DAQ-2025-000309

August 27,2024
Mr. Bryce Bird, Director
Division of Air Quality
Utah Dept. of Environmental Quality
150 North 1950 West
Salt Lake Ciry, Utah 84114
Director, Air and Toxics Division
EPA Region VIII
999 l8th Street
1 Denver Place, Suite 500
Denver, CO 80202-2405
CERTIFIED MAIL: 7022 0410 0002 3551 5878
CERTIFIED MAIL: 70220410 0002 3551 5885
,.dttFfinctorr
HF Sinclair Woods Cross Refining LLC
1070 W. 500 S, West Bountiful, UT 84087
801 -299-6600 | H FSinclair.com
Re: 40 CFR Part 63, Subpart UUU - Notilication of Compliance Status, and
Operation, Maintenance & Monitoring Plan Updates
HF Sinclair Woods Cross Refining LLC
Approval Order: DAQE-AN101230057-23, Title V Operating Permit: 1100013001
Director,
HF Sinclair Woods Cross Refining LLC (HFSWCR) is a major source of Hazardous Air Pollutants
(HAPs) and subject to 40 CFR Part 63, Subpart Utru. In accordance with 40 CFR 63.1574(a)(3),
HFSWCR is submitting a notification of compliance status (NOCS) with regard to 40 CFR 63.1568 and
an updated Operation, Maintenance and Monitoring Plan (OMMP), per 40 CFR 63.9(h)(3) and 40 CFR
63.1s74(d) & (0.
The NOCS and OMMP is being updated to reflect compliance with HFSWCR's request to modiff
Approval Order DAQE-AN101230057-23 with a voluntary reduction to the applicable SRU emission
limit for SOz from the NSPS 60.102a(f)(2Xi) of 2,500 ppmvd atloh oxygen (I2-hour rolling average) to
100 ppmvd at 07o oxygen (12-hour rolling average). This request was submitted to the Utah Division of
Air Quality, UDAQ, on May 17,2024.
If you have any questions concerning this matter, please feel free to contact me at [phone] or via
email at [e-mail].
Sincerely,
Richmond Thornley
Environmental Engineer
c: E. Benson (r) File 2.1.1.2.2
Encl.: 40 CFR Part 63, Subpart UUU Notification of Compliance Status & OMMP ,ilti",ffi'.tffi?[^3i,
a i' :
Di\/ISION OF AtR OUALIT'
REVIEWEDInitials:Date: Jan 8, 2025Complinace Status: OKFile #: 10123 (B2)
Notification of Compliance Status
National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries
40 CFR Part 63, Subpart UUU
Name of Facility:
Operating Permit Number:
Name of Owner/Operator:
Mailing Address:
Physical Address:
Contact Person:
Dustin Simmonds-Vice President & Refinery
Manaeer
HF Sinclair Woods Cross Refining LLC
DAQE-AN I 01230057 -23 and TV #1 I 0001 3001
HF Sinclair Woods Cross Refining LLC
1070 West 500 South
West Bountiful, UT 84087-1442
393 South 800 West
Woods Cross, UT 8407-1435
Richmond Thornley
(80r) 299-66s8
Richmond.Thornley(@HFSinclair.com
I certifu that, based on information and belief formed after reasonable inquiry, the statements and
information in thigrepd$ and the supporting enclosures are true, accurate, and complete.
nature)
Bp^rn-.u
€o.t-'
(801 ) 2e9-660s
Dustin. Simmonds(dHFSinlair.com
(Date)
(Name/Title)(Telephone No./Email)
40 CFR 63 Subpart UUU Notification of Compliance Status
'llris rcpolt lirllills the uotillcation lcrprircrncrrts containerl in -10 ('lrR \\ 6.1 l-57{
( I ) Identilication of affected sources and ernission points:
Nature of Alfbcted Source: Sullur Recovery Unit
Size of Affected Source:
Design of Aff'ected Source:
Method of Operation:
Operating Design Capacity:
llAP [:mission Point:
10.22 long tons sulfur input
Claus conversion oxidation/reduction control systenr tbllowed by
incineration
Continuous
10.22 long tons sullur input
4V83 FCC Wet Gas Scrubber
25V45 FCC #2 Wet Gas Scrubber
S 63.1574 & Table 42:
(1)Identification of affected sources and emission points.
lnitial compliance: Identification of each emission limitation you will meet for each affected source,
including any option you select (i.e., NSPS, PM or Ni, flare, percent reduction, concentration,
options for bypass lines); if applicable, certification that you have already conducted a performance
test to demonstrate initial compliance with the NSPS for an affected source; certification that the
vents meet the applicable emission limit and the continuous opacity or that the emission monitoring
system meets the applicable performance specification; if applicable, certification that you have
installed and verified the operational status of equipment by your compliance date for each bypass
line that meets the requirements of Option 2,3, or 4 in $63.1569 and what equipment you installed;
identification of the operating limit for each affected source, including supporting documentation; if
your affected source is subject to the NSPS, certification of compliance with NSPS emission
limitations and performance specifications; a brief description of perfornance test conditions
(capacity, feed quality, catalyst, etc.); an engineering assessment (if applicable); and if applicable,
the flare design (e.g., steam-assisted, air-assisted, or non-assisted), all visible emission readings, heat
content determinations, flow rate measurements, and exit velocity determinations made during the
Method 22test.
Continuous compliance: Each monitoring option you elect; and identification of any unit or vent for
which monitoring is not required; and the definition of "operating day." (This definition, subject to
approval by the applicable permitting authority, must speciry the times at which a24-hr operating
(21
(3)
day begins and ends.
Associated Vents/Sources: None
(2) Identification of each emission limitation and certification(s):
Emission Limitation:Option 1 under 40 CFR 63. I 568(a)( I ), meet the NSPS
requirements in 40 CFR 60.102a(0(l):- 250 ppmvd SOz at 0o/o Oz per rolling l2-hours
Option l(a) under 40 CFR 63 Subpart UUU Table 29:- 250 ppmvd SOu at 0o% excess Oz
Voluntary requested limit reduction:- 100 ppmvd SO: at 0o/oOz per rolling l2-hours
The voluntary requested limit reduction refers to a notification HFSWCR submitted to the Utah Division
of Air Quality (UDAQ) on May 17 ,2024, requesting a modification to Approval Order DAQE-
AN I 01 2300 57 -23 . HFSWCR requested a voluntary limit of I 00 ppmvd SOz at 0o% oxygen per rolling
12-hour period be added to condition Il.B.l I "Conditions on the Unit l7 SRU/Tail Gas lncinerator" of
HFSWCR's approval order.
This requested voluntary limit will satisfy conditions II.B.3.b and II.B.9.g of HFSWCR's Title V
Operating Permit #l 100013001, issued on May 3,2024, which pertains to the SO: emission limit for the
SRU and associated monitoring requirements of 40 CFR 60 Subpart Ja for Sulfur Recovery Units.
Specifically, the request will align the limit to meet the monitoring specifications of 60.106a(aX I ) which
requires with a CEMS span value of two times the applicable SOr emission limit. Because the current
CEMS configuration also monitors compliance with the FCCU Subpart Ja limits, the lower limit is
needed to align the CEMS span requirements for both process unit's Subpart Ja monitoring requirements.
Certifications:This certifies that an initial perforrnance test was conducted on
the SO: and Oz continuous emission monitors for 4V83 FCC
Wet Gas Scrubber and25Y45 FCC #2 Wet Gas Scrubber. The
emission monitoring systems meets the applicable performance
specifications.
4V83 FCC Wet Gas Scrubber - An initial performance test
RATA was conducted on December 21,2012. The relative
accuracies were calculated to be 0.0% for the SOz monitor and
0.17% for the 02 monitor. These results are below the maximum
allowable relative accuracy limits stated in Specification 2 and 3
in Appendix B to Part 60.
The results of this testing were submitted to UDAQ on January
28.2013.
4V83's CEMS were replaced in May 2021, and a subsequent
initial performance test RATA was conducted on August 20,
2021. T\e relative accuracies were calculated to be L59%o for
the SOz monitor and 2.19%o for the 02 monitor. These results are
below the maximum allowable relative accuracy limits stated in
Specification 2 and 3 in Appendix B to Part 60. The results of
this testing were submitted to UDAQ on October 13,2016.
25V45 FCC #2 Wet Gas Scrubber - An initial performance test
RATA was conducted on September l5-16, 2016. T\e relative
accuracies were calculated to be 2.94% for the SOz monitor and
12.52% for the 02 monitor. These results are below the
maximum allowable relative accuracy limits stated in
Specification 2 and 3 in Appendix B to Part 60. The results of
this testing were submitted to UDAQ on October 13,2016.
(3) Each monitoring option:
Monitoring Option:Option l(a) under 40 CFR 63 Subpart UUU Table 3l:
Continuous emission monitoring system to measure and record
the hourly average concentration of SOz (dry basis), at 0%
excess air and oxygen concentration.
The operating day is from midnight to midnight.
Attached with this notification is a copy of our Operation, Maintenance, and Monitoring Plan for your
review and approval.
EP 2.13 \\'oods (-ross Refinerv Environnrental Procedures Pagelofll
Operation, Maintenance, and Monitoring Plans
Revision:No.3.5 Date: August2024 Next Scheduled Revision: September 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.
Personnel Effected
Operations
Maintenance
Shift Supervisor
Environmental
Procedure/Policy
Operation, Maintenance, and Monitoring Plans
continuous monitoring systems for each affected
SEP _ 3 ?-:C?A
(OMMP) are required for control systems and
source per 40 CFR Part 63.1574(f).
- r TiIffiFPARTMENT oF
e ruvi no u n,tg ru14t- o urgqr
DIVISION OF AIR OUALITY
Affected Sources ProcesVControl Device cMs/cEMs/cPMs
Catalytic 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
nressure)
Catalytic Cracking Unit, CCU (Unit 25)25FCC Scrubber - Wet
Gas Scrubber (WGS)
WGS Vent CEMS (CO)
WGS Vent CPMS ( Flow, Filter
module Dressure differential. L/G)
Catalytic Reforming Unit, CRU (Unit 6)Internal Caustic
Scrubbins Svstem Colorimetric Sampling
Sulfur Recovery Unit, SRUI SRU
Incinerator
WGS
(4V82 or
25FCC
Scrubber)
SOr
rSRU off gas is required to be routed to 4V82 FCC Scrubber (WGS) or 25FCC Scrubber (WGS) at all times (AO#
DAQE-22AN101230057-23 Condition II.B.l0.b TV Permit: I100013001 Condition II.B.3.a.i)
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. lf printed, it should be considered current as of August 27 ,2024 only.
EP 2.13 \\'oods ('ross l{cfincrr !lnvironnrental Procedurcs Page2ofll
Operation, Maintenance, and Monitoring Plans
Revision:No.3.5 Date: August2024 Next Scheduled Revision: Scptember 2025
Catalytic Crackine Units
o Process and control device parameters to be monitored for each FCCU, along with
establ i shed operating I imits (63 . I 57 4(I)(2 )(i )).
Source Limit option Procesvconrol Monitored Parameters Established Operating
Limits
CCU Unit
4
Option I under 40 CFR
63. I 564(a)( I )(i), comply
with the 1.0 lb per 1000
lbs of coke bum-off
limit. Also subject to
AO# DAQE-
AN101230057-23 and
CD (Consent Decree)
limit of 0.50Ib per 1000
lbs coke burn-off limit.
AMP,40 CFR
105(a)( I ), 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
1565(bXl), Continuous
emission monitoring
system (CEMS) to
measure and record the
concentration by volume
(dry basis) of the CO
emissions from each
catalyst regenerator
vent.
Option I under 40 CFR
1565(a)(lXi), 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 9.2 inches HzO2 I
hour averase
Filter Modules Pump
Discharge Pressure
- 66.0 psig2l-hour
average
CO < 500 ppm l-hour
average
This environmental procedure is maintained online. If printed, it should be considered currcnt as of August 27 ,2024 only
EP 2.13 \\'oods ('ross Relirrerv llrrvironnrcntal Proccdures Page3ofll
Operation, Maintenance, and Monitoring Plans
Revision:No.3.5 Date: August2024 Next Scheduled Revision: Septernber 2025
Option I under 40 CFR
63.1 56a(a)( l )(ii),
comply with the 0.5 lb
per 1000 lbs ofcoke
burn-off limit.
40 CFR 60.102a(cX2Xi-
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.
Unit
25
WGS 25FCC
Scrubber
Inorganic HAP (PM)
< 0.50 lb/1000 lb coke
burned (filterable)
< 0.60 lb/1000 lb coke
burned (filterable +
condensable)
Filter Module Pressure
Differential
2 15.0 inches H2O3-
Liquid to Gas Ratio < O.I9 GPMA4SCFH
< 500 ppm l-hour
2f'CCUt 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 parameters
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 (63.1 57 4(I)(2Xiii)).
Source Parameters Monitorine 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-
I 658)
CO Continuous monitor on WGS outlet (4AI- I 3 l3A)
Oz Continuous monitor on WGS outlet (4AI- l3 l3C)
COr Continuous monitor on WGS outlet (4AI-3032)
Unit
25
Flow Rate Continuous monitor on WGS outlet (25FI4305)
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)
Ot Continuous monitor on WGS outlet (25AI-3314)
COz Continuous monitor on WGS outlet (25AI-3018)
This environmental procedure is maintaincd online. lf printed, it should bc considered current as of August 21 ,2024 only.
EP 2.13 \\ oorls ('ross ltellnrrr []rtr ironntt'tttal l)rocctlurcs Page4ofll
Operation, Maintenance, and Monitoring Plans
Revision:No.3.5 Date: August2024 Next Scheduled Revision: September 2025
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.
R, = K'Q,(VICO. +%CO) + RtQ,- KrQ,lVoCOtZ) +YoCOz +WOi+ KtQq('ZrO*) @q 1)
where:
& : Coke burn-off rate, lb/hr;
Q.: Volumetric flow rate of exhaust gas ftom catalyst regenerator before
adding air or gas streams, dscflmin.
Q, : Volumetric flow rate of air to catalytic cracking unit catalyst
regenerator, as determined from instruments in the central control
room, dscf/min;
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);
ohOt : 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. I 303 (lb-min)/(hr-dsc0;
K: : Material balance and conversion factor, 0.0062 (lb-min)/(hr-dscf-%);
Qu*y : Volumetric flow rate of oxygen-enriched air stream to regenerator, as
determined from instruments in the catalytic cracking unit control
room, dscf/min
o O*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)(2)(iv)).
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(f)(2Xv)).
This requirement is not applicable, pH strips are not used.
This environmental p()cedure is maintained online. If printed, it should be considercd current as of August 27 ,2024 only .
EP 2.13 \l'oods ('ross Refinerv Environnrental Procedures Page5ofll
Operation, Maintenance, and Monitoring Plans
Revision:No.3.5 Date: August2024 Next Scheduled Revision: September 2025
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(0(2Xvii)).
The alternative procedures cannot be employed because a WGS
o Monitoring schedule, including when each affected source is or is not monitored (e.g.,
during the coke burn-off, regenerati on process) (63 . I 57 4(I)(2 )(vi i i )).
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 system (63.1574(f)(2Xix)).
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 ooeratins
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- I 3 13) when CCU
and WGS are ooeratins
Oz Continuous monitor on WGS outlet (4AI- I 3 l3C) when
CCU and WGS are operatins
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 ooeratinp
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 ooeratins
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 ooeratins
Thisenvironmentalprocedureismaintainedonline. Ifprinted,itshouldbeconsideredcurrentasofAugust2T,2024only.
EP 2.13 \\'oods Cross Refinerv Environnrental l)rocedures Page6ofll
Operation, Maintenance, and Monitoring Plans
Revision:No.3.5 Date: August2024 Next Scheduled Revision: September 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
maintenance (63. I 57a(0(2Xx)).
o If you use a fixed-bed gas-solid adsorption system 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 specifo 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 burn-off). If
the HCI concentration of the adsorption system exhaust gases is above the operating limit
when measured at any time, the adsorption bed must be replaced within 24 hours or
before the next regeneration cycle, whichever is longer (63.1574(I)(2Xxi)).
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 Turnaround
Every 5 years and as
scheduled by the
Turnaround grouo
Monitoring Systems
WGS Vent Flow CPMS
The procedures for monitoring devices are overseen bv
WGS Filter Module Pressure
Differential CPMS
WGS Filter Modules Pump
Discharse 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
This environmental procedure is maintained online. If printed, it should be considered current as of August 27 ,2024 only .
EP 2.t3 \\'oods Cross Refinerl Environnrental Procedures PageTofll
Operation, Maintenance, and Monitoring Plans
Revision:No.3.5 Date: August2024 Next Scheduled Revision: September 2025
purging prior to uncontrolled releases (i.e., during controlled purging 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
(63.1s74(f)(2Xxii)).
This requirement is not applicable, this applies only to CRU's.
Catalytic Reforming Unit
o Process and control device parameters to be monitored for the CRU, along with
establ i shed operating I im its (63 . I 57 4(f)(2 X i ) ).
o Procedures for monitoring emissions and process and control device operating parameters
for each affected source (63.1574(f)(2xii).
Source Limit Option ProcesdControl
Device Monitored Parameters Established Opcrating
Limits
CRU
Option I under 40
CFR
63.1 566(aX l ),
vent emissions to
a flare during
initial catalyst
deoressurins.
North and South
Flares
Presence of flame in flare Present
Absence of visible emissrons
from flare VE<5min.in2hours
Under 40 CFR
1567(a)(l), reduce
HCI emissions to
30 ppmv dry,
corrected to 37o
oxvsen.
Internal Caustic
Scrubbing System HCI concentration 27 ppm by colormetric
tubes
Source LimitOption ProcesdControl
Device Monitored Parameters Monitoring Procedure
CRU
Option I under
63.1566(b)(l), 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 (66AI-31 l7
and 66AI-3 I l8)
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 bum-off.
Internal Caustic
Scrubbing System HCI concentration
Colormetric tube samples
every 4 hours during coke
burn-off/catalyst
regeneration
Thisenvironmentalprocedureismaintainedonline. Ifprinted,itshouldbeconsideredcurrentasofAugust2T,2024only.
EP 2.t3 \\'oods ('ross Re[inerl ]lnvironntenlaI I)rocedures PageSofll
Operation, Maintenance, and Monitoring Plans
Revision:No.3.5 Date: August2024 Next Scheduled Revision: Septembc'r 2025
o 63.1574(0(2xiii) through 63.1574(I)(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 internal scrubbing system (i.e., no add-on control device) when using a
colormetric tube sampling system, including procedures for correcting for pressure (if
appl i cabl e to the sampling equipment) (63 . | 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 l2 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. I 5 74(f)(2 Xviii)).
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
maintenance (63. I 57a(fl(2)(x)).
Source Limit Option ProcesVControl
Device Monitored Parameters Monitoring Schedule
CRU
Option I under
63.1566(b)(l), 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 l7
and 66AI-31 l8) during
deoressurins and oursinp
Absence of visible
emissions from flare
Continuously during
deDressurins and pursing
Under 40 CFR
1567(b)(l), use
colormetric tube
sampling to monitor HCI
emissions during coke
burn-off.
Intemal Caustic
Scrubbing System HCI concentration
Colormetric tube samples
every 4 hours during
c oke burn-o ff/c atalyst
regeneration
This environmental procedure is maintained online. If printed, it should be considered current as of August 21,2024 only.
EP 2.13 \\'oods ('ross Refinerv Environnlental Procedures Page9ofll
Operation, Maintenance, and Monitoring Plans
Revision:No. 3.5 Date: August2024 Next Scheduled Revision: September 2025
Maintenance Procedure Schedule
Source CRU
Turnaround
Every 5 years and as
scheduled by the
Tumaround srouo
Regeneration
Every 12 to 18 months and
as scheduled by the
Turnaround group
Control Devices
Internal Caustic Scrubbing
System Inspection At regeneration
North and South Flares lnspection
Every 5 years and as
scheduled by the
Turnaround group
Monitoring Systems Flare Pilot Monitor Inspection
Regular maintenance
according to manufacturer
specifications.
o 63.1574(f)(2Xxi) and 63.1574(f)(2\(xii) do not apply to the CRU.
Sulfur Recovery Unit
o Process and control device parameters to be monitored for the SRU, along with
establ i shed operating I imits (63 . | 57 4(f)(2 )(i ) ).
tSRU off gas is required to be routed to 4V82 FCC Scrubber (WGS) or 25FCC Scrubber (WGS) at all times (AO#
DAQE-22AN101230057-23 Condition II.B.l0.b TV Permit: I 100013001 Condition II.B.3.a.i TV Permit:
I 100013001 Condition II.B.3.a.i)
o Procedures for monitoring emissions and process and control device operating parameters
for each affected source (63.1574(I)(2Xii)).
Source Process/Control
Device Monitored Parameters Monitoring Procedures
Source Limit Option ProcesVControl
Device Monitored Parameters Esablished Operating
Limits
SRUI
Subject to 40 CFR 60
Subpart Ja. Complies
with 40 CFR
60.102a(b)(3) forFCC
SOu emissions due to
SRU off gas being routed
to FCC wet qas scrubber.
WGS (4V82 or
25FCC
Scrubber)
SOz
100 ppmv dry (0%
excess air) l2-hour
rolling average
This environmental procedure is maintained online. If printed, it should be considered current as of August 27 ,2024 only.
EP 2.13 \\'oods ('ross Refinerl L,nvironmcntal Proccdures Page l0 of I I
Operation, Maintenance, and Monitoring Plans
Revision:No.3.5 Date: August2024 Next Scheduled Revision: September 2025
SRU'WGS (4V82 or
25FCC Scrubber)SOu
Continuous monitor on
WGS outlet (4AI-1313B
and 25AI-3313)
I SRU off gas is required to be routed to 4V82 FCC Scrubber (WGS) or 25FCC Scrubber (WGS) at all times (AO#
DAQE-22AN101230057-23 Condition II.B.l0.b TV Permit: I 100013001 Condition II.B.3.a.i)
o 63.1574(f)(2xiii) 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. I 5 74(0(2Xviii)).
SRU off gas is required to be routed to 4V82 FCC Scrubber (WGS) or 25FCC Scrubber (WGS) at all times (AO#
DAQE-22AN101230057-23 Condition II.B.l0.b TV Permit: I 100013001 Condition II.B.3.a.i)
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 systan needed to
meet applicable requirements for the system (63.1574(I)(2Xix)).
The CEMS (SOz) will 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
Environmental Department contains these procedures. In addition, procedures related to
calibrations, and adjustments are maintained and recorded by the I/E group.
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
maintenance (63. I 57a(0(2Xx)).
Source ProcesVControl
Device Monitored Parameters Monitoring Schedule
SRUI WGS (4V82 or
25FCC Scrubber)SOz
Continuous monitor on WGS outlet
(4AI-l3l38 and 25AI-3313) while
SRU is operatins
This environmental procedure is maintained online. lf printed, it should be considered current as of August 21,2024 only.
EP 2.13 \\'oods (-ross Refinerr' 1)rvironnrental Procedures Page l1 ofll
Operation, Maintenance, and Monitoring Plans
Revision:No.3.5 Date: August2024 Next Schedulcd Revision: Septernber 2025
Maintenance Procedure Schedule
Source SRU Turnaround
Every 3 years and as
scheduled by the
Turnaround qrouD: or
Waste Heat Boiler
inspection every 3 years and
as scheduled by the
InsDections group.
Control Devices WGS Turnaround
Every 5 years and as
scheduled by the
Turnaround srouo.
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)(2)(xi) 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 Perforrnance 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
uteu orpnRIMENT Ol
sEP - 3 2A2,\
__l
DIVISION OF AIR OUALITY
Thiscnvironmental procedureismaintainedonline. lfprinted,itshouldbeconsideredcurrentasofAugust2T,2024only.