HomeMy WebLinkAboutDAQ-2025-000425Chevronv
January 29,2024
CERTIFIED MAIL RETURN
RECEIPT NO. 7021 2720 00014083 6869
Troy Tortorich Salt Lake Refinery
Refinery Manager Chevron Products Company
685 South Chevron Way
Salt Lake City, UT 84054
Tel 801 539 7200
Fax 801 539 7130
UTAH DEPARTMEI.JT OF
ENVIRONMENTAL OUALIry
Mr. Bryce Bird, Director
Division of Air Quality
Utah Department of Environmental Quality
195 North 1950 West illVISlON OF AIR QUALITV
P.O. Box 144820
Salt Lake Ciry, UT 84114-4820
Attention: Joe Rockwell
Chevron SaIt Lake Refinery NSPS Subpart Ja - 2"d Half 2023 Periodic Report
Dear Mr. Bird:
In accordance with the reporting requirements of 40 CFR, Part 60, Subpart Ja, this correspondence
constitutes the periodic report required by 40 CFR Section 60.108a(d) applicable to the Chevron Products
Company Salt Lake Refinery (Refinery) flares, fuel gas combustion devices, fluid catalytic cracking unit
(FCCU) and sulfur recovery plants. This submittalcovers the reporting period of July 1,2023 to
December 31,2023.
Below is a summary of discharge events from the Refinery's flares, fuel gas combustion devices, fluid
catalytic cracking unit, and sulfur recovery plants. Attachments I through 4 provide additional
information in accordance with 40 CFR Section 60.108a(d).
I. Interconnected Flares No. 1 and No. 2 System
The interconnected Flares No. I and No. 2 system experienced a total of three events where the flow was
in excess of 500,000 standard cubic feet (scf) above the applicable baseline during a24-hour (hr) rolling
period and/or the emissions of sulfur dioxide (SOz) exceeded 500 pounds (lb) during a24-hr rolling
period. The dates and times of the events are shown in Table I and additional details are provided in
Attachments 1 through 3.
Table 1: Interconnected Flares No. I and 2 Svstem*
Flow
Start End
711312023 5:05 AM 711312023 l2:00 PM
712612023 5:00 PM 712712023 l2:00 AM
SOz
712612023 3:00 AM 712712023 6:00 AM
712812023 4:00 PM 712912023 3:00 PM
*The start time is the first 24-hr rolling average in excess of the applicable limit.
REVIEWEDInitials:Date: Jan 22, 2025Compliance Status:OKFile #: 10119 (B2)
II. Flare No.3
Flare 3 experienced no flow events in excess of 500,000 scf above the baseline during a24-hr rolling
period and no SOz events in excess of 500 lb during a24-hr rolling period.
III. Fuel Gas Combustion Devices (FGCDs)
There were no SOz events of more than 500 lb greater than the amount that would have been emitted if
the hydrogen sulfide (HzS) concentration was equal to the applicable concentration limit.
IV. FCCU
During the reporting period, there were no deviations from the applicable NOx or SOz emissions limits,
though one deviation from the applicable CO emissions limit occurred. Deviations and monitoring
downtime are reported in the quarterly continuous emissions monitoring system (CEMS) report submitted
for purposes of40 CFR 60.7(c) and R307-170-9.
V. Sulfur Recovery Plants: SRU I and SRU 2
There was one SOz discharge event of more than 500 lbs greater than the amount that would have been
emitted if the SOz concentration was equal to the applicable emissions limit. The date and time of the
event is shown in Table 2 and additional details are provided in Attachment 4.
Iahle 2: SRII I
SOu
1112112023 8:00 AM 1112312023 8:00 AM
VI. Alignment with Other Reports
The refinery is subject to additional emissions limits under 40 CFR 60 Subpart Ja which are addressed in
separate reports. For purposes of 40 CFR Section 60.7(c) and Utah Rule R307-170-9, quarterly CEMS
reports are submitted separately via the Utah State Electronic Data Reports. These reports address
monitoring downtime for CEMS are used to demonstrate compliance with the following emissions limits
from 40 CFR 60 Subpart Ja.
Table 3: Emission Limits
Unit Pollutant Limit
Flare no. 1,2, and 3 HzS 162 ppmvd per 3-hr rolline averaqe
FGCDs HzS 162 ppmvd per 3-hr rolling average
60 ppmvd per 365-dav rolline averase
FCCU CO 500 onmvd at DYo Ot oer 1-hr rollins averase
NO-80 ppmvd at 0%6 Oz. per 7-day rol ng average
SOz 50 ppmvd at 0Yo Oz,per 7-day rolling average
25 ppmvd at 0%o Oz per 365-dav rolline averaqe
SRU I and SRU 2 SOz 250 ppmvd atloh Oz per 12-hr rollins averase
Notes:
CO = carbon monoxide
NO, = nitrogen oxides
Oz: oxygen
oomvd = Darts Der million bv volume. drv basis
*r<**r<*
If you have any questions, please contact Lauren Vander Werff at (801) 539-7386 or
LVanderWerffl@chevron.com.
I certiff, based on information and belief formed after reasonable inquiry, the statements and information
in this document are true, accurate, and complete.
Sincerely,
Troy Tortorich
Attachments: Attachment I - Flow Event (Flares No. 1 and No. 2)
Attachment 2 - Flow & SOz Event (Flares No. I and No. 2)
Attachment 3 - SOz Event (Flares No. I and No. 2)
Attachment 4 - SOz Event (SRU l)
cc: CERTIFIED MAIL RETURN RECEIPT NO. 7021 2720 00014083 6876
Bob Gallagher
U.S. EPA Region 8 - Montana Office
l0 West l5s Street, Suite 3200
Helena" MT 59626
REVIEWEDInitials:Date: Jan 22, 2025Compliance Status:OKFile #: 10119 (B2)
F iB - ?- Z0Zt
l.
Attachment I
711312023 - Flow Discharge (Flares No. I and 2)
Description of Event: On July 13,2023, the Refinery flared excess fuel gas to relieve excess
pressure in the system and protect people, equipment, and the environment. The Crude Unit was in
the process of being started up. Operations took immediate action to reduce flow to the flares.
Date, time, and duration of event:
711312023 6:00 AM to l2:00 PM. Total duration = 30 hours (includes the first 23 hours of the first
24-hr period > the limit).
Was the exceedance concurrent with a startup, shutdown, or malfunction of an affected facility
or control system? Yes
The measured cumulative quantity of gas discharged over the discharge duration:
Approximately 939,028 scf
For each discharge greater than 500 lbs SOz in any 24-hour period from a flare, the measured
total sulfur (TS) concentration: N/A
For each discharge greater than 500 lbs SOz in excess of the emissions limit in
60.102a(g)(1)[HzS in excess of 162 ppmv determined hourly on a 3-hour rolling average basisl,
from a fuel gas combustion device, the measured concentration of HzS in the fuel gas: N/A
For each discharge greater than 500 lbs SOz in excess of the allowable limits from a sulfur
recovery plant, either the measured concentration of reduced sulfur or SOz discharged to the
atmosphere: N/A
For each discharge greater than 500 lbs SOz in any 24-hour period, the cumulative quantity of
HzS and SOz released to the atmosphere: N/A
Describe the actions taken, if any, and the steps taken to limit emissions during the discharge:
N/A
Root cause analysis, including a statement noting whether the discharge resulted from the
same root case(s) identified in a previous analysis: N/A
Corrective action analysis as required in 40 CFR Section 60.103a(d), including either a
description of the recommended corrective action(s) or an explanation of why corrective action
is not necessary under Section 60.103a(e): N/A
For any corrective actions required in 60.103a(e), a description ofthe corrective action(s)
completed within the first 45 days following the discharge, and for actions not already
completed, a schedule for implementation, including proposed commencement and completion
dates: See #l l.
If applicable, for each discharge that is the result of a planned startup or shutdown of a
refinery process unit or ancillary equipment connected to the flare, a statement that a root
cause analysis and correction action analysis are not necessary because the Flare Management
Plan was followed: This event occurred during the start-up of the Crude Unit. The Flare
Management Plan was followed, therefore, a root cause analysis and corrective action analysis are
not necessary.
If applicable, for any periods when monitoring data were not available, describe any changes
in operation of the emission control system during the period of data unavailability which
could affect the ability of the system to meet the applicable emission limit: N/A
2.
3.
4.
5.
6.
7.
8.
9,
10.
I l.
12.
13.
UTAHDEHKTMENI ('F
ENVTRoNMENI&_AUALITY
DIVISION OF AIR OUALITY
14.
Attachment 2
712612023 - Flow and SOz Discharge (Flares No. I and 2)
l. Description of Event: On the night of July 25,2023, Refinery Operators reduced feed to the Gas
Recovery Unit (GRU) #2 Deethanizer column (C32206) in order to perform repairs on an associated
reboiler. Instead of reducing the rate to the column, the column was shut down completely, which
resulted in more load on the GRU # I Absorber column (C3 I I 06) than expected. C3 I 106 has less
vapor handling capacity than C32206, so vapors were sent to the relief system through a pressure
relief device when the vapor load was completely on C3 I 106. At the same time Amine Unit #2 was in
shut down mode, reducing the amount of vapor that the relief system could process before impacting
Flare Vapor Recovery (FVR). The increased vapor to the relief system from C3l 106 and the
decreased relief capacity from Amine Unit#2 being shut down overwhelmed FVR, causing increased
flaring at Flares Nos. I and 2. During the event, Operators discovered the increased flow to FVR due
to C31 106, and began starfup of C32206. During the effort to startup C32206, the GRU #2
compressors tripped adding additional flow and SOz to FVR and, thus, Flares Nos. I and 2.
2. Date, time, and duration of event: 712612023 3:00 AM to 712712023 6:00 AM. Total duration : 51
hours (includes the first 23 hours of the first 24-hr period > the limit).
3. Was the exceedance concurrent with a startup, shutdown, or malfunction of an affected facility
or control system? No
4. The measured cumulative quantity of gas discharged over the discharge duration:
Approximately 1,620,47 7 scf
5. For each discharge greater than 500 lbs SOz in any 24-hour period from a flare, the measured
total sulfur (TS) concentration:
Date and Time Flare I TS %Flare 2 TS %
712512023 3:00 0.0002 2.08-19
712512023 4:00 0.0003 2.0E-19
712512023 5:00 0.0003 t.2E-06
712512023 6:00 0.0003 7.1E-06
712512023 7:00 0.0003 4.08-21
712512023 8:00 0.0005 4.0E-21
712512023 9:00 0.000s 4.08-21
7 t25t2023 0:00 0.0006 t.3E-07
712s12023 l:00 0.0006 t.2E-07
7t25t2023 2:00 0.0006 1 .l E-07
7125/2023 3:00 0.0006 5.7E-07
7 t25t2023 4:00 0.0006 1.6E-06
712512023 5:00 0.000s 1.8E-06
712512023 6:00 0.0004 2.tE-06
712512023 7:00 0.0003 2.78-06
712s12023 8:00 0.0002 3.28-06
712512023 9:00 8.7E-05 L8E-06
7/2512023 20:00 5.6E-05 4.0F-07
712512023 21:00 3.0E-05 6.lE-08
712512023 22:00 0.0042 0.0011
7.
8.
Date and Time Flare 1 TS %Flare 2 TS %
712512023 23:00 0.0191 0.0 5l
712612023 0:00 0.0047 0.0 68
7126120231:00 0.00ss 0.0 92
712612023 2:00 0.0202 0.0 t2
712612023 3:00 0.0107 0.0 45
712612023 4:00 0.0053 0.0 76
712612023 5:00 0.004 0.0 85
712612023 6:00 0.0032 0.0 81
712612023 7:00 0.00r 7 0.0 37
712612023 8:00 0.0008 0.0042
712612023 9:00 0.0003 0.0013
712612023 0:00 0.0003 0.0006
7t26t2023 l:00 0.0002 0.0003
712612023 2:00 0.0002 0.0006
712612023 3:00 0.0003 0.0032
712612023 4:00 0.0003 0.0012
712612023 5:00 0.0002 0.0034
7t26t2023 6:00 0.0002 0.0042
712612023 7:00 0.0002 0.004
712612023 8:00 0.0002 0.003
712612023 9:00 0.001 0.0033
712612023 20:00 0.001 3 0.0027
7126/2023 2l:00 0.0003 0.0006
712612023 22:00 0.0003 0.0023
712612023 23:00 0.0002 0.0028
712712023 0:00 0.0002 0.0007
7127120231:00 0.0008 0.0003
712712023 2:00 0.0005 0.0005
712712023 3:00 0.0007 0.0007
712712023 4:00 0.0007 0.0006
712712023 5:00 0.0006 0.0006
7/2712023 6:00 0.0006 0.0006
For each discharge greater than 500 lbs SOz in excess of the emissions limit in
60.102a(g)(1)[HrS in excess of 162 ppmv determined hourly on a 3-hour rolling average basis]o
from a fuel gas combustion device, the measured concentration of HzS in the fuel gas: N/A
For each discharge greater than 500lbs SOz in excess of the allowable limits from a sulfur
recovery planto either the measured concentration of reduced sulfur or SOz discharged to the
atmosphere: N/A
For each discharge greater than 500 lbs SOz in any 24-hour period, the cumulative quantity of
HzS and SOz released to the atmosphere: H2S : 0.16 lbs; SO2 : 1,77 4 lbs
9. Describe the actions taken, if any, and the steps taken to limit emissions during the discharge:
Refinery Operations attempted to restart the compressors before discovering the C3l 106 vapor
handling issue. Once discovered, Operations worked to startup C32206 and then were able to restart
the compressors.
10. Root cause analysis, including a statement noting whether the discharge resulted from the
same root case(s) identified in a previous analysis:
The C32206 was meant to be at reduced rate instead of completely shutting down.
I l. Corrective action analysis as required in 40 CFR Section 60.103a(d), including either a
description of the recommended corrective action(s) or an explanation of why corrective action
is not necessary under Section 60.103a(e):
a. Create a tool for Operations to be able to quickly identifo sources of flow to the relief system.
Provide training on tool at appropriate Operations consoles. Add a hyperlink to the Process
Optimization Dashboard and/or Operations Intranet page.
Start date: 91112023
Projected completion date: 5 I I 12024
b. Add warning to FCC console to confirm manual adjustments on valve greater than l0o/o.
Start date: 91112023
Projected completion date: 5 I I 12024
c. Conduct of Operations shift communications refresh - discuss importance of clear shift
turnover and documenting abnormal conditions.
Start date: 91112023
Projected completion date: 5 I I 12024
12. For any corrective actions required in 60.103a(e), a description ofthe corrective action(s)
completed within the first 45 days following the discharge, and for actions not already
completed, a schedule for implementation, including proposed commencement and completion
dates: See #1 l.
13. If applicable, for each discharge that is the result of a planned startup or shutdown of a
refinery process unit or ancillary equipment connected to the flare, a statement that a root
cause analysis and correction action analysis are not necessary because the Flare Management
Plan was followed: N/A
14. If applicable, for any periods when monitoring data were not available, describe any changes
in operation of the emission control system during the period of data unavailability which
could affect the ability of the system to meet the applicable emission limit: N/A.
Attachment 3
712812023 - SOz Discharge (Flares No. I and 2)
l. Description of Event: On July 28,2023, the Coker Unit wet gas compressor (K70001) tripped on
high amperage. Refinery Operations attempted several times to restart the compressor but were
unsuccessful. After these repeated attempts, the breaker "locked out" for 50 minutes, preventing the
manual restart of the compressor. During this incident, Coker off-gas was routed to the Flare Vapor
Recovery, which was overwhelmed and sent vapors to Flares Nos. I and2. After the compressor
unlocked, it tripped again during a startup attempt. After troubleshooting the compressor with
Refinery Operations and the Maintenance group, low accelerator sync was identified and corrected.
Then the compressor was able to restart.
2. Date, time, and duration of event: 712812023 4:00 PM to 712912023 3:00 PM. Total duration: 47
hours (includes the first 23 hours of the first 24-hr period > the limit).
3. Was the exceedance concurrent with a startup, shutdown, or malfunction of an affected facility
or control system? No
4. The measured cumulative quantity of gas discharged over the discharge duration:
Approximately 1,083,248 scf
5. For each discharge greater than 500lbs SOz in any 24-hour period from a flare, the measured
total sulfur (TS) concentration:
Date and Time Flare 1 TS %Flare 2 TS Yo
712712023 17:00 0.0003 0.0006
71271202318:00 0.0003 0.0006
71271202319:00 0.0003 0.0005
712712023 20:00 0.0003 0.000s
712712023 21:00 0.0003 0.0005
712712023 22:00 0.0003 0.0006
712712023 23:00 0.0003 0.0006
712812023 0:00 0.0003 0.0006
7128120231:00 0.0003 0.0006
7128/2023 2:00 0.0013 0.0006
712812023 3:00 0.0007 0.0007
712812023 4:00 0.0003 0.0008
712812023 5:00 0.0004 0.0019
712812023 6:00 0.001 0.0059
712812023 7:00 0.0008 0.0014
712812023 8:00 0.0006 0.001
712812023 9:00 0.000s 0.0009
7t28t2023 0:00 0.0004 0.0009
7t28t2023 l:00 0.000s 0.0008
712812023 2:00 0.0005 0.0007
7t28t2023 3:00 0.000s 0.0007
712812023 4:00 0.0022 0.0022
712812023 5:00 0.0204 0.0289
712812023 6:00 0.0228 0.0336
Date and Time Flare I TS %Flare 2 TS Yo
71281202317:00 0.0054 0.0107
71281202317:00 0.0007 0.0007
71281202319:00 0.0006 0.0006
712812023 20:00 0.0006 0.0006
712812023 2l:00 0.000s 0.000s
712812023 22:00 0.0006 0.0006
712812023 23:00 0.0006 0.0006
712912023 0:00 0.0006 0.0006
7129120231:00 0.0012 0.0007
712912023 2:00 0.001 0.0007
712912023 3:00 0.0007 0.0008
712912023 4:00 0.0006 0.0007
712912023 5:00 0.0006 0.0007
712912023 6:00 0.0006 0.0007
712912023 7:00 0.0006 0.0007
712912023 8:00 0.0006 0.0007
712912023 9:00 0.0006 0.0007
712912023 0:00 0.0005 0.0007
712912023 l:00 0.0004 0.0007
712912023 2:00 0.0004 0.0006
712912023 3:00 0.0004 0.0006
7 t29t2023 4:00 0.0003 0.0006
712912023 5:00 0.0004 0.000s
6. For each discharge greater than 500 lbs SOz in excess of the emissions limit in
60.102a(g)(1)[HrS in excess of 162 ppmv determined hourly on a 3-hour rolling average basis],
from a fuel gas combustion device, the measured concentration of HzS in the fuel gas: N/A
7. For each discharge greater than 500 lbs SO2 in excess of the allowable limits from a sulfur
recovery plant, either the measured concentration of reduced sulfur or SO2 discharged to the
atmosphere: N/A
8. For each discharge greater than 500 lbs SOz in any 24-hour period, the cumulative quantity of
HzS and SOz released to the atmosphere: H2S:0.062 lbs; SO2: 1,638.8Ibs
9. Describe the actions taken, if any, and the steps taken to limit emissions during the discharge:
Refinery Operations involved the Maintenance group to troubleshoot the compressor and restart it
successfully.
10. Root cause analysis, including a statement noting whether the discharge resulted from the
same root case(s) identified in a previous analysis:
The motor acceleration time was lower than vendor recommendations.
I 1. Corrective action analysis as required in 40 CFR Section 60.103a(d), including either a
description of the recommended corrective action(s) or an explanation of why corrective action
is not necessary under Section 60.103a(e):
Adjust the motor acceleration time to match vendor recommendations.
This action has been completed.
12. For any corrective actions required in 60.103a(e), a description ofthe corrective action(s)
completed within the first 45 days following the discharge, and for actions not already
completed, a schedule for implementation, including proposed commencement and completion
dates: See #l L
I 3. If applicable, for each discharge that is the result of a planned startup or shutdown of a
refinery process unit or ancillary equipment connected to the flare, a statement that a root
cause analysis and correction action analysis are not necessary because the Flare Management
Plan was followed: N/A
14. If applicable, for any periods when monitoring data were not available, describe any changes
in operation of the emission control system during the period of data unavailability which
could affect the ability of the system to meet the applicable emission limit: N/A.
Attachment 4
lll2ll2023 - SOz Discharge (SRU 1)
L Description of Event: On Novemb er 2l , 2023 , Sulfur Recovery Unit # I tripped due to the flame
scanners showing no flame in the incinerator. Once the burner was relit the temperature rapidly
increased and the unit tripped again. The burner was relit again and operations attempted to start up
the unit. However, excess oxygen was unintentionally being added into the system from a valve that
is normal closed and the trim air analyzer failed to transmit operating conditions. The extra oxygen
caused the iron sulfide in the reactor beds to combust and cause high sulfur dioxide emissions. Once
operations discovered the open valve, it was closed.
2. Date, time, and duration of event: 1112112023 8:00 AM to 1112312023 8:00 AM. Total duration =
48 hours (start time is the first l2-hr rolling average >250ppm SO).
3. Was the exceedance concurrent with a startup, shutdown, or malfunction of an affected facility
or control system? No
4. The measured cumulative quantity of gas discharged over the discharge duration:
Approximately 3,765,485 scf
5. For each discharge greater than 500 lbs SOz in any 24-hour period from a flare, the measured
total sulfur (TS) concentration: N/A
6. For each discharge greater than 500 lbs SOz in excess of the emissions limit in
60.102a(g)(1)[HrS in excess of 162 ppmv determined hourly on a 3-hour rolling average basisl,
from a fuel gas combustion device, the measured concentration of HzS in the fuel gas: N/A
7. For each discharge greater than 500 lbs SOz in excess of the allowable limits from a sulfur
recovery plant, either the measured concentration of reduced sulfur or SOz discharged to the
atmosphere: 6,l50lb
8. For each discharge greater than 500lbs SOz in any 24-hour period, the cumulative quantity of
HzS and SOz released to the atmosphere: See #7. HzS is not monitored on the SRU stack.
9. Describe the actions taken, if any, and the steps taken to limit emissions during the discharge:
Refinery Operations called the analyzer group to fix the trim air analyzer. Once the analyzer was
fixed and showed excess oxygen, operations found the open valve. Upon discovery the open valve
was closed.
10. Root cause analysis, including a statement noting whether the discharge resulted from the
same root case(s) identified in a previous analysis:
An open valve allowed excess oxygen to flow into the unit.
I 1. Corrective action analysis as required in 40 CFR Section 60.103a(d), including either a
description of the recommended corrective action(s) or an explanation of why corrective action
is not necessary under Section 60.103a(e):
a. Fix the trim air analyzer.
This action has been completed.
b. Update procedures to include a step to verifi the valve is closed in the field prior to lighting
the burner.
Start date: lll2l12023
Projected completion date: 613 12024
c. Update labeling in the field to improve identification of the correct valve.
Start date: 1112112023
Projected completion date: 4 I I 12024
12. For any corrective actions required in 60.103a(e), a description of the corrective action(s)
completed within the first 45 days following the discharge, and for actions not already
completed, a schedule for implementation, including proposed commencement and completion
dates: See #l l.
I 3. If applicable, for each discharge that is the result of a planned startup or shutdown of a
refinery process unit or ancillary equipment connected to the flare, a statement that a root
cause analysis and correction action analysis are not necessary because the Flare Management
Plan was followed: N/A
14. If applicable, for any periods when monitoring data were not available, describe any changes
in operation of the emission control system during the period of data unavailability which
could affect the ability of the system to meet the applicable emission limit: NiA.
UTAH DEPARTMEf'IT OF
ENVIRONMENTAL QUAUTY
iEB -', ','.'
DIVISION OF AIR OUALITY
REVIEWEDInitials:Date: Jan 22, 2025Compliance Status:OKFile #: 10119 (B2)