DAQ-2024-007241

333 W. Center Street . North Salt Lake Utah 84054 . 801.296.7700 . www.bigwestoil.com
January 30,2024
CERTIFIED MAIL
RETTTRN RECETPT NO.7020 1290 000210949107
Bryce Bird, Director
Utah Division of Air Quality
Utah State Department of Environmental Quality
UTAH DEPAFTMENT OF
ENVIRONMENTAL OUAI.ITY
FEB - ? 2024
DIVISION OF AIR OUAUTV
195 North 1950 West
P.O. Box 144820
salt Lake city, utah 84114-4820
RE: 40 CF'R 63 Subpart UUU: Semi-Annual Report: July 1, 2023,to December 3112023
Dear Mr. Bird,
As required under 40 CFR Subpart LruU, $63.1575, Big West Oil LLC (BWO) hereby submits its Semi-
Arurual Report for the 2d Half of 2023 (July I - December 3l).
Certification 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.
,rrr't-l'*
Should you have any questions regarding this report or the data submitted, please feel free to contact me
at [phone] or ernail at [e-mail].
Sincerely,
Brady Miller
Environmental Engineer
CC: CERTIFIED MAIL
RBTURN RECEIPT NO. 7020 1290 00021094 9091
Director, Air and Toxics Technical Enforcement Program
Office of Enforcement, Compliance and Environmental Justice
Mail Code 8ENF-AT
1595 Wynkoop Street
Denver, CO 80202-1129
Mr. Jeremy Marsigli - UDAQ
Alec Klingho
B-2-10122
Catalytic Reforming Unit (CRII)
The CRU converts low-octane straight-run naphtha into a high-octane gasoline blendstock (reformate).
The CRU consists of three catalytic reactors that increase the octane of the stream through a
dehydrogenation process. Following the series of reactors, catalyst is collected for regeneration, which
involves a rechlorination step that creates the potential for hydrochloric acid (HCl) emissions. The CRU
process unit operated for 4,413 hours in the reporting period.
BWO operates a continuous CRU. Therefore, as specified in $63.1567(a)(l) and ltemZ of Table22 to
Subpart lrt U, BWO must meet inorganic HAP emission limits by reducing emissions of HCl by 97%by
weight or to a concentration of l0 ppmv (dry basis), corrected to 3o/o Oz. The requirement is met during
coke bum-off and catalyst rejuvenation by venting the process gases to a wet gas scrubber. As stated in
Item 1 of Table 23 to Subpart (rLIIJ, facilities using a wet scrubber as a control device are required to
maintain the daily average pH of the water exiting the scrubber and the daily average liquid-to-gas ratio
above the limits established during the performance test, which BWO performed in April2005.
Wet Gas Scrubber: Effluent pH
There were no deviations from the WGS effluent pH daily average operating limit of 5.54 pH units on a
daily basis during the reporting period. In accordance with $63.1575(d)(3), there was one monitoring
downtime event for this monitoring system.
Wet Gas Scrubber: Liquid-to-Gas Ratio
There were no deviations from the liquid+o-gas ratio daily average limit of 0.29 gpm/MSCFD on a daily
average basis during the reporting period. In accordance with $63.1575(d)(3), there were no monitoring
downtime events for this monitoring system.
Sulfur Recovery Unit (SRLI)
BWO operates a Claus SRU. The SRU processes the overhead gases from the Sour Water Stripper and
the mixture of acid gas from the Amine Unit. These gases are charged in a thermal reactor and a series of
three catalytic reactors to convert the HzS into elemental sulfur. The gases produced in the catalytic
reactor are sent to the SRU Tail Gas Incinerator, where the small amount of remaining I{zS and other
reduced sulfur species are converted to SOz before discharge to the atmosphere. A continuous emissions
monitoring system (CEMS) monitors the Oz within the incinerator stack and a continuous parameter
monitoring system (CPMS) continuously monitors the temperattire of the incinerator firebox to verify
complete combustion of the reduced sulfur species. The SRU operated for 4,412 hours in the reporting
period.
The SRU at BWO is not subject to either of the New Source Performance Standards (NSPS) for sulfur
oxides at 40 CFR 60 Subpart J or Ja. To comply with 40 CFR 63 Subpart LruU HAP emission limits,
BWO complies with the Total Reduced Sulfur (TRS) limit (Option 2) as specified in $63.1568(aXlXii)
and Item 3 of Table 29 to Subpart UUU. This election requires that BWO maintain emissions of TRS
Start Date
Start
Time End Date
End
Time Reason
81412023 l6:40 811012023 9:45
Monitor equipment malfunction. According to
Work Order #114394, BWO lnstrumentation
technicians replaced the monitor's transmitter to
resolve the issue.
compounds expressed as an equivalent SOz concentration at or below 300 ppmv on a dry basis at zero
percent oxygen. This ernission limit is complied with by maintaining the daily average combustion zone
temperature of the incinerator and the daily average oxygen (Oz) concentration in the vent stream at or
above the limits established during June 2005 performance testing.
SRU Incinerator Combustion Zone Temperature
There were no deviations from the combustion zone minimum temperature operating limit of 1l66oF on a
daily block average, calculated midnight to midnight. In accordance with $63.1575(d), there were no
monitoring downtime events for this monitoring system.
SRU Incinerator Exhaust Oz Concentration
There were no deviations from the vent stream minimum 02 concentration operating limit ot35% (dry
basis) on a daily block average, calculated midnight to midnight.
Incinerator Alternative Standard: Oz Concentration and Temperature
Per 963.1568(a)(a)(iii), BWO may alternatively comply with 40 CFR 63 Subpart UUU during periods of
startup and shutdown by maintaining the hourly average firebox temperature of the incinerator at or above
1200"F and the hourly average outlet Oz concentration at or above 2% (dry basis). During the current
reporting period, the SRU complied with the default combustion zone temperature and exhaust Oz limits;
therefore, the altemative standards for stack 02 concentration and firebox temperature were not
utilized. There were no deviations from the standard.
Millisecond Catalytic Cracking Unit (MSCC)
The MSCC reactor breaks up heavy hydrocarbon molecules into smaller molecules to produce marketable
products. This cracking process takes place on the surface of a circulating, powdered catalyst within the
fluidized bed-type MSCC reactor. The flue gas from the catalyst regeneration process consists primarily
of nitrogen, carbon dioxide, water, and oxygen with a lower concentration of pollutants. For MSCC Metal
HAP, a COMS is used for compliance demonstration. For organic HAP, a CO CEMS is used to evaluate
compliance with the emissions limit. The MSCC operated for 4,416 hours in the reporting period.
The MSCC at BWO is subject to the NSPS for particulate matter (PM) as specified in NSPS Subpart J.
Per $63.156a(aX1) and Item 1 of Table 1 to Subpart (rlru, BWO must comply withthe metal HAP
emission limits of Subpart UUU by complying with NSPS Subpart J and is subject to limits of 1.0 lb
PM/l,000 lb of coke bum-off and 30o/o opacity, except for one six-minute average opacity reading in any
one-hour period. Per $63.156a@)Q) and Item I of Table 2 to Subpart lIfU, a 3-hour rolling average
opacity no greater than}}%o must also be maintained. During periods of startup, shutdown, or hot
standby, BWO may, alternatively, elect to demonstrate compliance by utilizing the alternative standard
(i.e., maintain inlet velocity to primary internal cyclones of the MSCC regenerator at or above 20
ff/second) in accordance with $63. I 56a(a)(5xii).
For organic HAP compliance, the MSCC at BWO is subject to the NSPS for carbon monoxide (CO) as
specified in 40 CFR 60 Subpart J. Per $63.1565(a)(l) and Item I of Table 8 to Subpart LIIU, BWO must
comply with the organic HAP emission limits within Subpart ULIU by complying with 40 CFR 60
Subpart J; CO emissions from the MSCC must not exceed 500 parts per million by volume on a dry basis
(ppmvd). During periods of startup, shutdown, or hot standby, BWO may, altematively, elect to
demonstrate compliance by utilizing the alternative standard (i.e., maintain oxygen concentration in the
exhaust gas from the regenerator at or above I volo/o) in accordance with $63.1565(a)(5xii).
MSCC Opacity Limits and Alternative Standard
There were no deviations from the 6-minute opacity emission limit (i.e., opacity of emissions must not
exceed 30o/o, except for one 6-minute average opacity reading in any 1-hour period) during the reporting
period.
There were also no deviations from the 3-hr rolling average opacity operating parameter limit (i.e., above
20Yo on a 3-hour rolling average).
MSCC Coke Burn-Off
There were no deviations from the coke burn-off emission limit ( I .0 lb PM/ I 000 lb coke bumed
off). Details on performance testing for compliance evaluation against this limit are described in the final
section ofthis report.
MSCC CO Emissions and Alternative Standard
There were two deviations from the CO emission limit (i.e., above the hourly average standard of 500
ppm). In each case, the MSCC complied with the alternate organic HAP emission limit of startup,
shutdown, and hot standby (i.e., maintain Oz concentration in exhaust from the catalyst regenerator >1%o
vol, dry basis).
Since the unit complied with either the emission limit or altemate standard at all times, there were no
deviations from work practice standards for CO during this reporting period. Therefore, fuither details
regarding deviations as described in the reporting requirements of $63.1575(e) are not applicable.
CEMS & COMS Deviations and Downtime
Information related to monitor status for MSCC Opacity, MSCC CO, MSCC Oz, and SRU Oz
concentration are included within the State Electronic Data Reports (SEDR) that cover this reporting
period that were submitted to Mr. Rob Leishman of the Utah Department of Air Quality (UDAQ). In
accordance with $63.1575(c)$), $63.1575(e), and $63.1575(g), all information related to CEMS/COMS
unavailability and excess emissions not included within this report are included within those reports.
Note: T\e MSCC Regenerator Vent CO limit for MACT Subpart UUU is reported in the SEDR (500
ppmvd CO, uncorrected); therefore, any deviations from the MACT UUU limit are included in the SEDR
report. Also, the MSCC Flue Gas Opacity limit for MACT Subpart IJIIU (30% opacity over 6 minutes
and20Yo over 3-hour rolling average) differs from that which is reported in the SEDR (20o/o opacity over
6 minutes); therefore, any deviations from the MACT ULIU opacity limit are included in this report
above.
Date
Start
Time
End
Time
CO
Conc
(nnmvd)Description
Oz Conc.
(o/"1
Complied
with Alt.
std.?
7t20t2023 14:00 l5:00 839 MSCC Hot Standby 15.6 Yes
7t20t2023 l5:00 l6:00 918 MSCC Hot Standby 12.8 Yes
Performance Tests, Performance Evaluations, and Emission Standard Applicability
Forpurposes of $63.1575(D(1), BWO conducted a RATA on the SRU Oz on December 11,2023.1n
accordance with $63.1575(k)(2), the pertinent information will be submitted through the EPA's
Electronic Reporting Tool (ERT) within 60 days of completing the evaluation. The previous RATA on
the SRU Oz was performed on December 6,2022, and was submitted through the EPA's ERT on
February 9,2023.
BWO also conducted a performance test on the MSCC Flue Stack for PM emissions, including coke
burn-offrates, on December 15,2023.In accordance with $63.1575(k)(1), the pertinent information was
uploaded to the EPA's Electronic Reporting Tool (ERT) on January 24,2024, under the report name
"63.1575(K)(l) Results of the Perfornance Test." The previous performance test on the MSCC PM was
perfomred on October 30,2019, and was provided in historical reporting.
BWO previously conducted a RATA on the MSCC Flue Stack for Oz, COz, SOz, NOx, and CO on March
28, 2023. In accordance with $63.1575(k) (2), the pertinent information was submitted through the EPA's
ERT tool on May 5,2023.
In accordance with $63.1575(e)(13), there were no changes to the continuous emission monitoring
systems or continuous opacity monitoring systems, processes, or controls since the last reporting period.
UTAH DEPAFTT"IET':T OF
ENVTBONMENTAL QUALITY
;Ll:
DIVISION OF AIR OUALIT