DAQ-2025-002101

ChevTon
Troy Tortorich Salt Lake Refinery
Refinery Manager Chevron Products Company
685 S Chevron Way
North Salt Lake, UT 84054
Tel [phone]
Fax [phone]
March 27, 2025
VIA ELECTRONIC SUBMISSION TO:
Erica Pryor, epryorI)utah.gov
Mr. Bryce Bird, Division Director
Utah Air Quality Division
P.O. Box 144820
195 North 1950 West
Salt Lake City, UT 84114-4820
Subject: Chevron Comments to Proposed Amendments to Utah State Implementation Plan, Section
IX, Part H.12
Dear Director:
The Chevron Products Company Salt Lake Refinery (the "Refinery") appreciates the opportunity to
provide comments regarding the Utah Division of Air Quality (UDAQ) proposed amendments to the Utah
State Implementation Plan (SIP), Section IX, Part H.12. We look forward to working with UDAQ staff to
facilitate the necessary changes to the proposed particulate mailer SIP.
Comment No. 1: Initial Stack Testing Compliance Date Infeasibility
The Fluid Catalytic Cracking unit (FCC) furnaces (F-32021 FCC Furnace #1 and F-32023 FCC Furnace
#2) are not currently configured with stack testing ports. Due to unforeseen circumstances at the Refinery,
the installation of the stack testing ports on those furnaces can no longer be safely completed during 2025.
We request to adjust the initial compliance stack testing deadline to allow additional time to safely install
the stack testing ports. We request that Subsections IX.H.12.d.iv and IX.H.12.d.v be revised to the
following.
Subsection IX.H.12.d.iv
Initial compliance testing for F-66100 VGO Furnace #1 and F-66200 VGO Furnace #2 is required.
The initial test shall be performed no later than December 31st, 2025. After the initial compliance
test, stack testing shall be performed at least once every three (3) years from the date of the last
stack test. Stack testing shall be nerformed as outlined in IX.H. 11 .e.
Subsection IX.H.12.d.v
A stack testing port shall be installed for F-32021 FCC Furnace #1. F-32023 FCC Furnace #2. F-
35001 Reformer Furnace F-I. and F-35002 Reformer Furnace F-2 and initial compliance testing
shall be performed no later than December 31st, 2027. Stack testing shall be performed as outlined
in IX.H.1 I.e.
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Comment No. 2: Stack Testing Frequency Revision
The proposed language regarding the timing of stack testing for the boilers and furnaces currently
requires that "stack testing shall be performed at least once every three (3) years from the date of the last
stack testing".
Requiring the timing of the stack testing to be based on the previous stack testing date will cause the
testing dates to shift forward within the calendar year every time to ensure compliance. To maintain the
Refinery in a safe posture while meeting required production rates for stack testing requires the
predictability of the testing to be at the same time every year. This also provides greater flexibility during
instances where periods of maintenance or process shutdowns would otherwise require moving planned
testing forward.
Additionally, there are several regulations that allow flexibility for the timing of stack testing.
" R307-1 65-2, Testing Frequency, states "stack testing at least once every five years"
" 40 CFR Part 60, Subpart Db, Standards ofPerforinance for Industrial-Commercial-Institutional
Steam Generating Units, states "Conduct subsequent performance tests once per calendar year or
every 400 hours of operation (whichever comes first)"
" 40 CFR Part 63, Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants
for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters, states
"you may choose to conduct performance tests for the pollutant every third year. Each such
performance test must be conducted no more than 37 months after the previous performance
test."
" New Hampshire Administrative Code Env-A 803.03, Periodic Compliance Stack Testingfor
NOx, states "The periodic compliance stack testing... shall be conducted at least every 3 years, or
within 12 calendar quarters, after the date of the initial compliance stack test"
Based on the language in these regulations, we request that Subsections IX.H.12.d.ii, IX.H.12.d.iv, and
IX.H.12.d.v be revised to either of the two following sets of suggested wordings. Please note that the
following proposed language includes the changes requested in Comment L
1)
Subsection IX.H.12.d.ii
Initial NOx stack testing has been performed for the following units: F-I 1005 Boiler #5, F- 11006
Boiler #6, F-2 1001 Crude Furnace #1. F-2 1002 Crude Furnace #2, F-360 17 Alkylation Furnace.
and F-70001 Coker Furnace. For these units, stack testing shall be conducted at least once every
three (3) years. Stack testing shall be performed as outlined in IX.H. 11 .e.
Subsection IX.H.12.d.iv
Initial compliance testing for F-66100 VGO Furnace #1 and F-66200 VOD Furnace #2 is required.
The initial test shall be performed no later than December 31st. 2025. After the initial compliance
test, stack testing shall be performed at least once every three (3) years. Stack testing shall be
performed as outlined in IX.H.1 I.e.
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Subsection IX.H.12.d.v
A stack testin oil shall be installed for F-32021 FCC Furnace #1 F-32023 FCC Furnace #2 F-
35001 Reformer Furnace F-I and F-35002 Reformer Furnace F-2 and initial corn liance testin
shall be rforrned no later than Decernber 31st 2027. After the initial corn liance tes stack testin
hall be rforrned at least once eve three 3 ears. Stack testin shall be rformed as outlined
in IX.1-I.1 I.e.
2)
Subsection IX.H. 12.d.ii
Initial NOx stack testin has been erformed for the followin units: F-I 1005 Boiler #5 F-47
11006 Boiler #6 F-21001 Crude Furnace #1 F-21002 Crude Furnace #2 F-36017 Alk lation
Furnace and F-70001 Coker Furnace. For these units stack testin shall be conducted at least once
e er thi -seven 37 rnonths. Stack testin shall be erformed as outlined in IX.H.1I.e.
Subsection IX.H.12.d.iv
Initial corn liance testin for F-66100 VGO Furnace #1 and F-66200 VGO Furnace #2 is re uired.
The initial test shall be erforrned no later than December 31st 2025. After the initial corn liance
test stack testin shall be erformed at least once ever thi -seven 37 months. Stack testin
shall be erforrned as outlined in iX.H.1 I.e.
Subsection IX.H.12.d.v
A tack testin ri shall be installed for F-3202I FCC Furnace #1 F-32023 FCC Furnace #2 F-
35001 Reforrner Furnace F-i and F-35002 Reformer Furnace F-2 and initial corn liance testin
shall be rforrned no later than Decernber 31s 2027. After the initial corn liance test stack testin
shall be erformed at least once thi -seven 37 rnonths. Stack testin shall be erforrned as
outlined in IX.H.1 I.e.
If you have any questions, please contact Lauren Vander Werff at [phone] or
LVanderWerff chevron.corn.
Sincerely,
Troy Tortorich
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