Loading...
HomeMy WebLinkAboutDAQ-2025-000293,,tttF$nctorr July 31,2024 Mr. Bryce Bird, Director Division of Air Quality Utah Department of Environmental Quality 195 North 1950 West salt Lake city, Utah 84116 UIAI.1 DT.PARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR OUAI ITY Certified Mail: 7022 0410 0002 3551 6455 RE:40 CFR Part 60, Subpart Ja Periodic Report January I through June 30, 2024 Dear Mr. Bird: Pursuant to 40 CFR 60 NSPS Subparl 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(c)(6). 40 CFR I 08a(c)(6) 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-hour period. These records are to be included in periodic excess emissions reports pursuant to 40 CFR 60.108a(dX5). For the period of January I , 2024 through June 30, 2024 the records maintained include the following: 60.108(c)(6)Discharge greater than 500 lbs SOz (24-hr 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 reportins period. Discharge in excess of 500,000 scf above baseline (24-fu oeriod) Affected Flare: 1 discharge, RCA 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 dated413012024 and712512024. 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 REVIEWEDInitials:Date: Jan 7, 2025 Compliance Status: OK File # 10123 (B2) Sincerely, Vice President and Refinery Manager Attachments cc: E. Benson (r) File 2.2.7.2 Attachment A- 60.10Ea(cXO - Root Cause Analysis (RCAs) ,.tttFfinctarr DATE: 612612024 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow and SOz from Flares per 60.103a(c)( I ) 60.108a(cX6Xi) A of the A 5,000 volt feeder in Substation 3 faulted, tripping its breaker relay. The ground fault pressure caused other breakers in the substation to trip, as well. The loss of power from the trips resulted in multiple units entering a state ofupset. Offgases from upset units relieved to the flare header system, causing an exceedance ofthe Interconnected flare flow limit and SOz limit. 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the Event Start Date & Time: 511312024 at 12:23 AM Event Duration: 55.50 hours 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 *re 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 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) 5,515,927 511312024 00:23 - 511412024 00:22 3,837,650 511412024 00:23 - 5ll5/2024 00:22 1,394,944 5l15/2024 00:23 - 5lt5/2024 07:53 283,333 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 at a representative location in the flare inlet. 24-Hour Period Average Measured Total Sulfur 1403.694 HF Sinclair Woods Cross Refining LLC 1070 W. 500 S, West Bountiful, UT 84087 801-299-6600 | HFSinclair.com 60. l08a(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 ded in $60.107a(e\(4\. Not applicable to this event. 60. 108a(c)(6) (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 Not applicable to this event. 60. l08a(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 aEnosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to SOz. For fuel gas combustion devices, assume 99 conversion of HzS to SOz. Affected Facility Cumulative Quantity of HzS Released over Emission Limit (oounds) Cumulative Quantity of SOu Released Over Emission Limit(oounds) Interconnected Flares (FGRU online) 29.96lbs 2,346.00 lbs 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the disc In order to minimize emissions, Maintenance worked to restore power and Operations worked to safely restart and line out units, per startup procedures. 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 explanation of why corrective action is not under $ 60.103a(e). Affected Facility(s): Interconnected Flares Date of Discharge: 5 I 13 12024 Duration of Discharge: 55.50 hours ROOT CAUSE ANALYSIS The initiating event was a splice failure on an abandoned cable being fed from section three of the station's switchgear. Although the cable was abandoned, its circuit breaker was not locked out, and it is believed that it was re-energized during the last substation preventative maintenance cycle. When that energized cable faulted, it tripped multiple breakers, causing power disruptions to multiple process units. These upset units relieved off gases to the flare headers, which resulted in exceedances of the Interconnected flare flow and SOz limits. CORRECTIVE ACTION ANALYSIS o Air gap and ground faulted feeder line to Substation 3. This incident did not result from the same root cause as previous events investigated per this rule. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are requked 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) , a schedule for implementation, includi cornmencement and comoletion dates.not Corrective Action Actions Completed within 45 days Proposed Start Date Completion Date Air gap and ground faulted feeder line to Substation 3.Yes 511312024 5n3t2024 60. 108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a 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 m o Not applicable to this event. UTn H Dt:PARI It4l-NT OF ENVIRONIIENTAL. QIJALITY t-___---__--r')rt)t ;Ii DIVISION OF AiR OI.'AI ITY