DAQ-2025-000430

v
Troy Tortorich Salt Lake Refinery
Refinery Manager Chevron Products Company
685 S Chevron Way
North Salt Lake, UT 84054
I:11%111,""1e,%
January 29,2024
CERTIFIED MAIL
RETURN RECEIPT No. 7021 2720 0001 4083 6e06 .ilH"ifit#lie;J":1,
Director, Air Enforcement Division
Office of Regulatory Enforcement
U.S. Environmental Protection Agency i [i] '2 '':-;'-1:a'
Mail Code 2242-A
i?:$'.?:il';t'ifi"ilffi) * DNrsroN oF ArR QUALrrvi
Consent Decree, U.^S. v. Chevron USA Inc.
Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report
Dear Sir or Madam:
Pursuant to Paragraph I l5 of the Consent Decree, this letter, along with all of its attachments, constitutes
Chevron Salt Lake City Refinery's semi-annual progress report for the period ending December 31,2023.
The reporting requirements for each subject area outlined in Paragraph I l5 of the Consent Decree are
provided as follows:
l. Progress report on the implementation of the requirements of Section V (Affirmative
Relief/Environmental Projects of the Consent Decree at the Salt Lake City Refinery): Ihrs
information is contained in Attachment l.
2. A summary of the emissions data for the Salt Lake City Refinery that is specifically required by
the reporting requirements of Section V of the Consent Decree for the period covered by the
report: The Salt Lake City Refinery is no longer required by the Consent Decree to report specific
emissions data.
3. A description of any problems anticipated with respect to meeting the requirements of Section V
of the Consent Decree at the Salt Lake City Refinery: None.
4. A description of all SEPs being conducted at the Salt Lake City Refinery in accordance with
Paragraph 109 of the Consent Decree: The Salt Lake City Refinery has completed all SEPs.
5. Any such additional matters as Chevron believes should be brought to the attention of EPA and
UDAQ: None.
6. BWON materials required to be submitted by Paragraph 82 of the Consent Decree'. This
information is provided in Attachment 2.
7. LDAR information required to be submitted by Paragraph 97 of the Consent Decree: None
Director, Air Enforcement Division
Office of Regulatory Enforcement
January 25,2024
Page2
If you have any questions or require additional information, please contact Lauren Vander Werff at (801)
539 -7 386 or [e-mail].
CERTIFICATION
I certifo under penalty of law that this information was prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my directions and my inquiry of the persons who manage the system, or
the persons directly responsible for gathering the information, the information submitted is, to the best of
my knowledge and belief, true, accurate, and complete.
Sincerely,
Troy Tortorich
Attachments
cc: Via E-Mail:
RIf,*rycp@ERc..o,,
marinathomas@agutah. gov
fo I ey. patric k@epa. gov
CERTIFIED MAIL NO 7021 2720OOOI4O83 6913
Bob Gallagher
U.S. EPA Region 8 - Montana Office
l0 West l5th Street, Suite 3200
Helena MT 59626
CERTIFIED MAIL NO 7O2I 2720 OOOI4O83 6920
Marina V. Thomas, Utah Assistant Attorney General
Environment/Health & Human Services Division
Utah Attorney General's Office
195 North 1950 West
PO Box 144820
Salt Lake ciry, uT 84114-0873
Attachment {
Affirmative Relief / Environmental Proiects lmplementation Proqress Report
for the period of 7/1/2023 throuqh 12131/2023
Section V.A. - NOx Emissions Reductions from FCCUs
Item to be Reported
CD
Reference Status
Establishing NOx Emission Limits:
EPA will use the data collected during the
baseline period, the Optimization Period, and
the Demonstration Period, as well as all other
available and relevant information to establish
limits for NOx emissions from the Salt Lake City
FCCU. EPA will establish a short term (i. e., 24-
hour or 7-day rolling average) and long term
(365-day rolling average) concentration-based
(ppmvd) NOx emission limit as measured at 0%
02. Chevron shall immediately (or within ninety
(90) days, if EPA's limit is more stringent than
the limit proposed by Chevron) operate the
FCCU so as to comply with the EPA-established
emission limits.
1113.b.Other than during periods of startup, shutdown, or
malfunction pursuant to fl13.c., the Chevron Salt Lake
City Refinery complied with the emission limits pursuant
to fl13.b.
Demonstrating Compliance with FCCU NOx Emission Limits:
Chevron shall install, certify, calibrate,
maintain and operate NOx and 02 CEMS
required by fl15 in accordance with the
provisions of 40 C.F.R. S 60.13 that are
applicable to CEMs and Part 60 Appendices A
and F, and the applicable performance
specification test of 40 C.F.R. Part 60
Appendix B.
With respect to 40 C.F.R. Part 60, Appendix F,
in lieu of the requirements of 40 C.F.R. Part
60, Appendix F S 5.1.1, 5.1.3 and 5.1.4,
conduct either a Relative Accuracy Audit
('RAA") or a Relative Accuracy Test Audit
('RATA') on each CEMS at least once every
three (3) years.
Conduct Cylinder Gas Audits ("CGA") each
calendar quarter during which a RAA or a
RATA is not performed.
11 15 The NOx and 02 CEMS continue to be calibrated,
maintained and operated according to the CD
requirements.
UTAH DEPARTIT'IE]'iT OF
ENVIRONMENTAL QUALITY
FIB
DIVISION OF AIR OUALIT'
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 3 of 25
Section V.B. - SO2 Emissions Reductions from FGCUs
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 4 of 25
Item to be Reported
CD
Reference Status
Compliance with Specific SO2 Emission Limits
. Chevron shall either;
1. by no later lhan 1213112008 comply with a
final SO2 limit of 25 ppmvd @ }ok 02 on
a 365-day rolling average basis and 50
ppmvd @ 0% 02 on a 7 day rolling
average basis through feed hydrotreating
and SO2 reducing catalyst additives; or
2. by no later lhan 1213112010, comply with a
final SO2 limit of 25 ppmvd @ 0o/o 02 on
a 365-day rolling average basis and 50
ppmvd @ lYo 02 on a 7 day rolling
average basis through installation and
operation of a wet gas scrubber.
fl 16.d.i.,
IJ 16.d.ii
Other than during periods of startup, shutdown, or
malfunction pursuant to fl16.e., the Chevron Salt Lake
City Refinery complied with the emission limits of 25
ppmvd @ 0% 02 on a 365-day rolling average and 50
ppmvd @ 0% 02 on a 7-day rolling average.
Demonstrating Compliance with FCCU SO2 Emission Limits
Chevron shall install, certify, calibrate,
maintain, and operate allSO2 and 02 CEMS
required by tf20 in accordance with the
provisions of 40 C.F.R. S 60.13 that are
applicable to CEMs and Part 60 Appendices A
and F, and the applicable performance
specification test of 40 C.F.R. Part 60
Appendix B.
With respect to 40 C.F.R. Part 60, Appendix F,
in lieu of the requirements of 40 C.F.R. Part
60, Appendix F SS 5. 1 .1 , 5.1 .3 and 5.1 .4,
Chevron shall conduct either a Relative
Accuracy Audit ("RAA") or a Relative Accuracy
Test Audit ('RATA") on each CEMS at least
once every three (3) years.
Chevron shall Conduct Cylinder Gas Audits
("CGA') each calendar quarter during which a
RAA or a RATA is not performed.
fl 20.The SO2 and 02 CEMS continue to be calibrated,
maintained and operated according to the CD
requirements.
Hydrotreater Outages
. No later than December 31 ,2004, Chevron
shall submit to EPA and the appropriate
Plaintiff-lntervenor, for approval by EPA, a
plan for the operation of the FCCU (including
associated air pollution control equipment)
during Hydrotreater Outages in a way that
minimizes emissions as much as practicable.
Chevron shall comply with the approved plan
at all times, including periods of Startup,
Shutdown, and Malfunction of the hydrotreater.
1[21.
To the extent that the Chevron Salt Lake City Refinery
experienced a Hydrotreater Outage during the reporting
period, the Chevron Salt Lake City Refinery complied
with the requirements of the approved Hydrotreater
Outage Plan dated November 20,2007 and fl 21
requirements.
ln the event that Chevron asserts that the
basis for a specific Hydrotreater Outage is a
shutdown (where no catalyst changeout
occurs) required by ASME pressure vessel
requirements or applicable state boiler
requirements, Chevron shall submit a report to
EPA that identifies the relevant requirements
and justifies Chevron's decision to implement
the shutdown during the selected time period.
121.Not applicable for this reporting period
Section V.C. - PM Emissions Reductions from FCCUs
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake Cig Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 5 of 25
Item to be Reoorted
CD
Reference Status. Chevron shall continue to control and may
further reduce particulate matter ("PM")
emissions from its Refineries by the operation
and optimization of electrostatic precipitators
Section V-C.Chevron Salt Lake City Refinery continues to operate
an electrostatic precipitator to control PM emissions.
Final PM Emission Limits
. By no later than 411012OO5, Chevron shall
comply with an emission limit of 1.0 pounds of
PM per 1000 pounds of coke burned on a 3-
hour average basis.
1123.
The Chevron Salt Lake City Refinery verified
compliance with the emission limit of 1.0 pounds of PM
per 1 000 pounds of coke burned on a 3-hour average
basis for the FCCU by stack test conducted August 16-
17,2023.
PM Testing for FCCUs
. Chevron shall follow the stack test protocol
specified in 40 C.F.R. $ 60.106(b)(2) to
measure PM emissions on the FCCU.
. Chevron shall conduct annual PM stack tests
at the FCCU.
. Upon demonstrating through at least three (3)
annual stack tests that the PM limits are not
being exceeded at the FCCU, Chevron may
requesl EPA approval to conduct tests less
frequently than annually at the FCCU.
1[234.See status for 1123.
Opacity Monitoring at FCCUs
. Chevron shall install, certify, calibrate,
maintain, and operate all COMS required by
this Consent Decree in accordance with 40
C.F.R. SS 60.1 '1, 60.13 and Part 60 Appendix
A, and the applicable performance
specification test of 40 C.F.R. Part 60
Appendix B.
1125.
The COMS continues to be calibrated, maintained, and
operated according to the CD requirements.
Section V.D. - CO Emissions Reductions from FCCUs
Section V.E. - NSPS Applicabilitv to FCCU Reqenerators
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 6 of 25
Item to be Reoorted
CD
Reference Status
CO Emissions Limits for Salt Lake City FCCU
By no later than April 10, 2005, Chevron shall
meet an emission limit of 500 ppmvd CO
corrected to 0% on a 1-hour average basis
1127.Other than periods of S/U, S/D, or malfunction pursuant
to fl 28, the Chevron Salt Lake City Refinery complied
with the emissions limits in fl 27 with the exception of
the following.
On December 14,2023, CO emissions from the FCC
exceeded the emission limit due to the unit operating in
abnormal conditions to correct a sulfur issue.
Demonstrating Compliance with CO Emissions Limits
Chevron shall install, certify, calibrate,
maintain, and operate all CO and 02 CEMS
required by fl29 in accordance with the
provisions of 40 C.F.R. S 60.13 that are
applicable to CEMs and Part 60 Appendices A
and F, and the applicable performance
specification test of 40 C.F.R. Part 60
Appendix B.
With respect to 40 C.F.R. Part 60, Appendix F,
in lieu of the requirements of 40 C.F.R. Part
60, Appendix F $S 5. 1 .1 , 5. 1 .3 and 5.1 .4,
conduct either a Relative Accuracy Audit
('RAA') or a Relative Accuracy Test Audit
('RATA') on each CEMS at least once every
three (3) years.
Conduct Cylinder Gas Audits ("CGA") each
calendar quarter during which a RAA or a
RATA is not performed.
112e.The CO and 02 CEMS continue to be calibrated,
maintained, and operated according to the CD
requirements.
Item to be Reported
CD
Reference Status
. By June 30, 2006, Chevron's FCCU Catalyst
Regenerator shall be an affected facility under
NSPS Subpart J for SO2, and Chevron shall
comply with the applicable requirements of
NSPS Subparts A and J for SO2.
. By April 10, 2005, Chevron's FCCU Catalyst
Regenerator shall be an affected facility under
NSPS Subpart J for PM, CO, and Opacity and
Chevron shall comply with the applicable
requirements of NSPS Subparts A and J for
PM.
fl 31.Chevron Salt Lake City Refinery is monitoring and
reporting under and as required by NSPS Subparts A
and J for PM, CO, SO2 and Opacity.
Section V.F. - NOx Emissions Reductions from Heaters and Boilers
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 PageT of 25
Item to be Reported
CD
Reference Status
lnstallation of NOx Control Technology
. Chevron shall select one or any combination of
the following "Qualifying Controls" to satisfu
the requirements of tf33 and fl37:
a. SCR or SNCR;
b. Current Generation or Next Generation
Ultra-Low NOx Burners;
c. other technologies which Chevron
demonstrates to EPA's satisfaction will
reduce NOx emissions to 0.040 lbs. per
mmBTU or lower; or
d. permanent shutdown of a heater or boiler
with revocation of its operating permit.
1[32.Refer to the NOx Control Plan previously submitted per
fl 35 of the CD requirements.
. On or before June 30,2011, Chevron shall use
Qualifuing Controls to reduce NOx emissions
from the heaters and boilers listed in Appendix
B by at leasl2777 tons per year, so as to satis!
the inequality in !f33.
1133.Complete.
Chevron shall submit a detailed NOx control
plan to EPA and Plaintiff-lntervenors for review
and comment by June 30, 2004, with annual
updates (covering the prior calendar year) on
June 30 of each year thereafter until termination
of the Consent Decree.
1135.The Annual NOx Control Plan update was submitted on
June 27,2023.
. By no later than June 30, 201 1, heaters and
boilers with Qualifying Controls shall represent
at least 30% of the total maximum heat input
capacity or, if less, the allowable heat input
capacity, as shown in Appendix B, of all
heaters and boilers greater than 40 mmBTU/hr
at the Salt Lake City Refinery.
1137 Complete.
Beginning no later than 180 days after
installing Qualifoing Controls on and
commencing operation of a heater and boiler
that will be used to satisfy the requirements of
fl33, Chevron shall monitor the heaters or
boilers as follows:
a. For heaters and boilers with a capacity
greater than 150 mmBTU/hr (HHV), install
or continue to operate a NOx CEMS;
b. For heaters and boilers with a capacity
greater than 100 mmBTU/hr (HHV) but less
than or equal to 150 mmBTU/hr (HHV),
install or continue to operate a NOx CEMS,
or monitor NOx emissions with a predictive
emissions monitoring system ('PEMS")
developed and operated pursuant to the
requirements of Appendix C of this Consent
Decree;
c. For heaters and boilers with a capacity of
less than or equal to 100 mmBTU/hr
(HHV), conduct an initial performance test
and any periodic tests that may be required
by EPA or by the applicable State or local
permitting authority under other applicable
regulatory authority. The results of the
initial performance testing shall be reported
to EPA and the appropriate Plaintiff-
lntervenor.
Chevron shall use Method 7E or an EPA-
approved alternative test method to conduct
initial performance testing for NOx emissions
required by subparagraph 38.c.
Monitoring with a PEMS that is required by
!f38 shall be conducted in accordance with the
requirements of Appendix C.
fl 38.Not applicable for this reporting period.
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page I ol 25
Beginning no later than 180 days after
installing Qualifoing Controls and commencing
operation of a heater or boiler that will be
monitored by use of a NOx CEMS that is
required by 1138, Chevron shall install, certify,
calibrate, maintain, and operale all CEMS in
accordance with the provisions of 40 C.F.R. $
60.13 that are applicable to CEMs and Part 60
Appendices A and F, and the applicable
performance specification test of 40 C.F.R.
Part 60 Appendix B.
With respect to 40 C.F.R. Part 60, Appendix F,
in lieu of the requirements of 40 C.F.R. Part
60, Appendix F SS 5.1.1, 5.1.3 and 5.1.4,
conduct either a Relative Accuracy Audit
('RAA") or a Relative Accuracy Test Audit
('RATA') on each CEMS at least once every
three (3) years.
Conduct Cylinder Gas Audits ("CGA") each
calendar quarter during which a RAA or a
RATA is not performed.
Units with Qualifying Controls installed before
Date of Entry that are subject to fl39 shall
comply with fl39 by June 30, 2004.
113e.No exceptions to report
. Chevron shall retain all records required to
support its reporting requirements under this
Section V.F. until termination of this Consent
Decree.
1541.Chevron Salt Lake City Refinery continues to retain
required records regarding NOx emission reductions
from heaters and boilers.
. lf Chevron transfers ownership of the Salt
Lake City Refinery before achieving all of the
NOx reductions required by fl33, Chevron shall
notifo EPA and the appropriate Plaintiff-
lntervenor of that transfer and shall submit an
allocation to EPA and the appropriate Plaintiff-
lntervenor for the Salt Lake City Refinery's
share of NOx reduction requirements of fl33
that will apply individually to the Salt Lake City
Refinery after such transfer. lf Chevron
chooses, such allocation may be zero.
1142.Not applicable for this reporting period.
Consenl Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 9 of 25
Section V.G. - SO2 Emissions Reductions from and NSPS Applicabilitv to Chevron
Heaters and Boilers and Other Specified Equipment
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 10 of 25
Item to be Reoorted
CD
Reference Status
NSPS Applicability to Heaters and Boilers and Other Specified Equipment
. Upon Date of Entry, all heaters and boilers
shall be affected facilities, under NSPS
Subpart J, and shall comply with the applicable
requirements of NSPS Subparts A and J for
fuel gas combustion devices, except for those
heaters and boilers listed in Appendix D, which
shall be affected facilities and shall be subject
to and comply with the applicable
requirements of NSPS Subparts A and J for
fuel gas combustion devices by the dates
listed in Appendix D.
fl 43.a.,
Appendix D.
The Chevron Salt Lake City Refinery is monitoring and
reporting under and as required by NSPS Subparts J
and A.
. By date listed in Appendix E, all equipment
listed in Appendix E shall be affected facilities,
under NSPS Subpart J, and shall be subject to
and comply with the applicable requirements
of NSPS Subparts A and J for fuel gas
combustion devices.
1143.b.
Appendix E
The Chevron Salt Lake City Refinery is monitoring and
reporting under and as required by NSPS Subparts J
and A.
Elimination / Reduction of Fuel Oil Burning
Effective on the Date of Entry, Chevron shall
not burn Fuel Oil in any combustion unit at its
Salt Lake City Refinery except that Chevron
may burn HF polymer at the Alkylation Plant,
fuel oil during Natural Gas Curtailment and
training, or Torch Oil in FCCU regenerators to
assist in starting, restarting, hot standby, orto
maintain regenerator heat balance.
n44.
Chevron Salt Lake City Refinery has continued not to
burn fuel oil in any combustion units except that
Chevron may burn HF polymer at the Alkylation Plant,
fuel oil during natural gas curtailment and training, or
torch oil in FCCU regenerators to assist in starting,
restarting, hot standby, or to maintain heat balance.
Section V.H. - Sulfur Recoverv Plants NSPS Applicabilitv
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 11 of 25
Item to be Reoorted
CD
Reference Status
Sulfur Pit Emissions
Chevron shall continue to route or re-route all
sulfur pit emissions so that they are eliminated,
controlled, or included and monitored as part
of the SRP's emissions subject to the NSPS
Subpart J limit for SO2, or to applicable
emissions limits under Paragraph 48 by no
later than the first turnaround of the applicable
Claus train that occurs on or after June 30,
2004 or by December 31, 2006 (whichever first
occurs).
1146.With the exceptions noted below, sulfur pit emissions
were controlled and monitored during the reporting
period.
On November 15 and 16, a steam system leak repair
caused the SRU 1 sulfur pit emissions to be routed to
the atmosphere for approximately 16 hours and 34
minutes. On November 21, SRU 1 sulfur pit emissions
were routed to the atmosphere for approximately 7
hours due to the plant shutting down unexpectedly.
ln several instances, the SRU 1 pit vent inadvertently
opened due to a plugged pressure indicator line, but in
no event was it the result of positive pressure in the pit.
Because the pit did not experience positive pressure
during these events, Chevron believes this
instrumentation issue did not result in any associated
emissions from the sulfur pit. Each event, which
typically lasted a few minutes was remedied by
unplugging the clogged pressure indicator line. These
events occurred on the following dates: July 8, July 13,
August 1 1, September 13, September 24, November
18, and December 4 for a total of t hours 33 minutes.
ln several instances, the SRU 2 pit vent inadvertently
opened due to a plugged pressure indicator line, but in
no event was it the result of positive pressure in the pit.
Because the pit did not experience positive pressure
during these events, Chevron believes this
instrumentation issue did not result in any associated
emissions from the sulfur pit. Each event, which
typically lasted a few minutes was remedied by
unplugging the clogged pressure indicator line. These
events occurred on the following dates: July 23, August
10, August 26, September 10, October 16, October 22,
November 10, November 17, November 21, and
December 29 for a total of 54 minutes.
Compliance with NSPS Emissions Limits at the Salt Lake Citv SRP. Chevron shall be an affected facility under
NSPS Subpart J and shall comply with all
applicable provisions of NSPS Subpart A and J.
Such SRP shall comply with 40 C.F.R.
560.10a(a)(2) at alltimes except during periods
of startup, shutdown, or malfunction of the SRP
and SRU, or during malfunction of the TGU.
l[47.a.The Chevron Salt Lake City Refinery SRPs are affected
facilities under NSPS Subpart Ja and have complied
with all applicable provisions of NSPS Subparts A and
Ja.
. Effective on the respective date on which the
SRP becomes an affected facility pursuant to
Paragraph 47.a, Chevron shall monitor all
emissions and shall report excess emissions
from the SRP under and as required by NSPS
Subpart J.
1147.b.The Chevron Salt Lake City Refinery monitored all
emissions and reported all excess emissions as
required by NSPS Subpart Ja.
. At all times, including periods of startup,
shutdown and malfunction, Chevron shall, to the
extent practicable, operate and maintain its
SRPs, SRUs, and TGUs and any supplemental
control devices. in accordance with oood air
1.I47 .c The Chevron Salt Lake City Refinery, to the extent
practicable, has operated and mainlained its SRP,
SRU, TGU, and incinerator in accordance with good air
pollution control practices as required in 40 C.F.R.
s60.1 1(d).
pollution control practices as required in 40
c.F.R. 560.11(d).
Optimization. Chevron shall continue to maintain its Best
Practices Team as a means to optimize Sulfur
Recovery Plant operations.
1150.b.
Chevron Salt Lake City Refinery continues to use its
Best Practices Team (now called a Business
lmprovement Network (BlN)) to optimize Sulfur
Recoverv Plant ooerations.
Good Operation and Maintenance
Chevron shall comply with the PMO Plan at all
times, including periods of Startup, Shutdown
and Malfunction of its SRPs. Chevron's
changes to a PMO Plan related to minimizing
Acid Gas Flaring and/or SO2 emissions shall
be summarized and reported to EPA and the
appropriate Plaintiff-l ntervenor on an annual
basis.
fl 51.a.Chevron Salt Lake City Refinery complied with the PMO
Plan at all times, including periods of Startup,
Shutdown, and Malfunction of its SRPs. Chevron Salt
Lake City Refinery is complying with the mosl recent
PMO Plan submittal dated March 29,2023.
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 12 of 25
Section V.l. - Flarinq Devices - NSPS ApplicabiliW
Section V.J. - Control of Acid Gas Flarinq lncidents and Tail Gas lncidents
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 3'l,2023
Attachment t Page 13 of 25
Item to be Reported
CD
Reference Status
Good Air Pollution Control Practices
. On and after the Date of Entry, Chevron shall
at all times and to the extent practicable,
including during periods of Startup, Shutdown,
and/or Malfunction, implement good air
pollution control practices for minimizing
emissions consistent with 40 C.F.R. S60.1 1(d).
1153.The Chevron Salt Lake City Refinery at all times and to
the extent practicable, including during periods of
Startup, Shutdown, and/or Malfunction, implements
good air pollution control practices for minimizing
emissions.
Refinery Fuel Gases
. By no later than December 31 , 2006, Chevron
shall:
1. Certifo compliance with applicable NSPS
requirements and accept NSPS Subpart J
applicability for at least 50% of the Flaring
Devices identified in Appendix F; and
2. Subrnit a schedule of
activities that Chevron will undertake to ensure
continuous compliance with applicable NSPS
requirements as soon as practicable at all
other Flarinq Devices.
1154.a.As previously reported, Chevron has certified
compliance with and accepted NSPS J applicability for
26 of 26 Flaring Devices in Appendix F.
. Except for a maximum of three flares, Chevron
shall certi{y compliance with applicable NSPS
Subpart J requirements and accept NSPS
Subpart J applicability for all those Flaring
Devices not previously addressed under
Paragraph 54.a.i. by December 3'1, 2008.
For any remaining flares, Chevron shall certify
compliance with applicable NSPS Subpart J
requirements and accept NSPS Subpart J
applicability for those Flaring Devices by
December 31,2010.
fl 54.a.See response in !154.a. above.
Item to be Reported
CD
Reference Status
lnvestigating and Reporting
. By no later than forty-five (a5) days following
the end of an Acid Gas Flaring lncident
occurring after the Date of Entry, Chevron
shall submit to EPA and the appropriate
Plaintiff-lntervenor a report that sets forth the
information in 1157.
'1157.No acid gas flaring incidents occurred during this
reporting period.
. To the extent that completion of the
implementation of corrective action(s), if any,
is not finalized at the time of the submission of
the report required under this Paragraph, then,
by no later than thirty (30) days after
completion of the implementation of corrective
actions(s), Chevron shall submit a report
identifoing the corrective action(s) taken and
the dates of commencement and completion of
imolementation.
fl 57.viii.The Chevron Salt Lake City Refinery has met the
requirements of Jf 57.viii during the reporting period.
Corrective Action
ln response to an AG Flaring lncident
occurring after the Date of Entry, Chevron
shall take, as expeditiously as practicable,
such interim and/or long-term corrective
actions, if any, as are consistent with good
engineering practice to minimize the likelihood
of a recurrence of the Root Cause and all
contributino causes of that AG Flarino lncident.
1158.a.The Chevron Salt Lake City Reflnery has met the
requirements of fl 58.a. during the reporting period.
Tail Gas lncidents
. For Tail Gas lncidents, Chevron shall follow
the same investigative, reporting, corrective
action and assessment of stipulated penalty
procedures as those outlined in Paragraphs 57
through 64 for Acid Gas Flaring lncidents.
Those procedures shall be applied to TGU
shutdown, bypasses of a TGU, and
unscheduled shutdowns of a Sulfur Recovery
Plant or other miscellaneous unscheduled
Sulfur Recovery Plant events which result in a
Tail Gas lncident.
1166.a.The Salt Lake Refinery had a Tail Gas lncident on
November 21,2023. The Refinery has met the
requirements of fl 57 for Tail Gas lncidents during the
reporting period.
Section V.K. - Control of Hvdrocarbon Flarinq lncidents
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 14 oI 25
Item to be Reported
CD
Reference Status
. For Hydrocarbon Flaring lncidents occurring
after the Date of Entry, Chevron shall follow
the same investigative, reporting, and
corrective action procedures as those outline
in paragraphs 57 and 58 for Acid Gas Flaring
lncidents; provided however, that in lieu of
analyzing possible corrective actions under
Paragraph 57.v and taking interim and/or long-
term corrective action under Paragraph 58.a
for a Hydrocarbon Flaring lncident attributable
to the Startup or Shutdown of a unit that
Chevron has previously analyzed under this
Paragraph, Chevron may identifo such prior
analysis when submitting the report required
under this Paraoraph.
T 67.The Refinery has met the requirements of !f 67 for
Hydrocarbon Flaring lncidents during the reporting
period.
Section V.L. - Benzene Waste NESHAP Program Enhancements
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 'l , 2023 through December 31 , 2023
Attachment 1 Page 15 of 25
Item to be Reported
CD
Reference Status
Current Compliance Status
. By no later than 1213112005, the Salt Lake City
Refinery shall comply with the compliance
option set forth at 40 C.F.R. $61.342(e), herein
referred to as the 6BQ compliance option.
fl 68.c.The Chevron Salt Lake City Refinery continues to
comply with 40 C.F.R. 561 .342(e), herein referred to
as the 6BQ compliance option.
One-Time Review and Verification of Each Refinery's TAB. Based on EPA's review of the BWON
Compliance Review and Verification Report(s),
EPA may select up to 20 additional waste
streams at each Refinery for sampling for
benzene concentration. Chevron will conduct
the required sampling and submit the results to
EPA within sixty (60) days of receipt of EPA's
request.
1[70.b.Not applicable for this reporting period.
. Chevron shall submit an amended BWON
Compliance Review and Verification Report
within ninety (90) days following the date of the
completion of the required Phase Two
sampling, if Phase Two sampling is required
by EPA.
fl 70.b.Not applicable for this reporting period.
lmplementation of Actions Necessary to Correct Non-Compliance or to Come lnto Compliance
. Within 60 days after receiving any notification
of disapproval or request for modification from
EPA, Chevron shall submit to EPA and the
a ppropriate P laintiff-l ntervenor a revised pla n
that resoonds to all identified deficiencies.
1171.d.Not applicable for this reporting period.
Carbon Ganisters
By no later than seven (7) days after the
installation of each secondary carbon canister,
Chevron shall start to monitor for breakthrough
between the primary and secondary carbon
canisters at times when there is actual flow to
the carbon canister, in accordance with the
frequency specified in 40 C.F.R. 561.354(d),
and shall monitor the outlet of the secondary
canister on a monthly basis or at its design
replacement interval (whichever is less) to
verifu the proper functioning of the system.
1172.d.Chevron Salt Lake City Refinery monitors for
breakthrough between primary and secondary carbon
canisters at the frequency specified in 40 C.F.R.
561.354(d) and monitors at the outlet of the second
canister on a monthly basis and is in compliance with
this requirement for this reporting period.
Chevron shall replace the original primary
carbon canisters (or route flow to an
appropriate alternative control device)
immediately when breakthrough is detected
between the primary and secondary canister.
The original secondary carbon canister (or a
fresh carbon canister) will become the new
primary carbon canister and a fresh carbon
canister will become the secondary canister.
ll72.e.Chevron Salt Lake City Refinery continues to replace
the original primary carbon canister immediately
when breakthrough is detected between the primary
and secondary canister and is in compliance with this
requirement for this reporting period.
. Beginning no later than January 1 ,2004,
Chevron shall monitor for breakthrough from
single carbon canisters each business day
(Monday through Friday, excluding legal
holidays) there is actual flow to the carbon
canister.
1172.r.Not applicable for this reporting period.
. Chevron shall replace the single carbon
canister with a fresh carbon canister,
discontinue flow or route the stream to an
alternate, appropriate device immediately
when breakthrouqh is detected.
1172.',f .Not applicable for this reporting period.
. Chevron shall maintain a supply of fresh
carbon canisters at each Refinery at all times.
1172.s.Chevron Salt Lake City Refinery maintains a supply
of fresh carbon canisters at the Salt Lake City
Refinerv.. Records for the requirements of Paragraph 72
shall be maintained in accordance with 40
c.F.R. S61.356(iX10).
1172.h.Records for the requirements of ll72 are maintained
in accordance with 40 C.F"R. 561.3560X10).
Annual Proqram. By not later than June 30,2004, Chevron shall
establish an annual program of reviewing
process information for each Refinery,
including but not limited to construction
projects, to ensure that all new benzene waste
streams are included in each Refinery's waste
stream inventory.
1173 Chevron Salt Lake City Refinery continues to
annually review process information for the Salt Lake
City Refinery to ensure all new benzene waste
streams are included in the Refinery's waste stream
inventory.
Laboratorv Audits. Chevron shall conduct audits of all laboratories
that perform analyses of Chevron's Benzene
Waste NESHAP samples to ensure that proper
analytical and quality assurance/quality control
procedures are followed.. During the life of this Consent Decree,
Chevron shall conduct subsequent laboratory
audits, such that each laboratory is audited
every two (2) years.
1174.
ll74.c.
Chevron Salt Lake City Refinery has a program in
place to audit any laboratory used for analysis of
benzene samples prior to such use.
The Chevron Technology Center conducted an audit
of Micro-Methods laboratory on February 16,2023.
The Chevron Technology Center conducted an audit
of Chemtech-Ford laboratory on March 15,2023.
Benzene Spills
Beginning on Date of Entry, for each spill at
each Refinery, Chevron shall review such
spills to determine if more than 10 pounds of
benzene waste was generated in any 24 hour
period. Chevron shall include the benzene
generated by such spills in the TAB and in the
uncontrolled benzene quantity calculation for
each Refinery, as and to the extent required
by Subpart FF.
1175.Spills continued to be reviewed to determine
whether the benzene quantity must be included in
the refinery TAB and in the uncontrolled benzene
quantity calculation.
Trainino. By no laterthan January 1,2004, Chevron
shall develop and begin implementation of
annual (i.e., once each calendar year) training
for all employees asked to draw benzene
waste samples.
fl 76.a.All employees asked to pull benzene waste samples
between July 1 and December 31 , 2023 have
completed annual computer-based training covering
proper sampling techniques.
. By no later than December 31, 2005, Chevron
shall complete an initial training program
regarding procedures for operating control
devices for all operators assigned to this
equipment.
Comparable training shall also be provided to
any persons who subsequently become
operators, prior to their assumption of this
dutY.
1176.b.Chevron Salt Lake City Refinery continues to train all
operators assigned to operate BWON control
devices.
During the semi-annual period from July 1 to
December 31 ,2023, operators new to BWON control
devices received on-the-job training prior to their
assumption of this duty.
. "Refresher" training in these control device
procedures shall be performed on a three year
cvcle.
11 76.b Not applicable for this reporting period.
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachmenl 1 Page 16 of 25
. As part of Chevron's training program,
Chevron must ensure that the employees of
any contractors hired to perform the
requirements of this Paragraph are properly
trained to implement all applicable provisions
of this Consent Decree.
fl 76.c.All employees of contractors asked to pull benzene
waste samples between July 1 to December 31,
2023, have been properly trained during this semi-
annual reporting period.
Waste Slop/Off-Spec Oil Management
. At a mutually agreed upon time, Chevron shall
submit revised schematics that reflect the
Parties' agreements regarding the
characterization of these oil streams and the
aoorooriate control standards. if necessarv.
ll77.a.Not applicable for this reporting period.
. All waste management units handling non-
exempt, non-aqueous benzene wastes, as
defined in Subpart FF, shall meet the
applicable control standards of Subpart FF.
1177.b.All waste management units handling non-exempt,
non-aqueous waste met the applicable control
standards during this reporting period.
. Chevron shall include all aqueous
waste/slop/off-spec oil streams in the TAB. All
WMU handling benzene waste shall either
meet the control standards of Subpart FF or
count toward the 6BQ limit.
ll77.c.All WMU handling benzene waste at the Chevron Salt
Lake City Refinery either meets the control standards
of Subpart FF or count toward the 6BQ limit.
End of Line Samplinq (6 Mq Compliance Option)
lf changes in processes, operations, or other
factors lead Chevron to conclude that its
approved EOL Plan may no longer provide an
accurate measure of the refinery's quarterly
"end of line" benzene determination and/or its
uncontrolled waste stream, Chevron shall
submit a revised EOL Plan to EPA and the
appropriate Plaintiff-l ntervenor for EPA
aooroval.
fl 78.b.Not applicable for this reporting period.
Chevron shall commence sampling under its
EOL Plan during the second calendar quarter
of 2006.
Chevron shall take, and have analyzed, at
least three representative samples from each
approved sampling location.
Chevron shall use the average of all samples
and approved flow calculations to make its
quarterly "end of the line" benzene
determination and in estimating a calendar
vear value for each Refinery.
1178.c.The Chevron Salt Lake City Refinery has taken and
analyzed at least three representative samples from
each proposed sampling location consistent with the
approved EOL Plan. The Lime Pond is out of service
and not sampled, per the EOL.
. lf the quarterly benzene determination
exceeds 1.5 Mg/yr or if the estimated calendar
year value exceeds 6 Mg/yr, Chevron shall
prepare and provide to EPA and the
appropriate Plaintiff-lntervenor a written
summary and schedule of activities necessary
to minimize benzene wastes at such Refinery
so as to ensure that it complies with the 6 BQ
compliance option that calendar year. This
summary and schedule are due no later than
sixtv (60) davs after the close of such quarter.
1t78.d.Not applicable for this reporting period.
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31 ,2023
Attachment 1 Page 17 of 25
After at least 8 quarters of sampling under an
approved EOL Plan, Chevron may submit a
report to EPA and the appropriate Plaintiff-
lntervenor that places uncontrolled aqueous
waste streams at a Refinery into three
categories: (a) consistently <0.05 Mg/yr
benzene that may not warrant continued
sampling; (ii) consistently >0.05 Mg/yr
benzene but with low variabilfty that may
warrant less frequent sampling; and (iii) all
others that are consistently 20.05 Mg/yr
benzene.
fl 78.e.Not applicable for this reporting period.
Miscellaneous Measures. By December 31, 2005, Chevron shall:
Manage all groundwater remediation wastes at
each of its Refineries in appropriate waste
management units under and as required by
the Benzene Waste NESHAP
Conduct monthly visual inspections of all
Subpart FF water traps within the Refinery's
individual drain systems
1[80
fl 80.a.
1180.b.
Chevron Salt Lake City Refinery continues to count
all groundwater remediation wastes toward its
Benzene Quantity as required by the BWON.
Chevron performed monthly visual inspections of
controlled drains subject to Subpart FF during this
reporting period.
P roiects/lnvestiqations. Chevron may conduct a study of the
effectiveness of the benzene and VOC limits
under Paragraph 72.c. This study shall last no
less than two (2) years and must be performed
in accordance with the guidelines established
in Appendix J.
Chevron shall submit a schedule and
statement of work to EPA at least 90 days
prior to beginning such work.
Chevron shall submit a report to EPA and the
a ppropriate P laintiff-l ntervenor s u mmarizing
the results of the study within ninety (90) days
of completion and may request a revision of
the limits under Paragraph 72.c based upon
the results ofthat study and any other relevant
information, including similar studies that may
be oerformed bv or for others.
fl 81.b.Not applicable for this reporting period.
Recordkeepinq and Reportinq Requirements for Section V.L. Chevron shall submit, as and to the extent
required, the following materials in the
progress report(s) for the quarter in which the
following identified activities occurred or are
required:
1182.See below.
. BWON Compliance Review and Verification
Reoort as amended. if necessarv (tl 70.b).
fl 82.a.Not applicable for this reporting period.
. Schematics of waste slop/off-spec oil
movements. as revised. if necessary 6177 .a.)
fl 82.s.Not applicable for this reporting period.
. EOL Plans and revised EOL Sampling Plans, il
necessarv (flfl 78.a and 78.b)
1182.i.Not applicable for this reporting period.
r Plan to ensure that uncontrolled benzene does
not equal or exceed 6 Mg/yr-or is
minimized-based on projected calendar year
uncontrolled benzene quantities as determined
throuqh EOL samplinq (ll78.d)
1182 j Not applicable for this reporting period.
Consenl Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December 31,2023
Attachment 1 Page 18 of 25
. Results of the study of "breakthrough" in
carbon canisters (1181.b)
1T 82.k.Not applicable for this reporting period.
ldentify all laboratory audits completed during
the preceding calendar year under fl74.a,
including the laboratory audited during that
quarter, a description of the methods used in
the audit and the results of the audit, in the
progress report for the 4th quarter of that year
fl 82.r Not applicable for this reporting period.
. Describe the measure taken that calendar
quarter to comply with the training provisions
of fl76
fl 82.m Refer to fl 76 for general information regarding
BWON training activities during the semi-annual
oeriod.
Provide all quarterly "end of line" benzene
determinations and a summary of supporting
sampling results for the preceding calendar
year under fl78 in the progress report for the
4th quarter of that year. The report shall
include a list of all waste streams sample and
the results of the benzene analysis for each
sample
fl 82.n.See Attachment 2.
r Describe the actions that Chevron is taking to
identify and correct the source of the
potentially elevated benzene quantities and/or
to ensure continuing compliance with the
Benzene Waste NESHAP under and as
provided in fl78.
fl 82.o.Not applicable for this reporting period.
Section V.M. - Leak Detection and Repair ("LDAR") Program Enhancements
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 19 ol 25
Item to be Reported
CD
Reference Status
Written Refinery-Wide LDAR Program
. Chevron shall update each such program as
may be necessary to ensure continuing
comoliance.
'1183.Not applicable for this reporting period.
No update this reporting period.
Training
. For personnel newly-assigned to LDAR
responsibilities, Chevron shall require LDAR
training prior to each employee beginning such
work
fl 84.a.All personnel newly assigned to LDAR responsibilities
receive training prior to beginning LDAR work.
. For all personnel assigned LDAR
responsibilities, Chevron shall provide and
require completion of annual LDAR training or
require its LDAR contractor to provide such
training (initial annual LDAR training for all
such personnel will be completed not later
than December 31, 2004)
1[84.b.All personnel assigned to LDAR responsibilities
receive annual training.
. "Refresher" training in LDAR shall be
oerformed on a three-vear cvcle.
fl 84.c.Refresher training was performed in 2023
LDAR Audits. Chevron shall retain a contractor(s) to perform
a third-party audit of the Refinery's LDAR
program at least once every four years.
u 85.b.Not applicable for this reporting period.
. Chevron shall conduct internal audits of each
Refinery's LDAR program by sending
personnel familiar with the LDAR program and
its requirements from one or more of
Chevron's other Refineries or locations to audit
another Chevron Refinerv.
fl 85.c.Not applicable for this reporting period
. Chevron shall complete an internal LDAR audit
by no later than two years from the date of the
completion of the third-party audits required in
Paragraphs 85.a and 85.b.
ll 85.c.The Salt Lake Refinery completed a third-party
internal audit in January 2024. The audit report and
corrective actions will be submitted in the semiannual
report covering January 1, 2024 through June 20,
2024.. Chevron shall perform an internal audit of each
Refinery's LDAR program at least once every
four years. Chevron may elect to retain third-
parties to undertake the internal audit,
provided that an LDAR audit at each Refinery
occurs everv two (2) vears.
fl 85.c.The Salt Lake Refinery completed a third-party
internal audit in January 2O24. The audit report and
corrective actions will be submitted in the semiannual
report covering January 1,2024 through June 20,
2024.
lmplementation of Actions Necessary to Correct Non-Compliance
lf the results of any of the audits conducted
pursuant to Paragraph 85 identify any areas of
non-compliance, Chevron shall implement, as
soon as practicable, all steps necessary to
correct the area(s) of non-compliance and to
prevent, to the extent practicable, a recurrence
of the cause of such non-comoliance.
1186 Not applicable for this reporting period.
. Chevron shall retain the audit reports
generated pursuant to Paragraph 85 and shall
maintain a written record of the corrective
actions that Chevron takes in response to
deficiencies identified in any audits.
fl 86.Chevron Salt Lake City Refinery is retaining the audit
reports generated pursuant to fl 85 and maintains a
written record of the corrective actions Chevron Salt
Lake City Refinery has taken in response to
deficiencies identified in any audits.
ln the quarterly report submitted pursuant to
the provisions of Section lX of this Consent
Decree (Recordkeeping and Reporting) for the
first calendar quarter of each year, Chevron
shall submit to EPA and the appropriate
Plaintiff-lntervenor the audit reports and
corrective action records for audits performed
and actions taken durinq the previous vear.
1186.Not applicable for this reporting period.
lnternal Leak Definition for Valves and Pumos. By no later than June 30, 2005, Chevron shall
utilize an intemal leak definition of no greater
than 500 ppm VOCs for each Refinery's
valves. excludinq pressure relief devices.
\87.a Chevron Salt Lake City Refinery is using an intemal
leak definition of 500 ppm VOC for valves.
. By no laterthan June 30, 2005, Chevron shall
utilize an internal leak definition of no greater
than 2000 oom for each Refinerv's oumos.
fl 87.b Chevron Salt Lake City Refinery is using an internal
leak definition of 2000 ppm VOC for pumps.
Reporting, Recording, Tracking Repairing and Remonitoring Leaks of Valves and Pumps Based on the lnternal
Leak Definitions. Chevron shall record, track, repair and re-
monitor all leaks in excess of the internal leak
definitions of Paragraph 87 at such time as
those definitions become applicable.. Except as provided otherwise in this Section
V.M, Chevron shall make a first attempt at
repair within five (5) calendar days and either
complete repairs and re-monitor leaks or place
such component on the Refinery's delay of
repair list within thifi (30) days.
T 88.b.All leaks in excess of the internal leak definitions of fl
87 are recorded and tracked using the LDAR
Monitoring Database.
LDAR Monitoring Database records indicate that first
attempts at repair, remonitoring, and delay of repair
requirements have been satisfied.
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 'l Page 20 ol 25
. By no later than March 31 ,2004, Chevron
shall promptly make an "initial attempt" to
repair any valve that has a reading greater
than 100 ppm of VOCs, excluding control
valves and components that LDAR personnel
are not authorized to repair.. Chevron or its designated contractor shall re-
monitor, within five (5) calendar days, all
valves that LDAR personnel attempted to
reoair under this Paraoraoh.
118e.LDAR Monitoring Database records indicate that
Chevron Salt Lake City Refinery made an initial
attempt at repair and remonitored within 5 calendar
days on all valves with a reading greater than 100
ppm.
LDAR Monitorinq Frequencv
When the lower internal leak definition for
pumps becomes appllcable under Paragraph
87.b and unless more frequent monitoring is
required by applicable federal, state and/or
local requirements, Chevron shall monitor
pumps at the internal leak definition on a
monthly basis.
'lJ90.a Chevron Salt Lake City Refinery is monitoring pumps
at the internal leak definition monthly.
Chevron shall monitor valves at the internal
leak definition on a quarterly basis (other than
difficult to monitor or unsafe to monitor valves).
1le0.b.Chevron Salt Lake City Refinery is monitoring light
liquid and gas/vapor valves at the internal leak
definition on a quarterly basis, with the exception of
those in process units in which the Sustainable Skip
Period Monitoring Program of Consent Decree
Appendix K has been implemented and those
classified as difficult to monitor.. Chevron may implement the Sustainable Skip
Period Program set forth in Appendix K of the
Consent Decree at the Salt Lake Citv Refinery.
fl 90.c.Chevron Salt Lake City Refinery has implemented
skip monitoring for the qualifying process units as set
forth in fl 90.c. and Appendix K.
Chevron shall have the option of monitoring
affected valves and pumps within process
unit(s) after completing a documented
maintenance, startup, or shutdown activity
without having the results of the monitoring
count as a scheduled monitoring activity,
provided that Chevron monitors according to
the followino schedule:
1le0.d.Chevron Salt Lake City Refinery has not used this
option for turnaround or shutdowns during this
reporting period.
. For events involving 1000 or fewer valves and
pumps, monitor within one (1) week of the
documented maintenance, start-up, or
shutdown activitv:
fl 90.d.i.Not applicable for this reporting period.
. For events involving greater than 1000 but
fewer than 5000 valves and pumps, monitor
within two (2) weeks of the documented
maintenance. start-uo. or shutdown activitv:
1T e0.d.ii.Not applicable for this reporting period.
. For events involving greater than 5000 pumps
and valves, monitor within four (4) weeks of
the documented maintenance, start-up, or
shutdown activitv.
!l90.d.iii.Not applicable for this reporting period.
Electronic Monitorino. Storino and Reoort of LDAR Data. Chevron has and will continue to maintain an
electronic database for storing and reporting
LDAR data.
fl 9'1.a.Chevron Salt Lake City Refinery continues to use the
Sky Bridge program for storing and reporting LDAR
data.. By no later than January 1,2004, Chevron
shall maintain operational specifications for the
data logger, software and monitoring
equipment it elects to use under this Consent
Decree.
T e1.b.The required documentation is maintained on file.
r Chevron shall use dataloggers and/or
electronic data collection devices during all
LDAR monitorinq.
fl e1.b.Chevron Salt Lake City Refinery is utilizing
dataloggers for LDAR monitoring.
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 21 of 25
. Chevron, or its designated contractor, shall
use its/their best efforts to transfer, by the end
of the next business day electronic data from
electronic data logging devices to the
electronic database of Paragraph 91.a. For all
monitoring events in which an electronic data
collection device is used, the collected
monitoring data shall include a time stamp and
identify the operator/monitoring technician and
the monitorino instrument used
fl 91.b.Chevron Salt Lake City Refinery uses its best effo(s
to transfer the data from the electronic data logging
device to the database system by the end ofthe next
business day. ln cases where data transfer and/or
other issues hinder transfer to the database system,
and manual entry of monitorlng data into the Sky
Bridge database is necessary, records of such entries
are maintained.
. Chevron may use paper logs where necessary
or more feasible (e.9., small rounds, re-
monitoring, orwhen data loggers are not
available or broken), and shall record, at a
minimum, the identity of the technician, the
date, monitoring starting and ending times,
and an identification of the monitoring
equipment.
1l e1.b.Chevron Salt Lake City Refinery has utilized paper
logs only for instances of retesting, small rounds, or
when data logger/serial data transfer difficulties are
encountered.
. Chevron shall use its best efforts to transfer
any manually recorded monitoring data to the
electronic database of Paragraph 91.a within
seven davs of monitorino.
fl e1.b Chevron Salt Lake City Refinery uses its best efforts
to transfer manually recorded data to the electronic
database within the seven-day timeframe.
QA/QC of LDAR Data. By no laler than March 31 ,2004, Chevron (or
a third party contractor retained by Chevron)
shall have developed and begun implementing
procedures for quality assurance/quality
control ("OA/OC") reviews of all data
generated by LDAR monitoring technicians.. Chevron shall ensure that monitoring data
provided by its contractors is periodically
reviewed for QfuQC by the contractors.o At least once per calendar quarter, Chevron
shall perform a QA/QC review of each
contractor's monitoring data which shall
include, but not be limited to: number of
components monitored per technician, time
between monitoring events and abnormal data
patterns.
11e2.Chevron Salt Lake City Refinery continues to
maintain procedures for QA/QC reviews of all data
generated by LDAR monitoring technicians. The
monitoring data is reviewed for QA/QC on a quarterly
basis and includes number of components monitored
per technician, time between monitoring events, and
abnormal data patterns.
LDAR Personnel. Chevron shall continue to maintain a position
at each Refinery that is responsible for LDAR
management and that has the authority to
implement LDAR improvements.
fl e3.Chevron Salt Lake City Refinery continues to
maintain this position.
Addinq New Valves and Pumps. By no later than June 30, 2004, Chevron shall
establish a tracking program for maintenance
records (e.9., a Management of Change
program) to ensure that valves and pumps
added to the Refinery during maintenance and
construction are integrated into each
Refi nerv's LDAR prooram.
1[e4.Chevron Salt Lake City Refinery continues to
maintain a tracking program for maintenance records
to meet CD requirements.
Calibration/Calibration Drift Assessmentr Chevron shall conduct all calibrations of LDAR
monitoring equipment using methane as the
calibration gas, in accordance with 40 C.F.R.
Part 60, EPA Reference Test Method 21 .
1le5.a.Chevron Salt Lake City Refinery utilizes methane as
the calibration gas in accordance with 40 C.F.R. Part
60, EPA Reference Test Method 21.
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31 ,2023
Attachment 1 Page 22 ol 25
. By no later than January 1,2004, Chevron
shall conduct calibration drift assessments of
LDAR monitoring equipment at the end of
each monitoring shift, at a minimum.. Chevron shall conduct the calibration drift
assessment using a calibration gas with a
concentration approximately equal to the
applicable internal leak definition.. lf any calibration drift assessment after the
initial calibration shows a negative drift of more
than 10% from the previous calibration,
Chevron shall re-monitor all valves that were
monitored since the last calibration that had a
reading greater than 100 ppm and shall re-
monitor all pumps that were monitored since
the last calibration that had a reading greater
than 500 oom.
,1195.b.Chevron Salt Lake City Refinery continues to:
1. Conduct calibration drift assessments of LDAR
monitoring equipment at the end of each
monitoring shifi, at a minimum.
2. Conduct the calibration drift assessment using a
calibration gas with a concentration approximately
equal to the applicable internal leak definition.3. Re-monitor all components that were monitored
after the initial calibration if the drift assessment
shows a negative drift of more than 10% from the
initial calibration.
Delav of Reoair. By no laterthan January 1,2004, Chevron
shall take the following actions for any
equipment that it intends and is allowed to
place on the "delay of repai/' list under
applicable requlations:
fl 96.a.See below.
. Require sign-off by the unit supervisor within
thirty (30) days of identifying that a piece of
equipment is leaking at a rate greater than the
applicable leak definition) that such equipment
qualifies for delayed repair under applicable
reoulations.
fl 96.a.i.Chevron Salt Lake City Refinery continues to require
sign-off by unit supervisor for equipment qualifuing for
delayed repair.
. lnclude equipment that is place on the "delay
of repair" list in Chevron's regular LDAR
monitorino.
fl 96.a.ii.Chevron Salt Lake City Refinery has included
equipment on the "delay of repair" list in Chevron's
reqular LDAR monitorinq.. Use its best efforts to isolate and repair pumps
identified as leaking at a rate of 2000 ppm or
oreater
1196.a.iii.Chevron Salt Lake City Refinery continues to use
best efforts to isolate and repair pumps identified as
leakinq at a rate of 2000 ppm or qreater.
. By no later than June 30, 2004, Chevron shall
take the following actions for any equipment
that it intends and is allowed to place on the
"delay of repai/' list under applicable
reoulations:
fl s6.b.See below.
For valves, other than control valves and
pressure relief valves, that qualifu to be on the
"delay of repai/' list, use the "drill and tap"
method (or an equivalent), rather than place a
valve on the "delay of repair" list, if it is leaking
at a rate of 50,000 ppm or greater unless
Chevron can demonstrate that there is a safety
or major environmental concern by attempting
to repairino the leak in this manner.
1le6.b.i Chevron Salt Lake City Refinery has met this
requirement for the current reporting period.
. Chevron shall perform the first "drill and tap"
(or equivalent repair method) within fifteen
days and a second attempt (if necessary)
within thirty (30) days after the leak is
detected.
,1196.b.i.Chevron Salt Lake City Refinery has met this
requirement for the current reporting period.
. Afier two unsuccessful attempts to repair a
leaking valve through the drill and tap (or
equivalent) method, Chevron may place the
leakino valve on its "delav of reoair" list.
1le6.b.i Chevron Salt Lake City Refinery has met this
requirement for the current reporting period.
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 23 o'f 25
For valves, other than control valves and
pressure relief valves, that qualify to be on the
"delay of repair" list, use the "drill and tap"
method (or an equivalent), rather than place a
valve on the "delay of repair" list, if it is leaking
at a rate of 10,000 ppm or greater unless
Chevron can demonstrate that there is a safety
or major environmental concern by attempting
to reoairino the leak in this manner.
fl 96.b.ii.Chevron Salt Lake City Refinery has met this
requirement for the current reporting period.
. Chevron shall perform a first and (if necessary)
a second "drill and tap" (or equivalent repair
method) as soon as practicable but not later
than 90 days afler such leak was detected.
1le6.b.ii.Chevron Salt Lake City Refinery has met this
requirement for the current reporting period.
. lf a new valve repair method not currently in
use by the refining industry is planned to be
used by Chevron, Chevron will advise EPA
prior to implementing such a method or, if prior
notice is not practicable, as soon as
oracticable after imolementation.
tf 96.c.
Chevron Salt Lake City Refinery has not used any
new valve repair methods not currently in use by the
refining industry.
Recordkeepinq and Reportinq Requirements for this Paraqraph. Consistent with the requirements of Section lX
(Recordkeeping and Reporting), Chevron shall
include the following information in the
progress report(s) for the quarter in which the
identified activitv occurred or was required:
fl 97.a See below
. An identification of the individual at the
Refinery responsible for LDAR performance as
required by 1193
fl 97.a.iv.Chevron Salt Lake City Refinery has identified an
individual responsible for LDAR performance. Kyle
Drach (HSE Manager) is the responsible individual
listed in the LDAR proqram.
. A copy of each Refinery's LDAR program
under 1183
tl97.a.viii.Not applicable for this reporting period.
. Chevron shall identifo each audit that was
conducted under Paragraph 85 in the previous
calendar year, including an identification of the
auditors, a summary of the audit results and
the actions that Chevron took or intends to
take to correct identified deficiencies.
ll e7.b.
The Salt Lake Refinery completed a third-party audit
in January 2024. The audit report and corrective
actions will be submitted in the semiannual report
covering January 1,2024 through June20,2024.
. ln Each Report due under 40 C.F.R. S 63.654,
Chevron shall include the information on LDAR
monitorinq outlined in 1197.c.i - fl97.c.ix.
fl97.c.The information outlined in fl97.c.i - fl97.c.ix. has
been included in all MACT semi-annual reports and
was submitted Januarv 15.2024.
Consent Decree, U.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31,2023
Attachment 1 Page 24 ol 25
Section V.N. - lncorporation of Consent Decree Requirements into Federallv
Enforceable Permits
Section Xvlll. - Termination
Consent Decree, IJ.S. v. Chevron USA lnc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31'2023
Attachment 1 Page 25 ol 25
Item to be Reported
CD
Reference Status
Obtaining Permit Limits for Consent Decree Emission Limits that Become Effective After Date of Entry
Except as set forth below in Paragraph 99.b,
as soon as practicable, but in no event later
than the later of ninety (90) days after the
effective date or establishment of any emission
limits and standards under Section V of this
Consent Decree orfifteen (15) days afterthe
Date of Entry of this Consent Decree, Chevron
shall submit applications to the appropriate
Plaintiff-lntervenor to incorporate those
emission limits and standards in federally
enforceable minor or major new source review
permits or other permits (other than Title V
permits) which are federally enforceable. Upon
issuance of such permit or in conjunction with
such permitting, Chevron shall file any
applications necessary to incorporate the
requirements of the permit into the Title V
permit of the refinery.
fl 99.a.On January 7 ,2015, the Chevron Salt Lake City
Refinery submitted a permit application for the final
FCCU NOx limits. All other necessary applications
have been submitted to Utah Division of Air Quality to
incorporate applicable emission limits and standards.
The Chevron Salt Lake City Refinery does not have a
final Title V permit. A Title V application has been
submitted (a reapplication was submitted on January
31 , 2020) and the incorporation of any emission limits
shall be in accordance with the State of Utah's Title V
rules.
Item to be Reported
CD
Reference Status
Certification of Completion: Paragraph 236
Chevron may certifo completion of the following
Consent Decree (CD) Sections:. Section V.A.: FCCU. Sections V.B - V.E.: FCCU. Sections V.F - V.G.: Heaters and Boilers. Section Vlll: Supplemental Environmental
Projects
fl 236 The Chevron Salt Lake City Refinery submitted a
certification of completion on December 17,2008
for CD Section Vlll. As of the conclusion of this
reporting period, EPA has not yet responded.
The Chevron Salt Lake City Refinery submitted a
termination package on July 16,2020. As of the
conclusion of this reporting period, EPA has not
yet responded.
Attachment 2
Attachments Related to Benzene Ytlaste NESHAP Prosram Enhancements
The following BWON information required to be submitted per Paragraph 82 is included in this
Attachment:
o Summary of all EOL benzene determinations and a summary of supporting sample results for the
period ot 111123 through 12131123 (u82.n.) including:o A list of all waste streams sampledo The results of the benzene analysis for each sample
FEB -2 Z0Zt
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