HomeMy WebLinkAboutDAQ-2025-000070'rl ,.tttF$nctorr
Jtuly 31,2023
Mr. Bryce Bird, Director Certified N.4.ail:70220410 00023551 6400
Division of Air Quality
Utah Department of Environmental Quality UTAH DEeARTMENT oF
195 North 1950 West ENVIRONMENTAL QUAUTY
Salt Lake city, Utah 84116
RE: 40 CFRPart60, SubpartJa AUC - " ?A23
Periodic Report January I through June 30, 2023
Dear Mr. Bird: DlvlstoN oF AIR QUALITY
Pursuant to 40 CFR 60 NSPS Subpart Ja and 40 CFR 60.7(c), HF Sinclair Woods Cross Refining LLC,
HFSWCR, is submitting this periodic report of excess emissions in accordance with 40 CFR 60.108a(d).
Additionally, HFSWCR maintains records of discharges exceeding certain amounts in accordance with 40
CFR 60. I 08a(cX6). 40 CFR I 08a(cX6) requires the owner/operator to maintain records of releases that
exceed 500 lbs SOz in any 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 24-hov period. These records are to be
included in periodic excess emissions reports pursuant to 40 CFR 60.108a(dX5). For the period of
January 1,2023 through June 30, 2023 the records maintained include the following:
60.108(cX6)Discharge greater than 500 lbs
SOz (24-tr period) from:
Affected Flare, Fuel Gas
Combustion Device, or SRU
Affected Flare: I discharge, RCA included
in Attachment A.
Fuel Gas Combustion Device: None during
reporting period.
SRU: None durins reoortins oeriod.
Discharge in excess of 500,000
scf above baseline (24-br neriod)
Affected Flare: 2 discharges, 2 RCAs
included in Attachment A.
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 dated412712023 and712512022.
If you have any questions or need additional information, please contact F. Travis Smith at (801) 299-
6625 or email ftravis.smith@hfsinclair.com.
I certiff under penalties of law that, based upon inquiry of personnel involved, the statements and
information contained in this report are truthful and accurate, and are a complete record of all monitoring
related events that occurred during the reporting period.
HF Sinclair Woods Cross Refining LLC
1070 W. 500 S, West Bountiful, UT 84087
801-299-6600 | HFSinclair.com
REVIEWED Initials: Date: Jan 8, 2025Compliance Status:OKFile #: 10123 (B2)
Sincerely,
Vice President and Refinery Manager
Attachments
cc: E. Benson (r) File 2.2.7.2
Attachment A - 60.108a(cX6) - Root Cause Analysis (RCAs)
UT
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DATE: 411212023 - RCA not required per 60.103a(dx3) - FMP followed for SU/SD eventi VISION
RE: 40 CFR Part 60 Subpart Ja: Investigation for flow from Flares per 60. I 03a(c)( I )
60.1 c A iption of the di
While bringing units down for a planned turnaround, off gases sent to the North Flare exceeded the flare gas flow
limit.
60.108a(cX6)(ii) The date and time the discharge was first identified and the duration of the discharge.
Event Start Date & Time31212023 at2:32PM
Event Duration: 129.40 hours
OF AIR
60. I 08a(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 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 ine reouirements in 660.1
Affected
Facility(s)
Measured Quantity of Gas
Discharged over Event
Duration (dscfl
24-Hour Period Quantity of Gas Discharged
in 24-Hour Period (dscf)
North Flare
(FGRU offline)
25,737,214 3 1212023 14:32 - 3 I 3 /2023
l4:31
3,919,106
3 / 3 12023 I 4:32 - 3 I 4 /2023
l4:31
5,867, I I 5
3 I 4 /2023 I 4:32 - 3 / 5 12023
l4:31
6,964,925
3 I 5 12023 14:32 - 3 I 612023
l4:31
6,699,982
3 /612023 | 4:32 - 3 17 12023
l4:31
1.880,822
31712023 14:32 - 31712023
23:56
406,364
HF Sinclair Woods Cross Refining LLC
1070 W. 500 S, West Bountiful, UT 84087
801 -299-6600 | HFSinclair.com
60. l08a(c)(6)(iv) For each discharge gr€ater 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
at a representative location in the flare inlet.
Not applicable to this event.
60. l08a(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 measwed concentration of HzS in the fuel gas or the
measured concentration of SOz in the sfream 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
in 060.107a(eX4
Not applicable to this event.
60.108a(c)(6) (vi) For each discharge greater than 500lbs SOz in excess of the allowable limits llom a sulfur
either the measured concentration of reduced sulfur or SOz di to the
Not applicable to this event.
60.108a(c)(6) (vii) For each discharge greater than 500lbs SO2 in any 24-how 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 sulfi.r 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 during the
In order to minimize emissions, Operations staggered flaring during the turnaround de-inventory. The flow
exceedance occurred, despite their efforts.
Affected Facility(s): North Flare
Date of Disch ar ge: 3 12 I 2023
Duration of Discharge: 129.40 hours
ROOT CAUSE ANALYSIS
. Offgases from the degassing ofturnaround units relieved to the flares, causing an exceedance ofthe north
flare flow limit.
60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in $ 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 ofthe
recommended corrective action(s) or an ion of whv corrective action is not under S 60.103a(e
CORRECTIVE ACTION ANALYSIS
. N/A
This incident did not result from the same root cause as previous events investigated per this rule.
60.108a(c)(6) (xi) For each discharge from any affected llere 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 management plan.
o RCA not required per 60.103a(d)(3) - FMP followed for SU/SD event.
60.108a(cX6) (x) For any corrective action analysis for which corrective actions are required in g 60.103a(e), a
description of tle corrective action(s) completed within the fir$t 45 days following the discharge and, for action(s)
a schedule for i commencement and cormletion dates.not
Corrective Action Actions
Completed
within 45 davs
Proposed Start
Date
Completion
Date
N/A N/A N/A N/A
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DATE: 511712023
RE: 40 CFR Part 60 Subpart Ja: Investigation for flow and SO2 from Flares per 60.103a(c)(l)
60, l08a(cX6 A of the disc
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 ofthe flare gas flow threshold for the interconnected flare
system, as well as a release of SOz in excess of 500 lbs.
60.108a(cX6)(ii) The date and time the discharge was first identified and the duration of the discharge.
Event Start Date & Time:41312023 at 8:20 AM
Event Duration: 19.13 hours
60.108a(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 ve location in the flare inlet.
24-Hour Period Average
Measured Total Sulfur
3414.9
60.108a(c)(6)(v) For each discharge greater than 500lbs SOz in excess of the applicable short-term emissions limit in
$60102a(gXl) 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
in $60.107a(eX4).
HF Sinclair Woods Cross Refining LLC
1070 W 500 S. West Bountiful. UT 84087
801 -299-6600 | HFSinclair.com
60. l08a(cX6)(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 ofgas discharged to the flare over the discharge duratiou. 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 altemative moni in S60.107
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
Flare (FGRU
online)
2,293,391 N/A N/A
Not applicable to this event.
60.108a(cX6) (vi) For each discharge greater than 500lbs SOz in excess of the allowable limits from a sulfur
either the measured concentration of reduced sulfur or SOz discharged to the al
Not applicable to this event.
60. l08a(cX6) (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 sulflr
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 sulfrr to SOz For fuel gas combustion devices,
assume 99-percent conversion of HzS to SOu.
Affected Facility Cumulative Quantity of HzS
Released over Emission
Limit (oounds)
Cumulative Quantity of
SOz Released Over
Emission Limit(pounds)
Interconnected
Flares (FGRU
online)
I 1.09 lbs 1,098.00 lbs
60. l08a(cX6) (viii) The steps that the owner or operator took to limit the emissions during the dischar
In order to minimize emissions, Operations worked to safely restart and line out units immediately after the outage,
per startup procedures.
Affected Facility(s): Interconnected Flare
Date of Discharge: 41312023
Duration of Discharge: 19. I 3 hours
ROOT CAUSE ANALYSIS
o The power supply to the majority of the plant was intemrpted after an off-site substation, operated by
Rocky Mountain Power, faulted. Per Rocky Mountain Power, heavy snow dislodged from lines at the
Parrish substation. The bouncing lines contacted, resulting in a fault that cascaded through the substation's
re-closers.
CORRECTIVE ACTION ANALYSIS
r 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 $ 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 ofthe
recommended corrective action(s) or an ion of whv corrective action is not under 6 60.103a(e
60. I 08a(cX6) (x) For any corrective action analysis for which corrective actions are required in $ 60. I 03a(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 i ion, incl commencement and completion dates.
T-
i
;
CorrcctivcActim Actiong
Corylaed
within45 davs
koposcd Suirt
Datc
Corylaion
Datc
N/A N/A N/A N/A
o N/A
t tAll DEPASTMENT OF
arvrnouenret- ot.lAtJTY
i
AUG - 3 2023
DMSION OF:IUR AUAUTY