DAQ-2025-000433

Chewonv
Tel [phone]
I,IAH DEPAFTMENT OF FAX [phone]
E?WIBONMENTAL OUALITY
FEB - 2 ?C,24
DIVISION OF AIR QUALTN.'
I iai, I v,:) , v',.;,: I
RE: Chevron Products Company, Salt Lake Refinery - DAQE-ANIOI190106-22
Voluntary Disclosure Pursuant to Utah Environmental Self-Evaluation Act
Dear Mr. Bird:
Pursuant to the Utah Environmental Self-Evaluation Act (UESEA) in Utah Code $197-7-109, this letter
constitutes a voluntary disclosure of information by Chevron Products Company, Salt Lake Refinery
(Chevron). The Chevron refinery processes various crude oils and other feedstocks to produce
transportation fuels, petroleum coke, sulfur, and various byproducts. The refinery is regulated by
Approval Orders DAQE-ANl0l 190106-22 (dated August 24,2022, referred to herein as "refinery AO")
and DAQE-ANl0l190104-22 (dated September 26,2022, identified for informationalpurposes only).
Chevron identified noncompliance with the following permit conditions and regulations as related to
certain equipment approved by the refinery AO:
c 1.2 - "The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]"
o I.3 - "Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]"
Background Information and Findinss
From November 2023 through January 2024, Chevron initiated a voluntary environmental self-evaluation
to review the inventory of stationary engines installed at the refinery. This effort included conducting a
refinery tour.to review stationary engines installed at the engines and their design power ratings, verif ing
that certain engines onsite are EPA-certified engines, reviewing past engine-specific permitting efforts for
purposes of alignment with equipment at the refinery, and assessing whether the engines were accurately
identified in the refinery AO (collectively referred to hereafter as "self-assessment"). The self-assessment
was completed on January 12,2024 and the following findings were identified:
e Within Condition II.A.3l ofthe refinery AO, the following engine is authorized: "#1 CWT: One
Emergency Cooling Water Pump. Rating: 630 hp (470 kW)." The design power rating of the
installed engine is 665 mechanical horsepower power output (hpm), which exceeds the approved
design power rating.
. Within Condition ll.A.32 of the refinery AO, an engine/generator package is authorized as
follows: "Crude Substation: One Backup Generator. Rating: 820 hp (6l l kW)." The
engine/generator package at the refinery includes a nameplate engine design rating of 900 hpm
Troy Tortorich
Refinery Manager
Salt Lake Refinery
Chevron Products Company
685 South Chevron Way
Salt Lake City, UT 84054
February 2,2024
HAND.DELIVERED
Mr. Bryce Bird, Director
Division of Air Quality
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake Ciry, UT 84114-4820
Page I of5
REVIEWEDInitials: Date: August 22, 2024Compliance Status: OKFile #: 10119 (B2)
and generator rating of 600 kW. Chevron believes that the permitting associated with this engine
was erroneously based on its prime rating instead of standby (worst-case) rating, as related
manufacturer's documentation for that engine's make/model list similar engine power ratings.
o Within Condition II.A.33 of the refinery AO, the following engine/generator package is
authorized: "One Canal Fire Water Emergency Generator. Rating: 369hp (275 kW)". The design
power rating of the installed engine is 462 hpm and generator rating is 300 kW, which exceed the
approved design power ratings.
r Within Condition ILA.33 of the refinery AO, the following engines are authorized: "Three Fire
Water Pumps. Rating: 755 hp (563.5 kW) each." The design power rating of each installed
engine is 950 hpm, which exceeds the approved design power ratings.
As part of the comparison between the refinery AO and installed equipment, Chevron also identified
several instances of inconsistent representation of engines and generators in the refinery AO. Generally,
Conditions II.A.3l to II.A.35 authorize installation of engines and engine/generator packages, and often
only list a generator rating (e.g., 400 kW for the "HDN Substation: One Emergency Generator"
authorized by Condition II.A.31) and an associated hp rating (e.g., 536 hpm, which is identified by
converting the 400 kW rating to hp by multiplying by the hp-to-kW conversion factor of l.3a kW/hp).
When a generator is driven by an engine, the engine is usually configured with a greater design power
rating (e.g. 601 hpm for the "HDN Substation: One Emergency Generator") than that of the generator
(i.e.,400 kW/536 hpm). To minimize any potential for confusion , Chevron is proposing to amend the
Approval Order to identifu both the compressor rating and corresponding engine power rating . The
following instances of this issue were identified:
. Within Condition II.A.31 the following is authorized: "Second North Substation Generator: One
Emergency Generator. Rating: 670 hp (500 kW)" The engine/generator package at the refinery
includes a 500 kW generator that is driven by an engine with design power rating of 750 hpm.
o Within Condition II.A.31, the following is authorized: "HDN Substation. One Emergency
Generator. Rating: 536 hp (400 kW)." The installed equipment includes a 400 kW generator that
is driven by an engine with design power rating of 601 hpm.
o Within Condition 11.A.32, the following is authorized: "Admin Building: One Backup Generator,
Rating 1676hp (1250 kW)." The installed equipment includes a 1,250 kW generator that is
driven by an engine with design power ratingof 2,220 hpm.
o Within Condition 11.A.32, the following is authorized: "TCLR : One Backup Generator Rating:
168 hp (125 kW)." The installed equipment includes a 125 kW generator that is driven by an
engine with design power rating of 197 hpm.
. Within Condition I1.A.32, the following is authorized: 'North Tank Field: One Backup Generator*NEW*. Rating: 896 hp (600 kW)." The engine/generator package at the refinery includes a 600
kW generator that is driven by an engine with design power rating of 896 hpm (which converts to
668 kWm).
. Within Condition II.A.33 of the refinery AO, an engine/generator package is authorized as
follows: "FCC MCC: One Emergency Generator. Rating: 805 hp (601 kW)." The
engine/generator package at the refinery includes a 600 kW generator that is driven by an engine
with design power rating of 895 hpm.
Page 2 of5
. Within Condition II.A.33, the following is authorized: "Alky: One Emergency Generator. Rating:
670 hp (500 kW)." The installed equipment includes a 500 kW generator that is driven by an
engine with design power rating of 752 hpm.
o Within Condition ILA.34 of the refinery AO, an engine/generator package is authorized as
follows: "One Reformer Substation Emergency Generator. Rating: 400 kW." The
engine/generator package at the refinery includes a 400 kW generator that is driven by an engine
with design power rating of 616 hpm.
Finally, as part of the self-evaluation, Chevron identified that one recently purchased generator/engine
package does not match the equipment authorized as part of the refinery AO. The Notice of Intentr
submitted on January 27,2022 requested authorization of a new 400 kW WWTP Generator (driven by a
617 hpm Tier 3 engine). As part of the self-evaluation, Chevron discovered that a 600 kW generator was
onsite (with a 895 hpm Tier 2-rated engine) in a temporary staging area. Additional review confirmed
that Chevron ordered a 600 kW engine/generator package instead ofa 400 kW engine/generator package.
To date, the engine and generator have not been installed or operated at the refinery; specifically, the
engine has not fired fuel and the generator has not provided electrical power. Accordingly, Chevron does
not believe that any actions taken to date for this engine constitute noncompliance with a permit
condition. However, this finding was identified as part of the self-evaluation and the identified
discrepancy between the purchased generator/engine package and permitted equipment is anticipated to
be addressed as part of corrective actions identified below.
Anticipated Corrective Actions to Resolve Findinss
Chevron will initiate corrective actions to resolve the potential violations identified in this disclosure
within the 60-day timeframe specified in Utah Code $19-7-109(2Xc) (i.e., by April2,2024).
Specifically, Chevron will arrange a meeting with the refinery's NSR permitting engineer and identifl, the
appropriate approach and schedule for correcting the aforementioned Approval Order inconsistencies.
Chevron anticipates that a permitting action could reasonably require greater than 60 days to receive an
updated Approval Order.
Chevron is also initiating internal corrective actions to prevent future recurrence of these findings.
Chevron Environmental personnel will provide internal refresher training on air permitting and related
requirements, update its internal engines permitting guidance (which is used by non-Environmental
personnel when planning projects), update its internal handbook for Capital Projects to further clarifu
permitting and related requirements, and improve project tracking efforts between the permitting and
operation phases of projects. These efforts are expected to augment existing safeguards to minimize
recurrence of these findings.
Compliance with Utah Code $f 9-7-109(2)
The requirements of Utah Code $19-7-109(2) are satisfied as follows:
(a) Discovery through an environmental self-evaluation. As described by Utah Code $ 19-
7-103(4),the term "Environmental self-evaluation" means "a self-initiated assessment, audit, or review,
not otherwise expressly required by an environmental law, that is performed to determine whether a
person is in compliance with environmental laws. A person may perform an environmental self-
evaluation through the use of employees or the use of outside consultants." Chevron's audit qualifies as
I Chevron submitted a Notice of Intent on January 20, 2022, requesting to replace two existing generators with new generators.
Specifically, the existing North Tank Field Generator would be replaced by a new WWTP generator, and the existing North
Tankfield Generator would be replaced by a new North Tankfield Generator. Later communications between UDAQ and
Chevron suggested that the project qualified as a "Reduction in Air Pollutants" project pursuant to R307-40 I - I 2 due to decrease
in potential to emit.
Page 3 of5
an environmental self-evaluation. The audit was self-initiated, not otherwise expressly required by an
environmental law, and was conducted to determine the refinery's recordkeeping accuracy and
completeness for stationary engines installed at the refinery.
(b) Voluntary and prompt disclosure in writing within 21 days of discovery. The self-
assessment was concluded on January 12,2024. The deadline for disclosure is 2l days after the entity's
discovery of the violation (i.e., February 2,2024). This notification meets this requirement.
(c) Corrective action within 60 days of discovery of the violation, or within a reasonable
amount of time if the violation cannot be remediated within 60 days. Chevron will initiate a
permitting action with UDAQ within the 60-day timeframe specified by Utah Code $19-7-109(2)(d) to
update equipment authorized by the refinery AO.
(d) Written outline of reasonable steps the regulated entity will take to prevent a
recurrence. Chevron will initiate a permitting action with UDAQ within the 60-day timeframe specified
by Utah Code $19-7-109(2Xd).
Compliance with Utah Code $19-7-109(3)
The requirements of Utah Code $19-7-109(3) are satisfied as follows:
(a) Due diligence. As identified above, Chevron self-initiated an assessment to determine
accuracy of onsite engines and the aforementioned findings were identified. The facility used due
diligence and evaluated all stationary engines at the facility as part of the self-assessment.
(b) Not a recurrence of similarly-caused violation. The specific instances of potential
noncompliance identified in this disclosure are not a recuffence of similarly caused specific violations
within the past three years. Chevron is not aware of a similar violation for any other onsite equipment at
the refinery.
(c) Not a reckless or willful disregard of environmental laws. As identified above,
Chevron voluntarily initiated a review of engines at the refinery and identified the findings noted above.
Chevron did not recklessly or willfully disregarded the permit requirements or permitting regulations of
R307-401.
(d) Not performed for a fraudulent purpose. As identified earlier, Chevron initiated a
self-review to evaluate recordkeeping accuracy and completeness for stationary engines installed at the
refinery. Chevron did not initiate the self-assessment for a fraudulent purpose.
(e) Not related to a compliance investigation by UDAQ. Chevron is not aware of any
compliance investigation initiated by UDAQ related to stationary engines at the refinery.
(0 Not initiated due to a legally mandated requirement. The self-investigation was not
discovered pursuant to a legally mandated monitoring, testing, or sampling requirement prescribed by
law, rule, permit, order, or consent agreement.
(g) No serious actual harm or imminent and substantial endangerment to human health
or the environment. The findings that are subject to this disclosure do not result in serious actual harm
or imminent and substantial endangerment to human health or the environment. The engines that are
subject to this disclosure operate on limited-use basis and are limited to no more than I 00 hours of non-
emergency operation annually per engine.
Page 4 of5
Accordingly, this matter meets the factors for consideration regarding waiver of civil penalties. Chevron
will continue to work with LJDAQ to resolve this matter promptly and as efiiciently as possible.
Please contact Lauren Vander Werffat [phone] or [e-mail] if you have any
additional questions or need additional information.
Sincerely,
-- ,-2.4 Dar,+ F. rc-/ f,.(.;.1..(-'o-/
Troy Tortorich
Page 5 of5