DAQ-2024-011545

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May 25,2023
Director, Air Enforcement Division
Office of Civil Enforcement
U.S. Environmental Protection Agency
MailCode 2242-A
1200 Pennsylvania Avenue, NW
Washington, DC 20460-0001
Executive Secretary, Utah Air Quality Board
Division of Air Quality
Utah Dept. of Environmental Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, UT 84LL4-482O
, l,
Certified Mail: 7019 1120 0000 0070 9078
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RE:Benzene Waste Operations Sampling Plan
Consent Decree Entered luly 2,2008 in the U.S. District for the District of Utah
United States of America, State of Utah v. Holly Refining & Marketing Company - Woods Cross
ln accordance with Paragraph 96.a. of the Holly Refining & Marketing Company - Woods Cross Consent
Decree, this submittal provides the current Benzene Waste Operations Sampling Plan for the Woods
Cross Refinery. Note, Holly Refining & Marketing Company - Woods Cross is now operating under the
name HF Sinclair Woods Cross Refining LLC. This revised sampling plan is being submitted no later than
ninety (90) days after HF Sinclair Woods Refining LLC, HF Sinclair, determined it to be no longer
providing an accurate measure, per Paragraph 96.a. The sampling plan was modified on May t5,2023,
and is being submitted for approval. HF Sinclair will implement the revised plan in the first full quarter,
3Q 2023, following this submission.
During an internal review of the BWON Sampling Plan, it was determined that a number of sample
points involving individual fuelgas coalescers and knockouts originate from a common upstream waste
source. The upstream waste source was sampled and found to contain the same relative concentration
of benzene as the downstream sources. The sampling plan has been modified to remove the following
samplepoints:4V43,6V24,8V23,19V5,20V18,2OV2O,and24V10andtoreplacethesepointswiththe
singular upstream waste POGTOV? FuelGas Mix Drum. This new point willaccount for allthe waste
volume that was previous accounted for at the removed points. ln addition, HF Sinclair has added six (6)
additional streams to the BWON SAP that were not previously sampled annually. These streams are
denoted in Table 1of the attached BWON SAP.
HF Sinclair has also made some minor language changes to the SAP to reflect the name change of the
company, and naming conventions of various equipment to better reflect the sampling plan's intent.
HF Sinclair Woods Cross Refining LLC
1070 W. 500 S, West Bountiful, UT 84087
801 -299-6600 | HFSinclair.com
REVIEWEDInitials: Date: November 14, 2024Compliance Status: OKFile #: 10123 (B2) Comment: FFY2023
Sincerely,
'M4r^;'*
,/.t/o.ni"tron
Vice President and Refinery Manager
Enclosure
c: Director, Air Enforcement Division Air Program Director
Office of Civil Enforcement Office of Enforcement, Compliance & Environmental Justice
c/o Matrix New World Engineering lnc. Environmental Protection Agency, Region 8
26 Columbia Turnpike, 2nd Floor 1595 Wynkoop Street
Florham Park, NJ 07932 Denver, CO 80202-LL29
Megan J. Houdeshel T. Jones
Dorsey & Whitney LLP R. Bagherian
111 S. Main Street, Suite 2100 E. Benson (4) File 2.6'3'1'093
Salt Lake CitY, UT 84111-2175
ec: [e-mail]
[e-mail]
[e-mail]
HF SINCLAIR WOODS CROSS REFINERY
SAMPLING AND ANALYSIS PLAN
FOR BENZENE WASTE OPERATION NESHAP
(BwoN)
Revised May 2023
HF Sinclair Woods Cross Refining LLC
1070 West 500 South
West Bountiful, UT 84087'1442
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TABLE OF CONTENTS
I. INTRODUCTION ....................... I
il. SAMPLE LOCATIONS AND SCHEDULE............... ...................... I
ru. SAMPLING PROCEDURES ..,...4
A. Equipment and Materials............. -...----...4
B. Preparation ..........5
C. Field Sampling.......... .....'.....5
l) Cooling Coil Sampling Protoco1.............. ..........5
2) Grab Sampling Protoco1.............. .......................5
3) Sample Handling... .........6
Appendix A EXAMPLE FIELD SAMPLE DATA SHEET ..............-......7
List of Tables
Table I BWON Sampling Points....... '................... I
BWON Sampling and Analysis Plan for TAB Calculation - Revision 10 May 2023
Page ii
I. INTRODUCTION
This document provides the Sampling and Analysis Plan (SAP) for determining benzene
concentrations in wastewater streams at the HF Sinclair Woods Cross Refining LLC Refinery.
The HF Sinclair refinery is located at 1070 West 500 South, West Bountiful, Utah. Specific
components to the SAP include:
o Identification of sample locations
o Priority of sample locations
o Schedule of sampling
o Criteria for locations proposed to be sampled
The plan ensures there is a methodology in place that
Annual Benzene (TAB) at the facility.
II. SAMPLE LOCATIONS AND SCHEDULE
for each calendar quarter
will support the calculation of Total
This SAP lists sampling locations used in calculating projected quarterly and annual TAB
calculations. A minimum of ten streams will be sampled each calendar quarter. The priorities of
the streams to be sampled are identified in Table 1.
If the annual TAB reveals that a stream consists of 0.05 Mdyr or greater benzene, then that
stream will be sampled every subsequent quarter after identification in the previous year's annual
TAB. If a stream drops below 0.05 Mg/yr as calculated in the annual TAB, it will be evaluated
for potential removal from sampling every quarter. Table I will be revised periodically to reflect
this evaluation.
Streams expected or determined to contribute less than 0.05 Mdyr will be sampled by priority.
Each new quarter starts at the point in the priority following the last sample taken in the previous
quarter (e.g., if #s 11 - 20 are sampled during a quarter, then the next rotating stream to be
sampled starts at #21). ln the event a sample is skipped because, for example, there is no flow,
or there is no aqueous waste where only water is tlpically drained, then that sample point will be
included first in the following quarter before the normal continuation point in the list.
Table I BWON Sampling Points
I Note: indicates waste streams thdt contributed to 0.05 Mgltr or more at the Point of Generalion
$rnple
Nrinber
UoIt
Number Srrlple Dercripton Srmple laodon
,Fkiw
Pqta-r4!!tdouMi*liod. ,
I 8 Unit 8 Crude Desalterl /r" pipe, male, south end 841-0160 Measured
2 8 ED Crude Desalterr '/o" drain off 4" line on inlet to 8P28 Recycle
Pumo Measured
J 24 Unt24 Crude Desalterr drain after 24PlllllA. 3/4" valve , female,
olussed Measured
BWON Sampling and Analysis Plan for TAB Calculation - Revision l0 May 2023
Page 1
Strnple
Numbor
Unlt
Numbsr Souple Dcecrtpfiol srnplel,oq0q!
4 LOD Light Oil Dock Manhole at Light Oil Dock Estimated
5 68 Tank 135 Cat gas water draw South side, 2" OD female Estimated
6 68
Tankl29 Naphtha
hydrodesulfu rization water
draw
South side, 2.5" OD male; NW side,4" OD
female; NE side, l3/q" OD male Estimated
7 68 Tank 13l Stove oil water draw South side, 2" OD female Estimated
8 68 Tank l0l CAT gas water draw South side, 2" OD female Estimated
9 68 Tank 100 Reformate water
draw South side, 2" OD female Estimated
l0 68 Tank 132 Gasoline water draw South side, 2" OD female Estimated
ll 68 Tank 109 Alkylate water draw South side,2" OD female Estimated
t2 68 Tank 108 Gasoline water draw South side, 2" OD female Estimated
r3 68 Tank 128 Jet fuel water draw South side, 2" OD female Estimated
l4 68 Tank 102 Crude oil water
draw South side, 2" OD female Estimated
l5 68 Tank 103 Gas oil water draw South side, 2" OD female Estimated
l6 68 Tank 107 Gasoline water draw West side, 3" OD female Estimated
t7 68 Tank 105 High reformate
water draw South side, 3" OD female Estimated
l8 68 Tank 145 Gasoline water draw South side, 2 OD female Estimated
l9 68 Tank 104 Isomerate water
draw South side, 3.5" OD female Estimated
20 68 Tank 146 Gasoline water draw South side, 2 OD female Estimated
2t 68 Tank 106 Gasoline water draw South side, 2" OD female Estimated
22 68 Tark126 Crude oil water
draw South side, 2" OD female Estimated
23 68 Tank 121 Crude oil water
draw South side, 2" OD female Estimated
24 68 Tank 7l Crude Oil water draw South side, 2" OD female Estimated
25 68 Tar*72 Gasoline water draw South side,2" OD female Estimated
26 7 U7 Alkylate SCS2 l/2" Pipe, Male Estimated
27 7 Regeneration Column 7V5 l" Pipe, Male Estimated
May2023
Page 2
BWON Sampling and Analysis Plan for TAB Calculation - Revision
$upls
NumFer
Uxtt
Itlumbtr SrnpleQesprlpttoa Srqplelocrdim
28 7 ASO Neutralization Drum
7Y28 l" Pipe, Male Estimated
29 7 Olefin Coalescer 7V34 l" Pipe, Male Estimated
30 l0 Solvent Comp. Dis. Bottles
(lst Stase) l0Kl 1" Pipe, Male Estimated
31 l0 Solvent Compressor Suction
KO Drum l0V9 l" pipe, male Estimated
32 t0 High Pressure Solvent
Receiver l0V6 HP Sol. Rec. Drain Pot 10V14 Estimated
3)l0 low Pressure Solvent
Receiver l0V7 LP Sol. Rec. Drain Pot 10V14A Estimated
34 lt Ul l Sand Towel l" Pipe, Male Estimated
35 ll Straight Run Gas Comp. Dis.
Bottles (lst Staee) llK2 l" Pipe, Male Estimated
36 ll Depentanizer Reflux
Accumulator llV3 before I lP5 Estimated
37 l1 Depropanizer Accumulatorttvt2 I /2" pipe, no threads Estimated
38 1l SRG Comp. lst Stage Suction
Scrubber llV24 3/t" ID valve, female Estimated
39 t2 Hydrogen Recycle
Compressor l2K1 1" Pipe, Male Estimated
40 t3 l3vl0 H2 Compressor KO
Pot2 l" Pipe, Male Estimated
41 l3 Feed Splitter OH Accumulator
t3Y2
2 Yz" or 1" OD pipes, no threads, leaking
vaDors Estimated
42 18 Sour Water Stripper /r" pipe, male, north end of stripper Estimated
43 l9 Salt Dryer 19V12 l" Pipe, Male Estimated
45 t9 Diesel Coalescer l9V9 1" Pipe, Male Estimated
46 22 Ammonia Stripper 22V3 /r" pipe, male, north end of stripper Estimated
47 25 25V13 Wet Gas Compressor
Suction Drum2 l" Pipe, Male Estimated
48 26 Water Blowdown Drum
26V18 l" Pipe, Male Estimated
49 66 66V14 North Flare Seal
Drum2 l" Pipe, Male Estimated
50 66 66V15 South Flare Seal
Drum2 l" Pipe, Male Estimated
51 '70 70V2 Fuel Gas Mix Drum2 l" Pipe, Male Estimated
2 Note: Indicates uraste streom that were added in this revision of the SAP
BWON Sampling and Analysis Plan for TAB Calculation - Revision l0 May2023
Page 3
All sampling is intended to be collected in the water phase and with a cooling coil. However, as
discussed below, grab sampling may be more appropriate for some sample locations.
A number of methods were used to determine wastewater rates and benzene concentrations. In
most cases, concentrations have been measured by taking representative samples of the waste
streams. Where samples had not been taken, approximate concentrations from similar streams
were used. Rates were determined using meters, other measuretnents, or other estimates of
knowledgeable personnel. For example, rates from the Unit 8 Desalter are determined by meter,
while the discharge from the knock engines was determined by collecting the discharge over a
fixed period of time and then determining the discharged volume. Most other periodic sources,
such as tank water draws, sample points, and accumulator drains were estimated by operations
personnel who normally perform the draining or sampling. The estimation volume may be
updated periodically in the quarterly and projected annual TAB based on operation variations.
III. SAMPLING PROCEDURES
Prior to sampling, any personnel asked to draw benzene waste samples will be properly trained
to ensure proper knowledge of the hazards associated with sampling benzene waste streams and
in order to ensure the employee is aware of the requirements for sampling per 40 CFR
61.355(c)(l) and (3). In addition, all personnel must follow the following sampling procedures
and comply with HF Sinclair safety procedures.
A minimum of three representative samples will be taken from each waste stream collection
point. Where feasible, samples will be collected from an enclosed pipe prior to the waste water
being exposed to the atmosphere; other samples will be taken such that benzene exposure to the
atmosphere is minimized. Samples will be collected in 40 mL VOA vials with Teflon@-lined
caps supplied by the laboratory. In accordance with SW-846, VOA vials will contain an
appropriate quantity of hydrochloric acid as required for aqueous samples.
HF Sinclair decides if a static mixer is required for each sample location. The plant can use
previous experience andlor plant operations knowledge to make this determination. Cunently all
sample points were determined to provide adequate mixing of samples and do not require a static
mixer. If a static mixer is required in the future, the mixer must be installed within two pipe
diameters upstream from the sample tap. The static mixer shall be installed in the process line or
in a by-pass line unless HF Sinclair demonstrates that installation of a static mixer in the line is
not necessary to accurately determine the benzene concentration of the waste stream.
A. Equipment and Materials
The following equipment should be prepared and used during sampling activities:
o Cooling coil
o 40 mL VOA vials with HCI preservatives
o Sample labels
BWON Sampling and Analysis Plan for TAB Calculation - Revision l0 May2023
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. Ice chest with ice to immediately transfer samples into after collection
o Permanent marker to label sample containers prior to collection
o PPE including:
- Hard hat
- Steel-toed shoes
- Fire Retardant Clothing (FRC)
- Protective safetY glasses
- Nitrile gloves
o Field notebook
o Laboratoryprovided chain-of-custody
B. Preparation
Prior to proceeding into the field:
l) Record necessary data in field logbook including:
a. Date
b. Time that each sample was collected
c. Weather conditions - temperature, precipitation, etc.
d. Split sample collected
prepare sampling equipment including decontamination of coil sampler prior to use.
Move equipment and supplies to sampling location.
C. Field Sampling
The variety of waste streams and locations may require different sampling techniques.
The recommended sampling technique will incorporate collection via a condensing
cooler (or gpab sample) in accordance with USEPA Method 25D.
l) Cooling Coil Sampling Protocol
A cooling coil and condensing cooler will be used as the sampling device unless it is
determinid not to be feasible in certain streams. After the cooling coil is connected to
the sampling location the coil will be purged with 4 volumes of waste to help ensure
no contamination is present in the coil. The VOA vial should not come in physical
contact with the outlet tip of the cooling coil. The samples will be cooled to less than
lgoC and remain at or below l0'C during the duration of sampling. Prior to sample
collection, and in between each individual sample, the temperature of the waste
stream exiting the condensing cooler will be recorded. The thermometer should be
cleaned between samples to avoid contamination. Waste stream samples will be
capped, labeled, and placed on ice within the ice chest for delivery to a qualified
May 2023
Page 5
2)
3)
BWON Sampling and Analysis Plan for TAB Calculation - Revision l0
2)
laboratory. Samples and chain-of-custody forms will be prepared as described in
Appendix A.
Grab Sampling Protocol
Certain waste streams that cannot be sampled using the cooling coil may be sampled
in a manner to minimize exposure of the sample to the atmosphere, as follows.
Aqueous and organic samples will be collected following protocols established in the
SW 846 sampling methods as site conditions dictate. Prior to collecting the sample,
each sample line will be purged with 4 volumes of waste to help ensure no
contamination is present. Each sample will be collected, either directly into a clean
40 mL VOA vial or using a laboratory-provided container, capped immediately, and
then transferred to a clean 40 mL VOA vial where it will be capped immediately and
placed on ice for delivery to the lab. Sampling equipment will be disposable and will
not require decontamination following the completion of each sampling event.
Sample Handling
Following sample collection, all sample containers will be labeled with the following
information, ffid then placed into a cooler with ice and delivered to the lab for
analysis along with a filled out chain of custody:
. Sample identification;
o Date and time of collection;
o Place of collection;
o Required preservatives.
3)
BWON Sampling and Analysis Plan for TAB Calculation - Revision 10 May2023
Page 6
Appendix A
EXAMPLE FIELD SAMPLE DATA SHEET
BWON Sampling and Analysis Plan for TAB calculation - Revision l0 May 2023
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FIELD SAMPLE DATA SHEET
BWON SAMPLING
UNIT NUMBER/SAMPLE DESCRIPTION :
SAMPLE LOCATION:
SAMPLE ID NUMBER:
DUPLICATE ID NUMBER:
Weather
SAMPLE DATA
Sunny Cloudy Rain ? | Temperature:"F _"c
Date Time Temperature of
sample
Duplicate
Collected
Rinsate
Collected
Product Thickness
Bottle Type v Amount & Volume Preservative Filter Phase
VOA Glass 40 ml HCI No
VOA Glass 40 ml HCI No
VOA Glass 40 ml HCI No
Total Bottles
Notes:
Sampled By:Signature:
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