DAQ-2024-011880

Department of
Environmental Quality
Kimberly D. Shelley
Executit'e Direclor
DTVISION OF AIR QUALITY
Bryce C. Bird
DireclorSPENCER J. COX
Goventor
DEIDRE HENDERSON
Lieutenant Governor
November 2L,2024
Sent Via Certified Mail No. 70190700000208347723
Dean Anderson, Vice President
Tesoro Refining and Marketing Company, LLC
474 West 900 Noth
salt Lake city, uT 84103
Dear Mr. Anderson:
DAQC-1156-24
Site ID 1033s (81)
Re:Warning Letter - Tesoro Refining and Marketing Company,LLC (Tesoro), Utah
Administrative Code (UAC) R307-170-7 and 40 CFR 60 Appendix F, Salt Lake County
Tesoro operates a Total Sulfur Continuous Emissions Monitor (CEM) on the North Flare at the
Salt Lake Refinery facility in Salt Lake City, UT. In accordance with UAC R307-170-7 and 40
CFR 60, Appendix F, the Total Sulfur CEM is required to be audited each calendar quarter. It was
reported by Tesoro that the Total Sulfur CEM on the North Flare was not audited during the third
calendar quarter of 2024, between July l, 2024, and September 30,2024.
Appendix A to the cover letter for the 3Q2024 State Electronic Data Report reported that Tesoro
conducted the required Cylinder Gas Audit (CGA) of the Total Sulfur CEM system on October
11,2024, for the Refinery North Flare. This CGA was performed to demonstrate a return to
compliance for this monitor. Results of the test were stated to be within audit specifications.
Tesoro stated in Appendix A that several factors contributed to the failure to audit the monitor for
Total Sulfur including: a RATA was performed on the unit for H2S for the quarter, an errant entry
in the SAP-based maintenance work order system, and failure to assign a specific team member to
the oversight of the unit calibration. The letter stated that the scheduling error has been corrected
and trained staff members have been assigned to the CEM oversight role to implement double
checks to better ensure that monitor calibrations and audits are performed correctly and on time.
Please be aware this letter is a warning and that future instances of noncompliance may be
considered violations of 40 CFR 60 Appendix F or UAC R307-170 and Tesoro may be assessed
penalties up to $10,000 per day if found to be in violation of the CFR or Utah Air Quality Rules.
195 North 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 144820 . Salt Lake City, UT 841144820
Telephone [phone]. Fax [phone]. T.D.D. [phone]
ww.deq.utqh.gov
Printcd on 100% recycled paper
DAQC-1ts6-24
Page2
A response to this letter is not required. If you have any questions regarding this letter, please
contact Harold Burge at [phone] or at [e-mail].
Sincerely,
,t- t'
lay [,lon is (Nov 20, 2024 09:38 [.4SI)
Bryce C. Bird
Director
BCB:HAB jl
cc: Salt Lake County Health Department
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DIVISION OF AIR QUALIW
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DEANANDERSON
TESORO REFINING AND MAR
474W 900 N
SALT LAKE CIry, UT 84103
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