DAQ-2024-007281

^i\\9""!Y.Tesoro Refining &
Marketing Company LLC
March 21,2024
Utah Division of Air Quality
Bryce Bird, Director
Attn: Jeremy Marsigli, Harold Burge
195 N. 1950 West
Salt Lake City, Utah 84114-4820
Update to Schedule of Completion of Corrective Actions and Interim Mitigation
Measures Identified in Self-Disclosure Pursuant to the Utah Environmental Self-
Evaluation Act Regarding Compliance with 40 CFR Part 60, Subpart QQQ for API
Oil Water Separator and Tank 241
Dear Mr. Bird,
As a follow up to Tesoro Refining & Marketing Company LLC's ("Tesoro") August 6,2019 Voluntary
Disclosure pursuant to the Utah Environmental Self-Evaluation Act (the "Voluntary Disclosure") and
Tesoro's October 20,2020letter describing Tesoro's agreement to undertake the necessary corrective actions
and interim mitigation measures to ensure compliance with 40 CFR Part 60, Subpart QQQ NSPS QQQ for
the API Oil Water Separator (API OWS) and Tank 241, as set forth in the Voluntary Disclosure, Tesoro is
providing this annual update on the status of completion of the corrective actions and mitigation measures.
Following is a description of the implementation progress achieved to date for the interim mitigation
measures and corrective actions that Tesoro previously committed to in its October 20,2020letter to resolve
the findings of the August 6,2019 Voluntary Disclosure and ensure compliance with NSPS QQQ. The
previous annual update was provided on December27,2022.
Tank 241
Proposed:
Corrective Actions.
Tesoro plans to fully replace Tank24l with a new tank ("New Tank") for the collection of stormwater and
oily process water. The New Tank will have a shell capacity of approximately 100,000 barrels and will be
designed to have an internal floating roof. Tesoro currently plans to have new Tar/r.241constructed and in
service by March 31,2023.
Tesoro will provide written notification of completion to UDAQ within 30 days of commencing operation of
the New Tank.
Update:
Construction of new tank24l is complete and the tank was put into service on November 8,
2022. A written NSPS Subpart Kb startup notification was submitted to the Division on
November 1012022. This measure is complete.
-.ufl!r DEPAEmmtF
E}WIRONMENTAL O(JAI.IrY
tlAR 2 1 2024
DM&oN OF AR OUnrnv
Re:
B-2-10335
Eiryce'Bird
March 21,2024
Page2
Proposed:
Interim Measures.
As an interim measure, and during the design and construction of the New Tank, Tesoro committed to use
Tank242, previously storing hydrocarbon, in the place of Tank24l and use the tank for diversion and
temporary storage.
Update:
This interim measure is complete. Tank 242 was converted and placed into stormwater and
oily process water service on January 11,2021. Tank242 was taken out of oily water service
when new Tank 241 was commissioned.
API Oil Water Separator
Proposed:
Corrective Actions.
As we committed to in our August 6,2019 Voluntary Disclosure letter, Tesoro has completed a feasibility
phase engineering study to assess appropriate corrective actions to bring the API OWS into compliance with
NSPS Subpart aaQ. Through our engineering evaluation, Tesoro has selected to install a new above ground
API Oil Water Separator (OWS) to meet the compliance requirements of NSPS QQQ. The new API OWS
will be designed to process all process waters from all refinery process units. Based on the project schedule
for engineering, site preparation and construction, Tesoro currently anticipates placing the new above ground
API OWS in operation by no later than June 30,2025. This timeline takes into consideration design,
engineering and procurement considerations, including certain equipment requiring long leads, as well as
permitting requirements.
Tesoro will provide written notification of completion to UDAQ within 30 days of commencing operation of
the API OWS.
Update:
Tesoro achieved significant progress on the new API OWS projectin2023. Highlights includes
construction of a new refinery wash pad, demolition of the existing wash pad to provide plot
space for the new API OWS, completion of detailed design engineering, and procurement of all
major equipment. The API and mixing tank vessels are being fabricated offsite and scheduled
for delivery in June of 2024.In January 2024 foundation excavation was conducted. Current
construction activities include underground drain piping construction, catch basin installation,
and foundation installation. Second quarter 2024 activities will include structural steel and
aboveground piping installation.
Total project spend through 2023 has been approximately $21.1 million. Total project spend
through completion is forecast to be approximately $70 million and will include approximately
140,000 work hours.
On January 9,2024 Tesoro submitted a notification to UDAQ pursuant to R307-401-12 stating
the project will result in a reduction of pollutants including NOx, SOz, CO, PMz.s, HzS, VOC,
and NHr.
Proposed:
Interim Measures.
At the time of our August 6,2019 Voluntary Disclosure, the API basins had floating covers with single seals,
while the inlet flume and forebay had fixed covers that did not appear to meet the requirements of Subpart
aaa. As an interim measure, Tesoro installed floating covers with double wiper seal floating covers on the
API OWS in the third quarter of 2019.
Bryce Bird
March 21,2024
Page 3
As an additional interim measure, Tesoro committed to work with a specialty design engineering firm to
retrofit cracks, holes, and other gaps in the existing fixed covers on the forebay, API and associated sumps.
The purpose of this interim measure is to minimize fugitive emissions to the extent practicable during this
interim period. Tesoro previously reported this work would be completed by no later than June 30, 2021.
Update:
All of these interim measures were completed by May 13,2021. Tesoro currently conducts
routine inspections on the API and has updated its maintenance program to ensure the interim
measures remain effective to the extent practicable until the new API is installed.
UDAQ has requested that Tesoro commit to providing annual status updates going forward until the project
is completed. Tesoro will continue to provide annual status updates.
It is important to recognize that the scheduled dates provided above are based on Tesoro's current, best
estimates; however, in view of the complexity of the work and the potential for disruptions, these dates may
change. In such event, Tesoro will provide an update to the schedule and an explanation forthe change.
Tesoro appreciates UDAQ's review of the information contained in this letter and requests that UDAQ
provide a response concurring with our progress and schedule.
Please do not hesitate to contact Chris Kaiser at 801 521-4959 or [e-mail] if you
have any questions or require further information regarding this matter in the meantime.
sinytv,
Y/"'-
Dean P. Anderson
Vice President
Tesoro Refining & Marketing Company LLC