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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