DAQ-2025-001210

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BigWest'Oil:,333 W. Center Street . North Salt Lake Utah 84054 . 801.296.7700. www.bigwestoil.com
January 30,2025
CERTIFIED MAIL
RETURN RECErpr NO. 9589 0710 5270 2348 4973 96
Bryce Bird, Director
Division of Air Quality
Utah Department of Environmental Quality
P.O. Box 144820
Salt Lake city, Utah 84114-4820
RE: Consent Decree Progress Report - 2od Semiannual Report lor 2024
Reference DOJ Case Number: 90-5-2-1-07689
Civil Action Case Name: USA et al V. Big West Oil
Civil Action Case Number: l:13-cv-00121-BSJ
Dear Mr. Bird,
Pursuant to Paragraph 127 of the Consent Decree entered on November 14,2013, this letter, along with
its accompanying attachments, constitutes Big West Oil LLC's semi-annual progress report for the period
ending on December 31,2024.
Should any questions arise regarding this report or the data submitted, please contact Brady Miller at
[phone] or by email at [e-mail].
Consent Decree I :13-cv-0012 1-BCW: $IX. 128 - Certification:
I certify 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 person(s) who manage the system,
or the person(s) directly responsible for gathering the information, the information submitted is, to the
best of my knowledge and belief, true, accurate, and complete.
JdU
urAt.l DEPAitl' wIE I'l l- OF
ENVIRONI"4EN IAI. O UAT.ITY
DIVISION OF AIR QLIALITY
Alec Klinghoffer
Refinery Manager
B-2-10122
CC: CERTIFIED MAIL
RETURN RECEIPT NO. 9589 0710 5270 2348 4973 89
Director, Air Enforcement Division
Office of Civil Enforcement
U.S. Environmental Protection Agency
Mail Code 2241-A
1200 Pennsylvania Avenue, N.W. Washington D.C. 20460-0001
CERTIFIED MAIL
RETURN RECETPT NO. 9589 0710 5270 2348 4973 72
Director, Air Enforcement Division
Office of Civil Enforcement
Attn: Norma Eichlin
c/o Matrix New World Eng. Inc.
26 Columbia Turnpike
Florham Park, NJ 07932-2213
CERTIFIED MAIL
RETURN RECEIPT NO.9589 07t0 52702348 4973 6s
Assistant Regional Administrator
Office of Enforcement
Compliance and Environmental Justice
1595 Wynkoop Street
Denver, CO 80202-1129
CERTIFIED MAIL
RETURN RECEIPT NO. 9589 0710 5270 2348 4973 58
Utah Division of Air Quality
Multi Agency State Office Building
195 North 1950 West - 4th Floor
Salt Lake City, Utah 84116
Electronic copies to:
j [e-mail]
[e-mail]
[e-mail]
Progress Report on the Implementation of the Requirements of Part V (Affirmative Relief/Environmental
Projects) - $IX. 127.a.(1) July 1,2024, through December 31,2024
CD Requirement CD
Reference Status/Comment
Part V.A. - NOx Emissions Reductions from FCCU
BWO shall implement a program to reduce NOX
emissions from the FCCU at the BWO Refinery.
Pursuant to Parl V.M (Incorporation into Federally-
Enforceable Permits), Big West Oil shall incorporate
emission limits established under fl I 2 into federally-
enfbrceable permits. BWO will monitor compliance
with the emission limits through the use of CEMS.
flll BWO has implemented a program to reduce NOx
emissions from the FCCU at the BWO Refinery
and limits are established into federally
enforceable permits. BWO continues to monitor
compliance of the emissions limits using CEMS.
NOx Emission Limit at FCCU. BWO shall comply
with NOx emission limits of 40 ppmvd at 0% 02 on
a 365-day rolling average basis and 60 ppmvd at 0%
02 on a 7-dav rolline averase basis from the FCCU.
fl 12.BWO has complied with the FCCU NOx
emissions limits during this reporting period.
NOx emissions during periods of SSM of the FCCU,
willnot be used in determining compliance with the
7-day average NOx emission limit established
pursuant to fl12, provided that during such periods
BWO implements good air pollution control practices
to minimize NOx emissions. Nothing in this fl shall
be construed to relieve BWO of any obligation under
any federal or state law, or regulation, or permit to
report emissions during periods of SSM or to
document the occurrence and/or cause ofa SSM
event.
fll 3.BWO has operated the FCCU in accordance with
good air pollution control practices to minimize
NOx emissions.
Demonstrating Compliance with FCCU NOx
Emission Limits. Beginning no later than the Date of
Entry, BWO shall use NOX and 02 CEMS to
monitor performance of the FCCU and to report
compliance with the terms and conditions of this
Consent Decree. The CEMS will be used to
demonstrate compliance with the respective NOX
emission limits established pursuant to fl12. BWO
shall make CEMS data available to EPA and the
State of Utah upon request as soon as practicable.
'lll4.The NOx and 02 CEMS continue to be used to
monitor performance of the FCCU and to report
compliance with the terms and conditions of this
CD.
Part V.B. - SO2 Emissions Reductions from FCCU
BWO shall implement a program to reduce SO2
emissions from the FCCU at the BWO Refinery.
Pursuant to Part V.M. (lncorporation into Federally-
Enforceable Permits) of this Consent Decree, BWO
shall incorporate SO2 emission limits established
under fl23 into federally-enforceable permits. BWO
will monitor compliance with the emission limits
throueh the use of CEMs.
ct))|- -'BWO has implemented a program to reduce SO2
emissions fiom the FCCU at the BWO Refinery
and limits are established in federally-enforceable
permits. BWO continues to monitor compliance of
the emissions limits using CEMS.
SO2 Emission Limit. BWO shall comply with SO2
emission limits of 25 ppmvd at 0%o 02 on a 365-day
n23.For any deviations of this limit, please see the 3rd
and 4th quarter 2024 CEMS Excess Emission
United States, et al. v. Big West Oil, LLC - Civil Action No. I : I 3-CV-0012 I BSJ
Semi-Annual Progress Report
July 01, 2024,through December 31,2024
rolling average basis and 50 ppmvd at0%o 02 on a 7-
day rolling average basis from the FCCU.
Reports submitted to Utah's Division of Air
Quality.
SO2 emissions during periods of SSM of the FCCU
if it is controlled by catalyst additives, or during
periods of malfunction of a wet gas scrubber or SO2
reducing catalyst additive system, will not be used in
determining compliance with the 7 -day average SO2
emission limits established pursuant to fl23, provided
that during such periods BWO implements good air
pollution control practices to minimize SO2
emissions.
fl24.BWO continues to use SO2 Reducing Catalyst
Additive system. BWO has operated the FCCU in
accordance with good air pollution control
practices to minimize SO2 emissions during
periods of SSM.
Demonstrating Compliance with FCCU S02
Emission Limits. BWO shalluse SO2 and 02 CEMs
to monitor performance of the FCCU and to reporl
compliance with the terms and conditions of this CD.
The CEMs will be used to demonstrate compliance
with the respective SO2 emission limits. BWO shall
make CEMs data available to the EPA and the State
ofUtah uDon reouest as soon as oracticable.
fl2s.The SO2 and 02 CEMS continue to be used to
monitor performance of the FCCU and to report
compliance with the terms and conditions of this
CD.
Part V.C. - PM Emissions Reductions from FCCU
BWO shall install a Flue Gas Filter system,
manufactured by Pall Corporation at the FCCU to
control emissions of PM
fl32.
fl38.
BWO continues to operate the Flue Gas Pall Filter
system to control emissions of PM from the
FCCU.
Emission Limils. BWO shall comply with a FCCU
PM emission limit of 0.5 pounds of PM per 1000 lb
ofcoke bumed on a 3-hr average basis, and continue
to comply with all other applicable requirements
regarding emission of PM from the FCCU that have
been established by UDEQ.
fl33.The refinery complied with the FCCU emissions
limits and continues to comply with all other
applicable requirements regarding emission of PM
from the FCCU that have been established by
UDEQ.
Interim Emission Limit for PM for the FCCU.fl34 See below.
PM Testingfor FCCU. BWO shall follow the stack
test protocol specified in 40 C.F.R. $ 60.106(b)(2) to
measure PM emissions from the FCCU, and shall
thereafter conduct annual stack tests at the FCCU no
later than October 3 I st of each year unless an
approval for less frequent testing is granted by the
EPA.
fl3s BWO has continued to follow the stack test
protocol specified to measure PM emissions from
the FCCU on an annual basis, except as noted
below. All stack tests under this CD have
demonstrated compliance with the PM emissions
limit offl33.
BWO requested a reduction in frequency of PM
testing on May 7 , 2019. BWO was approved to
conduct PM testing once every three years on
October 28,2021.
The most recent stack test was completed by
Alliance Source Testing on December 15,2023.
The next stack test is tentatively scheduled for
December 2026.
PM emissions during SSM shallnot be used in
determining compliance with the 3-hr average
emission limits set forth in fl33, provided that during
fl36.BWO continues to implement good air pollution
control practices to minimize PM emissions.
United States, et al. v. Big West Oil, LLC - Civil Action No. I : l3-CV-0012 I BSJ
Semi-Annual Progress Report
July 01, 2024, through December 31, 2024
such periods BWO implements good air pollution
control practices to minimize PM emissions.
Opacity Monitoring at FCCUs. BWO shall install
and operate a Continuous Opacity Monitoring System
("COMS") to monitor opacity at the FCCU. BWO
shall install, certify, calibrate, maintain, and operate
all COMS required by this CD.
1137.The COMS continues to be used to monitor
performance of the FCCU and to report
compliance with the terms and conditions of this
CD.
The COMS continues to be certified, calibrated,
maintained, and operated according to the CD
requirements.
Reporting. BWO shall include detailed reporting
regarding status of the installation of the filter system
and related infrastructure required pursuant to fl32 in
the reports required by Section IX (Reporting and
Recordkeenins).
fl38.Not applicable during this reporting period.
Part V.D. - CO Emissions Reductions from FCCU
CO Emissions Limitfor the FCCU. BWO shall
comply with an FCCU CO emission limit of 500
ppmvd on a l -hour average basis at 0o/o 02 and
continue to comply with all other applicable
requirements regarding emissions of CO from the
FCCU that have been established by UDEQ.
fl3e
fl41.
The refinery complied with the FCCU CO
emissions limits for this reporting period, except as
noted below, and continues to comply with all
other applicable requirements regarding emissions
of CO from the FCCU that have been established
by UDEQ.
BWO has operated the FCCU in accordance with
good air pollution control practices to minimize
CO emissions.
A summary of deviations has been prepared and is
included below in the table named:
Part lX.l27 .c.( I )(a),(c) - Duration of
Exceedance(s) and Downtime as % of Operating
Time ner Ouarter
NSR Emission Limit for CO for FCCU. At any time
during the term of the CD, BWO may accept a Final
CO Limit of 100 ppmvd on a 365-day rolling average
basis at 0% 02 for its FCCU.
fl40.Option is not currently under consideration.
Part V.E. - Demonstratins Compliance with FCCU Emissions Li mits
CEMS will be used to demonstrate compliance with
the NOx, SO2 and CO emission limits established
pursuant to !f 12, fl23, and fl39. BWO shall make
CEMs data available to EPA upon request as soon as
practicable. BWO shall install, certify, calibrate,
maintain, and operate all CEMS required by this CD.
BWO must conduct either a Relative Accuracy Audit
("RAA") or a Relative Accuracy Test Audit
("RATA") on each CEMS at least once every three
(3) years. BWO must also conduct CGAs each
calendar quarter during which a RAA or RATA is not
performed.
1142.BWO continues to use CEMS to demonstrate
compliance with the NOx, SO2 and CO emission
limits established pursuant to fl12, fl23, and fl39.
The NOx, SO2, and CO CEMS continue to be
certified, calibrated, maintained, and operated
according to the CD requiremcnts.
BWO is compliant with the FCCU CEMS
RAA/RATA. The most recent FCCU CEMS
RATA was conducted by Erthwrks, Inc. on April
11,2024.
United States, et al. v. Big West Oil, LLC - Civil Action No. I : l3-CV-0012 I BSJ
Semi-Annual Progress Report
July 0 1, 2024, through December 31, 2024
Part V.F. - NSPS Applicabilitv of the FCCU Reeenerator
The FCCU shall be an affected facility and shall be
subject to and comply with the requirements of NSPS
Suboarts A and J for all oollutants.
fl43.The FCCU is subject to NSPS Subparts A and J.
Part V.G. - NOx Emissions Reductions from Heaters and Boilers
BWO shall comply with the NOx emission limits of
0.035 lb/mmBTU on a 3-hour average for Covered
Heaters and Boilers (H-404, BLR-1, BLR-2, and
BLR.6).
1144.The refinery complied with the emissions limits
during this reporting period.
Monitoring NOx Emissions from Covered Heaters
and Boilers. BWO shall monitor and test to meet
requirements of 1144.
fl45.All BWO Covered heaters and boilers have a heat
input capacity ofequal to or less than 100
MMBTU/hr (HHV). Please refer to Semi-Annual
CD Reoort Julv 2014.
BWO shall include in the semi-annual reports
pursuant tolll27, a section describing installation of
ULNR burners.
fl46.Please see previous semi-annual reports.
Part V.H. - S02 Emissions Reductions from Heaters and Boilers & NSPS Apnlicabilitv
BWO shall undertakc measures to reduce SO2
emissions from heaters and boilers by restricting H2S
in Refinery fuel gas and by agreeing not to continue
and/or commence combusting Fuel Oil except under
the provisions set forth herein.
n47 BWO continues to undertake measures to reduce
SO2 emissions from Refinery heaters and boilers.
NSPS Applicability of Heaters and Boilers. All
heaters and boilers at the BWO Refinery shall be
affected facilities as that term is used in 40 CFR 60,
Subparts A and J. BWO shall install, certify,
calibrate, maintain, and operate a fuel gas CEMs.
fl48.BWO is monitoring and reporting under and as
required by NSPS Subparts A and J for all heaters
and boilers at the Refinery. There were no
exceedances ofthe short-term (3-hour rolling) or
long-term (annual) fuel gas H2S limits during the
semi-annual period covered by this report.
The fuel gas CEMS continues to be certified,
calibrated. maintained. and operated.
Elimination/Reduction of Fuel Oil Burning. BWO
shall not combust Fuel Oil in any fuel gas
combustion device except during periods of Natural
Gas Curtailment. test runs, and operator training.
Nothing herein is intended to limit or shall be
interpreted as limiting the use of torch oil during
FCCU Startups.
n4e.The refinery complied with the
elimination/reduction of fuel oil in any fuel gas
combustion device except under the provisions set
forth in fl49.
Part V.I. - Sulfur Recovery Plant
BWO owns and operates a Sulfur Recovery Plant
located at the BWO Refinery that consists of one 3
stage Claus recovery unit with a tail gas incinerator
with a rated caoacitv of 4 lons tons oer dav.
fls0.BWO continues to operate the Sulfur Recovery
Plant with one 3 stage Claus recovery unit with a
tail gas incinerator with a rated capacity of 4 long
tons per dav.
Caustic Scrubbers. BWO shall install and operate a
caustic scrubber system to contact the sour fuel gas
with caustic solution to extract H2S; and expand its
sour water storage capacity to shut down the SWS
and store sour water during SRP outages to ensure
flsl BWO continues to operate a caustic scmbber
system to contact the sour fuel gas during amine
unit outages and manages the sour water storage
capacity to shut down the SWS during outages of
the SRP to ensure compliance with NSPS Subpart
United States, et al. v. Big West Oil, LLC - Civil
Semi-Annual Progress Report
July 01, 2024, through December 31, 2024
No. l:13-CV-00121 BSJ
compliance with NSPS Subpart J at the fuel gas
combustion devices (heaters and boilers) and NSPS
Subpart Ja at the flares during amine unit and SRP
outages.
Ja at the fuel gas combustion devices (heaters and
boilers) and NSPS Subpart Ja at the flares during
the amine unit and SRP outages.
Sulfur Tank Emissrans. BWO shall route all sulfur
tank emissions from the SRP so that sulfur tank
emissions are either eliminated or included and
monitored as part of the applicable Sulfur Recovery
Plant (SRP) tail gas emissions limits set forth in the
applicable State of Utah Administrative Order.
ns2 BWO continues to route all sulfur tank emissions
from the SRP so that sulfur tank emissions are
either eliminated or included and monitored as part
of the applicable Sulfur Recovery Plant (SRP) tail
gas emissions limits set forth in the applicable
State of Utah Administrative Order.
Sulfur Recovery Plant Emissions Compliance. BWO
shallcomply with a 95o% recovery efficiency
requirement for all periods of operation except during
periods ofscheduled startup, scheduled shutdown, or
malfunction of the SRP. Recovery efficiency will be
determined on a daily basis; however, compliance
will be determined on a rollins 3O-dav averase basis.
fls3.BWO continues to be in compliance with the 95oh
recovery efficiency requirement rolling 30-day
average for this reporting period.
BWO shall immediately notify EPA and the State of
Utah in writing if monitoring indicates that sulfur
input to the SRP exceeds 20 LTPD.
fls4.BWO continues to be in compliance. Sulfur input
is well below the limit of 20 long tons in any
calendar day.
Good Operation and Maintenance. BWO shall
submit a Preventative Maintenance and Operation
Plan and comply with the plan at all times including
SSM. Any modifications made by BWO to the PMO
plan that are related to further minimizing Acid Gas
Flaring and/or SO2 emissions shall be summarized in
the semi-annual reoorts.
fl5s - fls6.BWO complies with the PMO Plan at all times,
including periods ofscheduled start up, scheduled
shut down, and malfunction of the SRP.
PMO Plan submittal dated May 8,2014.
Optimization Study. BWO shall complete an
optimization study on the SRP and report to EPA and
UDEQ. BWO shall implement the recommendations
of the optimization study and incorporate the results
of that study into the PMO Plan.
fl57.The Optimization Study was completed and
submitted. BWO implemented the
recommendations and incorporated the results of
that study into the PMO Plan.
BWO continues to operate a SRP that consists of
one 3 stage Claus sulfur recovery unit with a tail
gas incinerator with a rated capacity of 4 long tons
per day. BWO continues to comply with the
Preventative Maintenance and Operation Plan and
Ootimization Studv.
Reporting. BWO shall include detailed reporting of
the installation of the caustic scrubber systems in
semi-annual reports.
fls8,Please see previous semi-annual reports.
Part V.J. - NSPS Applicabilitv & Compliance for Flarine Devices
NSPS Subparts A and Ja shall apply for both BWO
flares. BWO shalI install, operate, calibrate and
maintain H2S CEMS at refinery flares in compliance
with Subpart Ja.
flse Flaring Devices at the BWO Refinery are
monitored and reported under and as required by
NSPS Subparts A and Ja. BWO continues to
operate, calibrate, and maintain CEMS on both the
South and West Flares. See fl127.c(l)(a-c).
United States, et al. v. Big West Oil, LLC - Civil Action No. l:13-CV-0012 I BSJ
Semi-Annual Progress Report
July 01, 2024,through December 31,2024
Good Air Pollution Control Practices. For all Flaring
Devices at the BWO Refinery, BWO shallcomply
with the NSPS obligation to implement good air
pollution control practices as required by 40 C.F.R. $
60.1 I (d) to minimize HC and AG Flarins Incidents.
fl60.For all flaring devices, BWO complied with the
NSPS obligation to implement good air pollution
practices to minimize flaring incidents during this
reporting period.
Flaring History. BWO has submitted a report to EPA
identifying each AG Flaring Incident between
I I I 1012004 and 812012010.
fl61 See previous reporting.
Provisions Applicable to Control of Floring
Incidents.
n62.See below.
BWO shall cornply with the provisions of fl63
through fl70 until the RCA and CA requirements for
flares under Suboart Ja become aoolicable.
\62.a.The root cause analysis and corrective action
requirements of Subpart Ja are incorporated into a
permit Dursuant to tTl07.
BWO shall comply with the provisions in Subpart Ja
regarding the investigation of the cause of flaring
incidents subject to investigation and corrective
action under Subpart Ja. Each Flaring Incident Report
shall be included in the Semi-Annual Report required
bv fl69.
n62.b.See fl69 below.
Interim Control of Acid Gas Flaring Incidents.
BWO agrees to implement a program to investigate
the cause of future AG flaring incidents, to take
reasonable steps to correct the conditions that have
caused or contributed to such incidents and to
minimize AC Flaring Incidents. BWO shall follow
procedures to evaluate whether future AG flaring
incidents are due to malfunctions or are subject to
stioulated oenalties.
fl63.There were no acid-gas flaring incidents during
this reporting period.
Investigation and Reporting. No later than 45 days
after an acid gas flaring incident, BWO shall conduct
an investigation into the root causes of the flaring
incident and record the result of the investigation.
Each incident report shall be included in the semi-
annual reDort.
1164.There were no acid-gas flaring incidents during
this reporting period.
Corrective Action. ln response to any AG flaring
incidents, BWO shall take, as expeditiously as
practicable, such interim and/or long+erm corrective
actions as are consistent with good engineering
practice to minimize the likelihood of a recurrence of
the root cause and all contributing causcs of the AG
flaring incident.
fl6s - fl67.There were no acid-gas flaring incidents during
this reporting period.
Tsil Gas Incidents. a. Investigation, Reporting,
Correclive Actiotr, and Stipulated Penalties. For tail
gas incidents BWO shall follow the same
investigative, reporting, and corrective action
requirements. These procedures shall be applied to
TGU shutdowns, bypasses of a TGU, or other events
which result in a Tail Gas Incident, including
unscheduled shutdowns of the Claus Sulfur Recoverv
fl68 There were no tail gas incidents during this
reporting period.
United States, et al. v. Big West Oil, LLC - Civil Action No. I :13-CV-00121 BSJ
Semi-Annual Progress Report
July 0l ,2024, through December 31,2024
plant. b. Calailqtion of the Qtv of SO2 Emissions
Resultingfiom a Tail Gas Incident See fl68.b
Semi-Annusl Reporting. BWO shall submit to EPA
and the State of Utah a Semi-Annual report that
includes copies of each and every report of all Acid
Gas Flaring lncidents, Tail Gas Incidents and
Hydrocarbon Flaring Incidents that BWO was
required to preDare.
fl6e All Acid Gas Flaring Incidents, Tail Gas Incidents
and Hydrocarbon Flaring lncidents that BWO was
required to prepare under !162.b, 64,68 and 70
during the previous six-month period are included
in this Semi-Annual Report if applicable for the
renortins oeriod under Attachment 2.
Control of Hydrocarbon Flaring Incidents. BWO
shall follow the same investigative reporting and
corrective action procedures as for AG flaring
incidents; provided however, that in lieu of analyzing
possible CA and taking interim and/or long-term CA
for a Hydrocarbon Flaring Incident attributable to the
startup or shutdown of a unit has previously been
analyzed. Use same formulas asn6'7.
fl70.There were no hydrocarbon flaring incidents
during this reporting period.
Part V.K. - Benzene Waste Operations NESHAP Program Enhancements
In addition to complying with Subpart FF, BWO
agrees to continue compliance with Subpart FF and
minimize or eliminate fugitive benzene waste
emissions.
fl71 BWO continues to comply with Subpart FF.
BWO has a TAB of less than l0Mg/yr. BWO will
review and verify the TABs at BWO refinery
consistent with the One-Time Review and
Verification.
n72.BWO complies with fl72.
If at any time BWO is determined to have a TAB
equal to or greater than l0 Mg/yr, BWO shall comply
with the compliance option set forth at 40 C.F.R. $
6l .342(e) (hereinafter referred to as the "6 BQ
compliance option").
fl73.BWO Refinery Total Annual Benzene ("TAB")
remains less than l0 Mg/yr.
One-Time Review and Verification of the BWO
Refinery's TAB. a. Phase One of the Review and
Verification Process. BWO shall complete a review
and verification of the TAB of the BWO Refinery. b.
Phase Two of the Review and Verification Process.
EPA may select up to 20 additional waste streams
uoon review.
1t'74.One-time review and verification of BWO
Refinery's TAB is complete.
Implementation of Actions Necessary to Correct
Non-Compliance.
n7s.See below.
a. Amended TAB Reports. If the results of the
BWON Compliance Review and Verification Report
or Amended BWON Compliance Review and
Verification Report indicate the BWO failed to file
the reports required or the filed report is inaccurate,
BWO shall submit an amended TAB report.
ll7 5.a.Not applicable for this reporting period.
United States, et al. v. Big West Oil, LLC
Semi-Annual Progress Report
July 01, 2024,through December 31,2024
Action No.BSJ
b. If the results indicate that BWO has a TAB over
l0Mg/yr, BWO shall submit to EPA and UDEQ a
plan that identifies with specificity the compliance
strategy and schedule that BWO shall implement to
ensure that the BWO refinery complies with the 6BQ
compliance option as soon as practicable.
fl7s.b.Not applicable for this reporting period.
c. Review and Approval of Plans Submitted Pursuant
to tl75b. Any plan submitted shall be subject to
approval, disapproval, or modification by EPA.
ll7 5.c.Not applicable for this reporting period.
d. Certification of Compliance with the 6BQ
Compliance Option. BWO shall submit a report to
EPA and UDEQ that the Refinery complies with
BWON.
fl75.d.Not applicable for this reporting period.
Annual Program. BWO shall establish, maintain, and
conduct an annual program for reviewing process
information for the BWO Refinery, including but not
limited to construction projects, to ensure that all new
benzene waste streams are included in the BWO
Refinery's waste stream inventory and TAB.
n76.BWO continues to annually review process
information for the BWO Refinery, including but
not limited to construction projects, to ensure that
all new benzene waste streams are included in the
BWO Refinery's waste stream inventory and
TAB.
Benzene Spills. For each spill at the refinery, BWO
shall review such spills to determine if benzene waste
was generated. BWO shall include benzene generated
by each spill(s) of 10 pounds or more of benzene in
any 24-hour period in the annual program TAB for
the BWO Refinerv.
fl77.There were no reportable spills that generated l0
pounds or more ofbenzene in any 24-hour period
during the reporting period.
Troinins.fl78.See below.
a. BWO shall develop and implement annual training
for all employees asked to draw benzene waste
samples.
!178.a.All employees and contractors asked to draw
benzene waste samples between July 01, 2024, to
December 31,2024, have completed BWON
annual computer-based training or equivalent
classroom trainins durins the reoortins oeriod.
b. If the TAB reaches l0Mg/yr or more BWO shall
develop and maintain SOP for all control equipment
used with BWON.
u78.b.Not applicable for this reporting period.
c. BWO must ensure that all contractors hired to
oerform BWON are properly trained.
u78.c.See !178.a. above.
lYaste/Sloo/Off-Soec Oil Manas ement.fl79.See below.
a. BWO shallprepare schematics that will be
submitted as part of the EOL Sampling Plan.
1179.a.EOL Sampling Plan and schematics submitted.
please see prior reporting.
b. Organic Benzene Waste Streams. If TAB reaches
l0Mg/yr and a compliance strategy is approved, all
waste management units handling benzene wastes
shall meet applicable control standards of Subpart FF
or asree to a schedule for completion.
fl79.b.Not applicable for this reporting period. TAB rs
below l0 Mg/yr.
c. Aqueous Benzene Waste Streams. Calculating the
TAB.
\79.c.Not applicable for this reporting period. TAB is
below l0 Me/vr.
d. PIan to Ouantify Uncontrolled Waste/Slop/Off-
Spec Oil Streams. Quantified in the EOL Sampling
Plan.
fl7e.d.Not applicable for this reporting period.
Periodic Sampling (TAB less than l0 MS/yr}fl80 See below.
United States, et al. v. Big West Oil, LLC - Civil
Semi-Annual Progress Report
July 0 l, 2024, throtgh December 3 l, 2024
Action No. I : l3-CV-00121 BSJ
a. These provisions shall apply when the One-Time
Review and Verification shows that the TAB is equal
to or greater than I Mg/yr but less than 10 Mglyr.
fl80.a.BWO continues to comply with the provisions of
fl80. All TAB submissions remain equal to or
greater than I Mg/yr but less than l0 Mg/yr.
The 2023 TAB report dated April 3,2024,
estimated that approximately 3.34 metric tons of
benzene were contained in the refinery process
waste streams for the 2023 ooerutins vear.
b. BWO shall conduct sampling of allwaste streams
(consistent with $61.355(c)(l) and (3)) that
contributed 0.05 Mg/yr or more to the TAB set in the
BWON Compliance Review and Verification Report,
Amended BWON Compliance and Verification
Report, or previous year's TAB, whichever is later.
fl80.b.BWO conducted annual sampling of all waste
streams containing benzene that contributed 0.05
Mglyr. or more in the previous year's TAB during
the reporting period.
Additional Information is included in Attachment
3.
c. EOL Sampling Plan. EOL sampling plan submitted
to EPA and UDEQ. If changes in processes,
operations, or other factors lead BWO to conclude
that either the approved sampling locations and/or the
approved methods for determining flow calculations
no longer provide an accurate measure of the BWO
refinery's EOL benzene quantity, BWO shall submit
a revised plan to EPA for approval and a copy ofthe
revised plan shall be submitted to the UDEQ.
fl80.c.Big West Oil submitted a modification to the EOL
sampling plan to the EPA and the UDEQ on April
11,2024, to address changes to the approved
sampling locations and a general update to the
plan. The EPA accepted the modified EOL
sampling plan on May 20,2024.
Big West Oi[ implemented the modified plan on
May 30, 2024. Any EOL sampling that took place
on or after May 30, 2024,was conducted
according to the modified EOL plan.
d. BWO shall conduct an EOL determination of
benzene quantity. BWO shall take and have analyzed
at least three representative samples from each
approved sampling location, with three of the
samples in each calendar quarter spaced at least one
month apart. BWO shall use the average of these
three samples as the benzene concentration for the
stream at the approved location. Based on the EOL
quarterly sampling results and the approved flow
calculations, BWO shall calculate the quarterly EOL
benzene quantity and a projected calendar year TAB,
utilizing all EOL results for that calendar year and
any other information (such as process turnarounds)
to undertake the oroiection.
fl80.d.BWO has taken and analyzed at least three
representative samples tiom each proposed
sampling location in each calendar quarter
consistent with the approved EOL Sampling Plan.
Big West Oil conducted testing from the updated
sampling locations in the modified plan.
Additional information is included in Attachment
J.
If the quarterly EOL benzene quantity is calculated to
exceed 2.5 Mg, BWO shall submit to EPA and
UDEQ an explanation of the excess benzene waste
generated. BWO shall submit this explanation within
30 days after the end of the quarter which resulted in
an EOL benzene ouantitv sreater than 2.5 Ms.
tj80.d. ( l )Not applicable for this reporting period.
United States, et al. v. Big West Oil,
Semi-Annual Progress Report
July 0 l, 2024, through December 31, 2024
Action No. 1: I 3-CV-0012 I BSJ
If the projected calendar year TAB is calculated to
equalor exceed l0 Mg, BWO shall submit to EPA
and UDEQ a plan that identifies with specificity the
actions and schedule for such actions that BWO will
take to ensure that the TAB for the BWO Refinery
does not exceed l0 Mg in the calendar year. BWO
shall submit this plan within 30 days after the end of
the quarter which resulted in a projection greater than
10 Ms.
fl80.d. (2)Not applicable for this reporting period.
Ifit appears that appropriate action cannot be taken to
ensure that the BWO Refinery maintains a TAB of
under l0 Mglyr BWO shall retain a third-party
contractor to undertake a comprehensive TAB study
and compliance review. Within sixty days of
submitting the plan, BWO shall submit a proposal to
EPA and UDEQ that identifies the contractor, the
contractor's scope of work and the contractor's
schedule for the third-party TAB study and
Compliance Review.
fl80.e.Not applicable for this reporting period.
Periodic Sampling (TAB of l0 MG/yr or More).fl81 See below.
Only applicable if BWO Refinery's TAB reaches or
exceeds 10 Ms/yr.
fl81 - fl82 Not applicable for this reporting period.
Recordkeeping and Reporting Requirements for this
Part V.K. At the times specified in the applicable
provisions of this Part, BWO shall submit, as and to
the extent required, the following reports to EPA and
UDEQ: Reports required pursuant to 40 C.F.R.
$61.357 and the Semi-annual Progress Report
Procedures of Part IX (Reporting and Record
Keenins) shall continue to aoolv.
fl83.See below and !180.d.( I )-(2).
BWON Compliance Review and Verification Report
('u74), as amended, if necessary;
!f83.a.Not applicable for this reporting period.
Amended TAB Report, if necessary, pursuant to fl
7 5.a.
1183.b.Not applicable for this reporting period.
Plan for the BWO Refinery to come into compliance
with the 6 BQ compliance option upon discovering
that its TAB equals or exceeds l0 Mg/yr through the
BWON Compliance Review and Verification Report
(tj75.b), or the Third-Party TAB Study and
Compliance Review that may result from EOL
samolinq (tl80.e):
flS3.c.Not applicable for this reporting period.
Compliance certification. if necessary tl75.d:{83.d.Not applicable for this report ns period.
Schedule to complete implementation of controls on
waste management units handling organic benzene
waste, if necessary (fl79.b);
fl83.e.Not applicable for this reporting period
EOL Sampling Plans (fl80.c and !f8l.b), and revised
EOL Sampling Plans, if necessary (fl80.c and flS1.c);
fl83.f.Refer to fl80.c. of this report.
Plan, if necessary, to ensure that uncontrolled
benzene does not equal or exceed, as applicable, 6 or
l0 Mg/yr, or is minimized, based on projected
fl83.e.Not applicable for this reporting period.
United States, et al. v. Big West Oil,
Semi-Annual Progress Report
July 01, 2024,through December 31,
LLC - Civil Action No. I : l3-CV-0012 I BSJ
2024
calendar year uncontrolled benzene quantities as
determined through EOL sampling (fl80.d.(1),
fl80.d.(2), and fl80.e);
Proposal for a Third-Party TAB Study and
Compliance Review, if necessary (fl80.e and fl81.0;
tTS3.h.Not applicable for this reporting period.
Third-Party TAB Study and Compliance Review, if
necessary (t180.e and !l8l.f1; and
fl83.i Not applicable for this reporting period.
Plan to implement the results of the Third- Party
TAB Study and Compliance Review, if necessary
(fl80.e and flS1.fl.
fl83.j Not applicable for this reporting period.
Reports Required under the Semi-annual Progress
Report Procedures of Part IX (Reporting and
Record Keeoind.
fl84.See below.
Refinery TAB > I Mg/yr but < l0 Mg/yr - BWO
shall submit the following information in Serni-
annual Progress Reports pursuant to the requirements
of Part IX (Reporting and Record Keeping) of this
Consent Decree:
'llT84.a.See below.
A description of the measures that it took to comply
with the training provisions of fl 78;
fl84.a.( I )Refer to'l[78.a, fl78.b and !f78.c of this report.
The annual, non-EOL sampling required at the BWO
Refinery pursuant to the requirements of
Subparagraph 80.b (Periodic Sampling<lOMG) (this
information shall be submitted in the first Semi-
annual Drosress report ofeach year);
flS4.a.(2)lnformation is included in Attachment 3.
The results of the quarterly EOL sampling
undertaken pursuant to Subparagraph 80.d (Periodic
Sampling) for the Calendar quarter. The report shall
include a list of all waste streams sampled, the results
of the benzene analysis for each sample, and the
computation of the EOL benzene quantity for the
respective quarter. The BWO Refinery shall identify
whether the quarterly benzene quantity equals or
exceeds 2.5 Mg and whether the projected calendar
year benzene quantity equals or exceeds l0 Mg. If
either condition is met, the BWO Refinery shall
include in the Semi-annual report the plan required
pursuant to fl80.e. and shall specifically seek EPA's
concurrence in the olan.
fl8a.a.(3)lnformation is included in Attachment 3.
TAB is l0 Mg/yr or more. If the BWO Refinery's
TAB reaches or exceeds l0 Mg/yr, BWO shall
submit the following information in the Semi-Annual
Reoorts.
fl84.b.Not applicable for this reporting period.
Agencies to Receive Reports, Plan and
Certijications Required in the Part. BWO shall
submit all reports, plans and certifications required to
be submitted under this Part to EPA and UDEQ.
fl85.Not applicable for this reporting period.
United States, et al. v. Big West Oil, LLC - Civil Action No. l: l3-CV-00121 BSJ
Semi-Annual Progress Report
July 01, 2024,through December 31,2024
Laboratory Audits. BWO shall conduct audits of all
laboratories that perform analyses of BWO's benzene
waste operations NESHAP samples to ensure that
proper analytical and quality assurance/quality
control procedures are followed. These audits may be
conducted either by BWO personnel or third parties.
BWO may retain third parties to conduct these audits
or use audits conducted by others as its own, but
BWO has the sole responsibility and obligation to
ensure comoliance with this CD and Subpart FF.
!186.a.BWO last conducted a third-party audit of the
Chemtech-Ford Laboratories facitiry located in
Sandy, Utah on May 8, 2024. An audit is not
required during the current reporting period. The
next BWON laboratory audit is tentatively
scheduled for the lst Quarter of 2026.
Following completion of the initial audit of the
laboratories used within one ( I ) year, BWO shall
audit any new laboratory used for analyses of
benzene samoles orior to use of the new laboratorv.
fl86.b Not applicable for this reporting period.
During the life of this Consent Decree, BWO shall
conduct subsequent laboratory audits, such that each
laboratory is audited every two (2) years.
!f86.c.BWO last conducted a third-party audit of the
Chemtech-Ford Laboratories facility located in
Sandy, Utah on May 8, 2024. An audit is not
required during the current reporting period. The
next BWON laboratory audit is tentatively
scheduled for the I st Ouarter of 2026.
Part V.L. -Leak Detection and Renair ("LDAR") Proqram Enhancements
BWO shall undertake the following measures to
improve the LDAR program. to minimize or
eliminate fugitive emissions from equipment in light
liquid and/or in gasivapor service, and to make all
existing facilities "affected facilities," within the
meaning of 40 C.F.R. $S 60.2 and 60.590(a)(3),
subiect to NSPS Suboart GGG.
fl87.All BWO Refinery Process Units are monitored
and reported under and as required by NSPS
Subparts GGGa.
BWO shall implement at the Refinery the
enhancements at this Part V.L to the LDAR program
under Title 40 of the Code of Federal Regulations,
Part 60, Subpart GGG; Part 61, Subparts J and V;
Part 63. Subparts F. H. and CC.
fl88.BWO has incorporated and implemented the
enhancements of Part V.L to the Refinery's LDAR
program.
Affected Facilities. Upon the Date of Entry, all
equipment, as defined by 40C.F.R. $ 60.591, within
each process unit and all compressors at BWO
Refinery shall become "affected faciIities" for
purposes of 40 C.F.R. Part 60, Subpart GGG, and
shall become subject to and comply with the
requirements of 40 C.F.R. Part 60, Subpart CGG, and
the requirements of Part V.L of this Consent Decree,
provided that any such equipment or compressors
that are subject to 40 C.F.R. Part 63, Subparts CC, F,
or H, or 40 C.F.R. Part 60, Subpart GGGa, shall
comply with those Subparts, as applicable, not
Suboart GGG.
fl8e.All BWO Refinery Compressors are monitored
and reported under and as required by NSPS
Subparts CGGa.
United States, et al. v. Big West Oil, LLC - Civil Action No. l:13-CV-00121 BSJ
Semi-Annual Progress Report
July 0 l, 2024, through December 31, 2024
t2
lVritten Refinery-Wide LDAR Program. BWO shall
update the program as necessary to ensure continuing
compliance. A description of program changes shall
be maintained on-site during the life of the Consent
Decree but need not be submitted to the agencies.
fle0.BWO maintains and implements a Written
Refinery-Wide LDAR Program pursuant to fl90. to
ensure compliance all applicable regulations.
Updates to the program are completed as
necessary to ensure continuing compliance. A
description of program changes is maintained on-
site and will be maintained during the life of the
Consent Decree.
Training. For personnel newly assigned to LDAR
responsibilities, BWO shall require LDAR training
orior to each employee beginning such work:
lle l .a.All personnel newly assigned to LDAR
responsibilities receive training prior to beginning
LDAR work.
For all personnel assigned LDAR responsibilities,
including but not limited to, monitoring technicians,
database users, QfuQC personnel and the LDAR
Coordinator, BWO shall provide and require
completion of initial LDAR training and annual
trainins thereafter: and
tle l.b.All personnel assigned to LDAR responsibilitres
receive annual training.
For all other Refinery operations and maintenance
personnel including, but not limited to, operators and
mechanics performing valve packing and designated
unit supervisors reviewing for delay of repair work,
BWO shall provide and require completion of atr
initial training program that includes instruction on
aspects of LDAR that are relevant to the person's
duties. "Refresher" training in LDAR for these
personnel shall be performed at a minimum on a
three (3) vear cvcle.
fl91.c.All personnel assigned to LDAR responsibilittes
receive annual and refresher training, which
includes refinery operations and maintenance
personnel.
If contract employees are performing LDAR work,
BWO's contractor shall comply with the training
requirements in 'U9l.a, b, and c for all such contractor
employees and, if such training is provided by
anyone other than BWO, shall provide its training
information and records to BWO.
fl9 r.d.If contract employees are performing LDAR work,
the contractors comply with the training
requirements in fl9 1.a, b, and c.
LDAR Audits. BWO shall implement the refinery-
wide audits to ensure the refinery's compliance with
all applicable LDAR requirements.
\le2 See fl92.b below.
Third-Pam.v Audits. BWO shall retain an independent
contractor(s) with expertise in LDAR program
rcquirements to perform a third-parfy audit of the
BWO Refinery's LDAR Program at least once every
four (4) years. The first third-party audit for the BWO
Refinery shall be completed tro later than twelve (12)
months after Date of Entry. Subsequent third-party
audits shall be held every four (4) vears thereafter.
fle2.b.
(2022,
2026\
A Third-Party LDAR Audit began on December
3rd,2024, and was concluded on December 5th,
2024.
United States, et al. v. Big West Oil, LLC - Civil
Semi-Annual Progress Report
July 01, 2024,through December 31,2024
Action No. I : l3-CV-001 2 I BSJ
Internal Audits. BWO shall conduct internal audits of
the BWO Refinery's LDAR Program by sending
personnel associated with BWO's LDAR
contractor(s) who are familiar with the LDAR
program and its requirements but are not routinely
assigned to the BWO Refinery. BWO shall complete
the first round of these internal LDAR audits within
two (2) years following completion of the first third-
party audit required under Subparagraph 92.b.
Internal audits of the BWO Refinery shall be held
everv four (4) vears thereafter.
\92.c.
(2020,
2024)
BWO has elected to comply with the intemal audit
provisions through the altemative compliance
option provided in V.L.fl92.e., which allows BWO
ReIinery to retain third parties to undertake these
audits.
This option was utilized for the 2024 Calendar
year audit that commenced on December 3rd,
2024.The 2024 LDAR CD Audit was performed
by Montrose Air Quality Services, LLC
(Montrose), of Deer Park, TX.
To ensure that an audit occurs every 2 years, third-
party and internal audits shall be separated by 2
Years.
fle2.d.The Third-Party and Internal LDAR Audits meet
this criteria.
Alternative. As an alternative to the internal audits
required BWO may elect to retain third parties to
undertake these audits, provided that an audit of
BWU refinery occurs every 2 years.
fl92.e.See fl92.c. above.
lmplementation of Actions Necessary to Correct
Non-Compliance. If the results of any of the audits
conducted pursuant to !J92. at the Refinery identify
any areas of non-compliance, BWO shall implement
all steps necessary to correct the area(s) ofnon-
compliance as soon as practicable, and to prevent a
recurrence of the cause of the non-compliance to the
extent practicable, Until two (2) years after
termination of this Consent Decree, BWO shall retain
the audit reports generated pursuant to fl92. and shall
maintain a written record of the corrective actions
that BWO takes at the Refinery in response to any
deficiencies identified in any audits. Pursuant to the
provisions of Part IX of this Consent Decree
(Reporting and Record Keeping), BWO shall submit
the audit reports and corrective action records for
audits performed and actions taken during the
orevious vear.
fle3.The results of the most recent Third Party LDAR
Audit conducted to f192. at the Refinery are still in
draft form. Should areas of non-compliance be
identified, BWO will implement all steps
necessary to correct the area(s) ofnon-compliance
as soon as practicable, and to prevent a recurrence
of the cause of the non-compliance to the extent
practicable. BWO has and will retain the audit
reports generated pursuant to fl92. Areas ofnon-
compliance and any associated corrective actions
will be submitted within one year of Third Party
LDAR Audit completion in a supplementalreport.
Internal Leak Dejinition for Valves and Pumps.
BWO shall utilize the following internal leak
definitions for valves in light liquid or gas/vapor
service and pumps in light liquid service, unless other
permi(s), regulations, or laws require the use of
lower leak definitions.
fle4 BWO utilizes the CD internal leak definitions for
valves in light liquid or gas/vapor service and
pumps in light liquid service, unless other
permit(s), regulations, or laws require the use of
lower leak definitions.
Leak Definition for Valves. BWO shall utilize an
internal leak definition of 500 ppm VOCs for all of
the BWO Refinery's valves, excluding pressure relief
devices. in lieht liquid or gas/vaDor service.
194.a.See fl94.
Leak Definition for Pumps. BWO shall utilize an
intemal leak definition of 2,000 ppm VOCs for all of
the BWO Refinerv's DUmDS in lisht liquid service.
fle4.b See. fl94.
United States, et al. v. Big West Oil, LLC - Civil Action No. I : l3-CV-0012 I BSJ
Semi-Annual Progress Report
July 01,2024, through December 31,2024
Reporting, Recording, Tracking, Repairing, and Re-
monitoring Leaks of Valves and Pumps Based in the
Internal Leuk Definitions.
fle5 See below.
Reportinq. For regulatory reporting purposes, BWO
may continue to report leak rates in valves and pumps
against the applicable regulatory leak definition, or
may use the lower, internal leak definitions specified
in fl94. BWO will identify in the report which
definition is beins used.
fl95.a.BWO has indicated in the regulatory reports which
definition is being used.
Recording, Tracking, Repairing and Re- monitoring
Leaks. BWO shall record, track, repair and re-
monitor all leaks in excess of the intemal leak
definitions of fl94. at such time as those definitions
become applicable, except that BWO shall have five
(5) days to make an initial attempt and re-monitor the
component and have thirty (30) days to make repairs
and re-monitor leaks that are greater than the internal
leak definitions but less than the applicable
regulatory leak definitions, or to place on the delay of
renair list accordins to fl103.
fles.b BWO has complied with the requirements to
record, track, repair, and re-monitor leaks in
excess of the internal leak definitions.
Initial Attempt at Repairs on Valves. BWO shall
promptly make an "initial attempt" at repair on any
valve that has a reading greater than 200 ppm of
VOCs, excluding control valves and other valves that
LDAR personnel are not authorized to repair. The
leaking valve will be re-monitored within 5 days of
identification. If the re-monitored leak reading is
below the internal leak definition, no further action
willbe necessary. If the re-monitored leak reading is
greater than the internal leak definition, BWO shall
repair the leaking valve according to the
requirements. All records of repairs, repair attempts,
and re-monitorine shall be maintained for life of CD.
fle6.BWO completes initial attempt at repairs and re-
monitoring within five (5) days and effective
repair and re-monitoring within thirty (30) days or
places the leaking component on the delay of
repair list according to the Delay-of-Repair
provisions in $V.L.103. BWO complies with the
provisions in fl96 and completes initial attempts at
repair on valves as required. All records of repairs,
repair attempts, and re-monitoring are maintained
fbr the life of the CD.
L DAR Mo n itori ns Freo u encv.1te7.See below.
Pumps. Unless more frequent monitoring is required
by a federal or state regulation, when the lower
intemal leak definition for pumps becomes applicable
pursuant to the provisions of fl94.b, BWO shall begin
monitoring pumps in light liquid service, other than
dual-mechanical seal pumps or pumps vented to a
control device, at the lower leak definition on a
monthly basis.
197.a.BWO is monitoring pumps at an intemal leak
definition monthly in accordance with fl97.a.
Valves. Unless more frequent monitoring is required
by a federal or state regulation, when the lower
intemal leak definition for valves becomes applicable
pursrrant to the provisions of fl94.a, BWO shall
monitor valves, other than difficult to monitor or
unsafe to monitor valves, on a quarterly basis, with
no abilitv to skio oeriods.
lle7.b.BWO is monitoring applicable valves on a
quarterly basis and has not applied skip period
monitoring in accordance with flg7.b.
United States, et al. v.
Semi-Annual Progress
July 01, 2024, through
Big West Oil, LLC - Civil Action No. I : l3-CV-0012 I BSJ
Report
December 31,2024
l5
Electronic Monitoring, Storing, and reporting of
LDAR Data.
fle8.See below.
Electronic Storing and Reporting of LDAR Data.
BWO shall continue to maintain an electronic
database for storing and reporting LDAR monitoring
and repair data from the BWO Refinery.
fl98.a.BWO continues to maintain an electronic database
for storing and reporting LDAR monitoring and
repair data from the BWO Refinery. The
LeakDAS Database is currently used to comply
with this orovision.
Electronic Data Collection Durins LDAR Monitorinq
and Transfer Thereafter. BWO shall use dataloggers
and/or electronic data collection devices during
LDAR monitoring. BWO, or its designated
contractor, shall use its/their best efforts to transfer, at
least every seven (7) days, electronic data from
clectronic datalogging devices to the electronic
database required in fl98.a. BWO shall transfer any
manually recorded monitoring data to the clectronic
database required in fl98.a within seven (7) days of
monitoring.
,lI198.b.BWO uses dataloggers and/or electronic data
collection devices during LDAR monitoring.
BWO, or its designated contractor, use its/their
best efforts to transfer, at least every seven (7)
days, electronic data from electronic datalogging
devices to the electronic database required in
fl98.a. BWO uses paper logs where necessary or
more feasible (e.9., small rounds, re-monitoring, or
when dataloggers are not available or broken).
BWO uses its best efforts to transfer any manually
recorded monitoring data to the electronic database
within seven (7) davs of monitorins.
QA/QC of LDAR Data. BWO, or a third-party
contractor retained by BWO, shall develop and
implement a review procedure to ensure a quality
assurance/qualify control ("QA/QC") of all data
generated by LDAR monitoring technicians. BWO or
contractor monitoring technicians shall review
monitoring data each day after monitoring is
conducted to ensure QA/QC of the data. At least once
per Calendar quarter, BWO shall perform QA/QC of
the monitoring data which shall include, but not be
limited to: number of components monitored per
technician, time between monitoring events, and
abnormal data patterns. BWO shall communicate
monitoring results to unit supervisors on a weekly
basis.
flee.BWO developed and implemented a procedure to
ensure all data generated by LDAR monitoring
technicians is reviewed for qualiry.
BWO or contractor monitoring technicians review
monitoring data each day after monitoring is
conducted to ensure QA/QC of the data.
At least once per Calendar quarter, BWO or
LDAR contractor's QAQC professional shall
perform QfuQC of thc monitoring data.
BWO or LDAR contractor monitoring technician
communicates monitoring results to unit
supervisors and maintenance planners on a weekly
basis.
LDAR Personnel. BWO shall establish a program
that will hold LDAR personnel accountable for
LDAR performance. BWO shall maintain a position
within the BWO Refinery responsible for LDAR
management, with the authority to implement
improvements ("LDAR Coordinator").
fl100.BWO maintains program that holds LDAR
personnel accountable for LDAR performance.
BWO maintains an LDAR Manager position
within the refinery in accordance with this
provision.
Addins New Valves und Pumps.flr 01.See below.
Management of Change. By no later than the Date of
Entry, BWO shall establish a tracking program for
maintenance records (e.9., a Management of Change
program) to ensure that valves and pumps added to
the BWO Refinery during maintenance and
construction are integrated into the LDAR Program.
fll01.a.BWO established a tracking program for
maintenance records (e.9., a Management of
Change program) to ensure that valves and pumps
added to the BWO Refinery during maintenance
and construction are integrated into the LDAR
Program.
Newly-Installed Valves.fll0l.a.See below.
United States, et al. v. Big West Oil, LLC - Civil Action No. I : I 3-CV-0012 I BSJ
Semi-Annual Progress Report
July 01, 2024, throtgh December 31, 2024
l6
BWO shall ensure that all newly installed valves
(other than sampling and instrumentation valves in
service on piping with a diameter of 5/8" or less) are
fitted, prior to installation, with Certif,red Low-
Leaking Valves or Certified Low-Leaking Valve
Packing Technology; and
fll0r.b.( r)BWO uses its best efforts to ensure that all newly
installed valves (other than sampling and
instrumentation valves in service on piping with a
diameter of 5/8" or less) are fitted, prior to
installation, with Certified Low-Leaking Valves or
Certified Low-Leaking Valve Packing Technology
("cLLT").
Modifo its purchasing procedures to ensure that the
BWO Refinery evaluates the availability of valves
and valve packing that meets the requirements for a
Certified Low-Leaking Valve or Certified Low-
Leaking Valve Packing Technology at the time that
the valves, valve packing and/or equipment is
acquired for the BWO Refinery.
fll0l.b.(2)BWO modified its purchasing procedures to
ensure that the BWO Refinery evaluates the
availability of valves and valve packing that meets
the requirements for a Certified Low-Leaking
Valve or Certified Low-Leaking Valve Packing
Technology at the time that the valves, valve
packing and/or equipment is acquired for the
BWO Refinery. BWO Refinery has developed an
Approved Manufacturers List ("AML") of Valve
& Packing OEMs with products that meet the
Consent Decree definition of Certified Low-
Leaking Technology.
Evaluation of potential additional control measures
in response to the observations noted in fll0l.b.( l)
is underwav.
Commercial Unavailability. BWO shall not be
required to utilize a CLLT to replace or repack a
valve if a CLLT is commercially unavailable, in
accordance with the orovisions of Aooendix B.
fl l0l .c.Not applicable for this reporting period.
lf BWO exercises the Commercial Unavailability
Exception under fll0l.c. for any valve, then BWO
shall report the information in fl101.d in the Semi-
Annual Reports required under Part IX (Reporting
and Record Keeping) BWO shall also install the
valve(s) or packing technology it has identified to be
commercially available that comes closest to meeting
Certified Low-Leaking Valve or Certified Low-
Leaking Valve Packing Technology requirements.
fl l0l .d.Not applicable for this reporting period.
Oneoine Assessment of Availabilit-y. BWO may use
a prior determination of Commercial Unavailability
ofa valve or valve packing pursuant to this Paragraph
and Appendix B for a subsequent Commercial
Unavailability claim for the same valve or valve
packing (or valve or valve packing in the same or
similar service), provided that the previous
determination was completed within the preceding
l2-month period. After one ( I ) year, BWO must
conduct a new assessment of the availability of a
valve or valve packing meeting Certified Low-
Leaking Valve or Certified Low-Leaking Valve
Packins Technolosv reouirements.
fll0l.e.As applicable for this reporting period, BWO has
not utilized the commercially unavailable
exception, in accordance with the provisions of
Appendix B, therefore the requirements for an
Ongoing Assessment of Availability are not
applicable to the facility at this time.
C a lib rutio n/C a I i b rati o n D r i ft A s s e s s m e n t.tTr02 See below.
United States, et al. v. Big West Oil, LLC - Civil Action No. I :13-CV-00121 BSJ
Semi-Annual Progress Report
July 01, 2024,throtgh December 31,2024
l7
Calibration. BWO or its contractor shall conduct all
calibrations of LDAR monitoring equipment using
methane as the calibration gas, in accordance with 40
C.F.R. Part 60, App.A, EPA Reference Test Method
21. BWO shallmaintain records of the instrument
calibrations required by this Paragraph for the
duration of the Consent Decree.
fl 102.a.BWO LDAR contractors conduct all calibrations
of LDAR monitoring equipment using methane as
the calibration gas, in accordance with 40 C.F.R.
Part 60, App. A, EPA Reference Test Method 21.
BWO maintains records of the instrument
calibrations required by this Paragraph for the
duration of the Consent Decree.
Calibration Drift Assessment. BWO or its contractor
shall conduct calibration drift assessments of LDAR
monitoring equipment at the end of each monitoring
shift, at a minimum. The calibration drift assessment
shall be conducted using, at a minimum, a 500-ppm
calibration gas. If any calibration drift assessment
after the initial calibration shows a negative drift of
more than 10% from the previous calibration, BWO
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 ppm.
fl 102.b.BWO LDAR contractors conduct calibration drift
assessments of LDAR monitoring equipment at the
end of each monitoring shift, at a minimum. The
calibration drift assessment is conducted using 500
ppm, 2,000 ppm, and 10,000-ppm calibration
gases. If any calibration drift assessment after the
initial calibration shows a negative drift of more
than 10% from the previous calibration, BWO
requires the LDAR contractors re-monitor all
valves that were monitored since the last
calibration that had a reading greater than 100 ppm
and re-monitor all pumps that were monitored
since the last calibration that had a reading greater
than 500 ppm.
Delay of Repair. For any equipment for which BWO
is allowed, under 40 CFR $ 60.482-9(a), to place on
the "delay of repair" list for repair, BWO shall:
fl 103.See below.
For all eouioment. BWO shall U l03.a.See below.
Require sign-off by the unit supervisor that the piece
of equipment is technically infeasible to repair
without a process unit shutdown, before the
component is eligible for inclusion on the "delay of
renair" list: and
fl 103.a.( I )The unit supervisor signs-off any piece of
equipment that is technically unfeasible to repair
without a process unit shutdown, before the
component is listed as "delay of repair".
Include equipment that is placed on the "delay of
repair" list in the regular LDAR monitoring program.
For leaks above the intemal leak definition rate and
below the regulatory ratc, BWO shall have thirty (30)
davs to nut the equipment on the delay of repair list.
fl 103.a.(2)Equipment that is placed on the "delay of repair"
list is included in the regular LDAR monitoring
program.
For valves, other than control valves, leaking at a rate
of 10,000 ppm or greater and which cannot be
repaired using traditional techniques, BWO shall use
the "drill and tap" or similarly effective repair
method for fixing such leaking valves, rather than
placing the valve on the "delay of repair" list, unless
BWO can demonstrate that there is a safety,
mechanical, or major environmental concern posed
by repairing the leak in that manner. BWO shatl
perform a first, and if necessary, a second, "drill and
tap" (or equivalent) repair method within thirty (30)
days after detecting a leak of 10,000 ppm or greater;
fl103.b.(r)BWO, per the provisions of 40 CFR $ 60.482-9(a),
places equipment on the "delay of repair" list for
repair. BWO Refinery requires sign-off by the unit
supervisor that the piece of equipment is
technically infeasible to repair without a process
unit shutdown before the component is eligible for
inclusion on the "delay ofrepair" list; and
equipment that is placed on the "delay of repair"
list is included in the regular LDAR monitoring
program. For valves, other than control valves,
leaking at a rate of 10,000 ppm or greater and
which cannot be repaired using traditional
techniques, BWO uses the "drill and tap" or
similarlv effective renair method for fixins such
United States, et al. v. Big West Oil, LLC - Civil Action No. l:13-CV-00121 BSJ
Semi-Annual Progress Report
July 0 1, 2024, through December 31, 2024
leaking valves, rather than placing the valve on the
"delay of repair" list, unless BWO can demonstrate
that there is a safety, mechanical, or major
environmental concem posed by repairing the leak
in that manner.
After fwo unsuccessful attempts to repair a leaking
valve through the "drill and tap" or similarly effective
repair method, BWO may place the leaking valve on
its "delay of repair" list. BWO shall advise EPA prior
to implementing repair methods equivalent to "drill
and tap" if such method develops for repairing
valves.
fl 103.b.(2)BWO uses its best effort to perform a first, and if
necessary, a second, "drill and tap" (or equivalent)
repair method within thirty (30) days after
detecting a leak of I 0,000 ppm or greater; only
after two unsuccessful attempts to repair a leaking
valve through the "drill and tap" or similarly
effective repair method, are the leaking valve
placed on the "delay of repair" list.
Chronic Leakers. BWO shall replace or repack all
non- control valves that are "chronic leakers" during
the next process unit turnaround. A chronic leaker
shall be defined as any component which leaks above
10,000 ppm in any two quarters between refinery
tumarounds durins the life of the Consent Decree.
fl104.BWO replaces or repacks all non-control valves
that are "chronic leakers" during the next process
unit turnaround. A chronic leaker has been defined
as any component which leaks above 10,000 pp*
in any two quarters between refinery tumarounds
durine the life of the Consent Decree.
Record Keeping and Reporting Requirements for
this Part V.L. BWO shall include the following
information in their semi-annual Drogress reports.
til0s.See below.
First Semi-Annual Progress Report Due under
Consent Decree.
fl 105.a See below.
First Semi-Annual Proeress Report for the Calendar
Year. BWO shall include an identification of each
audit that was conducted pursuant to the requirements
of fl92 in the previous calendar year including an
identification of the auditors, a summary of the audit
results, and a summary of the actions that BWO took
or intends to take to correct all deficiencies identified
in the audits. Dursuant to'|IT93.
fl 105.b Not applicable for this reporting period.
If applicable for reporting period information
included in Attachment 4.
MACT Subpart CC Reporting. In each report due
under 40 C.F.R. $ 63.655, BWO shall include CD
LDAR Reoortins Reouirements of this section.
fl 105.c.Not applicable for this reporting period.
Agencies to Receive Reports, Plans and
Certifications Required in this Part; Number of
Copies. BWO shallsubmit all reports, plans and
certifications required to be submitted under this Part
to EPA and UDEO.
fl106.BWO continues to submit all reports, plans and
certifications required to be submitted under this
Part to EPA and UDEQ.
Part V.M. - INCORPORATION OF CD REOUIREMENTS INTO FEDERALLY ENFORCEABLE PERIVIITS.
United States, et al. v.
Semi-Annual Progress
July 01,2024, through
Big West Oil, LLC - Civil Action No. I : l3-CV-0012 I BSJ
Report
December 31,2024
' Incorporate emission limits and standards into
Minor or Major NSR permits or other permits (other
than Title V permits) which are federally enforceable.
' Incorporate the requirements of those permits into
the Title V permit as set forth is !1109.' Emission Limits and Standards as set forth in
fll I l.a. shall constitute emission limits and standards
that shall survive termination of the CD by virtue of
beins incomorated into federallv enforceable oermits
w.M. r 07-lll BWO remains current with submittal of
applications of incorporating Emission Limits and
Standards as set forth in fll I l.a. of the Consent
Decree into federally enforceable permits.
Part V.I. - EMISSION CREDIT GENERATION.
BWO is prohibited from using emissions reductions
that will result from the installation and operation of
the controls required by this CD for the purpose of
emissions nctting or emissions offsets.
t[/.1.1 l2-
l14
BWO does not use emissions netting or emissions
offsets.
Part V.II. - MODIFICATIONS.
Material modifications to this CD will be in writing,
signed by the parties and will be effective upon
annroval bv the court.
!lv.il.l l5 Not applicable for this reporting period.
Part V.III. - SUPPLEMENTAL ENVIRONMENTAL PROJECT.
BWO shall implement the SEP.tlv.rr.r 16-
126
The SEP was submitted May 5,2014, and is being
implemented at the BWO Refinery.
Part V.IX. -REPORTING AND RECORDKEEPING.
BWO shall submit to EPA and UDEQ a progress
repoft containins the followins information:
nt27.See below.
General. Each Report shall contain: a progress report
on the implementation of the requirements of Part V
( Affi rmative Rel ief/Env i ronmental Proi ects) :
'lI1127.a.( I )See this semi-annual report.
A summary of the emissions data that is specifically
required by the reporting requirements of Part V of
this CD for the period covered by the report;
1t127.a.(2)See this semi-annual report and the quarterly
CEMs SEDR submittals for the current reporting
oeriod.
A description of any problems anticipated with
respect to meeting the requirements of Part V of this
CD.
lt27.a.(3)None for this reporting period.
A description of the starus of the SEP being
conducted at the Refinery under Part Vlll: and
nt27.a.@)The SEP project was submitted to the EPA and
UDEQ on May 5,2014. BWO complies with the
SEP.
Any additional matters as BWO believes should be
brought to the attention of EPA and UDEQ.
nt27.a.(5)None for this reporting period.
Emissions Data. In each semi-annual report required
to be submitted on July 3l of each year, BWO shall
provide a summary of annual emissions data at the
refinery for the prior calendar year. The summary
shall include estimates and/or calculations ot
11127.b.lf applicable for reporting period information
included in Attachment l.
NOx emissions in tpy for each heater and boiler
sreater than 40 mmBTU/trr maximum fired duW;
11r 27.b.( l )See comment in fl 127.b.
NOx emissions in tpy as a sum for all heaters and
boilers less than 40 mmBTU/hr maximum fired duty;
nt27.b.(2)See comment in'!J127.b.
SO2, CO, and PM emissions in tpy as a sum for all
heaters and boilers;
fl 127.b.(3)See comment in !f 127.b.
United States, et al. v. Big West Oil, LLC - Civil Action No. I : l3-CV-0012 I BSJ
Semi-Annual Progress Report
July 01, 2024,through December 31,2024
SO2 emissions from SRU in tpy;1,L27.b.(4\See comment n tTl27.b
SO2 emissions from all AG Flaring and TG Incidents
by flare in tpy;
fl127.b.(s)See comment in !f 127.b.
NOx, SO2, PM, and CO emissions in tpy as a sum for
all other emissions units for which emissions
information is required to be included in the facility's
annual emissions summaries and that are not
identified above;
fl 127.b.(6)See comment in fl127.b.
SO2, NOx, CO, and PM emissions in tpy for the
FCCU, and
nt27.b.(7)See comment in fl127.b.
For each of the estimates or calculations in fl I 27.b.( I )
through nl27 .b.(7) above, the basis for the emissions
estimate or calculation (i.e. stack tests, CEMs,
emission factor, etc.). To the extent that the required
emissions summary data are available in other reports
generated by BWO, such other reports can be
attached, or the appropriate information can be
extracted from such other reports and attached to the
semi-annual report to satisfu the requirement.
fl 127.b.(8)See comment in !J127.b.
Exceedances of Emissions Limits. In each semi-
annual report, BWO shalt identify each exceedance
of an emission limit required or establishcd by this
CD that occurred during the previous semi-annual
pcriod and, for any emissions unit subject to a limit
required or established by this CD that is monitored
by a CEMs, any periods of CEMs downtime that
occurred during the semi-annual period. For each
exceedance and/or each period of CEMs downtime,
BWO shall include the followine information:
nl27.c.See Table below.
United States, et al. v. Big West Oil, LLC - Civil Action No. I : l3-CV-001 2 I BSJ
Semi-Annual Progress Report
July 01, 2024, through December 31, 2024
United States, et al. v.
Semi-Annual Progress
July 01,2024, through
F.xceedances of Emission I imits - SIX. 127.c
Part IX.l27.c.(l)(a).(c) - Duration of Exceedance(s) and Downtime as % of Operating Time per
Ouarter
Part IX.l27.c.( I Xb) - If Operatine Unit Exceeded Limit more than I % of Total Time per Quarter
If applicable.for the re1torting period, additional information is included in Attachment 5.
Part IX.l27.c.( I Xd) - If CEMS Downtime Exceeded more than 5% of Total Time per Quarter
If applicablefor the reporting period, additional information is included in Attachment 5.
Part IX.127.c.( 1'l(c) - Duration of the CEMS Downtime % of Operatine Time per Ouarter
Process
Unit CEIlTS Downtime
03 o/o
Downtime
04 "h
MSCC (FCC)NOx 0.09%0.09%
MSCC (FCC)02 o.o90/"0.09%
MSCC (FCC)s02 0.09o/.0.09yo
MSCC (FCC)CO 0.09%0.09o/.
Amine H2S 4.6604 0.00%
S. Flare H2S 2.36%t.4s%
W. Flare H2S 0.32%1.59%
SRU s02 1.5404 2.76%
END OF REPORT
Big West Oil, LLC - Civil Action No. l: l3-CV-0012 I BSJ
Report
December 31,2024
CD Emissions Limits Averaging
Period CD
Reference
3'd Quarter 2024 4th Ouarter 2024
Exceedances Downtime
9'. of Otr.
Exceedance
% of Otr.
Downtime
% of Otr.
NOx 40 ppmvd NOx at 0Vo Oz_ FCCU 365-dav RA $v.A. 12, l3 0.00%
0.09%
0.00%
0.09%NOx 60 ppmvd NOx at 0o/o 02_ F'CCU 7-day RA $v.A.l2 0.00%0.00%
SO:25 ppmvd SO2 at 0% Ou -FCCU 365-dav RA sv.B.23-24 0.00Yo
0.09%
0.00o/n
0.09yoSO: 50 ppmvd SO2 at 0% O: -FCCU 7-dav RA $v.8.23-24 0.00%0.05%
CO 500 ppmvd CO at 0o/o Oz -FCCU I -hour $v.D.39 0.46Yo 0.090h 0.00%0.09o/o
H2S l62ppmH2S-Refinery
Fuel Gas 3-hour riv.H.48 0.00%
4.660/n
0.00,%
0.00%ll:S 60 ppm H2S - Refinery
Fuc'l Cas 365-day $v.H.48 0.00yo 0.000o
3i: 't ppm - s. Flare vent 3-hour $V.J.59.a 1.0104 2.360/o 0.00%1.45%
H:S 162 ppm - W. Flare Vent
Gas 3-hour $V.J.59.a 0.14%0.32%0.23%t.59%
957u Recovery Efficiency -SRP 30-day RA QV.r.s3 0.00%0.00%0.00%2.7 6o/n
_ u iAH s5r;a11ffi[]{]p-
El!l.11eru14rE-t'i IA!-!j i, n,, r "
22
Attachment I
Attachments Related to Emissions Reportine of Part V (Affirmative Relief/Environmental Proiects)
Attachments related to emissions reporting and stack tests demonstrating compliance with emissions limits.
The following information is included in this attachment:
Summary of Emissions Data for the prior CY - QIX. 127.b. (included in the first Semi-annual proeress
report ofeach year)
o Not applicable for the current reporting period.
FCCU Regen PM Stack Test Report
o Not applicable for the current reporting period
U.S. v. Bat West Oil LLC, Case l: ll<v{x)l2l-BSJ
CoMnt Decre Scmi-Amul Progr6s Repon
July 1.20!4, through Decmbcr 31.2024
Attachment 2
Attachments Related to Flarins Incidents Reportins of Part V (Affirmative Relief/Environmental Proiects)
All Acid Gas Flaring IncidenE, Tail Gas Incidents and Hydrocarbon Flarins Incidents that BWO was required to
prepare under1162.b. 64. 68 and 70 durins the previous six-monthperiod are included in this Semi-Annual Report.
The following information is included in this attachment:
o Acid Gas/Tail Gas Flarinq Incidents
o Not applicable for the current reporting period.
. Hydrocarbon Flarine Incidents
o Not applicable for the current reporting period
U.S. v. Big WestOil LLC, Case lrll{v40l2l-BSJ
CoEnt D.{re Semi-Annual Prcgrss Rcpon
July 1.20)4, ttuogh Dember 31.2024
Attachment 3
Attachments Related to BWON Renortins of Part V (Affirmative Relief/Environmental Proiects)
Attachments related BII/ON sampling and laboratory audits.
The followine information is included in this attachment:
BWON Ouarterly EOL Sampline Data and EOL Determination - u84.a.(3)o 3'd Quarter 2024
o 4'h Quarter 2024
BWON Periodic Sampling<lOMG -'1184.a.(2)
o BWON annual POG sampling results, non-EOL sampling pursuant to fl80.b
BWON Laboratory Audit Reports - fl86.a. & tl86.b.
o Not applicable for the current reporting period.
US v BigW6tOil LLC,Casc l:ll<v{X}lll-BS,
CoNnt Dsre Semi-Amul Progress Repon
July | . 20:4. rhrough Dcccmb€r 3 l. 2024
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Attachment 4
Attachments Related to LDAR Reportine of Part IX (Reoortins and Record Keepinq)
Attachments reluted to LDAR uudits and commerciul unavailability exception and ongoing assessment of avuilability summary
The followins information is included in this attachment:
o LDAR CD Audit Report Summary & Conective Actions - fl93.o Not applicable for the current reporting period.
. Commercial UnavailabiliW Exception and Onsoing Assessment of Availability Summary - nl0l.d. &
nl0l.e.o Not applicable for the current reporting penod.
U.S. v. Big Wcst Oil LLC, Case l:ll<v$o121-BSJ
Con$nt DccB Scmi-Am@l Prugre Rcpon
July 1.2024, through Deembcr 31.2024
Attachment 5
Attachments Related to Emissions Limit Exceedances of Part IX (Reportins and Record Keepins)
Atlachments related to exceedances of an emission limit more than I ?5 of totol time per quarter and exceedances o.f
downtime more than 5%o of total time per auarter.
The followine information is included in this attachment:
o Part IX.l27.c.( lXb) - If Operatine Unit Exceeded Lirhit more than l% of Total Time per Ouarter
o S. Flare H2S 162 ppm 3-Hr Exceedances - 3'd Quarter 2024
r Part IX. 127.c.( I Xd) - If CEMS Downtime Exceeded more than 5% of Total Time per Ouarter
o Not applicable for the current reporting period.
U.S. v. Big West Oil LLC, Casc l: ll<v-001? l-BSJ
Consnl Decrec Scmi-Anf,ual Progrcss Rcport
July l. 2024. through Deember 3 l. 2024
Excess Emisslons Summary
Reporting Period:
Source:
Pollutant:
Llmit:
3rd Quarter 2024
South Ftare
H25
162 ppmv H2S on 3-hour rotting average l:IVi:jlrli'l OF A!{r ()l-lALlTY
I
T
t-
i:--t
I
I
I
I
I
I
I
i
I
I
Start Date StartTlme Magnltude Event Cate(orv Descrlptlon of Event
8t29t2024 17:00 169.2 Startup/Shutdown High H25 correlating with Department 2 start-up and change
in ftow rate.
8t29t2024 18:00 202.2 Startup/Shutdown High H25 corretating with Department 2 start-up and change
in flow rate.
8t29t2024 19:00 176.6 Startup/Shutdown High H25 corretating with Department 2 start-up and change
in flow rate.
9t23t2024 7:00 404.7 Startup/Sh utdown
)tant-wide shutdown and startup due to power f ailure
laused by the Rocky Mountain Power substation fire.
9t2312024 8:00 586.2 Startup/Sh utdown Ptant-wide shutdown and startup due to power faiture
caused bv the Rockv Mountain Power substation fire.
9t23t2024 9:00 598.2 Startup/Shutdown
)tant-wide shutdown and startup due to power faiture
:aused bv the Rockv Mountain Power substation fire.
9t23t2024 10:00 247.2 Startup/Shutdown
)tant-wide shutdown and startup due to power faiture
:aused bvthe Rockv Mountain Power substation fire.
912312024 14:00 192.9 Startup/Shutdown
)tant-wide shutdown and startup due to power failure
:aused bythe Rocky Mountain Power substation fire.
9t23t2024 15:00 186.1 Startup/Shutdown
)tant-wide shutdown and startup due to power failure
laused bv the Rockv Mountain Power substation fire.
912312024 16:00 7237.8 Startup/Shutdown
rtant-wide shutdown and startup due to power failure
:aused bv the Rockv Mountain Power substation fire.
9t2312024 17:00 2M0.7 Startup/Shutdown
)tant-wide shutdown and startup due to power failure
laused bv the Rockv Mountain Power substation fire.
912312024 18:00 4066.1 Startup/Shutdown
)tant-wide shutdown and startup due to power f ailure
:aused bv the Rockv Mountain Power substation fire.
9123t2024 19:00 4704.5 Startup/Shutdown
rlant-wide shutdown and startup due to power failure
laused bv the Rockv Mountain Power substation fire.
9t2312024 20:00 34s9.3 Startup/Shutdown
)tant-wide shutdown and startup due to power failure
:aused bv the Rockv Mountain Power substation fire.
9t23t2024 21:00 1808.2 Startup/Shutdown
rtant-wide shutdown and startup due to power f ailure
raused bythe Rocky Mountain Power substation fire.
9t24t2024 0:00 474.s Startup/Sh utdown
)[ant-wide shutdown and startup due to power faiture
:aused bythe Rocky Mountain Power substation fire.
9t24t2024 1:00 990.6 Startup/Sh utdown
)lant-wide shutdown and startup due to power failure
:aused bv the Rockv Mountain Power substation fire.
9124t2024 2:00 1081.7 Startup/Sh utdown
)lant-wide shutdown and startup due to power faiture
:aused bv the Rockv Mountain Power substation fire.
912412024 3;00 719.9 Startup/Sh utdown
)[ant-wide shutdown and startup due to power faiture
:aused bv the Rockv Mountain Power substation fire.
9124t2024 4:00 176.1 Startup/Sh utdown
)lant-wide shutdown and startup due to power faiture
:aused bythe Rocky Mountain Power substation fire.
912412024 5:00 198.6 Startup/Sh utdown
)[ant-wide shutdown and startup due to power failure
;aused bythe Rocky Mountain Power substation fire.
9t24t2024 6:00 192.2 Startup/Sh utdown
)tant-wide shutdown and startup due to power faiture
:aused bv the Rockv Mountain Power substation fire.