HomeMy WebLinkAboutDAQ-2025-000069,.tttFfinchr
January 31,2023
Mr. Bryce Bird, Director
Division of Air Quality
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake city, Utah 84116
RE: 40 CFRPart60, SubpartJa
Periodic Report July I through December 31,2022
Dear Mr. Bird:
UTAH DEPARTMENT OF
ENVIRONMENTAL QUALITY
rtE -rj ?c2:)
DIVISION OF AIR QUALITY
Certified Mail: 7019 1 120 0000 0070 77 60
Pursuant to 40 CFR 60 NSPS Subpart Ja and 40 CFR 60.7(c), FIF Sinclair Woods Cross Refining LLC,
I{FSWCR, is submitting this periodic report of excess emissions in accordance with 40 CFR 60.108a(d).
Additionally, fmSWCR maintains records of discharges exceeding certain amounts in accordance with 40
CFR 60.108a(cX6). 40 CFR 108a(c)(6) requires the owner/operator to maintain records of releases that
exceed 500 lbs SOz in arry 24-hour period from any affected flare, discharges greater than 500 lbs SOz in
excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant and discharges
to an affected flare in excess of 500,000 scf above baseline in any Z4-hour period. These records are to be
included in periodic excess emissions reports pursuant to 40 CFR 60.108a(d)(5). For the period of July 1,
2022 tbrottgh December 31,2022 the records maintained include the following:
Additional requirements of reporting excess emissions as required in 40 CFR 60.7(c) and 40 CFR 60.108a
were reported in quarterly CEMS reports dated 1 0/1 8 12022 and 1127 12023 .
If you have any questions or need additional information, please contact F. Travis Smith at (801) 299-
6625 or email ftravis. smith@hfsinclair.com.
HF SinclairWoods Cross Refining LLC
1070 W. 500 S. West Bountiful, UT 84087
801 -299-6600 | HFSinclair.com
60.108(cX6)Discharge greater than 500 lbs
SO2 (24-hr period) from:
Affected Flare, Fuel Gas
Combustion Device, or SRU
Affected Flare: I discharge, 1012512022,
RCA included in Auachment A. The RCA
for the SOz event that occurred on
612912022 is also included in Attachment
A.
Fuel Gas Combustion Device: None during
reporting period.
SRU: None durins reportins period.
Discharge in excess of 500,000
scf above baseline (24-tt period)
Affected Flare: I discharge, 101512022,
RCA included in Attachment A. The RCA
for the flow event that occurred on
612912022 is also included in Attachment
A.
REVIEWEDInitials:Date: Jan 8, 2025Compliance Status: OKFile #: 10123 (B2)
I c€rtify under peiralties of law thd, bas€d upon lnquiry of personnel involve4 the statements and
information contained in this r€port are tuthful and acctratg and are a complete rrcord of all monitoring
rslated events that occurred during the reporting period.
Sincerely,
Vice Presideirt and RefineryManager
Attachments
cc: E. Benson (r) File 2.2.7.2
Attachment A - 60.108a(c)(6) - Root Cause Analysis (RCAs)
UTAH DEPABTMENT OF
ENVIRONMENTAL QUAUTY
1[3 _:2C?3
DIVISION OF AIR QUALITY
Page I of3
HollyFrontier Woods Cross Refining LLC
1070 West 500 South
West Bountitul, UT 84087
(801) 299-6600
DATE:811212022
RE: 40 CFR Part 60 Subpart Ja: Investigation for flow and SOz from Flares
per 60.103a(c)(l)HorryFnoNTIER
60.108a(cX6Xi) A on of the
Following a significant power loss 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 500 lbs.
60.108a(c)(6Xii) The date and time the discharge was fust identified and the duration of the discharge.
Event Start Date & Time: 612912022 at7:34 ANI
Event Duration: 14.58 hours
60. l08a(cX6Xiii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the
discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the
measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge
exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-how period. Engineering calculations are
allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative
monitori in S60.1
Affected Facility(s)Measured Quantity of Gas
Discharged over Event
Duration (dscfl
24-Hour Period Quantity of Gas Discharged
in 24-Hour Period (dscf;
Interconnected
Flares (FGRU
online)
1,978,322 N/A N/A
60. l08a(c)(6)(iv) For each discharge greater than 500lbs SOz in any 24-hour period from a flare, the measured total sulfur
concentration or both the measured HzS concentration and the estimated total sulfur concentration in the fuel gas at a
tive location in the flare inlet.
24-Hour Period Average
Measured Total Sulfur
5375.23
60.108a(c)(6)(v) For each discharge greater than 500lbs SOz in excess of the applicable short-term emissions limit in
$60102a(g)(l) from a fuel gas combustion device, either the measured concentration of HzS in the fuel gas or the
measured concentration of SOz in the stream discharged to the atmosphere. Process knowledge can be used to make these
estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in
060.107a(eX4).
Not applicable to this event.UTAH DEPARTIVIENT OF
i
HollyFrontierWoodsCrossRefiningLLC, l0T0WestS00South,WestBountiful, UT84[87-1442,Phone(801)299+OOO,fdx(601)2m$50tr-i.. DIVISION OF AIR QUALITYI
Page 2 of 3
HollyFrontier Woods Cross Refining LLC
1070 West 500 South
West Bountiful, UT 84087
(8Ol ) 299-6600
60.108a(c)(6) (vi) For each discharge greater than 500lbs SOz in excess of the allowable limits from a sulfur recovery
either the measured concentration of reduced sulfur or SOz discharged to the atmosphere.
Not applicable to this event.
60.108a(c)(6) (vii) For each discharge greater than 500lbs SOz in any 24-hour period from any affected flare or discharge
greater than 500lbs SOz in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the
cumulative quantity of HzS and SOz released into the atmosphere. For releases controlled by flares, assume 99-percent
conversion of reduced sulfur or total sulfur to SOz For fuel gas combustion devices, assume 99-percent conversion of HzS
to SOz.
Affected Facility Cumulative Quantity of HzS
Released over Emission
Limit (pounds)
Cumulative Quantity of
SOz Released Over
Emission Limit(oounds)
Interconnected
Flares (FGRU
online)
6.21 760.00
60.108a(cX6) (viii) The steps that the owner or operator took to limit the emissions durine the
In order to minimize emissions, Operations worked to safely bring units offline immediately after the outage. Following
the restoration ofpower, Operations brought units back online, per startup procedures.
Affected Facility(s): Interconnected Flare
Date of Disch arge: 6/29 I 2022
Duration of Discharge: 14.58 hours
ROOT CAUSE AI\ALYSIS
o The power supply to the majority of the plant was intemrpted after an off-site capacitor, operated by Rocky
Mountain Power, faulted following a bird strike.
CORRECTIVE ACTION ANALYSIS
o N/A
This incident did not result from the same root cause as previous events investigated per this rule.
60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in g 60.103a(d), including
an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge
resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended
corrective action(s) or an ex of whv corrective action is not under $ 60.103a(e).
60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in g 60.103a(e), a
description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not
a schedule for ntation, includi commencement and ion dates.
Corrective Action Actions
Completed
within 45 davs
Proposed Start
Date
Completion
Date
HollyFrontier Woods Cross Refining LLC, 1070 West 500 South, West Bountiful, UT 84087-1442, Phone (801 ) 2996600, Fax (801) 299-6609
Page 3 of3
HollyFrontier Woods Cross Refining LLC
1070 W6st 500 South
West Bountitul, UT 84087
60.108a(c)(6) (xi) For each discharge from any affected flare that is the result ofa planned startup or shutdown ofa
refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and
corrective action analysis are not because the owner or oDerator followed the flare
N/A
HollyFrontierWoods Cross Refining LLC, 1070 West 500 South, West Bountitul, UT 8/,087-1442, Phone (801) 299S600, Fax (801) 299-6609
Page 1 of3
HollyFrontier Woods Cross Refining LLC
1070 West 500 South
West Bountiful, UT 84087
(801) 299-6600
DATE: llll7l2022
RE: 40 CFR Part 60 Subpart Ja: Investigation for flow from Flares per
60.103a(cXl)HOTTyFnONTIER
60.108a(c)(6)(i) A of the
Repairs were ongoing to the controls for a valve in the Unit 4 FCC when a pressure swing interlocked the unit. Following
a subsequent loss of Unit 19 DHT, offgases overwhelmed the Flare Gas Recovery Unit. This resulted in an exceedance of
the flare gas flow threshold for the interconnected flare system.
60.108a(cX6)(ii) The date and time the discharge was fust identified and the duration of the discharge.
Event Start Date & Time: 101512022 at l2:22PM
Event Duration: 7.37 hours
60.108a(c)(6)(iv) For each discharge greater than 500lbs SOz in any 24-hour period from a flare, the measwed total sulfur
concentration or both the measured HzS concentration and the estimated total sulfrr concentration in the fuel gas at a
ive location in the flare inlet.
Not applicable to this event,
60.108a(c)(6)(v) For each discharge greater than 500lbs SOz in excess of the applicable short-term emissions limit in
$60102a(g)(1) from a fuel gas combustion device, either the measured concentration of HzS in the fuel gas or the
measured concentration of SOz in the stream discharged to the atmosphere. Process knowledge can be used to make these
estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in
.107a(eX4).
Not applicable to this event.
60. l08a(c)(6Xiii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the
discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the
measured or calculated cumulative quantity ofgas discharged to the flare over the discharge duration. Ifthe discharge
exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are
allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative
uirements in 060.1
Affected Facility(s)Measured Quantity of Gas
Discharged over Event
Duration (dscfl
24-Hour Period Quantity of Gas Discharged
in 24-How Period (dscf)
Interconnected
Flares (FGRU
online)
t6,086,467 N/A N/A
HollyFrontier Woods Cross Refining LLC, 1070 West 500 South, West Bountiful, UT U087-1442, Phone (801) 299{600, Fax (801) 299-6609
Page 2 of 3
HollyFrontier Woods Cross Refining LLC
1070 West 500 South
West Bountiful, UT 84087
(80't) 293-6600
60.108a(c)(6) (vi) For each discharge greater than 500lbs SOz in excess of the allowable limits from a sulfur recovery
either the measured concentration of reduced sulfur or SOz discharged to the
Not applicable to this event.
60.108a(c)(6) (vii) For each discharge grcater than 500lbs SOz in any 24-hour period from any affected flare or discharge
greater than 500lbs SOz in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the
cumulative quantity of HzS and SOz released into the atmosphere. For releases controlled by flares, assume 99-percent
conversion of reduced sulfur or total sulfur to SOz. For fuel gas combustion devices, assume 99-percent conversion of HzS
to SOz.
Not applicable to this event.
60.108a(cX6) (viii) The steps that the owner or operator took to limit the emissions durine the di
In order to minimize emissions, Operations and maintenance personnel worked to stabilize the units by repairing and
restarting affected equipment. The flow exceedance occurred despite their efforts.
60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in g 60.103a(d), including
an identification ofthe affected facility, the date and duration ofthe discharge, a statement noting whether the discharge
resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended
corrective action(s) or an explanation of why corrective action is not necessary under $ 60. I 03a(e
Affected Facility(s): Interconnected Flare
Date of Discharge: l0l5/2022
Duration of Discharge: 7.37 hours
ROOT CAUSE ANALYSIS
o A pressure swing in the Unit 4 Syn Tower during maintenance on its bottom EIV controls interlocked the unit.
Off gases resulting from the Unit 4 and Unit 19 interlocks relieved to the flares, causing an exceedance of the
interconnected flare flow threshold.
CORRECTIVE ACTION ANALYSIS
o Complete repairs to Syn Tower Bottoms EIV, in order to line out and restart units.
This incident did not result from the same root cause as previous events investigated per this rule.
60.108a(cX6) (x) For any corrective action analysis for which corrective actions are required in $ 60.103a(e), a
description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not
alreadv comoleted. a schedule for imolementation. includins orooosed commencement and comoletion dates.
Corrective Action Actions
Completed
within 45 davs
Proposed Start
Date
Completion
Date
Repair Syn Tower Bottoms EIV Yes t0l5/22 t0l5/2022
HollyFrontier Woods Cross Refining LLC, 1070 West 500 South, West Bountitul, UT 84087-1442, Phone (801) 2996600, Fax (801) 299-6609
Page 3 of3
HollyFrontier Woods Cross Refining LLC
1070 West 500 South
West Bountitul, UT 84087
(801) 2e96600
60.108a(c)(6) (xi) For each discharge from any affected flare that is the result ofa planned startup or shutdown ofa
refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and
corrective action analvsis are not because the owner or operator followed the flare
o N/A
HollyFrontierWoods Cross Refining LLC, 1070 West 500 South, West Bountitul, UT 8/;087-'1442, Phone (80,l) 2996600, Fax (S01) 299-6609
,.tttFfinctorr
DATE: l2lEl2022
RE: 40 CFR Part 60 Subpart Ja: Investigation for SOz from Flares per 60.103a(c)(l)
60.1 cX6Xi) A of the
Following an interlock of the Straight Run Gas Compressor, l lK2, off gases overwhelmed the Flare Gas Recovery
Unit. This resulted in a release of SOz from the interconnected flare system in excess of 500 lbs within a 24-hour
period.
60.108a(cX6Xii) The date and time the discharse was first identified and the duration of the di
Event Start Date & Timq 1012512022 at 5:33 ANI
Event Duration: 12.40 hours
60. l08a(c)(6)(iv) For each discharge greater than 500lbs SOz in any 24-hour period from a flare, the measured total
sulfur concentration or both the measured HzS concentration and the estimated total sulfur concentration in the fuel
ata ive location in the flare inlet.
24-Hour Period Average
Measured Total Sulfur
983.97
60.108a(c)(6)(v) For each discharge greater than 500lbs SOz in excess of the applicable short-term emissions limit in
$60102a(g)(l) from a fuel gas combustion device, either the measured concentration of HzS in the fuel gas or the
measured concentration of SOz in the stream discharged to the atmosphere. Process knowledge can be used to make
these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as
ided in $60.107a(eX4).
HF Sinclair Woods Cross Refining LLC
1070 W. 500 S, West Bountiful, UT 84087
801 -299-6600 | HFSinclair.com
60.108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If
the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record
the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the
discharge exceeds 24 hours, record the quantity ofgas discharged to the flare for each 24-hourperiod. Engineering
calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying
with the alternative monitorin in 860.1
Affected Facility(s)Measured Quantity of Gas
Discharged over Event
Duration (dscfl
24-Hour Period Quantity of Gas Discharged
in 24-Hour Period (dsc!
Interconnected
Flares (FGRU
online)
N/A N/A N/A
Not applicable to this event.
60. I 08a(c)(6) (vi) For each discharge greater than 500lbs SOz in excess of the allowable limits from a sulfur
recovery plant, either the measured concentration of reduced sulfur or SOz discharged to the atmosphere.
Not applicable to this event.
60.108a(c)(6) (vii) For each discharge greater than 500lbs SOz in any 24-hour period from any affected flare or
discharge greater than 500lbs SOz in excess of the allowable limits from a fuel gas combustion device or sulfur
recovery plant, the cumulative quantity of HzS and SOz released into the atmosphere. For releases controlled by
flares, assume 99-percent conversion of reduced sulfur or total sulfur to SOz For fuel gas combustion devices,
assume 99-percent conversion of HzS to SOz.
Affected Facility Cumulative Quantity of HzS
Released over Emission
Limit (oounds)
Cumulative Quantity of
SOz Released Over
Emission Limit(oounds)
Interconnected
Flares (FGRU
online)
N/A N/A
60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the di
In order to minimize emissions, Operations made numerous affempts 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 preJube oil pump motor, Operations lined the
compressor back out and brought units back up to charge rate.
Affected Facility(s): Interconnected Flare
Date of Discharge: 1012512022
Duration of Discharge: 12.40 hours
ROOT CAUSE AI\ALYSIS
o The motor for the pre-lube pump servicing I lK2 failed, resulting in the compressor interlocking.
CORRECTIVE ACTION ANALYSIS
r Replace I lK2's pre-lube oil pump motor.
This incident did not result from the same root cause as previous events investigated per this rule.
60. 1 08a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in g 60. I 03a(d),
including an identification of the affected facility, the date and duration of the discharge, a statement noting whether
the discharge resulted from the same root cause(s) identified in a previous analysis and either a description ofthe
recommended corrective action(s) or an ion of why corrective action is not under d 60.103a(e
60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in $ 60.103a(e), a
description of the corrective action(s) completed within the first 45 days following the discharge an4 for action(s)
not a schedule for implementati commencement and completion dates.
Corective Action Actions
Completed
within 45 davs
Proposed Start
Date
Completion
Date
Replace the pre-lube oil pump motor for l1K2 Y 1012512022 t012512022
60.108a(c[6) (xi) For each discharge from any affected flare that is the result ofa planned startup or shutdown ofa
refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and
corrective action analvsis are not because the owner or operator followed the flare
o N/A
UTAH DEPAHTMENT OF
ENVIRONMENTAL OUAUry
FEB _6 2023
DIVISION OF AIR QUALITY