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HomeMy WebLinkAboutDAQ-2025-0024701 DAQC-435-25 Site ID 10119 (B1) MEMORANDUM TO: FILE – CHEVRON PRODUCTS COMPANY – Salt Lake Refinery THROUGH: Harold Burge, Major Source Compliance Manager FROM: Joe Rockwell, Environmental Scientist DATE: May 2, 2025 SUBJECT: FULL COMPLIANCE EVALUATION (FCE #2 of #4) – WWTP, Tanks and Rail Loading Rack – Major, Davis County, FRS #UT0000004901100003 INSPECTION DATE: April 22-24, 2025 SOURCE LOCATION: 2351 North 1100 West, North Salt Lake, Utah MAILING ADDRESS: 685 South Chevron Way, North Salt Lake, Utah 84054 SOURCE CONTACT: Lauren Vander Werff, Environmental Team Lead, 801-539-7386 lvanderwerff@chevron.com OPERATING STATUS: Operating PROCESS DESCRIPTION: This inspection applies to the Waste Water Treatment Plant (WWTP), Tank Farm, and Crude Railcar Loading Rack. Chevron controls emissions from storage tanks by fitting tanks with either fixed roofs or external floating roofs. The tanks are used for storage of feedstocks and intermediate products awaiting further processing and/or blending. Tanks are also used for storing finished product. The roofs float on top of the product by means of a pontoon. The design of a floating roof is to control emissions by eliminating the vapor space in the tank and to minimize the amount of hydrocarbons exposed to the air. Roof seals on the edges of the floating roof control the emissions. Periodic inspections ensure the roof seals are intact and against the tank wall. Emissions from any gaps exceeding the limitations specified in the conditions below are calculated and included in the annual emissions inventory. The crude railcar loading rack has a design crude loading rate of 10,000 barrels per day. Railcars are loaded with crude for export by rail. A vapor recovery unit (VRU) serves as the air pollution control device to reduce VOC emissions during railcar loading. 2 APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN101190104-22, dated September 26, 2022 Utah Administration Code (UAC) R307-327 – Petroleum Liquid Storage 40 CFR 63 Subpart CC – MACT for Petroleum Refineries (portions applicable to storage tanks) 40 CFR 60 Subpart Kb – NSPS for Volatile Organic Liquid Storage Vessels 40 CFR 61 Subpart FF – NESHAP for Benzene Waste Operations SOURCE INSPECTION EVALUATION: Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] Status: This is a statement of fact and not an inspection item. I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] Status: In compliance – No limitations were noted to be exceeded at time of inspection. I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] Status: In compliance – No modifications to the equipment or processes were noted at time of the inspection. I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five (5) years. [R307-415-6b] Status: In compliance – Electronic and hard copy records were made available, for review, at time of the inspection. I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] Status: In compliance – The refinery appeared to be well maintained and operated at time of the inspection. The Maximo database is used to track preventative maintenance (PM) and as needed maintenance for the entire facility. 3 I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In compliance – The refinery is aware of the breakdown rule (UAC R 307-170) and breakdown reports. Breakdowns are also covered under federal regulations. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In compliance – Emission inventories have been submitted as required. The 2024 annual emission inventory was submitted on April 9, 2025. I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] Status: In compliance – The construction status notice regarding the Wastewater Treatment Plant equipment upgrades (2 Nitrogen Floatation Units), dated March 14, 2024, was received by the UDAQ on March 20, 2024. The two Nitrogen Floatation Units commenced operation in April 2025. See status of condition II.A and attached construction status correspondence. SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Tanks and WWTP II.A.2 Wastewater Treatment Plant (WWTP) Wastewater installations Two (2) dissolved nitrogen flotation units (NEW) Capacity: 3,000 gpm Each Collection box sump drains (approximately 513) Junction boxes (approximately 88) Dewatering devices Control: Regenerative thermal oxidizer Rotating biological contactors Submerged biological contactors Carbon canister controls II.A.3 Tank D09312 Capacity: 750 bbl Type: vertical fixed roof Contents: only sludge II.A.4 Tank D21016 Capacity: 50 bbl Type: horizontal Contents: chemical additive 4 II.A.5 Tank D61011 Capacity: 50 bbl Type: vertical fixed roof Contents: chemical additive tank (not currently in use) II.A.6 Tank D61012 Capacity: 50 bbl Type: vertical fixed roof Contents: chemical additive tank (currently not in use) II.A.7 Tank D61013 Capacity: 500 bbl Type: vertical fixed roof Contents: chemical additive (not currently in use) II.A.8 Tank D61014 Capacity: 500 bbl Type: vertical fixed roof Contents: chemical additive II.A.9 Tank D61045 Capacity: 300 bbl Type: internal floating roof Contents: chemical additive II.A.10 Tank T10085 Capacity: 10,000 bbl Type: vertical fixed roof Contents: petroleum distillates II.A.11 Tank T10086 Capacity: 10,000 bbl Type: vertical fixed roof Contents: petroleum distillates II.A.12 Tank T10094 Capacity: 10,000 bbl Type: external floating roof Contents: waste water/slop oil II.A.13 Tank T10095 Capacity: 10,000 bbl Type: external floating roof Contents: gasoline/blend components/feedstock storage 5 II.A.14 Tank T15088 Capacity: 15,000 bbl Type: vertical fixed roof Contents: petroleum distillates II.A.15 Tank T15090 Capacity: 15,000 bbl Type: vertical fixed roof Contents: petroleum distillates II.A.16 Tank T15093 Capacity: 15,000 bbl Type: external floating roof Contents: gasoline/blend components/feedstock storage II.A.17 Tank T15098 Capacity: 15,000 bbl Type: vertical fixed roof Contents: petroleum distillates II.A.18 Tank T15099 Capacity: 15,000 bbl Content: vertical fixed roof Contents: petroleum distillates II.A.19 Tank T15103 Capacity: 15,000 bbl Type: external floating roof Contents: waste water/slop oil II.A.20 Tank T15104 Capacity: 15,000 bbl Type: external floating roof Contents: waste water/slop oil II.A.21 Tank T1511 Capacity: 1,500 bbl Type: external floating roof Content: caustic storage II.A.22 Tank T1512 Capacity: 1,500 bbl Type: external floating roof Content: caustic storage II.A.23 Tank T20015 Capacity: 20,000 bbl Type: external floating roof Contents: waste water/slop oil 6 II.A.24 Tank T20016 Capacity 20,000 bbl Type: external floating roof Content: waste water/slop oil II.A.25 Tank T20017 Capacity: 20,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.26 Tank T20018 Capacity: 20,000 bbl Type: external floating roof Contents: gasoline/blend components/feedstock storage II.A.27 Tank T20019 Capacity: 20,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.28 Tank T20030 Capacity: 20,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.29 Tank T20031 Capacity: 20,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.30 Tank T20032 Capacity: 20,000 bbl Type: vertical fixed roof Contents: petroleum distillates II.A.31 Tank T20033 Capacity: 20,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.32 Tank T20040 Capacity: 20,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.33 Tank T2111 Capacity 2,300 bbl Type: external floating roof Content: waste water/slop oil 7 II.A.34 Tank T25108 Capacity: 25,000 bbl Type: external floating roof Content: waste water/slop oil II.A.35 Tank T25109 Capacity: 25,000 bbl Type: external floating roof Content: waste water/slop oil II.A.36 Tank T30020 Capacity: 30,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.37 Tank T30021 Capacity: 30,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.38 Tank T30022 Capacity: 30,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.39 Tank T30023 Capacity: 30,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.40 Tank T30024 Capacity: 30,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.41 Tank T30041 Capacity: 30,000 bbl Type: vertical fixed roof Contents: petroleum distillates II.A.42 Tank T30042 Capacity: 30,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.43 Tank T30043 Capacity: 30,000 bbl Type: vertical fixed roof Content: petroleum distillates 8 II.A.44 Tank T30069 Capacity: 30,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.45 Tank T30074 Capacity: 30,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.46 Tank T30080 Capacity: 30,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.47 Tank T30081 Capacity: 30,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.48 Tank T30082 Capacity 30,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.49 Tank T30091 Capacity: 30,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.50 Tank T30092 Capacity: 30,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.51 Tank T30096 Capacity: 30,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.52 Tank T30097 Capacity: 30,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.53 Tank T30107 Capacity: 30,000 bbl Type: external floating roof Content: waste water 9 II.A.54 Tank T3350 Capacity: 5,000 bbl Type: external floating roof Content: oily sludge II.A.55 Tank T35110 Capacity: 35,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.56 Tank T40050 Capacity: 40,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.57 Tank T40051 Capacity: 40,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.58 Tank T40052 Capacity: 40,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.59 Tank T40070 Capacity 40,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.60 Tank T40071 Capacity 40,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.61 Tank T40072 Capacity: 40,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.62 Tank T40073 Capacity: 40,000 bbl Type: external floating roof Content petroleum distillates/gasoline blend components storage II.A.63 Tank T40075 Capacity: 40,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage 10 II.A.64 Tank T40076 Capacity 40,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.65 Tank T40100 Capacity: 40,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.66 Tank T40112 Capacity: 40,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.67 Tank T50078 Capacity: 50,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.68 Tank T50079 Capacity 50,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.69 Tank T50113 Capacity: 50,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.70 Tank T5038 Capacity: 5,000 bbl Type: external floating roof Content: slop oil II.A.71 Tank T5083 Capacity: 5,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.72 Tank T5084 Capacity: 5,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.73 Tank T60059 Capacity: 60,000 bbl Type: external floating roof Content: crude oil storage 11 II.A.74 Tank T60060 Capacity: 60,000 bbl Type: external floating roof Content: crude oil storage II.A.75 Tank T60061 Capacity: 60,000 bbl Type: external floating roof Content: crude oil storage II.A.76 Tank T60062 Capacity: 60,000 bbl Type: external floating roof Content: crude oil storage II.A.77 Tank T60063 Capacity: 60,000 bbl Type: external floating roof Content: crude oil storage II.A.78 Tank T60077 Capacity: 60,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.79 T60114 60,000 bbl vertical fixed (cone) roof petroleum distillates storage tank II.A.80 Tanks T60118 Capacity: 60,000 bbl Type: vertical fixed roof Content: petroleum distillates II.A.81 Tank T90116 Capacity: 90,000 bbl Type: external floating roof Content: crude oil storage II.A.82 Tank T90117 Capacity: 90,000 bbl Type: external floating roof Content: crude oil storage II.A.83 Tank T7513 Capacity: 7,000 bbl Type: external floating roof Content: slop oil service storage 12 II.A.84 Tank T7514 Capacity: 7,000 bbl Type: internal floating roof Content: gasoline/blend components/feedstock storage II.A.85 Tank T7539 Capacity: 7,000 bbl Type: external floating roof Content: slop oil II.A.86 Tank T80115 Capacity: 80,000 bbl Type: external floating roof Content: gasoline/blend components/feedstock storage II.A.87 Tank T934 Capacity: 900 bbl Type: vertical fixed roof Content: caustic storage II.A.88 Tank V12684 Capacity: 1,300 bbl Type: horizontal pressure vessel Content: propane II.A.89 Tank V12685 Capacity: 1,300 bbl Type: horizontal pressure vessel Content: propane II.A.90 Tank V2567 Capacity: 2,500 bbl Type: pressurized sphere Content: butane II.A.91 Tank V31159 Capacity: 150 bbl Type: horizontal Content: chemical additive II.A.92 Tank V5064 Capacity 5,000 bbl Type: pressurized sphere Content: butane II.A.93 Tank V5065 Capacity: 5,000 bbl Type: pressurized sphere Content: butane 13 II.A.94 Tank V5066 Capacity: 5,000 bbl Type: pressurized sphere Content: olefin II.A.95 Tank V76801 Capacity: 650 bbl Type: horizontal pressure vessel Content: propane II.A.96 Tank V76802 Capacity: 650 bbl Type: horizontal pressure vessel Content: propane II.A.97 Tank V76803 Capacity: 650 bbl Type: horizontal pressure vessel Content: propane II.A.98 Loading Rack Railcar loading/unloading rack Controlled by vapor combustor unit Status: In compliance – No unapproved tanks were noted at time of the inspection. There are eight tanks that are considered to be Waste Water Treatment Tanks (items II.A.3, II.A.19, II.A.20, II.A.33, II.A.34, II.A.35, II.A.53, and II.A.54). The remaining tanks are tank farm tanks. The two dissolved nitrogen flotation (DNF) units (item II.A.2) were installed and commenced operation in April 2025. SECTION II: SPECIAL PROVISIONS II.B Requirements and Limitations II.B.1 Site-Wide Requirements II.B.1.a The owner/operator shall not exceed the following as listed under SIP Section IX.H.2.d, and Section IX.H.12.d: A. PM10 0.715 tons per day (tpd) and B. PM2.5 0.305 tons per day and 110 tons per rolling 12-month period C. SO2 1.05 tons per day (tpd) and 383.3 tons per rolling 12-month period D. NOx 2.1 tons per day (tpd) and 766.5 tons per rolling 12-month period. [SIP Section IX.H.12, SIP Section IX.H.2] 14 II.B.1a.1 Compliance shall be demonstrated as outlined in SIP Section IX.H.2.d and Section IX.H.12.d. [SIP Section IX.H.12, SIP Section IX.H.2] Status: In compliance – Emissions for the following source wide pollutants, for the 12-month period May 2024 – April 2025: Pollutant Emission Limits (Tons Per Day) Emission Limits (Tons Per 12- Month Period) Actual Emissions (Tons Per Day) Actual; Emissions (Tons Per 12- Month Period) PM10 0.715 No Limit 0.14 No Limit PM2.5 0.305 110 0.08 40.7 SO2 1.05 383.3 0.05 40.8 NOx 2.1 766.5 0.56 237.0 Note: See status of conditions II.B.1.f, II.B.1.g, II.B.1.h, and II.B.1.i in inspection memo (4 of 4). II.B.2 Conditions on Tank and Wastewater Process II.B.2.a The owner/operator shall operate the wastewater installation in accordance with the requirements of 40 CFR 61, Subpart FF. [40 CFR 61] Status: In compliance – The required Quarterly Benzene Waste Operations NESHAP (BWON) reports and Total Annual Benzene (TAB) reports are submitted as required. The last Quarterly BWON report, for the 4th quarter of 2024, was received on January 30, 2025. The 2024 TAB report, dated April 2, 2025, was received April 7, 2025. See Chevron Inspection Memo (3 of 4). II.B.2.b The owner/operator shall not exceed a throughput feed rate of 3,000 gpm of process wastewater through the dissolved nitrogen flotation system. [R307-401-8] II.B.2.b.1 Compliance shall be demonstrated through a flow meter and recorded in operator logs. [R307-401-8] Status: In compliance – The two dissolved nitrogen flotation (DNF) units were installed and commenced operation in April of 2025. Flow meter readings are electronically recorded using Data Historian (Dashboard), which provides real time continuous readings of the flow meter. According to the dashboard the flow meter had a reading of 900 gallon per minute (gpm) at time of the inspection. See status of condition II.A. II.B.2.c The following storage vessels/tanks are subject to specific federal regulations, which are listed here for convenience. The source must comply with the latest version of the CFR and applicable subparts. Tanks subject to 40 CFR 63, Subparts A and CC: 7514, 10095, 15093, 20017, 20018, 20019, 30020, 30021, 30022, 30024, 30091, 30092, 30096, 30097, 35110, 40075, 40076, 40100, 50078, 50079, 60059, 60077, 80115, 90116, and 90117. 15 Tanks subject to 40 CFR 60, Subparts A and Kb: 1512, 2111, 3350, 7513, 10094, 20017, 20018, 30024, 30092, 30096, 35110, 40100, 50078, 60077, 80115, 90116, 90117 and 7514 Tanks subject to 40 CFR 61, Subparts A and FF: 1511, 1512, 2111, 3350, 5038, 7513, 7514, 7539, 10094, 15103, 15104, 20015, 20016, 25108, 25109 and 30107 [40 CFR 60 Subpart CC, 40 CFR 61 Subpart FF, 40 CFR 63 Subpart A, R307-401] Status: In compliance – No unapproved tanks were noted at time of the inspection. See condition II.A and applicable sections below for evaluation of 40 CFR 60-63 requirements. II.B.3 Requirements on the Loading Rack II.B.3.a The owner/operator shall operate the crude oil loading rack in accordance with the requirements of 40 CFR 63 Subpart EEEE. The owner/operator shall limit VOC emissions from the crude oil loading rack to 10 milligrams per liter of crude oil. [40 CFR 63 Subpart EEEE, R307-401-8] II.B.3.a.1 Compliance with the VOC emission limit shall be demonstrated as outlined in 40 CFR 63.2354 and 63.2362. [40 CFR 63 Subpart EEEE] Status: In compliance – Additional rail loading rack controls are currently not required, according to semiannual checks. Loading documents are maintained in accordance with Subpart EEEE. II.B.3.b The owner/operator shall not exceed 10,000 bbls/day of total material loading in the loading rack. Materials include crude oil, desulfurized gas oil (DGO), vacuum gas oil (VGO) or naphtha. [R307-401-8] II.B.3.b.1 To demonstrate compliance with the daily limitation the owner/operator shall maintain a log of daily materials loaded. Records shall include the type and volume of material loaded. Records shall be kept for all periods when the plant is in operation. [R307-401-8] Status: In compliance – Railcar rack daily material loading is monitored by a flow meter. Flow meter readings are electronically recorded. Review of the records indicated that the above permitted limit has not been exceeded. 16 UAC R307-327 Petroleum Liquid Storage R307-327-4 General Requirements. (1) Any existing stationary storage tank, reservoir or other container with a capacity greater than 40,000 gallons (150,000 liters) that is used to store volatile petroleum liquids with a true vapor pressure greater than 10.5 kilo pascals (kPa) (1.52 psia) at storage temperature shall be fitted with control equipment that will minimize vapor loss to the atmosphere. Storage tanks, except those erected before January 1, 1979, which are equipped with external floating roofs, shall be fitted with an internal floating roof that shall rest on the surface of the liquid contents and shall be equipped with a closure seal or seals to close the space between the roof edge and the tank wall, or alternative equivalent controls, provided the design and effectiveness of such equipment is documented and submitted to and approved by the director. The owner or operator shall maintain a record of the type and maximum true vapor pressure of stored liquid. (2) The owner or operator of a petroleum liquid storage tank not subject to (1) above, but containing a petroleum liquid with a true vapor pressure greater than 7.0 kPa (1.0 psia), shall maintain records of the average monthly storage temperature, the type of liquid, throughput quantities, and the maximum true vapor pressure. Status: In compliance – This rule contains language considered by some to be ambiguous, and is being updated by DAQ’s rules section that is working with the engineering section. The three external floating roof tanks (T80115, T90116, T90117) have been approved by DAQ after this rule was enacted. The DAQ is currently working on a new Ozone Non-Attainment Tank Rule, which may replace UAC R3207-327. The new rule language is expected to clarify that these tanks approved after promulgation of this rule will not require this retrofitting. The remainder of the tanks at the Chevron refinery are in compliance with the requirements of UAC R307-327. R307-327-5 Installation and Maintenance. (1) The owner or operator shall ensure that all control equipment on storage vessels is properly installed and maintained. (a) There shall be no visible holes, tears or other openings in any seal or seal fabric and all openings, except stub drains, shall be equipped with covers, lids, or seals. (b) All openings in floating roof tanks, except for automatic bleeder vents, rim space vents, and leg sleeves, shall provide a projection below the liquid surface. (c) The openings shall be equipped with a cover, seal, or lid. (d) The cover, seal, or lid is to be in a closed position at all times except when the device is in actual use. (e) Automatic bleeder vents shall be closed at all times except when the roof is floated off or landed on the roof leg supports. Rim vents shall be set to open when the roof is being floated off the leg supports or at the manufacturer's recommended setting. (f) Any emergency roof drain shall be provided with a slotted membrane fabric cover or equivalent cover that covers at least 90 percent of the area of the opening. (2) The owner or operator shall conduct routine inspections from the top of the tank for external floating roofs or through roof hatches for internal floating roofs at six month or shorter intervals to insure there are no holes, tears, or other openings in the seal or seal fabric. (a) The cover must be uniformly floating on or above the liquid and there must be no visible defects in the surface of the cover or petroleum liquid accumulated on the cover. 17 (b) The seal(s) must be intact and uniformly in place around the circumference of the cover between the cover and tank wall. (3) A close visible inspection of the primary seal of an external floating roof is to be conducted at least once per year from the roof top unless such inspection requires detaching the secondary seal, which would result in damage to the seal system. (4) Whenever a tank is emptied and degassed for maintenance, an emergency, or any other similar purpose, a close visible inspection of the cover and seals shall be made. (5) The director must be notified 7 days prior to the refilling of a tank that has been emptied, degassed for maintenance, an emergency, or any other similar purpose. Any non-compliance with this rule must be corrected before the tank is refilled. Status: In compliance – Chevron conducts monthly and annual tank inspections. Monthly inspections are visual inspections of the seals. If problems are noted during the monthly inspections, semiannual reports are submitted to the DAQ. Annual inspections entail measuring and visually inspecting seals for gaps and tears. Probes are used to determine the size of gaps. All floating roof tanks, regardless of Federal Subpart applicability, are inspected. Anytime a tank is emptied and degassed, inspections are conducted and all needed repairs are made. Control devices have been installed as required. Annual Tank Inspection Reports are submitted as required. The last 2024 Tank Seal Inspection report, dated May 8, 2024, was received May 15, 2024. The 2025 Tank Seal Inspection report will be provided sometime in May of 2025. R307-327-6 Retrofits for Floating Roof Tanks. (1) Except where specifically exempted in (3) below, all existing external floating roof tanks with capacities greater than 950 barrels (40,000 gals) shall be retrofitted with a continuous secondary seal extending from the floating roof to the tank wall (a rim-mounted secondary seal) if: (a) The tank is a welded tank, the true vapor pressure of the contained liquid is 27.6 kPa (4.0 psia) or greater and the primary seal is one of the following: (i) A metallic type shoe seal, a liquid-mounted foam seal, a liquid-mounted liquid-filled seal, or (ii) Any other primary seals that can be demonstrated equivalent to the above primary seals. (b) The tank is a riveted tank, the true vapor pressure of the contained liquid is 10.5 kPa (1.5 psia) or greater, and the primary seal is as described in (a) above. (c) The tank is a welded or riveted tank, the true vapor pressure of the contained liquid is 10.5 kPa (1.5 psia) or greater and the primary seal is vapor-mounted. When such primary seal closure device can be demonstrated equivalent to the primary seals described in (a) above, these processes apply. (2) The owner or operator of a storage tank subject to this rule shall ensure that all the seal closure devices meet the following requirements: (a) There shall be no visible holes, tears, or other openings in the seals or seal fabric. (b) The seals must be intact and uniformly in place around the circumference of the floating roof between the floating roof and the tank wall. (c) For vapor mounted primary seals, the accumulated area of gaps between the secondary seal and the tank wall shall not exceed 21.2 cm2 per meter of tank diameter (1.0 in2 per ft. of tank diameter) and the width of any gap shall not exceed 1.27 cm (1/2 in.). The owner or operator shall measure the secondary seal gap annually and make a record of the measurement. (3) The following are specifically exempted from the requirements of (1) above: (a) External floating roof tanks having capacities less than 10,000 barrels (420,000 gals) used to store produced crude oil and condensate prior to custody transfer. (b) A metallic type shoe seal in a welded tank that has a secondary seal from the top of the shoe seal to the tank wall (a shoe mounted secondary seal). (c) External floating roof tanks storing waxy, heavy pour crudes. 18 (d) External floating roof tanks with a closure seal device or other devices installed that will control volatile organic compounds (VOC) emissions with an effectiveness equal to or greater than the seals required in (1) above. It shall be the responsibility of the owner or operator of the source to demonstrate the effectiveness of the alternative seals or devices to the director. No exemption under (3) shall be granted until the alternative seals or devices are approved by the director. Status: In compliance – All external floating roof tanks are equipped with mechanical shoe style primary seals and secondary wiper seals. R307-327-7 Alternate Methods of Control. (1) Any person may apply to the director for approval of an alternate test method, an alternate method of control, an alternate compliance period, an alternate emission limit, or an alternate monitoring schedule. The application must include a demonstration that the proposed alternate produces an equal or greater air quality benefit than that required by R307-327, or that the alternate test method is equivalent to that required by these rules. The director shall obtain concurrence from EPA when approving an alternate test method, an alternate method of control, an alternate compliance period, an alternate emission limit, or an alternate monitoring schedule. (2) Manufacturer's operational specifications, records, and testing of any control system shall use the applicable EPA Reference Methods of 40 CFR Part 60, the most recent EPA test methods, or EPA- approved state methods, to determine the efficiency of the control device. In addition, the owner or operator must meet the applicable requirements of record keeping for any control device. A record of all tests, monitoring, and inspections required by R307-327 shall be maintained by the owner or operator for a minimum of 2 years and shall be made available to the director or the director's representative upon request. Any malfunctioning control device shall be repaired within 15 calendar days after it is found by the owner or operator to be malfunctioning, unless otherwise approved by the director. (3) For purposes of determining compliance with emission limits, VOCs and nitrogen oxides will be measured by the test methods identified in federal regulation or approved by the director. Where such a method also inadvertently measures compounds with negligible photochemical reactivity, an owner or operator may exclude these negligibly reactive compounds when determining compliance with an emissions standard. Status: N/A – No alternate methods are used. R307-327-8 Compliance Schedule. All sources within any newly designated nonattainment area for ozone shall be in compliance with this rule within 180 days of the effective date of designation to nonattainment. Status: In compliance – The Chevron met the compliance deadline. 40 CFR 63 Subpart CC – National Emission Standards for Hazardous Air Pollutants From Petroleum Refineries 63.640 Applicability and designation of effected source. Status: In compliance – Chevron meets the most stringent standards for all tanks. 40 CFR 60 Subpart Kb – Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after July 23, 1984 19 60.110b Applicability and designation of affected facility. Status: In compliance – See information below, regarding Subpart Kb. 60.112b Standard for volatile organic compounds (VOC). Status: In compliance – All external floating roof tanks have primary and secondary seals. The primary seals are mechanical shoe seals and the secondary seals are rim mounted wipers or double wipers. All openings are kept closed with lids at all times except when in use, and have a projection below the liquid surface. Filling, emptying, or refilling is continuous and accomplished as rapidly as possible. According to Chevron, vapor pressures of all materials in NSPS Kb tanks were less than 11 psi (76.6 kPa). The tanks are set to alarm prior to the roof sitting on its legs. The legs are only extended for maintenance purposes. 60.113b Testing and procedures. Status: In compliance – Records show that Chevron measures and inspects primary seals for gaps and tears annually, on all floating roof tanks regardless of applicability of the various regulations. Secondary seals are visually inspected monthly. Probes are used to determine the size of gaps. All repairs required on the seals have been made within the 45 day time limit, unless an extension has been granted. Any time a tank is emptied and degassed, inspections are conducted and all needed repairs are made. 60.115b Reporting and record keeping requirements. Status: In compliance – Chevron keeps records and submits reports as required by this subpart. Annual Tank Seal Inspection reports, Tank Degas notices, and Tank Refilling notices are submitted as required. 60.116b Monitoring of operations. Status: In compliance – Records are maintained for the required 2 year period. Records of vessel dimensions and capacity are maintained in each tank file. The internal monthly inventory report shows the stock being stored. The vapor pressure is determined by the maximum expected storage temperatures, throughput, ambient temperature, and specific gravity. 20 EMISSION INVENTORY: Chevron Product Company’s 2024 annual emission inventory was received, by the DAQ, on April 9, 2025. PREVIOUS ENFORCEMENT ACTION: None within the previous five years. COMPLIANCE STATUS & RECOMMENDATIONS: Chevron Products Company should be considered to be in compliance with AO DAQE-AN101190104-22, dated September 26, 2022. Also, the tank requirements under UAC R307-327, 40 CFR 63 Subpart CC, 40 CFR 60 Subpart Kb, and 40 CFR 61 Subpart FF at the time of this inspection. HPV STATUS: N/A COMPIANCE ASSISTANCE: None RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual. ATTACHMENT: VEO Form Construction Status Correspondence Joe Rockwell <jrockwell@utah.gov> Chevron WWTP DNF Construction Update Notice 4 messages Vander Werff, Lauren <LVanderWerff@chevron.com>Fri, May 9, 2025 at 3:17 PM To: Joe Rockwell <jrockwell@utah.gov> Hi Joe, Just wanted to let you know that we are looking for the scanned copy of the WWTP DNF construction update notice. We did find the pre-signed version, which is attached. We also found the certified mail receipt indicating that it was delivered. However, we are having trouble finding the scanned copy in our files or in DAQ’s. We will keep looking. Just wanted to send you an update. Have a great weekend! Lauren Lauren Vander Werff (she/her) Environmental Team Lead LVanderWerff@chevron.com Salt Lake Refinery Chevron Products Company 685 South Chevron Way North Salt Lake, UT 84054 Tel +1 801 539 7386 Mobile +1 925 786 4911 saltlakecity.chevron.com 2024_03_14_WWTP Upgrades_Notice of Construction.doc 57K Joe Rockwell <jrockwell@utah.gov>Fri, May 9, 2025 at 3:29 PM To: "Vander Werff, Lauren" <LVanderWerff@chevron.com> Hi Lauren - 5/12/25, 12:49 PM State of Utah Mail - Chevron WWTP DNF Construction Update Notice https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1831679255263951116&simpl=msg-f:183167925526395111…1/3 You can send me a copy of the certified mail receipt, if you cannot find the scanned copy. That should work. You have a great weekend as will! Thanks Lauren, Joe Rockwell | Environmental Scientist Phone: 385-226-3738 195 North 1950 West, Salt Lake City, UT 84116 Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] Vander Werff, Lauren <LVanderWerff@chevron.com>Mon, May 12, 2025 at 9:59 AM To: Joe Rockwell <jrockwell@utah.gov> Hi Joe, Hope you had a good weekend. Here’s the certified mail slip. Thanks! Lauren From: Joe Rockwell <jrockwell@utah.gov> Sent: Friday, May 9, 2025 3:30 PM To: Vander Werff, Lauren <LVanderWerff@chevron.com> Subject: [**EXTERNAL**] Re: Chevron WWTP DNF Construcon Update Noce Be aware this external email contains an attachment and/or link. Ensure the email and contents are expected. If there are concerns, please submit suspicious messages to the Cyber Intelligence Center using the Report Phishing button. Hi Lauren - 5/12/25, 12:49 PM State of Utah Mail - Chevron WWTP DNF Construction Update Notice https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1831679255263951116&simpl=msg-f:183167925526395111…2/3 You can send me a copy of the certified mail receipt, if you cannot find the scanned copy. That should work. You have a great weekend as will! Thanks Lauren, Joe Rockwell | Environmental Scientist Phone: 385-226-3738 195 North 1950 West, Salt Lake City, UT 84116 Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] 2024.03.14 WWTP DNF UPGRADE NOTICE.pdf 221K Joe Rockwell <jrockwell@utah.gov>Mon, May 12, 2025 at 12:49 PM To: "Vander Werff, Lauren" <LVanderWerff@chevron.com> Thank You, Lauren. Joe Rockwell | Environmental Scientist Phone: 385-226-3738 195 North 1950 West, Salt Lake City, UT 84116 Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] 5/12/25, 12:49 PM State of Utah Mail - Chevron WWTP DNF Construction Update Notice https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1831679255263951116&simpl=msg-f:183167925526395111…3/3