DAQ-2025-000302

,.tttf$nctor
January 31,2024
Director, Air Enforcement Division CERTIFIED MAIL: 7022 0410 0002 3551 6714
Office of Civil Enforcement
U.S. Environmental Protection Agency
Mail Code 2242-A UTAH DEpARTMEIIT oF
1200 Pennsylvania Avenue, N.W. ENVIRONMENTAL QUAUTY
\flzshington, DC 20460-000 I
Executive Secretary, Utah Air Quality Board F E B : il ''ili't
Division of Air Quality
195 North 1950 West
p.o. Box t44lzo DIVISION OF AIR OUALII-
salt Lake city, uT 841144820
RE: Semiannual Progress Report
Consent Decree Entered July 2, 2008 in the U.S. District for the District of Utah
United States of America, State of Utah v. Holly Refining & Marketing Company - Woods
Cross (IlollyFrontier Woods Cross Refining LLC, Htr'WCR)
Dear Director and Executive Secretary:
In accordance with Paragraphs 135,147, and 149 of the subject consent decree, this submittal provides
the progress report for the Woods Cross Refinery for the semi-annual period from July I through
December 31,2023.
In accordance with Paragraph 149d, the following certification is provided:
I certiff under penalty of law that this information was prepared under my direction or supervision by
personnel qualified to properly gather and evaluate the information submitted. Based on my directions
and after reasonable inquiry of the person(s) directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete.
In accordance with Paragraph 261, copies of this report are also provided to EPA Region 8 and other
required government representatives.
Sincerely,
/*U-S,^..-^-o,*c.L
Dustin Simmonds
Vice President and Refinery Manager
HF Sinclair Woods Cross Refining LLC
1070 W. 500 S. West Bountiful, UT 84087
801-299-6600 | HFSinclair.com
REVIEWED Initials: Date: Jan 17, 2025Complinace Status:OKFile #: 10123 (B2)
January 31,2024
Director, Air Enforcement Division, et. al.
Page2
c: Dircctor, Air Enforcement Division Air Program Director
Office of Civil Enforcement Office of Enforceinen! Compliance & Environmental Justice
do Matrix New World Engineering Inc. Environmental Protec{ion Ageocy, Region 8
26 Columbia Tumpike, 2d Floor 1595 Wynkoop Sheet
Florham Padq NJ 07932 Denve,r, CO 80202-1129
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T. Go
of the Requirements
of Part V (Affirmative Relief/Environmental Projects)
cDfl Reoui Status/Comment
Section V.A. NOx Emissions Reductions from the FCCU
T2 Submit detailed design for NOx Control
System bv L2/3L|LO.Complete. Design sent 11/15/10.
13 lnstalland begin operation of NOx Control
System bv L2/37112.Complete. Operation began L0127 I 72.
L4
Commence 15-month interim
demonstration period to determine
interim FCCU NOx limit by 4/L/O9.
Data collection for NOx emissions from the
FCC began 4/7109 and was completed
6l30lLO.
15
Report results of interim NOx
demonstration by 90 days following
period.
Complete. lnterim report sent 9 /291 LO.
15 Propose and comply with 7-day and 355-
day interim NOx limits.
Complete. lnterim NOx limits proposed in
interim report of 180 ppm 7-day average and
110 ppm 365-day average.
T7
Comply with or dispute EPA-established
interim NOx limits within 90 days of
receipt.
EPA-established limits received and complied
with until final limits were set.
19
Commence 15-month demonstration
period upon startup of NOx Control System
to determine final FCCU NOx limit.
Complete. Final demonstration period
concluded on3l3OlL4.
20 Report results of final NOx demonstration
by 90 days following period.Complete. Final report sent 5/7 /14.
27 Propose and comply with 7-day and 365-
day final NOx limits.
Complete. Final NOx limits proposed in final
report of 80 ppm 7-day average and 40 ppm
365-day average and monitoring.
22 Comply with or dispute EPA-established
final NOx limits within 90 days of receipt.
Final limits submitted to EPA on 5/7 /L4. EPA
established final NOx limits, received
77/77/2O, of40 ppm 7-day average and 22.5
ppm 355-day average. We are complying
with those limits.
23 Use NOx and Oz CEMS to monitor FCCU
performancebv 4/7109.
Complete. NOx and Oz CEMS installed and
collectine emissions data 4ll/O9.
Section V.B. SOz Emissions Reductions from the FCCU
25
lnstall and begin operation of a Wet Gas
Scrubber at the FCCU by L2l3L/72 and
meet 25 ppm (365-day) and 50 ppm (7-
day)by 6/3olL3.
Complete. Wet Gas Scrubber installed
LO/271L2. We are complying with these limits.
26
Commence 15-month interim
demonstration period to determine
interim FCCU SOz limit by 4lUO9.
Complete. Data collection for SOz emissions
from the FCC began 4/L/O9 and was
completed 6/30/LO.
cD{Requirement Status/Comment
27
Report results of interim SOz
demonstration by 90 days following
period.
Complete. lnterim report sent 9129170.
28 Propose and comply with 7-day and 365-
day interim SOz limits.
Complete. lnterim SOz limits proposed in
interim report of 160 ppm 7-day average and
50 ppm 365-day average.
29
Comply with or dispute EPA-established
interim SOz limits within 90 days of
receipt.
EPA-established limits received, and complied
with those limits untilthe lower limits became
effective.
31 Use SOz and Oz CEMS to monitor FCCU
performance bv 4/L/O9.
Complete. SOz and Oz CEMS installed and
collecting emissions data 4/LlO9.
Section V.C. PM Emissions Reductions from the FCCU
32
Comply with limit of 1.0 pounds PM
1000 pounds coke burned for FCCU
6/30/L3.
per
by
Complete. PM performance testing
completed on 72/20172. Report sent to EpA
Ll23/13.
33
lnstall and begin operation of a Wet Gas
Scrubber at the FCCU by L2/3UI2.
Comply with limit of 0.5 pounds PM per
1000 pounds coke burned for FCCU by
6l30lt3.
Complete. PM performance testing
completed on L2/2OlL2. Report sent to EPA
t/23113.
35
Perform PM test on FCCU by LO/3UL3 and
annually thereafter by 10/31. Submit
results in next semiannual report.
lnitial PM performance testing completed on
L2/20112. Results sent to EPA under separate
cover letter l/231L3. First annual PM test
completed LO/22/L3. Second annual PM test
completed 70/21L4. Third annual PM test
completed LO|22/L5. Fourth annual PM test
completed L2/7/L6. Fifth annual PM test
completed IO/25/L7. Sixth annual PM test
completed tO/L9178. Seventh annual PM test
completed 9/4/19. First triennial PM test
completed 61L4122. Additional PM test
completed 9/6/23. Request to reduce testing
frequency was submitted to USEPA 6/26/78.
Request for triennial testing granted 9/6/79.
Section V.D. CO Emissions Reductions from the FCCU
35 Comply with 500 ppm CO (l-hour) at FCCU
bv L2l3Uo9.Complete. Monitoring CO emissions.
37 Option to comply with 100 ppm CO (365-
day) at FCCU.Option is not currently under consideration.
39 Use CO and Oz CEMS to monitor FCCU
performa nc e bV L2l 3UO9.
Complete. CO and Oz CEMS installed and
collecting emissions data 4lL/O9.
Section V.E. NSPS Applicability of the FCCU Catalyst Regenerator
cDfl Requirement Status/Comment
47 FCCU subject to NSPS for CO by L2/3L(O9,
and for SOz and PM by 6l3O/L3.
CO limit complete, 500 ppm CO (l-hour)at
FCCU. Wet Gas Scrubber installed and now
complying with SOz and PM NSPS limits.
43 lnstall and operate a COMS on the FCCU by
L2/3U12 or comply with t144.
Complete. Alternate Monitoring Plan (AMP)
request sent to EPA4/72/72. Revised AMP
request sent to EPA9/271L2. AMP approval
received LO/24/L2.
44 Request an AMP for monitoring opacity
from the FCCU or comply with 1143.
Complete. Alternate Monitoring Plan (AMP)
request sent to EPA4/t2/t2. Revised AMp
request sent to EPA9127 /L2.
Section V.F. NOx Emissions Reductions from Heaters and Boilers
46a
lnstall Next Generation ULNBs or
alternative NOx Control Technology on
6H1, or convert the Clark compressor
driver to electric, or replace the Clark
compressor with an electric-driven
compressor bV 72/3L/O9.
Complete. Clark compressor was replaced by
electric driven compressor 11K2. lnstallation
was complete 11177/09.
46a
lnstall Next Generation ULNBs or
alternative NOx Control Technology on 8H1
bv 12l3Llo9.
complete. lnstalled by 9/9108.
45a
lnstall Next Generation ULNBs or
alternative NOx Control Technology on
12H1by L2/37/o9.
Complete. lnstalled bV 9/7/08.
46a
lnstall Next Generation ULNBs or
alternative NOx Control Technology on #5
Boiler bv t2l3L/O9.
Complete. Selective Catalytic Reduction (SCR)
alternative NOx Control Technology was
installed on #5 Boiler on 12/30109.
46a
lnstall Next Generation ULNBs or
alternative NOx Control Technology on the
CO Boiler bV t2l3L/72 if disengaged from
FCCU.
Complete. CO Boiler disengaged from FCCU
LOl26l12. CO Boiler shut down permanently.
46a
lnstall Next Generation ULNBs or
alternative NOx Control Technology on
Boiler #8by 72/3L/L2.
Complete. Boiler shutdown on L2l3UL2 and
restarted L/LOlt3 with Selective Catalytic
Reduction (SCR) installed.
46a
lnstall Next Generation ULNBs or
alternative NOx Control Technology on 4H1
bV t2l3L/L2 if heat input capacity is raised
above 40 mmBTU/hr.
Heat input capacity is at or below 40
mmBTU/hr.
45b(1)
lnstalland operate NOx and Oz CEMS on
heaters/boilers over 100 mmBTU /hr by
date of NOx Control Technology
installation, and use to monitor emissions
by 6 months later.
No heaters or boilers have heat input
capacities over 100 mm BTU/hr (HHV).
cDfl Requirement Status/Comment
46b(2)
Conduct performance tests on
heaters/boilers equal to or less than 100
mmBTU/hr by 50 days after installation of
NOx Control Technology.
Complete. Performance test on 8Hl.
completed 7Ol9lO8. Performance test on
12H1 completed LO/t3/08. Performance test
on #5 Boiler completed 219/10 and retested
3/25lLO. Performance test on #8 Boiler
completed 4122/L3.
46c
Submit permit revision to State proposing
NOx emission limits (3-hour) for any NOx
Control Technology within 1.20 days of
start-up.
Complete. Notice of lntent for a change in
permit conditions for NOx limits on 8H1 and
12H1 submitted L2123/08. Notice of lntent
for a change in permit conditions for NOx
limits on #5 Boiler submitted 4/29lLO.
45d
Submit annual NOx Control Technology
progress report bV L2/37 beginning in
2008.
First report submitted t2/L5/O8. Subsequent
annual reports submitted : t2l2L/O9,
72/ 22 I 70, t2 122 I tL, L2 I zLl L2, Lzl 37 I L3,
721 30 I 14, 72 129 I Ls, 72 I 281 L6, t2/ 27 I 17,
12 / 3L / L8, 72 I 30 / t9, 72 I 30 I 20, L2 I 28 I 2021,
L2 I 30 / 2022, and t2 / 28 / 2023.
Section V.G. SOz Emissions Reductions from and NSPS Applicability to Heaters and Boilers
48 All heaters and boilers are subject to NSPS
Subpart J.
Complete. Prior to Consent Decree, fuel gas
for all heaters and boilers being monitored by
CEM, with quarterly reporting as required by
State of Utah.
49 May use alternative monitoring method
immediatelv uoon submittal of AMP.
Complete. 2 AMPs submitted June 24, 2009.
(AM Ps were subsequently rescinded.)
50
No liquid fossil fuel over 0.05% Sulfur by
weight shall be burned in any fuel gas
combustion device.
Complete. None used. lnternal memo sent
detailing limit. Copy and responses filed.
Section V.H. NSPS Applicability to the Sulfur Plant
52 NSPS shall apply if SRU exceeds 20 LTPD.Complete. Maximum SRU capacity is 10 LTPD.
Daily HzS feed shown in Attachment A.
52a lnstall and commence operation of SOz
CEMS at SRU by 712/08.
Complete. CEMS installed and operational
prior to 7 /2/O8.
52a
Demonstrate daily 95% recovery (30 day)
for SRU using measured HzS in feed and
SOz emissions from CEMS.
The calculation of 95% recovery from the
sulfur recovery unit has become impractical
due to the treatment of off gas from the
sulfur recovery unit by a fluidized catalytic
cracking unit's wet gas scrubber. A detailed
summary of these changes was submitted on
6le/76.
cDf Requirement Status/Comment
52a Determine HzS in SRU feed quarterly for 4
quarters and semiannually thereafter.
Sampling and analysis completed 9122/08,
70 / t6 I 08, 21 6 / 09, 5 / s I 09, 7 I 29 I 09, tO/ 72 I 09,
7 I 22 / LO, 8 /2s I LO, OLI 26/ 77, 7 / 281 7L,
2/28/ 72, 7 I 7L/ L2, 21 4/ 73, 7 /2/ L3, 21 78/ 74,
7 I 51 74, 7/21/ 75, 7 /7 I L5, and 219 I 76.
Sampling has been discontinued. The SRU off
gas is treated by a fluidized catalytic cracking
unit's wet gas scrubber.
52b,c
Complete SRP Optimization Study,
implement recommendations, and submit
study report within 1 year after 712/08.
Complete. Optimization Study was completed
and report submitted 6126109. Schedule of
implementation for the report's
recommendations was included in the report
that was submitted.
52d
Submit test protocolto EPA Region 8 and
State to perform 95% recovery efficiency
and emission limit test at least 30 days
before test. Conduct test within 5 months
after completion of SRP Optimization
Study.
SRP Optimization Study completed
6/26/2009. Test protocol was submitted
7t/ 23 / 2OO9. Testing perfo rmed 72 I 23 I 2OO9,
SRU achieved 95.2% recovery and 0.42 tons
per day (830 lbs)SO2.
52e
Submit a semiannual report covering SRU
recovery, emissions, operating
parameters, and daily feed.
The calculation of 95% recovery from the
sulfur recovery unit has become impractical
due to the treatment of off-gas from the
sulfur recovery unit by a fluidized catalytic
cracking unit's wet gas scrubber. A detailed
summary of these changes was submitted on
6le/16.
52f
Submit Plan for Maintenance and
Operation of SRP within 270 days from
712/O8.
Complete. Plan submitted 3126/2009.
52h
Submit schedule to comply with NSPS
within 120 days of SRU exceeding 20 LTPD
input.
Maximum SRU capacity has not increased
beyond 10 LTPD.
54 All sulfur pit emissions routed to
incinerator.
Complete. Commenced prior to Consent
Decree.
Section V.l. NSPS Applicability to Flaring Devices
56, 56a
North flare and South flare subject to NSPS
as of date of entry, eliminate all routinely-
generated gas.
complete. subject to NSPS prior to consent
Decree, no routinely-generated gas sent to
flare. As of November 7L,2075, all streams
going to the flares are being monitored for
compliance with the NSPS Ja standard, and
are reported in the quarterly CEMs reports.
cDfl Requirement Status/Comment
55,55a South flare subject to NSPS 6130/09,
eliminate all routinely-generated gas.
Complete. Study completed on routinely-
generated gas sources and rerouting
completed. Alternative Monitoring Plans
submitted for 2 streams. (AMPs were
subsequently rescinded.)
56,55a Propane flare subject to NSPS 72/3t/O9,
eliminate all routinely-generated gas.
Complete. New propane flare installed
LU77/2OO9. The propane flare and
associated storage pit were decommissioned
in December of 2013.
s6b
Conduct performance tests for each flare
within 180 days after bringing into
compliance with NSPS.
Performance tests for both North and South
Flares conducted December 10, 2008.
Performance test for the propane pit flare
conducted March 25, ?OLO.
57a Comply with 162 ppm HzS limit in fuel gas.Complete. Ongoing prior to Consent Decree.
Section V.J. Control of Acid Gas Flaring lncidents
59
Submit reports for Acid Gas Flaring
lncidents no later than 45 days after
incident.
No Acid Gas flaring events occurred in period.
Section V.K. Control of Hydrocarbon Flaring lncidents
68 Submit reports for Hydrocarbon Flaring
lncidents in semiannual orosress reoorts.
No Hydrocarbon flaring events occurred in
period.
Section V.L. CERCLA/EPCRA
59 Report any previously unreported SOz
releases bv 6/3O/09.
No previously unreported SOz releases were
identified.
Section V.M. Benzene Waste Operations NESHAPS Program Enhancements
72 lf TAB exceeds tOMg/yr, utilize the 6BQ
compliance option.TAB remains under 10 Mg/yr.
73
Complete review and verification of
refinery's TAB and compliance by 270 days
after date of entry.
Complete. Sampling plan, review and
verification were completed 3/18/09.
74,
103a
Submit report to the EPA and State by 60
days after review and verification.complete. Report submitted 5l2o/o9.
75
Conduct additional sampling and submit
results to EPA within 50 days after
receiving request from EPA.
EPA requested no additional sampling.
75,
103b
Revise report and resubmit within 120
davs after completion of samolins.Original report deemed final.
76
lf revised report indicates initial report was
unsatisfactory, resubmit report to State
within 120 days after completing revised
report.
Original report deemed satisfactory.
CDfl Requirement Status/Comment
77,
103c
lf revised report indicates TAB over 10
Mg/yr, submit plan within 180 days to
ensure future compliance or to comply
with 6BQ within 2 years.
No action required. The BWON Compliance
Review and Verification Report did not
indicate that the TAB exceeds 10 Mg/year.
79,
103d
lf actions are required under tl 77, submit
certification of compliance within 30 days
after completion of actions.
No action required. Neither the BWON
Compliance Review and Verification Report
nor current sampling pursuant to Paragraph
94 indicate that the TAB exceeds 10 Ms/vear
80
Develop program within 60 days from date
of entry to annually review process/project
information to ensure all new benzene
waste streams are included in inventory.
Complete. A task to complete an annual
review was added to the automated
environmental tracking system. lnventory
reviewed on L2|3O/O9, 72/27 /LO,12l3OlLL,
L2/27 /L2, 72/L9/73, L2/1OlL4, Lzl3o.lt5,
L2 / 28 I L6, t2 / 22 I t7, 3 / 24 I L8, 12 I 2tl L8,
L2 / 20 I 19, Lzl L7 /2O, L2 / 30/ 2L, 6 /30/ 22, and
sl3t/23.
82,94
Conduct audits of all laboratories used for
benzene waste analysis within 27O days
after date of entry, new labs before use,
and every two vears.
Laboratory audit compl eted 3/ LU L7, 3 / 8/ !3,
3 / L8/ Ls, 3 / L6l 77, 3 / 28 I L9, 3 I 22/ 2L, and
3/8123.
86
Review spills to determine if they generate
more than 10 lbs of aqueous benzene
waste, and include in TAB.
Environmental Procedure 5.02 incorporates
review requirements.
87
Develop and begin annual training for all
employees asked to draw benzene waste
samples, complete first within calendar
year.
lnitia I tra ining completed 05 lOLl 09. Contract
personnel were initially used to collect
samples. Additional training completed
annually. The latest training was completed
on 12129/23.
89 Ensure contractor employees hired to
perform training are adequately trained.
Completed for contract employees by
72/LslO8, L2/8/O9, and LL/OS/tO.
Contractors no longer used.
90,
103e
Subm it waste/slop/off-spec oil
management schematics Complete. Sent to State and EPAglzLlOS.
93,
103f
Submit quarterly/annual sampling plans to
EPA and State by 60 days after revised
report is finalized or original report is
accepted.
Original report accepted. Sampling plan sent
on7l2l72.
95 lmplement the sampling plan in the first
full quarter after submittal.
Complete. Sampling plan has been
implemented. The sampling plan is more
stringent than the CD in requiring quarterly
sampling for waste streams > 0.05 MglVr
benzene.
cD !t Requirement Status/Comment
96,
103f
lf changes affect the validity of the
sampling plan, submit revised plan within
90 days.
A revised sampling plan was submitted to EPA
on 5123/23. EPA approval for that revised
sampling plan has not been received.
97 Submit quarterly and annual projected
TAB with semiannual report.
The quarterly and annual projected TAB is
included in Attachment B.
98
lmplement corrective measures if
quarterly TAB > 2.5 Mg or annual TAB > 10
Mg.
No excesses during this period.
99 Provide reasons why causes of excess
quarterly or annualTAB will not recur.No excesses during this period.
100,
103g
Submit compliance assurance plan if
quarterly TAB > 2.5 Mg or annual TAB > 10
Mg.
No excesses during this period.
10L
Contract 3'd party to conduct TAB study
and compliance review if quarterly TAB >
2.5 Mg or annual TAB > 10 Mg. Submit
results to EPA and State within 30 days
and implement.
No excesses during this period.
704a Submit sampling results and TABs with the
semiannual report.
Sampling results and TABs are included in
Attachment B.
104b Submit description of training conducted
with the semiannual report.
Retraining completed for 2023 via review of
physical materials based on previous
computer-based training.
104c Submit a summary of lab audits conducted
with the semiannual report.
No audits were conducted during this
semiannualperiod.
105 Requests to modifli the frequency of
reporting under fl104.
No request has been made to modify the
frequency of reporting.
Section V.N. Leak Detection and Repair ("LDAR") Program Enhancements
109 Develop and maintain a written LDAR
proqram within 120 davs of date of entrv.
Complete. Submitted with Semi-Annual
Report dated U28lO9.
110,
135a
Submit LDAR program to EPA and State in
first semiannual report.
Complete. Submitted with Semi-Annual
Report dated U28/O9.
111a
Train employees newly assigned to LDAR
responsibilities before beginning LDAR
work.
Computer-based training is required for all
newly involved employees.
111b
Provide annual training for all employees
with specific LDAR responsibilities as
primary job function beginning within 1
year of 7 /2/O8.
Computer-based training program is required
for all employees with specific LDAR
responsibilities as their primary job function.
10
cD tl Requirement Status/Comment
111c
Provide training every 3 years for all
operations and maintenance employees
beginning within 1 year of 7l2lO8.
Training program established training for L46
employees and completed 612/09. Training
for 150 employees completed L2l2L/71.
Training for 218 employees completed
tzl3LlL3. Training for L73 employees
completed 72/3L/L5. Training for 2O7
employees completed L2l3L/L8. Training for
158 employees completed 2l L/22. 3 year
training for operations and maintenance
personnel typically takes place through
computer-based training (CBT). The refinery
transitioned to a new CBT software system in
late 2O2t. To facilitate the required training, a
training document was developed to
distribute to personnel, as an alternative.
Anti-phishing safeguards in our email
software prevented the timely distribution of
the training. Training for 163 employees
completed L2/22123.
111d Maintain records of annual training as in fl
111b for contract LDAR personnel.Maintained under file number 2.6.3.
7L3,
LL4
Conduct 3'd party audit of LDAR
compliance every 4 years, beginning within
12 months of date of entry.
3'd party audit conducted by ERM and report
submitted 6122/09.
113 Submit LDAR compliance certification to
EPA.
LDAR compliance certification submitted
Ll5ho.
115
Conduct an internal or 3'd party audit of
the LDAR program every 4 years, beginning
within 2 years after the initial 3'd party
audit.
3'd party audit condu cted 4/7817L, 4/8/13,
4 / L3 / 15, 5 I 76 I L7, 4/ Lt/ 79, 4 I 22/2L, and
sl4/23.
116 LDAR audits are to be conducted in the
same calendar quarter.
Allfuture LDAR audits will be conducted the
second calendar quarter of the year.
717
lmplement steps necessary to correct
areas of non-compliance identified in the
Consent Decree required LDAR audits.
All corrective actions identified in the first
LDAR Audit conducted 5/25-29/O9 are
complete. Corrective actions for the second
and third audits are complete. Corrective
actions for the fourth audit are complete.
Corrective actions for the fifth audit are
complete. Corrective actions for the sixth
audit are complete. Corrective actions for the
seventh audit are complete.
11
cD{Requirement Status/Comment
t20
Utilize internal leak definition of 500 ppm
for valves, except pressure relief devices,
bv 7/7/os.
Complete.
L27 Utilize internal leak definition of 2,000
ppm for pumps by 7 /l./LO.Complete.
722
Specify in report whether applicable
regulatory leak definition or lower internal
leak definitions are being used for leak
rates.
Applicable regulatory leak definition is used
for reporting leak rates.
124
Make initial attempt at repair on non-
control valves with reading over 200 ppm
and remonitor.
Complete.
L25 Monitor pumps in light service monthly
beginning 7l7lLO.Complete.
L26
Monitor valves, other than difficult to
monitor valves, quarterly beginning
7/7loe.
Complete.
127 Keep LDAR data in electronic database.Complete.
728 Use dataloggers/electronic data collection
for LDAR.Complete.
L29
Develop and implement a LDAR aA/qC
procedure within 90 days after date of
entry.
Complete.
130
All LDAR equipment calibrations to be
conducted per Method 2L, and records
maintained for life of Consent Decree.
As specified in procedures, see Semi-Annual
Report dated 7/28109, Attachment B.
131
Drift assessments performed at minimum
at the end of each shift, with remonitoring
if negative drift exceeds 70%.
Complete.
t32a
Sign off by responsible person for delay of
repair, and continued monitoring of
equipment.
Complete.
L32b
Employ "drill and tap" for valves leaking
over 10,000 ppm that cannot otherwise be
repaired.
As required, and as specified in procedures,
see Semi-Annual Report dated 7/28/09,
Attachment B.
734
Repair or replace non-control valves that
are chronic leakers at next process unit
turnaround.
As required, and as specified in procedures,
see semi-Annual Report dated Ll28/09,
Attachment B.
135a Provide LDAR program information in the
first semia nnual report.Complete.
t2
cDi Requirement Status/Comment
13sb
Provide description of audit report for
each audit conducted in the prior year in
the semiannual report (July 31 report
only).
Description of audit report to be included in
semiannual report due 7 /3712024.
135
Provide information on training and on
LDAR monitoring and repairs in the regular
NESHAPS reports.
lncluded in Semiannual MACT reports
beginning January 2009.
Section V.O. lncorporation of Consent Decree Requirements into Federally Enforceable Permits
737a
Submit permit revision for immediate
Consent Decree requirements within 90
days of date of entry.
Notice of lntent for a change in Approval
Order (AO) conditions to incorporate Consent
Decree requirements submitted 9179108. AO
# DAQE-AN07O723OO27 -09 received tU 2 I 09.
L37b
Submit permit revision for other Consent
Decree requirements within 90 days of
effective date.
Notice of lntent for a change in Approval
Order (AO) conditions for NOx limits on 8H1
and l2Hl submitted 72123108. AO # DAQE-
AN0101230027-O9 received 7tl2lO9. Notice
of lntent for a change in AO conditions for CO
limit on FCCU submitted 31291t0. AO #
DAQE-AN0101230032-10 received 8 /23 / 70.
Notice of lntent for a change in AO conditions
for #5 Boiler NOx limit submitted 4/29lLO. AO
# DAQE-AN0101230035-10 received
7t/t7lz0t0. Notice of lntent for a change in
AO conditions for interim NOx and SOz limits
on FCCU submitted 7713O/LO. AO # DAQE-
AN0101230038-10 received L2/ tG I 2O7O.
Notice of lntent for a change in AO conditions
for final SOz limits on FCCU submitted
5/23/2072. Notice of lntent for a change in
AO conditions for interim NOx limits on FCCU
submitted 3/2312013. AO #DAQE-
AN101230041-13 received tL/t8/L3. Notice
of lntent for a change in AO conditions for
final NOx limits on FCCU submitted 2lal2O27.
AO #DAQE-AN101230053-22 received
e/7/2022.
13
cDfl Requirement Status/Comment
Section V.H. NSPS Aoolicabilitv to the Sulfur Plant
52e
Submit a semiannual report covering SRU
recovery, emissions, operating
parameters, and daily feed.
The calculation of 95% recovery from the
sulfur recovery unit has become impractical
due to the treatment of off gas from the sulfur
recovery unit by a fluidized catalytic cracking
unit's wet gas scrubber. A detailed summary of
these changes was submitted on 6/91L6.
Summary of the Emissions Data Required by the Reporting Requirements
of Part V (Affirmative Relief/Environmental Projects)
Description of Any Problems Anticipated with Respect to Meeting the Requirements
of Part V (Affirmative Relief/Environmental Projects)
None for this report.
Progress Report on the lmplementation of the Requirements
of Part Vll (State Supplementa! Environmental Project)
Any Additional Matters to be Brought to the Attention of EPA and the State
None for this report.
Summary of Annual Emissions Data for the Prior Calendar Year
CDfl Requirement Status/Comment
Section Vll. State Supplemental Environmental Projecl
145a
Contribute S130,000 for purchase of
mobile command post, which shall be
acquired within 1 year of date of entry.
Complete. Delivery of mobile command post
4/8109. Public presentation 5/L9lO9.
145b
Submit a cost report and certification in
the semiannual report upon completion of
oroiect.
Complete. Submitted with Semi-Annual
Report dated 7 /29 /09, Attachment D.
747 Provide a progress report for the SEP in
each semiannual report.
Complete. Submitted with Semi-Annual
Report dated 7 129 109, Attachment D.
cD ll Reouirement Status/Comment
Section lX. Reporting and Recordkeeping, 11149b. Emissions Data
L49b
Estimation of NOx emissions for each
heater and boiler greater than 40
mmBtu/hr.
2023 Emissions data to be reported in
semiannual report due 7 /3L/24.
L4
749b
Estimate of NOx emissions as a sum for all
heaters and boilers less than 40
mmBtu/hr.
2023 Emissions data to be reported in
semia nnual report due 7 /3L124.
149b Estimate of SO2, CO and PM emissions as a
sum for all heaters and boilers.
2023 Emissions data to be reported in
semiannual report due 7 /3L/24.
L49b Estimate of SOz emissions from all Sulfur
Recovery Plants.
2023 Emissions data to be reported in
semiannual report due 7 I 37124.
149b SOz emissions from all acid gas flaring
incidents bv flare.
2023 Emissions data to be reported in
semiannual report due 7 / 37/24.
149b
NOx, SOz, PM, and CO emissions as a sum
at each refinery for all other emissions
units for which emissions information is
required to be included in the facilities'
AEI not identified above.
2023 Emissions data to be reported in
semiannual report due 7 l3L/24.
Exceedances of Emission Limits
CDfl Limit Exceedances
Section X. Reporting and Recordkeeping, fl149c. Exceedances of Emission Limits
16 lnterim NOx 7-day rolling average,
corrected to 0% oxygen, from FCCU
No longer applicable. Complying with final
limits.
16 lnterim NOx 365-day rolling average,
corrected to 0% oxvgen, from FCCU
No longer applicable. Complying with final
limits.
27 Final NOx 7-day rolling average, corrected
to 0% oxygen, from FCCU
3Q 2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly
report submitted 70/26123.
4Q2O23: No Emission Limit exceedances.
Totaldowntime of the CEM wasO.O4o/o of the
calendar quarter, as detailed in quarterly
report submitted 7/LU24.
27 Final NOx 355-day rolling average,
corrected to 0% oxygen, from FCCU
3Q 2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly
report submitted LO/26/23.
4Q2O23: No Emission Limit exceedances.
Total downtime of the CEM was 0.04% of the
calendar quarter, as detailed in quarterly
report submitted L/ t7/24.
15
CD 'II Limit Exceedances
25 Final SOz 7-day rolling average, corrected
to 0% oxygen, from FCCU
3Q 2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly
report submitted 70/26/23.
4Q2023: No Emission Limit exceedances.
Totaldowntime of the CEM wasO.O4% of the
calendar quarter, as detailed in quarterly
report submitted 7l LU 24.
25 Final SOz 365-day rolling average,
corrected to 0% oxygen, from FCCU
3Q 2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly
report submitted 7O126123.
4Q 2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.04% of the
calendar quarter, as detailed in quarterly
report submitted U 7L124.
28 Interim SOz 7-day rolling average,
corrected to 0% oxygen, from FCCU
No longer applicable. Complying with final
limits.
28 lnterim SOz 365-day rolling average,
corrected to 0% oxvgen, from FCCU
No longer applicable. Complying with final
limits.
32 1.0 pounds PM per 1000 pounds ofcoke
burned from FCCU
Not applicable. Holly is subject to stricter limit
of0.5 pounds PM per 1000 pounds ofcoke
burned from FCCU.
33 0.5 pounds PM per L000 pounds ofcoke
burned from FCCU
3Q 2023: Emission Limit exceeded 2.O4o/o of
the calendar quarter. Total downtime of the
CEM was O.OO% of the calendar quarter, as
detailed in quarterly report submitted
10126/23.
4Q2O23: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly
report submitted L/lLl24.
35 500 ppmvd CO l-hour average at 0%
oxygen, from FCCU
3Q 2023: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly
report submitted 70126/23.
4Q2O23: No Emission Limit exceedances. Total
downtime of the CEM was O.O4% of the
calendar quarter, as detailed in quarterly
report submitted t/ L7124.
37 100 ppmvd CO 355-day average at 0%
oxygen, from FCCU Not applicable
46c NOx 3-hour rolling average, from 8HL Not applicable.
16
CDfl Limit Exceedances
46c NOx 3-hour rolling average, from 12H1 Not applicable.
46c NOx 3-hour rolling average, from #5 Boiler Not applicable.
46c NOx 3-hour rolline averaqe, from CO Boiler Not applicable
45c NOx 3-hour rolling average, from #8 Boiler Not applicable
46c NOx 3-hour rolling average, from FCCU
Feed Heater Not applicable
48 162 ppm HzS 3-hour average, in fuel gas
3Q 2023: Emission Limit exceeded O.27% of
the calendar quarter. Total downtime of the
CEM was O.OO% of the calendar quarter, as
detailed in quarterly report submitted
tol26l23.
4Q2O23: No Emission Limit exceedances.
Total downtime of the CEM was 0.00% of the
calendar quarter, as detailed in quarterly
report submitted 71 7L/ 24.
52a 1.5 tons per day sulfur, from SRP
Emissions are combined with one of two FCCU
wet gas scrubber stacks. A detailed summary
of these changes was submitted on 619/L6.
The limit at each FCCU wet gas scrubber is
0.05 tons per day for the combined SRU tail
gas and regenerator scrubbed flue gas
streams.
59 500 pounds SOz in a 24-hour period from
acid gas flaring No incidents in period.
68 500 pounds SOz in a 24-hour period from
hvdrocarbon sas fla rine No incidents in period.
Stack Tests - Emissions Monitored through Stack Testtng
32,33 PM from FCCU Complete. PM performance testing completed
on 72120/72. Report sent to EPA7l23/L3.
46c NOx from 8H1
Complete. Stack test report submitted
72l15lOB to EPA and State of Utah in
accordance with fl46d.
46c NOx from 12H1
Complete. Stack test report submitted
72/LSlOg to EPA and State of Utah in
accordance with fl46d.
46c NOx from #5 Boiler
Complete. Stack Testing completed 2l9lt0
and retested 3125170. Stack test report
submitted 4129l70 with Notice of lntent.
46c NOx from CO Boiler Not applicable
46c NOx from #8 Boiler Complete. Performance test completed on
4122/73.
46c NOx from FCCU Feed Heater Not applicable
L7
Attachment A
SRP Summary Report
SRP Summary Report no longer included per notification submitted to the United State EPA Office of
Civil Enforcement on June 9, 2015 detailing the change in reporting for the Sulfur Recovery Unit
Attachment B
TAB Analysis Reports
BWON Samplod Waste Steams and Result3
2023
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Attachment C
Summary of BWON Lab Audit
No BWON Laboratory audits conducted during this semiannual period.
REVIEWED Initials: Date: Jan 17, 2025Complinace Status:OKFile #: 10123 (B2)
Attachment D
LDAR Audit Summary
No LDAR Audits conducted during this semiannual period.
Attachment E
Hydrocarbon/Acid Gas Flaring lncident Report
No incidents in period.
_qrAH DEPARruENT OFENVtRoNMENrnr. ouet-rry
FEB _ 6 20?_4
DIVISION OF AIR QUALTTY