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HomeMy WebLinkAboutDAQ-2025-000295TMENT OF ENVIRONMENTAL OUALITY ,.dttF&nctor July 30,2024 Mr. Bryce Bird, Director Division of Air Quality Utah Dept. of Environmental Quality 195 North 1950 West Salt Lake City, Utah 84114 Director, Air and Toxics Division U.S. EPA Region Vlll 1595 Wynkoop St. Denver, CO 802O2-1L29 CERTIFIED MAIL: 7022 0410 0002 3551 5847 CERTIFIED MAIL: 7022 0410 0002 3551 5854 40 cFR Part 63, Subparts CC, UUU, ZZZ.and DDDDD Periodic Report January 1 through June 30, 2024 Dear Director: The following is a periodic report covering the requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Petroleum Refineries (40 CFR 53 Subpart CC), the NESHAp for Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units (40 CFR 53 Subpart UUU), the NESHAP for Stationary Reciprocating lnternal Combustion Engines (40 CFR 63 Subpart ZZZZI,lhe NESHAP for lndustrial, Commercial, and lnstitutionalBoilers and process Heaters (40 CFR 63 Subpart DDDDD), and the Consent Decree by HF Sinclair Woods Cross Refining LLC (HFSWCR). This report covers those requirements outlined in 40 CFR sections 60.487(c) (as required by G3.655(d)), 63.655(eX1-L4), 63.L57i(c-h), 63.5650(c)(1-6), 63.7550 (cX1-11), and paragraph 136 of the Consent Decree (CD) entered July 2,2008 between the EPA, State of Utah, and Holly Refining & Marketing Company. No new types of fuel were burned during this period. lf you have any questions or need additional information, please contact Richmond Thornley by email at Richmond.Thornlev(oHFSinclair.com or by phone at (g01) 299-6G59. I certify that, based upon inquiry of personnel involved, the statements and information contained in this report are truthful, accurate, and complete. Sincerelv. T;-""1^-S.^^-- J- Dustin Simmonds Vice President and Refinery Manager Attachments cc: E. Benson (r) File 2.2.6.1 HF Sinclair Woods Cross Refining LLC 1070 W 500 S, West Bountiful, UT 84087 801 -299-6600 | HFSinclair.com AUG - 5 2024 DIVISION OF AIR OIJALITY RE: REVIEWEDInitials: Date: Jan 7, 2025Compliance Status: OKFile # 10123 (B2) Subpart CC Wastewater Provisions 63.6s5{a}Each owner or operator subject to the wastewater provisions in g 63.647 shall comply with the recordkeeping and reporting provisions in 55 61.356 and 6L.357 of 40 CFR part 51, subpart FF unless they are complying with the wastewater provisions specified in paragraph (oX2Xii)of 5 63.640. Not applicable. There are no Group 1 wastewater streams at the HF Sinclair Woods Cross Refining LLC petroleum refinery. Periodic measurement of benzene is performed as required under subpart FF of 40 CFR 61. 63.547(c)lf a flare is used that complies with the requirements in 553.670, include the items specified in $63.655(sX11). This requirement is not applicable, as a flare (as defined at 563.641) is not used as a control device for wastewater streams and treatment operations. Gasoline Loading Rack Provisions 63.6ss(b)Each owner or operator subject to the gasoline loading rack provisions in $ 63.650 shall comply with the recordkeeping and reporting provisions in g 63.428 (b)and (c), (gX1), (hX1) through (hX3), and (k) ofsubpart R. Not applicable. There are no gasoline loading racks classified under Standard Industrial Classification code 2911 located within a contiguous area under common controlwith HF Sinclair Woods Cross Refining LLC petroleum refinery. Marine Tank Vessel Provisions 63.655{c)Each owner or operator subject to the marine tank vessel loading operation standards in 5 53.651 shall comply with the recordkeeping and reporting provisions in 55 63.567(a)and 63.567(c) through (k) of subpart Y. Not applicable. There are no marine tank vessel loading operations at the HF Sinclair Woods Cross Refining LLC petroleum refinery. Equipment Leaks Provisions 63.5ss(d)Each owner or operator subject to the equipment leaks standards in 5 63.648 shall comply with the recordkeeping and reporting provisions in paragraphs (dX1) through (dX6) of this section. Facility complies with 40 CFR part 50 Subpart GGGa per the overlap provision of 63.640(p)(2) for all components. Quarterly leak reports per sections 60.486a and 60.487a of Subpart VVa, are completed under separate reports submitted April 15, 2024 and July 15, 2024. See section 63.655(g) below for additional PRD information. NOCS Requirements 63.6ss(f)Each owner or operator of a source subject to this subpart shall submit a Notification of Compliance Status report within 150 days after the compliance dates specified in 5 63.640(h) with the exception of Notification of Compliance Status reports submitted to comply with 5 63.640(lX3) and for storage vessels subject to the compliance schedule specified in g 53.640(hX2). N/A - No updates to Storage Vessel NOCS. Periodic Report Requ i rements 63.5ss(el The owner or operator of a source subject to this subpart shall submit Periodic Reports no later than 60 days after the end of each 6 - month period when any of the information specified in paragraphs (CX1)through (7) of this section or paragraphs (g)(9) throueh (la) of this section is collected. See sections 53.655 (eX1-14) below. Storage Vessels 63.5ss(fX6)Group l emission points (Storage vessels) No Group l emission points added du ring reporting period. 63.5ss(eXl)For storage vessels, Periodic Reports shall include the information specified for Periodic Reports in paragraphs (g)(2) through (s) of this section. See sections below. For inspection data see Attachment C. 63.6ss(gX2Xiil(Al-( Bl IFR: An owner or operator who elects to comply with 5 63.560 by using a fixed roof and an internal floating roof shall submit the results of each inspection conducted in accordance with S 63.1063(cX1), (d)(1), and (dX2) of subpart WW in which a failure is detected in the control equipment. For each failure, include the inspection date, identification of each storage vessel in which a failure was detected, and a description of the failure. Also describe the nature and date of the repair or the date the storage vessel was emptied. See Table 1 - Tank lnspections Summary 63.6ss(eX2XiiXcl IFR: lf an extension is utilized in accordance with 563. 1063(eX2) of Subpart WW, submit the documentation required by 563.1063(eX2). See Table 1 - Tank lnspections Summary 63.6ss(gX3Xii)EFR: An owner or operator who elects to comply with 5 63.550 by using an external floating roof shall meet the periodic reporting requirements specified in paragraphs (gxgXii)(a) and (B) of this section. See Table 1 - Tank lnspections Summary 63.6ss{eX3XiiXB)EFR: lf an extension is utilized in accordance with 953.1063(eX2) or (cXzXivXB) of Subpart WW, submit the requ ired documentation. See Table 1 - Tank lnspections Summary Tanks routed to Closed Vent System o r Control Device 63.6ss(el(s)An owner or operator who elects to comply with 5 63.646 or 5 53.660 by installing a closed vent system and control device shall submit, as part of the next Periodic Report, the information specified in paragraphs (exs[i) through (v) of this section, as applicable. See sections below. 63.655(eX5Xi- ii,iv-v) Tank 118 complies with the requirements of 60.112b(a)(3) and 60.113b(c), 60.115b(c) per 63.6a0(nX2). 53.5ss(gxsXi)The Periodic Report shall include the information specified in paragraphs (eXsXiXaland (B): See sections 63.6s5(g)(sXiXA) & (B)below. 63.6ss(g)(sXiXA)A description of the planned routine maintenance that is anticipated to be performed for the control device during the next 5 months. N/A, no CVS or control devices utilized. 63.6ss(el(sXiXB)A description of the planned routine maintenance that was performed for the control device during the previous 5 months. N/A, no planned routine maintenance during this reporting period. 53.6ss(g)(s)(ii)lf a control device other than a flare is used, the Periodic Report shall describe each occurrence when the monitored parameters were outside of the parameter ranges documented in the Notification of Compliance Status report. N/A, no control device other than a flare is used. 63.6ss(el{sX.v}lf a flare is used on or after the date for which compliance with the requirements in 5 63.670 is elected, which can be no later than January 30, 2019, the Periodic Report shall include the items specified in paragraph (eXf f ) of this section. N/A, a flare is not used for tank closed vent systems or control devices. 63.6ss{g}(s)(v}lf electing to comply with 563.650 by installing an alternate control device as described in $63.1064 of Subpart WW, submit a written application as described in 553.1056(bX3). N/A, no alternate control devices were utilized during this reporting period. Miscellaneous Process Vents 63.6ss(eX5)For miscellaneous process vents for which continuous parameter monitors are required by this subpart, periods of excess emissions shall be identified in the Periodic Reports and shall be used to determine compliance with the emission standards. See Sections below. 63.655(eX6Xi- iii) 63.6ss(el(51(il Period of excess emission means any of the following conditions : See sections below. 63.5ss(eX6XiXA-D) 63.6ss(cX6l(iXA)An operating day when the daily average value of a monitored parameter, except presence of a flare pilot flame, is outside the range specified in the Notification of Com pliance Status report. There were no instances when miscellaneous process vents' daily average value of a monitored parameter was outside the operating range during this reporting period. 63.6ss(cl(6XiXBl An operating day when all pilot flames of a flare are absent. There were no instances when miscellaneous process vents were routed to the flare while the pilot was out during this reporting period. 63.6ss(el(6XiXcl An operating day when monitoring data required to be recorded in paragraphs (i)(3xi) and (ii) of this section are available for less than 75 percent of the operating hours. There were no instances when monitoring data was available less than75% during this reporting period. 63.6ss(g)(6X.XD)For data compression systems under paragraph (hXsXiii) of this section, an operating day when the monitor operated for less than 75 percent of the operating hours or a day when less than 18 monitoring values were recorded. There were no instances when monitor operated for less than 75% during this reporting period. 63.6ss(g)(6)(ii)For miscellaneous process vents, excess emissions shall be reported for the operating parameters specified in table 10 of this subpart unless other site - specific parameter(s) have been approved by the operating permit authority. There were no instances of excess emissions from miscellaneous process vents during this reporting period. 63.65s(eXsXiiil For periods in closed vent systems when a Group 1 miscellaneous process vent stream was detected in the bypass line or diverted from the control device and either directly to the atmosphere or to a control device that does not comply with the requirements in 5 63.543(a), report the date, time, duration, estimate of the volume of gas, the concentration of organic HAP in the gas and the resulting mass emissions of organic HAp that bypassed the control device. For periods when the flow indicator is not operating, report the date, time, and duration. There were no instances when miscellaneous process vent stream bypassed or diverted from a control device during this reporting period. Performance Test 63.6ss(el(7)lf a performance test for determination of compl iance for a new emission point subject to this subpart or for an emission point that has changed from Group 2 to Group 1 is conducted during the period covered by a Periodic Report, the results of the performance test shall be included in the Periodic Report. N/A, no new emission point subject to this subpart or for an emission point that has changed from Group 2 to Group 1. Quarterly Reports 63.6ss(eX8)The owner or operator of a source shall submit quarterly reports for all emission points included in an emissions average. N/A, the facility does not use emissions averaging. Heat Exchange Systems 53.6ss(gXel For heat exchange systems, Periodic Reports must include the followins information : See sections 63.555(g)(9Xi-v) below. 63.6ss(g)(e)(i)The number of heat exchange systems at the plant site subject to the monitoring requirements in 5 63.654. Six (6) heat exchange systems in HAP service. 63.6ss(gXsX.il The number of heat exchange systems at the plant site found to be leaking. One (1) Heat exchange systems found to be leaking. 63.6ss(eXeXiii)For each monitoring location where the total strippable hydrocarbon concentration was determined to be equal to or greater than the applicable leak definitions specified in 5 63.55a(cX6), identification of the monitoring location (e.9., unique monitoring location or heat exchange system lD number), the measured total strippable hydrocarbon concentration, the date the leak was first identified, and, if applicable, the date the source of the leak was identified; See Table 2 - Heat Exchangers Compliance Summary. 63.5ss(g)(e)(iv)For leaks that were repaired during the reporting period (including delayed repairs), identification of the monitoring location associated with the repaired leak, the total strippable hydrocarbon concentration measured during re - monitoring to verify repair, and the re - monitoring date (i.e., the effective date of repair); and See Table 2 - Heat Exchangers Compliance Summary. 53.6ss(g|(e)(v)For each delayed repair, identification of the monitoring location associated with the leak for which repair is delayed, the date when the delay of repair began, the date the repair is expected to be completed (if the leak is not repaired during the reporting period), the total strippable hydrocarbon concentration and date of each monitoring event conducted on the delayed repair during the reporting period, and an estimate of the potential strippable hydrocarbon emissions over the reporting period associated with the delayed repair. No heat exchanger systems were placed on delayed repair during this reporting period. Pressure Relief Devices 63.6ss(gX10!For pressure relief devices subject to the requirements g 53.648(j), Periodic Reports must include the information specified in paragraphs (CXrO)(i) through (iv) of this section. See sections 63.655(e)(10Xi-iv) below. 63.6ss(gl(101(il For pressure relief devices in organic HAP gas or vapor service, pursuant to $ 63.648UX1), report any instrument reading of 500 ppm or greater. N/A, no instrument readings of 500 ppm or greater during this reporting period 63.6ss(eX10Xi.l For pressure relief devices in organic HAP gas or vapor service subject to $ 63.548UX2), report confirmation that any monitoring required to be done during the reporting period to show compliance was conducted. N/A, no applicable pressure relief device releases during the reporting period. 63.6ss(el(101(ii.)For pilot - operated pressure relief devices in organic HAP service, report each pressure release to the atmosphere through the pilot vent that equals or exceeds 72 pounds of VOC per day, including duration of the pressure release through the pilot vent and estimate of the mass quantity of each organic HAP released. No pressure releases to atmosphere through pilot vent that equals or exceeds 72lbs. VOC per day during this reporting period. 63.5ss(g)(10)(iv)For pressure relief devices in organic HAP service subject to 5 63.548UX3), report each pressure release to the atmosphere, including duration of the pressure release and estimate of the mass quantity of each organic HAP released, and the results of any root cause analysis and corrective action analysis completed during the reporting period, including the corrective actions implemented during the reporting period and, if applicable, the implementation schedule for planned corrective actions to be implemented subsequent to the reporting period. No pressure releases to atmosphere via PRDs subject to 563.648UX3) during this reporting period. Flares 63.6ss(eX1U For flares subject to 5 63.670, Periodic Reports must include the information specified in paragraphs (eXrf )(i) through (iv) of this section. See sections 63.555(e)(11)(i- iv) below. 63.6ss(gX11Xi)Records as specified in paragraph (i[g)(i) of this section for each 15 - minute block during which there was at least one minute when regulated material is routed to a flare and no pilot flame is present. No 15-minute blocks during which there was at least one minute when regulated material was routed to the flare and no pilot flame was present during this reporting period. 63.5ss(eX11l(iil Visible emission records as specified in paragraph (iX9XiiXC) of this section for each period of 2 consecutive hours during which visible emissions exceeded a total of 5 minutes. See Table 3a.1: - Flares: Visible Emissions Summary 63.6ss(gX11l(iiiI The 15 - minute block periods for which the applicable operating limits specified in 5 53.670(d)through (f) are not met. lndicate the date and time for the period, the net heating value operating pa ra meter(s) determined following the methods in 5 63.570(k) through (n) as applicable. See Table 3b: Flares: Combustion Zone NHV Compliance Summary No 15-Minute blocks with Vtip exceedances during this reporting period. NHVdil limit not applicable, flares are not air assisted. 63.6ss(g)(11)(ivl(a)- (c) Report emergency flaring events when the flare operated above the smokeless capacity. lnclude the following information: - Start time, stop time, and duration of the flaring event - The duration for which emissions were visible from the flare during the event - All t5-minute block averages where Vtip > Vmax during flaring event - Maximum Vtip 15-minute block average during the flaring event Flaring events did not meet the criteria in 563.670(oX3). Delayed Coking Units 63.6ss(gl(12)For delayed coking units, the Periodic Report must include the information specified in paragraphs (eXr2Xi) through (iv) of this section. N/A, no DCU present. Maintenance Vents 63.5ss(el(131 For maintenance vents subject to the requirements in 5 63.643(c), Periodic Reports must include the information specified in paragraphs (e)(13Xi) through (iv) of this section for any release exceeding the applicable limits in 5 63.643(c)(1). For the purposes of this reporting requirement, owners or operators complying with 5 53.643(c)(1)(iv) must report each venting event for which the lower explosive limit is 20 percent or greater; owners or operators complying with 5 63.643(c)(1)(v) must report each venting event conducted under those provisions and include an explanation for each event as to why utilization of this alternative was required. See Table 4: Maintenance Vents Compliance Summary Provisions in 63.643(c)(1)(v) were utilized during reporting period. not 63.6ss(g)(13)(i)ldentification of the maintenance vent and the equipment served by the maintenance vent. See Table 4: Maintenance Vents Compliance Summary 63.6ss(eX13Xiil The date and time the maintenance vent was opened to the atmosphere. See Table 4: Maintenance Vents Compliance Summary 63.6ss(g)(13){iii}The lower explosive limit, vessel pressure, or mass of VOC in the equipment, as applicable, at the start of atmospheric venting. lf the 5 psig vessel pressure option in 5 63.643(cXlXii)was used and active purging was initiated while the lower explosive limit was 10 percent or greater, also include the lower explosive limit of the vapors at the time active purging was initiated. See Table 4: Maintenance Vents Compliance Summary 63.6ss(gX13Xiv)An estimate of the mass of organic HAP released during the entire atmospheric venting event. See Table 4: Maintenance Vents Compliance Summary Changes to NOCS 63.6ss(el(1al Any changes in the information provided in a previous Notification of Compliance Status report. No changes in information provided in previous NOCS. Subpart UUU 53.1s7s(cXa) 63.1575(d),(e) Emission li mitation/work practice deviations Deviations of emission limitations are reported in the quarterly CEMS reports dated April 30, 2024 and July 25,2024. A copy of the quarterly CEMS reports are included as Attachment D of this report. 53.1575(ef Deviation from an emission limitation occurring at an affected source where using a CEMS See a copy of the quarterly CEMS reports dated April 30, 2024 and July 25,2024. in Attachment D. Excess emission quantities:2.2 lbs. PM10 CPMS and stack testing derived correlation. For deviation specific estimates see Table 5. 63.1s7s(fX1)Performance test results U4 FCCU which is subject to 40 CFR 63.$6a(a)(1)(i) completed PM testing on 9/6/2023. As specified in the testing report submitted on L0ILL/2023. U25 FCCU which is subject to 53.1554(aX1)(ii) completed pM testing on 8122/2023 and 8123/ZOZ3. As specified in the testing report su bmitted on 7Ol L7/2023. 53.1s7s{fX2}Changes in applicable emission standards A request to modify Approval Order DAQE-AN10L23O057 -23 with a voluntary reduction to the applicable SRU limit of SOz from the NSPS 50.102a(f)(2Xi) of 2,500 ppmvd atO% oxygen (12-hour rolling average) to 100 ppmvd atO% oxygen (12-hour rolling average) was submitted to the Utah Division of Air Quality, UDAQ, on May 77,2024. SubparlZZZZ 63.66s0(c)(a) 63.66s0(cXs) Number, duration, and brief description for reach type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. Also include a description of actions taken by an owner or operator during a malfunction of an affected source to minimize emissions in accordance with $63.5605(b), including actions taken to correct a malfunction. There were no deviations from the emission or operating limitations during this reporting period. 63.65s0(cX5)lf there were no periods during which the continuous monitoring system (CMS), including CEMS and CPMS, was out-of-control, as specified in $63.8(c)(7), a statement that there were no periods during which the CMS was out-of-control during the reporting period. N/A, no CMS present on stationary RICE. Subpart DDDDD 63.7ss0(cX1)lf the facility is subject to the requirements of a tune up you must submit a compliance report with the information in paragraphs (cXSXi) through (iii) of this section, (xiv) and (xvii) of this section, and paragraph (cX5Xiv) of this section for limited-use boiler or process heater. See sections 63.7750(c)(5)(ii, iv, xiv)below. 63.7ss0(cXsXi.)Process unit information, emissions limitations, and operating parameter limitations lncluded in Attachment A. 63.7ss0(c)(5)(iv), (xiv)Operating hours and most recent tune-up lncluded in Attachment B. Consent Decree cD fl 136 Training Training is complete for all HollyFrontier employees that require training per CD fl 111.b and c. Records are being maintained on site for contract employees performing LDAR work. List of Tables for Semaannual for 40 CFR Part 63 cc Iumber [ame l-able 1 l-ank I nspections Summary I-able 2 leat Exchangers Compliance Summary lable 3a.1 :lares: Visible Emissions Summary lable 3a.2 :lares: Camera Outage Summary l'able 3b Flares: Combustion Zone NHV Compliance Summary Iable 4 Vlaintenance Vents Compliance Summary l-able 5 SEMS Excess Emissions Attachment A )rocess Unit lnformation, Emissions Limitations, and Operating Parameter Limitations \ttachment B )ate of Most Recent Tune-up and Burner lnspection \ttachment C l-ank lnspection Records and Seal Gap Calculations \ttachment D mission Limitation/work practice Deviations - euarterly cEMS Reports Table 1 - Tank lnspeaions Summary lnternal Roof Tank and Repair Details Tank lD Date lnsoected Desqlptlon of Fallure Nature of Reoairc Repalr Complete 1,2 3126/2024 No Failure Observed N/A N/A 7t 3/26/2024 No Failure Observed N/A N/A 72 3/26/2024 No Failure Observed N/A N/A 106 3/2512024 No Failure Observed N/A N/A 138 3/26/2024 No Failure Observed N/A N/A 155 3/28/2024 No Failure Observed N/A N/A 158 3/26/2024 No Failure Observed N/A N/A 323 312812024 No Failure Observed N/A N/A lnternal Roof Tank - Extensions Tank lD Date lnspccted Descrlptlon of Fallure Sdtcdule for Repalrs/Removal From Scrvlce Altcmatlve Storate AvallaHe? N/A N/A No Extension Utilized N/A N/A External Roof Tank -and Repair Details Tenk lD Date lnsDected Desqlptlon of Fallure Nature of Reoalrc Repalr Completc 100 3/L2/2024 No Failure Observed N/A N/A 101 3lt3/2024 Secondary Seal had gap greater than 0.5"Seal repaired 4/24/2024 L02 3/19/2024 No Failure Observed N/A N/n 1.04 3/s/2024 No Failure Observed N/A N/a 105 3/2L/2024 No Failure Observed N/A N/Atol3/6/2024 No Failure Observed N/A N/A 108 3/7/2024 Sunshield/Pusher plate detached from wiper tip Sunshield/Pusher repaired during insoection 3/712024 109 3/t2/2024 No Failure Observed N/A N/A L21 3l2t/2024 No Failure Observed N/A N/A t26 3/18/2024 No Failure Observed N/A N/A r28 316/2024 No Failure Observed N/A N/A t29 3/79/2024 No Failure Observed N/a N/A r32 3/7/2024 No Failure Observed N/A N/A 135 3/t3/2024 Secondary Seal had gap greater than 0.5" Grounding shunt displacing seal repaired during inspection 3/13/2024 145 3/s/2024 No Failure Observed N/A N/A t45 3/s/2024 No Failure Observed N/A N/A 156 s/23/2024 Pusher plate/sunshield detached from tank rim; anti-rotation column wiper worn Sunshield/Pusher plate reattached to rim, Anti-rotation column wiper replaced 712/2024 r57 s/23/2024 Anti-rotation column wiper worn Anti-rotation column wiper replaced 7/2/2024 Roof ank - Extensions Tank lD Date Inspected Descraptlon of Fallure Sdredule for Repalrc/ Remoral From Servlce Altcrnatlvc Storage Avallablc? N/A N/A N/A N/A N/A