts of the closed vent system that are designated as difficult to inspect, an
explanation of why the equipment is difficult to inspect, and the plan for inspecting the equipment.

60.482-10a(l)(3)

For each inspection during which a leak is detected, a record of the information specified in 60.486a(c).

60.482-10a(l)(4)

For each inspection conducted in accordance with 60.485a(b) during which no leaks are detected, a record
that the inspection was performed, the date of the inspection, and a statement that no leaks were detected.

60.482-10a(l)(5)

For each visual inspection conducted in accordance with paragraph (f)(1)(ii) of this section during which
no leaks are detected, a record that the inspection was performed, the date of the inspection, and a
statement that no leaks were detected.

60.482-10a(m)

Closed vent systems and control devices used to comply with provisions of this subpart shall be operated
at all times when emissions may be vented to them.

Status: In compliance – Closed vent system inspections are completed. Records are maintained.
Closed vent systems are listed on the operator visual inspection checklist and log. The inspections
are recorded and available for review.

40
60.482-11a Standards: Connectors in gas/vapor service and in light liquid service.

Status: In compliance – Holly complies with 60.593(e) for all connectors with an AVO program as
detailed under 60.482.8a above. Note that connectors gas/vapor or light liquid service are exempt
from monitoring per 40 CFR 60 Subpart GGGa.

60.483-1a Alternative standards for valves—allowable percentage of valves leaking.

Status: N/A – Holly has no alternate standards under this program.

60.483-2a Alternative standards for valves—skip period leak detection and repair.

Status: N/A – Holly has no alternate standards under this program.

60.484a Equivalence of means of emission limitation.

Status: N/A – Holly has no alternate standards under this program.

60.485a Test methods and procedures.

60.485a(a)

In conducting the performance tests required in 60.8, the owner or operator shall use as reference methods
and procedures the test methods in appendix A of this part or other methods and procedures as specified
in this section, except as provided in 60.8(b).

60.485a(b)

The owner or operator shall determine compliance with the standards in 60.482–1a through 60.482–11a,
60.483a, and 60.484a as follows:

60.485a(b)(1)

Method 21 shall be used to determine the presence of leaking sources. The instrument shall be calibrated
before use each day of its use by the procedures specified in Method 21 of appendix A–7 of this part. The
following calibration gases shall be used:

60.485a(b)(1)(i)

Zero air (less than 10 ppm of hydrocarbon in air); and

60.485a(b)(1)(ii)

A mixture of methane or n-hexane and air at a concentration no more than 2,000 ppm greater than the
leak definition concentration of the equipment monitored. If the monitoring instrument's design allows for
multiple calibration scales, then the lower scale shall be calibrated with a calibration gas that is no higher
than 2,000 ppm above the concentration specified as a leak, and the highest scale shall be calibrated with
a calibration gas that is approximately equal to 10,000 ppm. If only one scale on an instrument will be
used during monitoring, the owner or operator need not calibrate the scales that will not be used during
that day's monitoring.

41
60.485a(b)(2)

A calibration drift assessment shall be performed, at a minimum, at the end of each monitoring day.
Check the instrument using the same calibration gas(es) that were used to calibrate the instrument before
use. Follow the procedures specified in Method 21 of appendix A–7 of this part, Section 10.1, except do
not adjust the meter readout to correspond to the calibration gas value. Record the instrument reading for
each scale used as specified in 60.486a(e)(7). Calculate the average algebraic difference between the three
meter readings and the most recent calibration value. Divide this algebraic difference by the initial
calibration value and multiply by 100 to express the calibration drift as a percentage. If any calibration
drift assessment shows a negative drift of more than 10 percent from the initial calibration value, then all
equipment monitored since the last calibration with instrument readings below the appropriate leak
definition and above the leak definition multiplied by (100 minus the percent of negative drift/divided by
100) must be re-monitored. If any calibration drift assessment shows a positive drift of more than 10
percent from the initial calibration value, then, at the owner/operator's discretion, all equipment since the
last calibration with instrument readings above the appropriate leak definition and below the leak
definition multiplied by (100 plus the percent of positive drift/divided by 100) may be re-monitored.
60.485a(c)

The owner or operator shall determine compliance with the no-detectable-emission standards in 60.482–
2a(e), 60.482–3a(i), 60.482–4a, 60.482–7a(f), and 60.482–10a(e) as follows:

60.485a(c)(1)

The requirements of paragraph (b) shall apply.

60.485a(c)(2)

Method 21 of appendix A–7 of this part shall be used to determine the background level. All potential
leak interfaces shall be traversed as close to the interface as possible. The arithmetic
difference between the maximum concentration indicated by the instrument and the background level is
compared with 500 ppm for determining compliance.

60.485a(d)

The owner or operator shall test each piece of equipment unless he demonstrates that a process unit is not
in VOC service, i.e., that the VOC content would never be reasonably expected to exceed 10 percent by
weight. For purposes of this demonstration, the following methods and procedures shall be used:

60.485a(d)(1)

Procedures that conform to the general methods in ASTM E260–73, 91, or 96, E168–67, 77, or 92, E169–
63, 77, or 93 (incorporated by reference—see § 60.17) shall be used to determine the percent VOC
content in the process fluid that is contained in or contacts a piece of equipment.

60.485a(d)(2)

Organic compounds that are considered by the Administrator to have negligible photochemical reactivity
may be excluded from the total quantity of organic compounds in determining the VOC content of the
process fluid.

60.485a(d)(3)

42
Engineering judgment may be used to estimate the VOC content, if a piece of equipment had not been
shown previously to be in service. If the Administrator disagrees with the judgment, paragraphs (d)(1)
and (2) of this section shall be used to resolve the disagreement.

60.485a(e)

The owner or operator shall demonstrate that a piece of equipment is in light liquid service by showing
that all the following conditions apply:

60.485a(e)(1)

The vapor pressure of one or more of the organic components is greater than 0.3 kPa at 20 ° C (1.2 in.
H2O at 68 ° F). Standard reference texts or ASTM D2879–83, 96, or 97 (incorporated by reference—see
60.17) shall be used to determine the vapor pressures.

60.485a(e)(2)

The total concentration of the pure organic components having a vapor pressure greater than 0.3 kPa at 20
° C (1.2 in. H2O at 68 ° F) is equal to or greater than 20 percent by weight.

60.485a(e)(3)

The fluid is a liquid at operating conditions.

60.485a(f)

Samples used in conjunction with paragraphs (d), (e), and (g) of this section shall be representative of the
process fluid that is contained in or contacts the equipment or the gas being combusted in the flare.

60.485a(g)

The owner or operator shall determine compliance with the standards of flares as follows:

60.485a(g)(1)

Method 22 of appendix A–7 of this part shall be used to determine visible emissions.

60.485a(g)(2)

A thermocouple or any other equivalent device shall be used to monitor the presence of a pilot flame in
the flare.

43
60.485a(g)(3)

The maximum permitted velocity for air assisted flares shall be computed using the following equation:

Vmax= K1+ K2HT

Where:

Vmax= Maximum permitted velocity, m/sec (ft/sec).

HT= Net heating value of the gas being combusted, MJ/scm (Btu/scf).

K1= 8.706 m/sec (metric units) = 28.56 ft/sec (English units).

K2= 0.7084 m 4 /(MJ-sec) (metric units) = 0.087 ft 4 /(Btu-sec) (English units).

60.485a(g)(4)

The net heating value (HT) of the gas being combusted in a flare shall be computed using the following
equation:

Where:

K = Conversion constant, 1.740 × 10 -7 (g-mole) (MJ)/(ppm-scm-kcal) (metric units) = 4.674 × 10 -6 [(g-
mole) (Btu)/(ppm-scf-kcal)] (English units).

Ci= Concentration of sample component “i,” ppm

Hi= net heat of combustion of sample component “i” at 25 ° C and 760 mm Hg (77 ° F and 14.7 psi),
kcal/g-mole.
60.485a(g)(5)

Method 18 of appendix A–6 of this part or ASTM D6420–99 (2004) (where the target compound(s) are
those listed in Section 1.1 of ASTM D6420–99, and the target concentration is between 150 parts per
billion by volume and 100 ppmv) and ASTM D2504–67, 77, or 88 (Reapproved 1993) (incorporated by
reference-see § 60.17) shall be used to determine the concentration of sample component “i.”

60.485a(g)(6)

ASTM D2382–76 or 88 or D4809–95 (incorporated by reference-see § 60.17) shall be used to determine
the net heat of combustion of component “i” if published values are not available or cannot be calculated.

60.485a(g)(7)

Method 2, 2A, 2C, or 2D of appendix A–7 of this part, as appropriate, shall be used to determine the
actual exit velocity of a flare. If needed, the unobstructed (free) cross-sectional area of the flare tip shall
be used.

44
60.485a(h)

The owner or operator shall determine compliance with 60.483–1a or § 60.483–2a as follows:

60.485a(h)(1)

The percent of valves leaking shall be determined using the following equation:

%VL= (VL/ VT) * 100

Where:

%VL= Percent leaking valves.

VL= Number of valves found leaking.

VT= The sum of the total number of valves monitored.

60.485a(h)(2)

The total number of valves monitored shall include difficult-to-monitor and unsafe-to-monitor valves only
during the monitoring period in which those valves are monitored.

60.485a(h)(3)

The number of valves leaking shall include valves for which repair has been delayed.

60.485a(h)(4)

Any new valve that is not monitored within 30 days of being placed in service shall be included in the
number of valves leaking and the total number of valves monitored for the monitoring period in which the
valve is placed in service.

60.485a(h)(5)

If the process unit has been subdivided in accordance with § 60.482–7a(c)(1)(ii), the sum of valves found
leaking during a monitoring period includes all subgroups.

60.485a(h)(6)

The total number of valves monitored does not include a valve monitored to verify repair.

Status: In compliance – Records confirm that calibrations are completed before each use in the
morning and again at lunchtime prior to afternoon runs. End of day calibrations are also
completed. Calibration gasses used meet the above requirements. Holly does not use skip
monitoring based on percent leaking valves. Component type and constituent determination is
made by engineering methods and testing as approved above.

45
60.486a Recordkeeping requirements.

60.486a(a)

60.486a(a)(1)

Each owner or operator subject to the provisions of this subpart shall comply with the recordkeeping
requirements of this section.

60.486a(a)(2)

An owner or operator of more than one affected facility subject to the provisions of this subpart may
comply with the recordkeeping requirements for these facilities in one recordkeeping system if the system
identifies each record by each facility.

60.486a(a)(3)

The owner or operator shall record the information specified in paragraphs (a)(3)(i) through (v) of this
section for each monitoring event required by 60.482–2a, 60.482–3a, 60.482–7a, 60.482–8a, 60.482–11a,
and 60.483–2a.

60.486a(a)(3)(i)

Monitoring instrument identification.

60.486a(a)(3)(ii)

Operator identification.

60.486a(a)(3)(iii)

Equipment identification.
60.486a(a)(3)(iv)

Date of monitoring.

60.486a(a)(3)(v)

Instrument reading.

60.486a(b)

When each leak is detected as specified in 60.482–2a, 60.482–3a, 60.482–7a, 60.482–8a, 60.482–11a, and
60.483–2a, the following requirements apply:

60.486a(b)(1)

A weatherproof and readily visible identification, marked with the equipment identification number
60.486a(b)(2)

The identification on a valve may be removed after it has been monitored for 2 successive months as
specified in 60.482–7a(c) and no leak has been detected during those 2 months.
46
60.486a(b)(3)

The identification on a connector may be removed after it has been monitored as specified in 60.482–
11a(b)(3)(iv) and no leak has been detected during that monitoring.

60.486a(b)(4)

The identification on equipment, except on a valve or connector, may be removed after it has been
repaired.

60.486a(c)

When each leak is detected as specified in 60.482–2a, 60.482–3a, 60.482–7a, 60.482–8a, 60.482–11a, and
60.483–2a, the following information shall be recorded in a log and shall be kept for 2 years in a readily
accessible location:

60.486a(c)(1)

The instrument and operator identification numbers and the equipment identification number, except
when indications of liquids dripping from a pump are designated as a leak.
60.486a(c)(2)

The date the leak was detected and the dates of each attempt to repair the leak.

60.486a(c)(3)

Repair methods applied in each attempt to repair the leak.
60.486a(c)(4)

Maximum instrument reading measured by Method 21 of appendix A–7 of this part at the time the leak is
successfully repaired or determined to be nonrepairable, except when a pump is repaired by eliminating
indications of liquids dripping.

60.486a(c)(5)

“Repair delayed” and the reason for the delay if a leak is not repaired within 15 calendar days after
discovery of the leak.

60.486a(c)(6)

The signature of the owner or operator (or designate) whose decision it was that repair could not be
effected without a process shutdown.

60.486a(c)(7)

The expected date of successful repair of the leak if a leak is not repaired within 15 days.

60.486a(c)(8)

Dates of process unit shutdowns that occur while the equipment is unrepaired.

60.486a(c)(9)
47

The date of successful repair of the leak.

60.486a(d)

The following information pertaining to the design requirements for closed vent systems and control
devices described in 60.482–10a shall be recorded and kept in a readily accessible location:

60.486a(d)(1)

Detailed schematics, design specifications, and piping and instrumentation diagrams.

60.486a(d)(2)

The dates and descriptions of any changes in the design specifications.
60.486a(d)(3)

A description of the parameter or parameters monitored, as required in 60.482–10a(e), to ensure that
control devices are operated and maintained in conformance with their design and an explanation of why
that parameter (or parameters) was selected for the monitoring.

60.486a(d)(4)

Periods when the closed vent systems and control devices required in 60.482–2a, 60.482–3a, 60.482–4a,
and 60.482–5a are not operated as designed, including periods when a flare pilot light does not have a
flame.

60.486a(d)(5)

Dates of startups and shutdowns of the closed vent systems and control devices required in 60.482–2a,
60.482–3a, 60.482–4a, and 60.482–5a.

60.486a(e)

The following information pertaining to all equipment subject to the requirements in 60.482–1a to
60.482–11a shall be recorded in a log that is kept in a readily accessible location:

60.486a(e)(1)

A list of identification numbers for equipment subject to the requirements of this subpart.
60.486a(e)(2)

60.486a(e)(2)(i)

A list of identification numbers for equipment that are designated for no detectable emissions under the
provisions of 60.482–2a(e), 60.482–3a(i), and 60.482–7a(f).

60.486a(e)(2)(ii)

The designation of equipment as subject to the requirements of 60.482–2a(e), 60.482–3a(i), or 60.482–
7a(f) shall be signed by the owner or operator. Alternatively, the owner or operator may establish a
mechanism with their permitting authority that satisfies this requirement.
48

60.486a(e)(3)

A list of equipment identification numbers for pressure relief devices required to comply with 60.482–4a.

60.486a(e)(4)

60.486a(e)(4)(i)

The dates of each compliance test as required in 60.482–2a(e), 60.482–3a(i), 60.482–4a, and 60.482–
7a(f).
60.486a(e)(4)(ii)

The background level measured during each compliance test.

60.486a(e)(4)(iii)

The maximum instrument reading measured at the equipment during each compliance test.

60.486a(e)(5)

A list of identification numbers for equipment in vacuum service.

60.486a(e)(6)

A list of identification numbers for equipment that the owner or operator designates as operating in VOC
service less than 300 hr/yr in accordance with 60.482–1a(e), a description of the conditions under which
the equipment is in VOC service, and rationale supporting the designation that it is in VOC service less
than 300 hr/yr.

60.486a(e)(7)

The date and results of the weekly visual inspection for indications of liquids dripping from pumps in
light liquid service.

60.486a(e)(8)

Records of the information specified in paragraphs (e)(8)(i) through (vi) of this section for monitoring
instrument calibrations conducted according to sections 8.1.2 and 10 of Method 21 of appendix A–7 of
this part and 60.485a(b).

60.486a(e)(8)(i)

Date of calibration and initials of operator performing the calibration.

60.486a(e)(8)(ii)

Calibration gas cylinder identification, certification date, and certified concentration.

60.486a(e)(8)(iii)

Instrument scale(s) used.
49

60.486a(e)(8)(iv)

A description of any corrective action taken if the meter readout could not be adjusted to correspond to
the calibration gas value in accordance with section 10.1 of Method 21 of appendix A–7 of this part.

60.486a(e)(8)(v)

Results of each calibration drift assessment required by 60.485a(b)(2) (i.e., instrument reading for
calibration at end of monitoring day and the calculated percent difference from the initial calibration
value).

60.486a(e)(8)(vi)

If an owner or operator makes their own calibration gas, a description of the procedure used.

60.486a(e)(9)

The connector monitoring schedule for each process unit as specified in 60.482–11a(b)(3)(v).

60.486a(e)(10)

Records of each release from a pressure relief device subject to 60.482–4a.

60.486a(f)

The following information pertaining to all valves subject to the requirements of 60.482–7a(g) and (h), all
pumps subject to the requirements of 60.482–2a(g), and all connectors subject to the requirements of
60.482–11a(e) shall be recorded in a log that is kept in a readily accessible location:

60.486a(f)(1)

A list of identification numbers for valves, pumps, and connectors that are designated as unsafe-to-
monitor, an explanation for each valve, pump, or connector stating why the valve, pump, or connector is
unsafe-to-monitor, and the plan for monitoring each valve, pump, or connector.

60.486a(f)(2)

A list of identification numbers for valves that are designated as difficult-to-monitor, an explanation for
each valve stating why the valve is difficult-to-monitor, and the schedule for monitoring each valve.

60.486a(g)

The following information shall be recorded for valves complying with 60.483–2a:

60.486a(g)(1)

A schedule of monitoring.

60.486a(g)(2)

The percent of valves found leaking during each monitoring period.
50

60.486a(h)

The following information shall be recorded in a log that is kept in a readily accessible location:

60.486a(h)(1)

Design criterion required in 60.482–2a(d)(5) and 60.482–3a(e)(2) and explanation of the design criterion;
and

60.486a(h)(2)

Any changes to this criterion and the reasons for the changes.
60.486a(i)

The following information shall be recorded in a log that is kept in a readily accessible location for use in
determining exemptions as provided in 60.480a(d):

60.486a(i)(1)

An analysis demonstrating the design capacity of the affected facility,

60.486a(i)(2)

A statement listing the feed or raw materials and products from the affected facilities and an analysis
demonstrating whether these chemicals are heavy liquids or beverage alcohol, and
60.486a(i)(3)

An analysis demonstrating that equipment is not in VOC service.

60.486a(j)

Information and data used to demonstrate that a piece of equipment is not in VOC service shall be
recorded in a log that is kept in a readily accessible location.

60.486a(k)

The provisions of 60.7(b) and (d) do not apply to affected facilities subject to this subpart.

Status: In compliance – The Guideware system, which tracks LDAR information records the
instrument used and calibration data. The operator loads a preset route and clicks on the valve to
be tested and this is recorded along with all readings. The route and reading information are
downloaded each day into Guideware and this information is kept for five plus years. If a leak is
found the operator places the leak tag and records the required information. The VOC monitor
technician is aware of the requirements for removing the tag. All delay of repairs are signed off by
the area specialist. A connector monitoring schedule is not required as connectors are exempt per
40 CFR 60 Subpart GGGa. Records are maintained on-site and were available for review.

51
60.487a Reporting requirements.

60.487a(a)

Each owner or operator subject to the provisions of this subpart shall submit semiannual reports to the
Administrator beginning 6 months after the initial startup date.

60.487a(b)

The initial semiannual report to the Administrator shall include the following information:

60.487a(b)(1)

Process unit identification.

60.487a(b)(2)
Number of valves subject to the requirements of 60.482–7a, excluding those valves designated for no
detectable emissions under the provisions of 60.482–7a(f).

60.487a(b)(3)

Number of pumps subject to the requirements of 60.482–2a, excluding those pumps designated for no
detectable emissions under the provisions of 60.482–2a(e) and those pumps complying with 60.482–2a(f).

60.487a(b)(4)

Number of compressors subject to the requirements of 60.482–3a, excluding those compressors
designated for no detectable emissions under the provisions of 60.482–3a(i) and those compressors
complying with 60.482–3a(h).

60.487a(b)(5)

Number of connectors subject to the requirements of 60.482–11a.

60.487a(c)

All semiannual reports to the Administrator shall include the following information, summarized from the
information in 60.486a:

60.487a(c)(1)

Process unit identification.

60.487a(c)(2)

For each month during the semiannual reporting period,

60.487a(c)(2)(i)

Number of valves for which leaks were detected as described in 60.482–7a(b) or 60.483–2a,

60.487a(c)(2)(ii)
52
Number of valves for which leaks were not repaired as required in 60.482–7a(d)(1),

60.487a(c)(2)(iii)

Number of pumps for which leaks were detected as described in 60.482–2a(b), (d)(4)(ii)(A) or (B), or
(d)(5)(iii),

60.487a(c)(2)(iv)

Number of pumps for which leaks were not repaired as required in 60.482–2a(c)(1) and (d)(6),

60.487a(c)(2)(v)
Number of compressors for which leaks were detected as described in 60.482–3a(f),

60.487a(c)(2)(vi)

Number of compressors for which leaks were not repaired as required in 60.482–3a(g)(1),

60.487a(c)(2)(vii)

Number of connectors for which leaks were detected as described in 60.482–11a(b)

60.487a(c)(2)(viii)

Number of connectors for which leaks were not repaired as required in 60.482–11a(d), and

60.487a(c)(2)(ix)-(x)

[Reserved]

60.487a(c)(2)(xi)

The facts that explain each delay of repair and, where appropriate, why a process unit shutdown was
technically infeasible.

60.487a(c)(3)

Dates of process unit shutdowns which occurred within the semiannual reporting period.
60.487a(c)(4)

Revisions to items reported according to paragraph (b) of this section if changes have occurred since the
initial report or subsequent revisions to the initial report.

60.487a(d)

An owner or operator electing to comply with the provisions of 60.483–1a or 60.483–2a shall notify the
Administrator of the alternative standard selected 90 days before implementing either of the provisions.

60.487a(e)

An owner or operator shall report the results of all performance tests in accordance with 60.8 of the
General Provisions. The provisions of 60.8(d) do not apply to affected facilities subject to the provisions
53
of this subpart except that an owner or operator must notify the Administrator of the schedule for the
initial performance tests at least 30 days before the initial performance tests.

60.487a(f)

The requirements of paragraphs (a) through (c) of this section remain in force until and unless EPA, in
delegating enforcement authority to a state under section 111(c) of the CAA, approves reporting
requirements or an alternative means of compliance surveillance adopted by such state. In that event,
affected sources within the state will be relieved of the obligation to comply with the requirements of
paragraphs (a) through (c) of this section, provided that they comply with the requirements established by
the state.

Status: In compliance – Quarterly and Semi-annual reports for R307-326, GGGa, VV, and VVa
(also consent decree) are submitted to the DAQ. All required information is included. No alternate
standards are in effect. Performance test reports are submitted to the DAQ.

60.488a Reconstruction.

For the purposes of this subpart:

60.488a(a)

The cost of the following frequently replaced components of the facility shall not be considered in
calculating either the “fixed capital cost of the new components” or the “fixed capital costs that would be
required to construct a comparable new facility” under 60.15: Pump seals, nuts and bolts, rupture disks,
and packings.

60.488a(b)

Under 60.15, the “fixed capital cost of new components” includes the fixed capital cost of all depreciable
components (except components specified in 60.488a(a)) which are or will be replaced pursuant to all
continuous programs of component replacement which are commenced within any 2-year period
following the applicability date for the appropriate subpart. (See the “Applicability and designation of
affected facility” section of the appropriate subpart.) For purposes of this paragraph, “commenced” means
that an owner or operator has undertaken a continuous program of component replacement or that an
owner or operator has entered into a contractual obligation to undertake and complete, within a reasonable
time, a continuous program of component replacement.

Status: This is not an inspection item. This is addressed under the NOI process.

60.489a List of chemicals produced by affected facilities.

Process units that produce, as intermediates or final products, chemicals listed in 60.489 are covered
under this subpart. The applicability date for process units producing one or more of these chemicals is
November 8, 2006.

Status: Holly is an affected source.

54
NSPS (Part 60), GGG: Standards of Performance for Equipment Leaks of VOC in Petroleum
And 40 CFR 60 Subpart VV - Standards of Performance for Equipment Leaks of VOC in the
Synthetic Organic Chemicals Manufacturing Industry for which Construction, Reconstruction, or
Modification Commenced After January 5, 1981, and on or Before November 7, 2006.

Status: In compliance – Subpart GGG and VV mirror Subpart GGGa and VVa, except it is for
pre-2006 facilities. Holly applies the 500-ppm limit set in Subpart GGGa and VVa to all its
facilities.

Utah State Implementation Plan Section IX, Part H

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

g. Petroleum Refineries

iv. Leak Detection and Repair Requirements.

A. Each owner or operator shall comply with the requirements of 40 CFR 60.590a to 60.593a no later
than January 1, 2016.

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.

Status: In compliance – Holly complies with 40 CFR 60.590a to 593a (see Subpart GGGa above).
Holly does not use Sustainable Skip monitoring.

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

55
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: Holly Refinery should be found in compliance with the applicable
portions of 40 CFR 63 Subpart A, 40 CFR 63 Subpart CC, UAC
R307-326, and 40 CFR 60 Subparts GGG, VV, GGGa, VVa, and the SIP
at the time of this 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