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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 ENVt*-I I I I I t_. DIVI AH ,.tttF$nclor ivl8l A 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$t 45 days following the discharge and, for action(s) a schedule for i commencement and cormletion dates.not Corrective Action Actions Completed within 45 davs Proposed Start Date Completion Date N/A N/A N/A N/A ,.tttF$nctor 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