DAQ-2024-011550

,.tttF$nctur
Director, Air Enforcement Division
Office of Civil Enforcement
U.S. Environmental Protection Agency
Mail Code 2242-A
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460-0001
Executive Secretary, Utah Air Quality Board
Division of Air Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, UT 841l6-4820
, l,
July 3l ,2023
CERTIFIED MAIL: 7022 0410 0002 3551 6417
_UTAH DEPARruENT OFENVIRONMENTAL QUAUTY
AllG _ 3 2023
IIIVI.SION OF AIR QUALITY
RE: Semiannual Progress Report
Consent Decree Entered July 2, 2008 in the U.S. District for the District of Utah
United States of America, State of Utah v. Holly Refining & Marketing Company - Woods
Cross
Dear Director and Executive Secretary:
In accordance with Paragraphs 135, 147, and 149 of the subject consent decree, this submittal provides
the progress report for the Woods Cross Refinery for the semi-annual period from January I through June
30,2023.
ln accordance with Paragraph 149d, the following certification is provided:
I certi$ 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
information 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,#4aJbff Danielson
Vice President and Refinery Manager
HF Sinclair Woods Cross Refining LLC
1070 W 500 S, Wesl Bountiful UT 84087
801 -299-6600 | HFSinclair.com
REVIEWEDInitials: Date: Nov 14, 2024Compliance Status:OKFile #: 10123 (B2) Comment: FFY 2023
tl I
hly 31,2023
Director, Air Enforcement Division, et. al.
Page2
ci Director, Air Enforcement Division Air Program Director
Office of Civil Enforcement OIfice of Enforcement, Compliance & Environmental Justice
c/o Matrix New World Engineering Inc. Environmental Protection Agency, Region 8
26 Columbia Tumpike,2d Floor 1595 Wynkoop Sheet
FlorhamPark,NJ 07932 Denver, CO 80202-ll}9
Megan J. Houdeshel T. Jones
Dorsey & Whitney LLP R. Bagherianlll S, Maiu Street, Suite 2100 E. Benson (4) File 2.6.3.1.149
salt Lake ciqy, uT 84lll-2176
ec: [e-mail]
foley.patrick@epa. eov
gallaeher.bob@epamail. epa. sov
T. Go
Progress Report on the Implementation of the Requirements
of Part V (Affirmative Relief/Environmental Projects)
CD tI Reouirement Status/Comment
Section V.A. NOx Emissions Reductions from the FCCU
t2 Submit detailed design for NOx Control
Svstem bv l2l3lll0.Complete. Design sent I l/15/10.
l3 Install and begin operation of NOx Control
Svstem bv l2l3lll2.Complete. Operation began l0 I 27 I 12.
t4
Commence I S-month interim
demonstration period to determine interim
FCCU NOx limit bv 411109.
Data collection for NOx emissions from the
FCC began 4lll09 and was completed 6130110.
15 Report results of interim NOx
demonstration bv 90 davs followine period.Complete. Interim report sent 9129110.
t6 Propose and comply with 7-day and 365-
day interim NOx limits.
Complete. Interim NOx limits proposed in
interim report of 180 ppm 7-day average and
I l0 oom 365-dav averase.
t7
Comply with or dispute EPA-established
interim NOx limits within 90 days of
receipt.
EPA-established limits received and complied
with until final limits were set.
19
Commence I S-month demonstration period
upon startup of NOx Control System to
determine final FCCU NOx limit.
Complete. Final demonstration period
concluded on3130114.
20 Report results of final NOx demonstration
bv 90 davs followins oeriod.Complete. Final report sent 517 I 14.
2t 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-dav averase and monitorins.
22 Comply with or dispute EPA-established
final NOx limits within 90 days of receipt.
Final limits submitted to EPA on 5l7ll4. EPA
established final NOx limits, received
llll7l20, of 40 ppm 7-day average and22.5
ppm 365-day average. We are complying with
those limits.
23 Use NOx and Oz CEMS to monitor FCCU
performance bv 4lll09.
Complete. NOx and Oz CEMS installed and
collecting emissions data 4l I 109.
Section V.B. SOz Emissions Reductions from the FCCU
25
Install and begin operation of a Wet Gas
Scrubber at the FCCU by l2l3lll2 and
meet25 ppm (365-day) and 50 ppm (7-
dav) bv 6130113.
Complete. Wet Gas Scrubber installed
l0l27l12. We are complying with these limits.
26
Commence I S-month interim
demonstration period to determine interim
FCCU SOz limit bv 4lll09.
Complete. Data collection for SOz emissions
from the FCC began 4lll09 and was
comoleted 6130110.
27 Report results of interim SOz
demonstration by 90 days following period.Complete. Interim report sent 9129110.
CD TI Reouirement Status/Comment
28 Propose and comply with 7-day and 365-
day interim SOz limits.
Complete. Interim SOz limits proposed in
interim report of 160 ppm 7-day average and
50 ppm 365-dav averase.
29
Comply with or dispute EPA-established
interim SOz limits within 90 days of
receipt.
EPA-established limits received, and complied
with those limits until the lower limits became
effective.
3l Use SOz and Oz CEMS to monitor FCCU
oerformance bv 4lll09.
Complete. SOz and Oz CEMS installed and
collectins emissions data 4l I 109.
Section V.C. PM Emissions Reductions from the FCC
32
Comply with limit of 1.0 pounds PM per
1000 pounds coke bumed for FCCU by
6130113.
Complete. PM performance testing completed
on l2l20l12. Report sent to EPA 1123113.
JJ
Install and begin operation of a Wet Gas
Scrubber at the FCCU by l2l31ll2.
Comply with limit of 0.5 pounds PM per
1000 pounds coke burned for FCCU by
6130fi3.
Complete. PM performance testing completed
on 12120112. Report sent to EPA ll23l13.
35
Perform PM test on FCCU by l0/31/13 and
annually thereafter by l0/31. Submit
results in next semiannual report.
Initial PM performance testing completed on
l2l20l12. Results sent to EPA under separate
cover letter ll23l13. First annual PM test
completed l0l22ll3. Second annual PM test
completed l0l2ll4. Third annual PM test
completed l0l22l15. Fourth annual PM test
completed l2l7l16. Fifth annual PM test
completed 10125117. Sixth annual PM test
completed l0ll9ll8. Seventh annual PM test
completed 9l4ll9. Eighth PM test completed
7114122. Request to reduce testing frequency
was submitted to USEPA 6126118. Request for
triennial testins sranted 9l6l19.
Section V.D. CO Emissions Reductions from the FCCI
36 Comply with 500 ppm CO (l-hour) at
FCCU bv l2l3ll09.Complete. Monitoring CO emissions.
37 Option to comply with 100 ppm CO (365-
dav) at FCCU.Option is not currently under consideration.
39 Use CO and Oz CEMS to monitor FCCU
oerformance bv 12131 109.
Complete. CO and Oz CEMS installed and
collectins emissions data 41 1 109.
Section V.E. NSPS Aoolicabilitv of the FCCU Catalvsl Resenerator
4t FCCU subject to NSPS for CO by
12131109, and for SOz and PM by 6130113.
CO limit complete, 500 ppm CO (l-hour) at
FCCU. Wet Gas Scrubber installed and now
comnlvins with SOr and PM NSPS limits.
43 Install and operate a COMS on the FCCU
by l2l31l12 or comply with fl44.
Complete. Altemate Monitoring Plan (AMP)
request sent to EPA4ll2ll2. Revised AMP
request sent to EPA9127ll2. AMP approval
received 10/24112.
CD tI Requirement Status/Comment
44 Request an AMP for monitoring opacity
from the FCCU or comply with fl43.
Complete. Altemate Monitoring Plan (AMP)
request sent to EPA4ll2l12. Revised AMP
request sent to EPA9127ll2.
Section V.F. NOx Emissions Reductions from Heaters and Boilers
46a
Install Next Generation ULNBs or
alternative NOx Control Technology on
6H 1, or convert the Clark compressor
driver to electric, or replace the Clark
compressor with an electric-driven
compressor bv l2l3ll09.
Complete. Clark compressor was replaced by
electric driven compressor I lK2. Installation
was complete lll17l09.
46a
Install Next Generation ULNBs or
alternative NOx Control Technology on
8Hl bv l2l3ll09.
Complete. Installed by 919108.
46a
Install Next Generation ULNBs or
alternative NOx Control Technology on
12Hl bv l2l3ll09.
Complete. Installed by 917108.
46a
Install Next Generation ULNBs or
alternative NOx Control Technology on #5
Boiler bv l2l3ll09.
Complete. Selective Catalytic Reduction
(SCR) alternative NOx Control Technology
was installed on #5 Boiler on 12130109.
46a
Install Next Generation ULNBs or
alternative NOx Control Technology on the
CO Boiler by l2l3ll12 if disengaged from
FCCT].
Complete. CO Boiler disengaged from FCCU
10126112. CO Boiler shut down permanently.
46a
Install Next Generation ULNBs or
alternative NOx Control Technology on
Boiler #8bv 12l3lll2.
Complete. Boiler shutdown on l2l3lll2 and
restarted lll0ll3 with Selective Catalytic
Reduction (SCR) installed.
46a
Install Next Generation ULNBs or
alternative NOx Control Technology on
4H1 by l2l31ll2 if heat input capacity is
raised above 40 mmBTU/hr.
Heat input capacity is at or below 40
mmBTU/hr.
46b(l)
Install and operate NOx and Oz CEMS on
heaters/boilers over 100 mmBTU/hr by
date of NOx Control Technology
installation, and use to monitor emissions
by 6 months later.
No heaters or boilers have heat input
capacities over 100 mm BTU/hr (HHV).
46b(2)
Conduct performance tests on
heaters/boilers equal to or less than 100
mmBTU/tr by 60 days after installation of
NOx Control Technology.
Complete. Performance test on SHl completed
1019108. Performance test on 12Hl completed
l0/13/08. Performance test on #5 Boiler
completed 2l9ll0 and retested 3125110.
Performance test on #8 Boiler completed
4122n3.
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 Intent for a change in
permit conditions for NOx limits on 8Hl and
l2Hl submitted,12123108. Norice of Intent for
a change in permit conditions for NOx limits
on #5 Boiler submitted 4129110.
CD 'II Resuirement Status/Comment
46d
Submit annual NOx Control Technology
progress report by l2l31 beginning in
2008.
iirst report submitted l2ll5l08. Subsequent
mnual reports submitted: l2l2l 109, l2l22l 10,
t2l22l I t, 12121 I 12, t2l3t I 13, t2l30l 14,
l2l29 l t5, t2l28l t 6, t2l27 l t7, t2l3 U t8,
l2l 30 I 19, t2t 30 120, 12128 t2021, and
t213012022.
Section V.G. SOz Emissions Reductions from and NSPS Applicabilitv 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 upon submittal of AMP.
Complete. 2 AMPs submitted June 24,2009.
(AMPs were subsequently rescinded.)
50
No liquid fossil fuel over 0.050/o Sulfur by
weight shall be burned in any fuel gas
combustion device.
Complete. None used. Internal memo sent
detailing limit. Copy and responses filed.
Section V.H. NSPS Applicabilitv to the Sulfur Plant
52 NSPS shall apply if SRU exceeds 20
LTPD.
Complete. Maximum SRU capacity is l0
LTPD. Daily HzS feed shown in Attachment
A.
52a Install and commence operation of SOz
CEMS at SRU bv 712108.
Complete. CEMS installed and operational
prior to 712108.
52a
Demonstrate daily 95% recovery (30 day)
for SRU using measured HzS in feed and
SOz emissions from CEMS.
The calculation of95% 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 chanses was submitted on 619116.
52a Determine HzS in SRU feed quarterly for 4
quarters and semiannually thereafter.
Sampling and analysis completed 9122108,
tol 1 6108, 21 6109, 5 I 5 109, 7 129 109, tol 12109,
I 122/ 10, 8125 I t0, 0t 126l I t, 7 l28l I t, 2l2gl 12,
7 I I I I 12, 2l4l 13, 7 l2l 13, 21 181 I 4, 7 I 51 14,
I l2l I I 5, 7 17 I I 5, and 219 I 1 6. 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 I year after 712108.
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.
CD TI Requirement Status/Comment
52d
Submit test protocol to EPA Region 8 and
State to perform 95o/o 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 612612009.
Test protocol was submitted 1112312009.
Testing performed 1212312009, SRU achieved
95.2% recovery and0.42 tons per day (830
lbs) SO2.
52e
Submit a semiannual report covering SRU
recovery, emissions, 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 chanses was submitted on 619116.
52f
Submit Plan for Maintenance and
Operation of SRP within 270 days from
712108.
Complete. Plan submitted 3 12612009,
52h
Submit schedule to comply with NSPS
within 120 days of SRU exceeding 20
LTPD input.
Maximum SRU capacity has not increased
beyond l0 LTPD.
54 All sulfur pit emissions routed to
incinerator.
Complete. Commenced prior to Consent
Decree.
Section V.L NSPS Applicabilitv to Flarins Devices
56,56a
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 I1,2015, all streams
going to the flares are being monitored for
compliance with the NSPS Ja standard, and are
renorted in the ouarterlv CEMs reDorts.
56,56a South flare subject to NSPS 6130109,
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
subsequently rescinded.)
56,56a Propane flare subject to NSPS l2l3ll09,
eliminate all routinely-generated gas.
Complete. New propane flare installed
1111712009. The propane flare and associated
storage pit were decommissioned in December
of20l3.
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, 2010.
57a Comply with 162 ppm HzS limit in fuel
gas-Complete. Ongoing prior to Consent Decree.
Section V.J. Control of Acid Gas Flarins Incidents
59
Submit reports for Acid Gas Flaring
Incidents no later than 45 days after
incident.
No Acid Gas flaring events occurred in period.
CD !I Requirement Status/Comment
Section V.K. Control of Hydrocarbon Flarine lncidents
68 Submit reports for Hydrocarbon Flaring
Incidents in semiannual progress reports.
Report for the incident on 413123 was
completed 5117123. Report submitted on
713,/2023.
Section V.L. CERCLA/EPCRA
69 Report any previously unreported SOz
releases bv 6130109.
No previously unreported SOz releases were
identified.
Section V.M. Benzene Waste Operations NESHAPS Prosram Enhancements
72 If TAB exceeds l0 Mg/yr, utilize the 6BQ
comoliance ootion.TAB remains under 10 Mg/yr.
73
Complete review and verification of
refinery's TAB and compliance by 270
davs after date ofentrv.
Complete. Sampling plan, review and
verification were completed 3/1 8/09.
74,
l03a
Submit report to the EPA and State by 60
days after review and verification.Complete. Report submitted 5120109.
75
Conduct additional sampling and submit
results to EPA within 60 days after
receivins request from EPA.
EPA requested no additional sampling.
7\
l03b
Revise report and resubmit within 120 days
after comoletion of samolinp.Original report deemed final.
76
If revised report indicates initial report was
unsatisfactory, resubmit report to State
within 120 days after completing revised
reDort.
Original report deemed satisfactory.
11
I 03c
If revised report indicates TAB over 10
Mglyr, submit plan within 180 days to
ensure future compliance or to comply with
680 within 2 vears.
No action required. The BWON Compliance
Review and Verification Report did not
indicate that the TAB exceeds 10 Mg/year.
79,
103d
If actions are required under !l 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 l0 Ms/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. Inventory
reviewed on l2l3o/09, 12127/10, l2/30lll,
12127 I t2, t2l t9 I 13, t2l 101 14, t2l30l 1 5,
t2t28t 16, 12t22t2017, 31241 18, t2l2t I tg,
121 201 19, t2l t7 120, 12t 30 t21, 12t30 t22, and
r212U23.
82,84
Conduct audits ofall laboratories used for
benzene waste analysis within 270 days
after date of entry, new labs before use, and
everv two vears.
Laboratory audit completed 3/l ll1l,3l8l13,
3 I 181 t5, 31 1 61 17, 3128t 19, 3 t22t2t, and
312812023.
CD !I Requirement Status/Comment
86
Review spi
more than
waste, and
ls to determine if they generate
0 lbs ofaqueous benzene
nclude 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 training completed 05 I 0 | I 09. Contract
personnel were initially used to collect
samples. Additional training completed
annually. The latest training was completed on
12130122.
89 Ensure contractor employees hired to
perform training are adequately trained.
Completed for contract employees by
12115108, 1218109, and I 1/05/10. Contractors
no lonser used.
90,
l03e
Submit waste/slop/off-spec oil
management schematics Complete. Sent to State and EPA 8/21108.
93,
l03f
Submit quarterly/annual sampling plans to
EPA and State by 60 days after revised
report is finalized or original report is
acceoted.
Original report accepted. Sampling plan sent
on 7l2l12.
95 Implement 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/yr
benzene.
96,
l03f
If changes affect the validity of the
sampling plan, submit revised plan within
90 davs.
A revised sampling plan was submitted to
EPA on 5125123.
97 Submit quarterly and annual projected
TAB with semiannual reoort.
The quarterly and annual projected TAB is
included in Attachment B.
98 Implement corrective measures if quarterly
TAB > 2.5Ms or annual TAB > l0 Ms.No excesses during this period.
99 Provide reasons why causes of excess
quarterly or annual TAB will not recur.No excesses during this period.
100,
l03g
Submit compliance assurance plan if
quarterly TAB > 2.5 Mg or annual TAB >
10 Ms.
No excesses during this period.
101
Contract 3'd party to conduct TAB study
and compliance review if quarterly TAB >
2.5 Mg or annual TAB > 10 Mg. Submit
results to EPA and State within 30 days
and imolement.
No excesses during this period.
l04a Submit sampling results and TABs with the
semiannual reDort.
Sampling results and TABs are included in
Attachment B.
l04b Submit description of training conducted
with the semiannual report.
Retraining completed for 2022 by attending a
third party consult training course and via
review of physical material based on existing
computer-based trainins.
CD qI Requirement Status/Comment
l04c Submit a summary of lab audits conducted
with the semiannual report.
Identification of the laboratory audited, a
description of the methods used in the audit,
and the results ofthe audit are provided as
Attachment C.
105 Requests to modiff the frequency of
reportins under fll04.
No request has been made to modiff the
frequencv of reuortins.
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 1128109.
I 10,
I 35a
Submit LDAR program to EPA and State
in first semiannual report.
Complete. Submitted with Semi-Annual
Report dated 1128109.
111a
Train employees newly assigned to LDAR
responsibilities before beginning LDAR
work.
Computer-based training is required for all
newly involved employees.
11lb
Provide annual training for all employees
with specific LDAR responsibilities as
primary job function beginning within I
vear of 712108.
Computer-based training program is required
for all employees with specific LDAR
responsibilities as their primary job function.
lllc Provide training every 3 years for all
operations and maintenance employees
beginning within I year of 712108.
Computer-based training program established
training for 146 employees and completed
612109. Computer-based training for I 60
employees completed l2l2ll1l. Computer-
based training for 218 employees completed
l2l3ll13. Training for 173 employees
completed l2l3l I 15. Training for 207
employees completed l2l3ll18. Training for
158 employees completed 21112022.
l1 ld Maintain records of annual training as in fl
I I lb for contract LDAR oersonnel.Maintained under file number 2.6.3.
I 13,
tt4
Conduct 3'o party audit of LDAR
compliance every 4 years, beginning within
12 months of date of entry.
3'o par{ audit conducted by ERM and report
submitted 6122109.
l13 Submit LDAR compliance certification to
EPA.
LDAR compliance certification submitted
11512010.
11s
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'o party audit conducted 4/18111,4/8113,
4/ 13 I I 5, 5 I I 61 17, 4l I I I 19, 4 122121, and 5 I 4123.
116 LDAR audits are to be conducted in the
same calendar quarter.
All future LDAR audits will be conducted the
second calendar quarter ofthe vear.
10
CD qi Requirement Status/Comment
tt7
Implement 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 5126-5129109 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 complete. Corrective actions for the
seventh audit are estimated to be completed by
81312023.
120
Utilize internal leak definition of 500 ppm
for valves, except pressure reliefdevices,
bv llll09.
Complete.
121 Utilize internal leak definition of 2,000
oom for DumDs bv 7llll0.Complete.
122
Speciff 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.
t24
Make initial attempt at repair on non-
control valves with reading over 200 ppm
and remonitor.
Complete.
125 Monitor pumps in light service monthly
beeinnine 7llll0.Complete.
126 Monitor valves, other than difficult to
monitor valves. ouarterlv beeinnins 1lll09.Complete.
t27 Keeo LDAR data in electronic database.Complete.
128 Use dataloggers/electronic data collection
for LDAR.Complete.
t29
Develop and implement a LDAR QA/QC
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 1128109, Attachment B.
131
Drift assessments performed at minimum at
the end of each shift, with remonitoring if
nesative drift exceeds l0%.
Complete.
l32a
Sign offby responsible person for delay of
repair, and continued monitoring of
eouioment.
Complete.
t32b
Employ "drill and tap" for valves leaking
over 10,000 ppm that cannot otherwise be
reDaired.
As required, and as specified in procedures,
see Semi-Annual Report dated 1128109,
Attachment B.
77
CD qI Reouirement Status/Comment
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 1128109,
Attachment B.
I 35a Provide LDAR program information in the
first semiannual report.Complete.
I 35b
Provide description ofaudit report for each
audit conducted in the prior year in the
semiannual report (July 3l report only).
Identification of the auditor, a summary of the
audit results, and the status of Holly's actions
related to the audit are provided as Attachment
D.
136
Provide information on training and on
LDAR monitoring and repairs in the
resular NESHAPS reoorts.
Included in Semiannual MACT reports
beginning January 2009.
Section V.O. Incorporation of Consent Decree Requirements into Federally Enforceable Permits
l37a
Submit permit revision for immediate
Consent Decree requirements within 90
days of date of entry.
Notice of Intent for a change in Approval
Order (AO) conditions to incorporate Consent
Decree requirements submitted 9119108. AO #
DAOE-ANO 101230027 -09 received I I 12109.
t37b
Submit permit revision for other Consent
Decree requirements within 90 days of
effective date.
Notice of Intent for a change in Approval
Order (AO) conditions for NOx limits on 8Hl
and l2Hl submitted 12123108. Ao # DAQE-
ANOl 01 230027 -09 received I I 12109. Notice
of Intent for a change in AO conditions for CO
limit on FCCU submitted 3129110. AO #
DAQE-ANO 101230032-10 received 8123/ 10.
Notice of Intent for a change in AO conditions
for #5 Boiler NOx limit submitted 4129110.
AO # DAQE-AN0l 01230036-1 0 received
11117110. Notice of lntent for a change in AO
conditions for interim NOx and SOz limits on
FCCU submitted lll30ll0. Ao # DAQE-
ANol 01230038-10 received l2l 161 10. Notice
of Intent for a change in AO conditions for
final SOz limits on FCCU submitted 5123112.
Notice of Intent for a change in AO conditions
for interim NOx limits on FCCU submitted
31231t3. AO # DAQE-AN101230041-13
received I l/18/13. AO # DAQE-
AN101230052-20 received 10/8/20. AO #
DAQE-AN I 01230053-22 received 9 I I 122 (no
CD requirements to be implemented in this
AO). AO # DAQE-AN1012300''-23
received 619123 (no additional CD
requirements to be implemented in this AO).
72
CDqI Reouirement Status/Comment
Section V.H. NSPS ApplicabiliW to the Sulfir Plant
52e
Submit a semiannual report covering SRU
recovery, emissions, operating parameters,
and daily feed.
The calculation of95% 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 619116.
Summary of the Emissions Data Required by the Reporting Requirements
of Part V (Affirmative Relief/Environmental Projects)
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 Implementation of the Requirements
of Part VII (State Supplemental Environmental Project)
Any Additional Matters to be Brought to the Attention of EPA and the State
None for this report.
CD tI Requirement Status/Comment
Section VII. State Supplemental Environmental Proiec
l45a
Contribute $ 130,000 for purchase of
mobile command post, which shall be
acquired within 1 vear of date of entry.
Complete. Delivery of mobile command post
418109. Public presentation 5 I 19109.
l45b
Submit a cost report and certification in
the semiannual report upon completion of
nroiect.
Complete. Submitted with Semi-Annual
Report dated 7 129 109, Attachment D.
147 Provide a progress report for the SEP in
each semiannual report.
Complete. Submitted with Semi-Annual
Report dated 7 129 I 09. Attachment D.
13
CD tI Reouirement Status/Comment
Section X. Reoortins and Recordkeeoins. !1149b. Emissions Data
t49b
Estimation of NOx emissions for each
heater and boiler greater than 40
mmBtu/hr.
6Hl; 21.74 tpy, SHl; 9.89 gy, l2Hl;7 .12 tpy,
20H2;5.75 tpy, #5 Boiler; 0.14 py, #6 Boiler;
0.0 tpy (decommissioned in 2012), #8 Boiler;
2.30 fpy, #9 Boiler; 0.63 tpy, #10 Boiler; 1.38
tpy, #l I Boiler; 0.65 tpy. All NOx emissions
for 8Hl, l2Hl,#5 Boiler, #8 Boiler, #9 Boiler,
#10 Boiler, and #l I Boiler were estimated
using stack testing results. All NOx emissions
for 6Hl and20HZ were estimated using
emission factors.
t49b Estimate of NOx emissions as a sum for all
heaters and boilers less than 40 mmBtu/hr.
Estimated NOx emissions for all heaters and
boilers less than 40 mmBtu/hr for the 2022
reportins vear:42.73 tpv (emission factors).
r49b Estimate of SOz, CO and PM emissions as
a sum for all heaters and boilers.
Estimated emission for the 2022 reporting year
are as follows: SOz; 10.09 tpy (CEMS), CO;
137.96 tpy (emission factor), PM (PMl0); 6.45
tpy (emission factor & stack testing), (PM2.5);
0.98 tov (emission factor & stack testins).
t49b Estimate of SOz emissions from all Sulfur
Recovery Plants.
Estimated SOz emissions for the 2022 reporting
year from all Sulfur Recovery Plants is 0 py
(All SRU emissions are routed to a FCCU
WGS).
l49b SOz emissions from all acid gas flaring
incidents bv flare.
Reporting year 2022 had no acid gas flaring
incidents.
t49b
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.
Estimated emission for all other emissions units
for the 2022 reporting year are as follows: NO*;
23.28 tpy, SOz; 3.19 tpy, CO; 123.18 tpy, PM
(PM l0); 12.06 tpy, (PM2.5); 2.41 tpy.
Summary of Annual Emissions Data for the Prior Calendar Year
Exceedances of Emission Limits
CD TI Limit Exceedances
Section X. Reportins and Recordkeeoine. 1ll49c. Exceedances of Emission Limits
t6 Interim NOx 7-day rolling average,
corrected to 0oZ oxvsen. from FCCU
No longer applicable. Complying with final
limits.
16 Interim NOx 365-day rolling average,
corrected to 0o% oxveen. from FCCU
No longer applicable. Complying with final
limits.
14
CD!I Limit Exceedances
2t Final NOx 7-day rolling average, corrected
to 0oZ oxygen, from FCCU
tQ2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly report
submitted 4127123.
2Q2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly report
submitted 7125123.
21 Final NOx 365-day rolling ayerage,
corrected to |Yo oxygen, from FCCU
tQ2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly report
submitted 4127123.
2Q 2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly report
submitted 7125123.
25 Final SOz 7-day rolling average, corrected
to 0% oxygen, from FCCU
lQ2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly report
submitted 4127123.
2Q2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly report
submitted 7125123.
25 Final SOz 365-day rolling average,
corrected to 0% oxygen, from FCCU
tQ2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly report
submitted 4127123.
2Q2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly report
submitted 7125123.
28 Interim SOz 7-day rolling average,
corrected to 0olo oxygen. from FCCU
No longer applicable. Complying with final
limits.
28 Interim SOz 365-day rolling average,
corrected to 0olo oxygen, from FCCU
No longer applicable. Complying with final
limits.
32 1.0 pounds PM per 1000 pounds of coke
burned from FCCU
Not applicable. Holly is subject to stricter limit
of0.5 pounds PM per 1000pounds ofcoke
burned from FCCU.
15
CDtt Limit Exceedances
JJ 0.5 pounds PM per 1000 pounds ofcoke
burned from FCCU
lQ 2023: Emission Limit exceeded 1,25o/, of
the calendar quarter. Total downtime of the
CEM was 0.00% of the calendar quarter, as
detailed in quarterly report submitted 4127123.
2Q2023: Emission Limit exceeded0.650/o of
the calendar quarter. Total downtime of the
CEM was 0.00% of the calendar quarter, as
detailed in quarterly report submitted 7 I 25 I 23.
36 500 ppmvd CO l-hour average at0o/o
oxygen, from FCCU
tQ2023: Emission Limit exceeded0.65oh of
the calendar quarter. Total downtime of the
CEM was 0.00% of the calendar quarter, as
detailed in quarterly report submitted 4127123.
2Q2023: Emission Limit exceeded 0.55% of
the calendar quarter. Total downtime of the
CEM was 0.00% of the calendar quarter, as
detailed in quarterly report submitted 7 I 25 I 23 .
37 100 ppmvd CO 365-day average at0%o
oxygen, from FCCU Not applicable.
46c NOx 3-hour rolline average. from 8H1 Not applicable.
46c NOx 3-hour rollins averase. from l2Hl Not aoolicable.
46c NOx 3-hour rolling average, from #5
Boiler Not applicable.
46c NOx 3-hour rolling average, 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 162ppm HzS 3-hour average, in fuel gas
lQ2023: Emission Limit exceeded 0.05% of
the calendar quarter. Total downtime of the
CEM was 0.00% of the calendar quarter, as
detailed in quarterly report submi tted, 4 1 27 1 23 .
2Q2023: Emission Limit exceeded 0.60% of
the calendar quarter. Total downtime of the
CEM was 0.00% of the calendar quarter, as
detailed in quarterly report submitted 7 125 I 23 .
52a L6 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
619116. 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.
L6
cDqt Limit Exceedances
68 500 pounds SOz in a24-hour period from
hydrocarbon gas flaring
Report for the incident on4/3123 was
completed 5117123. Report submitted on
713U2023.
Stack Tests - Emissions Monitored through Stack Testing
32,33 PM from FCCU Complete. PM performance testing completed
onl2l20ll2. Report sent to EPAll23ll3.
46c NOx from 8Hl
Complete. Stack test report submitted l2l15/08
to EPA and State of Utah in accordance with
fl46d.
46c NOx from l2Hl
Complete. Stack test report submitted l2ll5l08
to EPA and State of Utah in accordance with
fl46d.
46c NOx from #5 Boiler
Complete. Stack Testing completed 2l9ll0 and
retested 3125110. Stack test report submitted
4l29ll0 with Notice of Intent.
46c NOx from CO Boiler Not applicable.
46c NOx from #8 Boiler Complete. Performance test completed on
4/22113.
46c NOx from FCCU Feed Heater Not applicable.
t7
Attachment A
SRP Summary Report
SRP Summary Report no longer included per notification submitted to the Unhed State EPA ffice of
Gvil Enforcement on June 9, 2016 detailing the charge in reportingfor the Sulfur Recovery Unit
AUG .3 2OE
DIVISION OF AIR OUALITY
Attachment B
TAB Analysis Reports
BWON Samplsd Warte Str.m3 and R$ult
202ttdtutu
H B. E BHI b
1:Ss
dt
-
tht2D1w.krlll 29.6 I
r56
L1:57 I
IP 6/912071 12rm
l-6/9/2023 72:01
rl-
.I
,
I
I-I I w&, Ix! 16.1 | | I ss I
lt-
lr**l';,.,ffi
I I w.wlxl e3 I | | em I
tt-
l*..Jf"I**l , hkllL ,,v*" J ,,,, l-----4gqese---r| *Ji- I I hkllL zeao: | "r F-##-
tt-
I *- | I -*-LLiL r,rnor I roro F-Hffl---lI qlElmh L i dr lx ?630 I ..,.^., I .^.- I &@ Itt--;::--a,-".,t.".,,l_
I l-lw.uffi
I *- | I -*;ll!l! avrorr | rcc F-#---llffitrhl . or lxi e8so l^.^,"^^. l.^_. I som I,' - .-"aa--'.""'",'"-'l.......ffi
tt'
| ,** | I -**-EJ--,]ilLJ 'i'r'o'r I roor F-ffi---11ffifftu | . or III 86so 1.,.-,.-.. I .^_. I 60_@ II I ' -;;;.- '''"'*'i-'" r......-t:---
tt-
l*-l
I -"--*--I I we, Ixl 23 I I I 2rm I
I
lr*-l
,I l w.h, lry
I
lucr'-=---| | w.r.'lxl 5rr I J I st.t@ I
tl-
l r*,
I I w.b'lxl 114 I I I r2fi I
I
l ucm
I I lw.E,lxl 312 I I I !.rp I
tt-'
I
I
I
I*ol'
,I I lw.r.. lxl 0.@7 I | | qo, I
I
I**lt --:--I I lwd., lxl 018, I I | 0.x7 |
I
| *- I r -o*tL!L orano. I ro're F"ffi---lI.e*h I . or lrl s9ro L',-^-- I_-_^ I erom II l- -;;:-"'q'""1'""r ffi
tt-
l**
I I mn'lrl ro | | I *.* ,
It'
lr*-l
lffir&h
I
l r**
l.**h
I
l*-
t e.--E---I I w.t.. lxl 10.4 | | | ua I
I
l *--l*
I
I))
E
q
I0
!ooB
E
6E
5
2
=E
E
Es
ii I I E !t I 3 !
r*t:t-t E
E-
ii
E
:ail
ii
E
i t 3
8
lsrlt6a
I !i I !*
3E!'E
c
ii
t F I
E
li
ri
8 3 t
I
Ie
l5
8 88
E
E
3 E I !I {
Egat
a
I {5
!r
,:3
3
rlii<l
!!r
6
Esfltdd
!E E I E t E !E E q
t
IE!'I
E
it
ig:<
:
rti
lgr
t
E
rtI
E
E{.
et
I;
(
€I!
I
s
!
E
Et
e
i
I
,a
E
I ,
I
tE
,
Attachment C
Summary of BWON Lab Audit
Teleplrone. +1 80'l 589 2632
www erm.com
12 April2023
AlVargas
HollyFrontier Woods Cross Refining
'1070 West 500 South
West Bountiful, UT 84087
Reference: 06851 53
Subject: Benzene Waste Operations NESHAP (BWON) Third-Party Laboratory Audit Report
Audit of the Chemtech-Ford (Chemtech) Laboratory, Salt Lake City, Utah
Dear Al:
This report documents the third-party audit of facility operations at the Chemtech-Ford (Chemtech)
Laboratory in Salt Lake City, Utah, which the HollyFrontier (Holly) Woods Cross Refinery in Salt
Lake City uses for analysis of benzene waste samples. Environmental Resources Management,
lnc. (ERM) performed the audit on Tuesday, 28 March 2023,in accordance with the requirements
of Holly Refining's Consent Decree (CD) with the United States Department of Justice. Callee
Butcher of ERM served as the auditor.
ERM performed an audit of Chemtech's laboratory and analytical services, including facility safety
and chemical hygiene, quality assurance/quality controlsystems, certifications, employee training,
sample traceability and reproducibility, sample receiving, data collection and reporting,
subcontracting, vendor qualification, document management and retention, and corporate policies
and procedures. The audit was based on a physical survey of the laboratory and examination of a
sample of laboratory reports, manuals, policies and procedures, administrative and/or operating
records, and interviews with key personnel. The following key staff were interviewed for the audit
and facilitated onsite information gathering activities necessary to complete the audit:
r Jenn Osborn, Director of Quality
r Madeline Voloshin, Team Lead
r Andrew Royer, Section Manager
The compliance audit reviewed facility activities against applicable BWON requirements in Title 40
of the Code of Federal Regulations (40 CFR 61), Subpart FF; the CD; record retention
requirements; and requirements associated with the National Environmental Laboratory
Accreditation Conference (NELAC) Standard (United States Environmental Protection Agency
lus EPAy600/R-04/003).
FACILITY OVERVIEW AND DESCRIPTION
The Chemtech Salt Lake City site is a contract-environmental laboratory site. The laboratory is
located at 9632 South 500 West, Sandy, Utah 84070, and provides environmentalanalytical
services for private and public sector clients under Standard lndustrial Classifications Codes (SlC)
Code 8734. The laboratory conducts routine analyses of benzene waste samples from the Holly
Refinery under Standard Methods 8021 and 8260C, and USEPA Method 624. The laboratory is
[roo* -
I srir" tooo
I
satt rare ciry, Utah 84r 1'1
ERM
12 April 2023
Reference: 0685 1 53
Page 2 o{ 2
accredited by the NELAC, which administers the National Laboratory Accreditation Program and is
sponsored by the USEPA.
The Chemtech facility includes one two-story building that houses analytical laboratories, offices,
records, and supply storage.
The laboratory was audited in October 2O22by the Utah Environmental Laboratory Certification
Program (ELAP). All issues were resolved and corrective actions were documented and delivered
to ELAP.
FINDINGS
For the purposes of this audit, a finding is defined as a departure from, or exception to, an existing
applicable statute, regulation, permit, company standard, or policy that can be confirmed by the
audit team. ERM identified no findings related to BWON sample analysis.
The laboratory was identified as having sufficient systems in place for sample receiving, storage,
analysis, and data collection/reporting related to BWON samples. The auditor did not identify any
issues related to safety, chemical hygiene, quality assurance/quality control systems, or
hazardous waste management.
LIMITATIONS
This assessment represents ERM's professional interpretation and judgment of existing conditions
at Chemtech based on review of available records, facility inspections, and verbal interviews with
site personnel, lt is ERM's intent that the findings presented herein be used as guidance only;
ERM makes no guarantees, expressed or implied. Regulatory interpretation given in this report is
provided by a technical expert and not an attorney-at-law.
ERM appreciates the opportunity to assist Holly Refining with this important project. Please
contact Callee Butcher at (801 ) 589-2632 or Wes Leavitt at (720) 938-051 5 if you have any
questions.
Sincerely,
O.ur.ffidD
Callee Butcher
Consultant Director
Project Manager
V)*'fu
Wes Leavitt, CIH
Partner
Attachment D
LDAR Audit Summary
FINAL Third-Party LDAR Audit Report
HF Sinclair Woods Cross Refining LLC
West Bountiful, Utah
,.tttF$nctor
Emission Monitoring Service, Inc.
Baton Rouge Office
450 Laurel Street, Suite 2010
Baton Rouge, LA 70801
luly2023
pdlahrpe
lECriNtcAi clF()r.lP
TABLE OF CONTENTS
1. INTRODUCTION
2. AUDIT METHODOLOGY
1-1
2-1
2-l
2-l
2. 1. Compliance Document Review Methodolory....
2.2. LDAR Technician Observation
2.3. Field Review
2.4. Comparative Monitoring Methodology
2,4,1. Comparative Monitoring Leak Percentage........
2.4.2. Historic Average Leak Percentaqe..................................
2.4.2.2. Pumps
2.4.3. Comparative Monitoring Leak Ratio....................
3. AUDIT RESULTS
3.1. Comparative Monitoring and Statistical Analysis Results
3.2. Program Strengths
APPENDIX A: FINDINGS
3-1
HF Sinclair Woods Cross Refining [,LC
LDAR Audit
2-3
2-3
2-3
) -t"
',,,'...,,,.',.2.4
2-5
3-1
athtre
Table 3-L. Comparative Monitoring Component Counts
Table 3-2. Valve Comparative Monitoring Results
Table 3-3. Pump Comparative Monitoring Results
LIST OF TABLES
tlF Sinclair Wootjs Cross Refining Ll,C
l,l)AR ArrditAI6rrce
1: INTRODU-CT|ON
Alliance Technical Group (ATG) conducted a third-party leak detection and repair (LDAR) audit at the HF Sinclair
Woods Cross Refining LLC IHF Sinclair) petroleum refinery located in West Bountiful, Utah (the Woods Cross
Refinery) in accordance with Paragraph 112 through 116 of the facility's Consent Decree. The audit included on-
site activities and off-site database analysis. The site visit was conducted May 1, 2023 through May 4,2023.
The audit scope consisted of the following key items:
) Compliance with LDAR requirements under the facility's Consent Decree;> Compliance with applicable LDAR regulations;o Utah Administrative Code R307-326-9;
o 40 CFR 60, Subpart GGGa (NSPS GGGa);
o 40 CFR 60, Subpart Wa (NSPS Wa), as referenced in NSPS GGGa;o 40 CFR 63, Subpart CC (MACT CC); and> Compliance with United States Environmental Protection Agency's (US EPA) Method 21.
In accordance with Paragraph 112 of the Consent Decree, the specific tasks listed below were completed:
) Comparative monitoring for valves and pumps;
) Records review to ensure monitoring and repairs were completed in the required periods;
> Field auditing to ensure affected equipment has been identified and included in the facility's LDAR
program;
) Review of data management procedures; and> Observation of the LDAR technicians' calibration and monitoring techniques.
ATG's LDAR audit methodology and results of the LDAR audit are discussed in the following sections of this report.
all?atre HF' Sirrclair Woods Cross Refining l,LC
LDAR Audit
1-1
2: AUDTT METHO-DOLOGY
All items reviewed can be categorized as follows: review of compliance documents, LDAR technician observations,
field review, and comparative monitoring.
2.1 . COMPLIANCE DOCUMENT REVIEW METHODOLOGY
ATG provided an initial request for records to HF Sinclair on April 3,2023. The request included compliance
records for the time period of April L,2027 through March 3L,2023. Provided documents were reviewed for
compliance with the facility's Consent Decree, applicable LDAR regulations, and Method 2L.
Method 21 monitoring and visual inspection data was requested and provided for the aforementioned time
period. Data was analyzed to confirm that required monitoring/inspection frequencies and repair deadlines were
met and that all required recordkeeping information was properly included. Evaluations were made on data
collected by each LDAR technician to identify any anomalies that could indicate potential non-compliance or non-
conformance with industry standards.
Calibration records were reviewed for compliance with Method 21 to ensure proper calibration procedure. Delay
of repair (DOR) records were reviewed to confirm proper documentation was maintained. Management of change
(MOC) records were reviewed and discussed with facility personnel to ensure the MOC program adequately
captures the addition and/or removal of LDAR equipment. In addition, the following records were reviewed to
assess compliance with applicable Consent Decree requirements:
> The written refinery-wide LDAR program;
> Training records;
> Initial attempt at repair of valves greater than 200 ppm;> Electronic storing and reporting of LDAR data;> QA/QCofLDARdata;> Calibration drift assessments;> DOR sign-offs;
> Drill-and-taprecords;) Chronic leaker repair records;> Semiannual NSPS reports; and) Consent Decree reports.
2.2. LDAR TECHNICIAN OBSERVATIONS
ATG performed LDAR technician observations to confirm compliance with 40 CFR 60, Appendix A-7, Method 21.
Specifically, the following activities were observed:
> Calibration techniques used by the monitoring personnel, including the precision test, daily calibration,
calibration drift assessment, response time tests, verification of acceptable instruments and proper
utilization of calibration gases.
) Monitoring techniques used by the monitoring personnel, including sample collection procedures
(during which factors such as probe position and collection duration are considered), equipment
operation, and on-site equipment maintenance.
HF- Sinclail Woods Cross Refining LLC
LDAR Audit
EAliarrce
2-1
In addition, ATG discussed numerous aspects of Method 21 with the LDAR technicians to ensure methodologies
utilized at the Woods Cross Refinery are compliant with regulatory requirements.
2.3. FIELD REVIEW
During the audit, ATG performed unit walkthroughs and field review to identi$r potential non-compliance items
throughout the Woods Cross Refinery. Specifically, ATG focused on the following:
) Open-ended valves or lines;> LDAR tagging (i.e., LDAR component identification);
) Leaker tags [i.e., leaking component identification);> Accessibility of components for monitoring;> Difficult-to-monitorandunsafe-to-monitordesignations;> Sampling connection system compliance; and> Pressure relief device compliance.
The field review focused on component identification, tagging data management procedures, MOC procedures for
tagging of new components, and LDAR work practices in the selected process units.
ATG extracted a random assortment of components from the facility's LDAR database and verified that the
components were correctly characterized in the database, As part of the random field review, ATG also examined
select components included in the LDAR program to assess the quality of the MOC process. As part of this review,
components listed as difficult-to-monitor were reviewed to determine the accuracy of the difficult-to-monitor
designation. Additionally, ATG verified a subset of the pressure relief devices provided in the LDAR database were
accurately tagged in the field.
In order to evaluate best-in-class methods for tagging, ATG compiled a list of active leaking components, including
components on delay of repair, and verified that each such component had a current leak tag with the proper
information clearly displayed. In addition to current leaking components, ATG also verified that previously leaking
valves were still tagged if subsequent monthly follow-up monitoring events had not yet been completed.
In addition to reviewing the LDAR plan and procedures for leak repair when detected during Method 21
monitoring, ATG interviewed multiple operations and maintenance personnel to better understand the work
practices in place for leak detection by audio, visual, olfactory (AVO) methods and what procedures are in place
for repairing AVO leaks once they are detected. ATG also discussed field sampling procedures with operations and
maintenance personnel and observed the sampling process to verifu that open-ended lines were not generated
during routine sampling procedures.
2.4. COMPARATIVE MONITORING METHODOLOGY
ATG performed comparative monitoring for a semirandomly selected subset of valves in gas/vapor and light
liquid service and pumps in light liquid service in three (3) process units at the Woods Cross Refinery. ATG's
monitoring results were then compared to the Woods Cross Refinery monitoring results obtained during the four
complete quarters immediately preceding the audit (i.e., second quarter 2022 through first quarter 2023), as
prescribed in Paragraph 1 L2 ofthe Consent Decree. The comparative monitoring leak percentage, historic average
leak percentage, and comparative monitoring leak ratio were calculated as outlined below.
HF Sinclail Woods Cross }lefining l,l,C
LDAR Autlitall?atre
2.4.1. Comparative Monitoring Leak Percentage
In accordance with Paragraph 112.a of the Consent Decree, the Comparative Monitoring Leak Percentage is
calculated for valves and pumps by comparing the number of leaking components found during the audit to the
total number of components monitored during the audit for each process unit included in the comparative
monitoring analysis. Note that only a subset of components was monitored for this analysis. Therefore, 95%o
confidence intervals are calculated in order to estimate the range in which the actual leak rate for valves should
fall, based on the fact that the comparative monitoring tested only a sub-sample of components for only a single
point in time. The 950/o confidence intervals are estimated using the definition of a normal confidence interval,
defined in Equation 1.
Where:
CI=X=
rd/2, n-1
Sn=
n=
Equation 1. Conlidence Intervals
CI=X*totz,r-t!1n
Confidence Interval
The estimated sample average value
The 97.5th percentile from the Student-t distribution with n-1 degrees of freedom
Standard deviation for audit leak rates
Sample size
It should be noted that the 950/o confidence intervals for pumps is typically much larger than those for valves.
Because there are so few pumps in each process unit, the audit leak percentage will necessarily be less
statistically significant than the leak percentage for valves.
2.4.2. Historic Average Leak Percentage
This section describes the calculation methodology for each type of subject equipment (i.e., valves and pumps) in
accordance with Paragraph tLZ,b of the Consent Decree. Because the Consent Decree does not define a specific
methodology to determine Ieak percentage, the leak percentage is calculated as specified in NSPS Wa.
2.4.2.1. Volves
The Historic Average Leak Percentage for valves is calculated as specified in NSPS Wa. Calculations were
performed based on monitoring data provided by HF Sinclair. Data from the four (4) quarterly monitoring periods
immediately preceding the audit (i.e., second quarter 2022 through first quarter 2023) was used for this analysis.
Based on Paragraph 120 of the facility's Consent Decree, the leak definition is a Method 21 reading of 500 ppm or
greater.
Equation 2. Percent Leaker Calculation for Valves
o/oVy 100
Where:
Percentage of leaking valves
HI; Sinclair Woods Cross Ref ining l,l,C
I.DAR Audit
=(h)"
Alflarce
o/oVu
'z-3
Vr.
Vr
Number of valves found leaking
Total number of valves monitored in the monitoring period
The total number of valves monitored during a period, Vr, is determined by summing the total number of unique
valves monitored. If a valve is monitored more than once during a period, it is still only counted once for the
purposes of Vr. If a valve is found to be leaking one or more times during a monitoring period, regardless of how
many times it was monitored, the valve is still only counted once for Vr, as well as once for Vr..
2.4.2.2. Pumps
Since pump percent leaker calculations are not defined under NSPS Wa, ATG has elected to utilize an analogous
methodology as prescribed for valves. Calculations were performed based on monitoring data provided by HF
Sinclair. Data from the four complete quarters immediately preceding the audit (i.e., April 2022 through March
2023) was used for this analysis. Based on Paragraph 121 of the facility's Consent Decree, the leak definition is a
Method 21 reading of 2,000 ppm or greater.
Equation 3. Percent Leaker Calculation for Pumps
o/oP7=(&)"roo
Where:
Percentage of leaking pumps
Number of pumps found leaking
Total number of pumps monitored in the monitoring period
The total number of pumps monitored during a period, Pr, is determined by summing the total number of unique
pumps monitored. If a pump is monitored more than once during a period, it is still only counted once for the
purposes of Pr. If a pump is found to be leaking one or more times during a monitoring period, regardless of how
many times it was monitored, the pump is still only counted once for Pr, as well as once for Pr..
2.4.3. Comparative Monitoring Leak Ratio
The Comparative Monitoring Leak Ratio is used to assess the accuracy of the facility's historic monitoring results
based on results of comparative monitoring conducted during the audit. In accordance with Paragraph 712.c of
the Consent Decree, this ratio is calculated by dividing the Audit Leak Percentage by the Historic Average Leak
Percentage, both described above.
In accordance with Paragraph 117 of the Consent Decree, a Comparative Monitoring Leak Ratio greater than or
equal to 3.0 shall be deemed an area of non-compliance and cause for corrective action.
In addition to calculating the Comparative Monitoring Leak Ratio, the range of possible Comparative Monitoring
Leak Ratios given the 950/o confidence intervals were also calculated based on the audit leak percentage. This
calculation is performed to give a complete range of possibilities for the Comparative Monitoring Leak Ratio given
the number of components monitored during the audit.
o/oPt =
Pl=
Pr=
HF Sinclair Woocis Cross Refining LLC
LDAR AuditAl6rrce
2-4
Z. q.q. Chi-square Statistic
An additional statistical test called the Chi-Square was performed; this test indicates a percent probability that
two data sets are in strong agreement. The Chi-Square Statistic is intended to compare two sets of data with no
assumption that one set of data is the standard to which the other is to be compared. However, for this audit, the
historic site data is compared to the audit data, which is assumed to be the standard for comparison. Because the
audit was performed to confirm the rigor of previous monitoring, HF Sinclair is concerned only with audit data
that shows a higher leak rate than historic monitoring. If the historic leak percentage for a component in a process
unit is higher than or equal to the audit leak percentage, the Chi-square Statistic is set to 7000/0, indicating that the
historic data shows extremely rigorous monitoring as compared to the audit data. However, if audit data shows
a higher leak percentage than historic data, the Chi-Square Statistic shows how closely the audit and site data
correlate; a percentage closer to 100olo indicates a stronger agreement. It should be noted t}ta! similar to
confidence intervals, the Chi-Square Statistic is more statistically significant with a higher amount of data points.
at6tre HF Sinclair Woods Cross Refining LLC
LDAR Audit
2-5
3. AUDIT RESULTS
The table provided in Appendix A presents the potential compliance deviations (i.e., findings) noted during
the audit.
3.1. COMPARATIVE MONITORING AND STATISTICAL ANALYSIS RESULTS
Three (3) process units were selected for comparative monitoring at the Woods Cross Refinery:
) 08-Crude;
> L9-LCOIDHT;and> 26-Poly.
These three (3) units were chosen to represent process units across all spectrums of percent leakers: high,
medium, and low. These units were also chosen because they were operating at the time of the audit and
were not used for the comparative monitoring analysis performed during the previous audit.
ATG semi-randomly monitored a minimum of 25o/o of the valves and pumps for each selected process unit in
accordance with Paragraph 772 of the Consent Decree. To ensure randomness when monitoring in each
selected unit, ATG monitoring technicians did not utilize a pre-set route from the facility's database. Rather,
components were randomly selected for monitoring at the time of the comparative monitoring analysis
based on the knowledge and experience of the monitoring personnel. In this way, personnel walked
throughout each unit monitoring a randomly selected subset of components in a given process area. After
monitoring personnel randomly selected components for monitoring in a process area, personnel proceeded
to move across the process unit, ensuring a subset of components throughout each area within the unit were
included in the comparative monitoring analysis. A mixture of easily accessible components and components
on towers and up platforms were monitored to ensure a representative sample based on each unit's
configuration, Component population counts, 250lo thresholds, and number of components selected for
comparative monitoring are provided in Table 3-1 below.
1. There are 5 pumps in light liquid service in O8-Crude; however, only 3 were in service at the time of the audit.
2. No pumps in light liquid service operated in the 19-LCO/DHT unit.
3. All pumps in light liquid service in the 26-Poly follow the dual mechanical seal compliance option.
Comparative monitoring results are provided in Table 3-2 and 3-3 below.
IIF Sinclair Woods Cross Refining LLC
I.DAR Audit
Table 3-1, Comparative Monitoring Component Counts
Unit
Valve Analysis Pump Analysis1,2,3
Pouulation 2So/o Audited Population 2So/o Audited
0B-Crude 809 203 204 3 t 3
19-LCO/DHT 954 239 240 N/A N/A N/A
26-Polv 7283 327 332 N/A N/A N/A
Al6rrce
3-1
Table 3-2. Valve Comparative Monitoring Results
Unit
Valve Leak Percentage Confidence Interyal I Comparative
Monitoring
Leak Ratio
chi-
Square
Value 2HistoricAuditLow Hieh
08-Crude 0.22o/o 0.000/o 0.0070 L.79o/o 0.00 100.000/o
19.LCO/DHT 0.690/o 0.42o/o 0.07o/o 2.30o/o 0.60 100.00%o
26-Polv 0.940/o 0.30o/o 0.0lo/o \.670/o 0.32 100.00%o
1. Confidence intervals are set at 95ol0.
2. Chi-Square values are set to 100o/o ifthe historic leak percentage is higher than the audit leak percentage.
Table 3-3. Pump Comparative Monitoring Results
1. Confidence intervals are set at 95ol0.
2. Chi-Square values are set to 100% if the historic leak percentage is higher than the audit leak percentage.
3. No pumps subject to periodic (i.e., monthly) Method 21 monitoring are operated in the 19-LCO/DHT or 26-Poly units.
As prescribed in Paragraph lL7 of the Consent Decree, a Comparative Monitoring Leak Ratio of 3.0 or higher
shall be deemed an area of non-compliance and cause for corrective action. As such, the results provided in
Table 3-1 and 3-2 suggest compliant Method 21 monitoring for the Woods Cross Refinery, as all ratios are
below the 3.0 action level.
3.2. PROGRAM STRENGTHS
Overall, the Woods Cross Refinery LDAR program had multiple strengths worthy of mention. Specifically,
ATG observed the following program strengths:
> LDAR tagging and component identification for normal-to-monitor components, as well as detailed
and accurate location descriptions within the database, ensure components are accurately
accounted for and monitored efficiently;> All personnel groups work effectively to minimize open-ended lines, as observed from zero
missing caps/plugs on drain and bleeder valves;> Effective communication between personnel groups, including the LDAR Coordinator, LDAR
Contractor Personnel, Operations, and Maintenance, results in high-quality LDAR program
management; and> The HF Sinclair LDAR Coordinator and LDAR Contractor Personnel (Operations Manager, Site
Supervisor, and LDAR Technicians) are extremely knowledgeable and confident with their roles
and responsibilities at the facility.
llF- Sinclair Wootls Closs Ilefining LLC
LDAR Audit
Unit
Pump Leak Percentage Confidence Interyal r Comparative
Monitoring
Leak Ratio
chi-
Square
Value 2Historic Audit Low Hish
08-Crude 0.007o 0.000/o 0.0070 70.760/o 0.00 100.00%o
19-LCO/DHT3 N/A N/A N/A N/A N/A N/A
26-Polv3 N/A N/A N/A N/A N/A N/A
AI6rrce
3-2
APPENDIX A: FnNDINGS
ffi
AUG - 3 2023
F
OJJ
E
d
eO
E\
FEE;+4
n=5n +
,ag
.=d
oE 3,
=
a-?EE
6E,F:E
.9€>!
da
o's
ia
+4
;!
09:2a^ d
;,:u*d
oE 3,
=--
E:.8AE.J
eE!
E9
4iJ
ol k,a -^
Y '':q!! do=c
r 9e9= I2r;t >l!
o :.19-E 5 q-oi qi
E:,er Gz;E Eg
: E rIE F iai6Z_" T€; E ,*
r: A,
-8s <-a
t6 6=3E
eE Ti
Fq <E1Y,
9d =d:9 :E9q I;dii,; o
;d
:,E6 Nl
| = L!0 E et: ,4 EE
T I 96E9
< >= i I 6I *' E.ti
6 -: o ed d.J:{iE:
€. Yr'" 6sEE-E!o
.E {E ! q S.EiE.ec$te -=-*f9I = = xQt"i2E-3€.iE;EE 6-r?t9+;D 9.99d E=':96 q 6 @ q€:P"'3;.9eE:cor€G;9 6dESEE.E! 6 AcE E ?E;iEEE?:SE€f9E.E-s i€ e E,iBts<Etr39td:€a3-3
9 sd
, 9q
e.... z n
IeE"
;;€ P
A'64 -
"3'E;-FCEE.6 E:t,rb3
; EE B.
E !5 EE r;.9';o95
:6 A59c h I
* i 5-a
? 9E q
n'-.gE
Eoii
3 .q E.q; g:E
B ;! E
E 6rc."; g;Er =.ll
5o *5 o
E :EEX G9E- f€3
* E: g
3 !;9: .=38
E -E APa 6S c-
E i€;E ,5ET
p:!!N-9
a
q0
t
€
,
9
6 E 'i i
e d66i o >=J tr EOE <a.{5 .. .. v
i NNOa - *-
i?!M:? :::
O: E tr <99. ooo
Es-i $ g
E.9E g sEEE E Tg€! 7 tr-i a {
E0.^6EE, i 69 E'E d Et '= =o 6! '^ iiEE}E E EE=-3 .5 YElo 9 gEtE : E
.E? , =
-^A
fl.E; eExZ-iP .=;.=
E s i ! s!}EE E'EE".5G- t',av-'E @
2,! ; :;a
9'zE 5i5
EiF
zxfc5>
;*EEi i.
l6 t":=35:6
5tEEU:
;EE
dE!q
EEvE
E ;t FE€ e {
;€ ie
^,-v'E
)e3P
rsirsiii;r! ;9: E ;::I B i :" $ A EE;FEfEt! 5€EEi;E€F s;s
glEEgiii:,
E;i5if E!"Fsr€=.9*-r :iiIf
s # $i -: 3 x ; a FtEElE;t; E€;TE4tc+e.s EE;+
iiitiiEsgFi
F
!J
E
d
ea)3
>
9
4ck9
:=E
re "E
6 .: !
dl a
t >!9
g:ra
=Hk9
7"
5N Sor:29-66:=
3Q i
o6 q
5--
EEE:€_.?,;
.(-aiebq
h9
*q
Ef, +
-q=E?2 --
';6
=AE;
oi6 9.
6.:.9
bE3- 9-
? t;i >J!
k9
:EE
'i.E
E ' ':
.99€
o6I
6.: g
5Eg?t 2
i >r1
s:e
-9 ;qy ;UE
CF EeP x
EL Ele *
99 rzts d!; +
+E
3> E
.ia&E E,Pi 3 z4
!=UT E fr 6
,s g.! ,9 u
:o:! ,N e
E , e :; s E;=9=l t:
IEg5FigE$:EEgEi
i:,E?iEEge+EtiiE
itiit -tgi g ;€ij E: f
g
iliEa.eEE'ie€iiiiEg
3;frg3E IEEE gE?iig g3.
iiiiiii-iiiiriii?ti isi
-.a Bn.9: t.r;ts
:? E
;.! U
.:;-ELE >
..i;
TOE94IEtvpii
ii6 o
ii .! 6-6* 2z .Fes Ef :=! b ? 6,qp r 5 *Ei g; r'F r e€ Y(5 :0 E2d 'Ei- q
!= z4: ) c
^g E.e €D d 9-'9 E E.E ,9
6q ,e X2e r! *dE E-BE f = ;
- i tr 3
4C =;g* ;i :;'C: 6 o A U.. a
=E EE EgAg E? EE
EE 99a :.!p8.9 ;€ 8.5
:aN :d 6 E d,iitg trS; trs6is 6s!,F"e
o
1
a a;.qts
EU:9 " "EpE 4 E: +!€ETHE€r P X E B=i>;li.E
E E; !E:,EE E"E:3,
t67EaE3;E;55; k o iEoI 9 u E Agi 5 E I s"et,-E9rz
I ,;
E !€ r
=> E 8oa: E dE o- Ed! oEiEE:;, =E=gBEcEt! 33-;
fIEE a;: Eii
E !.i9e E t "tr} ?izEEZtt;iE$e E=;.9:: -E*+.",Eir;r :::f {E! HE! E E E.E=qFPn'e )D5
tlc5g€6
@ 5'b P+'; i; a=ia12-x!!r9sqL';n':
i=YEdh9 aEll
E E ; {,:E E-,E=
o Sf F I
i ao E o
gd.;==-
i9.1 =E,E F ns El,;27,:
_9q..9;
: B.q E U5 EY 9:
3 i-o: !6elZx
{oE iZvcq !o: /ne q q *
UY'-bs , , .=29 ,r ,t -sE { { 3o c d- 6- d,.6 .LaL;cE -z<z(:g€ ;x;x 56 S 5-H aH E
E-9 a(+{ E6 c Fd60.^
) E iE;6;r6i,! ;d;&:9\H\$ie E=H=X
I O^ O^ O; E z=z=z
E.E E FVFyF>
s E{ ***i*r4-^ d=d=daZZq J3 JT J:aiit;.9 ' :ERESE-g o I E ' E i E9 ' 4 >': >': >'EgE x
<i!5,
c != 6ici6i6A)-
r. q93*- 6-;;+ I Q<i! 6 E N6!
3.E E ri 32'='a I q f: A.= J 5 a
i m€ dEr: c ^^ !! o
2Ee A 0 E"
.P*E .9.9.-
-*= F F 9r'=eYzE'- > n E E tgE..! E in
=;: !!oAi.g 9I i
5.I =td4E e q +:E I E rr€EPP i^i;
o
F
I
!
oa 30: E0
,6r= E.a7 a ,Y >!E3I,?9;:-vl6:. EE 4 E tr 6I E E l+ *;E;.8 SEsF6:-eoxhdF-ageEE-t_srEEX€e- A u - c qbe.!.248-i.E
fff-FfErS:i.ElF;r:Eee96;qtaE:Ed
= o i q! , E;EEEEETEHF:g;;F; X - E >E: ^; ? te q6 E e-aE= ixE6q=::iii ts:€ E3al9 3.=.E g
=
'5!e9r:
oi
oq
o
a-yZ e '-.0 5ee E .*? 3 ; E
EE iFsEE I *+i I$:j;r ; Ei= aci9 i 5 €EE E:BFE E }Ecah:6 i oc 3 o : :t.q: o d at; +rriE E d E"dE E^ E E; 6 :i.z au P E E : ts EE: E: i o.: q !z.E E=^?o 9 i c E3E E;!i: s 6 ;i; E.E:;; : G ?;; *g6h.i : ? X:+ c a c ;3E Es;!; fi : 3E: E?TEE i : ;2! EoE:; =3= 2eE9E G e P
=E sBiNt : E-PEs €lsD3 9 iEEiJ ET:;T E :Fi6*9o ! d .96:i; ;iF;BE ,3 EiE
;:8 iHiEiE EEiri
a ! 9.9^ir frc" rEE9
=iE;+ra E;st r
I€;Ii? E,iFi ?eE:i'qf A:!E ;Ei.4 UE -9G al e?iEfii i:E€;1;iiEii FF;5It{i=;f€ ;E;E:i
3f-eEEE qif;;A
:gixii-f3EE$€Es8-iX.Ze;;aE.Eg
iiiEi:l$EEEE{Ec:;+*o6 I96e:tEg6 o d4d E.=: o &6 6 6!f r a.E = ! E f, g E s c E Ed'=9=E=d^ox':Ed=i9xqiEts-Ecg;-+
iH 2;i 6
9c A
z2 ?i
,ox
E9 6,: 3
Ei 2: t;.2.E$;;I
\
tEebE p ;:"E -d> iS, I E d ts >\ 9+, :'^ 8_9 I >,1 ,d: E ;i: .EO- ;"t+ V -92! 9;: Eg.i E 9L= ada 9-E ; iFE t27 i+6 -*, *!; 2;-* ;iB E E;i *Ei i"rH ; E?E i:€ sa*3 i?E5E E;s *$8;;Z ;EgE; ;ei gE[
e= '-€.cP.2 Ar a .:93
?"* Eif gi Ei: tE=iE E;:;€ [El E,:l
?g At"iit ;iE 8;xE q !tE 9: ,6 E o --b,' :;Et* g"e! :g;i; + EE AE" EE,1 :!iEi :iiF: EFE EIF
.9
.92*
<x,
rE6
9! ?i:>
,6r
EUE
^t'aE<9i: e
=6!:
g XE
a
it! qt e; Eo= E =
U.: E I
9i2 ;'
2J,: .Y!
6Ed 995 E: E="a d I u.tsd;i c !Y i'=* aE
v o 3 si
2Ei E Eer.Z ?F
c.E a = 3i'EE., e )aEri ;8
: M6 C E L
iE E € E {+E 6 b E a
UJI
'eE
d
eO!
i
:a
d ;:
i6
ERU!;6
3d)
t= i
I Ed
gaE
3E.4
EA !;q!;.!
EeE=*
eeEa
;
i
e
,
3
'
c
'
E
9
E
'
iE
EC
BqgEEf E , IE C E t; =>a 4t: o e>Eii; r iEEE.si5 iY5:i:-f !aEiE3b3 =EE9t o I Pi q+5r;E qi:a=2;E ;9a$!o93 s;ll€!EaE'q;ESEiai B;t*ElF3 9Sl:E.EEo :P{EEI6!gE;i6 d; f E i4 n !+ E;.EE*+ ZT
}5 H€o t;!
ENEFsE o.:o q
EEYrP
c:i9 i
E:;;g; g E.:ie g 3i"*9r;:
c ipi.!
Ei+1iEc;FEE
€r;t s
p€ E IetEig l ^a:
:iE EcIas; d at
=*E ig,
CSEEE
) 9 E {-aEEi:E
s €e i3ii;pEBc=; E ' o Eo o E XrE- o
E;T5::1
sEE"ai;*
;l;:Eg"s*;EEg$s
i; i*i g
H
E i.E; i E;,sEd*!iEE!:€i5g;3
ia
g:
n E.egir
E }E
iqg
P! E
3tFB9i
't +g
4.9 i
E3:
ts! ErEEi E-:I6t
ii ! cEiBE!E::
.T::
!le:: E? $
rt
tc
t!eiTbEElt
,,Ee
i!
xa
i:t
i2E
: EE
lE!
r: Eie 2 -,, E?
. FI:
E=9 E;is!!Er::E! I
i:eir;!t:
rEE
!.s!ar:
gE:3teiE:E1;
:€*!iE:tt*:1
€jE
?.8
I E:ati
E,!e!!r: EEEIg
i$!iEE? E;i:!,.Ii i
;dE
rEl
;E: *eaEl! E:;li!Eii;;9E1:! *? q
.E:e
s:e! Ei
E- e!
8..5
a g;I
:r3 !!E!i
"=Eq i
5?:
E;;(ri
ar:
EEi+
lEri
;fs{
!*"9 i
!*c
It;E
rZ;;vE
EF
d:
i6rY2.l-sdE-:c8i
iEllViz!i ! E
iPFE
$ _{: sgETT
:5F;i9il
e:
Erl
ll2,
+1
Ti
el
E]
=l
el
;
:i
2
E
I
ata
2
E
-!x
!
ca2Z
3€?a.Er5E6ilE!
=Ir
EE E
I
EI
Ei!
t
,!
zt
aE
!
n
t
i*
: t€
:t:
E!
E
6
I.r
!6
{ i4 i
i i3i
e ;r!
o .iZ: ? s-!d B, e: ;!i
: d{4
E IE F
E ! iEE -d!E Ir;3 Z.E€; dia
I
,
'E:!e,bB!3&.
,i e
!6 I
TE :
dr !63 !x* ;zz $:E :tE 5
E,i E-igr a E :€5!;;E $iiE ?
E:i,i g;;i !
ii i!EE; iiig :i:! igl!E :gEE ti
gg,iEiieEtiiEi
g:i:rEii !E!i ig,EE(EZZE i;-EE iE
igiiiiii ;g;i gi
H;AFiiE$ E{E; Ef
IEEiiiiliiEiiis
ai
i;
!EIFE{'t!!ElE,=
uE!i
ts9ZZ
pr;i
!:
;l!E
t!
s
&
e
EE I:! zEr :
€E I
E: rEE :es I
,B :
l; :Er E.Vz
!: ;
c.E s !
e g: e
€
xa
Ei
kaE
!
!
?
a
3
Eg
F
,:
E
E
E:*
a
tElaEI
TE
r: r
|,2t:
t::
ti9fs.E9 E
Bi€ 9
C Ei !
E ef !It;Et; E g
rP86
:i;iE; iE;
i; i E EE 5€.
ig;iii iiE
F5{tie iSii
iIE[iEiiii!i:i:; ilEE
liEi;E,3Ei:
rE *-
T E 8 E:€ tn: lE! k, E Eriv-;5e
iEiS€ e
'E!;EEI;Hi3E
i ; 5 ; !--
:EiEiF I:i-6i.E€ !iiEirtrEf;i:;: Ei 3iti
EiligEEiiit: rdi iEif !f € ! i E ! i r::FeEi=EIiE-E:ia4eEtaa))
5: { i6!iIn
i ! ,. E:
E,IEE;B; rgq
EI € Ei
Eiiii-ai:i;
i;i$i
! t;! g
; !9t;
EiETI
E E Y [;r?! e:
3
3
n
711tr
TE
3""
si ! i
!B i E[! - -
I6 Ed E,; *q I
; i -E-
E! 3;E
i: eEz
iE ZxEE; "3F3..!:ari!;2624
"E*E:vir!:t!!E--^
if!F1s!lIii:
Br I i i iitrEiii!a:-bie
x : P j i !?EfIeiUEETEB!iiE;E
s iI E E irE;iie
B!A+q:I
I!E
1E;!,E E;
t
i.
R
d!
,;'
t
t! E
- E*EEE$ q1
i dr9:r
P55
cn9
Ys!
3E s
=BE!i 55:*
:i
9l
EE
&e,
6U3:
Stltt! .
EiEtiC*EfE
EEiis{i i$iIEHESiEi;:iBEfiItrEss
i*sIt! itE:E
EfEEEiEiEE?
:*sH!^EiI
EETn.e;
o*.
f t=.a:'nPEIEEg;*
EEE€
i""9E;i6i
E I E:I CHEESEI
l!-! E
;I;Eiti-"
;:EEr;E,
F;ii
=qE!
E.
" !IeE I
r{",
B ':EE!
;Ei=
xatS! ! !,Ix ! 35!E!e
I9 EE
= tB I
its9E
!EiEat
Et
iiElr! a+
E
a
7
!i
Ea:E
E6 TE8 .i:. E
rE I
gE I;: ct: t4-- -'A: E
= E 9!
e 3 S'5E e:
f: !l
!tr 3!
gl "I .
:s tla; c:
:: i:
E
E;t{
ii;-! E !Ei r9!!I:j?;Ei i!n3EE;
: tEl
E ! 6a !"E;iit
i;5e,!
girl!
aA z;aE9;?EEi 6 a !
*; E E;E-EE9
B: iE E* 3 ' E€EdqEE
,t
EA
eZ!5
i6
TEa5
ETtg
i-E
:F24
c8
i:ZE
i,,
SE
E!
E E"9t l1zF iTB{ YI E
€ : t86 eaE: { af,
E i3f ti irt sE t;: ae 5E! =
e *4i ie EEE a
E +=: E: ::r +; ,4. ,
e i61 Ei 3E' E: -q€; -e
E ?8: p! .s[! Ig T;E E! !!E Ei EEA E
f,r ii* i
B-Er{!er:;rEEcF;;!i gEJ
68I I
EE:E ftE
g€ t
9:3
.lE!
Pa 43E RE83
:.:
Bs i
Ei;
Es<
E
e
3
!]
1
?
u
5
,:!!
EI
6I
EiiuBiiigii aig E;,
Eil ;fi ii!E:d ;e! lEii
iif9iEB:!:i5 EEt :E.
}gIIiFJiE
E
6
a
EI!
t
E
L
s
d
i.I; I
gii Ef c! E'I!E E
S E! Er +: !€:EE l.!i E! iEfi83 ii5 EE EI
i Ei EE9'E €TtEa -!1?EE':*iiiii!i
3€E;E;
Attachment E
Hydrocarbon Flaring lncident Report
at
Paee I of3
CD't159.c. Steps taken to limit the duration and/or quantity of SOz emissions:
Operations worked to safely restart and line out units immediately after the outage, per startup
procedures.
Flaring Incident Report
Brief Description of Incident: SO2 Release After Multiple Units Shutdown
lncident End Date: 410412023
Incident Type: tr Acid Gas (report due 45 days after end of event)
EI Hydrocarbon (report due in next quarterly NSPS, semiannual CD and MACT reports)
M Excess Volume (report due in next semiannual MACT report)
EI Excess HzS (report due in next quarterly CEMS report)
CD '1159. Report due: 511912023 (45-dav\,7131/2023 (Semiannual CD and MACT reoorts)
CD fl59.a. Start dates and times (list all if multiple releases are related to a sinsle event)
Start Date Start Time End Date End Time
4/3/23 8:20 am 4/4123 3:28 am
CD fl59.b. Emission Calculations for SOz from Flarins (round to one decimal point):
Constants:8.44x I 0-5 : lbmole HzS/37 9 scf HzS][64 lbs SOz/lbmole H:S] [ton/2000 lbs]
0. I 69 : [bmole HzS/379 scf HzS]F .0 lbmole SOz/l lbmole HzSl[6a lb Sor/lb mole SOz]
FR: Avg. flow rate to flare durins incident (scftr)l19.863.6
TD: Total duration of incident (hours)19.I
ConcHzS : Avg. conc. of HzS in gas flared (vol. fraction. scf HzS/scf eas)0.003
Tons of SOu: [FRllTDllConcHrSlt8.44 x l0{l 0.7
ER: Emission rate (lbs SOz/trour): [FRllConcHzSl[0.169]69.2
Root Cause Analvsis (CD tl59.d. and Subnart Ja)
Details of
lncident:
Following an external power outage which upset most of the plant's units, off gases
overwhelmed the Flare Gas Recovery Unit. This resulted in both an exceedance of the
flare gas flow threshold for the interconnected flare system, as well as a release of
SOz in excess of 500lbs.
Sequence
of events
in reverse
order
Result..Relief eas containinq SO2 was sent to the flare.
..caused bv..Multiple internal process units lost power and shut down.
..caused by..The substation faulted, intemrpting downstream power.
..caused bv..A fault cascaded through substation's re-closers.
...caused by..The bouncins lines contacted each other.
...caused bv..Heavy snow dislodged from lines at the external Parrish substation.
Root
Cause(s):
Heavy snow caused an upset at the external Rocky Mountain Power operated
substation.
Pase 2 of3
art
Flaring Incident Report
Force majeure? tr No El Yes
Significant
contributing
causes:
Heavy snowfall caused a service intemrption at the Parrish substation.
Corrective action required? tr Yes
MNo
If no, explain
basis for
conclusion:
Power intemrption was caused by an extemal force.
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:
Estimated cost:
Should an outside consultant be retained to assist in the analysis of alternatives? tr Yes
trNo
Evaluation
of possible
changes:
Design:
Operation:
Maintenance:
Status:
tr Completed
tr Schedule for implementation:Commencement:
Completion:
Measure 2
Probable effectiveness:
Estimated cost:
Should an outside consultant be retained to assist in the analysis of alternatives? tr Yes
trNo
Evaluation
of possible
changes:
Desien: N/A
Operation: Procedures and training will need to be developed.
Maintenance: Procedures and trainine will need to be develooed.
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
chanqes:
Design:
Operation:
Maintenance:
Flaring Incident Report
trC leted
tr Schedule for implementation:
CD fl59.f. Statement Identifuing Grounds for Stipulated Penalties
fl62. Grounds
for stipulated
penalties due
to root cause
tr 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 tr Startup/Shutdownfupset
fl63. Grounds
for stipulated
penalties due
to frequency
tr 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
ofSOz
! Total of Acid Gas Flaring Incidents in rolline l2-month oeriod >5 fN/A)
Defenses E Force Maieure tr Malfunction tr Startup/Shutdownfuoset
fl64. Grounds
for stipulated
penalties due
to cause
recuffence
tr First time
tr 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
E Recurrence. agreed-upon malfunction
E Recurrence, corrective action plan not yet completed
E Recurrence, root cause investisation still underwav
Clarification on first
time or recrurence:
Defenses
tr Force Majeure tr Malfunction tr Startup/Shutdown/Upset
tr Corrective action being developed tr Root cause of investigation pending
CD fl59.e. WilyDid investisation take lonser than 45 davs? D No tr Yes
lf yes, when will investigation be complete and report sent to EPA?
CD fl59.h. Will corrective action take > 45 days? tr No tr Yes (followup report to EPA w/in 30
days)