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HomeMy WebLinkAboutDAQ-2025-000426Chevronv Salt Lake Refinery Chevron Products Company 685 South Chevron Way Salt Lake City, UT 84054 Tel 801 539 7200 Fax 801 539 7130 luly 30,2024 CERTIFIED MAIL RETURN RECETPT NO. 7021 2720 0001 4083 707t Mr. Bryce Bird, Director Division of Air Quality Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144820 Salt Lake Ciry, UT B4l14-4920 Attention: Joe Rockwell chevron Salt Lake Refinery NSPS Subpart Ja - r't Harf 2024 periodic Dear Mr. Bird: Report In accordance with the reporting requirements of 40 CFR Part 60 Subpart Ja, this correspondence constitutes the periodic report required by 40 CFR Part 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 January l,Z024to Jun.30,2024. Below is a summary of discharge events from the Refinery's flares, fuel gas combustion devices, fluidcatalytic cracking unit, and sulfur recovery plants. Aftachments I and 2 frovide additional information in accordance with 40 CFR Part 60.108a(d). I. Interconnected Flares No. I and No.2 System The interconnected Flares No. I and No. 2 system experienced a total of two evenls where the flow was in excess of 500,000 standard cubic feet (scf) above the applicable baseline during a24-hour (hr) rollingperiod. The dates and times of the events are shown in Table I and additional details are provided inAttachments I and 2. There were no sulfur dioxide (SOz) events in excess of 500 pounds (lbs) during a24-hr rolling period. Table 1: Interconnected Flares No. I and 2 Svstem* Flow Start End l13l12024l2:10 PM 2/112024 9:00 AM 61271202410:00 PM 612812024 5:00 AM Troy Tortorich Refinery Manager r-)r\./rsroN oF AIR o(JALITY *The start time is the first 24-hr rolling average in excess of the applicable limir 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!b during a24-hr rolling period. Deviations from the hydrogen sulfide (HzS) concentration limit and monitoring downtime are reported separately as described in Section VI below. 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 HzS concentration was equal to the applicable concentration limit. Deviations from the HzS concentration limit are reported separately as described in Section VI below. IV. FCCU During the reporting period, there were no deviations from the applicable nitrous oxides (NOx) or SOu emissions limits. There was a deviation from the carbon monoxide (CO) emission limit. Deviations from emissions limits and monitoring downtime are reported separately as described in Section VI below. V. Sulfur Recovery Plants: SRU I and SRU 2 There were no SOz discharge events of more than 500 lb greater than the amount that would have been emitted if the SOz concentration was equal to the applicable emissions limit. Deviations from emissions limits and monitoring downtime are reported separately as described in Section VI below. VI. Alignment with Other Reports The refinery is subject to additional emissions limits and work practice standards under 40 CFR part 60 Subpart Ja which are addressed in separate reports instead of this report. For purposes of 40 CFR part 60.7(c) and Utah Rule R307-170-9, quarterly continuous emissions monitoring systems (CEMS) reports are submitted separately via the Utah State Electronic Data Reports. These reports address monitoring downtime for CEMS and are used to demonstrate compliance with the following emissions limits from 40 CFR Part 60 Subpart Ja. Table 2: Emission Limits Unit Pollutant Limits Flare no. l. 2. and 3 HzS 162 ppmvd per 3-hr rolline averase FGCDs HzS 162 ppmvd per 3-hr rolling average 60 ppmvd per 365-dav rollins averase FCCU CO 500 ppmvd at 0o/o Oz per I -hr rollins averase NO*80 ppmvd at |Yo Oz per 7-dav rollins averase SOz 50 ppmvd at |Yo Oz. per 7 -day rolling average 25 ppmvd at 0%o Oz. per 365-dav rollins averase SRU I and SRU 2 SOz 250 ppmvd at 0o/o Ot per l2-hr rol ns averase Notes: CO : carbon monoxide NO* : nitrogen oxides Oz : oxygen ppmvd : parts per million by volume, dry basis :f:t:8*** If you have any questions, please contact Lauren Vander Werff at (801) 539-7386 or L Van d e rWerff@ c hev ro n. com. I certifu, based on information and belief formed after reasonable inquiry, the statements and information in this document are true, accurate, and complete. Sincerely, t.oy {rtorich Attachments: Attachment I - Flow Event (Flares No. I and No. 2) Attachment 2 - Flow Event (Flares No. I and No. 2) cc: CERTIFIED MAIL RETURN RECEIPT NO. 7021 2720 00014083 7088 Bob Gallagher U.S. EPA Region 8 - Montana Office l0 West l5th Street, Suite 3200 Helena, MT 59626 REVIEWEDInitials: Date: Jan 22, 2025Compliance Status:OKFile #: 10119 (B2) Type text here l. 2. 3. 4. 5. 6. 7. 8, 9. t0. ll. 12. 13. Attachment I ll3ll2024 - Flow Discharge (Flares No. I and 2) Description of Event: On January 31,2024, the Refinery flared excess fuelgas 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 and therefore the refinery had insufficient demand for fuelgas. Date, time, and duration of event: I13012024 I : l0 PM to 21112024 9:00 AM. Total duration : 43.8 hours (includes the first 23 hours of the first 24-hr period > the lirnit). 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 1,621,324 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(gxl)[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: Refinery Operations continued to work towards safe and efficient startup of the Crude Unit. 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: N/A If applicable, for each discharge that is the result of a planned startup or shutdown of a refinell 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 14. 2. J. 4. 5. 6. t. 7. ll. Attachment 2 612712024 - Flow Discharge (Flares No. I and 2) Description of Event: On June 26,2024 the Alkylation unit was shutdown for a planned outage. The Alkylation unit uses olefins as a feedstock. The result of the unit being shutdown was an excess of olefins which required the refinery to ship them via rail cars. The vapors from rail car loading are routed to the relief system per our safety design. The Alkylation unit is a net fuelgas consumer, and shutdown of the unit resulted in reduced fuel gas demand and excess fuel gas at the refinery. Corrective actions to reduce fuel gas generation included cutting back on rates at the Coker unit (fuel gas producer) and increasing rates at the Crude Unit (fuel gas consumer) in order to reduce the amount of surplus fuel gas sent to flares I &. 2. Corrective actions were made while monitoring our 24-hr flare I & 2 rolling average flow predictor. Although the predictor indicated we would be below the 24-hr flare I & 2 rolling average flow limit, we exceeded our limit. Date, time, and duration of event: 612612024 I l:00 PM to 612812024 5:00 AM. Total durarion :30 hours (includes the firsr 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: Approximat ely 2,624,19 6 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 devicen 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 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: Corrective actions to reduce fuel gas generation included cutting back on rates at the Coker unit (fuel gas producer) and increasing rates at the Crude Unit (fuel gas consumer) in order to reduce the amount of surplus fuel gas sent to flares I & 2. 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): Two corrective actions were implemented. a. Add a predictor of 24-hr rolling average flare I & 2 flow to the vacuum gas oil (VGO) unit console. b. Add the liquid petroleum gas flow indication to the VGO. 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 8. 9. 10. 12. t3. 14. completed' a schedule for implementation, including proposed commencement and completion dates: See #1 I - all actions were completed within 45 days following the discharge. 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 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 UTAIJ DI.PARTMENT OF E NVIRONI\4ENTAL QUALITY AUG 2024 DIVISION OF AIR QIJALITY REVIEWEDInitials: Date: Jan 22, 2025Compliance Status:OKFile #: 10119 (B2)