DAQ-2025-001933

March 13,2025
CERTIFIED MAIL
RETURN RECETPT NO.9589 0710 52701318 3715 20
Bryce Bird, Director
Utah Division of Air Quality
195 North 1950 West
P.O. Box 144820
Salt Lake city, utah 84114-4820
RE: MACT Subpart CC Periodic Report -2d Half 2024 (July 15,2024 -January 14,2025)
Dear Mr. Bird,
ln compliance with the reporting requirements of 40 CFR 63 Subpart CC, the following constitutes the
periodic report required by $63.655 applicable to Big West Oil, LLC (BWO). This submittal covers the
period from July 15,2024 - January 14,2025.
Should you have any questions regarding the contents of this report, please contact lan Muller at (801)
296-7716.
Sincerely,
YL fl%.
Ian Muller
Environmental Engineer
CERTIFIED MAIL
RETURT\ RECEIPT NO. 9589 07t0 s2701318 3715 51
USEPA Region VIII
Mail Code 8ENF-AT
1595 Wynkoop Street
Denver, CO 80202-1129
333 W. Center Street. North Salt Lake Utah 84054. 801 .296.7700. www.bigwestoil.com
DEPARTMENT OF
ENVIBONMENTAL OUAL]TY
MAR 1 1 2.115
DIVISION OF AIR QUALITY
Jerany Marsigli, UDAQ - Electronic Copy
B-2-10122
$63.655(e) MACT CC Reporting Requirements
I. Wastewater Provisions - $63.655(a)
In accordance with $63.655(a), BWO complies with the annual reporting requirements in $61.357(c). The total
annual benzene (TAB) quantity from facility waste is less than l0 Mg/yr, but equal to or greater than I Mg/yr. A
separate updated TAB report is submitted separately each year. There are no additional reporting requirements for
wastewater per 40 CFR 63.655(a).
II. Gasoline Loading Rack Provisions - $63.655(b)
In accordance with 963.428(l)(3), excess emissions for the BWO bulk gasoline distribution are submitted in separate
Quarterly CEM Excess Emissions Reports. The quarterly reports were submitted on November 5,2024, and January
27,2025.
There were no deviations from operating parameters ($63.428(D(3)(i)) during the reporting period. BWO complies
with this requirement via $63.433(bXl) by operating a CEMS to ensure emissions do not exceed l0 milligrams of
total organic compounds per liter of gasoline loaded.
BWO complies with the reporting requirements for equipment leaks required in $63.428(D(3)(iv) in a separate
semiannual report for equipment leaks. The 2od Semiannual2024 MACT CC - Equipment Leaks Report was
submitted on January 15,2025.
BWO utilizes a terminal automation system to prevent gasoline cargo tanks that do not have valid cargo tank vapor
tightness documentation from loading (e.g., via a card lock-out system). In compliance with the periodic reporting
requirements of $63.655(b), the table directly below summarizes exceptions to the vapor tightness provision for bulk
gasoline distribution at the facility.
lll Each loading ofa gasollne cargo tankfor which vapor tightness doaonenldtion hdd not been previowly obtdined by the facility.
l2l Each irctance ofd nonvapor4ighl gosoline caryo t tnk loading at the fdcility in which the owner or operatorfailed to take steps lo 6stte that
such cargo tank would not be reloaded at the facility belore vapar tightness doamentation lor lhat cargo tank was obtained.
l3l Each reloading ofa nonvapor-tight gasoline cargo lank at the facility before vapor tightness doamentationfor thal catgo tank is obtained by the
Iacility in accotdance with li63.422(c)(2).
BWO does not include a loading rack in an emissions average therefore no additional reporting requirements for
gasoline loading racks are required under subpart CC.
III. Marine Tank Vessel Loading Operation Standards - $63.655(c)
Not applicable. BWO does not have a marine vessel loading operation regulated under 40 CFR 63 Subpart Y and
Subpart CC.
IV. Equipment Leaks Standards - $63.655(d)
BWO is an existing source subject to the provisions of $63.648 for equipment leaks aud has elected to comply with
the provisions 40 CFR 60 Subpart Wa in lieu of complying with Subpart H. [n accordance with the reporting
requirements of $63.655(d)(l), BWO submits a separate semiannual report for equipment leaks subject to 40 CFR
63 Subpart CC. The 2nd Semiannual 2024 MACT CC - Equipment Leaks Report was submitted on January 15,
2025.
V. Storage Vessels Periodic Report - $63.655(gXl)
The following section contains applicable storage vessel information required in Periodic Reports. BWO is an
existing source complying with the Storage Vessel Provisions of 963.646 or $63.660. Therefore, in accordance with
63.655(gXl), information related to gaskets, slotted membranes, and sleeve seals is not required for storage vessels
that are part of existing sources and that are complying with $63.646.
a. S63.646 Internal Floatine Roof (IFR) Storaee Vessel Inspections - 863.655(eX2)
i. IFR Annual Tank-T (Visual Hatch) I with Failures Detected -
fll Pursuant tith !63.655(g)(2)(i)(A)(1 ), alqilure is dertned as any time in which the intemal is not resting on the surlace ofthe liquid inside the storage
ressel and is not resting on the leg supports; or there is liquid on thelodting rco/; ot the rcal is detached lrcn the internal floating roof; or there ore holes, leqrs, or
other openigs in the seal or seol labic: or there are tisible gaps betueat the t?al and the rall ofthe storage vssel.
L2l Ifan eilension is utilized in atcordance qith the prctisions of !63. I 20 (a)(1) of subpan G, the entry " E\tension Utilized' is noted in the Narure of Repair Column.
The next Peiodic Repon *ill identdv the vssel. include the documentation specrfred in ,s63. I 20(a)(11 of subpan G,. and descibe the dote the srorage vssel *u
emptied *'ilh the dqle and narure of the repair of repair.
In addition, details for any failures identified during the annual inspections, as applicable, can be found in
Attachment B - $63.655(gX2)(iXe). See Attachment C for extension requests, if applicable -
$63.655(eX2XiXAX3).
ii. IFR Internal (Out-of-Service) I with Failures Detected - $63.655(g)(2XiXB)
|) Ptrswnt wilh !i63.655(e)(2Xi)(8)(l), A litilure is deJined u an.y time in which the internal.lloating rool'h6 delbcts: or the prinnry seal lru
holes, tears, or other openings in the seal or lhe seal.fdbric; or the secondary seal (iJ'one hrc been insnlled) hrc holes, lears, or other openi,tgs
in the seal or the seil JAbric: or, .l'or a slorage vessel thflt b parl oJ a new source. the grckets no longer close oJJ the liquid surJbce Jiom the
at,nosphere: or, .lbr a storage vessel lhat is part oJ s new source, the slotted membrane h6 more thail a I 0 percenl open area.
b. Q63.646 External Floatins Roof (EFR) Storage Vessel Inspections - Q63.655(e)(3)
i. EFR Primarv Seal s with Detected Failures -3Xi)
lll Prinary Seal Gap Faihaes ocar when lhe acamuldted uea ofgaps betueen the vessel wall and the primary seal etceed 2 12 sEure
centimeters per meter ofvessel dlameter and the width ofany pottion ofany gap shall erceeds 3.81 centineters ($6j.120(b)(j)) and where a
metallic shoe seal is in we, and one end of the metallic shoe does nol extend inlo the slored liqud and the other end exlend a minimun vertiul
distance ol6l centimeters above the stored liEtid surface: or where otherfaihr* nch as holes, tears, or other openings in the shoe, seal
fabric, or seal envelope were detecled.
12\ Ifan exrension is utilized in accordance with the provisions of$63. I 20(b)(7)(ii) or (b)(8) ofSubprt G, the entry "Extension Utilized' is
noted in the Nature of Repair Column. The net Periodic Report will identily the vusel; include the domentation speci,fied in $63.120(aX4) of
subpart G: and descilbe tlrc dale the storage vessel was emptied wlth the date and nafire oflhe repair ofrepair.
ii. EFR Seal tions with Detected Failures -
ll Secondary ocat when lhe arca oJ Saps the secondary seal uceed 2 1.2 sqtmre
cenlimelers per meter ofvestel diameter and the width of any portion ofany gap exceeds 1.27 centimeters ($63. I 20(b)(4)) and when secondary
seals are lound that do not complelely cover lhe space berween lhe roofedge or arelound lo have holes tedrs, or other openlngs in the seal of
seal fabric (!i63. I 20(b)(6)).
l2l lfan extension is uilbed in accordance with the provbions of $63. I 20(b)(7)(ii) or (b)(8) ofSubpart G, the entry "Extewion Utilized' is
noted in the Nafitre of Repair Cohmn. The next Periodic Report will identify the vessel: inchde the doanrcntation specified in $63. I 20(a)(4) of
subpart G; and desctibe the dale the storuge vessel was emplied with the date atd nafite oflhe rcFNir ofrepair.
In addition, the Seal Gap Calculations can be found in Attachment B, if applicable, when failures were
detected during the Seal Gap Measurements - $63.655(g)(3)(iXA). See Attachment C for extension requests,
if applicable - $63.6ss(e)(3XiXB).
c. 863.660 Floatine Roof (EFR & IFR) Inspections (initial fill. annual tank-top. internal) with
Detected Failures - S63.655(s)(2)(iil & (3Xii)
lll Pwswnt with 563.1063(d)(l)(i) through (d)(l)(iv) ofsubpart WW, inspectionfaihoes ale defined as stored liquid on the tloating roof: holes
ot tea6 ln lhe primry or secondary seal (if one b praent): loaing roof deck deckfittings, or rim seals that are notlnctioning 6 desigted:
failwe to comply with the oryational rcquirements in 563.1063(b): Gaps olmore than 0.32 centimeters (th inch) betwea any deckfitting
guket, seal, or wiper and any stoface thal it iJ intended to seal.
l2l lfan extension b utilbed in accordance with the provisions of563.1063(e)(2) ofsubpart tftV, lhe entry "Extension Utilized' is noted in the
Nanue of Repir Cohunn. The next Periodic Report \9ill lnchde the doanmentation specifed in !63.1063(e)(2) ofsubpart WW.
In addition, a copy of the inspection record required by$63.1065(b)of subpart WW is included in
Attachment B, if applicable, when an inspection failure occurs in accordance with the reporting provision in
$63.6ss(eX2)(iiXB) or (3)(i0(A).
d. $63.655(gX5) - Storage Vessels complying by installing a Closed Yent System and Control Device
BWO does not utilize closed vent system and control devices for compliance with the Group I Storage
Vessel provisions of $63.646 or $63.660. Therefore, periodic reporting requirements for this provision are
not applicable for the current reporting perid.
MACT CC - Group I Miscellanoous Process Vent - Diverted Flow from Required Controls - $63.555(gXO(iii)
Date Time Duration Estimate of the
Volume of Gas
Organic HAP
Concentration
ln the Ges
Mass Emissions of Organic
HAP that Bypassed the
Control Device
Nonc to RcFrfl NA NA NA NA NA
VI. Miscellaneous Process Vents Periodic Report- $63.655(gX6)
For miscellaneous process vents (MPVs) fbr which continuous parameter nlonitors are required by this subpart,
periods of excess enrissions are identilled in this section of the Periodic Report and are used to determine compliance
with the emission standards.
For purposes ol g63.655(9)(6Xiii), the follor.ving table provides the required infbnnation for rvhich a Group I MPV
stream was detected in the bypass line or diverted from the required control devicc either directly to the atmosphere
or to a control device that does not comply with the requirements in N63.643(a).
For purposes ol N63.655(gX6), the fbllowing table provides the required information tbr Group I MPV excess
enrissions e'v'ents, if applicable, for the currcnt reporting period. BWO complies with \63.643(a) fbr Group 1 MPVs
and voluntarily routes most Croup 2 MPVs to a flare meeting the requirements of 5s$63.670 and 63.671. BWO
reports flare information as specified in tsO3.65t,rr(l l) in this periodic report. Theretore, cxcess enrissions reporting
for a number of the operating parameters in Table 1 0 of subpart CC for Group 1 Miscellaneous Process Vents do not
apply to the facility.
[2] .lt opcnrt irtr tlrtr * hcn d l pilot .lltlt{s o/ a ./ltur {tr( ebsott.
vlrtrt nrottitoritt! tlrrla x.ere nttl collt<ted ;htll bt in<'lrdctt in tltL Ptiodi< R,'port
MACT CC - Group I MPV
Excess Emissions Periodic Reporting
s63.5ssGr(6XD & (iD
Formiscellaneous process vents, excess emissions are reported for the opeoting paramctcrs specified in table l0 ofsubparl CC unless othersite-specific paranrete(s)
have been approved by the operating pemrit authority.
Group I lltPV
Identificetion
Strrt
Dete
Start
Time
End
Drte f,nd Time
None t() ltcport N,\N,\N,\
Check the ADDroprilte Bor (if rpDlicrble)
Group
I MPV
ID
monitored
ptrumetcrs
out of range
Itt
all pilot
flemes
absent
for a
flarel2l
<75oh ot
hourly
monitoring
data
avrilablel3l
data
compression
with
insullicient
data l{l
flow diverted
to
atmosphere
from the
conlrol
device
flow diverted
to r non-
compliant
control
device
bypass flow
Indicator
not operating
bypass valve
found not
closed or seal
changed
$63.655
GX6)(ixA)
$63.655
(gX6)
(ixB)
$6.1.655
GX6)(iXC)
$63.655
(eXo)
(ixD)
$63.655
GX6)(ii)
$63.655
GX6)(ii)
$63.655
GX6)(ii)
$63.644
(cX2)
Nottc to
Re Jrorl
NA NA NA NA NA NA NA
VII. Periodic Report of Performance Tests for Determination of Compliance - $63.655(gX7)
No performance tests were conducted during the reporting period that demonstrated a change from Group 2 to
Group I nor for demonstrating compliance of a new emission point subject to Subpart CC.
VIII. Heat Exchange Systems Periodic Report - $63.655(gX9)
The periodic reporting requirements for Heat Exchange Systems are summarized in the table below. Monitoring
is conducted monthly in accordance with $63.654(c)(a)(i); therefore, the total strippable hydrocarbon leak
action level is 6.2 ppmv.
Drte &e Lrrk wes
firit ldendlled Monltorlng Locrtlon
Totet Strlpp$le
Hydrocerbon Conceotrrdon
(ppmv)
lfeppliceble, the Dete the Leelr
Sourcc ldendlled
7 i17 t2024 Alkv Coolins Tower 10.45 NA
9t)6/)O)4 A llzv Cnnlino Tnwpr 758 I t/t ti2024
Alkv Coolins Tower 6.58 12fi2/2024
2/10/2024 Crude Coolins Tower t4.82 t2t3t/2024
Drte the Lerk wrr
ftrst ldenfifled
Monltorlng Locedon
I.D $socleted with the Reprired Leak
Totd Strlppeble Hydrocrrbon
Conccntridon (ppmv) durlng
remonltoritrg to verio reprtr
tte remonltoring drte (1.e., tbe
efrecdve dete ofrepelr)
7 i t7 i2024 Alky Cooling Tower 6.t7 7 n9,2024
9t2612024 Alkv Coolins Tower 5.98 I I t 12t2024
I t,27 t2024 Alky Cmlins Tower 5.60 12.'1212024
t2t30/2024 Crude Cooling Tower 0.03 ut0t2025
$63.6ss(gXeXv)
For erch deleyed rcpelr, ldend0cedon ofthe Bonltorlag locetloo lsocleted
wlth thc lerk for whlch repelr k dehycd, tte drte when the dcley ofreprir
bc8rn, the drte the repelr ls expected to be cooplctcd (lfthe lerk lr not
repelred durlng the repordng perlod), the totd rtrtpprble bydrocrrbon
concentrrdon end dete oferch monitoring evcnt conducted on the dehycd
repelr durlng the reporflng perlod rnd rn edmrte ofthc potenfi rdppeble
hydrocrrbon emlsslonr over the repordng perlod trociated wlth the delryed
repdr.
Not applicable. there were no
delayed repairs for the
reporting period.
Quarterly Reports for Emission Points - $63.655(g)(8)
Not applicable. BWO does not utilize the emissions averaging provisions of $63.652.
Pressure Relief Devices (PRD) Periodic Reporting - $63.655(gXl0)
a. Q63.655(eXlOXi) - PRD with instrument readines of 500 ppm or ereater (Q63.648(iXl))
For pressure relief devices in organic HAP gas or vapor service, pursuant to $63.648(i)(l), BWO is required to
comply only with paragraphs $63.6480X1) and $63.648(iX2) for the pilot discharge vents and bonnet vents that
are not routed through a closed vent system to a control device, back into the process, or to the fuel gas system
IX.
x.
as described in 963.648(i)(4). For the above-described vents, BWO did not detect any instnrment reading of 500
ppm or greater during the reporting period.
b. 863.655(eXl0xii) - PRD Monitorine Demonstratine Compliance (863.648(iX2))
BWO is compliant with the applicable operating requirements in $63.6a8O(l) and pressure relief requirements
in $63.648(i)(2) for potential leaks from pilot-operated PRD discharge vents and balanced bellows PRD bonnet
vents. Routine instrument monitoring is conducted as specified in $60.485(b) or $63.180(c), and as applicable,
no later than 5 calendar days after the pressure relief device returns to organic HAP gas or vapor service
following a pressure release to demonstrate that the pressure relief device is operating with no detectable
emissions (instrument reading of less than 500 ppm).
c. Q63.655(exl0xiii) - Pilot-Operated PRDs Atmos. Release of 72 lbs. of VOC/dav or sreater
For pilot-operated pressure relief devices in organic HAP service, there were no pressure releases to atmosphere
through the pilot vent that equals or exceeds 72 pounds of VOC per day during the reporting period. The
duration of pressure releases through the pilot vent with the estimate of the mass quantity of each organic HAP
released will be reported if the limit is exceeded.
d. S63.655(sXl0Xiv) - PRDs Subiect to S63.648(iX3) - Release reportins ly/ RCA & CA
The primary release valves for all applicable pilot-operated and balanced bellows PRDs at the facility are routed
through a closed vent system to a conffol device, back into the process, or to the fuel gas system as described in
$63.6480X4). Therefore, BWO is not required to comply with the new provisions for pressure release
management as provided in paragraph $63.6480X3).
XI. Periodic Report for Flares subject to $63.670 - $63.655(gXll)
a. S63.655(eX1lXi) - Each lS-minute block durine which there was at least one minute when resulated
material is routed to a flare and no pilot flame is present.
b. Q63.655(eXl lxii) - Visible emission records as soecified in oaraeraph (il(9xiil(C) of this section for each
period of 2 consecutive hours durins which visible emissions exceeded a total of 5 minutes.
West Flare X-ltfl)
Absence of Pllot Fleme &
> I Mln Flow Regulrted Mrterhl
Abccncc of Ptlot Fhoc &
> I Mh Flow Regulrtcd Metcrlel
Estlmeted Vlslble Emlsrlons > 5
Mln for erch perlod of 2
couecutve hours
Erdmrted Vblble Emlgrlonr > 5
Mlo for cech perlod of2
8lll2124 16:00 - l8:00 9/23/2024 7:45 - 9:45
81212024 14:00 - l6:00 9D312024 12:40 - 14:40
81612024 l4:30 - l6:30 912312024 l5:00- l7:00
South Flare X-913
f,xceedance
Date & Time
(2 Hr Blocks)
Estimated Visible llmissions > 5
Min for each period of 2
consecutive hours
Exceedance
Date & Time
(2 Hr Blocks)
Estimated Visible Emisslons > 5
Min for erch period of 2
consecutive hours
1t17i2024 ll:00 l3:00 5.4 minutes 9'23 2024 7:10 - 9:l()24.9 nrinutcs
817120249'o0 ll:00 5.4 minutcs 9t23i20?4 16:00 llt:00 10.3 rninutes
c. Q63.655(eXl l)(iii) The lS-minute block neriods for which the applicable operatine limits
specified in Q63.670(d) throueh (f) are not met.
i. Flare Tip Velocitv Limit Exceedances - $63.670(d)
For purposes of 963.655(gX 1 I Xiii), the following table provides periods when the Flare Tip Velocity
operating limits in N63.670(d) were not met.
ii. Combustion Zone Operatine Limit Exceedances - {i63.670(e)
For purposes of the periodic reporting requirements of 963.655(gX I l Xiii), the fbllowing table provides
periods when the combustion zone operating limits in $63.670(e) were not met.
South Flare X-913
iii. Perimeter Air Assist Flare Dilution - $63.670(e)
BWO does not have a flare with perimeter air assist so the dilution operating linrits and reporting
provisions in $63.670(0 do not apply to the facility.
MACT CC - Requirements for Flare Control Devices - $63.670(d)
West Flare X-1800 South Flare X-913
Excedance Date & Time
(15 Min Blocks)
Vtip l5
>Vmer l5
Erceedance Dete & Time
(15 Min Blocks)
vtlpl5
>Vmaxl5
Nonc to Rcporl Nonc to Report
MACT CC - Requirements for Flare Control lhvices - S63.670(e)
\ilest Flare X-1t00
Exceedrnce Date & Time
(15 Ntin Blocks)
< 270 btu/scf
(15 1!lin Blocks)
f,xceedance Date & Tlme
(15 Min Blocks)
< 270 btu/scf
(15 Min Blocks)
None to Repofl Nonc to Report
MACT CC - Requlremenls for Flare Control Devlces - $53.670(e)
fxceedance Date & Time
(15 Nlin Blocks)
< 270 btu/scf
(15 Min Blocks)
Exceedance Dale & Time
(15 Min Blocks)
< 270 btu/scf
(15 Min Blocks)
7t17t2021 15:00 244.5 10,'14,2024 23 45 41 2
7/l'712024 l5:15 194.7 I 0i I 5/2024 0:00 45.6
l0'14'2024 22:30 2 t9.5 10,'l 5i202.{ 0: I 5 592
10, 1412024 22:45 72.6 l2'tl/2024 I I :30 156.9
10i1412024 2300 60.5 l2ttlt2024 ll 45 3 t.5
r o' l 4,'2024 2l: I 5 7 5.7 l2,rlli202.1 t2:00 31.7
l0r 14i2024 23:30 73.7 12, 1r,.202.1 l 2: l 5 I16.3
d. $63.655(sXllXM For Flarins events meetins the criteria in Q63.670(o)(3)
863.655(sXllXiv) Results of RCA and Corrective Action
The event on September 23,2024, were the result of a Rocky Mountain Power substation malfunction and
fire that resulted in a refinery-wide loss of power. The root cause of the event was off-site and out of Big
West Oil's control. This root cause contributes to both line items in the Table shown in section XI.d.
Excessive visible emissions were a result of a sudden, unexpected routing of relief gases from refinery
process units to both refinery flares. Flare steam assist systems were not functioning due to loss of power
and loss of boiler steam make capabilities. During the plant-wide emergency shutdown and startup, Big
West Oil personnel utilized flare minimization practices as closely as possible without posing risk to
employee and community health and safety.
Big West Oil has evaluated this event and evaluated potential corrective actions to mitigate the impact that a
future similar event would have on BWO's compliance with environmental limits. Due to the nature of this
event being entirely out of BWO's control, any major modification to the site's flare system would pose
significant complexities from permitting, economic, and logistical perspectives.
Alternative Test Methods
BWO uses both ALT-124 and ALT-l3l for monitoring the net heating value on the monitoring systems
associated with both flares (X-913 and X-1800). These methods are included in Attachment A.
Performance Evaluation for Flare NHV:
Not applicable for the current roporting period.
XII. Delayed Coking Unit Periodic Report - S63.655(gX12)
Not applicable; BWO does not operate a delayed coking unit.
XIII. Maintenance Vents Periodic Report - S63.655(gX13)
Pursuant to the maintenance vents periodic reporting requirements in $63.643(c), the following table will provide
any releases during the reporting period exceeding the applicable limits in $63.6a3(c)(l). The table below also
fu lfi lls reporting requirements established in $ 63. 655 (gX I 3).
BWO has not utilized the options in $63.6a3(c)(l)(iv) or $63.643(cXlXv). Therefore, there are no additional
reporting requirements for the Maintenance Venting provisions.
e.
g.
31.3 fl:/sec
ldcudhdon of thc
MdntcnraeVcnt (MY)
XfV. Notification of Compliance Status Changes - $63.655(9)(14) & $63.655(0
a. Updated NOCS - Storaee Vessels $63.655(fl(1xi)
For purposes of $63.655(0(6) and $63.640(lX3), BWO provides the following updates to the Notification
of Compliance Status report.
b.
Ul The date indicated is the month and year ofthe tirst degassing and cleaning aclivigfor an existingfloating roofsbrage vessel not awently
complianl. These lanks will achieve compliance lhe next time the lank is removedlrom senice prior to stutup.
On September 26,2016, BWO provided an initial NOCS required by 40 CFR 63 Subpart CC for amended
storage vessel requirements which became effective on April 29,2016.In this NOCS, BWO's wastewater
equalization tanks (Tank 9 and Tank 90) were included as Group I Storage Vessels subject to MACT CC.
However, these tanks are exempt from MACT CC per the definition of "Storage Vessel". Under MACT CC,
"Storage Vessel" does not include wastewater storage tanks. Therefore, Tank 9 and 90 will no longer be
considered as Group I Storage Vessels subject to MACT CC and will comply with 40 CFR 60 Subpart Kb.
Updated NOCS - Miscellaneous Process Yents (MPY) $63.655(0(lXii)
For purposes of $63.655(0(lxii), BWO provides an updated Notification of Compliance Status for
Miscellaneous Process Vents if applicable for the reporting period in the following table.
{ll Group I miscellaneous process venl meats a miscellaneorc process ventfor which the total organic HAP concentration is greater than or
eEul to 20 parts per million by vohw, and the total vohtile organic ampound emissions are greatel than or eqtal to 33 kilograns per day for
exisling sources and 6.8 kilograms per dayfor new sources at the outlet ofthefinal reavery device (dany) and priol to any control deyice and
prior to dbchuge to the atmospherc.
l2l Group 2 miscellaneots proc*s vent muns a iliscellaneotc pruess vent lhal dus nol meet the d{inilion of a Group I miscellueow
proc$s venl.
Attachment A
Net Heating Value Alternative Test Methods N-T-124 & ALT-l3l
DEPAIITMENT OF
ENVIHONMENTAL QUALITY
}llAR i ] (,:]!
DIVISION OF AIR OUALITY
.r+.,to "trae.g" 6 "'q
LYJ
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
BESEARCH TRIANGLE PARK, NC 27711
Mr. Chuck DeCarlo
Marketing Manager [tB 0 5 20i3
Extrel CMS. LLC
575 Epsilon Drive. Suite 2
Pittsburg. PA I 5238-2838
Mr. T'ony Slapikas
Product Manager for Mass Spectrometry
AMET'EK. Energy & Process Division
150 Freeport Road
Pittsburgh. PA I5238
Dear Mr. DeCarlo and Mr. Slapikas.
OFFICE OF
AIR OUALTY PLANNING
AND STANDARDS
I am w'riting in response to your letter dated August I 8. 201 7. requesting approval for use of
process nlass spectromelers as part of an alternative to testing procedures utilizing calorimeters
or gas chromatographs to measure Net Heating Value (NHVvri) in tlare vent gas as required
under 40 CFR Part 63, Subpart CC - National Emission Standards fbr Hazardous Air Pollutants
fiorn Petroleum Refineries. The owner or operator of tacilities subject to Subpart CC must
measure flare vent gas composition to determine NHVvr; in units of British Thermal Units per
standard cubic tbot (BTU/SCF). This BTU/SCF determination may be performed using a
calorimeter capable of continuously measuring, calculating, and recording NllVvr; at standard
conditions (40 CFR 63.670 (j)(3)) or equipment that determines the concenrration of individual
components in the flare vent gas (40 CFR 63.670 (iXl)), such as a gas chromatograph, and, if
desired. may directly measure the hydrogen concentration in the flare vent gas following the
methods provided in 40 CFR 63.670 (lX4). All monitoring equipment must meet the applicable
minimum accuracy, calibration and quality'controt requirements specified in Table l3 and
$63.671 of Subpart CC.
In your letter. you propose to use a process mass spectrometer analyzer and the following
measurement approach as an alternative to measure N[{Vvr;:
I ) The ouner or operator of the atfected facility will perfbrm a pre-survey to determine the list
and concentration of components that are present in flare vent gas tbed. This pre-survey will
be used in part to:
a) Determine an appropriate analysis method for the site-specific refinery flare vent gas:b) Create a list of vent gas components to be included in calibration gas cylinders to be used
to evaluate the quality'of the measurement procedure used to determine NHVvr;:c) Deflne calibration standards to be prepared by a l'endor at a certified accuracy of 2
percent and traceable to NIST; and
d) Pertbrm an initial calibration to identify mass tiagment overlap and response factors for
the target compounds.
lntemet Address (URL) o htp://www.epa.gov
Becycled/Becycleblo . Prtnted wtlh Vog€labb Oll Basod lnks on Reclclod Papor (Mintmum 257" PoslconsunEr)
2) The process mass spectrometer will be calibrated using calibration gas standards consistingof a mix of'the compounds identitled in the site specific flare gas pre-survey.3) During f)are gas analysis. compounds that are not identified during the pre-survey and thathave mass fragments identical to the compounds found during the pre-sirrvey will beincluded in the calculation of NHVv<;.4\ C'alibration error (CE) fbr each component in the calibration blend will be calculated usingthe follorving equation:r _acE="^ruoxloo
La
Where:
Cn,: Average instrument response. (ppm)
C" = Cylinder gas value or tag value, (ppm)
5) The average instrument CE lbr each calibration compound at any calibration concentration
must not differ by more than l0 percent fiom the cylinder gas value or tag value.6) For each set of triplicate injections at each calibration concentration fbr each calibrationcompound' any one introduction shall not deviate more than 5 percent liom the average
concentration measured at that level.
Your supporting infbnnation included Method 301 calculations that showed acceptable bias and
precision when you measured a mixture of gases trom a vendor certified gas cylinder. your
request also includes ref'erence to facilities needing to monitor flare gas composition
continuously to efl'ectively maintain flare etliciency while compensating fbr changes in the flare
gas composition.
With this letter. we are approving your request to substitute continuous process massspectrometry lbr continuous gas chromatography as allowed in 40 CFR 63.670 and 63.671predicated on both your proposed use of these process mass spectrometers as described aboveand the additional provisos listed below:
l) You must meet the requirements in 40 CFR 63.671 (eXl) and (2) including Table l3requirements tbr Net Heating Value by Gas Chromatograph.2) You ntay use the alternative sampling line temperature aliowed in 40 CFR 63, Subpart CC,Table 13, under Net Heating Value by Gas Chromatograph.3) You nlust meet applicable Performance Specification 9 (40 CFR parr 60, appendix B)requirements for initial continuous monitoring system acceptance including, but not limitedto:
o Performing a multi-point calibration check at three concentrations fbllowing theprocedure in Section 10.l: ando Perfbrming periodic process mass spectrometer calibrations as directed for gaschromatographs in 40 C)FR 63, Subpart CC, Table 13.4) You may augnlent the minimum list of calibratlon gas components found in 40 CFR63'671(e) rvith compounds lound during the pre-survey as needed to develop a site-specificanalysis method.
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5) For unknown gas components that have simirar anaryticar
compounds. you may report the unknowns as an inciease
compound.
mass fiagments to calibration
in the overlapped calibration gas
6) For unknor'r'n compounds that do not produce mass fragments that overlap calibrationcompounds. you may use the response f'actor fbr the neirest molecular *.ignt hydrocarbon inthe calibration mix to quantity the unknown component's NHVvc. This req"uirement parallelsthe requirernenrs in 40 cFR part63.67l (ex3) fbi gas chromarographs.7) You may use the response factor fbr n-pentane to quantily uny ,nkno*n componentsdetected rvith a higher molecular weight than n_pentane. '
8) You must meet all other applicable generic .eqrirem.nts of gg63.670 and 63.671 fbrmeasurement of NHVvci (i.e., measurement requirements noi specifically targeted to gaschromatographs).
9) A copy of this approval letter must be included in the report fbr each testing program wherethese alternative testing procedures are applied.
Since this alternative-test method approval under 40 cFR 63.7 (f) is appropriate for use at allfacilities subject to 40 cFR 63, Subpart CC. we will announce on EpA;s web site(https:/iv'wu'.epa.got/emc'/broadly-applicable-approved-ulterncrtive-test-methods) that thealternative method is broadly applicable to determination of NHVvr; under this subpart.
!fyou have any questions regarding this approval or need further assistance, please contact RayMerrill at [phone] or merrill.ral'[e-mail],. or Robin Segall at letoy 541-0g93 or
.s e ga I l. roh in@e pa. gor..
Sincerely.
Aa,,'/-i1*-'ilJ*"lt W s Mr
i
Steftan M. Johnson, Group Leader
Measurement Technology Group
Gerri Garwood. EPA/OAQPS/SPPD
Maria Malave. EPA/OECA/OC
Brenda Shine, EPA/OAQPS/SPPD
EPA Regional Testing Contacts
s'*X\'n
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
RESEARCH TRIANGLE PARK, NC 27711
Mr. Tinr Goedeker
Senior Principal Environmental Consultant
Phillips 66
2331 Cit"v-Wc'st Blvd. 5685
FIouston. TX77042.
Dear Mr. Goedeker:
OFFICE OF
AIR OUALITY PLANNING
AND STANDARDS
I am nriting in response to your letter dated September 26.2018. requesting approval fbr
alternatives to requirements in 40 CFR 63, Subpart CC - National Emission Standards lbr
Flazardous Air Pollutants liom Petroleum Ref-rneries (Subpart CC). and by reflerence.40 CtrR 60.
Appendix B. Pertbrmance Specitication 9 (PS 9) fbr determining Net Heating Value (Nflv).
You request using +10 percent agreement of the totalcalibration cylinder NHV as an alternative
to the PS 9 requirement that specifies calibration and calibration check individual compound
agreement of + l0 percent with cylinder certif ied tag values. You are requesting this altemative
lor broad application to allected facilities w,hich use Gas Chromatograph (GC) and/or Mass
Spectrometer (MS) technology for composition and corresponding NHV determinations required
under Subpart CC.
In y'our letter, you request the fbllowing specitic alternatives to the quality' assurance procedures
required in PS 9 and $$63.671(eX2) and (e)(3) when you demonstrate compliance with Subpart
CC:
Single daill' mid-level calibration check error to be calculated based on the total NHV of
a certitled calibration gas mixture. The instrument response filr NHV shall not vary by
more than l0 percent from the total NHV of the certified calibration gas mixture.
Quarterly multi-point calibration (see Table l3 of Subpart CC) error to be calculated
against the total NtlV of the certitled calibration gas mixtures (i.e.. low-. mid-. high-
level). 1'he average instrument response lbr total NHV shall not vary by more than I 0
percent from the total NHV of any of the certifled gas mixtures.
Your rationale lbr proposing these alternative procedures is based on the tenant that NllV is the
t'actor utilized to determine compliance with the Subpart CC flare combustion efliciency
requirement. These alternative procedures also simplify the calibration procedures fbr sites that
elect to use thenr. You provided calibration check data for both GC and MS NllV determinations
that shou the comparability of quality control on a per compound basis with quality control on a
total NHV basis.
lntemet Address (URL) ' htts://www epa gov
Hocycl.cuFecycl.bl. . Prhted wlth Veg€iabl€ Oil Bas€d lnks on Recycled Paper (Mlnlmum 257o Poslconsurn€r)
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You requesl these alternative procedures tbr use at Phillips 66 BP l'acilities subject to Subpart
CC and provide example taciiities including: Billings Refinery located at 401 S 23"1 Street.
Billings" MT. 59101: Ponca City Retinery located at 1000 S Pine Street. Ponca City, OK. 74601:-
and the Wood River Rellnery located at 900 S. Central Avenue, Roxana. IL. 62084.
With this letter, we are approving your request to use the relative percent error of total NtIV
measured versus the certified cylinder tag value for total NHV as the measure of agreement fbr
both the daily calibration and quarterly multi-point audits when using GC or MS tbr tlare tuel
l'eed NHV requirements in Subpart CC with the tbllowing provisos:
I ) Certified gas standards must be prepared consistent with the requirements in
$63.671(eX2).2) You must use certified calibration gases that meet the requirement in Section 7.I of PS 9
for daily calibration checks.
3) You must use performance audit gases that meet the requirements in Section 7.2 of PS 9
lbr 1'our quarterly multi-point calibration audits.
4) I'he measured NHV relative error lbr quarterly multi-point calibration audits must be
rvithin l0 percent of the certified cylinder gas tag value lbr NHV. NHV calculations must
be based on the individual component properties in Table l2 of Subpart CC. This
requirement replaces the compound-specific relative error requirement tbr perfbrmance
audits in Section 7.2 of PS 9.
5) Mid-level daily calibration standard measurements must also be within l0 percent of the
certitied of the cylinder gas tag value for NHV. This requirement replaces the compound-
specific relative error requirement for daily'calibration in Section 10.2 of PS 9.
You must include a copy of this approval letter in the report fbr each testing program or periodic
reporting period r"here these alternative testing procedures are applied.
Since this alternative test method approval under 40 CFR 63. Subpart CC, is appropriate fbr use
at all facilities subject to Subpart CC that must determine flare combustion efficiency, we will
announce on EPA's website (at https;r/'lru'.epo.goyiemc'/broadll'-applic'ablc-approved-
ultcrnatiw-test-methods) that our approval of this alternative is broadly applicable to 40 CFR 63.
Subpart CC. Should the alternative approvals authorized in this letter be superseded by tbrmal
actions to revise 40 CFR 63. Subpart CC. this approval may be rescinded.
If y'ou have any questions regarding this approval or need flrther assistance. please contact Ray
Merrill at (91 9) 541 -5225 or merrill.re)tmrrnr,rrru. g,or'.
Measurement Technology Group
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Cc: Jennifer Ahlskog, Phillips 66 Rodeo Refinery
Gerri Garwood, EPA/OAQPSiSPPD
Sri Kanukolanu, Phillips 66 Wood River Refinery
Maria Malave, EPA/OECA/OC
Dave Pavlich, Phillips 66 Principal Environmental Consultant
Ray Pilapil, Illinois Environmental Protection Agency
Brenda Shine, EPA/OAQPS/SPPD
EPA Regional Testing Contacts