DAQ-2024-011305

BigWestOil ,
July 30,2024
CERTIFIED MAIL
RETITRN RECEIPT NO. 9589 0710 52701318 3713 53
Bryce Bird, Director
Utah Division of Air Quality
Utah State Departrnent of Environmental Quality
195 North 1950 West
P.O. Box 144820
Salt Lake city, utah 84114-4820
Should you have any questions regarding this report, or the data submitted,
at [phone] or email at [e-mail].
Sincerely,-7-2.__@
Trevor Barlow
Environmental Engineer
333 w. cenrer streer ' North salt Lake utah 84054 . 801 .296.7700. www.bigwestoil.com
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RE: 40 CFR 63 Subpart U[IU: Semi-Annual Report: Januara l,20}4,to June 30rZ0Z4
Dear Mr. Bird,
As required under 40 CFR Subpart UUU, $63.1575, Big West Oil LLC (BWO) hereby submits its Semi-
Annual Report for the l't Half of 2024 (January I - June 30).
Certifi cation Statement:
I certifl 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 feel free to contact me
Alec Klinghoffer
Refinery Manager
B-2-10122
CC:CERTIFIED MAIL
RETURN RECEIPT NO. 9589 0710 52701318 3713 60
Director, Air and Toxics Technical Enforcement Program
Office of Enforcement, Compliance and Environmental Justice
MailCode SENF-AT
1595 Wynkoop Street
Denver, CO 80202-1129
Electronic copies to:
Mr. Jeremy Marsigli- UDAQ
[e-mail]
Catalytic Reforming Unit (CRII)
The CRU converts low-octane straight-run naphtha into a high-octane gasoline blendstock (reformate).
The CRU consists of three catalytic reactors that increase the octane of the stream through a
dehydrogenation process. Following the series of reactors, catalyst is collected for regeneration, which
involves a rechlorination step that creates the potential for hydrochloric acid (HCl) emissions. The CRU
process unit operated for 3,683 hours in the reporting period.
BWO operates a continuous CRU. Therefore, as specified in $63.1 567(a)(l) and Item 2 of Table22 to
Subpart UUU, BWO must meet inorganic HAP emission limits by reducing emissions of HCI by 97%by
weight or to a concentration of l0 ppmv (dry basis), corrected to 3%o Oz. The requirement is met during
coke burn-off and catalyst rejuvenation by venting the process gases to a wet gas scrubber. As stated in
Item I of Table 23 to Subpart UUU, facilities using a wet scrubber as a control device are required to
maintain the daily average pH of the water exiting the scrubber and the daily average liquid-to-gas ratio
above the limits established during the performance test, which BWO performed in April 2005.
Wet Gas Scrubber: Effluent pH
There were no deviations from the WGS effluent pH daily average operating limit of 5.54 pH units on a
daily basis during the reporting period. In accordance with $63.1575(d)(3), there were no monitoring
downtime events for this monitoring system.
Wet Gas Scrubber: Liquid-to-Gas Ratio
There were no deviations from the liquid-to-gas ratio daily average limit of 0.29 gpm,A4SCFD on a daily
average basis during the reporting period. In accordance with $63.1575(d)(3), there were no monitoring
downtime events for this monitoring system.
Sulfur Recovery Unit (SRU)
BWO operates a Claus SRU. The SRU processes the overhead gases from the Sour Water Stripper and
the mixture of acid gas from the Amine Unit. These gases are charged in a thermal reactor and a series of
three catalytic reactors to convert the HzS into elemental sulfur. The gases produced in the catalytic
reactor are sent to the SRU Tail Gas Incinerator, where the small amount of remaining HzS and other
reduced sulfur species are converted to SOz present in the process flue gas. A continuous emissions
monitoring systent (CEMS) monitors the Oz within the incinerator stack and a continuous parameter
monitoring system (CPMS) continuously monitors the temperature of the incinerator firebox to verifi
complete combustion of the reduced sulfur species. The SRU operated for 4,368 hours in the reporting
period.
The SRU at BWO is not subject to either of the New Source Performance Standards (I{SPS) for sulfur
oxides at 40 CFR 60 Subpart J or Ja. To comply with 40 CFR 63 Subpart UUU HAP emission limits,
BWO complies with the Total Reduced Sulfur (TRS) limit (Option 2) as specified in 963.1568(aXlXii)
and Item 3 of Table 29 to Subpart UUU. This election requires that BWO maintain emissions of TRS
compounds expressed as an equivalent SOz concentration at or below 300 ppmv on a dry basis at zero
percent oxygen. This emission limit is complied with by maintaining the daily average combustion zone
temperature of the incinerator and the daily average oxygen (Oz) concentration in the vent streant at or
above the limits established during June 2005 performance testing.
SRU Incinerator Combustion Zone Temperature
There were no deviations from the combustion zone minimum temperature operating limit of I l66oF on a
daily block average. In accordance with 563.1575(d), there were no monitoring downtime events for this
monitoring system.
SRU Incinerator Exhaust Oz Concentration
There were no deviations from the vent strearn minimum 02 concentration operating limit of 3.5% (dry
basis) on a daily block average.
Incinerator Alternative Standard: Oz Concentration and Temperature
Per $63.1568(a)(a)(iii), BWO may altematively comply with 40 CFR 63 Subpart UUU during periods of
startup and shutdown by maintaining the hourly average firebox temperature of the incinerator at or above
1200'F and the hourly average outlet Oz concentration at or above 2% (dry basis). During the current
reporting period, the SRU complied with the default combustion zone temperature and exhaust Oz limits;
therefore, the alternative standards for stack 02 concentration and firebox temperature were not
utilized. There were no deviations from the standard.
Millisecond Catalytic Cracking Unit (MSCC)
The MSCC reactor breaks up heavy hydrocarbon molecules into smaller molecules to produce marketable
products. This cracking process takes place on the surface of a circulating, powdered catalyst within the
fluidized bed-type MSCC reactor. The flue gas from the catalyst regeneration process consists primarily
of nitrogen, carbon dioxide, water, and oxygen with a lower concentration of pollutants. For MSCC Metal
HAP, a COMS is used for compliance demonstration. For organic HAP, a CO CEMS is used to evaluate
compliance with the emissions limit. The MSCC operated for 4,344 hours in the reporting period.
The MSCC at BWO is subject to the NSPS for particulate matter (PM) as specified in NSPS Subpart J.
Per $63.156a(a)(l) and Item I of Table I to Subpart UUU, BWO must comply with the metal HAP
emission limits of Subpart UUU by complying with NSPS Subpar.t J and is subject to limits of I.0 lb
PM/l ,000 lb of coke burn-off and 30%o opacity, except for one six-minute average opacity reading in any
one-hour period. Per $63.156a@)Q) and Item I of Table 2 to Subpart UUU, a 3-hour rolling average
opacity no greater than20%o must also be maintained. During periods of startup, shutdown, or hot
standby, BWO may, alternatively, elect to demonstrate compliance by utilizing the alternative standard
(i.e., maintain inlet velocity to primary internal cyclones of the MSCC regenerator at or above 20
ftlsecond) in accordance with $63. I 56a(a)(5Xii).
For organic HAP compliance, the MSCC at BWO is subject to the NSPS for carbon monoxide (CO) as
specified in 40 CFR 60 Subpart J. Per $63.1 565(a)( 1) and Item I of Table 8 to Subpart UUU, BWO must
comply with the organic HAP emission limits within Subpart UUU by complying with 40 CFR 60
Subpart J; CO emissions from the MSCC must not exceed 500 parts per million by volume on a dry basis
(ppmvd). During periods of startup, shutdown, or hot standby, BWO may, alternatively, elect to
demonstrate compliance by utilizing the alternative standard (i.e., maintain oxygen concentration in the
exhaust gas from the regenerator at or above I vol%) in accordance with $63.1565(a)(5)(ii).
MSCC Opacity Limits and Alternative Standard
There were seven deviations from the 6-rninute opacity emission limit (i.e., opacity of emissions must not
exceed 3002, except for one 6-minute average opacity reading in any l-hour period) during the reporting
period. During events related to startup, shutdown, and hot standby, the MSCC complied with the
alternate metal HAP emission limit (i.e., maintain inlet velocity to primary internal cyclones of the MSCC
regenerator at or above 20 ft/second). For events not related to startup, shutdown, and hot standby, a
compliance evaluation of inlet velocity was completed to demonstrate operation in a manner consistent
with safety and good air pollution control practices.
There were no deviations from the 3-hr rolling average opacity operating parameter limit (i.e., above 20Yo
on a 3-hour rolling average).
MSCC Coke Burn-Off
There were no deviations from the coke burn-off emission limit (1.0 lb PM/1000 lb coke burned
off). Details on performance testing for compliance evaluation against this limit are described in the final
section of this report.
MSCC CO Emissions and Alternative Standard
There were no deviations from the CO emission limit (i.e., above the hourly average standard of 500
ppm). BWO may comply with the alternate organic HAP emission limit during periods of startup,
shutdown, and hot standby (i.e., maintain 02 concentration in exhaust from the catalyst regenerator )lYo
vol, dry basis). During the current reporting period, the MSCC complied with the default limit;therefore,
the alternative standard was not utilized.
Since the unit complied with either the emission limit or alternate standard at all times, there were no
deviations from work practice standards for CO during this reporting period. Therefore, further details
regarding deviations as described in the reporting requirements of $63. 1575(e) are not applicable.
CEMS & COMS Deviations and Downtime
Information related to monitor status for MSCC Opacity, MSCC CO, MSCC 02, and SRU Oz
concentration are included within the State Electronic Data Reports (SEDR) that cover this reporting
period that were submitted the Utah Departrnent of Air Quality (UDAQ). In accordance with
$63.1575(c)(4), $63.1575(e), and $63.1575(g), all information related to CEMS/COMS unavailability and
excess emissions not included within this report are included within those reports.
Note: The MSCC Regenerator Vent CO limit for MACT Subpart UUU is reported in the SEDR (500
ppmvd CO, uncorrected); therefore, any deviations from the MACT UUU limit are included in the SEDR
report. Also, the MSCC Flue Gas Opacity limit for MACT Subpart UUU (30% opacity over 6 minutes
Date
Start
Time
End
Time
Opacity
(06l Reason
Inlet
Velocity
(fUs)
Complied
with Alt.
std.?
312812024 l6:42 16:48 48.22 Precipitation fouled the
opacity lenses with
moisture.
64.66 Yes
312812024 l6:48 l6:54 51.19 64.83 Yes
sls12024 4:30 4:36 30 A snowstorm caused the
analyzer to show
artifi cially elevated opacity
readings.
72.97 Yes
51512024 4:36 4:42 64.6 72.43 Yes
51512024 4:42 4:48 69.1 71.36 Yes
51512024 4:48 4:54 57.3 70.66 Yes
51512024 4:54 5:00 41.7 69.81 Yes
and 20yo over 3-hour rolling average) differs from that which is reported in the SEDR (20Yo opacity over
6 minutes); therefore, any deviations from the MACT UUU opacity limit are included in this report
above.
Performance Tests, Performance Evaluations, and Emission Standard Applicability
For purposes of $63. 1575(f)( I ), BWO conducted three RATAs on the MSCC Flue Stack for Oz, COz,
SOz, NOx, and CO during the reporting period.ln accordance with $63.1575(k)(2), the pertinent
information was submitted through the EPA's Electronic Reporting Tool (ERT) tool. Details on these
three performance evaluations are included in the table below. The previous RATA on the MSCC Flue
Stack for these pollutants was performed on March 28,2023.
BWO previously conducted a performance test on the MSCC Flue Stack for PM emissions, including
coke burn-off rates, on December 15,2023.In accordance with $63.1575(k)(l), the pertinent information
was uploaded to the EPA's ERT on January 29,2024.
BWO also previously conducted a RATA on the SRU Oz on December 11,2023.In accordance with
$63.1575(k)(2), the pertinent information was submitted through the EPA's ERT on February 9,2024.
In accordance with $63. 1575(e)( l3), there were no changes to the continuous emission monitoring
systems or continuous opacity monitoring systems, processes, or controls since the last reporting period.
U li^rl{ i)FPAii Ilv']F NT OFl-
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AI.IU
DI\/ISION OF AiR OUALITY l
Date Conducted Parameters Evaluated Date Submitted in ERT
3t13t2024 - 3n4t2024 Oz,COz, SO2, NOy, and CO 4t30t2024
3128t2024 Oz,COz, SOz, NOx, and CO slt612024
411112024 Oz,COz, SOz, NOx, and CO 513U2024