DAQ-2024-011549

rt ,.dttF$nctorr
January 31,2023
Director, Air Enforcement Division CERTIFIED MAIL: 7019 1120 0000 0070 7814
Offrce of Civil Enforcement
U.S. Environmental Protection Agency
Mail Code 2242-A UTAH DEpARTM1:NT oF
1200 Pennsylvania Avenue, N.W. ENVIR6NtuIENTAL ouAUry
Washington, DC 20460-0001
Executive Secretary, Utah Air Quality Board F EE 3 '1i"'i3
Division of Air Quality
195 North 1950 West
P.o. Box 144820 DlvlsloN oF AIR QUALITY
salt Lake city, uT 84114-4820
RE: Semiannual Progress Report
Consent Decree Entered July 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 (HollyFrontier Woods Cross Relining LLC,IIFWCR)
Dear Director and Executive Secretary:
In accordance with Paragraphs 135,747, aloid 149 of the subject consent decree, this submittal provides
the progress report for the Woods Cross Refinery for the semi-annual period from July 1 through
December 31,2022.
ln accordance with Paragraph 149d, the following certification is provided:
I certiff under penalty of law that this information was prepared under my direction or supervision by
personnel qualified to properly gather and evaluate the information submitted. Based on my directions
and after reasonable inquiry of the person(s) directly responsible for gathering the information, the
inforrration submitted is, to the best of my knowledge and belief, true, accurate, and complete.
In accordance with Paragraph 261, copies of this report are also provided to EPA Region 8 and other
required government representatives.
Sincerely,ffitu
Vice President and Refinery Manager
HF Sinclair Woods Cross Refining LLC
1070 W. 500 S. West Bountiful, UT 84087
801 -299-6600 | HFSinclair.com
REVIEWEDInitials: Date: Nov14, 2024Complinace Status:OKFile #: 10123 (B2) Comment:FFY 2023
I
Rt-lL
January 31,2023
Director, Air Enforcement Division, et. al.
Page2
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UTAH DEPABTMENT OF
ENVIBONMENTAL OUAUTY
FEB - 3 2C23
Progress Report on the lmpleDBilfiBlG)ilto(lfe ndftaeH$$Y
of Part V (Affirmative Relief/Environmental Projects)
cDf Requirement Status/Comment
Section V.A. NOx Emissions Reductions from the FCCU
L2 Submit detailed design for NOx Control
System bv L2l3tltO.Complete. Design sent 1U15l10.
13 lnstall and begin operation of NOx Control
Svstem bv L2l3LlL2.Complete. Operation began LOl27 I 72.
14
Commence 15-month interim
demonstration period to determine
interim FCCU NOx limit by 4/UO9.
Data collection for NOx emissions from the
FCC began 4lt/Og and was completed
6/30170.
15
Report results of interim NOx
demonstration by 90 days following
oeriod.
Complete. lnterim report sent 9/29170.
16 Propose and comply with 7-day and 365-
day interim NOx limits.
Complete. lnterim NOx limits proposed in
interim report of 180 ppm 7-day average and
110 oom 355-dav averase.
t7
Comply with or dispute EPA-established
interim NOx limits within 90 days of
receiot.
EPA-established limits received and complied
with until final limits were set.
19
Commence 15-month demonstration
period upon startup of NOx Control System
to determine final FCCU NOx limit.
Complete. Final demonstration period
concluded on 3l3O/74.
20 Report results of final NOx demonstration
bv 90 davs followine oeriod.Complete. Final report sent 5/7 /74.
27 Propose and comply with 7-day and 365-
day final NOx limits.
Complete. Final NOx limits proposed in final
report of 80 ppm 7-day average and 40 ppm
365-day average and monitoring.
22 Comply with or dispute EPA-established
final NOx limits within 90 days of receipt.
Final limits submitted to EPA on 5/7 /74. EPA
established final NOx limits, received
LL/17/2O, of40 ppm 7-day average and 22.5
ppm 355-day average. We are complying
with those limits.
23 Use NOx and Oz CEMS to monitor FCCU
oerformancebv 4/tlO9.
Complete. NOx and Oz CEMS installed and
collectine emissions data 4/LlO9.
Section V.B. SOz Emissions Reductions from the FCCU
25
lnstall and begin operation of a Wet Gas
Scrubber at the FCCU by L2/3L/72 and
meet 25 ppm (355-day) and 50 ppm (7-
day)by 6l3olt3.
Complete. Wet Gas Scrubber installed
tol27l72. We are complying with these limits.
26
Commence 15-month interim
demonstration period to determine
interim FCCU SOz limit by 4l7l19.
Complete. Data collection for SOz emissions
from the FCC began 4lL/O9 and was
completed 6130ltO.
.l
CDfl Requirement Status/Comment
27
Report results of interim SOz
demonstration by 90 days following
oeriod.
Complete. lnterim report sent 9/291 70.
28 Propose and comply with 7-day and 365-
day interim SOz limits.
Complete. lnterim SOz limits proposed in
interim report of 150 ppm 7-day average and
50 ppm 365-dav averase.
29
Comply with or dispute EPA-established
interim SOz limits within 90 days of
receiot.
EPA-established limits received, and complied
with those limits untilthe lower limits became
effective.
31 Use SOz and Oz CEMS to monitor FCCU
performancebv alilO9.
Complete. SOz and Oz CEMS installed and
collecting emissions data 4lL/O9.
Section V.C. PM Emissions Reductions from the FCCU
32
Comply with limit of 1.0 pounds PM per
1000 pounds coke burned for FCCU by
6130113.
Complete. PM performance testing
completed on L2/2OlL2. Report sent to EPA
u23113.
33
lnstall and begin operation of a Wet Gas
Scrubber at the FCCU bV 72/3UL2.
Comply with limit of 0.5 pounds PM per
1000 pounds coke burned for FCCU by
6/30113.
Complete. PM performance testing
completed on 72/2O/L2. Report sent to EPA
tl23lt3.
35
Perform PM test on FCCU by 7O/3t/L3 and
annually thereafter by 10/31. Submit
results in next semiannual report.
lnitial PM performance testing completed on
t2l20/12. Results sent to EPA under separate
cover letter L/23/13. First annual PM test
completed 7O/22/L3. Second annual PM test
completed 71l2lt4. Third annual PM test
completed 70/22/15. Fourth annual PM test
completed 72/71L6. Fifth annual PM test
completed 7O/25/L7. Sixth annual PM test
completed 70/t9lt8. Seventh annual PM test
completed 9/4179. First triennial PM test
completed 6/L412O22. Request to reduce
testing frequency was submitted to USEPA
61261L8. Request for triennial testing granted
9l6lL9.
Section V.D. CO Emissions Reductions from the FCCU
36 Comply with 500 ppm CO (1-hour)at FCCU
bv L213U09.Complete. Monitoring CO emissions.
37 Option to comply with 100 ppm CO (365-
davl at FCCU.Option is not currently under consideration.
39 Use CO and Oz CEMS to monitor FCCU
performanc e bv L2/ 37/ 09.
Complete. CO and Oz CEMS installed and
collecting emissions data 4/LlO9.
Section V.E. NSPS Applicability of the FCCU Catalyst Regenerator
1l
cD1 Requirement Status/Comment
41 FCCU subject to NSPS for CO by L2/3UO9,
and for SOz and PM by 61301L3.
CO limit complete,500 ppm CO (1-hour) at
FCCU. Wet Gas Scrubber installed and now
complying with SOz and PM NSPS limits.
43 lnstall and operate a COMS on the FCCU by
t2/3L/72 or comply with 1144.
Complete. Alternate Monitoring Plan (AMP)
request sent to EPA 41L2172. Revised AMP
request sent to EPA9127/12. AMP approval
received 10/24112.
44 Request an AMP for monitoring opacity
from the FCCU or comply with fl43.
Complete. Alternate Monitoring Plan (AMP)
request sent to EPA4lt2l72. Revised AMP
request sent to EPAgl2T/72.
Section V.F. NOx Emissions Reductions from Heaters and Boilers
46a
lnstall Next Generation ULNBs or
alternative NOx Control Technology on
6H1, or convert the Clark compressor
driver to electric, or replace the Clark
compressor with an electric-driven
compressor bV t2 / 3L/O9.
Complete. Clark compressor was replaced by
electric driven compressor 11K2. lnstallation
was complete LLltT/09.
46a
lnstall Next Generation ULNBs or
alternative NOx ControlTechnology on 8H1
bv 72/3Llo9.
Complete. lnstalled bV 9l9lOA.
46a
lnstall Next Generation ULNBs or
alternative NOx Control Technology on
12H1by t2/3L/o9.
Complete. lnstalled bV 9/7/O8.
46a
lnstall Next Generation ULNBs or
alternative NOx Control Technology on #5
Boiler bv 12/31109.
Complete. Selective Catalytic Reduction (SCR)
alternative NOx Control Technology was
installed on #5 Boiler on t2l3olO9.
46a
lnstall Next Generation ULNBs or
alternative NOx ControlTechnology on the
CO Boiler bV L2l3tltZ if disengaged from
FCCU.
Complete. CO Boiler disengaged from FCCU
tol26/72. CO Boiler shut down permanently.
46a
lnstall Next Generation ULNBs or
alternative NOx Control Technology on
Boiler #8bv L2/3L/12.
Complete. Boiler shutdown on L2/3LlL2 and
restarted tlLO/L3 with Selective Catalytic
Reduction (SCR) installed.
46a
lnstall Next Generation ULNBs or
alternative NOx Control Technology on 4H1
bV 12137/t2 if heat input capacity is raised
above 40 mmBTU/hr.
Heat input capacity is at or below 40
mmBTU/hr.
46b(1)
lnstall and operate NOx and Oz CEMS on
heaters/boilers over 100 mmBTU lhr bV
date of NOx ControlTechnology
installation, and use to monitor emissions
bv 5 months later.
No heaters or boilers have heat input
capacities over 100 mm BTU/hr (HHV).
.I
cDf Requirement Status/Comment
46b(2)
Conduct performance tests on
heaters/boilers equal to or less than 1@
mmBTU/hr by 50 days after installation of
NOx Control Technology.
Complete. Performance test on 8H1
completed LOlglO8. Performance test on
12H1 completed tOlL3/08. Performance test
on f5 Boiler completed 2l9lL0 and retested
3l25lLO. Performance test on #8 Boiler
comoleted 4122173.
46c
Submit permit revision to State proposing
NOx emission limits (3-hour) for any NOx
Control Technology within 120 days of
start-up.
Complete. Notice of lntent for a change in
permit conditions for NOx limits on 8H1 and
12H1 submitted t2/23/08. Notice of lntent
for a change in permit conditions for NOx
limits on #5 Boiler submitted 4l29lLO.
46d
Submit annual NOx Control Technology
progress report by 72/3L beginning in
2008.
First report submitted 121L5/08. Subsequent
annual reports submitted: L2|2L/O9,
12 I 22 / LO, t2 I 22 I Ll, L2 I 2L I 12, 12 I 3L I L3,
121 3Ol L4, t2 129 I L5, t2 l28l t6, L2 I 27 I 17,
72 I 3t / L8, L2 / 30 / t9, 12 / 30 I 20, L2 I 28 I 2027,
and 1213012022.
Section V.G. SOz Emissions Reductions from and NSPS Applicability to Heaters and Boilers
48 All heaters and boilers are subject to NSPS
Subpart J.
Complete. Prior to Consent Decree, fuel gas
for all heaters and boilers being monitored by
CEM, with quarterly reporting as required by
State of Utah.
49 May use alternative monitoring method
immediatelv uoon submittalof AMP.
Complete. 2 AMPs submitted June 24, 2009.
(AMPs were subsequently rescinded.)
50
No liquid fossil fuel over 0.05% Sulfur by
weight shall be burned in any fuel gas
combustion device.
Complete. None used. lnternal memo sent
detailing limit. Copy and responses filed.
Section V.H. NSPS Applicability to the Sulfur Plant
52 NSPS shallapply if SRU exceeds 20 LTPD.Complete. Maximum SRU capacity is 10 LTPD.
Daily HzS feed shown in Attachment A.
52a lnstall and commence operation of SOz
CEMS at SRU by 712/08.
Complete. CEMS installed and operational
orior to 7l2lo8.
52a
Demonstrate daily 95% recovery (30 day)
for SRU using measured HzS in feed and
SOz emissions from CEMS.
The calculation of 95% recovery from the
sulfur recovery unit has become impractical
due to the treatment of off gas from the
sulfur recovery unit by a fluidized catalytic
cracking unit's wet gas scrubber. A detailed
summary of these changes was submitted on
619176.
(l
cDf Requirement Status/Comment
52a Determine HzS in SRU feed quarterly for 4
quarters and semiannually thereafter.
Sampling and analysis completed 9/22/08,
LOI t6 lO8, 21 6 lO9, 5 I 5 / 09, 7 129 I 09, L0 I L2/ 09,
Ll22l 10, 8/25 I LO, OLI 26 I Lt, 7 I 281 tL,
2 l28l 12, 7 / tL/ L2, 2/ 4 / L3, 7 l2l L3, 21 78/ 74,
7 15 I L4, LlzLl 15, 7 /7 I t5, and 2/9 I L6.
Sampling has been discontinued. The SRU off
gas is treated by a fluidized catalytic cracking
unit's wet gas scrubber.
52b,c
Complete SRP Optimization Study,
implement recommendations, and submit
study report within l year afterTl2/O8.
Complete. Optimization Study was completed
and report submitted 6126109. Schedule of
implementation for the report's
recommendations was included in the report
that was submitted.
52d
Submit test protocolto EPA Region 8 and
State to perform 95% recovery efficiency
and emission limit test at least 30 days
before test. Conduct test within 6 months
after completion of SRP Optimization
Studv.
SRP Optimization Study completed
6126/2009. Test protocol was submitted
LL/ 23 I 2@9. Testi ng pe rfo rmed L2 / 23 I 2009,
SRU achieved95.2% recovery and 0.42 tons
per day (830 lbs) SO2.
52e
Submit a semiannual report covering SRU
recovery, em issions, operating
parameters, and daily feed.
The calculation of 95% recovery from the
sulfur recovery unit has become impractical
due to the treatment of off-gas from the
sulfur recovery unit by a fluidized catalytic
cracking unit's wet gas scrubber. A detailed
summary of these changes was submitted on
6le/16.
52f
Submit Plan for Maintenance and
Operation of SRP within 270 days from
7l2lo8.
Complete. Plan submitted 312612009.
52h
Submit schedule to comply with NSPS
within 120 days of SRU exceeding 20 LTPD
input.
Maximum SRU capacity has not increased
beyond 10 LTPD.
54 All sulfur pit emissions routed to
incinerator.
Complete. Commenced prior to Consent
Decree.
Section V.l. NSPS Applicability to Flaring Devices
55,55a
North flare and South flare subject to NSPS
as of date of entry, eliminate all routinely-
generated gas.
Complete. Subject to NSPS prior to Consent
Decree, no routinely-generated gas sent to
flare. As of November 7L,2OL5, all streams
going to the flares are being monitored for
compliance with the NSPS Ja standard, and
are reported in the quarterlv CEMs reports.
ll
cD ct Requirement Status/Comment
56,56a south flare subject to NsPs 6130/09,
eliminate all routinely-generated gas.
Complete. Study completed on routinely-
generated gas sources and rerouting
completed. Alternative Monitoring Plans
submitted for 2 streams. (AMPs were
subsequentlv rescinded.)
56,56a Propane flare subject to NSPS 72131109,
eliminate all routinely-generated gas.
Complete. New propane flare installed
Lt/7712W9. The propane flare and
associated storage pit were decommissioned
in December of 2013.
56b
Conduct performance tests for each flare
within 180 days after bringing into
compliance with NSPS.
Performance tests for both North and South
Flares conducted December 10, 2008.
Performance test for the propane pit flare
conducted March 25, 2O7O.
57a Comply with 162 ppm HzS limit in fuel gas.Complete. Ongoing prior to Consent Decree.
Section V.J. Control of Acid Gas Flarins lncidents
59
Submit reports for Acid Gas Flaring
lncidents no later than 45 days after
incident.
No Acid Gas flaring events occurred in period.
Section V.K. Control of Hvdrocarbon Flarine lncidents
68 Submit reports for Hydrocarbon Flaring
lncidents in semiannual progress reports.
Report for the incident on 6/29/2022was
completed 81L212022 and is included as
Attachment E. Report for the incident on
LO|25/2O22 was completed 7210712022 and is
included as Attachment E.
Section V.L. CERCLA/EPCRA
69 Report any previously unreported SOz
releases bv 6/30/09.
No previously unreported SOz releases were
identified.
Section V.M. Benzene Waste Ooerations NESHAPS Prosram Enhancements
72 lf TAB exceeds 10 Mg/yr, utilize the 6BQ
compliance option.TAB remains under 10 Mg/yr.
73
Complete review and verification of
refinery's TAB and compliance by 270 days
after date of entrv.
Complete. Sampling plan, review and
verification were completed 3/18/09.
74,
103a
Submit report to the EPA and State by 60
davs after review and verification.Complete. Report submitted 5/2OlO9.
75
Conduct additional sampling and submit
results to EPA within 60 days after
receiving request from EPA.
EPA requested no additional sampling.
75,
103b
Revise report and resubmit within 120
davs after comoletion of samoline.Original report deemed final.
aa
cDfl Reouirement Status/Comment
76
lf revised report indicates initial report was
unsatisfactory, resubmit report to State
within 120 days after completing revised
reoort.
Original report deemed satisfactory.
77,
103c
lf revised report indicates TAB over 10
Melvr, submit plan within 180 days to
ensure future compliance or to comply
with 6BQ within 2 years.
No action required. The BWON Compliance
Review and Verification Report did not
indicate that the TAB exceeds 10 Mg/year.
79,
103d
lf actions are required under fl 77, submit
certification of compliance within 30 days
after completion of actions.
No action required. Neither the BWON
Compliance Review and Verification Report
nor current sampling pursuant to Paragraph
94 indicate that the TAB exceeds 10 Me/vear
80
Develop program within 60 days from date
of entry to annually review process/project
information to ensure all new benzene
waste streams are included in inventory.
Complete. A task to complete an annual
review was added to the automated
environmental tracking system. lnventory
reviewed on L2l3O/09, 72/27 /L0, L2/3O/17,
Lzl 27 / 72, L2 / L9 I L3, t2 I 7Ol L4, t2/ 30 / 75,
t2/ 28 I 16, L2 I 22 I L7, 3 I 24 I 78, L2/2Ll t8,
t2 / 20 I 19, 72 / 77 I 20, t2 / 30 I 27, and
6/3012022.
82,84
Conduct audits of all laboratories used for
benzene waste analysis within 27O days
after date of entry, new labs before use,
and every two vears.
Laboratory audit compl eted 3/ tL/ 7L, 31 81 13,
3 I t8 I L5, 3 I L6/ L7, 3 128 I 19, and 3 /22/2L.
85
Review spills to determine if they generate
more than 10 lbs of aqueous benzene
waste. and include in TAB.
Environmental Procedure 5.02 incorporates
review requirements.
87
Develop and begin annual training for all
employees asked to draw benzene waste
samples, complete first within calendar
year.
lnitial tra ining com pleted 05 IOL/ 09. Contract
personnel were initially used to collect
samples. Additional training completed
annually. The latest training was completed
on L2128122.
89 Ensure contractor employees hired to
perform training are adequately trained.
Completed for contract employees by
LZlLSIOS, L2l8lO9, and 1L/05/LO.
Contractors no longer used.
90,
103e
Subm it waste/slop/off-spec oil
manasement schematics Complete. Sent to State and EPAS/21/O8.
93,
103f
Submit quarterly/annual sampling plans to
EPA and State by 50 days after revised
report is finalized or original report is
acceoted.
Original report accepted. Sampling plan sent
on7l2l72.
CDfl Requirement Status/Comment
95 lmplement the sampling plan in the first
full quarter after submittal.
Complete. Sampling plan has been
implemented. The sampling plan is more
stringent than the CD in requiring quarterly
sampling for waste streams > 0.05 Mg/Vr
benzene.
96,
103f
lf changes affect the validity of the
sampling plan, submit revised plan within
90 davs.
A revised sampling plan was submitted to EPA
on 515/2L. EPA approval for that revised
sampling plan received 6/8/2L.
97 Submit quarterly and annual projected
TAB with semiannual reoort.
The quarterly and annual projected TAB is
included in Attachment B.
98
lmplement corrective measures if
quarterly TAB > 2.5 Mg or annual TAB > 10
Ms.
No excesses during this period.
99 Provide reasons why causes of excess
ouarterlv or annual TAB will not recur.No excesses during this period.
100,
103g
Submit compliance assurance plan if
quarterly TAB > 2.5 Mg or annual TAB > 10
Me.
No excesses during this period.
101
Contract 3'd party to conduct TAB study
and compliance review if quarterly TAB >
2.5 Mg or annualTAB > 10 Mg. Submit
results to EPA and State within 30 days
and imolement.
No excesses during this period.
7O4a Submit sampling results and TABs with the
semiannual report.
Sampling results and TABs are included in
Attachment B.
104b Submit description of training conducted
with the semiannual report.
Retraining completed for 2O22 by attending a
third party consultant training course and via
review of physical material based on existing
computer-based training .
104c Submit a summary of lab audits conducted
with the semiannual report.
No audits were conducted during this
semiannual period.
105 Requests to modify the frequency of
reporting under t|104.
No request has been made to modify the
frequency of reporting.
Section V.N. Leak Detection and Repair ("LDAR") Program Enhancements
109 Develop and maintain a written LDAR
program within 120 days of date of entry.
Complete. Submitted with Semi-Annual
Report dated tl28lO9.
LLO,
135a
Submit LDAR program to EPA and State in
first semiannual report.
Complete. Submitted with Semi-Annual
Report dated 1128/09.
71].a
Train employees newly assigned to LDAR
responsibilities before beginning LDAR
work.
Computer-based training is required for all
newly involved employees.
10
cD It Requirement Status/Comment
111b
Provide annual training for all employees
with specific LDAR responsibilities as
primary job function beginning within 1
vear of 7l2lo8.
Computer-based training program is required
for all employees with specific LDAR
responsibilities as their primary job function.
111c
Provide training every 3 years for all
operations and maintenance employees
beginning within 1 year of 712/08.
Training program established training for 746
employees and completed 6/2109. Training
for 150 employees completed 72/2Ll2oL7.
Training for 218 employees completed
L2/3U2O\3. Training for 173 employees
completed 12l3tl20t5. Training for 207
employees completed L2/3L/2O18. Training
for 158 employees completed 2/1/2022.3
year training for operations and maintenance
personnel typically takes place through
computer-based training (CBT). The refinery
transitioned to a new CBT software system in
late 2021. To facilitate the required training, a
training document was developed to
distribute to personnel, as an alternative.
Anti-phishing safeguards in our email
software prevented the timely distribution of
the trainine.
111d Maintain records of annual training as in 'll
111b for contract LDAR personnel.Maintained under file number 2.6.3.
1L3,
7L4
Conduct 3'd party audit of LDAR
compliance every 4 years, beginning within
12 months of date of entry.
3'd party audit conducted by ERM and report
submitted 6122/09.
113 Submit LDAR compliance certification to
EPA.
LDAR compliance certifi cation submitted
Lls/L0.
115
Conduct an internal or 3'd party audit of
the LDAR program every 4 years, beginning
within 2 years after the initial 3'd party
audit.
3'd party audit conducted 4lt8/Lt,4l8/t3,
4 / L3 1 L5, 5 / L6 / L7, 4/ Ltl L9, and 4 1 22 127.
116 LDAR audits are to be conducted in the
same calendar quarter.
Allfuture LDAR audits will be conducted the
second calendar quarter ofthe year.
tt7
lmplement steps necessary to correct
areas of non-compliance identified in the
Consent Decree required LDAR audits.
All corrective actions identified in the first
LDAR Audit conducted 5/26-29109 are
complete. Corrective actions for the second
and third audits are complete. Corrective
actions for the fourth audit are complete.
Corrective actions for the fifth audit are
complete. Corrective actions for the sixth
audit are comolete.
11
CDfl Requirement Status/Comment
120
Utilize internal leak definition of 500 ppm
for valves, except pressure relief devices,
bv LltlOg.
Complete.
tzt Utilize internal leak definition of 2,000
ppm for pumps by 7lt/LO.Complete.
122
Specify in report whether applicable
regulatory leak definition or lower internal
leak definitions are being used for leak
rates.
Applicable regulatory leak definition is used
for reporting leak rates.
L24
Make initial attempt at repair on non-
control valves with reading over 200 ppm
and remonitor.
Complete.
t25 Monitor pumps in light service monthly
beeinnins 7lLlLO.Complete.
726
Monitor valves, other than difficult to
monitor valves, quarterly beginning
uuos.
Complete.
127 Keep LDAR data in electronic database.Complete.
728 Use dataloggers/electronic data collection
for LDAR.Complete.
L29
Develop and implement a LDAR AA/aC
procedure within 90 days after date of
entry.
Complete.
130
All LDAR equipment calibrations to be
conducted per Method 27, and records
maintained for life of Consent Decree.
As specified in procedures, see Semi-Annual
Report dated L/28109, Attachment B.
131
Drift assessments performed at minimum
at the end of each shift, with remonitoring
if negative drift exceeds tO%.
Complete.
t32a
Sign off by responsible person for delay of
repair, and continued monitoring of
eouioment.
Complete.
132b
Employ "drill and tap" for valves leaking
over 10,000 ppm that cannot othenrvise be
repaired.
As required, and as specified in procedures,
see Semi-Annual Report dated 1128/09,
Attachment B.
t34
Repair or replace non-control valves that
are chronic leakers at next process unit
turnaround.
As required, and as specified in procedures,
see Semi-Annual Report dated Ll28lO9,
Attachment B.
135a Provide LDAR program information in the
fi rst semiannual report.Complete.
t2
CDfl Requirement Status/Comment
135b
Provide description of audit report for
each audit conducted in the prior year in
the semiannual report (July 31 report
onlv).
Description of audit report to be included in
semiannual report due 7 13L12023.
136
Provide information on training and on
LDAR monitoring and repairs in the regular
NESHAPS reports.
lncluded in Semiannual MACT reports
beginning January 2009.
Section V.O. lncorooration of Consent Decree Requirements into Federallv Enforceable Permits
L37a
Submit permit revision for immediate
Consent Decree requirements within 90
days of date of entry.
Notice of lntent for a change in Approval
Order (AO) conditions to incorporate Consent
Decree requirements submitted 9/79108. AO
# DAQE-AN0L0L23OO27 -09 received 7L/21O9.
L37b
Submit permit revision for other Consent
Decree requirements within 90 days of
effective date.
Notice of lntent for a change in Approval
Order (AO) conditions for NOx limits on 8H1
and l2Hl submitted L2l23lO8. AO # DAQE-
ANO101230027 -O9 received tt/ 2l 09. Notice
of lntent for a change in AO conditions for CO
limit on FCCU submitted3/291L0. AO #
DAQE-AN0101230032-10 received 8123 / 70.
Notice of lntent for a change in AO conditions
for #5 Boiler NOx limit submitted 4129170. AO
# DAQE-AN0101230035-10 received
LLlt7l20t0. Notice of lntent for a change in
AO conditions for interim NOx and SOz limits
on FCCU submitted 7tl3O/7O. AO # DAQE-
AN0101230038-10 received L2l LG |2OLO.
Notice of lntent for a change in AO conditions
for final SOz limits on FCCU submitted
5123/2OL2. Notice of lntent for a change in
AO conditions for interim NOx limits on FCCU
submitted 312312OL3. AO #DAQE-
AN101230041-13 received 11118/13. All
previous limits have been incorporated into
AO #DAQE-AN 101230052-20 received
L0l8/20.
Summary of the Emissions Data Required by the Reporting Requirements
of Part V (Affirmative Relief/Environmental Proiects)
cD !t Requirement Status/Comment
Section V.H. NSPS Applicability to the Sulfur Plant
13
52e
Submit a semiannual report covering SRU
recovery, em issions, operating
parameters, and daily feed.
The calculation of 95% recovery from the
sulfur recovery unit has become impractical
due to the treatment of off gas from the sulfur
recovery unit by a fluidized catalytic cracking
unit's wet gas scrubber. A detailed summary of
these changes was submitted on 619/L6.
Description of Any Problems Anticipated with Respect to Meeting the Requirements
of Part V (Affirmative Relief/Environmental Projects)
None for this report.
Progress Report on the lmplementation of the Requirements
of Part Vl! (State Supplemental Environmenta! Proiect)
Any Additional Matters to be Brought to the Attention of EPA and the State
None for this report.
Summary of Annual Emissions Data for the Prior Calendar Year
cD1 Requirement Status/Comment
Section Vll. State Supplemental Environmental Proiecl
145a
Contribute $130,000 for purchase of
mobile command post, which shall be
acquired within 1 year of date of entry.
Complete. Delivery of mobile command post
4/8/09. Public presentation 5/L9lO9.
145b
Submit a cost report and certification in
the semiannual report upon completion of
oroiect.
Complete. Submitted with Semi-Annual
Report dated 7 129 109, Attachment D.
L47 Provide a progress report for the SEP in
each semiannual report.
Complete. Submitted with Semi-Annual
Report dated 7 129 109, Attachment D.
cD lt Reouirement Status/Comment
Section lX. Reportins and Recordkeepins, 11149b. Emissions Data
149b
Estimation of NOx emissions for each
heater and boiler greater than 40
mmBtu/hr.
2022 Emissions data to be reported in
semiannual report due 7 /3L123.
149b
Estimate of NOx emissions as a sum for all
heaters and boilers less than 40
mmBtu/hr.
2022 Emissions data to be reported in
semiannual report due 7 /37123.
74
t49b Estimate of SOz, CO and PM emissions as a
sum for all heaters and boilers.
2022 Emissions data to be reported in
semiannual report due 7 /3t/23.
149b Estimate of SOz emissions from all Sulfur
Recoverv Plants.
2022 Emissions data to be reported in
semiannual report due 7 l3t/23.
149b SOz emissions from all acid gas flaring
incidents by flare.
2022 Emissions data to be reported in
semiannual reDort due 7 l3Ll23.
149b
NOx, SOz, PM, and CO emissions as a sum
at each refinery for all other emissions
units for which emissions information is
required to be included in the facilities'
AEI not identified above.
2022 Emissions data to be reported in
semiannual report due 7 /31/23.
Exceedances of Emission Limits
cD ll Limit Exceedances
Section X. Reporting and Recordkeeping, 11149c. Exceedances of Emission Limits
16 lnterim NOx 7-day rolling average,
corrected to 0% oxygen, from FCCU
No longer applicable. Complying with final
limits.
16 lnterim NOx 365-day rolling average,
corrected to 0% oxygen, from FCCU
No longer applicable. Complying with final
limits.
2L Final NOx 7-day rolling average, corrected
to 0% oxygen, from FCCU
3Q2022: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly
report subm itted tO/ Lg /22.
4Q2O22: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly
report submitted L/27 /23.
27 Final NOx 365-day rolling average,
corrected to 0% oxygen, from FCCU
3Q2O22: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly
report submitted t0l tgl22.
4Q2O22: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly
report submitted L/27 123.
15
CDfl Limit Exceedances
25 Final SOz 7-day rolling average, corrected
to 0% orygen, from FCCU
3Q2O22: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly
report submitted tol L8 I 22.
4Q2O22: No Emission Limit exceedances.
Total downtime of the CEM was O.$OYo of the
calendar quarter, as detailed in quarterly
report submitted Ll27 /23.
25 FinalSOz 365-day rolling average,
corrected to 0% oxygen, from FCCU
3Q2022: No Emission Limit exceedances.
Totaldowntime of the CEM was o.OOYo of the
calendar quarter, as detailed in quarterly
report submitted 7Ol 78/22.
4Q2022: No Emission Limit exceedances.
Totaldowntime of the CEM was O.OOYo of the
calendar quarter, as detailed in quarterly
report submitted 7127 123.
28 lnterim SOz 7-day rolling average,
corrected to 0% oxvgen, from FCCU
No longer applicable. Complying with final
limits.
28 lnterim SOz 355-day rolling average,
corrected to 0% oxvsen, from FCCU
No longer applicable. Complying with final
limits.
32 1.0 pounds PM per 1000 pounds ofcoke
burned from FCCU
Not applicable. Holly is subject to stricter limit
of0.5 pounds PM per 1000 pounds ofcoke
burned from FCCU.
33 0.5 pounds PM per 1000 pounds ofcoke
burned from FCCU
3Q2O22: Emission Limit exceed ed O.46Yo of
the calendar quarter. Total downtime of the
CEM was O.OO% of the calendar quarter, as
detailed in quarterly report submitted
LOILs/22.
4Q2O22: Emission Limit exceeded 0.59% of
the calendar quarter. Total downtime of the
CEM was O.OO% of the calendar quarter, as
detailed in quarterly report submitted
u27123.
36 500 ppmvd CO l-hour average at 0%
oxygen, from FCCU
3Q2O22: Emission Limit exceeded 0.05% of
the calendar quarter. Total downtime of the
CEM was O.OOYo of the calendar quarter, as
detailed in quarterly report submitted
LO/18/22.
4Q2O22: Emission Limit exceed ed O.82% of
the calendar quarter. Total downtime of the
CEM was O.0O% of the calendar quarter, as
detailed in quarterly report submitted
tl27/23.
16
cDfl Limit Exceedances
37 100 ppmvd CO 355-day average at 0%
oxvsen. from FCCU Not applicable
46c NOx 3-hour rolling average, from 8H1 Not aoolicable.
46c NOx 3-hour rolling average, from 12H1 Not applicable.
46c NOx 3-hour rolling average, from #5 Boiler Not applicable.
46c NOx 3-hour rollins averase, from CO Boiler Not applicable
46c NOx 3-hour rolling average, from #8 Boiler Not applicable
46c NOx 3-hour rolling average, from FCCU
Feed Heater Not applicable
48 162 ppm HzS 3-hour average, in fuel gas
3Q2022: Emission Limit exceeded O.32% of
the calendar quarter. Total downtime of the
CEM was 0.00o/o of the calendar quarter, as
detailed in quarterly report submitted
L0/L8/22.
4Q2O22: No Emission Limit exceedances.
Totaldowntime of the CEM was O.0O% of the
calendar quarter, as detailed in quarterly
report submitted U27 123.
52a 1.6 tons per day sulfur, from SRP
Emissions are combined with one of two FCCU
wet gas scrubber stacks. A detailed summary
of these changes was submitted on 6/9/L6.
The limit at each FCCU wet gas scrubber is
0.05 tons per day for the combined SRU tail
gas and regenerator scrubbed flue gas
streams.
59 500 pounds SOz in a 24-hour period from
acid gas flaring No incidents in period.
58 500 pounds SOz in a 24-hour period from
hydrocarbon gas flaring
Report for the incident on 612912022 was
completed 8/12/2022 and is included as
Attachment E. Report for the incident on
LOl25l2O22 was completed 12107/2022 and is
included as Attachment E.
Stack Tests - Emissions Monitored through Stack Testine
32, 33 PM from FCCU Complete. PM performance testing completed
on L2120/L2. Report sent to EPAll23/73.
46c NOx from 8H1
Complete. Stack test report submitted
L2/LSIOB to EPA and State of Utah in
accordance with fl46d.
46c NOx from 12H1
Complete. Stack test report submitted
72115108 to EPA and State of Utah in
accordance with fl45d.
77
cDfl l,Imlt Erceedances
46c NOx from #5 Boiler
Complete. Stack Testing completed U9ILO
and retestedSlzSlLO. Stack test report
submitted 4l29ll0 with Notice of lntent.
46c NOxfrom CO Boiler Not aoolicable
46c NOx from f8 Boiler Complete. Performance test completed on
41221L3.
46c NOx from FCCU Feed Heater Not applicable
18
Attachment A
SRP Summary Report
SRP Summary Report no longer included per notification submitted to the United State EPA Office of
Civil Enforcement on June 9, 2016 detailing the change in reporting for the Sulfur Recovery Unit
Attachment B
TAB Analysis Reports
BWON Samplod Wa3ie Steams and Rosullg
2022
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Attachment C
Summary of BWON Lab Audit
No BWON Laboratoryaudits conducted during this semiannual period.
Attachment D
LDAR Audit Summary
No LDAR Audits conducted during this semiannual period.
::'lilHili f.ia"nt Re port
Flaring Incident Report
of
Brief Description of lncident: Multiple Unit Shutdown After Loss of Power.
Iircident End Date: 612912022
Incident Type: tr Acid Gas (report due 45 days after end of event)
M Hydrocarbon (report due in next quarterly NSPS, semiannual CD and MACT reports)
M Excess Volume (report due in next semiannual MACT report)
M Excess HzS (report due in next quarterly CEMS report)
CD fl59. Report ilte:811312022 @S-day), l/31/23 (Semiannual CD and MACT reports)
CD 1159.a. Start dates and times flist all if multiple releases are related to a sinsle event)
Start Date Start Time End Date End Time
6t29/22 7:34 am 6t29/22 10:09 om
CD fl59.b. Emission Calculations for SOz from Flarins (round to one decimal ooint):
Constants:8.44x10-5 : fibmole HzS/379 scf HzS][64 lbs SOz/lbmole HzS][ton/2000 lbs]
0.169: fibmole HzSl379 scf HzS][.0 lbmole SOz/1 lbmole HzS][6a lb SOz/lb mole SOz]
FR: Ave. flow rate to flare durine incident (scfh)135687.4
TD: Total duration of incident (hours)t4.6
ConcHzS: Avg. conc. of HzS in gas flared (vol. fraction, scf HzS/scf sas)0.004
Tons of SOz: l"FRll-TDllConcHzSl[8.44 x 10-'l 0.6
ER: Emission rate 0bs SOz/hour): [FRllConcHzSl[0.1691 80.0
CD fl59.c. Steps taken to limit the duration and./or quantity of SOz emissions:
Operations personnel worked to safely bring down affected units as quickly as possible to
minimize flaring emissions during the outage. Following the restoration of power, Operations
brought units back online, per startup procedures.
Root Cause Analvsis (CD !159.d. and Subpart Ja)
Details of
Incident:
Following a power outage, multiple plant units were upset and had to be brought
down to minimize emissions. Plant power was restored after t hour and29 minutes.
Facility personnel then worked to safely bring units back online, per operating
procedures. During the outage, and in the hours following power restoration,
sulfurous off-gases were sent to the flare system.
Sequence
of events
in reverse
order
Result..Sulfur containine sases were sent to the flare.
...caused by..Multiple units entered a state of upset or were shutdown.
...caused bv..Power was lost to most of the facilitv.
...caused by..The capacitor at the off-site substation faulted.
...caused bv..A bird contacted RMP's bank 3 capacitor.
...caused by..
Root
Cause(s):
The power supply to the majority of the plant was intemrpted after an off-site
capacitor, operated by Rocky Mountain Power, faulted.
Flaring Incident Report
majeure?trNoMYes
Significant
contributing
causes:
At the time of the incident, a power backup line was out of service for repairs.
Corrective action required? tr Yes
MNo
If no, explain
basis for
conclusion:
Cause was offsite and outside of the control of facility personnel.
CD fl59.e. Alternative measures available to reduce the likelihood of a recurrence:
Measure I N/A
Measure 2:N/A
Measure 3:N/A
Measure I
Probable effectiveness : Good
Estimated cost: $0
Should an outside consultant be retained to assist in the analysis of altematives? tr Yes
trNo
Evaluation
of possible
changes:
Desien: N/A
Operation: N/A
Maintenance:N/A
Status:
tr Completed
tr Schedule for implementation:Commencement:
Completion:
Measure 2
Probable effectiveness: Good
Estimated cost:
Should an outside consultant be retained to assist in the analysis of altematives? tr Yes
trNo
Evaluation
of possible
changes:
Desisx: N/A
Operation: N/A
Maintenance:N/A
Status:
tr Completed
tr Schedule for implementation:Commencement:
Completion:
Measure 3
Probable effectiveness :
Estimated cost:
Should an outside consultant be retained to assist in the analysis of alternatives? tr Yes
trNo
Evaluation
of possible
changes:
Desisn:
Operation:
Maintenance:
tr Comoleted
Stutus tr Schedule for implementation:Commencement:
Flaring Incident Report
Paee 3 of3
CD fl59.h. Will corrective action take > 45 days? tr No tr Yes (followup.report to EPA w/in 30
days)
CD fl59.f. Statement Identifyine Grounds for Stipulated Penalties
fl62. Grounds
for stipulated
penalties due
to root cause
M None
tr Careless operation
tr Failure to follow written procedures
tr Equipment failure due to failure to operate and maintain equipment in
accordance with good engineering practice.
Defenses tr Force Maieure M Startup/Shutdown/Uoset
fl63. Grounds
for stipulated
penalties due
to frequency
M None
tr SOz emissions > 20.0
pounds/hour for 3
consecutive hours or more
and
tr Failure to act in accordance with PMO Plan
tr Took no action to limit duration or quantity
of SOz
tr Total of Acid Gas Flaring Incidents in rolling l2-month period >5 fN/A)
Defenses tr Force Maieure tr Malfunction M Startup/Shutdown/Upset
tf64. Grounds
for stipulated
penalties due
to cause
recurTence
M First time
tr Root cause was sudden, infrequent, and not reasonably
preventable
tr Root cause was sudden" infrequent. and reasonablv preventable
E Recurrence:Root
cause was result of
previously-identified
root cause
tr Malfunction
E Recurrence. agreed-upon malfunction
E Recurrence. corrective action plan not vet comoleted
El Recurrence. root cause investigation still underwav
Clarification on first
time or recurrence:
Defenses
M Force Majeure tr Malfunction tr Startup/Shutdown/Upset
tr Corrective action being developed tr Root cause of investieation oendins
CD fl59.e. WilyDid investigation take longer than 45 days? M No tr Yes
If ves. when will investisation be comnlete and reoort sent to EPA?
Flaring Incident Report
o
Brief Description of [ncident: l1K2 interlocked after loss of pre-lube pumD
Incident End Date: 1012512022
Incident Tlpe: tr Acid Gas (report due 45 days after end of event)
EI Hydrocarbon (report due in next quarterly NSPS, semiannual CD and MACT reports)
tr Excess Volume (report due in next semiannual MACT report)
tr Excess HzS (report due in next quarterly CEMS report)
CD fl59. Report due 121912022 (45-day),ll3ll23 (Semiannual CD and MACT reports)
CD fl59.a. Stan dates and times (list all if multiple releases are related to a single event)
Start Date Start Time End Date End Time
10125t2022 5:33 am 1012s12022 5:57 pm
CD fl59.b. Emission Calculations for SOz from Flaring (round to one decimal point):
Constants:8.44x10r : fibmole HzSl379 scf HzS][64 lbs SOz/lbmole HzS][ton/2000 lbs]
0.169 : [lbmole HzS/379 scf HzS][l.0 lbmole SOz/l lbmole HzS][64 lb SOz/lb mole SOz]
FR: Avg. flow rate to flare durine incident (scfh)146634.9
TD = Total duration of incident (hours)t2.4
ConcHzS: Avg.conc. of HzS in gas flared (vol. fraction. scf HuS/scf sas)0.006
Tons of Soz: [FRllTDllConcHzSllS.44 x t0rl 0.5
ER: Emission rate (lbs SOz/hour): lFRllConcHzSl[0.169]80.2
CD t[59.c. Steps taken to limit the duration and/or of SOz emissions:
In order to minimize emissions, Operations made numerous attempts to restart the compressor.
When that was unsuccessful, operators bypassed the compressor and worked to reduce charge in
numerous units to perform troubleshooting and repairs. Following the replacement of the pre-lube
oil pump motor, Operations lined the compressor back out and brought units back up to charge
rate.
Root Cause Analysis (CD {59.d. and Subpart Ja)
Details of
Incident:
Following a breakdown of its pre-lube oil pump, lrK2, the Straight Run Gas
Compressor, interlocked, sending off gases to the relief header. These off gases
overwhelmed the Flare Gas Recovery Unit and, in turn, proceeded to the flare stacks.
This resulted in a release of SOz from the interconnected flare system in excess of 500
lbs.
Sequence
ofevents
in reverse
order
Result Sulfur containing gases were sent to the flare.
...caused by..Flare Gas Recovery Unit was overwhelmed.
...caused by..l lPC60lA opened to the relief header.
...caused bv..l1K2 interlocked.
...caused bv..1lK2 pre-lube oil pump failed.
...caused bv..Pre-lube oil pump motor grounded.
Flaring Incident Report
o
Roott
Cause(s):
The motor of the pre-lube pump that services 1lK2 Straight Run Gas Compressor
failed and required replacement.
Force majeure? M No tr Yes
Significant
contributing
causes:
No replacement part on-site.
Corrective action required? M Yes
trNo
If no, explain
basis for
conclusion:
N/A
CD fl59.e. Alternative measures available to reduce the likelihood of a recurrence:
Measure I N/A
Measure 2:N/A
Measure 3:N/A
Measure I
Probable effectiveness: Good
Estimated cost: $N/A
Should an outside consultant be retained to assist in the analysis of altematives? tr Yes
MNo
Evaluation
of possible
changes:
Design: N/A
Operation: N/A
Maintenance: N/A
Status:
M Completed
M Schedule for implementation:Commencement: 1012512022
Completion: 1012512022
Measure 2
Probable effectiveness :
Estimated cost:
Should an outside consultant be retained to assist in the analysis of altematives? tr yes
trNo
Evaluation
of possible
changes:
Design: N/A
Operation: N/A
Maintenance: N/A
Status:
tr Completed
tr Schedule for implementation:Commencement:
Completion:
Measure 3
Probable effectiveness :
Estimated cost:
Should an outside consultant be retained to assist in the analysis of alternatives? tr Yes
trNo
Design:
Flaring Incident Report
of3
Evaluation
bf possible
Operation:
Maintenance:
Status:
tr Completed
tr Schedule for implementation:Commencement:
Completion:
CD fl59.f. Statgment Identi&ing Grounds for Stipulated penalties
fl62. Grounds
for stipulated
penalties due
to root cause
EINone
tr Careless operation
tr Failure to follow written procedures
tr Equipment failure due to failure to operate and maintain equipment in
accordance with good engineering practice.
Defenses tr Force Maj )ure tr Startup/Shutdown/Upset
!f63. Grounds
for stipulated
penalties due
to frequency
EI None
tr SOz emissions > 20.0
poundsftrour for 3
consecutive hours or more
and
tr Failure to act in accordance with PMO Plan
tr Took no action to limit duration or quantity
ofSOz
tr Total of Acid Gas J&4qglnqrdqrts in rolling l2-month period >5 rN/A)
Defenses tr Force Majeure tr Malfunction tr Startup/Shutdown/upset
J[64. Grounds
for stipulated
penalties due
to cause
reculTence
BI First time
EI Root cause was sudden, infrequent, and not reasonably
preventable
tr Root cause was sudden, infrequent, and reasonablv preventable
tr Recurrence: Root
cause was result of
previously-identified
root cause
tr Malfunction
tr Recurrence, agreed-upon malfunction
tr Recurrence, corrective action plan not yet comoleted
tr Recurrence, root cause investigation still underwav
Clarification on first
time or recurrence:
Defenses
tr Force Majeure M Malfunction
tr Corrective action being developed
tr Startup/Shutdown/Upset
tr Root cause of investigation pending
CD fl59.g. WilVDid investigation take longer than 45 days? EI No tr yA
If yes, when will investigation be complete and report sent to EpA?
CD fl59.h. Will corrective action take > 45 days? EI No tr Yes (followup repon to EpA '6,7i1 30
days)
UTAH DEPAHTMENT OF
ENVIRONMENTAL OUAUTY
FEB -J 2C2:3
DIVISION OF AIR QUALTTY