HomeMy WebLinkAboutDAQ-2024-0108791
DAQC-1011-24
Site ID 10122 (B1)
MEMORANDUM
TO: FILE – BIG WEST OIL (Waste Water Drains)
THROUGH: Harold Burge, Major Source Compliance Section Manager
FROM: Jeremiah R. Marsigli, Environmental Scientist
DATE: October 4, 2024
SUBJECT: Partial Compliance Evaluation (#2 of 4), Major, Davis County,
FRS #UT0000004901100008
DATE OF INSPECTION: September 12, 2024
SOURCE ADDRESS: 333 West Center Street, North Salt Lake, Utah
SOURCE CONTACTS: E. Faithe Schwartzengraber, Environmental Manager, (801) 296-7763
Ian Muller, Environmental Engineer, (801) 296-7716
Brady Miller, Environmental Engineer, (385) 324-1275
OPERATING STATUS: Operating normally
PROCESS DESCRIPTION: Flying J is a petroleum refinery capable of processing 30,000 bbls/day.
This inspection focused on wastewater streams, sumps, and separators.
Wastewater from several sources is ducted to a main line. The process
drains are controlled by P-traps, which have double curved tubes filled
with water to keep the oil-laden water from leaving the openings. Most
of the P-traps are drains to allow removal of oily wastewater. The water
layer is checked daily during refinery rounds and a tap is connected to
allow refilling as needed. The trap water is allowed to run during the
winter to prevent freezing. The oily water is ducted to a series of junction
boxes, which allow several drains to enter into a single out-going line.
The wastewater then goes to one of two sumps/separators (according to
API weight). The sump/separator consists of several chambers, which
allow the oil base to float to the top where it is skimmed off the top by a
scraper and deposited in the end tank area. This oil is later removed by
vacuum truck and either reused in the refinery process or sold as slop.
The junction boxes are controlled by lids with a barrier seal and the API
separators are also controlled by a lid with seals. The lids are opened
only for removal of material or maintenance. All separator lids have hold
down latches. There is a third sump/separator for the heavier oil, which
works the same way and is controlled in the same way as the other
separators.
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APPLICABLE
REGULATIONS: AO dated July 20, 1982 – Separators and Covers
NSPS subpart QQQ, Wastewater Systems
UAC-R307-326
SOURCE INSPECTION
EVALUATION:
R307-326-3. Wastewater (Oil/Water) Systems.
Any wastewater separator handling volatile organic compounds shall be equipped with:
(1) covers and seals approved by the executive secretary on all separators and fore bays,
(2) lids or seals on all openings in covers, separators, and fore bays. Such lids or seals shall be in
the closed position at all times except when in actual use.
Status: In compliance. The wastewater separator system is equipped with the required
covers, seals, and lids, which were closed during this inspection.
Subpart QQQ-Standards of Performance for VOC Emissions From Petroleum Refinery Wastewater
Systems
60.690 Applicability and designation of affected facility.
(a)(1) The provisions of this subpart apply to affected facilities located in petroleum refineries for
which construction, modification, or reconstruction is commenced after May 4, 1987.
(2) An individual drain system is a separate affected facility.
(3) An oil-water separator is a separate affected facility.
(4) An aggregate facility is a separate affected facility.
(b) Notwithstanding the provisions of 40 CFR 60.14(e)(2), the construction or installation of a
new individual drain system shall constitute a modification to an affected facility described in §
60.690(a)(4). For purposes of this paragraph, a new individual drain system shall be limited to all
process drains and the first common junction box.
Status: This subpart applies to the Alkylation, SWS, HDS, and MSCC units. All sumps
were constructed prior to 1974, except for the sewer system. An AO was issued in
1982 for the covers only.
60.692-1 Standards: General.
(a) Each owner or operator subject to the provisions of this subpart shall comply with the
requirements of §§ 60.692-1 to 60.692-5 and with §§ 60.693-1 and 60.693-2, except during
periods of startup, shutdown, or malfunction.
(b) Compliance with §§ 60.692-1 to 60.692-5 and with §§ 60.693-1 and 60.693-2 will be
determined by review of records and reports, review of performance test results, and inspection
using the methods and procedures specified in § 60.696.
(c) Permission to use alternative means of emission limitation to meet the requirements of §§
60.692-2 through 60.692-4 may be granted as provided in § 60.694.
(d)(1) Storm water sewer systems are not subject to the requirements of this subpart.
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(2) Ancillary equipment, which is physically separate from the wastewater system and does not
come in contact with or store oily wastewater, is not subject to the requirements of this subpart.
(3) Non-contact cooling water systems are not subject to the requirements of this subpart.
(4) An owner or operator shall demonstrate compliance with the exclusions in paragraphs (d)(1),
(2), and (3) of this section as provided in § 60.697 (h), (I), and (j).
Status: In compliance. Subject drains, P-traps, and junction boxes have been identified and
diagramed on inspection forms.
60.692-2 Standards: Individual drain systems.
(a)(1) Each drain shall be equipped with water seal controls.
(2) Each drain in active service shall be checked by visual or physical inspection initially and
monthly thereafter for indications of low water levels or other conditions that would reduce the
effectiveness of the water seal controls.
(3) Except as provided in paragraph (a)(4) of this section, each drain out of active service shall be
checked by visual or physical inspection initially and weekly thereafter for indications of low
water levels or other problems that could result in VOC emissions.
(4) As an alternative to the requirements in paragraph (a)(3) of this section, if an owner or
operator elects to install a tightly sealed cap or plug over a drain that is out of service, inspections
shall be conducted initially and semiannually to ensure caps or plugs are in place and properly
installed.
(5) Whenever low water levels or missing or improperly installed caps or plugs are identified,
water shall be added or first efforts at repair shall be made as soon as practicable, but not later
than 24 hours after detection, except as provided in § 60.692-6.
(b)(1) Junction boxes shall be equipped with a cover and may have an open vent pipe. The vent
pipe shall be at least 90 cm (3 ft) in length and shall not exceed 10.2 cm (4 in) in diameter.
(2) Junction box covers shall have a tight seal around the edge and shall be kept in place at all
times, except during inspection and maintenance.
(3) Junction boxes shall be visually inspected initially and semiannually thereafter to ensure that
the cover is in place and to ensure that the cover has a tight seal around the edge.
(4) If a broken seal or gap is identified, first effort at repair shall be made as soon as practicable,
but not later than 15 calendar days after the broken seal or gap is identified, except as provided in
§ 60.692-6.
(c)(1) Sewer lines shall not be open to the atmosphere and shall be covered or enclosed in a
manner so as to have no visual gaps or cracks in joints, seals, or other emission interfaces.
(2) The portion of each unburied sewer line shall be visually inspected initially and semiannually
thereafter for indication of cracks, gaps, or other problems that could result in VOC emissions.
(3) Whenever cracks, gaps, or other problems are detected, repairs shall be made as soon as
practicable, but not later than 15 calendar days after identification, except as provided in §
60.692-6.
(d) Except as provided in paragraph (e) of this section, each modified or reconstructed individual
drain system that has a catch basin in the existing configuration prior to May 4, 1987 shall be
exempt from the provisions of this section.
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(e) Refinery wastewater routed through new process drains and a new first common downstream
junction box, either as part of a new individual drain system or an existing individual drain
system, shall not be routed through a downstream catch basin.
Status: In compliance. All subject drains, P-traps, and junction boxes have been identified
and diagramed on inspection forms. Water seals in the p-traps are checked monthly
and recorded. Traps were spot checked during this inspection.
Junction boxes have covers and a seal, and no open vent pipes are installed.
Junction boxes are inspected semi-annually as required.
One sewer line is underground (buried) and another was replaced with steel pipe in
a concrete trench and is fully enclosed. Inspection of the unburied sewer line in the
HDS Unit is performed and recorded semi-annually.
Big West Oil does not have any catch basins associated with this drain system.
60.692-3 Standards: Oil-water separators.
Status: In compliance. All subject separators have been identified and diagramed on
inspection forms. Tanks are all equipped with a fixed roof.
60.692-5 Standards: Closed vent systems and control devices.
Status: Not applicable. Flying J does not have any enclosed combustion or control devices
for the HDS/MDDW drain system.
60.692-6 Standards: Delay of repair.
(a) Delay of repair of facilities that are subject to the provisions of this subpart will be allowed if
the repair is technically impossible without a complete or partial refinery or process unit
shutdown.
(b) Repair of such equipment shall occur before the end of the next refinery or process unit
shutdown.
Status: In compliance. There have been no instances of delay of repair since the inspections
began.
60.692-7 Standards: Delay of compliance.
Status: Not applicable to this facility.
60.693-1 Alternative standards for individual drain systems.
Status: An alternative standard has not been requested.
60.693-2 Alternative standards for oil-water separators.
Status: Not applicable to this facility.
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60.694 Permission to use alternative means of emission limitation.
Status: No alternative means have been requested to date.
60.695 Monitoring of operations.
Status: This section is not applicable to the facility.
60.696 Performance test methods and procedures and compliance provisions.
Status: Not applicable. This refinery does not use a closed vent system or control.
60.697 Record keeping requirements.
(a) Each owner or operator of a facility subject to the provisions of this subpart shall comply with
the Record keeping requirements of this section. All records shall be retained for a period of 2
years after being recorded unless otherwise noted.
(b)(1) For individual drain systems subject to § 60.692-2, the location, date, and corrective action
shall be recorded for each drain when the water seal is dry or otherwise breached, when a drain
cap or plug is missing or improperly installed, or other problem is identified that could result in
VOC emissions, as determined during the initial and periodic visual or physical inspection.
(2) For junction boxes subject to § 60.692-2, the location, date, and corrective action shall be
recorded for inspections required by § 60.692-2(b) when a broken seal, gap, or other problem is
identified that could result in VOC emissions.
(3) For sewer lines subject to §§ 60.692-2 and 60.693-1(e), the location, date, and corrective
action shall be recorded for inspections required by §§ 60.692-2(c) and 60.693-1(e) when a
problem is identified that could result in VOC emissions.
(c) For oil-water separators subject to § 60.692-3, the location, date, and corrective action shall be
recorded for inspections required by § 60.692-3(a) when a problem is identified that could result
in VOC emissions.
(d) For closed vent systems subject to § 60.692-5 and completely closed drain systems subject to
§ 60.693-1, the location, date, and corrective action shall be recorded for inspections required by
§ 60.692-5(e) during which detectable emissions are measured or a problem is identified that
could result in VOC emissions.
(e)(1) If an emission point cannot be repaired or corrected without a process unit shutdown, the
expected date of a successful repair shall be recorded.
(2) The reason for the delay as specified in § 60.692-6 shall be recorded if an emission point or
equipment problem is not repaired or corrected in the specified amount of time.
(3) The signature of the owner or operator (or designee) whose decision it was that repair could
not be affected without refinery or process shutdown shall be recorded.
(4) The date of successful repair or corrective action shall be recorded.
(f)(1) A copy of the design specifications for all equipment used to comply with the provisions of
this subpart shall be kept for the life of the source in a readily accessible location.
(2) The following information pertaining to the design specifications shall be kept.
(I) Detailed schematics and piping and instrumentation diagrams.
(ii) The dates and descriptions of any changes in the design specifications.
(3) The following information pertaining to the operation and maintenance of closed drain
systems and closed vent systems shall be kept in a readily accessible location.
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(I) Documentation demonstrating that the control device will achieve the required control
efficiency during maximum loading conditions shall be kept for the life of the facility. This
documentation is to include a general description of the gas streams that enter the control device,
including flow and VOC content under varying liquid level conditions (dynamic and static) and
manufacturer's design specifications for the control device. If an enclosed combustion device with
a minimum residence time of 0.75 seconds and a minimum temperature of 816 C (1,500ºF) is
used to meet the 95-percent requirement, documentation that those conditions exist is sufficient to
meet the requirements of this paragraph.
(ii) A description of the operating parameter (or parameters) to be monitored to ensure that the
control device will be operated in conformance with these standards and the control device's
design specifications and an explanation of the criteria used for selection of that parameter (or
parameters) shall be kept for the life of the facility.
(iii) Periods when the closed vent systems and control devices required in § 60.692 are not
operated as designed, including periods when a flare pilot does not have a flame shall be recorded
and kept for 2 years after the information is recorded.
(iv) Dates of startup and shutdown of the closed vent system and control devices required in §
60.692 shall be recorded and kept for 2 years after the information is recorded.
(v) The dates of each measurement of detectable emissions required in §§ 60.692, 60.693, or
60.692-5 shall be recorded and kept for 2 years after the information is recorded.
(vi) The background level measured during each detectable emissions measurement shall be
recorded and kept for 2 years after the information is recorded.
(vii) The maximum instrument reading measured during each detectable emission measurement
shall be recorded and kept for 2 years after the information is recorded.
(viii) Each owner or operator of an affected facility that uses a thermal incinerator shall maintain
continuous records of the temperature of the gas stream in the combustion zone of the incinerator
and records of all 3-hour periods of operation during which the average temperature of the gas
stream in the combustion zone is more than 28ºC (50ºF) below the design combustion zone
temperature, and shall keep such records for 2 years after the information is recorded.
(ix) Each owner or operator of an affected facility that uses a catalytic incinerator shall maintain
continuous records of the temperature of the gas stream both upstream and downstream of the
catalyst bed of the incinerator, records of all 3-hour periods of operation during which the average
temperature measured before the catalyst bed is more than 28ºC (50ºF) below the design gas
stream temperature, and records of all 3-hour periods during which the average temperature
difference across the catalyst bed is less than 80 percent of the design temperature difference, and
shall keep such records for 2 years after the information is recorded.
(x) Each owner or operator of an affected facility that uses a carbon absorber shall maintain
continuous records of the VOC concentration level or reading of organics of the control device
outlet gas stream or inlet and outlet gas stream and records of all 3-hour periods of operation
during which the average VOC concentration level or reading of organics in the exhaust gases, or
inlet and outlet gas stream, is more than 20 percent greater than the design exhaust gas
concentration level, and shall keep such records for 2 years after the information is recorded.
(g) If an owner or operator elects to install a tightly sealed cap or plug over a drain that is out of
active service, the owner or operator shall keep for the life of a facility in a readily accessible
location, plans, or specifications, which indicate the location of such drains.
(h) For Storm water sewer systems subject to the exclusion in § 60.692-1(d)(1), an owner or
operator shall keep for the life of the facility in a readily accessible location, plans or
specifications which demonstrate that no wastewater from any process units or equipment is
directly discharged to the Storm water sewer system.
(I) For ancillary equipment subject to the exclusion in § 60.692-1(d)(2), an owner or operator
shall keep for the life of a facility in a readily accessible location, plans or specifications which
demonstrate that the ancillary equipment does not come in contact with or store oily wastewater.
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(j) For non-contact cooling water systems subject to the exclusion in § 60.692-1(d)(3), an owner
or operator shall keep for the life of the facility in a readily accessible location, plans or
specifications which demonstrate that the cooling water does not contact hydrocarbons or oily
wastewater and is not recirculated through a cooling tower.
Status: In compliance. Monthly drain inspections have been conducted and recorded.
Drains were spot checked during this inspection. Records indicate when a drain
requires water to be added. Semi-annual visual and Method 21 junction box,
exposed sewer line, and oil-water separator inspections have been conducted and
recorded. Junction box repairs are documented. No problems have been noted on
the sewer lines. No oil/water separators are subject to this subpart. Design
specifications for all systems are maintained in the office. As stated above, this
facility does not have a control device or closed vent system on this unit. The crude
unit is not subject to this regulation.
Storm water drains into the concrete trench and flows into the junction box. Most
wastewater flows into the junction box through the steel pipe in the trench, and this
water is treated as process water. The reformer unit has a segregated stormwater
system that is discharged.
60.698 Reporting requirements.
(a) An owner or operator electing to comply with the provisions of § 60.693 shall notify the
Administrator of the alternative standard selected in the report required in § 60.7.
(b)(1) Each owner or operator of a facility subject to this subpart shall submit to the
Administrator within 60 days after initial startup a certification that the equipment necessary to
comply with these standards has been installed and that the required initial inspections or tests of
process drains, sewer lines, junction boxes, oil-water separators, and closed vent systems and
control devices have been carried out in accordance with these standards. Thereafter, the owner or
operator shall submit to the Administrator semiannually a certification that all of the required
inspections have been carried out in accordance with these standards.
(2) Each owner or operator of an affected facility that uses a flare shall submit to the
Administrator within 60 days after initial startup, as required under § 60.8(a), a report of the
results of the performance test required in § 60.696(c).
(c) A report that summarizes all inspections when a water seal was dry or otherwise breached,
when a drain cap or plug was missing or improperly installed, or when cracks, gaps, or other
problems were identified that could result in VOC emissions, including information about the
repairs or corrective action taken, shall be submitted initially and semiannually thereafter to the
Administrator.
(d) As applicable, a report shall be submitted semiannually to the Administrator that indicates:
(1) Each 3-hour period of operation during which the average temperature of the gas stream in the
combustion zone of a thermal incinerator, as measured by the temperature monitoring device, is
more than 28°C (50°F) below the design combustion zone temperature,
(2) Each 3-hour period of operation during which the average temperature of the gas stream
immediately before the catalyst bed of a catalytic incinerator, as measured by the temperature
monitoring device, is more than 28°C (50°F) below the design gas stream temperature, and any
3-hour period during which the average temperature difference across the catalyst bed (i.e., the
difference between the temperatures of the gas stream immediately before and after the catalyst
bed), as measured by the temperature monitoring device, is less than 80 percent of the design
temperature difference, or,
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(3) Each 3-hour period of operation during which the average VOC concentration level or reading
of organics in the exhaust gases from a carbon absorber is more than 20 percent greater than the
design exhaust gas concentration level or reading.
(e) If compliance with the provisions of this subpart is delayed pursuant to § 60.692-7, the
notification required under 40 CFR 60.7(a)(4) shall include the estimated date of the next
scheduled refinery or process unit shutdown after the date of notification and the reason why
compliance with the standards is technically impossible without a refinery or process unit
shutdown.
Status: In compliance. The initial certification was submitted. All inspections of the water
seals, junction boxes, and drain have been made. Reports are submitted in June and
December.
AO Dated July 20 1982 for Separator covers, Secondary Storage Tanks Seals, and Vacuum System
Controls
1. Wastewater Separators
1. All separators shall have a cover, which shall be properly installed and
maintained.
2. All cover inspection hatches shall be closed at all times except during
maintenance. All hatches shall be lined around the parameter with a rubber
gasket. The hatches shall be kept in as nearly an airtight condition as practicable.
3. The separators shall be equipped with rubber gaskets between the steel plates
(covers) and concrete walls.
4. The Executive Secretary shall be notified when the covers are installed, as an
initial compliance inspection is required.
Status: In compliance. All separators are covered and wastewater is directed to fully
enclosed fixed roof tanks. The initial inspection was conducted several years ago.
2. Storage Tank Seals
1. The secondary seals shall be properly installed and maintained.
2. The accumulated area of gaps between each tank wall and the secondary seal
shall not exceed one (1) square inch per foot of tank diameter and the width of
any portion of any gap shall not exceed 0.5 inch.
3. There shall be no holes, tears, or other openings in the seal or seal fabric.
4. The Executive Secretary shall be notified when the seals have been installed, as
an initial compliance inspection is required.
Status: In compliance. The tanks have been installed for several years and an initial
compliance inspection has been completed. The report is in the file. Seal and gap
measurements are performed and recorded.
3. Non-Condensable from Vacuum Systems
1. The non-condensibles shall be piped to the vacuum unit heater.
2. The Executive Secretary shall be notified when the piping is completed, as an
initial compliance inspection is required.
Status: Not applicable. The vacuum unit is out of service.
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EMISSIONS INVENTORY: The following figures are from DAQ’s 2023 emissions inventory
database:
Pollutant Tons/yr
PM10 ..................... 15.13
PM2.5 .................... 14.83
NOX .................... 112.98
SOX ...................... 70.54
CO ...................... 192.85
VOC ................... 295.84
NH3...................... 27.00
PREVIOUS ENFORCEMENT
ACTIONS: Warning - February 11, 2019 - Exceeding flare limit of no more than five
minutes of visible emissions in a two hour period.
NOV - October 22, 2021 - Exceeding flare limit of no more than five
minutes of visible emissions in a two hour period.
Warning - January 11, 2023 - Failed H2S audit.
COMPLIANCE STATUS &
RECOMMENDATIONS: Big West Oil should be considered to be in compliance with the
regulations and AO conditions evaluated at the time of this inspection.
HPV STATUS: Not Applicable
COMPLIANCE
ASSISTANCE: No
RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual.
ATTCHMENT: VEO/Inspection form