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Home My WebLink AboutDAQ-2025-000318UTAH DEPAHTMENT OF ENVIRONMENTAL OUALITY,.tttF$nclon iil l,Y May 28,2024 Mr. Bryce Bird, Director Attn.: Dave Beatty, operating Permits Program Manager cERTtFtED MAIL: 7022 0410 0002 3551 7063 Harold Burge, Major Source Compliance program Manager Division of Air Quality Utah Dept. of Environmental euality 195 North 1950 West Salt Lake City, Utah 8411G Environmental Protection Agency, Region Vlll CERTIFIED MA|L: 7022 0410 00O2 3551 7094 Office of Enforcement, Complia nce a nd Environmenta I J ustice (mailcode SENF) 1595 Wynkoop Street Denver, CO 8O202-L129 RE: HF Sinclair Woods Cross Refining LLC- Title V Operating permit 11qrO13OOl Schedule for Submission of Title VAnnual Compliance Certification & Semi-Annua! Compliance Reports Dear Mr. Bird: The purpose of this correspondence is to clarifli HF sinclair woods cross Refining LLC (HFswcR) plans to comply with the obligation to submit its annual compliance certifications and semi-annual monitoring reports. HFSWCR was issued a Title V operating permit on May g,2O24.The permit specifies an annual certification is due on May 31, 2024 and that date of every calendar year thereafter. The permit does not expressly identifo the period covered by the certification. The permit also requires that HFSWCR submit semi-annual monitoring reports "every six months" but does not specifo the period covered by the semi-annual monitoring reports. Based on a review of permits issued and discussions with UDAQ staff, we understand that it is typical for a source to have a reasonable period of time following the end of the compliance period covered by the annual compliance certification to submit the certification. This typically appears to be at least a month. This practice appears to be consistent with the approach taken by other states and is consistent with UDAQ's own guidance on Title V reporting which provides that UDAQ "has chosen not to define exactly when the six-month periods [for semi-annual monitoring reports] occur to allow sources to adjust their reporting schedule to their existing practices and schedule when possible."l As the guidance explains, ,,it is impossible to report data through a certain date (for example Dec 31) and submit that report by the same date. A period of time is necessary to collect, analyze and report data. lt can typically take 30 days 1 UoeQ Title V guidance memorandum , Title V Six-Month Monitoring Reports (June 30, 201g). HF Sinclair Woods Cross Refining LLC 1070 W. 500 S, West Bountifut, UT 84087 801 -299-6600 | HFSinclair.com REVIEWEDInitials: Date: August 7, 2024Compliance Status: OKFile # 10123 (B2)Comment: It was agreed that this letter would be revised to reflect changes in annual compliance certification and monitoring report submittals. (or in some caset longer) for a source to accomplish the necessary tasks to submit a report following the cut-off date for the data."2 Accordingly, HFSWCR proposes to define the compliance periods for reporting purposes as follows:o Compliance period for annual compliance certification: May l-April 30 (to be filed NLT May 31 annually).o Semi-annualmonitoringreports: o 1$ reporting period: May l-Oct. 31 (to be submitted NLT November 30 annually).o 2nd reporting period: Nov. l-April 30 (to be submitted NLT May 31 annualy). These dates will provide HFS with approximately one month following the conclusion of each reportingperiod to complete the certifications/reports and willensure complete reporting for all periods of time commencing with the May 3,2024 issuance date for the Title V operating permit. Furthermore, because HFSWCR was not subject to the Title V operating permit until the May 3,2024 issue date, no reporting is required for the annuat compliance certification otherwise due on May 31, 2024; that is, there was no operation under the Title V permit for May t,2OZ3 through April 30,2024. Additionally, HFSWCR's first semi-annuat monitoring report will be due on Novembei 30,2024. lf you have any questions or need additional information, please contad Eric Benson at (go1) 299-662g or email eric.benson@hfsincla ir.com. ln accordance with Title V Operating Permit provision l.K and UAC R3O7-415-5d, and based on information and belief formed after reasonable inquiry, I certifo that the statements and information in this document are true, accurate, and complete. Sincerely,-l^t- S *-,*)3 Dustin Simmonds Vice President and Refinery Manager cc: E. Benson (r) File 2.5.3 R. Bagherian S. Gokhale D. Simmonds 1 ld.