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HomeMy WebLinkAboutDAQ-2025-002235fii\@,/. October 30,2024 Bryce Bird, Director Utah Division of Air Quality 195 North 1950 West P.O. Box 144820 Salt Lake ciry, uT 84114-4820 Re: New Source Performance Standard (NSPS). Subpart Ja - April l. 2024 - Seotember 30. 2024 Dear Mr. Bird: Attached is Tesoro Refining & Marketing Company, LLC's NSPS Subpart Ja semi-annual report as required by 40 CFR 60.108a(d) and 40 CFR 60.7(c) for the Salt Lake City (SLC) Refinery. This report addresses operations from April I ,2024 through September 30,2024 for the following sources: r All affected refinery flares, including the North Refinery Flare, South Refinery Flare and the Sulfur Recovery Unit (SRU) Flare. o The refinery fuel gas system and Cogeneration Turbine & Heat Recovery Steam Generation (HRSG) Systems, in accordance with the Utah PMz s SIP Subsection IX.H.1, which has been approved by UDAQ.o The Fluidized Cataly'tic Cracking Unit (FCU), CO Boiler, Electrostatic Precipitator (ESP), and Wet Gas Scrubber (WGS) for SO:, NOx, CO and PM, in accordance with refinery's Approval Order DAQE-AN103350075-18 issued by UDAQ. Refinery Flares: The North and South refinery flares are served by a common Flare Gas Recovery System (FGRS). These two flares serve all process units in the refinery, except for the SRU and the Tailgas Treatment Unit; these two process units are served by a dedicated SRU Flare. These three flares have been modified under $60.100a(c)(l) and are therefore subject to NSPS Subpart Ja. This report addresses the following Work Practice Standards at $60.103a(h), $60.103a(c)( I )(i), and $60.103a(c)( I Xii) as applicable for the refinery's North, South, and SRU Flares during the reporting period. Due to a shared FCRS, Tesoro is complying with the SOz work practice standard in $60.103a(c)( I )(i) at the North and South Flares by comparing cumulative SOz emissions from both flares to the 500 lb SOz Root Cause Analysis (RCA) and Corrective Action Analysis (CAA) applicability trigger. Similarly, Tesoro is complying with the Work Practice Standard at $60.103a(cX I Xii) by comparing cumulative flare gas sent to the two flares against the RCA/CAA applicability trigger of 500,000 scf/24-hour period in excess of the baseline scenarios identified in the refinery's NSPS Subpart Ja Flare Management Plan. Tesoro is complying with the Work Practice Standard at $60.103a(h) bV using a total sulfur analyzer in lieu of a HzS analyzer at the SRU Flare, in accordance with $60.107a(a)(2)(v). ENVIHONMEN]AL Jdrr.rboqrdtr.ry Tesoro Refining & Marketing Company DIPANTMENT OF OUAUTY LLC OCT 30 2024 t *qna cleit/era) DIVISION OF AIR OUALTTY HaNo DelrvpRso B-2-10335 The refinery most recently submitted an update to its NSPS Subpart Ja Flare Management Plan to USEPA on August 28,2022. In accordance with $60.103a(b)(2), Tesoro has operated in accordance with the latest updated plan during the reporting period. Since the end of the reporting period, an additional Flare Management Plan has been submitted and will be in effect during subsequent reporting periods. During the reporting period, there were no exceedances of the 500 lb SOZl24-hour period Work Practice Standard at $60. I 03a(c)( I )(i) or the 500,000 scfl24-hour period Work Practice Standard at $60.103a(c)( I Xii), based on observed cumulative gas flared concurrently from the North and South flares or SRU flare. Determination of flaring events that exceeded the 500,000 scf/24-hour period Work Practice Standard at $60. l03a(cX I Xii) consider applicable alternative operating scenarios established pursuant to $60. I 03a(a)(a)(ii). Details of any exceedances of the H:S 3-hour rolling average limit are included in the quarterly State Electronic Data Reports. Refinery Fuel Cas System: Tesoro is also subject to requirements within NSPS Subpart Ja for the V-917 refinery fuel gas balance drum. In accordance with the UDAQ-approved Utah PMz s Moderate Non-Attainment State Implementation Plan (SIP) Section IX.H.l l(g)(ii), which applies to petroleum refineries, Tesoro shall comply with specified applicable requirements within NSPS Subpart Ja for HzS content within refinery fuel gas. There were no exceedances of the 365-day rolling average limit during the reporling period. Details of any exceedances of the HzS 3-hour rolling average limit are included in the quarterly State Electronic Data Reports for the 2nd Quarter 2024 and 3rd Quarter 2024. Cogeneration Turbine & HRSG Systems: Tesoro has interpreted from the Utah PM: s Moderate Non-Attainment SIP that the East and West Cogeneration Turbines are subject to the same aforementioned provisions as the V-917 fuel gas system. Furthermore, SIP condition IX.H.l2(p)(iii)(c) applies specifically to the East and West Cogeneration Turbines and allow use of a SOz/O: or HzS CEMS. Each turbine fires a mixture of utility natural gas and sweet fuelgas, generated from amine treating of sour fuelgas in the SRU. This fuelgas differs in composition from that in the V-917 refinery fuelgas balance drum. In addition, downstream of each turbine, a HRSG system is installed for steam production using the turbine exhaust flue gas and additional refinery fuelgas from V-917. Tesoro operates a H:S Continuous Emissions Monitoring System (CEMS) to measure the mixture of natural gas and fuel gas fired at the Cogen turbine sections; both Cogen process trains (i.e. East and West) fire the same mixture of fuel, therefore the monitoring is achieved with one analyzer. As noted previously, the refinery fuel gas fired at the HRSGs is monitored with the H:S CEMS installed on the V-917 fuelgas drum. Therefore, Tesoro is complying with the existing HzS standard in SIP Section IX.H.I I (g)(ii) and condition IX.H.l2(p)(iii)(c) by complying with $60.102a(g)( I )(ii) for each fuel gas mixture. This monitoring approach was conducted in accordance with the Custom Fuel Monitoring Schedule Update to NSPS Subparts JlJaand GG, approved by EPA Region 8 on April 5, 2018. There were no exceedances of the HzS 365-day rolling average limit within $60.102a(g)(lXii) from the East and West Cogeneration trains during the reporting period. Details of any exceedances of the HzS 3- hour rolling average limit within $60.102a(g)(lXii) have been included in the State Electronic Data Reports for the 2nd Quarter 2024 and 3rd Quarter 2024. FCU Regenerator/CO Boiler/ESP/WGS: Tesoro is subject to requirements within NSPS Subpart Ja for the FCU affected facility, consisting of the FCU Regenerator, CO Boiler, ESP, and WGS. Effective January l, 2018, this equipment is regulated by Subpart Ja for PM, CO, and SO:. Stack testing was conducted to establish operating limits at the Regenerator, ESP, and Wet Gas Scrubber for PM on May 1,2024; the most recent operating limits became effective on April 1,2024. Details of any exceedances of the applicable CO limit (corrected to 0% Oz) within $60.102a(b)(4) for the FCU Regenerator/CO Boiler/ESP/WGS during the reporting period have been included in the State Electronic Data Reports for the 2nd Quarter 2024 and 3'd Quarter 2024. During the aforementioned reporting period, any deviations from allowable operating limits within $60.102a(c)(1)(i) and $60. l02a(c)( I Xii) for the FCU Regenerator/CO Boiler/ESPiWGS are included in the summary report tables and attachment tables (if applicable). Alignment with State Ouarterly Reports: Monitoring system performance for all regulated CEMS and Continuous Parametric Monitoring Systems (CPMS) at the North Flare (HuS, Flow and Total Sulfur), South Flare (HzS, Flow and Total Sulfur), SRU Flare (Flow and Total Sulfur), FCU WGS (SOz, NOx, CO and Oz), FCU CO Boiler Bypass Stack (SOz, NOx, CO, and Oz) V-917 Fuel Gas Balance Drum (HzS), East and West Cogeneration Turbine and HRSG trains (shared HzS) required by NSPS Subpart Ja are reported per $60.7(c) with the State Electronic Data Reports. These reports also address all CEMS QA/QC practices, including initial certification testing (i.e. 7-day drift test and initial Relative Accuracy Test Audits) and on-going Cylinder Gas Audits (CGAs) and RATAs. Tesoro submitted reports for 2nd Quarter 2024 and 3rd Quarter 2024. QNQC downtime for the CPMS for purposes of NSPS Subpart Ja at the FCU Regenerator/CO Boiler/ESP/WGS, including Total Power, Secondary Current, WGS Differential Pressure, WGS L/G Ratio and Total Coke-Burn are included in this report. Certifi cation Statement: I certifu 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. Please call Chris Kaiser at (801) 521-4959 if you have any questions. Sincerely. t()*o,r/ Dean P. Anderson Vice President Tesoro Refining & Marketing Company LLC Attachments cc: USEPA Region VIII SUBMITTED VIe CouRIeR Subpart Ja Summary Report ((10 CFR 60.7(c), 10 CFR 60.108a(d)(1-7)) tll Signed statement, if applicable, is included on the verification sheet. Unit: North Refinery Flare (Served by Shared Flare Gas Recovery with South Flare) Parameter: Hydrogen Sulfide (HrS) Reporting Period: April l, 2024 - September 30,2024 Work Practice 162 ppmvd H:S,3-hour Standard: rolling average Periods of Deviation from Work Practice Standardlrl: See submitted State Electronic Data2nd Quarter 2024 and 3rd Quarter 2024 Periods for which HzS monitoring data are not availabletrl: See submitted State Electronic Data Reports 2nd Quarter 2024 and 3rd Quarter 2024 Subpart Ja Summary Report ((40 CFR 60.7(c), 40 CFR 60.108a(d)(1-7)) tll Signed statement, if applicable, is included on the verification sheet. Unit: South Refinery Flare (Served by Shared Flare Gas Recovery with North Flare) Parameter: HzS Reporting Period trl: April l, 2024 - September 30,2024 Work Practice 162 ppmvd HzS,3-hourStandard: rolling average Periods of Deviation from Work Practice Standardtrl: See submitted State Electronic Data Reports 2nd Quarter 2024 and 3rd Quarter 2024 Periods for which HzS monitoring data are not availabletrl: See submitted State Electronic Data Reports 2nd Quarter 2024 and 3rd Quarter 2024 Subpart Ja Summary Report ((40 CFR 60.7(c), 10 CFR 60.108a(d)(l-7)) Unit: North and South Refinery Flares (Served by Shared Flare Gas Recoverv) Parameter: Sulfur Dioxide (SOz) Reporting Period: April 1, 2024 - September 30,2024 Work Practice 500 lb SOz/24-hour Standards: period, or 500,000 scf flared above baseline flare flow ttll24-hour period. Each standard applies as sum from both flares. Periods of Deviation from Work Practice Standards tl'21: Events identified below (SO2 and/or flare flow)[3]: None during reporting period. Periods for which Total Sulfur (TS) and flare flow monitoring data are not available t2l: See submitted State Electronic Data Reports 2nd Quarter 2024 and 3rd Quarter 2024 tll ln accordance with 40 CFR 60.103a(c)( 1)(ii), the work practice standard is set at 500,000 scf in excess of the baseline flow reported in the NSPS Ja Flare Management Plan. The baseline flow to the north and south flares is 0 scf/hr during normal operations. Therefore, the work practice standard is set at 500,000 scf per 24-hour period during normal operations. Four alternative baseline scenarios are identified in the NSPS Ja Flare Management Plan and the work practice standard is set at 500,000 scf above the applicable alternative baseline per 24- hour period only during the applicable scenario. Signed statement, if applicable, is included on the verification sheet. Time period indicate entire period 24-hour average remained over threshold. t2l t3l lll: 12) Subpart Ja Summary Report ((40 CFR 60.7(c), 40 CFR 60.108a(d)(1-7)) In accordance with 40 CFR 60.107a(a)(2Xv), a total sulfur monitor is used in lieu of a hydrogen sulfide monitor. Signed statement, if applicable, is included on the verification sheet. Unit: SRU Flare (no Flare Cas Recovery) Parameter: HzS Reporting Period: April l, 2024 - September 30,2024 Work Practice 162 ppmvd TS as HzS,Standardtrl: 3-hour rolling average Periods of Deviation from Work Practice Standardttl: See submitted State Electronic Data Reports 2nd Quarter 2024 and 3rd Quarter 2024 Periods for which TStrl monitoring data are not availablet2l: See submitted State Electronic Data Reports 2nd Quarter 2024 and 3rd Quarter 2024 lll: [2]: Subpart Ja Summary Report ((10 CFR 60.7(c), 40 CFR 60.108a(d)(l-7)) In accordance with 40 CFR 60.103a(c)( I )(ii), the work practice standard is set at 500,000 scf in excess of the baseline flow reported in the NSPS Ja Flare Management Plan. The baseline flow to the SRU Flare is 28,800 scf/hr. Therefore, the work practice standard is set at 528,800 scfper 24-hour period. Signed statement, if applicable, is included on the verification sheet. Unit: SRU Flare (no Flare Gas Recovery) Parameter: SOz Reporting Period: April l, 2024 - September 30,2024 Work Practice 500 lb SOz/24-hour Standard: period, or 500,000 scf flared above baseline flare flowtr1/24-hour period. Periods of Deviation from Work Practice Standardst2l: Event identified below (SO2 and/or flare flow): None during reporting period. Periods for which TS and flare flow monitoring data are not availablet2l: See submitted State Electronic Data Repofts 2nd Quarter 2024 and 3rd Quarter 2024 Unit: Y-917 Refinery Fuel Gas Balance Drum Parameter: HrS Reporting Period: April l, 2024 - September 30,2024 Emissions Limit: 162 ppmvd HzS, 3-hour Rolling Average Periods of Excess Emissions[1 See submitted State Electronic Data Reports 2nd Quarter 2024 and 3rd Quarter 2024 Periods for which HzS monitoring data are not availabletri: See submitted State Electronic Data Reports 2nd Quarter 2024 and 3rd Quarter 2024 Reporting Period: April l, 2024 - September 30,2024 Emissions Limit: 60 ppmvd HzS, 365-day Rolling Average Periods of Excess Emissionstrl No excess emissions during the reporting period For each Excess Emissions event: Explanation of the Exceedance: No excess emissions during the reporting period Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected facility or control system: No excess emissions during the reporting period A description of the action taken, if any:No excess emissions during the reporting period Periods for which H:S monitoring data are not rvailabletrl: See submitted State Electronic Data Reports 2nd Quarter 2024 and 3rd Quarter 2024 []: Signed statement, if applicable, is included on the verification sheet. Unit: East Cogen & West Cogen Turbines Parameter: HrS Reporting Period: April 1, 2024 - September 30,2024 Emissions Limit: 162 ppmvd H:S, 3-hour Rolling Average Periods of Excess Emissionstrl See submitted State Electronic Data Reports 2nd Quarter 2024 and 3rd Quarter 2024 Periods for which H:S monitoring data are nol availabletrl: See submitted State Electronic Data Reports 2nd Quarter 2024 and 3rd Quarter 2024 Reporting Period: April l, 2024 - September 30,2024 EmissionsLimit: t:fil"fi5iilgou.,u*. Periods of Excess Em issionsl I 1 No excess emissions during the reporting period For each Excess Emissions event: Explanation of the Exceedance: No excess emissions during the reporting period Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected facility or control system: No excess emissions during the reporting period A description of the action taken, if any:No excess emissions during the reporting period Signed statement, if applicable, is included on the verification sheet. UNit: FCU _ WGS Parameter: CO Reporting Period: April l, 2024 - September 30,2024 Emissions Limit: 500 ppmvd CO, corrected to |Yo Oz, l-hr Block Aueraee Periods of Deviation from Emissions Limit See submitted State Electronic Data Reports Znd Quarter 2024 and 3rd Quarter 2024 Periods for which CO monitoring data are not availabletrl: See submitted State Electronic Data Reports Znd Quarter 2024 and 3rd Quarter 2024 []: Signed statement, if applicable, is included on the verification sheet. Unit: FCU - ESP Parameter: Total Power Reponing Period: April l, 2024 - September 30,2024 Operating Limitslrl: 0 kW All limits as 3-hour rollins cNerase I ) Duration of Excess Emissions in reporting period lue to: l) CMS downtime in reporting period due to: a) Startup/ 0 hr shutdown a) Monitor equipment 0.0 hr malfunctions b) Controlequipment oroblems hr0 b) Non-Monitor equipment 0.0 hr malfunctions hrc)Process Problems hr0.0c) Qualiry assurance calibration d) Other known causes 0 hr d) Other known causes 0.0 hr e) Unknown causes 0 hr e) Unknown causes 0.0 hr 2) Total duration ofexcess 0 hr emissions: 2) TotalCPMS downtime: 0.0 hr 3) Total Operatins Hoursl rl 4392 hr 3 ) Total Operatine Hourslrl 4.392 hr 1) Excess Emissions, as 0.0 % lercentage of operating time ,o/o\ 4) CPMS downtime, as 0.00 % percentage of operating time (%) For each Excess Emissions event: Date ofthe Exceedance:No exceedances during reporting period Explanation of the Exceedance: Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected facility or control system: A description of the action taken, if any: For any periods for which monitoring data are not available, any changes made in operation of the emission control system during the period of data unavailability which could affect the abiliry of the system to meet the applicable emission limit. Minimum allowable Total Power was zero so no concern with meeting emission limit. [1]:$60.102a(c)( I )(i) requires for FCUs controlled by an average total power and secondary current above the performance test. ESP to maintain the 3-hour rolling level established during the most recent Unit: FCU _ ESP Parameter: Secondarv Current Reporting Period: April l, 2024 - September 30,2024 Cperating Limitstr): 0 Amps 4ll limits as 3-hour ,ollino averase I ) Duration of Excess Emissions in reporting period lue to: l) CMS downtime in reporting period due to: a) Startup/shutdown 0 hr a) Monitor equipment 0.0 hr malfunctions b) Controlequipment 0 hr problems: b) Non-Monitorequipment malfunctions 0.0 hr c) Process Problems 0 hr c) Quality assurance 0.0 hr calibration d) Other known causes 0 hr d) Other known causes 0.0 hr e) Unknown causes 0 hr e) Unknown causes 0.0 hr 2) Total duration ofexcess 0 hr emissions: 2) Total CPMS downtime: 0.0 hr 3) Total Ooeratine Hoursl rl 4.392 hr 3) Total Ooeratins Hourslrl 4392 hr {) Excess Emissions, as 0.0 % rercentage of operating time (%) 1) CPMS downtime, as 0.00 % lercentage of operating time 'vo\ For each Excess Emissions event: Date ofthe Exceedance:No exceedances during reporting period Explanation of the Exceedance: Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected faciliW or control system: A description of the action taken, if any: For any periods for which monitoring data are not available, any changes made in operation of the emission control system during the period of data unavailability which could affect the ability of the svstem to meet the aoplicable emission limit. Minimum allowable Secondary Current was zero so no concern with meeting emission limit. []: $60.102a(c)(l)(i) requires for FCUs controlled by an ESP to maintain the 3-hour rolling average total power and secondary current above the level established during the most recent performance test. Unit: FCU Regenerator Parameter: Coke-Burn Reporting Period: April l, 2024 - September 30,2024 operating Limitstrl: 20,671 lblhr 4ll limits as daily lVerage l) Duration of Excess Emissions in reporting oeriod due to: 1) CMS downtime in reporting period due to: a) Startup/ 0 hr shutdown a) Monitor equipment malfunctions hr0.0 b) Control equipment 0 hr problems: b) Non-Monitor equipment malfunctions hr0.0 c) Process Problems 0 hr c) Quality assurance 0.0 hr calibration d) Other known 0 hr causes d) Other known causes hr0.0 e) Unknown causes 0 hr e) Unknown causes 0.0 hr 2) Total duration of 0 hr excess emissions: 2) TotalCPMS 0.0 hr downtime: 3) Total Operating 4,392 hr Hourstll 3) Total Operating 4,392 hr Hourstll 4) Excess Emissions, as 0.0 % percentage of operating time (%) 4) CMS downtime, as 0.00 % percentage of operating time (%) For each Excess Emissions event: Date of the Exceedance:No exceedances during reporting period Explanation of the Exceedance: Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected faciliw or control svstem: A description of the action taken, if any: For any periods for which monitoring data are not available, any changes made in operation of the emission control system during the period of data unavailability which could affect the ability of the system to meet the applicable emission limit. No downtime during reporting period []: $60.102a(c)(lXii) requires the daily average exhaust coke burn-off rate not exceed the level established during the most recent performance test. Jnit: wGS Parameter: Differential Pressure Reporting Period: April I ,2024 - September 30,2024 Operating Limitstrl 4.4 in HzO 4ll limits as 3-hour ,ollins averaae l) Duration of Excess Emissions in reporting reriod due to: I ) CMS downtime in reporting period due to: a) Startup/ shutdown hr0 a) Monitor equipment 0.0 hr malfunctions b) Control equipment 0 hr oroblems b) Non-Monitor equipment 0.0 hr malfunctions c) Process Problems 0 hr c) Quality assurance 0.0 hr calibration d) Other known causes 7 hr d) Other known causes 0.0 hr e) Unknown causes 0 hr e) Unknown causes 0.0 hr 2) Totalduration of excess 7 hr :missions: 2) Total CPMS downtime: 0.0 hr l) Total Operatins Hourstrl 4,392hr 3) Total Operatins Hourstrl 4,392hr 1) Excess Emissions, as 0.2 % lercentage of operating time,%\ 4) CPMS downtime, as 0.00 % percentage of operating time (%\ lor each Excess Emissions event: Date ofthe Exceedance:Date: 4130-5 I I 12024 (interm ittent blocks) On multiple days including 4130-51112024, Tesoro conducted its annual source test to establish new operating parameters. The Wet Gas Scrubber was operated at multiple operating conditions to demonstrate compliance. Reference Method particulate testing conducted on these dates demonstrate the unit's particulate emissions were less than the 1.0 lb. PM/1,000 lb. of coke burn emission limit. The exceedance did not occur during a startup, shutdown, or malfunction. After the annual source test was completed, Wet Gas Scrubber parameters were returned to the nreviouslv establ ished setno ints. Explanation of the Exceedance: Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected facility or control system: A description of the action taken, if any: For any periods for which monitoring data are not available, any changes made in operation of the emission control system during the period of Cata unavailability which could affect the ability cf the system to meet the applicable emission limit. No downtime during reporting period [ ]: Operating limits for DP were established during performance testing. Operating limits determined by this testing are included in this Semiannual Report, and these limits are effective upon submittal of the report to UDAQ. Unit: wGS Parameter: L/G Ratio Reporting Period: April l, 2024 - September 30,2024 CperatingLimitstrl 65.3 galll\4scf 4ll limits as 3-hour nollins overase l) Duration of Excess Emissions in reporting period due to: l) CMS downtime in reporting period due to: a) Startup/ 0 hr shutdown l) Monitor equipment 0.0 hr malfunctions b) Controlequipment 0 hr nrohlems b) Non-Monitor equipment 0.0 hr malfunctions c) Process Problems 0 hr :) Quality assurance 0.0 hr :alibration d) Other known causes 0 hr 1) Other known causes 0.0 hr e) Unknown causes t hr :) Unknown causes 0.0 hr 2) Total duration ofexcess 0 hr emissions: 2) TotalCPMS downtime: 0.0 hr 3)TotalOperatineHourstrl 4.392hr 3) Total Operating Hourstll 4.392 hr 4) Excess Emissions, as 0.2 % percentage of operating time (%\ 4) CPMS downtime, as 0.00 % percentage of operating time (%\ For each Excess Emissions event: Date ofthe Exceedance:Date: 4 130 -5 I I 12024 (interm ittent blocks) On multiple days including 4130-51112024, Tesoro conducted its annual source test to establish new operating parameters. The Wet Gas Scrubber was operated at multiple operating conditions to demonstrate compliance. Reference Method particulate testing conducted on these dates demonstrate the unit's particutate emissions were less than the 1.0 lb. PM/1,000 lb. of coke burn emission limit. The exceedance did not occur during a startup, shutdown, or malfunction. After the annual source test was completed, Wet Gas Scrubber parameters were returned to the previouslv established setpoints. Explanation of the Exceedance: Whether the exceedance was concurrent with a startup, shutdown, or malfunction of an affected facility or control system: A description of the action taken, if any: For any periods for which monitoring data are rot available, any changes made in operation of :he emission control system during the period of lata unavailability which could affect the ability rf the system to meet the applicable emission Limit. No downtime during reporting period []: Operating limits for DP were established during performance testing. Operating limits determined by this testing are included in this Semiannual Report, and these limits are effective upon submittal of the UTAH DFPAR]MENT EI.JVI RONMENTAL QUALITY DIVISION OF AIR OUALITY report to UDAQ.