Loading...
HomeMy WebLinkAboutDAQ-2024-008513m\E@" UTAH DEPAHTMENT OF E}W]RONMENTAL OUA.TTY ljtrrbotyrdl.ly Tesoro Refining & Marketing Company LLCAPH 3 0 20?_4 April30,2024 Bryce Bird, Director Utah Division of Air Quality 195 North 1950 West P.O. Box 144820 Salt Lake city, uT 84114-4820 Hanct belirtereai DMSION OF AIR QUAL]TY HaNo Delrvrnpo Re: New Source Performance Standard (NSPS)" Subpart Ja - October l. 2023 - March 30. 2024 Dear Mr. Bird: Attached is Tesoro Refining & Marketing Company, LLC's NSPS Subpart Ja semi-annualreport as required by 40 CFR 60.108a(d) and 40 CFR 60.7(c) for the Salt Lake City (SLC) Refinery. This report addresses operations from October 1,2023 through March 30,2024 for the following sources: o Allaffected refinery flares, including the North Refinery Flare, South Refinery Flare and the Sulfur Recovery Unit (SRU) Flare. o The refinery fuel gas system and Cogeneration Turbine & Heat Recovery Steam Generation (HRSG) Systems, in accordance with the Utah PMz s SIP Subsection IX.H.l, which has been approved by UDAQ.o The Fluidized Catalytic Cracking Unit (FCU), CO Boiler, Electrostatic Precipitator (ESP), and Wet Gas Scrubber (WGS) for SOz, NOx, CO and PM, in accordance with refinery's Approval Order DAQE-AN103350075-l 8 issued by UDAQ. Refinery Flares: The North and South refinery flares are served by a common Flare Cas Recovery System (FGRS). These two flares serve all process units in the refinery, except for the SRU and the Tailgas Treatment Unit; these two process units are served by a dedicated SRU Flare. These three flares have been modified under $60.100a(c)( I ) and are therefore subject to NSPS Subpart Ja. This report addresses the following Work Practice Standards at $60.103a(h), $60.103a(c)(l)(i), and $60.103a(c)(l)(ii) as applicable forthe refinery's North, South, and SRU Flares during the reporting period. Due to a shared FGRS, Tesoro is complying with the SOz work practice standard in $60.103a(cXl)(i) at the North and South Flares by comparing cumulative SOz emissions from both flares to the 500 lb SOz Root Cause Analysis (RCA) and Corrective Action Analysis (CAA) applicability trigger. Similarly, Tesoro is complying with the Work Practice Standard at $60.103a(c)(l)(ii) by comparing cumulative flare gas sent to the two flares against the RCA/CAA applicability trigger of 500,000 scf/24-hour period in excess of the baseline scenarios identified in the refinery's NSPS Subpart Ja Flare Management Plan. Tesoro is complying with the Work Practice Standard at $60.103a(h) by using a total sulfur analyzer in lieu of a HzS analyzer at the SRU Flare, in accordance with $60.107a(a)(2)(v). B-2-10335 The refinery most recently submitted an update to its NSPS Subpart Ja Flare Management Plan to USEPA on August 28,2022. In accordance with $60.103a(b)(2), Tesoro has operated in accordance with the latest updated plan during the reporting period. During the reporting period, there were no exceedances of the 500 lb SOZl24-hour period Work Practice Standard at $60. I 03a(c)( t )(i). There was one flaring event that exceeded the 500,000 scf/24-hour period Work Practice Standard at $60.103a(c)(lXii), based on observed cumulative gas flared concurrently from the North and South flares or SRU flare. This flare event is presented in the attached report and was a result of a planned plantwide turnaround. Determination of flaring events that exceeded the 500,000 scf/24-hour period Work Practice Standard at $60.103a(c)( I )(ii) consider applicable alternative operating scenarios established pursuant to $60. I 03a(aXaXii). Details of any exceedances of the HzS 3-hour rolling average limit are included in the quarterly State Electronic Data Reports. Refinery FuelGas System: Tesoro is also subject to requirements within NSPS Subpart Ja for the V-917 refinery fuel gas balance drum. In accordance with the UDAQ-approved Utah PMz s Moderate Non-Attainment State Implementation Plan (SIP) Section IX.H.l I (g)(ii), which applies to petroleum refineries, Tesoro shall comply with specified applicable requirements within NSPS Subpart Ja for HzS content within refinery fuel gas. There were no exceedances of the 365-day rolling average limit during the reporting period. Details of any exceedances of the HzS 3-hour rolling average limit are included in the quarterly State Electronic Data Reports for the 4th Quarter 2023 and I't Quarter 2024. Cogeneration Turbine & HRSG Systems: Tesoro has interpreted from the Utah PMz s Moderate Non-Attainment SIP that the East and West Cogeneration Turbines are subject to the same aforementioned provisions as the V-917 fuel gas system. Furthermore, SIP condition IX.H.l2(p)(iii)(c) applies specifically to the East and West Cogeneration Turbines and allow use of a SOz/Oz or HzS CEMS. Each turbine fires a mixture of utility natural gas and sweet fuel gas, generated from amine treating of sour fuel gas in the SRU. This fuel gas differs in composition from that in the V-917 refinery fuel gas balance drum. In addition, downstream of each turbine, a HRSG system is installed for steam production using the turbine exhaust flue gas and additional refinery fuel gas from V-917. Tesoro operates a HzS Continuous Emissions Monitoring System (CEMS) to measure the mixture of natural gas and fuel gas fired at the Cogen turbine sections; both Cogen process trains (i.e. East and West) fire the same mixture of fuel, therefore the monitoring is achieved with one analyzer. As noted previously, the refinery fuel gas fired at the HRSGs is monitored with the HzS CEMS installed on the V-917 fuel gas drum. Therefore, Tesoro is complying with the existing HzS standard in SIP Section IX.H. I I (e)(ii) and condition IX.H. I 2(pXiii)(c) by complying with $60. I 02a(g)( I Xii) for each fuel gas mixture. This monitoring approach was conducted in accordance with the Custom Fuel Monitoring Schedule Update to NSPS Subparts JlJaand GG, approved by EPA Region 8 on April 5, 201 8. There were no exceedances of the HzS 365-day rolling average limit within $60.102a(g)(lXii) from the East and West Cogeneration trains during the reporting period. Details of any exceedances of the HzS 3- hour rolling average limit within $60.102a(g)(lXii) have been included in the State Electronic Data Reports for the 4th Quarter 2023 and l't Quarter 2024. FCU Regenerator/CO Boiler/ESP/WGS : Tesoro is subject to requirements within NSPS Subpart Ja for the FCU affected facility, consisting of the FCU Regenerator, CO Boiler, ESP, and WGS. Effective January l, 2018, this equipment is regulated by Subpart Ja for PM, CO, and SOz. Stack testing was conducted to establish operating limits at the Regenerator, ESP, and Wet Gas Scrubber for PM on April 8,2023; the most recent operating limits became effective on May 3,2023. Details of any exceedances of the applicable CO limit (corrected to 0% Oz) within $60.102a(b)(4) for the FCU Regenerator/CO Boiler/ESP/WGS during the reporting period have been included in the State Electronic Data Reports for the 4th Quarter 2023 and l't Quarter 2024. During the aforementioned reporting period, any deviations from allowable operating limits within $60.102a(c)( I Xi) and $60.102a(c)(lXii) for the FCU Regenerator/CO Boiler/ESP/WGS are included in the summary report tables and attachment tables (if applicable). Alignment with State Ouarterly Reports: Monitoring system performance for all regulated CEMS and Continuous Parametric Monitoring Systems (CPMS) at the North Flare (HzS, Flow and Total Sulfur), South Flare (HzS, FIow and Total Sulfur), SRU Flare (Flow and Total Sulfur), FCU WGS (SOz, NOx, CO and O2), FCU CO Boiler Bypass Stack (SOz, NOy, CO, and Ou) Y-917 FuelGas Balance Drum (HuS), East and West Cogeneration Turbine and HRSG trains (shared HzS) required by NSPS Subpart Ja are reported per $60.7(c) with the State Electronic Data Reports. These reports also address all CEMS QA/QC practices, including initial certification testing (i.e. 7-day drift test and initial Relative Accuracy Test Audits) and on-going Cylinder Gas Audits (CGAs) and RATAs. Tesoro submitted reports for 4'r' Quarter 2023 and I't Quarter 2024. QAIQC downtime for the CPMS for purposes ofNSPS Subpart Ja at the FCU Regenerator/CO Boiler/ESPAVGS, including Total Power, Secondary Current, WGS Differential Pressure, WGS L/G Ratio and Total Coke-Burn are included in this report. Certifi cation Statement: I certifu that this information was prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my directions and my inquiry of the person(s) who manage the system, or the person(s) directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. Please call Chris Kaiser at (801) 521-4959 if you have any questions. Sincerely,M Dean P. Anderson Vice President Tesoro Refining & Marketing Company LLC Attachments cc: USEPA Region VIII SusN4rrreo Vra CouRren Subpart Ja Summary Report ((40 CFR 60.7(c), 40 CFR 60.108a(d)(1-7)) tll Signed statement, if applicable, is included on the verification sheet. Unit: North Refinery Flare (Served by Shared Flare Gas Recovery with South Flare) Parameter: Hydrogen Sulfide (HzS) Reporting Period: October 1,2023 - March 30,2024 Work Practice 162 ppmvd HzS,3-hour Standard: rolling average Periods of Deviation from Work Practice Standardttl: See submitted State Electronic Data 4b Quarter 2023 and I't Quarter 2024 Periods for which HzS monitoring data are not availabletrl: See submitted State Electronic Data Reports 4th Quarter 2023 and l't Quarter 2024 Subpart Ja Summary Report ((40 CFR 60.7(c), 40 CFR 60.108a(d)(1-7)) tll Signed statement, if applicable, is included on the verification sheet. Unit: South Refinery Flare (Served by Shared Flare Gas Recovery with North Flare) Parameter: HzS Reporting Period [rl: October 1,2023 - March 30,2024 Work Practice 162 ppmvd HzS, 3-hour Standard: rolling average Periods of Deviation from Work Practice Standardtrl: See submitted State Electronic Data Reports 4th Quarter 2023 and l't Quarter 2024 Periods for which HzS monitoring data are not available trl: See submitted State Electronic Data Reports 4th Quarter 2023 and I't Quarter 2024 Subpart Ja Summary Report ((10 CFR 60.7(c), 40 CFR 60. l08a(d)(l-7)) Unit: North and South Refinery Flares (Served by Shared Flare Gas Recoverv) Parameter: Sulfur Dioxide (SOz) Reporting Period: October 1,2023 - March 30,2024 Work Practice 500 lb SOz/24-hour Standards: period, or 500,000 scf flared above baseline flare flow ltUz4-hour period. Each standard applies as sum from both flares. Periods of Deviation from Work Practice Standards tl'21: Events identified below (SO2 and/or flare flow)[3]: Event #l - flare flow: 2l 13124 I 6:00 till 3 128124 2l:00 Periods for which Total Sulfur (TS) and flare flow monitoring data are not available t2l: See submitted State Electronic Data Reports 4th Quarter 2023 and I't Quarter 2024 t1l In accordance with 40 CFR 60.103a(c)(l)(ii), the work practice standard is set at 500,000 scf in excess of the baseline flow reported in the NSPS Ja Flare Management Plan. The baseline flow to the north and south flares is 0 scf/hr during normal operations. Therefore, the work practice standard is set at 500,000 scf per 24-hour period during normal operations. Four alternative baseline scenarios are identified in the NSPS Ja Flare Management Plan and the work practice standard is set at 500,000 scf above the applicable alternative baseline per 24- hour period only during the applicable scenario. t2) Signed statement, if applicable, is included on the verification sheet. t3l Time period indicate entire period 24-hour average remained over threshold. Subpart Ja Summary Report ((40 CFR 60.7(c), 10 CFR 60.108a(d)(1-7)) NSPS Ja Flare RCA and CAA Summary per $$60.108a(dX5) and (cX6) Section 1.' Background Information (Complete Sections I through 3 for each 24-hour period ofdischarge)r Refinery Name: Tesoro Refining and Marketing Company LLC, Salt Lake City Refinery Refinery Address: 474 West 900 North, Salt Lake City, UT 84103 Contact Report Date: 412124 Telephone: (801)521-4959 Contact E-mail Report Contact: Chris Kaiser Address: cUt<aiser@maratno Report Type (lnitial/Follow-up) I4!!i41 If Follow-up, list dates of previous report(s):N/A Section 2: Event Description Emission Source (flare): North and South Flare Description of flaring event2: Event #l : Ql2024 TAR planned plantwide outage Incident Start Date3: 211312024 Time (24-hour clock) 3: l6:00 Incident End Date3: 312812024 Time (24-hour clock) 3: 21 :00 If Planned Startup/Shutdown, were Flare Management Plan (FMP) procedures Yes, FMP procedures followed? (YNf were followed. This was a planned, plant- wide turnaround. (lf incident was due to a planned startup/shutdown and FMP procedures were followed, no Root Cause Analysis or Corrective Action description is necessary, do not complete Sections 3 and 4 of this report form.)a lf incident was not due to planned startup or shutdown, provide a brief explanation of event.a Event was a planned plant-wide turnaround. These events are scheduled approximately every three years. Daily flaring exceeded 500 Mscf intermittently during this period. r40 CFR 60. l08a(c)(6) 240 CFR 60. l08a(c)(6)(i) 340 CFR 60. l08a(c)(6)(ii) 440 CFR 60. l08a(c)(6)(xi) Subpart Ja Summary Report ((40 CFR 60.7(c), 40 CFR 60.108a(d)(1-7)) Cumulative quantity of gas discharged during this 24-hour period (scf;s: 22,487.5 Mscf over 44 days (or 509 Mscf daily average) Was the cumulative quantity of gas discharged >500,000 scf over baseline during this 24-hour period? (Y/)rl)s: (500,000 scf for the North & South Flares since the baseline is 0 scf, 528,800 scf for the SRU Flare since the baseline is 28,800 scO Yes Did SOz emissions exceed 500 lb during this 24-hour period? 6'7 lf yes, List cumulative quantity of SOz emissions during each 24-hour period (lb, assumin g 99% sulfur conversion)7: And List cumulative quantity of HzS emissions during each 24-hour period (lb, assuming 1o% uncombusted)7: And List total sulfur concentration (ppmvd) ar HzS and estimated total sulfur in fuel during each 24-hour period that exceeded that threshold (ppmv/ppmv)6: No N/A N/A N/A Steps taken to limit the emissions during the discharge8: Flare Management Plan procedures were followed. Note that the reported cumulative quantity of gas includes inert constituents. For example, the time weighted average hydrogen content of the flare gas during this event was 32 mol%o. The flare volume reported against facility Consent Decree flare caps was considerably lower during this event. 540 CFR 60. l08a(c)(6) & (6)(iii) 640 CFR 60. l08a(c)(6)(iv) 740 CFR 60. 108a(c)(6)(vii) 840 CFR 60. l08a(c)(6)(viii) Section 3: Root Cause Analysisro (complete within 45 days of triggering event) Description of root cause analysis: N/A. Planned startup/Shutdown and FMP measures were followed. Was cause same as that identified in a previous flaring incident?ro (YN) N/A lf yes, identifo previous incident date(s): ro40 CFR 60. I 08a(cX6Xix) N/A Subpart Ja Summary Report ((10 CFR 60.7(c), 40 CFR 60.108a(d)(1-7)) Section 4: Corrective Action Analysisrr (Complete within 45 days of triggering event): N/A. Planned startup/Shutdown and FMP measures were followed. Planned for completion more than 45 days after triggering event: Corrective Action(s)Schedule for Completion N/A N/A ' '40 CFR 60. l08a(c)(6)(x) & (ix) Subpart Ja Summary Report ((40 CFR 60.7(c), 40 CFR 60.108a(d)(I-7)) []: In accordance with 40 CFR 60.107a(a)(2Xv), a total sulfur monitor is used in lieu of a hydrogen sulfide monitor. tzl Signed statement, if applicable, is included on the verification sheet. Unit: SRU Flare (no Flare Gas Recovery) Parameter: HrS Reporting Period: October 1,2023 - March 30,2024 Work Practice 162 ppmvd TS as HzS, Standardttl: 3-hour rolling average Periods of Deviation from Work Practice Standardtrl: See submitted State Electronic Data Reports 4th Quarter 2023 and 1't Quarter 2024 Periods for which TSt'l monitoring data are not availablet2l: See submitted State Electronic Data Reports 4h Quarter 2023 and I't Quarter 2024 Subpart Ja Summary Report ((40 CFR 60.7(c), 40 CFR 60.108a(d)(1-7)) Unit: SRU Flare (no Flare Gas Recovery) Parameter: SOz Reporting Period: October 1,2023 - March 30,2024 Work Practice 500 lb SOz/24-hour Standard: period, or 500,000 scf flared above baseline flare flowtrl/24-hour period. Periods of Deviation from Work Practice Standardst2l: Event identified below (SOz and/or flare flow): None during reporting period. Periods for which TS and flare flow monitoring data are not availablet2l : See submitted State Electronic Data Reports 4th Quarter 2023 and I't Quarter 2024 []: In accordance with 40 CFR 60.103a(c)(l)(ii), the work practice standard is set at 500,000 scf in excess of the baseline flow reported in the NSPS Ja Flare Management Plan. The baseline flow to the SRU Flare is 28,800 scf/hr. Therefore, the work practice standard is set at 528,800 scf per 24-how period. l2): Signed statement, if applicable, is included on the verification sheet. Unit: Y-917 Refinery Fuel Gas Balance Drum Parameter: HrS Reporting Period: October 1,2023 - March 30,2024 Emissions Limit: 162 ppmvd HzS, 3-hour Rolling Average Periods of Excess Emissionstrl See submitted State Electronic Data Reports 4th Quarter 2023 and 1't Quarter 2024 Periods for which HzS monitoring data are not availabletll: See submitted State Electronic Data Reports 4th Quarter 2023 and I't Quarter 2024 Reporting Period: October 1,2023 - March 30,2024 Emissions Limit: 60 ppmvd HzS, 365-day Rolling Averase Periods of Excess Emissionstrl No excess emissions during the reporting period For each Excess Emissions event: Explanation of the Exceedance: No excess emissions during the reporting period Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected facility or control system: No excess emissions during the reporting period A description of the action taken, if any:No excess emissions during the reporting period Periods for which HzS monitoring data are not lvailabletrl: See submitted State Electronic Data Reports 4th Quarter 2023 and I't Quarter 2024 []: Signed statement, if applicable, is included on the verification sheet. Unit: East Cogen & West Cogen Turbines Parameter: HrS Reporting Period: October 1,2023 - March 30,2024 Emissions Limit: 162 ppmvd HzS, 3-hour Rolling Averase Periods of Excess EmissionsU See submitted State Electronic Data Reports 4th Quarter 2023 and I't Quarter 2024 Periods for which HzS monitoring data are not availabletrl: See submitted State Electronic Data Reports 4th Quarter 2023 and l"t Quarter 2024 Reporting Period: October 1,2023 - March 30,2024 EmissionsLimit: 5:i-ooilfl5ii;*a',,..ur" Periods of Excess Emissionstrl No excess emissions during the reporting period For each Excess Emissions event: Explanation of the Exceedance: No excess emissions during the reporting period Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected facility or control system: No excess emissions during the reporting period A description of the action taken, if any:No excess emissions during the reporting period []: Signed statement, if applicable, is included on the verification sheet. UNit: FCU _ WGS Parameter: CO Reporting Period: October 1,2023 - March 30,2024 Emissions Limit: 500 ppmvd CO, corrected to 0%o Oz l-hr Block Ar.rus. Periods of Deviation from Emissions Limittrl:See submitted State Electronic Data Reports 4th Quarter 2023 and I't Quarter 2024 Periods for which CO monitoring data are not availabletrl: See submitted State Electronic Data Reports 4th Quarter 2023 and 1't Quarter 2024 [1]: Signed statement, if applicable, is included on the verification sheet. UNit: FCU - ESP Parameter: Total Power Reporting Period: October 1,2023 - March 30,2024 Operating Limitstu: 0 kW 4ll limits as 3-hour ,ollins rveros?. I ) Duration of Excess Emissions in reporting period lue to: l) CMS downtime in reponing period due to: a) Startup/ 0 hr shutdown a) Monitor equipment 0.0 hr malfunctions b) Control equipment 0 hr problems b) Non-Monitorequipment malfunctions hr0.0 hrc) Process Problems hr0.0c) Quality assurance calibration d) Other known causes 0 hr d) Other known causes 0.0 hr e) Unknown causes 0 hr e) Unknown causes 0.0 hr Z) Total duration ofexcess 0 hr :missions: 2) Total CPMS downtime: 0.0 hr 3) Total Ooeratins Hourslrl 3.869 hr 3) Total Ooeratine Hourslrl 3.869 hr 1) Excess Emissions, as 0.0 % )ercentage of operating time :%\ 4) CPMS downtime, as 0.00 % percentage of operating time (%) For each Excess Emissions event: Date ofthe Exceedance:No exceedances during reporting period Explanation of the Exceedance: Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected facility or control system: A description ofthe action taken, ifany: For any periods for which monitoring data are not available, any changes made in operation of the emission control system during the period of data unavailability which could affect the ability of the system to meet the applicable emission limit. Minimum allowable Total Power was zero so no concern with meeting emission limit. []: $60.102a(c)(l)(i) requires for FCUs controlled by an ESP to maintain the 3-hour rolling average total power and secondary current above the level established during the most recent performance test. UNit: FCU - ESP Parameter: Secondary Current Reporting Period: October 1,2023 - March 30,2024 Operating Limitstu: 0 Amps All limits as 3-hour rollino dverase l) Duration of Excess Emissions in reporting period due to: l) CMS downtime in reporting period due to: a) Starhrp/shutdown 0 hr a) Monitor equipment malfunctions 0.0 hr b) Control equipment 0 hr problems: b) Non-Monitorequipment malfunctions 0.0 hr c) Process Problems 0 hr c) Quality assurance calibration 0.0 hr d) Other known causes 0 hr d) Other known causes 0.0 hr e) Unknown causes 0 hr e) Unknown causes 0.0 hr 2) Total duration ofexcess 0 hr emissions: 2) TotalCPMS downtime: 0.0 hr ) Total Ooeratins Hourslrl 3.869 hr 3) Total Operatins Hourslrl 3,869 hr l) Excess Emissions, as 0.0 % )ercentage of operating time (%) 1) CPMS downtime, as 0.00 % )ercentage of operating time '%) For each Excess Emissions event: Date ofthe Exceedance:),lo exceedances during reporting period Explanation of the Exceedance: Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected facilitv or conffol system: A description ofthe action taken, ifany: For any periods for which monitoring data are not available, any changes made in operation of the emission control system during the period of data unavailability which could affect the abiliry of the svstem to meet the aoolicable emission limit. Minimum allowable Secondary Current was zero so no concern with meeting emission limit. []: $60.102a(c)(1)(i) requires for FCUs controlled by an ESP to maintain the 3-hour rolling average total power and secondary current above the level established during the most recent performance test. Unit: FCU Regenerator Parameter: Coke-Burn Reporting Period: October 1,2023 - March 30,2024 OperatingLimitstrl: 20,647lblhr 4ll limits as daily averdge 1) Duration of Excess Emissions in reporting oeriod due to: l) CMS downtime in reporting period due to: a) Startup/ 0 hr shutdown a) Monitor 0.0 hr equipment malfunctions b) Controlequipment 0 hr problems: b) Non-Monitor 0.0 hr equipment malfunctions c) Process Problems 0 hr c) Quality assurance 0.0 hr calibration d) Other known 0 hr causes d) Other known 0.0 hr causes e) Unknown causes 0 hr e) Unknown causes 0.0 hr 2) Total duration of 0 hr 3xcess emissions: 2) Total CPMS 0.0 hr Jowntime: 3) Total Operating 3,869 hr Hourstll 3) Total Operating 3,869 hr Hourstll 1) Excess Emissions, as 0.0 % cercentage of operating time (%o\ 1) CMS downtime, as 0.00 % percentage of operating time (%) For each Excess Emissions event: Date ofthe Exceedance:No exceedances during reporting period Explanation of the Exceedance: Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected facilitv or control system: A description ofthe action taken, ifany: For any periods for which monitoring data are not available, any changes made in operation of the emission control system during the period of data unavailability which could affect the ability of the system to meet the applicable emission limit. No downtime during reporting period []: $60.102a(c)(lxii) requires the daily average exhaust coke bum-off rate not exceed the level established during the most recent performance test. Jnit: WGS Parameter: Differential Pressure R.eporting Period: October 1,2023 - March 30,2024 Operating Limitstrl 4.9 in HzO All limits as 3-hour rollins cNerase l) Duration of Excess Emissions in reporting oeriod due to: l) CMS downtime in reporting period due to: a) Startup/ 0 hr shutdown a) Monitor equipment 0.0 hr malfunctions b) Control equipment 0 hr problems b) Non-Monitor equipment 0.0 hr malfunctions c) Process Problems 0 hr c) Quality assurance 0.0 hr calibration d) Other known causes 0 hr d) Other known causes 0.0 hr e) Unknown causes 0 hr e) Unknown causes 0.0 hr Z) Total duration ofexcess 0 hr :missions: 2) TotalCPMS downtime: 0.0 hr ]) Total Ooeratins Hourstrl 3.869 hr 3) Total Ooeratins Hourstrl 3.869 hr [) Excess Emissions, as 0.0 % rercentage of operating time,%\ 4) CPMS downtime, as 0.00 % percentage of operating time (o/n\ For each Excess Emissions event: Date ofthe Exceedance:No exceedances during reporting period Explanation of the Exceedance: Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected facility or control system: A description of the action taken, if any: For any periods for which monitoring data are rot available, any changes made in operation of :he emission control system during the period of lata unavailability which could affect the ability rf the system to meet the applicable emission timit. No downtime during reporting period []: Operating limits for DP were established during performance testing. Operating limits determined by this testing are included in this Semiannual Report, and these limits are effective upon submittal of the report to UDAQ. Jnit: WGS Parameter: L/G Ratio Reporting Period: October 1,2023 - March 30,2024 Operating Limitstrl 62.9 gal/lvlscf All limits as 3-hour rollins cverase l) Duration of Excess Emissions in reporting oeriod due to: I ) CMS downtime in reporting period due to: a) Startup/ 0 hr shutdown a) Monitor equipment 0.0 hr malfunctions b) Control equipment 0 hr oroblems b) Non-Monitor equipment 0.0 hr malfunctions c) Process Problems 0 hr c) Quality assurance 0.0 hr calibration d) Other known causes 0 hr d) Other known causes 0.0 hr e) Unknown causes 0 hr e) Unknown causes 0.0 hr 2) Total duration of excess 0 hr :missions: 2)Total CPMS downtime: 0.0 hr l) Total Operatins Hourstrl 3.869 hr 3) Total Operatins Hourstrl 3"869 hr 1) Excess Emissions, as 0.0 % rercentage of operating time ,YO\ 4) CPMS downtime, as 0.00 % percentage of operating time (%\ or each Excess Emissions event: Date ofthe Exceedance:No exceedances during reporting period Explanation of the Exceedance: Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected facility or control system: A description of the action taken, if any: ior any periods for which monitoring data are rot available, any changes made in operation of :he emission control system during the period of lata unavailability which could affect the ability )f the system to meet the applicable emission imit. No downtime during reporting period []: Operating limits for DP were established during performance testing. Operating limits determined by this testing are included in this Semiannual Report, and these limits are effective upon submittal of the report to UDAQ. UTAH DEPARTMENT ENVIRONMENTAL QUALITY DIVISION OF AIR OUALITY