DAQ-2024-010885

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DAQC-1031-24
Site ID 10122 (B1)

MEMORANDUM

TO: FILE – BIG WEST OIL

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Jeremiah R. Marsigli, Environmental Scientist

DATE: October 8, 2024

SUBJECT: Partial Compliance Evaluation (#3 of 4), Major, Davis County,
FRS ID# UT0000004901100008
____________________________________________________________________________

INSPECTION DATE: September 12, 2024

SOURCE LOCATION: 333 West Center Street, North Salt Lake, Utah

MAILING ADDRESS: 333 West Center Street, North Salt Lake, Utah 84054

SOURCE CONTACTS: E. Faithe Schwartzengraber, Environmental Manager, [phone]
Ian Muller, Environmental Engineer, [phone]
Brady Miller, Environmental Engineer, [phone]

OPERATING STATUS: Operating

PROCESS DESCRIPTION:

Big West Oil is a petroleum refinery capable of processing 30,000 bbls/day. Units include crude heater,
crude pre-flash heater, vacuum heater, unifiner heater, reformer, boilers, MSCC and alky heaters, 2 flares,
MIDW furnace, SRU, tanks, and HDS Unit. A full description is provided in the process inspection.

This inspection focused on VOC emissions and leaks in the refinery. Big West Refinery has numerous
valves, pumps, flanges, and other components in VOC service. The company has a LDAR program,
which is administered by a contractor. All components are included on the piping diagram. The company
has an industry standard leak detection log program, which is administered by a contractor who does the
leak detection. All components (except pumps) have first attempt at repair during the leak detection
activities. This first attempt includes tightening of bolts and covers. The company has not requested skip
monitoring with the exception of the allowed quarterly valve checks under NSPS.

APPLICABLE REGULATIONS:

UACR307-326 - R307-326. Ozone Nonattainment and Maintenance Areas: Control of Hydrocarbon
Emissions in Petroleum Refineries

UACR307-328 – Gasoline Transfer and Storage

NSPS subpart GGG, GGGa and VV apply. Subparts GGG and VV are not evaluated as GGGa, State
Rules, and Consent Decree requirements are more stringent

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Approval Order dated January 14, 2004 (DAQE-AN0122027-04)

SOURCE INSPECTION
EVALUATION:

R307-326. Ozone Nonattainment and Maintenance Areas: Control of Hydrocarbon Emissions in
Petroleum Refineries.

UAC R307-326 -2-9 Control of Hydrocarbon Emissions in Refineries

R307-326-4. Vacuum Producing Systems.
The emission of noncondensable volatile organic compounds from the condensers, hot wells, or
accumulators of vacuum producing systems shall be controlled by:
(1) piping the noncondensable vapors to a firebox or incinerator, or
(2) compressing the vapors and adding them to the refinery fuel gas, or
(3) other equally effective means provided the design and effectiveness of such means are
documented and submitted to and approved by the executive secretary.

Status: Not applicable. The Vacuum unit has been removed.

R307-326-6. Process Unit Turnaround.

The owner or operator of a petroleum refinery shall insure that a minimum of volatile organic
compounds (VOC) are emitted to the atmosphere during process unit turnarounds. The owner or
operator shall develop and submit to the executive secretary for approval a procedure for
minimizing VOC emissions during turnarounds. The procedure shall be submitted by April 1,
1990. As a minimum, the procedure shall provide for:
(1) venting of the process unit or vessel during depressurization and purging to a vapor recovery
system, flare or firebox, and
(2) preventing discharge to the atmosphere of emissions of volatile organic compounds from a
process unit or vessel until its internal pressure is 136 kPa (19.7 psia) or less; or
(3) an equally effective system provided the design and effectiveness of such system are
documented and submitted to and approved by the executive secretary.
(4) keeping records of the following items:
(a) every date that each process unit or vessel is shut down;
(b) the approximate vessel VOC concentration when the VOCs were first discharged to the
atmosphere; and
(c) the approximate total quantity of VOCs emitted to the atmosphere.
(5) maintaining records. The records required in (4) above shall be kept for at least two years and
shall be made available for review by the executive secretary or his representative.

Status: In compliance. The submitted procedure for minimizing VOC emissions during
turnarounds was dated May 8, 1990. This procedure requires the system to evacuate to the
flare until the pressure in the system is less than 5 psig, with current practices attempting to
reduce pressure much lower than 5 psig. Big West Oil also performs a steam and nitrogen
purge, detergent and chemical cleaning as necessary, and achieves less than 10% L.E.L.

Records of turnarounds are kept and contain the date and unit or vessel which is shut
down, the approximate VOC concentration at first discharge, and the approximate total
quantity of VOC’s emitted to the atmosphere. Calculations of the VOC released to
atmosphere are performed by the company for each piece of equipment to determine the
amount of VOC's discharged.
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R307-326-7. Catalytic Cracking Units.

Flue gas produced by catalytic cracker catalyst regeneration units shall be vented to a waste heat
boiler, a process heater firebox, incinerated, or controlled by other methods provided the design
and effectiveness of such methods are documented and submitted to and approved by the
executive secretary.

Status: In compliance. Flue gas is vented to the cyclone system and then to the Pall filter for the
capture of particulate. A COM is installed and operating.

R307-326-8. Safety Pressure Relief Valves.

All safety pressure relief valves handling organic material shall be vented to a flare, firebox, or
vapor recovery system, or controlled by the inspection, monitoring, and repair requirements
described in R307-326-7.

Status: In compliance. All safety pressure relief valves are vented to a flare.

R307-326-9. 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 start up
of the petroleum refinery complex or as determined necessary by the executive secretary.
(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 which has a VOC concentration 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 calibration gas. Components not subject to New Source Performance
Standards subpart GGG shall use methane or hexane as calibration gas, provided a relative
response factor 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 required by (7) below. The executive
secretary, in coordination with the refinery owner or operator, may require early unit turnaround
based on the number and severity of tagged leaks awaiting turnaround.
(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;
(ii) Monitor four times per year (quarterly) all compressor seals, valves in gaseous service, and
pressure relief valves in gaseous service.
(iii) Monitor visually 52 times per year (weekly) all pump seals;
(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;
(v) Monitor any relief valve within 24 hours after it has been vented to the atmosphere;
(vi) monitor immediately after repair any component that was found leaking;

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(vii) for 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). This documentation shall be submitted for approval
to the executive secretary 15 days after the last day of each calendar year.
(b) For the purpose of R307-326, gaseous service for pipeline valves and pressure relief valves is
defined as the VOC 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.
(4) Exemptions. The following are exempt from the monitoring requirements of (3) above:
(a) Pressure relief devices which are connected to an operating flare header, firebox, or vapor
recovery devices, storage tank valves, and valves that are not externally regulated; and
(b) Refinery equipment containing a stream composition less than 10 percent by weight VOC;
and
(c) Refinery equipment containing natural gas supplied by a public utility as defined by the Utah
Public Service Commission.
(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 alternative monitoring procedures; and
(iv) a description of the proposed alternative operational or equipment controls.
(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 executive secretary
upon request.
(7) Reporting Requirements. The operator or owner of a petroleum refinery complex shall submit
a report to the executive secretary 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 not repaired within 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 a signed statement with each report that all monitoring has been performed
as stipulated in R307-14-4.FR307-326-9.

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(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. Big West Oil is under a consent decree and monitors all components to more
stringent standards than any state or federal regulation. Records are kept and available for
review. All monitoring is conducted by a contractor named Tri-Hydro Corp. The contractor
notifies Big West Oil of the VOC components found leaking and attempts immediate repair
if capable (depends on the component type). The Big West Oil maintenance unit makes first
attempt at repair within 5 days on equipment (even if Tri-Hydro made an immediate
repair). Follow-up monitoring is immediately performed on repaired components. Delay of
Repair components are tagged and reported to DAQ as required. The most recent annual
difficult to monitor and unsafe to monitor report was received by DAQ on January 22,
2024. The most recent quarterly VOC monitoring report for UAC R307 was received by
DAQ on July 22, 2024.

UAC R307-328 – Gasoline Transfer and Storage

R307-328-4. Loading of Tank Trucks, Trailers, Railroad Tank Cars, and Other Transport Vehicles.

(1) No person shall load or permit the loading of gasoline into any gasoline cargo tank unless the
emissions from such vehicle are controlled by use of a vapor collection and control system and
submerged or bottom filling. RACT shall be required and in no case shall vapor emissions to the
atmosphere exceed 0.640 pounds per 1,000 gallons transferred.
(2) Such vapor collection and control system shall be properly installed and maintained.
(3) The loading device shall not leak.
(4) The loading device shall utilize the dry-break loading design couplings and shall be maintained
and operated to allow no more than an average of 15 cc drainage per disconnect for 5 consecutive
disconnects.
(5) All loading and vapor lines shall be equipped with fittings which make a vapor tight connection
and shall automatically close upon disconnection to prevent release of the organic material.
(6) A gasoline storage and transfer installation that receives inbound loads and dispatches outbound
loads ("bulk plant") need not comply with R307-328-4 if it does not have a daily average throughput
of more than 3,900 gallons (15,000 or more liters) of gasoline based upon a 30-day rolling average.
Such installations shall on-load and off-load gasoline by use of bottom or submerged filling. The
emission limitation is based on operating procedures and equipment specifications using Reasonably
Available Control Technology as defined in EPA documents EPA 450/2-77-026 October 1977,
"Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals," and EPA-450/2-77-035
December 1977, "Control of Volatile Organic Emissions from Bulk Gasoline Plants." The design
effectiveness of such equipment and the operating procedures must be documented and submitted to
and approved by the director.
(7) Hatches of gasoline cargo tanks shall not be opened at any time during loading operations except
to avoid emergency situations or during emergency situations. Pressure relief valves on storage tanks
and gasoline cargo tanks shall be set to release at the highest possible pressure, in accordance with
State or local fire codes and National Fire Prevention Association guidelines. Pressure in the vapor
collection system shall not exceed the gasoline cargo tank pressure relief setting.
(8) Each owner or operator of a gasoline storage or dispensing installation shall conduct testing of
vapor collection systems used at such installation and shall maintain records of all tests for no less
than two years. Testing procedures of vapor collection systems shall be approved by the director and
shall be consistent with the procedures described in the EPA document, "Control of Volatile Organic
Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems," EPA-450/2-78-051.
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(9) Semi-annual testing shall be conducted and records maintained of such test. The frequency of
tests may be altered by the director upon submittal of documentation which would justify a change.
(10) The vapor collection and vapor processing equipment shall be designed and operated to prevent
gauge pressure in the gasoline cargo tank from exceeding 18 inches of water and prevent vacuum
from exceeding 6 inches of water. During testing and monitoring, there shall be no reading greater
than or equal to 100 percent of the lower explosive limit measured at 1.04 inches around the
perimeter of a potential leak source as detected by a combustible gas detector. Potential leak sources
include, but are not limited to, piping, seals, hoses, connections, pressure or vacuum vents, and vapor
hoods. In addition, no visible liquid leaks are permitted during testing or monitoring.

Status: In compliance. Trucks are loaded through submerged bottom filling and only into certified
trucks. A computerized system called Scully must be connected to each truck prior to
filling, and ensures trucks are certified and vapor collection hoses are attached. Big West
complies with a 10mg/L emissions limit, which is much more stringent than 0.640lbs/1,000
gallons (76.6mg/L). A CEMS is installed and reports are submitted to DAQ quarterly. The
loading arms utilize dry-break design. No loading occurred during this inspection so no
disconnects were observed. Plant policy is for operators to check for leaks three times per
shift and keep record of these checks. All leaks observed during inspection or day-to-day
activities are submitted for repair. Contractor ZEECO performs semi-annual maintenance
on loading rack vapor recovery, including pressure and vacuum checks.

NSPS Subpart GGGa - Standards of Performance for Equipment Leaks of VOC in Petroleum
Refineries

Status: In compliance. Subpart GGGa applies. This refinery is under a consent decree (CD) that
requires more stringent regulations than Subpart GGGa. Monthly pump monitoring has
been performed and recorded. Weekly visual inspections of pumps in light liquid service
have been performed and recorded. The leak definition for these is the most stringent under
state and federal regulations or more stringent per the CD. In compliance with first attempt
and delay of repair requirements. Compressors are monitored quarterly. This source has
not had any pressure relief device (PRD) releases during the 12-month period preceding
this inspection. PRD events greater than 72 lbs of VOC are reported in semi-annual
Subpart CC reports. Sampling connection systems and open-ended valves are designed to
meet this code. Valves in gas/vapor service and in light liquid service are monitored
monthly when found leaking, or quarterly under the skip monitoring provision. The
consent decree requires a 500 ppm limit and an “action level” of 200 ppm. Company policy
is for personnel to report valves in heavy liquid service seen leaking so repairs can be
performed. Annual Method 21 inspections are also performed on valves in heavy liquid
service. Closed vent systems vent to a flare that is kept in compliance with 40 CFR 60. This
system consists of hard-piping. An initial inspection has been performed and annual visual
inspections are performed and recorded.

Approval Order dated January 14, 2004 (DAQE-AN0122027-04)

General Conditions:

1. This Approval Order (AO) applies to the following company:

Site Office Corporate Office Location
Flying J Inc./Big West Oil LLC Flying J Inc.
333 West Center 1104 County Hill Drive
North Salt Lake, Utah 84054 Ogden, Utah 84403
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Phone Number [phone] [phone]
Fax Number [phone] [phone]

The equipment listed in this AO shall be operated at the following location:

PLANT LOCATION:

333 West Center
North Salt Lake
Universal Transverse Mercator (UTM) Coordinate System: UTM Datum NAD27
4,535.4 kilometers Northing, 431.5 kilometers Easting, Zone 12

Status: No discrepancies noted.

2. All definitions, terms, abbreviations, and references used in this AO conform to those used in the
Utah Administrative Code (UAC) Rule 307 (R307), and Title 40 of the Code of Federal
Regulations (40 CFR). Unless noted otherwise, references cited in these AO conditions refer to
those rules.

Status: No discrepancies noted.

3. The limit(s) set forth in this AO shall not be exceeded.

Status: In compliance. None of the limits set forth in this AO appear to have been exceeded.

4. Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be approved in accordance with R307 401-1.

Status: In compliance. No unapproved modifications to the equipment or processes
approved by this AO that could affect the emissions covered by this AO were noted.

5. All records referenced in this AO and the MACT standards, which are required to be kept by the
owner/operator, shall be made available to the Executive Secretary or Executive Secretary’s
representative upon request, and the records shall include the two-year period prior to the date of
the request. All records shall be kept for the following minimum periods as specified below:

• Emission inventories: Five years from the due date of each emission statement or until
the next inventory is due, whichever is longer.

• All other records: Two years

Status: In compliance. All requested records have been provided.

6. Flying J Inc./Big West Oil shall keep and operate as a backup the old vapor recovery unit,
designated as the South VRU, at the Loading Rack facility and operate it in accordance with the
terms and conditions of this AO, which were written pursuant to the notice of intent, submitted on
November 13, 2003.

Status: No discrepancies noted.

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7. This AO shall replace the AO-DAQE-AN0122025-03, dated June 13, 2003.

Status: No discrepancies noted.

8. The approved installations at Flying J/Big West Oil shall consist of the following:

a. A gasoline loading rack,
b. The old vapor recovery unit [the South VRU]
c. A vapor recovery unit [the North VRU] that shall include two vessels of activated carbon.

Status: In compliance. No unapproved equipment or processes approved by this AO that could
affect the emissions covered by this AO were noted.

9. The gasoline loading and transportation from Flying J/Big West Oil shall not exceed 384 million
gallons per 12-month period.

Status: In compliance. For the 12-month period ending August 3, 2024, records indicated that
289,282,014 gallons of gasoline were loaded or transported.

10. To determine compliance with the rolling 12-month total the owner/operator shall calculate a new
12-month total by the twentieth day of each month using data from the previous 12 months. The
supervisor shall keep a daily record of the gasoline that is shipped.

Status: In compliance. Records were made available and found in compliance.

Federal Limitations and Requirements

11. In addition to the requirements of this AO, all applicable provisions of 40 CFR 60, Subpart A and
40 CFR 63, Subpart CC [National Emission Standards for Hazardous Air Pollutants from
Petroleum Refineries] shall apply to this operation.

Status: In compliance. No discrepancies noted.

12. The plant-wide emissions of VOC from the loading operation shall not exceed 15.93 tons per
rolling 12-month total.

Compliance with the limitation shall be determined on a rolling 12-month total. Based on the
twentieth day of each month, a new 12-month total shall be calculated using data from the
previous 12 months.

Status: In compliance. For the 12-month period ending August 31, 2024, 1.40 tons of VOC
from the loading operation were recorded.

Monitoring - General Process

13. The owner/operator shall install, calibrate, maintain, and operate a continuous emission monitors
to measure the emission of gasoline vapor from each of the vapor recovery units.

Status: In compliance. CEM’s are installed and quarterly reports are submitted to DAQ.

Records & Miscellaneous

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14. At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this Approval
Order including associated air pollution control equipment in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Executive Secretary which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source. All
maintenance performed on equipment authorized by this AO shall be recorded, and the records
shall be maintained for a period of two years.

Status: In compliance. The facility appeared to be well maintained.

EMISSIONS INVENTORY: Taken 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 in compliance with the rules and
conditions evaluated at the time of this inspection.

HPV STATUS: Not Applicable

COMPLIANCE
ASSISTANCE: No

RECOMMENDATION FOR
NEXT INSPECTION: None

ATTACHMENT: VEO form