DAQ-2024-011829

-BigWis 333W.Center Street. North Salt Lake Utah 84054. 801.296.7700. wwwbigwestoil.com
DfPATIIMENT OF
ENVIHONMINIAL QUALITYNovember 20,2024
CERTIFIED MAIL
RETURN RECETPT NO. 9589 0710 5270 0120 7651 14
Bryce Bird, Director
Division of Air Quality
Utah Department of Environmental Quality
P.O. Box 144820
Salt Lake city, Utah 84114-4820
RE: SIP PM 2.5 & PM 10 Deviation Report - November 1,2022, to October 31,2024
Dear Mr. Bird,
In compliance with the requirements of the Utah State Implementation Plan, Section IX, Part H, the
following constitutes "a report of any deviation from the applicable requirements of this Subsection IX.H"
(gH.l.c.iii & $H.l Lc.ii) applicable to the Big West Oil, LLC - North Salt Lake Refinery @WO). This
submittal covers the period from November 1,2022, to October 31,2024
Certification Statement:
I certify that this information was prepared under my direction or supervision in accordance with a system
designed to ensure that qualified personnel properly gather and evaluate the information submitted. Based
on my directions and my inquiry of the person(s) who manage the system, or the person(s) directly
responsible for gathering the information, the information submitted is, to the best of my knowledge and
beliel true, accurate, and
Alec Klinghoffer
Refinery Manager
If you have any questions concerning the content of this report, please contact Trevor Barlow at (385) 324-
1261.
Jeremy Marsigli, UDAQ - Electronic Copy
Page I of5
B-2-10122
$H.l and $H.11 General Requirements for PM l0 & PM 2.5
I. Stack Tests - $H.l.e & $H.1l.e
As applicable, BWO complies with the stack testing requirements found in $H.l .e.i & $H.1 1.e.i. Records
of Stack Test Protocols are sent to Utah's Division of Air Quality (UDAQ) for approval. Stack test results
are also sent to UDAQ.
II. Continuous Monitoring - $H.l.f & SH.l1.f
Any deviations from continuous monitoring found in $H.l.f.i.A & $H.ll.f.i.A are reported to UDAQ
the Quarterly SEDR/CEM Excess Emission Reports. BWO complies with all other requirements found
$H.l.f and $H.l l.f.
III. FCCU SO2 Emission Limits - $H.1.g.i.A & $H.11.g.i.A
The SO2 emission limit for the FCCU listed in $H.l .g.i.A.I & $H.l I .g.i.A.l is 25 ppmvd @ 0% excess air
on a 365-day rolling average basis, and 50 ppmvd @ 0% excess air on a 7-day rolling average basis. Any
deviations from this limit are reported to UDAQ in the Semiarmual Consent Decree Report.
IV. FCCU PM Emission Limits - $H.l.g.i.B & $H.11.g.i.B
BWO is compliant with the emission limit of l.0 pounds PM per I 000 pounds burn-off found in $H. I .g.i.B.I
& $H.l Lg.i.B.I. This was demonstrated by the Stack Tests performed on the MSCC on December 15,2023.
BWO installed a COMS as per the requirements of 40 CFR 63.1572(b) bV January 1,2019, as specified in
gH.l.g.i.B.III & $H.1.g.i.B.III. Any deviations from the opacity limit are found in the Semiannual MACT
UUU reports submitted to UDAQ.
V. Fuel Gas Limits - $H.l.g.ii.A & $H.11.g.ii.A
The fuel gas at BWO is applicable to the appropriate subparts of NSPS Ja. Any deviations from those
monitoring or emission limits are submitted in the Quarterly SEDWCEM Excess Emission Reports.
VI. No Burning of Liquid Fuel Oil in Stationary Sources - $H.1.g.iv & H.ll.g.vii
BWO complies with $H.l.g.iv.A & $H.1l.g.vii.A and does not burn liquid fuel oil in stationary sources
except during natural gas curtailment. BWO reserves the right to use diesel fuel for emergency equipment
that meets the specifications of 40 CFR 80.510 as specified in $H.1.g.iv.B, $H.2.a.iv.A, $H.1l.g.vii.B &
$H.l2.a.iv.A.
VII. Requirements on Hydrocarbon Flares - $H.l.g.v & $H.ll.g.v
All hydrocarbon flares are applicable to NSPS Ja, as listed in $H.l.g.v.A & $H.ll.g.v.A. Deviations to
those regulations are reported in the Quarterly SEDR/CEM Excess Emission Report, the Semiannual
Consent Decree Report, and the Semiarmual NSPS Ja Report.
in
in
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BWO had two hydrocarbon flares during the reporting period: the South Flare (X-913) and the West Flare
(FLR-I800). BWO is subject to $H.l.g.v.B.2 & $H.ll.g.v.B.2, which limits flaring during normal
operations to 500 MSCFD for each flare on a 24-hour block average.
^. 8H.1.e.v.B & QH.11.e.v.B - Hvdrocarbon Flare Dailv Flows above 500 MSCFD durine
Normal Operations.
SIP PM 10 & PM 2.5 - High Flare Flow Deviations During Reporting Period
South Flare X-913 West Flare FLR-1800
Deviation Date Daily Flare FIow
>5OO MSCFD Deviation Date Daily Flare Flow
>5OO MSCFD
12t2812022 504.73 1210612023 s01.23
0410112024 543.85
0710712024 s08.91
i. Flare Flow Probable Cause and Corrective Actions or Preventative Measures- South
Flare Event I on 1212812022
The excess vent gas flow causing this flow exceedance was attributed to normal flow to the flare.
Immediate corrective actions included operations training to improve the continuous monitoring of
environmental Iimits.
ii. Flare Flow Probable Cause and Corrective Actions or Preventative Measures- West
Flare Event 2 on 1210612023
The excess vent gas flow causing this flow exceedance was not identified. Big West Oil operations
attempted to identify the cause of the West Flare's high flow. They blocked in relief valves within
the Reformer, Butamer, Crude, HDS, Amine, and MIDW units, but the flow did not significantly
decrease. Flow returned to normal levels before additional flow exceedances occurred.
iii. Flare Flow Probable Cause and Corrective Actions or Preventative Measures- West
Flare Event 3 on 04/01/2024
The excess vent gas flow causing this flow exceedance was attributed to an increase in
supplemental gas flow used to raise the net heating value (NHV) of the flare vent gas, causing the
total flare flow to fluctuate between 600 and 850 MSCFD between 08:00 and l8:00 on March 31,
2024. This resulted in an elevated 24-hour flow in excess of 500 MSCFD. Flow was reduced as
soon as the NHV normalized.
iv. Flare Flow Probable Cause and Corrective Actions or Preventative Measures- West
Flare Event 4 on 07 107 12024
West Flare steam flow was increased to improve combustion and mitigate flare visible emissions.
The increase in steam flow lowered the combustion zone NHV. More supplemental gas was needed
to comply with the flare's NHV limits. This resulted in an elevated 24-hour flow in excess of 500
MSCFD.
Page 3 of5
Stationary Tank Opening and Degassing Notification Deviations - SH.ll.g.vi
Date Tank Service Capacity TVP
812912023 Tank 9 Wastewater 833,700 gal 3.56 psia
VIII. Sulfur Removal Units - $H.l.g.iii
BWO elects to comply with a 95% Sulfur Removal Efficiency, as listed in $H.l.g.iii.a.I, and Amine acid
gas and Sour Water Stripper acid gas are processed in the SRU as listed in $H.l.g.iii.B. Any deviations
from the SRU Efficiency on a 30-day rolling average (as listed in $H.l.g.iii.C) are listed in the Semiarurual
Consent Decree Report.
IX. Limits on Heat Exchangers - $H.11.g.iii
BWO complies with 40 CFR 63.654 for heat exchange systems in VOC service as listed in $H.11.g.iii. Any
deviations from this standard are reported in the MACT CC Semiannual Report.
X. Leak Detection and Repair Requirements - $H.11.g.iv
BWO complies with 40 CFR 60.590a to 593a as listed in $H.ll.g.iv.A. Any deviations from those
requirements are reported in the MACT CC Semiannual Report.
XI. Requirement on Tank Degassing - $H.11.g.vi
BWO is subject to $H.1 I .g.vi.C and its requirements to properly notify the Director of the intent to degas
any tanks applicable to $H.1 1.g.vi.A of 40,000 gallons or greater with a true vapor pressure equal to or
greater than 1.25 psia at least 3 days prior to degassing operations. Any deviations to this requirement are
included in this report.
a. Tank Degassing Deviation Events and Corrective Actions
The table above highlights an event on August 29, 2023, where a stationary tank applicable to
$H.l1.g.vi.A was opened without degassing and without propernotihcation to the state. BWO has
implemented administrative changes to organization roles and responsibilities, operations and
maintenance expectations, and environmental department involvement in tank logistics meetings that
will prevent this oversight from occurring in the future.
Page 4 of5
H.2 & H.12 Source Specific Emission Limitations to Salt Lake County PM 10 & PM 2.5, Big West
Oil Specific Requirements
XII. Source-Wide NOx Cap- $H.2.a.ii & SH.f2.b.ii
BWO has a NOx cap of no greater than 0.8 tons per day and 195 tons per rolling l2-month period as listed
in gH.2.a.ii and $H.l2.b.ii. No NOx emission deviations of the daily or l2-month caps occulred during the
reporting period.
XIII. Source-Wide SO2 Cap- $H.2.a.iii & $H.12.b.iii
BWO has an SO2 cap of no greater than 0.6 tons per day and 140 tons per rolling l2-month period as listed
in gH.2.a.iii and $H.l2.b.iii, save during times when the FCCU is starting up or shutting down, as listed
below. No SO2 emission deviations of the daily or l2-month caps occurred during the reporting period.
XIV. Alternate Startup and Shutdown Requirements- $H.2.a.v & $H.12.b.v
On any day that includes startup or shutdown of the FCCU, the SO2 emission cap is raised to 1.2 tons per
day, as listed in $H.2.a.v.A and $H.l2.b.v.A. This exemption is only allowed to be claimed 10 days per 12-
month rolling period, as listed in $H.2.a.v.B and $H.l2.b.v.B. There were no days where the FCCU was in
startup or shutdown and the SO2 emissions exceeded 1.2 tons per day, and there were fewer than l0 days
that BWO used the alternate startup/shutdown limit.
XV. Control Emission Equipment- $H.2.a.vi & $H.l2.b.vi
All control equipment listed in $H.2.a.vi & $H.12.b.vi. is installed and in operation at Big West Oil.
XVI. Source-Wide PM10 Cap- $H.2.a.i
BWO has a PM10 cap of no greater than 1.037 tons per day, as listed in $H.2.a.i and $H.2.b.i. Additionally,
PM10 stack tests on the FCCU shall be conducted at a minimum of once every three (3) years as listed in
$H.2.a.i.B and $H.l1.g.i.B.II. The most recent stack test was performed in December 2023, and the next
stack test is scheduled to be conducted before December 2026. No PMIO deviations of the daily or 12-
month caps occurred during the reporting period.
XWI. Source-Wide PM2.5 Cap- $H.12.b.i
BWO has a PM2.5 cap of no greater than 0.29 tons per day and 72.5 tons per rolling l2-month period as
listed in $H.12.b.i. Additionally, PM2.5 stack tests on the FCCU shall be conducted at a minimum of once
every three (3) years as listed in $H.2.a.i.8 and $H.l l.g.i.B.IL The most recent stack test was performed in
December 2023, and the next stack test is scheduled to be conducted before December 2026. No PM2.5
deviations of the daily or 12-month caps occurred during the reporting period.
END OF REPORT
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