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HomeMy WebLinkAboutDAQ-2025-000077,.dttF$nctor September 8,2022 Mr. Bryce Bird, Director Division of Air Quality Utah Dept. of Environmental Quality 195 North 1950 West salt Lake city, utah 84116 UT,4.I-.I DET.,'' IiTMENT CF El'iVi,,Ci ri,,ENTAL QUqlt i v sEp .I3 zfl:l: DIVISTON OF AIR QUALITY Certified Mail: 7019 1120 0000 0070 8248 RE:NESHAP Subpart UUU - Operation, Maintenance, and Monitoring Plan - Request for Review and Approva! Director Bird: ln accordance with 40 CFR 63.1574(fX1), HollyFrontier Woods Cross Refining LLC is submitting for review and approval an updated copy of their Operation, Maintenance, and Monitoring Plan (oMMP). HollyFrontier Woods Cross Refining LLC has updated their OMMP to include continuous monitoring systems that have been replaced, along with updates to established operating limits, and genera! information. Attached is a hard copy of the OMMP. lf you have any questions or need additiona! information, please call me at (801) 299-6658 or by email at Richmond.Thornley@HFSinclair.com Richmond Thornley Environmental Engineer E. Benson (r) File 2.L.L.2 HollyFrontier Woods Cross Refining LLC 1070 W. 500 S, West Bountiful, UT 84087 801-299-6600 | HFSinclair.com c: REVIEWEDInitials: Date: Jan 8, 2025Compliance Status: OKFile #: 10123 (B2) EP 2.13 Woods Cross Refinery Environmental Procedures Page I ofll Operation, Maintenance, and Monitoring Plans Revision:No.3.04 Date: Septernber 2022 Next Scheduled Revision: June 2025 Purpose The purposes of this document are to:l. Ensure that equipment that emits Hazardous Air Pollutants (HAPs) and associated air pollution monitoring systems are operated in compliance with standards. 2. Detail the operation, maintenance, and monitoring procedures that should be followed to comply with those standards. UT4 I] IIEP,I'NTMENI OI. personnel Effected E['i'i i '-,,'")''i::lrirAl ouALlrY 'l: ,, ni OperationsMaintenance DIVISION OF AIR QUALTTY Shift Supervisor Environmental Procedure/Policy Operation, Maintenance, and Monitoring Plans (OMMP) are required for control systerns and continuous monitoring systerns for each affected source per 40 CFR Part 63.1574(D. Affected Sources ProcesVContol Device CMS/CEMS/CPMS Catalyic Cracking Unit, CCU (Unit 4)4Y82 - Wet Gas Scrubber (WGS) WGS Vent CEMS (CO) WGS Vent CPMS ( Flow, Filter module pressure differential, Filter module recycle pump discharge oressure) Catalytic Cracking Unit, CCU (Unit 25)25FCC Scrubber - Wet Gas Scrubber (WGS) WGS Vent CEMS (CO) WGS Vent CPMS ( Flow, Filter module pressure differential, L/G) Catalytic Reforming Unit, CRU (Unit 6)Intemal Caustic Scrubbins Svstem Colorimeric Sampling Sulfur Recovery Unit, SRUr SRU Incinerator WGS (4V82 or 25FCC Scrubber) SOz SRU offgas is required to be routed to 4Y82 FCC Scrubber (WGS) or 25FCC Scrubber (WGS) at all times (AO# DAQE-ANl 0 1230053-22 Condition ILB. t0.b) o OMMP Procedures Whenever this equipment is started up or shut down, or when it malfunctions, documented operating procedures should be followed (See EP 2.04 - Startup, Shutdown, and Malfunction Plan). Normal emissions and monitoring standards are to be followed at all times. This environmental procedure is maintained online. If printed, it should be considered current as of September 8,2022 only. EP 2.t3 Woods Cross Refinery Environmental Procedures Page2of11 Operation, Maintenance, and Monitoring Plans Revision:No.3.04 Date: September 2022 Next Scheduled Revision: June 2025 Catalytic Crackins Units o Process and control device parameters to be monitored for each FCCU, along with establi shed operating limits (63 . I 57 4(f)(2xi)). Source Limit Option Process/Control Monitored Parameters Established Operating Limits CCU Unit 4 Option I under 40 CFR 63. I 56a(a)(l )(i), comply with the 1.0 lb per 1000 lbs of coke burn-off limit. Also subject to AO# DAQE- AN101230053-22 and CD (Consent Decree) limit of 0.50 lb per 1000 lbs coke burn-off limit. AMP,40 CFR 105(a)(l), and 40 CFR 63.1 57 2(c), Continuous parameter monitoring system (CPMS) to measure and record the pressure differential across the filtering modules, and the pressure at the filtering modules pump discharge. Option I under 40 CFR I 565(b)(l ), Continuous emission monitoring system (CEMS) to measure and record tle concentration by volume (dry basis) of the CO emissions from each catalyst regenerator vent. Option I under 40 CFR 1565(a)(1)(i), comply with the NSPS requirements of 500 ppm (dry basis) CO hourly average emission limit. WGS 4V82 Inorganic HAP (PM)< 0.51b/1000 lb coke burned Flow Rate None Filter Module Pressure Differential 2 14.5 inches HzO2l- hour averase Filter Modules Pump Discharge Pressure > 82.4 psig2 l-hour average CO < 500 ppm l-hour average This environmental procedure is maintained online. Ifprinted, it should be considered current as of September 8,2022 only. EP 2.13 Woods Cross Refinery Environmental Procedures Page3of11 Operation, Maintenance, and Monitoring Plans Revision:No.3.04 Date: September2022 Next Scheduled Revision: June 2025 Unit 25 Option I under 40 CFR 63. I 564(a)(l)(ii), comply with the 0.5 lb per 1000 lbs ofcoke burn-off limit. 40 CFR 60. l02a(c)(2)(i- ii) Continuous parameter monitoring system (CPMS) to measure and record the pressure differential across the filtering modules, and the liquid to gas ratio to determine the respective 3-hour rolling averages. WGS 25FCC Scrubber Inorganic HAP (PM) < 0.50 lb/1000 lb coke burned (filterable) < 0.60 lb/I000 lb coke burned (filterable + condensable) 2 12.9 inches H2O3- < O.I9 GPMA{SCFH < 500 ppm l-hour 2fCCUt is subject to approved AMP for opacity compliance, these parameters are monitored continuously, with stack testing every 3 years to determine compliance with the PM limit. o Procedures for monitoring emissions and process and control device operating parirmeters for each affected source (63.1574(f)(2xii). o Procedures to determine the coke burn-rate, the volumetric flow rate (if process data rather than direct measurement is used), and the rate of combustion of liquid or solid fossil fuels if an incinerator-waste heat boiler to burn the exhaust gases from the catalyst regenerator is used (63 .l 57 4(f)(2xiii)). Source Parameters Monitorins Procedures CCU Unit 4 Flow Rate Continuous monitor on WGS outlet (4FI-1419) Filter Module Pressure Differential Continuous monitor on WGS filter modules (4PDI-1660) Filter Modules Pump Discharge Pressure Continuous monitor on WGS circulation pump outlet (4PI- 1658) CO Continuous monitor on WGS outlet (4AI-l3l3A) Oz Continuous monitor on WGS outlet (4AI-l3l3C) COz Continuous monitor on WGS outlet (4AI-3032) Unit 25 Flow Rate Continuous monitor on WGS outlet (25FI-4305) Filter Module Pressure Differential Continuous monitor on WGS filter modules (25PDI-6301) Liquid to Gas Ratio Continuous monitor on WGS circulation pump outlet and WGS outlet (Calculated from 25FI-4381 and 25FI-4305) CO Continuous monitor on WGS outlet (25AI-3312) Oz Continuous monitor on WGS outlet (25AI-3314) COz Continuous monitor on WGS outlet (25AI-3018) Thisenvironmentalprocedureismaintainedonline. Ifprinted,itshouldbeconsideredcurrentasofSepternberS,2022only. EP 2.r3 Woods Cross Refinery Environmental Procedures Page4of1l Operation, Maintenance, and Monitoring Plans Revision:No.3.04 Date: September 2022 Next Scheduled Revision: Jlune2025 The procedures used to determine coke burn rate for compliance purposes follow the procedures in 40 CFR 63.1564 and according to the equation listed below. The volumetric flow rate is determined with a direct measurement device on the outlet of each WGS. 4 = r,A(o cox+%co)+ KtSo- KrQ,lVoca4+Yocot+yooi+ KtSrylno*) (Eq t) where: R": Coke burn-offrate, lb/hr; Q.: Volumetric flow rate of exhaust gas from catalyst regenerator before adding air or gas streams, dscf/min. Q": Volumetric flow rate of air to catalytic cracking unit catalyst regenerator, as determined from instruments in the central control room, dscflmin; o/oCOz = Carbon dioxide concentration in regenerator exhaust, percent by volume (dry basis); %CO: Carbon monoxide concentration in regenerator exhaust, percent by volume (dry basis); o/oOz: Oxygen concentration in regenerator exhaust, percent by volume (dry basis); Kr : Material balance and conversion factor, 0.0186 (lb-min)/(hr-dscf-%); Kz: Material balance and conversion factor, 0.1303 (lb-min)/(hr-dscf); Kr : Material balance and conversion factor, 0.0062 (lb-min)/(hr-dscf-%); Qo*y: Volumetric flow rate of oxygen-enriched air stream to regenerator, as determined from instruments in the catalytic cracking unit control room, dscflmin YoO*y: Oxygen concentration in oxygen-enriched air stream, percent by volume (dry basis) o Procedures and analytical methods to determine the equilibrium catalyst Ni concentration, the equilibrium catalyst Ni concentration monthly rolling average, and the hourly or hourly average Ni operating value (63.1574(f)(2Xiv)). This requirement is not applicable. o Procedures to determine the pH of the water (or scrubbing liquid) exiting a wet scrubber if you use pH strips. (63.1574(I)(2)(v)). This requirement is not applicable, pH strips are not used. This environmental procedure is maintained online. If printed, it should be considered current as of September 8,2022 only. EP 2.13 Woods Cross Refinery Environmental Procedures Page5of1l Operation, Maintenance, and Monitoring Plans Revision:No.3.04 Date: September 2022 Next Scheduled Revision: h:ne2025 o Procedures to determine the gas flow rate for a catalytic cracking unit if using the alternative procedure based on air flow rate and temperature (63.157a(f(2)(vii)). The alternative procedures cannot be employed because a WGS is used. o Monitoring schedule, including when each affected source is or is not monitored (e.g., during the coke burn-off, regeneration process) (63 .1 57 4(f)(2)(viii). o Quality control plan for each continuous parameter monitoring system and continuous emission monitoring system used to meet an emission limit. This plan includes procedures for calibrations, accuracy audits, and adjustments to the system needed to meet applicable requirements for the systern (63.1574(f)(2)(ix)). The temperature, pressure, carbon monoxide, and oxygen monitors on the two CCUs are parametric monitoring systems. The CEMS comply with the procedures for calibrations, accuracy audits, and adjustments specified by 40 CFR Part 60 Appendix B, Specification 1-4 and manufacturers recommendations. The CEMS QA/QC Plan maintained by the Source Parameters Monitorine Schedule CCU Unit 4 Flow Rate Continuous monitor on WGS outlet (4FI-1419) when CCU and WGS are operatins Filter Module Pressure Differential Continuous monitor on WGS filter modules (4PDI-1660) when CCU and WGS are ooeratins Filter Modules Pump Discharge Pressure Continuous monitor on WGS circulation pump outlet (4PI- 1658) when CCU and WGS are operatins CO Continuous monitor on WGS outlet (4AI-1313) when CCU and WGS are operating Oz Continuous monitor on WGS outlet (4AI-l3l3C) when CCU and WGS are ooeratins COz Continuous monitor on WGS outlet (4AI-3032) when CCU and WGS are ooeratins Unit 25 Flow Rate Continuous monitor on WGS outlet (25FI-4305) when CCU and WGS are operatins Filter Module Pressure Differential Continuous monitor on WGS filter modules (25PDI-6301) when CCU and WGS are ooeratins Liquid to Gas Ratio Continuous monitor on WGS circulation pump outlet and WGS outlet (Calculated from 25FI-4381 and 25FI-4305) when CCU and WGS are ooeratine CO Continuous monitor on WGS outlet (25AI-3312) when CCU and WGS are operatins Oz Continuous monitor on WGS outlet (25AI-3314) when CCU and WGS are ooeratins COz Continuous monitor on WGS outlet (25AI-3018) when CCU and WGS are ooeratine This environmental procedure is maintained online. If printed, it should be considered current as of September 8,2022 only. EP 2,13 Woods Cross Relinery Environmental Procedures Page6ofll Operation, Maintenance, and Monitoring Plans Revision:No.3.04 Date: September 2022 Next Scheduled Revision: June 2025 Environmental Department contains these procedures. In addition, procedures related to calibrations, and adjustments are maintained and recorded by the I/E group. o Maintenance schedule for each affected source, monitoring system, and control device that is generally consistent with the manufacturer's instructions for routine and long-term maintenanc e (63 .l 57 4(0(2)(x)). If you use a fixed-bed gas-solid adsorption systern to control emissions from a catalytic reforming unit, you must implement corrective action procedures if the HCI concentration measured at the selected compliance monitoring sampling location within the bed exceeds the operating limit. These procedures must require, at minimum, repeat measurement and recording of the HCI concentration in the adsorption system exhaust gases and at the selected compliance monitoring sampling location within the bed. If the HCI concentration at the selected compliance monitoring location within the bed is above the operating limit during the repeat measurement while the HCI concentration in the adsorption system exhaust gases remains below the operating limit, the adsorption bed must be replaced as soon as practicable. Your procedures must specify the sampling frequency that will be used to monitor the HCI concentration in the adsorption system exhaust gases subsequent to the repeat measurement and prior to replacement of the sorbent material (but not less frequent than once every 4 hours during coke bum-off). If the HCI concentration of the adsorption system exhaust gases is above the operating limit when measured at arry time, the adsorption bed must be replaced within 24 hours or before the next regeneration cycle, whichever is longer (63.1574(f)(2)(xi)). This requirement is not applicable, this only applies to CRU's. Procedures that will be used for purging the catalyst if you do not use a control device to comply with the organic HAP emission limits for catalytic reforming units. These procedures will include, but are not limited to, specification of the minimum catalyst temperature and the minimum cumulative volume of gas per mass of catalyst used for Maintenance Procedure Schedule Source CCU Turnaround Every 5 years and as scheduled by the Turnaround srouo Control Devices WGS Tumaround Every 5 years and as scheduled by the Turnaround srouo Monitoring Systems WGS Vent Flow CPMS The procedures for monitoring devices are overseen by WGS Filter Module Pressure Differential CPMS WGS Filter Modules Pump Discharge Pressure CPMS the assigned Environmental SME, and are maintained, performed, and recorded by the I/E group. WGS Vent CO, COz, SOz, and Oz CEMs Thisenvironmentalprocedureismaintainedonline. Ifprinted,itshouldbeconsideredcurrentasofSeptemberS,2022only. EP 2.t3 Woods Cross Refinery Environmental Procedures Page7ofl1 Operation, Maintenance, and Monitoring Plans Revision:No.3.04 Date: Septernber2022 Next Scheduled Revision: June 2025 purgng prior to uncontrolled releases (i.e., during conholled purglng events); the maximum purge gas temperature for uncontrolled purge events; and specification of the monitoring systems that will be used to monitor and record data during each purge event (63 .t s7 4(f)(2)(xii)). This requirement is not applicable, this applies only to CRU's. Catalytic Reformine Unit o Process and control device parameters to be monitored for the CRU, along with establi shed op eratin g limits (63 . I 57 4(f)(2 Xi )). o Procedures for monitoring emissions and process and control device operating parameters for each affected source (63.1574(f)(2)(ii). Source Limit Option Process/Contol Device Monitored Parameters Established Operating Limits CRU Option I under 40 CFR 63.1566(a)(l), vent emissions to a flare during initial catalyst deoressurins. North and South Flares Presence of flame in flare Present Absence of visible emissions from flare VE<5min.in2hours Under 40 CFR 1567(a)(l), reduce HCI emissions to 30 ppmv dry, corrected to 3olo oxvsen. lnternal Caustic Scrubbing System HCI concentration 27 ppmby colormetric tubes Source Limit Option Process/Control Device Monitored Parameters Monitoring Procedure CRU Option I under 63.1566OX1), vent emissions to a flare during initial catalyst depressuring, and monitor for pilot flame. North and South Flares Presence of flame in flare Continuous IR monitor on flare pilots (66A1-3117 and 66AI-3118) Absence of visible emissions from flare Method 22 observation if visible emissions occur during purging Under 40 CFR 1567(b)(l), use colormetric tube sampling to monitor HCI emissions durins coke burn-off. Internal Caustic Scrubbing System HCI concentration Colormetric tube samples every 4 hours during coke burn-of?catalyst regeneration This environmental procedure is maintained online. Ifprinted, it should be considered current as ofSepternber S,2022 only. EP 2.13 Woods Cross Refinery Environmental Procedures Page8ofll Operation, Maintenance, and Monitoring Plans Revision:No.3.04 Date: Septernber2022 Next Scheduled Revision: lune2025 o 63.1574(I)(2xiii) through 63.1574(f)(2)(v) are not applicable to the CRU, these are only applicable to CCU's. o Procedures to determine the HCI concentration of gases from the semi-regenerative CRU with an intemal scrubbing system (i.e., no add-on control device) when using a colormetric tube sampling systern, including procedures for correcting for pressure (if applicable to the sampling equipment) (63 .l 57 4(f)(2)(vi)).. Colormetric tube samples are taken every 4 hours, unless it appears that the coke bum steps will be completed in less than 12 hours, in which case times are adjusted to ensure that at least 4 samples are taken. Samples are taken at the vent stack of the separator. o 63.1574(f)(2)(vii) is not applicable to the CRU, this only applies to CCU's. o Monitoring schedule, including when each affected source is or is not monitored (e.g., during the coke burn-off, regeneration process) (63 .l 57 4(D(2)(viii)). o 63.1574(f)(2)(ix) is not applicable to the CRU, the CRU does not have COMS/CEMS. o Maintenance schedule for each affected source, monitoring system, and control device that is generally consistent with the manufacturer's instructions for routine and long-term maintenanc e (63 .l 57 4(0(2Xx)). Source Limit Option ProcesVControl Device Monitored Parameters Monitoring Schedule CRU Option I under 63.1566(b)(1), vent emissions to a flare during initial catalyst depressuring, and monitor for pilot flame. North and South Flares Presence of flame in flare Continuously monitor flare pilot (66AI-31 17 and 664I-31 l8) during deoressurins and oursins Absence of visible emissions from flare Continuously during depressuring and oursins Under40 CFR 1567(b)(l), use colormetric tube sampling to monitor HCI emissions during coke burn-off. Internal Caustic Scrubbing System HCI concentration Colormetric tube samples every 4 hours during coke burn-offlcatalyst regeneration This environmental procedure is maintained online. Ifprinted, it should be considered current as of Septonber 8,2022 only. EP 2.13 Woods Cross Refinery Environmentd Procedures Page9ofll Operation, Maintenance, and Monitoring Plans Revision:No.3.04 Date: September2022 Next Scheduled Revision: June 2025 Maintenance Procedure Schedule Source CRU Turnaround Every 5 years and as scheduled by the Turnaround erouo Regeneration Every 12 to l8 months and as scheduled by the Turnaround eroup Control Devices Internal Caustic Scrubbing Svstem Inspection At regeneration North and South Flares Inspection Every 5 years and as scheduled by the Turnaround group Monitoring Systems Flare Pilot Monitor Inspection Regular maintenance according to manufacturer soecifications. o 63.1574(I)(2)(xi) and 63.1574(f(2)(xii) do not apply to the CRU. Sulfur Recover.v Unit o Process and control device parameters to be monitored for the SRU, along with established operating limits (63 .l 57 4(f)(2xi)). SRU off gas is required to be routed to 4V82 FCC Scrubber (WGS) or 25FCC Scrubber (WGS) at all times (AO# DAQE-ANI 0 12300 53 -22 Condition II.B. I 0.b) o Procedures for monitoring ernissions and process and control device operating parameters for each affected source (63.1574(f)(2xii)). Source LimitOption Process/Contol Device Monitored Parameters Established Operating Limits SRUI Subject to 40 CFR 60 Subpart Ja. Complies with40 CFR 60.102a(bX3) for FCC SOz emissions due to SRU off gas being routed to FCC wet gas scrubber. WGS (4V82 or 25FCC Scrubber)SOz 25 ppmv dry (0% excess air) 365-day rollins averase 50 ppmv dry (0% excess air) 7-day rolling average This environmental procedure is maintained online. If printed, it should be considered current as of Septonber 8,2022 only. EP 2.13 Woods Cross Refinery Environmental Procedures Page l0 of I 1 Operation, Maintenance, and Monitoring Plans Revision:No.3.04 Date: Septernber 2022 Next Scheduled Revision: June 2025 Source ProcesVControl Device Monitored Pararneters Monitoring Procedures SRUI WGS (4V82 or 25FCC Scrubber)SOz Continuous monitor on WGS outlet (4AI-1313 and 25Ar-33 l3) SRU off gas is required to be routed to 4V82 FCC Scrubber (WGS) or 25FCC Scrubber (WGS) at all times (AO# DAQE-ANl0 1230053-22 Condition II.B. l0.b) o 63.1574(f)(2)(iii) through 63.1574(f)(2)(vii) are not applicable to the SRU. These requirements are only applicable to CCU's and CRU's. o Monitoring schedule, including when each affected source is or is not monitored (e.g., during the coke burn-off, regeneration process) (63 .l 57 4(D(2)(viii)). I SRU off gas is required to be routed to 4Y82 FCC Scrubber (WGS) or 25FCC Scrubber (WGS) at all times (AO# DAQE-ANI01230053-22 Condition II.B. I 0.b) o Quality control plan for each continuous parameter monitoring system and continuous ernission monitoring system used to meet an emission limit. This plan includes procedures for calibrations, accuracy audits, and adjustrnents to the system needed to meet applicable requirements for the syston (63.1574(f)(2Xix)). The CEMS (SOz) will comply with the procedures for calibrations, accuracy audits, and adjustments specified by 40 CFR Part 60 Appendix B, Specification l-4 and manufacturers recommendations. The CEMS QA/QC Plan maintained by the Environmental Department contains these procedures. In addition, procedures related to calibrations, and adjustments are maintained and recorded by the VE group. o Maintenance schedule for each affected source, monitoring system, and control device that is generally consistent with the manufacturer's instructions for routine and long-term maintenanc e (63 .l 57 4(f)(2)(x)). Source ProcesVContol Device Monitored Parameters Monitoring Schedule SRUI WGS (4V82 or 25FCC Scrubber)SOz Continuous monitor on WGS outlet (4AI-1313 and 25AI-3313) while SRU is operatins Thisenvironmentalprocedureismaintainedonline. Ifprinted,itshouldbeconsideredcurrentasofSepternberS,2022only. EP 2.13 Woods Cross Refinery Environmental Procedures Page ll of11 Operation, Maintenance, and Monitoring Plans Revision:No.3.04 Date: Septernber2022 Next Scheduled Revision: June 2025 Maintenance Procedure Schedule Source SRU Turnaround Every 3 years and as scheduled by the Turnaround srouD: or Waste Heat Boiler inspection every 3 years and as scheduled by the Insnections srouo. Control Devices WGS Turnaround Every 5 years and as scheduled by the Turnaround group. Monitoring Systems WGS Vent SOz CEMS The procedures for monitoring devices are overseen by the assigned Environmental SME, and are maintained, performed, and recorded by the I/E group. o 63.1574(f)(2Xxi) and 63.1574(f(2)(xii) are not applicable to the SRU; these requirements only apply to CRU's. Supplemental Information 40 CFR 63 Subpart A - General Provisions 40 CFR 63 Subpart CC - National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries 40 CFR 63 Subpart UUU - National Emission Standards for Hazardous Air Pollutants for Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units 40 CFR 60 Subpart Ja - Standards of Performance for Petroleum Refineries for which Construction, Reconstruction, or Modification Commenced After May 14,2007 40 CFR 60 Appendix B, F - Performance Specifications and Quality Assurance Procedures UTAH DEPARfMENToF DIVISION OFAIR QUALITY This environmental procedure is maintained online. Ifprinted, it should be considered current as of Septernber 8,2022 only.