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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)