DAQ-2024-011331

VIA EMAILAND CERTIFIED MAIL
RETURN RECEIPT NO. 9589 0710 5270 1318 3712 6t
Bryce Bird, Director Division ofAir Quality
Utah Department of Environmental Quality
195 North I950 West
P.O. Box 144820
Salt Lake City, Utah 84114-4820
E. Faithe Schwartzengra ber
Environmental Manager -Big West Oil
333 W. Center Street
North Salt Lake City, UT 84054
801,-296-7763 (office)
I,TAH DEPABTMENT OF
ET.IVIRONMENTAL OUATITY
AUG 1 3 2A24
DIVISION OF AIR QUALITY
Re: Voluntary Self- Disclosure by Big West Oil LLC ("BWO") 40 CFR Part 60, Subpart eee,Potential Non-Compliance Issues and Interim Measures Follow-up
Dear Mr. Bird:
Pursuant to the Utah Environmental Self-Evaluation Act (the "Utah Act"), Big West Oil, LLC ("BWO")
voluntarily submitted to the Utah Department of Environmental Quality ("UDEQ") to self-report potential
violations of 40 CFR Part 60, Subpart QQQ (Standards of Perforrnance for VOC Emissions from petroleum
Refinery Wastewater Systems) ("NSPS QQQ"), at the BWO North Salt Lake Refinery ("Refinery") on June
20,2024.
This letter is to provide additional information regarding equipment that the independent auditor and others
found that potentially does not meet the requirements of NSPS QQQ and the proposed corrective actions
associated with that equipment. Please note that as additional review, evaluation, and engineering is
completed, the corrective actions included in the table below may be modified.
Individual Drain Systems
Some existing, reconstructed, and individual drain systems previously determined as not applicable to the
rule requirements were determined to be subject to the rule. These drain systems will need to be upgraded
or modified to meet the rule requirements.
Existing drains were found to have missing water seals or caps. Junction box covers and lift stations will
need to be properly sealed. Piping into junction boxes were found to enter above the water line. Some drain
systems will need to be controlled by implementing modifications to piping configurations and drain design.
Some stormwater and cooling tower water not fully segregated from the oily water system
segregated or controlled.
Wash pad controls will need repaired or upgraded.
need to be
B-2-10122
Mr. Bryce Bird
Page 2
Oil-water separators
Covers on oil-water separators need to be repaired including inspection hatches and other components.
Aggregate facility
The aggregate facility consisting of the DAF ancillary equipment will need to be upgraded.
Closed vent systems and control devices
Closed vent systems and control devices will need to be installed on the Crude, Mini, and MSCC oil-water
separators and Tank lA. The design of the vent and control device system on Tank 1B will be reviewed.
Equipment Repairs and Timing
Eouioment TVoe Completion <60 Days Completion >60 Davs
Drains 60 48
Junction Boxes 9 26
Pipine Connections/Modifi cations J l8
Manhole Covers 4 2
Separator Reoairs 0 4
Tanks 0
The repair numbers listed in the above table may change due to ongoing evaluation of
determinations of repairs needed, and optimization of controls.
Interim Measures
The following interim measures have been or will be implemented prior to completion of the equipment
repairs:
1. Update inspection forms and instructions (completed)
2. Update Management of Change procedures (completed)
3. Update training for inspectors (completed)
4. Develop a QQQ Compliance Management Plan
5. Ensure all QQQ compliance related equipment is included in the site equipment
inventory system
Due to complexity of the work and difficulty of working in operating process units, much of the repair work
will extend well beyond 60 days from the time of discovery. Factors affecting timing include:
l. Conducting feasibility studies2. Completing engineering design3. Planning and coordination within various departments at BWO4. Identifu work that may require a shutdown to safely complete5. Completion of procurement and construction
Mr. Bryce Bird
Page 3
The schedule to complete installation of the necessary equipment and controls will depend on the results ofthe feasibility studies and engineering design. BWO will provide UDAQ with a schedule following the
conclusion of the engineering phase and the selection of the specific corrective options to be implem"nt"d.
If you have any questions or require additional information, please contact Faithe Schwartzengraber
at (80 I) 296-77 63 or [e-mail].
""f,LW
Alec Klinghoffer
VP Operations and General Manager
Big West Oil
cc: Jeremy Marsigli