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Home My WebLink AboutDAQ-2025-000393Chcvronv July 15,2024 CERTIFIED MAIL RETURN RECEIPT NO. 7018 0680 0001 4890 0369 Mr. Bryce Bird Director, Division of Air Quality Department of Environmental Quality P.O. Box 144820 195 North 1950 West Salt Lake city, uT 84114-4820 Refinery NESHAP I't Half Semiannual Report for2024 - Equipment Leaks Chevron Products Co., Salt Lake Refinely Dear Mr. Bird: In compliance with the reporting requirements of 40 CFR Part 63, Subpart CC, the following information constitutes the semiannual report under $63.655(dXl) applicable to Chevron Products Company's Salt Lake Refinery. This report also contains the information required per the Chevron U.S.A. Inc. Consent Decree (No. C 03-04650 CRB), Paragraph 97 (c), which was entered on June 27,2005. I certifo under penalty of law that all information contained in the report is truthful and accurate and is a complete record of all events that occurred during the period. Please contact Tony Pollock at (801) 539-7162 for additional information regarding this report. Sincerely. f 'io1'4 Troy Tortorich Troy Tortorlch Refinery Manager Chevron Products Company Salt Lake Refinery 685 South Chevron Way North Salt Lake, UT 84054 rel (801) 539-7200 [,TAH DEPARTMENT OF EW]RONMENTAL OI.IAUTY JUL 22 ?O?4 DIVTSION OF AIR QUALITV REVIEWEDInitials: Date: August 19, 2024Compliance Status: OKFile #: 10119 (B2) Mr. Bryce Bird Departnrent of Environmental Quality luJy 15.2024 Page 2 of 12 Reporting Period Stafi Repofting Period End January 1,2024 lune 30.2024 Number of Subpart CC Leakinq Valves: 40 CFR 60.487a(cX2xi) (500 ppm leak definition) Process Unit January February March April May June Alkv 0 0 0 0 0 0 Amine 0 0 0 0 0 0 Amine II 0 0 0 0 0 0 Coker 0 0 0 0 0 Crude 0 0 0 0 0 0 FCC 0 0 0 0 0 0 FVR 0 0 0 0 0 0 HDN 0 0 0 0 0 HDS 0 0 0 0 0 0 Isom 0 0 0 0 0 0 Jet Treater 0 0 0 0 0 0 LPG 0 0 0 0 0 0 Reformer 0 0 0 0 0 Tank Field 0 0 0 0 0 4 TCLR 0 0 0 0 0 0 VGO 0 0 0 0 0 0 Number of Subpart CC Leakinq Pumps: 40 CFR 60.487a(c)(2Xiii) Process Unit January February March April May June Alkv 0 0 0 0 0 I Amine 0 0 0 0 0 0 Amine II 0 0 0 0 0 0 Coker 0 0 0 0 0 Crude 0 0 0 I 0 l FCC 0 0 0 0 0 0 FVR 0 0 0 0 0 0 HDN 0 0 0 0 0 I HDS 0 0 0 0 0 0 Isom 0 0 0 0 0 0 Jet Treater 0 0 0 0 0 0 LPG 0 0 0 0 0 0 Reformer 0 0 0 0 0 0 Tank Field 0 0 0 0 0 I TCLR 0 0 0 0 0 0 VGO 0 0 0 0 0 Mr. Bryce Bird Department of Environmental Quality luly 15,2024 Page3ofl2 Number of Subpart CC Leakins Compressors: 40 CFR 60.487a(cX2Xv Process Unit January February March April May June Alkt 0 0 0 0 0 0 Am ne 0 0 0 0 0 0 Am ne II 0 0 0 0 0 0 Coker 0 0 0 0 0 0 Crude 0 0 0 0 0 0 FCC 0 0 0 0 0 0 FVR 0 0 0 0 0 0 HDN 0 0 0 0 0 0 HDS 0 0 0 0 0 0 Isom 0 0 0 0 0 0 Jet Treater 0 0 0 0 0 0 LPG 0 0 0 0 0 0 Reformer 0 0 0 0 0 0 Tank Field 0 0 0 0 0 0 TCLR 0 0 0 0 0 0 VGO 0 0 0 0 0 0 Number of Subpart CC Leaking Valves, Pumps and Compressors not repaired as required by 60.482-1a(dxl),60.482-2a(c)(1) and 60.482-3a(gXl) after detection: 40 CFR 60.487a(c)(2)(ii), (iv) and (vi). Process Unit January February March April May June Alkv 0 0 0 0 0 0 Amine 0 0 0 0 0 0 Amine II 0 0 0 0 0 0 Coker 0 0 0 0 0 0 Crude 0 0 0 0 0 0 FCC 0 0 0 0 0 0 FVR 0 0 0 0 0 0 HDN 0 0 0 0 0 0 HDS 0 0 0 0 0 0 Isom 0 0 0 0 0 0 Jet Treater 0 0 0 0 0 0 LPG 0 0 0 0 0 0 Reformer 0 0 0 0 0 0 Tank Field 0 0 0 0 0 0 TCLR 0 0 0 0 0 0 VGO 0 0 0 0 0 0 Mr. Bryce Bird Deparlment of Environmental Quality July 15,2024 Page 4 of 12 Subpart CC components on the Delay-of-Repair Listing (during the reporting period; includes components that have been repaired and removed from the Delay-of-Repair Listing): 40 CFR 60.487a(cX2Xxi) Process Unit Tag No.Description Type Date of Orisin Reason(s) Delayed HDN P7r 030A P7l030A Seal-Frac Reflux Pump Pump 0611012024 Equipment is isolated from the process and does not remain in VOC service. Alky P3600r P-36001 Alkine flush pump Pump 0611012024 Equipment is isolated from the process and does not remain in VOC service. Mr. Bryce Bird Department of Environmental Quality Iuly 15,2024 Page 5 of12 40 CFR 60.487a(c)(3) Dates of process unit shutdowns which occurred within the reporting period Process Unit Januarv Februarv March Aoril May June Alky 3t3-3n3 slt2-5117 6t26-6128 Amine Amine II Boiler Coker 419-4125 Crude 3124-4121 FCC FVR HDN I /t 6-t lt9 4nt-4122 HDS 3t29-3t31 4lt-4122 Isom I lt 6-r l17 2t20-2t22 314-3129 4llt-4130 sll -517 , 5lt3-5118 617-619, 6ll8-6120 Jet Treater LPG Reformer 4t9-4121 Sulfur Tankfield TCLR VGO 612-6/12 Mr. Bryce Bird Department of Environmental Quality July 15,2024 Page 6 of 12 Process Units or Equipment for which revisions to the initial semiannual report information have occurred during the reporting period: 40 CFR 60.a87a(c)(4) Process Unit Number of Subpart CC GV/LL Valves subject to 40 CFR 60 Subpart YVa monitorins rules Number of Subpart CC LL Pumps subject to 40 CFR 60 Subpart Wa monitoring ruIes Number of Subpart CC Compressors subject to 40 CfR 60 Subpart Wa monitoring rules Alkv I 159 l8 0 Amine 44 0 0 Amine II 47 0 0 Coker 8s3 l3 0 Crude I 535 t4 0 FCC 1678 23 7 FVR 322 5 0 HDN 404 5 0 HDS 296 2 0 Isom 20 2 0 Jet Treater ll 0 0 LPG 9 I 0 Reformer 618 J 0 Tankfield 2972 64 0 TCLR 184 2 0 VGO 413 6 0 Mr. Bryce Bird Department of Environmental Quality luly 15,2024 Page 7 of 12 Prior to entry into the Consent Decree, Chevron had irnplemented provisions under the $60.483-2(b)(3) "Alternative standards for valves - skip period leak detection and repair" rule in some process units. Initial implementation of $60.483-2(bX3) monitoring occurred in the 4th quarter of 2003. Chevron is now conducting skip period monitoring based upon the "sustainable Skip Period Monitoring Program" in Appendix K of the Consent Decree, which has instituted enhanced rules for skip monitoring to be used in lieu of $60.483-2(b)(3) rules. The following table reports information required under the Consent Decree paragraphs 97(c)(i), (ii), (iii), iv) and (v Process Unit - E'E 3€ g. 9E E,E€Eo'= oEE Tz- ah(l):e*r;E> E(l)!? oAV-- -at6.iEE E =iA.EE E2 (l)l.= " EEE tEsz PE.!*" f60EL J oXE;Obi bEJEEtr> 6za 8.lsr6! 'i aJ EEE. EA, tE=z a0Etr4E A6EaQ.-lo rF.r lnQ o2YL9Lr€gE> Eza oboEtr EE=aE6 EEEl)o.s6YZ0r Alkv Feb: Mal 42 of 42 5225 9 s262 l5 Ausust Am ne Julv 3 of 3 0 0 )0 Julv Am ne II Jan; April 2 of2 433 0 432 2 July Boiler Plant Jan: April 5 of 5 376 4 369 2 Julv Coker April 30 of30 r80 0 1499 8 Aoril Crude Juh 6 of 6 4 0 41 0 Julv FCC March 45 of 45 3043 4 3l I March FVR Man Jun 14 of 14 720 0 725 0 Seotember HDN Anr 12 of 12 J 0 967 J Aoril HDS January; July 20 of20 1324 t4 128 I July ISOM Mar: Jun l4 of l4 804 9 788 I Seotember Jet Treater Jan: Aoril 0 of 0 ll 0 ll 0 Julv LPG Jan: Apr l9 of l9 I 191 5 1t7 t I August Reformer Febl May 50 of 50 2393 29 2379 5 Julv Sulfur October lof I 46 46 0 Julv TCLR Jan: April 0 of 0 167 0 r65 0 Julv Tankfield June 38 of38 8 0 317 4 l0 June VGO October 28 of28 4 29 0 October Mr. Bryce Bird Department of Environmental Quality July 15,2024 PageSofl2 The following table reports information required under the Consent Decree paragraphs 97(cXii) and (iii) Process Unit Number of Pumps Monitored in 1'r Ouarter Number of Pumps Leaking in I'tQuarter (2000 nom) Number of Pumps Monitored in 2odOuarter Number of Pumps Leaking in 2od Quarter(2000 oom) Alkv 35 0 36 2 Amine 0 0 0 0 Amine II 0 0 0 0 Boiler Plant 0 0 0 0 Coker l3 l3 0 Crude t6 0 l6 2 FCC 30 0 30 2 FVR 5 0 5 0 HDN 5 0 5 I HDS 2 0 2 0 ISOM 8 0 8 I Jet Treater 0 0 0 0 LPG 7 7 0 Reformer 9 0 9 I Sulfur 0 0 0 0 TCLR 2 0 2 0 Tankfield 6l 0 62 I VGO 6 0 6 I The following table reports information required under Consent Decree paragraph 97(c)(vi): All facilitv components on the Delav of Repair List (as of June 024 Comoonent No.Tvne Unit Date of Delav Description P3600 I Pump Alky 6t2512024 Equipment is isolated from the process and does not remain in VOC service P360978 Pump Alkv 6t25t2024 Equipment is isolated from the process and does not remain in VOC service Mr. Bryce Bird Department of Environmental Quality July 15,2024 Page9ofl2 The following table reports information required under Consent Decree paragraph 97(cXvii): Initial repair attempts for valve readings above the action level (100 ppm) not completed within 5 d The follorving table reports information required under Consent Decree paragraph 97(c)(ix): 90 Corrections to Prior Reporting: This inforrnation is corrective to information contained within l't Half 2023 Subpart GGGa semiannual reporting. As per requirements at 60.482-2athe following 1l pumps in the tank field unit were inadvertently marked out of service on 61512023. They were not monitored again until 912612023. Monitoring is required monthly as per 60.482-2a(a)(l). P61216 P6t274 P6l28l P61285 P61286 P6128',1 P61288 P61289 P61290 P6t297 P61333 The following is corrective to information contained within 2d Half 2023 Subpart GGGa semiannual reporting. As per requirements at 60.482-7(a)(2), the following 8 valves in the Reformer unit missed follow up monitoring after the initial monitoring for new components. Initial monitoring was completed in August. The components were placed out of service on September l5'h before they were able to be monitored. Follow up monitoring has been completed as appropriate for components brought back in service. For remaining components, follow up monitoring will be completed once brought back in service. 3370 33'74 3371 3375 33',72 3376 3373 3377 a Comoonent No.Tvpe Unit Date of Orisin Descriotion None to report The follorving table reports information required under Consent Decree paragraph 97(c)(viii): Drill and TaD" Repairs (>50,000 ppm) not completed with Ln 30 Component No.Type Unit Date of Oriein Descrintion None to reoort Drill and Tap" Repairs (10,000 to not completed within ComDonent No.Tvoe Unit Date of Orisin Descrintion None to reDort Mr. Bryce Bird Depaft ment of Environmental Qualitv July 15^ 2024 Page l0of12 This information is corrective to the information contained within 2'd Half 2023 Subpart GGGa semiannualreporting. As per requirements at 60.482-7a (a)(l), the following 3 valves missed monitoring because they were put out of service on 711412023 before we could monitor them. Follow up monitoring has been completed as appropriate for components brought back in service. For remaining components, follow up monitoring will be completed once brought back in service. 182 r83 184 This information is corrective to information contained within 2d Half 2023 Subpart GGGa semiannual reporting. As per 60.482-7a(axl)the following4 valves in the Alky unitwere placed ouf of service before we were able to monitor them for the month of November 2023. Follow up monitorirtg has been completed as appropriate for components brought back in service. For remaining components, follow up monitoring will be completed once brought back in service. 4305 7301 4306 5066 Internal Audit Findinss: This information is findings that occurred during an internalChevron Audit in September 2023.The following citations fall under Subpart GGGa requirements. l. Citation $60.482-6a, Open-Ended Lines: During the field review of the Isom and Coker on 9l1l/2023 and9ll212023. seven instances of uncontrolled Open-Ended Lines were found. Identification and Corrective Actions: Tag# 732 - closed open valve(lsom) 9/ll Tag# 382 - PIug added(lsorn) 9/l I Tag # 413 - Plug added(Coker) 9112 'l'ag# 496 - Cap was added(Coker) 9l12 Tag# 34 - 3/4" closed upstream valve(Coker) 9/12 Tag # 37 - 314" case drain on P7006A Plug added (Coker)9/l2 Heavy liquid case drain P7002A-PIug added (Coker) 9112 2. Citation $60.482-7a. Overlooked Components: During the field review, components that are in VOC service but not captured in the LDAR Program were found. Identification and Corrective Actions: Overlooked components in the VGO and Coker have been identified. tagged in the field, added to Sky Bridge database, and monitored on 09/l 412023. vco-1553. t554-9114 Coker- 1346, 1347, 1348. 1355,1357. 1358 and 1362 9113. Mr. Bryce Bird Department of Environmental Quality luly 15,2024 Page ll of12 3. Citation g60.482-7a(a)(2), Missed Initial Monitoring: Newly installed valves missed a second successive monthly inspection before beginning routine quarterly monitoring. Identification and Corrective Actions: Performed successive monitoring for 35XVl43 and 35XVl44 on lll2l12023 and 1211212023. Verified scheduling in Skybridge database is correct for future monitoring event on 35XV143 and 35XV144. 4. Citation g60.452-7a(c)(2), Post Repair Follow-up Inspection: One (l ) leaking valve missed the first and second month post-repair follow-up inspections. Identification and Corrective Actions: Performed two months of consecutive monitoring for VOC tag 5700 on lll8l2023 and 12/12/2023. Changed the leak definition in Skybridge database from 500PPM to 499PPM under 60GGGa rule. This will prevent another missed monitoring post follow-up exercise. Mr. Bryce Bird Department of Environmental Qual ity July 15,2024 Page l2of12 CC: CERTIFIED MAIL RETURN RECEIPT NO.7OI8 0680 OOOI 4890 6699 Director, Air Enforcement Division Office of Regulatory Enforcement U.S. Environmental Protection Agency MailCode 2242-A 1200 Pennsylvania Ave., N.W. Washington, D.C. 20460-000 I CERTIFIED MAIL RETURN RECEIPT NO.7OI8 0680 OOOI 4890 6705 Air Director Technical Enforcement Program MailCode SENF-T Office of Enforcement, ComPliance & Environmental Justice US EPA Region 8 1595 Wynkoop Street Denver, CO 80202-1129 CERTIFIED MAIL RETURN RECEIPT NO. 7OI8 0680 OOOI 4E9O 0376 Director, Air Enforcement Division Office of Regulatory Enforcement c/o Matrix New World Engineering Inc. 26 Columbia Tpke Ste 200 Florham Park, N.J. 07932-2213 Attn: Norma Eichlin CERTIFIED MAIL RETURN RECEIPT NO.7OI8 O6EO OOOI 4890 O3E3 Marina V. Thomas, Utah Assistant Attorney General Environmental/Health & Human Services Division Utah Attorney General's Office 195 North 1950 West P.O. Box 140873 Salt Lake ciry, uT 841l4-0873 Electronic Copies: Eeler.pslrcI'gEpa€q! shepherdson. tnelan ie@,epa.gov IIacki?llnrrwe'com REVIEWEDInitials: Date: August 19, 2024Compliance Status: OKFile #: 10119 (B2)